U.S.NRCNUREG-1437

*U.S.N R CSupplement 39

United States Nuclear Regulatory Commission

Protecting People and the Environment

Generic Environmental

Impact Statement for

License Renewal of

Nuclear Plants

Supplement 39

Regarding

Prairie Island Nuclear

Generating Plant,

Units I and 2

Draft Report for Comment

Office of Nuclear Reactor Regulation
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* U.S.NRC Supplement NUREG-143739

United States Nuclear Regulatory Commission

Protecting People and the Environment

Generic Environmental

Impact Statement for

License Renewal of

Nuclear Plants

Supplement 39

Regarding

Prairie Island Nuclear

Generating Plant,

Units 1 and 2

Draft Report for Comment

Manuscript Completed: September 2009

Date Published: October 2009

Office of Nuclear Reactor Regulation

NUREG-1437, Supplement 39, has been

reproduced from the best available copy.
Proposed Action

Type of Statement

Agency Contact

Issuance of renewed operating licenses DPR-42 and DPR-60 for

Prairie Island Nuclear Generating Plant, Units 1 and 2, in the city

of Red Wing, Dakota County, Minnesota.

Draft Supplemental Environmental Impact Statement

Elaine Keegan

U.S. Nuclear Regulatory Commission

Office of Nuclear Reactor Regulation

Mail Stop 0-11 F1

Washington, D.C. 20555-0001

Phone: 301-415-8517

Email: Elaine.keegan@nrc.gov

Any interested party may submit comments on this supplemental

environmental impact statement. Please specify NUREG-1437,

Supplement 39, draft, in your comments. Comments must be

received by January 30, 2010. Comments received after the

expiration of the comment period will be considered if it is practical

to do so, but assurance of consideration of late comments will not

be given. Comments may be emailed to PrairielslandEIS@nrc.gov

or mailed to:

Chief, Rulemaking, Directives, and Editing Branch

U.S. Nuclear Regulatory Commission

Mail Stop T6-D59

Washington, D.C. 20555-0001

Comments

October 2009 Draft NUREG-1437, Supplement 39
Abstract

1 ABSTRACT

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

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

application submitted by Northern State Power Co. to renew the operating license for Prairie

Island Nuclear Generating Plant, Units 1 and 2 for an additional 20 years.

This draft supplemental environmental impact statement includes the preliminary analysis that

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

action. Alternatives considered include replacement power from new natural-gas-firedcombination cycle; combination including natural gas, wind, wood-fired generation; combination

including one PINGP 1 and 2 unit, natural gas, and wind; and not renewing the license (the noaction alternative).

The preliminary recommendation is that the Commission determine that the adverse

environmental impacts of license renewal for Prairie Island Nuclear Generating Plant, Units 1

and 2, are not so great that preserving the option of license renewal for energy-planning

decision makers would be unreasonable.

October 2009 iii Draft NUREG-1437, Supplement 39 A

Table of Contents

1 Table of Contents

2 ASTRACT .................................................................................................................................... iii

3 EXECUTIVE SUM MARY ....................................................................................................... xiii

4 ABBREVIATIONS AND ACRO NYM S ...................................................................... ................. xix

5 1.0 Purpose and Need for Action ......................................................................................... 1-1

6 1.1 Proposed Federal Action ........................................................................................... 1-1

7 1.2 Purpose and Need for the Proposed Federal Action ................................................... 1-1

8 1.3 Major Environmental Review M ilestones .................................................................... 1-2

9 1.4 Generic Environm ental Im pact Statement ................................................................... 1-3

10 1.5 Supplemental Environmental Im pact Statement ......................................................... 1-5

11 1.6 Cooperating Agencies .......................................... 1-6

12 1.7 Consultations .............................................................................................................. 1-6

13 1.8 Correspondence .......................................................................................................... 1-7

14 1.9 Status of Com pliance ................................................................................................ 1-11

15 1.10 References ............................................................................................... I ................. 1-12

16 2.0 Affected Environm ent .................................................................................................... 2-1

17 2.1 Facility Description ...................................................................................................... 2-1

18 2.1.1 Reactor and Containm ent Systems ....................................................................... 2-1

19 2.1.2 Radioactive W aste Managem ent ........................................................................... 2-2

20 2.1.2.1 Radioactive Liquid W aste ............................................................................... 2-3

21 2.1.2.2 Radioactive Gaseous W aste .......................................................................... 2-7

22 2.1.2.3 Solid Radioactive W aste ................................................................................ 2-7

23 2.1.3 Nonradiological W astes ......................................................................................... 2-8

24 2.1.3.1 Hazardous Waste ....................................... 2-9

25 2.1.3.2 Universal Waste ........................................ 2-9

26 2.1.3.3 Perm itted Discharges ................................................................................... 2-10

27 2.1.3.4 Pollution Prevention and W aste M inim ization .............................................. 2-10

28 2.1.4 Plant Operation and M aintenance ....................................................................... 2-10

29 2.1.5 Power Transm ission System ............................................................................... 2-11

30 2.1.6 Cooling and Auxiliary W ater System s ................................................................. 2-15

31 2.1.6.1 Intake Screenhouse and Fish Return .......................................................... 2-16

32 2.1.6.2 Discharge and Cooling Tower System ......................................................... 2-18

33 2.1.6.3 Requirements Under NPDES Perm it ........................................................... 2-18

34 2.1.7 Facility W ater Use and Quality ............................................................................ 2-22

35 2.1.7.1 Groundwater Use ........................................................................................ 2-22

36 2.1.7.2 Surface W ater Use....................................................................................... 2-23

37 2.1.7.3 Surface W ater Quality .................................................................................. 2-23

38 2.1.7.4 Dredging ........................................................................................................ 2-24

39 2.2 Affected Environm ent ................................................................................................ 2-24

40 2.2.1 Land Use ............................................................................................................. 2-24

41 2.2.2 Air and Meteorology ............................................................................................ 2-25

42 2.2.2.1 Clim ate and Meteorology ............................................................................. 2-25

43 2.2.2.2 Air Quality .......................................................................................................... 2-26

44 2.2.3 G roundwater Resources ...................................................................................... 2-26

45 2.2.3.1 PINGP 1 and 2 W ater Supply W ells ............................................................ 2-27

46 2.2.3.2 PINGP 1 and 2 Groundwater Monitoring ..................................................... 2-28

October 2009 V Draft NUREG-1437, Supplement 39
Table of Contents

1 2.2.4 Surface W ater Resources ................................................................................ 2-28

2 2.2.5 Description of Aquatic Resources ..................................................................... 2-30

3 2.2.6 Terrestrial Resources ........................................................................................ 2-33

4 2.2.7 Threatened and Endangered Species ............................................................... 2-35

5 2.2.7.1 Aquatic Species ......................................................................................... 2-35

6 2.2.7.2 Terrestrial Species .................................................................................... 2-40

7 2.2.8 Socioeconomic Factors ..................................................................................... 2-44

8 2.2.8.2 Housing ..................................................................................................... 2-46

9 2.2.8.3 Public Services .......................................................................................... 2-47

10 2.2.8.4 Offsite Land Use ........................................................................................ 2-50

11 2.2.8.5 Visual Aesthetics and Noise ....................................................................... 2-54

12 2.2.8.6 Demography .............................................................................................. 2-55

13 2.2.8.7 Economy .................................................................................................... 2-60

14 2.2.9 Historic and Archaeological Resources ............................................................ 2-65

15 2.2.9.1 Cultural Background .................................................................................. 2-65

16 2.2.9.2 Historic and Archaeological Resources ........................ 2-69

17 2.3 Related Federal and State Activities ....................................................................... 2-72

18 2.4 References ................... .......................................................................................... 2-72

19 3.0 Environmental Impacts of Refurbishment ..................................................................... 3-1

20 3.1 Refurbishment Activities at PINGP 1 and 2 ............................................................... 3-2

21 3.2 Environmental Impacts of Refurbishment ............................. 3-3

22 3.2.1 Terrestrial Resources - Refurbishment Impacts ................................................. 3-3

23 3.2.2 Threatened and Endangered Species ................................................................. 3-4

24 3.2.2.1 Terrestrial Species ....................................................................................... 3-4

25 3.2.2.2 Aquatic Species .... ............................... ..... 3-4

26 3.2.3 Air Quality During Refurbishment (Non-Attainment and Maintenance Areas) ...... 3-5

27 3.2.4 Housing Impacts ................................................................................................. 3-6

28 3.2.5 Public Services - Education (Refurbishment) ..................................................... 3-7

29 3.2.6 Public Services - Public Utilities ......................................................................... 3-7

30 3.2.7 Public Services - Transportation ......................................................................... 3-7

31 3.2.8 Offsite Land Use (Refurbishment) ....................................................................... 3-8

32 3.2.9 Historic and Archaeological Resources ............................................................... 3-8

33 3.2.10 Environmental Justice ......................................................................................... 3-9

34 3.3 Evaluation of New and Potentially Significant Information on

35 Impacts of Refurbishment ...................................................................................... 3-10

36 3.4 Summary of Impacts of Refurbishment ................................................................... 3-10

37 3.5 References ............................................................................................................. 3-12

38 4.0 Environmental Impacts of Operation ............................................................................ 4-1

39 4.1 Land Use .................................................................................................................. 4-1

40 4.2 Air Quality ................................................................................................................ 4-1

41 4.3 Ground W ater .......................................................... 4-2

42 4.3.1 Ground W ater Use Conflicts (plants using >100 gpm ) ........................................ 4-2

43 4.3.2 Ground W ater Use Conflicts (make-up from a small river) .................................. 4-2

44 4.4 Surface W ater .......................................................................................................... 4-3

45 4.4.1 W ater Use Conflicts ............................................................................................ 4-4

46 4.5 Aquatic Resources ................................................................................................... 4-5

47 4.5.1 Generic Aquatic Ecology Issues .......................................................................... 4-5

48 4.5.2 Entrainment and Impingement ............................................................................ 4-5

49 4.5.3 Heat Shock ....................................................................................................... 4-11

Draft NUREG-1437, Supplement 39 vi October 2009
Table of Contents

1 4.5.4 Total Impacts on Aquatic Resources ................................................................. 4-13

2 4.6 Terrestrial Resources ............................................................................................. 4-13

3 4.7 Threatened or Endangered Species ....................................................................... 4-14

4 4.7.1 Aquatic Species ................................................................................................ 4-15

5 4.7.2 Terrestrial Species ............................................................................................ 4-17

6 4.8 Human Health ........................................................................................................ 4-17

7 4.8.1 Generic Human Health Issues .......................................................................... 4-18

8 4.8.2 Microbiological Organisms - Public Health ....................................................... 4-21

9 4.8.3 Electromagnetic Fields -Acute Shock .............................................................. 4-23

10 4.8.4 Electromagnetic Fields - Chronic Effects .......................................................... 4-24

11 4.9 Socioeconomics ....................................... .............................................................. 4-25

12 4.9.1 Generic Socioeconomic Issues ......................................................................... 4-25

13 4.9.2 Housing Im pacts ............................................................................................... 4-25

14 4.9.3 Public Services: Public Utility Impacts ............................................................... 4-26

15 4.9.4 Offsite Land Use - License Renewal Period ............. ........................................ 4-27

16 4.9.5 Public Services: Transportation Impacts ........................................................... 4-28

17 4.9.6 Historic and Archaeological Resources ............................................................. 4-29

18 4.9.7 Environmental Justice ....................................................................................... 4-33

19 4.10 Evaluation of New and Potentially Significant Information ....................................... 4-46

20 4.11 Cumulative Im pacts ................................................................................................ 4-46

21 4.11.1 Cumulative Impacts on Aquatic and W ater Resources ..................................... 4-47

22 4.11.2 Cumulative Impacts on Terrestrial Resources .......... ............. 4-49

23 4.11.3 Cumulative Human Health Impacts ................................................................... 4-50

24 4.11.4 Cumulative Socioeconomic Impacts .................................................................. 4-51

25 4.11.5 Cumulative Environmental Justice Impacts ....................................................... 4-52

26 4.11.6 Summary of Cumulative Impacts ...................................................................... 4-53

27 4.12 References ............................................................................................................. 4-54

28 5.0 Environmental impacts of postulated accidents ............................... 5-1

29 5.1 Design Basis Accidents ............................................................................................ 5-1

30 5.2 Severe Accidents...................................................................................................... 5-2

31 5.3 Severe Accident Mitigation Alternatives .................................................................... 5-3

32 5.3.1 Introduction ........................................................................................................ 5-3

33 5.3.2 Estimate of Risk .................................................................................................. 5-4

34 5.3.3 Potential Plant Im provements ............................................................................. 5-5

35 5.3.4 Evaluation of Risk Reduction and Costs of Improvements ................................. 5-5

36 5.3.5 Cost-Benefit Comparison .................................................................................... 5-6

37 5.3.6 Conclusions ........................................................................................................ 5-7

38 5.4 Environmental Justice Issues Related to Severe Accidents ...................................... 5-7

39 5.5 References ............................................................................................................... 5-8

40 6.0 Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management ...... 6-1

41 6.1 The Uranium Fuel Cycle ........................................................................................... 6-1

42 6.2 Greenhouse Gas Emissions ..................................................................................... 6-2

43 6.2.1 Introduction ......................................................................................................... 6-2

44 6.2.2 PINGP 1 and 2 ................................................................................................... 6-2

45 6.2.3 GElS ................................................................................................................... 6-2

46 6.2.4 Other Studies ...................................................................................................... 6-3

47 6.2.5 Qualitative ............................................................................................... I ........... 6-3

48 6.2.6 Quantitative ........................................................................................................ 6-4

49 6.2.7 Summary of Nuclear Greenhouse Gas Emissions Compared to Coal ................. 6-5

October 2009 vii Draft NUREG-1437, Supplement 39
Table of Contents

1 6.2.8 Summary of Nuclear Greenhouse Gas Emissions Compared to Natural Gas ..... 6-6

2 6.2.9 Summary of Nuclear Greenhouse Gas Emissions Compared to Renewable

3 Energy Sources. ................................................................................................. 6-7

4 6.2.10 Conclusions ........................................................................................................ 6-8

5 6.3 References ............................................................................................................... 6-9

6 7.0 Environm ental Im pacts of Decom m issioning ............................................................... 7-1

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

8 8.0 Environm ental Im pacts of Alternatives ......................................................................... 8-1

9 8.1 Gas-fired Generation ................................................................................................ 8-3

10 8.1.1 Air Q uality ........................................................................................................... 8-5

11 8.1.2 Groundwater Use and Q uality ............................................................................. 8-7

12 8.1.3 Surface W ater Use and Q uality ........................................................................... 8-7

13 8.1.4 Aquatic and Terrestrial Ecology .......................................................................... 8-7

14 8.1.5 Hum an Health ..................................................................................................... 8-8

15 8.1.6 Socioeconom ics .................................................................................................. 8-9

16 8.1.7 W aste M anagem ent .......................................................................................... 8-13

17 8.2 Com bination Alternative 1 ....................................................................................... 8-13

18 8.2.1 Air Q uality ............................................................................................. 8-14

19 8.2.2 Groundwater Use and Quality ..................................... 8-16

20 8.2.3 Surface Water Use and Quality ................................ 8-16

21 8.2.4 Aquatic and Terrestrial Ecology ........................................................................ 8-16

22 8.2.5 Hum an Health ................................................................................................... 8-17

23 8.2.6 Socioeconom ics ................................................................................................ 8-18

24 8.2.7 W aste M anagem ent ......................................................................................... 8-23

25 8.3 Com bination Alternative 2 ...................................................................................... 8-23

26 8.3.1 Air Q uality ......................................................................................................... 8-24

27 8.3.2 G roundwater Use and Q uality ........................................................................... 8-24

28 8.3.3 Surface W ater Use and Q uality ......................................................................... 8-24

29 8.3.4 Aquatic and Terrestrial Ecology ........................................................................ 8-25

30 8.3.5 Hum an Health ................................................................................................... 8-25

31 8.3.6 Socioeconom ics ................................................................................................ 8-26

32 8.3.7 W aste Managem ent .......................................................................................... 8-30

33 8.4 Purchased Power ................................................................................................... 8-30

34 8.5 Alternatives Considered but Dism issed .................................................................. 8-31

35 8.5.1 W ind Power ..................................................................................................... 8-31

36 8.5.2 W ood W aste ..................................................................................................... 8-31

37 8.5.3 Energy Conservation ........................................................................................ 8-32

38 8.5.4 Solar Power ...................................................................................................... 8-32

39 8.5.5 Hydroelectric Power .......................................................................................... 8-33

40 8.5.6 Geotherm al Power ............................................................................................ 8-33

41 8.5.7 Biofuels ............................................................................................................. 8-33

42 8.5.8 New Nuclear Power .......................................................................................... 8-33

43 8.5.9 Coal-fired Power ............................................................................................... 8-33

44 8.5.10 O il-fired Power .................................................................................................. 8-34

45 8.5.11 Fuel Cells ........................................................................................................ 8-34

46 8.5.12 M unicipal Solid W aste ....................................................................................... 8-34

47 8.5.13 Delayed Retirement ................ ........................ 8-35

48 8.6 No-Action Alternative .............................................................................................. 8-35

49 8.6.1 Air Q uality ......................................................................................................... 8-36

Draft NUREG-1437, Supplement 39 viii October 2009
Table of Contents

1 8.6.2 Groundwater Use and Quality ............................................................................. 8-36

2 8.6.3 Surface Water Use and Quality .......................................................................... 8-36

3 8.6.4 Aquatic and Terrestrial Resources ...................................................................... 8-36

4 8.6.5 Human Health ...................................................................... ..... .... ... 8-36

5 8.6.6 Socioeconomics ........................................... 8-37

6 8.6.7 Waste Management ............................................................................................ 8-39

7 8.7 Alternatives Summary ............................................................................................... 8-39

8 8 .8 R efe re nce s ............................................................................................................... 8-4 1

9 9 .0 C o n c lu sio n ...................................................................................................................... 9 -1

10 9.1 Environmental Impacts of License Renewal ......................................................... 9-1

11 9.2 Comparison of Environmental Impacts of License Renewal and Alternatives ............ 9-2

.12 9.3 Resource Commitments ............................................................................................. 9-2

13 9.3.1 Unavoidable Adverse Environmental Impacts ....................................................... 9-2

14 9.3.2 Relationship Between Local Short-Term Uses of the Environment and the

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

16 9.3.3 Irreversible and Irretrievable Commitments of Resources .................................... 9-3

17 9.4 R ecom m endations ...................................................................................................... 9-4

18 10 .0 List of P re pare rs ........................................................................................................... 10-1

19 A. Comments Received on the Prairie Island Nuclear Generating Station, Units I and 2,

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

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

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

23 D. Consultation correspondence .................................................................................. D-1

24 B iological A ssessm ent ............................................................................................................ D -70

25 1.0 Introduction and Purpose ........................................................................................... D-71

26 2.0 P roposed A ction .......................................................................................................... D -7 1

27 3.0 S ite D escriptio n ........................................................................................................... D -72

28 4.0 Assessment of Listed Species and Critical Habitat ..................................................... D-78

2 9 5 .0 C o nclusio n .................................................................................................................. D -80

30 6 .0 R efe re nce s .......................................................................... ....................................... D -8 1

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

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

33 Alternatives (SAMAs) for Prairie Island Nuclear Generating Plant, Units 1 and 2, in

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

35

36 FIGURES

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

38 Figure 1-2. Environmental Issues Evaluated During License Renewal ..................................... 1-5

39 Figure 2-1. Location of Prairie Island Nuclear Generating Plant, Units 1 and 2, 50-mi (80-km)

4 0 R e g io n ................................................................................................................... 2 -4

October 2009 ix Draft NUREG-1437, Supplement 39
Table of Contents

1 Figure 2-2. PINGP 1 and 2 General Site Layout and Exclusion Area Boundary ...................... 2-5

2 Figure 2-3. PINGP 1 and 2 Substation and Transmission Line Layout .................................. 2-13

3 Figure 2-4. PINGP 1 and 2 Transmission System ................................................................. 2-14

4 Figure 2-5. Lithology and Generalized Geologic Section for the Prairie Island Low Island

5 T e rra ce ............................................................................................................. 2 -27

6 Figure 3-1. Potential Areas Impacted by Unit 2 Steam Generator Replacement ................... 3-11

7 Figure 4-1. Prairie Island Indian Community Trust Land Boundary ........................................ 4-36

8 Figure 4-2. Minority Block Groups with a 50-mi (80 km) radius of PINGP 1 and 2 ................. 4-37

9 Figure 4-3. Low-income Block Groups with a 50-mi (80 km) radius of PINGP 1 and 2 .......... 4-38

10

11 TABLES12 Table 1-1. Licenses and Perm its ......................................................................................... 1-11

13 Table 2-1. PING P 1 and 2 Transm ission Lines ...................................................................... 2-15

14 Table 2-2. Post-modification Velocity Profiles for the PINGP 1 and 2 Cooling Water

15 Intake S ystem .................................................................................................. 2-17

16 Table 2-3. PINGP 1 and 2 Screen Mesh Size and Spray Wash Pressure Requirements ...... 2-19

17 Table 2-4. PINGP 1 and 2 Plant Flow (Discharge) Restrictions ............................................. 2-19

18 Table 2-5. PINGP 1 and 2 Cooling Mode Requirements ....................................................... 2-19

19 Table 2-6. NPDES Effluent Limitations for PINGP 1 and 2 .................................................... 2-21

20 Table 2-7. Surface Discharge (SD) and Internal Waste Stream (WS) Discharges from

21 PINGP 1 and 2 (in millions of gallons per day [mgd]) ........................................ 2-22

22 Table 2-8. Total Annual Groundwater Withdrawal (Gallons) for PINGP 1 and 2 .................... 2-28

23 Table 2-9. Monthly Average Discharge Flow at Lock and Dam 3 from 1999 to 2006 ............. 2-29

24 Table 2-10. Total Yearly Discharge Flow at Lock.and Dam 3 from 1999 to 2006 .................. 2-30

25 Table 2-11. Listed Aquatic Species ....................................................................................... 2-38

26 Table 2-12. Listed Terrestrial Species ..................................................................... .............. 2-41

27 Table 2-13. PINGP 1 and 2 Employee Residence by County ................................................ 2-46

28 Table 2-14. Housing in Goodhue County and Dakota Counties, Minnesota,

29 and Pierce County, W isconsin .......................................................................... 2-47

30 Table 2-15. Major Public Water Supply Systems (in million gallons per day [gpd]) ................ 2-49

31 Table 2-16. Major Commuting Routes in the Vicinity of the Prairie Island Nuclear

32 Generating Plant and 2007 Average Annual Daily Traffic (AADT) Counts ......... 2-51

33 Table 2-17. Population and Percent Growth in Goodhue County and

34 Dakota County, Minnesota, and Pierce County, Wisconsin,

35 from 1970 to 2000 and Projected for 2006 to 2050 ........................................... 2-55

36 Table 2-18. Demographic Profile of the Population in the PINGP 1 and 2 Three-County

37 Socioeconomic Region of Influence in 2000 ..................................................... 2-56

38 Table 2-19. Demographic Profile of the Population in the PINGP 1 and 2 Three-County

39 Socioeconomic Region of Influence in 2005-2007, 3-Year Estimate ........ 2-57

40 Table 2-20. Seasonal Housing in Counties Located within 50 mi (80 kin) of

4 1 P IN G P 1 and 2 .................................................................................................. 2-58

42 Table 2-21. Migrant Farm Worker and Temporary Farm Labor in Counties Located

43 within 50 m i (80 km ) of PINGP 1 and 2 ............................................................. 2-59

44 Table 2-22. Major Employers in Goodhue County ................................................................. 2-61

45 Table 2-23. 2005-2007 Estimated Income for the PINGP 1 and 2 Region of Influence .......... 2-62

46 Table 2-24. PINGP 1 and 2 Property Tax Paid and Percentage of Goodhue County,

47 City of Red Wing, and School District 256 Tax Revenues, 2001 to 2006 .......... 2-64

48 Table 2-25. Archaeological Sites within the PINGP 1 and 2 Site Boundary ........................... 2-69

Draft NUREG-1437, Supplement 39 X October 2009
Table of Contents

1 Table 3-1. Issues Related to Refurbishment at PINGP 1 and 2 ................................................ 3-1

2 T able 4-1. Land U se Issues ...................................................................................................... 4-1

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

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

5 Table 4-4. Surface W ater Q uality Issues ................................................................................... 4-3

6 Table 4-5. A quatic R esources Issues ....................................................................................... 4-5

7 Table 4-6. Estimated Number of Fish Impinged at PINGP 1 and 2, 1973-1984 ........................ 4-7

8 Table 4-7. Estimated Number and Percent Composition of Fish Life Stages

9 Impinged on Fine Mesh Screens April through August, 1984-1988 .................... 4-10

10 Table 4-8. Upper Lethal Thresholds of Common Fish Species Occurring in the

11 V icinity of P IN G P 1 and 2 .................................................................................... 4-12

12 Table 4-9. Terrestrial Resources Issues ................. ................................................................ 4-14

13 Table 4-10. Threatened or Endangered Species ..................................................................... 4-14

14 Table 4-11. H um an H ealth Issues ........................................................................................... 4-17

15 Table 4-12. Socioeconom ic Issues .......................................................................................... 4-25

16 Table 4-13. Summary of Cumulative Impacts on Resources Areas ........................................ 4-53

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

18 Table 5-2. PINGP 1 and 2 Core Damage Frequency ................................................................ 5-4

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

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

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

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

23 Table 6-4. Nuclear Greenhouse Gas Emissions Compared to Renewable Energy Sources .... 6-7

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

25 Table 8-1. Summary of Environmental Impacts of Gas-Fired Combined-Cycle Generation

26 Compared to Continued PINGP 1 and 2 Operation ........................ 8-5

27 Table 8-2. Summary of Environmental Impacts of Combination Alternative 1

28 Compared to Continued PINGP 1 and 2 Operation ............................................ 8-14

29 Table 8-3. Summary of Environmental Impacts of Combination Alternative 2

30 Compared to Continued PINGP 1 and 2 Operation ............................................ 8-24

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

32 Continued PINGP 1 and 2 Operation ............................... .... 8-36

33 Table 8-5. Summary of Environmental Impacts of Proposed Action and Alternatives ............. 8-40

34 T able 10-1. List of P reparers .................................................................................................... 10-1

35

October 2009 xi Draft NUREG-1437, Supplement 39

Summary

1 EXECUTIVE SUMMARY

2 Background

3 By letter dated April 11, 2008, Northern States Power Co. (NSP) [formerly Nuclear Management

4 Company, LLC (NMC)] submitted an application to the U.S. Nuclear Regulatory Commission

5 (NRC) to issue renewed operating licenses for Prairie Island Nuclear Generating Plant, Units 1

6 and 2 (PINGP 1 and 2), for an additional 20-year period.

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

8 implementing Section 102 of the National Environmental Policy Act of 1969 (NEPA; 42 USC

9 4321) in Title 10 of the Code of Federal Regulations (CFR), Part 51 (10 CFR Part 51). In 10

10 CFR 51.20(b)(2), the Commission indicates that issuing a renewed power reactor operating

11 license requires preparation of an Environmental Impact Statement (EIS) or a supplement to an

12 existing EIS. In addition, 10 CFR 51.95(c) States that the EIS prepared at the operating license

13 renewal stage will be a supplement to the Generic Environmental Impact Statement for License

14 Renewal of Nuclear Plants (GElS), NUREG-1437, Volumes and 2 (NRC 1996; 1999).

15 Upon acceptance of NSP's application, the NRC staff began the environmental review process

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

17 scoping. We conducted a site audit at the plant in August 2008 and held public scoping

18 meetings on July 30, 2008, in Red Wing, Minnesota. In the preparation of this supplemental

19 environmental impact statement (SEIS) for PINGP 1 and 2, we reviewed NSP's environmental

20 report (ER) and compared it to the GElS, consulted with other agencies, conducted a review of

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

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

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

24 process.

25 Proposed Action

26 NSP initiated the proposed Federal action - requesting a renewed power reactor operating

27 licenses - by submitting an application for license renewal of PINGP 1 and 2, for which the

28 existing licenses (DPR-42 and DPR-60) expire on August 9, 2013 and October 29, 2014,

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

30 20 years.

31 Purpose and Need for Action

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

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

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

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

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

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

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

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

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

41 If the renewed license is issued, State regulatory agencies and NSP will ultimately decide

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

43 matters within the State's jurisdiction or the purview of the owners. If the operating license is not

October 2009 xiii Draft NUREG-1437, Supplement 39
Summary

1 renewed, then the facility must be shut down on or before the expiration dates of the current

2 operating licenses: August 9, 2013, for Unit 1 and October 29, 2014, for Unit 2.

3 Environmental Impacts of License Renewal

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

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

6 and the NRC staff established separate processes for identifying and evaluating the significance

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

8 PINGP 1 and 2. Neither NSP nor the NRC identified information that is both new and significant

9 related to Category 1 issues that would call into question the conclusions in the GElS. Similarly,

10 neither the scoping process nor the NRC has identified any new issue applicable to PINGP 1

11 and 2 that has a significant environmental impact. Therefore, the NRC staff relies upon the

12 conclusions of the GElS for all the Category 1 issues applicable to PINGP 1 and 2.

13 Land Use

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

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

16 would be no impacts beyond those discussed in the GELS.

17 Air Quality

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

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

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

21 beyond those discussed in the GELS.

22 However, air quality during refurbishment and maintenance areas is a Category 2 issue. The

23 NRC staff concludes that the impact of vehicle exhaust emissions resulting from refurbishment

24 activities would be SMALL. Potential mitigation measures include implementation of a dust

25 control plan and the use of vans and workforce shift changes to reduce the number of vehicles

26 on the road at any one given time.

27 Ground Water Use and Quality

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

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

30 river) are Category 2 issues related to license renewal at PINGP 1 and 2. Information provided

31 by NSP, including drawdown calculations and consumptive use calculations, was reviewed by

32 the NRC staff, and determined that the impact of water withdrawal at PINGP 1 and 2 is SMALL.

33 Surface Water Use and Quality

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

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

36 and 2. Withdrawals of Mississippi River water by PINGP 1 and 2 are less than 11 percent of the

37 lowest annual mean flow and approximately 4.6 percent of the average river flow. Relative to

38 the total flow of the Mississippi River, PINGP 1 and 2's consumptive use and related impact to

39 the river is SMALL.

40 Aquatic Resources

41 SMALL. Aquatic Resources conflicts: impingement, entrainment, and heat shock are Category 2

42 issues related to license renewal at PINGP 1 and 2. Information provided by NSP, as well as the

Draft NUREG-1437, Supplement 39 xiV October 2009
Summary

1 conclusions drawn by NRC staff, shows that the impacts of aquatic resources at PINGP 1 and 2

2 are small.

3 For refurbishment, regarding the transportation route of the new steam generators to the PINGP

4 unit 2 site, NSP will need to consult with the appropriate State and Federal agencies regarding

5 potential impacts of the transportation plan on aquatic resources and threatened and

6 endangered aquatic species.

7 Terrestrial Resources

8 SMALL. With regard to operation of PINGP 1 and 2 during the license renewal term, the NRC

9 did not identify any Category 2 issues for terrestrial resources, nor did the staff identify any new

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

11 beyond those discussed in the GEIS.

12 However, impacts to terrestrial resources during refurbishment activities is a Category 2 issue.

13 The majority of refurbishment activities will take place on existing facility grounds at PINGP 1

14 and 2, and use of existing structures will minimize new construction. All new, temporary

15 structures will be constructed on previously disturbed land. No road improvements would be

16 required for delivery of the steam generators to PINGP 1 and 2 as the new steam generators

17 would be offloaded from a barge to a nuclear transporter directly onto the PINGP 1 and 2 site.

18 Potential mitigation measures to minimize impacts to terrestrial resources include installing silt

19 fences to minimize sediment transport, the use of best management practices, and the

20 restoration of cleared land upon completion of construction activities.

21 Threatened and Endangered Species

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

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

24 indicated that the Higgins eye pearly mussel (Lampsi/is higginsi) is present in Upper Mississippi

25 River within the vicinity of PINGP 1 and 2, though no designated critical habitat is present for the

26 species in Goodhue County. The staff concluded that the impact to this species is SMALL. The

27 Minnesota Department of Natural Resources indicated that although several State-listed

28 species of concern are known to occur in the vicinity of the PINGP 1 and 2 project site, no

29 impact to these species is anticipated.

30 Refurbishment activities will take place on existing facility grounds at the PINGP I and 2 site,

31 and all new, permanent structures will be constructed on previously disturbed land; therefore, no

32 impact to threatened or endangered species is anticipated. While steam generators will travel to

33 the PINGP 1 and 2 site via barge, though no changes to the river or dams are anticipated.

34 Human Health

35 SMALL. With regard to Categ6ry i human health issues during the license renewal term36 microbiological organisms (occupational health), noise, radiation exposures to public,

37 occupational radiation exposureso,•ard electromagnetic fields (chronic effects)-the NRC staff

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

39 there are no impacts beyond those discussed in the GElS. Slightly higher radiation doses to

40 members of the public are expected from PINGPI and 2 during the refurbishment period.

41 However, based on past regulatory compliance, the dose to a maximally exposed individual in

42 the vicinity of PINGP 1 and 2 for the refurbishment period is expected to continue to be a small

43 fraction of the limits and standards specified in 10 CFR Part 20, Appendix I to 10 CFR Part 50,

44 and 40 CFR Part 190.

October 2009 XV Draft NUREG-1437, Supplement 39
Summary

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

2 shock) are Category 2 human health issues. Between 2000 and 2005, the highest ambient river

3 water temperature upstream of the discharge canal was 86.0 *F (30 'C), and the highest

4 temperature downstream of the discharge canal was 86.4 'F (30.2 'C), both measured in

5 August 2001. The highest'temperature measured at the PINGP 1 and 2 discharge canal was 99

6 'F (37.2 °C), in August 2003. Maximum temperature conditions could allow for the presence of

7 thermophilic microbiological organisms; however, given the growth rate of these organisms, it is

8 not expected that the period of time in which the heated discharge water moves through the

9 discharge canal would allow for any noticeable impact on growth rates of microbiological

10 organisms. Additionally, potential thermophilic microbiological organisms present in the

11 discharge canal would likely be in limited numbers and would not be expected to cause a

12 significant risk to public health. Additionally, the PINGP 1 and 2 discharge canal and adjacent

13 portions of the Mississippi River do not allow for public access; therefore, the impact is SMALL.

14 NRC staff reviewed NSP's analysis of electromagnetic fields-acute shock resulting from

15 induced charges in metallic structures, and verified that none of PINGP 1 and 2's in-scope

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

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

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

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

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

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

22 on this issue.

23 Socioeconomics

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

SMALL to MODERATE. The NRC did not identify any Category 1 public services and aesthetic

impacts, or new and significant information during the environmental review. Therefore, there

would be no impacts beyond those discussed in the GELS. Category 2 socioeconomic impacts

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

transportation), historic and archaeological resources, and environmental justice. Since PINGP

1 and 2 is located in a high-density population area, and growth control measures are not in

effect, any changes in PINGP 1 and 2 employment would have little noticeable effect on

housing availability in the surrounding area. NSP has indicated that the steam generator

replacement would require a one-time increase in the number of refueling outage workers for up

.to 80 days, which would create an additional demand for temporary (rental) housing in the

immediate vicinity of PINGP 1 and 2. This also applies to offsite land use and transportation

issues - because non-outage employment levels at PINGP 1 and 2 would remain relatively

unchanged during the license renewal period, there would be no land use impacts related to

population or tax revenues, an-netransportation impacts. Category 2 socioeconomic impacts

related to refurbishment at PINGP 1 and 2 would be SMALL, as the PINGP unit 2 steam

generator project is expected to require a one-time increase of outage workers for up to 70

days-a short duration of time.

Impacts to known historical and archeological resources are MODERATE from continued

operation of PINGP 1 and 2 during the license renewal term. These impacts are potentially

mitigated with the implementation of new commitments proposed by NPS. These commitments

are described in chapter 4 of this draft SEIS. Since PINGP 1 and 2 is situated in an

archaeologically sensitive area, continuing to develop cultural resources management plans in

addition to NPS's review procedures would serve to integrate cultural resource considerations

with ongoing PINGP 1 and 2 activities. Additionally, training of PINGP 1 and 2 staff in the

Section 106 process would ensure that informed decisions are made when considering the

Draft NUREG-1437, Supplement 39 xv; October 2009
Summary

1 effects of future projects on historic and archaeological resources. Lands that have not been

2 surveyed should be investigated by a professional archaeologist prior to any ground

3 disturbance. Because refurbishment activities will occur on previously disturbed land, the

4 impacts associated with refurbishment are not expected to adversely affect historic or

5 archaeological sites in the area of PINGP unit 2.

6 Regarding environmental justice, an analysis of minority and low-income populations residing

7 within a 50-mile (80-kilometer) radius of PINGP 1 and 2 indicated there would be no

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

9 of PINGP 1 and 2 during the license renewal period. Additionally, based on recent monitoring

10 results, concentrations of contaminants in native leafy vegetation, soils and sediments, surface

11 water, and fish in areas surrounding PINGP 1 and 2 have been low (at or near the threshold of

12 detection) and seldom above background levels. Consequently, no disproportionately high and

13 adverse human health impacts would be expected in special pathway receptor populations in

14 the region as a result of subsistence consumption of fish and wildlife.

15 Severe Accident Mitigation Alternatives

16 Since PINGP 1 and 2 had not previously considered alternatives to reduce the likelihood or

17 potential consequences of a variety of highly uncommon but potentially severe accidents, NRC

18 regulation 10 CFR 51.53(c)(3)(ii)(L) requires that PINGP 1 and 2 evaluate Severe Accident

19 Mitigation Alternatives (SAMAs) in the course of license renewal review. SAMAs are potential

20 ways to reduce the risk or potential impacts of uncommon but potentially severe accidents, and

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

22 Based on our review of potential SAMAs, we conclude that PINGP 1 and 2 made a reasonable,

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

24 PINGP 1 and 2, and the plant improvements already made, we conclude that none of the

25 potentially cost-beneficial SAMAs relate to adequately managing the effects of aging during the

26 period of extended operation; therefore, they need not be implemented as part of the license

27 renewal pursuant to 10 CFR Part 54.

28 Alternatives

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

30 These alternatives include other methods of power generation and not renewing the PINGP 1

31 and 2 operating license (the no-action alternative). Replacement power options considered were

32 1) gas-fired combined-cycle plant at the PINGP 1 and 2 site and an undetermined alternate site;

33 2) a combination including a gas-fired unit, wind power, conservation, and wood-waste biomass;

34 and 3) a combination including continued operation of one of the two PINGP 1 and 2 unit, wind

35 power, and conservation. Wherever possible, we evaluated potential environmental impacts for

36 these alternatives located both at the PINGP 1 and 2 site and at some other unspecified

37 alternate location. We evaluated each alternative using the same impact areas that we used in

38 evaluating impacts from license renewal. The results of this evaluation are summarized in the

39 table on the following page.

40 All alternatives capable of meeting the needs currently served by PINGP 1 and 2 entail

41 potentially equal or greater impacts than the proposed action of license renewal of PINGP 1 and

42 2. The no-action alternative does not meet the purpose and need of this draft SEIS, though if it

43 triggers either combination alternative 1 or 2 to replace the capacity currently supplied by

44 PINGP 1 and 2, it could result in an overall SMALL impact, as well.

October 2009 xvii Draft NUREG-1437, Supplement 39
Summary

Impact Area

4.. EE

0) = 0 0 0 0

t. 4) 0 0 0)

0

Alternative

PINGP 1 and 2

License Renewal

Gas-fired at PINGP

1 and 2 site

Gas-fired at

Alternative Site

Combination

Alternative 1(a)

Combination

Alternative 2 (b)

No Action

Alternative

MODERATE SMALL

SMALL

SMALL

MODERATE SMALL

MODERATE

SMALL

SMALL

SMALL to

MODERATE

SMALL to

MODERATE

MODERATE

SMALL to

MODERATE

SMALL

SMALL to MODERATE

SMALL to MODERATE

SMALL to MODERATE

SMALL

SMALL

SMALL

SMALL

SMALL

SMALL

SMALL to MODERATE MODERATE SMALL to

MODERATE

SMALL SMALL SMALL SMALL to SMALL MODERATE

SMALL to SMALL SMALL SMALL MODERATE

(a)Combination Atlernative 1 consists of gas-fired generation, wood-fired generation, wind power, and conservation

(b)Combination Alternative 2 consists of continued operation of one of the two PINGP I and 2 units, wind power, and

conservation

1 Recommendation

2

3

4

5

6

7

8

9

Our preliminary recommendation is that the Commission determine that the adverse

environmental impacts of license renewal for PINGP 1 and 2 are not so great that preserving

the option of license renewal for energy planning decisionmakers would be unreasonable. This

recommendation is based on (1) the analysis and findings in the GELS; (2) information

submitted in the NSP's ER; (3) consultation with other Federal, State, and local agencies; (4) a

review of other pertinent studies and reports; and (5) a consideration of public comments

received during the scoping process.

Draft NUREG-1437, Supplement 39 xviii October 2009
Abbreviations and Acronyms

1 ABBREVIATIONS AND ACRONYMS

2

3 AEA Atomic Energy Act of 1954

4 AEC U.S. Atomic Energy Commission

5 AEO Annual Energy Outlook

6 ALARA as low as is reasonably achievable

7 APE area of potential effect

8 APP Avian Protection Plan

9

10 BTU/kWh British thermal. units per kilowatt hour

•11 BO Biological Opinion

12

13 °C degrees Celsius

14 CAA Clean Air Act

15 CDC U.S. Center for Disease Control and Prevention

16 CDF Core Damage Frequency

17 CDM Clean Development Mechanism

18 CEQ Council on Environmental Quality

19 CFR Code of Federal Regulations

20 cfs cubic feet per second

21 CeqlkWh carbon equivalent per kilowatt-hour

22 cm centimeter

23 CO carbon monoxide

24 C02 carbon dioxide

25 CWA Clean Water Act

26

27 DBA design-basis accident

28 DOE U.S. Department of Energy

29 DPR demonstration power reactor

30

31 EHA essential habitat area

32 EIA Energy Information Administration (of DOE)

33 EIS environmental impact statement

34 ELF-EMF extremely low frequency-electromagnetic field

35 EMS environmental management system

36 ER environmental report

37 EPA U.S. Environmental Protection Agency

38 EPCRA Emergency Planning and Community Right-to-Know Act

39 ESA Endangered Species Act of 1973

40

41 OF degrees Fahrenheit

42 FES Final Environmental Statement

43 fps feet per second

44 FR Federal Register

45 FSAR Final Safety Analysis Report

46 ft feet

47 ft's feet per second

48 FWS U.S. Fish and Wildlife Service

49

October 2009 xix Draft NUREG-1437, Supplement 39
Abbreviations and Acronyms

1 GE General Electric Company

2 GElS Generic Environmental Impact Statement for License Renewal of Nuclear

3 Plants, NUREG-1437

4 GHG greenhouse gas

5 gpm gallons per minute

6

7 HID high intensity discharge

8

9 in. inch

10 Inc. Incorporated

11 IPE Individual Plant Examination

12 IPEEE Individual Plant Examination of External Events

13 ISFSI independent spent fuel storage installation

14 ISLOCA interfacing system loss-of-coolant accidents

15

16 kg/cm 2 kilograms per square centimeter

17

18 LLC limited liability corporation

19 LOCA loss of coolant accident

20

21 m meter

22 MACCS2 MELCOR Accident Consequence Code System 2

23 MDH Minnesota Department of Health

24 mgd million gallons per day

25 mGy milligray (unit of absorbed radiation dose)

26 MNDNR Minnesota Department of Natural Resources

27 MOU memorandum of understanding

28 MPCA Minnesota Pollution Control Agency

29 mrad millirad (unit of absorbed radiation dose)

30 m/s meters per second

31 m3/s cubic meters per second

32 mSy millisievert

33 MT metric tonne

34 MTU metric tonne uranium

35 MW megawatt

36 MWd megawatt days

37 MWe megawatt-electric

38 MWt megawatt-thermal

39

40 NA not applicable

41 NAAQS National Ambient Air Quality Standards

42 NAS National Academy of Sciences

43 NEPA National Environmental Policy Act of 1969

44 NHPA National Historic Preservation Act

45 NIEHS National Institute of Environmental Health Sciences

46 NMC Nuclear Management Company, LLC

47 NO) nitrogen oxide(s)

48 NPDES National Pollutant Discharge Elimination System

49 NRC U.S. Nuclear Regulatory Commission

50 NRHP National Register of Historic Places

51 NSP Northern States Power Co.

Draft NUREG-1437, Supplement 39 XX October 2009
Abbreviations and Acronyms

1

2

3

4

5

6

7

8

9

10

11

12

.13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

NUREG

03

PAM

PCB

pCi/L

PFOS

PIIC

PINGP 1 and 2

PM2.

5

PM10

PRA

psi

PWR

RCRA

rem

REMP

RM

ROW(s)

RWST

SAMA

SAR

SD

SEIS

SER

SGTR

SHPO

SO2

Sv

NRC Regulatory Guide

ozone

primary amoebic meningoencephalitis

polychlorinated biphenol

picocuries per liter

perfluorooctanesulfonic acid

Prairie Island Indian Community

Prairie Island Nuclear Generating Plant, Units 1 and 2

particulate matter, 2.5 microns or less in diameter

particulate matter, 10 microns or less in diameter

Probabilistic Risk Assessment

pound per square inch

pressurized water reactor

Resource Conservation and Recovery Act

Rontgen equivalent

radiological environmental monitoring program

river mile

right-of-way(s)

refueling water storage tank

Severe Accident Mitigation Alternative

Safety Analysis Report

surface discharge

supplemental environmental impact statement

Safety Evaluation Report

steam generator tube rupture

State Historic Preservation Office

sulfur dioxide

sievert

toxic characteristic leaching procedure

Uranium

United States

United States Army Corps of Engineers

United States Code

U.S. Geological Survey

Wisconsin Department of Natural Resources

Wisconsin Department of Health Services

waste streams

TCLP

U

U.S.

USACE

U.S.C.

USGS

WDNR

WIDHS

WS

October 2009 xxi Draft NUREG-1437, Supplement 39

Pupose and Need for Action

1

2 1.0 PURPOSE AND NEED FOR ACTION

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

4 in Title 10, Part 51, of the Code of Federal Regulations (10 CFR 51), which implement the

5 National Environmental Policy Act of 1969 (NEPA), issuance of a new nuclear power plant

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

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

8 reactors be granted for up to 40 years with an option to renew for up to another 20 years. The

9 40-year licensing period was based primarily on economic and antitrust considerations rather

10 than on technical limitations of the nuclear facility.

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

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

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

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

15 environmental and safety requirements in the NRC's regulations can be met during the period of

16 extended operation.

17 1.1 Proposed Federal Action

18 Northern States Power Co. (NSP) [formerly Nuclear Management Company, LLC. (NMC)]

19 initialized the proposed Federal action by submitting an application for license renewal of Prairie

20 Island Nuclear Generating Plant, Units 1 and 2 (PINGP 1 and 2), for which the existing licenses

21 DPR-42 (Unit 1) and DPR-60 (Unit 2) expire August 9, 2013, and October 29, 2014,

22 respectively. NRC's Federal action is the decision whether to renew the licenses for an

23 additional 20 years.

24 1.2 Purpose and Need for the Proposed Federal Action

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

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

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

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

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

30 findings in the safety review required by the AEA or findings in the NEPA environmental

31 analysis that would lead the NRC to reject a license renewal application, the NRC does not

32 have a role in the energy-planning decisions of State regulators and utility officials as to whether

33 a particular nuclear power plant should continue to operate.

34 If the renewed license is issued, State regulatory agencies and NSP will ultimately decide

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

36 matters within the State's jurisdiction or the purview of the owners. If the operating license is not

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

38 operating license, August 9, 2013, for Unit 1 and October 29, 2014, for Unit 2.

39

October 2009 1-1 Draft NUREG-1437, Supplement 39
Purpose and Need for Action

1

2 1.3 Major Environmental Review Milestones

3 NSP submitted an environmental report (NMC 2008) as part of its license renewal application

4 (NMC 2008b) in January 2008. After reviewing the application and the environmental report

5 (ER) for sufficiency, the NRC staff published a Notice of Acceptability and Opportunity for

6 Hearing on June 17, 2008, in the

7 Federal Register (Volume 73, p. Figure 1-1. Environmental Review Process.

8 34335, (73 FR 34335)). Then, on The environmental review provides opportunities for

9 July 22, 2008, the NRC published public involvement.

10 another notice in the Federal

11 Register (73 FR 42628) on its

12 intent to conduct scoping, thereby Application

13 beginning the 60-day scoping Submitted to

14 period. NRC

15 The NRC held two public scoping

16 meetings on July 30, 2008, in Red

17 Wing, Minnesota. The NRC report

18 entitled, "Environmental Impact Review

19 Statement Scoping Process Application

20 Summary Report for Prairie Island

21 Nuclear Generating Plant, Units 1

22 and 2," dated May 1, 2009,

23 presents the comments received *Scoping

24 during the scoping process in theirPro Environmental

25 entirety (NRC 2009). Appendix A Site Audit

26 to this supplemental environmental

27 impact statement (SEIS) presents

28 the comments considered to be

29 within the scope of the Draft

30 environmental license renewal SEIS

31 review and the associated NRC Issued

32 responses.

33 In order to independently verify

34 information provided in the ER, the *Draft

35 NRC staff conducted a site audit at SEIS

36 the Prairie Island Nuclear Process

37 Generating Plant, Units 1 and 2

38 (PINGP 1 and 2), site in August of

39 2008. During the site audit, the

40 NRC staff met with plant Final SEIS

41 personnel, reviewed specific Issued

42 documentation, toured the facility,

43 and met with interested Federal,

44 State, and local agencies. A

45 summary of that site audit and a NRC

46 list of the attendees is contained in Decision

47 the Summary of site audit related

48 to the review of the license

Draft NUREG-1437, Supplement 39 1-2 October 2009
Purpose and Need for Action

1 renewal application for Prairie Island Nuclear Generating Plant, Units 1 and 2 published January

2 27, 2009 (NRC 2009a).

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

4 draft SEIS (Figure 1-1). This document is being made available for public comment for 75 days.

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

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

7 publish the final SEIS.

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

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

10 years of plant life. The safety review, which documents its finding in a Safety Evaluation Report,

11 is conducted simultaneously with the environmental review. The findings in both the SEIS and

12 the Safety Evaluation Report (SER) are both factors in the Commission's decision to either

13 grant or deny the issuance of a renewed license.

14 1.4 Generic Environmental Impact Statement

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

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

17 Environmental Impact Statement for License Renewal of Nuclear Power Plants (referred to as

18 the GELS), documents the results of the NRC staffs systematic approach to evaluating the

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

20 operating them for an additional 20 years (NRC 1996, 1999).' The NRC staff analyzed in detail

21 and resolved those environmental issues that could be resolved generically in the GELS.

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

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

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

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

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

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

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

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

30 significance of the effect for both beneficial and adverse effects, (5) determines whether the

31 results of the analysis apply to all plants, and (6) considers whether additional mitigation

32 measures would be warranted for impacts that would have the same significance level for all

33 plants.

34 The NRC's standard of significance for impacts was established using the Council on

35 Environmental Quality (CEQ) terminology for "significant." The NRC established three levels of

36 significance for potential impacts-SMALL, MODERATE, and LARGE, as defined below.

1 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.

October 2009 1-3 Draft NUREG-1437, Supplement 39
Purpose and Need for Action

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

2 destabilize nor noticeably alter any important

3 attribute of the resource. Significance indicates the

4 MODERATE - Environmental effects are sufficient importance of likely environmental

5 to alter noticeably, but not to destabilize, important impacts and is determined by

6 attributes of the resource. considering two variables: context

and intensity.

7 LARGE - Environmental effects are clearly

8 noticeable and are sufficient to destabilize Context is the geographic,

9 important attributes of the resource. ýbiophysical, and social context in

which the effects will occur.

10 The GElS includes a determination whether the

11 analysis of the environmental issue can be applied Intensity refers to the severity of the

12 to all plants and whether additional mitigation

13 measures would be warranted (Figure 1-2). Issues impact, in whatever context it occurs.

14 are assigned a Category 1 or a Category 2

15 designation. As set forth in the GELS, Category 1 issues are those that meet all of the following

16 criteria:

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

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

19 type of cooling system or other specified plant or site characteristics;

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

21 assigned to the impacts (except for collective offsite radiological impacts from

22 the fuel cycle and from high-level waste and spent fuel disposal); and

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

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

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

26 implementation.

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

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

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

30 do not meet one or more of the criterion for Category 1 issues, and therefore, additional site31 specific review for these issues is required. The SEIS documents the results of that site-specific

32 review.

33

Draft NUREG-1437, Supplement 39 1-4. October 2009
Purpose and Need for Action

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

initially evaluated in the GEIS. A site-specific analysis is required for

23 of those 92 issues.

Environmental Issue related to

nuclear power plant operation

Process

used

to analyze

and

categorize

issues in

the GElS

Process

used

to analyze

issues for

each SEIS

1.5 Supplemental Environmental Impact Statement

6

7

8

9

10

11

12

13

14

15

16

17

18

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

operation of PINGP 1 and 2, alternatives to license renewal, and mitigation measures for

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

potential environmental impacts from alternatives while Chapter 9 presents the preliminary

recommendation to the Commission on 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 on the draft SEIS.

In the preparation of this SEIS for PINPG 1 and 2, the NRC staff undertook the following

activities:

* reviewed the information provided in the NSP ER,

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

" conducted an independent review of the issues during the site audit, and

October 2009 1-5 Draft NUREG-1437, Supplement 39
Purpose and Need for Action

1 0 considered the public comments received during the scoping process.

2 New information can be identified from a

3 number of sources, including the New and significant information either:

4 applicant, NRC, other agencies, and (1) identifies a significant environmental issue

5 public comments. If a new issue is

6 revealed, then it is first analyzed to notscoered in the GElS ano

7 determine whether it is within the scope

8 of the license renewal evaluation. If it is leads to an impact finding that is different from

9 not addressed in the GElS, the NRC the finding presented in the GELS.

10 then determines its significance and

11 documents its analysis in the SEIS.

12 1.6 Cooperating Agencies

13 Trust Responsibility:

14 The federal government owes a general trust responsibility to federally recognized Indian

15 Tribes. In the absence of a specific duty placed on the government with respect to Indians, an

16 independent regulatory agency, such as the NRC, discharges its obligations under the trust

17 responsibility by complying with regulations and statutes designed to protect the public at large,

18 in this case, the Atomic Energy Act (AEA) and the National Environmental Policy Act (NEPA).

19 The Memorandum of Understanding:

20 In June 2008, the NRC and the Prairie Island Indian Community (PIIC) entered into a

21 Memorandum of Understanding (MOU). The MOU acknowledges the PIIC's special expertise in

22 the areas of historic and archaeological resources, socioeconomics, land use, and

23 environmental justice as they relate to license renewal for PINGP 1 and 2. The MOU provides a

24 mechanism by which the PIIC can assist the NRC in preparing the Supplemental Environmental

25 Impact Statement (SEIS). The MOU establishes a Cooperating Agency relationship between the

26 NRC and the PIIC and describes the responsibilities of the two entities and the process they will

27 use to produce a SEIS that incorporates and reflects the PIIC's views in the areas of its special

28 expertise. The MOU can be found in ADAMS at accession number ML081610273.

29 The PIIC Tribal Government

30 The PIIC is a Federally-recognized Indian tribe organized under the Indian Reorganization Act

31 of 1934. The PIIC's Constitution and By-Laws, adopted by tribal members on May 23, 1936,

32 and subsequently approved by the Secretary of the Interior on June 20, 1936, provide the terms

33 and conditions under which the tribe is governed. The Constitution and By-laws provide that the

34 Community Council (also known as the Tribal Council) shall be the governing body for the PIIC.

35 The five-member Tribal Council consists of a President, Vice-President, Secretary, Treasurer,

36 and Assistant Secretary/Treasurer, each of whom is elected to a two-year term. (PIIC 2008)

37 1.7 Consultations

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

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

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

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

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

Draft NUREG-1437, Supplement 39 1-6 October 2009
Purpose and Need for Action

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

2 documents.

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

4 Bureau of Indian Affairs, Fort Snelling, Minnesota

5 Minnesota Department of Natural Resources, St. Paul, Minnesota

6 Prairie Island Indian Community, Welch, Minnesota

7 State Historic Preservation Office, St. Paul, Minnesota

8 Wisconsin Department of Natural Resources, Madison, Wisconsin

9 U.S. Fish and Wildlife Service, Bloomington, Minnesota

10 1.8 Correspondence

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

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

13 of all documents sent and received during the environmental review.

