NUREG-1943, Vol. 2 

Environmental Impact Statement 

for Combined Licenses (COLs) for 

Comanche Peak Nuclear Power Plant 

Units 3 and 4 

Final Report 

U.S. Nuclear Regulatory Commission 

Office of New Reactors 

Washington, DC 20555-0001 

U.S. Army Corps of Engineers 

U.S. Army Engineer District, Fort Worth 

Fort Worth, TX 76102-6199 
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(NUREGB0750).
 NUREG-1943, Vol. 2 

Environmental Impact Statement 

for Combined Licenses (COLs) for 

Comanche Peak Nuclear Power Plant 

Units 3 and 4 

Final Report 

Manuscript Completed: May 2011 

Date Published: May 2011 

Division of Site and Environmental Review 

Office of New Reactors 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 

Regulatory Branch 

Planning, Environmental, and Regulatory Division 

U.S. Army Engineer District, Fort Worth 

U.S. Army Corps of Engineers 

Fort Worth, TX 76102-6199 
Paperwork Reduction Act Statement 

This NUREG references information collection requirements that are subject to the Paperwork 

Reduction Act of 1995 (44 U.S.C. 3501 et seq.). These information collections were approved 

by the Office of Management and Budget, approval numbers 3150-0011; 3150-0021; and 3150-

0151. 

Public Protection Notification 

The NRC may not conduct or sponsor, and a person is not required to respond to, a request for 

information or an information collection requirement unless the requesting documents displays a 

currently valid OMB control number.

NUREG-1943, Volume 2, has been 

reproduced from the best available copy. 
May 2011 iii NUREG-1943 

Abstract 

This environmental impact statement (EIS) has been prepared to satisfy the requirements of the 

National Environmental Policy Act of 1969, as amended. This EIS has been prepared in 

response to an application submitted to the U.S. Nuclear Regulatory Commission (NRC) by 

Luminant Generation Company LLC (Luminant), acting for itself and as agent for Nuclear 

Project Company LLC (subsequently renamed Comanche Peak Nuclear Power Company LLC), 

for combined construction permits and operating licenses (combined licenses or COLs). The 

proposed actions related to the Luminant application are (1) NRC issuance of COLs for two new 

nuclear power reactor units (Units 3 and 4) at the Comanche Peak Nuclear Power Plant 

(CPNPP) site in Hood and Somervell Counties, Texas, and (2) U.S. Army Corps of Engineers 

(Corps) issuance of a permit to perform certain construction activities on the site. The Corps is 

participating with the NRC in preparing this EIS as a cooperating agency and participates 

collaboratively on the review team. 

This EIS includes the analysis by the NRC and Corps staff that considers and weighs the 

environmental impacts of building and operating two new nuclear units at the CPNPP site and at 

alternative sites, and mitigation measures available for reducing or avoiding adverse impacts. 

The EIS includes the evaluation of the proposed action’s impacts to waters of the United States 

pursuant to Section 404 of the Federal Water Pollution Control Act (Clean Water Act) and 

Section 10 of the Rivers and Harbors Appropriation Act of 1899. The Corps will conduct a 

public interest review in accordance with the guidelines promulgated by the U.S. Environmental 

Protection Agency under authority of Section 404(b) of the Clean Water Act. The public interest 

review, which will be addressed in the Corps’ permit decision document, will include an 

alternatives analysis to determine the Least Environmentally Damaging Practicable Alternative. 

After considering the environmental aspects of the proposed action, the NRC staff’s 

recommendation to the Commission is that the COLs be issued as requested. This 

recommendation is based on (1) the application, including the Environmental Report (ER) 

submitted by Luminant and Luminant’s responses to the NRC and Corps staff’s requests for 

additional information (RAIs); (2) consultation with Federal, State, Tribal, and local agencies; 

(3) the NRC and Corps staff’s independent review; (4) the NRC and Corps staff’s consideration 

of public comments; and (5) the assessments summarized in this EIS, including the potential 

mitigation measures identified in the ER and this EIS. The Corps permit decision will be made 

following issuance of the final EIS, and the Corps will issue its Record of Decision based, in 

part, on this EIS. 

May 2011 v NUREG-1943 

Contents 

Page 

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

Executive Summary .................................................................................................................... xxi

Abbreviations/Acronyms ........................................................................................................... xxiii 

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

1.1 Background ............................................................................................................. 1-1 

1.1.1 Application and Review ............................................................................... 1-2 

1.1.2 Preconstruction Activities ............................................................................ 1-4 

1.1.3 Cooperating Agencies ................................................................................. 1-4 

1.1.4 Concurrent NRC Reviews ........................................................................... 1-5 

1.2 The Proposed Federal Actions ................................................................................ 1-6 

1.3 The Purpose and Need for the Proposed Actions ................................................... 1-6 

1.4 Alternatives to the Proposed Actions ...................................................................... 1-6 

1.5 Compliance and Consultations ............................................................................... 1-7 

1.6 Report Contents ...................................................................................................... 1-8 

1.7 References .............................................................................................................. 1-8 

2.0 Affected Environment ....................................................................................................... 2-1 

2.1 Site Location ........................................................................................................... 2-1 

2.2 Land Use ................................................................................................................. 2-7 

2.2.1 The Site and Vicinity .................................................................................... 2-7 

2.2.2 Transmission Lines and Other Offsite Corridors ....................................... 2-10 

2.2.3 The Region ................................................................................................ 2-12 

2.3 Water ..................................................................................................................... 2-12 

2.3.1 Hydrology .................................................................................................. 2-12 

2.3.2 Water Use ................................................................................................. 2-20 

2.3.3 Water Quality ............................................................................................. 2-24 

2.3.4 Water Monitoring ....................................................................................... 2-28 

2.4 Ecology ................................................................................................................. 2-30 

2.4.1 Terrestrial Ecology .................................................................................... 2-32 

2.4.2 Aquatic Ecology ......................................................................................... 2-50 

2.5 Socioeconomics .................................................................................................... 2-77 

2.5.1 Demographics ........................................................................................... 2-78 

2.5.2 Community Characteristics ....................................................................... 2-82 

2.6 Environmental Justice ........................................................................................... 2-97 

2.6.1 Methodology .............................................................................................. 2-97 

2.6.2 Scoping and Outreach ............................................................................. 2-102 

2.6.3 Subsistence and Communities with Unique Characteristics ................... 2-102 

2.6.4 Migrant Populations ................................................................................. 2-103 

2.6.5 Environmental Justice Summary ............................................................. 2-103 
NUREG-1943 vi May 2011 

2.7 Historic and Cultural Resources .......................................................................... 2-103 

2.7.1 Cultural Background ................................................................................ 2-103 

2.7.2 Historic and Cultural Resources at the Site ............................................. 2-105 

2.7.3 Consultation ............................................................................................ 2-106 

2.8 Geology ............................................................................................................... 2-106 

2.9 Meteorology and Air Quality ................................................................................ 2-109 

2.9.1 Climate .................................................................................................... 2-109 

2.9.2 Air Quality ................................................................................................ 2-115 

2.9.3 Atmospheric Dispersion .......................................................................... 2-116 

2.9.4 Meteorological Monitoring ....................................................................... 2-119 

2.10 Nonradiological Health ........................................................................................ 2-119 

2.10.1 Public and Occupational Health .............................................................. 2-119 

2.10.2 Transportation ......................................................................................... 2-122 

2.10.3 Electromagnetic Fields ............................................................................ 2-122 

2.11 Radiological Environment or Monitoring ............................................................. 2-123 

2.12 Related Federal Projects and Consultations ....................................................... 2-123 

2.13 References .......................................................................................................... 2-124 

3.0 Site Layout and Plant Description .................................................................................... 3-1 

3.1 External Appearance and Plant Layout ................................................................... 3-1 

3.2 Proposed Plant Structures, Systems, and Components ......................................... 3-3 

3.2.1 Reactor Power Conversion System ............................................................ 3-3 

3.2.2 Structures with a Major Environmental Interface ......................................... 3-6 

3.3 Construction and Preconstruction Activities .......................................................... 3-16 

3.3.1 Site Preparation ......................................................................................... 3-17 

3.3.2 Power Block Construction ......................................................................... 3-26 

3.3.3 Transmission Lines ................................................................................... 3-27 

3.3.4 Construction Workforce ............................................................................. 3-28 

3.3.5 Summary of Resource Commitments during Construction and 

Preconstruction ......................................................................................... 3-30 

3.4 Operational Activities ............................................................................................ 3-30 

3.4.1 Description of Operational Modes ............................................................. 3-31 

3.4.2 Plant-Environment Interfaces during Operation ........................................ 3-31 

3.4.3 Radioactive Waste Management System ................................................. 3-35 

3.4.4 Nonradioactive Waste Systems ................................................................ 3-38 

3.4.5 Summary of Resource Parameters during Operation ............................... 3-41 

3.5 References ............................................................................................................ 3-42 

4.0 Construction Impacts at the Proposed Site ...................................................................... 4-1 

4.1 Land-Use Impacts ................................................................................................... 4-3 

4.1.1 The Site and Vicinity .................................................................................... 4-3 

4.1.2 Transmission Line and Pipeline Right(s)-of-Way and Offsite Areas ............ 4-4 

4.2 Water-Related Impacts ........................................................................................... 4-7 
May 2011 vii NUREG-1943 

4.2.1 Hydrological Alterations ............................................................................... 4-7 

4.2.2 Water Use Impacts ...................................................................................... 4-9 

4.2.3 Water Quality Impacts ............................................................................... 4-10 

4.2.4 Hydrological Monitoring ............................................................................. 4-11 

4.3 Ecological Impacts ................................................................................................ 4-11 

4.3.1 Terrestrial Impacts ..................................................................................... 4-11 

4.3.2 Aquatic Ecology and Wetlands Impacts Related to Construction and 

Preconstruction ......................................................................................... 4-26 

4.4 Socioeconomic Impacts ........................................................................................ 4-36 

4.4.1 Physical Impacts ....................................................................................... 4-36 

4.4.2 Demography .............................................................................................. 4-40 

4.4.3 Economic Impacts to the Community ........................................................ 4-42 

4.4.4 Infrastructure and Community Service Impacts ........................................ 4-46 

4.4.5 Potential Mitigation Measures for Socioeconomic Impacts ....................... 4-60 

4.4.6 Summary of Socioeconomic Impacts ........................................................ 4-60 

4.5 Environmental Justice Impacts ............................................................................. 4-61 

4.5.1 Health and Environmental Impacts ........................................................... 4-61 

4.5.2 Socioeconomic Impacts ............................................................................ 4-63 

4.5.3 Subsistence and Special Conditions ......................................................... 4-64 

4.5.4 Summary of Environmental Justice Impacts ............................................. 4-64 

4.6 Historic and Cultural Resources ............................................................................ 4-64 

4.7 Meteorological and Air Quality Impacts ................................................................. 4-65 

4.7.1 Construction and Preconstruction Activities .............................................. 4-66 

4.7.2 Transportation ........................................................................................... 4-67 

4.7.3 Summary ................................................................................................... 4-67 

4.8 Nonradiological Health Impacts ............................................................................ 4-68 

4.8.1 Public and Occupational Health ................................................................ 4-68 

4.8.2 Noise Impacts ............................................................................................ 4-70 

4.8.3 Transporting Construction Materials and Personnel to the CPNPP 

Site ............................................................................................................ 4-71 

4.8.4 Summary of Nonradiological Health Impacts ............................................ 4-72 

4.9 Radiological Exposure to Construction Workers ................................................... 4-72 

4.9.1 Direct Radiation Exposures ....................................................................... 4-73 

4.9.2 Radiation Exposures from Gaseous Effluents ........................................... 4-73 

4.9.3 Radiation Exposures from Liquid Effluents ............................................... 4-73 

4.9.4 Total Dose to Construction Workers ......................................................... 4-74 

4.9.5 Summary of Radiological Health Impacts ................................................. 4-74 

4.10 Nonradioactive Waste Impacts ............................................................................. 4-74 

4.10.1 Impacts to Land ......................................................................................... 4-74 

4.10.2 Impacts to Water ....................................................................................... 4-75 

4.10.3 Impacts to Air ............................................................................................ 4-75 
NUREG-1943 viii May 2011 

4.10.4 Summary of Impacts ................................................................................. 4-75 

4.11 Measures and Controls to Limit Adverse Impacts during Construction and 

Preconstruction Activities ...................................................................................... 4-76 

4.12 Summary of Construction Impacts ........................................................................ 4-76 

4.13 References ............................................................................................................ 4-82 

5.0 Operational Impacts at the Proposed Site ........................................................................ 5-1 

5.1 Land-Use Impacts ................................................................................................... 5-1 

5.1.1 The Site and Vicinity .................................................................................... 5-1 

5.1.2 Transmission Line and Pipeline Corridors ................................................... 5-6 

5.2 Water-Related Impacts ........................................................................................... 5-6 

5.2.1 Hydrological Alterations ............................................................................... 5-7 

5.2.2 Water-Use Impacts ...................................................................................... 5-7 

5.2.3 Water-Quality Impacts ............................................................................... 5-10 

5.2.4 Water Monitoring ....................................................................................... 5-15 

5.2.5 Potential Mitigation Measures for Operation-Related Water Impacts ....... 5-16 

5.3 Ecological Impacts ................................................................................................ 5-16 

5.3.1 Terrestrial Impacts Related to Operations ................................................. 5-16 

5.3.2 Aquatic and Wetlands Impacts .................................................................. 5-28 

5.4 Socioeconomic Impacts ........................................................................................ 5-48 

5.4.1 Physical Impacts ....................................................................................... 5-48 

5.4.2 Demography .............................................................................................. 5-52 

5.4.3 Economic Impacts to the Community ........................................................ 5-54 

5.4.4 Infrastructure and Community Services .................................................... 5-58 

5.4.5 Potential Mitigation Measures for Operation-Related Socioeconomic 

Impacts ...................................................................................................... 5-67 

5.4.6 Summary of Socioeconomic Impacts ........................................................ 5-67 

5.5 Environmental Justice Impacts ............................................................................. 5-67 

5.5.1 Health and Environmental Impacts ........................................................... 5-68 

5.5.2 Socioeconomic Impacts ............................................................................ 5-69 

5.5.3 Subsistence and Special Conditions ......................................................... 5-69 

5.5.4 Summary of Environmental Justice Impacts ............................................. 5-70 

5.6 Historic and Cultural Resource Impacts from Operation ....................................... 5-70 

5.7 Meteorological and Air Quality Impacts ................................................................. 5-71 

5.7.1 Air Quality Impacts .................................................................................... 5-71 

5.7.2 Cooling System Impacts ............................................................................ 5-72 

5.7.3 Summary ................................................................................................... 5-73 

5.8 Nonradiological Health Impacts ............................................................................ 5-73 

5.8.1 Etiologic Agents ......................................................................................... 5-73 

5.8.2 Noise ......................................................................................................... 5-75 

5.8.3 Acute Effects of Electromagnetic Fields .................................................... 5-77 

5.8.4 Chronic Effects of Electromagnetic Fields ................................................. 5-78 
May 2011 ix NUREG-1943 

5.8.5 Occupational Health .................................................................................. 5-78 

5.8.6 Impacts of Transporting Operations Personnel and Waste Salt ............... 5-80 

5.8.7 Summary of Nonradiological Health Impacts ............................................ 5-80 

5.9 Radiological Impacts of Normal Operations .......................................................... 5-82 

5.9.1 Exposure Pathways ................................................................................... 5-82 

5.9.2 Radiation Doses to Members of the Public ............................................... 5-85 

5.9.3 Impacts to Members of the Public ............................................................. 5-88 

5.9.4 Occupational Doses to Workers ................................................................ 5-90 

5.9.5 Dose to Biota Other Than Humans ........................................................... 5-90 

5.9.6 Radiological Monitoring ............................................................................. 5-92 

5.10 Nonradioactive Waste Impacts ............................................................................. 5-93 

5.10.1 Impacts to Land ......................................................................................... 5-93 

5.10.2 Impacts to Water ....................................................................................... 5-94 

5.10.3 Impacts to Air ............................................................................................ 5-95 

5.10.4 Mixed Waste Impacts ................................................................................ 5-95 

5.10.5 Summary of Waste Impacts ...................................................................... 5-95 

5.11 Environmental Impacts of Postulated Accidents ................................................... 5-96 

5.11.1 Design Basis Accidents ............................................................................. 5-97 

5.11.2 Severe Accidents .................................................................................... 5-100 

5.11.3 Severe Accident Mitigation Alternatives .................................................. 5-109 

5.11.4 Summary of Postulated Accident Impacts ............................................... 5-110 

5.12 Measures and Controls to Limit Adverse Impacts During Operation .................. 5-111 

5.13 Summary of Operational Impacts ........................................................................ 5-111 

5.14 References .......................................................................................................... 5-125 

6.0 Fuel Cycle, Transportation, and Decommissioning .......................................................... 6-1 

6.1 Fuel Cycle Impacts and Solid Waste Management ................................................ 6-1 

6.1.1 Land Use ..................................................................................................... 6-7 

6.1.2 Water Use ................................................................................................... 6-8 

6.1.3 Fossil Fuel Impacts ..................................................................................... 6-8 

6.1.4 Chemical Effluents ...................................................................................... 6-9 

6.1.5 Radiological Effluents .................................................................................. 6-9 

6.1.6 Radiological Wastes .................................................................................. 6-12 

6.1.7 Occupational Dose .................................................................................... 6-13 

6.1.8 Transportation ........................................................................................... 6-13 

6.1.9 Conclusions ............................................................................................... 6-14 

6.2 Transportation Impacts ......................................................................................... 6-14 

6.2.1 Transportation of Unirradiated Fuel ........................................................... 6-15 

6.2.2 Transportation of Spent Fuel ..................................................................... 6-22 

6.2.3 Transportation of Radioactive Waste ........................................................ 6-31 

6.2.4 Conclusions ............................................................................................... 6-32 

6.3 Decommissioning Impacts .................................................................................... 6-33 
NUREG-1943 x May 2011 

6.4 References ............................................................................................................ 6-34 

7.0 Cumulative Impacts .......................................................................................................... 7-1 

7.1 Land Use ................................................................................................................. 7-2 

7.2 Water Use and Quality ............................................................................................ 7-8 

7.2.1 Water-Use Impacts ...................................................................................... 7-8 

7.2.2 Water-Quality Impacts ............................................................................... 7-11 

7.3 Ecology ................................................................................................................. 7-14 

7.3.1 Terrestrial Ecology .................................................................................... 7-14 

7.3.2 Aquatic Ecosystem and Wetlands Impacts ............................................... 7-18 

7.4 Socioeconomics and Environmental Justice ......................................................... 7-23 

7.4.1 Socioeconomics ........................................................................................ 7-23 

7.4.2 Environmental Justice ............................................................................... 7-24 

7.5 Historic and Cultural Resources ............................................................................ 7-25 

7.6 Air Quality .............................................................................................................. 7-26 

7.6.1 Criteria Pollutants ...................................................................................... 7-26 

7.6.2 Greenhouse Gas Emissions ...................................................................... 7-27 

7.6.3 Summary ................................................................................................... 7-28 

7.7 Nonradiological Health .......................................................................................... 7-28 

7.8 Radiological Impacts of Normal Operation ............................................................ 7-30 

7.9 Postulated Accidents ............................................................................................. 7-31 

7.10 Fuel Cycle, Transportation, and Decommissioning ............................................... 7-32 

7.10.1 Fuel Cycle ................................................................................................. 7-32 

7.10.2 Transportation ........................................................................................... 7-32 

7.10.3 Decommissioning ...................................................................................... 7-33 

7.11 Conclusions and Recommendations ..................................................................... 7-34 

7.12 References ............................................................................................................ 7-36 

8.0 Need for Power ................................................................................................................. 8-1 

8.1 Description of Power System .................................................................................. 8-3 

8.1.1 The Applicant .............................................................................................. 8-3 

8.1.2 The Restructured Texas Utility Industry ...................................................... 8-4 

8.1.3 The Role of Market Forces in the Restructured System ............................. 8-5 

8.1.4 ERCOT Load Forecasting Process ............................................................. 8-5 

8.2 Power Demand ..................................................................................................... 8-14 

8.2.1 Peak Load Demand for Power .................................................................. 8-14 

8.2.2 Potential Reductions to ERCOT Peak Load Forecasts due to 

Conservation ............................................................................................. 8-15 

8.3 Power Supply ........................................................................................................ 8-16 

8.3.1 Generating Capacity Analysis and Planning ............................................. 8-16 

8.3.2 ERCOT Future Generation ........................................................................ 8-19 

8.3.3 Reserve Margin ......................................................................................... 8-19 

8.4 Assessment of Need for Power ............................................................................. 8-20 
May 2011 xi NUREG-1943 

8.4.1 Need for Power Analysis ........................................................................... 8-21 

8.4.2 Sensitivity Analysis .................................................................................... 8-21 

8.4.3 Summary and Conclusions ....................................................................... 8-24 

8.5 NRC Staff Conclusions ......................................................................................... 8-25 

8.6 References ............................................................................................................ 8-26 

9.0 Environmental Impacts of Alternatives ............................................................................. 9-1 

9.1 No-Action Alternative .............................................................................................. 9-2 

9.2 Energy Alternatives ................................................................................................. 9-3 

9.2.1 Alternatives Not Requiring New Generation Capacity ................................. 9-3 

9.2.2 Alternatives Requiring New Generation Capacity ....................................... 9-6 

9.2.3 Other Alternatives ...................................................................................... 9-19 

9.2.4 Combination of Alternatives ...................................................................... 9-27 

9.2.5 Summary Comparison of Alternatives ....................................................... 9-29 

9.3 Alternative Sites .................................................................................................... 9-33

9.3.1 Site Selection Process .............................................................................. 9-33 

9.3.2 The Coastal Site ........................................................................................ 9-38 

9.3.3 The Pineland Site ...................................................................................... 9-66 

9.3.4 The Tradinghouse Site .............................................................................. 9-92 

9.3.5 Comparison of the Impacts of the Proposed Action and Alternative 

Sites ........................................................................................................ 9-115 

9.4 System Design Alternatives ................................................................................ 9-120 

9.4.1 Heat Dissipation Systems ....................................................................... 9-120 

9.4.2 Circulating Water System ........................................................................ 9-124 

9.4.3 Conclusion ............................................................................................... 9-128 

9.5 References .......................................................................................................... 9-129

10.0 Conclusions and Recommendations .............................................................................. 10-1 

10.1 Impacts of the Proposed Action ............................................................................ 10-2 

10.2 Unavoidable Adverse Environmental Impacts ...................................................... 10-3 

10.2.1 Unavoidable Adverse Impacts during Construction and 

Preconstruction ......................................................................................... 10-3 

10.2.2 Unavoidable Adverse Impacts during Operation ....................................... 10-7 

10.3 Relationship Between Short-Term Uses and Long-Term Productivity of the 

Human Environment ............................................................................................. 10-8 

10.4 Irreversible and Irretrievable Commitments of Resources .................................. 10-12 

10.4.1 Irreversible Commitments of Resources ................................................. 10-12 

10.4.2 Irretrievable Commitments of Resources ................................................ 10-13 

10.5 Alternatives to the Proposed Action .................................................................... 10-13 

10.6 Benefit-Cost Balance .......................................................................................... 10-14 

10.6.1 Benefits ................................................................................................... 10-15 

10.6.2 Costs ....................................................................................................... 10-21 

10.6.3 Summary of Benefits and Costs .............................................................. 10-24 

10.7 Staff Conclusions and Recommendations .......................................................... 10-25 
NUREG-1943 xii May 2011 

10.8 References .......................................................................................................... 10-25 

Appendix A Contributors to the Environmental Impact Statement ........................................ A-1 

Appendix B Organizations Contacted ................................................................................... B-1 

Appendix C Chronology of the Nuclear Regulatory Commission and the U.S. Army 

Corps of Engineers Staff Environmental Review Correspondence Related 

to Luminant Generation Company LLC, Application for Combined 

Licenses at the Comanche Peak Nuclear Power Plant Site .............................. C-1 

Appendix D Scoping Comments and Responses ................................................................. D-1 

Appendix E Draft Environmental Impact Statement Comments and Responses ................. E-1 

Appendix F Key Consultation Correspondence Regarding the Comanche Peak 

Nuclear Power Plant, Units 3 and 4, Combined Licenses Application ............... F-1 

Appendix G Supporting Information and Data: Population Projections and Health 

Physics .............................................................................................................. G-1 

Appendix H List of Authorizations, Permits, and Certifications ............................................. H-1 

Appendix I Severe Accident Mitigation Alternatives .............................................................. I-1 

Appendix J Carbon Dioxide Footprint Estimates for a 1000 MW(e) Light Water 

Reactor (LWR) ................................................................................................... J-1 
May 2011 xiii NUREG-1943 

Figures 

Figure Page 

2-1 50-mi Regional Location of the CPNPP Site .................................................................... 2-2 

2-2 Location of the CPNPP Site Within Hood and Somervell Counties, Texas ...................... 2-3 

2-3 The Site Plan for CPNPP Units 3 and 4 ........................................................................... 2-4 

2-4 Location of Proposed CPNPP Units 3 and 4 in Relation to Existing Units 1 and 2 

on the CPNPP Site ........................................................................................................... 2-5 

2-5 Existing and Proposed Water Pipelines from Lake Granbury to the CPNPP Site ............ 2-6 

2-6 Land Use on CPNPP Site ................................................................................................. 2-8 

2-7 Land Use Features in Project Vicinity ............................................................................... 2-9 

2-8 Vicinity Land Use ............................................................................................................ 2-11 

2-9 Federal Lands Within the CPNPP Region ...................................................................... 2-13 

2-10 Regional Land Use ......................................................................................................... 2-14 

2-11 Predominant Surface-water Hydrologic Features of the CPNPP Site Area, 

Including Locations of Gauging Stations ........................................................................ 2-16 

2-12 Map of the Middle Brazos River Watershed, Including Locations of Possum 

Kingdom Lake (Reservoir), Lake Granbury, Lake Whitney, and Several Other 

Brazos River Reservoirs ................................................................................................. 2-17 

2-13 Existing and Proposed Transmission Line ROWs and Pipeline Routes ......................... 2-31 

2-14 Ecological Cover Type Vegetation Map ......................................................................... 2-35 

2-15 Vegetative Cover of the CPNPP Site ............................................................................. 2-65 

2-16 Squaw Creek Reservoir Wetland Delineation. ............................................................... 2-68 

2-17 Locations of the Contributors to Transient Populations in the Region ............................ 2-81 

2-18 Road and Highway System in Somervell and Hood Counties ........................................ 2-90 

2-19 Census Block Groups with Minority Populations Within a 50-mi Radius of CPNPP 

Units 3 and 4 ................................................................................................................ 2-100 

2-20 Census Block Groups with Low-Income Populations Within a 50-mi Radius of 

CPNPP Units 3 and 4 ................................................................................................... 2-101 

2-21 Physiographic Map of Texas. ....................................................................................... 2-107 

2-22 Bedrock Stratigraphic Column for the CPNPP Site Area ............................................. 2-108 

2-23 Geologic Map of the Region Within 25 mi of the CPNPP Site ...................................... 2-110 

2-24 Active Gas Wells in the Vicinity of the CPNPP Site and Production Volumes .............. 2-111 

3-1 Photograph of Existing CPNPP Units 1 and 2, with an Artist’s Conception of the 

Proposed Units 3 and 4 on the Left-Hand Side of the Photograph .................................. 3-2 

3-2 Simplified Flow Diagram for the CPNPP Reactor Power Conversion System ................. 3-4 

3-3 Simplified Water Use Diagram for CPNPP Units 3 and 4 ................................................. 3-7 

3-4 Mass Balance for Blowdown Treatment Facility (BDTF) when Lake Granbury Total 

Dissolved Solids (TDS) and Chloride Concentrations are High. .................................... 3-13 

3-5 Oncor Transmission Line Towers with Vacant Circuit Positions .................................... 3-15 

3-6 Detailed Site Plan Showing Construction Laydown Areas ............................................. 3-19 

3-7 Proposed Makeup Water Intake Structure on Lake Granbury (Cross Section) .............. 3-24 

3-8 Blowdown Water System Discharge Diffuser as Proposed for Construction in Lake 

Granbury ....................................................................................................................... 3-25 

4-1 Potentiometric Map Showing Groundwater Isopleths and Flow Directions Beneath 

the CPNPP Site .............................................................................................................. 4-12 
NUREG-1943 xiv May 2011 

4-2 Ecological Cover Types Within Development Footprint ................................................. 4-13 

5-1 Schematic Layout of the Proposed Blowdown Treatment Facility Showing 

Distances from the Misters to Nearby Locations. ............................................................. 5-3 

5-2 Exposure Pathways to Man ............................................................................................ 5-83 

5-3 Exposure Pathways to Biota Other than Man ................................................................. 5-84 

6-1 The Uranium Fuel Cycle: No-Recycle Option .................................................................. 6-5 

6-2 Illustration of Truck Stop Model ...................................................................................... 6-24 

8-1 Electric Reliability Council of Texas Region. .................................................................... 8-1 

8-2 ERCOT Historical Load versus System Peak Load Growth ............................................. 8-7 

8-3 ERCOT Forecasted Average Load versus System Peak Growth .................................... 8-8 

8-4 Weather Zones ................................................................................................................. 8-9 

8-5 The Forecasting Process ................................................................................................ 8-10 

8-6 Historical and Base Forecast Hourly Peak Demand, Temperature Uncertainty 

Scenario ......................................................................................................................... 8-11 

8-7 Comparison of 2009 and 2010 Forecast of Hourly System Peak Demand .................... 8-12 

9-1 Map Showing the Locations of Luminant’s Alternative Sites .......................................... 9-36 
May 2011 xv NUREG-1943 

Tables 

Table Page 

2-1 Surface Water Withdrawals in the Vicinity of the CPNPP Site in 2006 .......................... 2-22 

2-2 Chemical Analysis of Surface Water Samples Collected in Lake Granbury Near 

DeCordova Dam, January 2001 Through September 2006 

11860—Lake Granbury DeCordova Dam (01/01–09/06) ............................................... 2-26 

2-3 TPDES-Permitted Discharges to Lake Granbury and the Brazos River Below 

Lake Granbury ................................................................................................................ 2-27 

2-4 Range of Concentrations of Chemical Constituents in Water Samples Collected in 

Lake Granbury and Other Monitoring Stations in the Brazos and Paluxy Rivers ........... 2-29 

2-5 Species Characterizing the Silver Bluestem – Texas Wintergrass Grassland Cover 

Type ................................................................................................................................ 2-33 

2-6 Species Characterizing the Oak-Mesquite-Juniper Savanna and Woodlands Cover 

Type ................................................................................................................................ 2-33 

2-7 Distribution of Cover Types and Acreage Totals at CPNPP ........................................... 2-36 

2-8 Water-Dependent Bird Species Observed at CPNPP in 2007 ....................................... 2-38 

2-9 Upland Game Birds, Birds of Prey, and Woodpeckers Observed at CPNPP in 2007 .... 2-38 

2-10 Ecologically Oriented Public Recreation Areas Within a 50-mi Radius of CPNPP ......... 2-41 

2-11 Acreages of Vegetation Types that Would Be Crossed by Expanded Existing 

Transmission Lines on Existing Towers ......................................................................... 2-42 

2-12 Pipeline Corridor Land Use and Cover Types ................................................................ 2-43 

2-13 Threatened, Endangered, or Rare Terrestrial Plant and Animal Species Listed 

in Somervell, Hood, and Bosque Counties ..................................................................... 2-45 

2-14 Fish Numbers and Catch Rates from TPWD Surveys of Lake Granbury ....................... 2-55 

2-15 Fish Species Occurring in Lake Granbury ...................................................................... 2-56 

2-16 Fish Species Occurring in Squaw Creek Reservoir ........................................................ 2-58 

2-17 Fish Species Potentially Occurring in the Brazos River Between Lake Granbury 

and Lake Whitney ........................................................................................................... 2-62 

2-18 Federally and State-Listed Aquatic Species Occurring in the Vicinity of Proposed 

CPNPP Units 3 and 4 and Proposed New 345-kV Transmission Line ROWs ............... 2-72 

2-19 Counties Entirely or Partially Located Within the 50-mi CPNPP Region ........................ 2-78 

2-20 Population and Percent Population Change in the EIA and the State of Texas 

(1970–2040) ................................................................................................................... 2-79 

2-21 Annual Average Labor Force, Employment, and Unemployment in the EIA and the 

State of Texas (2008) ..................................................................................................... 2-82 

2-22 Total Non-Farm Employment by Industry Type in the EIA (2007) .................................. 2-84 

2-23 Place of Residence for CPNPP Units 1 and 2 Workers ................................................. 2-86 

2-24 Total Personal and per Capita Income in the EIA and the State of Texas (2007) .......... 2-86 

2-25 Property Tax Rates and Revenues in Somervell and Hood Counties (2007) ................ 2-88 

2-26 Ad Valorem Taxes Paid by CPNPP Units 1 and 2 (2006) .............................................. 2-88 

2-27 Housing Data for the EIA (2000 or 2007) ....................................................................... 2-89 

2-28 Housing Data for Glen Rose, Granbury, Pecan Plantation CDP, and Tolar (2000) ....... 2-93 

2-29 Minority and Low-Income Population as a Percent of Total Population Within 50-mi 

of CPNPP and for the State of Texas (2000) ............................................................... 2-102 

2-30 Expected Maximum Tornado Wind Speeds and Upper Limits ..................................... 2-114 
NUREG-1943 xvi May 2011 

2-31 Emissions and Operations Limits Associated with CPNNP Units 1 and 2 ................... 2-116 

2-32 CPNPP Short-Term Atmospheric Dispersion Estimates for Accident Releases .......... 2-118 

3-1 Heat Transfer to the Environment for Six Operating Modes ............................................. 3-8 

3-2 Water Withdrawn and Discharged per Unit for Six Operating Modes............................... 3-9 

3-3 Chemicals that Would be Added to the ESWS and 

CWS of CPNPP Units 3 and 4 ........................................................................................ 3-10 

3-4 Descriptions and Examples of Building Activities for CPNPP Units 3 and 4 .................. 3-18 

3-5 Schedule for Construction of CPNPP Units 3 and 4 ....................................................... 3-19 

3-6 Total Workforce by Craft for Construction of CPNPP Units 3 and 4 ............................... 3-29 

3-7 Expected Numbers of Onsite Workers by Year for Construction of CPNPP Units 3 

and 4 ............................................................................................................................... 3-29 

3-8 Summary of Resource Commitments Associated with Building CPNPP Units 3 and 

4 ...................................................................................................................................... 3-30 

3-9 Average Annual Pollutant Emissions from CPNPP Unit 3 and 4 Stationary Fuel 

Burning Equipment ......................................................................................................... 3-40 

3-10 Parameters Associated with Operation of CPNPP Units 3 and 4 ................................... 3-41 

4-1 Acres of Habitat Types Before and After Construction and Preconstruction at the 

CPNPP Site that Would Be Affected by Development of Units 3 and 4 ......................... 4-14 

4-2 Terrestrial Habitat Present on CPNPP Site and Vicinity (6- mi Radius) ......................... 4-16 

4-3 Stream Crossings Within the 18-mi Segment of New ROW for the Whitney 

Transmission Line .......................................................................................................... 4-31 

4-4 Stream Crossings for the New Pipelines to be Installed in the Existing ROW 

Between CPNPP and Lake Granbury ............................................................................ 4-32 

4-5 Total Number of Units 3 and 4 Construction and Operations Workers Onsite Each 

Year During Building ....................................................................................................... 4-41 

4-6 Potential Population Growth in the EIA Due to Peak Building Year (2014) 

Employment at CPNPP Units 3 and 4 ............................................................................ 4-43 

4-7 Potential Total Ad Valorem Taxes Paid on CPNPP Units 3 and 4 ................................. 4-46 

4-8 Peak Hour Traffic Impacts on FM 56 During the Peak Building Year at CPNPP 

Units 3 and 4 .................................................................................................................. 4-49 

4-9 Expected Daily Traffic Distribution During the Peak Building Period at CPNPP 

Units 3 and 4 .................................................................................................................. 4-50 

4-10 Vacant Permanent and Temporary Housing Units and Projected Housing Demand 

from In-Migrating CPNPP Workers (2014) in the EIA ..................................................... 4-53 

4-11 Existing Excess Water and Wastewater Treatment Capacity and Projected Water 

Demand from In-Migrating CPNPP Workers (2014) in the EIA ...................................... 4-56 

4-12 Projected Total Nonfatal Occupational Illnesses and Injuries to Construction Force 

Using 2007 Rates for Various Groups ............................................................................ 4-69 

4-13 Construction Noise Sources and Attenuation with Distance .......................................... 4-70 

4-14 Summary of Measures and Controls Proposed by Luminant to Limit Adverse 

Impacts During the Construction Period ......................................................................... 4-77 

4-15 Summary of Impacts from Building Proposed CPNPP Units 3 and 4 ............................. 4-80 

5-1 Annual Hours of Fogging and Icing Affecting Residential Area Adjacent to CPNPP 

Boundary .......................................................................................................................... 5-2 

5-2 Estimated Concentrations of Selected Water Quality Constituents at the Discharge 

of CPNPP Units 3 and 4 When Diluted in Lake Granbury .............................................. 5-12 
May 2011 xvii NUREG-1943 

5-3 Egg and Spawning Characteristics of Lake Granbury Fish Species .............................. 5-32 

5-4 Thermal Tolerances of Some Fish Species of Lake Granbury ....................................... 5-34 

5-5 Potential Population Growth in the EIA Due to Peak Operations Employment at 

CPNPP Units 3 and 4 ..................................................................................................... 5-54 

5-6 Average Annual Salary for Operations Workforce at CPNPP Units 3 and 4 .................. 5-56 

5-7 Potential Total Annual Ad Valorem Taxes Paid on CPNPP Units 3 and 4 During 

Operations ...................................................................................................................... 5-57 

5-8 Vacant Housing Units and Projected Housing Demand from In-Migrating CPNPP 

Operations Workers in the EIA ....................................................................................... 5-61 

5-9 Air Emissions Associated with CPNPP Units 3 and 4 .................................................... 5-71 

5-10 Predicted Noise Levels (DbA) Expected Due to Plant Operations ................................. 5-77 

5-11 Expected Annual Total Recordable Cases of Injuries and Illnesses .............................. 5-79 

5-12 Annual Expected Impacts of Transporting Operations Personnel to the 

Comanche Peak Site ...................................................................................................... 5-81 

5-13 Annual Expected Impacts of Transporting Salt Waste from CPNPP Units 3 and 4 ....... 5-81 

5-14 Annual Doses to the MEI for Liquid Effluent Releases from a New Unit ........................ 5-85 

5-15 Annual Doses to MEI from Gaseous Effluent Releases from a New Unit ...................... 5-87 

5-16 Comparison of Annual MEI Dose for Single Unit with 10 CFR 50, Appendix I Dose 

Design Objectives ........................................................................................................... 5-88 

5-17 Comparison of MEI Annual Doses (mrem/yr) with 40 CFR Part 190 Standards ............ 5-89 

5-18 Biota Annual Doses for Proposed Units 3 and 4 ............................................................ 5-91 

5-19 Comparison of Biota Doses from the Proposed Units 3 and 4 at the CPNPP Site to 

Relevant Guidelines for Biota Protection ........................................................................ 5-92 

5-20 Atmospheric Dispersion Factors for Comanche Peak Site DBA Calculations ................ 5-98 

5-21 DBA Doses for a US-APWR for Proposed CPNPP Units 3 and 4 .................................. 5-99 

5-22 Environmental Risks from a US-APWR Severe Accident at the Comanche Peak 

Site (2006 Meteorological Data) ................................................................................... 5-102 

5-23 Total Severe Accident Health Effects (Based on 2006 Meteorological Data) .............. 5-103 

5-24 Comparison of Environmental Risks for a US-APWR at the Comanche Peak Site 

Using 2006 Meteorological Data with Risks for Current-Generation Reactors at 

Five Sites Evaluated in NUREG-1150 .......................................................................... 5-104 

5-25 Comparison of Environmental Risks from Severe Accidents for a US-APWR at the 

Comanche Peak Site with Risks for Current Plants from Operating License 

Renewal Reviews, Including CPNPP Units 1 and 2 ..................................................... 5-106 

5-26 The Mean CDF and LRF Estimated Contributions for US-APWR at CPNPP .............. 5-107 

5-27 Summary of Measures and Controls Proposed by Luminant to Limit Adverse 

Impacts During Operation ............................................................................................. 5-112 

5-28 Summary of Operational Impacts at the Proposed Unit 3 and 4 Comanche Peak 

Site ............................................................................................................................... 5-120 

6-1 Uranium Fuel Cycle Environmental Data as Provided in Table S-3 of 10 CFR 

51.51(b) ............................................................................................................................ 6-2 

6-2 Comparison of Annual Average Dose Received by an Individual from All Sources ....... 6-11 

6-3 Numbers of Truck Shipments of Unirradiated Fuel for the Reference LWR and the 

US-APWR ....................................................................................................................... 6-16 

6-4 RADTRAN 5.6 Input Parameters for Unirradiated Fuel Shipments ................................ 6-18 
NUREG-1943 xviii May 2011 

6-5 Radiological Impacts under Normal Conditions of Transporting Unirradiated Fuel to 

the CPNPP Site and Alternative Sites ............................................................................ 6-18 

6-6 Nonradiological Impacts of Transporting Unirradiated Fuel to the CPNPP Site and 

Alternative Sites, Normalized to Reference LWR ........................................................... 6-22 

6-7 Transportation Route Information for Shipments from the CPNPP Site and 

Alternative Sites to the Proposed Geologic Repository at Yucca Mountain, Nevada 

(Johnson and Michelhaugh 2003) Spent Fuel Disposal Facility ..................................... 6-24 

6-8 RADTRAN 5.6 Normal (Incident-Free) Exposure Parameters ....................................... 6-25 

6-9 Normal (Incident-Free) Radiation Doses to Transport Workers and the Public from 

Shipping Spent Fuel from the CPNPP Site and Alternative Sites to the Proposed 

High-Level Waste Repository at Yucca Mountain .......................................................... 6-26 

6-10 Radionuclide Inventories Used in Transportation Accident Risk Calculations for the 

US-APWR ....................................................................................................................... 6-28 

6-11 Annual Spent Fuel Transportation Accident Impacts for an US-APWR Reactor at 

the CPNPP Site and Alternative Sites Normalized to Reference 1100-MW(e) LWR 

Net Electrical Generation ................................................................................................ 6-30 

6-12 Nonradiological Impacts of Transporting Spent Fuel from the CPNPP Site and 

Alternative Sites to the Proposed Geologic HLW Repository at Yucca Mountain, 

Nevada, Normalized to Reference LWR ........................................................................ 6-31 

6-13 Summary of Radioactive Waste Shipments from the CPNPP Site and Alternative 

Sites ................................................................................................................................ 6-32 

6-14 Nonradiological Impacts of Radioactive Waste Shipments from the CPNPP Site ......... 6-32 

7-1 Projects and Other Actions Considered in the Cumulative Analysis at the CPNPP 

Site ................................................................................................................................... 7-3 

7-2 Comparison of Annual Carbon Dioxide Emission Rates ................................................ 7-27 

7-3 Cumulative Impacts on Environmental Resources, Including the Impacts of the 

Proposed CPNPP Units 3 and 4 ..................................................................................... 7-35 

8-1 Comparison of ERCOT Peak Load Forecasts, Loads Acting as Reserves, and 

Demand-Side Management Energy Saving for 2010, 2011, 2014, 2019, and 2024 ...... 8-15 

8-2 Capacity, Demand, and Reserves in the ERCOT Region Based on 2010 Data ............ 8-18 

8-3 Generation Interconnection Information ......................................................................... 8-19 

8-4 Need for Power Analysis ................................................................................................ 8-22 

8-5 Scenario Analysis and Reserve Margins: Scenario 1—Conservation Increase ............. 8-22 

8-6 Scenario Analysis and Reserve Margins: Scenario 2—Additional Wind Capacity ......... 8-23 

8-7 Scenario Analysis and Reserve Margins: Scenarios 1 and 2 Combined ....................... 8-23 

8-8 Scenario Analysis and Reserve Margins: Scenario 4—Omit Capacity over 50 

Years of Age ................................................................................................................... 8-24 

9-1 Land Areas of Luminant Lignite Coal Plants .................................................................. 9-12 

9-2 Summary of Environmental Impacts of Coal-Fired Power Generation ........................... 9-15 

9-3 Summary of Environmental Impacts of Natural Gas-Fired Power Generation ............... 9-19 

9-4 Summary of Environmental Impacts of a Combination of Power Sources ..................... 9-30 

9-5 Summary of Environmental Impacts (Impact Category Level) of Construction and 

Operation of New Nuclear, Coal-Fired, and Natural Gas-Fired Generating Units, 

and a Combination of Alternatives .................................................................................. 9-31 

9-6 Comparison of Direct Carbon Dioxide Emissions for Energy Alternatives ..................... 9-32 
May 2011 xix NUREG-1943 

9-7 Projects and Other Actions Considered in the Cumulative Analysis at the Coastal 

Site ................................................................................................................................. 9-39 

9-8 Threatened or Endangered Terrestrial Species that May Occur within 10 mi of 

Coastal Site .................................................................................................................... 9-46 

9-9 State-Listed Aquatic Species and State Species of Concern Potentially Occurring 

in the Vicinity of the Coastal Site .................................................................................... 9-51 

9-10 Population and Labor Force in Victoria County, Texas, and the Other Counties 

Surrounding the Coastal Site .......................................................................................... 9-57 

9-11 Minority and Low-Income Percentages in Victoria County, Texas, and the Other 

Counties Surrounding the Coastal Site .......................................................................... 9-58 

9-12 Nearby Nuclear Projects/Facilities Considered in the Cumulative Analysis at the 

Coastal Site .................................................................................................................... 9-65 

9-13 Projects and Other Actions Considered in the Cumulative Analysis at the Pineland 

Site ................................................................................................................................. 9-66 

9-14 Threatened or Endangered Terrestrial Species that May Occur within 10 mi of the 

Pineland Site .................................................................................................................. 9-74 

9-15 State-Listed Aquatic Species and State Species of Concern Potentially Occurring 

in the Vicinity of the Pineland Site .................................................................................. 9-79 

9-16 Population and Labor Force in San Augustine County, Texas, and the Other 

Counties and Parishes Surrounding the Pineland Site ................................................... 9-85 

9-17 Minority and Low-Income Percentages in San Augustine County, Texas, and the 

other Counties and Parishes Surrounding the Pineland Site ......................................... 9-87 

9-18 Projects and Other Actions Considered in the Cumulative Analysis at the 

Tradinghouse Site .......................................................................................................... 9-94 

9-19 Threatened or Endangered Terrestrial Species that May Occur within 10 mi of 

Tradinghouse Site ........................................................................................................ 9-100 

9-20 Federally and State-Listed Aquatic Species and State Species of Concern 

Potentially Occurring in the Vicinity of the Tradinghouse Site ...................................... 9-104 

9-21 Population and Labor Force in McLennan County, Texas, and the Other Counties 

Surrounding the Tradinghouse Site .............................................................................. 9-108 

9-22 Minority and Low-Income Percentages in McLennan County, Texas, and the Other 

Counties Surrounding the Tradinghouse Site ............................................................... 9-109 

9-23 Nearby Nuclear Projects/Facilities Considered in the Cumulative Analysis at the 

Tradinghouse Site ........................................................................................................ 9-115 

9-24 Comparison of Cumulative Impacts at the CPNPP site and Alternative Sites .............. 9-117 

10-1 Unavoidable Adverse Environmental Impacts during Construction and 

Preconstruction ............................................................................................................... 10-5 

10-2 Unavoidable Adverse Environmental Impacts from Operations ..................................... 10-9 

10-3 Monetary and Nonmonetary Benefits from Constructing and Operating CPNPP 

Units 3 and 4 ................................................................................................................ 10-16 

10-4 Internal and External Costs of Constructing and Operating CPNPP Units 3 and 4 ...... 10-18 

May 2011 xxi NUREG-1943 

Executive Summary 

By letter dated September 19, 2008, the U.S. Nuclear Regulatory Commission (NRC) received 

an application from Luminant Generation Company LLC (Luminant), acting for itself and as 

agent for Nuclear Project Company LLC (subsequently renamed Comanche Peak Nuclear 

Power Company LLC), for combined construction permits and operating licenses (combined 

licenses or COLs) for two new nuclear reactor power units (the proposed Units 3 and 4) at the 

Comanche Peak Nuclear Power Plant (CPNPP) site, which is located in Hood and Somervell 

Counties, Texas. The NRC staff’s evaluation is based on Luminant’s November 2009 revision 

to the application, responses to requests for additional information (RAIs), and supplemental 

letters. 

The proposed actions related to the CPNPP Unit 3 and 4 application are (1) NRC issuance of 

COLs for two new nuclear power reactor units at the CPNPP site and (2) U.S. Army Corps of 

Engineers (Corps) issuance of a permit pursuant to Section 404 of the Federal Water Pollution 

Control Act (Clean Water Act) and Section 10 of the Rivers and Harbors Act to perform certain 

construction activities on the site. The Corps is participating as a cooperating agency with the 

NRC in preparing this environmental impact statement (EIS) and participates collaboratively on 

the review team. The reactor specified in the application is a Mitsubishi Heavy Industries, Ltd. 

(MHI), U.S. Advanced Pressurized-Water Reactor (US-APWR) design (hereafter referred to as 

US-APWR in this EIS). 

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

(42 USC 4321 et seq.) directs that an EIS be prepared for major Federal actions that 

significantly affect the quality of the human environment. The NRC has implemented Section 

102 of NEPA in Title 10 of the Code of Federal Regulations (CFR) Part 51. Further, in 10 CFR 

51.20, the NRC has determined that the issuance of a COL under 10 CFR Part 52 is an action 

that requires an EIS. 

The purpose of Luminant’s requested NRC action is to obtain COLs to construct and operate 

two new baseload nuclear power units. These licenses are necessary but not sufficient for 

construction and operation of the units. A COL applicant must obtain and maintain the 

necessary permits from other Federal, State, Tribal, and local agencies and permitting 

authorities. Therefore, the purpose of the NRC’s environmental review of Luminant’s 

application is to determine the impacts on the human environment if two new nuclear power 

units of the proposed US-APWR design are constructed and operated at the CPNPP site. The 

purpose of Luminant’s requested Corps action is to obtain a permit to perform regulated 

activities that would have an effect on waters of the United States. 

Upon acceptance of the Luminant application, the NRC began the environmental review 

process described in 10 CFR Part 51 by publishing in the Federal Register (FR) a Notice of 

Intent (73 FR 9604) to prepare an EIS and to conduct scoping. On January 6, 2009, the NRC 

held two scoping meetings in Glen Rose, Texas, to obtain public input on the scope of the 

environmental review. The staff reviewed the comments received during the scoping process 

and contacted Federal, State, Tribal, regional, and local agencies to solicit comments. 

To gather information and to become familiar with the sites and their environs, the NRC, its 

contractors [the Oak Ridge National Laboratory (ORNL) and Information Systems Laboratories, 

Inc. (ISL)], and the Corps visited the CPNPP site in February 2009 to examine the ecological 

resources of the site and to conduct an environmental site audit. The NRC and its contractors 

also visited three alternative sites (the Coastal site, the Pineland site, and the Tradinghouse 

site) in Texas in February 2009. During the site visits, the NRC staff and its contractors met 

with Luminant staff, public officials, and the public. 
NUREG-1943 xxii May 2011 

Included in this EIS are (1) the results of the joint NRC/Corps review team’s analyses, which 

consider and weigh the environmental effects of the proposed actions; (2) potential mitigation 

measures for reducing or avoiding adverse effects; (3) the environmental impacts of alternatives 

to the proposed action; and (4) the NRC staff’s recommendation regarding the proposed action. 

To guide its assessment of the environmental impacts of a proposed action or alternative 

actions, the NRC has established a standard of significance for impacts based on Council on 

Environmental Quality guidance (40 CFR 1508.27). Table B-1 of 10 CFR Part 51, Subpart A, 

Appendix B, provides the following definitions of the three significance levels – SMALL, 

MODERATE, and LARGE: 

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. 

In preparing this EIS, the review team reviewed the application, including the Environmental 

Report (ER) submitted by Luminant; consulted with Federal, State, Tribal, and local agencies; 

and followed the guidance set forth in NUREG-1555, Environmental Standard Review Plan and 

Staff Memorandum on Addressing Construction and Preconstruction, Greenhouse Gas Issues, 

General Conformity Determinations, Environmental Justice, Need for Power, Cumulative Impact 

Analysis, and Cultural/Historical Resources Analysis Issues in Environmental Impact 

Statements. In addition, the NRC staff considered the public comments related to the 

environmental review received during the scoping process. Comments within the scope of the 

environmental review are included in Appendix D of this EIS. 

A 75-day comment period began on August 13, 2010, when the U.S. Environmental Protection 

Agency (EPA) published a Notice of Availability of the draft EIS to allow members of the public 

and agencies to comment on the results of the NRC and Corps staffs’ review. During this 

period, the NRC and Corps staff conducted two public meetings in Glen Rose, Texas, to 

describe the results of the environmental review, respond to questions, and receive public 

comments on the draft EIS. All comments received on the draft EIS are included in Appendix E. 

Changes made in response to public comments, updates to the material, and other substantive 

changes are identified by change bars in the margins of this final EIS. 

The NRC staff’s recommendation to the Commission related to the environmental aspects of the 

proposed action is that the COLs be issued as requested. This recommendation is based on (1) 

the application, including the ER submitted by Luminant and Luminant’s supplemental letters 

and responses to the review team’s RAIs; (2) consultation with other Federal, State, Tribal, and 

local agencies; (3) the review team’s independent review; (4) the review team’s consideration of 

public comments; and (5) the assessments summarized in this EIS, including the potential 

mitigation measures identified in the ER and this EIS. The Corps permit decision will be made 

following issuance of the final EIS, and the Corps will issue its Record of Decision (ROD) based, 

in part, on this EIS. 

The NRC staff’s evaluation of the site safety and emergency preparedness aspects of the 

proposed action will be addressed in the NRC’s Safety Evaluation Report, which is still being 

developed. The reactor specified in the application is the MHI US-APWR design, which is 

currently undergoing a design certification review. The NRC staff’s evaluation of the design 

certification is currently in progress. 
May 2011 xxiii NUREG-1943 

Abbreviations/Acronyms 

μg micrograms 

μS microsiemens 

Χ/Q dispersion values 

°C degree(s) Celsius 

°F degree(s) Fahrenheit 

A/B auxiliary building 

AADT Annual Average Daily Traffic 

ABWR Advanced Boiling Water Reactor 

ac acre(s) 

AC alternating current 

ACHP Advisory Council on Historic Preservation 

AD Attainment Demonstration 

AEC Atomic Energy Commission 

AEP Archaeology and Ethnography Program 

ALARA as low as reasonably achievable 

AML abandoned mine land 

AMUD Acton Municipal Utility District 

AN ammonia nitrogen 

APE Area of Potential Effect 

APLIC Avian Powerline Interaction Committee 

ASLB Atomic Safety and Licensing Board 

AWEA American Wind Energy Association 

BA bioliquid assessment 

BDTF Blowdown Treatment Facility 

BEA Bureau of Economic Analysis 

BEIR Biological Effects of Ionizing Radiation 

BLS U.S. Bureau of Labor Statistics 

BMP best management practice 

BOD biochemical oxygen demand 

Bq Becquerel(s) 

BRA Brazos River Authority 

BRM Brazos River mile 

Btu British thermal unit(s) 

BUL balancing up load 

BWR boiling-water reactor 

C/V containment vessel 

CAA Clean Air Act 

CBC Christmas Bird Count 

CBOD carbonaceous biochemical oxygen demand 

CCD Census County Division 

CCWS component cooling water system 

CDC Center for Disease Control and Prevention 
NUREG-1943 xxiv May 2011 

CDF core damage frequency 

CDP census-designated place 

CDR Capacity, Demand, and Resources Report 

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations 

cfs cubic feet per second (water flow) 

cfu colony forming units 

Ci Curie(s) 

CLNGT Calhoun Liquefied Natural Gas Terminal 

cm centimeters 

cm2

 centimeter(s) squared 

CMP Coastal Management Program 

CMZ Coastal Management Zone 

CO carbon monoxide 

CO2 carbon dioxide 

COL combined license 

Corps U.S. Army Corps of Engineers 

CP construction permit 

CPCN Certificate of Public Convenience and Necessity 

CPNPP Comanche Peak Nuclear Power Plant 

CPS Energy City Public Service Board of San Antonio, Texas 

CPUE catch per unit effort 

CR County Road (CR 360, CR 392) 

CREZ Competitive Renewable Energy Zones 

CS containment spray 

CVCS Chemical and Volume Control System 

CVDT containment vessel reactor coolant drain tank 

CWA Clean Water Act 

CWIS circulating water intake structure 

CWS circulating water system 

d day 

D/Q annual normalized total surface deposition rates 

DA Department of the Army 

dBA decibel(s) (acoustic) 

DBA Design Basis Accident 

DBH diameter at breast height 

DC direct current 

DCD Design Control Document 

DDT dichlorodiphenyltrichloroethane 

DFPS Department of Family Protective Services 

DFW Dallas–Fort Worth 

DHV design hourly volume 

DNL day-night average sound levels 

DO dissolved oxygen 

DOE U.S. Department of Energy 

DOT U.S. Department of Transportation 
May 2011 xxv NUREG-1943 

DSM demand side management 

DSWG Demand Side Working Group 

DWS demineralized water system 

EAB Exclusion Area Boundary 

ECP essential cooling pond 

EFH Energy Future Holdings Corporation 

EFH essential fish habitat 

EIA Energy Information Administration 

EIS environmental impact statement 

ELCC effective load carrying capacity 

ELF extremely low frequency 

EMF electromagnetic field 

EPA U.S. Environmental Protection Agency 

ER Environmental Report 

ERCOT Electric Reliability Council of Texas 

ESA U.S. Endangered Species Act of 1973, as amended 

ESP early site permit 

ESRP Environmental Standard Review Plan 

ESWS essential service water system 

FAA Federal Aviation Administration 

FAC free available chlorine 

FC fecal coliform 

FDA final design approval 

FERC Federal Energy Regulatory Commission 

FES Final Environmental Statement 

FM Farm-to-Market Road 

FPS fire protection system 

FR Federal Register 

FRA Federal Railroad Administration 

FSAR Final Safety Analysis Report 

ft foot or feet 

ft3 cubic feet 

FWS U.S. Fish and Wildlife Service 

gal gallon(s) 

GAM general area monitoring 

GATF Generation Adequacy Task Force 

GBq gigabecquerel 

GBRA Guadelupe-Blanco River Authority 

GCC global climate change 

GCD Groundwater Conservation District 

GCRP Global Change Research Program 

GE General Electric 

GED Global Energy Decisions, Inc. 

GEIS generic environmental impact statement 
NUREG-1943 xxvi May 2011 

GEIS-DECOM GEIS-Decommissioning of Nuclear Facilities (NUREG-0586) 

GHG greenhouse gas 

GIT Georgia Institute of Technology 

GIWW Gulf Intracoastal Waterway 

gpd gallon(s) per day 

gpm gallon(s) per minute 

GPS global positioning system 

GTG gas turbine generator 

GWMS Gaseous Waste Management System 

ha hectare(s) 

HCLPF high confidence of low probability of failures 

HCP Ham Creek Park 

hr hour(s) 

HT holdup tank 

HUD U.S. Department of Housing and Urban Development 

HVAC heating, ventilation, and air conditioning 

Hz hertz 

IA Interconnection Agreement 

IAEA International Atomic Energy Agency 

ICRP International Commission on Radiological Protection 

IGCC integrated gasification combined cycle 

in. inch(es) 

INL Idaho National Laboratory 

IOU investor owned utility 

ISD Independent School District 

ISFSI Independent Spent Fuel Storage Installation 

ISL Information Systems Laboratories, Inc. 

ISO independent system operator 

JPPP E.S. Joslin Power Plant Project 

KC Keystone Center 

km kilometer(s) 

km2 square kilometer(s) 

kV kilovolt(s) 

kWh kilowatt-hour(s) 

L liter(s) 

LaaR load acting as resource 

lb pound(s) 

LC50 concentration lethal to 50% of the sample population 

LCRA Lower Colorado River Authority 

LCRWPG Lower Colorado Regional Water Planning Group 

Ldn day-night average sound level 

LEDPA least environmentally damaging practicable alternative 

lin ft linear foot (feet) 
May 2011 xxvii NUREG-1943 

LLMW low-level mixed waste 

LLW low-level radioactive waste 

LOCA loss of coolant accident 

LOS Level of Service 

LPSD low power shutdown 

LPZ low population zone 

LRF large release frequency 

LSI Langelier Saturation Index 

LST local standard time 

LTSF Long-Term Storage Facility 

LVW low volume waste 

LWA Limited Work Authorization 

LWMS liquid waste management system 

LWR light-water reactor 

m meter(s) 

m2

 square meter(s) 

m3 cubic meter(s) 

mA milliampere 

MBq megabecquerel 

MCCI molten corium-to-concrete interaction 

mcf million cubic feet 

mCi millicurie 

MCR main cooling reservoir 

MDC main drainage channel 

MDCT mechanical draft cooling tower 

MEI maximally exposed individual 

mG milligauss 

mg milligram(s) 

MGD million gallon(s) per day 

MHI Mitsubishi Heavy Industries, Ltd. 

MHz megahertz 

mi mile(s) 

mi2 square mile(s) 

min minute 

MIT Massachusetts Institute of Technology 

mL milliliter(s) 

MMS Minerals Management Service 

MNES Mitsubishi Nuclear Energy Systems 

mo month 

MOU Memorandum of Understanding 

MOX mixed oxide (fuel) 

mph mile(s) per hour 

mpn most probable number 

mR milliroentgen 

mrad millirad(s) 

mrem millirem(s) 
NUREG-1943 xxviii May 2011 

MSA Metropolitan Statistical Area 

MSL above mean sea level 

mSv millisievert(s) 

MT metric ton(s) (or tonne[s]) 

MTU metric ton(s) of uranium 

MW megawatt(s) 

MW(e) megawatt(s) electrical 

MW(t) megawatt(s) thermal 

MWd megawatt-day(s) 

MW-h megawatt-hour(s) 

MWS makeup water system 

N nitrogen 

NAAQS National Ambient Air Quality Standard 

NCA Noise Control Act 

NCI National Cancer Institute 

NCRP National Council on Radiation Protection & Measurements 

NEPA National Environmental Policy Act of 1969, as amended 

NERC North American Electric Reliability Corporation 

NESC National Electric Safety Code 

NESWS nonessential service water system 

NGO nongovernmental organization 

NHPA National Historic Preservation Act of 1966, as amended through 2000 

NIEHS National Institute of Environmental Health Sciences 

NMM navigation mile marker 

NO2 nitrite 

NO3 nitrate 

NOAA National Oceanic and Atmospheric Administration 

NOx nitrogen oxide(s) 

NPDES National Pollutant Discharge Elimination System 

NRC U.S. Nuclear Regulatory Commission 

NRHP National Register of Historic Places 

NWPCC Northwest Power and Conservation Council 

O&M operations and maintenance 

ODCM offsite dose calculation manual 

OECD Organization for Economic Cooperation and Development 

OPO4 orthophosphate 

ORNL Oak Ridge National Laboratory 

OSF Onsite Staging Facility 

OSHA Occupational Safety and Health Administration 

P phosphorous 

PAM primary amoebic meningoencephalitis 

PBS&J Post, Buckley, Schuh & Jernigan, Inc. 

pCi picocuries 

PGC Power Generation Company 
May 2011 xxix NUREG-1943 

PGMA Priority Groundwater Management Plan 

PIR Public Interest Review 

PKL Possum Kingdom Lake 

PM particulate matter 

PM10 particulate matter with a diameter of 10 microns or less 

PM2.5 particulate matter with a diameter of 2.5 microns or less 

PNNL Pacific Northwest National Laboratory 

ppm parts per million 

ppt parts per thousand 

PRA probabilistic risk assessment 

PSD prevention of significant deterioration 

PSWS potable and sanitary water system 

PUCT Public Utility Commission of Texas 

PURA Public Utilities Regulatory Act 

PWR pressurized-water reactor(s) 

Q flow 

QSE qualified scheduling entity 

R/B reactor building 

RAI Request for Additional Information 

RCDT reactor coolant drain tank 

RCRA Resource Conservation and Recovery Act of 1976, as amended 

RCW Reactor Building Cooling Water 

rem Roentgen equivalent man (a special unit of radiation dose) 

REMP radiological environmental monitoring program 

REP retail electric provider 

RFP Reasonable Further Progress 

RHR residual heat removal 

RIMS Regional Input-Output Model System 

RLE review level earthquake 

RMPF Reservoir Makeup Pumping Facility 

RMR reliability must run 

ROD Record of Decision 

ROI region of interest 

ROW right-of-way 

rpm revolutions per minute 

RRY reference reactor year 

RSICC Radiation Safety Information Computational Center 

RSW Reactor Service Water 

RV recreational vehicle 

RWST refueling water storage tank 

Ryr reactor-year 

s second(s) 

SACTI Seasonal and Annual Cooling Tower Impacts Prediction Code 

SAMA severe accident mitigation alternative 
NUREG-1943 xxx May 2011 

SAMDA severe accident mitigation design alternative 

SAWS San Antonio Water System 

SB Senate Bill 

SCR Squaw Creek Reservoir 

SCWD Somervell County Water District 

SER Safety Evaluation Report 

SES Steam Electric Station 

SFSI Spent Fuel Storage Installation 

SG steam generator 

SGBD Steam Generator Blowdown 

SGIA signed generation permit agreement 

SGTR steam generator tube rupture 

SH state highway 

SHPO State Historic Preservation Office 

SIP State Implementation Plan 

SMA Seismic Margin Analysis 

SNDC summer net dependable capability 

SO2 sulfur dioxide 

SOP System Operation Permit 

SOx sulfur oxide 

SPP Southwest Power Pool 

SSC structure, system, or component 

STP South Texas Project Electric Generating Station 

STPNOC STP Nuclear Operating Company 

SWATS Surface Water and Treatment System 

SWMS Solid Waste Management System 

SWPPP Stormwater Pollution Prevention Plan 

SWWTS sanitary wastewater treatment system 

T&D transmission and distribution 

TAC Texas Administrative Code 

TBEG Texas Bureau of Economic Geology 

TBq terabecquerel(s) 

TCC Texas Central Company 

TCEQ Texas Commission on Environmental Quality 

TCS turbine component cooling water system 

TCWP Texas Coastal Watershed Program 

TDS total dissolved solids 

TDSHS Texas Department of State Health Services 

TEDE total effective dose equivalent 

Temp temperature 

THC Texas Historical Commission 

THPO Tribal Historic Preservation Office 

TIS Texas Interconnected System 

TLD thermoluminescent dosimeter 

TMDL total maximum daily load 

TPDES Texas Pollutant Discharge Elimination System 
May 2011 xxxi NUREG-1943 

TPWD Texas Parks and Wildlife Department 

TPWP Texas Prairie Wetlands Project 

tpy tons per year 

TRC total residual chlorine 

TSDC Texas State Data Center 

TSS total suspended solids 

TSWQS Texas Surface Water Quality Standard 

TUGC Texas Utilities Generating Company 

TW terawatt 

TWC Texas Water Code 

TWDB Texas Water Development Board 

TW-h terawatt-hour(s) 

TX Texas 

TxDOT Texas Department of Transportation 

TXNDD Texas Natural Diversity Database 

UC University of Chicago 

U3O8 triuranium octaoxide (“yellowcake”) 

UF6 uranium hexafluoride 

UFC uranium fuel cycle 

UHS ultimate heat sink 

UO2 uranium oxide 

USACE U.S. Army Corps of Engineers (Corps) 

US-APWR U.S. Advanced Pressurized Water Reactor 

USCB U.S. Census Bureau 

USFWS U.S. Fish and Wildlife Service 

USGCRP U.S. Global Change Research Program National Assessment 

USGS U.S. Geological Survey 

VCNS Victoria County Nuclear Station 

VCT volume control tank 

VFD Volunteer Fire Department 

VOC volatile organic compound 

WBR Wheeler Branch Reservoir 

WDA Workforce Development Area 

WHO World Health Organization 

WMA Wildlife Management Area 

WWS wastewater system 

yd yard(s) 

yd3 cubic yard(s) 

yr year(s)

Appendix A 

Contributors to the Environmental Impact Statement 

 

May 2011 A-1 NUREG-1943 

Appendix A 

Contributors to the Environmental Impact Statement 

The overall responsibility for the preparation of this environmental impact statement was 

assigned to the Office of New Reactors, U.S. Nuclear Regulatory Commission (NRC). The 

statement was prepared by members of the Offices of New Reactors with assistance from other 

NRC organizations, the U.S. Army Corps of Engineers, the Oak Ridge National Laboratory, and 

the Information Sciences Laboratory. 

Name Affiliation Function or Expertise

NUCLEAR REGULATORY COMMISSION

Michael Willingham Office of New Reactors Environmental Project Manager 

Donald Palmrose Office of New Reactors Senior Project Manager 

Alicia Williamson Office of New Reactors Project Manager/Support 

John Fringer Office of New Reactors Project Manager 

Jack Cushing Office of New Reactors Senior Project Manager/Advisor 

Mark Notich Office of New Reactors Assistant Project Manager/Advisor 

Gregory Hatchett Office of New Reactors DSER/RAP1 Branch Chief 

Gwen Hawkins Office of New Reactors Project Management Support 

Michelle Moser Office of New Reactors Project Manager/Advisor 

Nebiyu Tiruneh Office of New Reactors Surface Water Hydrology 

Daniel Barnhurst Office of New Reactors Groundwater Hydrology; Geology 

Harriet Nash Office of New Reactors Aquatic Ecology 

Peyton Doub Office of New Reactors Terrestrial Ecology; Land Use 

Dan Mussatti Office of New Reactors Socioeconomics; Environmental Justice; 

Benefit-Cost Analysis; Need for Power 

Barry Zalcman Office of New Reactors Alternatives 

Rich Emch Office of New Reactors Health Physics; Human Health; Cultural 

Resources; Nonradiological Waste 

Richard Clement Office of New Reactors Health Physics (Operations) 

Ron LaVera Office of New Reactors Health Physics (Construction) 

Kevin Quinlan Office of New Reactors Meteorology and Air Quality 

Stan Echols Office of Nuclear Material Safety and 

Safeguards 

Uranium Fuel Cycle; Radiological 

Waste 

Edward Fuller Office of New Reactors Accidents 

Michelle Hart Office of New Reactors Accidents 

Kevin Witt Office of Nuclear Material Safety and 

Safeguards 

Transportation 

Jessica Glenny Office of Nuclear Material Safety and 

Safeguards 

Transportation 

Allen Fetter Office of Federal and State Materials and 

Environmental Management Programs 

Decommissioning 
Appendix A 

NUREG-1943 A-2 May 2011 

Name Affiliation Function or Expertise

Jim Shepherd Office of Federal and State Materials and 

Environmental Management Programs 

Decommissioning 

U.S. ARMY CORPS OF ENGINEERS 

David Madden Regulatory Branch, Forth Worth District Section 404; Wetlands 

OAK RIDGE NATIONAL LABORATORY (ORNL)a

Gregory Zimmerman Environmental Sciences Division Team Leader 

Barry Shumpert Environmental Sciences Division Land Use 

Brennan Smith Environmental Sciences Division Hydrology 

Ellen Smith Environmental Sciences Division Hydrology 

Glenn Cada Environmental Sciences Division Hydrology/Water Quality 

David Watson Environmental Sciences Division Hydrology /Geohydrology 

Harry Quarles, III Environmental Sciences Division Terrestrial Ecology 

James Saulsbury Environmental Sciences Division Socioeconomics; Environmental Justice 

Keith Eckerman Environmental Sciences Division Health Physics; Human Health 

Kathy Gant Environmental Sciences Division Health Physics; Human Health 

Scott Ludwig Global Nuclear Security Technology Division Transportation 

Kent Williams b

 Nuclear Science & Technology Division Uranium Fuel Cycle; Radiological Waste 

Fred Peretz Nuclear Science & Technology Division Uranium Fuel Cycle; Radiological Waste; 

Decommissioning 

David Bjornstad Environmental Sciences Division Benefit-Cost Analysis; Need for Power 

Walter Koncinski Creative Media Organization Technical Editing 

Priscilla Henson Creative Media Organization Technical Editing 

INFORMATION SYSTEMS LABORATORIES, INC. (ISL)c

Terry Gitnick ISL Project Manager 

Steve Dillard ISL/AECOM d Aquatic Ecology 

Steve Duda ISL/AECOM d

 Aquatic Ecology 

Karmen King ISL/SC&A e Aquatic Ecology 

Abe Zeitoun ISL/SC&A e Aquatic Ecology 

Matt Goodwin ISL/AECOM d Cultural Resources 

Susan Provenzano ISL/AECOM d

 Cultural Resources 

Robert Dover ISL/AECOM d

 Meteorology/Air Quality; Alternatives 

Ed Kaczmarczyk ISL/AECOM d

 Meteorology/Air Quality 

Bruce Mrowca ISL Accidents 

M. Ali Azarm ISL Accidents 

Roberta Hurley ISL/AECOM d Alternatives 

Kevin Taylor ISL/AECOM d

 Alternatives 

a Oak Ridge National Laboratory is operated for the U.S. Department of Energy by UT-Battelle LLC. 

b Retired from Oak Ridge National Laboratory. 

c Information Systems Laboratories (ISL) is a private-sector company performing services under contract to NRC. 

d AECOM is a private-sector subcontractor to ISL. 

e SC&A is a private-sector subcontractor to ISL. 
Appendix B 

Organizations Contacted 

 

May 2011 B-1 NUREG-1943 

Appendix B 

Organizations Contacted 

The following Federal, State, regional, Tribal, and local organizations were contacted during the 

course of the U.S. Nuclear Regulatory Commission staff’s independent review of potential 

environmental impacts from the construction and operation of two new nuclear units (Units 3 

and 4) at the Comanche Peak Nuclear Power Plant site in Hood and Somervell Counties, 

Texas. 

Advisory Council on Historic Preservation, Washington, D.C. 

Apache Tribe of Oklahoma, Anadarko, Oklahoma 

Toni Ballew, Director, Hood County United Way, Granbury, Texas 

Caddo Nation of Oklahoma, Binger, Oklahoma 

Cheyenne and Arapaho Tribes of Oklahoma, Concho, Oklahoma 

City of Glen Rose, Texas, Betty Gosdin, Chair of City Planning and Zoning Commission 

City of Granbury, Texas, David Southern, Mayor 

City of Granbury, Texas, Harold Sandel, City Manager 

City of Granbury, Texas, Ron Berryman, Assistant City Manager 

City of Granbury, Texas, Lee Daniels, Chair of City Planning and Zoning Commission 

Luis Crespo, Pastor, Maranatha Lighthouse Church, Glen Rose, Texas 

Delaware Tribe of Oklahoma, Bartlesville, Oklahoma 

The Delaware Nation, Delaware Tribe of Western Oklahoma, Anadarko, Oklahoma 

Hood County, Texas, Andy Rash, County Judge 

Hood County, Texas, Mike Sympson, County Commissioner 

Kickapoo Traditional Tribe of Texas, Eagle Pass, Texas 

National Marine Fisheries Service, St. Petersburg, Florida 

Oncor Electric Delivery Company LLC, Dallas, Texas 

Somervell County, Texas, Walter Maynard, County Judge 

Somervell County, Texas, Mike Ford, County Commissioner 

Somervell County, Texas, Susanne Reynolds, Emergency Management 

Texas Parks and Wildlife Department, Wildlife Habitat Assessment Program, Austin, Texas 

Texas State Historic Preservation Officer, Austin, Texas 

U.S. Army Corps of Engineers, Fort Worth District, Fort Worth, Texas 
Appendix B 

NUREG-1943 B-2 May 2011 

U.S. Fish and Wildlife Service, Houston, Texas 

Wichita and Affiliated Tribes, Anadarko, Oklahoma 

Norma Wright, Volunteer, Hood County food pantry and other local charitable organizations, 

Granbury, Texas 
Appendix C 

Chronology of the Nuclear Regulatory Commission and the 

U.S. Army Corps of Engineers Staff Environmental 

Review Correspondence Related to Luminant 

Generation Company, LLC, Application for 

Combined Licenses at the Comanche 

Peak Nuclear Power Plant Site 

 

May 2011 C-1 NUREG-1943 

Appendix C 

Chronology of the Nuclear Regulatory Commission 

and the U.S. Army Corps of Engineers Staff 

Environmental Review Correspondence Related 

to Luminant Generation Company, LLC, Application 

for Combined Licenses at the Comanche 

Peak Nuclear Power Plant Site 

This appendix contains a chronological listing of correspondence between the U.S. Nuclear 

Regulatory Commission (NRC) and Luminant Generation Company LLC (Luminant), and other 

correspondence related to the NRC staff’s environmental review, under Title 10 of the Code of 

Federal Regulations (CFR) Part 51, for Luminant’s application for combined licenses (COLs) at 

the Comanche Peak Nuclear Power Plant (CPNPP) in Somervell and Hood Counties, Texas. 

Additionally, correspondence related to the U.S. Army Corps of Engineers (USACE or Corps) 

environmental review of Luminant’s application for two new units at the CPNPP site is also 

included. All documents, with the exception of those containing proprietary information, are 

available at the Commission’s Public Document Room, at One White Flint North, 11555 

Rockville Pike (first floor), Rockville, Maryland, and are available electronically from the Public 

Electronic Reading Room found on the internet at the following web address: 

http://www.nrc.gov/reading-rm.html. From this site, the public can gain access to the NRC’s 

Agencywide Document Access and Management System (ADAMS), which provides text and 

image files of NRC's public documents in the component of ADAMS. The ADAMS accession 

numbers for each document are included below. 

September 19, 2008 Letter from Mr. Mitch Lucas, Vice President, Luminant Generation 

Company LLC (Luminant), to the U.S. Nuclear Regulatory Commission 

(NRC), transmitting Combined License Application for Comanche Peak 

Nuclear Power Plant, Units 3 and 4 (Accession No. ML082680250). 

November 3, 2008 Federal Register Notice of Receipt and Availability of Application of 

Combined License for Luminant Generation Company LLC (73 FR 

66276) (Accession No. ML083010072). 

November 3, 2008 Letter from Stephen Raul Monarque, NRC, to Mr. Don Woodlan, 

Manager, Luminant, transmitting Acknowledgement of Receipt of the 

Combined License Application for Comanche Peak Nuclear Power Plant, 

Units 3 and 4, and Associated Federal Register Notice (Accession No. 

ML082420365). 

December 2, 2008 Federal Register Notice of Acceptance for Docketing of an Application for 

Combined License for Comanche Peak Nuclear Power Plant, Units 3 and 

4 (73 FR 75141) (Accession No. ML083390640). 

December 2, 2008 Letter from Stephen Raul Monarque, NRC, to Mr. Mitch Lucas, Luminant, 

transmitting Acceptance Review for the Comanche Peak Nuclear Power 

Plant, Units 3 and 4 Combined License Application and Associated 

Federal Register Notice (Accession No. ML082420435). 
Appendix C 

NUREG-1943 C-2 May 2011 

December 9, 2008 Letter from Michael Willingham, NRC, to Ms. Peggy Oldham transmitting 

Maintenance of Reference Materials at the Somervell County Library 

Related to the Environmental Review of the Luminant Generation 

Company LLC Combined License Application at the Comanche peak 

Nuclear Power Plant Site (Accession No. ML083390652). 

December 9, 2008 Letter from Michael Willingham, NRC, to Ms. Sheri McAllister transmitting 

Maintenance of Reference Materials at the Hood County Library Related 

to the Environmental Review of the Luminant Generation Company LLC 

Combined License Application at the Comanche peak Nuclear Power 

Plant Site (Accession No. ML083390662). 

December 18, 2008 Letter from Mr. Mitch Lucas, Luminant, to Michael Willingham, NRC, 

transmitting Comanche Peak, Units 3 and 4, Reassessment of 

Proprietary Information (Accession No. ML083590296). 

December 12, 2008 Federal Register Notice of Intent to Prepare an Environmental Impact 

Statement and Conduct Scoping Process for the Comanche peak Nuclear 

Power Plant, Units 3 and 4 Combined License Application (73 FR 77076) 

(Accession No. ML090690659). 

December 22, 2008 Memorandum to William Burton, NRC, from Michael Willingham, NRC, 

transmitting Notice of Public Meeting to Discuss Environmental Scoping 

Process for the Comanche Peak Nuclear Power Plant Combined License 

Application for Units 3 and 4 (TAC No. RF2683) (Accession No. 

ML083530985). 

December 23, 2008 Letter from William Burton, NRC, to Mr. Lawerence Oaks, Executive 

Director, Texas State Historic Preservation Officer, transmitting 

Notification and Request for Consultation and Participation in the Scoping 

Process for the Comanche Peak Nuclear Power Plant, Units 3 and 4 

Combined License Application Review (Accession No. ML083400507). 

December 23, 2008 Letter from William Burton, NRC, to Ms. Kathy Boydston, Texas parks 

and Wildlife Department, transmitting Request for Participation in the 

Scoping Process and the List of State Listed Protected Species for the 

Environmental Review for the Comanche Peak Nuclear Power Plant, 

Units 3 and 4 Combined License Application (Accession No. 

ML083400514). 

December 23, 2008 Letter from William Burton, NRC, to Mr. Don Klima, Director, Office of 

Federal Agency Programs, Advisory Council on Historic Preservation, 

transmitting Request for Participation in the Scoping Process for the 

Comanche peak Nuclear Power Plant, Units 3 and 4 Combined License 

Application Review (Accession No. ML083410002). 

December 23, 2008 Letter from William Burton, NRC, to Mr. Tom Cloud, U.S. Fish and Wildlife 

Service, transmitting Request for Consultation and Participation in the 

Environmental Scoping Process and a List of Protected Species within 

the Area Under Evaluation for the Comanche peak Nuclear power Plant, 

Units 3 and 4 Combined License Application Review (Accession No. 

ML083450242). 
Appendix C 

May 2011 C-3 NUREG-1943 

December 23, 2008 Letter from William Burton, NRC, to Mr. David Bernhart, National Marine 

Fisheries Service, transmitting Request for Participation on the 

Environmental Scoping Process and a List of Protected Species and 

Habitat within the Area under Evaluation for Comanche Peak Units 3 and 

4 Combined License Application Review (Accession No. ML083450284). 

December 23, 2008 Letter from William Burton, NRC, to Governor Scott Miller, Absentee 

Shawnee Tribe Headquarters, transmitting Notification and Request for 

Consultation and Participation in the Scoping Process for the 

Environmental Review of the Comanche Peak Nuclear Plant, Units 3 and 

4 Combined License Application (Accession No. ML083460276). 

December 23, 2008 Letter from William Burton, NRC, to Chairman Ronnie Lupe, White 

Mountain Apache Tribe, transmitting Notification and Request for 

Consultation and Participation in the Scoping Process for the 

Environmental Review of the Comanche Peak Nuclear Power Plant, Units 

3 and 4 Combined License Application (Accession No. ML083460284). 

December 23, 2008 Letter from William Burton, NRC, to Bryant Celestine, Alabama-Coushatta 

Tribe of Texas, transmitting Notification and Request for Consultation and 

Participation in the Scoping Process for the Environmental Review of the 

Comanche Peak Nuclear Power Plant, Units 3 and 4 Combined License 

Application (Accession No. ML083460323). 

December 23, 2008 Letter From William Burton, NRC, to Chairman Alonzo Chalepah, Apache 

Tribe of Oklahoma, transmitting Notification and Request for Consultation 

and Participation in the Scoping Process for the Environmental Review of 

the Comanche Peak Nuclear Power Plant, Units 3 and 4 Combined 

License Application (Accession No. ML083460347). 

December 23, 2008 Letter from William Burton, NRC, to Chairwoman LaRue Parker, Caddo 

Nation of Oklahoma, transmitting Notification and Request for 

Consultation and Participation in the Scoping Process for the 

Environmental Review of the Comanche Peak Nuclear Power Plant, 

Units 3 and 4 Combined License Application (Accession No. 

ML083460378). 

December 23, 2008 Letter from William Burton, NRC, to Governor Darrell Flyingman, 

Cheyenne and Arapaho Tribes of Oklahoma, transmitting Notification and 

Request for Consultation and Participation in the Scoping Process for the 

Environmental Review of the Comanche Peak Nuclear Power Plant, 

Units 3 and 4 Combined License Application (Accession No. 

ML083460400). 

December 23, 2008 Letter from William Burton, NCR, to Chairman Wallace Coffey, Comanche 

Nation, transmitting Notification and Request for Consultation and 

Participation in the Scoping Process for the Environmental Review of the 

Comanche Peak Nuclear Power Plant, Units 3 and 4 Combined License 

Application (Accession No. ML083460416). 

December 23, 2008 Letter from William Burton, NRC, to President Kerry Holton, Delaware 

Tribe of Western Oklahoma, transmitting Notification and Request for 

Consultation and Participation in the Scoping Process for the 

Environmental Review of the Comanche Peak Nuclear Power Plant, 
Appendix C 

NUREG-1943 C-4 May 2011 

Units 3 and 4 Combined License Application (Accession No. 

ML083460442). 

December 23, 2008 Letter from William Burton, NRC, to Chief Jerry Douglas, Delaware Tribe 

of Oklahoma, transmitting Notification and Request for Consultation and 

Participation in the Scoping Process for the Environmental Review of the 

Comanche Peak Nuclear Power Plant, Units 3 and 4 Combined License 

Application (Accession No. ML083460483). 

December 23, 2008 Letter from William Burton, NRC, to Chairman Jeff Houser, Fort Sill 

Apache Tribe of Oklahoma, transmitting Notification and Request for 

Consultation and Participation in the Scoping Process for the 

Environmental Review of the Comanche Peak Nuclear Power Plant, 

Units 3 and 4 Combined License Application (Accession No. 

ML083460509). 

December 23, 2008 Letter from William Burton, NRC, to Director Lorene Willis, Jicarilla 

Apache Nation, transmitting Notification and Request for Consultation and 

Participation in the Scoping Process for the Environmental Review of the 

Comanche Peak Nuclear Power Plant, Units 3 and 4 Combined License 

Application (Accession No. ML083460546). 

December 23, 2008 Letter from William Burton, NRC, to Chairman Juan Garza, Jr., Kickapoo 

Traditional Tribe of Texas, transmitting Notification and Request for 

Consultation and Participation in the Scoping Process for the 

Environmental Review of the Comanche Peak Nuclear Power Plant, 

Units 3 and 4 Combined License Application (Accession No. 

ML083460577). 

December 23, 2008 Letter from William Burton, NRC, to Chairman Billy Horse, Kiowa Tribe of 

Oklahoma, transmitting Notification and Request for Consultation and 

Participation in the Scoping Process for the Environmental Review of the 

Comanche Peak Nuclear Power Plant, Units 3 and 4 Combined License 

Application (Accession No. ML083460598). 

December 23, 2008 Letter from William Burton, NRC, to President Carleton Naiche-Palmer, 

Mescalero Apache Tribe, transmitting Notification and Request for 

Consultation and Participation in the Scoping Process for the 

Environmental Review of the Comanche Peak Nuclear Power Plant, 

Units 3 and 4 Combined License Application (Accession No. 

ML083460623). 

December 23, 2008 Letter from William Burton, NRC, to President Leslie Standing, Wichita 

and Affiliated Tribes, transmitting Notification and Request for 

Consultation and Participation in the Scoping Process for the 

Environmental Review of the Comanche Peak Nuclear Power Plant, 

Units 3 and 4 Combined License Application (Accession No. 

ML083470301). 

December 23, 2008 Letter from William Burton, NRC, to Principal Chief Jim Roan Grey, 

Osage Nation, transmitting Notification and Request for Consultation and 

Participation in the Scoping Process for the Environmental Review of the 

Comanche Peak Nuclear Power Plant, Units 3 and 4 Combined License 

Application (Accession No. ML083470322). 
Appendix C 

May 2011 C-5 NUREG-1943 

January 5, 2009 Letter from Mr. Donald L. Patterson, Tonkawa Tribe of Oklahoma, to the 

NRC transmitting reply to Environmental Review of the Comanche Peak 

Nuclear Power Plant, Units 3 and 4 Combined License Application 

(Accession No. ML090500590). 

January 8, 2009 Letter from Mr. David Bernhart, National Marine Fisheries Service, to 

William Burton, NRC, transmitting response to the Nuclear Regulatory 

Commission (NRC) letter dated December 23, 2008 regarding the 

Comanche Peak Nuclear Power Plant near Glen Rose, Texas (Accession 

No. ML090230148). 

January 30, 2009 Federal Register Notice - Comanche Peak Nuclear Power Plant, Units 3 

and 4, Opportunity to Petition for Leave to Intervene and Order Imposing 

Procedures for Access to Sensitive Unclassified Non-Safeguards (74 FR 

6177) (Accession No. ML090140359). 

January 30, 2009 Letter from Stephen Raul Monarque, NRC, to Mr. Mitch Lucas, Luminant, 

transmitting Comanche Peak Nuclear Power Plant, Units 3 and 4, 

Opportunity to Petition for Leave to Intervene and Order Imposing 

Procedures for Access to Sensitive Unclassified Non-Safeguards 

Information and Safeguards Information for Contention Preparation 

(Accession No. ML083440401). 

February 2, 2009 Memorandum from Michael Willingham, NRC, to William Burton, NRC, 

transmitting Summary of Public Scoping Meetings Related to the 

Combined License Application Review of the Comanche Peak Nuclear 

Power Plant, Units 3 and 4 (Accession No. ML090300226). 

February 5, 2009 Press Release No. 09-023: NRC Announces Opportunity to Participate In 

Hearing On New Reactor Application For Comanche Peak Site In Texas 

(Accession No. ML090360555). 

February 5, 2009 Letter from Mr. Mitch Lucas, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak, Units 3 and 4, Joint Venture 

Announcement and Name Change of Nuclear Project Company LLC 

(Accession No. ML090540056). 

February 13, 2009 Letter from Mr. Mitch Lucas, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak Nuclear Power Plant, Units 3 and 4, 

Submittal of Golden-Cheeked Warbler Report (Accession No. 

ML090490382). 

February 13, 2009 Letter from Mr. Mitch Lucas, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak, Units 3 and 4, Update Regarding 

Proprietary Information and Submittal of Nuclear Power Plant Siting 

Report (Accession No. ML090490419). 

February 13, 2009 Letter from Ms. Cathy Gilmore, Environmental Protection Agency, to 

Michael Lesar, NRC, transmitting Early Coordination Comanche Peak 

Nuclear Power Plant (Accession No. ML090680037). 

February 16, 2009 Letter from Mr. Carter Smith, Texas Parks and Wildlife Department, to 

Michael Lesar, NRC, transmitting Comanche Peak, Units 3 and 4 
Appendix C 

NUREG-1943 C-6 May 2011 

Combined License Application Environmental Impact Statement 

(Accession No. ML090680387). 

February 17, 2009 Letter from Ms. Charlene Dwin Vaughn, Advisory Council on Historic 

Preservation, to William Burton, NRC, transmitting reply to notification 

and request for consultation and participation in the scoping process for 

Units 3 and 4 Combined License Application Review for the Comanche 

Peak Nuclear Power Plant near Glen Rose, Texas (Accession No. 

ML090500077). 

February 19, 2009 E-mail from Sean Patrick Edwards, U.S. Fish and Wildlife Service, to 

Michael Willingham, NRC, comments in regard to Units 3 and 4 

Combined License Application Review for the Comanche Peak Nuclear 

Power Plant near Glen Rose, Texas (Accession No. ML092430749). 

February 23, 2009 Letter from James Biggins, NRC, to Representative Lon Burnam, State of 

Texas, transmitting Response to Request for Access to Sensitive 

Unclassified Non-Safeguards Information Luminant Generation Company, 

LLC, Comanche Peak Nuclear Power Plant, Units 3 and 4 (Accession No. 

ML090550065). 

February 23, 2009 Letter from James Biggins, NRC, to Mr. Robert Eye, Kaufman Eye, 

transmitting Response to Request for Access to Sensitive Unclassified 

Non-Safeguards Information Luminant Generation Company, LLC, 

Comanche Peak Nuclear Power Plant, Unit 3 and 4 (Accession No. 

ML090550232). 

February 23, 2009 Letter from James Biggins, NRC, to Mr. Tom “Smitty” Smith and 

Mr. Matthew Johnson, Public Citizen, Texas Office, transmitting 

Response to Request for Access to Sensitive Unclassified NonSafeguards Information Luminant Generation Company, LLC, Comanche 

Peak Nuclear Power Plant, Units 3 and 4 (Accession No. ML090550368). 

March 10, 2009 Letter from Gregory P. Hatchett, NRC, to Mr. Stephen Brooks, U.S. Army 

Corps of Engineers (USACE), transmitting CPNPP Units 3 and 4, 

Invitation Ltr. to Participate as a Cooperating Agency in the NRC Staff's 

Preparation of an Environmental Impact Statement (Accession No. 

ML090140149). 

March 31, 2009 Letter from Mr. Rafael Flores, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak, Units 3 and 4, Submittal of Documents to 

Facilitate Environmental Review (Accession No. ML091120524). 

April 2, 2009 Letter from Mr. Rafael Flores, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak, Units 3 and 4, Submittal of Combined 

License Application Update Tracking Report, Revision 0 (Accession No. 

ML091120280). 

April 15, 2009 Letter from Gregory P. Hatchett, NRC, to Mr. Don Woodlan, Luminant, 

transmitting Comanche Peak Nuclear Power Plant, Units 3 and 4, COL 

License Application Online Reference Portal (TAC RF2695) (Accession 

No. ML090890219). 
Appendix C 

May 2011 C-7 NUREG-1943 

April 15, 2009 Letter from Mr. Rafael Flores, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak, Units 3 and 4, Submittal of Documents to 

Facilitate the Environmental Review (Accession No. ML091120279). 

April 16, 2009 Letter from Mr. Rafael Flores, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak, Units 3 and 4, Transmittal of Combined 

License Application Update Tracking Report, Rev. 1 (Accession No. 

ML091130575). 

April 21, 2009 Letter from Mr. Rafael Flores, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak, Units 3 and 4, Response to Conditions for 

Using an Online Reference Portal During the Review of Combined 

License Application (Accession No. ML091120717). 

April 24, 2009 Letter from Ms. Karen Hardin, Texas Parks and Wildlife Department, to 

Michael Lesar, NRC, transmitting Comanche Peak, Units 3 and 4 

Combined License Application on Specific Yucca Species During Site 

Audit & Refined Data Regarding Known Occurrences of Rare Resources 

in Vicinity of Specific (Accession No. ML091310617). 

April 27, 2009 Letter from Mr. Rafael Flores, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak Nuclear Power Plant, Units 3 and 4, 

Submittal of Documents to Facilitate Environmental Review (Accession 

No. ML093290427). 

April 28, 2009 Letter from Mr. Rafael Flores, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak, Units 3 and 4 Combined License 

Application, Update Tracking Report (Accession No. ML091260719). 

May 8, 2009 Letter from Mr. Rafael Flores, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak, Units 3 and 4, Submittal of Document to 

Facilitate Environmental Review (Accession No. ML091320330). 

May 14, 2009 Letter from Mr. Rafael Flores, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak, Units 3 and 4 Combined License 

Application, Submittal of Update Tracking Report (Accession No. 

ML091400217). 

May 27, 2009 Letter from Mr. Rafael Flores, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak, Units 3 and 4, Submittal of Documents to 

Facilitate Environmental Review (Accession No. ML091490263). 

June 26, 2009 Letter from Michael Willingham, NRC, to Mr. Don Woodlan, Luminant, 

transmitting Request for Additional Information (RAI) Regarding the 

Environmental Review of the Combined License Application for 

Comanche Peak Nuclear Power Plant, Units 3 and 4 (Accession No. 

ML091460707). 

July 1, 2009 Memorandum from Michael Willingham, NRC, to Gregory P. Hatchett, 

NRC, transmitting Scoping Summary Report Related to the 

Environmental Scoping Process for the CPNPP, Units 3 and 4, COL 

Application (Accession No. ML091390873). 

July 20, 2009 Letter from Mr. Rafael Flores, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak, Units 3 and 4, First Partial Response to 
Appendix C 

NUREG-1943 C-8 May 2011 

Request for Additional Information re the Environmental Review of the 

Combined License Application (Accession No. ML092090653). 

July 24, 2009 Letter from Mr. Rafael Flores, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak, Units 3 and 4 Combined License 

Application Update Tracking Report (Accession No. ML092090582). 

July 27, 2009 Letter from Mr. Rafael Flores, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak, Units 3 and 4, Second Partial Response to 

Request for Additional Information Regarding the Environmental Review 

of the Combined License Application (Accession No. ML092180066). 

August 3, 2009 Letter from John Fringer, NRC, to Mr. Don Woodlan, Luminant, 

transmitting RAI - Regarding the Environmental Review of the COL 

Application for Comanche Peak Nuclear Power Plant, Units 3 and 4 

(Accession No. ML091970377). 

August 10, 2009 Letter from Mr. Rafael Flores, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak Nuclear Power Plant, Units 3 and 4, Final 

Partial Response to Request for Additional Information Regarding the 

Environmental Review of the Combined License Application (Accession 

No. ML092360142). 

August 12, 2009 Letter from Mr. Rafael Flores, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak Nuclear Power Plant, Units 3 and 4, 

Supplement to Final Partial Response to Request for Additional 

Information Regarding the Environmental Review of the Combined 

License Application of Comanche Peak Units 3 and 4 (Accession No. 

ML092290396). 

August 28, 2009 Letter from Mr. Rafael Flores, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak, Units 3 and 4, Supplemental Information for 

the Environmental Review RAI Questions SOC-09 through SOC-14 

(Accession No. ML092440358). 

September 1, 2009 Memorandum from John Fringer, NRC, to Gregory P. Hatchett, NRC, 

transmitting 08/12/2009 Summary of Teleconference Held with Luminant 

Generation Company LLC Regarding Requests for Additional Information 

(Accession No. ML092290018). 

September 9, 2009 Letter from Mr. Rafael Flores, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak Nuclear Power Plant, Units 3 and 4, 

Supplemental Information for Environmental Review RAI Responses 

(Accession No. ML093080095). 

September 14, 2009 Memorandum from Michael Willingham, NRC, to Gregory P. Hatchett, 

NRC, transmitting Trip Report - Ecology Site Audit and Alternative Sites 

Visit related to the Review of Luminant's Combined License Application 

for Comanche Peak Nuclear Power Plant, Units 3 and 4 (Accession No. 

ML091410721). 

September 16, 2009 Letter from Mr. Rafael Flores, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak, Units 3 and 4, Supplemental Information for 

the Environmental Review RAI, Questions GEN-03, HYD-16, SOC-23, 
Appendix C 

May 2011 C-9 NUREG-1943 

SOC-27, TE-04, TE-11, TE-15, TE-18, and TE-19 (Accession No. 

ML092640643). 

October 9, 2009 Memorandum from John Fringer, NRC, to Gregory P. Hatchett, NRC, 

transmitting Summary of Teleconference Held with Luminant Generation 

Company LLC Regarding Requests for Additional Information (Accession 

No. ML092590369). 

October 21, 2009 Letter from Mr. Rafael Flores, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak, Units 3 and 4 Combined License 

Application Update Tracking Report (FSAR #7, ER #5) (Accession No. 

ML093020156). 

December 4, 2009 Memorandum from Michael Willingham, NRC, to Gregory P. Hatchett, 

NRC, transmitting Summary of the Environmental Site Audit Related to 

the Review of the Luminant's Combined License Application for 

Comanche Peak Nuclear Power Plant, Units 3 and 4 (Accession No. 

ML092510499). 

December 7, 2009 Memorandum from John Fringer, NRC, to Gregory P. Hatchett, NRC, 

transmitting Summary of August 20, 2009, Teleconferences held with 

Luminant Generation Company LLC regarding Requests for Additional 

Information (Accession No. ML092880235). 

December 8, 2009 Letter from Rafael Flores, Luminant, to Dave Matthews, NRC, 

transmitting Comanche Peak Nuclear Power Plant, Units 3 and 4 

Combined License Application Part 3, Environmental Report, Revision 1, 

Update Tracking Report Revision 0 (Accession No. ML093440179). 

December 18, 2009 Letter from Rafael Flores, Luminant, to Dave Matthews, NRC, 

transmitting Comanche Peak Nuclear Power Plant, Units 3 and 4, 

Supplemental Information in Response to the Request for Additional 

Information Regarding the Environmental Review (Accession No. 

ML093620032). 

January 15, 2010 Letter from Michael Willingham, NRC, to Mr. Don Woodlan, Luminant, 

transmitting Request for Additional Information Regarding the 

Environmental Review of the COL Application for CPNPP, Units 3 and 4 

(Accession No. ML093280707). 

January 15, 2010 Letter from Rafael Flores, Luminant, to Dave Matthews, NRC, 

transmitting Comanche Peak Nuclear Power Plant, Units 3 and 4, COL 

Application Part 3, Environmental Report, Update Tracking Report 

(Accession No. ML100191529). 

January 19, 2010 Letter from Rafael Flores, Luminant, to Dave Matthews, NRC, 

transmitting Comanche Peak Nuclear Power Plant, Units 3 and 4, 

Corrections for COL Application Part 3, Environmental Report, Update 

Tracking Report (Accession No. ML100210301). 

January 19, 2010 Letter from Dave Matthews, NRC, to Rafael Flores, Luminant, 

transmitting Combined License Application Environmental Review 

Schedule for Comanche Peak Nuclear Power Plant, Units 3 and 4 

(Accession No. ML100260655). 
Appendix C 

NUREG-1943 C-10 May 2011 

February 24, 2010 Letter from Rafael Flores, Luminant, to Dave Matthews, NRC, 

transmitting Comanche Peak Nuclear Power Plant, Units 3 and 4, 

Response to Request for Additional Information Regarding the 

Environmental Review and Supplemental Information for Previous 

Environmental Questions (Accession No. ML100630660). 

March 3, 2010 Letter from Gregory P. Hatchett, NRC, to Donald Woodlan, Luminant, 

transmitting NRC Staff Clarification for the Environmental Impact of the 

Blow-down Treatment Facility Proposed in the Comanche Peak Nuclear 

Power Plant, Units 3 and 4 Combined License Application (Accession No. 

ML100500642). 

March 3, 2010 Letter from Rafael Flores, Luminant, to Dave Matthews, NRC, 

transmitting Comanche Peak Nuclear Power Plant, Units 3 and 4, COL 

Application Part 3, Environmental Report, Update Tracking Report 

Revision 3 (Accession No. ML100640170). 

March 5, 2010 Letter from Rafael Flores, Luminant, to Dave Matthews, NRC, 

transmitting Comanche Peak Nuclear Power Plant, Units 3 and 4, 

Response to Environmental Review Questions ALT-03 and SOC-33, and 

Supplemental Information for Question TE-04 (Accession No. 

ML100710613). 

March 9, 2010 Letter from Rafael Flores, Luminant, to Dave Matthews, NRC, 

transmitting Comanche Peak Nuclear Power Plant, Units 3 and 4, 

Supplemental Information for Environmental Review Requests for 

Additional Information HYD-11, HYD-18, and HYD-19 (Accession No. 

ML100710027). 

March 19, 2010 Letter from Rafael Flores, Luminant, to Dave Matthews, NRC, 

transmitting Comanche Peak Nuclear Power Plant, Units 3 and 4, 

Supplemental Information for Responses to Environmental Review 

Request for Additional Information GEN-03 and GEN-07 (Accession No. 

ML100820402). 

April 12, 2010 Letter from Rafael Flores, Luminant, to Dave Matthews, NRC, 

transmitting Comanche Peak Nuclear Power Plant, Units 3 and 4, 

Unclassified Change to Physical Security Plan Due to Squaw Creek 

Reservoir Opening (Accession No. ML101040261). 

May 6, 2010 Letter from Rafael Flores, Luminant to David B. Matthews, NRC, 

transmitting Comanche Peak Nuclear Power Plant, Units 3 and 4, COL 

Application Part 3, Environmental Report Revision 1, Update tracking 

Report Revision 4 (Accession No. ML101300088). 

July 12, 2010 Letter from Rafael Flores, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak Nuclear Power Plant, Units 3 and 4, Update 

Tracking Report Regarding Opening Squaw Creek Reservoir (Accession 

No. ML102030191). 

July 28, 2010 Letter from Rafael Flores, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak Nuclear Power Plant, Units 3 and 4, 

Request for Exemption from 10 CFR 50.71(e)(3)(iii) (Accession No. 

ML102110179). 
Appendix C 

May 2011 C-11 NUREG-1943 

August 6, 2010 Letter from Scott Flanders, NRC, to U.S. Environmental Protection 

Agency, Office of Federal Activities, transmitting Submittal of Draft 

Environmental Impact Statement for the Combined License for 

Comanche Peak Nuclear Power Plant, Units 3 and 4 (Accession No. 

ML101890752). 

August 6, 2010 Letter from Gregory P. Hatchett, NRC, to Don Woodlan, Luminant, 

transmitting Notice of Availability of the Draft Environmental Impact 

Statement Related to the Combined Licenses for the Comanche Peak 

Nuclear Power Plant, Units 3 and 4 (Accession No. ML101900378). 

August 6, 2010 Letter from Gregory P. Hatchett, NRC, to Tangela Niemann, Texas 

Commission on Environmental Quality, transmitting Notification of the 

Issuance of and Request for Comments on the Draft Environmental 

impact Statement for the Comanche Peak Nuclear Power Plant, Units 3 

and 4, Combined License Application Review (Accession No. 

ML101950280). 

August 6, 2010 Letter from Gregory P. Hatchett, NRC, to Tom Cloud, U.S. Fish & Wildlife 

Service, transmitting Request for Comments on the Draft Environmental 

Impact Statement and Biological Assessment Related to the Review of 

the Combined License Application for Comanche Peak Nuclear Power 

Plant, units 3 and 4 (Accession No. ML101960020). 

August 6, 2010 Letter from Gregory P. Hatchett, NRC, to David Bernhart, National Marine 

Fisheries Service, transmitting Notification of the Issuance of and 

Request for Comments on the Draft Environmental Impact Statement for 

the Comanche Peak Nuclear Power Plant, Units 3 and 4, Combined 

License Application Review (Accession No. ML101960039). 

August 6, 2010 Letter from Gregory P. Hatchett, NRC, to Kathy Boydston, Texas Parks 

and Wildlife Department, transmitting Notification of the Issuance of and 

Request for Comments on the Draft Environmental Impact Statement for 

the Comanche Peak Nuclear Power Plant, Units 3 and 4 Combined 

License Application Review (Accession No. ML1019600500). 

August 6, 2010 Letter from Gregory P. Hatchett, NRC, to Ronnie Lupe, White Mountain 

Apache Tribe, transmitting Section 106 Consultation and Notification of 

the Issuance of the Draft Environmental Impact Statement for the 

Comanche Peak Nuclear Power Plant, Units 3 and 4 Combined License 

Application Review (Accession No. ML102090382). 

August 10, 2010 Letter from Gregory P. Hatchett, NRC, to LaRue Parker, Caddo Nation of 

Oklahoma, transmitting Section 106 Consultation and Notification of the 

Issuance of the Draft Environmental Impact Statement for the Comanche 

Peak Nuclear Power Plant, Units 3 and 4 Combined License Application 

Review (Accession No. ML102180328). 

August 10, 2010 Letter from Gregory P. Hatchett, NRC, to Henry Kostzuta, Apache Tribe 

of Oklahoma, transmitting Section 106 Consultation and Notification of 

the Issuance of the Draft Environmental Impact Statement for the 

Comanche Peak Nuclear Power Plant, Units 3 and 4 Combined License 

Application Review (Accession No. ML102180335). 
Appendix C 

NUREG-1943 C-12 May 2011 

August 10, 2010 Letter from Gregory P. Hatchett, NRC, to Gary McAdams, Wichita and 

Affiliated Tribes, transmitting Section 106 Consultation and Notification of 

the Issuance of the Draft Environmental Impact Statement for the 

Comanche Peak Nuclear Power Plant, Units 3 and 4 Combined License 

Application Review (Accession No. ML102180341). 

August 10, 2010 Letter from Gregory P. Hatchett, NRC, to Charles Surveyor, Cheyenne 

and Arapaho Tribes of Oklahoma, transmitting Section 106 Consultation 

and Notification of the Issuance of the Draft Environmental Impact 

Statement for the Comanche Peak Nuclear Power Plant, Units 3 and 4 

Combined License Application Review (Accession No. ML102180356). 

August 10, 2010 Letter from Gregory P. Hatchett, NRC, to Lawrence Snake, Delaware 

Tribe of Western Oklahoma, transmitting Section 106 Consultation and 

Notification of the Issuance of the Draft Environmental Impact Statement 

for the Comanche Peak Nuclear Power Plant, Units 3 and 4 Combined 

License Application Review (Accession No. ML102180361). 

August 10, 2010 Letter from Gregory P. Hatchett, NRC, to Jimmy Arterberry, Comanche 

Nation, transmitting Section 106 Consultation and Notification of the 

Issuance of the Draft Environmental Impact Statement for the Comanche 

Peak Nuclear Power Plant, Units 3 and 4 Combined License Application 

Review (Accession No. ML102210305). 

August 10, 2010 Letter from Gregory P. Hatchett, NRC, to Don Patterson, Tonkawa Tribe 

of Indians of Oklahoma, transmitting Section 106 Consultation and 

Notification of the Issuance of the Draft Environmental Impact Statement 

for the Comanche Peak Nuclear Power Plant, Units 3 and 4 Combined 

License Application Review (Accession No. ML102210307). 

August 10, 2010 Letter from Gregory P. Hatchett, NRC, to Jim Roan Gray, Osage Nation, 

transmitting Section 106 Consultation and Notification of the Issuance of 

the Draft Environmental Impact Statement for the Comanche Peak 

Nuclear Power Plant, Units 3 and 4 Combined License Application 

Review (Accession No. ML102210316). 

August 10, 2010 Letter from Gregory P. Hatchett, NRC, to Mark Chino, Mescalero Apache 

Tribe, transmitting Section 106 Consultation and Notification of the 

Issuance of the Draft Environmental Impact Statement for the Comanche 

Peak Nuclear Power Plant, Units 3 and 4 Combined License Application 

Review (Accession No. ML102210327). 

August 10, 2010 Letter from Gregory P. Hatchett, NRC, to Donald Tofpi, Kiowa Indian 

Tribe of Oklahoma, transmitting Section 106 Consultation and Notification 

of the Issuance of the Draft Environmental Impact Statement for the 

Comanche Peak Nuclear Power Plant, Units 3 and 4 Combined License 

Application Review (Accession No. ML102210329). 

August 10, 2010 Letter from Gregory P. Hatchett, NRC, to Juan Garza, Kickapoo 

Traditional Tribe of Texas, transmitting Section 106 Consultation and 

Notification of the Issuance of the Draft Environmental Impact Statement 

for the Comanche Peak Nuclear Power Plant, Units 3 and 4 Combined 

License Application Review (Accession No. ML102210332). 
Appendix C 

May 2011 C-13 NUREG-1943 

August 10, 2010 Letter from Gregory P. Hatchett, NRC, to Larry Nuckolls, Absentee 

Shawnee Tribe, transmitting Section 106 Consultation and Notification of 

the Issuance of the Draft Environmental Impact Statement for the 

Comanche Peak Nuclear Power Plant, Units 3 and 4 Combined License 

Application Review (Accession No. ML102210352). 

August 11, 2010 Letter from Gregory P. Hatchett, NRC, to Gifford Velarde, Jicarilla Apache 

Nation, transmitting Section 106 Consultation and Notification of the 

Issuance of the Draft Environmental Impact Statement for the Comanche 

Peak Nuclear Power Plant, Units 3 and 4 Combined License Application 

Review (Accession No. ML102210333). 

August 11, 2010 Letter from Gregory P. Hatchett, NRC, to Joe Brooks, Delaware Tribe of 

East Oklahoma, transmitting Section 106 Consultation and Notification of 

the Issuance of the Draft Environmental Impact Statement for the 

Comanche Peak Nuclear Power Plant, Units 3 and 4 Combined License 

Application Review (Accession No. ML102210334). 

August 11, 2010 Letter from Gregory P. Hatchett, NRC, to Jeff Houser, Fort Sill Apache 

Tribe of Oklahoma, transmitting Section 106 Consultation and Notification 

of the Issuance of the Draft Environmental Impact Statement for the 

Comanche Peak Nuclear Power Plant, Units 3 and 4 Combined License 

Application Review (Accession No. ML102210337). 

August 11, 2010 Letter from Gregory P. Hatchett, NRC, to Bryant Celestine, AlabamaCoushatta Tribe of Texas, transmitting Section 106 Consultation and 

Notification of the Issuance of the Draft Environmental Impact Statement 

for the Comanche Peak Nuclear Power Plant, Units 3 and 4 Combined 

License Application Review (Accession No. ML102210338). 

August 12, 2010 Letter from Gregory P. Hatchett, NRC, to Mark Wolfe, Texas Historical 

Commission, transmitting Notification of the Issuance of and the Request 

for Comments on the Draft Environmental Impact Statement for the 

Comanche Peak Nuclear Power Plant, Units 3 and 4 Combined License 

Application Review (Accession No. ML101950205). 

August 12, 2010 Letter from Gregory P. Hatchett, NRC, to Reid Nelson, Advisory Council 

on Historic Preservation, transmitting Section 106 Consultation and 

Notification of the Issuance of the Draft Environmental Impact Statement 

for the Comanche peak Nuclear Power Plant, Units 3 and 4 Combined 

License Application Review (Accession No. ML101950267). 

August 12, 2010 Letter from Jim Harrison, Texas Commission on Environmental Quality, to 

Gregory P. Hatchett, NRC, transmitting TCEQ Grant and Texas Review 

and Comment System (TRACS) #2010-420, City of Glen Rose, Somervell 

County – Comanche Peak Nuclear Power Plant (Accession No. ML 

102600188). 

August 17, 2010 Letter from Michael Willingham, NRC, to Sheri McAllister, Hood County 

Library, transmitting Maintenance of Reference Materials at the Hood 

County Library for the Comanche Peak Nuclear Power Plant, Units 3 and 

4 Combined License Application (Accession No. ML101950427). 
Appendix C 

NUREG-1943 C-14 May 2011 

August 17, 2010 Letter from Michael Willingham, NRC, to Peggy Oldham, Somervell 

County Library, transmitting Maintenance of Reference Materials at the 

Somervell County Library for the Comanche Peak Nuclear Power Plant, 

Units 3 and 4 Combined License Application (Accession No. 

ML101950494). 

September 2, 2010 E-mail from Jason Ross, Delaware Nation, to Gregory P. Hatchett and 

Michael Willingham, NRC, transmitting Comments regarding the Draft 

Environmental Impact Statement for the Comanche Peak Nuclear Power 

Plant, Units 3 and 4 Combined License Application Environmental Review 

(Accession No. ML102500343). 

September 27, 2010 Letter from Stephen Monarque, NRC, to Donald Woodlan, Luminant, 

transmitting Comanche Peak Nuclear Power Plant, Units 3 and 4, 

Combined License Application – Exemption from the Requirements of 

Title 10 of the Code of Federal Regulations 50.71(e)(3)(iii) (Accession No. 

ML102360123). 

October 20, 2010 Letter from Stephen Spencer, U.S. Department of the Interior, to Chief, 

Rulemaking and Directives Branch, NRC, transmitting Draft 

Environmental Impact Statement (DEIS), NUREG-1943, for the 

Combined Licenses for Comanche Peak Nuclear Power Plant, Units 3 

and 4, Hood and Somervell Counties, Texas (Accession No. 

ML102980431). 

October 25, 2010 Letter from Rafael Flores, Luminant, to David Matthews, NRC, 

transmitting Comanche Peak Nuclear Power Plant, Units 3 and 4, 

Comments on the Draft Environmental Impact Statement (Accession No. 

ML102990431). 

October 26, 2010 Letter from Rhonda Smith, Environmental Protection Agency – Region 6, 

to Chief, Rulemaking and Directive Branch, NRC, transmitting Rating and 

Comments on the Draft Environmental Impact Statement (DEIS) dated 

August 2010, for the Comanche Peak Nuclear Power Plant (CPNPP) 

Units 3 and 4 (Accession No. ML103220200). 

November 5, 2010 Letter from Ross Melinchuk, Texas parks and Wildlife Department, to 

Cindy Bladey, NRC, transmitting Proposed Comanche peak Nuclear 

Power Plant Units 3 and 4 Combined License Application Review, Draft 

Environmental Impact Statement (DEIS), Somervell and Hood Counties 

(Accession No. ML103230413). 
Appendix D 

Scoping Comments and Responses

May 2011 D-1 NUREG-1943 

Appendix D 

Scoping Comments and Responses 

On December 12, 2008, the U.S. Nuclear Regulatory Commission (NRC) published a Notice of 

Intent to Prepare an Environmental Impact Statement and Conduct Scoping Process in the 

Federal Register (73 FR 77076-8). The Notice of Intent notified the public of the staff’s intent to 

prepare an environmental impact statement (EIS) and conduct scoping for the combined license 

(COL) application received from Luminant Generation Company LLC (Luminant), acting for itself 

and as agent for Nuclear Project Company LLC, for 2 units, identified as Comanche Peak 

Nuclear Power Plant (CPNPP) Units 3 and 4, to be located adjacent to the existing CPNPP 

Units 1 and 2, located approximately 40 mi southwest of Fort Worth, Texas. This EIS has been 

prepared in accordance with provisions of the National Environmental Policy Act of 1969 

(NEPA), Council on Environmental Quality guidelines, and Title 10 of the Code of Federal 

Regulations (CFR) Parts 51 and 52. As outlined by NEPA, the NRC initiated the scoping 

process with the issuance of the Federal Register Notice. The NRC invited the applicant; 

Federal, Tribal, State, and local government agencies; local organizations; and individuals to 

participate in the scoping process by providing oral comments at the scheduled public meeting 

and/or submitting written suggestions and comments no later than February 17, 2009. 

D.1 Overview of the Scoping Process 

The scoping process provides an opportunity for public participation to identify issues to be 

addressed in the EIS and to highlight public concerns and issues. The notice of intent identified 

the following objectives of the scoping process: 

 Define the proposed action that is to be the subject of the EIS. 

 Determine the scope of the EIS and identify significant issues to be analyzed in depth. 

 Identify and eliminate from detailed study those issues that are peripheral or that are not 

significant. 

 Identify any environmental assessments and other EISs that are being prepared or will be 

prepared that are related to, but not part of, the scope of the EIS being considered. 

 Identify other environmental review and consultation requirements related to the proposed 

action. 

 Identify parties consulting with the NRC under the National Historic Preservation Act 

(NHPA), as set forth in 36 CFR 800.8(c)(1)(i). 

 Indicate the relationship between the timing of the preparation of the environmental 

analyses and the NRC’s tentative planning and decision-making schedule. 

 Identify any cooperating agencies and, as appropriate, allocate assignments for preparation 

and schedules for completing the EIS to the NRC and any cooperating agencies. By letter 

dated April 21, 2009, the U.S. Army Corps of Engineers (USACE) accepted the NRC’s 

invitation to participate as a cooperating agency on the CPNPP Units 3 and 4 COL 

application environmental review. 

 Describe how the EIS will be prepared, and identify any contractor assistance to be used. 

Two public scoping meetings were held at the Glen Rose Expo Center, in Glen Rose, Texas, on 

January 6, 2009. The NRC announced the meetings in local and regional newspapers (Glen 

Rose Newspaper, Hood County News, and Fort Worth Star-Telegram) and issued press 
Appendix D 

NUREG-1943 D-2 May 2011 

releases locally. Approximately 110 people attended the afternoon scoping meeting and 

approximately 50 attended the evening session. The scoping meetings began with NRC staff 

members providing a brief overview of NRC’s review process for COL applications and the 

NEPA process. After the NRC’s prepared statements, the meetings were opened for public 

comments. 

Twenty-five (25) afternoon scoping meeting attendees and 26 evening scoping meeting 

attendees provided oral comments that were recorded and transcribed by a certified court 

reporter. Twelve (12) written statements were received during the meeting. In addition to the 

oral and written statements provided at the public scoping meeting, 2 letters and 30 e-mail 

messages were received during the scoping period. 

Transcripts for both afternoon and evening scoping meetings can be found in ADAMS under 

accession numbers ML090290409 and ML090291005, respectively. A scoping meeting 

summary memorandum (ML090300226) was issued February 2, 2009. 

At the conclusion of the scoping period, the NRC staff reviewed the scoping meeting transcripts 

and all written material received during the comment period and identified individual comments. 

These comments were organized according to topic within the proposed EIS or according to the 

general topic, if outside the scope of the EIS. Once comments were grouped according to 

subject area, the staff determined the appropriate response for the comment. The staff made a 

determination on each comment that it was one of the following: 

 A comment that was actually a question and introduced no new information. 

 A comment that was either related to support or opposition of combined licensing in general 

(or specifically the Comanche Peak Unit 3 and 4 COL) or that made a general statement 

about the COL process. In addition, it provided no new information and did not pertain to 

10 CFR Part 52. 

 A comment about an environmental issue that 

– provided new information that would require evaluation during the review 

– provided no new information. 

 A comment that was outside the scope of the COL, which included, but was not limited to 

– a comment on the safety of the existing units. 

Preparation of the EIS has taken into account the relevant issues raised during the scoping 

process. The comments received on the draft EIS will be considered in the preparation of the 

final EIS. The final EIS, along with the staff’s Safety Evaluation Report (SER), will provide much 

of the basis for the NRC’s decision on whether to grant the Comanche Peak Unit 3 and 4 COL. 

The comments related to this environmental review are included in this appendix. They were 

extracted from the Specific Plant Combined License Scoping Summary Report (ML091390849), 

and are provided for convenience of those interested specifically in the scoping comments 

applicable to this environmental review. The comments that are outside the scope of the 

environmental review for the proposed Comanche Peak Units 3 and 4 are not included in this 

Appendix. These include comments related to: 

 Safety 

 Emergency Preparedness 

 NRC Oversight for operating plants 

 Security and Terrorism 
Appendix D 

May 2011 D-3 NUREG-1943 

 Support or Opposition to the licensing action, licensing process, nuclear power, hearing 

process or the existing plant 

More detail regarding the disposition of general or out of scope comments can be found in the 

Scoping Summary Report (ML091390849). To maintain consistency with the Scoping Summary 

Report, the comment source ID and comment number along with the name of the commenter 

used in that report is retained in this appendix. 

