* U.S.NRC

United States Nuclear Regulatory Commission

Protecting People and the Environment

NUREG-1437

Supplement 37

Generic Environmental

Impact Statement for

License Renewal of

Nuclear Plants

Supplement 37

Regarding

Three Mile Island

Nuclear Station, Unit I

Final Report

Office of Nuclear Reactor Regulation
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U.S.N R NUREG-1437 * U.S.NRCSupplement 37

United States Nuclear Regulatory Commission

Protecting People and the Environment

Generic Environmental

Impact Statement for

License Renewal of

Nuclear Plants

Supplement 37

Regarding

Three Mile Island

Nuclear Station, Unit 1

Final Report

Manuscript Completed: June 2009

Date Published: June 2009

Office of Nuclear Reactor Regulation

ABSTRACT

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

application submitted by Exelon Generation Company, LLC to renew the operating license for

Three Mile Island Nuclear Station, Unit 1 for an additional 20 years.

This supplemental EIS includes the preliminary analysis that evaluates the environmental

impacts of the proposed action and alternatives to the proposed action. Alternatives considered

include replacement power from new supercritical coal-fired generation and natural gas

combined-cycle generation; energy conservation/energy efficiency; and a combination of

alternatives that included natural gas combined-cycle generation, conservation/efficiency, and

improvements to hydroelectric dams; and not renewing the license (the no-action alternative).

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

Mile Island Nuclear Station, Unit 1 are not so great that preserving the option of license renewal

for energy-planning decisionmakers would be unreasonable. This determination is based on (1)

the analysis and findings in the GELS; (2) the Environmental Report submitted by Exelon

Generation; (3) consultation with Federal, Sate, and local agencies; (4) the NRC staff's own

independent review; and (5) the NRC staffs consideration of public comments received during

the scoping process and draft supplement EIS comment period.

June 2009 iii NUREG-1437, Supplement 37

Table of Contents

Table of Contents

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

Executive Sum mary .................................................................................................................. xv

Abbreviations and Acronym s .................................................................................................. xxiii

1.0 Purpose and Need for Action ........................................................................................ 1-1

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

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

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

1.4 Generic Environm ental Im pact Statement ................................................................. 1-3

1.5 Supplem ental Environmental Impact Statement ........................................................ 1-5

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

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

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

1.9 Status of Com pliance ................................................................................................ 1-9

1.10 References .............................................................................................................. 1-11

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

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

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

2.1.2 Radioactive W aste Management .......................................................................... 2-5

2.1.2.1 Radioactive Liquid W aste ............................................................................. 2-6

2.1.2.2 Radioactive Gaseous W aste ......................................................................... 2-7

2.1.2.3 Solid Radioactive W aste ............................................................................... 2-8

2.1.3 Nonradiological W astes ........................................................................................ 2-9

2.1.3.1 Hazardous W aste ..................................... .................................................... 2-9

2.1.3.2 Residual W aste .......................................................................................... 2-10

2.1.3.3 Universal W aste ......................................................................................... 2-10

2.1.3.4 M ixed W aste ............................................................................................... 2-10

2.1.3.5 Perm itted Discharges ................................................................................. 2-11

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

2.1.4 Plant Operation and Maintenance ........................... ........................................... 2-12

2.1.5 Power Transm ission System ............................................................................ 2-12

2.1.6 Cooling and Auxiliary W ater System s ......................... : ....................................... 2-14

2.1.7 Facility W ater Use and Quality ........................................................................... 2-15

2.1.7.1 Ground W ater Use ...................................................................................... 2-15

2.1.7.2 Surface W ater Use ..................................................................................... 2-15

2.1.7.3 Surface W ater Quality ................................................................................. 2-16

2.2 Affected Environm ent .................................................. ............................................ 2-21

2.2.1 Land Use ............................................................................................................ 2-21

2.2.2 Air and Meteorology ........................................................................................... 2-22

June 2009 v NUREG-1437, Supplement 37
Table of Contents

2.2.2.1 Regional Air Quality Impacts.... '................ ..... ......... 2-25

2.2.3 Ground W ater Resources ................................................................................... 2-25

2.2.3.1 TM I-1 W ater Supply W ells .......................................................................... 2-26

2.2.3.2 TMI-1 Monitoring W ells ............................................................................... 2-27

2.2.4 Surface W ater Resources .................................................................................. 2-28

2.2.5 Description of Aquatic Resources ....................................................................... 2-31

Macroinvertebrates .................................................................................................. 2-31

Plankton .................................................................................................................. 2-32

Fish ......................................................................................................................... 2-32

2.2.6 Terrestrial Resources ......................................................................................... 2-35

2.2.7 Threatened and Endangered Species ................................................................ 2-38

2.2.7.1 Aquatic Species .......................................................................................... 2-38

2.2.7.2 Terrestrial Species ...................................................................................... 2-39

Federally Protected and Formerly Protected Terrestrial Species ............................. 2-39

State Protected Terrestrial Species ......................................................................... 2-40

2.2.8 Socioeconom ic Factors ...................................................................................... 2-49

2.2.8.1 Housing ...................................................................................................... 2-50

2.2.8.2 Public Services ........................................................................................... 2-51

W ater Supply ........................................................................................................... 2-51

Education ................................................................................................................ 2-52

Transportation ......................................................................................................... 2-53

2.2.8.3 Offsite Land Use ......................................................................................... 2-54

Dauphin County ....................................................................................................... 2-54

Lancaster County .................................................................................................... 2-55

2.2.8.4 Visual Aesthetics and Noise ....................................................................... 2-56

2.2.8.5 Demography ............................................................................................... 2-57

Transient Population ................................................................................................ 2-59

Migrant Farm W orkers ............................................................................................. 2-60

2.2.8.6 Economy .................................................................................................... 2-62

Em ployment and Incom e ......................................................................................... 2-62

Unem ployment ........................................................................................................ 2-63

Taxes ...................................................................................................................... 2-63

2.2.9 Historic and Archaeological Resources ............................ 2-65

2.2.9.1 Cultural Background ...................................... 2-65

2.2.9.2 Historic and Archaeological Resources ......................... 2-68

2.3 Related Federal and State Activities ................................. 2-70

2.4 References ................. ............................................................................................. 2-71

3.0 Environm ental Im pacts of Refurbishm ent..................................................................... 3-1

3.1 Refurbishment Activities at TM I-1 .............................................................................. 3-2

3.2 Environmental Im pacts of Refurbishm ent .................................................................. 3-4

3.2.1 Terrestrial Resources - Refurbishm ent Im pacts ................................................... 3-5

3.2.2 Threatened and Endangered Species .................................................................. 3-6

3.2.2.1 Terrestrial Species ..................................................................................... *.3-6

3.2.2.2 Aquatic Species ............................................................................................ 3-6

3.2.3 Air Quality During Refurbishment (Non-Attainment and Maintenance Areas) ....... 3-7

NUREG-1437, Supplement 37 vi June 2009
Table of Contents

3.2.4 Housing Im pacts ................................................................................................ 3-10

3.2.5 Public Services - Education (Refurbishm ent) ..................................................... 3-10

3.2.6 Public Services - Public Utilities ........................................................................ 3-10

3.2.7 Public Services - Transportation ........................................................................ 3-11

3.2.8 Offsite Land Use (Refurbishm ent) ...................................................................... 3-12

3.2.9 Historic and Archaeological Resources ............................................................. 3-12

3.2.10 Environm ental Justice ........................................................................................ 3-13

3.3 Evaluation of New and Potentially Significant Information on Impacts of

Refurbishm ent ........................................................................................................ 3-13

3.4 Sum m ary of Im pacts of Refurbishm ent .................................................................... 3-14

3.5 References ............................................................................................................... 3-14

4.0 Environm ental Im pacts of Operation ............................................................................ 4-1

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

4.2 Air Q uality .................................................................................................................. 4-1

4.3 G round W ater ............................................................................................................ 4-2

4.3.1 Ground Water Use Conflicts (plants using greater than 100 gpm) ........................ 4-2

4.3.2 G round W ater Use Conflicts (m ake-up from a sm all river) .................................... 4-2

4.4 Surface W ater ......................................................................................................... 4-3

4.4.1 W ater Use Conflicts ............................................................................................. 4-4

4.5 Aquatic Resources .................................................................................................... 4-5

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

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

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

4.7.2 Terrestrial Species ............................................................................................... 4-7

4.8 Hum an Health ........................................................................................................... 4-9

4.8.1 Generic Hum an Health Issues.............................................................................. 4-9

4.8.2 M icrobiological O rganism s - Public Health ......................................................... 4-12

4.8.3 Electrom agnetic Fields - Acute Effects (Electric Shock) ...................................... 4-15

4.8.4 Electrom agnetic Fields - Chronic Effects ........................................................... 4-17

4.9 Socioeconom ics ................................................................ ........ 4-17

4.9.1 Generic Socioeconom ic Issues ......................................................................... 4-18

4.9.2 Housing Im pacts ................................................................................................. 4-18

4.9.3 Public Services: Public Utility Im pacts ................................................................ 4-19

4.9.4 Offsite Land Use - License Renewal Period ....................................................... 4-20

Population-Related Im pacts ..................................................................................... 4-20

Tax Revenue-Related Im pacts ................................................................................ 4-21

4.9.5 Public Services: Transportation Im pacts ....... I ...................................................... 4-21

4.9.6 Historic and Archaeological Resources ............................. 4-22

4.9.7 Environm ental Justice ........................................................................................ 4-24

M inority Population in 2000 ..................................................................................... 4-26

Low-Income Population in 2000 .......... ........................... 4-26

Analysis of Im pacts .................................................................................................. 4-29

Subsistence Consum ption of Fish and W ildlife ........................................................ 4-29

June 2009 vii NUREG-1437, Supplement 37
Table of Contents

4.10 Evaluation of New and Potentially Significant Information ........................................ 4-31

4.11 Cum ulative Impacts ................................................................................................. 4-32

4.11.1 Cumulative Impacts on W ater Resources ........................................................... 4-32

4.11.2 Cumulative Impacts on Aquatic Resources ........................................................ 4-34

4.11.3 Cumulative Impacts on Terrestrial Resources ................................................... 4-37

4.11.4 Cumulative Human Health Impacts .................................................................... 4-39

4.11.5 Cumulative Socioeconomic Impacts ................................................................... 4-41

4.11.6 Summary of Cumulative Impacts ........................................................................ 4-42

4.12 References .............................................................................................................. 4-43

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

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

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

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

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

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

5.3.3 Potential Plant Improvements ............................................................................... 5-6

5.3.4 Evaluation of Risk Reduction and Costs of Improvements .................................... 5-7

5.3.5 Cost-Benefit Comparison ..................................................................................... 5-7

5.3.6 Conclusions .......................................................................................................... 5-9

5.4 References ................................................................................................................ 5-9

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

6.1 References ................................................................................................................ 6-2

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

7.1 References ................................................................................................................ 7-1

8.0 Environmental Impacts of Alternatives .......................................................................... 8-1

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

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

Sulfur Oxides ............................................................................................................. 8-6

Nitroqen Oxides .......................................................................................................... 8-6

Particulates ................................................................................................................ 8-7

Carbon Monoxide ...................................................................................................... 8-7

Hazardous Air Pollutants ........................................................................................... 8-7

Carbon Dioxide .......................................................................................................... 8-8

Summary of Air Quality .............................................................................................. 8-8

8.1.2 Ground W ater Use and Quality ............................................................................. 8-8

8.1.3 Surface W ater Use and Quality ............................................................................ 8-9

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

Terrestrial Ecology ..................................................................................................... 8-9

Aquatic Ecology ........ I ................................................................................................ 8-9

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

Radiological Human Health Risks ............................................................................ 8-10

PAH Human Health Risks ........................................................................................ 8-10

NUREG-1437, Supplement 37 viii June 2009
Table of Contents

Mercury Human Health Risks ................................................................................... 8-11

NOx and S02 Human Health Risks .......................................................................... 8-11

8.1.6 Socioeconom ics ................................................................................................. 8-12

Land Use ................................................................................................................ 8-12

Socioeconom ics ...................................................................................................... 8-13

Transportation ................................................................................ .......................... 8-14

Aesthetics ........................................................................................... ................... 8-14

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

Environmental Justice ........................................... 8-15

8.1.7 W aste Managem ent .......................................................................................... 8-16

8.2 Natural Gas Combined-Cycle Generation ............................. 8-16

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

8.2.2 Ground W ater Use and Quality .......................................................................... 8-20

8.2.3 Surface W ater Use and Quality . . . . . .............................. ......................... 8-20

8.2.4 Terrestrial and Aquatic Ecology ......................................................................... 8-20

Terrestrial Ecology ................................................................................................... 8-20

Aquatic Ecology ..................................................................................................... 8-21

8.2.5 Hum an Health .................................................................................................... 8-21

8.2.6 Socioeconom ics ................................................................................................. 8-21

Land Use ................................................................................................................. 8-21

Socioeconom ics ..................................................................................................... 8-22

Transportation ........................................................................................................ 8-23

Aesthetics ................................................................. 8-23

Historic and Archaeological Resources ............................... .... 8-24

Environmental Justice .................. ......................... 8-24

8.2.7 W aste Managem ent ........................................................................................... 8-25

8.3 Energy Conservation/Energy Efficiency .................................................................. 8-25

8.3.1 Air Quality .......................................................................................................... 8-27

8.3.2 Ground W ater Use and Quality ............................................................................ 8-27

8.3.3 Surface W ater Use and Quality ....................................................................... 8-27

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

Terrestrial Ecology ............................................. 8-27

Aquatic Ecology ...................................................................................................... 8-27

8.3.5 Human Health 8-2.........................

8-28

8.3.6 Socioeconom ics ................................................................................................. 8-29

Land Use ................................................................................................................. 8-29

Socioeconom ics ..................................................................................................... 8-29

Transportation ........................................................................................................ 8-29

Aesthetics ................................................................................................................ 8-29

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

Environmental Justice ............................................................................................. 8-29

8.3.7 W aste Management ........................................................................................... 8-30

8.4 Com bination Alternative ........................................................................................... 8-30

8.4.1 Air Quality ........................................................................................................... 8-31

June 2009 ix NUREG-1437, Supplement 37
Table of Contents

8.4.2 Ground W ater Use and Quality .......................................................................... 8-32

8.4.3 Surface W ater Use and Quality .......................................................................... 8-32

8.4.4 Terrestrial and Aquatic Ecology .......................................................................... 8-32

Terrestrial Ecology ................................................................................................... 8-32

Aquatic Ecology .......................................................................... 8-33

8.4.5 Human Health .................................................................................................... 8-33

8.4.6 Socioeconomics ................................................................................................ 8-33

Land Use ................................................................................................................. 8-33

Socioeconomics ...................................................................................................... 8-34

Transportation ......................................................................................................... 8-34

Aesthetics ................................................................................................................ 8-35

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

Environmental Justice ............................................................................ ................ 8-35

8.4.7 W aste Management ........................................................................................... 8-36

8.5 Purchased Power .................................................................................................... 8-36

8.6 Alternatives Considered but Dismissed ................................................................... 8-36

8.6.1 Coal-Fired Integrated Gasification Combined-Cycle ........................................... 8-37

8.6.2 New Nuclear ...................................................................................................... 8-37

8.6.3 W ind Power ........................................................................................................ 8-37

8.6.4 Solar Power ........................................................................................................ 8-38

8.6.5 W ood W aste ............................................... 8-38

8.6.6 Conventional Hydroelectric Power ...................................................................... 8-39

8.6.7 Wave and Ocean Energy ...................................... 8-39

8.6.8 Geothermal Power ............................................................................................. 8-39

8.6.9 Municipal Solid W aste ........................................................................................ 8-40

8.6.10 Biofuels .............................................................................................................. 8-40

8.6.11 Oil-Fired Power ............. ; ................................ 8-41

8.6.12 Fuel Cells ........................................................................................................... 8-41

8.6.13 Delayed Retirement ........................................................................................... 8-41

8.7 No-Action Alternative ............................................................................................... 8-42

8.7.1 Air Quality .......................................................................................................... 8-43

8.7.2 Ground W ater Use and Quality ........................................................................... 8-43

8.7.3 Surface W ater Use and Quality .......................................................................... 8-43

8.7.4 Aquatic and Terrestrial Ecology ....................................................... ................... 8-43

Terrestrial Ecology ................................................................................................... 8-43

Aquatic Ecology ....................................................................................................... 8-43

8.7.5 Human Health .................................................................................................... 8-43

8.7.6 Socioeconomics ................................................................................................. 8-44

Land Use ................................................................................................................ 8-44

Socioeconomics ...................................................................................................... 8-44

Transportation ......................................................................................................... 8-44

Aesthetics ................................................................................................................ 8-45

Historic and Archaeological Resources ................................................................... 8-45

Environmental Justice ............................................................................................. 8-45

8.7.7 W aste Management ........................................................................................... 8-45

8.8 Alternatives Summary ............................................................................................. 8-45

NUREG-1437, Supplement 37 x June 2009
Table of Contents

8 .9 R eferences ...................................................................................... I ....................... 8-47

9 .0 C o nclusio n .................................................................................................................... 9-1

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

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

9.3 R esource C om m itm ents ............................................................................................ 9-2

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

9.3.2 Relationship Between Local Short-Term Uses of the Environment and the

Maintenance and Enhancement of Long-Term Productivity ........................... 9-3

9.3.3 Irreversible and Irretrievable Commitments of Resources .................................... 9-4

9.4 R ecom m endations ..................................................................................................... 9-4

10.0 List of P reparers .......................................................................................................... 10-1

1 1 .0 In d e x ........................................................................... ............................................... 1 1-1

A. Comments Received on the Three Mile Island Nuclear Station, Unit 1,

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

B. NEPA Issues for License Renewal of Nuclear Power Plants ..................................... B-1

C. Applicable Regulations, Laws, and Agreements ....................................................... C-1

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

E. Chronology of Environmental Review Correspondence ........................................... E-1

F. U.S. Nuclear Regulatory Commission Staff Evaluation of Severe Accident

Mitigation Alternatives (SAMAs) for Three Mile Island Nuclear Station, Unit 1 in

Support of License Renewal Application Review ....................................................... F-1

FIGURES

Figure 1-2.

Figure 2-1.

Figure 2-2.

Figure 2-3.

Figure 2-4.

Figure 2-5.

Figure 2-6.

June 2009

Environmental Issues Evaluated During License Renewal ................................... 1-5

Location of Three Mile Island Nuclear Station, Unit 1, 50-mi (80-km)

R e g io n ............................................................................................................... 2 -2

Location of Three Mile Island Nuclear Station, Unit 1, 6-mi (10-km) Region ......... 2-3

Three Mile Island Nuclear Station, Unit 1, General Site Layout ............................. 2-4

Three Mile Island Nuclear Station Unit 1, Transmission System ......................... 2-13

Three Mile Island Nuclear Station, Unit 1, Inlet and Discharge

T em pe ratures ................................................................................................... 2-17

Three Mile Island Nuclear Station, Unit 1, Site Boundary Map ............................ 2-23

xi NUREG-1437, Supplement 37
Table of Contents

Figure 2-7. Monthly Mean Flow of the Susquehanna River in 2004 and the Maximum,

Mean, and Minimum Monthly Mean Flow Date for 1891-2004 .......................... 2-30

Figure 2-8. Three Mile Island Nuclear Station, Unit 1, Site Area Over Map

and Transm ission Lines .................................................................................... 2-36

Figure 4-1. Aggregate Minority Populations Within 50 Mi (80 km) of Three Mile Island

N uclear S tation, U nit 1 ...................................................................................... 4-27

Figure 4-2. Low Income Populations Within 50 Mi (80 km) of Three Mile Island

N uclear S tation, U nit 1 ...................................................................................... 4-28

TABLES

Table 2-1. Monthly Average, Minimum, and Maximum AT (OF) Based on Automatic

Temperature Sensors at the Intake Screen Pump House ................................. 2-18

Table 2-2. National Pollutant Discharge Elimination System Effluent Limitations for

T M I-1 ................................................................................................................ 2 -2 0

Table 2-3. Total Annual Ground Water Withdrawal (Gallons) and Average Daily

Withdrawal Rate (Gallons) for Industrial Wells, A, B, and C and

Combined for 2003-2005 ................................................................................. 2-27

Table 2-4. Rate of Tritiated Ground Water Migration to the Susquehanna River as

Affected by Onsite Pumping and Background Levels of Tritium (Curies

P e r Y ea r) ......... ................................................................................................. 2-2 8

Table 2-5. American Shad Passage at the Conowingo, Holtwood, Safe Harbor, and

Red Hill Dams on the Susquehanna River ........................................................ 2-34

Table 2-6. Listed Aquatic and Terrestrial Species ................................................................. 2-42

Table 2-7. TMI-1 Employee Residence By County ................................................................ 2-50

Table 2-8. Housing in Dauphin and Lancaster, Pennsylvania ............................................. 2-51

Table 2-9. Major Public Water Supply Systems .................................................................... 2-52

Table 2-10. Major Commuting Routes in the Vicinity of the Three Mile Island Nuclear

Station and 2006 Average Annual Daily Traffic (AADT) Counts ........................ 2-53

Table 2-11. Population and Percent Growth in Dauphin County and Lancaster County,

Pennsylvania, from 1970 to 2000, and Projected for 2010 and 2050 ................ 2-57

Table 2-12. Demographic Profile of the Population in the TMI-1 Two-County

Socioeconomic Region of Influence in 2000 ......................... 2-58

Table 2-13. Demographic Profile of the Population in the TMI-1 Two-County

Socioeconomic Region of Influence in 2006 (Estimate) .................................... 2-59

Table 2-14. Seasonal Housing in Counties Located within 50 Miles of TMI-1 ....................... 2-59

Table 2-15. Migrant Farm Worker and Temporary Farm Labor in Counties Located

w ithin 50 M iles of T M I-1 .................................................................................... 2-61

Table 2-16. Major Employers in Dauphin County in 2007 ..................................................... 2-62

Table 2-17. Income Information for the TMI-1 Socioeconomic Region of Influence ............... 2-63

Table 2-18. TMI-1 Property Tax Paid and Percentage of Dauphin County,

Londonderry Township, and the Lower Dauphin School District from

Property Tax Revenues, 2000 to 2005 .............................................................. 2-64

Table 3-1. Issues Related to Refurbishment at TMI-1 ............................................................. 3-1

Table 4-1. Land U se Issues .................................................................................................... 4-1

NUREG-1437, Supplement 37 xii June 2009
Table of Contents

T able 4-2. A ir Q uality Issue ..................................................................................................... 4-1

Table 4-3. Ground Water Use and Quality Issues ................................................................... 4-2

Table 4-4. Surface Water Quality Issues ................................................................................ 4-3

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

Table 4-6. Terrestrial Resources Issues ................................................................................. 4-6

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

Table 4-8. Hum an Health Issues ............................................................................................. 4-9

Table 4-9. Results of Induced Current Analysis .................................................................... 4-16

Table 4-10. Socioeconom ic Issues ....................................................................................... 4-18

Table 4-11. Summary of Cumulative Impacts on Resources Areas ...................................... 4-42

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

Table 5-2. TMI-1 Internal Events Core Damage Frequency ................................................... 5-5

Table 5-3 TMI-1 External Flooding Events Core Damage Frequency ..................................... 5-5

Table 5-4. Breakdown of Population Dose by Containment Release Mode ............................ 5-6

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

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

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

Compared to Continued Operation of TMI-1 ....................................................... 8-5

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

Generation Compared to Continued Operation of TMI-1 ................................... 8-18

Table 8-3. Summary of Environmental Impacts of Energy Conservation/Energy

Efficiency Compared to Continued Operation of TMI-1 ..................................... 8-26

Table 8-4. Summary of Environmental Impacts of the Combination Alternative

Compared to Continued Operation of TMI-1 ..................................................... 8-31

Table 8-5. Summary of Environmental Impacts of the No Action Alternative Compared

to Continued Operation of TMI-1 ...................................................................... 8-42

Table 8-6. Summary of Environmental Impacts of Selected Alternatives Compared to

Continued Operation of TMI-1 ........................................................................... 8-47

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

Table A-I. Commenters on the Scope of the Environmental Review ..................................... A-2

Table A-2. Commenters on the Draft Supplemental EIS .................................................. A-1 8

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

Table C-1. State Environmental Requirements ................................ C-1

Table C-2. Federal, State, and Local Permits and Other Requirements ................................. C-3

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

Table F-i.a TMI-1 Internal Events Core Damage Frequency .................................................. F-3

Table F-i.b TMI-1 External Flooding Events Core Damage Frequency .................................. F-3

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

Table F-3. TMI-1 PRA Historical Summary ............................................................................. F-6

Table F-4. TMI-1 Seismic Events Core Damage Frequency.. ..................... F-9

Table F-5. TMI-1 Fire Areas and Their Contribution to Fire CDF ....................................... F-10

Table F-6. SAMA Cost/Benefit Screen Analysis for TMI-1 .................................................... F-22

June 2009 xiii NUREG-1437, Supplement 37

EXECUTIVE SUMMARY

Background

By letter dated January 8, 2008, Exelon Generation Company, LLC (Exelon Generation)

submitted an application to the U.S. Nuclear Regulatory Commission (NRC) to issue a renewed

operating license for Three Mile Island Nuclear Station, Unit 1 (TMI-1) for an additional 20-year

period.

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

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

States Code (42 U.S.C. 4321), in Title 10 of the Code of Federal Regulations (CFR), Part 51 (10

CFR Part 51). In 10 CFR 51.20(b)(2), the Commission indicates that issuing a renewed power

reactor operating license requires preparation of an Environmental Impact Statement (EIS) or a

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

operating license renewal stage will be a supplement to the Generic Environmental Impact

Statement for License Renewal of Nuclear Plants (GELS), NUREG-1 437, Vol. 1 and 2 (NRC

1996, 1999).

Upon acceptance of Exelon Generation's application, we (the NRC staff) began the

environmental review process described in 10 CFR Part 51 by publishing a Notice of Intent to

prepare an EIS and conduct scoping. We conducted a site audit at the plant in late April 2008

and held public scoping meetings on May 1, 2008, in Middletown, Pennsylvania. In the

preparation of this supplemental EIS for TMI-1, we reviewed Exelon Generation's environmental

report and compared it to the GELS, consulted with other agencies, conducted a review of the

issues following the guidance set forth in NUREG-1 555, Supplement 1: Standard Review Plans

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

Renewal (NRC 2000), and considered the public comments received during the scoping

process and on the draft supplemental EIS.

Proposed Action

Exelon Generation initialized the proposed Federal action-issuing a renewed power reactor

operating license-by submitting an application for license renewal of TMI-1, for which the

existing license (DPR-50) expires April 19, 2014. NRC's Federal action is the decision whether

to renew the license for an additional 20 years.

Purpose and Need for Action

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

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

plant operating license, and to meet future system generating needs, as determined by State,

utility, and, where authorized, Federal (other than NRC) decisionmakers. This definition of

purpose and need for action reflects the Commission's recognition that, unless there are

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

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

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

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

If the renewed license is issued, State regulatory agencies and Exelon Generation will ultimately

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

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

June 2009 XV NUREG-1437, Supplement 37
Summary

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

the current operating license-April 19, 2014.

Environmental Impacts of License Renewal

The supplemental EIS evaluates the potential environmental impacts of the proposed action.

The environmental impacts from the proposed action can be SMALL, MODERATE, or LARGE.

Exelon Generation and the NRC staff established separate processes for identifying and

evaluating the significance of any new and significant information on the environmental impacts

of license renewal of TMI-1. Neither Exelon Generation nor the NRC identified information that

is both new and significant related to Category I issues that would call into question the

conclusions in the GElS. Similarly, neither the scoping process nor the NRC has identified any

new issue applicable to TMI-1 that has a significant environmental impact. Therefore, the NRC

staff relies upon the conclusions of the GElS for all the Category 1 issues applicable to TMI-1.

Land Use

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

identify any new and significant information during the environmental review. Therefore, there

would be no impacts beyond those discussed in the GELS.

Air Quality

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

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

review. Therefore, for plant operation during the license renewal term, there are no impacts

beyond those discussed in the GElS.

However, air quality during refurbishment (in nonattainment and maintenance areas) is a

Category 2 issue. Emission calculations for refurbishment activities at TMI-1 indicate that

emissions are not expected to exceed emission budgets specified in the Pennsylvania State

Implementation Plan, and on this basis, the NRC staff concludes that the impact of vehicle

exhaust emissions resulting from refurbishment activities would be SMALL. Potential mitigation

measures include implementation of best management practices for dust control and the use of

staggered workforce shift changes to reduce the number of vehicles on the road at any one

given time.

Ground Water Use and Quality

SMALL. Ground water use conflicts: potable and service water-plants using greater than 100

gallons per minute; and plants using cooling towers withdrawing make-up water from a small

river) are Category 2 issues related to license renewal at TMI-1. Information provided by Exelon

Generation, including Susquehanna River Basin Commission pump test data, shows that TMI-1

ground water withdrawal has no effect on offsite ground water wells and ground water supplies.

In addition, the withdrawal of surface water from the Susquehanna River is a small percentage

of overall river flow and does not affect ground water levels in the area.

Surface Water Use and Quality

SMALL. Water use conflicts-plants with cooling ponds or cooling towers using make-up water

from a small river with low flow is a Category 2 issue related to license renewal at TMI-1.

Withdrawals of Susquehanna River water by TMI-1 are less than 1.6 percent of the lowest daily

mean flow and less than 0.1 percent of the average annual flow of the river. TMI-1 also

NUREG-1437, Supplement 37 xvi June 2009
Summary

participates in the Cowanesque Lake water storage project, which releases water to the

Susquehanna River during drought conditions. There are no Category 2 issues related to

surface water use and quality during refurbishment activities.

Aquatic Resources

SMALL. With regard to operation of TMI-1 during the license renewal term, the NRC did not

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

significant information during the environmental review. Therefore, there are no impacts beyond

those discussed in the GELS. Besides Threatened and Endangered Species (discussed below),

there are no Category 2 issues related to aquatic resources during refurbishment activities.

Terrestrial Resources

SMALL. With regard to operation of TMI-1 during the license renewal term, the NRC did not

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

significant information during the environmental review. Therefore, there are no impacts beyond

those discussed in the GEIS.

Impacts to terrestrial resources during refurbishment activities is a Category 2 issue. The

majority of refurbishment activities will take place on existing facility grounds at TMI-1, and new,

permanent structures will be constructed on previously disturbed land. Exelon Generation's

steam generator vendor, AREVA NP, Inc. (AREVA) is required to obtain all necessary Federal

and State environmental and construction permits to cover the transportation route of the new

steam generators from Port Deposit, Maryland, to the TMI-1 site. Environmental and

construction permits, as well as consultation correspondence with Pennsylvania and Maryland

State resource agencies, will likely contain mitigation measures to minimize impacts to

terrestrial resources, including installing silt fences to minimize sediment transport, the use of

best management practices, and the restoration of cleared land upon completion of construction

activities. Based on the environmental permit requirements and implementation of mitigation

measures, impacts to terrestrial resources during refurbishment activities at the TMI-1 site and

along the steam generator transportation route will be SMALL.

Threatened and Endangered Species

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

and during refurbishment activities are Category 2 issues. The U.S. Fish and Wildlife Service

indicated that no known Federally-listed threatened and endangered species occur within the

project area; therefore, the proposed project would not likely impact any Federally-listed

species. The Pennsylvania Department of Natural Resources indicated that although several

State-listed species of concern are known to occur in the vicinity of the TMI-1 project site, no

impact to these species is anticipated. Furthermore, the Pennsylvania Fish and Boat

Commission indicated that no adverse impacts to State-listed rare, candidate, threatened, or

endangered aquatic species are expected from the proposed project.

Refurbishment activities will take place on existing facility grounds at the TMI-1 site, and new,

permanent structures will be constructed on previously disturbed land; therefore, no impact to

these species is anticipated.

June 2009 xvii NUREG-1437, Supplement 37
Summary

With regard to the transportation of the new steam generators from Port Deposit, Maryland, to

the TMI-1 site, AREVA is required to consult with the Pennsylvania Fish and Boat Commission,

the Pennsylvania Game Commission, and the Pennsylvania Department of Natural Resources

to determine if modifications to existing bridges, construction of temporary bridge by-passes,

and other infrastructure modifications could impact threatened and endangered species along

the steam generator transportation route. The consultation process will likely include mitigation

measures to minimize potential impacts to threatened or endangered species that may be

present in the vicinity of transportation route. AREVA will also require a joint permit for waterway

construction work from the Pennsylvania Department of Environmental Protection and the U.S.

Army Corps of Engineers. Approval of this permit is predicated on consultations with State

resource agencies regarding impacts to threatened and endangered species.

Human Health

SMALL. With regard to Category 1 human health issues during the license renewal termmicrobiological organisms (occupational health), noise, radiation exposures to public,

occupational radiation exposures, and electromagnetic fields (chronic effects)-the staff did not

identify any new or significant information during the environmental review. Therefore, there are

no impacts beyond those discussed in the GELS. Refurbishment activities are not expected to

generate an amount of radioactive material that is significantly different from the historical

radiological effluent releases which included refueling outage activities. Based on past

regulatory compliance, the dose to a maximally exposed individual in the vicinity of TMI-1 for the

refurbishment period is expected to continue to be a small fraction of the limits and standards

specified in 10 CFR Part 20, Appendix I to 10 CFR Part 50, and 40 CFR Part 190.

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

shock) are Category 2 human health issues. When thermal discharge from TMI-1 is at its

maximum temperature and the Susquehanna River is at its maximum temperature, the resulting

temperature of the mixed water in the vicinity of the TMI-1 discharge is approximately 91.3

degrees Fahrenheit, which is well outside the optimal growth temperature range of thermophilic

microbiological organisms; therefore the impact is SMALL. Potential mitigation measures to

reduce human health impacts include monitoring for thermophilic organisms in the water and

sediments near the discharge, as well as prohibiting recreational use near the discharge plume.

NRC staff reviewed Exelon Generation's analysis of electromagnetic fields-acute shock

resulting from induced charges in metallic structures, and verified that none of TMI-I's in-scope

transmission lines have the capability to induce greater than 5 milliamperes in a vehicle parked

beneath the lines. This finding conforms with National Electric Safety Code provisions for

preventing electric shock from induced current. Potential mitigation measures include limiting

public access to transmission line structures, installing signs at road crossings, and increasing

transmission line clearances. The NRC staff considers the GElS finding of "uncertain" for

electromagnetic fields-chronic effects still appropriate and will continue to follow developments

on this issue.

NUREG-1437. SuDDlement 37 xviii June 2009 . . . . . . . • - - r i . . . .
Summary

Socioeconomics

SMALL. The NRC identified no Category 1 public service and aesthetic impacts applicable to

TMI-1, or new and significant information during the environmental review. Therefore, there

would be no impacts related to these issues beyond those discussed in the GELS. Category 2

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

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

TMI-1 is located in a high-density population area, and growth-control measures are not in

effect, any changes in TMI-1 employment would have little noticeable effect on housing

availability in the surrounding area. Exelon Generation has indicated they have no plans to-add

non-outage employees during the license renewal period; therefore non-outage employment

levels at TMI-1 would remain relatively unchanged with no additional demand for public water

and sewer services. This also applies to offsite land use and transportation issues. Because

non-outage employment levels at TMI-1 would remain relatively unchanged during the license

renewal period, there would be no land use impacts related to population or tax revenues, and

no transportation impacts. Category 2 socioeconomic impacts related to refurbishment at TMI-1

would be SMALL, because the TMI-1 steam generator project is expected to require a one-time

increase of outage workers for up to 70 days-a short duration of time.

No impacts to known historic and archaeological resources are expected from the continued

operation of TMI-1 during the license renewal term. Exelon Generation has indicated no plans to

change or modify the plant or transmission line structures. Based on the review of Pennsylvania

Historical and Museum Commission files, archaeological surveys, assessments, and other

information, the potential impacts on historic and archaeological resources at TMI-1 would be

SMALL. Since TMI-1 is situated in an archaeologically sensitive area, development of a cultural

resources management plan in addition to Exelon Generation's review procedures would serve

to integrate cultural resource considerations with ongoing TMI-1 activities. Additionally, training

of Exelon Generation staff in the Section 106 process would ensure that informed decisions are

made when considering the effects of future projects on historic and archaeological resources.

Lands that have not been surveyed should be investigated by a professional archaeologist prior

to any ground disturbance. In addition, the historical farmstead site (36Da235) should be

recorded and evaluated for eligibility. Because refurbishment activities will occur on previously

disturbed land, the impacts associated with refurbishment are not expected to adversely affect

historic or archaeological sites in the area of TMI-1. An analysis of minority and low-income

populations residing within a 50-mile (80-kilometer) radius of TMI-1 indicated there would be no

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

of TMI-1 during the license renewal period. Based on recent monitoring results, concentrations

of contaminants in native leafy vegetation, soils and sediments, surface water, and fish in areas

surrounding TMI-1 have been low (at or near the threshold of detection) and seldom above

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

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

subsistence consumption of fish and wildlife.

Severe Accident Mitigation Alternatives

Since TMI-1 had not previously considered alternatives to reduce the likelihood or potential

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

June 2009 xix NUREG-1437, Supplement 37
Summary

regulation 10 CFR 51.53(c)(3)(ii)(L) requires that TMI-1 evaluate Severe Accident Mitigation

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

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

include changes to plant components, systems, procedures, and training. Based on our review

of potential SAMAs and Exelon Generation responses to the NRC staff's requests for additional

information, we conclude that TMI-1 made a reasonable, comprehensive effort to identify and

evaluate SAMAs. Based on the review of the SAMAs for TMI-1, and the plant improvements

already made, we conclude that none of the potentially cost-beneficial SAMAs relate to

adequately managing the effects of aging during the period of extended operation; therefore,

they need not be implemented as part of the license renewal pursuant to 10 CFR Part 54.

Alternatives

We considered the environmental impacts associated with alternatives to license renewal.

These alternatives include other methods of power generation and not renewing the TMI-1

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

supercritical coal-fired generation, natural gas combined-cycle generation and, as part of the

combination alternative, uprates to existing hydroelectric dams located in Pennsylvania.

Wherever possible, we evaluated potential environmental impacts for these alternatives located

both at the TMI-1 site and at some other unspecified alternate location. Energy

conservation/energy efficiency, purchased power, and a combination alternative, which included

natural gas combined-cycle generation, energy conservation/energy efficiency, and a series of

uprates to hydroelectric dams, were also considered. We evaluated each alternative using the

same impact areas that we used in evaluating impacts from license renewal. The results of this

evaluation are summarized in the table on the following page.

Comparison of Alternatives

The coal-fired alternative is the least environmentally favorable alternative, due to the following:

impacts to air quality from nitrogen oxides, sulfur oxides, particulate matter, polycyclic aromatic

hydrocarbons, carbon monoxide, carbon dioxide, and mercury-and the corresponding human

health impacts; construction impacts to aquatic, terrestrial, and potentially historic and

archaeological resources are also factors that make the coal-fired alternative the least

environmentally favorable alternative. The gas-fired alternative would have slightly lower air

emissions, and impacts to aquatic, terrestrial, and historic and archaeological resources would

vary depending upon location of the plant. Purchased power would likely have operational

impacts that would include aspects of coal-fired, gas-fired, and existing nuclear generation.

The NRC notes that the energy conservation/energy efficiency alternative has SMALL impacts

in all categories evaluated and, upon shut down of TMI-1, current operating impacts of TMI-1

would cease. Therefore, the energy conservation/energy efficiency alternative is the

environmentally preferred alternative to license renewal. All other alternatives capable of

meeting the needs currently served by TMI-1 entail potentially greater impacts than the

proposed action of license renewal of TMI-1. The no-action alternative does not meet the

purpose and need of this supplemental EIS, though if it triggers the energy conservation/energy

efficiency action to replace the capacity currently supplied by TMI-1, it could result in an overall

SMALL impact, as well.

NUREG-1437, Supplement 37 XX June 2009
Summary

Recommendation

The NRC has determined that the adverse environmental impacts of license renewal for TMI-1

are not so great that preserving the option of license renewal for energy-planning

decisionmakers would be unreasonable. This determination is based on (1) the analysis and

findings in the GELS; (2) the Environmental Report submitted by Exelon Generation; (3)

consultation with Federal, Sate, and local agencies; (4) the NRC staffs own independent

review; and (5) the NRC staffs consideration of public comments received during the scoping

process and draft supplement EIS comment period.

Impact Area

"r- 4) 0~ -E

0~~ 000 0 

007 00

< < 0

Alternative < W 0

un

License Renewal SMALL SMALL SMALL SMALL SMALL SMALL' SMALL

Supercritical coal-fired SMALL SMALL to SMALL to SMALL to

alternative at a new site MODERATEL MODERATE LARGE MODERATE LARGE MOETE LRE MDAE

Gas-fired alternative MODERATE SMALL SMALL SMALL SMALL SMALL to SMALL

at the TMI-1 site MODERATE

Gas-fired alternative SALSMALL to

at alnewnsite MODERATE SMALLSML SMALL SMALL to SMALL M tE SMALL

at a new site LARGE MODERATE

Energy Conservation/ SMALL SMALL SMALL SMALL SMALL SMALL SMALL

Energy Efficiency

Combination of SMALL to SMALL to

Alternatives AtraieMDETESMALL MODERATE SMALL SMALL SMALL MOEAE MODERATE SMALL

SMALL to

No Action Alternative SMALL SMALL SMALL SMALL SMALL MODERATE MODERtE SMALL

June 2009 xxi NUREG-1437, Supplement 37

Abbreviations and Acronyms

ABBREVIATIONS AND ACRONYMS

ACC averted cleanup and decontamination costs

AEA Atomic Energy Act of 1954

AEC U.S. Atomic Energy Commission

ALARA as low as reasonably achievable

CDF Core Damage Frequency

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

CFS cubic feet per second

COPC chemicals of potential concern

CWA Clean Water Act.

DBA design-basis accident

DCNR Pennsylvania Department of Conservation and Natural Resources

DOE U.S. Department of Energy

DPR demonstration project reactor

DSM demand-side management

EIA Energy Information Administration (of DOE)

EIS environmental impact statement

ELF-EMF extremely low frequency-electromagnetic field

EMS environmental management system

EOP Emergency Operating Procedure

ER environmental report

EPA U.S. Environmental Protection Agency

ESA Endangered Species Act

ESRP Environmental Standard Review Plan, NUREG-1555, Supplement 1, Operating

License Renewal

FAA Federal Aviation Administration

FES Final Environmental Statement

FR Federal Register

FSAR Final Safety Analysis Report

FWS U.S. Fish and Wildlife Service

GDC general design criteria

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

NUREG-1437

June 2009 xxiii NUREG-1437, Supplement 37
Abbreviations and Acronyms

GPD gallons per day

GPM gallons per minute

HLW high-level waste

IPE Individual Plant Examination

IPEEE Individual Plant Examination of External Events

ISFSI independent spent fuel storage installation

LLMW low-level mixed waste

LLW low-level waste

LNG liquefied natural gas

LOCA loss of coolant accident

LWR light-water reactor

MGD million gallons per day

MSA Magnuson-Stevens Fishery Conservation and Management Act of 1996

Msl mean sea level

MW megawatt

MWe megawatt-electric

MWt megawatt-thermal

NA not applicable

NAAQS National Ambient Air Quality Standards

NAS National Academy of Sciences

NCI National Cancer Institute

NEPA National Environmental Policy Act of 1969

NESC National Electric Safety Code

NHPA National Historic Preservation Act

NIEHS National Institute of Environmental Health Sciences

NMFS National Marine Fisheries Service

NOAA National Oceanic and Atmospheric Administration

NRHP National Register of Historic Places

NO nitrogen oxide(s)

NPDES National Pollutant Discharge Elimination System

NRC U.S. Nuclear Regulatory Commission

NWPPC Northwest Power Planning Council

ODCM Offsite Dose Calculation Manual

PADEP Pennsylvania Department of Environmental Protection

pCi/L picocuries per liter

NUREG-1437, Supplement 37 xxiv J une 2009
Abbreviations and AcronYms

PDS plant damage state

PFBC Pennsylvania Fish and Boat Commission

PGC Pennsylvania Game Commission

PHMC Pennsylvania Historical and Museum Commission

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

PM10 particulate matter, 10 microns or less in diameter

PRA Probabilistic Risk Assessment

PSA Probabilistic Safety Assessment

PSD prevention of significant deterioration

PSW plant service water

PWR pressurized water reactor

RAB reactor auxiliary building

RAI request for additional information

RCP reactor coolant pump

REMP radiological environmental monitoring program

rms root mean square

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

SAMA Severe Accident Mitigation Alternative

SAR Safety Analysis Report

SER Safety Evaluation Report

SHPO State Historic Preservation Office

SO2 sulfur dioxide

SRBC Susquehanna River Basin Commission

TMI-1 Three Mile Island Nuclear Station, Unit 1

TSCA Toxic Substances Control Act

U Uranium

UFSAR Updated Final Safety Analysis Report

U.S. United States

USACE United States Army Corps of Engineers

U.S.C. United States Code

USCB U.S. Census Bureau

USDA U.S. Department of Agriculture

VOCs Volatile Organic Compounds

WHO World Health Organization

June 2009 XXV NUREG-1437, Supplement 37

1.0 PURPOSE AND NEED FOR ACTION

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

in Title 10, Part 51, "Environmental Protection Regulations for Domestic Licensing and Related

Regulatory Functions," of the Code of Federal Regulations (10 CFR Part 51), which implement

the National Environmental Policy Act (NEPA), issuance or renewal of a nuclear power plant

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

The Atomic Energy Act of 1954 originally specified that licenses for commercial power reactors

be granted for up to 40 years with an option to renew for another 20 years. The 40-year

licensing period was based on economic and antitrust considerations rather than on technical

limitations of the nuclear facility.

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

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

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

deny a license renewal application, based on whether the applicant has demonstrated that the

environmental and safety requirements in the agency's regulations can be met during the period

of extended operation.

1.1 Proposed Federal Action

On January 12, 2008, AmerGen Energy Company, LLC (AmerGen) initialized the proposed

Federal action by submitting an application for license renewal of Three Mile Island Nuclear

Station, Unit 1 (TMI-1), for which the existing license, DPR-50, expires April 19,ý 2014. The

NRC's Federal action is the decision whether to renew the license for an additional 20 years.

On January 8, 2009, Exelon Generation Company, LLC (Exelon Generation) officially integrated

the nuclear generation assets held by its subsidiary, AmerGen, into Exelon Generation and

dissolved the AmerGen legal entity. Accordingly, throughout the supplemental EIS, AmerGen

Energy Company, LLC and AmerGen, have been replaced with Exelon Generation Company,

LLC and Exelon Generation, respectively.

1.2 Purpose and Need for the Proposed Federal Action

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

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

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

determined by State, utility, and, where authorized, Federal (other than NRC) decisionmakers.

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

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

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

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

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

If the renewed license is issued, State regulatory agencies and Exelon Generation will ultimately

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

June 2009 1-1 NUREG-1437, Supplement 37
Purpose and Need For Action

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

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

the current operating license-April 19, 2014.

Figure 1-1. Environmental Review Process.

The environmental review process provides opportunities

for public involvement.

1.3 Major Environmental

Review Milestones Appl ication

I Exelon Generation submitted an Submitted to

environmental report (AmerGen NRC

2008a) as part of its license

renewal application (AmerGen

2008) in January 2008. After

reviewing the application and the

environmental report for

sufficiency, the NRC staff

published a Notice of Acceptability

and Opportunity for Hearing on

March 14, 2008, in the Federal *Scoping Environmental

I Register(Vol. 73, p. 13923, (73 FR Process Site Audit

13923)). Then, on March 28, 2008,

the NRC published another notice

in the Federal Register (73 FR

16729) on its intent to conduct Draft

scoping, thereby beginning the 60- SEIS

day scoping period. Issued

The agency held two public

scoping meetings on May 1, 2008,

in Middletown, Pennsylvania. The

NRC report entitled,

"Environmental Impact Statement

Scoping Process Summary Report Process

for Three Mile Island Nuclear

Station, Unit 1," dated August 8,

2008, presents the comments

received during the scoping Final SEIS

process in their entirety (NRC Issued

2008b). Appendix A to this

supplemental EIS presents thef

comments considered to be within

the scope of the environmental NRC

license renewal review and the Decision

associated NRC responses.

NUREG-1437, Supplement 37 1-2 June 2009
Purpose and Need For Action

To independently verify information provided in the environmental report, the NRC staff

conducted a site audit at TMI-1 from April 28 through May 1, 2008. During the site audit, staff

met with plant personnel, reviewed specific documentation, toured the facility, and met with

interested Federal, State, and local agencies. The agency published a summary of that site

audit and a list of the attendees in a report entitled, "Summary of Site Audit Related to the

Review of the License Renewal Application for Three Mile Island Nuclear Station, Unit 1," dated

August 5, 2008 (NRC 2008).

Upon completion of the scoping period and site audit, the staff compiled its findings in this

document, the supplemental EIS (Figure 1-1). The draft supplemental EIS was published in

December 2008. The NRC staff held two public meetings in Harrisburg, Pennsylvania, on

February 24, 2009, to describe the preliminary results of the NRC environmental review, to

answer questions, and to provide members of the public with information to assist them in

formulating comments on the draft supplemental EIS. When the comment period ended on

March 4, 2009, the NRC staff considered and addressed all of the comments received. These

comments are addressed in Section A-2 of Appendix A, Comments Received on the

Environmental Review, in this supplemental EIS.

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

period of time with clear requirements to ensure safe plant operation for up to an additional 20

years of plant life. The safety review is conducted simultaneously with the environmental

review. The staff documents the findings of the safety review in a safety evaluation report. The

Commission considers the findings in both the supplemental EIS and the safety evaluation

report in its decision to either grant or deny the issuance of a new license.

1.4 Generic Environmental Impact Statement

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

license renewal to improve the efficiency of the license renewal. NUREG-1437, Generic

Environmental Impact Statement for License Renewal of Nuclear Power Plants, documents the

results of the NRC's systematic approach to evaluating the environmental consequences of

renewing the licenses of individual nuclear power plants and operating them for an additional 20

years (NRC 1996, 1999)1. The NRC staff analyzed in detail and resolved those environmental

issues that could be resolved generically in the Generic Environmental Impact Statement

(GELS).

The GElS establishes 92 separate issues for the NRC staff to independently verify. Of these,

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

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

environmental justice and the chronic effects of electromagnetic fields must be evaluated on a

site-specific basis. Appendix B to this report lists all 92 issues.

For each potential environmental issue, the GElS (1) describes the activity that affects the

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

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

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

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

June 2009 1-3 NUREG-1437, Supplement 37
Purpose and Need For Action

significance of the effect for both beneficial and Significance indicates the

adverse effects, (5) determines whether the results impor-tance of likely environmental

of the analysis apply to all plants, and (6) considers impacts and is'determined by

whether additional mitigation measures would be ,con'sidering two variables: context'

warranted for impacts that would have the same and intensity.'

significance level for all plants.

The NRC's standard of significance for impacts Context is the geographic,

was established using the Council on biophysical, and social context in

Environmental Quality terminology for "significant." whc h fet ilocr

The NRC established three levels of significance Inest eestjh eeiyo h

for potential impacts-SMALL, MODERATE, and impatens~ whaevers onthex iten ofcuthe ILARGE, as defined below. KImc otx tocr In~ht~ 

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

destabilize nor noticeably alter any important attribute of the resource.

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

important attributes of the resource.

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

attributes of the resource.

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

applied to all plants and whether additional mitigation measures would be warranted (Figure 1-2

on the following page). Issues are assigned a Category 1 or a Category 2 designation. As set

forth in the GElS, Category 1 issues are those that meet all of the following criteria:

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

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

or other specified plant or site characteristics;

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

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

high-level waste and spent fuel disposal); and

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

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

are likely not to be sufficiently beneficial to warrant implementation.

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

supplemental EIS unless new and significant information is identified. Chapter 4 of this report

presents the process for identifying new and significant information. Site-specific issues

(Category 2) are those that do not meet one or more of the criterion for Category 1 issues, and

therefore, additional site-specific review for these issues is required. The supplemental EIS

documents the results of that site-specific review.

NUREG-1437, Supplement 3714Jue20 1-4 June 2009
Purpose and Need For Action

Figure 1-2. Environmental -Issues Evaluated During License Renewal. 92 issues were

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

issues.

Environmental Issue ,relatedt.o

\,nu. nuclear power plant operation.ý,,,

Process

used

Environmental Environmental to analyze

impacts'same impacts differ and

at all sites acrosssites and'

categorizes.

itssues in

.the GElS

Cate gto r Issue 1 Category 2 Issue

... dwaed New isseNeW Issue

significant significant no alyze

informa~tion informalioný in the GElS

related to relatedto.

Process

ýused

to analyze

Site-specific anal ysis issues for

each SEIS

Adopt concl.usions

of the GElS Siesecific'conclusion

1.5 Supplemental Environmental Impact Statement

The supplemental EIS presents an analysis that considers the environmental effects of the

continued operation of TMI-1, alternatives to license renewal, and mitigation measures for

minimizing adverse environmental impacts. Chapter 8 analyzes and compares the potential

environmental impacts from alternatives, while Chapter 9 presents the preliminary

recommendation as to whether or not the environmental impacts of license renewal are so great

that preserving the option of license renewal would be unreasonable. The recommendation will

be made after consideration of comments received during the public scoping period and on the

supplemental EIS.

In the preparation of this supplemental EIS for TMI-1, the staff undertook the following activities:

June 2009 1-5 NUREG-1437, Supplement 37
Purpose and Need For Action

* reviewed the information provided in the Exelon Generation environmental report;

* consulted with other Federal, State, and local agencies;

• conducted an independent review of the issues during site audit; and

• considered the public comments received during the scoping process.

New information can be identified from a

number of sources, including the applicant,

the NRC, other agencies, or public sntionmental issu

comments. If a new issue is revealed,

then it is first analyzed to determine n coered in te GES or (

whether it is within the scope of the license onsidred in the a sistn the GEIS and

renewal evaluation. If it is not addressed danpading that idifrent o

in the GElS then the NRC determines its f presented int GEIS

significance and documents its analysis in

the supplemental EIS.

1.6 Cooperating Agencies

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

agencies in the preparation of this supplemental EIS.

1.7 Consultations

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

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

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

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

fisheries, or historic and archaeological resources, respectively. Below are the agencies and

groups with whom the NRC consulted; Appendix D to this report includes copies of consultation

documents.

Absentee-Shawnee Tribe of Oklahoma, Shawnee, Oklahoma

Advisory Council on Historic Preservation

Cayuga Nation, Versailles, New York

Delaware Nation, Anadarko, Oklahoma

Eastern Shawnee Tribe of Oklahoma, Seneca, Missouri

Oneida Indian Nation, Verona, New York

Oneida Nation of Wisconsin, Oneida, Wisconsin

Onondaga Nation, Nedrow, New York

Pennsylvania Historical and Museum Commission

Seneca-Cayuga Tribe of Oklahoma, Miami, Oklahoma

Seneca Nation of Indians, Salamanca, New York

Shawnee Tribe, Miami, Oklahoma

St. Regis Mohawk Tribe, Akwesasne, New York

Stockbridge-Munsee Band of the Mohican Nation -Wisconsin, Bowler, Wisconsin

Tonawanda Seneca Nation, Basom, New York

NUREG-1437, Supplement 37 1-6 June 2009
Purpose and Need For Action

Tuscarora Nation, Lewiston, New York

U.S. Fish and Wildlife Service, Pennsylvania Field Office

1.8 Correspondence

During the course of the environmental review, the NRC staff contacted the following Federal,

State, regional, local, and tribal agencies. Appendix E to this report contains a chronological list

of all documents sent and received during the environmental review.

Absentee-Shawnee Tribe of Oklahoma, Shawnee, Oklahoma

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

Cayuga Nation, Versailles, New York

Delaware Nation, Anadarko, Oklahoma

Eastern Shawnee Tribe of Oklahoma, Seneca, Missouri

Oneida Indian Nation, Verona, New York

Oneida Nation of Wisconsin, Oneida, Wisconsin

Onondaga Nation, Nedrow, New York

Pennsylvania Department of Conservation and Natural Resources, Harrisburg,

Pennsylvania

Pennsylvania Department of Environmental Protection, Harrisburg, Pennsylvania

Pennsylvania Department of Environmental Protection, South Central Regional Office,

Harrisburg, Pennsylvania

Pennsylvania Fish and Boat Commission, Bellefonte, Pennsylvania

Pennsylvania Game Commission, Harrisburg, Pennsylvania

Pennsylvania Historical and Museum Commission, Harrisburg, Pennsylvania

Seneca-Cayuga Tribe of Oklahoma, Miami, Oklahoma

Seneca Nation of Indians, Salamanca, New York

Shawnee'Tribe, Miami, Oklahoma

St. Regis Mohawk Tribe, Akwesasne, New York

Stockbridge-Munsee Band of the Mohican Nation - Wisconsin, Bowler, Wisconsin

Susquehanna River Basin Commission, Harrisburg, Pennsylvania

Tonawanda Seneca Nation, Basom, New York

Tuscarora Nation, Lewiston, New York

U.S. Fish and Wildlife Service, Pennsylvania Field Office, State College, Pennsylvania

A list of persons who received a copy of this supplemental EIS is provided below:

Senior Vice President- Vice President-Licensing

T Exelon 1 StenePratident Generation. Operations, r,.. .... . .... Mid-Atlantic, and . . ... Regulatory Affairs, Exelon

Exelon 'eneration ~eneraiiori

Regional Administrator, Chairman, Board of.County Chairman, Board of

Commissioners of Dauphin Supervisors of Londonderry Region 1, NRC County Township

Director-Licensing and, David Allard, Pennsylvania

David Kern, Regulatory Affairs, Exeloh Department of Environmental

NRC Generation Protection !

June 2009 *1-7 NUREG-1437, Supplement 37
Purpose and Need For Action

SPlant Manger - TMl-1, Exelon Regulatory Assurance Ronald Bellamy, GeaneMaton Manager-TMI-1, Exelon NRC

Generation Generation

Ronnie Gardner, AREVA NP Judith Johnsrud, Sierra Club Eric Epstein,

Inc. TMI Alert

Manager Licensing-TMI-1i, Correspondence Control Exelon Generation Company, Christopher Crane,

Desk, Exelon Generation LLC Exelon Generation

Charles Pardee, Associate General Counsel, Chief Operating Officer,

Exelon Generation Exelon Generation Exelon Generation

Senior Vice President' Spenatiors Vic P eent- t Frederic W. Polaski, Albert A. Fulvio,

perations Support, Exelon Exelon Nuclear Exelon Nuclear

Generation

Rich Janati, Pennsylvania Michael Murphy, Michael G. Brownell,

Department of Environmental Pennsylvania Department of Susquehanna River Basin

Protection Environmental Protection Commission

Rachel Diamond, Nancy Ranek, Christopher Wilson,

Pennsylvania Department of Nan Nek, Cse r Wlson

Environmental Protection Exelon Nuclear Exelon Nuclear

Michael P. Gallagher, Kathleen Yhip William R. Geisel

Exelon Nuclear

Anne Lovell, James Oliver,

TetraTech NUS TetraTech NUS

Michael R. Helfrich, Lower

Larry Robbins Mary Osborn us eha nn R iveri eeper Susquehanna RiverKeeper

Linda Braasch, Harrisburg Douglas McLearen

Diocesan Council of Catholic Bradford S. Flynn Pennsylvania Historical and

Women Museum Commission

Anne Norton-Miller Kimberly DePaul William S. Arguto

U.S. Environmental U.S. Environmental U.S. Environmental Protection

Protection Agency Protection Agency Agency, Region 3

John J. Piazza Joyce A. Scott

Three Mile Island Nuclear David Atherholt Harrisburg Diocesan Council

Station, Unit 1 of Catholic Women

Karen Walsh Paul Friesema

Pennsylvania Energy Alliance Northwestern University

John Garver Jounty TriCounty Boat Boat Club Charles Alley Scott Portzline, TMI Alert

NUREG-1437, Supplement 37 1-8 June 2009
Purpose and Need For Action

1.9 Status of Compliance

Exelon Generation is responsible for complying with all NRC regulations and other applicable

Federal, State, and local requirements; Appendix H to the GElS describes some of the major

Federal statutes. Table 1-1 lists the numerous permits and licenses issued by Federal, State,

and local authorities for activities at TMI-1.

Table 1-1. Licenses and Permits. Existing environmental authorizations for TMI-1

Operations.

I

Permit Number Dates Responsible

Agency

Issued: 4/19/1974

Operating License DPR-50 U.S. NRC

Expires: 4/19/2014

Consumptive Water Use Permit Docket 19950302 Issued: 3/14/1980 Susquehanna River

Expires: 3/14/2010 Basin Commission

Issued: 1/26/1999 Susquehanna River

Ground Water Withdrawal Permit Docket 19961102 Susqn River Expires: 11/26/2021 Basin Commission

Pennsylvania

Synthetic Minor Operating Permit 22-05029 Department of

Expires: 12/31/2011 Environmental

Protection

Pennsylvania

National Pollutant Discharge PA 0009920 Issued: 10/30/2007 Department of

Elimination System Permit Expires: 10/31/2012 Environmental

Protection

CENAB-OP-RPA 

Maintenance Dredging Permit Issued: 1/3/2006 U.S. Army Corps of (AmerGenEnier

197500083-4) Expires: 12/31/2015 Engineers

Pennsylvania Issued: 1/13/1976 Pennsylvaniao

Maintenance Dredging Permit 21275724 Department of

Expires: Not Listed Environmental

Protection

•Pennsylvania

Issued: 1/20/2000 Departmeantio

Public Water Supply Permit 22296501-TI Department of

Expires: Not Listed Environmental

Protection

June 2009 1-9 NUREG-1437, Supplement 37
Purpose and Need For Action

Permit Number Dates Responsible Agency

Pennsylvania Issued: 1/20/2000 Pnslai

Public Water Supply Permit 22296501-T2 Department of

Expires: Not Listed Environmental

Protection

Acknowledgement of Notification PAR 000037861 Issued: 3/22/1999 U.S. Environmental

of Regulated Waste Activity Expires: Not Listed Protection Agency

Issued: 6/4/2008 Pennsylvania

Storage Tank Registration/Permit 22-60170 Expires: 6/4/2009 Department of

Certificate Environmental

(Annual Renewal) Protection

Hazardous Materials Certificate of 022307-701- Issued: 5/16/2007 U.S. Department of

Registration 002PR Expires: 6/30/2010 Transportation

Flammable and Combustible Issued: 6/12/1970 Pennsylvania

168,466 Department of Liquid Storage Tank Approval Expires: Not Listed Labor and Industry

Flammable and Combustible Issued: 6/12/1970 Pennsylvania

Lammage ank Approval 168,465 Department of Liquid Storage Tank Approval Expires: Not Listed Labor and Industry

Flammable and Combustible Issued: 11/17/1977 Pennsylvania

Liquid Storage Tank Approval 187,165 Department of

Expires: Not Listed Labor and Industry

Flammable and Combustible Issued: 8/4/1989 Pennsylvania

203,271-B Department of Liquid Storage Tank Approval Expires: Not Listed Labor and Industry

Flammable and Combustible Issued: 9/22/1989 Pennsylvania

Liquid Storage Tank Approval 122-203,393 Department of Expires: Not Listed Labor and Industry

Pennsylvania Issued: 1/1/1995 Pnslai

Sewage Disposal System Permit C1 79678 and Department of

Modification C21434 Expires: Not Listed Environmental

Protection

NUREG-1437, Supplement 37 1-10 June 2009
Purpose and Need For Action

Permit Number Dates Responsible

Agency

Pennsylvania

Sewage Sludge Disposal Issued: 6/20/2000 Department of.

Agreement Expires: Not Listed Environmental

Protection

Issued: 4/17/2007 Pennsylvania

Environmental Laboratory Reg. No. 22- Expires: 4/30/2009 Department of

Accreditation Certification 00649 Environmental

(Annual Renewal) Protection

Pennsylvania

On Lot Sewage Disposal System U003282 Issued: 8/10/2007 Department of

Permit Expires: Not Listed Environmental

Protection

1.10 References

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions."

73 FR 13923. U.S. Nuclear Regulatory Commission, Washington, D.C., "Notice of Acceptance

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

Facility Operating License No. DPR-50 for an Additional 20-Year Period; AmerGen Energy

Company, LLC Three Mile Island Nuclear Station, Unit 1." Federal Register: Vol. 73, No. 51,

pp. 13923-13925. March 14, 2008.

73 FR 16729. U.S. Nuclear Regulatory Commission, Washington, D.C., "Three Mile Island

Nuclear Station, Unit 1; Notice of Intent to Prepare an Environmental Impact Statement and

Conduct Scoping Process." Federal Register. Vol. 73, No. 61, pp. 16729-16731. March 28,

2008.

AmerGen (AmerGen Energy Company, LLC). 2008. "Three Mile Island Generating Station, Unit

1, License Renewal Application." ADAMS No. ML080220207.

AmerGen (AmerGen Energy Company, LLC). 2008a. "Three Mile Island Nuclear Station,

Applicant's Environmental Report, License Renewal Operating Stage." Kennett Square,

Pennsylvania. ADAMS Nos. ML080220255, ML080220257, ML080220261, and ML080220282.

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

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

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

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

National Environmental Policy Act of 1969. 42 U.S.C. 4321, et seq.

June 2009 1-11 NUREG-1437, Supplement 37
Purpose and Need For Action

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

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

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

No. ML061770605.

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

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

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

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

NRC (U.S. Nuclear Regulatory Commission). 2008. "Summary of Site Audit Related to the

Review of the License Renewal Application for Three Mile Island Nuclear Station, Unit 1."

ADAMS No. ML081420398.

NRC (U.S. Nuclear Regulatory Commission). 2008b. "Environmental Impact Statement Scoping

Process Summary Report, Three Mile Island Nuclear Station, Unit 1." ADAMS No.

ML081920230.

NUREG-1437, Supplement 37 1-12 June 2009
2.0 AFFECTED ENVIRONMENT

Three Mile Island Nuclear Station, Unit 1 (TMI-1) is located in Londonderry Township of

Dauphin County about 3 miles (mi) (4.8 kilometers [km]) south of Middletown, Dauphin County,

and about 1.25 mi (2 km) east of the community of Goldsboro, York County. The site is

approximately 10 mi (16 km) southeast of Harrisburg, Pennsylvania (AEC 1972). Figures 2-1

and 2-2 present the 50-mi (80-km) and 6-mi (1 0-km) vicinity maps, respectively. For purposes of

the evaluation in this report, the "affected environment" is the environment that currently exists

at and around TMI-1. Because existing conditions are at least partially the result of past

construction and operation at the plant, the impacts of these past and ongoing actions and how

they have shaped the environment are presented here. Section 2.1 of this report describes the

facility and its operation, and Section 2.2 discusses the affected environment.

2.1 Facility Description

This assessment of the affected environment begins with a description of TMI-1, the source of

potential environmental effects. TMI-1 is a pressurized-water reactor (PWR) utilizing oncethrough steam generators and licensed to operate at a power level of 2568 megawatt-thermal

(MWt). Certain buildings and structures associated with Three Mile Island, Unit 2 (TMI Unit 2),

which is owned by FirstEnergy Corporation (FirstEnergy), are intermingled with TMI-1 and its

associated structures. TMI Unit 2 has been shut down since the accident in March 1979. Since

December 1993, it has been in a stable, safe storage mode called post defueling monitored

storage (AmerGen 2008).

The most conspicuous structures on the TMI-1 site are the four, 370-foot, hyperbolic, natural

draft cooling towers. The two cooling towers to the south are inactive and were formerly utilized

by the TMI Unit 2 reactor system. The two northern cooling towers are associated with the TMi1 reactor. Other salient buildings on the TMI-1 site include the reactor building, auxiliary

building, fuel-handling building, station blackout diesel generator building, intake screen and

pump house, and the turbine building(AmerGen 2008). Figure 2-3 provides a general layout of

the TMI-1 site.

2.1.1 Reactor and Containment Systems

TMI-1 is a single-unit plant with a Babcock and Wilcox PWR. Gilbert Associates, Inc. was the

architect-engineer for TMI-1 (AEC 1972). TMI-1 received its construction permit in 1968 and its

operating license in 1974, and began commercial operation on September 2, 1974. The initial

licensed core thermal power of TMI-1 was 2535 MWt. In July 1988, the NRC approved a

measurement uncertainty recapture uprate that increased the core thermal power by 1.3

percent to 2568 MWt (NRC 1996).

The reactor fuel is sintered low-enriched uranium dioxide pellets sealed in zirconium-based alloy

tubing and caps (AmerGen 2008). Core reactivity is controlled by 69 movable control rod

assemblies and borated water (boric acid is a neutron absorber). The control rods are silverindium-cadmium alloy encapsulated in stainless steel. Control rods are used for short-term

reactivity control associated with changes in power level and with changes in fuel burnup

June 2009 2-1 NUREG-1437, Supplement 37
Affected Environment

Legend

* Three Mile Isa Nuclear Station Unit I

Interstate

Major Road

Urban Area

E State Bounday

County Boundary

water

P-asIvm

a13 5 10 1-M W

Figure 2-1. Location of Three Mile Island

Nuclear Station, Unit 1, 50-mi (80-km)

Region (Source: AmerGen 2008)

NUREG-1437, Supplement 37 2-2 June 2009
Affected Environment

Legend

Three Mile Island Nucer. Station Un•it,

Rakoad

Primary Road Awh LUnited Access

= Pmary Road

- Secondary Road

County Boundary

Populated Areas

Water

Figure 2-2. Location of Three Mile Island

Nuclear Station, Unit 1, 6-mi (10-km) Region

(Source: AmerGen 2008)

June 2009 2-3 NUREG-1437, Supplement 37
Metecowlogicat

Tower

Uitdy Bld~g

ILm r

Fence 0 Potable Water Wells enfcle Supply Wells

Unit 2 facilities (not -I--iV-/- Railroad Tracks

operational); not Part of Transmission Lines

TMI-A License Renewal Flood Protection Dike

Joint Facilities TMI-1 & 2 Discharge Pipe

Figure 2-3. Three Mile Island

Nuclear Station, Unit 1, General Site

Layout

(Source: AmerGen 2008) I ______________________________________________________

June 2009 2-4 NUREG-1437, Supplement 37
Affected Environment

between adjustments in reactor coolant dissolved boron concentrations. If a reactor trip signal is

received, all 69 control rod assemblies fall into the core by gravity (AEC 1972).

In the PWR power generation system, reactor heat is transferred from the primary coolant to a

lower pressure secondary coolant loop, allowing steam to be generated in the steam supply

system. The primary coolant loops each contain one steam generator, two centrifugal coolant

pumps, and the interconnected piping. Reactor coolant is pumped from the reactor through the

steam generators and back to the reactor inlet by two centrifugal coolant pumps located at the

outlet of each steam generator. Each steam generator is a vertical straight tube-and-shell heat

exchanger that produces superheated steam at a constant pressure over the reactor operating

power range. Coolant flows downward through the tubes, and steam is generated on the lower

pressure shell side. Steam then flows from the steam generators to the 1800-revolutions per

minute, tandem compound, six-flow turbine generator, manufactured by General Electric (AEC

1972). NUREG/CR-5640, "Overview and Comparison of U.S. Commercial Nuclear Power Plant,

Nuclear Power Plant System Source" (NRC 1990), provides a comprehensive overview and

description of the PWR power generation system.

The primary containment is the reactor building and its associated isolation systems. The

reactor building consists of a reinforced concrete slaband structure with cylindrical wall, a flat

foundation mat, and a shallow dome roof. The 3-ft (1-meter [m]) concrete cylindrical wall is prestressed with a post-tensioning system in the vertical and horizontal directions. The dome roof is

pre-stressed using a three-way post-tensioning system. The inside surface of the-reactor

building is lined with a carbon steel liner 3/4-inch (1.9 centimeter [cm]) thick for the cylinder and

dome and 1/4-inch (0.63 cm) thick for the base.

2.1.2 Radioactive Waste Management

TMI-1 radioactive waste systems are designed to collect, treat, and dispose of the radioactive

and potentially radioactive wastes that are byproducts of plant operations. Byproducts include:

activation products created from the irradiation of reactor water and impurities contained in that

water (which are principally metallic corrosion products); and fission products created by

defective fuel cladding or uranium contamination within the reactor coolant system (AmerGen

2008). Operating procedures for radioactive waste systems ensure that radioactive wastes are

safely processed and discharged from the plant within the limits set forth in 10 CFR Part 20,

"Standards for Protection against Radiation," 10 CFR Part 50, "Domestic Licensing of

Production and Utilization Facilities," the plant's technical specifications, and the TMI-1 offsite

dose calculation manual (ODCM) (AmerGen 2007a).

Radioactive wastes resulting from plant operations are classified as liquid, gaseous, or solid.

Liquid radioactive wastes are generated from liquids received directly from portions of the

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

system. Gaseous radioactive wastes are generated from gases or airborne particulates vented

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

solids from the reactor coolant system, solids that came into contact with reactor coolant system

liquids or gases, or solids used in the reactor coolant system or steam and power conversion

system operation or maintenance (AmerGen 2006a).

June 2009 2-5 NUREG-1437, Supplement 37
Affected Environment

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

as spent fuel. Spent fuel assemblies are removed from the reactor core and replaced with fresh

fuel assemblies during routine refueling outages-typically every 24 months. Spent fuel

assemblies are then stored for a period of time in the spent fuel pool in the reactor building.

The TMI-1 ODCM contains the methodology and parameters used to calculate offsite doses

resulting from radioactive gaseous and liquid effluents, and the gaseous and liquid effluent

monitoring alarm and trip setpoints used to verify the radioactive material being discharged

meets regulatory limits (AmerGen 2007a). The ODCM also contains the radioactive effluent

controls and radiological environmental monitoring activities and descriptions of the information

that should be included in the annual radiological environmental operating report and annual

radioactive effluent release report required by Appendix I, "Numerical Guides for Design

Objectives and Limiting Conditions for Operation to Meet the Criterion 'As Low as is Reasonably

Achievable' for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents," to

10 CFR Part 50 and 10 CFR 50.36a, "Technical Specifications on Effluents from Nuclear Power

Reactors," respectively.

2.1.2.1 Radioactive Liquid Waste

The TMI-1 radioactive liquid waste disposal system collects, holds, treats, processes, and

monitors all liquid radioactive wastes for reuse or disposal. The system is divided into several

subsystems so liquid wastes from various sources can be segregated and processed

separately. Cross-connections between the subsystems provide additional flexibility for

processing the wastes by alternate methods. The wastes are collected, treated, and disposed of

according to their conductivity and/or radioactivity (AmerGen 2006a).

Radioactive liquid waste from TMI-1 is collected in sumps and drainage tanks and transferred to

the appropriate subsystem collection tanks for subsequent treatment, disposal, or recycle. The

liquid wastes are processed by a series of components which employ various processes

specifically designed to provide maximum decontamination factors. The processing methods

used include filtration, reverse osmosis, and/or demineralization. Following treatment, the

processed wastes in the waste evaporator condensate tank, waste monitor tanks, or secondary

liquid waste monitor tanks are analyzed for chemical and radioactive content before being

discharged. In addition, the system can handle effluent streams that typically do not contain

radioactive material, but that may, on occasion, become radioactive. Liquid radioactive wastes

released to the west channel of the Susquehanna River are limited to the maximum extent

possible to satisfy the design objectives of Appendix I to 10 CFR Part 50. Liquid discharges

occur when the radioactive material has been analyzed and the projected dose to members of

the public has been calculated to be within the values specified in the ODCM, 10 CFR Part 20,

and Appendix I to 10 CFR Part 50 (AmerGen 2006a).

The NRC staff reviewed the TMI-1 radioactive effluent release reports for 2003 through 2007 for

liquid effluents (AmerGen 2004b, 2005b, 2006b, 2007a, 2008b). Based on the liquid waste

processing systems and effluent controls and performance from 2003 through 2007, the liquid

discharges for 2007 are consistent with the radioactive liquid effluents discharged from 2003

through 2006. Variations on the amount of radioactive effluents released from year to year are

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

and maintenance activities. The liquid radioactive wastes reported by TMI-1 are reasonable and

no unusual trends were noted.

NUREG-1437, Supplement 37 2-6 June 2009
Affected Environment

Exelon Generation intends to replace the TMI-1 steam generators before the period of extended

operation. Such an action is not likely to significantly increase the amount of liquid radioactive

effluents above the amount discharged during normal plant operations. This is because any

liquids generated, processed, and released during the outage will be offset by the amount of

liquid waste that would not be generated, processed, and released during normal plant

operations. Based on the historical evaluation and because a significant increase in liquid

effluents from the potential repair or replacement of the TMI-1 steam generators is not

expected, similar quantities of radioactive effluents are expected to be generated during normal

operations and outages from TMI-1 during the period of extended operations. The liquid

releases during refurbishment will still be controlled and limited to satisfy the dose objectives of

Appendix I to 10 CFR Part 50. These releases would result in doses to members of the public

that are well below the as low as reasonably achievable (ALARA) dose design objectives, as

discussed in Section 4.8.1 of this report.

2.1.2.2 Radioactive Gaseous Waste

The TMI-1 radioactive gas waste disposal system processes and disposes of routine radioactive

gaseous effluent to the atmosphere. The system comprises reactor coolant drain tanks,

miscellaneous waste storage tanks, waste gas, decay tanks, waste gas compressors, and

charcoal and high efficiency particulate filters, to accumulate, store, and process the waste

fission product gases. Before gaseous radioactive waste is released to the atmosphere through

the plant vents, the gas must be analyzed to determine and document the amount of

radioactivity being released (AmerGen 2006a).

TMI-1 discharges gaseous'waste in accordance with the procedures and methodology

described in the ODCM. The gaseous radioactive waste system is used to reduce radioactive

materials in gaseous effluents before discharge to meet the dose limits in 10 CFR Part 20 and

the ALARA dose design objectives in Appendix I to 10 CFR Part 50.

The NRC staff reviewed the TMI-1 radioactive effluent release reports for 2003 through 2007 for

gaseous effluents (AmerGen 2004b, 2005b, 2006b, 2007a, 2008b). Based on the gaseous

waste processing systems and effluent controls and performance from 2003 through 2007, the

gaseous discharges for 2007 are consistent with the radioactive gaseous effluents discharged

from 2003 through 2006. Variations on the amount of radioactive effluents released from year to

year are expected based on the overall performance of the plant and the number and scope of

outages and maintenance activities. The radioactive gaseous wastes reported by TMI-1 are

reasonable and no unusual trends were noted.

Exelon Generation intends to replace the TMI-1 steam generators before the period of extended

operation. This action is not likely to result in a significant increase in the amount of radioactive

gaseous waste discharged over the amount discharged during normal plant operations,

because any radioactive gaseous waste generated, processed, and released during the outage

will be offset by the amount of radioactive gaseous waste that would not be generated,

processed, and released during normal plant operations. Based on the historical evaluation and

because no significant increase in radioactive gaseous effluents from the potential repair or

replacement of the TMI-1 steam generators is anticipated, similar quantities of radioactive

gaseous effluents are expected to be generated during normal operations and outages from

TMI-1 during the period of extended operations. The radioactive gaseous waste releases to the

environment during the refurbishment will still be controlled and limited to satisfy the dose

June 2009 2-7 NUREG-1437, Supplement 37
Affected Environment

objectives of Appendix I to10 CFR Part 50. These releases would result in doses to members of

the public that are well below the ALARA dose design objectives, as discussed in Section 4.8.1.

2.1.2.3 Solid Radioactive Waste

The TMI-1 radioactive solid waste disposal system is designed to safely collect, process, store,

and prepare wet and dry solid radioactive waste materials for onsite storage and offsite

shipment. The system consists of a wet process stream used to collect, process, dewater, and

solidify wet solid wastes, and a dry process stream used to collect and package dry solid

wastes. Wet solid wastes include spent resins, filter cartridges, and filter crud. Dry solid wastes

include contaminated rags, clothing, paper, outage equipment, and other radioactively

contaminated equipment (AmerGen 2006a). Transportation of the radioactive solid waste is

conducted in accordance with NRC and U.S Department of Transportation (DOT) regulations as

specified in 10 CFR Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste,"

and 10 CFR Part 71, "Packaging and Transportation of Radioactive Material."

The NRC staff reviewed the TMI-1 solid radioactive waste reports for 2003 through 2007

(AmerGen 2004b, 2005b, 2006b, 2007a, 2008b). The solid waste volumes and radioactivity

amounts generated in 2007 are typical of previous annual waste shipments made by TMI-1.

Variations in the amount of solid radioactive waste generated and shipped from year to year are

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

maintenance work outages. The volume and activity of solid radioactive wastes reported by

TMI-1 are reasonable and no unusual trends were noted.

Exelon Generation intends to replace the TMI-1 steam generators before the period of extended

operation. Such an action is likely to result in a small increase in the amount of solid radioactive

waste generated. This is based on an increase in the number of personnel working at the plant

which will result in the generation of more solid waste during the outage and any other

associated related work. An outage of this type will also result in an increased use of protective

clothing, safety equipment, and filters, as well as a general increase in the generation of debris

that will have to be disposed of as radioactive waste. The increased volume is expected to be

within the range of solid waste that can be safely handled by TMI-1 during the period of

extended operations. The transportation of the radioactive solid wastes related to the

refurbishment activities will be conducted in accordance with NRC and DOT regulations as

specified in 10 CFR Part 61 and 10 CFR Part 71.

Low-level mixed waste (LLMW) is waste that exhibits hazardous characteristics and contains

low levels of radioactivity. LLMW has been regulated under multiple authorities. The U.S.

Environmental Protection Agency (EPA) or State agencies regulate the hazardous component

of LLMW through the Resource Conservation and Recovery Act (RCRA), and either the U.S.

Department of Energy (DOE) or the NRC regulates the radioactive component. TMI-1 has not

had any LLMW stored on site for the past 5 years and does not expect to have to store any in

the foreseeable future.

The State of South Carolina's licensed low-level radioactive waste disposal facility, located in

Barnwell, has limited the access from radioactive waste generators located in States that are

not part of the Atlantic Low-Level Waste Compact. Pennsylvania is not a member of the Atlantic

Low-Level Waste Compact. This has impacted the ability of TMI-1 to dispose of its low-level

solid radioactive waste and necessitated the need for TMI-1 to store its low-level solid

radioactive waste on site. TMI-1 has decided to store its low-level solid radioactive waste in the

NUREG-1437, Supplement 37 2-8 June 2009
Affected Environment

solid waste staging facility (SWSF). The NRC staff has reviewed the TMI-1 SWFS plant

procedure and has found that the SWSF performs no active function and was used for

temporary staging of low-level radioactive waste before preparation for shipment and disposal.

Because the SWSF is located outside and is exposed to the weather, the concrete structure and

individual cells utilize gaskets, slots and weep holes, a drainage piping system, and a common

sump, with its associated equipment and instrumentations, to protect the waste containers and

to control the disposal of any effluent that may collect in the sump. TMI-1 has a monitoring,

inspection, and testing program, which includes periodic evaluation of the operability and

functional performance of active components of the SWSF system. The SWSF was designed to

provide a controlled but ready access for material handling operations, to ensure that worker

radiation exposures are controlled in accordance with the ALARA criteria, and to ensure that the

offsite dose does not exceed any of the Federal limits specified in 10 CFR Part 20, as well as

the EPA radiation standards in 40 CFR Part 190, "Environmental Radiation Protection

Standards for Nuclear Power Operations."

2.1.3 Nonradiological Wastes

RCRA governs the disposal of solid and hazardous waste. RCRA regulations are contained in

Title 40, "Protection of the Environment," Parts 239 through 299 (40 CFR 239, et seq.), of the

Code of Federal Regulations. Parts 239 through 259 of Title 40 contain regulations for solid

(nonhazardous) waste, and Parts 260 through 279 contain regulations for hazardous waste.

RCRA Subtitle C establishes a system for controlling hazardous waste from "cradle to grave,"

and RCRA Subtitle D encourages States to develop comprehensive plans to manage

nonhazardous solid waste and mandates minimum technological standards for municipal solid

waste landfills (EPA 2007). Pennsylvania State RCRA regulations are administered by the

Division of Hazardous Waste Management of the Pennsylvania Department of Environmental

Protection (PADEP) and address the identification, generation, minimization, transportation, and

final treatment, storage, or disposal of hazardous and nonhazardous wastes. TMI-1 generates

nonradiological waste including oils, hazardous and nonhazardous solvents and degreasers,

laboratory wastes, expired shelf-life chemicals and reagents, asbestos wastes, paints and paint

thinners, antifreeze, nonroutine (i.e., project-specific) wastes, point-source discharges regulated

under the National Pollutant Discharge Elimination System (NPDES), sanitary waste (including

sewage), and routine, daily refuse (AmerGen 2008).

2.1.3.1 Hazardous Waste

Hazardous waste means solid waste, or a combination of solid wastes, which, because of its

quantity, concentration, or physical, chemical, or infectious characteristics, may cause or

contribute to an increase in mortality or serious illness. Such waste may also pose a significant

present or potential hazard to human health or the environment if it is not properly treated,

stored, transported, disposed of, or otherwise handled (40 CFR Part 261, "Identification and

Listing of Hazardous Waste"). TMI-1 generates a variety of hazardous waste including spent

and off-specification chemicals, laboratory chemical wastes, hazardous solvents and

degreasers, and occasional project-specific wastes. TMI-1 is classified as a "small quantity

generator" of hazardous waste because the plant generates less than 1000 kilograms of

hazardous waste in 1 month, and no more than 6000 kilograms of hazardous waste may be

accumulated on site at any one time (EPA 2007a).

June 2009 2-9 NUREG-1437, Supplement 37
Affected Environment

According to the EPA Envirofacts Warehouse, TMI-1 is classified as an active small quantity

generator of hazardous wastes (EPA ID No. PAR000037861). The Envirofacts Warehouse

database showed no violations for TMI-1 (EPA 2008a). During the site audit, the NRC viewed

I the TMI-1 waste accumulation building, which is a central facility designed for the safe and

proper collection, sorting, packaging, and shipment of hazardous wastes. Also during the site

I audit, NRC staff reviewed Exelon Generation's hazardous waste procedures and determined

they complied with applicable RCRA regulations.

2.1.3.2 Residual Waste

TMI-1 generates solid waste, as defined by RCRA, as part of routine plant maintenance,

cleaning activities, and plant operations. In Pennsylvania, solid waste is further classified as

either municipal waste or residual waste by PA Code Article VIII and Article IX, respectively,

based on its origin. TMI-1 nonhazardous solid waste is classified as residual waste. In

Pennsylvania, residual waste is defined as nonhazardous industrial waste, including solid,

liquid, or gaseous waste material produced by industrial, mining, or agricultural operations (PA

Code Article IX). In addition to plant garbage, residual wastes generated at TMI-1 include

nonhazardous waste oil and oily debris resulting from maintenance of oil-filled equipment;

nonhazardous sludge from the industrial water supply treatment facility, waste water facility, or

air pollution control facility; nonhazardous solvents and degreasers; asbestos; antifreeze; and

occasional project-specific nonhazardous wastes. In 2007 TMI-1 generated approximately 26

tons (t) (24 MT) of residual waste, not including approximately 198 t (179 MT) of garbage, of

which approximately 188 t (170 MT) was incinerated at a resource recovery facility (AmerGen

2008d).

2.1.3.3 Universal Waste

Universal waste is hazardous waste that is generated in a variety of settings and by a vast

community and poses collection and management problems and often is not appropriately

managed under existing hazardous waste regulations. EPA classifies several hazardous wastes

as universal wastes including batteries, certain pesticides, mercury-containing devices, and

fluorescent lamps (40 CFR Part 273, "Standards for Universal Waste Management").

Pennsylvania has incorporated by reference the EPA regulations regarding universal wastes.

TMI-1 is a small quantity handler of universal waste (meaning the facility cannot accumulate

more than 5000 kilograms (approximately 11,000 pounds) of universal waste at any one time),

generating common operational wastes such as lighting ballasts containing polychlorinated

biphenyls (PCBs), lamps, and batteries. In 2007 TMI-1 generated approximately 7,271 pounds

(3,298 kilograms) of universal wastes (AmerGen 2008d).

2.1.3.4 Mixed Waste

As previously discussed in Section 2.1.2.3, LLMW contains both low-level radioactive waste and

RCRA hazardous waste (40 CFR Part 266, "Storage, Treatment, Transportation, and Disposal

of Mixed-Waste"). Pennsylvania has incorporated by reference Federal regulations exempting

LLMW from RCRA storage and treatment regulations, provided the waste meets specific

conditions (PADEP 2001). TMI-1 has not generated any mixed waste in the past five years

(AmerGen 2008d).

NUREG-1437, Supplement 37 2-10 June.2009
Affected Environment

2.1.3..5 Permitted Discharges

TMI-1 generates two types of wastewater-industrial effluents and sanitary liquid wastes, both

of which are discharged to the Susquehanna River according to the TMI-1 Individual

Wastewater Discharge NPDES Permit No. PA0009920, enforced by PADEP (radioactive liquid

waste is addressed in Section 2.1.2.1 of this report). Normal operating processes are used to

control the pH of the reactor coolant prevent scale and corrosion in the cooling system and

clean and defoul the condenser of biological organisms that generate chemical and biocide

wastes. Waste liquids containing chemicals from these processes are combined with cooling

tower blowdown and are discharged to the Susquehanna River according to the limitations

contained in the TMI-1 NPDES permit. The industrial waste treatment system provides

treatment of secondary plant sumps and drains to meet NPDES permit effluent limitations.

Treatment includes settling and filtration to remove solids, an air flotation unit to remove oil and

grease, and pH adjustment. TMI-1 has an onsite sewage treatment plant to treat sanitary

wastewater generated by the plant. The sewage treatment plantaverages approximately

11,000-12,000 gallons (41,640-45,420 liters [L]) of effluent per day; approximately 7,000

gallons (26,500 L) are treated effluent and approximately 4,000 gallons (15,140 L) are filtered

water used to deliver chlorine gas to the effluent for disinfection. Digested sanitary sludge from

the sewage treatment plant is analyzed for radionuclides and transferred to a PADEP-approved

agriculture utilization facility for disposal (AmerGen 2008d). Section 2.1.7.3 of this report

provides more information on TMI-1 NPDES permit and effluent limitations.

2.1.3.6 Pollution Prevention and Waste Minimization

Currently, TMI-1 implements a waste minimization program which consists of steps such as

segregating hazardous and nonhazardous wastes, choosing nonhazardous substitutes when

possible, recycling or reclaiming appropriate waste materials, monitoring expired chemicals to

determine minimum stocking requirements to reduce recurring excess, finding alternate uses for

excess materials, or returning unused materials to the manufacturer. During the summer of

2008, TMI-1 implemented a recycling program for common waste materials such as paper,

plastic, and aluminum.

In support of nonradiological waste minimization efforts, the EPA Office of Pollution Prevention

and Toxics established a clearinghouse that provides information regarding waste management

and technical and operational approaches to pollution prevention. The EPA clearinghouse can

be used as a source for additional opportunities for waste minimization and pollution prevention

at TMI-1, as appropriate (EPA 2008b).

EPA also encourages the use of environmental management systems (EMSs) for organizations

to assess and manage the environmental impact associated with their activities, products, and

services in an efficient and cost-effective manner. EPA defines an EMS as "a set of processes

and practices that enable an organization to reduce its environmental impacts and increase its

operating efficiency." EMSs help organizations fully integrate a wide range of environmental

initiatives, establish environmental goals, and create a continuous monitoring process to help

meet those goals. The EPA Office of Solid Waste especially advocates the use of EMSs at

RCRA-regulated facilities to improve environmental performance, compliance, and pollution

prevention (EPA 2008a). Introductory Web-based EMS training is available at the EPA Web

June 2009 2-11 NUREG-1 437, Supplement 37
Affected Environment

site. 2 Exelon Generation has implemented an EMS at TMI-1, and TMI-1 is an ISO 14001-

certified plant, which requires a commitment to continuous improvement, emergency response

planning, and independent monitoring of all environmental impact areas including energy and

water consumption, sewage discharge, airborne emissions, hazardous material and noise

levels.

2.1.4 Plant Operation and Maintenance

Maintenance activities conducted at TMI-1 include inspection, testing, and surveillance to

maintain the current licensing basis of the facility and to ensure compliance with safety and

environmental requirements. Various programs and activities currently exist at TMI-1 to

maintain, inspect, test, and monitor the performance of facility equipment. These maintenance

activities include inspection requirements for reactor-vessel materials, boiler and pressure

vessel in-service inspection and testing, a maintenance structures monitoring program, and

maintenance of water chemistry (AmerGen 2008c).

Additional programs include those implemented to meet technical specification surveillance

requirements, those implemented in response to NRC generic communications, and various

periodic maintenance, testing, and inspection procedures. Certain program activities are

performed during the operation of the unit, while others are performed during scheduled

refueling outages. Nuclear power plants must periodically discontinue the production of

electricity for refueling, periodic in-service inspection, and scheduled maintenance. TMI-1

refuels on a 24-month interval (AmerGen 2008c).

2.1.5 Power Transmission System

TMI-1 is connected to the regional grid via four, 230-kilovolt (kV) transmission lines, which total

5.6 mi (9.0 km) in length. These transmission lines are owned by Exelon Generation, who

purchased TMI-1 from FirstEnergy in 1999; however, FirstEnergy continues to operate and

maintain the transmission lines and their right-of-ways (ROWs) (AmerGen 2008). Transmission

lines considered in scope for license renewal are those constructed to connect the facility to the

transmission system (10 CFR 51.53(c)(3)(ii)(H)); therefore, the four lines, Line No. 1091, Line

No. 1092, Line No. 1051, and the TMI-1 to TMI-1 500-kV substation line, are considered in

scope and are discussed below in detail.

All four transmission lines originate at the TMI-1 switchyard and are shown in Figure 2-4 on the

following page. Line No. 1091 and Line No. 1092 extend 1.5 mi (2.4 km) northeast to the

Middletown Junction Substation near Middletown, Pennsylvania. These lines share a 150-footwide (46-meter [m]) ROW. Line No. 1051 travels south for 4.1 mi (6.6 km) from the TMI-1

switchyard to the Jackson Substation, which is located near Jackson, Pennsylvania. The fourth

line, unnumbered, travels from the TMI-1 switchyard 0.7 mi (1.1 km) to the TMI 500-kV

substation. Line No. 1051 and the unnumbered line share a 150-foot-wide (46 m) ROW

(AmerGen 2008).

2 Web-based EMS training available URL: http://www.epa.qov/epaoswer/ems/ems-101/emsl01 .htm

NUREG-1437, Supplement 37 2-12 June 2009
Affected Environment

'I

Figure 2-4. Three Mile Island Nuclear Station,

Unit 1, Transmission System

(Source: AmerGen 2008)

June 2009 2-13 NUREG-1 437, Supplement 37
Affected Environment

In total, FirstEnergy operates and maintains 5.6 mi (9.0 km) of transmission lines and maintains

142 acres (ac) (57 hectares [ha]) of transmission line ROWs (AmerGen 2008). The four lines

cross the Susquehanna River in three locations, as shown in Figure 2-4. The lines do not cross

any Federal, State, or local parks. FirstEnergy has vegetative maintenance procedures in place

to prevent vegetation from interfering with the lines (FirstEnergy 2007). ROW vegetative

maintenance practices use an integrated vegetation management approach that includes both

mechanical and chemical control methods. Mechanical methods consist primarily of mowing,

with supplementary pruning, felling, and hand trimming as needed. Chemical control methods

consist of application of EPA-approved herbicides and tree-growth-regulating chemicals

(FirstEnergy 2008). Procedures are in place to manage environmental incidents that might

occur within the ROW, such as a chemical buildup in a wetland area. Exelon Generation, in

conjunction with FirstEnergy staff, limits erosion around stream crossings and wetlands by using

appropriate procedures and methods. ROWs that cross farmland or pastures are not maintained

by FirstEnergy, as the land is cultivated by the local farmers. FirstEnergy will maintain the

existing ROWs regardless of whether TMI-1 is granted a renewed operating license (AmerGen

2008).

2.1.6 Cooling and Auxiliary Water Systems

The TMI-1 circulating water system withdraws cooling water from, and discharges cooling tower

blowdown to, the Susquehanna River. TMI-1 uses two hyperbolic natural draft cooling towers to

dissipate heat from the plant's steam cycle to the atmosphere. Other systems that dissipate

heat from the plant include the secondary services cooling system, the nuclear services cooling

system, and the decay-heat cooling system (AEC 1972).

Water that is lost through cooling tower evaporation, wind, and as blowdown returned to-the

Susquehanna River is termed "makeup" water. Makeup water is obtained from the secondary

services river water pumping system. The river intake structure is located on the shoreline of the

Susquehanna River and is designed to pump under three river conditions-minimum river level

of 271 ft (83 m) ("loss of the York Haven Dam"), normal river elevation of 278 ft (85 m), and

flood levels. A deicing line operates during periods of subfreezing temperatures to prevent ice

from forming and possibly blocking the intake structure. Under normal operation in subfreezing

weather, condenser circulating water is the source of deicing water (AEC 1972).

River water enters the intake structure at a velocity of approximately 0.2 feet per second (ft/s)

(0.06 m per second [m/s]), passes under a skimmer wall, travels through automated trash racks

with 1-inch vertical bar spacing, through 3/8-inch mesh traveling screens, through the river

water pumps,'and lastly through 1/8-inch mesh strainers before entering the heat exchangers.

Once in the heat exchangers, river water mixes with the circulating water in the circulating

pumps. The circulating water pump building contains six circulating water pumps-three pumps

feed each of the two, 102-inch-diameter mains (AEC 1972). The circulating water system

contains a chemical injection system for controlling bacterial and algae growth and metal

corrosion (AmerGen 2008). The chemical injection to the circulating water comprises sodium

hypochlorite, sulfuric acid, sodium bromide, scale inhibitor, dispersants, and other associated

chemicals (AmerGen 2008c).

Under normal operation, maximum withdrawal of makeup water from the Susquehanna River for

cooling tower losses is approximately 15,250 gallons per minute (gpm) (34 cubic ft per second

NUREG-1437, Supplement 37 2-14 June 2009
Affected Environment

[cfs], or 1 cubic meter per second [m3/s]). Water is pumped to a high point on the site, and

cooling tower blowdown is drained by gravity and discharged back to the Susquehanna River

through a 48-inch-diameter river discharge line, which is located behind the natural shoreline

downstream of the river intake structure. Cooling tower blowdown ranges from 3000 gpm (6.7

cfs, or 0.19 m3/s) during normal operation to 6000 gpm (13.4 cfs, or 0.38 m3/s) during maximum

operation. Under normal conditions the discharge velocity is 2.7 ft/s (0.8 m/s) with a maximum

value of 5.2 ft/s (1.6 m/s) (AEC 1972). The PADEP regulates plant discharges under NPDES

Individual Wastewater Discharge Permit No. PA 0009920 (AmerGen 2008). Section 2.1.7.3 of

this report discusses the discharges permitted from TMI-1.

The TMI-1 intake structure does not have a fish return system, therefore fish and other aquatic

organisms that may become entrained in the TMI-1 intake structure and impinge on the trash

racks, traveling screen, or mesh strainers are not returned to the river. However, the TMI-1

circulating water system is equipped with cooling towers, which is considered the best

technology available for minimizing impingement and entrainment impacts to aquatic species.

Also, as stated above, the flow velocity at the intake structure under normal operating conditions

is approximately 0.2 ft/s (AmerGen 2008).

2.1.7 Facility Water Use and Quality

The TMI-1 circulating water system and the service water system both draw water from, and

discharge to, the Susquehanna River. Onsite ground water wells also supply water for cooling

water makeup, domestic water consumption, and other industrial uses. The following sections

detail water use at TMI-1.

2.1.7.1 Ground Water Use

A portion of the water utilized by TMI-1 for its operation is ground water. Specifically, ground

water is used for station fire service, makeup water to the demineralized water system, bearing

lubrication for the screen house intake pumps, service water for onsite buildings and equipment,

and drinking water. Onsite ground water is drawn from three service wells (installed in 1996)

and two drinking water wells (one of which can also be used, when needed, to supply additional

water to the service system). Two additional wells are located offsite and supply potable water

too the Visitors Center and the Training Center/Simulator Building. Drinking water is treated on

site using a zinc orthophosphate solution, and a sodium hypochlorite solution, as permitted by

PADEP. The site also operates a sanitary wastewater treatment facility, with a capacity of up to

80,000 gallons per day (gpd) (302,833 liters per day [Lpd]) though the typical flow ranges from

10,000 gpd to 15,000 gpd (37,854 Lpd to 56,781 Lpd), with a maximum flow of 40,000 gpd

(151,416 Lpd) during outages (AmerGen 2008).

2.1.7.2 Surface Water Use

Susquehanna River water is withdrawn for use in the circulating cooling water system through

the intake structure located on the island's western bank. Under typical conditions the flow

velocity at the intake structure is around 0.2 ft/s (0.06 m/sec), with a normal river elevation of

277 feet (84.4 m). Approximately 12,250 gpm (27.3 cfs, or 0.8 m3/s) is withdrawn from the river

under these conditions, and the maximum withdrawal of makeup water is approximately 15,250

gpm (34 cfs, or 1.0 m3/s) (AmerGen 2008). The intake structure is designed to pump river water

June.2009 2-15 NUREG-1437, Supplement 37
Affected Environment

into the system during normal conditions and during extreme conditions such as the loss of the

York Haven Dam and major flood levels (AmerGen 2008).

Cooling tower blowdown typically ranges from 3000 gpm to 6,000 gpm (6.68 to 13.4 cfs, or 0.2

to 0.4 m3/s) at its maximum. Water not lost by evaporation or drift from the cooling towers is

discharged at a rate ranging from 2.7 ft/s to 5.2 ft/s (0.82 m/s to 1.58 m/s) at its maximum, in a

manner complying with the plant's NPDES Individual Wastewater Discharge Permit No. PA

0009920 issued by PADEP in October 2007 (AEC 1972; AmerGen 2008).

The primary sources of river water consumption are evaporation and drift losses. TMI-1 has an

SRBC (Susquehanna River Basin Commission) permit allowing for the consumptive use of river

water of up to 18 million gpd (mgd) (68 million Lpd) (SRBC 1995). To abide by this permit, TMI1 takes part in the Cowanesque Reservoir Water Allocation Project. This project keeps TMI-1

from having to shut down in the event of a severe drought in the Susquehanna River by allowing

for water stored in the reservoir to be discharged downstream during such an emergency.

2.1.7.3 Surface Water Quality

Between the years 1974 and 1982, Metropolitan Edison and GPU Nuclear performed various

studies on the water quality around Three Mile Island to evaluate the impacts of the plant on

local water quality (Ichthyological Associates 1983). These studies utilized data on water

chemistry, macroinvertebrates, larval and adult fishes, and thermal plume mapping. The last

year with available data for both operating units is 1978 because of the accident at TMI Unit 2 in

March 1979. During this period of combined operation of the two units, none of the water quality

criteria violated the State requirements. The studies examined water quality parameters

including turbidity, alkalinity, sulfate, total dissolved solids, total and dissolved copper, and total

and dissolved zinc. The data were gathered near both the upstream and downstream discharge

structures. Additional measurements of water temperature, pH, and dissolved oxygen were

taken at various sampling locations (Ichthyological Associates 1983).

The studies concluded that mean levels for dissolved oxygen, turbidity, total copper, and total

zinc peaked in April, whereas water temperature, alkalinity, sulfate, and total dissolved solids

peaked in July. Dissolved zinc was highest in November. The data also showed that levels of

alkalinity, sulfate, dissolved copper, and total zinc were generally higher values upstream,

whereas levels of water temperature, dissolved oxygen, turbidity, total dissolved solids, and

dissolved zinc were higher downstream (Ichthyological Associates 1979; 1983).

The Susquehanna River was tested for water temperature and showed a typical pattern of low

temperatures in the winter, with highs in the late summer months. Water temperature data

obtained immediately below the discharge indicated that the thermal effluent did not heat the

surrounding water enough to exceed the temperatures mandated by the State. It also showed

that the upstream and downstream temperatures did not differ by over 5 degrees Fahrenheit

(OF) (Ichthyological Associates 1979; 1983). Water temperature data collected between March

1979 and 1982 represent ambient conditions because, following the TMI.Unit 2 accident, both

units were shut down, with TMI-1 not resuming operation until 1985.

In more recent years, Exelon Generation has collected water temperature data using an

automatic temperature sensor located at the intake screen pump house and the discharge

monitoring pit, which is before the discharge water is mixed with the river water. Figure 2-5 on

the following page represents the recorded daily average discharge and intake temperatures

NUREG-1437, Supplement 37 2-16 June 2009
nt

120

100

0I

1)

0.

E

0)

80

60

40

20-

O01 -Aug-05 07-Nov-05 13-Feb-06 22-May-06 28-Aug-06 04-Dec-06 12-Mar-07 18-Jun-07 24-Sep-07

Date

LEGEND

Daily Average Inlet

Daily Average Discharge :Penny

Figure 2-5. Three Mile Island Nuclear Station, Unit 1,

Inlet and Discharge Temperatures

(Source: AmerGen 2007c)

June 2009 2-17 NUREG-1437, Supplement 37
Affected Environment

between August 2005 and September 2007, with the 2006 maximum discharge recorded as

110.2°F (43.4 degrees Celsius [0C]) and the 2007 maximum as 101.1 0 F (38.4 °C) (recorded in

August and September, respectively). Table 2-1 represents the calculated differences between

discharge and intake temperature (AT) on a month-to-month basis recorded during the same

time period. The maximum temperature difference recorded is 30.16 °F in April 2006 (AmerGen

2007c).

Table 2-1. Monthly Average, Minimum, and

Maximum AT (°F) Based on Automatic

Temperature Sensors at the Intake

Screen Pump House

Year Month Average AT Minimum AT Maximum AT

2005 August 11.66 7.50 13.80

September 11.04 2.76 16.46

October 11.16 1.61 16.58

November 5.98 0.78 14.67

December 11.13 4.74 14.02

2006 January 9.47 6.30 10.77

February 9.43 6.35 11.67

March 12.23 5.32 17.04

April 15.86 11.26 30.16

May 16.10 7.13 20.61

June 17.80 8.96 22.68

July 16.59 9.72 21.17

August 16.86 11.99 21.88

September 18.84 10.26 21.56

October 17.10 10.18 21.27

November 16.04 4.83 22.41

December 17.17 5.42 21.71

2007 January 16.88 11.35 20.22

February 17.32 11.01 19.36

March 17.35 9.64 24.37

April 20.55 10.99 28.96

May 21.01 15.97 27.08

June 14.87 8.67 19.17

July 15.01 11.62 18.04

August 13.95 10.08 16.53

September 15.56 8.74 20.95

Source: AmerGen 2007c

Historically, monitoring in the Susquehanna River has shown river flow to be a very influential

parameter in determining water quality. Over the past few decades of recorded data, mean river

flow fluctuated based on snow melt, spring runoff, rain, and periods of drought. A parameter

analysis conducted using 17 years of water temperature, pH, and dissolved oxygen data, and

13 years of total dissolved solids data found that trends appear to relate more to meteorological

June 2009 2-18 NUREG-1437, Supplement 37
Affected Environment

cycles, river flows, and land and water uses than to operations at the TMI-1 site. In addition, the

data showed no significant impact of TMI-1 discharge on water quality (Normandeau 2007).

The water quality of the Lower Susquehanna River Basin has considerably improved since the

1970s. Water quality issues in this area were historically dominated by acid mine drainage

discharges upstream, which have been considerably reduced, as well as sewage-treatment

plant improvements, a ban on phosphate detergents, and improvement of agricultural practices.

The concentration of nitrate, however, has been shown to be increasing. A 2002 water quality

study conducted by the SRBC collected data from 25 stations along the river, as well as at the

mouths of its three major tributaries. Six of these stations were determined to be moderately

impaired, and 19 were designated as slightly impaired. Out of the 950 tested water quality data

points, 79 were found to exceed the tolerance levels for aquatic life. According to the SRBC

report, this is an indication of fairly good water quality (SRBC 2006).

In accordance with the Federal Water Pollution Control Act (or the Clean Water Act (CWA)),

TMI-1 effluent discharges are regulated by NPDES Individual Wastewater Discharge Permit No.

PA 0009920 issued and enforced by PADEP. Section 402 of the CWA states that "NPDES

prohibits [discharges] of pollutants from any point source into the nation's waters except as

allowed under an NPDES permit." The purpose of this permit is to regulate wastewater

discharge to preserve the water quality of the surrounding water bodies. As of the most recent

permit issued, there have been no notices of violation for the TMI-1 site. Information in this

section was obtained from the TMI-1 NDPES. The applicant's license renewal environmental

report includes a copy of the most recent TMI-1 NPDES permit (AmerGen 2008).

The most recent renewal of this permit occurred in October 2007. Table 2-2 on the following

page shows the quantitative effluent limitations regulated under the NPDES permit. In addition

to these effluent limitations, the permit also stipulates that during any 1-hour period, discharge

may not affect the temperature of the receiving water body by more than 2 OF. No violations of

this limit have been recorded.

The permit outlines the effluent limitations and monitoring requirements of 10 different discharge

outfalls. In addition to the effluent limitations shown in Table 2-2, the permit also outlines the

minimum number of sampling events that are required for each outfall, where necessary.

Additionally, the discharge of "floating solids, visible foam, or other substances that produce

color, tastes, odors, turbidity or settle to form deposits" are to be controlled, and pH is to be

monitored, with the required levels being between 6.0 and 9.0.

Outfall 001 (the main station outfall) receives wastewater from the circulating cooling water,

secondary service water, reactor building emergency cooling, decay heat, nuclear service

water, liquid radioactive waste treatment, station blackout diesel cooling water, and several

other minor sources. Its discharge limitations were calculated based on a maximum discharge

rate of 81.02 mgd (306.7 million Lpd). Outfall 003 is an emergency outfall, meant to receive

discharge from TMI-1 in the event that Outfall 001 is blocked. Outfall 004 is another emergency

outfall which receives discharge from TMI-1 in the event that the TMI-1 mechanical draft cooling

tower basin is blocked. Both of these emergency outfalls are based on the same rate of 81.02

mgd (306.7 million Lpd) as Outfall 001. If either of these outfalls is used, the facility is required

to notify PADEP within 2 days to explain the composition of the discharge and the reason for its

use.

June 2009 2-19 NUREG-1437, Supplement 37
Affected Environment

z

C

m

C:

CD

C--

C:

(D

(D

Table 2-2. National Pollutant Discharge Elimination System Effluent Limitations for TMI-1

Total Suspended Oil and CBOD-5 Free Available Phosphorus Total Residual Spectrus Hydrazine Temperature

Solids Grease Day Chlorine Oxidants

Ouffall (mg/L) (mg/L) (mglL) (mg/L) (mglL) (mglL) (mg/L) (mg/L) (9F)

No. Avg. Max. Inst. Avg. Max. Inst. Avg. Inst. Max. Inst. Avg. Inst. Max. Inst. Max. Inst. Instant 10/1- 4/1-

Month Daily Max. Month Daily Max. Month Max. Daily Max. Month Max. Daily Max. Daily Max. Max. 3131 9/30

001 NLR NLR NLR NLR NLR NLR NLR NLR 0.2 0.5 NLR NLR 0.14 0.17 0.1 0.3 Not 110 115

Detectable

003 NLR NLR NLR NLR NLR NLR NLR NLR 0.2 0.5 NLR NLR 0.14 0.17 0.1 0.3 Not 110 115

Detectable

004 NLR NLR NLR NLR NLR NLR NLR NLR 0.2 0.5 NLR NLR 0.14 0.17 0.1 0.3 Not NLR NLR

Detectable

005A NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR

005B 30 100 NLR 15 20 30 NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR

006 NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR

101 30 NLR 60 NLR NLR NLR 25 50 NLR NLR 2.0 4 NLR NLR NLR NLR NLR NLR NLR

401 30 100 NLR 15 20 30 NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR

501 30 100 NLR 15 20 30 NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR

701 30 100 NLR 15 20 30 NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR NLR

Source: NPDES No. PA 0009920

NLR = No Longer Regulated
Affected Environment

Outfall 101 receives wastewater from the sewage treatment plant, and its limitations are based

on a discharge rate of 0.08 mgd (302,833 Lpd). In addition to the effluent limitations shown, the

permit requires this outfall to be monitored for fecal coliform levels, which are restricted to an

average monthly concentration of 200 per 100 milliliters from May to September, and 2000 per

100 milliliters from October to April. Outfall 401 receives wastewater from the industrial waste

filter system, and its limitations are based on a discharge rate of 0.3 mgd (1.1 million Lpd).

Outfall 501 receives wastewater from the TMI-1 secondary neutralizer tank, and its limitations

are based on a discharge rate of 0.3 mgd (1.1 million Lpd). Outfall 701 receives wastewater

from the industrial waste treatment system, and its limitations are based on a discharge rate of

0.3 mgd (1.1 million Lpd).

Outfall 005B receives wastewater from screen house desilting, dewatering of the TMI-1 natural

draft cooling towers, fire brigade training, the fuel oil offloading station, industrial cooler

maintenance, emergency diesel generator building.floor drains, and operation of the east dike

settling basin drain valve. The discharge rates upon which these limitations are based are not

specified by the permit. Outfall 006 receives wastewater from intake screen wash and sluice

water, the intake pump strainer backwash, and the intake chlorinator building floor drain. No

discharge limitations are put on this outfall,' but it does require the collection of all debris found

on the intake screens which is not discharged into the Susquehanna River. The stormwater

outfalls (SO) are 005A, SO1, SO2, S03, and S04. They do not have specific effluent limitations,

but are required to be inspected annually or monitored for biochemical oxygen demand (BOD-5

Day), chemical oxygen demand, total suspended solids, total phosphorus, total Kjeldahl

nitrogen, dissolved iron, oil and grease, and pH levels.

TMI-1 is required to report effluent monitoring data to PADEP using discharge monitoring

reports. TMI-1 is also required to report, within 24 hours of their occurrence, any unexpected

diversions of wastewater that exceed any listed effluent limitation, upsets that exceed or

threaten to exceed any limitations, and any violations of maximum daily discharge limitations.

Part C of the NPDES permit specifies that waterborne releases of radioactive material must

conform to the guidelines in Appendix I to 10 CFR Part 50. The facility must provide reports

which describe quantities of unrestricted radioactive material released in effluent discharge to

the PADEP Bureau of Radiation Protection and the NRC.

2.2 Affected Environment

This section provides general descriptions of the environment near TMI-1 as background

information. This section also provides detailed descriptions where needed to support the

analysis of potential environmental impacts of refurbishment and operation during the renewal

term, as discussed in Chapters 3 and 4. Section 2.2.9 describes historic and archaeological

resources in the TMI-1 area, and Section 2.3 describes the possible impacts associated with

other Federal project activities.

2.2.1 Land Use

Three Mile Island covers approximately 370 acres (ac) (150 hectares [ha]), of which about 200

ac (81 ha) are occupied by the TMI-1 and TMI Unit 2 facilities. Exelon Generation owns the

June 2009 2-21 NUREG-1437, Supplement 37
Affected Environment

entire island except certain TMI Unit 2 facilities. Exelon Generation also owns all or a portion of

some of the smaller islands in the vicinity of Three Mile Island and a portion of the eastern bank

of the Susquehanna River. TMI-1 is surrounded by fencing and contains few areas that have not

been developed or previously disturbed. As can be seen in Figure 2-6, the undeveloped land on

the island is found south of the TMI-1 and TMI Unit 2 facilities. The majority of this undeveloped

land lies under the 10-year flood level and is subject to seasonal variations in water level. The

southern part of the island contains a wetland that was formed when borrow pits created during

construction of a flood dike system, which surrounds the TMI-1 and TMI Unit 2 facilities, filled

with water. The southern portion of the island also contains fallow field areas that are

surrounded by a woodland buffer (AmerGen 2008).

The TMI-1 site encompasses several properties that total approximately 440 ac (162 ha).

Included are Three Mile Island; St. John's Island and Evergreen Island (also referred to as

"Sand Beach Island"), which are situated north of Three Mile Island and together total

approximately 31 ac (13 ha); a 6.4-ac (2.6-ha) section of Shelley Island, which is part of the

western half of the TMI-1 exclusion area; and a 32-ac (13-ha) strip of land east of Three Mile

Island along the eastern shore of the Susquehanna River (AmerGen 2008).

Three Mile Island is approximately 11,000 ft long and 1,700 ft wide with the long axis aligned

north to south in the river. It lies approximately 900 ft from the east bank of the Susquehanna

River and approximately 6500 ft from the west bank of the river (see Figure 2-6 on the following

page). The Susquehanna River makes a sharp change in directional flow from southeasterly to

nearly due south just north of Three Mile Island where the river widens to approximately 1.5 mi

(2.4 km). This widening resulted from the Red Hill and York Haven Dams, which transect the

river on either side of the downstream end of Three Mile Island creating a barrier for the

purpose of hydroelectric generation (AmerGen 2008). State Highway (SH)-441 parallels Three

Mile Island to the east, and tracks of the Norfolk Southern Railroad parallel the Susquehanna

River on the eastern and western banks. Shelley Island is located west of Three Mile Island in

the middle of the river, and the borough of Goldsboro is located on the western bank of the river.

The developed portion of the TMI-1 site is surrounded by a flood protection dike system. Access

to the northern portion of Three Mile Island is by a bridge connecting the main entrance to the

TMI-1 site and the mainland near the junction of SH-441 and Geyers Church Road. Another

bridge connects the southern end of Three Mile Island with the east bank of the Susquehanna

River near Falmouth on SH-441 in Lancaster County. The southern bridge serves as access to

TMI-1 for some station operation personnel, refueling outage workers, and construction

equipment. It also provides an alternate egress route.

2.2.2 Air and Meteorology

TMI-1 is located in Dauphin County, one of the four counties comprising the Harrisburg

metropolitan area (AmerGen 2008). Pennsylvania is divided into 10 climate regions. Dauphin

County belongs to Climate Region 5, along with Lycoming, Columbia, Montour, Union,

Northumberland, Snyder, Mifflin, Juniata, and Perry Counties (PSC 2008). Data collected in the

region since 1899 show that average winter temperature is 29.9 'F (1.2 degrees Celsius [°C]),

rarely dropping below 20 'F (-6.7 'C), while average summer temperature is 61.15 OF (16.39

°C), with July being the hottest month (PSC 2008a).

NUREG-1437, Supplement 37 2-22 June 2009
Affected Environment

NHill

Islamn

G)ey N

4iand, ~Church/

sland' _ -

North

Access Amtrk

NVRoad Railroad

Shelley

Islad

-... 2000

Foot

Exclusion

Site Rood

Protection

Dike

It Ladder

I Hill Dam

Norfolk Southern

Th Mile

I d

South

Legend

-- YorkhavenDam

---- altroad

Roads

2•920i Foot Exclusion Radius

Populated Areas

Miles

Miles I

0.3 0.6 12 I

Figure 2-6. Three Mile Island Nuclear Station"

Unit 1, Site Boundary Map

(Source: AmerGen 2008) Flood PIotection ..... Dike

June 2009 2-23 NUREG-1 437, Supplement 37
Affected Environment

Precipitation is fairly evenly distributed throughout the year. Annual precipitation amounts

generally range between 30 to 48 inches, with occasional amounts reaching 54 to 58 inches.

The greatest amounts of precipitation usually occur in the spring and summer months, while

February is the driest month, amounting to about 2 inches less than the wettest months (PSC

2008b). As documented by Pennsylvania State climatologists, average mean snowfall from

1957 through 2007 was 35.4 inches (PSC 2008c).

The dominant wind direction throughout the State of Pennsylvania is from the west, with some

seasonal variation. TMI-1 historical meteorological reports show that yearly winds from the

northwest prevail, with stronger winds in winter (windspeed varies from 4 to 10 knots) and

calmer winds in summer (windspeed varies from 0 to 6 knots). The median annual windspeed

as reported by the National Weather Service station located in Harrisburg (approximately 10 mi

[16 km] northwest of TMI-1) is 7.5 mi per hour (mph) (4.1 knots) (NCDC 2008; PSC 2008b).

While the prevailing westerly winds result in most of the air masses that affect Pennsylvania

(those originating from the interior of the continent), the Atlantic Ocean does have a limited

influence on the climate of the State. Coastal storms can affect the day-to-day weather,

primarily in the eastern section of the State.

Severe weather events in Pennsylvania are generally uncommon. Severe snowstorms are

infrequent, but when they do occur, they can approach blizzard conditions. High winds have

been known to cause huge drifts that can disrupt normal routines for several days. While the

incidence of tornadoes is very low, the region has occasionally been hit with storms that caused

loss of life and property damage. June is the month of highest tornado frequency, followed

closely by July and August. The National Climatic Data Center (NCDC 2008a) reported 13

tornadoes in Dauphin County from 1950 through February 2008-three at FO, six at F1, and

four at F2 strengths.3 The most destructive activity in Dauphin County occurred on April 5, 1977,

and caused $2.5 million in property damage (NCDC 2008b). There was also an occurrence of

an F3 tornado on July 14, 2004 in Campbelltown, PA, located in Lebanon County, which caused

approximately $18 million in property damages (NOAA 2007).

The TMI-1 meteorological data monitoring system consists of Alpha and Bravo systems. Alpha

system allows it to measure windspeed and direction at 100 ft (30 m) and 150 ft (46 m), ambient

temperature at 33 ft (10 m), and differential temperature at 150 ft (46 m). Measurement of

windspeed and direction on Bravo system is conducted at 100 ft, while ambient temperature is

measured at 33 ft (10 m) and differential temperature is measured at 150 ft (46 m). The

meteorological data are collected via e-mail sent by the TMI-1 chemistry department. It is

sampled once per hour and stored in the meteorological database which is edited once a week;

invalid data are deleted during the data review process performed by a meteorologist. The

The Fujita six-point scale (FO to F5) is used to rate the intensity of a tornado based on the damage it inflicts

to structures and vegetation. The lowest intensity is FO; the highest is F5. Fujita scale categories are based

on estimated (not measured) sustained windspeeds compared against observed structural damage. An

enhanced Fujita scale replaced the original Fujita scale in February 2007. The enhanced Fujita scale still

uses six categories of tornado intensity (EFO to EF5), but defines those categories differently. For additional

information about the Fujita scale, see the following National Oceanic and Atmospheric Administration Web

site and the hypertext links therein-http://www.spc.noaa.gov/faq/tomado/f-scale.html.

NUREG-1437, Supplement 37 2-24 June 2009
Affected Environment

quality-assured meteorological data are then compiled into monthly, quarterly, and annual

reports (AmerGen 2006).

2.2.2.1 Regional Air Quality Impacts

TMI-1 is located within the Mid-Atlantic Air Quality Control Region 3, as designated by the EPA.

The Mid-Atlantic Air Protection Region 3 is represented by Delaware, the District of Columbia,

Maryland, Pennsylvania, Virginia, and West Virginia. The Bureau of Air Quality of PADEP is

responsible for regulating all air emission sources within the State. Pennsylvania's ambient air

monitoring program is a result of the implementation of the Federal Clean Air Act on a State

level. The State is divided into six air regions, and Dauphin County, where TMI-1 is located,

belongs to the Southcentral Air Quality Region, which includes the counties of Adams, Bedford,

Berks, Blair, Cumberland, Dauphin, Franklin, Fulton, Huntington, Juniata, Lancaster, Lebanon,

Mifflin, Perry, and York. Dauphin County is a nonattainment area for fine particulate matter

(PM2.

5) and a part of the Harrisburg-Lebanon-Carlisle PM2.5 nonattainment area, which includes

Cumberland, Dauphin, and Lebanon Counties. There are two monitoring sites in the HarrisburgLebanon-Carlisle PM2.5 nonattainment area-one in Dauphin County (Harrisburg) and one in

Cumberland County (Carlisle). PADEP also operates several types of PM2.5 monitors in Carlisle

and Harrisburg (PADEP 2004).

TMI-1 is recognized as a synthetic minor facility by Pennsylvania State regulators because of

the quantities of emissions of criteria pollutants released. by its stationary sources; therefore

operation of the sources is regulated by a State Only Operating Permit for Synthetic Minor

Facility (AmerGen 2006d). TMI-1 has a number of stationary emission sources, including two

auxiliary boilers, two fire service pump diesel engines, two emergency power generators, a

blackout emergency generator, a security system uninterruptible power generator, and two

substation emergency power generators. A number of sources do not require any work practice

standards, test monitoring, recordkeeping, or reporting requirements, as defined by the PADEP

permit for TMI-1. Some of these sources include three air compressors, the turbine building,

vents, turbine oil vapor extractor, a 15,000-gallon (56,781 L) turbine lubricating oil storage tank,

water and waste water treatment chemical storage tanks, water and waste water treatment

system, two natural draft cooling towers, two mechanical draft industrial box coolers, diesel fuel

and fuel oil storage tanks, and an emergency warehouse diesel-fueled fire pump. The

generators are tested periodically to ensure their continued ability to perform their intended

function, and there are procedures in place to ensure monitoring and emissions data reporting.

2.2.3 Ground Water Resources

Three Mile Island is one of a sequence of Triassic lowland deposits in an area known as the

Gettysburg Basin. The island itself formed during the later stages of glaciation as a result of

fluvial deposition (materials deposited by river flow) of glacial melt-water by the slow-moving

flow of the Susquehanna River and the resulting steady accumulation of sediments to form the

island.

Two aquifers are located beneath the TMI-1 site. The shallowest aquifer consists of surficial

alluvial deposits under unconfined conditions: The alluvial layer is made up of silty sand, with

some gravels and clay, and ranges from 7-19 ft (2.1-5.8 m) in thickness. This layer overlies

June 2009 2-25 NUREG-1437, Supplement 37
Affected Environment

layers of glacial outwash, which range from 12-21 ft (3.7-6.4 m) in thickness and are composed

of dense gravel and silt.

The second and underlying aquifer is the Gettysburg shale, which is the primary aquifer in the

area of the site. Ground water in the Gettysburg shale is under semi-confined conditions, based

on information gathered during drilling operations on the island. The shale is found 19-28 ft

(5.8-8.5 m) below the surface (AmerGen 2008). It is described as a tabular aquifer, meaning

some beds within the Gettysburg shale are able to transmit water, while others are not. The

range of permeability within the bedrock is primarily caused by varying frequencies of fractures

(Conestoga-Rovers 2006). Within the bedrock, which dips to the northwest, ground water is

found within joints, fractures, and bedding separations. Two major joint sets occur on the island,

with one dipping nearly 90 degrees, and the other dipping 50-60 degrees in the southwestern

direction. The hydraulic conductivity of the aquifer ranges from 2,126 ft-4,208 ft/yr (648.0-

1282.6 m/yr).

The ground water conditions found in the upper aquifer (the alluvial deposits) are directed by the

river itself, with the water table's maximum elevation centered in the middle of the island and

gently sloping toward the island's shores. The Susquehanna acts as a boundary for this aquifer

as the ground water flows into the river. The lower aquifer (the Gettysburg shale) is unlikely to

receive flow from the river because of its lower flow characteristics, but could occur if pumping

from the surface is heavy enough to cause infiltration.

2.2.3.1 TMI- 1 Water Supply Wells

Of the 54 water supply wells found in a specified 1-mile radius of the TMI-1 site, only 7 are

associated with the plant, Five of these wells are onsite, while the remaining two supply potable

water to the Visitors Center and the Training Center/Simulator Building. The Visitors Center well

is installed at a depth of 121 ft (36.8 m) and produces up to 10 gpm (0.02 cfs, or 0.001 m3

/s),

while the Training Center/Simulator Building well is at 100 ft (30 m) and can yield up to 30 gpm

(0.07 cfs, or 0.002 m3/s) (Conestoga-Rovers 2006). From 2003-2005, these seven ground

water wells yielded a combined total that averaged to about 95-115 gpm (0.21-0.25 cfs, or

0.006-0.007 m3/s) (AmerGen 2004; 2005; 2006e).

Of the five onsite wells, two (the Operations Support Facility/North Office Building [OSF] well

and the Building 48 [48S] well) supply the plant's public water system. The 48S well is installed

at a depth of 996 ft (303 m) and produces a maximum of 30 gpm (0.07 cfs, or 0.002 m3

/s). The

OSF well, at 775 ft (236 m), can yield a maximum of 40 gpm (0.09 cfs, or 0.003 m3

/s) and can

be used, if necessary, to supplement the water production of the three industrial makeup water

wells (A, B, and C). These three service water wells are installed at 400 ft (122 m), 500 ft (152

m), and 400 ft (122 m), respectively. Their water is utilized for the fire service, makeup to the

demineralized water system, bearing lubrication in the screen house pumps, and various other

building and equipment uses. Table 2-3 on the following page shows the annual ground water

withdrawal data for the three industrial wells (both individually and combined) for the years

2003-2005.

NUREG-1437, Supplement 37 2-26 June 2009
Affected Environment

Table 2-3. Total Annual Ground Water Withdrawal (Gallons) and Average Daily

Withdrawal Rate (Gallons) for Industrial Wells, A, B, and C and Combined for

2003-2005

Well A Well B Well C Total

Total Avg. Daily Total Avg. Daily Total Avg. Daily Total Avg. Daily

Year Withdrawn Withdrawal Withdrawn Withdrawal Withdrawn Withdrawal Withdrawn Withdrawal

(xl 000) Rate (xl000) Rate (x1 000) Rate Rate

2003 20,648 55,805 12,895 34,851 15,664 42,335 49,207,000 132,992

2004 20,434 54,930 11,696 31,441 10,859 29,191 42,989,000 115,562

2005 19,080 51,429 6229 16,790 6,787 18,294 32,096,000 86,512

Source: AmerGen 2004, AmerGen 2005, AmerGen 2006a

The SRBC originally approved the use of ground water by the TMI-1 site in 1996. Before doing

so, two 48-hour pump tests were conducted at a rate of 168,750 gpd (638,788 Lpd), and no

adverse impacts were determined (SRBC 1999). When TMI-1 applied to the SRBC in 1998 for

an increase in ground water withdrawal from its three industrial wells (A, B, and C), the original

pump test data were considered in addition to observations of plant operations. After deciding

that there were no production impacts to any of the onsite wells (including OSF and 48S) or any

wells along the eastern shore of the island, SRBC approved the increase. Currently, all three

industrial wells may pump a maximum limit of 225,000 gpd (156 gpm, or 851,718 Lpd) on a 30-

day average (SRBC 1999).

2.2.3.2 TMI-1 Monitoring Wells

The Three Mile Island Nuclear Station began installing ground water monitoring wells in 1980 to

monitor for the ground water infiltration of radionuclides such as tritium. As tritium decays, it

emits a low-energy beta particle that cannot travel far into either tissue or air. It is produced from

man-made sources as well as natural processes. In 2006, the background concentration of

tritium in the onsite ground water was said to be (at most) 200 picoCuries per liter (pCi/L)

(Conestoga-Rovers 2006).

That same year, Exelon began a study to evaluate the possible impacts of plant operation on

nearby ground water and surface water, leading to the installation of 31 new onsite ground

water monitoring wells. The initiation of this Exelon project was considered Phase 1 of the

ground water monitoring effort at TMI-1, with Phase 2 being the continuation of the ground

water monitoring program that had been in place at the station for over 20 years. Samples were

collected from up to 76 well locations and the concentration of tritium was not found to exceed

the EPA drinking water standard of 20,000 pCi/L'in any location, but was detected to be higher

than the background concentration during both studies. Samples taken from offsite drinking

water wells proved to have no detectable concentrations of tritium (AmerGen 2007).

As a result of these studies, Exelon Generation introduced the Radiological Ground Water

Protection Program (RGPP) in 2007. The purpose of this program is to ensure the detection and

adequate response to any possible radiological releases to ground water. The program includes

59 onsite monitoring wells (5 of which are the water supply wells mentioned in Section 2.2.3.1),

which are sampled for tritium, strontium-90, and gamma-emitting radionuclides (Exelon 2007).

Results from these samples are compared to the results of the 2006 studies, which now serve

June 2009 2-27 NUREG-1437, Supplement 37
Affected Environment

as the baseline monitoring round, to enable the use of trends, quickly identify contamination

issues, and ensure that ground water quality is maintained.