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

15 Bois Forte Reservation, Nett Lake, Minnesota

16 Bureau of Indian Affairs, Fort Snelling, Minnesota

17 Cheyenne River Sioux Tribe, Eagle Battle, South Dakota

18 Crow Creek Sioux Tribe, Fort Thompson, South Dakota

19 Dakota County Offices, Hastings, Minnesota

20 Flandreau Santee Sioux Tribe, Flandreau, South Dakota

21 Florence Township Commission, Frontenac, Minnesota

22 Fond du Lac Reservation, Cloquet, Minnesota

23 Goodhue County Courthouse, Red Wing, Minnesota

24 Goodhue County Offices, Red Wing, Minnesota

25 Goodhue County Land Use Management, Red Wing, Minnesota

26 Grand Portage Reservation, Grand Portage, Minnesota

27 Ho-Chunk Nation, Black River Falls, Wisconsin

28 Leech Lake Reservation, Cass Lake, Minnesota

29 Lower Brule Sioux Tribe, Lower Brule, South Dakota

30 Lower Sioux Indian Community of Minnesota, Morton, Minnesota

31 Mayor, City of Lake City, Minnesota

32 Mille Lacs Band of Ojibwe Indians, Onamia, Minnesota

33 Minnesota Chippewa Tribe, Cass Lake, Minnesota

34 Minnesota Department of Commerce, St. Paul, Minnesota

35 Minnesota Department of Health, St. Paul, Minnesota

October 2009 1-7 Draft NUREG-1437, Supplement 39
Purpose and Need for Action

1 Minnesota Department of Natural Resources, St. Paul, Minnesota

2 Minnesota Pollution Control Agency, St. Paul, Minnesota

3 Oglala Sioux Tribe, Pine Ridge, South Dakota

4 Prairie Island Indian Community, Welch, Minnesota

5 Red Lake Band of Chippewa Indians of Minnesota, Red Lake, Minnesota

6 Red Wing City Council, Red Wing, Minnesota

7 Rosebud Sioux Tribe, Rosebud, South Dakota

8 Santee Sioux Nation, Niobrara, Nebraska

9 Sisseton-Wahpeton Oyate of the Lake, Agency Village, South Dakota

10 Shakopee Mdewakanton Sioux Community, Prior Lake, Minnesota

11 Spirit Lake Tribe, Fort Totten, North Dakota

12 State Historic Preservation Office, St. Paul, Minnesota

13 Standing Rock Sioux Tribe, Fort Yates, North Dakota

14 St. Croix Chippewa Indians of Wisconsin, Webster, Wisconsin

15 Turtle Mountain Band of Chippewa, Belcourt North Dakota

16 Upper Sioux Community of Minnesota, Granite Falls, Minnesota

17 U.S. Fish and Wildlife Service, Bloomington, Minnesota

18 White Earth Reservation, White Earth, Minnesota

19 Winnebego Tribe, Winnebego, North Dakota

20 Wisconsin Department of Natural Resources, Madison, Wisconsin

21 Yankton Sioux Tribe, Marty, South Dakota

22 A list of persons who received a copy of this draft SEIS is provided below:

Peter M. Glass, Xcel

Energy Services, Inc.

Resident Inspector's Office,

NRC

Heather Westra, Prairie

Island Indian Community

Katie Himanga, City of Lake

City

Nuclear Asset Manager,

Xcel Energy, Inc.

Kay Kuhlmann, Red Wing

City Council

Manager, Regulatory

Affairs, Northern States

Power Co.

Philip R. Mahowald, Prairie

Island Indian Community

Administrator, Goodhue

County Courthouse

Commissioner, Minnesota

Department of Commerce

Dennis L. Koehl, Northern

States Power Co.

Joan Marshman

Manager, Minnesota

Attorney General=s Office

Gene Eckholt, Northern

States Power Co.

Jim Holthaus, Northern

States Power Co.

Tribal Council, Prairie

Island Indian Community

Joel P. Sorenson, Northern

States Power Co.

Deanna Sheely, Red Wing

City Council

Draft NUREG-1437, Supplement 39 1-8 October 2009
Purpose and Need for Action

Kristen Eide-Toffefson, Lisa Hanni, Goodhue Nancy Shouweiller, Dakota

Florence Township County Land Use County, Fourth District

Commission Management

Carolyn Homsten, CPA, Mr. Don L. Klima, Director, Terrance Virden, U.S.

Goodhue County Advisory Council on Bureau of Indian Affairs

Historic Preservation

Stanley Crooks, Shakopee John L. Stine, Minnesota Ms. Lisa A. Joyal,

Mdewakanton Sioux Department of Health Minnesota Department of

Community Natural Resources

Stan Ellison, Shakopee Leonard Wabasha, Emily Rusch, Wisconsin

Mdewakanton Sioux Shakopee Mdewakanton Department of Natural

Community Sioux Community Resources

John Wurst Joe Ellingson Michael McKay, Wacouta

Township

Elaine and Arlen Diercks, Doub Lansing, Maiden Matrix Energy Solutions

Hay Creek Township Rock Village

Mr. Ronald Johnson, Prairie Mr. Kevin Jensvold, Upper Jean Stacy, Lower Sioux

Island Indian Community Sioux Community of Indian Community of

Minnesota Minnesota

Joseph Brings Plenty, Lester Thompson, Crow Joshua Weston, Flandreau

Cheyenne River Sioux Creek Sioux Tribal Council Santee Sioux Executive

Tribe Committee

Michael Jandreau, Lower John Yellow Bird Steele, Rodney Bordeaux,

Brule Sioux Tribal Council Oglala Sioux Tribal Council Rosebud Sioux Tribal

Council

Roger Trudell, Santee Michael Selvage, Sr., Myra Pearson, Spirit Lake

Sioux Nation Sisseton-Wahpeton Oyate Tribal Council

of the Lake

Ron His Horse Is Thunder, Marcus D. Wells, Jr., Three David Brien, Turtle

Standing Rock Sioux Tribal Affiliated Tribes Business Mountain Band of

Council Council Chippewa

Matthew Pilcher, Robert Cournoyer, Yankton Wilfrid Cleveland, HoWinnebago Tribal Council Sioux Tribal Business & Chunk Nation

Claims Committee

Norman Deschampe, Tony Sullins, U.S. Fish & Thomas A. Lovejoy,

Minnesota Chippewa Tribe Wildlife Service Wisconsin Department of

Natural Resources

Kevin Leecy, Bois Forte Karen R. Diver, Fond du Norman Deschampe,

Reservation Business Lac Reservation Business Grand Portage Reservation

Committee Business Committee

George Goggleye, Leech Melanie A. Benjamin, Mille Erma Vizenor, White Earth

Lake Reservation Business Lacs Band of Ojibwe Reservation Business

Committee Indians Committee

October 2009 1-9 Draft NUREG-1437, Supplement 39
Purpose and Need for Action

Floyd Jourdain, Red Lake Hazel Hindsley, St. Croix Mr. Dennis A. Gimmestad,

Band of Chippewa Indians Chipewa Indians of Minnesota Historical

of Minnesota Wisconsin Society

Katrina Kessler, Minnesota Carol A. Overland, Lea Foushee, NAWO

Pollution Control Agency Overland Law Office

Gary Wege, U.S. Fish and Nick Schaff, Wisconsin

Wildlife Service Department of Natural

Resources

1

Draft NUREG-1437, Supplement 39 1-10 October 2009
Purpose and Need for Action

1 1.9 Status of Compliance

2 NSP is responsible for complying with all NRC regulations and other applicable Federal, State,

3 and local requirements; Appendix H to the GElS describes some of the major Federal statutes.

4 Table 1-1 lists the numerous permits and licenses issued by Federal, State, and local authorities

5 for activities at PINGP 1 and 2.

6 Table 1-1. Licenses and Permits. Existing environmental authorizations for PINGP 1 and 2,

7 Operations.

Permit Number Responsible Agency

Operating Licenses DPR-42 and U.S. NRC DPR-60

Certification of the Environmental 027-049-218 Minnesota Department of

Lab Health

Construction of intake canal Docket 050-282 Minnesota Department of

system and 050-306 Natural Resources

Construction of discharge canal Docket 050-282 Minnesota Department of

system and 050-306 Natural Resources

National Pollutant Discharge MN0004006 Minnesota Pollution

Elimination System Permit Control Agency

Fish, mussels, and icthyoplankton MN State rules Minnesota Department of

collection Permit 14658,14567, Natural Resources and 159

Surface Water Appropriation 690172 Minnesota Department of

Permit Natural Resources

Permit Nos.

690171, Minnesota Department of

Groundwater Appropriation Permit 785153, Natural Resources

865114, and

965042

Hazardous materials shipments UPR-211635- Minnesota Department of

MN Transportation

Minnesota Pollution Industrial wastewater discharge toMinstPolin Mindustrpia wtewaerdis g t MN0004006 Control Agency, Industrial

Mississippi River Permit Division

Operation of air emissions system Minnesota Pollution

for an electric utility power 00000001-003 Control Agency

generation system Permit

Operation of oil-fired boiler and

diesel-fired engines for emergency 04900030-003 Minnesota Pollution

power, pump cooling water, and Control Agency

fire fighting system Permit

Above ground storage tank MPCA 51557 Minnesota Pollution

registration Control Agency

October 2009 1-11 Draft NUREG-1437, Supplement 39
Purpose and Need for Action

Permit Number Responsible Agency

Hazardous Waste Generator Minnesota Pollution

License, Small Quantity Control Agency

South Carolina Department

Transportation of radioactive waste of Health and

into the State of South Carolina 0051-22-08-X Environmental Control -

Permit Division of Waste

Management

State of Tennessee

Transportation of radioactive waste Department of

into the State of Tennessee Permit T-MN003-L08 Environmental and

Conservation Division of Radiological Health

State of Utah Department

Transportation of radioactive waste 0402002748 of Environmental Quality

into the State of Utah Permit Division of Radiation

Control

Collect fish and ichthyoplankton for SCP-WCR-20- Wisconsin Department of

radiological and biological C-08 Natural Resources

monitoring

Maintenance dredging and erosion U.S A

control discharge canal General GP/LOP-98-MN Engineers

Permit

Air quality monitoring station at DACW37-3-06- U.S. Army Corps of

Lock and Dam Number 3 License 0071 Engineers

Maintenance dredging in front of U.S. Army Corps of

the River Intake Structure GP-01-MN Engineers

Dredging Permit

Hazardous materials shipments 062706 552 U.S. Department of

Registration 0090 Transportation

Retrieve, transport, and

temporarily possess carcasses of U.S. Fish and Wildlife

migratory birds as well as collect, MB074020-0 Service

stabilize, and transport sick/injured

migratory birds Wildlife Permit

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 34335. U.S. Nuclear Regulatory Commission. Washington D.C. "Nuclear Management

Company, LLC, Prairie Island Nuclear Generating Plant, Units 1 and'2; Notice of Acceptance for

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

1

2

3

4

5

6

Draft NUREG-1437, Supplement 39 1-12 October 2009
Purpose and Need for Action

1 Facility Operating License Nos. DPR- 42 and DPR-60 for an Additional 20- Year Period."

2 Federal Register. Vol. 73, No. 117, pp34335-34337. June 17, 2008.

3 73 FR 42628. U.S. Nuclear Regulatory Commission. Washington D.C. "Nuclear Management

4 Company, LLC.; Prairie Island Nuclear Generating Plant, Units 1 and 2; Notice of Intent To

5 Prepare an Environmental Impact Statement and Conduct Scoping Process." Federal Register:

6 Vol. 73, No. 141, pp42628-42630. July 22, 2008.

7 Atomic EnergyAct of 1954.42 U.S.C. 2011, et seq.

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

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

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

11 National Environmental Policy Act of 1969. 42 U.S.C. 4321, et seq.

12 National Historic Preservation Act. 16 U.S.C. 470, et seq.

13 NMC (Nuclear Management Company, LLC). 2008. Prairie Island Nuclear Generating Plant,

14 Units 1 and 2, License Renewal Application, Appendix E -Applicant's Environmental Report,

15 License Renewal Operating Stage. Redwing, Minnesota. April 2008. ADAMS Nos.

16 ML081130677, ML081130681, and ML081130684.

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

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

19 ADAMS Nos. ML040690705 and ML040690738.

20 NRC (U.S. Nuclear Regulatory Commission). 1999. Generic Environmental Impact Statement

21 for License Renewal of Nuclear Plants, Main Report, "Section 6.3 - Transportation, Table 9.1,

22 Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report."

23 NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

24 NRC (U.S. Nuclear Regulatory Commission). 2009. Environmental Impact Statement Scoping

25 Process Summary Report, Prairie Island Nuclear Generating Station, Units 1 and 2. ADAMS

26 Nos. ML090270154 and ML090270418.

27 NRC (U.S. Nuclear Regulatory Commission). 2009a. Summary of site audit related to the review

28 of the license renewal application for Prairie Island Nuclear Generating Plant, Units 1 and 2.

29 ADAMS No. ML083440479.

30

October 2009 1-13 Draft NUREG-1437, Supplement 39

Affected Environment

1 2.0 AFFECTED ENVIRONMENT

2 Prairie Island Nuclear Generating Plant (PINGP 1 and 2) is located on the west bank of the

3 Mississippi River in Goodhue County within the city limits of Red Wing, Minnesota (Figure 2-1).

4 The City of Hastings is located approximately 13 mi (21 kin) northwest (upstream) of the plant.

5 Minneapolis and St. Paul are located approximately 39 mi (63 km) and 32 mi (51 kin),

6 respectively, to the northwest of the plant. For purposes of the evaluation in this report, the

7 "affected environment" is the environment that currently exists at and around PINGP 1 and 2.

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

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

10 environment are presented here. Section 2.1 of this report describes the facility and its

11 operation, and Section 2.2 discusses the affected environment.

12 2.1 Facility Description

13 This assessment of the affected environment begins with a description of PINGP 1 and 2, the

14 source of potential environmental effects. PINGP 1 and 2 is a two-unit pressurized water reactor

15 (PWR) plant that utilizes- a hybrid cooling system, which consists of three modes of operation:

16 open cycle (once-through cooling, with no cooling towers in operation), helper cycle (once17 through cooling, with mechanical draft cooling towers in operation), and closed cycle (using

18 cooling towers to recirculate up to 95 percent of the cooling water). The plant is licensed to

19 operate at 1650 megawatt-thermal (MWt) per unit, or 575 megawatts-electrical (MWe) of gross

20 electrical output per unit.

21 The most conspicuous structures on the site are the four natural draft cooling towers. Other

22 salient buildings on the PINGP 1 and 2 site include the reactor building, auxiliary building,

23 turbine building, intake and plant screenhouses, and the PINGP 1 and 2 substation (NMC

24 2008). Figure 2-2 provides a general layout of the PINGP 1 and 2 site.

25 PINGP 1 and 2 used (or spent) fuel is stored in a pool inside the plant until it is cooled, and

26 transferred to dry storage containers located on site, called the Independent Spent Fuel Storage

27 Installation (ISFSI). Spent fuel will be stored there until the federal government removes it to be

28 reprocessed or stored at a government facility. As of early 2009, Prairie Island's ISFSI housed

29 24 dry-storage containers, which hold a total of approximately 920 spent fuel assemblies (NMC

30 2008).

31 2.1.1 Reactor and Containment Systems

32 PINGP 1 and 2 is a two-unit plant with Westinghouse Electric Company PWRs. PINGP 1 and 2

33 received its construction permit on June 25, 1968. Full commercial operating began on

34 December 16, 1973, for Unit 1 and December 21, 1974, for Unit 2 (NMC 2008).

35 Reactor fuel consists of uranium-dioxide enriched to 5.0 percent by weight with uranium-235

36 enclosed in Zircaloy tubes (NMC 2008). Each reactor core consists of 121 fuel assemblies and

37 29 moveable control rod assemblies (NMC 2008). Control rods consist of stainless steel

38 absorber rods and Zircaloy guide tubes and are used for short-term reactivity control associated

39 with changes in power level and with changes in fuel burnup between adjustments in reactor

40 coolant dissolved boron concentrations (AEC 1973). Average fuel burnup does not exceed

41 62,000 megawatt days per metric ton uranium (MWd/MTU) for the peak rod (NMC 2008).

42 In the PWR power generation system, reactor heat is transferred from the primary coolant to a

43 lower pressure secondary coolant loop, allowing steam to be generated in the steam supply

44 system. The primary coolant loops, two for each unit, each contain one steam generator, one

October 2009 2-1 Draft NUREG-1437, Supplement 39
Affected Environment

1

2

3

4

5

6

7

8

9

10

11

12

13

centrifugal coolant pump, and the interconnected piping. Reactor coolant is pumped from the

reactor through the steam generators and back to the reactor via vertical, single-stage,

centrifugal pumps. Each steam generator is a vertical U-tube unit that produces superheated

steam at a constant pressure over the reactor operating power range. Coolant flows from the

tubes, and steam is generated on the lower pressure shell side. Steam then flows from the

steam generator to the tandem-compound, three-element 1800-rpm turbine generator (AEC

1973). 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 is a cylindrical steel pressure vessel with a hemispherical dome and ellipsoidal

bottom (NMC 2008). Secondary containment consists of a 205-ft (62.5-m)-high by 120-ft (36.6-

m)-diameter cylindrical shield building made of reinforced concrete (NMC 2008).

14 2.1.2 Radioactive Waste Management By design, the operation

of nuclear power plants is

15 PINGP 1 and 2's radioactive waste disposal systems are expected to result in small

16 designed to collect, treat, and dispose of the radioactive and releases of radiological

17 potentially radioactive wastes that are byproducts of plant effluents (gaseous, liquid,

18 operations. Byproducts include: activation products resulting and solid) through

19 from the irradiation of reactor water and impurities therein controlled processes,

20 (principally metallic corrosion products) and fission products However, releases must

21 resulting from defective fuel cladding or uranium contamination meet stringent NRC and

22 within the reactor coolant system. Operating procedures for EPA regulatory limits.

23 radioactive waste disposal systems ensure that the radioactive __ _

24 wastes are safely processed and discharged from the plant in

25 manners that meet the release limits as set forth in 10 CFR Part 20, "Radiation Protection

26 Standards;" 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities;" the

27 plant's technical specifications; and the PINGP 1 and 2 Offsite Dose Calculation Manual (NMC

28 2007b).

29 Radioactive wastes resulting from plant operations are classified as liquid, gaseous, or solid.

30 Liquid radioactive wastes are generated from liquids received directly from portions of the

31 reactor coolant system or were contaminated by contact with liquids from the reactor coolant

32 system. Gaseous radioactive wastes are generated from gases or airborne particulates vented

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

34 solids from the reactor coolant system, solids that have come into contact with reactor coolant

35 system liquids or gases, or solids used in the reactor coolant system or steam and power

36 conversion system operation or maintenance.

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

38 as spent fuel. Spent fuel assemblies are removed from the reactor core and replaced with fresh

39 fuel assemblies during routine refueling outages, typically every 18 to 24 months (NMC 2008).

40 Spent fuel assemblies are then stored for a period of time in the spent fuel pool in the reactor

41 building and later transferred to the PINGP 1 and 2 Independent Spent Fuel Storage

42 Installation. (ISFSI; NMC 2008)

43 PINGP 1 and 2's Offsite Dose Calculation Manual contains the methodology and parameters

44 used to calculate offsite doses resulting from radioactive gaseous and liquid effluents, and the

45 gaseous and liquid effluent monitoring alarm and trip set points used to verify that the

46 radioactive material being discharged meets regulatory limits (NMC 2007b). The Offsite Dose

Draft NUREG-1437, Supplement 39 2-2 October 2009
Affected Environment

1 Calculation Manual also contains the radioactive effluent controls and radiological

2 environmental monitoring activities and descriptions of the information that should be included in

3 the annual Radiological Environmental Operating Report and annual Radioactive Effluent

4 Release Report required by Appendix I, "Numerical Guides for Design Objectives and Limiting

5 Conditions for Operation to Meet the Criterion 'As Low as is Reasonably Achievable' (ALARA)

6 for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents," to 10 CFR

7 Part 50, and 10 CFR 50.36a, "Technical Specifications on Effluents from Nuclear Power

8 Reactors," respectively.

9 2.1.2.1 Radioactive Liquid Waste

10 The PINGP 1 and 2's liquid radioactive waste processing system, in combination with the steam

11 generator blowdown system, collects, holds, treats, processes, and monitors all liquid

12 radioactive wastes for reuse or disposal. The PINGP 1 and 2 liquid radioactive waste

13 processing system segregates various stream wastes at the point of their collection into the

14 following categories: non-aerated and aerated wastes, chemical drains, steam generator

15 blowdown and resin waste.

October 2009 2-3 Draft NUREG-1437, Supplement 39
Affected Environment

7/ N

Sherbsirr4eNýIoni Wildlife Chis*qC I______ 1i _ 

61 River Ra015 S

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cwmv Region (Source: NMC 2008)

1

Draft NUREG-1437, Supplement 39 2-4 October 2009
Affected Environment

Legend

XceI oErgy Promlyt

M Plant FeaOl et

- Pormne,rw n tolan oniog

Lmal NeVtor~ord mr Rw.] Rosa

1 0 500 1,000 wi 3000 4,000

Figure 2-2. PINGP 1 and 2 General Site Layout

and Exclusion Area Boundary

(Source: NMC 2008)

1

October 2009 2-5 Draft NUREG-1437, Supplement 39
Affected Environment

1 Liquid wastes are collected in sumps and drain tanks and transferred to the appropriate

2 subsystem collection tanks for subsequent treatment, disposal, or recycling. Non-aerated waste

3 is originated primarily by the reactor coolant system, which is transferred to the holdup tanks for

4 processing after collection. Aerated waste originates primarily from the floor drains, aerated

5 equipment drains and leaks, laundry equipment drains, and decontamination area drains and is

6 transferred to aerated drains treatment tanks for monitoring and final release or reprocessing.

7 Chemical drains from the hot sampling station and hot chemical laboratory are collected in the

8 chemical drain tank, periodically neutralized (if needed), transferred to the aerated sump tank

9 and finally transferred to the aerated drains treatment collection tanks for processing through

10 the aerated drains treatment cartridge filters and three flushable ion-exchangers, which are

11 shared by PINGP 1 and 2, and final discharge. PINGP 1 and 2 steam generators blowdown

12 waste is discharged into a flash tank in the associated unit, transferred to the holdup tanks and

13 directed to the condenser through the system of a filter and ion exchanger under normal

14 operation conditions. Occasionally (such as during startup) the blowdown used to control steam

15 generator chemistry is released to the circulating water canal via a radiation monitor. Liquid

16 releases from the steam generator blowdown monitor tank are made based on the results of a

17 radiochemical batch analysis of the tank contents and are monitored by the waste disposal

18 system liquid effluent monitor. Resin waste is collected from the resin disposal building sump in

19 the drains collection tanks or the waste holdup tank. Waste water from the truck loading

20 enclosure sump is pumped to the aerated sump tank and further processed by the liquid

21 radioactive waste processing system. The PINGP 1 and 2 liquid radwaste discharge point and

22 steam generator blowdown was extended from the original discharge point at the head of the

23 circulating water discharge canal to just upstream of the circulating water canal discharge

24 structure at the Mississippi River in order to minimize the potential for the tritium to enter the

25 local groundwater. Liquid releases are limited to the maximum extent possible to satisfy the

26 design objectives of Appendix I to 10 CFR Part 50. Liquid discharges occur when the

27 radioactive material has been analyzed and the projected dose to members of the public has

28 been calculated to be within the values specified in the Offsite Dose Calculation Manual, 10

29 CFR 20, and Appendix I to 10 CFR 50. (NMC 2001)

30 The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the PINGP 1 and 2 radioactive

31 effluent release reports for 2003 through 2007 for liquid effluents (NMC 2004a, 2005a, 2006b,

32 2007c, 2008b). The releases in 2007 were representative of the releases in prior years.

33 Variations in the amount of radioactive effluents released from year to year are expected based

34 on the overall performance of the plant and the number and scope of outages. The liquid

35 radioactive wastes reported by PINGP 1 and 2 are reasonable and no unusual trends were

36 noted. These releases would result in minimal doses to members of the public that are well

37 below the ALARA dose design objectives of Appendix I to 10 CFR 50, as discussed in Section

38 4.8.1.

39 Northern States Power Co. (NSP) is planning to replace the Unit 2 steam generators during the

40 period of extended operations. Such an action is not likely to result in a significant increase of

41 liquid radioactive effluents being discharged as compared to the amount discharged during

42 normal plant operations. This is based on consideration that any liquids generated, processed,

43 and released during the outage will be offset by the amount of liquid waste that would not be

44 generated, processed, and released during normal plant operations. Based on the historical

45 evaluation and there being no significant increase in liquid effluents from the replacement of the

46 PINGP Unit 2 steam generators, similar quantities of radioactive liquid effluents are expected to

47 be generated during normal operations and outages from PINGP 1 and 2 during the period of

48 extended operations.

Draft NUREG-1437, Supplement 39 2-6 October 2009
Affected Environment

1 2.1.2.2 Radioactive Gaseous Waste

2 The gaseous radioactive waste processing system and the plant ventilation exhaust system

3 control, collect, process, store, and dispose of gaseous radioactive wastes generated as a result

4 of normal operation. Gaseous effluents are treated before release to the environment. PINGP 1

5 and 2's gaseous radioactive waste processing system consists of two interconnected process

6 loops: the low level and the high level loops.

7 PINGP 1 and 2's gaseous radioactive waste processing system receives radioactive gases

8 mainly from the four sources: displacement of cover gases as liquids accumulate in various

9 tanks, miscellaneous equipment vents and relief tanks, automatic gas analysis and sampling for

10 hydrogen and oxygen in cover gases and nitrogen stripping of reactor coolant to remove

11 hydrogen during shutdown operations. The low-level loop is designed to accumulate, contain

12 and process cover gases from all these sources. During normal operating conditions the gas

13 flow is split through the hydrogen recombiner to the decay tanks. The system is vented into the

14 atmosphere and resulted in an occasional discharge only in case of the disposal of the gases

15 collected from shutdown operations and from miscellaneous vents. Prior to discharge the low16 level decay tank content is sampled and analyzed to record gas activity, and discharged to the

17 auxiliary building vent at a controlled rate. The high-level loop is designed to collect, hold and

18 process high-activity gases received during hydrogen reactor coolant stripping that allows

19 removing of the fission gases. The high-level loop is normally not used because the activity level

20 of the reactor coolant fission gas is usually low. The high-level loop gas decay tanks are used

21 for the low-level loop reserve holding capacity, which minimizes the frequency of gas decay tank

22 releases. PINGP 1 and 2 maintains radioactive gaseous effluents in accordance with the

23 procedures and methodology described in the Offsite Dose Calculation Manual. The gaseous

24 radioactive waste processing system is used to reduce radioactive materials in gaseous

25 effluents before discharge to meet the ALARA dose objectives in Appendix I to10 CFR Part 50.

26 (NMC 2007b)

27 The NRC staff reviewed the PINGP 1 and 2 radioactive effluent release reports for 2003 through

28 2007 for gaseous effluents (NMC 2004a; 2005a; 2006b; 2007c; 2008b). The gaseous

29 discharges for 2007 are consistent with the radioactive gaseous effluents discharged from 2003

30 through 2006. Based on the gaseous waste processing systems and effluent controls and

31 performance from 2003 through 2007, similar small quantities of radioactive gaseous effluents

32 are expected from PINGP 1 and 2 and are not expected to increase or decrease during the

33 period of extended operation. These releases would result in doses to members of the public

34 that are well below the ALARA dose design objectives. Section 4.8.1 provides a discussion of

35 the calculated doses to the maximally exposed individual as a result of these releases.

36 NSP is planning to replace the Unit 2 steam generators during the period of extended

37 operations. Such an action is not likely to result in a significant increase of gaseous radioactive

38 effluents being discharged as compared to the amount discharged during normal plant

39 operations. This is based on consideration that any gaseous effluents released during the

40 outage will be offset by the amount of gaseous effluents that would not be generated,

41 processed, and released during normal plant operations. Based on the historical evaluation and

42 there being no significant increase in gaseous effluents from the replacement of the PINGP Unit

43 2 steam generators, similar quantities of radioactive gaseous effluents are expected to be

44 generated during normal operations and outages from PINGP 1 and 2 during the period of

45 extended operations.

46 2.1.2.3 Solid Radioactive Waste

47 The solid radioactive waste management system at PINGP 1 and 2 is designed to collect,

48 package, provide shielded storage facilities and to allow temporary storage prior to offsite

October 2009 2-7 Draft NUREG-1437, Supplement 39
Affected Environment

1 shipment for processing or disposal of low-level radioactive wastes generated as a result of

2 normal plant operation. The system is designed to maintain ALARA radiation exposure to plant

3 personnel in accordance with General Design Criterion 60 of the Appendix A to 10 CFR Part 50

4 and Regulatory Guide 8.8. This system maintains personnel exposures below 10 CFR Part 20

5 requirements. The solid radioactive waste management system equipment is located in the

6 radioactive waste processing facility and the dry active waste facility. The dry active waste

7 facility is also capable of storing the packaged waste until it is shipped offsite to a waste

8 processor for treatment/disposal or to the licensed burial sites. Transportation and disposal of

9 solid radioactive wastes are performed in accordance with the applicable requirements of 10

10 CFR Part 71 and 10 CFR Part 61, respectively. Access to the process equipment and solid

11 radioactive waste storage areas is controlled to minimize personnel exposure by suitable

12 barriers such as locked doors, gates, or control cards.

13 Low-level mixed waste is waste that exhibits hazardous characteristics and contains low levels

14 of radioactivity. PINPGP does not produce any low-level mixed waste.

15 PINGP 1 and 2 solid wastes are comprised mainly of dry active waste such as contaminated

16 paper, plastic, wood, metals and spent resin that can be compacted for offsite disposal or stored

17 onsite. PINGP 1 and 2's solid radioactive waste management system operations include

18 dewatering and pH adjustment of beaded resins, powdered resins, evaporator bottoms, and

19 solidification of the waste with an in-drum cement system. Contaminated metals are compacted

20 for offsite disposal (or may be stored onsite if the disposal site is not available). Spent resins are

21 received, dewatered and handled in the disposal building, next to the radwaste building (NMC

22 2001).

23 The NRC staff reviewed PINGP 1 and 2 solid radioactive waste reports for 2003 through 2007

24 (NMC 2004b; 2005b; 2006c; 2007d; 2008c). Based on the performance from 2003 through

25 2007, similar quantities of radioactive solid wastes are expected from PINGP 1 and 2 during the

26 period of extended operation. Variations on the amount of solid radioactive waste generated

27 and shipped from year to year are expected based on the overall performance of the plant and

28 the number and scope of maintenance work and outages. The volume and activity of solid

29 radioactive waste reported by PINGP 1 and 2 are reasonable and no unusual trends were

30 noted.

31 NSP is planning to replace the Unit 2 steam generators during the period of extended

32 operations. Such an action is likely to result in a small increase in the amount of solid

33 radioactive waste generated. During an outage of this type, there will be an increased use of

34 protective clothing, safety equipment, increased use of filters, and a general increase in

35 generation of debris that will have to be disposed of as radioactive waste. However, the

36 increased volume is expected to be within the range of solid waste that can be safely handled

37 by PINGP 1 and 2 during the period of extended operations.

38 2.1.3 Nonradlological Wastes

39 Section 2.3.7.3 of the GElS states, "The nonradioactive waste generated at nuclear power

40 plants is generally not of concern unless it is classified as Resource Conservation and Recovery

41 Act (RCRA) waste. All waste that is hazardous, that is, classified as RCRA waste, is packaged

42 and disposed of in a licensed landfill consistent with the provisions of RCRA." RCRA governs

43 the disposal of solid and hazardous wastes, and its regulations are contained in Title 40,

44 "Protection of the Environment," Parts 239 through 299 (40 CFR 239, et seq.), of the Code of

45 Federal Regulations. Parts 239 through 259 of Title 40 contain regulations for solid

46 (nonhazardous) waste, and Parts 260 through 279 contain regulations for hazardous waste.

47 RCRA Subtitle C establishes a system for controlling hazardous waste from "cradle-to-grave,"

Draft NUREG-1437, Supplement 39 2-8 October 2009
Affected Environment

1 and RCRA Subtitle D encourages States to develop comprehensive plans to manage

2 nonhazardous solid waste and mandates minimum technological standards for municipal solid

3 waste landfills (EPA 2007). In Minnesota, RCRA regulations are administered by the Minnesota

4 Pollution Control Agency (MPCA). MPCA addresses the identification, generation, minimization,

5 transportation, and final treatment, storage, or disposal of hazardous and nonhazardous wastes.

6 PINGP 1 and 2 generate nonradioactive waste from routine plant maintenance, cleaning, and

7 operational processes-most of this waste consists of nonhazardous waste oil, oil-filled

8 equipment, and oily debris (NMC 2008).

9 2.1.3.1 Hazardous Waste

10 Hazardous waste means solid waste, or a combination of solid wastes, which, because of its

11 quantity, concentration, or physical, chemical, or infectious characteristics, may cause or

12 contribute to an increase in mortality or serious illness. Such waste may also pose a significant

13 present or potential hazard to human health or the environment if it is not properly treated,

14 stored, transported, disposed of, or otherwise handled (40 CFR Part 261, "Identification and

15 Listing of Hazardous Waste"). PINGP 1 and 2 generate a small quantity of hazardous waste

16 including spent and expired chemicals, laboratory chemical wastes, Freon-contaminated oil, and

17 occasional project-specific wastes (NMC 2008).

18 PINGP 1 and 2 are classified as a Small Quantity Generator of hazardous waste because the

19 plant generates less than 1,000 kilograms (kg) (2,205 pounds (Ibs)) of hazardous waste in one

20 month, and no more than 6,000 kg (13,228 Ibs) of hazardous waste may be accumulated on site

21 at any one time (EPA 2007a). According to the U.S. Environmental Protection Agency (EPA)

22 Envirofacts Warehouse online database, PINGP 1 and 2 is classified as an active small quantity

23 generator of hazardous wastes (EPA ID No. MND049537780). The Envirofacts Warehouse

24 database showed no violations for PINGP 1 and 2 (EPA 2009). In accordance with the

25 Minnesota hazardous waste generator re-licensing process (Minnesota Administrative Rules,

26 part 7045.0248), PINGP 1 and 2 submit annual reports to MPCA detailing the amounts and

27 types of hazardous wastes generated at the plant. A review of hazardous waste license

28 applications submitted by Xcel Energy to MPCA revealed that through 2003 through 2007,

29 PINGP 1 and 2 generated approximately 12,575 kg (27,724 Ibs) of hazardous waste. The

30 majority of this was paint-related waste, hazardous metals, and corrosive liquids.

31 The Emergency Planning and Community Right-to-Know Act (EPCRA) requires applicable

32 facilities to provide information on hazardous and toxic chemicals to local emergency planning

33 authorities and the EPA. On October 17, 2008, EPA finalized several changes to the

34 Emergency Planning Notification (Section 302), Emergency Release Notification (Section 304),

35 and Hazardous Chemical Storage Reporting Requirements (Sections 311 and 312) regulations

36 (73 FR 65452). PINGP 1 and 2 are subject to Federal EPCRA reporting requirements, and thus

37 submits annual Emergency and Hazardous Chemical Inventory Forms to the Minnesota

38 Emergency Response Commission, pursuant to Section 312.

39 2.1.3.2 Universal Waste

40 Universal waste is hazardous waste that is generated in a variety of settings by a vast

41 community, which poses collection and management problems. EPA classifies several

42 hazardous wastes as universal wastes-including batteries, certain pesticides, mercury43 containing devices, and fluorescent lamps (40 CFR Part 273, "Standards for Universal Waste

44 Management"). Minnesota has incorporated EPA's regulations regarding universal wastes in

45 Minnesota Administrative Rules part 7045.1400, "Adoption of Federal Standards for Universal

46 Waste Management." MPCA defines lighting ballasts, polychlorinated biphenyl (PCB) small

47 capacitors, mercury containing devices, batteries, antifreeze, circuit boards, electronics,

48 photographic negatives, cathode ray tubes, alkaline batteries, and non-TCLP (toxic

October 2009 2-9 Draft NUREG-1437, Supplement 39
Affected Environment

1 characteristic leaching procedure) fluorescent and HID (high intensity discharge) lamps as

2 universal waste. PINGP 1 and 2 are classified as a Small Quantity Generator of universal

3 waste, accumulating less than 5,000 kg (11,023 Ibs) of universal waste per month (NMC 2008).

4 2.1.3.3 Permitted Discharges

5 PINGP 1 and 2 generate two types of wastewater: industrial effluents and sanitary liquid wastes.

6 Industrial effluents, including cooling water, are discharged to the Mississippi River according to

7 the facility's individual wastewater discharge NPDES permit (No. MD0004006), as enforced by

8 MPCA (MPCA 2006). Normal operating processes used to control the pH of reactor coolant,

9 prevent scale and erosion in the cooling system, and clean and defoul the condenser of

10 biological organisms, all generate chemical and biocide wastes. Waste liquids from these

11 processes are combined with cooling water and are discharged to the Mississippi River

12 according to the NPDES permit limitations.

13 Sanitary liquid wastes are directed to seven onsite septic systems. Section 2.1.7.3 of this report

14 provides more information on the PINGP 1 and 2 NPDES permit and effluent limitations, and

15 radioactive liquid waste is addressed in Section 2.1.2.1.

16 2.1.3.4 Pollution Prevention and Waste Minimization

17 Under NSP's (formerly Xcel Energy's) Waste Management Program Procedure/Waste

18 Management Guidance Manual, PINGP 1 and 2 implement a waste minimization program that

19 consists of steps such as segregating hazardous and nonhazardous wastes, choosing

20 nonhazardous substitutes when possible, recycling or reclaiming appropriate waste materials,

21 monitoring expired chemicals to determine minimum stocking requirements to reduce recurring

22 excess, finding alternate uses for excess materials, or returning unused materials to the

23 manufacturer. The manual also provides guidelines for proper handling, storage, transport, and

24 disposal of hazardous materials (NMC 2008). NRC staff determined at the site audit in August

25 of 2008 that PINGP 1 and 2 do not recycle common waste materials such as paper, plastic, or

26 aluminum.

27 In support of nonradioactive waste minimization efforts, the EPA Office of Pollution Prevention

28 and Toxics established a clearinghouse that provides information regarding waste management

29 and technical and operational approaches to pollution prevention. The EPA clearinghouse can

30 be used as a source for additional opportunities for waste minimization and pollution prevention

31 at PINGP 1 and 2, as appropriate (EPA 2008b).

32 2.1.4 Plant Operation and Maintenance

33 Maintenance activities conducted at PINGP 1 and 2 include inspection, testing, and surveillance

34 to maintain the current licensing basis of the facility and to ensure compliance with

35 environmental and safety requirements. Various programs and activities currently exist at

36 PINGP 1 and 2 to maintain, inspect, test, and monitor the performance of facility equipment.

37 These maintenance activities include inspection requirements for reactor vessel materials, boiler

38 and pressure vessel in-service inspection and testing, a maintenance structures monitoring

39 program, and maintenance of water chemistry.

40 Additional programs include those implemented to meet technical specification surveillance

41 requirements, those implemented in response to the NRC generic communications, and various

42 periodic maintenance, testing, and inspection procedures. Certain program activities are

43 performed during the operation of the unit, while others are performed during scheduled

44 refueling outages. Nuclear power plants must periodically discontinue the production of

45 electricity for refueling, periodic in-service inspection, and scheduled maintenance. PINGP 1

46 and 2 refuel on at 20-month interval.

Draft NUREG-1437, Supplement 39 2-10 October 2009
Affected Environment

1 2.1.5 Power Transmission System

2 The PINGP 1 and 2 substation, located on the PINGP 1 and 2 site just north of the generating

3 facilities, provides connections for four 345-kV lines, owned by NSP and maintained by Xcel

4 Energy, and one 161-kV line, owned and maintained by Great River Energy (Figure 2-3). Unless

5 otherwise noted, the discussion of the power transmission system is adapted from the ER (NMC

6 2008), or information gathered during NRC's site audit.

7 NSP constructed approximately 78 mi (126 km) of new transmission lines to support the

8 operation of PINGP 1 and 2 and acquired 32.8 mi (528 km) of new right-of-way (ROW) land for

9 these newly constructed lines (AEC 1973). In total, the transmission lines associated with the

10 operation of PINGP 1 and 2 comprise approximately 2300 ac (930 ha) of ROW land.

11 Transmission lines considered in scope for license renewal are those constructed specifically to

12 connect the facility to the transmission system (10 CFR 51.53(c)(3)(ii)(H)); therefore, the Red

13 Rock 1 connection, the Adams connection, the Red Rock 2 line, the Blue Lake Line, and the

14 Spring Creek line are considered in-scope for this supplemental environmental impact

15 statement (SEIS) and are discussed below in detail. These transmission lines span Goodhue,

16 Dakota, Scott, and Washington Counties (Figure 2-4).

17 The Red Rock 1 connection and the Adams connection split a previously existing transmission

18 line, the 345-kV Red Rock-Adams line, in order to connect the line to the PINGP 1 and 2

19 substation. Because the Red Rock-Adams line was constructed and put into service before the

20 construction of PINGP 1 and 2, only the two portions constructed to connect this line to the

21 PINGP 1 and 2 substation are considered in-scope for purposes of this analysis. Each

22 connection is 345 kV and 2.5 mi (4.0 km) in length. The connections are contained within

23 Goodhue County and share a 250-ft (76-m)-wide ROW with the Red Rock 2 and Blue Lake

24 lines.

25 The 345-kV Red Rock 2 line runs northwest for approximately 32 mi (52 km) to the Red Rock

26 substation in St. Paul, Minnesota. The line spans Goodhue, Dakota, and Washington Counties.

27 The Red Rock 2 line shares a 250-ft (76-m)-wide ROW with the Red Rock-Adams transmission

28 line connections and the Blue Lake line for the first 2.5 mi (4.0 km) and shares a 350-ft (107-m)-

29 wide ROW with the Red Rock 1 line for the remaining length. Construction of this line did not

30 require the creation of any additional ROWs because the entire length of the line was routed

31 along an existing ROW.

32 The 345-kV Blue Lake line runs west for approximately 50 mi (80 km) to the Scott County

33 substation. The line spans Goodhue, Dakota, and Scott Counties. The Blue Lake line shares a

34 250-ft (76-m)-wide ROW with the Red Rock-Adams transmission line connections and the Red

35 Rock 2 line for the first 2.5 mi (4.0 km) and has a 150-ft (46-m)-wide ROW for the remaining

36 length. The first segment of this line required the creation of a new ROW from PINGP 1 and 2 to

37 the Inver Grove substation in Dakota County, Minnesota; the remaining length to the Blue Lake

38 substation was routed along an existing ROW.

39 The 161-kV Spring Creek line runs south for approximately 5 mi (8 km) to the Spring Creek

40 substation near Red Wing, Minnesota. The line is contained within Goodhue County and has a

41 100-ft (30 m)-wide ROW.

42 Xcel Energy and Great River Energy maintain transmission line ROWs to promote low-growing

43 grasses and non-woody vegetation directly under towers and conductors. ROW borders are

44 maintained to promote slow-growing shrubs and shorter trees that do not interfere with

45 transmission lines or structures. Woody vegetation within ROWs may be pruned, chemically

46 controlled, or removed to ensure adequate line clearance; however, neither Xcel Energy nor

47 Great River Energy disturb or remove trees and shrubs unless they have the potential to

October 2009 2-11 Draft NUREG-1437, Supplement 39
Affected Environment

1 interfere with transmission facilities. The majority of ROWs associated with PINGP 1 and 2

2 consist of grasslands or agricultural land, which require minimal maintenance. Herbicides, when

3 necessary, are applied by licensed certified applicators in full compliance with the Minnesota

4 Pesticide Control Law of 1987. All herbicides used near waterways or in wetland areas are

5 EPA-approved for aquatic application. Xcel Energy does not spray herbicides on foliage at

6 heights above 10 ft (3 m), which minimizes the risk of drift to wetlands and waterways. For

7 pesticides that are not approved for aquatic use, Great River Energy requires a non-treated

8 buffer zone of 25 to 50 ft (7.6 to 15.2 m) between the treated areas and any waterways.

9

Draft NUREG-1437, Supplement 39 2-12 October 2009
Affected Environment

Legend

PmodwdlOn wen

Tanrýss•on Line

r• Plan| Featulim 1 oCx• 200

a ~Feel - Locat, Neigpmoo. or Rural Road

Railroad

Figure 2-3. PINGP I and 2 Substation and

Transmission Line Layout (Source: NMC 2008)

2

October 2009 2-13 Draft NUREG-1437, Supplement 39
Affected Environment

1

Draft NUREG-1437, Supplement 39 2-14 October 2009
Affected Environment

1 Both Xcel Energy and Great River Energy perform regular flyovers to identify areas that require

2 maintenance. Because much of the ROW land is privately owned agricultural land, Xcel Energy

3 will avoid spraying herbicides at the owner's request and will only remove trees and shrubs that

4 are hazardous to transmission lines or structures. The Xcel Energy vegetative management

5 guidelines also includes measures to ensure avian protection by including procedures workers

6 must follow when tree crews encounter active and/or inactive nests and dead or injured birds.

7 All transmission lines will remain a permanent part of the transmission system and will be

8 maintained by Xcel Energy and Great River Energy, regardless of PINGP 1 and 2 continued

9 operation.

10 Table 2-1. PINGP 1 and 2 Transmission Lines. Five transmission lines convey

11 electricity from PINGP I and 2 to the regional electric transmission system via three

12 rights of way (ROWs).

Approximate ROW

Distance Width ROW Area

Line Owner kV mi (km) ft (m) ac (ha)

Red Rock 1 connection NSP (Formerly Xcel) 345 2.5 (4.0) 250 (76) 76 (31)ya,

Red Rock 2 NSP 345 32 (52) 350 (107) 1360 (550)(a)

Blue Lake NSP 345 50 (80) 150 (46) 940 (380)(a)

Adams connection NSP 354 2.5 (4.0) 250 (76) 76 (31)(a)

Spring Creek Great River Energy 161 5 (8) 100 (30) 61(25)

(a) ROW area values for the Red Rock 1 connection, the Adams connection, the Red Rock 2 line, and the Blue Lake line

include 76 ac (31 ha) shared by all four lines along the first 2.5 mi (4.0 kin) of ROW traveling west from PINGP 1 and 2.

Source: NMC 2008

13 2.1.6 Cooling and Auxiliary Water Systems

14 The Mississippi River is the source for cooling water for the main condenser at PINGP 1 and 2.

15 Cooling river water can be circulated through the station in one of three modes of operation:

16 open cycle (once-through cooling, with no cooling towers in operation), helper cycle (once17 through cooling, with mechanical draft cooling towers in operation), and closed cycle (using

18 cooling towers to recirculate up to 95 percent of the cooling water). The mode of operation is

19 selected by the applicant to limit the heat discharged to the river to ensure compliance with the

20 thermal limits of the NPDES permit No. MD0004006 (MPCA 2006; NMC 2008).

21 The components of the current cooling water system are the eight intake bays, the intake

22 screenhouse, trash racks, traveling screens, high/low pressure wash systems, fish return

23 system, bypass gates, intake canal, plant screenhouse, circulating water pumps, condensers,

24 discharge basin, mechanical draft cooling towers, discharge canal, and distribution basin. (NMC

25 2008)

26 The Final Environmental Statement (FES) for PINGP 1 and 2 (NRC 1973) describes the original

27 cooling water system. Water was withdrawn from the Mississippi River into the 750-ft (230-m)-

28 long intake canal, and into what is now called the plant screenhouse. Inside the screenhouse,

29 the water passed through trash racks and coarse-mesh traveling screens to remove fish and

30 debris before supplying the condensers. The plant could operate in each of the three modes

October 2009 2-15 Draft NUREG-1437, Supplement 39
Affected Environment

1 described above, and so the heated effluent from the plant was either pumped to the cooling

2 towers or released to the river, via an 800-ft (240-m)-long canal.

3 In the early 1980s, the State of Minnesota directed PINGP 1 and 2 to modify the cooling system

4 to reduce impacts to aquatic communities. This was done by installing the intake screenhouse,

5 equipped with trash racks, coarse- and fine-mesh traveling screens, variable pressure wash

6 systems, and a fish return system, described below (Stone and Webster 1983).

7 Water flows from the river, under a skimmer wall, into the eight intake bay openings, each 18.5

8 by 11.2 ft (5.6 by 3.4 m), of the intake screenhouse. The intake bays each have a trash rack, a

9 traveling screen, and high/low pressure wash systems, and a fish return system. After passing

10 through the intake screenhouse, water flows down the intake canal to the plant screenhouse,

11 where four 147,000-gpm (9.3-m3/s) circulating water pumps supply water to the condensers for

12 a total flow for both units of approximately 588,000 gpm (37.1 m3/s). (NMC 2008)

13 After leaving the condensers, the cooling water then enters the discharge basin, and from there

14 the final path of the cooling water is determined by the operating mode of the plant. In open

15 cycle, the cooling water flows from discharge basin, through the distribution basin, into the

16 discharge canal, ultimately returning to the Mississippi River. In helper and closed cycles, the

17 water is pumped from discharge basin to the cooling towers, and from there returns to the intake

18 canal for recirculation (closed cycle) or flows through the distribution basin, into the discharge

19 canal, and out to the Mississippi River (helper cycle). A small amount of warm water from the

20 discharge canal is pumped to the intake structure to prevent ice formation on trash racks,

21 traveling screens, and bypass gates. (NMC 2008)

22 2.1.6.1 Intake Screenhouse and Fish Return

23 Within the intake screenhouse are the trash racks and traveling screens. The trash rack in each

24 bay is made of 3/8 in. by 3 in. (0.95 cm by 7.6 cm) steel bars, mounted on an incline 1.5 in. (3.8

25 cm) apart; a trash rake clears accumulated debris (NMC 20008; Stone and Webster 1983).

26 After passing through.the trash rack, the water flows through the traveling screens. The NPDES

27 permit No. MD0004006, issued June 30, 2006, by the MPCA, dictates that from September 1

28 through March 31, PINGP 1 and 2 may operate with up to 3/8 in. (0.95 cm) mesh traveling

29 screens, and that from April 1 through August 31, the traveling screens must be 0.5 mm (0.02

30 in.) fine mesh screens (MPCA 2006). Before the cooling water system was modified in 1983, the

31 approach velocity to the existing traveling screens was 1.3 fps (0.40 m/s) at normal water levels

32 and 1.4 fps (0.43 m/s) at low water levels. The design criteria for the average face velocity

33 through the gross area of the screen material for the fine mesh screens should not exceed 0.5

34 fps (0.15 m/s) at low water level and a discharge rate of 800 cfs (22.6 m3/s). Flow

35 measurements taken in 1983 and 1984 were less than 0.2 m/s (0.66 fps), and most were below

36 0.1 m/s (0.33 fps). Intake velocities were again studied in 2003, during coarse mesh screen

37 operation, and the results of that study are shown in Table 2-2. Based on this data, the authors

38 of the study concluded that the intake velocities are not outside the design requirements. (Xcel

39 Energy Environmental Services 2006).

40

Draft NUREG-1437, Supplement 39 2-16 October 2009
Affected Environment

1

2

3

Table 2-2. Post-modification Velocity Profiles for the PINGP 1 and 2

Cooling Water Intake System

Blowdown in River Level in Average Velocity at Center of Bays in Average Velocity

cfs (m3

/s) ft (m) fps (m/s) Across All Bays

Maximum Minimum in fps (mis)

1006 (28) 674.6 (205.6) 0.388 (0.118) 0.599 (0.183) 0.481 (0.147)

815 (23) 674.6 (205.6) 0.337 (0.103) 0.427 (0.130) 0.362 (0.110)

Blowdown in River Level in Average Calculated Through-Screen Average Velocity

cfs (m3/s) ft (m) Velocity (Coarse Mesh) in fps (m/s) Across All Bays

Maximum Minimum in fps (m/s)

1006 (28) 674.6 (205.6) 0.807 (0.246) 1.246 (0.380) 1.00 (0.305)

815 (23) 674.6 (205.6) 0.701 (0.214) 0.888 (0.271) 0.752 (0.229)

Blowdown in River Level in Average Calculated Through-Screen Average Velocity

cfs (m3/s) ft (m) Velocity (Fine Mesh) in fps (m/s) Across All Bays

Maximum Minimum in fps (mis)

1006 (28) 674.6 (205.6) 0.899 (0.274) 1.388 (0.423) 1.114 (0.340)

815 (23) 674.6 (205.6) 0.781 (0.238) 0.989 (0.301) 0.838 (0.255)

Source: adapted from Xcel Energy Environmental Services 2006

To remove larvae and fish from the upward travel side of the screen, a low pressure spray is

used, at 10 psi (0.7 kg/cm2) from the inside for the fine mesh screen (larval screenwash), and at

20 (1.4 kg/cm2 ) psi from the outside when the coarse mesh screen is in use (fish screenwash)

(Stone and Webster 1983; NMC 2008). On the downward travel side of the screen, a high

pressure spray from the inside is used to remove debris from the screens, at 50 psi (3.5 kg/cm 2)

for the fine mesh screen and 100 psi (7 kg/cm 2) for the coarse mesh screen (NMC 2008). The

fine mesh screens rotate continuously between 3 and 20 fpm (1 and 6 m/min), based on the

amount of debris collected; the coarse mesh screens rotate at the same range of speeds when

the screen differential is higher than 4 in. (10 cm) or if the screens have not rotated for 8 hours

(Xcel Energy Environmental Services 2006; NMC 2008).

Fish are washed off the upward travel side of the screens into a trough and debris is washed

from the downward travel side into a separate trough. The troughs combine into a common

trough and are transported back to the river via a 2200-ft-(670-m)-long, buried pipe, which

discharges into the river 1500 ft (460 m) south of the Intake Screenhouse, below mean water

elevation, and at a depth below any ice cover. Fish and debris travel through the pipe at

velocities between 3 to 5 ft/s (1 to 1.5 m/s), but may speed up in sections of the pipe. (Stone

and Webster 1983; Xcel Energy Environmental Services 2006; NMC 2008).

If the screens are clogged, the head differential across the traveling screens or across the

intake screenhouse can become too high, triggering bypass gates to open allowing water to

circumvent the intake screenhouse. The plant screenhouse (part of the original cooling system)

is still equipped with 3/8 in. screens that remove debris before the water enters the condensers,

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October 2009 2-17 Draft NUREG-1437, Supplement 39
Affected Environment

1 and the intake screens are cleared to minimize the time the bypass gates are open. (Stone and

2 Webster 1983).

3 2.1.6.2 Discharge and Cooling Tower System

4 The discharge basin receives all of the cooling water from the condensers. The path that the

5 water takes next is dependent on the operating mode of the cooling system.

6 During open cycle, the water flows through the distribution basin, into the discharge canal, and

7 out to the Mississippi River. During closed and helper cycles, the water is pumped to the cooling

8 towers. The cooled water is then routed via the cooling tower return canal to the distribution

9 basin. In closed cycle, the distribution basin returns the water to the intake canal to recycle

10 through the condensers. In helper cycle, the distribution basin routes the water to the discharge

11 canal to be discharged into the river. (NMC 2008)

12 Water enters the discharge canal through four 10 by 11 ft (3 by 3.4 m) openings to four sluice

13 gates which are operated by motors. The sluice gates lead to four pipes, which vary in diameter

14 [5, 6, 7, and 8 ft (1.5, 1.8, 2.1, and 2.4 m)] and are used in different combinations to achieve the

15 desired discharge rate. If only the smallest pipe is in use, the discharge rate is 150 cfs (4 m3/s).

16 If all four pipes are used (all sluice gates are open), the maximum discharge rate is 1390 cfs (39

17 m3

/s), and the velocity of the discharging water is 10.17 ft/s (3.1 m/s). (Stone and Webster

18 1983)

19 The mechanical draft cooling tower system includes four cooling towers, fans, water distribution

20 headers, and basins. Each tower, made up of a bank of 12 sections cells, includes a cooling

21 tower pump, which pumps water from the discharge basin through distribution pipes to the top

22 of the cooling tower. Spray nozzles disperse the water, which drops through a maze of "fill" to

23 the basin at the base of the cooling towers. Fans blow air up through the falling water,

24 evaporating water and allowing the heat to disperse out the top of the cooling towers into the

25 atmosphere. The water in the cooling tower basin flows through the cooling tower return canal

26 to the distribution basin, where it can either be routed back through the facility's condensers by

27 way of the intake canal (closed cycle) or sent to the discharge canal to return to the Mississippi

28 River (helper cycle). The cooling towers can be used for the total circulating water flow of

29 588,000 gpm (37.1 m3/s) and can remove up to 96 percent of the waste heat created by the

30 facility. (NMC 2008)

31 2.1.6.3 Requirements Under NPDES Permit

32 In accordance with the Federal Water Pollution Control Act (or the Clean Water Act [CWA]),

33 PINGP 1 and 2 effluent discharges are regulated by the NPDES and State Disposal System

34 Permit No. MN0004006 issued and enforced by the MPCA. Section 402 of the CWA states that

35 "NPDES prohibits [discharges] of pollutants from any point source into the nation's waters

36 except as allowed under an NPDES permit." The purpose of this permit is to regulate

37 wastewater discharge to preserve the water quality of the surrounding water bodies. As of the

38 most recent permit issued, there have been no notices of violation for the PINGP 1 and 2 site.

39 Information in this section was obtained from the most recent PINGP 1 and 2 NPDES permit, a

40 copy of which is included in the applicant's license renewal ER. The most recent renewal of this

41 permit occurred in June 2006 and expires August 2010.

42 In order to minimize the impacts from the PINGP 1 and 2 cooling system on entrainment and

43 impingement of fish and shellfish, the NPDES permit dictates the screen size the plant must use

44 during the spring and summer (Table 2-3).

45 Additionally, the NPDES permit imposes limits on the discharge of cooling water from April to

46 June, in order to minimize the impacts of entrainment and impingement of fish and shellfish

Draft NUREG-1437, Supplement 39 2-18 October 2009
Affected Environment

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(Table 2-4). This indirectly restricts the withdrawal rates, as the discharge rate approximates the

withdrawal rate.

To minimize the impacts of the heated discharge from the PINGP 1 and 2 cooling system, the

NPDES permit specifies the times and trigger points when the plant must switch the operating

mode of the cooling system (Table 2-5). The permit defines the fall trigger point as when the

daily average upstream ambient river temperature falls below 43 OF (6 0C) for five consecutive

days. (MPCA 2006)

Table 2-3. PINGP 1 and 2 Screen Mesh Size and Spray Wash Pressure

Requirements. Mesh size and spray wash pressure are specified by the PINGP I and

2 NPDES permit and vary by time of year.

Time of Year Screen Mesh Size Spray Wash Pressure

April I to August 31 0.5 mm fine mesh screen Low Pressure (larval): 10 psi

High Pressure (debris): 50 psi

September 1 to March 31 3/8 in. coarse mesh screen Low Pressure (fish): 20 psi

High Pressure (debris): 100 psi

Table 2-4. PINGP 1 and 2 Plant Flow (Discharge) Restrictions. Discharge

restrictions are implemented in the PINGP I and 2 NPDES permit and vary by time of

year and river flow.

Time of Year River Flow Plant Flow (Discharge)

April 15-30 < 15,000 cfs (425 m3/s) 97 mgd (150 cfs; 4.25 ms/s)

April 15-30 > 15,000 cfs (425 m3/s) 194 mgd (300 cfs; 8.5 m3/s)

May n/a 194 mgd (300 cfs; 8.5 ms/s)

June 1-15 n/a 259 mgd (400 cfs; 11.3 ms/s)

June 16-30 n/a 517.5 mgd (800 cfs; 22.7 m3

/s)

Table 2-5. PINGP I and 2 Cooling Mode Requirements. Cooling mode requirements

are specified by the PINGP 1 and 2 NPDES permit and vary by time of year.