Table D-1 identifies in alphabetical order the individuals providing comments during the scoping 

period, their affiliation, if given, and the ADAMS accession number that can be used to locate 

the correspondence. Although all commenters are listed, the comments presented in this 

appendix are limited to those within the scope of the environmental review. Table D-2 lists the 

comment categories in alphabetical order and commenter names and comment numbers for 

each category. The balance of this appendix presents the comments themselves with NRC 

staff responses organized by topic category. 
Appendix D 

NUREG-1943 D-4 May 2011 

Table D-1. Individuals Providing Comments During the Comment Period

Commenter Affiliation (if stated) Comment Source and 

ADAMS Accession # 

Correspondence 

ID Number 

Atkinson, Bill Glen Rose Chamber of 

Commerce 

Meeting Transcript 

(ML090290409) 0016 

Bahlburg, Kelly Self Email (ML090230174) 0013 

Bernhart, David NOAA, National Marine Fisheries 

Service Email (ML090230148) 0003 

Bernier, Jim Self Email (ML090300670) 0020 

Berry, Steve Hood County Meeting Transcript 

(ML090290409) 0016 

Bisbee, Kay Self Meeting Transcript 

(ML090291005) 0017 

Boydston, Kathy Texas Parks and Wildlife 

Department Email (ML090490221) 0029 

Burnam, Lon Texas Legislature Meeting Transcript 

(ML090290409) 0016 

Burnam, Lon Texas Legislature Meeting Transcript 

(ML090291005) 0017 

Cathey, Jack Self Meeting Transcript 

(ML090260390) 0018 

Cathey, Jack Self Meeting Transcript 

(ML090290409) 0016 

Chorost, Amy Self Email (ML090230169) 0012 

Cohn, Ann Self Meeting Transcript 

(ML090291005) 0017 

Downing, Kevin Self Meeting Transcript 

(ML090291005) 0017 

Drechel, Gary Self Email (ML090230155) 0007 

Duck, Kathy Self Email (ML090230157) 0009 

Duncan, Jim North Texas Renewable Energy Meeting Transcript 

(ML090291005) 0017 

Duvall-Gabriel, 

Najah 

Advisory Council on Historic 

Preservation Email (ML090500077) 0036 

Edwards, Chet U.S. House of Representatives Meeting Transcript 

(ML090260371) 0019 

English, Maurice Self Meeting Transcript 

(ML090290409) 0016 

Gentling, Suzanne Self Email (ML090490226) 0031 
Appendix D 

May 2011 D-5 NUREG-1943 

Table D-1. (contd) 

Commenter Affiliation (if stated) Comment Source and 

ADAMS Accession # 

Correspondence 

ID Number 

Hadden, Karen Sustainable Energy & Economic 

Development (SEED) Coalition Email (ML090230176) 0014 

Hadden, Karen Sustainable Energy & Economic 

Development (SEED) Coalition Email (ML09049231) 0033 

Hadden, Karen Sustainable Energy & Economic 

Development (SEED) Coalition Email (ML090480025) 0022 

Hadden, Karen Sustainable Energy & Economic 

Development (SEED) Coalition Email (ML090490224) 0030 

Hadden, Karen Sustainable Energy & Economic 

Development (SEED) Coalition 

Meeting Transcript 

(ML090260371) 0019 

Hadden, Karen Sustainable Energy & Economic 

Development (SEED) Coalition 

Meeting Transcript 

(ML090290409) 0016 

Hadden, Karen Sustainable Energy & Economic 

Development (SEED) Coalition 

Meeting Transcript 

(ML090291005) 0017 

Hale, Rod Self Meeting Transcript 

(ML090290409) 0016 

Harper, Debbie Self Meeting Transcript 

(ML090291005) 0017 

Harper, Paul Glen Rose Network Corp. Meeting Transcript 

(ML090291005) 0017 

Hind, Rebecca Nuclear Energy for Texans 

(NET) 

Meeting Transcript 

(ML090260390) 0018 

Illegible, Illegible Tokawa Tribe of Oklahoma Letter (ML090500590) 0037 

Independent School 

District, Glen Rose Self Meeting Transcript (ML090260371) 0019 

Inge, Charles and 

Dominique Self Email (ML090490218) 0028 

Johnson, Lisa City of Granbury Meeting Transcript 

(ML090290409) 0016 

Kinzie, W.T. Self Meeting Transcript 

(ML090290409) 0016 

Leising, Joe Self Meeting Transcript 

(ML090291005) 0017 

Lowe, Ed Friends of the Brazos River Email (ML090480028) 0025 

Luton, John Henry First National Bank of Granbury Email (ML090230149) 0004 

Marks, Gary Glen Rose Medical Center Meeting Transcript 

(ML090290409) 0016 

Maynard, Walter Somervell County 

Commissioners Court 

Meeting Transcript 

(ML090290409) 0016 
Appendix D 

NUREG-1943 D-6 May 2011 

Table D-1. (contd)

Commenter Affiliation (if stated) Comment Source and 

ADAMS Accession # 

Correspondence 

ID Number 

Maynard, Walter Somervell County 

Commissioners Court 

Meeting Transcript 

(ML090291005) 0017 

Mayo, Ann B. Self Email (ML090480029) 0026 

Meyers, Kevin Self Meeting Transcript 

(ML090290409) 0016 

Miller, Pam Glen Rose Meeting Transcript 

(ML090291005) 0017 

Miller, Russ 

Chalk Mountain Wildlife 

Management Association; Light 

Pollution Committee 

Email (ML090480030) 0024 

Norton, Barbara & 

Tom Self Letter (ML090500381) 0038 

Orcutt, David Lake Granbury Medical Center Meeting Transcript 

(ML090260390) 0018 

Orcutt, David Lake Granbury Medical Center Meeting Transcript 

(ML090290409) 0016 

Osowski Morgan, 

Sharon L. 

U.S. Environmental Protection 

Agency Email (ML090480031) 0027 

Otte, Melinda Comanche Peak WIN chapter Email (ML090230168) 0011 

Overstreet, Lee Granbury Rotary Club Meeting Transcript 

(ML090290409) 0016 

Phillips, Marilyn Somervell School District Meeting Transcript 

(ML090290409) 0016 

Phillips, Marilyn Somervell School District Meeting Transcript 

(ML090291005) 0017 

Ramsey, Terry Self Email (ML090230152) 0006 

Rash, Andy Hood County Commissioners 

Court 

Meeting Transcript 

(ML090290409) 0016 

Rash, Andy Hood County Commissioners 

Court 

Meeting Transcript 

(ML090291005) 0017 

Reed, Cyrus Lone Star Chapter of the Sierra 

Club Email (ML09040228) 0032 

Reed, Cyrus Lone Star Chapter of the Sierra 

Club Email (ML090490228 ) 0035 

Reed, Cyrus Lone Star Chapter of the Sierra 

Club 

Meeting Transcript 

(ML090290409) 0016 

Richardson, Karen Self Email (ML090430065) 0021 

Rittenhouse, Ryan Public Citizen Meeting Transcript 

(ML090291005) 0017 
Appendix D 

May 2011 D-7 NUREG-1943 

Table D-1. (contd)

Commenter Affiliation (if stated) Comment Source and 

ADAMS Accession # 

Correspondence 

ID Number 

Roan, Richard Self Meeting Transcript 

(ML090260390) 0018 

Roan, Richard Self Meeting Transcript 

(ML090290409) 0016 

Rooke, Molly Self Meeting Transcript 

(ML090291005) 0017 

Rosenfeld, Joshua Brazos River Conservation 

Commission 

Meeting Transcript 

(ML090290409) 0016 

Sanders, Jan Self Meeting Transcript 

(ML090291005) 0017 

Scott, Mike Granbury Chamber of 

Commerce 

Meeting Transcript 

(ML090260371) 0019 

Scott, Mike Granbury Chamber of 

Commerce 

Meeting Transcript 

(ML090290409) 0016 

Shaar, Julie Self Meeting Transcript 

(ML090290409) 0016 

Sheaks, Jerry Self Meeting Transcript 

(ML090291005) 0017 

Shroyer, Danielle Self Email (ML090230167) 0010 

Smith, Hugh Self Meeting Transcript 

(ML090290409) 0016 

Smith, Tom Texas Office of Public Citizen Email (ML090210450) 0002 

Spears, Linda Self Email (ML090230177) 0015 

Stamler, Richard Self Email (ML090230156) 0008 

Stuard, Gary Interfaith Environmental Alliance Meeting Transcript 

(ML090291005) 0017 

Sumners, Allen Self Meeting Transcript 

(ML090291005) 0017 

Sykes, Victoria Congressman Chet Edward's 

Office 

Meeting Transcript 

(ML090290409) 0016 

Taylor, Kevin Somervell County Water District Meeting Transcript 

(ML090290409) 0016 

Ubico, Jean Self Email (ML090480027) 0023 

Ward, Mary 

Granbury-Hood County 

Economic Development 

Corporation 

Meeting Transcript 

(ML090290409) 0016 
Appendix D 

NUREG-1943 D-8 May 2011 

Table D-1. (contd)

Commenter Affiliation (if stated) Comment Source and 

ADAMS Accession # 

Correspondence 

ID Number 

Wildwood, Kathleen Self Meeting Transcript 

(ML090290409) 0016 

Wohler, Will Self Meeting Transcript 

(ML090260390) 0018 

Wohler, Will Self Meeting Transcript 

(ML090291005) 0017 

Wolz, Conrad Trophy Club Texas Email (ML090230150) 0005 

Wyatt, Dr. Bill Self Meeting Transcript 

(ML090291005) 0017 

 
Appendix D 

May 2011 D-9 NUREG-1943 

Table D-2. Comment Categories with Associated Commenters and Comment IDs

Comment Category Commenter (Comment ID) 

Accidents-Design Basis  Gentling, Suzanne (0031-6) 

 Hadden, Karen (0017-26) (0022-47) (0022-54) 

 Osowski Morgan, Sharon L. (0027-4) 

 Reed, Cyrus (0032-10) 

Accidents-Severe  Burnam, Lon (0016-41) 

 Hadden, Karen (0019-11) (0022-28) (0022-45) 

 Harper, Debbie (0017-51) 

 Reed, Cyrus (0032-11) 

Alternatives-Energy  Bisbee, Kay (0017-47) 

 Burnam, Lon (0017-16) 

 Cohn, Ann (0017-34) (0017-37) 

 Duncan, Jim (0017-53) 

 Hadden, Karen (0016-12) (0016-14) (0016-15) (0016-17) (0016-19) 

(0016-20) (0019-7) (0022-5) (0022-48) (0022-49) (0022-50) (0022-

51) (0030-2) (0030-7) 

 Osowski Morgan, Sharon L. (0027-3) 

 Reed, Cyrus (0016-51) (0032-14) (0032-15) (0032-17) 

 Rittenhouse, Ryan (0017-61) 

 Sanders, Jan (0017-73) 

 Shaar, Julie (0016-76) 

 Shroyer, Danielle (0010-2) 

 Stuard, Gary (0017-79) 

 Wildwood, Kathleen (0016-61) 

 Wohler, Will (0017-59) (0018-3) 

Alternatives-No-Action  Wohler, Will (0017-58) 

Alternatives-System Design  Hadden, Karen (0022-19) (0022-41) 

 Lowe, Ed (0025-2) 

 Miller, Russ (0024-1) 

 Osowski Morgan, Sharon L. (0027-6) (0027-8) (0027-11) 

 Reed, Cyrus (0032-12) 
Appendix D 

NUREG-1943 D-10 May 2011 

Table D-2. (contd)

Comment Category Commenter (Comment ID) 

Benefit-Cost Balance  Gentling, Suzanne (0031-8) 

 Hadden, Karen (0019-8) (0030-1) 

 Harper, Debbie (0017-50) 

 Osowski Morgan, Sharon L. (0027-24) (0027-26) 

 Richardson, Karen (0021-3) 

 Sanders, Jan (0017-81) 

 Stuard, Gary (0017-77) 

 Ubico, Jean (0023-7) 

Cumulative Impacts  Burnam, Lon (0016-37) 

 Cathey, Jack (0016-65) 

 Hadden, Karen (0022-24) (0022-27) 

 Osowski Morgan, Sharon L. (0027-25) 

 Reed, Cyrus (0032-9) 

 Rittenhouse, Ryan (0017-64) (0017-65) 

 Stuard, Gary (0017-78) 

Decommissioning  Burnam, Lon (0016-38) 

 Hadden, Karen (0022-16) (0022-17) (0022-39) 

 Inge, Charles and Dominique (0028-3) 

 Reed, Cyrus (0032-18) 

Ecology-Aquatic  Bernier, Jim (0020-2) 

 Boydston, Kathy (0029-1) (0029-3) (0029-5) (0029-16) (0029-17) 

(0029-18) (0029-19) 

 Burnam, Lon (0016-43) (0017-18) 

 Cathey, Jack (0016-64) (0018-5) (0018-7) 

 Gentling, Suzanne (0031-3) 

 Hadden, Karen (0019-12) (0022-8) (0022-11) (0022-13) (0022-18) 

(0022-21) 

 Kinzie, W.T. (0016-69) 

 Lowe, Ed (0025-1) 

 Osowski Morgan, Sharon L. (0027-10) (0027-21) 

 Reed, Cyrus (0032-7) 
Appendix D 

May 2011 D-11 NUREG-1943 

Table D-2. (contd)

Comment Category Commenter (Comment ID) 

Ecology-Terrestrial  Boydston, Kathy (0029-2) (0029-6) (0029-7) (0029-8) (0029-9) 

(0029-10) (0029-11) (0029-12) (0029-13) (0029-14) (0029-15) 

(0029-21) (0029-22) (0029-23) (0029-24) (0029-25) 

 Hadden, Karen (0022-14) 

 Miller, Russ (0024-2) 

 Osowski Morgan, Sharon L. (0027-7) (0027-22) (0027-23) 

Environmental Justice  Hadden, Karen (0019-25) 

 Osowski Morgan, Sharon L. (0027-20) 

Geology  Hadden, Karen (0019-22) (0022-9) 

Health-Radiological  Burnam, Lon (0016-39) (0017-10) (0017-14) (0017-17) 

 Gentling, Suzanne (0031-4) 

 Hadden, Karen (0016-21) (0016-22) (0016-25) (0019-9) (0019-10) 

(0019-15) (0019-27) (0022-7) (0022-12) (0022-15) (0022-26) (0022-

29) (0022-30) (0022-35) (0022-36) (0022-37) (0022-38) (0022-40) 

 Osowski Morgan, Sharon L. (0027-5) 

 Reed, Cyrus (0016-53) (0016-54) (0032-8) 

 Rittenhouse, Ryan (0017-62) 

 Rooke, Molly (0017-38) (0017-39) 

 Sanders, Jan (0017-69) (0017-71) 

Historic and Cultural 

Resources 

 Duvall-Gabriel, Najah (0036-1) 

 Illegible, Illegible (0037-1) 

 Osowski Morgan, Sharon L. (0027-19) 

Hydrology-Groundwater  Cohn, Ann (0017-35) 

 Hadden, Karen (0019-13) (0019-14) (0019-28) 

 Kinzie, W.T. (0016-66) 

 Osowski Morgan, Sharon L. (0027-15) (0027-16) 

 Richardson, Karen (0021-2) 

 Rooke, Molly (0017-40) (0017-43) 
Appendix D 

NUREG-1943 D-12 May 2011 

Table D-2. (contd)

Comment Category Commenter (Comment ID) 

Hydrology-Surface Water  Bernier, Jim (0020-1) 

 Berry, Steve (0016-28) 

 Burnam, Lon (0016-42) 

 Cathey, Jack (0016-63) (0018-4) (0018-6) 

 Gentling, Suzanne (0031-2) 

 Hadden, Karen (0016-23) (0019-16) (0019-17) (0019-31) (0019-32) 

(0022-6) (0022-10) (0022-20) (0022-22) (0022-55) (0030-5) 

 Inge, Charles and Dominique (0028-1) (0028-2) 

 Kinzie, W.T. (0016-62) (0016-68) 

 Osowski Morgan, Sharon L. (0027-9) (0027-12) (0027-13) (0027-

14) 

 Reed, Cyrus (0016-52) (0032-5) (0032-6) 

 Richardson, Karen (0021-1) 

 Rooke, Molly (0017-41) (0017-42) 

 Rosenfeld, Joshua (0016-79) 

 Sanders, Jan (0017-66) (0017-72) 

 Stamler, Richard (0008-1) 

 Stuard, Gary (0017-76) 

Land Use-Site and Vicinity  Luton, John Henry (0004-3) 

Land Use-Transmission 

Lines 

 Hadden, Karen (0019-24) 

Meteorology and Air Quality  Osowski Morgan, Sharon L. (0027-18) 
Appendix D 

May 2011 D-13 NUREG-1943 

Table D-2. (contd)

Comment Category Commenter (Comment ID) 

Need for Power  Burnam, Lon (0017-11) (0017-15) 

 Hadden, Karen (0016-13) (0019-21) (0030-8) 

 Reed, Cyrus (0016-50) (0032-16) 

 Bisbee, Kay (0017-46) 

 Cohn, Ann (0017-33) 

 Gentling, Suzanne (0031-1) 

 Harper, Debbie (0017-52) 

 Mayo, Ann B. (0026-3) 

 Stuard, Gary (0017-74) 

 Burnam, Lon (0016-45) 

 Hadden, Karen (0016-10) (0017-19) (0017-20) (0017-21) (0017-22) 

(0017-23) (0017-24) (0017-25) (0019-29) (0022-1) (0022-2) 

 Harper, Debbie (0017-49) 

 Mayo, Ann B. (0026-2) 

 Reed, Cyrus (0016-48) (0016-56) (0032-1) (0032-2) 

 Duncan, Jim (0017-54) 

 Hadden, Karen (0016-11) (0019-6) 

 Mayo, Ann B. (0026-1) 

 Reed, Cyrus (0016-49) 

 Rittenhouse, Ryan (0017-60) 

 Shroyer, Danielle (0010-1) 

 Wolz, Conrad (0005-1) 

 Berry, Steve (0016-27) 

 Burnam, Lon (0017-13) 

 Downing, Kevin (0017-31) 

 Hadden, Karen (0019-18) (0019-19) (0019-20) (0022-46) 

 Inge, Charles and Dominique (0028-4) 

 Maynard, Walter (0017-6) 

 Norton, Barbara & Tom (0038-2) 

 Hadden, Karen (0022-52) 

 Inge, Charles and Dominique (0028-5) 

 Smith, Tom (0002-1) 

 Hadden, Karen (0017-27) (0022-42) 

 Shroyer, Danielle (0010-4) 

 Hadden, Karen (0030-3) 

 Burnam, Lon (0016-36) 

 Hadden, Karen (0017-28) (0019-33) (0022-33) (0022-53) (0030-4) 

 Inge, Charles and Dominique (0028-6) 

 Kinzie, W.T. (0016-67) 

 Reed, Cyrus (0032-13) 

 Shroyer, Danielle (0010-3) 
Appendix D 

NUREG-1943 D-14 May 2011 

Table D-2. (contd)

Comment Category Commenter (Comment ID) 

Process-NEPA  Chorost, Amy (0012-1) 

 Downing, Kevin (0017-30) 

 Osowski Morgan, Sharon L. (0027-1) (0027-2) (0027-27) 

Site Layout and Design  Boydston, Kathy (0029-4) 

 Osowski Morgan, Sharon L. (0027-17) 

 Rooke, Molly (0017-44) 

 Ubico, Jean (0023-2) (0023-3) (0023-4) (0023-5) (0023-6) 
Appendix D 

May 2011 D-15 NUREG-1943 

Table D-2. (contd)

Comment Category Commenter (Comment ID) 

Socioeconomics  Boydston, Kathy (0029-20) 

 Burnam, Lon (0017-12) 

 Drechel, Gary (0007-1) 

 Hadden, Karen (0019-23) (0022-23) 

 Johnson, Lisa (0016-3) 

 Kinzie, W.T. (0016-70) 

 Luton, John Henry (0004-4) 

 Miller, Pam (0017-1) 

 Miller, Russ (0024-3) 

 Rosenfeld, Joshua (0016-78) 

 Sheaks, Jerry (0017-56) 

 Ubico, Jean (0023-1) 

 Ward, Mary (0016-32) 

 Atkinson, Bill (0016-47) 

 Bahlburg, Kelly (0013-1) 

 Berry, Steve (0016-26) (0016-29) 

 Downing, Kevin (0017-32) 

 Duck, Kathy (0009-1) 

 English, Maurice (0016-74) 

 Hind, Rebecca (0018-8) 

 Independent School District, Glen Rose (0019-2) 

 Johnson, Lisa (0016-2) 

 Leising, Joe (0017-55) 

 Luton, John Henry (0004-2) 

 Marks, Gary (0016-59) 

 Maynard, Walter (0016-5) (0017-5) 

 Meyers, Kevin (0016-46) 

 Miller, Pam (0017-2) 

 Norton, Barbara & Tom (0038-1) 

 Orcutt, David (0016-72) (0018-2) 

 Overstreet, Lee (0016-62) 

 Phillips, Marilyn (0016-31) (0017-9) 

 Ramsey, Terry (0006-1) 

 Rash, Andy (0016-7) (0016-9) (0017-7) 

 Roan, Richard (0016-6) (0018-1) 

 Scott, Mike (0016-34) (0019-3) 

 Sheaks, Jerry (0017-57) 

 Smith, Hugh (0016-77) 

 Sumners, Allen (0017-80) 

 Sykes, Victoria (0016-57) 

 Taylor, Kevin (0016-35) 
Appendix D 

NUREG-1943 D-16 May 2011 

D.2 In-Scope Comments and Responses 

The in-scope comment categories are listed alphabetically in Table D-3 in the order that they 

are presented in this EIS. In-scope comments and responses are included below the table. 

Parenthetical numbers shown after each comment refer to the Comment Identification (ID) 

number (document number-comment number) and the commenter name.

Table D-2. (contd)

Comment Category Commenter (Comment ID) 

 Ward, Mary (0016-33) 

 Wyatt, Dr. Bill (0017-29) 

 Edwards, Chet (0019-1) 

 Spears, Linda (0015-1) 

 English, Maurice (0016-73) 

 Hale, Rod (0016-71) 

 Johnson, Lisa (0016-1) 

 Luton, John Henry (0004-1) 

 Marks, Gary (0016-58) 

 Maynard, Walter (0016-4) (0017-4) 

 Miller, Pam (0017-3) 

 Phillips, Marilyn (0016-30) (0017-8) 

 Rash, Andy (0016-8) 

Transportation  Gentling, Suzanne (0031-7) 

Uranium Fuel Cycle  Burnam, Lon (0016-40) (0016-44) 

 Cohn, Ann (0017-36) 

 Gentling, Suzanne (0031-5) 

 Hadden, Karen (0016-16) (0016-18) (0016-24) (0019-26) (0019-30) 

(0022-3) (0022-4) (0022-25) (0022-31) (0022-32) (0022-34) 

(0022-43) (0022-44) (0030-6) 

 Harper, Paul (0017-48) 

 Reed, Cyrus (0016-55) (0032-3) (0032-4) 

 Rittenhouse, Ryan (0017-63) 

 Rooke, Molly (0017-45) 

 Sanders, Jan (0017-67) (0017-68) (0017-70) 

 Shaar, Julie (0016-75) 

 Stuard, Gary (0017-75) 

 Wildwood, Kathleen (0016-60) 
Appendix D 

May 2011 D-17 NUREG-1943 

Table D-3. Comment Categories in Order as Presented in This Report

D.2.2 Comments Concerning Process - NEPA 

D.2.3 Comments Concerning Site Layout and Design 

D.2.4 Comments Concerning Land Use - Site and Vicinity 

D.2.5 Comments Concerning Land Use - Transmission Lines 

D.2.6 Comments Concerning Meteorology and Air Quality 

D.2.7 Comments Concerning Geology 

D.2.8 Comments Concerning Hydrology - Surface Water 

D.2.9 Comments Concerning Hydrology - Groundwater 

D.2.10 Comments Concerning Ecology - Terrestrial 

D.2.11 Comments Concerning Ecology - Aquatic 

D.2.12 Comments Concerning Socioeconomics 

D.2.13 Comments Concerning Historic and Cultural Resources 

D.2.14 Comments Concerning Environmental Justice 

D.2.16 Comments Concerning Health - Radiological 

D.2.17 Comments Concerning Accidents - Design Basis 

D.2.18 Comments Concerning Accidents - Severe 

D.2.19 Comments Concerning the Uranium Fuel Cycle 

D.2.20 Comments Concerning Transportation 

D.2.21 Comments Concerning Decommissioning 

D.2.23 Comments Concerning Cumulative Impacts 

D.2.25 Comments Concerning the Need for Power 

D.2.26 Comments Concerning Alternatives - No-Action 

D.2.27 Comments Concerning Alternatives - Energy 

D.2.28 Comments Concerning Alternatives - System Design 

D.2.30 Comments Concerning Benefit - Cost Balance 
Appendix D 

NUREG-1943 D-18 May 2011 

D.2.2 Comments Concerning Process - NEPA 

Comment: Please seriously consider environmental impact when deciding on the two new 

reactors proposed for the Comanche Peak site. (0012-1 [Chorost, Amy]) 

Response: The NRC Staff is considering the potential environmental impacts of the proposed 

licensing action. An explanation of the NRC's approach to evaluating and documenting 

environmental impacts is available in Title 10 of the Code of Federal Regulations, Part 51. 

Comment: I think that with the due diligence that is represented by the people in this room, by 

the due diligence of the people that I know at the plant. 

You have heard of Bruce Turner's name tonight several times. I have a lot of faith and 

confidence in that gentleman, and in other people like him that work for Luminant. 

Environmental impact studies need to happen. (0017-30 [Downing, Kevin]) 

Response: This comment provides no information related to the scope of this EIS and will 

therefore not be considered further in the staff's environmental review. 

Comment: The need for the project should be clearly stated, as well as potential benefits and 

adverse effects of the proposed project. Project impacts and impact mitigation are evaluated in 

the context of project need. (0027-1 [Osowski Morgan, Sharon L.]) 

Response: The purpose and need for the proposed power plant will be explained in Section 

1.3 of the EIS. The impacts and alternatives will be evaluated in the context for the project 

need. 

Comment: The analysis of alternatives is the core of the NEPA process. The forthcoming 

Environmental Impact Statement (EIS) should include a minimum of two feasible action 

alternatives to be fully considered, as well as the No-Action Alternative. 

A rationale for rejecting certain alternatives from further consideration should be provided. The 

rationale should include environmental reasons, along with other considerations. The selected 

alternative should avoid/minimize adverse impacts, so that the need for mitigation of impacts will 

be lessened or eliminated. A critical factor of the alternatives analysis is the 

avoidance/minimization of adverse impacts. (0027-2 [Osowski Morgan, Sharon L.]) 

Response: Analysis of alternatives is at the heart of the NEPA process. Chapter 9 of the EIS 

will evaluate appropriate alternatives to the proposed action and explain why other alternatives 

were not examined in detail. Mitigation measures will be examined and addressed as 

appropriate in Chapters 4 and 5 of the EIS. 

Comment: There is no mention of CPNPP participation in EPA's Performance Track Program 

or whether CPNPP has an Environmental Management System (EMS) in place. The Council on 

Environmental Quality (CEQ) published Aligning NEPA processes with Environmental 

management Systems-A Guide for NEPA and EMS Practitioners to improve NEPA 

implementation and environmental sustainability goals in NEPA and Executive Order 13423. 

The NEPA document should discuss EMS as appropriate. (0027-27 [Osowski Morgan, 

Sharon L.]) 

Response: Although the NRC does not require nuclear power plants to employ an 

environmental management system (EMS), the NRC will evaluate whether or not Luminant has 

developed an EMS and its use in the development of the environmental report in Section 3.3 of 

the EIS. 
Appendix D 

May 2011 D-19 NUREG-1943 

D.2.3 Comments Concerning Site Layout and Design 

Comment: do you know what would happen when the ambient temperature becomes too high, 

and the water temperature becomes too high for the plant to operate safely? And when that 

happens, do you have plans in place? Do you know what would happen at that point? 

(0017-44 [Rooke, Molly]) 

Response: Section 3.3.2.2 of the EIS will explain what changes to plant operations would be 

initiated in response to unusually high ambient temperatures. At minimum, plant power would 

be reduced to ensure continued safe plant operation within the constraint of the available 

cooling capacity. Analyses for the EIS and/or environmental regulator requirements may also 

lead to additional constraints on plant power to protect environmental resources. 

Comment: How long are spent rods from nuclear waste stored in temporary pools from the 

existing Comanche Peak reactor? (0023-2 [Ubico, Jean]) 

Comment: How many pounds of nuclear waste presently exist in the temporary storage bins at 

Comanche Peak? (0023-3 [Ubico, Jean]) 

Comment: How much additional nuclear waste will be generated as the nuclear reactor ages? 

(0023-5 [Ubico, Jean]) 

Comment: What is the long-term plan for disposal of nuclear waste at Comanche Peak? 

(0023-6 [Ubico, Jean]) 

Response: Section 3.3.3 of the EIS will describe radioactive waste management activities 

associated with operation of the proposed units. The environmental impacts of waste 

management activities will be discussed in Chapter 6 of the EIS. 

Comment: How much additional waste will be generated per day by the proposed construction 

of the two additional reactors? (0023-4 [Ubico, Jean]) 

Comment: Chapter 3 -Plant Description 

The ER does not provide details of the site plan for the blowdown treatment facility (BDTF) other 

than large blocks showing the proposed location. The February 2, 2009 site visit indicated that 

several ponds of unknown size, shape or location would be constructed within this area. Power 

transmission lines were observed in the area. 

Comment: The size, shape, and location of the BDTF ponds relative to the transmission lines 

need to be revealed in a site plan drawing. (0029-4 [Boydston, Kathy]) 

Response: Plant construction will be described in Section 3.3 of the EIS. The plant description 

will include details requested in the comments. 

Comment: The ER does not provide much information on meeting the requirements of the 

Resource Conservation and Recovery Act (RCRA). Clarification on RCRA permitting of Units 3 

and 4, hazardous waste satellite accumulation areas, and storage times (i.e., greater than 

90 days) is requested. 

The contaminant monitoring list seems too narrow. We recommend reviewing site operations, 

wastes, chemical storage and use, etc. to determine appropriateness of including other 

contaminants on list. The constituents of concern (COC's) should reflect the actual constituents 

and their daughter or degradation products that are being utilized by CPNPP. 
Appendix D 

NUREG-1943 D-20 May 2011 

The information on solid waste management should be expanded. Discussion should include 

summary of how groundwater monitoring will include all RCRA wastes and any potential solid 

waste management units. (0027-17 [Osowski Morgan, Sharon L.]) 

Response: Section 3.3.4 of the EIS will describe nonradioactive waste management systems, 

including systems for management of hazardous materials. 

D.2.4 Comments Concerning Land Use - Site and Vicinity 

Comment: The expansion of the current plant allows the wise use of the existing infrastructure 

??? cooling lake, transmission lines, and the like with little or no impact on surrounding 

landowners or the environment. (0004-3 [Luton, John Henry]) 

Response: The impacts on land use resulting from construction and operation of the proposed 

facility will be discussed in Chapters 4 and 5 of the EIS. 

D.2.5 Comments Concerning Land Use - Transmission Lines 

Comment: 

What land will need to be condemned or purchased in order to build or upgrade new 

transmission lines? 

What environmental and economic impacts will result from new transmission lines, including the 

345 kV line planned to go between the plant site and the Whitney Switch, going through much of 

Somervell and Bosque Counties? (0019-24 [Hadden, Karen]) 

Response: Environmental impacts associated with any planned new transmission rights-ofway will be addressed in Chapters 4 and 5 of the EIS, as will potential impacts associated with 

any upgrades to existing lines or corridors. The applicant is required to follow all Federal, State, 

and local guidelines concerning siting, construction, and maintenance of proposed transmission 

corridors and lines, although the NRC does not have regulatory authority over these activities. 

D.2.6 Comments Concerning Meteorology and Air Quality 

Comment: All emissions resulting from the project must be in compliance with all applicable air 

quality regulations, particularly relative to the National Ambient Air Quality Standards (NAAQS) 

for criteria air pollutants (e.g., ozone, carbon monoxide, nitrogen oxides, sulfur dioxide, lead and 

particulates). All construction equipment should be tuned to manufacturer's specifications to 

reduce air emissions. We recommend water for fugitive dust control during construction, instead 

of oils and other chemicals. (0027-18 [Osowski Morgan, Sharon L.]) 

Response: The NRC staff will evaluate air quality impacts from construction and operation of 

the station in Chapters 4 and 5, respectively, of the EIS. This evaluation will include 

assessment of potential equipment operation and dust control measures that may be used to 

reduce emissions. 

D.2.7 Comments Concerning Geology 

Comment: Subsidence is a shifting downward of the earth's surface. Causes of subsidence 

include depleted groundwater, mining, natural gas and oil extraction. What impacts are there 

from existing industries that put the area at risk? What landfills are still in existence that could 

contaminate cooling water? Will local oil and gas operations impact the plant site or vice versa? 

(0019-22 [Hadden, Karen]) 
Appendix D 

May 2011 D-21 NUREG-1943 

Response: Geologic impacts on the proposed facility from off-site actions are within the scope 

of the safety analysis and will be addressed in the (final safety analysis report) (FSAR) issued 

and maintained by the applicant and in the SER issued by the NRC. The topic of subsidence 

and the potential impact on the proposed facility will be addressed in Section 2.5 of the 

FSAR. This portion of the comment is out of scope with regard to the EIS. The impacts of nonplant discharges to water bodies used for Unit 3 and 4 makeup water will be addressed in the 

EIS, as will cumulative impacts of Unit 3 and 4 water use and discharges on local and regional 

water resources. 

Comment: Additional analysis should be undertaken to determine the long-term viability of the 

Squaw Creek Reservoir retention structure under various scenarios including seismic events, 

protracted drought and abandonment by the licensee. (0022-9 [Hadden, Karen]) 

Response: The availability of water for Unit 3 and 4 operations and its potential impact on 

water availability for Unit 1 and 2 operations will be addressed in the EIS. Seismic hazards are 

outside of the scope of the environmental review. As part of the NRC's site safety review, the 

staff considers whether, taking into consideration the site criteria in 10 CFR Part 100 and 

information provided by the applicant, a proposed reactor or reactors can be constructed and 

operated without undue risk to the health and safety of the public. Abandonment of Squaw 

Creek Dam by the licensee is outside the scope of the EIS, but would be regulated by the Texas 

Commission on Environmental Quality (TCEQ) under Title 30 of the Texas Administrative Code, 

Chapter 299, and would be addressed by State and Federal regulations governing 

decommissioning and operating license termination for the nuclear plant. 

D.2.8 Comments Concerning Hydrology - Surface Water 

Comment: my question relates to the water requirement. I know from experience that when the 

Comanche peak reservoir gets low, they drain Lake Granbury to make up the difference. I’ve 

seen our lake drop over a foot and a half in less than a week during severe drought conditions. 

This combined with Brazos River Authorities recent decision to sell millions of gallons of water 

to the natural gas industry looks like it can form a perfect storm to drain our lake during these 

times of drought. (0008-1 [Stamler, Richard]) 

Comment: We need to look closely at water that would be used. I've looked into the license 

application and found that each reactor, and there's two, would use over 30,000 gallons of water 

every single minute. And that's huge. And the acre-feet per year are also extensive. There are 

some diagrams and some facts and figures that we'll be glad to get to you. (0016-23 [Hadden, 

Karen]) 

Comment: And, you know, even our lake—we'll talk about our lake. Granbury is built on a lake 

community. The whole community, we're lucky, because our water is used to cool those 

reactors. Because of that, we're not a constant-level lake with BRA, but because of that reason, 

our lake always will have access to water. (0016-28 [Berry, Steve]) 

Comment: I think we've barely begun to look at the water quantity and quality issues here, but 

I do find it interesting the reminder that the lake is a guaranteed constant-level lake. Well, what 

do you think that does to everybody else down river? (0016-42 [Burnam, Lon]) 

Comment: It's been mentioned about the water flow down the Brazos River. In the—every 

Thursday in the Fort Worth paper, it tells how much low the lakes are and the water flow. The 

last—on the first of this year, the PK, where this water comes from and where it would have to 

be released from if it came here, was 2-1/2 foot low, and the floatation was below minimum. So 
Appendix D 

NUREG-1943 D-22 May 2011 

if this—if y'all's lake here and your river needs more water, you're going to have to find 

someplace else to get it. 

Granbury was also 2-1/4 foot low.. It was below minimum floatation, and the water flow was 30 

cubic feet per second. And Whitney is 20 [cubic] feet per second. Sounds like the river is drying 

up. Their floatation is also below minimum. Whitney was 9-3/4 foot low. 

(0016-62 [Kinzie, W.T.]) 

Comment: The water is the biggest issue of all, I would think, because there's so much a 

demand for it. And if this plant takes more water than it's already taking, then, of course, they 

have to release more water from the Brazos River Authority. However, when they release this 

water, the plant takes the water, and that leaves nothing coming down the river, the Brazos 

River. (0016-63 [Cathey, Jack]) 

Comment: So the people here may have to make a choice between, what it said in the paper, 

$22 billion in the economic impact and how good that's going to do you when you have no 

drinking water. And that problem is hitting the Dallas-Fort Worth area also. 

Lon, you probably know the more specifics on the Dallas-Fort Worth area trying to have another 

lake or two built, reservoirs for drinking water? And the people in the local areas didn't want their 

land flooded to make a lake, so it's not going to happen. So Fort Worth and Dallas are trying to 

get other places for their drinking water. And it's getting to them to where they're not so much 

worried about their electricity and where it comes from, nuclear power or gas. They're worried 

about water. (0016-68 [Kinzie, W.T.]) 

Comment: our water which we use for drinking water and for recreation, will also be under 

pressure. So, we have to be very careful, as many have already stated, about the water. (0016-

79 [Rosenfeld, Joshua]) 

Comment: how will the use of the water affect the run of the river water needed for 

environmental flows? (0017-41 [Rooke, Molly]) 

Comment: if global warming, climate change is occurring, and as severe as we anticipate, will 

there be enough water for cooling decline, with a 35 percent decrease, when it occurs, in river 

flows? (0017-42 [Rooke, Molly]) 

Comment: Waste of water. (0017-66 [Sanders, Jan]) 

Comment: Water; we need to be conserving water. Not developing an energy form that is 

going to soak it up. We need it for our plants, for our agriculture. We need it to keep on cooling 

the two reactors that we already have, not building two more. (0017-72 [Sanders, Jan]) 

Comment: it is now being predicted that the Southwestern part of the United States will be 

suffering from a permanent drought for many years. We already see that water is a shortage of 

water is a critical issue in this state, and will continue to be. (0017-76 [Stuard, Gary]) 

Comment: Water flow from Granbury Lake needs to be looked at. (0018-4 [Cathey, Jack]) 

Comment: If global warming is occurring and as severe as scientists predict will there be 

enough cool water to operate the reactors safely? The EIS needs to include analysis based on 

input from global warming scientists. (0019-16 [Hadden, Karen]) 

Comment: In drought conditions, will there be enough water for cities, businesses, farms and 

ranches if two nuclear reactors are built? (0019-17 [Hadden, Karen]) 
Appendix D 

May 2011 D-23 NUREG-1943 

Comment: Every minute 31,341 gallons of makeup water from Lake Granbury would be 

needed for each reactor. (from Environmental report 3.3-5) "Makeup water" replaces the water 

lost to evaporation and the water called "blowdown" would be returned to Lake Granbury. 

(0019-31 [Hadden, Karen]) 

Comment: This year was one of the worst for water availability that I have seen in the past 31 

years. The lake has been sustained at 2.5 feet down from normal levels for most of 2008 and 

now going into 2009. My family hasn’t been able to use the lake for skiing for most of this time. 

Not being able to use the lake as intended is probably due to a general lack of rain. The 

increase in water consumption from the lake, authorized by the BRA, hasn’t helped the 

situation. We may be looking at decreased lake levels for years to come due to global warming. 

There was an article in the Hood County News that was entitled “NUCLEAR: Lake Granbury 

water will cool the units”. This is in reference to our water being taken to cool two new reactors. 

There are two points were questions should be asked. Since the conservation pool level is at 

693 ft. above mean sea level and the minimum operating elevation is at 675 ft., (a difference of 

18 ft.) and Luminant is still in negotiation with the BRA on releasing 75,000 acre feet of water 

that will help keep Granbury at a usable level and construction is proposed to start late in 2009, 

then where is the assurance to the people of Granbury that our lake will be usable in the future. 

Negotiations are not complete, and prevailing rain is not looking good. Is the BRA going to 

cripple Possum Kingdom Lake to save Lake Granbury? (0020-1 [Bernier, Jim]) 

Comment: Global warming and its impacts on rainfall are better understood now and must be 

considered in the context of determining whether adequate water resources will be available for 

nuclear plant operations. It is clear that nuclear plants require enormous amounts of water for 

operations. In fact, the environmental report states that 30,000 gallons of water are needed for 

each reactor every minute, and shows in Figure 2.3-30 that approximately two-thirds of this 

water would evaporate. It is also clear, based on the Comanche Peak environmental report, that 

the proponents of the plant assume that there will be adequate water resources for purposes of 

plant operations associated with Comanche Peak Units 3 and 4. However, impacts from global 

warming will include protracted drought that may seriously compromise water resources 

required for plant operations. (0022-55 [Hadden, Karen]) 

Comment: Expanded use of nuclear power in North Texas assumes that there will be an 

adequate supply of fresh water for purposes of plant operations. This assumption is faulty 

because of the failure of the Comanche Peak environmental report to analyze impacts of global 

warming on rainfall and the hydrological cycle. (0022-6 [Hadden, Karen]) 

Comment: Future demands on water use should be evaluated. How will CPNPP interact with 

the surrounding area? For example, investigate interactions with activities related to the Barnett 

Shale as well as municipal and agricultural water use. A citation from the Texas Water 

Development Board (TWDB) indicates uncertainty as to whether all supplies indicated in the ER 

can be obtained. (0027-12 [Osowski Morgan, Sharon L.]) 

Comment: The Environmental Report is confusing regarding water uses from sources other 

than the SCR. For example, p. 2.4-21 indicates that CPNPP is authorized to use 48,300 acrefeet from Lake Granbury each year, but 45,826 was transported in 2006. This seems to indicate 

that CPNPP exceeded their authorized use. Also, it is not clear why Lake Granbury is used 

instead of SCR. Please clarify the water uses; perhaps a matrix indicating water intake and 

discharge, with amounts, etc. would be helpful. (0027-13 [Osowski Morgan, Sharon L.]) 

Comment: According to the ER, the estimated water withdrawal for the operation of CPNPP 

Units 3 and 4 from Lake Granbury is 63,550 gpm (91,512,000 gpd) during maximum operations. 
Appendix D 

NUREG-1943 D-24 May 2011 

The water discharge rate to Lake Granbury during maximum operations, including loss 

estimates is estimated at 24,876 gpm (35,821,440 gpd). Consumptive water use for Units 3 and 

4 is estimated at 55,690,560 gallons per day. Where are the 55 million gallons of water going 

each day? (0027-14 [Osowski Morgan, Sharon L.]) 

Comment: 100,000 acre feet per year gross water allocation for two new reactors is excessive 

considering Lake Granbury???s 130,000 gross acre foot pool, and the current (and increasing) 

contractual obligations for water usage relative to this pool. (0028-1 [Inge, Charles and 

Dominique]) 

Comment: Vast quantities of increasingly precious water would be consumed (0030-5

[Hadden, Karen]) 

Comment: The projected amount of water required for the cooling system is unacceptable and 

risky, to say the least. We are currently facing a water crisis not only in this area but all of 

Texas. Long range projections indicate a likely increase in drought conditions due to climate 

change. The continuing, rampant development of this area, along with the Barnett Shale 

industry, has already pushed the use of our existing water resources to dangerous limits. 

(0031-2 [Gentling, Suzanne]) 

Comment: The application assumes that plenty of water will be available at Squaw Reservoir 

utilizing a complex pipeline scheme. The EIS must address short and long-term climate change 

and the resulting hydrological balance. Significant scholarly work now concludes that central 

north Texas will likely be drier, with less rainfall, putting the plant’s expected water use in 

jeopardy. (0032-5 [Reed, Cyrus]) 

Comment: The EIS should also analyze the loss of water to the Brazos River System ??? 

including the Paluxy River, Whitney Lake, Lake Granbury and Possum Kingdom, as well as the 

bays downstream, and their likely hydrological and ecological impacts. (0032-6 [Reed, Cyrus]) 

Response: The construction and operation of a nuclear plant involves the consumption of 

water. The staff will independently assess the impact of these consumptive water losses on the 

sustainability of both the local and regional water resources. This assessment will consider both 

current and future conditions, including changes in water demands to serve the needs of the 

future population and changes in water supply resulting from climate variability and climate 

change. While NRC does not regulate or manage water resources, it does have the 

responsibility under NEPA to assess and disclose the impacts of the proposed action on water 

resources. The staff’s assessment of the impacts on the sustainability of water resources will 

be presented in Chapters 4 and 5 of the EIS for construction and operation, respectively. 

Comment: Need study of impact "down" river. (0018-6 [Cathey, Jack]) 

Comment: Biocide, algaecide, pH adjuster, corrosion inhibitor and silt dispersant would be 

injected into water drawn from Lake Granbury, and only a fraction of the "blowdown" water 

would be treated before being returned to the lake or sent to an evaporation pond. Why wouldn't 

all of the water be treated before being returned to the lake? (0019-32 [Hadden, Karen]) 

Comment: My primary environmental impact concerns deal with water. Specifically: 

 The amount of surface water required for cooling. (33 billion gallon/year) 

 The amount of evaporation rate, taking 18 billions gallons per year out of the current fresh 

water system 

 The impact on the immediate environment having 18 billion gallons of water vapor released 

yearly 
Appendix D 

May 2011 D-25 NUREG-1943 

 The impact on the water flow in the Brazos River downstream of Lake Granbury 

 The quality of the water in Lake Granbury 

(0021-1 [Richardson, Karen]) 

Comment: Global warming and its impacts on rainfall are better understood now and must be 

considered in the context of determining whether adequate water resources will be available for 

nuclear plant operations. It is clear that nuclear plants require enormous amounts of water for 

operations. In fact, the environmental report states that 30,000 gallons of water are needed for 

each reactor every minute, and shows in Figure 2.3-30 that approximately two-thirds of this 

water would evaporate. It is also clear, based on the Comanche Peak environmental report, that 

the proponents of the plant assume that there will be adequate water resources for purposes of 

plant operations associated with Comanche Peak Units 3 and 4. However, impacts from global 

warming will include protracted drought that may seriously compromise water resources 

required for plant operations. 

The compromised water resources should be considered both from a quantitative perspective 

and a temperature sensitive analysis since plant operations are dependent on a narrow band of 

water temperatures. (0022-10 [Hadden, Karen]) 

Comment: The study should also include an analysis of pollution impacts downstream from 

water contaminated by chemical treatment such as biocides, algaecides, pH adjustors, 

corrosion inhibitor and silt dispersant chemicals injected at the reactor site as well as chlorine, 

salts and non-radioactive effluent. The differential impact of treatment of 100 percent of the 

water versus the lesser amount of treatment proposed by the applicant should be considered. 

(0022-20 [Hadden, Karen]) 

Comment: The EIS should also consider whether regional waterways will be impacted in terms 

of water quantity and quality by the use of vast quantities of water for Units 3 and 4, including 

Lake Granbury, the Brazos River, the Paluxy River, Whitney Lake, a popular fishing lake, and 

popular recreational areas such as Possum Kingdom. According to the Texas Parks and Wildlife 

Department web site, the drinking water at Possum Kingdom State Park is currently non-potable 

due to a high salt content, and visitors must bring their own water for consumption. The potential 

to increase salt content of waterways in the region by further drawdown of water levels, 

including impacts to the local aquifer and drinking wells should be examined thoroughly in the 

EIS. (0022-22 [Hadden, Karen]) 

Comment: Questions of the water quality and quantity of “blowdown” water returned to the lake 

need more thorough evaluation (volume; flow; temperature; salinity; pollutants). (0028-2 [Inge, 

Charles and Dominique]) 

Response: The construction and operation of a nuclear plant involves the consumption of 

water and some discharges to nearby water bodies. The Clean Water Act designated the EPA 

as the Federal agency with responsibility for effluent discharges to the nation’s waters. While 

the NRC does not regulate effluents other than radiological effluents, it does have the 

responsibility under NEPA to assess and disclose the expected impacts of the proposed action 

on water quality throughout the plant’s life. That assessment will include consideration of salts 

concentrated in the blowdown system and chemicals injected into raw water systems. Neither 

does NRC regulate or manage water resources, but it does have the responsibility under NEPA 

to assess and disclose the impacts of the proposed action on water resources. The staff’s 

assessment will independently determine if the designated uses of the local and regional water 

supplies are jeopardized by the construction or operation of a nuclear plant at the proposed site, 

and will independently assess the impact of any consumptive water losses on the sustainability 
Appendix D 

NUREG-1943 D-26 May 2011 

of both the local and regional water resources. This assessment will consider both current and 

future conditions, including changes in water demands to serve the needs of the future 

population and changes in water supply resulting from climate variability and climate 

change. The staff’s assessments of the nonradiological impacts to water quality and impacts to 

water supply sustainability will be presented in Chapters 4 and 5 of the EIS for construction and 

operation, respectively. 

Comment: I do have significant questions about water quantity and 'water quality and the 

impacts of taking that much water from Lake Granbury downstream. And I would urge you, as 

part of your assessment, to also look at climate models and weather, given what we think we 

know about climate change, how that will change the water balances in Lake Granbury. 

(0016-52 [Reed, Cyrus]) 

Response: The construction and operation of a nuclear plant involves the consumption of 

water and some discharges to nearby water bodies. The Clean Water Act designated the EPA 

as the Federal agency with responsibility for effluent discharges to the nation’s waters. While 

the NRC does not regulate effluents other than radiological effluents, it does have the 

responsibility under NEPA to assess and disclose the expected impacts of the proposed action 

on water quality throughout the plant’s life. Neither does NRC regulate or manage water 

resources, but it does have the responsibility under NEPA to assess and disclose the impacts of 

the proposed action on water resources. The staff’s assessment will independently determine if 

the designated uses of the local and regional water supplies are jeopardized by the construction 

or operation of a nuclear plant at the proposed site, and will independently assess the impact of 

any consumptive water losses on the sustainability of both the local and regional water 

resources. This assessment will consider both current and future conditions, including changes 

in water demands to serve the needs of the future population and changes in water supply 

resulting from climate variability and climate change. The staff’s assessments of the 

nonradiological impacts to water quality and impacts to water supply sustainability will be 

presented in Sections 4 and 5 of the EIS for construction and operation, respectively. 

Comment: Section 6.2.5: This section indicates that within the CPNPP environs, there have 

been detections of tritium above lower limits of detection in Squaw Creek Reservoir (SCR), and 

those detections have been well below the reporting limit (30,000 pCi/I). Please clarify whether 

this means that there have been no detections of tritium in water in Squaw Creek below the 

dam. Figure 6.2-1 indicates the presence of a surface water collection site on Squaw Creek, 

although Table 6.2-3 does not list it. It is important to characterize tritium levels in downstream 

waters as well as the SCR. It would be helpful if the EIS clarified what radiologicals are being 

collected in Squaw Creek below the dam and provide any data available. (0027-9 [Osowski 

Morgan, Sharon L.]) 

Response: Staff will clarify the availability of tritium monitoring in and downstream of SCR and 

will include an assessment of available information in the EIS. 

D.2.9 Comments Concerning Hydrology - Groundwater 

Comment: [if global warming, climate change is occurring, and as severe as we anticipate] and 

so then, will the ground water decline? (0017-43 [Rooke, Molly]) 

Response: The construction and operation of a nuclear plant involves the consumption of 

water. The staff will independently assess the impact of these consumptive water losses on the 

sustainability of both the local and regional water resources. This assessment will consider both 

current and future conditions, including changes in water demands to serve the needs of the 

future population and changes in water supply resulting from climate variability and climate 
Appendix D 

May 2011 D-27 NUREG-1943 

change. While NRC does not regulate or manage water resources, it does have the 

responsibility under NEPA to assess and disclose the impacts of the proposed action on water 

resources. The staff’s assessment of the impacts on the sustainability of water resources will 

be presented in Chapters 4 and 5 of the EIS for construction and operation, respectively. 

Comment: will it need any groundwater for make up water. (0017-40 [Rooke, Molly]) 

Response: The design of Units 3 and 4 as presented in the license application does not 

require the use of groundwater for operation. 

Comment: The aquifer below Kames County has been contaminated by uranium mill tailings. 

The Department of Energy estimates clean up will cost $348 million but, according to a Texas 

Department of Agriculture report, will not implement the clean up plan. (0019-28 [Hadden, 

Karen]) 

Response: The issue raised in the comment is outside the scope of the environmental 

review. There is no evidence of hydrologic connection between Comanche Peak Nuclear Plant 

surface or subsurface hydrology and that of the aquifer below Karnes County, TX. 

Comment: So, you know, and then recently most of y'all have heard about the Barnett shale in 

the Tarrant County and Dallas County area, and y'all may have some of it here too. One of the 

things they do is drill wells, water wells, to get their water from to drill the gas wells, In Parker 

County, the local farmers, their water wells are drying up. (0016-66 [Kinzie, W.T.]) 

Response: Local and regional uses of groundwater will be considered in Section 2.3.2 of the 

EIS. 

Comment: The EIS should examine the impacts of vast water consumption on the aquifer and 

the water table levels. Will wells be sucked dry? (0019-13 [Hadden, Karen]) 

Comment: [What are] The indirect impacts on the major aquifers in the region [? Specifically, 

the]---Paluxy and Trinity. (0021-2 [Richardson, Karen]) 

Response: The applicant is proposing to use less groundwater in the future than what is 

currently used. The impacts of the proposed groundwater use will be addressed in the 

Section 5.2 of the EIS. 

Comment: you have mentioned ground water (0017-35 [Cohn, Ann]) 

Comment: How high is the risk of contamination of the aquifer and other waterways through 

radioactive leaks? Could the problem ever be remediated if radioactive or chemical leaks 

occurred? (0019-14 [Hadden, Karen]) 

Comment: The hydrogeological characterization appears adequate for a fundamental 

understanding of the site (future reactors 3 and 4). Information contained in the ER includes 

subsurface geology, groundwater occurrence, water levels, flow direction and velocity, and 

other related information. However, the characterization may not be adequate for detailed 

analysis of complex groundwater flow conditions and mechanisms including complex fracture 

flow, groundwater flow along bedding planes, preferential pathways, and other flow 

complications. (0027-15 [Osowski Morgan, Sharon L.]) 

Comment: The ER discusses packer tests and concludes the Glen Rose Formation and 

sections of the Twin Mountain Formation are impermeable. The Twin Mountain Formation is a 

highly productive aquifer around the site including numerous public supply wells. It is 

recommended that additional information be provided to substantiate the claim that these are 

indeed impermeable. 
Appendix D 

NUREG-1943 D-28 May 2011 

The ER does not include an individual section indicating the risk of groundwater contamination 

nor was a methodology for evaluating groundwater risk identified. This information should be 

part of the conceptual site model. To evaluate site impacts from future groundwater production, 

it will be necessary to develop a sub-regional scale groundwater model to predict how 

increased/decreased uses could affect units 3 and 4. 

Groundwater flow velocity has been estimated using input from site-specific hydrologic test 

results. However, if groundwater flow directions or gradients are found to be different than 

reported, or change over time, the effectiveness of the well network will need to be reevaluated. 

It is reasonable to expect that additional wells will need to be installed as more water level data 

become available and flow directions are refined over time. 

Groundwater monitoring should include monitoring for contaminants and mixed waste from 

these sources: non-radioactive solid, liquid, and gaseous waste streams associated with the 

construction and operation of CPNPP Units 3 and 4, chlorinated fluorocarbons (CFCs), 

solvents, and used oil. Other sources may include liquid scintillation fluids, other types of 

organic materials, and metals such as lead and chromium, and aqueous corrosives. (0027-16

[Osowski Morgan, Sharon L.]) 

Response: The risk of contamination of aquifers and other waterways will be addressed in the 

EIS. Although NRC regulations require licensees to make surveys, as necessary, to evaluate 

the potential hazard of radioactive material released in order to assess doses to members of the 

public and workers, recent discoveries of releases at other plants indicate that undetected 

leakage to groundwater from facility structures, systems, or components can occur, resulting in 

unmonitored and unassessed exposure pathways to members of the public. The NRC has 

identified several instances of unintended tritium releases, and all available information shows 

no threat to the public. Nonetheless, the NRC is inspecting each of these events to identify the 

cause, verify the impact on public health and safety, and review licensee plans to remediate the 

event. The NRC also established a lessons learned task force to address inadvertent, 

unmonitored liquid radioactive releases from U.S. commercial nuclear power plants. This task 

force reviewed previous incidents to identify lessons learned from these events and to 

determine what, if any, changes are needed to the regulatory program. Detailed information 

and updates on these liquid releases can be found on the NRC public website at 

http://www.nrc.gov/reactors/operating/ops-experience/grndwtr-contam-tritium.htm. 

D.2.10 Comments Concerning Ecology — Terrestrial 

Comment: When the first two reactors were built the sky glow light pollution went from zero to 

off the scale in the direction of the reactors. The latest round of fixture modernization reduced 

the sky glow by about 40 percent. Our Concern is the two new units will increase the sky glow 

beyond what it was after initial construction. We would like to see a comprehensive relighting 

program for all four reactors, using the latest technology zero cut-off fixtures, such as those 

approved by the International Dark-sky Association in order to achieve an overall reduced light 

pollution impact than what now exists. www.darksky.org (0024-2 [Miller, Russ]) 

Response: Potential impacts on wildlife of light pollution from operation of the proposed two 

new nuclear reactor units will be addressed in Chapter 5 of the EIS. 

Comment: The environmental report indicates that Squaw Creek Reservoir will continue to be 

the receiving body of water for various discharges from Comanche Peak Units 3 and 4. The 

Environmental Report concedes that radioactive particulate matter released to Squaw Creek 

Reservoir in liquid effluents will be deposited into the sediment layer of the reservoir bottom and 

remain there indefinitely. Comanche Peak NPP Environmental Report, p.5.11-3. In the event of 
Appendix D 

May 2011 D-29 NUREG-1943 

a protracted drought, and inadequate flow into Squaw Creek Reservoir. The sediment layer 

could become exposed and, if adequately deliquified, would become dust and subject to 

transport by wind with clear public health and environmental consequences. 

Therefore, it is crucial that the EIS include a complete radiological profile of the existing 

sediment in Squaw Creek Reservoir and an analysis of the cumulative radiological impacts 

expected from operations on it from Units 3 and 4. This analysis is required in order to fully 

gauge the environmental and public health impacts from the use of the earthen Squaw Creek 

Reservoir as a discharge point for radioactive effluent from Comanche Peak Units 3 and 4. Part 

of this analysis should be an assumption that the Squaw Creek Reservoir dam will at some 

point fail and release the sediment that is burdened by radioactive particulates. Downstream 

impacts on water quality, use, and impacts on mortality and morbidity must be a part of a proper 

EIS. The Squaw Creek Reservoir dam should also be analyzed for structural integrity. 

Protracted drought, seismic activity, or other natural events have the potential to weaken the 

dam and if a failure of the structure occurs radioactive sediment could be carried downstream 

with significant potential for environmental and public health impacts. (0022-14 [Hadden, 

Karen]) 

Response: The staff will evaluate the radiological impacts of normal operation of the proposed 

new reactor units in Chapter 5 and the cumulative impacts of the new units in conjunction with 

existing Units 1 and 2 in Chapter 7 of the EIS. Potential effects on both human health and 

ecological receptors will be assessed based on appropriate exposure scenarios. 

Comment: The EIS should discuss the location, amount, type, and quality of wetland acreage 

in the study area, and how wetlands were delineated (i.e., COE, contractor, lead agency, etc.). 

A draft mitigation plan to compensate for predicted wetland losses should be developed during 

the NEPA process. Feasible alternatives that avoid wetland impacts should be consistent with 

the 404(b)(I) guidelines of the Clean Water Act. (0027-7 [Osowski Morgan, Sharon L.]) 

Response: The NRC staff will describe wetlands potentially impacted by the project in Section 

2.3.4 of the EIS. The potential impacts to these wetlands will be evaluated in Sections 4.3 and 

5.3 of the EIS. Mitigation will be considered in Sections 4.3.3.5 and 5.3.3.5. 

Comment: Biodiversity is defined as the variety of plants and animals (biota) of a site or region, 

and is typically measured by the number of different species and number of individuals per 

species. In general, the more diverse an area is (number of habitat types and animal 

inhabitants) and the better represented these components are (population counts), the more 

rigorous (resistant, undisturbed, natural, healthy) the area is considered. Specifically, 

sustainable (or self managed) native biodiversity is preferred compared to an increase in the 

number of invasive, edge, or opportunistic species. Invasive, edge, or opportunistic species may 

compete with native species and have the potential to dramatically change local ecosystems so 

that they are not sustainable. Implementing BMPs or other measures to reduce invasive species 

establishment should be discussed (Executive Order 13112). 

The NEPA document should discuss native biodiversity aspects of the proposal as appropriate. 

For example, will the project increase, restore, or decrease native biodiversity of the area or 

region? Coordination with the U.S. Fish and Wildlife Service (FWS), and Texas Parks and 

Wildlife Department is recommended regarding the design of any project mitigation areas to 

enhance or restore biodiversity. (0027-22 [Osowski Morgan, Sharon L.]) 

Response: The NRC staff will consider and describe biodiversity in the project area in Section 

2.4 of the EIS. Impacts to biodiversity, and mitigation measures as appropriate, will be 

discussed in Sections 4.3 and 5.3. 
Appendix D 

NUREG-1943 D-30 May 2011 

Comment: The FWS is the responsible agency for endangered species compliance, so EPA 

defers to FWS regarding assessments of Federally-protected endangered species. However, 

the NEPA document should discuss survey results and adjust the proposed alignment as 

appropriate. Early coordination with FWS is recommended. (0027-23 [Osowski Morgan, 

Sharon L.]) 

Response: The NRC staff has begun early consultation with the U.S. Fish and Wildlife Service 

(FWS) concerning potential project impacts on federally protected threatened and endangered 

species. NRC’s consultations with FWS regarding threatened and endangered species will be 

discussed in Chapter 4 of the EIS. 

Comment: Chapter 2 -Existing Environment 

Section 2.4 of the ER references a List of Somervell County Threatened and Endangered 

Species to address state-listed threatened or endangered species that may occur at the 

proposed CPNPP site. The ER failed to include the TPWD Annotated List of Rare Species for 

Hood County, though it appears that components of the project would occur within Hood 

County. Additionally, the ER only addressed state-listed threatened or endangered species, but 

did not address all species included on the Annotated County List of Rare Species. Those 

species on the list with a blank under federal or state status are tracked by TPWD and 

considered rare. Rare species are of conservation concern by TPWD within Texas, and efforts 

to minimize impact to such species are encouraged to help prevent future listing of the species. 

The most up-to-date TPWD Annotated County Lists of Rare Species are available at 

http://gis.tpwd.state.tx.us/TpwEndangeredSpecies/DesktopDefault.aspx. The lists provide 

information regarding rare species that have potential to occur within each county. Rare species 

could potentially be impacted if suitable habitat is present at or near the project site. (0029-

2[Boydston, Kathy]) 

Comment: The EIS should address all species on the Hood and Somervell County Lists 

including rare, threatened, and endangered species. The project site should be assessed to 

determine if suitable habitat for any of these species occurs within or near the proposed area 

and to determine if construction and operation of the project would impact the species or 

habitats. (0029-2 [Boydston, Kathy]) 

Response: The NRC staff will address potential impacts to terrestrial and aquatic biota, 

including State-listed threatened and endangered species, and suitable habitat potentially on 

the project site, in Sections 4.3 and 5.3 of the EIS. 

Comment: Wooded riparian corridors along streams generally provide nesting habitat for birds, 

soil stabilization for enhanced water quality, and food, cover, and travel corridors for wildlife. 

Riparian habitat is a high priority habitat type for conservation by TPWD across the state. 

Comment: The project should be designed and constructed to avoid disturbance to stream and 

riparian areas. (0029-6 [Boydston, Kathy]) 

Response: The NRC staff will address potential impacts to stream and riparian areas, and 

mitigation measures as appropriate, in Sections 4.3 and 5.3 of the EIS. 

Comment: The proposed project is situated in the Cross Timbers and Prairies Ecoregion of 

Texas which has generally supported native grassland valley communities with higher wooded 

divides. Native grassland communities have become increasingly rare in Texas due to historical 

conversion to row crop agriculture, overgrazing, invasion by woody species from a lack of fire on 

the landscape, conversion to non-native pastures and hayland, and other development 

associated with humans. Native grasslands are an important resource for wildlife adapted to 
Appendix D 

May 2011 D-31 NUREG-1943 

grassland environments. Population declines of many grassland birds are attributed to this loss 

of habitat. (0029-7 [Boydston, Kathy]) 

Comment: The location of facilities should be sited to avoid native grassland communities and 

placed in areas of previous disturbance or in areas previously converted to non-native pasture. 

(0029-7 [Boydston, Kathy]) 

Response: The NRC staff will address potential impacts to native grassland communities, and 

mitigation measures as appropriate, in Sections 4.3 and 5.3 of the EIS. 

Comment: Because native vegetation is adapted to the soil and climate of the area, it usually 

requires less maintenance and watering than introduced species. Water conservation is 

warranted for the relatively dry climate of the project area. The disease tolerance of native 

vegetation provides longevity to the landscape without high cost. Mature trees and shrubs 

provide nesting, loafing, and forage habitat for birds and other wildlife. (0029-8 [Boydston, 

Kathy]) 

Comment: The project site should be carefully planned and constructed to avoid and preserve 

existing native vegetation. To eliminate or reduce the need for permanent irrigation, native trees, 

shrubs, grasses, and forbs should be incorporated into the landscape plan. The following 

websites describe appropriate native vegetation for the project area, 

http://www.tpwd.state.tx.us/huntwild/wild/wildscapes/ and http://tpid. tpwd.state.tx.us/. (0029-8

[Boydston, Kathy]) 

Response: The NRC staff will discuss preservation of native vegetation and use of native 

species for revegetation in Sections 4.3 and 5.3 of the EIS. 

Comment: The revegetation and maintenance plan for temporary disturbed areas should focus 

on re-establishing native cover through natural regeneration and/or planting and should be 

developed in coordination with TPWD. Plans for natural regeneration and/or revegetation of 

disturbed areas should include measures to treat and control undesirable and/or invasive 

species and should include management practices to benefit wildlife. (0029-9 [Boydston, Kathy]) 

Response: The NRC staff will discuss preservation of native vegetation, use of native species 

for revegetation, and consideration of control of invasive species in Sections 4.3 and 5.3 of the 

EIS. 

Comment: The ER did not address the potential for the project site to contain rare plant 

species or sensitive plant communities that are tracked by TPWD and/or included on our 

annotated county lists of rare species; therefore impacts to those species or communities were 

not addressed. (0029-10 [Boydston, Kathy]) 

Comment: Sites should be surveyed to identify potential impacts to rare plant species and 

natural communities identified by TPWD. (0029-10 [Boydston, Kathy]) 

Response: The NRC staff will describe rare and sensitive plant species that potentially occur 

on the project site in Section 2.4. The potential impacts to these species, based on the 

likelihood of such species to be present, and potential mitigation measures, will be evaluated in 

Sections 4.3 and 5.3 of the EIS. 

Comment: Protecting vegetated buffers is discussed in Section 4.3.1.1, though no vegetated 

buffer areas are specifically identified in the ER. (0029-11 [Boydston, Kathy]) 

Comment: The vegetated buffer areas that would receive protection need to be identified and 

mapped. (0029-11 [Boydston, Kathy]) 
Appendix D 

NUREG-1943 D-32 May 2011 

Response: The NRC staff will discuss locations and preservation of vegetative buffer areas in 

Sections 4.3 and 5.3 of the EIS. 

Comment: Figure 4.2-1 indicates that the area immediately adjacent to the wetland identified 

along SCR on the cooling tower peninsula is slated as a construction area. During the February 

2,2009 site visit, Luminant noted that a buffer area would be placed around the wetland. It is 

unclear the amount of wooded area on the slopes of the draw that would be excluded from 

construction activities to serve as the buffer area to the wetland. (0029-12 [Boydston, Kathy]) 

Comment: A buffer area developed in coordination with TPWD should be established along the 

slopes to protect water quality, provide wildlife habitat, and shelter the wetland located down 

slope at this location. (0029-12 [Boydston, Kathy]) 

Response: The NRC staff will address wetland mitigation, including provision of buffer areas, 

in Chapters 4 and 5 of the EIS. 

Comment: Section 4.3.1 of the ER indicates that the disturbed area is equivalent to 275 acres 

and 384 acres, for the CPNPP and the BDTF, respectively. The ER does not distinguish 

between permanent and temporary disturbance areas per the CPNPP site and the BDTF. The 

275-acre CPNPP site is the only area showing impacts by cover type, but the amount of each 

cover type lost to permanent construction is not provided. No impact assessment per cover type 

is provided for the 384-acre BDTF, the pipelines, the power transmission lines, or the intake and 

return structure areas. (0029-13 [Boydston, Kathy]) 

Comment: The permanent and temporary disturbances should be revealed per cover type 

(grassland, scrub brush, disturbed, juniper woodland, wetland, hardwood forest, etc.) per facility 

(CPNPP, BDTF, power transmission lines, pipelines, and intake and return structure areas). 

Total temporary and permanent impacts per cover type should be provided for the proposed 

project, inclusive of the CPNPP, the BDTF, the pipelines, the transmission lines, and the intake 

and discharge structure areas. This type data can easily be presented in table form. (0029-13

[Boydston, Kathy]) 

Response: The NRC staff will distinguish between permanent and temporary disturbance 

areas on the project site, including the area of the proposed Blowdown Treatment Facility, as 

well as assessing habitat cover types in the entire project area. Ecological impacts within the 

entire project area will be evaluated in Sections 4.3 and 5.3. 

Comment: Construction crews should be informed of the rare species in the project counties 

and should avoid disturbance to sensitive species if encountered during construction. Only 

personnel with a TPWD scientific collection permit are allowed to handle and move state listed 

species. For further information on the required permit please contact Chris Maldonado at (512) 

389-4647. (0029-14 [Boydston, Kathy]) 

Response: The NRC staff will describe mitigation measures for rare species in Sections 4.3 

and 5.3. Should mitigation include handling and movement of State-listed species, all legal and 

regulatory requirements would be met. 

Comment: The ER did not address the potential for the project site to contain rare species that 

are tracked by TPWD and included on our annotated county lists of rare species; therefore 

impacts to those species were not addressed. The ER does not include a detailed evaluation of 

impacts associated with the BDTF construction. (0029-15 [Boydston, Kathy]) 
Appendix D 

May 2011 D-33 NUREG-1943 

Comment: Site surveys of the CPNPP and BDTF sites for rare species with potential to occur 

within the area should be conducted prior to construction. Occurrences should be avoided or a 

mitigation plan developed in coordination with TPWD. (0029-15 [Boydston, Kathy]) 

Response: The NRC staff will describe rare and sensitive plant species that potentially occur 

on the project site, including the Blowdown Treatment Facility, in Section 2.4. The potential 

impacts to these species, based on the likelihood for such species to be present, and potential 

mitigation measures, will be evaluated in Sections 4.3 and 5.3 of the EIS. 

Comment: It is not apparent that Chapter 5 of the ER addresses impacts to wildlife associated 

with operation of the BDTF. The proposed site for the BDTF would include a large area of ponds 

that may be placed near and/or under existing power transmission lines. The BDTF area is also 

in close proximity to a large reservoir. Therefore, there is increased potential for use of the area 

near the transmission lines by migratory and resident waterfowl and shorebirds once the BDTF 

ponds are installed. The attractiveness of the BDTF ponds to birds would increase the potential 

for bird collision with the transmission lines. (0029-21 [Boydston, Kathy]) 

Comment: Potential collision impacts to migratory and resident birds as a result of constructing 

large ponds near and/or under transmission lines should be addressed. Measures to avoid or 

mitigate potential impacts should be developed in coordination with TPWD, such as 

transmission line marking, relocation of the proposed BDTF ponds, and pre-and postconstruction monitoring. (0029-21 [Boydston, Kathy]) 

Response: The NRC staff will describe potential impacts to wildlife from operation of the 

proposed Blowdown Treatment Facility, and potential mitigation measures, in Sections 4.3 and 

5.3 of the EIS. 

Comment: Any potential dangers to wildlife as a result of exposure to the BDTF ponds should 

also be made apparent. Significant impacts should be mitigated. (0029-22 [Boydston, Kathy]) 

Response: The NRC staff will describe potential impacts to wildlife from operation of the 

proposed Blowdown Treatment Facility, including associated ponds, and potential mitigation 

measures, in Sections 4.3 and 5.3 of the EIS. 

Comment: Comment: TPWD is concerned that high salinity reject water (brine) from any 

desalination process be disposed of in a manner that does not impact fish and wildlife 

resources. TPWD may offer additional comment when Luminant provides greater detail of 

proposed operations of the BDTF. (0029-23 [Boydston, Kathy]) 

Response: The NRC staff notes the comment. 

Comment: Because the CPNPP boundary encompasses approximately 7,950 acres inclusive 

of Squaw Creek Reservoir and large areas of undeveloped property, there is opportunity for 

Luminant to develop a working plan for conservation, protection, and management offish and 

wildlife resources within the CPNPP boundary. An adaptive wildlife management plan should be 

developed in coordination with TPWD. Suggestions for activities to address in the management 

plan include, but are not limited to: 

! Opening Squaw Creek Reservoir or portions of the reservoir for public fishing 

! Creating and maintaining native grassland communities within transmission line ROWs and 

areas of non-native grasslands 

! Creating and protecting riparian corridor habitat 

! Developing a grazing management plan for areas leased to livestock 
Appendix D 

NUREG-1943 D-34 May 2011 

! Developing livestock exclusion areas or rotation plans near ponds to help improve water 

quality and increase wildlife diversity 

! Conducting deer management in areas that are overpopulated 

! Monitoring and treatment of invasive or undesirable species (0029-24 [Boydston, Kathy]) 

Response: Creation of an adaptive wildlife plan is outside the scope of this review. 

Comment: Rare Resource Occurrences 

To support preparation of the EIS, the NRC has requested information regarding state-listed, 

proposed, and candidate species and protected habitat that may be in the vicinity of the 

proposed site, the alternative sites, and the transmission line ROWs. 

The ER indicates that three alternative sites and a preferred site were considered for the 

proposed nuclear power plants. The applicant has not revealed the alternative site locations 

because they hold the locations as proprietary information. The three alternative sites have 

been described as occurring A) near the border of Victoria and Calhoun counties, B) near the 

border of San Augustine and Sabine counties, and C) near the border of McLennan and 

Limestone counties. Therefore, TPWD must present the data regarding known occurrences of 

rare resources based on countywide sets of data for two counties per site. TPWD has included 

a l-mile radius buffer beyond the two counties because including a buffer to a project site is 

typical practice for Texas Natural Diversity Database (TXNDD) searches. This buffer also 

encompasses area that may be in a different county, but still within 10 miles of the border of the 

two given counties. To eliminate bias in the evaluation of site alternatives by the NRC, TPWD is 

submitting data for the proposed site in the same manner encompassing Hood and Somervell 

counties and a la-mile radius buffer area. 

If the actual locations of the alternative sites are provided to TPWD, then we will provide a less 

intensive list of TXNDD occurrences to the NRC by site location rather than countywide. 

TPWD is also submitting a set of data specific to the proposed site location including 

occurrences within a l-mile buffer area. This data should be considered when assessing the 

potential impacts to rare resources if the alternatives analysis of the EIS indicates that the 

proposed site is adequate as the preferred site. Thus, an appropriate evaluation of impacts to 

rare resources specific to the preferred site can be conducted. 

The ER identifies two new proposed 345-kV transmission line routes requiring new ROW, one 

extending 45 miles to a substation near Lake Whitney in Bosque County and one extending 17 

miles to a switching station near Lake Granbury. There are also two new proposed circuits that 

will be added to vacant positions on two separate existing 345-kV double lattice steel tower 

structures, one extending 44.8 miles to a switching station in Tarrant County and one extending 

41.6 miles to a switching station in Parker County. TPWD understands that the proposed 

transmission line ROW routes are preliminary and not final. Therefore, the information provided 

regarding resources within the vicinity of the two new proposed 345-kV transmission line ROWs 

will need to be updated and an assessment of potential impacts to rare resources will need to 

be reevaluated once specific routes are identified. 

Determining the actual presence of a species in a given area depends on many variables 

including daily and seasonal activity cycles, environmental activity cues, preferred habitat, 

transiency and population density (both wildlife and human). The absence of a species can be 

demonstrated only with great difficulty and then only with repeated negative observations, taking 

into account all the variable factors contributing to the lack of detectable presence. 
Appendix D 

May 2011 D-35 NUREG-1943 

The TXNDD is intended to assist users in avoiding harm to rare species or significant ecological 

features. Given the small proportion of public versus private land in Texas, the TXNDD does not 

include a representative inventory of rare resources in the state. Absence of information in the 

database does not imply that a species is absent from that area. Although it is based on the 

best data available to TPWD regarding rare species, the data from the TXNDD do not provide a 

definitive statement as to the presences, absence or condition of special s (0029-25 [Boydston, 

Kathy]) 

Response: The NRC staff notes the comment. Since actual locations of the alternative sites 

have been provided to Texas Parks and Wildlife Department by NRC, staff notes that scope of 

the occurrence list will be reduced. 

D.2.11 Comments Concerning Ecology - Aquatic 

Comment: I want an honest environmental impact statement on protein sources at the estuary 

of the Brazos River. We keep, over and over again, putting negative impacts on our ability to 

produce protein from our coastline. And this is just one more example of that. If the NRC does 

not do an honest assessment of that, it is not a legitimate planning process. I'd like to see that 

addressed. (0016-43 [Burnam, Lon]) 

Comment: It is about the production of protein at the end of this river stream. We are facing a 

probably extended drought, and you have got the protection here, because your lake is a 

guaranteed level. But I want to ask you about Possum Kingdom, which is low already. I want to 

ask you about maintaining the estuary and the protein production at the end of this assembly 

line, as it were. (0017-18 [Burnam, Lon]) 

Response: The impact of water withdrawals from and discharges to the Brazos River for 

operation of the proposed new nuclear units will be evaluated and presented in Chapter 5 of the 

EIS. 

Comment: I used to go fishing in Squaw Creek. In the local paper, like I said, it always gives 

the lake levels and the temperature of the waters. Squaw Creek would go -the highest I ever 

saw it was 104 degrees. And, yes, there would be fish dead. Matter of fact, no matter where I 

was in the lake, I could always see at least one dead fish, unless I was on the—close to the 

bank. Then there was a lot of dead fish and a lot of buzzards. 

And that may sound kind of funny, but the ones that the dead fish and the maggots and that sort 

of stuff that the buzzards eat, it kind of went over the spillway. And that might be why these 

problems with Squaw Creek downstream. And also, when you came over the hill to go down to 

the boat ramp area, you could smell dead fish. 

And it's not as if I was going to eat something I caught out of that lake at that time, but I just 

went out there to kind of see what kind of deal this is. And I wish I had taken a movie or 

something to show you, because it would make an effect on your—just the way you think. 

(0016-69 [Kinzie, W.T.]) 

Comment: Discharging "hot" water from Squaw Creek needs to be studied. Loss of fish, 

turtles, frogs. (0018-5 [Cathey, Jack]) 

Response: The NRC staff will assess potential impacts to aquatic life in Lake Granbury, the 

Brazos River, and Squaw Creek due to thermal discharge from the proposed new reactor units 

in Section 5 of the EIS. 
Appendix D 

NUREG-1943 D-36 May 2011 

Comment: Need study of impact "down" river. (0018-7 [Cathey, Jack]) 

Response: The NRC staff will assess potential ecological and hydrological impacts in Lake 

Granbury, the Brazos River, and Squaw Creek Reservoir due to operation of the intake and 

discharge from the proposed new reactor units in Chapter 5 of the EIS. 

Comment: The adverse effects of elevating water temperatures in our rivers is sacrificing the 

integrity of these precious ecosystems and harming biological development and survival. This is 

unacceptable and irresponsible. (0031-3 [Gentling, Suzanne]) 

Response: The NRC staff will assess potential impacts to aquatic life in the Brazos River from 

thermal discharge of the proposed new reactor units in Chapter 5 of the EIS. 

Comment: The EIS must do a full analysis of how much of each of these contaminants [i.e., 

biocide, algaecide, pH adjuster, corrosion inhibitor and silt dispersant] would end up in Lake 

Granbury, how much would migrate into the Brazos River and how much would escape through 

evaporation. The exact chemical names must be included, not just generic terms such as 

"biocide." The impacts of exposure of humans, animals and wildlife to these toxic compounds 

should be analyzed. (0019-12 [Hadden, Karen]) 

Comment: The study should also include an analysis of pollution impacts downstream from 

water contaminated by chemical treatment such as biocides, algaecides, pH adjustors, 

corrosion inhibitor and silt dispersant chemicals injected at the reactor site as well as chlorine, 

salts and non-radioactive effluent. The differential impact of treatment of 100 percent of the 

water versus the lesser amount of treatment proposed by the applicant should be considered. 

(0022-18 [Hadden, Karen]) 

Response: The staff’s assessment of the nonradiological impacts to water quality will be 

presented in Chapter 5 of the EIS. 

Comment: Global warming and its impacts on rainfall are better understood now and must be 

considered in the context of determining whether adequate water resources will be available for 

nuclear plant operations. It is clear that nuclear plants require enormous amounts of water for 

operations. In fact, the environmental report states that 30,000 gallons of water are needed for 

each reactor every minute, and shows in Figure 2.3-30 that approximately two-thirds of this 

water would evaporate. It is also clear, based on the Comanche Peak environmental report, that 

the proponents of the plant assume that there will be adequate water resources for purposes of 

plant operations associated with Comanche Peak Units 3 and 4. However, impacts from global 

warming will include protracted drought that may seriously compromise water resources 

required for plant operations. The compromised water resources should be considered both 

from a quantitative perspective and a temperature sensitive analysis since plant operations are 

dependent on a narrow band of water temperatures. (0022-11 [Hadden, Karen]) 

Comment: The EIS should also consider whether regional waterways will be impacted in terms 

of water quantity and quality by the use of vast quantities of water for Units 3 and 4, including 

Lake Granbury, the Brazos River, the Paluxy River, Whitney Lake, a popular fishing lake, and 

popular recreational areas such as Possum Kingdom. According to the Texas Parks and Wildlife 

Department web site, the drinking water at Possum Kingdom State Park is currently non-potable 

due to a high salt content, and visitors must bring their own water for consumption. The potential 

to increase salt content of waterways in the region by further drawdown of water levels, 

including impacts to the local aquifer and drinking wells should be examined thoroughly in the 

EIS. Coastal environmental impacts are known to result from alterations of freshwater flow into 

the Gulf of Mexico, affecting lagoons, estuaries and wetlands, altering salinity patterns, 

nutrients, dissolved oxygen levels and therefore impacting productivity of coastal plant and 
Appendix D 

May 2011 D-37 NUREG-1943 

animal populations. The biological impacts must be considered in the EIS including the 

possibility of eutrophication, productivity and sediment impacts, and potential contamination. 

(0022-21 [Hadden, Karen]) 

Comment: Friends of the Brazos River (FBR) is a non-profit organization with 450 members in 

the Glen Rose, Granbury, Dallas and Ft. Worth area whose main concern is the ecological 

integrity of the Brazos between Lakes Granbury and Whitney. In our opinion, the Brazos is an 

imperiled ecosystem, largely due to the over-allocation of Brazos water by the Brazos River 

Authority. We are currently working cooperatively with BRA, TCEQ and other state agencies to 

insure that BRA???s current water right application allows for adequate in stream flows. 

It is our understanding that the cooling systems for the additional reactors at Comanche Peak 

will lose approximately 55,000 acre ft. of Brazos water annually to evaporation. Whereas, we do 

not oppose the additional reactors. We do oppose the loss of so much Brazos water. (0025-1

[Lowe, Ed]) 

Response: The staff will assess the impact of consumptive water losses related to the 

proposed action on the sustainability of both local and regional water resources. This 

assessment will consider both current and future conditions, including changes in water 

demands to serve the needs of future populations, and changes in water supply resulting from 

climate variability and climate change. The staff’s assessment of impacts on water resources 

and related ecological impacts will be presented for construction and operation in Chapters 4 

and 5 of the EIS, respectively. 

Comment: The environmental report indicates that Squaw Creek Reservoir will continue to be 

the receiving body of water for various discharges from Comanche Peak Units 3 and 4. The 

Environmental Report concedes that radioactive particulate matter released to Squaw Creek 

Reservoir in liquid effluents will be deposited into the sediment layer of the reservoir bottom and 

remain there indefinitely. Comanche Peak NPP Environmental Report, p.5.11-3. In the event of 

a protracted drought, and inadequate flow into Squaw Creek Reservoir. The sediment layer 

could become exposed and, if adequately deliquified, would become dust and subject to 

transport by wind with clear public health and environmental consequences. 

Therefore, it is crucial that the EIS include a complete radiological profile of the existing 

sediment in Squaw Creek Reservoir and an analysis of the cumulative radiological impacts 

expected from operations on it from Units 3 and 4. This analysis is required in order to fully 

gauge the environmental and public health impacts from the use of the earthen Squaw Creek 

Reservoir as a discharge point for radioactive effluent from Comanche Peak Units 3 and 4. Part 

of this analysis should be an assumption that the Squaw Creek Reservoir dam will at some 

point fail and release the sediment that is burdened by radioactive particulates. Downstream 

impacts on water quality, use, and impacts on mortality and morbidity must be a part of a proper 

EIS. The Squaw Creek Reservoir dam should also be analyzed for structural integrity. 

Protracted drought, seismic activity, or other natural events have the potential to weaken the 

dam and if a failure of the structure occurs radioactive sediment could be carried downstream 

with significant potential for environmental and public health impacts. (0022-13 [Hadden, 

Karen]) 

Comment: Squaw Creek Reservoir should be analyzed for radiological hazards because of 

radioactive particulates currently discharged from Comanche Peak Units 1 and 2 that are 

accumulating in sediment and additional radionuclide loading if Units 3 and 4 are operational. 

(0022-8 [Hadden, Karen]) 

Response: The staff will evaluate the radiological impacts of normal operation of the proposed 

new reactor units in Chapter 5, and the cumulative impacts of the new units in conjunction with 
Appendix D 

NUREG-1943 D-38 May 2011 

existing Units 1 and 2 in Chapter 7 of the EIS. Potential effects on both human health and 

ecological receptors will be assessed based on appropriate exposure scenarios. 

Comment: Tritium and other radioactive particulates as well as water temperatures are major 

concerns for the receiving waters. These must be adequately addressed in light of the additional 

water discharges from Units 3 and 4 both in the receiving waters, but also downstream. (0032-7

[Reed, Cyrus]) 

Response: The staff will evaluate the radiological impacts of normal operation of the proposed 

new reactor units in Chapter 5, and the cumulative impacts of the new units in conjunction with 

existing Units 1 and 2 in Chapter 7 of the EIS. Potential effects on both human health and 

ecological receptors will be assessed based on appropriate exposure scenarios. Potential 

impacts to aquatic life from the thermal discharge of the proposed new units also will be 

assessed for Lake Granbury and the Brazos River downstream in Section 5 of the EIS. 

Comment: The other thing I'd like to address is the biggest thing that we missed of all, is on the 

environmental studies, is what happens after they cool the plant. They release the water down 

Squaw Creek, which is just about a mile behind you. And that water is extremely hot. It's not 

warm water; it's hot water. 

Now then, in the past ten to 12 years—and I'm just talking about Squaw Creek, which is not a 

very big area—there were many, many frogs and soft-shelled turtles, many of them, and nobody 

in this room has been on that river more than I have. There's no soft-shelled turtles down there. 

The frogs are gone. And I've always been informed in environmental, frogs are the first thing 

that tell you there's something wrong. And there's something wrong with the release of that 

water. 

The water is too hot. It has bothered the spawning of the fish. When I say there's no—I don't 

mean there's not any. mean, they're disappearing. The fish, they're still there, but they're 

disappearing. There's something wrong that needs to be looked into in your study very, very 

serious. Something that's not happening, not something that you need to do later on; it's 

something that needs to be done right now. It's happening as we're sitting here. 

And it's something on all these studies—and I notice on that chart up there, it said aquatic 

studies. I've never seen one. I've never seen one of what happens after the fact. Studies are 

done about the fish in the lake, but nothing is happen—and it's just growing right down the river. 

The—it's not the only problem, The problem is with low water, if you add hot water, you get hot 

water down the river in the summertime. And if you—all you have to do is go stick your hand in 

it. And it's hot. And it's something that I'd like for you to address, and really it's never been even 

looked at. And why we let it get by, I don't know, but I never thought about it until after the fact. 

And the only way that I really know about this is firsthand information, because I'm on that river 

every single day. (0016-64 [Cathey, Jack]) 

Response: The NRC staff will assess potential impacts to aquatic life in Lake Granbury, the 

Brazos River, and Squaw Creek due to thermal discharge from the proposed new reactor units 

in Chapter 5 of the EIS. 

Comment: The above article said that water will be returned at 91 to 93 degrees. If we have 

limited rain and the BRA chooses to decrease the flow from PK then what will happen to the 

water temperature of the water at the dam site? This is the only deep water area of the lake. 

What becomes of our game fish? 

(0020-2 [Bernier, Jim]) 
Appendix D 

May 2011 D-39 NUREG-1943 

Response: The NRC staff will assess potential ecological and hydrological impacts in Lake 

Granbury, the Brazos River, and Squaw Creek Reservoir due to operation of the intake and 

discharge from the proposed new reactor units in Chapter 5 of the EIS. 

Comment: A Total Dissolved Solids (TDS) concentration of 1680 mg/l is on the borderline for 

lethal toxicity, and a TDS concentration of 2500 mg/l is above. Given that there will also be 

biocide usage in the cooling towers, whole effluent toxicity (WET) testing will be required, and 

there is reason to expect lethal and sublethal effects in WET testing. CPNPP should sample the 

water from Lake Granbury and perform 7-day chronic toxicity tests. CPNPP should also 

evaporate a portion of the sample to approximately 2500 mg/l and perform the same test. This 

would be predictive of the final effluent and would provide a sound basis for decision-making. 

(0027-10 [Osowski Morgan, Sharon L.]) 

Response: Impacts on aquatic biota and habitat due to liquid chemical effluents resulting from 

facility operation will be discussed in Section 5.3.2. 

Comment: Biodiversity is defined as the variety of plants and animals (biota) of a site or region, 

and is typically measured by the number of different species and number of individuals per 

species. In general, the more diverse an area is (number of habitat types and animal 

inhabitants) and the better represented these components are (population counts), the more 

rigorous (resistant, undisturbed, natural, healthy) the area is considered. Specifically, 

sustainable (or self managed) native biodiversity is preferred compared to an increase in the 

number of invasive, edge, or opportunistic species. Invasive, edge, or opportunistic species may 

compete with native species and have the potential to dramatically change local ecosystems so 

that they are not sustainable. Implementing BMPs or other measures to reduce invasive species 

establishment should be discussed (Executive Order 13112). 

The NEPA document should discuss native biodiversity aspects of the proposal as appropriate. 

For example, will the project increase, restore, or decrease native biodiversity of the area or 

region? Coordination with the U.S. Fish and Wildlife Service (FWS), and Texas Parks and 

Wildlife Department is recommended regarding the design of any project mitigation areas to 

enhance or restore biodiversity. 

Studies as similar as possible to those performed prior to Units 1 and 2 becoming operational 

(1981) should be conducted for comparison purposes and to ascertain losses in species 

abundance and richness over time. For example, 26 species of fish were caught in 1987, but 

only 10 in 2007 (Table 2.4-13). Tables 2.4-3, 2.4-4, 2.4-7, 2.4-13, and 2.4-14 all show declines 

in species richness over time. If the method used led to misleading sample, then new sampling 

schemes should be developed or methods used in 1987 should be used (p. 2.4-24). Table 2.4-4 

has observed and expected data; therefore, simple statistics (like Chi squared, etc) could be 

performed to provide confidence bounds on the data and to determine whether the observations 

show a true pattern or are random statistical events. 

The ER indicated that CPNPP would draw water for cooling from Lake Granbury. Additional 

studies of the impacts to aquatic ecology should be performed. Even though aquatic organisms 

may retreat to other areas in SCR or Lake Granbury, there are limits to what the organisms can 

tolerate, both in pollutant load, sediment load, high water temperature, and the amount of time 

they are exposed to such conditions (p. 4.3-10). (0027-21 [Osowski Morgan, Sharon L.]) 

Response: Impacts on aquatic ecology from cooling water withdrawals and discharges, 

including the potential for impacts on the biodiversity of aquatic communities, will be analyzed 

based on available data for Lake Granbury, the Brazos River, and Squaw Creek Reservoir in 

Chapters 4 and 5 of the EIS. 
Appendix D 

NUREG-1943 D-40 May 2011 

Comment: Chapter 2 -Existing Environment: Section 2.4 of the ER references a List of 

Somervell County Threatened and Endangered Species to address state-listed threatened or 

endangered species that may occur at the proposed CPNPP site. The ER failed to include the 

TPWD Annotated List of Rare Species for Hood County, though it appears that components of 

the project would occur within Hood County. Additionally, the ER only addressed state-listed 

threatened or endangered species, but did not address all species included on the Annotated 

County List of Rare Species. Those species on the list with a blank under federal or state status 

are tracked by TPWD and considered rare. Rare species are of conservation concern by TPWD 

within Texas, and efforts to minimize impact to such species are encouraged to help prevent 

future listing of the species. 

The most up-to-date TPWD Annotated County Lists of Rare Species are available at 

http://gis.tpwd.state.tx.us/TpwEndangeredSpecies/DesktopDefault.aspx. The lists provide 

information regarding rare species that have potential to occur within each county. Rare species 

could potentially be impacted if suitable habitat is present at or near the project site. (0029-1

[Boydston, Kathy]) 

Comment: The EIS should address all species on the Hood and Somervell County Lists 

including rare, threatened, and endangered species. The project site should be assessed to 

determine if suitable habitat for any of these species occurs within or near the proposed area 

and to determine if construction and operation of the project would impact the species or 

habitats. (0029-1 [Boydston, Kathy]) 

Response: For both Somervell and Hood Counties, species with a Federal or State listing 

status of endangered or threatened and species considered by the State as rare will be 

identified in Chapters 2 of the EIS, and potential impacts to these species from construction and 

operation of the proposed new reactor units will be evaluated in Chapters 4 and 5, respectively. 

Comment: Section 2.4.2.2 of the ER provides basic details about the fish studies conducted for 

Squaw Creek Reservoir and Lake Granbury. Fish avoidance of gill nets is a known problem in 

reservoirs with high water clarity, such as Squaw Creek Reservoir and near the dam on Lake 

Granbury. (0029-3 [Boydston, Kathy]) 

Comment: Further information is needed about the monofilament nets used to sample the fish 

population, the depth at which gill nets were placed, and the gill net mesh size used. Mesh sizes 

too large to capture smaller fish would produce inaccurate results. Electrofishing, even with high 

total dissolved solids, would likely provide important additional information on fish populations in 

both reservoirs. Seining in littoral areas could provide information about smaller species that are 

unlikely to be captured by gill nets. (0029-3 [Boydston, Kathy]) 

Response: Additional information about fish sampling methods and apparatus will be provided 

in Section 2.4.2 of the EIS. 

Comment: During the February 2, 2009 site visit, and in Section 4.3.2.4 of the ER, it was 

mentioned that fish populations are struggling in Lake Granbury. The consultant's sampling at 

four sites near the dam claims to support this opinion. The TPWD Inland Fisheries staff 

conducts full fishery studies on the lake every four years as well as ongoing fish sampling. 

These studies show that only a few fish species have declined post-golden algae kills, many 

have remained at the same population levels, and some have increased in numbers (Baird and 

Tibbs 2006). The opinion that the fishery is dead by the dam due to golden algae is not 

supported by the information provided. Request: TPWD requests a copy of the fish studies 

conducted by Luminant's consultant, specifically the studies referenced in Chapter 2.4 of the 
Appendix D 

May 2011 D-41 NUREG-1943 

ER, Bio-West 2008a and 2008b. TPWD staff may have additional comments following review of 

the consultant's report. (0029-5 [Boydston, Kathy]) 

Response: The information provided by the TPWD fisheries study in Lake Granbury will be 

considered in conjunction with the studies cited in the applicant's ER when the NRC staff 

assesses in the EIS the current condition of fish populations in the lake and potential future 

impacts. 

Comment: Section 5.2 discusses water-related impacts associated with water withdrawal from 

Lake Granbury, water loss, and return discharge to Lake Granbury. The ER claims that there is 

currently minimal use of water in the Brazos River from Possum Kingdom Lake to Lake 

Whitney; and due to the minimal water use and other users returning water to the Brazos River 

Basin, the project impacts are not expected to affect the available water for other water users 

nor for the aquatic ecological communities of the Brazos River. The ER considers the impacts 

from the CPNPP water withdrawal and discharge rates as small. The ER presents the reported 

mean monthly discharges at DeCordova Bend Dam at 1,031 cubic feet per second (cfs) and 

indicates that anticipated normal discharge would be 55.43 cfs during operation of CPNPP 

Units 3 and 4. 

The operational impacts associated with water use do not specifically address potential impacts 

to aquatic resources such as potential impacts to the state threatened Brazos Water Snake 

(Nerodia harteri), various rare species of mollusks listed on the county lists, and other aquatic 

resources occurring or potentially occurring downstream of Lake Granbury. Potential impacts 

associated with CPNPP water losses need to be specifically addressed for aquatic resources 

within the Brazos River Basin. (0029-16 [Boydston, Kathy]) 

Response: The NRC staff will assess potential impacts on aquatic life in the Brazos River 

basin due to hydrological effects from operation of the proposed new reactor units in Chapter 5 

of the EIS. 

Comment: Chapter 2 Section -2.3.3.1.9 and Chapter 5 Sections -5.2.1. 7 and 5.2.3.4, Golden 

algae, specifically Prymnesium parvum, are microscopic plants present in Possum Kingdom 

Reservoir, Lake Granbury, and Lake Whitney, as well as other areas in the state. The alga 

prefers saltier water for growth as it is a marine species. Lower water levels in Possum Kingdom 

Reservoir would likely make the lake more susceptible to golden alga. Like most other 

reservoirs, when the water level in Possum Kingdom Reservoir is low, conditions become more 

saline and nutrients become more concentrated. Historically, both conditions have been 

associated with increased occurrence and severity of golden algal blooms in Possum Kingdom 

Reservoir and other Texas reservoirs. An increase in salinity (conductivity) within Lake 

Granbury would likely also cause enhanced golden algal blooms. With the return water entering 

by the dam, the potential for increased conductivity by the dam and immediately downstream is 

a concern as well. (0029-17 [Boydston, Kathy]) 

Comment: If golden alga occurrences increase in severity after periods of water loss, then 

Luminant may be required through TPWD's civil restitution process to mitigate for fish mortalities 

from these golden alga kills and may be asked to contribute to annual restocking efforts or 

golden alga treatment and research. (0029-17 [Boydston, Kathy]) 

Response: Water quality impacts from operation of the proposed new reactor units and their 

potential effects on aquatic life will be assessed in Chapter 5 of the EIS. 

Comment: TPWD has concerns about increased selenium levels in Lake Granbury and 

downstream portions of the Brazos River resulting from the discharge. As stated in 

Section 5.2.3.4, When half the detection limit was used to estimate concentrations that would 
Appendix D 

NUREG-1943 D-42 May 2011 

result from CPNPP Units 3 and 4 2.4-cycle cooling tower operation, selenium was estimated to 

exceed the Texas Commission on Environmental Quality (TCEQ) Criteria for Specific Metals in 

Water for Protection of Aquatic Life and also for both the mean and maximum concentrations 

when mixed with Lake Granbury at low flow. However, selenium is expected to be reduced to 

concentrations less than the TCEQ standards for Specific Metals in Water for Protection of 

Aquatic Life at the edge of the mixing zone in Lake Granbury during the annual mean flow for 

both mean and maximum concentrations. The acute freshwater criteria for selenium is 0.020 

mg/L and freshwater chronic criteria is 0.005 mg/L (TCEQ 2008). Exceeding the set criteria can 

be harmful to aquatic life within and downstream of the reservoir. (0029-18 [Boydston, Kathy]) 

Comment: Section 5.2.2.3.1: The consumptive demands from the project are a concern for the 

Brazos River Basin. Chapter 3 Section 4 indicates that Luminant will use up to 103,000 acrefeet per year (ac-ft/yr) of water from Lake Granbury for the cooling process with an estimated 

evaporative loss of 61,000 ac-ft/yr. The loss of 61,000 ac-ft/yr from Possum Kingdom Reservoir, 

Lake Granbury and the Brazos River will lead to declines in lake levels, a reduction of 

streamflow downstream of Lake Granbury, and a resultant wide range of impacts on fish and 

wildlife resources and recreation. 

Fisheries may be impacted; reduced flows in the Brazos River below Waco may impact several 

imperiled fish species, as well as a vulnerable alligator gar fishery. Water levels are also 

anticipated to drop in Possum Kingdom Reservoir since the water for Units 3 and 4 will be taken 

from Lake Granbury but supplied by releases from Possum Kingdom Reservoir. Currently, 

Possum Kingdom Reservoir struggles with having enough water to inundate littoral vegetation 

during spawning times for a variety of sport fish. The proposed water loss would exacerbate an 

already less than desirable condition. In addition, lowering the water level in Possum Kingdom 

Reservoir will expose fish habitat used for sheltering and feeding, as well as for breeding. This 

loss of habitat, especially during spawning season, is likely to impact fish populations. (0029-19

[Boydston, Kathy]) 

Response: The NRC staff will assess potential hydrological, water quality, and resulting 

ecological impacts in the Brazos River basin associated with the intake and discharge from 

operation of the proposed new reactor units in Chapter 5 of the EIS. 

D.2.12 Comments Concerning Socioeconomics 

Comment: And as far as y'all wanting to bring in extra jobs and more people, you would think it 

would be a joke about Weatherford having traffic problems. But try to be on Main Street or 

Santa Fe some day between four and five o'clock. Weatherford has traffic jams, and it's crazy, 

but at least they've got those big trucks and all the equipment that are related to the Barnett 

shale drilling. And the trucks are tearing up our roads. (0016-70 [Kinzie, W.T.]) 

Response: Potential effects on local roads and traffic conditions will be addressed in Section 4 

of the EIS for the construction period and in Chapter 5 of the EIS for the operations period. 

Comment: The City knows that this could have some burdens on the City, because we don't 

get any tax dollars for it, and we know that it could prevent a lot of people from moving into the 

city. It might have an effect on the water and the sewer and the roads. (0017-1 [Miller, Pam]) 

Response: Potential effects on local roads and traffic conditions, public services, and tax 

revenues will be addressed in Chapter 4 of the EIS for the construction period and in Chapter 5 

of the EIS for the operations period. 

Comment: The EIS should also consider whether regional waterways will be impacted in terms 

of water quantity and quality by the use of vast quantities of water for Units 3 and 4, including 
Appendix D 

May 2011 D-43 NUREG-1943 

Lake Granbury, the Brazos River, the Paluxy River, Whitney Lake, a popular fishing lake, and 

popular recreational areas such as Possum Kingdom. According to the Texas Parks and Wildlife 

Department web site, the drinking water at Possum Kingdom State Park is currently non-potable 

due to a high salt content, and visitors must bring their own water for consumption. The potential 

to increase salt content of waterways in the region by further drawdown of water levels, 

including impacts to the local aquifer and drinking wells should be examined thoroughly in the 

EIS. (0022-23 [Hadden, Karen]) 

Response: Potential impacts of plant operations on water quantity and quality in regional 

waterways will be addressed in Chapter 5 of the EIS. 

Comment: Since the specialized job skills required to manufacture nuclear reactors are 

virtually non-existent in the US, what is the plan to create jobs for Americans if the Comanche 

Peak project is approved? (0023-1 [Ubico, Jean]) 

Response: Potential effects on employment will be addressed in Chapter 4 of the EIS for the 

construction period and in Chapter 5 of the EIS for the operations period. 

Comment: When the first two reactors were built the sky glow light pollution went from zero to 

off the scale in the direction of the reactors. The latest round of fixture modernization reduced 

the sky glow by about 40 percent. Our Concern is the two new units will increase the sky glow 

beyond what it was after initial construction. We would like to see a comprehensive relighting 

program for all four reactors, using the latest technology zero cut-off fixtures, such as those 

approved by the International Dark-sky Association in order to achieve an overall reduced light 

pollution impact than what now exists. 

www.darksky.org (0024-3 [Miller, Russ]) 

Response: The effects of light pollution from the proposed new reactors will be addressed in 

Chapter 5 of the EIS. 

Comment: I would like to see the lake at the Comanche Peak Nuclear Power Plant reopened 

for fishing. The possiblilty of a special license seems like a logical way to go to me. Restricted to 

Texas residences with concealed handgun licenses may be an option, since they have already 

passed a background check. Also, advance reservations, limited number of boats on the lake at 

a time, no more than 3 people per boat, etc. Fingerprints, photo on file, etc. Fishing only. No 

skiing or jet skis. Daylight hours only. I would like to allow tube floats and oar prepelled 

watercraft. You could even set it up with a limited season only open during certain months. It 

just seems a shame to me that this lake is closed to the taxpayers of Texas and the honest law 

abiding fishermen (and women). (0007-1 [Drechel, Gary]) 

Response: The potential effects of plant construction and operations on recreation will be 

addressed in Chapters 4 and 5 of the EIS. 

Comment: The new plant will need to use existing roads and to build new ones. Lots of cars, 

trucks, and machinery will pass over them. 

 How will Luminant ensure that roads are not congested? How will Luminant transport 

uranium and on which highways? Which communities will it pass through, and will their 

police and firefighting forces be trained to deal with a radioactive accident? 

 How would Luminant transport low-level and high-level radioactive waste if offsite storage 

ever gets approved? 

(0019-23 [Hadden, Karen]) 
Appendix D 

NUREG-1943 D-44 May 2011 

Response: Existing local road and traffic conditions will be described in Chapter 2 of the 

EIS. The effects of plant construction and operations on local roads and traffic will be addressed 

under Socioeconomics in Chapters 4 and 5. In addition, the impacts of transporting unirradiated 

and spent fuel will be addressed directly in Chapter 6 of the EIS. 

Comment: Comanche Peak is very vital to the local economy (0004-4 [Luton, John Henry]) 

Response: The potential effects of plant construction and operations on local employment, 

expenditures, and tax revenues will be addressed in Chapters 4 and 5 of the EIS. 

Comment: The City of Granbury has joined Hood County in soliciting funds, or looking for 

funds, to build the new access route to come near the Comanche Peak location, to provide 

better access to and from the location. We do hope you all will endorse that project as well. 

(0016-3 [Johnson, Lisa]) 

Response: A description of local roads and traffic conditions in the vicinity of the site will be 

provided in Chapter 2 of the EIS. The effects on local roads and traffic conditions during the 

construction and operation periods will be addressed in Chapters 4 and 5 of the 

EIS. Endorsement of mitigation activities are outside the scope of the NRC’s authority and will 

not be addressed further. 

Comment: And as an economic development, I know that the NRC is not in economic 

development, but it's very nice for our community to have the jobs that come along with 

expansion, the jobs and the need for new housing, the need for restaurants and services in our 

community, which currently is vastly needed. (0016-32 [Ward, Mary]) 

Response: The effects of plant construction and operations on local employment, 

expenditures, and housing will be addressed in Chapters 4 and 5 of the EIS. 

Comment: I'm also the incoming president of the Brazos River Conservation Coalition. ... 

We're an organization of about 700 members from Parker, Palo Pinto, and Hood and Somervell 

County. Right now we have an initiative to declare the—and it's in the legislature, or it's going in 

this session—the Brazos River and Lake Granbury—Brazos River in Hood and Somervell 

County as part of the John Graves Scenic Riverway. I don't know how many people from 

outside the area know just what a beautiful resource it is. We heard some of the people talking 

about it. It's a resource that's under a lot of pressure. (0016-78 [Rosenfeld, Joshua]) 

Response: A description of local aesthetic and recreational resources in the vicinity of the site 

will be provided in Chapter 2 of the EIS. Effects on local aesthetic and recreational resources 

during the construction and operation periods will be addressed in Chapters 4 and 5 of the EIS. 

Comment: We don't need to contribute to the economy of Somervell County and Hood County 

for the benefit of their gaining on a rate. (0017-12 [Burnam, Lon]) 

Response: The impacts of plant construction and operations on local employment, 

expenditures, and tax revenues will be addressed in Chapters 4 and 5 of the EIS. 

Comment: I am a business owner here in Glen Rose. I have been, and I have had land here 

for over ten years. And one of the things that attracted me to this area was the fact that there 

was a nuclear power plant here. Recently, I just invested over $6 million in this community in a 

hotel. Based on the future growth that these kind of communities bring. (0017-56 [Sheaks, 

Jerry]) 

Response: The effects of plant construction and operations on the local economy and the 

demand for housing will be addressed in Chapters 4 and 5 of the EIS. 
Appendix D 

May 2011 D-45 NUREG-1943 

Comment: Section 5.2.2.3.1: The consumptive demands from the project are a concern for the 

Brazos River Basin. Chapter 3 Section 4 indicates that Luminant will use up to 103,000 acre 

feet per year (ac-ft/yr) of water from Lake Granbury for the cooling process with an estimated 

evaporative loss of 61,000 ac-ft/yr. The loss of 61,000 ac-ft/yr from Possum Kingdom Reservoir, 

Lake Granbury and the Brazos River will lead to declines in lake levels, a reduction of 

streamflow downstream of Lake Granbury, and a resultant wide range of impacts on fish and 

wildlife resources and recreation. ... Potential recreational effects span from Possum Kingdom 

Reservoir, to below the Lake Granbury dam, to the Brazos River below the city of Waco. 

Possum Kingdom Reservoir receives heavy recreational use, Lake Granbury supports 

recreational use, water skiers frequently use the Brazos River between Lake Granbury and 

Lake Whitney, and Lake Whitney has been rated the top destination by the citizens in the 

Dallas/Fort Worth area. Downstream of Lake Whitney, the Brazos River has been recognized as 

a canoeing and kayaking destination and Lake Brazos within the city of Waco is currently being 

developed into a major greenbelt. (0029-20 [Boydston, Kathy]) 

Response: Potential impacts of plant operation on water-based recreation in the region will be 

addressed in Chapter 5 of the EIS. 

D.2.13 Comments Concerning Historic and Cultural Resources 

Comment: On December 30, 2008, the Advisory Council on Historic Preservation (ACHP) 

received from the Nuclear Regulatory Commission (NRC) a notification pursuant to Section 

800.8(c) of the ACHP's regulations, Protection of Historic Properties (36 CFR 800), regarding 

the referenced project. We appreciate receiving your notification, which establishes that NRC 

will use the process and documentation required for the preparation of an EA/FONSI or an 

EIS/ROD to comply with Section 106 of the National Historic Preservation Act in lieu of the 

procedures set forth in 36 CFR 800.3 through 800.6. 

In addition to notification to the ACHP, NRC must also notify the Texas State Historic 

Preservation Officer and meet the standards in Section 800.8(c)( I)(i) through (v) for the 

following: 

 identifying consulting parties; 

 involving the public; 

 identifying historic properties and assessing the undertaking's effects on historic properties; 

and 

 consulting regarding the effects of the undertaking on historic properties with the 

SHPO/THPO, Indian tribes and Native Hawaiian organizations that might attach religious 

and cultural significance to affected historic properties, other consulting parties, and the 

ACHP, where appropriate, during NEPA scoping, environmental analysis, and the 

preparation of NEPA documents. 

To meet the requirement to consult with the ACHP as appropriate, the NRC should notify the 

ACHP in the event NRC determines, in consultation with the SHPO/THPO and other consulting 

parties, that the proposed undertaking(s) may adversely affect properties listed, or eligible for 

listing, on the National Register of Historic Places (historic properties). In addition, Section 

800.8(c)(2)(i) requires that you submit to the ACHP any DEIS or EIS you prepare. Inclusion of 

your adverse effect determination in both the DEIS/EIS and in your cover letter transmitting the 

DEIS/EIS to the ACHP will help ensure a timely response from the ACHP regarding its decision 

to participate in consultation. Please indicate in your cover letter the schedule for Section 106 

consultation and a date by which you require a response by the ACHP. 
Appendix D 

NUREG-1943 D-46 May 2011 

The regulations do not specifically require that an agency submit an EA to the ACHP. However, 

keep in mind that, in the case of an objection from the ACHP or another consulting party, 

Sections 800.8(c)(2)(ii) and (c)(3) provide for ACHP review of an EA (in addition to a DEIS or 

EIS) to determine whether preparation of the EA, DEIS or EIS has met the standards set forth in 

Section 800.8(c)(1) and/or to evaluate whether the substantive resolution of the effects on 

historic properties proposed in an EA, DEIS or EIS is adequate. 

If NRC's determination of adverse effect will be documented in an EA, we request that you 

notify us of the adverse effect and provide adequate documentation for its review. The ACHP's 

decision to review an EA, DEIS or EIS will be based on the applicability of the criteria in 

Appendix A of the ACHP's regulations. (0036-1 [Duvall-Gabriel, Najah]) 

Response: If the staff determines that the proposed undertaking will adversely affect properties 

listed, or eligible for listing, on the National Register of Historic Places (historic properties), the 

NRC will notify the ACHP in accordance with the consulting requirements. Additionally, in 

accordance with Section 800.8(c)(2)(i) of 36 CFR Chapter 800, the NRC staff will submit copies 

of the DEIS and EIS to the ACHP upon completion of the documents. As part of its 

environmental review of historic and cultural resources, the NRC staff consulted with the Texas 

Historical Commission (THC) and other appropriate information sources. The results of the 

analysis will be presented in Chapter 4 of the EIS, and the staff will take any appropriate action 

called for as a result of this review. 

Comment: The Tonkawa Tribe has no specifically designated historical or cultural sites 

identified in any of the above listed project areas. However if any human remains, funerary 

objects, or other evidence of historical or cultural significance is inadvertently discovered then 

the Tonkawa Tribe would certainly be interested in proper disposition thereof. 

We appreciate notification by your office of the many projects on-going, and as always the 

Tonkawa Tribe is willing to work with your representatives in any manner to uphold the 

provisions of NAGPRA to the extent of our capability. (0037-1 [Illegible, Illegible]) 

Response: As part of its environmental review of historic and cultural resources, the staff met 

with the Texas Historical Commission (THC) and other appropriate information sources. The 

results of the analysis will be presented in Chapter 4 of the EIS, and the staff will take any 

appropriate action called for as a result of this review. 

Comment: A cultural resource survey should be coordinated with the State Historic 

Preservation Officer (SHPO). Besides the consideration of listed historical sites, the NEPA 

document should discuss procedures for events such as unearthing archaeological sites during 

prospective construction. Such procedures should include work cessation in the area until 

SHPO approval of continued construction. (0027-19 [Osowski Morgan, Sharon L.]) 

Response: A previously conducted cultural resource survey provided coverage of the area that 

might be impacted by the proposed project. On February 21, 2007, the Texas State Historic 

Preservation Officer (SHPO) sent a concurrence letter to the applicant noting that no historic 

properties would be affected by the proposed action. This letter was referenced in the 

applicant's Environmental Report and will be included in an appendix of the EIS. Additionally, 

the NRC staff will discuss the applicant's procedures for dealing with unanticipated 

archaeological finds in Chapter 4 of the EIS. 
Appendix D 

May 2011 D-47 NUREG-1943 

D.2.14 Comments Concerning Environmental Justice 

Comment: The proposed new plants would affect low income and minority residents. 

 How much will rent go up when the influx of construction workers and their families come to 

Somervell County? 

 Will pollution from construction and operation reach low-income housing areas? 

(0019-25 [Hadden, Karen]) 

Response: Effects on housing availability will be addressed in Chapter 4 of the EIS for the 

construction period and in Section 5 of the EIS for the operations period. Effects on minority 

and low-income populations specifically will also be addressed in Chapters 4 and 5 of the EIS. 

Comment: Consistent with Executive Order 12898, potential EJ [environmental justice] impacts 

should be considered in the NEPA document. An EJ survey is to ensure equitable 

environmental protection regardless of race, ethnicity, economic status or community, so that no 

segment of the population bears a disproportionate share of the consequences of environmental 

pollution attributable to a proposed project. 

Since uranium mining that occurs in the US may impact tribal lands or environmental justice 

areas in the western states primarily (including portions of New Mexico and Texas), the potential 

impacts of increased uranium mining (e.g., in situ leach) and increased exposure of residents 

should be evaluated. Links between the proposed project and NUREG-19l0 should be included 

in the NEPA document. 

Secondary impacts to low income, minority, and tribal communities concerning the use of the 

Yucca Mountain repository and transportation routes from the uranium processing facility should 

also be incorporated. 

EPA recommends that the EIS provide clarification regarding resource dependencies or 

practices, such as subsistence agriculture, hunting, or fishing, through which certain populations 

could be disproportionately affected. Low-income populations are likely to conduct such 

subsistence practices. EPA recommends the EIS include a more comprehensive discussion of 

potential benefits and impacts associated with the project, as it relates to minority and lowincome populations and the population at large. (0027-20 [Osowski Morgan, Sharon L.]) 

Response: Impacts on low-income and minority populations residing in the impact region, 

including impacts associated with subsistence activities in the vicinity of the plant, will be 

addressed in Chapters 4 and 5 of the EIS. Possible impacts occurring outside the impact region 

(such as those associated with mining and spent fuel storage) are beyond the scope of this 

environmental review and will not be addressed in the EIS. Mining, milling, and waste storage 

operations are all subject to separate regulatory processes. 

D.2.16 Comments Concerning Health - Radiological 

Comment: There are routine releases from nuclear plants. Most people don't know this. This is 

not being adequate addressed, and needs to be, through the environmental impact statement 

and other avenues. There is no federal standard called a MACT, maximum achievable control 

technology standard, for radionuclides. That has been done for other industries, for example, for 

their mercury in the coal plants. That needs to happen. (0016-21 [Hadden, Karen]) 

Comment: Right now there are high levels of tritium from this plant, and this needs to be 

looked into in the environmental impact statement. And they are high compared to other nuclear 

reactors in the country. (0016-25 [Hadden, Karen]) 
Appendix D 

NUREG-1943 D-48 May 2011 

Comment: But let's talk about the cancer and the background rate. 

It is a simple fact of life that there is background radiation. And then there is also a simple fact of 

life, since the first above-ground explosions of nuclear weapons, we've increased that 

background radiation. There's also a simple fact of life that background radiation is higher at 

every nuclear power facility in the country. And if you double that, it's a simple fact of life that 

you're going to double background radiation in this community. 

I want the environmental impact statement to do an honest analysis and assessment of what 

that means to the cancer rate in this region. I represent 150,000 people within 50 miles of this 

facility, and I think it's reasonable to expect that that kind of analysis is done. (0016-39 [Burnam, 

Lon]) 

Comment: I also hope that you'll be looking at issues like release of tritium to the water, the 

potential—I'm not—I don't know that much about this particular process, because frankly the 

design hasn't been certified yet, but in terms of—there have been problems in the past with 

releases of tritium into water at nuclear plants. I don't know if that would be the case in this 

particular plant. So I would urge you to look at that. 

(0016-53 [Reed, Cyrus]) 

Comment: I would urge you to look at, you know, there's not a lot of scientific study on what 

are the impacts of noble gases, which are often released at nuclear plants. But I hope that will 

be part of your review as well. (0016-54 [Reed, Cyrus]) 

Comment: But the problem is, that not only do we have a massive increase of cancer, because 

of the entire fuel line from the uranium mining, to the fact that we haven't been able to resolve 

the deposition of the polluted radiation, we have got a gene pool issue. (0017-10 [Burnam, Lon]) 

Comment: Why is the tritium level higher here? You have got the problem now with the two 

facilities. Will two additional facilities make that tritium level even that much higher? (0017-14

[Burnam, Lon]) 

Comment: One of my biggest concerns is the risk from the radiation. And the fact that the 

more radiation that there is, that the greater risk will be to the community. And the 

Environmental Impact Statement should thoroughly examination all of the radiation health risks. 

And no national standard has been set for the radio nucleate emissions, despite the fact that 

nuclear reactors routinely emit cancer causing radioactivity. And really, no new reactors should 

be licensed until this standard has been set. 

Research has shown an increase in cancer rates around nuclear plants. And Dr. Joseph 

Mangano of the Radiation and Public Health Project studied the cancer death rate in the three 

counties closest to the South Texas Nuclear Project. An area that originally had a cancer rate 

below the statewide rate, in 16 years after the reactors began running, the cancer death rate in 

the area had risen over 16 percent. (0017-38 [Rooke, Molly]) 

Comment: the EIS should research the extent to which the new reactors would add to the 

cancer risks. 

And four reactors at one site would produce significantly more radioactive risks than the two 

existing reactors. 

And what would be the total amount of low level radiation emitted? And how much would 

surrounding populations be exposed to this? And how much radioactivity would be emitted, just 

in the routine operations. 
Appendix D 

May 2011 D-49 NUREG-1943 

And so the EIS should use background radiation levels in their studies and to compare them to 

construction of the two existing nuclear reactors. And I am concerned about what would happen 

with the radioactive gasses that would be vented. And not just during the normal operations, but 

during purges. And I am also concerned about what tritium would be released into the water at 

the new proposed plant. (0017-39 [Rooke, Molly]) 

Comment: Because as you have heard other people say, radiation affects you on a genetic 

level. It affects your DNA. So what damages your DNA will remain in all of the generations of 

your family to come. (0017-62 [Rittenhouse, Ryan]) 

Comment: from the very beginning to the very end, there is risk of radioactive release. 

(0017-69 [Sanders, Jan]) 

Comment: It hits the genetic mechanism of the human body and messes it up. And it is a slow 

deformity. But it has been tested out. It has been proven. And so why take the risk? 

(0017-71 [Sanders, Jan]) 

Comment: 

The ElS should research the extent to which new reactors would add to cancer risks. Four 

reactors at one site would produce significantly more radioactive risk than the two existing 

reactors. What would be the total amount of low-level radiation emitted? How much would 

surrounding populations be exposed? How much radioactivity would be in routine operations? 