In 2007 the RGPP successfully identified significantly elevated tritium levels in several

monitoring wells from May-July, three of which were found to have exceeded the EPA standard

of 20,000 pCi/L (peaking at 29,600 pCi/L in July). The facility was able to identify the problem

and the source of the tritium leak, isolate the source, and then repair it. Once the problem was

corrected, tritium levels returned to acceptable standards.

Conestoga-Rovers & Associates also calculated the rate and amount of tritiated ground water

migrating to the Susquehanna River, and the results were confirmed again following the tritium

leak incident (Conestoga-Rovers 2007). Table 2-4 shows the rate of migration as affected by

the pumping of onsite water supply wells, as well as with and without background levels.

Conestoga-Rovers concluded that the migration of tritium to the Susquehanna River was

negligible, and that the amount of tritium entering the river in ground water was "minimal"

(Conestoga-Rovers 2006).

Table 2-4. Rate of Tritiated Ground Water Migration to the Susquehanna River as

Affected by Onsite Pumping and Background Levels of Tritium

(Curies Per Year)

Total Mass Flux with Background Total Mass Flux

Background (Ci/yr) Contribution without Background (Ci/yr) (Cilyr)

No Pumping 0.32 0.09 0.23

Tritium Captured by 0.20 0.013 0.18

Pumping

With Pumping 0.12 0.074 0.05

Source: Conestoga-Rovers 2006

2.2.4 Surface Water Resources

TMI-1 is located at approximately river mile 58 on the Susquehanna River, about 10 mi (16 km)

south of the city of Harrisburg, Pennsylvania, on the northern half of the 370-ac (150-ha) Three

Mile Island (AmerGen 2008). Three Mile Island is almost 12,000 ft (3,700 m) long and up to

2200 ft (700 m) wide. The Susquehanna River ranges in width from 7,000 ft-8,400 ft (2,100-

2600 m) at Three Mile Island, but narrows to less than 1,800 ft (500 m) wide within 3,500 ft

(1,100 m) downstream of Three Mile Island (AmerGen 2008). Three Mile Island is the longest in

a group of islands that divides the river into three channels (west, center, and east), as

illustrated in Figure 2-6. The intake and discharge structures for TMI-1 are located along the

western shore of Three Mile Island, in the center river channel (Ichthyological Associates 1983).

As described in detail in Section 2.1.6, the Susquehanna River provides makeup water for and

receives blowdown from the two TMI-1 cooling towers (AmerGen 2008).

NUREG-1437, Supplement 37 2-28 June 2009
Affected Environment

The Susquehanna River forms from two main branches, the North Branch Susquehanna River

and the West Branch Susquehanna River. The source of the North Branch is Ostego Lake in

Cooperstown, New York. The North Branch flows somewhat south in a meandering fashion

through Sunbury, Pennsylvania, where it joins with the shorter West Branch that begins in

central-western Pennsylvania. The two branches combine to form the mainstem of the

Susquehanna River, which is the largest tributary of the Chesapeake Bay. The Susquehanna

River flows over 440 mi (708 km) from Ostego Lake to the Chesapeake Bay. Major tributaries of

the Susquehanna River include the Juniata River, the West Branch Susquehanna River, and

the Chemung River (SRBC 2006).

The Susquehanna River Basin includes portions of the Allegheny Plateau region of the

Appalachian Mountains of Pennsylvania and New York, the rolling hills and farmland closer to

Three Mile Island situated in the Piedmont Plateau of Pennsylvania, and the coastal plain to the

Chesapeake Bay in Maryland. It drains over 27,500 square miles (mi 2

) (71,200 km 2) of central

Pennsylvania, south-central New York, and a small portion of northeastern Maryland, and is the

second-largest watershed in the eastern United States (SRBC 1999; SRBC 2006).

The Susquehanna River Basin is divided into six major subbasins: (1) the Upper Susquehanna

Subbasin, (2) the Chemung Subbasin, (3) the Middle Susquehanna Subbasin, (4) the West

Branch Susquehanna Subbasin, (5) the Juniata Subbasin, and (6) the Lower Susquehanna

Subbasin, which is the location of TMI-1 (SRBC 2006). The Lower Susquehanna Subbasin is

located primarily south and downstream of the other five subbasins. This subbasin drains about

5,900 mi 2 (15,300 km2) of urban and rural areas, ridges, and open valleys and empties into the

Chesapeake Bay at Havre de Grace, Maryland. The ridges of this subbasin are primarily

forested, and the valleys are predominantly used for agriculture. Other portions of this subbasin

contain developed areas, with only limited abandoned mine lands. The cities of Harrisburg,

Lancaster, and York are the largest populated areas in the Lower Susquehanna Subbasin

(SRBC 2006a).

Susquehanna River flow is monitored by the United States Geological Survey (USGS) from a

station located near Harrisburg. The river supplies about 19 million gpm (42,000 cfs, or 1200

m3/s) of freshwater to the Chesapeake Bay, which is about half of the Chesapeake Bay's flow of

freshwater (SRBC 2006). Figure 2-7 on the following page shows that in 2004, a year with

above-average flows, the daily mean flow of the Susquehanna River through Harrisburg was

56,400 cfs (25 million gpm or 1600 m3

/s), compared to the historic annual mean flow of 34,500

cfs (15 million gpm or 1000 m3/s). Daily mean flow in 2004 ranged from 9600 cfs (4 million gpm

or 300 m3/s) to 500,000 cfs (224 million gpm or 14,000 m3

/s). The lowest average annual mean

flow recorded at the Harrisburg gauging station is about 16,900 cfs (8 million gpm or 500 m3

/s),

with the lowest daily mean recorded as 1700 cfs (1 million gpm or 50 m3

/s) (Durlin and

Schaffstall 2005).

The Susquehanna River is well known for the flooding damage it has caused in the past, with

over 40 serious floods recorded since 1736 (Alliance for the Chesapeake Bay undated). To

protect the site and possible contamination of the river during a serious flood event, the

developed area of TMI-1 is bordered by a flood protection dike system (AmerGen 2008).

June 2009 2-29 NUREG-1437, Supplement 37
Affected Environment

Figure 2-7. Monthly Mean Flow of the Susquehanna River in 2004 and the Maximum, Mean,

and Minimum Monthly Mean Flow Date for 1891-2004

250000, 2000DO onthlv'vean of Current Water Year aEd Max. Mean. and Min Monthly Mean for 1891 - 2004

20.

Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep

Source: Durlin and Schaffstall 2005

Three Mile Island is located within a reservoir portion of the river adjacent to two dams, the

run-of-the-river York Haven Dam and the smaller Red Hill Dam, as illustrated in Figure 2-6. The

reservoir formed behind the two dams that includes part of Three Mile Island is known as York

Haven Pond and Lake Frederick (AmerGen 2008). At normal levels Lake Frederick has a

surface area of 2.3 mi2 (596 ha) and extends 3.5 mi (5.6 km) upstream. The normal full pool

elevation of Lake Frederick is 277 ft (84 m) above mean sea level, and the mean depth is 9 ft

(2.7 m) (ichthyological Associates 1983). Both dams are owned and operated by York Haven

Power Company. The York Haven Dam runs diagonally downstream and southwest from the

southern end of Three Mile Island and is over 9,200 ft (2,800 m) long. The dam connects Three

Mile Island to the mainland on the western side of the river, and is the site of a 19-20 MWe

hydroelectric plant, which controls river flow at Three Mile Island (AmerGen 2008). The dam is

located at the Conewago Falls, where the river drops 19 ft (6 m) (Kapsch 2004). The 900-footlong (290-m-long) Red Hill Dam is located at the midway point of Three Mile Island along the

eastern side of the island and regulates the flow of the Susquehanna River in the eastern

channel. Between the dam and Three Mile Island is a fish ladder where fish passage can be

monitored (AmerGen 2008).

The larger water bodies that flow into the Susquehanna River near Three Mile Island include the

Swatara Creek, East Conewago Creek, West Conewago Creek, and Fishing Creek. East

Conewago Creek discharges into the Susquehanna River from the eastern shoreline adjacent to

the southern access bridge to Three Mile Island (PADEP 2008).

The Susquehanna River Basin Commission (SRBC) performs bioassessments of the

Susquehanna River, the six subbasins, and a number of streams within each subbasin to

monitor water quality and the biological health of the river basin. As part of the Susquehanna

Large River Assessment Project, the SRBC collected biological and water chemistry data at 25

stations in 2005 on the mainstem Susquehanna River and at the mouths of three tributaries.

Nineteen of the stations were designated slightly impaired and six other stations were

designated moderately impaired. However, less than 10 percent of the samples analyzed from

the 25 stations exceeded levels of tolerance for aquatic life, indicating that the Susquehanna

River maintains fairly good water quality. Five of the 25 stations were located in the Lower

Susquehanna Subbasin. Thirty-one of the 44 samples obtained at these five stations in the

Lower Susquehanna Subbasin were designated slightly impaired, and 12 of the samples were

NUREG-1437, Supplement 37 2-30 June 2009
Affected Environment

designated moderately impaired. Only one of the samples was rated non-impaired (SRBC

2006).

In a comparison of surveys conducted in the Lower Susquehanna Subbasin in 1996 and 2005,

biological conditions improved slightly, while some parameters for water quality improved and

others degraded. The SRBC has attributed high levels of nutrients, sediments, and toxins in

some samples to the prevalence of agricultural lands in the Lower Susquehanna Subbasin,

along with areas of residential, commercial, and industrial development, and to some areas in

the subbasin containing abandoned mine lands. Data collected in 2005 during the Lower

Susquehanna Subbasin Survey, near the confluence of the Swatara Creek with the

Susquehanna River and 2 miles upstream of Three Mile Island, rated the habitat as partially

supporting, with elevated nutrient levels, elevated sodium, and nonimpaired biological

conditions. Further upstream on Swatara Creek, acid mine drainage and development affected

the watershed (SRBC 2006a).

2.2.5 Description of Aquatic Resources

Macroinvertebrates

Sampling was performed for macroinvertebrates above and below the TMI-1 discharge pipes

from 1974-1982 (Ichthyological Associates 1975; 1976; 1983) and from 1986-1990

(Normandeau 2007; RMC 1991), with the most taxa (165) collected in 1982. Dominant taxa

were aquatic tube worms (Limnodrilus hoffmeisten), the larvae of Diptera-midges (Chironomus

decorus), and mollusks (Pisidium spp.). Virginia river snail (Elimia virginica) and L. hoffmeisteri

had the greatest biomass. Distributions varied seasonally, as did relative abundance, density,

and biomass, particularly after the 1980 drought in this region (Ichthyological Associates 1983).

Biological data collected in 1996 by the SRBC at Conewago Falls, immediately downstream of

Three Mile Island, indicated that Emphemeroptera (mayflies) and Trichoptera (caddisflies) were

two of the four dominant taxa in the samples. These families are typically found in water bodies

of better water quality. Coleoptera (beetle larvae) were also dominant in the sample, with

Amphipoda (shrimp-like crustaceans) the most dominant of the four taxa, indicating less than

ideal water quality (SRBC 1996).

Macroinvertebrate samples collected by the SRBC 12 mi (19 km) downstream of Three Mile

Island (river mile 45) and 20 mi .(32 km) upstream of Three Mile Island (river mile 77) during the

1996 Lower Susquehanna River Subbasin Survey contained Corbicula fluminea-invasive

Asiatic clams. Macroinvertebrate samples collected on the Susquehanna River at the

Conewago Falls boat launch (river mile 57) contained Corbicula as well as the native pea clam

(Pisidium spp.) (SRBC 1996), characterized by its extremely small size (0.5 in.) (Pennsylvania

Sea Grant 2008a). Several species of snails (Gastropoda) were also identified from the boat

launch samples, including Ferrissia spp., Lymnaea spp., Physa spp., and Viviparus spp. (SRBC

1996). No Corbicula or pea clams were collected at the sampling stations located at river mile

45 and river mile 77 during the 2005 Lower Susquehanna Subbasin Survey, and the only snails

that were collected were Leptoxis spp. and Pleurocera spp. (SRBC 2005).

The nonnative mollusk Asiatic clam (C. fluminea) is present in the Susquehanna River and has

been observed attached to the intake structures at TMI-1. Corbicula is a small bivalve originally

from eastern Asia and Africa that has spread into many estuarine habitats and river beds of the

June 2009 2-31 NUREG-1437, Supplement 37
Affected Environment

United States. The adults typically do not grow over 1.5 in. in size. Corbicula tolerates polluted

environments better than native mussels, which allows it to colonize areas that would most likely

not be inhabited by native mussels. Corbicula is inadvertently spread by boats transported from

one waterway to another, and can cause biofouling of intake structures and irrigation systems

(Pennsylvania Sea Grant 2008). At TMI-1, a biocide is applied to the intake water as it reaches

the screens to prevent any infestations by Corbicula (AmerGen 2008).

In the fall of 2008, another common, nonnative invasive mollusk, the zebra mussel (Dreissena

polymorpha), was discovered in the southern portion of the Susquehanna River at the

Conowingo Dam in Maryland (PADEP 2008b). The zebra mussel, originally from Europe, has

spread through many states east of the Mississippi River. Zebra mussels were first discovered

in a Pennsylvania waterway of the Susquehanna watershed in May of 2007, in Cowanesque

Lake, which is near the New York State line (Alliance for the Chesapeake Bay 2007;

Pennsylvania Sea Grant 2008b). In June 2007, zebra mussels were identified in the

Susquehanna River mainstem in Oneonta, New York (Harman and Underwood 2008). And

while conducting the Upper Susquehanna Subbasin Survey in 2007, SRBC discovered zebra

mussels in the Susquehanna River at Great Bend, Pennsylvania, which was the furthest point

downstream in the Susquehanna River mainstem that zebra mussels had been identified, until

the recent siting at the Conowingo Dam by PADEP and Pennsylvania Fish and Boat

Commission (PFBC) officials (SRBC 2008; Pennsylvania Sea Grant 2008b).

Plankton

Phytoplankton and zooplankton were studied in 1974 and 1975 at the intake and discharge

structures at TMI-1. A total of 95 genera of phytoplankton were identified in 1975, with the

division Chlorophyta (green algae) the most common, followed by the division Bacillariophyta

(diatoms). Also identified were genera from the division Cyanophtya (blue-green algae),

Pyrophyta (dinoflagelltes), Euglenophyta (euglenoids), and Chrysophyta (yellow-green algae). A

total of 85 taxa of zooplankton were identified in 1974 and 1975 at the TMI-1 intake and

discharge structures. Cladocerans, rotifers, and copepods were the most abundant, and

comprised 98.9 percent of the number of zooplankton that were identified (Ichthyological

Associates 1975; 1976).

Fish

Several fish studies have been conducted by the facility in the vicinity of Three Mile Island from

1974-1982 using various sampling methods (trapnet, seine, and electrofishing), with a total of

58 different species captured. Flathead catfish (Pylodictis olivaris), channel catfish (Ictalurus

punctatus), pumpkinseed (Lepomis gibbosus), smallmouth bass (Micropterus dolomieui), black

crappie (Pommoxis nigromaculatus), and white crappie (Pomoxis annularis) dominated the

catches, and the common carp (Cyprinus carpio) contained the greatest biomass in the catch

(Ichthyological Associates 1983). A 1990 study that sampled fish in Lake Frederick found the

most common fish collected, in descending order, were the mimic shiner (Notropis volucellus),

the spotfin shiner (Cyprinella spiloptera), channel catfish, smallmouth bass, the tessellated

darter (Etheostoma olmstedi), the spottail shiner (Notropis hudsonius), pumpkinseed, the white

sucker (Catostomus commersonfi), the bluntnose minnow (Pimephales notatus), and the

common carp (RMC 1991). Fish sampling conducted from 2002-2005 in the vicinity of the

Brunner Island steam electric station, located about 4 mi downstream from Three Mile Island,

NUREG-1437, Supplement 37 2-32 June 2009
Affected Environment

has demonstrated species composition similar to the fish sampled in the vicinity of York Haven

Dam. Creel surveys in the vicinity of Lake Frederick from 2007 when compared to the 1974-

1982 study indicated that similar taxa of sportfish dominated the catch as well as walleye

(Sander vitreus) and muskellunge (Esox masquinongy) (Normandeau 2007).

The American shad (Alosa sapidissima) is an anadromous fish that historically numbered in the

millions along the entire Susquehanna River, but have substantially dropped in the last 100

years. Before 1904, millions of American shad migrated up the Susquehanna River for,.

spawning, and over 2.5 million lb (1.1 million kg) of shad were commercially harvested during

the peak of this fishery in 1885 (PFBC undated). Between 1904 and 1930, four hydroelectric

dams were constructed along the lower Susquehanna River between Three Mile Island and

close to the mouth of the Susquehanna River in Maryland, resulting in a loss of river access for

shad above each dam: York Haven Dam (1904); Holtwood Dam (1910), Conowingo Dam

(1928); and Safe Harbor Dam (1930). Safe Harbor is approximately 26 mi (42 km) south of

Three Mile Island, Holtwood is approximately 33 mi (53 km) south, and Conowingo is

approximately 48 mi (77 km) south. Construction of the Conowingo Dam in Maryland near the

mouth of the Chesapeake Bay resulted in the complete loss of accessibility to spawning habitat

for American shad and other anadromous fishes on the Susquehanna River. It also led to the

closure of the shad industry, since fish could no longer pass through this first dam on the

Susquehanna River (The Native Fish Conservancy 2008).

A combination of fish passage restoration projects performed at the Red Hill Dam, Safe Harbor

Dam, Holtwood Dam, and Conowingo Dam over the past several decades has returned

migratory access to American shad and other migratory fishes of the Susquehanna River. The

construction of fish lifts, fish ladders, low-flow fish passages, and the completion of a fish

passage facility at the Red Hill dam in 2000 has potentially opened the Susquehanna River to

American shad and other anadromous fishes as far upriver as Binghamton, NY. Fish passage

facilities are also being constructed on the tributaries of the Susquehanna River and on smaller

streams where impasses may exist. Millions of shad larvae, fry, and fingerlings are stocked

annually within the Chesapeake Bay watershed, including the Susquehanna River and its

tributaries, with over 455 million American shad stocked in the Chesapeake Bay watershed

since 1986 (CBP 2008). Cooperative stocking efforts between New York, Pennsylvania, and

Maryland are attempting to rebuild the population of American shad (Sadzinski and Jarzynski

undated).

Since the opening of the fishway in 2000 at the Red Hill Dam, York Haven Power Company has

monitored this fishway for passage of American shad, gizzard shad (Dorosoma cepedianum),

walleye, smallmouth bass, and other species. The numbers of American shad, gizzard shad,

walleye, and smallmouth bass passing the Red Hill Dam fishway have fluctuated since 2000

(York Haven Power Company 2008). American shad passage at all four dams has continued to

decline since 2006, as shown in Table 2-5 on the following page (PFBC 2008a). A number of

factors can be causing the decrease in American shad numbers in the Susquehanna River,

such as coast-wide declines in shad populations, low hatchery outputs, low wild juvenile

survival, and fish passage effectiveness (PFBC 2008d). While predation on newly stocked

American shad larvae may reduce the number that survive to adulthood (Johnson and Dropkin

1992), mortality at Susquehanna River stocking sites was less than 2 percent (PFBC 2008e).

June 2009 2-33 NUREG-1437, Supplement 37
Affected Environment

Table 2-5. American Shad Passage at the Conowingo, Holtwood, Safe

Red Hill Dams on the Susciuehanna River

Harbor, and

Year Conowingo(a) Holtwood(b) Safe Harbor(b) Red Hill

2008 19,914 2,795 1,252 21

2007 25,464 10,338 7,215 192

2006 56,899 35,968 24,929 1,913

2005 68,853 34,189 24,425 1,772

2004 109,360 3,482 2,109 219

2003 125,135 25,254 16,646 2,536

2002 108,001 17,522 11,705 1,555

2001 193,574 109,976 89,816 16,200

2000 153,546 29,421 21,079 4,675

1999 69,712 34,702 34,150 --

1998 39,904 8,235 6,054 --

1997 90,971 28,063 20,828

(a) The Conowingo Dam fish lift was built in 1991, but did not pass fish until 1997.

(b) The Holtwood Dam and Safe Harbor Dam fish lifts came online in 1997.

Source: PFBC 20008a

Other fish besides American and gizzard shad, walleye, and smallmouth bass use the Red Hill

fish ladder. While monitoring for American shad passage during a three-week period in 2008,

data collected by the York Haven Power Company indicated that the gizzard shad was the

species that most frequently passed up the ladder (15,930), followed by channel catfish (3,286),

quillback (Carpiodes cyprinus) (2,045), walleye (905), carp (332), shorthead redhorse

(Moxostoma macrolepidotum), and smallmouth bass (150). Several other species were also

observed in lower numbers passing up the fish ladder (York Haven Power Company 2008).

I The smallmouth bass is popular with recreational anglers on the Susquehanna River, but recent

events have caused a concern with fisheries managers regarding the health of smallmouth bass

and other fishes in the Susquehanna River. In the summers of 2005 and 2007, die-offs of mostly

young smallmouth bass occurred in the Susquehanna River, Juniata River, and the West

Branch Susquehanna River (PFBC 2008c). Mortality has been attributed to a bacterial infection

caused by Flavobacterium columnaris, which results in large, visible lesions on infected fish.

Greater than 50 percent of the young-of-the-year sampled in 2005 and 2007 in a study

conducted by the PFBC had visible external lesions. Scientists from the USGS suspect that

stress from low rainfall and correspondingly low flows and low dissolved oxygen levels with high

temperatures played a key role in making these fish susceptible to colonization by F. columnaris

(USGS 2008). Research was conducted in 2008 by the USGS and PFBC to determine the

cause of these outbreaks (USGS 2008).

NUREG-1437, Supplement 37 2-34 June 2009
-Affected Environment

The Susquehanna River in the vicinity of Three Mile Island is used for recreational fishing for a

variety of species, such as the smallmouth bass, flathead catfish, channel catfish, and walleye

(McNally 2008; PFBC 2008). To enhance recreational fishing, the PFBC annually stocks several

species of fish in the Susquehanna River, typically above Lake Frederick. From 1991-2008,

species stocked by the PFBC within the Lower Susquehanna Subbasin included muskellunge

and tiger muskellunge (E. lucius xE. masquinongy), walleye, striped bass (Morone saxatilis),

Hickory shad (Alosa mediocris), and American shad. The stocking of striped bass in the

Susquehanna River was discontinued in 2006 (PFBC 2008f).

The cold-water tributaries of the Susquehanna River are home to several species of trout. A

number of streams in the vicinity of Three Mile Island and Harrisburg are stocked with trout for

recreational fishing and to enhance the naturally reproducing populations. Several streams near

Three Mile Island-such as the headwaters of a tributary of Swatara Creek, located less than 2

mi upriver of Three Mile Island-also contain naturally reproducing trout populations. The

Yellow Breeches, located along the west shoreline of the Susquehanna River and opposite

Three Mile Island, also contains a naturally reproducing population of trout, (PFBC 2008b). No

essential fish habitat has been designated for any species along the Susquehanna River

upstream of Conowingo Dam (NOAA undated).

The EPA has outlined a nationwide program for the analysis of fish to establish fish

consumption advisories. This program includes a listing of parameters for tissue analysis

including PCBs, pesticides, and heavy metals..To comply with this program, Pennsylvania has

conducted fish tissue contaminant monitoring throughout the Commonwealth since 1976. Public

health advisories, based on fish tissue contaminant levels, are published annually in the PFBC

annual summary of fishing regulations'and laws. Since 2002, Pennsylvania has issued a

general Statewide advisory recommending that people consume no more than one meal per

week of recreationally caught sport fish. The Commonwealth issues more restrictive advisories

for specific water bodies.

For the reach of the Susquehanna River within the vicinity of the TMI-1 facility and the nearest

major water bodies-including Swatara Creek, East Conewago Creek, West Conewago Creek,

and Fishing Creek-Pennsylvania issued a health advisory to limit the consumption of

smallmouth bass to no more than two meals per month due to mercury contamination (PFBC

2008g).

2.2.6 Terrestrial Resources

The TMI-1 site and its associated transmission lines are located within the Lower Susquehanna

River Subbasin and span Lancaster, York, and Dauphin Counties. Before construction, the

entire TMI-1 site was within the 10-year floodplain; however, today, only the southern,

undisturbed portion of the island remains in the 10-year floodplain. Three Mile Island is

approximately 370 ac (150 ha) and includes both the TMI-1 and TMI Unit 2 facilities. The

buildings associated with plant generation and maintenance, parking lots, and onsite roads

occupy 200 ac (81 ha) of the overall island area (AmerGen 2008). The remaining 170 ac (69 ha)

are covered by fields, forested land, and wetlands with several intermittent ponds. Natural areas

June 2009 2-35 NUREG-1437, Supplement 37
Affected Environment

Legend

A usia -Transmisscion Line

S0 05•

Figure 2-8. Three Mile Island

Nuclear Station, Unit 1, Site Area

Overview Map and Transmission

Lines (Source: AmerGen 2008)

NUREG-1437, Supplement 37 2-36 June 2009
Affected Environment

within the TMI-1 site and associated transmission line ROWs include upland; riparian; river

floodplain forest communities; open fields; grasslands; and ponds, streams, and wetlands,

whose primary water source is the Susquehanna River. Figure 2-8 is a map of Three Mile

Island, the TMI-1 site, its associated transmission lines, and the surrounding area.

Preconstruction habitat at the TMI-1 site consisted of open field habitats with upland and

riparian forests as well as wetlands, while the transmission line ROWs consisted mostly of

forested and agricultural land. As a result of constructing the TMI-1 and TMI Unit 2 facilities on

Three Mile Island, slightly more than half of the island became disturbed land. Continual

maintenance of the transmission lines retains previously forested ROW land in an early

successional state.

Upland areas at the TMI-1 site primarily support Virginia pine (Pinus virginiana), sweet birch

(Betula lenta), flowering dogwood (Cornus florida), white oak (Quercus alba), northern red oak

(Quercus rubra), black oak (Quercus velutina), and tuliptree (Liriodendron tulipifera). Common

nonwoody species include fan-shaped clubmoss (Lycopodium flabelliforme), intermediate

woodfern (Dryopteris intermedia), ground ivy (Glechoma hederacea), white avens (Geum

canadense), common cinquefoil (Potentilla simplex), common blue violet (Viola papilionacea),

and Swan's sedge (Carex swanii) (WHC 2005).

Forested riparian areas at the TMI-1 site support a mix of maples (Acer spp.), alders (Alnus

spp.), birches (Betula spp.), and sycamores (Platanus occidentalis) (AmerGen 2008). Common

tree species found in the river floodplain forests in and around the TMI-1 site are silver maple

(A. saccharinum), river birch (B. nigra), and northern red oak (Quercus rubra). Nonwoody

species found in river floodplain forests include ostrich fern (Matteuccia struthiopteris),

mayapple (Podophyllum peltatum), dame's rocket (Hesperis matronalis), false mermaid

(Floerkea proserpinacoides), Dutchman's breeches (Dicentra cucullaria), jumpseed (Polygonum

virginianum), common blue violet (Viola papilionacea), and dogtooth violet (Erythronium

americanum) (WHC 2005).

Open fields and grassland make up the predominant habitat on the southern end of Three Mile

Island. Foxtail grasses (Alopercurus spp.) are the dominant genus; other grasses and sedges

common to the TMI-1 site include Allegheny blackberry (Rubus allegheniensis), northern

dewberry (Rubus flagellaris), white heath aster (Symphyotrichum ericoides), white panicle aster

(Symphyotrichum lanceolatum), wrinkleleaf goldenrod (Solidago rugosa), common sheep sorrel

(Rumex acetosella), common cinquefoil (Potentilla simplex), yellowfruit sedge (Carex

annectens), creeping bentgrass (Agrostis stolonifera), little bluestem (Andropogon scoparius),

poverty oatgrass (Danthonia spicata), and common timothy (Phleum pretense) (WHC 2005).

Sycamores, sweetgum (Liquidambar styraciflua), basswood (Tilia spp.), and locust trees are

found near the edges of the grasslands (AmerGen 2008).

The U.S. Fish and Wildlife Service (FWS) National Wetlands Inventory database indicates that

wetlands, some of which are classified as significant habits; exist on the southern end of the

TMI-1 site, as well as in the vicinity of the site along the Susquehanna River shoreline (FWS

2008). Figure 2-4 shows the location of the wetlands in proximity to the TMI-1 site. The onsite

wetlands were formed when borrow pits were created during the construction of a dike system

that surrounds the entire island (AmerGen 2008). The former borrow pits now have standing

water approximately seven months of the year (AmerGen 2008). Dragonflies, amphibians, frogs,

June 2009 2-37 NUREG-1437, Supplement 37
Affected Environment

and salamanders are all common species in the wetland ecosystems on the TMI-1 site (WHC

2005).

Invasive plant species common to Pennsylvania floodplain forests include tree-of-heaven

(Ailanthus altissima), Oriental bittersweet (Celastrus orbiculatus), and garlic mustard (Alliaria

officinalis), which encroach upon woodland areas, while purple loosestrife (Lythrum salicaria),

wild hops (Humulusjaponicus), and Japanese knotweed (Polygonum cuspidatum) are known to

colonize areas along the Susquehanna River (TNC 2005). Exelon Generation is not required to

keep records of known invasive species and does not have programs or procedures in place to

control terrestrial plant or animal invasive populations on the TMI-1 site.

A variety of wildlife exists on and in the vicinity of the TMI-1 site. Mammals common to the TMI1 site include white-tailed deer (Odocoileus virginianus); raccoon (Procyon lotor); gray squirrel

(Sciurus carolinensis); red fox (Vulpes vulpes); striped skunk (Mephitis mephitis); small

insectivores, such as moles, shrews, and bats; and rodents, such as mice and voles (AmerGen

2008). Reptiles and amphibians common to the TMI-1 site include snakes, turtles, lizards,

salamanders, and toads.

The TMI-1 site provides habitat to a variety of songbirds, upland game birds, waterfowl, and

raptors. Exelon Generation maintains onsite nests for osprey (Pandion haliaetus), peregrine

falcon (Falco peregrinus), and mallard duck (Anas platyrhynchos), as well as boxes for wood

duck (Aix sponsa) (AmerGen 2008). In March 2008, Exelon Generation installed new wood

duck houses on the southern end of the island in cooperation with the Susquehanna River

Waterfowl Association (York Daily Record 2009).

Exelon Generation has several procedures for protecting the environment, including vegetation

and wildlife, from impacts that could result from activities at TMI-1. The procedures require TMI1 activity planners to complete an environmental review checklist to determine if a proposed

activity requires further evaluation for environmental impacts and risk. If the environmental

review checklist reveals that a planned activity could disturb vegetation or wildlife habitat, then

an environmental evaluation must also be completed, and a qualified subject matter expert must

evaluate the potential for adverse impacts on endangered or threatened wildlife and plant

species or critical habitat. If the evaluation concludes that the proposed activity would result in

an environmental impact, then the activity may not proceed until the impact has been resolved

through avoidance, mitigation, or a compliance plan, when allowed by regulation.

2.2.7 Threatened and Endangered Species

Table 2-6, beginning on page 2-42 lists threatened, endangered, or candidate species known to

occur in Dauphin County, in which TMI-1 is located, or York and Lancaster counties, through

which transmission line ROWs associated with TMI-1 traverse.

2.2.7. 1 Aquatic Species

One Federally listed and State-listed endangered species, the dwarf wedgemussel

(Alasmidonta heterodon), was recorded in Lancaster County, but not in the vicinity of TMI-1 or in

the waterways along the transmission line corridors. The black bullhead (Amerius melas), a

State-listed species, has been recorded in Dauphin County (PNHP 2008), but is not known to

NUREG-1437, Supplement 37 2-38 June 2009
Affected Environment

occur in the vicinity of TMI-1 or in the waterways along the transmission line corridors (AmerGen

2008).

The FWS indicated by letter dated April 23, 2008, that no Federally listed or proposed

threatened or endangered species are known to occur within the project impact area, so no

biological assessment or further consultation under the Endangered Species Act is required with

the FWS (FWS 2008). PFBC indicated by letter dated June 3, 2008, that no adverse impacts to

State-listed rare, candidate, threatened, or endangered aquatic species are expected from the

proposed project. (PFBC 2008h).

2.2.7.2 Terrestrial Species

Two Federally listed threatened or endangered terrestrial species, the bog turtle (Glyptemys

muhlenbergii) and the northeastern bulrush (Scirpusancistrochaetus), are potentially'found in

the vicinity of the TMI-1 site (FWS 2008). The bald eagle (Haliaeetus leucocephalus) and the

peregrine falcon were formerly listed as Federally threatened and may also be found in the

vicinity of the TMI-1 site. Eleven State-listed species were identified as species for consideration

of the proposed license renewal of TMI-1, including the (1) osprey, (2) prothonotary warbler

(Protonotaria citrea), (3) yellow-crowned night heron (Nycticorax violacea), (4) black-crowned

night heron (Nycticorax nycticorax), (5) aster-like boltonia (Boltonia Dsteroids), (6) Short's sedge

(Carex shortiana), (7) flat-stemmed spike-rush (Eleocharis compressa), (8) ellisia (Ellisia

nyctelea), (9) bronze copper (Lycaena hyllus), and the formerly Federally listed (10) bald eagle,

and (11) peregrine falcon (DCNR 2008a; PGC 2008; AmerGen 2008; PNHP 2008). The

American Holly (flex opaca), State-listed as endangered, has been documented as occurring on

the TMI-1 site; however, neither the Pennsylvania Department of Conservation and Natural

Resources (DCNR) nor the Pennsylvania Game Commission (PGC) has identified the species

for consideration of the proposed license renewal of TMI-1 (AmerGen 2008; DCNR 2008a; PGC

2008; PNHP 2008).

Federally Protected and Formerly Protected Terrestrial Species

The northeastern bulrush and the bog turtle have ranges that include the TMI-1 project area, but

neither species is known to occur on the TMI-1 site or along its associated transmission line

ROWs (AmerGen 2008). Additionally, neither species was identified in the April 23, 2008, letter

from FWS as species requiring consideration for this proposed action (FWS 2008).

On July 9, 2007, the FWS issued a Federal Register notice announcing the delisting of the bald

eagle from the Federal List of Endangered and Threatened Wildlife (72 FR 37346). Eagles

continue to be protected at the national level by the Bald and Golden Eagle Protection Act; as

well as the Migratory Bird Treaty Act, and at the State level as a Pennsylvania-listed threatened

species. The bald eagle is a large bird, even among raptor species, and can reach a weight of

more than 13 lb (6 kg). The eagle has a white head and tail, with brown body feathers. Bald

eagles eat fish, small mammals, birds, and occasionally carrion. Bald eagles are known to occur

in Dauphin, Lancaster, and York Counties, and are seen regularly along the Susquehanna

River. The eagle is occasionally seen on Three Mile Island; however, the closest known nest is

20 mi (32 km) south of TMI-1, near the Holtwood Dam (AmerGen 2008).

The peregrine falcon was removed from Federal listing in August 1999, but continues to be

listed as endangered at the State level. Adult birds have a bluish-black head and wings, are 14-

19-in. (36-48 cm) tall, and have a 39-43-in (99-109 cm) wingspan (Cornell 2003). Peregrine

June 2009 2-39 NUREG-1437, Supplement 37
Affected Environment

falcons nest on high cliffs near river systems and on bridges and tall buildings (PGC 2006). The

species was not observed nesting in Pennsylvania from 1959 to 1987, coinciding with the

population depletion between 1950 and 1970 caused by the species' sensitivity to DDT (Cornell

2003). Reintroduction efforts in Pennsylvania and neighboring states have facilitated the growth

of the population since the early 1990s (PGC 2006). A breeding pair has nested on the TMI-1

reactor building every year since 2002 (AmerGen 2008). In an effort to protect the nesting pair

and their young, Exelon Generation regularly communicates with FWS, DCNR, and PADEP

(AmerGen 2008).

State Protected Terrestrial Species

The Pennsylvania State-listed threatened osprey occurs on the Susquehanna River shoreline

throughout the project area, and osprey nests are known to occur on the TMI-1 site (AmerGen

2008). The osprey is a fairly large bird of prey with a body length of about 21-24 in. (53-61 cm)

and a wingspan of 4.5-5.5 ft (1.4-1.7 m). Osprey feed exclusively on live fish (FWS 2008a).

Individuals are brown with a white belly and have distinctive patches on their wings. The osprey

has long, sharp talons, which are used for gripping fish. Females are larger than males, which

is true for most birds of prey. The osprey's habitat includes rivers, lakes, and shallow water

estuaries. Nesting often occurs on artificial structures such as flat-topped wooden platforms,

metrological towers, channel markers, and radio towers, where such structures are near shallow

waters that support plentiful fish. Osprey pairs tend to be solitary nesters, and may colonize

secure areas such as islands (USGS undated). Since 2004, ospreys have nested on the TMI-1

meteorological tower, located on the north end of Three Mile Island (AmerGen 2008). Exelon

Generation built a 55-ft (1 7-m) nesting platform in an attempt to relocate the nesting pair to a

location more secluded from human activity, but relocation efforts have been unsuccessful

(AmerGen 2008). Although it is unknown why relocation efforts were unsuccessful, ospreys are

known to pair for life and typically use the same nest site for many years (USGS undated). The

ospreys at TMI-1 continue to successfully nest on the meteorological tower.

The Pennsylvania State-listed endangered aster-like boltonia, also a Pennsylvania species of

special concern, grows on rocky shores and exposed, rocky river beds (DCNR2008a). The

boltonia is a tall, slender plant with stalks commonly growing to heights of 4-6 ft (1.2-1.8 m).

The plant has white flowers with a yellow center, which appear between July and October (Fike

2008). The closest location of the boltonia to the TMI-1 site is the riverside outcrop community

(Fike 1999).

Short's sedge, a species of special concern in Pennsylvania, occurs near wetlands along the

Susquehanna River (PHNP 2008). Short's sedge is a grass-like plant, ranging in height from 8-

35 in. (20-89 cm) (PNHP 2008b). The stems are light green, three-sided, and have no hairs

(PNHP 2008b). Flowers, which grow on the top of each stem, are densely packed, brown

cylindrical spikes and look like very small pinecones (PNHP 2008b). Short's sedge is known to

occur near TMI-1 and its associated transmission line ROWs (PNHP 2008b; DCNR 2008a).

The flat-stemmed spike-rush, a grass-like plant in the sedge family, is listed as endangered in

the Commonwealth of Pennsylvania (DCNR 2008a). DCNR also identifies the plant as a

species of special concern (DCNR 2008a). The medium-to-dark green species grows 0.5-1.5 ft

(15- 46 cm) in height and has a uniform diameter of 0.04 in. (1 mm) (Hilty 2006b). Generally

NUREG-1437, Supplement 37 2-40 June 2009
Affected Environment

one long, oval-shaped flower can be found per stalk. Flowers range in color from light-tomedium brown with small white spikes (Hilty 2006b).

The Pennsylvania-threatened ellisia is also a species of special concern for TMI-1 and the

associated transmission line ROWs (DCNR 2008a). The 4-16-in. (10-41 cm) wildflower has

pale green to pale purple stems and dark green, hairy leaves (Hilty 2006a). Individual flowers

appear in May, span 0.25 in. (6.4 mm) in diameter, and have five small white petals surrounding

a pale blue center (DCNR 2008a; Hilty 2006a). Ellisia is known to occur in the area of TMI-1 and

its associated transmission line ROWs, and is generally found in damp, shady areas near

stream banks with rich soils (DCNR 2008a; PNHP 2008a).

The bronze copper, a Pennsylvania species of special concern, is a butterfly that lives in wet

meadowsand marshes (DCNR 2008a). The DCNR does not currently rank the species as

endangered, threatened, or rare because of a lack of or conflicting information about population

trends (DCNR 2008a). The male is brown and the female is yellow-orange with black spots. In

both sexes, the underside is orange with black spots. The bronze copper likes to perch on low,

nontree plants ranging less than 3-4 ft (1-1.2 m) in size. When in its caterpillar phase, the

species eats green leaves from plants.

The prothonotary warbler, a Pennsylvania species of special concern, is known to nest and

forage in proximity to the TMI-1 site, according to PGC (PGC 2008); however, the species is not

identified by the FWS or DCNR as rare, threatened, or endangered for the TMI-1 site. The

warbler is a very colorful bird, with a bright yellow-golden head and underside, olive body, bluegray wings and tail, and white underwings. Prothonotary warblers live and breed in wooded

swamps, bottomland, flooded forests, and alongside slow-moving rivers. The warbler feeds

primarily on caterpillars, insects, fruit, and seeds (Audubon 2008). Exelon Generation has no

monitoring programs for the prothonotary warbler.

The Pennsylvania-endangered yellow-crowned night heron lives in proximity to the TMI-1 site

(PGC 2008). Adult herons are approximately 2 ft (61 cm) tall with a long, slender appearance,

have a 3-4-ft (1.0-1.2 m) wingspan, and are blue to gray in color. The species feeds mostly on

fish. Exelon Generation has no monitoring programs in place for the yellow-crowned night

herons, therefore their population numbers within the vicinity of TMI-1 are unknown.

The black-crowned night heron, listed in Pennsylvania as endangered, is a medium-sized heron

with a stocky body and short legs and neck (PNHP 2008). The heron has a black crown; a black

and white face, chest, and belly; and blue-gray wings. It feeds primarily on aquatic

invertebrates, fish, and frogs. The PGC identifies the species as one of special concern

because it nests near the TMI-1 site (PGC 2008). Exelon Generation has no monitoring

programs in place for the black-crowned night heron; therefore, their population within the

vicinity of TMI-1 is unknown.

.June 2009 2-41 NUREG-1437, Supplement 37
Affected Environment

Table 2-6. Listed Aquatic and Terrestrial Species. The species listed are Federallylisted, Pennsylvania-listed, or both that are threatened, endangered, or

candidate species. These species may occur on the TMI-1 site, within the

Susquehanna River, or within the transmission line corridors.

Federal State Scientific Name Common Name Status(a) Status(b) Habitat

Fish

Ameiurus melas black bullhead PE Quiet backwaters

Reptiles and

Amphibians

Glyptemys muhlenbergii bog turtle T PE Wetlands, bogs, fens,

meadows, and wet grassy

areas

Opheodrys aestivus rough green snake PE Hilly, forested, dry areas

Pseudemys rubriventris redbelly turtle PT Aquatic species found in

lakes, rivers, ponds, and

marshes

Insects

Lycaena hyllus bronze copper SC Low wet meadows and

marshes, especially in

river flood plains (DCNR

2008a)

Birds

Bartramia longicauda upland sandpiper PT Bogs, fens, grasslands,

and pastures

Botaurus lentiginosus American bittern PE Freshwater wetlands and

shorelines

Casmerodius albus great egret PE Aquatic and wetland

habitats

Cistothorus platensis sedge wren PE Wet meadows, freshwater

marshes, and bogs

Falco peregrinus peregrine falcon PE Cliffs, usually near riverine

areas

Haliaeetus leucocephalus bald-eagle PT Forests near water bodies

NUREG-1437, Supplement 37 2-42 June 2009
Affected Environment

Federal State Scientific Name Common Name Status(a) Status(b) Habitat

Nyctanassa violacea yellow-crowned PE Freshwater and saltwater

night-heron marshes, wooded

swamps, and shore areas

Nycticorax nycticorax black-crowned night- PE Fresh and saltwater

heron marshes, swamps, lakes,

and wooded streams

Pandion haliaetus osprey PT Close proximity to watery

areas such as lakes, bogs,

rivers, bay areas, and

oceans

Rallus elegans king rail PE Freshwater and brackish

marshes

Mammals

Cryptotis parva least shrew PE Grasses, brushes, and

weedyfields

Neotoma magister Allegheny woodrat PT Rocky, forested areas

Plants

Agalinis auriculata

Ammannia Coccinea

Arethusa bulbosa

Aristida purpurascens

Arnica acaulis

Asplenium bradleyi

Boltonia asteroides

eared false-foxglove

scarlet ammannia

swamp-pink

arrow-feathered

three awned

Leopard's-bane

Bradley's spleenwort

aster-like boltonia

PE

PE

PE

PT

PE

PT

PE,SC

Prairies, dry woods, and

open fields

Moist, sandy shorelines

Wetland areas

Moist areas, swamps,

shores, and wetlands

Wooded areas

Exposed, barren areas;

cliffs; and rocks

Rocky shores and

exposed rocky river beds

(DCNR 2008a)

Grasslands and barren

areas

Wetlands, ponds,

marshes, and areas with

standing water

Bouteloua curtipendula

Carex aquatilis

tall gramma

water sedge

PT

PT

June 2009 2-43 NUREG-1437, Supplement 37
Affected Environment

Federal State Scientific Name Common Name Statusla) Status(b) Habitat

Carex bullata bull sedge PE Wetlands, ponds,

marshes, and areas with

standing water

Carex diandra lesser panicled PT Wetlands, ponds,

sedge marshes, and areas with

standing water

Carex polymorpha variable sedge PE Wetlands, ponds,

marshes, and areas with

standing water

Carex prairea prairie sedge PT Wetlands, ponds,

marshes, and areas with

standing water

Carex shortiana sedge SC Wet meadows, swamps,

and wooded areas (DCNR

2008a)

Carex sterilis sterile sedge PT Wetlands, ponds,

marshes, and areas with

standing water

Carex tetanica sedge PT Wetlands, ponds,

marshes, and areas with

standing water

Carex typhina cattail sedge PE Wetlands, ponds,

marshes, and areas with

standing water

Chrysopsis mariana

Cirsium horridulum

Cladium mariscoides

Clitoria mariana

Cynanchum laeve

Cyperus diandrus

Maryland goldenaster

horrible thistle

twig rush

butterfly-pea

smooth swallow-wort

umbrella flatsedge

PT

PE

PE

PE

PE

PE

Well-drained, open woods

Shores, marshes, or sandy

fields

Wetlands, bogs, and

freshwater shorelines

Dry, open areas on sandy

soil

Open areas or areas with

slight ground cover

Wetlands and wet

meadows

NUREG-1437, Supplement 37 2-44 June 2009
Affected Environment

Federal State

Scientific Name Common Name StFt(a) Status(b) Habitat

Cyperus refractus reflexed flatsedge PE Open dry fields, clearings,

open forests, and sandy

soils

Cyperus retrorsus retrorse flatsedge PE Open dry fields, clearings,

open forests, and sandy

soils

Cypripedium reginae showy lady's-slipper PT Bogs, swamps, wet

meadows, and damp

forests

Dodecatheon radicatum jeweled PT Moist, shaded areas and

shooting-star river bluffs

Eleocharis compressa flat-stemmed PE,SC River banks with sandy

spike-rush soils and usually wet areas

(DCNR 2008a)

Eleocharis intermedia

Elephantopus

carolinianus

Ellisia nyctelea

Epilobium strictum

Erigenia bulbosa

Euphorbia purpurea

matted spike-rush

elephant's foot

ellisia

downy willow-herb

harbinger-of-spring

glade spurge

PT

PE

PTSC

PE

PT

PE

Marshes, wetlands, and

muddy areas

Dry, open woods

River banks and alluvial

woods (DCNR 2008a).

Bogs, swamps, and

wetlands

Wet, wooded areas

Cool, moist woods,

swamps, and alongside

streambanks

Wet, wooded areas and

wet meadows

Swampy, damp

grasslands, and wetlands

Open areas in forest

habitats

Glades, prairies, and open

fields

Woodlands, prairies, and

open rocky areas

Festuca paradoxa

Fimbristylis annua

Gaylussacia dumosa

Gymnopogon ambiguus

Helianthemum bicknellii

cluster fescue

annual fimbry

dwarf huckleberry

broad-leaved

beardgrass

Bicknell's hoary

rockrose

PE

PT

PE

PE

PE

June 2009 2-45 NUREG-1437, Supplement 37
Affected Environment

Scientific Name

Hypericum densiflorum

Common Name

bushy St.

John's-wort

American holly

crested dwarf iris

slender blue iris

Federal State

Status(a) Status(b)

PT

Ilex opaca

Iris cristata

Iris prismatica

PT

PE

PE

Iris verna

Juncus arcticus var.

littoralis

dwarf iris

baltic rush

PE

PT

Juncus brachycephalus small-headed rush PT

Juncus dichotomus forked rush PE

Juncus scirpoides scirpus-like rush PE

Habitat

Stream banks, pond and

lake edges, and wet

meadows

Moist, sandy woodlands

Wooded areas and ravines

Saltwater and freshwater

marshes, shores, and wet

meadows

Grassy areas and shaded

woody areas

Wetland areas, wet

meadows, and wet grassy

areas

Wetland areas, wet

meadows, and wet grassy

areas

Wetland areas, wet

meadows, and wet grassy

areas

Wetland areas, wet

meadows, and wet grassy

areas

Dry, open grasslands

Glades, prairies, and open

fields

Pond and stream edges

and wetlands

Pond and stream edges,

wetlands, and wet areas

Wet, wooded areas, and

wetlands

Swampy, damp

grasslands, and wetlands

Swamps, marshes, wet

meadows, and wetlands

Linum intercursum

Linum sulcatum

Lipocarpha micrantha

Lobelia kalmii

Lobelia puberula

Ludwigia decurrens

Ludwigia polycarpa

sandplain wild flax

grooved yellow flax

common hemicarpa

brook lobelia

downy lobelia

upright

primrose-willow

false loosestrife

seedbox

PE

PE

PE

PE

PE

PE

PE

NUREG-1437, Supplement 37 2-46 June 2009
Scientific Name

Lycopodiella appressa

Lyonia mariana

Magnolia tripetala

Magnolia virginiana

Matelea obliqua

Melica nitens

Myriophyllum sibiricum

Panicum scoparium.

Passiflora lutea

Phemeranthus teretifolius

Phlox ovata

Phyllanthus caroliniensis

Poa paludigena

Polygala cruciata

Polygala incarnata

Polygonum setaceum

var. interjectum

Potamogeton hillii

Common Name

southern bog

clubmoss

stagger-bush

umbrella magnolia

sweet bay magnolia

oblique milkvine

three-flowered

melic-grass

northern water-milfoil

velvety panic-grass

passion-flower

round-leaved

fame-flower

mountain phlox

Carolina leaf-flower

bog bluegrass

cross-leaved

milkwort

pink milkwort

swamp smartweed

Hill's pondweed

Federal State

Status(a) Status(b)

PT

PE

PT

PT

PE

PT

PE

PE

PE

PT

PE

PE

PT

PE

PE

PE

PE

Affected Environment

Habitat

Bogs, wetlands, and sandy

banks

Moist, sandy, and wooded

areas

Wooded areas and forests

Wooded areas and forests

Open wooded areas, rocky

slopes, and wooded edges

Dry, rocky woods, and

open areas along edges

Lakes, ponds, and streams

Prairies, glades,

roadsides, and fields

Rich woods, rocky areas,

and slopes

Wooded areas

Sunny fields and open

areas

Open fields

Wet woods, bogs, and

sedge meadows

Wet, sandy meadows and

marshes

Open fields and semi-open

forests

Sandy wetlands and moist

fields

Ponds, lakes, streams,

and mostly submerged

areas

Ponds, lakes, streams,

and mostly submerged

areas

Potamogeton obtusifolius blunt-leaved PE

pondweed

June 2009 2-47 NUREG-1437, Supplement:37
Affected Environment

Scientific Name

Potamogeton richardsonii

Common Name

red-head pondweed

Federal

Status(a) St

of I.

Pycnanthemum torrei

Quercus shumardii

Ranunculus fascicularis

Rhexia mariana

Torrey's

mountain-mint

Shumard's oak

tufted buttercup

Maryland

meadow-beauty

dwarf azalea

capillary

beaked-rush

limestone petunia

Rhododendron atlanticum

Rhynchospora capillacea

Ruellia strepens

tatus(b) 'Habitat

PT Ponds, lakes, streams,

and mostly submerged

areas

PE Fields and open woods

PE Forest habitats

PE Dry woods, glades,

prairies, and roadsides

PE Wet meadows, freshwater

marshes, bogs, and

wetlands

PE Wooded areas

PE Open wetlands

PT Moist, open woods and

wetlands, and

streambanks

PE Marshes and bogs

PE Wetlands, shores,

mudflats, and beaches

PE Small wetlands

PT Moist, sandy soils,

wetlands, wet meadows,

and bogs

PE Marshes, bogs, wetlands,

and wet meadows

PE Dry fields and open woods

PE Open areas, floodplains,

and some wet areas

PE Fields, open woods,

meadows, and edges of

salt marshes

PE Riverbanks, open areas,

and water edges

Scheuchzeria palustris

Schoenoplectus smithii

Scirpus ancistrochaetus

Scleria pauciflora

pod-grass

Smith's bulrush

northeastern bulrush

few flowered nutrush

E

E

Scleria verticillata

Sericocarpus linifolius

Sida hermaphrodita

Sisyrinchium atlanticum

whorled nutrush

narrow-leaved whitetopped aster

sida

eastern blue-eyed

grass

sticky golden-rod Solidago simplex ssp.

Solidago simplex ssp.

randii var. racemosa

NUREG-1437, Supplement 37 2-48 June 2009
Affected Environment

Federal State Scientific Name Common Name Status(a) Status(b) Habitat

Solidago speciosa var. slender golden-rod PE Dry, open fields, tall,

erecta grassy areas, and

roadsides

Sparganium androcladum branching bur-reed PE Swamps and shallows

Spiranthes vernalis spring ladies'-tresses PE Wet or dry upland prairies,

and roadsides

Sporobolus clandestinus rough dropseed PE Prairies, glades,

roadsides, fields, and

rocky edges

Sporobolus heterolepis prairie dropseed PE Open fields and prairies

Symphyotrichum serpentine aster PT Dry fields and open woods

depauperatum -

Thalictrum coriaceum thick-leaved PE Rocky, open, wooded

meadow-rue areas, and with moist soils

Triphora trianthophora nodding pogonia PE Dense forests

Vernonia glauca tawny ironweed PE Meadows and upland

forests

Viburnum nudum possum-haw PE Moist woods, wetlands,

and swamps

Vittaria appalachiana Appalachian PT Rock outcrop areas in

gametophyte fern fields and forests

(a) E = Federally endangered; T = Federally threatened

(b) PE = Pennsylvania endangered; PT = Pennsylvania threatened; SC = State species of concern

2.2.8 Socioeconomic Factors

This section describes current socioeconomic factors that have the potential to be directly or

indirectly affected by changes in TMI-1 operations. TMI-1 and the communities that support it

can be described as a dynamic socioeconomic system. The communities provide the people,

goods, and services required by TMI-1 operations. TMI-1 operations, in turn, create the demand

and pay for the people, goods, and services in the form of wages, salaries, and benefits for jobs

and dollar expenditures for goods and services. The measure of the communities' ability to

support the demands of TMI-1 depends on its ability to respond to changing environmental,

social, economic, and demographic conditions.

The socioeconomics region of influence (ROI) is defined by the areas where TMI-1 employees

and their families reside, spend their income, and use their benefits, thereby affecting the

economic conditions of the region. The TMI-1 ROI consists of a two-county area (Dauphin and

Lancaster counties) where approximately 71 percent of TMI-1 employees reside. The following

June 2009 2-49 NUREG-1437, Supplement 37
Affected Environment

sections describe the housing, public services, offsite land use, visual aesthetics and noise,

population demography, and the economy in the ROI surrounding TMI-1.

Exelon Generation employs a permanent workforce of approximately 525 employees (AmerGen

2008). Approximately 97 percent live in Dauphin, Lancaster, Lebanon, York, Cumberland, Perry,

and Berks Counties, PA (Table 2-7). The remaining 3 percent of the workforce are divided

among 12 counties in Pennsylvania, ranging from one to five employees per county. Given the

residential locations of TMI-1 employees, the most significant impacts of plant operations are

likely to occur in Dauphin and Lancaster counties. The focus of the socioeconomic impact

analysis in this supplemental environmental impact statement (EIS) is therefore on the impacts

of TMI-1 on these two counties.

Refueling outages at TMI-1 occur at 24-month intervals. During refueling outages, site

employment increases by as many as 1,400 workers for approximately 20 to 30 days (AmerGen

2008). Most of these workers are assumed to be located in the same geographic areas as the

permanent TMI-1 staff.

Table 2-7. TMI-1 Employee Residence by County

County Number of Percentage

Employees of Total

Dauphin, PA 196 37

Lancaster, PA 176 34

Lebanon, PA 57 11

York, PA 41 8

Cumberland, PA 26 5

Perry, PA 7 1

Berks, PA 6 1

Other 16 3

Total 525 100

Source: AmerGen 2008

2.2.8.1 Housing

Table 2-8 on the following page lists the total number of occupied and vacant housing units,

vacancy rates, and median value in the two-county ROI. According to the 2000 census, there

were over 291,000 housing units in the socioeconomic region, of which approximately 275,000

were occupied. The median value of owner-occupied units ranged from $99,900 in Dauphin

County to $119,300 in Lancaster County. The vacancy rate was lower in Lancaster County (4.1

percent) than Dauphin County (7.6 percent).

NUREG-1437, Supplement 37 2-50 June 2009
Affected Environment

By 2006, the number of housing units in Dauphin County grew to an estimated total of 115,896

units, an increase of more than 4,700 units, and the number of occupied units grew by more

than 1,600 units to an estimated total of 104,336 units. As a result, the number of available

vacant housing units in Dauphin County increased by more than 3,090 units to 11,560, or 10

percent of the available units. In addition, the estimated number of vacant housing units also

increased in Lancaster County (USCB 2008).

Table 2-8. Housing in Dauphin and Lancaster Counties, Pennsylvania

Dauphin Lancaster Region

2000

Total 111,133 179,990 291,123

Occupied housing units 102,670 172,560 275,230

Vacant units 8,463 7,430 15,893

Vacancy rate (percent) 7.6 4.1 5.5

Median value (dollars) 99,900 119,300 109,600

2006*

Total 115,896 192,351 308,247

Occupied housing units 104,336 184,581 288,917

Vacant units 11,560 7,770 19,330

Vacancy rate (percent) 10.0 4.0 6.3

Median value (dollars) 136,200 171,900 154,050

* Estimated

2.2.8.2 Public Services

This section presents a discussion of public services including water supply, education, and

transportation.

Water Supplv

Because TMI-1 is located in Londonderry Township (in Dauphin County) and most of the TMI-1

employees reside in Dauphin and Lancaster counties, the discussion of public water supply

systems is limited to Dauphin and Lancaster counties.

Dauphin County

Dauphin County is currently served by 14 public water systems. Public water systems serve

approximately 240,000 persons with approximately 74,000 connections (Dauphin County 2008).

The largest populations served are those receiving water from United Water Pennsylvania

(94,000 persons served), the Harrisburg Municipal Water Authority (66,500 persons), and the

Pennsylvania American Water Company-Hershey (42,000 persons) (PADEP 2008). The

June 2009 2-51 NUREG-1437, Supplement 37
Affected Environment

sources for these public water systems are primarily surface water (i.e. various creeks, streams

and a reservoir), while the majority of the smaller systems are dependent upon ground water

sources (Dauphin County 2008). County planners state that there is currently ample water to

meet demand. Table 2-9 lists the largest municipal water suppliers in Dauphin County.

Lancaster County

Lancaster County has more than 30 major public water systems providing services for larger

communities in the county. Although these systems draw from ground water and surface water

sources, they are becoming increasingly dependent on ground water to meet growing public

demand. Over the last several decades, Lancaster County's population has grown at a faster

rate than the Commonwealth of Pennsylvania, reflecting an increase in demand for water.

Lancaster County currently has ample supply to meet the county's needs. However, county

planning officials are concerned about future supplies. Table 2-9 lists some of the major

community water supply systems in the two-county area.

Table 2-9. Major Public Water Supply Systems

Water Source Average Daily Design Population

Water Supplier a a, b Production c Capacity c Served

Dauphin County

Harrisburg Municipal Water Authority SW 9 20 66,540

Pennsylvania American Water SW 6 9 42,398

Company-Hershey

United Water Pennsylvania SW 11 16 94,000

Lancaster County

City of Lancaster SW 16 40 108,000

Columbia Water Company SW 2 3 21,500

Elizabethtown Area Water SW 1 2 15,000

Ephrata Area Joint Authority SW 3 4 17,937

East Hem pfield Water Authority GW 2 3 16,761

(a) GW = ground water; SW = surface water;

(b) EPA 2008c

(c) Million gallons per day

Source: PADEP 2008a

Education

TMI-1 is located in the Lower Dauphin School District (PDE 2004), Dauphin County, which had

an enrollment of approximately 3,950 students in 2006-2007 school year (PDE 2007a).

Including the Lower Dauphin School District, Dauphin County has 10 public school districts

(PDE 2007a) with over 38,500 enrolled students (PDE 2007b). Lancaster County has a total of

NUREG-1437, Supplement 37 2-52 June 2009
Affected Environment

16 public school districts (PDE 2007a). Total enrollment in Lancaster County public schools in

the 2006-2007 school year was approximately 71,000 students (PDE 2007b).

Transportation

TMI-1 is located in the southwest corner of Dauphin County (near the northern border of

Lancaster County), approximately 10 mi southeast of Harrisburg, Pennsylvania. Dauphin

County is traversed by four interstate highways: 81, 83, 283, and 76. The nearest interstate,

1-76, can be accessed approximately 7 mi north of TMI-1 (see Figures 2-1 and 2-2).

Road access to TMI-1 is via State Highway 441 (SH-441), which runs north to south on the east

side of the Susquehanna River. There are two access roads to TMI-1, Liberty Lane to the north

(North Access Road), and Constitution Drive to the south (South Access Road), and they both

intersect with SH-441 (see Figure 2-6). The majority of the plant's operation workforce uses the

northern entrance; a limited number of employees working on the southern portion of the

station, as well as the outage and refurbishment workforces use the southern entrance

(AmerGen 2008). Approximately 4-5 mi north of TMI-1, SH-441 intersects with 1-76, which runs

east to west (Figure 2-2). Exelon Generation and contractor employees traveling to TMI-1 from

Harrisburg, Hummelstown, and Middletown from the north would use 1-76, or a variety of

interstate, State, and secondary roads to access SH-441. Workers traveling to TMI-1 from

Elizabethtown, Mount Joy, and Lancaster from the south would also use a variety of State

highways and secondary roads to access SH-441.

Employees traveling from the southwest would travel north to 1-76, cross the Susquehanna

River, and access SH-441 to reach TMI-1.

Table 2-10 on the following page lists commuting routes to TMI-1 and average annual daily

traffic (AADT) volume values. The AADT values represent traffic volumes for a 24-hour period

factored by both day of week and month of year.

Table 2-10. Major Commuting Routes in the Vicinity of the Three Mile Island

Nuclear Station and 2006 Average Annual Daily Traffic (AADT)

Counts

Roadway and Location AADT (a)

State Highway 230, south of Interstate 76, near Harrisburg International

Airport to Middletown 13,000-17,000

State Highway 441, just north of Interstate 76 6,400

State Highway 441, south of Interstate 76, near Middletown 7,100

State Highway 441, south of Interstate 76, near Royalton 6,700

State Highway 441, near northern entrance to Three Mile Island 3,300

State Highway 441, between Dauphin County border and intersection with 4,200

State Highway 241 (Lancaster County)

State Highway 441, between intersection with State Highway 241 and 5,100-6,300

intersection with State Highway 743 (Lancaster County)

June 2009 2-53 NUREG-1437, Supplement 37
Affected Environment

Table 2-10. Major Commuting Routes in the Vicinity of the Three Mile Island

Nuclear Station and 2006 Average Annual Daily Traffic (AADT)

Counts

Roadway and Location AADT (a)

State Highway 441, between intersection with State Highway 743 and 1100

intersection with State Highway 772 (Lancaster County)

State Highway 441, between intersection with State Highway 772 and 16,000

intersection with State Highway 23 (Lancaster County)

State Highway 441, between intersection with State Highway 23 and 17,000

intersection with U.S. Route 30 (Lancaster County)

State Highway 441, between intersection with U.S. Route 30 and 12,000

intersection with State Highway 462 Lancaster County)

Source: PennDOT 2008.

(a) All AADTs represent traffic volume during the average 24-hour day during 2006.

2.2.8.3 Offsite Land Use

Offsite land use conditions in Dauphin and Lancaster Counties are described in this section,

because the majority of TMI-1 employees live in these two counties. In addition to the real

estate taxes paid by Exelon Generation to Dauphin County, Dauphin and other counties in the

vicinity of TMI-1 receive revenue from the taxes and fees paid by Exelon Generation and longterm contract employees residing in the region. In addition, changes in the number of workers

employed at TMI-1 and the amount of taxes paid to local jurisdictions could affect land use

conditions in these counties. The TMI-1 facility is located in southwestern Dauphin County.

Lancaster County is located southeast of Dauphin County along the Susquehanna River.

Dauphin County

Dauphin County is approximately 525 mi 2 (1360 km2) and has 40 municipalities including the

Pennsylvania State capital in Harrisburg (USCB 2008b). The county is located in south-central

Pennsylvania, along the Susquehanna River. Dauphin County planners are concerned about

future population growth and making growth decisions that will not overburden taxpayers.

County planners are focused on revitalizing older developed areas of the county and managing

growth that will not change its rural character.

Dauphin County planners are working to manage development within the county through the

use of Planned Growth Areas. Dauphin County adopted the Regional Growth Management Plan

produced by the Tri-County Regional Planning Commission (which includes Cumberland and

Perry Counties). The goal is to focus development in and around Planned Growth Areas where

services such as sewer, water, transit, highway access, and community facilities exist to

maximize the investment in existing infrastructure (Dauphin County 2008).

The recently adopted Dauphin County Comprehensive Plan describes the following land use:

0 Residential: 15 percent

NUREG-1437, Supplement 37 2-54 June 2009
Affected Environment

* Public and semi-public lands: 26 percent (two-thirds comprised of state game lands

and forest)

* Agricultural and undeveloped lands: 55 percent

* Industrial: 2 percent

* Transportation: less than 1 percent

* Commercial and service: less than 1 percent each.

In 2000, 34.5 percent of the county's residents lived in Harrisburg and 16 boroughs while others

made their homes in townships and villages. As part of the 2008 Comprehensive Plan, the

county considered future land use by including geographic planning sections. Northern Dauphin

County is characterized by low-density residential development. Southeastern Dauphin County

is characterized by medium-density residential development. Southwestern Dauphin County

and Harrisburg are characterized by high-density mixed urban development (Dauphin County

2008).

Throughout the county, non-residential development occurs in a scattered fashion adjacent to

roadways. The greatest concentration of non-residential development occurs between the city of

Harrisburg and Derry Township, adjacent to U.S. Routes 83, 322, and 422. Limited

non-residential land use has occurred on limited access intersections of Interstates 81 and 83

and the Pennsylvania Turnpike. The portions of the county located in the heart of the

Susquehanna Valley contain the majority of agricultural activity. The northeastern tier of the

county is mountainous and forested (Dauphin County 2008).

The Land Needs Concept forecasts land use needs by considering regional population growth

trends, employment needs resulting from population growth, and real estate market projections.

Previously, most planning did not take this picture into account and relied solely on population

projections. The future land use map identifies land needed to accommodate population

projections through 2020. All other land is designated as Rural Reserve/Agriculture for future

evaluation and use (Dauphin County 2008).

Lancaster County

Lancaster County is approximately 949 mi 2 (2458 km 2), nearly twice the size of Dauphin County

in acreage and population, and has 60 municipalities (USCB 2008b). Farming plays a major role

in Lancaster County, and land use planning focuses on preservation of agricultural areas.

Farmland presently occupies 69 percent of the available land area in the county. Lancaster

County and Municipal Planners are concerned about preserving the farming culture and

heritage of the county, especially that of the Amish. Tourists visiting these areas add $1.6 billion

annually to the county's economy.

In 1993, the county adopted a Growth Management element to its Comprehensive Plan. Future

growth would be directed to Designated Growth Areas (similar to Dauphin County's Planned

Growth Areas) or areas already impacted by development to emphasize reinvestment in

previously developed areas. The plan defined two types of growth areas as Urban Growth

Areas and*Village Growth Areas to manage future land use in the county (Lancaster County

2006). The growth areas have defined boundaries around a city, borough, or village, and

include developed portions of surrounding townships and enough buildable land to meet future

land use needs over a 20-year period. Since 1993, 39 growth areas have been established in

June 2009 2-55 NUREG-1437, Supplement 37
Affected Environment

Lancaster County. Between 1994 and 2002, residential land use outside Designated Growth

Areas occurred at a net density of 0.8 dwellings per acre, while growth inside Designated

Growth Areas occurred at a net density of 5.5 dwellings per acre (Lancaster County 2006).

Currently, the largest residential, commercial and industrial development concentrations are

found in the City of Lancaster and surrounding areas. Development can also be found along

major road corridors heading north and northwest (Interstate 76, U.S. 30, U.S. 222, and PA 283)

through the county (Lancaster County 2006).

The Lancaster County Planning Commission is updating the Growth Management Plan element

of the Lancaster County Comprehensive Plan. The update will plan for growth throughout the

county through 2030, and it will be guided by the Policy Element of the Comprehensive Plan.

The growth management plan will:

* Examine current and projected growth patterns and infrastructure needs

* Review urban and village growth areas

* Address issues of concern within rural areas

* Provide recommendations to achieve sustainable growth that balances development

with the preservation of farmland and open space.

2.2.8.4 Visual Aesthetics and Noise

TMI-1 is located on an island in the middle of the The EPA geneiaily uses 55

Susquehanna River. TMI-1 as a whole can be seen from

the river, but is shielded on the land side for the most thaesh level noidring

part by surrounding vegetation due to its position along out activities However,

the river in the Susquehanna River Valley. The cooling according to the EPA, this

towers, turbine buildings, and reactor containment threshold does "not*constitute

structures dominate the site's landscape and can be a sandard, specification, or

seen from the Susquehanna River. regilatjon," but was intended

With natural draft cooling towers, the most obvious to provide a basis for state

aesthetic impact is the visible plume in the sky. The and local govenments

plumes are most persistent under certain meteorological stablhingnoise standards

conditions when the capacity for the atmosphere to hold (EPA 1974).

additional water vapor is lowest. This occurs when

relative humidity is high or air temperatures are low. Observations of cooling towers in the same

region suggest that under certain meteorological conditions the visible plume could extend 1-2

mi (1.6-3.2 km) (AEC 1972).

Noise from TMI-1 can be detected offsite. Sources of noise from station operation include the

cooling towers, turbines, and large pumps and cooling water system motors. Given the industrial

nature of the station, noise emissions from the station are generally nothing more than an

intermittent minor nuisance. Noise levels may sometimes exceed the 55 dBA level that the EPA

uses as a threshold level to protect against excess noise during outdoor activities. However,

according to the EPA this threshold does "not constitute a standard, specification, or regulation,"

NUREG-1437, Supplement 37 2-56 June 2009
Affected Environment

but was intended to provide a basis for State and local governments establishing noise

standards.

2.2.8.5 Demography

According to the 2000 Census, approximately 787,800 people lived within 20 mi (32 km) of TMI1, which equates to a population density of 627 persons per square mile (AmerGen 2008). This

density translates to the least sparse Category 4 density level (greater than or equal to 120

persons per square mile within 20 mi). Approximately 2,546,500 people live within 50 mi (80 km)

of TMI-1 (AmerGen 2008). This equates to a population density of 325 persons per square mile.

Applying the GElS proximity measures, TMI-1 is classified as proximity Category 4 (greater than

or equal to 190 persons per square mile within 50 mi). Therefore, according to the sparseness

and proximity matrix presented in the GElS, TMI-1 rankings of sparseness Category 4 and

proximity Category 4 result in the conclusion that TMI-1 is located in a high population area.

Table 2-11 shows population projections and growth rates from 1970 to 2050 in Dauphin and

Lancaster counties. The growth rate in Dauphin County showed an increase of 5.9 percent for

the period of 1990 to 2000. County populations are expected to continue to grow in both

counties in the next decades although Lancaster County's population is expected to increase at

a higher rate through 2050.

Table 2-11. Population and Percent Growth in Dauphin County and Lancaster

County, Pennsylvania, from 1970 to 2000, and Projected for 2010 and 2050

Year Dauphin Lancaster

Percent Percent

Population Growth(a) Population Growth(a)

1970 223,834 - 319,693 -

1980 232,317 3.8 362,346 13.3

1990 237,813 2.4 422,822 16.7

2000 251,798 5.9 470,658 11.3

2006 254,176 0.9 494,486 5.1

2010 256,478 1.9 499,261 6.1

2020 263,198 2.6 527,486 5.7

2030 270,543 2.8 554,611 5.1

2040 279,024 3.2 591,901 6.7

2050 286,710 2.7 623,536 5.3

- No data available.

(a) Percent growth rate is calculated over the previous decade.

Sources: Population data for 1970-2000 (USCB 2008a); population data

for 2006 (estimated) 2006 American Community Survey; population

projections for 2010- 2030 by Pennsylvania State Data Center, February

2008; population projections for 2040 and 2050 (calculated)

June 2009 2-57 NUREG-1437, Supplement 37
Affected Environment

The 2000 and 2006 (estimate) demographic profiles of the two-county region of influence

population are presented in Table 2-12 and Table 2-13. In 2000, minority individuals (both race

and ethnicity) comprised 15.5 percent of the total two-county population. The minority

population was comprised largely of Black or African American and Hispanic or Latino residents.

Table 2-12. Demographic Profile of the Population in the TMI-1 Two-County

Socioeconomic Region of Influence in 2000

Region of

Dauphin Lancaster Influence

Total Population 251,798 470,658 722,456

Race (percent of total population, not Hispanic or Latino)

White 75.6 89.3 84.5

Black or African American 16.6 2.5 7.4

American Indian and Alaska Native 0.1 0.1 0.1

Asian 1.9 1.4 1.6

Native Hawaiian and Other Pacific Islander 0.0 0.0 0.0

Some other race 0.1 0.1 0.1

Two or more races 1.5 0.8 1.1

Ethnicity

Hispanic or Latino 10,404 26,742 37,146

Percent of total population 4.1 5.7 5.1

Minority Population (including Hispanic or Latino ethnicity)

Total minority population 61,451 50,292 111,743

Percent minority 24.4 10.7 15.5

Source: USCB 2008a

According to the U.S. Census Bureau's 2006 American Community Survey, minority populations

in the two-county region were estimated to have increased by nearly 17,000 persons and

comprised 17.2 percent of the total two-county population in 2006 (see Table 2-13). The largest

increases in minority populations were estimated to occur in Hispanic or Latino and Asian

populations. The Black or African American population increased by approximately 9.4 percent

from 2000 to 2006, but remained relatively unchanged as a percentage of the total four-county

population.

NUREG-1437, Supplement 37 2-58 June 2009
Affected Environment

Table 2-13. Demographic Profile of the Population in the TMI-1 Two-County

Socioeconomic Region of Influence in 2006 (Estimate)

Region of

Dauphin Lancaster Influence

Total Population 254,176 494,486 748,662

Race (percent of total population, not-Hispanic or Latino)

White 73.5 87.6 82.8

Black or African American 17.2 3.0 7.8

American Indian andAlaska Native 0.2 0.1 0.1

Asian 2.4 1.5 1.8

Native Hawaiian and Other Pacific Islander 0.0 0.0 0.0

Some other race 0.1 0.2 0.2

Two or more races 1.5 0.9 1.1

Ethnicity

Hispanic or Latino 12,910 32,894 45,804

Percent of total population 5.1 6.7 6.1

Minority Population (including Hispanic or Latino ethnicity)

Total minority population 67,434 61,435 128,869

Percent minority 26.5 12.4 .17.2

Source: USCB 2008a

Transient Population

Within 50 mi (80 km) of TMI-1, colleges and recreational opportunities attract daily and seasonal

visitors who create demand for temporary housing and services. In 2007, there were

approximately 63,000 students attending colleges and universities within 50 mi (80 kin) of TMI-1

(IES 2008).

In 2000 in Dauphin County, 0.5 percent of all housing units were considered temporary housing

for seasonal, recreational, or occasional use. By comparison, seasonal housing accounted for

0.4 percent and 2.8 percent of total housing units in Lancaster County and Pennsylvania,

respectively (USCB 2008). Table 2-14 provides information on seasonal housing located within

50 mi of TMI-1.

Table 2-14. Seasonal Housing in Counties

County (a)

Pennsylvania

Adams

Berks

Chester

Columbia

Cumberland

Dauphin

Franklin

June 2009

Housing units

5,249,750

35,831

150,222

163,773

27,733

86,951

111,133

53,803

Located within 50 Miles of TMI-1

Vacant housing units: For

seasonal, recreational, or

occasional use P

148,230 2.

672 1.

744 0.

571 0.

1,304 4.

379 0.

570 0.

572 1.

ercent

.8

9

5

3

7

4

5

1

2-59 NUREG-1 437, Supplement 37
Affected Environment

Vacant housing units: For

seasonal, recreational, or

County (a) Housing units occasional use Percent

Juniata 10,031 945 9.4

Lancaster 179,990 808 0.4

Lebanon 49,320 458 0.9

Mifflin 20,745 1,082 5.2

Northumberland 43,164 246 0.6

Perry 18,941 1,270 6.7

Schuylkill 67,806 865 1.3

Snyder 14,890 495 3.3

York 156,720 946 0.6

County Subtotal 1,191,053 11,927 2.4 (avg.)

Maryland 2,145,283 38,880 1.8

Baltimore 313,734 1,212 0.4

Carroll 54,260 117 0.2

Cecil 34,461 1,410 4.1

Frederick 73,017 284 0.4

Harford 83,146 299 0.4

Washington 52,972 468 0.9

County Subtotal 611,590 3,790 1.1 (avg.)

County Total 1,802,643 15,717 2.0 (avg.)

USCB 2008

(a) Counties within 50 mi (80 km) of TMI-1 with at least one block group located within the 50-mile radius

avg. = percent average for counties within the TMI-1 50-mile radius and excludes State percentage

Migqrant Farm Workers

Migrant farm workers are individuals whose employment requires travel to harvest agricultural

crops. These workers may or may not have a permanent residence. Some migrant workers may

follow the harvesting of crops, particularly fruit, throughout the northeastern U.S. rural areas.

Others may be permanent residents near TMI-1 who travel from farm to farm harvesting crops.

Migrant workers may be members of minority or low-income populations. Because they travel

and can spend a significant amount of time in an area without being residents, migrant workers

may be unavailable for counting by census takers. If uncounted, these workers would be

-"underrepresented" in USCB minority and low-income population counts.

Information on migrant farm and temporary labor was collected in the 2002 Census of

Agriculture. Table 2-15 provides information on migrant farm workers and temporary farm labor

(less than 150 days) within 50 mi (80 kin) of TMI-1. According to the 2002 Census of

Agriculture, approximately 25,000 farm workers were hired to work for less than 150 days and

were employed on 5,800 farms within 50 mi (80 km) of TMI-1. The county with the largest

number of temporary farm workers (5,841 workers on 1,627 farms) was Lancaster County,

Pennsylvania.

NUREG-1437, Supplement 37 2-60 June 2009
Affected Environment

In the 2002 Census of Agriculture, farm operators were asked for the first time whether any

hired migrant workers, defined as a farm worker whose employment required travel that

prevented the migrant worker from returning to their permanent place of residence on the same

day. A total of 648 farms in the 50-mile radius of TMI-1 reported hiring migrant workers. Chester

County reported the most farms (158) with hired migrant workers, followed by Lancaster County

(126). By comparison, the 10 farms in Dauphin County host relatively small numbers of migrant

workers. According to 2002 Census of Agriculture estimates, 425 temporary farm laborers

(those working fewer than 150 days per year) were employed on 147 farms in Dauphin County,

and as previously discussed 5,841 temporary farm workers were employed on 1,627 farms in

Lancaster County (USDA 2002 Census of Agriculture).

Table 2-15. Migrant Farm Worker and Temporary Farm Labor in Counties Located

within 50 Miles of TMI-1

County(a)

Pennsylvania

Adams

Berks

Chester

Columbia

Cumberland

Dauphin

Franklin

Juniata

Lancaster

Lebanon

Mifflin

Northumberland

Perry

Schuylkill

Snyder

York

County Subtotal

Number of farm

workers working for

less than 150 days

13,512

293

549

710

252

189

194

482

172

1,976

325

250

204

150

173

242

404

6,565

3,321

273

244

162

294

148

188

1,309

7,874

Number of farms

hiring workers for

less than 150 days

10,232

211

383

494

196

130

147

342

158

1,627

180

106

156

112

128

189

327

4,886

2,453

201

169

123

223

101

129

946

5,832

Number of farms

reporting migrant

farm labor

41,606

2,437

2,128

2,470

1,408

420

425

1,819

304

5,841

547

249

595

392

556

534

1,104

21,229

10,551

762

414

713

1,269

406

443

4,007

25,236

Number of farms

with hired farm

labor

745

88

28

158

8

4

10

27

2

126

6

1

27

7

10

16

23

541

212

47

6

7

17

26

4

107

648

Maryland

Baltimore

Carroll

Cecil

Frederick

Harford

Washington

County Subtotal

County Total

(a)Counties within 50 mi (80 km) of TMI-1 with at least one block group located within the 50-mi (80-km) radius

2002 Census of Agriculture - County Data; Table 7. Hired Farm Labor - Workers and Payroll: 2002

June 2009 2-61 NUREG-1437, Supplement 37
Affected Environment

2.2.8.6 Economy

This section contains a discussion of the economy, including employment and income,

unemployment, and taxes.

Employment and Income

Between 2000 and 2006, the civilian labor force in Dauphin County increased 6 percent from

128,611 to 136,359. During the same time period, the civilian labor force in Lancaster County

grew by nearly the same percentage (5.8 percent) (USCB 2008a).

In 2006, educational services, health care and social assistance represented the largest sector

of employment in the two-county region followed closely by manufacturing and retail trade

industry. The educational services, health care, and social assistance sector employed the most

people in Dauphin County, followed by the retail trade and public administration sectors. A list of

some of the major employers in Dauphin County in 2007 is provided in Table 2-16. As shown in

the table, the largest private employer in Dauphin County was Hershey Foods Corporation.

Table 2-16. Major Employers in Dauphin County in 2007

Name Name

Pennsylvania State Government

Milton S Hershey

Hershey Foods Corporation

HERCO Inc./ Hershey Entertainment and Resorts

Pinnacle Health System

Federal Government

Pennsylvania Higher Education Assistance Agency

Tyco Electronics Corporation

Central Dauphin School District

United Parcel Service

Pennsylvania State University

Capital Blue Cross

Harrisburg Area Community College

Dauphin County Government

Milton S Hershey School and School Trust

Harrisburg School District

Giant Food Stores LLC

Wal-Mart Associates Inc.

Keystone Service Systems Inc.

Nationwide Mutual Insurance Company

United Concordia Companies Inc.

Diocese of Harrisburg

DST Health Solutions Services

City of Harrisburg

ArcelorMittal Steelton LLC

D & H Distributing Company

Derry Township School District

ENERFAB Inc.

Lower Dauphin School District

C & S Wholesale Grocers

Center for Workforce Information and Analysis 2008

Income information for the TMI-1 region of influence is presented in Table 2-17. In 1999, the

date of the last economic census, the two counties each had median household incomes above

the Pennsylvania Commonwealth average. Per capita income, with the exception of Lancaster

County, was also above the average for all of Pennsylvania. In 1999, only 7.8 percent of the

population in Lancaster County was living below the official poverty level, while in Dauphin

County and the Commonwealth of Pennsylvania, 9.7 and 11 percent of the respective

populations were living below poverty level. The percentage of families living below the poverty

level was about the same for Dauphin County and Pennsylvania as a whole. Lancaster County

had a smaller percentage of families living below the poverty level (USCB 2008a).

NUREG-1437, Supplement 37 2-62 June 2009
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Table 2-17. Income Information for the TMI-1 Socioeconomic Region of Influence

Dauphin Lancaster Pennsylvania

Median household income 1999 (dollars) 41,507 45,507 40,106

Per capita income 1999 (dollars) 22,134 20,398 20,880

Percent of families living below the poverty level (2000) 7.5 5.3 7.8

Percent of individuals living below the poverty level (2000) 1 9.7 7.8 11.0

USCB 2008

Unemployment

In 2006, the annual unemployment averages in Dauphin and Lancaster Counties were 4.8 and

3.6 percent,. respectively, which were lower than the annual unemployment average of 6.2

percent for the Commonwealth of Pennsylvania (USCB 2008a).

Taxes

Currently, Exelon Generation pays annual property taxes on TMI-1 to Dauphin County,

Londonderry Township, and the Lower Dauphin School District. Prior to 2000, real estate taxes

were paid to the Commonwealth of Pennsylvania for power generation, transmission, and

distribution facilities. During that time, under authority of the Pennsylvania Utility Realty Tax Act

(PURTA), real estate taxes collected from all utilities (water, telephone, electric, and railroads)

were redistributed to the taxing jurisdictions within the Commonwealth. In Pennsylvania, these

jurisdictions included counties, cities, townships, boroughs, and school districts. The distribution

of PURTA funds was determined by formula, and was not necessarily based on the individual

utility's effect on a particular government entity.

Under 1999 Amendments to PURTA, the assessment methodology for utilities was revised from

the depreciated book value to the market value of utility property. Additionally, as of January 1,

2000, the owners of TMI-1 were required to begin paying real estate taxes directly to local

jurisdictions, ceasing payments to the Commonwealth's PURTA fund. Accordingly, since that

time, the owner of TMI-1 has periodically negotiated with local taxing jurisdictions regarding

market value assessments of the station and the amount of taxes that will be paid.

While maintaining open appeals of the assessments from 1998 through 2002, Exelon

Generation and the previous owners of TMI -1 entered into a Stipulation and Interim Settlement

agreement with the taxing authorities, dated December 22, 2000 (2000 Stipulation). Under the

2000 Stipulation, Exelon Generation paid Dauphin County approximately $146,900 annually in

property taxes from 2000 through 2004. These payments represented approximately 0.2 to 0.3

percent of Dauphin County's total property tax revenues for that time period (see Table 2-18 on

the following page).

Also from 2000 through 2004 under the 2000 Stipulation, Exelon Generation paid property taxes

annually to Londonderry Township and Lower Dauphin School District in the amounts of

$30,000 and $394,500, respectively. These payments represented approximately 0.5 to 0.7

percent of Londonderry Township's total property tax revenues and approximately 2.1 to 2.9

percent of total property tax revenues for the Lower Dauphin School District (see Table 2-18 on

the following page).

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I In 2005, Exelon Generation and PECO signed a settlement with the local taxing bodies (the

2005 Settlement) that both acknowledged the 1999 PURTA Amendments' change in the way

TMI-I's value would be assessed and reported a corresponding reduction in assessed value.

I As a result, the 2005 Settlement slightly decreased Exelon Generation's property tax payments

to Dauphin County, Londonderry Township, and the Lower Dauphin School District in

I comparison with payments made under the 2000 Stipulation. For 2005, Exelon Generation's

property tax payments represented approximately 0.2 percent of Dauphin County's total

property tax revenues, and approximately 1.7 percent of the Lower Dauphin School District's

total property tax revenues (see Table 2-18).

From 2000 to 2005, Exelon Generation's annual property tax payments to both Dauphin County

and Londonderry Township for TMI-1 represented less than 1 percent of each of their total

property tax revenues. Annual property tax payments to the Lower Dauphin School District

during the same time period represented an average of approximately 2.4 percent of the school

district's total property tax revenues (see Table 2-18).

In July of 2008, Exelon Generation negotiated a new agreement with the,three taxing entities

(2008 Agreement) which provides for an increase in the property taxes Exelon Generation

currently pays. The 2008 Agreement obligates Exelon Generation to pay a total of $930,000 to

the Lower Dauphin School District, Dauphin County and Londonderry Township. Annually, the

school district will receive $637,000, the county will receive $254,634, and the township will

receive $37,665. These payments will begin in 2008 and continue through 2017.

Dauphin County property taxes are used to pay for county operations, the judicial system, public

safety, public works, cultural and recreational programs, human services and conservation and

development programs. Londonderry Township property taxes pay the operating costs for

libraries, hospitals, roads, school districts, and fire departments. The continued availability of

TMI-1 and the associated tax base is an important feature in the ability of the Dauphin County

and Londonderry Township to continue to invest in infrastructure and to draw industry and new

residents.

Table 2-18. TMI-1 Property Tax Paid and Percentage of Dauphin County,

Londonderry Township, and the Lower Dauphin School District from

Property Tax Revenues, 2000 to 2005

Property Tax

Total Property Tax Paid by Exelon

Revenue Generation Percent of

Entity Year (millions of dollars) (thousands of dollars) Total Revenue

Dauphin County 2000 58.0 146.9 0.3

2001 60.1 146.9 0.2

2002 60.5 146.9 0.2

2003 61.5 146.9 0.2

2004 73.9 146.9 0.2

2005 89.3 141.6 0.2

NUREG-1437, Supplement 37 2-64 June 2009
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Property Tax

Total Property Tax Paid by Exelon

Revenue Generation Percent of

Entity Year (millions of dollars) (thousands of dollars) Total Revenue

Londonderry 2000 4.0 30.0 0.7

Township 2001 4.8 30.0 0.6

2002 5.1 30.0 0.6

2003 5.6 30.0 0.5

2004 6.3 30.0 0.5

2005 6.4 21.0 0.3

Lower Dauphin 2000 13.8 394.5 2.9

School District 2001 14.1 394.5 2.8

2002 15.8 394.5 2.5

2003 17.5 394.5 2.3

2004 18.6 394.5 2.1

2005 20.1 343.0 1.7

Source: AmerGen 2008

2.2.9 Historic and Archaeological Resources

This section discusses the cultural background and the known historic and archaeological

resources at the site of TMI-1 and in the surrounding area.

2.2.9.1 Cultural Background

The region around TMI-1, located on the northern end of Three Mile Island, contains prehistoric

and historic Native American and Euro-American cultural resources. Three Mile Island was

formed as a result of water deposited sands and gravels resting on deposits of sedimentary

sandstones, siltstones, and clays (Smith 1977). TMI-1 lies within the Gettysburg Section of the

Piedmont physiographic province, which is characterized by rolling low hills and valleys (DCNR

2008a). The Piedmont region contains some of the most agriculturally productive land in

Pennsylvania both currently and historically, and is a favored area of settlement (Raber 1985).

There are 369 properties in Dauphin, York, and Lancaster counties that are listed on the

National Register of Historic Places (NRHP), and 19 properties are located within 6 mi (10 kin)

of TMI-1 (USDOI 2008). No NRHP listed properties are affected by operation of TMI-1. PaleoIndians occupied North America approximately 15,000-10,000 years ago, subsisting on hunted

game and gathered plant material. In the Pennsylvania area, Paleo-lndians migrated into an

environment changed by retreating glacial ice. The climate in Pennsylvania at the time was

wetter and cooler than it is today. Large areas of grasslands mixed with coniferous and

deciduous forests were characteristic of the region (Raber 1985). Paleo-Indian populations were

highly mobile and hunted large animals such as mastodons, bison, caribou, mammoths, horse,

deer, giant beaver, moose, and elk (Raber 1985; Funk 1972). The primary artifact associated

with the Paleo-lndian period is the Clovis point, a distinctive, fluted, lanceolate point that is

June 2009 2-65 NUREG-1437, Supplement 37
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widely distributed throughout Pennsylvania, especially in the Susquehanna and Delaware River

valleys (AmerGen 2008). Regional studies indicate that there is a high probability for Clovis

points to be found in the Susquehanna River Valley (Kent et al. 1971). Other tools commonly

found at Pennsylvania Paleo-lndian sites include scrapers; spurred-end scrapers; drills; cores;

bifaces; microblades; and small uniface, biface, and flake knives (AmerGen 2008).

During the Archaic Period, from approximately 10,000 years ago until about 3,000 years ago,

subsistence strategies underwent changes to adapt to resource availability. As the glaciers

retreated northward and larger animals disappeared from the region, humans adapted to exploit

modern plants and smaller game animals. Like Paleo-lndians, early Archaic foragers were

highly mobile (Carr 1998). As resource quality and the cultural means to access resources

improved, archaeologists find evidence of larger populations by the end of the Archaic Period, a

time when climate reached its modern condition. As a result of diversification of prey species, a

shift in the design of hunting technology occurred. Prehistoric megafauna were replaced by

deer, elk, bear, turkey and other species common to deciduous forests (Raber 1985). Projectile

points also changed to smaller, barbed points (Raber 1985). Archaic people collected, hunted,

and gathered most of what they needed for survival in their home territory. Large base camps

found near major water sources provided a focal point for groups during the winter months.

During this period, Archaic peoples developed well-defined seasonal foraging activities.

The "Woodland" culture existed from 3,000 years ago until European contact around 1,500 A.D.

This period is defined by the introduction of horticulture to augment subsistence hunting and

gathering. A reliance on agriculture led to the establishment of more permanent settlements

during this period. The earliest evidence of agriculture in Pennsylvania was found at the

Meadowcroft rock shelter where evidence of squash and maize (corn) appear in the

archaeological record (Adovasio and Johnson 1981). Other characteristics of Woodland culture

include an increase in population, the emergence of social hierarchy, expanded interregional

trade, more elaborate burial rituals, the introduction of the bow and arrow, and the use of

ceramics for storage and cooking (Cowin 1985).

The area around TMI-1 was home to a number of prehistoric populations. Evidence from

archaeological sites in the region reflect the influences of Laurentian, Lamoka, Piedmont and

later Hopewell cultural traditions (AmerGen 2008). Native Americans used the Susquehanna

River and several overland paths and trails as their primary transportation routes. Native

American societies in the region shared several important characteristics at the time of first

contact with Europeans. These characteristics included an economic base that combined

hunting and gathering with domesticated plants and an annual settlement pattern that varied in

population size between semi-permanent river-side villages in summer, large camps in winter,

and population dispersal among scattered camps in the spring and fall.

In the 1600s, Europeans came to the Pennsylvania area and came into contact with Late

Woodland peoples known as the Delaware, Shawnee, Iroquois, and Susquehannock (AmerGen

2008). The Susquehannocks were an Iroquoian-speaking tribe that lived along the

Susquehanna River in Pennsylvania and Maryland (PGA Undated). Living in Algonkianspeaking tribes' territory, they engaged in many wars (AmerGen 2008). The Susquehannocks

lived about 20 miles downstream from Three Mile Island in a town called Sasquesahanaugh,

located on the eastern side of the Susquehanna River at Washington Boro (AEC 1972).

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Susquehannock populations were reduced by diseases brought by Europeans and by attacks

from Marylanders and the Iroquois. By 1675, the Susquehannocks ceased to exist as a Nation

(PGA Undated).

The rise of nation-states in Europe coincided with European land acquisition in North America.

Wars in southern Germany caused many Germans to migrate to Pennsylvania. The struggle for

religious freedom in England brought Quakers, Puritans, and Catholics to Pennsylvania (PHMC

Undated-a). Captain John Smith was the first European to explore the region. In 1608, Smith

journeyed from Virginia up the Susquehanna River and made contact with the Susquehannock

Indians. Around this time, Henry Hudson's voyages document the relations between the

European settlers and the Indian Nations occupying Pennsylvania (Raber 1985). Between" 1609

and 1681, the Dutch, Swedes, and English inhabited and fought over the region which would

later become eastern Pennsylvania. Ultimately, the English prevailed in Pennsylvania and the,

area fell under English rule (PHMC Undated-a). The effects of European contact upon Indian

populations included death due to disease, increased intergroup warfare, and a dependence on

European goods (Jennings 1968).

William Penn, a member of the Society of Friends, also known as Quakers, a persecuted

religious sect in England petitioned the King of England for a haven in the New World. On

March 4, 1681, the King granted the petition and named the new colony in honor of William

Penn's father (PHMC Undated-a). Although William Penn was granted all of the land in

Pennsylvania, he and his heirs chose not to grant or settle any part of it without first buying the

claims of Native Americans who lived there. Most of Pennsylvania was purchased by 1768 and

the remaining portion was purchased by the Commonwealth by 1789 (PHMC Undated-a).

English, German, and Scotch-Irish immigrants eventually settled in the region.

As previously discussed, TMI-1 is located in Londonderry Township in Dauphin County.

Dauphin County was created on March 4, 1785, from part of Lancaster County, and it was

named for the French dauphin (prince), the king's eldest son (PHMC Undated-b). Harrisburg,

the county seat, was named for its founder John Harris, and was incorporated as a borough in

1791 and chartered as a city in 1810 (PHMC Undated-b). John Harris, a native of Yorkshire,

England, was one of the first emigrants to accompany William Penn (Harrisburg Websites

Undated). In 1705, Harris secured a license to obtain land and around 1718, settled in the

wilderness of what was to become Harrisburg (PHMC Undated-b). There are several islands

within Londonderry Township, one of which is Three Mile Island, formerly called Elliot's Island

and prior to that Conewago Island (Londonderry Township Undated).

Several historic canals were constructed on both sides of the Susquehanna River in the vicinity

of TMI-1. The nearest canal, Pennsylvania Canal's Eastern Division (Eastern Division Canal)

ran on the east side of the Susquehanna River for 43 mi (69 km) between Columbia, PA

(Lancaster County) and Duncan's Island at the mouth of the Juniata River north of Harrisburg

(Citizendium 2007). The Eastern Division Canal was originally owned and operated by the

Commonwealth of Pennsylvania. Due to the cost of maintaining the canal and competition from

railroads, the whole of Pennsylvania's Main Line canal system was sold to the Pennsylvania

Railroad (PRR) in the 1850s. The PRR operated the canal until 1901, when it was replaced by

the existing railroad, which is built on top of the old canal. Later, railroads became the

predominant mode of freight transportation which resulted in the abandonment of the canals.

June 2009 2-67 NUREG-1437, Supplement 37
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2.2.9.2 Historic and Archaeological Resources

The islands in the Susquehanna River Valley were heavily utilized by prehistoric and historic

native populations, as well as European immigrants. Three Mile Island was first purchased in

1749 by Thomas Cookson who served as Thomas Penn's Deputy Surveyor for Lancaster

County (Huber 1982). The island was passed down through Cookson's extended family and

sold to James Duffy in 1879 (Huber 1982). Duffy's son rebuilt and transformed an existing farm

on the island into a tobacco producing station (Huber 1982). In 1904, ice and elevated levels of

water from the winter thaw flooded the island and ruined Duffy's tobacco station. Duffy

unknowingly sold the island to the York Haven Water and Power Company, which in turn sold

the land to Metropolitan Edison in 1924 (Huber 1982). Between 1957 and the start of

construction, 270 acres on Three Mile Island were leased for farming (AEC 1972). At the time,

there was no access to the island by bridge, so equipment and produce were transported by

barge. In addition to farming, there were 70 cabins on the island that were also leased (53 on

the west side and 17 on the east side), along with a picnic area, a boat dock, and a well for

drinking water (AEC 1972).

A search of the PHMC site file records identified nine prehistoric sites and one historic site on

Three Mile Island. One additional historic site was identified on the island during NRC's

walkover survey. Of the nine previously recorded sites, two sites (36Da51 and 36Da98) are not

associated with any cultural period. Sites 36Da96, 36Da97, 36Da99, and 36Da100 contain

material from Late Archaic to the Late Woodland period. Dates for these sites were based upon

collected lithics, points, and pottery. Site 36Da96 was situated in a cultivated area near TMI-1

and TMI Unit 2 and was assigned a cultural designation of Late Archaic to Early Woodland. It is

unclear if any portions of the 36Da96 site remain. Site 36Da97 was also located where TMI-1

and TMI Unit 2 are currently situated. The site form indicates that Woodland pottery was

collected; however, no examples were available for study. Site 36Da97 was destroyed by

construction of TMI-1 and TMI Unit 2. Sites 36Da99 and 36Da100 are large multi-component

campsites. On their respective site forms, 36Da99 is listed as Late Archaic and 36Da100 as a

Late Woodland site.

Site 36Da52 is also listed as primarily an Archaic site, but some Woodland components were

also recovered there. This site was recorded by the William Penn Memorial Museum in 1967

(now known as the* State Museum of Pennsylvania) perhaps as part of Ira Smith's salvage

excavation. It is unclear whether or not Site 36Da52 was destroyed during the construction of

TMI-1 and TMI Unit 2.

In 1967, prior to construction of TMI-1 and TMI Unit 2, a cultural resource study was conducted

by the Pennsylvania Historical and Museum Commission (PHMC) (AEC 1972). Five areas of

the island were tested, and one multi-component site (36Da50) was selected as the most likely

candidate to yield information about the island's cultural sequence. The site was excavated and

yielded a rich inventory of lithic and ceramic information dating to the Early and Middle

Woodland periods. The types and quantities of lithic and ceramic artifacts recovered suggests

that Three Mile Island was intermittently occupied by small groups of Early and Middle

Woodland peoples utilizing the area for hunting and fishing (Smith 1977). At the time, 36Da50

was the largest Early to Middle Woodland site excavated in the Lower Susquehanna River

Valley of Pennsylvania. Previous research in the area had primarily focused on small campsites

NUREG-1437, Supplement 37 2-68 June 2009
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and rock shelters. In total, eight different ceramic types were recovered from the island along

with eight categories of projectile points, ten types of flake tools,and four classes of bifacials

and cleavers (Smith 1977). This suggests that Three Mile Island was used for securing and

processing food (Smith 1977). In total, more than 1,000 artifacts were recovered spanning from

4,000 B.C. to 1,000-plus A.D.

In 1987, a paper was presented by two archaeologists at the Mid Atlantic Archaeological

Conference Annual Meeting in Lancaster Pennsylvania for archaeological work conducted at

Three Mile Island. The paper defined the cultural occupations of the island based on examining

artifacts gathered by local collectors, reviewing previous archaeological reports, and performing

limited testing on the island. Research and fieldwork (completed in 1986) indicated that the

earliest occupation of Three Mile Island was during the Early Archaic period. Additionally, Early,

Middle, and Late Woodland periods are also well represented. The continuous use of the island

is surprising because experts believed that Late Woodland sites are comparatively infrequent on

islands. To date, no Paleo-lndian artifacts have been found. While Three Mile Island was used

continuously over the last 12,000 years, much of the cultural data, stratigraphy, and features

relating to prehistoric occupations remain to be investigated (AmerGen 2008).

In 1988, the Curator of Archaeology from the State Museum of Pennsylvania performed an

excavation of an historical burial site (36Da101) discovered eroding out of the river bank by a

TMI-1 employee (Warfel 1988). According to PHMC survey records, 36Da101 is a large site that

borders the riverbank and contains both Late Archaic and Late Woodland period artifacts in

addition to the historic artifacts recovered during Warfel's excavation. As previously discussed,

the island was extensively farmed in the 1 8 th and 1 9 th centuries (Warfel 1988). Residents of the

island built houses, barns, and other structures. Records verify that children were born and

adults died on the island, so the likelihood of additional burials is high (Warfel 1988).

Fragmentary remains were collected and analysis of the bones and artifacts determined the

burial dates to be in the 1860s-1880s time period and the bones to have originated from an

adult male aged 50-plus years (Warfel 1988). The remains were collected and later reburied in a

location near the original burial site. Artifacts associated with the burial were donated to the

State Museum of Pennsylvania (AmerGen2008).

Another archaeological survey was conducted in 1998 for a proposed fish passage to be

located on the east side of Three Mile Island. Previous research indicated that site 36Da51 was

located in the vicinity of the project. PHMC records for 36Da51 did not indicate site type or

cultural affiliation. Test units from the survey yielded some lithic flakes, fire-cracked rock, two

pottery shards, and some historic artifacts. Analyses of the materials recovered indicated that

further testing was not warranted. The portion of site 36Da51 that would be impacted by the

proposed fish ladder did not meet any of the criteria for listing on the National Register of

Historic Places.

As noted earlier, during the walkover survey of Three Mile Island an additional historic site was

identified. Remnants of an historic farmstead were found in the woods. This farmstead is a large

complex complete with foundations for approximately 10 buildings (possibly a house, barns, and

other outbuildings). There is also a standing silo made from ceramic bricks. Further examination

of the silo revealed manufacturing information at the base of the structure indicating that it was a

NATCO Imperishable Silo, patented by the National Fire Proofing Company of Pittsburgh,

Pennsylvania. The National Fire Proofing Company was purportedly established in 1889;

June 2009 2-69 NUREG-1437, Supplement 37
Affected Environment

however, financial records put the date of establishment closer to 1902 (University of Melbourne

Undated). NATCO's imperishable silo is constructed of curved, hollowed blocks in which the

courses are staggered (University of Melbourne Undated). This dates the silo to the first quarter

of the 2 0 ' century. As a result of this discovery, Exelon Generation submitted a Pennsylvania

Archaeological Site Survey Form along with photographs to the PHMC and the site was

assigned State number 36Da235.

Another potential historic site on Three Mile Island is TMI Unit 2. On March 28, 1979, TMI Unit 2

experienced a loss of coolant accident that resulted in a partial core meltdown, and is

considered the nation's worst commercial nuclear accident (Walker 2004). Although the

structure is under 40 years of age, it can be considered potentially eligible for listing on the

National Register of Historic Places under Criterion A, as a site of exceptional importance. In

1999, a historical marker was placed on Pennsylvania State Highway 441, commemorating the

20th anniversary of the TMI Unit 2 accident (AmerGen 2008).

2.3 Related Federal and State Activities

The NRC staff reviewed the possibility that activities of other Federal agencies might impact the

renewal of the operating license for TMI-1. Any such activity could result in cumulative

environmental impacts and the possible need for a Federal agency to become a cooperating

agency in the preparation of the TMI-1 supplemental EIS.

The NRC staff has determined that there are no Federal projects that would make it desirable

for another Federal agency to become a cooperating agency in the preparation of the

supplemental EIS. Federal facilities and National Parks within 50 mi (80 km) of TMI-1 are listed

below. There are no known American Indian lands within 50 mi (80 km) of TMI-1.

" Fort Indiantown Gap Military Reservation, Annville (closed)

• Blue Marsh Lake (U.S. Army Corps of Engineers)

" New Cumberland General Depot (U.S. Military Reservation)

* Mechanicsburg Naval Ship Parts Control Center

* Letterkenny Army Depot

* Gettysburg National Military Park

* Eisenhower National Historic Site

• Fort Ritchie Raven Rock Site

* U.S. Army Chemical Center

* Appalachian National Scenic Trail (various areas)

NRC is required under Section 102(2)(c) of the National Environmental Policy Act of 1969

(NEPA) to consult with and obtain the comments of any Federal agency that has jurisdiction by

law or special expertise with respect to any environmental impact involved. NRC has consulted

with the Advisory Council on Historic Preservation and the U.S. Fish and Wildlife Service.

Federal Agency consultation correspondence and comments on the supplemental EIS are

presented in Appendix D.

NUREG-1437, Supplement 37 2-70 June 2009
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2.4 References

10 CFR 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for Protection

Against Radiation."

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

Production and Utilization Facilities."

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

of Operating Licenses for Nuclear Power Plants."

10 CFR 61. Code of Federal Regulations, Title 10, Energy, Part 61, "Licensing Requirements for

Land Disposal of Radioactive Waste."

10 CFR 71. Code of Federal Regulations, Title 10, Energy, Part 71, "Packaging and

Transportation of Radioactive Material."

10 CFR 100. Code of Federal Regulations, Title 10, Energy, Part 100, "Reactor Site Criteria."

25 PA Code VII § 262. Pennsylvania Code, Title 25, Environmental Protection, Article VII,

Hazardous Waste Management, Section 262a, "Standards Applicable to Generators of

Hazardous Waste."

25 PA Code VIII. Pennsylvania Code, Tile 25, Environmental Protection, Article VIII, Municipal

Waste.

25 PA Code IX. Pennsylvania Code, Tile 25, Environmental Protection, Article IX, Residual

Waste.

40 CFR 81. Code of Federal Regulations, Title 40, Protection of Environment, Part 81,

"Designation of Areas for Air Quality Planning Purposes."

40 CFR 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190,

"Environmental Radiation Protection Standards for Nuclear Power Operations."

40 CFR Part 261. Code of Federal Regulations, Title 40, Protection of Environment, Part 261,

"Identification and Listing of Hazardous Waste."

40 CFR 262. Code of Federal Regulations. Title 40, Protection of Environment, Part 262,

"Standards Applicable to Generators of Hazardous Waste."

40 CFR 266. Code of Federal Regulations, Title 40, Protection of Environment,. Part 266,

"Storage, Treatment, Transportation, and Disposal of Mixed-Waste."

40 CFR Part 273. Code of Federal Regulations, Title 40, Protection of Environment, Part 273,

"Standards for Universal Waste Management."

72 FR 37346, U.S. Fish and Wildlife Service. "Endangered and threatened wildlife and plants;

removing the bald eagle in the lower 48 States from the list of endangered and threatened

wildlife." Federal Register Volume 72, No. 130, pp. 37346-37372. July 9, 2007.

Adovasio and Johnson (Adovasio, James and William C. Johnson). 1981. "The Appearance of

Cultigens in the Upper Ohio Valley: A View from Meadowcroft Rockshelter." Pennsylvania

Archaeologist. Vol. 51 (1-2): pp. 63-80.

June 2009 2-71 NUREG-1437, Supplement 37
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AEC (U.S. Atomic Energy Commission). 1972. Final Environmental Statement related to the

operation of Three Mile Island Nuclear Station, Units I and 2. Metropolitan Edison Company, et

al. Docket Nos. 50-289 and 50-320. Directorate of Licensing. December. Washington, D.C.

ADAMS No. ML080090250.

Alliance for the Chesapeake Bay. 2007. "Zebra Mussels Found in Pennsylvania Lake on

Cowanesque River Near NY." Chesapeake Bay Journal. (September 2007). Available URL:

http://www.baviournal.com/article.cfm?article=3149 (accessed June 12, 2008). ADAMS No.

ML082381094.

AmerGen (AmerGen Energy Company, LLC). 2004. Three Mile Island 2003 Annual Report,

Record of Well Pumpage and Water Levels. Susquehanna River Basin Commission Permit No.

19961102. Middletown, PA. ADAMS No. ML082880148.

AmerGen (AmerGen Energy Company, LLC). 2004a. Three Mile Island Nuclear Station Unit I

and Unit 2 Operating License No. DPR-50 and Possession Only License No. DPR 73 Docket

Nos. 50-289 and 50-320. Radiological Environmental Monitoring Program Report, 1 January

through 31 December 2003. Middletown, PA. ADAMS No. ML041250580.

AmerGen (AmerGen Energy Company, LLC). 2004b. Three Mile Island Nuclear Station Unit 1

and Unit 2 Operating License No. DPR-50 and Possession Only License No. DPR 73 Docket

Nos. 50-289 and 50-320. Combined 2003 Annual Radioactive Effluent Release Report.

Middletown, PA. ADAMS No. ML0411180052.

AmerGen (AmerGen Energy Company, LLC). 2005. Three Mile Island 2004 Annual Report,

Record of Well Pumpage and Water Levels. Susquehanna River Basin Commission Permit No.

19961102. Middletown, PA. ADAMS No. ML082880148.

AmerGen (AmerGen Energy Company, LLC). 2005a. Three Mile Island Nuclear Station Unit I

and Unit 2 Operating License No. DPR-50 and Possession Only License No. DPR 73 Docket

Nos. 50-289 and 50-320. Radiological Environmental Monitoring Program Report. 1 January

through 31 December 2004. Middletown, PA. ADAMS No. ML051260258.

AmerGen (AmerGen Energy Company, LLC). 2005b. Three Mile Island Nuclear Station Unit 1

and Unit 2 Operating License No. DPR-50 and Possession Only License No. DPR 73 Docket

Nos. 50-289 and 50-320. Combined 2004 Annual Radioactive Effluent Release Report.

Middletown, PA. ADAMS No. ML051260269.

AmerGen (AmerGen Energy Company, LLC). 2006. Annual Report on the Meteorological

Monitoring Program at the Three Mile Island Generating Station 2006. Middletown, PA. ADAMS

No. ML082110253.

AmerGen (AmerGen Energy Company, LLC). 2006a. Three Mile Island Nuclear Station Unit-1

and Unit-2 Operating License No. DPR-50 and Possession Only License No. DPR 73 Docket

Nos. 50-289 and 50-320. Updated Final Safety Analysis Report. Middletown, PA. ADAMS No.

ML080800161.

AmerGen (AmerGen Energy Company, LLC). 2006b. Three Mile Island Nuclear Station Unit-1

and Unit-2 Operating License No. DPR-50 and Possession Only License No. DPR 73 Docket

NUREG-1437, Supplement 37 2-72 June 2009
Affected Environment

Nos. 50-289 and 50-320. Combined 2005 Annual Radioactive Effluent Release Report.

Middletown, PA. ADAMS No. ML061230244.

AmerGen (AmerGen Energy Company, LLC). 2006c. Three Mile Island Nuclear Station Unit-1

and Unit-2 Operating License No. DPR-50 and Possession Only License No. DPR 73 Docket

Nos. 50-289 and 50-320. Radiological Environmental Monitoring Program Report, 1 January

through 31 December 2005. Middletown, PA. ADAMS No. ML061220487.

AmerGen (AmerGen Energy Company, LLC). 2006d. Three Mile Island, Unit 1, Enclosure A -

Post Audit Environmental Information - Question ENV-0 70, Monthly Report on the

Meteorological Monitoring Program, March 2007 through End (Non-Proprietary Version). "Three

Mile Island Nuclear Station State Only Operating Permit for Synthetic Minor Facility: State Only

Permit No: 22-05029." Pp. 275-315. ADAMS No. ML082110253.

AmerGen (AmerGen Energy Company, LLC). 2006e. Three Mile Island 2005 Annual Report,

Record of Well Pumpage and Water Levels. Susquehanna River Basin Commission Permit No.

19961102. ADAMS No. ML082880148.

AmerGen (AmerGen Energy Company, LLC). 2007. Three Mile Island Nuclear Station Units I

and 2 Annual Radiological Environmental Operating Report, 1 January Through December

2006, Appendix F, "Annual Radiological Ground Water Protection Program Report, 1 January

Through December 2006." April. Middletown, PA. ADAMS No. ML081980698.

AmerGen (AmerGen Energy Company, LLC). 2007a. Three Mile Island Nuclear Station Unit 1

and Unit 2 Operating License No. DPR-50 and Possession Only License No. DPR 73 Docket

Nos. 50-289 and 50-320. Combined 2006 Annual Radioactive Effluent Release Report (ODCM

Revision 25 Enclosed). Middletown, PA. ADAMS No. ML071290369.

AmerGen (AmerGen Energy Company, LLC). 2007b. Three Mile Island Nuclear Station Unit 1

and Unit 2 Operating License No. DPR-50 and Possession Only License No. DPR 73 Docket

Nos. 50-289 and 50-320. Radiological Environmental Monitoring Program Report, 1 January

through 31 December 2006. Middletown, PA. ADAMS No. ML071290163.

AmerGen (AmerGen Energy Company, LLC). 2007c. "Automatic Temperature Monitoring Data

for TMI-1 Intake Screen Pumphouse and Discharge Monitoring Pit." Middletown, PA. ADAMS

No. ML081980678.

AmerGen (AmerGen Energy Company, LLC). 2008. Three-Mile Island Nuclear Station, Unit 1,

Applicant's Environmental Report, License Renewal Operating Stage. ADAMS Nos.

ML080220255, ML080220257, ML080220261, and ML080220282.

AmerGen (AmerGen Energy Company, LLC). 2008a. Three Mile Island Nuclear Station Unit I

and Unit 2 Operating License No. DPR-50 and Possession Only License No. DPR 73 Docket

Nos. 50-289 and 50-320. Radiological Environmental Monitoring Program Report, 1 January

through 31 December 2007. Middletown, PA. ADAMS No. ML081300255.

AmerGen (AmerGen Energy Company, LLC). 2008b. Three Mile Island Nuclear Station Unit 1

and Unit 2 Operating License No. DPR-50 and Possession Only License No. DPR 73 Docket

Nos. 50-289 and 50-320. Combined 2007 Annual Radioactive Effluent Release Report.

Middletown, PA. ADAMS No. ML081300410.

June 2009 2-73 NUREG-1437, Supplement 37
Affected Environment

AmerGen (AmerGen Energy Company, LLC). 2008c. Three Mile Island Generating Station, Unit

1, License Renewal Application. Kennett Square, PA. ADAMS No. ML080220207.

AmerGen (AmerGen Energy Company, LLC). 2008d. Three Mile Island, Unit 1, Enclosure A -

Post Audit Environmental Information - Index Through Audit Question ENV-070, Monthly

Report on the Meteorological Monitoring Program, February 2007 (Non-Proprietary Version).

June 10. ADAMS No. ML082110252.

Audubon Society. 2008. "Prothonotary Warbler." Available URL:

http://audubon2.orq/watchlist/viewSpecies.isp?id=165 (accessed June 4, 2008). ADAMS No.

ML082880486.

Carr, K.W. 1998. "The Early Archaic Period in Pennsylvania." Pennsylvania Archaeologist. Vol.

68. Issue 2, pp. 42-69.

Center for Workforce Information and Analysis. 2008. "Pennsylvania Department of Labor and

Industry, Harrisburg, Pennsylvania." Available URL: http://www.paworkstats.state.pa.us

(accessed September 12, 2008). ADAMS No. ML082880507.

CBP (Chesapeake Bay Program). 2008. "American Shad Management and Restoration."

Available URL:

http://www.chesaPeakebay.net/americanshadmanagement.aspx?menuitem=1 4771 (accessed

July 18, 2008). ADAMS No. ML082381098.

Clean Air Act. 42 U.S.C. 7401, et seq. United States Code, Title 42, The Public Health and

Welfare, Chapter 85, "Air Pollution Prevention and Control."

Conestoga-Rovers (Conestoga-Rovers & Associates). 2006. Hydrogeologic Investigation

Report, Fleetwide Assessment, Three Mile Island Generating Station, Middletown,

Pennsylvania. September. ADAMS Nos. ML081980689, ML081980691, ML081980692.

Conestoga-Rovers (Conestoga-Rovers & Associates). 2007. Estimated Mass Flux of Tritiated

Groundwater to the Susquehanna River, Three Mile Island Generating Station, Middletown,

Pennsylvania. October. ADAMS No. ML081980693.

Cornell (Cornell Lab of Ornithology). 2003. ,"Peregrine Falcon." Available URL:

http://www.birds.cornell.edu/AllAboutBirds/BirdGuide/PeregrineFalcondtl.html (accessed June

6, 2008). Accessible at ML073300303.

Cowin, Verna. 1985. "The Woodland Period." A Comprehensive State Plan for the Conservation

of Archaeological Resources. Volume II. pp. 185-193. Edited by P. Raber. Pennsylvania

Historical and Museum Commission. Harrisburg, PA.

CWA (Clean Water Act, or Federal-Water Pollution Control Act). 33 U.S.C. 1251 et seq.

Dauphin County (Dauphin County Planning Commission). 2008. Dauphin County

Comprehensive Plan. Available URL: http://www.tcrpc-pa.or~q/dccompplan.htm (accessed

September 4, 2008). ADAMS No. ML082880507.

DCNR (Pennsylvania Department of Conservation and Natural Resources). 2008. "GettysburgNewark Lowland Section Piedmont Province." Available URL:

NUREG-1437, Supplement 37 2-74 June 2009
Affected Environment

http://www.dcnr.state.pa.us/topogeo/map13/13gnls.aspx (accessed on September 23, 2008).

ADAMS No. ML082880546.

DCNR (Pennsylvania Department of Conservation and Natural Resources). 2008a. Letter from

R. Bowen, Environmental Review Specials, Pennsylvania Department of Conservation and

Natural Resources, to L. Lund, Branch Chief, Division of License Renewal, Nuclear Regulatory

Commission. Subject: Pennsylvania Natural Diversity Inventory Review, PNDI Number 19605,

Three Mile Island Unit 1 License Renewal Species of Special Concern, Dauphin & Lancaster

Counties." May 2, 2008. ADAMS No. ML081300048.

Durlin, R.R. and W.P. Schaffstall. 2005. Water Resources Data Pennsylvania Water Year 2004,

Water-Data Report PA-04-2. U.S. Geological Survey. May. New Cumberland, PA. ADAMS No.

ML081980705.

EPA (U.S. Environmental Protection Agency). 1974. "Information on Levels of Environmental

Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety."

Report 550/9-74-004, Washington, D.C. Available URL:

http://www.nonoise.org/library/levels74/levels74.htm. March. (See also "EPA Identifies Noise

Levels Affecting Health and Welfare." September 21, 2007. Available URL:

http://www.epa.qov/history/topics/noise/O l.htm.) Accessed March 2, 2009.

EPA (U.S. Environmental Protection Agency). 2000. RCRA, Superfund & EPCRA Hotline

Training Module. Introduction to: RCRA Statutory Overview. EPA530-5-99-063. February.

Available URL: http://www.epa.,qov/osw/inforesources/pubs/hotline/trainincq/enforc.pdf (accessed

August 28, 2008). ADAMS No. ML082880301.

EPA (U.S. Environmental Protection Agency). 2007. Hazardous Waste Generators Regulations.

May. Available URL: http:l/www.epa.qov/osw/hazard/downloads/tool.pdf (accessed October 14,

2008). ADAMS No. ML082880301.

EPA (U.S. Environmental Protection Agency). 2007a. "Wastes - Laws and Regulations."

Available URL: http://www.epa..qov/osw/laws-reqs/index.htm (accessed August 28, 2008).

ADAMS No. ML082880301.

EPA (U.S. Environmental Protection Agency). 2008. "Environmental Management Systems

(EMS)." Available URL: http://www.epa.qov/ems/index.html (accessed August 28, 2008).

ADAMS No. ML082880301.

EPA (U.S. Environmental Protection Agency). 2008a. "EPA EnviroFacts Warehouse - Facility

Detail Report - AmerGen Energy Three Mile Island Nuclear Station." Available URL:

http://oaspub.epa.qov/enviro/fii query dtl.disp proqram facility?pcqm sys id in=PAR00003786

1&pDqm sys acrnm in=RCRAINFO (accessed August 28, 2008). ADAMS No. ML082880301.

EPA (U.S. Environmental Protection Agency). 2008b. "Pollution Prevention Information

Clearinghouse (PPIC)." Available URL: http://www.epa.qov/oppt/ppic/ (accessed August 28,

2008). ADAMS No. ML082880301.

EPA (U.S. Environmental protection Agency). 2008c. "Local Drinking Water Information,

Pennsylvania Drinking Water, Envirofacts Data on Pennsylvania, County Search - Dauphin and

Lancaster Counties - April 15, 2008." Searchable database. Available URL:

June 2009 2-75 NUREG-1437, Supplement 37
Affected Environment

http://oaspub.epa.gov/enviro/sdw form v2.create paqe?state abbr=PA (accessed September

2008).

ESA (Endangered Species Act). 16 U.S.C. 1531, et seq.

Exelon (Exelon Corporation, Inc.). 2007. TMI Radiological Groundwater Protection Program

(RGPP) Sample Point Data and Standard Control Limits. CY-TM-1 70-400. December 16.

Fike, J. 1999. Terrestrial and Palustrine Plant Communities of Pennsylvania. Pennsylvania

Natural Diversity Inventory. Chapter 8: Herbaceous Wetlands. Pennsylvania Natural Diversity

Inventory. Available URL: http://www.dcnr.state.pa.us/wrcf/fikebook/21 chapter8.pdf (accessed

June 3, 2008). ADAMS No. ML082880541.

FirstEnergy (FirstEnergy Forest Services). 2007. First Energy Vegetation Management

Specifications. ADAMS No. ML082110252.

FirstEnergy (FirstEnergy Forest Services). 2008. Vegetation Control with Herbicides. ADAMS

No. ML082110252.

Funk, R.E. (Funk). 1972. "Early Man in the Northeast and Late Glacial Environment." Man in the

Northeast. Vol. 4, pp. 7-39.

FWS (U.S. Fish and Wildlife Service). 2008. Letter from D. Densmore, Supervisor, U.S. Fish

and Wildlife Service, Pennsylvania Field Office, to L. Lund, Branch Chief, Division of License

Renewal, Nuclear Regulatory Commission. Subject: Three Mile Island Nuclear Station, Unit 1,

License Renewal Application Review. April 23, 2008. ADAMS No. ML081280307.

FWS (U.S. Fish and Wildlife Service). 2008a. "Osprey: Pandion haliaetus." Available URL:

http://www.fws..qov/chesapeakebav/osprey. html (accessed May 15, 2009). Accessible at

ML082880486.

Harman, W.N. and E. Underwood. 2008. Survey of the Pearly Freshwater Mussels

(Unionidae:Bibalvia) of the Susquehanna River in a reach between Exits 14 and 15 of Interstate

88, Oneonata, NY. State University of New York, College at Oneonta. Available URL:

http://www.oneonta.edu/academics/biofld/PUBS/ANNUALU2007/Susquehanna%20DOT%20mus

sel%20report%20for%20BFS%20AR.pdf (accessed July 22, 2008). ADAMS No. ML082381099.

Harrisburg Websites. Undated. "Dauphin County History." Available URL:

http://www.harrisburqwebsites.com/Publications/Dauphin County HistorV.htm (accessed on

September 29, 2008). ADAMS No. ML082880526.

Hilty, J. 2006a. "Aunt Lucy." Available URL:

http://www.illinoiswildflowers.info/woodland/plants/aunt lucy.htm (accessed June 3, 2008).

Accessible at ML082880486.

Hilty, J. 2006b. "Flat-Stemmed Spike Rush." Available URL:

http://www.illinoiswildflowers.info/qrasses/plants/fs spikerush.htm (accessed June 3, 2008).

Accessible at ML082880486.

Huber, Elaine. 1982. "Three Mile Island Had a Sometime Stormy Past." Lancaster Sunday

News. (July 4,1982). ADAMS No. ML082110252.

NUREG-1437, Supplement 37 2-76 June 2009
Affected Environment

Ichthyological Associates, Inc. 1975. An Ecological Study of the Susquehanna River Near the

Three Mile Island Nuclear Station - Annual Report for 1974. February. Etters, PA. ADAMS No.

ML082381102.

Ichthyological Associates, Inc. 1976. An Ecological Study of the Susquehanna River Near the

Three Mile Island Nuclear Station - Annual Report for 1975. February. Etters, PA. ADAMS No.

ML082381103.

Ichthyological Associates, Inc. 1983. An Ecological Study of the Susquehanna River Near the

Three Mile Island Nuclear Station - Annual Report for 1982. April. Etters, PA. ADAMS No.

ML081980679.

Institute of Educational Science (IES). 2008. U.S. Department of Education. National Center for

Educational Statistics. "College Opportunities Online Locator." Zip Code 17057. Available online

at http://nces.ed.qov/ipeds/cool/RefineSearch.aspx (accessed September 9, 2008).

Johnson, J.H. and D.S. Dropkin. 1992. "Predation on Recently Released Larval.American Shad

in the Susquehanna River Basin." North American Journal of Fisheries Management 12(3):504-

508. ADAMS No. ML082381104.

Kapsch, Robert J. 2004. Canals. W.W. Norton & Company. U.S. p. 310.

Kent et al. (Kent, Barry C., Ira F. Smith Ill, and Catherine McCann eds.) 1971. Foundations of

Pennsylvania Prehistory. Pennsylvania Historical and Museum Commission Anthropological

Series, #1. Harrisburg, PA.

Lancaster County (Lancaster County Planning Commission). 2006. "The Growth Management

Element of The Comprehensive Plan for Lancaster County, Pennsylvania prepared by the

Lancaster County Planning Commission and Lancaster County Growth Management Update

Task Force." April. Available URL:

www.co.lancaster.pa.uslplanning/lib/planning/balance full report.pdf (accessed October 5,

2006). ADAMS No. ML082880507.

Londonderry Township. Undated. "Londonderry Township Historical Society." Available URL:

http://www.londonderrypa.org/history.php (accessed on September 30, 2008). ADAMS No.

ML082880526.

Lebanon County. 2005. "Union Canal of Pennsylvania." Available URL:

http://dsf.pacounties.or-q/lebanon/cwp/view.asp?A=3&QUESTION ID=479797 (accessed on

September 30, 2008). ADAMS No. ML082880526.

McNally, B. 2008. "Small Times on the Susquehanna". Available URL:

http://www.boats.com/news-reviews/articledetail.html?lid=2284 (accessed July 10, 2008).

ADAMS No. ML082880347.

The Native Fish Conservancy. 2008. "Migratory Fish Restoration and Passage on the

Susquehanna River." Available URL:

http://www.nativefish.orq/articles/Miqratory Fish Restoration.php (accessed June 10, 2008).

ADAMS No. ML082381108.

June 2009 2-77 NUREG-1437, Supplement 37
Affected Environment

NCDC (National Climate Data Center). 2008. Comparative Climatic Data. Available URL:

http://www.ncdc.noaa.qov/oa/climate/online/ccd/avqwind.html (accessed June 10, 2008).

ADAMS No. ML082880549.

NCDC (National Climate Data Center). 2008a. "Storm Events." Searchable database. Available

URL: http://www4.ncdc.noaa.qov/ccqi-win/wwcqi.dll?wwevent-storms (accessed June 12, 2008).

NCDC (National Climate Data Center). 2008b. "Storm Events: Dauphin County, PA most

destructive tornado event." Available URL: http://www4.ncdc.noaa..qov/cqiwin/wwcqi.dll?wwevent-ShowEvent-135093 (accessed June 12, 2008). ADAMS No.

ML082880549.

NEPA (National Environmental Policy Act of 1969). 42 U.S.C. 4321, et seq.

NOAA (National Oceanic and Atmospheric Administration). Undated. "Guide to Essential Fish

Habitat Designations in the Northeastern United States." Available URL:

http://www.nero.noaa.qov/hcd/est.htm#MARYLAND (accessed June 19, 2008). ADAMS No.

ML0823801 11.

NOAA (National Oceanic and Atmospheric Administration). 2007. "Lebanon County Tornado,

Jul7 14, 2004." Available URL: http://www.erh.noaa.qov/ctp/features/2004/Julvl4/Lebanon.php

(accessed May 15, 2009). ADAMS No. ML091350465.

Normandeau (Normandeau Associates, Inc.). 2007. Summary of Environmental Studies Near

the Three Mile Island Nuclear Station. October. Drumore, PA. ADAMS No. ML081980680.

NRC (U.S. Nuclear Regulatory Commission). 1976. NUREG-0112. Final Supplement to the

Final Environmental Statement Related to the Operation of Three Mile Island Nuclear Station,

Unit 2, Metropolitan Edison Company et aL, Docket No. 50-320. Office of Nuclear Reactor

Regulation, Washington, D.C. December. ADAMS No. ML080090250.

NRC (U.S. Nuclear Regulatory Commission). 1988. Issuance of Amendment No. 143 to Facility

Operating License No. DPR-50 for the Three Mile Island Nuclear Station, Unit No. 1.

Washington, D.C. ADAMS No. ML003779786.

NRC (U.S. Nuclear Regulatory Commission). 1990. Overview and Comparison of U.S

Commercial Nuclear Power Plant, Nuclear Power Plant System Source. NUREG/CR-5640.

Washington, D.C.

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

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

ADAMS No. ML061770605.

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

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

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

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

PADEP (Pennsylvania Department of Environmental Protection). 2001. "Overview of EPA's

Final Rule on Storage, Treatment, Transportation and Disposal of Mixed Waste." Available URL:

NUREG-1437, Supplement 37 2-78 June 2009
Affected Environment

http://www. dep .state. pa. us/dep/subiect/advcoun/1 rw/20O1 /OverviewEPAFinaIRuleMixedWaste. p

df (accessed July 15, 2008). ADAMS No. ML082880301.

PADEP (Pennsylvania Department of Environmental Protection). 2004. Pennsylvania Air Quality

Monitoring 2004 Annual Report. Division of Air Quality Monitoring. Harrisburg, PA. Available

URL: http://www.deP.state.pa.us/dep/deputate/airwaste/a/aQm/amareport2004aqreport.pdf

(accessed August 16, 2008). ADAMS No. ML082880549.

PADEP (Pennsylvania Department of Environmental Protection). 2008. "eMapPA." Searchable

database. Available URL: http://www.emappa.dep.state.pa.us/emappa/viewer.htm (accessed

October 14, 2008).