Time of Year Requirements

April 1 through Fall Trigger Operate cooling towers as necessary so that:

* Receiving water is not raised by more than 5 OF (-15 0C)

above ambient.

* Cooling water discharge does not exceed a daily average

temperature of 86 OF (30 0C)

" If the daily average ambient temperature reaches 78 OF

(26 °C) for two consecutive days, all cooling towers shall

be operated to maximum extent practicable

October 2009 2-19 Draft NUREG-1437, Supplement 39
Affected Environment

Fall Trigger through March 31 If temperature of receiving water exceeds 43 OF (6 °C) for two

consecutive days, the MPCA and MN DNR must be notified. The

MPCA may require the use of cooling towers or alternative

measures to reduce water temperatures.

1 Requirements begin April 1, but can be earlier, if the daily average ambient river temperature increases to 43 IF (6

°C) or above for five consecutive days. 2 The fall trigger point is when the daily average upstream ambient river temperature falls below 43 IF (6 'C) for five

consecutive days.

3 Receiving water is the water immediately below Lock and Dam 3.

4 Ambient water temperatures are based on upstream monitoring and the monthly averages of maximum daily

temperatures at three monitoring probes located at the dam.

1 Periodically, NSP treats the PINGP 1 and 2 cooling water system with oxidizing biocides,

2 chlorine and bromine, to prevent the growth of biofouling micro-organisms. The NPDES permit

3 limits the release of these biocides, as shown in Table 2-6. (MPCA 2006; NMC 2008)

4 Table 2-6 shows the quantitative effluent limitations regulated under the NPDES permit, or the

5 residual concentrations of permitted chemical additives that may be discharged to the surface

6 waters. In accordance with this permit, if PINGP 1 and 2 introduce any new chemical additives

7 in its operation, or the current dosages are increased, they must first be reviewed and approved

8 by the MPCA. In addition to these effluent limitations, the permit includes thermal limitations and

9 water intake restrictions.

10

Draft NUREG-1437, Supplement 39 2-20 October 2009
Affected Environment

1

2 Table 2-6. NPDES Effluent Limitations for PINGP 1 and 2

Total Suspended Total Residual Total Residual Oil and Grease

Solids (mg/L) Bromine Chlorine [Hexane Extraction]

Outfall (mg/L) (mg/L) (mg/L)

No. Quarterly Daily Daily Instant Daily Instant Monthly Daily

Avg. Max. Max. Max. Max. Max. Avg. Max.

SDO01 NLR NLR 0.001 0.05 0.04 0.2 NLR NLR

SD002 30 100 NLR NLR NLR NLR NLR NLR

SD003 30 100 NLR NLR NLR NLR NLR NLR

SD004 NLR NLR NLR NLR NLR NLR NLR NLR

SDO05 30 100 NLR NLR NLR NLR 10 15

SD006 30 100 NLR NLR NLR NLR 10 15

SD01O 30 100 NLR NLR NLR NLR 10 15

SDO12 NLR NLR NLR NLR NLR NLR NLR NLR

Source: MPCA 2006

NLR = No Longer Regulated

3 The permit outlines the effluent limitations and monitoring requirements of eight different

4 discharge outfalls. In addition to the effluent limitations shown in Table 2-6, the permit describes

5 the minimum number of sampling events that are required for each outfall, where necessary.

6 Flow monitoring requirements (based on the time of year) are outlined for certain outfalls, as

7 well as required pH monitoring, with the pH levels expected to be between 6.0 and 9.0 year8 round. The permit also stipulates there will be no discharge of oil or other substances that result

9 in a visible film, as well as no discharge of floating solids or visible foam.

10 The outfall effluent limitations in Table 2-7 were calculated based on the maximum discharge

11 flow rates from Table 2-6. Outfall SD 001 is the circulating water system discharge canal, which

12 discharges wastewater directly to the Mississippi River. A portion of the water from this canal is

13 rerouted to the intake screenhouse during the winter months to help prevent ice build-up there.

14 All of the following surface discharges (SD) are monitored outfalls; however, they are all

15 discharged to the Mississippi via SD 001, the circulating water system discharge canal. Steam

16 generator blowdown is discharged via SD 002. Radwaste treatment system effluent is

17 discharged via SD 003. The reverse osmosis system effluent is discharged via SD 004. SD 005

18 and SD 006 discharge wastewater from the Unit 1 and Unit 2 turbine building sumps, which are

19 comprised of noncontact cooling water, condensate traps and drains, roof and floor drains, Unit

20 1 and Unit 2 condensate blowdown and the heating system blowdown. SD 010 discharges

21 wastewater from miscellaneous floor drains. The Unit 1 and Unit 2 cooling water systems are

22 the plant's two internal waste streams (WSs), WS 001 and WS 002. These waste streams

23 contain bromine and chlorine residuals and are also discharged to the river via SD 001.

24 The only surface discharge aside from SD 001 that discharges directly to the Mississippi is

25 SD 012. SD 012 discharges the plant intake screen backwash as well as the fish return system

26 of any impinged fish, aquatic organisms, or debris directly to the river.

October 2009 2-21 Draft NUREG-1437, Supplement 39
Affected Environment

1 Table 2-7. Surface Discharge (SD) and Internal Waste Stream (WS) Discharges

2 from PINGP 1 and 2 (in millions of gallons per day [mgd])

Maximum Average

Outfall Flow Flow

No. (mgd) (mgd)

SD 001 864.0 503.0

SD 002 0.576 0.012

SD 003 0.230 0.002

SD 004 0.244 0.051

SD 005 0.360 0.030

SD 006 0.360 0.030

SD 010 0.015 0.001

SD 012 3.200 2.000

WS 001&

WS 002 69.00 25.00

Source: MPCA 2006

3 Cooling water discharge is restricted at certain times of the year. From April 15 to April 30

4 discharge is restricted to 194 mgd (7.34 x 105 m3/day) if the flow of the Mississippi River is at or

5 above 15,000 cfs (424.8 m3

/s). If the river flow is below this level, discharge is limited to 97 mgd

6 (3.67 x 105 m3/day). From May 1 to May 31 discharge is restricted to 194 mgd (7.34 x 105

7 m3/day), from June 1 to June 15 the discharge rate may increase to 259 mgd (9.80 x 105

8 m3/day), and from June 16 to 30 it may increase to 517.5 mgd (1.96 x 106 m3/day). Outfall SD

9 001 is permitted to exceed these discharge limitations only in the event that it is necessary in

10 order to prevent temperatures from exceeding 85 OF (29 0C).

11 Thermal limitations require temperature monitoring at five different locations: the discharge

12 canal outfall (SD 001), the plant intake (SD 002), a specified point in the main river channel (SD

13 003), a specified point in Sturgeon Lake (SD 004), and a point directly downstream of Lock and

14 Dam No. 3 (SD 001) which is to be monitored using three different temperature probes. The

15 permit states that the daily average temperature should under no circumstances exceed 86 OF

16 (30 °C) and that the temperature of the receiving water should not be raised over 5 °F (-15 0C)

17 above the ambient water temperature. The permit specifies that if the ambient water

18 temperature reaches 78 °F (26 0C) for two consecutive days all cooling towers should be

19 operated to their maximum extent.

20 2.1.7 Facility Water Use and Quality

21 The PINGP 1 and 2 circulating water system and the service water system both draw water

22 from, and discharge to, the Mississippi River. Onsite groundwater wells also supply water for

23 cooling water makeup, domestic water consumption, and other industrial uses. The following

24 sections detail water use at PINGP 1 and 2.

25 2.1.7.1 Groundwater Use

26 A portion of the water utilized by PINGP 1 and 2 for its supplemental operations is groundwater.

27 Specifically, PINGP 1 and 2 uses groundwater to supplement primary and secondary makeup

Draft NUREG-1437, Supplement 39 2-22 October 2009
Affected Environment

1 cooling water, plant sanitary facilities, pump bearing lubrication, pump motor cooling, pump seal

2 lubrication, domestic uses, and lawn watering (Minnesota Department of Natural Resources

3 [MNDNR] Permit 865114). The plant draws onsite groundwater from six wells screened in the

4 surficial aquifer. The MNDNR permits five of these wells for groundwater withdrawal, while the

5 sixth remains unpermitted because it draws less than 10,000 gallons per day (37.9 m3/day) and

6 therefore does not require a permit (MNDNR Permit 865114).

7 Sanitary wastewater is treated either with the site's septic system or is transported to the Red

8 Wing Wastewater Treatment Plant or the Prairie Island Community Water Treatment Plant

9 because there is no onsite sanitary wastewater treatment facility (MPCA 2006).

10 2.1.7.2 Surface Water Use

11 PINGP 1 and 2's treatment and disposal systems include a chemical treatment system (in which

12 water is treated with bromine and/or chlorine to control biofouling organisms), a reverse osmosis

13 system, a radioactive waste treatment system, an intake screening system, and mechanical

14 draft cooling towers (MPCA 2006). The surface water used in the plant's circulating water

15 system and the cooling water system is withdrawn from the Mississippi River through the plant's

16 intake structure and is eventually discharged back to the river via the discharge canal (MPCA

17 2006).

18 PINGP 1 and 2 withdraw approximately 2.0 x 1011 gallons per year (848 cfs; 24 m3/s) from the

19 river annually under these conditions, with a highest recorded annual withdrawal of 2.08 x 1011

20 gallons (882 cfs; 25 m3/s) in 2005 (TtNUS 2006). The intake structure is designed to pump river

21 water into the system during both normal conditions and major flood levels. PINGP 1 and 2 has

22 no formal protocol to accommodate extremely low river conditions because the upstream Lock

23 and Dam 3 controls the river elevation at the site. However, the plant does have an emergency

24 plan in the event of the loss of Lock and Dam 3.

25 Cooling tower blowdown discharge averages 1.9 x 1011 gallons per year (810 cfs; 23 m3/s), with

26 a highest recorded average of 2.0 x 1011 gallons per year (851 cfs; 24 m3/s) in 2000 (TtNUS

27 2006). Blowdown discharges back to the Mississippi via the plant's discharge canal in a manner

28 complying with the plant's NPDES Individual Wastewater Discharge Permit No. MN 0004006

29 issued by MNDNR in 2006 (MPCA 2006). The primary sources of river water consumption and

30 evaporation are drift losses and PINGP 1 and 2 averages 9.2 x 109 gallons per year (39 cfs; 1.1

31 m3/s). The plant's consumptive river water use constitutes 4.6 percent of the Mississippi River

32 flow at the site, which averages 18,380 cfs (520 m3

/s) annually (TtNUS 2006).

33 2.1.7.3 Surface Water Quality

34 While no water quality studies have been conducted by PINGP 1 and 2 in recent years, the

35 MPCA monitors water quality at Lock and Dam 3.

36 PINGP 1 and 2 is located in the Upper Mississippi Sub-basin, an area of the Mississippi River

37 that has a number of water quality issues. Hypoxia, a zone of decreased dissolved oxygen, has

38 become a serious problem in the Gulf of Mexico as a result of nutrient enrichment, particularly

39 nitrogen enrichment (EPA 2006). The Mississippi River is one of the two main nutrient

40 contributors to the Gulf of Mexico and Minnesota in particular contributes an estimated five to

41 six percent of this nitrogen flux to the Gulf of Mexico (EPA 2006). Management practices in the

42 Upper Sub-basin are implemented to reduce nitrogen and phosphorus discharges into the river

43 system (MPCA 2000).

44 Wastewater discharges from the PINGP 1 and 2 facility to the Mississippi River are regulated by

45 the MPCA issued NPDES permit. In terms of surface water quality issues, the facility's NPDES

October 2009 2-23 Draft NUREG-1437, Supplement 39
Affected Environment

1 permit regulates effluent limitations, thermal limitations, and water intake restrictions. For a more

2 detailed description of the NPDES permit, refer to Section 2.1.6.3.

3 PINGP 1 and 2 implements a Storm Water Pollution Prevention Plan onsite to reduce the

4 amount of pollution discharged through storm water runoff. The purpose of this plan is to

5 eliminate any contact that discharged storm water may have with possibly contaminated

6 materials.

7 2.1.7.4 Dredging

8 Since the original construction of the discharge canal, PINGP 1 and 2 has not conducted any

9 dredging aside from routine maintenance. In 2009, PINGP 1 and 2 plans to perform several

10 larger-scale maintenance dredging projects, including work on the main discharge canal and the

11 intake channel. NSP has stated that it will implement best management practices to reduce

12 pollution risks will be implemented during these dredging activities.

13 2.2 Affected Environment

14 This section provides general descriptions of the environment near PINGP 1 and 2 as

15 background information. This section also provides detailed descriptions where needed to

16 support the analysis of potential environmental impacts of refurbishment and operation during

17 the renewal term, as discussed in Chapters 3 and 4. Section 2.2.9 describes historic and

18 archaeological resources in the PINGP 1 and 2 area, and Section 2.3 describes the possible

19 impacts associated with other Federal project activities.

20 2.2.1 Land Use

21 PINGP 1 and 2

22 PINGP 1 and 2 are located on approximately 578 ac (234 ha) of land, owned by NSP. Prior to

23 construction of PINGP 1 and 2, the site was used for agriculture. Approximately 240 ac (97 ha)

24 were disturbed by the construction of the plant in the early 1970s. The developed portion of the

25 PINGP 1 and 2 site, which occupies approximately 60 ac (24 ha), consists of the power plant

26 structure and associated buildings, maintenance facilities, parking lots (AEC 1973). The

27 remaining 180 ac (73 ha) of disturbed land were landscaped after construction was completed

*28 and most of this land is grassland (AEC 1973). The remainder of the site (about 338 ac [137

29 ha]) is primarily wooded. Figure 2.2 depicts the general site layout and exclusion zone

30 boundary. The exclusion zone boundary extends east of the plant to the main channel of the

31 Mississippi River. Islands within this boundary, as well as a small strip of land northeast of the

32 plant, are owned by the U.S. Army Corps of Engineers (USACE) (NMC 2008).

33 PIIC

34 The Prairie Island Indian Community (PIIC) is a Federally-recognized Indian Tribe organized

35 under the Indian Reorganization Act (25 USC 476). PINGP 1 and 2 are located immediately

36 south, south-east of the Prairie Island Indian Community. It is because of the PINGP 1 and 2's

37 location relative to the PIIC that the Tribal Council asked to be a Cooperating Agency for

38 purposes of developing sections of the supplemental Environmental Impact Statement (SEIS)

39 for the PINGP 1 and 2 license renewal environmental review.

40 The PIIC has gained land through several Federal reorganization acts and direct purchases by

41 the Tribal Council. The PIIC's land holdings now total over 3000 ac (1200 ha) (both land and

42 water). The PIIC has grown substantially since PINGP 1 and 2 first went on-line in 1973.

43 Currently, the PIIC consists of 801 enrolled band members, of whom approximately 250

44 members reside within 2 mi (3.2 km) of PINGP 1 and 2 on tribal lands. PIIC's reservation

Draft NUREG-1437, Supplement 39 2-24 October 2009
Affected Environment

1 contains 60 housing units on the reservation, new Trust lands (i.e., the Upper Island) hold 29

2 housing units, and 47 additional units are proposed for 2009. (See Chapter 4, Figure 4-1) (PIIC

3 2009)

4 The PIIC owns and operates the Treasure Island Resort and Casino, which is on reservation

5 land and located within 1 mi (1.6 km) of PINGP 1 and 2. Treasure Island also includes a 24-

6 lane bowling center, a multi-use event center, an RV park, a marina, and a sightseeing and

7 dinner cruise boat. (PIIC 2009)

8 Because of its unique legal and political status as a Federally-recognized Indian Tribe, the

9 Prairie Island Indian Community is not subject to State or local land use jurisdiction. The Tribe

10 is free to develop its own land-use policies and management plans for its Trust lands. (PIIC

11 2009)

12 2.2.2 Air and Meteorology

13 2.2.2.1 Climate and Meteorology

14 Minnesota's climate is characterized by the Koppen Climate Classification System as humid

15 continental, or Dfa, in which precipitation is low, but adequate, and seasonal temperatures vary

16 greatly (Strahler 1984). The region is subject to temperature extremes in winter from continental

17 polar and/or Arctic air masses, and in summer from tropical air masses moving in from the Gulf

18 of Mexico, which can cause occasional extended periods of heat (NCDC 2006). Common storm

19 systems include Alberta Clippers, fast moving air masses with low pressure that develop in the

20 north in winter months and move southward, and Panhandle Hooks, low pressure air masses

21 that form in the southwest and move northeast and often carry significant moisture (NWS

22 2008a; NWS 2008b). Statewide mean monthly temperatures range from 4 OF (-15 'C) in

23 January to 70 OF (20 0C) in July (NCDC 2006). Data collected from 1949 to 2001 at the Red

24 Wing Dam 3 weather station indicate that the mean monthly temperatures in the vicinity of

25 PINGP 1 and 2 range from 12.0 OF (-11 °C) in January to 72.1 OF (22.2 0C) in July (MRCC

26 2001). Statewide 1-day temperature extremes range from -60 OF (-51 °C) to 114 OF (45.6 0C)

27 (NCDC 2006).

28 Mean annual precipitation ranges from 35 in. (89 cm) in the southeastern portion of the state to

29 19 in. (48 cm) in the northwest portion of the state (NCDC 2006). Data collected from 1971 to

30 2000 at the Red Wing Dam 3 weather station indicate that the mean annual precipitation in the

31 vicinity of PINGP 1 and 2 is 29.95 in. (76.07 cm); the period June through August receives the

32 highest mean precipitation (NCDC 2000). Approximately two-thirds of annual precipitation

33 occurs between May and September, which coincides with the April-to-October native growing

34 season and May-to-September row crops growing season (NCDC 2006). Thunderstorms are

35 most common during months of heavier rainfall. Southern Minnesota averages 45 thunderstorm

36 days annually (NCDC 2006).

37 Statewide annual snowfall varies greatly and averages from 40 in. in the southern portion of the

38 state to 70 in. (180 cm) in the northeastern portion of the state (NCDC 2001). In the vicinity of

39 the PINGP 1 and 2 site, annual snowfall averages about 44 in. (110 cm) per year (NMC 2008).

40 Snowfalls of 4 in. (10 cm) or greater are common from mid-November to mid-April and snowfall

41 with blizzard conditions occur about two times per year (NCDC 2006).

42 Average annual wind speed documented over a 30-year period is 10.6 mph (17.1 kph) for

43 Minneapolis, 39 mi (63 km) northwest of PINGP 1 and 2 (NCDC 2005). Prevailing wind

44 directions for the site region are northwest in the winter months, east-southeast in the early

45 summer, and south in the late summer months (NCDC 1998). In the vicinity of the PINGP 1 and

46 2 site, wind direction is primarily influenced by the Mississippi River Valley.

October 2009 2-25 Draft NUREG-1437, Supplement 39
Affected Environment

1 Tornadoes have been documented in Minnesota from March through November and occur most

2 frequently in May, June, and July (MCWG 2008). These months account for over 75 percent of

3 observed tornadoes, of which June accounts for 33 percent of these (NCDC 2006). Goodhue

4 County has 18 recorded tornadoes between the period of 1950 to 2005 (NWS 2005). Of these,

5 all occurred between May and August; twelve were FO, four were F1, and one was an F3 on the

6 Fujita Tornado Damage Scale (NWS 2005).

7 The PINGP 1 and 2 Meteorological Monitoring Program, which is part of the PINGP 1 and 2

8 Environmental Monitoring Program, includes operation of weather instruments mounted on a

9 primary 140-ft (42.6-m)-high tower, which is located approximately 1800 ft (549 m) northwest of

10 the reactor building. Wind speed, direction and temperature variance are measured at 33 ft

11 (10 m) and 197 ft (60 m). Precipitation is measured at ground level. This meteorological data is

12 gathered once per hour and stored in a database, which is reviewed daily by the site

13 meteorologist. Quality controlled meteorological data is then compiled into monthly, quarterly

14 and annual reports.

15 2.2.2.2 Air Quality

16 Under the Clean Air Act (CAA), the EPA has established National Ambient Air Quality

17 Standards (NAAQS) six criteria pollutants: nitrogen dioxide, sulfur dioxide, carbon monoxide,

18 lead, ozone, and particulate matter (PM10 and PM2.5). Under the NAAQS, areas are designated

19 as being in "attainment" or "non-attainment" for the standards established for each criteria

20 pollutant. Areas that are re-designated attainment after being designated non-attainment are

21 considered "maintenance areas." In addition to meeting the air quality standards, maintenance

22 areas must create a plan describing how the area will continue to meet the air quality standards

23 over a 10-year period.

24 Goodhue County, in which PINGP 1 and 2 is located, is part of the Southeast Minnesota25 LaCross (Wisconsin) Interstate Air Quality Control Region (40 CFR 81.66). All of these counties,

26 with the exception of Olmsted County, are in attainment (NMC 2008). Olmsted County, which is

27 approximately 65 mi (105 km) from the PINGP 1 and 2 site, is a maintenance area for sulfur

28 dioxide and PM10 (40 CFR 81.324).

29 PINGP 1 and 2 has a number of stationary emission sources, which include four standby

30 emergency power supply diesel generators, one backup generator and auxiliaries required for

31 safe start-up and continuous operation, that do not require the facility to secure a Title V permit.

32 PINGP 1 and 2 are recognized as a Synthetic Minor facility by Minnesota State due to the low

33 quantity of emissions and the restrictions on operation of its stationary sources; therefore,

34 operation of the sources is regulated by a Minnesota Synthetic Minor Operating Permit. PINGP

35 1 and 2 generators are tested periodically to ensure their continued performance capability, and

36 NPS has procedures in place to ensure continuous monitoring, sampling, and filtering of the oil.

37 Used oil is collected for offsite disposal; waste management is discussed in Section 2.1.3.

38 2.2.3 Groundwater Resources

39 Prairie Island is an island terrace within a three mile wide valley of the Mississippi River

40 floodplain. Six groundwater wells utilize the surficial aquifer directly beneath the site. The

41 deepest of these wells extends to 165 ft (50.3 m) (NMC 2008). This alluvial aquifer (or, water

42 table) is 130 to 200 ft (39.6 to 60.9 m) thick and is composed of sands, gravels, and other finer43 grained lake sediments resulting from glacial outwash (Cowdery 1999). The water table is found

44 5 to 20 ft (1.5 to 6.1 m) underneath the PINGP 1 and 2 site. The groundwater flow in the surficial

45 aquifer is influenced directly by its hydraulic surface water boundaries: the Mississippi River to

46 the northeast and the Vermillion River to the southwest. Typically, the groundwater flows

47 southwest from the Mississippi to the Vermillion (Winterstein 2001). However, in the spring if

Draft NUREG-1437, Supplement 39 2-26 October 2009
Affected Environment

1 there are conditions of snowmelt or heavy rain, a groundwater mound can form, resulting in

2 radial flow (Cowdery 1999). Recharge to the aquifer comes from interaction with these surface

3 water systems as well as from rain, snowmelt and floodwater. A sediment barrier limits the

4 recharge and discharge flow interaction between the surficial aquifer and the surface waters

5 (Ruhl 2002).

6 The area's primary aquifers are found in bedrock composed of layers of limestone and

7 sandstone. The Prairie du Chien Group and Jordan Sandstone are the uppermost of these

8 aquifers (See Figure 2-1). The Jordan Sandstone is a confined aquifer and the St. Lawrence

9 Formation separates it from the underlying Franconia Formation. Because the Mississippi River

10 Valley cuts through these formations, forming the bluffs on either side of the valley, the

11 Franconia Formation is the aquifer found directly beneath the shallow alluvial aquifer at the

12 PINGP 1 and 2 site and is less thick at this point than its total measured thickness of 180 feet

13 (24.4 m).

Figure 2-5. Lithology and Generalized Geologic Section for the

Prairie Island Low Island Terrace (Source: Cowdery 1999)

SWI(- NfNES~YfA VACO N SIc ->m ) NE 1,100 -

• LS ,- : Glacial oulwa• l\ aeeionsL)•'~ * Fmalno nstly ... sand and gravel): .:. '•;-:7 - " '"•

*"":e •':•; '•,R:'. v~ -- '¢' , - -=• I-..• l :.+ "•.:': :- ..." 'i* -. 'F ,-_.. . . . ......~~pox at

VERTICAL EXAGGERATION 1OX I MUql

14

15 The upper three strata discharge from the bluffs as springs, while the deeper Franconia

16 Formation discharges to the sediments that partially fill the Mississippi Valley. Beneath the

17 Franconia Formation is the Dresbach formation, which consists of sandstone, siltstone and

18 shale and measures over 100 ft (30.5 m) in thickness. The Dresbach formation includes the

19 Mount Simon formation, which is the primary water producing aquifer for the nearby community

20 of Red Wing and the PIIC. The wells at the PINGP 1 and 2 site, however, draw water from the

21 shallow alluvial aquifer. The Cowdery study notes that despite a high hydraulic head gradient

22 between aquifers, the exchange of water between the alluvial aquifer and the bedrock aquifer

23 below is small because of a boundary of clay-rich materials between the two strata. (Cowdery

24 1999)

25 2.2.3.1 PINGP 1 and 2 Water Supply Wells

26 PINGP 1 and 2 has six onsite wells screened in the surf icial aquifer (NMC 2001g). Five of these

27 wells are permitted for groundwater withdrawal by MNDNR, while the sixth remains unpermitted

28 because it draws less than 10,000 gpd (37.9 m3/day) and therefore does not require a permit

29 (NMC 2006a). The two largest of these wells are 165 ft (50.3 m) in depth and 10 inches (25.4

3 3U

30 cm) in diameter and yield up to 116,000 ft3/day (3,285 m3/day) of groundwater.

31 The average total yield of the five permitted wells is 91 gpm (5.7 x i0-• m3/s), with the

32 unpermitted well averaging 1 gpm (6.3 x 10• m3Is), resulting in a total annual average yield of

33 92 gpm (5.8 x 10-• m3/s) from 2000 to 2005 (See Table 2-8). The highest recorded annual

October 2009 2-27 Draft NUREG-1437, Supplement 39
Affected Environment

1 average yield occurred in 2005 at 118 gpm (7.4 x 10-3 m3

/day) and the lowest was recorded in

2 both 2000 and 2002 at 77 gpm (4.9 x 10.3 m3

/day).

3 Table 2-8. Total Annual Groundwater Withdrawal (Gallons) for PINGP 1 and 2.

Well Well Well Well Well Well Total Annual

Year (Non- 256120 256121 611076 402599 [BLANK] gal gpm

permitted)

2000 - 13,676,800 12,812,800 3,745,780 7,474,900 2,242,900 39,953,180 76

2001 - 16,974,300 16,372,060 3,663,190 7,267,700 2,971,700 47,248,950 90

2002 - 18,958,300 11,609,300 3,550,800 4,280,700 1,674,100 40,073,200 76

2003 - 10,648,800 14,248,900 4,163,190 10,969,500 1,884,000 41,914,390 80

2004 563,100 18,576,900 13,336,200 5,280,430 15,517,800 1,824,900 54,536,230 104

2005 563,100 20,833,300 19,933,600 6,830,210 12,055,695 1,946,200 61,599,005 117

Total Withdrawal 99,668,400 88,312,860 27,233,600 57,566,295 12,543,850 285,324,955 -

Avg. Annual Withdrawal 16,611,400 14,718,810 4,538,933 9,594,383 2,090,633 47,554,159

Avg. gpm 1.07 32.00 28.00 9.00 18.00 4.00 - 91

Source: [NMC 2008]

4 2.2.3.2 PINGP I and 2 Groundwater Monitoring

5 Groundwater monitoring at PINGP 1 and 2 is primarily targeted at the groundwater infiltration of

6 radionuclides such as tritium. Tritium is a product of manmade sources, as well as natural

7 processes. Groundwater sampling first revealed detectable levels of tritium in a nearby

8 residence well in 1989, which led to the first establishment of a tritium sampling program at

9 PINGP 1 and 2. In 1991, the plant modified the discharge canal by lengthening the submerged

10 liquid discharge pipe. This pipe ensured that all liquid discharges from the plant were released

11 towards the end of the canal, preventing any radioactive water from remaining in the discharge

12 canal long enough to allow tritium to leach into the groundwater supply. In response to an

13 unusually high tritium sample (1360 picocuries per liter [pCi/L]) in one of the onsite wells, the

14 plant replaced an aging pipe system in 1992. (NMC 2006s)

15 Conclusions drawn from the 2006 Radiation Environmental Monitoring Program Annual Report

16 indicate that, while tritium levels detected in that same onsite well fluctuate from year to year,

17 high tritium levels have not been detected since the plant took steps towards the prevention of

18 tritium leaching. All groundwater sampling, both onsite and offsite, has yielded results well

19 below the EPA's tritium drinking water standard of 20,000 pCi/L. (NMC 2006s)

20 Aside from the Radiation Environmental Monitoring Program, PINGP 1 and 2 does not currently

21 implement a general Groundwater Monitoring Program. However, PINGP 1 and 2 has plans to

22 initiate one in the near future. (NMC 2008x)

23 2.2.4 Surface Water Resources

24 PINGP 1 and 2 are located on Prairie Island, which is on the Mississippi River. The Mississippi

25 is the longest river in North America and spans 2302 mi (3705 km) from its source at Lake

26 Itasca in Minnesota to where it empties into the Gulf of Mexico. The river drains approximately

27 189,000 square miles and 31 different states. The Mississippi can be divided into six sub28 basins: the Upper Mississippi River, Lower Mississippi River, Arkansas Red-White River, Ohio

Draft NUREG-1437, Supplement 39 2-28 October 2009
Affected Environment

1 River, Missouri River, and Tennessee River Sub-basins. The PINGP 1 and 2 facility is located in

2 the Upper Mississippi sub-basin. (EPA 2006)

3 The Upper Mississippi Sub-basin covers 20,100 square miles and has 12 major tributaries, the

4 most notable being the Missouri River, the Illinois River, the Wisconsin River, and the Iowa

5 River (MPCA 2008). Annual average discharge of this portion of the river ranges from 9,180 cfs

6 to 204,800 cfs (259.9 to 5799.2 m3/s). (USGS 2006)

7 Prairie Island itself is a low-lying island located in a one to three mile-wide (1,609 to 4,828 m)

8 section of the Mississippi River Valley, with the majority of the island being less than 25 feet

9 (7.6 m) above the river. On either side of the valley are 360 foot high (110 m) bluffs composed

10 of Paleozoic limestones and sandstones (Cowdery 1999). Prairie Island is located between the

11 Mississippi River and the Vermillion River, with the confluence of the two rivers at the

12 downstream end of the island (EPA 2006). About 1.5 miles (7920 ft) downstream from the island

13 is Lock and Dam Number 3, which controls the water level and flow of this stretch of the

14 Mississippi (USGS 2006). Typically, the Mississippi is kept at a water level higher than that of

15 the Vermillion River and discharge from Lock and Dam Number 3 tends to be at its peak in the

16 spring and summer. (Cowdery 1999)

17 PINGP 1 and 2 are located on Sturgeon Lake, an area of the Mississippi created by the rise in

18 water elevation by Lock and Dam Number 3 and the subsequent flooding of sections of the

19 floodplain. The nearest upstream flow monitoring station to PINGP 1 and 2 is the Prescott U.S.

20 Geological Survey (USGS) monitoring station, located at river mile 811.4. The nearest

21 downstream flow monitoring station is the Winona USGS monitoring station, located at river mile

22 725.7. At the Prescott station the annual recorded mean flow from 1928 to 2005 is 18,380 cfs

23 (520.5 m3/s), with the highest annual mean flow being 38,540 cfs (1,091 m3/s) and the lowest

24 4,367 cfs (123.7 m3/s). At the downstream Winona station the annual recorded mean flow from

25 1928 to 2005 is 29,590 cfs (837.9 m3/s), with the highest annual mean flow being 56,850 cfs

26 (1,610 m3/s) and the lowest 9,742 cfs (276 m3/s). Table 2-4 and 2-5 show the monthly average

27 and yearly total discharge flows at Lock and Dam 3 from 1999 to 2006 respectively. (USGS

28 2006)

29 Table 2-9. Monthly Average Discharge Flow at Lock and Dam 3 from 1999 to 2006

Monthly

Average

Month (cfs)

January 10,425

February 10,621

March 15,654

April 44,634

May 39,562

June 33,758

July 23,641

Month (cfs)

August 14,223

September 13,294

October 16,084

October 2009 2-29 Draft NUREG-1437, Supplement 39
Affected Environment

Monthly

Average

November 14,578

December 11,455

Source: USGS 2006

1 Table 2-10. Total Yearly Discharge Flow at Lock and Dam 3 from 1999 to 2006

Total

Year Discharge

Flow (cfs)

1999 272,245

2000 168,796

2001 355,385

2002 280,864

2003 198,688

2004 221,612

2005 272,099

2006 213,727

Source: USGS 2006

2 2.2.5 Description of Aquatic Resources

3 PINGP 1 and 2 is located on the west bank of the Mississippi River, north of Red Wing,

4 Minnesota. The cooling system withdraws from and discharges to the main stem of the

5 Mississippi, 13 river miles (21 river kilometers) below the confluence of the St. Croix River and 4

6 river miles north of where the Vermillion River joins the Mississippi (AEC 1973). The Mississippi

7 is dammed for navigation about 1.5 mi (2.4 km) downstream from the facility by Lock and Dam

8 3. The area of the river adjacent to PINGP 1 and 2 is known as Pool 3, and is bounded by Lock

9 and Dam 3 (downstream) and Lock and Dam 2 (upstream), which lie about 18 river miles (29

10 river kilometers) apart (NMC 2008). Immediately north and east of the plant is Sturgeon Lake, a

11 side slough or impoundment that would be considered a marsh if it were not associated with the

12 main stem of the river (AEC 1973). The Vermillion River borders the southwest of the site. The

13 power transmission system includes three in-scope lines, which cross a variety of water bodies,

14 as discussed in Section 2.1.5.

15 Mississippi River and River Basins

16

-17

18

19

20

Because the river is always changing, the exact length of the Mississippi River varies. According

to USGS, the river flows about 2300 mi (3700 km), from Lake Itasca in Minnesota to the Gulf of

Mexico (NPS 2008a). The Mississippi River Basin, which drains 41 percent of the continental

United States, a total area between 1.2 and 1.8 million mi 2 (3.1 and 4.7 million km2

), and

includes all or portions of 31 states and 2 Canadian provinces, is divided into six subbasins:

Draft NUREG-1437, Supplement 39 2,30 October 2009
Affected Environment

1 Upper Mississippi River, Lower Mississippi River, Arkansas Red-White River, Ohio River,

2 Missouri River, and Tennessee River (NPS 2008a).

3 The Upper Mississippi River, flowing about 1300 mi (2100 km) from the head waters in Lake

4 Itasca to the confluence of the Ohio River, was dammed to provide 9-ft (2.7-m) deep channels

5 for navigation, and is not used for flood control (UMRBA undated; USACE 2004). As described

6 above, PINGP 1 and 2 are located on the Minnesota shore of Pool 3, the area of the Mississippi

7 River created by Lock and Dams 2 and 3. The normal level of Pool 3, 674.5 ft (205.6 m) above

8 mean sea level, is controlled by Lock and Dam 3, located a little over a mile downstream from

9 the facility (NMC 2008).

10 Phytoplankton and zooplankton were monitored in preoperational studies, but have not been

11 studied since (NMC 2008; AEC 1973). Monitoring showed high phytoplankton densities in the

12 vicinity of the plant. Dominant species indicated eutrophic conditions, and pollution-tolerant

13 species were common. Zooplankton was primarily rotifers, crustaceans, and protozoa.

14 Phytoplankton and zooplankton communities may have changed in the decades since these

15 studies were performed.

16 Due to barge navigation, much of the river bottom at the time of preoperational monitoring was

17 scoured so that only the sand and clay substrate remained, and very little benthic fauna. The

18 areas that were not so disturbed by shipping were dominated by midge fly larvae and

19 oligochaetes, as well as tubificid worms, groups generally tolerant of severe pollution and

20 environmental disturbance. Pollution-tolerant macroinvertebrates, such as caddisflies and

21 mayflies, had begun to establish themselves just above Lock and Dam 3, downstream of the

22 discharged waste and runoff from the urban areas, Minneapolis and St. Paul, Minnesota. The

23 FES for PINGP 1 and 2 reported only a few small clam beds in the area, without giving more

24 details on the species present, and indicated that areas monitored upstream on the Mississippi

25 River and on the St. Croix revealed a higher diversity of species, which generally increased as

26 water quality increased. (AEC 1973)

27 In 2000 and 2001, MN DNR conducted a survey of mussels in the Mississippi National River

28 and Recreation Area Corridor for the National Park Service (Kelner and Davis 2002). The

29 southern-most reach of study sites was Upper Pool 3, defined from Lock and Dam 2 to

30 approximately 9 river miles (14 km) upstream of PINGP 1 and 2. Among the areas studied,

31 Upper Pool 3 was the most species-rich area of the survey, and second in overall mussel

32 abundance - Upper Pool 2 had the highest abundance. The 2,486 mussels collected covered

33 23 species; the top three species were 0. relexa (47.2 percent), A. plicata (25.0 percent), and F.

34 flava (10.1 percent). A high number of empty shells were collected, indicating that the historic

35 number of species was at least 37 species. The survey also found that 2.6 percent of native

36 mussels in Upper Pool 3 were infested by zebra mussels (Dreissena polymorpha), the highest

37 level of infestation in the study.

38 In 1988, the non-native zebra mussel made its first appearance in the United States, in Lake St.

39 Clair near Detroit, Michigan. By 1990, the invasive bivalve had colonized in all the Great Lakes,

40 and by 1992, established populations in many major rivers, including the Mississippi (Benson

41 2008). In the Upper Mississippi River System, adults or veligers (free-swimming larvae) have

42 been identified as far upriver as Lock and Dam 1 (River Mile [RM] 848) (rkm 1365) by St. Paul,

43 Minnesota and as far downriver as Lock and Dam 24, at Hannibal, Missouri (Tucker et al. 1993;

44 MNDNR 2008i). Annual surveys of zebra mussel population densities conducted in the lower St.

45 Croix River from 2005 through 2007 showed a dramatic increase in the relative abundance of

46 zebra mussels at Prescott, located at the confluence of the Mississippi River and St. Croix River

47 (RM 815, rkm 1312), about 11 mi (18 km) upriver from PINGP 1 and 2 (RM 797, rkm 1283). The

48 density of zebra mussels increased over the three-year study from 72/M2 (86/yd2) to 574/M2

October 2009 2-31 Draft NUREG-1437, Supplement 39
Affected Environment

1 (686/yd2). Four miles upriver of Prescott on the St. Croix River at St. Croix Bluffs, the density of

2 zebra mussels increased exponentially during this same period from 89/M2 (106/yd 2) to

3 12,288/M2 (14,696/yd 2) (NPS 2008b).

4 Zebra mussels are filter feeders and are one of the only freshwater mollusks capable of firmly

5 attaching themselves to solid objects, using adhesive structures called byssal threads (WDNR

6 2004). They are often found in large numbers attached to various underwater objects, including

7 boat hulls, pilings, pipes, rocks, other larger bivalves, and each other (USGS 2008). Females

8 can produce up to one million eggs annually (MNDNR 2008i), and the fertilized eggs develop

9 into larvae, or veligers. The veligers swim in the water column for one to five weeks and then

10 begin to sink. The veligers then attach to a solid surface where they metamorphose to adult

11 shape, grow, and eventually reproduce, often reaching reproductive maturity in the first year

12 (WDNR 2004). Zebra mussels can live from three to nine years (USGS 2008).

13 At high densities zebra mussels can cause severe biofouling of water intake structures and

14 irrigation systems and can cause severe ecological problems. Zebra mussels will frequently

15 colonize the intake pipes of public water supply plants and the cooling water intake structures at

16 power plants, and may reduce by two-thirds the diameter of the intake pipes, thereby

17 constricting cooling water flow. In a USACE study, zebra mussels colonized upon native

18 mussels at an average infestation rate of 5 to 58 zebra mussels per native mussel (NPS 2008b).

19 At higher colonization densities zebra mussels can smother native mussels. Their filter feeding

20 can effectively deplete the water column of suspended planktonic organisms used for food by

21 other aquatic organisms, including fish and native mussels (WDNR 2004). Even though

22 waterfowl and fish such as the common carp feed on zebra mussels (WDNR 2004; Tucker et al.

23 1996), once the zebra mussels have become established in a waterway, there is very little that

24 can be done to control their numbers (WDNR 2004).

25 Preoperational monitoring (1969-1971) indicated that the composition of the fish population

26 varied between the lower end of Pool 3 and upstream portion of Pool 4 (downstream of Lock

27 and Dam 3), due to the difference in flow. Slow currents above the dam yielded a relatively

28 stable, lake-like habitat, while downstream of Lock and Dam 3 exhibited a fast-water, riverine

29 habitat. Rough (non-game) fish, such as common carp (Cyprinus carpio), and redhorse

30 (Moxostoma spp.) made up about 66 percent of the species in Pool 3 and 87 percent of the

31 species in Sturgeon Lake, with game species, including black crappie (Pomoxis

32 nigromaculatus), white crappie (P. annularis), and white bass (Morone americana), making up

33 the remaining species. Pool 4 had a much higher proportion of game fish, including walleye

34 (Stizostedion vitreum) and sauger (S. canadense), and was considered a major spawning and

35 rearing area for game fish, compared to Pool 3. (AEC 1973)

36 Sections 3169(a) and 316(b) of the CWA requires that the location, design, construction, and

37 capacity of the cooling water intake structures reflect the best technology available (BTA) in

38 order to minimizing adverse environmental impacts, specifically impingement and entrainment,

39 to protect fish, shellfish, and other forms of aquatic life (33 USC 1326). Phase II of Section

40 316(b)'s implementing regulations applies to large existing electric generating plants, such as

41 PINGP 1 and 2, that withdraw more than 50 million gallons of water per day (gpd; 6.7 million

42 cubic feet per day [cfd]). The EPA implemented Phase II on July 9, 2004 (69 FR 41575). The

43 new Phase II performance standards were designed to significantly reduce impingement

44 mortality due to water withdrawals associated with cooling water intake structures used for

45 power production and were to be implemented through the National Pollution Discharge

46 Elimination System (NPDES) permitting process. The rule would require licensees to

47 demonstrate compliance with Phase II performance standards upon renewal of their NPDES

48 permit. To attain a renewed NPDES permit, licensees may have been required to alter their

Draft NUREG-1437, Supplement 39 2-32 October 2009
Affected Environment

1 intake structure, redesign the cooling system, modify station operation, or take other mitigative

2 measures to comply with the Phase II regulations.

3 However, EPA suspended the Phase II rule on July 9, 2007 (72 FR 37107) in response to the

4 Second Circuit Court of Appeals decision in Riverkeeper, Inc. v. EPA, No. 04-6692. As a result,

5 the EPA directed NPDES permit writers for Phase II facilities to develop technology-based

6 permit conditions on a case-by-case basis using all reasonably available and relevant data and

7 Best Professional Judgement (BPJ) as to the BTA.

8 PINGP 1 and 2 conducted monitoring as a requirement of Sections 316(a) and 316(b) of the

9 Clean Water Act. Gizzard shad (Dorosoma cepedianum), white bass, freshwater drum

10 (Aplodinotus grunniens), and common carp made up over half the fish collected between 1973

11 and 1976 (NMC 2008). In later years (1988-2006), the relative abundance of eight species

12 (carp, white bass, freshwater drum, sauger, black crappie, shorthead redhorse [Moxostoma

13 macrolepidotum], walleye, and gizzard shad) ranged from 69 to 89 percent of all fish caught

14 each year (ESWQD 2005). The status of eight species (carp, white bass, freshwater drum,

15 sauger, shorthead redhorse, walleye, gizzard shad, smallmouth bass [Micropterus dolomieuil],

16 and largemouth bass [Micropterus salmoides]) is discussed in each annual environmental

17 monitoring report. Each of these eight species was considered "relatively stable" in the last

18 available annual report (ESWQD 2005).

19 The Minnesota Department of Health (MDH) has published fish consumption guidelines for the

20 general public and for sensitive groups, defined as women who are or may become pregnant

21 and children under the age of 15, due to the presence of mercury, PCBs, and

22 perfluorooctanesulfonic acid (PFOS). For Pool 3, from Hastings Dam to Red Wing, MDH

23 recommends no more than one meal per week of bluegill sunfish (Lepomis macrochirus),

24 crappie, (Pomoxis spp.), flathead catfish (Pylodictis olivaris), freshwater drum, largemouth bass,

25 northern pike (Esox lucius), sauger, smallmouth bass, walleye for both the general public and

26 sensitive groups. Additionally, for sensitive groups, flathead catfish larger than 20 in. should not

27 be eaten more than once a month. MDH recommends both the general public and sensitive

28 groups eat no more than one meal per month of buffalofish (Ictiobus spp.), carp (Cyprinidae),

29 channel catfish (Ictalurus punctatus), and white bass. (MDH 2008a; MDH 2008b)

30 2.2.6 Terrestrial Resources

31 The 578-ac (234-ha) PINGP 1 and 2 site is located on the west bank of the Mississippi River on

32 a low island terrace of the Mississippi River floodplain. This region is characterized by prairie

33 land, bluffs, and stream valleys that range from 500 to 600 ft (150 to 180 m) in depth (MNDNR

34 2006b). The PINGP 1 and 2 site is composed of flat to slightly rolling topography (NMC 2008).

35 The Vermillion River lies to the west of Prairie Island, and the Mississippi River lies to the east.

36 Approximately 60 ac (24 ha) of the PINGP 1 and 2 site contain the generating facility,

37 associated buildings, parking lots, and roads (NMC 2008). An additional 180 ac (73 ha) of

38 previously disturbed land has been converted to maintained grassy areas or prairie grassland

39 habitat (NMC 2008). The remaining 338 ac (137 ha) consist of wooded areas characteristic of

40 eastern broadleaf forests (NMC 2008). Vegetation varies by type of habitat found on the PINGP

41 1 and 2 site, which includes floodplain, flat uplands, north-facing slopes, and south-facing

42 slopes. White oak (Quercus alba), red oak (Q. rubra), black oak (Q. velutina), bitternut hickory

43 (Juglans cinerea), and shagbark hickory (Carya ovata) comprise the dominant species in oak44 hickory forests of eastern broadleaf habitat (USFS Undated). Additionally, the FES (AEC 1973)

45 for PINGP 1 and 2 also noted the presence of silver maple (Acer saccharinum), cottonwood

46 (Populus deltoids), and green ash (Fraxinus pennsylvanica) within floodplain areas; burr oak (Q.

47 marcrocarpa), pin oak (Q. ellipsaidalis), and eastern red cedar (Juniperus virginiana) within flat

October 2009 2-33 Draft NUREG-1437, Supplement 39
Affected Environment

1 uplands; sugar maple (A. saccarum), American basswood (Tilia americana), paper birch (Betula

2 paprifera), ironwood (Carpinus caroliniana), and black walnut (Juglans nigra) on north-facing

3 valley slopes; and trembling aspen (P. tremuloides) and bitternut hickory (Carya cordiformis) on

4 south-facing slopes (AEC 1973; NMC 2008). Major shrub species that occur within a 10-mi (16-

5 km) radius of PINGP 1 and 2 include bittersweet (Celastrus scandens), red-osier dogwood

6 (Cornus stolonifera), river grape (Vitis riparia), red raspberry (Rubusindaeus spp.), Virginia

7 creeper (Parthenocissus quinquefolia), and prickly ash (Xanthoxylum americanum) (AEC 1973).

8 The PINGP 1 and 2 site contains and is surrounded by freshwater emergent wetland and

9 freshwater forested/shrub wetland habitat, as indicated by the U.S. Fish and Wildlife (FWS)

10 National Wetlands Inventory database (FWS 2008c). Though these areas remain undisturbed,

11 no wetlands on or near the PINGP 1 and 2 site have been officially delineated.

12 A variety of wildlife is found in the forested and grassland communities on and in the vicinity of

13 the PINGP 1 and 2 site. The small fragmented forest tracts in the northern portion of the site

14 provide habitat for small mammals such as raccoons (Procyon lotor), gray squirrels (Sciurus

15 carolinensis), and fox squirrels (S. niger) as well as birds such as wood warblers, thrushes,

16 woodpeckers, kinglets and hawks (NMC 2008). Larger spans of wooded areas found on the

17 southern portion contain sloughs and lakes, which support salamanders, frogs, and other

18 amphibians as well as birds, including numerous duck species and wading birds (AEC 1973;

19 NMC 2008).

20 The Mississippi River Valley is a major North American migratory flyway. Approximately 40

21 percent of migratory birds and waterfowl in the U.S. use the flyway as their primary migration

22 corridor (NPS 2006a). Migrating birds commonly observed on and in the vicinity of the PINPG

23 site include herons, hawks, plovers, terns, flycatchers, nuthatches, wrens, thrushes, shrikes,

24 warblers, and blackbirds (AEC 1973; NMC 2008). Additionally, the FES for PINGP 1 and 2

25 noted a number of bird species that have been recorded to nest within 10 mi (16 km) of the site,

26 which included wading birds such as great blue herons (Ardea herodias) and green herons

27 (Butorides virescens); raptors such as Cooper's hawks (Accipiter cooperii), red-tailed hawks

28 (Buteojamaicensis), northern harriers (Circus cyaneus), great horned owls (Bubo virginianus),

29 and barred owls (Strix varia); and songbirds such as black-capped chickadees (Poecile

30 atricapillus), wrens, thrushes, cedar waxwings (Bombycilla cedrorum), belted kingfishers

31 (Megaceryle alcyon), horned larks (Eremophila alpestris), and whip-poor-wills (Caprimulgus

32 vociferous) (AEC 1973). More detailed listings of migratory bird species and nesting bird

33 species recorded to be common to the PINGP 1 and 2 site can be found in Appendix A of the

34 FES for PINGP 1 and 2 (AEC 1973).

35 Purple loosestrife (Lythrum salicaria), a perennial herb, is the only terrestrial invasive species

36 that has been documented on the PINGP 1 and 2 site. The plant is native throughout Europe

37 and Asia and was introduced to the U.S. in the 1800s (PCA 2006). Purple loosestrife can invade

38 wetland areas and outcompete native grasses and sedges to form dense stands (PCA 2006).

39 NSP does not manage purple loosestrife populations as the species has not been found to

40 interfere with any intake structures or operation of the facility.

41 The Mississippi National River and Recreation Area corridor lies about 20 mi (32 km) northwest

42 of the PINGP 1 and 2 site and spans 72 mi (116 km) of the Mississippi River from Hastings,

43 Minnesota to Ramsey, Minnesota (NMS 2008; NPS 2006b). The corridor encompasses part of

44 the Mississippi flyway and provides habitat for more than 50 species of mammals, 270 species

45 of birds, 150 species of fish, and 25 species of mussels (NPS 2006a). More than a dozen pairs

46 of bald eagles (Haliaeetus leucocephalus) nest within the corridor, and several heron, egret, and

47 cormorant rookeries exist along the river as well (NPS 2006a). The corridor contains a variety of

48 eastern deciduous forest and tall grass prairie communities, which include floodplain forest,

Draft NUREG-1437, Supplement 39 2-34 October 2009
Affected Environment

1 upland prairie, maple-basswood forest, oak-savanna, dry oak forest, mesic oak forest,

2 brushland, wetland, wet meadows, and fens (NPS 2006c).

3 The Upper Mississippi River National Wildlife and Fish Refuge lies about 30 mi (48 kin)

4 southeast of the PINGP 1 and 2 site and spans 261 mi (420 km) of the Mississippi River and

5 240,220 ac (97,213 ha) of land beginning at the confluence of the Chippewa River near

6 Wabasha, Minnesota and continuing to Rock Island, Illinois (FWS Undated a; Undated b). The

7 refuge encompasses part of the Mississippi flyway and constitutes the largest river refuge in the

8 continental United States (FWS Undated b). The refuge contains 167 known bald eagle nests

9 and 5,000 blue heron (Ardea herodias) and great white egret (Ardea alba) nests in 15 colonies

10 as well as over 48,000 ac (19,400 ha) of marsh habitat (FWS Undated a). The FWS focuses on

11 restoration of riverine habitat and native grass prairie, bank stabilization, island building, and

12 bird and waterfowl nest counts and surveys in their management of the refuge (FWS Undated

13 b).

14 PINGP 1 and 2-associated transmission lines cross five wildlife refuges, wildlife management

15 areas, and parks. The Red Rock 2 line crosses Gores Pool #3 Wildlife Management Area, a

16 6449-ac (2610-ha) area in Goodhue County that consists of floodplain forest and backwater

17 marshes and contains a migratory bird refuge; Lost Valley Scientific and Natural Area, a 200-ac

18 (81-ha) bluff prairie in Washington County that is one of the few sites in the state containing rock

19 sandwort (Minuartia michauxii); and the northern part of Cottage Grove Ravine Regional Park in

20 Washington County (MNDNR 2008c; MNDNR 2008h; NMC 2008). The Blue Lake line crosses

21 the Black Dog Unit of the Minnesota Valley National Wildlife Refuge and the Savage Fen

22 Scientific and Natural Area, a 43-ac (17-ha) area in Scott County that consists of a unique

23 wetland plant community that grows on moist peat substrate and is sensitive to disturbance

24 (MNDNR 2008e; NMC 2008).

25 2.2.7 Threatened and Endangered Species

26 Tables 2-11 and 2-12 lists threatened, endangered, or candidate species known to occur in

27 Goodhue County, in which PINGP 1 and 2 is located, or Dakota, Washington, or Scott Counties,

28 through which transmission line ROWs associated with PINGP 1 and 2 traverse. Table 2-11

29 also includes any aquatic species listed in Pierce County, WI, which lies on the opposing shore

30 of the Mississippi River from PINGP 1 and 2.

31 2.2.7.1 Aquatic Species

32 Higgpins eye pearlymussel

33 The Higgins eye pearlymussel was Federally listed as an endangered species on June 14, 1976

34 (41 FR 24064). The Higgins eye was never abundant, although the historical range is not

35 completely known. It is currently found in the Upper Mississippi River above Lock and Dam 19,

36 in the St. Croix, Wisconsin, and Rock Rivers, an estimated 50 percent from the historical range

37 (FWS 2000a).

38 Preferring medium to large rivers with firm substrate ranging from sand to boulders, the Higgins

39 eye are typically found in large, stable, species-diverse mussel beds (FWS 2000a; 2004a).

40 Current velocities typical of Higgins eye habitat range from 0.5 to 1.5 fps (1.5 to 4.5 cm/s), and

41 depths range from 3.3 to 19.7 ft (1-6 m) (FWS 2000a). Although no critical habitat is listed for

42 the species, 10 Essential Habitat Areas (EHAs) have been designated for the Higgins eye: six in

43 the Mississippi River, three in the St. Croix River, and one in the Wisconsin River (FWS 2004a).

44 The closest EHA to PINGP 1 and 2 is in the St. Croix river, just upstream of the junction with the

45 Mississippi River, near Prescott, Wisconsin (FWS 2004a).

October 2009 2-35 Draft NUREG-1437, Supplement 39
Affected Environment

1 To reproduce, male Higgins eyes release sperm into the water. As the females siphon water for

2 food, they also take in the'sperm to fertilize eggs in gill sacs (marsupia), where the fertilized

3 eggs mature into glochidia, a larval stage. The ribbon-like mantle edge near the posterior of the

4 female acts as a lure to attract fish; when the fish attack the mantle, glochidia are released into

5 the water and attach to the gills of the host fish. If the glochidia successfully attach to fish gills,

6 they can mature into juvenile mussels (typically 3 weeks), excyst from the gills, settle to suitable

7 substrate, and mature into adults. Some studies suggest glochidia remain in the marsupia

8 through winter and are released in spring or summer. (FWS 2000a; FWS 2004a)

9 Suitable fish hosts for the glochidia of the Higgins eye pearlymussel include freshwater drum

10 (Aplodinotus grunniens), largemouth bass (Micropterus salmoides), smallmouth bass

11 (Micropterus dolomieu), yellow perch (Perca falvescens), sauger (Stizostedion canadense), and

12 walleye (Stizostedion vitreum vitreum); marginal fish hosts include northern pike (Esox lucius),

13 bluegill (Lepomis macrochirus), and green sunfish (Lepomis cyanellus) (FWS 2004a).

14 Currently, the major threat to the Higgins eye pearlymussel, like most other native mussels in

15 the Upper Mississippi River, is the invasion of the zebra mussel. As described in Section 2.2.5,

16 zebra mussels compete for food and space, and even colonize on native mussels. The

17 subfamily Lampsilinae (to which the Higgins eye belongs) is one of the most sensitive groups of

18 mussels to zebra muscles (FWS 2000a). Researchers have not developed effective and

19 practical measures to control zebra populations without harming native aquatic organisms

20 (WDNR 2004).

21 The creation of the lock and dam system in the Upper Mississippi River has resulted in pools

22 replacing once-flowing water, and species of fish that serve as hosts to native mussel species

23 are now restricted in their movements. In the case of the Higgins eye, it is possible that the

24 damming of the Mississippi led to higher populations of the species in some pools, given the

25 species' propensity towards low velocity waters. However, some observations state that the

26 population of Higgins eye has decreased since impoundment in other pools, possibly due to

27 conditions such as increased sedimentation. Therefore it is uncertain how the changes to the

28 Mississippi River have affected the Higgins eye populations. (FWS 2000a)

29 Other activities, such as dredging, the disposal of dredged material, channelization, and

30 commercial navigation are all threats to the survival of native mussel species, including Higgins

31 eye pearlymussel. There are few documented reports of the commercial harvest of Higgins eye.

32 (FWS 2000a)

33 In 1993, the USACE began a consultation with the FWS under Section 7 of the Endangered

34 Species Act of 1973 (ESA) for a project, the operation and maintenance of the 9-foot Navigation

35 Project on the Upper Mississippi River. The Higgins eye pearlymussel was included in this

36 consultation. In 2000, FWS issued a Biological Opinion (BO) (FWS 2000a), with a jeopardy

37 determination for the Higgins eye. In the BO, FWS provided reasonable and prudent

38 alternatives to allow for the project while offsetting adverse impacts to the species involved,

39 including the alternative that USACE develop a Higgins' eye pearlymussel relocation action

40 plan, as well as conduct a study to control the spread of zebra mussels.