The ElS should use background radiation levels not only from before the construction of the two 

existing nuclear reactors also from before the testing of nuclear weapons in the United States, 

which resulted in radioactive fallout. (0019-10 [Hadden, Karen]) 

Comment: Radioactive tritium can leak from nuclear reactors and increase cancer risks. 

According to NRC reports tritium levels are already high at the Comanche Peak site compared 

to other reactor sites. What would adding more reactors do to the already high levels of 

contamination? (0019-15 [Hadden, Karen]) 

Comment: The Environmental Impact Statement (ElS) should thoroughly examine radiation 

health risks. (0019-9 [Hadden, Karen]) 

Comment: Comanche Peak Units 1and 2 already utilize Squaw Creek Reservoir as a 

discharge water body that receives radionuclides including tritium and radioactive particulates. 

Dr. Arjun Makhijani, president of the Institute for Energy and Environmental Research has noted 

the relatively high levels of tritium at this site compared to other nuclear reactors, which should 

be examined and compared to other sites in the EIS, and additional cumulative impacts should 

be analyzed. (0022-12 [Hadden, Karen]) 

Comment: The cumulative impacts on the food chain from the bioaccumulation and 

bioconcentration of radionuclides discharged from Units 3 and 4 should be considered in terms 

of the public health implications and the mortality and morbidity calculations related thereto 

should be a part of the EIS. (0022-29 [Hadden, Karen]) 

Comment: The EIS for the proposed expansion of Comanche Peak should quantify and 

speciate the various radionuclides emitted and quantify the total air emissions anticipated as a 

result of operation of Units 3 and 4 and determine mortality and morbidity consequences 

thereof. Additionally, because radionuclides are considered a hazardous air pollutant the EIS 

should analyze radioactive air emissions on a comparative basis with the emissions permitted 
Appendix D 

NUREG-1943 D-50 May 2011 

under the more relaxed standards applied to Units 1 and 2 and air emissions from Units 3 and 4 

under a MACT standard. (0022-38 [Hadden, Karen]) 

Comment: Squaw Creek Reservoir should be analyzed for radiological hazards because of 

radioactive particulates currently discharged from Comanche Peak Units 1 and 2 that are 

accumulating in sediment and additional radionuclide loading if Units 3 and 4 are operational. 

(0022-7 [Hadden, Karen]) 

Comment: The inevitable increase in radioactive emissions into the environment will not be 

beneficial. (0031-4 [Gentling, Suzanne]) 

Comment: Tritium and other radioactive particulates ... are major concerns for the receiving 

waters. These must be adequately addressed in light of the additional water discharges from 

Units 3 and 4 both in the receiving waters, but also downstream. (0032-8 [Reed, Cyrus]) 

Response: The EIS will address the human health impacts of exposure to radiological effluents 

from the existing and proposed Comanche Peak units in Section 5.9 of the EIS. 

Comment: We need to look closely at worker exposure. (0016-22 [Hadden, Karen]) 

Comment: Risks to employees and area residents should be addressed. 

Statements about high doses and low doses of radiation, their potential health effects, and 

established risk or exposure standards should be included in the NEPA document. (0027-5

[Osowski Morgan, Sharon L.]) 

Response: Occupational radiation exposure will be discussed in Chapter 5 of the 

EIS. Radiation exposure to construction workers will be addressed in Chapter 4 of the EIS. 

Comment: According to the Nuclear Information and Resource Service, the "Use of MOX fuel 

attacks commercial nuclear reactors where they are the weakest ... Because of its high neutron 

flux levels, the reactor pressure vessel can become embrittled and fail during accident 

conditions. A nuclear accident involving MOX fuel could cause a meltdown more serious than 

Three Mile Island or Chernobyl, because the levels of radiation inside a reactor using MOX are 

even higher than in a normal atomic reactor." These increased risks and the related increased 

worker and terrorism risks and potential resulting economic impacts from utilization of MOX fuel 

should be included in the EIS. (0022-26 [Hadden, Karen]) 

Response: Luminant has stated that it does not plan to use mixed-oxide fuel. If at some future 

date, Luminant should decide to use mixed oxide fuel at the Comanche Peak plant, the NRC 

staff would conduct a safety and environmental review of the proposal. 

Comment: The Comanche Peak environmental report at p. 5.7-3 concedes the fact that there 

is presently no means by which to dispose of high-level waste. Management of high-level waste 

on-site is limited to spent fuel pools or dry cask storage units. Alternatively, the environmental 

report suggests that for plants with inadequate wet or dry on-site storage capacity, spent fuel 

could be transferred off-site to another plant that has adequate storage capacity available. The 

EIS therefore, must consider the long-term environmental and public health consequences of 

spent fuel remaining on site at Comanche Peak indefinitely. A federal repository for spent fuel 

has not been approved and the prospects for such are, at best, problematic. Long-term spent 

fuel management on-site represents risks that are not fully assessed in the environmental 

report. ... Even if the dry cask storage units are not breached they still represent significant longterm sources of radiation. These radiation measurements should be calculated and added to the 

current projections for exposures to the extent that the environmental report understates such 

based on the assumption that spent fuel will eventually be moved off-site. The EIS should 
Appendix D 

May 2011 D-51 NUREG-1943 

assume that the dry cask storage units will remain on Comanche Peak's site indefinitely and 

make radiation exposure projections accordingly. (0022-40 [Hadden, Karen]) 

Response: Discussions of the estimated dose to construction workers and the public, including 

doses from dry cask storage, will be found in Chapters 4 and 5 of the EIS. 

Comment: I would love to see the issue addressed about Kleberg County, where the ground 

water currently contains unsafe levels of uranium and the EPA strongly advises against 

drinking it. 

It is not just about your counties. It is about Kleberg County. (0017-17 [Burnam, Lon]) 

Comment: The Environmental Protection Agency has warned residents of Kleberg County that 

their groundwater currently contains unsafe levels of uranium, and strongly advises against 

drinking it. (0019-27 [Hadden, Karen]) 

Response: The NRC will consider this information as part of the evaluation of cumulative 

impacts of the existing and proposed Comanche Peak units in Chapter 7 of the EIS. 

Comment: 

In 1980 the NRC conducted a study of what would happen under a worst-case scenario 

accident at each nuclear plant site. The Comanche Peak estimates were 

 1210 early deaths (25 mile radius around plant) 

 13,800 early injuries (35 mile radius) 

 $117 billion (1980 dollars) in financial consequences 

The EIS should update these risk figures and include the analysis in the report, taking into 

account the current population since the area has grown significantly since 1980 and since 

there would be two additional reactors at the site. 

The National Academy of Sciences has concluded that radiation is dangerous even at low levels 

(BEIR VII study). While low-level radiation exposure is not as damaging as high-level radiation 

on a short-term basis, prolonged exposure to low-level radioactivity can be just as damaging to 

humans. The EIS should research the extent to which new reactors would add to cancer risks, 

birth defects and genetic impacts. 

The EIS should include analysis of how much radioactivity would be released in routine 

operations and the frequency of releases that would occur. 

Original background radiation levels should be included in the report. Data or radiation 

estimates from before the two existing nuclear reactors were constructed should be included, as 

well as calculations of the true original background level that was present before the testing of 

nuclear weapons in the United States, and the radioactive fallout that resulted. (0022-30

[Hadden, Karen]) 

Response: The NRC will evaluate the human health impacts of exposure to radiological 

effluents from the existing and proposed Comanche Peak units in Section 5.9 of the EIS. The 

NRC will evaluate the human health risks of severe accidents in Section 5.10 of the EIS. 

Comment: The Comanche Peak environmental report relies on data from Table S-3. P. 5.7-17. 

However, Table S-3, fails to consider health effects from radioactive effluents and further does 

not estimate releases of either Radon-222 or Technetium-99. The Comanche Peak 

environmental report does discuss the dose commitment estimates of both RN-222 and TC-99. 
Appendix D 

NUREG-1943 D-52 May 2011 

However, there is no analysis of mortality or morbidity consequences related to conditions of 

either radionuclide. The EIS should consider the mortality and morbidity consequences related 

to the emissions of all the radionuclides anticipated from the routine operations of Comanche 

Peak Units 3 and 4. Mortality and morbidity analyses should also occur for accident scenarios 

involving releases of radionuclides from Comanche Peak Units 3 and 4. (0022-36 [Hadden, 

Karen]) 

Comment: The EIS for the proposed expansion of Comanche Peak must account for 

increased quantities of radiological waste streams and the environmental impacts and public 

health consequences thereof. The environmental report fails to fully quantify the environmental 

impacts and public health consequences and omits altogether mortality and morbidity analyses 

associated therewith. A proper EIS must account for environmental and public health 

consequences associated with increased quantities of radioactive waste originating at Units 3 

and 4. This analysis should include disposition of large plant components such as steam 

generators that may require replacement before expiration of the reactors' useful lives. 

Replacement and disposition of steam generators is not a far-fetched or speculative possibility. 

The Trojan nuclear plant in Oregon replaced its steam generators. Trojan's original steam 

generators were shipped on the Columbia River by barge to a disposition site in Washington 

state. The EIS related to Comanche Peak should include an analysis of the environmental 

impacts and public health consequences of replacing steam generators at Comanche Peak 

Units 3 and 4 including radiological impacts both on-site and off-site. (0022-37 [Hadden, Karen]) 

Response: The impacts of the uranium fuel cycle, including disposal of low-level radioactive 

waste and spent fuel, will be addressed in Chapter 6 of the EIS. 

Comment: The environmental report indicates that Squaw Creek Reservoir will continue to be 

the receiving body of water for various discharges from Comanche Peak Units 3 and 4. The 

Environmental Report concedes that radioactive particulate matter released to Squaw Creek 

Reservoir in liquid effluents will be deposited into the sediment layer of the reservoir bottom and 

remain there indefinitely. Comanche Peak NPP Environmental Report, p.5.11-3. In the event of 

a protracted drought, and inadequate flow into Squaw Creek Reservoir, the sediment layer 

could become exposed and, if adequately deliquified, would become dust and subject to 

transport by wind with clear public health and environmental consequences. 

Therefore, it is crucial that the EIS include a complete radiological profile of the existing 

sediment in Squaw Creek Reservoir and an analysis of the cumulative radiological impacts 

expected from operations on it from Units 3 and 4. This analysis is required in order to fully 

gauge the environmental and public health impacts from the use of the earthen Squaw Creek 

Reservoir as a discharge point for radioactive effluent from Comanche Peak Units 3 and 4. Part 

of this analysis should be an assumption that the Squaw Creek Reservoir dam will at some 

point fail and release the sediment that is burdened by radioactive particulates. Downstream 

impacts on water quality, use, and impacts on mortality and morbidity must be a part of a proper 

EIS. The Squaw Creek Reservoir dam should also be analyzed for structural integrity. 

Protracted drought, seismic activity, or other natural events have the potential to weaken the 

dam and if a failure of the structure occurs radioactive sediment could be carried downstream 

with significant potential for environmental and public health impacts. (0022-15 [Hadden, 

Karen]) 

Comment: Because the Comanche Peak nuclear plants discharge radioactive effluent into the 

Squaw Creek Reservoir that drains into the Brazos River and Paluxy River, the EIS should 

quantify the mortality and morbidity impacts, potential cancer and birth defect increases and 

genetic damage from exposure to radioactive water by municipal and other users. This analysis 

should include consideration of the public health and environmental consequences of a failure 
Appendix D 

May 2011 D-53 NUREG-1943 

of the Squaw Creek dam and the transport downstream of radioactive particulates in the 

reservoir's sediment. (0022-35 [Hadden, Karen]) 

Response: The NRC will evaluate the human health impacts of exposure to radiological 

effluents from the existing and proposed Comanche Peak units in Section 5.9 of the EIS. This 

evaluation will include exposure to radionuclides expected to be deposited in the sediments of 

Squaw Creek Reservoir during routine operation. The other dose pathway scenarios postulated 

by the commenters are very unlikely and will not be addressed in the EIS. 

D.2.17 Comments Concerning Accidents - Design Basis 

Comment: I would like to request an explanation of how it is safe to build and operate new 

nuclear reactors prior to the implementation of the same post 9-11 security hardening 

requirements that existing nuclear reactors have that has not been done. Without this in place, 

there are risks to the environment that are increased. This should be analyzed in the 

Environmental Impact Statement. If they can do this at existing reactors, why not new ones? 

(0017-26 [Hadden, Karen]) 

Response: Comments related to security and terrorism are safety issues that are not within the 

scope of the staff's environmental review. The NRC is devoting substantial time and attention to 

terrorism-related matters, including coordination with the Department of Homeland Security. As 

part of its mission to protect public health and safety and the common defense and security 

pursuant to the Atomic Energy Act, the NRC staff is conducting vulnerability assessments for 

the domestic utilization of radioactive material. Since the events of September 2001, the NRC 

has identified the need for license holders to implement compensatory measures and has 

issued several orders to license holders imposing enhanced security requirements. Finally, the 

NRC has taken actions to ensure that applicants and license holders maintain vigilance and a 

high degree of security awareness. Consequently, the NRC will continue to consider measures 

to prevent and mitigate the consequences of acts of terrorism in fulfilling its safety 

mission. Additional information about the NRC staff's actions regarding physical security since 

September 11, 2001, can be found on the NRC's public web site http://www.nrc.gov. 

Comment: Luminant is adding two reactors on top of two existing reactors and the cumulative 

impacts of all four units must be addressed ... . In addition, the impacts of any minor or major 

accident at one unit on other units must be addressed. (0032-10 [Reed, Cyrus]) 

Response: The frequency and consequences of accident scenarios that lead to radiological 

consequences are determined through the use of probabilistic risk assessment techniques. In 

accordance with MHI, LTD., “U.S-APWR Probabilistic Risk Assessment (Level 3),” MUAP-8004-

P (R1), the estimated CDF for Comanche Peak 3 and 4 is 1.2E-06 per year per unit and the 

sum of all containment release frequencies is 1E-07 per year per unit. Therefore, the frequency 

where a severe accident could potentially impact the operating units is approximately 2E-07 per 

year. Because this frequency is below the screening criteria (1E-06 per year) for initiating 

events contained in ASME/ANS RA-S-2008, “Standard for Level 1/Large Early Release 

Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications,” Supporting 

Requirement IE-C4, its impact on the operating units would not be considered to be 

material. The impact of accident scenarios associated with the current units, Comanche Peak 1 

and 2, on the proposed units, Comanche Peak 3 and 4, is not considered to be in-scope of the 

current EIS. Cumulative impacts will be addressed in Chapter 7 of the EIS. 

Comment: The evaluation methodology utilized in the Comanche Peak environmental report 

for design basis accidents is flawed. P. 7.1-1. The postulated loss of cooling accident assumes 

that there will be a lower magnitude of radioactivity releases than a worst-case scenario 
Appendix D 

NUREG-1943 D-54 May 2011 

assumes. The EIS should approach a loss of cooling accident from the perspective that a 

complete loss of radioactive inventory will occur. A complete loss of radioactive inventory should 

be the base assumption for determining anticipated doses that may be received by the public. 

Accordingly, the EIS should not adopt the Comanche Peak environmental report evaluation 

methodology for design basis accidents and should assume a worst-case scenario that includes 

a complete release of all radiation from both Units 3 and 4. (0022-47 [Hadden, Karen]) 

Response: The staff's position is that the assessment of design basis accidents is based on 

conservative assumptions and calculations used in NRC safety evaluations as stated in Section 

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

Nuclear Power Plants.” This conservative assessment is used to establish performance 

requirements of the plant's engineered safety features. Among the conservative assumptions 

used pursuant to the Section 15 analysis is the use of adverse meteorological dispersion 

conditions (i.e., 95th percentile X/Q). As actual consequences will likely be far less severe than 

those given for the same events, design basis accidents are evaluated using more realistic 

meteorological conditions (50th percentile site-specific X/Q values). The evaluation 

methodology used in the Comanche Peak environmental report is consistent with this 

approach. In addition, existing requirements provide assurance that the probability of 

simultaneous accidents at multiple units would be substantially less (e.g., over an order of 

magnitude) than the probability of accidents involving a single unit. For example, 10 CFR Part 

50, General Design Criterion 5, "Sharing of structures, systems, and components," requires that 

structures, systems, and components important to safety not be shared unless it can be shown 

that such sharing will not significantly impair their ability to perform their safety functions, 

including, in the event of an accident in one unit, an orderly shutdown and cool down of the 

remaining units. Also, a plant- and site-specific probabilistic risk assessment (PRA) will be 

required prior to operation of any future plant pursuant to 10 CFR 50.34(f)(1)(i). This PRA will 

determine whether the risk from the as-built units will be low and will account for any inter-unit 

dependencies. In contrast, the consequences associated with an accident involving multiple 

units (e.g., a multi-unit core-melt accident) could reasonably be expected to be only marginally 

greater than for a single unit event. For example, given the same accident release 

characteristics for both units, the total releases from two reactor cores (and the associated 

accident consequences) would, as a first-order-of-magnitude approximation, be about twice that 

for a single unit. The substantially lower frequency of a multiple unit accident would more than 

offset the potentially greater consequences of the multiple unit accident. Thus, the risk 

associated with multiple, simultaneous accidents would be a negligible contributor to the overall 

risk from all units on the site. Accordingly, the staff does not plan to address multi-unit 

accidents as part of the EIS review. 

Comment: Each nuclear reactor design has unique flaws and weaknesses, and experience 

shows equipment and design failures, as well as areas and situations where human error is 

likely. The history of similar Pressurized Reactor Water (PWR) reactors in Japan should be 

considered in the EIS analysis, not just the Design Control Document. 

The proposed USAPWR reactor design has never been approved and the design has never 

been built anywhere in the world, but has been developed from the design used in existing PWR 

reactors in Japan. Problems with existing PWR reactors there could provide clues to potential 

problems with Comanche Peak Units 3 and 4, allowing estimation of the likelihood that they 

could result in any number of environmental and health impacts. Design history should be 

considered in the EIS. (0022-54 [Hadden, Karen]) 

Comment: The proposed Mitsubishi reactors are of a design as yet untested in the field. This is 

not reassuring. (0031-6 [Gentling, Suzanne]) 
Appendix D 

May 2011 D-55 NUREG-1943 

Response: The EIS will address the potential environmental impacts of postulated designbasis and severe accidents associated with the US-APWR design (the designation used for the 

design of the proposed Mitsubishi reactors). In a separate action, the staff is evaluating the 

potential consequences of design-basis accidents and the probability and consequences of 

severe accidents for the US-APWR as part of its review of the application for certification of the 

reactor design. A detailed description of the design certification review is beyond the scope of 

the EIS. However, the staff uses well-established methods to analyze a new design to 

determine the potential consequences of accidents. The results of the certification review 

process will be compared to the results of the evaluation of the environmental impacts of 

potential radiological releases to ensure consistency. 

Comment: The EIS should discuss monitoring of radiation, prevention of releases, and 

emergency planning procedures in case of an unintended release. (0027-4 [Osowski Morgan, 

Sharon L.]) 

Response: Radiation monitoring for the existing and proposed Comanche Peak units will be 

addressed in Section 5.9 of the EIS. Those radiation releases associated with normal operation 

will be addressed in Section 5.9, and those releases associated with postulated accidents will 

be addressed in Section 5.10. Section 5.10 also addresses the identification and evaluation of 

severe accident design and procedural or training mitigation alternatives that can be justified to 

further reduce the likelihood or consequences of severe accidents. However, emergency 

planning is outside the scope of the EIS and will not be considered further in the staff's 

environmental review. An evaluation of emergency planning issues will be part of the safety 

evaluation report (see 10 CFR 52.18). 

D.2.18 Comments Concerning Accidents - Severe 

Comment: There is a whole issue of accident and securIty. Back in 1980, the NRC conducted 

a study, and they concluded at that time that early deaths—and that's a nice catchword for 

people that die immediately as opposed to long-term, protracted, strung-out deaths— they 

estimated early deaths of 1,210 within the first 25-mile radius. They estimated early injuries 

within a 35-mile radius of 13,800. 

They estimated financial consequences—you know, we always talk in the legislative process 

about the unplanned consequences or the unintended consequences—well, the financial 

consequences could be in excess of $117 billion. 

Well, you know, it doesn't take a brilliant person to figure out that almost 30 years later—it'll be 

35 or 40 years later—once this thing, if it's built, is operational, that those early deaths will be far 

more than that. In part because of the rapid population growth in Hood and Somervell Counties, 

those early injuries will be far more than that. And those financial consequences to the entire 

North Texas region will be far more than what you projected back in 1980. So I look for and 

anticipate an honest and accurate analysis of those problems. 

(0016-41 [Burnam, Lon]) 

Response: The EIS will include an evaluation of the risks associated with potential severe 

accidents, including accidents that involve reactor core melts. The EIS will address the potential 

consequences of postulated design-basis and severe accidents and will take into account the 

current and anticipated population growth of the surrounding counties during the projected 

operational period of these plants. However, comments related to security and terrorism are 

safety issues that are not within the scope of the NRC staff's environmental review and are 

regulated by 10 CFR Part 73, “Physical Protection of Nuclear Power and Materials.” 
Appendix D 

NUREG-1943 D-56 May 2011 

Comment: The risk of a nuclear accident and the magnitude of devastation would increase 

with more reactors on the site. 

... In 1980 the NRC conducted a study of what would happen under a worst-case scenario 

accident at each nuclear plant site. The Comanche Peak estimates were: 

 1210 early deaths (25 mile radius around plant) 

 13,800 early injuries (35 mile radius) 

 $117 billion (1980 dollars) in financial consequences 

The Environmental Impact Statement should include a similar study to update these risk figures, 

since the population of the region has grown and since there would be more reactors. (0019-11

[Hadden, Karen]) 

Response: The EIS will include an evaluation of the risks associated with potential severe 

accidents, including accidents that involve reactor core melts. The EIS will address the potential 

consequences of postulated design-basis and severe accidents, and will take into account the 

current and anticipated population growth of the surrounding counties during the projected 

operational period of these plants. 

Comment: Additionally, cumulative impacts from accident scenarios should also be 

considered. For example, the EIS should consider whether a radiological accident, at one plant 

could interfere/interrupt operations at the remaining plants at the Comanche Peak site. Further, 

there should be a careful consideration of whether an accident or event at one plant could 

actually preclude operations at the remaining plants. This is relevant because of the close 

proximity of the planned Units 3 and 4 to the existing Units 1 and 2. (0022-28 [Hadden, Karen]) 

Comment: Luminant is adding two reactors on top of two existing reactors and the cumulative 

impacts of all four units must be addressed ... . In addition, the impacts of any minor or major

accident at one unit on other units must be addressed. (0032-11 [Reed, Cyrus]) 

Response: The frequency and consequences of accident scenarios that lead to radiological 

consequences are determined through the use of probabilistic risk assessment techniques. In 

accordance with MHI, LTD., “U.S-APWR Probabilistic Risk Assessment (Level 3),” MUAP-8004-

P (R1), the estimated CDF for Comanche Peak 3 and 4 is 1.2E-06 per year per unit and the 

sum of all containment release frequencies is 1E-07 per year per unit. Therefore, the frequency 

where a severe accident could potentially impact the operating units is approximately 2E-07 per 

year. Because this frequency is below the screening criteria (1E-06 per year) for initiating 

events contained in ASME/ANS RA-S-2008, “Standard for Level 1/Large Early Release 

Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications,” Supporting 

Requirement IE-C4, its impact on the operating units would not be considered to be 

material. The impact of accident scenarios associated with the current units, Comanche Peak 1 

and 2, on the proposed units, Comanche Peak 3 and 4, is not considered to be in-scope of the 

current EIS. Cumulative impacts will be addressed in Chapter 7 of the EIS. 

Comment: The Comanche Peak emergency evacuation plan assumes that 100% of the 

affected population from a radiological emergency would be evacuated. p. 7.2-3. The model is 

further compromised because it does not adequately account for evacuees that are transported 

25 miles from the Comanche Peak site as they "disappear" from the emergency evacuation 

analysis. Id. Accordingly, the results of the dose and dollar risk assessments for severe accident 

analysis are understated in the Comanche Peak environmental report Table 7.2-5. The EIS 

should not assume that 100% of the affected population will be evacuated. Rejecting this 

assumption requires that the data in Table 7.2-5 be adjusted to account for increased dose risk, 
Appendix D 

May 2011 D-57 NUREG-1943 

dollar risk, early fatalities, latent fatalities, and water ingestion dose risk. Moreover, there should 

be an accounting for evacuees and the doses to which they have been exposed even if those 

evacuees are moved 25 miles beyond the Comanche Peak site. (0022-45 [Hadden, Karen]) 

Response: This comment addresses two evacuation model issues that appear to be within the 

scope of the environmental review: (1) the percentage of population assumed to be evacuated 

and (2) the treatment of the evacuated population once they are transported over 25 miles. The 

removal of the evacuated population once they exceed a fixed distance is a standard analysis 

approach. The distance that is selected (i.e., 25 miles) is a user input. Shorter distances have 

been used in other analyses. Although a sensitivity analysis has not been performed, it is 

believed that the any additional dose that would be received by this evacuated population would 

not be material. 

Comment: And that, because of this, the other factor is that part of that energy bill said that if 

there is some kind of a dangerous, let's say, explosion or something happens that ruins the area 

around here, who is going to pay for it? We are. Because they put some things into the energy 

bill that does not require the company to be 100 percent responsible for the cleanup for it. It will 

be the taxpayers. And the people in Congress have been lowering the standards for that. So it 

all falls back on us. (0017-51 [Harper, Debbie]) 

Response: The NRC is not involved in establishing energy policy; rather, it regulates nuclear 

energy to protect public health and safety within existing policy. These comments provide no 

new information and were not considered further. This comment provides no information 

related to the scope of this EIS and will therefore not be considered further in the staff's 

environmental review. 

D.2.19 Comments Concerning the Uranium Fuel Cycle 

Comment: There are so many ways to build the local economy more effectively and not put 

anyone at risk from radioactive fuel, from handling it, from trying to store it. Right now it's being 

stored on site, and it appears that that would be the continuing manner in which the radioactive 

waste is handled, because we don't have a national repository. That's of huge concern. 

(0016-16 [Hadden, Karen]) 

Comment: I want this assessment to include an evaluation of what we do with the radioactive 

waste. It's still on site. You all know when this facility started operating in the early '90s, it's still 

on site. It doesn't seem like we're any closer than we were in that time frame to get a permanent 

waste repository. What are we going to do with this radioactive waste and material? (0016-40

[Burnam, Lon]) 

Comment: I'd also like to make it clear that while people in Somervell and Granbury may feel 

like it's been relatively clean and unharmful to them, they don't live where the uranium is mined. 

And I guarantee you, if you talk to the tribal leaders in New Mexico, you'll find out that it is not a 

clean process. And the cancer rates on the tribal lands where this uranium is taken from have 

gone up exponentially as a result of the mining. So from the beginning of the process to the end 

of the process, we've yet to have an honest analysis of the environmental impact on health and 

safety. (0016-44 [Burnam, Lon]) 

Comment: And finally, I hope you're going to look at the whole cycle. While we're talking about 

a license for a particular plant to basically boil water, it involves a whole cycle of uranium. And 'I 

would hope that your assessment will look at that whole cycle, where the uranium will come 

from and where the results of using the uranium will go, as part of your assessment. And so I 

would urge you to do that. (0016-55 [Reed, Cyrus]) 
Appendix D 

NUREG-1943 D-58 May 2011 

Comment: For many years I've been concerned about nuclear power and the problem that we 

seem to ignore, what to do with the waste. I think we really need to look at that very, very 

carefully. (0016-60 [Wildwood, Kathleen]) 

Comment: But there is no mention of the waste, the radioactive waste, which is a problem. I 

don't think anyone can deny that. (0017-36 [Cohn, Ann]) 

Comment: So radioactive low level and high level waste is spewed out as it is being mined. It 

is at risk when it is being transported, if there is a wreck. There is risk in the actual production of 

the energy. And then there is a risk as it is put into the waste areas. The full chain is risky. 

(0017-70 [Sanders, Jan]) 

Comment: One is the waste. We know the fact that we are drowning worldwide under nuclear 

waste. We do not have a safe means of having them stored. Of course, everyone will mention 

Yucca Mountain. Yucca Mountain is still a no-go. There have been reports of more 

problems with Yucca Mountain of leakage. It is not a safe place. We don't have something else 

to take its place. And this stuff is toxic for thousands of years. (0017-75 [Stuard, Gary]) 

Comment: In the last ten years, the Texas Department of Health Services has cited several 

instances of radioactive waste spills by uranium mining companies, including Cogema Inc.'s 

1998 spill of over 20,000 gallons of radioactive solution in Bruni, Texas. (0019-26 [Hadden, 

Karen]) 

Comment: The uranium fuel cycle has substantial greenhouse gas impacts that should be 

considered at each phase of the fuel cycle. 

The uranium fuel cycle is a contributor to greenhouse gases. The EIS should carefully consider 

and include in its analysis the greenhouse gas impacts that are unavoidable as a result of 

mining, processing, fabrication, transportation fuel burn up, waste streams management, 

decommissioning and long-term site maintenance that are an integral part of the uranium fuel 

cycle. While the proponents of an expanded Comanche Peak nuclear plant posit that there will 

be fewer greenhouse gases produced as a result of the operations of Comanche Peak Units 3 

and 4 compared to fossil fueled plants, there are inevitable greenhouse gas emissions 

associated with each phase of the fuel cycle. These conditions need to be carefully considered 

to determine the full impact of an expanded Comanche Peak nuclear plant. 

The decision in Massachusetts V. EPA, 549 U.S.497 (2007) requires that carbon dioxide be 

considered a pollutant. Carbon dioxide emissions are inevitable in the production of fuel for 

nuclear plants. Likewise, carbon dioxide emissions can be anticipated during routine operations 

of a nuclear plant and are foreseeable as a plant is decommissioned. Any benefits derived by 

operation of a nuclear plant in terms of avoidance of greenhouse gases needs to be considered 

in light of greenhouse gas production as it occurs in various stages in the fuel cycle. An 

adequate EIS should require such an analysis. (0022-3 [Hadden, Karen]) 

Comment: Each part of the uranium fuel cycle has substantial radiological, environmental and 

public health impacts that are cumulative in nature and should be considered in the context of 

an EIS. 

Each phase of the uranium fuel cycle has radiological, environmental and public health impacts 

that must be analyzed and quantified in the context of an EIS. For example, mining uranium is 

known to cause an increase in radiation related illnesses among miners. Mortality and morbidity 

analyses should be done for uranium mining and associated activities related to supplying fuel 

to Comanche Peak Units 3 and 4. (0022-4 [Hadden, Karen]) 
Appendix D 

May 2011 D-59 NUREG-1943 

Comment: radioactive waste would be stored onsite since there is still no national nuclear 

waste repository. (0030-6 [Hadden, Karen]) 

Response: Impacts related to the uranium fuel cycle and its transportation steps, including 

disposal of low-level radioactive waste and spent fuel, will be addressed in Chapter 6 of the 

EIS. The generic impacts of the fuel cycle are codified in 10 CFR 51.51(b), Table S-3, "Table of 

Uranium Fuel Cycle Environmental Data." Per the guidance in 10 CFR 51.51 and Section 5.7 of 

NUREG-1555, the staff will rely on Table S-3 as a basis for uranium fuel cycle impacts. The 

safety and environmental effects of long-term storage of spent fuel on site have been evaluated 

by the NRC and set forth in the Waste Confidence Rule at 10 CFR 51.23 

(http://www.nrc.gov/reading-rm/doc-collections/cfr/part051/part051-0023.html). 

Comment: Based on the assumption that Comanche Peak Units 3 and 4 will utilize MOX fuel, 

careful analyses of the radiological and public health impacts associated with MOX fuel 

fabrication should be a part of the EIS. 

MOX fuel fabrication has remote handling requirements not associated with uranium fabrication 

facilities. MOX fuel includes plutonium, a strong alpha emitter, that has a higher specific 

radioactivity than uranium. The plutonium, if inhaled, presents a well-recognized health hazard. 

A MOX fuel fabrication facility, while subject to more stringent requirements than a uranium fuel 

fabrication facility, still involves handling increased amounts of plutonium. The environmental 

and public health impacts associated with increased use and handling of plutonium should be a 

part of a proper EIS. CP Environmental Report, page 5.7-4. The EIS should include 

environmental impacts associated with routine operations of a MOX fuel fabrication facility as 

well as accident scenarios that could involve such a facility. (0022-25 [Hadden, Karen]) 

Comment: Our understanding is that in addition to uranium, the Comanche Peak facility will 

utilize MOX fuel fabrication, which in itself will lead to other environmental and public health 

challenges which must be addressed by an EIS. (0032-4 [Reed, Cyrus]) 

Response: The COL submitted by Luminant for CPNP Units 3 & 4 is for reactors fueled with 

uranium oxide only. Any future use of MOX fuel would be covered in separate license 

amendment process. For this reason the environmental effects of MOX fuel will not be covered 

in the EIS. 

Comment: The Comanche Peak environmental report recognizes that there has been an 

overall reduction of the demand for uranium fuel and the elimination of legal restrictions on 

importation of foreign uranium which has caused the closing and decommissioning of most 

domestic uranium mines and mills. The economic conditions pertaining to the uranium market 

favor utilization of foreign uranium rather than uranium mined in the United States. The 

Comanche Peak environmental report suggests that these changes have made uranium mining 

and milling and enrichment more "environmentally friendly". p. 5.7-4. However, there is no 

analysis in the environmental report of environmental or public health impacts of mining and 

milling uranium in foreign countries. The EIS should include a full analysis of the impacts of 

mining and milling uranium in foreign countries. 

(0022-31 [Hadden, Karen]) 

Response: The NRC environmental review process only covers environmental effects in the 

United States. The comment above requests the review of mining operations outside the 

US. Since such review is outside the legal scope of this NRC licensing process, such effects 

will not be covered in the EIS. 

Comment: Nuclear waste is not our solution to energy independence. It has health impacts. 

(0016-24 [Hadden, Karen]) 
Appendix D 

NUREG-1943 D-60 May 2011 

Comment: One other concern I will just touch on is, that the contamination from the uranium, 

what would happen in building more nuclear reactors, is there would have to be more uranium 

brought in, of course. And it might be something that the local community isn't thinking as much 

about. But there are other local communities even in Texas that are very concerned about that. 

(0017-45 [Rooke, Molly]) 

Comment: And that is the radioactive waste that is stored here in Somervell County. We take 

our garbage to the local dump. Or if you live in the city, you have it picked up, because the city 

provides that service. And then it is transported off to somewhere else. Yet we keep our 

radioactive waste here. 

Yucca Mountain is not open. And we want to expand the amount of radioactive waste we are 

actually going to store here in this county, by opening these new plants. I don't think it is such a 

wise move to keep increasing the size of the radioactive waste, without figuring out what to do 

with it first. (0017-48 [Harper, Paul]) 

Comment: No high or low-level waste sites are available. 

 Nuclear reactors produce tons of high and low-level radioactive waste that remains 

dangerous to living beings for tens of thousands of years. Radioactive and toxic waste is 

produced at every stage of the fuel cycle, including routine plant operations. 

 Federal law prohibits the licensing of any new nuclear plant until there is an adequate waste 

disposal plan. Nuclear plants have been operating for 50 years, but the waste disposal 

problem has not been solved. Radioactive waste remains stored onsite at reactors across 

the county. 

 There is no national storage facility for high-level radioactive waste and the Yucca Mountain 

repository is unlikely to open in the near future. The Associated Press wrote: "The Energy 

Department is cutting operations and the chief contractor is laying off its staff at the desert 

site where the government plans to build a national nuclear waste repository..." Jan 8, 2008. 

 The Andrews County low-level waste dump application has been deemed incomplete by the 

Texas Commission on Environmental Quality. 

 The impacts and risks of storing additional high -level radioactive waste on site needs to be 

studied thoroughly in the EIS. The long-term cumulative health impacts of additional lowlevel radiation need to be studied thoroughly and included in the environmental impact study 

as well. Impacts on humans, wildlife and plant life need to be considered, with special 

attention given to threatened and endangered species. 

 The EIS should study the additional safety and security risks of more radioactive waste. 

 The license for two new reactors at Comanche Peak, or any other reactor, should not be 

issued since there is no effective resolution of the storage issue. 

(0019-30 [Hadden, Karen]) 

Comment: There is a resurgence of uranium mining in South Texas at this time, with nineteen 

exploration permits being pursued. Impacts on communities in Texas including drinking water 

contamination which should be researched and examined thoroughly in the EIS. New mining 

operations are being pursued even though aquifers contaminated by earlier mining operations 

have not been restored and some residents in Texas still cannot drink their water due to 

contamination. Adding two more reactors at Comanche Peak would likely impact the amount of 

mining in South Texas and environmental and health impacts in those communities should be 

analyzed and considered thoroughly in the EIS. (0022-34 [Hadden, Karen]) 
Appendix D 

May 2011 D-61 NUREG-1943 

Comment: The Comanche Peak environmental report assumes that so-called low-level 

radioactive waste will be disposed of at land burial facilities. Based on this assumption, the 

environmental report assumes that there will be no significant radioactive releases to the 

environment. p. 5.7-8.This assumption is dubious at best considering that low-level radioactive 

waste streams contain very long-lived radionuclides that would not be adequately sequestered 

in land burial facilities for the duration of their hazardous lives. 

Moreover, the availability of land burial sites is problematic. Attempts to establish new land 

burial sites for the so-called low-level radioactive waste stream have largely been unsuccessful. 

The sites that were planned for Nebraska, California and Texas have been rejected in the past 

and the TCEQ decision to issue a state permit for a site in West Texas is likely to be appealed, 

so it should be assumed in the EIS that there will be no off-site capacity to dispose of the socalled low-level radioactive waste stream. The EIS should consider the long-term environmental 

and public health consequences of managing the so-called low-level radioactive waste stream 

on the Comanche Peak site. The analysis of this issue should include an analysis of radiation 

exposures to employees and the public based on the assumption that the low-level radioactive 

waste stream will not be disposed of off-site. (0022-43 [Hadden, Karen]) 

Comment: The Comanche Peak environmental report assumes that there will be no significant 

radioactive releases to the environment related to off-site disposal of the radioactive waste 

streams that originate at Units 3 and 4. p. 5.7-8. The EIS should not adopt this assumption. The 

EIS should fully consider the public health and environment consequences of major releases to 

the environment of radioactive materials as a result of off-site disposal activities. The off-site 

releases could originate from on-site processing, transportation accidents, off-site processing, 

and long-term releases from the disposal site because of either improper or inadequate waste 

site characterization, natural events such as earthquakes, and intentional or unintentional 

releases. Irrespective of the cause of the releases such should be considered for the impacts to 

the environment and public health consequences. (0022-44 [Hadden, Karen]) 

Comment: The only existing solution to the toxic waste issue is to bury it somewhere. I've read 

that West Texas is currently being identified as a depository. Storage and transportation of 

these wastes is simply a disaster waiting to happen and is an irresponsible choice for our 

environment and for future generations. (0031-5 [Gentling, Suzanne]) 

Comment: The EIS must address the complete uranium cycle from cradle to grave and the 

impacts of that cycle. Where will the plant obtain its raw uranium for the life of the plant? Where 

will it be processed? Enriched? Deconverted? What are the impacts of the mining, processing 

and enrichment processes in their place of origin? 

What happens to the waste streams along the way during that process, including at the end of 

the uranium cycle. Each part of the uranium fuel cycle has environmental, radiological and 

public health impacts that must be addressed. (0032-3 [Reed, Cyrus]) 

Response: The impact of the uranium fuel cycle and its transportation steps, including disposal 

of low-level radioactive waste and spent fuel, will be addressed in Chapter 6 of the EIS. The 

generic impacts of the fuel cycle are codified in 10 CFR 51.51(b), Table S-3, "Table of Uranium 

Fuel Cycle Environmental Data." Per the regulation in 10 CFR 51.51 and guidance in Section 

5.7 of NUREG-1555, the staff will rely on Table S-3 as a basis for uranium fuel cycle 

impacts. The safety and environmental effects of long-term storage of spent fuel on site has 

been evaluated by the NRC and, as set forth in the Waste Confidence Rule at 10 CFR 51.23 

(available at http://www.nrc.gov/reading-rm/doc-collections/cfr/part051/part051-0023.html), the 

NRC generically determined that "if necessary, spent fuel generated in any reactor can be 

stored safely and without significant environmental impacts for at least 30 years beyond the 
Appendix D 

NUREG-1943 D-62 May 2011 

licensed life for operation (which may include the term of a revised or renewed license) of that 

reactor at its spent fuel storage basin or at either onsite of offsite independent spent fuel 

installations. Note that the waste confidence decision is being updated through rulemaking and 

references to the timing of repository availability is being omitted in the updated version. It is 

outside the scope of this EIS to address specific low-level waste burial locations, existing or 

proposed. Site specific data for these locations is developed as part of the NRC licensing 

process under 10 CFR 61. 

Comment: Are we willing to bank on the fact that governments will still be in place thousands 

of years from now? How many have lasted thousands of years? Are we willing to put our 

children's children's children at risk because we couldn't figure out a smarter way to use our 

energy and to generate it? And those smarter ways exist right now, and they create jobs, and 

they're better for our economy. (0016-18 [Hadden, Karen]) 

Response: Chapter 6 of the EIS will address the impacts of the fuel cycle, including radioactive 

wastes. 

Comment: I'm also interested in sustainability, and uranium is not a sustainable product. 

(0016-75 [Shaar, Julie]) 

Comment: Dependence on foreign sources for uranium should also be considered in the EIS 

as a potentially harmful environmental and public health consequence. Recent experience with 

dependence on foreign sources for oil has heightened awareness that supplies may be 

interrupted or artificially inflated in costs. The economic impacts from such dependence can be 

far ranging and adverse. Accordingly, such impacts should be considered in a proper EIS. 

(0022-32 [Hadden, Karen]) 

Response: The sufficiency of the supply of uranium for nuclear power plant fuel will be 

addressed in Chapter 6 of the EIS. 

Comment: Nuclear, the mining associated with nuclear power, the uranium mining is incredibly 

destructive. And it is killing people, literally killing. people. (0017-63 [Rittenhouse, Ryan]) 

Comment: And waste [of] waste. (0017-67 [Sanders, Jan]) 

Comment: It was pointed out that in Texas, we are kind of in the zero target in relation to 

nuclear, because there are a lot of uranium deposits in Texas. (0017-68 [Sanders, Jan]) 

Response: The impacts related to the uranium fuel cycle will be addressed in Chapter 6 of the 

EIS. The generic impacts of the fuel cycle are codified in 10 CFR 51.51(b), Table S-3, "Table of 

Uranium Fuel Cycle Environmental Data." Per the guidance in 10 CFR 51.51 and Section 5.7 of 

NUREG-1555, the staff will rely on Table S-3 as a basis for uranium fuel-cycle impacts. 

D.2.20 Comments Concerning Transportation 

Comment: The effect of the increased truck traffic, noise and pollution levels from a 

construction project of this size on an infrastructure that is already pushed to the limit would not 

be desirable to humans or wildlife. (0031-7 [Gentling, Suzanne]) 

Response: Impacts of plant construction and operation on the use of existing local 

infrastructure including transportation networks, noise and pollution levels, and other community 

services or the need for such new infrastructure will be addressed in Chapters 4 and 5 of the 

EIS. 
Appendix D 

May 2011 D-63 NUREG-1943 

D.2.21 Comments Concerning Decommissioning 

Comment: The reality is the two now are halfway through their life cycle. They'll be closed 

down. They'll be moth-balled. And in the 50 years of the operation of nuclear power plants, we 

still have not resolved that issue. So any real, accurate environmental impact statement will 

have a very careful analysis of the implication of storing this material on site forever. (0016-38

[Burnam, Lon]) 

Comment: Additionally, given the very long-term nature of the radiological hazard represented 

by the accumulation of radioactive particulates discharged during plant operations, it should be 

assumed that the reservoir will require, at the minimum, management and perimeter security for 

a time that extends far beyond the term of operation license. Questions surrounding postlicense ownership of and responsibility for Squaw Creek Reservoir should be addressed and 

resolved in the EIS. Accordingly, the EIS should fully consider the structural reliability of the 

Squaw Creek Reservoir dam and analyze adverse environmental and public health 

consequences that could occur as a result of its failure. (0022-16 [Hadden, Karen]) 

Comment: The Comanche Peak environmental report acknowledges that it does not provide 

anything more than an initial projection of expected future environmental impacts related to 

decommissioning. The details related to environmental impacts expected from decommissioning 

are put off to a future unspecified date. The Comanche Peak environmental report assumes 

impacts related to decommissioning are either negligible or require, at most, a site-specific 

assessment. However, the environmental report assumes that site-specific and off-site land use 

activities and aquatic ecology activities beyond the operational area, terrestrial ecology activities 

beyond the operational area, threatened and endangered species, environmental justice, and 

cultural historic resource impacts beyond the operational area are expected to be negligible. 

However, there is no analysis in the environmental report whatsoever of any of these impacts 

either from a public health or environmental consequence standpoint. p. 5.9-1. Accordingly, a 

proper EIS should carefully consider decommissioning impacts including the likelihood that a 

decommissioned plant will be disassembled and transported to a site that will be the recipient of 

highly irradiated materials. Additionally, the EIS should consider contingent possibilities that offsite removal of a decommissioned nuclear plant will not be a practicable alternative. In that 

scenario, the environmental consequences and public health impacts of the in situ, long-term 

radioactive decay of Comanche Peak Units 3 and 4 should be considered in the EIS. 

Decommissioning has its own waste stream issues, as well. The EIS should consider the 

radiological and public health impacts from the various decommissioning waste streams and 

environmental justice and other implications of disposition of highly irradiated materials off-site. 

Additionally, the EIS should consider whether off-site disposition of decommissioning materials 

is even feasible. The decommissioning of nuclear plants is an evolving technology, and the land 

use, environmental and public health implications of decommissioning activities are not well 

understood. The EIS should fully analyze the probability that there will be significant resistance 

to transportation and disposition of highly irradiated decommissioned plant materials to a remote 

site. 

Moreover, in promotional materials published by the reactor manufacture Mitsubishi, it is 

acknowledged that technology for decommissioning is still in the process of being developed. 

Mitsubishi Nuclear Plants, p. 27. Hence, there is currently inadequate technology to carry out 

decommissioning. The assumption appears to be that adequate technologies will be developed 

in the future. However, a proper EIS should consider the scenario that adequate technologies 

for decommissioning are not developed in the future or proved to be inadequate for the task. 

The EIS should take into account contingencies that would require long-term secure storage of 
Appendix D 

NUREG-1943 D-64 May 2011 

Comanche Peak Units 3 and 4 because either decommissioning technology is inadequate [or] 

where there is no remote site available for the disposition of wastes from decommissioning 

activities. This analysis would require a consideration of radiological impacts related to the longterm delay in decommissioning, as well as public health and environmental consequences 

related thereto. (0022-39 [Hadden, Karen]) 

Comment: These enormous, single-purpose facilities have a limited life and store on site their 

partially-spent fuel. What provisions will be made for de-commissioning, with removal of all 

structures and hazardous materials, together with restoration of the site? (0028-3 [Inge, Charles 

and Dominique]) 

Comment: The EIS should examine both the Texas and federal decommissioning procedures, 

as well as the funds set up to pay for decommissioning to assure that adequate monies exist to 

pay for any clean up and decommissioning and the public is not, as it has on multiple occasions, 

held responsible for these costs. How a merchant plant selling power on the wholesale market 

will be paid for is of serious concern. (0032-18 [Reed, Cyrus]) 

Response: NRC regulations establish a framework to ensure that decommissioning of all 

nuclear reactor facilities will be accomplished in a safe and timely manner and that funding will 

be available for this purpose. Federal regulations (10 CFR 50.33(k) and 10 CFR 50.75(b)) 

require an applicant for a COL license to certify that sufficient funds will be available to ensure 

radiological decommissioning at the end of power operations. The financial decommissioning 

funding assurance mechanism analysis will be in the SER not the EIS. The environmental 

impact from decommissioning a permanently shutdown commercial nuclear power reactor is 

discussed in Supplement 1 to NUREG-0586, Generic Environmental Impact Statement on 

Decommissioning of Nuclear Facilities, which was published in 2002. If fuel is maintained 

onsite in an Independent Spent Fuel Storage Installation (ISFSI), a license for the ISFSI will be 

maintained and any required security and monitoring would be provided by the ISFSI 

licensee. Evaluation of such a facility is not within the scope of this EIS. The Squaw Creek 

Reservoir is an existing site feature constructed for Comanche Peak 1 and 2. The evaluation of 

the impacts and maintenance of the Squaw Creek Reservoir dam is not within the scope of this 

EIS. 

Comment: Additionally, given the very long-term nature of the radiological hazard represented 

by the accumulation of radioactive particulates discharged during plant operations, it should be 

assumed that the reservoir will require, at the minimum, management and perimeter security for 

a time that extends far beyond the term of operation license. Questions surrounding postlicense ownership of and responsibility for Squaw Creek Reservoir should be addressed and 

resolved in the EIS. (0022-17 [Hadden, Karen]) 

Response: The NRC regulations require the decommissioning of all nuclear power 

facilities. The licensee remains responsible for the site until the entire site is surveyed and 

released for unrestricted use. 

D.2.23 Comments Concerning Cumulative Impacts 

Comment: The simple fact that you'll have twice as many reactors, the large visible target of 

the cooling towers, twice as much transportation issues, both for bringing the radioactive 

material in and dealing with it, if you ever choose to deal with it, off site, taking it off site. All of 

those are kind of geometrically increased problems over the two. (0016-37 [Burnam, Lon]) 
Appendix D 

May 2011 D-65 NUREG-1943 

Comment: But this is one thing that needs to be looked into. There's just something wrong. 

And if you add another power plant or two, to me, that would increase the flow of the—it would 

also increase the temperature of the water. 

The water, I understand, it has—can't reach a certain temperature. But when they release that 

water, it's too hot. You need to release the water some way where it's not as hot, or find some 

cooling system after you release that water. I think it would help the situation. (0016-65 [Cathey, 

Jack]) 

Comment: Adding two 1600 MW reactors to a site that has already been impacted by 

continued operation of Comanche Peak Units 1 and 2 will result in unprecedented 

concentrations of reactor operations. The cumulative impacts of operational releases of 

radiation from four operating reactors should be a part of a proper EIS. (0022-27 [Hadden, 

Karen]) 

Comment: The NEPA document should estimate cumulative impacts of resources of concern 

associated with the proposed project. Cumulative impacts include the additive effects of a given 

parameter for all contributing projects in the study area and watershed. The document should 

define what cumulative impacts would result from implementation of the proposed project. 

Existing or future projects (Federal and non-Federal projects) with attendant pollutants should 

also be considered. (0027-25 [Osowski Morgan, Sharon L.]) 

Comment: Luminant is adding two reactors on top of two existing reactors and the cumulative 

impacts of all four units must be addressed in terms of water discharges, air borne radioactivity, 

and radioactive waste. (0032-9 [Reed, Cyrus]) 

Response: Cumulative impacts are the impacts that result from the combination of the 

proposed action and past, present and reasonably foreseeable actions, regardless who takes 

the actions. The cumulative impacts associated with the construction and operation of the 

proposed Units 3 and 4 will be evaluated for each affected resource. The results of cumulative 

impact analyses will be presented in the Chapter 7 of the EIS. 

Comment: One last thing that I will mention in relationship to this global warming stuff, is there 

is also global warming on the thermal level. You know, it is not just how much C02 we are 

putting out into the atmosphere. It is actually the active heating of our planet by burning stuff. 

And that is something that isn't talked about very much. But that is what is referred to as the 

thermal load of the facility. And a nuclear plant has about three times the thermal load of a coal 

plant. The heat it emits and the water that it heats up is three times the amount of the average 

coal plant. So that is also something to consider. 

(0017-65 [Rittenhouse, Ryan]) 

Response: Contributions of both direct heat emissions and greenhouse gases to cumulative 

effects on global climate change will be addressed in Section 7.11 of the EIS. 

Comment: There is a carbon footprint of nuclear plants. Approximately, it is estimated that 

about a million tons of C02 every year is attributed to one nuclear plant. And that is because of 

the mining process and everything else. 

Yes, there is no C02 coming -out of the water coolant towers or anything like that, but there is 

fossil fuel burning that goes on in relationship to nuclear power generation. And it does have a 

carbon footprint. 

Also, you are probably well aware that nuclear plants take a lot of concrete to build. And it is 

estimated that in every ton of concrete, there is about a ton of C02 that is released in 
Appendix D 

NUREG-1943 D-66 May 2011 

manufacturing that concrete. So this all adds up. And it estimated that it accounts, the amount of 

C02 is about the same as about a fifth to a third of a gas plant. So yes, it is less. But there are 

other forms—there isn't none. (0017-64 [Rittenhouse, Ryan]) 

Comment: nuclear energy is not carbon free. From the cycle, the whole nuclear cycle from 

uranium mining, ... But the whole process from mining and milling and enrichment, fuel 

fabrication, and disposal of radioactive waste do add significant greenhouse gas emissions to 

this planet. (0017-78 [Stuard, Gary]) 

Comment: The most prevalent global warming impacts come from increased heat and 

humidity in the atmosphere. At a nuclear power plant two-thirds of the heat energy gets emitted 

into the air and heated water vapor is released into the air. Thus nuclear reactors themselves 

are global warming agents in terms of heat, including water vapor from steam and heat radiating 

from cooling towers and ponds. The EIS should contain an analysis of the production of heat 

energy emitted into the atmosphere and water by Comanche Peak Units 3 and 4 in terms of 

contributions to global warming. (0022-24 [Hadden, Karen]) 

Response: The cumulative effects of heat, water vapor, and greenhouse gas emissions by 

construction and operation (including the fuel cycle) of the proposed units on global warming will 

be addressed in Section 7.11 of the EIS. 

D.2.25 Comments Concerning the Need for Power 

Comment: The right way to meet our energy needs right now is through energy efficiency, first 

and foremost, through better building codes. And that's starting to happen throughout the state. 

Many cities are passing building codes. If we just get smarter about our energy use, we won't 

need so much. I maintain that these reactors are not necessary. (0016-13 [Hadden, Karen]) 

Comment: one thing that I hope you'll do in your assessment of their assessment is to look 

carefully at their section dealing with the need for energy and the need for this type of power. 

One thing I would say is, because of when their assessment was written, it was based upon 

numbers which we already think aren't legitimate. Those numbers are based on ERCOT 

projections of 2007. Already the ERCOT projections about power needs in Texas of May of 

2008 have a much different view on the need for additional power in the coming years. And 

that's simply in part because of changes in the growth of our economy, but also in part because 

Texas has fairly aggressively begun to implement energy-efficiency programs. 

And so our—we don't believe this plant is needed to meet our energy needs, and we think there 

are documents out there that would support that view, including ERCOT's own projections. 

And I would also point out that we have a new Speaker of the House, someone who is very 

much in favor of energy efficiency. He passed legislation last session. Part of that legislation 

was to commission a report to look at the potential for greater gains in energy efficiency so we 

can meet more of our needs through energy-efficiency programs. So I would urge you to both 

look at the Itron report—and I can—in my written comments, I can get you a reference to that, 

but also—I don't know what your time line is, but also look at the actions during this legislative 

session. We expect, with the new Speaker of the House and with substantial interest in both the 

House and the Senate on both energy efficiency and promoting other sources of energy, like 

solar, geothermal, biomass, there will be significant legislative action that will add to our power 

mix in Texas, not in terms of nuclear, but in terms of both energy efficiency and other 

renewables. 
Appendix D 

May 2011 D-67 NUREG-1943 

So I want you to look at that projection, look at some of the studies that have been done by 

Itron, by ACEEE and others for Texas, to see if their assessment is realistic in terms of what's 

needed in Texas and whether we can't meet this demand through other means, including 

means that, frankly, Luminant is looking at, like wind, and I know they're looking at the potential 

for utility-scale solar. So I'd urge you to look at that. (0016-50 [Reed, Cyrus]) 

Comment: Luminant has not proven there is a need for this new energy. 

 The application ignores the effect energy efficiency and renewable energy will have in the 

future. Are recent state-mandated energy efficiency and renewable energy goals be factored 

into the energy needs assessment? 

 Studies have shown that Dallas/Ft. Worth could meet 101% of projected growth in demand 

using efficiency and renewable energy. 

 State energy use projections should be revisited in light of the economic downturn. 

(0019-21 [Hadden, Karen]) 

Response: The EIS Chapter 8 analysis of need for power will reflect ongoing efforts to promote 

energy efficiency, conservation mandates, and updated demand forecasts by ERCOT. 

Comment: Moreover, the report [ER] largely discounts the role energy efficiency can play. 

Nonetheless, Luminant will be operating and selling power within ERCOT, where considerable 

advances in energy efficiency programs have resulted. First, the Texas Legislature through 

SB 7 in 1999 required the large transmission companies to meet 10 percent of their growth in 

demand through energy efficiency programs, a requirement that was doubled in 2007 with the 

passage of HB 3693. The program at the nine investor-owned utilities has been successful. Full 

reports of the program are available at 

http://www.texasefficiency.com/report.html 

The following table is from the 2007 report from Fronteir Associates and demonstrates the 

success of the program in reducing peak demand and saving energy for a fraction of the cost of 

the nuclear plant. 

HB 3693 also required the Public Utility Commission to look at the potential for utilities meeting 

50 percent of the growth in demand through energy efficiency programs, and the resulting study 

concluded that Texas statewide could reduce its peak energy demand by 23 percent by 2018, 

and that the 50 percent goal by 2015 was economically and technically achievable. The full 

report – by ITRON – is available through the Public Utility Commission website. 

http://www.puc.state.tx.us/rules/rulemaking/33487/33487.cmf. This legislative session, bills have 

already been introduced that would accomplish that or similar goals (HB 280, SB 601). (0032-16

[Reed, Cyrus]) 

Response: Chapter 8 of the EIS will reflect legislative mandates for energy conservation that 

apply to regulated portions of the electric power delivery system in Texas and updates to 

ERCOT forecasts that reflect the initial impacts of these mandates. 

Comment: We don't need the energy. (0017-11 [Burnam, Lon]) 

Comment: We all know that we need to produce more energy. (0017-15 [Burnam, Lon]) 

Comment: Energy efficiency can reduce electric demand, and help address global warming 

today, while building the local economy. (0030-8 [Hadden, Karen]) 
Appendix D 

NUREG-1943 D-68 May 2011 

Table 3. Utility Funds Expended with Associated Demand and Energy Savings 2007* (From the Annual 

Energy Efficiency Reports, including SB7 and non-SB7 programs.)

Utility Funds Expended ($) Demand Savings (MW) Energy Savings (MWh) 

AEP-SWEPCO 1,234,200 1.61 5,496 

AEP-TCC 5,203,100 9.50 25,491 

AEP-TNC 993,800 1.37 4,894 

CNP 19,563,098 52.28 135,364 

EGSI 2,968,000 5.34 15,034 

EPE 1,115,000 1.21 5,000 

TNMP 819,757 2.30 3,394 

Oncor 46,384,709 89.23 216,371 

Xcel 2,008,000 4.14 16,818 

TOTAL 80,289,664 166.98 427,862 

* All energy savings are calculated at meter. 

Response: Chapter 8 of the EIS will describe the results of the NRC staff independent review 

the need for power and will present an analysis of economic conditions and other factors that 

influence the need for power. 

Comment: Based on the assumption that a federal repository will not be available for spent 

fuel management, the EIS should consider the environmental and public health consequences 

of either the State of Texas or the United States government becoming the de facto custodians 

of spent fuel at the Comanche Peak site after the operating license has lapsed and post-closure 

activities of the licensee have been completed. If, at the end of the post-closure responsibilities 

of the licensee, spent fuel remains on-site it will have to be managed and secured for the 

indefinite future. The only institutional capacity for long-term spent fuel management is a unit or 

units of government. To the extent that units of government are responsible for managing onsite spent fuel, calculations for employee exposures and public exposures should be included in 

the EIS. Additionally, other public health environmental consequences reasonably associated 

with indefinite governmental management of spent fuel on site should also be considered in the 

EIS. 

The EIS should also consider specifically what entity would actually have legal ownership of the 

spent fuel after the operating license has lapsed and post-closure activities have ceased. Will 

the ownership of the spent fuel default to some unit of government? If so, what costs can be 

reasonably anticipated by the de facto custodian/owner of spent fuel? Do the anticipated costs 
Appendix D 

May 2011 D-69 NUREG-1943 

have environmental and public health consequences? The EIS should resolve these questions. 

(0022-42 [Hadden, Karen]) 

Response: Impacts related to the uranium fuel cycle and its transportation steps, including 

disposal of low-level radioactive waste and spent fuel, will be addressed in Chapter 6 of the 

EIS. The generic impacts of the fuel cycle are codified in 10 CFR 51.51(b), Table S-3, "Table of 

Uranium Fuel Cycle Environmental Data." Per the guidance in 10 CFR 51.51 and Section 5.7 of 

NUREG-1555, the staff will rely on Table S-3 as a basis for uranium fuel cycle impacts. The 

safety and environmental effects of long-term storage of spent fuel on site have been evaluated 

by the NRC and set forth in the Waste Confidence Rule at 10 CFR 51.23 

(http://www.nrc.gov/reading-rm/doc-collections/cfr/part051/part051-0023.html). 

D.2.26 Comments Concerning Alternatives - No-Action 

Comment: There are lots of impacts, environmental and otherwise of all alternatives, too, 

including the oft-overlooked alternative of doing little or nothing about the situation which the 

project is being considered. (0017-58 [Wohler, Will]) 

Response: The no-action alternative will be evaluated and addressed in Chapter 9 of the EIS 

in comparison with the proposed action. 

D.2.27 Comments Concerning Alternatives - Energy 

Comment: I would suggest that we very seriously consider geothermal energy. (0016-61

[Wildwood, Kathleen]) 

Comment: There are so many sustainable products that need to be looked into, such as was 

mentioned, geothermal, solar, wind, even gas. But that has disadvantages too, but I would like 

to ask that you look at those questions. (0016-76 [Shaar, Julie]) 

Comment: I think there are cleaner, safer and more economical ways to generate electricity, 

which is what everybody wants. (0017-34 [Cohn, Ann]) 

Comment: TXU could produce electricity safer, cleaner, and cheaper, it is my opinion, if they 

went solar or wind. (0017-37 [Cohn, Ann]) 

Comment: There are alternatives; wind, solar. We can do better. Why can't we be visionary 

about energy? (0017-47 [Bisbee, Kay]) 

Comment: They surely knew, saw the handwriting on the wall for the future, existing and future 

potential for renewable energy. Yet they went ahead and bought at least Luminant, knowing that 

they had designs to build these new nuclear power plants. All these facts were available. (0017-

53 [Duncan, Jim]) 

Comment: Alternative renewable energy sources have their own serious environmental 

impacts. (0017-59 [Wohler, Will]) 

Comment: The energy of the future lies in wind and solar, energy efficiency and other forms of 

renewable power. (0017-61 [Rittenhouse, Ryan]) 

Comment: Additionally, processing uranium into fuel requires substantial amounts of electrical 

energy and water. The impacts from the use of the substantial amounts of energy and water 

must be part of a proper EIS. Without this analysis of the use of energy and water in the 

production of uranium fuel there cannot be a meaningful comparison with practicable 
Appendix D 

NUREG-1943 D-70 May 2011 

alternatives that do not utilize large amounts of water and electricity for fuel production. 

(0022-5 [Hadden, Karen]) 

Comment: The Comanche Peak environmental report also fails to carefully compare the 

greenhouse gas effects expected from each of the alternative technologies. This analysis is 

crucial because of the relationship between greenhouse gases and global warming and 

because it is expected that the use of fossil fuels to support the uranium fuel cycle will become 

more expensive over time. This circumstance will be aggravated by the anticipated use of 

foreign produced uranium that will have a greater greenhouse gas impact because of, among 

other reasons, a longer supply line. In contrast, renewable fuel technologies are expanding 

manufacturing capacities domestically. Hence, the EIS should project anticipated greenhouse 

gas emissions related to the competing technologies. (0022-51 [Hadden, Karen]) 

Comment: Alternatives that assess local power generation should be evaluated. For example, 

several small, local power plants may equal the amount of electricity generated by the proposed 

Comanche Peak Nuclear Power Plant (CPNPP) project. Local power generation, in contrast to 

large regional power generation, may have benefits that have not been explored (e.g., local 

transmission and use of power instead of long distance transmission, ability to deliver electricity 

in the event of a catastrophic event, smaller potential impacts to water use, waste generation, 

etc.) (0027-3 [Osowski Morgan, Sharon L.]) 

Comment: Safer, cleaner, more affordable ways are now available to generate electricity, 

including wind, solar and geothermal energy. (0030-7 [Hadden, Karen]) 

Response: Alternative energy sources, including fossil fuels and renewable energy sources 

such as wind, solar, and geothermal, will be evaluated and addressed in Chapter 9 of the EIS in 

comparison with the proposed action. 

Comment: If we get energy storage to combine the wind and the solar power, we can have a 

good base load impact. Our real needs are for peak energy to begin with, and we get that with 

West Texas Wind. (0016-15 [Hadden, Karen]) 

Comment: The Comanche Peak environmental report generally understates the efficacy of 

alternative sources of electric power generation. p. 9.2-1, et seq. The EIS should evaluate 

alternative sources of generating capacity based on the current data available regarding 

capacity factors, technological advances that overcome intermittency challenges regarding wind 

and solar power, and historical operational experience. It should be noted that Texas leads the 

nation in wind generation. In 2005, Texas set a goal of 5880 MW of wind by 2015, but the state 

has already exceeded this amount, and nearly $5 billion additional transmission lines have 

already been approved. The costs of various forms of energy generation should be considered 

as well, especially considering that the Federal Energy Regulatory Commission (FERC) 

published the following data in 2008, showing nuclear power to be the most expensive way to 

generate electricity. 

The Comanche Peak environmental report assumes that renewable fuels such as wind and 

solar cannot provide adequate baseload generating capacity. However, recent advances in 

technology such as compressed air energy storage and improved battery storage capacity call 

into question some of the environmental report's assumptions concerning problems with 

intermittency. Additionally, current technology advances are proving the assumptions about 

renewable fuels made in the environmental report to be outdated and inaccurate. Expansions of 

renewable energy capacity are occurring daily. In contrast, nuclear capacity, as a percentage of 

total generating capacity, is shrinking. The EIS should evaluate the competing technologies in 
Appendix D 

May 2011 D-71 NUREG-1943 

light of current energy policy which places a greater emphasis on renewable fuels than did 

previous energy policy that favored nuclear power and fossil fuels. (0022-48 [Hadden, Karen]) 

Comment: The Comanche Peak environmental report understates the ability of Texas to meet 

its energy demands through energy efficiency and renewable energy. While acknowledging that 

these technologies will play an increasing role, the report submitted by Luminant assumes that 

Texas needs large base-load plants to meet future energy demand and that solar, wind, and 

geothermal technologies are incapable of meeting these needs. Nevertheless, recent reports 

and advances in technology show that Texas can meet its energy demand through a 

combination of these technologies. (0032-14 [Reed, Cyrus]) 

Comment: First of all, the Texas legislature only recently, in 1999, adopted a Renewable 

Portfolio Standard, requiring certain utilities to obtain part of their energy mix with renewable 

power. By 2005, the Legislature chose to raise the requirements to 5,880 MWs by 2015 and a 

target of 10,000 MWs by 2025. However, Texas has already surpassed the 2105 target and 

recently approved a $5 billion transmission plan, awarded to some 10 companies, that will lead 

to approximately 18,000 MWs of largely wind development between existing and planned 

development. This should occur before 2015. (0032-15 [Reed, Cyrus]) 

Comment: Furthermore, recent developments prove that costs for solar power, energy storage 

and geothermal energy have declined and will continue to decline in the future, especially given 

federal action to stimulate these new sources of energy. Luminant itself is engaged in a joint 

investment with Shell to developed air compressed storage from a wind farm in West Texas that 

could lead to 1,000 MWs of stored energy, in addition to the wind power itself. 

The recent Federal Stimulus package as well as action by the Texas legislature could make 

these energy sources even more attractive, and the planned expansion of the nuclear plant 

should be judged against these energy sources. We would suggest that the EIS incorporate any 

recent changes in state and federal law which would make the development of these 

alternatives more likely. We would suggest that the life-cycle costs, environmental and public 

health impacts of nuclear be compared to solar, wind, geothermal, coal, natural gas, and energy 

efficiency and conservation as part of the EIS. (0032-17 [Reed, Cyrus]) 

Response: Alternative energy sources, including combinations of sources such as fossil fuels 

and renewable energy sources, will be evaluated and addressed in Chapter 9 of the EIS in 

comparison with the proposed action. Due to the extensive wind resources in the ERCOT 

service area and the actions already taken or planned to expand wind energy, Chapter 9 of the 

EIS will provide a detailed analysis of environmental impacts of wind energy as alternative to the 

proposed action. 

Comment: An expanding number of studies show that nuclear energy is neither clean nor costeffective in relation to other energy alternatives such as wind and solar energy. The cost of the 

possible new reactor- up to $22 billion- could retrofit over 7 million Texas homes to make them 

more energy efficient. (0010-2 [Shroyer, Danielle]) 

Comment: There are cleaner ways that make a stronger local economy. The PUC, the Public 

Utility Commission of Texas, Commissioner Barry Smitherman, recently testified that for every 

dollar put into energy efficiency, we get two dollars' worth of savings back. (0016-20 [Hadden, 

Karen]) 

Comment: The technique of analysis used in the Comanche Peak environmental report to 

determine the relative advantages of renewable fuels compared to nuclear power is inherently 

flawed. For example, the environmental report essentially eliminates conservation/energy 

efficiency as an alternative that should be considered. p. 9.2-3. The environmental report 
Appendix D 

NUREG-1943 D-72 May 2011 

excuses the consideration of conservation/energy efficiency, because Comanche Peak Units 3 

and 4 will be merchant power plants. And as such, conservation and demand side management 

programs to encourage consumers to modify levels of electricity usage "are not within the 

capability or responsibility of the wholesale baseload merchant generator." Id. However, the 

Comanche Peak reactors would operate within the ERCOT system in Texas, so the market is 

not unlimited. They are bound to buy or sell electricity to within ERCOT, which is wholly within 

the state. The environmental report attempts to rationalize omission of conservation/energy 

efficiency measures by citing to NRC policy that has determined that conservation measures 

are not reasonable alternatives to merchant power plants that sell wholesale power. Id.

However, the EIS should not be controlled by the same artificial constraint. The Comanche 

Peak nuclear power plant expansion proposal should be viewed in the larger context of other 

means by which to influence electricity usage. Adopting the environmental report's conclusions 

essentially allows merchant power plants to ignore the proven effectiveness of conservation and 

energy efficiency programs that have been tested numerous time by various utilities as a means 

to curtail demand. 

Texas is in the process of taking further steps to pursue energy efficiency. A new report 

commissioned by the Texas Public Utilities Commission shows that the state could reduce 

electric usage by 23% if utilities invest more in efficiency measures, saving Texans as much 

$11.9 billion on their electric bills. The findings bolster the call by a coalition of local elected 

officials, business leaders, community groups and faith leaders for the Legislature to increase 

the mandate on utilities for energy efficiency investments. The Texas legislature passed an 

energy efficiency bill last session (2007) and is expected to strengthen energy efficiency 

commitments in 2009, as well as enacting improved buildings codes which will significantly 

reduce energy demand. The federal stimulus bill includes initiatives and incentives which will 

further these efficiency efforts and reduce the growth in demand for electricity. (0022-49

[Hadden, Karen]) 

Comment: Two additional nuclear reactors are currently proposed by Luminant for the 

Comanche Peak site southwest of Dallas/Fort Worth near Glen Rose, Texas, where two 

reactors exist now. The proposed reactors could cost up to $22 billion. This sum used differently 

could instead retrofit over seven million homes to make them more energy efficient, saving 

money for consumers, creating local jobs, reducing pollution and addressing global warming 

directly right now. (0030-2 [Hadden, Karen]) 

Response: The NRC is not involved in establishing energy policy; rather, it regulates nuclear 

energy to protect public health and safety within existing policy. While energy efficiency 

measures could reduce energy demands in the Comanche Peak service area, in accordance 

with NUREG-1555, a merchant power plant is not required to perform a demand side 

management analysis or consider measure to increase energy efficiency as an alternative to the 

proposed action. 

Comment: Be sure to keep the broad picture in view... 

Why would we consider the environmental impact of any proposed project separately from 

considering the impacts of whatever the alternative(s) to that project are?? For that matter, how 

could we consider only the environmental impacts of the project?? There are lots of impacts, 

environmental and otherwise, of all the alternatives, too -including the oft-ignored alternative of 

doing little or nothing about the situation for which the project is being considered!! 

Surely, if we don't take a broad view of the situation, we run the risk of skewed policy decisions, 

no? (& the narrower our focus, the greater the skewing risk!) 
Appendix D 

May 2011 D-73 NUREG-1943 

Alternative / Renewable energy sources have their own serious environmental Impacts! (not to 

mention their much lower energy 'density' & continuity of availability). For example, the 

infrastructure needed to harness these other power sources consumes tremendous resources 

(in materials, land & monetarily). And unless a great deal more resources are used for the 

capacity storage that all these sporadically-available power sources require, we'll still have to 

use conventional, always-available power sources to 'fill in' for when the Alternative / 

Renewable sources aren't available. (Wind & Solar are highly variable in availability!) 

Excessive Conservation also has adverse environmental impacts -from the more impoverished 

conditions resulting from too much reliance on Conservation. A more prosperous society is 

more able to afford the costs of higher levels of environmental preservation! 

Just as "No one is an Island" (unto themselves), we dare not consider, in isolation, the impacts 

of just one (kind of) proposal. 

Something else to keep in mind as deliberation proceeds on these proposed new nuclear power 

generating facilities: 

The validity of scientific (and other) theories & findings, is not in any way dependent on how 

many -or few -people express those theories & findings. Likewise, the wisdom of any particular 

public policy(ies) also has no necessary relationship to the number of people supporting them. 

None of those things bears any necessary relationship to majority (or minority) views. (0018-3

[Wohler, Will]) 

Comment: The right way to meet our energy needs right now is through energy efficiency, first 

and foremost, through better building codes. And that's starting to happen throughout the state. 

Many cities are passing building codes. If we just get smarter about our energy use, we won't 

need so much. I maintain that these reactors are not necessary. (0016-13 [Hadden, Karen]) 

Comment: Wind and solar energy are well developed now and more affordable than nuclear 

power. Energy efficiency helps curb demand. We do not need nuclear power or the risks that it 

entails. (0019-7 [Hadden, Karen]) 

Response: The NRC is not involved in establishing energy policy; rather, it regulates nuclear 

energy to protect public health and safety within existing policy. While energy efficiency 

measures could reduce energy demands in the Comanche Peak service area, in accordance 

with NUREG-1555, a merchant power plant is not required to perform a demand side 

management analysis or to consider measures to increase energy efficiency as an alternative to 

the proposed action. Chapter 9 of the EIS will describe potential impacts from alternative 

energy sources. Due to the extensive wind resources in the ERCOT service area and the 

actions already taken or planned to expand wind energy, Chapter 9 of the EIS will provide a 

detailed analysis of environmental impacts of wind energy as alternative to the proposed action. 

Comment: With the wind turbine, there may be an accident now and then, but you don't have 

thousands of people at risk from a radioactive waste release with a wind turbine. (0016-19

[Hadden, Karen]) 

Comment: The Comanche Peak environmental report is also flawed to the extent that it fails to 

make a realistic comparison between the environmental impacts and public health 

consequences of nuclear power compared to energy efficiency and renewable fuels. For 

example, there should be a side-by-side comparison of mortality and morbidity consequences of 

nuclear power compared to energy efficiency and renewable fuels in order to accurately 

determine the consequences of each. Of course, the comparisons would indicate that energy 

efficiency and renewable fuels do not cause increased mortality and morbidity while nuclear fuel 
Appendix D 

NUREG-1943 D-74 May 2011 

does. Moreover, there should be a side-by-side comparison of nuclear fuels and energy 

efficiency and renewable fuels, related to the effects of catastrophic accidents. Such a side-byside comparison would indicate that a catastrophic loss of, for example, a wind generating 

accident or capacity loss would be negligible compared to a major loss of cooling accident at 

Comanche Peak Units 3 and 4. The EIS should engage such a comparative analysis in order to 

fairly determine the environmental consequences and public health impacts of each. (0022-50

[Hadden, Karen]) 

Response: The NRC is not involved in establishing energy policy; rather, it regulates nuclear 

energy to protect public health and safety within existing policy. The EIS will evaluate the risk 

and consequences of design basis and severe accidents in Chapter 5. The discussion of 

alternative energy sources, including wind and solar, will be addressed in Chapter 9 of the EIS, 

which will compare and describe potential environmental impacts from alternative energy 

sources. Alternative energy sources will be evaluated first to determine if the energy source can 

meet the purpose and need of the project. If they cannot meet the purpose and need then they 

are not evaluated further. As part of the COL process and in conjunction with the EIS, the NRC 

staff will conduct a safety review detailing site-specific safety analysis and design specific 

analysis, including NRC acceptance. 

Comment: It's [nuclear power is] not a useful solution to climate change. You can't build 

reactors fast enough to meet any significant portion of the energy needs to be produced. (0016-

12 [Hadden, Karen]) 

Response: The NRC is not involved in establishing energy policy; rather, it regulates nuclear 

energy to protect public health and safety within existing policy. Alternative energy sources, 

including fossil and renewable energy sources such as wind, solar, and geothermal, will be 

evaluated and addressed in Chapter 9 of the EIS in comparison with the proposed action. 

Comment: Do I have to waste the energy I'm wasting today? In the little things that we do, 

inefficient lighting, the extras that we do through every day, the things that we leave on that we 

could turn off, do we have to do that so badly that we're willing to leave a legacy of radioactive 

waste that literally will last millions of years, that someone someday is going to have to 

repackage and make sure it's contained safely so it doesn't escape into the environment. 

(0016-17 [Hadden, Karen]) 

Response: The NRC is not involved in establishing energy policy; rather, it regulates nuclear 

energy to protect public health and safety within existing policy. While energy efficiency 

measures could reduce energy demands in the Comanche Peak service area, in accordance 

with NUREG-1555, a merchant power plant is not required to perform a demand side 

management analysis or consider measure to increase energy efficiency as an alternative to the 

proposed action. Section 9 of the EIS will describe potential impacts from alternative energy 

sources. The impact of the uranium fuel cycle, including disposal of low-level radioactive waste 

and spent fuel, will be addressed in Chapter 6 of the EIS. 

Comment: there will be significant legislative action that will add to our power mix in Texas, not 

in terms of nuclear, but in terms of both energy efficiency and other renewables. 

And I left in the back sort of some of the legislative goals that Lone Star Chapter of the Sierra 

Club has, many of—all of which, frankly, are also for economic benefit. It's about promoting 

other kinds of energy use and energy efficiency that are also good for the economy. And our 

view is that if you look at all the different energy sources, nuclear really should be the last option 

we look at. 
Appendix D 

May 2011 D-75 NUREG-1943 

So I want you to look at that projection, look at some of the studies that have been done by 

Itron, by ACEEE and others for Texas, to see if their assessment is realistic in terms of what's 

needed in Texas and whether we can't meet this demand through other means, including 

means that, frankly, Luminant is looking at, like wind, and I know they're looking at the potential 

for utility-scale solar. So I'd urge you to look at that. (0016-51 [Reed, Cyrus]) 

Response: The NRC is not involved in establishing energy policy; rather, it regulates nuclear 

energy to protect public health and safety within existing policy. The discussion of alternative 

energy sources, including wind and solar, will be addressed in Chapter 9 of the EIS, which will 

compare and describe potential environmental impacts from alternative energy sources. Due to 

the extensive wind resources in the ERCOT service area and the actions already taken or 

planned to expand wind energy, Chapter 9 of the EIS will provide a detailed analysis of 

environmental impacts of wind energy as alternative to the proposed action. 

Comment: The right way to meet our energy needs right now is through energy efficiency, first 

and foremost, through better building codes. And that's starting to happen throughout the state. 

Many cities are passing building codes. If we just get smarter about our energy use, we won't 

need so much. I maintain that these reactors are not necessary. (0016-14 [Hadden, Karen]) 

Comment: And we all know that we need to do conservation. (0017-16 [Burnam, Lon]) 

Comment: An easier way to increase, or to use energy more efficiently is a better way of 

conserving energy, and Texas leads in being energy wasteful. Energy conservation and energy 

efficiency are easy ways to go. (0017-79 [Stuard, Gary]) 

Response: The NRC is not involved in establishing energy policy; rather, it regulates nuclear 

energy to protect public health and safety within existing policy. While energy efficiency 

measures could reduce energy demands in the Comanche Peak service area, in accordance 

with NUREG-1555, a merchant power plant is not required to perform a demand side 

management analysis or consider measure to increase energy efficiency as an alternative to the 

proposed action. 

Comment: say, cut this off right now, and go for alternative sources of energy, truly green jobs. 

If you want a jobs program, get one that is not going to hurt the next generation. (0017-73

[Sanders, Jan]) 

Response: The NRC is not involved in establishing energy policy; rather, it regulates nuclear 

energy to protect public health and safety within existing policy. Chapter 9 of the EIS will 

describe potential impacts from alternative energy sources. 

D.2.28 Comments Concerning Alternatives - System Design 

Comment: The study should also include an analysis of pollution impacts downstream from 

water contaminated by chemical treatment such as biocides, algaecides, pH adjustors, 

corrosion inhibitor and silt dispersant chemicals injected at the reactor site as well as chlorine, 

salts and non-radioactive effluent. The differential impact of treatment of 100 percent of the 

water versus the lesser amount of treatment proposed by the applicant should be considered. 

(0022-19 [Hadden, Karen]) 

Comment: The proposed project will withdraw water for cooling tower makeup from Lake 

Granbury and return the cooling tower blowdown back to Lake Granbury. Currently, Lake 

Granbury is listed as being impaired for chlorides. CPNPP should know that a total maximum 

daily load (TMDL) will be prepared for Lake Granbury to address the chloride impairment. The 

TMDL will give a wasteload allocation for chlorides to CPNPP for its cooling tower blowdown 
Appendix D 

NUREG-1943 D-76 May 2011 

discharge. CPNPP should be aware that it may be required to meet the water quality standard 

for chlorides or significantly reduce the level of chloride in its discharge. Texas Commission on 

Environmental Quality (TCEQ) is responsible for developing TMDLs and TMDL Implementation 

plans. EPA reviews and approves TMDLs developed by TCEQ. (0027-11 [Osowski Morgan, 

Sharon L.]) 

Comment: Best Management Practices (BMPs) should be used to reduce erosion during 

construction. Typical BMPs include the use of staked hay bales, silt fences, mulching and 

reseeding, and appropriate buffer zones along water bodies. The document should include an 

erosion control plan or reference the State erosion control regulations and a commitment to 

compliance. Compliance should include both BMP application and maintenance. (0027-8

[Osowski Morgan, Sharon L.]) 

Response: The construction and operation of a nuclear plant involves some discharges to 

nearby water bodies. The Clean Water Act designated the U.S. Environmental Protection 

Agency as the Federal agency with responsibility over effluent discharges to the nation’s 

waters. While it only regulates radiological effluents, the NRC does have the responsibility 

under NEPA to assess and disclose the expected impacts of the proposed action on water 

quality throughout the plant’s life. The staff’s assessment of the nonradiological impacts to 

water quality will be presented in Chapter 5 of the EIS. Luminant's proposed blowdown waste 

water treatment would return water to Lake Granbury in compliance with all regulatory water 

quality requirements. Consequently, additional levels of water treatment would not be 

necessary. Alternatives for additional water treatment, including those suggested in the 

comment, will not be addressed in the EIS. 

Comment: The Energy Policy Act of 2005 directed the United States Department of Energy to 

research and develop proliferation resistant fuel recycling and transmutation technologies that 

are intended to minimize damage to the environment and public health and to enhance safety of 

spent fuel management. The EIS should consider this alternative and determine whether it is 

technologically feasible and prudent to pursue. The reason for this alternative to be considered 

as a spent fuel management technique is because it assumes that a federal repository for spent 

fuel will not be available. Proliferation resistant fuel recycling and transmutation technologies 

may have the effect of managing spent fuel in a way that minimizes adverse impacts to the 

public's health and the environment. Therefore, the EIS should fully develop the state of these 

technologies and determine whether such would be available for purposes of managing spent 

fuel at Comanche Peak. (0022-41 [Hadden, Karen]) 

Response: Chapter 6 of the EIS evaluates the fuel cycle impacts including both a no-recycle 

process and a recycle process. The safety and environmental effects of spent fuel storage 

onsite have been evaluated by the NRC and, as set forth in the Waste Confidence Rule (10 CF 

51.23), the NRC generically determined that such storage could be accomplished without 

significant environmental impacts. In the Waste Confidence Rule, the Commission determined 

that spent fuel can be safely stored onsite for at least 30 years beyond the plant's life. 

Comment: When the first two reactors were built the sky glow light pollution went from zero to 

off the scale in the direction of the reactors. The latest round of fixture modernization reduced 

the sky glow by about 40 percent. Our Concern is the two new units will increase the sky glow 

beyond what it was after initial construction. We would like to see a comprehensive relighting 

program for all four reactors, using the latest technology zero cut-off fixtures, such as those 

approved by the International Dark-sky Association in order to achieve an overall reduced light 

pollution impact than what now exists. www.darksky.org (0024-1 [Miller, Russ]) 
Appendix D 

May 2011 D-77 NUREG-1943 

Response: The physical impacts of the facility operation at the proposed site, including the 

impacts of the proposed plant lighting, will be evaluated in Chapter 5 of the EIS. 

Comment: In my conversations with engineers, it is commonly believed that a better 

engineered cooling system could easily reduce or eliminate this water loss. [Loss of 55,000 acre 

feet per year to evaporative cooling.] FBR [Friends of the Brazos River] respectfully asks that 

you delay this permit until a less wasteful cooling system can be designed. (0025-2 [Lowe, Ed]) 

Response: The construction and operation of a nuclear plant involves the consumption of 

water. The staff will independently assess the impact of these consumptive water losses on the 

sustainability of both the local and regional water resources. This assessment will consider both 

current and future conditions, including changes in water demands to serve the needs of the 

future population, and changes in water supply resulting from climate variability and climate 

change. While the NRC does not regulate or manage water resources, it does have the 

responsibility under NEPA to assess and disclose the impacts of the proposed action on water 

resources. The staff’s assessment of the impacts on water resources from the plant’s proposed 

cooling system will be presented in Chapters 4 and 5 of the EIS for construction and operation, 

respectively. The impacts of alternatives to the proposed cooling system will be evaluated in 

Chapter 9 of the EIS. 

Comment: The Comanche Peak report admits that there is no federal site for disposition of 

high-level nuclear waste and that present options for disposal of low-level radioactive waste are 

limited. Given the difficulty in siting both low-level and high-level radioactive waste, an EIS 

should consider all of the waste disposal options, including long-term storage at the site itself. 

(0032-12 [Reed, Cyrus]) 

Response: The impact of the uranium fuel cycle, including disposal of low-level radioactive 

waste and spent fuel, will be addressed in Section 6 of the EIS. The generic impacts of the fuel 

cycle are codified in 10 CFR 51.51(b), Table S-3, "Table of Uranium Fuel Cycle Environmental 

Data." Per the guidance in 10 CFR 51.51 and Section 5.7 of NUREG-1555, the staff will rely on 

Table S-3 as a basis for uranium fuel-cycle impacts. The Waste Confidence Rule (10 CFR 

51.23) has determined that spent fuel can be safely stored on site for at least 30 years beyond 

the life of the plant. 

Comment: Given the uncertainty involved with licensing the Yucca Mountain Nevada facility for 

the disposal of spent nuclear fuel, all utilities planning on constructing additional nuclear units on 

current sites should consider contingencies for long-term storage of waste on-site. (0027-6

[Osowski Morgan, Sharon L.]) 

Response: The safety and environmental effects of spent fuel storage onsite have been 

evaluated by the NRC and, as set forth in the Waste Confidence Rule (10 CF 51.23), the NRC 

generically determined that such storage could be accomplished without significant 

environmental impacts. In the Waste Confidence Rule, the Commission determined that spent 

fuel can be safely stored onsite for at least 30 years beyond the plant's life. 

D.2.30 Comments Concerning Benefit - Cost Balance 

Comment: The two proposed Comanche Peak reactors could cost up to $22 billion according 

to Luminant's own documents. This is before cost overruns. This amount could make 7.3 million 

homes more energy efficient. Pursuing efficiency lowers bills, reduces electricity consumed, and 

creates local jobs. The existing Comanche Peak reactors ran ten times over budget and were 

years late coming online. What if this happened again? (0019-8 [Hadden, Karen]) 
Appendix D 

NUREG-1943 D-78 May 2011 

Response: These points will be noted and discussed in the EIS. NUREG-1555 call for the 

Benefit-Cost analysis to include consideration of internal and external costs. The scope of the 

analysis for internal costs are those costs for the design proposed by the applicant (NUREG1555). Scenario analysis of vast departures from these costs is therefore outside the scope of 

this analysis. 

Comment: Further, I request to see an analysis of water use per kilowatt hour produced for the 

proposed new plant reactors and the cost of this power if Luminiant had to pay current 

wholesale water rates. (0021-3 [Richardson, Karen]) 

Response: The EIS will reflect the cost of cooling systems in its analysis and the water 

quantities lost through evaporation and other losses in Chapter 10 of the EIS. 

Comment: 3. Reactor Lifespan - (a) What is the average effective life span of a nuclear 

reactor? 

(b) How much additional funding will be required to maintain an aging reactor? 

(0023-7 [Ubico, Jean]) 

Response: The assumptions of reactor life span and costs used in this analysis will be 

provided in Section 10 of the EIS. Costs for all phases of reactor construction and maintenance 

will be discussed, but data are specific to the proposed plants and the alternatives chosen and 

cannot be applied to a "representative" reactor. The license period for a combined license is 40 

years. A licensee can request renewal for an additional 20 years. The cost benefit analysis is 

done for the license period of 40 years. It would not be appropriate to assume additional cost or 

benefit for an additional 20 years of license renewal when that action has not been requested or 

approved. 

Comment: The second piece entitled 'Troubled History of Comanche Peak' is intended to 

bolster the case for including consideration of existing reactors' history in the EIS. The past is 

prelude to the future. The EIS must address the possibility that difficulties similar to those which 

occurred in the past might occur again. The problems that arose in the past were frequently 

related to using new technologies. As the USAPWR design proposed for Comanche Peak Units 

3 and 4 has never been built anywhere in the world, the likelihood of problems and resulting 

health and environmental impacts is likely to increase. A full analysis of the difficulties of 

building the reactors successfully including an examination of the history of existing reactors 

should be undertaken in the EIS. (0030-1 [Hadden, Karen]) 

Response: The EIS will contain a detailed analysis of the proposed reactors and comparisons 

of alternatives to the proposed reactors. A detailed analysis of the history of the nuclear power 

industry that goes beyond the proposed reactors and the alternatives is beyond the scope of 

this EIS. 

Comment: Nuclear technology is not cost effective, requiring massive subsidies from 

taxpayers. (0031-8 [Gentling, Suzanne]) 

Response: The NRC is not involved in establishing energy policy; rather, it regulates nuclear 

energy to protect public health and safety within existing policy. An analysis of the proposed 

facilities and alternatives will be presented in Chapter 9 of the EIS. 

Comment: I have read, from a financial standpoint, how much taxpayers are paying for this 

nuclear power plant. I have read the bills that have to do with the energy bills for 2005 and so 

on, that show all the subsidies that are going into the nuclear power plants. So we are paying for 

it. (0017-50 [Harper, Debbie]) 
Appendix D 

May 2011 D-79 NUREG-1943 

Response: Chapters 9 and 10 of the EIS will review the costs of constructing the plant and 

compare the proposed site with alternatives. Non-monetary costs, such as environmental 

impacts and other costs, will also be analyzed and summarized in a benefit cost section. The 

NRC staff is aware that nuclear energy receives some subsidies and that all other energy forms 

are also subsidized in different ways. A complete analysis that compares all of these subsidies 

on a common basis is beyond the scope of the EIS. 

Comment: [The proposed Comanche Peak units 3 and 4 are a] Waste of money. (0017-81

[Sanders, Jan]) 

Response: Chapter 10 of the EIS will contain an analysis of the need for the power for the 

proposed facility, the alternatives to the proposed facility, and a summary of benefits and 

costs. Ultimately, the plant will be evaluated relative to other ways to meet the forecasted 

demands for power. 

Comment: Ecosystem services are the benefits humans derive from nature. The concept of 

ecosystem services encompasses natural renewable resources and processes that are 

essential to human well being like clean water, clean air, and a host of other services that have 

not been traditionally incorporated into cost-benefit analyses, but can be considered. The 

concepts of ecosystem services and sustainability are interconnected. If use of ecosystem 

services exceeds the environment's capacity to perform those services, then the activity is not 

sustainable over time. The NEPA document should discuss aspects of ecosystem services and 

sustainability as appropriate. (0027-24 [Osowski Morgan, Sharon L.]) 

Response: The comment correctly notes that the environment and other natural systems 

provide services that contribute to societal well-being, but that these services are not marketed 

and are difficult to measure. For this reason, the EIS process has traditionally sought to add the 

costs of mitigating external impacts to the costs summarized in Chapter 10 of the EIS. Where 

possible a quantitative value for mitigated costs will be used and where this is not possible a 

qualitative analysis will be used. Unmitigated costs are termed unavoidable and are valued and 

included in the analysis in the same way. The scope of this analysis is described in NUREG1555 p. 2.4.2 and will be followed in Chapter 10 of the EIS. 

Comment: The cost to the taxpayers. I think all of us should feel quite sore already from the 

fact that we have been stuck with high bills, given corporate malfeasance and corruption, and 

that we have been left with paying the bill. The only reason why nuclear power could be on the 

plate or the playing field is the fact that it is going to be heavily subsidized, i.e.; you and I will 

pay for it. I don't know about you, but that doesn't leave a good taste in my mouth. 

Also a recent study that has just recently come out, called Business Risks and Costs of New 

Nuclear Power has put the generation cost of power or power from nuclear power plants at from 

25 to 30 cents per kilowatt hour. That is triple the current U.S. electricity rate. (0017-77 [Stuard, 

Gary]) 

Response: The EIS will review the environmental costs of constructing the plant and compare 

the proposed site with alternatives. Non-monetary costs, such as environmental impacts and 

other costs, will also be analyzed and summarized in a benefit cost section. The NRC staff is 

aware that nuclear energy receives some subsidies and that all other energy forms are also 

subsidized in different ways. A complete analysis that compares all of these subsidies on a 

common basis is beyond the scope of the EIS. However, it is noteworthy that following the 

restructuring of the ERCOT electric power system, wholesale power producers must compete 

with other power suppliers and that their investors have their capital at risk if the facilities cannot 

successfully compete in the marketplace. Under this system, power generators are not subject 

to rate of return regulation and have no guaranteed profits. 
Appendix D 

NUREG-1943 D-80 May 2011 

Comment: The indirect or secondary impacts should be assessed. In particular, the potential 

impacts associated with water use from sources other than SCR. The secondary impacts from 

fuel mining and processing should also be investigated. Currently, there does not seem to be 

enough information in Section 10.2.1.6 section to evaluate. The ER states impacts from mining 

on geological resources are expected to be small. This statement is not consistent with the large 

scale and wide-ranging impacts mining may potentially have on the environment. Additional 

information should be provided. (0027-26 [Osowski Morgan, Sharon L.]) 

Response: Chapters 4 and 5 of the EIS will review secondary impacts from constructing and 

operating the plant including impacts from water usage and from the nuclear fuel cycle, 

including mining, processing, and fuel fabrication. Where staff finds the applicant's analysis 

unpersuasive or inadequate, staff will request additional information from the applicant. If 

necessary staff will carry out additional independent analyses. The public will have an 

opportunity to review the draft EIS and to comment on it. 
Appendix E 

Draft Environmental Impact Statement 

Comments and Responses 
 
May 2011 E-1 NUREG-1943 

Appendix E 

Draft Environmental Impact Statement 

Comments and Responses 

As part of the U.S. Nuclear Regulatory Commission (NRC) review of the Luminant Generation 

Company LLC (Luminant) application for combined licenses (COLs) for proposed Units 3 and 4 

at the Comanche Peak Nuclear Power Plant (CPNPP) site, the NRC and the U.S. Army Corps 

of Engineers (Corps or USACE) (together referred to as the “review team”) solicited comments 

from the public on the draft environmental impact statement (EIS). The draft EIS was issued in 

August 2010. A 75-day comment period began on August 13, 2010, when the U.S. 

Environmental Protection Agency (EPA) issued a Federal Register Notice (75 FR 49486) of 

filing of the draft EIS to allow members of the public to comment on the results of the 

environmental review. 

As part of the process to solicit public comments on the draft EIS, the review team: 

 Placed a copy of the draft EIS at the Somervell County Public Library in Glen Rose, Texas, 

and at the Hood County Public Library, in Granbury, Texas 

 Made the draft EIS available in the NRC’s Public Document Room in Rockville, Maryland 

 Placed a copy of the draft EIS on the NRC website at www.nrc.gov/reading-rm/doccollections/nuregs/staff/sr1943/ 

 Provided a copy of the draft EIS to any member of the public who requested one 

 Sent copies of the draft EIS to certain Federal, State, Tribal, and local agencies 

 Published a notice of availability of the draft EIS in the Federal Register on August 12, 2010 

(75 FR 48998) 

 Filed the draft EIS with the U.S. Environmental Protection Agency (EPA) 

 Held two public meetings on September 21, 2010, in Glen Rose, Texas. 

A combined total of approximately 250 people attended the two public meetings, and numerous 

attendees provided oral comments. A certified court reporter recorded these oral comments 

and prepared written transcripts of the meeting. The transcripts of the public meetings were 

published in October 2010 (see Agencywide Documents Access and Management System 

[ADAMS] Accession Number ML102850649 for the transcript of the afternoon meeting and 

ML102850689 for the evening meeting). In addition to the comments received at the public 

meeting, the NRC received 62 letters and e-mail messages with comments. 

The comment letters, e-mail messages, and transcripts of the public meeting are available in 

ADAMS, which is accessible at http://www.nrc.gov/reading-rm.html. Persons who do not have 

access to ADAMS or who encounter problems in accessing the documents located in ADAMS 

should contact the NRC’s Public Document Room reference staff at 1-800-397-4209 or 301-

415-4737. The ADAMS accession numbers for the letters and e-mail messages are provided in 

Table E-1. 
Appendix E 

NUREG-1943 E-2 May 2011 

E.1 Disposition of Comments 

Each set of comments from a given commenter was given a unique correspondence identifier, 

allowing each set of comments from a commenter to be traced back to the transcript, letter, or 

e-mail in which the comments were submitted. 

After the comment period concluded, the review team considered and dispositioned all 

comments received. To identify each individual comment, the team reviewed the transcript of 

the public meeting and each letter and e-mail received related to the draft EIS. As part of the 

review, the review team identified statements that it believed were related to the proposed 

action and recorded the statements as comments. Each comment was assigned to a specific 

subject area, and similar comments were grouped together. Finally, responses were prepared 

for each comment or group of comments. 

This appendix presents the comments and responses to them grouped by similar issues as 

follows: 

 Comments Concerning Process – COL 

 Comments Concerning Process – NEPA 

 Comments Concerning Site Layout and Design 

 Comments Concerning Land Use – Site and Vicinity 

 Comments Concerning Land Use – Transmission Lines 

 Comments Concerning Meteorology and Air Quality 

 Comments Concerning Hydrology – Surface Water 

 Comments Concerning Hydrology – Groundwater 

 Comments Concerning Ecology – Terrestrial 

 Comments Concerning Ecology – Aquatic 

 Comments Concerning Socioeconomics 

 Comments Concerning Historic and Cultural Resources 

 Comments Concerning Environmental Justice 

 Comments Concerning Nonradiological Waste 

 Comments Concerning Nonradiological Health 

 Comments Concerning Radiological Health 

 Comments Concerning Severe Accidents 

 Comments Concerning the Uranium Fuel Cycle 

 Comments Concerning Transportation 

 Comments Concerning the Need for Power 

 Comments Concerning Energy Alternatives 

 Comments Concerning Alternatives – System Design 

 Comments Concerning Alternative Sites 

 Comments Concerning Benefit-Cost Balance 

 General Comments in Support of the Licensing Action 

 General Comments of Support of Nuclear Power 

 General Comments in Support of the Existing Plant 
Appendix E 

May 2011 E-3 NUREG-1943 

 General Comments in Opposition to the Licensing Action 

 General Comments in Opposition to the Licensing Process 

 General Comments in Opposition to Nuclear Power 

 Comments Concerning Issues Outside Scope – Emergency Preparedness 

 Comments Concerning Issues Outside Scope – Miscellaneous 

 Comments Concerning Issues Outside Scope – Safety 

 Comments Concerning Issues Outside Scope – Security and Terrorism 

 General Editorial Comments 

When the comments resulted in a change in the text of the draft EIS, the corresponding 

response refers the reader to the appropriate section of the EIS where the change was made. 

Throughout this EIS, with the exception of this new appendix, revisions to the text from the draft 

EIS are indicated by change bars (vertical lines) in the margin beside the text. 

Table E-1 provides a list of commenters identified by name, affiliation (if given), comment 

number, and the source of the comment. Some comments addressed topics and issues that 

are not part of the environmental review for this proposed action. These comments included 

questions about NRC’s safety review, general statements of support or opposition to nuclear 

power, and comments on the NRC regulatory process in general. These comments are 

included in this appendix; however, detailed responses to such comments are not provided 

because the comments addressed issues that do not directly relate to the environmental effects 

of this proposed action and are thus outside the scope of the National Environmental Policy Act 

(NEPA) review of this proposed action. Many comments specifically addressed the scope of the 

environmental review, analyses, and issues contained in the draft EIS. 

Table E-2 is an alphabetical index to the comment categories and lists the commenters and 

comment identification number(s) that were included in each category. 

The balance of this appendix presents the comments, along with review team responses, 

organized by topic category. 
Appendix E 

NUREG-1943 E-4 May 2011 

Table E-1. Individuals Providing Comments on the Draft EIS

Commenter Affiliation (if stated) Comment Source and 

ADAMS Accession #

Correspondence ID 

Number

Answorth, Charles Self Meeting Transcript 

(ML102850649) 0063-1 

Apple, Thomas Self Email (ML102500359) 0003 

Barker, M. Blake Self Meeting Transcript 

(ML102850649) 0063-31 

Barnard, James Somervell County 

Commissioner 

Meeting Transcript 

(ML102850649) 0063-8 

Beard, Jim Self Meeting Transcript 

(ML102850649) 0063-26 

Bellu, Toni United Way of Hood 

County 

Meeting Transcript 

(ML102850649) 0063-20 

Benning, Rita Self Meeting Transcript 

(ML102850649) 0063-29 

Bernier, Jim Self Email (ML102740519) 0048 

Berry, Steve Hood County Meeting Transcript 

(ML102850649) 0063-10 

Best, Darrell Glen Rose Chamber of 

Commerce 

Meeting Transcript 

(ML102850649) 0063-17 

Boyd, John Self Email (ML102500354) 0001 

Bradley, Scott Self Meeting Transcript 

(ML102850689) 0062-17 

Burnam, Lon Texas Legislature Meeting Transcript 

(ML102850649) 0063-2 

Burnam, Lon Texas Legislature Meeting Transcript 

(ML102850649) 0063-5 

Clark, Becky Self Email (ML102500374) 0005 

Clark, Becky Self Email (ML102500374) 0020 

Condy, Pat Fossil Rim Wildlife Center Meeting Transcript 

(ML102850689) 0062-10 

Condy, Ymke Self Meeting Transcript 

(ML102850689) 0062-1 

Condy, Ymke Self Meeting Transcript 

(ML102850689) 0062-8 

Conway, Bretta Self Meeting Transcript 

(ML102850649) 0063-23 

Curtis, John Self Meeting Transcript 

(ML102850649) 0063-33 
Appendix E 

May 2011 E-5 NUREG-1943 

Table E-1. (contd)

Commenter Affiliation (if stated) Comment Source and 

ADAMS Accession #

Correspondence ID 

Number

Dooley, Mike Self Meeting Transcript 

(ML102850649) 0063-27 

Drager, Judy Self Email (ML102500360) 0004 

Eatenson, Linda Self Email (ML102660283) 0031 

Edinboro, Sr., 

Christopher Self Email (ML102500377) 0015 

English, Maurice Self Meeting Transcript 

(ML102850649) 0063-38 

Ferrero, Phil and 

Tracey Self Email (ML102660284) 0032 

Fitzgerald, C.C. 

(Fitz) Self Email (ML102500379) 0017 

Fitzgerald, C.C. 

(Fitz) Self Email (ML102660287) 0034 

Flores, Rafael Comanche Peak Nuclear 

Power Plant Letter (ML102990431) 0073 

Flores, Rafael Comanche Peak Nuclear 

Power Plant 

Meeting Transcript 

(ML102850649) 0063-12 

Flores, Rafael Comanche Peak Nuclear 

Power Plant 

Meeting Transcript 

(ML102850689) 0062-5 

Ford, Mike Somervell County 

Commissioner 

Meeting Transcript 

(ML102850649) 0063-9 

Fowler, John Self Email (ML102740518) 0047 

Frick, Terry Self Email (ML102510150) 0005 

Frick, Terry Self Email (ML102510150) 0022 

Fuller, David Self Meeting Transcript 

(ML102850689) 0062-11 

Garner, Todd Granbury Chamber of 

Commerce Letter (ML102740137) 0054 

Garner, Todd Granbury Chamber of 

Commerce 

Meeting Transcript 

(ML102850649) 0063-14 

Geiger, Carol Public Citizen -- Texas 

Office Email (ML103050162) 0067 

Griffin, Dwayne Somervell County Justice 

of the Peace 

Meeting Transcript 

(ML102850689) 0062-4 

Hackett, Ken Self Meeting Transcript 

(ML102850649) 0063-36 

Hadden, Karen 

Sustainable Energy & 

Economic Development 

(SEED) Coalition 

Letter (ML103360219) 0071 
Appendix E 

NUREG-1943 E-6 May 2011 

Table E-1. (contd)

Commenter Affiliation (if stated) Comment Source and 

ADAMS Accession #

Correspondence ID 

Number

Hadden, Karen 

Sustainable Energy & 

Economic Development 

(SEED) Coalition 

Meeting Transcript 

(ML102850649) 0063-30 

Hanna, Jim Self Email (ML102660286) 0033 

Harrison, Jim Texas Commission on 

Environmental Quality Email (ML102600188) 0027 

Higgins, Larry C. Self Letter (ML102740137) 0059 

Hinterleiter, David Self Email (ML102570033) 0023 

Hoodenpyle, Kelly Paluxy River Trading 

Company Letter (ML102740137) 0060 

Huett, David Mallard Pointe Property 

Owners Association Letter (ML102740137) 0058 

Inge, Charles Self Email (ML102980433) 0065 

Inge, Charles Self Letter (ML102980433) 0055 

Jacobson, Jake Self Email (ML102720315) 0045 

Jalbert, Ann Lake Granbury Waterfront 

Owners Association Email (ML102920650) 0051 

Jalbert, Pete Lake Granbury Waterfront 

Owners Association Email (ML102929650) 0051 

Jones, DeeDee Glen Rose Chamber of 

Commerce 

Meeting Transcript 

(ML102850689) 0062-9 

Keffer, James L. District 60, State of Texas Letter (ML102740137) 0057 

Kelly-Elliott, Cathy Self Email (ML102500376) 0005 

Kelly-Elliott, Cathy Self Email (ML102500376) 0021 

King, Arnold Brazos River Conservation 

Coalition Letter (ML102740137) 0055 

Kurtz, Jeff Self Email (ML102660298) 0040 

LaMarca, Jeff Self Meeting Transcript 

(ML102850689) 0062-15 

Lawson, Donny Self Email (ML102660279) 0028 

Leach, Dan Self Email (ML102510789) 0005 

Lowrance, Cleo Self Email (ML102660293) 0038 

Lusty, C.P. Self Email (ML102700594) 0044 

Marks, Gary Glen Rose Medical Center Meeting Transcript 

(ML102850649) 0063-28 

Martin, Joe Self Email (ML102660281) 0030 

Martin, Joe Self Email (ML102660299) 0041 

Martinez, Shirley U.S. Department of the 

Interior Email (ML102980431) 0064 
Appendix E 

May 2011 E-7 NUREG-1943 

Table E-1. (contd)

Commenter Affiliation (if stated) Comment Source and 

ADAMS Accession #

Correspondence ID 

Number

Mayfield, Ron Glen Rose Independent 

School District 

Meeting Transcript 

(ML102850689) 0062-13 

Maynard, Walter Somervell County 

Commissioners Court 

Meeting Transcript 

(ML102850649) 0063-3 

McClain, Janet Self Email (ML102500363) 0006 

McCold, Lance Self Email (ML103120125) 0069 

McHugh, Judy Lake Granbury Waterfront 

Owners Association Email (ML102920650) 0051 

McHugh, Judy Lake Granbury Waterfront 

Owners Association 

Meeting Transcript 

(ML102850689) 0062-6 

McHugh, Judy Self Email (ML102530254) 0019 

McLay, Chandler Self Meeting Transcript 

(ML102850689) 0062-18 

Melinchuk, Ross Texas Parks and Wildlife 

Department Letter (ML103230413) 0068 

Miller, Pam Glen Rose Meeting Transcript 

(ML102850649) 0063-6 

Moore, Jim Self Email (ML102660292) 0037 

Murphy, Bill Mouser Electronics, Inc. Email (ML102500378) 0016 

Murphy, Bill Mouser Electronics, Inc. Email (ML102660291) 0036 

Niemann, Tangela Texas Commission on 

Environmental Quality Email (ML102600188) 0027 

Orcutt, David Lake Granbury Medical 

Center Letter (ML102740137) 0053 

Peralta, Patsy and 

Dan Self Email (ML102660297) 0039 

Petry, Susan Self Email (ML102660280) 0029 

Phillips, Doug Self Email (ML102500371) 0013 

Phillips, Marilyn Somervell School District Meeting Transcript 

(ML102850649) 0063-22 

Pratt, Rickie Mayor of Granbury TX Meeting Transcript 

(ML102850649) 0063-7 

Quirk, Jim Self Letter (ML102740137) 0061 

Quirk, Jim and 

Sharon Self Email (ML102570034) 0024 

Rash, Andy Hood County 

Commissioners Court 

Meeting Transcript 

(ML102850689) 0062-2 

Reed, Cyrus Lone Star Chapter of the 

Sierra Club 

Meeting Transcript 

(ML102850649) 0063-18 

Reed, Cyrus Lone Star Chapter, Sierra 

Club Letter (ML102740137) 0052 
Appendix E 

NUREG-1943 E-8 May 2011 

Table E-1. (contd)

Commenter Affiliation (if stated) Comment Source and 

ADAMS Accession #

Correspondence ID 

Number

Reed, Cyrus Sierra Club, Lone Star 

Chapter Letter (ML103420218) 0066 

Reeder, Dan Self Email (ML102500364) 0007 

Regas, Tori State Representative 

James L. Keffer 

Meeting Transcript 

(ML102850649) 0063-4 

Rhodes, Bill Self Email (ML102500362) 0005 

Roberts, Keith Self Email (ML102590215) 0026 

Robinson, Pennie Self Email (ML102720317) 0046 

Rollins, W.H. Self Email (ML102500370) 0012 

Rooke, Molly Self Meeting Transcript 

(ML102850649) 0063-32 

Rosenfeld, Joshua Brazos River Conservation 

Coalition Email (ML102660300) 0042 

Rosenfeld, Joshua Brazos River Conservation 

Coalition Letter (ML102740137) 0055 

Ross, Jason The Delaware Nation Email (ML102500373) 0014 

Rotan, G. Wayne Glen Rose Independent 

School District Letter (ML102740137) 0056 

Rotan, G. Wayne Glen Rose Independent 

School District 

Meeting Transcript 

(ML102850649) 0063-21 

Slough, Gene and 

Phyllis Self Email (ML102590214) 0025 

Smith, Hugh Somervell County Water 

District 

Meeting Transcript 

(ML102850649) 0063-11 

Smith, Rhonda U.S. Environmental 

Protection Agency Letter (ML103220200) 0070 

Smith, Tom Texas Office of Public 

Citizen 

Meeting Transcript 

(ML102850649) 0063-16 

Spencer, Stephen U.S. Department of the 

Interior Email (ML102980431) 0064 

Stewart, Michael Nuclear Energy for Texas Meeting Transcript 

(ML102850649) 0063-19 

Sumners, Allen Self Meeting Transcript 

(ML102850689) 0062-19 

Sweeney, Lorrie Self Email (ML102660289) 0035 

Taylor, Kevin Somervell County Water 

District 

Meeting Transcript 

(ML102850689) 0062-3 

Thompson, Sue Self Email (ML102500380) 0018 

Tresnicky, Larry and 

Phyllis Self Email (ML102500365) 0008 

Uhlhorn, Ralph Self Email (ML102500358) 0002 
Appendix E 

May 2011 E-9 NUREG-1943 

Table E-1. (contd)

Commenter Affiliation (if stated) Comment Source and 

ADAMS Accession #

Correspondence ID 

Number

Underwood, Sid Self Meeting Transcript 

(ML102850649) 0063-35 

Vaughn, Jane Friends of the Brazos River Meeting Transcript 

(ML102850649) 0063-34 

Veale, James Self Email (ML102700591) 0043 

Wayson, Jacqueline 

and Thomas Self Email (ML102510149) 0005 

Wayson, Thomas Self Email (ML102510152) 0005 

Wicker, Julie Texas Parks and Wildlife 

Dept. Letter (ML103230413) 0068 

Williams, Joe Lake Granbury Waterfront 

Owners Association Email (ML102920650) 0051 

Williams, Joe Save Lake Granbury Meeting Transcript 

(ML102850649) 0063-15 

Williams, Joe Save Lake Granbury Meeting Transcript 

(ML102850689) 0062-12 

Williams, Robert Self Meeting Transcript 

(ML102850689) 0062-14 

Williams, Sue Lake Granbury Waterfront 

Owners Association Email (ML102920650) 0051 

Williams, Sue Lake Granbury Waterfront 

Owners Association 

Meeting Transcript 

(ML102850649) 0063-24 

Williamson, Eileen Self Meeting Transcript 

(ML102850689) 0062-7 

Williamson, Frank Self Meeting Transcript 

(ML102850649) 0063-25 

Williamson, Frank Self Meeting Transcript 

(ML102850689) 0062-16 

Williamson, William 

F. (Frank) and 

Eileen G. 