PADEP (Pennsylvania Department of Environmental Protection). 2008a. "Survey Information.

Water Supply Data for Dauphin and Lancaster Counties." Searchable database. Available URL:

www.drinkinqwater.state.pa.us/dwrs/HTM/DEP frm.html (accessed September 9, 2008).

PADEP (Pennsylvania Department of Environmental Protection). 2008b. "Zebra Mussel Found

on Susquehanna River at Conowingo Dam in Maryland." November 24. Available URL:

http://www.ahs2.dep.state.pa.us/newsreleases/default.asp?ID=5364&varqueryTyp (accessed

March 18, 2009). ADAMS No. ML090770897.

PDE (Pennsylvania Department of Education). 2004. Map of Pennsylvania School Districts and

Intermediate Unit 15. March. Available URL:

http://www.dot.state.pa.us/lnternet/Bureaus/pdPlanRes.nsf/infoBPR Education PA Intermediat

e unit (accessed September 9, 2008). ADAMS No. ML082880507.

PDE (Pennsylvania Department of Education). 2007a. "Public School Enrollments by County,

LEA, School, Grade and Gender Workbook 2006-2007." Excel database. July 12. Available

URL: http://www. pde.state.pa.us/kl 2statistics/lib/k1 2statistics/0607PubEnrCtySchGraGen.xls.

(accessed September 9, 2008).

PDE (Pennsylvania Department of Education). 2007b. "Public, Private and Nonpublic Schools

Enrollments 2006-07." August. Available URL:

http://www.pde.state.pa.us/k12statistics/cwp/view.asp?a=3&q=129090 (accessed September 9,

2008). ADAMS No. ML082880507.

PennDOT (Pennsylvania Department of Transportation). 2008. "2006 Traffic Volume Map -

Dauphin County." Searchable database. Available URL:

http://www.dot.state.pa.us/internet/Bureaus/pdPlanRes.nsf/infoBPRTrafficlnfoTrafficVolumeMap

(accessed September 9, 2008). ADAMS No. ML082880507.

Pennsylvania Sea Grant. 2008. "Aquatic Invasive Species of Pennsylvania. Asiatic Clam."

Available URL: http://www.pserie.psu.edu/seaqrant/ais/watershed/clam.htm (accessed June 11,

2008). ADAMS No. ML082381162.

Pennsylvania Sea Grant. 2008a. "Aquatic Invasive Species of Pennsylvania. Zebra

Mussel/Quagga Mussel." Available URL:

http://www.pserie.psu.edu/seaprant/ais/watershed/mussel.htm (accessed June 11, 2008).

ADAMS No. ML082381267.

June 2009 2-79 NUREG-1437, Supplement 37
Affected Environment

Pennsylvania Sea Grant. 2008b. "Pennsylvania Zebra and Quagga Mussel Monitoring

Network." Available URL: http://seaqrant.psu.edu/zm/index.htm (accessed July 22, 2008).

ADAMS No. ML082381268.

Pennsylvania State Data Center. 2008. The Pennsylvania Bulletin - Pennsylvania State Data

Center; Pennsylvania Population Projections; Public Review [38 Pa.B. 1415] [Saturday, March

22, 2008] "Pennsylvania Preliminary Population Projections: 2000-2030." February. Available

URL: http://www.pabuiletin.com/secure/data/vo138/38-12/524.html (accessed September 9,

2008). ADAMS No. ML082880507.

PFBC (Pennsylvania Fish and Boat Commission). Undated. Commercial Shad Landings.

Available URL: http://www.fish.state.pa.us/education/whereshaddata.pdf (accessed June 10,

2008). ADAMS No. ML082381 111.

PFBC (Pennsylvania Fish and Boat Commission). 2008. "Biologist Reports, Susquehanna River

Smallmouth Bass, Lancaster/York County." Available URL:

http://www.fish.state.pa.us/imaqes/fisheries/afm/2006/6xl 1 13accomac.htm (accessed June

11, 2008). ADAMS No. ML082381114.

PFBC (Pennsylvania Fish and Boat Commission). 2008a. "Susquehanna River American Shad."

Available URL: (http://www.fish.state.pa.us/shad susq.htm (accessed June 11, 2008). ADAMS

NO. ML082381115.

PFBC (Pennsylvania Fish and Boat Commission). 2008b. PA Stream Sections that Support

Natural Reproduction of Trout. Available URL: http://www.fish.state. pa. us/trout repro.pdf

(accessed June 11, 2008). ADAMS No. ML082381116.

PFBC (Pennsylvania Fish and Boat Commission). 2008c. Susquehanna River Drainage YOY

Smallmouth Bass Disease Investigations 2005 and 2007. Available URL:

http://www.fish.state.pa.us/pafish/bass black/meetinqs/fish committee2007sep/mortalitv07 05.

pdf?bcsi scan B666AIDE717DB577=0&bcsi scan filename=mortality07 05.pdf (accessed

June 3, 2008). ADAMS No. ML082880420.

PFBC (Pennsylvania Fish and Boat Commission). 2008d. Andrew Shiels-Personal

communications. July 22, 2008. ADAMS No. ML082381123.

PFBC (Pennsylvania Fish and Boat Commission). 2008e. Michael Hendricks-Personal

communications. July 22, 2008. ADAMS No. ML082381123.

PFBC (Pennsylvania Fish and Boat Commission). 2008f. "Historical WW/CW Species Stocking

by County." Available URL:

http://pfbc.state.pa.us/pfbc webqis/WWCWStockinqDetails historical.aspx (accessed July 21,

2008). ADAMS No. ML082381124.

PFBC (Pennsylvania Fish and Boat Commission). 2008g. "2008 Pennsylvania Fishing

Summary, Summary of Fishing Regulations and Laws". Available URL:

http://www.fish.state.pa.us/fishpub/summarv/zOOcomplete.pdf (accessed July 23, 2008).

ADAMS No. ML082880450.

PFBC (Pennsylvania Fish and Boat Commission). 2008h. Letter from C. Urban, Chief, Natural

Diversity Section, Pennsylvania Fish & Boat Commission, Bellefonte, Pennsylvania, to S.

NUREG-1437, Supplement 37 2-80 June 2009
Affected Environment

Lopas, Nuclear Regulatory Commission, Rockville, Maryland. Subject: Species Impact Review

(SIR) - Rare, Candidate, Threatened and Endangered Species, Three Mile Island Nuclear

Station, Londonderry Township/Borough, Dauphin County, PA. June 3, 2008. ADAMS No.

ML081610104.

PGA (Pennsylvania General Assembly). Undated. "Pennsylvania on the Eve of Colonization."

Available URL: http://www.legis.state.pa.us/WUO1NC/visitor info/pa history/pa history.htm

(accessed on October 1, 2008). ADAMS No. ML082880526.

PGC (Pennsylvania Game Commission). 2006. "Peregrine Falcon." Available URL:

http://www.pqc.state. pa. us/pqc/cwp/view.asp?a=486&q = 160961 (accessed June 6, 2008).

Accessible at ML073300495.

PGC (Pennsylvania Game Commission). 2008. Letter from J. Leigey, Division of Environmental

Planning and Habitat Protection, Bureau of Wildlife Habitat Management, to L. Lund, Branch

Chief, Division of License Renewal, Nuclear Regulatory Commission. Subject: State-Protected

Bird and Mammal Species Review, Three Mile Island Nuclear Station License Renewal

Application, Londonderry Township, Dauphin County, PA. May 14, 2008. ADAMS No.

ML081500671.

PHMC (Pennsylvania Historical and Museum Commission). Undated-a. "Pennsylvania on the

Eve of Colonization." Available URL:

http://www.phmc.state.pa.us/bah/pahist/colony.asp?secid=31 (accessed on October 1, 2008).

ADAMS No. ML082880526.

PHMC (Pennsylvania Historical and Museum Commission). Undated-b. "Harrisburg:

Pennsylvania's Capital City." Available URL:

http://www.phmc.state.pa.us/ppet/harrisburg/paqe1.asp?secid=31 (accessed on September 29,

2008). ADAMS No. ML082880526.

PNHP (Pennsylvania Natural Heritage Program). 2008. "State Species List, Update June 2008."

Available URL: http://www.naturalheritaQe.state.pa.us/Homepage.aspx (accessed July 14,

2008). ADAMS No. ML082381127.

PNHP (Pennsylvania Natural Heritage Program). 2008a. "Ellisia; waterpod (Ellizia nycetelea)."

Available URL: http://www.naturalheritaqe.state.pa.us/factsheets/14002.pdf (accessed June 3,

2008). Accessible at ML082880486.

PNHP (Pennsylvania Natural Heritage Program). 2008b. "Short's Sedge (Carex shortiana)."

Available URL: http://www.naturalheritage.state.pa.us/factsheets/15124.pdf (accessed June 3,

2008). Accessible at ML082880486.

Raber (Raber, Paul. ed.). 1985. A Comprehensive State Plan for the Conservation of

Archaeological Resources. Vol. II. Pennsylvania Historical and Museum Commission.

Harrisburg, PA.

RCRA (Resource Conservation and Recovery Act). 40 CFR Part 239, et seq.

RMC (RMC Environmental Services). 1991. An Ecological Study of the Susquehanna River

Near The Three Mile Island Nuclear Station, Annual Report for 1990. March. Drumore, PA.

ADAMS No. ML081980683.

June 2009 2-81 NUREG-1437, Supplement 37
Affected Environment

Sadzinski, B. and Tony Jarzynski. Undated. "Shad School." Maryland Department of Natural

Resources. Available URL: http://dnr.md.qov/fisheries/education/shadschool.html (accessed

June 10, 2008). ADAMS No. ML082381161.

Smith Ill, Ira F. (Smith). 1977. Early and Middle Woodland Campsites on Three Mile Island,

Dauphin County, Pennsylvania. Pennsylvania Historical and Museum Commission and

Metropolitan Edison Company, Three Mile Island Nuclear Generating Station Project.

Harrisburg, PA. January. Non-public reference per 37 Pa. C.S.A. § 506(c) and consultation with

Pennsylvania Historical and Museum Commission.

SRBC (Susquehanna River Basin Commission). 1995. GPU Nuclear Corporation. Three Mile

Island Nuclear Station Unit 1, Application 199550302. March. Harrisburg, PA. ADAMS No.

ML081980711.

SRBC (Susquehanna River Basin Commission). 1996. Unpublished data. ADAMS No.

ML082381269.

SRBC (Susquehanna River Basin Commission). 1999. GPU Nuclear, Inc. Application 19961102

(Revised). January. Harrisburg, PA. ADAMS No. ML081980709.

SRBC (Susquehanna River Basin Commission). 2005. Unpublished data. ADAMS No.

ML082381269.

SRBC (Susquehanna River Basin Commission). 2006. Susquehanna Large River Assessment

Project. Publication 245. August. ADAMS No. ML082381271.

SRBC (Susquehanna River Basin Commission). 2006a. Lower Susquehanna Subbasin Survey:

A Water Quality and Biological Assessment, June - November 2005. Publication 247.

September. ADAMS No. ML082381273.

SRBC (Susquehanna River Basin Commission). 2008. Susan Buda-Personal

communications. ADAMS No. ML082381269.

USCB (U.S. Census Bureau). 2008. "American FactFinder, American Community Survey of

Dauphin and Lancaster Counties, Data Profile Highlights. Housing Characteristics for 2000 and

2006." Available URL: http://factfinder.census.gov (accessed August 16, 2008).

USCB (U.S. Census Bureau). 2008a. "Decennial Census 2000 Data, American FactFinder,

American Community Survey of Dauphin and Lancaster Counties, Data Profile Highlights.

Selected Economic Characteristics: 2006." Searchable database. Available URL:

http://factfinder.census.qov (accessed September 12, 2008).

USCB (U.S. Census Bureau). 2008b. "State and County QuickFacts, 2006 Data of Dauphin and

Lancaster Counties." Searchable database. Available URL: http://quickfacts.census.qov

(accessed September 5, 2008).

USDA (U.S. Department of Agriculture). 2008. "2002 Census of Agriculture." Available URL:

http://www.nass.usda.qov/census/census02/volumel/pa/index2.htm (accessed September 12,

2008). ADAMS No. ML082880507.

NUREG-1437, Supplement 37 2-82 June 2009
Affected Environment

USDOI (U.S. Department of the Interior). 2008. "Index by State and County, National Register

Information System." Available URL: http://www.nr.nps.qov/nrlocl.htm (accessed on September

23, 2008). ADAMS No. ML082880722.

USGS (U.S. Geological Survey). Undated. "Biological and Ecotoxicological Characteristics of

Terrestrial Vertebrate Species Residing in Estuaries. Osprey." Available URL:

http://www.pwrc.usqs.qov/bioeco/osprey.htm (accessed on May 15, 2009). ADAMS No.

ML091350285.

USGS (U.S. Geological Survey). 2008. "Temperature, Dissolved-Oxygen, and Nutrient

Monitoring in the Susquehanna River - Summer 2008. A Project Proposal." Available URL:

http://www.fish.state.pa.us/pafish/bass black/meetincqs/susq2008prowect proposal.pdf

(accessed June 10, 2008). ADAMS No. ML082381274.

Walker, J. Samuel, Three Mile Island: A Nuclear Crisis in Historical Perspective, Berkeley:

University of California Press, 2004.

Warfel, Stephen G. 1988. A Report on the Discovery of a Human Skeleton at Three Mile Island,

Dauphin County, Pennsylvania. The State Museum of Pennsylvania. Harrisburg, PA. (March 21,

1988). Non-public reference per 37 Pa. C.S.A. § 506(c) and consultation with Pennsylvania

Historical and Museum Commission.

York Daily Record. 2009. "TMI Project Makes Ducks Feel at Home." March 2. Available URL:

http://vdr.invork.com/ci 11814515?source=most emailed (accessed March 18, 2009). ADAMS

No. ML090771036.

York Haven Power Company. 2008. Unpublished data. June. ADAMS No. ML082880482.

June 2009 2-83 NUREG-1437, Supplement 37

3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT

Facility owners or operators may need to undertake or, for economic or safety reasons, may

choose to perform refurbishment activities in anticipation of license renewal or during the license

renewal term. The major refurbishment class of activities characterized in the generic

environmental impact statement (GELS) (NRC 1996, 1999) is intended to encompass actions

that typically take place only once in the life of a nuclear plant, if at all. Examples of these

activities include, but are not limited to, replacement of boiling-water reactor recirculation piping

and pressurized-water reactor steam generators. As noted in the GELS, refurbishment activities

could result in environmental impacts beyond those that occur during normal plant operations.

For issues that meet Category 1 criteria, no additional plant-specific analysis is required in this

supplemental environmental impact statement (EIS) unless new and significant information is

identified. Category 2 issues are those that do not meet criteria for Category 1 and, therefore,

additional plant-specific review of these issues is required. Refurbishment activities may affect a

variety of environmental issues as listed in Table 3-1 below.

Table 3-1. Issues Related to Refurbishment at TMI-1

Issues Category

Surface Water Quality, Hydrology, and Use

Impacts of refurbishment on surface water quality 1

Impacts of refurbishment on surface water use 1

Aquatic Ecology

Refurbishment 1

Terrestrial Resources

Refurbishment impacts 2

Threatened and Endangered Species

Threatened and Endangered Species 2

Ground Water Use and Quality

Impacts of refurbishment on ground water use and quality 1

Air Quality

Air quality during refurbishment (nonattainment and maintenance areas) 2

Land Use

Onsite land use 1

I

June 2009 3-1 NUREG-1437, Supplement 37
Environmental Impacts of Refurbishment

Table 3-1 (continued). Issues Related to Refurbishment at TMI-1

Human Health

Radiation exposures to the public during refurbishment 1

Occupational radiation exposures during refurbishment 1

Socioeconomics

Public Services: Public Safety, Social Services, and Tourism and Recreation 1

Aesthetic Impacts (refurbishment) 1

Housing Impacts 2

Public Services: Education (refurbishment) 2

Public Services: Public Utilities 2

Offsite land use (refurbishment) 2

Public Services: Transportation 2

Historic and Archaeological Resources 2

Environmental Justice

Environmental Justice Uncategorized

Exelon Generation Company, LLC (Exelon Generation) plans to replace the two steam

generators at Three Mile Island Nuclear Station, Unit 1 (TMI-1), with new, once-through,

enhanced steam generators. As such, Exelon Generation and the NRC have analyzed steam

generator replacement as a refurbishment activity, pursuant to Title 10, Section 51.53(c)(3)(ii),

of the Code of Federal Regulations (10 CFR 51.53(c)(3)(ii)).

3.1 Refurbishment Activities at TMI-1

Steam generator replacement activities will take approximately 70 days to complete and will

occur sometime between the refueling outage scheduled for October 2009 and the expiration of

the original license period in April 2014. The original TMI-1 steam generators contain tubing

made of alloy 600MA, which can degrade over time because of corrosion! and mechanical stress

.from normal plant operation. Exelon Generation determined that both of the steam generators at

TMI-1 are affected by degradation and should be replaced with new steam generators fitted with

tubing made of alloy 690TT, which is more resistant to stress-corrosion cracking. Exelon

Generation will also replace the hot-leg elbows, portions of the piping, and all existing steam

generator insulation. Exelon Generation indicated that the steam generator refurbishment will

I

I

NUREG-1437, Supplement 37 3-2 June 2009
Environmental Impacts of Refurbishment

allow TMI-1 to operate safely throughout the period of license extension and will increase the

steam generator blowdown system 'capacity (AmerGen 2008).

The replacement steam generators will be manufactured in France and transported to the TMI-1

site. Transportation of these large components (each steam generator weighs approximately

500 tons [454 metric tons]) will be by a combination of boat, barge, rail, and road (AmerGen

2008). The steam generators will be transferred to land at Port Deposit, Maryland. Preliminary

bathymetry studies have provided reasonable assurance that dredging in the Susquehanna

River will not be required to accommodate the transfer at that location (NRC 2008).

The route from Port Deposit to the TMI-1 site has been identified by Exelon Generation's steam

generator vendor, and has preliminary approval from the Maryland State Highway

Administration and the Pennsylvania Department of Transportation, pending final approval of

engineering plans and environmental permitting.. The steam generator route will encompass 13

miles (mi) (21 kilometers [km]) of Maryland roads and 62 mi (100 km) of Pennsylvania roads,

including 21 stream crossings in Maryland and 29 stream crossings in Pennsylvania. Some

bridges can support the weight of the steam generators and will require no modification,

however, some bridges will require modifications (such as support beams or bracing) or

overbridges, which are steel plates that span a length greater than the bridge to provide a deck

for the transporters to drive over. Some bridges may need to be avoided entirely by constructing

a temporary bridge bypass. Three bridges in Pennsylvania will require modifications, and at

least two, and possibly four, temporary bridge by-passes will be constructed over Pequea Creek

and Chicques Creek, and Conowingo Creek and Conoy Creek. Temporary stream bypasses will

be removed after the transporters have crossed them, and the area will be returned to its

original condition.

For transportation within the United States, Exelon Generation (or its vendor) will be required to

meet all Federal, State, and local requirements that may be applicable to the following activities:

dredge or fill activities performed in waterways as related to bridge modifications or bridge

bypasses; temporary or permanent removal of route interferences (such as narrow tunnels and

low-hanging overhead wires); and movement of wide or heavy loads over rail and roadways.

The following list details environmental permits and consultations that are required for steam

generator transportation from Port Deposit to TMI-I. These permits and consultations are in

addition to engineering approvals and permits required and issued by the Maryland State

Highway Administration and the Pennsylvania Department of Transportation.

• Joint Permit Application - Engineering plans, stream and wetland water and hydrology

impacts, hydraulic impact calculations; approved by the Pennsylvania Department of

Environmental Protection (PADEP) and the U.S. Army Corps of Engineers (USACE).

(Approval of the joint permit requires documentation of consultation with the'State

resource agencies described. below.)

* Consultation with the Pennsylvania Historic Museum Commission (PHMC) -

Determination of No Adverse Impact to Historic Resources (see PHMC 2009).

* Consultation with Pennsylvania Fish and Boat Commission (PFBC) - Stream impact

assessment and threatened and endangered species impacts.

* Consultation with Pennsylvania Game Commission (PGC) - threatened and endangered

species impacts.

June 2009 3-3 NUREG-1437, Supplement 37
Environmental Impacts of Refurbishment

* Consultation with Pennsylvania Department of Conservation and Natural Resources

(DCNR) - threatened and endangered species impacts.

* Coordination letters where environmental studies will occur in Londonderry Township,

Conoy Township, Marietta Borough, East Donegal Township, Manor Township, Pequea

Township, Providence Township, Fulton Township, Little Britian Township, and West

Nottingham Township.

* Erosion and Sediment Control Plans - Approved by Maryland Department of the

Environment, Lancaster County, and Dauphin County.

* National Pollutant Discharge Elimination System Permit - Permit will address over night

pullout locations, and must be approved by Maryland Department of the Environment,

Lancaster County, and Dauphin County.

Once onsite, the steam generators will be moved via a heavy-duty, self-propelled modular

transporter to a temporary, open-air, storage area that will be created without the need for

ground disturbance. To permanently store the original steam generators after removal, a 5000-

square-foot (ft2) (465 square meters [M2]) steam generator storage building will be constructed

on the power block within the flood protection dike. The building will be approximately 90-ft-long

by 50-ft-wide (27-m-long by 17-m-wide) and 30-ft-high (9 m). Design specifications include a

watertight roof membrane and reinforced concrete thick enough to provide radiological shielding

to ensure that dose rates will remain within the limits set in 10 CFR Part 20, "Standards for

Protection Against Radiation" (AmerGen 2008).

The steam generator storage facility will be the only permanent structure built to support the

I refurbishment project. Temporary facilities will be used for offices, fabrication and welding

activities, and laydown areas; however, the 4500-square-ft (418 M2 ) fabrication/weld test shop

will have a permanent concrete slab, which will remain after the building is removed. Exelon

Generation estimates that the total area to be disturbed for refurbishment activities will be less

than 10 acres (ac) (4 hectares [ha]), and disturbance will all take place on the power block,

which is previously disturbed property (AmerGen 2008).

To remove the old steam generators and install the new ones, a 26 ft by 25 ft (8 m by 7.6 m)

opening will be created in the 3.5-foot thick (1-m-thick), reinforced concrete containment

building by hydrodemolition (high-pressure water) and other mechanical methods. The process

of creating this opening in the containment includes detensioning and removing tendons,

removing concrete, cutting rebar, and cutting and removing a section of the steel liner. The

original steam generators will be drained and cut away from the piping, and penetrations and

openings will be welded closed. Loose radiological contamination will be removed, and a

coating will be applied to the exterior of the original generators to seal any residual

contamination in place (AmerGen 2008).

3.2 Environmental Impacts of Refurbishment

The following sections discuss the Category 2 issues associated with refurbishment activities at

TMI-1. Any environmental impacts from refurbishment will be in addition to those associated

with continued operation of TMI-1 for the period of license renewal; Chapter 4 of this report

NUREG-1437, Supplement 37 3-4 June 2009
Environmental Impacts of Refurbishment

discusses those issues.

3.2.1. Terrestrial Resources - Refurbishment Impacts

Section 2.2.6 of this supplemental EIS describes the terrestrial resources on and in the vicinity

of the TMI-1 site. Section 2.1.5 describes the transmission line right-of-ways (ROWs). For

purposes of this analysis, Sections 2.1.5 and 2.2.6 describe the geographic area considered in

this evaluation.

The majority of steam generator replacement activities for TMI-1 will take place on existing

facility grounds at the TMI-1 site. The replacement project will require laydown areas, a

permanent holding facility for the old steam generators, and several temporary buildings to

support the steam generator replacement activities. All new, permanent structures will be

constructed on previously disturbed land. Temporary and permanent facilities will use less than

10 ac (4 ha) of land. Some minimal, short-term noise impacts from construction may occur.

Exelon Generation will need to obtain all required State and Federal permits for construction of

the facilities associated with refurbishment (AmerGen 2008).

The new steam generators will be delivered to TMI-1 from Port Deposit, Maryland, and will

travel over land via flatbed vehicles. The route identified by Exelon Generation's steam

generator vendor has preliminary approval from the Maryland State Highway Administration and

the Pennsylvania Department of Transportation, pending final approval of engineering plans and

environmental permitting. As discussed above, some bridges will require modifications such as

steel support beams, some bridges will require no modification, and other bridges will be

avoided entirely. Exelon Generation has identified at least three bridges in Pennsylvania that will

require modification, and at least two temporary bridge by-passes will be constructed.

Temporary bridge by-passes will be removed after the transporters have crossed them, and the

area will be returned to its original condition. Additional activities likely to occur during transport

of the steam generator include increasing the height of telephone and electric power poles and

removal and relocation of traffic signals along the roadways to allow for clearance of the steam

generators. Impacts to terrestrial resources from these activities are expected to be negligible.

Exelon Generation's steam generator vendor, AREVA NP, Inc. (AREVA), will repair and restore

the transportation route to its original condition after transportation is complete.

On the basis of the information from the staff's review of Exelon Generation's environmental

report for the TMI-1 proposed license renewal, the staffs site visit, the scoping process,

comments on the draft supplemental EIS, and the evaluation of other reports and information,

impacts to terrestrial resources during the proposed steam generator replacement will be

SMALL. Mitigation measures that could reduce impacts to the terrestrial environment during

construction of the onsite permanent storage building and temporary bridge by-passes include

installing silt fences to minimize sediment transport, the use of best management practices, and

the restoration of cleared land remaining after completion of construction. These mitigation

measures could reduce impacts by reducing erosion and minimizing the movement of sediment,

nutrients, and pollutants to surface and ground water resources.

June 2009 3-5 NUREG-1437, Supplement 37
Environmental Impacts of Refurbishment

3.2.2 Threatened and Endangered Species

3.2.2.1 Terrestrial Species

As discussed in Section 2.2.7 of this report, State and Federal agencies have recognized two

I Federally listed and 11 State-listed threatened, endangered, or special concern terrestrial

species as occurring in the vicinity of the TMI-1 site and its associated transmission line ROWs.

I Additional facilities associated with refurbishment are not likely to exceed 10 ac (4 ha) in total

land use; therefore no additional impacts to threatened and endangered species within the TMII 1 site and its associated transmission line ROWs are expected (AmerGen 2008). The steam

generators will be transported over land from Port Deposit to the TMI-1 site, traveling 13 mi (21

km) of Maryland roads and 62 mi (100 km) of Pennsylvania Roads. Activities such as

I constructing bridge modifications and by-passes, and removing road obstructions are not likely

to have additional impacts on the threatened or endangered species because they will be

confined to previously developed land. However, as a condition of their USACE and PADEP

joint permit for waterway work, AREVA must consult with PGC and DCNR regarding potential

impacts to threatened and endangered terrestrial species in the vicinity of this work.

On the basis of information from the staffs review of Exelon Generation's environmental report

for the TMI-1 proposed license renewal (AmerGen 2008), the staffs site visit, the scoping

process, comments received on the draft supplemental EIS, and the evaluation of other reports

and information, impacts to threatened or endangered terrestrial species during the proposed

steam generator replacement will be SMALL. Mitigation measures will be similar to those used

to minimize impacts to terrestrial resources.

3.2.2.2 Aquatic Species

As stated in Section 3.2.1, the implementation of best management practices, such as installing

silt fences, during onsite refurbishment activities will mitigate the impact of sediment-laden runoff to surface waters and aquatic species. Water used during hydrodemolition of the

containment building will be treated and monitored prior to discharge to the Susquehanna River.

As such, refurbishment activities at the TMI-1 site will likely have a SMALL impact on Federally

and State-listed threatened, endangered, or special concern aquatic species.

Section 3.1 notes that the path of delivery of the steam generators for the 75 mi (121 km) trip

from Port Deposit, Maryland, to the TMI-1 site in Pennsylvania includes 21 stream crossings in

Maryland and 29 stream crossings in Pennsylvania. It also includes the construction of 2-4

temporary bridge by-passes in Pennsylvania. Some instream work may be required for

construction of the bridge by-passes, which can potentially disrupt various lifecycles of Federally

and State-listed threatened, endangered, or special concern aquatic species.

AREVA has indicated that no anadromous fish are present at bridge by-pass locations, and that

they are coordinating with the PFBC, DCNR, and PGC to determine if construction of temporary

bridge by-passes could impact threatened or endangered aquatic species or their critical

habitats. AREVA will be required to comply with any special conditions for protection of

threatened and endangered species that may be contained in a joint permit for waterway

construction work from the PADEP and USACE. Approval of the joint permit is predicated on the

NUREG-1437, Supplement 37 3-6 June 2009
Environmental Impacts of Refurbishment

State resource agency consultations described above. Any potential impacts to threatened or

endangered aquatic species would need to be mitigated prior to approval of the joint permit.

Because the bridge by-passes are temporary, and AREVA is required to comply with Federal

and State permits will likely include best management practices and mitigation for any impacts

to threatened and endangered aquatic species, instream work related to bridge modifications or

bridge by-passes along the steam generator transport route will likely have a SMALL impact on

Federally or State-listed threatened, endangered, or special concern aquatic species.

3.2.3 Air Quality During Refurbishment (Non-Attainment and Maintenance Areas)

Air quality during refurbishment (nonattainment and maintenance areas) is a Category 2 issue.

Table B-1 of Appendix A to Subpart B, "Environmental Effect of Renewing the Operating

License of a Nuclear Power Plant," of 10 CFR Part 51, "Environmental Protection Regulations

for Domestic Licensing and Related Regulatory Functions," notes the following:

1 Air quality impacts from plant refurbishment associated with license renewal are

2 expected to be small. However, vehicle exhaust emissions could be cause for concern at

3 locations in or near nonattainment or maintenance areas. The significance of the

4 potential impact cannot be determined without considering the compliance statues of

5 each site and the numbers of workers expected .to be employed during the outage.

Specifically, 10 CFR 51.53(c)(3)(ii)(F) requires the following:

6 If the applicant's plant is located in or near a nonattainment or maintenance area, an

7 assessment of vehicle exhaust emissions anticipated at the time of peak refurbishment

8 work force must be provided in accordance with the Clean Air Act as amended.

The GElS states the following:

The 1990 Clean Air Act amendments include a provision that no federal agency shall

support any activity that does not conform to a state implementation plan designed to

achieve the National Ambient Air Quality Standards (NAAQS) fo& criteria pollutants

(sulfur dioxide, nitrogen dioxide, carbon monoxide, ozone, lead, and particulate matter

less than 10 pm in diameter). On November 30, 1993, the U.S. Environmental Protection

Agency (EPA) issued a final rule (58 FR 63214) implementing the new statutory

requirements, effective January 31, 1994. The final rule requires that federal agencies

prepare a written conformity analysis and determination for each pollutant where the

total of direct and indirect emissions caused by proposed federal action would exceed

4 5 established threshold emission levels in a nonattainment4 or maintenance area .

Exelon Generation is planning to replace the two TMI-1 steam generators with enhanced oncethrough steam generators. Exelon Generation stated that an additional 900 temporary

employees will be needed for the duration of the project, which is estimated to be 70 days

An area is designated "nonattainment" for a criteria pollutant if it does not meet the National Ambient Air

Quality Standard (NAAQS) for the pollutant.

A maintenance area has been redesignated by a State from nonattainment to attainment; the State must

submit to EPA a plan for maintaining the NAAQS as a revision to its State Implementation Plan.

June 2009 3-7 NUREG-1 437, Supplement 37
Environmental Impacts of Refurbishment

(AmerGen 2008). Exelon Generation and their steam generator vendor have determined the

steam generator route from Port Deposit, Maryland, to the TMI-1 site. The steam generators will

travel through Cecil County, Maryland, and Lancaster and Dauphin Counties in Pennsylvania.

During steam generator replacement project activities at the TMI-1 site some minor and shortduration air quality impacts are expected to occur. The main sources of these air quality impacts

will be fugitive dust from construction activities associated with the project and exhaust

emissions from the motorized equipment and vehicles of workers.

The majority of the refurbishment activities will be performed inside existing buildings and will

not cause additional atmospheric emissions. However, a permanent steam generator building

and several temporary facilities will be constructed and some land will be used for laydown

areas. During construction activities, some minor air quality impacts are expected to occur as a

result of equipment emissions and fugitive dust from the operation of earth-moving and materialhandling equipment. The small size of disturbed area and Exelon Generation's commitment to

use best management practices, such as watering, silt fences, covering soil piles, and

hydrodemolition, will minimize the amount of fugitive dust generated during operation of earthmoving and debris-hauling equipment.

Refurbishment activities are known to cause localized temporary increases in atmospheric

concentrations of nitrogen oxides (NOx), carbon monoxide, sulfur dioxide (SO2), volatile organic

compounds (VOCs), ammonia, and particulate matter (PM10 and PM2.

5) as a result of exhaust

emissions from workers' vehicles, diesel generators, and construction equipment. Federal

agencies are prohibited from issuing a license for any activity that does not conform to an

applicable implementation plan (40 CFR Part 51, "Requirements for Preparation, Adoption, and

Submittal of Implementation Plans," and 40 CFR Part 93, "Determining Conformity of Federal

Actions to State or Federal Implementation Plans"). TMI-1 is required to show conformity to the

applicable Pennsylvania State Implementation Plans by analyzing vehicle exhaust emissions

that will occur during the steam generator replacement project.

Exelon Generation stated, and the NRC staff has confirmed, that Cecil County, MD is in

attainment for all criteria pollutants. Dauphin County and Lancaster County are designated as

8-hour ozone maintenance and particular matter (PM2. 5) non-attainment areas. Using an EPAapproved screening model, Exelon Generation estimated the impacts of direct and indirect

ozone and particulate emissions related to refurbishment on air quality in the nonattainment

areas. The results of model calculations indicate that the emissions associated with the

refurbishment activities at TMI-1 will conform to the Pennsylvania State Implementation Plans

for the nonattainment areas (72 FR 40749).

PM2.

5 emissions from mobile sources are generated from three general processes--(1) direct

emissions from the tailpipes of cars, trucks, and other onroad vehicles, (2) reentrainment from

materials found on the roadway (typically known as fugitive dust), and (3) secondary formation

from precursor emissions such as SO2, NOx, VOCs and ammonia. EPA requires that PM2.5

conformity assessments consider NOx and SO2 emissions, however, VOC and ammonia

emissions need only be considered if they are significant. No such determination has been

made for Dauphin and Lancaster Counties.

NUREG-1437, Supplement 37 3-8 June 2009
Environmental Impacts of Refurbishment

Exelon Generation performed a preliminary screening analysis (using an EPA-approved model)

of the emissions during the construction and outage stages of the steam generator replacement

project for a period of 70 days.

Exelon Generation estimated total annual emissions of NOx during the construction stage to be

21.27 tons per year (ton/yr), which is 0.16 percent of the total 2001 Dauphin County emissions

and 21.27 percent of the EPA threshold level for this PM2.

5 precursor. Total NOx emissions

during the outage stage-were estimated to be 8.34 tons/yr, which is 0.06 percent of the total

2001 Dauphin County emissions and 8.34 percent of the EPA threshold level (AmerGen 2008a).

Total annual emissions of SO2 during the construction stage were estimated to be 0.59 tons/yr,

which is 0.01 percent of the total 2001 Dauphin County emissions. During the outage stage,

total SO2 emissions were estimated to be 0.12 tons/yr, which is less than 1 percent of the total

2001 Dauphin County emissions and 0.12 percent of the EPA threshold level (AmerGen 2008a).

Exelon Generation estimated total annual emissions of PM2.5 during the construction stage to be

1.5 tons/yr, which is 0.06 percent of the total 2001 Dauphin County emissions and 1.5 percent

of the EPA threshold level. During the outage stage, total PM2.

5 emissions were estimated to be

0.53 tons/yr, which is 0.02 percent of the total 2001 Dauphin County emissions and 0.53

percent of the EPA threshold level (AmerGen 2008a).

Dauphin County is part of the Harrisburg-Lebanon-Carlisle 8-hour ozone attainment area (basic

maintenance area). Ground-level ozone is formed when NOx and VOCs react in the presence

of heat and sunlight. Exelon Generation estimated total annual emissions of VOCs during the

construction stage to be 2.78 tons/yr, which is 0.02 percent of the total 2001 Dauphin County

emissions and 5.55 percent of the EPA threshold level. During the outage stage, total VOC

emissions were estimated to be 4.04 tons/yr, which is 0.03 percent of the total 2001 Dauphin

County emissions and 8.09 percent of the EPA threshold level (AmerGen 2008a).

Exelon Generation is in the process of obtaining all applicable permits and approvals from

Maryland and Pennsylvania State and local authorities. The transportation portion of the steam

generator replacement project at TMI-1 would cause short term increases in emissions, which

would not significantly affect Cecil, Dauphin and Lancaster counties' air quality. Emissions from

the transportation of the steam generators would remain below EPA threshold levels. The

results of the model calculations indicate that the emissions associated with the proposed action

conform to the implementation plans for the nonattainment areas. Total direct and indirect

emissions resulting from the replacement of the two TMI-1 steam generators are not expected

to exceed emission budgets specified in the Pennsylvania State implementation plans and

rates, established by the EPA, for nonattainment and maintenance areas as described in 40

CFR Part 51. On this basis, the NRC staff concludes that the impact of vehicle exhaust

emissions during the steam generator replacement project will be SMALL. The NRC staff

acknowledges that the applicant will use best management practices that could mitigate

potential air quality impacts resulting from the TMI-1 steam generator replacement project.

Additionally, the NRC staff also identified the use of staggered workforce shift changes to

reduce the number of vehicles on the road at any one given time.

June 2009 3-9 NUREG-1437, Supplement 37
Environmental Impacts of Refurbishment

3.2.4 Housing Impacts

Housing impacts during refurbishment is a Category 2 issue. Table B-1 of 10 CFR Part 51,

Subpart A, Appendix B, notes the following:

Housing impacts are expected to be of small significance at plants located in a

medium or high population area and not in an area where growth control

measure that limit housing development are in effect. Moderate or large housing

impacts of the workforce associated with refurbishment may be associated with

plants located in sparsely populated areas or in areas with growth control

measures that limit housing development.

Exelon Generation estimates that steam generator replacement would require a one-time

increase in the number of refueling outage workers for up to 70 days at TMI-1. Approximately

900 workers would be needed to perform TMI-1 steam generator replacement project activities

in addition to the normal number of refueling outage workers (AmerGen 2008).

The number of additional workers would cause a short-term increase in the demand for

temporary (rental) housing units in the region beyond what is normally experienced during a

I refueling outage at TMI-i. Since TMI-1 is located in a high population area, and Dauphin and

Lancaster counties are not subject to growth control measures that would limit housing

development, any changes in TMI-1 employment would have little noticeable effect on housing

availability in these counties. In addition,; the number of available housing units has kept pace

with or exceeded the increase in the county populations. However, the rental housing market in

the region is very large and based on this information, employment-related housing impacts

I would be SMALL.

3.2.5 Public Services - Education (Refurbishment)

Public services: education (refurbishment) is a Category 2 issue. Table B-1 of 10 CFR Part 51,

Subpart A, Appendix B, notes that "Most sites would experience impacts of small significance

but larger impacts are possible depending on site- and project-specific factors."

As discussed in Section 3.2.4, Exelon Generation estimates that TMI-1 steam generator

replacement would require a one-time increase in the number of refueling outage workers for up

to 70 days at TMI-1 (AmerGen 2008). Due to the short amount of time needed to replace the

steam generators, workers would not be'expected to bring families and school-age children with

them and therefore there would be no impact on educational services during this extended

refueling outage.

3.2.6 Public Services - Public Utilities

Public services: public utilities is a Category 2 refurbishment issue. Table B-1 of 10 CFR Part

51, Subpart A, Appendix B, notes that "An increased problem with water shortages at some

sites may lead to impacts of moderate significance on public water supply availability."

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Environmental Impacts of Refurbishment

Since there is no water shortage in the TMI-1 region and the public water systems located in

Dauphin and Lancaster Counties have excess capacity, any changes in TMI-1 and employee

public water usage would have little noticeable affect on public water supply availability in these

counties.

As discussed in Section 3.2.4, Exelon Generation estimates that steam generator replacement

would require a one-time increase in the number of refueling outage workers for up to 70 days

at TMI-1 (AmerGen 2008). The additional number of refueling outage workers needed to

replace the steam generators would cause a short-term increase in the amount of public water

and sewer services used in the immediate vicinity of TMI-1. Since the region has excess

capacity water supply impacts would be very SMALL.

3.2.7 Public Services - Transportation

Public services: transportation is a Category 2 refurbishment issue. Table B-1 of 10 CFR Part

51, Subpart A, Appendix B, notes the following:

Transportation impacts (level of service) of highway traffic generated during plant

refurbishment and during the term of the renewed license are generally expected

to be of small significance. However, the increase in traffic associated with

additional workers and the local road and traffic control conditions may lead to

impacts of moderate or large significance at some sites.

The additional number of refueling outage workers and truck material deliveries needed to

support the replacement of the steam generators would cause a short-term level. of service

impact on access roads in the immediate vicinity of TMI-1. As previously discussed in Section

2.2.8.2, major commuting routes to TMI-1, including State Highway 441, are mostly rural and

uncongested. Increased traffic volumes entering and leaving TMI-1 during refueling outages,

which occur at intervals of approximately 24 months, has not degraded the level of service

capacity on local roads. In addition, the TMI-1 site has two entrances. The entrance to the north

is used by the operating work force. The entrance to the south is used by a limited number of

operational employees working on the southern portion of the station and construction and

outage workforces. According to Exelon Generation, during the refurbishment project,

construction workers would use the southern entrance to the site. This could alleviate potential

congestion problems at the northern site entrance.

Based on this information and due to the short time duration (up to 70 days) for the steam

generator replacement project after the arrival of the steam generators, transportation (level of

service) impacts in the vicinity of TMI-1 would be SMALL and would only occur during shift

changes.

In addition, transporting the two new steam generators to TMI-1 would have a major impact on

roads, highways, and bridges from Port Deposit, Maryland, to the TMI-1 site in Pennsylvania.

Approximately 75 mi (121 km) of Federal, State, and local roads and highways in Maryland and

Pennsylvania would be used to transport the two new replacement steam generators.

The trip will take approximately 20 to 25 days because the special trailers carrying the two

steam generators can only travel about 5 miles per hour, and State law prohibits the movement

June 2009 3-11 NUREG-1437, Supplement 37
Environmental Impacts of Refurbishment

of the steam generators after dark. A convoy of escort vehicles will accompany the steam

generators as they travel north to TMI-1. Interferences, such as traffic signals, low-hanging

overhead telephone and power lines, and narrow roadway obstructions (e.g., guardrails) would

have to be moved or removed entirely (e.g. trees). At various points along the transportation

route, due to height restrictions and to avoid having to move large numbers of traffic signals and

overhead wires, the steam generators will travel north in the southbound lanes, against traffic.

Several bridges in Pennsylvania will also require overbridges, bracing, or other modifications to

carry the load. Three-inch steel plating will be used to prevent the collapse of pipe culverts and

stormwater pipes. Such activities would be temporary and localized causing short-term lane and

road closures as as traffic backups, delays, and detours. Once the steamr generator convoy has

passed, roadways would be reopened and traffic would return to normal levels. Any damage to

roadways, bridges, parking lots, buildings and other structures, stream crossings, and parks

caused by the movement of the steam generators will be repaired and/or paid for by Exelon

Generation's steam generator vendor, AREVA. Permits and approvals would be obtained from

the appropriate Federal, State, and local agencies prior to the movement of the steam

generators.

3.2.8 Offsite Land Use (Refurbishment)

Offsite land use (refurbishment) is a Category 2 issue. Table B-1 of 10 CFR Part 51, Subpart A,

Appendix B, notes that "Impacts may be of moderate significance at plants in low population

areas."

Since TMI-1 is located in a high population area any changes in TMI-1 employment would have

little noticeable affect on land use in the region. Due to the short amount of time needed to

replace the steam generators, the additional number of refueling outage workers would not

cause any permanent population- and tax revenue-related land use changes in the immediate

vicinity of TM I-i.

3.2.9 Historic and Archaeological Resources

Historic and archaeological resources are a Category 2 refurbishment issue. Table B-1 of 10

CFR Part 51, Subpart A, Appendix B, notes the following:

Generally, plant refurbishment and continued operation are expected to have no

more than small adverse impacts on historic and archaeological resources.

However, the National Historic Preservation Act requires the Federal agency to

consult with the State Historic Preservation Officer to determine whether there

are properties present that require protection.

The area potentially affected by the steam generator replacement project is in an area that was

previously disturbed by the construction of TMI-1 and TMI Unit 2. Ground disturbing activities

associated with the project include the excavation of previously disturbed areas in the vicinity of

TMI-1 and in several areas located south and west of the TMI Unit 2 cooling towers (AmerGen

2008b). A 5,000 ft2 (465 M2 ) storage facility built to house the old steam generators and other

NUREG-1437, Supplement 37 3-12 June 2009
Environmental Impacts of Refurbishment

temporary structures will be constructed within the existing industrial footprint of the site

(AmerGen 2008b).

Should Exelon Generation proceed with the steam generator project, all activities would be

reviewed in accordance with Exelon Generation's site procedures which are designed to ensure

that site investigations and consultations with the Pennsylvania Historical and Museum (PHMC;

Pennsylvania's State Historic Preservation Office, PA SHPO) are conducted as needed, and

that existing and unknown cultural resources are adequately protected. Exelon Generation has

consulted with the PHMC. The PHMC determined that the project would have no effect on

known historic and archaeological resources. However, should the project include additional

ground disturbing activities beyond what is currently planned, then further consultation and

mitigation would be necessary (PHMC 2009).

The delivery of the steam generators from the eastern shore of the Susquehanna River to TMI-1

could impact remnants of the Pennsylvania Canal's Eastern Division (Eastern Division Canal)

which ran on the east side of the Susquehanna River. Prehistoric and historic properties along

the route could be affected by vibrations from the movement of the heavy transporter over

roadways and bridges. However, most activities would be temporary and localized. Permits and

approvals would be obtained from the appropriate Federal, State, and local agencies prior to the

movement of the steam generators.

The impacts associated with this activity are not expected to adversely impact historic or

archaeological sites located in the vicinity of TMI-1 and TMI Unit 2. Therefore, the potential

impacts from this activity on historic or archaeological resources would be SMALL. However,

should archaeological resources be encountered during construction, work would cease until

Exelon Generation environmental personnel perform an evaluation and consider possible

mitigation measures through consultation with the PHMC.

3.2.10 Environmental Justice

Environmental justice is a Category 2 refurbishment issue. Table B-1 of 10 CFR Part 51,

Subpart A, Appendix B, notes that "The need for and the content of an analysis of

environmental justice will be addressed in plant specific reviews."

Since TMI-1 is located in a high population area any changes in TMI-1 employment would have

little noticeable effect on minority and/or low-income populations in the region. Due to the short

amount of time (up to 70 days) needed to replace the TMI-i steam generators and based on the

analysis of impacts for the other resource areas-discussed in Section 3.2, there would be no

disproportionately high and adverse impacts on minority and low-income populations located in

the immediate vicinity of TMI-1.

3.3 Evaluation of New and Potentially Significant Information on Impacts of

Refurbishment

For all Category 1 issues related to refurbishment, the NRC staff has not identified any new and

significant information during its review of the TMI-1 ER, the staff's environmental site audit, the

scoping process, or the evaluation of other available information, including the July 17, 2008

June 2009 3-13 NUREG-1437, Supplement 37
Environmental Impacts of Refurbishment

telephone conference call between NRC and Exelon Generation, during which, Exelon

Generation's refurbishment plans were discussed (NRC 2008). Therefore, the NRC staff adopts

the findings in the GElS for Category 1 issues associated with refurbishment, and concludes

that there would be no environmental impacts during the renewal term beyond those discussed

in the GElS for these issues.

3.4 Summary of Impacts of Refurbishment

For the nine Category 2 issues and environmental justice, the impacts of refurbishment at TMI-1

range from no impact to SMALL. For the refurbishment issues Public Services: Education,

Offsite Land Use, and Environmental Justice, the NRC staff concludes that there would be no

noticeable impact. For the refurbishment issues Terrestrial Ecology, Threatened or Endangered

Species, Air Quality (Nonattainment and Maintenance Areas), Housing Impacts, Public

Services: Public Utilities, Public Services: Transportation, and Historic and Archeological

Resources, the NRC staff concludes that the potential environmental effects are of SMALL

significance.

3.5 References

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

Regulations for Domestic Licensing and Related Regulatory Functions."

40 CFR 51. Code of Federal Regulations, Title 40, Protection of Environment, Part 51,

"Requirements for Preparation, Adoption, and Submittal of Implementation Plans."

I 40 CFR 93. Code of Federal Regulations, Title 40, Protection of Environment, Part 93,

"Determining Conformity of Federal Actions to State or Federal Implementations Plans."

72 FRN 40749. July 25, 2007. "Approval and Promulgation of Air Quality Implementation

Plans; Pennsylvania; Redesignation of the Harrisburg-Lebanon-Carlisle Ozone Nonattainment

Area to Attainment and Approval of the Area's Maintenance Plan and 2002 Base Year

Inventory." Federal Register. Volume 72, No. 142, pp. 40749. Washington, D.C.

AmerGen (AmerGen Energy Company, LLC). 2008. Three Mile Island Nuclear Station,

Applicant's Environmental Report, License Renewal Operating Stage. Kennett Square,

Pennsylvania. ADAMS Nos. ML080220255, ML080220257, ML080220261, and ML080220282.

AmerGen (AmerGen Energy Company, LLC). 2008a. Three Mile Island, Unit 1, Enclosure A -

Post Audit Environmental Information - Question ENV-070, Monthly Report on the

Meteorological Monitoring Program, March 2007 through End (Non-Proprietary Version). "TMI

Refurbishment Emissions.xls." Pp. 432-439. June 10. ADAMS No. ML082110253.

AmerGen (AmerGen Energy Company, LLC). 2008b. Three Mile Island, Unit 1, Enclosure A -

Post Audit Environmental Information - Index through Audit Question ENV-070, Monthly Report

on the Meteorology Program, February 2007 (Non-Proprietary Version). ADAMS No.

ML082110252.

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Environmental Impacts of Refurbishment

Clean Air Act. 42 U.S.C. 7401, et seq. United States Code, Title 42, The Public Health and

Welfare, Chapter 85, "Air Pollution Prevention and Control."

Clean WaterAct. 33 U.S.C. 26. United States Code, Title 33, Navigation and Navigable

Waters, Chapter 26, "Water Pollution Prevention and Control"

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

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

ADAMS No. ML061770605.

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

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

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

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

NRC (U.S. Nuclear Regulatory Commission). 2008. Summary of Telephone Conference Call

Held on July 17, 2008, Between the U.S. Nuclear Regulatory Commission and AmerGen

Energy Company, LLC, Concerning Follow-Up Questions Pertaining to the Three Mile Island

Nuclear Station, Unit 1 License Renewal Environmental Review and Site Audit. Washington,

D.C. ADAMS No. ML082120727.

PHMC (Pennsylvania Historical and Museum Commission). 2009. Letter from D. McLearen,

Chief, Archaeology and Protection Division, Bureau of Historic Preservation, Pennsylvania

Museum and Historical Commission, Harrisburg, Pennsylvania, to T. Scanlon, Michael Barker

Jr., Inc., Harrisburg, Pennsylvania. Subject: ER 2007-1737-043-F, COE: Proposed Temporary

Roadway and Bridge Improvements from Port Deposit, Maryland to Dauphin County,

Pennsylvania for Oversize Vehicles. March 23, 2009. ADAMS No. ML091130569.

June 2009 3-15 NUREG-1437, Supplement 37

4.0 ENVIRONMENTAL IMPACTS OF OPERATION

This chapter addresses potential environmental impacts related to the period of extended

operation of Three Mile Island Nuclear Station, Unit 1 (TMI-1). These impacts are grouped and

presented according to resource. Generic issues (Category 1) rely on the analysis provided in

the generic environmental impact statement (GELS) prepared by the U.S. Nuclear Regulatory

Commission (NRC) (NRC 1996, 1999) and are discussed briefly. NRC staff analyzed sitespecific issues (Category 2) for TMI-1 and assigned them a significance level of SMALL,

MODERATE, or LARGE. Some remaining issues are not applicable to TMI-1 because of site

characteristics or plant features. Section 1.4 of this report explains the criteria for Category 1

and Category 2 issues and defines the impact designations of SMALL, MODERATE, and

LARGE.

4.1 Land Use

Land use issues are listed in Table 4-1. The staff did not identify any Category 2 issues for land

use. The staff also did not identify any new and significant information during the review of the

environmental report (ER) (AmerGen 2008) prepared by Exelon Generation Company, LLC

(Exelon Generation), the site audit, or the scoping process. Therefore, there are no impacts

related to these issues beyond those discussed in the GELS. For these issues, the GElS

concludes that the impacts are SMALL, and additional site-specific mitigation measures are not

likely to be warranted.

Table 4-1. Land Use Issues. Section 2.2.1 of this report describes the land use

around TMI-1.

Issues GElS Section Category

Onsite land use 4.5.3 1

Power line right-of-way 4.5.3 1

4.2 Air Quality

The air quality issue applicable to TMI-1 is listed in Table 4-2. The staff did not identify any

Category 2 issues related to the effects of transmission lines on air quality. Staff also did not

identify any new and significant information during the review of Exelon Generation's ER

(AmerGen 2008), the site audit, or the scoping process. Therefore, there are no impacts related

to this issue beyond those discussed in the GELS. For these issues, the GElS concludes that

the impacts are SMALL, and additional site-specific mitigation measures are not likely to be

warranted.

Table 4-2. Air Quality Issue. Section 2.2.2 of this report describes air quality in the

vicinity of TMI-1.

Issue GElS Section Category

Air quality effects of transmission lines 4.5.2 1

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4.3 Ground Water

The following sections discuss the Category 2 ground water issues applicable to TMI-1, which

are listed in Table 4-3.

Table 4-3. Ground Water Use and Quality Issues. Section 2.2.3 of this report

discussed ground water use and quality at TMI-1.

Issues GElS Section Category

Ground Water use conflicts (potable and service water, 4.8.1.1 2

plants using >100 gpm)

Ground Water use conflicts (plants using cooling towers 4.8.1.3 2

withdrawing make-up water from a small river)

4.3.1 Ground Water Use Conflicts (plants using greater than 100 gpm)

The NRC specifies as issue 33 in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, that, "if

the applicant's plant... pumps more than 100 gallons (total onsite) of ground water per minute

(gpm), an assessment of the impact of the proposed action on ground water use must be

provided." The NRC further states that "plants that use more than 100 gpm may cause ground

water use conflicts with nearby ground water users," (10 CFR 51.53[c][3][ii][C]). This applies to

TMI-1 because, as discussed in Section 2.2.3.1 of this report, TMI-1 used between 95 and 115

gallons per minute (gpm) of ground water pumped from seven onsite wells from 2003 to 2005.

A ground water withdrawal rate of over 100 gpm has the potential to create a cone of

depression large enough to affect offsite wells and ground water supplies, limiting the amount of

ground water available for the area surrounding the plant. The Susquehanna River Basin

Commission (SRBC) originally approved ground water withdrawal at a rate of 168,750 gallons

per day (gpd) (117 gpm) at TMI-1 from wells A, B, and C after a process of simultaneous pump

tests in 1995. In 1998, TMI-1 applied to SRBC for a ground water withdrawal upgrade. Based on

information gathered during the original pumping tests, and after observing that there had been

no impacts on the operation of the onsite Operations Support Facility/North Office Building

(OSF) well, the Building 48 (48S) well, or any other onsite wells, or along the eastern shore of

the Susquehanna River, SRBC approved a new ground water withdrawal rate of 225,000 gpd.

After publication of the draft supplemental EIS, Exelon Generation submitted an application to

SRBC to utilize the existing OSF well for both potable and industrial purposes, with no increase

in the approved ground water withdrawal rate (Exelon Generation 2009).

After reviewing the information provided by the applicant, as well as the 1996 SRBC pump test

data from wells A, B, and C, which showed no effect on nearby ground water wells, the NRC

staff concludes that the impacts of TMI-1 ground water withdrawal on nearby ground water

users would be SMALL.

4.3.2 Ground Water Use Conflicts (make-up from a small river)

The NRC specifies that, "if the applicant's plant utilizes cooling towers or cooling ponds and

withdraws makeup water from a river whose annual flow rate is less than 3.15x1 012 cubic ft per

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Environmental Impacts of Operation

year (ft3/year) [(99,885 Cubic ft per second (cfs)] ... -[t]he applicant shall also provide an

assessment of the impacts of the withdrawal of water from the river on alluvial aquifers during

low flow," (10 CFR 51.53[c][3][ii][A]). For water use conflicts; the NRC further states, as issue 34

in Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 that, "water use conflicts may result

from surface water withdrawals from small water bodies during low flow conditions which may

affect aquifer recharge, especially if other ground water or upstream surface water users come

online before the time of license renewal...." This issue is applicable to TMI-1 because the plant

uses cooling towers, and makeup water for its cooling systems is withdrawn from the

Susquehanna River, which has an annual mean flow of approximately 1.09x1 012 ft3/yr (34,450

cfs), thus meeting the NRC's definition of a small.river. Flow is monitored at the Harrisburg

gauging station, about 11 mi (18 km) upstream of TMI-1.

Consumptive water losses at TMI-1 comprise a small fraction of the Susquehanna River flow at

Lake Frederick (which is created by the damming of the Susquehanna River by the Red Hill

Dam and the York Haven Dam), where TMI-1 is situated. The rate at which TMI-1 withdraws

surface water is about 1.6 percent of the lowest daily mean flow of the Susquehanna River,

which is less than 0.2 percent of the lowest annual mean flow and less than 0.1 percent. of the

average annual flow. TMI-1 is also part of the Cowanesque Lake water storage project, allowing

the site 8,274 acre-feet of storage. During a period of severe drought, SRBC can direct the

release of water to alleviate any impacts to the Susquehanna River caused by the consumptive

loss from plant operations, allowing for the continuation of TMI-1 operations.

Furthermore, the Commonwealth of Pennsylvania requires facilities that withdraw or use more

than 10,000 gpd (378,541 liters per day [Lpd]) of surface or ground water, such as TMI-1, to

register and periodically report their water usage for Commonwealth water planning purposes.

Thus, the NRC staff concludes that the impacts from consumptive water use on ground water

would be SMALL.

4.4 Surface Water

The following sections discuss the surface water quality issues applicable to TMI-1 which are

listed in Table 4-4. The staff did not identify any new and significant information during the

review of Exelon Generation's ER (AmerGen 2008), the site audit, or the scoping process.

Therefore, no impacts are related to these issues beyond those discussed in the GELS. For

these issues, the GElS concludes that the impacts are SMALL, and additional site-specific

mitigation measures are not likely to be warranted.

Table 4-4. Surface Water Quality Issues. Section 2.2.4 of this report describes

surface water quality conditions at TMI-1.

Issues GElS Section Category

Altered current patterns at intake and discharge 4.2.1.2.1 1

structures

Altered salinity gradients 4.2.1.2.2 1

Temperature effects on sediment transport capacity,- 4.2.1.2.3 1

Scouring caused by discharged cooling water 4.2.1.2.3 1

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Environmental Impacts of Operation

Issues GElS Section Category

Eutrophication 4.2.1.2.3 1

Discharge of chlorine or other biocides 4.2.1.2.4 1

Discharge of sanitary wastes and minor chemical spills 4.2.1.2.4 1

Discharge of other metals in wastewater 4.2.1.2.4 1

Water use conflicts (plants with cooling ponds or cooling

towers using make-up water from a small river with low 4.3.2.1; 4.4.2.1 2

flow)

4.4.1 Water Use Conflicts

The NRC specifies that, "if the applicant's plant uses cooling towers or cooling ponds and

withdraws makeup water from a river whose annual flow rate is less than 3.15X1 012 cubic feet

per year (ft3/year) [99,885 cubic feet per second (cfs)], an assessment of the impact of the

proposed action on the flow of the river and related impacts on instream and riparian ecological

communities must be provided" (10 CFR 51.53[c][3][ii][A]). For water use, conflicts, the NRC

further states as issue 13 in Table B-1 of Appendix B to Subpart A of 10 CFR Part 51, "The

issue has been a concern at nuclear power plants with cooling ponds and at plants with cooling

towers. Impacts on instream and riparian communities near these plants could be of moderate

significance in some situations." This issue is applicable to TMI-1 because the plant uses a

cooling-tower-based heat dissipation system. Water used to replace that lost to evaporation in

the cooling system is withdrawn from the Susquehanna River, which has an annual mean flow

of approximately 1.09x1 012 ft3/yr (34,450 cfs), thus meeting the NRC's definition of a small river.

Flow is monitored at the Harrisburg gauging station, about 11 mi (18 km) upstream of TMI-1.

In the GELS, surface water conflicts are considered a Category 2 issue for two reasons:

(1) Consumptive water use can adversely affect riparian vegetation and instream

aquatic communities. Reducing the amount of water available to either the

riparian zones or instream communities could result in impacts to threatened

and endangered species, wildlife, and recreational uses of the water body. In

addition, riparian vegetation performs several important ecological functions,

including stabilizing channels and floodplains, influencing water temperature

and quality, and providing habitat for aquatic and terrestrial wildlife.

(2) Continuing operation of these facilities depends on the, availability of water

within the river from which they are withdrawing water. For facilities that are

located on small bodies of water, the volume of water available is expected to

be susceptible to droughts and to competing water uses within the basin. In

cases of extreme drought, these facilities may be required to curtail

operations if the volume of water available is not sufficient.

An additional potential effect of the withdrawal of water from a small river is that the withdrawal

may have an impact on ground water levels and therefore, result in ground water use conflicts

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Environmental Impacts of Operation

(NRC 1996). The staff considers this to be a separate Category 2 issue, which is evaluated in

Section 4.3 of this supplemental environmental impact statement (EIS).

The Susquehanna River meets the definition of a small river because, based on data taken 11

mi (18 km) upstream of TMI-1 at Harrisburg, the annual mean flow of the river is 1.09x10 12 ft3/yr

(34,450 cfs). Currently, TMI-1 is permitted to consume up to 18 million gpd, with its average

estimated rate of withdraw being 24,000 gpm. The withdraws from TMI-1 are less than 1.6

percent of the Susquehanna River flow under the conditions of a typical drought period, less

than 0.2 percent of the lowest annual mean flow of the river, and less than 0.1 percent of the

average annual flow. In March 2009, Exelon Generation submitted an application to SRBC to

modify TMI-l's Consumptive Water Use Docket No. 19950302 from 18 million gpd to 19.2

million gpd to accommodate TMI-1 water needs for possible future operations. Surface water

withdrawals at TMI-1 were initiated prior to November 11,1995 (when surface water withdrawals

became subject to SRBC regulation) and have been in "grandfathered" status. Accordingly,

Exelon Generation has also requested a maximum daily/maximum 30-day average water

withdrawal of 122.8 million gpd (Exelon Generation 2009). These withdrawals are insignificant

relative to the flow in the Susquehanna River and would not be expected to impact the river's

aquatic and riparian ecological communities or the alluvial water-bearing material (aquifers).

Additionally, as detailed in Section 2.1.7.2 of this report, TMI-1 participates in the Cowanesque

Lake water storage project and sponsors 8,274 acre-feet of water storage. SRBC monitors the

flow of the Susquehanna River and, in the event of a drought emergency, it has the authority to

signal the U.S. Army Corps of Engineers to release predetermined quantities of water from

storage.

The staff has reviewed the available information, including that provided by the applicant,

additional SRBC data, information gathered at the staff's site visit and the scoping process, and

other available sources. Considering TMI-1's small consumptive water use relative to the flows

in the Susquehanna River, as well as the potential for SRBC to release water into the river

during periods of extreme drought, the NRC staff concludes that the impact of water use on the

Susquehanna River at TMI-1 would be SMALL.

4.5 Aquatic Resources

Table 4-5 on the following page lists the issues related to aquatic resources applicable to TMI-1.

No Category 2 issues are related to aquatic resource. The NRC staff did not identify any new

and significant information during the review of the Exelon Generation ER (AmerGen 2008), the

site audit, the scoping process, or the evaluation of other available information. Therefore, the

staff concludes that there would be no impacts related to these issues beyond those discussed

in the GElS (NRC 1996). Regarding these issues, the GElS concludes that the impacts are

SMALL, and additional site-specific mitigation measures are not likely to warrant

implementation.

June 2009 4-5 NUREG-1437, Supplement 37
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Table 4-5. Aquatic Resources Issues. Section 2.1.6 of this report describes the

TMI-1 cooling water system; Section 2.2.5 describes the aquatic

resources.

Issues GElS Section Category

For All Plants

Accumulation of contaminants in sediments or biota 4.2.1.2.4 1

Entrainment of phytoplankton and zooplankton 4.2.2.1.1 1

Cold shock 4.2.2.1.5 1

Thermal plume barrier to migrating fish 4.2.2.1.6 1

Distribution of aquatic organisms 4.2.2.1.6 1

Premature emergence of aquatic insects 4.2.2.1.7 1

Gas supersaturation (gas bubble disease) 4.2.2.1.8 1

Low dissolved oxygen in the discharge 4.2.2.1.9 1

Losses from predation, parasitism, and disease among 4.2.2.1.10 1

organisms exposed to sublethal stresses

For Plants with Cooling Tower-Based Heat Dissipation Systems

Entrainment of fish and shellfish in early life stages 4.3.3 1

Impingement of fish and shellfish 4.3.3 1

Heat shock 4.3.3 1

4.6 Terrestrial Resources

The issues related to terrestrial resources applicable to TMI-1 are discussed below and listed in

Table 4-6. There are no Category 2 issues are related to terrestrial resources for license

renewal. The NRC staff did not identify any new and significant information during the review of

the Exelon Generation ER (AmerGen 2008), the site audit, the scoping process, or the

evaluation of other available information. Therefore, the NRC staff concludes that there would

be no impacts related to these issues beyond those discussed in the GElS (NRC 1996).

Regarding these issues, the GElS concludes that the impacts are SMALL, and additional sitespecific mitigation measures are not likely to be sufficiently beneficial to implement.

Table 4-6. Terrestrial Resources Issues. Section 2.2.6 provides a description of the

terrestrial resources at TMI-1 and in the surrounding area.

Issues GElS Section Category

Cooling tower impacts on crops and ornamental

vegetation 4.3.4 1

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Issues GElS Section Category

Cooling tower impacts on native plants 4.3.5.1 1

Bird collisions with cooling towers 4.3.5.2 1

Power line right-of-way management (cutting herbicide 4.5.6.1 1

application)

Bird collisions with power lines 4.5.6.1 1

Impacts of electromagnetic fields on flora and fauna

(plants, agricultural crops, honeybees, wildlife, livestock)

Floodplains and wetland on power line right-of-way 4.5.7 1

4.7 Threatened or Endangered Species

Table 4-7. Threatened or Endangered Species. Section 2.2.7 describes the

threatened or endangered species on or near TMI-1.

Issue GElS Section Category

Threatened or endangered species 4.1 2

4.7.1 Aquatic Species

One Federally- and State-listed endangered species, the dwarf wedgemussel (Alasmidonta

heterodon), was recorded in Lancaster County, but not in the vicinity of TMI-I or in the

waterways along the transmission line corridors. The black bullhead (Amerius melas), a Statelisted species, has been recorded in Dauphin County (PNHP 2008), but is not known to occur

either in the vicinity of TMI-1 or in the waterways along the transmission line corridors

(AmerGen 2008).

The U.S. Fish and Wildlife Service (FWS) indicated by letter dated April 23, 2008, that no

Federally listed or proposed threatened or endangered species are known to occur within the

project impact area; hence no biological assessment or further consultation with FWS, as

required by the Endangered Species Act, is necessary (FWS 2008). The Pennsylvania Fish and

Boat Commission (PFBC) indicated by letter dated June 7, 2007, that no adverse impacts to

State-listed rare, candidate, threatened, or endangered aquatic species are expected from the

proposed project (PFBC 2008).

4.7.2 Terrestrial Species

An evaluation of impacts to threatened and endangered terrestrial species requires consultation

with appropriate agencies to determine whether such species are present and whether they

would be adversely affected by continued operation of the TMI-1 site during the license renewal

term. Sections 2.2.6 and 2.2.7 of this supplemental EIS discuss the characteristics and habitat

of threatened and endangered species in the vicinity of the TMI-1 site.

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The NRC staff contacted FVVS, the Pennsylvania Department of Conservation and Natural

Resources (DCNR), and the Pennsylvania Game Commission (PGC) to request information that

could assist in assessing the environmental impacts associated with license renewal. In

response, on April 28, 2008, the FWS indicated that no known Federally-listed threatened or

endangered species occur within the project area; therefore, the proposed project would not

likely adversely affect any Federally-listed species (FWS 2008). In a May 2, 2008,letter to the

NRC, DCNR stated that, although several species of concern are known to occur in the vicinity

of the TMI-1 project site, no impact to these species is anticipated (DCNR 2008). In a May 14,

2008, letter to the NRC, PGC indicated that, "the renewal of the TMI Operating License is not

anticipated to cause any adverse impacts to special concern species of birds and mammals that

may be in the vicinity of the transmission line corridors associated with the electric generating

station" (PGC 2008).

Two Federally-listed threatened or endangered species, the bog turtle (Glyptemys muhlenbergi)

and the northeastern bulrush (Scirpus ancistrochaetus), are potentially found in the vicinity of

the TMI-1 site (PNHP 2008). The bald eagle (Haliaeetus leucocephalus) and the peregrine

falcon (Falco peregrinus) were formerly listed as Federally-threatened. Eleven State-listed

threatened or endangered species have been determined to be species of special concern for

the TMI-1 site, including the osprey (Pandion haliaetus), the prothonotary warbler (Protonotaria

citrea), the yellow-crowned night heron (Nycticorax violacea), the black-crowned night heron

(Nycticorax nyticorax), the aster-like boltonia (Boltonia asteroides), a sedge species (Carex

shortiana), the flat-stemmed spike-rush (Eleocharis compressa), the ellisia (Ellisia nyctelea), the

bronze copper (Lycaena hyllus), and the formerly Federally-listed birds, the bald eagle and

peregrine falcon (DCNR 2008; PGC 2008; AmerGen 2008; PNHP 2008)., Section 2.2.7 of this

report describes these species in greater detail.

The NRC staff encourages Exelon Generation and FirstEnergy Corporation (FirstEnergy), who

owns the transmission lines, to report the existence of any Federally- or State-listed endangered

or threatened species within or near the transmission line right-of-ways (ROWs) to DCNR or

FWS or both, if any such species are identified during the license renewal term. In particular, if

any evidence of injury to or mortality of migratory birds or threatened or endangered species is

observed within the corridor during the license renewal period, the NRC staff encourages

Exelon Generation and FirstEnergy to promptly report this to the appropriate wildlife

management agencies. Additionally, the NRC staff encourages Exelon Generation to continue

reporting information concerning the peregrine falcon pair and their young that nest on the

reactor building to the Commonwealth of Pennsylvania.

Operation of the TMI-1 site and its associated transmission lines is not expected to adversely

affect any threatened or endangered species during the license renewal term. Therefore, the

NRC staff concludes that adverse impacts to threatened or endangered species during the

period of extend operation would be SMALL. The following mitigation measures are currently in

place at the TMI-1 site are found to be adequate and minimize the effects of plant operation on

terrestrial species. They include: nest construction and placement for several species (including

the peregrine falcon and osprey), environmental review checklists, environmental evaluation

forms, and best management practices.

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4.8 Human Health

The human health issues applicable to TMI-1 are discussed below and listed in Table 4-8 for

Category 1, Category 2, and uncategorized issues. Category 1 issues are discussed further in

Section 4.8.1, and Category 2 and uncategorized issues are discussed in Sections 4.8.2

through 4.8.4.

Table 4-8. Human Health Issues. Table B-1 of Appendix B to Subpart A of 10 CFR

Part 51 contains more information on these issues.

Issues GElS Section Category

Microbiological organisms (occupational health) 4.3.6 1

Microbiological organisms (public health, for plants 4.3.6 2

using small rivers)

Noise 4.3.7 1

Radiation exposures to public (license renewal term) 4.6.1, 4.6.2 1

Occupation radiation exposures (license renewal term) 4.6.3 1

Electromagnetic fields - acute effects (electric shock) 4.5.4.1 2

Electromagnetic fields - chronic effects 4.5.4.2 Uncategorized

4.8.1 Generic Human Health Issues

The staff did not identify any new and significant information during its review of the Exelon

Generation ER, the site audit, or the scoping process. Therefore, there are no impacts related to

Category 1 human health issues beyond those discussed in the GELS. For these Category 1

issues, the GElS concluded that the impacts are SMALL, and additional site-specific mitigation

measures are not likely to be sufficiently beneficial to be warranted.

TMI-1 conducts an annual Radiological Environmental Monitoring Program (REMP) in which

radiological impacts to the public and the environment surrounding the TMI-1 site are monitored,

documented, and compared to the appropriate standards. The objectives of the REMP are to:

" Measure and evaluate the levels of radiation and radioactive material in the environs

around the TMI-1 site to assess the radiological impacts, if any, of plant operation on the

environment.

* Supplement the results of the radiological effluent monitoring program by verifying that

the measurable concentrations of radioactive material and levels of radiation are not

higher than expected based on the measurement of radioactive effluents and modeling

for the applicable exposure pathways.

" Demonstrate compliance with the requirements of applicable Federal regulatory

agencies.

Two reports summarize radiological information about the TMI-1 site-the annual radiological

environmental operating report and the annual radioactive effluent release report. The TMI-1

offsite dose calculation manual (ODCM) specifies limits for all radiological releases (AmerGen

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2007). The ODCM is used to meet Federal standards and requirements. The TMI-1 REMP

samples environmental media in the environs around the site to analyze and measure the

radioactivity levels that may be present. The media samples are representative of the radiation

exposure pathways to the public from all plant radioactive effluents. The REMP measures the

aquatic and atmospheric environment, as well as the ambient gamma radiation, for radioactivity

in the vicinity of the TMI-1 site. Ambient gamma radiation pathways include radiation from

buildings and plant structures and airborne material that may be released from the plant. In

addition, the REMP also measures background radiation (i.e., cosmic sources, global fallout,

and naturally occurring radioactive material, including radon). Thermoluminescent dosimeters

(TLDs) are used to measure direct radiation. The atmospheric environmental monitoring

consists of sampling the air for particulates and radioiodine. Terrestrial environmental

monitoring consists of analyzing samples of milk and food products. The aquatic environmental

monitoring consists of analyzing samples of surface water, drinking water, stormwater, ground

water, and fish and sediment from the Susquehanna River.

The NRC staff reviewed the TMI-1 radioactive environmental operating reports for 2003 through

2007 to look for any significant impacts to the environment or any unusual trends in the data

(AmerGen 2004, 2005, 2006b, 2007a, 2008a). During 2007, no plant-related activation or fission

products were detected in airborne and foodborne samples. The only radionuclide attributable to

plant operation detected in 2007 was tritium, which was measured in samples of surface, storm,

effluent, and drinking water (AmerGen 2008a). No unusual trends were noted and all reported

data on the radionuclides'detected in environmental samples were below applicable NRC

reporting levels and showed no significant or measurable impact from the operations at TMI-1

(AmerGen 2008a).

The Pennsylvania Department of Environmental Protection (PADEP), Bureau of Radiation

Protection (BRP), also conducts a comprehensive environmental radiation monitoring program

in Pennsylvania that routinely samples and analyzes selected environmental media in

conjunction with TMI-1. The BRP environmental radiation monitoring program includes TLDs for

monitoring direct radiation and samples of air, vegetation, milk, drinking water, fish, and river

sediment. The results of the BRP 2003-2004 environmental radiation monitoring program

showed detectable levels of radioactivity attributable to operation of TMI-1. In 2003, low levels of

tritium were detected in drinking water samples near the plant site, but no reactor-produced

radionuclides were detected in the fish, produce, air or milk samples. However, radioactivity

from remnants of atomic weapons testing and the accident at Chernobyl was detected in water

and milk samples. The report concluded, "The results of the 2003 and 2004 environmental

sampling program indicate that Pennsylvanians have not been exposed to levels of radiation

above normal background. This has been determined by comparing samples collected around

nuclear facilities with those from locations that would not be influenced by such facilities."

(PADEP 2008).

In addition to the routine REMP, the applicant established an onsite ground water protection

program in 2006. The program is designed to monitor the onsite environment for indication of

leaks from plant systems and pipes carrying liquids with radioactive material. The results were

reported as Appendix F to the TMI-1 2007 annual radiological environmental operating report.

The results indicated that tritium was detected in 15 ground water samples at three locations at

concentrations greater than the U.S. Environmental Protection Agency (EPA) drinking water

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standard (and the NRC reporting limit) of 20,000 picocuries per liter (pCi/L) (740,000 Becquerels

per cubic meter [Bq/m 3]). Tritium was detected in 47 of 68 ground water monitoring locations.

The tritium concentrations ranged from 206 pCi/L (7622 Bq/m 3) to 29,600 pCi/L (1,095,200

Bq/m 3). Tritium that was detected in ground water at the station is believed to have been from a

leak in the condensate de-ice line, historical releases, or background radiation or all three.

There were no known active releases into the ground water at the TMI-1 site at the end of 2007.

Based on the sample results, the applicant calculated that the potential dose to a member of the

public from drinking this water was less than 0.008 millirems (mrem) (0.00008 milliSeiverts

[mSv]). This dose is a very small fraction of the dose design objective specified in Appendix I to

10 CFR Part 50, "Numerical Guide for Design Objectives and Limiting Conditions for Operation

to Meet the Criterion 'As Low as is Reasonably Achievable' for Radioactive Material in LightWater-Cooled Nuclear Power Reactor Effluents."

Historical data of releases from TMI-1 and the resultant dose calculations demonstrate that the

amount of radiation received to a hypothetical maximally exposed individual in the vicinity of

TMI-1 is a small fraction of the limits specified in 10 CFR Part 20, the as low as is reasonably

achievable (ALARA) dose design objectives in Appendix I to 10 CFR Part 50, and EPA's

radiation standards in 40 CFR Part 190, "Environmental Radiation Protection Standards for

Nuclear Power Operations." For 2007, dose estimates were calculated based on actual liquid

and gaseous effluent release data and conservative models to simulate the transport

mechanisms. The TMI-1 2007 annual radioactive effluent release report (AmerGen 2008b)

describes the results. The following summarizes the calculated hypothetical maximum dose to

an individual located at the TMI-1 site boundary from liquid and gaseous effluents released

during 2007:

• The maximum whole-body dose to an offsite member of the general public from liquid

effluents was 0.056 mrem (0.00056 mSv), which is well below the 3-mrem dose criterion

in 10 CFR Part 50, Appendix I.

* The maximum air dose at the site boundary from gamma radiation in gaseous effluents

was 0.000365 mrad (0.00000365 mGy), which is well below the 1 0-mrad dose criterion

in 10 CFR Part 50, Appendix I.

* The maximum air dose at the site boundary from beta radiation in gaseous effluents was

0.000326 mrad (0.00000326 mGy), which is well below the 20-mrad dose criterion in 10

CFR Part 50, Appendix I.

* The maximum organ dose (child thyroid) to an offsite member of the general public from

radioactive iodine, tritium, and particulates in gaseous effluents was 0.00814 mrem

(0.0000814 mSv), which is well below the 15-mrem dose criterion in 10 CFR Part 50,

Appendix I.

" The maximum whole-body dose to an offsite member of the general public from all

radioactive emissions (radioactive gaseous and liquid effluents and direct radiation

shine) was 0.33 mrem (Q.0033 mSv), below the 25-mrem standard in EPA's 40 CFR

Part 190.

Based on the review and assessment of the TMI-1 radioactive waste system performance in

controlling radioactive effluents and the resultant doses to members of the public in

conformance with the ALARA criteria, the NRC staff found that the 2007 radiological data for

TMI-1 are consistent, with reasonable variation attributable to operating conditions and outages,

with the 5-year historical radiological effluent releases and resultant doses. These results

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demonstrate that TMI-1 is operating in compliance with Federal radiation protection standards

contained in 10 CFR Part 50, Appendix 1, 10 CFR Part 20, and 40 CFR Part 190. Continued

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

the impacts from radioactive effluents are not expected to change.

The applicant plans to conduct refurbishment activities (i.e., replacement of steam generators)

during the license renewal term. The applicant is expected to maintain radiological releases in

accordance with its ODCM and regulatory requirements as it has in the past. Thus, the

refurbishment activities are not expected to generate an amount of radioactive material that is

significantly different from the historical radiological effluent releases which included refueling

outage activities. The staff concludes that the dose to a member of the public and to plant

workers from TMI-1 during routine operation and refurbishment activities is expected to continue

to be a small fraction of the dose limits and standards specified in 10 CFR Part 20, 10 CFR Part

50, Appendix I, and 40 CFR Part 190. Therefore, based on there being no significant difference

in radiological effluents with the addition of the refurbishment activities from the historical

radiological effluent levels, the impacts from radioactive effluents are not expected to change.

4.8.2 Microbiological Organisms - Public Health

Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 lists the effects of thermophilic

microbiological organisms on human health as a Category 2 issue and requires the conduct of a

plant-specific evaluation before license renewal for those plants using closed-cycle cooling that

are located on a small river. The average annual flow of the Susquehanna River at the nearest

measuring station to TMI-1 is approximately 1.09x1 012 ft3/yr (3.08x1 010 cubic meters per year

(m3/yr)) (Durlin and Schaffstall 2005). This is less than the 3.15x1 012 ft3

/yr (9x1 010 m3/yr), which

is the threshold value in 10 CFR 51.53(c)(3)(ii)(G) for thermal discharge to a small river.

Nevertheless, recreational uses of the Susquehanna River in the vicinity of TMI-1, which include

boating, fishing, and swimming, create the potential for human exposure to thermophilic

microbiological organisms. Consequently, the effects of its discharge on microbiological

organisms must be addressed for TMI-1 license renewal.

The Category 2 designation is based on the magnitude of the potential public health impacts

associated with thermal enhancement of enteric pathogens such as Salmonella spp. and

Shigella spp., the Pseudomonas aeruginosa bacterium, the pathogenic strain of the free-living

amoebae Naegleria spp., and a number of species from genus Legionella (NRC 1996).

Thermophilic biological organisms generally occur at temperatures of 77 to 176 degrees

Fahrenheit (OF) (25 to 80 degrees Celsius (°C)), with optimal growth occurring between 122 and

150 OF (50 and 66 °C) and minimum tolerance of 68°F (20 'C) (Joklik and Willett 1976).

However, thermal preference and tolerances vary across the bacteria family.

P. aeruginosa is an opportunistic pathogen that causes serious and sometimes fatal infections

in immunocompromised individuals by producing and releasing toxins. It has an optimal growth

temperature of 99 OF (37 °C) (Todar 2007). Legionella spp. consists of at least 46 species and

70 serogroups and is responsible for Legionnaires' disease, with the onset of pneumonia in the

first 2 weeks of exposure. Risk groups for Legionella spp. include the elderly, cigarette smokers,

persons with chronic lung or immunocompromising disease, and persons receiving

immunosuppressive drugs. Legionella spp. grows best at 90 to 105 OF (32 to 41 °C) (CDC

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2007). Salmonella typhimurium and Salmonella enteritidis are two of the more common species

of Enterobacteriaceae which cause fever, abdominal cramps, and diarrhea. Salmonella spp. can

occasionally establish localized infection (e.g., septic arthritis) or can progress to sepsis. All

ages can be affected, but groups at greatest risk for severe or complicated disease include

infants, the elderly, and persons with compromised immune systems. Salmonella spp. occurs at

temperatures between 50 and 120 OF (10 and 49 'C) (CDC 2007), with optimal growth occurring

at 95 to 99 0F (35 to 37 °C) (ESR 2002). The pathogenic amoeba flagellate Naegleria fowleri is

the causative agent of human primary amoebic meningioencephalitis. All ages can be affected,

but groups at greatest risk for severe or complicated disease include infants, the elderly, and

persons with compromised immune systems. Naegleria spp. is ubiquitous in nature and can be

enhanced in thermally altered water bodies at temperatures ranging from 95 to 106 OF (35 to 41

°C) or higher, but this organism is rarely found in water cooler than 95 OF (35 °C), and infection

rarely occurs at these water temperatures (Tyndall et al. 1989).

The maximum temperature of the discharge stream on September 11, 2007, was approximately

101.1 OF (38.4 °C), with a maximum ambient river temperature of 81.5 OF (27.50C) (AmerGen

2008). As described in the GElS (NRC 1996), nuclear power plants that discharge to "small

rivers" have the greatest chance of affecting the public by increases in thermophilic

microbiological organism populations. A small river is defined as one with a monthly average

flow rate of less than 2,800 m3/s (100,000 ft3/s). The annual average flow rate of the

Susquehanna River at the nearest measuring station to TMI-1 is approximately 1.09x1012 ft3

/yr

(3.08x10 l0 m3/yr), which equates to 978.1 cubic meters per second (m3

/s) (34,540 cubic feet per

second (ft3/s)) (Durlin and Schaffstall 2005). The average flow rate from the main station outfall

is about 12,000 gpm (11.4 ft3/s). This flow rate is less than 1 percent of the annual average flow

rate of the Susquehanna River. Thus, at a given volume of the discharge stream with a maximal

temperature of 101.1 OF (38.4 °C), there will be approximately 100 equivalent diluting volumes

of the Susquehanna River water with a maximal temperature of 81.5 °F (27.5 9C). When a

higher temperature system comes in physical contact with a lower temperature system, there

will be a net transfer of heat from the higher temperature system to the lower temperature

system, until the two systems reach thermal equilibrium (Adkins 1984). As such, when the plant

discharge temperature is at its maximum and the ambient Susquehanna River water is at its

maximum, the temperature range of the Susquehanna River (below the discharge outfall) would

maximally be 91.3 °F (33.0 'C). This temperature range is well outside the optimal growth

temperature range of thermophilic microbiological organisms, which is between 122 OF and 150

°F (50 and 66 °C) (Joklik and Willett 1976). Hence, such organisms are not expected to cause

any significant public health risks.

During the year, ambient river temperatures average 33.8 OF (1 0C) with a maximum

temperature of 81.5 OF (27.5 °C) (NRC 1976). The maximum temperature of the discharge

stream (at the discharge monitoring pit and before the water mixes with the Susquehanna River)

on September 11, 2007, was approximately 101.1 °F (38.4 0C) (AmerGen 2008). The ambient

river temperature was 81.5 OF (27.5 0C). Assume the temperature of the heated effluent area or

mixing zone is 101.1 °F (38.4 °C), the lowest daily mean river flows are 34,540 ft3

/s (978.1 m3/s)

(Durlin and Schaffstall 2005), and the mixing zone is located 16 feet (4.88 meters) offshore and

82 feet (25 meters) downstream of the discharge monitoring pit (AmerGen 2008). These

thermophilic microbiological organisms would be entrained through this thermal plume for about

30 seconds to less than five minutes, based on a river flow rate of 34,540 ft3

/s (978.1 m3

/s).

Because the growth rate for thermophilic microbiological organisms is measured in hours to

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days (Hendricks 1972), it is not expected that the short period of plume passage would notably

affect growth rates of thermophilic microbiological organisms compared to ambient river

temperatures. Therefore, thermophilic microbiological organisms are not expected to cause any

significant public health risks.

The current National Pollutant Discharge Elimination System (NPDES) permit requires TMI-1 to

monitor fecal coliform in the plant's sewage treatment effluent. Fecal coliform bacteria are

classified within the family Enterobacteriaceae. The most common species of fecal coliform is

Escherichia coli, a prokaryotic, gram-negative, rod-shaped bacteria. The value of determining

fecal coliform concentrations is to establish the extent to which the Susquehanna River has

been polluted with fecal wastes. Their presence in the water indicates the potential for other

pathogenic microbes, including those that cause typhoid fever, bacterial or viral gastroenteritis,

or hepatitis A (NAS 2004). TMI-1 has been collecting river water samples once per quarter for

fecal coliform analysis and has been implementing a disinfection program of the TMI-1 sewage

treatment plant effluent in compliance with TMI-1 NPDES permit requirements. In addition, the

NPDES permit requires TMI-1 to control disease-producing organisms during the swimming

season (May 1 through September 30) through "effective disinfection" and to impose a fecal

coliform count limit of 200 cells per 100 milliliters.

Exelon Generation consulted the PADEP Water Management Program to determine whether or

not there was any concern about the potential occurrence of thermophilic microbiological

organisms in the Susquehanna River at the TMI-1 location (AmerGen 2008). PADEP indicated

that it agrees with Exelon Generation's conclusion that the discharge of cooling water from the

operation of TMI-1 over the license renewal term would not stimulate growth of thermophilic

pathogens (AmerGen 2008).

Available data assembled by the U.S. Centers for Disease Control and Prevention (CDC) for the

years 1999 to 2004 (CDC 2001, 2002, 2002a, 2003, 2003a, 2004, 2005, 2006, 2007b) report no

occurrence of waterborne disease outbreaks in the Commonwealth of Pennsylvania resulting

from exposure to the thermophilic microbiological organisms Naegleria fowleri and

Pseudomonas aeruginosa from the operation of TMI-1. Outbreaks of legionellosis,

samonellosis, or shigellosis that occurred in the Commonwealth of Pennsylvania were within the

range of national trends (CDC 2001, 2002, 2002a, 2003, 2003a, 2004, 2005, 2006, 2007b) in

terms of cases per 100,000 population or total cases per year, and the outbreaks were

associated with hotel pools and spas.

The NRC staff independently reviewed the Exelon Generation ER and visited the TMI-1 site.

Based on the evaluation previously stated, thermophilic microbiological organisms are not likely

to present a public health hazard as a result of TMI-1 discharges to the Susquehanna River.

The NRC staff concludes that impacts on public health from thermophilic microbiological

organisms from continued operation of TMI-1 in the period of extended operation would be

SMALL.

The staff identified a variety of measures that could mitigate the potential impacts of

thermophilic microbiological organism resulting from continued operation of TMI-1. These

mitigation measures include periodically monitoring for thermophilic microbiological organisms

in the water and sediments near the discharge, as well as prohibiting recreational use near the

discharge plume. These mitigation measures could reduce human health impacts by minimizing

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public exposures to thermophilic microbiological organisms. The staff did not identify any costbenefit studies applicable to the mitigation measures previously mentioned.

4.8.3 Electromagnetic Fields - Acute Effects (Electric Shock)

Based on the GELS, the NRC found that electric shock resulting from direct access to energized

conductors or from induced charges in metallic structures has not been a problem at most.

operating plants and generally is not expected to be a problem during the period of extended.

operation. However, a site-specific review is required to determine the significance of the

electric shock potential along the portions of the transmission lines within the scope of the

supplemental EIS.

The GElS states that, without a review of the conformance of each nuclear plant transmission

line with National Electrical Safety Code (NESC) (NESC 2007) rules, it is not possible to

determine the significance of the electric shock potential. Evaluation of individual plant

transmission lines is necessary because the issue of electric shock safety was not addressed in

the licensing process for some plants. For other plants, land use in the vicinity of transmission -

lines may have changed, or power distribution companies may have chosen to upgrade line

voltage. To comply with the requirements of 10 CFR 51.53(c)(3)(ii)(H), the applicant must

provide an assessment of the potential shock hazard if the transmission lines that Were

constructed for the specific purpose of connecting the plant to the transmission system do not

meet the recommendations of the NESC for preventing electric shock from induced currents.

An analysis of the conformance of the TMI-1 transmission lines with the NESC standard was

conducted using computer-modeled data of induced current under the transmission lines.

Objects located near the transmission lines can become electrically charged because of their

immersion in the electromagnetic field surrounding the lines. This electrical charge results in a

current that flows through the object to the ground. This current is called "induced" because

there is no direct connection between the line and the object. The induced current can also flow

to the ground through the body of a person who touches the electrically charged object. An

object that is insulated from the ground can actually store an electrical charge, becoming what is

called "capacitively charged." A person standing on the ground and touching a vehicle or a

fence receives an electrical shock from the sudden discharge of the capacitive charge through

the person's body to the ground. After the initial discharge, a steady-state current can develop,

with the magnitude of the current depending upon several factors. These factors include the

strength of the electric field (dependent on the voltage of the transmission line and its height and

geometry), the size of the object on the ground, and the extent to which the object is grounded

(AmerGen 2008).

As described above, four 230-kilovolt (kV) transmission lines were specifically constructed to

distribute power from TMI-1 to the electrical grid. Exelon Generation began its analysis of these

lines by identifying the limiting case for each line, that is, the configuration along each line where

the potential for induced-current shock would be greatest. Once the limiting case was identified,

the electric field strength for each transmission line was calculated, and the induced current was

calculated. Exelon Generation calculated electric field strength and induced current using a

computer code called ACDCLINE, produced by the Electric Power Research Institute. The,

results of this program have been field-verified through actual electrostatic field measurements

by several utilities. The input parameters for the ACDCLINE program include the design

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features of the limiting-case scenario, the NESC requirement that line sag be determined at a

conductor temperature of 120 OF, and the maximum vehicle size under the lines (a tractortrailer). The analysis determined that none of the transmission lines has the capacity to induce

greater than 5 milliamperes in a Vehicle parked beneath the lines (Table 4-9). Therefore, the

TMI-1 transmission lines conform to the NESC provisions for preventing electric shock from

induced current (AmerGen 2008).

FirstEnergy has surveillance and maintenance procedures that provide assurance that design

ground clearances will not change. These procedures include routine aerial inspections that

check for evidence of clearance problems, including encroachments, broken conductors, broken

or leaning structures, and signs of burning trees. In addition, ground-level inspections include

examination of clearances at questionable locations, evaluation of the integrity of structures,

and surveillance for dead or diseased trees that may fall on the lines. Problems noted during

any inspection are identified for corrective action by the appropriate organization (AmerGen

2008).

Table 4-9. Results of Induced Current Analysis.

Maximum Induced

Transmission Line (kilovolts) Current

(kiloolts)(milliamperes)

Line No. 1051-TMI-1 plant to Jackson 230 1.09

Line No. 1091-TMI-1 plant to Middletown Junction 230 1.38

Line No. 1092-TMI-1 plant to Middletown Junction 230 2.09

Line from TMI-1 plant to the 500-kV substation 230(a) 1;33

(a) Line from TMI-1 plant to the 500-kV substation Was designed to operate at 500 kilovolts, but it

currently operates at 230 kilovolts

Source: AmerGen 2008

The staff has reviewed the available information, including the applicant's evaluation and

computational results, the site visit, the scoping process, and other public sources of

information. Based on this information, the staff evaluated the potential impacts of electric shock

resulting from operation of TMI-1 and its'associated transmission lines. The staff concludes that

the potential impacts of electric shock during the renewal term would be SMALL.

The staff identified a variety of measures that could mitigate potential acute electromagnetic

field impacts resulting from continued operation of the TMI-1 transmission lines. These

mitigation measures include limiting public access to transmission line structures, installing

signs at road crossings warning against idling beneath the lines, and increasing transmission

line clearances.

These mitigation measures could reduce human health impacts by minimizing public exposures

to electric shock hazards. NESC rules, as specified in Part 2, Rules 232C1c and 232D3c,

contain provisions that are considered necessary for the protection of employees and the public

from acute electromagnetic field hazards associated with transmission lines, which currently

apply to TMI-1 and would apply during the period of extended operation. Exelon Generation

currently meets these rules. The staff did not identify any cost benefit studies applicable to the

NUREG-1437, Supplement 37 4-16 June 2009
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mitigation measures mentioned above.

4.8.4 Electromagnetic Fields - Chronic Effects

The GElS did not designate the chronic effects of 60-hertz electromagnetic fields from power

lines as either Category 1 or 2; such a designation will not occur until a scientific consensus is

reached on the health implications of these fields.

The potential for chronic effects from these fields continues to be studied and is not known at

this time. The National Institute of Environmental Health Sciences (NIEHS) directs related

research through the U.S. Department of Energy (DOE). An NIEHS (1999) report contains the

following conclusion which is supported by the recently published Environmental Health Criteria

Monograph No. 238 (2007):

The NIEHS concludes that ELF-EMF [extremely low frequency-electromagnetic

field] exposure cannot be recognized as entirely safe because of weak scientific

evidence that exposure may pose a leukemia hazard. In our opinion, this finding

is insufficient to warrant aggressive regulatory concern. However, because

virtually everyone in the United States uses electricity and therefore is routinely

exposed to ELF-EMF, passive regulatory action is warranted such as a continued

emphasis on educating both the public and the regulated community on means

aimed at reducing exposures. The NIEHS does not believe that other cancers or

non-cancer health outcomes provide sufficient evidence of a risk to currently

warrant concern.

This statement is not sufficient to cause the NRC staff to change its position with respect to the

chronic effects of electromagnetic fields. This position is expressed in Footnote 5 to Table B-1 of

Appendix B to Subpart A of 10 CFR Part 51 as follows:

If in the future, the Commission finds that, contrary to current indications, a

consensus has been reached by appropriate Federal health agencies that there

are adverse health effects from electromagnetic fields, the Commission will

require applicants to submit plant-specific reviews of these health effects as part

of their license renewal applications. Until such time, applicants for license

renewal are not required to submit information on this issue.

The NRC staff considers the GElS finding of "uncertain" still appropriate and will continue to

follow developments on this issue.

4.9 Socioeconomics

The socioeconomic issues applicable to TMI-1 follow in Table 4-10 on the following page for

Category 1, Category 2, and uncategorized issues.

June 2009 4-17 NUREG-1437, Supplement 37
Environmental Impacts of Operation

Table 4-10. Socioeconomic Issues. Section 2.2.9 of this report describes the

socioeconomic conditions near TMI-1.

Issues GElS Section Category

Housing Impacts 4.7.1 2

Public Services: public safety, social services, and 4.7.3; 4.7.3.3; 1

tourism and recreation 4.7.3.4; 4.7.3.6

Public Services: public utilities 4.7.3.5 2

Public Services: education (license renewal) 4.7.3.1 1

Offsite Land Use (license renewal term) 4.7.4 2

Public Services: transportation 4.7.3.2 2

Historic and Archaeological Resources 4.7.7 2

Aesthetic Impacts (license renewal term) 4.7.6 1

Aesthetic impacts of transmission lines (license renewal 4.5.8 1

term)

Environmental Justice Not addressed(a) Uncategorized(a)

(a) Guidance related to environmental justice was not in place at the time the GElS and the

associated revisions to 10 CFR Part 51 were prepared. Therefore, environmental justice must

be addressed in plant-specific reviews.

4.9.1 Generic Socioeconomic Issues

The NRC staff reviewed and evaluated the TMI-1 ER, scoping comments, other available

information, and visited TMI-1 in search of new and significant information that would change

the conclusions presented in the GELS. No new and significant information was identified during

this review and evaluation. Therefore, it is expected that there would be no impacts related to

these Category 1 issues during the period of extended operation beyond those discussed in the

GELS. For TMI-1, the staff incorporates the GElS conclusions by reference. Impacts for

Category 2 and uncategorized issues are discussed in Sections 4.9.2 through 4.9.7, below.

4.9.2 Housing Impacts

Appendix C to the GElS presents a population characterization method based on two factors;

sparseness and proximity (see Section C. 1.4). Sparseness measures population density within

20 mi (32 km) of the site, and proximity measures population density and city size within 50 mi

(80 km). Each factor has categories of density and size (see Table C.1). A matrix is used to rank

the population category as low, medium, or high (see Figure C.1).

According to the 2000 Census, approximately 787,800 people lived within 20 mi (32 km) of TMI1, which equates to a population density of 627 persons per square mile (AmerGen 2008). This

density translates to the least sparse Category 4 (greater than or equal to 120 persons per

NUREG-1437, Supplement 37 4-18 June 2009
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square mile within 20 mi [32 km]). Approximately 2,546,500 people live within 50 mi (80 km) of

TMI-1 (AmerGen 2008). This equates to a population density of 325 persons per square mile.

Applying the GElS proximity measures, TMI-1 is classified as proximity Category 4 (greater than

or equal to 190 persons per square mile within 50 mi [80 km]). Therefore, according to the

sparseness and proximity matrix presented in the GELS, TMI-1 rankings of sparseness Category

4 and proximity Category 4 result in the conclusion that TMI-1 is located in a high population

area.

Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 states that impacts on housing

availability are expected to be of small significance in high-density population areas where

growth control measures are not in effect. Since TMI-1 is located in a high population area, and

Dauphin and Lancaster Counties are not subject to growth control measures that would limit

housing development, any changes in TMI-1 employment would have little noticeable effect on

housing availability in these counties. Since Exelon Generation has indicated that they have no

plans to add non-outage employees during the license renewal period, non-outage employment

levels at TMI-1 would remain relatively constant with no additional demand for permanent

housing during the license renewal term. In addition, the number of available housing units has

kept pace with or exceeded the increase in area population. Based on this information, there

would be no impact on permanent housing during the license renewal term beyond what is

currently being experienced.

However, Exelon Generation indicated in its ER that TMI-1 steam generators would be replaced

prior to the~license renewal term. Exelon Generation estimates that steam generator I

replacement would require a one-time increase in the number of refueling outage workers for up

to 70 days at TMI-1 (AmerGen 2008). These additional workers would create an additional

demand for temporary (rental) housing in the immediate vicinity of TMI-1. The impacts of TMI-1

steam generator replacement are discussed in Chapter 3 of this supplemental EIS.

4.9.3 Public Services: Public Utility Impacts

Impacts on public utility services are considered SMALL if there is little or no change in the

ability of the system to respond to demand and thus there is no need to add capital facilities.

Impacts are considered MODERATE if service capabilities are overtaxed during periods of peak

demand. Impacts are considered LARGE if services (e.g., water, sewer) are substantially

degraded and additional capacity is needed to meet ongoing demand. The GElS indicated that,

in the absence of new and significant information to the contrary, the only impacts on public

utilities that could be significant are impacts on public water supplies.,

Analysis of the impacts on the public water and sewer systems considered both plant demand

and plant-related population growth. Section 2.2.8 of this supplemental EIS describes the TMI-1

permitted withdrawal rate and actual use of water.

Since Exelon Generation has indicated that they have no plans to add non-outage employees

during the license renewal period, non-outage employment levels at TMI-1 would remain

relatively unchanged with no additional demand -for public water and sewer services. Public

water systems in the region would be adequate to meet the demands of residential and

industrial customers in the area. Therefore, impacts on public utility services by TMI-1 operation

June 2009 4-19 NUREG-1437, Supplement 37
Environmental Impacts of Operation

would be SMALL during the license renewal term because there would be no additional impact

to public water and sewer services beyond what is currently being experienced.

As discussed in Section 4.9.2, Exelon Generation indicated in their ER that TMI-1 steam

generators would be replaced prior to the license renewal term (AmerGen 2008). The additional

number of refueling outage workers needed to replace the steam generators would cause a

short-term increase in the amount of public water and sewer services used in the immediate

vicinity of TMI-I. These impacts are discussed in Chapter 3 of this supplemental EIS.

4.9.4 Offsite Land Use - License Renewal Period

Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 notes that "significant changes in land

use may be associated with population and tax revenue changes resulting from license

renewal."

Section 4.7.4 of the GElS defines the magnitude of land-use changes as a result of plant

operation during the period of extended operation as follows:

SMALL - Little new development and minimal changes to an area's land-use pattern.

MODERATE - Considerable new development and some changes to the land-use pattern.

LARGE - Large-scale new development and major changes in the land-use pattern.

Tax revenue can affect land use because it enables local jurisdictions to provide the public

services (e.g., transportation and utilities) necessary to support development. Section 4.7.4.1 of

the GElS states that the assessment of tax-driven land-use impacts during the license renewal

term should consider (1) the size of the plant's payments relative to the community's total

revenues, (2) the nature of the community's existing land-use pattern, and (3) the extent to

which the community already has public services in place to support and guide development. If

the plant's tax payments are projected to be small relative to the community's total revenue, taxdriven land-use changes during the plant's license renewal term would be SMALL, especially

when the community has pre-established patterns of development and has provided adequate

public services to support and guide development.

Section 4.7.2.1 of the GElS states that if tax payments by the plant owner are less than 10

percent of the taxing jurisdiction's revenue, the significance level would be SMALL. If the plant's

tax payments are projected to be medium to large relative to the community's total revenue,

new tax-driven land-use changes would be MODERATE. If the plant's tax payments are

projected to be a dominant source of the community's total revenue, new tax-driven land-use

changes would be LARGE. This would be especially true when the community has no preestablished pattern of development or has not provided adequate public services to support and

guide development.

Population-Related Impacts

Since Exelon Generation has indicated that they have no plans to add non-outage employees

during the license renewal period, there would be no noticeable change in land use conditions in

NUREG-1437, Supplement 37 4-20 June 2009
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the vicinity of TMI-1. Therefore, there would be no population-related land use impacts during

the license renewal term beyond those already being experienced.

As discussed in Section 4.9.2, Exelon Generation indicated in their ER that TMI-1 steam

generators would be replaced prior to the license renewal term (AmerGen 2008). Due to the

short amount of time needed to replace the steam generators, the additional number of refueling

outage workers would not cause any permanent population-related land use changes in the

immediate vicinity of TMI-1. These impacts are discussed in Chapter 3 of this supplemental EIS.

Tax Revenue-Related Impacts

As previously discussed in chapter 2, Exelon Generation pays annual real estate taxes to

Dauphin County, Londonderry Township, and the Lower Dauphin School District. For the threeyear period from 2003 through 2005, tax payments to Dauphin County represented 0.2 percent

of the County's total annual property tax revenues, and payments to Londonderry Township

represented approximately 0.3 to 0.5 percent of the Township's total annual property tax

revenues. Exelon Generation's tax payments to the Lower Dauphin School District, for the

period 2003 through 2005, represented 1.7 to 2.3 percent of the District's total annual property

tax revenues.

Since Exelon Generation started making payments to local jurisdictions, population levels and

land use conditions in Dauphin County and Londonderry Township have not changed

significantly, which might indicate that these tax revenues have had little or no affect on land

use activities within the county. However, discontinuing the current level of tax revenues could

have a negative economic impact on these jurisdictions and the Lower Dauphin School District.

Exelon Generation has indicated that they have no plans to add non-outage employees during

the license renewal period, non-outage employment levels at TMI-1 would remain relatively

unchanged. Accordingly, there would be no increase in the assessed value of TMI-1, and

annual property tax payments to Dauphin County, Londonderry Township, and the Lower

Dauphin School District would be expected to remain relatively unchanged throughout the

license renewal period. Based on this information, there would be no land use impacts related to

tax revenue during the license renewal term beyond those already being experienced.

As discussed in Section 4.9.2, Exelon Generation indicated in their ER that TMI-1 steam

generators would be replaced prior to the license renewal term (AmerGen 2008). The

replacement of the existing steam generators would not likely increase the assessed value of

TMI-1, and property tax payments would remain unchanged. These impacts are discussed in

Chapter 3 of this supplemental EIS.

4.9.5 Public Services: Transportation Impacts

Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 states the following:

Transportation impacts (level of service) of highway traffic generated.. .during the

term of the renewed license are generally expected to be of small significance.

However, the increase in traffic associated with additional workers and the local

road and traffic control conditions may lead to impacts of moderate or large

significance at some sites.

June 2009 4-21 NUREG-1437, Supplement 37
Environmental Impacts of Operation

All applicants are required by 10 CFR 51.53(c)(3)(ii)(J) to assess the impacts of highway traffic

generated by the proposed project on the level of service of local highways during the term of

the renewed license.

I Since Exelon Generation has no plans to add non-outage employees during the license renewal

period; there would be no noticeable change in traffic volume and levels of service on roadways

in the vicinity of TMI-1. Therefore, there would be no transportation impacts during the license

renewal term beyond those already being experienced.

I As discussed in Section 4.9.2, Exelon Generation indicated in their ER that TMI-1 steam

generators would be replaced prior to the license renewal term (AmerGen 2008). The additional

number of refueling outage workers and truck material deliveries needed to support the

replacement of the steam generators would cause a one-time short-term transportation impact

on access roads in the immediate vicinity of TMI-1. These impacts are discussed in Chapter 3 of

this supplemental EIS.

4.9.6 Historic and Archaeological Resources

The National Historic Preservation Act (NHPA) requires Federal agencies to consider the effects

of their undertakings on historic properties. Historic properties are defined as resources that are

eligible for listing on the National Register of Historic Places (NRHP). The criteria for eligibility

are listed in Title 36, "Parks, Forests, and Public Property," Part 60, Section 4, "Criteria for

Evaluation," of the Code of Federal Regulations (36 CFR Part 60.4) and include (1) association

with significant events in history; (2) association with the lives of persons significant in the past;

(3) embodies distinctive characteristics of type, period, or construction, and (4) or sites or places

that have yielded or are likely to yield important information (ACHP 2008). The historic

preservation review process (Section 106 of the NHPA) is outlined in regulations issued by the

Advisory Council on Historic Preservation in Title 36, "Parks, Forests, and Public Property,"

Part 800, "Protection of Historic Properties," of the Code of Federal Regulations

(36 CFR Part 800). The issuance of a renewed operating license for a nuclear power plant is a

federal action that could possibly affect either known or undiscovered historic properties located

on or near the plant site and its associated transmission lines. In accordance with the provisions

of the NHPA, the NRC is required to make a reasonable effort to identify historic properties in

the area of potential effect. The area of potential effect (APE) for a license renewal action is the

area at the power plant site and its immediate environs that may be impacted by post-license

renewal land-disturbing operations or projected refurbishment activities associated with the

proposed action. If no historic properties are present or affected, the NRC is required to notify

the State Historic Preservation Office before proceeding. If it is determined that historic

properties are present, the NRC is required to assess and resolve possible adverse effects of

the undertaking. While Exelon Generation owns Three Mile Island, the APE is confined to the

northern portion of the island where the plant is located. The following discussion summarizes

the historic and archaeological research that has been conducted on the island.

Exelon Generation contacted the Pennsylvania Historical and Museum Commission (PHMC) on

May 22, 2007, requesting information on historic and archaeological resources and describing

the proposed action (AmerGen 2008). In a letter dated June 4, 2007, the PHMC stated that the

activities described in the proposed action should have no effect on historic and archaeological

NUREG-1437, Supplement 37 4-22 June 2009
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resources (AmerGen 2008). The PHMC requested that if the applicant becomes aware of any

unidentified historic buildings, structures, or archaeological resources located on site, or if the

project could have an effect on historic properties, the PHMC should be contacted immediately

(AmerGen 2008). In accordance with 36 CFR 800.8(c), the NRC contacted the PHMC (NRC

2008a), the Advisory Council on Historic Preservation (NRC 2008b), and the appropriate

Federally-recognized Native American Tribes to initiate consultation. These letters are

contained in Appendix D of this report.

As previously discussed in Section 2.2.9, a search of the PHMC site files identified nine

prehistoric sites and one historic site on Three Mile Island. One of the sites, 36Da98 was a

possible find spot reported by a local collector south of the powerblock. No time period was

determined for the 36Da98 and portions of the site could still be intact and should be avoided.

Sites 36Da96 and 36Da97 were located in a cultivated area which later became the

construction site for TMI-1 and TMI Unit 2. Portions of the 36Da96 could also be intact due to its

location on the edge of the construction zone. Site 36Da97 was destroyed by the construction of

TMI-1 and TMI Unit 2. One additional site 36Da52 was recorded by the William Penn Memorial

Museum in 1967. It is unclear whether 36Da52 was destroyed during the construction of TMI-1

and TMI Unit 2 because it was also situated on the edge of the construction area.

Site 36Da50 is a large multi-component occupation that was excavated prior to the construction

of TMI-1 and TMI Unit 2. During the walkover survey, it was noted that the northernmost

portions of 36Da50 remain and it is an area that should be avoided. Sites 36Da99, 36Da100,

and 36Da101 are large multi-component occupation sites near the riverbank. 36Da101 also

contains historic artifacts. Another prehistoric occupation site is 36Da51. While test units

recovered a low concentration of artifacts, portions of this site may still be intact and should be

avoided. These archaeological and historic sites have the potential to contribute a large amount

of prehistoric information. Archaeological surveys and reports indicate that undisturbed portions

of Three Mile Island could contribute to the archaeological record of the lower Susquehanna

River valley. Archaeological investigations should be conducted if ground disturbing activities

would occur in undisturbed areas of the island.

In addition to the prehistoric sites mentioned above, Three Mile Island also contains historic

sites. As noted earlier, a historic farmstead was identified (36Da235) during NRC's walkover

survey of Three Mile Island. A preliminary Pennsylvania Archaeological Site Survey form was

completed by Exelon Generation, however, documentation is incomplete. This site must be

recorded and evaluated for eligibility to the National Register of Historic Places (NRHP).

Additionally, remnants of the Pennsylvania Canal's Eastern Division (Eastern Division Canal)

are located on the eastern shore of the Susquehanna River next to Exelon Generation's

property. Another potential resource of historic significance on Three Mile Island is TMI Unit 2.

TMI Unit 2 could be considered potentially eligible for listing on the NRHP under Criterion A, as

a site of exceptional importance, and Criteria Consideration G, as a property achieving

significance within the past 50 years; but its eligibility has not yet been determined. While

Exelon Generation does not own TMI Unit 2, Exelon Generation will cooperate with FirstEnergy

Corporation and the PHMC to further record and evaluate both TMI Unit 2 and the historic

farmstead for NRHP eligibility (Exelon 2009a).

Exelon Generation has indicated no plans to change or modify the plant or transmission line

structures. However, because of the high potential for the presence of historic and

archaeological resources, Exelon Generation should take care during continued operations and

June 2009 4-23 NUREG-1437, Supplement 37
Environmental Impacts of Operation

I maintenance activities to not affect these resources. Exelon Generation's review procedures for

onsite ground disturbing activities take into account the protection of historic and archaeological

resources. Since publication of the draft supplemental EIS, Exelon Generation has revised its

procedures to provide guidance regarding the protection of historic and archaeological

resources, and has implemented a stop work provision if these resources are inadvertently

discovered. It should be noted in the procedures that previously disturbed lands are areas that

were disturbed by the construction of TMI-1 and TMI Unit 2. Plow zone disturbance (farming) is

not considered previously disturbed land because the depth of disturbance is minimal. If ground

disturbing activities are planned that may adversely affect these resources, then Exelon

Generation should hire a qualified archaeologist to survey the proposed site prior to

construction. To date, Exelon Generation has employed cultural resource management firms to

ensure that ground disturbing activities would not adversely affect historic and archaeological

resources.

Exelon Generation will develop and implement a cultural resources management plant (CRMP)

that will consider the impacts of plant operation on historic and archaeological resources. The

CRMP will also include periodic monitoring of erosion along shoreline areas (Exelon Generation

2009a). The CRMP will be developed in consultation with the PHMC and the NRC. Additionally

Exelon Generation will receive Section 106 training (Exelon Generation 2009a).

As discussed in Chapter 3, Exelon Generation plans to replace the existing steam generators

for TMI-1. A dedicated storage facility to house the replaced generators will be constructed

I within the existing industrial footprint of the site and will be located in an area that has been

previously disturbed (AmerGen 2008). The NRC staff has reviewed the potential environmental

impacts of this activity in Chapter 3 of this supplemental EIS.

No adverse impacts to known historic and archaeological resources are expected from the

continued operation of TMI-1 during the license renewal term. Based on the review of PHMC

files, archaeological surveys, assessments, and other information, the potential impacts on

historic and archaeological resources at TMI-1 would be SMALL. Exelon Generation further

mitigated the NRC finding of SMALL impact in the draft supplemental EIS by committing to

develop and implement a CRMP and by training staff in the-Section 106 process. The revised

procedures and the CRMP integrate cultural resource considerations with ongoing TMI-1

activities. Staff training will aid Exelon Generation staff in making informed decisions when

considering the effects of continued operations and future projects on historic and

archaeological resources. As previously discussed, lands not previously surveyed should be

investigated by a professional archaeologist prior to any ground disturbance. In addition, the

historical farmstead site (36Da235) should be recorded and evaluated for eligibility.

4.9.7 Environmental Justice

Under Executive Order 12898 (59 FR 7629), Federal agencies are responsible for identifying

and addressing potentially disproportionately high and adverse human health and

environmental impacts on minority and low-income populations. In 2004, the Commission

issued a Policy Statement on the Treatment of Environmental Justice Matters in NRC

Regulatory and Licensing Actions (69 FR 52040), which states, "The Commission is committed

NUREG-1437, Supplement 37 4-24 June 2009
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to the general goals set forth in Executive Order 12898, and strives to meet those goals as part

of its NEPA review process."

The Council of Environmental Quality (CEQ) provides the following information in its 1997 report

entitled, "Environmental Justice: Guidance Under the National Environmental Policy Act":

Disproportionately High and Adverse Human Health Effects. Adverse health

effects are measured in risks and rates that could result in latent cancer fatalities,

as well as other fatal or nonfatal adverse impacts on human health. Adverse

health effects may include bodily impairment, infirmity, illness, or death.

Disproportionately high and adverse human health effects occur when the risk or

rate of exposure to an environmental hazard for a minority or low-income

population is significant (as defined by NEPA [National Environmental Policy

Act]) and appreciably exceeds the risk or exposure rate for the general

population or for another appropriate comparison group (CEQ 1997).

Disproportionately High and Adverse Environmental Effects. A

disproportionately high environmental impact that is significant (as defined by

NEPA) refers to an impact or risk of an impact on the natural or physical

environment in a low-income or minority community that appreciably exceeds the

environmental impact on the larger community. Such effects may include

ecological, cultural, human health, economic, or social impacts. An adverse

environmental impact is an impact that is determined to be both harmful and

significant (as defined by NEPA). In assessing cultural and aesthetic

environmental impacts, impacts that uniquely affect geographically dislocated or

dispersed minority or low-income populations or American Indian tribes are

considered (CEQ 1997).

The environmental justice analysis assesses the potential for disproportionately high and

adverse human health or environmental effects on minority and low-income populations that

could result from the operation of TMI-1 during the renewal term. In assessing the impacts, the

following CEQ (1997) definitions of minority individuals and populations and low-income

population were used:

Minority individuals. Individuals who identify themselves as members of the

following population groups: Hispanic or Latino, American Indian or Alaska

Native, Asian, Black or African American, Native Hawaiian or Other Pacific

Islander, or two or more races meaning individuals who identified themselves on

a Census form as being a Mriember of two or more races, for example, Hispanic

and Asian.

Minority populations. Minority populations are identified when (1) the minority

population of an affected area exceeds 50 percent or (2) the minority population

percentage of the affected area is meaningfully greater than the minority

population percentage in the general population or other appropriate unit of

geographic analysis.

June 2009 4-25 NUREG-1437, Supplement 37
Environmental Impacts of Operation

Low-income population. Low-income populations in an affected area are

identified with the annual statistical poverty thresholds from the Census Bureau's

Current Population Reports, Series PB60, on Income and Poverty.

Minority Population in 2000

According to the 2000 census data, 11 percent of the population (approximately 2,536,000

individuals) residing within a 50-mi (80-km) radius of TMI-1 identified themselves as minority

individuals. The largest minority group was Black or African American (131,000 persons or 5.2

percent), followed by Hispanic or Latino of any race (107,000 or about 4.2 percent) (USCB 2003

- LandView 6). About 24.4 percent of the Dauphin County population identified themselves as

minorities, with Black or African American the largest minority group (16.9 percent) followed by

Hispanic or Latino (4.1 percent) (USCB 2008) (see Table 2-12).

The 50-mi (80 km) radius around TMI-1 includes 16 counties in Pennsylvania and six counties

in Maryland. The geographic area includes any census block group with part of its area within

the 50-mi (80 km) radius. Of the 1,931 census block groups located wholly or partly within the

50-mi (80 km) radius of TMI-1, 155 block groups were determined to have high density minority

population percentages that exceeded the Pennsylvania average by 20 percentage points or

more. The largest number of high density minority block groups was Black or African American,

with 78 block groups that exceed the Pennsylvania average of 20 percent or more. These block

groups are concentrated in urban areas with high population densities. The greatest number of

high density block groups with minority populations are located in four Pennsylvania counties

(Berks, Dauphin, Lancaster, and York). The closest high density minority population to TMI-1 is

located in Harrisburg, Pennsylvania.

Based on the 2000 census data, Figure 4-1 shows the location of high density minority block

groups within a 50-mi radius of TMI-1.

Low-Income Population in 2000

According to 2000 census data, approximately 36,000 families and 188,000 individuals

(approximately 5.3 and 7.4 percent, respectively) residing within a 50-mi (80-km) radius of TMI1 were identified as living below the Federal poverty threshold in 1999 (USCB 2003 - LandView

6). The 1999 Federal poverty threshold was $17,029 for a family of four.

According to Census data, the median household income for Pennsylvania in 2006 was

$46,259, while 12.1 percent of the State population was determined to be living below the

Federal poverty threshold. Dauphin County had higher median household incomes ($49,093)

and a lower percentage (10.1 percent) of individuals living below the poverty level when

compared to the State. Lancaster County had a much higher median household income in 2006

($52,064) and a lower percentage (9.2 percent) of individuals living below the poverty level

when compared to the State and Dauphin County (USCB 2008). Census block groups were

considered high density low-income block groups if the percentage of households below the

Federal poverty threshold exceeded the Pennsylvania average by 20 percent or more. Based

on 2000 Census data, there were 66 block groups within the 50-mi (80 kin) radius of TMI-1 that

exceeded the Pennsylvania average for low income households by 20 percent or more. The

majority of census block groups with low-income populations were located in two counties,

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Legend

LegendTree Mae Island Nuclear Station Unit I

Aggregate of Races Minority

Water

Urb~an Area

State Boundary

County Boundary

Figure 4-1. Aggregate Minority Populations

Within 50 Mi (80 kin) of Three Mile Island

Nuclear Station, Unit I (AmerGen 2008)

June 2009 4-27 NUREG-1437, Supplement 37
Environmental Impacts of Operation

Legend

4 Three Mile Wland Nuclear Slation Unit I

Low-Income PopuLaton

•, Water

Urban Area

State Boundary

r County Boundary

I

Figure 4-2. Low Income Populations Within

50 Mi (80 km) of Three Mile Island Nuclear

Station, Unit I (AmerGen 2008)

NUREG-1437, Supplement 37 4-28 June 2009
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Berks County (16 block groups) and Dauphin County (12 block groups) in Pennsylvania. The

nearest high density low-income population to TMI-1 is located in Harrisburg, Pennsylvania.

Figure 4-2 shows the location of high density low-income census block groups within a 50-mi

(80-km) radius of TMI-1.

Analysis of Impacts

Consistent with the impact analysis for the public and occupational health and safety, the

affected populations are defined as minority and low-income populations who reside within a 50-

mi (80-km) radius of TMI-I. Based on the analysis of environmental health and safety impacts

presented in this supplemental EIS for other resource areas, there would be no

disproportionately high and adverse impacts to minority and low-income populations from the

continued operation of TMI-1 during the license renewal period.

As discussed in Section 4.9.2, Exelon Generation indicated in their ER that TMI-1 steam

generators would be replaced prior to the license renewal term. Exelon Generation estimates

that steam generator replacement would require a one-time increase in the number of refueling

outage workers for up to 70 days at TMI-1 (AmerGen 2008a). These additional workers would

have little noticeable affecton minority and/or low-income populations in the region. These

impacts are discussed in Chapter 3 of this supplemental EIS.

NRC also analyzed the risk of radiological exposure through the consumption patterns of

special pathway receptors, including subsistence consumption of fish, native vegetation, surface

waters, sediments, and local produce; absorption of contaminants in sediments through the

skin; and inhalation of plant materials. The special pathway receptors analysis is important to

the environmental justice analysis because consumption patterns may reflect the traditional or

cultural practices of minority and low-income populations in the area.

Subsistence Consumption of Fish and Wildlife

Section 4-4 of Executive Order 12898 (1994) directs Federal agencies, whenever practical and

appropriate, to collect and analyze information on the consumption patterns of populations who

rely principally on fish and/or wildlife for subsistence and to communicate the risks of these

consumption patterns to the public. In this supplemental EIS, NRC considered whether or not

there were any means for minority or low-income populations to be disproportionately affected

by examining impacts to American Indian, Hispanic, and other traditional lifestyle special

pathway receptors. Special pathways that took into account the levels of contaminants in native

vegetation, crops, soils and sediments, surface water, fish, and game animals on or near the

TMI-1 site were considered.

Historic analyses of deer meat samples collected at TMI-1 from 1990 through 1997 found

concentrations of cesium-1 37, tritium, and strontium-90. Cesium-1 37 was only detected in

control samples (AmerGen 2008c). Since cesium-1 37 was not found in indicator samples, the

presence of cesium-1 37 could be attributed to past fallout from nuclear weapons tests. Tritium

was found in both indicator and control deer meat samples during this time period at

concentrations similar to each other and similar to concentrations of tritium'detected in other

control food products such as milk, fruits, and vegetables (AmerGen 2008c). Since tritium

occurs naturally in the environment and since the levels of concentrations were similar, the

presence of tritium in both control and indicator samples therefore could not be directly

attributed to TMI-1 operations. Strontium-90 was found in only one deer meat sample collected

June 2009 4-29 NUREG-1437, Supplement 37
Environmental Impacts of Operation

in 1992 and was consistent with the concentration found in one 1989 control sample (AmerGen

2008c). Therefore, the presence of strontium-90 in the deer meat sample could also be

attributed to past fallout from nuclear weapons tests.

Exelon Generation has an ongoing comprehensive Radiological Environmental Monitoring

Program (REMP) at TMI-1 to assess the impact of site operations on the environment. Samples

are collected from the aquatic and terrestrial pathways in the vicinity of TMI-1 and TMI Unit 2.

The aquatic pathways include fish, Susquehanna River surface water, ground water, and

sediment. The terrestrial pathways include airborne particulates, milk, and food product garden

(leaf)

vegetation, and direct radiation. During 2007, 1,718 analyses were performed on 1,318

collected samples of environmental media as part of the required REMP and showed no

significant or measurable radiological impact from TMI-1 operations (AmerGen 2008b).

During 2007, cesium-1 37, strontium-90, and tritium were the only potentially plant-related

radionuclides detected in environmental samples. No radionuclides other than naturally

occurring and tritium were detected in the Susquehanna River water samples collected in 2007.

Tritium, the presence of which is likely to be due to plant operations, has been detected in the

past, was detected in 8 of 24 surface water samples taken downstream of the effluent outfall in

concentrations well below regulatory limits. Tritium was also detected in 3 of 36 drinking water

samples at slightly above the lower limit of detection. Cesium-1 37 was identified in sediment

samples in 2007 at very low levels (just above the lower limit of detection), and were not

distinguishable from background levels (AmerGen 2008b).

Strontium-90 was detected in 11 of 21 milk samples collected in 2007. The amount of activity

detected was consistent with those detected in the pre-operational years. Strontium-90 was also

detected in 24 of 26 food product samples in both the indicator and control samples (AmerGen

2008b). The source of the strontium-90 could be attributed to residual fallout from weapons

testing.

The results of the 2007 REMP demonstrate that routine operation at TMI-1 had no significant or

measurable radiological impact on the environment. No elevated radiation levels were detected

in the offsite environment as a result of plant operations and the storage of radioactive waste.

The results of the REMP continue to demonstrate that the operation of TMI-1 does not result in

a significant measurable dose to a member of the general population or adversely impact the

environment as a result of radiological effluents. The REMP continues to demonstrate that the

dose to a member of the public from the operation of TMI-1 remains significantly below the

federally required dose limits specified in 10 CFR Part 20 and 40 CFR Part 190.

The PADEP BRP maintains a comprehensive environmental radiation monitoring program in

Pennsylvania, as required by the "Radiation Protection Act" (No. 1984-147). The purpose of the

program is to evaluate long-term trends in environmental radiation levels; assess the

environmental impact of particular sites, such as TMI-1; and provide this information to the

public. The BRP currently maintains off-site environmental radiation monitoring programs

around five nuclear power plants in Pennsylvania including TMI-I. Monitoring stations serve as

indicators of any effects from plant operation and at control locations, which are beyond the

measurable influence of the facility. These stations also provide verification of utility effluent

monitoring programs during routine operations.

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Each year, BRP collects dosimetry, air, water, milk, fish, produce, and sediment samples in the

vicinity of TMI-I. Fish samples were collected in the vicinity of the TMI-1 discharge and produce

samples of cabbage were collected from a truck garden located 0.4 mi east of TMI-1 in 2003

and 2004. No reactor-related radioisotopes were detected in the fish and produce samples.

BRP also found no traces of cesium-1 37 in milk samples taken monthly at two local farms.

Cesium-1 37 was detected in sediment samples collected upstream (control) and downstream

(indicator) of the TMI-1 discharge. The presence of cesium-137 could be attributed to fallout

from past weapons testing and the accident at Chernobyl in April 1986. BRP also found no

reactor-related radioisotopes in fish and produce samples collected in 2001 and 2002 (PADEP

BRP 2008).

Based on recent monitoring results, concentrations of radiological contaminants in native leafy

vegetation, soils and sediments, surface water, and fish in areas surrounding TMI-1 have been

quite low (at or near the threshold of detection) and seldom above background levels.

Consequently, no disproportionately high and adverse human health impacts would be

expected in special pathway receptor populations in the region as a result of subsistence

consumption of fish and wildlife.

4.10 Evaluation of New and Potentially Significant Information

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

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

(2) information that was not considered in the analyses summarized in the GElS and that leads

to an impact finding that is different from the finding presented in the GElS and codified in 10

CFR Part 51.

In preparing to submit its application to renew the TMI-1 operating license, Exelon Generation

developed a process to ensure that information not addressed in or available during the GElS

evaluation regarding the environmental impacts of license renewal for TMI-1 would be properly

reviewed before submitting the ER, and to ensure that such new and potentially significant

information related to renewal of the operating license for TMI-1 would be identified, reviewed,

and assessed during the period of NRC review. Exelon Generation reviewed the Category 1

issues that appear in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, to verify that the

conclusions of the GElS remained valid with respect to TMI-1. This review was performed by

personnel from TMI-1 and its support organization who were familiar with NEPA issues and the

scientific disciplines involved in the preparation of a license renewal ER.

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

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

Reviews for Nuclear Power Plants, Supplement 1,: Operating License Renewal (NRC 2000).

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

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

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

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

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

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

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

June 2009 4-31 NUREG-1437, Supplement 37
Environmental Impacts of Operation

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

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

The NRC staff has not identified any new and significant information on environmental issues

listed in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, related to the operation of TMI-1

during the period of license extension. The NRC staff also determined that information provided

during the public comment period did not identify any new issues that require site-specific

assessment. The NRC staff reviewed the discussion of environmental impacts in the GElS

(NRC 1996) and conducted its own independent review (including the public scoping meetings

held in May 2008) to identify new and significant information.

4.11 Cumulative Impacts

The NRC staff considered potential cumulative impacts in the environmental analysis of

continued operation of TMI-1. For the purposes of this analysis, past actions are those related to

the resources at the time of the power plant licensing and construction, present actions are

those related to the resources at the time of current operation of the power plant, and future

actions are considered to be those that are reasonably foreseeable through the end of plant

operation including the period of extended operation. Therefore, the analysis considers potential

impacts through the end of the current license terms as well as the 20-year renewal license

term. The geographic area over which past, present, and future actions would occur is

dependent on the type of action considered and a description follows for each impact area.

The impacts of the proposed action, as described in Sections 4.1-4.9, are combined with other

past, present, and reasonably foreseeable future actions regardless of what agency (Federal or

non-Federal) or person undertakes such other actions.

4.11.1 Cumulative Impacts on Water Resources

The SRBC regulates consumptive water use at TMI-1 and at all facilities drawing water from the

Susquehanna River and the river basin. The SRBC is an independent agency that develops,

effectuates, coordinates and adopts plans, policies, and programs related to water resources in

the Susquehanna River basin (SRBC 2008). According to the SRBC, 89 percent of water use in

the Lower Susquehanna River Basin (Lower Subbasin) is for power generation, 4.8 percent for

industrial use, 4.2 percent for municipal use, 1.2 percent for agricultural use, and 0.8 percent for

domestic use (SRBC 2007). TMI-1 has a permit with SRBC for consumptive use of river water

up to 18 million gallons per day (mgd), on a 30-day average, for electric generation. TMI-1 also

I participates in the Cowanesque Lake water allocation project, which releases water to the

Susquehanna River to augment flow during periods of drought (AmerGen 2008).