41 In 2002, USACE, in cooperation with the Mussel Coordination Team, an interagency team of

42 biologists, issued a definite project report and environmental assessment for a relocation plan

43 for the Higgins eye (USACE 2002), with a proposal to establish five new populations of the

44 Higgins eye by moving adults from zebra mussel-infested areas into sections of the river that

45 had no or low levels of zebra mussels, as well as raising juvenile mussels at hatcheries and

46 stocking areas of the river (USACE 2002).

Draft NUREG-1437, Supplement 39 2-36 October 2009
Affected Environment

1 A team including FWS, USACE, and the Mussel Coordination Team, selected an area within

2 Pool 3, 0.5 mi (0.8 km) upstream of the PINGP 1 and 2 intake structure for one of the relocation

3 sties. In the 2002 environmental assessment (USACE 2002), the USACE states that this site

4 had shown good recovery of mussels after the relocation of 100 adult Higgins eye by MNDNR,

5 WDNR, and FWS. In addition, the location was identified as a good relocation site based on the

6 2000 Minnesota 305(b) water quality status report, which listed Pool 3 as "full support" for

7 aquatic life (USACE 2002). Over 4000 sub-adults have been relocated to the Sturgeon Lake

8 section of Pool 3, as of the 2005 Status Report (Mussel Coordination Team 2005). The Mussel

9 Coordination Team (2005) reported "good recovery" for Pool 3 subadults after conducting

10 monitoring in 2003. Other sites have not had as positive results, such as Pool 4 (just

11 downstream of Lock and Dam 3, in which only 5 percent of the mussels were recovered;

12 predation by carp could be the cause of the low success of the Pool 4 population (Mussel

13 Coordination Team 2005).

14 Winqed mapleleaf

15 The winged mapleleaf (Quadrula fragosa) is Federally listed as an endangered species.

16 Historically found in 34 rivers and 12 states, the winged mapleleaf has been limited to one

17 population that is known to be reproducing, on a 12.4-mi stretch of the St. Croix River, 44 river

18 miles upstream of the confluence with the Mississippi (FWS 2000a). Additionally, there are

19 populations in the Ouachita and Saline Rivers of Arkansas and the Bourbeuse River in Missouri

20 (FWS 2004b). The FWS lists the winged mapleleaf as endangered within Washington County. It

21 is also state-listed as endangered by Minnesota in Dakota and Washington Counties (counties

22 crossed by PINGP 1 and 2 transmission lines), and by Wisconsin in Pierce County (the county

23 located across the Mississippi River from PINGP 1 and 2) (FWS 2008d; MNDNR 2008b; WDNR

24 2008). The winged mapleleaf is not known to be present in the vicinity of PINGP 1 and 2 or

25 associated transmission line ROWs.

26 Spectaclecase and Sheepnose

27 The spectaclecase (Cumberlandia monodonta) and sheepnose (Plethobasus cyphyus) are

28 considered candidates for listing by FWS. In Minnesota, populations of spectaclecase exist in

29 the Mississippi and St. Croix Rivers and Rush Creek; populations of sheepnose (also called

30 bullhead) occur in the Mississippi and St. Croix Rivers (FWS 2002a; 2002b). Neither species of

31 mussel is known to be present in the vicinity of PINGP 1 and 2 or associated transmission line

32 ROWs.

33 Paddlefish

34 The paddlefish (Polyodon spathula) is state-listed by both Minnesota and Wisconsin as

35 threatened. Reaching weights of 50 lb (23 kg) in Minnesota, topping 150 lb (68 kg) farther south,

36 the paddlefish feeds on plankton, is found in larger rivers and river lakes, and migrates into

37 streams to spawn (Phillips et al. 1982). Human activities including water pollution,

38 channelization, dredging, damming rivers, and over-fishing have reduced the numbers of

39 paddlefish in the Mississippi River drainage (Schmidt 2004). Sturgeon Lake once provided

40 habitat for the paddlefish, but sediment deposition reduced the suitability of the area for the fish

41 (Schmidt Undated). However, individuals are occasionally found in the vicinity of PINGP 1 and 2

42 by Xcel Energy biologists.

43 Mucket, Butterfly, and Washboard

44 The mussels mucket (Actinonaias ligamentina), butterfly (Ellipsaria lineolata), and washboard

45 (Megalonaias nervosa) are all Minnesota state-listed as threatened (MNDNR 2008b); Wisconsin

46 lists the butterfly as endangered, and washboard as a species of special concern (WDNR

47 2008). The threats to these species are typical of the threats to mussels in the Mississippi,

October 2009 2-37 Draft NUREG-1437, Supplement 39
Affected Environment

1 including impoundment, dredging, and zebra mussel infestation. All three have been found in

2 the vicinity of the PINGP 1 and 2 site.

3 Table 2-11. Listed Aquatic Species. The species below are Federally listed,

4 Minnesota-listed, and/or Wisconsin-listed as threatened, endangered, or candidate

5 species. These species may occur on the PINGP 1 and 2 site, within the Upper

6 Mississippi River Basin, or within the transmission line rights-of-way.

Scientific Name Common Name(a) Federal Status(b) State Status(c)

Fish

Acipenser fulvescens lake sturgeon - MSC; WSC

Alosa chrysochloris skipjack herring - MSC; WE

Ammocrypta asprella crystal darter - MSC; WE

Anguilla rostrata American eel - WSC

Clinostomus elongatus redside dace WSC

Cycleptus elongatus blue sucker MSC; WT

Etheostoma asprigene mud darter WSC

Etheostoma clarum western sand darter - WSC

Fundulus diaphanus banded killifish - WSC

Hiodon alosoides goldeye WE

Ictiobus niger black buffalo MSC; WT

Macrhybopsis aestivalis shoal chub WT

Macrhybopsi storeiana silver chub - WSC

Moxostoma carinatum river redhorse - WT

Notropis amnis pallid shiner MSC; WE

Notropis texanus weed shiner WSC

Opsopoeodus emiliae pugnose minnow - WSC

Polyodon spathula paddlefish MT; WT

Mussels

Actinonaias ligamentina mucket - MT

Draft NUREG-1437, Supplement 39 2-38 October 2009
Affected Environment

Scientific Name Common Name(a) Federal Status(b) State Status(c)

Alasmidonta marginata elktoe MT; WSC

Arcidens confragosus rock pocketbook ME; WT

Cumberlandia monodonta spectaclecase C MT; WE

Cyclonaias tuberculata purple wartyback - MT; WE

Ellipsaria lineolata butterfly MT; WE

Elliptio crassidens elephant-ear ME; WE

Elliptio dilatata spike MSC

Epioblasma triquetra snuffbox MT; WE

Fusconaia ebena ebonyshell ME; WE

Lampsilis higginsi Higgins eye E ME; WE

Lampsilis teres yellow/slough sandshell - ME; WE

Lasmigona costata fluted-shell MSC

Ligumia recta black sandshell - MSC

Megalonaias nervosa washboard MT; WSC

Obovaria olivaria hickory nut MSC

Plethobasus cyphyus sheepnose (bullhead) C ME; WE

Pleurobema sintoxia (formerly P. round pigtoe MT; WSC

coccineu)

Quadrula fragosa winged mapleleaf E ME; WE

Quadrula metanevra monkeyface MT; WT

Quadrula nodulata wartyback ME

Tritogonia verrucosa pistolgrip (buckhorn) - MT; WT

(a) Common names indicated by parentheses are those listed by the Wisconsin Department of Natural Resources

(b) C = Candidate; E = Federally endangered; T = Federally threatened; - = No listing

(c) ME = Minnesota endangered; MT = Minnesota threatened; MSC = Minnesota species of concern; WE =

Wisconsin endangered; WT = Wisconsin threatened; WSC = Wisconsin species of concern

Sources: FWS 2008a; MNDNR 2008b; NMC 2008; WDNR 2008

October 2009 2-39 Draft NUREG-1437, Supplement 39
Affected Environment

1 2.2.7.2 Terrestrial Species

2 Two Federally listed species, the dwarf trout lily (Erythronium propullans) and the prairie bush

3 clover (Lespedeza leptostachya), potentially occur on or in the vicinity of the PINGP 1 and 2 site

4 or along the in-scope transmission line ROWs. One state-listed species, the peregrine falcon

5 (Falco peregrinus), is known to occur in the vicinity of PINGP 1 and 2.

6 Dwarf Trout Lily

7 The dwarf trout lily is Federally and Minnesota State-listed as endangered. The species is a

8 spring ephemeral wildflower endemic to Minnesota and only occurs in Rice, Goodhue, and

9 Steele Counties within the Straight, Cannon, Little Cannon, and North Fork Zumbro Rivers and

10 Prairie Creek (FWS 2008c; Sather 1990a). Dwarf trout lily is found on north-facing slopes of

11 maple- and basswood-dominated forests as well as elm- and cottonwood-dominated floodplains

12 (FWS 2008c). Leaves are tapered and slightly mottled in color, and small, pale pink, four- to six13 petal flowers are sparsely dispersed (Sather 1990a). The plant's rarity is attributed to its slow

14 rate of reproduction as only a small percentage (one-tenth) of plants produce flowers each

15 spring (Sather 1990a). The species generally reproduces vegetatively by putting out

16 underground runners that bear new bulbs (Sather 1990a; FWS 2008c). Neither the FWS nor the

17 MNDNR listed this species as present on or in the vicinity of the PINGP 1 and 2 site in their

18 correspondence with the NRC regarding the proposed license renewal of PINPG (FWS 2008b;

19 MNDNR 2008b).

20 Prairie Bush Clover

21 The prairie bush clover is Federally and Minnesota State-listed as threatened. The species is a

22 slender-leaved legume in the pea family with pink to cream flowers that bloom in July (Sather

23 1990b). The prairie bush clover is endemic to the Midwest and only occurs in Minnesota,

24 Wisconsin, Iowa, and Illinois tall-grass prairie habitat within the upper Mississippi River Valley

25 (FWS 2000b). In 1990, about 100 known prairie bush clover sites existed, and by 2000, fewer

26 than 40 known sites remained (FWS 2000b; Sather 1990b). Loss of prairie habitat is attributed

27 to this species' decline (FWS 2000b). Neither the FWS or MNDNR listed this species as present

28 on or in the vicinity of the PINGP 1 and 2 site in their correspondence with the NRC regarding

29 the proposed license renewal of PINPG (FWS 2008b; MNDNR 2008b).

30 Peregrine Falcon

31 The peregrine falcon was removed from Federal listing in August 1999 but continues to be

32 threatened at the State level. Adult birds have a bluish-black head and wings, are 14 to 19 in.

33 (36 to 48 cm) tall, and have a wingspan of 39 to 43 in. (99 to 109 cm) (Cornell 2003). Peregrine

34 falcons nest from April to July on high cliffs and bluffs and on tall city buildings along the North

35 Shore of Lake Superior and the Mississippi River in the southeastern portion of the State

36 (MNDNR 2008d). Females lay 2 to 5 eggs, which hatch in 28 to 29 days, and young leave the

37 nest within 6 to 9 weeks of hatching (MNDNR 2008d). Peregrine falcons prey on ducks,

38 pigeons, and other birds as well as small mammals and insects (MNDNR 2008d).

39 Approximately 36 breeding pairs nest in Minnesota (MNDNR 2008d).

40 The PINGP 1 and 2, Unit 1, containment building has a nest box, in which a breeding pair has

41 nested consistently since 1997 (NMC 2008). The pair is usually first observed in March, and

42 young fledge by July; NSP has recorded 31 falcons that have fledged since 1997 (NMC 2008).

43 NSP has designated staff members to monitor the peregrine falcons on site in conjunction with

44 the MNDNR and the University of Minnesota Raptor Center. NSP educates its staff members on

45 the falcons to ensure the safety of the birds in the event that specialists would need to be

46 notified, such as if a fledgling fell from the nest and required veterinary care.

Draft NUREG-1437, Supplement 39 2-40 October 2009
Affected Environment

1 Bald Eagle

2 The bald eagle (Haliaeetus leucocephalus) is a species of special concern in the State of

3 Minnesota. Bald eagles mature at 4 to 5 years of age and average 8 to 9 lbs (kg) for males and

4 10 to 14 lbs (kg) for females with a 6 to 7.5 ft (m) wingspan (MNDNR 2008a). The FWS formally

5 removed the bald eagles from the Federal List of Endangered and Threatened Wildlife effective

6 August 8, 2007 though the species continues to be protected under the Bald and Gold Eagle

7 Protection Act and the Migratory Bird Treaty Act (72 FR 37346). Two bald eagle nests are

8 known to occur near the PINGP 1 and 2 site, though no bald eagle nests have been observed

9 on PINGP 1 and 2 property (NMC 2008). A nest is located on the Vermillion River just south of

10 the PINGP 1 and 2 site, and a nest is located approximately 2 mi (km) upstream of Lock and

11 Dam 3 on the Mississippi River (NMC 2008). The Minnesota population continues to grow.

12 According to statewide bald eagle surveys conducted by MNDNR in conjunction with the FWS

13 and USGS, a 28 percent increase in active nests was observed between 2000 and 2005

14 (MNDNR 2006a).

15 Trumpeter Swan

16 The trumpeter swan (Cygnus buccinator) is migratory bird that is Minnesota State-listed as

17 threatened. Adult trumpeter swans have white plumage and black bills and feet. Adults are 4 to

18 5 ft (m) tall, have a wingspan up to 8 ft (m), and weigh 20 to 30 lbs (kg) (MNDNR 2008f). Swans

19 nest in marshy areas beginning at 3 to 4 years of age, and females lay clutches of 5 to 7 eggs in

20 late April, which hatch within 33 to 37 days (MNDNR 2008f). Young swans generally fly at 14 to

21 17 weeks of age (MNDNR 2008f). The MNDNR Nongame Wildlife Program has been involved

22 in restoration efforts of the Minnesota flock since the 1980s, and the population has gone from

23 virtually extinct to more than 2000 individuals as of 2004 (MNDNR 2008g). The MNDNR did not

24 list this species as prescent on or in the vicinity of the PINGP 1 and 2 site in their

25 correspondence with the NRC regarding the proposed renewal of PINGP 1 and 2 (MNDNR

26 2008b).

27 Table 2-12. Listed Terrestrial Species. The species below are Federally listed,

28 Minnesota-listed, or both, as threatened, endangered, or candidate species. These

29 species may occur on the PINGP I and 2 site, within the Mississippi River, or within the

30 transmission line ROWs.

Federal State

Scientific Name Common Name Ftal Status(a) State Status(b) Habitat

Reptiles and Amphibians

Acris crepitans northern cricket frog - ME ponds and streams with

submerged vegetation

Clemmys insculpta wood turtle - MT large rivers with sandy

substrate

Coluber constrictor blue racer - MSC riparian areas; swamps

Crotalus horridus timber rattlesnake - MT forested areas; swamps

Emydoidea Blanding's turtle - MT shallow ponds; marshes;

blandingii swamps

Pituophis catenifer gopher snake - MSC woodlands; agricultural

areas; prairie

October 2009 2-41 Draft NUREG-1437, Supplement 39
Affected Environment

Scientific Name Common Name Federal State Habitat Status(a) Status(b)

Insects

Aflexia rubranura red tailed prairie - MSC mesic prairie

leafhopper

Speyeria idalia regal fritillary - MSC tall-grass prairie; meadows;

floodplain forest edges

Birds

Buteo lineatus red-shouldered hawk - MSC deciduous and deciduousconifer forest; swamps

.Cygnus buccinator trumpeter swan - MT prairie; marshes; shallow

lakes

Dendroica cerulea cerulean warbler - MSC old-growth deciduous

floodplain forest

Falco peregrinus peregrine falcon - MT grasslands; meadowlands

Haliaeetus bald eagle DL MSC forested areas near open

leucocephalus water

Lanius ludovicianus loggerhead shrike - MT thicketed areas; meadows

bordered by trees

Sterna forsteri Forster's tern - MSC marshes

Wilsonia citrina hooded warbler - MSC heavily forested areas

Mammals

Perognathus plains pocket mouse - MSC sparsely vegetated areas

flavescens

Plants

Agalinis auriculata

Aristida tuberculosa

Arnoglossum

plantagineum

Asclepias

amplexicaulis

Asclepias sullivantii

Besseya bullii

Botrychium

oneidense

eared false foxglove

sea-beach

needlegrass

tuberous Indianplantain

clasping milkweed

sullivant's milkweed

kitten-tail

blunt-lobed

grapefern

ME

MSC

MT

MSC

MT

MT

ME

mesic tall-grass prairie

prairie

prairie

prairie; sand barrens

prairie; sedge meadows

prairie

moist, acidic woods; swamps

Draft NUREG-1437, Supplement 39 2-42 October 2009
Affected Environment

Scientific Name Common Name Federal State Habitat Status(a) Status(b)

Botrychium

rugulosum

Carex sterilis

Cirsium hillii

Cladium

mariscoides

Cristatella jamesii

Cypripedium

candidum

Eleocharis

rostellata

Eryngium

yuccifolium

Erythronium

propullans

Hudsonia

tomentosa

Juniperus

horizontalis

Lespedeza

leptostachya

Lesquerella

ludoviciana

Minuartia

dawsonensis

Oenothera

rhombipetala

Opuntia macrorhiza

Orobanche

fasciculata

Panax

quinquefolius

Rhynchospora

capillacea

Scirpus clintonii

Scleria verticillata

Trillium nivale

St. Lawerence

grapefern

sterile sedge

Hill's thistle

twig-rush

James' polanisia

small white Lady'sslipper

beaked spike-rush

rattlesnake-master

dwarf trout lily

beach-heather

creeping juniper

prairie bush clover

bladder pod

rock sandwort

rhombic-petaled

evening primrose

plains prickly pear

clustered broomrape

American ginseng

hair-like beak-rush

Clinton's bulrush

whorled nut-rush

snow trillium

E

T

MT

MT

MSC

MSC

ME

MSC

MT

MSC

ME

MSC

MSC

MT

ME

MSC

MSC

MSC

MSC

MSC

MT

MSC

MT

MSC

open fields; secondary

forests

lowland forest

prairie

sand dunes

river banks; prairie

lowland forest; .prairie

wet fens; shores

prairie

deciduous forest floodplains

sand barrens

cliffs; sand barrens; sand

dunes

prairie

coastal bluffs; prairie

disturbed slopes; mesic

forest openings; prairie

prairie; sand barrens

grassy woodlands;

coniferous forests

prairie

upland forests

sand dunes

open forested areas;

wetlands

marshes; bogs

forested areas; floodplain

October 2009 2-43 Draft NUREG-1437, Supplement 39
Affected Environment

Scientific Name Common Name Federal State Habitat Status(a) Status(b)

riverbanks

Valeriana edulis valerian MT lowland forest; prairie

ciliata

(a) DL = Delisted; E = Federally endangered; T = Federally threatened; - = No listing

(b) ME = Minnesota endangered; MT = Minnesota threatened; MSC = Minnesota species of concern

Sources: FWS 2008a; MNDNR 2008b; NMC 2008

1 2.2.8 Socioeconomic Factors

2 This section describes current socioeconomic factors that have the potential to be directly or

3 indirectly affected by changes in PINGP 1 and 2 operations. PINGP 1 and 2 and the

4 communities that support it can be described as a dynamic socioeconomic system. The

5 communities provide the people, goods, and services required to operate PINGP 1 and 2.

6 PINGP 1 and 2 operations, in turn, create the demand and pay for the people, goods, and

7 services in the form of wages, salaries, and benefits for jobs and dollar expenditures for goods

8 and services. The measure of the communities' ability to support the demands of PINGP 1 and

9 2 depends on their ability to respond to changing environmental, social, economic, and

10 demographic conditions.

11 The socioeconomics region of influence (ROI) is defined as the areas in which PINGP 1 and 2

12 employees and their families reside, spend their income, and use their benefits, thereby

13 affecting the economic conditions of the region. The PINGP 1 and 2 ROI consists of a three14 county area (Goodhue and Dakota Counties in Minnesota and Pierce County in Wisconsin)

Draft NUREG-1437, Supplement 39 2-44 October 2009
Affected Environment

Legend

: -:Xcel En.19y P....elly

C3 Plant Feslt.,e

ffl Eo h- Afo~ea 80.. 8ty

Prairoe W~at~ol cr, Con-k~ty

- Local Ne.j~fhD,Tho m Rwal Roao

0 5W) 1,000 2,000) IWO) 4,000

Figure 2-2. PINGP General Site Layout

and Exclusion Area Boundary

(Source: NMC 2008)

1

2 where approximately 83 percent of PINGP 1 and 2 employees reside as well as the PH1

3 following sections describe the housing, public services, offsite land use, visual aesthel

4 noise. DoDulation demoaraohv, and economv in PINGP 1 and 2's ROI.

C. The

tics and

I , I

October 2009 2-45 Draft NUREG-1437, Supplement 39
Affected Environment

1 NSP employs a permanent workforce of approximately 685 employees (NMC 2008).

2 Approximately 83 percent live in Goodhue County and Dakota County, Minnesota, and Pierce

3 County, Wisconsin (Table 2.13). The remaining 17.2 percent of the workforce are divided

4 among 21 counties in Minnesota and Wisconsin with numbers ranging from 1 to 47 employees

5 per county. Given the residential locations of PINGP 1 and 2 employees, the most significant

6 impacts of plant operations are likely to occur in Goodhue County, Dakota County, and Pierce

7 County. Therefore, the socioeconomic impact analysis in this SEIS will focus on the impacts of

8 PINGP 1 and 2 on these three counties.

9 Table 2-13. PINGP 1 and 2 Employee Residence by County

Percentage

County Number of Employees of Total

Goodhue, MN 329 48

Dakota, MN 139 20

Pierce, WI 99 15

Other 118 17

Total 685 100

Source: NMC 2008

10 Refueling outages at PINGP 1 and 2 generally occur at 20-month intervals. During refueling

11 outages, site employment increases by as many as 925 workers for approximately 45 to 90

12 days (NMC 2008). Most of these workers are assumed to be located in the same geographic

13 areas as the permanent PINGP 1 and 2 staff.

14 2.2.8.2 Housing

15 Table 2.14 lists the total number of occupied and vacant housing units, vacancy rates, and

16 median value in the three-county ROL. According to the 2000 Census, there were over 165,000

17 housing units in the socioeconomic region, of which approximately 161,000 were occupied. The

18 median value of owner-occupied units ranged from $116,000 in Goodhue County to $152,400 in

19 Dakota County. Goodhue County has the highest vacancy rate (5.0 percent), followed by 20 Pierce County (3.5 percent), and then Dakota County (1.9 percent). (USCB 2000)

21 By 2007, the estimated number of housing units within the three counties grew by approximately

22 14.2 percent. In Goodhue County, the number of housing units grew by 10.9 percent to an

23 estimated 19,830 units. In Dakota County the number of housing units grew by 14.6 percent to

24 an estimated 153,326 units. In Pierce County, the number of housing units grew by 13.8 percent

25 to an estimated 15,354 units. (USCB 2007)

26

Draft NUREG-1437, Supplement 39 2-46 October 2009
Affected Environment

1

2

Table 2-14. Housing in Goodhue County and Dakota Counties, Minnesota,

County, Wisconsin

and Pierce

Goodhue Dakota Pierce Region

2000

Total 17,879 133,750 13,493 165,122

Occupied housing units 16,983 131,151 13,015 161,149

Vacant units 896 2,599 478 3,973

Vacancy rate (percent) 5.0 1.9 3.5 2.4

Median value (dollars) 116,000 152,400 123,100 130,500

2007(a)

Total 19,830 153,326 15,354 188,510

Occupied units 18,438 146,728 14,706 179,872

Vacant units 1,392 6,598 648 8,638

Vacany rate (percent) 7.0 4.3 4.2 4.6

Median value (dollars) 192,100 246,800 203,600 214,167

(a)Housing values for 2007 are estimates based on 2005-2007 American Community Survey 3-Year

Estimates, U.S. Census Bureau

Sources: USCB 2000; USCB 2007

3 2.2.8.3 Public Services

4 This section presents a discussion of public services including water supply, education, and

5 transportation.

6 Water Supply

7 Because approximately 83 percent of workers at PINGP 1 and 2 reside in Goodhue and Dakota

8 Counties, Minnesota, and Pierce County, Wisconsin, the discussion of public water supply

9 systems is limited to these counties. In Table 2.15, information about major municipal water

10 suppliers in the three counties, their permitted capacities and/or maximum design yields,

11 reported annual peak usage, and population served are presented. The primary source of

12 potable water in the vicinity of the PINGP 1 and 2 is groundwater (NMC 2008).

13 Goodhue County tries to balance the county's natural resources, environmental habits, and

14 growth to achieve long-term economic and ecological sustainability. Erosion control and

15 stormwater issues are the greatest concern to watershed impacts. Planning officials are

16 concerned with agricultural and household contaminants getting into the groundwater and the

17 potential impact this could have on surface water (Goodhue County 2004).

18 Dakota County is concerned about projected population growth through 2025 and the impact

19 this growth will have on the availability of groundwater and the effect this could have on surface

20 water resources, which are dependent on groundwater (Dakota County 2005).

21 Approximately 70 percent of Wisconsin's private residents and most public water systems use

22 groundwater for their water source. Wisconsin implemented a program in 1999 designed to

23 develop capacity for these water systems. A capacity evaluation is required for all new water

24 supply systems.

25 Most of the PlIC's water is supplied by the PIIC's central water system. This system

26 serves all homes immediately adjacent to PINGP 1 and 2, the Treasure Island Resort

October 2009 2-47 Draft NUREG-1437, Supplement 39
Affected Environment

1 and Casino, Dakota Station and government offices. The PIIC's average winter daily

2 use is approximately 100,000 gpd (379,000 liters per day [LPD]), and their average

3 summer daily use is approximately 370,000 gpd (1,401,000 LPD). Treasure Island has

4 480 sleeping rooms, which typically increase summer water use by approximately

5 370,000 gpd (1,401,000 LPD). The total expected peak daily usage is approximately

6 740,000 gpd (2,800,000 LPD). The central water system draws from the Mt. Simon7 Hinckley aquifer at a depth of 500 ft (150 m). (PIIC 2008)

8 The newer homes on the PIIC's Upper Island land, which are located about 3 mi (5 km)

9 from the PINGP 1 and 2 site, have individual wells. These wells draw from the Mt.

10 Simon-Hinckley aquifer at about 180 ft (55 m). The 47 proposed additional homes,

11 which would be located about 2 mi (3.2 km) from the PINGP 1 and 2 site, may also use

12 individual wells. (PIIC 2008)

13 Education

14 PINGP 1 and 2 are located in Red Wing School District 256, which had an enrollment of

15 approximately 2,900 students in the 2007-2008 school year (MDE 2007; 2008a). Including

16 School District 256, Goodhue County has 4 public school districts with over 7,000 enrolled

17 students (MDE 2008a, MDE 2008b). Dakota County has 8 public school districts (MDE 2008a).

18 Total enrollment in Dakota County public schools in the 2007-2008 school year was

19 approximately 74,500 students (MDE 2008b). Pierce County, Wisconsin, has 6 public school

20 districts with a total enrollment of 7452 students (WDPI 2009).

21 Children from the PIIC attend Red Wing public schools or private schools. Additionally, the PIIC

22 offers its members tutoring services, Dakota language classes, summer school, GED

23 preparation, and assistance with college applications at its Learning Center, located on Prairie

24 Island (PIIC 2008).

25

Draft NUREG-1437, Supplement 39 2-48 October 2009
Affected Environment

1 Table 2-15. Major Public Water Supply Systems (in million gallons per day [gpd])

Peak Annual

Water Withdrawal Permitted Annual Population

Water Supplier a Source(a)(b) (2004 - 2007)(c) Withdrawal(b) Served(c)

Goodhue County, Minnesota

City of Cannon Falls GW 206 1,250 3,800

City of Kenyon GW 65 144 1,700

City of Pine Island GW 119 332 2,300

City of Red Wing GW 624 6,750 16,100

City of Wanamingo GW 35 120 1,000

City of Zumbrota GW 179 660 3,000

Dakota County, Minnesota

City of Apple Valley GW 2,640 57,000 48,000

City of Burnsville GW 2,980 57,800 62,200

City of Eagan GW 3,350 89,700 66,700

Empire Township GW 81 270 1,300

City of Farmington GW 810 8,000 18,000

City of Hastings GW 1,000 7,000 21,600

City of Inver Grove Heights GW 1,150 10,000 33,200

City of Lakeville GW 2,550 48,000 52,000

City of Rosemount GW 944 11,500 21,000

City of South St. Paul GW 1,240 9,600 20,300

Pierce County, Wisconsin

Ellsworth Waterworks GW 101 368 2,800

Prescott Waterworks GW 171 1,310 4,000

River Falls Waterworks GW 396 2,600 12,600

Spring Valley Waterworks GW 38 258 1,300

(a) GW = Groundwater; SW = surface water

(b) EPA 2008b

Cc) MNDNR 2008 for Minnesota; NMC 2008 for Wisconsin.

Sources: EPA 2008; MNDNR 2008; NMC 2008.

2 Transportation

3

4

5

6

7

8

9

10

11

12

13

Plant workers that commute from northeastern, southern, and central Dakota County may take

U.S. Highway (US) 61 East (1) to the intersection of County Road 19, (2) continue to County

Road 31, which connects with County Road 18, or (3) continue east on US 61 to County Road

18. For each route, workers must travel north on County Road 18 to Sturgeon Lake Road and

then proceed east approximately 0.5 mi (0.8 km) on Sturgeon Lake Road, turn south onto the

plant access road, and proceed to the plant entrance just past the intersection of Wakonade

Drive. Plant workers that commute from the southern and eastern portions of Dakota County

willl most likely travel to PINGP 1 and 2 via US 61.

Workers that commute from Pierce County may take US 63 and cross into Goodhue County at

Red Wing and continue to US 61. Pierce County employees may also cross the Mississippi

River via US 10, which connects with US 61 South via State Road 316. Employees would then

October 2009 2-49 Draft NUREG-1437, Supplement 39
Affected Environment

1 travel southeast to Goodhue County Road 68 and then northeast to County Road 18.

2 Commuters may also access County Road 18 via County Road 54 in Hastings to County Road

3 68 East.

4 Table 2.16 lists commuting routes to PINGP 1 and 2 and average annual daily traffic (AADT)

5 volumes. The AADT values represent traffic volumes for a 24-hour period factored by both day

6 of week and month of year. Table 2.16 data indicates that current AADTs are below maximum

7 capacities for the roads leading to PINGP 1 and 2.

8 Because Sturgeon Lake Road is the only access road to the PIIC and PINGP 1 and 2,

9 the PIIC is concerned about PINGP 1 and 2-related traffic impacts. Many PINGP 1 and

10 2 employees exit the plant in the afternoon via Wakonade Drive, which is currently

11 limited to north-bound out-going traffic from the PINGP 1 and 2 site, and proceed to

12 Sturgeon Lake Road and through the PIIC reservation, rather than accessing Sturgeon

13 Lake Road directly from the plant access road. This traffic volume is cause for concern

14 to the PIIC because the section of Sturgeon Lake Road that runs through the reservation

15 has more pedestrian, bicycle, and small motorized cart traffic than the rest of the road.

16 (PIIC 2009)

17 In addition to the traffic created by 685 full-time employees of PINGP 1 and 2 (and as

18 many as 925 additional workers during outages), daily traffic on Sturgeon Lake Road

19 includes approximately 102 Tribal government employees, and as many as 16,000

20 Treasure Island guests, and 1,500 Treasure Island employees. (PIIC 2009)

21 2.2.8.4 Offsite Land Use

22 Offsite land use conditions in Goodhue County, Dakota County, and Pierce County are

23 described in this section. In addition to property taxes, Goodhue and other counties in the

24 vicinity of PINGP 1 and 2 also receive revenue from sales taxes and fees paid by NSP and its

25 employees residing in the region. Changes in the number of workers at PINGP 1 and 2 and tax

26 payments to local jurisdictions could affect land use conditions in these counties. PINGP 1 and

27 2 are located in northeastern Goodhue County. Dakota County and Pierce County are located

28 north and northeast of Goodhue County along the Mississippi River.

29 Although Goodhue County remains largely undeveloped, the county's population has

30 experienced some growth (see Section 2.2.8.5) and State and local planning officials expect the

31 county to grow another 7 percent by 2010. The majority of residential, commercial, and

32 industrial development has occurred along two highway corridors, US 61 and US 52. Regional

33 planners estimate that, as the Minneapolis-St. Paul area continues to expand and commuting

34 distances increase, growth will continue in this region (Goodhue County 2004).

35 Goodhue County has a comprehensive land use plan and zoning and subdivision ordinances to

36 guide development. The ordinances promote the public health, safety, and general welfare of

37 residents; protect agricultural land from urban sprawl; and provide a basis for orderly

38 development. The ordinances require building permits, conditional use permits, plat

39 development, zoning district controls, and variance requests; however, the county has no formal

40 growth control measures.

Draft NUREG-1437, Supplement 39 2-50 October 2009
Affected Environment

Table 2-16. Major Commuting Routes in the Vicinity of the Prairie Island Nuclear

Generating Plant and 2007 Average Annual Daily Traffic (AADT) Counts

Road/Highway Capacity Annual Average Daily Roadway and Location (vehicles per day) Traffic (AADT)(al

County Road 18 (just north of intersection 12,000 6,000

with Sturgeon Lake Road)

County Road 18 Segment (south of

intersection with Sturgeon Lake Road and 12,000 6,300

north of County Road 19)

County Road 18 (between County Road

19 and County Road 46, Mt. Carmel 12,000+ 6,200

Road)

Sturgeon Lake Road 20,000 10,500

County Road 19 (between County Road 5,000 315

18 and U.S. Highway 61)

County Road 31 (between County Road 10,000 530

18 and U.S. Highway 61)

County Road 7 (just south of intersection N/A 580

with U.S. Highway 61)

U.S. Highway 61 (between CountyRoad 40,000 17,000

18 and County Road 19)

U.S. Highway 61 (between State Road 40,000 11,200

316 and County Road 19)

(a) All AADTs represent traffic volume during the average 24-hour day during 2006.

Source: Mn/DOT 2007; NMC 2008

1 Dakota County. Minnesota

2

3

4

5

6

7

8

9

10

11

12

13

Dakota County is located south of Minneapolis-St. Paul and covers approximately 370,000 ac

(150,000 ha). The largest category of land use in Dakota County is agricultural. Land used for

agriculture comprises approximately 65 percent of the county area. Commercial, industrial, and

residential land use covers 22 percent. Open water, parks, and public land cover the remaining

15 percent (Dakota County 1999). The majority of the county population is concentrated in the

northern third of the county.

As the cities of Minneapolis-St. Paul have grown, residential development has expanded to

neighboring counties, such as Dakota County, and residents commute to the cities for

employment (Dakota County 1999). In general, land use decision-making occurs at the city

and township level through zoning and the influence of land use planning at the regional level

(Dakota County 2005).

October 2009 2-51 Draft NUREG-1437, Supplement 39
Affected Environment

1 Pierce County, Wisconsin

2 Pierce County, located east of Minneapolis-St. Paul and northeast of PINGP 1 and 2, covers

3 approximately 380,000,ac (154,000 ha), and is currently developing a county-wide

4 comprehensive plan (Pierce County 2006). Land development activities are guided by the

5 County's municipalities through the use of local zoning and subdivision regulations until the

6 county plan is complete.

7 Pierce County planners report that, between 2002 and 2005, approximately 8 percent of the

8 county's farmland was converted from agriculture to other uses. Planners estimate that, by

9 2025, the county may need to accommodate over 7,000 ac (280 ha) of new residential,

10 commercial, and industrial land use along with additional acreage needed for infrastructure,

11 parks, community facilities, and similar uses (Pierce County 2006).

12 Prairie Island Indian Community

13 Most of the PIIC's lands are held in Trust, for the benefit of the PIIC, by the U.S. Government.

14 Trust status means that the land is protected from State or local jurisdiction, including taxation,

15 can never be sold, and is forever available for the common benefit of the Tribe. Regulations

16 governing the transfer of land into Trust can be found at 25 CFR 151. (PIIC 2008)

17 Past Congressional actions (i.e., the General Allotment Act or the Dawes Act, in effect from

18 1887 until 1934), resulted in the loss of Indian lands to non-Indians because of foreclosure due

19 to the inability to pay property taxes on land allotted to individual Indians. During the 47 years

20 that the Allotment Act was in effect, approximately 90,000,000 ac (36,400,000 ha) of Treaty21 protected land or about two-thirds of the 1887 national tribal land base was lost. The Indian

22 Reorganization Act (or Wheeler-Howard Act), passed by Congress in 1934, slowed the practice

23 of assigning tribal lands to individual tribal members and reduced the loss of Indian land

24 holdings. (PIIC 2008)

25 In addition to its Trust land, the PIIC also owns approximately 685 ac (280 ha) of land that is not

26 in Trust and is therefore subject to State and local land use jurisdiction. The Mount Frontenac

.27 Golf Course (426 ac [170 ha]) is not in Trust and the Tribe does not plan to request that the U.S.

28 Government, through the Bureau of Indian Affairs, take the land into Trust. The PIIC Tribal

29 Council is in the process of developing Fee-to-Trust applications for the remaining 259 ac (105

30 ha) of land in order to develop additional home sites. (PIIC 2008)

31 As mentioned previously, the PIIC's land (with the exception of the 685 ac [280 ha] not in Trust)

32 are not subject to State or local land use jurisdiction. The PIIC is therefore free to develop its

33 own land-use management policies and plans for Trust lands. Some land management projects"

34 include the following (PIIC 2008):

35 Native Prairie Restoration Project

36 The prairie restoration project has restored over 200 ac (80 ha) of native prairie.

37 The restored prairies serve several important functions: they are an important

38 food source for the Tribe's Buffalo herd; they are a potential source of medicinal

39 and culturally important plants; they protect the Mississippi River by reducing

40 agricultural and sediment run-off; and they provide important habitat for birds and

41 other wildlife. Since each prairie planting has its own personality, proper

42 management is the key to maintaining a healthy prairie. The Tribe is in the

43 process of creating a comprehensive prairie management plan to guide

44 management practices that will allow the tribe to create and maintain healthy

45 diverse prairies in the future. (PIIC 2008)

46 Wild Rice Re-seeding Project

Draft NUREG-1437, Supplement 39 2-52 October 2009
Affected Environment

1 Wild rice is culturally significant to the Prairie Island Indian Community and an

2 important food source for many waterfowl species found near Prairie Island. For

3 these reasons, the Tribe has been re-establishing wild rice beds since 2001. To

4 date, over 30 ac (12 ha) of wild rice have been seeded in wetlands along the

5 Mississippi River. This project will be continued until the wild rice plants are self6 sustaining. (PIIC 2008)

7 Water Quality Monitoring

8 The Prairie Island Indian Community has been conducting its own water quality

9 monitoring since 1999. The Tribe has collected water quality data for the lakes,

10 rivers, sloughs, and backwaters (i.e., habitats) adjacent to and within the study

11 area (i.e., the lands of the Prairie Island Indian Community). Current studies

12 include water quality monitoring, macroinvertebrate surveys, aquatic plant

13 surveys, sediment quality monitoring, and shoreline habitat/land use surveys.

14 This data will be useful in determining the current health of the lakes, river, and

15 wetlands and determining the viability of re-establishing freshwater fish and other

16 aquatic species. (PIIC 2008)

17 Source Water Protection Plan

18 The Tribe is currently developing a Source Water Protection Plan (SWPP) to

19 ensure the safe supply of drinking water and protect these water resources.

20 Once the SWPP is complete, strategies will be developed for protecting the

21 Tribe's drinking water, planning for the future, and contingency planning. (PIIC

22 2008)

23 Higgins Eye Mussel Restoration Project

24 The Tribe has also been collaborating with the Minnesota Department of Natural

25 Resources (MNDNR), the U.S. Fish and Wildlife Service (FWS), and the U.S.

26 Army Corp. of Engineers (USACE) to restore the Higgins eye pearly mussel

27 (Lampsilius higginsii), which has been on the endangered species list since

28 1976. The Higgins pearly mussel aids water quality and is a food source for

29 muskrats and otters (an important traditional species for tribal members), whose

30 numbers have also declined in the last several decades. (PIIC 2008)

31 The MNDNR, FWS, and USACE are taking mussels from Lake Pepin, below

32 Lock and Dam No. 3, where conditions are unfavorable due to the zebra mussel,

33 and relocating them to Sturgeon Lake, adjacent to the tribe's land and within Pool

34 3 of Lock and Dam No. 3, where conditions are now more favorable for the

35 mussel. (PIIC 2008)

36 Habitat Assessment through Breeding Bird Surveys

37 The tribe conducted an existing habitat assessment by conducting a breeding

38 bird survey. In general, excellent habitat will have many species of birds, while

39 poor and degraded habitat will have fewer species. The field work for this project

40 was completed in June and July 2008 and May and June of 2009. In 2008, 72

41 long-term sampling sites were established in all areas of the reservation. Sixty42 nine bird species were surveyed during 2008. The same sample sites were

43 visited in 2009 and 75 bird species were surveyed. Several species of

44 conservation concern for MN were surveyed in both years, including the Bald

45 eagle, Dickcissel, Prothonotary Warbler, Cerulean Warbler, Wood Thrush, and

46 the Willow Flycatcher. The diversity of habitats on tribal lands-prairies,

October 2009 2-53 Draft NUREG-1437, Supplement 39
Affected Environment

1 meadows, wetlands, and riparian forests-are important to many of these

2 breeding species. The Tribe's current and future management activities include

3 efforts to maintain and enhance existing breeding habitats for birds. (PIIC 2008)

4 Invasive Plant Inventory and Native Plant Community Assessment

5 Because of concerns about invasive plants taking over native plant habitat, the

6 Tribe conducted a plant inventory on reservation lands in 2008. Fortunately,

7 many areas still consist of healthy natural habitats and a total of 460 vascular

8 plant species were documented. The project also identified 22 invasive plant

9 species on tribal lands. Buckthorn is the most prevalent invasive species in

10 Reservation woodland areas; it was originally planted as a hedgerow tree and it

11 spread quickly. Purple loosestrife was the most prevalent invasive species in

12 wetland areas, especially near the Mississippi River. An extensive database and

13 vegetation maps were created for this project to assist the Tribe has in managing

14 lands in the future. The tribe has also begun the removal of buckthorn and

15 purple loosestrife in some areas. (PIIC 2008)

16 Medicinal and Culturally Important Plants

17 The Tribe is currently conducting a project to assess the presence of medicinal

18 and culturally important plant species on tribal lands. Surveys were conducted in

19 the summer of 2008 and are continuing during the spring/summer of 2009. As

20 part of the study, the tribe has collected voucher specimens for a permanent

21 herbarium. Thus far, 72 of the 180 potential cultural/medicinal plant species

22 historically present on Prairie Island have been found. The medicinal plant

23 survey will help the Tribe manage lands and restore areas with plant species that

24 are currently not present. (PIIC 2008)

25 Forest Inventory

26 The Bureau of Indian Affairs (BIA), Midwest Region, is conducting a forest

27 inventory of Tribal lands which will include a delineation of forest cover types,

28 such as open prairie, forested wetlands, shrub swamps, and other palustrine

29 wetland types. The BIA began the inventory in the fall of 2008 and will complete

30 the project in 2009. The inventory will be beneficial, as the data from the

31 inventory will help establish habitat enhancement targets. (PIIC 2008)

32 Draw-down Study of Pool 3 (Sturgeon Lake)

33 The Prairie Island Indian Community is working with the USACE (St. Paul

34 District) on various aspects of a proposed water level management plan aimed at

35 modifying river regulation in Pool 3 to improve habitat conditions. This

36 ecosystem restoration project would target goals to improve water quality,

37 emergent and submersed aquatic plants, and fish and wildlife. (PIIC 2008)

38 Agricultural Leases

39 The tribe annually leases 726 ac (290 ha) to tribal members for agricultural

40 production. Typically corn and soybeans are planted. (PIIC 2008)

41 2.2.8.5 Visual Aesthetics and Noise

42 PINGP 1 and 2 are located on an island on the west side of the Mississippi River. Both units

43 can be-seen from the river, but are partly shielded by surrounding vegetation. The turbine

44 building and reactor containment structures dominate the landscape of the site.

Draft NUREG-1437, Supplement 39 2-54 October 2009
Affected Environment

1 With mechanical draft cooling towers, the most obvious aesthetic impact is the visible steam

2 plume in the sky. The plumes are more persistent under certain meteorological conditions when

3 the capacity for the atmosphere to hold additional water vapor is lowest. This occurs when

4 relative humidity is high and/or air temperatures are low. Plume rise is less with a mechanical5 draft tower than it is for a natural-draft tower, and plumes can rise to heights between 200 and

6 500 ft (60 to 150 m) before evaporating completely. (AEC 1973)

7 Noise from nuclear plant operations can be detected offsite. Sources of noise from PINGP 1

8 and 2 operations include the mechanical-draft cooling towers, turbines, large pumps, and

9 cooling water system motors. Given the industrial nature of the station, noise emissions from

10 the station are generally nothing more than an intermittent minor nuisance. However, noise

11 levels may sometimes exceed the 55 dBA level that the EPA uses as a threshold level to protect

12 against excess noise during outdoor activities (EPA 1974). However, according to the EPA this

13 threshold does "not constitute a standard, specification, or regulation," but was intended to

14 provide a basis for state and local governments establishing noise standards.

15 2.2.8.6 Demography

16 According to the 2000 Census, approximately 107,131 people lived within 20 mi (32 kin) of

17 PINGP 1 and 2, which equates to a population density of 85 persons per square mile (mi 2)

18 (NMC 2008). This density translates to the less sparse generic environmental impact statement

19 (GELS) Category 3 (60 to 120 persons/mi 2 or less than 60 persons/mi 2 with at least one

20 community with 25,000 or more persons within 20 mi [32 km]). Approximately 2,733,326 people

21 live within 50 mi (80 km) of PINGP 1 and 2 (NMC 2008). This equates to a population density of

22 349 persons/mi 2. Applying the GElS proximity measures, this density is classified as proximity

23 Category 4 (greater than or equal to 190 persons/mi2 within 50 mi [80 km]). Therefore,

24 according to the sparseness and proximity matrix presented in the GELS, the rankings of

25 sparseness Category 3 and proximity Category 4 result in the conclusion that PINGP 1 and 2

26 are located in a high population area.

27 Table 2.17 shows population projections and growth rates from 1970 to 2050 in Goodhue

28 County and Dakota County, Minnesota, and Pierce County, Wisconsin. The growth rate in

29 Goodhue County showed an increase of 8.4 percent for the period of 1990 to 2000. County

30 populations are expected to continue to grow in all three counties in the next decades although

31 Dakota County's population is expected to increase at a higher rate than the others through

32 2050.

33 Table 2-17. Population and Percent Growth in Goodhue County and Dakota

34 County, Minnesota, and Pierce County, Wisconsin, from 1970 to 2000 and

35 Projected for 2006 to 2050

Goodhue, MN Dakota, MN Pierce, Wl

Percent Percent

Year Population Growth(a) Population Growth(a) Population Percent Growth(a)

1970 34,763 - 139,808 - 26,652 -

1980 38,749 11.5 194,279 39.0 31,149 16.9

1990 40,690 5.0 275,227 41.7 32,765 5.1

2000 4,127 8.4 355,904 29.3 6,804 12.3

2007 5,539 3.2 385,971 8.4 9,296 6.8

October 2009 2-55 Draft NUREG-1437, Supplement 39
Affected Environment

2010 47,140 6.8 422,990 18.8 39,818 8.2

2020 50,430 7.0 470,460 11.2 42,655 7.1

2030 52,890 4.9 501,020 6.5 45,850 7.5

2040 55,873 5.6 595,611 18.9 49,640 8.3

2050 58,798 5.2 659,939 10.8 52,919 6.6

- No data available.

( Percent growth rate is calculated over the previous decade.

Sources: MSCD 2002; USCB 2008; WDSC 2004

1 Demographic Profile

2 The 2000 and 2006 (estimated) demographic profiles of the three-county region of influence

3 (ROI) population is presented in Table 2.18 and Table 2.19. According to the 2000 Census,

4 minorities (race and ethnicity combined) comprised 8.8 percent of the total three-county

5 population. The minority population is composed largely of Hispanic or Latino and Asian

6 residents.

7 According to the most recent U.S. Census Bureau's 2005-2007 American Community Survey

8 3-Year Estimates, minority populations in the three-county region were estimated to have

9 increased by nearly 19,700 persons and comprised 12.3 percent of the total three-county

10 population (see Table 2.19). The largest increases in minority populations were estimated to

11 occur in Black or African American populations. The Hispanic or Latino and Asian populations

12 were both estimated to have increased by approximately 54 percent, and have also increased

13 slightly as a percentage of the total three-county population.

14 Prairie Island Indian Community

15 Currently, the PIIC has 801 enrolled members; approximately 250 members reside on tribal

16 land. The PIIC is growing at an approximate rate of 30 new members per year (based on birth

17 rates for the past several years). It is expected that the PIIC will grow by 600 members over the

18 20-year PINGP 1 and 2 renewed license period. (PIIC 2009)

19

20 Table 2-18. Demographic Profile of the Population in the PINGP I and 2 Three21 County Socioeconomic Region of Influence in 2000

Goodhue, Dakota, Pierce, Region of

MN MN WI Influence

Total Population 44,127 355,904 36,804 436,835

Race (percent of total population, Not-Hispanic or Latino)

White 96.1 90.0 97.5 91.2

Black or African American 0.6 2.2 0.2 1.9

American Indian and Alaska Native 0.9 0.3 0.3 0.4

Asian 0.6 2.9 0.4 2.4

Native Hawaiian and Other Pacific Islander 0.0 0.0 0.0 0.0

Some other race 0.1 0.1 0.1 0.1

Draft NUREG-1437, Supplement 39 2-56 October 2009
Affected Environment

1

2

Two or more races 0.6 1.5 0.6 1.3

Ethnicity

Hispanic or Latino 473 10,459 301 11,233

Percent of total population 1.1 2.9 0.8 2.6

Minority Populations (including Hispanic or Latino ethnicity)

Total minority population 1,722 35,662 908 38,292

Percent minority 3.9 10.0 2.5 8.8

Source: USCB 2008b

Table 2-19. Demographic Profile of the Population in the PINGP 1 and 2 ThreeCounty Socioeconomic Region of Influence in 2005-2007, 3-Year Estimate

Goodhue, Dakota, Pierce, Region of

MN MN WI Influence

Total Population 45,539 385,971 36,804 470,806

Race (percent of total population, Not-Hispanic or Latino)

White 95.0 85.9 96.7 87.7

Black or African American 1.0 3.9 0.1 3.3

American Indian and Alaska Native 0.9 0.4 0.4 0.5

Asian 0.8 4.0 1.5 3.5

Native Hawaiian and Other Pacific Islander 0.2 0.0 0.0 0.1

Some other race 0.1 0.2 0.0 0.2

Two or more races 0.4 1.4 0.3 1.2

Ethnicity

Hispanic or Latino 768 16,147 379 17,294

Percent of total population 1.7 4.2 1.0 3.7

Minority Populations (including Hispanic or Latino ethnicity)

Total minority population 2,274 54,392 1,292 57,958

Percent minority 5.0 14.1 3.3 12.3

Source: USCB 2008b

Transient Population

Within 50 mi (80 km) of PINGP 1 and 2, colleges and recreational opportunities attract daily and

seasonal visitors who create demand for temporary housing and services. In 2007,

approximately 187,000 students attended colleges and universities within 50 mi (80 km) of

PINGP 1 and 2 (IES 2008).

In 2000, 1.8 percent of all Goodhue County housing units were considered temporary housing

for seasonal, recreational, or occasional use. By comparison, seasonal housing accounted for

0.3 percent and 5.1 percent of total housing units in Dakota County and Minnesota, respectively

3

4

5

6

7

8

9

10

October 2009 2-57 Draft NUREG-1437, Supplement 39
Affected Environment

1 (USCB 2008a). Seasonal housing accounted for 1.3 percent and 6.1 percent of total housing

2 units in Pierce County and Wisconsin, respectively (USCB 2008). Table 2.20 provides

3 information on seasonal housing for the 25 counties located all or partly within 50 mi (80 km) of

4 PINGP 1 and 2.

5 The Treasure Island Resort and Casino, located on Prairie Island, may have as many as 16,000

6 guests at any given time. The hotel also has 480 sleeping rooms (with an approximate 90

7 percent occupancy rate); an RV park (95 pads), and a marina (137 permanent and daily slips

8 are typically full during the summer months). During the PIIC's annual Pow-Wow in July, an

9 additional 500 to 2000 visitors may be in and around the Pow-Wow grounds. The reservation

10 does not have any rental housing units or campgrounds. (PIIC 2008).

11 Table 2-20. Seasonal Housing in Counties Located within 50 mi (80 km) of PINGP

12 1 and 2

Vacant housing units: For

seasonal, recreational, or

County(a) Housing units occasional use Percent

Minnesota 2,065,946 105,609 5.1

Anoka 108,091 300 0.3

Carver 24,883 124 0.5

Chisago 15,533 679 4.4

Dakota 133,750 381 0.3

Dodge 6,642 18 0.3

Goodhue 17,879 314 1.8

Hennepin 468,824 2,491 0.5

Le Sueur 10,858 973 9.0

Olmsted 49,422 226 0.5

Ramsey 206,448 808 0.4

Rice 20,061 628 3.1

Scott 31,609 150 0.5

Steele 13,306 103 0.8

Wabasha 9,066 239 2.6

Waseca 7,427 79 1.1

Washington 73,635 604 0.8

Winona 19,551 163 0.8

County Subtotal 1,216,985 8,280 1.6 (avg.)

Wisconsin 2,321,144 142,313 6.1

Barron 20,969 2,299 11.0

Buffalo 6,098 247 4.1

Dunn 15,277 285 1.9

Eau Claire 37,474 375 1.0

Pepin 3,036 134 4.4

Pierce 13,493 182 1.3

Polk 21,129 4,211 19.9

St. Croix 24,265 281 1.2

County Subtotal 141,741 8,014 5.6 (avg.)

County Total 1,358,726 16,294 2.9 (avg.)

Source: USCB 2008

(a)Counties within 50 mi (80 km) of PINGP 1 and 2 with at least one block group located within

the 50-mi (80 kin) radius

avg..= percent average for counties within the PINGP 1 and 2 50-mi (80 km) radius and

excludes state percentage

Draft NUREG-1437, Supplement 39 2-58 October 2009
Affected Environment

1 Migrant Farm Workers

2 Migrant farm workers are individuals whose employment requires travel to harvest agricultural

3 crops. These workers may or may not have a permanent residence. Some migrant workers

4 follow the harvesting of crops, particularly fruit, throughout the rural U.S. Others may be

5 permanent residents near PINGP 1 and 2 who travel from farm to farm to harvest crops.

6 Migrant workers may be members of minority or low-income populations. Because they travel

7 and can spend a significant amount of time in an area without being actual residents, migrant

8 workers may be unavailable for counting by census takers. If uncounted, these workers would

9 be "underrepresented" in USCB minority and low-income population counts.

10 Information on migrant farm and temporary labor was collected in the 2007 Census of

11 Agriculture. Table 2.21 provides information on migrant farm workers and temporary farm labor

12 (less than 150 days) within 50 mi (80 km) of PINGP 1 and 2. According to the 2007 Census of

13 Agriculture, approximately 15,700 farm workers were hired to work for less than 150 days and

14 were employed on 4,800 farms within 50 mi (80 km) of PINGP 1 and 2. The county with the

15 largest number of temporary farm workers (1,025 workers on 150 farms) was Washington

16 County, Minnesota.

17 In the 2002 Census of Agriculture, farm operators were asked for the first time whether any

18 hired migrant workers, defined as a farm worker whose employment required travel that

19 prevented the migrant worker from returning to their permanent place of residence the same

20 day. A total of 237 farms in the 50-mi (80-km) radius of PINGP 1 and 2 reported hiring migrant

21 workers. Dakota County, Minnesota reported the most farms (28) with hired migrant workers,

22 followed by Winona County and Goodhue County in Minnesota with 22 and 18 farms,

23 respectively.

24 According to 2007 Census of Agriculture estimates, 970 temporary farm laborers were

25 employed on 338 farms in Goodhue County, and 1,012 temporary farm workers were employed

26 on 218 farms in Dakota County (USDA 2007a). Pierce County, Wisconsin, had 720 temporary

27 farm workers employed on 298 farms (USDA 2007b).

28 Table 2-21. Migrant Farm Worker and Temporary Farm Labor in Counties Located

29 within 50 mi (80 km) of PINGP 1 and 2

Number of farm Number of farms

workers working hiring workers Number of farms Number of farms

for less than 150 for less than 150 reporting migrant with hired farm

Count(a) days days farm labor labor

Minnesota 19,337 16,085 54,851 1,186

Anoka 94 77 451 7

Carver 220 177 548 15

Chisago 179 160 612 4

Dakota 270 218 1,012 28

Dodge 207 172 547 9

Goodhue 433 338 970 18

Hennepin 154 110 696 6

Le Sueur 226 194 512 2

October 2009 2-59 Draft NUREG-1437, Supplement 39
Affected Environment

County(a)

Olmsted

Ramsey

Rice

Scott

Steele

Wabasha

Waseca

Washington

Winona

Minnesota

Counties Subtotal

Wisconsin

Barron

Buffalo

Dunn

Eau Claire

Pepin

Pierce

Polk

St. Croix

Wisconsin

Counties Subtotal

All Counties Total

Number of farm

workers working

for less than 150

days

300

13

264

182

208

270

198

179

341

3,738

Number of farms

hiring workers

for less than 150

days

250

12

224

143

167

207

151

150

255

3,005

Number of farms

reporting migrant

farm labor

837

66

671

496

552

695

532

1,025

795

11,017

Number of farms

with hired farm

labor

11

0

2

6

7

6

7

11

22

161

17,889

354

274

304

254

121

358

277

355

2,297

13,169

251

197

219

193

86

298

219

290

1,753

45,921

726

455

714

506

196

720

594

793

4,704

636

9

11

18

8

2

7

4

17

76

(a)Counties within 50 n

Sources: USDA 2007a

6,035 4,758 15,721 237

ni (80 km) radius of PINGP 1 and 2 with at least one block group

a; USDA 2007b

1

2

3

4

5

6

7

8

9

2.2.8.7 Economy

This section contains a discussion of the economy, including employment and income,

unemployment, and taxes.