Self Email (ML102500369) 0011 

Willis, Stephen Self Meeting Transcript 

(ML102850649) 0063-37 

Yancey, Darren Self Meeting Transcript 

(ML102850649) 0063-13 

 
Appendix E 

NUREG-1943 E-10 May 2011 

Table E-2. Commenters and the Categories Associated with Their Respective Comments 

Comment Category Commenter (Comment ID)

Accidents-Severe  Flores, Rafael (0073-8) (0073-9) 

 Hadden, Karen (0063-30-10) (0071-28) (0071-29) 

Alternatives-Energy  Beard, Jim (0063-26-1) (0063-26-3) 

 Boyd, John (0001-6) 

 Eatenson, Linda (0031-1) 

 Geiger, Carol (0067-10) 

 Hadden, Karen (0063-30-3) (0063-30-7) (0063-30-8) (0063-30-11) 

(0071-11) 

 Reed, Cyrus (0052-10) (0052-11) (0052-12) (0052-13) (0052-14) 

(0052-15) (0052-16) (0063-18-9) (0063-18-10) (0066-2) (0066-4) 

(0066-10) (0066-11) (0066-15) 

 Rooke, Molly (0063-32-10) 

 Smith, Tom (0063-16-5) 

Alternatives-Sites  Martin, Joe (0030-3) 

 McCold, Lance (0069-7) 

Alternatives-System 

Design 

 Apple, Thomas (0003-3) 

 Beard, Jim (0063-26-4) 

 Clark, Becky (0005-3) 

 Drager, Judy (0004-2) 

 Edinboro, Sr., Christopher (0015-3) 

 Fitzgerald, C.C. (Fitz) (0017-2) (0034-4) 

 Fowler, John (0047-1) 

 Frick, Terry (0005-3) 

 Hackett, Ken (0063-36-5) 

 Hinterleiter, David (0023-4) 

 Inge, Charles (0055-5) 

 Jacobson, Jake (0045-4) 

 Jalbert, Ann (0051-10) 

 Jalbert, Pete (0051-10) 

 Keffer, James L. (0057-4) 

 Kelly-Elliott, Cathy (0005-3) 

 King, Arnold (0055-5) 

 Leach, Dan (0005-3) 

 Lowrance, Cleo (0038-6) (0038-9) 

 Lusty, C.P. (0044-1) 

 
Appendix E 

May 2011 E-11 NUREG-1943 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Martin, Joe (0041-1) 

 McHugh, Judy (0019-3) (0051-10) 

 Moore, Jim (0037-7) 

 Murphy, Bill (0036-3) 

 Petry, Susan (0029-3) 

 Quirk, Jim and Sharon (0024-3) 

 Regas, Tori (0063-4-4) 

 Rhodes, Bill (0005-3) 

 Rollins, W.H. (0012-1) 

 Rosenfeld, Joshua (0055-5) 

 Smith, Rhonda (0070-6) 

 Sweeney, Lorrie (0035-2) 

 Vaughn, Jane (0063-34-1) 

 Veale, James (0043-2) 

 Wayson, Jacqueline and Thomas (0005-3) 

 Wayson, Thomas (0005-3) 

 Williams, Joe (0051-10) (0062-12-5) 

 Williams, Sue (0051-10) 

 Williamson, Eileen (0062-7-2) 

 Williamson, William F. (Frank) and Eileen G. (0011-4) 

 Yancey, Darren (0063-13-4) 

Benefit-Cost Balance  Benning, Rita (0063-29-8) 

 Fuller, David (0062-11-2) 

 Hackett, Ken (0063-36-9) 

 Hadden, Karen (0071-12) (0071-16) (0071-21) 

 Inge, Charles (0055-9) 

 Jalbert, Ann (0051-13) 

 Jalbert, Pete (0051-13) 

 King, Arnold (0055-9) 

 McHugh, Judy (0051-13) 

 Rosenfeld, Joshua (0055-9) 

 Williams, Joe (0051-13) 

 Williams, Sue (0051-13) 

Ecology-Aquatic  Jalbert, Ann (0051-2) (0051-3) (0051-8) 

 Jalbert, Pete (0051-2) (0051-3) (0051-8) 

 McHugh, Judy (0051-2) (0051-3) (0051-8) 

 Melinchuk, Ross (0068-2) (0068-20) (0068-26) (0068-27) (0068-

28) (0068-29) (0068-30) (0068-46) (0068-47) (0068-56) (0068-57) 
Appendix E 

NUREG-1943 E-12 May 2011 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

(0068-59) (0068-64) (0068-65) 

 Wicker, Julie (0068-2) (0068-20) (0068-26) (0068-27) (0068-28) 

(0068-29) (0068-30) (0068-46) (0068-47) (0068-56) (0068-57) 

(0068-59) (0068-64) (0068-65) 

 Williams, Joe (0051-2) (0051-3) (0051-8) 

 Williams, Sue (0051-2) (0051-3) (0051-8) 

Ecology-Terrestrial  Flores, Rafael (0073-7) 

 Marks, Gary (0063-28-2) 

 Martinez, Shirley (0064-2) (0064-3) (0064-4) (0064-5) (0064-6) 

 Melinchuk, Ross (0068-3) (0068-6) (0068-7) (0068-9) (0068-11) 

(0068-19) (0068-21) (0068-22) (0068-23) (0068-24) (0068-25) 

(0068-37) (0068-40) (0068-41) (0068-42) (0068-43) (0068-44) 

(0068-45) (0068-50) (0068-51) (0068-53) (0068-54) (0068-55) 

(0068-63) 

 Rooke, Molly (0063-32-6) 

 Spencer, Stephen (0064-2) (0064-3) (0064-4) (0064-5) (0064-6) 

 Wicker, Julie (0068-3) (0068-6) (0068-7) (0068-9) (0068-11) 

(0068-19) (0068-21) (0068-22) (0068-23) (0068-24) (0068-25) 

(0068-37) (0068-40) (0068-41) (0068-42) (0068-43) (0068-44) 

(0068-45) (0068-50) (0068-51) (0068-53) (0068-54) (0068-55) 

(0068-63) 

Editorial Comments  Melinchuk, Ross (0068-13) 

 Wicker, Julie (0068-13) 

Environmental Justice  Burnam, Lon (0063-2-1) 

 Hadden, Karen (0071-45) (0071-46) 

 Smith, Rhonda (0070-17) (0070-18) 

Health-Nonradiological  Benning, Rita (0063-29-4) 

Health-Radiological  Benning, Rita (0063-29-2) (0063-29-3) (0063-29-5) (0063-29-6) 

 Hadden, Karen (0063-30-4) (0071-22) (0071-23) (0071-25) (0071-

34) 

 Melinchuk, Ross (0068-38) 

 Smith, Rhonda (0070-2) 

 Wicker, Julie (0068-38) 

Historic and Cultural 

Resources  Ross, Jason (0014-1) 

Hydrology-Groundwater  Flores, Rafael (0073-2) 

 Hadden, Karen (0071-33) (0071-40) 

 Melinchuk, Ross (0068-10) 

 Smith, Rhonda (0070-4) (0070-5) (0070-7) 
Appendix E 

May 2011 E-13 NUREG-1943 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Wicker, Julie (0068-10) 

Hydrology-Surface Water  Answorth, Charles (0063-1-1) 

 Apple, Thomas (0003-1) (0003-2) 

 Barker, M. Blake (0063-31-1) (0063-31-2) (0063-31-3) 

 Benning, Rita (0063-29-1) 

 Bernier, Jim (0048-1) (0048-3) 

 Berry, Steve (0063-10-2) (0063-10-4) 

 Boyd, John (0001-2) (0001-5) 

 Burnam, Lon (0063-5-3) 

 Clark, Becky (0005-1) 

 Conway, Bretta (0063-23-2) (0063-23-3) (0063-23-5) 

 Flores, Rafael (0062-5-2) (0063-12-1) (0073-3) 

 Frick, Terry (0005-1) (0022-1) 

 Fuller, David (0062-11-1) 

 Garner, Todd (0063-14-4) 

 Geiger, Carol (0067-3) (0067-5) 

 Griffin, Dwayne (0062-4-3) 

 Hackett, Ken (0063-36-1) (0063-36-3) (0063-36-4) (0063-36-6) 

 Hadden, Karen (0063-30-2) (0063-30-13) (0071-10) (0071-31) 

(0071-32) (0071-36) (0071-37) 

 Hanna, Jim (0033-2) 

 Harrison, Jim (0027-3) 

 Hinterleiter, David (0023-1) 

 Huett, David (0058-2) (0058-4) 

 Inge, Charles (0055-1) (0055-3) (0055-4) (0055-6) 

 Jacobson, Jake (0045-1) 

 Jalbert, Ann (0051-1) (0051-4) (0051-6) (0051-7) (0051-9) (0051-

12) 

 Jalbert, Pete (0051-1) (0051-4) (0051-6) (0051-7) (0051-9) (0051-

12) 

 Keffer, James L. (0057-1) (0057-3) 

 Kelly-Elliott, Cathy (0005-1) 

 King, Arnold (0055-1) (0055-3) (0055-4) (0055-6) 

 Lawson, Donny (0028-1) 

 Leach, Dan (0005-1) 

 Lowrance, Cleo (0038-1) (0038-3) 

 McClain, Janet (0006-1) (0006-4) 

 McHugh, Judy (0019-5) (0051-1) (0051-4) (0051-6) (0051-7) 

(0051-9) (0051-12) (0062-6-2) 
Appendix E 

NUREG-1943 E-14 May 2011 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Melinchuk, Ross (0068-15) (0068-17) (0068-35) (0068-48) (0068-

49) (0068-62) (0068-66) 

 Moore, Jim (0037-5) 

 Murphy, Bill (0016-2) 

 Niemann, Tangela (0027-3) 

 Orcutt, David (0053-3) 

 Peralta, Patsy and Dan (0039-1) 

 Petry, Susan (0029-1) 

 Phillips, Doug (0013-1) (0013-2) 

 Pratt, Rickie (0063-7-3) (0063-7-6) (0063-7-7) 

 Quirk, Jim (0061-1) 

 Regas, Tori (0063-4-1) (0063-4-3) 

 Rhodes, Bill (0005-1) 

 Robinson, Pennie (0046-2) 

 Rooke, Molly (0063-32-2) 

 Rosenfeld, Joshua (0042-1) (0055-1) (0055-3) (0055-4) (0055-6) 

 Slough, Gene and Phyllis (0025-1) (0025-2) 

 Smith, Rhonda (0070-3) (0070-8) (0070-9) (0070-10) (0070-11) 

(0070-12) (0070-14) (0070-15) 

 Smith, Tom (0063-16-2) (0063-16-3) 

 Stewart, Michael (0063-19-2) 

 Thompson, Sue (0018-1) 

 Uhlhorn, Ralph (0002-1) 

 Veale, James (0043-1) 

 Wayson, Jacqueline and Thomas (0005-1) 

 Wayson, Thomas (0005-1) 

 Wicker, Julie (0068-15) (0068-17) (0068-35) (0068-48) (0068-49) 

(0068-62) (0068-66) 

 Williams, Joe (0051-1) (0051-4) (0051-6) (0051-7) (0051-9) (0051-

12) (0062-12-1) (0062-12-2) (0062-12-3) (0062-12-4) (0063-15-2) 

(0063-15-3) (0063-15-4) (0063-15-5) (0063-15-6) (0063-15-7) 

(0063-15-8) (0063-15-9) (0063-15-10) 

 Williams, Robert (0062-14-1) (0062-14-2) (0062-14-3) (0062-14-4) 

 Williams, Sue (0051-1) (0051-4) (0051-6) (0051-7) (0051-9) 

(0051-12) (0063-24-1) (0063-24-2) (0063-24-3) 

 Williamson, Frank (0062-16-1) (0062-16-2) (0062-16-3) (0063-25-

1) (0063-25-2) (0063-25-3) (0063-25-5) 

 Williamson, William F. (Frank) and Eileen G. (0011-2) (0011-3) 

 Yancey, Darren (0063-13-1) (0063-13-2) (0063-13-3) 

Land Use-Site and Vicinity  Flores, Rafael (0073-6) 
Appendix E 

May 2011 E-15 NUREG-1943 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Land Use-Transmission 

Lines  Condy, Ymke (0062-1-1) 

 Hadden, Karen (0071-43) 

 Melinchuk, Ross (0068-16) (0068-39) 

 Wicker, Julie (0068-16) (0068-39) 

Meteorology and Air 

Quality  Harrison, Jim (0027-1) 

 Niemann, Tangela (0027-1) 

 Smith, Tom (0063-16-1) 

Need for Power  Burnam, Lon (0063-5-2) 

 Geiger, Carol (0067-6) 

 Hadden, Karen (0063-30-12) (0071-14) (0071-15) (0071-39) 

 Reed, Cyrus (0052-1) (0052-3) (0052-4) (0052-5) (0052-6) (0052-

7) (0052-8) (0052-9) (0063-18-1) (0063-18-2) (0063-18-3) (0063-

18-4) (0063-18-5) (0063-18-6) (0063-18-7) (0063-18-8) (0066-1) 

(0066-3) (0066-5) (0066-6) (0066-7) (0066-8) (0066-9) (0066-12) 

(0066-13) (0066-14) 

 Rooke, Molly (0063-32-11) 

Opposition-Licensing 

Action  Boyd, John (0001-1) (0001-3) (0001-4) (0001-7) 

 Clark, Becky (0020-1) 

 Edinboro, Sr., Christopher (0015-2) 

 Fitzgerald, C.C. (Fitz) (0017-1) (0034-2) 

 Hanna, Jim (0033-1) 

 Hadden, Karen (0071-27) 

 Hinterleiter, David (0023-3) 

 Kurtz, Jeff (0040-1) 

 Martin, Joe (0030-2) (0041-2) 

 McHugh, Judy (0019-2) (0019-4) 

 Moore, Jim (0037-3) 

 Murphy, Bill (0016-1) (0016-3) 

 Petry, Susan (0029-2) 

 Quirk, Jim and Sharon (0024-1) 

 Williamson, Eileen (0062-7-1) 

 Williamson, William F. (Frank) and Eileen G. (0011-1) 

Opposition-Licensing 

Process  Hackett, Ken (0063-36-10) 

Opposition-Nuclear Power  Hadden, Karen (0063-30-1) (0071-9) (0071-17) (0071-19) 

Outside ScopeEmergency Preparedness  Hackett, Ken (0063-36-8) 

 Hadden, Karen (0071-38) 
Appendix E 

NUREG-1943 E-16 May 2011 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Inge, Charles (0055-8) 

 King, Arnold (0055-8) 

 Rosenfeld, Joshua (0055-8) 

Outside ScopeMiscellaneous  Jalbert, Ann (0051-5) 

 Jalbert, Pete (0051-5) 

 McClain, Janet (0006-3) 

 McHugh, Judy (0051-5) 

 Pratt, Rickie (0063-7-5) 

 Roberts, Keith (0026-1) 

 Williams, Joe (0051-5) 

 Williams, Sue (0051-5) 

Outside Scope-Safety  Benning, Rita (0063-29-7) 

 Geiger, Carol (0067-1) (0067-2) (0067-4) (0067-7) (0067-8) 

(0067-9) 

 Hadden, Karen (0071-35) (0071-48) 

 Smith, Tom (0063-16-4) 

Outside Scope-Security 

and Terrorism  Hadden, Karen (0063-30-5) (0071-26) (0071-30) 

 Rooke, Molly (0063-32-7) 

Process-COL  Burnam, Lon (0063-5-1) (0063-5-6) 

 Conway, Bretta (0063-23-1) 

 Ferrero, Phil and Tracey (0032-2) 

 Flores, Rafael (0073-1) 

 Ford, Mike (0063-9-1) 

 Hadden, Karen (0071-3) (0071-4) (0071-5) (0071-6) (0071-7) 

(0071-8) (0071-13) (0071-20) (0071-44) 

 Harrison, Jim (0027-2) 

 Keffer, James L. (0057-5) 

 McHugh, Judy (0062-6-1) (0019-1) 

 Melinchuk, Ross (0068-5) (0068-14) (0068-34) 

 Niemann, Tangela (0027-2) 

 Regas, Tori (0063-4-5) 

 Smith, Hugh (0063-11-3) 

 Sumners, Allen (0062-19-3) 

 Wicker, Julie (0068-5) (0068-14) (0068-34) 

 Williams, Robert (0062-14-6) 

 Willis, Stephen (0063-37-2) 

Process-NEPA  Hadden, Karen (0071-1) (0071-2) 
Appendix E 

May 2011 E-17 NUREG-1943 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Harrison, Jim (0027-4) 

 Martinez, Shirley (0064-1) 

 Melinchuk, Ross (0068-1) 

 Niemann, Tangela (0027-4) 

 Ross, Jason (0014-2) 

 Smith, Rhonda (0070-1) 

 Spencer, Stephen (0064-1) 

 Wicker, Julie (0068-1) 

Site Layout and Design  Flores, Rafael (0073-4) (0073-5) 

 Hackett, Ken (0063-36-2) 

 Inge, Charles (0055-2) 

 King, Arnold (0055-2) 

 McCold, Lance (0069-1) (0069-2) (0069-3) (0069-4) (0069-6) 

 Melinchuk, Ross (0068-33) (0068-36) (0068-52) 

 Rosenfeld, Joshua (0055-2) 

 Smith, Rhonda (0070-6) 

 Wicker, Julie (0068-33) (0068-36) (0068-52) 

Socioeconomics  Apple, Thomas (0003-4) 

 Bernier, Jim (0048-2) 

 Berry, Steve (0063-10-1) (0063-10-3) 

 Clark, Becky (0005-2) 

 Drager, Judy (0004-1) 

 Ferrero, Phil and Tracey (0032-1) 

 Fitzgerald, C.C. (Fitz) (0017-3) (0034-3) 

 Frick, Terry (0005-2) (0022-2) 

 Garner, Todd (0054-2) (0063-14-2) 

 Hadden, Karen (0063-30-9) (0071-41) 

 Hanna, Jim (0033-3) 

 Hinterleiter, David (0023-2) 

 Huett, David (0058-1) (0058-2) (0058-3) (0058-5) 

 Jacobson, Jake (0045-2) (0045-3) 

 Jalbert, Ann (0051-11) 

 Jalbert, Pete (0051-11) 

 Keffer, James L. (0057-2) 

 Kelly-Elliott, Cathy (0005-2) (0021-1) 

 Leach, Dan (0005-2) 

 Lowrance, Cleo (0038-2) (0038-4) (0038-5) (0038-7) (0038-10) 

 Martin, Joe (0030-1) 
Appendix E 

NUREG-1943 E-18 May 2011 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Mayfield, Ron (0062-13-2) 

 McHugh, Judy (0051-11) 

 Melinchuk, Ross (0068-4) (0068-8) (0068-12) (0068-18) (0068-31) 

(0068-32) (0068-60) 

 Moore, Jim (0037-4) (0037-6) 

 Murphy, Bill (0036-1) 

 Quirk, Jim and Sharon (0024-2) 

 Reeder, Dan (0007-1) 

 Regas, Tori (0063-4-2) 

 Rhodes, Bill (0005-2) 

 Slough, Gene and Phyllis (0025-3) 

 Smith, Rhonda (0070-13) (0070-16) (0070-19) 

 Thompson, Sue (0018-2) 

 Tresnicky, Larry and Phyllis (0008-1) (0008-2) 

 Wayson, Jacqueline and Thomas (0005-2) 

 Wayson, Thomas (0005-2) 

 Wicker, Julie (0068-4) (0068-8) (0068-12) (0068-18) (0068-31) 

(0068-32) (0068-60) 

 Williams, Joe (0051-11) 

 Williams, Robert (0062-14-5) 

 Williams, Sue (0051-11) 

 Williamson, Eileen (0062-7-3) 

 Williamson, Frank (0062-16-4) (0062-16-5) (0062-16-6) (0063-25-

4) 

Support-Licensing Action  Barnard, James (0063-8-1) (0063-8-3) 

 Best, Darrell (0063-17-1) (0063-17-3) 

 Bradley, Scott (0062-17-1) 

 Condy, Pat (0062-10-2) 

 Condy, Ymke (0062-8-1) 

 Dooley, Mike (0063-27-1) 

 English, Maurice (0063-38-1) (0063-38-2) 

 Garner, Todd (0054-1) (0063-14-1) 

 Griffin, Dwayne (0062-4-2) (0062-4-4) 

 Higgins, Larry C. (0059-2) 

 Hoodenpyle, Kelly (0060-1) 

 Jones, DeeDee (0062-9-3) 

 Lowrance, Cleo (0038-8) 

 Mayfield, Ron (0062-13-3) 

 Miller, Pam (0063-6-2) 
Appendix E 

May 2011 E-19 NUREG-1943 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Moore, Jim (0037-2) 

 Orcutt, David (0053-1) 

 Phillips, Marilyn (0063-22-3) 

 Pratt, Rickie (0063-7-1) 

 Rash, Andy (0062-2-2) 

 Robinson, Pennie (0046-1) 

 Rotan, G. Wayne (0056-1) (0056-2) (0063-21-2) (0063-21-4) 

 Smith, Hugh (0063-11-1) (0063-11-5) 

 Stewart, Michael (0063-19-1) 

 Sumners, Allen (0062-19-4) 

 Taylor, Kevin (0062-3-1) (0062-3-3) 

 Underwood, Sid (0063-35-3) 

 Williams, Joe (0063-15-1) 

Support-Nuclear Power  Beard, Jim (0063-26-2) 

 Edinboro, Sr., Christopher (0015-1) 

 Flores, Rafael (0062-5-1) 

 Jones, DeeDee (0062-9-2) 

 Moore, Jim (0037-1) 

 Orcutt, David (0053-2) (0053-4) 

 Pratt, Rickie (0063-7-2) 

 Smith, Hugh (0063-11-4) 

 Underwood, Sid (0063-35-1) 

Support-Plant  Barnard, James (0063-8-2) 

 Bellu, Toni (0063-20-1) 

 Best, Darrell (0063-17-2) 

 Condy, Pat (0062-10-1) 

 Conway, Bretta (0063-23-4) 

 Curtis, John (0063-33-1) 

 Griffin, Dwayne (0062-4-1) 

 Higgins, Larry C. (0059-1) 

 Jones, DeeDee (0062-9-1) 

 LaMarca, Jeff (0062-15-1) 

 Marks, Gary (0063-28-1) 

 Mayfield, Ron (0062-13-1) 

 Maynard, Walter (0063-3-1) 

 McLay, Chandler (0062-18-1) 

 Miller, Pam (0063-6-1) 

 Phillips, Marilyn (0063-22-1) (0063-22-2) 
Appendix E 

NUREG-1943 E-20 May 2011 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Rash, Andy (0062-2-1) 

 Rotan, G. Wayne (0063-21-1) (0063-21-3) 

 Smith, Hugh (0063-11-2) 

 Sumners, Allen (0062-19-1) (0062-19-2) 

 Taylor, Kevin (0062-3-2) 

 Underwood, Sid (0063-35-2) 

 Willis, Stephen (0063-37-1) 

Transportation  Burnam, Lon (0063-5-5) 

Uranium Fuel Cycle  Burnam, Lon (0063-5-4a) (0063-5-4b) (0063-5-7) (0063-5-8) 

 Hackett, Ken (0063-36-7) 

 Hadden, Karen (0071-24) (0071-25) (0071-47) 

 Inge, Charles (0055-7) 

 King, Arnold (0055-7) 

 Melinchuk, Ross (0068-61) 

 Reed, Cyrus (0063-18-11) 

 Rooke, Molly (0063-32-3) (0063-32-4) (0063-32-5) (0063-32-8) 

(0063-32-9) 

 Rosenfeld, Joshua (0055-7) 

 Wicker, Julie (0068-61) 
Appendix E 

May 2011 E-21 NUREG-1943 

E.2 Comments and Responses 

E.2.1 Comments Concerning Process – COL 

Comment: [The Texas Commission on Environmental Quality (TCEQ) has reviewed the 

above-referenced project and offers following comments:] We do not anticipate significant long 

term environmental impacts from this project as long as construction and waste disposal 

activities associated with it are completed in accordance with applicable local, state, and federal 

environmental permits and regulations. (0027-2 [Harrison, Jim] [Niemann, Tangela])

Response: In developing the EIS, the review team interacted with Federal and State agencies 

to obtain information relevant to the environmental review. The review team specifically 

solicited comments from the Texas Commission on Environmental Quality (TCEQ). The NRC 

appreciates the comments offered by the TCEQ. Before building and operating new units, 

Luminant is required to obtain certain Federal, State, and local environmental permits, as well 

as meet applicable statutory and regulatory requirements. The list of such authorizations, 

permits, and certifications relevant to the proposed Comanche Peak Units 3 and 4 is included in 

Appendix H of this EIS. 

Comment: And to the members of the NRC who are here -- and we constantly have the 

nuclear -- the US Nuclear Regulatory presence there, and I think when you look at any agency 

in government, state level, and especially federal level, there's a lot of agencies that I don't feel 

real comfortable with, but I do have a lot of faith in the NRC. I'd ask you to please continue on 

doing that. (0062-19-3 [Sumners, Allen])

Comment: I have also seen how the Nuclear Regulatory Commission holds very strict 

guidelines to the utility and makes sure that they're following those. I believe that the Nuclear 

Regulatory Commission has done their part to make sure that they're looking at everything. 

And that's what this hearing is about today. They're doing their part to hear the community and 

to make sure that all the issues are addressed. (0063-37-2 [Willis, Stephen])

Response: These comments express support for and/or confidence in the NRC and the 

process by which it reviews license applications for new nuclear power generating units. 

Because these comments did not provide new and significant information about environmental 

impacts no changes were made to the EIS as the result of these comments. 

Comment: I know that you will take the concerns and suggestions of the citizens of Hood 

County seriously and professionally. I sincerely appreciate your consideration, and I would be 

happy to further discuss these issues with you personally. (0057-5 [Keffer, James L.])

Comment: Please don't make this meeting just a check on the board; please take our 

comments seriously. (0062-14-6 [Williams, Robert])

Comment: You, the Nuclear Regulatory Commission, have indicated that public sentiment is 

critical and crucial to your decisions. I certainly hope you mean that. (0062-6-1 [McHugh, Judy])

Comment: I know that you will take the concerns and suggestions of the citizens of Hood 

County seriously and professionally. (0063-4-5 [Regas, Tori])

Comment: What I would want to say is, all due respect to others who think otherwise, I look at 

this as a local issue. And by local I mean Somervell and Hood County. We are the folks that 

are directly affected. And one of the things that I watched at the last hearing was how much 

attention was being paid to those either for or against the COL from this county and the 

information that they were providing. I watched and read through the document that we just 
Appendix E 

NUREG-1943 E-22 May 2011 

received to be sure that there was attention paid to those issues that were raised at that point in 

time. 

It occurred to me this summer as we were choking on the emissions that come from the 

Metroplex that we're not even invited to sit down at the table when that kind of stuff occurs 

there. And yet, we're -- it's -- and I understand the reason that we do invite everybody to 

participate in this process. But I would want to stress to the NRC and I hope you will, as you 

consider all of the information that you have to consider in order to determine the COL that 

special attention and most attention be paid to those comments and those concerns of local 

citizens who are going to live with this. I do believe that that is -- that's been missed in all of 

this. And I -- and my recommendation to you is that you pay specific and special attention to 

those concerns locally. (0063-9-1 [Ford, Mike]) 

Comment: It is my understanding that the NRC uses public sentiment in making decisions 

about nuclear projects. Good for you and I hope you mean it! (0019-1 [McHugh, Judy])

Comment: Please consider the comments, requests and ideas of those of us who live, work 

and play on Lake Granbury before granting Luminant it's request. Indeed, Luminant has already 

begun purchasing full page newspaper advertisements to support its position. Individuals like us 

can only compete with their kind of financial and political power by appealing to those who we 

hope will protect the interests of the public, not the just the corporations and lobbyists. We 

appeal to you. (0032-2 [Ferrero, Phil and Tracey])

Response: These comments request that public input be considered seriously by the NRC in 

its licensing decision. The licensing process for COL applications is specified in Title 10 of the 

Code of Federal Regulations (CFR) Part 52. The review team will make a recommendation to 

the Commission based on the Environmental Report submitted by the Applicant; consultation 

with Federal, State, Tribal and local agencies; the staff's independent review; public comments; 

and the assessments summarized in the EIS and in the Safety Evaluation Report. Certainly, the 

factual information offered by the public who live in the region around the site is important to the 

NRC. However, all comments received by the public on the Draft EIS are on display and are 

addressed in Appendix E of this EIS. Because no new or significant information about 

environmental impacts was offered in the comment, no changes were made to the EIS as the 

result of these comments. 

Comment: As stated in previous [Texas Parks and Wildlife Department] TPWD comments, this 

project is a federal action, and would therefore be subject to NEPA requirements. Although the 

[Certificate of Convenience and Necessity] CCN process is not always subject to NEPA, the 

transmission lines associated with the CPNPP would be associated with a federally-regulated 

project and would therefore have a federal nexus. As stated previously, to not fully address the 

direct impacts of the proposed transmission line corridors in the final EIS could appear to be 

“segmenting” by attempting to address the impacts of these transmission corridors under the 

CCN process. An analysis of alternative routes and a preferred route for each proposed new 

transmission line should be identified for the EIS. (0068-34 [Melinchuk, Ross] [Wicker, Julie]) 

Comment: The NRC defines construction as those activities within its regulatory authority. 

NRC indicates activities associated with the project that are not within the purview of the NRC 

action to license Units 3 and 4 are grouped under the term preconstruction and include clearing 

and grading, excavating, erection of support buildings and transmission lines, and other 

associated activities. The NRC does not consider the preconstruction activities as direct impacts 

from the proposed action and has evaluated preconstruction activities in the cumulative impacts 

analysis. 
Appendix E 

May 2011 E-23 NUREG-1943 

Recommendation: TPWD does not agree with NRC’s decision regarding the exclusion of 

preconstruction activities from the proposed action. TPWD finds the scope as defined by NRC 

to be too narrow to meet the requirements and intent of NEPA regulations. Under Council on 

Environmental Quality regulations, Section 1502.4, (a) Agencies shall make sure the proposal 

which is the subject of the environmental impact statement (EIS) is properly defined Agencies 

shall use the criteria for scope (Section1508.25). 

Section 1508.25 clarifies the Scope criteria to include connected actions, defined in part as (ii) 

Cannot or will not proceed unless other actions are taken previously or simultaneously; (iii) Are 

interdependent parts of a larger action and depend on the larger action for their justification 

TPWD recommends the scope of the DEIS be revised to include the preconstruction activities. 

Activities such as clearing, grading, excavating, and erection of support buildings and 

transmission lines, and other associated activities are necessary to build, operate and maintain 

the nuclear reactor. These preconstruction activities are an integral part of the larger action and 

should be under the scope of the DEIS. (0068-14 [Melinchuk, Ross] [Wicker, Julie]) 

Comment: Proposed new location 345-kY transmission line routes have not been fully 

assessed through a routing and alternatives evaluation, thus impacts associated with the 

proposed new lines are not fully articulated. Without an assessment of routes and their 

alternatives for inclusion in the DEIS, the NRC may be segmenting project impacts under 

Section 1508.27 (7) of NEPA. This section states, Significance [of impacts] cannot be avoided 

by terming an action temporary or by breaking it down into small component parts. (0068-5

[Melinchuk, Ross] [Wicker, Julie]) 

Response: These comments refer to the NRC's definition of "construction" based on its 

regulatory authority. As authorized by the Atomic Energy Act of 1954, as amended, NRC is 

charged with protecting the public health and safety with regard to the civilian use of nuclear 

material. CEQ’s environmental protection regulations at 40 CFR 1500-1508 are available to 

those Federal agencies that have not established their own procedures for complying with the 

National Environmental Policy Act. NRC’s environmental protection regulations are located at 

10 CFR Part 51; its regulations are subject to public participation prior to becoming effective 

(see, for example, 72 FR 57416-57447). As defined in 10 CFR 51.4, construction refers to 

building safety-related structures, systems or components (SSCs) necessary for power plant 

construction. Construction also includes SSCs required to provide physical protection and 

onsite emergency planning. Activities such as clearing and grading; excavating; building 

transmission lines; and erecting support buildings that are not required for nuclear safety, 

physical protection, or emergency planning, are now considered “preconstruction” activities. For 

NRC regulatory purposes, construction authorization for the facility does not include 

preconstruction activities such as site preparation, excavation, and transmission line routing 

(see 10 CFR 51.4). Most of these activities are regulated by other agencies and require permits 

to proceed. For example, the Public Utility Commission of Texas will conduct its own 

environmental review and make recommendations for the issuance of the Certificate of 

Convenience and Necessity to construct the new transmission lines. In this EIS, the review 

team has independently evaluated the proposed routes for these new lines (see Figure 2-13) 

and has assessed the direct environmental impacts associated with them. The review team 

believes the analyses contained in Chapters 4 and 5 of this EIS in regard to the new 

transmission lines adequately address the concerns identified in the comments. Additionally, 

the environmental effects of preconstruction activities are considered in the cumulative impacts 

evaluation for the proposed project in Chapter 7 and for the alternative sites in Chapter 9; 

consequently, this is not considered segmentation. No changes were made to the EIS as a 

result of this comment. 
Appendix E 

NUREG-1943 E-24 May 2011 

Comment: Consider the following excerpted portion of the DEIS (Volume 2, page D-20) and 

the response that was provided: 

D.2. Comments Concerning Land Use - Transmission Lines 

Comment: What land will need to be condemned or purchased in order to build 

or upgrade new transmission lines? What environmental and economic impacts 

will result from new transmission lines, including the 345 kV line planned to go 

between the plant site and the Whitney Switch, going through much of Somervell 

and Bosque Counties? (0019-24 [Hadden, Karen])

Response: Environmental impacts associated with any planned new 

transmission rights-of way will be addressed in Chapters 4 and 5 of the EIS, as 

will potential impacts associated with any upgrades to existing lines or corridors. 

The applicant is required to follow all Federal, State, and local guidelines 

concerning siting, construction, and maintenance of proposed transmission 

corridors and lines, although the NRC does not have regulatory authority over 

these activities. 

This answer contains no meaningful or useful information whatsoever. It is only one example 

which constitutes a refusal to answer the question. (0071-6 [Hadden, Karen])

Comment: We prepared detailed comments and questions at this time despite the fact that our 

first notice of the upcoming scoping hearing was by a phone call to a Public Citizen staff 

member on Christmas Eve. SEED Coalition Executive Director Karen Hadden received word 

through a phone call from the staff member while at the hospital with her sick mother, and never 

received any written notice, despite having requested previously to be on the notification list. 

Now, with over a year and a half in which to address the many SEED Coalition concerns, it is 

most disappointing to see an inadequate response stating that a question will be addressed in 

the EIS. A real response is now long overdue. (0071-7 [Hadden, Karen]) 

Response: The first comment above, and its embedded response, was received during the 

scoping period for this EIS. The scoping process conducted during the earliest stages of the 

review is an important step in the development of an EIS; that process included the public 

scoping meeting in January 2009. The review team benefits from this process in revealing 

issues of interest so that the scope of the review is informed by the public. After the scoping 

period ended, the review team determined which comments and issues were within the scope of 

the environmental review and issued a Scoping Summary Report. The Report is not intended to 

resolve the comments or issues; those that are within the scope of the review are included in 

Appendix D of this EIS, so that the public can track how it contributed to the scope of the 

environmental review and how the review team accounted for the comments and issues raised. 

Land use as mentioned in the comment is addressed in Chapters 4 and 5 of the EIS as 

indicated in the response to the comment in Appendix D of the EIS. No changes were made to 

the EIS as a result of this comment. 

Comment: SEED Coalition is raising some new questions and concerns, but is resubmitting 

many concerns raised previously because the responses given in the DEIS are inadequate, 

typically reflecting only a cursory look at very serious concerns and questions. The nature of 

many of the responses is broad and generic. Vague answers have been provided to very 

specific questions. (0071-3 [Hadden, Karen])

Comment: The lack of an honest attempt to thoughtfully review, analyze and/or rebut the 

comments submitted demonstrates an example of why few citizens have any faith in the nuclear 
Appendix E 

May 2011 E-25 NUREG-1943 

licensing process or even attempt to participate in the NRCs supposed opportunities for public 

involvement. Based on the replies in the DEIS, a thinking individual might ask. What exactly is 

the point of submitting comments?(0071-4 [Hadden, Karen])

Comment: We request real responses and real data be provided in a timely manner, which 

means long before the issuance of the final EIS, which to our understanding is scheduled for 

January 2011. (0071-5 [Hadden, Karen])

Response: The NRC staff prepared this EIS in accordance with the requirements of NEPA, 10 

CFR Part 52, and 10 CFR Part 51. In its review, the NRC staff and the Corps (review team) 

focused on the environmental effects of construction and operation of a new reactor. The 

team’s review was based on information presented in the COL application environmental report 

(ER) submitted by the applicant and information obtained from independent sources. Data and 

analyses in the EIS are to be commensurate with the importance of the impact, with less 

important material summarized, consolidated, or simply referenced. The level of information on 

the environmental consequences of the action (and mitigative opportunities to reduce impacts) 

and each alternative to the action considered in detail is to reflect the depth of analysis required 

for sound decisionmaking. The EIS is not intended to be encyclopedic; it is intended to be a 

sound basis for making decisions. In the draft EIS, the review team believes that it has been 

responsive to all of the comments offered during the scoping period by conducting its 

independent evaluation and performing independent analyses, when necessary, consistent with 

the importance of the impacts. The public input and comments received, whether during the 

scoping period or during the 75-day comment period on the Draft EIS, are an important part of 

the NRC's environmental review process, and it is the staff's intent to adequately address all 

comments that fall within the scope of the environmental review. The responses to comments 

received on the Draft EIS appear in Appendix E of this EIS. 

Comment: The public hearing on the DEIS was equally appalling. SEED Coalition, 

represented by Karen Hadden, asked questions about the Lake Granbury water levels impacts 

that would result from Comanche Peak 3 & 4, and where in the DEIS this issue was addressed. 

The question was brushed off brusquely, and no answer was provided regarding these impacts. 

Why is it that no one could answer the question or that no one bothered to get back to me with a 

real response, including actual anticipated measurements and numbers related to lake water 

levels? (0071-8 [Hadden, Karen]) 

Response: The purposes for meetings that the review team holds in the vicinity of the nuclear 

power plant sites include affording the public an additional opportunity to share its comments on 

the Draft EIS. The conduct of the meeting is established by ground rules described by the 

facilitator at the outset to ensure that the entire audience has a productive meeting. The brief 

"question and answer (Q&A)" period provided after the review team’s presentation of the 

content of the EIS is to assist the audience in understanding the remaining stages of the review 

and the format for the public’s portion of the meeting. As part of this meeting process, the 

review team holds an informal “Open House” to assist interested members of the public, who 

arrive before the appointed meeting starting time, with the navigation of the EIS. At the 

conclusion of each meeting, the review team members are available to follow up with 

commenters on those areas that were not clear to them. The Q&A period is specifically not 

intended to provide a tutorial on one or more technical issues, nor is it intended to serve as the 

forum for detailed or in-depth responses. In response to the specific concern raised in this 

comment, water levels in Lake Granbury are addressed in Section 5.2.2.1 of this EIS. No 

changes were made to the EIS as a result of this comment. 

Comment: Luminant's review of the Draft Environmental Impact Statement (DEIS) found the 

DEIS to be a conservative, bounding assessment of the potential environmental impacts of 
Appendix E 

NUREG-1943 E-26 May 2011 

CPNPP Units 3 and 4. Many of the impacts in the DEIS, if not most of them, would never occur 

to the extent discussed in the DEIS. As a result, some impacts determined by Luminant to be 

SMALL in the Environmental Report (ER) were found by the NRC to be SMALL to MODERATE 

in the DEIS. This is not inconsistent, rather a reflection of the very conservative assessment 

performed by the NRC in reviewing the ER. The impacts stated in the DEIS are not expected to 

occur, but conservatively bound the impacts that might potentially be expected. (0073-1 [Flores, 

Rafael]) 

Response: The comments regarding the determination of impact levels in the DEIS is noted. 

The findings and conclusions in the DEIS represent the review team's independent assessment, 

and as such may differ from what was presented in the Applicant's Environmental Report. No 

changes were made to the EIS as a result of this comment. 

Comment: What environmental and economic impacts will result from new transmission lines, 

including the 345 kV line planned to go between the plant site and the Whitney Switch, going 

through much of Somervell and Bosque Counties? (0071-44 [Hadden, Karen])

Response: The environmental impacts of the new transmission lines are discussed primarily in 

Chapter 4 and are included in the assessments for each resource category. For example, 

Section 4.1.2 discusses the land use impacts, and Sections 4.3.1.2 and 4.3.2.2 discuss the 

impacts to ecological resources. In regard to the economic impacts of the new transmission 

lines, the cost of installing and maintaining such lines is beyond the scope of this EIS. No 

changes were made to the EIS as a result of this comment. 

Comment: The US-APWR reactors proposed by Luminant are a design that is not approved by 

the Nuclear Regulatory Commission and has never been built anywhere in the world. Why 

should Texans be the guinea pigs for a radioactive experiment? The reactor design isn’t even 

scheduled to be approved until shortly before the license is to be granted. Citizens won’t have 

the benefit of the NRC analysis of the design, while the licensing process speeds forward. 

The Environmental Impact Statement should stress the need for a complete and approved 

design before any further steps are taken in the licensing process. Human and environmental 

health are at risk due to this major fast-tracking of nuclear reactor licensing. The design should 

be submitted and not approved until deemed adequate, then construction licensing should be 

considered, followed by consideration of an operating license, but all three processes are 

occurring simultaneously in a rush to get plants licensed. Health, safety and economic 

concerns are being put on the back burner, while Luminant and other utilities greedily reach for 

loan guarantees, a subsidy that ratepayers will pay for in the end with higher electric bills. 

(0071-20 [Hadden, Karen]) 

Comment: There is an added level of risk for delays and construction problems with 

Comanche Peak 3 & 4 since the US-APWR reactor design has never been built anywhere in the 

world. To the best of our knowledge, the reactor design is still under review by the NRC. (0071-

13 [Hadden, Karen])

Response: The NRC's COL licensing process provides for the simultaneous review of the 

design, the safety review, and the environmental review. Title 10, Part 52, of the Code of 

Federal Regulations (CFR) provides flexibility for a prospective applicant to decide how it would 

seek regulatory approval to construct and operate a nuclear power plant. Part 52 has several 

important features that can be addressed independently or in combination with each other. In 

promulgating Part 52, the NRC did consider public comments before finalizing the rule or 

amendments to the rule. One feature, 52.55(c), allows a COL applicant, at its own risk, to 

reference a design that is under review by the NRC but not yet certified. The U.S. APWR 

reactor design is one such design currently under review. However, a COL referencing a 
Appendix E 

May 2011 E-27 NUREG-1943 

particular design cannot be issued by the NRC until the reactor design is certified by the 

NRC. Applicants select a reactor technology based on their own business criteria. The Design 

Certification Documentation for the US-APWR Reactor proposed for the Comanche Peak Units 

3 and 4 was submitted to NRC in December 2007. The NRC staff is currently conducting a 

detailed review of that design. The documentation submitted with the application for US-APWR 

design certification provided sufficient details to evaluate issues relevant to this EIS. As allowed 

by 10 CFR 52.55(c), applicants are allowed, at their own risk, to reference a design certification 

application that has been docketed but not granted. If substantive changes to the design are 

made as a result of the NRC's certification review, those changes will be evaluated to determine 

whether a supplement to the EIS will be needed. The NRC's COL licensing process provides 

for the simultaneous review of the design, the safety review, and the environmental review. 

However, if the U.S. APWR does not receive certification in the timeframe sought by the 

applicant, Luminant then would have to determine whether it would proceed with a different 

reactor technology. A change in reactor technology would need to be considered by the NRC to 

determine whether the change would be significant in terms of the environmental impacts of 

construction or operation. No changes were made to the EIS as a result of this comment. 

Comment: I am state representative from Fort Worth. I anticipate going into my eighth session 

representing an inner-city district which is predominantly low to moderate income. And it is the 

closest predominant low to moderate income legislative district to the proposed site in the state. 

And we have largely been left out of the process. So the first point I want to register is a 

complaint, a violation of fundamental EIS principals of who gets to participate. As a practical 

matter my low-income constituents in inner-city Fort Worth can't make it out to Glen Rose in the 

middle of the afternoon to participate in this hearing. (0063-5-1 [Burnam, Lon])

Comment: [The transportation of radioactive waste through the region] that is one of the 

primary reasons we have a right to have a public hearing in Tarrant, Dallas County at night 

when people can get there and can talk about that. (0063-5-6 [Burnam, Lon])

Response: In regard to the locations of the public meetings, the NRC typically schedules 

public meetings in the county in which the proposed licensing action would occur. The NRC 

also provides advanced public notice for all interested parties to participate in those 

meetings. Regardless of whether a personal appearance is made at such meetings, the NRC 

notices also provide instructions on how to submit written by e-mail or by regular mail. The 

NRC staff believes all affected parties have been afforded an opportunity to participate in the 

scoping process and in the public comment process for this EIS. No changes were made to the 

document as a result of this comment. 

Comment: And I want to say that I thought this was going to be a discussion about the impact 

of the power plant and its additions on our environment. And I've heard very little of that. But I 

hear a lot of concerns about the lack of water, the lack of money going up to Fort Worth. (0063-

11-3 [Smith, Hugh])

Comment: In summary, the Chamber believes that cooperation can exist with the different 

entities to bring our community a significant economic boom and a healthy lake. We look 

forward to ongoing discussions with interested parties. (0063-14-5 [Garner, Todd])

Response: The purpose of the NRC's public meetings on the DEIS was to obtain public 

comments on the data, analyses, findings, and conclusions as presented in the DEIS. Often 

these meetings take on the features of a public forum in which the commenters express their 

opinion on a variety of topics. The types of information exchange and interactions described in 

these comments did occur during the September 21, 2010, public meeting in Texas; however, 

no changes were made to the EIS as a result of these comments. 
Appendix E 

NUREG-1943 E-28 May 2011 

Comment: What we are, as Hood County citizens, asking for is for the NRC to be as aware as 

possible -- because spent the last three years making ourselves aware -- of the total impact of 

the nuclear expansion. (0063-23-1 [Conway, Bretta])

Response: The NRC staff, in conjunction with the U.S. Army Corps of Engineers, has 

developed this EIS to address the full range of potential environmental impacts that would 

accompany the licensing of Comanche Peak Units 3 and 4. The purpose of the NRC's public 

meeting on the DEIS was to obtain public comments on the data, analyses, findings, and 

conclusions as presented in the DEIS. The additional concerns offered in other comments from 

this same commenter, as well as other comments received on the DEIS from other 

commenters, have been taken into consideration in developing the final version of this EIS. 

E.2.2 Comments Concerning Process - NEPA 

Comment: [The Texas Commission on Environmental Quality (TCEQ) has reviewed the 

above-referenced project and offers following comments:] NRC has addressed all required 

elements for a NEPA assessment of environmental, socioeconomic, and public health and 

safety impacts. The overall impacts of the construction and operation of additional reactor units 

at Comanche Peak have been fully explored. Thank you for the opportunity to review this 

project. (0027-4 [Harrison, Jim] [Niemann, Tangela])

Response: The review team appreciates the review of the DEIS that was conducted by the 

Texas Commission on Environmental Quality (TCEQ). The comments on the required elements 

of NEPA, as well as the TCEQ's observations about the overall impacts being fully explored, are 

noted. No change was made to the EIS as a result of this particular comment. 

Comment: The U.S. Department of the Interior is providing the following comments in 

response to the subject DEIS and to assist in assessing and avoiding impacts to federally listed 

species, wetlands, and other fish and wildlife resources. (0064-1 [Martinez, Shirley] [Spencer, 

Stephen])

Response: The review team appreciates the review of the DEIS that was conducted by the 

U.S. Department of the Interior. No change was made to the EIS as a result of this particular 

comment; however, the additional comments received from the Department of the Interior have 

been cataloged and are addressed under the respective categories for those separate 

comments and concerns. 

Comment: Texas Parks and Wildlife Department (TPWD) received the August 6, 2010 

notification for issuance of and request for comment on the above-referenced DEIS. The 

notification was submitted in accordance with the National Environmental Policy Act of 1969, as 

amended (NEPA), and the Fish and Wildlife Coordination Act of 1934, as amended. Nuclear 

Regulatory Commission (NRC) prepared the DEIS as part of its review of Luminant Generation 

Company LLC (Luminant) application for combined licenses for construction and operation of 

two new nuclear units at its existing Comanche Peak Nuclear Power Plant (CPNPP) site near 

Glen Rose, Texas. U.S. Army Corps of Engineers Fort Worth District (USACE) is a cooperating 

agency in the DEIS so that the EIS can be used to decide on issuance of permits pursuant to 

Section 404 of the Clean Water Act and Section 10 of the Rivers and Harbors Act. 

Based on TPWD staff review of the information provided, TPWD offers specific 

recommendations regarding the DEIS and concerns regarding the project that can be found in 

Attachment A to this letter. (0068-1 [Melinchuk, Ross] [Wicker, Julie])

Response: The review team appreciates the review of the DEIS that was conducted by the 

Texas Parks and Wildlife Department (TPWD). No change was made to the EIS as a result of 

this particular comment; however, the additional comments and recommendations received 
Appendix E 

May 2011 E-29 NUREG-1943 

from the TPWD in its Attachment A have been cataloged and are addressed under the 

respective categories for those separate comments and concerns. 

Comment: In accordance with the National Environmental Policy Act and Section 309 of the 

Clean Air Act, Environmental Protection Agency (EPA) Region 6 has reviewed the Draft 

Environmental Impact Statement (DEIS) dated August 2010, for Combined Licenses (COLs) for 

Comanche Peak Nuclear Power Plant (CPNPP) Units 3 and 4. The DEIS would authorize 

construction and operation of two new units at the CPNPP. 

EPA rates the DEIS as EC-2, i.e., EPA has Environmental Concerns and Requests Additional 

Information in the Final EIS (FEIS). Detailed comments are enclosed with this letter and more 

clearly identify our concerns and the informational needs requested for incorporation into the 

FEIS. EPA appreciates the opportunity to review the DEIS. (0070-1 [Smith, Rhonda])

Response: The review team appreciates the review of the DEIS that was conducted by the 

U.S. Environmental Protection Agency (EPA). The EPA rating of EC-2 for the Comanche Peak 

DEIS is noted. No change was made to the EIS as a result of this particular comment; however, 

the additional comments received in the enclosure from the EPA have been cataloged and are 

addressed under the respective categories for those separate comments and concerns. 

Comment: We question the quality of the consultation with Federal, State, Tribal and local 

agencies. (0071-2 [Hadden, Karen])

Response: The NRC regulations related to consultations with Federal, State, Tribal, and local 

agencies are identified in 10 CFR 51.28 and 10 CFR 51.29. Appendix F of this EIS presents a 

list of key consultation correspondence during the evaluation process for the combined license 

application for siting the proposed Units 3 and 4 at the Comanche Peak Nuclear Power Plant 

(CPNPP) site. The review team believes that the consultation process followed during the 

evaluation process adequately identified and obtained input from Federal, State, Tribal, and 

local authorities in accordance with 10 CFR 51.28, 10 CFR 51.29, and guidance set forth in 

NUREG-1555, Environmental Standard Review Plan, and recent updates. No changes were 

made to the EIS as a result of this comment. 

Comment: SEED Coalition questions whether the Draft Environmental Impact Statement 

satisfies the requirements of the National Environmental Policy Act of 1969 (NEPA) or 

requirements related to the issuance of a U.S. Army Corps of Engineers issuance of a permit to 

perform certain construction activities on the site. We believe that the evaluation of the 

proposed action’s impacts to waters of the United States pursuant to Section 404 of the Federal 

Water Pollution Control Act (Clean Water Act) and Section 10 of the Rivers and Harbors 

Appropriation Act of 1989 is inadequate. (0071-1 [Hadden, Karen])

Response: Section 102 of the National Environmental Policy Act (NEPA) of 1969, as 

amended, requires preparation of an environmental impact statement (EIS) for major Federal 

actions that significantly affect the quality of the human environment. The NRC has 

implemented Section 102 of NEPA in 10 CFR Part 51. Further, in 10 CFR 51.20, the NRC has 

determined that the issuance of a combined license under 10 CFR Part 52 is an action that 

warrants an EIS. Detailed procedures for conducting the environmental review are found in 

guidance set forth in NUREG-1555, Environmental Standard Review Plan, and recent updates. 

Section 2.3 of the EIS describes the surface water and groundwater features of the Comanche 

Peak Nuclear Power Plant (CPNPP) site and the surrounding region that could be affected by 

the construction and operation of the proposed CPNPP Units 3 and 4. Section 4.2 of the EIS 

describes the water related impacts involved in building the proposed units at the site. Section 

5.2 describes the water-related impacts to the site and surrounding region that could occur from 
Appendix E 

NUREG-1943 E-30 May 2011 

operating the proposed units. The review team believes that the EIS adequately addresses 

water related impacts according to the NRC’s rules, regulations, and guidance. The U.S. Army 

Corps of Engineers (Corps) participated as part of the review team in the review of the CPNPP 

COL application environmental review. The Corps’ role as a cooperating agency in the 

preparation of this EIS is to ensure that the information presented is adequate to fulfill the 

requirements of Corps regulations applicable to construction of the preferred alternative 

identified in the EIS. This EIS includes the Corps’ evaluation of construction and maintenance 

activities that impact waters of the United States. The commenter has not provided specific 

facts in this comment that would allow the review team to reconsider its review and conclusions. 

No changes were made to the EIS as a result of this comment. 

E.2.3 Comments Concerning Site Layout and Design 

Comment: [T]he potential negative environmental effects of the reduced volume of water 

returned to the lake and river, along with increased salinity, heat discharge, salt spray mist, 

noise, aerosol drift, visible atmospheric plume and disposable salt accumulation associated with 

the preliminary design of the Blow Down Treatment Facilities (BDTF) intended to remove 

excess heat at the proposed plant have yet to be accurately estimated. (0055-2 [Inge, Charles] 

[King, Arnold] [Rosenfeld, Joshua])

Comment: That the potential negative environmental effects of the reduced water volume 

return to the lake and river along with increased salinity, heat discharge, salt spray mist, noise, 

aerosol draft, visible atmospheric plume and disposable salt accumulation associated with the 

preliminary design of the blow-down treatment facilities intended to remove excessive heat at 

the proposed plant has yet to be accurately estimated. (0063-36-2 [Hackett, Ken])

Response: Potential impacts of the BDTF have been described, estimated, and evaluated in 

the EIS. The reduced volume of water returned to Lake Granbury is addressed in Section 

5.2.2.1 of this EIS. The increased salinity, as well as the heat discharge, are addressed in 

Section 5.2.3.1 in the discussion of discharge limits to be imposed by the State of Texas. Salt 

spray is addressed in Sections 5.1.1 and 5.3.1.1. Noise is addressed in Section 5.8.2. Aerosol 

drift and visible atmospheric plume are addressed in Section 5.3.1.1. The disposable salt 

accumulation is addressed in Section 5.1.1. Because this comment did not offer new or 

significant information about environmental impacts, it did not result in any changes to the EIS. 

Comment: The description of the blowdown treatment facility (BDTF) (Section 3.2.2.2) is 

inadequate and leads to overly optimistic estimates of environmental impacts. By its footnote 

on page 3-12, the review team acknowledges that it realizes that the BDTF design is unreliable. 

While the footnote might lead one to believe that the uncertainty about the BDTF is just one of 

many minor uncertainties encountered in preparing an environmental impact statement (EIS), 

the truth is quite different. (0069-1 [McCold, Lance])

Response: The review team’s assessment of potential impacts associated with the BDTF as 

described in Section 3.2.2.2 is based on the conceptual design provided by the Applicant. The 

review team has concluded that sufficient detail exists in the Applicant's conceptual design to 

conduct an adequate analysis of potential environmental impacts. Uncertainty within a NEPA 

assessment does not imply unreliability. It is important to note that 10 CFR 51.71(d) states 

when”[t]o the extent that there are important qualitative considerations or factors that cannot be 

quantified; these considerations or factors will be discussed in qualitative terms.” The staff’s 

analysis of potential impacts from the construction and operation of the BDTF addresses the 

uncertainties in such qualitative terms later in the EIS. Because this comment did not offer any 

new or significant information about environmental impacts, no changes were made to the EIS 

as a result of the comment. 
Appendix E 

May 2011 E-31 NUREG-1943 

Comment: Section 3.2.2.2 reports that the BDTF would demineralize the blowdown by reverse 

osmosis and evaporate BDTF wastewater in a 128-ac evaporation pond. However, 128 ac for 

evaporation reported in Section 3.2.2.2 is a gross underestimate of the actual area that would 

be required to evaporate the quantity of water that would be produced by the BDTF if Luminant 

followed through with its commitment to discharge wastewater that did not exceed 2500 mg/L 

TDS. Evaporation pond details are not presented in the EIS. The reader must carefully review 

the applicant's responses to requests for additional information (cited in Section 3.5) to learn 

how the evaporation pond is supposed to work. (0069-2 [McCold, Lance])

Response: The commenter describes the function of the proposed BDTF. The review team 

used 400 acres in Section 4.1.1 to bound the size of the BDTF and has based its assessment of 

impacts upon that 400 acres and not the 128 acres mentioned in the comment. The review 

team has concluded that sufficient detail exists in the Applicant's conceptual design to conduct 

an adequate analysis of potential environmental impacts. Because this comment did not offer 

new or significant information about environmental impacts, no changes were made to the EIS 

as a result of the comment. 

Comment: Luminant estimates that they need to evaporate 5,200 gpm of reverse osmosis 

brine, about 7.5 million gallons per day (Mg/d). For estimating evaporation pond performance, 

Luminant assumed a 10-year average pan evaporation rate of 5.1 inches per month, and 182 

evaporators in a 2364-ft by 2364-ft (128-acre) evaporation pond. Based on the average pan 

evaporation rate and Slimline Manufacturing LTD (Slimline)-provided sizing guidance for their 

Turbo-Mist evaporators, Luminant claims an evaporator efficiency of 35.7%. That is, they 

expect that over a long period of time, 35.7% of water pumped through the evaporators will be 

evaporated. To evaluate the reliability of the impacts that would result from the BDTF, one 

needs to examine Slimline information (http://www.turbomisters.com/downloadable-pdfs.php) 

and the results of research conducted at the Salton Sea by the U.S. Bureau of Reclamation 

(http://www.usbr.gov/lc/region/saltnsea/pdf_files/salincntrl/report.pdf). Review of these sources 

reveals several reasons that the Luminant's evaporation pond claims are not reliable. The 

reasons are described below. 

Locating 182 misters (evaporators) in 128 acres would reduce evaporator efficiency to the point 

that the system would fail to achieve an average evaporation rate of 7.5 Mg/d. 

The Slimline evaporator web site offers several “suggested” or “sample” pond layouts 

(http://turbomister.com/downloadable-pdfs.php). The radial arrangements for up to 12 

evaporators indicate that the units should be located on a 20-m-diameter island with the 

evaporators pointed outward. One drawing indicates that the perimeter fence should be located 

at least 200 m from the evaporators. If 200 m to the perimeter fence is required, 12 evaporators 

would require 44 acres, plus space for access roads and piping. In this case, the 128 acres for 

evaporation would only accommodate fewer than 40 evaporators. At this density, the 

evaporation pond would need to be 700 to 800 acres to accommodate 182 misters. Perhaps 

another 100-200 acres for access would be required for a total of 800 to 1000 acres. 

The U.S. Bureau of Reclamation study of evaporators at the Salton Sea seems to be the only 

published report on evaporator efficiency relevant to the CPNPP situation. That study offers the 

following recommendations related to evaporator spacing: 

Based on experience gained in the operation of EES units at the test base, it would be 

necessary to space the devices at least 250 apart. The devices should be placed in long rows. 

A survey of operations at the Test Base yielded the conclusion that salt and/or mist from the 

evaporators can travel 1,300 feet. Therefore, the rows of evaporators should be placed at least 

1,300 feet apart. The ideal configuration would be to place the units in long rows over a large 
Appendix E 

NUREG-1943 E-32 May 2011 

pond. The system should be designed to shut down any time the winds exceed 10 miles per 

hour. Otherwise, the 1,300 feet will not be adequate. Determining drift characteristics at speed 

in excess of 10 miles per hour was not possible at the Test Base. The permits for the operation 

of the EES units limited operations to 10 miles and hour or less. Additional research into drift 

distances at higher speeds would be required before a large-scale system could be designed. 

However, increased drift distances would only translate into much larger pond sizes and row 

spacing. 

The motivation for the spacing recommendations was the tendency for the evaporators foul with 

gypsum and other salts. The author noted that mist was often recirculated into the intake of the 

evaporators. The recirculated mist caused fouling of the motor and impeller blades. To prevent 

damage to the impellers, they found it necessary to pressure wash the evaporators inside and 

out “every couple days.” Using the Salton Sea study recommendation, each evaporator would 

need about 7.5 acres; and 182 evaporators would require 1,365 acres. In addition to the area

(0069-3 [McCold, Lance])

Response: The detailed design information, recommendations, and observations offered in the 

comment are appreciated. The review team’s assessment of potential impacts associated with 

the BDTF as described in Section 3.2.2.2 is based on the conceptual design provided by the 

Applicant. The review team has concluded that sufficient detail exists in the Applicant's 

conceptual design to conduct an adequate analysis of potential environmental impacts. 

Additionally, the staff assessment of the potential impacts examined the monthly evaporation 

rates for the region rather than a yearly average as discussed above. Applying monthly 

evaporation rates is necessary because the conditions in the summer could allow for the 

evaporation of the excess amounts of brine built up over the winter and, therefore, would be 

more technically accurate when factored into an assessment of impacts. Because this 

comment did not offer any new or significant information about environmental impacts, no 

changes were made to the EIS as a result of the comment. 

Comment: The foregoing discussion is structured as though Luminant would compensate by 

poorer than expected evaporation pond performance by expanding it and adding more misters. 

Such a response would lead to larger land use and increases to the impacts that are related to 

land use. However, expanding the BDTF evaporation pond system, perhaps to more than two 

square miles, may not be the most attractive solution. For example, it would be much less 

expensive for Luminant to negotiate a permit from the State of Texas that would allow discharge 

of blowdown water with higher concentrations of TDS and chloride. Or, the State of Texas 

could even amend the water quality standard for Lake Granbury, from 2500 to 3000 mg/L for 

instance. Different reaches of the Brazos River have different water quality standards. While 

the Lake Granbury 2500-mg/L TDS limit is relatively high, there is no assurance the State of 

Texas wouldn't raise it further to help Luminant. The EIS does not evaluate the environmental 

impacts of such a change. (0069-4 [McCold, Lance])

Response: The hypothetical situation described in the comment (i.e., a discharge limit into 

Lake Granbury that is higher than the 2500 mg/L as analyzed in Section 5.2.3.1 of this EIS) is 

speculative. The discharge limit for Comanche Peak Units 3 and 4 will be established and 

enforced by the State of Texas; the State has indicated that the limit will be 2500 mg/L. If 

Luminant applies for a permit with a value higher than 2500 mg/L and such a limit is 

established, then the environmental effects of an alternate limit may need to be considered. 

Establishing and enforcing water quality discharge limits is the responsibility of the Texas 

Commission on Environmental Quality and the U.S. Environmental Protection Agency, under 

the Federal Water Pollution Control Act (also known as the Clean Water Act). No changes were 

made to the EIS as a result of this comment. 
Appendix E 

May 2011 E-33 NUREG-1943 

Comment: DEIS Section 3.3.1.13, page 3-23, lines 40-42: Two additional gravity-drain 42-in. 

blowdown discharge pipelines (one from Unit 3 and one from Unit 4) with multiport diffusers are 

to be located approximately 900 ft upstream from DeCordova Bend Dam, in the vicinity of the 

existing discharge pipe. 

According to the response to ER RAI SOC-33 (ML100710613), the diffusers are planned to be 

located approximately 800 ft upstream from DeCordova Bend Dam. (0073-4 [Flores, Rafael])

Response: The information offered in these comments has been used to revise Section 

3.3.1.13 in this Final EIS. 

Comment: DEIS Section 3.4.4.1, page 3-39, lines 33-43: Luminant reports that total 

suspended solids (TSS) in the vicinity of DeCordova Bend Dam near the south end of Lake 

Granbury average 11 mg/L with a range of results from 2 to 120 mg/L. Luminant does not 

report discharge of TSS. Luminant reports that TDS in blowdown discharged to Lake Granbury 

would be limited to 2500 mg/L assuming the inlet TDS concentration is 1680 mg/L. The use of 

1680 mg/L TDS was removed from the ER by the supplemental response to ER RAI GEN-03 

(ML093620032) because the statement was no longer valid. (0073-5 [Flores, Rafael])

Response: The text in Section 3.4.4.1 in this Final EIS has been revised to delete the 

reference to the value of 1680 mg/L. 

Comment: Page 3-12 discussed the BDTF as a conceptual design with design details not yet 

complete, though the parameters for the facility may change as Luminant pursues a permit from 

the state for discharging blowdown water to Lake Granbury. The 400-acre area would consist 

of reverse osmosis and ultrafiltration equipment buildings, a 47-acre storage pond, and a 128-

acre evaporation pond. Approximately 83 percent of blowdown would pass through 

ultrafiltration followed by reverse osmosis to create a product stream with low total dissolved 

solids (TDS) and chloride concentrations, which will be mixed with the remaining 13 percent, 

untreated blowdown water from the cooling towers that is allowed to bypass the BDTF. This 

mixture will be discharged to Lake Granbury. Waste streams recovered from the reverse 

osmosis and ultrafiltration process would be combined in the storage pond. Storage pond water 

would be routed to the evaporation pond to evaporate wastewater to the point salts could be 

disposed of at a landfill. To accelerate evaporation, the evaporation pond would have 182 

misters, each with a sound level of 95 decibels at a distance of 25 feet. Spray from the misters 

would be forced approximately 60 feet into the air, and the pond would be surrounded by a 16-

foot tall fabric fence to capture salt drift falling out of the spray. Recommendation: When the 

final design for the BDTF has been completed, TPWD recommends the applicant provide the 

complete BDTF description and an environmental analysis for review as a supplemental report 

to the DEIS. (0068-33 [Melinchuk, Ross] [Wicker, Julie])

Response: The review team considered the conceptual design of the BDTF. The commenter 

summarized the function of the proposed BDTF, as well as its operational characteristics and 

features as analyzed in this EIS. The review team has determined that the design information 

submitted by the Applicant provides sufficient details to assess the potential environmental 

impacts of the proposed BDTF. If the actual design of the BDTF changes significantly, then the 

updated design may need to be considered. The BDTF would require a permit from the State of 

Texas, should changes be made to the design the State would consider that in its permitting 

action as well. No changes were made to the EIS as a result of this comment. 

Comment: The DEIS identifies many areas of uncertainty associated with the BDTF, including 

distance of salt deposition, concentration in the salt spray, effectiveness of the salt intercepting 

fence, level of wildlife safety hazard and exclusion controls. Recommendation: TPWD 
Appendix E 

NUREG-1943 E-34 May 2011 

recommends the uncertainty issues surrounding the BDTF operation be resolved prior to 

licensing. The uncertainties should be resolved in a manner that avoids and minimizes adverse 

impacts on wildlife and the surrounding habitat. (0068-52 [Melinchuk, Ross] [Wicker, Julie])

Comment: There are always uncertainties inherent in preparation of an EIS. The correct way 

to deal with such uncertainties is to evaluate the foreseeable impacts of the possibilities and to 

modify the action to assure that unacceptable impacts do not result. In this case, the NRC has 

accepted the applicant's proposal [for the blowdown treatment facility (BDTF)] as though it were 

feasible. Surely, the Commission has people on its staff with sufficient technical capabilities to 

evaluate the applicant's faulty proposal. (0069-6 [McCold, Lance])

Response: These comments address uncertainties in the BDTF design and/or uncertainties 

noted in the review team's analyses of the impacts from the operation of the proposed BDTF. A 

description of the proposed BDTF is provided in Section 3.2.2.2. Additionally, footnote 2 on pg 

3-12 of the EIS states that the BDTF is a conceptual design and the design parameters for the 

facility could change. A final design of the BDTF would not be completed until prior to the 

applicant’s submission of a permit application to the TCEQ. The applicant would have to obtain 

permits from the TCEQ prior to constructing and operating the BDTF. The staff's assessment of 

potential environmental impacts associated with the BDTF is based on the conceptual design 

provided by the Applicant. The staff has concluded that sufficient detail exists in the Applicant's 

conceptual design to conduct an adequate analysis of potential environmental impacts. The 

DEIS noted the uncertainties in the impacts (such as those to land use or terrestrial ecology) 

that could result from the operation of the BDTF in accord with the conceptual design submitted 

by the Applicant; however, the review team believes that design is adequate for the purpose of 

evaluating potential environmental impacts because a bounding-analysis approach used. The 

bounding analysis includes evaluating the effects of the facility with and without the Applicant’s 

proposed mitigation measures. The review team’s acknowledgment of the uncertainties in the 

DEIS is an explicit part of that bounding analysis. In the event that significant changes are made 

to the final design of the BDTF, then the updated design may need to be evaluated by the 

TCEQ. No changes were made to the EIS as a result of these comments. 

Comment: An alternate disposal method for the accumulated salts [from the BDTF] could be 

underground injection which would require a Class I, non-hazardous Underground Injection 

Control (VIC) permitted well. EPA asks that NRC's consideration of an alternative treatment 

method of treatment be discussed in the FEIS. (0070-6 [Smith, Rhonda]) 

Response: Alternative water treatment methods are discussed in Section 9.4.2.4 of the EIS. In 

a letter dated March 5, 2010 (ADAMS Accession No. ML100710613), Luminant provided 

discussion of deep well injection, in response to a request for additional information by the 

review team, indicating that it would not be a viable alternative to the proposed BDTF. Luminant 

cited the large volume of waste generated and the potential necessity of pretreatment to reduce 

suspended solids and scaling as factors in considering the disposal method. Additionally, test 

borings would be necessary to determine if it would be possible at the site. The review team did 

not consider deep well injection as a viable alternative to the BDTF. No changes were made to 

the EIS as a result of this comment.

Comment: Page 3-28 discussed Oncor’s full-cut clearing and selective-cut transmission line 

ROW clearing standards, but notes the standard does not contain a directive documenting the 

circumstances under which either method would be applied. Recommendation: TPWD 

recommends NRC request clarification from the applicant or Oncor on the directives specifying 

the conditions under which each method is to be used. Given the 160-foot wide corridors 

required for the lines, the selective-cut method should be employed where safety precautions 

permit. (0068-36 [Melinchuk, Ross] [Wicker, Julie])
Appendix E 

May 2011 E-35 NUREG-1943 

Response: The comment requests that the review team provide additional information 

regarding the conditions under which selective-cut and full-cut clearing methods would be used 

by Oncor, the transmission service provider, to clear transmission line right-of-ways. The NRC 

does not have regulatory oversight of building and operating new transmissions lines. A 

separate environmental analysis will be required of Oncor by the Public Utility Commission of 

Texas and the Electric Reliability Council of Texas. However, the EIS does describe the effects 

of building and operating new transmission lines. The review team’s analysis of the effects of 

building the new transmission lines include direct injury and mortality to wildlife; habitat loss and 

fragmentation; disturbance and displacement of wildlife; and land use changes that may occur. 

This analysis also includes clearing, grading, and leveling necessary to build the transmission 

line. In Section 4.1.2 of the EIS, the review team concludes that building the proposed 

transmission lines right-of-ways will have a noticeable effect on land use, but would not 

destabilize important attributes of the resource. Additionally, the review team concluded in 

Section 4.3.1.6 of the EIS that building the proposed transmission line right-of-ways would have 

a noticeable effect on terrestrial resources, but would not destabilize important attributes of the 

resource. These sections also include potential mitigation measures that could reduce the 

effect of building the transmission lines. Additionally, Section 4.3.1.3 of the EIS notes that 

coordination with TPWD and U.S. Fish and Wildlife Service to determine the potential impacts to 

Federally Listed and State Listed species could be undertaken to identify additional mitigation 

measures that could minimize impacts. Section 4.3.1.3 of the EIS has been revised to provide 

a description of the types of consultations that Oncor could perform to minimize some of the 

effects of building new transmission lines. 

E.2.4 Comments Concerning Land Use - Site and Vicinity 

Comment: DEIS Section 5.1.1, page 5-5, lines 41-48: The SMALL to MODERATE conclusion 

also reflects the potential for salt drift from operation of the BDTF to affect rural residential 

properties adjoining the CPNPP perimeter. The most serious potential adverse effect of the salt 

drift on those properties would be salt-induced injury to sensitive landscape vegetation, as well 

as possible increased corrosion rates for aluminum siding and other metal structural 

components of houses. Possible mitigation measures, in addition to the salt fence and 

directional spray misting units proposed by Luminant, might include provision of salt-tolerant 

vegetation, compensation for corrosion of metal property, and, in the worst case, purchase of 

affected residential properties. A summary of the meteorological data at CPNPP demonstrates 

that on an annual average the wind is generally out of the north (i.e., NW-to-NE sector) 

approximately 26% of the year, primarily from November through March. This wind direction 

would disperse the mist toward the CPNPP southern property boundary. The data summary 

also demonstrates the wind speed from the north averages between 9 to 13 mph with an annual 

average of approximately 10.3 mph. The Salton Sea Salinity Control Research Project, upon 

which Luminant's evaluation of the effects of BDTF operation were based, stated that salt 

and/or mist from the evaporators can travel 1,300 ft in a 10-mph wind. Luminant commits to 

limiting salt deposition beyond the CPNPP property boundary, which is greater than 1,300 ft 

from the BDTF, to minimize or totally prevent the potentially adverse impacts. ER Subsection 

5.3.2.3 states that mitigative measures such as salt fences or wind velocity sensors that halt 

misting could be employed to contain salt drift when wind speeds exceed 10 mph. Therefore, 

Luminant is not considering provision of salt-tolerant vegetation, compensation for corrosion of 

metal property, and, in the worst case, purchase of affected residential properties as possible 

mitigation measures for BDTF operation. (0073-6 [Flores, Rafael])

Response: The EIS proposes possible mitigation measures, in addition to those that were 

proposed by Luminant, such as the ones mentioned in the comment. The EIS indicates that the 

proposed additional mitigation measures may reduce the effect of salt drift from the blowdown 
Appendix E 

NUREG-1943 E-36 May 2011 

treatment facility (BDTF). Any decision to implement these or other mitigation measures would 

be made by Luminant. The SMALL to MODERATE conclusion assumes that only those saltdrift related mitigation measures specifically proposed by Luminant in the ER would be 

implemented. The EIS was not changed in response to this comment. 

E.2.5 Comments Concerning Land Use - Transmission Lines 

Comment: if you look at a map, you will see that the transmission lines that come through the 

wind towers or planning to put across our county. We also have gas pipelines crossing our 

county. My question is, have you discussed this Environmental Impact study with any other -- 

the impact of how your transmission lines -- talk about 1,100 acres of new transmission line right 

of way, so if you look at all the right of ways for pipelines and for future transmission lines, did 

you bring that into consideration? (0062-1-1 [Condy, Ymke])

Response: This EIS evaluates the impacts of general corridor locations for proposed new 

transmission lines to serve CPNPP Units 3 and 4. This analysis, reported in Section 4.1.2 of the 

EIS, does not reveal likely conflicts between the proposed corridors and existing pipelines. 

Under Texas statutes, Oncor Electric Delivery System LLC will be responsible for applying to 

the Public Utility Commission of Texas to identify specific routes for the transmission lines. If 

appropriate, that process may involve a more detailed evaluation of the relationship between the 

proposed transmission lines and existing pipelines. The EIS was not changed in response to 

this comment.

Comment: Figure 2-9 Federal Lands and State Parks in the Region does not include a 

representation of state parks within the project vicinity. Recommendation: Geographic 

information system (GIS) shapefiles of park boundaries can be obtained from [the] TPWD GIS 

Laboratory Manager Kim Ludeke. Figure 2-9 should include state parks or wildlife management 

areas that occur within the vicinity of the project including Cleburne State Park (SP), Dinosaur 

Valley SP, Lake Whitney SP, Meridian SP, Lake Mineral Wells SP and Trailway, Possum 

Kingdom SP, and Cedar Hill SP. The Eagle Mountain State Recreation Area is no longer 

owned by TPWD, though identification of this park should be delineated on the map. (0068-16

[Melinchuk, Ross] [Wicker, Julie])

Response: As recommended in the comment, shape files of the state park boundaries were 

obtained from the TPWD GIS Laboratory. Unfortunately, these files were not in a usable format 

for inclusion on Figure 2-9 of the EIS. State parks in the CPNPP region have been identified in 

the text of Section 2.2.3 of the EIS. The only state park expected to be potentially affected by 

the proposed project, Dinosaur Valley State Park, is depicted on Figure 2-7. Section 2.2.3 of the 

EIS has been revised to include State parks not presented in Figure 2-9. 

Comment: Figure 2-13 shows the approximate corridors of the two proposed new location 345-

kV transmission lines associated with the project, including the 17-mile route to DeCordova and 

the 45-mile route to Whitney. The DEIS indicates the routes would occupy approximately 148 

acres and 954 acres, respectively, that consist of grassland, oak/juniper woodlands, and 

developed land. The figure shows the Whitney corridor potentially crosses Dinosaur Valley SP 

and Fossil Rim Wildlife Center. As previously mentioned, the exact routes have not yet been 

decided, and the routes would be developed as required by ERCOT and PUCT. 

The DEIS evaluation of direct impacts on land use indicates the proposed Whiney transmission 

line corridor, as currently shown, would pass very close to Dinosaur Valley SP, possibly 

encroaching on its western boundary, and would cross Fossil Rim. The DEIS indicates that 

land-use impacts of construction and preconstruction activities associated with transmission 

lines and pipelines would be MODERATE and impacts of NRC-authorized construction activities 
Appendix E 

May 2011 E-37 NUREG-1943 

would be SMALL. Page 4-6 suggests mitigation measures for land use impacts of transmission 

line ROWs could include designating Dinosaur Valley State Park and Fossil Rim, and all areas 

visible from the park and Fossil Rim, as exclusion areas for the routing study. 

Dinosaur Valley SP exhibits some of the world’s best preserved fossil records of dinosaur 

tracks, provides endangered species habitat, and is a popular camping and hiking area. Fossil 

Rim is a nonprofit center specializing in breeding indigenous and exotic threatened and 

endangered species. Crossing through either area could adversely impact the wildlife, habitats 

and paleontological resources that have been protected to support their recovery and 

preservation for the benefit of the public. Part of the enjoyment of natural area recreation 

activities includes viewsheds devoid of man-made structures. Visibility of the transmission line 

would degrade the recreational experience for the park and wildlife center visitors. 

Recommendation: TPWD supports the mitigation measures, presented in this section and 

summarized in NRC’s conclusions and recommendations Table 10-1, to designate Dinosaur 

Valley SP and Fossil Rim and all areas visible from these properties as land use exclusion 

areas during the transmission line routing study. TPWD recommends every effort be made to 

avoid crossing these facilities. 

If the final project design requires that transmission lines cross any state-owned or managed 

lands, such as Dinosaur Valley State Park, the NRC, Luminant, and Oncor should be aware of 

the requirements of Chapter 26 of TPW Code (Chapter 26). Chapter 26 is modeled on a federal 

statute, known as “section 4(f)” and codified at 49 U.S.C. §303. In fact, much of Chapter 26 is 

taken word for word from section 4(f). Chapter 26 requires that before any department, agency, 

political subdivision, county or municipality of this state can approve any project that will result in 

the use or taking of public land designated as a park, public recreation area, scientific area, 

wildlife refuge, or historic site, that entity must provide certain notice to the public, conduct a 

hearing, and render a finding that there is no reasonable or prudent alternative and that the 

project includes all reasonable planning to minimize harm to taking of such lands. If it appears 

the transmission lines may cross or come near a state park, please contact David Riskind of 

TPWD State Parks Division Natural Resources Program. (0068-39 [Melinchuk, Ross] [Wicker, 

Julie])

Response: The commenter's concurrence with possible measures identified in the DEIS for 

mitigating impacts of a new transmission line on Dinosaur Valley State Park and Fossil Rim 

Wildlife center is noted. The specific route for this new transmission line would be established 

by the Public Utility Commission of Texas in response to an application from Oncor Electric 

Delivery System LLC. The route selection process will comply with all applicable Federal, State, 

and local laws, regulations, and ordinances. The EIS was not changed in response to this 

comment. 

Comment: What land will need to be condemned or purchased in order to build or upgrade 

new transmission lines? (0071-43 [Hadden, Karen])

Response: This EIS evaluates the impacts of general corridor locations for proposed new 

transmission lines to serve CPNPP Units 3 and 4. Based on these general corridors, estimates 

of the total amount of land by category that would fall within the new rights-of-way are presented 

in Section 4.1.2. Under Texas Statutes, Oncor Electric Delivery System LLC (Oncor) will be 

responsible for applying to the Public Utility Commission of Texas to identify specific routes for 

the transmission lines. Once the actual routing is determined from within the corridors 

evaluated the specific parcels will be identified. The EIS was not changed in response to this 

comment.
Appendix E 

NUREG-1943 E-38 May 2011 

E.2.6 Comments Concerning Meteorology and Air Quality 

Comment: The Texas Commission on Environmental Quality (TCEQ) has reviewed the abovereferenced project and offers following comments: A review of the project for General 

Conformity impact in accordance with 40 CFR Part 93 and Title 30, Texas Administrative Code 

§ 101.30 indicates that the proposed action is located in the City of Glen Rose, Somervell 

County, which is currently unclassified or in attainment of the National Ambient Air Quality 

Standards for all six criteria air pollutants. Therefore, General Conformity does not apply. 

Although any demolition, construction, rehabilitation or repair project will produce dust and 

particulate emissions, these actions should pose no significant impact upon air quality 

standards. Any minimal dust and particulate emissions should be easily controlled by the 

construction contractors using standard dust mitigation techniques. (0027-1 [Harrison, Jim] 

[Niemann, Tangela])

Response: The information provided in the comment is consistent with the information 

presented and conclusions reached in the DEIS. This comment did not result in any changes to 

the EIS. 

Comment: One of the concerns that we have is shared by the NRC and the EPA and almost 

every scientist in the world. And that is, the climate is changing. And the NRC is proud to 

promote low -- nuclear power plants as a solution to global warming. But they don't really look 

far enough down the process to really understand exactly how it might affect the operations in 

their own plants. (0063-16-1 [Smith, Tom])

Response: The NRC licenses and regulates nuclear power production to ensure protection of 

public health and safety. The NRC is not engaged in finding a “solution” to climate change and 

does not promote the use of nuclear energy. Additionally, the NRC is not responsible for 

planning for the impact of climate change on the operation of nuclear power plants. Planning 

and management for future conditions that may affect nuclear power plant operations is the 

responsibility of the plant operators, such as Luminant. It is not within the NRC's scope as a 

regulator of nuclear safety. 

The NRC remains vigilant of emerging environmental issues, regulatory approaches, and 

analytical methods that may inform its decisions. The review team relied heavily on the work of 

other Federal agencies, especially those with a direct mandate to address the science and the 

effects of climate change on public health and welfare; now that the U. S. Government position 

has crystallized, the review team believed that it was important to consider the new 

circumstances. As a starting point, on December 15, 2009, the Administrator of EPA issued her 

determination under her authority under the Clean Air Act that: 

... greenhouse gases in the atmosphere may reasonably be anticipated both to 

endanger public health and to endanger public welfare.... The Administrator reached 

her determination by considering both observed and projected effects of greenhouse 

gases in the atmosphere, their effect on climate, and the public health and welfare risks 

and impacts associated with such climate change. (74 FR 66496) 

In addition to the finding, the bases for the finding provide insights on the extensive efforts within 

the Federal government to weigh and balance science and public policy issues when 

considering GHG emissions and the effects of climate change; GHG emissions are treated as a 

surrogate for the potential effects on climate. Several of the germane findings included: 

The Administrator has considered how elevated concentrations of the well-mixed 

greenhouse gases and associated climate change affect public health by evaluating the 

risks associated with changes in air quality, increases in temperatures, changes in 
Appendix E 

May 2011 E-39 NUREG-1943 

extreme weather events, increases in food- and water-borne pathogens, and changes in 

aeroallergens. 

The Administrator has considered how elevated concentrations of the well-mixed 

greenhouse gases and associated climate change affect public welfare by evaluating 

numerous and far-ranging risks to food production and agriculture, forestry, water 

resources, sea level rise and coastal areas, energy, infrastructure, and settlements, and 

ecosystems and wildlife. 

... with regard to government acceptance and approval of IPCC [Intergovernmental 

Panel on Climate Change] assessment reports, the USGCRP Web site states that: 

‘‘When governments accept the IPCC reports and approve their Summary for 

Policymakers, they acknowledge the legitimacy of their scientific content.’’ It is the 

Administrator’s view that such review and acceptance by the U.S. Government lends 

further support for placing primary weight on these major assessments. 

EPA has no reason to believe that the assessment reports do not represent the best 

source material to determine the state of science and the consensus view of the world’s 

scientific experts on the issues central to making an endangerment decision with respect 

to greenhouse gases. EPA also has no reason to believe that putting this significant 

body of work aside and attempting to develop a new and separate assessment would 

provide any better basis for making the endangerment decision, especially because any 

such new assessment by EPA would still have to give proper weight to these same 

consensus assessment reports. 

The latter represents an endorsement by the EPA of the GCRP (also known as the Karl Report). 

The Council on Environmental Quality draft guidance regarding climate change as an element 

of the NEPA review has been considered by the NRC staff in crafting its approach for 

developing EISs for new reactor applications. While it is important to disclose the comparison of 

GHG emissions among the proposed project and its alternatives, the conclusion that lower GHG 

(or CO2-equivalent) emissions would result in lower climate change risks from this action is too 

broad a conclusion to state without more detailed analysis. A more detailed analysis to support 

such a conclusion was not warranted for this NEPA review. Appendix J presents the review 

team’s estimate of the CO2 footprint of the nuclear power generation alternative. The 

comparison of CO2 footprints of nuclear power and alternatives is presented in Section 9.2.5. 

The NRC staff has also included consideration of climate change impacts in its assessment of 

cumulative impacts in EIS Section 7. These comments did not result in any changes to the EIS. 

E.2.7 Comments Concerning Hydrology - Surface Water 

Comment: [The Texas Commission on Environmental Quality (TCEQ) has reviewed the 

above-referenced project and offers following comments:] We recommend that the applicant 

take necessary steps to insure that best management practices are utilized to control runoff 

from construction sites to prevent detrimental impact to surface and ground water. (0027-3

[Harrison, Jim] [Niemann, Tangela])

Comment: EPA also recommends ensuring that the storm water management system will be 

designed in accordance with TCEQ standards. (0070-15 [Smith, Rhonda])

Response: The review team expects that the applicant will implement best management 

practices (BMPs) to control construction site runoff to prevent detrimental impact to surface and 

groundwater, consistent with the Clean Water Act stormwater permit (TPDES General Permit 
Appendix E 

NUREG-1943 E-40 May 2011 

TXR150000) issued by TCEQ under the Texas Pollutant Discharge Elimination System 

(TPDES). No changes were made to the EIS as a result of this comment. 

Comment: Twelve million dry pounds of wood fiber would be generated from clearing the main 

construction area, and would be used as hydraulic mulch for on-site erosion control. TPWD has 

concerns regarding the quality of the stormwater runoff. Depending on the binding agent used 

in the mulch, the stormwater runoff could potentially carry elevated levels of nutrients or 

chemicals, such as nitrogen and ammonium, as a result of mulch decays. Luminant has not 

accounted for final disposition of 36 million pounds of biomass associated with BDTF clearing. 

Recommendation: TPWD recommends Luminant consider the potential effects to water quality 

from stormwater runoff associated with decaying hydromulch material and include measures to 

monitor and/or treat such runoff water in the Stormwater Pollution Prevention Plan for the 

CPNPP site. TPWD recommends the applicant find a beneficial use for excess mulched 

vegetation that would not be needed for hydraulic mulching. Beneficial use could be in the form 

of materials donation to the Texas Department of Transportation Fort Worth and Waco Districts 

for erosion control on road construction projects or recycling at a composting facility. (0068-35

[Melinchuk, Ross] [Wicker, Julie])

Response: EIS Section 4.2.3 has been expanded to provide additional discussion on the 

potential for impacts from stormwater runoff from areas treated with mulched wood waste. 

Because the projected quantities of this material appear to exceed the quantity that could be 

used beneficially on-site, the other beneficial uses suggested by the commenter may be good 

ways to mitigate some potential impacts. The NRC has no authority to require best 

management practices (BMPs), monitoring, or mitigation measures such as this one to prevent 

nonradiological water quality impacts from site runoff. Any requirements for Stormwater 

Pollution Prevention Plan provisions or other mitigation measures would be the responsibility of 

the EPA or the Texas Commission on Environmental Quality under the authority of the Clean 

Water Act and other laws. 

Comment: Since all the talk of the new reactors has started suddenly the lake is being kept 

above the 692.5 feet BRA says it trys to maintain. The lake level figures can be readily acessed 

at the USGS. lake level site. I personaly believe that there is some monetary hanky panky 

going on here but I can not believe that our officals on Lake Granbury would do that. (0013-2

[Phillips, Doug])

Comment: This has been one of the hottest summers in several years and official reports show 

we were over 5 inches of rain below normal yet the lake has remained full. What happened to 

the evaporation the BRA has blamed the previous low levels on? (0038-3 [Lowrance, Cleo])

Response: Luminant applied to the NRC for a combined operating license for proposed Units 3 

and 4 in September 2008. The review team held public scoping meetings for this EIS in 

January 2009. USGS records available at http://waterdata.usgs.gov/ indicate that water levels 

in Lake Granbury fell below normal full pool early in the summer of 2008 and remained low until 

the fall of 2009. The water level started to recover in September 2009 and the lake has been at 

or near full pool since October 2009. The lake’s recovery in September and October 2009 can 

be explained by the unusually heavy rainfall that the region received in those months (see 

Romolo 2009a and 2009b, below in this response). NOAA Southern Regional Climate Center 

data (available from http://www.srcc.lsu.edu/monthlyclimrpt/) indicate that several of the 

following months were much wetter than normal in the watershed above Lake Granbury; this 

would have allowed water levels to be maintained even if there was relatively little rain in the 

immediate area of the lake. No changes were made to the EIS as a result of this comment. 
Appendix E 

May 2011 E-41 NUREG-1943 

 Romolo, Luigi. 2009a. Monthly Climate Summary, September, 2009. NOAA Southern 

Regional Climate Center. Retrieved from http://www.srcc.lsu.edu/monthlyclimrpt/, 

November 29, 2010. 

 Romolo, Luigi. 2009b. Monthly Climate Summary, October, 2009. NOAA Southern 

Regional Climate Center. Retrieved from http://www.srcc.lsu.edu/monthlyclimrpt/, 

November 29, 2010. 

Comment: According to the Draft Statement, the consumptive use of water for Units 3 and 4 

will be 62,700 acre-feet/year from Lake Granbury, and 92,600 acre-feet/year with all four 

reactors running. The DEIS states on page 2-21 that less than 20,000 acre-feet are lost to 

evaporation in Units 1 and 2. EPA needs an explanation as to why there is such a large 

increase in consumptive water use with Units 3 and 4. Please discuss in the FEIS. (0070-8

[Smith, Rhonda])

Response: The difference in water consumption is explained by the use of different 

technologies for reactor heat dissipation. Units 1 and 2 use once-through cooling, whereas 

Units 3 and 4 would use mechanical-draft cooling towers. In once-through cooling systems, 

cooling water is returned to a body of water after circulating through the nuclear unit just once. 

The surplus heat from the reactor is discharged to the body of water. This increases the water 

temperature; it also increases evaporation, but this is a secondary effect occurring as a result of 

higher water temperatures. In contrast, in mechanical-draft cooling, surplus heat is discharged 

to the atmosphere through the physical process of evaporation of cooling water. The reliance 

on evaporation as a heat-dissipation mechanism means that much more water is lost to 

evaporation than with once-through cooling. The comparative impacts of different heatdissipation technologies are discussed in the EIS in Section 9.4.1; that section has been revised 

to include additional information on their impacts on water use. 

Comment: [T]he Nuclear Regulatory Commission has relied too heavily on preliminary design 

and performance data furnished by the Applicants to conclude that projections of water usage 

from Lake Granbury and the extended Brazos River system (including Possum Kingdom Lake) 

will not have large (i.e., serious) long-term negative impacts on the environs of the river, and its 

lakes. (0055-1 [Inge, Charles] [King, Arnold] [Rosenfeld, Joshua])

Comment: [T]he Nuclear Regulatory Commission has relied too heavily on preliminary design 

and performance data furnished by the applicant to conclude that projections of water usage 

from Lake Granbury and the extended Brazos River system, including Possum Kingdom Lake 

will not have a large, that is serious, long-term negative impacts on the environs of the river and 

its lakes. (0063-36-1 [Hackett, Ken])

Response: Section 3.2.2 of the EIS provides a description of the proposed new units 

structures with environmental interfaces. Some of the design information and other data used in 

the EIS are preliminary. This is consistent with guidance from the Council on Environmental 

Quality, which advises that NEPA documents should be prepared early in an agency's decision 

process, typically before detailed designs may be available. In its regulation 40 CFR 1501.2, 

the CEQ states that this should be done "to insure that planning and decisions reflect 

environmental values, to avoid delays later in the process, and to head off potential conflicts." 

The proposed new units affects on surface water use is described in Section 5.2.2.1 of the EIS. 

Where uncertainty exists regarding details needed in an EIS analysis, the review team has 

made conservative assumptions that should ensure that the EIS does not underestimate 

environmental impacts. The review team determined that the operation of CPNPP Units 3 and 

4 would have a noticeable affect of surface water uses. 
Appendix E 

NUREG-1943 E-42 May 2011 

Comment: One other thing about Lake Granbury is it builds up with sediment. At a certain 

point the BRA even stated that Lake Granbury will become a dead lake. My concern is not for 

today but off into the future. When you wind up with sedimentation built up and you don't have 

as much water in Lake Granbury the level might look the same but it's going to actually be full of 

sediment down in the bottom regions. If you're pulling water out of Lake Granbury, out of the 

channel, the channel is going to be the first part to start building up with this sedimentation. 

(0063-7-6 [Pratt, Rickie])

Response: The effect of future sediment buildup in Lake Granbury is included in the water 

availability models that are used in the EIS. Additionally, a discussion of current sediment 

patterns is provided in Section 2.3.1.1 on page 2-18 of the EIS. No changes were made to the 

EIS as a result of this comment.

Comment: I know there are a lot of people that are here that are better experts at speaking to 

the water issues than I am. And I'm going to let them take the lead in that. But I want to lift that 

up as a second point. I think the analysis of the Environmental Impact Statement is 

fundamentally flawed with regards to the water issue. (0063-5-3 [Burnam, Lon])

Response: Impacts to water uses are described in Section 4.2.2 and 5.2.2 of the EIS. This 

comment expresses concerns about the EIS analysis of water-related impacts, but it provides 

no specific information about those concerns and will therefore not be considered further in the 

staff's environmental review. No changes were made to the EIS as a result of this comment.

Comment: I have just read the NRC study for the Comanche Peak Nuclear Complex. As a 

property owner in Ports O’Call, Granbury, Texas, I am appalled and concerned at its 

implications! Predicted population expansion around Lake Granbury in the next 50 years will 

apparently result in an increased demand for water of 21%. At the same time, a loss of 25% 

water volume is predicted on the basis of sedimentation. Add to that, the water usage 

requirements for the cooling of the expansion known as Comanche Peak 3 and 4, and the entire 

environment surrounding the lake is at risk (0003-1 [Apple, Thomas])

Comment: According to the NRC studies in the years to come there will be 21 percent more 

water demand from just population grown. This doesn't include any power plant water. So 

household water will increase by 21 percent. And this is going to have an impact. (0063-15-5

[Williams, Joe])

Comment: We already talked about de-sedimentation. According to the study 25 percent of 

the lake will be full of sedimentation here in the next 50 years. So that decreases the amount of 

volume. (0063-15-6 [Williams, Joe])

Response: The EIS considers future population increases in the region, increased demand for 

Brazos River water, and reservoir sedimentation based on projections contained in the Texas 

Water Development Board's Brazos G Regional Water Plan and related planning documents. 

The impacts analysis presented in EIS Section 5.2.2.1 considers the effects of water usage for 

Comanche Peak Units 3 and 4 in combination with the other water demands and reservoir 

sedimentation conditions projected for the year 2020. The discussion of cumulative surface 

water impacts presented in EIS Section 7.2.1.1 considers the effect of increased water demand 

projected for later decades. Section 7.2.1.1 has been revised in the final EIS to provide more 

quantitative information on future cumulative impacts. 

Comment: The plan will exhaust the water from Lake Granbury (0001-2 [Boyd, John])
Appendix E 

May 2011 E-43 NUREG-1943 

Comment: Granbury is a very shallow lake which struggles to get by in the dry summer 

months. The proposed water use plan would destroy everything that has been gained since the 

lake was created in the 1960s. (0001-5 [Boyd, John])

Comment: Since I moved here in 2001 BRA has been unable or unwilling to keep Lake 

Granbury at a reasonable level. I have been coming here since the early 40's because all of my 

family is from this area and many times as a preteen I have swam across the Brazos river 

because of the numerous droughts keeping it more like a creek than a river. I believe that 

thousands of people that are currently living on the lake will not be able to access the lake in the 

summer when they would like to use it a majority of the time (0013-1 [Phillips, Doug])

Comment: I believe that additional selling of water from Lake Granbury, by the BRA to 

support Comanche Peak Expansion 3 and 4, will cause detrimental effects to our lake and 

significantly reduce the water levels. (0018-1 [Thompson, Sue])

Comment: The Comanche Peak Expansion will result in a net loss of 60 million gallons of 

water per day from Lake Granbury. The lake will be full only 46% of the time. It will be 2 feet or 

more lower 25% of the time. During drought conditions the water level would be 6 to 8 feet low. 

How can we allow this to happen? (0023-1 [Hinterleiter, David])

Comment: As resident of Hood County, I would like to voice my concern about the proposed 

expansion of the Comanche Peak Power plant. Please advise how this can be done without 

impacting the Brazos River basin and Lake Granbury? (0028-1 [Lawson, Donny])

Comment: The water levels of Lake Granbury vary enough due to factors of nature and man, 

so the addition of new nuclear reactors would obviously decrease the water levels significantly. 

(0033-2 [Hanna, Jim])

Comment: I am a waterfront property owner on Lake Granbury and am concerned about the 

amount of water that will be lost if all the water for the Comanche Peak expansion comes from 

the Brazos River. (0038-1 [Lowrance, Cleo])

Comment: I would like to voice my concern over the possibility of the BRA additional use of the 

water at Lake Granbury. (0045-1 [Jacobson, Jake])

Comment: What will the effect on the water level of Lake Granbury be with the addition of plant 

units 3 & 4? (0061-1 [Quirk, Jim])

Comment: I just very briefly want to state, not against the power going in, but I'm really 

concerned about the water at Lake Granbury. (0062-14-1 [Williams, Robert])

Comment: Reading from the draft statement about the water usage it says, During operation of 

all four reactors Luminant would withdraw a total volume for approximately 137,800 feet, which 

incidentally is more capacity that is in the lake. Of course, it refills during the year. But so 

137,800 acre-feet from Lake Granbury, while approximately 42,000 feet per year would be 

returned to the lake, a net loss of 96,800 acre-feet per year. Approximately 34,000 acre-feet of 

Lake Granbury was used -- was consumed maintaining Squaw Creek Reservoir in support of 

units 1 and 2. So overall, with all four units working there's about a 70 percent loss of the water 

that's pulled out according to the draft statement. (0063-1-1 [Answorth, Charles])

Comment: A few weeks ago gathering with a few of my friends we were discussing about the 

NRC study and, you know, of course, concerning the expansion and the impact it would have on 

Lake Granbury. Sixty million gallons gone every day. The lake would be much lower. There 

would be longer durations of drought on the lake that would occur. This is from the NRC study. 

(0063-15-2 [Williams, Joe])
Appendix E 

NUREG-1943 E-44 May 2011 

Comment: But we have the problem that we are adamantly opposed to them drawing 20 billion 

gallons a year more out of Lake Granbury to cool the two new towers at Comanche Peak. 

We're retired business people. We spent our whole life, between us 90 years, in business. And 

we certainly don't oppose business, we don't oppose nuclear power. But we do not want them 

to drain Lake Granbury. (0063-25-1 [Williamson, Frank])

Comment: I'm your neighbor over in Dallas-Fort Worth. I've worked on air and water issues for 

15 years. And I am here to echo the concerns of some of the citizens here today about the 

water issue that's been expressed today. You can't replace water once it's gone. And some of 

the analysis and some of the comments given today about the amount of water that could be 

going out of Lake Granbury is of concern and needs further evaluation. (0063-29-1 [Benning, 

Rita])

Comment: The DEIS points out that the water level at Lake Granbury would drop which is of 

great concern to SEED Coalition and many local citizens. (0071-10 [Hadden, Karen])

Response: The comment expresses general concern about the impacts of the proposed new 

units on water levels in Lake Granbury. EIS Section 5.2.2.1 presents the assessment of 

impacts on Lake Granbury water levels from the proposed new units. Section 5.2.2.1 has been 

revised to provide additional details of the analysis of impacts to Lake Granbury and Possum 

Kingdom Lake.

Comment: My husband and I adamantly oppose the use of water from the BRA for cooling 

new towers at Comanche Peak! Hopefully our group will be loud enough and powerful enough 

to get this rape stopped! (0039-1 [Peralta, Patsy and Dan])

Response: The comment expresses opposition to the proposed action due to concern about 

the impacts of the proposed new units on water levels in Lake Granbury. EIS Section 5.2.2.1 

presents the assessment of impacts on Lake Granbury water levels from the proposed new 

units. Section 5.2.2.1 has been revised to provide additional details of the analysis of impacts to 

Lake Granbury and Possum Kingdom Lake. 

Comment: If Lake Granbury is lowered even 20 feet, the following will result (using only area 

from City Beach to Indian Harbor): 

1. No water at City Beach, behind the Hilton or new Convention Center (main river channel on 

opposite side). 

2. No water in canals or behind houses near 377 bypass before the bridge. 

3. No water behind new developments -- Waters Edge, most of Harbor Lakes, and Harbor 

Lakes canals. 

4. No water behind homes or in canals in Ports O'Call and Indian Harbor. Canals and Coves 

off Aztec and Lands End at “normal” level have 6 feet or less. 

This situation will apply in other areas as well. This is only an example. (0011-3 [Williamson, 

William F. (Frank) and Eileen G.])

Comment: If it's lowered 20 feet the following will result. And this is only using the area from 

City Beach up to Indian Harbor where I live. There will be no water at the City Beach. There 

will be no water behind the Hilton. No water behind the convention center. As the main river 

channel is on the opposite side from where they sit. There will be no water in the canals or 

behind the houses along that area from 377 up by the bridge there. 

There will be no water behind the new developments. Waters Edge. Probably $100 million 

worth of new homes that have gone in there recently. No water in Harbor Lakes canals. No 
Appendix E 

May 2011 E-45 NUREG-1943 

water behind the homes or in the canals in Ports of Call or Indian Harbor. No water in the 

canals or coves off of Aztec. Literally thousands and thousands. And we can say this is 

minimum effect. (0063-25-3 [Williamson, Frank])

Response: The comments describe some of the impacts that would occur to the Lake 

Granbury lakefront if the lake water level were to drop 20 feet below its normal full pool. 

Section 5.2.2.1 of the EIS provides a description of the effects of the withdrawal of water from 

Lake Granbury associated with the operations of the proposed Units 3 and 4 under year 2020 

conditions, with all water rights fully exercised, for the conditions recorded in 68 years of 

streamflow records. The largest drop in water level found in that analysis was less than 10 

feet. A 20-foot water level drop might be possible, either with or without the proposed new 

CPNPP units, but it is very unlikely. As a result of these comments on impacts to Lake 

Granbury, Section 5.2.2.1 has been revised to provide additional details of the analysis. 

Comment: After years of research and construction modifications within the scope of this 

+$25B project it would appear to most of us in the area that better care for the use and return of 

safe water would have been considered for this project. According to Federal reports on the 

initial 2 reactors there is no return of water resources back to the water shed once taken. That 

already has a devastating impact during drought and marginal rain fall periods for both Possum 

Kingdom and Lake Granbury communities. It also overtly demonstrates the lackadaisical 

attitude expressed by the NRC and the private sector towards the needs of our communities. 

Either figure out how to return a significant portion of the water for All reactors (new and old) 

during the proposed upgrade or move the project to another basin like the Colorado River 

system near or on Lake Austin (a constant level lake). Share the burden so to speak. (0016-2

[Murphy, Bill])

Response: The comment asks for consideration of several alternatives to reduce the impact of 

the proposed new units on water availability in Possum Kingdom Reservoir and Lake Granbury. 

The review team and the applicant have explored alternatives to reduce this impact, as 

documented in EIS Chapter 9. Section 9.4 presents the review team’s assessment of several 

system design alternatives, including alternatives to reduce water use, and Section 9.3 presents 

the review team’s assessment of alternative sites that the applicant considered, including sites 

outside the Brazos River basin. This comment did not result in any changes to the EIS.

Comment: After receiving the blown up advertisement for the Luminant company about the 

Comanche Nuclear power plant and it's proposed expansion, I knew I had to write you. In the 

ad it went on and on about how they had helped to pay for the construction of Lake Granbury 

and through all of the hoopla indicated that they practically owned the lake.There was no 

mention about the water they plan to be taking from the lake when they build two more plants. 

Even when they return (maybe 30%) anyone can tell that eventually the lake would be dried up. 

(0029-1 [Petry, Susan])

Response: As discussed in Section 5.2.2.1 of the EIS, analysis indicates that the additional 

water use for operation of Units 3 and 4 would result in lower water levels in Lake Granbury. 

The independent review conducted by the review team did not discover a scenario in which 

Lake Granbury would dry up. As a result of these comments on impacts to Lake Granbury, 

Section 5.2.2.1 has been revised to provide additional details of the analysis of impacts to Lake 

Granbury. 

Comment: The Draft EIS indicates that Lake Granbury would be 2 feet or more below full pool 

10% of the time without units 3 & 4 and 25% of the time with the additional units. It concludes 

that the effect is only 15% of the time and characterizes this as a moderate impact. This is 

flawed, in that it is, in fact, a 250% increase in the time that Lake Granbury would be 2 feet or 
Appendix E 

NUREG-1943 E-46 May 2011 

more below full pool. Obviously this is a large impact rather than moderate. (0043-1 [Veale, 

James])

Response: The conclusion of “moderate” impact that is stated in the EIS is not based on the 

“15% of the time” projection stated in the comment. The NRC has established three levels of 

impacts -- small, moderate, or large -- that provide a common framework for categorizing 

impacts. The three levels are defined below: 

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

destabilize nor noticeably alter any important attribute of the resource. 

 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. 

Consistent with this framework, the review team determined that water use for operation of 

Units 3 and 4 would noticeably alter important attributes of the surface water resource, but 

would not destabilize the resource. Thus, water use would have MODERATE impacts on 

surface water resources. The conclusion is based on the percentage of time that both Lake 

Granbury and Possum Kingdom Lake will be at full pool and changes to the flow of the Brazos 

River downstream of Lake Granbury and Possum Kingdom Lake. Section 5.2.2.1 has been 

revised to provide additional details of the analysis of impacts to Lake Granbury.. 

Comment: [T]he amount of water that is going to be drawn by the plant will be of minimal 

Impact on Lake Granbury's water table. Palo Verde drew very little from it's supply source, and 

that plant was much larger. I do not find this a concern of any magnitude. (0046-2 [Robinson, 

Pennie])

Response: The comment expresses an opinion on how water use for the proposed units would 

affect water levels in Lake Granbury. A quantitative analysis of the size of the impact on water 

levels is presented in EIS Section 5.2.2.1. This comment did not result in any changes to the 

EIS. 

Comment: The NRC report considers no study in regards to the impact downstream that the 

additional water losses that would occur with the Comanche Peak Expansion. Currently, the 

BRA is seeking an increase in water rights with TCEQ in the amount of 500,000 acre ft. 

100,000 acre ft would be needed for the Comanche Peak Expansion. Dow Chemical, Friends 

of the Brazos, and others have filed an injunction (see attached) to temporarily prevent the BRA 

from being awarded all the water rights that they seek. (0051-7 [Jalbert, Ann] [Jalbert, Pete] 

[McHugh, Judy] [Williams, Joe] [Williams, Sue])

Comment: I asked the NRC, what if you can't get the water because BRA does not get their 

water rights approval? What would you do? And they said, That's not our concern; that's 

between Luminant and the BRA. (0062-12-2 [Williams, Joe])

Response: Luminant's proposal to construct and operate Comanche Peak Units 3 & 4 is based 

on the assumption that BRA's application for a new system operating permit (SOP) will be 

approved by the State of Texas. The State’s approval of the SOP would grant additional water 

rights to the BRA, as noted in the comment. The review team cannot speculate on whether and 

how Luminant might change its proposal if the State denies the BRA's application for a new 

SOP or if the legal challenges described in the comment are successful. This comment did not 

result in any changes to the EIS. 
Appendix E 

May 2011 E-47 NUREG-1943 

Comment: Now, if you don't have a concern, who does? Well, let's try Dow Chemical. Dow 

Chemical has filed an injunction against the BRA to stop them from getting these water rights. 

That's why it's taken six years since they've applied for these water rights, and they haven't 

been able to get them yet. Who else is in this injunction? Matthews Land & Cattle Company, 

Texas Westmoreland Coal Company, Aldine Improvement District Number 11, Number 15; the 

City of Bryan and the City of College Station. They may have made a deal; I haven't quite 

figured that one out, so they maybe dropped out. Friends of the Brazos, the National Wildlife 

Federation, the Gulf Coast Water Authority, Bradley B. Ware, George Bingham out of 

Comanche. They've got a group of people. 

All these people are trying to block the water rights that the BRA is seeking, 500,000 acre- feet 

adds up to about 165 billion gallons. That's what they're seeking. Now, why would Dow 

Chemical and friends -- why would they be concerned? They said it's minimal impact that the 

Comanche Peak will have on it. Why are they concerned? If it's not a concern, why are they 

trying to block these rights? (0062-12-3 [Williams, Joe])

Comment: Right now the BRA has gone to the state and are asking for 500,000 more acre-feet 

of water rights to sell on the market. 500,000 acres. That is basically the whole Brazos River 

basin. Out of that 500,000 acre-feet 100,000 acre-feet will go to the Comanche Peak 

expansion. They don't even have their water yet. The state hasn't allowed it. They haven't 

agreed to that. he community's hedge against the drought and the environmental damage is 

just 500,000 acre-feet. This is our hedge that we always have been ensured over the years that 

we would never have severe drought conditions out there. How do I know that it's a hedge? I 

don't have to tell you. 

Let Dow Chemical tell you. Dow Chemical, Friends Along the Brazos, the National Wildlife 

Association, they have an injunction with the -- down there in Austin to block the BRA from 

getting these contracts. So it's not only us. It's several people on the Brazos. They know. 

(0063-15-8 [Williams, Joe])

Response: The NRC is not a party to the lawsuit described in the comment and cannot 

speculate on the motivations of the plaintiffs. The review team’s assessment of the impacts on 

the Brazos River system from operation of Units 3 and 4 is presented in Section 5.2.2.1. This 

comment did not result in any changes to the EIS. 

Comment: While Luminant's partnership with and contributions to the community cannot be 

discounted, it must be fairly balanced against the concerns of the citizens of Hood County for 

the preservation of the lake. I applaud the steps that Luminant has taken thus far that will serve 

to reduce the impact the reactors will have on the lake, such as designing a return of 40% of the 

new required water to the lake. (0057-3 [Keffer, James L.])

Comment: While Luminant's partnership with and contributions to the community cannot be 

discounted, it must be fairly balanced against the concerns of the citizens of Hood County for 

the preservation of the lake. I applaud the steps that Luminant has taken thus far that will serve 

to reduce the impact of the reactors that they will have on the lake, such as designing a return at 

40 percent of the new required water to the lake. (0063-4-3 [Regas, Tori])

Response: The comment notes that Luminant's proposal includes elements designed to 

partially mitigate the project's impacts on Lake Granbury. This comment did not result in any 

changes to the EIS. 

Comment: Secondly, there is a significant safety concern should the regular level of the lake 

be 1 to 1.5 feet below the historical regular level, not to mention the highly increased hazards in 

low rain or drought conditions. The lake, as you all know, has many trees and stumps only a 
Appendix E 

NUREG-1943 E-48 May 2011 

short distance below the regular lake level that are hazards to boaters and skiers when the lake 

level is reduced. (0058-2 [Huett, David]) 

Response: Section 5.2.2.1. provides a description of the effects of withdrawal of water from 

Lake Granbury on water levels. Boaters and skiers should expect that lake levels will fluctuate 

with or without the proposed new units. This comment did not result in any changes to the EIS. 

Comment: When the question of possible flooding is brought up, the answer has been that the 

lake is regulated to a constant level and even though there may be flooding downstream, the 

lake level will be maintained. Examples of flooding on the river in Pecan Plantation have been 

sighted as the results of such an event. The discussion usually stops there. (0058-4 [Huett, 

David])

Response: Reservoir operation is the responsibility of the BRA. The NRC does not have 

responsibility for managing Brazos River reservoirs, nor does it have authority over BRA’s 

management of the Brazos River reservoirs. The NRC is not aware of any commitment by the 

BRA to maintain a constant water level in Lake Granbury. This comment did not result in any 

changes to the EIS. 

Comment: The Lake Granbury Waterfront Owners Association (LGWOA) was formed in 2007 

to monitor water quantity and quality on Lake Granbury, oversee property tax evaluations, and 

seek economic stability for the city of Granbury. LGWOA has several hundred members along 

with thousands of Hood County and statewide contacts regarding Lake Granbury. We have 

thoroughly reviewed the U.S. Commission's Draft Report for Comment, published in August 

2010, concerning Luminant's application for licensing of the Comanche Peak Expansion 3 and 

4. Our research here at LGWOA, finds that the water level impact study on Lake Granbury and 

the Brazos River Basin has not been thoroughly reviewed, and there were other studies that 

were not considered. (0051-1 [Jalbert, Ann] [Jalbert, Pete] [McHugh, Judy] [Williams, Joe] [Williams, 

Sue])

Response: This comment states that the review team did not consider other studies relevant to 

Lake Granbury water level and impacts in the Brazos River basin. This comment refers to an 

unpublished study by Trungale Engineering & Science dated 2009 that is appended to the 

comment letter which addresses Lake Granbury water levels and impacts in the Brazos River 

basin. The review team reviewed the Trungale report during preparation of the final EIS. The 

review team found that Trungale's study discusses the impact of instream flow changes on 

aquatic ecosystem health. These impacts are discussed in EIS Section 5.3.2. Section 2.3.1.1 

of the EIS provides a discription of the surface-water hydrology and Section 5.2.2.1 provides a 

discussion of the impacts of the proposed units on surface-water uses. The review team found 

that Trungale's report does not introduce any new information on instream flow thresholds or 

hydrologic conditions that was not already discussed and reviewed in the draft EIS. Therefore, 

this comment did not result in any changes to the EIS text. 

Comment: The issue is not the building of the plant but the additional cooling water 

requirements that will be imposed by units 3 and 4. With the current usage of 45,000 acre feet 

per year for units 1 and 2, we have had several years where the lake was not usable for boating 

during the summer months. This year the BRA has supplied Lake Granbury with enough water 

to sustain peak levels. Last year, with slightly less rainfall than this year for the summer 

months, the lake was down 2 to 3 feet. Creating an unusable lake. The EIS says that this falls 

into the 10 percent category where the lake would be down 2 or more feet. (Since the summer 

months has the least rainfall, then it is safe to assume that the 10 percent will always fall in the 

summer months) It the more feet that scares me. I'm told that the current agreement would 

allow the lake to be drawn down to 17 foot level. That agreement is in place and will stand for 
Appendix E 

May 2011 E-49 NUREG-1943 

units 3 and 4 as well. The project of usage for units 3 and 4 is 65,000 acre feet per year. That 

is a total of 110,000 acre feet per year for all four units. Lake Granbury holds 105,000 acre feet. 

Since Granbury doesn't even hold what the units will use, the EIS conclusion of little impact is 

totally dependent on rainfall. And rainfall is unpredictable at best. (0048-1 [Bernier, Jim])

Response: The comment expresses concern about the impacts of the proposed new units on 

water levels in Lake Granbury, comments on the low water levels of 2009, and expresses 

several opinions about the timing and predictability of periods of low water level. Water levels in 

the lake do not respond only to recent rainfall in the immediate area in the lake. Rather, they 

are affected by rainfall over long periods in the large watershed above the lake. The low water 

levels in 2009 resulted from the combined effects of the closure of the hydroelectric plant at 

Morris Sheppard Dam and a prolonged period of below-normal rainfall in upper portions of the 

Brazos River watershed. That drought ended after heavy rains in the fall of 2009, which 

resulted in more normal lake levels in much of 2010. Rainfall can be unpredictable in the short 

term. However, the modeling discussed in EIS Section 5.2.2.1 considers conditions in the entire 

watershed and the variability in rainfall and streamflow that was observed over a 68-year 

period. The findings reported in Section 5.2.2.1 are based on this long-term modeling. As a 

result of this comment on impacts to Lake Granbury, Section 5.2.2.1 has been revised to 

provide additional details of the analysis. Please note that low water levels in Lake Granbury do 

not always correspond with the summer months. 

Comment: I conclude to you, ladies and gentlemen, this is The Perfect Storm that they don't 

want to talk about. Let me conclude. We're asking today that Luminant not be a participant in 

The Perfect Storm. Please redesign the system, withdraw your pipes out of Lake Granbury. 

For the past 20 years we have supported Comanche Peak. Now it's Luminant's time to support 

the integrity in Lake -- of Lake Granbury and the Brazos River basin. Please do not take our 

water. (0063-15-9 [Williams, Joe])

Response: The comment expresses opposition to the proposed design of CPNPP Units 3 and 

4 due to concern about impacts to Lake Granbury and the Brazos River basin. Section 5.2.2.1 

of the EIS provides a description of the effects of water use by the proposed units on Lake 

Granbury. No changes were made to the EIS as a result of this comment. 

Comment: It is my understanding that the proposal will result in water levels at Lake Granbury 

that are approximately 5 inches lower during good weather and as much as 6.5 feet lower 

during extreme drought conditions. Some studies estimate the levels could be as much as 8 

feet lower! This past year’s lake levels were reported to be 4 feet lower than normal, so simple 

arithmetic would indicate that had these two towers been in operation and using cooling water 

from Lake Granbury, lake levels would have been between 10.5 and 12 feet lower than normal! 

I believe the proposed use of water for cooling Comanche Peak 3 and 4 to be ill advised, both in 

the immediate future and for some years to come. (0003-2 [Apple, Thomas])

Response: The comment expresses opposition to the proposed design of CPNPP Units 3 and 

4 due to concern about impacts to Lake Granbury. The numerical estimates of impact to Lake 

Granbury that are cited in the comment do not fully agree with the estimates presented in EIS 

Section 5.2.2.1. For example, the analysis presented in that section indicates that Lake 

Granbury would be at its normal full pool for 46% of the time, not 5 inches lower. See Section 

5.2.2.1 for additional details. Section 5.2.2.1 has been revised to provide additional details of 

the analysis of impacts to Lake Granbury. 

Comment: Possum Kingdom dwarfs Granbury Lake in size and in depth and capacity. That 

difference in size must be reflected in the commitment of water for this project. To my 
Appendix E 

NUREG-1943 E-50 May 2011 

knowledge BRA has made a commitment for Granbury but not for Possum Kingdom. THIS IS A 

DEAL BREAKER. (0002-1 [Uhlhorn, Ralph])

Comment: We are extremely excited about it in Hood County. Those of us that live on the lake 

are excited about it. We may even end up with more water in our lake because they've got to 

supply more water to Luminant. (0063-23-2 [Conway, Bretta])

Response: The review team’s analysis of water use impacts, presented in EIS Section 5.2.2.1, 

assumes that the BRA would be able to commit the necessary water for the proposed project as 

a result of implementing its proposed system operating plan (SOP). Under that plan, the 

operations of the dams that control Possum Kingdom Reservoir, Lake Granbury, and other 

Brazos River system reservoirs would be modified to optimize water availability for all of BRA's 

contracted water users. Water contracts would commit water from the flow of the river, not from 

a specific reservoir. Water for CPNPP Units 3 and 4 would be withdrawn from Lake Granbury, 

but water levels in both Lake Granbury and Possum Kingdom Reservoir would be affected. No 

changes were made to the EIS as a result of this comment. 

Comment: Please consider the impact of the BRA's request to increase the amount of water it 

can sell. While I understand that the BRA does not guarantee any lake levels as it sells water, 

there is more at stake with the current request than merely having lower lake levels. (0006-1

[McClain, Janet])

Response: The NRC does not have a role in deciding whether the BRA is granted approval to 

implement its proposed system operating plan (SOP). Under that plan, the BRA would modify 

the operation of the dams that control Brazos River system reservoirs to increase the amount of 

water available to the BRA's contracted water users. Under the SOP, the water supply 

requirements of CPNPP would be one factor in determining the volume and timing of water 

releases from Possum Kingdom Reservoir. The review team’s analysis of water use impacts, 

presented in EIS Section 5.2.2.1, assumes that the BRA implements the SOP. No changes 

were made to the EIS as a result of this comment. 

Comment: The fact that [the BRA] does not guarantee constant lake levels should not be an 

excuse to ignore negative impacts that reach far beyond having less water. (0006-4 [McClain, 

Janet])

Response: In this EIS, the review team considers the potential environmental impacts of 

constructing and operating the CPNPP Units 3 and 4. The NRC does not have responsibility for 

managing Brazos River reservoirs, nor does it have authority over BRA's management of the 

Brazos River reservoirs. However, the review team has considered the impacts of the BRA's 

proposed system operating plan to the extent that those impacts are related to the impacts of 

the proposed nuclear units. This comment did not result in any changes to the EIS. 

Comment: We simply do not believe they should drain the Brazos River Basin to cool those 

towers. The Brazos River Authority had sold so much water from this Basin that even a slight 

drought had the water level so low last year that residents could not get their boats out of the 

docks and several launch ramps were closed. This extra usage would eliminate most of Lake 

Granbury as well as Possum Kingdom in a few short years, even given normal rainfall. (0011-2

[Williamson, William F. (Frank) and Eileen G.])

Response: The comment provides opinions about the causes of low water levels in Lake 

Granbury in 2009 and about the effects of additional water use on the lake, and it expresses 

opposition to the proposed design of CPNPP Units 3 and 4 due to concern about impacts to 

Lake Granbury, Possum Kingdom Reservoir, and the Brazos River basin. Note that water 

levels in the lake are affected by rainfall over long periods in the large watershed above the 
Appendix E 

May 2011 E-51 NUREG-1943 

lake. Section 2.3.1 of the EIS describes the site-specific and regional hydrological features that 

could be affected by the proposed units. Although the drought may have seemed merely “slight” 

in the Granbury area, the low water levels in 2009 resulted from the combined effects of the 

closure of the hydroelectric plant at Morris Sheppard Dam and a prolonged period of belownormal rainfall in upper portions of the Brazos River watershed. As discussed in Section 

5.2.2.1, analysis indicates that additional water use for the proposed new units would result in 

lower water levels in Lake Granbury and Possum Kingdom Reservoir, but neither lake would be 

eliminated. The NRC does not have responsibility for managing Brazos River reservoirs, nor 

does it have authority over BRA's management of the Brazos River reservoirs. No changes 

were made to the EIS as a result of this comment. 

Comment: The BRA did not exercise “due diligence” in studying the environmental impact the 

loss of 20 million gallons a day would make on Lake Granbury and environments. (0019-5

[McHugh, Judy])

Comment: But what we are asking for the NRC to do is to be as vigilant as we've been in trying 

to keep the word out to the users of water that we've got to be careful with our most precious 

resource. So the thing about not getting enough water through the damn at Morris Sheppard, 

the thing about the property values dropping when we don't have water, all of that should be 

taken into consideration. (0063-23-3 [Conway, Bretta])

Response: The NRC does not regulate or manage water resources, nor does it have authority 

over BRA's management of the Brazos River reservoirs. However, the NRC does have the 

responsibility under NEPA to assess and disclose the impacts of the proposed action on water 

resources, and Section 5.2.2.1 presents the review team’s assessment of the impacts of 

CPNPP Units 3 and 4 water use on Lake Granbury and associated environments. This 

comment did not result in any changes to the EIS. 

Comment: Please reconsider the idea of draining our lake. Take into consideration that 

Possum Kingdom Lake is much deeper than Granbury lake and IF you insist on the new 

development please make an agreement with that if you are going to take our water that BRA 

should release water from Possum Kingdom lake to allow us not to become a mudhole. Our 

normal level now is already lower than it was when we bought our property. We are saddened 

by the thought that no one cares what we, the people, think. (0025-1 [Slough, Gene and Phyllis])

Response: The comment expresses concern about the impacts of the proposed new units on 

water levels in Lake Granbury and suggests using water from Possum Kingdom Reservoir 

instead. Luminant's proposal and EIS analysis both assume that the BRA would modify the 

operations of its dams, including the dams that control Possum Kingdom Reservoir and Lake 

Granbury, to increase the amount of water available for CPNPP and other BRA water users. 

Water contracts would commit water from the flow of the river, not from a specific reservoir. 

Water for CPNPP Units 3 and 4 would be withdrawn from Lake Granbury, but water levels in 

both Lake Granbury and Possum Kingdom Reservoir would be affected. This impact is 

discussed in EIS Section 5.2.2.1. No changes were made to the EIS as a result of this 

comment. 

Comment: The NRC study has no water level impact that has occurred since the closing of the 

Morris Shepherd Hydroelectric Plant at the Possum Kingdom dam in 2007. This closure has 

had a significant impact on the water flow from Possum Kingdom Lake to Lake Granbury. 

(0051-4 [Jalbert, Ann] [Jalbert, Pete] [McHugh, Judy] [Williams, Joe] [Williams, Sue])

Comment: The second problem we have, as you may or may not be aware, a few years ago 

we used to have an electrical plant coming off of Possum Kingdom. Because it was being run 
Appendix E 

NUREG-1943 E-52 May 2011 

by that water, they had to release X amount of water into Lake Granbury. Well, BRA has shut 

down that electrical plant, and as a result, we no longer get that water in Lake Granbury; it just 

adds a second layer of problems that we have with the water at Lake Granbury. (0062-14-3

[Williams, Robert])

Comment: So I don't know that if either of those factors [Morris Shepard Dam not operational 

and BRA selling more water rights that are available] -- I've not read your document -- if they 

were factored into the document or if they were, if they were factored properly. But you need to 

consider these because these have disparate impacts on both of these counties and on the 

ability to survive. (0063-13-3 [Yancey, Darren]) 

Comment: Mayor Pratt hit on something very lightly awhile ago about the potential issue that's 

been created up at Possum Kingdom Lake on the Morris Sheppard Dam with the dam not being 

operational. What he didn't go into detail for you on is the reasons why that dam was shut 

down. It's a breach of contract issue. And there's monies that have been allocated to the State 

of Texas and bond issuance that have not been spent that are basically in dispute that have 

shut that down. And what that dam does is it brings a continuous flow of acre-feet to Lake 

Granbury on a continuous basis. So it not only affects Lake Granbury and Hood County, it 

actually has an impact on Somervell County with flow down the Brazos and on recreational use. 

So you need to keep that in mind. (0063-13-1 [Yancey, Darren])

Comment: Morris Sheppard Dam, hydro-electric. They shut it down. The cleanest, greenest 

energy we could produce. They shut it down. Brazos Electric? They breached their contract 

with them. They wanted to buy it from them and BRA breached the contract. BRA -- I'm sorry. 

Brazos Electric has taken BRA to the Texas Supreme Court on this issue. They are poorly 

mismanaged. Downstream we have Dow Chemical. The Friends Along the Brazos. We have 

those people. They have senior water rights over almost everybody in -- on the Brazos River 

system. Why is this important? They're going to get their water down there. They will get it. So 

it will flow through Lake Granbury and drain on the system and go on downstream. (0063-15-4

[Williams, Joe]) 

Comment: However, the issue of water is of great concern to the constituents and the citizens 

around Lake Granbury. And my concern is that we have an issue with the lake that's up river of 

us. And I'd like for the NRC to be aware of it. It's a lake called Possum Kingdom Dam. It's an 

80 foot deep lake. It's got a hydro-electric plant located at its dam. But the issue is -- and we 

felt this during a drought last year -- is that water can only flow over the dam at a certain level. 

Once that lake reaches a level below that point no water can flow over the dam. It's a manually 

operated dam system in the first place to allow water to flow off the levy. The only other way it 

can generate any water downstream is by way of its hydro-electric plant. The hydro-electric 

plant is capable of pulling water from the lower levels and allows it to flow down river. When we 

wind up not having any water flow our level at Lake Granbury drops tremendously. (0063-7-3

[Pratt, Rickie])

Response: The review team’s impact analysis is focused on the impacts of the proposed 

nuclear units. The review team’s analysis of water use impacts, presented in EIS Section 

5.2.2.1, assumes that the BRA would implement its proposed system operating plan (SOP). 

Under that plan, the BRA would operate its Brazos River system reservoirs to increase the 

amount of water available to the BRA's contracted water users. The volume and timing of water 

releases from Possum Kingdom Reservoir at Morris Sheppard Dam would be adjusted to help 

meet the water supply requirements of CPNPP and other users. Water would be released from 

Morris Sheppard Dam as needed, whether or not the hydroelectric plant is operating. 

Additionally, Section 7.2.1.1 of the EIS provides a description of the impacts of other past 
Appendix E 

May 2011 E-53 NUREG-1943 

present and reasonable foreseeable impacts to surface water uses. Section 5.2.2.1 has been 

revised to include more information on potential impacts to water levels in the lakes.

Comment: The study says the additional units would cause the lake level to go down 2 or more 

feet for 25 percent of the time. That would be 3 months out of the summer. If I'm not mistaken 

there are only 3 months in the summer. And the more, to 17 ft., is a distinct possibility. (0048-3

[Bernier, Jim])

Response: As the comment states, Section 5.2.2.1 of the EIS reports that the new units would 

change the frequency of water levels more than 2 feet below full pool from 10 percent of the 

time to 25 percent of the time. However, this does not necessarily mean that water levels would 

be this low every summer, as low water levels in Lake Granbury do not always correspond with 

the summer months. The largest drop in lake water level in Lake Granbury predicted by the 

model were 6.5 feet below full pool level and would increase to 9.4 feet with the operation of the 

proposed units. These levels were associated with the extreme drought conditions encountered 

during the drought of record in 1953. A drought of record is the worst recorded drought since 

compilation of meteorologic and hydrologic data began and is, therefore, an extreme and 

unusual event. In Lake Granbury, water levels 5 ft or more below full pool are estimated to occur 

about 3 percent of the time under current conditions and 5 percent of the time with the proposed 

units operating. A water level drop of 17 feet may be possible with or without the proposed new 

units, but it was not observed in the model. Section 5.2.2.1 has been revised to include more 

information on potential impacts to water levels in the lakes. 