I TMI-1 has seven onsite ground water wells, and uses ground water for various industrial

operations and for drinking water on site, as permitted by the SRBC. This water is primarily

drawn from the Gettysburg shale aquifer located directly beneath the site (AmerGen 2008). The

SRBC monitors and manages ground water use in the area including and surrounding Three

Mile Island under the "Groundwater Management Plan for the Susquehanna River Basin," which

was initiated in 1993 (SRBC 2005). The SRBC estimates that the use of ground water in the

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Susquehanna River Basin is approximately 390 mgd. The main use in the basin is to supply

drinking water wells, with the largest consumers being public water suppliers (115 mgd),

followed by mining sites (90 mgd), domestic consumers (80 mgd), industrial consumers (48

mgd), agricultural consumers (42 mgd), and commercial consumers (12 mgd) (SRBC 2005).

According to the most recently issued draft ground water management plan (SRBC 2005), the

quality of ground water in the Susquehanna River Basin is generally good, with the most

common impacts being the geology of the area and land use. Degradation of ground water in

the area is largely a result of abandoned coal mines (acid mine drainage) as well as agricultural

and residential use of pesticides and contaminants. A particular problem addressed by the

SRBC is the diversion of stormwater runoff into sinkholes, which essentially delivers the water

directly to the aquifer. Section 4.11.2 of this report discusses ground water quality and its

impacts on aquatic resources of the Susquehanna River in more depth. Other significant issues

outlined by the SRBC management plan include increases in land development, overuse of

ground water resources, transfer of discharge wastewater to a different watershed, unregulated

use of ground water resources, drought impacts, and the need for flow compensation for

consumptive water users in the basin (SRBC 2005).

The potential cumulative effects of climate change on the Susquehanna River basin, whether

from natural cycles in climate or related to anthropogenic activities, could result in a variety of

changes to the surface and ground water resources in the Susquehanna River basin. A report

issued by the Union of Concerned Scientists in October 2008 (UCS 2008) on climate change in

Pennsylvania predicted that from the years 2010-2039, average annual temperatures across

Pennsylvania could increase by 2.5-3.0 degrees Fahrenheit (0F). Temperatures will warm the

most in summer and winter; fall and spring will experience smaller temperature increases.

Extreme heat events in summer are expected to increase in number, intensity, and duration.

Some of the most significant anticipated impacts of climate change could result from changes in

surface and ground water hydrology. Across Pennsylvania, precipitation is expected to increase

by more than 5 percent above historical average, with increases in seasonal rainfall occurring

mainly in spring and fall. More heavy rainfall events (defined as more than 2 inches of rain in a

24-hour period) are expected to occur. Increased rainfall would increase stream and river flow

and recharge ground water aquifers, alleviating low-flow issues in the Susquehanna River

during those periods. Adverse effects of heavy precipitation include impacts on water quality of

surface and ground water, contamination of drinking wells, and more frequent flooding events.

Conversely, warmer temperatures and changing timing and distribution of precipitation could

lead to an increase in droughts during summer months. (UCS 2008) Warmer temperatures and

heat waves could spur increased demand in electricity for cooling purposes, potentially resulting

in power plants located on the Susquehanna River using more river water to support higher

energy output-a cycle that would exacerbate low-flow conditions in the river.

The SRBC regulatory program, which includes the regulation of withdrawals, monitoring and

enforcement duties, and the ability to designate protected areas, manages the basin's ground

water resources. The regulatory program also allows for the development of ground water

quality standards and conservation requirements. Additionally, the ground water management

plan focuses on public outreach and education (SRBC 2005).

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Recently there has been strong interest in the development of gas well drilling of the Marcellus

shale, a gas reservoir stretching from Pennsylvania into Ohio and West Virginia which some

claim contains enough gas to satisfy U.S. demand for two years (Buurma 2008; SRBC 2008).

With the recent success of drilling the Barnett shale in Texas and new technological advances

in horizontal drilling, several drilling companies have taken serious interest in the Appalachian

area (SRBC 2008). The gas drilling process involves both horizontal drilling and the use of a

technique known as hydraulic fracturing or, "hydrofracking". Hydrofracking is the high-pressure

injection of a combination of sand, water, and chemicals into rock to fracture it and make it more

permeable (Buurma 2008). The chemicals used in hydrofracking, however, are toxic and have

the potential to contaminate drinking water and ground water systems. There is less concern

over the transfer of these chemicals into ground water supplies simply because the wells are far

deeper (4,000 to sometimes 8,000 ft deep) than the water-bearing aquifers (SRBC 2008).

However, there is concern over the disposal of the toxic drilling water and where and how it will

be discharged. Before any drilling can begin, each company must apply to the SRBC for various

water use permits. In August 2008, SRBC made the decision to require all natural gas drilling

projects to apply for water withdrawal permits, regardless of the amount of water being

withdrawn, as well as to raise the area's consumptive use mitigation fee (SRBC 2008).

To ensure that surface water and ground water resources of the Susquehanna River basin

continue to meet the needs of the basin population, in addition to enforcing water use

regulations, the SRBC coordinates with State and Federal agencies, conducts extensive water

resources monitoring, project review, water withdrawal registration, drought coordination, flood

management, low-flow management (i.e., water storage), reservoir feasibility studies, and

ground water management (SRBC 2008). On the basis of this information, the independent

review by the NRC staff concludes that the cumulative impact to water resources during the

license renewal period would be SMALL.

4.11.2 Cumulative Impacts on Aquatic Resources

This section addresses past, present, and future actions that could result in adverse cumulative

impacts on aquatic resources. For the purpose of this analysis, the geographic area considered

for cumulative impacts on aquatic resources at TMI-1 is the Lower Subbasin, which is one of the

six Susquehanna River major subbasins. The Lower Subbasin runs south from Sunbury in

Northumberland County, PA, to Havre de Grace, MD. The lower Subbasin discharges into the

Chesapeake Bay.

The Lower Subbasin, which drains approximately 5,809 square miles (mi 2

) (15,045 square

kilometers [km 2]) of land, is the most developed of the six Susquehanna River subbasins. The

cities of Harrisburg, Lancaster, York, Lebanon, and Carlisle are contained within the Lower

Subbasin. The subbasin is characterized by a mixture of land uses including residential areas,

agricultural land, undeveloped land, forests, and recreational areas (SRBC 2008). The northern

section of the Lower Subbasin consists primarily of forested areas interspersed with agriculture

and residential areas, while the southern half of the subbasin is dominated by agriculture and

urban areas, with some undeveloped areas, parks, and recreation areas (SRBC undated).

Almost a century of intensive anthracite coal mining within the Wyoming Valley seriously

impaired the Susquehanna River's water quality and ecological resources. The river received

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highly acidic, iron-rich drainage from numerous mining sites that operated from the late 1800s

through the early 1970s. These sites were mostly in the upper subbasins of the Susquehanna

River; however, the Lower Subbasin was also impacted due to the natural flow of the river and

the movement of pollutants downstream. Anthracite mining in Pennsylvania reached its peak

around 1930 and ceased almost entirely in 1972, in part because of the evolving fossil fuel

economy and tightening water quality regulations. However, the mines continued to leak ironcontaminated acidic runoff to streams that fed the river for many years following their

abandonment. In addition to high levels of total iron and other dissolved heavy metals, mining

effluents were also responsible for the high sulfate content, and low pH and dissolved oxygen

levels in the river (CBF 2006).

Between 1972 and 1981, considerable improvement in the water quality of the Susquehanna

River was noted. During this period, the volume of mining effluents being discharged to the river

decreased. The reduction in mining caused a decrease in solids, iron, and sulfate

concentrations throughout the Susquehanna River. These trends on improved water quality

have continued, and will most likely continue as long as mining is kept at a minimum.

Agriculture and livestock production in the Lower Subbasin have contributed to declines in river

water quality. Nutrient discharges including nitrates, nitrogen, phosphorus, and orthophosphates from runoff of pesticide and fertilized agricultural and livestock lands have been a primary

source of decreased water quality (CBF 2005). Agricultural practices from the land along the

Lower Subbasin have caused decreased river water quality in the Chesapeake Bay (CBF 2005).

Numerous wastewater treatment plants are located along the Lower Subbasin, discharges from

which can contribute to decreases in river water quality. Treated water leaving wastewater

plants can have increased levels of phosphates, orthophosphates, and chlorine (SRBC 2006).

During high storm events, untreated overflow from treatment plants can add additional nutrient

runoff to the Susquehanna River.

As mentioned previously, the Lower Subbasin runs through more urban areas of Pennsylvania

such as Harrisburg, Lancaster, and York. Urbanized areas contain more impervious surfaces

than other land uses; this increases stormwater runoff to waterways and causes subsequent

decreases in river water quality.

Anthropogenic sources of pollution will likely be an ongoing issue for the Susquehanna River.

However, the SRBC, PADEP, and other environmental groups such as the Chesapeake Bay

Foundation are working collaboratively in their efforts to conduct basin-wide monitoring and

promote watershed protection and management. Furthermore, PADEP will continue to enforce

water quality regulations through its NPDES permitting program. NPDES permits, issued by the

PADEP Bureau of Water Supply and Wastewater Management, will continue to regulate

municipal and industrial effluents to the Susquehanna River. The PADEP periodically reviews

and renews NPDES permits; thus it is reasonable to predict that the improving trends in the

Susquehanna River's water quality will likely continue throughout the license renewal period.

Construction of hydroelectric dams on the river in the Lower Subbasin has also created

significant impacts on the aquatic ecosystem; and as power needs in Pennsylvania increase in

the future, it is reasonable to predict potential uprates and improvements to current dams on the

Susquehanna River. Dams can change aquatic ecosystems by altering flow, sediment transport,

critical habitats, water temperature, and chemistry (CBF 2006). As discussed in Section 2.2.5 of

this supplemental EIS, the American shad (Alosa sapidissima) is an anadromous fish species

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that was once of major sport and commercial importance within the Susquehanna River.

Currently, American shad are rarely found in the upper reaches of the river because dams

constructed in the last 100 years have blocked the species' natural upstream migration.

Between 1904 and 1932, four hydroelectric dams were constructed on the Susquehanna River.

Fish passage facilities at these early dams were primitive and often prevented shad passage.

The 1928 construction of the 95-ft-high (29-m-high) Conowingo Dam, located 10 mi (16 km)

above the mouth of the Susquehanna River, effectively put an end to shad migration in the

Susquehanna River, and at the time, authorities deemed the Conowingo Dam too high to

include fish passage modifications in the dam's design. Fish ladders or lifts currently exist at all

dams throughout the Lower Subbasin, however, in the years 2006-2008, shad populations have

declined throughout all the dammed areas in the subbasin (PFBC 2008a).

Shad restoration attempts began in the mid-20th century with feasibility studies conducted by the

Pennsylvania Fish Commission (now the PFBC). From 1970-1980, the first Conowingo fish lift

was built, and hatchery cultures of fry were stocked in the Susquehanna River and its

tributaries. From 1985-1994, increasing numbers of fry were stocked, and over 125,000 adult

shad were stocked above the Conowingo Dam. Fry were stocked in the North Branch

Susquehanna River in Pennsylvania and New York, Chemung River in New York, West Branch

Susquehanna River, Juniata River, Susquehanna River near Montgomery Ferry, Conodoguinet

Creek, Conestoga River, Swatara Creek, and West Conewago Creek. Durng this period, the

annual return of shad grew from 1,500 to 60,000.

During the years of 1988-1997, a permanent fish passage facility was built at Conowingo Dam,

and through a series of settlements with utility companies that owned Susquehanna River

dams, fish elevators were constructed at the Holtwood and Safe Harbor dams. In 1997, the

shad return at Conowingo exceeded 100,000 fish. In 1999 and 2000, a fish ladder was

completed at the Red Hill Dam, and smaller upriver dams along the Susquehanna River and

major tributaries were reopened to allow natural shad migration through Binghamton, NY. In

2001, American shad passage at the Conowingo Dam exceeded 190,000 fish. In 2008, the

number of American shad passing the Conowingo Dam had decreased to less than 20,000 fish,

with only 21 American shad passing the Red Hill (York Haven) Dam fish ladder at TMI-1 (PFBC

2008a). An assessment of the coast-wide stock of American shad by the Atlantic States Marine

Fisheries Commission noted that American shad stocks are at an all-time low and not

recovering, with the primary causes for the decline attributed to "overfishing, pollution loss, and

habitat loss due to dam construction" (ASMFS 2007). Design flaws in existing fish ladders at

dams also limit fish passage at dams located on the Susquehanna River (Greenwire 2008). The

stocking program continues to be conducted annually in efforts to rebuild the American shad

population in the Susquehanna River (PFBC 2007b).

Other fish such as the smallmouth bass (Micropterus dolomieu) have also experienced a

decline in their Susquehanna River populations. Damming of the river, bacterial infections, river

pollution,. and low dissolved oxygen levels are some of the known reasons for smallmouth bass

decline (PFBC 2008b).

Twenty major electric power generating plants are located in the Susquehanna River Basin.

Plants in the Lower Subbasin that withdraw cooling water from the Susquehanna River include

Brunner Island, a three-unit, coal-fired, 1483-megawatt (MW) plant located 5 mi (8 km) south of

Harrisburg (PPL 2008), and Peach Bottom Atomic Power Station, a two-unit, 2130-MW nuclear

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plant, located 18 mi (29 km) south of Lancaster (NRC 1996). PADEP and SRBC regulate these

facilities with regard to their consumptive water use, NPDES-permitted discharges, and impact

on aquatic resources in the Susquehanna River.

Potential cumulative effects of climate change on the Susquehanna River basin could result in a

variety of changes to the aquatic resources in the Susquehanna River. Increases in average

annual temperatures, extreme heat events, and the potential for more frequent drought

conditions could increase Susquehanna River water temperatures. Water temperature

increases could affect spawning patterns or success of aquatic organisms, as well as their

distribution, including invasive species. Smallmouth bass is an example of a fish species that

depends on cooler water for survival-warmer water contains lower levels of dissolved oxygen,

creating areas of the river unsuitable for smallmouth survival. In addition to warmer water

temperatures, low-flow conditions in the Susquehanna River could generally impact fish

survival. Conversely, increased average rainfall and flood events in the fall and spring could

change the nature of sediment and nutrient inputs in the river system, possibly impacting

primary production, and ultimately the river food web. Increased frequency of floods could also

impact the spawning success of aquatic species. (USC 2008; EPA 1997) The extent and

magnitude of climate change impacts on aquatic resources in the Susquehanna River could be

significant in the context of cumulative impacts on the river.

As discussed in Section 4.11.1 of this supplemental EIS, SRBC regulates consumptive water

use at TMI-1 and at all facilities drawing water from the Susquehanna River. To ensure the

water resources of the Susquehanna River Basin continue to meet the needs of the basin

population, the SRBC coordinates with other State and Federal agencies and conducts

extensive water resources monitoring, project review, water withdrawal registration, drought

coordination, low-flow management (i.e., water storage), reservoir feasibility studies, and ground

water management (SRBC 2007b).

The NRC staff concludes that the minimal aquatic impacts expected from the continued TMI-1

operations would not contribute to an overall decline in the condition of aquatic resources.

However, the cumulative impacts on aquatic resources resulting from all past, present, and

reasonably foreseeable future actions, including non-TMI-1 actions, would be SMALL to

MODERATE.

4.11.3 Cumulative Impacts on Terrestrial Resources

This section addresses past, present, and future actions that could result in adverse cumulative

impacts to terrestrial resources, including wildlife populations, upland habitats, wetlands,

riparian zones, invasive species, protected species, and land use. For purposes of this analysis,

the geographic area considered in the evaluation includes the TMI-1 site, the land owned by

Exelon Generation along the eastern bank of the Susquehanna River, the wetlands on and in

the vicinity of the TMI-1 site, and the in-scope transmission line ROWs identified in Section 2.1.5

of this report.

Before construction of the TMI-1 and TMI Unit 2 sites, terrestrial communities on Three Mile

Island supported forest habitat, floodplain habitat, riparian areas, grasslands, and potential

wetland habitat. Initial construction of the TMI-1 and TMI Unit 2 sites converted 200 ac (81 ha)

of the island's 370 ac (150 ha) for plant facilities and industrial uses, which caused loss of

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Environmental Impacts of Operation

terrestrial habitat (AmerGen 2008). A dike system was created during initial construction of the

TMI-1 and TMI Unit 2 facilities, and a wetland habitat developed once the associated borrow

pits began to fill with water (AmerGen 2008).

Construction of the transmission line ROWs maintained by FirstEnergy for the TMI-1 site

resulted in subsequent changes to the plant species present within the ROWs. Because the

length of in-scope transmission lines constructed for TMI-1 is relatively short (5.6 mi [9 km]),

construction most likely did not affect wildlife in the vicinity of the lines. However, fragmentation

resulting from the transmission line ROWs likely caused edge effects such as changes in light,

wind, and temperature; an increased susceptibility to invasive species; and a possible reduction

in habitat ranges for certain species. ROW maintenance has likely had past impacts and is likely

to have present and future impacts on the terrestrial habitat, which may include the buildup of

herbicide chemicals, prevention of natural succession stages, an increase in edge species, a

decrease in interior species, and an increase in invasive species.

Neither Exelon Generation nor FirstEnergy manage invasive species on their land holdings;

therefore, a potential exists for invasive species to be introduced on or in the vicinity of the TMI1 site or its associated transmission line ROWs from present and future actions. Introduction of

these species may contribute to the establishment of an invasive species population, which

could compete with native populations for resources and degrade areas of terrestrial habitat.

As mentioned above, Brunner Island Power Plant is approximately 5 mi (8 km) south of TMI-1,

and has three coal-fired units, totaling a 1,483-MW capacity (PPL 2008). Fossil plants release

carbon dioxide, mercury, nitrogen oxides, and sulfur oxides, among other air emissions.

Nitrogen oxides and sulfur oxides can combine with water to form acid rain, which can lead to

erosion and changes in soil pH levels. Mercury can deposit on soils and surface water, and may

then be taken up by plant or animal species, posing the risk of bioaccumulation. For these

reasons, the Brunner Island Plant is likely to have current and future impacts to the terrestrial

environment on the TMI-1 site and its surrounding area.

Two dams, the York Haven Hydroelectric Station, also known as Olympia Dam, and the Red Hill

Dam, are both located less than 10 mi (16 km) from the TMI-1 project site. The Olympia Dam

produces 19-20 megawatt electric (MWe) (AmerGen 2008). The Red Hill Dam does not

produce electricity. Hydroelectric plants restrict the flow velocity of water downstream, which

can lead to changes in downstream ecosystems. Because TMI-1 is located upstream of

Olympia Dam, the plant is not likely to have cumulative impacts to the terrestrial environment on

the TMI-1 site and its surrounding area.

Two wastewater treatment plants are located within 7 mi (11 km) of the TMI-1 site-the Borough

of Middletown Wastewater Treatment Plant in Middletown, approximately 2 mi (3.2 km) north of

the TMI-1 site, and the Fairview Sewerage Treatment Plant in New Cumberland, approximately

7 mi (11 km) north of the TMI-1 site. Both plants are on the Susquehanna River. Chemical

discharges from these wastewater treatment plants that enter the Susquehanna River may have

current and future impacts on the surrounding vegetation, wetlands, and wildlife.

Bioaccumulation of chemical discharges from these treatment plants also poses a threat to

terrestrial and riparian habitats as well as to wildlife species.

Prior and continued residential, commercial, and industrial development of Dauphin, Lancaster,

and York Counties may impact terrestrial habitat in the vicinity of TMI-1 and the associated

NUREG-1437, Supplement 37 4-38 June 2009
Environmental Impacts of Operation

transmission line ROWs. Increases in both commercial and residential development have

occurred in these counties over the past 40 years. As this area continues to grow, additional

runoff from roads and impervious surfaces, development adjacent to wetlands and riparian

zones, and an increase in waste releases could have future impacts on the terrestrial habitat.

Section 2.2.8.3 discusses offsite land use in the vicinity of TMI-I:

The potential cumulative effects of climate change could result in a variety of changes to

terrestrial resources on and around the TMI-1 site. Increases in average annual temperature

and increased frequency of heat waves, droughts, and heavy rainfall events all have the

potential to impact wildlife populations, protected species, upland habitats, wetlands, riparian

zones, and invasive species. Increased precipitation could change vegetation composition on

Three Mile Island, potentially increasing wetlands, and decreasing riparian communities due to

coastal erosion. Long-term effects of climate change on terrestrial resources could include a

shift in forest composition or even an overall loss of forests, loss of bird diversity, a change in

local mammal populations, and an increase in the range of invasive species and other pests.

(EPA 1997)

The NRC staff believes that the cumulative impacts during the term of license renewal on

terrestrial habitat and associated species, when added to past, present, and reasonably

foreseeable future actions, would be SMALL.

4.11.4 Cumulative Human Health Impacts

The NRC and EPA developed radiological dose limits for protection of the public and workers to

address the cumulative impact of acute and long-term exposure to radiation and radioactive

material. These dose limits are codified in 10 CFR Part 20 and 40 CFR Part 190. This analysis

includes the area within a 50-mi (80-km) radius of the TMI-1 site. The REMP conducted by

Exelon Generation in the vicinity of the TMI-1 site measures the cumulative impact of radiation

and radioactive materials from all sources, including the shut-down and defueled TMI Unit 2;

Peach Bottom Atomic Power Station, Units 2 and 3; and Peach Bottom Unit 1, which has been

shut down since October 1974.

In addition to the Unit 1 operating reactor, Three Mile Island also contains the remains of the

TMI Unit 2 facility that had an accident with a partial fuel meltdown in 1979. TMI Unit 2 is

permanently shut down and defueled. The damaged fuel and core debris was shipped offsite to

a DOE facility. The facility has been in a monitored storage mode since December 1993 and will

remain in that condition until the operating license for TMI-1 expires, at which time both plants

will be decommissioned.

Even though TMI Unit 2 is defueled and in a monitored storage mode, there are still some

controlled radioactive effluent discharges resulting from maintenance and cleanup activities.

These radioactive discharges are a very small fraction of the radioactivity released from TMI-1.

The calculated radiation doses to members of the public from all radioactive material released

from the TMI-1 site are well within NRC's radiation safety limits. In addition to the radioactive

effluent information, the staff reviewed the TMI-1 annual radiological environmental monitoring

report. This report summarizes the results of environmental monitoring Conducted in the

environs around the TMI-1 site to determine the environmental impact from the radioactive

June 2009 4-39 NUREG-1437, Supplement 37
Environmental Impacts of Operation

releases from -the entire TMI-1 site. No unusual trends or significant radiation levels were

detected in the environment from the two units located on Three Mile Island.

Peach Bottom Atomic Power Station has two active nuclear reactor units (Units 2 and 3). Each

unit includes a light-water boiling reactor and a steam-driven turbine generator. The facility's

core power output from the two units is 3,458 megawatt-thermal (MWt). In addition to the

operating units, the site also contains the shut-down Peach Bottom Atomic Power Station Unit

1. Unit 1 was a prototype, high-temperature, gas-cooled reactor that had a net electrical output

of 40 MWe (115 MWt) and operated from 1966-1974. Since then it has been maintained in a

storage mode. As part of normal operations, Peach Bottom Atomic Power Station, Units 2 and

3, release radioactive effluents, contributing to the cumulative dose impacts to members of the

public and the environment.

As discussed in Section 4.8.1 of this report, the staff reviewed the radiological environmental

radiation monitoring results for the five-year period from 2003-2007 as part of the cumulative

impacts assessment. Cumulative radiological impacts from all uranium fuel cycle facilities,

including those discussed above, within a 50-mi (80-km) radius of the TMI-1 site, are limited by

the dose limits codified in 10 CFR Part 20 and 40 CFR Part 190. In Section 4.8,of this report,

the NRC staff concluded that the impacts of radiation exposure from the operation of TMI-1

during the renewal term to the public would be SMALL. The NRC and the Commonwealth of

Pennsylvania will regulate any future actions in the vicinity of the TMI-1 site that could contribute

to cumulative radiological impacts.

The continued operation of TMI-1 has a low risk of causing outbreaks from thermophilic

microbiological organisms associated with thermal discharges. Available data assembled by the

CDC for the years 1999 to 2004 (CDC 2001, 2002, 2002a, 2003, 2003a, 2004, 2005, 2006,

2007b) report no occurrence of waterborne disease outbreaks in the Commonwealth of

Pennsylvania resulting from thermophilic microorganisms Naegleria fowleri and Pseudomonas

aeruginosa from the operation of TMI-I. Outbreaks of legionellosis, samonellosis, or shigellosis

that occurred in the Commonwealth of Pennsylvania were within the range of national trends in

terms of cases per 100,000 population or total cases per year, and the outbreaks were

associated with hotel pools and spas (CDC 2001, 2002, 2002a, 2003, 2003a, 2004, 2005, 2006,

2007b).

As part of its evaluation of cumulative impacts, the NRC staff also considered the effects of

thermal discharges from other facilities on the Susquehanna River located within one mile

upstream of TMI-1 that are also producing thermal effluents. Such facilities could promote the

growth of thermophilic microbiological organisms. The NRC staff did not find any such facilities.

On the basis of these considerations, the NRC staff determined that the cumulative impacts to

public health from thermophillic microbiological organisms resulting from operation of the TMI-1

thermal discharge to the aquatic environment or in the vicinity of the site would be SMALL.

The staff determined that the electric field-induced currents from the TMI-1 transmission lines

are well below the NESC recommendations for preventing electric shock from induced currents.

Therefore, the TMI-1 transmission lines do not detectably affect the overall potential for electric

shock from induced currents within the analysis area. With respect to the chronic effects of

electromagnetic fields, although the GElS finding of "not applicable" is appropriate to TMI-1, the

transmission lines associated with TMI-1 are not likely to detectably contribute to the regional

NUREG-1437, Supplement 37 4-40 June 2009
Environmental Impacts of Operation

exposure to extremely low frequency electromagnetic fields. Therefore, the staff has determined

that the cumulative impacts of the continued operation of the TMI-1 transmission lines would be

SMALL.

4.11.5 Cumulative Socioeconomic Impacts

As discussed in Section 4.9 of this supplemental EIS, continued operation of TMI-1 during the

license renewal term would have no impact on socioeconomic conditions in the region beyond

those already being experienced. Since Exelon Generation has indicated that no additional

workers would be hired during the license renewal term, overall expenditures and employment

levels at TMI-1 would be expected to remain relatively constant with no additional demand for

permanent housing, public utilities, and public services. In addition, since employment levels

and the value of TMI-1 would not change, there would be no population and tax revenue-related

land use impacts. There would also be no disproportionately high and adverse health and

environmental impacts on minority and low-income populations in the region. Based on this and

other information presented in this supplemental EIS, there would be no cumulative

socioeconomic impacts from the continued operation of TMI-1 during the license renewal term

beyond those already being experienced.

However, Exelon Generation indicated in its ER that TMI-1 steam generators would be replaced

prior to the license renewal term. Exelon Generation estimates that steam generator

replacement would require a one-time increase in the number of refueling outage workers for up

to 70 days at TMI-1 (AmerGen 2008). These additional workers would create a one-time shortterm increase in the demand for temporary (rental) housing, increase use of public water and

sewer services, and transportation impacts on access roads in the immediate vicinity of TMI-1.

Given the short amount of time needed to replace the steam generators, the additional number

of refueling outage workers and truck material deliveries needed to support this one-time

replacement of the TMI-1 steam generators could have a temporary cumulative effect on

socioeconomic conditions in the~vicinity of TMI-1. However, there would be no long-term

cumulative socioeconomic impacts from TMI-1 steam generator replacement in the region.

As discussed in Section 4.9.6, 'continued operation of TMI-1 during the license renewal term

would have a SMALL impact on historic and archaeological resources. Exelon Generation has

no plans to construct additional facilities at TMI-1 related to license renewal. Any land disturbing

activities would be carried out under Exelon Generation's corporate procedures that ensure the

protection of cultural resources (AmerGen 2008). Exelon Generation does not anticipate any

changes or additions to transmission line structures. Additionally, Exelon Generation plans to

revise its procedures to provide clear guidance regarding consideration of potential impacts on

historic and archaeological resources. This revision includes a "stop work" provision when

cultural resources are inadvertently discovered (AmerGen 2008). Since Exelon Generation has

committed to issue revised procedures, no additional adverse impacts to historic and

archaeological resources are expected during the license renewal term. However, as noted in

Section 4.9.6, there is the potential for prehistoric and historic archaeological resources to be

present at TMI-1. Should project plans change, then further mitigation and consultation would

be initiated by Exelon Generation with the PHMC. Based on this and other information

presented in the supplemental EIS, the staff finds that there would be no cumulative historic and

June 2009 4-41 NUREG-1437, Supplement 37
Environmental Impacts of Operation

archaeological impacts from the continued operation of TMI-1 during the license renewal term

beyond those that have already occurred.

I Exelon Generation has indicated that it plans to replace TMI-1 steam generators prior to the

license renewal term. Construction, decontamination, and laydown activities would be less than

10 ac (4 ha) and would be limited to previously disturbed areas (AmerGen 2008). Exelon

Generation has consulted with the PHMC regarding this activity. The PHMC stated that the

project would have no effect on historic and archaeological resources, however, should

I additional ground-disturbing activities occur, then further consultation with the PHMC would be

required (AmerGen 2008).

4.11.6 Summary of Cumulative Impacts

We considered the potential impacts resulting from operation of TMI-1 during the period of

extended operation and other past, present, and future actions in the vicinity of TMI-1. The

preliminary determination is that the potential cumulative impacts resulting from TMI-1 operation

during the period of extended operation would be SMALL to MODERATE.

Table 4-11. Summary of Cumulative Impacts on Resources Areas.

Resource Area Impact Discussion

Water Resources SMALL Impacts to water resources in the subbasin include

increases in land development, overuse of ground water

resources, unregulated use of ground water resources,

drought impacts, and the need for flow compensation for

consumptive water users. The SRBC regulates,

monitors, and enforces withdrawals of ground water and

surface water in the subbasin, and manages the

subbasin's water resources. Continued operation of TMI1 would have small cumulative impacts to water

resources if compliance with SRBC regulations and

participation in their water storage project is maintained.

Aquatic Resources SMALL to Impacts to aquatic resources from continued operation

MODERATE of TMI-1 would have small cumulative impacts. Past

impacts to Susquehanna River water quality have

impacted aquatic resources; and continued impacts from

agriculture, livestock production, and development will

continue to impact aquatic resources. Regulation of

point-source discharges by PADEP and of subbasin

water use by the SRBC will continue to mitigate impacts.

Continued operation and potential future uprates to dams

on the Susquehanna River will also impact aquatic

resources.

NUREG-1437, Supplement 37 4-42 June 2009
Environmental Impacts of Operation

1

Terrestrial Resources SMALL ROW maintenance, emissions from the Bruner Island

coal-fired power plant, invasive species, chemical

discharges from nearby wastewater treatment plants,

and development of Dauphin, Lancaster, and York

Counties have all impacted terrestrial habitat and

species in the vicinity of TMI-1, and would likely

continue in the future.

Human Health SMALL The cumulative human health impacts of continued

operation of TMI-1 from radiation exposure to the

public, microbiological organisms from thermal

discharge to the Susquehanna River, and electricfield-induced currents from the TMI-1 transmission

lines would all be small.

Socioeconomics N/A There would be no cumulative impacts to

socioeconomics durihg the license renewal period,

and no long7term cumulative impacts from

refurbishment. There would be no cumulative impacts

to historic and archaeological resources during the

license renewal period, including refurbishment,

beyond those that have already occurred.

4.12 References

10 CFR 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for Protection

Against Radiation."

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

Production and Utilization Facilities."

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

Regulations for Domestic Licensing and Related Regulatory Functions."

10 CFR Part 61. Code of Federal Regulations, Title 10, Energy, Part 61, "Licensing

Requirements for Land Disposal of Radioactive Waste."

10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part'71, "Packaging and

Transportation of Radioactive Material."

36 CFR Part 60. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property,

Part 60, Section 4, "Criteria for Evaluation."

36 CFR 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, Part

800, "Protection of Historic Properties."

40 CFR 190. Code of Federal Regulations, Title 40, Protection of the Environment, Part 190,

"Environmental Radiation Protection Standards for Nuclear Power Operations."

June 2009 4-43 NUREG-1437, Supplement 37
Environmental Impacts of Operation

59 FRN 7629. Executive Order 12898. "Federal Actions to Address Environmental Justice in

Minority Populations and Low-Income Populations." Federal Register Vol. 59, No. 32, p. 7629.

Washington, D.C. February 16, 1994.

69 FRN 52040. "Treatment of Environmental Justice Matters in NRC Regulatory and Licensing

Actions." Federal Register. Vol. 69, No. 163, pp. 52040-52048. Washington, D.C. August 24,

2004.

ACHP (Advisory Council on Historic Preservation). 2008. "National Register Evaluation Criteria."

Available URL: http://www.achp.gov/nrcriteria.html (accessed on October 10, 2008). ADAMS

No. ML082880723.

Adkins, C.J. 1984. Equilibrium Thermodynamics, 3rd ed. Cambridge University Press.

AEC (U.S. Atomic Energy Commission). 1972. Final Environmental Statement related to the

operation of Three Mile Island Nuclear Station, Units I and 2. Metropolitan Edison Company, et

al. Docket Nos. 50-289 and 50-320. Directorate of Licensing. December. Washington, D.C.

ADAMS No. ML080090250.

AmerGen (AmerGen Energy Company, LLC). 2004. Three Mile Island Nuclear Station Unit-1

and Unit-2 Operating License No. DPR-50 and Possession Only License No. DPR 73 Docket

Nos. 50-289 and 50-320. Radiological Environmental Monitoring Program Report, 1 January

through 31 December 2003. Middletown, PA. ADAMS No. ML041250580.

AmerGen (AmerGen Energy Company, LLC). 2004a. Three Mile Island Nuclear Station Unit-1

and Unit-2 Operating License No. DPR-50 and Possession Only License No. DPR 73 Docket

Nos. 50-289 and 50-320. Combined 2003 Annual Radioactive Effluent Release Report.

Middletown, PA. ADAMS No. ML041180052.

AmerGen (AmerGen Energy Company, LLC). 2005. Three Mile Island Nuclear Station Unit-1

and Unit-2 Operating License No. DPR-50 and Possession Only License No. DPR 73 Docket

Nos. 50-289 and 50-320. Radiological Environmental Monitoring Program Report. 1 January

through 31 December 2004. Middletown, PA. ADAMS No. ML051260258.

AmerGen (AmerGen Energy Company, LLC). 2005a. Three Mile Island Nuclear Station Unit-1

and Unit-2 Operating License No. DPR-50 and Possession Only License No. DPR 73 Docket

Nos. 50-289 and 50-320. Combined 2004 Annual Radioactive Effluent Release Report.

Middletown, PA. ADAMS No. ML051260269.

AmerGen (AmerGen Energy Company, LLC). 2006. Three Mile Island Nuclear Station Unit-1

and Unit-2 Operating License No. DPR-50 and Possession Only License No. DPR 73 Docket

Nos. 50-289 and 50-320. Updated Final Safety Analysis Report. Middletown, PA. ADAMS No.

ML080800161.

AmerGen (AmerGen Energy Company, LLC). 2006a. Three Mile Island Nuclear Station Unit-I

and Unit-2 Operating License No. DPR-50 and Possession Only License No. DPR 73 Docket

Nos. 50-289 and 50-320. Combined 2005 Annual Radioactive Effluent Release Report.

Middletown, PA. ADAMS No. ML061230244.

AmerGen (AmerGen Energy Company, LLC). 2006b. Three Mile Island Nuclear Station Unit-1

and Unit-2 Operating License No. DPR-50 and Possession Only License No. DPR 73 Docket

NUREG-1437, Supplement 37 4-44 June 2009
Environmental Impacts of Operation

Nos. 50-289 and 50-320. Radiological Environmental Monitoring Program Report, 1 January

through 31 December 2005. Middletown, PA. ADAMS No. ML061220487.

AmerGen (AmerGen Energy Company, LLC). 2007. Three Mile Island Nuclear Station Unit-1

and Unit-2 Operating License No. DPR-50 and Possession Only License No. DPR 73 Docket

Nos. 50-289 and 50-320. Combined 2006 Annual Radioactive Effluent Release Report (ODCM

Revision 25 Enclosed). Middletown, PA. ADAMS No. ML071290369.

AmerGen (AmerGen Energy Company, LLC). 2007a. Three Mile Island Nuclear Station Unit-Iand Unit-2 Operating License No. DPR-50 and Possession Only License No. DPR 73 Docket

Nos. 50-289 and 50-320. Radiological Environmental Monitoring Program Report, 1 January

through 31 December 2006. Middletown, PA. ADAMS No. ML071290163.

AmerGen (AmerGen Energy Company, LLC). 2008. Three Mile Island Nuclear Station, Unit 1,

Applicant's Environmental Report, License Renewal Operating Stage. Kennett Square, PA.

ADAMS Nos. ML080220255, ML080220257, ML080220261, and ML080220282.

AmerGen (AmerGen Energy Company, LLC). 2008a. Three Mile Island Nuclear Station Unit-1

and Unit-2 Operating License No. DPR-50 and Possession Only License No. DPR 73 Docket

Nos. 50-289 and 50-320. Radiological Environmental Monitoring Program Report, 1 January

through 31 December 2007. Middletown, PA. ADAMS No. ML081300255.

AmerGen (AmerGen Energy Company, LLC). 2008b. Three Mile Island Nuclear Station Unit-1

and Unit-2 Operating License No. DPR-50 and Possession Only License No. DPR 73 Docket

Nos. 50-289 and 50-320. Combined 2007 Annual Radioactive' Effluent Release Report.

Middletown, PA. ADAMS No. ML081300410.

AmerGen (AmerGen Energy Company, LLC). 2008c. "Excerpts about meat sampling from the

Annual Radiological Environmental Monitoring Program (REMP) Reports for the period from

1990 through 2001." Three Mile Island, Unit 1, Enclosure A -Post Audit Environmental

Information - Index Through Audit Question ENV-070, Monthly Report on the Meteorological

Monitoring Program, February 2007 (Non-Proprietary Version). June 10. ADAMS No.

ML082110252.

ASMFC '(Atlantic States Marine Fisheries Commission). 2007. Review of the Atlantic States

Marine Fisheries Commission Fishery Management Plan for Shad and River Herring (Alosa

spp.). October 3, 2007. Available'URL:

http://www.asmfc.org/speciesDocuments/shad/fmps/2007ShadFMPReviewfor2OO6.pdf

(accessed November 7, 2008). ADAMS No. ML083170642.

CBF (Chesapeake Bay Foundation). 2005. The Mighty Susquehanna River: Pollution Degrades

Our Streams, the River, and the Chesapeake Bay. Available URL:

http://www.cbf.orq/site/DocServer/susquehanna factsheet.pdf?doclD=3443 (accessed July 18,

2008). ADAMS No. ML082381277.

CBF (Chesapeake Bay Foundation). 2006. Waters at Risk; Pollution in the Susquehanna

Watershed - Sources and Solutions. Available URL:

http://www.cbf.orq/site/DocServer/WatersAtRisk.pdf?doclD=5724 (accessed August 21, 2008).

ADAMS No. ML082880724.

CDC (Centers for Disease Control and Prevention). 2001. Summary of Notifiable Diseases,

United States 1999. Morbidity and Mortality Weekly Report, Vol. 48, No. 53. April 6. Atlanta, GA.

June 2009 4-45 NUREG-1437, Supplement 37
Environmental Impacts of Operation

CDC (Centers for Disease Control and Prevention). 2002. Summary of Notifiable Diseases

United States, 2000. Morbidity and Mortality Weekly Report, Vol. 49, No. 53. June 14. Atlanta,

GA.

CDC (Centers for Disease Control and Prevention). 2002a. Surveillance for WaterborneDisease Outbreaks - United States, 1999-2000. Morbidity and Mortality Weekly Report, Vol. 51

(SS08). November 22. Atlanta, GA.

CDC (Centers for Disease Control and Prevention). 2003. Summary of Notifiable Diseases -

United States, 2001. Morbidity and Mortality Weekly Report, Vol. 52, No. 40. May 2. Atlanta,

GA. May 2, 2003.

CDC (Centers for Disease Control and Prevention). 2003a. Primary Amebic

Meningoencephalitis - Georgia, 2002. Morbidity and Mortality Weekly Report, Vol. 50, No. 53.

October 10. Atlanta, GA.

CDC (Centers for Disease Control and Prevention). 2004. Surveillance for Waterborne-Disease

Outbreaks Associated with Recreational Water-United States, 2001-2002. Morbidity and

Mortality Weekly Report, Vol. 53 (SS08). October 22. Atlanta, GA.

CDC (Centers for Disease Control and Prevention). 2005. Summary of Notifiable Diseases -

United States, 2003. Morbidity and Mortality Weekly Report, Vol. 52, No. 54. April 22. Atlanta,

GA.

CDC (Centers for Disease Control and Prevention). 2006. Summary of Notifiable Diseases -

United States, 2004. Morbidity and Mortality Weekly Report, Vol. 53, No. 53. June 16. Atlanta,

GA.

CDC (Centers for Disease Control and Prevention). 2007. "Legionellosis: Legionnaires Disease

and Pontiac Fever." Available URL:

http://www.cdc.gov/ncidod/dbmd/diseaseinfo/lecqionellosis .q.htm (accessed on March 27,

2008). ADAMS No. ML080230326.

CDC (Centers for Disease Control and Prevention). 2007a. "Salmonellosis." Available URL:

http://www.cdc.qov/ncidod/dbmd/diseaseinfo/salmonellosis .q.htm (accessed on March 27,

2008). ADAMS No. ML080230323.

CDC (Centers for Disease Control and Prevention). 2007b. Summary of Notifiable Diseases -

United States, 2005. Morbidity and Mortality Weekly Report, Vol. 54, No. 53. March 30. Atlanta,

GA.

CEQ (Council on Environmental Quality). 1997. Environmental Justice: Guidance Under the

National Environmental Policy Act. Executive Office of the President. December 10.

Washington, DC. Available URL:

http://www.epa..qov/compliance/resources/lpolicies/em/e* ,guidance nepa ceql297.pdf (accessed

August 18, 2008). ADAMS No. ML082520150.

DCNR (Pennsylvania Department of Conservation and Natural Resources). 2008. Letter from R.

Bowen, Environmental Review Specials, Pennsylvania Department of Conservation and Natural

Resources, to L. Lund, Branch Chief, Division of License Renewal, Nuclear Regulatory

Commission. Subject: Pennsylvania Natural Diversity Inventory Review, PNDI Number 19605,

NUREG-1437, Supplement 37 4-46 June 2009
Environmental Impacts of Operation

Three Mile Island Unit 1 License Renewal Species of Special Concern, Dauphin & Lancaster

Counties. May 2, 2008. ADAMS No. ML081300048.

Durlin, R.R. and W.P. Schaffstall. 2005. Water Resources Data Pennsylvania Water Year 2004,

Water-Data Report PA-04-2. U.S. Geological Survey. May. New Cumberland, PA. ADAMS No.

ML081980705.

EPA (U.S. Environmental Protection Agency). 1997. Climate Change and Pennsylvania.

September. Available URL:

http://yvosemite.epaa.gov/OAR/cLqobalwarming. nsf/UniqueKeyLookup/SHSU5BVMDY/$File/pa im

pct.pd (accessed May 19, 2009). ADAMS No. ML091390884.

ESR (Institute of Environmental Science & Research Limited). 2002. Risk Profile: Salmonella

(Non Typhoid) in Poultry (Whole and Pieces). Christchurch, New Zealand. October. Available

URL: http://www. nzfsa.govt. nz/science/risk-profiles/salmonella-in-poultrymeat.pdf?bcsi scan 513F405096A035F7=0&bcsi scan filename=salmonella-in-poul

(accessed on March 27, 2008). ADAMS No. ML080880142.

Exelon Generation (Exelon Generation Company, LLC). 2009. Three Mile Island Nuclear

Station Unit I License Renewal Updated Environmental Information. "Combined Docket

Application Water Withdrawals and Consumptive Use Three Mile Island Nuclear Station." March

25. Kennett Square, Pennsylvania. Pp. 55-107. ADAMS No. ML090890364.

Exelon Generation (Exelon Generation Company, LLC). 2009a. "Three Mile Island Nuclear

Station Unit 1 License Renewal Application Supplemental Updated Environmental Information."

May 15. ADAMS No. ML091390217.

FWS (United States Fish and Wildlife Service). 2008. Letter from D. Densmore, Supervisor,

U.S. Fish and Wildlife Service, Pennsylvania Field Office, to L. Lund, Branch Chief, Division of

License Renewal, Nuclear Regulatory Commission. Subject: Three Mile Island Nuclear Station,

Unit 1, License Renewal Application Review. April 23, 2008. ADAMS No. ML081280307.

Greenwire. 2008. Renewable Energy: Hydropower Makes a Quiet Comeback. October 28.

Available URL: http://www.eenews.net/Greenwire/2008/10/28/archive/4?terms=holtwood

(accessed November 7, 2008). ADAMS No. ML0831170642.

Hendricks, C.W. 1972. "Enteric Bacterial Growth Rates in River Water." Applied Microbiology

24(2): 168-174.

Joklik, W. K, and H. P. Willet. 1976. Zinsser Microbiology, 16th ed. Appleton-Century-Crofts,

New York.

NAS (National Research Council of the National Academies of Science). 2004. Indicators for

Waterborne Pathogens. The National Academies Press, Washington, D.C.

NESC (National Electrical Safety Code). 2007. Institute of Electrical and Electric Engineers. NY.

ADAMS No. ML080880143.

NHPA (National Historic Preservation Act). 1996. 16 U.S.C. 470, et seq.

NIEHS (National Institute of Environmental Health Sciences). 1999. NIEHS Report on Health

Effects from Exposure to Power Line Frequency and Electric and Magnetic Fields. Publication

No. 99-4493, Research Triangle Park, NC.

June 2009 ,4-47 NUREG-1 437, Supplement 37
Environmental Impacts of Operation

NRC (U.S. Nuclear.Regulatory Commission). 1976. NUREG-0112. Final Supplement to the

Final Environmental Statement Related to the Operation of Three Mile Island Nuclear Station,

Unit 2, Metropolitan Edison Company et aL, Docket No. 50-320. Office of Nuclear Reactor

Regulation, Washington, D.C. December. ADAMS No. ML080090250.

NRC (U.S. Nuclear Regulatory Commission). 1981. Final Environmental Statement Related to

the Operation of Susquehanna Steam Electric Station. Pennsylvania Power & Light Company

and Allegheny Electric Cooperative, Inc. Docket Nos. 50-387 and 50-388. Office of Nuclear

Reactor Regulation, Washington, D.C. June. ADAMS No. ML080150291.

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

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

No. ML061770605.

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

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

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

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

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

Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal. NUREG-1 555,

Supplement 1, Washington, D.C.

NRC (U.S. Nuclear Regulatory Commission). 2008. Letter from L. Lund, U.S. Nuclear

Regulatory Commission, Washington, D.C., to J. Cutler, Pennsylvania Historical and Museum

Commission, Harrisburg, Pennsylvania. Subject: "Three Mile Island Nuclear Station, Unit 1,

License Renewal Application Review (File No. ER 07-1737-043-A)." ADAMS No.

ML080930380.

NRC (U.S. Nuclear Regulatory Commission). 2008a. Letter from L. Lund, U.S. Nuclear

Regulatory Commission, Washington, D.C., to C. Vaughn, Advisory Council on Historic

Preservation, Washington, D.C.Subject: "Three Mile Island Nuclear Station, Unit 1, License

Renewal Application Review." ADAMS No. ML080930296.

PADEP (Pennsylvania Department of Environmental Protection). 2008. Environmental

Radiation in Pennsylvania. 2003 and 2004 Annual Reports. Available URL:

http://www.dep.state.pa.us/brp/BRP Info/Annual Reports.htm (accessed August 18, 2008).

ADAMS No. ML082880726.

PGC (Pennsylvania Game Commission). 2008. Letter from J. Leigey, Division of Environmental

Planning and Habitat Protection, Bureau of Wildlife Habitat Management, to L. Lund, Branch

Chief, Division of License Renewal, Nuclear Regulatory Commission. Subject: State-Protected

Bird and Mammal Species Review, Three Mile Island Nuclear Station License Renewal

Application, Londonderry Township, Dauphin County, PA. May 14, 2008. ADAMS No.

ML081500671.

PFBC (Pennsylvania Fish & Boat Commission). 2007. Migratory Fish Restoration and Passage

on the Susquehanna River. Available URL:

http://www.fish.state.pa.us/pafish/shad/miqratory fish.pdf (accessed July 31, 2008). ADAMS

No. ML080230330.

NUREG-1437, Supplement 37 4-48 June 2009
Environmental Impacts of Operation

PFBC (Pennsylvania Fish & Boat Commission). 2008. Letter from C. Urban, Chief, Natural

Diversity Section, Pennsylvania Fish & Boat Commission, Bellefonte, Pennsylvania, to S.

Lopas, Nuclear Regulatory Commission, Rockville, Maryland. Subject: Species Impact Review

(SIR) - Rare, Candidate, Threatened and Endangered Species, Three Mile Island Nuclear

Station, Londonderry Township/Borough, Dauphin County, Pennsylvania. June 3, 2008.

ADAMS No. ML081610104.

PFBC (Pennsylvania Fish & Boat Commission). 2008a. "Susquehanna River American Shad."

Available URL: (http://www.fish.state.pa.us/shad susq.htm (accessed June 11, 2008). ADAMS

No. ML082381115.

PFBC (Pennsylvania Fish & Boat Commission). 2008b. Susquehanna River Drainage YOY

Smallmouth Bass Disease Investigations 2005 and 2007. URL:

http://www.fish.state.pa.us/pafish/bass black/meetinqs/fish committee2007sep/mortality07 05.

pdf?bcsi scan B666AIDE717DB577=0&bcsi scan filename=mortality07 05.pdf (accessed

June 3, 2008). ADAMS No. ML082880420.

PFBC (Pennsylvania Fish & Boat Commission). 2008c. "2008 Pennsylvania Fishing Summary,

Summary of Fishing Regulations and Laws". Available URL:

http://www.fishlstate.pa.us/fishpub/summarv/zOOcomplete.pdf (accessed July 23, 2008).

ADAMS No. ML082880450.

PNHP (Pennsylvania Natural Heritage Program). 2008. "State Species List, Update June 2008."

Available URL: http://www.naturalheritaqe.state.pa.us/Homepage.aspx (accessed July 14,

2008). ADAMS No. ML082381127.

PPL Corporation (PPL). 2008. "Bruner Island Fact Sheet." Available URL:

http:g/www.pp[web.com/ppl+pqeneration/coal+plants/ppl+brunner+island+-+fact+sheet.htm

(accessed June 5, 2008). Accessible at ML08082381272.

SRBC (Susquehanna River Basin Commission). 2005. Groundwater Management Plan for the

Susquehanna River Basin. June 8. Available URL:

http://www.srbc.net/pcroqrams/docs/GW Mnqt Plan June2005/Groundwater Mgt Plan 2005.ht

rn (accessed July 28, 2008). ADAMS No. ML082880727.

SRBC (Susquehanna River Basin Commission). 2006. Lower Susquehanna Subbasin Survey:

A Water Quality and Biological Assessment, June - November 2005, Publication 247.

September. Available URL:

http://www.srbc.net/pubinfo/techdocs/Publication 247/LowerSusqRept.pdf (accessed August

21, 2008). ADAMS No. ML082381270.

SRBC (Susquehanna River Basin Commission). 2008. Draft Comprehensive Plan for the Water

Resources of the Susquehanna River Basin. Harrisburg, PA. May. Available URL:

http://www.srbc.net/planninq/comp plan with appendicies.pdf (accessed August 20, 2008).

ADAMS No. ML082880729.

SRBC (Susquehanna River Basin Commission). Undated. "Lower Susquehanna Subbasin

Information." Available URL: http://www.srbc.net/subbasin/lowersus.htm (accessed August 20,

2008). ADAMS No. ML082381278.

Todar, K. 2007. Todar's Online Textbook of Bacteriology. Available URL:

http://www.textbookofbacteriology.net (accessed on July 27, 2007).

June 2009 4-49 NUREG-1437, Supplement 37
Environmental Impacts of Operation

Tyndall, R. L., et al. 1989. "Effect of thermal additions on the density and distribution of

thermophilic amoebae and pathogenic Naegleria fowleri in a newly created cooling lake."

Applied Environmental Microbiology 55:722-732.

UCS (Union of Concerned Scientists). 2008. Climate Change in Pennsylvania - Impacts and

Solutions for the Keystone State. October. Available URL:

http://www.ucsusa.orq/assets/documents/qlobal warminq/Climate-Chanqe-inPennsylvania Impacts-and-Solutions.pdf (accessed May 19, 2009). ADAMS No. ML091390883.

USCB (U.S. Census Bureau). 2003. Landview 6 - Census 2000 Profile of General Demographic

Characteristics DP-1 (100%) and Census Profile of Selected Economic Characteristics DP-3,

Summary of Census Block Groups in a 50-mile Radius around TMI-1 (40.154569 Lat., -

76.725256 Long.) December. Washington, D.C.

USCB (U.S. Census Bureau). 2008. "American FactFinder, Census 2000 Information," and

"State and County QuickFacts on Dauphin and Lancaster Counties." Searchable databases.

Available URLs: http://factfinder.census.gov and http://quickfacts.census.qov (accessed July

2008).

WHO (World Health Organization). 2007. Extremely Low Frequency Fields Environmental

Health Criteria Monograph No.238. Geneva, Switzerland. Available URL:

http://www.who.int/peh-emf/publications/elf ehc/en/index.html (accessed October 14, 2008).

ADAMS No. ML082880728.

NUREG-1437, Supplement 37 4-50 June 2009
5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS

This chapter describes the environmental impacts from postulated accidents that might occur

during the period of extended operation. The term "accident" refers to any unintentional event

outside the normal plant operational envelope that results in a release or the potential for

release of radioactive materials into the environment. Two classes of postulated accidents are

evaluated in the GElS and are listed in Table 5-1 below. These are design-basis accidents

(DBAs) and severe accidents.

Table 5-1. Issues Related to Postulated Accidents. Two issues related to

postulated accidents are evaluated under NEPA in the license renewal

review, design-basis accidents and severe accidents.

Issues GElS Section Category

Design-basis accidents 5.3.2; 5.5.1 1

Severe accidents 5.3.3; 5.3.3.2;

5.3.3.3; 5.3.3.4; 2

5.3.3.5; 5.4; 5.5.2

5.1 Design Basis Accidents

In order to receive NRC approval to operate a nuclear power facility, an applicant for an initial

operating license must submit a safety analysis report (SAR) as part of its application. The SAR

contains the design criteria and design information for the proposed reactor and comprehensive

data on the proposed site. The SAR also discusses various hypothetical accident situations and

the safety features that are provided to prevent and mitigate accidents. The NRC staff reviews

the application to determine whether or not the plant design meets the Commission's

regulations and requirements and includes, in part, the nuclear plant design and its anticipated

response to an accident.

DBAs are those accidents that both the licensee and the NRC staff evaluate to ensure that the

plant can withstand normal and abnormal transients, and a broad spectrum of postulated

accidents, without undue hazard to the health and safety of the public. A number of these

postulated accidents are not expected to occur during the life of the plant, but are evaluated to

establish the design basis for the preventive and mitigative safety systems of the facility. The

acceptance criteria for DBAs are described in 10 CFR 50 and 10 CFR 100.

The environmental impacts of DBAs are evaluated during the initial licensing process, and the

ability ofthe plant to withstand these accidents is demonstrated to be acceptable before

issuance of the operating license. The results of these evaluations are found in license

documentation such as the applicant's final safety analysis report (FSAR), the safety evaluation

report (SER), the final environmental statement (FES), and Section 5.1 of this supplemental

environmental impact statement (EIS). A licensee is required to maintain the acceptable design

and performance criteria throughout the life of the plant, including any extended-life operation.

The consequences for these events are evaluated for the hypothetical maximum exposed

individual; as such, changes in the plant environment will not affect these evaluations. Because

of the requirements that continuous acceptability of the consequences and aging management

programs be in effect for the period of extended operation, the environmental impacts as

June 2009 5-1 NUREG-1437, Supplement 37
Environmental Impacts of Postulated Accidents

calculated for DBAs should not differ significantly from initial licensing assessments over the life

of the plant, including the period of extended operation. Accordingly, the design of the plant

relative to DBAs during the period of extended operation is considered to remain acceptable

and the environmental impacts of those accidents were not examined further in the GELS.

The Commission has determined that the environmental impacts of DBAs are of SMALL

significance for all plants because the plants were designed to successfully withstand these

accidents. Therefore, for the purposes of license renewal, design-basis accidents are

designated as a Category 1 issue. The early resolution of the DBAs makes them a part of the

current licensing basis of the plant; the current licensing basis of the plant is to be maintained by

the licensee under its current license and, therefore, under the provisions of 10 CFR 54.30, is

not subject to review under license renewal.

No new and significant information related to design-basis accidents was identified during the

review of Exelon Generation's environmental report (ER) (AmerGen 2008a), site audit, scoping

process, or evaluation of other available information. Therefore, there are no impacts related to

these issues beyond those discussed in the GELS.

5.2 Severe Accidents

Severe nuclear accidents are those that are more severe than DBAs because they could result

in substantial damage to the reactor core, whether or not there are serious offsite

consequences. In the GELS, the staff assessed the impacts of severe accidents during the

license renewal period, using the results of existing analyses and site-specific information to

conservatively predict the environmental impacts of severe accidents for each plant during the

renewal period.

Severe accidents initiated by external phenomena such as tornadoes, floods, earthquakes,

fires, and sabotage have not traditionally been discussed in quantitative terms in FESs and

were not specifically considered for the Three Mile Island Nuclear Station, Unit 1 (TMI-1) site in

the GElS (NRC 1996). However, the GElS did evaluate existing impact assessments

performed by NRC and by the industry at 44 nuclear plants in the United States and concluded

that the risk from beyond design basis earthquakes at existing nuclear power plants is SMALL.

The GElS for license renewal performed a discretionary analysis of terrorist acts in connection

with license renewal, and concluded that the core damage and radiological release from such

acts would be no worse than the damage and release expected from internally initiated events.

In the GELS, the Commission concludes that the risk from sabotage and beyond design-basis

earthquakes at existing nuclear power plants is small and additionally, that the risks from other

external events are adequately addressed by a generic consideration of internally initiated

severe accidents (NRC 1996).

Based on information in the GELS, the Commission found that

The probability weighted consequences of atmospheric releases, fallout onto

open bodies of water, releases to ground water, and societal and economic

impacts from severe accidents are small for all plants. However, alternatives to

NUREG-1437, Supplement 37 5-2 June 2009
Environmental Impacts of Postulated Accidents

mitigate severe accidents must be considered for all plants that have not

considered such alternatives.

We identified no new and significant information related to postulated accidents during the

review of Exelon Generation's ER (AmerGen 2008a), the site audit, the scoping process, or

evaluation of other available information. Therefore, there are no impacts related to these

issues beyond those discussed in the GELS. However, in accordance with 10 CFR

51.53(c)(3)(ii)(L), we have reviewed severe accident mitigation alternatives (SAMAs) for TM I-I.

The results of the review are discussed in Section 5.3.

5.3 Severe Accident Mitigation Alternatives

Section 51.53(c)(3)(ii)(L) requires that license renewal applicants consider alternatives to

mitigate severe accidents if the staff has not previously evaluated SAMAs for the applicant's

plant in an EIS or related supplement or in an environmental assessment. The purpose of this

consideration is to ensure that plant changes (i.e., hardware, procedures, and training) with the

potential for improving severe accident safety performance are identified and evaluated.

SAMAs have not been previously considered for TMI-1; therefore, the remainder of Chapter 5

addresses those alternatives.

5.3.1 Introduction

This section presents a summary of the SAMA evaluation for TMI-1 conducted by Exelon

Generation Company, LLC (Exelon Generation) and the NRC staffs review of that evaluation.

The NRC staff performed its review with contract assistance from Pacific Northwest National

Laboratory. The NRC staff's review is available in full in Appendix F; the SAMA evaluation is

available in full in Exelon Generation's ER.

The SAMA evaluation for TMI-1 was conducted with a four step approach. In the first step

Exelon Generation quantified the level of risk associated with potential reactor accidents using

the plant specific probabilistic risk assessment (PRA) and other risk models.

In the second step Exelon Generation examined the major risk contributors and identified

possible ways (SAMAs) of reducing that risk. Common ways of reducing risk are changes to

components, systems, procedures, and training. Exelon Generation identified 33 potential

SAMAs for TMI-1. Exelon Generation performed an initial screening to determine if any SAMAs

could be eliminated because they are not applicable to TMI-1 due to design differences, or have

estimated implementation costs that would exceed the dollar value associated with completely

eliminating all severe accident risk at TMI-1 related to power generation operations. No SAMAs

were eliminated based on this screening, leaving all 33 for further evaluation.

In the third step Exelon Generation estimated the benefits and the costs associated with each of

the SAMAs. Estimates were made of how much each SAMA could reduce risk. Those

estimates were developed in terms of dollars in accordance with NRC guidance for performing

regulatory analyses (NRC 1997). The cost of implementing the proposed SAMAs was also

estimated.

June 2009 5-3 NUREG-1437, Supplement 37
Environmental Impacts of Postulated Accidents

Finally, in the fourth step, the costs and benefits of each of the remaining SAMAs were

compared to determine whether the SAMA was cost beneficial, meaning the benefits of the

SAMA were greater than the cost (a positive cost benefit). Exelon Generation concluded in its

ER that several of the SAMAs evaluated are potentially cost-beneficial (AmerGen 2008a).

However, in response to NRC staff inquiries regarding estimated benefits for certain SAMAs

and lower cost alternatives, several additional potentially cost-beneficial SAMAs were identified

(AmerGen 2008b).

The potentially cost-beneficial SAMAs do not relate to adequately managing the effects of aging

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

license renewal pursuant to 10 CFR Part 54. Exelon Generation's SAMA analyses and the

NRC's review are discussed in more detail below.

5.3.2 Estimate of Risk

I Exelon Generation submitted an assessment of SAMAs for TMI-1 as part of the ER (AmerGen

2008a). This assessment was based on the most recent TMI-1 PRA available at that time, a

plant specific offsite consequence analysis performed using the MELCOR Accident

Consequence Code System 2 (MACCS2) computer program, and insights from the TMI-1

Individual Plant Examination (IPE) (GPU 1993) and Individual Plant Examination of External

Events (IPEEE) (GPU 1994).

The scope of the Level 1 PRA model includes both internal and external initiating events. The

external events evaluated are external floods, seismic events, and internal fires. However, the

external events models are neither integrated with the internal event model, nor maintained as

living analyses, thereby necessitating a separate assessment of the risk (and risk reduction) for

internal and external events. Exelon Generation placed particular emphasis on external

flooding events since they dominate the calculated risk at TMI-1.

The baseline CDF for the purpose of the SAMA evaluation is approximately 2.37 x 10-5 per year

for internal events (including internal flooding events), and 8.11 x 10-5 per year for external

I flooding events. Exelon Generation accounted for the potential risk reduction benefits

associated with internal event- and external flooding-related SAMAs by separately quantifying

the benefits using the internal event or external flooding model, respectively. For internal eventI related SAMAs, Exelon Generation accounted for the potential risk reduction benefits

associated with non-flooding external events (i.e., seismic and fire events) by doubling the

I estimated benefits for internal events. For seismic- and fire-related SAMAs, Exelon Generation

separately estimated the risk reduction benefits using the seismic and fire risk models. The

breakdown of CDF by initiating event for TMI-1 is provided in Tables 5-1 and 5-2 for internal

events and external flooding events, respectively.

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Environmental Impacts of Postulated Accidents

Table 5-2. TMI-1 Internal Events Core Damage

Frequency

Initiating Event CDF

(Per Year) Contribution

to CDF

Loss of Offsite Power 7.73 x 10-6 32.6

Transients 5.80 x 10-6 24.5

Small and Very Small LOCA 4.66 x 10-6 19.7

Loss of Nuclear Service River Water 3.67 x 10-6 15.5

Steam Generator Tube Rupture 9.93 x 10-7 4.2

Internal Floods 4.50 x 107 1.9

Large and Medium LOCA 2.06 x i0-7 < 1

ISLOCA 1.80 x 107 <1

Total CDF (internal events) 2.37 x 10- 100

Table 5-3 TMI-1 External Flooding Events Core Damage

Frequency

External Flooding Event CDF Contribution

(Per Year) to CDF

>310 feet 6.37 x 10.5 78.5

305 to 310 feet 1.71 x 10.5 21.1

<305 feet 2.50 x 107 < 1

Total 8.11 x 10-5 100

As shown in these tables, internal event CDF is dominated by loss of offsite power events,

transients, small loss of coolant accidents (LOCA), and loss of nuclear service water events.

External flooding CDF is dominated by events with flood levels exceeding 305 feet mean sea

level (msl).

Exelon Generation estimated the dose to the population within 50 mi (80 kin) of the TMI-1 site to

be approximately 0.323 person-sievert (Sv) (32.3 person-rem) per year (AmerGen 2008a) for

internal events and 1.76 person-Sv (176 person-rem) per year for external flooding events

(AmerGen 2008b). The breakdown of the total population dose by containment release mode is

summarized in Table 5-4. Steam generator tube rupture (SGTR) accidents, and basemat meltthrough are the dominant contributors to population dose risk from internal events. For external

flooding events, late containment failures and early containment failure (less than 12 hours

following accident initiation) are the dominant contributors to population dose risk.

June 2009 5-5 NUREG-1437, Supplement 37
Environmental Impacts of Postulated Accidents

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

Internal Events External Flooding Events

Population Population

Dose % Dose %

Containment Release Mode (Person- Contribution (Person- Contribution

Rem Per Rem Per

Year) Year)

Steam generator tube rupture 11.7 36 0.1 <0.1

Interfacing system LOCA 1.0 3 negligible 0

Containment isolation failure 1.1 3 29 16

Early containment failure 5.6 17 61 35

Late containment failure (large) 0.3 1 15 9

Late containment failure (small) 1.7 5 66 37

Basemat melt-through 6.9 22 4 2

No containment failure 4.0 13 1 1

Total 32.3 100 176 100

1

One person-Rem = 0.01 person-Sv

I The NRC staff has reviewed Exelon Generation's data and evaluation methods and concludes

that the quality of the risk analyses is adequate to support an assessment of the risk reduction

potential for candidate SAMAs. Accordingly, the staff based its assessment of offsite risk on the

CDFs and offsite doses reported by Exelon Generation.

5.3.3 Potential Plant Improvements

Once the dominant contributors to plant risk were identified, Exelon Generation searched for

ways to reduce that risk. In identifying and evaluating potential SAMAs, Exelon Generation

considered insights from the plant-specific PRA, and SAMA analyses performed for other

operating plants that have submitted license renewal applications. This search included

reviewing insights from the plant-specific risk studies, and reviewing plant improvements

I considered in previous SAMA analyses. Exelon Generation identified 33 potential risk-reducing

improvements (SAMAs) to plant components, systems, procedures and training. A detailed

cost-benefit analysis was performed for each of the SAMAs.

I The staff concludes that Exelon Generation used a systematic and comprehensive process for

identifying potential plant improvements for TMI-1, and that the set of potential plant

I improvements identified by Exelon Generation is reasonably comprehensive and, therefore,

acceptable.

NUREG-1437, Supplement 37 5-6 June 2009
Environmental Impacts of Postulated Accidents

5.3.4 Evaluation of Risk Reduction and Costs of Improvements

Exelon Generation evaluated the risk reduction potential of the candidate SAMAs. The SAMA

evaluations were performed using realistic assumptions with some conservatism.

Exelon Generation estimated the costs of implementing the candidate SAMAs through the

application of engineering judgment and the use of other licensee's estimates for similar

improvements. The cost estimates conservatively did not include the cost of replacement power

during extended outages required to implement the modifications, nor did they account for

inflation.

The staff reviewed Exelon Generation's bases for calculating the risk reduction for the various

plant improvements and concludes that the rationale and assumptions for estimating risk

reduction are reasonable and generally conservative (i.e., the estimated risk reduction is higher

than what would actually be realized). Accordingly, the staff based its estimates of averted risk

for the various SAMAs on Exelon Generation's risk reduction estimates.

The staff reviewed the bases for the applicant's cost estimates. For certain improvements, the

staff also compared the cost estimates to estimates developed elsewhere for similar

improvements, including estimates developed as part of other licensees' analyses of SAMAs for

operating reactors and advanced light-water reactors. The staff found the cost estimates to be

reasonable, and generally consistent with estimates provided in support of other plants'

analyses.

The staff concludes that the risk reduction and the cost estimates provided by Exelon

Generation are sufficient and appropriate for use in the SAMA evaluation.

5.3.5 Cost-Benefit Comparison

The cost benefit analysis performed by Exelon Generation was based primarily on NUREG/BR

0184 (NRC 1997) and was executed consistent with this guidance. NUREG/BR-0058 has

recently been revised to reflect the agency's revised policy on discount rates. Revision 4 of

NUREG/BR-0058 states that two sets of estimates should be developed - one at 3 percent and

one at 7 percent (NRC 2004). Exelon Generation performed the SAMA analysis using only a 3

percent discount rate (AmerGen 2008a) and based its decisions on potentially cost-beneficial

SAMAs on these values. Use of only a 3 percent discount rate in the cost-benefit analysis is

considered acceptable for the purposes of the SAMA evaluation since it would tend to result in

identification of a greater number of potentially cost-beneficial SAMAs.

Exelon Generation identified nine potentially cost-beneficial SAMAs in the baseline analysis

contained in the ER. The potentially cost-beneficial SAMAs are:

SAMA 8 - Automate reactor coolant pump trip on high motor bearing cooling temperature.

SAMA 11 - Enhance extreme external flooding mitigation equipment to address station

blackout and loss of reactor coolant pump seal cooling scenarios.

June 2009 5-7 NUREG-1437, Supplement 37
Environmental Impacts of Postulated Accidents

SAMA 12 - Use the decay heat removal system as an alternate suction source for high

pressure injection.

SAMA 16 - Automate high pressure injection on low pressurizer level.

SAMA 19 - Install battery backed hydrogen igniters or a passive hydrogen ignition system.

SAMA 21 - Install concrete shields to block direct pathways from the reactor pressure

vessel to the containment wall and/or direct containment flooding early in external flooding

scenarios.

SAMA 27 - Improve the 480V AC load center welds.

SAMA 32 - Pre-stage severe external flooding equipment.

SAMA 33 - Increase the flood protection height.

Exelon Generation performed additional analyses to evaluate the impact of parameter choices

and uncertainties on the results of the SAMA assessment (AmerGen 2008a). If the benefits are

increased by a factor of 2.75 to account for uncertainties, six additional SAMA candidates were

determined to be potentially cost-beneficial:

SAMA 2 - Install damage-resistant high temperature reactor coolant pump seals with a

portable 480V AC generator for extended emergency feedwater (EFW) operation.

SAMA 7 - Use fire service water as an alternate cooling source for the intermediate closed

cooling water heat exchangers.

SAMA 15 - Automate swap to recirculation mode.

SAMA 23 - Develop alarm response procedures to direct operation of RR-V-5 on low

reactor building emergency cooling flow.

SAMA 24 - Install damage-resistant high temperature reactor coolant pump seals with a

diesel engine as an alternate drive for an EFW pump and a portable 480V AC generator for

extended EFW operation.

SAMA 26 - Reroute cables so that they do not pass over ignition sources in fire zone CBFA-2e or wrap them in fire proof material.

As a result of an additional sensitivity analysis and response to an NRC staff request, Exelon

Generation identified two additional potentially cost-beneficial SAMAs (AmerGen 2008b):

SAMA 10 - Automate borated water storage tank refill.

SAMA 13 - Change instrument air system logic to automatically start IA-P-1A/B

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Environmental Impacts of Postulated Accidents

The staff concludes that, with the exception of the potentially cost-beneficial SAMAs discussed

I above, the costs of the SAMAs evaluated would be higher than the associated benefits when

they are considered independently.

5.3.6 Conclusions

I The staff reviewed Exelon Generation's analysis and concluded that the methods used and the

implementation of those methods were sound. The treatment of SAMA benefits and costs

I support the general conclusion that the SAMA evaluations performed by Exelon Generation are

reasonable and sufficient for the license renewal submittal.

I Based on its review of the SAMA analysis, the staff concurs with Exelon Generation's

identification of areas in which risk can be further reduced in a cost-beneficial manner through

the implementation of all or a subset of potentially cost-beneficial SAMAs. Given the potential

for cost-beneficial risk reduction, the staff considers that further evaluation of these SAMAs by

I Exelon Generation is warranted. However, none of the potentially cost-beneficial SAMAs relate

to adequately managing the effects of aging during the period of extended operation.

Therefore, they need not be implemented as part of the license renewal pursuant to 10 CFR

Part 54.

5.4 References

AmerGen (AmerGen Energy Company, LLC). 2008a. "Three Mile Island Nuclear Station,

Applicant's Environmental Report, License Renewal Operating Stage." Kennett Square,

Pennsylvania. ADAMS Accession Nos. ML080220255, ML080220257, ML080220261, and

ML080220282.

AmerGen (AmerGen Energy Company, LLC). 2008b. Letter from Michael P. Gallagher,

AmerGen Energy Company, LLC, to U.S. Nuclear Regulatory Commission Document Control

Desk. Subject: "Response to NRC Request for Additional Information Related to Three Mile

Island Nuclear Station 1 License Renewal Application (TAC No. MD7702)," dated July 17, 2008.

GPU (GPU Nuclear Corporation). 1993. Letter from T. G. Broughton, GPU, to U.S. NRC.

Subject: Three Mile Island Nuclear Generation Station, Unit 1 (TMI-1), Operating License No.

DPR-50, Docket No. 50-289, Response to Generic Letter 88-20, "Individual Plan Examinations

for Severe Accident Vulnerabilities (IPE)". May 20, 1993.

GPU (GPU Nuclear Corporation). 1994. Letter from R. W. Keaten, GPU, to U.S. NRC.

Subject: Three Mile Island Nuclear Generation Station, Unit 1 (TMI-1), Operating License No.

DPR-50, Docket No. 50-289, Response to Generic Letter 88-20, Supplement 4, "Individual Plan

Examination of External Events (IPEEE) for Severe Accident Vulnerabilities". December 29,

1994.

NRC (U.S. Nuclear Regulatory Commission). 1997. Regulatory Analysis Technical Evaluation

Handbook. NUREG/BR 0184, Washington, D.C.

NRC (U.S. Nuclear Regulatory Commission). 2004. Regulatory Analysis Guidelines of the U.S.

Nuclear Regulatory Commission. NUREG/BR-0058, Rev. 4, Washington, D.C.

June 2009 5-9 NUREG-1437, Supplement 37

6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE

AND SOLID WASTE MANAGEMENT

This chapter addresses issues related to the uranium fuel cycle and solid waste management

during the period of extended operation. The uranium cycle includes uranium mining and

milling, the production of uranium hexafluoride, isotopic enrichment, fuel fabrication,

reprocessing of irradiated fuel, transportation of radioactive materials, and management of lowlevel wastes and high-level wastes related to uranium fuel cycle activities. The generic

environmental impact statement (GELS) (NRC 1996, 1999) details the potential generic impacts

of the radiological and nonradiological environmental impacts of the uranium fuel cycle and

transportation of nuclear fuel and wastes, as listed in Table 6-1 below. The GElS is based, in

part, on the generic impacts provided in Table S-3, "Table of Uranium Fuel Cycle Environmental

Data," in Title 10, Section 51.51(b), of the Code of Federal Regulations (10 CFR 51.51(b)), and

in Table S-4, "Environmental Impact of Transportation of Fuel and Waste to and from One LightWater-Cooled Nuclear Power Reactor," in 10 CFR 51.52(c). The GElS also addresses the

impacts from radon-222 and technetium-99.

The staff of the U.S. Nuclear Regulatory Commission (NRC) did not identify any new and

significant information related to the uranium fuel cycle during the review of the Exelon

Generation Company, LLC environmental report (AmerGen 2008), the site audit, and the

scoping process. Therefore, there are no impacts related to these issues beyond those

discussed in the GELS. For these Category 1 issues, the GElS concludes that the impacts are

SMALL, except for the collective offsite radiological impacts from the fuel cycle and from highlevel waste and spent fuel disposal.

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

Management. Nine generic issues are related to the fuel cycle and solid

waste management. There are no site-specific issues.

Issues GElS Section Category

Offsite radiological impacts (individual effects from other

than the disposal of spent fuel and high-level waste)

Offsite radiological impacts (collective effects)

Offsite radiological impacts (spent fuel and high-level

waste disposal)

Nonradiological impacts of the uranium fuel cycle

Low-level waste storage and disposal

6.1,6.2.1,

6.2.2.1, 6.2.2.3,

6.2.3- 6.2.4, 6.6

6.1, 6.2.2.1,

6.2.3, 6.2.4, 6.6

6.1, 6.2.2.1,

6.2.3, 6.2.4, 6.6

6.1, 6.2.2.6,

6.2.2.7, 6.2.2.8,

6.2.2.9, 6.2.3,

6.2.4,6.6

6.1, 6.2.2.2,

6.4.2, 6.4.3,

6.4.3.1, 6.4.3.2,

6.4.3.3, 6.4.4,

6.4.4.1, 6.4.4.2,

1

1

1

1

1

June 2009 6-1 NUREG-1437, Supplement 37
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

Issues GElS Section Category

6.4.4.3, 6.4.4.4,

6.4.4.5, 6.4.4.5.1,

6.4.4.5.2,

6.4.4.5.3,

6.4.4.5.4, 6.4.4.6,

6.6

Mixed waste storage and disposal 6.4.5.1, 6.4.5.2,

6.4.5.3, 6.4.5.4,

6.4.5.5, 6.4.5.6,

6.4.5.6.1, 1

6.4.5.6.2,

6.4.5.6.3,

6.4.5.6.4, 6.6

Onsite spent fuel 6.1, 6.4.6,

6.4.6.1, 6.4.6.2,

6.4.6.3, 6.4.6.4, 1

6.4.6.5, 6.4.6.6,

6.4.6.7, 6.6

Nonradiological waste 6.1, 6.5, 6.5.1,

6.5.2, 6.5.3, 6.6

Transportation 6.1, 6.3.1,

6.3.2.3, 6.3.3, 1

6.3.4, 6.6,

Addendum 1

6.1 References

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions."

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

Renewal of Operating Licenses for Nuclear Power Plants."

AmerGen (AmerGen Energy Company, LLC). 2008. "Three Mile Island Nuclear Station,

Applicant's Environmental Report, License Renewal Operating Stage." Kennett Square,

Pennsylvania. ADAMS Nos. ML080220255, ML080220257, ML080220261, and ML080220282.

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

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

No. ML061770605.

NUREG-1437, Supplement 37 6-2 June 2009
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

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

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

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

Report." NUREG-1437, Vol. 1, Addendum 1. Washington, D.C.

June 2009 6-3 NUREG-1437, Supplement 37

7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING

Decommissioning is defined as the safe removal of a nuclear facility from service and the

reduction of residual radioactivity to a level that permits release of the property for unrestricted

use and termination of the license. The U.S. Nuclear Regulatory Commission (NRC) issued a

generic environmental impact statement (GELS) for decommissioning (NRC 2002) that

evaluated the environmental impacts from the activities associated with the decommissioning of

any reactor before or at the end of an initial or renewed license.

The NRC staff has not identified any new and significant information during the review of the

Exelon Generation Company, LLC environmental report (AmerGen 2008), the site audit, or the

scoping process. Therefore, there are no impacts related to these issues beyond those

discussed in the GElS (NRC 1996, 1999). For the issues listed in table 7-1 below, the GElS

concluded that the impacts are SMALL.

Table 7-1. Issues Related Decommissioning. Decommissioning would occur

regardless of whether or not Three Mile Island Nuclear Station, Unit 1, is

shut down at the end of its currect operating license or at the end of the

period of extended operation. There are no site-specific issues related to

decommissioning.

Issues GElS Section Category

Radiation doses 7.3.1; 7.4 1

Waste management 7.3.2; 7.4 1

Air quality 7.3.3; 7.4 1

Water quality 7.3.4; 7.4 1

Ecological resources 7.3.5; 7.4 1

Socioeconomic impacts 7.3.7; 7.4 1

7.1 References

AmerGen (AmerGen Energy Company, LLC). 2008. Three Mile Island Nuclear Station,

Applicant's Environmental Report, License Renewal Operating Stage. Kennett Square,

Pennsylvania. ADAMS Accession Nos. ML080220255, ML080220257, ML080220261, and

ML080220282.

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

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

ADAMS No. ML061770605.

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

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

June 2009 7-1 NUREG-1437, Supplement 37
Environmental Impacts of Decommissioning

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

Report." NUREG-1437, Vol. 1, Addendum 1. Washington, D.C.

NRC (U.S. Nuclear Regulatory Commission). 2002. Generic Environmental Impact Statement

on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of

Nuclear Power Reactors. NUREG-0586, Supplement 1, Vol. 1 and 2. Washington, D.C.

NUREG-1437, Supplement 37 7-2 June 2009
8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES

The National Environmental Policy Act (NEPA) mandates that each environmental impact

statement (EIS) consider alternatives to any proposed major Federal action. NRC regulations

implementing NEPA for license renewal require that a supplemental EIS "consider and weigh

the environmental effects of the proposed action [license renewal]; the environmental impacts of

alternatives to the proposed action; and alternatives available for reducing or avoiding adverse

environmental impacts," (10 CFR 51.71 [dQ). In this case, the proposed Federal action is issuing

a renewed license for Three Mile Island Nuclear Station, Unit 1 (TMI-1), which will allow the

plant to operate for 20 years beyond its current license expiration date. In this chapter, we

examine the potential environmental impacts of alternatives to issuing a renewed operating

license for TMI-1.

While NUREG-1437 "Generic Environmental Impact Statement for License Renewal of Nuclear

Plants", (GELS; NRC 1996, 1999), reached generic conclusions regarding many environmental

issues associated with license renewal, it did not determine which alternatives are reasonable or

reach conclusions about site-specific environmental impact levels. As such, NRC staff must

evaluate environmental impacts of alternatives on a site-specific basis.

Alternatives to the proposed action of issuing a renewed TMI-1 operating license must meet the

purpose and need for issuing a renewed license; they must

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

a current nuclear power plant operating license to meet future system generating

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

authorized, Federal (other than NRC) decisionmakers."

The NRC staff ultimately makes no decision as to which alternative (or the proposed action) to

implement, since that decision falls to utility, State, or other Federal officials to decide.

Comparing the environmental effects of these alternatives will assist the NRC in deciding

whether the environmental impacts of license renewal are so great that preserving the option of

license renewal for energy-planning decisionmakers would be unreasonable (10 CFR

51.95[c](4]). If the NRC acts to issue a renewed license, all of the alternatives, including the

proposed action, will be available to energy-planning decisionmakers. If the NRC decides not to

renew the license (or takes no action at all), then energy-planning decisionmakers may no

longer elect to continue operating TMI-1 and will have to resort to another alternative-which

may or may not be one of the alternatives the NRC considers in this section-to meet their

energy needs.

In evaluating alternatives to license renewal, we first select energy technologies or options

currently in commercial operation, as well as some technologies not currently in commercial

operation but likely to be commercially available by the time the current TMI-1 operating license

expires.

Second, we screen the alternatives to remove those that cannot meet future system needs.

Then, we screen the remaining options to remove those whose costs or benefits don't justify

inclusion in the range of reasonable alternatives. Any alternatives remaining constitute

June 2009 8-1 NUREG-1437, Supplement 37
Alternatives

alternatives to the proposed action that the NRC evaluates in-depth throughout this section. At

the end of the section, we will briefly address each alternative that we removed during

screening.

The NRC staff initially considered 17 discrete potential In-Depth Alternatives

alternatives to the proposed action, and narrowed the list 0 C

to the four discrete alternatives and one combination Supercritical

alternative, which are considered in Sections 8.1 through 0

8.5. Combined-cycle

Once we identify the in-depth alternatives, the staff refer to Conservaion / Energy

generic environmental impact evaluations in the GELS. ency '

The GElS provides overviews of some energy Combination

technologies available at the time of its publishing in 1996, Alternative

though it does not reach any conclusions regarding which Purchased Power

alternatives are most appropriate, nor does it precisely

categorize impacts for each site. Since 1996, many energy Other Alternatives

technologies have evolved significantly in capability and Considered

cost, while regulatory structures have changed to either Coal-firedIGCC

promote or impede development of particular alternatives. * Wind Power

Where applicable, our analyses draw on the GElS and e Solar Power

include updated information from sources like the Energy (photovoltaic and

Information Administration (EIA), other organizations c.

within the Department of Energy (DOE), the U.S. 0 Wood Waste

Environmental Protection Agency (EPA), industry sources 0 Conventional

and publications, and information submitted by the Hydroelectri Power

applicant (Exelon Generation Company, LLC [Exelon 0 Wave and Ocean

Generation]) in the Environmental Report (ER). Energy

Geothermal~ Power•' For each in-depth analysis, we analyze environmental Mic l

impacts across seven impact categories: (1) air quality, (2) Biofun ls W

ground water use and quality, (3) surface water use and Olfr Powe

quality, (4) ecology, (5) human health, (6) socioeconomics, F Cele r

and (7) waste management. As in earlier chapters of this Cells Rten

supplemental EIS, we use the NRC's three-level standard

of significance-SMALL, MODERATE, or LARGE-to

indicate the intensity of environmental effects for each alternative that we evaluate in-depth. By

placing the detailed alternative analyses in this order, the NRC staff do not mean to imply which

alternative would have the least impact, or which alternative an energy-planning decisionmaker

would be most likely to implement.

Sections 8.1-8.5 contain our analyses of environmental impacts of alternatives to license

renewal. Alternatives include a supercritical coal-fired plant (Section 8.1), a combined-cycle

natural gas-fired power plant (Section 8.2), a conservation alternative (Section 8.3), and a

combination of alternatives (Section 8.4), which includes some natural gas-fired capacity,

uprates at hydropower dams in Pennsylvania, and about one-half of the conservation capacity

utilized in Section 8.3. The NRC also considers a purchased-power alternative in Section 8.5. A

NUREG-1437, Supplement 37 8-2 June 2009
Alternatives

Energy Outlook Each y discussion of alternatives considered but

Info nAdmiri A prt odismissed is included in Section 8.6. Finally, in nfrtD ), issutes. Section 8.7, the NRC considers the

itS. Department of ErgJ .environmental i( ~ effects that could occur if NRC

its 2008ted dis hatl, coaly anduatlook (A . takes no action and does not issue a renewed

license for TMVI-1.

'gas. are likely to fuel~rnost new electnical liesfoTMI.

capaciythrough 2030, with significant

contributions from newrenewable sources, 8.1 Supercritical Coal-Fired Generation

and omegroth n nucear capacity (EIA~

2008a),though all projIn this section, we evaluate the environmental

fec developments in fuelpimpacts of supercritical coal-fired generation at

an offsite location. Given that the available

space at the TMI-1 site is smaller than the

Naturaigas-fire ntsb hgenerally have ts amount of space we predict a new coal-fired

lower caacfitycosts but higherfuel costs alternative would require, we will not consider a coal-fired alternative at the TMI-1 site. A fie lns con o 40 percent of

summary of the environmental impacts from the

2?030, compared wh acoal-fired alternative compared to continued

fornauralgs.Renwableanuclear operation of TM I-1 is contained in Table 8-1 on

page 8-5.

plants ten pageehihinetmn

s ad Coal-fired generation accounts for a greater

0 ashare of U.S. electrical power generation than

areexpected toany other fuel (EIA 2007). Furthermore, the EIA

from r~enewable andnuclear plants,~ projects that coal-fired power plants will account

wihre and 6 for the greatest share of capacity additions

percent of total addition, respectivel . through 2030-more than natural gas, nuclear,

e q t aor renewable generation options. While coaladditions can also be affected by ~ fired power plants are widely used and likely to

different fuel price pathsvor growth rates ~ remain widely used, we acknowledge that future

forelectricity demand~. coal capacity additions may be affected by

perceived or actual efforts to limit greenhouse

gas emissions. For now, we consider a coalfired alternative to be a feasible, commercially-available option for providing electrical

generating capacity beyond TMI-1's current license expiration.

Supercritical technologies are increasingly common in new coal-fired plants. Supercritical plants

operate at higher temperatures and pressures than most existing coal-fired plants (beyond

water's "critical point," where boiling no longer occurs and no clear phase change occurs

between steam and liquid water). Operating at higher temperatures and pressures allows this

coal-fired alternative to operate at a higher thermal efficiency than many existing coal-fired

power plants. While supercritical facilities are more expensive to construct, they consume less

fuel for a given output, reducing environmental impacts. Based on technology forecasts from

EIA, we expect that a new, supercritical coal-fired plant beginning operation in 2014 would

operate at a heat rate of 9,069 British thermal units per kilowatt-hour (Btu/kWh), or

approximately 38 percent thermal efficiency (EIA 2008b).

June 2009 8-3 NUREG-1437, Supplement 37
Alternatives

In a supercritical coal-fired power plant, burning coal heats pressurized water. As the

supercritical steam/water mixture moves through plant pipes to a turbine generator, the

pressure drops and the mixture flashes to steam. The heated steam expands across the turbine

stages, which then spin and turn the generator to produce electricity. After passing through the

turbine, any remaining steam is condensed back to water in the plant's condenser.

In most modern U.S. facilities, condenser cooling water circulates through cooling towers or a

cooling pond system (either of which are closed-cycle cooling systems). Older plants often

withdraw cooling water directly from existing rivers or lakes and discharge heated water directly

to the same body of water (called open-cycle cooling). For this analysis, the NRC assumed that

a new supercritical coal-fired power plant would rely on closed-cycle cooling with cooling towers.

The plant likely would withdraw makeup water from nearby surface water sources and

discharge blowdown (water containing concentrated dissolved solids and biocides) back to that

same surface water. Cooling towers could be either natural draft (similar to the existing towers

at TMI-1: tall towers powered only by the difference in density between heated, humid air, and

surrounding cooler and usually drier air) or mechanical draft (shorter towers powered by

mechanical fans).

In order to replace the 802 megawatt-electric (MWe) that TMI-1 currently supplies, the coal-fired

alternative would need to produce roughly 850 megawatts (MW), using about 6 percent of

power output for onsite power usage (AmerGen 2008). Onsite electricity usage powers

scrubbers, cooling towers, coal-handling equipment, and other onsite electrical needs. A

supercritical coal-fired power plant equivalent in capacity to TMI-1 would require slightly less

cooling water than TMI-1 because the plant operates at a higher thermal efficiency.

Aside from cooling towers, other onsite structures would include the turbine building, boiler

building, plant exhaust stack, coal pile, electrical switchyard, and a rail spur or coal dock. The

GElS (NRC 1996) estimated that a coal-fired alternative would require roughly 1.7 acres (ac) (1

hectare [ha]) per MWe capacity, or roughly 1,450 ac (587 ha). Exelon Generation indicated in

their ER that the plant would require 129 ac (52 ha), a number more consistent with minimum

utility needs as demonstrated by nearby power plants (including PPL Corporation's Brunner

Island facility). We will adopt Exelon Generation's estimate for this analysis. Additional offsite

land could be required for waste disposal, though much of the plant's ash and scrubber sludge

could be reused in concrete and gypsum wallboard, respectively (ACAA 2007).

This 850 MWe power plant would consume 2.51 million tons (t) (2.28 million metric tons [MT]) of

coal annually assuming an average heat content of 11,459 Btu/Ib (EIA 2006). The EIA reported

that most coal consumed in Pennsylvania originates in Pennsylvania. Coal would be mined

either in underground mines or in surface mines, then mechanically processed and washed,

before being transported-likely by rail- to the power plant site. Limestone for scrubbers would

also arrive by rail. This coal-fired alternative would produce 404,000 t (366,000 MT) of ash and

263,000 t (238,000 MT) of scrubber sludge. Much of the coal ash and scrubber sludge could be

reused, as noted above.

Environmental impacts from the coal-fired alternative will be greatest during construction. Site

crews will clear the plant site of vegetation, prepare the site surface, and begin excavation

before other crews begin actual construction on the plant and any associated infrastructure,

including a rail spur to serve the plant and electricity transmission infrastructure connecting the

NUREG-1437, Supplement 37 8-4 June 2009
Alternatives

plant to existing transmission lines. Given available space onsite, the coal-fired alternative must

be located elsewhere. Impacts resulting from a coal-fired unit offsite will vary depending on the

nature of the site selected (e.g., a site that has never been developed will likely experience

greater impacts than a site that was previously industrial; a site near other power plants or

industrial facilities will likely experience smaller impacts than a site surrounded by farmland or

relatively natural surroundings).

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

Generation Compared to Continued Operation of TMI-1.

Supercritical Coal-Fired Generation Continued TMI-1

At TMI-1 site At alternate site Operation

Air Quality N/A MODERATE SMALL

Ground Water N/A SMALL SMALL

Surface Water N/A SMALL SMALL

Aquatic and Terrestrial N/A SMALL to LARGE SMALL

Resources

SMALL to

Human Health N/A MODERATE MODERtE SMALL

Socioeconomics N/A SMALL to LARGE SMALL

Waste Management N/A SMALL to N WasteManagement ________/AMODERATE N/A

8.1.1 Air Quality

Air quality impacts from coal-fired generation can be substantial because emissions contain

significant quantities of sulfur oxides (SOx), nitrogen oxides (NOx), particulates, carbon

monoxide (CO), and hazardous air pollutants such as mercury. However, many of these

pollutants can be effectively controlled by various technologies.

TMI-1 is located within the Mid-Atlantic Air Quality Control Region, as designated by the EPA.

The State is divided into six air regions and Dauphin County, where TMI-1 is located, belongs to

the Southcentral Air Quality Region. Dauphin County is a nonattainment area for fine particulate

matter (PM2.5) and is part of the Harrisburg-Lebanon-Carlisle PM2.5 nonattainment area (which

includes Cumberland, Dauphin and Lebanon counties). A new coal-fired generating plant

developed at the TMI-1 site would need to comply with the new source performance standards

for coal-fired plants set forth in 40 CFR 60 Subpart D(a), "Standards of Performance for Electric

Utility Steam Generating Units for Which Construction is Commenced After September 18,

1978." The standards establish limits for particulate matter and opacity (40 CFR 60.42D(a)),

sulfur dioxide (SO2) (40 CFR 60.43D(a)), and NOx (40 CFR 60.44D(a)). A coal-fired power plant

constructed elsewhere in Pennsylvania would also need to comply with applicable provisions of

the Clean Air Act (CAA) (42 U.S.C. 7401), based on the attainment status of the selected

alternate site.

Section 169A of the CAA establishes a national goal of preventing future and remedying

existing impairment of visibility in mandatory Class I Federal areas when impairment results

from man-made air pollution. In 1999, EPA issued a new regional haze rule (64 FR 35714). The

rule specifies that for each mandatory Class I Federal area located within a state, the state must

June 2009 8-5 NUREG-1 437, Supplement 37
Alternatives

establish goals that provide for reasonable progress towards achieving natural visibility

conditions. The reasonable progress goals must provide an improvement in visibility for the

most-impaired days over the period of the implementation plan and ensure no degradation in

visibility for the least-impaired days over the same period (40 CFR 51.308(d)(1)). If a coal-fired

plant were located close to a mandatory Class I area, additional air pollution control

requirements would be imposed. There are no Mandatory Class I Federal areas in

Pennsylvania, the closest is Brigantine Wilderness Area in New Jersey, roughly 125 miles eastsoutheast of TMI-1. At an alternate site, consideration may need to be given to the installation

of additional air emission control systems if that site were in proximity to any Class I areas.

Pennsylvania regulates air emissions from power plants pursuant to terms of the Pennsylvania

Air Pollution Control Act (APCA) (35 P.S. §§ 4001-4015). Regulations issued by the

Pennsylvania Department of Environmental Protection (PADEP) adopt the EPA's CAA rules

with modifications, to limit power plant emissions of SOx, NOx, particulate matter, and

hazardous air pollutants (PADEP 2008). Depending where a new coal-fired facility is located

within Pennsylvania, the facility will need to comply with the applicable Federal and State air

regulations.

A supercritical coal-fired alternative would produce the following quantities of air pollutants:

Sulfur Oxides

A coal-fired alternative at the TMI-1 site would likely use wet, limestone-based scrubbers to

remove SOx. EPA indicates that this technology can remove more than 95 percent of SOx from

flue gases (EPA 2002). NRC projects total SOx emissions would be 4,991 t (4,528.20MT) per

year. SOx emissions from a new coal-fired power plant would be subject to the requirements in

Title IV of the CAA. Title IV was enacted to reduce emissions of SO2 and NOx, the two principal

precursors of acid rain, by restricting emissions of these pollutants from power plants. Title IV

caps aggregate annual power plant SO2 emissions and imposes controls on SO2 emissions

through a system of marketable allowances. EPA issues one allowance for each ton of SO2 that

a unit is allowed to emit. New units do not receive allowances, but are required to have

allowances to cover their SO2 emissions. Owners of new units must therefore purchase

allowances from owners of other power plants or reduce SO2 emissions at other power plants

they own. Allowances can be banked for use in future years. Thus, provided a new coal-fired

power plant is able to purchase sufficient allowances to operate, it would not add to net regional

SO2 emissions, although it might do so locally.

Nitroqen Oxides

A coal-fired alternative at the TMI-1 site would most likely employ various available NOx-control

technologies including low-NOx burners, over-fire air, and selective catalytic reduction. The EPA

notes that when these emissions controls are used in concert, they can reduce NOx emissions

by up to 95 percent (EPA 1998a). Assuming the use of such technologies, NOx emissions after

scrubbing are estimated to be 628 t (570 MT) annually.

Section 407 of the CAA establishes technology-based emission limitations for NOx emissions. A

new coal-fired power plant would be subject to the new source performance standards for such

plants as indicated in 40 CFR 60.44a(d)(1). This regulation, issued on Sept 16, 1998 (63 FR

49442), limits gas discharges to 200 nanograms (ng) of NOx per joule (J) of gross energy output

NUREG-1437, Supplement 37 8-6 June 2009
Alternatives

(equivalent to 1.6 lb/MWh), based on a 30-day rolling average. The NRC estimates that the total

annual NOx emissions for a new coal-fired power plant with the modem emission controls

identified in the previous paragraph would be approximately 12.4 percent of the new source

performance standard mission rate. The EPA further controls the total amount of NOx that can

be emitted on a State-level basis. Annual budget for NOx covered by allowances for 2009-2014

is 99,049 t (89,856 MT) (EPA 2005). A new coal-fired power plant would need to offset

emissions through credit purchases or from a set-aside pool. It should be noted that NOx

emissions would have been subject to ozone-controlling elements of the Clean Air Interstate

Rule (CAIR) had CAIR not been vacated by the D.C. Circuit Court in July of 2008. On

September 24, 2008, EPA filed for a rehearing of the D.C. Circuit Court decisions. Until EPA,

Congress, or the courts act, future NOx regulatory approaches remain uncertain.

Particulates

A new coal-fired power plant would use fabric filters or electrostatic precipitators to remove

particulates from flue gases. Exelon Generation indicates that fabric filters would remove 99.9

percent of particulate matter (AmerGen 2008). The EPA notes that filters or precipitators are

each capable of removing in excess of 99 percent of particulate matter, and that SO2 scrubbers

further reduce particulate matter emissions (EPA 2002). As such, NRC staff believes Exelon

Generation's removal factor is appropriate. Based on this, the new supercritical coal-fired plant

would emit 161.27 t (146.3 MT) of total suspended particulates and approximately 37.09 t

(33.65 MT) of PM10 annually. In addition, coal burning would also result in PM2.5 emissions, and

coal-handling equipment would introduce fugitive dust emissions when fuel is being transferred

to on-site storage and then reclaimed from storage for use in the plant. During the construction

of a coal-fired plant, on-site activities would also generate fugitive dust. Vehicles and motorized

equipment would create exhaust emissions during the construction process. These impacts

would be intermittent and short-lived, however, and to minimize dust generation construction

crews would use applicable dust-control measures.

Carbon Monoxide

Based on EPA emission factors (EPA 1998), NRC staff estimates that the total CO emissions

would be approximately 628 t (570 MT) per year.

Hazardous Air Pollutants

Following the D.C. Circuit Court's February 8, 2008, ruling that vacated its Clean Air Mercury

Rule (CAMR), EPA is working to evaluate how it will regulate mercury emissions (EPA 2007).

Before CAMR, EPA determined that coal- and oil-fired electric utility steam-generating units are

significant emitters of hazardous air pollutants (HAPs) (EPA 2000a). EPA determined that coal

plants emit arsenic, beryllium, cadmium, chromium, dioxins, hydrogen chloride, hydrogen

fluoride, lead, manganese, and mercury (EPA 2000a). EPA concluded that mercury is the HAP

of greatest concern and that (1) a link exists between coal combustion and mercury emissions,

(2) electric utility steam-generating units are the largest domestic source of mercury emissions,

and (3) certain segments of the U.S. population (e.g., the developing fetus and subsistence fisheating populations) are believed to be at potential risk of adverse health effects resulting from

mercury exposures caused by the consumption of contaminated fish (EPA 2000a). In light of

the recent court decision, EPA will revisit mercury regulation, although it is possible that the

agency will continue to regulate mercury as a HAP, thus requiring the use of best available

control technology to prevent its release to the environment.

June 2009 8-7 NUREG-1437, Supplement 37
Alternatives

Carbon Dioxide

A coal-fired plant would also have unregulated carbon dioxide (CO 2) emissions during

operations as well as during mining, processing, and transportation. Burning bituminous coal in

the United States emits roughly 205.3 lb of CO2 per million Btu (Hong and Slatick 1994). The

supercritical coal-fired plant would emit approximately 5.914 million t (5.365 million MT) of C02

per year.

Summary of Air Quality

While the GElS analysis mentions global warming from unregulated CO 2 emissions and acid

rain from SOx and NOx emissions as potential impacts, it does not quantify emissions from

coal-fired power plants. However, the GElS analysis does imply that air impacts would be

substantial (NRC 1996). The above analysis shows that emissions of air pollutants, including

SOx, NOx, CO, and particulates, exceed those produced by the existing nuclear power plant, as

well as those of the other alternatives considered in this section. Operational emissions of C02

are also much greater under the coal-fired alternative.6 Adverse human health effects such as

cancer and emphysema have also been associated with air emissions from coal combustion,

and are discussed further in Section 8.1.5.

The NRC analysis for a coal-fired alternative at an alternative site indicates that impacts from

the coal-fired alternative would have clearly noticeable effects, but given existing regulatory

regimes, permit requirements, and emissions controls, the coal-fired alternative would not

destabilize air quality. Thus, the appropriate characterization of air impacts from coal-fired

generation would be MODERATE. Existing air quality at the alternate location would result in

varying needs for pollution control equipment to meet applicable local requirements, or varying

degrees of participation in emissions trading schemes.

8.1.2 Ground Water Use and Quality

An off-site location for a coal-fired plant was assumed because Three Mile Island is too small to

accommodate the area needed for this alternative. If the alternative site is adjacent to the

Susquehanna River and operates 10 percent more efficiently than the current nuclear plant,

most of the approximately 13,000 gallon per minute (gpm) for maximum cooling water

withdrawal would be taken from the river, with an average consumptive loss of about 16 million

gallons per day (mgd). The need for ground water at the plant would be minor, with supply wells

used for potable drinking water and various service water functions. No effect on ground water

quality would be apparent.

Construction of a coal-fired plant at a new site could have a localized effect on ground water

due to temporary dewatering and run-off control measures. Because of its temporary nature,

the impact Of construction would be SMALL.

6 Table S-3 in 10 CFR 51.51 indicates that electrical energy consumed during the uranium fuel cycle to supply

a 1,000 MW(e) reactor is equivalent to the electricity produced by a 45 MW(e) coal-fired power plant.

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8A1.3 Surface Water Use and Quality

Again, an offsite location for a coal-fired plant was assumed because Three Mile Island is too

small to accommodate the area needed for this alternative. If the alternative site is adjacent to

the Susquehanna River, most of the approximately 13,000 gpm needed for maximum

withdrawal would be taken from the river with an average consumptive loss of about 16 mgd.

This consumptive loss is less than 0.1 percentof the average annual flow of the Susquehanna

River, and as such the NRC concludes the impact of surface water use at an alternative site

would be SMALL. A new coal-fired plant would be required to obtain a National Pollutant

Discharge and Elimination System (NPDES) permit from the PADEP for regulation of industrial

waste water, storm water, and other discharges. If the plant is operated within the limits of the

permit, the impact of discharges on surface water quality would be SMALL.

8.1.4 Terrestrial and Aquatic Ecology

Terrestrial Ecology

As indicated in previous sections, constructing the coal-fired alternative will require 129 ac (52

ha) of land. Coal-mining operation will also affect terrestrial ecology in offsite coal mining areas,

although some of the land is likely already disturbed by mining operations. On-site and-offsite

land disturbarnces form the basis for impacts to terrestrial ecology.

Impacts to terrestrial ecology will vary based on the degree to which the proposed plant site is

already disturbed. On a previous industrial site, impacts to terrestrial ecology would be minor,.

unless substantial transmission line right-of-ways (ROWs), railways, or roads would need to be

constructed through less disturbed areas. These construction activities may have a cumulative

effect of fragmenting or destroying habitats. Any on-site or offsite water disposal by landfilling

will also affect terrestrial ecology at least through the time period when the disposal area is

reclaimed. Some areas onsite, such as buffer areas, may remain undeveloped and could serve

as habitat for terrestrial species, though site lighting, noise, and activities may degrade the value

of these ecosystems. Deposition of acid rain or other emissions can also affect terrestrial

ecology. Given the emission controls discussed in Section 8.1.1, air deposition impacts may be

noticeable, but are not likely to be devastating. Impacts to terrestrial resources from a coal-fired

alternative would be SMALL, and occur mostly during construction.

Aquatic Ecology

A new coal-burning power plant constructed at an alternate site would need a source of water

for the plant's cooling system (likely closed-cycled with cooling towers) as well as a discharge

point for plant cooling tower blowdown. Aquatic impacts at an alternate site depend on location

and ecology of the site, and the surface water body used for intake and discharge. These

impacts are likely SMALL at a previously industrial site, owing to generally closer access to

pipelines and transmission lines than at undeveloped sites. Impacts could range from SMALL to

LARGE at previously undisturbed sites. Decreases in withdrawal from and discharge to the

Susquehanna River may partially offset some aquatic impacts at an alternate site. Impacts will

depend upon location and ecology of the site, and the surface water body used for intake and

discharge.

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8.1.5 Human Health

Human health risks of coal-fired power plants are described in general, in the GElS Table 8-2

and Section 8.3.9. Cancer and emphysema are identified as potential health risks to

occupational workers and members of the public (NRC 1996). The human health risks of coalfired power plants, both to occupational workers and to members of the public, are greater than

those of the current TMI-1 due to exposures to chemicals such as mercury; SOx; NOx;

radioactive elements such as uranium and thorium; and polycyclic aromatic hydrocarbon (PAH)

compounds, including benzo(a)pyrene. However, the current Federal and State regulatory

frameworks pertaining to air emission standards allow for the adequate protection of

occupational workers and members of the public. Therefore, the NRC staff has adopted (where

applicable) the Federal and State air quality regulatory limits as significance thresholds for

determining the human health risks associated with the operation of a new coal-fired power

plant.

Radiological Human Health Risks

Coal contains uranium, thorium, and other naturally occurring radioactive elements. The U.S.

Geological Survey (USGS) indicates that Western and Illinois Basin coals contain uranium and

thorium at roughly equal concentrations, mostly between 1 and 4 parts per million (ppm), but

also indicates that some coals may contain concentrations as high as 20 ppm of both elements

(USGS 1997). A typical 1,000 MWe coal-fired plant could release roughly 5.2 t (4.7 MT) of

uranium and 12.8 t (11.6 MT) of thorium to the atmosphere (Gabbard 1993). The USGS and

Gabbard indicate that almost all of the uranium, thorium, and most decay products remain in

solid coal wastes, especially in the fine glass spheres that constitute much of coal's fly ash.

Modern emission controls, such as those included for this coal-fired alternative, allow for

recovery of greater than 99 percent of these solid wastes (EPA 1998), thus retaining most of

coal's radioactive elements in solid form rather than releasing them to the atmosphere. Even

after concentration in coal waste, the level of radioactive elements remains relatively lowtypically 10 to 100 ppm-and consistent with levels found in naturally occurring granitic rocks,

shale, and phosphate rocks (USGS 1997). Natural radioactive material in rocks and soil account

for about 29 millirem (mrem) or 8 percent of the radiation dose a person typically receives in a

year from all sources (natural and manmade). Currently, there is no scientific evidence that

radiation dose exposures of 29 mrem above the natural background dose would cause adverse

human health impacts. The Biological Effect of Ionizing Radiation (BEIR) committee has

calculated the lifetime attributable risk (LAR) of incidence and mortality for all solid cancers and

for leukemia to be four to five persons per 100,000 persons exposed to 100 milliseiverts (mSv)

(10 rem), which is over 20 times that of the natural background radiation dose of 360 mrem

(NAS 2005). Therefore, the radiological human health risks from a 1,000 MWe coal-fired plant to

occupational workers and members of the public would be SMALL.

PAH Human Health Risks

The EPA has classified seven PAHs-benzo(a)pyrene, benz(a)anthracene, chrysene,

benzo(b)fluoranthene, benzo(k)fluoranthene, dibenz(a,h)anthracene, and indeno(1,2,3-

cd)pyrene-as probable human carcinogens (EPA 199a, EPA 199b, EPA 1999c). PAHs have

been detected in ambient air from sources including coal tar production plants, coking plants,

and coal-gasification sites. Epidemiologic studies have reported an increase in lung cancer risks

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in humans exposed to emission from coal tar production plants, coking plants, and coalgasification sites. Each of these emissions mixtures contains a number of PAH compounds

(ATSDR 1995, HHS 1993). The Occupational Safety and Health Administration (OSHA) has set

a limit of 0.2 mg of PAHs per cubic meter (M3 ) of air. Given that the plant must comply with

OSHA regulatory limits, the health risks to occupational workers and members of the public from

benzo[a]pyrene emission is expected be MODERATE.

Mercury Human Health Risks

As noted in Section 8.1.1, the EPA determined that coal-fired electric utility steam generating

power plants were significant emitters of hazardous air pollutants and concluded that mercury is

the hazardous air pollutant of greatest concern due to its persistence in the environment,

potential to bioaccumulate, and toxicity to humans and the environment (65 FR 32214). Noncancer risks of oral exposure to methyl-mercury have been observed to produce significant

developmental effects in humans. Infants born to women who ingested high concentrations of

methyl mercury exhibited central nervous system effects, such as mental retardation, ataxia,

deafness, constriction of the visual field, blindness, and cerebral palsy. At lower methyl-mercury

concentrations, developmental delays and abnormal reflexes were noted (ATSDR 1999, EPA

1997). No studies are available on the carcinogenic effects or cancer risks of methyl-mercury in

humans, and only one available animal study reported renal tumors in mice; nevertheless, the

EPA has classified methyl-mercury as a possible human carcinogen (EPA 1999d). The methylmercury dose resulting from emissions from a typical coal-fired power plant are uncertain. As

noted in Section 8.1.1, EPA's CAMR regulation was vacated this year, and the near-term

regulatory structure for mercury emission is uncertain. It is possible that EPA will return to

regulating mercury as a HAP. The NRC staff expects that the EPA will implement new mercury

regulations prior to the operational date of a coal-fired alternative. Because any new coal-fired

plant will have to comply with EPA regulatory limits, the health risks to occupational workers and

members of the public from mercury emissions is expected be MODERATE.

NOx and SO? Human Health Risks

NOx causes a wide variety of health risks and environmental impacts because of various

compounds and derivatives in the family, including nitrogen dioxide, nitric acid, nitrous oxide,

nitrates, and nitric oxide. NOx reacts with ammonia, moisture, and other compounds to form

nitric acid and related particles. Human health risks include impacts to the respiratory system,

damage to lung tissue, and premature death. Small particles penetrate deeply into sensitive

parts of the lungs, and can cause or worsen respiratory diseases such as emphysema and

bronchitis, and can aggravate existing heart disease (EPA 2008a). Environmental impacts

include increased acidic deposition, and contributions to acid rain.

The combustion of fossil fuels (particularly coal) accounts for 50 percent of annual global SO2

emissions. Human health risks of SO2 include aggravation of asthma and chronic bronchitis,

emphysema, impairment of pulmonary functions, respiratory irritation, and increased mortality.

Environmental concentrations of 50-100 micrograms per cubic meter (pg/M3) affect some plants

species. SO2 also contributes to the formation of acid rain in a similar manner as NOx (EPA

2008c).

As indicated in the Air Quality section, NOx and SO2 emissions from coal-fired power plants are

subject to the requirements in Title IV of the CAA. Because CAA regulations are based on

human health or environmental criteria for setting permissible levels, it sets limits both to protect

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public health (including the health of "sensitive" populations such as asthmatics, children and

the elderly) and to protect public welfare (including protection against decreased visibility, and

damage to animals, crops, vegetation, and buildings). Given that the plant must comply with

CAA regulatory limits, the environmental impact and health risks to occupational workers and

members of the public from NOx and SO2 is expected be MODERATE.

Summary

Regulatory agencies, including the EPA and State agencies, set air emission standards and

requirements based on human health risks. These agencies also impose site-specific emission

limits as needed to protect human health. Human health risks to occupational workers and to

members of the public from a coal-fired power plant are expected be SMALL to MODERATE.

Trading or offset mechanisms in nonattainment areas will act to prevent further degradation.

8.1.6 Socioeconomics

Land Use

The GElS generically evaluates the impacts of nuclear power plant operations on land use both

on and off each power plant site. The analysis of land use impacts focuses on the amount of

land area that would be affected by the construction and operation of a new supercritical coalfired power plant. Land-use impacts would vary depending on where the plant would be located

and whether construction would take place on undeveloped land or within a previously disturbed

(brownfield) area.

Exelon Generation indicated that approximately 129 ac (52 ha) would be necessary to support a

coal-fired alternative capable of replacing TMI-1. The GELS, however, estimates a need for up to

1,700 ac (688 ha) for a 1,000-MWe generating station (NRC 1996). This amount of land use

would include other plant structures and associated infrastructure. By scaling the GElS

estimate, a 853-MWe plant could require up to approximately 1,450 ac (587 ha) of land for the

plant site, transmission line ROWs, and a rail spur.

Based on land use for other power plants, the NRC staff believes the Exelon Generation

estimate to be reasonable, although additional land may be used for buffer around plant

structures or to support transmission lines and a rail spur. Even assuming additional land use

for these purposes, total land required by the coal-fired alternative is unlikely to exceed 1,450 ac

(587 ha) for all uses, excluding coal mining.

Many locations suitable for siting the coal-fired alternative (especially flat terrain areas along

rivers similar to power plants currently located in this part of the United States) may have been

disturbed by previous development. Brownfield sites, or sites that were previously used for

industrial purposes, may be the most likely location for a new supercritical coal-fired power

plant. Sites along rivers generally have easier access to transportation for coal fuel and major

plant components, both by barge and train. Sites that have previously been used for industrial

activities may also have existing rail spurs and dock or pier infrastructure and may be closer to

transmission lines.

Coal mining introduces offsite land use impacts in addition to direct land use impacts from the

construction and operation of new coal-fired power plants. Land disturbance would likely occur

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in Pennsylvania, Ohio, or West Virginia because a significant amount of coal used in

Pennsylvania power plants originates in these three States, although significant amounts of coal

also come from Kentucky and western States like Wyoming (EIA 2006).

According to analyses conducted for the GELS, approximately 22,000 ac (8,903 ha) of land

could be affected by coal mining and waste disposal in support of a 1,000-MWe.coal plant

during its operational life (NRC 1996). By scaling the GElS estimate, an 853-MWe plant could

require up to 18,800 ac (7,600 ha) of land to support a coal-fired power plant capable of

replacing TMI-1; however, most of this land is located in existing coal-mining areas and has

already been disturbed. The elimination of uranium fuel for TMI-1 could partially offset off site

land use. In the GELS, the NRC staff estimated that approximately 1,000 ac (405 ha) would not

be needed for mining and processing uranium during the operating life of a 1,000-MWe nuclear

power plant. For TMI-1, roughly 850 ac (344 ha) of uranium mining area would no longer be

needed. However, an additional 159 ac (64 ha) of land would be needed for waste disposal

during the 40 year plant life.8 This is a smaller amount of land area than was estimated by

Exelon Generation in the ER (AmerGen 2008), because of higher ash and gypsum recycling

rates.

Land use impacts could range from MODERATE to LARGE, depending on where the power

plant is located. The ambunt of land required under the coal-fired alternative could be reduced

by constructing new transmission lines in existing ROWs.

Socioeconomics

Socioeconomic impacts are defined in terms of changes to the demographic and economic

characteristics and social conditions of a region. For example, the number of jobs created by the

construction and operation of a new coal-fired power could affect regional employment, income,

and expenditures. Job creation is characterized by two types: (1) construction-related jobs,

which are transient, short in duration, and less likely to have a long-term socioeconomic impact;

and (2) operation-related jobs in support of power plant operations, which have the greater

potential for permanent, long-term socioeconomic impacts. Workforce requirements of power

plant construction and operation for the coal-fired alternative were determined in order to

measure their possible effect on current socioeconomic conditions.

Exelon Generation projected a maximum construction workforce of 1,328 (AmerGen 2008). The

GElS projects a workforce of 1,200 to 2,500 for a 1,000-MWe plant (when extrapolated, a

workforce of 1,000 to 2,100 for an 853-MWe plant). The NRC staff believes that the Exelon

Generation estimate is reasonable and is within the range provided by the GELS. Furthermore,

the upper-end estimate of the GElS is probably too large.

During the five-year construction period, the communities surrounding the plant site would

experience increased demand for rental housing and public services, although these effects

would be moderated if the construction site is located near an urban area with many skilled

Western coal tends to have lower sulfur and somewhat lower heating content than eastern coal. Many

power stations use western, subbituminous coal to reduce sulfur oxide emissions without having to install

scrubber equipment. A power plant equipped with scrubbers is more likely to use local, higher sulfur coals

rather than incurring the cost of shipping low-sulfur coal from western states.

Only half of the land area needed for waste disposal is directly attributable to the alternative of renewing the

TMI-1 operating license for 20 years.

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workers. The relative economic effect of these workers on local economy and tax base would

vary over time.

After construction, local communities may be temporarily affected by the loss of construction

jobs and associated loss in demand for business services, and the rental housing market could

experience increased vacancies and decreased prices. As noted in the GELS, the

socioeconomic impacts at a rural construction site could be larger than at an urban site,

because the workforce would have to move to be closer to the construction site. The impact of

construction on socioeconomic conditions could range from SMALL to LARGE depending on

whether the new power plant would be located at an urban or rural site. The socioeconomic

impacts of power plant construction could be reduced if the power plant is located near an urban

area with many skilled workers.

Exelon Generation estimated a power plant operations workforce of 92 (AmerGen 2008), while

extrapolated GElS estimates would call for up to 213 workers. The Exelon Generation estimate

appears reasonable and is consistent with trends toward lowering labor costs by reducing the

size of power plant operations workforces. Operations impacts will likely be SMALL to

MODERATE, depending on whether the power plant is located near an urban or rural area.

Transportation

During five years of construction, up to 2,100 workers would be commuting to the construction

site. This would increase the volume of traffic on roads leading to and coming from the

construction site. Effects would vary depending on the number of site access roads. In addition

to workers vehicles, trucks would deliver construction material and remove debris from the

worksite. The number of additional vehicles on local roads could increase the overall effect.

Trains or barges, or both, could be used to deliver large power plant components to the plant

site.

Transportation impacts would be greatly reduced after construction of the power plant. The

number of operations personnel commuting to and from the plant site would range from 92 to

213 workers. More significant, though, would be the frequent deliveries of coal and limestone to

the plant site, most likely by rail, which would result in traffic delays at railroad crossings.

Approximately 252 unit trains (trains with up to 100 cars carrying 100 t of coal per car for 10,000

t [9,070 MT] per train) per year would be necessary. Onsite coal storage would make it possible

to receive several trains per day. Limestone would also be delivered by rail, which could cause

additional traffic delays at railroad crossings (though considerably less rail traffic than that

generated by coal deliveries). If coal and limestone were delivered by barge, rail transportationrelated impacts to be would be reduced.

Overall, the coal-fired alternative would likely have SMALL to MODERATE transportation

impacts in the vicinity of the power plant site, although the extent of impacts would depend on

existing infrastructure capacity and demand, as well as whether coal and limestone would be

delivered by rail or barge.

Aesthetics

Aesthetic resources are the natural and man-made features that give a particular landscape its

character and aesthetic quality. The aesthetics impact analysis focuses on the degree of

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contrast between the power plant and the surrounding landscape and the visibility of the power

plant.

The coal-fired alternative's power plant could be up to 200 ft (61 m) tall and may be visible off

site in daylight hours. The exhaust stack could be up to 600 ft (183 m) high (at least 500 ft [152

m] for good engineering practice). Additional visual impacts would occur if a natural-draft cooling

tower is constructed. Similar to the cooling towers at TMI-1, the natural-draft cooling tower may

be several hundred feet high and sometimes topped with condensate plumes. Mechanical draft

towers would also generate condensate plumes but will be lower than the plumes from the

natural-draft tower. Other buildings onsite may also affect aesthetics, as could construction of

new transmission lines. Noise and light from plant operations, as well as lighting on plant

structures, may be detectable off site.

If the coal-fired alternative is located along a river valley terrain, impacts may be moderated by

higher elevation ridges along the valley rim, which could make it difficult to see and hear the

plant outside of the river valley. Aesthetic impacts could be further mitigated if the plant were

located in an industrial area adjacent to other industrial facilities and power plants. Overall, the

aesthetic impacts associated with the coal-fired alternative would likely be SMALL to

MODERATE, depending on the location of the site, topography, and proximity to other industrial

facilities, as opposed to areas where visual resources are particularly valued.

Historic and Archaeological Resources

It is difficult to determine the effects on historic and archaeological resources when a specific

location has not been selected. The potential for historic and archaeological resources can vary

greatly depending on the location of the proposed site. To consider a project's effects on historic

and archaeological resources, any proposed areas will need to be surveyed to identify and

record historic and archeological resources, identify cultural resources, and develop possible

mitigation measures to address any adverse effects from ground-disturbing activities. Studies

will be needed for all areas of potential disturbance at the proposed plant site and along

associated corridors where new construction will occur (e.g., roads, transmission corridors, rail

lines, or other ROWs). In most cases, project proponents should avoid areas with the greatest

sensitivity. Depending on the resource richness of the site ultimately chosen for the coal-fired

alternative, impacts will range from SMALL to MODERATE.

Environmental Justice

The environmental justice impact analysis evaluates the potential for disproportionately high and

adverse human health and environmental effects on minority and low-income populations that

could result from the construction and operation of a new supercritical coal-fired power plant.

Adverse health effects are measured in terms of the risk and rate of fatal or nonfatal adverse

impacts on human health. Disproportionately high and adverse human health effects occur

when the risk or rate of exposure to an environmental hazard for a minority or low-income

population is significant and exceeds the risk or exposure rate for the general population or for

another appropriate comparison group. The minority and low-income populations are subsets of

the general public residing around the site, and all are exposed to the same hazards generated

from various operations at the site.

Minority and low-income populations could be affected by the construction and operation of a

new supercritical coal-fired power plant. Some of these effects have been identified in resource

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areas discussed in this section. The extent of environmental justice effects is difficult to

determine since it would depend in part on the location of the coal-fired power plant and

whether a plant in a given location would contribute to impacts that are both adverse and

disproportionate for minority or low-income populations. For example, increased demand for

rental housing during construction could disproportionately affect low-income populations.

However, demand for rental housing could be mitigated if the alternate plant site is constructed

near a metropolitan area. Also, increased coal consumption may affect employment

opportunities and environmental conditions in low-income regions in Pennsylvania, Ohio, or

West Virginia.

Environmental justice impacts on minority and low-income populations from the construction

and operation of a coal-fired alternative could range from SMALL to MODERATE and would

depend on whether effects from the plant on minority and low-income populations are adverse

and disproportionate.

8.1.7 Waste Management

Coal combustion generates several waste streams including ash (a dry solid) and sludge (a

semi-solid by-product of emission control system operation). The NRC staff estimates that an

850-MWe power plant would generate 222,000 t (201,000 MT) of ash and approximately 55,200

t (50,000 MT) of scrubber waste per year, which would need to be disposed of onsite or in an

offsite landfill (ACAA 2007). Based on industry-wide average recycling rates, of this waste,

182,000 t (165,000 MT) of the ash and 208,000 t (188,000 MT) of scrubber sludge could be

recycled (ACAA 2007).

On-site disposal is likely to encompass approximately 159 ac (64 ha) over 40 years of

operation. In addition to coal combustion wastes, a supercritical coal-fired alternative would also

produce small amounts of domestic and hazardous wastes.

Waste impacts to ground water and surface water would extend beyond the operating life of the

plant if leaching and runoff from the waste storage area makes its way into ground water or

surface water. Disposal of the waste would noticeably affect land use and ground water quality if

not properly managed, but with appropriate management and monitoring, impacts to ground

water resources would be prevented. After closure of the landfill and revegetation, the disposal

area would be available for other uses. Impacts of the waste generated by a coal-fired

alternative are considered by the NRC to be SMALL to MODERATE.

8.2 Natural Gas Combined-Cycle Generation

In this section, we evaluate the environmental impacts of natural gas-fired combined-cycle

generation at the TMI-1 site and at an alternate site. On page 8-18, Table 8-2 contains a

summary of environmental impacts of natural gas combined-cycle generation in comparison to

continued operation of TMI-I.

Natural gas fueled 20 percent of electric generation in the United States in 2006 (the most

recent year for which data are available), accounting for the second greatest share of electrical

power after coal (EIA 2007). Like coal-fired power plants, natural-gas-fired plants may be.

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affected by perceived or actual action to limit greenhouse gas emissions, though they produce

markedly fewer greenhouse gases per unit of electrical output than coal-fired plants. Natural

gas-fired power plants are feasible, commercially available options for providing electrical

generating capacity beyond TMI-I's current license expiration.

Combined-cycle power plants differ significantly from coal-fired and existing nuclear power

plants. They derive the majority of their electrical output from a gas-turbine cycle, and then

generate additional power-without burning any additional fuel-through a second, steamturbine cycle. The first, gas turbine stage (similar to a large jet engine) bums natural gas which

turns a driveshaft that powers an electric generator. The exhaust gas from the gas turbine is still

hot enough, however, to boil water to steam. Ducts carry the hot exhaust to a heat recovery

steam generator, which produces steam to drive a steam turbine and produce additional

electrical power. The combined-cycle approach is significantly more efficient than any one cycle

on its own; efficiencies can exceed 60 percent. Since the natural-gas-fired alternative derives

much of its power from a gas turbine cycle, and because it wastes less heat than either the

coal-fired alternative or the existing TMI-1, it requires significantly less cooling water and smaller

cooling towers.

In order to replace the 802 MWe that TMI-1 currently supplies, the NRC selected a gas-fired

alternative that uses two General Electric S107H combined-cycle generating units. While any

number of commercially-available combined-cycle units could be installed in a variety of

combinations to replace the power currently produced by TMI-1, the S107H is a highly-efficient

model that will help to minimize environmental impacts. Other manufacturers, like Siemens,

offer similar high efficiency models. This gas-fired alternative produces a net 400 MWe per unit.

Two units produce a total of 800 MWe, or nearly the same output as TMI-I.

The combined-cycle alternative operates at a heat rate of 5,690 Btu/kWh, or nearly 60 percent

thermal efficiency (GE 2007). Allowing for onsite power usage, including cooling towers and site

lighting, the gross output of these units would be roughly 830 MWe. As noted above, this gasfired alternative would require much less cooling water than TMI-1, because it operates at a

higher thermal efficiency and requires much less water for steam cycle condenser cooling.

Cooling towers for this alternative would likely be mechanical draft-type towers approximately 65

ft (20 m) in height.

In addition to cooling towers, other visible structures onsite include the turbines and heat

recovery steam generators (which may be enclosed in a single building), two exhaust stacks, an

electrical switchyard, and, possibly, equipment associated with a natural gas pipeline, like a

compressor station. The GElS (NRC 1996) estimated that a 1,000 MWe gas-fired alternative

would require 110 ac (40 ha), meaning this 830-MWe plant would require 92 ac (37 ha). Exelon

Generation indicated that the plant would require 32 ac (13 ha), a number more consistent with

minimum utility needs as demonstrated by nearby power plants (including Dominion Resources'

Fairless Energy Works). We will adopt Exelon Generation's estimate for the purposes of the

following analysis.

This 830 MWe power plant would consume 34.2 billion cubic feet (ft3) (970 million M3) of natural

gas annually assuming an average heat content of 1,033 Btu/ft3 (EIA 2006). Natural gas would

be extracted from the ground through wells, then treated to remove impurities (like hydrogen

sulfide), and blended to meet pipeline gas standards, before being piped through the interstate

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pipeline system to the power plant site. This gas-fired alternative would produce relatively little

waste, primarily in the form of spent catalysts used for emissions controls.

Environmental impacts from the gas-fired alternative will be greatest during construction. Site

crews will clear vegetation from the site, prepare the site surface, and begin excavation before

other crews begin actual construction on the plant and any associated infrastructure, including a

pipeline spur to serve the plant and electricity transmission infrastructure connecting the plant to

existing transmission lines.

I Constructing the gas-fired alternative on Exelon Generation property located immediately south

of remaining TMI Unit 2 plant structures would allow the gas-fired alternative to make use of

TMI-I's existing transmission system, as well as take advantage of an already cleared and

graded section of Three Mile Island. During the environmental site audit, TMI-1 staff indicated

that some of this land is occasionally used for parking during outages and could be used during

TMI-1 and TMI Unit 2 decommissioning. Additional offsite land, land farther south on Three Mile

Island, or remaining land around the new gas-fired plant may be available for occasional use to

offset this land requirement.

A gas-fired unit constructed offsite may cause additional construction-related impacts depending

on the nature of the site selected (e.g., a site that has never been developed will likely

experience greater impacts than a site that was previously industrial; a site near other power

plants or industrial facilities will likely experience smaller impacts than a site surrounded by

farmland or relatively natural surroundings).

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

Generation Compared to Continued Operation of TMI-1.

Natural Gas Combined-Cycle Continued TMI-1

At TMI-1 site At alternate site Operation

Air Quality MODERATE MODERATE SMALL

Ground Water SMALL SMALL SMALL

Surface Water SMALL SMALL SMALL

Aquatic and Terrestrial SMALL SMALL TO LARGE SMALL

Resources

Human Health SMALL SMALL SMALL

Socioeconomics SMALL TO SMALL TO

MODERATE MODERATE

Waste Management SMALL SMALL N/A

8.2.1 Air Quality

Dauphin County does not meet the National Ambient Air Quality Standards established by EPA

under the CAA and is a nonattainment area for PM2.5. A new gas-fired generating plant

developed at the TMI-1 site would need to comply with the new source performance standards

set forth in 40 CFR 60 Subpart D(a). The standards establish limits for particulate matter and

opacity (40 CFR 60.42(a)), SO 2 (40 CFR 60.43(a)), and NOx (40 CFR 60.44(a)).

NUREG-1437, Supplement 37 8-18 June 2009
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A gas-fired power plant constructed elsewhere in Pennsylvania would need to comply with

applicable provisions of the CAA, based on the attainment status of the selected alternate site. If

a natural gas-fired plant were located close to a mandatory Class I area, additional air pollution

control requirements could be imposed. Pennsylvania does not have any designated Class I

wilderness areas, the closest being Brigantine, New Jersey. For an alternate site, consideration

may need to be given to installation of additional air emission control systems if the plant could

potentially affect visibility in any of the Class I areas.