Employment and Income

Between 2000 and 2007, the civilian labor force in Goodhue County increased 6.6 percent from

24,100 to 25,692 individuals. During the same time period, the civilian labor force in Dakota

County and Pierce County grew by 9.6 and 10.3 percent, respectively. (USCB 2008a)

In 2007, educational services, health care and social assistance represented the largest sector

of employment in the three-county region followed by manufacturing and retail trade industry.

Draft NUREG-1437, Supplement 39 2-60 October 2009
Affected Environment

1

2

3

4

5

The educational services, health care and social assistance sector employed the most people in

Goodhue County followed by manufacturing and retail trade sectors. A list of some of the major

employers in Goodhue County is provided in Table 2.22. As shown in the table, the largest

employer in Goodhue County is the Treasure Island Resort and Casino.

Table 2-22. Major Employers in Goodhue County

Firm or Company

Treasure Island Casino

Red Wing Shoe Co.

Xcel Energy

Fairview Red Wing Medical Center

Independent School District #256

Norwood Promotional Products

SB Foot Tanning Co.

Express Services

Cannon Falls Public Schools-ISD#252

DB Industries, Inc.

Dairy Farmers of America

Bergquist Co.

Foldcraft-Plymold Co.

Gemini Inc.

DS Manufacturing Inc.

Midwest of Cannon Falls Inc.

Cannon Equipment Co.

Zumbrota-Mazeppa Public Schools

Pine Haven Care Center

Number of Employees

1500,5,

724

61 1(a,

585

500

380

260

236

230

225

220

200

200

184

170

164

161

160

150

6

7

8

9

10

11

12

13

14

15

16

(a) The ER (NMC 2008) reports the Treasure Island Casino to have 1600 employees and Xcel Energy to

have 685 employees

Source: MDEED 2009

Estimated income information for the PINGP 1 and 2 ROI is presented in Table 2.23. According

to the USCB 2005-2007 American Community Survey 3-Year Estimates (USCB 2007a), median

household income in Dakota and Pierce Counties were each above their respective state

median household income averages. Conversely, with the exception of Dakota County, per

capita income in Goodhue County and Pierce County were both below their respective state

averages. In Goodhue and Dakota Counties, an estimated 7.9 and 5.3 percent of the

population was living below the official poverty level, respectively, while the percentage for the

State of Minnesota as a whole was 9.6 percent. In Pierce County, an estimated 6.9 percent of

the population was living below the official poverty level, while the percentage for the State of

Wisconsin as a whole was 10.8 percent. The percentage of the population by family living

October 2009 2-61 Draft NUREG-1437, Supplement 39
Affected Environment

1 below the poverty level was lower in all three counties than their respective state-wide

2 estimates. The percentage of families living below the poverty level in Goodhue County (5.7

3 percent) was lower than the percentage of families in the State of Minnesota as a whole (6.3

4 percent). Dakota County had a much smaller percentage of families (3.8 percent) living below

5 the poverty level. In Pierce County, an estimated 2.3 percent of the families were living below

6 the official poverty level, while the percentage for the State of Wisconsin as a whole was 7.1

7 percent. (USCB 2007a)

8 Table 2-23. 2005-2007 Estimated Income for the PINGP I and 2 Region of

9 Influence

Goodhue Dakota Minnesota Pierce Wisconsin

Median household income (dollars) 55,098 72,393 55,616 58,011 50,309

Per capita income (dollars) 26,187 33,284 28,536 25,327 25,742

Families living below the poverty

level (percentage) 5.7 3.8 6.3 2.3 7.1

Individuals living below the poverty

level (percentage) 7.9 5.3 9.6 6.9 10.8

Source: USCB 2007a

10 Unemployment

11 According to the U.S. Census Bureau's 2005-2007 American Community Survey 3-Year

12 Estimates (USCB 2007a), the annual unemployment average in Goodhue and Dakota Counties

13 was 5.6 and 5.1 percent, respectively, which were slightly higher and lower than the annual

14 unemployment average of 5.4 percent for the State of Minnesota, respectively. The annual

15 unemployment average in Pierce County, Wisconsin was 5.4 percent, which was lower than the

16 annual unemployment average of 5.8 percent for the state of Wisconsin (USCB 2007a).

17 Taxes

18 In Minnesota, public utilities are valued using cost and income approaches. Jurisdictional

19 budgets are developed and taxes are levied to meet those budgets. Historically, annual

20 property taxes have been gradually decreasing due to depreciation and the growth in

21 Minnesota's residential and commercial tax bases. Additionally, state lawmakers have been

22 conducting hearings for a rule change that could affect the way commercial businesses

23 depreciate their facilities. Currently, NSP is unable to fully depreciate PINGP 1 and 2. Should

24 the rule change, NSP may be able to increase the depreciation on PINGP 1 and 2 to further

25 reduce the plant's value and tax payments. However, NSP plans to implement some

26 refurbishment activities at PINGP 1 and 2 (see Chapter 3) that could increase the plant's

27 assessed value, resulting in an increase in the amount of money NSP pays in property taxes.

28 As stated in NSP's ER (NMC 2008):

29 The Minnesota Department of Revenue (DOR) is in the process of possibly

30 revising its current utility company valuation rule. According to a fiscal impact

31 study prepared by the DOR and based on the latest draft of the revised rule, the

32 amount of property tax revenue received by the city of Red Wing and Goodhue

33 County would decrease by approximately $1.4 million and $1.2 million annually,

34 respectively. In order to stabilize these communities for their anticipated loss of

35 property tax revenue from NSP due to a rule change, NSP executed revenue

36 stabilization agreements with Red Wing and Goodhue County representatives in

37 November 2006 (City of Red Wing, Minnesota and NSP 2006). NSP is also

38 assessed the State General Tax, however, it will not be analyzed here because

Draft NUREG-1437, Supplement 39 2-62 October 2009
Affected Environment

1 the state's revenues are very large and NSP's payments represent an extremely

2 small percentage of those revenues. Nuclear fuel is not taxed in the State of

3 Minnesota and therefore is not included in the site's property tax assessment.

4 Property taxes are paid directly to Goodhue County, which in turn distributes the

5 money to the aforementioned taxing jurisdictions. Property taxes are the chief

6 source of revenue for Minnesota counties, generally providing between 30 and

7 50 percent of their revenues (AMC 2002).

8 From 2001 through 2005, Goodhue County collected between $20.6 and $22.3

9 million annually in property tax revenues Table 2.24. Goodhue County property

10 tax revenues fund, among other things, county operations, public safety, public

11 works, cultural and recreational programs, human services, health services,

12 roadway maintenance, economic development, and conservation programs

13 (Hove 2006). Table 2.24 details the property tax payments made by the owners

14 of PINGP for the same years. From 2001 to 2005, PINGP property tax payments

15 represented 16.6 to 27.5 percent of Goodhue County's total property tax

16 revenues.

17 From 2001 through 2006, the City of Red Wing collected between $8.9 and $11.6

18 million annually in property tax revenues Table 2.24. The City of Red Wing's

19 property tax revenues fund city operations. Table 2.24 details the property tax

20 payments made by the owners of PINGP for the same years. From 2001 to 2006,

21 NSP property tax payments represented 52.3 to 36.4 percent of the City of Red

22 Wing's total property tax revenues. Due to small PINGP payment decreases and

23 increases in the City's total revenues collected, NSP's payment percentages are

24 trending downward.

25 From 2002 through 2006, the School District 256 collected between $6.5 and

26 $6.9 million annually in property tax revenues Table 2.24. From 2002 to 2006,

27 PINGP property tax payments represented 28.5 to 38.0 percent of the School

28 District 256's total property tax revenues. Prior to 2002, PINGP tax payments to

29 School District 256 were significantly larger because the state-determined local

30 school tax was included in School District 256 payments prior to year 2002. The

31 2001 Tax Law provided for major changes in the source of school funding in

32 Minnesota and replaced the state-determined local school tax with the State

33 General Tax, a statewide property tax levied for taxes payable on commercial,

34 industrial and seasonal properties. Taxes under the State General Tax are paid

35 into the State General Fund and redistributed by a state-determined formula to

36 school districts state-wide, in part, based on student numbers. The State General

37 Tax is levied at a uniform rate within each county, and the levy rate is determined

38 by the Commissioner of Revenue (Fredrikson & Byron 2001).

October 2009 2-63 Draft NUREG-1437, Supplement 39
Affected Environment

1

2

Table 2-24. PINGP 1 and 2 Property Tax Paid and Percentage of Goodhue County,

City of Red Wing, and School District 256 Tax Revenues, 2001 to 2006

Entity

Goodhue County

City of Red Wing

Year

2001

2002

2003

2004

2005

2006

2001

2002

2003

2004

2005

2006

2001

2002

2003

2004

2005

2006

Total Revenue

(millions of dollars)

21.0

20.6

21.1

21.7

22.3

22.4

8.9

10.9

11.4

11.5

10.9

11.6

14.8

6.5

5.7

6.9

6.7

6.9

Property Tax

Paid by NSP

(millions of dollars)

5.8

4.6

4.4

4.0

3.7

3.7

4.7

4.8

4.8

4.5

4.0

4.3

6.6

2.5

2.0

2.1

1.8

2.0

Percent of

Total Revenue

27.6

22.3

20.9

18.4

16.6

16.5

52.8

44.0

42.1

39.1

36.7

37.1

44.6

38.5

35.1

30.4

26.9

29.0

School District 256

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

Source: NMC 2008; OSA 2007

In 2003, the PIIC entered into a Settlement Agreement with NSP, which includes certain

provisions that relate to the PIIC's long-standing health and safety concerns about PINGP 1 and

2. (Minn. Stat. § 216B.1645, Subd. 4; Laws 2003, First Special Session Chapter 11.) This

agreement was approved by the Minnesota Public Utilities Commission (MN PUC) and the

Minnesota Legislative. Through the Agreement, funds are allocated to the PIIC to address a

variety of issues: health concerns, emergency management, land acquisition, construction of

community infrastructure, or other community purposes. The Agreement is in place as long as

PINGP 1 and 2 is operational and the ISFSI continues to be used for dry cask storage, although

certain provisions of the Agreement end when the current operating licenses expire. (PIIC

2008).

NSP also provided $25,000 to the PIIC to fund a preliminary engineering study or other activities

to help facilitate the construction of an overpass over the railroad lines which cross Sturgeon

Lake Road, which is the only exit from the reservation (PIIC 2008).

Similar to the support it provides to Goodhue County and the State of Minnesota, NSP also

provides the PIIC with up to $17,000 annually to reimburse the Community for radiological

emergency preparedness (REP) activities, such as training, travel to meetings, and supplies

(PIIC 2008; 2009).

Draft NUREG-1437, Supplement 39 2-64 October 2009
Affected Environment

1 2.2.9 Historic and Archaeological Resources

2 This section discusses the cultural background and the known historic and archaeological

3 resources at the site of PINGP 1 and 2 and in the surrounding area.

4 2.2.9.1 Cultural Background

5 The region around PINGP 1 and 2 contains prehistoric and historic Native American and Euro6 American cultural resources. Sixty properties in Goodhue County are listed in the National

7 Register of Historic Places (NRHP) (NPS 2009). Of these, 35 properties are located in Red

8 Wing within 6 mi (9.7 km) of PINGP 1 and 2. The nearest property, the Bartron Village site, is

9 partially located on the PINGP 1 and 2 site. Nine properties are located across the Mississippi

10 River in Pierce County, Wisconsin. Two of these properties are within 6 mi (9.7 km) of PINGP 1

11 and 2.

12 The land around Prairie Island is composed of limestone cliffs and various river drainages, and

13 is bounded by the Cannon and Trimbelle River Bluffs (Dobbs 1988; Schirmer 2002). Prairie

14 Island was formed from the deposition of enriched silt resulting from glacial melt and periodic

15 flooding from the Mississippi and other river drainages (Gibbon 1979). The USACE Lock and

16 Dam No. 3, constructed in the 1930s, created Sturgeon Lake and flooded portions of the island,

17 obscuring the original shoreline. The landscape within the PINGP 1 and 2 site boundary is

18 mostly level with some wooded and swampy areas. The majority of the land is open grassland.

19 Prehistoric Periods

20 Paleo-Indians migrated into Southern Minnesota approximately 10,000 to 12,000 years ago

21 when the glaciers receded and the forests and prairies reappeared (Scullin 1996). Paleo-Indian

22 populations were highly mobile and left little evidence of their activities. Most Paleo-lndian sites

23 would have been short-term occupations (campsites). Paleo-lndian people subsisted on hunted

24 game and gathered plant material. The early Paleo-lndian period dates from 9550 B.C. to

25 8050 B.C. and includes the Clovis and Folsom cultures (Hildebrandt 2008). The primary artifact

26 associated with the Paleo-Indian period is the Clovis point: a distinctive, fluted, lanceolate point.

27 To date, no intact Clovis or Folsom sites have been identified within Minnesota; however spear

28 points have been found. The late Paleo-lndian period dates from 8050 B.C. to 6050 B.C.

29 During the Archaic Period, from approximately 6050 B.C. to 1050 B.C., subsistence hunting and

30 gathering underwent changes to adapt to resource availability. As glaciers retreated northward

31 and larger animals disappeared from the region, humans adapted to modern plants and smaller

32 game animals. Very few intact Archaic period sites have been found in Minnesota. Most

33 information comes from surface finds and private artifact collections. Rapid climate changes

34 and subsequent flooding may have buried or disturbed many Archaic sites. Archaic people did

35 not appear to establish permanent settlements, though there is evidence that some areas were

36 utilized frequently. Archaic people collected, hunted, and gathered most of what they needed

37 for survival in their home territory. There are no known Archaic sites within Goodhue County

38 (Dobbs 1988).

39 The Woodland culture existed from 1050 B.C. until European contact around 1600 A.D. This

40 period is defined by the introduction of horticulture to augment subsistence hunting and

41 gathering. A reliance on agriculture led to the establishment of more permanent settlements

42 during this period. In Minnesota, Woodland culture is also defined by the production of pottery

43 and earthen mound construction. Other characteristics of Woodland culture include increased

44 population, emergence of social hierarchy, expanded interregional trade, and the introduction of

45 the bow and arrow. Woodland peoples exchanged ideas and technologies with other locations

46 in the Midwest. This period is typically divided into Early, Middle, and Late Woodland periods

47 (Dobbs 1988). Changes in climate during this period caused changes in Woodland culture.

October 2009 2-65 Draft NUREG-1437, Supplement 39
Affected Environment

1 Very few Early Woodland cultural sites have been found in Minnesota and most are located in

2 the southeastern portion of the state where the deciduous forest dominates the landscape.

3 Early Woodland settlements were small and seasonally occupied. Sites from this period are

4 difficult to locate and may be deeply buried.

5 In contrast, the Middle Woodland period is defined by more elaborate ritual and mortuary

6 activities and increased trade. Mounds built during this time are larger than those found later in

7 the Woodland period and include linear mounds, log crypts, and multiple burials (Hildebrandt

8 2008). Communities that lived in and around the Ohio and Mississippi valleys, including Prairie

9 Island, acquired a wide range of exotic goods and raw materials from all over North America.

10 Middle Woodland communities were linked by a network archaeologists refer to as the Hopewell

11 Interaction Sphere involving the dissemination of ideas about social organization, technology,

12 and long distance trade from various centers of Hopewell culture.

13 Late Woodland cultures are poorly understood in Minnesota. Many Late Woodland sites are

14 located on floodplains where site preservation is compromised by flooding and erosion.

15 Additionally, pottery types found in the area have not been well defined in Minnesota.

16 Population densities in the Late Woodland were low and the peoples lived as hunters and

17 gatherers (Dobbs 1988). Typical sites include mound groups (conical or effigy mounds ranging

18 from two to fifteen mounds), short-term seasonal occupations, seasonal villages, rock shelters

19 and caves, and shell middens (archeological feature comprised mainly of mollusk shells).

20 Two major cultural phases that follow the Late Woodland period are the Oneota and Middle

21 Mississippian cultures. Current research is unable to clearly define the level of interactions

22 between the Late Woodland, Oneota, and Middle Mississippian cultures in Minnesota. The

23 period of most concentrated use of the Red Wing area, which includes Prairie Island, was the

24 Silvernale Phase that is associated with the Mississippian culture (A.D. 1000 to 1300). The

25 Silvernale Phase is distinguished by the presence of local and non-local pottery styles and

26 decorations. Silvernale Phase artifacts are only found in the Red Wing area, unlike the Oneota

27 artifact assemblages which are found throughout the Midwest (Gibbon and Dobbs 1991). There

28 are at least seven major village sites in the Red Wing area.

29 One example is the Bartron Village site (21GD02). The Bartron Village site has yielded Middle

30 Mississippian, Oneota, and Late Woodland artifacts. This evidence suggests discrete

31 "neighborhood" along "cultural" lines (Gibbon 1979; Dobbs 1988; Gibbon and Dobbs 1991;

32 Schirmer 2002:54, 57). The Bartron Village site has characteristics common to other Middle

33 Mississippian occupations located throughout the Midwest. This multi-component site (from

34 A.D. 1050 to 1300) is important for understanding the cultural evolutionary and settlement

35 patterns at Prairie Island. Oneota peoples can be traced through the years to ancestral

36 Chiwere, and Dakota and Dheigiha Sioux-speaking peoples (Hildebrandt 2008).

37 Oneota and Silvernale villages typically have associated mound groups. These mound groups

38 are numerous and are usually conical and/or linear (ellipsoid) shaped. Oneota and Middle

39 Mississippian habitation sites include semi-permanent (seasonal) Oneota or Silvernale villages,

40 (possibly fortified) permanent Silvernale villages, outlying Silvernale-related farmsteads, garden

41 plots, quarry sites, and sites associated with elite architecture and trade activities (Dobbs 1988).

42 During both prehistoric and historic (European contact) periods, the Mississippi River and its

43 tributaries played an important role in the settlement and history of the region. The Mississippi

44 River was the major means of transportation of people and goods resulting in a high density of

45 prehistoric and historic sites along the Red Wing and Prairie Island areas (NMC 2008). There

46 are hundreds of habitation sites in Goodhue and Pierce Counties, however, very few sites have

47 been tested or professionally excavated.

Draft NUREG-1437, Supplement 39 2-66 October 2009
Affected Environment

1 Historic Period

2 During the 17th century, the two major tribes within Minnesota were the Dakota (Sioux) and the

3 Ojibwe (Chippewa) (Willis 1914). Father Louis Hennepin was the first European to explore the

4 Upper Mississippi River region. In 1680, he was captured near Milles Lacs by a Dakota war

5 party and later discovered Lake Pepin and St. Anthony Falls while in captivity (Willis 1910).

6 In 1685, another Frenchman Nicholas Perrot established a trading post at Trempealau on the

7 east bank of the Mississippi River, and Fort Saint-Antoine on Lake Pepin (Kneisler 1999).

8 Frenchman, Pierre Charles Le Seuer, explored the region at the confluence of the Mississippi

9 and Minnesota rivers, where Fort Snelling was later established. Le Seuer built a trading post

10 on Prairie Island around 1695 (AEC 1973).

11 Evidence indicates that Le Sueur wintered on the southern end of Prairie Island from 1694 to

12 1695; however, this encampment has never been found (Hildebrandt 2008). Historic Dakota

13 encampments and trading posts were also reported to exist on Prairie Island though none have

14 been found (Hildebrandt 2008).

15 Around 1727, the French built Fort Beauharnois on the Mississippi River which facilitated the

16 trade of furs with the Dakota people (MNDNR 2008). A chapel built at Fort Beauharnois, named

17 the Mission of St. Michael the Archangel, is purported to be the first church in Minnesota. In

18 1763, the Treaty of Paris ended the French and Indian War (MNDNR 2008). As a result, Fort

19 Beauharnois and the Frontenac settlement were abandoned. Subsequently, most of France's

20 land holdings within the New World were divided between Spain and England.

21 Fort Snelling was built between 1819 and 1825 by the U.S. Army (MHS 2009). Fort Snelling

22 was an important outpost that provided a meeting place for the U.S. government officials and

23 representatives of the Dakota and Objibwe nations. The American and Columbia fur companies

24 also constructed headquarters in this area, and the families of these employees settled at

25 nearby Mendota. European immigrants and settlers from the East Coast established a

26 settlement that later became St. Paul City (MHS 2009). Europeans settled on the west bank of

27 the Mississippi River as a result of a treaty signed at Mendota in 1851. In 1857, Red Wing was

28 incorporated as a city. A year later, in 1858, the territory of Minnesota became the 32nd state

29 (City of Red Wing 2003).

30 According to a tribal elder (born in 1937), the land now owned by Xcel/NSP was predominately

31 owned by two families. The Nauer family owned most the land where the PINGP 1 and 2 is

32 located. Two Nauer family members are still residing (and farming) in the vicinity. The Larson

33 family owned most of the land that is closest to the tribe's land (Edoka Street vicinity), where the

34 north-south transmission lines are located. These two families had homesteads and barns.

35 Whether these are the 5 cottages referenced in the 1973 AEC FES is unknown. (PIIC 2008)

36 History of the Prairie Island Indian Community

37 Today's PIIC members are descendents of the Mdewakanton Band of Eastern Dakota,

38 who are also known as the Mississippi or Minnesota Sioux, who were parties to treaties

39 with the U.S. Government from 1805 to 1863. Members of the PIIC have lived on Prairie

40 Island for countless generations. According to archaeological evidence, Prairie Island

41 has been a place of historical and cultural significance for thousands of years. The

42 descendants of those earliest known inhabitants, the Mdewakanton Dakota (Sioux),

43 traditionally used Prairie Island as a summer encampment for fishing, hunting, gathering

44 medicines and foods, and raising crops.

45 The Prairie Island people are also part of a larger group called the "Dwellers of the Spirit

46 Lake," or in the Dakota language, the Mde wakan ed otunwahe. This name has been

October 2009 2-67 Draft NUREG-1437, Supplement 39
Affected Environment

1 shortened over the years to Mdewakantonwan or Mdewakanton (M'DAY-wah-kahn2 tahn). The Mdewakanton are one of the seven sub-tribes who make up the alliance

3 known as Oceti Sakowin - the Seven Council Fires. This alliance is more commonly

4 known as the Sioux, which comes from an Ojibwe word nadowessi for "Little snakes."

5 The name was changed by the French to Nadowesioiux or simply Sioux. Today, the

6 Sioux call themselves Dakota, Lakota, or Nakota, a word that means "allies" or "friends"

7 in all three dialects. The Dakota, Lakota, and Nakota have reservations in the states of

8 Minnesota, Nebraska, South Dakota, North Dakota, and Montana, and in the Canadian

9 provinces of Manitoba and Saskatchewan.

10 The following four paragraphs are provided by the PIIC as a history of the Dakota

11 Uprising and PIIC land acquisition.

12 In 1891, the U.S. Secretary of the Interior purchased 120 ac (49 ha) of land on

13 Prairie Island for the benefit of the Mdewakanton Sioux in Minnesota who did not

14 participate in the Dakota Uprising of 1862, an armed conflict between the United

15 States and several bands of the Eastern Dakota which began on August 17,

16 1862, along the Minnesota River in southwest Minnesota.

17 During the early to mid-1800s, the Dakota ceded vast tracts of land to the U.S.

18 Government through various treaties with the U.S. In exchange, the Dakota were

19 promised cash and annuities (goods and food) by the U.S. Government. Very

20 little of the appropriated cash and annuities was actually paid to the Dakota, but

21 instead went directly to the traders from whom the Dakota were purchasing

22 goods. Tensions rose during the summer of 1862 when crops failed, the annuity

23 payments were delayed, the U.S. Government refused to hand out food that was

24 stored for the Dakota, and the traders refused to allow the Dakota to purchase

25 food and goods on credit. The resulting severe food shortages caused

26 widespread hunger among the Dakota.

27 Frustrated with this situation and the continued encroachment of their lands, a

28 council of Dakota decided to attack settlements throughout the Minnesota River

29 Valley in an effort to drive whites out of the area. Continued battles between the

30 Dakota against settlers and later, the U.S. Army, culminated with the surrender of

31 most of the Dakota. On September 26, 1862, over 1200 Dakota men, women,

32 and children were taken into custody at Fort Snelling, Minnesota. Two days later,

33 on September 28, 393 Dakota were tried for their involvement in the conflict; 303

34 were sentenced to hang. On December 26, 1862, 38 Dakota were hanged in

35 Mankato, Minnesota; this was the largest mass execution in U.S. history. In April

36 of 1863, the rest of the Dakota were expelled from Minnesota and the U.S.

37 Congress abolished their reservations.

38 This land purchased in 1891 for the Mdewakanton Sioux at Prairie Island was

39 assigned to individual Mdewakanton Sioux members (in 5 and 10 ac [2 and 4 ha]

40 tracts) residing on Prairie Island. These land assignments, also known as the

41 Red Seal Lands, were originally restricted to the descendents of the

42 Mdewakanton Sioux who were residing in the State of Minnesota on May 20,

43 1886. A 1980 Act of Congress changed the status of those lands, transferring

44 them into trust for the benefit of the PIIC.

45 Following the Indian Reorganization Act of 1034, the U.S. Government purchased and

46 placed into trust an additional 414 ac (168 ha) of land for the PIIC. This purchase, which

47 abutted the original 120 ac (49 ha), established the Prairie Island Reservation. Over the

48 last several years, the PIIC has been able to expand its land base through the purchase

Draft NUREG-1437, Supplement 39 2-68 October 2009
Affected Environment

1 of additional adjacent lands. The "Prairie Island Land Conveyance Act of 2005," passed

2 by Congress in 2005, authorized the transfer of an additional 1,300 ac (526 ha) of

3 USACE land (485 ac [196 ha] of forested wetlands and prairie and 819 ac [819 ha] of

4 open water) to the PIIC. Today, the PIIC has grown to over 3,000 ac (1200 ha)

5 (including land and water). Additionally, the tribe owns 685 ac (277 ha) of land (in

6 Goodhue County) that are not in Trust and not considered part of the reservation, 465 ac

7 (188 ha) in Florence Township and 259 ac (105 ha) in Welch Township.

8 2.2.9.2 Historic and Archaeological Resources

9 Previous Archaeological Research at Prairie Island

10 There are nine archaeological sites on the PINGP 1 and 2 property including seven known and

11 recorded archaeological sites, one reported site (Vergil Larson II Mound Group site [21GDI]),

12 and one unrecorded site (Prairie Island District 132 Schoolhouse) (see Table 2.25). The earliest

13 investigation on Prairie Island was conducted by T.H. Lewis in 1885. Lewis was a surveyor for

14 the Northwest Archaeological Survey. He documented the presence of hundreds of mounds

15 and created a series of maps. Lewis never published his notes or maps. Lewis's work was

16 followed by Jacob Brower and Warren Upham in the late 1880s. Many of the sites documented

17 by Lewis were recorded in relation to a shoreline that no longer exists due to flooding from the

18 construction of dams on the Mississippi River (Hildebrandt 2008). The discussion below is a

19 chronological summary of the archaeological surveys and studies performed in the vicinity of the

20 PINGP 1 and 2 site.

21 In the 1940s and 1950s, Lloyd Wilford, a professor at the University of Minnesota, continued the

22 archaeological study of mounds and other sites on Prairie Island. He conducted a number of

23 interviews with landowners and excavated some mounds and archeological sites on the island.

24 He also conducted archaeological investigations at the Bartron Village site (21GD02) and the

25 Birch Lake Mound Group (21GD58), both of which are on the present-day PINGP 1 and 2

26 property.

27 In the 1960s, Elden Johnson conducted several archaeological surveys and salvage

28 excavations on Prairie Island. During a 1960 survey, Johnson reportedly located 41 burial

29 mounds. In 1967, in anticipation of the construction of PINGP 1 and 2, Johnson conducted and

30 coordinated surveys and excavations with NSP and the Minnesota Historical Society (MHS).

31 Johnson identified and recorded an Oneota village (21 GD02, previously excavated by Wilford in

32 1948) and site 21GD148, a prehistoric habitation site. Archaeological excavation of 21GD02

33 uncovered various subsurface features, including storage/refuse pits, fire hearths, and

34 postmolds. Portions of two houses were also uncovered and possibly a portion of a palisade,

35 also known as a type of fence.

36 Table 2-25. Archaeological Sites within the PINGP 1 and 2 Site Boundary

Site Site Name Description Condition

Number

21GD02 Bartron Village Site Village Site; Oneota (Blue Earth Moderately disturbed (from

Phase) affiliation cultivation) (Gibbon 1979)

21GD58/61 Birch Lake Mound Group Eight mounds; Mississippian Unknown (Johnson, Peterson,

affiliation and Streiff 1969)

21GD59 NSP II Mound Group Six mounds; Mississippian Heavily disturbed/destroyed

affiliation (from cultivation and PINGP

construction) (Johnson Data

October 2009 2-69 Draft NUREG-1437, Supplement 39
Affected Environment

Recovery 1969)

21GD62 Mound One mound; probable Moderately disturbed (from

Woodland affiliation cultivation and possibly

railroad construction)

21GD148 Habitation site Woodland and probable Minimally disturbed (Johnson

Mississippian affiliation 1980a)

21GD149 Possible Earthwork, Possible Woodland and Heavily disturbed (from

Mound, or Habitation probably Oneota affiliation erosion) (Johnson 1980

Site and Artifact Scatter survey work)

21GD207 Artifact Scatter Woodland affiliation Unknown (Johnson 1980

survey work)

21GDI Vergil Larson II Mound Reported 3 mounds Unknown

Group

No site Prairie Island District 132 Subsurface remains of District Minimally disturbed, site not

number Schoolhouse Site Schoolhouse (1873 to 1953) formally investigated

Source: Boden 2008; Hildebrandt 2008

1 In 1968, the U.S. Atomic Energy Commission (AEC) issued the construction permits for PINGP

2 1 and 2. Shortly after the issuance of the permits, archaeological excavations began at the

3 Bartron Village Site (21 GD02), and continued through 1969. In 1979, Guy Gibbon documented

4 the results from Johnson's 1968 and 1969 excavations at the Bartron Village Site (21GD02).

5 Johnson also coordinated excavatiOns at the Birch Lake Mound Group (21GD58/61) and the

6 NSP II Mound Group (21GD59). Excavations at the Birch Lake Mound Group (21GD58/61)

7 yielded enough information for publication (Johnson, Peterson, and Streiff 1969). There is no

8 summary of the excavations conducted at the NSP II Mound Group (21GD59).

9 The layout of the PINGP 1 and 2 cooling towers was modified several times, finally resulting in

10 an east-west configuration. Burial mounds at the NSP II Mound Group (21GD59) were reported

11 to be in the vicinity and artifacts were encountered during excavation and were curated at the

12 Minnesota Historic Society (MNHS) (Hildebrandt 2008). The four remaining mounds were either

13 covered with fill or leveled during grading activities for the PINGP 1 and 2 cooling towers. No

14 human remains were encountered.

15 In 1971, the Bartron Village Site (21GD02) was listed on the National Register of Historic Places

16 (NRHP). NSP agreed to set aside the southern portion of the PINGP 1 and 2 property for

17 archaeological preservation (NMC 2008).

18 A voluntary ban on excavating Indian burials in Minnesota began in the mid-1970s. Minnesota's

19 Private Cemeteries Act (M.S 307.08) protects "...all human burials, human remains, and human

20 burial grounds shall be accorded equal treatment and respect for human dignity without

21 reference to their ethnic origins, cultural backgrounds, or religious affiliations. The provisions of

22 this section shall apply to all human burials, human remains, or human burial grounds found on

23 or in all public or private lands or waters in Minnesota." Previously, burials on public land were

24 protected while burials on private land were not afforded the same protection.

Draft NUREG-1437, Supplement 39 2-70 October 2009
Affected Environment

1 In the early 1980s, Christine Harrison of the MNHS conducted a systematic survey of Goodhue

2 County, including the PINGP 1 and 2 site. At this time, Elden Johnson returned to PINGP 1 and

3 2 to conduct archaeological investigations for the modification of the cooling discharge canal.

4 Sites potentially impacted by the proposed modification were the NSP II Mound Group

5 (21GD59) and the 21GD148 habitation site (Hildebrandt 2008). A new site, 21GD207, an

6 artifact scatter, was also identified during this survey. Johnson completed his final report in

7 December 1980. Site 21GD148 was nominated to the NRHP though it did not make the list.

8 Also in 1980, but unrelated to the canal survey work, another new site (21GD149) was

9 discovered eroding out of a river bank by NSP biologists on land owned by the USACE and

10 leased by NSP. In 1991, 1994, and 2005 archaeological surveys and testing continued on the

11 PINGP 1 and 2 property, with no artifacts recovered.

12 In 1999, the PIIC hired The 106 Group, Ltd., to perform an archaeological reconnaissance

13 survey and Geographic Information Systems (GIS) inventory of archaeological sites on and in

14 the vicinity of the PIIC. Survey efforts during the inventory were unable to field verify the Vergil

15 Larson II Mound Group (21GDI). No subsurface testing was attempted in the area out of

16 respect for the potential burials interred in the mounds (Abel et al. 1999).

17 Xcel Energy (Xcel) contracted with The 106 Group, Ltd., in 2008 to conduct a cultural resources

18 assessment of archaeological sites located on and in the immediate vicinity (within 1 mi [0.6

19 km]) of the PINGP 1 and 2 site (Boden 2008). Xcel recently partnered with Minnesota State

20 University, Mankato, to conduct archaeological excavations of the Bartron Village Site

21 (Hildebrandt 2008).

22 Traditional Cultural Properties

23 Traditional cultural properties are cultural resources that are historically important for a

24 community to maintain its cultural heritage. Examples of traditional cultural properties include

25 gathering areas, plant material, a sacred mountain and/or landscape that is crucial to a

26 community's identity, or burial locations that, for example, connect American Indians with their

27 ancestors. Most traditional cultural properties can be identified only through consultation with

28 members of these communities. Identifying traditional cultural properties is an important part of

29 the Section 106 consultation under the National Historic Preservation Act (NHPA).

30 While no traditional cultural properties have been identified at the PINGP 1 and 2 site, there is

31 the potential for these properties to exist. The PIIC has also expressed concern about invasive

32 plants on Prairie Island displacing native species that are culturally significant to the PIIC. Many

33 of these plants are used as medicines and in religious ceremonies by members of the PIIC. A

34 2008 survey conducted by the PIIC found 22 invasive plant species on tribal lands. Work is

35 underway to remove buckthorn and purple loosestrife from some areas (PIIC 2009).

36 Because of concerns about declining native plant species, the PIIC conducted an

37 inventory of medicinal and culturally important plant species on tribal lands. The

38 inventory, which was conducted in the fall of 2008 and spring/summer of 2009, is a

39 follow-up to an inventory conducted in 1998 (PIIC 2009). According to the 1998

40 inventory, 70 percent of the original native medicinal and culturally significant plant

41 species have been lost during the last generation. Of the 189 medicinal or culturally

42 important plant species historically present on Prairie Island and used by tribal members,

43 only 52 were identified in the 1998 field survey. The 1998 study also discussed the

44 findings of past plant studies conducted by NSP within the boundaries of PINGP 1 and 2

45 since 1975. Medicinal and culturally important plant species found to be present in both

46 the Xcel/NSP and Prairie Island studies included: yarrow, ragweed, big milkweed, lamb's

47 quarter, wild strawberry, sunflower, sweet clover, sand primrose, Virginia creeper,

48 goldenrod, and pennyroyal. (PIIC 2009)

October 2009 2-71 Draft NUREG-1437, Supplement 39
Affected Environment

1 As part of the 2008/2009 inventory, Tribal elders were interviewed to gain a historical

2 perspective on the locations and uses of these plants on the PIIC Reservation. Some elders

3 stated that medicinal plants they have used in the past were not as strong or abundant as they

4 once were. All of the elders interviewed agreed that conducting periodic surveys is important

5 and that the PRIC should develop some kind of management plan to protect species, enhance

6 growing conditions, and educate PIIC members about native plant species and their uses. (PIIC

7 2009)

8 2.3 Related Federal and State Activities

9 The NRC staff reviewed the possibility that activities of other Federal agencies might impact the

10 renewal of the operating license for PINGP 1 and 2. Any such activity could result in cumulative

11 environmental impacts and the possible need for a Federal agency to become a cooperating

12 agency in the preparation of the PINGP 1 and 2 SEIS.

13 The NRC staff has determined that there are no Federal projects that would make it desirable

14 for another Federal agency to become a cooperating agency in the preparation of the SEIS.

15 Federal facilities and National Parks within 50 mi (80 km) of PINGP 1 and 2 are listed below.

16 ° St. Anthony Falls Lock and Dam

17 ° Lower St. Anthony Falls Lock and Dam

18 & Lock and Dam 1

19 ° Lock and Dam 2

20 • Lock and Dam 3

21 ° Mississippi National River and Recreation Area

22 0 Fort McCoy (U.S. Military Installation)

23 0 Army National Guard Family Assistance Center

24 0 Minneapolis-St. Paul Air Reserve Station

25 The NRC has entered into a Memorandum of Understanding (MOU) with the PIIC for the PINGP

26 1 and 2, license renewal application review, which is described in more detail in Section 1.6.

27 The American Indian lands listed below lie within 50 mi (80 km) of PINGP 1 and 2. Tribal

28 agencies contacted during the environmental review in addition to those listed below are listed

29 in Section 1.8 of this draft SEIS.

30 0 Prairie Island Indian Community, Welch, Minnesota

31 0 Shakopee Mdewakanton Sioux Community, Prior Lake, Minnesota

32 NRC is required under Section 102(2)(c) of the National Environmental Policy Act of 1969

33 (NEPA) to consult with and obtain the comments of any Federal agency that has jurisdiction by

34 law or special expertise with respect to any environmental impact involved. NRC has consulted

35 with the American Council on Historic Preservation and the FWS. Federal Agency consultation

36 correspondence and comments on the SEIS are presented in Appendix D.

37 2.4 References

38 10 CFR 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for Protection

39 Against Radiation."

Draft NUREG-1437, Supplement 39 2-72 October 2009
Affected Environment

1 10 CFR 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of

2 Production and Utilization Facilities."

3 10 CFR 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental Protection

4 Regulations for Domestic Licensing and Related Regulatory Functions."

5 10 CFR 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for Renewal

6 of Operating Licenses for Nuclear Power Plants."

7 10 CFR 61. Code of Federal Regulations, Title 10, Energy, Part 61, "Licensing Requirements for

8 Land Disposal of Radioactive Waste."

9 10 CFR 71. Code of Federal Regulations, Title 10, Energy, Part 71, "Packaging and

10 Transportation of Radioactive Material."

11 10 CFR 100. Code of Federal Regulations, Title 10, Energy, Part 100, "Reactor Site Criteria."

12 40 CFR 81. Code of Federal Regulations, Title 40, Protection of Environment, Part 81,

13 "Designation of Areas for Air Quality Planning Purposes."

14 40 CFR 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190,

15 "Environmental Radiation Protection Standards for Nuclear Power Operations."

16 40 CFR 239, et seq. Code of Federal Regulations, Title 40, Protection of Environment, Chapter

17 I, Environmental Protection Agency, Subchapter I, "Solid Wastes."

18 40 CFR 261. Code of Federal Regulations, Title 40, Protection of Environment, Part 261,

19 "Identification and Listing of Hazardous Waste."

20 40 CFR 262. Code of Federal Regulations. Title 40, Protection of Environment, Part 262,

21 "Standards Applicable to Generators of Hazardous Waste."

22 40 CFR 266. Code of Federal Regulations, Title 40, Protection of Environment, Part 266,

23 "Storage, Treatment, Transportation, and Disposal of Mixed-Waste."

24 40 CFR 273. Code of Federal Regulations, Title 40, Protection of Environment, Part 273,

25 "Standards for Universal Waste Management."

26 41 FR 24064. U.S. Fish and Wildlife Service. Endangered and threatened wildlife and plants;

27 endangered status for taxa of animals. June 14, 1976.

28 63 FR 31268. U.S. Environmental Protection Agency. Changes to the hazardous chemical

29 reporting regualations. June 8, 1998.

30 72 FR 37346, U.S. Fish and Wildlife Service. Endangered and threatened wildlife and plants;

31 removing the Bald Eagle in the lower 48 states from the list of endangered and threatened

32 wildlife. July 9, 2007.

33 73 FR 65452, Environmental Protection Agency. "Emergency Planning and Community Right34 to-Know Act; Amendments to Emergency Planning and Notification; Emergency Release

35 Notification and Hazardous Chemical Reporting; Final Rule." Federal Register Volume 73, No.

36 213, pp. 65452-65484.

37 Abel, Elizabeth, Zakariah Johnson, and Mollie M. Lyon. 1999. Phase 1 Archaeological

38 Reconnaissance Survey and GIS Inventory for the Prairie Island Indian Community, Prairie

39 Island Reservation and Parcel D, Goodhue County, Minnesota. Final Report. Submitted to the

40 Prairie Island Indian Community and St. Paul District Corps of Engineers. St. Paul, MN. The

41 106 Group Ltd. August. Non-public reference per 36 CFR 800.11(c), NHPA § 304[16 U.S.C.

42 470w-3(a) - Confidentiality of the location of sensitive historic resources], and Minnesota

43 Statute 307.08, Sub. 11.

October 2009 2-73 Draft NUREG-1437, Supplement 39
Affected Environment

1 AEC (Atomic Energy Commission). 1973. Final Environmental Statement Related to the

2 Operation of Prairie Island Nuclear Generating Plant. Washington, D.C. ADAMS No.

3 ML081840311.

4 Boden, Peggy J. 2008. Cultural Resources Assessment for the Prairie Island Nuclear

5 Generating Plant, Goodhue County, Minnesota. St. Paul, MN. The 106 Group Ltd. -

6 Archaeological Report. Non-public reference per 36 CFR 800.11(c), NHPA § 304[16 U.S.C.

7 470w-3(a) - Confidentiality of the location of sensitive historic resources], and Minnesota

8 Statute 307.08, Sub. 11.

9 CAA (Clean AirAct. 42 U.S.C. 7401, et seq.). United States Code, Title 42, The Public Health

10 and Welfare, Chapter 85, "Air Pollution Prevention and Control."

11 City of Red Wing. 2003. "City History." Available URL: http://www.red-wing.org (accessed:

12 March 1, 2009).

13 Cornell (Cornell Lab of Ornithology). 2003. "Peregrine Falcon." Available URL:

14 http://www.birds.cornell.edu/AllAboutBirds/BirdGuide/PeregrineFalcondtl.html. Accessed

15 October 2, 2007. ADAMS No. ML073300303.

16 Cowdery, Timothy K. 1999. Water Resources of the Prairie Island Indian Reservation,

17 Minnesota, 1994-1997: Water-Resources Investigation Report 99-4069. U.S. Geological

18 Survey. Available URL: http://mn.water.usgs.gov/pubs/99-4069.pdf (accessed October 10,

19 2008).

20 CWA (Clean Water Act; or Federal Water Pollution Control Act). 33 U.S.C. 1251 et seq.

21 Dakota County. 1999. Dakota County 2020 Land Use Policy Plan. October. Available URL:

22 http://www.co.dakota.mn.us/NR/rdonlyres/000008fa/ckgrsunrmqgcekbkcouzfbchsucsbdwg/3Lan

23 dUse.pdf (accessed December 29, 2008).

24 Dakota County. 2005. Environmental and Natural Resource Management Policy Plan, Dakota

25 County Comprehensive Plan. October 4. Available URL:

26 http://www.co.dakota.mn.us/NR/rdonlyres/00001 137/gkcoqwzasmhkzybxqpfbblfowhmsfcek/6En

27 vNaturalResources905.pdf?bcsi_scanA3171404B2C9D30E=0&bcsiscanfilename=6EnvNatu

28 ralResources905.pdf (accessed December 29, 2008).

29 Dobbs, Clark A. 1988. Outline of Historic Contexts for the Prehistoric Period (ca. 12,000 B.P. -

30 A.D. 1700): A Document in the Series Minnesota History in Sites and Structures. Reports of

31 Investigations, Nos. 37 et seq. Minneapolis: Institute of Minnesota Archaeology. Prepared for

32 the Minnesota State Historic Preservation Office, St. Paul.

33 EPA (U.S. Environmental Protection Agency). 1974. Information on Levels of Environmental

34 Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety. Report

35 550/9-74-004, Washington, D.C. Available URL:

36 http:/lwww.nonoise.org/library/levels74/1evels74.htm (accessed March 2, 2009).

37 EPA (U.S. Environmental Protection Agency). 2006. "Mississippi River Basin & Gulf of Mexico

38 Hypoxia Upper Mississippi: Background on Upper Mississippi River Basin." Available URL

39 www.epa.gov/msbasin/subbasins/upper/index.htm (accessed October 10, 2008).

40 EPA (U.S. Environmental Protection Agency). 2007. Hazardous Waste Generators Regulations.

41 May. Available URL: http://www.epa.gov/oswfhazard/downloads/tool.pdf (accessed January 16,

42 2009). ADAMS No. ML082880301.

43 EPA (U.S. Environmental Protection Agency). 2007a. "Wastes - Laws and Regulations."

44 Available URL: http://www.epa.gov/osw/laws-regs/index.htm (accessed January 16, 2009).

45 ADAMS No. ML082880301.

Draft NUREG-1437, Supplement 39 2-74 October 2009
Affected Environment

1 EPA (U.S. Environmental Protection Agency). 2008. "Pollution Prevention Information

2 Clearinghouse (PPIC)." Available URL: http://www.epa.gov/oppt/ppic/ (accessed January 16,

3 2009). ADAMS No. ML082880301.

4 EPA (U.S. Environmental Protection Agency). 2008a. "Environmental Management Systems

5 (EMS)." Available URL: http://www.epa.gov/ems/index.html (accessed January 16, 2009).

6 ADAMS No. ML082880301.

7 EPA (U.S. Environmental Protection Agency). 2008b. "Safe Drinking Water Information

8 System, County Search - Goodhue, Dakota, and Pierce Counties - October 31, 2008."

9 Available URL: http://www.epa.gov/enviro/html/sdwis/sdwisquery.html (accessed December

10 19,2008).

11 EPA (U.S. Environmental Protection Agency). 2009. "EPA EnviroFacts Warehouse - Facility

12 Detail Report - Northern States Power Company." Available URL:

13 http://iaspub.epa.gov/enviro/fiiquerydtl.dispprogram-facility?pgmsysidin=MN D04953778

14 0&pgmsys-acrnmin=RCRAINFO (accessed January 16, 2009). ADAMS No. ML090160473.

15 ESA (Endangered Species Act). 16 U.S.C. 1531, et seq.

16 ESWQD (Environmental Services Water Quality Department). 2005. Prairie Island Nuclear

17 Generating Plant Environmental Monitoring and Ecological Studies Program. Annual Report.

18 ADAMS No. ML083120223.

19 FWS (U.S. Fish and Wildlife Service). 2000a. Biological Opinion for the Operation and

20 Maintenance of the 9-Food Navigation Channel on the Upper Mississippi River System. U.S.

21 Fish and Wildlife Service, Division of Endangered Species, Fort Snelling, Minnesota. Available

22 URL: http://www.fws.gov/midwest/endangered/section7/umrbofinal.pdf (accessed September

23 25, 2008).

24 FWS (U.S. Fish and Wildlife Service). 2000b. "Threatened and Endangered Species: Prairie

25 Bush Clover (Lespedeza leptostachya)." Available URL:

26 http://www.fws.gov/midwest/endangered/plants/pdf/lelefctsht.pdf (accessed July 10, 2008).

27 ADAMS No. ML082760088.

28 FWS (U.S. Fish and Wildlife Service). 2002a. Status Assessment Report for the Sheepnose,

29 Plenthobasus cyphyus, Cccurring in the Mississippi River System (U.S. Fish and Wildlife

30 Service Regions 3, 4, 5, and 6). Ohio River Valley Ecosystem Team, Ashville, North Carolina.

31 December. Available URL:

32 http://www.fws.gov/midwest/mussel/documents/plethobasusstatus.pdf (accessed October 15,

33 2008).

34 FWS (U.S. Fish and Wildlife Service). 2002b. Status Assessment Report for the Spectaclecase,

35 Cumberlandia monodonta, Cccurring in the Mississippi River System (U.S. Fish and Wildlife

36 Service Regions 3, 4, 5, and 6). Ohio River Valley Ecosystem Team, Ashville, North Carolina.

37 December. Available URL: http://www.fws.gov/midwest/mussel/documents/

38 cumberlandia_status.pdf (accessed December 3, 2008).

39 FWS (U.S. Fish and Wildlife Service). 2004a. Higgins Eye Pearlymussel (Lampsilis higginsii)

40 Recovery Plan: First Revision. Ft. Snelling, Minnesota. 126 pp. Available URL:

41 http://ecos.fws.gov/docs/recoveryplans/2004/040714.pdf (accessed August 27, 2008).

42 FWS (U.S. Fish and Wildlife Service). 2004b. "Winged mapleleaf." Available URL:

43 http://www.fws.gov/Midwest/endangered/clams/pdf/wmapleleaf.pdf (accessed December 3,

44 2008). ADAMS No. ML083380487.

October 2009 2-75 Draft NUREG-1437, Supplement 39
Affected Environment

1 FWS (U.S. Fish and Wildlife Service). 2008a. "County Distribution of Minnesota's Federally

2 Threatened, Endangered, and Candidate Species." Available URL:

3 http://www.fws.gov/midwest/endangered/lists/mn08cty.pdf (accessed July 9, 2008). ADAMS No.

4 ML082760093.

5 FWS (U.S. Fish and Wildlife Service). 2008b. Letter from D. Sullins, Field Supervisor, U.S. Fish

6 and Wildlife Service, to R. Franovich, Branch Chief. Subject: Request for list of Federally

7 protected species within the area under evaluation for the Prairie Island Nuclear Generating

8 Plant, Units 1 and 2, license renewal application review. August 13, 2008. ADAMS No.

9 ML082470303.

10 FWS (U.S. Fish and Wildlife Service). 2008c. "Minnesota Dwarf Trout Lily (Erythronium

11 propullans) Fact Sheet." Available URL:

12 http://www.fws.gov/midwest/endangered/plants/dwarftro.html (accessed July 10, 2008). ADAMS

13 No. ML082760096.

14 FWS (U.S. Fish and Wildlife Service). 2008d. "Wetlands Digital Data: Wetlands Mapper."

15 Available URL: http://wetlandsfws.er.usgs.gov/NWI/index.html (accessed July 2, 2008). ADAMS

16 No. ML082760098.

17 FWS (U.S. Fish and Wildlife Service). Undated. "Fact Sheet: Upper Mississippi River: National

18 Wildlife and Fish Refuge." Available URL:

19 http://www.fws.govlmidwest/UpperMississippiRiver/Documents/ff.pdf (accessed July 8, 2008).

20 ADAMS No. ML082760100.

21 FWS (U.S. Fish and Wildlife Service). Undated b. "Upper Mississippi River National Wildlife and

22 Fish Refuge." Available URL: http://www.fws.gov/refuges/profiles/index.cfm?id=32579

23 (accessed July 8, 2008). ADAMS No. ML082760103.MNDNR (Minnesota Department of Natural

24 Resources). 2006a. "2005 Minnesota Bald Eagle Surveys Summary." Available URL:

25 http://files.dnr.state.mn.us/eco/nongame/projects/eaglereport_2005.pdf (accessed September

26 8, 2008). ADAMS No. ML082760072.

27 Gibbon, Guy E. 1979. "The Mississippian Occupation of the Red Wing Area." Minnesota

28 Prehistoric Archaeology. Series, 13. St Paul: Minnesota Historical Society.

29 Gibbon, Guy E. and Clark A. Dobbs. 1991. "The Mississippian Presence in the Red Wing Area,

30 Minnesota." New Perspectives on Cahokia: Views from the Periphery. James Stoltman, ed.

31 Pp. 281-305. Monographs in World Archaeology, 2. Madison, WI: Prehistory Press. Available

32 URL:

33 http://www.fromsitetostory.org/sources/papers/rwlprepressmississippian/rwlprepressmississippi

34 an.asp#ar (accessed January 30, 2009). ADAMS Accession No. ML090630832.

35 Goodhue County. 2004. 2004 Inventory Document Goodhue County Comprehensive Plan.

36 Available URL http://www.co.goodhue.mn.us/misc/files/CompPlan_2004.pdf (accessed

37 December 29, 2008).

38 Indian Reorganization Act. 14 U.S.C. 461, et seq.

39 Hildebrandt, Emily. 2008. Literature Search and Assessment of Historical and Archaeological

40 Resources Impacted by Construction and Operations Activities at the Prairie Island Nuclear

41 Plant, Goodhue County, Minnesota. Final Report. Submitted to Nuclear Management

42 Company. Welch, Minnesota. Minnesota State University, Mankato. August. Non-public

43 reference per 36 CFR 800.11(c), NHPA § 304[16 U.S.C. 470w-3(a) - Confidentiality of the

44 location of sensitive historic resources], and Minnesota Statute 307.08, Sub. 11.

Draft NUREG-1437, Supplement 39 2-76 October 2009
Affected Environment

1 Institute of Educational Science (IES). 2008. U.S. Department of Education, National Center

2 for Educational Statistics. "College Opportunities Online Locator." Zip Code 55089. Available

3 URL: http://nces.ed.gov/ipeds/cool/RefineSearch.aspx. (accessed August 3, 2009).

4 Kelner, D.E. and M. Davis. 2002. Final Report: Mussel (Bivalvia: Unionidae) Survey of the

5 Mississippi National River and Recreation Area Corridor, 2000-01. Contract report to the

6 National Park Service Mississippi National River and Recreation Area and the Great Lakes

7 Network Inventory and Monitoring Program. Minnesota Department of Natural Resources.

8 Kneisler, J. 1999. "Nicholas Perrot: Early Wisconsinite." University of Wisconsin-LaCrosse,

9 International Studies. Available URL: http://www.uwgb.edufwisfrench/study/research/perrot.htm

10 (accessed March 1, 2009). ADAMS Accession No. ML090630835.

11 MCWG (Minnesota Climatology Working Group). 2008. "Minnesota Tornado History and

12 Statistics." Available URL: http://climate.umn.edu/doc/historical/tornadic.htm (accessed

13 December 4, 2008). ADAMS No. ML083460351.

14 MDE (Minnesota Department of Education). 2007. "Minnesota Public School Districts, 2007 -

15 2008 School Year." Available URL

16 http://education.state.mn.us/mdeprod/groups/InformationTech/documents/Maps/000804.pdf?bc

17 si scanA3171404B2C9D30E=0&bcsiscanfilename=000804.pdf (accessed December 29,

18 2008).

19 MDE (Minnesota Department of Education). 2008a. "Minnesota Department of Education

20 Student Enrollment Data By District". Data set "2007-2008 Enrollment-District--

21 Grade/Ethnicity/Gender". Available URL

22 http://education.state.mn.usNWebsiteContent/ContentArchive.jsp?siteld=7&siteSection=Data%2

23 FData+Downloads%2FStudent%2FEnrollment%2FDistrict%3B (accessed December 29, 2008).

24 MDE (Minnesota Department of Education). 2008b. "Minnesota Department of Education

25 Student Enrollment Data By County". Data set "2007-2008 Enrollment-County--

26 Grade/Ethnicity/Gender". Available URL:

27 http://education.state.mn.us/WebsiteContent/ContentArchive.jsp?siteId=7&siteSection=Data%2

28 FData+Downloads%2FStudent%2FEnrollment%2FCounty%3B (accessed December 29, 2008).

29 MDEED (Minnesota Department of Employment and Economic Development). 2009.

30 Community Profile Database for Goodhue County Major Employers. Available URL:

31 http://www.mnpro.com (accessed August 3, 2009).

32 MDH (Minnesota Department of Health). 2008a. Fish Consumption Guidelines for the General

33 Population, Rivers. Available URL: http://www.health.state.mn.us/

34 divs/eh/fish/eating/genpoprivers.pdf (accessed December 2, 2008). ADAMS No. ML083370704.

35 MDH (Minnesota Department of Health). 2008b. Fish Consumption Guidelines for Women Who

36 Are or May Become Pregnant and Children Under Age 15, Rivers. Available URL:

37 http://www.health.state.mn.u's/divs/eh/fish/eating/specpoprivers.pdf (accessed December 2,

38 2008). ADAMS No. ML083370705.

39 MNHS (Minnesota Historical Society). 2009. "Historic Fort Snelling: A Brief History of Fort

40 Snelling." Available URL: http://www.rmnhs.org/places/sites/hfs/history.html (accessed March 1,

41 2009).

42 Minnesota Administrative Rules. Chapter 7045, Hazardous Waste, Part 7045.0248 "License

43 Renewal Application." Available URL: https://www.revisor.leg.state.mn.us/rules/?id=7045.0248

44 (accessed January 16, 2009). ADAMS No. ML ML090160449.

October 2009 2-77 Draft NUREG-1437, Supplement 39
Affected Environment

1 Minnesota Administrative Rules. Chapter 7045, Hazardous Waste, Part 7045.1400 "Adoption of

2 Federal Standards for Universal Waste Management." Available URL:

3 https://www.revisor.leg.state.mn.us/rules/?id=7045.1400 (accessed January 16, 2009). ADAMS

4 No. ML090160439.

5 MNDNR (Minnesota Department of Natural Resources). 2006a. "2005 Minnesota Bald Eagle

6 Surveys Summary." Available URL:

7 http://files.dnr.state.mn.us/eco/nongame/projects/eaglereport_2005.pdf (accessed September

8 8, 2008). Accessible at ML082760072.

9 MNDNR (Minnesota Department of Natural Resources). 2006b. Tomorrow's Habitat for the Wild

10 and Rare: An Action Plan for Minnesota Wildlife, Comprehensive Wildlife Conservation Strategy

11 - Blufflands Subsection Profile. Division of Ecological Services, Minnesota Department of

12 Natural Resources. Available URL:

13 http://files.dnr.state.mn.us/assistance/nrplanning/bigpicture/cwcs/profiles/bIufflands.pdf

14 (accessed July 1, 2008). ADAMS No. ML082760076.