Comment: The NRC study shows no research in regards to proposed reservoirs to be built 

upstream that would have an additional detrimental effect on Lake Granbury and its water 

levels. In 2006, the construction of the Cedar Ridge reservoir (see attached) was proposed. 

The new reservoir would be located north of Abilene, and would be built on the Clear Fork of the 

Brazos River which currently flows into Possum Kingdom Lake. Studies have now shown that 

Cedar Ridge would actually prohibit more water from reaching Possum Kingdom. This would be 

due to increased evaporation losses (est. 5000-20,000 acre ft.) and losses from the selling of 

water rights to the city of Abilene and other power plant facilities. This loss of Possum Kingdom 

water would have additional negative water level impact on Lake Granbury which has not been 

factored into the environmental impact study. (0051-6 [Jalbert, Ann] [Jalbert, Pete] [McHugh, Judy] 

[Williams, Joe] [Williams, Sue])

Response: The potential effects of Cedar Ridge Reservoir and the proposed additional 

allocation of Brazos River water to the city of Abilene are considered in the Brazos G water 

planning studies that are cited in Section 7.2.1 and used as a basis for assessing cumulative 

impacts of water use for the proposed new units. That EIS section has been revised to include 

additional quantitative information on estimated cumulative impacts. 

Comment: In the light of the rapid population growth affecting this area, along with ongoing 

depletion of the Trinity aquifer. Lake Granbury will increasingly serve as the principal source of 

area water supplies. The authorities responsible for the protection and allocation of our natural 

resources must be certain of the projected water withdrawal and its environmental impacts. 

(0051-12 [Jalbert, Ann] [Jalbert, Pete] [McHugh, Judy] [Williams, Joe] [Williams, Sue])

Comment: In the light of the rapid population growth affecting this area, along with ongoing 

depletion of the Trinity aquifer, Lake Granbury will increasingly serve as the principal source of 

area water supplies. The authorities responsible for the protection and allocation of our natural 

resources must be certain of the projected water withdrawal and its environmental impacts. 

Luminant's application does not provide sufficiently accurate data, nor does it consider 
Appendix E 

NUREG-1943 E-54 May 2011 

alternative plans to permit complete understanding of the additional reactors' impact. (0055-6

[Inge, Charles] [King, Arnold] [Rosenfeld, Joshua]) 

Comment: The other -- the name of the Brazos River Authority's been brought up a couple of 

different times and their lake management system. And I think everybody in the room would 

agree the Brazos River Authority has no lake management system. They have problems. They 

sell off water rights that they don't have. (0063-13-2 [Yancey, Darren])

Comment: Regarding potential water use, it's important to recognize that even if these new 

units are not built there is still a large water demand in the rest of the basin. So if Texas water is 

not used here it will be sold downstream, along with the massive economic developments that 

go with it. (0063-19-2 [Stewart, Michael]) 

Response: The NRC does not have the authority or responsibility to regulate or manage water 

resources, nor does it have authority over BRA’s management of the Brazos River reservoirs. 

The EIS presents an analysis of the impacts of water use for the proposed new units that uses 

information from the authorities that are responsible for managing water resources, including the 

Texas Water Development Board and the Brazos River Authority. Cumulative impacts on water 

resources, including the effect of population growth in the region, are discussed in EIS Section 

7.2. Alternatives are discussed in EIS Section 9. Where uncertainty exists regarding details 

needed in an EIS analysis, the NRC has made bounding assumptions to ensure that the EIS 

does not underestimate environmental impacts. These comments did not result in changes to 

the EIS text. 

Comment: I know that many present are concerned about the water levels in Lake Granbury. I 

recently moved to a home on Lake Granbury, and my young children are looking forward to 

years fishing and boating on our lake. However, opposition to the Comanche Peak expansion is 

not the solution. First, the Brazos River Authority controls the sale of the river's water. If they 

don't commit it to Comanche Peak, they will sell it elsewhere. Opposition to water commitments 

should be address to the BRA. Second, if the water is to be used, the best solution for 

Granbury and Glen Rose is for the water to be used for economic development in our counties. 

Finally, Comanche Peak will be returning about 40% of the water back to Lake Granbury. (0053-

3 [Orcutt, David])

Response: The comment indicates a general concern about the impacts of the proposed new 

units on water levels in Lake Granbury, points out that BRA is the agency that controls water 

allocation, expresses support for water uses that support economic development in Hood and 

Somervell Counties, and notes that Luminant's proposal includes elements designed to partially 

mitigate the project's impacts on Lake Granbury. This comment did not result in any changes to 

the EIS. 

Comment: As Chairman of the Energy Resources Committee in the Texas House, I 

understand the importance to develop nuclear power in this state as a reliable source of energy 

to meet the needs of our rapidly growing population, and the Hood County community appears 

mostly supportive of the construction of the new reactors. I am aware that it was the original 

contract with Luminant, then TXU, that funded the construction of Lake Granbury, and it is 

Luminant's continued presence that, in part, keeps water flowing from upstream sources into 

Lake Granbury. In addition, the construction ofthe two proposed reactors will translate to a 

significant number of badly needed jobs and economic growth to the area and to the state of 

Texas. However, I want to stress the importance of mitigating the impact that the new reactors 

will have on Lake Granbury. (0057-1 [Keffer, James L.])
Appendix E 

May 2011 E-55 NUREG-1943 

Comment: I understand the importance to develop nuclear power in the state as a reliable 

source of energy to meet the needs of our rapidly growing population. And the Hood County 

appears mostly supportive of the construction of the new reactors. I am aware that it was the 

original contract with Luminant, then TXU that funded the construction of Lake Granbury and it's 

Luminant's continued presence that in part, keeps water flowing from upstream sources into 

Lake Granbury. In addition, the construction of the two proposed reactors will translate to a 

significant number of badly needed jobs and economic growth to the area and to the State of 

Texas. However, I want to stress the importance of mitigating the impact that the new reactors 

will have on Lake Granbury. (0063-4-1 [Regas, Tori])

Response: The comment states that it is important to mitigate the impacts of the proposed new 

units on Lake Granbury. The EIS describes potential mitigation measures to reduce the affect 

of the proposed new units on water use and water quality. No changes were made to the EIS 

as a result of this comment. 

Comment: And I want to get something very factual and very straight: The BRA only has 

control of 696,000 acre-feet of the Brazos River basin; that's it. The State limits them, and they 

limit them for a reason. In regards to the lake, the levels go up and down. In the last 20 years 

the lake has gone approximately about two to two and a half feet down, or less, 10 percent of 

the time. You may have a three foot, but about 10 percent of the time it goes down and then it 

comes back up to constant pool. So there's history, 20 years: 10 percent of the time, not very 

often. Now, if you read the studies, that's going to be increased to 25 percent, and they're going 

to be deeper and they're going to be longer. I would like to go forward, though. The BRA -- I'm 

going to make this very short as I can. The BRA, in regard to the contracts that they have now, 

has applied to the State for another 500,000 acre-feet with the TCEQ. Now, 100,000 acre-feet 

will be applied toward the Comanche Peak expansion if they get approval of these rights. That 

means today if they tried to build the plant, BRA cannot provide the water, period, today. (0062-

12-1 [Williams, Joe]) 

Response: Luminant's proposal is based on an assumption that BRA's application to the State 

of Texas for a new system operating permit (SOP) will be approved, allowing BRA to supply 

water to the proposed new units at the Comanche Peak Nuclear Power Plant. The comment 

cites some findings of the EIS analysis of the impacts of the increased water use for the 

proposed new units. That analysis is based on the assumption that the BRA application will be 

approved. No changes were made to the EIS as a result of this comment.

Comment: Joe Trungale is a in-flow study expert throughout the nation. He's out of Austin, 

Texas. It's called Trungale Engineering. He has done -- he's a civil engineer out of the 

University of Washington. He has done project -- these are study projects -- for the Lower 

Colorado River flow study in San Antonio. He's done studies for the Caddo Lake/Cypress Basin 

sustainable river project. He's done studies for the Trinity and San Jacinto basins, all in Texas. 

He's an expert. Did the NRC use his study in their DEIS? No. Why not? I don't really know. 

Did the BRA know about this study? Oh, yes, they know about the study. I'm going to give you 

the conclusion to this study. Listen very carefully. The duration of drought events would also be 

expected to have substantially increased under the water management plan that includes the 

Comanche Peak expansion project 3 and 4. 

Listen: Under natural conditions, without the expansion 3 and 4, only two drought events lasted 

more than three months, and none any longer lasted more than four months. Under the 

proposed plans -- expansion of Comanche Peak 3 and 4 -- there are more than 20 events in 

which drought conditions are four continuous months or more, and one event that will last over 

17 continuous months. (0062-12-4 [Williams, Joe]) 
Appendix E 

NUREG-1943 E-56 May 2011 

Comment: How do they know? How in the hell do they know that this 500,000 acre-feet that 

the BRA want -- how do they know that it's going to be a problem? Trungale studies. Joe 

Trungale is a civil engineer out of Washington. Nobody has talked about the Trungale studies. 

The NRC -- they did their study. Did they consider the Trungale studies? No. Who is Joe 

Trungale? Who is engineering. He -- Okay. Trungale is -- he has done studies on the Lower 

Colorado River. He's done it on the Caddo Lake. He's done it on the Trinity River. He has also 

done it on the Brazos River basin. This is the conclusion. Listen very carefully. The duration of 

drought events would also be expected to substantially increase under the water management 

plan that includes the proposed Comanche Peak 3 and 4 project. 

Listen. Under natural conditions without 3 and 4 only two drought events lasted more than three 

months and none lasted more than four months. Under the proposed plans adding the additions 

of 3 and 4 there are more than 20 events in which drought conditions are going to be four 

continuous months or more. And one event that lasts for 17 continuous months. (0063-15-10

[Williams, Joe]) 

Response: These comments refer to an unpublished report by Trungale Engineering & 

Science dated April 2009 that was provided to the review team. The Trungale report discusses 

the potential effects of Units 3 and 4 on instream flows deemed necessary for aquatic 

ecosystem health. These impacts are discussed in EIS Section 5.3.2. The review team found 

that Trungale's report does not introduce any new information on instream flow thresholds or 

hydrologic conditions that was not already discussed and reviewed in the draft EIS. Note that 

when the Trungale report states that the severity, frequency and duration of "drought" would 

increase, a "drought event" is defined as a "continuous period of time during which flows remain 

below recommended targets" for instream flow. The time periods when streamflows do not 

meet criteria for aquatic ecosystem health do not necessarily correspond to periods of low lake 

water levels. No changes were made to the EIS as a result of this comment.

Comment: As someone mentioned earlier, Hood County is a very, very fast-growing county. I 

believe they said it tripled, you know, ten years and tripled again. I don't remember the exact 

figures, but the bottom line is it is very fast growing. Where do you think we're going to get our 

water? It comes out of Lake Granbury. So now we've got a triple whammy going on Lake 

Granbury, and you're sitting there telling me the water level's not going to appreciably change. I 

don't believe you. (0062-14-4 [Williams, Robert])

Response: The EIS considers the impacts of the proposed new units together with the impacts 

of increased water demand due to population growth. The impacts analysis presented in EIS 

Section 5.2.2.1 considers the effects of water usage for Comanche Peak Units 3 and 4 in 

combination with the other water demands and reservoir sedimentation conditions projected for 

the year 2020. Section 7.2.1.1 discusses the effects of past, present, and reasonable 

foreseeable water demands on water resources, and includes water demand projections 

through the year 2060. The review team concluded that there would be a noticeable effect on 

water quantity as a result of the alterations in the Brazos River System to accommodate 

increase water demands. As a result of this and other comments on impacts to Lake Granbury, 

Section 5.2.2.1 has been revised to provide additional details of the analyses. 

Comment: What little bit of research I've been able to, as do was mentioned earlier, we're 

going to take 60 million gallons of water a day. That is not a small amount of water; I don't care 

what you call it. That's hefty. To tell me it's going to lower my lake by six inches, I don't believe 

you. It's just that simple. I don't believe you. (0062-14-2 [Williams, Robert])

Comment: It is important to note that the environmental impact study of Units 3 and 4 includes 

water usage models that have been calculated using the hottest three months of the year, then 
Appendix E 

May 2011 E-57 NUREG-1943 

projected through the entire year. This is by far a worst-case scenario. The Nuclear Regulatory 

Commission then took this model and applied it to their economic impact study -- I'm sorry -- 

their environmental impact study. According to Section 5.221 of this study, surface water use 

impacts, page 5-9, lines 10 and 11, it says, Operation of Comanche Peak nuclear power plant 

Units 3 and 4 would reduce the average water levels by .6 feet in Lake Granbury and by 1.5 feet 

in Possum Kingdom Lake.” That means that if we have the worst-case scenario, the addition of 

Units 3 and 4 could reduce current lake levels by only 7.2 inches. (0062-4-3 [Griffin, Dwayne])

Comment: The Draft Environmental Impact Statement model identifies boundaries of potential 

environmental impact; it doesn't identify the reality that these two nuclear units will have on the 

lake. The reality is that the impact will be less than the boundaries identified, and here's a 

couple of examples why: The model uses the hottest times of the year and applies those 

temperatures across the entire year. We did that because we needed to be conservative; that's 

just the way the nuclear business does things: very conservative. The model also assumes the 

100 percent use of all water rights, something that's never occurred. Third, in addition this 

model does not take into account our aggressive internal studies of how to reduce potential 

water use. We're continuing to take a look at what we need to do to minimize the impact to 

Lake Granbury. We're not through; it's been changing. And finally, this model does not take 

any credit for the Brazos River Authority's lake management plan, something they are currently 

studying. (0062-5-2 [Flores, Rafael])

Comment: The Draft Environmental Impact Statement model identifies some boundaries of 

potential environmental impacts. It does not identify the reality that two new nuclear units will 

have on the lake. The reality is that the impact will be less than what we've identified as the 

boundaries. And here's why. The modeling that we used for the study uses the hottest times of 

the year and applies those temperatures across the entire year. We did that because we 

wanted to be as conservative as possible. That's really the way the nuclear business does its 

work. We try to be very conservative. The modeling also assumes 100 percent use of all the 

water rights. Something that's never occurred. In addition, the model does not take into 

account aggressive internal studies on how to reduce potential water use. Those are ongoing. 

They continue to be ongoing, as Steve mentioned in his comments. We're working to minimize 

the impact of that lake. And finally, this model doesn't take any credit for the Brazos River 

Authority's Lake Management Plan, something they're currently studying. (0063-12-1 [Flores, 

Rafael])

Comment: We are not against the Comanche Peak towers 3 and 4 or nuclear energy. What 

we are against is the detrimental use of Lake Granbury to cool those towers. Your study 

supposedly indicates minimal impact on water levels. We have seen studies that indicate the 

opposite and, quite frankly, we cannot take the chance that you might be wrong. (0062-6-2

[McHugh, Judy])

Comment: I want to address the water issue. I think it's of critical importance. The questions I 

asked earlier were real questions. And the answers were not adequate. On page 5-9 of the 

Draft Environmental Impact Statement -- you can get it on disc in the back of the room or get a 

hard copy -- there is this information. That currently Lake Granbury is at full pool 57 percent of 

the time. I think those around the lake need to look at that. Because I think it's pretty close to 

that a lot of the time. With additional reactors it would only be at full pool 46 percent of the time. 

And they say a .6 foot decrease would be likely. Possum Kingdom they call full pool 34 percent 

of the time and they say that would go down to 26 percent of the time. 

For Lake Granbury they say it currently falls -- see if this is true -- two feet or more full pool 10 

percent of the time. Is that true? Is it two feet low 10 percent of the time? It would be 25 percent 

of the time that it would be two feet or more below full pool with units 3 and 4 according to this 
Appendix E 

NUREG-1943 E-58 May 2011 

study. I think this data needs to be looked at. And if it is true it's a concern as it is. Possum 

Kingdom, five feet or more below full pool now 10 percent of the time. That would go to 25 

percent of the time. And the seasonal distributions of stream flow downstream would be 

altered. I think this needs to be looked at seriously. And the alternations that were discussed 

earlier -- there was no answer to the question on that. (0063-30-13 [Hadden, Karen]) 

Comment: So I would ask that as we leave here we find a way, an assurance that your draw 

downs are correct, that you're exactly right when you say it's only going to be seven inches. 

(0063-10-4 [Berry, Steve])

Response: These comments express concern that the analysis presented in the EIS may 

underestimate impacts. The analyses in the EIS are conservative. That is, in order to ensure 

that potential impacts are not underestimated or overlooked, the analyses are based on 

assumptions that are expected to result in upper-end estimates of impacts. However, while it 

has been stated that the water level in Lake Granbury would be 0.6 ft (7 inches) lower on 

average with the new units operating, this single average value does not effectively 

communicate the size of the impact. This is an average of values that range from zero (for 

periods when the water level would be unchanged) to values much larger than 7 inches. Since 

the analysis indicates that Lake Granbury would be at its normal full pool for 46% of the time 

(zero difference from the situation without the new units), the average has to reflect many 

values greater than 7 inches. See Section 5.2.2.1 for additional details on estimated reductions 

in lake water levels. The assumption that 100 percent of existing water rights are exercised by 

their owners may not be completely realistic, but this assumption is necessary to provide 

assurance that water use by CPNPP Units 3 and 4 would not conflict with other users' water 

rights. The EIS analysis does assume that the BRA would implement its system operating plan, 

which is intended to optimize water availability for the benefit of all users. It is useful to know 

that Luminant and the BRA are continuing to study ways to mitigate the impacts on the lakes 

and the river system of water use for the new units. Section 5.2.2.1 has been revised to provide 

additional details of the analyses. 

Comment: I fully believe that if you didn't pass this BRA would sell the water right on down the 

river. (0063-10-2 [Berry, Steve])

Comment: We started thinking about the BRA. And everybody was saying, You know, it's the 

BRA, they control the water. Luminant does not control the water, the NRC doesn't control the 

water, BRA is the only organization, agency that has the water rights out of the Brazos River 

system. They say it's their water and they'll do what they want to with it. I question what's the 

truth. What is the truth? Do they control all the water? Do they do what they want to with it? I 

want the truth. Here's the truth. The very contracts for 696,000 acre-feet of water that they can 

sell off out of the Brazos River system. Period. 64,000 acre-feet can come out of Lake 

Granbury. Period. Most of that goes to the existing Comanche Peak that sits there here in 

Somervell County. This is true. This is the truth. (0063-15-3 [Williams, Joe]) 

Response: The authority or responsibility to regulate or manage water resources belongs to 

the Brazos River Authority. The EIS presents an analysis of the impacts of water use for the 

proposed new units that uses information from the authorities that are responsible for managing 

water resources, including the Texas Water Development Board and the BRA. Luminant's 

proposal to construct and operate two new nuclear power units is based on an assumption that 

BRA's application for a new system operating permit (SOP) will be approved by the State of 

Texas, allowing BRA to supply water to the proposed new units at the Comanche Peak Nuclear 

Power Plant site. The State’s approval of the SOP would grant additional water rights to the 

BRA. If the BRA receives approval to increase its water sales (by implementing its proposed 

SOP) and the proposed new units are not built, the BRA would have the authority to sell some 
Appendix E 

May 2011 E-59 NUREG-1943 

other user the water that would have been allocated to these units. The review team cannot 

speculate on how the BRA would utilitize the additional water made available through the SOP if 

the SOP is approved, but the proposed units are not built. No changes were made to the EIS as 

a result of these comments.

Comment: But briefly, we are concerned that nuclear power is not a real solution to climate 

change. It's vulnerable to severe climate conditions, as pointed out earlier to hot water 

temperatures. We are already seeing U.S. reactors have to shut down -- close down because 

the water's too hot for cooling. (0063-30-2 [Hadden, Karen]) 

Comment: And so it concerns a lot of us that are in Granbury as to whether or not we're going 

to see the level of the water stay the same but the temperature of the water is going to wind up 

rising. Further into the future if you don't have that cool water flowing down river we're going to 

wind up suffering because our temperature is going to wind up rising. And that's going to affect 

the cooling of the nuclear plant. (0063-7-7 [Pratt, Rickie])

Comment: If global warming is occurring and as severe as scientists predict will there be 

enough cool water to operate the reactors safely? The EIS needs to include analysis based on 

input from global warming scientists. (0071-36 [Hadden, Karen])

Response: The NRC licenses and regulates nuclear power production to ensure protection of 

public health and safety. The NRC is not engaged in finding a “solution” to climate change and 

does not promote the use of nuclear energy. Additionally, the NRC is not responsible for 

planning for the impact of climate change on the operation of nuclear power plants. Planning 

and management for future conditions that may affect nuclear power plant operations is the 

responsibility of the plant operators, such as Luminant. The NRC has included consideration of 

climate change impacts in its assessment of cumulative impacts in EIS Section 7. The gradual 

effects of climate change on plant operation are a safety issue, and provisions exist for license 

holders to update their Safety Analysis Report as required by 10 CFR 50.71(e). This includes 

site safety issues. Power plants have derated or shutdown during periods of high water 

temperature or low flow conditions. These comments did not result in any changes to the EIS. 

Comment: According to the DEIS, the project may cause the long term ambient water quality 

for Total Dissolved Solids (TDS) and chlorides to increase. The DEIS also states that treatment 

chemicals containing phosphorus will be added to the cooling water. EPA is concerned that this 

could possibly cause problems in the future with excess nutrients in Lake Granbury leading to 

algae blooms. Blue Green algae blooms are related to excessive nutrients, especially 

phosphorus. Currently, water quality data for Lake Granbury and Lake Whitney (downstream of 

Granbury) indicate that chlorophyll A levels are above their screening values. Additional 

loadings of phosphorus into the system may become a problem in the future. Please discuss 

this concern in the FEIS. (0070-3 [Smith, Rhonda])

Response: The comment notes that the use of water treatment chemicals containing 

phosphorus could increase phosphorus loading to Lake Granbury and the Brazos River when 

the water is discharged, thus contributing to nuisance algal blooms. In response to this 

comment, EIS Section 5.2.3.1 has been revised to include an analysis of the potential for 

impacts from the use of water treatment chemicals. Using conservative assumptions, the 

analysis found that the use of water treatment chemicals could increase phosphorus 

concentrations by a factor of 6.3 x 10-7 (about one part in 1.6 million). The review team 

considers the effects of this small addition to be negligible. 

Comment: Although the DEIS concludes that impacts on surface water quality would be Small 

to Moderate, higher levels of TDS and chlorides may increase the need for public water supply 
Appendix E 

NUREG-1943 E-60 May 2011 

treatment capacity. EPA recommends including an analysis of water quality and resultant 

treatment and cost impacts resulting from concentrated contaminants to include applicable 

inorganic chemicals, metals, etc. (contaminants in addition to chloride and TDS). (0070-14

[Smith, Rhonda])

Response: As stated in Section 5.2.3.1, higher levels of dissolved solids would increase the 

need for treatment to make the water suitable for public water supply and other uses. The 

review team has not identified any other substances potentially present in effluents from Units 3 

and 4 that could create a need for new treatment capabilities. The principal public water 

supplier that would be affected by increased concentrations of dissolved substances is the Lake 

Granbury Surface Water and Treatment System (SWATS), which is operated by the BRA to 

supply Lake Granbury water to five municipal water systems. Reverse osmosis is the primary 

treatment method used by SWATS. Because reverse osmosis technology is a nonselective 

treatment process that minimizes the concentrations of all dissolved substances, it would be 

effective in treating any inorganic chemicals that would be introduced in small concentrations by 

discharge of CPNPP Units 3 and 4 effluents. Higher concentrations of dissolved solids could, 

however, increase the cost of treatment in SWATS. This comment did not result in any changes 

to the EIS.

Comment: The Final EIS should also confirm, in consultation with applicable water treatment 

plant(s) (including Lake Granbury Surface Water and Treatment Plant) that the lowered Lake 

Granbury and Possum Kingdom Lake water levels will not destabilize water use which would 

include drinking water treatment and raw water intake. (0070-12 [Smith, Rhonda])

Response: The Brazos River Authority, which would supply water for the proposed new units, 

also is the operator of the Lake Granbury Surface Water and Treatment Plant and the two 

reservoirs named in the comment. As such, the BRA has the authority and the responsibility to 

manage water supply in these reservoirs to assure a stable supply for users. In preparing the 

analysis of water use impacts presented in the EIS, the review team used information from the 

Brazos River Authority that indicates that the proposed water allocation for the new units would 

not destabilize other water uses. 

Comment: The DEIS explains that the right to use surface water in the State of Texas is 

regulated by the Texas Water Code which is administered by the Texas Commission of 

Environmental Quality (TCEQ). In the Brazos River Basin, the CPNPP will have to obtain its 

additional water by entering a contract with the Brazos River Authority (BRA). TCEQ will then 

have to grant this need for more water to the BRA. EPA suggests that NRC closely coordinate 

with both parties on the matter ofincreased amounts of surface water use. Of particular concern 

is how this use will affect the water supply for the entire region in times of sustained drought. A 

decrease in surface water may have a detrimental affect on groundwater wells in the area. 

Please address this concern in the FEIS. (0070-9 [Smith, Rhonda]) 

Comment: the system for prioritizing and allocating water administered by the Brazos River 

Authority (BRA) clearly has not anticipated the enormous consumption of water necessary for 

additional reactors of the type that Luminant is proposing, and that "in the case of drought 

conditions" that "BRA would apportion the reductions in water availability to all of its contract 

customers", including residential and municipal consumers who could be subject to water 

rationing while the nuclear plant has defacto first call on the water supply. (0055-4 [Inge, Charles] 

[King, Arnold] [Rosenfeld, Joshua])

Comment: That the system for prioritizing and allocating water administered by the Brazos 

River Authority, the BRA, clearly has not anticipated the enormous consumption of water 

necessary for additional reactors of the type that Luminant is proposing and that in case of 
Appendix E 

May 2011 E-61 NUREG-1943 

drought conditions -- this is important -- that the BRA would apportion the reduction in water 

availability to all its contract users, including residential and municipal consumers who would be 

subject to water rationing while the nuclear power plant has de facto first call on all the water 

supply. (0063-36-4 [Hackett, Ken])

Comment: In drought conditions, will there be enough water for cities, businesses, farms and 

ranches if two nuclear reactors are built? (0071-37 [Hadden, Karen])

Response: The EIS analysis of the impacts of water use for the proposed new units uses 

information from the authorities that have responsibility for managing water resources, including 

the Texas Water Development Board and the Brazos River Authority. The analysis described in 

Section 5.2.2.1 uses 68 years of historical data on streamflows in the Brazos River basin, 

including data from the “drought of record.” It determined that the use of surface water for the 

proposed new units would not interfere with the supply requirements of other users in the 

region. A decrease in surface water availability during a sustained drought could induce 

additional use of groundwater. However, as discussed in EIS Section 2.3.2, the trend in the 

region is toward decreased use of groundwater, due in part to an increased emphasis on longterm sustainability in groundwater management in the state's water planning. This comment did 

not result in any changes to the EIS.

Comment: EPA recommends mitigating low-flow or drought source water issues by ensuring 

that CPNPP contractually require BRA to (a) have banked (stored) water set-aside to mitigate 

the risk of supplies being inadequate and (b) BRA curtail other contracted water users as 

required. (0070-10 [Smith, Rhonda])

Response: The EIS evaluates the potential effects of plant construction and operation on the 

environment, not the effects of the environment on the plant. Therefore, the potential impacts of 

drought conditions on proposed Units 3 and 4 are not within the scope of environmental review. 

The operation of the proposed units during low-flow or drought conditions may raise site-safety 

issues, and license holders are required to update their Safety Analysis Report as specified in 

10 CFR 50.71(e). This includes site safety issues such as low-flow or drought conditions, and, 

where required for safety reasons, power plants have derated or shutdown during these 

conditions. There would be no need to ask BRA to provide supplementary supplies or curtail 

other contracted water users. No changes were made to the EIS as a result of this comment.

Comment: According to the DEIS, BRA will obtain rights to Texas water from TCEQ to fulfill 

the proposed CPNPP contract in accordance with the Texas Water Code to provide surface 

water to operate. The Final EIS should confirm, in consultation with the TCEQ Water Division 

(Public Drinking Water) and the Texas Water Development Board (TWDB), that the lowered 

Lake Granbury and Possum Kingdom Lake water levels and the reduced Brazos River flow will 

not destabilize water use including conditions under low flow. CPNPP Units 3 and 4 operations 

are estimated (via the TCEQ Water Availability Model) to result in averages of 0.6 ft lower water 

levels in Lake Granbury and 1.5 ft lower water levels in Possum Kingdom Lake. (0070-11 [Smith, 

Rhonda])

Response: The EIS analysis of the impacts of water use for the proposed new units uses 

TCEQ methodology and information from the authorities that are responsible for regulating or 

managing water resources, including the Texas Water Development Board and the Brazos 

River Authority. The analysis finds that the proposed water allocation for the new units would 

not destabilize other water uses under any flow condition encountered in the 68 years of record 

considered in the analysis. This comment did not result in any changes to the EIS.
Appendix E 

NUREG-1943 E-62 May 2011 

Comment: The DEIS refers to the site plan Figure 2-3 when discussing various features of the 

facility, though not all features are included or labeled on the figure. Major water features not 

represented on the site plan include the safety shutdown impoundment, non-radioactive 

wastewater evaporation ponds, an emergency spillway, stormwater retention ponds, and 

drainage swales. The terminology referring to several features is inconsistent or overlaps 

current features that support Units 1 and 2. Recommendation: TPWD recommends the DEIS 

clearly label various features as they relate to the current units and the proposed units on the 

site. TPWD recommends all water features discussed in the DEIS be shown and labeled on 

Figure 2-3 or a new figure to facilitate reader clarity of the water features. (0068-15 [Melinchuk, 

Ross] [Wicker, Julie])

Response: The features that the comment identifies as being missing from the site plan 

illustration are features that are either not included in the proposed action or have not yet been 

sited. The figure does not include locations for a safe shutdown impoundment or emergency 

spillway because neither of these is required for Units 3 and 4. The specific location for nonradioactive wastewater evaporation ponds has not been determined, but EIS Figure 2-5 shows 

a proposed location. Stormwater retention ponds and drainage swales will be developed as 

part of the SWPPP that must be reviewed and approved by TCEQ as a requirement for the 

applicant to obtain a permit for stormwater discharges. No changes were made to the EIS as a 

result of this comment. 

Comment: And there also appears to be a gross under-estimate of what will happen with 

increasing water shortages. (0063-32-2 [Rooke, Molly])

Comment: In light of the rapid population growth affecting this area, along with ongoing 

depletion of the Trinity Aquifer Lake Granbury will increasingly serve as the principal source of 

area water supplies. The authorities responsible for the protection and allocation of our natural 

resources must be certain of the projected water withdrawal and its environmental impacts. 

Luminant's application does not provide sufficient accurate data, nor does it consider alternative 

plans to permit complete understanding of the additional reactors' impact. (0063-36-6 [Hackett, 

Ken])

Response: The comment expresses concern that the analysis presented in the EIS may 

underestimate impacts related to future water supplies. The analyses in the EIS are 

conservative. That is, in order to ensure that potential impacts are not underestimated or 

overlooked, the analyses are based on assumptions that are expected to result in upper-end 

estimates of impacts. The impacts analysis presented in EIS Section 5.2.2.1 considers the 

effects of water usage for the proposed Comanche Peak Nuclear Power Plant Units 3 and 4 in 

combination with the other water demands and reservoir sedimentation conditions projected for 

the year 2020. The discussion of cumulative water-use impacts presented in EIS Section 

7.2.1.1 considers the effect of increased water demand projected for later decades. The review 

team and the applicant both have explored alternatives to reduce impacts to water resources, 

as documented in EIS Section 9.4. These comments did not result in changes to the EIS.

Comment: Page 2-20 includes information regarding regional water projections of annual 

consumptive water demand across the region, however the DEIS indicates that the regional 

water demand projections do not include water requirements for the project nor for expanded 

development of natural gas from the Barnett Shale. Section 5.2.2 indicates that Luminant has 

participated in the Brazos Region G Water Planning Group process to ensure that Units 3 and 4 

water use impacts are managed in coordination with other users. The DEIS lacks a summary of 

Luminant’s involvement in the process, does not reveal an estimated projection of water 

demand based on the project or the Barnett Shale gas developments, nor does it reveal when 

reports supporting such information would be available. These factors are essential to future 
Appendix E 

May 2011 E-63 NUREG-1943 

projections and should be analyzed. Recommendation: Because the water consumption of the 

project and the gas development of the Barnett Shale are essential to future water demand and 

supply projections, TPWD recommends these water use requirements be included in the 

discussion of Texas Water Development Board’s regional water demand projections and the 

Texas State Water Plan. The DEIS should indicate why these projections were left out of the 

Texas Water Development Board’s projections and Texas State Water Plan. The DEIS should 

indicate when Luminant began its involvement in the Region G water planning process for Units 

3 and 4 and should provide an estimate of water demand projections based on the project. The 

DEIS should indicate when reports supporting future water demands for the project and for 

expanded development of natural gas from the Barnett Shale will be available. (0068-17

[Melinchuk, Ross] [Wicker, Julie])

Response: The comment refers to summary water-demand information in the draft EIS that 

was derived from the 2007 Texas State Water Plan, which was adopted late in 2006. Water 

requirements for Units 3 and 4 were not included in the Water Plan adopted in 2006. However, 

a July 2008 amendment to the Brazos G Water Plan includes an annual requirement 103,717 

acre-ft for these units, including 27,447 acre-ft of BRA water already under contract to Luminant 

and an additional 76,270 acre-ft of new contractual water from the BRA. Section 2.3.2 of the 

final EIS has been revised to add clarity regarding water demand estimates, and Section 7.2 

has been revised to include additional information on water use for Barnett Shale gas 

development and related environmental impacts. The NRC has no role in regulating or 

managing water resources; questions regarding the inclusion of information in the Texas State 

Water Plan and Luminant's role in the water planning process are outside the scope of the EIS. 

Comment: The DEIS indicates that Luminant has been active in Region G and H Water 

Planning Groups and that water for Units 3 and 4 would be obtained primarily from the more 

efficient system-wide operations developed as part of the Brazos Water Authority (BRA) permit 

application on file TCEQ. The proposed system-wide operations are intended to achieve 

efficiency and additional water yield for its customers. The DEIS indicates stored or banked 

waters in BRA reservoirs under BRA current or future water rights would mitigate the risk of 

supplies being inadequate for Units 3 and 4 during extreme droughts. It is expected during 

extreme droughts that BRA would apportion the reductions in water availability to all of its 

contract customers. 

The DEIS states that withdrawal and use of water from Lake Granbury for use by Units 3 and 4 

would result in consumptive uses for Units 3 and 4 estimated at 61,617 acre-feet/year. These 

consumptive uses would result in lower water levels in Lake Granbury and decreased flows in 

the Brazos River downstream. Additionally, Brazos River system operations would be altered to 

accommodate the additional withdrawals including changes in timing of water releases from 

PKL, resulting in lowered water levels in that lake. Water levels would fall 2 feet or more below 

full pool for Lake Granbury, and 5 feet or more for PKL, 25 percent of the time. This would 

occur 15 percent more often than under current conditions which is 10 percent of the time. 

The DEIS does not clearly convey 1) the effects on water levels during drought and drought-ofrecord conditions, and 2) definitions for drought and extreme drought. The DEIS should clearly 

identify Lake Granbury and PKL water levels during drought conditions and drought-of-record, 

under current and proposed conditions. It is TPWD’s understanding that the BRA permit 

application has not yet been approved by TCEQ and, pending the outcome of the contested 

case hearing, could result in changes to the strategies that were evaluated in the DEIS. 

Recommendation: The DEIS should include an evaluation of impacts the anticipated 

withdrawals would have on lake system water levels under various seasonal and climatic 

conditions including drought-of-record scenarios. TPWD is concerned the water withdrawal and 
Appendix E 

NUREG-1943 E-64 May 2011 

consumptive use for Units 3 and 4 and the associated alterations in system-wide water 

management within the basin will have a significant impact on the lake system levels and overall 

hydrology of the Brazos River Basin. (0068-48 [Melinchuk, Ross] [Wicker, Julie])

Response: Sections 5.2.2.1 and 7.2.1.1 have been revised in the final EIS to provide additional 

quantitative information on estimated impacts of water use for the new units on lake water levels 

and streamflow in the Brazos River Basin. 

Comment: The DEIS indicates that the intake structure may alter flow patterns in the vicinity of 

the proposed diffuser during periods of low flow through the DeCordova Dam, which may 

diminish the effectiveness of the diffuser in mixing effluent from Units 3 and 4 while it is 

discharged to Lake Granbury. Locally elevated concentrations of effluent chemicals and 

temperature are possible under these conditions. Luminant has indicated that BRA controlled 

releases from PKL upstream would supply the flow required by the intake structure, thereby 

mitigating the potential for flow pattern alteration and any resultant local water quality 

perturbations. The DEIS states additional mitigation procedures that could be taken by 

Luminant and the BRA to support the effectiveness of their mitigation measures would include 

hourly or daily local flow monitoring, decision-support systems and processes, or water 

management policies. Recommendation: TPWD supports these measures and recommends 

additional water quality monitoring in Lake Granbury and Brazos River downstream, particularly 

during low flow periods to confirm water quality criteria are being met. (0068-49 [Melinchuk, Ross] 

[Wicker, Julie])

Response: The support for mitigation and the recommendation for additional water quality 

monitoring in Lake Granbury and the Brazos River are noted. The Texas Commission on 

Environmental Quality may consider including these requirements as conditions of permits or 

approvals. This comment did not result in any changes to the EIS. 

Comment: The other problem we have with this particular process and looking at the future 

with global warming in mind, as the NRC is doing or -- and we don't believe it has done well in 

this particular DEIS -- is that with global warming comes another phenomena. And that's 

dramatic decreases in the amount of water available in our reservoirs and river systems. The 

EPA says somewhere in the neighborhood of 35 percent in Texas. Kind of going in a little bit 

tighter and looking at this part of the world, maybe 25 percent according to George Worth, the 

University of Texas. That's a 25 percent decrease in the amount of water that's already coming 

through Possum Kingdom, down that river and into that lake. (0063-16-3 [Smith, Tom])

Comment: There may also be questions about the amount of water available in the Brazos 

River Basin for recharge of Lake Granbury Since 1997 the EPA has been warning that: “A 

warmer and drier climate would lead to greater evaporation, as much as a 35% decrease in 

streamflow, and less water for recharging groundwater aquifers” A more recent study found: 

The efficiency of thermal power plants, fossil or nuclear, is sensitive to ambient air and water 

temperatures; higher temperatures reduce power outputs by affecting the efficiency of cooling. 

There is a high likelihood that water shortages will limit power plant electricity production in 

many regions. Future water constraints on electricity production in thermal power plants are 

projected for Arizona, Utah, Texas, Louisiana, Georgia, Alabama, Florida, California, Oregon, 

and Washington state by 2025. 

A recent report entitled Impact of Global Warming on Texas published by the Houston 

Advanced Research Center found that: “(T)he question stated at the outset (is) whether Texas 

water supply is potentially vulnerable to climate changes on the order of those projected for a 

greenhouse-warmed scenario. The answer is clearly affirmative. Taking flows to the coast as a 

measure of river-basin impact, the net effect statewide of the assumed greenhouse climate 
Appendix E 

May 2011 E-65 NUREG-1943 

change, a 3.6°F increase in air temperature and a 5% decrease in precipitation, is to reduce 

these flows by about 25% under normal conditions and by 42% under drought conditions, 

relative to the already reduced flows under 2050-projected water-use demands. The 2050 

projected flows to the coast are 70% of the 2000 normal values under normal conditions with 

the effect of a greenhouse climate imposed, and 15% of 2000 normal under drought conditions. 

In general, the effect of climate on water demands and watershed processing of rainfall is to 

amplify the changed-climate signal, because the causal connections are nonlinear and 

reinforcing.” 

The DEIS notes that the increase temperatures due to global warming could reduce the ability 

of Lake Granbury to dilute chlorides and waste heat. Later the DEIS notes that decreased 

precipitation and reduction in runoff and increased enviro- transpiration would contribute to 

reduced streamflow. The following charts paint a picture of the impact of drought on the 

demand for water. Note the 5 to 24% decrease in precipitation, the 10 to 32% increase in lake 

evaporation, and the 280% increase in use of water by steam electric plants. We would 

question whether this plant is sustainable given the high likelihood of a 20% increase in 

evaporation and a 36% reduction in water flows in the central Texas region. (0067-3 [Geiger, 

Carol]) 

Comment: The electric power industry requires a consistent supply of water, and accounts for 

39 percent of total freshwater withdrawals in the U.S. Fossil fuel plants and nuclear power 

plants require about 140 liters and 200 liters of water per kilowatt-hour of electricity produced, 

respectively. Water scarcity and uncertainty about the reliability of supply due to climate change 

may have significant impacts on operations (see Box 10). In summer 2007, prolonged drought 

conditions forced the Tennessee Valley Authority to partially shut down its Brown Ferry nuclear 

plant in Alabama due to the high temperature of the cooling water drawn from the Tennessee 

River. Furthermore, heated discharges from power plants have a harmful effect on water quality 

and local ecosystems, which is only exacerbated as water levels drop. Electricite de France 

had to shut down a quarter of its 58 nuclear plants due to water shortages caused by a record 

setting heat wave. The closures triggered price spikes of 1,300 percent and about ‚¬300 million 

in losses for the French utility. (REF xi) (0067-5 [Geiger, Carol])

Response: The analyses in EIS Sections 7.2 and 9.3.2.2, 9.3.3.2, and 9.3.4.2 of cumulative 

impacts on water resources related to climate change at the CPNPP site and alternative sites 

have been revised to include discussion of the information provided in these comments. The 

NRC licenses and regulates nuclear power production to ensure protection of public health and 

safety. The NRC is not engaged in finding a “solution” to climate change and it does not 

promote the use of nuclear energy. The NRC does not operate nuclear power plants. 

Additionally, it is not responsible for planning for the impact of climate change on the operation 

of nuclear power plants. Planning and management for future conditions that may affect 

nuclear power plant operations is the responsibility of the plant operators, such as Luminant. 

The NRC has included consideration of climate change impacts in its assessment of cumulative 

impacts in EIS Section 7. The gradual effects of climate change on plant operation are a safety 

issue, and provisions exist for license holders to update their Safety Analysis Report as required 

by 10 CFR 50.71(e). This includes site safety issues, and where required for safety reasons, 

power plants have derated or shutdown during periods of high water temperature or low flow 

conditions. These comments did not result in any changes to the EIS. 

Comment: Well, will these plants operate when it gets hot. And we've heard stories out of the 

southern United States, France, Germany that nuclear plants have to shut down when it gets to 

a certain temperature. So I started looking around to see if I could figure out what the operating 

parameters were. And thanks to the miracles of Google I found a study done on the Comanche 
Appendix E 

NUREG-1943 E-66 May 2011 

Peak plant answering the question of what happens and how can we operate the plant if the 

water gets too hot here at Lake Granbury or at Squaw Creek. It seems that when the 

temperature of that water gets above 95 degrees they have to start curtailing it. At 101 degrees 

they have to start shutting it down. Well, my inquiring mind asked, Well, just how hot is Lake 

Granbury in the summertime. And I found looking at the Lake Granbury Watershed 

Management Plan that in the summertime the average temperature in July and August is 95 

degrees, at the temperature where they have to start curtailing. And then I started thinking if as 

the NRC says, the impact of global warming is going to be moderate what does that mean to the 

ambient temperature. It's somewhere between 1.6 and 6 degrees Fahrenheit difference in the 

average summer temperature during our lifetimes, between now and 2050. May be some of 

your lifetimes. I probably won't make it to 2050. And if I do, I'll be really grumpy, I'll tell you 

what. But anyway, you get out there and you start looking at that increase to temperature. And 

so suddenly that water temperature is likely to increase according to the Watershed 

Management Plan the same proportion. So you might see a 96 or a 101 degree temperature. 

Well, at 95 they were starting to ask the question, Well, how can we cool it so we can operate 

that plant without curtailing. At 101 they have to shut down. (0063-16-2 [Smith, Tom])

Response: The report that the commenter found on the Internet (at http://www.ermsmg.com/TXU%20Comanche%20Peak.pdf) is about the effects of CPNPP Units 1 and 2 on 

water temperatures in Squaw Creek Reservoir. The information in that report is not relevant to 

Units 3 and 4. Units 1 and 2 use once-through cooling, whereas Units 3 and 4 would use 

mechanical-draft cooling towers. In once-through cooling, cooling water is returned to a body of 

water after circulating through the nuclear unit just once, discharging the surplus heat from the 

reactor to the body of water. In contrast, in mechanical-draft cooling, surplus heat is discharged 

to the atmosphere. Because cooling towers will be used to dissipate heat from the new units, 

thermal impacts on water resources are much smaller than with the once-through cooling 

technology that is employed in Units 1 and 2 and most of the other nuclear plants mentioned in 

the comment. Also, because Units 3 and 4 would neither use water from Squaw Creek 

Reservoir nor discharge water to it, the temperature in Squaw Creek Reservoir has no 

relevance to the operation of Units 3 and 4. The review team’s assessment of the thermal 

effects of Units 3 and 4 on Lake Granbury, presented in EIS Section 5.3.2, found minimal 

effects. 

Comment: And so last week, when we got so much rain, I was beginning to doubt who 

controlled it. We got about nine or ten inches at my place; the lake came up nine feet, and it got 

within two feet of the finished- floor level of my house. My wife was sending me pictures all day, 

as I watched the water level come up, and thank goodness it finally quit. I think the problem at 

Lake Granbury the homeowners associations and all have is the water going the other direction, 

I think. And so I understand your pain, but what I really would encourage you to do is even if 

Units 3 and 4 were never built, I think the homeowners associations ought to look at that and 

really partner with the BRA and start partnering with them, because that water level in Lake 

Granbury is going to change regardless if we're ever built of not. And it's going to go up and 

down and it's going to go up and down, so I'd really encourage you to partner with the BRA, 

work with the BRA, and understand who really controls that water level, and it's not Comanche 

Peak. (0062-11-1 [Fuller, David])

Response: The comment points out that reservoir operation is the responsibility of the BRA 

and that water levels in the BRA reservoirs will fluctuate with or without the proposed new 

reactor units. This comment did not result in any changes to the EIS. 

Comment: I'm not going to go through everything that I said this afternoon, but I am going to 

summarize it quickly for you. I spoke, based on the 15 years that my wife and I were in the 
Appendix E 

May 2011 E-67 NUREG-1943 

marine business in southern California, about the effects that overselling water out of the 

Colorado River has had on that whole ecological system, up through the Grand Canyon and all 

the way up past Glen Canyon, down to Lake Powell. Lake Powell at the moment is down 41 

percent from its normal level. Lake Mead, as I'm sure most of you have been there to see 

Hoover Dam -- if you're as old as I am, you went there when it was named Boulder Dam; that 

was a long time ago. But Lake Mead has a normal full level of 500 feet. If you go to that dam 

right now, you have to look down 300 feet to see the water level. There's only 200 feet in it 

behind the dam. Now, this was caused because of overselling the water. Initially the water was 

going to go to Los Angeles, San Diego, farming communities down that way, Laughlin, Las 

Vegas, and a few other small cities. In the late '80s and the early '90s, the Authority decided 

that they would also supply water to Phoenix and then to Tucson and to some Indian 

communities and small communities in between. 

In the period of the last 12 years, Lake Mead has dropped 120 feet since they got that elevator 

in and started taking the water up over the mountains to Phoenix and Tucson. The problem is 

they don't have any place to go now. They've already done it. They're down to 200 feet on 

Lake Mead; they're down a couple hundred feet from their full level on Lake Powell. What are 

they going to do? They could go to desalination. We lived only 25 miles from the San Onofre 

plant when we lived in southern California, and it is operated off of water out of the Pacific 

Ocean, as you probably know. But they've got a long ways to go to build desalination plants 

and try to get water back into southern California. It was caused first by selling it. Secondly 

they blame it on lack of snow pack. We haven't had enough snow in any year to drain the water 

down and fill the Colorado River back up. And thirdly, of course, on the drought, because 

they've had a pretty severe drought in the western states for a number of years. (0062-16-1

[Williamson, Frank])

Comment: And I've heard what they've said. And frankly, I don't believe it. And I'm going to 

tell you why. I lived for 15 years before I retired here, in California. There's a little river out 

there called the Colorado River some of you may be familiar with. The -- We were in the marine 

business so I was over there on that river and on those lakes all the time. We saw firsthand the 

effects of over consumption from a river. Water level in 2009 was down 60 percent at Hoover 

Dam. Hoover Dam is full at 500 feet. So actually, 726 feet tall. But it's full at 500 feet. So if it's 

down 60 percent they've got 200 feet of water backed up behind that dam. Now, you consider 

what that did to Lake Mead all the way up to the other end. Let me just tell you a couple of 

things about it. River flow between the two lakes was reduced so much that the Grand 

Canyon's ecological system is totally imbalanced. They've tried to solve the problem by 

allowing surges from Glen Canyon down to simulate the flash flooding which used to occur 

before the dam was completed in 1966. There's even talk that they might completely knock this 

dam down to return the natural flow of the river through the Grand Canyon. (0063-25-5

[Williamson, Frank])

Response: These comments provide information on the impacts of drought and water 

management decisions on water levels and other conditions in the Colorado River basin in the 

western United States. The NRC does not have the authority or responsibility to regulate or 

manage water resources. The EIS analysis of the impacts of water use for the proposed new 

units uses information from the authorities that do have responsibility for managing water 

resources, including the Texas Water Development Board and the Brazos River Authority. The 

analysis described in Section 5.2.2.1 uses 68 years of historical data on streamflows in the 

Brazos River basin, including data from the “drought of record.” These comments did not result 

in any changes to the EIS. 
Appendix E 

NUREG-1943 E-68 May 2011 

Comment: But my problem is this: I don't believe in models. I watch the weather every night, 

and I hear these guys talking about, Our model shows it's going to do this, and our model shows 

it's going to do that. And I don't care whether you're talking about hurricanes or rainstorms or 

whatever. They don't get it right 50 percent of the time. And also we've got this climate change 

model, where the Himalayas were going to melt by 2035; all the glaciers in that area were going 

to melt. They write all these models, but models are models; they're not the facts. (0062-16-2

[Williamson, Frank]) 

Comment: We are writing to you because we are concerned about the lake level after the 

Comanche Peak Expansion. As you know the lake level dropped so low in 2009 that even the 

public boat ramps closed. We were not able to get on the lake from our home way before that. 

Evidently, the people in charge do not take into consideration the homeowners that live on 

canals or shallow parts of the lake because they continued to let water out. When I made a 

comment at the appraisal office the person there said, ' oh the lake is 20 or more feet'. Well, not 

where a lot of us live. How can Lake Granbury handle even more water being let out after the 

expansion? Yes, I know it was a drought that year but it won't even have to be a drought to 

keep it that low after the expansion. And God forbid if there is a drought. (0025-2 [Slough, Gene 

and Phyllis])

Comment: We had a big drought here recently, AND the Burnett Shale people or somebody 

was purchasing vast quantities of water from Lk. Granbury in 2009, and Lk. Granbury looked 

almost empty. The canal I have my property on was down at least 3 feet. You could see dry 

ground under the boat lifts. (0037-5 [Moore, Jim]) 

Response: These comments express a current concern in reliance upon models and a 

preference for facts. The EIS must address questions about what might happen in the future. It 

is not possible to describe actual observations regarding conditions that do not yet exist and 

events that have not yet occurred. Therefore, predictive models are a valuable tool. Models 

are scientifically accepted representations of the physical world. Moreover, the review team is 

required to base its analysis on the best practice currently available, and modeling is accepted 

best practice in science. The models used to evaluate the impacts of water use for the new 

units could be described as being similar to a complex collection of computer 

spreadsheets. The models use real historical data on stream conditions, gathered over a 68-

year period. Starting with the historical data, models are used to calculate what conditions 

would have been throughout the Brazos River basin for that 68-year period under various 

different conditions. For example, the models are used to postulate the reservoir water levels 

for every month during that period assuming the existing system of dams and reservoirs had 

been in place and that all water rights were fully exercised. The review team used the models 

to compare water conditions with the new reactor units operating to water conditions without the 

new units. As a result of the conservation assumptions made, the models could overstate the 

severity of the lake-level impacts, both with and without the new units. However, the model 

predictionsfor conditions without the proposed units compare reasonably well with historical 

data. No changes were made to the EIS as a result of these comments.

Comment: [W]e have 55 feet behind our dam here. As you go up the river -- I live in Indian 

Harbor -- we have 43 feet in the deepest part of the lake. If you go on up to the city beach, you 

have about 35 feet in the deepest part of the lake, but that's the deepest part of the lake, where 

the old river ran for years and years and years before we made this lake. The shallow part of 

the lake is five feet, and there are hundreds and hundreds and hundreds of houses that, when 

the lake was down four feet last year, could not get their boats off their -- out of the docks. 

(0062-16-3 [Williamson, Frank])
Appendix E 

May 2011 E-69 NUREG-1943 

Response: The comment provides information on water depths in Lake Granbury and how 

lower water levels can affect access to the lake for boaters. This comment did not result in any 

changes to the EIS. 

Comment: It's important to note that there are huge differences between the lake levels the 

BRA reports and those exhibited upriver. I mentioned that in Lake Mead the upriver marina had 

to be closed. Here when the water level is reported as being down two feet at my house, which 

is only about seven miles up from the dam, the water will actually be down about four feet. If 

you go on up as far as the city like behind where the new beach is being built and behind the 

convention center and those areas it will be down even more than the four feet that it is at my 

house. If Lake Granbury is lowered 20 feet -- and I know you guys are saying, It's only going to 

be lowered about a foot -- right? We're going to take 60 billion gallons a year out of it but we're 

only going to lower a foot? Come on. Give me a break. (0063-25-2 [Williamson, Frank])

Response: The comment states that reductions in water level are not uniform throughout Lake 

Granbury and expresses disbelief in statements about the amount that Lake Granbury water 

levels would decline as a result of the operating the proposed new units. EIS Section 5.2.2.1 

presents the review team’s assessment of impacts on Lake Granbury water levels from the 

proposed new units. The analysis finds that there would be many periods when the lake's water 

level would be unchanged and other periods when lake levels would be lower due to water use 

in the new units. The largest total drop in water level predicted by the analysis was less than 10 

feet. A 20-foot drop in water level might be possible, either with or without the proposed new 

CPNPP units, but it is very unlikely. There could be large reductions in water levels. Because 

the lake surface is not flat during periods of significant streamflow in the Brazos River, the water 

elevation at full pool is somewhat higher at the upstream end of the lake than near the dam. 

Thus, as the commenter notes, during low-water periods when little flow is occurring and the 

water surface is nearly flat, the observed reduction in water level is higher in upstream areas 

than near the dam. As a result of this and other comments on impacts to Lake Granbury, 

Section 5.2.2.1 has been revised to provide additional details of the analysis.

Comment: I think Hood County is getting a lot of lemons in passing the lemonade downstream. 

I don't see many benefits at all for Hood County. I am a selfish, lakefront owner who has retired 

to Granbury, living in some wonderful places around the world in my life. On July 7 of this last 

year my shoreline here extended to where the partition is. My boat dock was in between. On 

August -- I'm talking about small and moderate impact. That's a small impact. Right? On 

August 17 the water only came about to the end of that wall. 130 feet from shore during that 

drought. 130 feet. Another two-and-a-half feet drop in a drought is going to increase it to 225 

feet from the shoreline. Kind of tough to get a boat out. Kind of tough to throw a line that far. 

(0063-31-1 [Barker, M. Blake])

Response: The comment provides information on water depths in Lake Granbury and how 

lower water levels can affect access to the lake and it questions the conclusions of “small and 

moderate” impact that are stated in the EIS. The NRC has established three levels of impacts -- 

smsall, moderate, or large -- that provide a common framework for categorizing impacts and 

describing them. The three levels are defined below: 

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

destabilize nor noticeably alter any important attribute of the resource. 

 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. 
Appendix E 

NUREG-1943 E-70 May 2011 

Consistent with this framework, the review team determined that water use for operation of 

Units 3 and 4 would noticeably alter important attributes of the surface water resource, but 

would not destabilize the resource. Thus, water use would have MODERATE impacts on 

surface water resources. Section 5.2.2.1 has been revised to provide additional details of the 

analysis. 

Comment: We have a fixed pool in Granbury. So many gallons can be there. As the drought 

and as water is turned out the saline increases, which affects the biostock within the lake, which 

increases the silt levels within the lake, which raises the temperature of the lake. None of them 

good things. (0063-31-2 [Barker, M. Blake])

Response: The comment expresses concern about the effects of lower lake water levels on 

salinity, aquatic life, siltation, and water temperature. Potential impacts of Units 3 and 4 on lake 

salinity are discussed in EIS Section 5.2.3.1. Potential impacts on aquatic life and water 

temperature are discussed in EIS Section 5.3.2. Siltation occurs in dammed streams because 

the dams prevent sediment from moving downstream; lower lake levels do not normally 

increase siltation. However, the effects of siltation on reservoir water volume are considered in 

the assessments of water-use impacts presented in Sections 5.2.2.1 and 7.2.1.1. 

Comment: DEIS Section 3.2.2.1, page 3-9, lines 1-5: During normal operation, the Wheeler 

Branch Reservoir (WBR) supplies up to 300 gpm. This water supply includes up to 50 gpm for 

daily potable water use for the entire site and from 0 to 250 gpm to the raw water storage tanks, 

which in turn supply water to the demineralized water system (DWS). The amount of water 

needed from WBR is bounded by the maximum delivery rate of 300 gpm, with the estimated 

monthly maximum being 1.3 x 10^7 gal. 

According to the response to ER Request for Additional Information (RAI) HYD-27 

(ML100630660), WBR supplies up to 350 gpm during normal operation, of which 50 gpm is for 

potable and from 0 to 300 gpm is for the raw water storage tanks. The estimated monthly 

maximum is 1.51 x 10^7 gal. (0073-3 [Flores, Rafael])

Response: Section 3.2.2.1 of the final EIS has been revised to incorporate this information. 

Comment: Do a very simple thing on a $45 million investment that TXU funded to create Lake 

Granbury. Increase the pool. Dredge the shallows of the lake. Use that as landfill on the new 

projects for units 3 and 4 and you increase the oxygen level, you decrease the silt level, you 

increase the habitat for the fish in the lake and you increase a larger pool to draw from which is 

a cooler lake. You can remove 20 cubic yards of soil for $200. Seems like a pretty simple 

solution and a pretty much a win-win for Granbury and the area and Luminant, as well. (0063-31-

3 [Barker, M. Blake]) 

Response: This comment suggests or proposes an alternate means of increasing the quantity 

of water in Lake Granbury to provide cooling water for the proposed new nuclear units. The 

NRC does not have the authority or responsibility to regulate or manage water resources. The 

EIS analysis of the impacts of water use for the proposed new units, located in Section 5.2.2, 

uses information from the authorities that do have responsibility for managing water resources, 

including the Texas Water Development Board and the Brazos River Authority. Alterations to 

the the hydrologic resources such as the one mentioined by the commenter, would be the 

responsibility of those authorities. No changes were made to the EIS as a result of this 

comment. 

Comment: Page 7-7 indicates the U.S. Global Climate Research Program projects this region 

(Great Plains) may warm as much as 12 degrees Fahrenheit between 2000 and 2090 and tend 

to have less rainfall. Page 7-9 notes water management, under proposed changed strategies in 
Appendix E 

May 2011 E-71 NUREG-1943 

this water planning region, would minimize adverse impacts on water availability for users with 

valid water rights. The decreased precipitation and increased temperatures associated with 

global climate change would reduce surface water runoff and increase evapotranspiration, 

contributing to cumulative impacts on water quantity of streamflows. The NRC review team 

identifies the cumulative impacts on surface water quantity as MODERATE with noticeable 

alterations in the Brazos River system. The surface-water quality impacts discussion in Section 

7.2.2.1 (page 7-11) states these changes could reduce the ability of Lake Granbury and the 

Brazos River to dilute natural salt concentrations and waste heat and other constituents in the 

effluent from Units 3 and 4. The cumulative impacts to surface water quality is evaluated as 

SMALL to MODERATE with the MODERATE level based on the potential impacts to ambient 

water conditions and downstream users from increased dissolved solids, particularly during low 

flow conditions. The DEIS, however, does state that current and future potable water users 

would still be required to treat water to address salinity regardless of the increase in salt 

concentrations attributable to Units 3 and 4. Aquatic life in the Brazos River Basin does not 

presently qualify for a water right and under the current system, has been adversely impacted. 

It is unclear if the ecosystem could stabilize, under these future cumulative conditions. 

Recommendation: The facility should plan to address adverse impacts imposed by global 

climate changes. To offset cumulative impacts, TPWD recommends that Luminant’s discharge 

to Lake Granbury during seasonal and drought low flow conditions be maintained at or below 

ambient lake concentrations. It would result in larger volumes of salt solids needing to be 

disposed off site, but would only occur during drought and summer periods. This mitigation 

measure would avoid the added stress of the lake and river needing to dilute Units 3 and 4 

effluents. (0068-62 [Melinchuk, Ross] [Wicker, Julie])

Response: The comment recommends that, as a mitigation measure for water quality impacts 

in Lake Granbury and downstream, dissolved solids concentrations in discharges to Lake 

Granbury from Units 3 and 4 should be maintained below ambient concentrations in the lake. 

As discussed in EIS Section 5.2.3.1, Luminant proposes to maintain discharge concentrations 

below the Texas state water quality standards for Lake Granbury of 2500 mg/L and 1000 mg/L 

of TDS and chloride, respectively. Although concentrations in the lake sometimes are above 

these criteria, the average TDS concentration in the lake is lower, so discharges at these 

concentrations would result in a small net increase in the TDS concentration in Lake Granbury 

and downstream (a study cited in the EIS estimated that the average TDS concentration could 

increase by 50 to 60 mg/L). The proposed mitigation measure would prevent this small 

increase. However, as the comment notes, this measure would result in a larger quantity of salt 

solids needing to be disposed offsite. Also, it would somewhat reduce the amount of water 

returned to the lake and somewhat increase the required production capacity of the BDTF. The 

NRC has no authority over water quality limits for discharges to the lake. Any requirement 

related to this proposed mitigation measure would be the responsibility of EPA or the Texas 

Commission on Environmental Quality under authority of the Clean Water Act and other laws. 

No changes were made to the EIS as a result of this comment. 

Comment: In an area that suffers drought conditions one-third of the time such a huge 

additional drain on the water reserves does not seem prudent. Over- allocation of water 

increases the fragility of the ecology and the economy of the entire area. Committing such a 

huge volume of water limits the options available to us for a robust future in the Brazos River 

basin. (0063-24-2 [Williams, Sue])

Comment: Finally, keep this analogy in mind [with respect to the proposed withdrawal of water 

from Lake Granbury]. Human blood donors only donate one pint of blood at a time. If you pull 

out pint number two the donor won't do very well. And pint number three just might kill him. 

(0063-24-3 [Williams, Sue])
Appendix E 

NUREG-1943 E-72 May 2011 

Response: The comments express concern about the cumulative impacts of water use. The 

assessment of water use impacts in EIS Section 5.2.2.1 considers the impacts of the new units 

in the context of other existing uses of Brazos River water, and the discussion of cumulative 

impacts in Section 7.2.1 also considers impacts of other past, present, and reasonably 

foreseeable demands. Section 5.2.2.1 of the EIS has been revised to include more details of 

the review teams analysis.

Comment: After reviewing the study I have come to the conclusion that the loss of this water to 

the Expansion will be devastating to the Brazos River Basin and Lake Granbury. Here are the 

most important critical issues regarding Lake Granbury that are stated in the study: * The 

Comanche Peak Expansion would require 102,000 acre ft (33 billion gallons) from Lake 

Granbury for cooling purposes. 30-40% (13 billion gallons) would return to Lake Granbury with 

a net loss of 20 billion gallons. This amount would be equal to 60 million gallons of water LOST 

EVERY DAY. 

* With the additions of Comanche Peak 3 and 4, Lake Granbury would be at full pool (level) only 

46% of the time. The water level at Lake Granbury would also be 2 feet or MORE lower 25% of 

the time. The operations of units 3 and 4 would result in somewhat smaller releases from Lake 

Granbury and lower resulting water flow in the Brazos River near Glen Rose. (Sec 5-8) 

* Consumptive water use for cooling 3 and 4 would cause lower lake levels at Possum Kingdom 

(PK) and Lake Granbury, and decreased flows in the Brazos River Basin below Lake Granbury. 

Elevations at PK would be 1.3 ft. LOWER on average, and elevations in Lake Granbury would 

be .4 ft LOWER due to 3 and 4 water consumption. During extreme drought conditions, Lake 

Granbury would be 2.5 ft LOWER (than previous drought conditions without 3 and 4) and PK 

would be 12.6 ft Lower. (Sec 5-18) 

Case in point: Last year on Lake Granbury the lake was 4 ft low because of drought conditions. 

With the additions of Comanche Peak 3 and 4 under those same conditions, the lake would 

actually be 6.5 ft lower. Some models are indicating that might actually be closer to 8 ft. 

* Even without the Comanche Peak Expansion, future modeling of Lake Granbury for the next 

50 years shows there will be an increase in demand from 85,138 acre ft/year to 107,302 acre 

ft/year(21% increase) due to population growth. The model also indicates that 25% of the lake 

will lose its volume in water due to sedimentation. (Sec. 7-8) 

How can we allow 60 million gallons of water EVERY DAY from Lake Granbury to disappear 

forever? As you can see from the study this would be devastating to the Brazos River Basin and 

Lake Granbury. (0005-1 [Clark, Becky] [Frick, Terry] [Kelly-Elliott, Cathy] [Leach, Dan] [Rhodes, Bill] 

[Wayson, Jacqueline and Thomas] [Wayson, Thomas])

Response: The comment expresses concern about the impacts of the proposed new units on 

water levels in Lake Granbury and it restates some of the findings regarding impacts that were 

presented in Sections 5.2.2.1, 5.3.1.1, and 7.2.1.1 of the draft EIS. These sections present and 

discuss the review team’s assessment of impacts on Lake Granbury water levels from the 

proposed new units; some additional information has been provided and other revisions have 

been made in these sections of the final EIS. 

Comment: If the statistics below are true, you can bet the NRC will be under extreme fire for 

letting these 2 new reactors get built without have a water-conservation plan for Lake Granbury 

in place. (0022-1 [Frick, Terry])

Response: The comment expresses concern about the impacts of the proposed new units on 

water levels in Lake Granbury and calls for a water conservation plan. It also restates some of 
Appendix E 

May 2011 E-73 NUREG-1943 

the findings regarding impacts that were presented in Sections 5.2.2.1, 5.3.1.1, and 7.2.1.1 of 

the draft EIS. These sections present and discuss the review team’s assessment of impacts on 

Lake Granbury water levels from the proposed new units; some additional information has been 

provided and other revisions have been made in these sections of the final EIS. The NRC does 

not have the authority or responsibility to regulate or manage water resources or to require 

water conservation plans. Water conservation planning falls under the jurisdictions of 

organizations including TCEQ, the Texas Water Development Board, and the Brazos River 

Authority. 

Comment: In light of remarks made at the NRC Town Hall meeting in Glen Rose on Sept. 21, 

I submit the following article for your consideration: 

http://journals.tdl.org/twj/article/view/1043/740 This article places the water availability situation 

into the context of climate change, and raises serious doubts about the drought model for the 

Comanche Peak expansion. (0042-1 [Rosenfeld, Joshua])

Response: The comment refers to an article entitled "Climate Change Impacts on Texas 

Water: A White Paper Assessment of the Past, Present and Future and Recommendations for 

Action," published online by the Texas Water Resources Institute in Texas Water Journal, 

Volume 1, Number 1, Pages 1-19, September 2010. The article discusses paleoclimate 

research findings that indicate that in the last thousand years Texas experienced droughts of 

longer duration than the 1950s "drought of record," and it states a need for Texas water 

resource managers to consider the potential for droughts more severe than the drought of 

record to occur again due to natural or human-induced climate change. In response to this and 

other comments on this topic, the analyses in EIS Sections 7.2 and 9.3.2.2, 9.3.3.2, and 9.3.4.2 

of cumulative impacts on water resources related to climate change at the CPNPP site and 

alternative sites have been revised to include discussion of the potential impacts of drought 

conditions more severe than the drought of record.

Comment: LGWOA believes that other factors of consideration that have not been fully studied 

include excessive water temperature increases on Lake Granbury (0051-9 [Jalbert, Ann] [Jalbert, 

Pete] [McHugh, Judy] [Williams, Joe] [Williams, Sue])

Response: The review team’s assessment of the thermal effects of Units 3 and 4 on Lake 

Granbury and its aquatic ecosystem is presented in EIS Section 5.3.2. That assessment found 

minimal effects. 

Comment: Take all these elements into place. You got the contracts the BRA is already 

selling. You already have Morris Sheppard Dam shut down where you don't get any flow. You 

got Dow Chemical. They want their water. You've got, you know, population growth. And 

guess what you've got after that. You have Mother Nature. Rain? Drought? Which one are we 

going to get. We have no control over that. So we have all these elements. Four out of the five 

elements happened last year when our lake was four feet low. Four out of five. Right? The only 

thing that didn't occur that -- we didn't have the population growth over the years to come. Was 

that The Perfect Storm? Hum. That was barely a thunderstorm. (0063-15-7 [Williams, Joe])

Response: The comment expresses concern about the cumulative impacts of water use. The 

assessment of water use impacts in EIS Section 5.2.2.1 considered the variability in rainfall and 

streamflow that was observed over a 68-year period, including the "drought of record," and 

considers the impacts of the new units in the context of other existing uses of Brazos River 

water. The discussion of cumulative impacts in Section 7.2.1 also considers impacts of other 

past, present, and reasonably foreseeable demands. No changes were made to the EIS as a 

result of this comment. 
Appendix E 

NUREG-1943 E-74 May 2011 

Comment: If you think we love our water, you're absolutely right. So let's all try to protect it, 

whether you're Somervell or Hood. If you're NRC, TCEQ or the BRA, let's take care of the 

water. (0063-23-5 [Conway, Bretta])

Response: The support for measures to protect and conserve Brazos River Basin water is 

noted. No changes were made to the EIS as a result of this comment. 

Comment: I am personally very, very concerned with the water issues facing our area, our 

state and our nation. During the 1950s there was a drought across this land that brought the 

great State of Texas to its knees. In response to the devastation that gripped our state the 

Texas Water Development Board was created. Its charge is to head up the development and 

implementation of a plan to prevent hardships and losses due to conditions similar to the great 

drought of record. Texans have responded to the call to protect their state providing their 

property, their money and their labor. As a result Texas has an enviable system of water 

reservoirs and pock lines across the state to make sure that water is available when needed. 

One would think gazing today over a brimming Lake Granbury that there is plenty of water for 

everyone and for every purpose. But evidently, such is not the case. I have read the official 

reports, read the newspaper articles, spoken with water district officials, researched the 

international group reports and even read the statement in a hunting magazine from a state 

senator that there will not be enough water. There is not enough water available to meet the 

future demands of our state. Period. And at this time we don't even know what and when 

unexpected demands will appear. Why then would we commit to providing such a amount of 

additional water to the Comanche Peak expansion from Lake Granbury? (0063-24-1 [Williams, 

Sue])

Response: The comment expresses general concern about the impacts of the proposed new 

units on Texas water resources, particularly Lake Granbury. EIS Section 5.2.2.1 presents the 

review team’s assessment of impacts from the proposed new units on the Brazos River water 

and on Lake Granbury water levels. 

Comment: Many groups that have been involved would include Luminant, Lake Granbury 

Waterfront Owners Association, the City of Granbury and even the Brazos River Authority. 

Through the discovery process the Chamber understands that lake levels have tremendous 

complexity and are affected by many variables. The Chamber believes that our work with the 

Task Force is unfinished. We do appreciate that the Brazos River Authority has acknowledged 

the usability difference in lake levels between Lake Granbury and Possum Kingdom Lake. We 

anxiously anticipate the BRA study that compares the two lakes and should make a 

recommendation for better methods at synchronizing lake levels. In addition, the Chamber 

looks to the BRA to provide information about the closure of the Morris Sheppard Dam. We 

believe that this was a major factor in the low lake levels in the summer of 2009. (0063-14-4

[Garner, Todd])

Response: The NRC does not have the authority or responsibility to regulate or manage water 

resources, including reservoir water levels. Water management falls under the authority of 

organizations including TCEQ, the Texas Water Development Board, and the Brazos River 

Authority. In assessing the impacts of the proposed new nuclear units in this EIS, the review 

team assumes that the BRA would manage the reservoirs in accordance with its proposed 

system operating plan. This comment did not result in any changes to the EIS. 

Comment: Biocide, algaecide, pH adjuster, corrosion inhibitor and silt dispersant would be 

injected into water drawn from Lake Granbury, and only a fraction of the “blowdown” water 

would be treated before being returned to the lake or sent to an evaporation pond.Why wouldn’t 

all of the water be treated before being returned to the lake? (0071-31 [Hadden, Karen])
Appendix E 

May 2011 E-75 NUREG-1943 

Response: Luminant proposes to treat blowdown water to the extent necessary to ensure that 

effluent discharged to Lake Granbury meets the Texas State Water Quality Criteria for that lake, 

which are 2500 mg/L and 1000 mg/L for TDS and chloride, respectively. The NRC has no 

authority over Luminant's water treatment or wastewater discharge. However, in EIS Section 

9.4.2.4, the review team assesses the potential environmental impacts of several possible 

alternatives for treatment of influent and effluent water. In the State of Texas, regulatory 

authority over wastewater discharge is administered by the TCEQ. Luminant will need to obtain 

a permit to discharge wastewater into or adjacent to waters of the State from the TCEQ prior to 

operations. Appendix H of the EIS list the permits and licenses that Luminant will need to obtain 

prior to building and operating the proposed units. This comment did not result in any changes 

to the EIS. 

Comment: The EIS must do a full analysis of how much of each of these contaminants [from 

the treated blowdown water discharge] would end up in Lake Granbury, how much would 

migrate into the Brazos River and how much would escape through evaporation. The exact 

chemical names must be included, not just generic terms such as “biocide.” The impacts of 

exposure of humans, animals and wildlife to these toxic compounds should be analyzed. (0071-

32 [Hadden, Karen])

Response: EIS Table 3-3 provides information on the chemical names and quantities of water 

additives proposed for use in CPNPP Units 3 and 4, as well as expected effluent concentration 

limits for residual chlorine and sulfuric acid, which are the only potentially toxic compounds 

proposed for use in the facility. Concentrations and loadings of these substances would be 

small. EIS Section 5.2.3.1 has been revised to include additional information regarding the 

assessment of potential impacts from water additives. 

Comment: [A] specific case in point is the Applicant's use of the annual average wet-bulb 

temperature (76°F) rather than the normal summer design wet-bulb temperature (78°F) to 

calculate cooling water usage, indicating that a greater volume of cooling water will be needed 

at precisely the time of year when area and reactor water demand is at its maximum and 

drought conditions are most likely. In addition, the exhaust from the four large cooling towers 

and associated spray ponds should increase the design wet bulb temperature for the cooling 

towers by 1 or 2 degrees, thus increasing the cooling tower size considerably and the amount of 

water usage for make-up and blow-down. (0055-3 [Inge, Charles] [King, Arnold] [Rosenfeld, Joshua])

Comment: That a specific case in point in the applicant's use of the annual average wet-bulb 

temperature of 76 degrees Fahrenheit, rather than normal summer design wet-bulb temperature 

of 78 degrees Fahrenheit to calculate cooling water usage, indicating that a greater volume of 

cooling water will be needed at precisely the time when the area and the reactor water demand 

is at its maximum and drought conditions are most likely. In addition, the exhaust from the four 

large cooling towers and associated spray ponds should increase the design wet-bulb 

temperature for the cooling towers by one or two degrees, thus increasing the cooling tower size 

considerably and the amount of water usage for makeup water and blow-down. (0063-36-3

[Hackett, Ken]) 

Response: These comments question the assumptions used by the Applicant in estimating the 

amount of water required to operate the proposed CPNPP Units 3 and 4. The comments 

suggest that the Applicant may have underestimated the water requirement. Although the wetbulb temperature design value of 76 degrees Fahrenheit, as used by the Applicant to size the 

cooling towers, is lower than the worst one-day average value of 78.6 degrees Fahreneit 

reported for the Dallas-Ft. Worth Airport, it is consistent with the worst consecutive 30-day wet 

bulb average value, which is 76.1 degrees Fahrenheit. As a result, there may be short 

periods when the actual wet-bulb temperature exceeds the design wet-bulb temperature. This 
Appendix E 

NUREG-1943 E-76 May 2011 

would decrease the operating efficiency of CPNPP Units 3 and 4, and it might require that the 

units de-rate (i.e., reduce electrical output) or shut down, but it would not affect the amount of 

heat that must be dissipated by the cooling tower or the amount of water used for operating the 

units. These comments did not result in any changes to the EIS text. 

Comment: The shoreline habitat discussion on page 5-19 identified a reduction in water levels 

in PKL and Lake Granbury and a reduction in Brazos River flows between Lake Granbury and 

Lake Whitney. The DEIS indicates a maximum modeled change during periods of extreme 

drought in Lake Granbury is 2.5 feet and at PKL is 12.6 feet. The DEIS did not indicate the 

amount of reduction in Brazos River flows. Some shoreline areas contain steep, rocky terrain, 

while other portions, such as coves, contain shallower wetland habitat. The water level changes 

in the lakes will cause shoreline vegetation to migrate to a lower elevation. Drastic changes in 

water level can cause colonization of undesirable or invasive vegetation and affect shallow 

wetland habitat. Recommendation: TPWD recommends the applicant mitigate for the 

ecosystem impacts resulting from drops in water levels. TPWD suggests Luminant delineate 

and quantify shoreline habitat from PKL to the Brazos River at Lake Whitney and utilize these 

data to develop a strategic monitoring and mitigation plan to account for impacts to the Brazos 

River ecosystem including impacts to shoreline habitat and wetlands. Habitats should be 

delineated pre-operation and at incremental periods once operation begins. Mitigation could 

include monitoring and controlling undesirable or invasive species and restoring diverse wetland 

habitats along the lakes and river shoreline. The anticipated amount of reduction in Brazos 

River flows should be provided in the DEIS. (0068-66 [Melinchuk, Ross] [Wicker, Julie]) 

Response: Section 5.2.2.1 of the EIS has been revised to provide additional information on 

impacts of the proposed new units on water levels in the lakes and stream flows in the Brazos 

River. For the extreme conditions of the drought of record in 1953, the analysis indicates that 

Lake Granbury water levels could be almost 3 ft lower than with the new units operating than 

without the new units, while Possum Kingdom Lake water levels could be almost 15 ft lower with 

the new units than without them. Under more typical conditions, flows and water levels would 

be lower on average, but the overall ranges of water levels and flows would be essentially the 

same. That is, there would still be periods of high stream flows and full pools in the lakes, lower 

flows and reduced pools in the lakes would occur more often. Drastic fluctuations could occur 

during floods and other high-flow periods, but operation of the new units would not cause drastic 

fluctuations at other times. However, lower average stream flows and lake levels would 

increase the duration and areal extent of dry conditions affecting shoreline habitat. The 

recommendation in the comment is noted. 

E.2.8 Comments Concerning Hydrology - Groundwater 

Comment: TPWD notes various inconsistencies in the DEIS including the following: The 

number of potable groundwater wells stated on Page 2-20 differs from what is stated on 

Page 2-24. (0068-10 [Melinchuk, Ross] [Wicker, Julie])

Comment: DEIS Section 2.3.1.2, page 2-20, lines 9-15: Eleven existing water wells were 

identified on the CPNPP site. The wells include: six potable water wells that support CPNPP 

Units 1 and 2 operations; four observation wells, one of which was identified as a converted 

domestic well; and one privately owned stock well. 

ER Revision 0 did state there were 11 onsite wells, but the number was revised in Revision 1 to 

correctly state 12 onsite wells. The wells include seven active potable water wells that support 

CPNPP Units 1 and 2 operations, one inactive potable water well associated with Squaw Creek 

Park, and four observation wells. [ER 2.3.2.3] (0073-2 [Flores, Rafael])
Appendix E 

May 2011 E-77 NUREG-1943 

Response: Sections 2.3.1.2 and 2.3.2 in the final EIS have been corrected to resolve 

inconsistencies and incorporate the revised information supplied by the applicant.

Comment: The DEIS explains that CPNPP will use only a small amount of groundwater and 

that depletion of the aquifer should not be a concern. The CPNPP is located in Hood and 

Somervell counties. Hood County is in the Upper Trinity Groundwater Conservation District and 

Somervell County is in the Prairie land Groundwater Conservation District, no legal restrictions 

are imposed on groundwater withdrawals. However, if the amount of groundwater usage should 

increase in the future, EPA recommends that the Groundwater Conservation Districts (GCD) 

should be contacted. Their contact information can be found at the following website. 

http://www.twdb.state.tx.us/gwrd/gcd/gcdhome.htm (0070-4 [Smith, Rhonda])

Response: Section 2.3.2.2 of the final EIS has been revised to acknowledge that Somervell 

County is now part of the Prairielands Groundwater Conservation District, which was formed in 

2009. As discussed in Section 2.3.2.2, Luminant plans to supply all CPNPP site potable water 

needs with water from Wheeler Branch Reservoir, and Luminant has implemented a 

groundwater use reduction program at Units 1 and 2 which has greatly reduced its current 

groundwater use. Thus, there is no expectation of increased groundwater use. If the use of 

groundwater were to increase in the future, Luminant would be responsible for coordination with 

the respective Groundwater Conservation Districts. 

Comment: The CPNPP is located in the Trinity Aquifers outcrop area where released 

contaminants have the potential to percolate to the Twin Peaks formation which is a source of 

fresh water for down gradient users. From the groundwater point of view, a major concern of 

EPA is the facility's reliance on a Blowdown Treatment Facility (BDTF) that has a 47 acre 

storage pond and a 128 acre evaporation pond to treat high TDS waters. This could result in a 

build-up of even higher TDS as the minerals build up in the evaporation pond as evaporation 

reduces the water volume. This water has the potential to overflow, given that the freeboard 

design is only for a 10 year, 2 hour rainfall event. EPA is concerned that over time, the 

accumulation of salts from the cool down towers and the misters at the BDTF have the potential 

to infiltrate into the groundwater. (0070-5 [Smith, Rhonda])

Response: The discussion in Section 5.2.3.2 of groundwater quality impacts associated with 

the proposed BDTF has been revised to more fully address the potential for impacts, as 

described in the comment. 

Comment: Also, because of potential groundwater contamination, EPA recommends that the 

twenty 100 feet deep well clusters that were installed in 2006 for baseline monitoring for CPNPP 

Units 3 and 4 continue to be monitored during operational time ofthe CPNPP and for the same 

time after Units 3 and 4 have been discontinued to insure no contaminants (salts from 

evaporation and lagoon leakage) are endangering the groundwater in the project vicinity. (0070-

7 [Smith, Rhonda])

Response: Monitoring of groundwater in the vicinity of the BDTF is a potential mitigation 

measure that could help to avoid or reduce adverse impacts related to the evaporation ponds. 

Section 5.2.5 has been revised to reflect this. However, because many of the baseline 

monitoring wells installed in 2006 will be destroyed during construction they could not be used 

for long-term monitoring. Additionally, while the NRC has authority to require and review 

radiological monitoring on the site, any requirement for non-radiological groundwater monitoring 

near site facilities, such as the BDTF, would be implemented under the EPA Clean Water Act 

or by the Texas Commission on Environmental Quality through the applicable permitting 

process. The permits that Luminant must obtain are listed in Appendix H of this EIS. 
Appendix E 

NUREG-1943 E-78 May 2011 

Comment: The EIS should examine the impacts of vast water consumption on the aquifer and 

the water table levels. Will wells be sucked dry? How high is the risk of contamination of the 

aquifer and other waterways through radioactive leaks? Could the problem ever be remediated 

if radioactive or chemical leaks occurred? (0071-33 [Hadden, Karen])

Response: Impacts on groundwater quantity from reactor operation are examined in EIS 

Section 5.2.2.2. Operation of CPNPP Units 3 and 4 would not increase the use of groundwater 

at the CPNPP site. The water requirements for the new units would be supplied from surface 

water sources. Also, groundwater use by Units 1 and 2 has been reduced in recent years and 

is expected to decrease further in the future due to the use of surface water from Wheeler 

Branch Reservoir. As a result of this decreased usage, the impact on groundwater quantity is 

judged to be SMALL. Impacts on groundwater quality from construction and operation are 

examined in EIS Sections 4.2.3.2 and 5.2.3.2, respectively, and are judged to be SMALL. 

Because shallow groundwater in the vicinity of the site area is not used for water supply, the 

underlying drinking water aquifer is overlain by low permeability rock, and the most plausible 

pathway of any contamination entering shallow groundwater from leaks or spills is toward 

Squaw Creek Reservoir, there is little risk of contamination to the aquifer. No changes were 

made to the EIS as a result of this comment. 

Comment: Subsidence is a shifting downward of the earth’s surface. Causes of subsidence 

include depleted groundwater, mining, natural gas and oil extraction. What impacts are there 

from existing industries that put the area at risk? What landfills are still in existence that could 

contaminate cooling water? Will local oil and gas operations impact the plant site or vice versa?

(0071-40 [Hadden, Karen])

Response: The comment is concerned with the potential for land-surface subsidence and 

groundwater contamination due to resource-extraction activities, industry, and landfills in the 

area. The review team conducted a review to identify past, present, and reasonably 

foreseeable future actions and activities in the site region that could result in cumulative 

impacts. EIS Section 7 describes the methodology and findings of this review and Section 

7.2.2.2 presents an assessment of potential cumulative impacts to groundwater quality. Also, 

Section 2.8 discusses subsidence, which is not an issue in the site area. No changes were 

made to the EIS as a result of this comment. 

E.2.9 Comments Concerning Ecology - Terrestrial 

Comment: Last but not least, from an economic -- from an ecological standpoint, I noticed we 

saw the golden-cheeked warblers and some other animals that have been evaluated here. But 

also, as a hobby of mine as a photographer of nature, the last five to ten years I've seen bald 

eagles, osprey eagles, Mexican eagles, owls all migrate to this area. So I think this has been an 

ecologically stronghold for bringing in nature that has typically not been in this area. And that's 

something that I've observed the last five to ten years, as opposed to the '50s and '60s when 

there were not those type of migratory birds in this area. (0063-28-2 [Marks, Gary])

Response: These comments support the discussion of baseline ecological conditions 

presented in Section 2.4.1.1 of the EIS. This baseline discussion supports the analyses of 

potential impacts of birds and other terrestrial wildlife in Sections 4.3.1, 5.3.1, and 7.3. .These 

Sections have been revised to include additional information regarding threatened and 

endangered species. 

Comment: I also wanted to say that the impact on humans, wildlife and plant life need to be 

considered with special attention given to threatened and endangered species. (0063-32-6

[Rooke, Molly])
Appendix E 

May 2011 E-79 NUREG-1943 

Response: These impacts have been considered in the EIS. Impacts to threatened and 

endangered species are specifically addressed in Sections 2.4.1.3, 4.3.1.3, and 5.3.1.3. These 

Sections have been revised to include additional information regarding threatened and 

endangered species . 

Comment: The DEIS indicates that the endangered black-capped vireo (Vireo atricapillus) and 

golden- cheeked warbler (Dendroica chrysoparia) may occur within Hood and Somervell 

Counties. A relatively small patch of potentially suitable golden-cheeked warbler habitat exists 

within a portion of the project site near the reservoir shoreline. On February 2, 2009, U.S. Fish 

and Wildlife Service personnel and Comanche Peak Nuclear Power Plant facility staff visited the 

project area to assess habitat suitability. During this site visit, habitat patch size was 

determined to be too small and distant from other suitable habitat to be likely to support goldencheeked warblers. Likewise, the vegetation present consisted almost entirely of ashe juniper 

(Juniperus asheii) with few necessary hardwood trees present. (0064-2 [Martinez, Shirley] 

[Spencer, Stephen])

Response: Information describing this small patch of potentially suitable habitat and the basis 

for a conclusion that it is too small for a breeding pair of golden-cheeked warblers is included in 

Section 4.3.1.3 of the EIS. The EIS was not changed in response to this comment.

Comment: The DEIS does not, however, mention the endangered whooping crane (Grus 

americana) which is known to stopover at wetlands, water bodies, and croplands in Hood and 

Somervell Counties during its annual migration. The FWS is concerned that the proposed 47-

acre storage pond and 128-acre evaporation pond may be an attractive destination to migrating 

whooping cranes. (0064-4 [Martinez, Shirley] [Spencer, Stephen])

Response: Additional information concerning potential impacts to whooping cranes from 

proposed project features has been added to the EIS in Sections 2.4.1.3, 4.3.1.3 and 5.3.1.3. 

Comment: Because the new transmission lines are in the vicinity of potential habitat, known 

occurrences, and migratory corridors of endangered species, there may be unforeseen impacts 

to the federal-and state-endangered Black-capped Vireo (Vireo atricapilla) (BCY), Goldencheeked Warbler (Dendroica chrysoparia) (GCW), and Whooping Crane (Grus americana). 

Potential impacts to these species associated with transmission line construction and operation 

cannot be determined from the information presented in the DEIS, as site surveys along the 

routes for suitable breeding and/or migratory stopover habitat have not been conducted. (0068-

6 [Melinchuk, Ross] [Wicker, Julie])

Response: Potential impacts to Federal and state listed threatened and endangered species 

from new transmission lines following estimated general corridors are discussed in Sections 

4.3.1.3 and 5.3.1.3 of the EIS. The EIS text notes that until the exact routes of the transmission 

lines are chosen, the possibility of adverse impacts to these species as a result of constructing 

the transmission lines can not be ruled out. Sections 4.3.1.3 and 5.3.1.3 of the EIS have been 

revised to provide additional details on Federal and state listed threatened and endangered 

species.

Comment: Hydrologic changes in the Brazos River ecosystem will result from increased 

withdrawals and consumptive water losses and associated alterations in water management 

from Possum Kingdom Lake to the Brazos River below Lake Granbury. Impacts on aquatic and 

wetlands biota and habitat could be substantial as a result of hydrologic alterations to the 

Brazos River system, particularly Lake Granbury, Possum Kingdom Lake, and the river below 

Lake Granbury. The reductions in water levels would likely change shoreline vegetation, affect 
Appendix E 

NUREG-1943 E-80 May 2011 

shallow water habitats, and affect access to both public and private boat docks and ramps, 

especially during drought conditions. (0068-3 [Melinchuk, Ross] [Wicker, Julie])

Response: Impacts to shoreline habitat are described in Section 5.3.1.1. Impacts to aquatic 

and wetlands biota are addressed in Section 5.3.2. No changes to the the EIS have been 

made as a result of this comment. 

Comment: Page 2-40 indicates the CPNPP site is a migratory stopover for birds, especially 

waterfowl. Within Texas, the federal- and state-listed endangered Whooping Crane (Grus 

americana) utilizes a 200mile wide primary migration corridor. The CPNPP site occurs within 

the central-most 60-mile wide corridor within which 75 percent of migration sightings have been 

documented. Recommendation: TPWD recommends the DEIS Page 2-40 reflect the 

Whooping Crane migration corridor as an important migratory and stopover route that crosses 

the CPNPP site. (0068-19 [Melinchuk, Ross] [Wicker, Julie])

Response: This information has been added to Section 2.4.1.1.

Comment: Page 2-45 indicates the federal- and state-listed endangered Black-capped Vireo 

(Vireo atricapilla) (BCV) is only found in Oklahoma and Texas. BCV are known to nest in 

Mexico and winter exclusively in Mexico. Recommendation: TPWD recommends the DEIS 

include BCV current range. (0068-21 [Melinchuk, Ross] [Wicker, Julie])

Response: This information has been added to Section 2.4.1.3. 

Comment: Page 2-50 mentions a record for the species of concern Glen Rose yucca (Yucca 

necopina) as possibly occurring within the discharge pipeline ROW. TPWD is including more 

detailed reports and maps for all records of rare and listed species within 1.5 miles of the project 

site, transmission lines and pipelines. Please note that three records for this species, EOID 

8961, 7952 and 813, could occur in the ROW of the transmission line or water pipeline, 

depending on the final proposed alignments. As indicated through previous correspondence, 

the TXNDD does not include a representative inventory of rare resources in the state. Absence 

of information in the database does not imply that a species is absent from the area. 

Recommendation: TPWD recommends updating the DEIS to indicate that Glen Rose yucca 

may occur where suitable habitat is present and suitable habitat for the species may occur 

within the project site including the proposed transmission line and pipeline ROWs. (0068-24

[Melinchuk, Ross] [Wicker, Julie])

Response: Additional information on the Glen Rose yucca has been added to the EIS in 

Section 2.4.1.3. 

Comment: The DEIS indicates that the native grasses are the preferred cover for most 

disturbed areas and promote diversity. However, page 4-13 refers to buffalograss (Bouteloua 

dactyloides) as an improved grass that would be used in highly erosive areas. 

Recommendation: Buffalograss is a native grass and TPWD recommends correcting the text. 

TPWD supports the use of this species in landscaped areas mixed with Blue grama (Bouteloua 

gracilis) for a low maintenance turf grass. Buffalograss can be used elsewhere for erosion 

control in diverse native seed mixes with Blue grama, Green sprangletop (Leptochloa dubia), 

Curly mesquite (Hilaria berlangeri), Indiangrass (Sorghum nutans), Little bluestem 

(Schizachyrium scoparium), Prairie wildrye (Elymus canadensis), Texas cupgrass (Eriochloa 

sericea), Sand dropseed (Sporobolus cryptandrus), Sand Lovegrass (Eragrostis trichodes), 

Cane bluestem (Bothriochloa barbinodis) and Sideoats grama (Bouteloua curtipendula). (0068-

40 [Melinchuk, Ross] [Wicker, Julie])
Appendix E 

May 2011 E-81 NUREG-1943 

Response: Section 4.3.1.1 has been revised to indicate that buffalograss is a native species 

and to include other information from this comment in the discussion of how disturbed areas 

might be seeded. 

Comment: Page 4-22 states that monitoring for federally and state protected species would 

take place during pre-construction activities, and Luminant would stop work and contact state 

agency officials if workers encounter special status species, their habitat or vegetation. 

Recommendation: TPWD appreciates that Luminant has made this commitment to help protect 

sensitive state resources. Luminant may contact the following staff if special status species are 

encountered at the site: TPWD regional diversity biologist Nathan Rains, TPWD Headquarters 

Diversity Program at (512) 389-8111, or TPWD assessment biologist Celeste Brancel. (0068-44

[Melinchuk, Ross] [Wicker, Julie])

Response: Your recommendation is noted. No changes to the EIS have been made as a 

result of this comment. 

Comment: There is no reference to Fossil Rim regarding potential areas of important species 

impacts. Recommendation: TPWD recommends including the potential for impacts to Fossil 

Rim as contributing to the potential for moderate impacts. (0068-45 [Melinchuk, Ross] [Wicker, 

Julie])

Response: A discussion of potential impacts to Fossil Rim have been added to Section 

4.3.1.3, 4.3.1.6, and 5.3.1.3 of the EIS. 

Comment: The DEIS indicates that new transmission lines are not anticipated to cause any 

increase in bird collisions if proper mitigation were employed and would not be expect to 

increase and contribute to cumulative effects. TPWD is concerned that the proposed project 

and future development in the area would increase the number of transmission lines in the area, 

and without guaranteed mitigation measures, may cause cumulative increases in bird collisions. 

At this time, mitigation measures to reduce bird collisions for this project have not been decided 

for the five proposed transmission lines associates with the project. Additionally, the BDTF site 

layout has not been finalized; thus strategic placement of the evaporation ponds away from 

existing transmission lines to minimize bird collisions has not been finalized or employed. The 

DEIS indicates the proposed project and future development in the area would likely reduce 

habitat of the Limestone Cut Plain of the Western Cross Timbers ecoregion, and such impacts 

may be sufficient to noticeably alter the important attributes of wildlife habitat. Cumulative 

impacts to terrestrial ecological resources are assessed as MODERATE. Recommendation:

Strategic transmission line placement and guaranteed use of bird collision deterrent devices 

would be actions to reduce the cumulative impacts. To mitigate for cumulative losses to wildlife 

habitat, developers for this and future projects should employ site planning, design, and 

construction to limit disturbance footprints and to permanently set aside large contiguous areas 

and corridors to support wildlife habitat. Because the CPNPP site encompasses a large area of 

habitat that will remain undeveloped, management strategies to promote wildlife conservation 

and diversity will aid in mitigating the cumulative impact associated with habitat loss due to the 

project. (0068-63 [Melinchuk, Ross] [Wicker, Julie])

Response: The mitigation measures proposed in this comment would aid in minimizing 

cumulative impact associated with habitat loss due to the project. Information on the possible 

benefits of the measures has been added to Sections 4.3.1.5 of the EIS. However, any decision 

to implement the measures would have to be made by Luminant and Oncor. The NRC does not 

have the authority to require the proposed mitigation.
Appendix E 

NUREG-1943 E-82 May 2011 

Comment: Figure 2-13 shows the approximate 345-kV transmission line alignment to Whitney 

could cross through both Dinosaur Valley SP and Fossil Rim. Ecologically oriented recreational 

areas identified in the DEIS as wildlife protection areas include, among others, Dinosaur Valley 

SP and Fossil Rim, though Page 2-50 indicates that Dinosaur Valley SP is the only wildlife 

protection area that could potentially be affected by new transmission line construction. 

Recommendation: The DEIS page 2-50 should be updated to reflect that Fossil Rim may also 

be affected by a transmission line crossing. Subsequent DEIS evaluation of impacts associated 

with the Whitney transmission line should also include Fossil Rim. (0068-25 [Melinchuk, Ross] 

[Wicker, Julie])

Response: Section 2.4.1.3 of the EIS has been updated to indicate that Fossil Rim may also 

be affected by a transmission line crossing. Potential impacts of this crossing have been 

evaluated in subsequent sections. 

Comment: The DEIS also indicated that, depending on the final route ultimately selected, the 

Whitney transmission line right-of-way associated with this project could pass through habitat 

occupied by black-capped vireos and/or golden-cheeked warblers. The FWS recommends a 

qualified biologist assess habitat suitability for both species within the proposed Whitney 

transmission line right-of-way and contact the FWS if suitable habitat is found. The FWS would 

be willing to assist in developing alternative routes or other measures to minimize/avoid impacts 

to either of these species. (0064-3 [Martinez, Shirley] [Spencer, Stephen])

Response: The EIS evaluates potential impacts from estimated general corridors for the 

transmission lines. Under Texas Statutes, Oncor Electric Delivery System LLC would be 

responsible for applying to the Public Utility Commission of Texas to identify specific routes for 

the transmission lines. As explained in Section 4.3.1.2 of the EIS, selection of the final routes 

for the transmission lines will follow a legal and regulatory process of ERCOT and PUCT that 

includes the preparation of a separate Environmental Analysis. If appropriate, field evaluations 

of habitat within the selected routes can be conducted at that time. Your recommendation is 

appreciated and should be made as part of this future regulatory process. The EIS was not 

changed in response to this comment.

Comment: Because new power lines are also proposed to provide power for necessary 

pumping facilities for these ponds, along with high voltage power lines planned and existing 

within the vicinity, the possibility exists that whooping cranes or other migratory birds may be 

killed by colliding with these power lines. The DEIS does not indicate that bird flight diverters or 

other marking devices would be installed as part of the proposed project. The FWS is 

requesting the electric transmission industry’s assistance in reducing the cumulative impacts to 

the whooping crane from power lines within the migratory corridor. The FWS is recommending 

the proposed project be marked as described in, “Mitigating Bird Collisions with Power Lines: 

The State of the Art in 1994,” by the Avian Power Line Interaction Committee. For the FWS to 

track cooperative efforts to mitigate collision hazards, we would appreciate being notified if any 

active mitigation measures (i.e., bird flight diverters) for whooping cranes and other migratory 

birds are incorporated into this project. Marking power lines with red aviation balls or similar 

bird diverters, especially near wetlands and riparian corridors, has been shown to reduce the 

incidence of collision by 60 to 70 percent (APLIC 1994 [Mitigating Bird Collisions with Power 

Lines: the State of the Art in 1994. Edison Electric Institute. Washington, D.C.]). By marking 

new, re-constructed, and existing power lines in areas within close proximity to known or 

anticipated stop-over and foraging sites, the collision hazard can be substantially reduced. 

(0064-5 [Martinez, Shirley] [Spencer, Stephen])

Response: Section 5.3.1.1 of the EIS states that transmission lines would be monitored for 

possible adverse impacts on birds and bird deterrent procedures and equipment would be used 
Appendix E 

May 2011 E-83 NUREG-1943 

as needed (e.g., noise cannons, netting, artificial predators, periodic patrols, and minimizing 

periods of time in which standing water is present) (Luminant 2009f). Luminant further states 

that bird deterrents or other devices that might be used would be selected during the final 

design stage based on discussions with the TPWD and the USFWS (Luminant 2009f). 

Recommendations concerning marking of power lines associated with cooling system operation, 

as well as the new Whitney and DeCordova transmission lines, could be coordinated during 

these discussions. In addition, your recommendations could be presented during the final route 

selection process according to legal and regulatory process of ERCOT and PUCT. This 

process includes the preparation of a separate Environmental Analysis for the Whitney and 

DeCordova transmission lines. The EIS was not changed in response to this comment. 

Comment: Construction of the transmission line may potentially take nesting migratory birds 

(eggs, nestlings, or adults) if that construction occurs during the nesting season. Such take 

would constitute a violation of the Migratory Bird Treaty Act (MBTA). To avoid take under the 

MBTA, those actions that could take migratory birds should be completed outside of their 

nesting seasons. This includes clearing or cutting of vegetation or grubbing. Nesting seasons 

for migratory birds vary greatly between species and geographic location, but generally peak 

from early April to mid-July. However, the breadth of the nesting season can extend from early 

February through late August depending on which species occur in the project area, with a few 

species nesting into November. Eagles may initiate nesting as early as late December or 

January in some areas. Due to this variability, project proponents should consult with the 

FWS’s Regional Migratory Bird Office (U.S. Fish and Wildlife Service, Migratory Bird Office, 

P.O. Box 1306, Albuquerque, New Mexico 87103; phone: 505-248-6878) for information on 

specific nesting seasons at the locality in question. The FWS recommends you strive to 

complete all disruptive activities outside the peak of migratory bird nesting season to the 

greatest extent possible and always avoid any habitat alteration, removal, or destruction during 

the primary nesting season for migratory birds. Clearing of vegetation in the year prior to 

construction (but not within the nesting season) may discourage birds from attempting to nest in 

the proposed construction area, thereby decreasing chance of take during construction 

activities. (0064-6 [Martinez, Shirley] [Spencer, Stephen])

Response: This request for consultation and mitigation for possible transmission line impacts 

is noted. Section 4.3.1.5 has been expanded to discuss the possible benefits of these actions; 

however, the decision to implement them will lie with Luminant and Ocor once they have 

selected exact routes for the transmission lines. 

Comment: The approximate location of the proposed 345-kV Whitney transmission line shown 

in the DEIS crosses Dinosaur Valley State Park. In addition to providing habitat for the BCY 

and GCW, this state park offers public recreation activities that would be impacted by 

construction of a transmission line across or in sight of the park. This park and its viewshed 

should be avoided if at all possible. If the final project design requires that transmission lines 

cross any state-owned or managed lands, such as Dinosaur Valley State Park, the NRC, 

Luminant, and Oncor should be aware of the requirements of Chapter 26 of TPW Code 

(Chapter 26) discussed in Attachment A. (0068-7 [Melinchuk, Ross] [Wicker, Julie])

Response: The specific route for this new transmission line would be established by the Public 

Utility Commission of Texas in response to an application from Oncor Electric Delivery System 

LLC. The route selection process will comply with all applicable Federal, State, and local laws, 

regulations, and ordinances. The EIS was not changed in response to this comment.

Comment: The NRC transmittal letter indicated that the NRC and USACE have different 

regulatory authorities and requests that if TPWD issues an incidental take statement then 

TPWD should specify within the statement which terms and conditions are imposed on which 
Appendix E 

NUREG-1943 E-84 May 2011 

agency. Under Chapter 68, Texas Parks and Wildlife (TPW) Code, state-listed species are 

prohibited from take. TPW Code does not establish an incidental take permit analogous to the 

U.S. Fish and Wildlife Service (USFWS) Section 10 permit established under the Endangered 

Species Act. TPWD cannot provide an incidental take permit in response to a DEIS. 

Recommendation: Although TPWD does not provide incidental take permits, only personnel 

with a TPWD scientific collection permit are allowed to handle and move state-listed species. 

Should the applicant require moving state-listed species out of harms way for construction 

activities, the person handling the species must possess a scientific collection permit, which can 

be obtained from TPWD Permitting Specialist, Chris Maldonado, at (512) 389-4647 or at 

Chris.Maldonado@tpwd.state.tx.us. (0068-9 [Melinchuk, Ross] [Wicker, Julie])

Response: This comment is directed toward the applicant since the NRC has no authority over 

the State of Texas’ permitting requirement. However, Section 4.3.1.4 of the EIS has been 

revised to discuss the requirement for a scientific collection permit prior to relocation of statelisted species.

Comment: Pages 2-46 and 2-47 and Chapter 4 pages 4-20 and 4-21 correctly indicate the 

BCV and the federal- and state-listed endangered Golden-cheeked Warbler (Dendroica 

chrysoparia) (GCW) have been observed as foraging and nesting within Dinosaur Valley SP. 

TPWD records indicate the BCV and GCW have also been observed at Fossil Rim Wildlife 

Center (Fossil Rim) and are identified as Texas Natural Diversity Database (TXNDD) Element 

Occurrence Record (EOID) 7664 and EOID 2780, respectively. These occurrences were 

mapped and provided in DEIS reference TPWD 2009i. Please refer to the additional attached 

detail records for these locations. Recommendation: The DEIS should be updated to indicate 

that the BCV and GCW have been recorded at Fossil Rim, which tentatively occurs within the 

proposed corridor of the 45-mile Whitney transmission line. TPWD recommends the NRC 

contact Fossil Rim directly for more current information on the documented rare, threatened and 

endangered species present at the site. This facility conducts research and breeding programs 

for endangered species, including native and exotic endangered species. Subsequent chapters 

that address impacts should include potential impacts at Fossil Rim. Please note that later 

sections in this letter address TPWD concerns related to transmission lines in the vicinity of 

state parks and impacts of transmission line construction on wildlife, habitats and 

paleontological resources. (0068-22 [Melinchuk, Ross] [Wicker, Julie])

Response: The information provided in this comment, including additional information on 

ongoing activities at Fossil Rim, has been added to the EIS. 

Comment: Page 2-47 indicated the Whooping Crane could possibly migrate over the project 

area, though no natural heritage records for occurrence exist for the species in Hood, Somervell 

or Bosque counties, nor are there natural heritage records for occurrences within 10 miles of the 

site, transmission lines, and pipelines. It is important to understand the basis and limitations of 

the TXNDD dataset for appropriate interpretation. For the Whooping Crane, methodology 

includes mapping only wintering grounds and repeated-use stopover sites in Texas. Because 

observations of birds in migration would not be mapped, the TXNDD is not expected to contain 

an occurrence record of a migratory flyover or single confirmed stopover of the Whooping 

Crane. As indicated in previous correspondence, for federally-listed species it is important to 

contact the USFWS for additional data and information on these species. Recommendation:

TPWD recommends the NRC consult with the USFWS for possible additional information on the 

nearest and most current recorded stopover sites for the Whooping Crane in central and north 

Texas. The DEIS should include additional detail on this species, including the potential on-site 

habitat and suitable stopover habitat in the vicinity of the proposed transmission lines and 

pipelines. Wetland habitat should not be limited to jurisdictional wetlands, as non-jurisdictional 
Appendix E 

May 2011 E-85 NUREG-1943 

wetlands also provide habitat for the Whooping Crane. Further information on the Whooping 

Crane migration corridor and Whooping Crane migratory behaviors are available in the 

International Recovery Plan for the Whooping Crane (USFWS 2007) at 

http://ecos.fws.gov/docs/ recovery_plan/070604_v4.pdf and in Whooping Cranes and Wind 

Development: An Issue Paper (USFWS 2009) at http://www.fws.gov/southwest/es/library/. 

(0068-23 [Melinchuk, Ross] [Wicker, Julie])

Response: NRC obtained additional information from USFWS on stopover habitat for the 

whooping crane in central and north Texas. Sections 4.3.1.3 and 5.3.1.3 of the EIS have been 

modified to include consideration of this additional information. The EIS addresses impacts to 

any wetlands meeting federal criteria based on vegetation, soils, and hydrology, regardless of 

jurisdictional status under the Clean Water Act.

Comment: Page 3-28 also states the electrical lines would meet or exceed the design 

requirements set forth in the National Electrical Safety Code and American National Standards 

Institute. The Avian Power Line Interaction Committee (APLIC) has developed the following 

guidelines for minimizing adverse encounters with wildlife. 

 APLIC. 1994. Mitigating Bird Collisions with Power Lines: The State of the Art in 1994. 

Edison Electric Institute, Washington, D.C., 78 pp. 

 APLIC. 2006. Suggested Practices for Avian Protection on Power Lines: The State of the 

Art in 2006. Edison Electric Institute, APLIC, and the California Energy Commission, 

Washington, D.C. and Sacramento, CA, 140 pp. 

Recommendation: TPWD recommends Luminant and Oncor incorporate these guidelines into 

the project to limit adverse impacts to wildlife, including migratory birds. These resources are 

available online at: www.aplic.org, www.eei.org, www.energy.ca.gov or at 1-800-334-5453. 

(0068-37 [Melinchuk, Ross] [Wicker, Julie])

Response: Section 5.3.1.1 of the EIS states that for transmission lines associated with cooling 

system operation potential impacts on birds would be monitored and bird deterrent procedures 

and equipment would be used as needed (e.g., noise cannons, netting, artificial predators, 

periodic patrols, and minimizing periods of time in which standing water is present) (Luminant 

2009f). Luminant further states that bird deterrents or other devices that might be used would 

be selected during the final design stage based on discussions with the TPWD and the USFWS 

(Luminant 2009f). The recommendations included in the comment concerning marking of 

power lines associated with cooling system operation, as well as the new Whitney and 

DeCordova transmission lines, could be coordinated during these discussions. In addition, the 

recommendations could be presented during the final route selection process according to legal 

and regulatory process of ERCOT and PUCT. This procedure includes the preparation of a 

separate Environmental Analysis for the Whitney and DeCordova transmission lines. The 

APLIC references have been added to Section 5.3.1.5 as potential mitigation measures. Other 

than that, the EIS was not changed in response to this comment.

Comment: Page 4-21 states the map provided by TPWD showed no records of rare species 

occurrences at Fossil Rim. As previously discussed, occurrences for the BCV and GCW, EOID 

7664 and 2870, respectively, have been recorded for Fossil Rim. The discussion of impacts 

indicates that, other than Dinosaur Valley SP, construction and preconstruction would have 

minimal impact on important habitat. TPWD notes that Dinosaur Valley SP and Fossil Rim are 

not the only important terrestrial habitat in the area. Large acreages of grassland and forest 

occur within the affected counties. It is erroneous to assume that the managed preserves and 

areas with known TXNDD occurrences of rare resources are the only important sources of 

habitat. Not only are known locations of rare resources important, also important are 
Appendix E 

NUREG-1943 E-86 May 2011 

undocumented locations of rare resources. The absence of data in the TXNDD is not to be 

interpreted as absence of rare and protected species or important habitats on the landscape. 

Recommendation: TPWD recommends every effort be made to avoid crossing Dinosaur Valley 

SP and Fossil Rim and to avoid disturbance to wildlife habitat along the transmission line routes 

with potential to support rare species. Wildlife habitat contiguous with Dinosaur Valley SP and 

Fossil Rim should also be avoided. To protect large areas of habitat important to wildlife, TPWD 

also recommends that the transmission lines be sited in previously disturbed areas, along 

existing utility ROW, and away from areas of habitat to minimize the fragmentation that results 

from transmissions lines. Site surveys of the preferred and alternative routes should be 

conducted for the EIS to assess the habitat and determine potential impacts, including potential 

impacts to listed species and their habitat. Mitigation measures, of this section and NRC’s 

conclusions and recommendations Table 10-1, should include avoidance of Fossil Rim as well 

as avoidance of areas of BCV and GCW suitable habitat. (0068-41 [Melinchuk, Ross] [Wicker, 

Julie])

Response: The specific route for this new transmission line would be established by the Public 

Utility Commission of Texas in response to an application from Oncor Electric Delivery System 

LLC. The route selection process will comply with all applicable Federal, State, and local laws, 

regulations, and ordinances. The recommendations in this comment could be presented during 

the final route selection process according to the legal and regulatory procedures of ERCOT 

and PUCT. These procedures include the preparation of a separate Environmental Analysis for 

the transmission lines. The EIS has been updated to include information on Fossil Rim Wildlife 

Center. Mitigation measures in Section 4.3.1.5 and Table 10-1 have modified to include 

avoidance of Fossil Rim Wildlife Center and areas of black-capped vireo and golden-cheeked 

warbler suitable habitat. 

Comment: The discussion of avoiding impacts to BCV and GCW, pages 4-21, 4-22 and 10-3, 

suggest that Oncor could adjust the timing of building and the location of the transmission lines 

within the corridors. Recommendation: Adjustments to ROW clearing and construction timing 

to avoid impacts may not be an acceptable practice and should be discussed with USFWS prior 

to implementing the practice. TPWD supports the recommendation to adjusting the location of 

the transmission lines to avoid habitat of BCV and GCW habitat. TPWD recommends Luminant 

and Oncor avoid removal of BCV and GCW habitat, wherever feasible, and mitigate for the loss 

of habitat for both species when avoidance is not feasible. Avoiding removal of habitat should 

be practiced in the vicinity of Dinosaur Valley SP and Fossil Rim as well as other locations 

within the affected counties that exhibit habitat for these species. Surveys should be conducted 

along the proposed routes to identify suitable habitat. USFWS should be consulted regarding 

permits required for take of federal-listed species and plans to offset the loss of habitat for either 

of these species. If recommended by the USFWS, Oncor and Luminant should manage for 

BCV habitat within transmission line ROW, where site characteristics are appropriate. (0068-42

[Melinchuk, Ross] [Wicker, Julie])

Response: The specific route for this new transmission line would be established by the Public 

Utility Commission of Texas in response to an application from Oncor Electric Delivery System 

LLC. The route selection process would comply with all applicable Federal, State, and local 

laws, regulations, and ordinances. The recommendations in this comment could be presented 

during the final route selection process according to the legal and regulatory procedures of 

ERCOT and PUCT. These procedures include the preparation of a separate Environmental 

Analysis for the transmission lines. The EIS was not changed in response to this comment. 

Comment: The DEIS page 4-23 discusses mitigation actions to be utilized if the Glen Rose 

yucca is encountered during pipeline placement. As previously commented, the Glen Rose 
Appendix E 

May 2011 E-87 NUREG-1943 

yucca may occur where suitable habitat is present throughout the project area including the 

transmission line and pipeline ROWs. Recommendation: TPWD supports our previous 

recommendation to survey for the Glen Rose yucca in areas of suitable habitat that would be 

disturbed by the project activities. TPWD recommends avoiding impact to the Glen Rose yucca 

during site planning and design. If the Glen Rose yucca is found in an area that must be 

disturbed, transplanting the specimens to a new location should be done under the guidance of 

a botanist familiar with this rare species and with the requirements specific to cultivating this 

species. (0068-43 [Melinchuk, Ross] [Wicker, Julie])

Response: Section 4.3.1.3 of the EIS states that monitoring for state protected species, such 

as Glen Rose yucca, would take place prior to ground disturbance of potentially suitable habitat, 

and that Luminant would stop work and contact state officials if workers encounter special 

status species or their habitat. Coordination of any mitigation efforts, such as transplanting, 

could be done during this contact. The EIS was not changed in response to this comment. 

Comment: The DEIS notes the vicinity of the proposed BDTF ponds under and adjacent to 

existing transmission lines and discusses the potential of the ponds to attract birds and cause 

collision-related deaths. The DEIS indicates that Luminant is prepared to monitor for potential 

impacts to birds, conduct bird deterrent procedures, and install bird deterrent equipment as 

needed including noise cannons, netting, artificial predators, periodic patrols, and minimizing 

periods of time in which standing water is present. Such bird deterrent procedures and devices 

would be selected during final design based on discussions with TPWD and USFWS. 

Recommendation: Because the design of the BDTF is not yet finalized, TPWD recommends 

the applicant consider a proactive approach by locating the BDTF ponds away from existing or 

proposed transmission lines. This would eliminate the need for avoidable long-term, laborintensive, or costly preventative measures. TPWD prefers locating the BDTF in areas of 

previous disturbance or low quality habitat, where feasible. An alternative consideration would 

be to re-locate the existing transmission lines away from the proposed ponds. (0068-50

[Melinchuk, Ross] [Wicker, Julie])

Response: The recommendations included in this comment and their possible benefits have 

been noted in Section 5.3.1.1 of the EIS. 

Comment: Page 5-17 indicates that fogging may occur within 0.25 mile north and south of the 

cooling towers including areas around SCR and small wetlands. The DEIS did not indicate if tall 

structures would be within 0.25 mile of the cooling towers and potentially within the fog plume. 

Recommendation: The DEIS should address if fogging due to the cooling towers could increase 

potential bird collisions with existing or proposed tall structures within 0.25 mile of Units 3 and 4 

cooling towers. Tall structures in the area may include Units 1 and 2 and existing or proposed 

transmission lines and towers. (0068-51 [Melinchuk, Ross] [Wicker, Julie])

Response: Additional information has been received from the applicant indicating that the area 

of fogging is larger than originally modeled and reported in the DEIS, and now would extend to 

0.37 mi. Information on the possible occurrence of tall structures within the anticipated 

maximum fogging zone and the possible hazards they pose to birds has been added to Section 

5.3.1.1 of the EIS.

Comment: The DEIS indicates that additional nighttime artificial lighting would be minimal, and 

it would be lessened by using low sodium lighting as was previously done to lessen lighting 

impact from Units 1 and 2. Nighttime artificial lighting can induce fatal light attraction 

phenomenon on night migrating birds. Additional nighttime light may contribute to the effects on 

night-migrating birds when nighttime light combines with cooling tower fog. Recommendation: 

As appropriate to Chapters 2, 3, and 5, TPWD recommends the DEIS include discussions on 
Appendix E 

NUREG-1943 E-88 May 2011 

the amount of additional nighttime light created by the proposed project and the potential effect 

increased lighting combined with cooling tower fog may have on wildlife. In addition to lowering 

lighting levels, TPWD recommends down shielding lights to prevent light from being directed up 

into the night sky. (0068-53 [Melinchuk, Ross] [Wicker, Julie])

Response: The discussion of potential adverse impacts of artificial lighting on migrating birds 

in Section 5.3.1 of the EIS has been expanded. The expanded discussion includes information 

on the possible benefits of down shielding lights. 

Comment: The shoreline habitat discussion on page 5-19 identified a reduction in water levels 

in PKL and Lake Granbury and a reduction in Brazos River flows between Lake Granbury and 

Lake Whitney. The DEIS indicates a maximum modeled change during periods of extreme 

drought in Lake Granbury is 2.5 feet and at PKL is 12.6 feet. The DEIS did not indicate the 

amount of reduction in Brazos River flows. Some shoreline areas contain steep, rocky terrain, 

while other portions, such as coves, contain shallower wetland habitat. The water level changes 

in the lakes will cause shoreline vegetation to migrate to a lower elevation. Drastic changes in 

water level can cause colonization of undesirable or invasive vegetation and affect shallow 

wetland habitat. Recommendation: TPWD recommends the applicant mitigate for the 

ecosystem impacts resulting from drops in water levels. TPWD suggests Luminant delineate 

and quantify shoreline habitat from PKL to the Brazos River at Lake Whitney and utilize these 

data to develop a strategic monitoring and mitigation plan to account for impacts to the Brazos 

River ecosystem including impacts to shoreline habitat and wetlands. Habitats should be 

delineated pre-operation and at incremental periods once operation begins. Mitigation could 

include monitoring and controlling undesirable or invasive species and restoring diverse wetland 

habitats along the lakes and river shoreline. The anticipated amount of reduction in Brazos 

River flows should be provided in the DEIS. (0068-54 [Melinchuk, Ross] [Wicker, Julie])

Response: The discussion of possible mitigation measures addressing impacts to shoreline 

habitats in EIS section 5.3.1.5 has been expanded to describe the measures recommended in 

this comment. Any decision to implement these mitigation measures would lie with Luminant. 

Comment: [TPWD notes various inconsistencies in the DEIS including the following:] Section 5 

species-specific reference for the Guadalupe bass (Micropterus trecullii), TPWD 2009d, is used 

for the reference on every state-listed species on Page 5-23. (0068-11 [Melinchuk, Ross] [Wicker, 

Julie]) 

Response: Section 5.3.1.3 of the EIS has been revised in response to this comment. 

Comment: The DEIS and the Biological Assessment of Appendix F (BA) do not assess 

operational impacts to the federal- and state-listed endangered Whooping Crane. The BA 

analysis relies on observations at the CPNPP site and known occurrences in the TXNDD and 

does not consider migration stopover. The BA indicates Whooping Crane are not likely to use 

the inland habitats found on the site for foraging, roosting, or nesting; thus they are not 

considered further in the BA. As previously indicated, the project site is located within the 

Whooping Crane migratory corridor, which is based on all verified stopover and fatality sites 

recorded for the cranes. These records are estimated to only account for approximately 4 

percent of stopovers. The entire alignment for the proposed transmission lines is within the 60-

mile wide central pathway of the statistical corridor. Please note the only naturally occurring 

population of the Whooping Crane in the wild is currently estimated at less than 250 individuals, 

and collisions with power lines are a known cause of fledged Whooping Crane mortality. 

Whooping Cranes can choose stopover sites opportunistically and due to weather conditions. 