Pennsylvania regulates air emissions from power plants pursuant to terms of the APCA, as

discussed in Section 8.1.1. Regulations enforced by the PADEP adopt the EPA's CAA rules,

with modifications, to limit power plant emissions of SOx, NOx, particulate matter, and

hazardous air pollutants, among other matters (PADEP 2008). Depending where a new gasfired facility is located within the State, that facility will need to comply with the applicable

Federal and State air regulations.

NOx is typically the pollutant of greatest concern for natural-gas-fired power plants. This gasfired alternative relies on dry, low-NOx burners, as well as selective catalytic reduction (SCR) to

reduce NOx emissions.

Pennsylvania and most other eastern states had been subject to requirements of 40 CFR

51.121(e), "Findings and requirements for submission of State implementation plan revisions

relating to emissions of oxides of nitrogen," and the total amount of NOx emissions allowed for

the Pennsylvania State implementation plan was 2,57,928 t (233,988 MT) for the 2007 ozone

season, and would have been subject to ozone-controlling elements of the Clean Air Interstate

Rule (CAIR) had CAIR not been vacated by the D.C. Circuit Court in July of 2008. On

September 24, 2008, EPA filed for a rehearing of the D.C. Circuit Court decisions. Until EPA,

Congress, or the courts act, future NOx regulatory approaches remain uncertain.

The NRC staff projects the following emissions for a gas-fired alternative based on data

published by the EIA, on EPA emissions factors, and on performance characteristics for this

alternative and its emissions controls:

" Sulfur dioxide - 60 tons per year (t/yr)

" Nitrogen oxides - 192 t/yr

* Carbon monoxide- 40 t/yr

" PM10-33.5 t/yr

A natural gas-fired plant would also have unregulated CO2 emissions and, in the case of this

alternative to TMI-1, would emit approximately 1.99 million tons of CO2 per year.

In December 2000, the EPA issued regulatory findings on emissions of hazardous air pollutants

from electric utility steam-generating units (65 FR 32214). Natural gas-fired power plants were

found by the EPA to emit arsenic, formaldehyde, and nickel. Unlike coal- and oil-fired plants, the

EPA did not determine that emissions of hazardous air pollutants from natural gas-fired power

plants should be regulated under Section 112 of the CAA.

Construction activities would also result in some air effects, including those from temporary

fugitive dust, though construction crews would employ dust-control practices to limit this impact.

Exhaust emissions would also come from vehicles and motorized equipment used during the

June 2009 8-19 NUREG-1437, Supplement 37
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construction process, though these emissions are likely to be intermittent in nature and will

occur over a limited period of time. As such, construction stage impacts would be SMALL.

The overall air-quality impacts of a new natural gas-fired combined cycle plant sited at TMI-1 or

at an alternate site would be MODERATE.

8.2.2 Ground Water Use and Quality

The use of ground water for a natural gas combined cycle plant would likely be limited to supply

wells for drinking water and possibly filtered service water for system cleaning purposes. The

impact of ground water use would be SMALL. No effects on ground water quality would be

apparent except during the construction phase when possible dewatering and run-off controls

are used.

8.2.3 Surface Water Use and Quality

Consumptive use of surface water from the Susquehanna River, or from another body of water

at an alternate site, would be much less for a gas-fired plant than the 18 mgd currently used on

average by TMI-1. In addition, the discharge of waste water using this technology would be

minimal. Impact on surface water resources at both the TMI-1 site and an alternate site would

be SMALL.

8.2.4 Terrestrial and Aquatic Ecology

Terrestrial Ecology

As indicated in previous sections, constructing the natural gas alternative will require 32 ac (13

ha) of land. These land disturbances form the basis for impacts to terrestrial ecology. (Gas

extraction and collection will also affect terrestrial ecology in offsite gas fields, although, as

noted in Section 8.2.6, much of this land is likely already disturbed by gas extraction, and the

incremental effects of this alternative on gas field terrestrial ecology are difficult to gauge.)

Impacts to terrestrial ecology will be minor because the selected site has been previously

disturbed and is located on the southern end of the island. There is potential for disturbance of

some areas with trees or manmade wetlands, and possible habitat fragmentation would occur.

Construction of transmission line ROWs, a lengthy pipeline, or additional roads on undisturbed

or less-disturbed areas could adversely impact terrestrial ecology by fragmenting or destroying

habitats. However, a pipelined fuel source and a small workforce would help to minimize the

need for additional transportation infrastructure.

In addition, construction onsite may eliminate onsite habitats and alter the site for a long period

of time. Some areas onsite, such as any buffer areas, may remain undeveloped and could still

harbor habitat for terrestrial species, though site lighting, noise, and activities may degrade the

value of any remaining ecosystems. Deposition of air pollutants from this alternative may affect

terrestrial ecology, but it is unlikely to be noticeable. Impacts to terrestrial resources from a

natural gas combined-cycle alternative at both the TMI-1 site and an alternate site would like be

SMALL.

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Aquatic Ecology

Aquatic ecology actually benefits from the onsite, gas-fired alternative, as the combined-cycle

plant rejects significantly less heat to the environment than the existing TMI-1, thus requiring

less water. A gas-fired alternative would require less than half as much water as the existingplant due to its much higher thermal efficiency. As the onsite gas-fired alternative would

continue to use the existing cooling system, impacts to aquatic ecology would also be minimal.

Aquatic impacts at an alternate site depend on location and ecology of the site, and the surface

water body used for intake and discharge. These impacts are likely smaller at urban or

previously industrial sites, owing to generally closer access to pipelines and transmission lines

than at undeveloped sites. Overall, the ecological impacts are considered SMALL at the TMI-1

site and could range from SMALL to LARGE at a different location., depending on the sensitivity

of local aquatic communities.

8.2.5 Human Health

Like the coal-fired alternative discussed above, a gas-fired plant would emit criteria air

pollutants, but generally in smaller quantities (except NOx, which requires additional controls to

reduce emissions). Human health risks of a gas-fired alternative are generally low, although in

Table 8-2 of the GElS (NRC 1996), the NRC staff identified cancer and emphysema as potential

health risks from a gas-fired alternative. However, the current Federal and State regulatory

frameworks, pertaining to air emission standards, allow for the adequate protection of

occupational workers and members of the public. Therefore, the NRC staff has adopted (where

applicable) the Federal and State air quality regulatory limits as significant thresholds for

determining the human health risks associated with the operation of a new gas-fired power

plant.

NOx emissions contribute to ozone formation, which in turn contribute to human health risks.

Emission controls on this gas-fired alternative maintain NOx emissions well below air quality

standards established for the purposes of protecting human health, and emissions trading or

offset requirements mean that overall NOx in the region would not increase. Health risks to

workers may also result from handling spent catalysts that may contain heavy metals. Ove'rall,

human health risks to occupational workers and to members of the public from gas-fired power

plant emissions sited at TMI-1 or at an alternate site would be similar to the risks described for

coal-fired alternative and therefore, would likely be SMALL.

8.2.6 Socioeconomics

Land Use

A discussed in Section 8.1, the GElS generically evaluates the impacts of nuclear power plant

operations on land use both on and off each power plant site. The analysis of land use impacts

focuses on the amount of land area that would be affected by the construction and operation of

a natural gas-fired combined-cycle generation power plant at the TMI-1 site and at an alternate

site. Land-use impacts would vary depending on where the plant would be located and whether

construction would take place on undeveloped land or within a previously disturbed (brownfield)

area.

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I Exelon Generation indicated that approximately 32 ac (13 ha) would be necessary to support a

natural gas-fired alternative capable of replacing TMI-1. The GELS, however, estimates 110 ac

(45 ha) for a 1000-MWe generating station (NRC 19.96). This amount of land use would include

other plant structures and associated infrastructure. By scaling the GElS estimate, an 853-MWe

plant could require up to 92 ac (37 ha) of land. This amount of land will encompass the plant site

at both TMI-1 and an alternate site, and transmission line ROWs at an alternate site. The NRC

I staff believes that the Exelon Generation estimate is reasonable. However, if additional land

would be necessary for a buffer around plant structures or to support transmission lines at an

alternate site and gas pipelines at both TMI-1 and at an alternate site, the NRC staff believes

the GElS estimate for land use provides a more useful approximation. Nevertheless, land use

impacts from construction would be SMALL, and could be further reduced if the power plant is

collocated with another generating station or on a previously industrial site like TMI-1. Impacts

could be further mitigated at an alternate site by constructing new transmission lines in existing

ROWs.

In addition to onsite land requirements, land will be required off site for natural gas wells and

collection stations. The GElS estimates that 3,600 ac (1,457 ha) would be required for wells,

collection stations, and pipelines to bring the gas to a 1,000-MWe generating facility. If this land

requirement were scaled directly with generating capacity, an alternative to TMI-1 could require

up to 3,000 ac (1,200 ha) (though actual requirements will vary significantly). Most of this land

requirement would occur on land where gas extraction already occurs. In addition, some natural

gas that could be used by the new power plant may come from outside of the United States and

would be delivered as liquefied gas. Effects from gas extraction are generally smaller than those

for coal mining, as most land around a gas extraction site remains undisturbed, except for roads

and collection pipe network. Site reclamation after natural gas extraction would be less involved

than land previously used for coal mining.

The elimination of uranium fuel for TMI-1 could partially offset off site land requirements. In the

GELS, the NRC staff estimated that approximately 1,000 ac (405 ha) would not be needed for

mining and processing uranium during the operating life of a 1,000-MWe nuclear power plant.

For TMI-1, roughly 850 ac (344 ha) of uranium mining area would no longer be needed. Overall

land use impacts from a gas-fired power plant would be SMALL to MODERATE, depending on

local land use and the availability of land near the proposed site.

Socioeconomics

As discussed in Section 8.1, socioeconomic impacts are defined as changes to the

demographic and economic characteristics and social conditions of a region. For example, the

number of jobs created by the construction and operation of a new natural gas-fired power could

affect regional employment, income, and expenditures. Job creation is characterized by two

types: (1) construction-related jobs, which are transient, short in duration, and less likely to have

long-term socioeconomic impacts; and (2) operation-related jobs in support of power plant

operations, which have the greater potential for permanent, long-term socioeconomic impacts.

Workforce requirements of power plant construction and operations for the gas-fired alternative

were determined in order to measure their possible effect on current socioeconomic conditions.

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The socioeconomic impacts from constructing and operating a gas-fired plant would have little

noticeable effect. Compared to the coal-fired alternative, the small size of the construction and

operations workforce would have little or no socioeconomic impact.

Exelon Generation indicated that a 483-member workforce would be required to construct the

gas-fired alternative (AmerGen 2008). After construction, local communities may be temporarily

affected by the loss of construction jobs and associated loss in demand for business services,

and the rental housing market could experience increased vacancies and decreased prices. The

impact of construction on socioeconomic conditions could range from SMALL to MODERATE

depending on whether or not the new power plant would be located at TMI-1 or an alternate

site. The socioeconomic impacts of power plant construction could be reduced if the power plant

is located near an urban area with a large pool of skilled workers.

Following construction, a gas-fired alternative could provide up to 27 jobs, based on Exelon

Generation estimates, or up to 125 jobs based on an extrapolated estimate fro the GELS.

Depending on location, the small number of workers would not have a noticeable effect on

socioeconomic conditions in the region. Therefore, socioeconomic impacts associated with

operation of a gas-fired power plant would be SMALL.

Transportation

Transportation impacts associated with construction and operation of a two unit power plant

under the gas-fired alternative would consist of commuting workers and truck deliveries of

construction materials to the TMI-1 worksite. Transportation effects would vary depending on

the characteristics of site access roads. In addition to commuting workers, trucks would deliver

construction materials to the worksite. These vehicles would increase the overall number of

vehicles on local roads. Pipeline construction and modification to existing natural gas pipeline

systems may also have a short-term impact.

Conversely, transportation impacts would almost disappear during plant operations. The

estimated number of operating personnel would be approximately 27 workers, although the

GElS indicates that as many as 125 operations workers could be required. Since fuel is

transported by pipeline, most transportation infrastructure will experience little increased use

from plant operations.

Since fuel would be transported by pipeline, the transportation infrastructure would experience

little to no increased use from plant operations. Overall, the gas-fired alternative would have a

SMALL impact on transportation conditions in the region around TMI-1. Transportation impacts

may vary at an alternate site and would depend on roadway capacity and average daily volume.

Aesthetics

As discussed in Section 8.1, aesthetic resources are the natural and man-made features that

give a particular landscape its character and aesthetic quality. The aesthetics impact analysis

focuses on the degree of contrast between the power plant and the surrounding landscape and

the visibility of the power plant.

The two gas-fired units could be approximately 100 ft (30 meters [m]) tall, with two exhaust

stacks at least 175 ft (53 m) tall or taller depending on the topography at an alternate site. Some

structures may require aircraft warning lights. If the plant is located near the existing TMI-1,

impacts may be moderated as higher elevations and vegetation along the river valley could

June 2009 8-23 NUREG-1 437, Supplement 37
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make it difficult to see or hear the plant outside of the river valley. Power plant infrastructure

would generally be smaller and less noticeable than TMI-1 containment and cooling tower. The

mechanical draft cooling towers would be markedly shorter than the natural-draft towers located

at TMI-1, but they would also generate condensate plumes and operational noise. Noise during

power plant operations would be limited to industrial processes and communications.

In addition to seeing new power plant structures, the alternate plant site may require the

construction of transmission lines and natural gas pipelines. The transmission lines would have

a lasting visual effect on the landscape.

Noise from plant operations would be primarily limited to industrial processes and

communications. Unlike the coal-fired alternative, pipelines would deliver natural gas fuel, thus

eliminating the noises from fuel and waste handling and associated transportation equipment.

Noise from the pipelines could be audible off site near compressors.

In general, aesthetic changes would be limited to the immediate vicinity of TMI-1 or an alternate

site. Impacts would likely to be SMALL to MODERATE, depending on the amount of new

transmission line required.

Historic and Archaeological Resources

The potential for historic and archaeological resources can vary greatly depending on the

location of the proposed site. To consider a project's effects on historic and archaeological

resources, any proposed areas will need to be surveyed to identify and record historic and

archeological resources, identify cultural resources, and develop possible mitigation measures

to address any adverse effects from ground disturbing activities. Studies will be needed for all

areas of potential disturbance at the proposed plant site and along associated corridors where

new construction will occur (e.g., roads, transmission corridors, rail lines, or other ROWs). In

most cases, project proponents should avoid areas with the greatest sensitivity.

Depending on the resource richness of the site ultimately chosen for the gas-fired alternative,

impacts will range from SMALL to MODERATE.

Environmental Justice

The environmental justice impact analysis evaluates the potential for disproportionately high and

adverse human health and environmental effects on minority and low-income populations that

could result from the construction and operation of a new natural gas-fired combined-cycle

generation power plant. Adverse health effects are measured in terms of the risk and rate of

fatal or nonfatal adverse impacts on human health. Disproportionately high and adverse human

health effects occur when the risk or rate of exposure to an environmental hazard for a minority

or low-income population is significant and exceeds the risk or exposure rate for the general

population or for another appropriate comparison group. The minority and low-income

populations are subsets of the general public residing around the site, and all are exposed to

the same hazards generated from various power plant operations.

Minority and low-income populations could be disproportionately affected by the construction

and operation of a new natural gas-fired power plant. Some of these effects have been

identified in resource areas discussed in this section. For example, increased demand for rental

housing during construction could disproportionately affect low-income populations. However,

demand for rental housing could be mitigated if the alternate plant site is constructed near a

NUREG-1437, Supplement 37 8-24 June 2009
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metropolitan area. Environmental justice impacts from the construction and operation of a gasfired alternative could range from SMALL to MODERATE and would depend on whether effects

from the plant on minority and low-income populations are adverse and disproportionate.

8.2.7 Waste Management

Minor quantities of waste are generated during burning of natural gas compared to other

alternatives, however use of SCR to control NOx will generate spent SCR catalysts and small

amounts of solid waste products.

It is concluded in the GElS by the NRC staff that gas-fired technology waste generation would

be minimal (NRC 1996) and the waste impacts would be SMALL for a natural gas-fired

combined-cycle plant sited at TMI-1 or at alternate site.

8.3 Energy Conservation/Energy Efficiency

In this section, the NRC staff evaluates the environmental impacts of a demand-side energy

conservation or energy efficiency alternative. On the following page Table 8-3 summarizes the

environmental impacts of energy conservation and energy efficiency compared to continued

operation of TMI-I.

Though often used interchangeably,- energy conservation and energy efficiency are different

concepts. Energy efficiency typically means deriving a similar level of services by using less

energy, while energy conservation simply indicates a reduction in energy consumption. Both fall

into a larger category known as demand-side management (DSM). DSM measures-unlike the

energy supply alternatives discussed in previous sections-address energy end uses. DSM can

include measures that shift energy consumption to different times of day to reduce peak loads,

measures that interrupt certain large customers during periods of high demand or measures that

interrupt certain appliances during high demand periods, and measures like replacing older, less

efficient appliances, lighting, or control systems. DSM also includes measures that utilities use

to boost sales, such as encouraging customers to switch from gas to electricity for water

heating.

Unlike other alternatives to license renewal, the GElS notes that conservation is not a discrete

power generating source; it represents an option that states and utilities may use to reduce their

need for power generation capability (NRC 1996). In addition, conservation represents a

possible option in case of the no-action alternative. The GElS "assumes that conservation

technologies produce enough energy savings to permit the closing of a nuclear plant."

Prior to the implementation of Pennsylvania's Alternative Energy Portfolio Standard (AEPS),

several Pennsylvania foundations sponsored a study by engineering firm Black and Veatch to

document the potential effects renewable energy, conservation/efficiency, and unconventional

power sources like waste coal (Pletka 2004). The study distinguished between energy efficiency

and conservation, and defined conservation as demand-side measures, and efficiency as

supply-side measure like repowering or other power plant, transmission, or distribution

improvements. Because Black and Veatch's defined energy efficiency as only supply-side

options, and because Black and Veatch defined conservation as including all demand-side

measures to reduce electricity consumption, we will only use Black and Veatch's conservation

June 2009 8-25 NUREG-1437, Supplement 37
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estimates in the following section. Black and Veatch's analysis indicated 18,206 gigawatt-hours

(GWh) of conservation could be achieved within 10-15 years of the study's 2004 publication

date (Pletka 2004), or roughly three times the amount of electricity produced byTMI-1 in a given

year. The total magnitude of these savings could be as large as 6872 MW, or more than eight

times TMI-1's power output. Overall, Black and Veatch indicated that Pennsylvania had "good"

conservation resources.

Since the study, PJM9 has instituted new measures to capture energy efficiency potential, and

energy efficiency measures which now count for inclusion in the AEPS. The NRC had difficulty

determining how much of the potential identified in the 2004 report remains available in

Pennsylvania, though it appears unlikely that all or even most of this potential would already

have been exploited. Beyond near-term potential, Black and Veatch's analysis identified an

additional 70,000 GWh or 28,824 MW of conservation potential, some of which may be

available at higher costs or on longer time horizons. Also, because TMI-1 sells power into the

PJM interconnection, conservation in other nearby states may also help to offset power

produced by TMI-1, even though sufficient capacity appears to exist in Pennsylvania alone.

Therefore, the NRC staff chose to evaluate conservation as an alternative to license renewal.

A conservation alternative will produce different impacts than the other alternatives addressed.

Unlike the discrete generation options, there is no major construction and few ongoing

operational impacts. The most significant effects occur during installation or implementation or

conservation measures, when old appliances may be disposed of, buildings may be retrofitted,

or control devices may be installed. In some cases, increases in efficiency may come from

better management of existing control systems. Many of these items may 'be recycled, though

volumes of landfilled trash may still increase.

The GElS generally indicates that impacts from a conservation alternative are small and that

some postulated effects (like increases in mercury, polychlorinated biphenyls (PCBs), or

chlorofluorocarbon (CFC) releases as fluorescent bulbs, old transformers or old refrigerators are

replaced) may prove not to be significant as effective disposal methods can prevent health

effects, and as more environmentally-benign alternatives have emerged (NRC 1996).

Table 8-3. Summary of Environmental Impacts of Energy ConservationlEnergy

Efficiency Compared to Continued Operation of TMI-1.

Continued TMI-1 Energy Conservation/Energy Efficiency Operation

Air Quality SMALL SMALL

Ground Water SMALL SMALL

Surface Water SMALL SMALL

Aquatic and Terrestrial SMALL SMALL

Resources

Human Health SMALL SMALL

Socioeconomics SMALL SMALL

Waste Management SMALL N/A

PJM Interconnection is a regional transmission organization (RTO) that coordinates the movement of

wholesale electricity in all or parts of 13 states and the District of Columbia, including Pennsylvania.

NUREG-1437, Supplement 37 8-26 June 2009
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8.3.1 Air Quality

Implementation of the energy conservation alternative reduces direct fuel use and reduces

environmental emissions resulting from plant fuel cycles, workers' commuting, and plant

operation and maintenance. Improvements in efficiency may also reduce consumption of fuels

used for space or water heating at the same time they reduce electrical consumption.

As noted above, no major construction would be required and few ongoing operational impacts

would be experienced during implementation of the conservation alternative. The conservation

alternative would likely cause only minor and short-duration air quality impacts-use of best

management practices would minimize air quality impacts during installation of new appliances

or systems. Implementation of energy conservation measures would improve efficiency of

boilers and heating units and would help to reduce already low air emissions.

The overall impacts on air quality of the energy conservation and/or energy efficiency alternative

would be SMALL.

8.3.2 Ground Water Use and Quality

The conservation alternative would not require any groundwater. It is possible that wastes

produced during installation of improved equipment could have an effect on groundwater if

leachate from landfills infiltrate groundwater, but this effect is not likely to be noticeably altered

by a small increase in overall waste production, if any, associated with the conservation

alternative. Overall impacts to groundwater are SMALL.

8.3.3 Surface Water Use and Quality

The impacts on surface water use and quality because of energy conservation efforts would be

SMALL, but positive. The consumptive use of water from the Susquehanna River would

certainly decrease as would the discharge of waste water streams.

8.3.4 Terrestrial and Aquatic Ecology

Terrestrial Ecolocq

Terrestrial ecology impacts would be SMALL. No additional land disturbances on or offsite

would be required.

Aquatic Ecology

Impacts to aquatic resources would be SMALL, but positive, as withdrawals from and

discharges to the Susquehanna River would cease, since the no-power generation alternative

would take the place of TMI-I. If more energy is conserved than is produced by TMI-1, then

positive impacts to aquatic resources could extend beyond the Susquehanna River to other

water bodies. This net conservation of energy could result in less demand for power production

at other plants and could lead to lower rates of water withdrawal and discharge at these power

plants. The implementation of conservation measures, such as the increased use of mercurycontaining compact fluorescent light bulbs and their impact to the environment after landfill

June 2009 8-27 NUREG-1437, Supplement 37
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disposal, would result in SMALL impacts to the aquatic environment. While increased mercury

levels in landfills could leach into adjacent waterways, State and local landfill regulations could

reduce or eliminate such pollution.

8.3.5 Human Health

Energy demand reduction measures are specific procedures or technologies that are

undertaken to reduce energy demands. Human health risks of the energy conservation

alternative are minimal, although in Table 8-2 of the GElS (NRC 1996) the NRC staff identified

radon as the major potential health risk from the energy conservation alternative. Currently,

there are no Federal or State regulatory frameworks pertaining to radon exposure standard,

therefore, the NRC staff has chosen the EPA recommendation level of 4 picocuries per Liter

(pCi/L) as a significant threshold for determining the human health risks associated with the

energy conservation alternative.

Radon-222 is a naturally occurring radioactive noble gas that is formed from the decay of

radium-226. Radiation exposure from radon-222 is indirect. Radon has a short half-life (4 days)

and decays into other solid particulate radioactive nuclides that give off high energy alpha

particles. These radioactive particles are inhaled and remain lodged in the lungs, causing

continued exposure. People in affected localities can receive up to 10 mSv per year background

radiation of radon-222. Radon-222 is thus the second leading cause of lung cancer after

smoking, and accounts for 15,000 to 22,000 cancer deaths per year in the U.S. alone (Darby

1989). The general population is exposed to small amounts of polonium as a radon-daughter in

indoor air; the isotopes polonium-214 and polonium-218 are thought to cause the majority of the

estimated lung cancer deaths from radon (Darby 1989). A Bonneville Power Administration

radon-222 exposure study found that radon-222 was a serious concern in new home

construction if mitigation measures were not implemented. Cancer cases from radon-222

exposures were estimated to be 335 per 100,000 for baseline homes but as high as 767 cases

per 100,000 for new homes with advanced infiltration control but no exhaust or mechanical

ventilation (Pace 1991).

EPA recommends homes be fixed if the radon level is 4 pCi/L or more. Because there is no

known safe level of exposure to radon, EPA also recommends that Americans consider fixing

their homes for radon levels between 2 pCi/L and 4 pCi/L. The average radon concentration in

the indoor air of America's homes is about 1.3 pCi/L. The average concentration of radon in

outdoor air is 0.4 pCi/L, about 1/10th of EPA's 4 pCi/L action level (EPA 2008b). Given that a

member of the public has taken appropriate mitigative actions-such as installing a more

efficient ventilation system for radon removal, sealing cracks in basements, etc.-to achieve an

indoor radon concentration below 2 pCi/L, the human health risks to members of the public from

the energy conservation alternative would be within the range of the national average and would

likely be SMALL.

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8.3.6 Socioeconomics

Land Use

Since Exelon Generation would continue to use the existing transmission lines land use impacts

of an energy efficiency alternative would be SMALL. Quickly replacing and disposing of Old

inefficient appliances could generate waste material and potentially increase the size of landfills.

However, given the 10 to 15-year timeline for program development and implementation, the

cost of replacements, and the average life of an appliance; the replacement process would

probably be more gradual. Older appliances would simply be replaced by more efficient

appliances as they fail (especially in the case of frequently replaced items, like lightbulbs). In

addition, many items (like home appliances or industrial equipment) have substantial recycling

value and would likely not be disposed of in landfills.

Socioeconomics

Socioeconomic effects of an energy efficiency program would be SMALL. As noted in the GELS,

the program would likely employ additional workers. Lower-income families could benefit from

weatherization and insulation programs. This effect would be greater than the effect for the

general population because low-income households experience home energy burdens more

than four times larger than the average household (OMB 2007).

Transportation

Transportation impacts would be SMALL, because fewer employees would commute to TMI-1.

Any transportation effects from the energy efficiency alternative would be widely distributed

across the State, and would not be noticeable.

Aesthetics

Impacts from energy efficiency programs would be SMALL because TMI-1 would be

decommissioned with no alternative power plant to replace it. The transmission lines would

remain after plant decommissioning. Traffic to the plant would decrease, however, as would

noise and emissions. Some noise impacts could occur in instances of energy efficiency

upgrades to major building systems, though this impact would be intermittent and short-lived.

Historic and Archaeologqical Resources

Impacts from the energy conservation/energy efficiency alternative would be SMALL, since TMI1 would be decommissioned with no alternative power plant to replace it. A separate

environmental review would be conducted for decommissioning. That assessment will address

the protection of historic and archaeological resources.

Environmental Justice

Weatherization programs could target low-income residents as a cost-effective energy efficiency

option since low-income populations tend to spend a larger proportion of their incomes paying

utility bills (according to the Office of Management and Budget, low income populations

experience energy burdens more than four times as large as those of average households

[OMB 2007]). Impacts to minority and low-income populations from energy efficiency programs

would be SMALL, depending on program design and enrollment. The impacts from these

programs may be disproportionate, but are not likely to be adverse.

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8.3.7 Waste Management

The most significant effects occur during installation or implementation or conservation

measures, when old appliances may be disposed of, buildings may be retrofitted, or control

devices may be installed. Implementation of the, recycling programs would help to decrease

volumes of the generated waste, though volumes of the trash sent to the landfills may still

increase.

According to the GELS, impacts from a conservation alternative are minimal, and some

postulated effects (like increases in mercury, PCBs, or CFC releases as fluorescent bulbs, old

transformers or old refrigerators are replaced) may prove to be insignificant as more

environmentally-benign alternatives have emerged, and if proper disposal methods are

employed (NRC 1996).

Overall, the waste impacts would be SMALL for the energy conservation and/or energy

efficiency alternative.

8.4 Combination Alternative

In this section, we evaluate the environmental impacts of a combination of alternatives. This

combination will include a portion of the energy efficiency/conservation potential identified in

Section 8.3, a portion of the combined-cycle gas-fired capacity identified in Section 8.2, and a

series of uprates to existing hydroelectric dams. This alternative requires little new construction

(only for the single gas-fired unit installed at the TMI-1 site and minor renovation at uprated

dams). We acknowledge that we could also include some amount of wind power in this

alternative as a companion to the hydropower uprates, though the NRC elected not to do so

since constructing wind power facilities would likely increase the environmental impact of the

combination alternative without a commensurate decrease in operating impacts from other

portions of the combination alternative. Table 8-4 on the following page contains a summary of

the environmental impacts of the combination alternative compared to continued operation of

TMI-1.

In this alternative, slightly more than half of TMI-1's output (approximately 420 MW) would be

replaced by conservation. Power uprates at existing hydroelectric dams will account for roughly

100 MWe of capacity (as identified in INEEL 1997) and 280 MWe will come from one GE

S107FB combined cycle power plant. The only major construction we anticipate will happen at

the current TMI-1 site where the combined-cycle gas-fired power plant would be constructed.

No major construction should be necessary for the conservation portion, and relatively minor

construction would occur at existing dams for purposes of power uprates.

The appearance of the single-unit gas-fired facility would be similar to that of the two-unit gasfired alternative considered in Section 8.2, except smaller. We estimate that the single-unit gasfired facility would require approximately 35 percent of the space necessary for the two-unit gasfired facility considered in Section 8.2, and that all construction effects-as well as operational

aesthetic, fuel-cycle, air quality, socioeconomic, land use, environmental justice, and water

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consumption effects-will scale accordingly.' 0 Since the gas-fired portion of this alternative uses

roughly a third of the available land south of TMI Unit 2 on Three Mile Island, Exelon Generation. I

may still be able to use most of the available space for outage personnel, and eventual

decommissioning activities of TMI-1.

Table 8-4. Summary of Environmental Impacts of the Combination Alternative Compared

to Continued Operation of TMI-1.

Combination Alternative Continued TMI-1

At TMI-1 Site At Alternate Site Operation

SMALL to

Air Quality MODERATE MODERATE SMALL

Ground Water SMALL SMALL SMALL

Surface Water SMALL SMALL SMALL

Aquatic and Terrestrial SMALL SMALL SMALL

Resources

Human Health SMALL SMALL SMALL

SMALL to SMALL TO

Socioeconomics MODERATE SMODERtE MODERATE MODERTE SMALL

Waste Management SMALL SMALL N/A

8.4.1 Air Quality

As noted in Section 8.2.1, Dauphin County does not meet the National Ambient Air Quality

Standards established by EPA under the CAA and is in a nonattainment area for PM2.

5. A new

gas-fired generating plant developed at the TMI-1 site would need to comply with the new

source performance standards set forth in 40 CFR 60 Subparts D(a). The standards establish

limits for particulate matter and opacity, SO2 , and NOx.

Pennsylvania and most other eastern states had been subject to requirements of 40 CFR

51.121(e), "Findings and requirements for submission of State implementation plan revisions

relating to emissions of oxides of nitrogen," and the total amount of NOx emissions allowed for

the Pennsylvania State implementation plan was 257,928 t (233,988 MT) for the 2007 ozone

season, and would have been subject to ozone-controlling elements of the Clean Air Interstate

Rule (CAIR) had CAIR not been vacated by the D.C. Circuit Court in July of this year. On

September 24, 2008, EPA filed for a rehearing of the D.C. Circuit Court decision. Until EPA,

Congress, or the courts act, future NOx regulatory approaches remain uncertain.

As noted in 8.2.1, NOx is typically the pollutant of greatest concern for natural-gas-fired power

plants. Like the plant in 8.2.1, this gas-fired portion of this alternative relies on dry, low-NOx

burners, as well as selective catalytic reduction (SCR) to reduce NOx emissions.

For the combination alternative only one gas-fired unit would be built. Emissions of SOx, NOx,

mercury, and particulate matter would be approximately 37 percent of those detailed in Section

10 The S107FB unit considered here is slightly less efficient than the S207H units considered in Section 8.2

(heat rate of 5950 btu/kWh for the S107FB versus 5690 btu/kWh for the S207H; GE 2007). We've

calculated air quality impacts in the following sections accordingly.

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8.2.1. A natural gas-fired plant would also have unregulated CO2 emissions; a single-unit gasfired facility would emit approximately 728,000 t (660,000 MT) of CO2 per year.

As noted in 8.2.1, EPA has determined that natural gas-fired power plants emit arsenic,

formaldehyde, and nickel. Unlike coal and oil-fired plants, EPA did not determine that emissions

of hazardous air pollutants from natural gas-fired power plants should be regulated under

Section 112 of the CAA.

Construction activities for the gas-fired unit as well as retrofits at existing dams would also result

in some air effects, including those from temporary fugitive dust, though construction crews

would employ dust-control practices to limit this impact. Exhaust emissions would also come

from vehicles and motorized equipment used during the construction process, though these

emissions are likely to be intermittent in nature and would occur over a limited period of time.

Construction stage impacts would, therefore, be SMALL.

The overall air-quality impacts of the combination alternative-based largely on the impacts

from a new, single-unit, natural gas-fired combined cycle plant sited at TMI-1-would be

SMALL to MODERATE.

8.4.2 Ground Water Use and Quality

If the onsite gas-fired plant continued to use ground water for drinking water and service water,

the total usage would likely be much less than TMI-1 uses, because many fewer workers are

onsite, and because the gas-fired unit would have fewer auxiliary systems requiring service

water. The current permitted withdrawal rate is 225,000 gpd, and pumping tests indicate this

rate would not cause an effect on nearby supply wells. A reduction in this withdrawal rate

means that impacts of the combination alternative would remain SMALL.

8.4.3 Surface Water Use and Quality

Using a combined alternative with conservation as a major component will reduce the amount of

surface water consumed for cooling purposes. The maximum consumptive use would be

reduced to'a fraction of the 18 mgd used by the current nuclear plant. This represents less than

0.1 percent of the average annual flow rate in the river. The impact of this withdrawal would be

SMALL.

8.4.4 Terrestrial and Aquatic Ecology

Terrestrial Ecoloqy

Impacts to terrestrial ecology would be SMALL. ROW maintenance would continue, although no

additional transmission lines would be necessary. The only construction activities that would

occur for the combination alternative are the construction of a combined-cycle gas-fired power

plant and any retrofit-related construction (largely internal) at existing dams. These activities

would be confined to previously disturbed areas at the TMI-1 site, and would be relatively limited

at dam sites. Some habitat fragmentation impacts on the southern part of the island may occur.

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Aquatic Ecoloqy

Aquatic ecology would actually benefit from the combination efficiency/conservation,

hydroelectric power plant uprates, and gas-fired power plant alternative, as the combined-cycle

plant would reject significantly less heat to the environment than the existing TMI-1, thus

requiring less water. Impacts to aquatic resources would be SMALL, but positive, as

withdrawals from and discharges to the Susquehanna River would be significantly less. Energy

conservation and efficiency would likewise result in less withdrawals and discharges

corresponding to a decreased demand for power generation as discussed in Section 8.3.

Uprates to hydroelectric power plants to compensate for loss of power generation at TMI-1

could lead to slight increases in entrainment and impingement impacts at these hydroelectric

plants, but these impacts would be regulated and likely SMALL.

8.4.5 Human Health

The human health risks of a combination of altematives include those that have already been

discussed in their respective sections (i.e. energy conservation and combined cycle gas-fired

alternatives). The human health risks are uncertain, but considered to be SMALL given the

combination of alternatives must comply with health-based Federal and State emission

standards.

8.4.6 Socioeconomics

Land Use

As discussed in Section 8.1, the GElS generically evaluates the impacts of nuclear power plant

operations on land use both on and off each power plant site. The analysis of land use impacts

focuses on the amount of land area that would be affected by the construction and operation of

a single natural gas-fired unit power plant at the TMI-1 site and minor renovation of dams.

Approximately 11 ac (5 ha) would be necessary to support a single natural gas-fired unit

combination alternative based on Exelon Generation estimates for a discrete gas-powered

alternative. By scaling the GElS estimate, a 280 MWe plant could require up to approximately

32 ac (13 ha) of land and would encompass available space at the TMI-1 site. The NRC staff

believes that the Exelon Generation estimate is reasonable. However, if additional land were

necessary for a buffer around plant structures and the construction of gas pipelines at TMI-1,

the NRC staff believes the GElS estimate provides a more useful approximation. Nevertheless,

land use impacts from construction would be SMALL.

In addition to onsite land requirements, land will be required offsite for natural gas wells and

collection stations. The GElS estimates that 3,600 ac (1,457 ha) would be required for wells,

collection stations, and pipelines to bring the gas to a 1 000-MWe generating facility. If this land

requirement were scaled directly with generating capacity, the combination alternative could

require up to 1,025 ac (425 ha), though actual requirements will vary significantly. As previously

discussed in Section 8.2, most of this land requirement would occur on land where gas

extraction already occurs. In addition, some natural gas that could be used by the new power

plant may come from outside of the U.S. and would be delivered as liquefied gas. Effects from

gas extraction are generally smaller than those for coal mining, as most land around a gas

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extraction site remains undisturbed, except for roads and collection pipe network. Site

reclamation after natural gas extraction would be less involved than reclamation of land

previously used for coal mining.

As previously discussed, the elimination of uranium fuel for TMI-1 could partially offset offsite

land requirements. In the GELS, the NRC staff estimated that approximately 1,000 ac (405 ha)

would no longer be needed for mining and processing uranium during the operating life of a

1 000-MWe nuclear power plant. For TMI-1, roughly 850 ac (344 ha) of uranium mining area

would no longer be needed. Overall land use impacts from a single natural-gas-fired power

plant unit under the combination alternative would be SMALL.

Socioeconomics

As discussed in Section 8.1, socioeconomic impacts are defined in terms of changes to the

demographic and economic characteristics and social conditions of a region. For example, the

number of jobs created by the construction and operation of a new single natural gas-fired

power plant unit could affect regional employment, income, and expenditures. Job creation is

characterized by two types: (1) construction-related jobs, which are transient, short in duration,

and less likely to have long-term socioeconomic impacts; and (2) operation-related jobs in

support of power plant operations, which have the greater potential for permanent, long-term

socioeconomic impacts. Workforce requirements for power plant construction and operations for

the combination alternative were determined in order to measure their possible effect on current

socioeconomic conditions.

The socioeconomic impacts from constructing and operating a single unit natural-gas-fired plant

and minor renovation of dams would have little noticeable effect. Compared to the coal-fired

alternative, the small size of the construction and operations workforce would have little or no

socioeconomic impact.

Exelon Generation indicated that a peak construction workforce of 169 workers would be

required to construct this alternative (AmerGen 2008). After construction, local communities

may be temporarily affected by the loss of the construction jobs and associated loss in demand

for business services, and the rental housing market could experience increased vacancies and

decreased prices. The impact of construction on socioeconomic conditions would be SMALL.

Following construction, a single unit gas-fired combination alternative could provide up to nine

jobs, based on Exelon Generation estimates, or up to 44 jobs based on an extrapolated

estimate from the GELS. Socioeconomic impacts associated with the operation of a single unit

natural-gas-fired power plant would be SMALL.

Transportation

Transportation impacts associated with construction and operation of a single unit gas-fired

power plant under the combination alternative would consist of commuting workers and truck

deliveries of construction materials to the TMI-1 worksite. These vehicles would increase the

overall number of vehicles on local roads. Pipeline construction and modification to existing

natural gas pipeline systems may also have an additional, short-term impact.

Conversely, transportation impacts would almost disappear during plant operations. The

estimated number of operating personnel would be approximately nine workers, although, the

GElS indicates that as many as 44 operations workers could be required. Since fuel would be

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transported by pipeline, the transportation infrastructure would experience little to no increased

use from plant operations. Overall, the combination alternative would have a SMALL impact on

transportation conditions in the region around TMI-1.

Aesthetics

As discussed in Section 8.1, aesthetic resources are the natural and man-made features that

give a particular landscape its character and aesthetic quality. The aesthetics impact analysis

focuses on the degree of contrast between the power plant and the surrounding landscape and

the visibility of the power plant.

A single natural gas-fired unit located at TMI-1 could be approximately 100 ft (30 m) tall, with an

exhaust stack of at least 175 ft (53 m) tall. The impact would be moderated as higher elevations

and vegetation along the river valley could make it difficult to see or hear the power plant

outside of the river valley. The alternative power plant infrastructure would generally be smaller

and less noticeable than the current TMI-1 containment and cooling tower. The mechanical draft

cooling towers would be markedly shorter than the natural-draft towers located at TMI-1, but

they would also generate condensate plumes and operational noise. Noise during power plant

operations would be limited to industrial processes and communications.

In addition'to the power plant structures, construction of natural gas pipelines would have a

short-term impact. Noise from the pipelines could be audible offsite near compressors.

In general, aesthetic changes would be limited to the immediate vicinity of TMI-1; therefore

aesthetic impacts would be SMALL.

Historic and Archaeological Resources

As discussed in Section 8.2.6, depending on the resource richness of the site ultimately chosen

for the gas-fired single unit as part of the combination alternative, impacts will range from

SMALL to MODERATE.

Environmental Justice

The environmental justice impact analysis evaluates the potential for disproportionately high and

adverse human health and environmental effects on minority and low-income populations that

could result from the construction and operation of a single unit natural gas-fired power plant

and uprates to existing hydroelectric dams. Adverse health effects are measured in terms of the

risk and rate of fatal or nonfatal adverse impacts on human health. Disproportionately high and

adverse human health effects occur when the risk or rate of exposure to an environmental

hazard for a minority or low-income population is significant and exceeds the risk or exposure

rate for the general population or for another appropriate comparison group. The minority and

low-income populations are subsets of the general public residing around the site, all of whom

are exposed to the same hazards generated from power plant operations.

Minority and low-income populations could be affected by the construction and operation of a

new single unit natural gas-fired combined-cycle generation power plant at TMI-1. Some of

these effects have been identified in resource areas discussed in this section. Effects on

minority and low-income populations in the vicinity of TMI-1 would vary from construction to

operations. Increased localized rental housing demand during construction in some locations

could disproportionately affect low-income populations. Overall though, the impacts on minority

and low-income populations from the combination alternative would likely be SMALL, as the

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NRC staff finds that the potential for adverse impacts is smaller than for the gas-fired

alternative, and any disproportionate impacts from implementing conservation are unlikely to be

adverse.

8.4.7 Waste Management

As discussed in Sections 8.2.7 and 8.3.7, NRC staff concluded in the GElS that gas-fired

technology waste generation would be minimal (NRC 1996) and the waste impacts would be

SMALL for a natural gas-fired combined-cycle plant sited at TMI-1 or at an alternate site; and

impacts from a conservation alternative would be SMALL. Overall, the waste impacts from the

combination alternative would be SMALL.

8.5 Purchased Power

I Exelon Generation participates in the PJM Interconnection. This restructured energy supply

system allows for the sale of energy across parts of 13 States and the District of Columbia (PJM

2008). Across the PJM, coal is the predominant fuel used for generation, accounting for 55.3

percent in 2007, followed by nuclear (33.9 percent), natural gas (7.7 percent), hydroelectric (1.7

percent), oil (0.5 percent), solid waste (0.7 percent), and wind (0.2 percent) (PJM 2008). Many

of PJM's gas-fired units are actually able to burn fuel oil, as well, although gas utilization is

much higher due to lower costs and emissions. Given the size and flexibility of PJM, the NRC

staff considers it likely that purchased power could reasonably replace TMI-1.

Impacts would likely be similar to those of the above options located at alternate sites. If power

purchases cause currently existing capacity to operate at higher capacity factors, however,

rather than triggering new construction, then construction stage impacts would be eliminated. It

is likely, then, that purchased power would come from older, less efficient plants than those

considered in this chapter, from plants with once-through cooling, or from plants-without modern

emissions controls. Accordingly, impacts are difficult to quantify, although they are likely similar

I to those of other alternatives considered in Sections 8.2 through 8.4 in this supplemental EIS,

as well as in the GELS.

Given the location of TMI-1, it is unlikely that purchased power from outside the U.S. could

replace TMI-1 capacity, regardless of whether or not either country has sufficient existing export

capacity.

Since purchased power may come from a variety of generating resources, including coal,

natural gas, nuclear, hydroelectric, and perhaps oil-fired installations (where impacts in previous

NRC documents, including the supplemental EIS and the GELS, were determined to be similar

to or larger than those of natural-gas fired generation), NRC staff evaluation indicates that

impacts from the purchased power alternative would be greater than the impacts of license

renewal, and within the range of other alternatives considered in this chapter.

8.6 Alternatives Considered but Dismissed

In this section, the NRC staff presents the alternatives it initially considered for analysis as

alternatives to license renewal of TMI-1, but later dismissed due to technical, resource

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

likely to continue to exist when the existing TMI-1 license expires. Under each of the following

technology headings, the NRC staff indicates why it dismissed each alternative from further

consideration.

8.6.1 Coal-Fired Integrated Gasification Combined-Cycle

While utilities across the U.S. have considered or are considering plans for integrated

gasification combined-cycle (IGCC) coal-fired power plants, few IGCC facilities have yet been

constructed. All facilities constructed in the U.S. to date have been smaller than TMI-1.

The technology, however, is commercially available and essentially relies on a gasifier stage

and a combined-cycle turbine stage. Existing combined-cycle gas turbines (like the ones

considered in Section 8.2) could be used as part of an IGCC alternative.

EIA indicates that IGCC and other advanced coal plants may become increasingly common in

coming years (EIA 2008a, 2008b), though uncertainties about construction time periods and

commercial viability in the near future leads NRC staff to believe that IGCC is an unlikely

alternative to TMI-1 license renewal. For plants whose licenses expire at later dates, IGCC

(with or without carbon capture and storage) may prove to be a viable alternative, though NRC

did not evaluate IGCC as an alternative to TMI-1 license renewal.

8.6.2 New Nuclear

In its ER, Exelon Generation indicated that it is unlikely that a nuclear alternative could be sited,

constructed and operational by the time the TMI-1 operating license expires in 2014 (AmerGen

2008). Sources in the nuclear industry have recently indicated that reactor projects currently

under development are likely eight or nine years from completion (Nucleonics Week 2008), or

possibly online in the 2016-2017 timeframe. While several new reactor proposals currently

under development or undergoing NRC review are within the footprint of PJM, they are unlikely

to be available prior to the expiration of the TMI-1 operating license. Further, potential plant

owners or operators wishing to submit a new proposal specifically to offset the capacity of TMI-1

would require additional time to develop an application. Given the relatively short time

remaining on the current TMI-1 operating license, NRC staff has not evaluated new nuclear

generation as an alternative to license renewal.

8.6.3 Wind Power

Wind power, by itself, is not suitable for large baseload capacity. As discussed in Section 8.3.1

of the GELS, wind has a high degree of intermittency and low average annual capacity factors

(up to 30 to 40 percent). Wind power, in conjunction with energy storage mechanisms or

another readily dispatchable power source, like hydropower, could serve as a means of

providing baseload power. Current energy storage technologies are too expensive for wind

power to serve as a large baseload generator.

The Commonwealth of Pennsylvania is mostly a wind power Class 1 region, although some

areas, particularly along ridgelines, may provide wind classes ranging from 4 to 6 (DOE 2003).

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Wind turbines are economical in wind power Classes 4 through 7, which have average

windspeeds of 12.5 to 21.1 miles per hour (20 to 34 kilometers per hour) (DOE 2007).

Through the end of 2007, operators had installed 294 MWe in Pennsylvania (DOE 2008). While

installed wind power capacity is relatively low, wind power installation in Pennsylvania has

accelerated in recent years. As noted by the NRC staff in the supplemental EIS for the

Susquehanna Steam Electric Station, PJM has a maximum potential of 6,658 MWe of wind

capacity with an achievable potential of 665 MWe to 1,995 MWe. Given that this capacity will

function at a 30-40-percent capacity factor, it is unlikely that there will be sufficient wind power

potential to replace TMI-1.

Therefore, the NRC staff does not consider wind power to be a stand-alone alternative to TMI-1

license renewal.

8.6.4 Solar Power

Solar technologies use the sun's energy to produce electricity. Currently, the TMI-1 site receives

approximately 4 to 4.5 kWh per square meter per day (approximately 0.4 kWh of solar radiation

per square foot per day), as does much of Pennsylvania (NREL 2008), for solar collectors

oriented at an angle equal to the installation's latitude. Since flat-plate photovoltaics tend to be

roughly 25 percent efficient, a solar-powered alternative will require at least 3,590 to 4,040 ac

(1,450 to 1,640 ha) of collectors to provide an amount of electricity equivalent to that generated

by TMI-1. Space between parcels and associated infrastructure increase this land requirement.

This amount of land, while large, is consistent with the land required for coal and natural gas

fuel cycles. In the GElS, the NRC staff noted that, by its nature, solar power is intermittent (i.e.,

it does not work at night and cannot serve baseload when the sun is not shining), and the

efficiency of collectors varies greatly with weather conditions. A solar-powered alternative will

require energy storage or a backup power supply to provide electric power at night. Given the

challenges in meeting baseload requirements, the NRC staff did not evaluate solar power as an

alternative to license renewal of TMI-1.

8.6.5 Wood Waste

In 1999, DOE researchers estimated that Pennsylvania has biomass fuel resources consisting

of urban, mill, agricultural, and forest residues, as well as speculative potential for energy crops.

Excluding potential energy crops, DOE researchers projected that Pennsylvania had 5,090,000

tons (4,617,570 metric tons) of plant-based biomass available at $50 per ton delivered (Walsh

et al. 2000; costs are in 1995 dollars). The Bioenergy Feedstock Development Program at Oak

Ridge National Laboratory estimated that each air-dry pound of wood residue produces

approximately 6,400 Btu of heat (ORNL 2007). Assuming a 33 percent conversion efficiency,

using all biomass available in Pennsylvania at $50 per ton-the maximum price the researchers

considered-would generate roughly 6.3 terawatt hours of electricity. This is roughly the same

as the amount of electrical energy produced by TMI-1 operating at 85 percent capacity for one

year.

Walsh et al. (2000), go on to note that these estimates of biomass capacity contain substantial

uncertainty, and that potential availability does not mean biomass will actually be available at

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the prices indicated or that resources will be usably free of contamination. Some of these plant

wastes already have reuse value, and would likely be more costly to deliver because of

competition. Others, such as forest residues, may prove unsafe and unsustainable to harvest on

a regular basis. As a result, the available resource potential is likely less than the estimated

totals in Walsh et al., and the total resource is not likely to be sufficient to substitute for the

capacity provided by TMI-1. As a result, the NRC staff has not considered a wood-fired

alternative to TMI-1 license renewal.

8.6.6 Conventional Hydroelectric Power

According to researchers at Idaho National Energy and Environmental Laboratory,

Pennsylvania has an estimated 2,217 MW of technically available, undeveloped hydroelectric

resources at 104 sites throughout the State (INEEL 1997). This amount occurs primarily in small

installations generating 10 MWe or less, though one site in Pennsylvania is capable of providing

at least 100 MWe. These sites are scattered widely across the state, with a significant number

in the Susquehanna River Basin region. The NRC staff notes that the total available hydropower

potential is greater than the capacity considered for the other alternatives to license renewal of

TMI-1, although INEEL indicates that many sites may not be available for development for a

variety of reasons. Given the large numbers of individual installations needed to replace the

TMI-1 capacity and the uncertainty surrounding available resource potential, the NRC staff did

not evaluate hydropower as an alternative to license renewal. The NRC does, however,

consider that the portion of this potential capacity that is available through uprates at existing

hydroelectric facilities could play a role in a combination alternative in Section 8.4.

8.6.7 Wave and Ocean Energy

Wave and ocean energy has generated considerable interest in recent years. Ocean waves,

currents, and tides are often predictable and reliable. Ocean currents flow consistently, while

tides can be predicted months and years in advance with well-known behavior in most coastal

areas. Most of these technologies are in relatively early stages of development, and while some

results have been promising, they are not likely to be able to replace the capacity of TMI-1 by

the time its license expires. The NRC staff has previously evaluated the potential for wave or

ocean energy to provide an alternative to license renewal for the Oyster Creek Nuclear

Generating Station (OCNGS) in New Jersey, also part of PJM and located on the coast. In

2007, the NRC staff concluded that wave and ocean energy could not provide a feasible

alternative to license renewal at OCNGS, a smaller plant than TMI-1 (NRC 2007)..While testing

of new technologies to produce electricity from the ocean continues, the NRC has not yet seen

technological advances significant enough to consider wave and ocean energy as an alternative

to TMI-1 license renewal.

8.6.8 Geothermal Power

Geothermal energy has an average capacity factor of 90 percent and can be used for baseload

power where available. However, geothermal electric generation is limited by the geographical

availability of geothermal resources (NRC 1996). As illustrated by Figure 8.4 in the GElS, no

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feasible eastern location for geothermal capacity exists to serve as an alternative to TMI-I. The

NRC staff concluded that geothermal energy is not a reasonable alternative to license renewal

at TMI-1.

8.6.9 Municipal Solid Waste

Municipal solid waste combustors incinerate waste to produce steam, hot water, or electricity.

Combustors use three types of technologies-mass burn, modular, and refuse-derived fuel.

Mass burning is currently the method used most frequently in the United States and involves no

(or little) sorting, shredding, or separation. Consequently, toxic or hazardous components

present in the waste stream are combusted, and toxic constituents are exhausted to the air or

become part of the resulting solid wastes. Currently, approximately 89 waste-to-energy plants

operate in the United States. These plants generate approximately 2,700 MWe, or an average

of approximately 30 MWe per plant (Integrated Waste Services Association 2007). More than

25 average-sized plants will be necessary to provide the same level of output as the other

alternatives to TMI-1 license renewal.

Estimates in the GElS suggest that the overall level of construction impact from a waste-fired

plant will be approximately the same as that for a coal-fired power plant. Additionally, wastefired plants have the same or greater operational impacts than coal-fired technologies (including

impacts on the aquatic environment, air, and waste disposal). The initial capital costs for

municipal solid-waste plants are greater than for comparable steam-turbine technology at coalfired facilities or at wood-waste facilities because of the need for specialized waste separation

and handling equipment (NRC 1996).

The decision to burn municipal waste to generate energy is usually driven by the need for an

alternative to landfills rather than energy considerations. The use of landfills as a waste disposal

option is likely to increase in the near term as energy prices increase; however, it is possible

that municipal waste combustion facilities may become attractive again.

Regulatory structures that once supported municipal solid waste incineration no longer exist.

For example, the Tax Reform Act of 1986 made capital-intensive projects such as municipal

waste combustion facilities more expensive relative to less capital-intensive waste disposal

alternatives such as landfills. Also, the 1994 Supreme Court decision C&A Carbone, Inc. v.

Town of Clarkstown, New York, struck down local flow control ordinances that required waste to

be delivered to specific municipal waste combustion facilities rather than landfills that may have

had lower fees. In addition, environmental regulations have increased the capital cost necessary

to construct and maintain municipal waste combustion facilities.

Given the small average installed size of municipal solid waste plants and the unfavorable

regulatory environment, the NRC staff does not consider municipal solid waste combustion to

be a feasible alternative to TMI-1 license renewal.

8.6.10 Biofuels

In addition to wood and municipal solid-waste fuels, there are other concepts for biomass-fired

electric generators, including direct burning of energy crops, conversion to liquid biofuels, and

NUREG-1437, Supplement 37 8-40 June 2009
Alternatives

biomass gasification. In the GELS, the NRC staff indicated that none of these technologies had

progressed to the point of being competitive on a large scale or of being reliable enough to

replace a baseload plant such as TMI-1. After reevaluating current technologies, the NRC staff

believes other biomass-fired alternatives are still unable to reliably replace the TMI-1 capacity.

For this reason, the NRC staff does not consider other biomass-derived fuels to be feasible

alternatives to TMI-1 license renewal.

8.6.11 Oil-Fired Power

EIA projects that oil-fired plants will account for very little of the new generation capacity

constructed in the United States during the 2007 to 2030 time period. Further, EIA does not

project that oil-fired power will account for any significant additions to capacity (EIA 2008a).

The variable costs of oil-fired generation tend to be greater than those of the nuclear or coalfired options, and oil-fired generation tends to have greater environmental impacts than naturalgas-fired generation. In addition, future increases in oil prices are expected to make oil-fired

generation increasingly more expensive. The high cost of oil has prompted a steady decline in

its use for electricity generation. Thus the NRC staff did not consider oil-fired generation as an

alternative to TMI-1 license renewal.

8.6.12 Fuel Cells

Fuel cells oxidize fuels without combustion and its environmental side effects. Power is

produced electrochemically by passing a hydrogen-rich fuel over an anode and air (or oxygen)

over a cathode and separating the two by an electrolyte. The only byproducts (depending on

fuel characteristics) are heat, water, and C02. Hydrogen fuel can come from a variety of

hydrocarbon resources by subjecting them to steam under pressure. Natural gas is typically

used as the source of hydrogen.

At the present time, fuel cells are not economically or technologically competitive with other

alternatives for baseload electricity generation. EIA projects that fuel cells may cost $5,374 per

installed kW (total overnight costs) (EIA 2008b), or 3.5 times the construction cost of new coalfired capacity and 7.5 times the cost of new, advanced gas-fired, combined-cycle capacity. In

addition, fuel cell units are likely to be small in size (the EIA reference plant is 10 MWe). While it

may be possible to use a distributed array of fuel cells to provide an alternative to TMI-1, it

would be extremely costly to do so. Accordingly, the NRC staff does not consider fuel cells to be

an alternative to TMI-1 license renewal.

8.6.13 Delayed Retirement

Neither Exelon Generation nor its parent company, Exelon, has any plans to retire generating

capacity within PJM (AmerGen 2008). As a result, delayed retirement is not a feasible

alternative to license renewal. Other generation capacity may be retired within PJM prior to the

expiration of the TMI-1 license, but this capacity is likely to be older, less efficient, and without

modern emissions controls.

June 2009 8-41 NUREG-1437, Supplement 37
Alternatives

8.7 No-Action Alternative

This section will examine the environmental effects that will occur if NRC takes no action. No

action in this case means that the NRC does not issue a renewed operating license for TMI-1,

and the license expires at the end of the current license term, in April 2014. If the NRC takes no

action, the plant will shutdown at or before the end ,of the current license. After shutdown, plant

operators will initiate decommissioning according to 10 CFR 50.82, "Termination of License."

Table 8-5 below contains a summary of the environmental impacts of the no-action alternative

compared to continued operation of TMI-1.

We note that no action is the only alternative that we consider in-depth that does not satisfy the

purpose and need for this supplemental EIS, because it does not provide power generation

capacity. Furthermore, it would not meet the needs currently met by TMI-1, or the alternatives

evaluated in sections 8.1 through 8.4. Assuming that a need currently exists for the power

generated by TMI-1, the no-action alternative would require the appropriate energy planning

decisionmakers to rely on an alternative to replace the capacity of TMI-1 or reduce the need for

power.

In this section, we address only those impacts that arise directly as a result of plant shutdown.

The NRC already addressed- in several other documents- environmental impacts from

decommissioning and related activities. These documents include the Final Generic

Environmental Impact Statement on Decommissioning of Nuclear Facilities, NUREG 0586,

Supplement 1 (NRC 2002); the license renewal GElS (Chapter 7; NRC 1996); and Chapter 7 of

this supplemental EIS. These analyses either directly address or bound the environmental

impacts of decommissioning whenever Exelon Generation ceases operating TMI-1.

We note that, even with a renewed operating license, TMI-1 will eventually shut down, and the

environmental effects we address in this section will occur at that time. Since these effects have

not otherwise been addressed in this supplemental EIS, we will address the impacts in this

section. We expect that- as with decommissioning effects- shutdown effects will be similar

whether they occur at the end of the current license or at the end of a renewed license.

Table 8-5. Summary of Environmental Impacts of the No Action Alternative

Compared to Continued Operation of TMI-1.

No Action Continued TMI-1

At TMI-1 site At alternate site Operation

Air Quality SMALL N/A SMALL

Ground Water SMALL N/A SMALL

Surface Water SMALL N/A SMALL

Aquatic and Terrestrial SMALL N/A SMALL

Resources

Human Health SMALL N/A SMALL

Socioeconomics SMALL to MOEAEN/A SMALL

MODERATE

Waste Management SMALL N/A N/A

NUREG-1437, Supplement 37 8-42 June 2009
Alternatives

8.7.1 Air Quality

When the plant stops operating, there will be a reduction in emissions from activities related to

plant operation, such as use of diesel generators and employees' vehicles. In Chapter 4, the

NRC staff determined that these emissions would have a SMALL impact on air quality during

the renewal term. Therefore, if the emissions decrease, the impact to air quality would also

decrease and would be SMALL.

8.7.2 Ground Water Use and Quality

The use of ground water would diminish as plant personnel are removed from the site and

operations cease. Some consumption of ground water may continue as a small staff remains

onsite to maintain facilities prior to decommissioning. Overall impacts would be smaller than

during operations, but would remain SMALL.

8.7.3 Surface Water Use and Quality

The rate of consumptive use of surface water would decrease as the plant is shut down and the

reactor cooling system continues to remove the heat of decay. Wastewater discharges would

also be reduced considerably. Shutdown would reduce the already SMALL impact on surface

water resources and quality.

8.7.4 Aquatic and Terrestrial Ecology

Terrestrial Ecologqy

Terrestrial ecology impacts would be SMALL. No additional land disturbances on or offsite

would occur.

Aquatic Ecolocy

If the plant were to cease operating, impacts to aquatic ecology would decrease, as the plant

would withdraw and discharge less water than it does during operations. Shutdown would

reduce the already SMALL impacts to aquatic ecology.

8.7.5 Human Health

Human health risks would be smaller following plant shutdown. The plant, which is currently

operating within regulatory limits, would emit less gaseous and liquid radioactive material to the

environment. In addition, following shutdown, the variety of potential accidents at the plant

(radiological or industrial) would be reduced to a limited set associated with shutdown events

and fuel handling and storage. In Chapter 4 of this supplemental EIS, the NRC staff concluded

that the impacts of continued plant operation on human health would be SMALL. In Chapter 5,

the NRC staff concluded that the impacts of accidents during operation were SMALL. Therefore,

as radioactive emissions to the environment decrease, and as the likelihood and variety of

June 2009 8-43 NUREG-1437, Supplement 37
Alternatives

accidents decrease following shutdown, the NRC staff concludes that the risks to human health

following plant shutdown would be SMALL.

In addition, the no-action alternative would require TMI-1 to initiate decommissioning activities.

Environmental impacts from the activities associated with the decommissioning of any reactor

before or at the end of an initial or renewed license are evaluated in the Generic Environmental

Impact Statement for Decommissioning of Nuclear Facilities: Supplement 1, Regarding the

Decommissioning of Nuclear Power Reactors, NUREG-0586, Supplement 1 (NRC 2002). The

NRC's evaluation of the environmental impacts of decommissioning presented in NUREG-0586,

Supplement 1, identifies a range of impacts for each environmental issue including human

health risks. Based on information in the GElS (NRC 1996) along with the information in

Chapter 7 of this supplemental EIS, the Commission found that doses to the public will be well

below applicable regulatory standards regardless of which decommissioning method is used.

Occupational doses would increase no more than 1 person-rem caused by buildup of long-lived

radionuclides during the license renewal term. Therefore, the human health risks to an

occupational worker and to a member of the public, from the decommissioning of TMI-1, due to

the no-action alternative, would be SMALL.

8.7.6 Socioeconomics

Land Use

Plant shutdown will not affect onsite land use. Plant structures and other facilities will likely

remain in place until decommissioning. Most transmission lines at TMI-i will remain in service

after the plant stops operating. Maintenance of most existing transmission lines will continue as

before. The NRC staff expects the impacts on land use from plant shutdown to be SMALL.

Socioeconomics

Plant shutdown will have a minimal impact on socioeconomic conditions in the region around

TMI-1, primarily because of the plant's proximity to the Harrisburg-Carlisle metropolitan

statistical area and its relatively small contribution to local services. Plant shutdown will

eliminate up to 525-695 jobs and will reduce tax revenue in the region, though 'the TMI-1

contributions to local taxing jurisdictions are a small percentage of total revenue for each of the

jurisdictions discussed in Chapter 4 of this supplemental EIS. The loss of these contributions,

which may not entirely cease until after decommissioning, will have a SMALL impact, although

job losses could increase the impact level slightly. Overall, the staff expects the impacts of plant

shutdown to be SMALL to MODERATE. See Appendix J to NUREG 0586, Supplement 1 (NRC

2002), for additional discussion of the potential socioeconomic impacts of plant

decommissioning.

Transportation

Traffic volumes on the roads in the vicinity of TMI-1 will decline after plant shutdown. Most of the

reduction in traffic volume will be associated with the loss of jobs. The shipment of material to

and from the plant will be reduced before decommissioning. Transportation impacts will be

SMALL as a result of plant shutdown. Transportation impacts will increase if a new reactor or

alternative energy facility is constructed on the TMI-1 site or in the immediate vicinity. Such

impacts will be SMALL to MODERATE, but of short duration.

NUREG-1 437, Supplement 37 8-44 June 2009
Alternatives

Aesthetics

Plant structures and other facilities will likely remain in place until decommissioning, although

plumes from the plant's cooling towers are likely to disappear entirely. Noise caused by plant

operation will cease. The NRC staff concludes that the aesthetic impacts of plant closure will be

SMALL.

Historic and Archaeological Resources

Impacts from the no-action alternative would be SMALL, since TMI-1 would be decommissioned

with no alternative power plant to replace it. A separate environmental review would be

conducted for decommissioning. That assessment will address the protection of historic and

archaeological resources.

Environmental Justice

Plant shutdown is unlikely to disproportionately affect minority and low-income populations.

Impacts to all other resource areas would be SMALL to MODERATE. The communities in the

immediate vicinity of TMI-1 do not have large populations of minority or low-income residents.

Minority and low-income populations are generally concentrated in the urban areas of

Harrisburg, Lancaster, and York. Thus, impacts from plant shutdown are likely to be SMALL.

See Appendix J of NUREG 0586, Supplement 1 (NRC 2002), for additional discussion of these

impacts.

8.7.7 Waste Management

After implementation of the no-action alternative, generation of high-level waste would stop and

generation of low-level and mixed waste would decrease. Impacts from implementation of the

no-action alternative are expected to be SMALL.

8.8 Alternatives Summary

In this chapter, we considered the following alternatives to TMI-1 license renewal: supercritical

coal-fired generation, natural gas combined-cycle generation, energy conservation and energy

efficiency, and a combination alternative. We also considered no action by the NRC and the

effects it would have. The impacts for all alternatives are summarized in Table 8-6 on page 8-

47.

The environmental impacts of the proposed action (issuing a renewed TMI-1 operating license)

would be SMALL for all impact categories, except for the Category 1 issues of collective offsite

radiological impacts from the fuel cycle, high level waste (HLW), and spent fuel disposal. The

NRC staff did not assign a single significant level to these impacts, but the Commission

determined them to be Category 1 issues nonetheless.

The coal-fired alternative is the least environmentally favorable alternative due to impacts to air

quality from nitrogen oxides, sulfur oxides, particulate matter, PAHs, carbon monoxide, carbon

dioxide, and mercury (and the corresponding human health impacts); and construction impacts

to aquatic, terrestrial, and potential historic and archaeological resources. The gas-fired

June 2009 8-45 NUREG-1437, Supplement 37
Alternatives

alternative would have slightly lower air emissions, and impacts to aquatic, terrestrial, and

historic and archaeological resources would vary depending upon location of the plant.

Purchased power would likely have operational impacts that would include aspects of coal-fired,

gas-fired, and existing nuclear generation.

The NRC notes that the energy conservation/energy efficiency alternative has SMALL impacts

in all categories evaluated, and upon shut down of TMI-1, current operating impacts of TMI-1

would cease. Therefore, the energy conservation/energy efficiency alternative is the

environmentally preferred alternative to license renewal. All other alternatives capable of

meeting the needs currently served by TMI-1 entail potentially greater impacts than the

proposed action of license renewal of TMI-1. The no-action alternative does not meet the

purpose and need of this supplemental EIS, however if it triggers the energy

conservation/energy efficiency action to replace the capacity currently supplied by TMI-1, it

could result in an overall SMALL impact, as well.

NUREG-1437, Supplement 37 8-46 June 2009
Alternatives

Table 8-6. Summary of Environmental Impacts of Selected Alternatives

Compared to Continued Operation of TMI-1.

Impact Area

4-- 4- )

0- Eo

Alternative 2: o 0

License Renewal SMALL SMALL SMALL SMALL SMALL SMALL SMALL

Supercritical coal-fired MDRT M toSMALLt L 

alternative at a new site MODERATE SMALL SMALL toAS MODERATE LARGE MODERATE LARGEMOETE LRE MDAE

Gas-fired alternative MODERATE SMALL SMALL SMALL SMALL SMALL to SMALL

at the TMI-1 site MODERATE

SMALL Gas-fired alternative MODERATE SMALL SMALL to SMALL SMALL to SMALL

at a new site LARGE MODERATE

Energy Conservation/ SMALL SMALL SMALL SMALL SMALL SMALL SMALL

Energy Efficiency

Combination of SMALL to Alternatives MODERATE SMALL SMALL SMALL SMALL MODERATE SMALL

No Action Alternative SMALL SMALL SMALL SMALL SMALL SMALL to SMALL MODERATE

8.9 References

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

Production and Utilization Facilities."

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

Regulations for Domestic Licensing and Related Regulatory Functions."

June 2009 8-47 NUREG-1437, Supplement 37
Alternatives

36 CFR 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, Part

800, "Protection of Historic Properties."

36 CFR Part 60. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property,

Part 60, Section 4, "Criteria for Evaluation."

40 CFR 51. Code of Federal Regulations, Title 40, Protection of Environment, Part 51,

"Requirements for Preparation, Adoption, and Submittal of Implementation Plans."

40 CFR 60. Code of Federal Regulations, Title 40, Protection of Environment, Part 60,

"Standards of Performance for New Stationary Sources."

63 FR 49442. Environmental Protection Agency, Washington, D.C, "Revision of Standards of

Performance for Nitrogen Oxide Emissions From New Fossil-Fuel Fired Steam Generating

Units; Revisions to Reporting Requirements for Standards of Performance for New Fossil-Fuel

Fired Steam Generating Units." Federal Register Vol. 63, NO. 179, pp. 49422-49455.

September 16, 1998.

64 FR 35714. Environmental Protection Agency, Washington, D.C, "40 CFR Part 51, Regional

Haze Regulations, Final Rule." Federal Register Vol. 64, No. 126, pp. 35714-35774. July 1,

1999.

65 FR 32214. Environmental Protection Agency, Washington, D.C., "40 CFR Part 261, Notice of

Regulatory Determination on Wastes from the Combustion of Fossil Fuels." Federal Register

Vol. 65, No. 99, pp. 32214-32237. May 22, 2000.

ACAA (American Coal Ash Association). 2007. "ACAA Releases 2006 CCP Production and Use

Survey." August. Aurora, CO. Available URL: http://www.acaausa.org/associations/8003/files/2006 CCP Survey (Final-8-24-07).pdf (accessed October 14,

2008). ADAMS No. ML082880731.

Air Pollution Control Act. 35 P.S. §§ 4001-4015. Pennsylvania Statutes, Title 35, Health and

Safety, Chapter 23, "Air Pollution."

AmerGen (AmerGen Energy Company, LLC). 2008. "Three Mile Island Nuclear Station,

Applicant's Environmental Report, License Renewal Operating Stage." Kennett Square, PA.

ADAMS Nos. ML080220255, ML080220257, ML080220261, and ML080220282.

ATSDR (Agency for Toxic Substances and Disease Registry). 1995. Toxicological Profile for

Polycyclic Aromatic Hydrocarbons (PAHs). Public Health Service, U.S. Department of Health

and Human Services, Atlanta, GA.

ATSDR (Agency for Toxic Substances and Disease Registry). 1999. Toxicological Profile for

Mercury. Public Health Service, U.S. Department of Health and Human Services. Atlanta, GA.

California Environmental Protection Agency (CaIEPA). 1997. Air Toxics Hot Spots Program Risk

Assessment Guidelines: Technical Support Document for Determining Cancer Potency Factors.

Draft for Public Comment. Office of Environmental Health Hazard Assessment. Berkeley, CA.

Clean Air Act. 42 U.S.C. 7401, et seq. United States Code, Title 42, The Public Health and

Welfare, Chapter 85, "Air Pollution Prevention and Control."

NUREG-1437, Supplement 37 8-48 June 2009
Alternatives

Darby, S. C. December 1989. "Health Risks of Radon and Other Internally Deposited Alpha

Emitters-BEIR IV". Biometrics 45 (4): 1341-1342. National Research Council.

DOE (U.S. Department of Energy). 2008. "Installed U.S. Wind Capacity and Wind Project

Locations." Interactive Maps. February 26, 2008. Available URL:

http://www.eere.enerqy..qov/windandhydro/windpoweringamerica/wind installed capacity.asp

(accessed April 18, 2008).

EIA (Energy Information Administration). 2006. "Cost and Quality of Fuel for Electric Plants,

2004 and 2005." DOE/EIA 0191(2006). Washington, D.C. Available URL:

http://www*eia.doe.qov/cneaf/electricity/cq/cqa2005.pdf (accessed March 16, 2007). ADAMS

No. ML082880730.

EIA (U.S. Department of Energy, Energy Information Administration). 2007. "Summary Statistics

for the United States." Table ES1 from Electric Power Annual with data for 2006. Accessed at:

http:l/www.eia.doe.qov/cneaf/electricity/epa/epates.html (accessed June 11, 2008). ADAMS No.

ML082880730.

EIA (U.S. Department of Energy, Energy Information Administration). 2008a. Annual Energy

Outlook 2008 With Projections to 2030. DOE/EIA 0383(2008). Washington, D.C. Available URL:

http://tonto.eia.doe.qov/FTPROOT/forecastinq/0383(2008).pdf (accessed July 18, 2008).

ADAMS No. ML082880730.

EIA (Energy Information Administration. 2008b. Assumptions to the Annual Energy Outlook

2008 With Projections to 2030. DOE/EIA 0554(2008). Washington, D.C. Available URL:

http:l//tonto.eia.doe.gov/FTPROOT/forecastinq/0554(2007).pdf (accessed July 22, 2008).

ADAMS No. ML082880730.

EPA (U.S. Environmental Protection Agency). 1997. Mercury Study Report to Congress.

Volume V: Health Effects of Mercury and Mercury Compounds. Office of Air Quality Planning

and Standards, Office of Research and Development. Washington, D.C.

EPA (U.S. Environmental Protection Agency). 1998. Compilation of Air Pollutant Emission

Factors, Volume 1: Stationary Point and Area Sources: AP 42, Fifth Edition. "Section 1.1:

Bituminous and Subbituminous Coal Combustion: Final Section Supplement E." Washington,

D.C..

EPA (U.S. Environmental Protection Agency). 1999a. Integrated Risk Information System (IRIS)

on Polycyclic Organic Matter. National Center for Environmental Assessment, Office of

Research and Development. Washington, D.C.

EPA (U.S. Environmental Protection Agency). 1999b. Integrated Risk Information System (IRIS)

on Benzo(a)pyrene. National Center for Environmental Assessment, Office of Research and

Development. Washington, D.C.

EPA (U.S. Environmental Protection Agency). 1999c. Integrated Risk Information System (IRIS)

on Benz[alanthracene. National Center for Environmental Assessment, Office of Research and

Development. Washington, D.C.

EPA (U.S. Environmental Protection Agency). 1999d. Integrated Risk Information System (IRIS)

on Methyl mercury. National Center for Environmental Assessment, Office of Research and

Development. Washington, D.C.

June 2009 8-49 NUREG-1437, Supplement 37
Alternatives

EPA (U.S. Environmental Protection Agency). 2000. "Regulatory Finding on the Emissions of

Hazardous Air Pollutants from Electric Utility Steam Generating Units." Federal Register, Vol.

65, No. 245, pp. 79825-79831. Washington, DC. December 20, 2000.

EPA (U.S. Environmental Protection Agency). 2005. "Regional and State SO2 and NOx

Emissions Budgets." March. Washington, D.C. Available URL:

http://www.epa.gov/cair/pdfs/finaltech06.pdf (accessed October 12, 2008). ADAMS No.

ML082880732.

EPA (U.S. Environmental Protection Agency). 2007. "Clean Air Mercury Rule." Available URL:

http://www.epa..ov/air/mercurvrule/ (accessed July 9, 2007). ADAMS No. ML082880732.

EPA (U.S. Environmental Protection Agency). 2008a. "Nitrogen Oxide." Available URL:

http://www.epa.,qov/air/urbanair/nox/hlth.html (accessed July 19, 2008). ADAMS No.

ML082880732.

EPA (U.S. Environmental Protection Agency). 2008b. "Radon Exposure." Available URL:

http://www.epa.,qov/radon/healthrisks.html (accessed July 19, 2008). ADAMS No.

ML082880732.

EPA (U.S. Environmental Protection Agency). 2008c. "Sulfur Dioxides." Available URL:

http://www.epa.qov/air/urbanair/so2/ (accessed July 19, 2008). ADAMS No. ML082880732.

Gabbard, A. 1993. "Coal Combustion: Nuclear Resource or Danger." Oak Ridge National

Laboratory Review. Oak Ridge National Laboratory, Oak Ridge, TN. Summer/ Fall 1993.

Available URL: http://www.ornl.qov/ORNLReview/rev26-34/text/colmain.html (accessed May 23,

2007). ADAMS No. ML082880731.

GE (General Electric). 2007. "Gas Turbine and Combined Cycle Products." May 2007. Available

URL: http://www.qepower.com/prod serv/products/gas turbines cc/en/downloads/

.asturbine cc products.pdf (accessed April 14, 2008). ADAMS No. ML082880731.

HHS (U.S. Department of Health and Human Services). 1993. Hazardous Substances Data

Bank. National Toxicology Information Program, National Library of Medicine. Bethesda, MD.

INEEL (Idaho National Engineering and Environmental Laboratory). 1997, "U.S. Hydropower

Resource Assessment for Pennsylvania." DOE/ID-10430(PA). Idaho Falls, ID. (December

1997). Available URL: http://hydropower.inl.qov/resourceassessment/pdfs/states/pa.pdf

(accessed March 20, 2007). ADAMS No. ML082880730.

Integrated Waste Services Association. 2007. "Waste-to-Energy and the Production Tax Credit."

Washington, DC. Available URL: http://www.wte.orqg/docs/FactSheetPTC.pdf (accessed May

24, 2007). ADAMS No. ML083050223.

NAS (National Academy of Sciences). 2005. Health Risks from Exposure to Low Levels of

Ionizing Radiation: Biological Effects of Ionizing Radiation (BEIR) VII, Phase 2, Seventh Ed.

Washington, D.C.

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

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

ADAMS No. ML061770605.

NUREG-1 437, Supplement 37 8-50 June 2009
Alternatives

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

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

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

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

NRC (U.S. Nuclear Regulatory Commission). 2002. Generic Environmental Impact Statement

on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of

Nuclear Power Reactors. NUREG-0586, Supplement 1, Volumes 1 and 2. Washington, D.C.

NRC (U.S. Nuclear Regulatory Commission). 2007. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants, Supplement 28, Regarding Oyster Creek Nuclear

Generating Station, Final Report - Main Report. Washington, D.C.

NREL (National Renewable Energy Laboratory). 2008. "United States Atlas of Renewable

Resources." Interactive Map. Available URL:

http://mapserve2.nrel.gov/website/Resource Atlas/viewer.htm (accessed April 18, 2008).

Nucleonics Week. 2008. "US new reactors more likely online in 2016 and beyond, NEI official

says." Vol. 49, No. 15. April 10, 2008.

OMB (U.S. Office of Management and Budget). 2007. ExpectMore.gov. "Detailed Information on

the Low Income Home Energy Assistance Program Assessment." Available URL:

http://www.whitehouse.qov/omb/expectmore/detail/10001059.2003.html (accessed July 10,

2007). ADAMS No. ML082880730.

ORNL (Oak Ridge National Laboratory). 2007. "Bioenergy Conversion Factors." Available URL: http:lbioener~qy.ornl.,qovlpaperslmisclenerqy conv.html (accessed November 6, 2007).

ADAMS No. ML083050223.

Pace University Center for Environmental Legal Studies, Environmental Cost of Energy,

Oceana Publications, NY, 1991.

PADEP (Pennsylvania Department of Environmental Protection). 2008. "Pennsylvania's Clear

Air Plans." Available URL:

http://www.dep.state.pa.us/dep/deputate/airwaste/aq/plans/Clean air plans.htm (accessed

October 12, 2008). ADAMS No. ML082880732.

PJM (PJM Interconnection, Inc.). 2008. 2007 State of the Market Report, Volume 1:

Introduction. March. Available U RL: http://www2.pim.com/mnarkets/marketmonitor/downloads/mmu-reports/2007-som-volumel.pdf (accessed October 24, 2008). ADAMS

No. ML083050232.

Pletka, R. 2004. "Potential Impact of an Advanced Energy Portfolio Standard in Pennsylvania."

Presented at NREL Energy Analysis Forum, November 9, 2004. Available URL:

http://www.nrel.-qov/analysis/forum/docs/2004/pletka.ppt (accessed March 19, 2009). ADAMS

No. ML090780880.

USGS (U.S. Geological Survey). 1997. "Radioactive Elements in Coal and Fly Ash: Abundance,

Forms, and Environmental Significance; USGS Fact Sheet FS-163-97." Available URL:

http://qreenwood.cr.usqs..ov/enerqy/factshts/163-97/FS-163-97. pdf (accessed May 22, 2007).

ADAMS No. ML082880731.

June 2009 8-51 J NUREG-1 437, Supplement 37
Alternatives

Walsh et al. (Walsh, M.E., R.L. Perlack, A. Turhollow, D. de la Torre Ugarte, D.A. Becker, R.L.

Graham, S.A. Slinsky, and D.E. Ray). 2000. "Biomass Feedstock Availability in the United

States: 1999 State Level Analysis." Available URL:

hftp://bioenerqy.ornl.qov/resourcedata/index.html (accessed May 22, 2007). ADAMS No.

ML083050223.

NUREG-1437, Supplement 37 8-52 June 2009
9.0 CONCLUSION

This supplemental environmental impact statement (EIS) contains the preliminary environmental

review of Exelon Generation Company, LLC's (Exelon Generation's) application for a renewed

operating license for Three Mile Island Nuclear Station, Unit 1 (TMI-1) as required by Part 51 of

Title 10, of the Code of Federal Regulations (10 CFR Part 51), the NRC's regulations that

implement the National Environmental Policy Act (NEPA). Chapter 9 presents the conclusions

and recommendations from the site-specific environmental review of TMI-1 and summarizes

site-specific environmental issues of license renewal that were identified during the review. The

environmental impacts of license renewal are summarized in Section 9.1; a comparison of the

environmental impacts of license renewal and energy alternatives is presented in Section 9.2;

unavoidable impacts of license renewal and energy alternatives and resource commitments are

discussed in Section 9.3; and conclusions and NRC staff recommendations are presented in

Section 9.4.

9.1 Environmental Impacts of License Renewal

Our review of site-specific environmental issues in this supplemental EIS leads us to conclude

that issuing a renewed license would have SMALL impacts for the 21 Category 2 issues

applicable to license renewal and refurbishment at TMI-1, as well as environmental justice and

chronic effects of electromagnetic fields.

Mitigation measures were considered for each Category 2 issue, as applicable. For ground

water and surface water use issues, current measures to mitigate the environmental impacts of

plant operation were found to be adequate. Potential mitigation measures for reducing impacts

from thermophilic microbiological organisms resulting from TMI-I's thermal discharge include

periodically monitoring for thermophilic microbiological organisms in the water and sediments

near the discharge, and prohibiting recreational use near the discharge plume. The staff

identified a variety of measures that could mitigate potential acute electromagnetic field impacts

resulting from continued operation of the TMI-1 transmission lines, including limiting public

access to transmission line structures, installing signs at road crossings to warn against idling,

and increasing transmission line clearances.

Mitigation measures that could reduce impacts to the terrestrial environment and threatened

and endangered species during refurbishment activities include installing silt fences to minimize

sediment transport, the use of best management practices, and restoring cleared land that

remains after completion of construction. Mitigation measures to reduce potential air quality

impacts resulting from refurbishment activities include implementation of best management

practices for dust control to minimize emissions from construction activities, and the use of

staggered workforce shift changes to reduce the number of vehicles on the road at any one

given time.

No impacts to known historic and archaeological resources are expected from the continued

operation of TMI-1 during the license renewal term. However, TMI-1 is situated in an

archaeologically sensitive area and impact to archaeological resources is possible. Since

publication of the draft supplemental EIS, Exelon Generation has revised its review procedures

June 2009 9-1 NUREG-1437, Supplement 37
Conclusion

for onsite ground disturbing activities to provide guidance regarding the protection of historic

and archaeological resources, and has implemented a stop work provision if these resources

are inadvertently discovered. Exelon Generation further mitigated the NRC finding of SMALL

impact in the draft supplemental EIS by committing to develop and implement a cultural

resources management plan (CRMP) and by training staff in the Section 106 process. Lands

not previously surveyed should be investigated by a professional archaeologist prior to ground

disturbance. In addition, the historical farmstead site (36Da235) should be recorded and

evaluated for eligibility.

The NRC also considered cumulative impacts of past, present, and reasonably foreseeable

future actions, regardless of what agency (Federal or non-Federal) or person undertakes them.

The staff concluded that cumulative impacts of TMI-1 license renewal and refurbishment would

be SMALL for potentially affected resources.

9.2 Comparison of Environmental Impacts of License Renewal and Alternatives'

In the conclusion to Chapter 8, we determined that impacts from license renewal are generally

less than the impacts of alternatives to license renewal, with the exception of energy -

conservation and energy efficiency. In comparing likely environmental impacts from supercritical

coal-fired generation, natural gas combined-cycle generation, energy conservation and energy

efficiency, and a combination alternative that included natural gas, conservation/efficiency, and

uprates to existing hydroelectric dams, to environmental impacts from license renewal, we found

that the energy conservation and energy efficiency alternative would result in the lowest

environmental impact. Based on our analysis, we found that the impacts of license renewal are

reasonable in light of the impacts from alternatives to the license renewal of TMI-1.

9.3 Resource Commitments

9.3.1 Unavoidable Adverse Environmental Impacts

Unavoidable adverse environmental impacts are impacts that would occur after implementation

of all feasible mitigation measures. Implementing any of the energy alternatives considered in

this supplemental EIS, including the proposed action, would result in some unavoidable adverse

environmental impacts.

Minor unavoidable adverse impacts on air quality would occur due to emission and release of

various chemical and radiological constituents from power plant operations. Nonradiological

emissions resulting from power plant operations are expected to comply with U.S.

Environmental Protection Agency (EPA) emissions standards, though the alternative of

operating a fossil-fueled power plant in some areas may worsen existing attainment issues.

Chemical and radiological emissions would not exceed the National Emission Standards for

Hazardous Air Pollutants.

During nuclear power plant operations, workers and members of the public would face

unavoidable exposure to radiation and hazardous and toxic chemicals. Workers would be

NUREG-1437, Supplement 37 9-2 June 2009
Conclusion

exposed to radiation and chemicals associated with routine plant operations and the handling of

nuclear fuel and waste material. Workers would have higher levels of exposure than members

of the public, but doses would be administratively controlled and would not exceed any

standards or administrative control limits. In comparison, the alternatives entailing the

construction and operation of a non-nuclear power generating facility would also result in

unavoidable exposure to hazardous and toxic chemicals to workers and the general public.

The generation of spent nuclear fuel and waste material, including low-level radioactive waste,

hazardous waste, and nonhazardous waste would also be unavoidable. In comparison,

hazardous and nonhazardous wastes would also be generated at non-nuclear power generating

facilities. Wastes generated during plant operations would be collected, stored, and shipped for

suitable treatment, recycling, or disposal in accordance with applicable Federal and State

regulations. Due to the costs of handling these materials, power plant operators would be

expected to conduct all activities and optimize all operations in a way that generates the

smallest amount of waste practical.

9.3.2 Relationship Between Local Short-Term Uses of the Environment and the

Maintenance and Enhancement of Long-Term Productivity

The operation of power generating facilities would result in short-term uses of the environment

as described in Chapters 4, 5, 6, 7, and 8. "Short term" is the period of time during which

continued power generating activities would take place.

Power plant operations would necessitate short-term use of the environment and commitments

of resources, and would also commit certain resources (e.g., land -and energy) indefinitely or

permanently. Certain short-term resource commitments would be substantially greater under

most energy alternatives, including license renewal, than under the No Action Alternative due to

the continued generation of electrical power as well as continued use of generating sites and

associated infrastructure. During operations, all energy alternatives would entail similar

relationships between local short-term uses of the environment and the maintenance and

enhancement of long-term productivity.

Air emissions from power plant operations would introduce small amounts of radiological and

nonradiological constituents to the region around the plant site. Over timethese emissions

would result in increased concentrations and exposure, but are not expected to impact air

quality or radiation exposure to the extent that public health and long-term productivity of the

environment would be impaired.

Continued employment, expenditures, and tax revenues generated during power plant

operations would directly benefit local, regional, and State economies over the short term. Local

governments investing project-generated tax revenues into infrastructure and other required

services could enhance economic productivity over the long term.

The management and disposal of spent nuclear fuel, low-level radioactive waste, hazardous

waste, and nonhazardous waste would require an increase in energy and would consume

space at treatment, storage, or disposal facilities. Regardless of the location, the use of land to

meet waste disposal needs would reduce the long-term productivity of the land.

June 2009 9-3 NUREG-1 437, Supplement 37 I
Conclusion

Power plant facilities would be committed to electricity production over the short term. After

decommissioning these facilities and restoring the area, the land could be available for other

future productive uses.

9.3.3 Irreversible and Irretrievable Commitments of Resources

This section describes the irreversible and irretrievable commitments of resources that have

been identified in this supplemental EIS. Irreversible resources refer to when primary or

secondary impacts limit the future options for a resource. An irretrievable commitment refers to

the use or consumption of resources that are neither renewable nor recoverable for future use.

Irreversible and irretrievable commitment of resources for electrical power generation would

include the commitment of land, water, energy, raw materials, and other natural and man-made

resources required for power plant operations. In general, the commitment of capital, energy,

labor, and material resources would also be irreversible.

The implementation of any of the energy alternatives considered in this supplemental EIS would

entail the irreversible and irretrievable commitment of energy, water, chemicals, and, in some

cases, fossil fuels. These resources would be committed during the license renewal term and

over the entire life cycle of the power plant and would essentially be unrecoverable.

Energy expended would be in the form of fuel for equipment, vehicles, and power plant

operations and electricity for equipment and facility operations. Electricity and fuels would be

purchased from offsite commercial sources. Water would be obtained from existing water supply

systems. These resources are readily available, and the amounts required are not expected to

deplete available supplies or exceed available system capacities.

The irreversible and irretrievable commitment of material resources includes materials that

cannot be recovered or recycled, materials that are rendered radioactive and cannot be

decontaminated, and materials consumed or reduced to unrecoverable forms of waste.

However, none of the resources used by these power generating facilities are in short supply,

and, for the most part, are readily available.

Various materials and chemicals, including acids and caustics, would be required to support

operations activities. These materials would be derived from commercial vendors, and their

consumption is not expected to affect local, regional, or national supplies.

The treatment, storage, and disposal of spent nuclear fuel, low-level radioactive waste,

hazardous waste, and nonhazardous waste would require the irretrievable commitment of

energy and fuel and would result in the irreversible commitment of space in disposal facilities.

9.4 Recommendations

Based on (1) the analysis and findings in the GElS; (2) information provided in the

Environmental Report submitted by Exelon Generation; (3) consultation with Federal, State, and

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

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

supplemental EIS public comment period, the NRC has determined that the adverse

NUREG-1437, Supplement 37 9-4 June 2009
Conclusion

environmental impacts of license renewal for TMI-1 are not so great that preserving the option

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

I June 2009 9-5 NUREG-1437, Supplement 37

10.0 LIST OF PREPARERS

This supplemental EIS was prepared by members of the Office of Nuclear Reactor Regulation,

with assistance from other NRC organizations and contract support from Pacific Northwest

National Laboratory.

Table 10-1. List of Preparers. Pacific Northwest National Laboratory provided

contract support for the severe accident mitigation alternatives (SAMA)

analysis, presented in Chapter 5 and Appendix F.

Name Affiliation Function or Expertise

Nuclear Regulatory Commission

Briana Balsam Nuclear Reactor Regulation Ecology, Project Support

Dennis Beissel Nuclear Reactor Regulation Hydrology

Richard Bulavinetz Nuclear Reactor Regulation Aquatic Ecology

Andrew Carerra Nuclear Reactor Regulation Radiation Protection; Human

Health

Jennifer Davis Nuclear Reactor Regulation Historic and Archaeological

Resources

Nathan Goodman Nuclear Reactor Regulation Terrestrial Ecology

Stephen Klementowicz Nuclear Reactor Regulation Radiation Protection

Ekaterina Lenning Nuclear Reactor Regulation Air Quality

Dennis Logan Nuclear Reactor Regulation Ecology

Sarah Lopas Nuclear Reactor Regulation Project Manager,

Nonradiological Waste

Robert Palla Nuclear Reactor Regulation Severe Accident Mitigation

Alternatives

Jeffrey Rikhoff Nuclear Reactor Regulation Socioeconomics; Land Use;

Environmental Justice

Andrew Stuyvenburg Nuclear Reactor Regulation Alternatives

Allison Travers Nuclear Reactor Regulation Hydrology

SAMA Contractor(a)

Steve Short Pacific Northwest National Severe Accidents Mitigation

Laboratory Alternatives

Bruce Schmitt Pacific Northwest National Severe Accidents Mitigation

Laboratory Alternatives

Tye Blackburn Pacific Northwest National Severe Accidents Mitigation

Laboratory Alternatives

(a) Pacific Northwest National Laboratory is operated by Batelle for the U.S. Department of Energy

June 2009 10-1 NUREG-1437, Supplement 37

Index

11.0 INDEX

accidents. xix, 5-1, 5-2, 5-3, 5-5, 8-43, A-1 6,

B-11, B-12, F-5

aestheticxix, 2-56, 4-25, 8-14, 8-15, 8-23, 8-

24, 8-30, 8-35, 8-45

alternatives.iii, xix, xx, 1-30, 5-2, 5-3, 5-4, 8-

1, 8-2, 8-8, 8-25, 8-26, 8-30, 8-33, 8-42,

8-45, 8-46, 9-1, 9-2, 9-3, 9-4, 10-1, A-i,

A-15, A-16, A-17, B-12, E-6, E-7

archaeological resources..xix, 1-31, 2-21, 2-

65, 3-12, 3-13, 4-41, 4-42, 8-15, 8-24, 8-

11, D-1

Bam well ........................................ 2-8, A-15

biota ........... 4-6, A-4, A-13, B-2, B-3

burnup ...... ............ .................... 2-1, B-16

chronic effects xviii, 1-28, 4-9, 4-17, 4-40, 9-

1, B-10

Clean Air Act2-25, 2-74, 3-7, 3-15, 8-5, 8-48

closed-cycle cooling ........ 4-12, 8-4, A-4, B-6

consumptive use... 2-16, 4-32, 4-34, 8-27, 8-

32, A-8

cultural resources 3-13, 4-41, 8-15, 8-24, C1

decommissioning .... 7-1, 8-18, 8-29, 8-31, 8-

42,.8-44, 8-45,.9-4, B-15, B-16, B-17

dem ography ......................................... 2-50

design-basis accidents ............ xxiii, 5-1, 5-2

discharges. xviii, 2-7, 2-15, 2-16, 2-18, 2-19,

2-21, 2-28, 2-31, 2-32, 3-6, 4-3, 4-6, 4-12,

4-13, 4-14, 4-15, 4-31, 4-33, 4-40, 8-4, 8-

9, 8-20, 8-21, 8-27, 8-43, 9-1, A-4, A-6, A7, A-8, A-11, A-12, B-i, B-3, B-4, B-9, C2, C-5

dose xviii, 2-5, 2-6, 2-7, 2-9, 3-4, 4-10, 4-11,

4-30, 4-39, 4-40, 5-5, 8-10, 8-11, A-11, A12, A-14, B-9, 1-12, 8-13, B-14, F-32, F33

dredging ............. ...... 3-3, C-6

education 2-51, 2-80, 2-82, 3-10, 4-18, 4-33,

4-42, B-10, B-11

electromagnetic fields.. xviii, 1-28, 4-7, 4-17,

4-40, 9-1, B-7, B-10

42

43

44

45

46

47

48

49

50

51

52

53

54

55

56

57

58

59

60

61

62

63

64

65

66

67

68

69

70

71

72

73

74

75

76

77

78

79

80

81

82

entrainment .................. 8-33, A-4, B-2, B-4

environmental justice 1-28, 3-13, 3-14, 4-18,

4-25, 4-29, 8-15, 8-24, 8-30, 8-35, 9-1, B17

EPA xxiii, 2-8, 2-9, 2-10, 2-11, 2-14, 2-25, 2-

27, 2-28, 2-35, 2-52, 2-56, 2-75, 2-78, 3-

7, 3-8, 3-9, 4-11, 4-39, 8-2, 8-5, 8-6, 8-7,

8-10, 8-11, 8-12, 8-18, 8-19, 8-28, 8-31,

8-49, 8-50, A-6, A-10, B-14, C-1, C-5

fish ladder .................. 2-30, 2-33, 2-34, 4-36

fish passage ....................... 2-30, 2-33, 4-36

GELS.. xv, xvi, xvii, xviii, xix, xxiii, 1-28, 1-29,

1-31, 1-34, 2-57, 3-1, 3-7, 3-14, 4-1, 4-2,

4-3, 4-4, 4-5, 4-6, 4-7, 4-9, 4-15, 4-17, 4-

18, 4-19, 4-20, 4-31, 4-32, 4-40, 5-1, 5-2,

5-3, 6-10, 7-1, 8-1, 8-2, 8-4, 8-10, 8-12, 8-

13, 8-14, 8-17, 8-21, 8-22, 8-23, 8-25, 8-

26, 8-28, 8-29,:8-30, 8-33, 8-34, 8-36, 8-

42, 8-44, 9-4, A-i, A-4, A-9, A-14, A-15,

A-16, B-12

ground water.. xvi, 2-15, 2-26, 2-27, 2-28, 2-

52, 3-1, 3-5, 4-2, 4-3, 4-5, 4-10, 4-30, 4-

32, 4-33, 4-34, 4-37, 4-42, 8-2, 8-8, 8-16,

8-20, 9-1, A-6, A-7, A-8, A-10, A-11, A-12,

A-13, B-5, B-6, C-1

hazardous waste .... 2-9, 2-10, 8-16, 9-3, 9-4,

C-5

high level waste ....... B-12, B-13, B-14, B-15

impingement ........v.-8-33, A-4, B-2, B-4, B-5

invasive species ........ 2-38, 4-37, 4-38

low level waste .............................. xxiv, A-15

mitigation ... xvi, xvii, xviii, 1-29, 1-30, 3-5, 3-

13, 4-1, 4-3, 4-5, 4-6, 4-9, 4-14, 4-16, 4-

34, 4-41, 5-3, 5-7, 8-15, 8-24, 8-28, 9-1,

9-2, 10-1, A-7, A-16, E-6, E-7, F-34

mixed waste ................. xxiv, 2-8, 8-45, B-16

NEPA. xv, xxiv, 1-26, 1-37, 2-70, 2-78, 3-15,

4-25, 4-31, 4-48, 5-1, 6-12, 7-2, 8-1, 8-51,

9-1, A-i, B-i, B-13, B-14, D-1

no-action alternative. iii, xx, 8-25, 8-42, 8-44,

8-45

NUREG-1437, Supplement 37 11-1 June 2009
Index

nonattainmentxvi, 2-25, 3-1, 3-7, 3-9, 8-5, 8-

18, 8-31, B-8

nonnative ..................................... 2-31,2-32

nonradiological waste .................... 2-9, 2-11

NPDES..xxiv, 2-9, 2-11, 2-15, 2-16, 2-19, 2-

21, 4-14, 4-35, 4-37, 8-9, A-4, A-5, A-8,

B-2, C-1

nuclides ................................................. 8-28

Pennsylvania Department of Conservation

and Natural Resourcesxxiii, 2-39, 2-40, 2-

41, 2-42, 2-43, 2-44, 2-45, 2-74, 2-75, 4-

8, 4-46

Pennsylvania Department of Environmental

Protection ... xxiv, 2-9, 2-10, 2-11,2-15, 2-

16, 2-19, 2-21, 2-25, 2-30, 2-40, 2-51, 2-

52, 2-78, 2-79, 4-10, 4-14, 4-30, 4-31,4-

35, 4-37, 4-48, 8-6, 8-9, 8-19, 8-51, A-5

Pennsylvania Fish and Boat Commission

..xxv, 2-33, 2-34, 2-35, 2-39, 2-80, 4-7, 4-

36, 4-48, 4-49

Pennsylvania Game Commission.xxv, 2-39,

2-40, 2-41, 2-81, 4-8, 4-48

Pennsylvania Historic and Museum

Commission.... xxv, 2-81, 3-13, 4-41, 4-42

postulated accidents ........................ 5-1, 5-3

pressurized water reactor ....................... xxv

radon-222 ........................... 6-10, 8-28, B-12

reactor..xv, xxiii, xxiv, xxv, 2-1, 2-5, 2-6, 2-7,

2-11, 2-12, 2-19, 2-40, 2-56, 3-1,4-8, 4-

10, 4-31,4-39, 4-40, 5-1, 5-2, 5-3, 5-7, 5-

8, 7-1, 8-43, 8-44, B-6, B-12, F-34, F-35

refurbishment .xvi, xvii, xix, 2-7, 2-8, 2-21, 2-

53, 3-1, 3-2, 3-4, 3-5, 3-6, 3-7, 3-8, 3-10,

3-11, 3-12, 3-13, 3-14, 9-1, 9-2, A-8, A-9,

B-i, B-2, B-5, B-8, B-9, B-10, B-11, C-5

replacement power ................... iii, 5-7, F-34

scoping...xv, xvi, 1-27, 1-28, 1-30, 1-31, 3-5,

3-6, 3-13, 4-1, 4-3, 4-5, 4-6, 4-9, 4-16, 4-

18, 4-32, 5-2, 5-3, 6-10, 7-1, 9-4, A-1I A2, E-2, E-3, E-4, E-5, E-6, E-7

severe accidents (SAMA) .xxv, 5-3, 5-4, 5-6,

5-7, 5-8, 5-9, 10-1, A-16, F-5, F-15, F-34,

F-35

solid waste..2-8, 2-9, 2-10, 6-10, 8-10, 8-25,

B-17, C-1

spent fuel ...xxiv, 1-29, 2-6, 6-10, 6-11, 8-45,

B-12, B-13, B-15, B-16

steady-state current ............................... 4-15

stormwater ................... 2-21, 4-10, 4-33, A-8

surface waterxvi, xix, 2-27, 2-52, 3-1, 3-6, 4-

3, 4-10, 4-29, 4-30, 4-31,.4-38, 8-2, 8-4,

8-9, 8-16, 8-20, 8-21, 8-27, 8-32, 8-43, 9-

1, A-7, A-8, A-9, A-12, B-I, B-6, C-1 -

Susquehanna River Basin Commission xxv,

2-16, 2-19, 2-27, 2-29, 2-30, 2-31, 2-32,

2-82, 4-2, 4-3, 4-5, 4-32, 4-33, 4-34, 4-35,

4-37, 4-42, 4-49, A-5, A-6, A-7

taxes .......................... 2-54, 2-62, 4-21, A-1 6

threatened and endangered species. xvii, 1-

31, 2-38, 2-39, 2-40, 2-41, 2-42, 2-49, 2-

71, 3-6, 4-4, 4-7, 4-8, 9-1, A-9, A-11, B-3,

B-8, C-1, C-6, D-1

Three Mile Island Unit 2.xix, 2-1, 2-16, 2-21,

2-35, 2-72, 2-73, 2-78, 3-12, 3-13, 4-30,

4-37, 4-39, 4-48, 8-18, 8-31, A-2

transmission corridors ................. 8-15, 8-24

transmission lines.. xviii, 2-12, 2-14, 2-35, 2-

37, 4-1,4-8, 4-15, 4-16, 4-18, 4-38, 4-40,

8-5, 8-9, 8-12, 8-13, 8-15, 8-18, 8-21, 8-

22, 8-24, 8-29, 8-44, 9-1, B-8, B-11

tritium.2-27, 2-28, 4-10, 4-29, 4-30, A-10, A11, A-13

U.S. Fish and Wildlife Service. xxiii, 2-37, 2-

39, 2-40, 2-41, 2-76, 4-7, 4-8, 4-47, C-6

universal waste ...................................... 2-10

uranium. 2-1, 2-5, 2-6, 4-40, 6-10, 8-8, 8-10,

8-13, 8-22, 8-34, B-12, B-15, B-16

wastewater2-11, 2-15, 2-19, 2-21,4-4, 4-33,

4-35, 4-38, A-8, B-2

Yucca ................................. B-13, B-14, B-16

June 2009 11-2 NUREG-1437, Supplement 37
Appendix A

Comments Received on the

Three Mile Island Nuclear Station, Unit 1,

Environmental Review

A. Comments Received on the Three Mile Island Nuclear Station,

Unit 1, Environmental Review

A.1 Comments Received During Scoping

The scoping process began on March 28, 2008 with the publication of the NRC's Notice of

Intent to conduct scoping in the Federal Register (73 FR 16729). The scoping process included

twot public meetings held at The Elks Theatre and Londonderry Elementary School in

Middletown, Pennsylvania on May 1, 2008. Approximately 90 people attended the meetings.

After the NRC's prepared statements pertaining to the license renewal process, the meetings

were open for public comments. Attendees provided oral statements that were recorded and

transcribed by a certified court reporter. Transcripts of the entire meeting, as well as written

statements submitted at the public meetings, were placed into the NRC are an attachment to

the Scoping Summary Report dated August 8, 2008 (NRC 2008). In addition to the comments

received during the public meetings, comments were received through the mail and email.

Each commenter was given a unique identifier so every comment could be traced back to its

author. Table A-1 identifies the individuals who provided comments applicable to the

environmental review and the Commenter ID associated with each person's set of comments.

The individuals are listed in the order in which they spoke at the public meeting, and in

alphabetical order for the comments received by letter or e-mail. To maintain consistency with

the Scoping Summary Report, the unique identifier used in that report for each set of comments

is retained in this appendix.

Specific comments were categorized and consolidated by topic. Comments with similar specific

objectives were combined to capture the common essential issues raised by participants.

Comments fall into one of the following general groups:

Specific comments that address environmental issues within the purview of the NRC

environmental regulations related to license renewal. These comments address Category 1

(generic) or Category 2 (site-specific) issues or issues not addressed in the Generic

Environmental Impact Statement for License Renewal of Nuclear Power Plants (GELS).

They also address alternatives to license renewal and related Federal actions.

General comments (1) in support of or opposed to nuclear power or license renewal or (2)

on the renewal process, the NRC's regulations, and the regulatory process. These

comments may or may not be specifically related to the TMI-1 license renewal application.

Comments that do not identify new information for the NRC to analyze as part of its

environmental review.

Comments that address issues that do not to fall within or are specifically excluded from the

purview of NRC environmental regulations related to license renewal. These comments

Juhe 2009 .A-1 NUREG-1437, Supplement 37
Appendix A

typically address issues such as the Three Mile Island Unit 2 and the 1979 accident,

emergency response and preparedness, security and terrorism, energy costs, energy

needs, current operational safety issues, and safety issues related to operation during the

renewal period.

Table A-1. Commenters on the Scope of the Environmental Review. Each

comment is identified along with their affiliation and how their comment

was submitted.

ADAMS Commenter Commenter Affiliation Comment Source Accession

ID Number

Scott Afternoon Scoping ML081300739 TMI-A Portzline TMI Alert Meeting; ML081330183

Written Comments

TMI-E Andrew Susquehanna River Afternoon Scoping ML081300739

Dehoff Basin Commission Meeting

Afternoon Scoping ML081300739

TMI-F Eric Epstein TMI Alert Meeting; Written ML081330183

Comments

Afternoon Scoping ML081300739 TMI-H TIHOuassiai Mary Osborn Concerned TMI Alert Mothers, Meig Meeting; Written rte ML081330183 L8 318

Comments; Letter ML081690678

TMI-J Michael Lower Susquehanna Afternoon Scoping ML081300739 Helfrich RIVERKEEPER Meeting

Rachel S. Pennsylvania

TMI-N Diamond; Department of Letter ML081500598 David J. Environmental

Allard Protection

TMI-O Michael G. Susquehanna River Letter ML081580174 Brownell Basin Commission

Comments received during scoping applicable to this environmental review are presented in this

section along with the NRC response. The comments that are general or outside the scope of

the environmental review for TMI-1 are not included here, but can be found in the Scoping

Summary Report (NRC 2008).

Scoping comments are grouped in the following categories:

* Aquatic Ecology

* Water Quality and Use

" Terrestrial Resources

" Air Quality

* Nonradiological Solid Waste and Hazardous Materials

* Socioeconomics

NUREG-1437, Supplement 37 A-2 June 2009
Appendix A

* Human Health

* Uranium Fuel Cycle and Waste Management

* Postulated Accidents

* Alternatives

A.1.1 Aquatic Ecology

Comment: I had - we've had some concerns lately with the area that Three Mile Island is in as

far as fish health. We've had some fish kills there recently, and we believe, not caused

necessarily by TMI, but in the vicinity there is a decline in some fish and a decline in small

mouth bass that we were observing.

Let's see. We also have concerns with thermal pollution in this area, and although the amount it

seems that is going into the river is much less than some of the other contributors, we would be

interested to know if there were thermal shock zones in the area similar to Brunner Island which

has problems there where the hot water is meeting the cold water at different times of the year.

So although I've talked to one of the NRC biologists earlier, and they said that approximately

one dead fish found per day in the intakes, I'm interested in what's going on in the effluent, and

also the temperatures of that effluent, and the temperature differences between the river

temperatures and the effluent. (TMI-J-1)

Comment: And also with the thermal impact as brought up, where we are pre-boiling the fish

that you catch, the 102 degree temperatures, we are going to see even increased temperatures

with the droughts that are occurring across the nation, and the thermal impact of nuclear power

plants is going to be pronounced in decades. (TMI-A-1)

Comment: "Whether the kills are legal or not, a former southern Lancaster County worker at

the Peach Bottom nuclear plant said he was "sickened" by the large numbers of sport fish he

saw sucked out of the Susquehanna. "When the water comes in, fish would swim in through

tunnels and swim into wire baskets," said the man who lives in southern Lancaster County and

asked that his name not be used. "There were hundreds and hundreds of fish killed each day.

Stripers and bass and walleye and gizzard shad and all kinds of fish. It took a forklift to carry

them out. "Every species in the river comes in there when they turn those big intakes on."

(Intelligencer Journal, January 15, 2005) TMI has a similar system for disposing of the fish and

other organisms that make it through the intake maze. "If they get that far, they're not going

back," said Pete Ressler, a spokesman for TMI owner AmerGen. "They are dumped into a

* container and disposed of." Will this system function in the same manner for an additional 20

years? (TMI-F-7)

Comment: The Environmental Report states that in the early study (IA, 1979) the delta T did

not exceed 5 degrees F while in the later study (2006 and 2007), delta T is often greater than 10

degrees F, and at one point was over 30 degrees. The cause for the increase in temperature

change should be identified, and the potential adverse impacts assessed. Dramatic changes in

temperature can be as detrimental, and sometimes more so, for long-term community

sustainability than high temperatures. Any thermal assessments should also include the volume

of discharged water, as that parameter is important to the delta T. (TMI-O-1)

June 2009 A-3 NUREG-1437, Supplement 37
Appendix A

I Comment: AmerGen concludes that heat shock issue does not apply to TMI-1 because the

unit does not use once-through cooling. However, it is conceivable that heat shock could be an

issue during extremely low flows or during unusual operations (such as unexpected flow

interruption or loss of York Haven pond). Such potential should be investigated. Again, without

I accurate determination of discharge water quantity and temperature, AmerGen's conclusion is

unfounded. (TMI-O-2)

Comment: Irreversible and Irretrievable Resource Commitments. There is no mention of the

long-term implications to the resource of the facility's thermal discharge. (TMI-O-3)

Comment: Short-Term Use Versus Long-Term Productivity of the Environment. As with the

previous issue, there is no recognition of the potential impact due to the facility's thermal

discharge. (TMI-O-4)

Comment: The Environmental Report states the number of shad passed (total, high, and low),

but does not compare those numbers to what was passed downstream at Safe Harbor.

Although Safe Harbor is a significant distance downstream, the percentages should at least be

mentioned as a comparison - and to put the overall restoration into context. As with previous

two comments, the quantities of water withdrawn and discharged and their potential effects on

shad movement should be assessed. (TMI-O-5)

Response: The comments, in general, express concern regarding the impacts on aquatic

organisms resulting from operation of the TMI-1 closed-cycle cooling system. To operate TMI1, NRC regulations require Exelon Generation to comply with the Clean Water Act and its

associated requirements imposed by the U.S. Environmental Protection Agency (USEPA), as

part of their National Pollutant Discharge Elimination System (NPDES) permit. The NRC staff

based its analysis of environmental impacts of the TMI-1 license renewal.on the GELS, which

was issued in 1996, as amended in 1999. The effects of closed-cycle cooling system operation

on aquatic biota are all Category I issues. In considering the effects of closed-cycle cooling

systems on aquatic ecology in the GELS, the staff evaluated the same issues that were

evaluated for open-cycle systems, including impingement of fish and shellfish, entrainment of

fish and shellfish early life stages, and thermal discharge effects. Based on reviews of literature

and operation monitoring reports, consultations with utilities and regulatory agencies, and

comments on the draft GELS, these potential effects have not been shown to cause reductions

in the aquatic populations near any existing nuclear power plants.

No change in operation of the TMI-1 cooling system is expected during the license renewal

term, so no change in effects of cooling towers on aquatic biota in the Susquehanna River is

anticipated. However, as part of its review the NRC staff looked for any new and additional

information that might call into question the conclusions reached in the GElS for Category 1

issues - no new and significant information was identified, therefore, there are no impacts

beyond those discussed in the GELS.

With regard to comment TMI-O-1 concerning the temperature of TMI-1 discharge water, Section

2.1.7.3 discusses TMI-I's NPDES permit limitations, and states "..the permit also stipulates that

during any 1-hour period, discharge may not affect the temperature of the receving body by

more than 2' F. No violations of this limit have been recorded."

NUREG-1437, Supplement 37 A-4 June 2009
Appendix A

Comment: It appears that all of the presented information and conclusions are based on data

at least 18 years old. Reference is made to monitoring conducted from 1974-1982 and through

1990, but nothing more recent, and there is no mention of the quantity of water withdrawn and

whether-that has changed over time. The environmental assessment for relicensing should

require the collection of new monitoring data and evaluation of that data and any changes it

shows. (TMI-0-6)

Response: The NRC staff believes there is sufficient information available to perform an

assessment of the impacts of license renewal at TMI-1. Furthermore, NRC cannot require the

collection of additional aquatic ecology data to support preparation of the supplemental

environmental impact statement (EIS)-the Pennsylvania Department of Environmental

Protection (PADEP) issues and enforces the TMI-1 NPDES permit and has the authority to

require additional data collection. NRC staff used the best available information, drawing from a

variety of sources including data collected by Exelon Generation, the Pennsylvania Fish and

Boat Commission, the Susquehanna River Basin Commission, other governmental agencies,

independent researchers, and others. If new and significant information becomes available in

the future that demonstrates a significant impact to the aquatic environment as a result of

continued station operation, the staff would expect PADEP to require modifications to station

operation as necessary to protect aquatic resources through the NPDES permitting process.

A.1.2 Water Quality and Use

Comment: I am Andrew Dehoff. I'm the director of planning and operations at the

Susquehanna River Basin commission in Harrisburg. First off I'd like to thank NRC and

AmerGen staff for including us in the informational briefings and the facility tours that took place

earlier this week. It was very helpful.

SRBC is still at the stage of gathering information, and as such don't have comments, specific

comments, ready to share today, but we will be submitting written comments by the deadline.

Preliminarily I can offer that SRBC's main concerns would be related to the water withdrawn

from the river for plant operations, and the water used onsite, and also any changes to

operations or equipment that would affect the water use on site. Some examples of other

issues, we might be commenting on, would relate to the facility and its situation on the river.

And by that I mean flood preparedness and drought preparedness, and the fact-that there is a

great deal more water use both upstream and downstream of TMI than there was when the

plant began operating. Finally just a thank you to NRC for hosting this open house today, and

giving us the opportunity to speak. (TMI-E)

Comment: How does the NRC plan to deal with the following water related issues and

structural challenges caused by: Micro fouling versus macro foiling, micro biologically influenced

corrosion, biofilm's disease causing bacteria such as Legionella and listeria, the difficulty in

eliminating established biofilms, oxidizing versus nonoxidizing biocides, chlorine versus bleach,

alkaline versus non-alkaline environments, possible decomposition into carcinogens, and the

eastward migration of Asiatic clams, zebra mussels and the anticipated arrival quagga mussels?

(TMI-F-8)

.June 2009 A-5 NUREG-1437, Supplement 37
Appendix A

Comment: Drinking Water. In Section 2.91 of the Environmental Report (ER), Dauphin County

is listed as having 14 public water systems. According to the Safe Drinking Water Act (SDWA)

definition of a public water system, that number is incorrect. The SDWA definition of a public

water supply is: a system which provides water to the public for human consumption which has

at least 15 service connections or regularly serves an average of at least 25 individuals daily at

least 60 days out of the year. The definition goes on to define a community water system as: a

public water system which serves at least 15 service connections used by year-round residents

or regularly serves at least 25 year-round residences. Dauphin County residents are currently

served by 28 community public water supplies. The population listed for two of the largest

community water supplies also appears to be incorrect; the population for United Water

Pennsylvania and Pennsylvania American Water Company - Hershey should be verified with

the water companies.

Table 2.9-1 of the ER lists the community public water supplies in Dauphin County that serve

more than 10,000 persons. The data provided for United Water Pennsylvania should be verified

because it is not correct. Also, Middletown Borough Water Authority should be .included in this

table, Middletown's population (including two consecutive water systems that receive all their

water from Middletown) is 10,247 persons.

In Section 2.3, 4.15.1 and 4.15.2, the ER states that the plant does not use water from a public

water system. The SDWA defines a nontransient noncommunity public water system as: a

public water system which is not a community water system that regularly serves at least 25 of

the same persons over six months per year. Based on this definition, the Three Mile Island

facility is a public water system and provides potable water to the plant population. (TMI-N-1)

Comment: It was observed during the site tour that soil has eroded from around and behind

the headwall at Outfall 001. Backfilling around and behind the headwall may be necessary to

prevent damage to the discharge line. (TMI-N-2)

Comment: Although generally satisfied with the ground water explanation, the 'glacial'

materials could not in fact have been deposited by glaciers as their limit of extent is some 20

miles north of TMI. Water in the Gettysburg shale is commonly considered to be semi-confined

and not artesian. (TMI-O-7)

Comment: SRBC has approved Wells 1, 2, and 3 (aka A, B, C) for industrial water supply and

is perplexed to learn that the OSF Well is also used to augment the supply of service water. If

this is the case, the well would require review and approval by SRBC. (TMI-O-8)

Comment: EPA-Regulated Facilities in Dauphin, Lancaster and York Counties. Review of the

impacts of extending TMI's license should include analysis of potential effects of TMI's water

use and thermal discharge on the operations and/or waste assimilation capability of

downstream withdrawals and discharges; likewise, the operation, withdrawals and discharges of

upstream facilities should be analyzed for potential impacts to TMI's operations and thermal

discharge assimilation. (TMI-O-9)

Comment: The potential for nearby power facilities to impact TMI's operations, and vice versa,.

should be evaluated. Of particular concern is operations during periods of severe low flow and

extreme temperatures, including heat and river ice conditions. (TMI-O-10)

NUREG-1437, Supplement 37 A-6 June 2009
Appendix A

Comment: What is the auxiliary water? What are the provisions for backup supply? What is

the source of auxiliary? Has it been sufficiently reviewed, and does it have the appropriate

permits? (TMI-O-1 1)

Comment: AmerGen concludes that any impacts caused by TMI-1 make-up water withdrawal

would be "SMALL" and would not warrant additional mitigation. What is the conclusion based

on? How small is "SMALL"? The assumptions and conditions used in the analysis should be

provided; they may not be valid if the same assumptions and conditions were used as in the

original siting study 40 years ago. In particular, the amount of other consumptive water use on

the river both upstream and downstream of TMI has changed dramatically, and will continue to

grow. Natural hydrologic conditions may also have changed. Without a demonstration of

accurate accounting for water withdrawal and discharge, it is impossible to assess potential

impacts to downstream water users. (TMI-O-12)

Comment: The assessment should include the potential impact of all ground water wells on

site. The conclusions presented in the Environmental Report are based on the well withdrawals

already approved by SRBC; however, there is at least one additional unapproved well in

production. The 1996 pump tests cited by AmerGen do not include any unapproved wells, and

are thus insufficient to evaluate potential ground water use conflicts.

The use of additional unapproved wells has likely increased the quantity of ground water

withdrawal on site. It appears that all ground water evaluations in the Environmental Report are

based on the withdrawal quantity from approved wells only; all assessments involving ground

water impacts or conflicts should be performed again using an accurate value for total ground

water withdrawal.

Applicant should assess the potential ground water conflicts among wells in their own system, to

ensure their long-term viability. (TMI-O-13)

Comment: What is the basis for the conclusion by AmerGen that the impacts of the river

withdrawal to local ground water are small? The details of that analysis should be made

available for review.

As the Environmental Report states, SRBC directs the release of storage on behalf of TMI

during times of drought. However, the quantity released is equivalent only to the consumptive

loss at the plant, and not the total withdrawal, which is considerably greater. Further,

replacement releases are made only during very severe droughts, and not during moderate

droughts and other short-term periods of unusually low flows. Thus, despite releases by SRBC,

there remains the potential for ground water impacts due to the difference between total

withdrawal and consumptive loss, and during periods of moderate and short-term severe

droughts. These potential impacts should be assessed.

There is no documentation presented demonstrating that TMI-1's surface water withdrawal is

capturing only river water, and not also drawing ground water from the adjacent aquifer. (TMI0-14)

Comment: In addition to the impacts listed, other unavoidable impacts include thermal

discharge and localized impacts of the river withdrawal. There~may be others. (TMI-0-15)

June 2009 A-7 NUREG-1437, Supplement 37
Appendix A

Comment: Not listed among the resource commitments is the water demand. The water lost

through plant operations is removed from the Susquehanna River Basin forever, and it is a

cumulative loss that will continue through the end of license period. The long-term commitment

and ultimate loss of that water renders it unavailable for use by any other power plant, water

supply intake, recreational interest, aquatic habitat, or inflow to Chesapeake Bay. It is also

important to note that renewal of the license commits that water in such a way that it is also

unavailable to uses upstream of TMI, in order to ensure its continued availability for use at the

plant. It is unexpected to find that AmerGen would overlook a resource as critical and integral to

plant operations, as well as to the natural, social and economic development of the entire

region, in its Environmental Report. (TMI-O-16)

Response: The comments, in general, pertain to the plant's consumptive use of surface water

from the Susquehanna River, ground water resources in the vicinity of TMI-1, the plant's use of

ground water, and the plant's impact on surface and ground water quality. Surface and ground

water use and water quality issues, including cumulative impacts, are Category 2 issues and are

addressed in Sections 2.1.7, 2.2.3, 2.2.4, 4.3, and 4.4 of this supplemental EIS.

As stated in Section 4.3.1, after publication of the draft supplemental EIS, Exelon Generation

submitted an application to SRBC to utilize the existing OSF well for both potable and industrial

purposes, with no increase in the approved ground water withdrawal rate (Exelon Generation

2009).

Comment: Water Quality. During steam generator replacement, high pressure water will be

used to cut openings in the Unit 1 containment building. The containment building walls are

made of concrete and are approximately 3 feet thick. According to AmerGen personnel, a

temporary package plant will be used to treat wastewater from cutting activities (i.e., to settle

suspended concrete particles and adjust pH) before discharge to the Susquehanna River. A

temporary discharge permit is required for this plant. As an alternative, wastewater from this

operation can be collect and sent off-site for treatment. Under no circumstances should this

wastewater stream be sent to the existing wastewater treatment plant. Also, AmerGen should

notify the DEP once the package plant is installed so DEP personnel can inspect it and sample

the discharge. (TMI-N-3)

Comment: Water Resources. If transportation of the new generators along Pennsylvania

highways or bridges requires any transportation system upgrades or other work, that work may

encroach upon wetlands or waterways. Federal and State wetlands and stream encroachment

permits or authorizations may be required for such encroachments. A 401 certification may also

be necessary. Contrary to the statement made in the EIS, TMI's National Pollutant Discharge

Elimination System (NPDES) permit (i.e., discharge permit) does not carry with it a new 401

certification. (TMI-N-4)

Comment: An erosion and sedimentation plan, and possibly a construction stormwater NPDES

permit, will be required for earth disturbance associated with the new building construction.

(TMI-N-5)

I Response: The comments pertain to Exelon Generation's planned replacement of the TMI-1

once-through steam generators. Environmental impacts of refurbishment activities are

I evaluated in Chapter 3 of this supplemental EIS. Impacts of refurbishment on ground water and

NUREG-1437, Supplement 37 A-8 June 2009
Appendix A

surface water use and quality were examined in the GElS and are Category I impacts. During

its review the NRC did not identify any new and additional information that would call into

question the conclusions reached in the GElS for Category I issues. Chapter 3 also addresses

the impact of refurbishment activities on threatened and endangered species, including aquatic

species that may be impacted by erosion into and sedimentation of the Susquehanna River.

A.1.3 Terrestrial Resources

Comment: AmerGen should consider enhancement of the created open-water wetlands

established on-site from the original plant excavations. Such enhancements would be used to

offset any impacts to aquatic resources that may occur as the result of its intake or other project

activities. (TMI-N-6)

Comment: What is the value and quality of the wetlands that have been formed from the

borrow pits? Consideration should be given to undertaking some enhancement features -

perhaps in conjunction with a local environmental group. (TMI-O-17)

Response: The potential impacts of the continued operation of TMI-1 on terrestrial ecology is

is addressed in Sections 2.2.6 and 4.6. Impacts of continued operation on terrestrial ecology

were examined in the GElS and are Category I impacts. During its review, the NRC did not

identify any new and additional information that would call into question the conclusions reached

in the GElS for Category 1 issues. Impacts of continued operation to protected terrestrial

species is a Category 2 issue and is addressed in Sections 2.2.7 and 4.7 of this supplemental

EIS.

A.1.4 Air Quality

Comment: Asbestos. As the date of construction falls within the general timeframe when the

use of asbestos-containing materials (ACM) was phased out, there is some possibility that ACM

maybe be present on-site. In the event that the project includes disturbance of any ACM, it may

be subject to the federal asbestos regulations found at 40 CFR Part 61, Subpart M, beginning at

40 CFR 61.140. (TMI-N-7)

Comment: Fugitive Emissions. Construction and earthmoving activities must comply with 25

Pa. Code Sections 123.1 and 123.2. These sections generally require that: 1) reasonable

measures must be taken to minimize airborne dust nuisances from construction activities, 2)

any dirt drag-out onto paved streets must be promptly removed, and 3) any airborne dust

generated from construction activities may not visibly cross off-property. (TMI-N-8)

Response: The comments pertain to impacts to air quality during Exelon Generation's planned

replacement of the TM!- I once-through steam generators. Impacts to air quality during

refurbishment activities is a Category 2 issue and is evaluated in Section 3.2.3 of this

supplemental EIS.

A.1.5 Nonradiological Solid Waste and Hazardous Materials

June 2009' A-9 NUREG-1437, Supplement 37
Appendix A

Comment: AmerGen should consider deconstruction and salvage to reduce waste disposal to

the extent possible. All construction and demolition waste that cannot be salvaged or recycled

should be properly transported and disposed of at a DEP-permitted facility. Open burning of

waste is not acceptable. (TMI-N-9)

Comment: Documentation should be provided demonstrating that the flood protection dike - or

the location and storage of hazardous material - ensures there is protection from contamination

during the flood of record. (TMI-O-18)

Response: Nonradioactive waste management and pollution prevention is discussed in

Section 2.1.3 of this supplemental EIS. The staff reviewed the plant's protocols for storing and

managing hazardous materials on site, however, the Pennsylvania Department of

Environmental Protection has ultimate authority in implementing regulations regarding the

treatment, storage, and disposal of hazardous materials.

A.1.6 Socioeconomics

Comment: How many people work at TMI-I? How many people worked at TMI-1 when

AmerGen purchased the plant from GPU? How many people does the NRC project will be

working at TMI-1 in 20 years? Can you factor economics, staffing levels, or the tax base into a

relicensing decision? (TMI-F-10)

Response: The comments are related to the socioeconomic impacts associated with the

continued operation or closure of TMI- 1. Socioeconomic impacts such as housing,

transportation, employment, and land use are Category 2 issues and are addressed in Sections

2.2.8 and 4.9 of this EIS.

A.1.7 Human Health

Comment: TMI is located on Susquehanna River so any leaking contaminants from waste

storage facilities will flow towards and eventually into the Bay. There are no monitoring wells

lining the shoreline. Tritium and other leaks - examples and NRC policy on self-monitoring -

also exist at Three Mile Island. How has the NRC changed modified its relicensing process to

evaluate tritium monitoring? (TMI-F-1 1)

Comment: It was reported last year that tritium was being found in the ground water. We

would like to know the extent of that, where the plumes of this are; also whether we can expect

this to be increasing. Don't know that much about it, so I'd like to learn a lot more. But

obviously when we are dealing with radiation and things with potentially very long half-lives,

bioaccumulate - or accumulation in the environment is definitely a concern. So even though we

were all - supposedly our concerns were quelled last year that these levels were not very high,

if this is an ongoing issue, we would definitely want to know more about that, and have some

kind of comparison to a more virgin area, perhaps somewhere far from nuclear reactors, that we

might be able to get a better comparison of that. (TMI-J-2)

Comment: In sections 2.2.3 and 5.1, the report mentions an Environmental Protection Agency

(EPA) drinking water standard for tritium of 20,000 pCi/L, which is used as a reference value to

NUREG-1437, Supplement 37 A-1 0 June 2009
Appendix*A

add perspective to results obtained in the their ground water monitoring program. Based on the

method EPA uses to calculate the maximum contaminant level (MCL) for beta particle and

photo radioactivity (of which tritium is a constituent), the report should have referenced the fact

that gross beta analysis is routinely conducted and tritium is the only constituent which is

detected in the samples. The clarification would better explain what contaminants are analyzed

for, which have been detected, and how they relate to EPA's drinking water standards. (TMI-N10)

Comment: AmerGen references data presented in Section 2.3 on ground water resources at

TMI, concluding that tritium in the on-site ground water is not a threat to nearby ground water

sources because the Susquehanna River acts as a boundary between the island and the

aquifers on the east and west shore. If that is the case, what amount of tritium is being

delivered to and carried away by the Susquehanna River? What is the potential impact to the

aquatic community of such delivery? Have the, appropriate regulatory agencies been properly

notified? (TMI-O-19)

Comment: I would be very interested in getting some biological studies of the macroinvertebrates in the area, including radiation testing. I would also like someone to look at the

mussels. The mussels are very much ignored in the Susquehanna River, but throughout the

United States, 70 percent of our mussel species are endangered or threatened. And the

mussels are the longest living thing I believe in the river. Some mussels - we are not entirely

sure how long some of them live, but some of them have been known to live 120 years. The

ones that we know of in the Susquehanna live up to 40 years, and we think that testing the

mussels would be a good gauge of telling radiological bioaccumulation. (TMI-J-3)

Comment: The greater number of adverse health effects from nukes occur predominantly

downwind and go further than five miles, depend on atmospheric conditions and in the older

plants (which now include all U.S. nukes) - case the classic mutations in flora and fauna

exposed. Which includes much of the food we eat. Mutated tomatoes, yellow squash, zucchini,

peaches, plums, corn, turnips and even a Heinz pickle have been grown, not only from TMI

country a few other areas as well. Do you care? (TMI-H-1)

Comment: Are the existing monitoring wells adequate (appropriate locations and density) to

capture any problems? Has the risk of radwaste on the island contaminating local aquifers or

water supply wells been assessed? Is there any need to consider monitoring quality and

quantity at some neighboring residences or businesses? (TMI-O-20)

Comment: Radioactive Liquid Waste Disposal System: There is no mention of restrictions to

liquid radwaste discharge during periods of low flow. There should be an analysis of

appropriate flow thresholds below which it is inadvisable to discharge radwaste. There is no

discussion in the application of precautions against spills or other accidental introduction of

radwaste to surface or ground water. (TMI-0-21)

Response: NRC regulations require licensees to control and limit radioactive releases,

including tritium, to the environment (the air and water) to very small amounts. As part of the

NRC requirements for operating a nuclear power facility, licensees must keep releases of

radioactive material into the environment during normal operations as low as is reasonably

achievable (ALARA), as required by 10 CFR Part 50.36a, and comply with radiation dose limits

June 2009 A-1 1 NUREG-1437, Supplement 37
Appendix A

for the public in 10 CFR Part 20. For liquid discharges from nuclear power plants, the ALARA

standard is to keep the annual dose to a member of the public to no more than 3 mrem. In

comparison, the annual dose to an average member of the public from background radiation is

approximately 360 mrem per year. Sources of background radiation include cosmic sources,

naturally occurring radioactive materials, including radon (except as a decay product of source

or special nuclear material) and global fallout as it exists in the environment from the testing of

nuclear explosive devices.