15 MNDNR (Minnesota Department of Natural Resources). 2008. "DNR Water Appropriation

16 Permits, Active Permits by County." Available URL

17 http://files.dnr.state.mn.us/waters/watermgmt-section/appropriations/index-county-Iocation18 active.pdf (accessed December 29, 2008).

19 MNDNR (Minnesota Department of Natural Resources). 2008a. "Bald Eagle (Haliaeetus

20 leucocephalus). Available URL: http://www.dnr.state.mn.us/birds/eagles/index.html (accessed

21 September 8, 2008). ADAMS No. ML0827701159.

22 MNDNR (Minnesota Department of Natural Resources). 2008b. Letter from H. Cyr, Minnesota

23 Department of Natural Resources, to R. Franovich, Branch Chief, Division of License Renewal.

24 Subject: Reply to Request for Natural Heritage Information in the Vicinity of the Prairie Island

25 Nuclear Generating Plant. August 26, 2008. ADAMS No. ML083290584.

26 MNDNR (Minnesota Department of Natural Resources). 2008c. "Lost Valley Prairie SNA."

27 Available URL: http://www.dnr.state.mn.us/snas/snaO1041/index.html (accessed July 8, 2008).

28 ADAMS No. ML082770153.

29 MNDNR (Minnesota Department of Natural Resources). 2008d. "Peregrine Falcon (Falco

30 peregrinus)." Available URL: http://www.dnr.state.mn.us/snapshots/birds/peregrinefalcon.html

31 (accessed July 10, 2008). ADAMS No. ML082770154.

32 MNDNR (Minnesota Department of Natural Resources). 2008e. "Savage Fen SNA." Available

33 URL: http://www.dnr.state.mn.us/snas/sna00999/index.html (accessed July 8, 2008). ADAMS

34 No. ML082770155.

35 MNDNR (Minnesota Department of Natural Resources). 2008f. "Trumpeter Swan Life History."

36 Available URL: http://www.dnr.state.mn.us/eco/nongame/projects/trumpeterswan/lifehistory.html

37 (accessed September 8, 2008). ADAMS No. ML082770156.

38 MNDNR (Minnesota Department of Natural Resources). 2008g. "Trumpeter Swan Restoration

39 Project." Available URL:

40 http://www.dnr.state.mn.us/eco/nongame/projects/trumpeterswan/index.html (accessed

41 September 5, 2008). ADAMS No. ML0827701157.

42 MNDNR (Minnesota Department of Natural Resources). 2008h. "WMA Detail Report: Gores

43 Pool #3 WMA." Available URL:

44 http://www.dnr.state.mn.us/wmas/detail-report.html?map=COMPASS-MAPFILE&mode=itemqu

45 ery&qlayer=bdry-adwma2py3_query&qitem=uniqueid&qstring=WMA0000700 (accessed July 8,

46 2008). ADAMS No. ML082770158.

Draft NUREG-1437, Supplement 39 2-78 October 2009
Affected Environment

1 MNDNR (Minnesota Department of Natural Resources). 2008i. "Zebra Mussel Fact Sheet."

2 Available URL: http://www.dnr.state.mn.us/invasives/aquaticanimals/zebramussel/index.html

3 (accessed September 12, 2008). ADAMS No. ML083380491.

4 MNDNR (Minnesota Department of Natural Resources). 2009. "Frontenac State Park."

5 Available URL: http://files.dnr.state.mn.us/maps/stateparks/spk00160_winter.pdf (accessed

6 March 1, 2009).

7 MPCA (Minnesota Pollution Control Agency). 2000. "Upper Mississippi River Basin Information

8 Document." Available URL: http://www.pca.state.mn.us/water/basins/uppermiss/bid9 uppermiss.pdf (accessed October 10, 2008). ADAMS No. ML083380233.

10 MPCA (Minnesota Pollution Control Agency). 2006. National Pollution Discharge Elimination

11 System, Permit MN0004006, Prairie Island Nuclear Generating Plant. June. ADAMS No.

12 MPCA (Minnesota Pollution Control Agency). 2008k. "Upper Mississippi River Basin." Available

13 URL: http://www.pca.state.mn.us/water/basins/uppermiss/index.html (accessed October 10,

14 2008). ADAMS No. ML083380243.

15 MRBDC (Minnesota River Basin Data Center). 2000. "State of the Minnesota River: Summary of

16 Surface Water Quality Monitoring." Available URL:

17 http://mrbdc.mnsu.edu/reports/basin/statemrOO.html (accessed November 15, 2008). ADAMS

18 No. ML083380246.

19 OSA (Minnesota Office of the State Auditor). 2007. Independent Auditor's Report: Goodhue

20 County, Red Wing, Minnesota, Year Ended December 31, 2006. November 29. Available URL:

21 http://www.co.goodhue.mn.us/departments/auditortreasurer/files/2006%2OFinancial%2OStatem

22 ent.pdf (accessed August 3, 2009).

23 MSDC (Minnesota State Demographic Center). 2002. Minnesota Population Projections 2000

24 - 2030. St. Paul, MN. October. Available URL:

25 http://www.demography.state.mn.us/DownloadFiIes/00Proj/PopulationProjectionsO2.pdf

26 (accessed August 3, 2009).

27 Minnesota Statute 307.08, Subd. 11. Private Cemeteries Act. - Publicly Available Statute

28 Mn/DOT (Minnesota Department of Transportation). "2007 Traffic Volumes General Highway

29 Map, Goodhue County, Minnesota." Available URL

30 http://www.dot.state.mn.us/traffic/data/maps/trafficvolume/2007/counties/goodhue1.pdf

31 (accessed December 29, 2008).

32 MRCC (Midwestern Regional Climate Center). 2001. "Historical Climate Data; Temperature

33 Summary: Station 216822 Red Wing Dam 3, MN." Available URL:

34 http://mrcc.isws.illinois.edu/climate-midwest/historical/temp/mn/216822-tsum.html (accessed

35 December 4, 2008). ADAMS No. ML083460353.

36 Mussel Coordination Team. 2005. Status of Implantation of Higgins Eye Pearlymussel

37 (Lampsilis higginsih) Reasonable and Prudent Alternatives and Reasonable and Prudent

38 Measures and Winged Mapleleaf (Quadrula fragosa) Reasonable and Prudent Measures.

39 November 2005. Available URL: http://www.fws.gov/midwest/mussel/documents/

40 statushigginseyewingedmapleleaf 2005.pdf (accessed August 29, 2008)

41 NCDC (National Climatic Data Center). 1998. "Climatic Wind Data for the United States."

42 Available URL: http://www5.ncdc.noaa.gov/documentlibrary/pdf/wind1996.pdf (accessed

43 December 4, 2008). ADAMS No. ML083460357.

44 NCDC (National Climatic Data Center). 2000. "Climatology of the Unites States No. 20, 1971-

45 2000, Station: Red Wing Dam 3, MN." Available URL:

October 2009 2-79 Draft NUREG-1437, Supplement 39
Affected Environment

1 http://cdo.ncdc.noaa.gov/climatenormals/clim20/mn/216822.pdf (accessed December 4, 2008).

2 ADAMS No. ML083460359.

3 NCDC (National Climatic Data Center). 2005. "Normals, Means, and Extremes: Minneapolis,

4 MN (MSP)." Available URL:

5 http://climate.umn.edu/pdf/normals-means-and-extremes/2005-Annual-LCD-MSP-page-3.pd

6 f (accessed December 4, 2008). ADAMS No. ML083460365.

7 NCDC (National Climatic Data Center). 2006. "Climate of Minnesota." Available URL:

8 http://www5.ncdc.noaa.gov/climatenormals/clim60/states/ClimMNO1 .pdf (accessed

9 December 4, 2008). ADAMS No. ML083460368.

10 NEPA (National Environmental Policy Act of 1969). 42 U.S.C. 4321, et seq.

11 NMC (Nuclear Management Company, LLC). 2001q. Prairie Island Nuclear Generating Plant,

12 Units 1 and 2, "2000 - DNR Annual Report of Water Use." ADAMS No. ML083120233.

13 NMC (Nuclear Management Company, LLC). 2002. Prairie Island Nuclear Generating Plant,

14 Units 1 and 2, "2001 - DNR Annual Report of Water Use." ADAMS No. ML083120233.

15 NMC (Nuclear Management Company, LLC). 2003. Prairie Island Nuclear Generating Plant,

16 Units 1 and 2, "2002 - DNR Annual Report of Water Use." ADAMS No. ML083120233.

17 NMC (Nuclear Management Company, LLC). 2004q. Prairie Island Nuclear Generating Plant,

18 Units 1 and 2, "2003 - DNR Annual Report of Water Use." ADAMS No. ML083120233.

19 NMC (Nuclear Management Company, LLC). 2004a. Prairie Island Nuclear Generating Plant -

20 Units 1- and 2, Operating License No.DPR-42, DPR-60 and SNM-2506. Annual Radioactive

21 Effluent Release Report and Offsite Dose Calculation Manual, Enclosure 2, "Annual Radioactive

22 Effluent Report. Supplemental information. January 01, 2003 - December 31, 2003." Goodhue

23 County, Minnesota. ADAMS No. ML041420504.

24 NMC (Nuclear Management Company, LLC). 2004b. Prairie Island Nuclear Generating Plant -

25 Units 1 and 2, Operating License No.DPR-42, DPR-60. Annual Radioactive Effluent Release

26 Report and Offsite Dose Calculation Manual, Enclosure 3, "Effluent and Waste Disposal Annual

27 Report. Solid Waste and Irradiated Fuel Shipments. January 01, 2003 - December 31, 2003."

28 Goodhue County, Minnesota. ADAMS No. ML041420504.

29 NMC (Nuclear Management Company, LLC). 2005q. Prairie Island Nuclear Generating Plant,

30 Units 1 and 2, "2004 - DNR Annual Report of Water Use." ADAMS No. ML083120233.

31 NMC (Nuclear Management Company, LLC). 2005a. Prairie Island Nuclear Generating Plant -

32 Units 1 and 2, Operating License No.DPR-42, DPR-60 and SNM-2506. Annual Radioactive

33 Effluent Release Report and Offsite Dose Calculation Manual, Enclosure 2, "Annual Radioactive

34 Effluent Report. Supplemental information. January 01, 2004 - December 31, 2004." Goodhue

35 County, Minnesota. ADAMS No. ML051360426.

36 NMC (Nuclear Management Company, LLC). 2005b. Prairie Island Nuclear Generating Plant -

37 Units 1 and 2, Operating License No.DPR-42, DPR-60. Annual Radioactive Effluent Release

38 Report and Offsite Dose Calculation Manual, Enclosure 3, "Effluent and Waste Disposal Annual

39 Report. Solid Waste and Irradiated Fuel Shipments. January 01, 2005 - December 31, 2005."

40 Goodhue County, Minnesota. ADAMS No. ML051360426.

41 NMC (Nuclear Management Company, LLC). 2006a.. E-mail from B. Bergland, Nuclear

42 Management Company, LLC, to E. McRee, Tetra Tech NUS, Inc. Subject: Additional Water

43 Data for 2005 for Unpermitted Well. August 24, 2006. ADAMS No. ML083120227.

Draft NUREG-1437, Supplement 39 2-80 October 2009
Affected Environment

1 NMC (Nuclear Management Company, LLC). 2006z. Prairie Island Nuclear Generating Plant

2 Operations Manual, Section D14.6, "Storm Water Pollution Prevention Plan." March 2006.

3 ADAMS No. ML028806950.

4 NMC (Nuclear Management Company, LLC). 2006s. Prairie Island Nuclear Generating Plant

5 Radiation Environmental Monitoring Program Annual Report to the U.S. Nuclear Regulatory

6 Commission. Environmental Inc., Midwest Laboratory. December 31, 2006. ADAMS No.

7 ML083120233.

8 NMC (Nuclear Management Company, LLC). 2006q. Prairie Island Nuclear Generating Plant,

9 Units 1 and 2, "2005 - DNR Annual Report of Water Use." ADAMS No. ML083120233.

10 NMC (Nuclear Management Company, LLC). 2006b. Prairie Island Nuclear Generating Plant -

11 Units 1 and 2, Operating License No.DPR-42, DPR-60 and SNM-2506. Annual Radioactive

12 Effluent Release Report and Offsite Dose Calculation Manual, Enclosure 2, "Annual Radioactive

13 Effluent Report. Supplemental information. January 01, 2005 - December 31, 2005." Goodhue

14 County, Minnesota. ADAMS No. ML061370092.

15 NMC (Nuclear Management Company, LLC). 2006c. Prairie Island Nuclear Generating Plant -

16 Units 1 and 2, Operating License No.DPR-42, DPR-60. Annual Radioactive Effluent Release

17 Report and Offsite Dose Calculation Manual, Enclosure 3, "Effluent and Waste Disposal Annual

18 Report. Solid Waste and Irradiated Fuel Shipments. January 01, 2005 - December 31, 2005."

19 Goodhue County, Minnesota. ADAMS No. ML061370092.

20 NMC (Nuclear Management Company, LLC). 2007b. Offsite Dose Calculation Manual Changes,

21 Enclosure 5, Revision 21, Prairie Island Nuclear Generating Plant - Units 1 and 2, Docket No.

22 50-282 and 50-306, Goodhue County, Minnesota. ADAMS No. ML081370318.

23 NMC (Nuclear Management Company, LLC). 2007q. Prairie Island Nuclear Generating Plant,

24 Units 1 and 2, "2006 - DNR Annual Report of Water Use." ADAMS No. ML083120233.

25 NMC (Nuclear Management Company, LLC). 2007c. Prairie Island Nuclear Generating Plant -

26 Units 1 and 2, Operating License No.DPR-42, DPR-60. Annual Radioactive Effluent Release

27 Report and Offsite Dose Calculation Manual, Enclosure 2, "Annual Radioactive Effluent Report.

28 Supplemental information. January 01, 2006 - December 31, 2006." Goodhue County,

29 Minnesota. ADAMS No. ML071370287.

30 NMC (Nuclear Management Company, LLC). 2007d. Prairie Island Nuclear Generating Plant -

31 Units 1 and 2, Operating License No.DPR-42, DPR-60. Annual Radioactive Effluent Release

32 Report and Offsite Dose Calculation Manual, Enclosure 3, "Effluent and Waste Disposal Annual

33 Report. Solid Waste and Irradiated Fuel Shipments. January 01, 2006 - December 31, 2006."

34 Goodhue County, Minnesota. ADAMS No. ML071370287.

35 NMC (Nuclear Management Company, LLC). 2008. Prairie Island Nuclear Generating Plant,

36 Units 1 and 2, License Renewal Application, Appendix E - Applicant's Environmental Report,

37 License Renewal Operating Stage. Redwing, Minnesota. April 2008. ADAMS Nos.

38 ML081130677, ML081130681, and ML081130684.

39- NMC (Nuclear Management Company, LLC). 2008a. E-mail from G. Malinowski, Nuclear

40 Management Company, LLC, to B. Bergland Nuclear Management Company, LLC, Subject:

41 Statement re: Groundwater Monitoring Program. September 8, 2008. ADAMS No.

42 NMC (Nuclear Management Company, LLC). 2008b. Prairie Island Nuclear Generating Plant -

43 Units 1 and 2, Operating License No.DPR-42, DPR-60 and SNM-2506. 2007 Annual

44 Radioactive Effluent Release Report and Offsite Dose Calculation Manual, Enclosure 2, "Annual

45 Radioactive Effluent Report. Supplemental information. January 01, 2007 - December 31,

46 2007." Goodhue County, Minnesota. ADAMS No. ML081370317.

October 2009 2-81 Draft NUREG-1437, Supplement 39
Affected Environment

1 NMC (Nuclear Management Company, LLC). 2008c. Prairie Island Nuclear Generating Plant -

2 Units 1 and 2, Operating License No.DPR-42, DPR-60. Annual Radioactive Effluent Release

3 Report and Offsite Dose Calculation Manual, Enclosure 3, "Effluent and Waste Disposal Annual

4 Report. Solid Waste and Irradiated Fuel Shipments. January 01, 2007 - December 31, 2007."

5 Goodhue County, Minnesota. ADAMS No. ML081370317.

6 NPS (National Park Service). 2006a. "Mississippi National River and Recreation Area: Animals."

7 Available URL: http://www.nps.gov/miss/naturescience/animals.htm (accessed July 8, 2008).

8 ADAMS No. ML082760079.

9 NPS (National Park Service). 2006b. "Mississippi National River and Recreation Area: Natural

10 Features and Ecosystems." Available URL:

11 http://www.nps.gov/miss/naturescience/naturalfeaturesandecosystems.htm (accessed July 8,

12 2008). ADAMS No. ML082760080.

13 NPS (National Park Service). 2006c. "Mississippi National River and Recreation Area: Plants."

14 Available URL: http://www.nps.gov/miss/naturescience/plants.htm (accessed July 8, 2008).

15 ADAMS No. ML082760081.

16 NPS (National Parks Service). 2008a. Mississippi River facts. Available URL:

17 http://www.nps.gov/miss/riverfacts.htm (accessed October 9, 2008). ADAMS No.

18 ML090560559.

19 NPS (National Park Service). 2008b. Annual Report: Quantitative Assessment of Zebra Mussels

20 Associated With Native Mussel Beds in the Lower St. Croix River - 2007. Prepared for U.S.

21 Army Corps of Engineers, St. Paul District. March. Available URL:

22 http://www.nps.gov/sacn/naturescience/upload/2007%2OFinal%20St.%20Croix %20River

23 %20Zebra%2OMussel%2ODensity%2OReport.doc (accessed October 9, 2008). ADAMS No.

24 NPS (National Park Service). 2009. National Register Information System (NRIS) database:

25 index by state and county for Goodhue County, Minnesota. Available URL:

26 http://nrhp.focus.nps.gov/natreghome.do?searchtype=natreghome (accessed January 30,

27 2009).

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

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

30 ADAMS Nos. ML040690705 and ML040690738.

31 NRC (U.S. Nuclear Regulatory Commission). 1999. Generic Environmental Impact Statement

32 for License Renewal of Nuclear Plants, Main Report, "Section 6.3 -Transportation, Table 9.1,

33 Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report."

34 NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

35 NWS (National Weather Service). 2005. "Tornado Statistics: Goodhue County, MN." Available

36 URL: http://www.crh.noaa.gov/mpx/TornadoStats/GoodhueMN.php (accessed December 4,

37 2008). ADAMS No. ML083460371.

38 NWS (National Weather Service). 2008a. "Alberta Clipper." Available URL:

39 http://www.crh.noaa.gov/glossary.php?word=Alberta%20clipper (accessed December 4, 2008).

40 ADAMS No. ML083460373.

41 NWS (National Weather Service). 2008b. "Panhandle Hook." Available URL:

42 http://www.crh.noaa.gov/glossary.php?word=panhandle+hook (accessed December 4, 2008).

43 ADAMS No. ML083460377.

Draft NUREG-1437, Supplement 39 2-82 October 2009
Affected Environment

1 PCA (Plant Conservation Alliance). 2006. "Purple Loosestrife." Available URL:

2 http://www.nps.gov/plants/ALIEN/fact/lysal .htm (accessed September 5, 2008). ADAMS No.

3 ML082760084.

4 Philips G.L., W.D. Schmid, and J.C. Underhill. 1982. Fishes of the Minnesota Region.

5 Minneapolis: University of Minnesota Press.

6 PRIC (Prairie Island Indian Community). 2008. Information provided by the Prairie Island Indian

7 Community (PIIC) will aid NRC staff in the preparation of the Supplemental EIS (SEIS). PIIC

8 Supplemental Information. Non-public reference per 36 CFR 800.11(c).

9 PIIC (Prairie Island Indian Community). 2009. Information provided by the Prairie Island Indian

10 Community (PIIC). PIIC Supplemental Information. Non-public reference per 36 CFR 800.11(c).

11 Pierce County. 2006. Pierce County "Smart Growth" Comprehensive Plan, Phase 1: Data

12 Collection. Available URL:

13 http://www.co.pierce.wi.us/Land%20Management/Comprehensive%20Plan/Phase-1/PierceDat

14 aCollection06. pdf?bcsi_scan_A3171404B2C9D30E=0&bcsi_scan_filename=PierceDataCollecti

15 on06.pdf (accessed December 29, 2008).

16 RCRA (Resource Conservation and Recovery Act). 40 CFR Part 239, et seq.

17 Ruhl, J.F. 2002. Simulation of Ground-Water Flow and Delineation of Areas Contributing

18 Recharge within the Mt. Simon-Hinckley Aquifer to Well Fields in the Prairie Island Indian

19 Community, Minnesota: Water-Resources Investigation Report 02-4155. U.S. Geological

20 Survey. Available URL: http://pubs.usgs.gov/wri/wri0241 551pdf/wriO2-4155.book.pdf (accessed

21 December 4, 2008).

22 Sather, N. 1990a. "Minnesota Dwarf Trout Lily: An Endangered Minnesota Wildflower."

23 Minnesota Department of Natural Resources. Available URL:

24 http://files.dnr.state.mn.us/natural_resources/ets/dwarf.trout-lily.pdf (accessed July 10, 2008).

25 ADAMS No. ML082760086.

26 Sather, N. 1990b. "Prairie Bush Clover: A Threatened Midwestern Prairie Plant." Minnesota

27 Department of Natural Resources. Available URL:

28 http://files.dnr.state.mn.us/naturalresources/ets/prairiebush_clover.pdf (accessed July 10,

29 2008). ADAMS No. ML082760087.

30 Schirmer, Ronald C. 2002. Plant-Use Systems and Late Prehistoric Culture Change in the Red

31 Wing Locality. Ph.D. dissertation, Department of Anthropology, University of Minnesota. -

32 Archaeological Report. Non-public reference per 36 CFR 800.11(c), NHPA § 304[16 U.S.C.

33 470w-3(a) - Confidentiality of the location of sensitive historic resources], and Minnesota

34 Statute 307.08, Sub. 11.

35 Schmidt, K.P. 2004. "Paddlefish (Polyodon spathula) survey results in the Mississippi River from

36 St. Paul to Red Wing." Minnesota Department of Natural Resources, Division of Ecological

37 Services. Available URL: http://www.dnr.state.mn.us/invasives/aquaticanimals/

38 zebramussel/index.html (accessed December 2, 2008).

39 Schmidt, K.P. Undated. "The distribution and status of paddlefish (Polyodon spathula) in

40 Minnesota." The Native Fish Conservancy. Available URL: http://www.nativefish.org/articles/

41 PallidfishDistrobution.php (accessed October 21, 2008).Schmidt. ADAMS No. ML083380495.

42 Scullin, Michael. 1996. Southern Minnesota Prehistory. Cahokia State Agricultural Extension

43 Office, Occasional Paper No. 1. ADAMS Accession No. ML090630836.

October 2009 2-83 Draft NUREG-1437, Supplement 39
Affected Environment

1 Stone and Webster (Stone and Webster Engineering Corp.). 1983. Modify Circulating Water

2 Intake and Discharge: System Description and Design Criteria. Prepared for Northern States

3 Power Co. Denver. April 1, 1983. ADAMS No. ML0831202223.

4 Strahler, A. N. Elements of Physical Geography. New York: John Wiley & Sons, Inc., 1984.

5 TtNUS (Tetra Tech NUS, Inc.). 2006. Calculation Package Water Use, 2000 through 2005.

6 August. ADAMS No. ML083120233.

7 Tucker, J.K., C.H. Theiling, K.D. Blodgett, and P.A. Thiel. 1993. Initial occurrences of zebra

8 mussels (Dreissena polymorpha) on freshwater mussels (Family Uniondae) in the Upper

9 Mississippi River System. Journal of Freshwater Ecology 8:245-251. Available URL:

10 http://www.sgnis.org/publicat/papers/tucker7.pdf (accessed September 12, 2008).

11 Tucker, J.K., F.A. Cronin, D.W. Soergel, and C.H. Theil. 1996. Predation on zebra mussels

12 (Dreissena polymorpha) by common carp (Cyprinus carpio). J. Freshwater Ecol. 11:363-372.

13 Available URL: http://www.sgnis.org/publicatlpapers/tucker3.pdf (accessed October 9, 2008).

14 UMRBA (Upper Mississippi River Basin Association). Undated. "River Basin and Facts."

15 Available URL: http://www.umrba.org/facts.htm (accessed October 9, 2008). ADAMS No.

16 ML090560568.

17 USDA (U.S. Department of Agriculture). 2007a. Census of Agriculture, Table 7. Hired Farm

18 Labor-Workers and Payroll: 2007, County Level Data, Minnesota. Available URL:

19 http://www.agcensus.usda.gov/Publications/2O07/FullReport/Volume_l ,_Chapter2_County_L

20 evel/Minnesota/index.asp(accessed August 6, 2009).

21 USDA (U.S. Department of Agriculture). 2007b. Census of Agriculture, Table 7. Hired Farm

22 Labor- Workers and Payroll: 2007, County Level Data, Wisconsin. Available URL:

23 http://www.agcensus.usda.gov/Publications/2007/FullReport/Volume_l ,_Chapter2_County_L

24 evel/Wisconsin/st55_2_007_007.pdf (accessed August 6, 2009).

25 USACE (U.S. Army Corps-of Engineers). 2002. Final July 2002 Definite Project Report and

26 Environmental Assessment for Relocation Plan for the Endangered Higgins' Eye Pearlymussel

27 (Lampsilis higginsih), Upper Mississippi River and Tributaries, Minnesota, Wisconsin, Iowa, and

28 Illinois. In cooperation with the Mussel Coordination Team. July. Available URL:

29 http://www.fws.gov/Midwest/mussel/documents/ dprrelocationplan finaljuly_2002.pdf

30 (accessed August 27, 2008).

31 USACE (U.S. Army Corps of Engineers). 2004. Mississippi Locks and Dams. Available URL:

32 http://www.mvp.usace.army.mil/navigation/default.asp?pageid=145 (accessed October 9,

33 2008). ADAMS No. ML083380503.

34 USCB (U.S. Census Bureau). 2000. Census 2000 Summary File 1 (SF1) 100-Percent

35 Data,Tables H1. Housing Units, and H5. Vacancy Status, and Census 2000 Summary File 3

36 (SF 3) Sample Data, Table H76. Median Value (Dollars) for Specified Owner-Occupied Housing

37 Units, By County, for Goodhue and Dakota Counties, Minnesota, and Pierce County, Wisconsin.

38 Available URL:

39 http://factfinder.census.gov/servlet/DatasetMainPageServlet?_lang=en&-ts=268050395362&-d

40 sname--DEC_2000_SF1_U&_program= (accessed August 3, 2009).

41 USCB (U.S. Census Bureau). 2007. 2005-2007 American Community Survey 3-Year Estimates,

42 Table B25001. Housing Units, Table B25004 Vacancy Status, and Table B25077 Median Value

43 (Dollars) for Owner-Occupied Housing Units, By County, for Goodhue and Dakota Counties,

44 Minnesota, and Pierce County, Wisconsin. Available URL:

45 http://factfinder.census.gov/servlet/DatasetMainPageServlet?_program=ACS (accessed August

46 6, 2009).

Draft NUREG-1437, Supplement 39 2-84 October 2009
Affected Environment

1 USCB (U.S. Census Bureau). 2007a. 2005-2007 American Community Survey 3-Year

2 Estimates, Table DP3YR-3. Selected Economic Characteristics: 2005-2007 for Goodhue and

3 Dakota Counties, Minnesota, and Pierce County, Wisconsin. Available URL:

4 http://factfinder.census.gov/servlet/DatasetMainPageServlet?_lang=en&_ts=268149170172&_d

5 sname=ACS_2000_EST_G00_&_program= (accessed August 3, 2009).

6 USCB (U.S. Census Bureau). 2008. Surveys of Goodhue County and Dakota County,

7 Minnesota, and Pierce County, Wisconsin. Housing data for 2000 and 2006. Available URL:

8 http://factfinder.census.gov and http://quickfacts.gov (accessed March 7, 2009).

9 USCB (U.S. Census Bureau). 2008a. State and County QuickFacts, 2006 Data of Goodhue,

10 Dakota, and Pierce Counties. Available URL http://quickfacts.census.gov (accessed December

11 29, 2008).

12 USCB (U.S. Census Bureau). 2008b. Census 2000 Summary File 1 (SF1) 100-Percent Data

13 Table DP-1 Profile of General Demographic Characteristics: 2000, By County and State, for

14 Goodhue County and Dakota Counties, Minnesota, and Pierce County, Wisconsin. Available

15 URL:

16 http://factfinder.census.gov/servlet/DatasetMainPageServlet?_lang=en&_ts=268148145491 &_d

17 sname=DEC_2000_SF1_U&_program= (accessed October 28, 2008).

18 USFS (U.S. Forest Service). Undated. "Eastern Broadleaf Forest Continental Province.';

19 Available URL: http://www.fs.fed.us/colorimagemap/images/222.html (accessed July 2, 2008).

20 ADAMS No. ML082760106.

21 USGS (U.S. Geological Survey). 2006. Water Resources Data, Minnesota, Water Year 2005:

22 Water Data Report MN-05-051. April 5, 2006. ADAMS No. ML028806950

23 USGS (U.S. Geologic Service). 2008. Nonindigenous Aquatic Species Fact Sheet - Dreissena

24 polymorpha). Available URL: http://nas.er.usgs.gov/queries/FactSheet.asp?specieslD=5

25 (accessed September 10, 2008). ADAMS No. ML083380519.

26 WDSC (Wisconsin Demographics Services Center). 2004. Wisconsin Population 2030: A

27 Report on Projects State, County and Municipal Populations and Households for the Period

28 2000-2030. Madison, WI. March. Available URL:

29 http://www.doa.state.wi.us/docview.asp?docid=2114 (accessed August 3, 2009).

30 WDNR (Wisconsin Department of Natural Resources). 2004. Zebra Mussels (Dreissena

31 polymorpha). Available URL: http://dnr.wi.gov/invasives/fact/ zebra.htm (accessed September

32 11, 2008). ADAMS No. ML083380525.

33 WDPI (Wisconsin Department of Public Instruction). 2009. "Public SchoolEnrollment Data."

34 Data set "PEM09". Available URL: http://dpi.wi.gov/lbstat/pubdata2.html (accessed July 30,

35 2009).

36 Willis, J. W. 1910. "Louis Hennepin." From 1910 edition of Catholic Encyclopedia. Available

37 URL: http://www.newadvent.org/cathen/07215c.htm (accessed March 1, 2009).

38 Willis, J. W. 1914. "Minnesota." From 1914 edition of Catholic Encyclopedia. Available on line at

39 http://www.newadvent.org/cathen/10326c.htm (accessed-March 1, 2009).

40 Winterstein, T.A. 2001. Hydraulic Properties of Mt. Simon Aquifer, Prairie Island Indian

41 Community, Southeastern Minnesota: Water-Resources Investigation Report 02-4263. U.S.

42 Geological Survey. Available URL: http://pubs.usgs.gov/wri/wri024263/pdf/wriO24263.pdf

43 (accessed December 4, 2008).

44 Xcel Energy Environmental Services. 2006. Xcel Energy Prairie Island Nuclear Generating

45 Plant: Design and Construction Technology Plan. Submitted in accordance with the NPDES

October 2009 2-85 Draft NUREG-1437, Supplement 39
Affected Environment

1 final regulations to establish requirements for cooling water intake structures at Phase II existing

2 facilities. NPDES Permit #MN0004005. October 23, 2006.

3

Draft NUREG-1437, Supplement 39 2-86 October 2009
Environmental Impacts of Refurbishment

1

2

3

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6

7

8

9

10

11

12

13

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16

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 for License Renewal of Nuclear Power Plants (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 replacement of 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 draft supplemental environmental

impact statement (SEIS) 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 PINGP I and 2

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

Human Health

Radiation exposures to the public during refurbishment 1

October 2009 3-1 Draft NUREG-1437, Supplement 39
Environmental Impacts of Refurbishment

Issues Category

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

Public Services: Transportation 2

Historic and Archaeological Resources 2

Environmental Justice

Environmental Justice Uncategorized

1 Northern State Power Co. (NSP) plans to replace the two steam generators at Prairie Island

2 Nuclear Generating Plant, Unit 2 with new, once-through, enhanced steam generators to

3 support plant operations through the renewed license period. Steam generators would only be

4 replaced on Unit 2 as the Unit 1 steam generators were replaced in 2004. Accordingly, NSP and

5 the U.S. Nuclear Regulatory Commission (NRC) have analyzed steam generator replacement

6 as a refurbishment activity, pursuant to Title 10, Section 51.53(c)(3)(ii), of the Code of Federal

7 Regulations (10 CFR 51.53(c)(3)(ii)). Unless otherwise noted, the discussion of the

8 refurbishment activities is adapted from the Environmental Report (ER) (NMC 2008) or

9 information gathered during NRC's site audit.

10 3.1 Refurbishment Activities at PINGP 1 and 2

11 Steam generator replacement activities will take approximately 80 days to complete. The

12 replacement steam generators would be manufactured by AREVA in Chalon Saint-Marcel,

13 located in central Eastern France and will be delivered in April-June 2013 and will be installed in

14 August-October 2013 (AREVA 2008). The steam generator replacement will be coordinated

15 with scheduled outage maintenance and refueling. The replacement steam generators will be

16 transported via barge across the Atlantic Ocean and up the Mississippi River. The barge will

17 pass through Lock and Dam 3 and be offloaded at the Prairie Island Nuclear Generating Plant,

18 Units 1 and 2 (PINGP 1 and 2) barge landing, which was used previously for the Unit 1 steam

19 generator replacement in 2004. For transportation within the United States, NSP will be required

20 to meet all Federal, State, and local requirements, such as those that may be applicable to

21 dredge or fill activities. The U.S. Army Corps of Engineers (USACE) will regulate such work

22 pursuant to Section 404 of the Clean Water Act (CWA) and Section 10 of the Rivers and

23 Harbors Act of 1899 if any of the work is performed in "navigable waters."

24 Once on site, the steam generators will be moved via a self-propelled transporter to a temporary

25 building, which will house the replacement steam generators until they are ready for installation.

26 No onsite road improvements would be required to offload the steam generators. Several

Draft NUREG-1437, Supplement 39 3-2 October 2009
Environmental Impacts of Refurbishment

1 additional temporary buildings will be constructed, including office space for construction

2 contractors and a decontamination building. This temporary construction area will be located

3 approximately 100 yds (91 m) northwest of the turbine building. Warehouses will be built for

4 storage purposes during the steam generator replacement and will remain after the steam

5 generator replacement is complete. No construction will take place on previously-undisturbed

6 land. The old steam generators will be transported offsite via rail car for disposal.

7 NSP estimates that additional 750 workers would be required to complete the combined

8 maintenance and refueling and steam generator replacement during the September 2013

9 outage.

10 3.2 Environmental Impacts of Refurbishment

11 The following sections discuss the Category 2 issues associated with refurbishment activities at

12 PINGP 1 and 2. Any environmental impacts from refurbishment will be in addition to those

13 associated with continued operation of PINGP 1 and 2 for the period of license renewal;

14 Chapter 4 of this report discusses those issues.

15 3.2.1 Terrestrial Resources - Refurbishment Impacts

16 The terrestrial resources on and in the vicinity of the PINGP 1 and 2 site are described in

17 Section 2.2.7 of this draft SEIS. Unless otherwise noted, the discussion of the impacts of

18 refurbishment to terrestrial ecology is adapted from the ER (NMC 2008), or information gathered

19 during NRC's site audit.

20 The Unit 2 steam generators replacement project would likely require laydown areas and the

21 construction of temporary structures. An area located approximately 300 ft (90 m) from the

22 turbine building would be used for temporary construction. Temporary construction would

23 include a facility to house the steam generators before the replacement, office space for

24 construction contractors, and a decontamination building. Any warehouses constructed for

25 materials storage would likely remain after the steam generator replacement outage. No

26 permanent storage building would be built because the old steam generators would be disposed

27 of after being removed from Unit 2. All construction activities associated with refurbishment

28 would occur on site and would not impact any previously undisturbed areas. Any ground29 disturbing activities that take place would require the appropriate permits from local, state, and

30 Federal agencies.

31 No road improvements would be required for delivery of the steam generators to PINGP 1 and 2

32 as delivery of the new steam generators would not require extensive overland travel. The new

33 steam generators would be offloaded from a barge to a transporter directly onto the PINGP 1

34 and 2 site.

35 Some noise and construction impacts may impact edge species and wildlife for the period of

36 onsite activity, but these effects will likely be minimal and short term as the proposed

37 refurbishment outage would last a total of approximately 80 days.

38 Based on information from the staff's independent review of NSP's ER for the PINGP 1 and 2

39 proposed license renewal, the staff's site visit, the scoping process, and evaluation of other

40 reports and information, impacts to terrestrial resources during the proposed Unit 2 steam

41 generator replacement would be SMALL. A few mitigation measures that could reduce impacts

42 to the terrestrial environment during construction of the temporary facilities include silt fences to

43 minimize sediment transport, the use of best management practices, and revegetation of

44 cleared land remaining after completion of construction. These mitigation measures could

October 2009 3-3 Draft NUREG-1437, Supplement 39
Environmental Impacts of Refurbishment

1 reduce impacts by reducing erosion and minimizing the movement of sediment, nutrients, and

2 pollutants.

3 3.2.2 Threatened and Endangered Species

4 3.2.2.1 Terrestrial Species

5 The threatened and endangered terrestrial species on or in the vicinity of the PINGP 1 and 2

6 site or along the in-scope transmission line ROWs are described in Section 2.2.7.2 of this draft

7 SEIS. Unless otherwise noted, the discussion of the impacts of refurbishment to threatened and

8 endangered terrestrial species is adapted from the ER (NMC 2008) or information gathered

9 during NRC's site audit.

10 As described in Section 3.2.1 above, all construction activities associated with refurbishment

11 would occur on site and would not impact any previously undisturbed land, and no overland

12 travel or associated road improvements would be required for transportation of the new steam

13 generators to the PINGP 1 and 2 site.

14 Minimal noise and construction impacts may impact edge species and wildlife for the period of

15 onsite activity; however no threatened or endangered species will likely be impacted as a result

16 of refurbishment activities. Though bald eagles (Haliaeetus leucocephalus) are known to nest

17 within the vicinity of the PINGP 1 and 2 site, the species is not likely to be impacted by

18 refurbishment activities because these activities will be confined to the PINGP 1 and 2 site. The

19 pair of peregrine falcons (Falco peregrineus) that nest on Unit 1 are not likely to be affected by

20 the proposed Unit 2 steam generator replacement because the nest is far enough from the

21 ground. In addition, the steam generator replacement is not expected to cause significant noise

22 or other types of disturbance to the birds. Additionally, NSP would undertake the proposed

23 steam generator replacement outside of the falcon breeding period, which generally lasts from

24 March through July.

25 Based on information from the staff's independent review of NSP's ER for the PINGP 1 and 2

26 proposed license renewal, the staffs site visit, the scoping process, and evaluation of other

27 reports and information, impacts to threatened and endangered terrestrial species during the

28 proposed Unit 2 steam generator replacement would be SMALL. A few mitigation measures that

29 could reduce impacts to threatened and endangered terrestrial species include undertaking the

30 steam generator replacement outside of the peregrine falcon breeding season, and minimizing

31 activities that may cause significant noise during midday hours when peregrine falcons are more

32 likely to hunt for food.

33 3.2.2.2 Aquatic Species

34 The threatened and endangered aquatic species in the vicinity of the PINGP 1 and 2 site are

35 described in Section 2.2.7.1 of this draft SEIS. Unless otherwise noted, the discussion of the

36 impacts of refurbishment to aquatic threatened and endangered species is adapted from the ER

37 (NMC 2008), or information gathered during NRC's site audit.

38 As described above, Unit 2 will be receiving replacement steam generators, transported up the

39 Mississippi River by barge, and offloaded directly onto the PINGP 1 and 2 site. Because of the

40 Lock and Dam system on the Mississippi River, designed to allow barges to navigate up the

41 river, no changes to the river or dams are anticipated. Because there is already a cement pad

42 on the shoreline where the steam generators will be offloaded from the barge onto the plant site,

43 there will be little to no change to the shoreline.

44 Based on information from the staffs independent review of NSP's ER for the PINGP 1 and 2

45 proposed license renewal, the staffs site visit, the scoping process, and evaluation of other

Draft NUREG-1437, Supplement 39 3-4 October 2009
Environmental Impacts of Refurbishment

1 reports and information, impacts to aquatic resources during the proposed Unit 2 steam

2 generator replacement would be SMALL. An example of a mitigation measure that could reduce

3 impacts to the aquatic threatened and endangered species during transport and offloading of

4 the steam generators include ensuring that the barges do not approach the site of the Higgins

5 eye relocation project, described in Section 2.2.7.

6 3.2.3 Air Quality During Refurbishment (Non-Attainment and Maintenance Areas)

7 Air quality during refurbishment (nonattainment and maintenance areas) is'a Category 2 issue.

8 Table B-1 of Appendix A to Subpart B, "Environmental Effect of Renewing the Operating

9 License of a Nuclear Power Plant," of 10 CFR Part 51, "Environmental Protection Regulations

10 for Domestic Licensing and Related Regulatory Functions," notes the following:

11 Air quality impacts from plant refurbishment associated with license renewal are

12 expected to be small. However, vehicle exhaust emissions could be cause for

13 concern at locations in or near nonattainment or maintenance areas. The

14 significance of the potential impact cannot be determined without considering the

15 compliance statutes of each site and the numbers of workers expected to be

16 employed during the outage.

17 Specifically, 10 CFR 51.53(c)(3)(ii)(F) requires the following:

18 If the applicant's plant is located in or near a nonattainment or maintenance area,

19 an assessment of vehicle exhaust emissions anticipated at the time of peak

20 refurbishment work force must be provided in accordance with the Clean Air Act

21 (CAA) as amended.

22 The GElS states the following:

23 The 1990 CAA amendments include a provision that no federal agency shall

24 support any activity that does not conform to a state implementation plan

25 designed to achieve the National Ambient Air Quality Standards (NAAQS) for

26 criteria pollutants (sulfur dioxide, nitrogen dioxide, carbon monoxide, ozone, lead,

27 and particulate matter less than 10 pm in diameter). On November 30, 1993, the

28 U.S. Environmental Protection Agency (EPA) issued a final rule (58 FR 63214)

29 implementing the new statutory requirements, effective January 31, 1994. The

30 final rule requires that federal agencies prepare a written conformity analysis and

31 determination for each pollutant where the total of direct and indirect emissions

32 caused by proposed federal action would exceed established threshold emission

33 levels in a nonattainment or maintenance area. An area is designated

34 "nonattainment" for a criteria pollutant if it does not meet the NAAQS for the

35 pollutant. A maintenance area has been redesignated by a State from

36 nonattainment to attainment; the State must submit to EPA a plan for maintaining

37 the NAAQS as a revision to its State Implementation Plan.

38 The steam generator replacement project would result in minor air quality impacts for the

39 duration of the approximately 80-day period needed to complete refurbishment activities. The

40 main sources of air quality impacts would be fugitive dust from construction activities associated

41 with the project, and exhaust emissions from motorized equipment, and vehicles of temporary

42 workers.

43 Although NSP plans to use the existing buildings and structures from the previously completed

44 PINGP 1 and 2, Unit 1 steam generator replacement, some additional temporary structures

45 would be built. These include a facility for preparing the steam generators. The construction of

46 this facility may result in some minor, temporary air quality impacts due to emissions and

October 2009 3-5 Draft NUREG-1437, Supplement 39
Environmental Impacts of Refurbishment

1 fugitive dust from operation of earth-moving and material handling equipment. NSP would use

2 best management practices to minimize fugitive dust and emissions resulting from construction

3 activities. (NMC 2008)

4 NSP indicated that an additional 750 temporary employees would be needed for the steam

5 generator replacement project which is estimated to take 80 days to complete. NSP assumed

6 that the additional temporary workforce would commute from areas within PINGP 1 and 2's 50-

7 miles radius. This would result in an additional 37,500 vehicle miles travelled within the county,

8 which is approximately 2.12 percent of the 1,771,899 average vehicles miles per day for the

9 Goodhue County in 2007. (NMC 2008)

10 Dakota County, located 12 miles northwest of the plant, is the closest maintenance area for

11 lead, sulfur dioxide (SO2) and carbon monoxide (CO). Olmsted County, located 35 miles south

12 of the PINGP 1 and 2 site, is a maintenance area for sulfur dioxide (SO 2) and PM10. Since

13 temporary workforce would be coming from all over the 50-mile region, the additional 37,500

14 vehicle miles travelled would represent 0.35 percent of the total miles traveled in the Dakota

15 County per day and approximately 1 percent of the total miles traveled in the Olmsted County

16 per day, which is a very small fraction of the total miles travelled in these two counties each day.

17 The NRC staff concludes that the impact on air quality of vehicle exhaust emissions and

18 construction activities during the PINGP Unit 2 steam generator replacement project would be

19 SMALL. The NRC staff identified a variety of measures that could mitigate potential air quality

20 impacts resulting from the PINGP 1 and 2, Unit 2, steam generator replacement project. These

21 include the use of the best management practices and implementation of dust control plan to

22 minimize emissions from construction activities, the use of multi-person vans and the

23 implementation of shift changes for the workforce to reduce the number of vehicles on the road

24 at any given time. The NRC staff did not identify any cost-benefit studies applicable to these

25 mitigation measures.

26 3.2.4 Housing Impacts

27 Housing impacts during refurbishment is a Category 2 issue. Table B-1 of 10 CFR Part 51,

28 Subpart A, Appendix B, notes that:

29 Housing impacts are expected to be of small significance at plants located in a

30 medium or high population area and not in an area where growth control

31 measures that limit housing development are in effect. Moderate or large

32 housing impacts of the workforce associated with refurbishment may be

33 associated with plants located in sparsely populated areas or in areas with

34 growth control measures that limit housing development.

35 NSP estimates that steam generator replacement would require a one-time increase in the

36 number of refueling outage workers for up to 80 days at PINGP 1 and 2. Approximately 750

37 workers would be needed to the perform PINGP 1 and 2, Unit 2, steam generator replacement

38 project activities in addition to the normal number of refueling outage workers (NMC 2008).

39 The number of additional workers would cause a short-term increase in the demand for

40 temporary (rental) housing units in the region beyond what is normally experienced during a

41 refueling outage at PINGP 1 and 2. Since PINGP 1 and 2 are located in a high population area

42 (see Section 2.2.8.5) and the number of available housing units has kept pace or exceeded

43 changes in county populations (see Section 2.2.8.1), any changes in employment would have

44 no noticeable effect on the availability of housing in the socioeconomic region of influence

45 (ROI). Because of the short duration of the steam generator replacement activity and the

Draft NUREG-1437, Supplement 39 3-6 October 2009
Environmental Impacts of Refurbishment

1 availability of housing in the region, employment-related housing impacts would have no

2 noticeable impact.

3 3.2.5 Public Services - Education (Refurbishment)

4 Education is a Category 2 refurbishment issue. Table B-1 of 10 CFR Part 51, Subpart A,

5 Appendix B, notes that "[m]ost sites would experience impacts of small significance but larger

6 impacts are possible depending on site- and project-specific factors."

7 As discussed in Section 3.2.4, NSP estimates that the PINGP 1 and 2, Unit 2, steam generator

8 replacement would require a one-time increase in the number of refueling outage workers for up

9 to 80 days at the PINGP 1 and 2 site (NMC 2008). Because of the short duration of the steam

10 generator replacement activity, workers would not be expected to bring families and school-age

11 children with them; therefore, there would be no impact on educational services during this

12 extended refueling outage.

13 3.2.6 Public Services - Public Utilities

14 Public utilities refurbishment is a Category 2 issue. Table B-1 of 10 CFR Part 51, Subpart A,

15 Appendix B, notes that "[a]n increased problem with water shortages at some sites may lead to

16 impacts of moderate significance on public water supply availability."

17 Since there is no water shortage in the region and the public water systems in Goodhue County,

18 Dakota County, and Pierce County have excess capacity, any changes in PINGP 1 and 2

19 employee water usage would have little noticeable affect on public water supply availability in

20 these counties.

21 As discussed in Section 3.2.4, NSP estimates that the PINGP 1 and 2, Unit 2, steam generator

22 replacement would require a one-time increase in the number of refueling outage workers for up

23 to 80 days at the PINGP 1 and 2 site (NMC 2008). The additional number of refueling outage

24 workers needed to replace the steam generators would cause a short-term increase in the

25 amount of public water and sewer services used in the immediate vicinity of PINGP 1 and 2.

26 Since the region has excess water supply capacity with no restrictions, this replacement activity

27 would create no noticeable impact.

28 3.2.7 Public Services - Transportation

29 Transportation is a Category 2 refurbishment issue. Table B-1 of 10 CFR Part 51, Subpart A,

30 Appendix B, notes that:

31 Transportation impacts (level of service) of highway traffic generated during plant

32 refurbishment and during the term of the renewed license are generally expected

33 to be of small significance.

34 However, the increase in traffic associated with additional workers and the local

35 road and traffic control conditions may lead to impacts of moderate or large

36 significance at some sites.

37 As previously discussed in Section 2.2.8.2, the primary access road to PINGP 1 and 2 is County

38 Road 18, which is mostly rural and uncongested. PINGP 1 and 2 has one plant access road via

39 Sturgeon Lake Road and County Road 18. County Road 18 and Sturgeon Lake Road are also

40 access routes to the Prairie Island Indian Community's (PIIC) residential areas, government

41 offices, health clinics, and gaming enterprise, Treasure Island Resort and Casino, located just

42 off Sturgeon Lake Road east of the plant access road (PIIC 2009). NSP employees have the

43 option of exiting the site via Wakonade Drive or the plant access road to Sturgeon Lake Road

October 2009 3-7 Draft NUREG-1437, Supplement 39
Environmental Impacts of Refurbishment

1 and County Road 18. Traffic at the intersections of the plant access road and Sturgeon Lake

2 Road, Wakonade Drive and Sturgeon Lake Road, and Sturgeon Lake Road and County Road

3 18 are controlled by stop signs. Steam generator replacement and refueling outage workers

4 would use the same entrance and exit roads as current PINGP 1 and 2 employees.

5 County Road 18 and Sturgeon Lake Road currently have the capacity to handle the additional

6 volume of traffic. However, due to the lack of timed traffic signals, there could be problems with

7 traffic flow along Sturgeon Lake Road during the PINGP 1 and 2 site refueling outage shift

8 changes. Increased traffic volumes during refueling outages at the PINGP 1 and 2 site,

9 occurring approximately every 20 months, has affected the level of service capacity on Sturgeon

10 Lake Road for short periods of time.

11 Based on this information and because of the short duration of the steam generator

12 replacement activity (up to 80 days), transportation (level of service and noise) impacts in the

13 vicinity of PINGP 1 and 2 would be SMALL to MODERATE and would mostly occur during shift

14 changes. During periods of high traffic volume (i.e., morning and afternoon shift changes), NSP

15 could stagger work schedules and use NSP employees and/or local police officials to direct

16 traffic entering and leaving PINGP 1 and 2 to minimize level of service impacts on Sturgeon

17 Lake Road. In addition, NSP could work with the PIIC to establish additional mitigation

18 measures, such as developing an agreement to coordinate shift changes, coordinate event

19 schedules, identify days where traffic volume will be high, or to use traffic control staff (PIIC

20 2009).

21 3.2.8 Qffsite Land Use (Refurbishment)

22 Offsite land use is a Category 2 refurbishment issue. Table B-1 of 10 CFR Part 51, Subpart A,

23 Appendix B, notes that "impacts may be of moderate significance at plants in low population

24 areas."

25 Since PINGP 1 and 2 are located in a high population area, any changes in the PINGP 1 and 2

26 employment would have little noticeable affect on land use in the region. Because of the short

27 duration of the steam generator replacement activity, the additional number of refueling outage

28 workers would not cause any permanent population- and tax revenue-related land use changes

29 in the immediate vicinity of PINGP 1 and 2.

30 3.2.9 Historic and Archaeological Resources

31 Historic and archaeological resources are a Category 2 refurbishment issue. Table B-1 of 10

32 CFR Part 51, Subpart A, Appendix B, notes that:

33 Generally, plant refurbishment and continued operation are expected to have no

34 more than small adverse impacts on historic and archaeological resources.

35 However, the National Historic Preservation Act requires the Federal agency to

36 consult with the State Historic Preservation Officer to determine whether there

37 are properties present that require protection.

38 Continued operation of PINGP 1 and 2 during the license renewal term would have a

39 MODERATE impact on archaeological resources at the PINGP 1 and 2 site (see section 4.4.5

40 for a detailed discussion). NSP has no plans to alter the PINGP 1 and 2 site for license

41 renewal. Should plans change, further consultation would be initiated by NSP with the NRC,

42 Minnesota Historical Society (MNHS), and the PIIC. Any land disturbing activities would be

43 carried out under corporate procedures.

Draft NUREG-1437, Supplement 39 3-8 October 2009
Environmental Impacts of Refurbishment

1 NSP is in the process of revising its corporate procedures to improve its protection of

2 archaeological resources. Specifically, NSP has proposed to include in its corporate

3 procedures detailed instructions for its employees to follow in the case of unexpected discovery

4 of archaeological resources (Xcel 2009). NSP is currently seeking comment from the MNHS,

5 the Bureau of Indian Affairs, the Office of the State Archaeologist, and the PIIC on its revised

6 procedures.

7 NSP has indicated that the PINGP 1 and 2, Unit 2, steam generators would be replaced. The

8 steam generator replacement project would take place in an area that was previously disturbed

9 by the construction of PINGP 1 and 2. All construction will take place within the existing

10 developed industrial portions of the plant site. Undisturbed areas of the plant site would not be

11 affected (NMC 2008). NSP has contacted the MNHS and the PlIC to inform them of this

12 refurbishment activity. For a map of potentially affected areas, refer to Figure 3.1.

13 Ground disturbing activities associated with the project would include the excavation of

14 previously disturbed areas in the vicinity of PINGP 1 and 2 (NMC 2008). Several temporary

15 buildings would be built, including a facility for preparing the steam generators, office space for

16 construction contractors, and a decontamination building. Warehouse(s) would also be built

17 within the developed portions of the plant to temporarily house the replaced steam generators

18 and would remain after the steam generator replacement outage (NMC 2008). No road

19 improvements would be required because the steam generators would arrive via barge and be

20 offloaded to a self-propelled nuclear transporter capable of traveling on existing site roads

21 without damage. The transporter will move along an existing dirt service road that extends from

22 the barge landing to PINGP 1 and 2, Unit 2. The service road area was previously heavily

23 disturbed during construction of PINGP 1 and 2. Most activities would be temporary and

24 localized. According to NSP, permits and approvals would be obtained from the appropriate

25 Federal, State, and local agencies prior to the moverment of the steam generators.

26 Because any refurbishment work done would primarily be on previously disturbed land, the

27 impacts associated with the replacement of the PINGP 1 and 2, Unit 2, steam generator are not

28 expected to adversely impact historic or archaeological sites located in the vicinity of PINGP 1

29 and 2. Therefore, the potential impacts from this activity on historic or archaeological resources

30 would be SMALL. However, should archaeological resources be encountered during

31 construction, work would cease until NSP environmental personnel perform an evaluation and

32 consider possible mitigation measures through consultation with the NRC, MNHS, and the PIIC.

33 3.2.10 Environmental Justice

34 Environmental justice is a category 2 refurbishment issue and requires an impact assessment.

35 Due to its close proximity to PINGP 1 and 2, the PIIC could be disproportionately affected by

36 steam generator replacement activities. The effects could include transportation and noise

37 impacts during shift changes and the removal. of the old steam generators via rail across the

38 community's only access road to the reservation (Sturgeon Lake Road). As stated in section

39 3.2.8 of this draft SEIS, transportation impacts from refurbishment would be SMALL to

40 MODERATE. These impacts could disproportionately effect the PIIC. The PIC could also

41 experience the effects of increased noise levels from steam generator replacement activities.

42 However, these impacts are of short duration and are not expected to be high.

October 2009 3-9 Draft NUREG-1437, Supplement 39
Environmental Impacts of Refurbishment

1 3.3 Evaluation of New and Potentially Significant Information on Impacts of

2 Refurbishment

3 For all Category 1 issues related to refurbishment, the NRC staff has not identified any new and

4 significant information during its review of the PINGP 1 and 2 ER, the staffs environmental site

5 audit, the scoping process, or the evaluation of other available information, including the site

6 audit during the week of August 18, 2008, during which NSP's refurbishment plans were

7 discussed. Therefore, the NRC staff adopts the findings in the GElS for Category 1 issues

8 associated with refurbishment, and concludes that there would be no environmental impacts

9 during the renewal term beyond those discussed in the GElS for these issues.

10 3.4 Summary of Impacts of Refurbishment

11 For the nine Category 2 issues and environmental justice, the impacts of refurbishment at

12 PINGP 1 and 2 range from no impact to a MODERATE impact. For the refurbishment issues

13 Public Services: Education, Offsite Land Use, and Environmental Justice, the NRC staff

14 concludes that there would be a SMALL to MODERATE impact. For the refurbishment issues

15 Terrestrial Ecology, Threatened or Endangered Species, Air Quality (Nonattainment and

16 Maintenance Areas), Housing Impacts, Public Services: Public Utilities, Public Services:

17 Transportation, and Historic and Archeological Resources, the NRC staff concludes that the

18 potential environmental effects are SMALL to MODERATE.

19

Draft NUREG-1437, Supplement 39 3-10 October 2009
Environmental Impacts of Refurbishment

0~ 3M amF ý t Figure 3-1. Potential Areas Impacted by Unit 2

Steam Generator Replacement (Source: NMC 2008)

1 inch = 800 feet 1:9.600 I DATE: 02111109 J REVISED: 02/11109 I DRAWN BY: MLTehchertl

1

2

October 2009 3-11 Draft NUREG-1437, Supplement 39
Environmental Impacts of Refurbishment

1 3.5 References

2 10 CFR 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental Protection

3 Regulations for Domestic Licensing and Related Regulatory Functions."

4 40 CFR 51.850. Code of Federal Regulations, Title 40, Protection of Environment, Part 51,

5 "Requirements for Preparation, Adoption, and Submittal of Implementation Plans."