Project site features that can attract Whooping Cranes include wetlands, shoreline, lakes (as 

large distinct landmarks), rivers, rural setting, and distance from previous stopover site. The 
Appendix E 

May 2011 E-89 NUREG-1943 

DEIS page 4-29 noted the DeCordova transmission line would cross several inlets of the SCR, 

Squaw Creek, the Brazos River, and Lake Granbury. The Whitney transmission line would 

cross the Paluxy River, Lake Whitney and tributaries of the Brazos River. Sixty to 80 percent of 

Whooping Crane deaths occur during migration, and electrical utility lines are a leading known 

cause of death in Whooping Cranes. The issue paper previously cited, Whooping Cranes and 

Wind Development, includes a discussion on the impacts from utility lines. 

Two repeated-use Whooping Crane stopover sites, the Salt Plains National Wildlife Refuge 

(NWR), Oklahoma and the Quivira NWR, Kansas, are just over 300 and 400 miles from 

CPNPP, respectively. Whooping Cranes average between 200 and 400 miles between 

stopovers, possibly giving the project and surrounding area a higher probability for birds to 

stopover, if they have utilized these NWRs as their previous stops. Recommendation: The 

DEIS should address potential operational impacts to the federal- and state- endangered 

Whooping Crane. Additional information regarding the Whooping Crane migration corridor and 

potential impacts to this species from transmission lines should be coordinated with the 

USFWS. The existing transmission lines and lattice towers and the project’s proposed addition 

of new lines and towers could pose a threat to migrating cranes that may utilize stopover habitat 

in the vicinity of the project. The biological assessment of Appendix F and the DEIS should 

incorporate and assess potential impacts to the Whooping Crane and should identify all 

reasonable factors that may adversely impact this species. 

Luminant and Oncor should develop, maintain, and operate the transmission line system under 

an Avian Protection Plan (APP). TPWD recommends the plan ensure all transmission lines on 

the CPNPP site and the five new 345-kV lines proposed beyond the CPNPP site provide the 

best available protection for BCV, GCW, and Whooping Crane as well as other avian species. 

TPWD recommends contacting the USFWS to discuss the most appropriate safety measures to 

incorporate on the power lines and poles to protect Whooping Cranes and other large birds from 

collision hazards. TPWD recommends the plan be developed in accordance with the guidance 

provided by the Avian Power Line Interaction Committee, accessible online at 

http://www.aplic.org/ as referenced earlier in this letter, and with guidance from the USFWS. 

(0068-55 [Melinchuk, Ross] [Wicker, Julie])

Response: The EIS has been updated to include consideration of additional information 

obtained from the USFWS regarding the whooping crane migration corridor and potential 

impacts to whooping cranes from transmission lines. Section 5.3.1.1 of the EIS states that for 

transmission lines associated with cooling system operation potential impacts on birds would be 

monitored and bird deterrent procedures and equipment would be used as needed (e.g., noise 

cannons, netting, artificial predators, periodic patrols, and minimizing periods of time in which 

standing water is present) (Luminant 2009f). Luminant further states that bird deterrents or 

other devices that might be used would be selected during the final design stage based on 

discussions with the TPWD and the USFWS (Luminant 2009f). The recommendations 

concerning marking of power lines associated with cooling system operation, as well as the new 

Whitney and DeCordova transmission lines, could be coordinated during these discussions. In 

addition, these recommendations could be presented during the final route selection process 

according to legal and regulatory procedure of ERCOT and PUCT. This procedure includes the 

preparation of a separate Environmental Analysis for the Whitney and DeCordova transmission 

lines. 

Comment: DEIS Section 5.3.1.5, page 5-23, lines 38-43: Luminant has also indicated that 

they plan to confer with USFWS and TPWD regarding possible measures to reduce operational 

impacts from the BDTF. There could potentially be a need for the following mitigation 
Appendix E 

NUREG-1943 E-90 May 2011 

measures: Redesign and/or relocate BDTF to reduce potential for salt drift and fogging. 

Reroute existing transmission lines away from BDTF. 

Luminant has shown in the ER that salt drift will be managed, and concluded (ML100630660) 

that steam fog produced by the evaporation pond would be thin and mister operation will not 

cause fog (TE-21). Luminant is not considering rerouting the existing transmission lines. (0073-

7 [Flores, Rafael])

Response: After reviewing the available evidence, the review team continues to believe that 

uncertainty remains concerning the potential for adverse effects on terrestrial habitats caused 

by salt drift and fogging generated by BDTF operation, including a risk of increased bird strikes 

involving transmission lines crossing the BDTF. Section 5.3.1.5 states that agencies such as 

the USFWS and TPWD might recommend the indicated mitigation measures. Any decision to 

implement the measures would be Luminant’s. The EIS assesses impacts to terrestrial 

resources from BDTF operation assuming that the BDTF would be built in the location indicated 

by Luminant, without relocation of the existing transmission lines crossing that location. The 

EIS was not changed in response to this comment. 

E.2.10 Comments Concerning Ecology - Aquatic 

Comment: Upon review of the study regarding water level impact on Lake Granbury, there was 

no research that includes the Brazos River Basin such as the Trungale Study (see attached). 

The Trungale Study researches the impact of the Comanche Peak Expansion and shows the 

sizable impact, not only on Lake Granbury but on the Brazos River Basin. This study gives a 

complete analysis of the deeper drought periods that would occur with the addition of the 

Expansion and the longer times of recovery. (0051-2 [Jalbert, Ann] [Jalbert, Pete] [McHugh, Judy] 

[Williams, Joe] [Williams, Sue]) 

Comment: This [the deeper drought periods that would occur with the addition of the 

Expansion and the longer times of recovery] would have a tremendous destructive impact on 

marine life and the surrounding environment. (0051-3 [Jalbert, Ann] [Jalbert, Pete] [McHugh, Judy] 

[Williams, Joe] [Williams, Sue]) 

Comment: Along with the Trungale Study, many of the plaintiffs are concerned about the 

impact that the water losses would have on the Brazos River Basin including surrounding 

environment, loss of marine life, and overall long term viability of the Brazos River Basin. (0051-

8 [Jalbert, Ann] [Jalbert, Pete] [McHugh, Judy] [Williams, Joe] [Williams, Sue])

Comment: Hydrologic changes in the Brazos River ecosystem will result from increased 

withdrawals and consumptive water losses and associated alterations in water management 

from Possum Kingdom Lake to the Brazos River below Lake Granbury. Impacts on aquatic and 

wetlands biota and habitat could be substantial as a result of hydrologic alterations to the 

Brazos River system, particularly Lake Granbury, Possum Kingdom Lake, and the river below 

Lake Granbury. The reductions in water levels would likely change shoreline vegetation, affect 

shallow water habitats, and affect access to both public and private boat docks and ramps, 

especially during drought conditions. Reduced Brazos River flows downstream of Lake 

Granbury may impact aquatic resources including the state-threatened Brazos Water Snake 

(Nerodia harteri) and state-threatened and rare mussels. (0068-2 [Melinchuk, Ross] [Wicker, Julie]) 

Response: The EIS recognizes that water fluctuations and losses would occur and may affect 

the aquatic ecology and the surrounding environment. Sections 4.3.2 and 5.3.2 were revised in 

response to these comments. 
Appendix E 

May 2011 E-91 NUREG-1943 

Comment: In addition to the ecologically oriented recreational areas and wildlife protection 

areas listed on page 2-40 and 2-41 of the DEIS, the Paluxy River and the section of the Brazos 

River below the Lake Granbury dam down to its confluence with Camp Creek are both identified 

by TPWD as ecologically significant stream segments (ESSS). Through extensive review by 

TPWD staff, ESSSs throughout the state were identified to assist regional water planning 

groups in designating ecologically unique stream segments under Texas Administrative Code 

Title 31 Section 357.8. Until approved by the legislature, they are not a legal designation. The 

Brazos River ESSS was identified because it was a Texas Natural Rivers System nominee for 

outstandingly remarkable wildlife values and was rated the number one scenic and recreational 

river in the northern half of Texas by the National Parks Service (NPS) in 1995. The Paluxy 

River ESSS was identified as a riparian conservation area containing Dinosaur Valley State 

Park, which is a National Natural Landmark. Additional information about ESSSs can be found 

at http://www.tpwd.state.tx.us/landwater/water/environconcerns/ water_quality/sigsegs/. 

Recommendation: TPWD recommends these two stream segments be included as ecologically 

oriented recreational areas and wildlife protection areas in the DEIS. (0068-20 [Melinchuk, Ross] 

[Wicker, Julie])

Response: This comment identifies the fact that the Paluxy River and the section of the Brazos 

River below Lake Granbury dam down to its confluence with Camp Creek have been identified 

by TPWD as “ecologically significant stream segments.” Section 2.4.1.1 of the EIS was revised 

in response to this comment. 

Comment: The discussion of Lake Granbury aquatic community states that fish populations 

have been adversely affected since 2001 by golden alga (Prymnesium parvum) and that Lake 

Granbury has experienced relatively recent major fish kills, dated 2005, as a result of golden 

alga blooms. These findings were based on a 2009 reference to TPWD’s website for golden 

alga. Please note that in 2009, golden algae did not create a large fish kill as in years prior to 

the fish studies conducted in 2007 and 2008 by Luminant’s consultant, Bio-West. TPWD’s data 

regarding the reduced impacts due to golden algae in recent years do not support the DEIS 

claim that the Lake Granbury fishery is declining due to the algae. TPWD previously 

commented on this during the scoping process. Additional links on TPWD’s website provide 

status reports showing that from 2007-2009 Lake Granbury did not experience further fish kills 

of large magnitude. Additionally, pages 2-54 and 2-66, and portions of Chapter 7, Section 7.3.2 

continue to use older references and suggests that the fisheries in Lake Granbury have been 

severely impacted by golden algae. This conclusion is not warranted or scientifically 

documented. Current information is available online to more appropriately describe the status 

of the Lake Granbury fisheries. Lake Granbury is still a very good fishery, though varies 

depending on the species. Recommendation: TPWD recommends the DEIS be modified to 

correctly characterize the historic and current condition of the fisheries in Lake Granbury using 

the best currently available information. The most recent survey is online at 

http://www.tpwd.state.tx.us/publications/pwdpubs/media/lake_survey/pwd_rp_t3200_1300_2009

.pdf. (0068-26 [Melinchuk, Ross] [Wicker, Julie])

Response: The findings from the recent TPWD “Granbury Reservoir, 2009 Survey Report” 

(Prepared by M.S. Baird and J. Tibbs; July 31, 2010) have been incorporated into Sections 

2.4.2.1, 5.3.2.1, and 7.3.2 of the EIS, which have been revised in response to this comment.

Comment: The status for the state-listed threatened Brazos Water Snake (Nerodia harteri) on 

page 2-74 and in Chapters 4 and 5 notes the species as having not been observed in 20 years. 

Recent thesis work has found populations of this snake above and below Lake Granbury in the 

Brazos River. These surveys were conducted in 2006 and 2008. This species was not found in 

Lake Granbury; the researcher noted that high lake levels and undesirable sampling period 
Appendix E 

NUREG-1943 E-92 May 2011 

(July) combined to reduce the likelihood of finding this snake. Habitat for this species was found 

just below the Decordova dam and at the confluence of the Paluxy River and Brazos River 

(McBride 2009). Recommendation: TPWD recommends the DEIS include more current 

information on this species, its prey and habitat. A copy of the thesis is attached for your 

reference. (0068-27 [Melinchuk, Ross] [Wicker, Julie]) 

Comment: Regarding impacts on recreational fishery species within PKL, Lake Granbury, and 

Brazos River below Lake Granbury as a result of changes in water levels and flow regime, the 

DEIS indicates that impacts may range from negligible to noticeable. The impacts are 

dependent on the species and degree to which their habitat is affected, as well as the 

uncertainties of project impacts to characteristics associated with reproductive success. 

Regarding aquatic threatened and endangered species, the DEIS indicates no potential effects 

to the state-threatened Brazos Water Snake based on 1) no TXNDD reported observations of 

the snake in the vicinity of the project in more than 20 years, 2) the operation of submerged 

intake and discharge structures in Lake Granbury would not substantially alter the shallow, 

shoreline habitat potentially utilized by the snake nor reduce populations of small forage fish on 

which the snake would feed, and 3) there would be limited effects of water level changes on 

shoreline habitat along PKL and the Brazos River between PKL and Lake. However, as 

previously discussed in this letter, recent thesis work found populations of this snake above and 

below Lake Granbury in the Brazos River. Recommendation: Transmission lines across 

waterbodies can serve as perch sites for raptors that prey on aquatic species, including on the 

Brazos Water Snake. Long-term changes to the water levels proposed for the project could 

further modify the habitat of this species by moving the water level away from the current 

shoreline and leaving riffle areas dry. The sensitivity of this species and its prey base to 

changes in water quality, levels and temperatures are unknown. While juvenile snakes seem to 

adhere to the near shore areas, adults utilize deeper waters; therefore, the analysis should 

indicate whether this species could become impinged on the intake screens. The analysis 

provided in the DEIS should identify all reasonable factors that could come into play to 

adversely impact this species. (0068-56 [Melinchuk, Ross] [Wicker, Julie])

Response: Sections 2.4.2, 4.3.2, and 5.3.2 of the EIS have been revised in response to these 

comments.

Comment: Page 2-54 indicates surveys of the lake bottom above the Lake Granbury dam 

identified a limited community of benthic macroinvertebrates. No mussels appear to have been 

found; however all sampling appears to have been conducted around the cooling water intake 

and discharge points. The methodology used to identify sample locations on the lake bottom 

was not described. Recommendation: The DEIS should clarify why sampling was restricted to 

the areas around the intake and discharge points. Since effects in an aquatic environment can 

spread to both upstream and downstream reaches of a waterbody, the methodology used to 

select the sampling locations should be described. To properly characterize the benthic fauna, 

sampling should include areas representative of the variations in habitat used by benthic 

macroinvertebrates. (0068-28 [Melinchuk, Ross] [Wicker, Julie])

Response: The 2008 Bio-West surveys captured “five sampling sites based on information 

provided by Enercon Services professionals. The sites are all within 2.6 kilometers of the dam 

and located on the southern shore because any potential future intake or discharge structures 

will likely be located in this area; four of the sites are located in Lake Granbury and one site is 

located in the Brazos River downstream of DeCordova Bend Dam.” The lake sites 

encompassed different types of habitat settings and included a pelagic location located 110 to 

120 m from shore. A diversity of substrates was included by using these locations. The Brazos 

River site was approximately 75 m of stream length that was chosen “to adequately characterize 
Appendix E 

May 2011 E-93 NUREG-1943 

the assortment of aquatic habitats in the area.” The sampling program was designed to capture 

the spectrum of habitat types within Lake Granbury. Section 2.4.2.1 of the EIS has been 

revised in response to this comment.

Comment: On November 5, 2009, the Texas Parks and Wildlife Commission acted to place 15 

native freshwater mussel species on the state threatened species list; therefore, previous 

TPWD correspondence regarding the proposed project did not fully address the newly-listed 

species. The DEIS correctly identifies the threatened listing status of the Texas Fawnsfoot 

(Truncilla macrodon), False Spike (Quadrula mitchelli), and Smooth Pimpleback (Q. 

houstonensis). However, the 2007 and 2008 Bio-West fish surveys, which occurred at the 

project footprint location within Lake Granbury and at limited survey locations downstream of 

Decordova Dam within the Brazos River do not appear to have utilized appropriate survey 

methodology to assess mussels in the Brazos River from Possum Kingdom Lake (PKL) to 

downstream reaches below Lake Granbury. These areas of the river would experience 

changes in flow rate due the project as discussed later in the DEIS. 

The DEIS indicates that the Brazos River from Lake Granbury downstream to Lake Whitney 

could contain habitat supportive of rare and threatened mussels, though none were found 

during the Bio-West studies and none are known to occur in this river segment. Please note 

that the Brazos River from the dam at PKL in Palo Pinto County downstream to FM 2580 in 

Parker County, is designated by Texas Administrative Code (TAC Title 31, §57.157) as a 

mussel sanctuary. Surveys determined that some of the last remaining Texas Fawnsfoot 

mussels occur in this area. Texas Fawnsfoot only occurs in Central Texas and only about a 

dozen specimens have been found alive in recent decades (Howells 2004). Additionally, TPWD 

survey records of Brazos River in the vicinity of the project, which are not currently included in 

the TXNDD, indicate Texas Fawnsfoot in the area. Live Texas Fawnsfoot were found in Palo 

Pinto and Parker counties, and dead Texas Fawnsfoot ranging from recently dead to very long 

dead were found in Somervell, McLennan, and Stephens counties (Howells 1994 and 1996). 

Texas Mussel Watch Program found dead shells or valves in the following counties and years: 

Hood 2005, 2006, 2007; Somervell 2007; and Palo Pinto 2000. Recommendation: TPWD 

recommends the DEIS include a description of the mussels sampling methodology and its 

appropriateness for obtaining baseline data. The DEIS should include a summary of existing 

TPWD survey data for mussels from PKL to downstream of Lake Granbury. Because the data 

may be outdated, TPWD recommends Luminant conduct additional pre-operation mussels 

sampling from PKL to downstream reaches below Lake Granbury. Using survey methodology 

appropriate for mussels, sampling should assess the habitats that have suitable conditions to 

support mussels. For additional data regarding mussel survey records for the Brazos River in 

the project vicinity, please coordinate with Michael Warriner, TPWD Invertebrate Biologist, at 

(512) 389-8759. (0068-29 [Melinchuk, Ross] [Wicker, Julie]) 

Comment: The DEIS indicates that although habitat of all five of the rare mussels discussed in 

the document may occur within the Brazos River between Lake Granbury and Lake Whitney, 

none are known to occur there and none were found during the recent Bio-West studies 

conducted for this project. The DEIS indicates minimal impacts would occur to rare mussels. 

As previously discussed in this letter, there is potential for occurrence of state-threatened and 

rare mussels within the Brazos River below Lake Granbury to Lake Whitney, and lack of 

occurrences in TXNDD cannot be used as absence data from that region. Additionally, the BioWest studies conducted for the project did not appear to target mussels and were limited in 

scope, though detailed survey methodology was not presented in the DEIS. (0068-57 [Melinchuk, 

Ross] [Wicker, Julie]) 
Appendix E 

NUREG-1943 E-94 May 2011 

Response: The 2008 Bio-West surveys relied upon the use of D-frame nets along the bank 

edges and within the channel to collect organisms for identification. All samples were 

immediately stored in 95% ethanol solution and identification of invertebrates was performed in 

the laboratory. The D-frame net is a common benthic sampling tool that can capture most types 

of benthic aquatic species. NRC staff coordinated with Michael Warriner, and additional data 

collected during surveys in 1996, 2006, and 2007 for mussels have been obtained from TPWD. 

These datawere used to revise Section 2.4.2.1 of this EIS. Luminant does not plan to conduct 

formal development-related monitoring of aquatic ecosystems due to the small potential for 

adverse impacts. However if a protected species is observed, Luminant would contact 

appropriate agency officials to determine proper mitigation measures. Sections 2.4.2, 4.3.2, 

and 5.3.2 of the EIS were revised in response to these comments.

Comment: Page 2-75 indicates that specific operational monitoring programs have not yet 

been established for CPNPP Units 3 and 4, though they are expected to be similar to or 

modifications of existing monitoring programs for Units 1 and 2. Monitoring of fish and other 

components of ecological communities of Lake Granbury, SCR, PKL, and Brazos River may 

also be required by state regulatory agencies. Recommendation: TPWD recommends 

Luminant conduct long-term operational monitoring for mussels and Brazos Water Snake within 

the Brazos River system in the project vicinity. (0068-30 [Melinchuk, Ross] [Wicker, Julie])

Response: Luminant does not plan to conduct formal monitoring of aquatic 

ecosystems.However, if a protected species is observed, Luminant would contact appropriate 

agency officials to determine proper mitigation measures. NRC lacks the authority to require 

such monitoring. No changes were made to the EIS in response to this comment.

Comment: The DEIS indicates that the entire proposed DeCordova transmission line, 27 miles 

of the Whitney transmission line, and the proposed intake and discharge pipelines would 

parallel existing ROW. Infrastructure currently present to allow vehicles to cross streams in the 

existing transmission line and pipeline ROW could be used during the construction and longterm maintenance of the new transmission lines and pipeline. To further minimize stream and 

riparian habitat impacts, the pipelines would bore under all streams. However, the initial 18-mile 

segment of the Whitney transmission line would be located on new-location ROW; thus 

installation of permanent culvert crossings at streams for construction and long-term 

maintenance access roads are proposed. Recommendation: TPWD supports the plan to bore 

pipelines under stream crossings and their associated riparian corridors. TPWD recommends 

placing the bore entry/exit locations and equipment staging areas outside riparian habitat in 

previously disturbed sites. To minimize unnecessary disturbance to stream and riparian habitat 

along the new location portions of the Whitney transmission line, all efforts should be made to 

locate construction and maintenance access roads so that placement of temporary and/or 

permanent culverts in streams can be avoided. Culverts can also disrupt stream morphology as 

well as migration of aquatic wildlife in the stream; thus existing roads and bridge crossings 

should be used. (0068-46 [Melinchuk, Ross] [Wicker, Julie])

Response: NRC lacks the authority to require such recommendations. However, USACE 

would require compensatory mitigation for project-related impacts to waters of the United States 

through the development of a mitigation plan. No changes were made to the EIS as a result of 

this comment.

Comment: Page 4-33 discusses construction and preconstruction impacts to the state-listed 

threatened Brazos Water Snake. The potential for encounters with most rare species is low due 

to the rarity of the species. The Brazos Water Snake has a very restricted range but does occur 

in portions of the project area. Although there are specific habitat features along lake and river 

shoreline that attract the Brazos Water Snake, it may travel along the Brazos River and Lake 
Appendix E 

May 2011 E-95 NUREG-1943 

Granbury outside of its preferred habitat. Potential construction impacts to this snake or its 

habitat may occur at the project footprint along Lake Granbury shoreline. The cooling water 

intake/discharge structures could impede access for this species to its shoreline habitat along 

Lake Granbury. Recommendation: TPWD recommends Luminant restore all shoreline areas 

temporarily disturbed by project activities with habitat features appropriate for this species. If 

structures would be permanently placed at the shoreline, the structure-water interface should 

contain rocky habitat appropriate for this species. TPWD private lands biologist Dean 

Marquardt should be contacted for assistance in design details that would benefit this species. 

(0068-47 [Melinchuk, Ross] [Wicker, Julie])

Response: Section 4.3.2.4 states that in the event that a protected species were to be found 

present in areas affected by development, work in the area would be halted and the 

appropriated Federal and State agency officials and environmental consultants would be 

contacted. NRC lacks authority to require such recommendations. However, USACE would 

require in-kind compensatory mitigation for impacts to waters of the United States through the 

development of a mitigation plan. No changes were made to the EIS in response to this 

comment. 

Comment: The NRC review team summary of operational impacts on aquatic and wetland 

resources (Section 5.3.2.11) states substantial uncertainty associated with the magnitude of 

ecological effects that may result from hydrological changes in the Brazos River as well as Lake 

Granbury and PKL. The DEIS finds operational impacts on aquatic resources may range from 

SMALL to MODERATE and additional mitigation may be warranted to help reduce adverse 

effects of flow alterations on the Brazos River and suggest such mitigation measures could 

include managing water releases from PKL and Lake Granbury to maintain higher base flows 

and to periodically provide episodic high flows that would better simulate the natural instream 

flows regime of the river. TPWD is concerned that the anticipated changes in water levels at 

PKL and Lake Granbury will cause reductions in the fish and benthic invertebrate habitat and 

both aquatic and terrestrial cover along the edges of the lakes, which can have cascading 

adverse effects on reproduction and reduce recreational fishing areas. TPWD is also 

concerned that reduced flows anticipated for the Brazos River downstream of Lake Granbury to 

Lake Whitney will affect native organisms that rely on variable flow and certain water levels, 

including the Brazos Water Snake and rare mussels. Recommendation: Because of the 

uncertainty of impacts to biota and habitat of PKL, Lake Granbury, and Brazos River both below 

and above Lake Granbury as a result of water level changes and flow regime changes, TPWD 

recommends the NRC and USACE conservatively assume the effects are noticeable and 

substantial until Luminant is able to prove otherwise. Given the findings addressed in Section 

5.3.2 Ecological Impacts: Aquatic and Wetland Impacts, TPWD recommends operational 

monitoring of aquatic resources (biota and habitat) of PKL, Lake Granbury and Brazos River 

from PKL downstream to Lake Whitney. Operation procedures should be developed to detect 

levels of aquatic biota and habitat impact and to implement mitigation strategies as impacts 

above negligible levels are detected. An adaptive management strategy should be incorporated 

to mitigate the impacts revealed through monitoring. Additional pressures on biota and habitat 

as a result of the project should be reduced through mitigation to restore, enhance or create 

habitat to help offset anticipated impacts. As discussed in this section and in NRC’s 

conclusions and recommendations Table 10-2, TPWD supports the NRC review team 

suggestion of manipulating base flows and episodic releases to simulate the natural instream 

flow regime of the river to aid in mitigating impacts. (0068-59 [Melinchuk, Ross] [Wicker, Julie]) 

Comment: Withdrawals of water from the Brazos River system for Units 3 and 4 would be a 

major component of the increased withdrawals planned for under BRA water management 

policy. However, these increases are likely to occur even without Units 3 and 4 because the 
Appendix E 

NUREG-1943 E-96 May 2011 

2060 Brazos G Water Plan calls for full utilization of the yield from the Brazos River system 

between now and 2060. The DEIS indicates that future development of industries that compete 

for water along the Brazos River, as well as management of water budgets across the state, 

would likely affect aquatic resources in the Brazos River. The DEIS indicates noticeable SMALL 

to MODERATE cumulative effects on aquatic biota from the hydrological changes in the Brazos 

River, PKL, and Lake Granbury associated with increased water consumption by the proposed 

Units 3 and 4 in combination with other future users of BRA water allocations. 

Recommendation: TPWD recommends a mitigation measure to minimize cumulative effects on 

aquatic resources through aquatic life water allocations within the Brazos River. Any future 

innovations in cooling operating processes that reduce water consumption should be 

considered and employed, where feasible, at the CPNPP site. (0068-64 [Melinchuk, Ross] [Wicker, 

Julie]) 

Response: The review team’s conclusions of SMALL to MODERATE in Sections 5.3.2 and 

7.3.2 are based in part on the uncertainty of the water management and flow regimes. 

Depending on how the water is distributed by natural events and by the Brazos River Authority 

within the Brazos River system, the impacts of the proposed project could be SMALL, or the 

impacts of the proposed project could be MODERATE. NRC lacks the authority to require the 

recommended mitigation measures, but the USACE would require monitoring to establish 

compliance with the performance standards of elements included in the compensatory 

mitigation plan. Appendix H of the EIS list other permits and licenses that Luminant would need 

to obtain prior to building and operating the proposed units. No changes were made to the EIS 

as a result of these comments.

Comment: Page D-40, response to comment 0029-5, regarding TPWD’s and the applicant’s 

aquatic biota studies indicates that TPWD fisheries data would be considered, but did not 

indicate it would send the requested Bio-West studies to TPWD. Additionally, the NRC website 

shows an environmental Request for Additional Information (RAI) dated August 3, 2009, for 

which no response was received from Luminant (http://www.nrc.gov/reactors/newreactors/col/comanche-peak/rai.html). The RAI requested copies of reference materials be 

placed on the NRC docket and reading room for citation and reference in the EIS. The BioWest 2008a and 2008b studies were included in this request. TPWD was not able to locate 

these documents in the NRC reading room. Recommendation: TPWD has not received the 

studies, but is still interested in reviewing the documents. Please send Bio-West 2008a and 

2008b reference materials to the attention of Gloria Garza, TPWD Wildlife Habitat Assessment 

Program, at TPWD headquarters or Gloria.Garza@tpwd.state.tx.us for proper receipt/internal 

tracking and distribution to appropriate review personnel. (0068-65 [Melinchuk, Ross] [Wicker, 

Julie])

Response: The requested reference documents have been placed on the NRC docket; 

additionally, They are available on the NRC’s web-based Agencywide Documents Access and 

Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams/web-based.html under 

ADAMS Accession Nos. ML092180087 and ML092180088. 

E.2.11 Comments Concerning Socioeconomics 

Comment: [The water usage requirements for cooling Comanche Peak 3 and 4 will place the 

entire environment surrounding the lake at risk] as will be the property values for property 

owners! The just past summer of 2009 saw drought conditions and lake levels so low that many 

of us with property on the numerous canals off of Lake Granbury were unable to launch their 

boats after Memorial Day until Labor Day! (0003-4 [Apple, Thomas])
Appendix E 

May 2011 E-97 NUREG-1943 

Comment: I live on a canal and I will be very unhappy if I cannot launch my boat during the 

summer. I will be even more distressed if I am looking at a muddy ditch instead of a canal. In 

that event I will be expecting a massive reduction in my real estate taxes. If my neighbors and I 

are successful in getting tax relief, it will mean that taxes for those not living on the lake will go 

up. (0023-2 [Hinterleiter, David]) 

Comment: Lake Granbury has homes that are located close to the water and boat docks that 

are at a fixed height, not floating. If the lake level is lowered, our docks will not be useable, 

therefore lowering our property values. (0024-2 [Quirk, Jim and Sharon])

Comment: My boathouse would definitely be quite dry and that result defeats the whole 

purpose of building the facility, not to mention the cost of the project ($36000). (0033-3 [Hanna, 

Jim]) 

Comment: I told my Hood Co. Commissioners and anyone else who would listen at that time, 

"If I have dry ground where my canal was, then re-evaluate my property and I'll pay only 1/3rd of 

the property taxes I now pay because instead of my house/prop. being evalued at $200K, it will 

be like the guy across the street (not waterfront) at $80K. I'm adamant about this lake being at 

a constant level. (0037-6 [Moore, Jim]) 

Comment: Granbury stands to lose a lot of revenue if this goes through because the lake lots 

won’t be near as valuable and all of the lake owners will have to pay a lot of money to dock 

companies to allow the docks to float. I know I for one will be asking for a very significant 

decrease in the property valuations that just doubled a year ago. The lake front won’t be as 

desirable anymore. (0045-3 [Jacobson, Jake]) 

Comment: It all comes down to risk. Luminant feels that the risk is low enough to go ahead 

with the project. The home owners feel the risk is high enough to cause a decrease in property 

value due to the non-usability of the lake for recreation. Since Luminant calculated a low risk, 

then let them buy our property after the two units are built. We didn't buy into Lake Granbury 

because of the reactors, but because the lake level stays relatively constant. With two new 

units that changes, and property value goes down. (0048-2 [Bernier, Jim]) 

Comment: Thirdly is the impact on property values in our development and others on the lake 

or, for that matter, in the whole county should the economic status be deeply affected. The BRA 

has done a poor job in dispelling the myth that Lake Granbury is a “constant level lake.” 

Realtors for years have mentioned that or at least have not clearly explained the reality. (0058-3

[Huett, David]) 

Comment: People have invested great amounts of money for water front property as first or 

second homes, paying up to, and perhaps more than, $300,000 per acre for property that 

provides access to the lake for visual and recreational use. This plan will have an enormous 

impact on those investments. Please find a way to avoid destroying the economic investment 

that many thousands have made over the years. The lake has made Hood County what it is 

today and is vital to its future. (0058-5 [Huett, David]) 

Comment: Now, this is the other point: When we were sold the house here -- we lived in 

southern California; we're retiring -- we'd boated on Lake Michigan when we lived in Chicago; 

we'd boated on Lake of the Ozarks when we lived in St. Louis; we'd boated on the Pacific in the 

California, and I could go on and on and on -- we selected Lake Granbury because we thought it 

was a beautiful little place to retire, and we would be able to afford a place on the lake. This 

afternoon a couple of the Somervell County executives took a real shot at the Lake Granbury 

owners and asked them, saying, Suck it up; so what if your lake gets drained. You didn't have 

the water there before you dammed up the river anyway, before Luminant -- or back in those 
Appendix E 

NUREG-1943 E-98 May 2011 

days it wasn't Luminant. And I took umbrage with those guys, and I've been stewing on it all 

day long, to be honest with you, that we didn't live here when they offered that lake to -- when 

they offered this nuclear plant to Hood County. We didn't turn it down. And I'll bet you that 

that's true of 75 percent of the people on that lake. The ones who were initially on the lake have 

mostly died, quite honestly. And the ones who retired here came here because we could buy 

lakefront property; we could afford it. We worked 45 years to build up a small nest egg, and we 

spent about half that nest egg on our property on this lake. And these guys speaking today 

said, Suck it up. If you lose your water, so what. And I don't think that's right, but I do think this: 

that we have hundreds and hundreds of houses, thousands and thousands, actually, that were 

sold on Lake Granbury by the realtors on the basis that this is a fixed level lake and your level 

will always -- will be within a foot or two of what it is supposed to be at a constant level. (0062-

16-4 [Williamson, Frank]) 

Comment: That these houses were all sold by realtors. The BRA says, We don't guarantee a 

lake level. But all these homes were sold by realtors who said, This is a fixed level lake, come 

here and retire and you've already got your boat dock out there and you won't have to worry. 

Every three boat docks going up and down the river represents about a hundred -- I mean, 

going up to the lake represents about $100,000 of investment. There have been millions and 

millions of new homes built here the last two years on the false premise that this lake would be 

maintained at a certain level. And if it's not maintained at that level the economy of this area -- 

being Granbury -- is going to be devastating and there will be residual effects long over these 

other areas, as well. (0063-25-4 [Williamson, Frank]) 

Response: These comments address concerns of residents in proximity to Lake Granbury and 

Possum Kingdom Lake with respect to property values affected by lower lake levels. The review 

team has revised Section 5.4.4.3 (Housing) to include a discussion of the potential impacts of 

operating CPNPP Units 3 and 4 on property values proximate to the lakes in question. 

Comment: The City of Granbury and it's surrounding communities rely heavily on Lake 

Granbury for the economic stability of the city. Without the continued recreational use of the 

lake, our city's economy and tourist dollars will wither away. (0004-1 [Drager, Judy]) 

Comment: This would have a horrible effect on the economy in Granbury, tax revenues in 

Hood County, real estate sales and values in Granbury, future water needs for the community 

and a general sluggish population growth within the community (0005-2 [Clark, Becky] [Frick, Terry] 

[Kelly-Elliott, Cathy] [Leach, Dan] [Rhodes, Bill] [Wayson, Jacqueline and Thomas] [Wayson, Thomas]) 

Comment: I live on Lake Granbury. I have lived here two 1/2 years and I have seen the lake go 

up and down like a yo-yo. A water front property costs approximately $100,000. over the nonwater front neighbors. When the lake is way down, it is a liability, not an asset to the value of the 

property. If the Comanche Peak Nuclear expansion takes place, estimates say the lake will lose 

a minimum of 2 or more feet. That is when things are good. During a dry spell, that could mean 

6 or more feet additional loss of water. This town of Granbury has grown because of the lake. If 

the lake is unusable (all boat ramps were closed once last year) the town will take a major hit 

financially and to the reputation of the area. We would love to have the additional jobs and 

money influx from the plant expansion, but not at the cost of our lake. (0007-1 [Reeder, Dan])

Comment: To take additional water from Lake Granbury will probably have such an impact on 

the City of Granbury, that it will probably lose the aura of what makes Granbury the city it is 

today. With the loss at the proportions proposed, Granbury would lose me & many other out-oftowners that have lake property for recreational use only. With the amount of money we spend 

annually and multiply that figure by the thousand, there would be a trickle down impact as if a 

tornado went through town. (0008-1 [Tresnicky, Larry and Phyllis]) 
Appendix E 

May 2011 E-99 NUREG-1943 

Comment: As a Lakefront homeowner on Lake Granbury, I am pleading with you, along with 

many of my neighbors, regarding the BRA's request for additional water rights, and to do 

anything in your power to conserve our ability to use Lake Granbury for recreation. Two years 

ago, the Lake was down approx. 5 ft and it was devastating & impossible for many homeowners 

to use their boat docks. It certainly had to have a negative impact on all facets of the City of 

Granbury. Sales tax revenue, restaurants, boat dealers, shops on the Square all had to 

experience a negative impact. If we lose water at the proposed proportions, Granbury will be no 

more than a highway going north & south. (0008-2 [Tresnicky, Larry and Phyllis])

Comment: the economic impact of lower water levels on the city of Granbury and Hood County 

such as loss of tourism needs to be fully taken into consideration. (0051-11 [Jalbert, Ann] [Jalbert, 

Pete] [McHugh, Judy] [Williams, Joe] [Williams, Sue]) 

Comment: I represent the approximately 174 property owners of Mallard Pointe on Lake 

Granbury. The entire development was established on the recreational use of Lake Granbury 

and each property is either directly on the water or has deeded rights to a slip in the association 

owned marina. We have major concerns including, first, the economic impact to the Hood 

County community as it is largely dependent on Lake Granbury as a tourist destination. Many 

businesses will not survive if the lake is not useful by residents, weekend property owners and 

tourists. (0058-1 [Huett, David]) 

Comment: Last point I'd like to make is the town is Granbury is very much a tourist town. The 

city fathers I think have done a pretty good job of attracting tourists by various attractions. The 

biggest attraction is the lake. You go out there any time you want, look how many people are 

launching boats, from the Fort Worth-Dallas area; it's well thought of. If I can remind you of our 

drought that we had I believe it was about two years ago, you couldn't get a boat down to the 

lake, and that was before we took water to supply plants 3 and 4. 

The point I'm trying to make, I think you're going to have a very serious impact on the 

businesses and the economics of Granbury whenever the lake level is low. I think to prove that 

fact -- I haven't done my homework, so I can't say this is factual, but I think at the very least you 

guys should go talk to the various business owners in town. Ask them how were they affected 

by that drought and then add whatever the proper number is for the lake level going down and 

see how they're going to be affected. I think you will find they were affected a great deal. (0062-

14-5 [Williams, Robert]) 

Response: These comments address concerns related to the impacts of lower water levels in 

Lake Granbury and Possum Kingdom Lake on the recreation component of the local economy. 

Consequently, the review team has expanded Section 5.4.3.1 (Economy) to include a 

discussion of the potential impacts of operating CPNPP Units 3 and 4 on the recreation-related 

aspect of the local economy. 

Comment: Drawing more water from Lake Granbury will not only negatively effect the property 

values of all current waterfront property owners, but also any future industrial and residential 

expansion in the Granbury area. (0017-3 [Fitzgerald, C.C. (Fitz)])

Comment: Not only will existing water front owner's property values be negatively affected, 

Lake Grandbury will no longer be the lake of choice for individuals who desire to live on a lake. 

This community is built around the lake and low water levels not only affects water recreation 

but there could be dire economic consequences for the real estate market. (0018-2 [Thompson, 

Sue])
Appendix E 

NUREG-1943 E-100 May 2011 

Comment: I am very concerned about the Comanche Peak Expansion and the significant 

impact it will have on the environment, which will have a further negative impact on property 

values and the local economy. (0021-1 [Kelly-Elliott, Cathy])

Comment: So far they've paid lip-service to the concerns of both citizens and retailers (hey, 

without water, Granbury will dry up as a tourist destination), so it's time for the NRC to listen and 

for authorities to wake-up. (0022-2 [Frick, Terry]) 

Comment: Again, we are very concerned about the value of our home and the income of 

businesses being dropped to the point of having to close. Look around there are many towns 

near that have music, plays, antique stores, shopping. Granbury is unique we have all of that 

and it is right downtown with a lake. If we don't have the boating, fishing, and swimming 

attraction we will be like any other historical town around here. What will make the tourist come 

here and not that other historical town? (0025-3 [Slough, Gene and Phyllis]) 

Comment: The local Lake Granbury communities need the lake levels as they are in order to 

survive. Local economies will be hard hit if water levels were to decrease. (0030-1 [Martin, Joe]) 

Comment: Additional water draw will negatively effect current lakefront property owners in that 

the water will be too low to have a boat dock and/or launch our boats from existant docks. 

Additionally, decreased lake levels will negatively effect future growth of the Granbury area 

where the lake is a major attraction. (0034-3 [Fitzgerald, C.C. (Fitz)]) 

Comment: I believe they intentionally kept the level up this summer to quiet the complaints of 

low levels until the selling of water for the reactors suck the life from our property values and 

tourism. Our lake brings tourist dollars to Granbury and we need those dollars. (0038-4

[Lowrance, Cleo])

Comment: If the recreational boaters and tourists quit coming to Granbury all these new 

hotels, restaurants and other businesses will be empty and the tax dollars will dry up as quickly 

as our waterfront property values. (0038-7 [Lowrance, Cleo])

Comment: The value of the lake as an essential element to the economy and prosperity of 

Hood County cannot be overstated. Many people have made substantial personal investmentslife savings in many cases-building homes and businesses that depend on the health and 

robustness of the lake. (0057-2 [Keffer, James L.]) 

Comment: Lowering the water level of Lake Granbury would not only have a negative effect on 

current property values but also on future industrial and residential growth in the Granbury area. 

(0062-7-3 [Williamson, Eileen]) 

Comment: The value of the lake as an essential element to the economy and prosperity of 

Hood County cannot be overstated. Many people have made substantial personal investments, 

life savings in many cases, building homes and businesses that depend on the health and 

robustness of the lake. (0063-4-2 [Regas, Tori]) 

Response: These comments address concerns related to the impacts of lower water levels in 

Lake Granbury and Possum Kingdom Lake on lakefront property values and the recreation 

component of the local economy. Consequently, the review team has revised Section 5.4.4.3 

(Housing) to include a discussion of the potential impacts of operating CPNPP Units 3 and 4 on 

property values proximate to the lakes in question. Additionally, Section 5.4.3.1 (Economy) has 

been expanded to include a discussion of the potential impacts of operating CPNPP Units 3 and 

4 on the recreation-related aspect of the local economy.
Appendix E 

May 2011 E-101 NUREG-1943 

Comment: I bought my property on what I thought was a 'constant level' lake. How did I figure 

that? Well, Possum Kingdom, Grapevine, and Whitney are variable level lakes, meaning you 

cannot own property up to the water's edge. You can own up to the water's edge on Lake 

Granbury and several other lakes in Texas like Cedar Creek Lake. (0037-4 [Moore, Jim]) 

Comment: I have owned and originally built my house on the lake in 1988. When I bought I 

was told that it was a constant water lake. I know this to be true because none of the docks on 

the lake float!!! If it wasn’t why would the BRA approve all of the docks as stationary! They now 

claim that this is not the case but they are lying. (0045-2 [Jacobson, Jake])

Response: These comments address concerns related to the impacts of lower water levels in 

Lake Granbury and Possum Kingdom Lake without specific reference to aesthetics, recreation, 

property values, or the local economy. While the review team considered these comments to 

be important, no changes were made to the EIS based on them. The review team has revised 

Sections 5.4.1.4 (Aesthetics), 5.4.4.2 (Recreation), 5.4.4.3 (Housing), and 5.4.3.1 (Economy) 

because of specific comments related to these socioeconomic categories. 

Comment: For several summers our lake has been dangerous for recreation due to low water 

levels. (0038-2 [Lowrance, Cleo])

Comment: Secondly, there is a significant safety concern should the regular level of the lake 

be 1 to 1.5 feet below the historical regular level, not to mention the highly increased hazards in 

low rain or drought conditions. The lake, as you all know, has many trees and stumps only a 

short distance below the regular lake level that are hazards to boaters and skiers when the lake 

level is reduced. (0058-2 [Huett, David])

Response: These comments address concerns related to recreation on Lake Granbury and 

Possum Kingdom Lake. The review team assessed the potential for reduced recreational 

opportunities as a result of operating the proposed new reactors in Section 5.4.4.2 (Recreation). 

The review team acknowledged that the operation of CPNPP Units 3 and 4 would have a 

noticeable impact on the current level of recreational activity in the two lakes, but that the impact 

would not destabilize the recreation industry. Boaters and skiers should expect that lake levels 

will fluctuate with or without the proposed new units, and should take appropriate precautions. 

This comment provided no new information that would change the review team’s determination; 

hence, no changes were made to the EIS as a result of these comments.

Comment: We all have boat docks. That was a part of the plan; we wanted to have our boat in 

our backyard where we could go out boating, fishing, whatever, when we retired. These boat 

docks are not floating boat docks like they are in the West. On the Pacific Ocean, because the 

tide fluctuates, you have to have floating boat docks. I told you I was in the marine business; I 

know about this. On the lakes in California you have to have floating boat docks because 

there's a tremendous fluctuation in the lake from Eastman to Lake Pharr [phonetic]. And this is 

true throughout the west. Here every dock was built based on the fact that that's going to be the 

lake level, and you don't have to ever float that dock out further than where it is. (0062-16-5

[Williamson, Frank]) 

Comment: Everybody has a seawall that they've built that the county thinks that we who live on 

this lake are so good that they've increased my little lot size in appraisal from $70,000 to 

$170,000 in the eight years that we owned it. When I go down to protest it, what do I get? Well, 

you live on the main lake. That makes your lot worth a whole lot more money. The other night I 

went to a commissioners -- county commissioners meeting, and they said in that -- Judge Rash 

himself said in that meeting the average property in Hood County is taxed at $125,000. Well, 
Appendix E 

NUREG-1943 E-102 May 2011 

my lot's gone from $70,000 to $170,000 in eight years, so I don't think it'll ever go back down if 

you take this lake away from us. (0062-16-6 [Williamson, Frank]) 

Response: These comments address concerns related to the economic and recreational 

consequences of reduced access of lakefront property owners if water levels on Lake Granbury 

or Possum Kingdom Lake decrease due to the operation of CPNPP Units 3 and 4. The review 

team has revised Section 5.4.4.2 (Recreation) to address lower water level impacts.

Comment: We need to work with the Nuclear Regulatory Commission, TCEQ, Luminant to be 

a good neighbor. Judge Maynard's right. They've been a great neighbor. We've been a great 

neighbor to Somervell County. We just not reap the same benefits. So at the same time I 

would like to ask Luminant, BRA, TCEQ to be a great neighbor to Hood County and help assure 

us quality of life. If our lake levels continue to go down and stay down it will affect our ad 

valorem. Your property values will drop. When that does it will affect me. That's the only way 

my job comes into play. (0063-10-3 [Berry, Steve]) 

Comment: The Chamber also recognizes that many of our members are directly or indirectly 

impacted by low lake levels. Business revenues, property values and Granbury as a destination 

point suffer during periods of low water. Thus, the Chamber has been very involved in the Lake 

Granbury Task Force over the past year to address lake issues. (0063-14-2 [Garner, Todd]) 

Response: These comments address concerns related to the economic and fiscal 

consequences of reduced water levels on Lake Granbury and Possum Kingdom Lake due to the 

operation of CPNPP Units 3 and 4. While these comments provided no new information, the 

general concern for economic impacts due to reduced water levels is addressed in Section 

5.4.4.2 (Recreation). 

Comment: Hydrologic changes in the Brazos River ecosystem will result from increased 

withdrawals and consumptive water losses and associated alterations in water management 

from Possum Kingdom Lake to the Brazos River below Lake Granbury. Impacts on aquatic and 

wetlands biota and habitat could be substantial as a result of hydrologic alterations to the 

Brazos River system, particularly Lake Granbury, Possum Kingdom Lake, and the river below 

Lake Granbury. The reductions in water levels would likely change shoreline vegetation, affect 

shallow water habitats, and affect access to both public and private boat docks and ramps, 

especially during drought conditions. (0068-4 [Melinchuk, Ross] [Wicker, Julie]) 

Response: This comment addresses a broad spectrum of concerns related to the potential 

reduction of water levels in Lake Granbury and Possum Kingdom Lake. These concerns were 

addressed by the review team in Sections 5.3.1 (Terrestrial Impacts Related to Operations), 

5.3.2 (Aquatic and Wetland Impacts), and 5.4.4.2 (Recreation). While this comment provides no 

new information, the general concern for economic impacts due to reduced water levels is 

addressed in Section 5.4.4.2 (Recreation). 

Comment: When quantifying surface water quantity impact and socioeconomic effects, EPA 

suggests considering tourism and recreation in determination of the DEIS significance levels. 

(0070-16 [Smith, Rhonda])

Response: This comment recommends a methodology for determining socioeconomic 

impacts from the operation of CPNPP Units 3 and 4. The review team’s methodology is 

governed by a process defined in the guidance document NUREG-1555, Environmental 

Standard Review Plan (ESRP) (NRC 2000) and contains the suggestions proposed. This 

comment did not provide new information that would change the review team’s determination; 

hence, no changes were made to the EIS as a result of this comment. 
Appendix E 

May 2011 E-103 NUREG-1943 

Comment: The DEIS discusses the abundance of outdoor recreation offered at area lakes and 

parks. The area lakes and parks offering such recreation are listed on page 2-91, though 

Possum Kingdom SP is not included. Table 2-10 identifies ecological oriented public recreation 

areas within 50 miles of CPNPP. Although Possum Kingdom SP is not within 50 miles of 

CPNPP, the project will require water withdrawls from PKL and affect its water levels. 

Recommendation: Because the project would require water withdrawls from PKL to supply Lake 

Granbury, Possum Kingdom SP should be included in the list of recreation areas within the 

project area. Subsequent evaluations in the DEIS should address potential impacts to Possum 

Kingdom SP. (0068-32 [Melinchuk, Ross] [Wicker, Julie])

Response: This comment recommends inclusion of Possum Kingdom State Park in the 

analysis of recreational impacts from operations even though Possum Kingdom Lake is beyond 

the typical 50 mile radius the review team establishes for assessing impacts. Upon 

consideration of this recommendation, the review team has revised Sections 5.4.1.4 

(Aesthetics) and 5.4.4.2 (Recreation) to include additional information about the potential 

impacts of water level decreases in Possum Kingdom Lake on aesthetics and recreation. In 

addition, Section 5.4.3.1 (Economy) has been expanded to include a discussion of the potential 

impacts of operating CPNPP Units 3 and 4 on the recreation-related aspect of the local 

economy. 

Comment: We moved to Granbury seven years ago and invested all of our equity in a home on 

Lake Granbury. Anything that affects the beauty and quality of Lake Granbury literally affects 

our financial future. Meanwhile, we understand that the NRC's Draft Environmental Impact 

Statement (DEIS) concludes that there are no environmental impacts that would preclude 

issuing permits for two additional reactors (Comanche Peak 3 and 4) at Luminant Energy’s Glen 

Rose facility (italics added). Obviously, the definition of "environment" is far too narrow for the 

real impact on Lake Granbury. Indeed, our environment is our quality of life and any action that 

will reduce the water levels, recreational usage and beauty of Lake Granbury directly impacts 

that environment. (0032-1 [Ferrero, Phil and Tracey]) 

Comment: I have read that preliminary reports showed little to no environmental impact. I 

don't know what the criteria for environmental impact is but lowering the lake level an average of 

7 inches to 2 feet at times is certainly going to impact our property values and way of life. In 

drought years we won't be able to use our docks for boating or fishing and we surely won't be 

able to sell our property for what we paid for it. There are those that will profit from selling our 

water that will argue that the water belongs to them and we just bought property next to “their 

water.” In their opinions what we think and what happens to our property values does not 

matter. The taxpayers in this country are getting tired of being told what we think and what 

happens to what we have worked our entire lives for does not matter. We are reasonable 

people that feel with some effort the needs for Luminant and the needs of the waterfront 

property owners can both be met. (0038-10 [Lowrance, Cleo]) 

Comment: The Chamber also recognizes that many of our members are directly or indirectly 

impacted by low lake levels. Business revenues, property values, and Granbury as a 

destination point suffer during periods of low water. 

Thus, the Chamber has also been very involved in the Lake Granbury task force that has met 

over the past year to address lake issues. Many groups have been involved including 

Luminant, Lake Granbury Waterfront Owners Association, City of Granbury, and even the 

Brazos River Authority. Through the discovery process, the Chamber understands that lake 

levels have tremendous complexity and are affected by many variables. 
Appendix E 

NUREG-1943 E-104 May 2011 

The Chamber believes that our work with the task force is unfinished. We do appreciate that 

the Brazos River Authority has acknowledged a usability difference in lake levels between Lake 

Granbury and Possum Kingdom. We anxiously anticipate the BRA study that compares the two 

lakes and should make a recommendation for better methods at synchronizing water levels. 

In addition, the Chamber looks to the BRA to provide information about the closure of the Morris 

Shepperd Dam. We believe that this was a major factor in the low lake levels during the 

summer of 2009. 

In summary, the Chamber believes that cooperation can exist with the different entities to bring 

our community a significant economic boom and a healthy lake. We look forward to ongoing 

discussions with interested parties. (0054-2 [Garner, Todd]) 

Response: These comments address concerns related to a number of socioeconomic 

categories, including aesthetics and recreational opportunities at Lake Granbury and Possum 

Kingdom Lake not only for property owners, but also as a fundamental component of the local 

economy. Consequently, the review team has revised Sections 5.4.1.4 (Aesthetics) and 5.4.4.2 

(Recreation) to include additional information about the potential impacts of water level 

decreases in Lake Granbury and Possum Kingdom Lake on these socioeconomic categories. In 

addition, Section 5.4.4.3 (Housing) has been revised to include a discussion of the potential 

impacts of operating CPNPP Units 3 and 4 on property values proximate to the lakes in 

question. Finally, Section 5.4.3.1 (Economy) has been expanded to include a discussion of the 

potential impacts of operating CPNPP Units 3 and 4 on the recreation-related aspect of the local 

economy. 

Comment: We must work together to protect our water resources that we have come to 

depend on in this region of Texas. It is not just the concern over property values and recreation. 

It is the real concern for the ability of this area to depend on water for our very existence as 

more people move to this area over time. (0036-1 [Murphy, Bill])

Response: This comment presents a concern for the availability of domestic water due to the 

construction and operation of CPNPP Units 3 and 4. Sections 4.4.4.4 and 5.4.4.4 (Public 

Services) discuss the potential domestic water-related impacts of building and operating 

CPNPP Units 3 and 4. The review team determined the in-migration of new workers and the 

consumptive use of water from operating the plant would constitute minimal impacts on local 

water supplies. This comment provided no new information that would affect the review team’s 

determination of no environmental justice impact; hence, no changes were made to the EIS as a 

result of this comment. 

Comment: The temporary influx of workers on the Barnett Shale brought money into the city 

and the businesses in Granbury. Most of these workers and spenders have moved on to other 

areas taking their money with them. The process of building the two new reactors will add 

workers but once the construction is complete some of these workers will also move on to the 

next project. (0038-5 [Lowrance, Cleo])

Response: This comment presents a concern for the impact of new workers arriving for the 

construction and operation of CPNPP Units 3 and 4. Sections 4.4.2 and 5.4.2 (Demography) 

and Sections 4.4.3.1 and 5.4.3.1 (Economy) discuss the potential impacts from new workers 

during the construction and operation of CPNPP Units 3 and 4, and determined those economic 

and fiscal impacts to be generally beneficial. This comment provided no new information that 

would affect the review team’s determination of no environmental justice impact; hence, no 

changes were made to the EIS as a result of this comment. 
Appendix E 

May 2011 E-105 NUREG-1943 

Comment: In terms of financial impact, we look for the project to play a vital part in addressing 

our future financial issues for Granbury ISD. Experience with education and legislation over the 

past 20 years will indicate to us that we'll still be facing an educational financial crisis in the state 

of Texas by the time this plant goes on line. Financial assistance will and can be accomplished 

through student enrollment. During the past year Granbury ISD enrollment dropped 253 

students from September 9 to May 28. This drop in our enrollment translates into over $1.7 

million in revenues for our district. The problem with a loss of 253 students across 11 

campuses and 13 grades means that we did not have an opportunity to reduce our 

expenditures, because we could not eliminate any teaching position. The flip side of that is that 

if we can regain those 253 students, then we don't have to add any teaching positions across 

those grade levels, so we would not see any increased expenditures, but yet we'd see an 

increase of over $1.7 million on revenues for our district. I would venture to say right now, after 

careful review and study, that we could add over 300 students to Granbury ISD and not 

increase our teaching staff any to meet the needs of those students, thus increasing our 

district's revenue over $2 million. (0062-13-2 [Mayfield, Ron])

Response: This comment is a general discussion of the historic and expected changes in 

school funding and capacity and does not provide any new information to the EIS process. 

Sections 4.4.4.5 and 5.4.4.5 (Education) discuss the potential impacts from new workers during 

the construction and operation of CPNPP Units 3 and 4 on local schools. No changes were 

made to the EIS as a result of this comment. 

Comment: The main reason why I think this group sitting here and the large hands who show 

is a quality-of-life issue. A county commissioner doesn't appoint the board of the BRA. I don't 

know what the TCEQ board. I set ad valorem taxes. And the quality of-life issue has to do with 

the ad valorem tax. And that's what the Nuclear Regulatory Commission needs to understand.

(0063-10-1 [Berry, Steve])

Response: This comment addresses a concern for potential impacts to local residents from 

changes to the ad valorem tax due to the construction and operation of CPNPP Units 3 and 4. 

Sections 4.4.3.2 and 5.4.3.2 (Taxes) discuss the potential impacts on local taxes and find the 

impacts to be generally beneficial. No changes were made to the EIS as a result of this 

comment. 

Comment: A lot of the money would go overseas and to workers brought into the community 

while the local community would bear the cost of infrastructure, housing, hospitals, schools.

(0063-30-9 [Hadden, Karen])

Comment: The construction phase will require skilled labor and the low-income residents are 

unlikely to be hired for this work. After construction, the majority of workers at the nuclear 

power plant will be technical in nature. Please address in the FEIS the number of jobs that will 

be available to local residents, and or a plan to include the residents in the work force at the 

Comanche Peak Nuclear Power Plant. (0070-19 [Smith, Rhonda])

Response: This comment addresses potential inequities through which local residents would 

experience the costs of building and operating CPNPP Units 3 and 4, while in-migrating workers 

would only experience the beneficial (wage-related) impacts of that project. Sections 4.4.2 and 

5.4.2 (Demography) and Sections 4.4.3.1 and 5.4.3.1 (Economy) discuss the potential impacts 

from new workers during the building and operating of CPNPP Units 3 and 4, and determined 

those economic and fiscal impacts to be generally beneficial. These comments provided no new 

information that would affect the review team’s determination of no environmental justice 

impact; hence, no changes were made to the EIS as a result of this comment. 
Appendix E 

NUREG-1943 E-106 May 2011 

Comment: [TPWD notes various inconsistencies in the DEIS including the following:] Section 

7, Page 7-4 states the Squaw Creek Reservoir (SCR) is closed to recreational activities, though 

Section 2 and most other references have been updated to indicate SCR is now open for 

boating and fishing. (0068-12 [Melinchuk, Ross] [Wicker, Julie])

Comment: TPWD recommended in its February 16, 2009 comments that SCR be opened for 

recreational use. As such, DEIS page 2-24 indicates Luminant has reopened the reservoir for 

limited public use, including boating and fishing. TPWD recognizes and appreciates Luminant’s 

efforts at providing public recreation opportunity at SCR. (0068-18 [Melinchuk, Ross] [Wicker, Julie])

Response: These comments identify a statement in the draft EIS that has become outdated. 

Due to new information provided with the help of these comments, the review team has revised 

the EIS accordingly. No changes were made to the EIS as a result of this comment. 

Comment: Any increased water treatment cost at the water treatment plant(s); and any 

resultant socioeconomic impacts associated with water quality alteration should be fully 

evaluated. (0070-13 [Smith, Rhonda])

Response: Sections 4.4.4.4 and 5.4.4.4 discuss the potential socioeconomic impacts of 

building and operating CPNPP Units 3 and 4 to public services, including water and wastewater 

treatment. After reviewing the information provided by the applicant in its Environmental Report 

and conducting its own independent investigation and consultation with local public services 

managers, the review team determined the potential impact to public services from building and 

operating the two proposed units at CPNPP would be minimal. This comment did not provide 

any new information and, therefore, no changes were made to the EIS as a result of this 

comment. 

Comment: The new plant will need to use existing roads and to build new ones. Lots of cars, 

trucks, and machinery will pass over them. How will Luminant ensure that roads are not 

congested? How will Luminant transport uranium and on which highways? Which communities 

will it pass through, and will their police and firefighting forces be trained to deal with a 

radioactive accident? (0071-41 [Hadden, Karen])

Response: This comment refers to four transportation-related concerns: the need for a new 

haul road into the site, traffic congestion, transportation of radioactive materials, and emergency 

response. Sections 4.4.4.1 and 5.4.4.1 address the potential impacts of building and operating 

CPNPP Units 3 and 4 in terms of traffic congestion on local roads. The sections discuss 

possible mitigation measures that could be implemented by Luminant and/or the Texas 

Department of Transportation. In regard to how uranium would be transported, the 

transportation of radioactive material to and from the Comanche Peak site, including 

unirradiated fuel, spent fuel, and radioactive waste, will be conducted in accordance with 

Federal regulations. The NRC and U.S. Department of Transportation (DOT) are the lead 

Federal agencies in charge of regulating the safety of shipments of radioactive materials. The 

NRC establishes requirements for the design and manufacture of packages for radioactive 

materials (10 CFR 71, Packaging and Transportation of Radioactive Materials). The DOT 

regulates the shipments while they are in transit, and sets standards for labeling and smaller 

quantity packages (Title 49, Transportation, U.S. Code of Federal Regulations). In regard to 

which highways would be used to transport uranium, as well as the training of police and 

firefighting forces to deal with the transport of radioactive materials, those items are beyond the 

scope of this EIS. In particular, the training of local personnel falls under emergency 

preparedness, which will be addressed as part of the safety review that is being conducted by 

the NRC. Section 5.4.4.4 of the EIS (Public Services) discusses police and fire department 

impacts in general, and Section 5.11 (Environmental Impacts of Postulated Accidents) 
Appendix E 

May 2011 E-107 NUREG-1943 

discusses the general state of and expected impacts to local police and fire services from 

building and operating CPNPP Units 3 and 4. Because this comment provided no new 

information and did not identify an area of omission in the EIS, no changes were made to the 

EIS as a result of this comment. 

Comment: Page 2-91 indicates that Luminant installed low-sodium lighting at Units 1 and 2 as 

a result of local resident complaints of light pollution. The DEIS indicates the same type of lowsodium lighting for Units 3 and 4 would be installed. Recommendation: TPWD recommends 

DEIS indicate the amount of light pollution that exists at Units 1 and 2 with the use of lowsodium lighting. Subsequent impact evaluations in the DEIS should include the magnitude of 

light pollution increase that would occur with Units 3 and 4. (0068-31 [Melinchuk, Ross] [Wicker, 

Julie])

Response: Section 5.4.1.4 (Aesthetics) includes a discussion of the potential impacts of light 

pollution from the proposed CPNPP Units 3 and 4 and concludes that the impact would be 

SMALL. This comment suggests the NRC should provide greater detail to that discussion by 

quantifying the amount of light pollution extant and the increase in light pollution that would 

occur if the proposed new units were built and operated. The review team did not revise the EIS 

discussion of light pollution because the quantification of the present and future levels of light 

pollution would not change the conclusions of the analysis. 

Comment: The DEIS states the operation of Units 3 and 4 could affect the recreational use of 

Lake Granbury and PKL by decreasing water level elevations, especially during summer 

months. With Units 3 and 4, the average water level of Lake Granbury could decrease by a 

minimum of 0.6 foot and a maximum of 2.9 feet. The water level in PKL could decrease by a 

minimum of 1.5 feet and a maximum of 14.8 feet. The maximum reductions in water level 

provided in this section are different than those given in the discussion of shoreline habitat in 

Section 5.3.1.1, page 5-19. During the 2009 drought, Lake Granbury water level dropped 3.5 

feet, the lowest level since 1984. During that time in 2009, half of the public boat ramps (3) and 

many of the private boat ramps and fixed boat docks were out of the water. The DEIS concludes 

that a 0.6-foot decrease would have a SMALL impact on recreational use, and a 2.9-foot 

decrease in water level during drought conditions would have a MODERATE impact on 

recreational use, particularly on the use of boat ramps and fixed boat docks. 

This would be especially noticeable given that most of the residential boat docks are fixed docks 

and cannot adjust to changes in water level. 

In the 2009 drought PKL level dropped 5.2 feet below full pool elevation. The DEIS concluded 

that a 1.5-foot decrease at PKL would have a SMALL impact on recreational use; a 14.8-foot 

decrease during drought conditions would have a MODERATE impact on recreational use. The 

DEIS concludes that impact to recreation on PKL might be less noticeable than on Lake 

Granbury, due to the fact that most residential boat docks on PKL are floating docks that can 

adjust somewhat to changes in water level. 

TPWD is concerned with the amount of boat docks and boat ramps that would be left dry during 

drought periods combined with water level reductions due to Units 3 and 4. It appears that water 

levels would be at their lowest during spring and summer when recreational use of boat docks 

and ramps is at its highest. Nighttime lighting is not addressed in this section on recreation, 

although Dinosaur Valley SP is located approximately 2.5 miles from the CPNPP site. 

Recommendation: TPWD recommends the applicant propose mitigation for loss of access to 

public and private boat ramps and docks. TPWD recommends Luminant provide financial 

assistance to both public and private entities for retrofitting existing ramps and docks to allow 

reasonable access to these surface waters. WAM models should include an assessment of the 

amount of time water levels would be reduced such that any of the existing public boat ramps 
Appendix E 

NUREG-1943 E-108 May 2011 

would be dry and access from the boat ramps would be impacted. The values given for 

maximum water level reductions should be consistent throughout the document. Potential 

impacts associated with increased nighttime light pollution to park users at Dinosaur Valley SP 

should be addressed. Measures to minimize impacts to state parks should be developed in 

coordination with David Riskind of TPWD State Parks Division Natural Resources Program at 

(512) 389- 4897. (0068-60 [Melinchuk, Ross] [Wicker, Julie])

Response: In these comments, the Texas Parks and Wildlife Department (TPWD) advised the 

review team of potentially conflicting water level estimates discussed in different sections of the 

EIS. The review team acknowledges this issue and will resolve it in the final EIS. The remainder 

of TPWD’s comment does not provide any new information that would necessitate a change in 

the EIS. In its recommendations, TPWD suggested actions for the applicant, which falls outside 

the scope of the NRC’s authority to implement. Consequently, the review team did not revise 

the EIS as a result of information contained in this comment. 

Comment: The approximate location of the proposed 345-kV Whitney transmission line shown 

in the DEIS crosses Dinosaur Valley State Park. In addition to providing habitat for the BCY 

and GCW, this state park offers public recreation activities that would be impacted by 

construction of a transmission line across or in sight of the park. This park and its viewshed 

should be avoided if at all possible. If the final project design requires that transmission lines 

cross any state-owned or managed lands, such as Dinosaur Valley State Park, the NRC, 

Luminant, and Oncor should be aware of the requirements of Chapter 26 of TPW Code 

(Chapter 26) discussed in Attachment A. (0068-8 [Melinchuk, Ross] [Wicker, Julie]) 

Response: While this comment mentions recreation, the intent of the comment is not a 

socioeconomic issue, but a land use issue. Transmission lines are discussed in Section 5.3.1.2 

(Terrestrial Resources—Transmission Lines and Cooling Water Pipelines). The last part of this 

comment involves advice to the applicant about relevant state regulations governing 

transmission line siting on state owned or managed lands. This recommendation is not within 

the scope of the NRC’s authority to ensure, but the accessibility of all comments to the public 

indicates the applicant’s project management team has access to this Texas Parks and Wildlife 

Department comment. No changes were made to the EIS as a result of this comment. 

E.2.12 Comments Concerning Historic and Cultural Resources 

Comment: the Delaware Nation has no comment to provide on the project. Please continue 

with the project. (0014-1 [Ross, Jason]) 

Comment: The Delaware Nation has received correspondence regarding Notification of the 

issuance of the draft environmental impact statement for the Comanche Peak Nuclear Power 

Plant, Units 3 and 4 combined license application review. The Cultural Preservation Director, 

Ms. Tamara Francis has reviewed the information provided along with cross referencing with 

our files and has determined that the Delaware Nation has no comment to provide on the 

project. Please continue with the project. (0014-2 [Ross, Jason]) 

Response: The NRC appreciates the review of the DEIS that was conducted by the Delaware 

Nation. The lack of comments and the recommendation to continue with the project are both 

noted. No change was made to the EIS as a result of this comment. 

E.2.13 Comments Concerning Environmental Justice 

Comment: And I'm very aware of the negative impact the last round nuclear power plants had 

on constituents. Was in -- at the time I was involved with a consumer organization and we 

fought the 25 percent rate increases that we experienced in the early '90s as a result of those 
Appendix E 

May 2011 E-109 NUREG-1943 

plants. And I want to preface my question with a question to the audience. Because I've laid 

the predicate at previous public -- How many of you are actually from this county, Somervell 

County? And how many of you are from Hood County? And how many of you are from Tarrant 

County or Dallas County? Okay. So most of the low-income, minority populations in the State 

of Texas either live in urban areas or rural south Texas or east Texas. The design of this 

project in this area is fundamentally flawed from my perspective because we're not having any 

of these meetings in Tarrant or Dallas County and we haven't been asked about it. But why are 

there no public meetings in places where those people live? (0063-2-1 [Burnam, Lon])

Response: EIS Sections 4.5 and 5.5 discuss the potential impacts of building and operating 

CPNPP Units 3 and 4 on minority and low-income populations within a 50-mile radius of the 

CPNPP, including a portion of Tarrant County. The NRC schedules public meetings in the 

community closest to where the proposed licensing action would occur and provides public 

notice for all interested parties to participate. The review team also performs extensive 

outreach within the communities within the area surrounding the proposed plant where 

socioeconomic impacts would most likely be seen. This comment provides no new information 

which would affect the EIS’ environmental justice determination; hence, no changes were made 

to the EIS as a result of this comment. 

Comment: According to the DEIS, generally the construction and operation of this facility at 

this site will not disproportionately and adversely impact low-income and minority residents in 

the area, however, in some ways it may impact residents of Hood and Somervell Counties 

adversely and negatively. The DEIS describes the need for increased water supply for the 

plant's cooling system, etc. from local water sources (Lake Granbury, Possum Kingdom Lake 

and the Brazos River). Because of frequent droughts, increasing population rates and global 

warming, these water sources are decreasing. This may cause water rates to increase as the 

local municipalities seek solutions to their water problems. This could have a disproportionate 

effect on the lowincome residents who do live in these two counties because they have lowpaying jobs and few resources. (0070-17 [Smith, Rhonda])

Response: The EIS analysis of the impacts of water use for the proposed new units uses 

information from the Texas Water Development Board and the Brazos River Authority supplied 

to the review team by Luminant. Due to uncertainties in the project design and other factors 

relevant to impacts, that information is based on assumptions that are expected to result in 

upper-end estimates of impacts. This is appropriate in order to ensure that potential impacts 

are not underestimated or overlooked. The assumption that 100 percent of existing water rights 

are exercised by their owners may not be completely realistic, but this assumption is necessary 

to provide assurance that water use by CPNPP Units 3 and 4 would not conflict with other 

users' water rights. The analysis described in Section 5.2.2.1 uses 68 years of historical data 

on streamflows in the Brazos River basin, including data from the “drought of record.” It 

determined that the use of surface water for the proposed new units would not interfere with the 

supply requirements of all other users in the region, including municipal and private water 

demand. EIS Sections 4.4.4.4 and 5.4.4.4 (Public Services) and 4.5.2 and 5.5.2 Socioeconomic 

Impacts [to Environmental Justice communities]) discuss the potential domestic water-related 

impacts of building and operating CPNPP Units 3 and 4 on minority and low-income populations 

within a 50-mile radius of the CPNPP. The review team determined the in-migration of new 

workers and the consumptive use of water from operating the plant would constitute minimal 

impacts on local water supplies. These determinations were made after extensive assessment 

of the local hydrology and discussions with local public services managers. This comment 

provided no new information that would affect the review team’s determination of no 

environmental justice impact; hence, no changes were made to the EIS as a result of this 

comment. 
Appendix E 

NUREG-1943 E-110 May 2011 

Comment: The DEIS discusses the impact of heavy truck traffic on the roads and highways 

during the construction phase. During the operational phase, traffic will increase due to the 

additional workers at the plant. Although the counties/municipalities will receive large tax 

revenues from the facility, taxes may increase for the residents to offset the cost of increased 

services (police, fire protection, social services, etc.). These tax increases for residents could 

have a disproportionately negative impact on low-income residents. (0070-18 [Smith, Rhonda])

Response: EIS Sections 4.4.1.3 and 5.4.1.3 (Roads) discuss the potential impacts to roads 

from building and operating CPNPP Units 3 and 4. The review team determined that the 

construction-related impacts to roads and traffic would be SMALL on most roads in the EIA, but 

MODERATE on FM 56, especially north of the CPNPP entrance. The operations-related 

impacts to roads and traffic would necessarily be smaller, because the size of the operations 

workforce would be so much smaller than that of the building phase. Therefore, the review team 

determined that all of the operations-related impacts would be SMALL. Sections 4.5.2 and 5.5.2 

(Socioeconomic Impacts) discuss the potential impacts of building and operating CPNPP Units 

3 and 4 on minority and low-income populations within a 50-mile radius of the CPNPP. The 

review team determined that because there are no special conditions characterizing minority 

and low-income populations of interest in the vicinity of the plant, that there was no 

disproportionately high and adverse impact on environmental justice communities. This 

comment did not provide any new information or indicate any area of omission that would 

warrant revision to the EIS. 

Comment: The proposed new plants would affect low income and minority residents. How 

much will rent go up when the influx of construction workers and their families come to 

Somervell County? (0071-45 [Hadden, Karen]) 

Response: EIS Sections 4.4.4.3 and 4.5.2 (Housing) address the potential impacts of inmigrating construction and operations workers for CPNPP Units 3 and 4 on housing demand 

and prices, particularly for low-income residents. These sections state the reasons why the 

review team determined that the impacts from potential increases in housing costs would be 

minimal. This comment provided no new information and, therefore, the review team did not 

revise the EIS.

Comment: Will pollution from construction and operation reach low-income housing areas?

(0071-46 [Hadden, Karen]) 

Response: Construction and pre-construction impacts on air quality for the general public can 

be found in Sections 4.7.1(Construction and Preconstruction Activities) and 4.4.1.6 (Air Quality). 

Construction and pre-construction-related impacts on minority and low-income populations are 

addressed in greater detail in Section 4.5.1.3 (Air Pathway). Similarly, Sections 5.7.1(Air Quality 

Impacts) and 5.4.1.6 (Air Quality) discuss operations-related air quality impacts to the general 

public, and Section 5.5.1.3 (Air Pathway) discusses operations related air quality impacts to 

minority and low-income populations. Primarily due to the distance between identified minority 

and low-income populations of interest and the source of air quality emissions, the review team 

determined these impacts would be minimal. No changes were made to the EIS as a result of 

this comment. 

E.2.14 Comments Concerning Health - Nonradiological 

Comment: One of the other issues I worked on in the DFW area is cement plants that burn 

hazardous waste in that county, a town that's governed by cement near Midlothian. One of the 

largest Down Syndrome clusters in the state. And increase of cancer rates, prostate and breast 
Appendix E 

May 2011 E-111 NUREG-1943 

cancer. These types of things need to be in consideration. We may be getting jobs and taxes 

but what are we doing to our families and our children? (0063-29-4 [Benning, Rita])

Response: This comment concerns cumulative health impacts. Potential non-radiological 

health effects from operation of CPNP Units 3 and 4 are discussed in Section 5.8. Section 7.7 

contains a discussion of the cumulative effects of the proposed two units, when the two existing 

units and other activities near the site are considered. No changes have been made to the EIS 

as a result of these comments. 

E.2.15 Comments Concerning Health - Radiological 

Comment: But the other reason I'm here today is for another reason. And that is this 

environmental impact statement should thoroughly examine more on the radioactive health risks 

of these reactors. No national maximum available control technology standard has been set for 

radio nuclide emissions despite the fact that nuclear reactors routinely emit cancer-causing 

radioactivity. No new reactors should be licensed until the standard is set. (0063-29-2 [Benning, 

Rita])

Comment: Research has shown an increase in cancer rates around nuclear plants. Dr. 

Joseph Majohno of the Radiation and Public Health Project studied the cancer death rate in the 

three counties closest to the South Texas Nuclear Project, an area that originally had a cancer 

rate below the statewide rate. Sixteen years after the reactors began running the cancer death 

rate in the area has risen over 16 percent. (0063-29-3 [Benning, Rita])

Comment: The National Academy of Scientists has concluded that radiation is dangerous even 

at low levels. While low-level radiation exposure is not as damaging as high-level radiation on a 

short-term basis, prolonged exposure to low-level radioactivity can be just as damaging to 

humans. (0063-29-5 [Benning, Rita])

Comment: The Environmental Impact Statement (EIS) should thoroughly examine radiation 

health risks. No national (MACT) standard has been set for radionuclide emissions, despite the 

fact that nuclear reactors routinely emit cancer-causing radioactivity. No new reactors should 

be licensed until this standard is set. 

 Research has shown an increase in cancer rates around nuclear plants. Dr. Joseph 

Mangano of the Radiation and Public Health Project studied the cancer death rate in 

thethree counties closest to the South Texas Nuclear Project, an area that originally had a 

cancer rate below the statewide rate. Sixteen years after the reactors began running, the 

cancer death rate in the in the area had risen over 16%. 

 The National Academy of Sciences has concluded that radiation is dangerous even at low 

levels (BEIR VII study). 

 While low-level radiation exposure is not as damaging as high-level radiation on a shortterm basis, prolonged exposure to low-level radioactivity can be just as damaging to 

humans. (0071-22 [Hadden, Karen])

Comment: The EIS should research the extent to which new reactors would add to cancer 

risks. Four reactors at one site would produce significantly more radioactive risk than the two 

existing reactors. What would be the total amount of low-level radiation emitted? How much 

would surrounding populations be exposed? How much radioactivity would be in routine 

operations? The EIS should use background radiation levels not only from before the 

construction of the two existing nuclear reactors also from before the testing of nuclear weapons 

in the United States, which resulted in radioactive fallout. (0071-23 [Hadden, Karen])
Appendix E 

NUREG-1943 E-112 May 2011 

Comment: The environmental impact statement should research the extent to which new 

reactors would add cancer risk. After all, you're doubling the amount of reactors that you have 

now. Four reactors at one site would produce significantly more risk than two existing reactors. 

What would be the total amount of low level radiation emitted? Was anybody given the 

information regarding that? How much would surrounding populations be exposed? Not just 

right around the lake but beyond that. How much radioactivity would be in routine operations?

(0063-29-6 [Benning, Rita]) 

Comment: there are routine emissions of radio-nuclides. Those are not adequately addressed 

in the DEIS. (0063-30-4 [Hadden, Karen]) 

Response: The comments concern potential health effects such as cancer from radiation 

exposure. Section 5.9 discusses the estimated doses that members of the public would receive 

from operation of proposed CPNPP Units 3 and 4 and compares those doses to NRC and EPA 

dose standards. To assess cumulative impact, Table 5-17 compares the total expected doses 

from operation of the two existing reactors and the two proposed reactors at CPNPP to EPA’s 

dose standards. As Section 5.9 indicates, NRC assumes there is some health risk associated 

with any amount of radiation dose, no matter how small; this approach is consistent with the 

conclusions of BEIR VII and other expert panels such as the International Commisssion on 

Radiation Protection. Section 5.9 also discusses the potential health effects from operation of 

CPNPP Units 3 and 4 and concludes that there would most likely be zero excess health effects. 

The NRC staff has reviewed the claims by Dr. Mangano of the Radiation and Public Health 

Project of increased cancer around the South Texas Nuclear Project and discussed those 

claims with the Texas Department of State Health Services. The NRC concludes that the 

increases in cancer claimed by Dr. Mangano are not related to radiation exposure from the 

South Texas Project. No changes have been made to the EIS as a result of these comments. 

Comment: Liquid, gaseous, and solid radioactive waste would be produced as a byproduct of 

the facility operation. Each effluent will be processed to maintain releases within regulatory 

limits and as low as reasonably achievable before being released to the environment. The 

waste-processing systems are designed to meet objectives of federal guidelines discussed in 

the DEIS. Liquid radioactive waste is processed with radiation detection and sampling prior to 

release. The treated stream is discharged to SCR via CPNPP Units 1 and 2 circulating return 

line. The DEIS indicates that SCR tritium levels may approach allowable levels with all four 

units discharging to SCR at the same time, so Luminant plans to divert a portion the effluent to 

an evaporation pond, which would create an airborne dose pathway of tritium that is evaluated 

in Chapter 5 impacts. The DEIS does not indicate which evaporation pond and where liquid 

effluent from the evaporation pond discharges. Based on the discussion of the LRW handling 

processes, it is unclear if effluent other than to SCR may potentially contain tritium. Gaseous 

radioactive waste (GRW) containing radioactive isotopes, xenon, krypton, and iodine is 

processed to control and minimize release to the environment. The processed GRW is diluted 

with heating, ventilating and air conditioning (HVAC) flow and their release system is equipped 

with a discharge valve that closes if the radiation set point is exceeded. The temporary on-site 

storage of solid radioactive waste (SRW) is designed to store waste for up to 10 years. 

Approximately 30,000 cubic feet of SRW would be shipped from Units 3 and 4 annually. The 

DEIS does not indicate where the SRW would be shipped after leaving CPNPP. 

Recommendation: TPWD recommends the DEIS indicate to which evaporation pond the LRW 

may be routed, if liquid effluent from this pond is discharged, and to which surface water the 

evaporation pond discharges. TPWD recommends the DEIS indicate where the SRW would be 

shipped after temporary on-site storage. Impacts associated with SRW transportation should be 

assessed in subsequent chapters of the DEIS. (0068-38 [Melinchuk, Ross] [Wicker, Julie])
Appendix E 

May 2011 E-113 NUREG-1943 

Response: The comment concerns radioactive effluent release paths for the proposed CPNPP 

Units 3 and 4. Section 5.9.2.1 has been revised to indicate that any discharge from the 

evaporation pond in extreme weather conditions would be released to SCR along with the rest 

of the liquid radioactive effluents through the circulating water return line from CPNPP Units 1 

and 2. Radioactive material is not released to the evaporation pond that receives blowdown 

from the cooling towers. Section 6.2 addresses the environmental impacts of transportation of 

radioactive waste. 

Comment: EPA recommends CPNPP sample above and below the dam on Squaw Creek 

Reservoir. The reason being many older existing nuclear power plants (e.g., Oyster Creek in 

New Jersey for instance) is experiencing tritium leaks of close to 20,000 pico-curie / liter. Please 

respond to this concern in the FEIS. (0070-2 [Smith, Rhonda])

Response: The comment concerns radiological monitoring at SCR. The current Radiological 

Environmental Monitoring Program for CPNPP Units 1 and 2 includes water sampling in SCR. 

In addition, Luminant samples a number of wells on the CPNPP site for radioactive materials, 

including tritium. As described in Section 5.2.3.2, any leaked materials are expected to move 

toward SCR. No changes have been made to the EIS as a result of this comment. 

Comment: The impacts and risks of storing additional high -level radioactive waste on site 

needs to be studied thoroughly in the EIS. The long- term cumulative health impacts of 

additional low-level radiation need to be studied thoroughly and included in the environmental 

impact study as well. Impacts on humans, wildlife and plant life need to be considered, with 

special attention given to threatened and endangered species. (0071-25 [Hadden, Karen])

Comment: 

 Radioactive tritium can leak from nuclear reactors and increase cancer risks. According to 

NRC reports tritium levels are already high at the Comanche Peak site compared to other 

reactor sites. What would adding more reactors do to the already high levels of 

contamination? 

 Numerous radioactive tritium leaks in Illinois are so severe that people can’t drink or bathe in 

their water due to contamination. Cancer cluster, wildlife impacts, fines and lawsuits 

resulted. (0071-34 [Hadden, Karen])

Response: The comment concerns the potential cumulative level of tritium contamination in 

SCR and the potential for tritium leaks from operation of the proposed CPNPP Units 3 and 4. 

Section 5.9.1 has been revised to address the potential for tritium leaks from the proposed 

CPNPP Units 3 and 4. Section 7.8 has been revised to address the potential radiological 

impacts of the expected cumulative tritium concentration in SCR with all four CPNPP units 

operating (the two existing units and the two proposed units.)

E.2.16 Comments Concerning Accidents - Severe 

Comment: And there are risks that come with radioactivity for workers, for the community and 

especially if there ever was a severe accident that simply do not come with other forms of 

electric generation. (0063-30-10 [Hadden, Karen])

Comment: 

 The risk of a nuclear accident and the magnitude of devastation would increase with more 

reactors on the site. 
Appendix E 

NUREG-1943 E-114 May 2011 

 The public deserves to know the real risks of nuclear power. In 1980 the NRC 

conducted a study of what would happen under a worst-case scenario accident at each 

nuclear plant site. The Comanche Peak estimates were: 

 1210 early deaths (25 mile radius around plant) 

 13,800 early injuries (35 mile radius) 

 $117 billion (1980 dollars) in financial consequences 

The Environmental Impact Statement should include a similar study to update these risk figures, 

since the population of the region has grown and since there would be more reactors. (0071-28

[Hadden, Karen])

Response: The comments concern the risks of severe accidents. Section 5.11.2 addresses 

the potential consequence impacts of severe accidents for CPNPP Units 3 and 4. In particular, 

Table 5-25 estimates the risks of early and latent fatalities and environmental costs. These 

values are all presented as risk values per reactor-year; for example, the early fatalities are 

estimated by multiplying the release class frequency by the population dose for that release 

class and the health risk coefficient (early fatalities per person-Sv). The NRC believes that 

these risk values represent the most meaningful way to place the risk in context and inform the 

environmental assessment process. The values quoted by the commenter were peak values 

from a range of possible values based on worst case scenarios for the current Comanche Peak 

reactors. The values in Table 5-25 are based on mean estimates (more likely estimates) for the 

proposed Comanche peak reactors. The design of the proposed reactors includes features 

intended to lower the risk of severe accidents even further than the already safe risk level of the 

current reactors. The cumulative risk of severe accidents for all four reactors at CPNPP (the 

two currently operating and the two proposed) is discussed in Section 7.9. No changes have 

been made to the EIS as a result of these comments. 

Comment: The EIS should analyze and publicize the impacts of an airplane crashing into a 

nuclear reactor or the spent fuel pool and the impact that such a disaster would have for both 

humans and the environment. (0071-29 [Hadden, Karen])

Response: The comment concerns the potential impacts from an airplane crash. The 

likelihood of an airplane crash as an unintentional act will be evaluated as part of the safety 

review of this COL application; generally the estimated frequency of such a crash is less than 

1 x 10-7, and the NRC does not consider events at such low frequencies in an EIS because 

they are “remote and speculative.” In addition, the NRC does not assess the risk or 

environmental impact of releases of radioactive material that could be caused by terrorist 

attacks in an EIS. NRC considers postulation of such attacks to be “remote and speculative” as 

defined by NEPA. More appropriately, NRC does evaluate security issues outside the NEPA 

process. The NRC evaluates aircraft hazards and aspects of physical security as part of the 

safety review of a COL application. With regard to aircraft impacts, NRC regulations (74 FR 

28112) require applicants for new nuclear power reactors to perform a rigorous assessment of 

the design to identify design features and functional capabilities that could provide additional 

inherent protection to avoid or mitigate the effects of an aircraft impact. No changes have been 

made to the EIS as a result of this comment. 

Comment: DEIS Section 5.11.2, page 5-91, lines 6-9: The cumulative population dose 

associated with a severe accident without loss of containment at the CPNPP site is calculated to 

be 9 person-Sv. The population dose risk for this release class is the product of 1.1 x 10-6 Ryr1 and 9 person-Sv, which equals 1.1 x 10-5 person-Sv Ryr-1.The frequency of an intact 

containment event (RC6 -Intact Containment) is 1.1 E-06/RY as provided in ER Table 7.2-6. 

The dose risk is presented in this table for the 2001, 2003 and 2006 meteorological data cases 
Appendix E 

May 2011 E-115 NUREG-1943 

as: 9.97E-04, 1.18E-03, and 1.01 E-03 person-rem/RY, respectively (note: 100 rem = 1 Sv). 

The NRC value of 1.1 x 10-5 person-Sv Ryr-1 is not supported by the information in the DEIS 

(i.e., 1.1 x 10-6 Ryr-1 times 9 person-Sv). This is a very minor difference and is only included to 

inform the NRC of the error. (0073-8 [Flores, Rafael])

Response: The comment questions a risk value presented in Section 5.11.2 of the Draft EIS. 

The value was an error and has been corrected in Section 5.11.2. The error did not affect the 

conclusions of the analysis. 

Comment: DEIS Section 5.11.2.1, page 5-95, lines 22-26: The average individual latent 

cancer fatality risk is calculated using the population distribution within 10 mi of the~plant. For 

the plants considered in NUREG-1150, these risks were well below the Commission's safety 

goals (NRC 1990). Risks calculated for the US-APWR design at the CPNPP site as shown in 

Table 5-25 are also well below the Commission's safety goals. The DEIS states that dose risk 

is calculated at 10 miles from the plant, but DEIS Table 5-25 is based on 50-miles (0073-9

[Flores, Rafael])

Response: The comment questions statements regarding the basis of risk estimates in Section 

5.11.2.1 of the DEIS. Section 5.11.2.1 has been revised to clarify the basis of the risk estimates. 

MACCS2 calculates the average individual latent cancer fatality risk to the 10-mi population 

(latent fatality column in Table 5-22). Table 5-25 presents 50-mi population dose risks. The 

population dose risk estimates in Table 5-22 are also based on the 50-mi population. 

E.2.17 Comments Concerning the Uranium Fuel Cycle 

Comment: As residents of this area, we also have serious concerns about the increased buildup of on-site nuclear waste (0055-7 [Inge, Charles] [King, Arnold] [Rosenfeld, Joshua])

Comment: And I'm also concerned about the environmental impact of additional reactors, 

including the environmental impact of the nuclear waste, whether it's stored here at Comanche 

Peak or trucked around to other locations. Because regarding radioactive waste there is no 

solution in sight. There are no high or low- level waste currently available. Nuclear reactors 

produce tons of high and low-level radioactive waste that remains dangerous to living beings for 

tens of thousands of years. 

Radioactive and toxic waste is produced at every stage of the fuel cycle, including routine plant 

operations. And federal law prohibits licensing of any new nuclear plant until there is an 

adequate waste disposal plan. Nuclear plants have been operating for 50 years but the waste 

disposal problem has not yet been solved. (0063-32-3 [Rooke, Molly])

Comment: The impact and risk of storing additional high-level radioactive waste on site needs 

to be studied thoroughly in the EIS and the long-term cumulative health impact of additional lowlevel radiation needs to be studied and included in the study, as well. (0063-32-5 [Rooke, Molly])

Comment: As residents of this area we are -- we have serious concerns about the increased 

buildup of onsite nuclear waste (0063-36-7 [Hackett, Ken])

Comment: I may have more expertise in this area than anybody else in the room. And that is 

the entire fuel cycle. Chapter 6 is one of about four chapters that I consider to be fundamentally 

flawed. And I want to talk about that one the most. It's the fuel cycle. It's the transportation. 

And it's the de-commission in cost. For the seven sessions -- 14 years -- that I've been in the 

Legislature we have been struggling at the legislative state government level over what to do 

with the waste. The waste has been accumulating at this site since the first operation in the 
Appendix E 

NUREG-1943 E-116 May 2011 

early '90s. Now you're asking for the opportunity to double that amount of waste. And we have 

not resolved what to do with that. (0063-5-4a [Burnam, Lon])

Comment: Let's talk about the radioactive waste on site here. It is likely -- because of the 

failure of the state government to address the issues, it is likely once those two facilities are 

operating that that waste will continue to be stored on this site. That adds to any number of 

problems. This is simple math. You are doubling the amount of radioactive waste there. (0063-

5-7 [Burnam, Lon])

Comment: You need in the DEIS -- there's a discussion about the low level radioactive waste 

site. We will again submit comments. But you need to know that license is under appeal. 

Whether that actual facility actually opens up at the end of this year as they expect is under 

question. They're also under enforcement. And you also need to reflect that that license that 

has been granted by TCEQ is based upon waste from existing nuclear plants, including 

Comanche Peak, South Texas and the Vermont Yankee. But the license that was given by 

TCEQ, which is under appeal, is not large enough to actually incorporate waste from these new 

facilities. They don't have that license. Maybe in the future they'll expand it. But that current 

license would not cover this waste. (0063-18-11 [Reed, Cyrus])

Comment: Radioactive waste remains stored on site of reactors across the country. And there 

is no national storage facility for high-level radioactive waste. And the Yucca Mountain 

repository is unlikely to open in the near future. The Andrews County low-level waste dump 

application has been deemed incomplete by the Texas Commission on Environmental Quality. 

(0063-32-4 [Rooke, Molly])

Comment: I want to make sure people understand what we're talking about in storing this 

waste. Years ago the national government set up a Compact Commission process. Texas was 

one of three states in the Compact. And in theory we've agreed to be the host state to two other 

states. One state has withdrawn. The other one, Vermont Yankee -- well, the State of Vermont. 

But Vermont Yankee will be the major source, about 99 percent of the waste from Vermont will 

come from that decommissioned facility. They're not ready for it. And we're not funding the 

state agency that is responsible for regulating because we're doing this 5 percent and 10 

percent slash and burn to all our state agencies. Texas is fundamentally not in a good place to 

manage the waste that is already produced at the two nuclear power plants and the reactors 

that we have now. It is an even worse place to manage doubling in Texas. And it is 

phenomenal to me that people are not discussing the issue of the way the law was passed. 

And the way we are progressing in time it is most likely that this nuclear waste dump in Texas 

will fill up with nuclear waste other than Texas-generated waste before these facilities reach the 

end of their life if they're asked to be licensed. And the way the law is set up the people that get 

to pay for that mistake are the taxpayers of Texas. Because we fundamentally failed people in 

passing the legislation. The billionaire that owns this site made sure that he would make his 

money in the first 15 years just like any slum landlord building an apartment complex. And then 

the State of Texas will inherit the economic responsibilities for managing God knows how much 

waste generated from outside of the state. No telling what we're going to do with the waste if 

we add to that. (0063-5-8 [Burnam, Lon])

Comment: [P]lease consider the full life cycle of the environmental impact of these proposed 

nuclear reactors (0063-32-9 [Rooke, Molly])

Comment: The DEIS indicates that Class A low-level radioactive water (LLW) would be 

acceptable for disposal at the Energy Solutions site in Clive, Utah, though Class B and C LLW 

would not be acceptable at the Energy Solutions site in Barnwell, South Carolina. The DEIS 

indicates that Class A, B, and C LLW created from CPNPP Units 3 and 4 may likely be 
Appendix E 

May 2011 E-117 NUREG-1943 

disposable at the Waste Control Specialists, LLC (WCS) newly licensed radioactive material 

low-level waste facility in Andrews County, Texas. WCS received its license from TCEQ in 

September 2009, though at the time of the DEIS, construction and operation of the facility had 

not yet been approved. Approval of the WCS facility is expected in late 2010. The DEIS 

indicated it is likely alternate disposal pathways for Class B and C LLW would include 

compaction and storage at offsite vendor locations until disposal is secured and blending of 

waste types with subsequent disposal at available disposal sites. It is anticipated that Luminant 

could also temporarily store Class B and C LLW onsite in accordance with existing NRC 

regulations until offsite storage is available. 

The DEIS indicates that high-level and transuranic wastes are to be buried at a repository such 

as the candidate repository at Yucca Mountain, Nevada. The NRC Waste Confidence Decision, 

10 CFR 51.23, has made the generic determination that if necessary, spent fuel generated in 

any reactor can be stored safely and without significant environmental impacts for at least 30 

years beyond the licensed life for operation of that reactor at its spent fuel storage basin or at 

either onsite or offsite independent spent fuel storage installations. Additionally, the NRC 

believes there is reasonable assurance that at least one mined geologic repository will be 

available within the first quarter of the 21st century and sufficient repository capacity will be 

available within 30 years beyond the licensed life for operation of any reactor to dispose of the 

commercial high-level waste and spent fuel originating in such reactor and generated up to that 

time. Thus the NRC concludes SMALL impact associated with LLW and high level waste 

generated by Units 3 and 4. Recommendation: If the DEIS and EIS are not finalized until 2011, 

TPWD recommends the documents be updated to indicate the construction and operation 

status of the LLW WCS facility in Andrews County, Texas. Updates regarding the status of 

pending availability of high-level waste repositories should also be included as the EIS becomes 

finalized. (0068-61 [Melinchuk, Ross] [Wicker, Julie])

Comment: No high or low-level waste sites are available. 

 Nuclear reactors produce tons of high and low-level radioactive waste that remains 

dangerous to living beings for tens of thousands of years. Radioactive and toxic waste is 

produced at every stage of the fuel cycle, including routine plant operations. 

 Federal law prohibits the licensing of any new nuclear plant until there is an adequate waste 

disposal plan. Nuclear plants have been operating for 50 years, but the waste disposal 

problem has not been solved. Radioactive waste remains stored onsite at reactors across 

the county. 

 There is no national storage facility for high-level radioactive waste and the Yucca Mountain 

repository is unlikely to open in the near future. The Associated Press wrote: The Energy 

Department is cutting operations and the chief contractor is laying off its staff at the desert 

site where the government plans to build a national nuclear waste repository... Jan 8, 

2008. 

 The Andrews County low-level waste dump application has been deemed incomplete by the 

Texas Commission on Environmental Quality. (0071-24 [Hadden, Karen])

Comment: The impacts and risks of storing additional high -level radioactive waste on site 

needs to be studied thoroughly in the EIS. The long- term cumulative health impacts of 

additional low-level radiation need to be studied thoroughly and included in the environmental 

impact study as well. Impacts on humans, wildlife and plant life need to be considered, with 

special attention given to threatened and endangered species. (0071-25 [Hadden, Karen])

Response: These comments concern the environmental impacts of onsite storage and 

eventual disposal of (1) low-level radioactive waste and (2) spent fuel and high-level radioactive 
Appendix E 

NUREG-1943 E-118 May 2011 

waste produced by the proposed CPNPP Units 3 and 4. Section 5.9 of the EIS addresses the 

radiological impacts of operation of the proposed CPNPP Units 3 and 4, including the onsite 

storage of radioactive wastes until they can be shipped to a licensed waste disposal facility. 

Section 6.1 of the EIS addresses the environmental impacts of the fuel cycle, and Section 6.1.6 

specifically addresses the environmental impacts of radioactive waste disposal after it is 

shipped from the CPNPP site. Section 6.1.6 also addresses options such as the addition of 

temporary onsite storage capacity if licensed disposal facilities are temporarily not available. 

Section 6.1.6 has been revised to update the construction and operating status of the Waste 

Control Specialists LLC low-level radioactive waste disposal facility in Andrews County, Texas. 

Section 6.1.6 has also been revised to incorporate the recent revision of the NRC Commission’s 

Waste Confidence Decision and Rule (F75 FR 81037). In this decision, the Commission 

determines that that “if necessary, spent fuel generated in any reactor can be stored safely and 

without significant environmental impacts for at least 60 years beyond the licensed life for 

operation (which may include the term of a revised or renewed license) of that reactor in a 

combination of storage in its spent fuel storage basin and at either onsite or offsite independent 

spent fuel storage installations. Further, the Commission believes there is reasonable 

assurance that sufficient mined geologic repository capacity will be available to dispose of the 

commercial high-level radioactive waste and spent fuel generated in any reactor when 

necessary.”

Comment: In Chapter 6 we should have talked about the fuel cycle and the incidents of 

increased cancer in the uranium fields, both in south Texas and New Mexico. Anybody on the 

Indian reservations in northwestern New Mexico can tell you about the cancer rates caused by 

inadequate regulation in adequately addressing the fuel cycle issues. (0063-5-4b [Burnam, Lon])

Comment: And another big concern is when you're going to be putting in new reactors, you're 

going to be needing more fuel. And being originally from south Texas and still having a ranch 

down there, I know there's a lot of opposition to the mining of uranium down there and the 

contamination of water supply, because the mining and enrichment of uranium results in 

radioactive contamination of the environment and a risk to public health. Exposure to radon has 

been shown to cause kidney failure, chronic lung disease and tumors of the brain, bone, lung 

and nasal passage. And in the last ten years the Texas Department of Health Services has 

cited several instances of radioactive waste spills by uranium mining companies, including the 

1998 of over 20,000 gallons of radioactive solution in Bruni, Texas. 

The Environmental Protection Agency has warned that residents of Kleberg County and their 

groundwater currently contains unsafe levels of uranium and strongly advises against drinking it. 

And residents of Goliad and Kleberg Counties have both publicly opposed the continued 

operations of mining company below their communities. The aquifer below Karnes County has 

been contaminated by uranium mills tailings, and the Department of Energy estimates clean-up 

costs will cost 348 million but, according to a Texas Department of Agriculture report, will not 

implement the clean-up plan. (0063-32-8 [Rooke, Molly])

Comment: Contamination from Uranium would increase in South Texas Mining and enriching 

uranium results in radioactive contamination of the environment and risks to public health. 

Exposure to radon has been shown to cause kidney failure, chronic lung disease, and tumors 

for the brain, bone, lung, and nasal passage. 

 In the last ten years, the Texas Department of Health Services has cited several instances 

of radioactive waste spills by uranium mining companies, including Cogema Inc.’s 1998 spill 

of over 20,000 gallons of radioactive solution in Bruni, Texas. 
Appendix E 

May 2011 E-119 NUREG-1943 

 The Environmental Protection Agency has warned residents of Kleberg County that their 

groundwater currently contains unsafe levels of uranium, and strongly advises against 

drinking it. 

 Residents of Goliad and Kleberg counties have both publicly opposed the continued 

operations of mining companies in their communities. 

 The aquifer below Karnes County has been contaminated by uranium mill tailings. The 

Department of Energy estimates clean up will cost $348 million but, according to a Texas 

Department of Agriculture report, will not implement the clean up plan. (0071-47 [Hadden, 

Karen])

Response: These comments concern the levels of uranium in the groundwater in south Texas 

and New Mexico. Contamination at specific uranium mines or mills is beyond the scope of the 

assessment of environmental impacts for the COL application for the proposed CPNPP Units 3 

and 4. No change was made to the EIS as a result of these comments. 

E.2.18 Comments Concerning Transportation 

Comment: When it comes to transportation, because the state law is so fundamentally flawed 

and it will likely open the west Texas site becoming not only the nation's but maybe the 

international nuclear waste site, my district will get to be -- play host to most of the nuclear 

waste generated in this country as it comes from the east and midwest through the Dallas- Fort 

Worth area. (0063-5-5 [Burnam, Lon])

Response: The comments concern the environmental impacts of transportation of radioactive 

waste. The environmental impacts of transporting spent fuel and other radioactive wastes 

associated with the proposed new reactor units are discussed in Section 6.2 of this EIS. As 

discussed in Section 6.2, the transport of spent fuel and other radioactive wastes would be 

conducted in accordance with Department of Transportation (DOT) and NRC regulations. In 

addition, the cumulative impacts of transportation of spent fuel and other radioqctive wastes are 

addressed in Section 7.10.2 of this EIS. No changes were made to the EIS as a result of these 

comments. 

E.2.19 Comments Concerning the Need for Power 

Comment: Moreover, the need for power analysis is based upon the need for additional peak 

power, when nuclear power is intended to provide baseload power. Indeed, the DEIS should 

assess the expected growth in average load rather than peak power to determine additional 

needs in Texas. (0052-6 [Reed, Cyrus]) 

Comment: We also object to your almost near reliance on ERCOT's planning projections which 

are really based on peak demand when this plant is not about peak demand. It's about baseload. And we feel like you need to add some additional information as you look into the future 

that doesn't just reflect the rising peak but the actual annual load growth. (0063-18-7 [Reed, 

Cyrus])

Response: In response to these comments a discussion of baseload power was added to 

Section 8.4. The conclusions of the chapter were not changed in response to this comment. 

Comment: I would also mention that at least two commissioners at the Utility Commission -- 

this is again about new sources -- have told me they will be introducing a 500 megawatt by 2015 

requirement for renewable sources other than wind as a proposal at the end of this month or 

next month. Depending on the timing, we may need to incorporate that into your analysis. I've 

said that already. (0063-18-8 [Reed, Cyrus])
Appendix E 

NUREG-1943 E-120 May 2011 

Response: This comment speculates on the impact of a requirement that has not been 

implemented. The conclusions of this chapter were not changed in response to this comment. 

Comment: [Please consider] whether or not these proposed units are even needed. (0063-32-

11 [Rooke, Molly])

Response: This comment provides a general request for consideration of the need for power in 

the relevant area be incorporated in the EIS. Since they offered no additional information or 

identified an area of omission in the EIS Chapter 8 (Need For Power), the review team did not 

revise the EIS because of these comments. 

Comment: [T]he DEIS notes that ERCOT values wind capacity at 8.7 percent of name 

capacity, but this number was used for a reliability figure several years ago for peak times and is 

not reflective of wind capacity today, both overall and at peak. Thus, the DEIS should be 

updated to reflect more recent trends in wind development, which would show the need for 

power is much less than suggested in the DEIS. (0052-8 [Reed, Cyrus])

Comment: [T]he analysis seems to admit the buildout of wind in Texas on the one hand, but 

then fails to consider the additional capacity that would result from that build-out. The analysis 

also relies on the ERCOT valuation of wind at peak as only providing 8.7 percent of name 

capacity, even though the number is acknowledged by most as undervaluing wind's contribution 

at peak. Indeed, even if assuming wind's capacity is only 8.7 percent in hot summer afternoons, 

the analysis should provide wind's overall capacity during a year, since presumably nuclear 

power would be a base resource and not a peak resource. (0066-8 [Reed, Cyrus])

Response: These comments challenge the use of an 8.7 percent load carrying factor for wind. 

Since the publication of the DEIS, the ERCOT Board has reaffirmed the use of the 8.7 percent 

load carrying capacity parameter. NRC Staff has therefore maintained this assumption in our 

analysis. To an extent, the wind scenario added to the discussion addresses this comment by 

illustrating the impact of a doubling of wind power. The conclusions of the chapter were not 

changed in response to this comment. 

Comment: Nuclear plants in the southeastern U.S. faced a similar threat in 2007 when one 

nuclear plant was partially closed and several others were threatened by drought-induced water 

shortages. “Water is the nuclear industry”s Achilles heel,” says Jim Warren, executive director 

of the North Carolina Waste Awareness and Reduction Network. Nuclear plant closures in the 

southeastern U.S. would have adverse impacts on businesses due to the higher cost of 

replacement power. “Currently, nuclear power costs between $5 to $7 to produce a megawatt 

hour,” says Daniele Seitz, an energy analyst with New York-based Dahlman Rose & Co. “It 

would cost 10 times that amount if you had to buy replacement power – especially during the 

summer.” (REF xii) (0067-6 [Geiger, Carol])

Response: This comment discusses potential economic problems related to plant closures if 

the proposed CPNPP Units 3 and 4 were to be shut down as a result of drought conditions. 

Operations-related impacts as an environmental consideration (ecological, biological, and 

economic) are discussed in the EIS in Sections 5.2 (Water-Related Impacts), 5.3.2 Aquatic and 

Wetlands Impacts), 5.4.4.4 (Public Services—Water and Wastewater subsection), and 5.5.1.2 

(Water Pathway—for Environmental Justice considerations). Operations-related shortage 

issues are a safety concern and are covered thoroughly in the Safety Report. Since these 

comments provided no new information or identified any area of omission in the EIS, the review 

team did not revise the EIS because of these comments. 

Comment: Constellation Energy just withdrew their license application for a Maryland nuclear 

reactor due to high costs. Luminant’s parent company, Energy Future Holdings, has been 
Appendix E 

May 2011 E-121 NUREG-1943 

struggling financially, and shouldn’t even consider taking on extensive additional debt, which will 

likely result in skyrocketing electric bills and could result in the collapse of the company. (0071-

14 [Hadden, Karen])

Response: This comment discusses concerns about the potential rate increases that may 

occur if the proposed CPNPP Units 3 and 4 were to be constructed and operated. The purpose 

of the EIS is to disclose the potential environmental impacts of constructing and operating the 

proposed Units 2 and 3. Setting retail power rates in the context of a deregulated wholesale 

market is outside NRC's regulatory purview Because of the dynamic nature of the rate-setting 

process, including the uncertainty as to how any increase would be distributed between 

residential, commercial, and industrial customers, analyzing the likelihood and magnitude of 

future rate changes (if any) would entail undue speculation by the NRC Staff. The EIS was not 

modified as a result of these comments. 

Comment: By contrast to the wind, you know, that's on the increase in Texas, nuclear power is 

currently generating twelve-and-a-half percent of our power. One of the reactors went down in 

August at South Texas Project and no one even noticed it, 350 megawatts off 136 the grid one 

day. No one even blinked. We have a 21 percent reserve margin. ERCOT says we don't need 

and the economy does not support new coal or nuclear reactors at this point in time. That is 

their latest study. Why would anyone want to invest in that at this point in time? Who is going to 

buy the most expensive power on the market? There's not going to be buyers. And the cost to 

rate payers is going to go through the roof. (0063-30-12 [Hadden, Karen])

Comment: The Electric Reliability Council of Texas (ERCOT) 2009 State of the Market report 

says “Estimated net revenues for nuclear and coal resources were also insufficient to support 

new entry in 2009.” (0071-15 [Hadden, Karen])

Response: These comments state that current conditions in ERCOT do not justify building new 

Nuclear generating capacity and cites an ERCOT public report/statement to that effect. The 

2009 State of the Market Report was produced by Potomac Economics Ltd and was not a policy 

statement of the ERCOT Board. It referred to market conditions in 2009. The data in chapter 8, 

while not addressing the same issues as the Market Report, are focused on the period of 2014-

2024. Chapter 8 reports a reserve margin similar to the Market Report for 2010 but a quite low 

reserve margin for 2024. The conclusions of this chapter were not changed in response to this 

comment. 

Comment: As shown by Table 8-1, the DEIS published in August 2010, finds the analysis 

performed by Luminant assumed a peak electricity demand of 86, 803 MWs would be needed in 

2024, while the peak demand found in the DEIS based on 2009 analysis was significantly less, 

about 81,000 MWs. Thus even since the original application, the expected demand in Texas 

has been forecasted to be much less than expected just two years ago. Even with these lower 

projection within ERCOT, however, the DEIS overemphasizes the need for power and 

underestimates the expected savings from energy efficiency programs at utilities as well as 

savings from weatherization, demand response programs and new building codes. Thus, if 

these additional factors are considered, the additional 3200 MWs of the proposed two units are 

not needed, either for Texas as a whole or the North Central Texas region. (0052-1 [Reed, 

Cyrus])

Comment: [T]he analysis contained in the DEIS fails to account for three recent regulatory or 

legal changes that should reduce both load and peak demand in Texas substantially in the 

coming years: The June of 2010 decision by the State Energy Conservation Office to raise the 

minimum energy code from 2001 to 2009 standards beginning in April of 2011, which will lower 

overall energy use in new homes and buildings (0052-3 [Reed, Cyrus])
Appendix E 

NUREG-1943 E-122 May 2011 

Comment: [the analysis contained in the DEIS fails to account for three recent regulatory or 

legal changes that should reduce both load and peak demand in Texas substantially in the 

coming years:] The August of 2010 decision by the PUC to raise the energy efficiency goals of 

the nine Investor-owned Utilities, including ONCOR, from 20 to 30 percent of growth in demand

(0052-4 [Reed, Cyrus])

Comment: [the analysis contained in the DEIS fails to account for three recent regulatory or 

legal changes that should reduce both load and peak demand in Texas substantially in the 

coming years:] The spending of nearly $800 million between 2009 and 2012 as part of the 

American Recovery and Renewal Act, which includes some $300 million in weatherization 

monies, some $300 million in energy efficiency and onsite renewable projects in public 

buildings, and an additional $200 million in block grants to cities for energy efficiency. The 

analysis should reflect the expected declines in demand from these [three] changes. (0052-5

[Reed, Cyrus]) 

Comment: Finally, ERCOT's analysis relied upon in the DEIS fails to consider the additional 

capacity that is coming on-line in wind generation, --some 8,000 MWs of additional wind in the 

coming years -- and underestimates the capacity factor of wind in Texas, (0052-7 [Reed, Cyrus])

Comment: Luminant does not actually need to build two new units at Comanche Peak 

because load growth will not grow as much as even ERCOT estimated in 2009, it does not 

reflect recent changes to building codes, the use of the ARRA monies and the updated goals for 

utilities to meet demand through energy efficiency. It also fails to consider the expanded use of 

wind in Texas. (0052-9 [Reed, Cyrus])

Comment: Let me talk about the need for power. Let me first say that in Texas we don't 

require -- unlike some other states, we don't require generators of electricity to prove they need 

the plant in our deregulated market. That might be true for some other areas of Texas but 

within ERCOT we don't require them to do that. So this public assessment is very important 

because it may be our only public chance to look at do we need 3,200 megawatts into the future 

in Texas base-load from this plant. Let me say that as pointed out in the DEIS, the applicant 

used some numbers from ERCOT, who's our grid operator, from 2007, which is the data they 

had at the time. This application -- this DEIS uses 2009 data. And let me tell you, from two 

years, from 2007 to 2009 the guesstimate of what we need in Texas within ERCOT was 

reduced by 5,800 megawatts. Just two years ERCOT looking at data, their guesstimate went 

down by 5,800 megawatts. Just in two years. That shows how quickly the energy markets can 

change. And I think that's important. (0063-18-1 [Reed, Cyrus])

Comment: [T]his year the Public Utility Commission raised the energy efficiency goals that 

companies like Encore, the wireless company, must meet into the future. The goal has been 

raised from 20 percent of growth and demand to 30 percent of growth and demand by 2013. 

That should reduce the need for power. That should reflect in your DEIS. I don't know if it 

changes your conclusion. But we'd like your DEIS to reflect that. (0063-18-2 [Reed, Cyrus])

Comment: [I]n June of this year the State Energy Conservation Office said, All jurisdictions in 

Texas by the end of 2011 must update their building codes for new construction. They must 

adopt what's called -- this gets technical. But the 2009 IETC codes for all construction and for 

single-family homes in 2009 international residential codes energy chapter. Many cities already 

have those codes. But many places do not. That should reduce slightly the demand in Texas 

from new buildings, new homes and new commercial buildings. That should be reflected that 

we're going to have those changes within Texas. (0063-18-3 [Reed, Cyrus])
Appendix E 

May 2011 E-123 NUREG-1943 

Comment: Another fact, whether you agree with it or not, there were about -- there are about 

$800 million being spent from the Stimulus Funds, specifically on weatherization, efficiency of 

public buildings, onsite renewable power. We feel like the reduction demand should be 

reflected from those programs. That's a lot of money to spend between 2009 and 2012. 

Whether you think it was a good idea or a bad idea it will reduce overall energy needs. (0063-

18-4 [Reed, Cyrus])

Comment: AP, Encore have all started solar -- small solar rebate programs that again, should 

reduce demand slightly in these areas. So I'm saying demand is not going to be as high as you 

say it will be. (0063-18-5 [Reed, Cyrus])

Comment: The other thing we seriously object to is in this analysis you used a study of 

ERCOT that suggested for reliability we should use wind capacity at 8.7 percent. So the 

capacity of the wind at peak times. If we look at the reality of what's actually happened on the 

grid in these years, even at peak times when capacity is much greater and overall, obviously it's 

much greater. (0063-18-6 [Reed, Cyrus])

Comment: So I'm here to represent them and say 25 percent rate increase is what we last 

experienced. If you look at the economic environmental impact it may be great news for the 

people of Somervell County. But it is bad news for everybody else, many of whom are captive 

in a system that is not truly a competitive electric system. In the deregulation process we 

changed a fundamental rule. We had what was called CWIP, Construction Work in Progress. 

And I do not believe the change in the political environment in Texas that radically favors the 

industry over the consumer since the last project was started was even taken into consideration. 

So I feel like a lot of the economic analysis if fundamentally flawed. (0063-5-2 [Burnam, Lon])

Comment: While we have a variety of concerns about the proposed expansion of the plant and 

the draft environmental impact study, we are most concerned about the actual need for the 

power itself and alternatives --whether 3200 MWs of power will be needed by the time the plant 

would be built (0066-1 [Reed, Cyrus])

Comment: The analysis also fails to take into account an expected rule change presented as a 

strawman by the PUC earlier this year to implement a provision of Texas law which would 

require some 500 MWs of renewable energy other than wind to be developed by 2015. While it 

is still too early to predict whether this rulemaking will go forward -PUC has indicated it could 

propose a rule later this year or in early 2011, the final EIS should at least analyze the impact of 

this change in the ERCOT market. (0066-12 [Reed, Cyrus])

Comment: [W]e now have three announced utility-scale solar plants announced in Texas, 

including the Austin Energy Webberville project and two announced plants being pursued by 

CPS Energy. While these projects are relatively small -30 or 14 MWs as opposed to 3,200 

MWs -they point to the potential to replace a large project with several smaller-scale flexible 

projects throughout Texas. As mentioned, both Austin Energy and CPS Energy have made 

long-term commitments to obtain hundreds of Megawatts of electricity from solar over the next 

10 years. (0066-13 [Reed, Cyrus])

Comment: In addition to the utility-scale announcements, Texas has begun to install onsite 

photovoltaic solar production. Thus, while still a tiny part of the market -perhaps 5 to 10 MW s 

currently -a series of announcements in San Antonio, Austin and especially the Oncor Service 

territory suggest that onsite solar will lead to further reduction in demand for power from the 

proposed plant. Thus, earlier this year, SolarCily, a California company, announced a 

partnership in the Oncor Service Territory. Under this partnership, SolarCity will build solar 
Appendix E 

NUREG-1943 E-124 May 2011 

installations on homes in return for the ONCOR solar rebate and then charge homes only $35 

per month. (0066-14 [Reed, Cyrus])

Comment: We believe that the demand analysis contained in the DEIS seriously 

underestimates the reduction in demands and additional resources that will be arriving from 

energy efficiency, demand response, advanced meters, onsite solar and large-scale renewables 

resources like wind and solar. In fact, we believe the need for a large 3200 MW baseload plant 

for hire is questionable at best. (0066-3 [Reed, Cyrus])

Comment: [there is missing text here in the original comment] it should reduce energy use 

from new buildings by 10 to 15% according to the independent analysis done in September of 

2009 by the Energy Systems Laboratory. Only in the last year, Austin, El Paso, College Station 

and Laredo among others have adopted the 2009 IEec as their base code, in some cases with 

local amendments that make the codes stricter for new construction. This week, delegates at 

the International Code Council will he approving a new version of the IECC codes -the 2012 

Codes -and it should be expected that codes will continue to get more stringent in terms of 

energy use in new buildings. (0066-5 [Reed, Cyrus])

Comment: [I]n August of 2010, the Public Utility Commission approved new rules for the 

Energy Efficiency Program, which currently requires the seven Transmission and Distribution 

Companies to meet at least 20 percent of the average growth in peak demand -as well as a 

corresponding energy goal-in 2010. The new rules will raise that goal to 25% in 2012 and 30% 

in 2013 and thereafter. Again, while not a huge factor, the approved rules should drive more 

money into reducing both peak demand and overall energy use. An independent analysis 

attached suggests that these rule changes will not have major impacts on the programs through 

2014, but afterwards, as energy demand grows, they could become major drivers to reduce 

demand in Texas. The NRC should consider the impact of this rulemaking on overall demand in 

Texas. (0066-6 [Reed, Cyrus])

Comment: The third major change in Texas involves the spending of nearly $800 million in 

weatherization, energy efficiency and conservation block grants and programs run by the State 

Energy Conservation Office as part of funding provided by the American Recovery and Renewal 

Act (ARRA). (0066-7 [Reed, Cyrus])

Comment: In addition to these changes in the competitive energy market, several other factors 

within municipalities in Texas may also impact overall energy demand, meaning the need for 

such power plants as the proposed Comanche Peak units will shrink. Thus, there is no 

discussion about CPS Energy laudatory plan to reduce peak demand by 771 MWs by 2020, 

there is no attempt to assess how this would impact overall demand or the need for baseload 

power in the state as a whole. Thus, CPS Energy itself recently discovered that the 

combination of reduced demand, energy efficiency goals and increasing investments in 

renewable energy had made its initial plan to buy 1,200 MWs of power from nuclear plants 

unnecessary (0066-9 [Reed, Cyrus])

Comment: Luminant has not proven there is a need for this new energy. 

 The application ignores the effect energy efficiency and renewable energy will have in the 

future. Are recent state-mandated energy efficiency and renewable energy goals be 

factored into the energy needs assessment? 

 Studies have shown that Dallas/Ft. Worth could meet 101% of projected growth indemand 

using efficiency and renewable energy. 

 State energy use projections should be revisited in light of the economic downturn. (0071-39

[Hadden, Karen])
Appendix E 

May 2011 E-125 NUREG-1943 

Response: These comments challenge the review team’s need for power determination or its 

methodology and assumptions in a number of categories that pertain to updating the data in the 

chapter, taking into account various conservation initiatives, and taking into account the 

potential growth of wind power. Chapter 8 of the NRC’s NUREG-1555, Environmental Standard 

Review Plan (ESRP) (NRC 2000) guided the Staff’s review and analysis of the need for power 

from the proposed nuclear power plant. This guidance states that when forecasts and analyses, 

such as those by ERCOT, can be determined to be systematic, comprehensive, subject to 

confirmation, and responsive to forecasting uncertainty then the analysis is acceptable and 

need not be subject to further review by NRC. The NRC Staff determined that the ERCOT data, 

forecasts and analyses meet these criteria. Consequently, the review team relied upon the 

decision made by the Electric Reliability Council of Texas (ERCOT). Implicit in the NUREG 

1555 methodology is the acceptance of all underlying assumptions made by ERCOT, including 

all assumptions about future technology mixes, capacities, and implementation levels for 

voluntary programs such as Energy Efficiency (EE) and Demand Side Management (DSM). 

Moreover, NRC does not supplant or replace the determination of the States, which have 

traditionally been responsible for assessing the need for power generating facilities, their 

economic feasibility and for regulating rates and services. Finally, as ERCOT revises its 

analyses and the underlying assumptions that drive them, the NRC Staff assesses whether or 

not such changes need to be incorporated into the EIS Chapter 8 need for power analysis. As a 

result of updates to the ERCOT forecasts, data, and analyses, substantial revisions were made 

to the need for power analysis to incorporate the latest ERCOT data. In response to comments, 

the NRC Review team also added three scenarios to the chapter. These scenarios are not 

intended to replace the ERCOT forecasts, data and analyses, but rather to illustrate the degree 

of robustness of the ERCOT information. The scenarios considered an increase in energy 

savings due to conservation, a doubling of wind generation capacity, and the retirement of 

generating capacity greater than fifty years of age. As would be expected, additional wind 

capacity and additional conservation decreased the need for power and earlier retirements 

increased the need for power, but none affected Staff’s conclusons. No changes to the 

chapter’s conclusions resulted from the scenario analysis. 