TMI-1 conducts a radiological environmental monitoring program (REMP) in which radiological

impacts to the environment and the public around the TMI-1 site are monitored, documented,

and compared to NRC standards. Exelon Generation summarizes the results of their REMP in

an Annual Radiological Environmental Operating Report. The reports are publicly available on

the NRC's public website. The purpose of TMI- 's REMP is to:

* Evaluate the relationship between quantities of radioactive material released from the

plant and resultant radiation doses to individuals from principle pathways of exposure;

* Provide data on measurable levels of radiation and radioactive materials in the site

environs;

* To verify in-plant controls for the containment of radioactive materials;

* To determine buildup of long-lived radionuclides in the environment and changes in

background radiation levels;

* To provide reassurance to the public that the program is capable of adequately

assessing impacts and identifying noteworthy changes in the radiological status of the

environment; and

* To fulfill the requirements of the TMI-1 Technical Specifications.

The REMP samples environmental media in the environs around the site to analyze and

measure the radioactivity levels that may be present. The media samples are representative of

the radiation exposure pathways to the public from all plant radioactive effluents. The REMP

measures direct radiation, the airborne, and the waterborne pathways for radioactivity in the

vicinity of the TM!- I site. Direct radiation pathways include radiation from buildings and plant

structures and airborne material that may be released from the plant. In addition, the REMP

also measures background radiation (i.e. cosmic sources, and naturally occurring radioactive

material, including radon and global fallout). Thermoluminescent dosimeters (TLDs) are used to

measure direct radiation. The airborne pathway includes measurements of air, precipitation,

drinking water, and broad leaf vegetation samples. The waterborne pathway consists of

measurements of surface water, drinking water, effluent water, storm water, ground water, and

fish and sediment from the Susquehanna River.

For TMI-1, the waterborne pathway consists of Susquehanna River water, fish and

invertebrates, aquatic vegetation, bottom sediment, and shoreline soil. The NRC requires that

only commercially or recreationally important species in the vicinity of the discharge point be

sampled and analyzed. Other species, like mussels, while present in the area, do not represent

a significant dose pathway to humans and are not required to be discussed in the radiological

environmental report.

NUREG-1437, Supplement 37 A-1 2 June 2009
Appendix A

The REMP provides measurements of radiation and of radioactive materials in those exposure

pathways and for those radionuclides which lead to the highest potential radiation exposure to

members of the public. It does not require that every type of environmental media or biota in

the area be sampled and analyzed.

The results of the REMP are intended to supplement the results of the radiological effluent

monitoring program by verifying that the measurable concentrations of radioactive material and

levels of radiation are not higher than expected on the basis of the effluent measurements and

modeling of the environmental exposure pathways. The two programs work together as a

check against each other. The 2007 Annual Radiological Environmental Monitoring Report for

TMI-1 can be viewed in the ADAMS Public Electronic Reading Room, at accession number

ML081300255.

In addition to the routine REMP, starting in 2006, Exelon Generation implemented a ground

water monitoring program at TMI-1. This monitoring program was added by Exelon Generation

to assure that potential liquid release pathways were being thoroughly evaluated. The program

is used to characterize any onsite contamination, to quantify and determine its potential onsite

and offsite radiological impact to the workers, public and surrounding environment, and to aid in

identification and repair of any leaking systems, structures, or components.

As noted in one of the comments, in September 2005, TMI-1 had a localized tritium leakage

inside a utility access manway in the owner-controlled area. The highest concentration of tritium

detected in one water sample from inside the manway was 45, 000 picoCuries per liter. The

U.S. Environmental Protection Agency's drinking water standard is 20,000 picoCuries per liter;

however this water is not used for drinking. The leak was found and fixed. Sampling conducted

at nearby ground water wells did not have elevated levels of tritium. State and federal officials

were informed of the issue and kept updated throughout the event. A detailed discussion of the

inspection performed by the NRC for this event can be found in the ADAMS Public Electronic

Reading Room, at accession number ML062070664.

The radiological effluent monitoring and environmental monitoring programs are part of the

NRC's routine inspection program of every nuclear power plant to ensure compliance with

regulatory requirements. For license renewal, the NRC staff reviewed these areas and

discussions are presented in Sections 2.1.2 and 4.8 of this supplemental EIS.

Comment: AmerGen has implemented a long-term ground water monitoring effort at TMI-1

referred to as the Radiological Ground Water Protection Program (RGPP). Prior to AmerGen's

submittal of the license application to the Nuclear Regulatory Commission (NRC), DEP had

requested that the licensee provide a description of the TMI-1 RGPP. Although the inclusion of

this program in the license renewal application is not required by the Nuclear Regulatory

Commission (NRC), AmerGen responded favorably to DEP's request. The program description,

as included in the Environmental Section of the license renewal application (Appendix E),

indications that a primary purpose of the RGPP is to provide timely detection and response to

any radiological releases to ground water. Based on the information provided in this document

and DEP's independent review of the TMI-1 RGPP, it has concluded that AmerGen has taken

appropriate measures to protect public health and safety and the environment, both during

current and extended periods of TMI-1 operations. DEP will continue to monitor AmerGen's

activities in this area. This effort includes frequent interactions with the TMI-1 Environmental

June 2009 A-1 3 NUREG-1437, Supplement 37
Appendix A

Monitoring Program staff and sampling of selected on-site monitoring wells, as deemed

necessary. (TMI-N-1 1)

I Response: Sections 4.8 and 4.9.7 of this supplemental EIS contain the NRC staff's evaluation

of the applicant's environmental monitoring program.

Comment: DEP participated in the NRC's environmental audit of TMI-1 license renewal

application during the week of April 28, 2008. At the time of the audit, DEP requested additional

information regarding the Solid Waste Staging Facility (SWSF) at TMI-1. This facility is a

passive system for temporary stating of radioactive waste prior to shipment to a disposal facility.

The information requested by DEP includes a description of the system design, a description of

the facility leak collection and monitoring systems, and a document identifying on-site

monitoring wells within the SWSF area. DEP has reviewed the information provided by

I AmerGen and has no concerns. However, DEP staff will continue to perform on-site

surveillances at the TMI site to verify the condition of the SWSF and to periodically review the

sample results from the adjacent monitoring wells. (TMI-N-13)

Response: This comment is general in nature, regarding the TMI-1 Solid Waste Staging

Facility and on-site monitoring wells. The comment provided no new and significant information,

and was not evaluated further.

Comment: Have the owners of TMI-1 reassessed the National Academy of Science's

statements on the harmful effects of low dose radiation exposure? After learning this from Dr.

Helen Caldicott and Dr. Carl Johnson 29 years ago - the truth about the lower levels of radiation

exposure has finally been realized by National Academy of Science! (TMI-H-2)

Response: The GElS evaluated human health issues and determined them to be a Category 1I

issue. The amount of radioactive material released from nuclear power facilities is well

measured, well monitored, and known to be very small. The doses of radiation that are

received by members of the public as a result of exposure to nuclear power facilities are so low

that resulting cancers have not been observed and would not be expected. A number of studies

of cancer incidence in the vicinity of nuclear power facilities have been conducted and there are

no studies to date that are accepted by the scientific community that show a correlation between

radiation dose from nuclear power facilities and cancer incidence in the general public. The

comments were noted but provided no new and significant information and were not evaluated

further.

A.1.8 Uranium Fuel Cycle and Waste Management

Comment: Paducah, Kentucky, talking about the - one speaker just a few minutes ago

mentioned that there is no greenhouse gases released. That is not accounting for the mining

and the whole fuel cycle which you would probably have to take into effect when they do an

analysis, but the NRC is not going to look at that when it comes to operating this specific plant.

Paducah, Kentucky, emitted - one enrichment facility was emitting 88 percent of all United

States CFC ozone-eating gas, 88 percent of all those produced gases came from that plant.

That's - that was pretty bad. Fortunately they fixed some of those leaks in the refrigeration

system. (TMI-A-4)

NUREG-1437, Supplement 37 A-14 June 2009
Appendix A

Response: The carbon footprint of nuclear energy (including its fuel cycle) and alternative

energy sources is an air quality issue. Air quality issues were evaluated in the GElS and

determined to be Category 1 issues. Although these comments do not provide any new and

significant information on air quality pertaining to the reficensing of TMI-1, the carbon footprint of

nuclear power versus other alternate energy sources is addressed in Chapter 8 (alternatives) of

this EIS.

Comment: Barnwell S.C. announced that it will close to generators on June 20, 2008. The

NRC staff concluded that there was no new and significant information and therefore there

would be no impacts of low level waste storage and disposal associated with the renewal term.

The GElS stated that, "...The maximum additional on-site land that may be required for lowlevel waste storage during the term of a renewed license and associated impacts will be small."

TMI is located on Susquehanna River so any leaking contaminants from waste storage facilities

will flow towards and eventually into the Bay. There are no monitoring wells lining the shoreline.

We deserve to know what the LLRW storage plans are before the application is decided; so that

the re-licensing decision does not prejudge any LLRW storage decision. Where will the LLRW

going to be stored? For how long? And will the location be above the flood plain? (TMI-F-1 5)

Response: The comment is related to the environmental impacts associated with Low Level

Radioactive Waste Management (LLRW), which was evaluated in the GElS and determined to

be a Category I issue. The GElS evaluated impacts associated with LLRW management for all

plants, including TMI-1, and determined that the impact was small. During the plant-specific

environmental review of TMI-1, the NRC staff reviewed the future actions planned to be taken at

the TMI- I site for the storage of LLRW (see Section 2.1.2.3) and did not identify any new and

significant information that would call into the question the conclusions contained in the GElS

regarding LLRW.

A.1.9 Postulated Accidents

Comment: A few points to address some other things that came up after I spoke. The

atmospheric sciences, I saw that is part of the environmental concerns, seems to me

recognition by the nuclear industry that the atmosphere is changing; that there is more energy;

that global warming may be occurring. They are certainly advertising to that extent to have

people view nuclear power more favorably.

And if that were true then we do need to study the fact that the weather has more energy, and

tornadoes are more severe, floods are more severe. There is a trend growing. It's not hard to

see that in the next 10 to 20 years there could be some serious problems with tornadoes at

nuclear plants like what happened at Davis-Besse a few years ago where the control room

operator said, when they went into a station blackout situation, that their hearts went into their

throat until finally things started to settle down a little bit. But at first they had power problems

where they couldn't even read their control panels.

So I'd like to see that issue also cross-ties in with the security issues, where the loss of off-site

power and station blackout can be caused by terrorism. The same thing can happen with a

tornado, and that we need redundancy systems for - to prevent station blackout. There has

been some discussion of that with the security discussions, but with environmental impact

June 2009 A-1 5 NUREG-1437, Supplement 37
Appendix A

assessment including atmospheric sciences, I think that falls there too. So we've got to look at

the floods. Don't forget, we had a bad flood in 1972, excuse me, the Agnes Flood, which

flooded Three Mile Island. (TMI-A-6)

I Comment: "AmerGen prepared this sever accident mitigation alternatives analysis... with

support from it's parent company, Exelon." In case of another accident at TMI, and since

I AmerGen received the support from its parent company, Exelon, will Exelon also be held liable

for costs and damages to the offsite humans, fauna and flora? Based on the continuing

adverse effects caused by TMI-1 's brother plant, TMI-2, State, Federal, and local governments

must demand accountability next time - as many failed their constituents while, while few

helped. (TMI-H-5)

Comment: "Benefits, costs, and net value of implementing potential S.A.M.A.'s" - Your costrisk benefits have never been humane - benefitting only corporate profits (as usual - the NRC's

actions assist those they are to regulate instead of health and safety of those paying taxes to

play their employees.) Remember Davis-Besse?

Cost-Risk benefits actually should only be for promoting and protecting the life and health of

humans, flora and the planet. Corporate greed is the predominant cause of our earth in distress

from global warming and also nuclear-atomic zapping! Bomb fallout and Chernobyl dust is still

circling the planet and TMI mutations 29 years later are still growing - with another bumper crop

this year! (TMI-H-6)

Comment: Ground Water use must be considered a significant issue due to the fact that

nuclear plan uptake of water is only possible with what nature provides, and as the earthquakes

in China (5/2008) caused flow of rivers to cease and become a lake instead - you must be

prepared for the unexpected. Especially since TMI-1 and TMI-2 are on an earthquake fault line.

Remember April 22, 1984, where the meter was set so high it didn't register the quake - but the

control room operators did feel the 4.0 quake, centered in Lancaster County, under TMI and

under my home as well. (TMI-H-16)

Comment: A reassessment of likely flood scenarios should be performed. The original

assumptions related to the hydrology, flow patterns, and flood return intervals of the

Susquehanna River are likely outdated, and certainly do not account for potential changes over

the course of the extended license period due to climate change or other phenomena. (TMI-O26)

Response: The comments are related to the impacts of design basis accidents and severe

accidents. The impacts of design basis accidents were evaluated in the GElS and determined

to be small for all plants; therefore, it is a Category I issue. The impact of severe accidents is a

Category 2 issue and must have a site-specific evaluation. Additionally, alternatives to mitigate

severe accidents must be considered for all plants that have not considered such alternatives.

The applicant provided a severe accident mitigation alternatives (SAMA) analysis as part of the

license renewal application for TMI-1. The NRC staff's review of the SAMA analysis is

discussed in Section 5.3 and Appendix F of this supplemental EIS for TMI-I.

NUREG-1437, Supplement 37 A-1 6 June 2009
Appendix A

A. 1.10 Alternatives

Comment: Number one is conservation. Also energy created on site, on homes - not by

greedy corporate energy producers. The hydrogen fuel cell home created by college students

had a cost to build - but once built the cost of energy to operate the home was a big, fat zero =

$0. Antiquated machinery is currently still in use because the money goes to support and

finance nukes. Ancient Greece used solar and so did Florida - until electricity came along.

The time to change was 29 years ago - you obviously did not learn the lessons - even after

Chernobyl. Shut-down nuclear TMI-1, put windmills on your cooling towers, solar on your

parking lots - hydro from your little dam - non-tritiated water for geothermal under your ground

- waste and non-food biomass. And conservation! No more subsidies to you for your ultrahazardous (atomic bomb making) method of energy production. But going solar is what I

recommend for your future. So that our children will have a future. (TMI-H-4)

Comment: The assessment of alternatives in Chapter 7 is limited entirely to alternatives for

power production in lieu of continued operation of TMI. An evaluation should also be conducted

of alternatives to specific current operating practices at TMI that would allow continued

generation at the plant, but with lesser impacts to the air, soil, and water resources of the

region. Technology has advanced a great deal in the 40 years that have passed since the

design of TMI-1, and its adoption and use on-site should be investigated as a condition of

license renewal. (TMI-O-23)

Response" The comments are related to the environmental impacts of alternatives to license

renewal for TMI-1. Environmental impacts associated with various reasonable alternatives,

including a combination of energy sources, conservation, coal and natural gas, to renewal of the

operating licenses for TMI- I is evaluated in Chapter 8 of this supplemental EIS.

A.2 Comments Received on the Draft Supplemental EIS

Pursuant to 10 CFR Part 51, the staff transmitted the Generic Environmental Impact Statement

for License Renewal of Nuclear Plants Regarding Three Mile Island Nuclear Station, Unit 1,

Draft Report for Comment (NUREG-1437, Supplement 37, referred to as the draft supplemental

Environmental Impact Statement [EIS]) to Federal, State, and local government agencies, and

interested members of the public. As part of the process to solicit public comments on the draft

supplemental EIS, the staff:

* placed a copy of the draft supplemental EIS into the NRC's Public Electronic Reading

Room, on its license renewal website, and at the Londonderry Township Municipal

Building, the Middletown Public Library, and the Penn State Harrisburg Library, all in

Middletown, Pennsylvania;

" sent copies of the draft supplemental EIS to the applicant, members of the public who

requested copies, and certain Federal, state, and local agencies;

" published a notice of availability of the draft supplemental EIS in the Federal Register on

December 9, 2008 (73 FR 74766);

June 2009 A-1 7 NUREG-1437, Supplement 37
Appendix A

" announced and held two public meetings in Harrisburg, Pennsylvania, on February 24,

2009, to describe the results of the environmental review and answer questions on the

license renewal process;

* placed newspaper ads and issued press releases announcing the issuance of the draft

supplemental EIS, the public meetings, and instructions on how to comment on the draft

supplemental EIS; and

* established an email address to receive comments on the draft supplemental EIS

through the Internet.

During the comment period, the staff received a total of nine comment letters and emails in

addition to the comments received during the public meetings.

The staff has reviewed the public meeting transcripts and the comment letters that are part of

the docket file for the application, all of which are available in the NRC's Public Document

Room. This section of Appendix A contains a copy of each commenter's submission(s) during

the comment period. For those that provided oral comments at the February 24 meetings,

comments are taken from the meeting transcripts. Note that only comments from those

transcripts are included in this document; however, the complete meeting transcripts can be

accessed online or in-person from ADAMS at accession numbers ML090680558 and

ML090680578.

Comment letters and emails are also available online in ADAMS. A cross-reference of the

speaker or author of the comment, their affiliation (if stated), the comment source, the page

where the start of the comment can be found, and the ADAMS accession number of the

comment is provided in Table A-2.

Table A-2. Commenters on the Draft Supplemental EIS.

in alphabetical order.

Commenters are identified

Page ADAMS

Commenter Affiliation Comment Source Accession Number Number

Marjorie Citizen Email A-20 ML090840462

Aamodt

Holly Angelic Local citizen Afternoon Meeting A-25 ML090680558

Michael T. U.S.

Chezik Department of Letter A-27 ML090840544

Interior

Susquehanna

Andrew Dehoff River Basin Afternoon Meeting A-30 ML090680558

Commission

Eric Epstein TMI Alert Evening Meeting; A-31 ML090680578 Letter ML090680388

Exelon

Michael P.Eeo Michel Generation Letter A-46 ML090680038

Gallagher Company, LLC

NUREG-1437, Supplement 37 A-1 8 June 2009
Appendix A

1

ADAMS

Commenter Affiliation Comment Source e Accession Number Number

Gregory H. FirstEnergy Email A-53 ML090840664

Hanlon Corporation

Sierra Club;

Judith Environmental Evening Meeting A-53 ML090680578

Johnsrud Coalition on

Nuclear Power

Thomas C. Local citizen E-mail A-55 ML090840537

LeCrone

Diane Little Local citizen Afternoon Meeting A-56 ML090680558

U.S.

Kevin Magerr Environmental Letter A-60 ML090750180 Protection

Agency

Concerned Mary Osborn Mothers; TMI Evening Meeting; A-62 ML090680578

Ouassiai Letter ML090680766 Alert

Laura Piraino Sierra Club Evening Meeting A-71 ML090680578

Scott Portzline TMI Alert Afternoon Meeting; A-71 ML090680558;

Evening Meeting ML090680578

Harrisburg

Diocese and

Joyce Scott Council of Afternoon Meeting A-76 ML090680558

Catholic

Women

Linda Spears (no affiliation E-mail A-77 ML090840665 stated

Pennsylvania Karen Walsh Energy Alliance Afternoon Meeting A-77 ML090680558

A.2.1 Individual Comments and Responses

There was no significant new information provided on Category 1 issues, or information that

required further evaluation on Category 2 issues. Therefore, the conclusions in the GElS and

draft supplemental EIS remained valid and bounding, and no further evaluation was performed.

Comments without a supporting technical basis or without any new information are discussed in

this appendix, and not in other sections of this report. Relevant references that address the

issues within the regulatory authority of the NRC are provided where appropriate. Many of these

references can be obtained from the NRC Public Document Room.

June 2009 A-1 9 NUREG-1437, Supplement 37
Appendix A

Where the comment or question resulted in a change in the text of the draft report, the

corresponding response refers the reader to the appropriate section of this report where the

change was made. Revisions to text in the draft report are designated by vertical lines beside

the text.

Commenter: Marjorie Aamodt, citizen

Re: Application submitted by AmerGen Energy Company, LLC to renew operating license for

Three Mile Island Nuclear Station, Unit 1 for an addition twenty (20) years past year April, 2014.

Upon reading the U.S. Nuclear Regulatory Commission's preliminary assessment, Draft

NUREG-1437, I find that you have not considered or adequately considered the following:

(1) The five mile area population at the time of the 1979 accident at Unit 2 was identified by

the Pennsylvania Department of Health and the Centers for Disease Control to be followed for

the following twenty (20) years as their health status which was to be considered as decisive

concerning the impact the accident had on human health, if any. The bottom-line is that the lifeexpectancy of people living within five miles of the TMI accident has been shortened as

compared to vital statistics for the three counties adjacent to TMI. During the same time period,

national life span increased six years. Incredibly the researcher did not appreciate the

significance of her finding of shorter life expectancy for those living closest to the TMI accident

whereas it is well-known to radiation biologists that shortened life span of a population is an

expected result of exposure to ionizing radiation. (Talbott, Evelyn 0. et al. Long Term Follow-Up

of the residents of the Three Mile Island Accident Area: 1979-1998, 30 October 2002.

(2) Clearly, the people living near TMI are continuously impacted by ionizing radiation

already released to the environment since limited sampling found tritium in just about everything

sampled. To disregard this exposure because the source "could not be directly attributed to

TMI-I"* is not a responsible assessment of their environmental impact. (*Draft NUREG-1437,

Supp.37, p.4-29)

(3) Furthermore, the REMP program (Radiological Environmental Monitoring Program)

takes far too few samples to disprove far higher concentrations of radioactivity, for instance "21

milk samples collected in 2007" and "26 food product samples". The fact that "11" of those milk

samples and "24" of the food product samples contained Strontium-90 should be sufficient to

move the NRC to prevent any further exposure due to the repair and continued operation of the

TMI-1 reactor. It does not matter if the radiation in those food samples "could be attributed to

residual fallout from weapons testing", the concentrations in the food supply of TMI area

residents only shows that they are a population already impacted by exposure to ionizing

radiation in their food supply and should not be additionally exposed by continued operation of

the TMI-1 reactor. (Quotes, Id. 4-30)

(4) Your analysis of the hazards of radon-222 is informative. This gas decays to "particulate

radioactive nuclides that give off high energy alpha particles. These radioactive particles are

inhaled and remain lodged in the lungs, causing continued exposure."* Isn't that what happens

when particulate radioactive nuclides are routinely released from an operating nuclear power

plant and are taken in by breathing or by eating food containing these particles which release

not only alpha radiation but beta, gamma and X-rays directly to the cell? (* Id. 8-28)

NUREG-1437, Supplement 37 A-20 June 2009
Appendix A

(5) Lastly, I am amazed by the continued oversight of the inadequacy of a ten-mile

emergency planning zone. In or around 1985, a study undertaken by the Three Mile Island

Public Health Fund showed that emergency planning around TMI had to be for the twenty mile

radius due to the unique topography. I am referring to a study made at Clark University, which

was published in book form and was to be placed in the TMI area libraries.

(6) Whereas, the current owners are apparently addressing the matter of intrusion of

terrorists on foot, are you satisfied that the health and safety of TMI area residents are protected

from crash of a commercial airline due to terrorists' activity? Of course, you cannot be.

(7): My husband and I have great interest in the decision you are making. We have friends

and family who have remained in Pennsylvania. We visit them on a regular basis and have

considered returning to live in central Pennsylvania. We left our home near Coatesville,

Pennsylvania simply due to the insensitivity of the majority of the Commissioners to the

suffering of residents we uncovered in three communities in York County where cancer deaths

rose to more than six times the expected number during within six years following the accident.

We surveyed those neighborhoods after we learned on the occasion of a fifth-anniversary forum

in Middletown that many residents had symptoms of acute radiation illnesses during the

accident. Whereas correlation does not always indicate causation, in this instance it clearly did

as follow-up studies at Columbia University and at the University of North Carolina, both

studying the ten mile area population found significant increases in cancer incidence, and the

latter study related the incidence to the relative distribution of accident radiation.

(8) I am heartened by your comprehensive address of the alternative sources for generating

electricity. The people of central Pennsylvania can have electricity and jobs without incurring

additional exposure to ionizing radiation.

I am hoping that your concern for the people of central Pennsylvania who have been exposed to

fallout from weapons testing, routine releases from TMI-1 and TMI-2, the TMI and Chernobyl

accident releases of potentially as many as 500 different kinds of radionuclides*, clean-up

releases, and work-place clean-up and daily exposures of workers and of family by worker, will

lead both the NRC and AmerGen to deny re-licensing of TMI-1. (*Kocker)

Response:

Ms. Aamodt's concerns include health effects of the following: the 1979 TMI Unit 2 accident;

continued operation of TMI-1; and background radiation from fallout from weapons testing and

the Chernobyl accident; and the potential crash of an aircraft into TMI-1. Ms. Aamodt also

expresses approval of the analysis of alternatives presented in Chapter 8.

Comments regarding TMI Unit 2 and the radiological impact of the 1979 accident do not pertain

to the scope of the TMI-1 license renewal review and were not evaluated further. TMI Unit 2 has

been defueled and decontaminated to the extent the plant is in a safe, inherently stable

condition suitable for long-term management. Additional information on TMI Unit 2 can be found

on the NRC 's public website: http://www. nrc. -ov/readin-q-rm/doc-collectionslfact-sheets/3mileisle.htmL.

Regarding Ms. Aadmodt's comments numbers (1), (2), (7), and (8), the staff acknowledges the

articles and information provided, but they do not provide scientifically defensible information

June 2009 A-21' NUREG-1 437, Supplement 37
Appendix A

that would cause the NRC to alter its position that the current radiation protection safety

standards are protective of public heath and safety and the environment.

The NRC's primary mission is to protect the public health, safety and the environment from the

effects of radiation from nuclear reactors, materials, and waste facilities. The NRC's regulatory

limits for radiological protection are set to protect workers and the public from the harmful health

effects of radiation on humans. The limits are based on the recommendations of standardssetting organizations. Radiation standards reflect extensive scientific study by national and

international organizations (International Commission on Radiological Protection [ICRP],

National Council on Radiation Protection and Measurements [NCRP], and the National

Academy of Sciences [NAS]) and are conservative to ensure that the public and workers at

nuclear power plants are protected.

Health effects from exposure to radiation are dose-dependent, ranging from no effect at all to

death. Above certain doses, radiation can be responsible for inducing diseases such as

leukemia, breast cancer, and lung cancer. Very high (hundreds of times higher than a rem),

short-term doses of radiation have been known to cause prompt (or early, also called "acute')

effects, such as vomiting and diarrhea, skin burns, cataracts, and even death.

Although radiation may cause cancers at high doses and high dose rates, currently there are no

reputable scientifically conclusive data that unequivocally establish the occurrence of cancer

following exposure to low doses and dose rates, below about 0. 1 Sievert (10 rem). However,

radiation protection experts conservatively assume that any amount of radiation may pose some

risk of causing cancer or a severe hereditary effect and that the risk is higher for higher radiation

exposures. Therefore, a linear, no-threshold dose.response relationship is used to describe the

relationship between radiation dose and detriments such as cancer induction. Simply stated,

any increase in dose, no matter how small, results in an incremental increase in health risk. This

theory is accepted by the NRC as a conservative model for estimating health risks from

radiation exposure, recognizing that the model probably over-estimates those risks.

Based on this theory, the NRC conservatively establishes limits for radioactive effluents and

radiation exposures for workers and members of the public, as found in 40 CFR Part 190,

Environmental Radiation Protection Requirements for Normal Operations in the Uranium Fuel

Cycle, 10 CFR Part 20, Standards for Protection Against Radiation, and 10 CFR Part 50,

Appendix I, Domestic Licensing of Production and Utilization Facilities, Numerical Guides For

Design Objectives and Limiting Conditions for Operation to Meet the Criterion "As Low As is

Reasonably Achievable" For Radioactive Material In Light-Water-Cooled Nuclear Power

Effluents.

Regulatory limits are placed on the radiation dose that members of the public might receive from

all of the radioactive material released by the nuclear plant combined. Licensees are required to

report liquid, gaseous, and solid effluent releases as well as the results of their radiological

environmental monitoring program annually to the NRC. The annual effluent release and

radiological environmental monitoring reports submitted to the NRC are available to the public in

the ADAMS electronic reading room available through the NRC website:

htt,://www. nrc. qov/readinq-rm/adams. html.

NUREG-1437, Supplement 37 A-22 June 2009
Appendix A

The amount of radioactive material released from nuclear power facilities is well measured, well

monitored, and known to be very small. The doses of radiation that are received by members of

the public as a result of exposure to nuclear power facilities are so low that resulting cancers

have not been observed and would not be expected. Although a number of studies of cancer

incidence in the vicinity of nuclear power facilities have been conducted, there are no studies to

date that are accepted by the scientific community that show a correlation between radiation

dose from nuclear power facilities and cancer incidence in the general public. Specific studies

that have been conducted include:

" In 1990, at the request of Congress, the National Cancer Institute conducted a study of

cancer mortality rates around 52 nuclear power plants and 10 other nuclear facilities.

The study covered the period from 1950 to 1984, and evaluated the change in mortality

rates before and during facility operations. The study concluded there was no evidence

that nuclear facilities may be linked causally with excess deaths from leukemia or from

other cancers in populations living nearby.

* In June 2000, investigators from the University of Pittsburgh found no link between

radiation released during the 1979 accident at TMI Unit 2 and cancer deaths among

nearby residents. Their study followed 32, 000 people who lived within five miles of the

plant at the time of the accident.

* In 2000, the Illinois Public Health Department compared childhood cancer statistics for

counties with nuclear power plants to similar counties without nuclear plants and found

no statistically significant difference.

* In January 2001, the Connecticut Academy of Sciences and Engineering issued a report

on a study around the Haddam Neck nuclear power plant in Connecticut and concluded

radiation emissions were so low as to be negligible.

* The American Cancer Society in 2001 concluded that although reports about cancer

clusters in some communities have raised public concern, studies show that clusters do

not occur more often near nuclear plants than they do by chance elsewhere in the

population. Likewise, there is no evidence that links Strontium-90 (Sr-90) with increases

in breast cancer, prostate cancer, or childhood cancer rates. Radiation emissions from

nuclear power plants are closely controlled and involve negligible levels of exposure for

nearby communities.

" Also in 2001, the Florida Bureau of Environmental Epidemiology reviewed claims that

there are striking increases in cancer rates in southeastern Florida counties caused by

increased radiation exposures from nuclear power plants. However, using the same data

to reconstruct the calculations on which the claims were based, Florida officials were not

able to identify unusually high rates of cancers in these counties compared with the rest

of the State of Florida and the nation.

To ensure that the plants are operated safely within these requirements, the NRC licenses the

plants to operate, licenses the plant operators, and establishes technical specifications for the

operation of each plant. The NRC provides continuous oversight of plants through its Reactor

Oversight Process (ROP) to verify that they are being operated in accordance with NRC rules

and regulations. The NRC has full authority to take whatever action is necessary to protect

June 2009 A-23 NUREG-1 437, Supplement 37
Appendix A

public health and safety and may demand immediate licensee actions, up to and including a

plant shutdown.

The NRC has issued regulations establishing clear requirements for license renewal to assure

safe plant operation for extended plant life (codified in 10 CFR Parts 51 - Environmental

Protection Regulations For Domestic Licensing and Related Regulatory Functions and 54 -

Requirements For Renewal of Operating Licenses For Nuclear Power Plants). An applicant

must provide the NRC with an evaluation that addresses the technical aspects of plant aging

and describes the ways those aging effects will be managed. The applicant must also prepare

an evaluation of the potential impact on the environment if the plant operates for up to an

additional 20 years. During the review of the application for license renewal the NRC staff

verifies the safety evaluations through inspections and reviews environmental issues associated

with license renewal. The NRC staff has not identified any new and significant information

during its independent review of the TMI-1 Environmental Report, Annual Radioactive Effluent

Release reports, Annual Radiological Environmental Operating reports, and during the

environmental site audit.

The NRC has already fully considered and addressed these issues and the comments do not

present any significant new information or arguments that would warrant a change to the TMI-1

supplemental EIS.

Regarding Ms. Aamodt's comment number (3), the NRC requires every nuclear power plant to

conduct a radiological environmental monitoring program (REMP) to monitor the environment

around its facility for radioactivity released during operation. Various types of sample media (air,

water, and food products) are collected in order to measure and evaluate the levels of

radioactive material in the environs around the plant site to assess the radiological impacts, if

any, of plant operation on the environment. The program is a check on the radiological effluent

monitoring program to verify that the levels of radioactive materials in the environment are not

higher than expected based on data from the radiation monitors at the plant's effluent release

points. The REMP data is used to demonstrate compliance with NRC's reporting criteria for

environmental samples. The NRC performs periodic inspections of every nuclear power plant's

REMP to verify their compliance with NRC's radiation protection standards. The REMP

performed at TMI-1 is conducted in accordance with NRC criteria.

Regarding Ms. Aadmodt's comment number (4), the radioactive effluents discharged from

nuclear power plants do contain radionuclides that during their radioactive decay process, give

off alpha, beta, and gamma radiation. The particulates, if inhaled or ingested will result in a

radiation dose to the individual. All nuclear plants were licensed with the expectation that they

would release radioactive material to both the air and water during normal operation. Airborne

and liquid releases of radionuclides from nuclear power plants must meet radiation dose-based

limits specified in 40 CFR Part 190, 10 CFR Part 20, and the "as low as is reasonably

achievable" (ALARA) criteria in 10 CFR Part 50, Appendix I. Regulatory limits are placed on the

radiation dose that members of the public might receive from all of the radioactive material

released by the nuclear plant. The NRC performs periodic inspections of every nuclear power

plant to verify their strict compliance with NRC's radiation protection standards.

NUREG-1437, Supplement 37 A-24 June 2009
Appendix A

The NRC has already fully considered and addressed these issues and Ms. Aamodt's

comments regarding radiological impacts of TMI-1 do not present any significant new

information or arguments that would warrant a change to the TMI-1 supplemental EIS.

Regarding Ms. Aamodt's comment number (5) concerning the 10-mile emergency planning

zone (EPZ): To facilitate a preplanned strategy for protective actions during an emergency,

there are two EPZs around each nuclear power plant. The exact size and shape of each EPZ is

a result of detailed planning which includes consideration of the specific conditions at each site,

unique geographical features of the area, and demographic information. The plume exposure

pathway EPZ has a radius of about 10 miles from the reactor site. Predetermined protective

action plans are in place for this EPZ and are designed to avoid or reduce dose from potential

exposure to radioactive materials. These actions include sheltering, evacuation, and the use of

potassium iodide where appropriate. The ingestion exposure pathway EPZ has a radius of

about 50 miles from the reactor site. Predetermined protective action plans are in place for this

EPZ and are designed to avoid or reduce dose from potential ingestion of radioactive materials.

These actions include a ban of contaminated food and water.

The Commission considered the need for a review of emergency planning issues in the context

of license renewal during its rulemaking proceedings on 10 CFR Part 54, which included public

notice and comment. As discussed in the Statement of Considerations for rulemaking (56 FR

64966), the programs for emergency preparedness at nuclear plants apply to all nuclear power

plant licensees and require the specified levels of protection for each licensee regardless of

plant design, construction, or license date. Requirements related to emergency planning are in

the regulations at 10 CFR 50.47 and Appendix E to 10 CFR Part 50. These requirements apply

to all operating licenses and will continue to apply to plants with renewed licenses. Through its

standards and required exercises, the Commission reviews existing emergency preparedness

plans throughout the life of any plant, keeping up with changing demographics and other siterelated factors. Therefore, the Commission has determined that there is no need for a special

review of emergency planning issues in the context of an environmental review for license

renewal The comment provides no new information, and does not pertain to the scope of

license renewal under 10 CFR Part 51 and Part 54. No changes were made to the supplemental

EIS.

Regarding Ms. Aamodt's comment number (6), concerning the impacts of an aircraft collision at

TMI-1: the NRC's environmental review is confined to environmental matters relevant to the

extended period of operation as requested by the applicant. Appropriate safeguards and

security measures have been incorporated into the site security and emergency preparedness

plans. Any required changes to emergency and safeguards contingency plans related to

terrorist events will be incorporated and reviewed under the operating license-independent of

license renewal. The comment provides no new information and does not pertain to the scope

of license renewal under 10 CFR Parts 51 and 54. No changes were made to the supplemental

EIS. Further discussion of aircraft impacts can be found on page A-58.

Commenter: Holly Angelic, local citizen

My name is Holly Angelic. I'm a resident of Middletown. But I'm wondering if there are any

opportunities to other communities that are equally affected, like Goldsborough on the other

side of the river, to also offer public comments. Or do they have to come all the way here? It

June 2009 A-25 NUREG-1437, Supplement 37
Appendix A

concerns me in terms of public participation and public comments. It seems that they are left

out of this process or have been for this long. That's one of my questions. Just that everybody

gets a chance to participate, the people of Goldsborough and the west shore are getting the

public announcements, that's one of my questions.

I have a couple more too if we're just waiting for Scott. My quick question then before Scott

comes back is, in a scoping meeting that I went to there was a lot of discussion about Unit 2.

And, even though the NRC doesn't have to include Unit 2 in their environmental impact

assessment, I'm wondering if they have done anything and to sort of follow up on the issue of

the aircraft, the structure that's housing all that radioactivity, if the NRC has looked at that at all,

even though they haven't had to.

Response:

The NRC placed ads in the Middletown Press and Journal, the York Daily Record and the York

Sunday News, the Lancaster Intelligencer Journal, the Harrisburg Patriot-News, and the Sun

Newspaper for the May 2008 scoping meetings, and the York Daily Record, the Lancaster

Intelligencer Journal, and the Harrisburg Patriot-News for the February 2009 draft supplemental

EIS meetings. The NRC typically chooses meeting locations that are close to the plant and

easily accessible to the majority of the population surrounding the plant. The NRC realizes

Goldsboro and communities west of the Susquehanna River had to travel a farther distance to

reach the May 2008 and February 2009 meetings in Middletown and Harrisburg than those that

live east of the river. However, comments on the scope of the environmental review and on the

draft supplemental EIS were accepted via mail, email or telephone, and carried equal weight as

those submitted in person at the public meetings. By placing ads in the local newspapers the

NRC attempted to reach the general population surrounding the plant that is served by these

news outlets.

TMI Unit 2 is discussed in Sections 2.2.9.2 and 4.9.6 regarding the historical significance of the

site, and in Section 4.11.4, where TMI Unit 2 (along with Peach Bottom Atomic Power Station) is

included in the discussion of cumulative human health impacts. Section 4.11.4 states that

controlled radioactive discharges from TMI Unit 2 are a very small fraction of the radioactivity

released from TMI-1, and the calculated radiation does to members of the public from all

radioactive material released from the TMI-1 site are well within NRC's radiation safety limits.

No additional analyses regarding TMI-2 were done during the license renewal review of TMI-1.

NUREG-1437, Supplement 37 A-26 June 2009
Appendix A

Commenter: Michael T. Chezik, U.S. Department of the Interior

0 United States Department of the Interior

OFFICE OF THE SECRETARY

Office of Environmental Policy and Compliance TA•r Pmor.

Custom House, Room 244 INMERIC

200 Chestnut Street IN R.ELY REFETo Philadelphia, Pennsylvania 19106-2904

March 3, 2009

ER08/1285

Chief Rulemaking, Directives Editing Branch

U.S. NRC

Mail Stop T6-D59

Washington, D.C. 20555-0001

RE: Draft Generic Environmental Impact Statement, NUREG-1437, Supplement 37, for

the License Renewal of Three Mile Island Nuclear Station, Unit 1; Dauphin County,

Pennsylvania.

Dear Sir / Madame:

The Department of the Interior (Department) has reviewed the above-referenced Notice, dated

December 9,2008, regarding Three Mile Island Nuclear Station located in Londonderry

Township, Dauphin County, Pennsylvania. AmerGen, LLC, proposes to renew its license to

operate a nuclear power project at the existing Three Mile Island Nuclear Station.:

The following comments are provided pursuant to the Endangered Species Act of 1973 (87 Stat.

884, as amended; 16 U.S.C. 1531 etseq.) to ensure the protection of federally listed endangered

and threatened species, and the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16

U.S.C. 661 et seq.) to ensure protection of other fish and wildlife resources.

FEDERALLY LISTED SPECIES

Except for occasional transient species, no federally listed or proposed, threatened or endangered

species under our jurisdiction are known to occur within the project impact area. Therefore, .

based on currently available information, no biological assessment or further consultation under

the Endangered Species Act is required with the Fish and Wildlife Service. Should project plans

change, or if additional information on listed or proposed species becomes available, this

determination may be reconsidered.

BALD EAGLE

Bald eagles are known to occur in the vicinity of the Three Mile Island facility. Although the

bald eagle has been removed from the federal List of Endangered and Threatened Wildlife, and is

therefore no longer protected under the Endangered Species Act, it continues to be protected

under the Bald and Golden Eagle Protection Act (Eagle Act) ind the Migratory Bird Treaty Act

.(MBTA). Both acts protect bald eagles by prohibiting killing, selling or otherwise harming

June 2009 A-27 NUREG-1437, Supplement 37
Appendix A

eagles, their nests or eggs. The Eagle Act also protects eagles from disturbance. "Disturb"

means to agitate or bother a bald or golden eagle to a degree that causes, or is likely to cause,

based on the best scientific information available, 1) injury to an eagle; 2) a decrease in its

productivity, by substantially interfering with normal breeding, feeding, or sheltering behavior,

or 3) nest abandonment, by substantially interfering with normal breeding, feeding, or sheltering

behavior.

On June 4, 2007, the Service released several important documents related to the protection of

bald eagles under the Eagle Act, including 1) a final rule establishing a regulatory definition of

"disturb"; 2) a final environmental assessment of the "disturb" regulation; 3)National Bald Eagle

Management Guidelines; and 4) a proposed rule to establish a permit for the take of bald and

golden eagles. The proposed rule would establish regulations for issuing permits to take bald

and golden eagles where the take is associated with, and not the purpose of, otherwise lawful

activities. A second permit type would provide for permits to take bald and golden eagle nests

for safety emergencies (of humans or eagles). All of these documents can be found at

http://ww.fwvs. ov/migratorvbirdsibaldeagle.htm.

A bald eagle nest is located approximately three miles northwest from the Three Mile Island

facility. In addition, bald eagles are continuing to expand their breeding range along the

Susquehanna River, and therefore may be found in previously undocumented locations near the

facility. Consequently, we recommend that the applicant carefully evaluate the project type,

size, location and layout in light of the National BaldEagle Management Guidelines to

determine whether or not bald eagles might be disturbed as a direct or indirect result of this

project. If it appears that disturbance may occur, we recommend that the applicant consider

modifying the project to be consistent with the Guidelines. If the applicant has questions about

when and how to obtain a permit because he or she believes that the proposed project will disturb

bald eagles, and he or she is not able to implement measures to avoid disturbance, please contact

the Fish and Wildlife Service Migratory Bird Permit Program at 413-253-8643 or

permitsr5mb@fws.gov.

Lastly, the applicant should incorporate state-of-the art methods to prevent raptor electrocution

and collisions (see Suggested Practices for Avian Protection on Power Lines: the State of the Art

in 2006, available from the Avian Power Line Interaction Committee at http:iAww.aplic.org).

Siting new power lines as far as possible from known eagle nests would help reduce the

electrocution/collision risk, as would equipping existing or new lines with features that would

prevent raptor electrocution and collisions.

SPECIFIC COMMENTS

Section 2.2.7 Threatened and Endangered Species and Section 4.7 Threatened or

Endangered Species. The DEIS (pages 4-8 and 4-9) indicates that the osprey (Pandion

haliaetus) is one of the eleven State-listed threatened or endangered species that have been

determined to be species of special concern for the TMI- 1 site of the license renewal project.

The DEIS (pages 4-8 and 4-9) states that mitigation measures for the osprey (and other species)

currently in place at the TMI- 1 site include nest construction and placement, and that "these

current mitigation measures are found to be adequate." However, in a previous section, the

DEIS contradicts this conclusion, claiming (page 2-40) that nesting relocation efforts by the

State-listed, threatened osprey (Pandion haliaetus) have been unsuccessful, citing AmerGen

NUREG-1437, Supplement 37 A-28 June 2009
Appendix A

(2008) as the reference. It would benefit the public for the final EIS to include more specific

information as to why such relocation efforts may not be successful, and include the results of

scientific studies on such efforts, such as the undated US Geological Survey (USGS) citation

which indicates that "ospreys typically pair for life and use the same nest site in successive

years." The USGS reference also includes other relevant information and cites several additional

references that may be useful in the analyses and evalhtaion of proposed mitigation measures to

be included in the final EIS, such as studies which indicate that "Colonies [of ospreys] may arise

in secure areas such as islands or lakes, but most pairs tend to be solitary nesters, separated from

other nests by tens to hundreds of kilometers (McVey et al., 1993)." Available scientific

information regarding nesting relocation measures would be important considerations for

identifying appropriate mitigation measures and measuring the severity of the impact from the

proposed project

Table 2-6, pages 2-41 through 2-49. The correct designation in the footnote on page 2-49 for a

State-listed threatened species should be "PT" and not "ST" as currently listed.

Section 2.4 References, page 2-76. The link to the U.S. Fish andWildlife Service (2008a)

'citation (for ospreys) is not correct. The correct link should read as follows:

http://www. fws. gov/chesapeakebay/osprey.html.

Conclusions

The applicant should be directed to clarify or gather additional information on the questions

identified above. This may entail conducting appropriate field studies to obtain site-specific

information. We also ask that the Commission continue to coordinate with the Fish and Wildlife

Service throughout the license renewal process.

Thank you for the opportunity to review and comment on this Draft Environmental Impact

Statement. If you have any questions regarding this matter, please contact Lloyd Woosley of the

USGS Environmental Affairs Program-at.(703)J35-0i4J97_orJenniferLKagel of the U. S. Fish and

Wildlife Service's Pennsylvania Field Office at 814-234-4090.

Sincerely,

Michael T. Chezik

Regional Environmental Officer

3

June 2009 A-29 NUREG-1437, Supplement 37
Appendix A

Response:

The comments from the U.S. Department of Interior (DOI) state that based on currently

available information, no biological assessment or further consultation with the U.S. Fish and

Wildlife Service is necessary for the TMI- 1 license renewal review under the Endangered

Species Act. The letter moves on to state that a bald eagle nest is located approximately 3 miles

northwest from TMI-1, and recommends that Exelon Generation evaluate future projects in light

of the National Bald Eagle Management Guidelines to determine whether eagles may be

disturbed. DOI also recommends that the applicant equip existing powerlines with features that

would prevent raptor electrocution and death.

Section 2.2.7.2 Terrestrial Species has been edited to include information regarding osprey

nesting habits, as described in the undated USGS online publication. The footnote in Table 2-6,

Listed Aquatic and Terrestrial Species, has been corrected to reflect "Pennsylvania Threatened"

versus "State Threatened." The U.S Fish and Wildlife Service 2008a reference has also been

corrected.

Commenter: Andrew Dehoff, Susquehanna River Basin Commission

Thank you. My name is Andrew Dehoff. I'm the Director of Planning and Operations at the

Susquehanna River Basin Commission. First off, in looking through the draft EIS, it seems that

NRC has addressed most of the concerns that SRBC raised in the scoping process. And we're

thankful for that. However, I do have a few comments.

We'll start with two minor comments about specific points in the EIS. First, some information

that SRBC supplied regarding an invasive species, Zebra Mussels, indicated that they were only

present' in the headwaters of New York and the Great Bend portion of the Susquehanna River

and Pennsylvania. Unfortunately, later in 2008 they were discovered at the Conowingo Dam in

Maryland. So we can provide some updated information to you regarding that.

Second, the storage volumes that were cited as needed to mitigate for TMI's consumptive use

during a drought vWere unfamiliar to us. We're not sure what the source of those were. And

we'd just like the opportunity to discuss them with Exelon or NRC, where they came from.

Finally, a general comment. As you might guess, SRBC's main concern is related to

withdrawals of water from the river. And, I'd like to comment on NRC's finding in Section 3.1

and Table 411 that conclude that the refurbishment and continued operations of the plant pose

a small impact to the surface waters of the basin. The conclusion seems to be predicated on

Exelon's compliance with SRBC's regulatory programs. While we appreciate NRC's confidence

in our programs, we do hope that you'll remain involved in matters related to the potential

impacts to the resources of the river, particularly as they relate to the upgrades and continued

operations and cumulative impacts.

I am pleased to report that Exelon has recently submitted an application to SRBC for plant

modifications related to replacement of the steam generators and also submitted information

related to continued use of onsite wells. Exelon also indicated their intent to submit all

appropriate applications for groundwater withdrawal, surface water withdrawal and consumptive

water use by March 13th, at which time SRBC staff can begin its technical review.

NUREG-1 437, Supplement 37 A-30 June 2009
Appendix A

In summary, we anticipate full cooperation from Exelon regarding those applications. And we

look forward to continued coordination with NRC Staff. Thank you.

Response:

Section 2.2.5, Description of Aquatic Resources, has been updated to reflect that zebra mussels

were discovered at the Conowingo Dam in 2008. The NRC could not find a reference for the

figure of 4,250 acre-feet used in discussions of the Cowanesque Lake water storage project in

Sections 4.3.2 Ground Water Use Conflicts and Section 4.4.1 Water Use Conflicts in the draft

supplemental EIS. This figure has been removed from the final supplemental EIS text. The

removal of the figure has not caused any change in the conclusions for this section.

Mr. Dehoff and SRBC express concern that the NRC's conclusions in Chapter 4 regarding water

use are predicated on Exelon Generation's compliance with SRBC regulations. The NRC is

pleased that during the license renewal review SRBC identified areas where Exelon Generation

needed to modify their existing ground water withdrawal, surface water withdrawal, and

consumptive use permits for the operation of TMI-1 and the planned refurbishment activities.

The NRC will continue to work collaboratively with SRBC regarding water use and operating

issues at existing plants, and the siting of potential new units, in the Susquehanna River basin.

Commenter: Eric Epstein, TMI Alert

Evening Meeting

Eric Epstein, Three Mile Island Alert. I've been around a while. I now have gout and I'm bald

and fat. And I don't really care what people think what I have to say. And that's sad, because

this is actually my third re-licensing proceeding. I think more than anybody else in America I've

probably been intermittently involved with three processes that, frankly, I think have little to no

value.

I read the entire GElS. I'm not normally a big fan of fiction, but I did read it. I was going to offer

comments to telling issues. These were my comments. I'm not going to submit them. It won't

matter. It really won't matter. I read the entire document as I read the entire document at

Peach Bottom, as I read the entire document at Susquehanna and it had no value.

The only thing I'm going to formally enter -- and I'll give it to you, Sarah -- is on your chronology

of environmental review, there were 14 correspondences that you missed, among other things.

My comments tonight actually have very little to do with the re-licensing of Three Mile Island. I

think Exelon is a smart company. They are a strategic company. If I were them I would try to

re-license TMI -2. Frankly, TMI-2 would get through. I'm just telling you. And I said the same

thing before in May. By the way, to the police, relax. Hopefully you're getting overtime for this.

I have no idea why you're here. But relax and enjoy the evening. Actually, my neighbor could

have used you the other night, they had a domestic issue.

TMI re-licensing, as with the re-licensing of every nuclear power plant, is a done deal. It's a

smart move for Exelon. It doesn't cost a lot of money. In fact, the next generation of nuclear

power plants is where the existing generation is. It's a smart move. They'd be nuts not to do it.

In fact, that's why we didn't oppose or challenge re-licensing. In fact, that's why I settled with

June 2009 A-31 NUREG-1 437, Supplement 37
Appendix A

Exelon. It made more sense. I'm here tonight, frankly, to congratulate the Nuclear Regulatory

Commission on a job well done.

You know, from my experience, and I'm still involved in the re-licensing process at

Susquehanna, the process is designed to fast track and approve, much better than you did the

first time around, minimize public input, put a smiley face on a nuclear bail-out. You guys are

doing a good job. Frankly, it's amazing. Because we litigate, intervene, that's TMI Alert. Before

the EHB, before DEP, before the PUC.

You should really take a page from Pennsylvania public participation. They do, I think, a much

better job. On a solemn note, I was just looking for answers to the 50 questions I submitted on

May 1st. I don't think I'm ever going to get responses. Based on my experiences in relicensing, what happens is you put a question in and what comes back, it's bizarre. You don't

get your question back. You get this generic format. And then there's some response at the

end that bears no relation to the question. You may want to work on that.

I did find some issues here. But what I'm going to do is just go through the process that I

experienced as a human being, trying to offer input and comments on re-licensing.

Back on March 25th I contacted Sarah Lopas. And I said, I asked -- I kept all my notes because

I'm anal and have no social life. And I asked for responses to questions that I was going to

submit on May 1st. And she got back to me that day. And this was her response. She replied

quickly. It was great. I will do my best to answer any of the environmental license renewal

questions regarding TMI-1 or any questions you might have on the license renewal process in

general regarding consumptive water use, groundwater monitoring, bio-fuel control of the

circulating water system, da, da, da, da.

I was really getting into it and encouraged. So I can't make any definitive statements until

December until we tentatively plan to publish the draft. And then she outlined the scoping

period. And I thought initially, wow, this is pretty cool. We're getting off to a better start. I made

initial contact with the representative from the NRC who, by the way, came to visit in Harrisburg.

And we had established a dialogue. So far so good. Not really. Not really. If you look hard,

and I did when I read this, you can see how the NRC altered the intent in the content of my

questions and then they melded them into a response. It's like this massaged composite

format. I've never seen anything like it before. But you have to squint real hard, otherwise you

miss it. And I'll give you an example.

One example, I spent a lot of time submitting really well defined and researched questions

relating to invasive species, which is a problem not just for nuclear power plants, but for all

power plants on the Susquehanna River. You'd have to get out your microscope, but you might

find actually a reference to our questions on Asiatic clams and zebra mussels. Actually, if you

want to and you have nothing else to do, and you want to join me in not having a life, you would

go to 2.3, 2.32 and 2.3 -- you'd have to look hard. And then if you go back to the question we

asked, I thought it was right on. By the way, the question is listed on A-5 of the appendix with

no response. However, I persisted.

NUREG-1437, Supplement 37 A-32 June 2009
Appendix A

There's only one issue, frankly, after we settled with Exelon, that I really cared about more than

any other issue, and that's emergency planning. And I think that should be obvious by what

we've done at the NRC.

The EJ person, which I guess is your Environmental Justice person, which is really interesting

because the NRC's definition of environmental justice bears no relation to DEP's definition of

environmental justice. Just for shits and giggles I'll read you -- sorry, strike it, don't strike it, I

don't care. Environmental Justice to the DEP is the fair treatment and meaningful involvement

of all people, regardless of race, color, national origin or income with respect to the development

of .implementation.

I wrote a letter to Sarah. And she wrote back. She said he -- I guess there's some buddy

named Jeff Rikhoff who I never met, who never contacted me, and apparently I'm never going

to hear form. He wasn't coming to the meeting on Thursday. And you were very nice. She

said, I apologize for that, he has been CC'd on the email. I will ask him to give you a call to

discuss this week.

That was May 5th, never heard from him. My phone number has been the same. The address

remains the same. The bill collectors find me. My ex-wife finds me, he can find me. Hard to

miss.

Since the NRC'S socioeconomic designant, Mr. Rikhoff, did not attend the May 1st meeting I

followed up with Ms. Lopas and requested a meeting with the NRC representative on

socioeconomic impacts.

Again, this is just my experience trying to get some questions. Two months later, this is in

August, Mr. Rikhoff had not emailed me, but Ms. Lopas did and stated, actually, there are

numerous EJ issues that we're still wanting to contact Mr. Rikhoff about. That's what I was

saying to her. And she wrote. And again, Sarah's pretty good, the same day. If you have

specific questions regarding environmental justice and the TMI-1 license renewal I can forward

them on to him although, keep in mind, scoping is over.

So I'm not really sure how I was to be scoped if nobody contacted me. And we're putting the

draft SEIS together, which is why I recommend waiting until the draft is published. All right,

maybe miscommunication, maybe we missed each other. How does this all come together,

what issue am I raising? The only issue -- that's okay, Sarah, because you'll ignore me again

anyway.

The issue I'm raising is that of the Amish and the Mennonite, that I've been trying to raise for 25

or 30 years. It's very bizarre. It's that we have a special needs population who is not

ambulatory, who does not use electronic devices, who was left behind during the last accident. I

thought, very basic, just one issue we'll see if we can get some attention for. And this is what I

wrote Ms. Lopas. One of the special needs populations that is also an EJ issue is the status of

alerting and evacuating the Amish, who don't own cars or use phones or may not have access

to potassium iodine. However the Amish, as well as some Mennonite sects, are mostly

agricultural communities and will likely stay behind, which causes problems beyond their

enclaves. For instance, the sale of their produce and livestock, chronic health issues, low birth

weight from midwife delivery, dedicated water contamination, etcetera. And I said to you, that is

June 2009 A-33 NUREG-1437, Supplement 37
Appendix A

why we wanted to meet with a live human being. Visual inspections and the realities of these

problems just don't drop off the sheep.

Furthermore, I thought based on the experience we had with Three Mile Island -- and for some

people that's an ancient event -- and more recently the experience the Amish went through with

Nickel Mines should have sensitized people to the need to include these people in a plan so that

they're accounted for in the event of an accident or incident. The only issue I have pursued

since May. Nothing. I would also point out, and I don't know, and at some point maybe

somebody can explain this to me.

According to the GELS, I figured, look, if we can make a population disappear we can probably

make weather disappear. I don't know what a severe weather incident is. But, when I looked in

the records, and I may be wrong, we've had an earthquake, a tornado and a drought the last

couple of years. And they weren't included.

So, this isn't a criticism. I just and trying to find some idea of constitutes a severe event. This is

it. I mean, I'm not going to come up and testify in this process or participate in the process

anymore. We submitted 50 questions in the same format May 1st. I'm not going to get

responses. TMI Alert is not going to get responses. We're okay with that. You know, we tried

to work with the company. That's going so-so.

Based on my experiences at Susquehanna, I know even if I did get a response, the agency

would distill and homogenize and tailor that response to meet some limited low-hanging NRC

metric.

But part of the problem is me. And I recognize that. I mean, I can continue to participate in a

regulatory white-out and a linguistic shell game. Or what I'm going to propose tonight is I can

formally cease to exist. And I propose that I no longer exist. And my request to the NRC is

simple. And I'd like a response. And I think this would probably make Exelon happy.

I would like you to expunge every comment, every piece of paper, letter or whatever I submitted.

Get rid of it as if I - what I just said tonight, get rid of it. What I want you to do is expunge

everything that I've said or done relating to the re-licensing issue. And then I'll feel as if we're

okay, that I've done what I was supposed to do. Because I tried to do what I was supposed to

do. It didn't work. I realize that. I just think it would make everybody feel happy, certainly

Ralph, Jan, Exelon, the NRC because I will not be coming back.

And, Sarah, can you do that? Everything I just said, can you take off the record and everything I

testified before. Can you do that? Please get back to me because I don't want to put any more

effort into it and I don't want to be a party to it.

And to the guy back there, I'm sorry, I should have told you Iwas going to do it before you got

carpal tunnel issues. Poof, I'm gone. Have a nice evening.

NUREG-1437, Supplement 37 A-34 June 2009
Appendix A

Letter From Eric Epstein Dated, February 24, 2009 (Please see ADAMS Accession Number

ML090680166 for the complete document submission including supporting information.)

I. Background

I am not here to discuss relicensing. That's a done deal. Three Mile Island

Unit-i (TMI-i) will be relicensed as will every nuclear power plant that applies

for a license extension. That's a fact of life. And that's why Threel Hile Island

Alert, Inc. (TMIA) did not challenge the license extension, and whey I entered

into a Settlement with Exelon.

The Nuclear Regulatory Commission (NRC's) relicensing process is

designed to fast track and approve, minimize public input, and put a smily face

on a nuclear bailout.

The Commission views "public participation" as a regulatory burden. The

NRC's institutional hubris marks the agency's determination to return to the

regulatory world of pre-March 28, 1979.

Tonight we're here to congratulate the Nuclear Regulatory Commission

on it's partnership with nuclear industry. The Agency should be. recognized on

its successful efforts to collaborate with the American Nuclear Society, the

Institute for Nuclear Power Operations, and the Nuclear Energy Institute.

On a solemn note, Three Mile Island Alert is still awaiting responses to the

Testimony and questions I offered on behalf of TMI-Alert dating back to March

25, 2oo8 and officially filed on May 1 and 5, 20o8.

While I reviewed the entire document and prepared detailed testimony

relating to gaps in socioeconomics and emerging issues, I have opted not to enter

those comments into the official record. Instead, I am only going to review the

process as I experienced to date, and make additions to Appendix E: Chronology of

Environmental Review.

2

June 2009 A-35 NUREG-1437, Supplement 37
Appendix A

II. The Process

Back on March 25, 2008, I asked for responses to the questions and issues

TMIA planned to raise on May 1, 20o8. Sarah Lopas, Project Manager Division of

License Renewal replied quickly that same day at 11:19 am:

I will do my best to answer any of the environmental license renewal

questions regarding TMI Unit 1, or any questions you might have on the

license renewal process in general. Regarding consumptive water use,

groundwater monitoring, biofoul control of the circulating water system,

NPDES-regulated discharges to the Susquehanna, and fish kills - we are

just in the very beginning stages of the preparing the draft EIS, so I can't

make any definitive statements until December, when we tentatively

plan to publish the draft. And of course we will have the draft EIS public

meetings (tentatively scheduled for late January 2009) to answer

questions on our findings, and take comments on the draft.

The FRN of Intent to Prepare an EIS/Conduct. Scoping will be published

March 31, and we'll be back up to Middletown for the scoping meetingson

Thursday, May 1. The scoping comment period will end May 30, so I

encourage you to submit your comments for consideration via email

before then, or at the May 1 meetings. I'll forward the PDFs of the FRN and

meeting notice on to you when they are available.

On May 5, 20o8 at 9:15 Sarah Lopas, Project Manager Division of License

Renewal even requested a copy of TMIA's testimony, "if you have it available,

would it be possible to get a PDF (or Word) version of the most recent testimony

you submitted? That will make it easier for me to put it in the Scoping.

Summary Report." I provided the material in PDF format that same day.

So far, so good. Not really.

If you look hard, you can see how the NRC altered the intent and content of

TMIA's questions, and melded the responses into a massaged composite format.

But you have to squint real hard, otherwise you wont be able to connect the

regulatory dots. (4.32 through 4.42, A- 1 through A-8)

3

NUREG-1 437, Supplement 37 A-36 June 2009
Appendix A

For example, despite well-defined and researched questions relating to

invasive species, you would have to get out your microscope, but you can find

references in the NRC evasive response to Asiatic Clams (2-3 and 2-32) and

Zebra Mussels (2-32.)

The question is listed on A-5, but there no responses.

As part of the cost-benefit analysis of nuclear power plant licensing

applications, the NRC. is required to assess likely socioeconomic impacts of power

plant construction and operation on local communities and the surrounding

region. This is interesting relicensing standard since the NRC has no statutory

authority to collect tariffs from licensees or enforce decommissioning savings.

However, I persisted.

On May 5, 2008, at 9:15 AM, Sarah Lopas wrote, "He [Jeff Rickoff] wasn't

able to come to the meetings on Thursday - I apologize for that. He has been

CC'ed on this email. i will ask him to give you a call to discuss sometime this

week.

Since the NRC' socioeconomic designate, Mr. Jeff Rickoff, did not attend the

May 1, 20o8 meeting, I followed up with Ms. Lopas and requested a meeting with

the NRC representative on socioeconomic impacts.

Two months later Mr. Rickoff had not not contacted me. I e-mailed Ms.

Lopas on August 05, 20o8 4:00 and stated, "Actually there are numerous EJ

issues and we're still waiting to be contacted by Jeff [Rickoff]."

1 Environmental justice is the fair treatment and meaningful involvement

of all people regardless of race, color, national origin or income with respect to

the development, implementation and enforcement of environmental laws,

regulations and policies. N E W S R E L E A S E COMMONWEALTH OF

PENNSYLVANIA, Dept. of Environmental Protection, 1/27/2009

4

June 2009 A-37 NUREG-1437, Supplement 37
Appendix A

On August 5, 2008 at 4:14 pm Sarah Lopas wrote: "If you have specific

questions regarding EJ (environmental justice) and the TMI-1 license renewal I

can forward them on to him, although keep in mind scoping is over, and we're

putting the draft SEIS together now. Which is why I recommend waiting until

the draft is published so you can review the analysis and go from there.

I answered Ms. Lopas:

One of the special needs' populations that is also an EJ issue is the status of

alerting and evacuating the Amish who don't own cars or use phones and

may not have access to KI...

However, the Amish as well as some Mennonite sects (are mostly

agricultural communities), and will likely stay behind which causes

problems beyond their enclaves, i.e., sale of produce and livestock, chronic

health issues, low birth weight for mid-wife delivery, dedicated water

contamination, etc.

This is why we wanted to meet w/ a live a human: visual inspections and

the reality of the problems we experienced in 1979 don't jump off of the

pages.

The GEIS does not factor the special needs of Old Order Men nites and,

Amish living with ten miles of Three Mile Island. As witnessed byý'ltdown in

1979 and the Nickel Mines tragedy on September 30, 2006, this agricultural

based population requires and deserves dedicated planning since they do not use

telecommunication devices, operate motor vehicles or utilize electronics. (2-57,

2-62 and EJ 4.97)

Since the NRC can make a population disappear, I was curious if they could

also rewrite weather patterns. Pleased note that under 4.10 III. Evaluation of

New & Potentially Significant Information: This section has either omitted or

failed To Identify Severe Weather Events. The NRC stated severe weather is

"generally uncommon" (p. 2-24); however, an earthquake, tornado and drought

have impacted the TMI vicinity in recent years.

5

NUREG-1437, Supplement 37 A-38 .June 2009
Appendix A

* Earthquake: December 27, 2008

(Lebanon County, 12:04 a.m., 12/27/08) A 3.4 magnitude earthquake.

occurred northwest of the city of Lancaster, Lancaster County. The quake was

felt by residents in Berks, Cumberland, Dauphin, Lebanon and Lancaster. No

damage or injuries were reported.

The incident was terminated at 6:23 a.m.

Notifications: Departments of Health, Environmental Protection (Southcentral

Regional Office and Headquarters) and Transportation, Public Utility

Commission, Federal Emergency Operations Center, Turnpike Commission, PA-i

Call, Millersville University Geology Department, National Earthquake

Information Center, State Police, affected counties and PEMA Central and

Eastern Area Offices

* F3 Tornado: July 14, 2004

An F3 tornado, with wind speeds estimated between 175 and 200 mph,

pounded Campbelltown in Lebanon County ,Pennsylvania. The severe storm

which produced the tornado over ioo homes in a development in

Campbelltown. This thunderstorm also produced a weaker F1 tornado in.

northern York County as it moved eastward on Wednesday afternoon. The storm

injured twenty-four people in Campbelltown.

Pennsylvania Emergency Management (PEMA) reports showed that 32

houses were destroyed, 37 homes suffered major damage, and an additional 5o

homes suffered some form of damage from the storm (Figure 1). Two people

were hospitalized by the storm, one was critically injured. Fortunately, there

weie no fatalities with the tornado. In .addition to the homes damaged winds

that affected other areas of Dauphin and Lebanon Counties. A few farmhouses

and houses in other areas of Lebanon County were damaged by the strong

straight line winds.

Source: Lebanon County F3 Tornado, 14 July 2004 Richard H. Grumm

and Kevin Fitzgerald National Weather Service Office, State College, PA 168o3

* Drought: Summer 2002

During the 2002 drought nuclear power plants were exempted from water

conservation efforts and participate in a "voluntary" program.' In

Pennsylvania, 24 counties were designated as "drought emergencies", and

another 31 were on "drought watch.

6

June 2009 A-39 NUREG-1437, Supplement 37
Appendix A

III. Conclusion

I am submitting the same 5o questions in the same format from the May

1, 2oo8 meeting hoping somebody or something at the NRC will actually answer

the questions.

Based on my prior experiences with relicensing at the Susquehanna Steam

Electric Station, I realize that the NRC won't respond to the questions directly.

The Agency will distill and homogenize and tailor their responses to meet some

limited, low-hanging NRC metric(s).

However, I can continue to participate in egulatory "whiteout" and a

a linguistic shell game.

Or, in the alternative, I can formally cease to exist.

I choose not to be part of a perforated record.

Please expunge and strike all of my previous comments and Testimony.

Please disregard all of the comments I made this evening.

7

NUREG-1437, Supplement 37 A-40 June 2009
Appendix A

IV. Appendix E:

Chronology of Environmental Review

The information provided on the Timeline from E-1 to E-7 is incomplete

and fails to include the following:

" May 1 and 5, 2008: TMIA's Testimony was submitted to the NRC.

" May 19, 2oo8: Joint Press Release: "Exelon and EFMR Sign Community Based

Agreement."

• August 18, 20o8 "Re: Findings and Responses of the NRC Office of the Inspector

General Report on the License Renewal Program" from Senator Jeffrey E. Piccola

(R-15th Senatorial District) and Rep. Eugene A. DePasquale (D-95th Legislative

District)

* May 28, 2oo8 Letter to Peter Bramford from Douglas Beddelfor

Communications Manager for TMI, Re: Relocation of Joint Information Center to

Coatesville.

* July 23, 2oo8: Summary of Conference Call With AmerGen Company To

Discuss Responses to Request for Additional Information For Sections 4.2 and 4.4

of the Three Mile Island Unit i License Renewal Application (TAC NO. MD 7701)

• August 20, 2008: Request for Additional Information For Sections 2.3. 3 and

2.3.4 of the Three Mile Island Unit 1 License Renewal Application (TAC NO. MD

7701)

• August 22, 2008: Summary of Conference Call With AmerGen Company To

Discuss Responses to Request for Additional Information For Sections 2.2, 2.3.,

2.4 and 2.5 of the Three Mile Island Unit i License Renewal Application (TAC

NO. MD 7701)

* August 22, 2008: Request for Additional Information For Sections 2.2, 2.3,

2.4 and 2.5 of the Three Mile Island Unit 1 License Renewal Application (TAC

NO. MD 7701)

* November 12, 2008: Three Mile Island Unit 1 - Request for Additional

Information, Regarding Review of Steam Generator Inspection Report for the

2007 Outage (TAC NO. MD 8268)

'i

June 2009 A-41 NUREG-1437, Supplement 37
Appendix A

* October 24, 2008 - Exelon Announces Third Quarter Results; Increases Fourth

Quarter Common Dividend by 5 Percent

"Unrealized losses of $6o million, or $o.o9 per diluted share, related to!

nuclear decommissioning trust fund investments primarily related to the

AmerGen Energy Company, LLC (AmerGen) nuclear plants."

- November 17, 2008: Summary of Conference Call With AmerGen Company To

Discuss Responses to Request for Additional Information For Sections 2.3. and

2.3.4 of the Three Mile Island Unit i License Renewal Application (TAC NO. MD

7701)

- December 23, 2008: The Nuclear Regulatory Commission approved the formal

transfer of the operation licenses for these facilities to Exelon Generation on Dec.

23, 2008, which was a key step in the final integration process.

- January 8, 2009: Exelon Generation today officially integrated the nuclear

generation assets held by its AmerGen Energy Company LLC subsidiary into

Exelon Nuclear and dissolved the AmerGen legal entity.

The Nuclear Regulatory Commission approved the formal transfer of the

operation licenses for these facilities to Exelon Generation on Dec. 23, 2oo8,

which was a key step in the final integration process.

- January 5, 2009: Request for Additional Information For Sections 2.3. and&

2.3.4 of the Three Mile island Unit i License Renewal Application (TAC NO. MD

7701)

NUREG-1437, Supplement 37 A-42 June 2009
Appendix A

Response:

Mr. Epstein's comments express general dissatisfaction with the NRC license renewal process

and its opportunities for public participation. The NRC acknowledges his request to expunge his

comments from the TMI-1 license renewal review environmental scoping and draft supplemental

EIS comment proceedings, however, Mr. Epstein's comments will remain on the license renewal

record. 10 CFR Part 2.390, Public Inspections, Exemptions, and Requests For Withholding,

states that "final NRC records and documents, including but not limited to correspondence to

and from the NRC regarding the issuance ... of a license, permit, order, or standard design

approval, or regarding a rulemaking proceeding subject to this part shall not, in the absence of

an NRC determination of a compelling reason for nondisclosure after a balancing of the

interests of the person or agency urging nondisclosure, be exempt from disclosure..." Part

2.390(a) continues on to list categories of documents exempt from disclosure-none of Mr.

Epstein's TMI-1 license renewal submissions fall under these document categories.

Furthermore, Mr. Epstein's license renewal submissions do not fit the NRC's definition of

"record" under the Privacy Act of 1974 regulations (10 CFR Part 9, Subpart B), "Record means

any item, collection, or grouping of information about an individual that is maintained by the

NRC, including, but not limited to, his education, financial transactions, medical history,

employment history..." Because Mr. Epstein's submissions do not constitute a record under the

Privacy Act, they cannot be exempted from disclosure under the Act.

The scoping process and comment period on the draft supplemental EIS are both part of the

NRC's 10 CFR Part 51 regulations that implement the National Environmental Policy Act

(NEPA). 10 CFR 51.29(b) states that at the conclusion of the scoping process the NRC staff will

compile a summary of determinations and conclusions reached, i.e., the "Environmental Impact

Statement Scoping Process Summary Report," which was issued in August 2008 for TMI-1. 10

CFR 51.73 requires that each draft EIS is distributed with a request for comments, while 10

CFR 51.91(a) (2) requires that comments received on the draft EIS be attached to the final EIS.

The White House Council on Environmental Quality (CEQ) guidance on scoping states that

every comment received during scoping should be addresses in some manner in the EIS, either

by in-depth analysis or a short explanation as to why the comment was not examined further.

Part 1502.9(b) of the CEQ regulations for implementing NEPA state, "Final environmental

impact statements shall respond to comments as required in Part 1503 of this chapter. The

agency shall discuss at appropriate points in the final statement any responsible opposing view

which was not adequately discussed in the draft statement and shall indicate that agency's

response to the issues raised. "

Appendix E, Chronology of Environmental Review, contains documentation of correspondence

between the NRC and external parties as part of its environmental review of the TMI-1 license

renewal application. In-scope portions of Mr. Epstein's comments submitted at the public

scoping meetings in May 2008 are included in Section A. I of this supplemental EIS, and all of

his scoping comments (available online in ADAMS at ML01330183) are included in the

"Environmental Impact Statement Scoping Process Summary Report, "issued in August 2008.

The Scoping Process Summary Report is referenced at the end of this Appendix and is

available online in ADAMS at ML081920230. Furthermore, Mr. Epstein's "50 questions,"as

contained in his May 2008 scoping comments, were addressed in the "Environmental Impact

June 2009 A-43 NUREG-1437, Supplement 37
Appendix A

Statement Scoping Process Summary Report."Appendix E does not include correspondence

unrelated to the environmental review, such as correspondence regarding the license renewal

safety review or current plant operating issues. Appendix E also does not include press releases

other than those written by the NRC. No changes were made to Appendix E as a result of Mr.

Epstein's submission.

A discussion of zebra mussels (Dreissena polymorpha) and Asiatic clams (Corbicula fluminea)

is contained in Section 2.2.5, Description of Aquatic Resources. At TMI-1 a biocide is applied to

the intake water as it reaches the screen to prevent macrofouling of the cooling system. Section

2.1.3.5, Permitted Discharges, discusses how biocide wastes are discharged as plant

wastewater according to the plant's NPDES permit.

The Campbelltown tornado incident included in Mr. Epstein's comments was added to Section

2.2.2, Air and Meteorology. With regard to droughts, TMI-1 participates in the Cowanesque

Lake water storage program, which is described further in Section 2.1.7. 2, Surface Water Use,

Section 4.3.2, Ground Water Use Conflicts, and Section 4.4.1, Water Use Conflicts. The SRBC

and U.S. Army Corps of Engineers are the responsible agencies for making releases from

Cowanesque Lake during periods of low flow in the Susquehanna River.

Section 5.2 Severe Accidents, states that severe accidents initiated by external phenomena

such as tornadoes, floods, earthquakes, and fires were not specifically considered for TMI-1 in

the GElS (NRC 1996), however, the GElS did evaluate existing impact assessments performed

by the NRC and by the industry at 44 U.S. nuclear plants and concluded that the risk from

beyond design basis earthquakes at existing nuclear power plants is SMALL. Even if such an

event were to occur, the Commission would expect that resultant core damage and radiological

releases would be no worse than those expected from internally initiated events. Based on the

above, the commission concludes that the risk from beyond design basis earthquakes at

existing nuclear power plants is small and additionally, that the risks from other external events

are adequately addressed by a generic consideration of internally initiated severe accidents.

Furthermore, the staff's review of the SAMA analysis is discussed in Section 5.3, Severe

Accidents Mitigation Alternatives, and supporting analyses are contained Appendix F. No

changes to the supplemental EIS were made as a result of Mr. Epstein's comment regarding

earthquakes.

Mr. Epstein's environmental justice concerns include the definition of environmental justice and

emergency preparedness. Mr. Epstein expressed concern that NRC's definition of

environmental justice bears no relation to the Pennsylvania Department of Environmental

Protection's definition. Mr. Epstein also expressed a concern related to environmental justice

that special needs populations, including members of the Amish and Mennonite communities,

might be overlooked in the event of an alert and emergency evacuation.

Nuclear power plant owners, government agencies, and State and local officials work together

to create a system for emergency preparedness and response that will serve all members of the

public in the event of an emergency. The emergency plans for nuclear power plants cover

preparations for evacuation, sheltering, and other actions to protect all residents 'near nuclear

power plants in the event of a serious incident. The Commission has determined that there is no

need for a special review of emergency planning issues in the context of an environmental

review for license renewal. Therefore, decisions and recommendations concerning emergency

NUREG-1437, Supplement 37 A-44 June 2009
Appendix A

preparedness at nuclear plants are ongoing and outside the regulatory scope of license

renewal. In addition, the environmental justice impact analysis conducted by the NRC and the

definitions of minority and low-income populations based on Council of Environmental Quality

(CEQ) guidance under NEPA are presented in Section 4.9.7, Environmental Justice, in the

supplemental EIS. The analysis of impacts to minority and low-income populations, as defined

by the CEQ, is explained in NRC's "Policy Statement on the Treatment of Environmental Justice

Matters in NRC Regulatory and Licensing Actions" (69 FR 52040). No changes to the

supplemental EIS were made in response to Mr. Epstein's comments.

June 2009 A-45 NUREG-1437, Supplement 37
Appendix A

Commenter: Michael Gallagher, Exelon Generation Company, LLC

February 27, 2009

Page 1 of 5

TMI-09-034

Attachment

EXELON GENERATION COMPANY, LLC

COMMENTS ON NUREG-1437, SUPPLEMENT 37, DRAFT

Exelon Generation Company, LLC submits the comments listed below in response to the

U.S. Nuclear Regulatory Commission (NRC) "Notice of Availability of the Draft Supplement 37

to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants, and

Public Meeting for the License Renewal of Three Mile Island Nuclear Station, Unit 1," which was

published in the Federal Register on December 9, 2008 (73 FR 74766).

General Comment

On January 8, 2009, Exelon Generation Company, LLC ("Exelon Generation") officially

integrated the nuclear generation assets held by its subsidiary, AmerGen Energy Company,

LLC ("AmerGen*) into Exelon Generation and dissolved the AmerGen legal entity. Accordingly,

throughout the TMI-1 License Renewal Supplemental EIS, replace "AmerGen Energy Company,

LLC" and "AmerGen" with "Exelon Generation Company, LLC" and "Exelon Generation,"

respectively.

General Comment

Exelon Generation notes that in Chapters 3 and 4 of the TMI Supplemental EIS, the NRC

presents Category 1 issues differently than was previously done in license renewal

Supplemental EISs for other nuclear plants. Previously, Supplemental ElSs for license renewal

included, for each applicable Category 1 issue identified in the GElS, a table that listed the issue

and text that summarized the GElS determination concerning the issue. Otherwise, the text of

the Supplemental ElSs did not address Category 1 issues or discuss site-specific information

related to such issues. Exelon Generation suggests that, if site-specific information related to a

Category I issue is presented in the TMI-1 Supplemental EIS, then it should be made clear

whether the evaluation of impacts for that issue is adopted from the GElS or takes into account

the site-specific information.

Page 2-70, lines 2 & 3

Replace the sentence that reads: "On March 28, 1979, TMI Unit 2 experienced a loss of coolant

accident that resulted in a partial core meltdown, and is considered the nation's worst

commercial nuclear accident (Walker 2004)." with the following sentences: "On March 28, 1979,

TMI Unit 2 experienced a loss of coolant accident that resulted in a partial core meltdown.

Although the accident was the most serious in U.S. commercial nuclear power plant operating

history, off-site releases of radioactivity were very small, and there were no deaths or injuries to

plant workers or members of the public." This alternative text was derived from the "NRC Fact

Sheet on the Three Mile Island Accident (see http:/lwww.nrc.cov/readin-g-rm/doccollectionslfact-sheets/3mile-isle.html).

Exelon Generation believes that the suggested alternative text for the quoted sentence on p. 2-

70, lines 2 and 3, more clearly describes the TMI Unit 2 accident and its significance.

Furthermore, 'Walker 2004," which is the reference cited in the draft Supplemental EIS (p. 2-

70, line 3), is not listed in Section 2.4, "References."

NUREG-1437, Supplement 37 A-46 June 2009
Appendix A

February 27, 2009

Page 2 of 5

TMI-09-034

Attachment

Page 2-70, lines 3 to 5

Page 4-23, lines 35 to 38

Lines 3 to 5 on p. 2-70 contain the following sentence: "Although the [TMI Unit 2] structure is

under 40 years of age, it can be considered potentially eligible for listing on the National

Register of Historic Places under Criterion A, as a site of exceptional importance."

Lines 35 to 38 on p. 4-23 contain the following sentences: "Another potential resource of

historic significance on Three Mile Island is TMI Unit 2. TMI Unit 2 could be considered

potentially eligible for listing on the NRHP under Criterion A, as a site of exceptional importance

but its eligibility has not yet been determined.*

For the following reasons, Exelon Generation suggests that the sentences on pages 2-70 and 4-

23 quoted in this comment be deleted from the final TMI-1 License Renewal Supplemental EIS.

Exelon Generation acknowledges the historic significance of the events that occurred at TMI

Unit 2 on March 28, 1979. Consequently, Exelon Generation will cooperate with the owner of

TMI Unit 2 to commemorate those events in a manner that does not interfere with the eventual

decommissioning of either unit. However, Exelon Generation believes it is premature to

speculate on whether such commemoration could involve the listing of TMI Unit 2 on the

National Register of Historic Places.

Page 4-1, lines 8 & 9

The text states "Some remaining [GELS] issues are not applicable to TMI-1 because of site

characteristics or plant features." Exelon Generation recommends that, for completeness, all

GElS issues (Category 1 and Category 2) that do not apply to continued operation of TMI-1 or

refurbishment activities be identified in an appendix to the Supplemental EIS. This could be

easily accomplished by adding the information to the existing Supplemental EIS Appendix B,

"NEPA Issues for License Renewal of Nuclear Power Plants."

Page 4-12, lines 5 to 7

Page xvi, lines 9 to 14

Page xviii, lines 9 & 10

The text on p. 4-12, lines 5 to 7 states:

"Based on the applicant's assertion that refurbishment activities are planned, slightly higher

doses to members of the public, and the resultant environmental impacts, are expected from

TMI-1 during the refurbishment period."

Also, the text on p. xvi, lines 9 to 14 and the text on p. xviii, lines 9 and 10, both state:

"Slightly higher radiation doses to membersof the public are expected from TMI-1 during the

refurbishment period."

None of these statements is supported by a reference citation or other information presented in

the draft TMI-1 Supplemental EIS. Also, the statements are inconsistent with TMI-1 site-specific

information provided to the NRC Staff during the TMI-1 site environmental audit (Responses to

Questions ENV-53 and ENV-55).

The TMI-1 site-specific information indicates that replacing the steam generators at TMI-1 will

not increase radiological effluents (liquid and gaseous) at TMI-1, and that members of the

June 2009 A-47 NUREG-1437, Supplement 37
Appendix A

February 27, 2009

Page 3 of 5

TMI-09-034

Attachment

(Continued)

public are projected to receive no radiation dose as a result of the TMI-1 steam generator

replacement project.

Exelon Generation believes the NRC Staff's conclusions in the draft TMI-1 Supplemental EIS

were not based on the TMI-1 site-specific information. Rather, it appears that the NRC Staff

relied solely on the generic analysis of human health effects from radiation exposures during

refurbishment presented in the GElS (Appendix C).

Since the GElS analysis determined that the impact on human health of refurbishment is a

Category 1 issue, adoption of the GElS findings without considering TMI-1 site-specific dose

impacts is an acceptable approach because the GElS analysis bounds the planned TMI-1

refurbishment. However, as Section 3.8.1.2 (p. 3-32) in the GElS explains, the GElS analysis

used conservative assumptions, and the use of more realistic data should decrease dose

estimates in most cases.

In Section 3.8.1.5 (p. 3-35), the GElS further states that effluents and dose impacts observed at

example reactor sites (Cooper, Monticello, Nine Mile Point-i, Peach Bottom-2, and Vermont

Yankee) during major refurbishment activities, such as steam generator replacement in the case

of PWRs, did not differ significantly from normal operation. Notwithstanding, the GElS

speculates that "during the 9-month outage, a greater amount of work will be performed and

some of the effluents, especially atmospheric particulates and possibly some liquid effluents

associated with decontamination, may be slightly greater than were found during the [actual]

steam generator changeouts or recirculation piping replacements." Accordingly, the GElS

indicates that each licensee has the opportunity to provide site-specific information regarding

radiation exposures to members of the public, which Exelon Generation did.

Based on the site-specific information provided for TMI-1, the TMI-1 Supplemental EIS should

conclude that refurbishment is not expected to result in increased dose to any member of the

public, even though the GElS analysis concludes that doses to members of the public due to

refurbishment would be slightly higher than during a normal refueling outage. The TMI-1

Supplemental EIS should acknowledge that the TMI-1 conditions are more protective than the

bounding conditions assumed for the GElS analysis.

Specifically, the three sentences quoted at the beginning of this comment should be replaced

with the following sentence or its equivalent

"Based on the applicant's assertion that refurbishment activities will not increase radiological

effluents (liquid and gaseous) at TMI-1, doses to members of the public are expected to be

unchanged from those resulting from normal operations."

In addition, surrounding text should be modified for consistency with the change, and NRC staff

should consider moving the paragraph from p. 4-12, lines 5 to 11, into an appropriate location in

Chapter 3 (Environmental Impacts of Refurbishment) because the contents of these lines deal

with refurbishment impacts rather than impacts of operation. Consistent with its title, the

contents of Chapter 4 (Environmental Impacts of Operation) should focus on environmental

impacts of operation.

NUREG-1437, Supplement 37 A-48 June 2009
Appendix A

February 27, 2009

Page 4 of 5

TMI-09-034

Attachment

Page 8-16. line 3

The NRC Staff's environmental justice (EJ) analysis of the supercritical coal-fired generation

alternative concludes that the impacts would range from "Small to Moderate and would depend

on the location of the power plant site in proximity to minority and low-income populations."

While this statement is, to a degree, correct, the standard for assessing EJ impacts, as set forth

in NUREG-1555, Supplement 1, Section 4.4.3, is whether impacts to minority and low-income

populations would be significant and disproportionate. Thus, if the location of the coal-fired

plant results in significant impacts to all local residents, regardless of their minority or lowincome status, mitigation may not be warranted. The apt inquiry is whether location or other

operational factors result in disproportionate impacts tothe relevant minority and low-income

populace. Exelon Generation recommends that NRC Staff review the EJ impacts analyses for

other alternatives presented in Chapter 8 to verify that the appropriate standard of review is

applied.

Page 8-45, lines 36 to 41

Page 8-46, lines 1 to 3

On pp. 8-45, lines 36 to 41 and 8-46, lines 1 to 3, the draft text states:

"The NRC notes that the energy conservation/energy efficiency alternative has SMALL impacts

in all categories evaluated, and upon shut down of TMI-1, current operating impacts of TMI-1

would cease. Therefore, the energy conservation/energy efficiency alternative is the

environmentally preferred alternative to license renewal. All other alternatives capable of

meeting the needs currently served by TMI-1 entail potentially greater impacts than the

proposed action of license renewal of TMI-1. The no-action alternative does not meet the

purpose and need of this draft SEIS, however if it triggers the energy conservation/energy

efficiency action to replace the capacity currently supplied by TMI-1, it could result in an overall

SMALL impact, as well."

For the reasons set forth below, Exelon Generation disagrees that the energy

conservation/energy efficiency alternative is "capable of meeting the needs currently served by

TMI-1 ." While increased energy efficiency and energy conservation can play a role in long-term

resource planning, there are considerable uncertainties about the costs and effectiveness of

such proposals. As Black and Veatch notes in their work (Pletka, 2004) while there is the

potential for reduction in required long-term energy use, achieving these potential reductions

would require a wide variety of programs targeting behavior by many different sorts of

customers. We have two major concerns. First, the historical record shows that while regulatory

efforts and an increased awareness of efficiency and conservation has led to a slower rate of

load growth over the last 30 years, load continues to grow and per capita electricity use has

continued to increase. Second, while some of the potential savings alluded to in the Black and

Veatch analysis will undoubtedly prove feasible and economical, it is unreasonable to assume

that all of the. potential programs they consider will ultimately prove feasible. The potential 10%

savings they allude to in terms of total energy consumed must be considered an outer bound.

Exelon Generation believes that a more detailed look at the components of programs alluded to

by Black and Veatch would result in a much lower expectation of economical and feasible

June 2009 A-49 NUREG-1437, Supplement 37
Appendix A

February 27, 2009

Page 5 of 5

TMI-09-034

Attachment

(Continued)

reductions in load through increased efficiency and conservation. The EIA forecasts for longterm electricity demand growth, which implicitly assume that long-term trends toward greater

efficiency and conservation are extended in future decades, projects that long-term load growth

from 2007 to 2030 will average over 1 percent. (EIA, Annual Outlook 2009).

In addition to the uncertainty around the costs and effectiveness of potential conservation, it is

also unclear how not granting license renewal to TMI would lead to the implementation of

greater conservation and efficiency measures. If increased conservation and efficiency did not

completely offset the reduction in generation that would accompany the shut-down of TMI, the

remaining loss in generation would most likely be offset by higher use of fossil-fired generation,

probably resulting in higher costs as well as additional emissions.

It is also important to note that many demand-side management programs essentially serve to

peak-shave demand, and reduce peak demand by shifting this demand to other hours of the

day where underlying demand is lower. While this may reduce the need for new generation in

the peak hour, the level of underlying baseload generation - such as nuclear - is likely to be

relatively unaffected.

References

Pletka, R. 2004. "Potential Impact of an Advanced Energy Portfolio Standard in Pennsylvania."

Presented at NREL Energy Analysis Forum, November 9, 2004. Available at URL:

http:/Awww.nrel.gov/analysistforum/docs/2004/pletka.ppt

EIA (U.S. Department of Energy, Energy Information Administration). 2009. Annual Energy

Outlook 2009 Early Release Outlook. DOE/EIA 0383(2009). Washington, D.C. Available at

URL: http:/Awww.eia.doe.,ov/oiaf/aeolpdfloverview.pdf

NUREG-1437, Supplement 37 A-50 June 2009
Appendix A

Response:

The final supplemental EIS has been updated to reflect that AmerGen Energy Company, LLC,

was dissolved into Exelon Generation Company, LLC.

Section 4.8.1, Generic Human Health Issues, opens with a paragraph stating that the staff did

not identify any new and significant information during the license renewal review, and

therefore, there are no impacts related to those issues beyond those discussed in the GELS.

This paragraph was edited to make it clear that "Generic Human Health Issues" represent

Category I human health issues, which the GElS concluded that impacts are SMALL. The

remainder of Section 4.8.1 is a discussion of radiation exposures to the public and occupational

radiation exposures and the information the staff reviewed to verify that the conclusions in the

GElS regarding these issues are valid for TMI-1.

The NRC did not make any changes to Section 2.2.9.2, Historical and Archaeological

Resources, regarding the TMI Unit 2 1979 accident. The NRC believes the current sentence

regarding the accident is sufficient. The Samuel J. Walker reference, Three Mile Island: A

Nuclear Crisis in Historical Perspective, was corrected. No changes were made to Sections

2.2.9.2 and 4.9.6, Historical and Archaeological Resources, regarding TMI Unit 2 as potentially

eligible for listing on the National Register of Historic Places (NRHP). To support the

Pennsylvania Historical and Museum Commission (PHMC) in making their eligibility

determination, Exelon Generation will work with FirstEnergy Corporation (the owner of TMI Unit

2) in arranging access for PHMC personnel to the TMI Unit 2 property (Exelon Generation

2009).

Table B-1, Summary of Issues and Findings, in Appendix B, NEPA Issues for License Renewal

of Nuclear Power Plants, has been edited to identify which GElS issues do not apply to TMI-1

either because TMI-1 does not use that cooling system, or does not feature some other

specified plant or site characteristic.

Conclusions contained in the Executive Summary and in the last paragraph of Section 4.8. 1,

Generic Human Health Issues, have been edited to reflect that refurbishment activities at TMI-1

are not expected to generate an amount of radioactive material that is significantly different from

historical radiological effluent releases, including refueling outage activities.

Mr. Gallagher's comment about environmental justice concerns environmental justice impact

analysis of alternatives and the continued operation of TMI-1, as evaluated in the supplemental

EIS and compared to the environmental justice review standard presented in NUREG-1555,

Supplement 1, Section 4.4.6 (the comment erroneously cites Section 4.4.3). Specifically, the

concern is whether impacts to minority and low-income populations would be significant and

disproportionate. As discussed in the supplemental EIS, the disproportionate effect on minority

and low-income populations from the construction and operation of a new power plant cannot

be determined since it would depend on the proximity of these populations to the location of the

new power plant. It is assumed that the site selected for a new power plant would take into

consideration the potential effects of construction and operation on minority and low-income

communities; and avoid creating, as much as possible, any disproportionate effects. Thus the

impacts on minority and low-income populations from constructing and operating alternative

power plants would likely range from SMALL to MODERATE. The appropriate standard of

June 2009 A-51 NUREG-1437, Supplement 37
Appendix A

review was applied. NRC staff have edited relevant text to clarify that disproportionate adverse

impacts are the primary concern, and that location of potential alternatives may play a role in

determining whether such impacts are ultimately disproportionate or not.

With regard to Mr. Gallagher's comment about whether energy conservation/energy efficiency is

capable of meeting the needs currently served by TMI-1, the NRC staff has modified text in

Section 8.3, Energy Conservation/Energy Efficiency, to indicate that energy efficiency or

conservation could replace the capacity currently supported by TMI-1, rather than to indicate

that denial of renewal could 'trigger" conservation as a replacement for TMI-1. No additional

changes have been made in response to this comment, for the following reasons:

* In the process of developing the TMI-1 draft supplemental EIS, NRC staff reviewed the

study that supported the presentation ("Pletka 2004') that Exelon Generation references

in the comment. NRC staff refers to the study in Chapter 8 of the supplemental EIS. The

study indicates that Pennsylvania alone has 6,872 megawatts (MW) of "near-term"

energy conservation potential. Only 11.7 percent of this potential would be necessary to

satisfy the load served by TMI-1. Thus, as-as Exelon Generation suggests-most of

this potential could "essentially serve to peak-shave demand and reduce peak demand

by shifting this demand to other hours of the day..." and still allow for enough capacity to

offset TMI-1. Further, the 10 percent figure Exelon Generation quotes for total energy

savings-taken from the Pletka 2004 presentation-is based only on Black & Veatch's

analysis of near-term potential. Black-&-Veatch-identified-70,000-gigawatt-hours (GWh)

in total potential, or nearly five times the 16,000 GWh figure cited as 10 percent of

demand in Exelon Generation's source. Thus, the 10 percent figure is not an outer

bound, as Exelon Generation asserts it should be. Black & Veatch note that

conservation potential in Pennsylvania is good and that "[d]ecreased emphasis since

deregulation has left an opportunity to implement energy conservation measures."

* The NRC staff notes that the analysis of conservation potential contained in the draft

supplemental EIS is inherently conservative, in that the staff only considered

Pennsylvania's conservation potential. TMI-1 operates within and serves the PJM

Interconnection, which includes all or parts of many neighboring states. NRC staff did

not consider the conservation potential available in neighboring states. In addition, the

NRC staff did not include "efficiency" as identified by Black & Veatch. Black & Veatch

described efficiency as improvements to existing supply-side resources.

* Finally, while Exelon Generation indicates that the Energy Information Administration

projects long-term load growth of 1 percent through 2030 across the U.S., Pennsylvania

must reduce its overall energy consumption as well as peak energy demand and in the

coming years under the requirements of Act Number 129 (introduced as H.B. 2200, An

Act Amending Title 66 [Public Utilities] of the Pennsylvania Consolidated Statutes).

While the mandated reduction amount is less than the energy produced by TMI-1,

estimates of potential offered by Black & Veatch in the preceding paragraphs suggest

potential beyond the mandated amount. According the Federal Energy Regulatory

Commission (FERC 2009), many neighboring states have similar programs. Maryland

and Ohio have mandates to reduce consumption, Virginia has established a reduction

NUREG-1437, Supplement 37 A-52 -June 2009
Appendix A

goal, Delaware has created a sustainable energy utility with a focus on energy efficiency

and conservation, and New Jersey is currently considering an energy efficiency resource

standard (FERC 2009). New York, though not a part of PJM, also has substantial energy,

efficiency goals, including an overall reduction in electricity consumption.

The NRC staff has made no changes in response to the comment aside from those identified in

the first paragraph of the comment response.

Commenter: Gregory Hanlon, FirstEnergy Corporation

Comments regarding NUREG-1437, Supplement 37, draft; Generic Environmental Impact

Statement (GELS) for License Renewal of Nuclear Plants regarding Three Mile Island Nuclear

Station, Unit 1 (TMI-1)

FirstEnergy appreciates the opportunity to provide comments on the draft GElS Supplement for

TMI-1.

In the discussions of Historic and Archeological Resources (sections 2.2.9 and 4.9.6), there is

reference to potential eligibility for listing Three Mile Island Unit 2 (TMI Unit 2) on the National

Register of Historic Places. As the parent company of GPU Nuclear, the owner of TMI Unit 2,

FirstEnergy recognizes the historical significance of the 1979 events at TMI Unit 2 and their

influence on the entire nuclear industry. Appropriate recognition of these events would not be

expected to affect the ability to comply with decommissioning regulations at TMI Unit 2.

Contact: Gregory H. Hanlon, Director, Fleet Regulatory Affairs

Response:

The comment is noted. No changes were made to the supplemental EiS.

Commenter: Judith Johnsrud, Sierra Club and Pennsylvania Environmental Coalition on

Nuclear Power

Thank you. Am I audible? Good. My name is Judith Johnsrud. Ihold a Doctoral Degree in the

Geography of Nuclear Energy. I have served as an intervener in the licensing of TMI, the

operating license for TMI-1 and TMI-2, and TMI-1 restart following the accident.

I wanted to start my comments with the observation that, so far as I know, most of the

preparation of the EIS was based on existing criteria of the Agency, of the NRC, and no special

information was incorporated from what we may-be learning as the result of climate change. I

suggest to the NRC that it would be extremely important, as communities world-wide begin to

cope with changes in climate thatresult in different consequences that may be far more

damaging to the public than had been anticipated in the development of the EIS.

In addition to this, which I really urge the Agency and the Pennsylvania organization, I really

urge them to take into consideration the importance of preparing for changes in the future, the.

20 year future, hoping that there would not be another 20 year continuation beyond.

I have been asked to present a short presentation on behalf of another organization. In addition

to Sierra Club I do direct the Pennsylvania-based Environmental Coalition on Nuclear Power.

June 2009 A-53 NUREG-1437, Supplement 37
Appendix A

And I'm on the boards of a number of other organizations, including the Optimistic Beyond

Nuclear, which I commend to you all. The Radiation and Public Health Project has summarized

some data that I think also need to be carefully considered, particularly for those who live within

the vicinity within Dauphin County. Their statement begins, new data on high local disease

rates suggest link with TMI. Harrisburg, updated data documenting high rates of infant

mortalities, low weight births, child cancer deaths and thyroid cancer cases in Dauphin County

suggest radioactive discharges from the Three Mile Island Unit 1 nuclear reactor that may be

harming local citizens.

The analysis is presented today with the hope that they will be taken seriously by the Agency,

by the NRC and by the utility. I'm quoted in their statement, continued high local disease rates

in those most vulnerable to radiation exposure raise concerns.

And I want to add there that -- actually, he continues that the National Academy of Sciences in

1999 and again in 2005 concluded that there is not safe dose of ionizing radiation, that there

may be damages that do not show up immediately, there may be damages that will no occur for

a long time into the future but are the result of genetic alterations.

I've been following these issues for a number of years. And, I must say, that is a conclusion

that many specialists in these fields have now reached, that we have allowed far more sources

of radiation into our environment than we human beings and other species are capable of

coping with safely.

The data that I want to present to you now very briefly come from the U.S. Centers for Disease

Control and Prevention. And they show Dauphin County rates exceeded U.S. rates for the

following conditions.

First, a plus 21.1 percent for births under 5 and a half pounds. A 24.2 percent for deaths among

infants in the first month of life. A 28.6 percent for cancer deaths among children under the age

of 20, in other words, those that were born in the aftermath of the accident atTMI-1.

FACILITATOR BO PHAM: Judith, excuse me, could you state which report you're reading from

so we can get it in the record?

MS. JOHNSRUD: Yes, this is from Radiation and Public Health Project.

And, finally, of this short list, a 31.4 percent for the incidence of thyroid cancer among all ages.

Reactors produce over 100 radioactive chemicals to generate electricity.

Most are stored as waste. But, of course, increasingly some of those low dose wastes are

allowed to be released and recycled into consumer products. Some of these are routinely

emitted from local air and water, entering human bodies through breathing and the food chain.

These chemicals damage cells leading to cancer, especially thyroid cancers, and are especially

harmful for infants and children. Three Mile Island, Unit 1 began its operation in 1974 but was

closed in 1979 for a TMI-2 accident from 1979 to 1985 after the meltdown at Unit 2.

Like all reactors, this plant is licensedfor 40 years. The NRC has granted 20 year extensions

for some 51 of the 104 U.S. reactors. The NRC hearing is required by law. It takes place one

month prior to the 30th anniversary of the 1979 meltdown, the worst nuclear accident of U.S.

history. I hope that those of you who live in Dauphin County and those of you who have friends

NUREG-1437, Supplement 37 A-54 June 2009
Appendix A

and family who live in the county will take to heart the implications of this report from the

Radiation and Public Health Project. Thank you.

Response:

In response to Ms. Johnsrud's comment concerning incorporating the impacts of global climate

change into the supplemental EIS, a qualitative discussion of potential climate change impacts

has been added to Section 4.11, Cumulative Impacts.

In response to Ms. Johnsrud's comment regarding low dose wastes being recycled into

consumer products, and low doses routinely emitted from local air and water: all nuclear plants

were licensed with the expectation that they would release radioactive material to both the air

and water during normal operation. Airborne and liquid releases of radionuclides from nuclear

power plants must meet radiation dose-based limits specified in 40 CFR Part 190, 10 CFR Part

20, and the ALARA criteria in. 10 CFR Part 50, Appendix I. Regulatory limits are placed on the

radiation dose that members of the public might receive from all of the radioactive material

released by the nuclear plant. Licensees are required to report liquid, gaseous, and solid

effluent releases as well as the results of their radiological environmental monitoring program

annually to the NRC. The annual effluent release and radiological environmental monitoring

reports submitted to the NRC are available to the public in the ADAMS electronic reading room

available through the NRC website: http://www.nrc.gov/reading-rm/adams.html The NRC's

response to Ms. Marjorie Aamodt's comments on public health and radiation on pages A-21

through A-25 provide a more detailed description the NRC's radiation protection regulations.

The NRC does not allow nuclear power plants to release tools, equipment, scrap metal, trash,

or any other material containing plant-related radioactive material for recycling and reuse. Prior

to removal from the plant site, all material that was in radiation-controlled areas of the plant

must be surveyed to ensure there is no detectable radiation. If any radiation is detected, the

material must be controlled and handled as radioactive material in accordance with NRC

regulations. It will not be released into the public environment for recycling or reuse.

The staff acknowledges the Radiation and Public Health Project study that Ms. Johnsrud cites,

but this study does not provide scientifically defensible information that would cause the NRC to

alter its position that the current radiation protection, safety standards are protective of public

heath and safety and the environment.

The NRC has already fully considered and addressed these issues and Ms. Johnsrud's

comments do not present any significant new information or arguments that would warrant a

change to the TMI-1 supplemental EIS.

Commenter: Thomas C. LeCrone, local citizen

Dear NRC Staff,

Given the reality of global warming and the depletion of fossil fuels, I think that the Three Mile

Island operating license should be renewed. The older technology used at Three Mile Island

and the need for a "new generation" of nuclear facilities in the U.S. should limit the, renewal

license to no more than ten (10) years. It is my hope that the expansion of alternative fuels R &

D will evolve into public support for additional nuclear power plants in the U.S. in the next three

June 2009 A-55 NUREG-1437, Supplement 37
Appendix A

to five years. At that point, Three Mile Island can and should be closed and a new Exelon

Generation Company Nuclear plant licensed and opened in its place.

Pennsylvania utility companies received over $12.5 billion in transition payments over the last

10 years as part of PA electric deregulation. Unfortunately not one new electric plant has been

built in Pennsylvania during this same period. Limiting the renewal period will provide a

framework for planning new generation capacity.

Thank you for your consideration of my thoughts on this important topic.

Response:

10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants,

states that a renewed license will be issued for a fixed period of time, which is the sum of the

additional amount of time beyond the expiration of the operating license (not to exceed 20

years) that is requested in a renewal application, plus the remaining number of years on the

current operating license. The total term of any renewed license may not exceed 40 years. An

applicant may submit a license renewal application requesting a license extension for any length

of time up to 20 years-there are no regulations, stating that an applicant must apply for a 20-

year license extension. However, no plant that has applied for license renewal has requested

less than a 20-year license extension. TMI- I has requested a 20-year license extension. If a

renewed license is granted to TMI- 1, the new expiration of the operating license would be April

19, 2034. However, if at any time TMI- I cannot demonstrate compliance with NRC regulations

and terms of the NRC-issued license, the NRC can revoke, suspend, or modify a license.

Commenter: Diane Little, local citizen

Hi, my name is Diane Little. I live in Lower Paxton Township. I'm not necessarily opposed to

the re-licensing of the power station, because common sense dictates that we do need the

energy.

But common sense also dictates that we are a little bit more prudent in one area that I have

done some research on. This is with regard to the design-basis accidents potential. Basically,

what the containment structure can withstand the impact of, how it is protected. And I just ask

that, as part of the re-licensing, the NRC requires additional measures to strengthen the security

from potential accidents or terrorist attacks with regard to aircraft. I believe that all nuclear

power plants should have additional protection from aircraft. But, TMI is unique in that it is so

close to the Harrisburg International Airport.

And, any that has ever gone there, it's like how is this planned? I don't get it. Anyway,

according to the report, this is touched on briefly in the supplemental draft. It says, the

Commission has determined that the environmental impact of DBA's, which is design-basis

accidents, are of small significance for all plants because the plants are designed to

successfully withstand these accidents.

However, if we go back to that old book that some of you have, remember this old book, on

page 292, because I happened to read it, it says, and I have a copy of this. And this was put

out through the Nuclear Regulatory Commission in 1980. And it says, give me a minute here.

I'll just read it right from the book, then you know I'm not making it up. How's that? It says,

NUREG-1437, Supplement 37 A-56 June 2009
Appendix A

page 292, volume 2, part 1, Three Mile Island, a report to the Commissioners and to the public.

And this is a special inquiry group of the NRC.

The evidence is that the TMI-2 facility is not capable of withstanding the impact of an aircraft

weighing in excess of 200,000 pounds. Okay. It says it right there. And then it says, the

containment structure and other structures designed to withstand certain aircraft impact events

are of an adequate strength to withstand the impact of airplanes which can reasonably be

expected to frequent Harrisburg International Airport.

Now, I did go down to the airport. And I did do some research. We all know that the airport, it's

really not thriving. It's not doing a booming business. But, if you were to take -- let's just use

common sense here. But if you were just to take, they said they have 195 operations per day. I

think that's high. But that's what's on their website. If you were jut to count the jet airplanes,

and they have military aircraft. But, if they have 71,000 operations per year and say 13 percent

of them are jet airplanes, that's about -- just bear with me -- that's like 9,000.

Well, originally in this report -- this is what gets me -- they calculate risk factors. You know you

have to have risk factors. And the risk factor for the accident that did occur was a billion to one,

they say. But it did occur. Anyway, the NRC -- and I say this respectfully, because, like I said,

I'm not necessarily opposed to nuclear power, it says, at this time the Staff concluded that about

2,400 operations per year represented no undue risk to the health or to the safety of the public.

Okay. It says farther down, if it were to increase -- now 200,000 pounds is not a lot. The 747 is

about 700,000 pounds. And they don't have them-there much anymore. I don't know if they do

at all. This is from talking to someone. Although, it does say on their website they do have a

large aircraft, it says. Okay.

Conservatism in the crash probability analysis are consistent with the Staff's judgment that a

significant increase in the frequency of'operations is needed to justify a re-evaluation of the risk

to the public of larger than design-basis aircraft -- that's aircraft over 200,000 pounds.

Corrective measures, such as restrictions of air space in-the site of the vicinity or hardening of

plant structures could potentially be undertaken. Alternatively, plant shutdown may be required

if the crash probability becomes unacceptably high or large.

Now, what do we have? We have a unique situation with Three Mile Island Nuclear Station.

The airport was well before nuclear power plant. And I'm not opposed to re-licensing if more

prudent measures are taken.

Let's just use common sense. Probably a lot of you are thinking, it's a good idea to have a little

bit more protection from aircraft, but it's kind of like doubling that emphasis if you have a nuclear

power plant that's so close to an airport. And I know this hasn't been touched on much in the

report. I did read the supplemental.

But, anyway, just one last point, there's a Congressional Research Service Report that was

written August 8th, 2007. And this is Congressional Research Service, the Library of

Commerce, prepared for members and committee of Congress. Anyway, and I'll give this

report. It says the DBT, which is the design-basis threat final rule excluded aircraft attacks,

which raise considerable controversy. In approving the rule NRC rejected a petition from the

June 2009 A-57 NUREG-1437, Supplement 37
Appendix A

Union of Concerned Scientist to require that nuclear plants be surrounded by aircraft barriers

made of beams and cables. It's called the bedge hedge concept.

And critics of the rules charge that deliberate aircraft crashes were a highly plausible mode of

attack. Anyway, basically what I see and I have read a majority of the-report, the risk is "small."

And small is pretty relative.

I really think that what was written in 1980 is a promise. And I think that it should be

investigated because TMI does have a unique threat. And the new nuclear power plants are

putting more safety measures into the design with the extra steel inside the containment

structure.

Here's my closing. My closing is, okay, since there's going to be a lot of remodeling and

construction at the TMI Nuclear Station I think it would be a good time, it would make sense to

also consider doing some construction to improve security with regard to aircraft impact. Thank

you.

Response:

Ms. Little's comment concerns the safety of TMI-1 in the event of an aircraft crash into the plant.

She would-like to see improvements in plant structures that could increase resistance to aircraft

impact.

The NRC issued a final rule in February 2009 that requires applicants for new power reactors to

access the ability of their reactor designs to avoid or mitigate the effects of a large commercial

aircraft impact. This new rule does not apply to existing power reactors.

The NRC believes that the best approach to dealing with threats from aircraft is through

strengthening airport and airline security measures. Consequently, the NRC continues to work

closely with the appropriate Federal agencies to enhance aviation security and thereby the

security of nuclear power plants and other NRC-licensed facilities. Shortly after the September

11, 2001 attacks, NRC, working with representatives of the Federal Aviation Administration

(FAA) and Department of Defense (DOD), determined that a Notice to Airmen (NO TAM), issued

by the FAA, was the appropriate vehicle to protect the airspace above sensitive sites. This

NO TAM strongly urged pilots to not circle or loiter over the following sites: nuclear/electrical

power plants, power distribution stations, dams, reservoirs, refineries, or military installations.

Physically shielding (i.e., airplane-resistant cover) vital nuclear or non-nuclear installations from

attacks by large aircraft being used as missiles is not the approach adopted by the Federal

government to protect the nation. With respect to potential terrorist attacks by air, Federal

government efforts have increased substantially since September 11, 2001. Those efforts

include enhanced airline passenger and baggage screening, strengthened cockpit doors, and

the Federal Air Marshals program, among others. Federal law enforcement and intelligence

agencies have increased efforts to identify and mitigate potential aircraft related threats before

they can be carried out. In more than one case, the DOD and FAA have acted to protect

airspace above nuclear power plants in response to threats at the time thought to be credible

but which were later determined to be non credible. These and other government wide efforts

have improved protection against air attacks on all industrial facilities, both nuclear and non

nuclear. The NRC, other agencies of the Federal government, the local governments, and the

NUREG-1 437, Supplement 37 A-58 June 2009
Appendix A

licensees have taken comprehensive and in-depth actions to enhance NRC's defense-in-depth

philosophy, including, against air attacks. These actions have resulted in significant improvement

of nuclear plant security.

Sections 5.2 Severe Accidents discusses the impacts of severe accidents, including sabotage.

The GElS findings state that compliance with the NRC regulatory requirements under 10 CFR

Part 73, Physical Protection of Plants and Materials, provide reasonable assurance that the risk

from sabotage is SMALL. Even if such events were to occur, the Commission would expect that

resultant core damage and radiological releases would be no worse than those expected from

internally initiated events. Based on the above, the commission concludes that the risk from

sabotage at existing nuclear power plants is small and additionally, that the risks from other

external events (such as floods, earthquakes, and tornados), are adequately addressed by a

generic consideration of internally initiated severe accidents.

Furthermore, the NRC's environmental review is confined to environmental matters relevant to

the extended period of operation requested by the applicant. Appropriate safeguards and

security measures have been incorporated into the TMI-1 site security and emergency

preparedness plans. Any required changes to emergency and safeguards contingency plans

related to terrorist events will be incorporated and reviewed under the operating licenseindependent of license renewal. The comment provides no new information and does not

pertain to the scope of license renewal under 10 CFR Part 51 and 54. No changes were made

to the supplemental EIS.

June 2009 A-59 NUREG-1437, Supplement 37
Appendix A

Commenter: Kevin Magerr, U.S. Environmental Protection Agency, Region III

,-D Sa4

rT- UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

P •REGION III

1650 Arch Street PRO o Philadelphia, Pennsylvania 19103-2029

March 4, 2009

Chief, Rulemaking, Directives, and Editing Branch

U.S. NRC

Mail Stop T6-D59

Washington, D.C. 20555-0001

RE: Generic Draft Environmental Impact Statement for License Renewal of Nuclear Plants

Supplement 37 Regarding Three Mile Island Nuclear Station, Unit 1 December 2008 CEQ

#20080503

Dear Sir/Madam:

The U.S. Environmental Protection Agency (EPA), Region 3, reviewed the abovereferenced document pursuant to the National Environmental Policy Act (NEPA), Council on

Environmental Quality (CEQ) regulations (40CFR Parts 1500-1508), and Section 309 of the

Clean Air Act. Based on our review of the Draft Environmental Impact Statement (DEIS), EPA

has rated the environmental impacts ofthe preferred alternative as "EC" (Environmental

Concerns) and the adequacy of the impact statement as "2" (Insufficient Information). A

description of our rating system can be found at:

http ://www.epa.gov/compliance/nepa/comments/ratings.html.

The Generic DEIS states that the purpose and need for the proposed action (issuance of a

renewed license) is to provide an option that allows for power generation capability beyond the

term of the current nuclear power plant operating license, and to meet future system generating

needs, as determined by State, utility and where authorized, Federal (other than NRC) decisionmakers.

The Generic DEIS states on page 3-3 that the replacement generators needed for this

project will be manufactured in France and transported to the Three Mile Island-i site.

Transportation will be a combination of boat, barge, rail, and road. AmerGen (project sponsor)

will be required to meet all Federal, State, and local requirements that may be applicable to

dredge or fill activities, temporary or permanent removal of route interferences (such as narrow

tunnels, and low-hanging overhead wires), and movement of wide or heavy loads over rail and

roadways. Examples include temporary redirecting of streams, cofferdams, weight-bearing

modifications to bridges, etc. There may also be air quality impacts associated with the

transportation of the generators that are not discussed in this document.

Printed on 100% recycled/recyclable paper with 100% post-consumerfiber and process chlorine free.

Customer Service Hotline: 1-800-438-2474

NUREG-1437, Supplement 37 A-60 June 2009
Appendix A

AmeiGen has contracted a vendor to conduct a detailed study of the steam generator

transport process. The transportation study is scheduled to be completed in spring 2009. Until

the study is complete, AmerGen cannot provide specific information regarding potential

transportation routes for the replacement steam generators, work areas within the routes, or

Federal, State, or local permits required for potential routes. EPA requests that the Final

Environmental Impact Statement include the additional information on the transport process, its

potential impacts and efforts to avoid environmental impacts.

The project team should work with state and federal resource agencies as the project

develops to avoid and minimize impacts to the public and environment. We also recommend

coordinating with the appropriate state and federal agencies annually to address any impacts to

listed species and their habitats.

Thank you for the opportunity to offer these comments. If you have any questions, please

contact me at (215) 814-5724.

Sincerely,

iEnrmaglerr

Environmental Engineer

Printed on 100% recycled/recyclable paper with 100% post-consumer fiber and process chlorine free.

Customer Service Hotline: 1-800-438-2474

June 2009 A-U 1 NUI(W-14,i(, ~uppiement 3( June 2009 A-to1 NUKtU-14.3t, Supplernent.37
Appendix A

Response:

The TMI- 1 draft supplemental EIS received a rating of EC-2 (Environmental Concerns,

Insufficient Information) from the U.S. Environmental Protection Agency because information

regarding the transportation of the steam generators was unavailable at the time of publication

for review and incorporation into the draft EIS findings. Since then, the NRC has received

updated information from Exelon Generation and AREVA, the steam generator vendor,

regarding the transportation route of the steam generators from Port Deposit, Maryland, to the

TMI-1 site in Pennsylvania. This information has been incorporated into Chapter 3,

Refurbishment. Exelon Generation has stated that it will coordinate with all appropriate state

and Federal agencies to avoid or minimize environmental impacts, and will obtain all necessary

permits required for the transportation and installation of the new steam generators.

Commenter: Mary Osborn Ouassiai, Concerned Mothers and TMI Alert

Mary Osborn. I'd like to know how many curies a day TMI Unit 1 releases, how many curies a

month TMI-1 releases, how many curies a year TMI-1 releases. I know Unit 2 what they were

releasing. But I don't know what Unit 1 does.

Response:

Information on how much radioactivity is released from a nuclear power plant is public

information that is readily available in the ADAMS electronic reading room available through the

NRC website: http://www. nrc. gov/reading-rm/adams. htmL Every NRC licensed nuclear power

plant, including TMI-1, is required to submit an annual radioactive effluent release report that

contains a summary of all the types and amounts (i.e., curies) of radioactive material released

into the environment. The report also contains the dose to members of the public calculated

from the radioactive effluents. It is important to note that the NRC regulates the amount of

radioactive effluent discharged from a nuclear power plant by radiation dose, not on the amount

of curies. The dose is calculated based on the types and amounts of radioactive material

discharged into the environment and dispersion models that account for the receptor (i.e., river,

lake, or ocean) for the waste and the exposure pathway to a person. The dose will be different

for each plant not just because of the amount of curies released but because of the different

mixture of radionuclides each plant releases. Each radionuclide has its own specific dose

conversion factor that is part of the dose calculation. The resulting dose from the effluents is

required to be below NRC's radiation protection standards. No changes to the supplemental EIS

were made based on this comment.

NUREG-1437, Supplement 37 A-62 June 2009
Appendix-A

Letter Submitted by Mary Osborn Ouassiai dated February 27, 2009 (Please see ADAMS

Accession Number ML090680766 for the complete document submission including articles Ms.

Osborn references at the end of her comment.)

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Appendix A

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June 2009 A-67 NUREG-1 437, Supplement 37
Appendix A

Response:

Ms. Osborne's comments include concerns about the radiological impacts of the TMI Unit 2

1979 accident and the current operation of TMI-1, the NRC's definition of "affected environment"

in Chapter 2, and the storage facility that will house the old steam generators at the TMI-1 site

until the plant is decommissioned.

With regard to Ms. Osborn's question about the definition of the "affected environment"- The

description of the affected environment is affected by site- and plant-specific factors, and the

degree of detail is scaled according to the anticipated magnitude of potential impacts. NUREG1555, Supplement 1: Environmental Standard Review Plan, Standard Review Plans for

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

that the description of the affected environment should be sufficient to support land use and

socioeconomic assessments. When describing the affected environment, the NRC will typically

provide 6- and 10-mile (50- and 80-kilometer) maps of the site and vicinity. These maps may

show site boundaries, the exclusion area, current site structures and facilities, county and local

municipality boundaries, place names, residential areas, airports, industrial and commercial

facilities, roads, railroads, major land uses, utilities rights-of-way, rivers and other bodies of

water, wetlands, designated Federal, State, and local parks and natural areas, trust lands,

historic and archaeological sites, Native American tribal lands, military reservations, and

nonattainment and maintenance areas defined under the Clear Air Act, as amended.

With regard to Ms. Osborne's question about whether the steam generator storage facility will

be resistant to aircraft impacts: the steam generator storage facility will be designed to include a

watertight roof membrane and reinforced concrete thick enough to provide radiological shielding

to ensure that dose rates will remain within the limits set in 10 CFR Part 20, "Standards for

Protection Against Radiation." Similar to the responses to Ms. Little and Ms. Aamodt's

comments regarding aircraft impacts at the TMI-1 site, the NRC's environmental review is

confined to environmental matters relevant to the extended period of operation requested by the

applicant. Appropriate safeguards and security measures have been incorporated into the site

security and emergency preparedness plans. Any required changes to TMI-1 site emergency

and safeguards contingency plans with regard to the new steam generator storage facility and

potential terrorist events will be incorporated and reviewed under the operating license. The

comment provides no new information and does not pertain to the scope of license renewal

under 10 CFR Parts 51 and 54. No changes were made to the supplemental EIS.

Ms. Osborn provided the NRC staff with the following photocopied articles and information

related to radiation health effects. "Farmers Ridicule NRC Animal - Many Problems Noted

Before TMI" by Nancy Namoski; "Dairy Farming Downwind From Nuclear Power" by Chris

Nord; slide from Mary Osborn with observations of deformed plants and flowers; letter from Carl

J. Johnson, M.D. and Karl Z. Morgan, Ph.D. discussing the radiation exposures reported for

military personnel during a nuclear bomb exercise at the Nevada Test Site; "The Bulletin of the

Torrey Botanical Club" by James E. Gunckel, which discusses abnormalities in plants collected

in the area of Three Mile Island after the accident; "Dose-Rate Conversion Factors for External

Exposure to Photon and Electron Radiation from Radionuclides Occurring in Routine Releases

from Nuclear Fuel Cycle Facilities"by D.C. Kocher in the April 1980 issue of Health Physics;

"Safety Related Incidents at Three Mile Island Nuclear Power Plant" compiled from information

NUREG-1437, Supplement 37 A-68 June 2009
Appendix A

in the journal Nuclear Safety; "Isotopes Found In Area Again, "by John M. Baer in the Patriot

newspaper; "Where Radioactive Elements Concentrate in the Body, " a drawing of a cutaway

human body showing the organs where radionuclides can concentrate; "Three Mile Island

Dosimetry Reality," a collection of notes and radiation information related to the accident at TMI;

"Map of the area surrounding TMI'. a comment, 'fallout is Blowlin the ... downwind... ', anda

map of a neighborhood in the downwind location from TMI-1 showing the location of people

experiencing metallic taste and thyroid ills. These articles are available in ADAMS at

ML090680766.

The staff acknowledges the articles and information provided, but they do not provide

scientifically defensible information that would cause the NRC to alter its position that the

current radiation protection safety standards are protective of public heath and safety and the

environment.

The NRC's primary mission is to protect the public health and safety and the environment from

the effects of radiation from nuclear reactors, materials, and waste facilities. The NRC's

regulatory limits for radiological protection are set to protect workers and the public from the

harmful health effects of radiation on humans. The limits are based on the recommendations of

standards-setting organizations. Radiation standards reflect extensive scientific study by

national and international organizations (International Commission on Radiological Protection

[ICRP], National Council on Radiation Protection and Measurements [NCRP], and the National

Academy of Sciences [NAS]) and are conservative to ensure that the public and workers at

nuclear power plants are protected.

Health effects from exposure to radiation are dose-dependent, ranging from no effect at all to

death. Above certain doses, radiation can be responsible for inducing diseases such as

leukemia, breast cancer, and lung cancer. Very high (hundreds of times higher than a rem),

short-term doses of radiation have been known to cause prompt (or early, also called "acute')

effects, such as vomiting and diarrhea, skin burns, cataracts, and even death.

Although radiation may cause cancers at high doses and high dose rates, currently there are no

reputable scientifically conclusive data that unequivocally establish the occurrence of cancer

following exposure to low doses and dose rates, below about 0. 1 Sievert (10 rem). However,

radiation protection experts conservatively assume that any amount of radiation may pose some

risk of causing cancer or a severe hereditary effect and that the risk is higher for higher radiation

exposures. Therefore, a linear, no-threshold dose response relationship is used to describe the

relationship between radiation dose and detriments such as cancer induction. Simply stated,

any increase in-dose, no matter how small, results in an incremental increase in health risk.

This theory is accepted by the NRC as a conservative model for estimating health risks from

radiation exposure, recognizing that the model probably over-estimates those risks. Based on

this theory, the NRC conservatively establishes limits for radioactive effluents and radiation

exposures for workers and members of the public, as found in 40 CFR Part 190, 10 CFR Part

20, and 10 CFR Part 50, Appendix L Regulatory limits are placed on the radiation dose that

members of the public might receive from all of the radioactive material released by the nuclear

plant combined. Licensees are required to report liquid, gaseous, and solid effluent releases as

well as the results of their radiological environmental monitoring program annually to the NRC.

The annual effluent release and radiological environmental monitoring reports submitted to the

June 2009 A-69 NUREG-1437, Supplement 37
Appendix A

NRC are available to the public in the ADAMS electronic reading room available through the

NRC website: http://www.nrc.qpov/readinq-rm/adams.htmL.

The amount of radioactive material released from nuclear power facilities is well measured, well

monitored, and known to be very small. The doses of radiation that are received by members of

the public as a result of exposure to nuclear power facilities are so low that resulting cancers

have not been observed and would not be expected. Although a number of studies of cancer

incidence in the vicinity of nuclear power facilities have been conducted, there are no studies to

date that are accepted by the scientific community that show a correlation between radiation

dose from nuclear power facilities and cancer incidence in the general public. Specific studies

that have been conducted include:

* In 1990, at the request of Congress, the National Cancer Institute conducted a study of

cancer mortality rates around 52 nuclear power plants and 10 other nuclear facilities.

The study covered the period from 1950 to 1984, and evaluated the change in mortality

rates before and during facility operations. The study concluded there was no evidence

that nuclear facilities may be linked causally with excess deaths from leukemia or from

other cancers in populations living nearby.

" In June 2000, investigators from the University of Pittsburgh found no link between

radiation released during the 1979 accident at Three Mile Island power plant and cancer

deaths among nearby residents. Their study followed 32, 000 people who lived within five

miles of the plant at the time of the accident.

" In 2000, the Illinois Public Health Department compared childhood cancer statistics for

counties with nuclear power plants to similar counties without nuclear plants and found

no statistically significant difference.

* In January 2001, the Connecticut Academy of Sciences and Engineering, issued a

report on a study around the Haddam Neck nuclear power plant in Connecticut and

concluded radiation emissions were so low as to be negligible.

" The American Cancer Society in 2001 concluded that although reports about cancer

clusters in some communities have raised public concern, studies show that clusters do

not occur more often near nuclear plants than they do by chance elsewhere in the

population. Likewise, there is no evidence that links Sr-90 with increases in breast

cancer, prostate cancer, or childhood cancer rates. Radiation emissions from nuclear

power plants are closely controlled and involve negligible levels of exposure for nearby

communities.

* Also in 2001, the Florida Bureau of Environmental Epidemiology reviewed claims that

there are striking increases in cancer rates in southeastern Florida counties caused by

increased radiation exposures from nuclear power plants. However, using the same data

to reconstruct the calculations on which the claims were based, Florida officials were not

able to identify unusually high rates of cancers in these counties compared with the rest

of the State of Florida and the nation.

To ensure that the plants are operated safely within regulatory limits, the NRC licenses the

plants to operate, licenses the plant operators, and establishes technical specifications for the

operation of each plant. The NRC provides continuous oversight of plants through its Reactor

Oversight Process (ROP) to verify that they are being operated in accordance with NRC rules

NUREG-1437, Supplement 37 A-70 June 2009
Appendix A

and regulations. The NRC has full authority to take whatever action is necessary to protect

public health and safety and may demand immediate licensee actions, up to and including a

plant shutdown.

The NRC staff has not identified any new and significant information during its independent

review of the TMI- I Environmental Report, Annual Radioactive Effluent Release reports, Annual

Radiological Environmental Operating reports, and environmental site audit. The NRC has

already fully considered and addressed these issues and the comments do not present any

significant new information or arguments that would warrant a change to the TMI-1

supplemental EIS.

Commenter: Laura Piraino, Sierra Club

I just have a very brief statement. I was very encouraged that the NRC is considering energy

efficiency as an alternative consideration and investment, which the Sierra Club very much

supports, reducing demand through demand-side management, energy efficiency, green design

construction, and technologies, particularly non-polluting renewable energy technologies.