6 58 FR 63214. U.S. Environmental Protection Agency. Final General Conformity Regulations.

7 November 30, 1993.

8 AREVA. 2006. "Press Release: AREVA Wins Contract for Two Replacement Steam Generators

9 at Prairie Island Nuclear Generating Plant." Available URL: http://www.areva10 np.com/scripts/press/publigen/content/templates/show.asp?P=795&L=US (accessed November

11 25, 2008). ADAMS No. ML083310148.

12 NMC (Nuclear Management Company, LLC). 2008. Prairie Island Nuclear Generating Plant,

13 Units 1 and 2, License Renewal Application, Appendix E - Applicant's Environmental Report,

14 License Renewal Operating Stage. Redwing, Minnesota. April 2008. ADAMS Nos.

15 ML081130677, ML081130681, and ML081130684.

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

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

18 ADAMS Nos. ML040690705 and ML040690738.

19 NRC (U.S. Nuclear Regulatory Commission). 1999. Generic Environmental Impact Statement

20 for License Renewal of Nuclear Plants, Main Report, "Section 6.3-Transportation, table 9.1,

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

22 Report." NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

23 PIIC (Prairie Island Indian Community). 2008. Information provided by the Prairie Island Indian

24 Community (PIIC) will aid NRC staff in the preparation of the Supplemental EIS (SEIS). PIIC

25 Supplemental Information. Non-public reference per 36 CFR 800.11(c).

26 PIIC (Prairie Island Indian Community). 2009. Information provided by the Prairie Island Indian

27 Community (PIIC). PIIC Supplemental Information. Non-public reference per 36 CFR 800.11(c).

28 Xcel (Xcel Energy). 2009. Letter from M. Wadley, Site Vice President, Prairie Island Nuclear

29 Generating Plant, Units 1 and 2, Welch, Minnesota, to U.S. Nuclear Regulatory Commission,

30 Washington, D.C. Subject: Reply to Revisions to Environmental Report Regarding Application

31 for Renewed Operating Licenses. March 4, 2009. ADAMS No. ML090750915

32

Draft NUREG-1437, Supplement 39 3-12 October 2009
Environmental Impacts of Operation

1 4.0 ENVIRONMENTAL IMPACTS OF OPERATION

2 This chapter addresses potential environmental impacts related to the period of extended

3 operation of Prairie Island Nuclear Generating Plant, Units 1 and 2 (PINGP 1 and 2). These

4 impacts are grouped and presented according to resource. Generic issues (Category 1) rely on

5 the analysis provided in the Generic Environmental Impact Statement for License Renewal of

6 Nuclear Power Plants (GELS) prepared by the U.S. Nuclear Regulatory Commission (NRC)

7 (NRC 1996; 1999) and are discussed briefly. NRC staff analyzed site-specific issues (Category

8 2) for PINGP 1 and 2 and assigned them a significance level of SMALL, MODERATE, or

9 LARGE. Some remaining issues are not applicable to PINGP 1 and 2 because of site

10 characteristics or plant features. Section 1.4 of this report explains the criteria for Category 1

11 and Category 2 issues and defines the impact designations of SMALL, MODERATE, and

12 LARGE.

13 4.1 Land Use

14 Land use issues are listed in Table 4-1. The staff did not identify any Category 2 issues for land

15 use. The staff also did not identify any new and significant information during the review of the

16 applicant's environmental report (ER) (NMC 2008), the site audit, or the scoping process.

17 Therefore, there are no impacts related to these issues beyond those discussed in the GELS.

18 For these issues, the GElS concludes that the impacts are SMALL, and additional site-specific

19 mitigation measures are not likely to be warranted.

20 Table 4-1. Land Use Issues. Section 2.2.1 of this report describes the land use around

21 PINGP I and 2.

Issues GElS Section Category

Onsite land use 4.5.3 1

Power line right-of-way 4.5.3 1

22 4.2 Air Quality

23 The air quality issue applicable to PINGP 1 and 2 is listed in Table 4-2. The staff did not identify

24 any Category 2 issues for air quality. The staff also did not identify any new and significant

25 information during the review of the applicant's ER (NMC 2008), the site audit, or the scoping

26 process. Therefore, there are no impacts related to this issue beyond those discussed in the

27 GELS. For these issues, the GElS concludes that the impacts are SMALL, and additional site28 specific mitigation measures are not likely to be warranted.

29 Table 4-2. Air Quality Issue. Section 2.2.2 of this report describes air quality in the

30 vicinity of PINGP I and 2.

Issue GElS Section Category

Air quality effects of transmission lines 4.5.2 1

October 2009 4-1 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

1 4.3 Ground Water

2 The following sections discuss the Category 2 ground water issues applicable to PINGP 1 and

3 2, which are listed in Table 4-3.

4 Table 4-3. Ground Water Use and Quality Issues. Section 2.2.3 of this report

5 discussed ground water use and quality at PINGP I and 2.

Issues GElS Section Category

Ground Water use conflicts (potable and service water, plants 4.8.1.1 2

using >100 gpm)

Ground Water use conflicts (plants using cooling towers 4.8.1.3 2

withdrawing make-up water from a small river)

6 4.3.1 Ground Water Use Conflicts (plants using >100 gpm)

7 NRC specifies as issue 33 in 10 CFR 51, Subpart A, Appendix B, Table B-1, that "[if] the

8 applicant's plant... pumps more than 100 gallons [6.3 x 103 m3

/day] (total onsite) of groundwater

9 per minute (gpm), an assessment of the impact of the proposed action on groundwater use

10 must be provided." The NRC further states in 10 CFR 51.53(c)(3)(ii)(C), that "plants that use

11 more than 100 gpm may cause groundwater use conflicts with nearby groundwater users." This

12 applies to PINGP 1 and 2 because, as discussed in section 2.2.3.1 of this report, though PINGP

13 1 and 2 averaged 92 gpm (5.8 x 10-3 m3/s) annually from 2000 to 2005, in 2005, PINGP 1 and 2

14 pumped 118 gpm (7.4 x 10-3 m3/day).

15 A groundwater withdrawal rate of over 100 gpm (6.3 x 10-3 m3/day) has the potential to create a

16 cone of depression large enough to affect offsite wells and groundwater supplies, limiting the

17 amount of groundwater available for the plant's surrounding areas. To determine potential

18 impacts, the drawdown rate of 2005 groundwater use was calculated as if it were pumped from

19 a single onsite well. Using conservative values for recharge, a drawdown of 0.4 ft (0.1 m) for a

20 2100 ft (640 m) radius during the plant's first 10 operating years was calculated. No additional

21 drawdown would occur during the license renewal period. (TtNUS 2006)

22 In addition to these calculations, most nearby offsite wells draw water from the Mount Simon

23 aquifer in the Dresbach formation, while PINGP 1 and 2 draws water from the much shallower

24 alluvial aquifer. The Cowdery (1999) study indicates these aquifers have minimal water

25 exchange, so water drawn from the surficial aquifer is not expected to impact water drawn from

26 the Mount Simon aquifer.

27 After reviewing the information provided by the applicant as well as the drawdown calculations,

28 which show no effect on nearby groundwater wells during the license renewal period, the

29 impacts on nearby groundwater users will be SMALL.

30 4.3.2 Ground Water Use Conflicts (make-up from a small river)

31 NRC specifies in 10 CFR 51.53(c)(3)(ii)(A) that "if the applicant's plant utilizes cooling towers or

32 cooling ponds and withdraws makeup water from a river whose annual flow rate is less than

33 3.15 x 1012 cubic feet per year (ft3/yr) [99,885 cubic feet per second (cfs)]... [t]he applicant shall

34 also provide an assessment of the impacts of the withdrawal of water from the river on alluvial

35 aquifers during low flow." For water use conflicts, the NRC further states as issue 34 in 10 CFR

36 Part 51, Subpart A, Appendix B, Table B-1, that "...[w]ater use conflicts may result from surface

Draft NUREG-1437, Supplement 39 4-2 October 2009
Environmental Impacts of Operation

1 water withdrawals from small water bodies during low flow conditions which may affect aquifer

2 recharge, especially if other groundwater or upstream surface water users come online before

3 the time of license renewal..." This issue is applicable to PINGP 1 and 2 because the plant uses

4 cooling towers, and makeup water for its cooling systems is withdrawn from the Mississippi

5 River, which has an annual mean flow of approximately 18,380 cfs (5.8 x 1011 ft 3

/yr; 8.25 x 106

6 gpm), thus meeting the NRC's definition of a small river (TtNUS 2006). Flow is monitored at the

7 Prescott U.S. Geological Survey (USGS) Station, upstream of the PINGP 1 and 2 site.

8 Consumptive water losses at PINGP 1 and 2 comprise a small fraction of the Mississippi River

9 flow at Lake Sturgeon where PINGP 1 and 2 is situated. PINGP 1 and 2 withdraws surface

10 water at an average rate of 381,031 gpm (849 cfs; 24 m3

/s), which is about 11 percent of the

11 lowest annual mean flow of the Mississippi River and approximately 4.6 percent of the average

12 river flow. The rate of consumptive water use at the plant is 39 cfs (1.1 m3/s), which is the

13 recorded difference between the plant's surface water withdrawal and the blowdown discharge

14 from the plant back to the Mississippi. The consumptive use of PINGP 1 and 2 is only 0.2

15 percent of the average annual flow of the Mississippi River, and 0.5 percent of the lowest annual

16 mean recorded at the Prescott USGS monitoring station. (TtNUS 2006)

17 After reviewing the information provided by the applicant as well as the consumptive use

18 calculations above, the NRC staff concludes that the impacts from consumptive water use on

19 groundwater would be SMALL.

20 4.4 Surface Water

21 The following sections discuss the surface water quality issues applicable to PINGP 1 and 2,

22 which are listed in Table 4-4. For the Category 1 issues, the staff did not identify any new and

23 significant information during the review of the applicant's ER (NMC 2008), the site audit, or the

24 scoping process. Therefore, no impacts are related to these issues beyond those discussed in

25 the GELS. For these issues, the GElS concludes that the impacts are SMALL, and additional

26 site-specific mitigation measures are not likely to be warranted.

27 Table 4-4. Surface Water Quality Issues. Section 2.2.4 of this report describes

28 surface water quality conditions at PINGP 1 and 2.

Issues GElS Section Category

Altered current patterns at intake and discharge structures 4.2.1.2.1 1

Altered salinity gradients 4.2.1.2.2 1

Temperature effects on sediment transport capacity 4.2.1.2.3 1

Scouring caused by discharged cooling water 4.2.1.2.3 1

Eutrophication 4.2.1.2.3 1

Discharge of chlorine or other biocides 4.2.1.2.4 1

Discharge of sanitary wastes and minor chemical spills 4.2.1.2.4 1

Discharge of other metals in wastewater 4.2.1.2.4 1

Water use conflicts (plants with cooling ponds or cooling 4.3.2.1; 4.4.2.1 2

towers using make-up water from a small river with low flow)

October 2009 4-3 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

1 4.4.1 Water Use Conflicts

2 NRC specifies in 10 CFR 51.53(c)(3)(ii)(A) that "if the applicant's plant uses cooling towers or

3 cooling ponds and withdraws makeup water from a river whose annual flow rate is less than

4 3.15 x 1012 t

3

/yr (99,885 cfs), an assessment of the impact of the proposed action on the flow of

5 the river and related impacts on instream and riparian ecological communities must be

6 provided." For water use conflicts, the NRC further states as issue 13 in 10 CFR Part 51,

7 Subpart A, Appendix B, Table B-i, "[the] issue has been a concern at nuclear power plants with

8 cooling ponds and at plants with cooling towers. Impacts on instream and riparian communities

9 near these plants could be of moderate significance in some situations." This issue is applicable

10 to PINGP 1 and 2 because the plant uses a cooling tower-based heat dissipation system, and

11 makeup water to replace that lost to evaporation in the cooling system is withdrawn from the

12 Mississippi River, which has an annual mean flow of approximately 18,380 cfs (5.8 x 1011 ft3/yr;

13 8.25 x 106 gpm), thus meeting the NRC's definition of a small river (TtNUS 2006).

14 The GElS considered surface water use conflicts to be a Category 2 issue for two separate

15 reasons:

16 1) Consumptive water use can adversely affect riparian vegetation and instream

17 aquatic communities in the stream. Reducing the amount of water available

18 to either the riparian zones or instream communities could result in impacts to

19 threatened and endangered species, wildlife, and recreational uses of the

20 water body. In addition, riparian vegetation performs several important

21 ecological functions, included stabilizing channels and floodplains, influencing

22 water temperature and quality, and providing habitat for aquatic and

23 terrestrial wildlife.

24 2) Continuing operation of these facilities depends on the availability of water

25 within the river from which they are withdrawing water. For facilities that are

26 located on small bodies of water, the volume of water available is expected to

27 be susceptible to droughts and to competing water uses within the basin. In

28 cases of extreme drought, these facilities may be required to curtail

29 operations if the volume of water available is not sufficient.

30 An additional potential effect of the withdrawal of water from a small river is that withdrawal may

31 have an impact on groundwater levels and, therefore, result in groundwater use conflicts (NRC

32 1996). This is considered to be a separate Category 2 issue and is evaluated in Section 4.3.2 of

33 this report.

34 Withdrawal from PINGP 1 and 2 is about 11 percent of the lowest annual mean flow of the

35 Mississippi River and approximately 4.6 percent of the average river flow. The rate of

36 consumptive water use is only 0.2 percent of the average annual flow of the Mississippi River

37 and 0.5 percent of the lowest annual mean recorded at the Prescott USGS monitoring station.

38 These consumptive losses are insignificant relative to the flow in the Mississippi River and

39 would not be expected to impact the river's aquatic and riparian ecological communities or the

40 alluvial water bearing material (aquifers).

41 The NRC staff reviewed available information, including that provided by the applicant,

42 additional Minnesota Department of Natural Resources (MNDNR) data, information gathered at

43 the site audit and through the scoping process, and other available sources. Considering PINGP

44 1 -and 2's small consumptive water use relative to the flows in the Mississippi River, the NRC

45 staff concludes that the impact of water use on the Mississippi River at PINGP 1 and 2 would be

46 SMALL.

Draft NUREG-1437, Supplement 39 4-4 October 2009
Environmental Impacts of Operation

1

2

3

4

5

4.5 Aquatic Resources

The Category 1 and Category 2 issues related to aquatic resources applicable to PINGP 1 and

2 are discussed below and listed in Table 4-5.

Table 4-5. Aquatic Resources Issues. Section 2.1.6 of this report describes the

PINGP I and 2 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 Once-Through Heat Dissipation Systems

Entrainment of fish and shellfish in early life stages 4.3.3 2

Impingement of fish and shellfish 4.3.3 2

Heat shock 4.3.3 2

6 4.5.1 Generic Aquatic Ecology Issues

7 The NRC staff did not identify any new and significant information related to Category 1 aquatic

8 issues during the review of the applicant's ER (NMC 2008), the site audit, or the scoping

9 process. Therefore, there are no impacts related to these issues beyond those discussed in the

10 GELS. For these issues, the GElS concludes that the impacts are SMALL, and additional site11 specific mitigation measures are not likely to be warranted.

12 4.5.2 Entrainment and Impingement

13 For power plants with once-through cooling systems, the impingement of fish and shellfish on

14 screens associated with plant cooling systems and the entrainment of fish and shellfish in early

15 life stages by plant cooling systems are considered Category 2 issues, which require a site16 specific assessment before license renewal. PINGP 1 and 2 operate in a closed-cycle mode

17 part of the year, during which time impingement and entrainment are considered a Category 1

18 issue. The helper-cycle mode is not discussed in the GElS (NRC 1996), nor is it classified as

19 either a Category 1 or 2 issue. To be conservative, the NRC staff considered impingement and

20 entrainment at PINGP 1 and 2 as a Category 2 issue and undertook an assessment of

21 impingement and entrainment for the entire year under all three operating modes. To perform

22 this evaluation, the NRC staff reviewed the applicant's ER (NMC 2008) and related documents,

23 including the Clean Water Act (CWA) Section 316 demonstrations (NUS Corporation 1976; Xcel

October 2009 4-5 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

1 Energy Environmental Services 2006) and visited the PINGP 1 and 2 site. The NRC staff also

2 reviewed the applicant's most recent National Pollutant Discharge Elimination System (NPDES)

•3 Permit No. MN0004006 issued on June 30, 2006, by the Minnesota Pollution Control Agency

4 (MPCA).

5 Section 316(b) of the CWA requires that the location, design, construction, and capacity of the

6 cooling water intake structures reflect the best technology available for minimizing adverse

7 environmental impacts (33 USC 1326). Impingement and entrainment of fish and shellfish by

8 the cooling water system is a potential adverse environmental impact that can be minimized by

9 the use of the best technology available.

10 The original 316(b) demonstration for PINGP 1 and 2 was submitted to MPCA in 1976 (NUS

11 Corporation 1976). At this time, the plant was designed to operate in the three cooling modes

12 (closed, helper, open), but only operated in closed-cycle mode "to the maximum extent

13 practicable" (AEC 1973). Additionally, the original design used only coarse mesh traveling

14 screens. MPCA issued the NPDES permit No. MN0004006 in 1981, dictating changes to the

15 cooling system technology and operation (MPCA 1981).

16 Changes to the cooling system technology included the alteration or replacement of the cooling

17 water intake structure to minimize entrainment and impingement mortality; the installation of fine

18 mesh screens, fish buckets, and a fish return system; and design criteria limiting the screen face

19 velocity to 0.5 fps at a discharge rate of 800 cubic fps while the fine mesh screens were in use.

20 The applicant completed the modifications to the cooling system by 1983 (NMC 2008).

21 Changes to the operation of the cooling system included limits on plant flow and withdrawal

22 between April 1 and June 30, after completion of the new cooling water intake structure; the use

23 of the fine mesh screens from April 16 to August 31 (although the current permit sets the start

24 date as April 1); and the implementation of studies to evaluate the effectiveness of the new

25 cooling system (NMC 2008; MPCA 2006). The NPDES permit also specifies the conditions for

26 the three different cooling system modes, which will be discussed in Section 4.5.5.

27 On July 9, 2004, the U.S. Environmental Protection Agency (EPA) published a final rule in the

28 Federal Register (69 FR 41575) that addresses cooling water intake structures at existing power

29 plants, including PINGP 1 and 2, where flow levels exceed a minimum threshold value of 50

30 million gpd. The rule is Phase II in the EPA's development of CWA 316(b) regulations that

31 establish national requirements applicable to the location, design, construction, and capacity of

32 cooling water intake structures at existing facilities that exceed the threshold values for water

33 withdrawals. The national requirements, which were to be implemented through the NPDES

34 permitting process, minimize the adverse environmental impacts associated with the continued

35 use of the intake systems.

36 Under the Phase II rule, licensees would have been required to demonstrate compliance with

37 the Phase II performance standards at the time of renewal of the NPDES permit. As part of the

38 NPDES renewal, licensees may have been required to alter the intake structure, redesign the

39 cooling system, modify station operation, or take other mitigative measures to comply with this

40 regulation. The new performance standards were designed to significantly reduce impingement

41 mortality and entrainment due to water withdrawals associated with cooling water intake

42 structures used for power production. Any additional site-specific mitigation required as a result

43 of the 316(b) Phase 11 reviews would result in less impact from impingement and entrainment

44 during the license renewal period.

45 Effective July 9, 2007, the EPA suspended the Phase II rule (72 FR 37109). As a result, all

46 permits for Phase II facilities should include conditions under Section 316(b) of the CWA that

47 are developed on a Best Professional Judgment basis, rather than best technology available.

Draft NUREG-1437, Supplement 39 4-6 October 2009
Environmental Impacts of Operation

1 Best Professional Judgment is used by the NPDES permit writers to develop technology-based

2 permit conditions on a case-by-case basis using all reasonably available and relevant data. Any

3 site-specific mitigation required under the NPDES permitting process would result in a reduction

4 in the impacts of continued plant operations.

5 When the current NPDES permit was issued in 2006, the 316(b) Phase II rule was still in effect,

6 and the permit required Northern States Power Co. (NSP) to submit documents including a

7 comprehensive demonstration study to characterize entrainment and impingement mortality and

8 show that the changes to technology and operation of the cooling system satisfied the

9 performance standards of the Phase II rule. NSP submitted the required documents on time;

10 however, as described above, the Phase II rule was suspended in 2007 before MPCA issued a

11 316(b) determination for PINGP 1 and 2. At the time this draft was published, EPA had not put

12 in place new regulations, and until it does, it is unlikely that MPCA will review the submitted

13 documents. PINGP 1 and 2 will continue to operate under the existing 2006 NPDES permit,

14 unless otherwise directed by the State of Minnesota.

15 Baseline monitoring for impingement was conducted three days a week from 1973 through 1980

16 at PINGP 1 and 2; from 1981 through 1984, the samples were taken three days every other

17 week. Samples were taken by emptying the trash baskets, separating out debris, and counted

18 based on taxonomy. Both living and dead organisms were included in the impingement totals,

19 and counts were doubled for years 1981 to 1984 to account for the biweekly collection (Table 4-

20 6). Based on the table presented in the Impingement Mortality and Entrainment Characterization

21 Study (Xcel Energy Environmental Services 2006), the total annual impingement at PINGP 1

22 and 2 during the years before the changes to equipment and operation took effect ranged from

23 approximately 24,967 fish (in 1979) to 554,590 fish (in 1977); the average impingement over

24 those 12 years was 164,629 fish per year. Gizzard shad had the highest impingement,

25 comprising an average of about 80 percent of the total number impinged (Xcel Energy

26 Environmental Services 2006). Neither the original 316(b) demonstration (NUS 1976) nor the

27 Impingement Mortality and Entrainment Characterization Study (Xcel Energy Environmental

28 Services 2006) provide the mortality rates from these baseline studies, except to note that live

29 impinged organisms were counted and returned to the river.

30 Table 4-6. Estimated Number of Fish Impinged at PINGP 1 and 2, 1973-1984

Year Total Number Gizzard Shad Percent Gizzard Shad

1973 69,226 65,000 93.90

1974 146,063 136,667 93.57

1975 93,324 70,506 75.55

1976 261,295 152,878 58.51

1977 554,590 456,949 82.39

1978 105,983 93,895 88.59

1979 24,967 9,381 37.57

1980 110,764 97,840 88.33

1981 54,376 47,966 88.21

1982 121,896 67,338 55.24

1983 222,478 171,972 77.30

1984 210,590 203,956 96.85

October 2009 4-7 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

TOTAL 1,975,552 1,574,348 79.69

Source: Adapted from Xcel Energy Environmental Services 2006

1 The baseline studies for entrainment were conducted in 1974 and 1975. Abundance was

2 estimated for larval fish and eggs in the vicinity of Prairie Island, although the individual species

3 were not identified. NUS Corporation conducted entrainment monitoring in 1975 from May into

4 September and estimated that PINGP 1 and 2 entrained 8,371,000 fish eggs and 61,645,00

5 larval and juvenile fish were entrained during the sample period (NUS 1976). The authors of the

6 study concluded that the entrainment of these eggs and larvae represented a loss of 2,830,000

7 adult fish, an overwhelming percentage of which were forage fish. (Xcel Energy Environmental

8 Services 2006)

9 The new screenhouse was installed in 1983 and, in the spring of 1984, the fine-mesh screens

10 were placed into operation. Because of the finer mesh, the eggs, larvae, small juveniles, and

11 even some smaller adults, which in previous years would have been entrained, were now

12 impinged on the screens, washed into the fish return system, and discharged into the river.

13 Increased impingement meant that entrainment rates were dramatically reduced. In 1984,

14 samples were taken from the back wash of the fine-mesh screens and compared to the

15 impingement samples. The Impingement Mortality and Entrainment Characterization Study

16 found that, based on this data, the front spray wash was over 98 percent effective in minimizing

17 entrainment (Xcel Energy Environmental Services 2006). However, this reduction in entrainment

18 translates to a dramatic increase in impingement, as described below.

19 The impingement verification study was conducted by sampling the impingement on the fine20 mesh screens from 1984 through 1988, April through August. A quarter of the screen wash

21 water was diverted into collection tanks in the environmental lab to assess the number

22 impinged, determine taxonomy and age of impinged fish, and monitor initial and latent survival.

23 Based on the data from the verification studies, estimates for the weekly and annual number of

24 impinged organisms were extrapolated. In 1984, the estimated impingement during the months

25 April through August was 492.8 million organisms. However, the group responsible for the 1984

26 sampling hypothesized that this was a gross overestimate of impingement, due to a sampling

27 equipment design - the pipe from the screenhouse was not flushed before samples were taken,

28 allowing any organisms in the pipe prior to sampling to be included in the counts. This meant

29 that the sample counts included organisms that were not entrained during the sampling time

30 period, and when these counts were extrapolated to daily totals, the estimate was unrealistically

31 high (NSP 1985). Therefore, the sampling equipment was redesigned in 1985. The following

32 years showed a 10-fold decrease in the estimated impingement levels: 42.5 million (1985), 62.7

33 million (1986), 77.1 million (1987), and 67.2 million (1988). The estimated impingement during

34 the months April though August of 1984 through 1988, based on the verification studies, is

35 presented in Table 4-7 and is broken down into life stages. (Xcel Energy Environmental

36 Services 2006)

37 The average of the estimated number of eggs impinged during the spring and summer months

38 when the fine mesh screens were in place, excluding data from 1984, was about 12.5 million,

39 and the average level of impingement for larvae (prolarvae and postlarvae combined) per year

40 was approximately 46 million. In the 1975 baseline study for entrainment, NUS estimated just

41 over 8 million eggs and 61.5 million larvae were entrained. Annual fluctuations in impingement

42 levels, as shown in Tables 4-6 and 4-7, suggest that the difference between the baseline and

43 verification studies could be due to annual changes in the number of eggs and larvae present in

44 the river, and in fact, more eggs were impinged on average during the verification studies than

45 had been entrained during the baseline study.

Draft NUREG-1437, Supplement 39 4-8 October 2009
Environmental Impacts of Operation

1 Numbers of adults impinged by the fine mesh screens are far lower than the total number of fish

2 impinged during the baseline studies, although from the data, the NRC staff could not determine

3 what percentage of the baseline impinged fish were adults, as some juveniles would have been

4 impinged as well. Likewise, staff found it difficult to compare the numbers of impinged juveniles

5 from the verification studies to the impingement totals from the baseline studies. However, staff

6 assumed that many juveniles that had head-on dimensions smaller than 3/8 in. would have

7 been entrained prior to the installation of fine mesh screens.

8 For the impingement mortality and entrainment characterization study, Xcel Energy

9 Environmental Services (2006) calculated the survivorship of the impinged fish using only the

10 juvenile or larger fish that would have been impinged on the coarse mesh screens. The total

11 survivorship based on the study years 1984 through 1988 was 71.5 percent. When adjusted to

12 account for sampling-induced mortality, Xcel Energy Environmental Services calculated that the

13 survivorship rises to 80 percent. The original intake structure had no fish return system, only

14 trash baskets, and therefore impingement survivorship can be assumed to have been zero,

15 although the characterization study does note that organisms that were alive when collected for

16 impingement monitoring were released to the river.

October 2009 4-9 Draft NUREG-1437, Supplement 39
1

2

Environmental Impacts of Operation

Table 4-7. Estimated Number and Percent Composition of Fish Life Stages Impinged on Fine Mesh Screens April

through August, 1984-1988

1984 1985 1986 1987 1988

Percent in Percent Pecn ercent Percent

Life Stage Number yer Number Percear Number yercent Number Percear Number Percear

year in year in year in year in year

eggs 11,882,792 2.41 17,534,761 41.27 6,504,222 10.36 14,271,422 18.50 12,221,440 18.19

prolarvae 100,116,592 20.32 16,405,893 38.61 40,908,477 65.19 31,886,239 41.33 32,137,280 47.83

postlarvae 17,311,818 3.51 5,326,535 12.54 13,283,595 21.17 28,844,661 37.39 15,944,768 23.73

juveniles 363,039,236 73.67 3,096,336 7.29 1,963,864 3.13 2,125,830 2.76 6,567,904 9.78

adults 396,573 0.08 2,688 0.01 8,848 0.01 16,548 0.02 315,840 0.47

unidentified 71,624 0.01 120,816 0.28 84,045 0.13 0.00 0.00 0.00 0.00

TOTAL 492,818,635"'J 100.00 42,487,029 100.00 62,753,051 100.00 77,144,700 100.00 67,187,232 100.00

(')Data from 1984 was an overestimate due to sampling equipment design (Xcel Energy Environmental Services 2006).

Source: Adapted from Xcel Energy Environmental Services 2006

Draft NUREG-1437, Supplement 39 4-10 October 2009
Environmental Impacts of Operation

1 Based on the changes to PINGP 1 and 2's cooling system since the mid-1 980s, the use of fine2 mesh screens during sensitive times of year, the use of closed- and helper-cycle cooling modes,

3 and the reduction in flows from April through June, as well as the data presented in the CWA

4 Section 316 demonstrations, which show a reduction in impingement mortality and entrainment

5 after the installation of new intake structures (NUS Corporation 1976; Xcel Energy

6 Environmental Services 2006), the NRC staff determined that the potential impacts of

7 impingement and entrainment of fish and shellfish by the PINGP 1 and 2 cooling system during

8 the 20-year renewal period would be SMALL. PINGP 1 and 2 currently employ a number of

9 mitigation measures, including using closed and helper cycle cooling, fine-mesh screens, and

10 flow limitations. Additional mitigative measures that PINGP 1 and 2 could add include operating

11 in closed cycle more often, using the fine-mesh screens for a longer period of time, reducing

12 intake velocities, and operating under reduced intake flows. The staff did not identify any cost

13 benefit studies applicable to these mitigation measures. It is the responsibility of the MPCA to

14 impose any restrictions or modifications to the cooling system to reduce the impact of

15 entrainment and impingement under the NPDES permitting process.

16 4.5.3 Heat Shock

17 The NRC defines heat shock as acute thermal stress caused by exposure to a sudden elevation

18 of water temperature that adversely affects the metabolism and behavior of fish and can lead to

19 death. At power plants, heat shock is most likely to occur when an offline unit returns to service

20 or when a station has a discharge canal that effectively traps heated water in a smaller area

21 then would a discharge point directly on a river or lake. For plants with once-through cooling

22 systems, the impacts of heat shock are listed as a site specific, or Category 2 issue, and require

23 a plant-specific evaluation before license renewal, because of continuing concerns about acute

24 thermal-discharge impacts and the possible need to modify thermal discharges in the future in

25 response to changing environmental conditions (NRC 1996). PINGP 1 and 2 operate in a

26 closed-cycle mode part of the year, during which time heat shock is categorized as a Category 1

27 issue. The helper-cycle mode is not discussed in the GElS (NRC 1996), nor is it classified as

28 either a Category 1 or 2 issue. To be conservative, the NRC staff considered heat shock at

29 PINGP 1 and 2 as a Category 2 issue and undertook an assessment of heat shock for the entire

30 year under all three operating modes.

31 To perform this evaluation, the NRC staff reviewed the applicant's ER (NMC 2008) and related

32 documents, including the CWA Section 316 demonstrations (HDR 1978), and visited the PINGP

33 1 and 2 site. The NRC staff also reviewed the applicant's most recent NPDES Permit No.

34 MN0004006 issued on June 30, 2006, by the MPCA (MPCA 2006).

35 Section 316(a) of the CWA establishes a process by which a discharger can demonstrate that

36 the established thermal discharge limitations are more stringent than necessary to protect

37 balanced, indigenous populations of fish and wildlife and obtain facility-specific thermal

38 discharge limits (33 USC 1326). In 1978, Henningson, Durham, and Richardson, Inc., provided

39 MPCA with a Section 316(a) demonstration that addressed compliance with the thermal effluent

40 limitations of the NPDES permit and environmental impacts of the thermal discharge (HDR

41 1978).

42 For the demonstration, Henningson, Durham, and Richardson, Inc., modeled the thermal plume

43 for typical and extreme environmental conditions, including both two- and three-dimensional

44 models. In 13 of the 61 cases modeled, the plume exceeded the NPDES thermal limits that had

45 been proposed, and 11 of these cases were for "typical" environmental conditions. Therefore,

46 the 316(a) demonstration stated that a variance to the proposed NPDES permit would be

47 necessary to meet thermal criteria, or else the plant would have to be derated. The suggested

48 variance was an extension of the mixing zone boundary from October through March. The

October 2009 4-11 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

1 summary conclusion of the 316(a) was that the thermal discharge of PINGP 1 and 2 would not

2 "cause appreciable harm to any aquatic biota and the protection and propagation of a balance,

3 indigenous biota has been maintained." (HDR 1978)

4 In response to the 316(a) demonstration, MPCA issued the NPDES permit in 1981 for PINGP 1

.5 and 2. The permit stated that PINGP 1 and 2 required a new discharge structure. It also

6 specified changes to the operation of PINGP 1 and 2, including that the cooling towers be

7 operated to the maximum extent practicable from April 1 to November 30, new thermal limits for

8 the spring and summer months and fall and winter months, that the operators of PINGP 1 and 2

9 minimize to the extent practicable abrupt temperature changes, and that the river temperature

10 below Lock and Dam 3 be monitored continuously. The requirements of the current NPDES

11 permit are summarized in Section 2.1.6.3. (NMC 2008)

12 The new discharge structure was completed in 1983, along with the new intake structure as

13 described in Section 4.5.2. The design of the new discharge had several goals: promote mixing

14 of discharged and receiving waters, eliminate recirculation of heated discharge into intake,

15 minimize cold shock potential, and prevent fish from entering discharge pipes (discharge rate is

16 8 to 10 fps) (Stone and Webster 1983).

17 During the spring and summer months (from April 1 through the fall trigger point, when the daily

18 average upstream river temperature falls below 43 IF [6 °C]) the cooling towers are operated so

19 that the water temperature below Lock and Dam 3 is not raised more than 5 degrees above

20 ambient temperature and does not exceed a daily average of 86 OF (30 0C). During the fall and

21 winter months (from the fall trigger point through March 31), the water temperature below Lock

22 and Dam 3 cannot exceed 43 OF (6 0C) "for an extended period of time." (MPCA 2006)

23 Table 4-8 presents the upper lethal threshold for six common species of fish that occur in the

24 vicinity of PINGP 1 and 2. The summer daily average limit of 86 OF (30 0C) imposed by the

25 NPDES permit is protective of these species of fish, and is based on the fisheries data

26 available. The MPCA has updated the thermal limits in past NPDES permits to account for

27 changes in fishery data, and NRC assumes that MPCA will continue to apply the best

28 information available to future NPDES permits,

29 Table 4-8. Upper Lethal Thresholds of Common Fish Species Occurring in the

30 Vicinity of PINGP 1 and 2

Species Upper Lethal Threshold Life Stage

Walleye (Sander vitreus) 31.6 °C (88.8 OF) Juvenile

Channel catfish (Ictalurus punctatus) 38.3 "C (100.9 "F) Juvenile

33.5 °C (92.3 °F) Adult

Northern pike (Esox lucius) 33.3 "C (91.9 OF) Juvenile

Gizzard shad (Dorosoma cepedianum) 36.5 "C (97.7 "F) Juvenile

Carp (Cyprinidae) 41 °C (105.8 "F) Juvenile

36 "C (96.8 "F) Adult

Black crappie (Pomoxis nigromaculatus) 33 "C (91.4 "F) Juvenile

Source: Adapted from HDR 1978

31 Based on the applicant's ER (NMC 2008), the current NPDES permit (MPCA 2006), and the

32 316(a) demonstration (HDR 1978), the NRC staff determined that heat shock at PINGP 1 and 2

Draft NUREG-1437, Supplement 39 4-19 October 2009
Environmental Impacts of Operation

1 during the 20-year renewal period is unlikely because of the design and operation of the PINGP

2 1 and 2 cooling system. Therefore, the NRC staff concludes that the potential impact to fish and

3 shellfish due to heat shock during the renewal term is SMALL. PINGP 1 and 2 currently employ

4 a number of mitigation measures, including using closed and helper cycle cooling and flow

5 limitations. Additional mitigative measures that PINGP 1 and 2 could add include operating in

6 closed cycle more often and operating under reduced intake flows. The staff did not identify any

7 cost benefit studies applicable to these mitigation measures. It is the responsibility of the MPCA

8 to impose any restrictions or modifications to the cooling system to reduce the impact of heat

9 shock under the NPDES permitting process.

10 4.5.4 Total Impacts on Aquatic Resources

11 Impingement, entrainment and heat shock all act on the same populations of aquatic resources.

12 The purpose of this section is to provide perspective on the total impact of cooling system

13 operation on fish and other aquatic resources. The MPCA, not the NRC, is responsible for

14 issuing and enforcing NPDES permits. NRC assumes that MPCA will continue to apply the best

15 information available to future NPDES permits. Because the NRC level of impact associated

16 with impingement and entrainment is small and the level of impact associated with thermal

17 impacts is small, NRC staff believes that the total impact from all of these sources together on

18 aquatic resources would also be SMALL through the period of license renewal.

19 4.6 Terrestrial Resources

20 The issues related to terrestrial resources applicable to PINGP 1 and 2 are listed in Table 4-9.

21 There are no Category 2 issues related to terrestrial resources.

22 Regarding bird collisions with power lines, the GElS (NRC 1996)-notes that "no relatively high

23 collision mortality is known to occur along transmission lines associated with nuclear power

24 plants in the United States other than the Prairie Island plant in Minnesota." The GElS also

25 notes that PINPG 1 and 2 may be the only nuclear facility for which surveys have been

26 completed to determine the number and composition of birds that collide with offsite lines.

27 Goddard (1977; 1978; 1979) conducted a 5-year survey of Xcel-owned transmission lines at

28 PINGP 1 and 2. Data was gathered by walking several transmission line right-of-way (ROW)

29 transects on a weekly basis from April 22 through May 27 of 1974 through 1978. The transects

30 spanned from the substation just north of PINGP 1 and 2 to transmission line towers nearest the

31 Vermillion River along a portion of transmission lines that run perpendicular to the Mississippi

32 Flyway. A total of 453 birds were found over the entire 5-year period of observation, and most

33 collisions were found to occur during inclement weather (Goddard 1979). The study found that a

34 greater number of collisions occurred on transects that were perpendicular to flyways; however,

35 transmission lines only resulted in greater collisions for a few species. The majority of bird

36 carcasses identified were mourning doves, starlings, red-winged blackbirds, common grackle,

37 brown-headed cowbirds, ring-necked pheasants, American coots, and sora rails; no raptors

38 were found (Goddard 1979). No further formalized studies have been conducted on or near the

39 PINGP 1 and 2 site.

40 PINGP 1 and 2 associated transmission lines have marking devices on lines near waterways

41 and certain areas with a known history of avian collision. These marking devices are staggered

42 to divert bird flight paths and minimize the risk of collision with transmission lines. In a study

43 conducted in Lower Crab Creek, Washington, and Bybee Lake in Portland, Oregon, Beaulaurier

44 (1981) found that transmission line marking reduced collision mortality about as effectively as

45 groundwire removal where comparisons were possible. Effectiveness of reducing collisions for

46 certain species may vary by type and color of marking device, though marking devices, in

October 2009 4-13 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

general, reduce bird collision rates when compared to unmarked portions of transmission lines

(Janss and Ferrer 1998).

In 2002, Xcel Energy voluntarily entered into a Memorandum of Understanding (MOU) with the

U.S. Fish and Wildlife Service (FWS) in order to ensure the company's compliance with the

Migratory Bird Treaty Act and the Bald and Golden Eagle Protection Act (USDOJ 2002). The

MOU covers Xcel Energy transmission lines in 12 U.S. states. As a result of the MOU, Xcel

Energy is in the process of creating Avian Protection Plans (APPs) for each of these 12 states.

Xcel Energy completed a plan for Colorado in 2004, which was subsequently approved by FWS,

and Xcel Energy is currently drafting APPs for Wisconsin and Minnesota. A draft of Minnesota's

APP was submitted to FWS at the end of the 2008 calendar year. The MOU also requires semiannual reports of avian injury and mortality along Xcel Energy transmission lines, which are

submitted to FWS in February and July of each year. Since these reports began in 2002, only

one transmission line-related incident has been reported at PINGP 1 and 2, which entailed a

cormorant that was found dead near the PINGP 1 and 2 substation in October of 2002. Xcel

Energy provides training to its staff members that maintain transmission line ROWs to ensure

that the conditions of the MOU are met. Additionally, Xcel Energy established company-wide

Avian Protection Standards in 2006.

The NRC did not identify any new and significant information during the review of the applicant's

ER (NMC 2008), the staffs site audit, the scoping process, or the evaluation of other available

information. Therefore, there are no impacts related to these issues beyond those discussed in

the GElS. For these issues, the GElS concluded that the impacts are SMALL, and additional

site-specific mitigation measures are not likely to be sufficiently beneficial to warrant

implementation.

Table 4-9. Terrestrial Resources Issues. Section 2.2.6 provides a description of the

terrestrial resources at PINGP I and 2 and in the surrounding area.

Issues GElS Section Category

Cooling tower impacts on crops and ornamental vegetation 4.3.4 1

Cooling town 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, 4.5.6.3 1

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 4-10. Threatened or Endangered Species. Section 2.2.7 describes the

threatened or endangered species on or near PINGP 1 and 2.

Issue GElS Section Category

Threatened or endangered species 4.1 2

Draft NUREG-1437, Supplement 39 4-14 October 2009
Environmental Impacts of Operation

1 This site-specific, or Category 2 issue requires consultation with the appropriate agencies to

2 determine whether threatened or endangered species are present and whether they would be

3 adversely affected by continued operation of PINGP 1 and 2 during the license renewal term.

4 The characteristics and habitats of threatened and endangered species in the vicinity of the

5 PINGP 1 and 2 site are discussed in Sections 2.2.6 and 2.2.7 of this draft SEIS.

6 The NRC contacted the FWS on July 22, 2008, regarding threatened and endangered species

7 at the PINGP 1 and 2 site (NRC 2008b). A description of the site and the in-scope transmission

8 lines and a preliminary assessment of the Federal threatened, endangered, and candidate

9 species potentially occurring on or near the PINGP 1 and 2 site was provided in this letter. In

10 response, on August 13, 2008, the FWS indicated that the Higgins eye pearlymussel (Lampsilis

11 higginsi) is present in Upper Mississippi River within the vicinity of PINGP 1 and 2, though no

12 designated critical habitat is present for the species in Goodhue County (FWS 2008). No

13 terrestrial Federally listed species were included in the letter.

14 Although the NRC does not believe that license renewal would adversely affect the Federally

15 listed species, the Higgins eye pearlymussel, the NRC has prepared a Biological Assessment

16 for FWS, as part of the Section 7 consultation under the Endangered Species Act of 1973

17 (ESA), to document its review. This biological assessment is provided in Appendix E of this draft

18 SEIS.

19 The NRC contacted the MNDNR on July 22, 2008, to request data from the Minnesota Natural

20 Heritage Information System in order to determine which State-listed species may be affected

21 by continued operations and maintenance procedures at the PINGP 1 and 2 site and associated

22 transmission line ROWs (NRC 2008a). The MNDNR provided natural heritage data in the

23 vicinity of PINGP 1 and 2 in their response to the NRC staff dated August 26, 2008 (MNDNR

24 2008a).

25 4.7.1 Aquatic Species

26 As described in Section 2.2.7, two Federally listed endangered species and two candidate

27 species for Federal listing are known to exist within Goodhue County or within Dakota, Scott,

28 and/or Washington Counties, through which the in-scope transmission lines traverse. The

29 winged mapleleaf (Quadrula fragosa) is listed as endangered, and the spectaclecase

30 (Cumberlandia monodonta) and the sheepnose (Plethobasus cyphyus) are both candidates for

31 Federal listing; however, these three mussels are not known to be present in the vicinity of the

32 PINGP 1 and 2 site or within the transmission line ROWs.

33 The Higgins eye pearlymussel (Lampsilis higginsii) is the only Federally listed species that

34 occurs within the vicinity of the PINGP 1 and 2 site. As described in Section 2.2.6, State and

35 Federal agencies, including the FWS, determined that an area within Pool 3, which is located

36 0.5 mi (0.8 km) upstream of the PINGP 1 and 2 intake structure, was a suitable habitat for a

37 subadult Higgins eye relocation project. In 2002, the U.S. Army Corps of Engineers (USACE), in

38 cooperation with the Mussel Coordination Team, prepared an environmental assessment for the

39 relocation plan for the Higgins eye, in which they report "good recovery of mussels" following the

40 relocation of 100 adult Higgins eye by MNDNR, WDNR, and the FWS (USACE 2002). The

41 environmental assessment also states that the location was identified as a good relocation site

42 based on the 2000 Minnesota 305(b) water quality status report, which listed Pool 3 as having

43 "full support" for aquatic life (USACE 2002). As of a 2005 status report, over 4000 sub-adults

44 have been relocated to the Sturgeon Lake section of Pool 3 (Mussel Coordination Team 2005).

45 The Mussel Coordination Team (2005) reported "good recovery" for Pool 3 subadults after

46 conducting monitoring in 2003.

October 2009 4-15 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

1 The cooling water intake structure of a power plant can pose a threat to aquatic species

2 because fish and shellfish have the potential to be impinged on screens or entrained by the

3 cooling system. However, the life cycle of the Higgins eye pearly mussel makes it unlikely that

4 individuals of this species would be at risk of impingement or entrainment.

5 Fertilized Higgins eye eggs are carried by a gravid female until they mature into glochidia, a

6 microscopic larval stage of large freshwater mussel species. The female uses a lure to attract

7 host fish and then releases the glochidia into the water column, where they can attach to the

8 gills of the fish. If they fail to attach to the host, they have a low likelihood of attaching later, and

9 will, therefore, not mature into juveniles. Once attached to the host fish's gills, the glochidia

10 mature into juveniles and then drop to the river bottom where they settle. Once settled on

11 suitable substrate, the juveniles are sessile until maturation to adulthood. Because juveniles are

12 not present in the water column, the likelihood of entrainment during this life stage is very low.

13 The larval stage of the Higgins eye life cycle is the most likely to be affected by the cooling

14 system. Because glochidium attach to a host fish, if the host fish is impinged and killed on the

15 screens of the cooling system, the glochidium would be unlikely to be able to mature into a

16 juvenile. If the glochidium had reached maturity and dropped off the fish while the fish was

17 impinged, it would be swept into the cooling system and would be entrained.

18 Suitable fish hosts for Higgins eye glochidia include freshwater drum (Aplodinotus grunniens),

19 largemouth bass (Micropterus salmoides), smallmouth bass (Micropterus dolomieu), yellow

20 perch (Perca falvescens), sauger (Stizostedion canadense), and walleye (Stizostedion vitreum

21 vitreum); marginal fish hosts include northern pike (Esox lucius), bluegill (Lepomis macrochirus),

22 and green sunfish (Lepomis cyanellus) (FWS 2004).

23 Freshwater drum are in the Sciaedae family, which were not identified among the adults

24 impinged during the 316(b) demonstration study that Xcel Energy conducted between April and

25 August of 1984 through 1988. Largemouth bass, smallmouth bass, bluebill, and green sunfish

26 are members of the Centrarchidae family. The 316(b) demonstration indicated that an estimated

27 672 adults from this family were impinged in 1987, indicating a very low probability of adults of

28 this family being impinged by the PINGP 1 and 2 cooling system. Yellow perch, sauger, and

29 walleye are all members of the Percidae family. In 1984, an estimated 43,680 adults were

30 impinged, and in 1987, an estimated 1,176 adults were impinged. Again, the 316(b)

31 demonstration indicates that there is a low probability of adults from the Percidae family being

32 impinged by the PINGP 1 and 2 cooling system. (Xcel Energy Environmental Services 2006).

33 In order to assess the potential impact to the Higgins eye pearlymussel, the NRC staff

34 considered the life cycle of the Higgins eye, the limited time the mussel spends in the water

35 column during which it could be subject to entrainment, and the low probability of the primary

36 fish hosts being impinged. In addition, the NRC recognizes that the FWS determined that the

37 area just upstream of the PINGP 1 and 2 intake structure was a suitable site for the Higgins eye

38 relocation project. Therefore, the NRC staff concludes that the species is unlikely to be

39 adversely affected during the renewal period. If the Higgins eye relocation project is successful

40 in establishing a reproducing population during the renewal term of the licenses and if

41 impingement and entrainment at PINGP 1 and 2 of suitable fish hosts would appear to

42 adversely affect that mussel population, NRC might have to re-assess the potential for adverse

43 effects in the future. Attached to this draft SEIS is the biological assessment performed by the

44 NRC for the review of the FWS.

45 The NRC staff reviewed information from the applicant's ER (NMC 2008), the staffs site audit,

46 the scoping process, and reports from FWS, USACE, and the Mussel Coordination Team. The

47 NRC staff concludes that the continued operation of PINGP 1 and 2 during the license renewal

48 term is not likely to adversely affect any Federally listed aquatic species. Thus, the staff

Draft NUREG-1437, Supplement 39 4-16 October 2009
Environmental Impacts of Operation

1 concludes that the impact on threatened or endangered aquatic species from an additional 20

2 years of operation would be SMALL.

3 The NRC staff did not identify any mitigation measures except those discussed in Section 4.5.2,

4 which include operating in closed cycle more often, using the fine-mesh screens for a longer

5 period of time, and operating under reduced intake flows, each of which could potentially reduce

6 the overall impacts of entrainment and impingement on all species of fish and shellfish. The staff

7 did not identify any cost benefit studies applicable to these mitigation measures. The FWS could

8 issues a Biological Opinion (BO) for the Higgins eye pearlymussel in response to the NRC

9 staffs Biological Assessment. The FWS evaluates whether there are reasonable and prudent

10 measures to further minimize the impact of the PINGP 1 and 2 cooling system on the Higgins

11 eye, and these measures would be specified in the terms and conditions of the BO.

12 4.7.2 Terrestrial Species

13 Currently, no Federally listed threatened or endangered terrestrial species are known to occur

14 on the PINGP 1 and 2 site or within the in-scope transmission line ROWs. The State-listed

15 peregrine falcon (Falco peregrineus) and bald eagle (Haliaeetus leucocephalus) are known to

16 nest in the vicinity of the PINGP 1 and 2 site; however, these species are not expected to be

17 adversely affected by continued operation of PINGP 1 and 2. Operation of PINGP 1 and 2 and

18 its associated transmission lines are not expected to adversely affect any threatened or

19 endangered terrestrial species during the license renewal term.

20 The NRC staff encourages NSP, Xcel Energy, and Great River Energy to report the existence of

21 any Federally or State-listed endangered or threatened species within or near the transmission

22 line ROWs to the MNDNR and/or FWS if any such species are identified during the renewal

23 term. In particular, if any evidence of injury or mortality of migratory birds or threatened or

24 endangered species is observed within the corridor during the renewal period, NRC encourages

25 NSP, Xcel Energy, and/or Great River Energy to promptly report this to the appropriate wildlife

26 management agencies.

27 The NRC staff concludes that adverse impacts to threatened or endangered terrestrial species

28 during the license renewal term would be SMALL

29 4.8 Human Health

30 The human health issues applicable to PINGP 1 and 2 are discussed below and listed in Table

31 4-11 for Category 1, Category 2, and uncategorized issues.

32 Table 4-11. Human Health Issues. Table B-I of Appendix B to Subpart A of 10 CFR

33 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 using 4.3.6 2

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

October 2009 4-17 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

Issues GElS Section Category

Electromagnetic fields - chronic effects 4.5.4.2 Uncategorized

1 4.8.1 Generic Human Health Issues

2 No new and significant human health information was identified during the review of the

3 applicant's ER (NMC 2008), the site audit, or the scoping process. The following discussions

4 focus on the radiological environmental impacts and the dose impacts to the public and

5 environment in and around the PINGP 1 and 2 site.

6 The NRC staff reviewed historical data on radiological releases from PINGP 1 and 2 presented

7 in the Annual Radiological Environmental Monitoring Program (REMP) Reports (NMC 2004b;

8 2005b; 2006b; 2007b; 2008b) and Annual Radioactive Effluent Reports (NMC 2004a; 2005a;

9 2006a; 2007a; 2008a) during the period from 2003 through 2007. The resultant dose

10 calculations demonstrate that the doses to a maximally exposed individual in the vicinity of

11 PINGP 1 and 2 were a small fraction of the limits and standards specified in 10 CFR Part 20,

12 Appendix I to 10 CFR Part 50, and 40 CFR Part 190. Therefore, there are no impacts related to

13 these issues beyond those discussed in the GELS. For these issues, the GElS concluded that

14 the impacts are SMALL, and additional site-specific mitigation measures are not likely to be

15 sufficiently beneficial to be warranted.

16 PINGP 1 and 2 conducts an annual REMP report in which radiological impacts to the

17 employees, the public, and the environment in and around the PINGP 1 and 2 sites are

18 monitored, documented, and compared to the appropriate standards. The objectives of the

19 REMP are to:

20 0 Measure and evaluate the levels of radiation and radioactive material in the

21 environs around the PINGP 1 and 2 site to assess the radiological impacts, if

22 any, of plant operation in the environment.

23 0 Supplement the results of the radiological effluent monitoring program by

24 verifying that the measurable concentrations of radioactive material and

25 levels of radiation are not higher than expected based on the measurement of

26 radioactive effluents and modeling for the applicable exposure pathways.

27 0 Demonstrate compliance with the requirements of applicable Federal

28 regulatory agencies.

29 PINGP 1 and 2 radiological releases and the resultant environmental and dose impacts are

30 summarized in two kinds of reports: the annual REMP reports and Annual Radioactive Effluent

31 Reports. Limits for all radiological releases are specified in the PINGP 1 and 2 Offsite Dose

32 Calculation Manual, which is used to meet Federal limits and standards. The REMP includes

33 monitoring of the waterborne environment (surface and sediment from shoreline); airborne

34 environment (radioiodine and particulates and direct radiation); and ingestion pathways (milk,

35 fish, and food products). Direct radiation pathways include radiation from buildings and plant

36 structures, airborne material that may be released from the plant, cosmic radiation, fallout, and

37 the naturally occurring radioactive materials in soil, air and water. Thermoluminescent

38 dosimeters are used to measure direct radiation. The airborne pathway includes measurements

39 of radioiodine and particulates in air samples. The waterborne pathway consists of Mississippi

40 River water, drinking water, upstream and downstream collection of fish and sediment from the

41 shoreline near the discharge point for liquid radioactive effluents.

Draft NUREG-1437, Supplement 39 4-13 October 2009
Environmental Impacts of Operation

1 The PINGP 1 and 2 environmental monitoring program was initiated in May 1970 (prior to plant

2 operation) with the purpose of environmental monitoring for radioactivity in the site's vicinity.

3 The monitoring system is based on the indicator-control concept, which includes collection of

4 samples at both indicator locations (nearby, downwind, or downstream) and at control locations

5 (distant, upwind, or upstream). PINGP 1 and 2 compiles the results of their REMP in the Annual

6 Radiological Environmental Operating Reports.

7 In addition to the routine REMP, PINGP 1 and 2 has a tritium sampling program, which was

8 established after the detection of tritium in a residential well in the vicinity of PINGP 1 and 2 in

9 1989. The program is designed to monitor the onsite environment for indication of leaks from

10 plant systems and pipes carrying liquids with radioactive material. The results of the program

11 are reported in an appendix to the REMP report entitled "Special Well and Surface Water

12 Samples" (NMC 2007c; 2008c). Samples are taken from the onsite and offsite wells in the

13 vicinity of the PINGP 1 and 2 site. Since the beginning of this special sampling program, a

14 downward trend in the annual tritium level averages have been observed. In 2006, results of

15 tritium sampling showed that levels of tritium in well and ground water were at or near expected

16 natural background levels, except for one onsite well, which had levels fluctuating from 432

17 picocuries per liter [pCi/L] to 3773 pCi/L, though this range is well below the EPA drinking water

18 standard of 20,000 pCi/L (NMC 2007c). In 2007, two additional monitoring wells were sampled

19 and sampling frequency was increased. The 2007 results indicate that levels of tritium in the

20 well and ground water were at or near expected natural background levels (NMC 2008c). Levels

21 of tritium in the onsite well with fluctuating levels in 2006 as well as the two additional monitoring

22 wells fluctuated from 390 pCi/L in February to 2258 pCi/L in November 2007 (NMC 2007c). In

23 the report, the applicant indicated that the elevated tritium levels in the three onsite monitoring

24 wells might be due to prior leakage from the PINGP 1 and 2 liquid radwaste discharge pipe,

25 which was replaced in 1992, or as a result of the turbine building sump water discharge into a

26 landlocked area (NMC 2008c).

27 The Radiation Control Unit of the Minnesota Department of Health (MDH) monitors

28 environmental radioactivity in Minnesota. Monitoring allows the MDH to develop a database on

29 radioactivity within the state that can be used as a baseline during emergencies. As part of the

30 MDH radiological environmental program, gamma radiation samples are collected near PINGP

31 1 and 2 and Monticello Nuclear Generating Plant, located in Wright County. The MDH Public

32 Health Laboratory performs radiochemical analysis to estimate doses emitted from the plants.

33 Surveys of spent fuel storage casks are also performed as part of this program. The MDH

34 Environmental Radiation Data Report for 2006 states that, "In 2006, no Federal or state

35 standards or guidelines were exceeded anywhere in the state of Minnesota, including near the

36 nuclear power generating plants" (MDH 2006). Data from this program indicates that levels of

37 Strontium-90 in milk (an aftermath of historic above ground nuclear testing and the Chernobyl

38 Nuclear Power Plant accident in Ukraine), are low and now below the detection limit of isotopic

39 analysis equipment; levels of Strontium-90 in the environment will continue to decline with

40 isotopic decay. MDH also monitors levels surrounding the Independent Spent Fuel Storage

41 Installation (ISFSI) at PINGP 1 and 2. MDH data indicates that neutron levels increased

42 between 2006 and 2007, which is attributed to the addition of two casks to the ISFSI in 2006.

43 Monthly reports for the PINGP 1 and 2 ISFSI are prepared by MDH Radiation Control Unit and

44 provide data on radiation levels surrounding the PINGP 1 and 2 ISFSI (MDH 2008).