E.2.20 Comments Concerning Alternatives - Energy 

Comment: We must move beyond the cheap energy solutions - BP nearly destroyed the Gulf 

and it's way of life with shortcuts. (0001-6 [Boyd, John])

Comment: Please, please, don't go this direction to meet our needs for power. Invest in 

energy that is truly clean and renewable, and does not pose the long list of problems that 

nuclear does. -- The best way to have an impact on the environment is to have as little impact 

as possible. (0031-1 [Eatenson, Linda])

Comment: It is not a solution to energy independence. (0063-30-8 [Hadden, Karen])

Comment: [F]airly compare this with all alternative sources of power (0063-32-10 [Rooke, Molly])

Comment: [T]he Lone Star Chapter believes given its high cost, inflexibility and lengthy 

implementation schedule, Texas would be better served by developing smaller, more flexible, 

cheaper alternatives like on and off-site solar, additional natural gas plants, energy efficiency, 

coastal wind, energy storage and geothermal resources. (0066-15 [Reed, Cyrus])

Response: The NRC and the Corps do not establish energy policy for the Federal government 

nor do they promote any particular form of electrical energy generation, including nuclear 

power. However, the review team examined alternative energy sources that could provide the 

baseload electrical energy supply as part of its responsibilities to evaluate environmental 
Appendix E 

NUREG-1943 E-126 May 2011 

impacts of proposed actions. The review team's evaluation of renewable alternative energy 

sources, including wind, solar and other alternatives, in Section 9.2 of the EIS describes 

potential impacts from these sources in comparison with the proposed action. The review team 

concluded that individual renewable technologies did not represent reasonable alternatives to a 

large baseload power plant located at the Comanche peak site. No change was made to the 

EIS as a result of these comments. 

Comment: The DEIS correctly assumes that building new nuclear units is not the only option 

available to Luminant. However, the DEIS concludes that it is reasonable for Luminant to 

choice to pursue a 3200 MW nuclear facility, rather than a combination of available resources. 

Thus, the DEIS notes that a recent study in Texas concluded that ERCOT could incorporate 

between 18,000 and 24,000 MWs of wind from West Texas once transmission lines are 

complete, but discounts the potential for these added wind resources to be able to replace the 

resources for a new nuclear plant. (0052-10 [Reed, Cyrus])

Comment: Let me just say on the alternatives chapter I appreciate it's a big improvement over 

what Luminant had submitted, in terms of the alternatives. But again, we feel like it discounts 

the capacity of wind. We're building -- and some people don't like these transmission lines -- 

but we're going to build out to west Texas. We're talking about eight to 10,000 megawatts of 

additional power from west Texas from wind that Luminant has invested in and certainly could 

invest in some more. We think that meets -- we'll be providing some data on why we think the 

numbers will be bigger than you say they are in the DEIS. (0063-18-9 [Reed, Cyrus])

Comment: Wind power is Texas' most impressive victory that we've had in years. We have 

had now 25 percent of the energy up and turning, the energy that's on the ERCOT grid, coming 

from wind. Twenty-five percent was an all time high. It's a major success story. We're learning 

how to do it. We're learning how to deal with the intermittent sea of wind. We're learning more 

about energy storage. We're learning more about solar. And we're learning how to bring those 

costs down. And Luminant admits that these technologies are viable. In fact, the Atomic Safety 

and Licensing Board panel has accepted a contention submitted by our organization and others 

and a legal challenge that is about this very issue. Can't we use other ways to generate that 

electricity? And we say absolutely yes. (0063-30-11 [Hadden, Karen])

Comment: While the previous sections discussed why the need for the new nuclear plants are 

overstated in the EIS, we would also note that even if additional power is needed, Luminant has 

other options besides the nuclear plant to meet those needs and compete for share in the 

market. Indeed, the EIS admits as much, and presents several alternative scenarios for 

Luminant to build out 3200 MWs of power. 

One such scenario -replacing the nuke investments with wind power -is discounted by the EIS 

even though ERCOT is incorporating at least 18,000 MWs of power from West Texas, even as 

wind from East Texas along the coast is being developed as well. Thus, the analysis seems to 

discount the potential for a combination of east Texas and West Texas wind to do away with the 

need for the nuclear power plant even as other utilities like Austin Energy and CPS Energy are 

making large-scale investments in wind power even as they decide not to make major 

investments in nuclear energy. (0066-10 [Reed, Cyrus])

Response: These comments are related to the level of analysis the EIS provided with respect 

to wind energy and a combination of energies including wind as a component as an alternative 

to building and operating Comanche Peak Units 3 and 4. Alternatives requiring new generation 

capacity are described in Section 9.2 of the EIS. The EIS includes a thorough and accurate 

analysis of the energy sources that can meet the purpose and need for the project; a more 

detailed analysis of the available wind resources in the ERCOT region was considered 
Appendix E 

May 2011 E-127 NUREG-1943 

recognizing that such resources are currently being developed. However, while there are 

significant wind resource potential in the region, ERCOT still acknowledges that significant new 

baseload energy sources are needed to meet anticipated future power demands and reserve 

margins. In ERCOT’s high wind generation case, this baseload power is provided by 2724 MW 

of new baseload nuclear power and more than 3000 MW of new gas turbines. These insights 

were considered in defining the reasonable set of energy alternatives discussed in Section 9.2. 

No changes were made to the EIS as a result of these comments. 

Comment: In addition, while recognizing the vast solar potential throughout Texas, again the 

DEIS concludes that solar technology can not be part of an alternative approach because 3200 

MWs are simply not available and the amount of land needed to provide an equivalent amount 

of land would be too large. It should be noted that the analysis was based on some recent 

proposed plants in California for solar, but did not account for more recent developments in 

solar PV utility-scale plants. (0052-11 [Reed, Cyrus])

Comment: In addition, the analysis fails to consider that solar could be an available option for 

Luminant, since the land needed to generate a similar amount of power would be vast. 

However, again the analysis is based on available California plants and does not take into 

account more recent developments in both concentrated solar plants and PV plants that are 

currently being developed that are much more efficient in terms of power generated per acre of 

land. (0066-11 [Reed, Cyrus])

Response: The comments are related to the level of analysis the EIS provided with respect to 

solar energy as an individual energy alternative to building and operating Comanche Peak Units 

3 and 4. The DEIS includes an analysis of the available solar resources in the ERCOT region. 

ERCOT states that the region has a solar generation capacity of up to 4600 MW(e). However, 

the Solar Energy Industries Association (SEIA) currently list only 16 MW of utility-scale 

concentrating solar plants (CSP) and photovoltaic (PV) plants under construction in Texas and 

less than 450 MW(e) under development (SEIA 2010) and development of these resources 

would have a significant impact on land use. The review team does not believe that even full 

development of the region’s solar generation capacity would provide a reasonable alternative to 

baseload power provided by Comanche Peak Units 3 and 4. Nevertheless, the review team 

does consider that solar energy, in combination with other energy sources is a reasonable 

alternative; that analysis is provided in Section 9.2.4. The review team concluded that a 

combination of alternatives including solar resources would not be environmentally preferable to 

the proposed new nuclear units. The EIS did not changes as a result of these comments.

Comment: While the DEIS suggests several scenarios where a combination of wind, energy 

storage, solar and natural gas could replace the need for a new 3200 MW new nuclear plant, it 

sees no benefit in pursuing this strategy compared with the nuclear option. But such a 

combination approach would be more beneficial to Texas consumers and the environment. 

(0052-12 [Reed, Cyrus])

Comment: Recent analysis find that while the projected cost of nuclear power continues to 

climb, the cost of wind and solar continues to fall, while natural gas prices continue to remain 

low. Thus, by pursuing a flexible combination of other options, Luminant would not be locked 

into an inflexible, costly solution to Texas's power needs, and could also better operate a fleet of 

resources to respond to both average load and peak demand. (0052-16 [Reed, Cyrus])

Comment: And it is the most expensive way to generate electricity. Who says so? The 

Federal Energy Regulatory Commission among others. Comanche Peak 1 and 2 were the most 

expensive nuclear reactors built in the country. And the reactor design now chosen to be built is 
Appendix E 

NUREG-1943 E-128 May 2011 

one that has never been built anywhere in the world. There are similar ones but this design has 

never been built. (0063-30-7 [Hadden, Karen])

Comment: Texas is more likely to need flexible, smaller plants to meet energy needs at peak 

times, as well as a combination of energy storage and renewable energy and existing plants -

such as those provided by natural gas --to meet baseload. Interestingly, the applicant, 

Luminant, is indeed involved in and exploring options like energy storage and large-scale 

renewables, while the other companies owned by Energy Future Holdings, Oncor and TXU 

Energy -while not generation companies -have been actively involved in designing and 

implementing onsite solar and energy efficiency programs for their customers. (0066-4 [Reed, 

Cyrus])

Comment: we also question whether the cost of replacement power at peak during hot 

summer months, if curtailed, would be economical. We would argue that consideration of other 

alternatives such as energy efficiency, renewable energy with storage, or natural gas might be 

less risky and less costly than building a nuclear power plant that is too hot to cool. (0067-10

[Geiger, Carol])

Comment: We think you discount with the capability of renewable storage. We appreciate that 

you looked to the combination approach. And our argument would be a combination approach, 

a natural -- if you really did need that amount of power, a natural gas plant combined with solar 

and wind and storage would make more sense. Why? Because it's more flexible. You're not 

putting all of your chips, all of your money into one technology, into one huge centralized plant. 

You have more flexibility. If we really need 3,200 megawatts of power I'm the first to say let's do 

it. But we don't really know we need to invest 22 billion to make -- to do that today, that we 

might need that power in 15 years from now. So it seems like having a combination approach 

chunk by chunk, little by little, being flexible would be better environmentally, it wouldn't have 

the water impacts, it wouldn't have the radioactive waste impacts. And that's the approach we 

would prefer. (0063-18-10 [Reed, Cyrus])

Comment: In addition, by combining wind, solar and natural gas, Luminant could run the 

natural gas units when the sun wasn't shining or the wind wasn’t blowing or when natural gas 

prices were low. (0052-14 [Reed, Cyrus])

Comment: [While we have a variety of concerns about the proposed expansion of the plant 

and the draft environmental impact study, we are most concerned about] the lack of analysis to 

alternatives to the proposed plant itself (0066-2 [Reed, Cyrus])

Comment: rather than having to sink major resources into building two large, centralized 

facilities that might not even be needed and have no flexibility, Luminant could build up 

resources over time as they are needed. (0052-13 [Reed, Cyrus])

Comment: The failure of Luminant to analyze cleaner, cheaper and safer energy alternatives in 

their license application is a glaring omission considering that Luminant and Shell are exploring 

compressed air energy storage. Texas has excess energy capacity, with a 21% reserve 

margin, where only a 12.5% reserve margin is required. Texas leads the nation in wind 

generation and has met our state goals for 2025 already. Solar costs are plummeting. Energy 

storage and cheap gas can be used to back up renewable solar and wind power. By contrast, 

the proposed reactors are a hazard to our health, safety and our pocketbooks. (0071-11

[Hadden, Karen])

Comment: [Nuclear energy/power] It's not a good alternative to coal. (0063-30-3 [Hadden, 

Karen]) 
Appendix E 

May 2011 E-129 NUREG-1943 

Response: As regulatory agencies, the NRC and the Corps do not establish or comment on 

public or private policy regarding electric power supply alternatives, nor do they promote the use 

of nuclear power as a preferred energy alternative. Decisions regarding the need for new 

generation capacity, the timing for additional electrical energy supplies and which of the 

electrical generation sources to deploy are made by the applicant through least-cost planning 

and integrated resource plans. Additional regulatory adjudication is provided by bodies such as 

State energy-planning agencies and public utility commissions. The review team considered 

alternatives to the proposed Comanche Peak Units 3 and 4 individually and in combination, that 

could be reasonably expected to meet the need for power (including baseload power needs) of 

the proposed project, individually and in combination, in order to meet their obligations under 

NEPA. In addition, the review team considered the No-Action alternative under which the 

proposed project would not be built. 

As described more fully in Section 9.2 of this EIS, the alternatives energy sources that are 

considered are not established arbitrarily. Specific criteria are considered in determining the 

reasonable set of new electrical generation alternatives. The alternatives that are to be 

considered must be technically reasonable and commercially viable. The energy technology 

should be developed, proven, and available in the region; pilot, demonstration, prototype, and 

research projects do not meet these criteria. The energy source should provide power 

generation equivalent to the power level output of the Applicant’s proposed project baseload 

power and capacity factor. The power should be available within the time frame needed for the 

proposed project. Finally, There should be no unusual environmental impacts or exceptional 

costs associated with the energy source that would make it impractical. 

Chapter 9 of the EIS includes individual electrical generation supply alternatives (including 

renewable energy such as wind and solar, with and without energy storage strategies), and a 

reasonable combination of alternatives that can meet the purpose and need. For the 

reasonable alternatives, the potential environmental impacts of each alternative are assessed 

against those of the proposed Units 3 and 4 for key resource areas. If either one of the 

alternatives or the combination of alternatives was environmentally preferable to the proposed 

action, then institutional factors, including economic impacts, would have been considered. 

While the review team identified reasonable alternatives to the proposed project, none of these 

alternatives was found to be environmentally preferable to the proposed project. No changes 

were made to the EIS as a result of these comments. 

Comment: the use of solar and wind facilities would, like nuclear, involve limited emissions 

associated with the manufacture of those products, but unlike nuclear, would not involve such 

large water use, nor the production of highly toxic and dangerous radioactive waste. (0052-15

[Reed, Cyrus])

Comment: And I want to speak against wind-powered sources of electric energy because they 

will stop the flow of wind across the surface of the earth, stopping the distribution of water, 

which will result in climate change, as you might well figure out. (0063-26-1 [Beard, Jim])

Comment: We don't have to worry about making -- we don't have to worry about our carbon 

footprint. The energy from the sun stored by the plant life on the earth is in the form of carbon 

storage. It's responsible for all the food that everything on the earth eats comes from plants. 

There is not an animal on the earth that can absorb energy from the sun and make food. All 

they do is consume food. So we need carbon dioxide to grow plants to have food for everything 

that's alive on the earth. Carbon dioxide is the food that all plants eat and they exhale the 

oxygen that we breathe to make us run. So this carbon footprint is an obstacle and it's totally 

false in terms of science as being a pollutant. So we don't want to throw away our gas power 

plants to make electricity. We don't want to throw away our coal power plants to make 
Appendix E 

NUREG-1943 E-130 May 2011 

electricity. We want to make those plants knuckle down and reduce the pollution they put out. 

And carbon dioxide is not one. They put out water and they put out carbon dioxide inert fluid 

gases. Everything else can be taken out scientifically so it's not a pollutant. So don't throw away 

gas plants, don't throw away coal plants, don't throw away nuclear plants. Make science make it 

cleaner. And don't believe anybody that says that carbon dioxide is a polluting gas and you 

need to worry about your carbon footprint. Because if you do away with the food of the plants on 

the earth then all you have left to store energy from the sun is water in the ocean. So oil, gas, 

all those are carbon stored energy sources from our sun. (0063-26-3 [Beard, Jim])

Comment: Are we making an investment in the wrong kind of technology to come up with a 

plant that we know is going to dump hundreds of millions of therms of increased temperature 

into a lake that already is 95 degrees in the summertime, into a climate that we know is going to 

warm up, into a climate that we know we're going to have less water coming through that 

system. Now, for us as a society that might have to depend on this plant to keep our lights on 

the hottest days of the summer it's a darned good question. For those of you who live on this 

land and are the people who have to fish here, the people who are depending on this for water 

supply and for recreation it's an incredibly important question for you to answer. And we don't 

think that the DEIS as currently written fairly and adequately analyzes this question. And it 

should. (0063-16-5 [Smith, Tom])

Response: Alternative actions such as the No-Action alternative (energy efficiency and 

demand-side management), new generation alternatives (including natural gas and coal), 

purchased electrical power, alternative technologies (including renewable energy sources such 

as wind and solar), and the combination of alternatives are considered in Chapter 9 of the 

EIS. These considerations include evaluations of the impacts to local water resource and waste 

generation. All reasonable baseload power options summarized in Table 9-5 were considered 

to have MODERATE impacts on waste resources. Therefore there is no preferred option based 

on this category alone. All options, other than the coal option, were determined to have SMALL 

waste management impacts. Therefore there is no preferred option based on this category 

alone. The bases for consideration of Units 3 and 4 as the preferred option involve the full suite 

of environmental resource areas, including air resources and greenhouse gases. No changes 

were made to the EIS as a result of these comments. 

E.2.21 Comments Concerning Alternatives - System Design 

Comment: I also believe that there are viable alternatives to the use of Lake Granbury water 

for the Comanche Peak Expansion Project, and I strongly encourage all concerned to pursue 

those alternatives. (0003-3 [Apple, Thomas])

Comment: [I would plead with] Luminant to seek other water alternatives. (0005-3 [Clark, Becky] 

[Frick, Terry] [Kelly-Elliott, Cathy] [Leach, Dan] [Rhodes, Bill] [Wayson, Jacqueline and Thomas] [Wayson, 

Thomas])

Comment: We want to voice our concern that 20 billion gal. of water yearly from Lake 

Granbury will be used to cool proposed towers 3 and 4 at the Comanche Peak in Glenrose. 

Lake Granbury as well as the entire Brazos River Basin will experience great stress by this 

action of BRA. Alternative methods need to be found to save Lake Granbury (0012-1 [Rollins, 

W.H.])

Comment: I agree that the expansion should occur but believe that the required cooling water 

should come from another source. Lake Granbury already provides its fair share! (0017-2

[Fitzgerald, C.C. (Fitz)])
Appendix E 

May 2011 E-131 NUREG-1943 

Comment: We encourage you to require the BRA to look elsewhere for the water needed for 

the nuclear power plant addition. (0024-3 [Quirk, Jim and Sharon])

Comment: Please do what you can to save our beloved lake and make them find another 

solution for finding a source of water for coolant. (0029-3 [Petry, Susan])

Comment: The water for cooling the additional reactors should come from elsewhere! (0034-4

[Fitzgerald, C.C. (Fitz)])

Comment: [Luminant should] Up your budget to include a new lake. (0037-7 [Moore, Jim])

Comment: Lake Granbury is too important to our area to not look for other sources for cooling 

water. (0038-6 [Lowrance, Cleo])

Comment: I don't believe trading a precious resource like the Brazos River and Lake Granbury 

is the best solution. There are many large and small ranchers, farmers, and other landowners 

around Comanche Peak that would probably love to have small reservoir lakes built on their 

property. Some of the water needed for the reactors could come from these lakes giving the 

landowners a nice lake and some additional income from selling their own water. Being located 

closer to the reactors should be a plus by requiring shorter pipelines. A network of small lakes 

would still not supply all their needs but it would surely reduce the need from Lake Granbury. 

Better large rainwater collection systems and storage and of course wells could also help. 

(0038-9 [Lowrance, Cleo])

Comment: Please, the communities that depend on the water levels of Lake Granbury cannot 

survive the proposed nuclear reactors to be added to the Glen Rose plant. Please do not allow 

these reactors to be added unless an alternate source for their required cooling is obtained. 

(0041-1 [Martin, Joe])

Comment: The Final EIS should not recommend approval unless alternate water sources can 

be identified and made available. (0043-2 [Veale, James])

Comment: Because of the proposed units 3 and 4 will be a long time energy source and we 

feel it should be feasible to build a pipeline to from Whitney to supply water for cooling the 

reactor coils. The water could be dispersed back into Lake Granbury then sent back down the 

Brazos. Lake Whitney is a Army Corps of Engineers lake and has no water front properties that 

would be affecting property values that will be costly for Hood County if the lake levels drop 

significantly, as we feel will be the case, property taxes will drop along with the lake levels and 

we need those funds to operate our county effectively. Please understand we need the units to 

be built for our economy but we also feel that this could be a "win win" situation for all involved. 

We ask you to PLEASE take this idea into consideration for the sake of our livelyhoods and our 

lake. (0047-1 [Fowler, John])

Comment: [LGWOA believes that other factors of consideration that have not been fully 

studied include] availability of other water resources such as Lake Whitney. (0051-10 [Jalbert, 

Ann] [Jalbert, Pete] [McHugh, Judy] [Williams, Joe] [Williams, Sue])

Comment: the Applicant has not developed a broad enough approach to the use of the Brazos 

River system as its sole source of the Makeup Water for the Nuclear Plant. Lake Whitney, with 

almost 10 times the capacity of Lake Granbury, should be considered as a source through a 

connecting pipeline to capture and recirculate the discharge from Units 3 & 4 in order to 

decrease the impact on our area. Shoreline development and salinity in Lake Whitney are not 

nearly as sensitive to fluctuations in lake level as they are in Lake Granbury and Possum 

Kingdom Lake. (0055-5 [Inge, Charles] [King, Arnold] [Rosenfeld, Joshua])
Appendix E 

NUREG-1943 E-132 May 2011 

Comment: I do not oppose the expansion per se, but I feel that the additional cooling water 

required should come from somewhere else. We already provide our fair share. (0062-7-2

[Williamson, Eileen])

Comment: That the applicant has not developed a broad enough approach to the use of the 

Brazos River system as its sole source of the makeup water for the nuclear plant. Lake 

Whitney, with almost ten times the capacity of Lake Granbury should be considered as a source 

through a connecting pipeline to capture and recirculate the discharge from units 3 and 4 in 

order to decrease the impact to our area. Shoreline development and salinity in Lake Whitney 

are not nearly as sensitive to fluctuation in lake level as they are in Lake Granbury and Possum 

Kingdom Lake. (0063-36-5 [Hackett, Ken])

Response: These comments suggest or propose alternate sources of cooling water for the 

proposed new nuclear units. Alternative surface water supplies are addressed in Section 

9.4.2.3 of this EIS. Groundwater is not a viable option. The use of either Possum Kingdom 

Lake (located approximately 50 miles from the Comanche Peak site) or Lake Whitney 

(approximately 25 miles away) would involve the withdrawal of water from the same Brazos 

River that feeds Lake Granbury; consequently, there does not appear to be an environmental 

preference with water supplied from either Possum Kingdom Lake or Lake Whitney. Other 

nearby surface water bodies would not be capable of supplying the quantities of water required. 

Because these comments offer no new or significant information about environmental impacts, 

they did not result in any changes to the EIS. 

Comment: It makes absolutely no sense to purposely do this to the Brazos River Basin. 

Luminant has many alternative ways to cool those towers. If they are allowed to do this, it will 

only be a few years until they will have to pursue other alternatives anyway, but by that time the 

economy of Hood County and Palo Pinto County (and several more down the river as well) will 

be devastated. (0011-4 [Williamson, William F. (Frank) and Eileen G.])

Comment: Believe that alternate cooling methods are available to the NRC. Please direct 

Luminant to per sue alternate sources of cooling other than using Brazos water. (0015-3

[Edinboro, Sr., Christopher])

Comment: We also know there are alternatives to the use of Lake Granbury, but they would 

not yield the revenue the BRA is anticipating. (0019-3 [McHugh, Judy])

Comment: Other alternatives [instead of water taken from Lake Granbury] must be used. 

(0023-4 [Hinterleiter, David])

Comment: I just want to let you know that as a resident of Lake Granbury, I am not against the 

Comanche Peak expansion project, just the taking of Lake Granbury water to cool it. There are 

alternate methods that can and should be looked into. (0035-2 [Sweeney, Lorrie])

Comment: Please help us put a stop to this and get them to use other options that will keep 

them from reducing the lake levels. (0045-4 [Jacobson, Jake])

Comment: I understand that you may be presented with some alternative solutions that will 

further reduce the impact of the proposed to the lake. (0057-4 [Keffer, James L.])

Comment: So in conclusion, we are not against the Comanche Peak expansion. What we 

would like to do is to take this back to the drawing board, take the water lines out of Lake 

Granbury, out of the Brazos River basin, and withdraw it from Lake Granbury. For 20 years we 

have supported the community -- Granbury, Hood County has supported Comanche Peak. 

Now it's Luminant's time to support the integrity of Lake Granbury and the Brazos River basin. 

You must not take our water. (0062-12-5 [Williams, Joe])
Appendix E 

May 2011 E-133 NUREG-1943 

Comment: We need to think more about the future of our children in terms of science and not 

in terms of water. The water can be solved. They could solve it. Luminant could solve it. It just 

costs more. Don't worry about loss of water because won't have a boat to fish in. We need 

water to grow plants to feed everything that's alive on this earth. (0063-26-4 [Beard, Jim])

Comment: Friends of the Brazos does not oppose the addition of the two new reactors at 

Comanche Peak. We do oppose the current plan to withdraw 75,000 acre- feet of Brazos water 

per year from Lake Granbury. It's our understanding that roughly 75 percent of this water will be 

lost to evaporation. It's also our understanding that a closed-cycle recirculating cooling system 

certainly is one good alternative that would result in the withdrawal of significantly less water. 

There may be other -- well be other, more cost-effective ways to reduce this loss of water. 

Whereas, alternative cooling methods may increase the cost, further withdrawals of the Brazos 

water, especially in drought areas would have devastating effects on the ecological health of the 

Brazos downstream from Lake Granbury. (0063-34-1 [Vaughn, Jane])

Comment: I understand that you will be presented -- you may be presented with some 

alternative solutions that will further reduce the impact of the proposed reactors to the lake. 

(0063-4-4 [Regas, Tori])

Response: These comments suggest or propose alternative methods for cooling the proposed 

new reactor units. Alternative heat dissipation systems are addressed in Section 9.4.1 of this 

EIS. None of the systems and/or designs that were evaluated were found to be environmentally 

preferable to the system design that is proposed for use at the Comanche Peak site. Because 

these comments did not offer any new or significant information about environmental impacts, 

they did not result in any changes to the EIS. 

Comment: PUMP THE HOT WATER BACK TO LAKE GRANBURY, OUGHT TO BE CHEAP, 

ITS YOUR ELECTRICITY (0044-1 [Lusty, C.P.])

Response: It is not evident what issue or concern is associated with the "hot water" mentioned 

by the commenter. As described in Section 3.2.2.2 of this EIS, the proposed cooling towers and 

blowdown treatment facility would operate under a permit from the State of Texas such that the 

water returned to Lake Granbury would not exceed a temperature of 93 degrees Fahrenheit. 

The economics of moving water to and from Lake Granbury are not of concern in the 

assessments in this EIS. No changes were made to the EIS as a result of this comment. 

Comment: please consider that there must be a plan to engineer the expansion of the plant so 

that we return at least 75% of the water back into Lake Granbury in order for our city to survive 

and continue to be a wonderful place to live and visit. (0004-2 [Drager, Judy])

Response: The data in Table 3-2 in this EIS indicate that approximately 40% of the water 

withdrawn from Lake Granbury during power operation of the proposed new units would be 

returned to the lake. This is possible due to the design of the wet mechanical draft cooling 

towers that are proposed for the two new nuclear units. One of the consequences of 

discharging larger quantities of water (such as the 75% mentioned in the comment), and thus 

reducing the evaporative cooling, would be to increase the temperature of the water being 

discharged. As stated in Section 3.2.2.1 in this EIS, the State of Texas specifies a limit of 93 

degrees Fahrenheit for the discharge limit into Lake Granbury. No changes were made to the 

EIS as a result of this comment. 

Comment: Reliant and their engineering partners can find better ways to manage their cooling 

needs without disrupting and or destroying our way of life. I am almost sure none of us are 

blessed with an engineering back ground however the available information on alternative 

cooling should be looked at more closely. When you know how other countries handle it you 
Appendix E 

NUREG-1943 E-134 May 2011 

can see where there is a will there is a way at relatively low cost. Please make yourselves 

aware of these alternatives and start asking questions to motivate Luminant to alter their design 

approach. It is not too late! See below from World Nuclear Association http://www.worldnuclear.org/info/cooling_power_plants_inf121.html : 2. Cooling to condense the steam and 

discharge surplus heat. The second function for water in such a power plant is to cool the 

system so as to condense the low-pressure steam and recycle it. As the steam in the internal 

circuit condenses back to water, the surplus (waste) heat which is removed from it needs to be 

discharged by transfer to the air or to a body of water. This is a major consideration in siting 

power plants, and in the UK siting study in 2009 all recommendations were for sites within 2 km 

of abundant water - sea or estuary. This cooling function to condense the steam may be done 

in one of three ways: (1) Direct or "once-through" cooling. If the power plant is next to the sea, 

a big river, or large inland water body it may be done simply by running a large amount of water 

through the condensers in a single pass and discharging it back into the sea, lake or river a few 

degrees warmer and without much loss from the amount withdrawn[5]. That is the 

simplest method. The water may be salt or fresh. Some small amount of evaporation will occur 

off site due to the water being a few degrees warmer. (2) Recirculating or indirect cooling. If 

the power plant does not have access to abundant water, cooling may be done by passing the 

steam through the condenser and then using a cooling tower, where an up draught of air 

through water droplets cools the water. Sometimes an on-site pond or canal may be sufficient 

for cooling the water. Normally the cooling is chiefly through evaporation, with simple heat 

transfer to the air being of less significance. The cooling tower evaporates up to 5% of the flow 

and the cooled water is then returned to the power plant's condenser. The 3 to 5% or so is 

effectively consumed, and must be continually replaced. This is the main type of recirculating or 

indirect cooling. (3) Dry cooling. A few power plants are cooled simply by air, without relying on 

the physics of evaporation. This may involve cooling towers with a closed circuit, or high forced 

draft air flow though a finned assembly like a car radiator (0036-3 [Murphy, Bill]) 

Response: Alternative heat dissipation systems are addressed in Section 9.4.1 of this EIS, 

which includes consideration of each of the three methods described in the comment. None of 

the systems and/or designs that were evaluated were found to be environmentally preferable to 

the system design that is proposed for use at the Comanche Peak site. Because this comment 

did not offer any new or significant information about environmental impacts, it did not result in 

any changes to the EIS. 

Comment: There is a potential solution that you may have to look at, though, if you decide to 

go through with this because you are going to bring down water. It is going to have an 

economic impact. And that is, how do you get other water in without taking over these existing 

natural systems. 

We know we don't have enough groundwater. We know the aquifers are not being replenished 

enough. You're not going to have enough surface water. Building another reservoir is not a 

feasible option. One of the things you might want to consider is looking into desalination 

systems. Now, we all know that the current desalination technologies that are on the 

marketplace are prohibitively expensive and they do have environmental impacts on their own. 

But there are new technologies that are emerging. And my company happens to be one on the 

forefront where they're bringing out solar desalination technologies. In other words, this is 

something where we can take salt water, take the salt out and make it useable. And you can 

build plants and you can pipe water in. And what we're talking about is a potential long-term 

solution, not only for this situation but for other situations in Texas and throughout the United 

States. (0063-13-4 [Yancey, Darren])
Appendix E 

May 2011 E-135 NUREG-1943 

Response: The commenter advocates desalination systems to provide water for cooling; 

however, the source of water near the Comanche Peak Nuclear Power Plant site requiring 

desalination is not evident. Alternative sources of cooling water are addressed in Section 

9.4.2.3 of this EIS. While desalination systems are a proven technology, the water available 

from Lake Granbury would not require any such desalination before it could be used for cooling 

purposes. No other viable source of cooling water has been identified that would require 

desalination. Because this comment did not offer any new or significant information about 

environmental impacts, it did not result in any changes to the EIS. 

Comment: An alternate disposal method for the accumulated salts [from the BDTF] could be 

underground injection which would require a Class I, non-hazardous Underground Injection 

Control (VIC) permitted well. EPA asks that NRC's consideration of an alternative treatment 

method of treatment be discussed in the FEIS. (0070-6 [Smith, Rhonda])

Response: The analyses in this EIS are based on the BDTF design put forth by the 

Applicant. The NRC has no approval authority over the Applicant's BDTF, for which a discharge 

permit will be required from the State of Texas. Nevertheless, the review team previously asked 

the Applicant about the option of deep-well injection for disposition of the salt wastes from the 

BDTF. In its response (see Luminant's RAI response letter dated March 5, 2010; Luminant 

Reference No. TXNB-10021; ML100710613), the Applicant stated that deep-well injection 

would not be a viable option due to the volume of waste being generated and the fact that pretreatment of the blowdown would most likely be required to make it suitable for deep-well 

injection in order to avoid clogging of the well screens. In addition, suspended solids would 

likely need to be removed and softening may be required due to the potential for the high 

hardness or high TDS to form unwanted scale on the well screens that could interfere with 

discharge. No changes were made to the EIS as a result of this comment. 

E.2.22 Comments Concerning Alternatives - Sites 

Comment: Please find another location for this progress in power production. (0030-3 [Martin, 

Joe])

Response: Luminant conducted an adequate site selection study and chose the proposed site 

at the Comanche Peak Nuclear Power Plant (CPNPP) for business reasons. Luminant and the 

NRC -- in its independent review, as documented in Chapter 9 of this EIS -- undertook a site-bysite comparison of alternative sites with the CPNPP site to determine if any of the alternative 

sites were environmentally preferable to the proposed site. The review process involved the 

two-part sequential test outlined in NUREG-1555 (NRC 2000). The NRC's review process used 

reconnaissance-level information to determine whether there were environmentally preferable 

sites among the alternative sites; however, none of the alternative sites proved to be 

environmentally preferable to the proposed CPNPP site. No change was made to the EIS as a 

result of the comment. 

Comment: An important aspect of the NRC environmental decision is whether there is an 

alternative site that would be “environmentally preferable or obviously superior to the proposed 

CPNPP site.” In Section 10.5, the NRC Staff concludes that no alternative site would meet 

either of these criteria. Perhaps, this conclusion would not hold if the staff gave consideration to 

the full impacts of a realistic BDTF design. The ultimate reason for the BDTF is the existing 

poor water quality of the Brazos River at Lake Granbury. A site with better existing water quality 

would not need a BDTF to meet water quality standards, and would not involve the BDTF 

impacts that are necessary at Comanche Peak. The staff should prepare an honest 

assessment of the impacts likely to result from operation of a realistic BDTF, followed by a 

reassessment of its conclusions about alternative sites. (0069-7 [McCold, Lance])
Appendix E 

NUREG-1943 E-136 May 2011 

Response: The review team's conclusions in Section 10.5 considered that a BDTF would not 

be required for water treatment at any of the three alternative sites considered. Thus, the 

impacts of the BDTF at the Comanche Peak site were adequately factored into the comparison 

between and among alternative sites. All resource areas are considered in the final weighing 

and balancing of environmental impacts. With regard to that portion of the comment about "a 

realistic BDTF," the independent evaluation in this EIS included consideration of the BDTF 

design offered by the Applicant, which was in sufficient detail for consideration by the review 

team. This ultimate design would require permit approval from the state of Texas before 

authorized to operate. If the Applicant's design is revised or altered significantly, then further 

consideration of the environmental impacts may be necessary. No changes were made to the 

EIS as a result of this comment. 

E.2.23 Comments Concerning Benefit-Cost Balance 

Comment: LGWOA believes that the short term gains such as temporary jobs and negligible 

tax revenues for Hood County will fall short of long term losses due to the impacts of low water 

levels for Lake Granbury and the surrounding community. (0051-13 [Jalbert, Ann] [Jalbert, Pete] 

[McHugh, Judy] [Williams, Joe] [Williams, Sue]) 

Comment: The undoubted short-and intermediate-term economic benefits to be derived from 

the employment, taxes and non-fossil fuel power generation associated with the development of 

nuclear generating plants need to be carefully weighed against the longer-term critical 

disadvantage of overtaxing our water resources. (0055-9 [Inge, Charles] [King, Arnold] [Rosenfeld, 

Joshua]) 

Comment: I think that Chapter 4 of this environmental impact study it talks about the economic 

impact. I think we build the units, the economic impact will be very great for this area, and then I 

do believe it would still have a minimal impact as the -- I think the impact study shows small to 

moderate impact on the environment. (0062-11-2 [Fuller, David])

Comment: The undoubted short-term and intermediate-term economic benefits to be derived 

from the employment, the taxes and non-fossil fuel power generation associated with the 

development of nuclear- generating plants needs to be carefully weighted against the longerterm critical disadvantage of overtaxing our water resources. (0063-36-9 [Hackett, Ken])

Response: These comments provide general opinions about the EIS but do not provide any 

specific errors or omissions that would require revising the EIS. The review team did not revise 

the EIS because of these comments. 

Comment: So I say to you, my neighbors in Granbury, there are a lot of questions that aren't 

being answered in this DEIS today. That's what we need to look at. What about the water? 

What about the health of your community and your children? Taxes and jobs can never replace 

that. (0063-29-8 [Benning, Rita]) 

Response: This comment suggests deficiencies in the EIS but does not identify specific errors 

or omissions that would lead to revisions of the EIS. Construction-related water issues can be 

found in Sections 4.2 (Water-Related Impacts), 4.3.2 (Aquatic Ecology and Wetlands Impacts 

Related to Construction and Preconstruction), 4.4.4.4 (Public Services—Water and Wastewater 

subsection), and 4.5.1.2 (Water Pathway—for Environmental Justice considerations). 

Operations-related water issues can be found in Sections 5.2 (Water-Related Impacts), 5.3.2 

Aquatic and Wetlands Impacts), 5.4.4.4 (Public Services—Water and Wastewater subsection), 

and 5.5.1.2 (Water Pathway—for Environmental Justice considerations). Construction-related 

health issues can be found in Section 4.8 (Nonradiological Health Impacts). Operations-related 

health issues can be found in Sections 5.8 (Nonradiological Health Impacts) and 5.9 
Appendix E 

May 2011 E-137 NUREG-1943 

(Radiological Impacts of Normal Operations). Construction- and operations-related taxes and 

jobs are discussed in the EIS in Sections 4.4.3 and 5.4.3, respectively. The review team did not 

revise the EIS because of this comment. 

Comment: Nuclear power is the most expensive way to generate electricity. According to the 

applicant, the proposed Comanche Peak reactors could reach $22 billion or more, roughly equal 

to the current budget shortfall for the entire state of Texas. This is before cost overruns from 

delays and construction problems and the added costs of radioactive waste disposal and 

decommissioning. Nuclear reactors don't make sense financially. (0071-12 [Hadden, Karen])

Comment: The two proposed Comanche Peak reactors could cost up to $22 billion according 

to Luminant’s own documents. This is before cost overruns. This amount could make 7.3 

million homes more energy efficient. Pursuing efficiency lowers bills, reduces electricity 

consumed, and creates local jobs. The existing Comanche Peak reactors ran ten times over 

budget and were years late coming online. What if this happened again? (0071-21 [Hadden, 

Karen])

Response: These comments discuss the magnitude of the construction cost for the proposed 

CPNPP Units 3 and 4. The costs associated with the construction and operation of the 

proposed CPNPP project, including construction and debt management, operations and 

maintenance, fuel costs, and decommissioning are discussed in Section 10.6 of the EIS. The 

review team determined there was no new information of any identification of an omission in this 

comment that would warrant revising the EIS. 

Comment: The Associated Press recently reported, Even companies that are finalists for 

federal loan guarantees, NRG Energy and Constellation Energy, announced recently that they 

have nearly stopped spending on their projects... Analysts say low natural gas prices are 

making the project uneconomic. NRG chief executive David Crane said he will not pursue the 

company's two-reactor project in South Texas if gas prices stay low, even if his project is offered 

a loan guarantee. Luminant and Energy Future Holdings should pay heed to these serious 

financial concerns. (0071-16 [Hadden, Karen]) 

Response: This comment discusses the uncertainty of the proposed CPNPP project in the 

context of competitiveness vis a vis other electricity generating technologies’ fuel prices. 

Competitiveness and profitability are not within the scope of the NRC’s authority and therefore 

the review team did not revise the EIS in response to this comment.

E.2.24 General Comments in Support of the Licensing Action 

Comment: I'm all for Comanche Peak adding on new reactors! (0037-2 [Moore, Jim])

Comment: I believe nuclear power is the best way to meet our energy needs for the future and 

would love to see the expansion at Comanche Peak. (0038-8 [Lowrance, Cleo])

Comment: I am in support of the Licensing Application for the two new reactors at Comanche 

Peak. I have lived and owned business's by the largest Nuclear plant in the United States Palo 

Verde, and I can state from experience that there was no Environmental Impact at all from this 

plants operation. (0046-1 [Robinson, Pennie])

Comment: I wish to express my support for the expansion at Comanche Peak Nuclear Power 

Plant. (0053-1 [Orcutt, David])

Comment: Undeniably, the future expansion of the nuclear plant will bring an economic boom 

to Granbury. We certainly support the efforts of Luminant as they undertake this massive 
Appendix E 

NUREG-1943 E-138 May 2011 

endeavor. The financial impact to the Granbury area will be extraordinary. (0054-1 [Garner, 

Todd])

Comment: Whereas, Luminant has announced its intention to develop a combined operating 

and licensing application for 2 new nuclear power units at Comanche Peak in the Glen Rose 

Independent School District, and 

Whereas, Comanche Peak and Luminant have been a good business neighbor, providing jobs, 

taxes and helping the community meet its needs, and 

Whereas, Texas officials have clearly stated the need for continued investment into electric 

generation to meet the growing population of our state, and 

Whereas, if constructed, the new facilities will provide many jobs during construction and 

hundreds of permanent jobs after the units are running, and 

Whereas, if constructed, the units will add millions of dollars in estimated spending to the 

Somervell County economy, and 

Whereas, if constructed, the new facilities would add significant value to the property tax value 

of Somervell County and the Glen Rose Independent School District, and 

Whereas, Luminant is consistently available to provide information and answer questions about 

the existing units and the proposed license application to the Glen Rose Independent School 

District Board of Trustees 

Now, therefore be it resolved, that the Board of Trustees of the Glen Rose Independent School 

District endorses the combined operating and licensing application for Luminant's proposed 

facilities, Comanche Peak Units 3 & 4, in Somervell County, (0056-1 [Rotan, G. Wayne])

Comment: Be it further resolved, that Board of Trustees of the Glen Rose Independent School 

District encourages Federal and State officials to move forward to grant appropriate licensing 

and permitting and approve Luminant Power's combined operating and licensing request 

application for Comanche Peak units 3 & 4, (0056-2 [Rotan, G. Wayne])

Comment: Yes, we need this expansion here for our future growth of Glen Rose and I might 

add also for the surrounding community. (0059-2 [Higgins, Larry C.])

Comment: As a Somervell Co resident & business owner I would like to express my support of 

the expansion of Comanche Peak. I believe it would be a Great benefit to our local economy 

and continue to be a clean & reliable source of energy for the State of Texas. (0060-1

[Hoodenpyle, Kelly])

Comment: So we very much support Luminant as it exists now, and we support the future of 

Luminant, and we look forward to the extended, expanded power station building an even 

stronger local economy, which in its turn will help us build an even stronger tourism industry. 

(0062-10-2 [Condy, Pat])

Comment: Based on past experiences with Luminant, the potential for student growth, and the 

current educational partnerships, we support expansion of Luminant with this project. (0062-13-3

[Mayfield, Ron])

Comment: I'm supporting the new units. I've been a proponent of nuclear power all my life; 

specifically these two units I believe will not only help the economy of this area but they're the 

most environmentally sound answer we got. I also believe Rafael Flores that we're going to 

continue studying the water issue so we will not impact the lake. I don't live on the lake, but I 
Appendix E 

May 2011 E-139 NUREG-1943 

live in a community that uses the lake, and I play a lot of golf, and we use that lake water to 

water the golf course. I also believe in Squaw Creek, Squaw Valley. (0062-17-1 [Bradley, Scott])

Comment: And in closing I'd like to say that plant is important, because America needs the 

energy. Nationwide we need energy, and we need it from all sources, whether it be nuclear or 

power or fossil fuel. We do have to operate those in a responsible manner regardless of 

whether they're at or how they're powered. And for those of us that are really ecologically 

minded, particular living in areas like the Metroplex, where we're anxious for things and change 

and improvements like electric cars -- and I was just looking at a commercial the other day on 

electric cars, and just think, if everyone in Fort Worth, or a great percentage, went out and 

bought one of these little electric cars, when they go home at night and they open that little door 

and plug it up, where's the electricity coming from? We've got to have it. (0062-19-4 [Sumners, 

Allen])

Comment: And I'll just say that I'm in support of this expansion of the power plant. I've been to 

Washington three times and visited with the Nuclear Regulatory Commission and talked to them 

at length about this expansion, and I hope that you'll issue the license and we'll go ahead with it. 

And I think we can all coexist here and figure out a way to make it work. (0062-2-2 [Rash, Andy])

Comment: I'm here today speaking in support of the Luminant license application and the 

clean energy that it will bring to North Texas. (0062-3-1 [Taylor, Kevin])

Comment: I'm here today to express the support of the Somervell County Water District for this 

project, as well as the Somervell -- Glen Rose ISD, but also I think you heard earlier today from 

the Glen Rose ISD superintendent, and you know that we have passed a resolution at the 

school in support of this application, and that's why I'm here today. (0062-3-3 [Taylor, Kevin])

Comment: If built, Units 3 and 4 would produce the largest economic development project in 

Texas history. (0062-4-2 [Griffin, Dwayne])

Comment: This plant has been a great neighbor to our community for over 25 years and a 

great steward of our environment. I look forward to many more years of working closely with 

Comanche Peak, and for these reasons I strongly support this expansion. (0062-4-4 [Griffin, 

Dwayne])

Comment: I just want to thank NRC for the outstanding work. We're excited, we want to wish 

you well, and I'm for the expansion. (0062-8-1 [Condy, Ymke])

Comment: And I do want to also stress that the economic impact is very, very important, not 

just for Somervell but for Hood County, and we do appreciate very much the NRC and how 

much you have carefully considered this, and I do want to support the expansion. (0062-9-3

[Jones, DeeDee])

Comment: First, let me say that I am in favor of the NRC granting the permit to go forward. 

(0063-11-1 [Smith, Hugh])

Comment: I don't understand about this worry about water. God is going to control that. They 

can -- He can shut down and we can have a drought. Every time I go to church after a drought I 

hear the congregation pray and thank God for the rain that we have received. Well, who started 

the drought? Everything is going to depend on our nature no matter what. We need to take 

care of it. And I am certain NRC is going to look at it from that point of view. I'm for the granting 

of the permit to go forward. (0063-11-5 [Smith, Hugh])

Comment: Undeniably, the future expansion of the nuclear plant will bring an economic boom 

to Granbury, as well as Somervell County. We certainly support the efforts of Luminant as they 
Appendix E 

NUREG-1943 E-140 May 2011 

undertake this massive endeavor. The financial impact to the Granbury area and other 

surrounding areas will be extraordinary. (0063-14-1 [Garner, Todd])

Comment: For the past 20 years the majority of the Granbury community and myself have 

supported the Comanche Peak Power Plant. We will continue to support the expansion but we 

need one slightly design change done on the expansion here. (0063-15-1 [Williams, Joe])

Comment: I'm here in support of Luminant's application and am happy to see that the draft has 

supported the application, as well. (0063-17-1 [Best, Darrell])

Comment: And I would like to add the Chamber would like to see this permit approved. (0063-

17-3 [Best, Darrell])

Comment: While our country is looking to decrease reliance on foreign energy sources Texas 

is also in need of safe, reliable energy. Our state is expecting a surge in electrical demand over 

the next 20 years. The current sources of electricity are not nearly enough to meet these future 

needs. In addition, Texas continues to experience strong population growth, all of whom need 

more electricity from everything from iphones to appliances to computers. We believe the best 

policy answer to these needs in Texas is nuclear power. In this case, the proposed expansion 

of Comanche Peak. It is clean, safe and reliable with a low environmental impact. (0063-19-1

[Stewart, Michael])

Comment: On May 19, 2008 the Glen Rose ISD Board of Trustees passed a resolution that 

endorsed the licensing application for Comanche Peak and the expansion with the addition of 

units 3 and 4. (0063-21-2 [Rotan, G. Wayne])

Comment: And on behalf of the Board of Trustees we support the licensing application for the 

addition of units 3 and 4. (0063-21-4 [Rotan, G. Wayne])

Comment: Speaking for myself as a local citizen and business owner and community leader, I 

welcome the proposed expansion and to boost our local economy that it promises to bring. 

(0063-22-3 [Phillips, Marilyn])

Comment: My company manages this building and we wouldn't be here and I wouldn't be here 

if it weren't for Comanche Peak and Luminant and all the people that work there. And I wanted 

to say when you're looking at all the needs -- and a lot of them are obvious like water -- you 

need to look at what we have here in this community and in north Texas in this region. And this 

is the perfect place to add these two reactors. And it couldn't come at a better time. (0063-27-1

[Dooley, Mike])

Comment: I believe it is a safe and effective way to make power. If I didn't, as I said earlier, I 

wouldn't be involved with it. And I support it and will continue to do so. (0063-35-3 [Underwood, 

Sid])

Comment: I'm for the application of unit 3 and 4. And I'll tell you why. Recently I was able to 

visit the plant. And I would challenge some of you that are concerned about safety or security 

or environmental interests to make a visit. The visit --First of all, they are number one 

concerned about safety at the plant. And second, I think, environmental. And the security -- be 

prepared to spend about 30 or 40 minutes trying to get into the plant. But that's good. You 

don't want to have a plant out there that is concerned with nuclear energy that isn't number one 

concerned a little bit about security or a lot about security. That is the same reason that we 

have the security that we do in this country at -- in airports, nuclear plants and other plants of 

interest that will attract some type of a threat. (0063-38-1 [English, Maurice])
Appendix E 

May 2011 E-141 NUREG-1943 

Comment: First of all, I think that when you apply or when this application is granted or if it is 

granted to Comanche Peak we hope to see a lot of economy will be a necessary of it many 

people have talked about. I'm not going to be redundant because I think most of the things I 

would say have been discussed. And as an educator -- a retired educator with over 50 years 

experience, I have witnessed a lot of experiences in life. I look forward to the application being 

granted. And I think not only for my generation, but the future generations a safe and reliable 

source of energy is very important to this country's welfare. (0063-38-2 [English, Maurice])

Comment: I've lived in Glen Rose since 1961. So I've seen Glen Rose when it was one of the 

poorest communities and the schools were one of the poorest community -- poorest schools in 

the state. And then I've seen it after the plant has been here. And I just think everything that it 

has provided has been such a wonderful impact for this city and this community. And I just -- I 

think actually, we were fortunate to be the place chosen for the new units. And I think it will not 

only provide jobs for people here, but all the surrounding communities. I think it will have such 

an impact on the local businesses, as well. So I just wanted to say we support you and we are 

glad to do whatever we can. (0063-6-2 [Miller, Pam])

Comment: You know, it's great that we've got a $22 billion infusion into our local economy. 

And I welcome that whole-heartedly. (0063-7-1 [Pratt, Rickie])

Comment: I am Commissioner James Barnard, Somervell County, Precinct 4. And I'm here in 

support of the Luminant permit. (0063-8-1 [Barnard, James])

Comment: Thank you. I'm in support of the permit. (0063-8-3 [Barnard, James])

Response: These comments express support for the addition of new reactor units at the 

Comanche Peak Nuclear Power Plant site. They do not provide any specific information 

relating to the environmental effects of the proposed. No change was made to the EIS as a 

result of these comments. 

E.2.25 General Comments in Support of Nuclear Power 

Comment: I fully support the expansion of nuclear power generation in the USA. (0015-1

[Edinboro, Sr., Christopher])

Comment: I'm all for nuclear power! (0037-1 [Moore, Jim])

Comment: Our country is in dire need of domestic energy sources -nuclear power is the best 

we have. It is a source of high-quality American jobs, and creates long-term power sources. 

(0053-2 [Orcutt, David])

Comment: Much of the opposition to the proposed expansion stems from mis-education about 

the risks of nuclear power, and even a desire to change our lifestyles to dramatically reduce 

energy consumption. This is mis-guided. Nuclear power is a clean and safe energy source, 

with a manageable and containable by-product that can be efficiently stored. Significant 

adoption of nuclear power for base-load energy would dramatically reduce the nation's carbon 

footprint. Whether or not we are successful at reducing energy consumption, nuclear power is 

an important part of whatever ratio of powers sources we use. (0053-4 [Orcutt, David])

Comment: We believe nuclear power is a responsible way to produce electricity, and an 

environmentally friendly way. (0062-5-1 [Flores, Rafael])

Comment: We also recognize the need for energy, and energy is something that all of us, 

whether we like it or not, have to have., and I think this is the safest way that I know that we can 
Appendix E 

NUREG-1943 E-142 May 2011 

have this energy, and it seems to me from what I've heard that this is the minimal impact. (0062-

9-2 [Jones, DeeDee])

Comment: Please, let's start thinking in terms of our future and our children and what they've 

got to have. We can get all of the gas we want until it runs out, just like our oil is going to run 

out. But there seems to be an endless supply of atoms. They work, folks. They work. (0063-

11-4 [Smith, Hugh])

Comment: Now, nuclear power can make clean, nonpolluting energy. And they can do it 

without water if they want to. So we don't have to give up our water to have clean nuclear 

energy. It just will cost more. (0063-26-2 [Beard, Jim])

Comment: I do support nuclear power. If I didn't support nuclear power I wouldn't work there. 

If I didn't think it was safe I wouldn't work there. If I didn't think it was safe I would not have 

helped rear three children in this area. So I do believe it's safe, as my friend, John Curtis, 

mentioned earlier. (0063-35-1 [Underwood, Sid])

Comment: I'm a proponent for nuclear electricity. I've found that it's fascinated me since I was 

a kid. (0063-7-2 [Pratt, Rickie])

Response: These comments provide general information in support of nuclear power. They do 

not provide any specific information relating to the environmental effects of the proposed action 

and will not be evaluated further in the EIS. 

E.2.26 General Comments in Support of the Existing Plant 

Comment: I believe the Comanche Peak Nuclear Power Plant is vital for our economic growth. 

It helps create jobs, housing, even growth in our schools. It also has a large impact on our 

business here in town. I personally know quite a few employees presently working at the power 

plant. I believe safety is their #1 priority in operating that facility. (0059-1 [Higgins, Larry C.])

Comment: we are a tourist operation and a tourist theme, one of the biggest in this region, and 

it's very important from a tourism-attraction point of view that a tourist venue is situated in a 

place where the local economy is vibrant. Where you have a tourist facility in an area where the 

local economy is poor and almost nonexistent, it's extremely hard to get tourists to come to your 

facility. And in that regard, Luminant up to this point in time has been a very powerful and very 

fine neighbor and impact on the local economy, which makes it so much easier for Fossil Rim, 

among other venues, to help make tourism a very vibrant tourism industry in this local area. 

And I'm not just talking about Glen Rose, but Granbury benefits very much from it; so does 

Cleburne and so does Stephenville. (0062-10-1 [Condy, Pat])

Comment: In our past history, Luminant's been a great supporter of Granbury ISD, and I 

believe there would be no reason not to support this expansion. We understand we may not 

see the kind of student growth that we experienced in the '80s, but we would anticipate that we 

would get our fair share. (0062-13-1 [Mayfield, Ron])

Comment: I've been a scoutmaster for many years, and part of the items that a scoutmaster is 

concerned about is the environment, and the environment around Comanche Peak has been 

kept excellent. We've been able to use the resources around Squaw Creek for some of our 

camping trips. The boys and their parents have enjoyed the fishing, the outdoors, and the 

whole area around the power plant, and I know the company has been a great environmental 

source to make sure that it stays that way. (0062-15-1 [LaMarca, Jeff])

Comment: I lived in the community for a number of years, and then I was gone, and then I've 

come back. And it's a beautiful community, and what that facility does for our community has 
Appendix E 

May 2011 E-143 NUREG-1943 

allowed many people to have a livelihood, students to get an education that is really superior to 

many places. I've lived in many small communities, and when there's not a place that can 

support them economically, it's difficult. So I'm in support of what you do for the community and 

for the young ones at Fossil Rim and for all of who need electricity. We have become too 

dependent on it, I think, but we need it. (0062-18-1 [McLay, Chandler])

Comment: we looked at all the statistics, everything that you could find, and all the good things 

there are in Somervell County. And of course there's a nuclear power plant here, and we knew 

that. And I'm not a nuclear expert, but my last several years in the Air Force I was in emergency 

management, and we dealt with quite a lot, in emergency, nuclear contingencies. But we 

moved here, we didn't have any concern with the safety. And when you look at a company like 

Luminant and their predecessor, or the name before that, TXU, they've run that plant for many, 

many years, and they run it very efficiently. And I'm proud to be here and be a neighbor in 

Somervell County. I'm very proud that we have a corporate neighbor such as Luminant. They 

are a fantastic corporate neighbor, and I can say that in comparison to other counties, when 

you've lived near something really nice and clean like a paper mill. Have y'all ever seen a paper 

mill? Man, I tell you, that's rough on the environment. (0062-19-1 [Sumners, Allen])

Comment: Also, taking into consideration concerns of safety and the many safety plans and 

contingencies that are in place, and I think Hood County and Somervell County have partnered 

with Luminant and their emergency preparedness people, have done an excellent job. And I 

feel very safe living here, and I'd ask that Luminant continue on to run that plan in the 

professional, efficient manner that they've always run it. (0062-19-2 [Sumners, Allen])

Comment: I was not here earlier in the day; I couldn't make it to the earlier session, but I'd like 

to say that, in working with Luminant through the years, they have been a very good neighbor to 

the community. I've lived here all my life, and I've seen Granbury develop from around a 

population of 5,000 in the county, which was pretty stagnant until the lake was built, and then 

Texas Utilities came in and built the power plant after building the dam and creating Lake 

Granbury and, within the next ten years after that lake filled, tripled to around 18,000, and since 

then it's more than tripled again. Population estimated 2009 was 51,600. I don't know what the 

Census is going to show, but I think it's going to be close to 55,000. 

Without the lake being built and the power plants coming in here and bringing people into the 

community, that gave us a start, and it brought a lot of other people into the community, and it's 

been very good for the economic development of the community. One other thing I'll say, as 

director of emergency operations for the county, we probably have the best emergency 

operations plan in the state of Texas, and it's largely due to working with the people from 

Luminant and them helping us with our emergency plans and making sure that we have a good 

plan where we can, if we were to have some issue with the power plant, which, God willing, we'll 

never have, we have a plan to take care of it. They've been good for the community; there's 

hundreds and hundreds of people integrated into the community that came to help build the 

power plant and stayed here. There's people here that work at the plant now for Luminant that 

are very much a part of this community, and they are as concerned about what's going on here 

as the rest of you are, because they are a part of the community, and they want to see it 

continue to be a thriving community. (0062-2-1 [Rash, Andy])

Comment: I've worked very closely over the years with Comanche Peak, especially their 

environmental groups. I have nothing but respect for those guys. They're very good at what 

they do. Luminant's been a good neighbor to the residents of Somervell County; we've 

managed to coexist for a number of years. I have no reason to believe that we wouldn't 

continue to coexist with the two proposed units. (0062-3-2 [Taylor, Kevin])
Appendix E 

NUREG-1943 E-144 May 2011 

Comment: Comanche Peak nuclear power plant has greatly improved the life of the citizens of 

Somervell County through the great school system, roads, hospital, and their continued support 

of this community as a whole. (0062-4-1 [Griffin, Dwayne])

Comment: I want to reiterate our consideration that Luminant -- and, of course, we always 

refer to it as TXU; I can't ever remember Luminant -- has been a very good neighbor to us for 

many, many years. I was a teacher in the school system here, and I want to say how much we 

have appreciated all the concern and help that we have had through the taxes, of course, in this 

county. Most of you know that this was a very, very poor county before the power plant moved 

to this area, and we have really benefitted from all these things that we have had here. (0062-9-

1 [Jones, DeeDee])

Comment: Bless the heart of Luminant. They have become very successful, very friendly, 

environmentally friendly. (0063-11-2 [Smith, Hugh])

Comment: Luminant is an excellent corporate citizen. They are involved in a number of 

activities in Somervell County and Hood County that supports a number of organizations from 

Christmas In Action to Chambers to any number of organizations that needs additional help. 

And they're here and they're a good corporate citizen. They're also a good corporation. They 

provide employment with a liveable wage that supports our communities and the people that live 

here. When you look at a county like Somervell, people graduating from high school here, they 

want to return here because there's good jobs at a place to call home. Good jobs in 

engineering, technical and so forth. So not only are they a good corporate citizen, but they're a 

good corporate employer. (0063-17-2 [Best, Darrell])

Comment: Hood County is a community of haves and have-nots. Forty-eight percent of our 

children in the public school are on free and reduced lunch. What Luminant has done in the 

Hood County is unbelievable. Because they have given over 33 percent in the last ten years of 

the money that United Way has given away. They have not only given it by their employees but 

their corporation has matched dollar for dollar. I will tell you right now there are a lot of people 

in our community that would be hungry, would not have school supplies, would not have a 

health clinic if it were not for Luminant. Last year we had -- we opened a free health clinic. 

Before we got the doors open, Luminant called and said, What we can do? And their employees 

came out, and they painted, they built a ramp, they put all kinds of things together. I've been in 

the business of non-profit for 40 years. I've worked with a lot of corporations. And I understand 

the corporate culture comes from the top. The giving that goes on at the nuclear plant is 

because the company believes in the individual citizen. What that entails means that they serve 

on almost every single committee or board in Hood County. They come willingly. They give 

their time. And the -- one of the reasons they do that is because the company supports it all the 

way down from the top. We are very lucky to have them. 

Now, when you talk about poor people, you know what poor people need? They need jobs. And 

they need an economy that flourishes. And the way for that to happen is to have a company 

like Luminant bring the economic development in. It spills over all the way down. One of the 

beautiful things about the building of the nuclear plant is you don't have to have a master's or a 

Ph.D to work on that plant. You have to be able to do multiple different kinds of tasks. It allows 

community to bring people in who have different levels of actual expertise. I believe that what 

they want to do up there is a very good thing for our community. Locally, I believe it's very 

good. I will also tell you that it's my understanding that the BRA is going to sell that water 

whether we like it or not. I would prefer we sell the water to a company that has the kind of 

corporate responsibility that Luminant has demonstrated over the last 25 years. (0063-20-1

[Bellu, Toni])
Appendix E 

May 2011 E-145 NUREG-1943 

Comment: I'm superintendent of the Glen Rose Independent School District. Glen Rose ISD is 

considered a Chapter 41 school district. What does Chapter 41 mean? It means we're subject 

to Chapter 41 of the Texas Education Code, which means our wealth level exceeds a certain 

level per student and we have to send money back to the State of Texas. So since the 

inception of the Robin Hood school finance, Glen Rose ISD has sent 500 million local tax dollars 

to the State of Texas to finance, equalize other school districts across the State of Texas. 

With this project -- I heard somebody talk about the economic benefit to the school district -- it's 

kind of like the water, if it's not used here it's going to go on downstream. That -- none of that 

money is actually going to stay here unless our number of students goes up and allows us to 

retain more of that money. Currently right now about 50 cents out of every local tax dollar we 

collect is sent back to Austin, sent back to subsidize other school districts. And when you look 

at that a lot of people associate property wealth of a school district with the wealth of its 

students. Fifty percent, five out of ten of the kids that attend Glen Rose ISD live below the 

Federal Poverty Guidelines right now. Five out of ten of our students are on free and reduced 

lunch. 

Those are things that we feel like the plant expansion would help bring jobs to the community 

and help to improve the quality of life for some of our students. (0063-21-1 [Rotan, G. Wayne])

Comment: Luminant has been a great partner and continues to be a great partner with the 

school district. They have helped us fund a dual-credit welding certification program. When a 

lack of skilled labor was not available they helped us get a program started in which our 

students could graduate with a welding certification. They've also helped us start environmental 

studies science class that goes out and monitors the water quality in the Paluxy River. They 

have a program that -- Women in Nuclear, where they come and speak with our female 

students and help them get females excited about science and involved in science. They've 

sponsored environmental essay competitions for our grade level campuses. They've made lots 

of contributions to our district, to our students and to our community. (0063-21-3 [Rotan, G. 

Wayne])

Comment: as a 43 year citizen, 25 year business owner and 13 year member of the Glen Rose 

ISD Board of Trustees, along with having the opportunity to serve on many other community 

boards and committees, I can truthfully and with no reservations say that Comanche, TXU, 

Luminant has certainly been a friend to this community and our city and county and school on 

many levels. I know the reason -- main goal to be here is to produce electricity. And we have 

reaped many of the benefits from their being here. And I know it's been mentioned, the tax 

base, the jobs, the infrastructure, the activities that have come just as a result of their being 

here. And they have become a real member of our community. Through hosting and 

participating in community activities, their philanthropic giving to multiple local causes, 

Comanche Peak has become synonymous with Glen Rose, Somervell County. (0063-22-1

[Phillips, Marilyn])

Comment: And I would be lying if I were to say I understood everything about nuclear power 

and all the advantages and disadvantages, the potential risks and/or gain. But I believe that this 

company and particularly, this site of Comanche Peak has earned our respect and our trust as 

they have proven over the years their dedication to safety and to the environment. No one 

takes this more seriously than they do, which is evident by their continued success and their 

numerous awards in this area. (0063-22-2 [Phillips, Marilyn])

Comment: We do very much appreciate the good citizens that Luminant has been. As you 

heard earlier, we meet with them on a regular basis to try to figure out ways that we can support 
Appendix E 

NUREG-1943 E-146 May 2011 

each other and get the benefit for all of us brought about. So if you think that we don't love our 

neighbors, you're wrong. (0063-23-4 [Conway, Bretta])

Comment: They've been a great partner in the school system. When we had all the 

construction workers move into our community our school became over-crowded in the '80s. 

And it was the Texas Utilities that stepped up and helped us move our program forward to take 

care of issues and problems that we encountered at that time. So I feel very strongly that the 

owners of Texas Utilities and Luminant now have been a very, very good partner of this 

community during the entire process. (0063-28-1 [Marks, Gary])

Comment: I don't know of any company that spends more time or effort in making sure they're 

good stewards of the environment. They've spent more time just seeing how little water they 

could use in their operations out there. Not the -- producing power, but in the -- just the daily 

operations, the water coolers, the air conditioning. And, you know, a lot of people don't even 

think about companies that take the effort to do that. But I -- Bruce Turner's here somewhere. 

He's the head over that. I don't remember how much water they've saved, how little water they 

put back into the ground, as far as septic and all of that. Again, I cannot think of a company that 

has been a better partnership to this community than Luminant and Comanche Peak has been. 

I read the Nuclear Regulatory Commission's mission here. It says, Protect public health and 

safety, promote common defense and security, protect the environment. That describes 

Comanche Peak better than anybody I know. We spent the morning rehearsing emergency 

management today. And again, you just have to be involved in it to know the effort that they 

take in this. I've taken friends out to the plant. And they are just overwhelmed by the effort out 

there and the cleanliness and all of that. But anyway, yes, we have a vested interest. And 

we're the ones that will have the plant in our community. There are pluses and there are 

minuses. And so it's not all pluses. And it's -- we hope that they'll go forward with it. But in you 

all's comments on environment, I can't think of a company that's better stewards in the 

environment than Luminant, TXU, whatever the current name is. They wore out their badges 

changing it, I think. (0063-3-1 [Maynard, Walter])

Comment: I'm a resident of Somervell County. I went to work at Comanche Peak in 1979, so I 

lived through the start-ups, the delays, and I finished with the replacement of the steam 

generators in '07. My primary responsibility at Comanche Peak was radiation safety. The last 

11 years at Comanche Peak I was the radiation safety manager. So I'm fully aware of the 

concerns with radiation exposure. 

From an environmental standpoint, I think the NRC is well aware of the tens of thousands of 

surveys that we have taken, are taking and will continue to take and know the impact that we 

have had on the environment. And if it was negative, it would have been in the Fort Worth StarTelegram. You don't read that. And that is due to a fact of a dedicated work force, not because 

they work for Luminant, Texas Utilities; because we believe in what we do. We're out there to 

do a good job, to protect the health and safety of the public. And if you don't believe that I'm 

sorry. But that's what I stand for. (0063-33-1 [Curtis, John])

Comment: But also, I look at the stability that that site -- those plants have brought to this area. 

And I was familiar with Glen Rose and Somervell County before I moved here. But to see over 

the years the good things this plant has done, to see the impact it's had, to see the impact it will 

have in the future -- We have young folks here who have an option. They don't have to move 

off if they don't want to. There are sustainable jobs here with the existing units. And if you look 

down the road for generations to come it will offer opportunities. (0063-35-2 [Underwood, Sid])

Comment: I just want to say that I appreciate the utility for all they do for the community. And I 

appreciate mostly what they do for the environment. Most of the employees at Comanche Peak 
Appendix E 

May 2011 E-147 NUREG-1943 

live in the surrounding communities. And I have seen to their efforts, the caring and the things 

that they do to help the environment, to help the community. And I have seen what the plant 

has done. (0063-37-1 [Willis, Stephen])

Comment: I just wanted to say first of all, I agree with Judge Maynard about Comanche Peak 

being such a good neighbor and a good steward of the environment. And I also wanted to say 

that we really support -- I really support the new plants being here. (0063-6-1 [Miller, Pam])

Comment: They have been a very good environmental neighbor since they've been here. 

TXU before, now Luminant. I echo what Judge Maynard said. I thought he touched on a lot of 

good things that they've done. They have cared for and operate Squaw Creek Park since the 

mid to late '80s. And I was just brought aware that they're in support with the Glen Rose ISD 

about the environmental classes in the classroom and in the field, which the kids are doing 

water samples and studies. (0063-8-2 [Barnard, James])

Response: These comments express support either for the Applicant or the existing reactor 

units at the Comanche Peak site. Because they did not provide any new information, no 

change was made to the EIS as a result of these comments. 

E.2.27 General Comments in Opposition to the Licensing Action 

Comment: I am very opposed to the current expansion plan for Comanche Power Plant. 

(0001-1 [Boyd, John]) 

Comment: [The plan will] destroy homes, community and a way of life. (0001-3 [Boyd, John])

Comment: Mis use and lack of honesty by the current government appointed board that 

oversees this lake has already created a major upheaval in our community. While the claim of 

"more jobs!" may sound great in this economy. The destruction this project will cause far 

outweighs any short term job benefit. (0001-4 [Boyd, John])

Comment: Do not let the expansion destroy another community and way of life just because 

their business model needs cheap water that is used irresponsibly. (0001-7 [Boyd, John])

Comment: We are adamantly opposed to the use of 20 Billion gallons per year of additional 

Lake Granbury water to cool the two new towers at Comanche Peak. (0011-1 [Williamson, William 

F. (Frank) and Eileen G.]) 

Comment: I do not support the planned use of water from the Brazos Basin. This would be 

detrimental to the quality of life for lake dwellers and users. (0015-2 [Edinboro, Sr., Christopher])

Comment: I am apposed to the nuclear reactor expansion project to include 2 new reactors at 

the Comanche Peak facility. I am not apposed to nuclear energy but rather the use/misuse of 

water resources planned to be drawn from the BRA watershed. (0016-1 [Murphy, Bill])

Comment: I have no objection to nuclear power; just a singular concern for the impact on our 

communities that already have heavy growing dependence on the BRA watershed now and in 

the near future. Help us support the life and life styles we have come to know since the 

founding of these communities over 100 years ago. Electricity to power tens of thousands of 

American homes can not come at the economic loss/cost of the equivalent numbers of people 

in our region of America. Simply put, it’s Just Not Right! (0016-3 [Murphy, Bill])

Comment: I oppose drawing more water from Lake Granbury to accommodate the proposed 

expansion of the Comanche Peak power plant. (0017-1 [Fitzgerald, C.C. (Fitz)])
Appendix E 

NUREG-1943 E-148 May 2011 

Comment: I am totally against the use of Lake Granbury to cool the 2 new towers. We can't 

afford to give up that water. (0019-2 [McHugh, Judy])

Comment: Now is the time to say NO to the BRA and Luminant. Let me make this clear. This 

is not about being against nuclear energy, it is about the WATER! Our Lake WATER. Dont 

destroy it. Don't Kill Lake Granbury (0019-4 [McHugh, Judy])

Comment: This is written in opposition to the expansion of the Comanche Peak power plant. 

(0020-1 [Clark, Becky])

Comment: The use of water from the Brazos River Basin to supply the Comanche Peak 

Expansion will be a nightmare for everyone in Granbury and the politicians will be getting lots of 

heat for allowing it. Please oppose the use of water from Lake Granbury and the Brazos River 

Basin for the Comanche Peak Expansion. (0023-3 [Hinterleiter, David])

Comment: Having been water front owning residents of Granbury for over 30 years, we feel 

that we have a vested interest in the survival of the lake. We do vehemently oppose the BRA 

removing any additional water in support of the Nuclear Power Plant in Glen Rose, Texas. 

(0024-1 [Quirk, Jim and Sharon]) 

Comment: If this happens, Granbury would become a ghost town for sure and the Nuclear 

facility would also have to find another source. Somebody has to protect us. (0029-2 [Petry, 

Susan])

Comment: Please do not proceed with the proposed additional reactors which would 

necessitate lowering Lake Granbury water levels in order to provide cooling for these reactors. 

(0030-2 [Martin, Joe])

Comment: As a lakefront homeowner at Lake Granbury, I am adamantly opposed to the 

construction of two additional reactors at Comanche Peak. (0033-1 [Hanna, Jim])

Comment: I am very much OPPOSED to drawing any more water from our lake for the 

proposed additional two reactors at Comanche Peak. We already provide our fair share!! (0034-

2 [Fitzgerald, C.C. (Fitz)])

Comment: What I'm NOT for is using Lk. Granbury for cooling water. (0037-3 [Moore, Jim])

Comment: I am strongly opposed to the expansion of comanche peak due to the increased 

amount of water that will be used from the Brazos river. I do live on lake Granbury so I will 

personally be harmed by low water levels. (0040-1 [Kurtz, Jeff])

Comment: Please DO NOT SACRIFICE THE LOCAL Lake Granbury communities dependent 

on the water levels as they are now for this new power source. (0041-2 [Martin, Joe])

Comment: I am opposed to the proposal to increase the amount of water drawn from Lake 

Granbury for Comanche Peak usage when the expansion of that facility is completed. (0062-7-1

[Williamson, Eileen])

Comment: The license for two new reactors at Comanche Peak, or any other reactor, should 

not be issued since there is no effective resolution of the storage issue. (0071-27 [Hadden, 

Karen])

Response: These comments express general opposition to the licensing action for the 

proposed new units at the Comanche Peak site. They do not provide any specific information 

relating to the environmental effects of the proposed action. No changes were made to the EIS 

as a result of these comments. 
Appendix E 

May 2011 E-149 NUREG-1943 

E.2.28 General Comments in Opposition to the Licensing Process 

Comment: Therefore, we suggest that the NRC reject the current environmental study until 

planning deficiencies outlined above are remedied. (0063-36-10 [Hackett, Ken])

Response: This comment expresses general dissatisfaction with the EIS. As a required part of 

its licensing process, the review team has carefully reviewed the COL application and relevant 

information against its regulations that are intended to protect public health and safety and the 

environment. The staff has also assessed the environmental impacts, including physical, 

economical, and social aspects of the proposed action according to applicable regulations. No 

change was made to the EIS as a result of this particular comment; however, the "deficiencies" 

enumerated by this same commenter have been cataloged and are addressed under the 

respective categories for those separate comments and concerns. 

E.2.29 General Comments in Opposition to Nuclear Power 

Comment: Our organization is opposed to building new nuclear reactors. And there are many 

reasons why. I'm not going to dwell on that so much today. (0063-30-1 [Hadden, Karen])

Comment: Nuclear power is a bad choice for generating electricity and would divert precious 

resources from readily available technologies to reduce global warming gases that are both 

cheaper and can be deployed faster. 

Nuclear power: 

 Is not a useful solution to climate change. 

 Is vulnerable to severe climate conditions which prevent reliable operation. 

 Is not the alternative to coal. Efficiency, energy storage and renewable energy can do the 

job. 

 Is not clean. 

 Is not safe. 

 Poses serious terrorism risks. 

 Is the most expensive way to generate electricity. 

 Radioactive waste remains an unsolved problem. 

 Fosters nuclear weapons proliferation. 

 Is not the solution to energy independence. 

 Has negative health impacts. 

 Is not supported by the public at large. 

Why is nuclear power even being considered at a time when clean, affordable energy solutions 

exist? (0071-17 [Hadden, Karen])

Comment: When nuclear reactors were licensed in the 1970’s there were no great realistic 

alternatives. Wind and solar energy are well developed now and are more affordable than 

nuclear power. Energy efficiency helps curb demand. We do not need nuclear power or the 

risks that it entails. There is a moral imperative to not leave radioactive waste to generations to 

come, along with the nightmare of storing and repackaging it for millions of years. (0071-19

[Hadden, Karen])

Comment: Radioactive waste, safety and security issues, economics and the vast 

consumption of water are all reasons to avoid more nuclear reactors. (0071-9 [Hadden, Karen])
Appendix E 

NUREG-1943 E-150 May 2011 

Response: These comments express general opposition to nuclear power and do not provide 

any specific information relating to the environmental effects of the proposed action. No 

changes were made to the EIS as a result of these comments. 

E.2.30 Comments Concerning Issues Outside Scope - Emergency Preparedness 

Comment: [As residents of this area, we also have serious concerns about . . . ] existing 

critical emergency evacuation bottlenecks that will only get worse as development accelerates. 

(0055-8 [Inge, Charles] [King, Arnold] [Rosenfeld, Joshua])

Comment: [As residents of this area we are -- we have serious concerns about] existing critical 

emergency evacuation -- bottlenecks -- that will only get worse as development accelerates. 

(0063-36-8 [Hackett, Ken])

Comment: Luminant and the NRC need to do more to prepare the community for action in the 

event ofan accident or disaster, including distributing potassium iodide tablets. Readiness for 

an accident is a serious issue. 

 If there is an accident, will the community be able to evacuate? What hospitals would be 

used to care for those who might be exposed to radiation and how many people could they 

care for? How does the hospital facility availability compare to the number of potential 

injuries and radiation exposure victims? 

 Are there adequate firefighting and police forces? Do they have any training or any 

equipment to shield themselves from radioactivity in case of a nuclear accident? What more 

is needed to protect themselves, as well as others? 

 Potassium iodide tablets would be needed if there were a nuclear accident. The tablets 

would reduce human uptake of radioactive iodine, a carcinogen which goes to the thyroid 

gland. According to NRC rules, residents near nuclear plants must receive potassium iodide 

tablets in case of emergency. 

 Has anyone in the 50-mile radius around the existing two Comanche Peak reactors ever 

received potassium iodide tablets? Have they been told how to get them? (0071-38 [Hadden, 

Karen])

Response: Emergency preparedness capabilities of the proposed facility, evacuation 

procedures, and evacuation routes are emergency planning issues and are outside the scope of 

the environmental review. As part of its site safety review, the NRC staff will determine, after 

consultation with the Department of Homeland Security and the Federal Emergency 

Management Agency, whether emergency plans submitted by the applicant are acceptable. No 

changes to the EIS were made as a result of these comments. 

E.2.31 Comments Concerning Issues Outside Scope - Miscellaneous 

Comment: Energy Efficiency Done Right invites you to a webinar with information on 

opportunities in manufacturing or being a dealer of In'Flector See Through Radiant Barrier 

Window and Skylight Insulators. (0026-1 [Roberts, Keith])

Response: This comment provides no new information relevant to the environmental review of 

the COL application and therefore will not be evaluated further in the FEIS. 

Comment: I know you have received information from the NRC study, but I want to add my 

own plea that the BRA's request be denied in order to find another solution for Comanche Peak. 

We should not predicate the decision on just "doing things the same old way." In these stressed 

economic times we need to be creative and after meeting with the BRA I do not see any attempt 

to consider options. The BRA even admitted that quite a bit less water was being released due 
Appendix E 

May 2011 E-151 NUREG-1943 

to it closing a hydro plant at Possum Kingdom that released a good amount of water daily. The 

reason for the closing was cited as due to it being expensive to run the plant. With added 

revenue of the sale of additional water it seems that the hydro plant should be either turned 

back on or some money spent to find a way to run it more economically. I do not get the 

impression that either has been considered. That is just one consideration that easily comes to 

mind. (0006-3 [McClain, Janet])

Comment: The BRA has taken NO STEPS in the resolution of the working status of this facility 

[the Morris Shepherd Hydroelectric Plant] and continues to not be a good steward of the Brazos 

River Basin in the management of this facility. Also in this matter, the BRA is in litigation with 

Brazos Electric (http://www.supreme.courts.state.tx.us/ebriefs/files/20100611.htm) ; in the 

Texas Supreme Court which has allowed the answers to Morris Shepherd to go unresolved. 

(0051-5 [Jalbert, Ann] [Jalbert, Pete] [McHugh, Judy] [Williams, Joe] [Williams, Sue])

Comment: And right now there's litigation going on with the hydroelectric plant. I'd like to see if 

there's not some manner that the NRC or possibly Luminant might be able to step in, take over 

the dam in such a manner. I would like to see Luminant take over the hydroelectric plant in an 

effort to see water flow again. There's -- one of the issues that I've overheard from the BRA is 

that it costs X number of dollars to operate the plant and maintain it. And now they're in 

litigation with an electric coop that's effectively shut down the dam. And we're not sure how long 

before we see litigation resolved. So that's -- I would appreciate anything that we could get that 

would benefit Lake Granbury. It would also be a safety issue. (0063-7-5 [Pratt, Rickie])

Response: The NRC does not have regulatory authority over the operation of energy sources 

except nuclear power. Thus, the situation at Morris Shepherd Dam is outside the scope of the 

environmental review of the COL for Comanche Peak Units 3 and 4. Safety issues will be 

evaluated separately by the NRC as part of the NRC's development of a Safety Evaluation 

Report for this proposed action. These comments did not result in any changes in the EIS. 

E.2.32 Comments Concerning Issues Outside Scope - Safety 

Comment: Added to the kind of withdrawals that you all are talking about from this plant you 

have to question whether or not this plant will be able to operate with the increased 

temperatures. And that's what, in fact, TXU or Luminant, as they're now called, asked the -- 

their consultants. And they said, So how do we begin to reduce the intake temperature? And 

they came up with three or four different ways and said, All of them are technologically possible. 

We can increase the amount of our cooling surfaces, we can spray the intake water, we can do 

a bunch of other stuff, but none of them are cost effective. (0063-16-4 [Smith, Tom])

Comment: If global warming occurs as rapidly as projected, will Comanche Peak be able to 

operate safely especially during the hottest months when it is needed the most? On August 12, 

2010 , the La Salle nuclear plant in Illinois went off line due to overheated cooling water which 

exceeded 101 degrees Fahrenheit (°F). (REF i) There is a chance that climate change will 

warm the temperatures of the cooling water at Comanche Peak to levels in excess of 101°F or 

too high to allow the plants to operate safely. In the summer months of July and August, Lake 

Granbury air temperatures exceed 95°F, which is the temperature that leads to a reduction in 

generation at the plant. It appears that if the temperature exceeds 101 degrees, then the plant 

ultimately needs to be shut down. A recent study on Comanche Peak 1 and 2 alerted us to 

potential problems. It may be found at http://www.ermsmg.com/TXU%20Comanche%20Peak.pdf 

Water temperatures at Granbury Lake could exceed safe operating temperatures With 

additional potential increases in air temperature that might result from global warming, it is likely 
Appendix E 

NUREG-1943 E-152 May 2011 

that the water temperature will also increase thus making the feed water intake temperature 

close or above the 101 degrees that resulted in the shut down at La Salle and other operating 

reactors. The Lake Granbury Watershed Protection Plan notes how susceptible to the lake 

temperature is to air temperature: “Temperature changes are rapid, especially in winter and 

early spring when cold, dry polar air replaces warm, moist tropical air. Periods of cold weather 

are short and occur mostly in January; fair, mild weather is frequent. High daytime 

temperatures prevail for a long period in the summer when the maximum temperature reaches 

or exceeds 90°F daily. July is the hottest month with an average daily maximum temperature of 

95°F.” (REF ii) 

Vertical variation in temperature and dissolved oxygen (DO) are evident in historical data; data 

for the period February 1972 through March 2006 were analyzed. Temperature stratification is 

common April through August, with average temperature difference being greater than 5°C 

(Figure 3-2). Min and max temperature for each measurement where profiles were taken are 

shown in Figure 3-3. Depth to greatest change in temperature (approximation of thermocline 

depth) is generally 11m near the dam (Segment 1) in May, followed by either greater or lesser 

depths through September. 

Average water temperature in Lake Granbury run a little lower than air temperatures. They 

average about 27 degrees Celsius (°C) in most summer months or 89.6°F but have peaked at 

approximately 50°C or 104°F. More importantly there is a 7°F average differentiation between 

the hottest part of the lake and the norm bringing the average “hot spot” temperature to 93°F. 

(REF iii) This hot spot is very close to the cooling water inlets in section one near the dam and 

the outlet, which will increase the temperatures by an additional 1°F. If you add the increased 

4-12°F air temperature increase due to global warming, the lake could be too hot to cool the 

proposed reactors. (0067-1 [Geiger, Carol])

Comment: Likely increase of ambient air temperatures. 

The DEIS for Comanche Peak notes on page 7-17 at lines 34-35 that the GCRP shows 

temperatures in the area could increase by as much as 12°F by 2090. Using the analysis from 

the Nature Conservancy based on the Intergovernmental Panel on Climate Change’s (IPCC) 

Fourth Assessment Report at http://www.ClimateWizard.org, we find that likely temperature 

changes within the expected operating life of the plant to be in excess of 6°F. Add that to the 

average current high temperatures on Lake Granbury and the plant will likely have to curtail 

generation and may not be able to operate without constraint several months each summer. 

(0067-2 [Geiger, Carol])

Comment: Nuclear Power has been curtailed worldwide due to high temperatures and it has 

been costly to replace the power! France, Germany and Spain were forced to shut down dozens 

of nuclear plants due to a prolonged heat wave and low water levels. Scientists say climate 

change was a contributing factor to all of these events, which had far-reaching business 

impacts. (0067-4 [Geiger, Carol])

Comment: Cooling water could be too hot at Comanche Peak 1 and 2 and study found 

supplemental cooling water systems were not cost effective A recent study on Comanche Peak 

units 1 and 2 examined the impact of high cooling water temperatures and found when cooling 

temperature exceed 95°F plant production decreased and above 101°F required the plant to be 

shut down. It is noteworthy that the 80 days above 95°F simulation chosen closely mirrors the 

air temperature records in the Lake Granbury water shed. Could this mean that the water 

temperature will be too high to cool proposed units 3 and 4? For the simulation year chosen, 

intake temperatures exceeded 95°F more than 80 days. Plant production decreases once the 

intake temperature goes above 95°F and ultimately needs to be shut down at 101°F when the 
Appendix E 

May 2011 E-153 NUREG-1943 

condenser pressure reaches 5.0 in. HgA The study looked at four options to reduce 

temperatures: The supplemental cooling options that were analyzed for the study were: 

Oriented Spray Cooling Systems (OSCS) Mechanical Draft Cooling Towers (MDCT), and 

Water Garden Steps (WGS). The option of increasing the SCR surface area by 5% to enhance 

the surface heat exchange was also considered. These supplemental cooling systems were 

designed to cool 25% of the intake water. To increase the overall effectiveness of these 

systems, a dike enclosing the intake was designed to restrict the mixing of the cooled water and 

the hot reservoir water. (0067-7 [Geiger, Carol])

Comment: Results The SCR’s response to the designed supplemental cooling system was 

found to be favorable. On the other hand, the increased surface area did not contribute much to 

decrease the intake temperature. The supplemental cooling systems lowered the intake 

temperatures by up to 5 F making the occurrence of the “greater than 95°F” event almost nonexistent. While effective, these supplemental cooling systems increased the house load by a 

considerable amount. This increased house load alone rendered the MDCT and WGS systems 

ineffective in terms of capital and operational costs to benefit ratio. OSCS resulted in an 

increased power generation but was associated with high capital cost. A minimal return on 

investment of 2% was not justifiable economically and thus became the basis for subsequent 

rejection of the OSCS system. (REF xiii) (0067-8 [Geiger, Carol])

Comment: The question of whether global warming will make the water temperature too hot to 

cool the proposed units 3 and 4 is central to the issuance of a license and the final EIS. The 

DEIS documents the problem: global climate change may increase air by as much as 12°F, 

(REF xiv) which will increase enviro-transpiration; and decrease precipitation and runoff. (REF 

xv) The Lake Granbury watershed protection plan notes that there is a strong correlation 

between air and water temperature. (REF xvi) The charts show that the temperatures near the 

intake are often near the 95 at which generation is curtailed and have exceeded 101 the plant 

has to be shut off. Thus the ability of cooling lakes to dissipate could be degraded by global 

warming. (REF xvii) 

Comanche Peak has begun to study the effects of excess heat on the operations of units 1 and 

2 and the researchers noted that at temperatures above 95°F operations are curtail and above 

101°F the plant has to be shut off. (REF xviii) Thus we question whether the plant may not be 

able to operate due to high temperature cooling water within the lifetime of the plant (0067-9

[Geiger, Carol])

Comment: Nuclear reactors heat up the air and water around them. Several U.S. reactors 

have had to cut back electric generation because the cooling water got too hot. During the 2006 

heat wave in France nuclear and coal plants had to be shut down because the water was too 

hot to cool them. 2000 MW of energy had to be imported. (Source: False Promises, 

Debunking Nuclear Industry Propaganda, Nuclear Information and Resource Service,May 

2008.) (0071-35 [Hadden, Karen])

Response: These comments express general concerns about the safety of the proposed 

nuclear power plants, particularly in regard to acceptable water intake temperatures. These 

comments are not related to environmental impacts of plant construction or operation; therefore, 

they will not be addressed in the EIS. The NRC is developing a Safety Evaluation Report that 

analyzes all aspects of reactor and operational safety for the proposed new units. 

Comment: Now, you know, I've heard talk today about what a good neighbor Luminant and 

TXU has been in the past. But let's think about some of the historical headlines that have been 

in the area. 1984, Wall Street Journal, Safety Procedures at Comanche Peak Cited by NRC 
Appendix E 

NUREG-1943 E-154 May 2011 

Panel, at which time the article cited that 1974 the plant then was supposed to be $780 million. 

At that time in '84 it was $3.89 billion. Quite a cost overrun. 

Wall Street Journal, 1986, Texas Utility Company Finds New Problems at Comanche Peak. 

Wall Street Journal, December of '86, NRC Criticizes Manager in Texas Office on Data For 

Comanche Peak Nuclear Unit. New York Times, 1989, Texas Plant Comes Under Scrutiny as 

Coverup of Problems Charged. Fort Worth Star Telegram, 1991, Weakened Cooling System 

Closes Comanche Peak. 

I've got about 20 [newspaper articles] here. But here's another one. Fort Worth Star Telegram, 

1991, Comanche Peak Called Number One in Safety Violations. And in that same year a 

spokesman said the early closure and condenser repair would have minimal impact on the 

plant, completed at a cost of 9.1 billion, which in 1991 was more than ten times the original cost 

of this plant. (0063-29-7 [Benning, Rita]) 

Comment: Competence and Character in question, Poor Track Record at Existing Reactors. 

Here are some excerpts from articles about Comanche Peak reactors: (0071-48 [Hadden, Karen])

Response: The commenters offer a list of newspaper articles regarding surveys, inquiries, and 

NRC inspections of the existing reactors at the Comanche Peak Nuclear Power Plant site. 

Because the news excerpts deal primarily with safety and safety-related issues, these 

comments are beyond the scope of this EIS. The NRC is conducting a separate safety review 

for this COL, and the types of issues and concerns identified in the comments would be 

addressed in the safety review. Because these comments did not offer any new or significant 

information about environmental impacts, no changes were made to the EIS as a result of these 

comments. 

E.2.33 Comments Concerning Issues Outside Scope - Security and Terrorism 

Comment: [Nuclear energy/power] It's not safe. We have terrorism risks. We don't have those 

if we pursue other kinds of energy generation. (0063-30-5 [Hadden, Karen])

Comment: And the additional safety and security risks of more radioactive waste definitely 

needs to be studied. (0063-32-7 [Rooke, Molly])

Comment: The EIS should study the additional safety and security risks of more radioactive 

waste. (0071-26 [Hadden, Karen])

Comment: 

 Terrorists have considered crashing airplanes into nuclear reactors. Terrorist risks must be 

more thoroughly analyzed, as it would be easy enough to lob mortar from a construction site 

toward the existing spent fuel pool, creating a major nuclear accident. Heavy construction 

equipment could breach barricades between a construction site and existing reactors. 

Workers would come from any number of foreign countries, creating language barriers and 

security challenges. 

 The EIS should recommend that no new nuclear reactors be licensed until they can at least 

meet the same post-911 security hardening requirements as existing reactors. 

 The EIS should also recommend that no design be approved that cannot safely withstand 

an airplane attack or other form of terrorist assault. (0071-30 [Hadden, Karen])

Response: Comments related to aspects site safety, security, and terrorism are not within the 

scope of the staff's environmental review. In addition, the Commission, has determined that 

terrorism is not predictable and is not an inevitable consequence of a proposed licensing action, 
Appendix E 

May 2011 E-155 NUREG-1943 

and that an EIS is not an appropriate format to address the challenges of terrorism. Additional 

information about the review team's actions regarding physical security since September 11, 

2001, can be found on the NRC's public web site (www.nrc.gov). 

E.2.34 General Editorial Comments

Comment: TPWD recommends all numerics, references and duplicative statements between 

sections of the DEIS be checked for consistency and accuracy to ensure the proposed action is 

represented accurately and any contradictory statements have been removed from DEIS. 

(0068-13 [Melinchuk, Ross] [Wicker, Julie])

Response: The specific items identified in other comments from this same commenter have 

been corrected in the Final EIS. In addition, the NRC staff has reviewed the EIS in detail, and 

additional changes of an editorial nature have been made to the EIS in response to the general 

items identified in this comment.

Appendix F 

Key Consultation Correspondence 

Regarding the Comanche Peak 

Nuclear Power Plant, Units 3 and 4, 

Combined Licenses Application 

   

May 2011 F-1 NUREG-1943 

Appendix F 

Key Consultation Correspondence 

Regarding the Comanche Peak 

Nuclear Power Plant, Units 3 and 4, 

Combined Licenses Application 

Correspondence sent and received during the evaluation process for the combined license 

application for the siting of two new nuclear units, Units 3 and 4, at the Comanche Peak Nuclear 

Power Plant site in Somervell and Hood Counties, Texas is identified in Table 1. In addition, a 

full copy of the Biological Assessment is included in this appendix. 

Table 1. Key Consultation Correspondence

Source Recipient Date of 

Correspondence 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Texas State Historic Preservation 

Officer (Lawerence Oaks) 

December 23, 2008 

ML083400507 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Texas Parks and Wildlife Department 

(Kathy Boydston) 

December 23, 2008 

ML083400514 

U.S. Nuclear Regulatory Commission 

(William Burton) 

U.S. Advisory Council on Historic 

Preservation (Don Klima) 

December 23, 2008 

ML083410002 

U.S. Nuclear Regulatory Commission 

(William Burton) 

U.S. Fish and Wildlife Service 

(Tom Cloud) 

December 23, 2008 

ML083450242 

U.S. Nuclear Regulatory Commission 

(William Burton) 

National Marine Fisheries Service 

(David Bernhart) 

December 23, 2008 

ML083450284 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Absentee-Shawnee Tribe of 

Oklahoma (Scott Miller) 

December 23, 2008 

ML083460276 

U.S. Nuclear Regulatory Commission 

(William Burton) 

White Mountain Apache Tribe (Ronnie 

Lupe) 

December 23, 2008 

ML083460284 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Alabama-Coushatta Tribe of Texas 

(Bryant Celestine) 

December 23, 2008 

ML083460323 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Apache Tribe of Oklahoma 

(Alonzo Chalepah) 

December 23, 2008 

ML083460347 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Caddo Nation of Oklahoma 

(LaRue Parker) 

December 23, 2008 

ML083460378 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Cheyenne Arapaho tribes of 

Oklahoma (Darrell Flyingman) 

December 23, 2008 

ML083460400 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Comanche Nation (Wallace Coffey) December 23, 2008 

ML083460416 
Appendix F 

NUREG-1943 F-2 May 2011 

Table 1. (contd) 

Source Recipient Date of 

Correspondence

U.S. Nuclear Regulatory Commission 

(William Burton) 

The Delaware nation, Delaware Tribe 

of Western Oklahoma 

(Kerry Holton) 

December 23, 2008 

ML083460442 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Delaware Tribe of Western Oklahoma 

(Jerry Douglas) 

December 23, 2008 

ML083460483 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Ft. Sill Apache Tribe of Oklahoma 

(Jeff Houser) 

December 23, 2008 

ML083460509 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Jicarilla Apache Nation 

(Lorene Willis) 

December 23, 2008 

ML083460546 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Kickapoo Traditional Tribe of Texas 

(Juan Garza) 

December 23, 2008 

ML083460577 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Kiowa Tribe of Oklahoma 

(Billy Horse) 

December 23, 2008 

ML083460598 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Mescalero Apache 

Tribe (Carleton Naiche-Palmer) 

December 23, 2008 

ML083460623 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Wichita and Affiliated Tribes 

(Leslie Standing) 

December 23, 2008 

ML083470301 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Osage Nation (Jim Roan Gray) December 23, 2008 

ML083470322 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Tonkawa Tribe of Oklahoma (Anthony 

Street) 

December 23, 2008 

ML083470373 

Tonkawa Tribe of Oklahoma 

(Donald L. Patterson) 

U.S. Nuclear Regulatory Commission 

(William Burton) 

January 5, 2009 

ML090500590 

National Marine Fisheries Service 

(David M. Bernhart) 

U.S. Nuclear Regulatory Commission 

(William Burton) 

January 8, 2009 

ML090230148 

U.S. Environmental Protection Agency, 

Region 6 (Cathy Gilmore) 

U.S. Nuclear Regulatory Commission 

(Michael Lesar) 

February 13, 2009 

ML090680037 

Texas Parks and Wildlife Department 

(Carter Smith) 

U.S. Nuclear Regulatory Commission 

(Michael Lesar) 

February 16, 2009 

ML090680387 

Advisory Council on Historic 

Preservation (Charlene Dwin Vaughn) 

U.S. Nuclear Regulatory Commission 

(William Burton) 

February 17, 2009 

ML090500077 

U.S. Fish and Wildlife Services (Sean 

Patrick Edwards) 

U.S. Nuclear Regulatory Commission 

(Michael Willingham) 

February 19, 2009 

ML092430749 

Texas Parks and Wildlife Department 

(Karen Hardin) 

U.S. Nuclear Regulatory Commission 

(Michael Lesar) 

April 24, 2009 

ML091310617 

Texas Historical Commission 

(Mark Wolfe) 

Enercon Services Inc. 

(Stacy Burgess) 

June 10, 2009 

ML092090669 
Appendix F 

May 2011 F-3 NUREG-1943 

Table 1. (contd) 

Source Recipient Date of 

Correspondence

U.S. Nuclear Regulatory Commission 

(Scott Flanders) 

U.S. Environmental Protection Agency August 6, 2010 

ML101290752 

U.S> Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

Texas Commission on Environmental 

Quality (Tangela Niemann) 

August 6, 2010 

ML101950280 

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

U.S. Fish and Wildliffe Service (Tom 

Cloud) 

August 6, 2010 

ML101960020 

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

National Marine Fisheries Service 

(David Bernhart) 

August 6, 2010 

ML101960039 

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

Texas Parks and Wildlife Department 

(Kathy Boydston) 

August 6, 2010 

ML101960050 

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

White Mountain Apache Tribe (Ronnie 

Lupe) 

August 6, 2010 

ML102090382 

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

Caddo Nation of Oklahoma (LaRue 

Parker) 

August 10, 2010 

ML102180328 

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

Apache Tribe of Oklahoma (Henry 

Kostzuta) 

August 10, 2010 

ML102180335 

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

Wichita and Affiliated Tribes (Gary 

McAdams) 

August 10, 2010 

ML102180341 

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

Cheyenne and Arapaho Tribes of 

Oklahoma (Charles Surveyor) 

August 10, 2010 

ML102180356 

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

Delaware Tribe of Western Oklahoma 

(Lawrence Snake) 

August 10, 2010 

ML102180361 

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

Comanche Nation (Jimmy Arterberry) August 10, 2010 

ML102210305 

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

Tonkawa Tribe of Indians of 

Oklahoma (Don Patterson) 

August 10, 2010 

ML102210307 

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

Osage Nation (Jim Roan Gray) August 10, 2010 

ML102210316 

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

Mescalero Apache Tribe (Mark Chino) August 10, 2010 

ML102210327 

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

Kiowa Indian Tribe of Oklahoma 

(Donald Tofpi) 

August 10, 2010 

ML102210329 

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

Kickapoo Traditional Tribe of Texas 

(Juan Garza) 

August 10, 2010 

ML102210332 

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

Absentee Shawnee Tribe (Larry 

Nuckolls) 

August 10, 2010 

ML102210352 

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

Jicarilla Apache Nation (Gifford 

Velarde) 

August 11, 2010 

ML102210333 
Appendix F 

NUREG-1943 F-4 May 2011 

Table 1. (contd) 

Source Recipient Date of 

Correspondence

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

Delaware Tribe of East Oklahoma 

(Joe Brooks) 

August 11, 2010 

ML102210334 

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

Fort Sill Apache Tribe of Oklahoma 

(Jeff Houser) 

August 11, 2010 

ML102210337 

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

Alabama-Coushatta Tribe of Texas 

(Bryant Celestine) 

August 11, 2010 

ML102210338 

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

Texas Historical Commission (Mark 

Wolfe) 

August 12, 2010 

ML101950205 

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

Advisory Council on Historic 

Preservation (Reid Nelson) 

August 12, 2010 

ML101950267 

Texas Commission on Environmental 

Quality (Jim Harrison) 

U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett) 

August 12, 2010 

ML102600188 

Delaware Nation (Jason Ross) U.S. Nuclear Regulatory Commission 

(Gregory P. Hatchett and Michael 

Willingham) 

September 2, 2010 

ML102500343 

U.S. Department of the Interior 

(Stephen Spencer) 

U.S. Nuclear Regulatory Commission 

(Rulemaking and Directives Branch) 

October 20, 2010 

ML102980431 

Environmental Protection Agency – 

Region 6 (Rhonda Smith) 

U.S. Nuclear Regulatory Commission 

(Rulemaking and Directives Branch) 

October 26, 2010 

ML103220200 

Texas Parks and Wildlife Department 

(Ross Melinchuk) 

U.S. Nuclear Regulatory Commission 

(Cindy Bladely)) 

November 5, 2010 

ML103230413) 
Appendix F 

May 2011 F-5 NUREG-1943 

Biological Assessment 

U.S. Fish and Wildlife Service 

Comanche Peak Nuclear Power Plant 

Units 3 and 4 

U.S. Nuclear Regulatory Commission Combined License Application 

Docket Nos. 52-034 and 52-035 

U.S. Army Corps of Engineers Permit Application 

August 2010 

U.S. Nuclear Regulatory Commission 

Rockville, Maryland 

U.S. Army Corps of Engineers 

Fort Worth District 
Appendix F 

NUREG-1943 F-6 May 2011 

1.0 Introduction 

The U.S. Nuclear Regulatory Commission (NRC) is reviewing an application from Luminant 

Generation Company LLC (Luminant) for two combined licenses (COLs) for construction and 

operation of two new nuclear power plants at its Comanche Peak Nuclear Power Plant 

(CPNPP) site. The CPNPP site lies approximately 5 mi north of Glen Rose, Texas, and 

approximately 9 mi south of Granbury, Texas, outside the limits of either city (see Figure 1). 

The COL application was submitted by Luminant to the NRC on September 19, 2008. 

Concurrent with the NRC’s review, the U.S. Army Corps of Engineers (USACE) is reviewing 

Luminant’s COL application for a Department of the Army (DA) Permit to build the reactors and 

support structures in waters of the United States on the CPNPP site. The NRC and the USACE 

are cooperating agencies with the NRC being the lead agency, and this biological assessment 

(BA) supports a joint consultation with the U.S. Fish and Wildlife Service (USFWS) under 

Section 7 of the Endangered Species Act (ESA) of 1973. The USACE is cooperating with the 

NRC to ensure the information presented in the EIS is adequate to fulfill the requirements of 

Corps regulations; the Clean Water Act Section 404(b)(1) Guidelines, which contain the 

substantive environmental criteria used by the USACE in evaluating discharges of dredged or fill 

material into waters of the United States; and the USACE public interest review process. 

Currently there are two operating nuclear reactors on the CPNPP site, Units 1 and 2. 

The proposed new reactors, Units 3 and 4, would be located adjacent to the existing units in 

areas that had experienced previous temporary disturbance during development of Units 1 and 

2, along with some adjoining areas of previously undisturbed areas of land. The proposed 

support structures would also occupy previously developed land as well as grasslands, Ashe 

juniper (Juniperus ashei) woodland - savanna, and mixed hardwood communities. Luminant 

has identified the need for new and expanded transmission line and pipeline corridors as part of 

the project (see Figure 2). The routes for a proposed 17-mi transmission line (referred to as the 

DeCordova line) and a proposed 17-mi cooling water pipeline to Lake Granbury would go 

through Somervell and Hood Counties, Texas. A proposed 45-mi transmission line (referred to 

as the Whitney line) would go through Somervell and Bosque Counties. Although approximate 

corridors for the new lines have been identified, exact rights-of-way (ROWs) for the new lines 

are yet-to-be determined. For three other transmission line ROWs with lengths of 41.6, 22.4, 

and 22.4 mi, Luminant has stated that no land-use impacts are anticipated, since the new 

conductors would be added to vacant circuit positions on existing steel towers on ROWs where 

vegetative maintenance is already being performed on those ROWs (Luminant 2009a). 

The NRC is required to prepare an environmental impact statement (EIS) as part of the 

agency’s review of the COL and DA permit applications. As required by Title 10 of the Code of 

Federal Regulations (CFR) Part 51.26, the NRC has published in the Federal Register a Notice 

of Intent (73 FR 77076) to prepare an EIS and to conduct scoping. The final EIS would be 

issued after considering public comments on the draft EIS. The impact analysis in the EIS 

includes an assessment of the potential environmental impacts of the construction and 

operation of the two new nuclear power units at the CPNPP site and along the associated 

transmission and pipeline corridors, including potential impacts to threatened and endangered 

species. If approved, the COL and DA permit would authorize Luminant to construct and 

operate the new units. 

This BA examines the potential impacts on federally listed threatened or endangered terrestrial 

species of construction and operation of the proposed Units 3 and 4 at the CPNPP site and 

along the proposed new transmission and pipeline ROW, pursuant to Section 7(c) of the 

Endangered Species Act (ESA) of 1973, as amended. 
Appendix F 

May 2011 F-7 NUREG-1943 

Figure 1. Location of the CPNPP Site Within Hood and Somervell Counties, Texas 

(Luminant 2009a)
Appendix F 

NUREG-1943 F-8 May 2011 

Figure 2. Existing and Proposed Transmission Line Rights-of-Way and Pipeline Routes. 

Note: All Routes are Approximate, and the Exact Alignments of the Routes have 

Yet to be Determined. The Existing 345-kV Transmission Line Rights-of-Way Can 

Support a Second Circuit on the Existing Support Towers. The Existing 185 and 

345-kV Transmission Lines will not be Modified (Adapted from Luminant 2009a)
Appendix F 

May 2011 F-9 NUREG-1943 

2.0 CPNPP Project Site Description 

The CPNPP site lies within the Western Cross Timbers subdivision of the Grand Prairie 

physiographic province (Wermund 1996). The province is transitional between the vast prairies 

to the west and the forested hills or low mountains to the east. Ecologically, the site lies within 

the Western Cross Timbers subdivision of the Grand Prairie ecoregion, which is characterized 

by a mosaic of forest, woodland, savanna, and prairie with dominant vegetation that includes 

little bluestem (Schizachyrium scoparium) with scattered stands of blackjack oak (Quercus 

marilandica) and post oak (Q. stellata) (Griffith et al. 2004). Historical records indicate that 

much of the region existed as a grassland or open live oak savanna that supported herds of 

bison and other herbivores dependent on the tall grasses that dominated the region (TPWD 

2007). The introduction of domestic livestock, farming operations, and wildfire control changed 

the landscape of much of the region. These practices created a landscape that experienced 

invasion and localized domination in some areas by problematic scrub species such as 

mesquite (Prosopis spp.), Ashe juniper, and other native woody species. Overgrazing by 

livestock and elimination of naturally occurring fire also reduced native grass cover and allowed 

the invasion of other, less desirable annual grasses and forbs. 

Luminant prepared an ecological vegetation cover type map of the CPNPP site based on 

interpretation of aerial photographs showing the current spatial distribution of vegetation types 

and aquatic habitats present (Figure 3). The two general regional vegetation cover types (oakmesquite-juniper savanna and woodlands, and silver bluestem [Bothriochloa saccharoides]–

Texas wintergrass [Nassela (=Stipa) leucotricha]) were further classified into more site-specific 

descriptions using 1999 infrared aerial photography and ground-truthing in 2006 and 2007 

(Luminant 2009a). Figure 3 shows that terrestrial cover of the site is predominantly Ashe 

juniper woodland – savanna and grasslands. A description of each cover type follows: 

Ashe Juniper Woodland - Savanna. Strands of Ashe juniper woodland – savanna are 

evergreen, dominated by mature Ashe juniper trees or a combination of mature and immature 

Ashe juniper trees and saplings. Mature Ashe juniper trees are over 15 ft high with 5 in or more 

in diameter at breast height (DBH), approximately 4.5 ft above the ground. Hardwood species 

occupy 10 percent or less of the canopy. This cover type is the most common terrestrial habitat 

type at CPNPP and occupies a total of about 3071 ac or approximately 39 percent of the site. 

Ashe juniper woodland - savanna covers about 60 percent of the peninsula where new cooling 

towers for Units 3 and 4 would be located. This peninsula is located just to the northwest of, 

and adjacent to, the peninsula on which existing Units 1 and 2 are located (Figure 4). 

Substantial land clearing would be needed on the peninsula to accommodate the cooling 

towers. Similarly, the proposed blowdown treatment facility (BDTF), which is located to the 

southeast (see Figure 5), would be developed in what is now predominantly Ashe juniper 

habitat. This facility is only in design concept phase, but the roughly 400-ac location it would 

occupy, including its associated evaporation ponds, is depicted in Figure 5. 

Mixed Hardwood Forest. Mixed hardwood forests are dominated by a combination of 

hardwood tree species including live oak (Quercus virginiana), cedar elms (Ulmus crassifolia), 

mesquite, hackberry (Celtis spp.), Texas ash (Fraxinus texensis), chittamwood (Sideroxlyon 

lanuginosa), and occasional persimmon (Diospyros texana) trees. Ashe junipers comprise 

30 percent or less of the tree canopy in mixed hardwood stands. The shrub layer includes 

buckbrush (Ceanothus cuneatus), agarito (Berberis trifoliata), lemon sumac (Rhus aromatica), 

and Mexican buckeye (Ungnadia speciosa). This cover type occupies a total of about 528 ac at 

CPNPP or approximately 7 percent of the site. Transect data, collected by Luminant in 2007 
Appendix F 

NUREG-1943 F-10 May 2011 

(Luminant 2009a) on the peninsula where new cooling towers would be located, show that 

mixed hardwood forest covers approximately 16 percent of the transect lines surveyed. 

Figure 3. Ecological Vegetation Cover Type Map of the CPNPP Site (Luminant 2009a; Enercon 2009)

Grassland. Grasslands within the site are dominated by either a variety of native grasses, such 

as big (Andropogon gerardii), little, and silver bluestem; gramas (Bouteloua spp.); Texas 

wintergrass; and some forbs, or by monocultures of turf grass such as Bermuda grass 

(Cynodon dactylon) or fescues (Festuca spp.). Bermuda grass lawns are common at the site 

near the facility entrance and around buildings. Fescue is a genus of more than 300 species of 

tufted grasses commonly planted to supplement native grass in pastures. This cover type 

occupies a total of about 698 ac at CPNPP or approximately 9 percent of the site. Transect 

data collected by Luminant in 2007 (Luminant 2009a) on the peninsula where new cooling 

towers would be located show that grassy openings cover about 24 percent of the transect lines 

surveyed. 

Previously Disturbed. These are areas within the site that are either mechanically or naturally 

disturbed and consist either of bare ground or weedy plant species that are indicators of 

disturbance. This cover type occupies a total of about 60 ac at CPNPP or less than 1 percent of 

the site. 
Appendix F 

May 2011 F-11 NUREG-1943 

Figure 4. Peninsula Where New Cooling Towers for Units 3 and 4 

Would be Located (Enercon 2009)

Developed Areas. Developed areas within the site consist of office buildings, reactors and 

related facilities, switchyards, and storage facilities as well as pavement or gravel for parking 

lots and roads. Also included within this cover type are the dam, spillway, structures related to 

the dam, and the Safe Shutdown Impoundment and its equalization channel. This cover type 

occupies a total of about 439 ac at CPNPP or approximately 6 percent of the site. 

Open Water. The open water type at CPNPP consists primarily of Squaw Creek Reservoir 

(SCR), the Safe Shutdown Impoundment, evaporation ponds for nonradioactive waste water, 

and an emergency spillway. Because of SCR, open water is the most extensive cover type on 

the site and occupies a total of about 3125 ac or approximately 39 percent. 

Wetlands. Wetlands are areas transitional between land and open water. At CPNPP small 

areas of wetland occur primarily in and along the shoreline of coves on SCR. Wetlands occupy 

a total of about 53 ac at CPNPP or less than 1 percent of the site. 

The electric transmission lines and pipelines originating from CPNPP cross forested and range 

habitats typical of north-central Texas, predominantly grassland with patches of deciduous and 

evergreen forest. Acreages of vegetation types likely to be crossed by new transmission and 

pipeline ROWs are shown in Table 2. Acreages of vegetation types to be crossed cannot be 

determined precisely until the exact ROW boundaries are determined. 

Below is a brief description of the construction, operation, and related activities that could 

potentially affect federally listed threatened or endangered terrestrial species, should any be 

present. The determination of potential effects was based on habitat affinities and life history 

considerations, as well as the nature and spatial and temporal considerations of the activities. 
Appendix F 

NUREG-1943 F-12 May 2011 

Figure. 5. Approximate Location of 400 ac BDTF and Associated Evaporation and Storage 

Ponds (Adapted from Luminant 2009a)
Appendix F 

May 2011 F-13 NUREG-1943 

Table 2. Acreages of Vegetation Types Likely to be Crossed by New Transmission and 

Pipeline Right-of-Way

Cover Type Whitney DeCordova Cooling Water 

Pipeline 

Water 3.1 11.0 0.2 

Developed 20.7 12.9 7.7 

Barren Land 0.4 0.9 0.2 

Deciduous Forest 176.1 10.1 6.3 

Evergreen Forest 137.0 3.1 3.7 

Mixed Forest 0.0 0.0 0.0 

Scrub/Shrub 0.0 0.0 0.0 

Grassland 550.0 107.5 31.4 

Pasture 35.8 1.3 0.0 

Cropland 7.6 0.0 0.4 

Woody Wetlands 22.9 1.6 0.1 

Total 953.6 148.4 50.0 

Source: Luminant 2009a. 

3.0 Proposed Federal Actions 

The proposed federal actions are (1) NRC’s issuance of two COLs for the construction and 

operation of two new nuclear reactors at the proposed CPNPP site pursuant to Title 10 of the 

Code of Federal Regulations (CFR), Section 52.97 (10 CFR 52.97),, and (2) the USACE’s 

issuance of a DA permit pursuant to Section 404 of the Clean Water Act, and Section 10 of the 

Rivers and Harbors Act of 1899. 

The NRC, in a final rule dated October 9, 2007 (72 FR 57416), limited the definition of 

“construction” in 10 CFR 50.10 and to those activities that fall within its regulatory authority in 10 

CFR 51.4. Many of the activities required to build a nuclear power plant are not part of the NRC 

action to license the plant. Activities associated with building the plant that are not within the 

purview of the NRC action are grouped under the term “preconstruction.” Examples of 

preconstruction activities include the clearing and grading, building support buildings, and building 

transmission lines. Preconstruction activities may take place before the application for a COL is 

submitted, during the staff’s review of a COL application, or after a COL is granted. Although 

preconstruction activities are outside the NRC’s regulatory authority, many of them are within the 

regulatory authority of local, State, or other Federal agencies. The distinction between 

construction and preconstruction is not carried forward in this BA, and both are discussed jointly 

as construction for the purposes of this BA prepared jointly by NRC and USACE. 

The 7950-ac CPNPP site lies around SCR (Figure 6). Units 3 and 4 would be placed on the 

peninsula where Units 1 and 2 are located in areas of previously disturbed habitat and some 

adjoining undeveloped land. Cooling towers would be built on undisturbed land on a peninsula 

adjacent to and west of the new units, and the BDTF would be located in largely undisturbed 

habitat 
Appendix F 

NUREG-1943 F-14 May 2011 

Figure 6. Location of Proposed CPNPP Units 3 and 4 in Relation to Existing Units 1 

and 2 (Luminant 2009a

southeast of Units 1 and 2 below the SCR dam. The BDTF would remove salt via evaporation 

and reverse osmosis from used cooling water before returning it to its source, Lake Granbury. 

The DeCordova transmission line would leave the site and extend northeast to DeCordova. The 

Whitney transmission line would leave the site along a route to the south to Whitney (Figure 2). 

The cooling water pipeline would leave the site and extend northeast to Lake Granbury. Exact 

routes for these proposed new lines have not yet been determined. Specific locations would be 
Appendix F 

May 2011 F-15 NUREG-1943 

determined through a Routing Study Process considering environmental impacts, conducted 

under review of the Public Utility Commission of Texas (Luminant 2009a). 

The development (construction and preconstruction) and operation activities that could affect 

federally listed species include the following: 

Development (Construction and Preconstruction) 

 Removal (clearing) of habitat used by federally threatened or endangered terrestrial species 

for development of reactors and support structures. 

 Removal (clearing) of habitat used by federally threatened or endangered terrestrial species 

for development of new transmission and pipeline ROWs. 

 Fragmentation of habitat and interference with movement of wildlife. 

 Generation of sediment and fugitive dust. 

 Generation of noise by construction equipment and personnel. 

 Possible avian collisions with tall equipment or structures such as construction cranes or 

transmission towers. 

Operation 

 Potential impacts of noise, salt drift, fogging, and icing from operation of reactor cooling 

systems, should suitable habitat be present. 

 Potential impacts of required periodic vegetation maintenance on reactor grounds and 

transmission line and pipeline ROWs. 

Construction and Preconstruction: A total of 675 ac at the CPNPP site would be affected by 

construction and preconstruction activities for Units 3 and 4 and support structures, including 

the cooling towers and BDTF and associated evaporation ponds (Luminant 2009a). Of this area 

125 ac would be revegetated, and 550 ac would be occupied by various structures. The habitat 

that would be affected consists of 413 ac of Ashe juniper, 63 ac of mixed hardwood, 94 ac of 

grassland, and 105 ac that has already been developed (Luminant 2009a). These activities 

would result in loss of habitat in the areas developed as structures, and alteration of the 

remaining affected areas which would be revegetated. During clearing activities, as well as 

throughout preconstruction and construction work, nearby wildlife could be temporarily 

displaced and disturbed by noise. 

Building power lines and pipelines on new ROWs would result in a relatively small amount of 

permanent habitat loss for towers, access roads, and other structures. Most of the land crossed 

would not be occupied by permanent structures. Tower locations could be adjusted in the field 

to avoid particularly ecologically sensitive areas. Forested areas would be initially cleared, 

resulting in loss of forest habitat and fragmentation of remaining forest areas. Grassland areas 

would not be permanently altered, but all new ROWs would require vegetation management to 

keep woody species from becoming established and interfering with operations. As shown in 

Table 2, forested area to be crossed and managed would be approximately 313 ac for the 

Whitney transmission line, 13 ac for the DeCordova transmission line, and 10 ac for the cooling 

water pipeline. Actual acreages cannot be determined until exact routes for these lines have 

been selected. 

Operation: Wildlife present in locales adjacent to areas cleared by project activities could be 

affected by operation of the new structures associated with Units 3 and 4. Potential impacts 

from operation of cooling towers and the BDTF include increased fogging, icing, and salt drift 
Appendix F 

NUREG-1943 F-16 May 2011 

from evaporated water. Wildlife present along new transmission line and pipeline ROWs would 

be affected by periodic vegetation management of these areas. 

The transmission lines to be constructed are 385-kV (Luminant 2009a). This voltage is 

relatively small for major transmission lines; no electromagnetic effects to nearby flora and 

fauna would be expected (NRC 1996). 

4.0 Species Descriptions 

Federally threatened or endangered species listed by USFWS as occurring in Hood, Somervell, 

or Bosque counties are all birds: black-capped vireo (Vireo atricapillus), golden-cheeked 

warbler (Dendroica chrysoparia), and whooping crane (Grus americana) (USFWS 2010). There 

are two additional species (both fish) potentially occurring in Hood and Somervell Counties that 

are designated by USFWS as Federal candidates for listing: the sharpnose shiner 

(Notropis oxyrhynchus) and the smalleye shiner (Notropis buccula). Candidate species are 

under consideration for listing but are not currently protected under the ESA: therefore they are 

not addressed further in this BA. No critical habitat for these species has been designated 

within these counties (50 CFR Part 17.11). 

There are no known Federally listed aquatic species recorded as occurring in the three counties 

in which CPNPP Units 3 and 4 (Hood and Somervell Counties) and the proposed new 

transmission line ROWs (Somervell and Bosque Counties) would be located. 

4.1 Whooping crane 

The whooping crane is listed as occurring in Hood, Somervell, and Bosque Counties 

(USFWS 2010). Critical wintering habitat for the whooping crane lies approximately 525 mi 

southwest of the site at the Aransas National Wildlife Refuge. This species has not been 

observed on the CPNPP site (Luminant 2009a). No known occurrences of whooping cranes 

have been reported within a 10-mi radius of the CPNPP site, or the proposed powerline and 

pipeline corridors (TPWD 2009), and they are not likely to use the inland habitats found on the 

CPNPP site for foraging, roosting, or nesting. Therefore they are not considered further in this 

BA. 

4.2 Black-capped vireo 

Black-capped vireos are small, about 4.5 inches size, insectivorous, migratory songbirds found 

only in Oklahoma and Texas. Black-capped vireos prefer patchy woodlands or shrublands. 

Males are characterized by olive-green backs, white stomachs, and black caps with a white 

patch around a reddish eye. Females are more cryptic in color than males with dark coloration 

along their backs (Campbell 2003, Grzybowski 1995, USFWS 1991). 