But, coming from previously the College of Engineering at Penn State, I want to share with you

a quote from a Department of Energy Office of Energy Efficiency and Renewable Energy report

in 1997 since you're considering energy efficiency. A 30 percent improvement in U.S. building

efficiency would reduce energy bills for Americans by 75 billion dollars in 15 years and eliminate

the need for 80 new nuclear power plants over the next 20 years.

Building codes are up for review in the State of Pennsylvania. And that 30 percent improvement

in building efficiency could be achieved through improved building codes. Thank you.

Response:

The NRC acknowledges Ms. Piraino's comment. No changes were made to Section 8.3, Energy

Conservation/Energy Efficiency regarding this comment.

Cornmenter: Scott Portzline, TMI Alert

Afternoon Meeting

Sarah, you gave me -- yes, I'll have to take a few minutes. I have some questions. When there

was a recent earthquake that didn't register at Three Mile Island, has that problem been

resolved with the sensitivity of the monitoring? It's part of the environmental impact. Is there

anyone that would like to answer that question? Is there a reason we have this meeting?

The only difference between this type of meeting here in the United States and in East

Germany, they wouldn't even allow you to have a comment. But what good does it do you to

give a comment or have concerns or public participation if we don't get answers? So, the whole

setup is ridiculous. We don't get answers to our questions.

With the security issue that I brought up at the earlier meetings, I showed how there would be

an environmental impact if they implemented security to deny intruders entrance to the bridges,

access to the bridges or boats to go underneath that. Was that examined in your environmental

impact analysis? Sarah is saying no. She's not at a microphone. No, that's out of scope.

Again, what good does it do to raise an issue?

June 2009 A-71 NUREG-1437, Supplement 37
Appendix A

I didn't even ask a question. But I gave a comment and it wasn't even examined. The NRC has

no problem with breaking its own rules. We filed a petition for rule making to have entrance

guards, site protection officers at the entrances of nuclear plants. For seven years they sat on

that decision and broke their own guidelines on more than 40 occasions. So, if I'm sifting here

at a meeting and I interrupt or maybe seem a little bit out of line, I'm still 37 times shy of the 40

plus times the NRC hasn't followed their rules and guidelines.

Victor Gilinsky, former NRC Chairman, says that the public is virtually shut out of this process

and that the NRC has been very effective at public input being squashed. That's exactly what's

happening. It's really a waste of time to be here. But I still need to say what I think is right.

I think another problem, Sarah, that should come up with the water issue is you concluded that

the impact would be small. But, you know, the weather is changing. We have more frequency

of droughts and more frequency of floods. In particular with droughts, the impact could become

at least moderate and possibly severe. Was that examined in the environmental impact? Can

you respond on the record, please?

MS. LOPAS: Briefly. I'll just say real quickly that that's what the Cowanesque Water Storage

Project looks to alleviate, is droughts. That's the short answer.

MR. PORTZLINE: So, in other words, they have an optimistic plan, an overly optimistic plan to

release more water. Of course, if there's a drought, where'd you get it?

Let's see. I'd like to know how long the steam generators that are radioactive will be sitting in

the parking lot at Three Mile Island and be monitored before they are taken away from the plant.

Is there someone who can answer that question? I'd like to have it on the record, would that be

all right. But you do have a court appointed transcription service. So these are official

documents and records. Yet you don't want to have an official statement on those.

I've stated it enough times. We just keep bumping our heads on that same problem. I guess

the last thing I'll do then, because this is largely just an exercise in suppression, suppression of

actual, valuable, public exchange with our government.

Could you please turn on the computer? The little presentation is pretty much one of the

portions of the same thing I presented a year ago. The most annoying problem to me with the

environmental impact analysis is that the long-term waste storage, the financial considerations

of that are not part of this rule or process.

So here we have a environmental impact analysis that excludes the largest issue of them all.

And I don't know if we can play that video or not. You'll probably have to put a microphone next

to the speaker. If Matt could put a microphone near the speaker that might do it. If it doesn't,

we'll compensate or just stop. Okay. If it's not playable you'll be able to view it at the back.

But what it talks about is that the environmental impact analysis excluding the financial

considerations of waste is a folly, one of mankind's greatest follies. Because the payment

schedule will go on forever. And if you drew a one inch line on a sheet of paper and let that

equal one year, keep drawing that line until you're 72,000 miles in space. And that's your

payment schedule. How can that be fiscally responsible to pay for nuclear waste forever? We

benefitted from nuclear waste for 50 years. But we're going to pay for it longer -- well, the sun

will engulf the earth before you've made your last payment. I don't care if we need nuclear

NUREG-1437, Supplement 37 A-72 June 2009
Appendix-A

energy or not. Fiscally it's a failure. Okay. I guess that's it. If you want to see the video, you

can see it in the back. It will be online at TMIA.com pretty soon too.

Evening Meeting

For me that is the biggest problem that we have with environmental scoping, the most important

issue of all the longest lasting is not even on the table. That's a real problem.

I agree with Eric. That's a very odd Houdini act he's involved with. I certainly understand the

feeling because, as I said this afternoon, we filed a petition for rule-making with the Nuclear

Regulatory Commission on entrance guards, site protection officers to be required at the

entrances of all nuclear power plants. And, on 40 occasions, over a seven year period, the

NRC did not follow its own guidelines and broke its own rules. So it really does feel like -- and is

our experience, not just a feeling.

It's our experience that it doesn't do much good to participate in these hearings anymore,

whether it be the annual safety assessment of Three Mile Island where we can ask questions

and the NRC can answer but the company feels that it's not allowed to answer. At least that's

what the Vice President told me at the last meeting. So he doesn't even know the rules of how

the meeting goes. This gets to be old. And I'm not saying anything new tonight compared to

what I said this afternoon.

But there is one leftover question, and that was the concerns about the steam generator that will

be in the parking lot at Three Mile Island for a while. The answer given to me at the lunch break

was that there is no regulation saying how long that can be there, that it will be monitored for

radiation. I sure would like to see that monitoring be implemented into Eric's EMFR radiation

monitoring network. They should have a feed to that information also.

So my question to Exelon here tonight, and I know there's a couple people at least from Exelon,

what is the plan? How long will that steam generator be there? That's an expensive item to

move because it's enormously heavy. And there's going to be failures in the nuclear industry

just like there is in every other economic industry we have right now.

And there's going to be companies walking away. And so I think the State of Pennsylvania

would be concerned too about what they're going to walk away from and to try to minimize

Pennsylvania's exposure financially and radiologically.

So, how long will the steam generators remain at the parking lot, so to speak?

Why doesn't the Nuclear Regulatory Commission have a limitation? For how long they can

store nuclear waste on their site. As long as you have a radioactive source term of this degree

you have to have a license. And that's why even Unit 2 has to have a special license for postfuel monitored storage. So there's a specific classification. I want to know what the specifics

are for the Nuclear Regulatory Commission regarding the steam generator's storage and what

Exelon's plans are. And if you haven't thought about that, you're not doing your job. And I want

you to do your job.

Well, I would hope that Pennsylvania Department of Environmental Resources with their Bureau

of Radiation Protection, I see Mike back there, I hope you're paying attention to what some of

June 2009 A-73 NUREG-1 437, Supplement 37
Appendix A

the other states are doing, asking some hard questions and getting some court rules and getting

some commitments.

And, I think with the economic crises that we have today, it changes as to whether we could

have another flood that could impact even the storage of the steam generators, that

Pennsylvania will make some demands here and play a little more hardball. I mean, this is the

state that suffered the scariest and most dangerous accident in the United States. And you owe

it to us, and so does the NRC, to give us good answers.

We're asking good questions. The last thing I want to say is, let me give you a quick lesson in

security. That's what I do most of all, research in sabotage and terrorism in nuclear power

plants. It will be 25 years come April. And cyber-security is of course the new frontier for

terrorism. It happened right here in Harrisburg, actually, with a water treatment facility where a

hacker was able to take control of what's called Scada system. The engineers here know what

that means. And with that system they could disable the water treatment facility, poisoned us

with large release of chlorine, possibly, done some nasty things.

And so, the NRC is quite familiar with what I'm talking about. So, when I give you my flash drive

and you put it in your computer, and I appreciate that, so I can show the video, you've once

again broken policy -- As she says, it's her personal computer, and so was - what did you say?

By the way, a true friend doesn't stab you in the back, he stabs you in the front. So that's why

I'm making a public display of it. But I've had this conversation with the NRC on several other

occasions. And it continues to happen. The laptop that was used by the person who infiltrated

the Harrisburg Water Treatment Facility was also a home computer, a personal computer. And

one day you'll find yourself at work with that and using that. Well, there's exceptions to

everything. Maybe you won't. But it's not proper for the Nuclear Regulatory Commission to

allow people access to their computer like this. There could be a worm. There could be a data

monitor on my flash drive. I could have pulled information off of her computer right there. And

so, what I'm proposing is that in the future people like me who want to show video presentation

bring their own laptop and then it's only going through the projector, which has no -- well, I'm

sure that capability is around the corner too. But I don't think that should be happening. Okay,

that's it.

Response:

Mr. Portzline's concerns include the recent low-magnitude earthquake experienced in the

Lancaster area, drought and water use issues at TMI-1, the disposal of spent fuel, and nuclear

security issues.

Mr. Portzline's earthquake comment refers to the December 27, 2008, 3.3 magnitude

earthquake that was felt in the Lancaster County area. Section 5.2, Severe Accidents, states

that severe accidents initiated by external phenomena such as tornadoes, floods, earthquakes,

and fires were not specifically considered for TMI-1 in the GElS (NRC 1996), however, the GElS

did evaluate existing impact assessments performed by the NRC and by the industry at 44 U.S.

nuclear plants and concluded that the risk from beyond design basis earthquakes at existing

nuclear power plants is SMALL. Even if such events were to occur, the Commission would

expect that resultant core damage and radiological releases would be no worse than those

expected from internally initiated events. Based on the above, the commission concludes that

NUREG-1437, Supplement 37 A-74 June 2009
Appendix A

the risk from beyond design basis earthquakes at existing nuclear power plants is small and

additionally, that the risks from other external events, such are floods, are adequately

addressed by a generic consideration of internally initiated severe accidents. In addition, the

staff's review of the SAMA analysis is discussed in Section 5.3, Severe Accidents Mitigation

Alternatives, and supporting analyses are contained in Appendix F.

Mr. Portzline also refers to comments made at the May 1, 2008 scoping meetings regarding

environmental impacts of security-related improvements at TMI-1. As was discussed in the

August 2008 "Scoping Process Summary Report" (ADAMS No. ML081920230), security issues

such as safeguards planning are not tied to license renewal, but are considered to be issues

that need to be dealt with constantly as a part of the current operating licenses. Security issues

are periodically reviewed and updated (and extended) at every operating plant. These reviews

will continue throughout the period of any extended license. When issues related to security are

discovered at a nuclear plant, they are addressed immediately, and any necessary changes are

reviewed and incorporated under the operating license-such changes are not postponed until

the period of extended operation. Proposed security changes (or any type of license

amendment) that do not meet the NRC's criterion for Categorical Exclusion (detailed in 10 CFR

Part 51.22) will require a NEPA review, and the NRC will perform an environmental assessment

to review the impacts of the proposed action, i.e., the license amendment. The comments

provide no new information and do not pertain to the scope of license renewal under 10 CFR

Part 51 and 54. No changes were made to the final supplemental EIS.

With regard to Mr. Portzline's comment about the increasing frequency of droughts, TMI-1

participates in the Cowanesque Lake water storage program, which is described further in

Section 2.1.7.2, Surface Water Use, Section 4.3.2, Ground Water Use Conflicts, and Section

4.4.1, Water Use Conflicts. SRBC and the U.S. Army Corps of Engineers are the responsible

agencies for making releases from the Cowanesque Lake during periods of low flow in the

Susquehanna River.

Mr. Portzline showed a brief presentation at the evening meeting that discussed the issue of

spent fuel disposal. The safety and environmental effects of spent fuel storage on site have

been evaluated by the NRC and, as set forth in the Waste Confidence Rule -(10 CFR 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, including license

renewal. Onsite spent fuel storage is considered a Category I issue, which was evaluated in the

GElS, NUREG-1437; therefore, accidents would be included within the analysis of the Category

1 issue of on site spent fuel storage. The GElS is based upon the assumption that storage of

the spent fuel onsite is not permanent. The GElS considered a variety of spent fuel and waste

storage scenarios, including onsite storage of these materials for up to 30 years following

expiration of the operating license, transfer of these materials to a different plant, and transfer of

these materials to an Independent Spent Fuel Storage Installation (ISFSI). For each potential

scenario, the GElS determined that existing regulatory requirements, operating practices, and

radiological monitoring programs were sufficient to ensure that impacts resulting from spent fuel

and waste storage practices would be SMALL, and therefore were a Category 1 issue.

June 2009 A-75 NUREG-1437, Supplement 37
Appendix A

Regarding Mr. Portzline's questions about the used steam generators: the used steam

generators will be considered radioactive material and they must be controlled, handled, and

stored in accordance with the NRC's radiation protection standards. The NRC has safety limits

for the radiation dose to members of the public from all sources of radiation on'the TMI site. This

includes radiation from routine plant operation and any buildings containing radioactive material,

including used steam generators. The radioactive material must be stored in a ',safe and secure

condition under the full control of the licensee. The NRC routinely inspects the licensee's

compliance with our safety regulations.

There are other nuclear power plants in the U.S. that store their used steam generators on their

site in a safe and secure building. Because the buildings are typically designed with thick

shielded walls, only very low levels of radiation are emitted in the local area of the building.

Radiation levels outside of the plant site are typically not detectable above natural background

radiation.

The NRC does not have a specific time limit for the storage of the used steam generators. The

time limit is essentially tied to the Part 50 reactor operating license. When the operating license

expires and the plant shuts down and starts decommissioning the site, the licensee will deal

with the used steam generators in accordance with the NRC's safety regulations.

Regarding computer security at the NRC, on May 1, 2009, the NRC issued a security alert

regarding USB thumb drive risks. The security alert stated, "Users should be aware of risks

associated with use of USB thumb drives, a specific type of removable flash drive. Often USB

devices are given away free at conferences and meetings, and these may contain malicious

software. Also, USB devices infected with malware are intentionally planted in locations for

individuals to find, use and infect their computers. These USB devices have been a source of

the Conficker Worm.

To avoid introducing malicious software onto NRC systems, users should only employ NRCissued USB thumb drives with NRC computers and networks and must not use NRC issued

USB thumb drives on personally owned computers and networks."

Commenter: Joyce Scott, Harrisburg Diocese and Council of Catholic Women

Hello, I'm Joyce Scott from the HDCCW, which stands for the Harrisburg Diocese and Council

of Catholic Women. On behalf of the Diocese and Council, I am representing Our Commission

Chair Linda Brash, who has had surgery and could not be here today.

The Harrisburg Diocese and Council is made up of nine districts. And we cover Conewago,

which is Adams County, Cumberland Perry, the Dauphin County, Lancaster, Lebanon, North

Umberland, Sections of Franklin and York. So we're pretty wide-spread. This all came about

because at the national level there's been a program in existence which I was a committee

member of eight or nine years ago. And it's called CASE, and that's Children for A Safe

Environment. And there's always been a concern for our children to live in a safe environment.

We got the opportunity -- I'm an immediate past president of the council. We got the opportunity

two years ago to write a resolution. And, as I mentioned, Linda Braasch, one of her concerns,

because she lives in Middletown, has been TMI. And we decided that we would write this

NUREG-1437, Supplement 37 A-76 June 2009.
Appendix A

resolution, which we are in the process of submitting to National. And it does concern nuclear

safety and children's environment.

I'd like to share with you right now a few comment that Linda has sent to me. And this may

clear up some of the reasons I'm here today. Linda wrote, the promotion of nuclear energy,

solar, wind and other technologies is what's needed to become energy independent. So we do

recognize that. Create jobs and stabilize our economy, especially at this time. But we are

seeking truth and justice and a safe, secure energy for the future, upholding our human dignity,

respect for life and the integrity of our environment. And basically, that's what we are all about.

We feel before licensing is considered or implemented that there is a need for the Yucca

Mountain site to be established and operating as a permanent repository for spent nuclear fuel

before all of this takes place.

In addition, for the common good and our environment, establish a law to deny a license to a

nuclear site that has had an accident with uncontrolled releases of radiation.

We can secure for our children the truth and justice of a safe, secure energy future. We do feel

this is possible. Your response is gratefully appreciated. And I thank you.

Response:

In the Waste Confidence Rule (10 CFR 51.23), the Commission determined that spent fuel can

be safely stored onsite for at least 30 years beyond the plant's life, including license renewal.

Onsite spent fuel storage is considered a Category I issue, which was evaluated in the GELS,

NUREG-1437; the GElS is based upon the assumption that storage of the spent fuel onsite is

not permanent. The GElS considered a variety of spent fuel and waste storage scenarios,

including onsite storage of these materials for up to 30 years following expiration of the

operating license, transfer of these materials to a different plant, and transfer of these materials

to an Independent Spent Fuel Storage Installation (ISFSI). For each potential scenario, the

GElS determined that existing regulatory requirements, operating practices, and radiological

monitoring programs were sufficient to ensure that impacts resulting from spent fuel and waste

storage practices would be SMALL, and therefore were a Category I issue. The comment does

not present any new and significant information, and no changes were made to the

supplemental EIS.

Commenter: Linda Spears (no affiliation stated)

I fully support Nuclear Energy. Thank you for your consideration

Response:

The comment is in support of nuclear energy and is noted.

Comment: Karen Walsh, Pennsylvania Energy Alliance

Hello, my name is Karen Walsh. I'm the Executive Director of the Pennsylvania Energy Alliance.

I want to thank you for the opportunity to speak here today in support of the re-licensing of

Three Mile Island, Unit 1. As the Executive Director of the Pennsylvania Energy Alliance, I

speak for a group of independent community leaders and organizations representing

environmental, business, scientific, labor and healthcare interests. We have formed this

June 2009 A-77 NUREG-1437, Supplement 37
Appendix A

coalition to support nuclear energy and to advocate for additional clean, safe and reliable

sources of electricity generation in our commonwealth.

As you know, Pennsylvania is the Nation's second largest producer of nuclear energy. One

third of our electricity comes from this carbon-free source. Unfortunately, Pennsylvania also has

the distinction of ranking fourth highest in the nation in carbon dioxide emissions, second

highest in sulfur dioxide emissions, and fifth highest in nitrogen oxide emissions.

During the next ten years our electricity demand is expected to rise 1.5 percent a year. To meet

our ever-increasing demand for electricity in a way that does not destroy our environment, we

need a diverse energy mix that includes nuclear power, cleaner fossil fuels, renewable sources

and energy efficiency. However, conservation alone will not offset the expect growth in our

electricity use and renewable sources like wind and solar are unreliable.

Nuclear energy is the only source that can reliably generate electricity around the clock for

millions of consumers with no harmful greenhouse gas emissions. Each year in the United

States nuclear generated electricity avoids almost 700 million tons of carbon dioxide, three

million tons of sulfur dioxide and one million tons of nitrogen oxide. TMI-1 serves as just one

example of how nuclear power can provide a reliable source of electricity that does not

contribute to global warming. By operating nuclear power instead of coal, the area around TMI-1

avoids 271 tons of carbon dioxide per hour. Avoiding 271 tons of carbon dioxide per hour is the

equivalent of taking 29 SUVs or pickup trucks off the road for an entire year.

Furthermore, years of environmental monitoring has produced no evidence that TMI's Unit 1

operation negatively impacts Middletown and the surrounding communities. TMI officials

annually perform 1,700 analyses on roughly 1,300 environmental samples from air, water, fish,

cow's milk, soil and food products. In recent years TMI has teamed up with two state agencies,

the Pennsylvania Bureau of Radiation Protection and the Pennsylvania Emergency

Management Agency, to install a computer connection that provides both agencies with realtime radiation readings from in-plant monitors.

It's not surprising that a recent poll conducted by Terry Madonna Opinion Research found that

nearly three quarters of the people who live near TMI Unit 1 have a favorable opinion of the

facility. Knowing TMI's history of responsible environmental monitoring, the Pennsylvania

Energy Alliance is pleased to know that the NRC's analyses have produced similar findings that

TMI Unit 1 does not negatively impact the environment. This independent confirmation reaffirms

our belief in TMI Unit 1 and its goal of providing a clean, safe and reliable source of electricity

for over 800,000 homes in central Pennsylvania. Thank you.

Response:

Ms. Walsh's comments are supportive of license renewal of TMI-1. The comments are noted.

A.3 References

10 CFR 2. Code of Federal Regulations, Title 10, Energy, Part 2, "Rules of Practice for

Domestic Licensing Proceedings and Issuance of Orders."

NUREG-1437, Supplement 37 A-78 June 2009
Appendix A

10 CFR 9. Code of Federal Regulations, Title 10, Energy, Part 9, "Public Records."

10 CFR 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for Protection

Against Radiation."

10 CFR 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, P art 51, "Environmental

Protection Regulations for Domestic Licensing and Related Regulatory Functions."

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

of Operating Licenses for Nuclear Power Plants."

40 CFR 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190,

"Environmental Radiation Protection Standards for Nuclear Power Operations."

69 FR 52040. U.S. Nuclear Regulatory Commission, Washington, D.C. "Policy Statement on the

Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions." Federal

Register Volume 69, No. 163, pp. 52040-52048. August 24, 2004.

73 FR 16729. U.S. Nuclear Regulatory Commission, Washington, D.C, "Three Mile Island

Nuclear Station, Unit 1; Notice of Intent to Prepare an Environmental Impact Statement and

Conduct Scoping Process." Federal Register Vol. 73, No. 61, pp. 16729-16731. March 28,

2008.

73 FR 74766. U.S. Nuclear Regulatory Commission, Washington, D.C., "Three Mile Island

Nuclear Station, Unit 1; Notice of Availability of the Draft Supplement 37 to the Generic

Environmental Impact Statement for License Renewal of Nuclear Plants, and Public Meeting for

the License Renewal of Three Mile Island Nuclear Station, Unit 1." Federal Register Vol. 74,

No. 4, pp. 470. January 6, 2009.

Act Number 129, An Act Amending Title 66 (Public Utilities) of the Pennsylvania Consolidated

Statutes. Available URL:

http://www.legis.state.Pa.us/CFDOCS/Leqis/PN/Public/btCheck.cfm?txtType=PDF&sessYr=200

7&sesslnd=0&billBodv=H&billTvp=B&billNbr=2200&pn=4526 (accessed May 1, 2009).

Exelon Generation (Exelon Generation Company, LLC). 2009. "Three Mile Island Nuclear

Station Unit 1 License Renewal Application Supplemental Updated Environmental Information."

May 15. ADAMS No. ML091390217.

FERC (Federal Energy Regulatory Commission). 2009. "Electric Market Overview: Energy

Efficiency Resource Standards (EERS) and Goals." April 3. Available URL:

hfttp://www.ferc.qov/market-oversiqht/mkt-electric/overview/elec-ovr-eeps.pdf (accessed April

29, 2009).

June 2009 A-79 NUREG-1 437, Supplement 37
Appendix A

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

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

ADAMS No. ML061770605.

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

Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal. NUREG-1 555,

Supplement 1, Washington, D.C.

NRC (U.S. Nuclear Regulatory Commission). 2008. "Environmental Impact Statement Scoping

Process Summary Report, Three Mile Island Nuclear Station, Unit 1." ADAMS Accession No.

ML081920230.

NUREG-1437, Supplement 37 A-80 June 2009
Appendix B

NEPA Issues for License Renewal of Nuclear Power Plants

B. NEPA Issues for License Renewal of Nuclear Power Plants

Table B-1. Summary of Issues and Findings. This table is taken from Table B-1 in

Appendix B, Subpart A, to 10 CFR Part 51. Data supporting this table are

contained in NUREG-1437, Generic Environmental Impact Statement for

License Renewal of Nuclear Plants. Throughout this report, "Generic"

issues are also referred to as Category I issues, and "Site-specific" issues

are also referred to as Category 2 issues. If an issue is rHot applicable to

Three Mile Island Nuclear Station, Unit I (TMI-1), either because TMI-I

does not have that type of cooling system, or some other specified plant or

site charactistic, that is noted at the end of the finding.

Issue Type of Issue Finding

Surface Water Quality, Hydrology, and Use

Imoacts of Generic qAI I Imnet-fe nra =vnor-fori fn ho no linihla

refurbishment on

surface water

quality

Impacts of

refurbishment on

surface water use

Altered current

patterns at intake

and discharge

structures

Altered salinity

gradients

Altered thermal

stratification of

lakes

Temperature

effects on

sediment

transport capacity

Scouring caused

by discharged

cooling water

during refurbishment because best management

practices are expected to be employed to control

soil erosion and spills.

Generic SMALL. Water use during refurbishment will not

increase appreciably or will be reduced during plant

outage.

Generic SMALL. Altered current patterns have not been

found to be a problem at operating nuclear power

plants and are not expected to be a problem during

the license renewal term.

Generic SMALL. Salinity gradients have not been found to

be a problem at operating nuclear power plants and

are not expected to be a problem during the license

renewal term. Not applicable to TMI-I.

Generic

Generic

Generic

SMALL. Generally, lake stratification has not been

found to be a problem at operating nuclear power

plants and is not expected to be a problem during

the license renewal term. Not applicable to TMI-1.

SMALL. These effects have not been found to be a

problem at operating nuclear power plants and are

not expected to be a problem during the license

renewal term.

SMALL. Scouring has not been found to be a

problem at most operating nuclear power plants and

has caused only localized effects at a few plants. It

is not expected to be a problem during the license

renewal term.

I

June 2009 B-1 NUREG-1437, Supplement 37
Appendix B

Issue Type of Issue Finding

Eutrophication Generic SMALL. Eutrophication has not been found to be a

problem at operating nuclear power plants and is

not expected to be a problem during the license

renewal term.

Discharge of Generic SMALL. Effects are not a concern among regulatory

chlorine or other and resource agencies, and are not expected to be

biocides a problem during the license renewal term.

Discharge of Generic SMALL. Effects are readily controlled through

sanitary wastes NPDES permit and periodic modifications, if

and minor needed, and are not expected to be a problem

chemical spills during the license renewal term.

Discharge of Generic SMALL. These discharges have not been found to

other metals in be a problem at operating nuclear power plants with

wastewater cooling-tower-based heat dissipation systems and

have been satisfactorily mitigated at other plants.

They are not expected to be a problem during the

license renewal term.

Water use Generic SMALL. These conflicts have not been found to be a

conflicts (plants problem at operating nuclear power plants with

with once-through once-through heat dissipation systems. Not

cooling systems) applicable to TMI-1.

Water use Site-specific SMALL OR MODERATE. The issue has been a

conflicts (plants concern at nuclear power plants with cooling ponds

with cooling and at plants with cooling towers. Impacts on

ponds or cooling instream and riparian communities near these plants

towers using could be of moderate significance in some

make-up water situations. See § 51.53(c)(3)(ii)(A). Not applicable to

from a small river TMI-1.

with low flow)

Aquatic Ecology

Refurbishment Generic SMALL. During plant shutdown and refurbishment

there will be negligible effects on aquatic biota

because of a reduction of entrainment and

impingement of organisms or a reduced release of

chemicals.

NUREG-1437, Supplement 37 B-2 June 2009
Appendix B

Issue Type of Issue Finding

Accumulation of Generic SMALL. Accumulation of contaminants has been a

contaminants in concern at a few nuclear power plants but has been

sediments or satisfactorily mitigated by replacing copper alloy

biota condenser tubes with those of another metal. It is

not expected to be a problem during the license

renewal term.

Entrainment of Generic SMALL. Entrainment of phytoplankton and

phytoplankton zooplankton has not been found to be a problem at

and zooplankton operating nuclear power plants and is not expected

to be a problem during the license renewal term.

Cold shock /l•'- rin 4Z Al I 1nrlH chn,-he hoeKonn nfiefanrtnriil,

Thermal plume

barrier to

migrating fish

Distribution of

aquatic organisms

Premature

emergence of

aquatic insects

Gas

supersaturation

(gas bubble

disease)

Generic

Generic

Generic

Generic

mitigated at operating nuclear plants with oncethrough cooling systems, has not endangered fish

populations or been found to be a problem at

operating nuclear power plants with cooling towers

or cooling ponds, and is not expected to be a

problem during the license renewal term.

SMALL. Thermal plumes have not been found to be

a problem at operating nuclear power plants and are

not expected to be a problem during the license

renewal term.

SMALL. Thermal discharge may have localized

effects but is not expected to affect the larger

geographical distribution of aquatic organisms.

SMALL. Premature emergence has been found to

be a localized effect at some operating nuclear

power plants but has not been a problem and is not

expected to be a problem during the license renewal

term.

SMALL. Gas supersaturation was a concern at a

small number of operating nuclear power plants with

once-through cooling systems but has been

satisfactorily mitigated. It has not been found to be a

problem at operating nuclear power plants with

cooling towers or cooling ponds and is not expected

to be a problem during the license renewal term.

June 2009 B-3 NUREG-1 437, Supplement 37
Appendix B

Issue Type of Issue Finding

Low dissolved Generic SMALL. Low dissolved oxygen has been a concern

oxygen in the at one nuclear power plant with a once-through

discharge cooling system but has been effectively mitigated. It

has not been found to be a problem at operating

nuclear power plants with cooling towers or cooling

ponds and is not expected to be a problem during

the license renewal term.

Losses from Generic SMALL. These types of losses have not been found

predation, to be a problem at operating nuclear power plants

parasitism, and and are not expected to be a problem during the

disease among license renewal term.

organisms

exposed to

sublethal stresses

Stimulation of Generic SMALL. Stimulation of nuisance organisms has

nuisance been satisfactorily mitigated at the single nuclear

organisms (e.g., power plant with a once-through cooling system

shipworms) where previously it was a problem. It has not been

found to be a problem at operating nuclear power

plants with cooling towers or cooling ponds and is

not expected to be a problem during the license

renewal term.

Aquatic Ecology (for plants with once-through and cooling pond heat dissipation systems)

Entrainment of Site-specific SMALL, MODERATE, OR LARGE. The impacts of

fish and shellfish entrainment are small at many plants but may be

in early life stages moderate or even large at a few plants with oncethrough and cooling-pond cooling systems. Further,

ongoing efforts in the vicinity of these plants to

restore fish populations may increase the numbers

of fish susceptible to intake effects during the

license renewal period, such that entrainment

studies conducted in support of the original license

may no longer be valid. See § 51.53(c)(3)(ii)(B). Not

applicable to TMI-1.

Impingement of

fish and shellfish Site-specific SMALL, MODERATE, OR LARGE. The impacts of

impingement are small at many plants but may be

moderate or even large at a few plants with oncethrough and cooling-pond cooling systems. See §

51.53(c)(3)(ii)(B). Not applicable to TMI-1.

NUREG-1437, Supplement 37 B-4 June 2009
Appendix-B

Issue Type of Issue Finding

Heat shock Site-specific SMALL, MODERATE, OR LARGE. Because of

continuing concerns about heat shock and the

possible need to modify thermal discharges in

response to changing environmental conditions, the

impacts may be of moderate or large significance at

some plants. See § 51.53(c)(3)(ii)(B). Not applicable

to TMI-1.

Aquatic Ecology (for plants with cooling-tower-based heat dissipation systems)

Entrainment of Generic SMALL. Entrainment of fish has not been found to

fish and shellfish be a problem at operating nuclear power plants with

in early life stages this type of cooling system and is not expected to be

a problem during the license renewal term.

Impingement of Generic SMALL. The impingement has not been found to be

fish and shellfish a problem at operating nuclear power- plants with

this type of cooling system and is not expected to be

a problem during the license renewal term.

Heat shock Generic SMALL. :Heat shock has not been found to be a

problem at operating nuclear power plants with this

type of cooling system and is not expected to be a

problem during the license renewal term.

Ground Water Use and Quality

Impacts of

refurbishment on

ground water use

and quality

Ground water

use conflicts

(potable and

service water;

plants that use

<100 gpm)

Ground water use

conflicts (potable

and service water,

and dewatering

plants that use

>100 gpm)

Generic SMALL. Extensive dewatering during the original

construction on some sites will not be repeated

during refurbishment on any sites. Any plant wastes

produced during refurbishment will be handled in the

same manner as in current operating practices and

are not expected to be a problem during the license

renewal term.

Generic SMALL. Plants using less than 100 gpm are not

expected to cause any ground water use

conflicts. Not applicable to TMI-1.

Site-specific SMALL, MODERATE, OR LARGE. Plants that use

more than 100 gpm may cause ground water use

conflicts with nearby ground water users. See §

51.53(c)(3)(ii)(C).

June 2009 B-5 ̧ NUREG-1437, Supplement 37
Appendix B

Issue I

Ground water use

conflicts (plants

using cooling

towers

withdrawing

make-up water

from a small river)

Ground water use

conflicts (Ranney

wells)

Ground water

quality

degradation

(Ranney wells)

rype of Issue Finding

Site-specific SMALL, MODERATE, OR LARGE. Water use

conflicts may result from surface water withdrawals

from small water bodies during low flow conditions

which may affect aquifer recharge, especially if

other ground water or upstream surface water users

come on line before the time of license renewal. See

§ 51.53(c)(3)(ii)(A).

Site-specific SMALL, MODERATE, OR LARGE. Ranney wells

can result in potential ground water depression

beyond the site boundary. Impacts ofilarge ground

water withdrawal for cooling tower makeup at

nuclear power plants using Ranney wells must be

evaluated at the time of application for license

renewal. See § 51.53(c)(3)(ii)(C). Not applicable to

TMI-1.

Generic SMALL. Ground water quality at river sites may be

degraded by induced infiltration of poor-quality river

water into an aquifer that supplies large quantities of

reactor cooling water. However, the lower quality

infiltrating water would not preclude the current uses

of ground water and is not expected to be a problem

during the license renewal term. Not applicable to

TM!-1.

Generic SMALL. Nuclear power plants do not contribute

significantly to saltwater intrusion. Not applicable to

TM!-1.

Ground water

quality

degradation

(saltwater

intrusion)

Ground water

quality

degradation

(cooling ponds in

salt marshes)

Ground water

quality

degradation

(cooling ponds at

inland sites)

Generic

Site-specific

SMALL. Sites with closed-cycle cooling ponds may

degrade ground water quality. Because water in salt

marshes is brackish, this is not a concern for plants

located in salt marshes. Not applicable to TMI-1..

SMALL, MODERATE, OR LARGE. Sites with

closed-cycle cooling ponds may degrade ground

water quality. For plants located inland, the quality.

of the ground water in the vicinity of the ponds must

be shown to be adequate to allow continuation of

current uses. See § 51.53(c)(3)(ii)(D).!i Not applicable

to TMI-1.

NUREG-1437, Supplement 37 B-6 June 2009
Appendix B

Terrestrial Ecology

Refurbishment

impacts

Cooling tower

impacts on crops

and ornamental

vegetation

Cooling tower

impacts on native

plants

Site-specific

Generic

SMALL, MODERATE, OR LARGE. Refurbishment

impacts are insignificant if no loss of important plant

and animal habitat occurs. However, it cannot be

known whether important plant and animal

communities may be affected until the specific

proposal is presented with the license renewal

application. See § 51.53(c)(3)(ii)(E).

SMALL. Impacts from salt drift, icing, fogging, or

increased humidity associated with cooling tower

operation have not been found to be a problem at

operating nuclear power plants and are not

expected to be a problem during the license renewal

term. Not applicable to TMI-1.

SMALL. Impacts from salt drift, icing, fogging, or

increased humidity associated with cooling tower

operation have not been found to be a problem at

operating nuclear power plants and are not

expected to be a problem during the license renewal

term. Not applicable to TMI-1.

I

Generic

Bird collisions

with cooling

towers

Cooling pond

impacts on

terrestrial

resources

Power line right of

way management

(cutting and

herbicide

application)

Bird collisions

with power lines

Impacts of

electromagnetic

fields on flora and

fauna

Generic

Generic

Generic

Generic

Generic

SMALL. These collisions have not been found to be

a problem at operating nuclear power plants and are

not expected to be a problem during the license

renewal term.

SMALL. Impacts of cooling ponds on terrestrial

ecological resources are considered to be of small

significance at all sites. Not applicable to TMI-1.

SMALL. The impacts of right-of-way maintenance

on wildlife are expected to be of small significance

at all sites.

SMALL. Impacts are expected to be of small

significance at all sites.

SMALL. No significant impacts of electromagnetic

fields on terrestrial flora and fauna have been

identified. Such effects are not expected to be a

problem during the license renewal term.

June 2009 B-7 NUREG-1437, Supplement 37
Appendix B

Floodplains and

wetland on power

line right of way

Generic SMALL. Periodic vegetation control is necessary in

forested wetlands underneath power lines and can

*be achieved with minimal.damage to the wetland.

No significant impact is expected at any nuclear

power plant during the license renewal term.

Threatened and Endangered Species

Threatened or Site-specific SMALL, MODERATE, OR LARGE. Generally, plant

endangered refurbishment and continued operation are not

species expected to adversely affect threatened or

endangered species. However, consultation with

appropriate agencies would be needed at the time

of license renewal to determine whether threatened

or endangered species are present and whether

they would be adversely affected. See §

51.53(c)(3)(ii)(E).

Air Quality

Air quality during Site-specific SMALL, MODERATE, OR LARGE. Air quality

refurbishment impacts from plant refurbishment associated with

(non-attainment license renewal are expected to be small. However,

and maintenance vehicle exhaust emissions could be cause for

areas) concern at locations in or near nonattainment or

maintenance areas. The significance of the potential

impact cannot be determined without considering

the compliance status of each site and the numbers

of workers expected to be employed during the

outage. See § 51.53(c)(3)(ii)(F).

Air quality effects Generic SMALL. Production of ozone and oxides of nitrogen

of transmission is insignificant and does not contribute measurably

lines to ambient levels of these gases.

Land Use

Onsite land use Generic SMALL. Projected onsite land use changes required

during refurbishment and the renewal period would

be a small fraction of any nuclear power plant site

and would involve land that is controlled by the

applicant.

Power line right of Generic SMALL. Ongoing use of power line right of ways

way would continue with no change in restrictions. The

effects of these restrictions are of small significance.

NUREG-1437, Supplement 37 B-8 June 2009
Appendix B

Human Health

Radiation

exposures to the

public during

refurbishment

Occupational

radiation

exposures during

refurbishment

Microbiological

organisms

(occupational

health)

Generic SMALL. During refurbishment, the gaseous effluents

would result in doses that are similar to those from

current operation. Applicable regulatory dose limits

to the public are not expected to be exceeded.

Generic SMALL. Occupational doses from refurbishment are

expected to be within the range of annual average

collective doses experienced for pressurized-water

reactors and boiling-water reactors. Occupational

mortality risk from all causes including radiation is in

the mid-range for industrial settings.

Generic SMALL. Occupational health impacts are expected

to be controlled by continued application of

accepted industrial hygiene practices to minimize

worker exposures.

Microbiological

organisms (public

health)(plants

using lakes or

canals, or cooling

towers or cooling

ponds that

discharge to a

small river)

Noise

Electromagnetic

fields - acute

effects (electric

shock)

Site-specific

Generic

Site-specific

SMALL, MODERATE, OR LARGE. These

organisms are not expected to be a problem at most

operating plants except possibly at plants using

cooling ponds, lakes, or canals that discharge to

small rivers. Without site-specific data, it is not

possible to predict the effects generically. See §

51.53(c)(3)(ii)(G).

SMALL. Noise has not been found to be a problem

at operating plants and is not expected to be a

problem at any plant during the license renewal

term.

SMALL, MODERATE, OR LARGE. Electrical shock

resulting from direct access to energized conductors

or from induced charges in metallic structures have

not been found to be a problem at most operating

plants and generally are not expected to be a

problem during the license renewal term. However,

site-specific review is required to determine the

significance of the electric shock potential at the

site. See § 51.53(c)(3)(ii)(H).

June 2009 B-9 NUREG-1437, Supplement 37
Appendix B

Electromagnetic

fields - chronic

effects

Uncategorized UNCERTAIN. Biological and physical studies of 60-

Hz electromagnetic fields have not found consistent

evidence linking harmful effects with field

exposures. However, research is continuing in this

area and a consensus scientific view has not been

reached.

SMALL. Radiation doses to the public will continue

at current levels associated with normal operations.

Radiation

exposures to

public (license

renewal term)

Occupational

radiation

exposures

(license renewal

term)

Generic

Generic SMALL. Projected maximum occupational doses

during the license renewal term are within the range

of doses experienced during normal operations and

normal maintenance outages, and would be well

below regulatory limits.

Socioeconomic Impacts

Housing impacts

Public services:

public safety,

social services,

and tourism, and

recreation

Public services:

public utilities

Public services:

education

(refurbishment)

Site-specific

Generic

Site-specific

SMALL, MODERATE, OR LARGE. Housing impacts

are expected to be of small significance at plants

located in a medium or high population area and not

in an area where growth control measures that limit

housing development are in effect. Moderate or

large housing impacts of the workforce associated

with refurbishment may be associated with plants

located in sparsely populated areas or in areas with

growth control measures that limit housing

development. See § 51.53(c)(3)(ii)(I).

SMALL. Impacts to public safety, social services,

and tourism and recreation are expected to be of

small significance at all sites.

SMALL OR MODERATE. An increased problem

with water shortages at some sites may lead to

impacts of moderate significance on public water

supply availability. See § 51.53(c)(3)(ii)(I).

SMALL, MODERATE, OR LARGE. Most sites would

experience impacts of small significance but larger

impacts are possible depending onsite- and projectspecific factors. See § 51.53(c)(3)(ii)(I).

Site-specific

NUREG-1437, Supplement 37 B-1 0 June 2009
Appendix B

Public services:

education (license

renewal term)

Offsite land use

(refurbishment)

Offsite land use

(license renewal

term)

Generic

Site-specific

Site-specific

SMALL. Only impacts of small significance are

expected

SMALL OR MODERATE. Impacts may be of

moderate significance at plants in low population

areas. See § 51.53(c)(3)(ii)(I).

SMALL, MODERATE, OR LARGE. Significant

changes in land use may be associated with

population and tax revenue changes resulting from

license renewal. See § 51.53(c)(3)(ii)(I).

Public services:

transportation

Historic and

archaeological

resources

Site-specific

Site-specific

SMALL, MODERATE, OR LARGE. Transportation

impacts (level of service) of highway traffic

generated during plant refurbishment and during the

term of the renewed license are generally expected

to be of small significance. However, the increase in

traffic associated with the additional workers and the

local road and traffic control conditions may lead to

impacts of moderate or large significance at some

sites. See § 51.53(c)(3)(ii)(J).

SMALL, MODERATE, OR LARGE. Generally, plant

refurbishment and continued operation are expected

to have no more than small adverse impacts on

historic and archaeological resources. However, the

National Historic Preservation Act requires the

Federal agency to consult with the State Historic

Preservation Officer to determine whether there are

properties present that require protection. See §

51.53(c)(3)(ii)(K).

Aesthetic impacts

(refurbishment)

Aesthetic impacts

(license renewal

term)

Aesthetic impacts

of transmission

lines (license

renewal term)

Generic SMALL. No significant impacts are expected during

refurbishment.

Generic SMALL. No significant impacts are expected during

the license renewal term.

Generic SMALL. No significant impacts are expected during

the license renewal term.

Postulated Accidents

Design basis

accidents

Generic SMALL. The NRC staff has concluded that the

environmental impacts of design basis accidents are

of small significance for all plants'

June 2009 B-1 1 NUREG-1 437, Supplement 37
Appendix B

Severe accidents Site-specific SMALL. The probability weighted consequences of

atmospheric releases, fallout onto open bodies of

water, releases to ground water, and societal and

economic impacts from severe accidents are small

for all plants. However, alternatives to mitigate

severe accidents must be considered for all plants

that have not considered such alternatives. See §

51.53(c)(3)(ii)(L).

Uranium Fuel Cycle and Waste Management

Offsite

radiological

impacts

(individual effects

from other than

the disposal of

spent fuel and

high level waste)

Offsite

radiological

impacts

(collective effects)

Generic

Generic

SMALL. Off-site impacts of the uranium fuel cycle

have been considered by the Commission in Table

S-3 of this part. Based on information in the GELS,

impacts on individuals from radioactive gaseous and

liquid releases including radon-222 and technetium99 are small.

The 100 year environmental dose commitment to

the U.S. population from the fuel cycle, high level

waste and spent fuel disposal excepted, is

calculated to be about 14,800 person rem, or 12

cancer fatalities, for each additional 20-year power

reactor operating term. Much of this, especially the

contribution of radon releases from mines and tailing

piles, consists of tiny doses summed over large

populations. This same dose calculation can

theoretically be extended to include many tiny doses

over additional thousands of years as well as doses

outside the U. S. The result of such a calculation

would be thousands of cancer fatalities from the fuel

cycle, but this result assumes that even tiny doses

have some statistical adverse health effect which

will not ever be mitigated (for example no cancer

cure in the next thousand years), and that these

doses projected over thousands of years are

meaningful. However, these assumptions are

questionable. In particular, science cannot rule out

the possibility that there will be no cancer fatalities

from these tiny doses. For perspective, the doses

are very small fractions of regulatory limits, and

even smaller fractions of natural background

exposure to the same populations.

Nevertheless, despite all the uncertainty, some

NUREG-1437, Supplement 37 B-1 2 June 2009
Appendix B

Offsite

radiological

impacts (spent

fuel and high level

waste disposal)

Generic

judgment as to the regulatory NEPA implications of

these matters should be made and it makes no

sense to repeat the same judgment in every case.

Even taking the uncertainties into account, the

Commission concludes that these impacts are

acceptable in that these impacts would not be

sufficiently large to require the NEPA conclusion, for

any plant, that the option of extended operation

under 10 CFR Part 54 should be eliminated.

Accordingly, while the commission has not assigned

a single level of significance for the collective effects

of the fuel cycle, this issue is considered Category 1

[Generic].

For the high level waste and spent fuel disposal

component of the fuel cycle, there are no current

regulatory limits for offsite releases of radionuclides

for the current candidate repository site. However, if

we assume that limits are developed along the lines

of the 1995 National Academy of Sciences (NAS)

report, "Technical Bases for Yucca Mountain

Standards," and that in accordance with the

Commission's Waste Confidence Decision, 10 CFR

51.23, a repository can and likely will be developed

at some site which will comply with such limits, peak

doses to virtually all individuals will be 100 millirem

per year or less. However, while the Commission

has reasonable confidence that these assumptions

will prove correct, there is considerable uncertainty

since the limits are yet to be developed, no

repository application has been completed or

reviewed, and uncertainty is inherent in the models

used to evaluate possible pathways to the human

environment. The NAS report indicated that 100

millirem per year should be considered as a starting

point for limits for individual doses, but notes that

some measure of consensus exists among national

and international bodies that the limits should be a

fraction of the 100 millirem per year. The lifetime

individual risk from 100 millirem annual dose limit is

about 3 x 10-3.

Estimating cumulative doses to populations over

thousands of years is more problematic. The

likelihood and consequences of events that could

seriously compromise the integrity of a deep

geologic repository were evaluated by the

June 2009 B-1 3 NUREG-1437, Supplement 37
Appendix B

Department of Energy in the "Final Environmental

Impact Statement: Management of Commercially

Generated Radioactive Waste," October 1980. The

evaluation estimated the 70-year whole-body dose

commitment to the maximum individual and to the

regional population resulting from several modes of

breaching a reference repository in the year of

closure, after 1,000 years, after 100,000 years and

after 100,000,000 years. Subsequently, the NRC

and other federal agencies have expended

considerable effort to develop modelslfor the design

and for the licensing of a high level waste repository,

especially for the candidate repository at Yucca

Mountain. More meaningful estimates of doses to

population may be possible in the future as more is

understood about the performance of the proposed

Yucca Mountain repository. Such estimates would

involve very great uncertainty, especially with

respect to cumulative population doses over

thousands of years. The standard proposed by the

NAS is a limit on maximum individual dose. The

relationship of potential new regulatory

requirements, based on the NAS report, and

cumulative population impacts has not been

determined, although the report articulates the view

that protection of individuals will adequately protect

the population for a repository at Yucca Mountain.

However, EPA's generic repository standards in 40

CFR Part 191 generally provide an indication of the

order of magnitude of cumulative risk to population

that could result from the licensing of a Yucca

Mountain repository, assuming the ultimate

standards will be within the range of standards now

under consideration. The standards in 40 CFR Part

191 protect the population by imposing amount of

radioactive material released over 10,000 years.

The cumulative release limits are based on EPA's

population impact goal of 1,000 premature cancer

deaths worldwide for a 100,000 metric ton (MTHM)

repository.

Nevertheless, despite all the uncertainty, some

judgment as to the regulatory NEPA implications of

these matters should be made and it makes no

sense to repeat the same judgment in every case.

Even taking the uncertainties into account, the

NUREG-1437, Supplement 37 B-1 4 June 2009
Appendix-B

Commission concludes that these impacts are

acceptable in that these impacts would not be

sufficiently large to require the NEPA conclusion, for

any plant, that the option of extended operation

under 10 CFR Part 54 should be eliminated.

Accordingly, while the Commission has not

assigned a single level of significance for the

impacts of spent fuel and high level waste disposal,

this issue is considered in Category 1 [Generic].

Nonradiological

impacts of the

uranium fuel cycle

Low-level waste

storage and

disposal

Generic

Generic

SMALL. The nonradiological impacts of the uranium

fuel cycle resulting from the renewal of an operating

license for any plant are found to be small.

SMALL. The comprehensive regulatory controls that

are in place and the low public doses being

achieved at reactors ensure that the radiological

impacts to the environment will remain small during

the term of a renewed license. The maximum

additional on-site land that may be required for lowlevel waste storage during the term of a renewed

license and associated impacts will be small.

Nonradiological impacts on air and water will be

negligible. The radiological and nonradiological

environmental impacts of long-term disposal of lowlevel waste from any individual plant at licensed

sites are small. In addition, the Commission

concludes that there is reasonable assurance that

sufficient low-level waste disposal capacity will be

made available when needed for facilities to be

decommissioned consistent with NRC

decommissioninq requirements.

June 2009 B-1 5 NUREG-1437, Supplement 37
Appendix B

Mixed waste

storage and

disposal

On-site spent fuel

Nonradiological

waste

Transportation

Generic SMALL. The comprehensive regulatory controls and

the facilities and procedures that are in place ensure

proper handling and storage, as well as negligible

doses and exposure to toxic materials for the public

and the environment at all plants. License renewal

will not increase the small, continuing risk to human

health and the environment posed by mixed waste

at all plants. The radiological and nonradiological

environmental impacts of long-term disposal of

mixed waste from any individual plant at licensed

sites are small. In addition, the Commission

concludes that there is reasonable assurance that

sufficient mixed waste disposal capacity will be

made available when needed for facilities to be

decommissioned consistent with NRC

decommissioning requirements.

Generic

Generic

Generic

SMALL. The expected increase in the volume of

spent fuel from an additional 20 years of operation

can be safely accommodated onsite with small

environmental effects through dry or pool storage at

all plants if a permanent repository or monitored

retrievable storage is not available.

SMALL. No changes to generating systems are

anticipated for license renewal. Facilities and

procedures are in place to ensure continued proper

handling and disposal at all plants.

SMALL. The impacts of transporting spent fuel

enriched up to 5 percent uranium-235 with average

burnup for the peak rod to current levels approved

by NRC up to 62,000 MWd/MTU and the cumulative

impacts of transporting high-level waste to a single

repository, such as Yucca Mountain, Nevada are

found to be consistent with the impact values

contained in 10 CFR 51.52(c), Summary Table S-4

- Environmental Impact of Transportation of Fuel

and Waste to and from One Light-Water-Cooled

Nuclear Power Reactor. If fuel enrichment or burnup

conditions are not met, the applicant must submit an

assessment of the implications for the

environmental impact values reported in § 51.52.

NUREG-1437, Supplement 37 B-16 June 2009
Appendix B

Decommissioning

Radiation doses

Waste

management

Air quality

Generic

Generic

Generic

SMALL. Doses to the public will be well below

applicable regulatory standards regardless of which

decommissioning method is used. Occupational

doses would increase no more than 1 man-rem

caused by buildup of long-lived radionuclides during

the license renewal term.

SMALL. Decommissioning at the end of a 20-year

license renewal period would generate no more

solid wastes than at the end of the current license

term. No increase in the quantities of Class C or

greater than Class C wastes would be expected.

SMALL. Air quality impacts of decommissioning are

expected to be negligible either at the end of the

current operating term or at the end of the license

renewal term.

SMALL. The potential for significant water quality

impacts from erosion or spills is no greater whether

decommissioning occurs after a 20-year license

renewal period or after the original 40-year

operation period, and measures are readily

available to avoid such impacts.

Water quality

Ecological

resources

Socioeconomic

impacts

Generic

Generic SMALL. Decommissioning after either the initial

operating period or after a 20-year license renewal

period is not expected to have any direct ecological

impacts.

Generic SMALL. Decommissioning would have some shortterm socioeconomic impacts. The impacts would not

be increased by delaying decommissioning until the

end of a 20-year relicense period, but they might be

decreased by population and economic growth.

Environmental Justice

Environmental Uncategorized NONE. The need for and the content of an analysis

Justice of environmental justice will be addressed in plantspecific reviews.

June 2009 B-17 NUREG-1437, Supplement 37

Appendix C

Applicable Regulations, Laws, and Agreements

C. Applicable Regulations, Laws, and Agreements

The Atomic Energy Act authorizes States to establish programs to assume NRC regulatory

authority for certain activities. For example, through the Agreement State Program, beginning

on March 31, 2008, Pennsylvania assumed regulatory responsibility over certain byproduct,

source, and small quantities of special nuclear material. The Pennsylvania Department of

Environmental Protection (PADEP) is responsible for implementing State nuclear regulations,

which are contained in Title 25 of the Pennsylvania (Pa) Code, Environment, Article V,

Radiological Health, Chapters 215 through 240.

In addition to implementing some Federal programs, State legislatures develop their own laws.

State statutes supplement as well as implement Federal laws for protection of air, water quality,

and ground water. State legislation may address solid waste management programs, locally

rare or endangered species, and historic and cultural resources.

The Clean Water Act (CWA) allows for primary enforcement and administration through State

agencies, provided the State program is at least asstringent as the Federal program. The State

program must conform to the CWA and to the delegation of authority for the Federal National

Pollutant Discharge and Elimination System (NPDES) program from the EPA to the State. The

primary mechanism to control water pollution is the requirement for direct dischargers to obtain

an NPDES permit, or in the case of states where the authority has been delegated from the

EPA, an SPDES permit, pursuant to the CWA. In Pennsylvania, the PADEP issues and

enforces NPDES permits.

One important difference between Federal regulations and certain State regulations is the

definition of waters regulated by the State. Certain state regulations may include underground

waters, while the CWA only regulates surface waters.

C.1 State Environmental Requirements

Certain environmental requirements, including some discussed earlier, may have been

delegated to State authorities for implementation, enforcement, or oversight. Table C-1 provides

a list of representative State environmental requirements that may affect license renewal

applications for nuclear power plants.

Table C-1. State Environmental Requirements. TMI-1 is subject to numerous State

requirements regarding their environmental program. Those requirements

are briefly described below. See Section 1.9 for TMI-1's compliance status

with these requirements.

Law/Regulation Requirements

Air Quality Protection

Air Pollution Control Act, PA All emission sources at TMI-1 must obtain a Synthetic Minor Operating Permit prior

Public Law (P.L.) 2119 and 25 to operation; the PADEP issues and enforces permits.

Pa Code Chapter 127

June 2009 C-1 NUREG-1 437, Supplement 37
Appendix C

Table C-1. State Environmental Requirements. TMI-1 is subject to numerous State

requirements regarding their environmental program. Those requirements

are briefly described below. See Section 1.9 for TMI-I's compliance status

with these requirements.

LawlRegulation Requirements

Water Resources Protection

Clean Water Act (CWA) (33 The National Pollutant Discharge Elimination System (NPDES) permit is required

U.S.C. Section 1251 et seq.); for plant industrial, sanitary, and stormwater discharges to the Susquehanna River.

Pennsylvania's Clear Streams The NPDES permit requires the compliance of each point source with authorized

Law, as amended (35 discharge levels, monitoring requirements, and other appropriate requirements. The

Pennsylvania Statute [P.S.] PADEP is the responsible State agency for NPDES permitting.

Section 691.1 et seq.)

CWA (33 U.S.C. Section 401) The Clean Water Act Section 401 Water Quality Certification requires a Section 401

water quality certification and payment of applicable fees before the issuance of a

Federal permit or license to conduct any activity that may result in any discharge to

waters of the State. In Pennsylvania, State issuance of an NPDES permit

constitutes 401 Certification.

Susquehanna River Basin Requires a permit to cover consumptive water use over 20,000 gallons per day

Compact, P.L. 91-575, Article (gpd) (over a 30-day average) of surface and ground water; the SRBC is the

3, Section 3.10; and regulatory agency that issues and enforces consumptive water use permits.

Susquehanna River Basin

Commission (SRBC)

Regulation 803.61

Susquehanna River Basin The Compact requires a permit to cover ground water withdrawals over 100,000

Compact, P.L. 91-575, Article gpd or more (over a 30-day average) of surface water, ground water, or a

3, Section 3.10; and SRBC combination of the two; the SRBC is the regulatory agency that issues and enforces

Regulation 803.43 ground water withdrawal permits.

P.L. 834, 204, 851, 1987, etc. The U.S. Army Corps of Engineers issues maintenance dredging permits for

maintenance dredging of the TMI-1 intake bay.

P.L. 555, as amended Maintenance dredging of the TMI-1 intake bay in the Susquehanna River also

requires a maintenance dredging permit issued by the PADEP.

Pennsylvania Safe Drinking The PADEP issues and enforces public water supply permits for operation TMI-1

Water Act (P.L. 206, No. 43) plant site drinking water systems.

NUREG-1437, Supplement 37 C-2 June 2009
Appendix C

Table C-1. State Environmental Requirements. TMI-1 is subject to numerous State

requirements regarding their environmental program. Those requirements

are briefly described below. See Section 1.9 for TMI-1's compliance status

with these requirements.

Law/Regulation Requirements

Waste Management and Pollution Prevention

Pennsylvania Storage Tank The PADEP issues storage tank registration and permit certificates, which establish

and Spill Prevention Act (35 annual registration requirements for underground storage tanks containing

P.S. 6021.1016021.2104); 25 petroleum or other regulated substances.

PA Code Chapter (Ch.) 245

Pennsylvania Fire Marshall; The Act requires, a flammable and combustible liquid storage tank approval to

Pennsylvania Storage Tank construct or operate an underground storage tank containing flammable or

and Spill Prevention Act (35 combustible liquids.

P.S. 6021.1016021.2104); 25

PA Code Ch. 245

71 P.S. Sections 510520; The PADEP issues sewage sludge disposal agreements, which are required for the

Sections 5 and 402 of The disposal of sewage sludge. The PADEP also issues on-lot sewage disposal system

Clean Streams Law (35 P.S. permits, and permit modifications for approvals of additional flows to on-lot sewage

691.5 and 691.402); Section 9 treatment systems.

of the Pennsylvania Sewage

Facilities Act (35 P.S. Section

750.9).

C.2 Operating Permits and Other Requirements

Several operating permit applications may be prepared and submitted, and regulator approval

and permits would be received prior to license renewal approval by the NRC. Table C-2 lists

representative Federal, State, and local permits.

June 2009' C-3 NUREG-1437, Supplement 37
Appendix C

Table C-2. Federal, State, and Local Permits and Other Requirements. TMI-1 is subject to

other requirements regarding various aspects of their environmental program. Those requirements are

briefly described below.

License, Permit, or Other Required Responsible

Approval Agency Authority Relevance and Status

Air Quality Protection

Approval (operating permit) for PADEP Clean Air Act, Title Exelon Generation may need to

construction or modification of an air V, Sections 501- modify its existing Synthetic Minor

pollutant source. 507 (42 U.S.C. Operating Permit, or apply for a

7661-76610; Pa new permit for temporary emissions

Code Ch.127 associated with refurbishment.

Water Resources Protection,

NPDES permit for construction site PADEP CWA (33 U.S.C. Exelon Generation may need to

stormwater and other project-specific 1251 et seq.); 40 modify the existing TMI-1 NPDES

discharges. CFR Part 122; 25 permit, or otherwise obtain

Pa Code Ch. 92 authorization for temporary

discharges associated with

refurbishment.

Requires review and approval of any SRBC Susquehanna Modifications to the existing TMI-1

project that will result in consumptive River Basin consumptive water use permit may

use of water from the Susquehanna Compact; P.L. 91- be necessary to supply water for

River. 575, Article 3, refurbishment activities.

Section 3.10; 18

CFR Part 806; 25

Pa Code Ch. 806

Requires any person withdrawing or SRBC 'Susquehanna Refurbishment activities at TMI-1

diverting in excess of an average of River Basin may require additional ground

10,000 gpd for any consecutive 30-day Compact; P.L. 91- water or surface water withdrawal;

period, from ground or surface water 575, Article 3, the existing TMI-1 water withdrawal

sources to register the amount of the Section 3.10; 18 permit may require modification.

withdrawal. CFR Part 807; 25

Pa Code Ch. 807

NUREG-1437, Supplement 37 C-4 June 2009
Appendix C

Table C-2. Federal, State, and Local Permits and Other Requirements. TMI-1 is subject to

other requirements regarding various aspects of their environmental program. Those requirements are

briefly described below.

License, Permit, or Other Required Responsible

Approval Agency Authority Relevance and Status

Requires a permit be obtained before PADEP Flood Plain Exelon Generation is reviewing

construction, modification, removal, Management Act flood plain elevations associated

destruction, or abandonment of an (32 P.S. 679.101- with refurbishment activities; if

obstruction in a floodplain. 679.601); 25 Pa avoidance is not possible, Exelon

Code Ch. 106 Generation will apply for

appropriate permits.

A Spill Prevention Control and PADEP CWA (33 U.S.C. A SPCC Plan is required at nuclear

Countermeasures (SPCC) Plan is 1251 et seq.); 40 power plants storing large volumes

required for any facility that could CFR Part 112; 25 of diesel fuel or other petroleum

discharge diesel fuel in harmful Pa Code Ch. 245 products. Exelon Generation may

quantities into navigable waters or onto need to modify its existing SPCC

adjoining shorelines. Plan, or develop a new plan to

cover activities associated with

refurbishment.

New Underground Storage Tanks PADEP RCRA, as Required if new underground

System Registration is required within amended, Subtitle storage tank systems would be

30 days of bringing a new underground 1(42 U.S.C. installed during refurbishment at a

storage tank system into service. 6991 a76991 i); 40 nuclear power plant.

CFR §280.22;

Storage Tank and

Spill Prevention

(35 P.S. 6021.101-

6021.2104); 25 Pa

Code, Ch. 245

Waste Management and Pollution Prevention

Registration and Hazardous Waste PADEP RCRA, as Generators of hazardous waste

Generator Identification Number are amended (42 must notify EPA that the wastes

required before a facility that generates U.S.C. 6901 et exist and require management in.

over 100 kg (220 Ib) per calendar seq.), Subtitle C; compliance with RCRA. Exelon

month of hazardous waste ships the 25 Pa Code Generation will characterize wastes

hazardous waste off-site Articles VII generated by refurbishment to

(Hazardous Waste determine proper disposal

Management) and procedures and permit

IX (Residual Waste requirements.

June 2009 C-5 NUREG-1 437, Supplement 37
Appendix C

Table C-2. Federal, State, and Local Permits and Other Requirements. TMI-1 is subject to

other requirements regarding various aspects of their environmental program. Those requirements are

briefly described below.

License, Permit, or Other Required Responsible

Approval Agency Authority Relevance and Status

Management)

Emergency Planning and Response

Submission of a list of Material Safety State and Emergency Nuclear power plant operators are

Data Sheets is required for hazardous local Planning and required to submit a List of Material

chemicals (as defined in 29 CFR Part emergency Community Right- Safety Data Sheets to State and

1910) that are stored onsite in excess planning to-Know Act of. local emergency planning agencies.

of their threshold quantities. agencies 1986 (EPCRA),

Section 311 (42

U.S.C. 11021); 40

CFR §370.20

Transportation of Radioactive Wastes U.S. HMTA (49 U.S.C. When shipments of radioactive

and Conversion Products Packaging, Department of 1501 et seq.); materials are made, nuclear power

Labeling, and Routing Requirements Transportation Atomic Energy Act plant operators would comply with

for Radioactive Materials is required for (AEA), as U.S. Department of Transportation

packages containing radioactive amended (42 packaging, labeling, and routing

materials that will be shipped by truck U.S.C. 2011 et requirements.

or rail. seq.); 49 CFR

Parts 172, 173,

174, 177, and 397

Biotic Resource Protection

Threatened and Endangered Species U.S. Fish and Endangered NRC would consult with FWS and

Consultation is required between the Wildlife Species Act of State agencies regarding the

responsible Federal agencies and Service 1973, as amended impact of license renewal on

* affected States to ensure that the (FWS) and (16 U.S.C. 1531 et threatened or endangered species

project is not likely to: (1) jeopardize State seq.) or their critical habitats.

the continued existence of any species agencies

listed at the Federal or State level as

endangered or threatened; or (2) result

in destruction of critical habitat of such

species.

Clean Water Act Section 404 (Dredge U.S. Army CWA (33 U.S.C. Any dredging or placement of fill

and Fill) Permit is required to place Corps of 1251 et seq.); 33 material into wetlands within the

dredged or fill material into waters of Engineers CFR Parts 323 and jurisdiction of the U.S. Army Corps

the U.S., including areas designated as of Engineers at a nuclear power

NUREG-1437, Supplement 37 C-6 June 2009
Appendix C

Table C-2. Federal, State, and Local Permits and Other Requirements. TMI-1 is subject to

other requirements regarding various aspects of their environmental program. Those requirements are

briefly described below.

License, Permit, or Other Required Responsible

Approval Agency Authority Relevance and Status

wetlands, unless such placement is 330 plant would require a Section 404

exempt or authorized by a nationwide permit. Exelon Generation is

permit or a regional permit; a notice reviewing options for transportation

must be filed if a nationwide or regional of the new steam generators from

permit applies. Port Deposit, Maryland, to the TMI1 site. If the selected route requires

dredge or fill activities, Exelon

Generation would have to apply for

a section 404 permit.

Cultural Resources Protection

Archaeological and Historical Pennsylvania National Historic NRC would consult with the State

Resources Consultation is required Historic and Preservation Act of and Tribal Historic Preservation

before a Federal agency approves a Museum 1966, as amended Officers and representative Indian

project in an area where. Commission (16 U.S.C. 470 et tribes regarding the impacts of

archaeological or historic resources seq.); license renewal and the results of

might be located. Archaeological and archaeological and architectural

Historical surveys of nuclear power plant

Preservation Act of sites.

1974 (16 U.S.C.

469-469c-2);

Antiquities Act of

1906 (16 U.S.C.

431 et seq.);

Archaeological

Resources

Protection Act of

1979, as amended

(16 U.S.C. 470aamm)

June 2009 C-7 NUREG-1437, Supplement 37

Appendix D

Consultation Correspondence

D. Consultation Correspondences

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

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

require that Federal agencies consult with applicable State and Federal agencies and groups

prior to taking action that may affect threatened and endangered species, essential fish habitat,

or historic and archaeological resources, respectively. This appendix contains consultation

documentation.

Table D-1. Consultation Correspondences. This is a list of the consultation

documents sent between the NRC and other agencies we are required to

consult with based on NEPA requirements.

Author Recipient Date of Letter

U.S. Nuclear Regulatory

Commission (L. Lund).

U.S. Nuclear Regulatory

Commission (L. Lund)

U.S. Nuclear Regulatory

Commission (L. Lund).

U.S. Nuclear Regulatory

Commission (L. Lund)

U.S Nuclear Regulatory

Commission (L. Lund)

U.S Nuclear Regulatory

Commission (L. Lund)

U.S. Nuclear Regulatory

Commission (L. Lund)

Stockbridge-Munsee Tribal

Historic Preservation Office

(S. White)

U.S. Fish and Wildlife Service

(D. Densmore)

Oneida Indian Nation (R. Halbritter)

Advisory Council on Historic

Preservation

(C. Vaughn)

Pennsylvania Department of

Conservation and Natural

Resources (C. Firestone)

Pennsylvania Fish and Boat

Commission (C. Urban)

Pennsylvania Game Commission

(L. Leigey)

Pennsylvania Historical and

Museum Commission

(J. Cutler)

U.S. Nuclear Regulatory

Commission (L. Lund)

April 4, 2008

April 9, 2008(a)

April 15, 2008

April 15, 2008

April 15, 2008

April 15, 2008

April 15, 2008

April 21, 2008

June 2009 D-1 NUREG-1437, Supplement 37
Appendix D

Author Recipient Date of Letter

U.S. Fish and Wildlife Service U.S. Nuclear Regulatory April 23, 2008

(D. Densmore) Commission (L. Lund)

Pennsylvania Department of U.S. Nuclear Regulatory May 2, 2008

Conservation and Natural Commission (L. Lund)

Resources (R. Bowen)

Pennsylvania Game U.S. Nuclear Regulatory May 14, 2008

Commission (J. Leigey) Commission (L. Lund)

Pennsylvania Fish and Boat U.S. Nuclear Regulatory June 3, 2008

Commission (C. Urban) Commission (S. Lopas)

U.S. Department of Interior, U.S. U.S. Nuclear Regulatory March 3, 2009

Fish and Wildlife Service Commission

(M. Chezik)

(a) Similar letters went to fourteen other Native American Tribes listed in Section 1.8.

D.1 Consultation Correspondence

The following pages contain copies of the letters listed in Table D-1. Figures contained in the

first letter (pages D-6 and D-7) were included with each letter mailed to consultation agencies.

NUREG-1437, Supplement 37 D-2 June 2009
Appendix D

April 4,-2008

Mr. David Densmore

U. S.Fishi,& Wldlife Service

Penhn sylvania. Field Offi6e

315 South Allen Street, Suite 322-

State College, PA, 16801",4850

SUBJECT:: REQUESf' FOR LIST-OF PROTECT&E SPECIESWITHI N THEAREAlUNDER:

EVALUATION FORTHE THREE MILE ISLAND NUCLEAR STATION, UNIT 1.

LICENSE RENEWAAL ,APPLICATION, REVIEW

Dear Mr; DensmoreThe U.S. Nuclear Regulatory Commission (NRCýor the staff) is reviewing an application

sqbmittedbyýAMerGen Energy Company, LLC (AmerGen)', for the. renewal of the operating

license for Thee Mile- sland Nuclear Station, Unit 1 (TM-1). 'TMI-1 is-located on Three Mile

Island, which is situated in the Susquehanna. River, in"Londonderry Township of Dauphin County, Pennsylvania, aboutf2.5 miles north of the souher tip of Dauphin County. As part of

the review ofthe license reheWal applicatio n (LRA), the NRC is prepaing a Supplerental

Environmental,' lmpact Statement-,(SEIS) underthe provisions of Title 10 of the Code of Federal

Regulations Part,5 1(10 &R P art 51), i:the NRC's. regulation thatirmplements the. National.

Environmental' Policy:Act (NEPA) of 1969. The SEIS includes an analysis of pertinent

environmental issues, including endangered or threatened speciesand impacts to fish and

wildlife.. This letter is being, submitted Under'the provisionsof the Endange:red Species Act of

1973, as amended, and the Fish and Wildlife Coordination Act of 1934, as amended.

AmerGen-is requesting renewal:of its operatijng license forTMI-1 forba period of 20 years

beyond the expirationof the current license term of April 2014. The proposed action Would

include the use and continued maintenance of existing plant facilities and transmission lines.

For the purpose of license renewaliAmerGen plans to replace the TMI-I steam generators, and

estimates that the total area disturbed by construction, decontamination, and iaydownactivities

would be less than 10 acres,-all of which wouldbe previously disturbed property Within the

bounds.of the TMI-1 flood ýprotectiondike.,

The TMI-1 site encompasses several properties that total approximately -440 acres, including:

the physical plantklocation on 200.acres of the 370-acre Three Mile Island; St. John's Island and

Evergreen Island (also refeired to as "Sand Beach Island"), together totaling.31 acres;, a 6.47

acre section of Shelley lsland, which is part of the western half of the TMI-1 Exclusion Area; and

a 32-acre strip:of land east;of Three-Mile Island along the eastern'shore of the Susquehanna

River; please seethe attached site boundary map, The TMI-1 site is surrounded by fencing and

contains few areas of undeveloped or undisturbed land; undeveloped land on Three Mi le sland

lies south of TMI-1 facilities. The majobrity:bf this.land lies. under the ten-yearflood level, and

contains wetlands and fallow fieldareas surrounded by a woodland.buffer. Riparian buffer

areas:are intact around .the perimeter of the island, although forested riparian areas only, occur

on the-southern part of the island.

June 2009 D-3 NUREG-1437, Supplement 37
Appendix D

0. Densmore, -2.-

TMI-1 utilizes two hyperbolic natural draft cooling towers for dissipating heat from the plant

steam-cycle. The circulating water and servicewter sysms withdrawwater from the

Susqueyhanna; River;,ý andare. suppleme. neted, byth.ree: groundwa.ter vwells. TMI-1 has a permit

with the Susquehanna River. Basin.Commission~for consumptive use of river water up to018

million gallons per day, ona mrfinthly hverage, for electric denefati6m. RiverWater enters the

intake structure locatedon the wester'n bank of Ahe island;, passes under a skimmer wall,

through automated traish.rackswith I-inch vertical bar spacing, through 3/8-Inch-resh traveling

screensthrogugh the rver water pumps, and finallyt8hrough 1/8-inch-mesh strainers- before

entering the heat exchangers. Approximately 3000 gallons per.minute of cooling tower

blbwdown arVediscl~rged :tothe Susuelian'na Rivbr throUgh:a 48-inrh-diamiTeterriver iischiargb

line.

Four 230-kilovolt (kV) transmission lines totaling 56: miles. of.corridor and approximately 142'

acres connect TMI-1 to theýregional t ransmissi-onsystem; please seed the attached TMI-1

transmission systemh map. Twa of thbese lines plant ponnlectthe with the substation at

Middletown Junction,,east oflthe•Susquehanna River; each'of these lines extends 1.5 miles. A

third line extends for 4.1 miles'to the ..vistvside of .the Susquehanna Rivertwhere it connets. to.

a 230-V line terminating into the substation:near Jackson - this 'line crosses the river twice.

The fourth line extends 0.7 miles east across the Susquehanna River to the TMI-1 500kV:

substation.

To support the SEIS preparation process and to ensure compliance with Section"7 of the

Endangered Species Act, the, NRC requests informationmon Federally listed, proposed, and

candidate species:;and critical habitat that. may bei hthe vicinity of TMI-1 and its associated

transmissioni line corfidors. Inn addition, pleaseiprovide any informationhyoU' consider appropriate

under the provisions of th!e Fish .and.Wi~ldlife Coordinaption Act.

The NRC staffp'Plans to: hold two public NEPA scoping meetings on:May 1, 2008. The first

session will be held in the aftemoon and an identical session will be held later thatevening. The

afternoon session will be held at thed Elks Movie Theatre, 4 West EmausStreet, Middletown, PA

17057. The evening session will be held at Londonderry Elementary School,1 260 Schoolhouse

Road, Middletown, PA 1705T The fir•st meeting will convene at 1:30 p~m. and will continue until

4:30 p.m., as necessary~. The'second meeting willconvene at 7:00 pM. and will continue until

10:0O p-m., as necessary. In addition; during theweek of April,28,. 2008, the NRC plans to

conduct a site audit. YOu and your staffare invited to attend both the public meetings and the

site audit. Your office will receive-a copy of thedraft SEIS along with a request for comments.

Theanticipated publication date for the. draft SEiS is December 2008.

NUREG-1437, Supplement 37 D-4 June 2009
Appendix. D

D. Densmore: -3-

If you have any questions concerning the NRC staff's review of th is license renewal applicati on,

ple.ae contact Ms. Sarah Lopas, License: Rehewl Project Manager, at 301-415-1147 or sI;,!2,•nrc~aov.

Sincerely,

IRAYJ

iLouis0 Lund, Branch:'Chief

Projects.Branch 1

ivision, of License-Renewal

Office of Nuclear Reactor Regulation

Docket No. 50-289

Enclosures:

1. Site Boundary:.Map

2. TMI-1 Transmission System Map:

ccw/enicls.: See next page

June 2009 D-5 NUREG-1437, Supplement 37
Appendix D

NUREG-1437, Supplement 37 D-6 June 2009
Appendix D

June 2009 D-7 NUREG-1 437, Supplement 37
Appendix D

April 09, 2008

The, Honorable Raymond Halbritter

Nation Representative

Oneida Indian Nation

5218 Patrick Road

Verona, NY 13478

SUBJECT: REQUEST FORWSCOPING COMMENTS CONCERNING THE THREE MILE

ISLAND NUCLEAR STATION, UNIT 1, LICENSE RENEWALAPPLICATION

REVIEW

Dear Representative Halbritter:

The U.S. Nuclear Regulatory Commission (NRC or the staff) has recently received an application from AmerGen Energy Company, LLC (AmerGen), for the renewal of the operating

license for the Three Mile Island NuclearStation, Unit 1 (TMI-1), located on Three Mile Island,

which is situated in the Susquehanna River, in Londonderry= Township of Dauphin County,

Pennsylvania. The NRC is in'the initial stages of'developing a Supplemental Environmental

ImpactL Statement to the Generic Environmental Impact Statement (GELS), which will document

the impacts associated with the renewal of TM I-1. We would like your assistance in our review

by providing input to the NRC's environmental review scoping process. The NRC's process

includes an opportunity for public and inter-governmental participation in the environmental

review. We want to ensure that you are aware of our efforts pursuant to Title 10 of the Code of

Federal Regulations Part 51 ,Section 51.28(b). In addition, as outlined in 36&CFR 800.8(c)the

NRC plans to coordinate compliance with Section 106 of the. National Historic Preservation Act

of 1966through the requirements of the National Environmental Policy Act of 1969.

The NRC has also sent copies of this letter to the tribal contacts for the following Federallyrecognized tribes: Absentee-Shawnee Tribe of Oklahoma; Cayuga Nation; Delaware Nation;

Delaware Trust Board; Eastern Shawnee: Tribe of Oklahoma; Oneida Indian Nation; Oneida

Nation of Wisconsin; Onondaga Nation; Seneca Nation of Indianis; Seneca-Cayuga Tribe of

Oklahoma;ZSt, ýRegis Mqhawk Tribe; Shawnee Tribe; Stockbridge-Munsee Band of the Mohican

Nation of Wisconsin; Tonawanda Seneca Nation; and Tuscarora Nation.

Under NRC regulations, the original operating license for a nuclear power plant is issued for up

to 40 years. The license may be renewed for up to an additional 20 years, if NRC requirements

are met. The current operating license for TMI-I will expire in April 2014. The proposed action

would include the use and continued maintenance of existing plant facilities and Itransmission

lines. For the purpose of license renewal, AmerGen plans to replace the TMI-1 steam

generators, and estimates that the total area disturbed by construction, decontamination, and

laydown activities, would be less than: 10 acres, all of which would be previously disturbed

property within the bounds of the TM I-I flood protection: dike. Provided for your information is

the TMI-1 site boundary map (Enclosure I) and transmission system map (Enclosure 2).

The GElS considered the environmental impacts of renewing nuclear power plantoperating

licenses fora 20-year period on all currently operating sites. InIthe GElS the NRC staff

identified 92 environmental issues and developed generic conclusions related to environmental

NUREG-1437, Supplement 37 D-8 June 2009
Appendix .D

-2-

impacts for 69 of these ssues that apply toall plants or to plants with specificdesign or site

characteristics.. For the remaining.23 issues, plant-specific analyseswil! be documented in a

supplement to, the GElS. Asupplemental environmental impa..ct statementwill. be prepared for

TMI-1 to document thestaff's:re view of environmental impacts related to terrestrial ecology;

aquatic ecooOgy, :hydr6olgy•, cultural reiources, an'd socioeconomiciissus i(aiong others), and:

will .contain a recommendation regardi.ng the environmental acceptability ofthe license'renewal

action.

Please submit any comments that. you may have to I:offer. on the scope of.the environmental

review by May 30, 2008. Written comments should:be submitted'by mail to the Chief, Rules

and Directives Branch, Division of Administrative Services, Mail Stop T-6D5,9, U.S, Nuclear

Regulatory0Commission, Washington, DC, 20555-0001. Electronic comments may be submitted

to the NRC by e-mail at ThreeMiielslandEiS(•nrcxaov. Atthe conclusion of the scoping

process, the NRC staff will prepare a summary of the significant issues ideintified and the

onclusions reached, and maila copy'tb you.

To accoinmodate. interested membersobf the public, the NRC Will Ihold two public scoping

meetings for the: TMITI license renewal supplement to the GElS on May 1,'2008. The first

session will be held in the afternoon'and an identicaI session will be held .later that evening. The

aftemoon session will be held at the. Elks Movie Theatre,*4 West Enmaus.Street, Middletown, PA

17057. Theýevening session will be held at Londonderry Elementary School, 260 Schoolhouse,

Road, Middiletown, PA 17057.. 'The firstimeeting Will convene at 1:30 p.m. and will continue. until •

4:30p.m., as necessary.i The second meeting will.convene at 7:00 p.m..and will continue until

10:00 p.m., as necessaryý. Additionally, the NRC staff will host informal discussions one hour

beforeithe start of each session.

The TMI-1 license renewal appiication and the GEldS are available on the internet at

Wwv;nrc.gov/reactorsio-eratin-q/licesinqrenetaapplicati6hi§/three-mile-island. html In addition, the following locations have agreed to make the license Irenewal application and the

GElS available for public inspection: Londonderry Township Municipal Building, 783 South

Geyers Church Road, Middletown, PA 17057; Middletown Public Libraryj 20 North Catherine

Street, Middletown, PA 1,7057; ,and Penn State Harrisburg Library,:351 Oirristed Drive,

Middletown, PA 17057.

The staff expects to publish.the draft'supplemental ebnivironmenrtal impact statement in

December:2008. A copy of the document:will be sent.to you for your review and comment. The

NR C will hold another set o•public meetings in thesitevicinity to solicit comments on the draft

supplemental environmeital impact statement,. After consideration of'public comments

received, the N RC willprepare a final supplemental environmental impact statement, which is

scheduled to. be issued in July 2009.

June 2009 D-9 NUREG-1437, Supplement 37
Appendix D

-3-

if you need additional information regardingthe license renewal review process, please §.contact

Ms. SarahLopas, License ReneWal Project Manager, at?301 .415-1.147Tor at sii20,nric.dov.e

Sincerely,

\RAX

Louise 'Lund, Branch Chief

Projects Branch 1

Division of. License Renewal

Office of Nuclear Reactor Regulation

Docket No. 50-289

Enclosures:

As Stated

NUREG-1437, Supplement 37 D-1 0 June 2009
Appendix D

April 15,-2008

Ms. Charlene Dwin Vaughn

Assistant:Director

Advisory :Council on Historic Preservation

Office of:Federal Agency Programs

1100 Pennsylvania Ae, 'NW, Suite 803

Washington, W 20004

SUBJECT: THREE MILE ISLAND NUCLEAR STATION, UNIT 1, LICENSE RENEWAL

APPLICATION REVIEW

Dear Ms. Vaughn:

The U.S. Nuclear Regulatory Commission (NRC or thestaff). is reviewing an application to

renew the operating license for Three Mile Island Nuclear Station, unit i (TMI-1),.located on

Three Mile Isla-nd, which is situated in•the Susquehanna River, 'in:Lononnderry Twnshi pof

Daudphin Cournty,Penshylvania, about 2.51miles north 6f thebsouthefn'tip of Dauphin Cbunty.

TMIA- is operated by AmerGen Energy Cmpany, LLC (ArerGen). The application for renewal

was submitted by.AmrerGern in a letter dated January 8, 2008, pursuant to Title 10 of the code

of Federal.Regulations Part: 54 (10,CFR Part 54).

The NRC has established that, as part of the staff's review of any nuclear power plant'licenhse

renewal action. a site-specific Supplemental Environmental Impact Statement (SEIS) to its

"Generic Environmental ImpactNStatementforicense Renewal o uclear'Plants," NUREG1437, will be prepared under the provisions of 10CFR Part 51, the NRC's regulation that

implements the National Environmental PoIlicyAct of. 1969 (NEPA) In :accordance with

36CFR 800.8(c), the:SEISWill include analyses of potential impacts to historic and cultural

resources.

On May 1, 2008, the NRC will conduct two public NEPAscoping meetings. The first session will

be held in the afternoon andqan identical session will 6beheld later that even ing. The afternoon

session will be held at the Elks Movie Theatre, 4-West Emaus Street, Middletown, PA 17057.

The ,evening session wilibe held atfLondonderry Elementary School, 26OSchoolhouse R0ad,

Middletown, PA 17057. The first rneeting Will convene at 1 30. p.m. and1will continue until

4:30 p~m., as necessary.. The second meetingwill convene at 7:00 p.m. •and will continue until

10:30 p.m, as necessary. You and yourstaff are. invited to attend the public meetings., In

addition, during theweek.of April128, 2008, the NRC staff plans to conduct a site:audit at TMI-1.

Your office will receive a copy of the draft: SEIS along with a request for comments. The.

anticipated publication date for the Idraft SE Iis Decembe.r 2008.

June 2009 D-1 1 NUREG-1 437, Supplement 37
Appendix D

C. Vaughn -2-

If yqu have any questions or require additional information, please contact the LicenseRenewal.

Project Manager' Ms. Sarah.Lboas, at 301-415-1147 or by ei-mail at6s1122nrc~aov.

Sincerely,

IRAI

Louise Lund, Branch Chief

Projects Biranch 1

Division of License Renewal

Office ofNuclear Reactor Regulation

Docket No. 50•289

cc:- See next page

NUREG-1437, Supplement 37 D-1 2 June 2009
Appendix D

April 415, 2008

Ms. Chris Firestone

Native Plant Program Manager

BurIeau of. Forestry,(Plant Program):

Forestiy 'Advisory .Services

Pennsylvania'D epartment of Conservation

and Natural Resources

P.O. Bbx 8552

Harrisburg, PA. 17105-1,673,

SUBJECT: REQUEST FOR LIST OF STATE-PROTECTED SPECIES&AND IMPORTANT

HABITATSV ,ITHIN THE AREAUNDE-R EVALUATION FOR THE THREE MILE

ISLAND NUCLEAR STATION, UNIT 1, LICENSE RENEWAL APPLICATION:

REVIEW

Dear Ms. Firestone:

The: U.S. Nuclear Regulatory Commission (NRC or the.staff) is reviewing an applicationsubmitted'byAmerGen Energy Company, LLC (AmerGen), for the renewal of the operating

license for Three Mile'Island N uclear Station, Unit 1 (TMI- 1). TMI-1 is located on Three Mile

Island, which is situatedin the, Susquehanna River,, in Londonderry TownshipWof Dauphin

County, Pennsylvania, about:2.5 miles north of the southem tip of Dauphin County. As part of

the reviewiof the license renewal application (LRA)Ithe NRC is preparing a Supplremental

Environmental Impact Statement (SEIS) under~the provisions of Title 10 of }the Code of Federal

Regulations Part 51.(10 CFR Part 51), the NRC's.r egulation that implements the Natiohal Environmental Poy Act.(N EPA) of 1969. The SEIS includes an analysis of pertinent

environmental issues, including endangered.or threatened species and impacts to fish and

wildlife.

AmerGenr.is requesting renewal of its operating license.for TMI-1 fo• a peri6d of 20 years

beyond the expirationmof the current license term of April'201iý The proposed action .would

include the.use and continued maintenance of existing plant facilities and transmission lines.

F6r•the purpose of license renewall, AnierGen plans to replace the TMI-1 steabm generatbr5s, and

estimates that the total'area disturbed by construction,-decont)mination, and laydown iactivities

would be less than" 10 acres,; all of. which wUold be previously disturbed property. within the

bounds.of:the TMI-1 flood protection dike..

The TMI-I siteLencompasse•S severalipro6perties that totlala, approximately .4401acres, including:

the-physilcal p!antlocation on 200acres of the'.370-acre Three Mile Island: St. John's Island and

Evergreen Island (also referred to as "Sand Beach Island". together totaling 31 acres; a.4-

acre section of ShelleyIsland, which is-part of the western half of the TMI-! Exclusion Area; and

a 322-acre strip of land east of Three Mile Island along the eastern shore of theSusquehanna

River; please see the enclosed site boundary map. TheJTMI-1 site is surrounded. by fencing

and contains'few areas of undeyeloped or undisturbed land; undeveloped land on. Three Mile

Island lies south of TMI-1 facilities. The majority of this land lies under the ten-year flood level,

and contains wetlands and fallow field areas surrounded by a woodland buffer. Riparian buffer

areas are intact around the perimeter of the island, although forested riparian areas only occur

on the southern part of the island,

June 2009 D-1 3 NUREG-1437, Supplement 37
Appendix D

C. Firestone -2-

Four 230-kilovolt'(kV) transmission linestotaling 5.6 miles of corridor.and approximi-ately 142

acres connect TMI-! to thesregional transmissionmsysterm; please see ,the enclosed TMI-1

transmission'system map. Twoof. these lines connect the plant with the substation at

Middletdvii Juniction,. east of the Susquehanna River; each•of these lines exends 1.5 miles.

A third line extendslfor 4.1 mileslto the west side of the ;Susquehanna River, where. it connects

to a. 23-kv line terminating•into the substa•ionhnear.Jackson - thislirine crosses the rive twice.

The fourth line extends 0.7 miles:east across the Susquehanna River to the TMkI 500-kV

substation.

To:supportthe SEIS preparation process and to ensure compliance with Section 7 of the

Endangered Species:Act, the NRC requests information on state-listed, proposed, and

candidate;species and critical habitat that may be in the vicinity of TMI-1 zand its associated

transmission. lne corridors.

The NRC staff plans.to hold two public NEPA scopihg meetingson May 1, 2008. The first

session Will .be held in the afternoon and an identical session Will be held later that evening. The

afternoon session will be held at the Elks Movie Theatre, 4 West Emaus Street, Middletown, PA

17057. The:evening sess ion will be held at Londonderry. Elementary Schoo 260 Schol house

Road, Middletown, PA 17057.. The first meeting Wil convene at: 1:30 p.m. and will continue until

4:30p m,, as necessary. Thesecond meeting will convene at 7:00 p~mý.and •il continue until

10:00Ip.m., as necessary. In addition, during the week of Apri 28, 2008, .the NRC plansto:

conduct.a site audit. You and your staff are invited to attend both the public meetings and the.

site audit. Your office will receive.a copy of the draft SEIS alorng with a request for comrments.

The~anticipated publicatiOnrdate for the draft SEIS-is December 2008.

if you haveany questions concerning theN RC staff's review of this license renewal application,

please contact Ms, Sarah Lopas, License. Renewal Project Manager, at:3011-415- 1,47 or:by

e-ma il at.s,20-nrc.ciov.1

Sincerely,

/RA/

Louise Lund, Branch Chief

Projects Branch 1

Division of License Renewal

Office of NuclearýReactor Regulation

Docket No. 50-289

Enclosures:

As stated

cc w/encls. See next page

NUREG-1437, Supplement 37 D-1 4 June 2009
Appendix D

April 15, 2008

Mr. Christopher Urban

Chief of Natural Diversity Section

Pennsylvania Fish and Boat Commission

450.Robinson Lane

Bellefonte, PA 16823-9620

SUBJECT:" REQUEST FOR LIST OF STATE-PROTECTED SPECIES WITHIN THE AREA

UNDER EVALUATION FOR THE THREE MILE ISLAND NUCLEAR STATION,

UNIT 1, LICENSE RENEWAL APPLICATION REVIEW

Dear Mr. Urban:

The U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing an application

submitted by AmerGen Energy Company, LLC (AmerGen), for the. renewal of the operating

license for Three Mile Island Nuclear Station, Unit I (TMI-1). TMI-1 is located on Three Mile

Island, which is situated in the Susquehanna River, in Londonderry Township of Dauphin

County; Pennsylvania, about2.5 miles north of the southem tip of Dauphin County. As part of

the review of the license renewal, application (LRA), the NRC is preparing a Supplemental

Environmental Impact Statement (SEIS) under the provisions of Title 10 of the Code of Federal

Regulations Part 51 (10 CFR Part 51), the NRC's regulation that implements the National

Environmental Policy Act (NEPA) of 1969. The SEIS includes an analysis of pertinent

environmental issues, including endangered or threatened species and impacts to fish and

wildlife.

AmerGen is requesting renewal of its operating license for TMI-1 for a period of 20 years

beyond the expiration of the current license term of April2014. The proposed action would

include the use and continued maintenance of existing plant facilities and transmission lines.

For the purpose of license renewal, AmerGen plans to, replace the TMI-1 steam generators, and

estimates that the total area disturbed by construction, decontamination, and laydown activities

would be less than 10 acres, all of which would be previously disturbed property within the

bounds of the TMI-1 flood protectiondike.

The TMI-1 site encompasses several properties:that total approximately 440 acres, including:

the physical plant location on 200 acres of the 370-acre Three Mile Island; St- John's Island and

Evergreen Island (also referred to as "Sand Beach Island"), together totaling 31 acres; a 6;4- acre section of Shelley Island, which is part of the western half of the TMI-1 Exclusion Area;:and

a 32-acre strip of land east of Three Mile Island along the eastern shore of the Susquehanna

River; please see:the enclosed site boundary map. The TMI-1 site is surrounded by fencing

and contains few areas of undeveloped or undisturbed land; undeveloped land on Three Mile

Island lies south of TMI-1 facilities. The majority of this land lies under the ten-year flood level,

and contains-wetlands and fallow field areassurrounded by a woodland buffer. Riparian buffer, areas are intact around the, perimeter of the island, although forested riparian areas only occur

on the southern part of the island.

June 2009 D-1 5 NUREG-1437, Supplement 37
Appendix D

C. Urban -2-

TMI-1 utilizes two hyperbolic natural draftbCooling towers for dissipating heatfrom the plant

steam cycle. The circulating water and service water systems withdraw water from the

Susquehanna River, and are supplemented by three groundwater wells., TMI-1 has a permit

with the Susquehanna River Basin Commission for onsurmptive useof river Water up to-18

million gallons per day, on a monthly average,; for electric generation. River water enters the

intake structure located on the western bank of the island, passes under a skimmer wall,

through automated trash racks with 1-inch vertical bar spacing, through 3/8-inch-mesh traveling

screens, through the river water pumps, and finally through 1/8-inch-mesh strainers before

entering the heat exchangers. Approximately 3000 gallons per minutbeof coolinig tower

blowdown are discharged-to the Susquehanna River through a 48-inch-diameter river discharge

line.

Four 230-kilovolt (kV) transmission lines totaling 5.6 miles of corridor and approximately 142

acres€connect TMI-1 to the regional transmission system; please see the enclosed TMI-1

trarnsmissionmsystem map. Two of these lines connect the plant with thesubstation at,

Middletown Junction, east of the Susquehanna River; each of these lines extends 1.5 miles. A

third line extends for 4.1 miles to thewest side of the Susquehanna River,:where it connects to:

a 230-kV line terminating into the substation near Jackson - this line crosses the river twice.

The fourth line extends 0.7 miles east across the Susquehanna Rivefto the TMIl 500-kV

substation..

To-support the SEIS:preparation process andto ensure compliance with Section 7 of the.

Endangered Species Act, the NRC requests information on state-listed, proposed, and

candidate. species and critical habitat that may beJn the Vicinity of TMII-11and its associated

transmission line corridors. Please see the enclosed Species Impact Review (SIR) request.

form.

The NRC staff plans to hold two pub ic NEPA scoping meetings on May 1 2008- The first

session will be held in the afternoon0and an identical session will be held later that evening., The:

afternoon session will be held at.the Elks Movie Theatre, 4:West Emaus Street, Middletown, PA

17057. The evening sessionwill be held at Londonderry Elementary School, 260 Schoolhouse

Road, Middletown, PA 17057. The first meeting will convene at 1:30 p~m. and Will continue until

4:30 p.m., as necessary. The second meeting will convene at 7:00 p.m. and will continue until

10:00 p.m., as necessary. In addition, during the week QofApri 28, 2008, the NRC plans to

conduct a site audit. You and your staff are invited:to attend both the public :meetings and the

site audit Your office will receive a copy of the draft SEIS along with a request for comments;

The anticipated publication date for the draft SEIS is December 2008.

NUREG-1437, Supplement 37 D-16 June 2009
Appendix D

FISH AND BOAT COMMISSION

NATURAL DIVERSITY:SECTION

PFBlC-DES-NDS-A (03)s PECIES IMPACT REVIEW (SIR) REQUEST FORM

COM MONWEALTH .

A. This form provides the site information necessary. to perform a computer.database: search for species of special concern

listed under the Endangered Species Act of 19.73 the Wild Resource ConservationAcL the Pennsylvania Fish and Boat Code or the

Wildlife Code.

B. Use only one form foreach proposedproject orlocation. Complete the information below and.mail form toý OF PENNSYLVANIA Natural Diversity Sect finDivisiion

ofEnvironmental Services PA Fish

a Boat Commission .45.0

,Robinson Lanie Bellefonite, PA.

16823 'Fax: (814) 359-5175

C. This form, a cover letter ificludinf a project narrative,,and accompanying maps should.beseefitto. th-te above address for

environmental revieWs'that diily onceri reptiles,.amphibians, fishes and aquatic iitertebrates. Reiews:for .dther.hatural re surs6

riist be:tubrfiitted to other.appropriate agencies.

D.- The absence of recorded information from. our databases and files does not necessarily imply actual conditions.on site.

Future field investigations could~alter ýthis determinationr The-information contained in.our files is routinely update& A review is

valid for one year.

E. Please send us only one (1) copy of your request.- either by fax or by mail - not both. Mail is preferred to improve

legibility of maps. :Facsimile submission will not improve~ourresponse turn-around time.

F Allow.30 days:for completion of the reviewffrom the date of PFBC receipt. 'Large projects and worddoad mayextend this

review timeframe.

'G. In any future correspondence with us following.your receilt of the SIR response,,please refer io the..assigned SIR number

at the top left of our cover letter.

H. FORMS THAT•ARE NOT:COMPLETED IN FULLWILL NOT BE REVIEWED.

PLEASE-PRINT OR TYPE: If availableoprovide thieptenfialconflict PNDI SarchNumbc6 N/A

PFBCre•ponse should be sent to Compainy/Agencyr U.S. Nuclear RegulatorcbComm ission

FormPreparer: Sarah Lopas, LicenseeRenewal Project Manager

Address: U.S. Nuclear Regulatory.Commission, 11555Rockville Pike, Mail Stop'Og 11F1, Rockville MD 20852

Phone (8-00 AMto 40.)PMf): 301.415.1147

'Project Description: Three Mile Island Nuclear Station,VUnit 1, License Renewal (pleaseiseexover letter):

Indicate Will if the project is: Transportation' or Non-transportation X(check one) tie proposed project encach directly or ndirectly (eg., ruoff upon wetlands or water sys? .ircleone:•f•r •each:

Wetlands: Yes No0UIONO . Waterways: YES N6 Urnkntwn

Countyi: Diuphiin Township/Municipality. Londonderry

:Name of theýUnited States Geol6gical Survey (U:Sý.G.S) 7.5'Mrnute.Qua M• 4ag W'hi'eprject is' lcted.- Middletown

Projectsize (iniadres): Appiroximiatel,276 Attachart 85". by 11 phot6cok@ (DO6NOTREDUCE) of the s6etidn of the

U S.G.S Quadrangle Map which idenfifies the project location. On this imap, :indicate the lcationof the pr6ject centef'(if linea',

depict b4th ends),and outli•e the'ap'proximte boundaries:of the pfrjec are', Specify 1Ititude/loigiu 6f the projjeccentrf..

:Latitude: 400 /9.2 N

Longitude: .720 /43.5' W

FORPFBC USE ONLYý

SIR# quad. Name Data Source Search Result-Potentiil Species Conflict Action

June 2009 D-17 NUREG-1437, Supplement 37
Appendix D

April 15, 2008

Mr.- James Leigey

Wildlife Impact Review•Coordinator

Pennsylvania Game C•rmmission

2001 Elmerton Avenue

Harrisburg, PA 17110-9797:

SUBJECT: REQUEST FORLIST-OF STATE-PROTECTED. SPECIES WITHIN THE AREA

UNDER EVALUATION FOR THE THREE. MILE ISLAND NUCLEAR STATION,,

UNITf1 LICENSE RENEWAL APPLICATION REVIEW

Dear Mr. Leigey:

The.U.S. NuclearRegUlatory Commission (NRC.or the staff) is reviewing an application submittedby ,AmerGen Energy Company, LLC the renewal of theA..eren),for operating

license for Three Mile.lsland Nuclear Station, Unit 1 (TMI-1). TMI-1 is located on Three Milek

Island, which is situated inthe Susquehanna River. in Londonderry Township of'Dauphin

County, Pennsylvania, about 2.5 miles north of the southern tip of Dauphin County. As partof

the review.of the license renewal application (LRA),:the NRC: is preparing aýSulpplemental EnVironmental lmpac Statement (SE!S), underlthe provisions of Title 10 of the Code of Federal

Reguilatibns Part 51 (10 CFR Part 51),,the NRC'S regulation that implements the National,

Environmental Policy.Act (NEPA) of 1969. The SEIS ,includes. an analysis of pertinent

environmental issues, including endangeredor threatened species and impacts to fish and,

wildlife.

Amerden is requesting renewalhof its operatinglicenseofor TMI-l1 for a period-of 20 years

beyond' the expiration:of the current license termnof Ail1 2014. The proposed action would

include the use and continued maintenance:of existing plant facilities and transmission lines;.

For the purpose of license reniewal, AmerGen plans~to replace the'TMI-1 steam generators, and

estimates that the total area disturbed by construction,: decontamination, and laydown activities

would be less than 10 acres, al 1of which wouldfbe previously disturbed propertywthin the

bounds of the TMI-1 flo6d protectionhdike.:

The TMI-1 site encompasses'several propertiestfhat totalapproximiately 440 acres, .including:

the physical plant location on 200:acres of theZ370-acre Three Mile Island; St. John's Island and

Evergreen Island (also referred'to as "Sand Beach Island"), together totaling,31 acres;a: 6.4-

acre section of Shelley lsland,•which is:part of theWesternh half of the TMI-.1 Exclusinh;Arfea; zand

a 32-acre strip of land eastof Threeý Mile Island along the eastern shore of the:Susquehanna RiVer; please see the enclosed site boundary map. The TMI-1 siteis.surrounded by fencing

and contains few~areas of undeveloped'or undisturbed land; undeveloped land on Three Mile

Island lies south of TMI-1 :facilities. The majority:of this land lies under the. ten-year flood level,,

and contains wetlands and fallow field areas'surrounded by a woodland buffer. Riparian buffer

areas-are intact around the perimeter of the: island, although forested fiparian areas'only:occur

on the southern part of the island.

NUREG-1437, Supplement 37 D-18 June 2009
Appendix D

J. Leigey - 2-

Four 230-kilovolt (kV) transmission lines totaling 5.6 mmiles of corridor and approximately 142. acres connect TMI-1 to the regional transmissionisystem; please seethe enclosed TMI-1

transmission system map. Two of these lines connectthe plant with the substation at

Middletown Junction, east of the Susquehanna River; each of these lines extends 1.5 miles. A

third line extends for 4.1 miles to the west side 6fthe sUsquehanna River, where it connects to,

a 230-kV line terminating into the substation~near Jackson - this line crosses the river twice.

Thedfourth. line extends 0.7 miles east across the .Susquehanna River to the:TMI-1 500-kW

substation.

To0supportbthe SEIS preparation process and to ensure:compliance With Section 7 of the.

Endarngered Species Act, the NRC requestsinformation;on state-listed,:proposed, and

candidate.species and critical habitatthat m ay be in thd vicinityof TMi-! and ts associated

transmission line corridors.

The NRC staff plans to hold two, public NEPA scopinig meetings onMay 1, 2008. Thebfirst

session will be held in the aftemoomnand an iidentical session will be held later that evening.. The

aften-oon session will be held at the, Elks Movie Theatre,4West ErmausStreet, Middletown, PA

17057. T'heevening session will be held at Londonderry Elementary School, 260 Schoolhouse

Road, Middletown, PA 17057. The first meeting will!convene at 1:30 p.m. and will contnue until

4:30'p.m., as necessary. The second mibeetingý willicon6vene at 7'.00 p.m..arid will continue: until

10:00 p~m., as necessary. In addition, during the week of April28, 2008,the NRC plans to

conduct a site audit. You and your staffare invited to attend both the public meetings and the

site audit. Your office will receive a copy of the draft SEIS along with a request for:comments.

The anticipated publication date for the draft SEIS is December 2008.

If you have any questions concerning the.NRC staff's review of this license renewal application,

please contact Ms. Sarah Lopas, License Renewal Project Manager, at'301-415-1,147 or by

e-m ail :at sll26-nrc.gov.

Sincerely,

IRAI

Louise Lund, Branch Chief

Projects Branch 1

Division.o6f License Re neywal

Office of'NuclearReactor Regulation Docket No. 50-289

Enclosures:

As stated

cc w/encls: Seewnext page

June 2009 D-19 NUREG-1437, Supplement 37
Appendix D

April :15,:2008

Jean Cutler, Deputy.State HistoricPreservatiori Officer

Pennsylvania Historical and Museum Commission

Bureau-for Historic Preservation

Commonwealth KeystoneBuilding, Second Floor 400WNorth Street

Hadrrisburg, PA 17120-0093:

SUBJEiCT• THREE MILE ISLAND NUCLEAR STAtION, UNiT 1, LICENSE RENEWAL.

APPLICATION REVIEW-(FILE NO. ER 07-1737-043-A)

Dear: Ms. Cutler:

The'U.S, Nuclear Regulatory Commission (NRC'oir the staff) is. reviewing an applicationto

renewlthe operating license for Three Mile:Island Nuclear Station, Unit 1 (TMI-1), located on

Three Mile Island, which is situated. in thel Susquehanna: River,,in"Londonderry Township of

Dauphin County,,Pennsylvania, about 2.5 miles horth of-the.southernrtip of Dauphin County.

TMI-I is operated b AmerGen Energy .Company, LLC (AmerGen). The application for renewal

was submitted by AmerGen in a letter dated January 8.2008, pursuantto, Title 10of the Code

of Federal.Regulations Part 54 (10!CFRPart 54).

The NRC has established that, as part of the.staff's review of any nuclear power plant license

renewal action,:a site-specific SupplementalrEnvironmental Impact Statement (SEIS) to:its

"Generic Environmental Impact Statement for license Renewal of Nuclear Plants," NUREG1t437,•will be prepared under the provisions of 10:CFR:Part51, the NRC's regulation that

implements the Natonal Environmental Policy-Act olf 1969 (NEPA). !n accordance with 36CFRý 800.8(c), the SEIS wiI nclude analyses ofpotential impacts to historic aandculturl resources.

In thecontext of the National HistoricPreservation Act of 1966 as amended, the NRC staff has:

determirind tiat the area of potential effect (APE) for a license renewal action is the-area at the

power plant site and its immediate environs that may be impacted by post-license renewal landdisturbing operations or projected refurbishment activities associated With the proposed'actin.

The&APE may extend beyond the immediate environs in ,those instances where post-license

renewal land-disturb ing operations•or projected-refurbishment activities specifically related to

license renewal may potentially have anmeffect on known or. proposed historic sites. This.

determination is made irrespective of ownership or control of the Ilands-of interest.

On May 1, 2008, the NRC will conduct two public NEPA.scoping meetings. The first session will

be held in the afternoon and an identical session will be held later that evening. The afternoon

session Will be held at the Elks Movie Theatre, 4 West: Emaus Street, Middletown, PA 17057.

The: evening session will be held at'Londonderry Elementary'School, 260 Schoolhouse: Road,,

Middletown, PA 17057: The first meeting will convene at 1:30:pm. andwill continue until

4:30 p.m., as necessary. The second meeting will convene at 7:00 p.m, and will continue until

10:00 p.m., as necessary. Youand yourstaff are invitedto attend. Your office will-:receive a

NUREG-1437, Supplement 37 D-20 June 2009
Appendix D

J. Cutler -2:-

copy of the draft SEiS along~with.a request for comments. Thestaff expects to publish the draft

SEIS in December 2008. Ifoyoubhave any questions or require additional irnformation, please.

contact Ms. Sarah Lopas. License Renewal'Proct Managerby phone at:301-415-1147:or by

e-mail at sll20_nrc.pov.

Sincerely,

IRA/

Louise Lund, Branch Chief'

Projects Branch 1

Division of License Renewal

Office of Nuclear Reactor Regulation

Docket No. 50-289

cc w/encls-. See next page

June 2009 D-21 NUREG-1437, Supplement 37
Appendix D

Sck-ridge-Mu ee TriaNistoric Of

SMerry ite - Tri6alH~istric reservation (OffP"

W13047 Camp 14 Ro•d

PO. BoXO 70 NO AFPR 2.9 AN 8: 49

!Boroe, 'WI 54416

RECEIVED

Chief

Rules & Directives Branch

Division of Administrative Services

Mail Stop T-6D59

U.S. Regulatory Commission

Washington. Dbij ooo1 0

As described npur correspondence, the proposed ground

project is notfii-Vregion of archaeological interest to the St(

We appreciate your toperation - in notifyio g the Historic Pr

you have a questiA lfetl fireet otc

(71) 7933-3970 Emaiid r;yrdwit@mofiwtm-nmgov

NUREG-1437, Supplement 37 D-22 June 2009
Appendix D

United States Department of the Interior

FISH AND WILDLIFE: SERVICE

C N 3 Pennsylvania Field Office

315 South Allen Street; Suite 322

State College, Pennsylvania 16801-4850

April 23,2008

Louise Lund, Branch Chief

Projects Branch I

Division of License Renewal.

Office ofNuclear Reactor Regulation

Nuclear Regulatory Commission.

Washington, D.C. 205.55-0001

Re: Three Mile Island Nuclear Station, Unit 1, License Renewal Application Review

USFWS Project #2007-1764

Dear Ms. Lund:

This responds to your April 4, 2008, letter. requesting information on threatened or endangered

species or other natural resources of concern in the referenced project area. The following

comments are provided pursuant to the Endangered Species Act of 1973 (87 Stat.. 884, as

amended; 16 U.S.C. 1531 etseq.) to ensure theprotectionof endangered and threatened species,

and the Bald and Golden Eagle Protection Act (Eagle Act; 16 U.S.C. 668-668d).

Federally Listed Threatened or Endangered Species

Except for occasional transient species, no federally listed or proposed threatened or endangered

species under our jurisdiction are known to occur within the project impact area. Therefore,

based on.currently available information, no biological assessment or further consultAtion under

the Endangered Species Act is required with the Fish and Wildlife Service. Should project plans

change,.or-if additional information on listed or proposed species becomes available, this

determination may be reconsidered.

Bald Eagle

In a letter to Michael Gallagher of AmerGen (copy enclosed), dated.June 7,2007, we advised

that a bald eagle nest is located on the west side of the Susquehanna River to the northwest of the

Three Mile Island facility. At the time, the bald eagle was federally listed as threatened.

HOwever, the Fish and Wildlife Service has. since published a final rulemaking to~remove the

bald eagle from the federal.List of Endangered and Threatened Wildlife on July 9, 2007 (Federdl

Register, Vol. 72, No..130). This rule became effective On August 8, 2007. Although the bald

June 2009 D-23 NUREG-1437, Supplement 37
Appendix D

eagle no longer receives protection under the Endangered Species Act, it continues to be

protected under the Eagle Act and the.Migratory Bird Treaty Act. Both acts protect bald eagles

by prohibiting killing, selling or otherwise harming eagles, their nests or eggs. The Eagle Act

also protects eagles from disturbance. Disturb means to agitate or bother a bald or golden eagle

to a degree that causes, or is likely to cause, based on the best scientific informationmavailable, 1) injury to an eagle,. 2) a decrease in its productivity, by substantially interfering with normal.

breeding, feeding, or sheltering behavior, or 3) nest abandonment, by substantially interfering

with normal breeding, feeding, or sheltering behavior.

The Service has developed National Bald Eagle Management Guidelines to advise landowners,

land managers and others who share public and private lands with bald eagles when and under

what circumstances the protective provisions of theEagle Act may apply to their activities. The

Guidelines include general recommendations for land management practices that will benefit

bald eagles; however,.,the document is intended primarily as a tool to provide those who seek

information and recommendations regarding how to avoid disturbing bald eagles. Adherencelto

the: CGidelines Will benefit individuals, agencies, organizations and companiesby helping them

avoid violations of the law. The Guidelines can be found at httn*//Www.fýs.o6v/migratorybird/

baldeagle~htm; any questions about the Guidelines or how they would apply to a particular

project, can be directed to this office.

Transmission lines and their support structures within or close to the shores of the river would be

ideal perching locations for foraging eagles. If the lines are not already equippedwith features to

prevent raptor electrocution andcollisions, we recommend that any future.upgrades be adesigned

following the Suggested.PracticesforAvian Protection on Power Lines: The St.te of the Art in

2006 (available from the Avian Power Line Interaction Committee at http://www.aplicýorg)..

Based on our review-of the proposed projecteit is out determination that this project will not.

disturb bald eagles. Because io take or disturbance is anticipated, none is authorized. If.project

plans change, please contact the Service to determine whether or not the project modifications.

will result in effects to bald eagles that may necessitate an Eagle Act permit or Endangered

Species Act authorization.

Thank you for the opportunity to comment. Please direct any questions regarding this matter to

Cindy Tibbott of my staff at 814-234-4090.

Sincerely,

David Densmore

Supervisor

Enclosures

2

NUREG-1437, Supplement 37 D-24 June 2009
Appendix D

Cc:

Michael Gallagher, AmerGen, 200 Exelon Way, KSA/2-E, Kennett Square, PA 19348

CTibbott:clt 4/15/08

P:\Drafts\Drafts 2008\2007-1764 Three Mile Islanddoc

June 2009 D-25 NUREG-1437, Supplement 37
Appendix D

DPennsylvania Department of Conservation and Natural Resoures

Bureau of Forestry May 2, 2008

Louise Lund, Branch. Chief, Reactor Projects 1 C.C. Sarah Lopas

MSO I1FI MS O-11F1

Office of Nuclear ReactorRegulation U.S. Nudear Regulatory Commission

U.S. Nuclear Regulatory Commission 11555 Rockville Pike

Washington, DC 20555-0001 Rockville MD .20852

Pennsylvania Natural Diversity Inventory Review, PNDI Number 19605 (old #19248)

Three Mile'Island Unit 1 License Renewal Species of Special Concern

Dauphin & Lancaster Counties

Dear Ms. Lund,.

This responds to your request about a Pennsylvania Natural Diversity Inventory (PNDI) ER Tool "Potential

mfipa" ora.speiciesofspnd6Wl:cncermimpact review.; W'scieeniddthls projectifor potential impacts to spebies

and resources of special'concern under the Department of Conservation andNatural .Resources' responsibility;

Which iaclnd,:plants il:cofiics;trral ihvdrtebrdtds-auid geblogit features'oy:- 'l -' . -

PNDI records indicate that species and communities of special concern under DCNR's jurisdiction are known to

occur in the vicinity of the above-mentioned project. Please see'the attached fist for species found in the

vicinity of this project. No impact is anticipatied since earth disturbance is expected to be "within the

bounds of the Three MileIsland Flood Protection dike," as stated in April 15,-2008 letter to DCNR. If

plans change to include disturbance outside of the Flood Protection dike area (particularly if more

disturbance is required for Transmission Line No.1051), please coordinatewith our office as a survey may

be requested.

This retponse represents the~most up-to-date summary:of the:PNDI data files and is -good for:one. (l).year from

the date ofthis letter. An absence of recorded information does not necessarily imply actual conditions on-site.

A field survey of any' site may' reveal previously unreported populations. Should project plans change or

additional information onlisted or proposed species become~available, this determination may be reconsidered.

This finding applies to impacts to plants, natural communities, terrestrial invertebrates and geologic features

only. To complete your reviev"of state dad federally-listed'species of special concern, please be sure the U.S.

Fish hnd Wildlife ,Servic,)did 'PA.Gint• Com*issidii.and-the •Fish':atd Boat-:ComnmisSion::has.beei,,contacted

regarding".thisý project eithe'r directly-or by performing. a seairhwiith :tie online' PNDI'ER'. Tool found: at

........................ ......... ......

Rebecca K- Bowen, Environmental Review Specialist

DCNRIBOF/PNDI, PO Box 8552, Hamsburg, PA 17105 - Ph: 717-772-0258 - F: 717-772-0271 cjrboweistate.ius

Stewardship Partnership Service

An E•U2 Opportuniry Enpiover www.dcnr.fstte.p3•US Prntea on Reevea PaD-r

NUREG-1437, Supplement 37 D-26 June 2009
Appendix D

Bureau of Forestry May 2,2008

Pennsylvania Natural Diversity Inventory Review, PNDI Number 19605(old #19248)

Three Mile Island Unit 1 License Renewal Species of Special Concern

Dauphin & Lancaster Counties

Plant Species of Special Concern

Scientific Common Current Proposed

Name Name Status :Status Habitat Flowering time

Boltonla Aster-like rocky shores and exposed

-asteriies Botonia PE PE rocky river beds flowers July-Oct

Carex calcareous wet meadows and

shortiana Sedge N PR swamps and rich woods..

FlatEleochads stemmed. wet, sandy ground and river

compressa Spike-rush PE PE banks

Ellisia damp, shady banks and rich

nyctelea Ellisia PT PT alluvial woods flowers in May

Addifional Information:.

Butterfly S es of Special Concern

Scientific Common Global

Name Name Rank State Rank Habitat Larval Host

Currently unrankable due to Low wet meadows I Water dock

lack of information or due to marshes, especially (Rumex

substantially conflicting in river flood plains. orbiculatus) and

*Lycaena Bronze Globally 'information about status or Very large, floppy- curled dock

hyllus Copper Secure: trends, flying copper. (Rumex cnspus)

Geologic Features of Special Concern

Erosional Remna made up of a series of large potholes in diabase in the bed of the Susquehanna from the

Triassic Age is known to exist where the transmission lines cross the river towards'York Haven.

Communities of Special Concern

There is also a Riverside Outcrop Community in the vicinity. This. community is characterized by semipermanently or seasonally flooded vegetation of the riverbed, banks and islands.

More informationon this community may be. found online in Terrestrial & Palustrine Plant Communities of

Pennsylvania by Jean Fike, Pennsylvania Natural Diversity Inventory:

htp://www.dcnr:state.pa.us/wrce'fikebook/21 Chapter8.pdf (page 55).

No impact anticipated,- this siSt is for your own information.

June 2009 D-27 NUREG-1437, Supplement 37
Appendix D

COMMONWEALTH OF PENNSYLVANIA

PENNSYLVANIA GAME COMMISSION

2001 ELMERTON AvENUE, HARRISBURG,:PA 17110-9797

May 14, 2008

Ms. Louise Lund

U S. Nuclear Regulatory Commission

Projects Branch I

Division of License Renewal

Office of Nuclear Reactor Regulation

Washington, D.C. 20555-0001

In re: State-Protected Bird and Mammal Species Review

Three Mile Island Nuclear Station

License Renewal)Application

Londonderry Township, Dauphin County, PA

Dear Ms. Lund:

This is in response to your request of April 15, 2008 regarding information on state-listed,

proposed; .and candidate- species: of birds of. mammals,.: rec0g izedby the Pennsylvania Game

Commission (PGC), whiclh may be int the vicinity of the .Three.Mile Island Nudear Station (TMI).-

Our office review has determined that Prothonotary Warblers (Protonotaria citrea), Bald

Eagles (Hafiaeetus leucocephalus), Yellow-crowned Night Herons (A vccorc violIcea), and Black:

crowned Night Herons (Nycticorax nycticorax) have been documented nesting and foraging in

proximity to the Three Mile Island Nuclear Station. Peregrine Falcons (Falcoperegrinus) have been

documented nesting on the Unit I Reactor Building, and Ospreys (Pandion haliaetus) have been

documented nesting atop the weather: station at the TMI.

The renewal of the TMI Operating License in not, anticipated to cause any adverse impacts to

special concern species of birds and .mammals that may be in the vicinity of the transmission line

corridors associated the electric generating station. No adverse impacts to ospreys and peregrine

falcons are anticipated due to the license renewal since there has been ongoing coordination by the

AmerGen Energy Company, LLC with the PGC regarding Best Management Practices for the

endangered and threatened species nesting at TMI. This determination.may be reconsidered ifproject

plans change or extend beyond the present study area, or if additional information-becomeslavailable

on state-listed species-- . . .

S.. :.If you have unyr questions;, please contact me'at, (7-17)'787-4250: Preasebe advisdd that this

determination-is ohly valid for one year-ffrom the date of this letter:-...............

ADMINISTRAiVE BUREAUV.-

PERsoNNEL" 717-787-7836 ADMINISTRATION: 717-787-5670 AUTOMOTIVE AND PROCURMENTr 717-787-6594

LICENSE DMSION: 717-787-2084 WILDLIFE MAN4AGEMENTr. 717-787-5529 INFORMATION & EDUCATION: 717787.-6286

WILDLIFE PRO'EcTnoN: 717-787-5740 WILDUFE HABITAT MANAGEMENT- 717-787-6818 REAL ESTATE: 717-787-6568

AUToMATEDTECcHNOLOGY SYsIrIms: 717-787-4076

WWW.PGC.STATE.PA.LUS

NUREG-1437, Supplement 37 D-28 June 2009
Appendix.D

Zt

Ms. Louise Lund 2 May 14, 2008

Very truly yours,.

g James R. Leigey

Wildlife Impact Review Coordinator

Division of Environmental

Planning and Habitat Protection

Bureau of Wildlife Habitat Management

I Cc: File

June 2009 D-29 NUREG-1437, Supplement 37
Appendix D

Pennsylvania Fish & Boat Commission

I Division'fogfrironmen taletal-Servie

Natural Diversity Section

450 Robinson Lane

Bellefonte, PA 16823-9620

($14) 359-5237 Fax: (81.4) 359-5175

establhed 1866 June.3, 2008

IN REPLY REFER TO

SIR.# 28464

SARAH LOPAS

UNITED STATES NUCLEAR REGULATORY COMMISSION

11555 ROCKVILLE PIKE

MAILSTOPO-11FI

ROCKVILLE, MD 20852

RE: Species Impact Review (SIR) - Rare, Candidate, Threatened and Endangered Species

THREE MILE ISLAND NUCLEAR STATION

LONDONDERRY Township/Borough, DAUPHIN County,Pennsylvania

This responds-to your inquiry about a Pennsylvania Natural Diversity Inventory (PNDI) Internet Database. search "potential

conflict" or a threatened and endangered.species impact review. These projects are screened for potential conflicts with

,rare, candidate, threatened or endangered species under Pennsylvania Fish & Boat Commission jurisdiction(fish, reptiles,

amphibians, aquatic invertebrates only) using the Pennsylvania Natural Diversity Inventory (PNDI) ditabase and our own

files.. These species of special concern are listed under the Endangered Species Act of 1973, the Wild Resource

Conservation.Act, and the Pennsylvania Fish &,Boat Code (Chapter 75), or the Wildlife Code. Theabsence ofrecorded

information from-ourtfiles does:not necessarily imply actual conditions on site.- Future field investigations could alter this

determination. -The information-contained in our fileskis.routinely updated. A Species Impact Review 'is valid for one year

only.

X NO ADVERSE IMPACTS EXPECTED FROM THE PROPOSED PROJECT

Except for occasional transient species, rare, candidate, threatened or endangered species under our

jurisdiction are not known to exist in the vicinity of the project area. Therefore, no biological assessment

or further consultation regarding rare-species is needed With the Commission. Should project plans

change, or if additional information-on listed orproposed species becomes available, this determination

may be reconsidered.

X An element occurrence of a rare, candidate, threatened: or endangered.species under ourjurisdiction is

known from the vicinity of the proposed project. However, given the' nature of the proposed project, 'the

immediate location, or the current status of the nearby element occurrence(s) no adverse impacts are

expected to the species of special concern.

If you have any questions regarding this review, please contact the biologist indicated below:

Jeff Sehmid 814-359-5236 • Tina Walther 814-359-5186

X Nevin Welte .814-359-5234 Bob Morgan . 814-359-5129.

I am enclosing a copy of our "SIR Request Form', which is to be used for all future species impact review irequests,. Please

make copies ofthe attached.form and use w)ith all future. project reviews. Thank you in advance for your cooperation and

attention-to this importgaP matter ofspecies conservation and habitat protection. . . .. 

'SIGNAT RE: U " DATE: June3, 2008 • . :~'.-. histopherk A, l ir' - Vv . •

Chief, Naturail Diversity Section

Our Mission: www.fish.state.pa.us

To protect, conserve and enhance the Commonwealth "s aquatic resources and provide fishing-and boating opportunities.

NUREG-1437, Supplement 37 D-30 June 2009
Appendix D

NIRI

0United States Department of the Interior

OFFICE OF THE SECRETARY

Office of Environmental Policy and Compliance

Custom House, Room 244 INAMER.Pio

200 Chestnut Street

ý.Y FEFER TO: Philadelphia, Pennsylvania 19106-2904

March 3, 2009.

ER08/1285

Chief Rulemaking, Directives Editing Branch

U.S. NRC

Mail Stop T6-D59

Washington, D.C. 20555-0001

RE: Draft Generic Environmental Impact Statement, NUREG-1437, Supplement 37, for

the License Renewal of Three Mile Island Nuclear Station, Unit 1; Dauphin County,

Pennsylvania.

Dear Sir / Madame:

The Department of the Interior (Department) has reviewed the above-referenced Notice, dated

December 9, 2008, regarding Three Mile Island Nuclear Station located in Londonderry

Township, Dauphin County, Pennsylvania. AmerGen, LLC, proposes to renew its license to

operate a nuclear power project at the existing Three Mile Island Nuclear Station.

The following comments are provided pursuant to the Endangered Species Act of 1973 (87 Stat.

884, as amended; 16 U.S.C., 1531 etseq.) to ensure the protection of federally listed endangered

and threatened species, and the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16

U.S.C. 661 etseq.) to ensure protection of other fish and wildlife resources.

FEDERALLY LISTED SPECIES

Except for occasional transient species, no federally listed or proposed, threatened or endangered

species under our jurisdiction are known to occur within the project impact area. Therefore,

based on currently available information, no biological assessment or further consultation under

the Endangered Species Act is required with the Fish and Wildlife Service. Should project plans

change, or if additional information on listed or proposed species becomes available, this

determination may be reconsidered.

BALD EAGLE

Bald eagles are known to occur in the vicinity of the Three Mile Island facility. Although the

bald eagle has been removed from the federal List of Endangered and Threatened Wildlife, and is

therefore no longer protected under the Endangered Species Act, it continues to be protected

under the Bald and Golden Eagle Protection Act (Eagle Act) and the Migratory Bird Treaty Act

(MBTA). Both acts protect bald eagles by prohibiting killing, selling or otherwise harming

June 2009 D-31 NUREG-1437, Supplement 37
Appendix D

eagles, their nests or eggs. The Eagle Act also protects eagles from disturbance. "Disturb"

means to agitate or bother a bald or golden eagle to a degree that causes, or is likely to cause,

based on the best scientific information available, 1) injury to an eagle; 2) a decrease in its

productivity, by substantially interfering with normal breeding, feeding, or sheltering behavior,

or 3) nest abandonment, by substantially interfering with normal breeding, feeding, or sheltering

behavior.

On June 4, 2007, the Service released several important documents related to the protection of

bald eagles under the Eagle Act, including 1) a final rule establishing a regulatory definition of

"disturb"; 2) a final environmental assessment of the "disturb" regulation; 3)National BaldEagle

Management Guidelines; and 4) a proposed rule to establish a permit for the take of bald and

golden eagles. The proposed rule would establish regulations for issuing permits to take bald

and golden eagles where the take is associated with, and not the purpose of, otherwise lawful

activities. A second permit type would provide for permits to take bald and golden eagle nests

for safety emergencies (of humans or eagles). All of these documents can be found at

http:/iAww.fws. Rov/mi gratorvbirds/baldeagle.htm.

A bald eagle nest is located approximately three miles northwest from the Three Mile Island

facility. In addition, bald eagles are continuing to expand their breeding range along the

Susquehanna River, and therefore may be found in previously undocumented locations near the

facility. Consequently, we recommend that the applicant carefully evaluate the project type,

size, location and layout in light of the National BaldEagle Management Guidelines to

determine whether or not bald eagles might be disturbed as a direct or indirect result of this

project. Ifit appears that disturbance may occur, we recommend that the applicant consider

modifying the project to be consistent with the Guidelines. If the applicant has questions about

when and how to obtain a permit because he or she believes that the proposed project will disturb

bald eagles, and he or she is not able to implement measures to avoid disturbance, please contact

the Fish and Wildlife Service Migratory Bird Permit Program at 413-253-8643 or

permitsr5mbafws. Rov.

Lastly, the applicant should incorporate state-of-the art methods to prevent raptor electrocution

and collisions (see Suggested Practices for Avian Protection on PowerLines: the State of the Art

in 2006, available from the Avian Power Line Interaction Committee at http:i/www.aplic.org).

Siting new power lines as far as possible from known eagle nests would help reduce the

electrocution/collision risk, as would equipping existing or new lines with features that would

prevent raptor electrocution and collisions.

SPECIFIC COMMENTS

Section 2.2.7 Threatened and Endangered Species and Section 4.7 Threatened or

Endangered Species. The DEIS (pages 4-8 and 4-9) indicates that the osprey (Pandion

haliaetus) is one of the eleven State-listed threatened or endangered species that have been

determined to be species of special concern for the TMI-1 site of the license renewal project

The DEIS (pages 4-8 and 4-9) states that mitigation measures for the osprey (and.other species)

currently in place at the TMI- 1 site include nest construction and placement, and that "these

current mitigation measures are found to be adequate." However, in a previous section, the

DEIS contradicts this conclusion, claiming (page 2-40) that nesting relocation efforts by the

State-listed, threatened osprey (Pandion haliaetus) have been unsuccessful, citing AmerGen

2

NUREG-1437, Supplement 37 D-32 June 2009
Appendix .D

(2008) as the reference. It would benefit the public for the final EIS to include more specific

information as to why such relocation efforts may not be successful, and include the results of

scientific studies on such efforts, such as the undated US Geological Survey (USGS) citation

which indicates that "ospreys typically pair for life and use the same nest site in successive

years." The USGS reference also includes other relevant information and cites several additional

references that may be useful in the analyses and evaluation of proposed mitigation measures to

be included in the final EIS, such as studies which indicate that "Colonies [of ospreys] may arise

in secure areas such as islands or lakes, but most pairs tend to be solitary nesters, separated from

other nests by tens to hundreds of kilometers (McVey et al., 1993)." Available scientific

information regarding nesting relocation measures would be important considerations for

identifying appropriate mitigation measures and measuring the severity of the impact from the

proposed project

Table 2-6, pages 2-41 through 2-49. The correct designation inthe footnote on page 2-49 for a

State-listed threatened species should be "PT" and not "ST" as currently listed.

Section 2.4 References, page 2-76. The link to the U.S. Fish and Wildlife Service (2008a)

citation (for ospreys) is not correct. The correct link should read as follows:

http://www.fws.gov/chesapeakebay/osprey.html.

Conclusions

The applicant should be directed to clarify or gather additional information on the questions

identified above. This may entail conducting appropriate field studies to obtain site-specific

information. We also ask that the Commission continue to coordinate with the Fish and Wildlife

Service throughout the license renewal process.

Thank you for the opportunity to review and comment on this Draft Environmental Impact

Statement. If you have any questions regarding this matter, please contact Lloyd Woosley of the

USGS Environmental Affairs Program at (703) 350-8797, or Jennifer Kagel of the U. S. Fish and

Wildlife Service's Pennsylvania Field Office at 814-234-4090.

Sincerely,

Michael T. Chezik

Regional Environmental Officer

3

June 2009 D-33 NUREG-1437, Supplement 37

Appendix E

Chronology of Environmental Review

E. Chronology of Environmental Review Correspondence

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

Regulatory Commission (NRC) and external parties as part of its environmental review for

Three Mile Island Nuclear Station, Unit 1. All documents, with the exception of those containing

proprietary information are available electronically from the NRC's Public Electronic Reading

Room found on the Internet at the following Web address: http://www.nrc.gov/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 ADAMS. The ADAMS accession number for each document is included below.

E.1 Environmental Review Correspondence

January 8, 2008

January 25, 2008

January 28, 2008

January 31, 2008

February 14, 2008

February 26, 2008

March 10, 2008

Letter from AmerGen forwarding the application for renewal of

operating license for Three Mile Island, Unit 1, requesting an

extension of operating license for an additional 20 years (ADAMS

Accession No. ML080220219).

Letter to AmerGen, "Receipt and Availability of the License Renewal

Application for the Three Mile Island Nuclear Station, Unit 1" (ADAMS

Accession No. ML073310128).

NRC press release announcing the availability of the license renewal

application for Three Mile Island, Unit 1, for public inspection (ADAMS

Accession No. ML080280293).

Federal Register notice, "AmerGen Energy Company, LLC; Notice of

Receipt and Availability of Application for Renewal of Three Mile

Island Nuclear Station, Unit 1, Facility Operating License No. DPR-50

for an Additional 20-Year Period" (73 FR 5877).

Notice of public meeting to discuss the license renewal process for

the Three Mile Island Nuclear Station, Unit 1, license renewal

application Review (ADAMS Accession No. ML080380505).

NRC press release announcing the public meeting to discuss the

review of the license renewal application for Three Mile Island Nuclear

Power Plant (ADAMS Accession No. ML080570365).

Letter to AmerGen transmitting "Determination of Acceptability and

Sufficiency for Docketing, Proposed Review Schedule, and

Opportunity for a Hearing Regarding an Application from AmerGen

Energy Company, LLC, for Renewal of the Operating License for

June 2009 E-1 NUREG-1 437, Supplement 37
Appendix E

March 10, 2008

March 14, 2008

March 21, 2008

March 24, 2008

March 26, 2008

March 28, 2008

March 31, 2008

March 31, 2008

April 1, 2008

April 3, 2008

Three Mile Island Nuclear Station, Unit 1" (ADAMS Accession

No. ML080370352).

NRC press release announcing opportunity to request hearing on

license renewal application for Three Mile Island Nuclear Plant

(ADAMS Accession No. ML080700892).

Federal Register notice, "Notice of Acceptance for Docketing of the

Application and Notice of Opportunity for Hearing; Regarding Renewal

of Facility Operating License No. DPR-50 for an Additional 20-Year

Period; AmerGen Energy Company, LLC Three Mile Island Nuclear

Station, Unit 1" (73 FR 13923).

Letter to AmerGen, "Three Mile Island Nuclear Station, Unit 1 License

Renewal Application Online Reference Portal" (ADAMS Accession

No. ML080710465).

Letter to AmerGen forwarding Federal Register notice, "Three Mile

Island Nuclear Station, Unit 1; Notice of Intent to Prepare and

Environmental Impact Statement and Conduct Scoping," in support of

the review of the license renewal application (ADAMS Accession

No. ML080780085).

Notice of public meeting to discuss the environmental scoping

process for the Three Mile Island Nuclear Station, Unit 1, license

renewal application review (ADAMS Accession No. ML080800502).

Federal Register notice, "Three Mile Island Nuclear Station, Unit 1;

Notice of Intent to Prepare an Environmental Impact Statement and

Conduct Scoping Process" (73 FR 16729).

Letter from AmerGen, "Editorial Corrections to the Three Mile Nuclear

Station Unit 1 License Renewal Application Environmental Report"

(ADAMS Accession No. ML080930302).

Letter from AmerGen, "Three Mile Island Nuclear Station Unit 1

License Renewal Application Online Reference Portal" (ADAMS

Accession No. ML080930301).

Letter to AmerGen, "Environmental Site Audit Regarding Three Mile

Island Nuclear Station, Unit 1, License Renewal Application" (ADAMS

Accession No. ML080840029).

Letter from AmerGen, "Three Mile Island Nuclear Station Unit 1

License Renewal Application Selected Environmental Report

References" (ADAMS Accession No. ML081420193).

NUREG-1437, Supplement 37 E-2 June 2009
Appendix E

April 4, 2008

April 9, 2008

April 9, 2008

April 9, 2008

April 9, 2008

April 9, 2008

April 9, 2008

April 9, 2008

April 9, 2008

June 2009

Letter to David Densmore, U.S. Fish and Wildlife Service, request for

list of protected species for the Three Mile Island Nuclear Station,

Unit 1, license renewal review (ADAMS Accession No.

ML080840027).

Letter to The Honorable Raymond Halbritter, Nation Representative,

Oneida Indian Nation, inviting participation in scoping process related

to NRC's environmental review of the license renewal application for

Three Mile Island Nuclear Station, Unit 1 (ADAMS Accession

No. ML080980572).

Letter to The Honorable Paul Spicer, Chief, Seneca-Cayuga Tribe of

Oklahoma, inviting participation in scoping process related to NRC's

environmental review of the license renewal application for Three Mile

Island Nuclear Station, Unit 1 (ADAMS Accession No. ML080980572).

Letter to The Honorable Barry Snyder, Sr., President, Seneca Nation

of Indians, inviting participation in scoping process related to NRC's

environmental review of the license renewal application for Three Mile

Island Nuclear Station, Unit 1 (ADAMS Accession No. ML080980572).

Letter to The Honorable Robert Chicks, Tribal Chairman, StockbridgeMunsee Band of the Mohican Nation, Wisconsin, inviting participation

in scoping process related to NRC's environmental review of the

license renewal application for Three Mile Island Nuclear Station,

Unit 1 (ADAMS Accession No. ML080980572).

Letter to The Honorable Tony Gonyea, Faithkeeper, Onondaga

Nation, inviting participation in scoping process related to NRC's

environmental review of the license renewal application for Three Mile

Island Nuclear Station, Unit 1 (ADAMS Accession No. ML080980572).

Letter to The Honorable Gerald Dansforth, Chairwoman, Oneida

Nation of Wisconsin, inviting participation in scoping process related

to NRC's environmental review of the license renewal application for

Three Mile Island Nuclear Station, Unit 1 (ADAMS Accession

No. ML080980572).

Letter to The Honorable Glenna Wallace, Chief, Eastern Shawnee

Tribe of Oklahoma, inviting participation in scoping process related to

NRC's environmental review of the license renewal application for

Three Mile Island Nuclear Station, Unit 1 (ADAMS Accession

No. ML080980572).

Letter to The Honorable Kerry Holton, Tribal President, Delaware

Nation, inviting participation in scoping process related to NRC's

E-3 NUREG-1437, Supplement 37
Appendix E

April 9, 2008

April 9, 2008

April 9, 2008

April 9, 2008

April 9, 2008

April 9, 2008

April 15, 2008

April 15, 2008

environmental review of the license renewal application for Three Mile

Island Nuclear Station, Unit 1 (ADAMS Accession No. ML080980572).

Letter to The Honorable Clint Halftown, Heron Clan Representative,

Cayuga Nation, inviting participation in scoping process related to

NRC's environmental review of the license renewal application for

Three Mile Island Nuclear Station, Unit 1 (ADAMS Accession

No. ML080980572).

Letter to The Honorable Scott Miller, Governor, Absentee-Shawnee

Tribe of Oklahoma, inviting participation in scoping process related to

NRC's environmental review of the license renewal application for

Three Mile Island Nuclear Station, Unit 1 (ADAMS Accession

No. ML080980572).

Letter to The Honorable James Ransom, Chief, St. Regis Mohawk

Tribe, inviting participation in scoping process related to NRC's

environmental review of the license renewal application for Three Mile

Island Nuclear Station, Unit 1 (ADAMS Accession No. ML080980572).

Letter to The Honorable Roger Hill, Chief, Tonawanda Seneca Nation,

inviting participation in scoping process related to NRC's

environmental review of the license renewal application for Three Mile

Island Nuclear Station, Unit 1 (ADAMS Accession No. ML080980572).

Letter to The Honorable Leo Henry, Chief, Tuscarora Nation, inviting

participation in scoping process related to NRC's environmental

review of the license renewal application-for Three Mile Island Nuclear

Station, Unit 1 (ADAMS Accession No. ML080980572).

Letter to The Honorable Ron Sparkmann, Chairman, Shawnee Tribe,

inviting participation in scoping process related to NRC's

environmental review of the license renewal application for Three Mile

Island Nuclear Station, Unit 1 (ADAMS Accession No. ML080980572).

Letter to Charlene Dwin Vaughn, Assistant Director, Advisory Council

on Historic Preservation, regarding Three Mile Island Nuclear Station,

Unit 1 license renewal review (ADAMS Accession No. ML080930296).

Letter to Rich Janati, Chief, Division of Nuclear Safety, Bureau of

Radiation Protection, Pennsylvania Department of Environmental

Protection, regarding Three Mile Island Nuclear Station, Unit 1,

license renewal (ADAMS Accession No. ML080860022).

NUREG-1437, Supplement 37 E-4 June 2009
Appendix E

April 15, 2008

April 15, 2008

April 15, 2008

April 15, 2008

April 15, 2008

April 15, 2008

April 15, 2008

April 21, 2008

April 23, 2008

.Letter to Rachel Diamond, Regional Director, Pennsylvania

Department of Environmental Protection Southcentral Regional Office,

regarding Three Mile Island Nuclear Station, Unit 1, license renewal

review (ADAMS Accession No. ML080930617).

Letter to Michael G. Brownell, Chief, Water Resources Management,

Susquehanna River Basin Commission, regarding Three Mile Island

Nuclear Station, Unit 1, license renewal review (ADAMS Accession

No. ML080930632).

Letter to Chris Firestone, Native Plant Program Manager,

Pennsylvania Department of Conservation and Natural Resources,

request for list of protected species and important habitats for the

Three Mile Island Nuclear Station, Unit 1, license renewal review

(ADAMS Accession No. ML080930247).

Letter to Christopher Urban, Chief of Natural Diversity Section,

Pennsylvania Fish & Boat Commission, request for list of Stateprotected species for the Three Mile Island Nuclear Station, Unit 1,

license renewal review (ADAMS Accession No. ML080930486).

Letter to James Leigey, Wildlife Impact Review Coordinator,

Pennsylvania Game Commission, request for list of State-protected

species for the Three Mile Island Nuclear Station, Unit 1, license

renewal review (ADAMS Accession No. ML080930178).

Letter to Jean Cutler, Deputy State Historic Preservation Officer,

Pennsylvania Historic and Museum Commission, regarding Three

Mile Island Nuclear Station, Unit 1, license renewal review (ADAMS

Accession No. ML080930380).

NRC press release announcing the Three Mile Island, Unit 1, license

renewal environment scoping meeting (ADAMS Accession

No. ML081060426).

Letter from Sherry White, Tribal Historic Preservation Officer,

Stockbridge-Munsee Tribal Historic Preservation Office, regarding

Three Mile Island Nuclear Station, Unit 1, license renewal review

(ADAMS Accession No. ML081280309).

Letter from David Densmore, Supervisor, U.S. Fish and Wildlife

Service, Pennsylvania Field Office, regarding Three Mile Island

Nuclear Station, Unit 1, license renewal application review (ADAMS

Accession No. ML081280307).

June 2009 E-5 NUREG-1437, Supplement 37
Appendix E

April 23, 2008

May 2, 2008

May14, 2008

May21, 2008

May 22, 2008

June 3, 2008

June 3, 2008

June 10, 2008

June 12, 2008

July 17, 2008

Letter from Rebecca H. Bowen, Environmental Review Specialist,

Pennsylvania Department of Conservation and Natural Resources,

regarding Three Mile Island, Unit 1, license renewal species of special

concern (ADAMS No. Accession ML081300048).

Summary of public meetings related to the license renewal process

for the Three Mile Island Nuclear Station, Unit 1, license renewal

application (ADAMS Accession No. ML081000290).

Letter from James R. Leigey, Wildlife Impact Review Coordinator,

Pennsylvania Game Commission, regarding State-protected bird and

mammal species review for Three Mile Island Nuclear Station license

renewal application, Londonderry Township, Dauphin County,

Pennsylvania (ADAMS Accession No. ML081500671).

Letter to AmerGen, "Request for Additional Information Regarding

Severe Accident Mitigation Alternatives for Three Mile Island Nuclear

Station, Unit 1, License Renewal" (ADAMS Accession

No. ML081330714).

Summary of public environmental scoping meetings related to the

review of the Three Mile Island Nuclear Station, Unit 1, license

renewal application (ADAMS Accession No. ML081360648).

Letter from Christopher A. Urban, Chief, Natural Diversity Section,

Pennsylvania Fish & Boat Commission, regarding species impact

review for Three Mile Island Nuclear Station, Londonderry

Township/Borough, Dauphin County, Pennsylvania (ADAMS

Accession No. ML081610104).

Commission order denying Mr. Marvin Lewis's Petition to Intervene

(ADAMS Accession No. ML081550359).

Letter from AmerGen, "Three Mile Island Nuclear Station Unit 1

License Renewal Application Post-Audit Environmental Information"

(ADAMS Accession No. ML082110260).

Summary-of conference call with AmerGen to discuss the severe

accident mitigation alternatives and requests for additional information

for Three Mile Island Nuclear Station, Unit 1 (ADAMS Accession

No. ML081560666).

Letter from AmerGen, "Response to NRC Request for Additional

Information related to the Three Mile Island Nuclear Station Unit 1

License Renewal Application" (ADAMS Accession No.

ML082040144).

NUREG-1437, Supplement 37 E-6 June 2009
Appendix E

August 4, 2008

August 5, 2008

August 5, 2008

August 8, 2008

September 8, 2008

December 3, 2008

December 3, 2008

December 3, 2008

Summary of site audit related to the review of the license renewal

application for Three Mile Island Nuclear Station, Unit 1 (ADAMS

Accession No. ML081420398).

Summary of telephone conference call held on July 17, 2008,

between the NRC and AmerGen, concerning followup questions

pertaining to the Three Mile Island Nuclear Station, Unit 1, license

renewal environmental review and site audit (ADAMS Accession

No. ML082120727).

Letter from AmerGen, "Three Mile Island Nuclear Station Unit 1

License Renewal Application Post-Audit Environmental Information"

(ADAMS Accession No. ML082200589).

Letter to AmerGen regarding environmental scoping summary report

associated with the staffs review of the application by AmerGen for

renewal of the operating license for Three Mile Island Nuclear Station,

Unit 1 (ADAMS Accession No. ML081920230).

Summary of conference call with AmerGen Energy Company, LLC, to

discuss responses to severe accident mitigation alternatives request

for additional information for Three Mile Island Nuclear Station, Unit 1

(ADAMS Accession No. ML082340226).

Letter to AmerGen, "Notice of Availability of the Draft Plant-Specific

Supplement 37 to the Generic Environmental Impact Statement for

License Renewal of Nuclear Plants (GELS) Regarding Three Mile

Island Nuclear Station, Unit 1" (ADAMS Accession No.

ML083100818).

Letter to U.S. Environmental Protection Agency, Office of Federal

Activities, NEPA Compliance Division, regarding Notice of Availability

of the draft plant-specific Supplement 37 to the Generic

Environmental Impact Statement for License Renewal of Nuclear

Plants Regarding Three Mile Island Nuclear Station, Unit 1" (ADAMS

Accession No. ML083110491).

Letter to Doug McLearen, Chief, Division of Achaeology and

Protection, Pennsylvania Historical and Museum Commission,

regarding Notice of Availability of the draft plant-specific Supplement

37 to the Generic Environmental Impact Statement for License

Renewal of Nuclear Plants Regarding Three Mile Island Nuclear

Station, Unit 1" (ADAMS Accession No. ML083100943).

June 2009 E-7 NUREG-1437, Supplement 37
Appendix E

December 9, 2008

December 10, 2008

Decemeber 19, 2008

December 23, 2008

January 6, 2009

January 21, 2009

January 26, 2009

January 28, 2009

February 4, 2009

February 9, 2009

Federal Register notice, "Notice of Availability of the Draft Supplement

37 to the Generic Environmental Impact Statement for License

Renewal of Nuclear Plants, and Public Meeting for the License

Renewal of Three Mile island Nuclear Station, Unit 1" (73 FR 74766).

Notice of public meeting to discuss the draft supplemental

environmental impact statement regarding Three Mile Island Nuclear

Station, Unit 1 (ADAMS Accession No. ML083290436).

NRC press release announcing availability of draft supplemental

environmental impact statement regarding Three Mile Island, Unit 1

(ADAMS Accession No. ML083540649).

Letter to AmerGen, "Correction to December 9, 2008 Federal Register

Notice for Three Mile Island Nuclear Station, Unit 1 License Renewal"

(ADAMS Accession No. ML083470302).

Correction to Federal Register notice, "Notice of Availability of the

Draft Supplement 37 to the Generic Environmental Impact Statement

for License Renewal of Nuclear Plants, and Public Meeting for the

License Renewal of Three Mile island Nuclear Station, Unit 1" (74 FR

470).

NRC press release announcing public meetings to discuss draft

supplemental environmental impact statement regarding Three Mile

Island Nuclear Station, Unit 1 (ADAMS Accession No.

ML090210126).

Letter from Exelon Generation, "Future Correspondence Concerning

the License Renewal Application of Three Mile Island, Unit 1, and a

Revision to the License Renewal Commitment List" (ADAMS

Accession No. ML090280368).

NRC press release regarding cancellation of public meetings to

discuss draft supplemental environmental impact statement regarding

Three Mile. Island Nuclear Station, Unit 1 (ADAMS Accession No.

MIL090280117).

Notice of rescheduled public meeting to discuss the draft

supplemental environmental impact statement regarding Three Mile

Island Nuclear Station, Unit I (ADAMS Accession No.

ML090340443).

Letter to Exelon Generation, "Date and Location Correction to

December 9, 2008 Federal Register Notice for Three Mile Island

NUREG-1437, Supplement 37 E-8 June 2009
Appendix E

February 17, 2009

February 18, 2009

February 27, 2009

March 3, 2009

March 4, 2009

March 9, 2009.

March 25, 2009

March 30, 2009

May 15, 2009

Nuclear Station, Unit 1 License Renewal" (ADAMS Accession No.

ML090350448).

Correction to Federal Register Notice, "Notice of Availability of the

Draft Supplement 37 to the Generic Environmental Impact Statement

for License Renewal of Nuclear Plants, and Public Meeting for the

License Renewal of Three Mile Island Nuclear Station, Unit 1 (74 FR

7488).

NRC press release announcing rescheduled public meetings to

discuss draft supplemental environmental impact statement regarding

Three Mile Island Nuclear Station, Unit 1 (ADAMS Accession No.

ML090490459).

Letter from Exelon Corporation, "Comments on NUREG-1437,

Supplement 37 draft" (ADAMS Accession No. ML090680038).

Letter from Michael T. Chezik, Regional Environmental Officer, United

States Department the Interior, "Draft Generic Environmental Impact

Statement, NUREG-1,437, Supplement 37, for the License Renewal of

Three Mile Island Nuclear Station, Unit1; Dauphin County,

Pennsylvania" (ADAMS Accession No. MIL090840544).

Letter from Kevin Magerr, Environmental Engineer, U.S.

Environmental Protection Agency, "Generic Draft Environmental

Impact Statement for License Renewal of Nuclear Plants Supplement

37 Regarding Three Mile Island Nuclear Station, Unit 1 December

2008 CEQ #20080503" (ADAMS Accession No. ML090750180).

Summary of public meetings on the draft supplemental environmental

impact statement regarding Three Mile Island Nuclear Station, Unit 1

License Renewal Review (ADAMS Accession No. ML090620419).

Letter from Exelon Generation, "Three Mile Island Nuclear Station

Unit 1 License Renewal Updated Environmental Information" (ADAMS

Accession No. ML090890364).

Letter from Exelon Generation, "Three Mile Island Nuclear Station

Unit 1 License Renewal Updated Environmental Information" (ADAMS

Accession No. ML090910407).

Letter from Exelon Generation, "Three Mile Island Nuclear Station

Unit 1 License Renewal Application Supplemental Updated

Environmental Information." (ADAMS Accession No.: ML091390217).

June 2009 E-9 NUREG-1437, Supplement 37

Appendix F

U.S. Nuclear Regulatory Commission Staff Evaluation of

Severe Accident Mitigation Alternatives (SAMAs) for

Three Mile Island Nuclear Station, Unit 1

In Support of License Renewal Application Review

F. U.S. Nuclear Regulatory Commission Staff Evaluation of Severe

Accident Mitigation Alternatives (SAMAs) for Three Mile Island

Nuclear Station, Unit 1 in Support of License Renewal Application

Review

F.1 Introduction

Exelon Generation Company, LLC (Exelon Generation) submitted an assessment of severe

accident mitigation alternatives (SAMAs) for the Three Mile Island Nuclear Station, Unit 1 (TMI1) as part of the environmental report (ER) (AmerGen 2008a). This assessment was based on

the most recent TMI-1 probabilistic risk assessment (PRA) available at that time, a plant-specific

offsite consequence analysis performed using the MELCOR Accident Consequence Code

System 2 (MACCS2) computer code (NRC 1998a), and insights from the TMI-1 individual plant

examination (IPE) (GPU 1993) and individual plant examination of external events (IPEEE)

(GPU 1994). In identifying and evaluating potential SAMAs, Exelon Generation considered

SAMA candidates that addressed the major contributors to core damage frequency (CDF) and

population dose at TMI-1, as well as SAMA candidates for other operating plants which have

submitted license renewal applications. Exelon Generation identified 33 potential SAMA

candidates. Exelon Generation assessed the costs and benefits associated with each of the

potential SAMAs, and concluded in the ER that several of the candidate SAMAs evaluated are

potentially cost-beneficial.

Based on a review of the SAMA assessment, the U.S. Nuclear Regulatory Commission (NRC)

issued a request for additional information (RAI) to Exelon Generation by letter dated May 21,

2008 (NRC 2008a). Key questions concerned: major plant and modeling changes incorporated

within each evolution of the PRA model; justification for the multiplier used for external events;

assumptions used to quantify the benefits for certain SAMAs; identification of an optimal subset

of potentially cost-beneficial SAMAs; and further information on several specific candidate

SAMAs and low cost alternatives. Exelon Generation submitted additional information by letters

dated July 17, 2008 (AmerGen 2008b) and September 8, 2008 (NRC 2008b). In the responses,

Exelon Generation provided: additional information regarding the PRA model development;

additional justification for the treatment of external events; additional explanation and

justification for the assumptions used to quantify SAMA benefits; a qualitative assessment

identifying the potentially cost-beneficial SAMAs having the greatest risk reduction relative to the

cost of implementation; and additional information regarding several specific SAMAs. Exelon

Generation's responses addressed the NRC staff's concerns, and resulted in the identification

of two additional potentially cost-beneficial SAMAs.

An assessment of SAMAs for TMI-1 is presented below.

F.2 Estimate of Risk for TMI-1

Exelon Generation's estimates of offsite risk at TMI-1 are summarized in Section F.2.1. The

summary is followed by the NRC staff s review of Exelon Generation's risk estimates in Section

F.2.2.

NUREG-1437 F-1 June 2009
Appendix F

F.2.1 Exelon Generation's Risk Estimates

Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA

analysis: (1) the TMI-1 Level 1 and 2 analyses, which are represented by the current Level 1

(Exelon 2007a) and Level 2 (Exelon 2007b) internal events PRA and the~original IPEEE (GPU

1994), and (2) a supplemental analysis of offsite consequences and economic impacts

(essentially a Level 3 PRA) developed specifically for the SAMA analysis. The SAMA analysis is

based on the most recent TMI-1 Level 1 and 2 PRA model available at the time of the ER,

referred to as the 2004 Revision 2 Level 1 model (Exelon 2007a), and the Level 2 model of

2007 (Exelon 2007b). The scope of the Level 1 model includes both internal and external

initiating events. The external events evaluated include external floods, seismic events, and

internal fires. However, the external events models are not integrated with the internal events

model, thereby necessitating a separate assessment of the risk (and risk reduction) for internal

and external events. Exelon Generation placed particular emphasis on external flooding events

since they dominate the calculated risk at TMI-1.

The baseline CDF for the purpose of the SAMA evaluation is approximately 2.37 x 10-5 per year

for internal events (including internal flooding events), and 8.11 x 10-5 per year for external

I flooding events. Exelon Generation accounted for the potential risk reduction benefits

associated with internal event-and external flooding-related SAMAs by separately quantifying

the benefits using the internal event or external flooding model, respectively. For internal eventI related SAMAs, Exelon Generation accounted for the potential risk reduction benefits

associated with non-flooding external events (i.e., seismic and fire events) by doubling the

estimated benefits for internal events. For seismic- and fire-related SAMAs, Exelon Generation

separately estimated the risk reduction benefits using the seismic and fire risk models. This is

discussed further in Sections F.2.2 and F.6.2.

The breakdown of CDF by initiating event is provided in Tables F-1 a and F-I b for internal

events and external flooding events, respectively. As shown in these tables, internal event CDF

is dominated by loss of offsite power events, transients, small loss of coolant accidents (LOCA),

and loss of nuclear service water events. External flooding CDF is dominated by events with

flood levels exceeding 310 feet mean sea level (msl).

The Level 2 PRA model that forms the basis for the SAMA evaluation represents an updated

version of the original IPE Level 2 model. The Level 1 core damage sequences are binned into

Plant Damage State bins which provide the interface between the Level 1 and Level 2 models.

The Level 2 model utilizes a single containment event tree (CET) containing both

phenomenological and systemic events. CET nodes are evaluated using supporting fault trees

and logic rules.

NUREG-1437, Supplement 37 F-2 June 2009
Appendix F

Table F-l.a TMI-1 Internal Events Core Damage Frequency

Initiating Event (Per CDF%Year) Contribution

to CDF

Loss of Offsite Power 7.73 x 10-6 32.6

Transients 5.80 x 10-6 24.5

Small and Very Small LOCA 4.66 x 10-6 19.7

Loss of Nuclear River Water 3.67 x 10-6 15.5

Steam Generator Tube Rupture 9.93 x 10-7 4.2

Internal Floods 4.50 x 10"4 1.9

Large and Medium LOCA 2.06 x 10-7 < 1

ISLOCA 1.80 x 10-7 <1

Total CDF (internal events) 2.37 x 10-5 100

Table F-l.b TMI-1 External Flooding Events Core Damage

Frequency

External Flooding Event (Per CDF%Year) Contribution

to CDF

>310 feet 6.37 x 10-5 78.5

305 to 310 feet 1.71 x 10-5 21.1

<305 feet 2.50 x 107 < 1

Total 8.11 x 10.5 100

The result of the internal events Level 2 model is a set of 39 release categories with their

respective frequency and release characteristics. The release categories and their frequencies

are presented in Table E.2-16 of the ER. The categories were defined based on the timing,

duration, and magnitude of the release and whether the containment remains intact or is

bypassed. The frequency of each release category was obtained by summing the frequency of

the individual CET end states assigned to each release category. The 39 release categories

were further collapsed into nine major source term groups having similar containment response.

The nine major source term groups and their release characteristics are presented in Tables

E.2-17 and E.2-18 of the ER. The release characteristics for these nine source term groups

were developed from Modular Accident Analysis Program (MAAP) analyses performed

specifically to support the SAMA analysis (AmerGen 2008b).

June 2009 F-3 NUREG-1437, Supplement 37
Appendix F

For external flooding events, a simplified version of the internal events CET was developed and

used to map external flood sequences to representative release categories from the internal

events analysis. The result of the analysis is a set of eight release categories with their

respective frequencies. These release categories were subsequently collapsed into seven nonzero source term groups. The mapping of external flood sequences to source term group is

presented in Tables E.2-21 and E.2-23 of the ER.

The offsite consequences and economic impact analyses use the MACCS2 code to determine

the offsite risk impacts on the surrounding environment and public. Inputs for these analyses

include plant-specific and site-specific input values for core radionuclide inventory, source term

and release characteristics, site meteorological data, projected population distribution (within an

50-mile (mi) (80-kilometer [km]) radius for the year 2034, emergency response evacuation

modeling, and economic data. The magnitude of the onsite impacts (in terms of clean-up and

decontamination costs and occupational dose) is based on information provided in NUREG/BR0184 (NRC 1997a).

Exelon Generation estimated the dose to the population within 50 mi (80 km) of the TMI-1 site to

be approximately 0.323 person-sievert (Sv) (32.3 person-rem) per year (AmerGen 2008a) for

internal events and 1.76 person-Sv (176 person-rem) per year for external flooding events

(AmerGen 2008b). The breakdown of the total population dose by containment release mode is

summarized in Table F-2. Steam generator tube rupture (SGTR) accidents, and basemat meltthrough are the dominant contributors to population dose risk from internal events. For external

flooding events, late containment failures and early containment failure (less than 12 hours

following accident initiation) are the dominant contributors to population dose risk.

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

Internal Events External Flooding Events

Population Population

Dose % Dose %

Containment Release Mode (Person- Contribution (Person- Contribution

Rem Per Rem Per

Year) Year) .

Steam generator tube rupture 11.7 36 0.1 <0.1

Interfacing system LOCA 1.0 3 negligible 0

Containment isolation failure 1.1 3 29 16

Early containment failure 5.6 17 61 35

Late containment failure (large) 0.3 1 15 9

Late containment failure (small) 1.7 5 66 37

Basemat melt-through 6.9 22 4 2

No containment failure 4.0 13 1 1

Total 32.3 100 176 100

(a) One person-rem = 0.01 person-Sv

NUREG-1437, Supplement 37 F-4 June 2009
Appendix F

F.2.2 Review of Exelon Generation's Risk Estimates

Exelon Generation's determination of offsite risk at TMI-1 is based on the following major

elements of analysis:

" The Level 1 and 2 risk models that form the bases for the IPE submittal (GPU 1993) and

the IPEEE submittal (GPU 1994),

" The major modifications to the IPE model that have been incorporated in the 2004

Revision 2 Level 1 model (Exelon 2007a), and the Level 2 model of 2007 (Exelon

2007b)

* Assignment of severe accident source terms to external flooding sequences, and

0 The MACCS2 analyses performed to translate fission product source terms and release

frequencies from the Level 2 PRA model into offsite consequence measures.

Each of these analyses was reviewed to determine the acceptability of Exelon Generation's risk

estimates for the SAMA analysis, as summarized below.

The NRC staff's review of the TMI-1 IPE is described in an NRC report dated December 19,

1996 (NRC 1996). Based on a review of the IPE submittal and responses to RAIs, the NRC staff

concluded that the IPE submittal met the intent of GL 88-20 (NRC 1988); that is, the licensee's

IPE process is capable of identifying the most likely severe accidents and severe accident

vulnerabilities. Although no vulnerabilities were identified in the IPE, several improvements to

the plant or procedures were identified. These improvements have been either implemented at

the site or addressed in the SAMA evaluation process (AmerGen 2008a). These improvements

are discussed in Section F.3.2.

There have been six revisions to the Level 1 model since the 1992 IPE submittal. Exelon

Generation indicated that the 2004 Revision 2 Level 1 model reflects the TMI-1 configuration

and design as of the model's completion date of June 2007, but that no plant changes have

occurred since completion of the model that would impact the PRA. A comparison of internal

events CDF between the 1992 IPE and the current PRA model indicates a decrease of

approximately 43 percent (from 4.19 x 10-5 per year to 2.37 x 10-5 per year). A comparison of the

contributors to the total CDF indicates that some have increased (e.g., loss of offsite power)

while others have decreased (e.g., large and medium LOCA). A description of those changes

that resulted in the greatest impact on the internal events CDF was provided in Section E.2.2 of

the ER (AmerGen 2008a), and is summarized in Table F-3.

The CDF value from the 1992 IPE submittal (4.19 x 10-5 per year) is near the average of the

CDF values reported in the IPEs for B&W plants. Figure 11.6 of NUREG-1 560 shows that the

IPE-based total internal events CDF for these plants ranges from approximately 1 x 10-5 to

7 x 10.5 per year, with an average CDF for the group-of 3 x 10-5 per year (NRC 1997b). It is

recognized that other plants have updated the values for CDF subsequent to the IPE submittals

to reflect modeling and hardware changes. The current internal event CDF result for TMI-1 (2.37

x 10- per year, including internal flooding) is comparable to that for other plants of similar

vintage and characteristics.

June 2009 F-5 NUREG-1437, Supplement 37
Appendix F

Table F-3. TMI-1 PRA Historical Summary

PRA CDF Version Summary of Changes from Prior Model (re Version (per year)

1992 IPE Submittal (excluding internal flooding) 4.19 x 105

2000 August 2000 update (including internal flooding CDF of 3.0 x 10-)6 4.10 x 10-5

Update - Changed model from reliability block diagrams to fault tree structure

- Updated plant unavailability and failure rates

L2RV2 November 2001 update (including internal flooding CDF of 2.56 x 10') 3.95 x 10.5

- Linked Level 2 model directly with Level 1 sequences

ABSA July 2003 update (including internal flooding CDF of 3.5 x 107) 3.38 x 10-5

- Resolved Level A and B Facts and Observations (F&Os) from peer

certification

- Updated initiating event, component failure, unavailability, and common

cause databases

- Revised human reliability analysis (HRA) using the EPRI HRA

Calculator

- Updated success criteria and operator action timing based on thermalhydraulic (MAAP) analyses

- Refined internal flooding screening analysis

2004 Rev. 0 December 2004 update (including internal flooding CDF of 2.6 x 10-7) 3.09 x 10-5

- Converted model from RISKMAN linked event tree model to CAFTA

single event fault tree model

- Updated Main Feedwater and Main Steam system models related to

steam generator isolation for SGTR and secondary line breaks

- Updated 4KV/480V AC power system model to include individual fault

trees for 480V buses and motor control centers

- Updated common cause failure data to NUREG/CR-5497 (NRC 1998b)

- Added logic to evaluate system availability following offsite power

recovery

- Incorporated joint human error probability (JHEP) basic events

2004 Rev. 1 June 2005 update (including internal flooding CDF of 3.7 x 107) 3.36 x 10.5

- Corrected errors discovered subsequent to the conversion to CAFTA

2004 Rev. 2 June 2007 update (including internal'flooding CDF of 4.5 x 10-7) 2.37 x 10'

- Added new basic events for common cause failure of several

components

- Added new maintenance unavailability events to include maintenance

on various components

- Added human error probabilities (HEPs) for controlling emergency

feedwater, cooldown of the RCS, and steam generator isolation

- Revised loss of offsite power (LOOP) initiating event frequency

- Modified Very Small LOCAs event tree

NUREG-1437, Supplement 37 F-6 June 2009
Appendix F

The NRC staff considered the peer reviews performed for the TMI-1 PRA, and the potential

impact of the review findings on the SAMA evaluation. In the ER (AmerGen 2008a), Exelon

Generation described-the formal industry peer review of the 2000 Update Model conducted in

August 2000. The final report on the peer review stated that "it was the general assessment of

the peer review team that the TMI-1 PRA can be effectively used to support applications

involving risk significant determinations supported by deterministic analysis, once the technical

issues and recommendations for enhancements that are noted in the element summaries and

Fact and Observation Sheets are addressed to an appropriate level of quality." Exelon

Generation stated in the ER that all "A" and "B" facts and observations (F&O) with the exception

of one "B" level observation are closed, and that the unresolved "B" observation related to the

need for independent technical and system engineer reviews of system notebooks and would

have no significant impact on the SAMA evaluation. In response to an NRC staff RAI, Exelon

Generation stated that no other peer reviews of the TMI-1 PRA have been conducted since the

August 2000 peer review (AmerGen 2008b).

Given that the TMI-1 internal events PRA model has been peer reviewed and the peer review

findings were either addressed or judged to have no adverse impact on the SAMA evaluation,

and that Exelon Generation has satisfactorily addressed NRC staff questions regarding the

PRA, the NRC staff concludes that the internal events Level 1 PRA model is of sufficient quality

to support the SAMA evaluation.

As indicated above, the current TMI-1 PRA does not include an integral evaluation of external

events. In the absence of such an analysis, Exelon Generation used the TMI-1 IPEEE, in

conjunction with minor adjustments in seismic and fire risk results, to identify the highest risk

accident sequences and the potential means of reducing the risk posed by those sequences, as

discussed below.

The TMI-1 IPEEE was submitted in December 1994 (GPU 1994), in response to Supplement 4

of Generic Letter 88-20. This submittal included a seismic PRA, a fire-induced vulnerability

evaluation, and risk analyses for external flooding, high winds, and other external events. While

no fundamental weaknesses or vulnerabilities to severe accident risk in regard to external

events were identified, several opportunities for risk reduction were identified and implemented

when demonstrated to be cost effective as discussed below. In a letter dated July 9, 1999, the

NRC staff concluded that the submittal met the intent of Supplement 4 to Generic Letter 88-20,

and that the licensee's IPEEE process is capable of identifying the most likely severe accidents

and severe accident vulnerabilities (NRC 1999).

The IPEEE analysis of external flooding events followed the screening and evaluation

approaches described in Supplement 4 of GL 88-20 (NRC 1991). The TMI-1 IPEEE showed

that external floods are the most important contributors to external event CDF. The IPEEE

external flooding analyses employed a simplified external flooding PRA and containment

performance analysis. The evaluation used flood flow frequency data provided by the Corps of

Engineers (COE), an assessment of the effectiveness of TMI-1 design measures to protect

safety-related structures and components from the probable maximum flood (PMF), flood

scenario evaluation, and manual risk quantification. The CDF for each flood scenario was

obtained by multiplying the frequency of a flood reaching a given flood elevation by the

conditional core damage probability associated with that flooding scenario. The potential impact

on containment performance and isolation was evaluated following the core damage evaluation.

June 2009 F-7 NUREG-1 437, Supplement 37
Appendix F

The external flooding CDF from the IPEEE was estimated to be 8.11 x 10-5 year (GPU 1994).

The dominant external flooding initiating events and their contributions to the external flooding

CDF are provided in Table E.2-21 of the ER (AmerGen 2008a), and summarized in Table F-i.b.

While no external flooding vulnerabilities were identified in the IPEEE, one plant improvement

was identified. This improvement involved installing a flood-resistant means of providing 480V

AC power and pumps to provide reactor coolant pump (RCP) seal cooling and makeup to the

steam generators in station blackout conditions. Exelon Generation indicated that this external

flooding improvement was subsequently implemented (AmerGen 2008a). Based on the

information provided in the ER and in responses to RAIs (AmerGen 2008b), the NRC staff finds

the treatment of external flooding events to be reasonable for the purposes of the SAMA

analysis.

The TMI-1 IPEEE seismic analysis employed a seismic PRA with a simplified seismic

containment performance analysis consistent with NUREG-1407. The seismic approach

employed plant walkdowns by seismic review teams to identify components and structures that

may impact risk, development of seismic fragility values for seismic components and structures,

and CDF quantification using a modified version of the IPE risk model and integration of the

plant logic model with the seismic hazard curve. The seismic CDF was quantified using two

different sets of seismic hazard curves - those developed by the Electric Power Research

Institute (EPRI) (EPRI 1989) and those provided by Lawrence Livermore National Laboratory

(LLNL) (NRC 1994). The applicant determined the seismic CDF to be 3.21 x 10-5 per year using

the EPRI hazard curve and 8.43 x 10.5 per year using the LLNL hazard curve. Table F-4

summarizes the seismic CDF by initiating event category for both the EPRI and LLNL seismic

hazard curves. The IPEEE did not identify any seismic vulnerabilities nor did it identify any

seismic outliers beyond those already identified and resolved within the scope of the Unresolved

Safety Issue (USI) A-46 program. However, in the process of performing the IPEEE analysis,

several plant improvements were identified. These improvements involved modifications to:

reinforce 1P, 1R, 1S, and 1T load center gusset welds, add main control room ceiling supports,

add seismic restraint for penetration pressurization tank PP-T-1A, modify the supports for the

diesel-driven fire pump fuel oil tanks and battery racks, modify the anchorage for the decay heat

closed cooling water heat exchangers, and modify the anchorage for the emergency diesel

generator (EDG) air receivers. The structural improvements to the main control room ceiling, the

penetration pressurization tank, and the EDG air receiver anchorage were subsequently

implemented. The structural improvements to the remaining three components are addressed

by candidate SAMAs (SAMAs 27, 28, and 30). This is discussed further in Section F.3.2. The

NRC review and closure of USI A-46 for TMI-1 is documented in a letter dated August 12, 1998

(NRC 1998c).

NUREG-1437, Supplement 37 F-8 June 2009
Appendix F

Table F-4. TMI-1 Seismic Events Core Damage Frequency

CDF (per year)

Initiating Event Earthquake Range EPRI LLNL

SEIS1 0.052g to 0.2g 5.78 x 10' 1.26 x 10-5

SEIS2 0.2g to 0.3g 1.04 x 10' 2.61 x 10-5

SEIS3 0.3g to 0.5g 1.22 x 10' 3.25 x 10-5

SEIS4 0.5g to 1.01g 3.71 x 10' 1.31 x 10-'

Total Seismic CDF 3.21 x 10. 8.43 x 10'

To provide additional insight as to the appropriate seismic CDF to use for the SAMA evaluation,

the NRC staff developed an independent estimate of seismic CDF for TMI-1 using the

approximation method described in a paper by Robert P. Kennedy, entitled "Overview of

Methods for Seismic PRA and Margin Analysis Including Recent Innovations" and using

updated 2008 seismic hazard curve data from the U.S. Geologic Survey (USGS). This

approach uses a median capacity (C50) of 0.29g, based on the TMI-1 IPEEE high confidence of

low probability of failure (HCLPF) value for critical equipment. The NRC staff's independent

calculation estimates the seismic CDF for TMI-1 to be less than 3.3 x 10.5 per year. This is less

than half of the IPEEE-reported screening value based on the LLNL seismic hazard curve

(8.43 x 10-5 per year) and is essentially the same as the IPEEE-reported value based on the

EPRI seismic hazard curve (3.21 x 105 per year). Based on the NRC staffs independent

estimate of the seismic CDF, and the fact that structural improvements implemented since the

IPEEE have not been accounted for in the estimate of seismic CDF, the NRC staff concludes

that the seismic CDF is likely less than 3.2 x 10-5 per year.

The IPEEE fire analyses employed a progressive screening analysis, with quantification based

on the IPE PRA model. EPRI's fire-induced vulnerability evaluation (FIVE) methodology was

used with deviations. The evaluation was performed in nine steps: (1) identify critical areas of

vulnerability, (2) identify components important to safety, (3) locate components important to

safety, (4) review fire areas for growth and propagation, (5) evaluate component fragilities and

failure modes, (6) review fire detection and suppression systems, (7) identify impacts on top

events, (8) calculate screening CDF, and (9) perform detailed analysis of remaining fire areas

using FIVE fire and damage modeling techniques. The total fire CDF from the IPEEE was

estimated to be 2.4 x 10-5 year (GPU 1994). The dominant fire scenarios and their contributions

to the fire CDF are listed in Table F-5. The IPEEE did not identify any fire vulnerabilities or

improvements related to fire risk.

In the ER, Exelon Generation states that the use of the fire analysis results as a reflection of

CDF may be inappropriate and that while the fire PRA is generally self-consistent within its

calculational framework, the fire analysis does not compare well with the internal events PRA

because of a number of conservative assumptions that have been included in the fire analysis

process. The ER provides a list of fire analysis topics (involving technical inputs, data and

modeling) that prevent the effective comparison of the CDF between the internal events PRA

and the fire analysis. In response to an RAI requesting the applicability of the general topics to

June 2009 F-9 NUREG-1437, Supplement 37
Appendix F

the TMI-1 fire analysis (NRC 2008a), Exelon Generation provided several TMI-1-specific

examples of conservatisms in the fire analysis, including: potential reduction in fire ignition

frequencies, conservative fire protection system assumptions (e.g., automatic fire suppression

systems are not credited), conservative target fire damage assumptions (e.g., a fire in a given

area was assumed to destroy all equipment in the area), and conservative failure probabilities

for human recovery actions (e.g., manual fire suppression or detection is not credited)

(AmerGen 2008b). Based on the arguments regarding the conservatisms in the fire analysis

presented in the ER and RAI responses, Exelon Generation assumed a total fire CDF of 2.16 x

10.5 per year in the SAMA analysis, which is the sum of the fire CDF for the five fire areas

having a fire CDF greater than 1 x 10-6 per year. While this assumption appears to be nonI conservative, Exelon Generation noted in Section E.6.26 of the ER that the fire CDF for fire area

CB-FB-2e reported in the IPEEE (5.81 x 10-6 per year) contained an error that overestimated the

fire CDF and that the correct value is 3.09 x 10-6 per year. As shown in Table F-5, using the

corrected fire CDF for fire area CB-FB-2e results in a revised total fire CDF of 2.13 x 10-5 per

I year, and offsets Exelon Generation not including the CDF from fire areas having a fire CDF

less than 1 x 10-6 per year.

Based on the information provided by the applicant, the NRC staff finds the treatment of fire

events to be reasona-ble for the purposes of the SAMA-analysis.

Table F-5. TMI-1 Fire Areas and Their Contribution to Fire CDF

CDF (per year)

Fire Area Fire Area Description IPEEE Corrected IPEEE

CB-FA-2d East Inverter Room 4.94 x 10- 4.94 x 106

CB-FA-2e West Inverter Room 5.81 x 10' 3.09 x 1 0-(c)

CB-FA-3a 1 D Switchgear Room 3.94 x 10-' 3.94 x 107-

CB-FA-3b 1 E Switchgear Room 4.96 x 10-6 4.96 x 106

CB-FA-4b Control Room -- Console CR 1.96 x 10.6 1.96 x 10-

CB-FA-4b Control Room - Panel CC 8.40 x 107(a) 8.40 x 10-7(a)

CB-FA-2 East Battery Room 7.35 x 10-o 7.35 x 10-7(a

Other Scenarios 8.15 x 10-7(b) 8.15 x 107(b)

Total Fire CDF 2.4 x 10- 2.13 x 10-5

(a) Values provided in response to RAIs (AmerGen 2008b).

(b) Value derived as the difference between the total fire CDF reported in the IPEEE and the fire CDFs

reported for the seven fire areas.

(c) Corrected value from Section E.6.26 of the ER (AmerGen 2008a).

The IPEEE analysis of high winds and other non-flooding external events followed the screening

and evaluation approaches described in Supplement 4 of GL 88-20 (NRC 1991) and did not

identify any significant sequences or vulnerabilities (GPU 1994). (Exelon Generation modeled

external flooding events separately, as discussed above.) Based on this result, Exelon

Generation concluded that these other external hazards, which were estimated to have a

combined CDF of 1.33 x 10.6 per year, would not impact the conclusions of the SAMA analysis.

Accordingly, they did not consider specific SAMAs for these events. This is discussed further in

NUREG-1437, Supplement 37 F-1 0 June 2009
Appendix F

Section F.3.2. Exelon Generation noted that the risks from deliberate aircraft impacts were

explicitly excluded since this was being considered in other forums along with other sources of

sabotage.

Using the CDF values reported in the ER, the non-flooding external events CDF would be

approximately 4.5 times the internal events CDF (based on a seismic CDF of 8.43 x 10-5 per

year, a fire CDF of 2.16 x 10-5 per year, a combined CDF from high winds and other nonflooding external events of 1.33 x 10-6 per year, and an internal events CDF of 2.37 x 10-5 per

year). Accordingly, the total CDF from internal and non-flooding external events would be

approximately 5.5 times the internal events CDF. However, in assessing the benefits for

internal event-related SAMAs, Exelon Generation accounted for the potential risk reduction

benefits associated with non-flooding external events (i.e., seismic and fire events) by doubling

the estimated benefits for internal events. (This doubling was not applied to the seismic- and

fire- related SAMAs, since those SAMAs are specific to external events.)

The NRC staff requested additional justification for increasing the internal events benefits by

only a factor of two in view of the significant contribution to CDF from non-flooding external

events (NRC 2008a). In the RAI response, Exelon Generation clarified that the seismic CODF

reported-in the-ER (8.43 x-100-per-year)-is a screening-value based on LLNL seismic hazard..

curves and was used only in evaluating the benefit of seismic-related SAMAs (discussed later).

Exelon Generation indicated that, in order to not skew the external events CDF when comparing

it to the internal events CDF, the seismic CDF based on the EPRI seismic hazard curves

(3.21 x 10.5 per year) should be used in the multiplier development (AmerGen 2008b). In

response to the same RAI, Exelon Generation provided several TMI-i-specific examples of

conservatisms in the seismic analysis, including: use of conservative methods to assess

component seismic fragility, conservative seismic response assumptions (e.g., recovery of

seismically-induced failure of the offsite power system is not credited),- conservative seismic

damage assumptions (e.g., failure of the main control room ceiling is always assumed to

damage train B of Class 1 E AC power), and conservative component failure probabilities (e.g., if

a component fails in a seismic event then all similar components are assumed to fail) (AmerGen

2008b). Exelon Generation also noted that plant modifications to address seismic risk have

been implemented since the IPEEE (as described above) and are not reflected in the IPEEE

results. Exelon Generation further noted that the IPEEE fire CDF was based on conditional

core damage probability values from the IPE internal events model, and that a re-quantification

of the fire CDF based on the current internal events PRA would result in about a 43 percent

reduction in fire CDF (from 2.16 x 10-5 per year to 1.22 x 10-5 per year). Using the adjusted

seismic and fire CDF values, the total CDF for non-flooding external events (4.56 x 10-5 per year

based on a seismic CDF of 3.21 x 10-5 per year, a fire CDF of 1.22 x 105 per year, and high

winds/other non-flooding external event CDF of 1.33 x 10.6 per year) is approximately twice the

internal events CDF. The NRC staff concludes that Exelon Generation's use of a multiplier of

two in evaluating internal event-related SAMAs is reasonable for the purposes of the SAMA

evaluation. This is discussed further in Section F.6.2.

The NRC staff reviewed the general process used by Exelon Generation to translate the results

of the Level 1 PRA into containment releases, as well as the results of the Level 2 analysis, as

described in the ER and in response to NRC staff requests for additional information (AmerGen

2009a and 2008b).

June 2009 F-1 1 NUREG-1437, Supplement 37
Appendix F

The Level 2 PRA model that forms the basis for the SAMA evaluation is referred to as the

CAFTA Level 2 model of 2007 (Exelon 2007b). The model represents an updated version of

the original IPE Level 2 model previously reviewed by the NRC staff. The Level 2 model utilizes

a single containment event tree (CET), containing both phenomenological and systemic events,

that is directly linked with the CAFTA 2004 Revision 2 Level 1 model. CET nodes are evaluated

using supporting fault trees and logic rules. The model is fully described in TMI-PRA-001

(Exelon 2007b).

I Exelon Generation characterized the internal events releases for the spectrum of possible

radionuclide release scenarios using a set of 39 release categories. The release categories and

their frequencies are presented in Table E.2-16 of the ER. The categories were defined based

on the timing, duration, and magnitude of the release and whether the containment remains

intact or is bypassed. The frequency of each release category was obtained by summing the

frequency of the individual CET end states assigned to each release category. The 39 release

categories were further collapsed into nine major source term groups having similar

containment response. The nine major source term groups and their release characteristics are

presented in Tables E.2-17 and E.2-18 of the ER. The release characteristics for these nine

source term groups were developed from Modular Accident Analysis Program (MAAP) analyses

performed specifically to support the SAMA analysis -(Ame&Gen 2008b). .

The core damage sequences developed for the external flooding model include the three major

groups shown in Table F-i b. Of these groups, the floods above 310 feet and those below 305

feet are each represented by a single core damage sequence. The floods between 305 and

I 310 feet are represented by six sequences that were quantified using an ET developed

specifically for the IPEEE external flooding evaluation. The descriptions and frequencies of

I these flood sequences are summarized in Table E.2-21 of the ER. Exelon Generation

characterized the external flooding events releases for the spectrum of possible radionuclide

release scenarios using a set of eight release categories from the internal events analysis,

which were subsequently collapsed into seven non-zero source term groups. The source term

frequencies associated with each of the flooding sequences is provided in Table E.2-23 of the

I ER. In response to an RAI, Exelon Generation provided additional information on the logic used

to derive the source term frequencies for each of the flooding sequences (AmerGen 2008b). In

I response to another RAI, Exelon Generation provided a corrected frequency of 1.68 x 10-8 per

year for source term RC-1 (SGTR) in Table E.2-23 of the ER (AmerGen 2008b).

The NRC staffs review of the Level 2 IPE concluded that it addressed the most important

severe accident phenomena normally associated with large, dry containments, and identified no

significant problems or errors (NRC 1996). The, Level 2 PRA model was included in the TMI-1

peer. review mentioned previously. It should be noted, however, that the current Level 2 model

is a revision to version that was peer reviewed. The changes to the Level 2 model are

described in Section E.2.2.3 of the ER (AmerGen 2008). Based on the NRC staffs review of

the Level 2 methodology for both internal events and external flooding events and the

responses to the RAIs concerning the Level 2 model, the NRC staff concludes that the Level 2

PRA provides an acceptable basis for evaluating the benefits associated with various SAMAs.

As indicated in the ER, the reactor core radionuclide inventory used in the consequence

analysis was based on a 2002 plant-specific ORIGEN 2.1 calculation and corresponds to a 24-

month refueling cycle and the licensed thermal power of 2568 MWt. All releases were modeled

NUREG-1437, Supplement 37 F-1 2 June 2009
Appendix F

as occurring at 51.6 meters (top of the reactor building). The thermal content of each of the

releases is assumed to be 1.OE+07 watts based on values provided in Sample Problem A in the

MACCS2 user's manual (NRC 1998a) and NUREG/CR-4551 (NRC 1990a). Exelon Generation

assessed the impact of alternatively assuming either a ground level release or an ambient (nonbuoyant) plume. The results of these sensitivity cases showed that reducing the release height

to ground level results in about a 5 percent decrease in population dose-risk, and reducing the

thermal plume heat content to ambient conditions results in less than a 2 percent increase in

population dose-risk.

The NRC staff reviewed the process used by Exelon Generation to extend the containment

performance (Level 2) portion of the PRA to an assessment of offsite consequences (essentially

a Level 3 PRA). This included consideration of the source terms used to characterize fission

product releases for the applicable containment release categories and the major input

assumptions used in the offsite consequence analyses. The MACCS2 code was utilized to

estimate offsite consequences. Plant-specific input to the code includes the source terms for

each release category and the reactor core radionuclide inventory (both discussed above), sitespecific meteorological data, projected population distribution within a 50-mi (80-km) radius for

the year 2034, emergency evacuation modeling, and economic data. This information is

provided- in Attachment E of the:ER.

Exelon Generation used site-specific meteorological data for the 1998 calendar year as input to

the MACCS2 code. The data were collected from the onsite meteorological tower. Data from

1998 through 2000 were also considered, but the 1998 data were chosen because they were

the most complete and because results of a MACCS2 sensitivity analysis indicated that the

1998 data produced slightly more conservative results than the data sets for the other years. All

of the missing data gaps were less than 2 hours and interpolation was used to fill the gaps. The

NRC staff notes that previous SAMA analyses results have shown little sensitivity to year-toyear differences in meteorological data and concludes that the use of the 1998 meteorological

data in the SAMA analysis is reasonable.

The population distribution the licensee used as input to the MACCS2 analysis was estimated

for the year 2034, based on the U.S. Census Bureau population data for 2000, as provided by

the SECPOP2000 program (NRC 2003), and the expected annual population growth rate. The

baseline population was determined for each of sixteen directions and each of ten concentric

rings (total of 160 sectors) out to a radius of 50 mi (80 km) surrounding the site. The transient

population within 10 mi (16 km) of the site was included. U.S Census block-group level

population data is allocated to each sector based on the area fraction of the census blockgroups in that sector. The 1990 and 2000 census data were used to determine a ten.year

population growth factor for each of the 50-mi (80-km) radius rings. The population growth

factor for each ring was applied uniformly to all sectors in the ring to calculate the year 2034

population distribution. Population sensitivity cases were performed in which the baseline 2034

population was increased by 30 percent, and then decreased to the year 2000 population data

rather than the projected year 2034 population. The resulting population dose and offsite

economic cost risk increased and decreased by approximately 30 percent, respectively. In

response to an RAI regarding the sensitivity case using the year 2000 population, Exelon

Generation clarified that the population change from year 2034 (to year 2000) was

approximately 29 percent and that the change in offsite economic cost risk was consistent with

June 2009 F-1 3 NUREG-1437, Supplement 37
Appendix F

the change in population (AmerGen 2008b). The NRC staff considers the methods and

assumptions for estimating population reasonable and acceptable for purposes of the SAMA

evaluation.

The emergency evacuation model was modeled as a single evacuation zone extending out 10

mi (16 km) from the plant. Based on information in the ER, it was assumed that 95 percent of

the population would evacuate. This assumption is conservative relative to the NUREG-1 150

study (NRC 1990b), which assumed evacuation of 99.5 percent of the population within the

emergency planning zone (EPZ). The evacuation time used in the SAMA analysis was based

on a projection for the year 2034. The evacuees were assumed to begin evacuating 90 minutes

after a General Emergency has been declared and to evacuate at an average radial speed of

1.18 miles per hour (mph) (0.53 meters per second [m/s]). This speed is the time weighted

value accounting for season, day of the week, time of day, weather conditions, and special

events. A sensitivity analysis was performed in which the evacuation speed was decreased by

a factor of two (to 0.26 m/s). The result was a 15 percent increase in the total population dose.

The NRC staff concludes that the evacuation assumptions and analysis are reasonable and

acceptable for the purposes of the SAMA evaluation.

.Much of the site-specific. economic data was provided fromSECPOP2000 (NRC 2003) by ...

specifying the data for each of the counties surrounding the plant to a distance of 50 miles.

SECPOP2000 utilizes economic data from the 1997 Census of Agriculture (USDA 1998).

Generic economic data that applies to the region as a whole was taken from the MACCS2

sample problem input and revised when better information was available. Revised values

included daily living expenses for people who have been evacuated and relocated, and the

value of farm and non-farm wealth. The economic data were inflation-adjusted to the year 2006

using the consumer price index.

Exelon Generation addressed the impact on the SAMA analysis of three recently reported

problems with SECPOP2000. These problems involved: (1) an inconsistency in the format in

which several economic parameters were output from the SECPOP2000 code and input to the

MACCS2 code, (2) an error that resulted in use of agricultural/economic data for the wrong

counties in the SECPOP2000 calculations, and (3) an error that resulted in the economic data

for some counties being handled incorrectly. Correction of the first of these errors is reflected in

the baseline risk estimates provided in the ER. Correction of the second two errors was

evaluated in a sensitivity analysis contained in the ER. Correction of the second two errors

resulted in a decrease in population dose of approximately one percent and an increase in

offsite economic cost risk of approximately 15 percent. The revised population dose results are

reported in Section E.7.6.4 of the ER, and have been used as the basis for the NRC staff

evaluation.

The NRC staff concludes that the methodology used by Exelon Generation to estimate the

offsite consequences for TMI-1 provides an acceptable basis from which to proceed with an

assessment of risk reduction potential for candidate SAMAs. Accordingly, the NRC staff based

its assessment of offsite risk on the CDF and revised offsite doses reported by Exelon

Generation.

F.3 Potential Plant Improvements

NUREG-1437, Supplement 37 F-1 4 June 2009
Appendix F

The process for identifying potential plant improvements, an evaluation of that process, and the

improvements evaluated in detail by Exelon Generation are discussed in this section.

F.3.1 Process for Identifying Potential Plant Improvements

Exelon Generation's process for identifying potential plant improvements (SAMAs) consisted of

the following elements:

' Review of the most significant basic events from the current, plant-specific PRA,

* Review of potential plant improvements identified in the TMI-1 IPE and IPEEE,

* Review of Phase II SAMAs from license renewal applications for six other U.S. nuclear

sites,

* Review of dominant contributors to external flooding, seismic and fire events in the

current external event risk models, and

* Review of other industry documentation discussing potential plant improvements.

Based on this process, an initial set of 33 candidate SAMAs, referred to as Phase I SAMAs, was

identified. In Phase I-of the evaluation, Exelon Generation performed a qualitative screening of

the initial list of SAMAs using the following criteria:

• The SAMA is not applicable at TMI-1 due to design differences, or

* The SAMA has estimated costs that would exceed the dollar value associated with

completely eliminating all severe accident risk at TMI-1.

Based on this screening, no SAMAs were eliminated leaving all 33 for further evaluation. These

SAMAs, referred to as Phase II SAMAs, are listed in Table F.5-3 of the ER (AmerGen 2008a).

In Phase II, a detailed evaluation was performed for each of the 33 SAMA candidates, as

discussed in Sections F.4 and F.6 below.

Exelon Generation accounted for the potential risk reduction benefits associated with internal

event- and external flooding-related SAMAs by separately quantifying the benefits using the

internal event or external flooding model, respectively. For internal event-related SAMAs,

Exelon Generation accounted for the potential risk reduction benefits associated with nonflooding external events (i.e., seismic and fire events) by doubling the estimated benefits for

internal events. For seismic- and fire-related SAMAs, Exelon Generation separately estimated

the risk reduction benefits using the seismic and fire risk models.

F.3.2 Review of Exelon Generation's Process

Exelon Generation's efforts to identify potential SAMAs focused primarily on areas associated

with internal initiating events, but also included explicit consideration of potential SAMAs for

external flooding, seismic, and fire events. The initial list of SAMAs generally addressed the

accident sequences considered to be important to CDF from functional, initiating event, and risk

reduction worth (RRW) perspectives at TMI-1, and included selected SAMAs from prior SAMA

analyses for other plants.

June 2009 F-1 5 NUREG-1437, Supplement 37
Appendix F

I Exelon Generation provided a tabular listing of the PRA basic events sorted according to their

RRW (AmerGen 2008a). SAMAs impacting these basic events would have the greatest

I potential for reducing risk. Exelon Generation used a RRW cutoff of 1.01, which corresponds to

about a one percent change in CDF given 100-percent reliability of the SAMA. This equates to

a benefit of approximately $52,000 (after the benefits have been multiplied to account for nonflood external events). External flooding contributions were not included in the benefit

calculations establishing the RRW review threshold because the benefit of external flooding

I SAMAs are evaluated separately from the internal events model. Exelon Generation also

provided and reviewed the large early release frequency (LERF)-based RRW events down to a

RRW of 1.01. Exelon Generation correlated the basic events with highest risk importance in the

Level 1 and 2 PRA with the SAMAs evaluated in Phase I or Phase II, and showed that, with a

few exceptions, all of the significant basic events are addressed by one or more SAMAs

(AmerGen 2008a). Of the basic events of high risk importance that are not addressed by

SAMAs, each is closely tied to other basic events that had been addressed by one or more

SAMAs.

The staff noted that basic event GADF-PALL6-CP2FS was identified in the Level 2 importance

list review-as being addressed by the same SAMAs as identified in the Level 1 importance list

review for this same basic-"event b-ut that this basic ev-eht was_ not listed ifn the-Level I -....

importance list (NRC 2008a). In response to the RAI, Exelon Generation clarified that this event

contributes almost exclusively to station blackout (SBO) scenarios and is effectively addressed

by SAMAs 2 and 11 (AmerGen 2008b).

Exelon Generation considered the potential plant improvements identified in the IPE and IPEEE

in the identification of plant-specific candidate SAMAs for internal and external events, as

summarized below.

The TMI-1 IPE identified five major procedural improvements. These enhancements are: (1)

revise procedures to direct operators to throttle low pressure injection (LPI) prior:to swapping

the pump suction source from the borated water storage tank (BWST) to the containment sump,

(2) revise accident management guidelines for SGTR events to direct the operators to isolate

the failed steam generator and cooldown the primary system using the intact steam generator,

(3) revise accident management guidelines for SGTR events in which isolation. of the ruptured

steam generator is not possible to direct the operators to refill the BWST to keep pace with

reactor coolant system (RCS) inventory loss, (4) revise accident management guidelines to

direct the operators to verify closure of the MU-1 4 valves after the transition to recirculation

mode from high pressure injection (HPI) mode, and (5) include six specific operator actions in

I the licensed operator requalification training program. Exelon Generation noted that the first

four improvements have been implemented and the fifth improvement has been partially

implemented; therefore these improvements were not considered further in the SAMA analysis.

The six operator actions associated with the fifth improvement included: (1) switchover to

reactor sump recirculation following a LOCA, (2) properly throttling HPI flow after ES actuation,

(3) tripping RCPs before seal damage after loss of nuclear services closed cooling water

(NSCCW), (4) taking actions to prevent boron concentration when in recirculation following a

LOCA, (5) refilling the BWST given SGTR, and (6) holding open or reopening RCP seal

injection valve MU-V-20 on loss of instrument air. The first four operator actions have been

I implemented, and therefore were not considered further in the SAMA analysis. While Exelon

NUREG-1437, Supplement 37 F-1 6 June 2009
Appendix F

Generation has identified no specific training for the last two operator actions, failure to perform

these actions is included in the TMI-1 PRA model. The importance list review conducted by

Exelon Generation for the SAMA analysis identified failure of operator action (5) as an important

contributor to CDF. SAMA 10 was identified to address this event. The RRW for failure of

operator action (6) is less than the cutoff threshold of 1.01 for identifying potentially costbeneficial SAMAs. Nevertheless, this and similar loss of instrument air events is addressed by

SAMA 13.

The TMI-1 external flooding IPEEE identified one opportunity for improvement related to

external flooding events. This enhancement was to install a flood-resistant means of providing

480V AC power and pumps to provide RCP seal cooling and makeup to the steam generators.

Exelon Generation stated that this enhancement has been implemented and was credited in the

IPEEE external floods CDF. Nevertheless, Exelon Generation further considered potential

SAMAs for external floods and identified two opportunities for additional reduction of the

external flooding risk, specifically, SAMA 32, pre-stage severe external flooding equipment, and

SAMA 33, increase the flood protection height. The NRC staff questioned whether there was

adequate time to install the TMI-1 flood gates in fast-developing floods, such as the flood surge

produced by a hurricane, and requested justification for not identifying and evaluating potential

SAMAs to reduce this response time (e.g., pre-staging of cranes needed to install -the gates)

(NRC 2008a). In response to the RAI, Exelon Generation clarified that TMI-1 staff have about

7.5 hours to install the six flood panels at the Intake Screen Pumphouse, which are the last

flood gates to be installed if needed, but that TMI-1 staff only require at most about 3 hours to

install these panels (AmerGen 2008b). Exelon Generation further clarified that TMI-1 staff have

about 36 hours to install the many other flood gates, which is significantly more time than is

needed to complete their installation (AmerGen 2008c). Based on these arguments, Exelon

Generation determined that there were no additional potentially cost-beneficial SAMAs to

-mitigate external flooding events.

The TMI-1 seismic IPEEE identified six opportunities for improvements related to seismic

events. The enhancements included: (1) add gusset weld reinforcements to load centers 1 P,

1 R, 1S, and 1T to improve seismic ruggedness, (2) install additional supports for the main

control room (MCR) ceiling to prevent failure in seismic events, (3) install a restraint on

penetration pressurization tank PP-T-1A to prevent seismic interaction with reactor building

purge inlet isolation valve AH-V-1 D, (4) modify the diesel fire pump battery and fuel oil tank

supports to increase their seismic ruggedness, (5) modify the anchorage for the decay heat

service heat exchangers (DC-C-2A/B) to improve their seismic ruggedness, and (6) modify the

anchorage for the EDG air receivers to improve their seismic ruggedness. Exelon Generation

stated that enhancements (2), (3), and (6) were subsequently .implemented, and therefore were

not considered further in the SAMA analysis. As noted in Section E.5.1.6.2.2 of the ER

(AmerGen 2008a), SAMA 27, improve the 480V AC load center welds, SAMA 30, improve

diesel fire pump fuel oil tank and battery rack supports, and SAMA 28, improve the decay heat

service cooler (DC-C-2A/B) anchorages, were identified and retained for the Phase II evaluation

to specifically address un-implemented enhancements (1), (4), and (5), respectively. Exelon

Generation further reviewed the top contributors to seismic risk to identify additional areas for

potential plant improvement and identified three opportunities for additional reduction of the

seismic risk, specifically, SAMA 2, install damage resistant high temperature RCP seals with a

portable 480V AC generator for extended emergency feedwater (EFW) operation (originally

June 2009 F-1 7 NUREG-1437, Supplement 37
Appendix F

identified based on internal events risk), SAMA 29, replace EDG ground resistors, and SAMA

31, modify specific containment penetration motor operated valves (MOVs) to fail closed.

The TMI-1 fire IPEEE did not identify any opportunities for improvements related to fire events

I (AmerGen 2008a). Nevertheless, Exelon Generation further reviewed the top contributors to

fire risk to identify areas for potential plant improvement and identified two opportunities for

additional reduction of the fire risk, specifically, SAMA 2 (described above) and SAMA 26,

reroute cables so that they do not pass over ignition sources in fire zone CB-FA-2e or wrap

theses cables in fire proof material. In response to an RAI on the potential for SAMAs that could

I reduce the fire risk in other fire areas screened on low CDF, Exelon Generation evaluated the

fire risk for two additional fire scenarios, CB-FA-2f (East Battery Room) and the CC panel from

fire area CB-FA-4b, and identified no additional potentially cost-beneficial SAMAs to mitigate

these fire scenarios (AmerGen 2008b).

The TMI-1 IPEEE did not identify opportunities for improvements related to high winds,

accidental aircraft impact, and hazardous chemical release events (AmerGen 2008a). In

I Section E.5.1.6.5 of the ER, Exelon Generation states that the maximum benefit of completely

eliminating the risk of these events is less than the $50,000 minimum cost for implementing a

SAMA.- The NRC staff-questioned-the methodology used by Exelon Generation-to calculate the

I maximum benefit of these events and asked Exelon Generation to provide a revised

assessment of potential SAMAs based on the methodology presented by the NRC staff (NRC

I 2008a). In response to the RAI (AmerGen 2008b), Exelon Generation stated that the only types

of SAMA candidates that would be potentially cost-beneficial utilizing the higher benefit values

calculated utilizing the NRC methodology would be procedure changes, of which none could be

I identified to mitigate these types of events (AmerGen 2008b). Exelon Generation therefore

identified no additional potentially cost-beneficial SAMAs to mitigate high winds, accidental

aircraft impact, and hazardous chemical release events.

As discussed above, AmerGen's SAMA evaluation included SAMAs addressing unimplemented

enhancements identified in the IPE and IPEEE, and SAMAs addressing additional

enhancements based on a review of the dominant contributors to internal', external flooding,

seismic, and fire events. Based on this information, the NRC staff concludes that the set of

SAMAs evaluated in the ER addresses the major contributors to internal and external event

CDF, that the opportunity for SAMAs related to both internal and external events has been

adequately explored, and that it is unlikely that there are additional potentially cost-beneficial

SAMA candidates.

The NRC staff noted that none of the initial 33 SAMA candidates were screened from further

I consideration in the Phase I evaluation, and questioned whether Exelon Generation had

conducted a pre-screening process to develop this initial list (NRC 2008a). In response to the

I RAI, Exelon Generation stated that no formal pre-screening process had been used in the

development of the Phase I SAMA list and that the list of 33 SAMA candidates represents the

complete results of the SAMA identification process described in the ER (AmerGen 2008b).

For a number of the SAMAs evaluated in the ER, the information provided did not sufficiently

describe the proposed modification. Therefore, the NRC staff asked the applicant to provide

more detailed descriptions of the modifications for several of the Phase II SAMA candidates

(NRC 2008a). In response to the RAI, Exelon Generation provided the requested information

(AmerGen 2008b).

NUREG-1437, Supplement 37 F-1 8 June 2009
Appendix F

The NRC staff notes that the set of SAMAs submitted is not all inclusive, since additional,

possibly even less expensive, design alternatives can always be postulated. However, the NRC

staff concludes that the benefits of any additional modifications are unlikely to exceed the

benefits of the modifications evaluated and that the alternative improvements would not likely

cost less than the least expensive alternatives evaluated, when the subsidiary costs associated

with maintenance, procedures, and training are considered.

The NRC staff concludes that Exelon Generation used a systematic and comprehensive

process for identifying potential plant improvements for TMI-1, and that the set of potential plant

improvements identified by Exelon Generation is reasonably comprehensive and therefore

acceptable. This search included reviewing insights from the plant-specific risk studies, and

reviewing plant improvements considered in previous SAMA analyses. While explicit treatment

of external events in the SAMA identification process was limited, it is recognized that the prior

implementation of plant modifications for external flooding, seismic, and fire events and the

absence of external event vulnerabilities reasonably justifies examining primarily the internal

events risk results for this purpose.

F.4 Risk Reduction Potential of Plant Improvements

Exelon Generation evaluated the risk-reduction potential of the 33 SAMAs that were applicable

to TMI-1. The SAMA evaluations were performed using realistic assumptions with some

conservatism. On balance, -such calculations overestimate the benefit and are conservative.

For most of the SAMAs, Exelon Generation used model re-quantification to determine the

potential benefits. The CDF and population dose reductions for internal events were estimated

using the TMI-1 Level 1 and 2 PRA model (Version 2004 Revision 2) and for external flooding

events were estimated using the IPEEE external flooding PRA model with plant damage states

correlated to release categories from the internal events analysis. The changes made to the

models to quantify the impact of SAMAs are detailed in Section E.6 of Appendix E to the ER

(AmerGen 2008a). Table F-6 lists the assumptions considered to estimate the risk reduction for

each of the evaluated SAMAs, the estimated risk reduction in terms of percent reduction in CDF

and population dose, and the estimated total benefit (present value) of the averted risk. The

estimated benefits reported in Table F-6 reflect the combined benefit in both internal and

external events and reflect corrections to previously identified SECPOP2000 errors, as

described in Section E.7.6 of Appendix E to the ER (AmerGen 2008a). The determination of the

benefits for the various SAMAs is further discussed in Section F.6.

The NRC staff questioned the assumptions used in evaluating the benefits or risk reduction

estimates of certain SAMAs provided in the ER (NRC 2008a). For SAMA 1, enhance the SBO

EDG with auto start and load capability, the NRC staff requested the bases for the assumption

for SAMA 1 that making modifications to automate start of the SBO EDG only reduces the

probability of failure to start the SBO EDG by a factor of 10. In response, Exelon Generation

clarified that most of the benefit for this SAMA is from preventing all seal LOCA cases resulting

from the inability to provide power for *RCP seal cooling within 13 minutes. In order to show that

the results of this SAMA evaluation are not sensitive to the human error probability used in the

modeling process, Exelon Generation set the probability to zero and showed that the change in

June 2009 F-1 9 NUREG-1437, Supplement 37
Appendix F

CDF was negligible (AmerGen 2008b). The NRC staff considers the assumptions, as clarified,

to be reasonable and acceptable for purposes of the SAMA evaluation.

The NRC staff asked for clarification as to why SAMA 10, automate BWST refill, was assumed

to prevent, rather than just delay core damage (NRC 2008a). In response to the RAI, Exelon

Generation clarified that SAMA 10 would include the installation of a new, higher flow pump to

ensure the BWST can be refilled at a rate greater than inventory is being lost through the steam

generator tube rupture (AmerGen 2008b). The NRC staff considers the assumption, as

clarified, to be reasonable and acceptable for purposes of the SAMA evaluation.

I In a separate RAI on SAMA 10, the NRC staff asked Exelon Generation to provide an

assessment of the impact on the net value of this SAMA if the benefit of mitigating ISLOCA

events were considered in addition to the already estimated benefit of mitigating SGTR events

I (NRC 2008a). In response to the RAI, Exelon Generation re-evaluated this SAMA by assuming

the SAMA also eliminates all ISLOCA events. This bounding assumption resulted in a CDF

reduction of approximately 4.2 percent, compared to 3.4 percent reported in the ER, and a

population dose-risk reduction of approximately 17 percent, compared to 14 percent reported in

the ER (AmerGen 2008b). The NRC staff considers the assumption, as revised, to be

reasonable and acceptable for purposes of the SAMA evaluation.

The NRC staff questioned the modeling assumption that seismic SAMA 27, improve the 480V

AC load center welds (HCLPF of 0.12g), and seismic SAMA 28, improve the decay heat service

cooler anchorages (HCLPF of 0.09g), would result in seismic failure probabilities similar to that

for the BWST (HCLPF of 0.3g), given the design and functional dissimilarities between the

respective components (NRC 2008a). In response to the RAI (AmerGen 2008b), Exelon

Generation noted that SAMA 27 was shown to be cost-beneficial by a wide margin and that only

extreme fragility data changes could impact this result, which is not likely. For SAMA 28, Exelon

Generation compared the component failure probability data for decay heat service coolers,

which is considered a good surrogate for heat exchangers, with the BWST failure probability

data used in the IPEEE. Based on this comparison, Exelon Generation determined that they

generally have similar failure probabilities for the initiating events evaluated in the IPEEE, and

that use of the BWST values result in slightly larger averted cost-risk. The NRC staff considers

the assumptions, as clarified, to be reasonable and acceptable for purposes of the SAMA

.evaluation.

I For SAMAs that were specifically developed to address internal event issues, Exelon

Generation increased the benefit that was derived from the internal events model by a factor 2

to account for the additional benefits that these SAMAs might have. in external events other than

external floods (primarily seismic and fire events). The benefits in external floods were

separately quantified using the external flood risk model, where applicable (as noted in Table F6), and combined with these benefits.

For SAMAs that specifically address seismic events (i.e., SAMAs 27 through 31), the reduction

in seismic CDF and population dose was not directly calculated (in Table F-6 these are noted as

NOT ESTIMATED). For these SAMAs, a bounding estimate of the impact of the SAMA was

made based on general assumptions regarding: the approximate contribution to total risk from

external events relative to that from internal events; the fraction of the external event risk

attributable to seismic events; and the fraction of the seismic risk-affected by the SAMA (based

on information from the IPEEE). For example, Exelon Generation assumed. that the contribution

NUREG-1437, Supplement 37 F-20 June 2009
Appendix F

to risk from external events (excluding external flooding events) is approximately equal to that

from internal events, and that seismic events contribute about 80 percent of this external events

risk. The seismic analysis was then used to identify the fraction of the seismic risk that could be

eliminated by the potential enhancements.

The NRC staff notes that Exelon Generation's assumption that the seismic CDF is equivalent to

80 percent of the internal events CDF effectively results in a seismic CDF of 1.9 x 10-5 per year.

In response an RAI, Exelon Generation noted that the seismic CDF reported in the IPEEE

(based on use of the EPRI hazard curves) is 3.21 x 10-5. per year. Exelon Generation also

identified a number of conservative assumptions in the IPEEE seismic analysis, and identified

several seismic-related plant modifications that have been implemented but not reflected in the

IPEEE risk results (AmerGen 2008b). As discussed in Section F.2.2, based on an independent

estimate of the seismic CDF, and the fact that structural improvements implemented since the

IPEEE have not been accounted for in the estimate of seismic CDF, the NRC staff expects that

the seismic CDF would be less than 3.2 x 10-5 per year. The NRC staff assessed the impact

that use of the higher seismic CDF (3.2 x 10-5 per year) would have on the cost effectiveness of

the evaluated seismic SAMAs and found that the conclusions regarding these SAMAs would not

be impacted.

For the SAMA that specifically addresses fire events (i.e., SAMA 26), the reduction in fire CDF

and population dose also was not directly calculated. For this SAMA, a bounding estimate of

the impact of the SAMA was made using a methodology similar to that described for seismic

SAMAs. For example, it is assumed that the contribution to risk from external events (excluding

external flooding events) is approximately equal to that from internal events, and that internal

fires contribute 85 percent of this external events risk. The fire analysis was then used to

identify the fraction of the fire risk that could be eliminated by potential enhancements in the

applicable fire area. Exelon Generation's assumption that the fire CDF is equivalent to 85

percent of the internal events CDF effectively results in a fire CDF of 2.0 x 10-5 per year. As

discussed in Section F.2.2, using the corrected fire CDF for fire area CB-FB-2e results in a

revised total fire CDF of 2.13 x 10-5 per year. Thus, the fire CDF used in assessing the benefits

for the fire-related SAMA is consistent with the revised total fire CDF.

While noting that Exelon Generation's assumptions that seismic CDF is 80 percent and fire CDF

is 85 percent of the total non-flooding external events CDF appear internally inconsistent, the

NRC staff concludes that the resulting seismic and fire CDFs are in general agreement with the

seismic and fire CDFs and accompanying qualitative justification presented in Section F.2.2,

and that Exelon Generation's risk reduction estimates for the seismic-and fire-related SAMAs

are acceptable for purposes of the SAMA evaluation.

The NRC staff has reviewed Exelon Generation's bases for calculating the risk reduction for the

various plant improvements and concludes, that the rationale and assumptions for estimating

risk reduction are reasonable and generally conservative (i.e., the estimated risk reduction is

higher than what would actually be realized). Accordingly, the NRC staff based its estimates of

averted risk for the various SAMAs on Exelon Generation's risk reduction estimates.

June 2009 F-21 NUREG-1437, Supplement 37
Table F-6. SAMA Cost/Benefit Screen Analysis for TMI-1(a)

% Risk Reduction(b) Total Benefit(c) ($)

CDF Population Baseline Baseline With

SAMA Assumptions(d) Dose Uncertainty Cost ($)

1 - Enhance the SBO EDG with IE: Modify event tree to prevent all seal 21 16

auto start and load capability LOCA cases resulting from inability to provide

RCP seal cooling within 13 minutes. Reduce•

the probability of failure to start the SBO EDG

during loss of AC power events by a factor of

10, and set corresponding Joint Human Error 1.0M 2.9M 3.1M

Probabilities (JHEPs) to 0.

EF: Reduce the risk for LOOP scenarios for -0 -0

floods below 305' msl by the same percent

reduction as for intemal events.

2 - Install damage resistant high IE: Reduce the probabilities of RCP seal 53 53

temperature RCP seals with a LOCAs and loss of AC power to

portable 480V AC generator for instrument air during SBO by a factor of

extended EFW operation 10. Reduce the probability of failure to

operate EFW valve EF-V-30 due to loss of

instrument air by a factor of 10, and set 4.6M 13M 7.3M

corresponding JHEPs to 0.

EF: Eliminate all SBO events for floods 5 6

between 305' and 310' msl when flood

gates are correctly installed; eliminate all

risk from floods below 305' msl. _

3 - Use NSCCW as an alternate IE: Modify fault tree to include cross-tie of the 15 8

cooling source for the decay heat NSCCW system to the DHR heat

removal (DHR) heat exchangers exchangers.

(DH-C-1NB) 620K 1.7M 2.5M

EF: Eliminate power-recovered SBO events -0 -0

for floods between 305' and 310' msl when

flood gates are correctly installed; eliminate

all risk from floods below 305' msl.

June 2009 F-22 NUREG-1437, Supplement 37
Appendix F

Y *1*I

SAMA Assumptions(d) -1* 4 - Provide alternate power to HPI

pump minimum flow recirculation

valves MU-V-36 and MU-V-37

The RRW for the basic event is below the

cost-beneficia! cutoff. NOT ESTIMATED

5 - Enhance valves MU-V-76A/B IE: Reduce the probability of failure to align 6 3

and MU-V-77A/B to allow for rapid the "C" HPI pump to provide seal injection by

alignment changes in accident a factor of 100. 240K 660K 3.2M

conditions

EF: Reduce the risk for floods below 305' 0 0

msl by 6.3 percent.

6 - Add cross-ties within the trains IE: Modify fault tree to include cross-ties 13 5

of cooling systems - DHR, between Trains A and B of the DHRW

DHCCW, DHRW system, between Trains A and B of the

DHCCW system, between Trains A and B of

the LPI system, and between Trains A and B

of the DHR system. 410K 1.1M 2.8M

EF: Eliminate power-recovered SBO events -0 -0

for floods between 305' and 310' msl when

flood gates are correctly installed; eliminate

all risk from floods below 305' msl._

7 - Use fire service water as an IE: Modify fault tree to include cross-tie of 13 6

alternate cooling source for the the fire service water system to the ICCW

intermediate closed cooling heat exchangers. 470K 1.3M 1.0M

water (ICCW) heat exchangers

EF: Eliminate all risk from floods below -0 -0

305' msl.

8 - Automate reactor coolant IE: Reduce the probability of failure to trip 13 23

pump trip on high motor bearing the RCPs upon loss of NSCCW by a factor

cooling temperature of 10, and set corresponding JHEPs to 0. 1.3M 3.6M 150K

EF: Does not mitigate external flooding 0 0

June 2009 F-23 NUREG-1437, Supplement 37
Appendix F

T 7

SAMA Assumptions I.scenarios.

9 - Proceduralize local atmospheric

dump valve (ADV) operation

The current model is conservative in that it

does not credit existing procedures to

perform local ADV operations. Crediting the

existing procedures by assigning a human

error probability of 0.1 for failure to locally

operate ADVs on loss of air reduces RRW

below the cost-beneficial cutoff.

NOT ESTIMATED

10 - Automate BWST refill

Baseline Case(e) IE: Reduce the probability of failure to refill 4 17

the BWST from 2.65E-02 to 1.0E-04, and set

corresponding JHEPs to 0. Eliminate all

ISLOCA events. 1.3M~" 3.5M(f) 3.8M

EF: Does not mitigate external flooding 0 0

scenarios.

Sensitivity Case IE: Reduce the probability of failure to 17(f) 50(f)

refill the BWST from 1.0 to 1.0E-04, and

set corresponding JHEPs to 0. Eliminate

all ISLOCA events. 6.3M(' 17Mif 3.8M

EF: Does not mitigate external flooding 0 0

scenarios. _

11 - Enhance extreme external IE: Reduce the probability of failure to 34 25

flooding mitigation equipment to operate the EDGs and TD EFW pumps to

address SBO and loss of seal 0.

cooling scenarios 17M 47M 4.3M

EF: For all floods, reduce the probability 93 93

of failure to implement the external

flooding measures to 1.OE-04 and reduce

NUREG-1437, Supplement 37 F-24 June 2009
Appendix F

% Risk Reduction(b) Total Benefit(c) (

Population Baseline Baseline With

SAMA Assumptions(d) Dose Uncertainty Cost ($)

the probability of failure to provide floodresistant AC power to 2.OE-02.

12 - Use the DHR system as an IE: Modify fault tree to include alignment 4 3

alternate suction source for HPI of existing DHR valves DH-V-7A/B having

a probability of failure of 0.1. 210K 580K 50K

EF: Does not mitigate external flooding 0 0

scenarios.

13 - Change IA system logic to

automatically start IA-P-1 A/B

after a low voltage trip In

conjunction with an engineered

safeguards actuation signal

(ESAS)

Baseline Case IE: Reduce the probability of failure to start 3 4

the air compressors using emergency power

to 1.OE-05, and set corresponding JHEPs to

0. 330K 920K 950K

EF: Does not mitigate external flooding 0 0

scenarios.

Sensitivity Case(g) IE: Reduce the probability of failure to 8 19

start the air compressors using

emergency power to 1.0E-05, and set

corresponding JHEPs to 0. Set the

probability of failure to refill the BWST 2.4M(f) 6.6M(f) 950K

from 2.65E-2 to I (in both baseline and

sensitivity case).

EF: Does not mitigate external flooding 0 0

_ scenarios.

June 2009 F-25 NUREG-1437, Supplement 37
Appendix F

% Risk Reduction(b) Total Benefit(c) ($)

(d) CDF Population Baseline Baseline With SAMA Assumptions Dose Uncertainty Cost ($)

14 - Replace HPI pump cooling IE: Modify fault trees for all three makeup 17 8

alignment valves with MOVs pumps to include alignment of alternative

cooling sources NSCCW and DHCCW from

the MCR. 630K 1.73M 3.15M

EF: Eliminate all risk from floods below 305' -0 -0

msl.

15 - Automatic swap to IE: Reduce the probabilities of failure to 5 3

recirculation mode swap over from injection to recirculation

mode within one minute and within ten

minutes to 1.0E-05, and set corresponding

JHEP to 0. 210K 576K 450K

EF: Eliminate all manual recirculation 0 0

failures for floods between 305' and 310'

msl when flood gates are correctly

installed and for floods below 305' msl.

16 - Automate HPI injection on IE: Reduce the probability of failure to 6 26

low pressurizer level initiate HPI to 1.OE-04, and set

corresponding JHEPs to 0.

1.8M 4.8M I.1M

EF: Reduce the risk for floods below 305' 0 0

msl by the same percent reduction as the

internal events CDF.

17 - Auto isolate steam generators IE: Reduce the probability of failure to isolate 1 1 on high steam line flow the steam generators by a factor of 10, and

set corresponding JHEP to 0. 55K 150K 950K

EF: Does not mitigate external flooding 0 0

scenarios.

18 - Provide the capability to align IE: Reduce the probability of failure to align 2 -0

NUREG-1437, Supplement 37 F-26 June 2009
Appendix F

% Risk Reduction(b) Total Benefit(c) ($)

(d) CDF Population Baseline Baseline With

SAMA Assumptions Dose Uncertainty Cost ($)

the standby battery charger and the the standby battery charger by a factor of 10. 32K 89K 1OOK

IN1B DC cross-tie from the MCR

EF: Eliminate all manual battery charger 0 -0

alignment failures for floods between 305'

and 310' msl when flood gates are correctly

installed. Reduce the risk for floods below

305' msl by the same percent reduction as

the internal events CDF.

19 - Install battery backed IE: Modify fault tree for early containment 0 11

hydrogen igniters or a passive failures to represent addition of a

hydrogen ignition system hydrogen ignition system with an

unavailability of 0.01 in all sequences,

including LOOP and SBO scenarios.

3.4M 9.4M 760K

EF: For all floods with successful 0 18

containment isolation, reduce early

containment failure by the same

percentage as for internal events, and

reassign to late containment failure.

20 - Extend the high pressure IE: Completely eliminate all ISLOCA events. 1 3

boundary through DHR valve DH- 190K 520K 3.OM

V-3 for ISLOCA isolation EF: Does not mitigate external flooding 0 0

scenarios.

21 - Install concrete shields to IE: Reassign early containment failures 0 3

block direct pathways from the due to liner melt-thru to either basemat

reactor pressure vessel (RPV) to failure (75 percent of events) or intact

the containment wall, and/or containment (25 percent of events).

initiate containment flooding 1.3M 3.6M 1.2M

early in external flooding EF: Reassign early containment failures 0 7

scenarios due to liner melt-thru to either basemat

failure or intact containment depending on

availability of containment spray in

June 2009 F-27 NUREG-1437, Supplement 37
Appendix F

% Risk Reduction(b) Total Benefit(c) ($)

SAMA (d) CDF Population Baseline Baseline With

Assumptions Dose Uncertainty Cost ($)

specific flood sequence.

22 - Install an independent EFW IE: Modify fault trees to include the 6 17

system independent EFW system.

1.4M 3.8M 5.OM

EF: Eliminate all risk from floods below 305' -0 -0

msl.

23 - Develop alarm response IE: Reduce the probability of failure to 0 1

procedures to direct operation of open MOV RR-V-5 by a factor of 10.

RR-V-5 on low reactor building

emergency cooling (RBEC) flow EF: Reduce the population dose risk and 0 0 32K 89K 50K

annual offsite economic cost risk for

LOOP scenarios for floods below 305' msl

by the same percent reduction as for

internal events.

24 - Install damage resistant IE: Same as SAMA 2. In addition, 53 55

high temperature RCP seals, a completely eliminate failure of the TD EFW

diesel engine as an alternate pump to operate.

drive for an EFW pump, and a 4.7M 13M 8.4M

portable 480V AC generator for EF: Eliminate all SBO events for floods 5 6

extended EFW operations between 305' and 310' msl when flood

gates are correctly installed; eliminate all

risk from floods below 305' msl.

25 - Install an additional EDG IE: Eliminate all failures of the SBO EDG. 9 9

EF: Eliminate all risk for floods between 305' 5 6 1.6M 4.3M 6.OM

and 310' msl when flood gates are correctly

installed and from all floods below 305' msl.

26- Reroute cables so that they FE: Eliminate all cable damage due to fire 13 13

do not pass over ignition in fire zone CB-FA-2E. 400K 1.1M 900K

sources in fire zone CB-FA-2E

NUREG-1437, Supplement 37 F-28 June 2009
Appendix F

% Risk Reduction(b) Total Benefit(c) ($)

(d) CDF Population Baseline Baseline With

SAMA Assumptions Dose Uncertainty Cost ($)

(West Inverter Room) or wrap EF: Does not mitigate external flooding 0 0

them in fire proof material scenarios.

27 - Improve the 480V AC load SE: Reduce failure probabilities for 480V NOT NOT

center welds AC load centers IP, IR, IS, and IT to ESTIMATED ESTIMATED

those corresponding to a HCLPF of 0.30g. I.4M 3.9M 580K

EF: Does not mitigate external flooding 0 0

scenarios.

28 - Improve the decay heat SE: Reduce failure probabilities for decay NOT NOT

service cooler (DC-C-2A/B) heat service coolers to those corresponding ESTIMATED ESTIMATED

anchorages to a HCLPF of 0.30g. 51K 140K 580K

EF: Does not mitigate external flooding 0 0

scenarios.

29 - Replace EDG ground resistors SE: Eliminate all failures of the EDG ground NOT NOT

resistors. ESTIMATED ESTIMATED

28K 76K 800K

EF: Does not mitigate external flooding 0 0

_scenarios.

30 - Improve diesel fire pump fuel SE: Eliminate all failures of the FSW system NOT NOT

oil tank and battery rack supports supports. ESTIMATED ESTIMATED

28K 76K 150K

EF: Does not mitigate external flooding 0 0

scenarios.

31 - Modify specific containment The estimated cost is greater than the entire NOT ESTIMATED 4.1 M

penetration MOVs to fail closed seismic MACR.

32 - Pre-stage severe external IE: Does not mitigate internal events 0 0 14M 39M

flooding equipment scenarios. 1.7M

June 2009 F-29 NUREG-1437, Supplement 37
Appendix F

% Risk Reduction(b) Total Benefit(c) ($)

AiCDF Population Baseline Baseline With

SAMA Assumptions Dose Uncertainty Cost ($)

EF: For floods > 310' msl, reduce the 84 84

probability of failure to implement the

external flooding measures to I.QE-02 and

reduce the probability of failure to provide

flood-resistant AC power to 2.OE-02. For

floods between 305' and 310' msl, reduce

the probability of failure to implement the

severe flooding measures to 0.14.

33 - Increase the flood IE: Does not mitigate internal events 0 0

protection height scenarios.

EF: For floods > 310' msl, use same 61 59 9.8M 27M 2.7M

failure probability for installing flood

doors as used for the 305' to 310' msl

floods. _

(a) SAMAs in bold are potentially cost-beneficial.

(b) First risk reduction value reflects results of changes made to the internal events PRA model and second risk reduction value reflects results of

changes made to the external flooding PRA model (AmerGen 2008a).

(c) Estimated benefits reflect revised values provided after correction of SECPOP2000 errors, as reported in Section E.7.6.5 of the ER (AmerGen

2008a). Reported benefit values account for risk reduction in internal events, external floods, and other external events, including fire and

seismic events.

(d) IE: internal events; EF: extemal flooding events; FE: fire events; SE: seismic events.

(e) Analysis and results for risk reduction estimates provided in response to NRC staff RAI 6.i (AmerGen 2008b).

(f) Values estimated by NRC staff using data available in the ER (AmerGen 2008a) and provided in response to RAls (AmerGen 2008b).

(g) Analysis and results for risk reduction estimates provided in response to NRC staff RAI 6.f (AmerGen 2008b).

NUREG-1437, Supplement 37 F-30 June 2009
F.5 Cost Impacts of Candidate Plant Improvements

Exelon Generation estimated the costs of implementing the 33 candidate SAMAs through the

application of engineering judgment and use of other licensees' estimates for similar

improvements. The cost estimates conservatively did not include the cost of replacement power

during extended outages required to implement the modifications, nor did they generally include

contingency costs associated with unforeseen implementation obstacles (AmerGen 2008a,

AmerGen 2008b). The cost estimates provided in the ER did not account for inflation, which is

considered another conservatism.

The NRC staff reviewed the bases for the applicant's cost estimates (presented in Section E.6

of Attachment E to the ER). For certain improvements, the NRC staff also compared the cost

estimates to estimates developed elsewhere for similar improvements, including estimates

developed as part of other licensees' analyses of SAMAs for operating reactors and advanced

light-water reactors. In response to an RAI requesting a more detailed description of the

changes associated with SAMAs 1, 2, 3, 5, 6, 10, 11, 14, 15, 20, 21, 26, 27, 29, 29, 31, 32, and

33, Exelon Generation provided additional information detailing the analysis and plant

modifications included in the cost estimate of each improvement (AmerGen 2008b). The staff

reviewed the costs and found them to be reasonable, and generally consistent with estimates

provided in support of other plants' analyses.

The NRC staff requested additional clarification on the estimated cost of $950,000 for

implementation of SAMAs 13 and 17 and $1,100,000 for implementation of SAMA 16, which

seem high for what appear to be just logic changes (NRC 2008a). In response to the RAI,

Exelon Generation further described these modifications as involving the design, procurement,

and installation of hardware, simulator modifications, and changes to procedures and training

(AmerGen 2008b). Based on this additional information, the NRC staff considers these

estimated costs to be reasonable and acceptable for purposes of the SAMA evaluation.

The NRC staff concludes that the cost estimates provided by Exelon Generation are sufficient

and appropriate for use in the SAMA evaluation.

F.6 Cost-Benefit Comparison

Exelon Generation's cost-benefit analysis and the NRC staffs review are described in the

following sections.

F.6.1 Exelon Generation's Evaluation

The methodology used by Exelon Generation was based primarily on NRC's guidance for

performing

cost-benefit analysis, i.e., NUREG/BR-0184, Regulatory Analysis Technical Evaluation

Handbook (NRC 1997a). The guidance involves determining the net value for each SAMA

according to the following formula:

Net Value = (APE + AOC + AOE + AOSC) - COE where,

June 2009 F-31 NUREG-1437, Supplement 37
Appendix F

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 0nsite costs Cs)

COE = cost of enhancement ($).

If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the

benefit associated with the SAMA and it is not considered cost-beneficial. Exelon Generation's

derivation of each of the associated costs is summarized below.

NUREG/BR-0058 has recently been revised to reflect the agency's policy on discount rates.

Revision 4 of NUREG/BR-0058 states that two sets of estimates should be developed, one at 3

percent and one at 7 percent (NRC 2004a). Exelon Generation performed the SAMA analysis

using only a 3 percent discount rate (AmerGen 2008a) and based its decisions on potentially

cost-beneficial SAMAs on these values.

Averted Public Exposure (APE) Costs

The APE costs were calculated using the following formula:

APE = Annual reduction in public exposure (A person-rem per year)

x monetary equivalent of unit dose ($2000 per person-rem)

x present value conversion factor (15.04 based on a 20-year period with a

3-percent discount rate).

As stated in NUREG/BR-0184 (NRC 1997a), it is important to note that the monetary value of

the public health risk after discounting does not represent the expected reduction in public

health risk due to a single accident. Rather, it is the present value of a stream of potential

losses extending over the remaining lifetime (in this case, the renewal period) of the facility.

Thus, it reflects the expected annual loss due to a single accident, the possibility that such an

accident could occur at any time over the renewal period, and the effect of discounting these

potential future losses to present value. For the purposes of initial screening, which assumes

elimination of all severe accidents due to internal and external flooding events, Exelon

Generation calculated an APE of approximately $972,000 for internal events and $5,290,000 for

external flooding events for the 20-year license renewal period (AmerGen 2008b).

Averted Offsite Property Damage Costs (AOC)

The AOCs were calculated using the following formula:

AOC = Annual CDF reduction

x offsite economic costs associated with a severe accident (on a per-event basis)

x present value conversion factor.

For the purposes of initial screening, which assumes all severe accidents due to internal and

I external flooding events are eliminated, Exelon Generation calculated an annual offsite

NUREG-1437, Supplement 37 F-32 June 2009
Appendix F

economic risk of about $129,000 for internal events and $620,000 for external flooding events

based on the Level 3 risk analysis. This results in a discounted value of approximately

$1,940,000 for internal events and $9,320,000 for external flooding events for the 20-year

license renewal period (AmerGen 2008b).

Averted Occupational Exposure (AOE) Costs

The AOE costs were calculated using the following formula:

AOE = Annual CDF reduction

x occupational exposure per core damage event

x monetary equivalent of unit dose

x present value conversion factor.

Exelon Generation derived the values for averted occupational exposure from information

provided in Section 5.7.3 of the regulatory analysis handbook (NRC 1997a). Best estimate

values provided for immediate occupational dose (3300 person-rem) and long-term

occupational dose (20,000 person-rem over a 10-year cleanup period) were used. The present

value of these doses was calculated using the equations provided in the handbook in

conjunction with a monetary equivalent of unit dose of $2000 per person-rem, a real discount

rate of 3 percent, and a time period of 20 years to represent the license renewal period. For the

purposes of initial screening, which assumes all severe accidents due to internal and external

flooding events are eliminated, Exelon Generation calculated an AOE of approximately $15,000

for internal events and $50,000 for external flooding events for the 20-year license renewal

period (AmerGen 2008b).

Averted Onsite Costs

Averted onsite costs (AOSC) include averted cleanup and decontamination costs and averted

power replacement costs. Repair and refurbishment costs are considered for recoverable

accidents only and not for severe accidents. Exelon Generation derived the values for AOSC

based on information provided in Section 5.7.6 of NUREG/BR-0184, the regulatory analysis

handbook (NRC 1997a).

Exelon Generation divided this cost element into two parts - the onsite cleanup and

decontamination cost, also commonly referred to as averted cleanup and decontamination

costs, and the replacement power cost.

Averted cleanup and decontamination costs (ACC) were calculated using the following formula:

ACC = Annual CDF reduction

x present value of cleanup costs per core damage event

x present value conversion factor.

The total cost of cleanup and decontamination subsequent to a severe accident is estimated in

the regulatory analysis handbook to be $1.5 x 109 (undiscounted). This value was converted to

present costs over a 10-year cleanup period and integrated over the term of the proposed

license extension. For the purposes of initial screening, which assumes all severe accidents

due to internal and external flooding events are eliminated, Exelon Generation calculated an

June 2009 F-33 NUREG-1437, Supplement 37
Appendix F

ACC of approximately $462,000 for internal events and $1,580,000 for external flooding events

for the 20-year license renewal period (AmerGen 2008b).

Long-term replacement power costs (RPC) were calculated using the following formula:

RPC = Annual CDF reduction

x present value of replacement power for a single event

x factor to account for remaining service years for which replacement power is

required

x reactor power scaling factor

I Exelon Generation based its calculations on the value of 875 megawatt electric (MWe).

Therefore, Exelon Generation applied a power scaling factor of 875/910 (the ratio of the actual

power level to the "generic" plant power level in NUREG/BR-0184) to determine the

replacement power costs. For the purposes of initial screening, which assumes all severe

I accidents due to internal and external flooding events are eliminated, Exelon Generation

calculated an RPC of approximately $126,000 for internal events and $431,000 for external

flooding events for the 20-year license renewal period (AmerGen 2008b). For the purposes of

initial screening, which assumes all severe accidents due to internal and external flooding

I events are eliminated, Exelon Generation calculated the AOSC to be approximately $588,000

for internal events and $2,010,000 for external flooding events for the 20-year license renewal

period.

I Using the above equations, Exelon Generation estimated the total present dollar value

equivalent associated with completely eliminating severe accidents from internal and external

flooding events at TMI-1 to be about $3.5M and $16.7M, respectively, for a total of $20.2M. Use

of a multiplier of 2 to the internal events benefits (to account for external events other than

external flooding events) increases the value to $23.7M and represents the dollar value

associated with completely eliminating all internal and external event severe accident risk at

TMI-1, also referred to as the Modified Maximum Averted Cost Risk (MMACR).

Exelon Generation's Results

If the implementation costs for a candidate SAMA exceeded the calculated benefit, the SAMA

was considered not to be cost-beneficial. In the baseline analysis contained in the ER (using a

I 3 percent discount rate), Exelon Generation identified nine potentially cost-beneficial SAMAs.

The potentially cost-beneficial SAMAs are:

* SAMA 8 - Automate reactor coolant pump trip on high motor bearing cooling

temperature.

* SAMA 11 - Enhance extreme external flooding mitigation equipment to address SBO

and loss of RCP seal cooling scenarios.

* SAMA 12 - Use the decay heat removal (DHR) system as an alternate suction source

for HPI.

* SAMA 16 -Automate HPI injection on low pressurizer level.

" SAMA 19 - Install battery backed hydrogen igniters or a passive hydrogen ignition

system.

NUREG-1437, Supplement 37 F-34 June 2009
Appendix F

* SAMA 21 - Install concrete shields to block direct pathways from the reactor pressure

vessel (RPV) to the containment wall and/or direct containment flooding early in external

flooding scenarios.

* SAMA 27 - Improve the 480V AC load center welds.

* SAMA 32 - Pre-stage severe external flooding equipment.

* SAMA 33 - Increase the flood protection height.

Exelon Generation performed additional analyses to evaluate the impact of parameter choices

and uncertainties on the results of the SAMA assessment (AmerGen 2008a). If the benefits are

increased by a factor of 2.75 to account for uncertainties, six additional SAMA candidates were

determined to be potentially cost-beneficial:

* SAMA 2 - Install damage-resistant high temperature RCP seals with a portable 480V

AC generator for extended EFW operation.

* SAMA 7 - Use fire service water as an alternate cooling source for the intermediate

closed cooling water (ICCW) heat exchangers.

* SAMA 15 - Automate swap to recirculation mode.

• .. SAMA 23- Develop alarm response procedures-to direct operation of RR-V-5 on low--

reactor building emergency cooling (RBEC) flow.

' SAMA 24 - Install damage resistant high temperature RCP seals with a diesel engine as

an alternate drive for an EFW pump and a portable 480V AC generator for extendedEFW operation.

* SAMA 26 - Reroute cables so that they do not pass over ignition sources in fire zone

CB-FA-2e or wrap them in fire proof material.

These results, and the population dose and SAMA benefit estimates reported in the present

document (e.g., in Tables F-2 and F-5), reflect corrections to previously identified SECPOP2000

errors (AmerGen 2008a, AmerGen 2008b).

Exelon Generation also performed a sensitivity analysis of SAMA 10, automate BWST refill,

assuming the current manual BWST refill capability only delayed core damage, not prevented

core damage as assumed in the baseline analysis (AmerGen 2008a). Based on this sensitivity

analysis, SAMA 10 was determined to be potentially cost-beneficial.

In response to an RAI, Exelon Generation provided a sensitivity analysis of SAMAs 13 and 22

also assuming manual BWST refill capability only delayed, not prevented, core damage

(AmerGen 2008b). The sensitivity analysis resulted in identification of SAMA 13 being

potentially cost-beneficial.

The potentially cost-beneficial SAMAs, and Exelon Generation's plans for further evaluation of

these SAMAs are discussed in more detail in Section F.6.2.

F.6.2 Review of Exelon Generation's Cost-Benefit Evaluation

The cost-benefit analysis performed by Exelon Generation was based primarily on NUREG/BR0184

June 2009 F-35 NUREG-1437, Supplement 37
Appendix F

(NRC 1997a) and was executed consistent with this guidance.

NUREG/BR-0058 has recently been revised to reflect the agency's policy on discount rates.

Revision 4 of NUREG/BR-0058 states that two sets of estimates should be developed, one at 3

I percent and one at 7 percent (NRC 2004a). Exelon Generation performed the SAMA analysis

using only a 3 percent discount rate (AmerGen 2008a) and based its decisions on potentially

cost-beneficial SAMAs on these values. SAMA benefits produced using a 3 percent discount

rate are greater than those produced using a 7 percent discount rate, and would tend to result in

identification of a greater number of potentially cost-beneficial SAMAs. Since use of a 3 percent

discount rate is conservative, the NRC staff concludes that use of only a 3 percent discount rate

in the cost-benefit analysis is acceptable for the purposes of the SAMA evaluation.

SAMAs identified primarily on the basis of the internal events analysis could prOvide benefits in

certain external events, in addition to their benefits in internal events. To account for the

I additional benefits in external events, Exelon Generation: (1) multiplied the internal event

benefits by a factor of two for each SAMA, except those SAMAs that specifically address fire

and seismic risk (SAMAs 26 through 31), and (2) separately estimated the benefits of reducing

the risk of external floods for each SAMA using the external flooding risk model and an

approach similar to that for internal events. Doubling the internal event estimate for SAMAs-26

through 31, or including a benefit for reducing external flooding risk would not be appropriate

because these SAMAs are specific to fire and seismic risks and would not have a corresponding

benefit on the risk from internal or external flooding events.

I The NRC staff notes that using Exelon Generation's adjusted seismic and fire CDF values, the

total CDF for non-flooding external events (4.56 x 10-5 per year) is approximately twice the

internal events CDF. This would suggest that the internal events benefits be tripled rather than

doubled to account for additional SAMA benefits in external events. However, there are several

considerations that support the use of a lower external events multiplier, as summarized below.

* The external event CDF may be lower due to remaining conservatisms in the analysis.

The seismic, fire, and high winds analyses were performed in support of the IPEEE, well

before the current TMI-1 internal events PRA, and vary in their degree of completeness

and conservatism. The general trend in PRA development since the IPEEE has been to

remove conservative modeling practices as better techniques for assessing risk are

developed. Recognizing the level of conservatism in the earlier analyses and the fact

that seismic improvements implemented since the IPEEE are not accounted for in the

seismic CDF, the NRC staff agrees with Exelon Generation's claim that the CDF for nonflooding external events would likely be lower than reported above.

* The significance of the external events multiplier is diminished by separate quantification

of SAMA benefits in external floods and by consideration of additional SAMAs targeted

specifically to seismic and fire events. Exelon Generation separately assessed the

benefits that internal events-related SAMAs would provide in external flooding events

(which are the largest risk contributors at TMI-1), and separately quantified the benefits

of seismic- and fire-related SAMAs. The external events multiplier reflects only the

additional benefits that internal events-related SAMAs provide in seismic and fire events.

Use of an external events multiplier implicitly assumes that each SAMA would offer the

same percentage reduction in external event CDF and population dose as it offers in

NUREG-1437, Supplement 37 F-36 June 2009
Appendix F

internal events. However, internal events-related SAMAs would likely have smaller

benefits in seismic and fire events than in internal events, and smaller benefits than

external event-related SAMAs would have in external events. Thus, the use of a

somewhat lower external events multiplier is reasonable.

* The benefits of additional SAMAs would be reduced by implementation of the currently

identified cost-beneficial SAMAs. Exelon Generation evaluated the impact on the SAMA

results if the estimated total benefits (internal and external events) were increased by a

factor of 2.75, and included any additional potentially cost-beneficial SAMAs identified in

this analysis within the set of SAMAs that they intend to examine further for

implementation. Exelon Generation's SAMA analysis resulted in identification of 17

potentially cost-beneficial SAMAs in seven unique categories. Although use of a higher

external events multiplier (in the baseline and uncertainty analyses) might result in

identification of additional potentially cost-beneficial SAMAs, the currently identified

SAMAs would have a greater net value, and implementation of the most cost-effective

SAMAs from the set of 17 would likely reduce the benefits of any additional SAMAs to

the degree that they are no longer cost beneficial.

In consideration of the above factors, the NRC staff concludes that Exelon Generation's use of a

multiplier of two in evaluating internal event-related SAMAs is reasonable for the purposes of

the SAMA evaluation.

The NRC staff notes that of the nine SAMAs determined to be cost-beneficial in the baseline

analysis, two of these, SAMAs 19 and 21, improve containment performance but do not impact

CDF, and that similar SAMAs have not been found to be cost-beneficial in previous SAMA

evaluations for PWR plants. As with previously evaluated PWR plants, these SAMAs also

would not be cost-beneficial if just considering the benefit associated with internal events risk

reduction (and multiplier accounting for non-flooding external events); the significant additional

benefit associated with reduction of external flooding risk makes these SAMAs cost-beneficial at

TMI-1. The relatively high estimated benefits for these SAMAs are the result of early

containment failure due to SBO events caused by external flooding. The NRC staff found the

evaluation of these SAMAs to be reasonable.

Exelon Generation considered the impact that possible increases in benefits from analysis

uncertainties would have on the results of the SAMA assessment. In the ER, Exelon

Generation presents the results of an uncertainty analysis of the internal events CDF which

indicates that the 95th percentile value is a factor of 2.75 times the point estimate CDF. Exelon

Generation considered whether any additional Phase I SAMAs might be retained for further

analysis if the benefits (and MMACR) were increased by a factor of 2.75. However, since no

SAMAs were screened from further analysis during the Phase I screening, the use of the 95t'

percentile CDF has no impact on the Phase I analysis.

Exelon Generation also considered the impact on the Phase II screening if the estimated

benefits were increased by a factor of 2.75 (in addition to the multiplier of 2 for external events

other than external floods). Six additional SAMAs became cost-beneficial in Exelon

Generation's analysis (SAMAs 2, 7, 15, 23, 24, and 26, as described above). Although not costJune 2009 F-37 NUREG-1437, Supplement 37
Appendix F

I beneficial in the baseline analysis, Exelon Generation included these six SAMAs within the set

of potentially cost-beneficial SAMAs that they intend to examine further for implementation.

Exelon Generation did not develop a cost-risk analysis for three Phase II SAMAs:

* SAMA 4 - Provide alternate power to HPI pump minimum flow recirculation valves MUV-36 and MU-V-37,

" SAMA 9 - Proceduralize local ADV operation, and

* SAMA 31 - Modify specific containment penetration MOVs to fail closed.

I In the ER, Exelon Generation noted that the only events that could cause the valves in SAMA 4

to be "stranded closed" are those in which power was available to close the valves when

directed by an engineered safeguards actuation signal (ESAS) and then power was lost before

the valves could be re-opened prior to failure of the HPI pumps, which corresponds to an

I available time of 45 minutes out of 24 hours. To address this issue, Exelon Generation modified

the fault tree to include a new basic event representing the fraction of time available to re-open

I the valves. For SAMA 9, Exelon Generation noted that TMI-1 already has procedures to

perform local ADV operations that are not credited in the PRA model. To address this issue,

I Exelon Generation assigned a human error probability of 0.1 for the basic event representing

local ADV operation. For both SAMAs 4 and 9, Exelon Generation's analysis showed that both

the CDF and LERF based RRW for the basic events is below the review cutoff of 1.01 for

I identifying and assessing SAMAs. For SAMA 31, Exelon Generation noted the estimated cost

to replace existing isolation valves with "fail closed" AOVs was greater than the maximum

averted cost risk for seismic events. The benefits of these SAMAs were therefore not

evaluated. The NRC staff found this rationale to be reasonable.

Exelon Generation also provided the results of additional sensitivity analyses in the ER,

including variations in'MACCS2 input assumptions, assumptions regarding BWST refill

capability and extreme flooding mitigation capability, and the impact of implementing SAMA 32

.(pre-stage severe external flooding equipment) on the other potentially cost-beneficial SAMAs.

The analyses of the variation in MACCS2 input assumptions and extreme flooding mitigation

capability assumptions did not identify any additional potentially cost-beneficial SAMAs beyond

those already identified through the uncertainty analysis.

The baseline SAMA analysis contained in the ER assumes that manual BWST refill is capable

I of preventing core damage for SGTR events at TMI-1. Exelon Generation indicated in the ER

that the validity of this assumption has recently been called into question, and therefore included

in the ER an additional evaluation of SAMA 10 assuming the current capability only delayed, not

prevented, core damage (AmerGen 2008a). Based on these results, SAMA 10 was determined

to be potentially cost-beneficial, but was not included among the set of potentially cost-beneficial

SAMAs identified in the ER. In response to an NRC staff request for clarification regarding

I Exelon Generation's plans for enhancement of the BWST refill capability, the licensee indicated

that the SAMA process, in conjunction with other plant analyses, has identified the limited

BWST refill capability as a potential area for improvement at TMI-1, and that this issue has been

I captured in the TMI-1 Corrective Action Program. Exelon Generation further stated that while

the SAMA analysis does not explicitly evaluate the costs and benefits associated with only

NUREG-1437, Supplement 37 F-38 June 2009
Appendix F

enhancing the existing manual capability, this potential option will be considered further in

conjunction with the automation of the BWST refill function, i.e., SAMA 10 (AmerGen 2008b).

The NRC staff asked the licensee to identify and re-assess any other SAMAs that may be

impacted by the BWST manual refill capability assumption (NRC 2008a). In their response to

the RAI, Exelon Generation stated that only those SAMAs that significantly impacted SGTR

frequency would be impacted by this assumption, specifically SAMAs 2, 11, 13, 16, 22, and 24.

Of these, SAMAs 2, 11, 16, and 24 were already identified as being potentially cost-beneficial

and were. not evaluated further. Exelon Generation re-assessed the benefits of SAMAs 13 and'

22 assuming the current BWST refill capability only delayed, not prevented, core damage.

Based on this re-assessmentSAMA 13, change IA system logic to automatically start IA-P-1A/B

after a low voltage trip in conjunction with an ESAS, would be potentially cost-beneficial

(AmerGen 2008b).

The NRC staff notes that given the impact of BWST refill capability on the estimated benefits for

many of these potentially cost-beneficial SAMAs, it would be prudent for Exelon Generation to

either resolve the BWST issue prior to performing the more detailed evaluation of these SAMAs,

or to conservatively assume that the current manual BWST refill capability is not effective when

evaluating the potentially cost-beneficial SAMAs for implementation. . -. . . 7

In summary, the NRC staff notes that the 15 potentially cost-beneficial SAMAs (SAMAs 2, 7, 8,

11, 12, 15, 16, 19, 21, 23, 24, 26, 27, 32, and 33) identified in either Exelon Generation's

baseline analysis, or uncertainty analysis, are included within the set of SAMAs that Exelon

Generation will consider further for implementation (AmerGen 2008a). In response to an RAI by

the NRC staff (NRC 2008a), Exelon Generation stated that SAMAs 10 and 13 would also be

included within the set of SAMAs to be considered for implementation (NRC 2008b).

In the ER, Exelon Generation evaluated the impact of implementing SAMA 32, pre-stage severe

external flooding equipment, on the benefitestimate for the other potentially cost-beneficial

SAMAs. Since SAMA 32 addresses external flooding risk only, implementing this SAMA has no

effect on the internal events model and associated benefit results for the other cost-beneficial

SAMAs, nor does it have any affect on non-external flooding external events and those SAMAs

identified to specifically address seismic and fire risk. This sensitivity analysis was performed

for the baseline case assumptions with uncertainty (the most conservative case) and resulted in

one previously identified potentially cost-beneficial SAMA, SAMA 21, no longer being costbeneficial.

In light of the many potentially cost-beneficial SAMAs identified in the ER,the NRC staff asked

Exelon Generation to identify those SAMAs having higher priority for being considered for

implementation based on risk reduction potential and implementation cost, and which SAMAs

would no longer be cost-beneficial if these higher priority SAMAs were implemented (NRC

2008a). In response to the RAI (AmerGen 2008b), Exelon Generation performed a qualitative

assessment to prioritize the cost-beneficial SAMAs into a "minimal SAMA set" addressing the

most significant risk contributors. Those SAMAs determined to have the most cost-effective risk

reduction potential for each of the major risk areas defined the "minimal SAMA set." Other costbeneficial SAMAs were assigned to the "minimal SAMA set" category best representing the risk

contributors each is mitigating. Exelon Generation determined that SAMAs 32 and 2 would

have the highest priority based on their potential for significant reduction in risk (and relatively

low implementation cost in the case of SAMA 32). Exelon Generation further identified SAMAs

June 2009 F-39 NUREG-1437, Supplement 37
Appendix F

12, 15, 16, 26, and 27 as a second tier priority based on their mitigation of plant risk contributors

not addressed by SAMAs 32 and 2. The remaining cost-beneficial SAMAs were grouped into

one of these seven high priority groups. The impact of these remaining potentially costbeneficial SAMAs is expected to be reduced significantly if the higher priority SAMAs are

implemented. The NRC considers this approach for prioritizing SAMAs to be reasonable.

The NRC staff concludes that, with the exception of the potentially cost-beneficial SAMAs

discussed above, the costs of the other SAMAs evaluated would be higher than the associated

benefits.

F.7 Conclusions

I Exelon Generation compiled a list of 33 SAMAs based on a review of the most significant basic

events from the plant-specific PRA, insights from the plant-specific IPE and IPEEE, Phase II

SAMAs from license renewal applications for other plants, and review of other NRC and industry

documentation. An initial screening was performed to remove SAMA candidates that (1) were

not applicable at TMI-1 due to design differences or (2) had estimated costs that would exceed

the dollar value associated with completely eliminating all severe accident risk at TMI-1. Based

on this screening, no SAMAs were eliminated leaving all 33 candidate SAMAs for evaluation.

For the remaining SAMA candidates, a more detailed evaluation was performed as shown in

Table F-6. The cost-benefit analyses showed that nine of the SAMA candidates were

potentially cost-beneficial in the baseline analysis (SAMAs 8, 11, 12, 16, 19, 21, 27, 32, and 33).

Exelon Generation performed additional analyses to evaluate the impact of parameter choices

and uncertainties on the results of the SAMA assessment. As a result, six additional SAMAs

(SAMAs 2, 7, 15, 23, 24, and 26) were identified as potentially cost-beneficial. Exelon

Generation further identified SAMA 10 as being potentially cost-beneficial based on the results

of a sensitivity analysis. In addition, as a result of the NRC staff review, Exelon Generation

concluded that SAMA 13 was also potentially cost-beneficial. Exelon Generation has indicated

that all of these SAMAs (SAMAs 2, 7, 8, 10, 11, 12, 13, 15, 16, 19, 21, 23, 24, 26, 27, 32, and

33) will be considered further for implementation.

I The NRC staff reviewed the Exelon Generation analysis and concludes that the methods used

and the implementation of those methods were sound. The treatment of SAMA benefits and

I costs support the general conclusion that the SAMA evaluations performed by Exelon

Generation are reasonable and sufficient for the license renewal submittal. Although the

treatment of SAMAs for external events was somewhat limited, the likelihood of there being

cost-beneficial enhancements in this area was minimized by improvements that have been

realized as a result of the IPEEE process, separate analysis of external flooding events, and

inclusion of a multiplier to account for external events.

I The NRC staff concurs with Exelon Generation's identification of areas in which risk can be

further reduced in a cost-beneficial manner through the implementation of the identified,

potentially cost-beneficial SAMAs. Given the potential for cost-beneficial risk reduction, the

I NRC staff agrees that further evaluation of these SAMAs by Exelon Generation is warranted.

However, these SAMAs do not relate to adequately managing the effects of aging during the

period of extended operation. Therefore, they need not be implemented as part of license

NUREG-1437, Supplement 37 F-40 June 2009
Appendix F

rehewal pursuant to Title 10 of the Code of Federal Regulations, Part 54.

F.8 References

AmerGen (AmerGen Energy Company, LLC). 2008a. "Three Mile Island Nuclear Station,

Applicant's Environmental Report, License Renewal Operating Stage." Kennett Square,

Pennsylvania. ADAMS Accession Nos. ML080220255, ML080220257, ML080220261, and

ML080220282.

AmerGen (AmerGen Energy Company, LLC). 2008b. Letter from Michael P. Gallagher,

AmerGen Energy Company, LLC, to U.S. Nuclear Regulatory Commission Document Control

Desk. Subject: "Response to NRC Request for Additional Information Related to Three Mile

Island Nuclear Station 1 License Renewal Application (TAC No. MD7702)," dated July 17, 2008.

ADAMS No. ML082040144.

ETI (Earth Tech, Inc.). 2003. "Evacuation Time Estimates for the Three Mile Island Station

Emergency Planning Zone". July 2003.

EPRI (Electric Power Research Institute). 1989. "Probabilistic Seismic Hazard Evaluation at

Nuclear Plant Sites in the Central and Eastern United States: Resolution of the Charleston

Issue," EPRI NP-6395-DI, Palo Alto, CA, April 1989.

Exelon (Exelon Corporation). 2007a. TMI PRA Notebook, TMI-PRA-014 Quantification

Notebook, TMI PRA Model 2004 Revision 2, May 2007.

Exelon (Exelon Corporation). 2007b. TMI PRA Notebook, TMI-PRA-015.2 Level 2 Containment

Event Tree Analysis Notebook, TMI PRA Model 2004 Revision 2, May 2007.

GPU (GPU Nuclear Corporation). 1993. Letter from T. G. Broughton, GPU, to U.S. NRC.

Subject: Three Mile Island Nuclear Generation Station, Unit 1 (TMI-1), Operating License No.

DPR-50, Docket No. 50-289, Response to Generic Letter 88-20, "Individual Plan Examinations

for Severe Accident Vulnerabilities (IPE)". May 20, 1993.

GPU (GPU Nuclear Corporation). 1994. Letter from R. W. Keaten, GPU, to U.S. NRC.

Subject: Three Mile Island Nuclear Generation Station, Unit 1 (TMI-1), Operating License No.

DPR-50, Docket No. 50-289, Response to Generic Letter 88-20, Supplement 4, "Individual Plan

Examination of External Events (IPEEE) for Severe Accident Vulnerabilities". December 29,

1994.

Kennedy, Robert P. 1999. "Overview of Methods for Seismic PRA and Margin Analysis

Including Recent Innovations". Proceedings of the OECD-NEA Workshop on Seismic Risk,

Tokyo, Japan, August 1999.

NRC (U.S. Nuclear Regulatory Commission). 1988. Generic Letter 88-20, "Individual Plant

Examination for Severe Accident Vulnerabilities," November 23, 1988.

NRC (U.S. Nuclear Regulatory Commission). 1990a. Evaluation of Severe Accident Risks:

Quantification of Major Input Parameters.,NUREGICR-4551, Vol. 2, Rev. 1, Part 7, Washington,

D.C.

June 2009 F-41 NUREG-1437, Supplement 37
Appendix F

NRC (U.S. Nuclear Regulatory Commission). 1990b. Severe Accident Risks: An Assessment

for Five U.S. Nuclear Power Plants. NUREG-1150, Washington, D.C.

NRC (U.S. Nuclear Regulatory Commission). 1991. "Procedural and Submittal Guidance for the

Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities,"

NUREG-1407, Washington, D.C, June 1991.

NRC (U.S. Nuclear Regulatory Commission). 1994. "Revised Livermore Seismic Hazard

Estimates for 69 Nuclear Power Plant Sites East of the Rocky Mountains," NUREG-1 488,

Washington, D.C., April 1994.

NRC (U.S. Nuclear Regulatory Commission). 1996. "Review of Three Mile Island, Unit 1,

Individual Plant Examination Submittal, (TAC No. M74480)," Washington, D.C., December 19,

1996.

NRC (U.S. Nuclear Regulatory Commission). 1997a. Regulatory Analysis Technical Evaluation

Handbook. NUREG/BR-0184, Washington, D.C.

NRC (U.S. Nuclear Regulatory Commission). 1997b. Individual Plant Examination Program:

Perspectives on Reactor Safety and Plant Performance. NUREG-1 560, Washington, D.C.

NRC (U.S. Nuclear Regulatory Commission). 1998a. Code Manual for MACCS2: User's

Guide. NUREG/CR-6613, Vol. 1, Washington, D.C.

NRC (U.S. Nuclear Regulatory Commission). 1998b. Common-Cause FailureParameter

Estimations. NUREG/CR-5497, Washington, D.C.

NRC (U.S. Nuclear Regulatory Commission). 1998c. "Safety Evaluation Report for USI A-46

Program Implementation at Three Mile Island Unit 1 (TAC No. M69486)," Washington, D.C.,

August 12, 1998.

NRC (U.S. Nuclear Regulatory Commission). 1999. "Review of Three Mile Island Nuclear

Station, Unit 1 (TMI-1) Individual Plant Examination of External Events (IPEEE) Submittal (TAC

Nos. M83685)," Washington, D.C., July 9, 1999.

NRC (U.S. Nuclear Regulatory Commission). 2003. SECPOP2000: Sector Population, Land

Fraction, and Economic Estimation Program. NUREG/CR-6525, Rev. 1, Washington, D.C.

NRC (U.S. Nuclear Regulatory Commission). 2004. Regulatory Analysis Guidelines of the U.S.

Nuclear Regulatory Commission. NUREG/BR-0058, Rev. 4, Washington, D.C.

NRC (U.S. Nuclear Regulatory Commission). 2008a. Letter from Sarah Lopas, U.S. NRC, to

Michael P. Gallagher, AmerGen Energy Company, LLC. Subject: "Request for Additional

Information Regarding Severe Accident Mitigation Alternatives for Three Mile Island Nuclear

Station Unit 1, License Renewal (TAC No. MD7702)," May 21, 2008. ADAMS No.

ML0811330714.

NRC (U.S. Nuclear Regulatory Commission). 2008b. Letter from Sarah Lopas, U.S. NRC, to

AmerGen Energy Company, LLC. Subject: "Summary of Conference Call with AmerGen

Energy Company, LLC, to Discuss Responses to Severe Accident Mitigation Alternatives

Request for Additional Information for Three Mile Island Nuclear Station Unit 1 (TAC No.

MD7702)," September 8, 2008. ADAMS No. ML082340226.

NUREG-1437, Supplement 37 F-42 June 2009
Appendix F

USDA (U.S. Department of Agriculture). 1998. "1997 Census of Agriculture," National

Agriculture Statistics Service, 1998. Available URL:

http://www.nass.usda.gov/census/census97/volumel/vol1 pubs.htm.

June 2009 F-43 NUREG-1437, Supplement 37

NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

(9-2004) (Assigned by NRC, Add Vol., Supp., Rev.,

NRCMD 3.7 and Addendum Numbers, If any.)

BIBLIOGRAPHIC DATA SHEET

(See instructions on the reverse) NUREG-1437, Supp. 37

2. TITLE AND SUBTITLE 3. DATE REPORT PUBLISHED.

Generic Environmental Impact Statement for License Renewal of Nuclear Plants MONTH YEAR

Supplement 37

Regarding Three Mile Island Nuclear Station, Unit 1 June 2009

Final Report 4. FIN OR GRANT NUMBER

5. AUTHOR(S) 6. TYPE OF REPORT

See Chapter 10 of report. Technical

7. PERIOD COVERED (Inclusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address; if contractor,

provide name and mailing address.)

Division of License Renewal

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

9. SPONSORING ORGANIZATION -NAME AND ADDRESS (if NRC, type "Same as above" if contractor, provide NRC Division, Office or Region, U.S. Nuclear Regulatory Commission,

and mailing address.)

Same as 8 above.

10. SUPPLEMENTARY NOTES

Docket No. 50-289

11. ABSTRACT (200 words or less)

This supplemental environmental impact statement (EIS) has been prepared in response to an application submitted by Exelon

Generation Company, LLC (Exelon Generation) to the Nuclear Regulatory Commission (NRC) to renew the operating license

for Three Mile Island Nuclear Station, Unit 1 (TMI-1), for an additional 20 years under 10 CFR Part 54. The supplemental EIS

includes the NRC's analysis that considers and weighs the environmental impacts of the proposed action, the environmental

impacts of alternatives to the proposed action, and mitigation measures for reducingor avoiding adverse impacts. It also

includes the NRC's recommendation regarding the proposed action.

The NRC has determined that the adverse environmental impacts of license renewal for TMI-1 are not so great that preserving

the option of license renewal for energy-planning decisionmakers would be unreasonable. This determination is based on (1)

the analysis and findings in the GELS; (2) the Environmental Report submitted by Exelon Generation;.(3) consultation with

Federal, State, and local agencies; (4) the NRC's staffs own independent review; and (5) the NRC staffs consideration of

public comments received during the scoping process and draft supplement EIS comment period.

12, KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.) 13. AVAILABILITY STATEMENT

Three Mile Island Nuclear Station, Unit 1 unlimited

TMI-1 14. SECURITY CLASSIFICATION

Three Mile Island (This Page)

Supplement to the Generic Environmental Impact Statement unclassified

GEIS (This Report)

National Environmental Policy Act unclassified

NEPA

License Renewal 15. NUMBER OF PAGES

NUREG-1437

16. PRICE

NRC FORM 335 (9-2004) PRINTED ON RECYCLED PAPER
Federal Recycling Program

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

OFFICIAL BUSINESS