The black-capped vireo was Federally listed as endangered in 1987 due to threats from brownheaded cowbird (Molothrus ater) nest parasitism and loss of habitat due to such factors as 

urbanization, grazing, range improvement, and succession (52 FR 37420). A more recent 

status review of this species recommended the black-capped vireo be downlisted to Federally 

threatened due to finding that the known population is much larger than at the time of listing, 

and that while original threats to the species still exist, their magnitude has decreased 

(USFWS 2007). 
Appendix F 

May 2011 F-17 NUREG-1943 

Black-capped vireos arrive in Texas from mid-March to mid-April. Breeding habitat is quite 

variable across its range, but generally consists of shrublands with a distinctive patchy structure 

(USFWS 2007). They nest in areas with 30–60 percent cover of deciduous trees. Their 

preferred habitat contains woody plants in excess of 6 ft high with cover extending to the 

ground. Open grasslands play an important role in habitat, providing foraging areas for the 

vireos (Campbell 2003, Graber 1961). Home ranges vary from 3–10 ac (Campbell 2003, 

Graber 1961). Males and females both contribute to nest site selection and building, often in a 

fork of a deciduous tree branch (Grzybowski 1995). Black-capped vireos may live for more than 

five years, and usually return year after year to the same territory. They begin to migrate to the 

wintering grounds on Mexico’s western coast in July and are usually gone from Texas by midSeptember (USFWS 2007). 

Habitat losses have occurred through development, overbrowsing, and suppression and 

alteration of natural disturbance regimes. Cowbird nest parasitism has reduced vireo 

reproduction in many areas (USFWS 1991). Much of the current threat can largely be attributed 

to the invasion and growth of juniper species, especially Ashe juniper (USFWS 2007). Juniper 

invasion has contributed to an overall afforestation of rangeland habitats throughout much of the 

species’ breeding range (USFWS 2007). Suppression of fire has favored the spread of junipers 

over fire-adapted Quercus and Rhus species, resulting in loss of black-capped vireo habitat 

(USFWS 1991). 

4.3 Golden-cheeked warbler 

Golden-cheeked warblers are small migratory insectivorous songbirds, about 5 in long, which 

are characterized by yellow cheeks bisected by a black streak extending across the eye. Males 

and females are similar in appearance, although females are drabber in color (Campbell 2003, 

Ladd and Gass 1999). They are endemic to Texas during the breeding season, and certain 

upland sites within mature Ashe juniper forest at CPNPP may provide appropriate habitat 

(Luminant 2009a). During non-breeding season the range includes portions of Mexico, 

Guatemala, Honduras, and Nicaragua (USFWS 1992). 

The golden-cheeked warbler was Federally listed as endangered in 1990 (55 FR 53153) due to 

habitat loss and fragmentation resulting from urban encroachment into its range and widespread 

clearing of juniper as a range management practice. Brown-headed cowbird parasitism has 

increased in magnitude as habitat becomes more fragmented. A 5-year review to ensure that 

the classification of this species is still accurate was announced on April 21, 2006 

(71 FR 20714); to date its listing status has not changed (USFWS 2010). 

Golden-cheeked warblers are dependent on Ashe juniper, but also require stands mixed with 

oaks, elms, and other hardwoods in relatively moist areas, such as steep canyons and slopes, 

and adjacent uplands (USFWS 1992). Kroll (1980) reported that occupied golden-cheeked 

warbler habitats had lower juniper-oak ratio (1.35:1), contained junipers over 40 years old, and 

had lower understory diversity than unoccupied areas. Older Ashe junipers have peeling bark 

that is an essential component of golden-cheeked warbler nest construction. Older Ashe 

junipers are utilized as calling sites during mating. 

Breeding territory size estimates range from about 3.2 ac (Pulich 1976) to about 19.8 ac 

(Kroll 1980) per pair. Wahl et al (1990) reported the median density for all study sites with 

golden-cheeked warblers to be 16.5 ac per pair. 

After females arrive in March, mating begins and extends until April or May. Decline of goldencheeked warblers is attributed to habitat loss and fragmentation due to range improvement 
Appendix F 

NUREG-1943 F-18 May 2011 

practices, rapid urban development, flood control, and construction of impoundments (Ladd and 

Gass 1999). Nest parasitism by the brown-headed cowbird, and competition with blue jays 

(Cyanocitta cristata) have also contributed to population declines (Campbell 2003, Engels and 

Sexton 1994). The USFWS along with TPWD have implemented land-owner management 

plans and Safe Harbor Agreements to protect and enhance existing and potential goldencheeked warbler habitat (Campbell 2003, Ladd and Gass 1999, USFWS 1992). 

5.0 Potential Environmental Effects 

of the Proposed Actions 

This section describes potential impacts to black-capped vireo and golden-cheeked warbler 

from development and operation of the proposed Units 3 and 4 at the CPNPP site.

5.1 Black-capped vireo 

CPNPP site: Ten occurrences of black-capped vireo have been reported in the Texas Natural 

Diversity Database (TXNDD) for the area within 10 mi of the CPNPP site and new transmission 

and pipelines (TPWD 2009). None of the reported occurrences, however, is closer than about 

2.5 mi to the CPNPP site. 

Nevertheless, to determine whether black-capped vireos might use habitats at the site, 

Luminant conducted informal surveys during April 2007 at various times of the day over the 

course of three days at CPNPP concentrating on the peninsula area proposed for construction 

of the new cooling towers (Figure 4) (Luminant 2009a). Survey methods consisted of walking 

transects on east/west axes spaced approximately 100 m (328ft) apart. Black-capped vireos 

were not audibly or visually identified, and no suitable breeding habitat was noted (Luminant 

2009a). During an early May visit in 2007, a woven, pendulous nest was noted in a low tree 

branch. This nest may have been constructed by an unidentified vireo species, or possibly by a 

golden-cheeked warbler (Luminant 2009a). In April and May of 2008 the same area was 

surveyed again, but this time looking specifically for golden-cheeked warblers; presence of other 

bird species was noted and black-capped vireos was not reported (PBS&J 2008). 

DeCordova power transmission line, and cooling water pipeline: Neither the DeCordova 

transmission line ROW, nor the cooling water pipeline ROW, lie closer than about 2.5 mi to any 

TXNDD reported occurrence of black-capped vireo (TPWD 2009). 

Whitney power transmission line: Recorded occurrences of black-capped vireo have been 

documented about 2.5 mi southwest of the CPNPP site in Dinosaur Valley State Park where 

breeding populations of both species occur (TPWD 2009). The Whitney transmission line ROW 

might pass very close to, or possibly through, a small portion of the northwest corner of the 

park. Depending on the exact ROW that Oncor ultimately chooses, black-capped vireo habitat 

in Dinosaur Valley State Park, and possibly at other locations along the Whitney ROW, could be 

noticeably affected. Suitable breeding habitat could be lost, and nest parasitism by brownheaded cowbird could be increased due to additional forest fragmentation. 

Regulatory Coordination: Oncor would coordination with TPWD and USFWS to determine 

the potential for impacts to black-capped vireo would be undertaken as part of the 

environmental review process of the Electric Reliability Council of Texas (ERCOT) and the 

Public Utility Commission of Texas (PUCT) once it selects the exact ROW (Luminant 2009a). It 

is likely that with possible rerouting of the ROW, adjustment of tower placement, and timing of 

site preparation activities to avoid the breeding season, impacts to black-capped vireo could be 
Appendix F 

May 2011 F-19 NUREG-1943 

minimized or avoided. The review team expects that Oncor could adjust the exact ROW 

location and tower placement, as well as time project activities to avoid the breeding season, in 

a way that avoids or minimizes impacts to black-capped vireo. 

5.2 Golden-cheeked warbler 

This section describes potential impacts to golden-cheeked warbler from development and 

operation of the proposed Units 3 and 4 at the CPNPP site. 

CPNPP site: Thirteen occurrences of golden-cheeked warbler have been reported in the Texas 

Natural Diversity Database (TXNDD) for the area within 10 mi of the CPNPP site and new 

transmission and pipelines (TPWD 2009). None of these, however, is closer than about 2.5 mi 

to the CPNPP site. 

Nevertheless, to determine whether golden-cheeked warblers might use habitats at the site, an 

informal survey for them was conducted during April 2007 at various times of the day over the 

course of three days at CPNPP concentrating on the peninsula area proposed for construction 

of the new cooling towers (Figure 7). Survey methods consisted of walking transects on 

east/west axes spaced approximately 100 m (328 ft) apart. Golden-cheeked warblers were not 

audibly or visually identified (Luminant 2009a). During a separate visit in early May in 2007, a 

woven, pendulous nest was noted in a low tree branch. This nest may have been constructed 

by an unidentified vireo species, or possibly by a golden-cheeked warbler (Luminant 2009a). In 

2007 on the last day of the breeding season, May 15th, a targeted presence/absence survey for 

golden-cheeked warblers on the peninsula area was conducted, and again no visual or audio 

confirmation of golden-cheeked warbler presence was noted (PBS&J 2007). The biologist 

conducting the 2007 survey noted that most of the area of the peninsula would not be 

considered golden-cheeked warbler habitat due to the lack of a 20-percent mixture of 

hardwoods (PBS&J 2007). However, at a stream confluence at the southern base of the 

peninsula contained a slight mixture of hardwoods along the stream channels that would be 

considered as having very minimal characteristics associated with golden-cheeked warbler 

habitat (PBS&J 2007). 

In April and May of 2008, during the breeding season for golden-cheeked warbler, a second 

targeted presence/absence survey was conducted to USFWS protocol on the peninsula area 

(Figure 7) (PBS&J 2008). No golden-cheeked warblers were observed within the project survey 

area (PBS&J 2008). As in the 2007 survey, most of the peninsula area was judged not to meet 

golden-cheeked warbler habitat requirements, but one 3.7 ac area of a mixture of Ashe juniper 

and hardwoods at the confluence of three streams (outlined in red on Figure 7) was considered 

to exhibit marginal golden-cheeked warbler nesting habitat characteristics (PBS&J 2008). The 

investigators did not consider this area to be favorable for use as breeding/nesting habitat, 

however, because: 

These areas are lacking in extended habitat characteristics (canopy cover, hardwood 

diversity, and structural characteristics) beyond the vegetation surrounding the stream 

channel perimeter, and are therefore isolated from any nearby populations. The sum of 

the primary survey area (i.e., the potential golden-cheeked warbler habitat) is 3.7 acres, 

and is spread out across three thin corridors; this area is considered to be highly 

fragmented and too small in size to support favorable nesting conditions (PBS&J 2008). 
Appendix F 

NUREG-1943 F-20 May 2011 

Figure 7. Area Surveyed in Targeted Golden Cheeked Warbler Survey Conducted to USFWS 

Protocol in 2008 (PBS&J 2008)
Appendix F 

May 2011 F-21 NUREG-1943 

The 3.7 ac area was discussed at a scoping meeting with USFWS and TPWD held at CPNPP 

on February 2, 2009. It was noted that this area is surrounded by a small wetland, and USFWS 

recommended avoiding the wetland by an additional 100 ft buffer to provide a wildlife corridor in 

addition to a vegetative run-off “filter” to protect water quality (Edwards 2009). Current project 

plans, however, show that much of this area would be lost to project development (Enercon 

2009). 

An additional portion of the CPNPP site to be directly affected by development that could 

possibly contain suitable habitat for the golden-cheeked warbler is the 400-ac area that would 

be occupied by the BDTF and associated evaporation ponds (Figure 6). This area contains 

Ashe juniper habitat and smaller areas of mixed hardwood (Figure 4). To learn of habitat 

suitability, infrared aerial photographs of the area were examined to determine which areas 

would provide potential nesting habitat for the golden-cheeked warbler based on habitat 

descriptions provided by the USFWS (Luminant 2009a). Photographic signatures of tree 

species were used to identify areas that might require focused surveys. Areas were identified 

that had a mixture of Ashe juniper and deciduous hardwoods. These areas were groundtruthed by a visual qualitative analysis of density, canopy cover, and tree age on November 14, 

2007 to determine if habitat was present that would be suitable for golden-cheeked warblers 

(Luminant 2009a). The comparison was based on percent cover of hardwood and evergreen 

canopy from point-transect data taken within a known golden-cheeked warbler site in Dinosaur 

Valley State Park. It was determined that the BDTF area did not contain the density and 

maturity of Ashe junipers necessary to qualify as suitable for golden-cheeked warblers 

(Luminant 2009a). Canopy cover in and adjacent to the BDTF was found to be only about 

20 percent, which is less than the 35 percent minimum thought to be required (Luminant 

2010a). Additional site reconnaissance performed on February 4, 2009 reconfirmed absence of 

suitable golden-cheeked warbler habitat in the area of the BDTF (Luminant 2009a). 

It is unknown whether the additional Ashe juniper and hardwood cover type areas in the vicinity 

of the proposed BDTF, especially the isolated peninsula to the north (see Figure 4), could be 

suitable golden-cheeked warbler habitat. No golden-cheeked warbler surveys are known to 

have been performed in these areas. Depending on the location and design chosen for the 

BDTF, areas outside of the 400 ac could be affected by salt drift. Although salt drift from the 

misting system proposed to evaporate water at the BDTF has not been modeled in detail, salt 

concentrations leaving the misters would be approximately 576 kg/min (Luminant 2009a). 

Luminant estimates that salt drift from the misting units could be deposited up to 1300 ft from 

the source with a wind speed of 10 mph (Luminant 2009b). The tentative location of the 

evaporation pond is close to the CPNPP site boundary (Figure 5) and vegetation in the vicinity 

is primarily Ashe juniper woodland - savanna (Figure 3). Although the exact location of the 

BDTF has not yet been determined, Luminant provided a conceptual sketch of the location of 

the ponds within the 400 ac to be occupied by the BDTF (Figure 8) (Luminant 2010b). 

Luminant’s response states that a salt fence would surround the evaporation ponds, and a 500 

ft wide buffer would be provided between the first bank of misters and the outside edge of the 

evaporation ponds to provide sufficient distance between the mister nozzles and the salt fence 

barrier to ensure proper functioning of the salt fence to prevent drift (Luminant 2010b). The salt 

fence referred to by Luminant (Luminant 2010c) would be a 5 m (16 ft) high agricultural shade 

cloth netting which would be attached to a framework at the top, but loose at the bottom so it 

could blow in the wind to cause the fabric to shed accumulated salt. The manufacturer of the 

netting claims that salt passing through the netting falls out within one meter (3 ft) (Turbomist 

2010). Further, Luminant states that precautions will be taken to contain the salt within the 
NUREG-1943 F-22 May 2011 

Appendix F 

Figure 8. Schematic Layout of the Proposed Blowdown Treatment Facility Showing Distances from the Misters to Nearby 

Locations (Adapted from Luminant 2010b)
Appendix F 

May 2011 F-23 NUREG-1943 

BDTF by using directional spray misting units in addition to the salt fences (Luminant 2010a). 

With these measures in place, Luminant estimates that salt deposition is anticipated to be less 

than 1 kg/ha/yr beyond the 400 ac of the BDTF (Luminant 2010c), which is less than what the 

NRC recognized as capable of injuring vegetation (NRC 2000). 

The information provided by Luminant (Turbomist 2010) is not extensive enough to completely 

eliminate uncertainty regarding the potential for salt to be deposited beyond one meter from the 

salt fence. Luminant states that without the salt fence salt could drift 1300 ft from the misters 

(Luminant 2010b). If salt drifts to that distance then the review team estimates that deposition 

could spread over an area of about 199 ac beyond the evaporation pond (Quarles 2010). Much 

of this areal extent would be within the 400-ac area to be cleared for building the BDTF where 

the native vegetation would have been removed. 

Potential for salt drift may be greater than 1300 ft, however. A study of salt deposition from an 

evaporative spray system using the same general type of mister proposed by Luminant found 

that deposition rates of salt were substantially increased at a distance of 2096 to 3484 ft 

surrounding the misters (Alonso et al. 2005). Based on Luminant’s sketch of mister locations 

(Luminant 2010b) the review team estimates that this could result in drift over a total area 

beyond the evaporation pond of about 494 to 1226 ac. The area of increased salt deposition, 

assuming drift over the range of 1300 to 3484 ft, would extend over some or all of a peninsula to 

the north of the proposed BDTF location and covered by Ashe juniper woodland – savanna and 

mixed hardwood forest (Figure 3). 

Considering the limited case history data available to the review team regarding the misters and 

the salt fence, it is uncertain if the measures (including but not limited to salt fence, and 

unidirectional operation of the misters) proposed by Luminant could completely prevent salt drift 

from the BDTF from affecting nearby natural vegetation. Salt deposition potential from the 

BDTF has not been quantified further because the facility is only in conceptual design phase. 

Due to the high volumes of salt that would be processed by the facility, even a small percentage 

loss of salt to the surrounding environment could have the potential to damage vegetation. 

Depending on the exact extent of drift that results from operation of the BDTF, some of the Ashe 

juniper woodland - savanna and mixed hardwood forest habitat on the isolated peninsula to the 

north of the BDTF could be susceptible to salt drift injury. If this area contains suitable habitat 

for golden-cheeked warbler, then salt drift could affect this habitat and thereby affect goldencheeked warbler. Otherwise, impacts to golden-cheeked warbler would be minimal. 

DeCordova power transmission line, and cooling water pipeline: Neither the DeCordova 

transmission line ROW, nor the cooling water pipeline ROW, lies closer than about 2.5 mi to any 

TXNDD reported occurrence of golden-cheeked warbler (TPWD 2009). Recorded occurrences 

of golden-cheeked warbler, however, as well as black-capped vireo, have been documented 

about 2.5 mi southwest of the CPNPP site in Dinosaur Valley State Park where breeding 

populations of both species exist (TPWD 2009). The Whitney transmission line ROW might 

pass very close to, or possibly through, a small portion of the northwest corner of the park. 

Depending on the exact ROW that Oncor ultimately chooses, golden-cheeked warbler in 

Dinosaur Valley State Park, and possibly at other locations along the Whitney ROW, could be 

affected. Suitable breeding habitat could be lost, and predation by brown-headed cowbird could 

be increased due to additional forest fragmentation. 

Regulatory Coordination: Oncor would coordinate with TPWD and USFWS to determine the 

potential for impacts to golden-cheeked warbler as part of the environmental review process of 

ERCOT and PUCT once it selects the exact location of the new ROW (Luminant 2009a). The 

review team expects that Oncor could adjust the exact ROW location and tower placement, as 
Appendix F 

NUREG-1943 F-24 May 2011 

well as time project activities to avoid the breeding season, in a way that avoids or minimizes 

impacts to golden-cheeked warbler. 

6.0 Cumulative Impacts to Federal Protected Species 

In addition to impacts from construction, preconstruction, and operation, the following 

cumulative analysis also considers other past, present, and reasonably foreseeable projects 

that could affect the black-capped vireo and golden-cheeked warbler. For purposes of this 

cumulative analysis, a geographic area of interest is defined as Somervell, Hood, and Bosque 

Counties. These counties encompass the CPNPP site, anticipated transmission line and 

pipeline ROWs, and adjoining areas. They lie almost completely in the Limestone Cut Plain of 

the Western Cross Timbers ecoregion (Griffith et al. 2004). They are expected to encompass 

those other projects capable of interacting with the CPNNP Units 3 and 4 project to affect the 

the black-capped vireo and golden-cheeked warbler. 

Prior to settlement, the landscape in the three counties existed as grassland or open live oak 

savanna that supported herds of bison and other herbivores. Introduction of domestic livestock, 

farming, and wildfire control substantially altered the landscape. Today the landscape consists 

of a mosaic of forest, woodland, savanna, and prairie. The grassland with scattered blackjack 

oak and post oak trees is used mostly for rangeland and pastureland, with some areas of woody 

plant invasion and closed forest. Habitats favored by the black-capped vireo and goldencheeked warbler remain in only scattered locations. 

Since establishment of CPNPP Units 1 and 2, development in the three counties has continued 

and additional habitat for the black-capped vireo and golden-cheeked warbler has been lost or 

modified by farming, ranching, residential development, river and watershed projects, and 

transportation projects. Oil production has been a major activity in the area for over 80 years 

(Griffith et al. 2004), and oil and natural gas exploration and production continue. These trends 

are expected to continue over the projected operating life of proposed Units 3 and 4. 

Current and reasonably foreseeable actions within the three counties that could adversely affect 

the black-capped vireo and golden-cheeked warbler in a similar way to the CPNPP Units 3 and 

4 project include multiple proposed transportation projects, future urbanization, and continued 

oil and gas exploration and development. Other future actions that would contribute to 

cumulative effects include building and upgrading utility lines, including but not limited to those 

for Units 3 and 4; new road development and expansion; continued industrial and urban 

development; increased outdoor recreation; and nonpoint source runoff from agriculture, 

ranching, and development. 

Continued urbanization is a contributing factor to the losses of habitat for the black-capped vireo 

and golden-cheeked warbler. The Texas State Data Center (TSDC) projects that the population 

in a six-county area surrounding the CPNPP site (including Bosque, Erath, Hood, Johnson, 

Somervell, and Tarrant Counties) will increase by 41.5 percent by the year 2040 (TSDC 2009). 

The highest growth in the six-county area is projected to occur in areas close to Fort Worth; 

however, the more outlying counties are still expected to experience substantial growth. Even 

with the anticipated growth, the area around the CPNPP site is likely to continue to be 

predominantly rural in character, with some areas still providing habitat for black-capped vireo 

and golden-cheeked warbler. Recent urbanization in this area has occurred primarily in and 

around the cities of Granbury and Glen Rose. This trend is likely to continue, with most of the 

growth occurring in Hood County around and northeast of Lake Granbury, due primarily to 

recreation home development and commuting patterns associated with Fort Worth. The 

preconstruction, construction, and operations workforce for CPNPP Units 3 and 4 would make 
Appendix F 

May 2011 F-25 NUREG-1943 

only a minor contribution to this increase in the urban growth of the region. The cumulative 

urbanization in the geographic area of interest could reduce habitat available for black-capped 

vireo and golden-cheeked warbler. 

Global climate change is another factor contributing to the loss or degradation of habitat for the 

black-capped vireo and golden-cheeked warbler. The report on Global Climate Change Impacts 

in the United States, provided by the U.S. Global Change Research Program, summarizes the 

projected impacts of future climate changes in the U.S. (Karl et al. 2009). The report divides the 

U.S. into nine regions. The CPNPP site is located in the Great Plains region. The GCRP 

climate models for this region project continued warming in all seasons and an increase of as 

much as 12°F from 2000 to 2090. Additionally, climate models project that there will tend to be 

less rainfall in this area. The GCRP states that the precipitation could possibly alter the 

character of terrestrial habitats in the area, including habitats used by the black-capped vireo 

and golden-cheeked warbler. 

The actions noted above may potentially affect black-capped vireo and golden-cheeked warbler 

by decreasing or degrading available habitat. As noted in Chapter 4 of this BA, the major 

threats to both species are habitat modification, habitat loss, and habitat fragmentation due to 

range management practices and continued development. As noted in Chapter 5 of this BA, 

one of the expanded transmission line ROWs required for CPNPP Units 3 and 4 (the Whitney 

ROW) might pass through habitat occupied by both species. In addition, habitat potentially 

suitable for the golden-cheeked warbler could be altered by salt drift from the BDTF. Habitat 

loss and alteration due to the CPNPP project activities noted above, combined with effects from 

other projects, including non-Federal projects, in the area of geographical interest could be 

sufficient to noticeably alter populations of both species. 

Because suitable black-capped vireo habitat is not available on or close to the CPNPP site, 

DeCordova transmission line ROW, or cooling water pipeline ROW, activities proposed for 

those locations would not contribute to the cumulative effects on black-capped vireo. Activities 

on the Whitney transmission line ROW could however contribute substantially to cumulative 

effects on the black-capped vireo. Activities on both the site and transmission line ROWs could 

substantially contribute to cumulative effects on the golden-cheeked warbler. 

7.0 Conclusions 

The following section presents the conclusions of this BA. 

7.1 CPNPP site, DeCordova power transmission line and 

cooling water pipeline 

Black-capped vireo 

No habitat was seen in these areas; therefore, development and operation of project facilities in 

these locations is not likely to adversely affect black-capped vireos. Therefore, the review team 

concludes that these project elements would have no effect on the black-capped vireo. 

Golden-cheeked warbler 

On-site surveys did not indicate that golden-cheeked warblers are present in the areas 

surveyed; only marginal habitat was observed. However, possible golden-cheeked warbler 

habitat may exist in areas subject to possible salt drift from the BDTF. Should any of these 

areas be suitable for golden-cheeked warbler habitat, then operation at the CPNPP site may 
Appendix F 

NUREG-1943 F-26 May 2011 

affect golden-cheeked warblers. The potential for significant adverse effects is not 

discountable. Therefore, the review team concludes that development and operation of project 

facilities may affect, and is likely to adversely affect the golden-cheeked warblers. 

7.2 Whitney power transmission line 

Black-capped vireo and Golden-cheeked warblers 

If known locations of black capped vireo and golden-cheeked warblers, including Dinosaur 

Valley State Park, are avoided with sufficient buffer, then development and operation of the 

transmission line would not affect these species. If known breeding habitat cannot be avoided, 

then these species may be adversely affected. Because the potential for significant adverse 

effects is not discountable based on information available to the review team, the review team 

concludes that the project may affect, and is likely to adversely affect, the black-capped vireo 

and the golden-cheeked warbler. 

7.3 Summary 

Table 3 summarizes the review team’s conclusions. 

Table 3. Summary and Conclusions

 Black-capped vireo Golden-cheeked warbler 

CPNPP Site No effect May affect, is likely adversely 

affect 

DeCordova line and pipeline No effect No effect 

Whitney line May affect, is likely to 

adversely affect 

May affect, is likely to adversely 

affect 

8.0 References 

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

Production and Utilization Facilities.” 

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

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

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

50 CFR Part 17. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 17, 

“Endangered and Threatened Wildlife and Plants.” 

52 FR 37420. October 6, 1987. Endangered and Threatened Wildlife and Plants; 

Determination of the Black-capped Vireo TO BE an Endangered Species.” Federal Register. 

55 FR 53153. December 27, 1990. “Endangered and Threatened Wildlife and Plants; Final 

Rule to List the Golden-cheeked Warbler as Endangered.” Federal Register. 

71 FR 20714. April 21, 2006. “Endangered and Threatened Wildlife and Plants; 5-Year Review 

of 25 Southwestern Species.” Federal Register. 
Appendix F 

May 2011 F-27 NUREG-1943 

72 FR 57416. October 9, 2007. “Limited Work Authorizations for Nuclear Power Plants.” 

Federal Register. U.S. Nuclear Regulatory Commission. 

73 FR 77076. December 18, 2008. “Luminant Generation Company LLC; Comanche Peak 

Nuclear Power Plant Units 3 and 4 Combined License Application; Notice of Intent To Prepare 

an Environmental Impact Statement and Conduct Scoping Process.” Federal Register. U.S. 

Nuclear Regulatory Commission. 

Alonso, R., A. Bytnerowicz, J.L. Yee, and W.I. Boarman. 2005. Atmospheric Dry Deposition in 

the Vicinity of the Salton Sea, California—II: Measurement and Effects of an Enhanced 

Evaporation System”. Atmospheric Environment 39: 4681–4689. 

Campbell, L. 2003. Endangered and Threatened Animals of Texas. Texas Parks and Wildlife: 

Wildlife Division Publication: PWD BK W7000-013. 

Clean Water Act. (Federal Water Pollution Control Act). 33 USC 1251, et seq. 

Edwards, Sean. 2009. E-mail from Sean Edwards USFWS to Michael Willingham USNRC 

titled Comanche Peak comments. February 19, 2009. 

Enercon. 2009. Wetland and Other Potentially Jurisdictional Waterbody Identification and 

Delineation. Comanche Peak Nuclear Power Plant. No. TXUT-001-PR-015. 

Engels, T.M., and C.W. Sexton. 1994. “Negative Correlation of Blue Jays and GoldenCheeked Warblers near an Urbanizing Area.” Conservation Biology 8(1):286–290. 

Graber, J.W. 1961. “Distribution, Habitat Requirements, and Life History of the Black-Capped 

Vireo (Vireo atricapillus).” Ecological Monographs 31(4):313–336. 

Griffith, Bryce et al. 2004. Ecoregions of Texas (color poster with map, descriptive text, and 

photographs) Reston, Virginia, U.S. Geological Survey (map scale 1:2,500,000). 

Grzybowski, J.A. 1995. Black-Capped Vireo (Vireo atricapillus).” The Birds of North America 

Online, No. 181 (A. Poole and F. Gill, eds.). The Academy of Natural Sciences, Philadelphia, 

and The American Ornithologists’ Union, Washington, D.C. Accessed January 15, 2010, at 

http://bna.birds.cornell.edu/BNA. 

Karl, Thomas R., Jerry M. Melillo, and Thomas C. Peterson (eds.). 2009. Global Climate 

Change Impacts in the United States. Cambridge University Press, New York. Accession 

No. ML100580077. 

Kroll, J.C. 1980. “Habitat Requirements of the Golden-Cheeked Warbler: Management 

Implications.” Journal of Range Management 33(1):60–65. 

Ladd, C. and L. Gass. 1999. “Golden-Cheeked Warbler (Dendroica chrysoparia).” The Birds of 

North America Online, No. 420 (A. Poole and F. Gill, eds.). The Birds of North America, Inc. 

Philadelphia, PA. Accessed March 19, 2007, at http://bna.birds.cornell.edu/BNA. 

Luminant Generation Company (Luminant). 2009a. Comanche Peak Nuclear Power Plant 

Units 3 and 4, COL Application; Part 3, Environmental Report (Rev. 1). Luminant Power 

Generation Company LLC, Glen Rose, Texas, November 20. Accession No. ML100081557. 

Luminant Generation Company (Luminant). 2009b. Letter from R. Flores, Luminant Generation 

Company LLC, to U.S. Nuclear Regulatory Commission, Washington, D.C., “Comanche Peak, 

Units 3 and 4, Supplemental Information in Response to the Request for Additional Information 
Appendix F 

NUREG-1943 F-28 May 2011 

Regarding the Environmental Review,” Docket Nos. 52-034 and 52-035, Luminant Ref No. 

TXNB-09087, December 18. Accession No. ML093620032. 

Luminant Generation Company (Luminant). 2010a. Letter from R. Flores, Luminant Generation 

Company LLC, to U.S. Nuclear Regulatory Commission, Washington, D.C., “Comanche Peak 

Nuclear Power Plant Units 3 and 4, Docket Nos. 52-034 and 52-035, Responses to 

Environmental Review Questions ALT-03 and SOC-33 and Supplemental Information for 

Question TE-04.” Luminant Reference No. TXNB-10021, March 5. Accession No. 

ML100710613. 

Luminant Generation Company (Luminant). 2010b. Letter from R. Flores, Luminant Generation 

Company LLC, to U.S. Nuclear Regulatory Commission, Washington, D.C., “Comanche Peak 

Nuclear Power Plant Units 3 and 4, Docket Nos. 52-034 and 52-035, Supplemental Information 

for Environmental Review Requests for Additional Information GEN-03 and GEN-07,” Luminant 

Ref No. TXNB-10023, March 19. Accession No. ML100820402. 

Luminant Generation Company (Luminant). 2010c. Letter from R. Flores, Luminant Generation 

Company LLC, to U.S. Nuclear Regulatory Commission, Washington, D.C., “Comanche Peak, 

Units 3 and 4, Response to the Request for Additional Information Regarding the Environmental 

Review and Supplemental Information for Previous Environmental Questions,” Docket Nos. 

52-034 and 52-035, Luminant Ref No. TXNB-10013, February 24. Accession No. 

ML100630660. 

PBS&J. 2007. Golden-Cheeked Warbler Bird Survey Report (for) TXU Power, Comanche 

Peak Power Plant, Somervell County, Texas. Prepared for TXU Power, 1601 Bryan Street, 

Dallas, Texas 75201 by PBS&J, 18383 Preston Road, Suite 110, Dallas, Texas 75252. May. 

PBS&J. 2008. Golden-Cheeked Warbler Bird Survey Report (for) Luminant Power, Comanche 

Peak Power Plant, Somervell County, Texas. Prepared for Luminant Power, 1601 Bryan Street, 

Dallas, Texas 75201 by PBS&J, 18383 Preston Road, Suite 110, Dallas, Texas 75252. May. 

Pulich W.M. 1976. The Golden-Cheeked Warbler, a Bio-Ecological Study. Texas Parks and 

Wildlife Department, Austin, Texas. 172 pp. in 55 FR 53153. 

Quarles, H.D. 2010. Calculations Concerning Salt Drift Potential from CPNPP BDTF 

Evaporation Ponds. Oak Ridge National Laboratory, Oak Ridge, Tennessee. May 2010. 

Rivers and Harbors Appropriation Act of 1899, as amended. 33 USC 403, et seq. 

Texas Parks and Wildlife Department (TPWD). 2007. Cross Timbers and Prairies Ecological 

Region. Accessed January 15, 2010, at http://www.tpwd.state.tx.us/landwater/land/habitats/ 

cross_timbers/ecoregions/cross_timbers.phtml. 

Texas Parks and Wildlife Department (TPWD). 2009. Letter from C. Smith, Executive Director 

Texas Parks and Wildlife, Austin, TX, concerning Comanche Peak Nuclear Power Plant Units 3 

and 4 Combined License Application, to M. Lesar, NRC, Washington, D.C. February 16, 2009. 

Texas State Data Center. (TSDC). 2009. 2008 Population Projections—Texas Counties. 

Population Estimates and Projections Program, Texas State Data Center, Office of the State 

Demographer, Institute for Demographic and Socioeconomic Research, The University of Texas 

at San Antonio. February. Accessed May 29, 2009, at 

http://txsdc.utsa.edu/tpepp/2008projections/2008_txpopprj_cntytotnum.php. 
Appendix F 

May 2011 F-29 NUREG-1943 

Turbomist. 2010. Setup Variables—Salt Drift and Netting Waste Water Evaporation Treatment 

Water Mister System. Accessed February 8, 2010, at http://www.turbomister.com/setup/saltdrift-netting.php. 

U.S. Endangered Species Act (ESA). 16 USC 1531 et seq. 

U.S. Fish and Wildlife Service (USFWS). 1991. Black-Capped Vireo (Vireo atricapillus) 

Recovery Plan. 

U.S. Fish and Wildlife Service (USFWS). 1992. Golden-Cheeked Warbler (Dendroica 

chrysoparia) Recovery Plan. 

U.S. Fish and Wildlife Service (USFWS). 2007. Black-Capped Vireo (Vireo atricapillus) 5-Year 

Review: Summary and Evaluation. June 19, 2007. 

U.S. Fish and Wildlife Service (USFWS). 2010. Ecological Services: Southwest Region. 

Accessed January 15, 2010, at 

http://www.fws.gov/southwest/es/EndangeredSpecies/lists/default.cfm. 

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., 

May. Accessed June 16, 2009, at http://www.nrc.gov/reading-rm/doccollections/nuregs/staff/sr1437/. 

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

Reviews for Nuclear Power Plants. NUREG-1555, Volume . Washington, D.C. 

Wermund, E.G. 1996. Physiographic map of Texas. Bureau of Economic Geology. The 

University of Texas at Austin. University Station. Box X. Austin, Texas, 78713. 

Wahl, R.D., D. Diamond, and D. Shaw. 1990. The Golden-Cheeked Warbler: A Status 

Review. Prepared for U.S. Fish and Wildlife Service, Fort Worth, Texas. 63 pp. [In 55 FR 

53153]. 

9.0 Preparers 

Peyton Doub, PWS, CEP, 

B.S. Plant Sciences, M.S. Plant Physiology 

U.S. Nuclear Regulatory Commission 

Harry Quarles 

B.S. Biology, Ph.D. Terrestrial Ecology 

Oak Ridge National Laboratory 

Appendix G 

Supporting Information and Data: 

Population Projections and Health Physics 

 

May 2011 G-1 NUREG-1943 

Appendix G 

Supporting Information and Data: Population 

Projections and Health Physics 

G.1 Population Projections 

Tables G-1 and G-2 provide population projections for 2007 followed by 10-year increments to 

40 years beyond the estimated Comanche Peak Nuclear Power Plant (CPNPP) start-up date in 

2016 (Luminant 2009a). Projections were derived from county estimates that were based on 

the cohort-component method (TSDC 2009). Population projections for the years 2007, 2016, 

2026, 2036, 2046, and 2056 were estimated for each sector using the following methodology: 

1. Using linear and polynomial regression, an equation was derived for each county. This 

equation was then used in conjunction with the 2000 county level census data to produce a 

county growth ratio set for each projected year. 

2. Each set was then weighted by area into sectors and summed. 

3. The 2000 Census block level data were then sorted into the radial grid, weighted by area, 

and summed. 

4. The block level values for each sector were multiplied by their projection ratio, described in 

Step 1, to produce the final population sector tables (Tables G-1 and G-2) (Luminant 2009a, 

TSDC 2009). 

Tables G-3 and G-4 provide transient population data that correspond by sector. 
Appendix G 

NUREG-1943 G-2 May 2011 

Table G-1. The Projected Permanent Population for Each Sector 0–16 km (10 mi) for Years 2007, 2016, 

2026, 2036, 2046, and 2056

Direction / Year 

Sector 

0-2 

(km) 

2-4 

(km) 

4-6 

(km) 

6-8 

(km) 

8-10 

(km) 

10-16 

(km) 

0-16 

(km) 

NORTH 

2007 

2016 

2026 

2036 

2046 

2056 

0 

0 

0 

0 

0 

0 

16 

18 

21 

24 

27 

29

51 

59 

67 

76 

85 

94

154 

179 

206 

233 

260 

287

337 

390 

450 

509 

568 

628 

9395 

10,884 

12,540 

14,195 

15,850 

17,506 

9953 

11,530 

13,284 

15,037 

16,790 

18,544

NNE 

2007 

2016 

2026 

2036 

2046 

2056 

1 

1 

1 

1 

1 

1 

18 

21 

24 

26 

29 

32

39 

45 

52 

59 

66 

73

113 

131 

151 

171 

191 

210

220 

255 

293 

332 

371 

409 

6379 

7391 

8515 

9639 

10,763 

11,887 

6770 

7844 

9036 

10,228 

11,421 

12,612

NE 

2007 

2016 

2026 

2036 

2046 

2056 

0 

0 

0 

0 

0 

0 

15 

17 

19 

21 

23 

25

112 

130 

150 

170 

190 

209

161 

186 

214 

243 

271 

299

359 

416 

479 

542 

605 

668 

2296 

2660 

3065 

3469 

3874 

4279 

2943 

3409 

3927 

4445 

4963 

5480

ENE 

2007 

2016 

2026 

2036 

2046 

2056 

0 

0 

0 

0 

0 

0 

2 

2 

3 

3 

3 

3

36 

40 

45 

49 

54 

58

84 

95 

108 

121 

133 

146

271 

311 

355 

399 

443 

488 

2566 

2970 

3867 

4315 

4315 

4763 

2959 

3418 

3929 

4439 

4948 

5458

EAST 

2007 

2016 

2026 

2036 

2046 

2056 

0 

0 

0 

0 

0 

0 

5 

6 

6 

7 

8 

8

131 

145 

159 

174 

188 

203

29 

32 

35 

39 

42 

45

54 

60 

66 

72 

78 

84 

161 

177 

195 

213 

232 

250 

380 

420 

461 

505 

548 

590
Appendix G 

May 2011 G-3 NUREG-1943

Table G-1. (contd)

Direction / Year 

Sector 

0-2 

(km) 

2-4 

(km) 

4-6 

(km) 

6-8 

(km) 

8-10 

(km) 

10-16 

(km) 

0-16 

(km) 

ESE 

2007 

2016 

2026 

2036 

2046 

2056 

0 

0 

0 

0 

0 

0 

23 

25 

27 

30 

33 

35

57 

62 

69 

75 

81 

87

111 

123 

135 

147 

160 

172

247 

272 

299 

327 

355 

382 

495 

544 

600 

655 

710 

765 

933 

1026 

1131 

1234 

1339 

1442

SE 

2007 

2016 

2026 

2036 

2046 

2056 

0 

0 

0 

0 

0 

0 

71 

79 

87 

95 

102 

110

89 

98 

108 

117 

127 

137

135 

148 

163 

178 

193 

208

316 

348 

383 

419 

454 

489 

304 

335 

369 

403 

437 

471 

915 

1008 

1110 

1212 

1313 

1415

SSE 

2007 

2016 

2026 

2036 

2046 

2056 

0 

0 

0 

0 

0 

0 

140 

154 

169 

185 

200 

216

109 

120 

132 

144 

156 

168

799 

879 

968 

1057 

1146 

1235

1516 

1668 

1837 

2006 

2175 

2344 

598 

658 

725 

791 

858 

925 

3162 

3479 

3831 

4183 

4535 

4888

SSW 

2007 

2016 

2026 

2036 

2046 

2056 

29 

32 

35 

38 

41 

44 

67 

74 

81 

89 

96 

104

20 

22 

25 

27 

29 

32

25 

27 

30 

33 

36 

38

40 

44 

48 

52 

57 

61 

193 

213 

234 

256 

277 

299 

374 

412 

453 

495 

536 

578

SW 

2007 

2016 

2026 

2036 

2046 

2056 

28 

31 

34 

37 

40 

43 

51 

56 

62 

68 

73 

79

31 

35 

38 

42 

45 

49

44 

48 

53 

58 

63 

67

42 

46 

51 

55 

60 

65 

92 

101 

112 

122 

132 

143 

288 

317 

350 

382 

413 

446
Appendix G 

NUREG-1943 G-4 May 2011 

Table G-1. (contd)

Direction / Year 

Sector 

0-2 

(km) 

2-4 

(km) 

4-6 

(km) 

6-8 

(km) 

8-10 

(km) 

10-16 

(km) 

0-16 

(km) 

WSW 

2007 

2016 

2026 

2036 

2046 

2056 

39 

43 

47 

52 

56 

61 

31 

34 

37 

41 

44 

48

40 

45 

50 

54 

59 

64

23 

26 

29 

32 

36 

39

44 

50 

56 

62 

69 

75 

73 

83 

94 

105 

115 

126 

250 

281 

313 

346 

379 

413

WEST 

2007 

2016 

2026 

2036 

2046 

2056 

12 

14 

15 

16 

18 

19 

12 

14 

16 

17 

19 

21

49 

57 

65 

74 

83 

91

101 

117 

135 

153 

170 

188

45 

52 

60 

68 

76 

83 

119 

138 

159 

180 

201 

222 

338 

392 

450 

508 

567 

624

WNW 

2007 

2016 

2026 

2036 

2046 

2056 

1 

1 

1 

1 

1 

1 

5 

6 

7 

8 

9 

10

22 

26 

29 

33 

37 

41

68 

79 

91 

103 

115 

127

77 

89 

102 

116 

130 

143 

216 

250 

288 

326 

364 

402 

389 

451 

518 

587 

656 

724

NW 

2007 

2016 

2026 

2036 

2046 

2056 

1 

1 

1 

1 

1 

1 

2 

3 

3 

4 

4 

4

6 

7 

8 

9 

10 

11

4 

4 

5 

5 

6 

7

27 

32 

37 

41 

46 

51 

985 

1141 

1315 

1488 

1662 

1835 

1025 

1188 

1369 

1548 

1729 

1909

NNW 

2007 

2016 

2026 

2036 

2046 

2056 

1 

1 

1 

1 

1 

1 

4 

4 

5 

6 

6 

7

16 

18 

21 

24 

26 

29

63 

73 

85 

96 

107 

118

169 

196 

226 

256 

285 

315 

851 

986 

1136 

1286 

1436 

1585 

1103 

1277 

1473 

1668 

1860 

2054
Appendix G 

May 2011 G-5 NUREG-1943

Table G-1. (contd)

Direction / Year 

Sector 

0-2 

(km) 

2-4 

(km) 

4-6 

(km) 

6-8 

(km) 

8-10 

(km) 

10-16 

(km) 

0-16 

(km) 

Totals 

2007 

2016 

2026 

2036 

2046 

2056 

119 

131 

143 

156 

169 

182 

542 

601 

665 

730 

791 

855

832 

935 

1047 

1159 

1271 

1384

2038 

2283 

2558 

2832 

3106 

3377

3832 

4304 

4825 

5347 

5870 

6391 

25,088 

28,932 

33,207 

37,478 

41,749 

46,022 

32,451 

37,186 

42,445 

47,702 

52,956 

58,211

Cumulative Totals 0-2 

(km) 

0-4 

(km) 

0-6 

(km) 

0-8 

(km) 

0-10 

(km) 

0-16 

(km) 

 2007 

2016 

2026 

2036 

2046 

2056 

119 

131 

143 

156 

169 

182 

661 

732 

808 

886 

960 

1037

1493 

1667 

1855 

2045 

2231 

2421

3531 

3950 

4413 

4877 

5337 

5798

7363 

8254 

9238 

10,224 

11,207 

12,189 

32,451 

37,186 

42,445 

47,702 

52,956 

58,211 

Source: Luminant 2009a, TSDC 2009 

Table G-2. The Projected Permanent Population for Each Sector 16 km (10 mi)–80 km (50 mi) for 

Years 2007, 2016, 2026, 2036, 2046, and 2056

Direction / Year 

Sector 

16-40 

(km) 

40-60 

(km) 

60-80 

(km) 

16-80 

(km) 

NORTH 

2007 

2016 

2026 

2036 

2046 

2056 

11,320 

13,082 

15,040 

16,997 

18,955 

20,913 

37,256 

42,981 

49,342 

55,702 

62,063 

68,424 

17,904 

20,702 

23,811 

26,920 

30,028 

33,137 

66,480 

76,765 

88,193 

99,619 

111,046 

122,474 

NNE 

2007 

2016 

2026 

2036 

2046 

2056 

7586 

8777 

10,099 

11,422 

12,745 

14,067 

61,636 

70,856 

81,100 

91,345 

101,589 

111,834 

91,401 

104,610 

119,287 

133,964 

148,641 

163,318 

160,623 

184,243 

210,486 

236,731 

262,975 

289,219 
Appendix G 

NUREG-1943 G-6 May 2011 

Table G-2. (contd)

Direction / Year 

Sector 

16-40 

(km) 

40-60 

(km) 

60-80 

(km) 

16-80 

(km) 

NE 

2007 

2016 

2026 

2036 

2046 

2056 

5896 

6963 

8149 

9335 

10,521 

11,707 

207,161 

237,503 

271,217 

304,930 

338,644 

372,358 

646,328 

736,399 

836,478 

936,557 

1,036,636 

1,136,715 

859,385 

980,865 

1,115,844 

1,250,822 

1,385,801 

1,520,780 

ENE 

2007 

2016 

2026 

2036 

2046 

2056 

11,865 

14,123 

16,632 

19,141 

21,650 

24,160 

69,338 

82,491 

97,106 

111,721 

126,336 

140,950 

142,365 

167,494 

195,416 

223,337 

251,259 

279,180 

223,568 

264,108 

309,154 

354,199 

399,245 

444,290 

EAST 

2007 

2016 

2026 

2036 

2046 

2056 

27,428 

32,648 

38,447 

44,246 

50,045 

55,845 

15,290 

18,041 

21,097 

24,154 

27,211 

30,267 

9326 

11,060 

12,987 

14,914 

16,840 

18,767 

52,044 

61,749 

72,531 

83,314 

94,096 

104,879 

ESE 

2007 

2016 

2026 

2036 

2046 

2056 

975 

1129 

1301 

1472 

1644 

1815 

3951 

4398 

4894 

5391 

5888 

6384 

13,732 

15,293 

17,026 

18,760 

20,493 

22,227 

18,658 

20,820 

23,221 

25,623 

28,025 

30,426 

SE 

2007 

2016 

2026 

2036 

2046 

2056 

1154 

1249 

1355 

1461 

1566 

1672 

8043 

8816 

9676 

10,535 

11,394 

12,254 

6691 

7258 

7999 

8740 

9481 

10,222 

15,788 

17,323 

19,030 

20,736 

22,441 

24,148 
Appendix G 

May 2011 G-7 NUREG-1943

Table G-2. (contd)

Direction / Year 

Sector 

16-40 

(km) 

40-60 

(km) 

60-80 

(km) 

16-80 

(km) 

SSE 

2007 

2016 

2026 

2036 

2046 

2056 

1061 

1145 

1238 

1331 

1424 

1517 

2866 

3092 

3342 

3593 

3844 

4094 

7218 

7792 

8430 

9069 

9707 

10,345 

11,145 

12,029 

13,010 

13,993 

14,975 

15,956 

SOUTH 

2007 

2016 

2026 

2036 

2046 

2056 

1673 

1808 

1958 

2108 

2258 

2408 

933 

1000 

1074 

1147 

1220 

1291 

2547 

2776 

3022 

3262 

3493 

3718 

5153 

5584 

6054 

6517 

6971 

7417 

SSW 

2007 

2016 

2026 

2036 

2046 

2056 

688 

748 

814 

880 

946 

1012 

2050 

2132 

2211 

2276 

2329 

2368 

4478 

4639 

4788 

4906 

4991 

5045 

7216 

7519 

7813 

8062 

8266 

8425 

SW 

2007 

2016 

2026 

2036 

2046 

2056 

1172 

1291 

1424 

1557 

1689 

1822 

1360 

1471 

1590 

1706 

1819 

1927 

1492 

1541 

1580 

1601 

1605 

1592 

4024 

4303 

4594 

4864 

5113 

5341 

WSW 

2007 

2016 

2026 

2036 

2046 

2056 

5206 

5738 

6329 

6919 

7510 

8101 

21,732 

23,951 

26,417 

28,883 

31,348 

33,814 

5543 

5796 

6024 

6196 

6313 

6374 

32,481 

35,485 

38,770 

41,998 

45,171 

48,289 
Appendix G 

NUREG-1943 G-8 May 2011 

Table G-2. (contd)

Direction / Year 

Sector 

16-40 

(km) 

40-60 

(km) 

60-80 

(km) 

16-80 

(km) 

WEST 

2007 

2016 

2026 

2036 

2046 

2056 

1566 

1728 

1908 

2087 

2267 

2447 

3388 

3734 

4118 

4503 

4887 

5271 

996 

1035 

1068 

1090 

1100 

1100 

5950 

6497 

7094 

7680 

8245 

8818 

WNW 

2007 

2016 

2026 

2036 

2046 

2056 

1236 

1374 

1527 

1680 

1833 

1986 

853 

936 

1027 

1118 

1210 

1301 

1777 

1890 

2009 

2120 

2224 

2320 

3866 

4200 

4563 

4918 

5267 

5607 

NW 

2007 

2016 

2026 

2036 

2046 

2056 

1805 

2061 

2345 

2629 

2914 

3198 

1949 

2104 

2277 

2449 

2622 

2794 

1703 

1834 

1980 

2126 

2272 

2418 

5457 

5999 

6602 

7204 

7808 

8410 

NNW 

2007 

2016 

2026 

2036 

2046 

2056 

4307 

4979 

5726 

6474 

7221 

7969 

7022 

8013 

9115 

10,216 

11,317 

12,419 

23,143 

25,718 

28,580 

31,441 

34,303 

37,165 

34,472 

38,710 

43,421 

48,131 

52,841 

57,553 
Appendix G 

May 2011 G-9 NUREG-1943

Table G-2. (contd)

Direction / Year 

Sector 

16-40 

(km) 

40-60 

(km) 

60-80 

(km) 

16-80 

(km) 

Totals 

2007 

2016 

2026 

2036 

2046 

2056 

84,938 

98,843 

111,292 

129,739 

145,188 

160,639 

444,828 

511,519 

585,603 

659,669 

733,721 

807,750 

976,544 

1,115,837 

1,270,485 

1,425,003 

1,579,386 

1,733,643 

1,506,310 

1,726,199 

1,970,380 

2,214,411 

2,458,295 

2,702,032 

Cumulative Totals 16-40 

(km) 

16-60 

(km) 

16-80 

(km) 

 

2007 

2016 

2026 

2036 

2046 

2056 

84,938 

98,843 

114,292 

129,739 

145,188 

160,639 

529,766 

610,362 

699,895 

789,408 

878,909 

968,389 

1,506,310 

1,726,199 

1,970,380 

2,214,411 

2,458,295 

2,702,032 

Source: Luminant 2009a, TSCD 2009 

 
Appendix G 

NUREG-1943 G-10 May 2011 

Table G-3. The Current Residential and Transient Population for Each Sector 0–16 km (10 mi)

Direction (2007) 

Sector 

0-2 

(km) 

2-4 

(km) 

4-6 

(km) 

6-8 

(km) 

8-10 

(km) 

10-16 

(km) 

0-16 

(km) 

NORTH 0 16 51 154 337 39,034 39,592 

NNE 1 18 39 113 220 6439 6830 

NE 0 15 112 161 359 2504 3151 

ENE 0 2 36 84 271 2566 2959 

EAST 0 5 131 29 54 161 380 

ESE 0 23 57 111 247 495 933 

SE 0 71 2989 2326 879 373 6638 

SSE 0 140 109 799 3238 598 4884 

SOUTH 8 80 24 377 68 665 1222 

SSW 29 67 726 25 40 193 1080 

SW 28 51 31 44 42 92 288 

WSW 69 31 40 23 44 73 280 

WEST 12 12 49 101 45 119 338 

WNW 1 5 22 68 77 216 389 

NW 1 2 6 4 27 1154 1194 

NNW 0 4 16 63 169 851 1103 

Totals 149 542 4438 4482 6117 55,533 71,261 

Cumulative Totals 0-2 

(km) 

0-4 

(km) 

0-6 

(km) 

0-8 

(km) 

0-10 

(km) 

0-16 

(km) 

2007 149 691 5129 9611 15,728 71,261 

Source: Luminant 2009a 
Appendix G 

May 2011 G-11 NUREG-1943

Table G-4. The Projected Transient Population for Each Sector 0–80 km (50 mi) for Years 2007, 2016, 

2026, 2036, 2046, and 2056

Distance 

(km) Direction 2007 2016 2026 2036 2046 2056 

2 WSW 30 33 36 39 42 46 

6 SE 2900 3191 2514 3837 4160 4483 

6 SSW 706 776 855 934 1012 1091 

8 SE 2191 2411 2655 2899 3143 3387 

8 S 253 278 307 335 363 391 

10 SE 563 620 682 745 808 871 

10 SSE 1722 1895 2087 2279 2471 2663 

16 N 29,639 34,339 39,561 44,784 50,006 55,228 

16 NNE 60 69 80 90 101 111 

16 NE 208 242 278 315 352 388 

16 SE 69 76 84 91 99 107 

16 S 300 330 364 397 431 464 

16 NW 169 196 226 255 285 315 

40 N 136 157 180 204 227 251 

40 NNE 107 124 143 162 181 199 

40 NE 80 95 111 127 144 160 

40 E 11,634 13,848 16,308 18,768 21,228 23,687 

40 SSW 270 294 320 346 372 398 

40 SW 1 1 1 1 2 2 

40 WSW 5580 6150 6783 7416 8050 8683 

40 NW 22 26 29 33 36 40 

40 NNW 6 7 8 9 9 10 

60 N 45,423 52,403 60,158 67,913 75,668 83,423 

60 NNE 92 106 122 137 152 168 

60 NE 2215 2539 2899 3260 3620 3981 

60 ENE 5680 6757 7955 9152 10349 11,546 

60 SE 11,135 12,205 13,395 14,585 15,775 16,964 

60 SSE 715 771 834 896 959 1022 

80 N 114 131 151 171 191 210 

80 NNE 898 1028 1172 1316 1460 1604 

80 NE 210,974 240,374 273,042 305,710 338,377 371,045 

80 SSE 5321 5744 6215 6685 7155 7626 

80 SSW 1750 1813 1871 1917 1950 1971 

80 NNW 11,256 12,508 13,900 15,292 16,684 18,075 

Source: Luminant 2009a, TSCD 2009 
Appendix G 

NUREG-1943 G-12 May 2011 

G.2 Supporting Documentation on Radiological Dose 

Assessment 

The U.S. Nuclear Regulatory Commission (NRC) staff reviewed and performed an independent 

dose assessment of the radiological impacts from normal operation of the new and existing 

nuclear units at the CPNPP site. The results of the assessment are presented in this appendix 

and are compared with the results from Luminant’s assessment found in the Environmental 

Report (ER), Section 4.5, Radiation Exposure to Construction workers, and 5.4, Radiological 

Impacts of Normal Operation (Luminant 2009a, 2010). The appendix is divided into four 

sections: (1) dose estimates to the public from liquid effluents; (2) dose estimates to the public 

from gaseous effluents; (3) cumulative dose estimates; and (4) dose estimates to the biota from 

gaseous and liquid effluents. 

G.2.1 Dose Estimates to the Public from Liquid Effluents 

The NRC staff used the dose assessment approach specified in Regulatory Guide 1.109 (NRC 

1977) and the LADTAP II computer code (Strenge et al. 1986) to estimate doses to the 

maximally exposed individual (MEI) and population within 50 mi from the liquid effluent pathway 

of the proposed Units 3 and 4. The NRC staff used the projected radioactive effluents release 

values from the Final Safety Analysis Report (Luminant 2009b). The GASPAR II computer code 

(Strenge et al. 1987) was used to estimate doses to the MEI and population from liquid effluent 

diverted to an evaporation pond during the course of operations of the proposed Units 3 and 4. 

G.2.1.1 Scope 

The NRC staff and Luminant calculated the dose to the MEI assuming recreational use of the 

Squaw Creek Reservoir (SCR). Pathways included were the ingestion of fish caught in the SCR 

and external exposure to contaminated sediments deposited along the shoreline and to 

waterborne radionuclides while boating on the SCR. Water downstream of the SCR is not used 

as either drinking water or for irrigation. Access to the SCR for recreational activity (boating, 

fishing and shoreline activity) is controlled by Luminant. Population doses were calculated for 

the same pathways as were used for the MEI dose evaluation. 

The NRC staff reviewed the assumed exposure pathways and the input parameters and values 

used by Luminant for appropriateness. Default values from Regulatory Guide 1.109 

(NRC 1977) were used when site-specific input parameters were not available. The NRC staff 

concluded that the assumed exposure pathways were appropriate ingestion of fish and external 

exposure associated with recreational activities on the SCR. The NRC staff also concluded that 

the input parameters and values used by Luminant were appropriate. 

G.2.1.2 Resources Used 

To calculate doses to the public from liquid effluents, the NRC staff used a personal computer 

version of the LADTAP II code and GASPAR II code entitled NRCDOSE Version 2.3.15, 

(Chesapeake Nuclear Services, Inc. 2007) obtained through the Oak Ridge Radiation Safety 

Information Computational Center (RSICC). 

G.2.1.3 Input Parameters 

Table G-5 lists the major parameters used in calculating dose to the public from liquid effluent 

releases during normal operation. Luminant (2009a) projected the 50 mi population to the year 

2058. Section 5.4-1 of the Environmental Standard Review Plan (ESRP) (NRC 2000) suggests 

that the population be projected only five years out from the date of licensing action under 
Appendix G 

May 2011 G-13 NUREG-1943

consideration. However, the projected population for 2058 is larger than the projected 

population for the time suggested by the ESRP. Therefore, use of the 2058 population provides 

a bounding dose estimate. 

Table G-5. Parameters Used in Calculating Dose to the Public from Liquid Effluent Releases 

Annual Release (Ci) Annual Release (Ci) 

Nuclide(a) Liquid Evaporation

Pond Nuclide(a) Liquid Evaporation Pond 

H-3 1.60E+03 8.0E+02 Na-24 4.70E-03 2.35E-03 

Cr-51 1.30E-03 6.50E-04 Mn-54 7.00E-03 3.50E-04 

Fe-55 5.00E-04 2.50E-04 Fe-59 1.00E-04 5.00E-05 

Co-58 1.90E-03 9.50E-04 Zn-65 2.20E-04 1.10E-04 

Rb-88 2.80E-02 1.40E-02 Sr-89 6.00E-05 3.00E-05 

Sr-90 8.00E-06 4.00E-06 Sr-91 6.80E-05 3.40E-05 

Y-91m 4.40E-05 2.20E-05 Y-91 1.00E-05 5.00E-06 

Y-93 2.90E-04 1.45E-04 Zr-95 2.00E-04 1.00E-04 

Nb-95 1.00E-04 5.00E-05 Mo-99 1.64E-03 8.20E-04 

Tc-99m 1.70E-03 8.50E-04 Ru-103 3.11E-03 1.56E-03 

Ru-106 3.81E-02 1.91E-02 Ag-110m 6.00E-04 3.00E-04 

Te-129m 7.80E-05 3.90E-05 Te-129 3.10E-04 1.55E-04 

Te-131m 2.50E-04 1.25E-04 Te-131 7.60E-05 3.80E-05 

Te-132 4.70E-04 2.35E-04 I-131 4.00E-04 2.00E-04 

I-132 3.10E-04 1.55E-04 I-133 8.10E-04 4.05E-04 

I-134 8.90E-05 4.45E-05 I-135 7.80E-04 3.90E-04 

Cs-134 1.00E-03 5.00E-04 Cs-136 2.16E-02 1.08E-02 

Cs-137 2.00E-03 1.00E-03 Ba-140 4.89E-03 2.45E-03 

La-140 8.00E-03 4.00E-03 Ce-141 6.00E-05 3.00E-05 

Ce-143 5.00E-04 2.50E-04 Ce-144 1.70E-03 8.50E-04 

Pr-143 7.90E-05 3.95E-05 Pr-144 1.70E-03 8.50E-04 

W-187 3.50E-04 1.25E-04 Np-239 5.30E-04 2.65E-04 

 
Appendix G 

NUREG-1943 G-14 May 2011 

Table G-5. (contd) 

Parameter Staff Value Comments

Discharge flow rate 248500 gal/min 

553.7 ft3

/s 

Value from ER Table 5.4-1 (Luminant 

2009a).

Site type Fresh water Discharge to freshwater SCR. 

Re-concentration model Completely mixed 

impoundment model 

Value from ER Table 5.4-1 (Luminant 

2009a). 

Average effluent discharge rate 

from SCR 

45.4 ft3/sec Value from ER Table 5.4-1 (Luminant 

2009a).

Volume of SCR 6.3 x 109 ft3 Value from ER Table 5.4-1 (Luminant 

2009a).

Shore width factor (Squaw 

Creek) 

0.2 ER Table 5.4.-1 as suggested for river 

shoreline (NRC 1977). 

Dilution factors for aquatic food 

and boating, shoreline and 

swimming, and drinking water 

(Squaw Creek) 

1 ER Table 5.4-1; value of 1 indicates no 

dilution. 

Transit time to location of 

maximum individual dose (hr) 

7.3 hr ER Table 5.4-1. 

Consumption and usage factors 

for adults, teens, children, and 

infants 

Shoreline usage (hr/yr) 

 12 (adult) 

 67 (teen) 

 14 (child) 

 NA (infant) 

Boating exposure (hr/yr) 

 12 (adult) 

 67 (teen) 

 14 (child) 

 NA (infant) 

Fish consumption (kg/yr) 

 21 (adult) 

 16 (teen) 

 6.9 (child) 

 NA (infant)

ER Table 5.4-2; values from Reg. 

Guide 1.1.09, Table E-5. 

Swimming exposure assumed to be 

the same as shoreline usage. 

50-mile population 3,493,553 ER Table 5/4-1 (Luminant 2009a). 

Annual fish harvest, Whitney 

Reservoir and Brazos River 

(kg/yr) 

324,375 kg/yr ER Table 5.4-1 (Luminant 2009a). 

50-mi population usage of 

shoreline 

22,358,746 person-hr/yr ER Table 5.4.1; based on Reg. Guide 

1.109 exposure times, age group 

fractions and 50% of 50-mi population. 

50-mi population swimming 

usage 

22,358,746 person-hr/yr ER Table 5.4.1; based on Reg. Guide 

1.109 exposure times, age group 

fractions and 50% of 50-mi population.

50-mi population boating usage 22,358,746 person-hr/yr ER Table 5.4.1; based on Reg. Guide 

1.109 exposure times, age group 

fractions and 50% of 50-mi population.

(a) Only radionuclides included in Regulatory Guide 1.109 (NRC 1977) are considered.
Appendix G 

May 2011 G-15 NUREG-1943

G.2.1.4 Comparison of Results 

NRC staff’s dose calculations confirmed the doses estimated by Luminant. 

G.2.2 Dose Estimates to the Public from Gaseous Effluents 

The NRC staff used the dose assessment approach specified in Regulatory Guide 1.109 (NRC 

1977) and the GASPAR II computer code (Strenge et al. 1987) to estimate doses to the MEI 

and to the population within 50 mi of the Comanche Peak site from the gaseous effluent 

pathway for both the proposed units. The NRC staff used the projected radioactive gaseous 

effluents release values from the Final Safety Analysis Report (FSAR) (Luminant 2009b). 

G.2.2.1 Scope 

The NRC staff and Luminant calculated the MEI dose at 0.79 mi south-southwest (SSW) of the 

new units. Pathways included were plume, ground, inhalation, and ingestion of locally grown 

meat and vegetables. Although no milk animals were reported within 5 mi of the site, ingestion 

of milk from a cow was also considered at this location (0.79 mi SSW) for completeness. Milk 

animals could be introduced to the 5-mi area around the site in the future. 

The NRC staff reviewed the parameters and values used by Luminant (2009a) for 

appropriateness. Default values from Regulatory Guide 1.109 (NRC 1977) were used when 

site-specific input parameters were not available. The NRC staff concluded that the assumed 

exposure pathways and input parameters were appropriate. These pathways and parameters 

were used by the NRC staff in its independent calculations using GASPAR II. 

Joint frequency distribution data of wind speed and wind direction by atmospheric stability class 

for the Comanche Peak site provided in ER Table 2.7-105 (Luminant 2009a) were used as input 

to the XOQDOQ code (Sagendorf et al. 1982) to calculate average χ/Q and D/Q values for 

routine releases. The NRC staff reviewed the XOQDOQ output files provided by Luminant and 

concluded they are appropriate for use in dose calculations for the gaseous effluents. 

Population doses were calculated for all types of releases (i.e., noble gases, particulates, 

iodines, H-3 and C-14) using the GASPAR II code for the following: plume immersion; direct 

radiation from radionuclides deposited on the ground, inhalation; and ingestion of vegetables, 

milk, and meat. As noted in Section 5.9.2.2, milk consumption was included based on an earlier 

land-use census (Luminant 2009a). 

G.2.2.2 Resources Used 

To calculate doses to the public from gaseous effluents, the NRC staff used a personal 

computer version of the XOQDOQ and GASPAR II codes entitled, NRCDOSE Version 2.3.15, 

(Chesapeake Nuclear Services, Inc. 2007) obtained through the Oak Ridge RSICC. 

G.2.2.3 Input Parameters 

Tables G-6 provides a listing of the major parameters used in calculating dose to the public from 

gaseous effluent releases during normal operation. 

 
Appendix G 

NUREG-1943 G-16 May 2011 

Table G-6. Parameters Used in Calculating Dose to the Public from Gaseous Effluent 

Releases

Nuclide Annual Release (Ci) Nuclide Annual Release (Ci) 

H-3 1.80E+02 C-14 7.30E+00 

Ar-41 3.40E+01 Cr-51 6.10E-04 

Mn-54 4.30E-04 Co-57 8.20E-06 

Co-58 2.30E-02 Co-60 8.80E-03 

Fe-59 7.90E-05 Kr-85 1.40E+03 

Sr-89 3.00E-03 Sr-90 1.20E-03 

Zr-95 1.00E-03 Nb-95 2.50E-03 

Ru-103 8.00E-05 Ru-106 7.80E-05 

Sb-125 6.10E-05 I-131 4.20E-03 

I-133 6.40E-02 Xe-131m 2.60E+02 

Xe-133m 2.00E+00 Xe-135m 4.00E+00 

Xe-135 2.00E+00 Xe-137 4.00E+00 

Xe-138 1.00E+00 Cs-134 2.30E-03 

Cs-136 8.50E-05 Cs-137 3.60E-03 

Ba-140 4.20E-04 Ce-141 4.20E-05 

Parameter Staff Value Comments 

Wind speed and direction ER Tables 2.7-58 and 2.7-

71 

(Luminant 2009a) 

Site-specific data for 5-

yr period 2001-2006 

Atmospheric dispersion 

coefficients 

ER Tables 2.7-122 to 2.7-

126 

(Luminant 2009a) 

Site-specific data 

Ground deposition coefficient ER Table 2.7-127 (Luminant 

2009a) 

Site-specific data 

Annual milk production within 50-

mi radius of site 

9.08 x 108

 L/yr Site-specific data from 

ER Table 5.4-3 

(Luminant 2009a) 

Annual vegetable production 

within 50-mi radius of site 

4.81 x 108

 kg/yr Site-specific data from 

ER Table 5.4-3 

(Luminant 2009a) 

Annual meat production within 

50-mi radius of site 

4.26 x 107

 kg/yr Site-specific data from 

ER Table 5.4-3 

(Luminant 2009a) 

Receptor locations and 

Dispersion coefficients 

Site specific values ER 

Table 5.55 (Luminant 

2009a) 
May 2011 G-17 NUREG-1943 

Table G-6. (contd) 

Atmospheric Dispersion Coefficient χ/Q (s m-3) D/Q (m-2) Receptor Plain Decayed Decayed & depleted 

Exclusion Area Boundary 0.37 mi 

NNW 5.5 x 10-6 5.5 x 10-6 5.1 x 10-6 5.5 x 10-8

Nearest residence 0.79 mi SSW 

Plant vents 4.4 x 10-7 4.4 x 10-7 3.9 x 10-7 4.5 x 10-6

Nearest residence 0.79 mi SSW 

Evaporation Pond 3.1 x 10-6 3.1 x 10-6 2.9 x 10-6 2.1 x 10-8

Swim Beach 0.79 mi SSW 8.3 x 10-7 8.2 x 10-7 7.3 x 10-7 4.5 x 10-7

Consumption factors: 

Consumption factors; ER Table 5.4-3 (Luminant 2009a) 

Adult Teen Child Infant 

Milk (L/yr) 310 400 330 330 

Meat (kg/yr) 110 65 41 - 

Vegetables(kg/yr) 

 Leafy 

 Other 

64 

520 

42 

639 

26 

520 

- 

- 

Fraction of year leafy 

vegetables are grown 

1.0 Site-specific value ER Table 

5.403 (Luminant 2009a) 

Fraction of year milk cows are 

on pasture 

1.0 Site-specific value ER Table 

5.403 (Luminant 2009a) 

Fraction of MEI’s vegetable 

intake from own garden 

0.76 Site-specific value ER Table 

5.403 (Luminant 2009a) 

Fraction of year beef cattle on 

pasture 1.0 

Site-specific value ER Table 

5.403 (Luminant 2009a) 

Source: ER Table 5.4-7 (Luminant 2009a) 

Values from ER Table 5.4-7 (Luminant 2009a) 

G.2.2.4 Comparison of Doses to the MEI from Gaseous Effluent Releases 

The NRC staff’s dose calculations confirmed the doses estimated by Luminant (2009a, 2010). 

In a revision of the ER, Luminant indicated that recreational activities will be allowed on SCR 

under its control. The NRC staff evaluated the dose to individuals using the “swim beach” 

location for such activities. The resulting doses are shown in Table G-7 and were found to be 

smaller than the MEI for gaseous effluent releases. 

Table G-7. Annual Dose (mrem/yr) at Swim Beach(a) Due to Gaseous Effluent Releases 

Receptor Total Body Thyroid Skin 

Adult 0.000014 0.000020 0.000014 

Teen 0.000078 0.00012 0.000077 

Child 0.000016 0.000028 0.000016 

Infant(b) 0.000010 0.000020 0.000010 

(a) Recreational activities involve exposure pathways of inhalation and external exposure to plume and ground. 

(b) Infant’s external exposure during recreational activities based on mother’s exposure time. 
Appendix G

NUREG-1943 G-18 May 2011 

Table G-8, developed by NRC staff compares the combined dose estimates from direct 

radiation and gaseous and liquid effluents from existing Units 1 and 2 and the proposed Units 3 

and 4 against the 40 CFR Part 190 standards. The NRC staff used the reported MEI dose 

values for the year 2008 operation of Units 1 and 2 (Luminant 2009c) in Table G-8 . 

Table G-8. Comparison of MEI Annual Doses (mrem/yr) with 40 CFR Part 190 Standards 

 CPNPP Units 1 and 2(a)

 CPNPP Units 3 and 4(b) 

Liquid Gaseous Direct(c) Total Liquid Gaseous Total 

Site 

Total 

Regulatory

Standard 

Total 

Body 0.087 0.088 8.8 9.0 1.8 1.7 3.5 12 25 

Thyroid 0.13 0.41 8.8 9.3 0.3 3.1 1.8 11 75 

Other <0.001 0.0028 8.8 8.8 2.6 5.1 7.7 17 25 

(a) Liquid and gaseous dose values for Unit 1 and 2 operation in 2009 (Luminant 2009c). 

(b) Derived from ER Table 5.4-12 (Luminant 2009a). 

(c) Direct radiation values from ER Section 5.4.1.3 (Luminant 2009a). 

G.2.3 Cumulative and Population Dose Estimates 

Based on parameters shown for the liquid and gaseous pathways, Table G-5 and Table G-6, 

respectively, doses from the two proposed units were calculated for the MEI using LADTAP II 

and GASPAR II. The NRC staff’s assessment of the MEI dose for Units 1 and 2 is based on the 

doses reported for the MEI due to operations of Units 1 and 2 in 2008 (Luminant 2009c). The 

effluent releases during 2008 exceeded those in the preceding five years.

Based on parameters shown for the liquid and gaseous pathways, Table G-5 and Table G-6, 

respectively, doses were calculated using LADTAP II and GASPAR II to the population within 50 

mi of the CPNPP site (as discussed in Section G.2.1.3 and G.2.2.3). Doses due to milk 

ingestion were determined based on the 2002 agricultural census except in counties where that 

census indicated no milk animals (cows or goats) were present; in these cases, data from the 

1997 census were substituted. The dose estimated to the population within 50 mi of the 

CPNPP site from operations of proposed Units 3 and 4 is 8.0 person-rem. It is noted that the 

50-mi population was assumed to be for the year 2058; as discussed in Section G.2.1.3, this 

results in a bounding calculation of the dose compared to the ESRP methodology. For 

comparison, the annual background dose to the population within 50 mi from background 

radiation was estimated to be approximately 985,000 person-rem. This estimate is the product 

of the annual average dose to individuals from natural sources of 311 mrem, as stated in NCRP 

Report 160 (NCRP 2009), and the 2058 population of 3,490,000 persons. 

G.2.4 Dose Estimates to the Biota from Liquid and Gaseous Effluents 

The NRC staff performed confirmatory calculations of the doses to biota from liquid and 

gaseous effluents using the LADTAP II and GASPAR II. The NRC staff used a personal 

computer version of the LADTAP II code and GASPAR II code entitled, NRCDOSE 

Version 2.3.15, (Chesapeake Nuclear Services, Inc. 2007) obtained through the RSICC. 

G.2.4.1 Liquid Effluent Pathways 

The NRC estimated doses to biota from liquid effluents using fish, invertebrates, and algae as 

surrogate aquatic biota species. Muskrats, raccoons, herons, and ducks are used as surrogate 
Appendix G 

May 2011 G-19 NUREG-1943 

terrestrial biota species. The NRC staff recognizes the LADTAP II computer program as an 

appropriate method for calculating dose to the aquatic biota and for calculating the liquid 

pathway contribution to terrestrial biota. Most of the LADTAP II input parameters are specified 

in Section G.2.1.3; including the source term, the discharge flow rate to the receiving fresh 

water system, and the shore width factor. The NRC staff concluded these parameters were 

appropriate to use in calculating biota dose in the SCR. The NRC staff’s dose analysis 

confirmed the liquid pathway doses to biota estimated by Luminant as shown in Table 5-13. 

G.2.4.2 Gaseous Effluent Pathways 

The NRC staff assessed doses to terrestrial biota from the gaseous effluent pathway based on 

the results of the GASPAR II calculations for human doses discussed in Section G.2.2. Again, 

muskrats, raccoons, herons, and ducks are used as surrogate terrestrial biota species. The 

NRC staff assessed the doses at the exclusion area boundary (0.37 mi NNW) to achieve a 

reasonable estimate of the doses to terrestrial biota that might live on the CPNPP site. It was 

assumed that doses for raccoons and ducks were equivalent to adult human doses for 

inhalation, vegetation ingestion, and the plume. The dose from ground exposure was doubled. 

The doubling of doses from ground deposition reflects the closer proximity of these organisms 

to the ground. Muskrats and herons do not consume terrestrial vegetation, so that pathway was 

not included for these organisms. The NRC staff’s dose assessment confirmed the gaseous 

pathway doses to biota estimated by Luminant as shown in Table 5-13. 

G.3 References 

40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 

“Environmental Radiation Protection Standards for Nuclear Power Operations.” 

Chesapeake Nuclear Services, Inc. 2007. NRCDOSE for Windows. Radiation Safety 

Information Computational Center, Oak Ridge, Tennessee. 

Luminant Generation Company (Luminant). 2009a. Comanche Peak Nuclear Power Plant 

Units 3 and 4, COL Application; Part 3, Environmental Report (Rev. 1). Luminant Power 

Generation Company LLC, Glen Rose, Texas, November 20. Accession No. ML100081557. 

Luminant Generation Company (Luminant). 2009b. Comanche Peak Nuclear Power Plant, 

Units 3 and 4, COL Application; Part 2, Final Safety Analysis Report (Rev. 1). Luminant Power 

Generation Company LLC, Glen Rose, Texas, November 2009. Accession No. ML100082110. 

Luminant Generation Company (Luminant). 2009c. Comanche Peak Nuclear Power Plant 

2008 Radioactive Effluent Release Report, Luminant Generation Company LLC, Glen Rose, 

Texas, April 9. Accession No. ML091380039. 

Luminant Generation Company (Luminant). 2010. Comanche Peak Nuclear Power Plant 

Units 3 and 4, Docket Nos. 52-034 and 52-035, COL Application Part 3, Environmental Report, 

Update Tracking Report Revision 3, Luminant Power Generation Company LLC, Glen Rose, 

Texas, March 3. Accession No. ML100640170. 

National Council on Radiation Protection and Measurements (NCRP). 2009. Ionizing Radiation 

Exposure of the Population of the United States. NCRP Report No. 160, Bethesda, Maryland. 

Sagendorf J.F., J.T. Goll, and W.F. Sandusky. 1982. XOQDOQ: Computer Program for the 

Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations. 

NUREG/CR-2919, Pacific Northwest National Laboratory, Richland, Washington. 

Strenge, D.L., R.A. Peloquin, and G. Whelan. 1986. LADTAP II—Technical Reference and 

User Guide. NUREG/CR-4013, Pacific Northwest Laboratory, Richland, Washington. 
Appendix G

NUREG-1943 G-20 May 2011 

Strenge D.L., T.J. Bander, and J.K. Soldat. 1987. GASPAR II—Technical Reference and User 

Guide. NUREG/CR-4653, Pacific Northwest Laboratory, Richland, Washington. 

Texas State Data Center. (TSDC). 2009. 2008 Population Projections—Texas Counties. 

Population Estimates and Projections Program, Texas State Data Center, Office of the State 

Demographer, Institute for Demographic and Socioeconomic Research, The University of Texas 

at San Antonio. February. Accessed May 29, 2009, at 

http://txsdc.utsa.edu/tpepp/2008projections/2008_txpopprj_cntytotnum.php. 

U.S. Nuclear Regulatory Commission (NRC). 1977. Calculation of Annual Doses to Man from 

Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 

10 CFR Part 50, Appendix I. Regulatory Guide 1.109, Office of Nuclear Reactor Regulation, 

Washington, D.C. 

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. Accessed August 8, 2007, at http://www.nrc.gov/reading-rm/doccollections/nuregs/staff/sr1555/. 
Appendix H 

List of Authorizations, Permits, and Certifications 

May 2011 H-1 NUREG-1943 

Appendix H 

List of Authorizations, Permits, and Certifications 

Table H-1 contains a list of the environmental-related authorizations, permits, and certifications 

potentially required by Federal, State, regional, local, and affected Native American tribal 

agencies related to the combined licenses for the Comanche Peak Nuclear Power Plant, Units 3 

and 4. The table has been modified from Table 1.2-1 of the Environmental Report submitted to 

the U.S. Nuclear Regulatory Commission by the applicant, Luminant Generation Company LLC 

(Luminant 2009a). 

Reference 

Luminant Generation Company LLC (Luminant). 2009a. Comanche Peak Nuclear Power Plant 

Units 3 and 4, COL Application; Part 3, Environmental Report (Rev. 1). Luminant Generation 

Company LLC, Glen Rose, Texas, November 20. Accession No. ML100081557.
Appendix H 

NUREG-1943 H-2 May 2011 Table H-1. Authorizations, Permits, and Certifications Required for Combined Licenses Agency Authority Requirements Activity Covered/Comments U.S. Nuclear Regulatory Commission (NRC) 10 Code of Federal Regulations (CFR) Part 30 By-product License Approval to receive, possess, and use byproduct material. NRC 10 CFR 40 Source Materials License Approval to receive, possess, and use source material. NRC 10 CFR Part 52 Applicant submits Construction and Operating License Application (COLA) to NRC Applicant is required to submit an application to the NRC for a combined construction and operating license (COL). NRC 10 CFR 52.79 Applicant submits an Environmental Report (ER) Applicant is required to submit a complete ER, 10 CFR 52.80 (b), 72 FR 57447, Oct 9, 2007, 10 CFR 52.79, 10 CFR 51.45, 10 CFR 51.50. NRC 10 CFR Part 70 Special Nuclear Materials License Approval tp receive, possess, and use special nuclear material. U.S. Department of Energy (DOE) Nuclear Waste Policy Act of 1982; Section 302(b)(B) Applicant must have an agreement with the Department of Energy for the disposal of high-level waste and spent nuclear fuel Contracts with DOE exist for disposal of spent nuclear fuel and/or high-level radioactive waste. (Contract No. DE-CR01-09RW09022 for Comanche Peak Nuclear Power Plant (CPNPP) Unit 1; Contract No. DE-CR01-09RW09023 for CPNPP Unit 2). U.S. Fish and Wildlife Service (USFWS) & Texas Parks and Wildlife Department (TPWD) Consultation with Fish and Wildlife, Federal and State (FWS 2006) Consultation concerning potential impacts to federally threatened and endangered species must be obtained and interference with any listed species must be resolved prior to disturbance. 
Appendix H

May 2011 H-3 NUREG-1943 Table H-1. (contd) Agency Authority Requirements Activity Covered/Comments Federal Aviation Administration (FAA) & Texas Department of Transportation (TDOT) 14 CFR 77.13 Notice of construction for permanent structures Permit for structures over 200 ft in height (containment buildings, permanent facilities, cooling towers, etc.). Thirty days prior to construction of the obstruction. FAA & TDOT 14 CFR 77.13 Notice of construction for temporary structures Permit for structures over 200 ft in height (construction cranes, towers, etc.). Thirty days prior to construction of the obstruction. Texas Commission on Environmental Quality (TCEQ) & U.S. Environmental Protection Agency (EPA) 30 Texas Annotated Code (TAC) 335; EPA applies only to Units 1 and 2 Notice of Registration for solid waste management Transport, treatment, storage, and disposal of solid waste. Notice requires modification 3 months prior to any new solid waste not previously described. (Solid Waste Reg. # 33306; EPA ID # TXD02332078) U.S. Army Corps of Engineers (USACE) & TCEQ Clean Water Act 404 Permit Construction in a wetland or shoreline Submit 24 months prior to dredging/filling activities in wetland if required. Depends on the 401 permit process. EPA & TCEQ Clean Water Act Section 401 Construction in a wetland or shoreline Submit 24 months prior to dredging/filling activities in wetland if required. TCEQ Storm Water Pollution Prevention Plan (SWPPP); Texas Water Code Chapter 26 SWPPP for construction activities Stormwater to surface water discharge associated with land disturbance and industrial activity during construction activities. Submit plan modification with Notice of Intent for a disturbance of 5 acres or more. (General Permit No. TXR 150000) 
Appendix H 

NUREG-1943 H-4 May 2011 Table H-1. (contd) Agency Authority Requirements Activity Covered/Comments TCEQ Notice of Intent (NOI); Texas Water Code Chapter 26 (SWPPP) Pertains to General Permit relating to stormwater discharges from construction activities Submit NOI 3 months prior to disturbance of land. (General Permit No. TXR 150000) TCEQ SWPPP; Texas Water Code Chapter 26 SWPPP for operations of facility Submit plan modification concurrent with submittal of Stormwater Operations NOI. (Part III of General Permit No. TXR 050000) TCEQ NOI; Texas Water Code Chapter 26 Pertains to General Permit relating to stormwater discharges from operation activities Submit NOI 3 months prior to operations. (General Permit No. TXR 050000) TCEQ Texas Water Code Chapter 5 and 26 Texas Pollutant Discharge Elimination System (TPDES) Industrial Wastewater Permit (Major Source Modification); Clean Water Act Section 402 Modification or additions to wastewater facilities Certification and licensing of municipal and domestic wastewater facilities. Submit 18 months prior to new construction or modification. (TPDES # WQ0001854000; Must be renewed, but may require modification) TCEQ 30 TAC 285 Submit on-site sewage treatment and design permit Six months prior to construction. 
Appendix H

May 2011 H-5 NUREG-1943 Table H-1. (contd) Agency Authority Requirements Activity Covered/Comments Public Utilities Commission (PUC) of Texas Certificate of Convenience and Need Application Certification that present and future public convenience and necessity require or will require the operation of such equipment or facility and that it will be constructed and operated in compatibility with the environment. State Historic Preservation Officer (SHPO); Native American Tribes 13 TAC 26; Archeological sites Permission required prior to clearing of any lands (SHPO 2007) Identification and evaluation of historic properties and any cultural sites of significance to Native American tribes (site, transmission corridors, pipeline corridors). SHPO Section 106 National Historic Preservation Act (NHPA); 36 CFR 800 Permission required prior to clearing of any lands (SHPO 2007) Review and analysis of cultural and historical resources, including completion of NHPA Section 106 consultation. SHPO concurrence supports no new study needed at CPNPP site. Brazos River Authority (BRA) Use of surface water approved by local water authority New surface water rights secured from Lake Granbury for transfer to CPNPP site and return to Lake Granbury. TPWD 31 TAC 69 Scientific Collection Permit Sampling contractors need to have permit in hand for species collection. (Each Vendor maintains a permit for collection) TCEQ 30 TAC 335 Landfill #6 Closure Plan Plan to close landfill is needed 3 months prior to its being disturbed. TCEQ 30 TAC 335 Landfill #6 Closure Certification Report Report upon completion of excavation as to the results versus the plan. TCEQ 30 TAC 116 Concrete batch plant air permit Concrete batch plant air permit required 6 months prior to construction for operation of an on-site concrete plant. 
Appendix H 

NUREG-1943 H-6 May 2011 Table H-1. (contd) Agency Authority Requirements Activity Covered/Comments TCEQ 30 TAC 122 Title V Operating Permit for diesel units Diesel engines air permit for discharge to environment. Emergency diesels, fire pump diesels, auxiliary boilers, gas turbines, etc. Twelve months prior to initial firing of diesels. [TCEQ Air Permit No. 19225 (not Title V permit); Requires modification] TCEQ 7 TAC 111 Air permit for burning debris in pit After burn pit is constructed, the permit is required 3 months prior to any burn activities. EPA 40 CFR 110/112 Spill Prevention Control and Countermeasures Plan (SPCCP) Revise existing plan 6 months prior to construction if changes are indicated. EPA 40 CFR 110/112 SPCCP – Revision A revision to the plan may be required if contractors store more than 1320 gallons of petroleum products. TDOT; Hood and Somervell County agencies Road construction, road crossings, interruption of traffic flow Affected areas involving old or new roads – changes or interruption of traffic. TCEQ 30 TAC 106 Rock crusher operations For rock debris going to be crushed, obtain a permit 6 months prior to operation. NRC Appendix B - Facilities Operating License Environmental Protection Plan, non-radiological Changes required in the Environmental Protection Plan, non-radiological, to be modified pending final design reviews, approvals, and prior to operation of the facility. TCEQ 30 TAC 321.255; 30 TAC 210.23; 30 TAC 309 Evaporation pond liner and size requirements Certify evaporation pond meets requirements prior to use. 
Appendix H

May 2011 H-7 NUREG-1943 Table H-1. (contd) Agency Authority Requirements Activity Covered/Comments TCEQ Hazardous materials storage (Superfund Amendments and Reauthorization Act Title III) TCEQ Toxic chemical release inventory reporting form TCEQ Disposal Facility Radiological waste (Radwaste) disposal registration PUC of Texas PUC approval of decommissioning plan TCEQ 30 TAC 116 State construction air permit 

Appendix I 

Severe Accident Mitigation Alternatives 

 

May 2011 I-1 NUREG-1943 

Appendix I 

Severe Accident Mitigation Alternatives 

I.1 Introduction 

Luminant has submitted an application to construct two U.S. Advanced Pressurized Water 

Reactors (US-APWR) at the Comanche Peak Nuclear Power Plant (CPNPP) site. Current 

policy developed after the Limerick decision (Limerick 1989) requires that the U.S. Nuclear 

Regulatory Commission (NRC) staff consider alternatives to mitigate the consequences of 

severe accidents in a site-specific environmental impact statement (EIS). The severe accident 

mitigation alternative (SAMA) review presented here considers both severe accident mitigation 

design alternatives (SAMDAs) and procedural alternatives. 

In Title 10 of the Code of Federal Regulations (CFR), 10 CFR 52.79(a)(38), the NRC requires 

that applicants for combined licenses (COLs) include “... a description and analysis of design 

features for the prevention and mitigation of severe accidents...” The Environmental Report 

(ER) (Luminant 2009a) and the Final Safety Analysis Report (FSAR) (Luminant 2009b) in the 

Luminant COL application address these requirements. 

In 10 CFR 52.47(a)(23), the NRC requires that applicants for design certification include “... a 

description and analysis of design features for the prevention and mitigation of severe 

accidents...” in the application for design certification. In 10 CFR 52.47(a)(27) the NRC requires 

a description of a “...plant-specific probabilistic risk assessment (PRA) and its results,” and in 

10 CFR 52.47(b)(2) the NRC requires an ER that contains the information required by 

10 CFR 51.55. Mitsubishi Heavy Industries, Ltd. (MHI) has submitted all of this information in 

documents that are part of the application for certification of the US-APWR design. 

While the NRC staff has not completed its generic SAMDA review of the US-APWR for design 

certification, the staff has conducted a review of the Luminant SAMDA analysis specific to 

operation of two US-APWRs at the CPNPP site (Luminant 2009a). The analysis is based on: 

1. the PRA included as Section 19.1 of the Comanche Peak FSAR (Luminant 2009b) and the 

SAMDA analysis in the US-APWR ER (Luminant 2009a), and 

2. results of the analysis of probability-weighted risks of US-APWR design at the CPNPP site 

described in Section 5.11.2 of this EIS. 

An analysis for a US-APWR at a generic site is presented first; then the analysis is extended to 

include consideration of CPNPP site-specific information. The SAMDA analysis for the 

proposed US-APWR design certification will be finally resolved through the design certification 

rulemaking process. 

I.2 US-APWR SAMDA Review – Generic Site 

This section addresses the generic analysis of SAMDAs conducted by MHI, the applicant for 

certification of the US-APWR design. The SAMA review in Section I.3 extends the generic 

SAMDA analysis to include CPNPP site-specific factors including meteorology, population, and 

land use. Section I.3 also addresses SAMAs that were not included in the generic analysis 

because they do not involve reactor system design. 
Appendix I 

NUREG-1943 I-2 May 2011 

I.2.1 US-APWR PRA Results 

MHI, the applicant for certification of the US-APWR design, conducted Level 1 and Level 2 

PRAs to estimate the core damage frequencies (CDFs) that might result from a large number of 

initiating events and accident sequences. Table I-1 lists these CDF estimates and estimates of 

the large release frequencies (LRFs) of iodine, cesium, or tellurium. Releases associated with 

containment bypass, containment isolation failure, or containment failure at or before reactor 

vessel failure are considered to be large. Table I-1 also lists NRC staff goals related to CDFs 

and LRFs. 

Table I-1. Comparison of US-APWR PRA Results with the Design Goals

NRC Design Goal(a)

 US-APWR PRA Results(b)

Core 

Damage 

Frequency 

(yr-1) 

Large 

Release 

Frequency

(yr-1) 

Core 

Damage 

Frequency 

(yr-1) 

Large 

Release 

Frequency 

(yr-1) 

Internal At Power Events 1.0 × 10-4 1.0 × 10-6 1.2 × 10-6 1.0 × 10-7

Internal Flooding Events 1.0 × 10-4 1.0 × 10-6 1.5 × 10-6 4.0 × 10-7

Internal Fire Events 1.0 × 10-4

 1.0 × 10-6 1.7 × 10-6 1.2 × 10-7

Low Power and Shutdown Events 1.0 × 10-4

 1.0 × 10-6 2.5 × 10-7 2..5 × 10-7

(a) SECY-90-016 (NRC 1990a) and associated SRM (NRC 1990b) 

(b) From Chapter 19 of MHI (2009a) 

Although the US-APWR PRAs did not provide quantitative estimates of CDFs and LRFs for 

seismic and other external initiating events such as hurricanes and tornadoes, they are 

discussed in the FSAR. The Section 19.1.5.1 of the FSAR (Luminant 2009b) presents the 

results of a seismic margins analysis in which PRA methods are used to identify potential 

vulnerabilities in the design and so corrective measures can be taken to reduce risk. Similarly, 

FSAR Section 19.1.5 addresses risks associated with high winds and tornadoes, external 

flooding, transportation and nearby facility accidents and aircraft crash. Risks associated with 

these events are considered to be insignificant by MHI. 

I.2.2 Potential Design Improvements 

In the ER submitted as part of the design certification application (MHI 2009b), MHI identified 

156 candidate alternatives based on a review of industry documents, including previous SAMDA 

reviews and NRC evaluations of those reviews, and consideration of plant-specific 

enhancements. The candidate alternatives were then screened to identify candidates for 

detailed evaluation. The categories used in screening were: 

 not applicable 

 already implemented 

 combined 

 excessive implementation cost 

 very low benefit 

The development of the US-APWR design has benefitted from insights gained in numerous 

PRAs. The low CDFs and LRFs in Table I-1 are attributable to the implementation of design 
Appendix I 

May 2011 I-3 NUREG-1943 

improvements already incorporated into the US-APWR design. The following are examples of 

the 22 candidate alternatives included in the design: 

 install a gas turbine generator 

 improve emergency core cooling system suction strainers 

 provide an in-containment reactor water storage tank 

 provide capability for remote, manual operation of secondary side pilot-operated relief 

valves in a station blackout 

 provide a reactor coolant depressurization system 

 provide hardware connections to allow another essential raw cooling water system to cool 

charging pump seals 

 provide ability for emergency connection of existing or new water sources to feedwater and 

condensate systems 

 provide a reactor cavity flooding system 

The screening process eliminated 20 candidate alternatives as being inapplicable for the USAPWR design; 3 candidate alternatives were combined with similar alternatives; and 29 

candidate alternatives were procedural or administrative rather than design alternatives. Of the 

remaining 82 candidate alternatives, 69 were categorized as very low benefit because it would 

not significantly reduce risk, and 3 were categorized as having excessive implementation costs. 

These screening processes identified 10 candidate alternatives for further evaluation. The 10 

candidate SAMDAs are: 

1. Provide additional direct current (dc) battery capacity (At least one train emergency dc 

power can be supplied more than 24 hours.) 

2. Provide an additional diesel generator (At least one train emergency alternating current (ac) 

power can be supplied more than 24 hours.) 

3. Install an additional, buried off-site power source 

4. Provide an additional high pressure injection pump with independent diesel (With dedicated 

pump cooling) 

5. Add a service water pump (Add independent train) 

6. Install an independent reactor coolant pump seal injection system, with dedicated diesel 

(With dedicated pump cooling) 

7. Install an additional component cooling water pump (Add independent train) 

8. Add a motor-driven feedwater pump (With independent room cooling) 

9. Install a filtered containment vent to remove decay heat 

10. Install a redundant containment spray system (Add independent train) 

I.2.3 Cost-Benefit Comparison 

MHI used the cost-benefit methodology found in NUREG/BR-0184, Regulatory Analysis 

Technical Evaluation Handbook (NRC 1997), to calculate the maximum attainable benefit 

associated with completely eliminating all risk for the US-APWR. 

This methodology involves determining the net value for a SAMDA according to the following 

formula: 

Net Value = (APE + AOC + AOE + AOSC) - COE 
Appendix I 

NUREG-1943 I-4 May 2011 

Where 

APE = present value of averted public exposure ($) 

AOC = present value of averted offsite property damage costs ($) 

AOE = present value of averted occupational exposure costs ($) 

AOSC = present value of averted onsite costs ($); this includes cleanup, decontamination, 

and long-term replacement power costs 

COE = cost of enhancement ($) 

If the net value of a SAMDA is negative, the cost of implementing the SAMDA is larger than the 

benefit associated with the SAMDA and it is not considered to be cost beneficial. 

To assess the risk reduction potential for SAMDAs, MHI (MHI 2009b) assumed that each design 

alternative would completely eliminate all severe accident risk. This assumption is conservative 

as it maximizes the benefit of each design alternative. Luminant estimated the public exposure 

benefits for the design alternative on the basis of the reduction of risk expressed in terms of 

whole body person-rem per year received by the total population within a 50-mi radius of the 

generic site hosting a US-APWR. 

Table I-2 summarizes MHI’s estimates of each of the associated cost elements. The provided 

results are based on the approach, parameters, and data listed in NUREG/BR-0184. Baseline 

risks used in the analysis were 3.0 ×10-1 person-rem Ryr-1 for population dose risk and 

$706 Ryr-1 for cost risk for internal events during full-power operation (Luminant 2009a). 

Table I-2. Summary of Estimated Maximum Averted Costs for a Generic Site

Quantitative Attributes 

Averted Cost Estimate 

($) x 1000(a)

7% Discount 3% Discount 

Health Public (APE) 29.1 75.1 

Occupational (AOE) 2.3 5.9 

Property Offsite(b) (AOC) 0.5 1.3 

Onsite NA(c) NA(c)

Cleanup and Decontamination Onsite (AOSC)(d) 69.8 180.2 

Replacement Power (AOSC)(d)

 187.6 484.4k 

Total 289.3 747.1 

(a) From the design certification ER (MHI 2008). 

(b) Includes offsite cleanup and decontamination costs. 

(c) Not Analyzed. 

(d) AOSC includes onsite cleanup and decontamination costs and the cost of replacement power. 

(e) Based on internal event, internal flooding, and internal fire risks. 

The monetary present value estimate for each risk attribute does not represent the expected 

reduction in risk resulting from a single accident; rather, it is the present value of a stream of 

potential losses extending over the projected lifetime of the facility (in this case projected to be 

60 years). Therefore, the averted cost estimates reflect the expected annual loss resulting from 

a single accident, the possibility that such an accident could occur at any time over the licensed 

life, and the effect of discounting these potential future losses to present value. 
Appendix I 

May 2011 I-5 NUREG-1943 

As indicated above, MHI estimated the total present dollar value equivalent associated with 

complete elimination of severe accidents at a single US-APWR unit site to range between about 

$289k and about $747,000. The estimated cost of replacement power has the largest effect on 

the averted cost. For any SAMDA to be cost beneficial, the enhancement cost must be less 

than $747,000. Based on a cost estimate of $289,000, MHI concluded that none of the SAMDA 

candidates are cost beneficial. MHI states that older studies were used for cost examples of 

SAMDA candidates without attempting to adjust to present-day dollars with the exception of cost 

associated with procurement and installation, and where applicable, long-term maintenance, 

surveillance, calibration and training. In one case (Containment Spray System, SAMDA 10), the 

cost was scaled from a lower-power unit to the larger power (1610 Mwe) appropriate for the USAPWR. The cost of other SAMDA candidates was determined without power scaling 

(MHI 2008). 

I.2.4 Staff Evaluation 

In 10 CFR 52.47(a)(27), the NRC requires that an applicant for design certification perform a 

plant- or site-specific PRA. The aim of this PRA is to seek improvements in the reliability of core 

and containment heat removal systems that are significant and practical. The set of potential 

design improvements considered for the US-APWR include those from industry guidance, 

previous SAMDA review, and review of the US-APWR design. The US-APWR design already 

incorporates many design enhancements related to severe accident mitigation. Such design 

improvements have resulted in a CDF that is a factor of 3 of magnitude lower than the CDFs for 

the existing CPNPP Units 1 and 2. 

MHI’s averted cost estimates are based on point-estimate values, without consideration of 

uncertainties in CDF or offsite consequences. Even though this approach is consistent with that 

used in previous design alternative evaluations, further consideration of these factors could lead 

to significantly higher risk reduction values, given the extremely small CDF and risk estimates in 

the baseline PRA. Uncertainties either in CDF or in offsite radiation exposures resulting from a 

core damage event are fairly large because key safety features of the US-APWR design are 

unique, and their reliability has been evaluated through analysis and testing programs rather 

than through operating experience. 

Further, in evaluating the costs of SAMDA candidates, MHI did not explicitly assess the capital 

costs associated with the various alternatives. Instead, MHI used estimated costs of back fitting 

of similar SAMDAs provided by industry in license renewal applications. This approach has the 

potential to overestimate the actual costs of SAMDAs because the cost of implementing a 

modification to a reactor that has been built is always greater than implementing the 

modification in a design that is still evolving. 

I.3 Comanche Peak Site-Specific SAMA Review 

The discussion above evaluates SAMDAs for the US-APWR at a generic site. The discussion 

that follows updates that evaluation to include consideration of CPNPP site-specific factors 

including meteorological conditions, population distribution, and land use. It is based on the 

Luminant SAMDA analysis presented in the ER (Luminant 2009a). The last part of this 

discussion deals with procedural and training SAMAs. 

I.3.1 Risk Estimates 

Luminant estimated severe accident risks for a US-APWR at the CPNPP site in Section 7.2 of 

its ER (Luminant 2009a). The NRC staff evaluated the information for the US-APWR design 

supplied by MHI and Luminant (MHI 2009b; Luminant 2009b) and CPNPP site-specific data 
Appendix I 

NUREG-1943 I-6 May 2011 

(meteorology, demographics, and land use) provided by Luminant. The results of these 

analyses are found in Table 5-22, “Environmental Risks from a US APWR Severe Accident at 

the Comanche Peak Site,” in Chapter 5 of this EIS. 

Table 5-22 gives a CDF of 1.2×10-6 Ryr-1 and population dose and cost risks of 0.3 person-rem 

Ryr-1 and $714 Ryr-1, respectively. These risks are based on internally initiated events. Table 

5-23 [(Total Severe Accident Health Effects (based on 2006 Meteorological Data)] gives a CDF 

of 4.6×10-6 Ryr-1 when internal flooding events, internal fire events that occur while the reactor is 

at power, and low power and shutdown events are considered. 

I.3.2 Cost-Benefit Comparison 

In Section 7.3.2 of the ER (Luminant 2009a), Luminant estimates the averted costs associated 

with eliminating all severe accident risks associated for a US-APWR at the CPNPP site. The 

Luminant analysis is an update the MHI SAMDA analysis (MHI 2009b) to include site specific 

information. Luminant substituted population dose and offsite cost risks based on 2056 

population projections for the CPNPP site for the population dose and offsite property costs in 

the MHI analysis. Table I-3 shows both the MHI generic averted cost estimates and the 

Luminant estimates. 

Table I-3. Summary of Estimated Averted Costs for the Comanche Peak Site

Quantitative Attributes 

Averted Cost Value Estimate ($) x 1000 

MHI Generic(a) Comanche Peak Site(b)

7% Discount 3% Discount 7% Discount 3% Discount 

Health 

Public (APE) 29.1 75.1 16.5 42.7

Occupational 

(AOE) 2.3 5.9 2.3 6.0 

Property

Offsite(c)

(AOC) 0.5 1.3 28.0 72.4 

Onsite NA(d) NA(d) NA(d) NA(d)

Cleanup and 

Decontamination

Onsite 

(AOSC)(e)

69.8 180.2 70.5 182.0 

Replacement 

Power (AOSC)(e) 187.6 484.4 187 483.7 

Total 289.3 $747.1 304.6 786.7 

(a) From MHI (2009b) 

(b) Luminant estimates (Luminant 2009a) 

(c) Includes cleanup and decontamination costs 

(d) Not analyzed 

(e) AOSC includes onsite cleanup and decontamination cost and the cost of replacement power 

In assessing the risk reduction potential of design improvements for the US-APWR, the NRC 

staff evaluated the MHI risk reduction estimates for the various design alternatives and 

assessed the potential impact of uncertainties on the results. The analyses in Table I-2 and 

Table I-3 present the value of reducing the severe accident risk to zero. These values are used 

in screening potential SAMDAs. Using the results in Table I-2, MHI concluded that no candidate 

alternative from an initial list of 156 alternatives would be cost beneficial. The CPNPP sitespecific values, although higher than those estimated for a generic site, are below the minimum 
Appendix I 

May 2011 I-7 NUREG-1943 

estimated cost for a design change. Moreover, no SAMDA can reduce the risk to zero. 

Therefore, the staff concludes that it is highly unlikely that any SAMDA would be cost beneficial 

at the CPNPP site. 

I.3.3 Procedural and Training SAMAs 

The original list of 156 US-APWR SAMDAs included 29 candidate alternatives that were 

procedural or training in nature. These items were eliminated from consideration because they 

did not involve design changes. Examples of items screened out for this reason include 

 revise procedure to allow bypass of diesel generator trips 

 develop procedures for replenishing diesel fuel oil 

 emphasize steps in recovery of offsite power after a station blackout in training 

 provide additional training on loss of component cooling water 

 implement procedures to stagger high pressure safety injection pump use after a loss of 

service water 

 proceduralize local manual operation of auxiliary feedwater system when control power is 

lost. 

These candidate alternatives fall within the scope of the SAMA review that the NRC staff 

conducts as part of its environmental review of applications. However, such SAMAs generally 

involve procedures that have not been developed for a reactor that has not been built and that 

are typically not developed until construction has been completed and the plant is approaching 

operation. 

The staff reviewed the candidate alternatives that were previously screened out because they 

did not involve design changes. Because the maximum attainable benefit is low, an SAMA 

based on procedures or training for a US-APWR at the CPNPP site would have to reduce the 

CDF or risk by approximately 20 percent to become cost beneficial. Based on its evaluation, 

the staff concludes that none of these SAMAs would reduce the CDF or risk by 20 percent for a 

US-APWR at CPNPP. Therefore, they would not be likely to be cost effective if the procedures 

that are referenced actually existed. 

Luminant has stated that evaluation of administrative SAMAs would not be appropriate until the 

plant design is complete and that the appropriate administrative controls on plant operations 

would be incorporated into the plant’s managements systems as part of its baseline 

configuration (Luminant 2009b, Chapter 19). Based on this statement, the staff expects that 

Luminant will consider risk insights and mitigation measures in the development of procedures 

and training; however, this expectation is not crucial to the staff’s conclusions because the staff 

already concluded procedural and training SAMAs would be unlikely to be cost effective. 

I.4 Conclusions 

Based on its evaluation of the US-APWR PRA (MHI 2009a) and SAMDA analysis (MHI 2009b), 

the CPNPP site-specific severe accident and SAMDA analyses (Luminant 2009a and Luminant 

2009b) and its own independent review, the staff concludes that that there are no US-APWR 

SAMDAs that would be cost beneficial at the CPNPP site. The staff expects that Luminant will 

consider risk insights and mitigation measures in the development of procedures and training; 

however, this expectation is not crucial to the staff’s conclusions because the staff concludes 

that procedural and training SAMAs would be unlikely to be cost effective. 
Appendix I 

NUREG-1943 I-8 May 2011 

I.5 References 

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

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.” 

Limerick Ecology Action v. NRC (Limerick). 1989. “Federal Reporter, Second Series, Vol. 869, 

P 719 [3rd Circuit].” 

Luminant Generation Company (Luminant). 2009a. Comanche Peak Nuclear Power Plant 

Units 3 and 4, COL Application; Part 3, Environmental Report (Rev. 1). Luminant Power 

Generation Company LLC, Glen Rose, Texas, November 20. Accession No. ML100081557. 

Luminant Generation Company (Luminant). 2009b. Comanche Peak Nuclear Power Plant, 

Units 3 and 4, COL Application; Part 2, Final Safety Analysis Report (Rev. 1). Luminant Power 

Generation Company LLC, Glen Rose, Texas, November 2009. Accession No. ML100082110. 

Mitsubishi Heavy Industries, Ltd (MHI). 2008. US-APWR Applicant’s Environmental ReportStandard Design Certification. MUAP-DC021 Revision 1, August 2008. 

Mitsubishi Heavy Industries, Ltd (MHI). 2009a. Design Control Document for the US-APWR,

Chapter 19, Probabilistic Risk Assessment and Severe Accident Evaluation. MUAP-DC0019, 

Revision 2, October 2009. 

Mitsubishi Heavy Industries, Ltd (MHI). 2009b. US-APWR Applicant’s Environmental ReportStandard Design Certification. MUAP-DC021 Revision 2, October 2009. 

U.S. Nuclear Regulatory Commission (NRC). 1990a. “Evolutionary Light Water Reactor 

Certification Issues and Their Relationship to Current Regulatory Requirements.” SECY-90-

016, January 1990. 

U.S. Nuclear Regulatory Commission (NRC). 1990b. “SECY-90-16-Evolutionary Light Water 

Reactor Certification Issues and Their Relationships to Current Regulatory Requirements.” 

Staff Requirements Memorandum, June 1990. 

U.S. Nuclear Regulatory Commission (NRC). 1997. Regulatory Analysis Technical Evaluation 

Handbook. NUREG/BR-0184, NRC, Washington, D.C. 
Appendix J 

Carbon Dioxide Footprint Estimates for a 1000 MW(e) 

Light Water Reactor (LWR) 

 

May 2011 J-1 NUREG-1943 

Appendix J 

Carbon Dioxide Footprint Estimates for a 1000 MW(e) 

Light Water Reactor (LWR) 

The review team has estimated the carbon dioxide (CO2) footprint of various activities 

associated with nuclear power plants. These activities include building, operating, and 

decommissioning the plant. The estimates include direct emissions from the nuclear facility and 

indirect emissions from workforce transportation and the uranium fuel cycle. 

Construction equipment estimates listed in Table J-1 are based on hours of equipment use 

estimated for a single nuclear power plant at a site requiring a moderate amount of terrain 

modification. Equipment usage for a multiple unit facility would be larger, but it is likely that it 

would not be a factor of 2 larger. A reasonable set of emissions factors used to convert the 

hours of equipment use to CO2 emissions are based on carbon monoxide emissions (UniStar 

2007) scaled to CO2 using a scaling factor of 165 tons of CO2 per ton of CO. This scaling factor 

is based on emissions factors in Table 3.3-1 of AP-42 (EPA 1995). Equipment emissions 

estimated for decommissioning are one half of those for construction. 

Table J-1. Construction Equipment CO2 Emissions (Metric Tons Equivalent)

Equipment Construction Total(a) Decommissioning Total(b) 

Earthwork and Dewatering 1.1 × 104 5.4 × 103

Batch Plant Operations 3.3 × 103 1.6 × 103

Concrete 4.0 × 103

 2.0 × 103

Lifting and Rigging 5.4 × 103

 2.7 × 103

Shop Fabrication 9.2 × 102

 4.6 × 102

Warehouse Operations 1.4 × 103

 6.8 × 102

Equipment Maintenance 9.6 × 103

 4.8 × 103

TOTAL(c)

 3.5 × 104 1.8 × 104

(a) Based on hours of equipment usage over 7-yr period. 

(b) Based on equipment usage over 10-yr period. 

(c) Total not equal to the sum due to rounding. 

Workforce estimates are typical workforce numbers for new plant construction and operation 

based on estimates in various combined license (COL) applications, and decommissioning 

workforce emissions estimates are based on decommissioning workforce estimates in NUREG0586 S1, Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, 

Supplement 1 Regarding the Decommissioning of Nuclear Power Reactors (NRC 2002). A 

typical construction workforce averages about 2500 for a 7-year period with a peak work force 

of about 4000. A typical operations workforce for the 40-year life of the plant is assumed to be 

about 400, and the decommissioning workforce during a decontamination and dismantling 
Appendix J 

NUREG-1943 J-2 May 2011 

period of 10 years is assumed to be 200 to 400. In all cases, the daily commute is assumed to 

involve a 100-mi roundtrip with 2 individuals per vehicle. Considering shifts, holidays, and 

vacations,1250 roundtrips per day are assumed each day of the year during construction; 200 

roundtrips per day are assumed each day during operations; and 150 roundtrips per day are 

assumed 250 days per year for the decontamination and dismantling portion of 

decommissioning. If the SAFSTOR decommissioning option is included in decommissioning, 

20 roundtrips each day of the year are assumed for the caretaker workforce. 

Table J-2 lists the review team’s estimates of the CO2 equivalent emissions associated with 

workforce transport. The table lists the assumptions used to estimate total miles traveled by 

each workforce and the factors used to convert total miles to metric tons CO2 equivalent. CO2

equivalent accounts for other greenhouse gases, such as methane and nitrous oxide, that are 

emitted by internal combustion engines. The workers are assumed to travel in gasoline 

powered passenger vehicles (cars, trucks, vans, and sport utility vehicles) that get an average 

of 19.7 mi per gallon of gas (FHWA 2006). Conversion from gallons of gasoline burned to CO2

equivalent is based on Environmental Protection Agency emissions factors (EPA 2007a, 

2007b). 

Table J-2. Workforce CO2 Footprint Estimates

Construction 

Workforce 

Operational 

Workforce 

Decommissioning 

Workforce 

SAFSTOR 

Workforce 

Roundtrips per day 1250 200 150 20 

Miles per roundtrip 100 100 100 100 

Days per year 365 365 250 365 

Years 7 40 10 40 

Miles traveled 3.2 × 108

 2.9 × 108 3.8 × 107 2.92 × 107

Miles per gallon(a) 19.7 19.7 19.7 19.7 

Gallons fuel burned 1.6 × 107

 1.5 × 107 1.9 × 106 1.58 × 106

Metric tons CO2 per gallon(b) 8.81 × 10-3

 8.81 × 10-3 8.81 × 10-3 8.81 × 10-3

Metric tons CO2 1.4 × 105

 1.3 × 105 1.7 × 104 1.3 × 104

CO2 equivalent factor(c)

 0.971 0.971 0.971 0.971 

Metric tons CO2 equivalent 1.5 × 105

 1.3 × 105 1.7 × 104 1.3 × 104

(a) Source: FHWA 2006 

(b) Source: EPA 2007a 

(c) Source: EPA 2007b

Published estimates of uranium fuel cycle CO2 emissions required to support a nuclear power 

plant range from about 1 percent to about 5 percent of the CO2 emissions from a comparably 

sized coal-fired plant (Sovacool 2008). A coal-fired power plant emits about 1 metric ton of CO2
Appendix J 

May 2011 J-3 NUREG-1943 

for each megawatt hour generated (Miller and Van Atten 2004). Therefore, for consistency with 

Table S-3 of Title 10 of the Code of Federal Regulations 51.51 (10 CFR Part 51), the review 

team estimated the uranium fuel cycle CO2 emissions as 0.05 metric tons of CO2 per MWh 

generated. Finally, the review team estimated the CO2 emissions directly related to plant 

operations from the typical usage of various diesel generators onsite using EPA emissions 

factors (EPA 1995). The review team assumed an average of 600 hrs of emergency diesel 

generator operation per year (total for 4 generators) and 200 hrs of station blackout diesel 

generator operation per year (total for 2 generators). 

Given the various sources of CO2 emissions discussed above, the review team estimates the 

total life CO2 footprint for a reference 1000 MW(e) nuclear power plant with an 80 percent 

capacity factor to be about 18 million metric tons. The components of the footprint are 

summarized in Table J-3. The uranium fuel cycle component of the footprint dominates all other 

components. It is directly related to power generated. As a result, it is reasonable to use 

reactor power to scale the footprint to larger reactors. 

In closing, the review team considers the footprint estimated in Table J-3 to be appropriately 

conservative. The CO2 emissions estimates for the dominant component (uranium fuel cycle) 

are based on 30 year old enrichment technology assuming that the energy required for 

enrichment is provided by coal-fired generation. Different assumptions related to the source of 

energy used for enrichment or the enrichment technology that would be just as reasonable 

could lead to a significantly reduced footprint. 

Table J-3. 1000 MW(e) LWR Lifetime Carbon Dioxide Footprint

Source Activity 

Duration (yr) 

Total Emissions 

(Metric Tons) 

Construction Equipment 7 3.5 × 104

Construction Workforce 7 1.5 × 105

Plant Operations 40 1.9 × 105

Operations Workforce 40 1.3 × 105

Uranium Fuel Cycle 40 1.7 × 107

Decommissioning Equipment 10 1.8 × 104

Decommissioning Workforce 10 1.7 × 104

SAFSTOR Workforce 40 1.3 × 104

TOTAL 1.8 × 107

Emissions estimates presented in the body of this EIS have been scaled to values that are 

appropriate for the proposed project. The uranium fuel cycle emissions have been scaled by 

reactor power using the scaling factor determined in Chapter 6 and by the number of reactors to 

be built. Plant operations emissions have been adjusted to represent the number of large CO2

emissions sources (diesel generators, boilers, etc.) associated with the project. The workforce 

emissions estimates have been scaled to account for differences in workforce numbers and 

commuting distance. Finally, equipment emissions estimates have been scaled by estimated 
Appendix J 

NUREG-1943 J-4 May 2011 

equipment usage. As can be seen in Table J-3, only the scaling of the uranium fuel cycle 

emissions estimates makes a significant difference in the total carbon footprint of the project. 

J.1 References 

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

Federal Highway Administration (FHWA). 2006. Highway Statistics 2005 (Table VM-1). Office 

of Highway Policy Information. Washington, D.C. 

Miller, P.J., and C. Van Atten. 2004. North American Power Plant Air Emissions. Commission 

for Environmental Cooperation of North America, Montreal. 

Sovacool, B.K. 2008. “Valuing the Greenhouse Gas Emissions from Nuclear Power: A Critical 

Survey.” Energy Policy 36:2940–2953. Elsevier Ltd. 

UniStar Nuclear Energy, LLC (UniStar). 2007. Technical Report in Support of Application of 

UniStar Nuclear Operating Services, LLC for Certificate of Public Convenience and Necessity 

Before the Maryland Public Service Commission for Authorization to Construct Unit 3 at Calvert 

Cliffs Nuclear Power Plant and Associated Transmission Lines. Prepared for the Public Service 

Commission of Maryland, dated November 6, 2007. Accession No. ML090680065. 

U.S. Environmental Protection Agency (EPA). 1995. Compilation of Air Pollutant Emission 

Factors Volume 1: Stationary and Point and Area Sources. AP-42, 5th Edition. Office of Air 

and Radiation, U.S. Environmental Protection Agency, Research Triangle Park, North Carolina. 

U.S. Environmental Protection Agency (EPA). 2007a. “Conversion Factors to Energy Units 

(Heat Equivalents) Heat Contents and Carbon Content Coefficients of Various Fuel Types.” 

Inventory of U.S. Greenhouse Gas Emissions and Sinks: Fast Facts 1990–2005. EPA-430-R07-002. U.S. Environmental Protection Agency. Washington, D.C. 

U.S. Environmental Protection Agency (EPA). 2007b. Inventory of U.S. Greenhouse Gas 

Emissions and Sinks: 1990–2005 (Table 3-7). U.S. Environmental Protection Agency. 

Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 2002. Generic Environmental Impact Statement 

on Decommissioning of Nuclear Facilities, Supplement 1 Regarding the Decommissioning of 

Nuclear Power Reactors. NUREG-0586 S1, Vol. 1, Washington, D.C. 
BIBLIOGRAPHIC DATA SHEET

(See instructions on the reverse)

NRC FORM 335

(12-2010)

NRCMD 3.7

U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

 (Assigned by NRC, Add Vol., Supp., Rev.,

 and Addendum Numbers, if any.)

NUREG-1943, Vol. 2

3. DATE REPORT PUBLISHED

MONTH YEAR

4. FIN OR GRANT NUMBER

2. TITLE AND SUBTITLE

Environmental Impact Statement for Combined Licenses (COLs) for Comanche Peak Nuclear

Power Plant, Units 3 and 4: Final Report

5. AUTHOR(S)

See Appendix A of this Report

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,

Division of Site and Environmental Reviews/Office of New Reactors/U.S. Nuclear Regulatory Commission

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, 

provide name and mailing address.)

and mailing address.)

10. SUPPLEMENTARY NOTES

Docket Nos. 52-034 and 52-035

11. ABSTRACT (200 words or less)

This environmental impact statement (EIS) has been prepared to satisfy the requirements of the National Environmental Policy

Act of 1969, as amended. This EIS has been prepared in response to an application submitted to the U.S. Nuclear Regulatory

Commission (NRC) by Luminant Generation Company LLC (Luminant), acting for itself and as agent for the Nuclear Project

Company LLC (subsequently renamed Comanche Peak Nuclear Power Company LLC), for combined construction permits and

operating licenses (combined licenses or COLs). The proposed actions related to the Luminant application are (1) NRC

issuance of COLs for two new nuclear power reactor units (Units 3 and 4) at the Comanche Peak Nuclear Power Plant (CPNPP)

site in Hood and Somervell Counties, Texas, and (2) U.S. Army Corps of Engineers (Corps) issuance of a permit to perform

certain construction activities on the site. The Corps is participating with the NRC in preparing this EIS as a cooperating agency

and participates collaboratively on the review team.

After considering the environmental aspects of the proposed action, the NRC staff's recommendation to the Commission is that

the COLs be issued as requested. This recommendation to the Commission is based on (1) the application, including the

environmental report (ER) submitted by Luminant and Luminant's responses to the NRC and Corps staff's request for additional

information (RAIs); (2) consultation with Federal, State, Tribal, and local agencies; (3) the NRC and Corps staff's independent

review; (4) the NRC and Corps staff's consideration of public comments; and (5) the assessments summarized in the EIS,

including the potential mitigation measures identified in the ER and this EIS. the Corps will issue its Record of Decision based,

in part , on the EIS.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.)

Comanche Peak Nuclear Power Plant Units 3 and 4

National Environmental Policy Act/NEPA

Final Environmental Impact Statement/DEIS

Combined License/COL

New Reactors

14. SECURITY CLASSIFICATION

13. AVAILABILITY STATEMENT

unlimited

(This Page)

unclassified

(This Report)

unclassified

15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (12-2010)

Washington, DC 20555-0001

Division of Site and Environmental Reviews/Office of New Reactors/U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001


UNITED STATES 

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

--------------------

OFFICIAL BUSINESS
NUREG

-1943, Vol. 2

Final

Environmental Impact Statement for the Combined Licenses (COLs) for 

Comanche Peak Nuclear Power Plant Units 3 and 4