45 In addition to MDH's monitoring program, Wisconsin Public Health Statute §254.41 mandates

46 the Department of Health Services to conduct environmental radiation monitoring around

47 nuclear power facilities that impact Wisconsin in collaboration with the Radiation Protection

48 Section of the Wisconsin Department of Health Services (WIDHS), the Division of Public Health,

49 and the Bureau of Environmental Health. Therefore, the Wisconsin Department of Health

October 2009 4-19 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

1 Services conducts an extensive environmental monitoring program around PINGP 1 and 2. The

2 program includes collection of various types of samples from air, water and terrestrial exposure

3 pathways. Air, precipitation, ambient gamma radiation, surface water, fish, soil, milk, well water,

4 and vegetation samples are collected from selected locations at regular intervals (WIDHS

5 2008a; 2008b).

6 The NRC staff reviewed the PINGP 1 and 2 REMP reports for 2003 through 2007 (NMC 2004b;

7 2005b; 2006b; 2007b; 2008b) to identify any significant impacts to the environment. During

8 2007, there were no plant-related activation or fission products detected in airborne particulate

9 or radioiodine filters, milk, drinking water, surface water, fish, shoreline sediment samples, or

10 grassy or broadleaf vegetation. However, tritium was detected in groundwater samples. All

11 reported data on the tritium levels measured in the environmental samples were below

12 applicable NRC reporting levels and EPA drinking water standards (NMC 2008c).

13 Historical data on releases from PINGP 1 and 2 and the resultant dose calculations

14 demonstrate that the amount of radiation received by a maximally exposed individual in the

15 vicinity of PINGP 1 and 2 would be a small fraction of the limits specified in 10 CFR Part 20, the

16 as low as is reasonably achievable (ALARA) dose design objectives in Appendix I to 10 CFR

17 50, and EPA radiation standards contained in 40 CFR 190. In 2007, dose values were

18 calculated based on actual liquid and gaseous effluent release data and conservative models to

19 simulate the transport mechanisms. The results are described in the 2007 Annual Radioactive

20 Effluent Release Report (NMC 2008a). A summary of the calculated maximum dose to an

21 individual located at the PINGP 1 and 2 site boundary from liquid and gaseous effluents

22 released during 2007 is as follows:

23 0 The 2007 calculated maximum total body dose to an offsite member of the

24 general public from liquid effluents in 2007 was 0.86E-03 mrem (0.86E-5

25 mSv) from each PINGP 1 and 2 unit. These doses are well below the 3 mrem

26 (0.03 mSv) dose design objective in Appendix I to 10 CFR Part 50.

27 0 The 2007 calculated maximum organ (adult GI tract) dose to an offsite

28 member of the general public from liquid effluents in 2007 was

29 1.25E-03 mrem (1.25E-05 mSv) from each PINGP 1 and 2 unit. These doses

30 are well below the 10 mrem (0.10 mSv) dose design objective in Appendix I

31 to 10 CFR Part 50.

32 0 The 2007 calculated maximum gamma air dose at the site boundary from

33 noble gas discharges was 3.285E-06 mrad (3.285E-8 mGy) for each PINGP

34 1 and 2 unit. These doses are well below the 10 mrad (0.10 mGy) dose

35 design objective in Appendix I to 10 CFR Part 50.

36 * The 2007 calculated maximum beta air dose at the site boundary from noble

37 gas discharges was 1.025E-04 mrad (1.025E-6 mGy) for each PINGP 1 and

38 2 unit. These doses are well below the 20 mrad (0.20 mGy) dose design

39 objective in Appendix I to 10 CFR Part 50.

40 The NRC staff conclude that the PINGP 1 and 2 2007 radiological data are consistent, with

41 reasonable variation due to operating conditions and outages, with the five year historical

42 radiological effluent releases and resultant doses. These results confirm that PINGP 1 and 2 is

43 operating in compliance with Federal radiation protection standards contained in Appendix I to

44 10 CFR Part 50, 10 CFR Part 20, and 40 CFR Part 190. Continued compliance with regulatory

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

46 radioactive effluents are not expected to change.

Draft NUREG-1437, Supplement 39 4-20 October 2009
Environmental Impacts of Operation

1 Based on the applicant's assertion of planned refurbishment activities, slightly higher doses to

2 members of the public, with minimal resultant environmental impacts, are expected from PINGP

3 1 and 2 during the refurbishment period. However, based on past regulatory compliance and

4 experience, the dose to a maximally exposed individual in the vicinity of PINGP 1 and 2 for the

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

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

7 Refurbishment is addressed in Chapter 3 of this draft SEIS.

8 4.8.2 Microbiological Organisms - Public Health

9 Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 lists the effects of thermophilic

10 microbiological organisms on human health as a Category 2 issue, requiring a plant-specific

11 evaluation before license renewal for those plants using cooling towers that are located on a

12 small river. NRC specifies in 10 CFR 51.53(c)(ii)(G) that small rivers are those with an average

13 annual flow rate less than 3.15x1 012 ft3/yr (9x1 01 m3

/yr). The average annual flow rate of the

14 Mississippi River at the nearest measuring station to PINGP 1 and 2 is 5.8x1 011 ft3

/yr (1.64x1 010

15 m3

/yr), therefore the Mississippi River at PINGP 1 and 2 is considered a small river (NMC 2008).

16 Recreational uses of the Mississippi River in the vicinity of PINGP 1 and 2, which include

17 boating, fishing, and swimming, create the potential for human exposure to thermophilic

18 microbiological organisms (NMC 2008). Consequently, the effects of PINGP 1 and 2 thermal

19 discharge on microbiological organisms must be addressed for license renewal.

20 The Category 2 designation is based on the magnitude of the potential public health impacts

21 associated with thermal enhancement of enteric pathogens such as Salmonella spp. and

22 Shigella spp., the Pseudomonas aeruginosa bacterium, the pathogenic strain of the free-living

23 amoebae Naegleria spp., and a number of species from the Legionella genus (NRC 1996).

24 Thermophilic microbiological organisms generally occur at temperatures of 77 to 176 degrees

25 Fahrenheit ('F; 25 to 80 degrees Celsius [°C]), with optimal growth occurring at temperatures

26 from 122 to 150 OF (50 to 66 °C), and a minimum temperature tolerance of 68°F (20 °C) (Joklik

27 and Willett 1976). However, thermal preference and tolerances vary across the bacterial family.

28 In the GELS, the NRC staff noted that impacts of nuclear plant thermal discharges are

29 considered to be of small significance if they do not enhance the presence of microorganisms

30 that are detrimental to water quality and public health (NRC 1996).

31 P. aeruginosa is an opportunistic pathogen that causes serious and sometimes fatal infections

32 in immunocompromised individuals by producing and releasing toxins. It has an optimal growth

33 temperature of 99 OF (37 °C) (Todar 2007). The Legionella genus consists of at least 46 species

34 and 70 serogroups and is responsible for Legionnaires' disease, with the onset of pneumonia in

35 the first 2 weeks of exposure. Risk groups for Legionella spp. include the elderly, cigarette

36 smokers, persons with chronic lung or immunocompromising diseases, and persons receiving

37 immunosuppressive drugs. Legionella spp. grows best at 90 to 105 OF (32 to 41 *C) (CDC

38 2007a). Salmonella typhimurium and S. enteritidis are two of the more common species of

39 Enterobacteriaceae, which cause fever, abdominal cramps, and diarrhea. Salmonella spp. can

40 occasionally establish localized infection (e.g., septic arthritis) or can progress to sepsis. All

41 ages of individuals can be affected, but groups at greatest risk for severe or complicated

42 disease include infants, the elderly, and immunocompromised persons. Salmonella spp. occurs

43 at temperatures between 50 and 120 OF (10 and 49 'C) (CDC 2007b), with optimal growth

44 occurring at 95 to 99 OF (35 to 37 °C) (ESR 2002). The pathogenic amoeba flagellate Naegleria

45 fowleri is the causative agent of a rapidly fatal form of encephalitis, primary amoebic

46 meningoencephalitis (PAM). Naegleria spp. is ubiquitous in nature and can be enhanced in

47 thermally-altered water bodies at temperatures ranging from 95 to 106 OF (35 to 41 °C) or

48 higher. This organism is rarely found in water cooler than 95 °F (35 °C), and infection rarely

October 2009 4-21 O Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

1 occurs at these water temperatures (Tyndall et al. 1989). It is estimated that individual annual

2 risks to swimmers from PAM caused by the free-living N. fowleri are very low (approximately

3 4x10-6

); however, there have been reported cases of fatal Naegleria infections associated with

4 power plant cooling towers (NRC 1996).

5 As discussed in Chapter 2, the PINGP 1 and .2 circulating water system dissipates heat from the

6 reactors to the Mississippi River by using one of three modes: open cycle (once-through

7 cooling, with no cooling towers in operation), helper cycle (once-through cooling, with

8 mechanical draft cooling towers in operation), and closed cycle (using cooling towers to

9 recirculate up to 95 percent of the cooling water). The mode of cooling operation is selected by

10 the applicant to ensure compliance with the thermal limits of PINGP 1 and 2 NPDES permit No.

11 MD0004006 (MPCA 2006; NMC 2008).

12 The PINGP 1 and 2 NPDES permit specifies that during the warmer part of the year - from

13 April 1 through the date when the daily average upstream ambient river temperature falls below

14 43 OF (6 'C) for five consecutive days (the Fall Trigger date) -cooling towers must be operated

15 as necessary so that:

16 • Receiving water is not raised by more than 5 OF (2.8 °C) above ambient temperature;

17 * Cooling water discharge does not exceed a daily average temperature of 86 OF (30 °C);

18 and

19 * If the daily average ambient temperature reaches 78 OF (26 °C) for two consecutive

20 days, all cooling towers shall be operated to the maximum extent practicable (MPCA

21 2006).

22 To comply with these NPDES permit limitations, PINGP 1 and 2 monitors Mississippi River

23 water temperature at five locations: the discharge canal, the intake structure, the main river

24 channel (upstream), Sturgeon Lake (upstream), and immediately downstream of Lock and Dam

25 3. From 2000 through 2005, the highest ambient river water temperature upstream of the

26 discharge canal was 86.0 OF (30 0C), measured in August 2001. The highest temperature

27 downstream of the discharge canal was 86.4 OF (30.2 °C), measured on the same day. The

28 highest temperature measured at the PINGP 1 and 2 discharge canal was 99 OF (37.2 °C), in

29 August 2003 (NMC 2008).

30 Maximum temperatures in the discharge canal could allow for the presence of thermophilic

31 microbiological organisms. However, because the growth rate for microbiological organisms is

32 measured in hours and days (Hendricks 1972), it is not expected that the short period of time in

33 which the heated discharge water moves through the discharge canal would allow for any

34 noticeable impact on growth rates of microbiological organisms. As such, potential thermophilic

35 microbiological organisms present in the discharge canal would likely be in limited numbers and

36 would not be expected to cause a significant risk to public health. Furthermore, the PINGP 1

37 and 2 discharge canal and adjacent portions of the Mississippi River are within the plant's

38 exclusion area boundary (see Figure 2-2 in Chapter 2), and there is no public access to these

39 areas. Beyond the discharge canal, maximum ambient river water temperatures are well outside

40 the optimal temperature range for growth and reproduction of thermophilic microbiological

41 organisms.

42 Available data assembled by the U.S. Center for Disease Control and Prevention (CDC) for the

43 years 1978 through 2006 report no occurrence of waterborne disease outbreaks in Minnesota

44 resulting from the operation of PINGP 1 and 2 (CDC 2008). During the most recent two-year

45 reporting summary (2005 to 2006), Minnesota reported nine waterborne-disease outbreaks, the

46 highest number of outbreaks reported by any state (followed by New York and Florida each

47 reporting seven outbreaks, and Wisconsin reporting six). The etiological agents responsible for

Draft NUREG-1437, Supplement 39 4-22 October 2009
Environmental Impacts of Operation

1 these outbreaks were P. aeruginosa, pool chemicals or disinfection by-products,

2 Cryptosporidium hominis (an obligate parasite that colonizes the human gastrointestinal tract),

3 Legionella pneumophilla, elevated Escherichia coil levels, Shigella sonnei, Norovirus, and an

4 unidentified Vibrio species. All waterborne-disease outbreaks reported during 2005 to 2006

5 summary period resulted from the use of a hotel or private pool or spa (treated water), or a

6 recreational beach (untreated water) (CDC 2008).

7 The staff independently reviewed the applicant's ER (NMC 2008) and the applicant's Minnesota

8 NPDES permit (MPCA 2006). Based on the evaluation presented above, the staff concludes

9 that thermophilic microbiological organisms are not likely to present a public health hazard as a

10 result of PINGP 1 and 2 discharges to the Mississippi River, and the staff classifies the

11 expected impacts on public health from thermophilic microbiological organisms from continued

12 operation of PINGP 1 and 2 in the license renewal period as SMALL. In addition to maintaining

13 the current plant exclusion zone to restrict access to the Mississippi River shores in the vicinity

14 of the plant discharge canal, the staff identified one additional measure that could mitigate

15 potential thermophilic microbiological organism impacts resulting from continued operation of

16 PINGP 1 and 2. Periodic monitoring for thermophilic microbiological organisms in the water and

17 sediments in and near the discharge canal could reduce human health impacts by minimizing

18 the potential for public exposures to these organisms. The staff did not identify any cost-benefit

19 studies applicable to this mitigation measure.

20 4.8.3 Electromagnetic Fields - Acute Shock

21 Based on the GELS, the Commission found that electric shock resulting from direct access to

22 energized conductors or from induced charges in metallic structures has not been a problem at

23 most operating plants and generally is not expected to be a problem during the period of

24 extended operation. However, a site-specific review is required to determine the significance of

25 the electric shock potential along the portions of the transmission lines within the scope of the

26 SEIS.

27 The GElS states that it is not possible to determine the significance of the electric shock

28 potential without a review of the conformance of each nuclear plant transmission line with the

29 National Electrical Safety Code (IEEE 2007) criteria. Evaluation of individual plant transmission

30 lines is necessary because the issue of electric shock safety was not addressed in the licensing

31 process for some plants. For other plants, land use in the vicinity of transmission lines may have

32 changed, or power distribution companies may have chosen to upgrade line voltage. To comply

33 with 10 CFR 51.53(c)(3)(ii)(H), the applicant must provide an assessment of the potential shock

34 hazard if the transmission lines that were constructed for the specific purpose of connecting the

35 plant to the transmission system do not meet the recommendations of the National Electric

36 Safety Code for preventing electric shock from induced currents.

37 All transmission lines associated with PINGP 1 and 2 were constructed in accordance with

38 National Electric Safety Code and industry guidance in effect at that time (AEC 1973). The

39 transmission facilities are maintained to ensure continued compliance with current standards.

40 Routine ground inspections and aerial patrols are performed in order to identify any ground

41 clearance problems and the integrity of the transmission lines structures (NMC 2008). Since the

42 lines were constructed, a new criterion has been added to the National Electric Safety Code for

43 power lines with voltages exceeding 98 kV. This criterion requires that the minimum clearance

44 for a line must limit induced currents due to static effects to 5 mA. NSP has reviewed the

45 transmission lines for compliance with this criterion and indicated that all transmission lines

46 within the scope of this review have been reviewed and results show there are no locations

47 under the transmission lines that have the capacity to induce more than 5 mA in a vehicle

48 parked beneath the line (NMC 2008). No induced shock hazard to the public should occur, since

October 2009 4-23 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

1 the lines are operating within original design specifications and meet current National Electric

2 Safety Code clearance standards.

3 The NRC staff has reviewed the available information, including the applicant's evaluation and

4 computational results. Based on this information, the NRC staff evaluated the potential impacts

5 for electric shock resulting from operation of PINGP 1 and 2 and its associated transmission

6 lines. The NRC staff concludes that the potential impacts from electric shock during the renewal

7 period would be SMALL. The NRC staff identified a variety of measures that could mitigate

8 potential acute electromagnetic field impacts resulting from continued operation of the PINGP 1

9 and 2's transmission lines. These mitigation measures would include erecting barriers along the

10 length of the transmission line to prevent unauthorized access to the ground beneath the

11 conductors, installing road signs at road crossings, and raising the elevation of the lowest

12 energized conductor to increase the distance between it and a potentially exposed individual

13 directly beneath it. These mitigation measures could reduce human health impacts by

14 minimizing public exposures to electric shock hazards. The NRC staff did not identify any cost

15 benefit studies applicable to the mitigation measures mentioned above.

16 4.8.4 Electromagnetic Fields - Chronic Effects

17 The NRC specifies in 10 CFR 51, Subpart A, Appendix B, Table B-i, that "biological and

18 physical studies of 60-Hz electromagnetic fields have not found consistent evidence linking

19 harmful effects with field exposure. However, research is continuing in this area and a

20 consensus scientific view has not been reached." The GElS did not designate the chronic

21 effects of 60-Hz electromagnetic fields from power lines as Category 1 or 2; such a designation

22 will not occur until a scientific consensus is reached on the health implications of these fields.

23 The potential for chronic effects from these fields continues to be studied and is not known at

24 this time. The National Institute of Environmental Health Sciences (NIEHS) directs related

25 research through the U.S. Department of Energy (DOE). The report by NIEHS (1999) contains

26 the following conclusion, which is supported by the recently published World Health

27 Organization (2007) Environmental Health Criteria Monograph No.238:

28 The NIEHS concludes that ELF-EMF [extremely low frequency-electromagnetic

29 field] exposure cannot be recognized as entirely safe because of weak scientific

30 evidence that exposure may pose a leukemia hazard. In our opinion, this finding

31 is insufficient to warrant aggressive regulatory concern. However, because

32 virtually everyone in the United States uses electricity and therefore is routinely

33 exposed to ELF-EMF, passive regulatory action is warranted such as a continued

34 emphasis on educating both the public and the regulated community on means

35 aimed at reducing exposures. The NIEHS does not believe that other cancers or

36 non-cancer health outcomes provide sufficient evidence of a risk to currently

37 warrant concern.

38 This statement is not sufficient to cause the NRC staff to change its position with respect to the

39 chronic effects of electromagnetic fields. This position is expressed in Footnote 5 to Table B-1 of

40 Appendix B to Subpart A of 10 CFR Part 51 as follows:

41 If in the future, the Commission finds that, contrary to current indications, a

42 consensus has been reached by appropriate Federal health agencies that there

43 are adverse health effects from electromagnetic fields, the Commission will

44 require applicants to submit plant-specific reviews of these health effects as part

45 of their license renewal applications. Until such time, applicants for license

46 renewal are not required to submit information on this issue.

Draft NUREG-1437, Supplement 39 4-24 October 2009
Environmental Impacts of Operation

1

2

3

4

5

6

7

The NRC staff considers the GElS finding of "Uncertain" still appropriate and will continue to

follow developments on this issue.

4.9 Socloeconomics

The socioeconomic issues applicable to PINGP 1 and 2 follow in Table 4.12 for Category 1, Category

2, and uncategorized issues.

Table 4-12. Socioeconomic Issues. Section 2.2.9 of this report describes the

socioeconomic conditions near PINGP I and 2.

Issues GElS Section Category

Housing Impacts 4.7.1 2

Public Services: public safety, 4.7.3; 4.7.3.3; 4.7.3.4; 4.7.3.6 1

social services, and tourism and

recreation

Public Services: public utilities 4.7.3.5 2

Public Services: education 4.7.3.1 1

(license renewal term)

Offsite Land Use (license 4.7.4 2

renewal term)

Public Services: transportation 4.7.3.2 2

Historic and Archaeological 4.7.7 2

Resources

Aesthetic Impacts (license 4.7.6 1

renewal term)

Aesthetic impacts of transmission 4.5.8 1

lines (license renewal term)

Environmental Justice Not addressed(a) Ucategorized(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.

8 4.9.1 Generic Socioeconomic Issues

9 The NRC staff reviewed and evaluated the PINGP 1 and 2 ER, scoping comments, other

10 available information, and visited the PINGP 1 and 2 site. The NRC staff did not identify any

11 new and significant information that would change the conclusions presented in the GELS.

12 Therefore, it is expected that there would be no impacts related to the Category 1 issues during

13 the period of extended operation beyond those discussed in the GElS. For PINGP 1 and 2, the

14 staff incorporates the GElS conclusions by reference. Impacts for Category 2 and uncategorized

15 issues are discussed in Sections 4.9.2 through 4.9.7, below.

16 4.9.2 Housing Impacts

17 Appendix C, Section C.1.4, of the GElS presents a population characterization method based

18 on two factors, sparseness and proximity. Sparseness measures population density within 20

October 2009 4-25 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

1 mi (32 km) of the site, and proximity measures population density and city size within 50 mi (80

2 km). Each factor has categories of density and size (GELS, Table C.1). A matrix is used to rank

3 the population category as low, medium, or high (GELS, Figure C.1).

4 According to the 2000 Census, approximately 107,131 people lived within 20 mi (32 km) of

5 PINGP 1 and 2, which equates to a population density of 85 persons per mi 2 (142 persons per

6 km 2) (NMC 2008). This density translates to the less sparse GElS Category 3 (60 to 120

7 persons per mi2 [100 to 200 persons per km 2

] or less than 60 persons per mi2 [100 persons per

8 km2

] with at least one community with 25,000 or more persons within 20 mi [32 km]).

9 Approximately 2,733,326 people live within 50 mi (80 km) of PINGP 1 and 2 (NMC 2008). This

10 equates to a population density of 349 persons per mi 2 (582 persons per km 2). Applying the

11 GElS proximity measures, this density is classified as proximity Category 4 (greater than or

12 equal to 190 persons per mi2 [317 persons per km 2] within 50 mi [80 km]). Therefore, according

13 to the sparseness and proximity matrix presented in the GELS, the rankings of sparseness

14 (Category 3) and proximity (Category 4) result in the conclusion that PINGP 1 and 2 are located

15 in a high population area.

16 Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 states that impacts on housing

17 availability are expected to be of small significance in high-density population areas where

18 growth control measures are not in effect. Since the PINGP 1 and 2 site is located in a high

19 population area, and Goodhue and Dakota Counties, Minnesota, and Pierce County, Wisconsin,

20 are not subject to growth control measures that would limit housing development, any changes

21 in employment at PINGP 1 and 2 would have little noticeable effect on housing availability in

22 these counties. Since NSP has no plans to add non-outage employees during the license

23 renewal period, employment levels at PINGP 1 and 2 would remain relatively constant with no

24 additional demand for permanent housing during the license renewal term. In addition, the

25 number of available housing units has kept pace with or exceeded the increase in area

26 population. Based on this information, there would be no impact on permanent housing during

27 the license renewal term beyond what has already been experienced.

28 However, NSP indicated in their environmental report that the PINGP, Unit 2, steam generators

29 would be replaced prior to the license renewal term. NSP estimates that steam generator

30 replacement would require a one-time increase in the number of refueling outage workers for up

31 to 80 days at PINGP 1 and 2 (NMC 2008). These additional workers would create an additional

32 demand for temporary (rental) housing in the immediate vicinity of PINGP 1 and 2. The impacts

33 of the PINGP, Unit 2, steam generator replacement are discussed in Chapter 3 of this draft

34 SEIS.

35 4.9.3 Public Services: Public Utility Impacts

36 Impacts on public utility services are considered SMALL if there is little or no change in the

37 ability of the system to respond to demand and thus there is no need to add capital facilities.

38 Impacts are considered MODERATE if service capabilities are overtaxed during periods of peak

39 demand. Impacts are considered LARGE if services (e.g., water, sewer) are substantially

40 degraded and additional capacity is needed to meet ongoing demand. In the absence of new

41 and significant information to the contrary, the only impacts on public utilities that could be

42 significant would be impacts on public water supplies.

43 Analysis of impacts on the public water systems considered both plant demand and plant44 related population growth. Section 2.1.3 of this SEIS describes the permitted withdrawal rate

45 and actual use of water for reactor cooling for PINGP 1 and 2.

46 Since NSP has no plans to add non-outage employees during the license renewal period,

47 employment levels at PINGP 1 and 2 would remain relatively unchanged with no additional

Draft NUREG-1437, Supplement 39 4-26 October 2009
Environmental Impacts of Operation

1 demand for public water and sewer services. Public water systems in the region would be

2 adequate to meet the demands of residential and industrial customers in the area. Therefore,

3 there would be no additional impact to public water and sewer services during the license

4 renewal term beyond what is currently being experienced.

5 As discussed in Section 4.9.2, NSP indicated in their environmental report that the PINGP 1 and

6 2, Unit 2, steam generators would be replaced prior to the license renewal term (NMC 2008).

7 The additional number of refueling outage workers needed to replace the steam generators

8 would cause a short-term increase in the amount of public water and sewer services used in the

9 immediate vicinity of PINGP 1 and 2. These impacts are discussed in Chapter 3 of this draft

10 SEIS.

11 4.9.4 Offsite Land Use - License Renewal Period

12 Offsite land use during the license renewal term is a Category 2 issue (10 CFR 51, Subpart A,

13 Appendix B, Table B-1). Table B-1 of 10 CFR 51 Subpart A, Appendix B notes that "significant

14 changes in land use may be associated with population and tax revenue changes resulting from

15 license renewal."

16 Section 4.7.4 of the GElS defines the magnitude of land-use changes as a result of plant

17 operation during the license renewal term as follows:

18 SMALL - Little new development and minimal changes to an area's land-use pattern.

19 MODERATE - Considerable new development and some changes to the land-use pattern.

20 LARGE - Large-scale new development and major changes in the land-use pattern.

21 Tax revenue can affect land use because it enables local jurisdictions to provide the public

22 services (e.g., transportation and utilities) necessary to support development. Section 4.7.4.1 of

23 the GElS states that the assessment of tax-driven land-use impacts during the license renewal

24 term should consider (1) the size of the plant's payments relative to the community's total

25 revenues, (2) the nature of the community's existing land-use pattern, and (3) the extent to

26 which the community already has public services in place to support and guide development. If

27 the plant's tax payments are projected to be small relative to the community's total revenue, tax28 driven land-use changes during the plant's license renewal term would be SMALL, especially

29 where the community has pre-established patterns of development and has provided adequate

30 public services to support and guide development. Section 4.7.2.1 of the GElS states that if tax

31 payments by the plant owner are less than 10 percent of the taxing jurisdiction's revenue, the

32 significance level would be SMALL. If the plant's tax payments are projected to be medium to

33 large relative to the community's total revenue, new tax-driven land-use changes would be

34 MODERATE. If the plant's tax payments are projected to be a dominant source of the

35 community's total revenue, new tax-driven land-use changes would be LARGE. This would be

36 especially true where the community has no pre-established pattern of development or has not

37 provided adequate public services to support and guide development.

38 Population-related Impacts

39 Since NSP has no plans to add non-outage employees during the license renewal period, there

40 would be minimal plant operations-driven population increase in the vicinity of PINGP 1 and 2.

41 Therefore, there would be minimal population-related land use impacts during the license

42 renewal term beyond what has already been experienced.

43 As discussed in Section 4.9.2, NSP indicated in their environmental report that the PINGP, Unit

44 2, steam generators would be replaced prior to the license renewal term (NMC 2008). Due to

45 the short amount of time needed to replace the steam generators, the additional number of

October 2009 4-27 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

1 refueling outage workers would not cause any permanent population-related land use changes

2 in the immediate vicinity of PINGP 1 and 2. These impacts are discussed in Chapter 3 of this

3 draft SEIS.

4 Tax-Revenue-Related Impacts

5 As previously discussed in Chapter 2, NSP pays annual real estate taxes to Goodhue County,

6 City of Red Wing, and School District 256. For the three-year period from 2003 through 2005,

7 tax payments to Goodhue County represented 17 to 21 percent of the County's total annual

8 property tax revenues, and payments to the City of Red Wing represented approximately 36 to

9 42 percent of the City's total annual property tax revenues. NSP's tax payments to School

10 District 256, for the period 2003 through 2005, represented 28 to 36 percent of the District's total

11 annual property tax revenues.

12 Since NSP started making payments to local jurisdictions, population levels and land use

13 conditions in Goodhue County and the City of Red Wing have not changed significantly, which

14 might indicate that these tax revenues have had little or no effect on land use activities within

15 the county or city. Given that NSP has no plans to add non-outage employees during the

16 license renewal period, employment levels at PINGP 1 and 2 would remain relatively

17 unchanged. The assessed value of PINGP 1 and 2 is not expected to increase, and annual

18 property tax payments to Goodhue County, City of Red Wing, and School District 256 are

19 expected to remain relatively unchanged throughout the license renewal period. Based on this

20 information, there would be no significant land use impacts related to tax revenue during the

21 license renewal term beyond what has already been experienced.

22 As discussed in Section 4.9.2, NSP indicated in their ER that the PINGP, Unit 2, steam

23 generators would be replaced prior to the license renewal term (NMC 2008). The replacement

24 of the existing steam generators would not likely increase the assessed value of PINGP 1 and

25 2, and property tax payments would remain unchanged. These impacts are discussed in

26 Chapter 3 of this draft SEIS.

27 4.9.5 Public Services: Transportation Impacts

28 Table B-1 of 10 CFR Part 51 states: "Transportation impacts (level of service) of highway traffic

29 generated.. .during the term of the renewed license are generally expected to be of small

30 significance. However, the increase in traffic associated with additional workers and the local

31 road and traffic control conditions may lead to impacts of moderate or large significance at some

32 sites." All applicants are required by 10 CFR 51.53(c)(3)(ii)(J) to assess the impacts of highway

33 traffic generated by the proposed project on the level of service of local highways during the

34 term of the renewed license.

35 Since NSP has no plans to add non-outage employees during the license renewal period, there

36 would be no noticeable change in traffic volume and levels of service on roadways in the vicinity

37 of PINGP 1 and 2. Therefore, there would be minimal transportation impacts during the license

38 renewal term beyond what is currently being experienced.

39 As discussed in Section 4.9.2, NSP indicated in their environmental report that the PINGP 1 and

40 2, Unit 2, steam generators would be replaced prior to the license renewal term (NMC 2008).

41 The additional number of refueling outage workers and truck material deliveries needed to

42 support the replacement of the steam generators would cause a short-term transportation

43 impact on access roads in the immediate vicinity of PINGP 1 and 2. These impacts are

44 discussed in Chapter 3 of this draft SEIS.

Draft NUREG-1437, Supplement 39 4-28 October 2009
Environmental Impacts of Operation

1 Prairie Island Indian Community

2 The following information was provided by the PIIC (PIIC 2008).

3 As stated in Chapter 2 and 3, the Tribe is concerned about PINGP 1 and 2-

4 related traffic impacts on the Tribe's residential area (60 homes), the casino

5 (guests and employees) and the tribal government offices, especially the

6 increased volume of traffic that occurs during plant outages. Sturgeon Lake Road

7 provides the only access to the Tribe's residential area, its government center,

8 and its business. PINGP 1 and 2 full-time employees and outage workers also

9 heavily use Sturgeon Lake Road.

10 4.9.6 Historic and Archaeological Resources

11 The National Historic Preservation Act (NHPA) requires Federal agencies to consider the effects

12 of their undertakings on historic properties. Historic properties are defined as resources that are

13 eligible for listing on the NRHP. The criteria for eligibility are listed in Title 36, "Parks, Forests,

14 and Public Property," Part 60, Section 4, "Criteria for Evaluation," of the Code of Federal

15 Regulations (36 CFR Part 60.4) and include (1) association with significant events in history; (2)

16 association with the lives of persons significant in the past; (3) embodies distinctive

17 characteristics of type, period, or construction, and (4) or sites or places that have yielded or is

18 likely to yield important information (ACHP 2008). The historic preservation review process

19 (Section 106 of the NHPA) is outlined in regulations issued by the Advisory Council on Historic

20 Preservation (ACHP) in Title 36, "Parks, Forests, and Public Property," Part 800, "Protection of

21 Historic Properties," of the Code of Federal Regulations (36 CFR Part 800).

22 The issuance of a renewed operating license for a nuclear power plant is a federal action that

23 could possibly affect either known or undiscovered historic properties located on or near the

24 plant site and its associated transmission lines. In accordance with the provisions of the NHPA,

25 the NRC is required to make a reasonable effort to identify historic properties in the area of

26 potential effect. The area of potential effect for a license renewal action is the area at the power

27 plant site and its immediate environs that may be impacted during land-disturbing operations or

28 projected refurbishment activities associated with the proposed action. If no historic properties

29 are present or affected, the NRC is required to notify the State Historic Preservation Office

30 before proceeding. If it is determined that historic properties are present, the NRC is required to

31 assess and resolve possible adverse effects of the undertaking.

32 NSP contacted the MNHS in April 2007 to request information on historic and archaeological

33 resources in the vicinity of the PINGP 1 and 2 site and describe the proposed action (license

34 renewal) (NMC 2007a). The MNHS responded requesting additional information about the

35 license renewal process, and NSP provided additional information in March 2008 (NMC 2008a).

36 In response to NSP's request, the MNHS stated, in a letter dated April 29, 2008, that many

37 known archaeological sites are located on and in the vicinity of PINGP 1 and 2. MNHS noted

38 that many of these sites had been disturbed by the construction of PINGP 1 and 2. MNHS also

39 requested that NSP implement effective and proactive cultural resource management practices

40 during the license period, and that a programmatic agreement be negotiated (MNHS 2008).

41 NSP contacted the PIIC in July 2007 to request the PIIC's participation in the license renewal

42 application process (NMC 2007b). The PIIC submitted a letter to NSP detailing concerns

43 regarding the past treatment of historic and archaeological resources and other environmental

44 issues at PINGP 1 and 2 (PIIC 2008a).

45 In accordance with 36 CFR 800.8(c), the NRC contacted the MNHS (NRC 2008a), the ACHP

46 (NRC 2008b), the PIIC (2008c) and other Federally-recognized Native American Tribes to

October 2009 4-29 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

1 initiate consultation regarding the Section 106 consultation process. These letters are listed in

2 Appendix D.

3 On April 14, 2008, the NRC received a letter from the PRIC requesting participation as a

4 cooperating agency in the license renewal environmental review for PINGP 1 and 2. On June

5 17, 2008, the NRC and the PRIC entered into a Memorandum of Understanding (MOU) to

6 establish a framework for the NRC and the PRIC to work together to review potential

7 environmental impacts of the proposed license renewal. The MOU establishes a cooperating

8 agency relationship between the NRC and the PIIC for the preparation of the PINGP 1 and 2

9 SEIS.

10 As discussed in Section 2.2.9, a search of the MNHS, Bureau of Indian Affairs (BIA), and Office

11 of the State Archaeologist (OSA) site files identified nine archaeological sites, including seven

12 known and recorded archaeological sites, one reported site (Vergil Larson II Mound Group site

13 [21GDI]), and one unrecorded site (Prairie Island District 132 Schoolhouse) (see Table 2.25) at

14 the PINGP 1 and 2 site. The following is a brief description of the known archaeological sites.

15 Several surveys and archaeological excavations have been conducted over the years at the

16 Bartron village site (21GD02). This multi-component site contains intact features which could

17 contribute to the understanding of the cultural history of Prairie Island. The Bartron site extends

18 onto the PINGP 1 and 2 site. The Bartron village site contains intact features and should be

19 avoided.

20 The Birch Lake Mound Group (21GD58/61) dates to the Mississippian period. Five out of eight

21 mounds in this group were excavated as part of Elden Johnson's survey work in 1968. Human

22 remains and funerary objects were recovered from this site. The MNHS, Minnesota Indian

23 Affairs Council, and Hamline University are working on the repatriation of these remains.

24 Portions of this site could still be intact and should be avoided.

25 The NSP II Mound Group (21GD59) consists of six burial mounds and dates to the

26 Mississippian period. This mound group was located in the vicinity of the PINGP 1 and 2

27 cooling towers. Prior to construction, it was noted that some of the mounds had been impacted

28 by cultivation. In 1968 and 1969, two of the six mounds were excavated. Survey reports noted

29 that the mounds did not yield significant amounts of cultural artifacts (Johnson, Peterson, and

30 Streiff 1969). The four remaining mounds were either covered with fill or leveled during grading

31 activities for the PINGP 1 and 2 cooling towers. Aerial photos show heavy ground disturbance

32 on and in the vicinity of the NSP II Mound Group during the construction of the cooling towers.

33 A portion of 21 GD59 may not have been leveled and could be buried under fill. The exact

34 degree of preservation of this site is unknown. Portions of this site could still be intact and

35 should be avoided.

36 A single elongated mound (21GD62) was excavated in July 1969 by Elden Johnson. This

37 mound site has been disturbed by years of cultivation and could have been impacted by railroad

38 construction. The impact on this particular site from construction of PINGP 1 and 2 was minimal

39 because it was located outside the PINGP 1 and 2 site construction area. Portions of this site

40 could still be intact and should be avoided.

41 In 1980, site 21GD148 (a Late Woodland habitation site) and site 21GD207 (a Late Woodland

42 artifact scatter) were identified and excavated during Johnson's survey for the modification of

43 the cooling discharge canal. Portions of these sites are still intact and should be avoided.

44 Also, in 1980, site 21GD149 was discovered eroding out of a river bank by NSP biologists on

45 land owned by the USACE and leased by NSP. This site was discovered when water levels

46 were lowered (drawdown) in the pool above Lock and Dam No. 3 by the USACE. Site

47 21GD149 is listed as a possible earthwork, mound, or habitation site dating to the Late

Draft NUREG-1437, Supplement 39 4-30 October 2009
Environmental Impacts of Operation

1 Woodland and Mississippian periods. This site has the potential to yield important information

2 regarding the relationships between these cultures. This site has been heavily eroded by the

3 Mississippi River and is mostly under water (Hildebrandt 2008). NSP intends to survey this site

4 if future drawdown occurs.

5 The Vergil Larson II Mound Group (21 GDI), a group of three mounds, was discovered in the

6 1980s, and was likely impacted by farming at one time. A reconnaissance survey was

7 conducted in 1998 and 1999. However, no subsurface testing was conducted out of respect for

8 potential burials interred in the reported mounds. This site has not been field verified, but will be

9 revisited as part of the Phase I Reconnaissance Field Survey (Xcel 2009).

10 One potential historic resource is the Prairie Island (District 132) Schoolhouse. The

11 schoolhouse was operational from 1873 through 1953 (Hildebrandt 2008). This one room

.12 schoolhouse was attended by children who were both local members of the PIIC as well as non13 Indian children who are not members (PIIC 2008). It was torn down for construction of PINGP 1

14 and 2, however, the foundation remains preserved underneath a mowed area. This site has

15 never been formally investigated. This area should be avoided and investigated in the event of

16 any ground disturbing activities.

17 NSP has indicated no plans to alter the PINGP 1 and 2 site for license renewal. Nevertheless,

18 because there is a high potential for additional archaeological resources to .be discovered at the

19 PINGP 1 and 2 site, NSP should make sure that these resources are not affected by continued

20 operations and maintenance activities.

21 NSP is in the process of revising its corporate procedures to improve its protection of

22 archaeological resources. NSP has proposed the following four new license renewal

23 commitments to address the protection of archaeological, historical and cultural resources.

24 These commitments are stated exactly as they were issued by the applicant, (reference in the

25 text to NSPM, Xcel, NSP Minnesota and NSP are all referring to the applicant, NSP).

26 New Preliminary Commitment Number 37

27 NSPM will revise procedures for excavation and trenching controls and

28 archaeological, cultural and historic resource protection to identify sensitive areas

29 and provide guidance for ground-disturbing activities. The procedures will be

30 revised to include drawings and illustrations to assist users in identifying

31 culturally sensitive areas, and pictures of artifacts that are prevalent in the area of

32 the Plant site. The revised procedures will also require training of the Site

33 Environmental Coordinator and other personnel responsible for proper execution

34 of excavation or other ground-disturbing activities (NSP 2009).

35 New Preliminary Commitment Number 38

36 NSPM will conduct a Phase I Reconnaissance Field Survey of the disturbed

37 areas within the Plant's boundaries. In addition, NSPM will conduct Phase I field

38 surveys of areas of known archaeological sites to precisely determine their

39 boundaries. NSPM will use the results of these surveys to designate areas for

40 archaeological protection (NSP 2009).

41 New Preliminary Commitment Number 39

42 NSPM will prepare, maintain and implement a Cultural Resources Management

43 Plan (CRMP) to protect significant historical, archaeological, and cultural

44 resources that may currently exist on the Plant site. In connection with the

45 preparation of the CRMP, NSPM will conduct botanical surveys to identify

October 2009 4-31 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

1 culturally and medicinally important species on the plant site, and incorporate

2 provisions to protect such plants into the CRMP (NSP 2009).

3 New Preliminary Commitment Number 40

4 NSPM will consult with a qualified archaeologist prior to conducting any ground5 disturbing activity in any area designated as undisturbed and in any disturbed

6 area that is described as potentially containing archaeological resources (as

7 determined by the Phase I Reconnaissance Field Survey discussed in New

8 Preliminary Commitment Number 38) (NSP 2009).

9 NSP is currently seeking comment from the MNHS, BIA, the OSA, and the PIIC on its revised

10 procedures.

11 During the environmental site audit, NRC staff discovered that Excavation and Trenching

12 Control procedures were not consistently applied. An excavation was found near an existing

13 archaeological site, and NSP's procedures had not been followed. NSP has initiated corrective

14 actions including the training of employees and staff (NSP 2009). In addition, as previously

15 discussed in Chapter 2 of this draft SEIS, NSP will conduct a Phase I Reconnaissance Field

16 Survey of disturbed areas and known archaeological sites (Xcel 2009).

17 Based on the review of MNHS, OSA, and BIA files, information from the PIIC; archaeological

18 surveys, assessments, and other information; the potential impacts of continued operations and

19 maintenance of PINGP 1 and 2 on historic, archaeological, and cultural resources could be

20 MODERATE. NSP could mitigate MODERATE impacts by training NSP staff in the Section 106

21 consultation process and cultural awareness training to ensure that informed decisions are

22 made when considering the effects of continued operations and maintenance on historic and

23 archaeological resources. In addition, NSP would also develop a cultural resources

24 management plan which would coordinate procedures, policies, and effectively manage and

25 protect the archaeological sites and resources on the PINGP 1 and 2 site. The cultural

26 resources management plan should be developed in consultation with the NRC, PIIC, OSA,

27 BIA, and MHS. NSP should also establish a point of contact to facilitate open communication

28 with the PIIC regarding activities that could impact historic and archaeological resources.

29 Subsequent to the issuance of this draft SEIS, NSP has committed to conduct a Phase I

30 Reconnaissance Field Survey of the disturbed areas within the PINGP 1 and 2 site boundaries

31 (Xcel 2009). In addition, NSP will conduct Phase I field surveys of areas of known

32 archaeological sites to delineate their boundaries (Xcel 2009). NSP will use the results of these

33 reconnaissance field surveys to designate areas for archaeological protection at the PINGP 1

34 and 2 site (Xcel 2009). Lands that have not been surveyed should be investigated by a

35 qualified archaeologist prior to any ground disturbing activity.

36 As discussed in Chapter 3, NSP plans to replace the PINGP 1 and 2, Unit 2, steam generators.

37 Warehouse(s) will be constructed on the site to house the replaced generators (NMC 2008). All

38 construction will take place within the existing developed industrial portions of the plant site.

39 Undisturbed areas of the plant site will not be affected (NMC 2008). The environmental impacts

40 of PINGP 1 and 2, Unit 2, steam generator replacement project are addressed in Chapter 3 of

41 this draft SEIS.

42 Prairie Island Indian Community

43 The following information was provided by the PIIC (PIIC 2008).

44 All of the archaeological sites on Prairie Island (including those within the

45 boundaries of PINGP 1 and 2) are considered by Tribal members to be sacred

46 sites. NSP and the tribe have begun to work in a cooperative manner to ensure

Draft NUREG-1437, Supplement 39 4-32 October 2009
Environmental Impacts of Operation

1 that all archaeological sites are protected during refurbishment and the extended

2 period of operation. In addition, NSP is conducting a medicinal and cultural plant

3 inventory within the boundaries of the PINGP 1 and 2. The results of the NSP

4 plant inventory will be compared with the Tribe's 2008/2009 plant inventory.

5 Because of past damage to archaeological sites within the PINGP 1 and 2 site

6 boundaries, NSP is considering the Prairie Island Indian Community's suggestion

7 that a "healing ceremony" be held. During the summer of 2008, a tribal member

8 was allowed to cut down a ceremonial tree (for the Sun Dance) on land within the

9 PINGP 1 and 2 site boundaries.

10 The Tribe recommends that NSP conduct a Traditional Cultural Property (TCP)

11 survey of the PINGP 1 and 2 site to document past or lost use of cultural sites

12 and materials. Tribal members should be allowed access to burial sites for

13 ceremonial purposes, and procedures should be established for protecting all

14 archaeological sites within the PINGP 1 and 2 site.

15 4.9.7 Environmental Justice

16 Under Executive Order 12898 (59 FR 7629), Federal agencies are responsible for identifying

17 and addressing potential disproportionately high and adverse human health and environmental

18 impacts on minority and low-income populations. In 2004, the Commission issued a Policy

19 Statement on the Treatment of Environmental Justice Matters in NRC Regulatory and Licensing

20 Actions (69 FR 52040), which states, "[t]he Commission is committed to the general goals set

21 forth in Executive Order 12898 (EO), and strives to meet those goals as part of its NEPA review

22 process."

23 The Council of Environmental Quality (CEQ) provides the following information in Environmental

24 Justice: Guidance Under the National Environmental Policy Act (NEPA) (1997):

25 Disproportionately High and Adverse Human Health Effects. Adverse health

26 effects are measured in risks and rates that could result in latent cancer fatalities,

27 as well as other fatal or nonfatal adverse impacts on human health. Adverse

28 health effects may include bodily impairment, infirmity, illness, or death.

29 Disproportionately high and adverse human health effects occur when the risk or

30 rate of exposure to an environmental hazard for a minority or low-income

31 population is significant (as defined by NEPA) and appreciably exceeds the risk

32 or exposure rate for the general population or for another appropriate comparison

33 group (CEQ 1997).

34 Disproportionately High and Adverse Environmental Effects. A

35 disproportionately high environmental impact that is significant (as defined by

36 NEPA) refers to an impact or risk of an impact on the natural or physical

37 environment in a low-income or minority community that appreciably exceeds the

38 environmental impact on the larger community. Such effects may include

39 ecological, cultural, human health, economic, or social impacts. An adverse

40 environmental impact is an impact that is determined to be both harmful and

41 significant (as defined by NEPA). In assessing cultural and aesthetic

42 environmental impacts, impacts that uniquely affect geographically dislocated or

43 dispersed minority or low-income populations or American Indian tribes are

44 considered (CEQ 1997).

45 The environmental justice analysis assesses the potential for disproportionately

46 high and adverse human health or environmental effects on minority and lowOctober 2009. 4-33 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

1 income populations that could result from the operation of PINGP 1 and 2 during

2 the renewal term. In assessing the impacts, the following CEQ (1997) definitions

3 of minority individuals and populations and low-income population were used:

4 Minority individuals. Individuals who identify themselves as members of the

5 following population groups: Hispanic.or Latino, American Indian or Alaska

6 Native, Asian, Black or African American, Native Hawaiian or Other Pacific

7 Islander, or two or more races meaning individuals who identified themselves on

8 a Census form as being a member of two or more races, for example, Hispanic

9 and Asian.

10 Minority populations. Minority populations are identified when (1) the minority

11 population of an affected area exceeds 50 percent or (2) the minority population

12 percentage of the affected area is meaningfully greater than the minority

13 population percentage in the general population or other appropriate unit of

14 geographic analysis.

15 Low-income population. Low-income populations in an affected area are

16 identified with the annual statistical poverty thresholds from the Census Bureau's

17 Current Population Reports, Series PB60, on Income and Poverty.

18 Minority Population in 2000

19 According to 2000 Census data, 16.6 percent of the population (approximately 2,743,000

20 persons) residing within a 50-mi (80-km) radius of PINGP 1 and 2 identified themselves as

21 minority individuals. The largest minority group was Black or African American (185,000

22 persons or 6.7 percent), followed by Asian (140,000 persons or about 5.1 percent) (USCB

23 2003). About 3.9 percent of the Goodhue County population identified themselves as

24 minorities, with American Indian and Alaska Native the largest minority group (1.3 percent)

25 followed by Hispanic or Latino (1.1 percent) (USCB 2008) (see Table 2.2.8.5-2).

26 The 50-mi (80-km) radius around PINGP 1 and 2 includes 25 counties, 17 of which are in

27 Minnesota and 8 of which are in Wisconsin. The geographic area includes any census block

28 group with all or part of its area within the 50-mi (80-km) radius. Of the 2,197 census block

29 groups located wholly or partly within the 50-mi (80-km) radius of PINGP 1 and 2, 312 block

30 groups were determined to have high density minority population percentages that exceeded

31 the state average by 20 percentage points or more (NMC 2008). The largest number of high

32 density minority block groups was Black or African American, with 131 block groups that exceed

33 the state average 20 percent or more. These block groups are concentrated in urban areas with

34 high population densities. The greatest number of high density block groups with minority

35 populations is located in two Minnesota counties (Hennepin and Ramsey). The closest high

36 density minority population to PINGP 1 and 2 is located in Minneapolis. Based on 2000 Census

37 data, Figure 4-2 shows the location of high density minority block groups within a 50-mi (80-km)

38 radius of PINGP 1 and 2.

39 The NRC staff has designated the Prairie Island Indian Community (PIIC) as a minority

40 population within a 50-mi (80-km) radius of PINGP 1 and 2. Figure 4-1 shows the boundary of

41 the PIIC in relation to the PINGP 1 and 2 site.

42 Low-Income Population in 2000

43 According to 2000 Census data, approximately 32,000 families and 99,000 individuals

44 (approximately 4.7 and 7.2 percent, respectively) residing within a 50-mi (80-km) radius of

45 PINGP 1 and 2 were identified as living below the Federal poverty threshold in 1999 (USCB

46 2003). The 1999 Federal poverty threshold was $17,029 for a family of four.

Draft NUREG-1437, Supplement 39 4-34 October 2009
Environmental Impacts of Operation

1 According to Census data estimates, the median household income for Minnesota in 2005-2007

2 was $55,616, with 9.6 percent of the state population living below the Federal poverty threshold.

3 For the same time period, Goodhue County had a slightly lower median household income

4 average ($55,098) and a lower percentage (7.9 percent) of individuals living below the poverty

5 level when compared to the state average. Dakota County had much higher median household

6 income ($72,393) and a lower percentage (5.3 percent) of individuals living below the poverty

7 level when compared to the state and Goodhue County. The median household income for

8 Wisconsin in 2005-2007 was $50,309, with 10.8 percent of the state population living below the

9 Federal poverty threshold. For the same time period, Pierce County had a higher median

10 household income average ($58,011) and a lower percentage (6.9 percent) of individuals living

11 below the poverty level when compared to the state average (USCB 2008).

12 Census block groups were considered high density low-income block groups if the percentage

13 of households below the Federal poverty threshold exceeded the state average by 20 percent or

14 more. Based on 2000 Census data, there were 89 block groups within the 50-mi (80-km) radius

15 of PINGP 1 and 2 that exceeded the state average for low income households by 20 percent or

16 more. The majority of census block groups with low-income populations were located in two

17 counties, Hennepin County (61 block groups) and Ramsey County (23 block groups) in

18 Minnesota. The nearest high density low-income population to PINGP 1 and 2 is located in

19 Minneapolis-St. Paul, Minnesota (NMC 2008). Figure 4-3 shows the location of high density

20 low-income census block groups within a 50-mi (80-km) radius of PINGP 1 and 2.

21 Analysis of Impacts

22 As Cooperating Agencies, the NRC staff consulted with the PIIC during its environmental review

23 of the proposed license renewal for PINGP 1 and 2 to develop analyses of certain impacts. As a

24 result of such consultation, the information presented in this section represents the two different

25 approaches used by the NRC staff and PIIC in conducting their independent analyses of

26 environmental justice.

27 The NRC Staff's Analysis of Environmental Justice

28 As discussed earlier, the NRC addresses environmental justice matters for license renewal

29 through (1) identification of any low income and/or minority populations that may be

30 disproportionately affected by the proposed license renewal, and (2) examining any

31 disproportionately high and adverse human health or environmental effects on such

32 populations.

33 The discussion and figures above indentifies the minority and low-income populations who

34 reside within a 50-mi (80-km) radius of PINGP 1 and 2. This area of impact is consistent with

35 the impact analysis for public and occupational health and safety, which also focuses on

36 populations within a 50-mi (80-km) radius of the plant. The PIIC, which is considered a minority

37 population in this analysis, is located immediately north and adjacent to the NSP property within

38 1-mi (1.6-km) of PINGP 1 and 2. Because of its proximity to the plant and the uniqueness of the

39 community, NRC staff acknowledges that there may be the potential for disproportionate

40 impacts to the PIIC. However, as discussed in the previous sections of Chapter 4 of this SEIS,

41 the analyses of impacts for all resource areas (e.g., land, air, water, ecology, human health, and

42 socioeconomics), with the one exception of historic and archaeological resources, indicated that

43 the impact from license renewal would be SMALL. As discussed in Section 4.9.6, the

44 MODERATE finding of impacts on historic and archaeological resources is based on the known

45 proximity of the site to cultural resources and the high potential for future discovery of additional

46 resources. However, given the applicant's proposed mitigation strategies, as outlined in Section

47 4.9.6, the staff believes that adequate measures are in place to address such potential future

48 impacts to historic and archaeological resources.

October 2009 4-35 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

(0 Prairie Island Indian Community

Figure 4-1 Prairie

Island Indian

Community Trust Land

Boundary

Source PIIC 2009

1

2

Draft NUREG-1437, Supplement 39 4-36 October 2009
Environmental Impacts of Operation

1

2

October 2009 4-37 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

1

2

Draft NUREG-1437, Supplement 39 4-38 October 2009
Environmental Impacts of Operation

1 Further, Chapter 5 of this SEIS discusses the both the environmental impacts and

2 environmental justice impacts from postulated accidents that might occur during the period of

3 extended operation for PINGP 1 and 2, which include design basis accidents. The Commission

4 has generically determined that impacts associated with such accidents are SMALL because

5 the plants were designed to successfully withstand design basis accidents.

6 In addition, Chapter 3 of this SEIS discusses the environmental justice impacts of refurbishment

7 activities at PINGP 1 and 2. As discussed above, NSP has indicated that PINGP, Unit 2, steam

8 generators would be replaced prior to the license renewal term. NSP estimates that steam

9 generator replacement would require a one-time increase in the number of refueling outage

10 workers for up to 80 days at PINGP 1 and 2 site (NMC 2008). Additionally, section 3.2.8 of this

11 draft SEIS concludes that the steam generator replacement would have a SMALL to

12 MODERATE impact on transportation. The NRC staff evaluated whether such an increase in

13 the workforce could have a disproportionate effect on the PIIC, and whether these effects could

14 be considered adverse. It is important to note that these impacts are of short duration, and are

15 not expected to be high.

16 Therefore, based on the overall findings discussed in Chapters 3, 4, and 5 of this SEIS, and a

17 further examination to see if any of the resource impacts could present a unique adverse impact

18 to an affected population, the staff concludes that there exists no disproportionately high and

19 adverse impacts to the PIIC or any other minority and low-income populations from the

20 continued operation of PINGP 1 and 2 during the license renewal period.

21 As part of addressing environmental justice associated with license renewal, the NRC staff also

22 analyzed the risk of radiological exposure through the consumption patterns of special pathway

23 receptors, including subsistence consumption of fish, native vegetation, surface waters,

24 sediments, and local produce; absorption of contaminants in sediments through the skin; and

25 inhalation of plant materials. As discussed below, the special pathway receptors analysis is

26 important to the environmental justice analysis because consumption patterns may reflect the

27 traditional or cultural practices of minority and low-income populations in the area.

28 Subsistence Consumption of Fish and Wildlife

29 Section 4-4 of Executive Order 12898 (1994) directs Federal agencies, whenever practical and

30 appropriate, to collect and analyze information on the consumption patterns of populations that

31 rely principally on fish and/or wildlife for subsistence and to communicate the risks of these

32 consumption patterns to the public. In this SEIS, NRC considered whether there were any

33 means for minority or low-income populations to be disproportionately affected by examining

34 impacts to American Indian, Hispanic, and other traditional lifestyle special pathway receptors.

35 Special pathways that took into account the levels of contaminants in native vegetation, crops,

36 soils and sediments, surface water, fish, and game animals on or near PINGP 1 and 2 were

37 considered.

38 NSP has an ongoing comprehensive Radiological Environmental Monitoring Program (REMP)

39 at PINGP 1 and 2 to assess the impact of site operations on the environment. To assess the

40 impact of the plant on the environment, the radiological monitoring program at PINGP 1 and 2

41 uses indicator-control sampling. Samples are collected at nearby indicator locations downwind

42 and downstream from the plant and at distant control locations upwind and upstream from the

43 plant. A plant effect would be indicated if the radiation level at an indicator location was

44 significantly larger than at the control location. The difference would also have to be greater

45 than could be accounted for by typical fluctuations in radiation levels arising from other

46 naturally-occurring sources.

October 2009 4-39 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

1 Samples are collected from the aquatic and terrestrial pathways in the vicinity of PINGP

2 1 and 2. The aquatic pathways include fish, Mississippi River surface water, groundwater, and

3 sediment. The terrestrial pathways include airborne particulates, milk, and food product garden

4 (leaf) vegetation, and direct radiation. During 2007, analyses performed on collected samples

5 of environmental media showed no significant or measurable radiological impact from PINGP 1

6 and 2 site operations (NMC 2008b).

7 Aquatic sampling in the vicinity of PINGP 1 and 2 consists of semi-annual upstream and

8 downstream collections of fish, periphyton (algae) or invertebrates, and bottom sediments.

9 Shoreline sediment is collected semi-annually from one location. All samples are analyzed for

10 gamma-emitting isotopes. River water is collected weekly at two locations, one upstream of the

11 plant and one downstream. Monthly composites are analyzed for gamma-emitting isotopes.

12 Quarterly composites are analyzed for tritium. Drinking water is collected weekly from the City

13 of Red Wing well. Monthly composites are analyzed for gross beta, iodine-131, and gamma14 emitting isotopes. Quarterly composites are analyzed for tritium (NMC 2008b).

15 Fish were collected in May and October 2007, and analyzed for gamma emitting isotopes. Only

16 naturally-occurring potassium-40 was detected, and there was no significant difference between

17 upstream and downstream results. There was no indication of an effect from plant operations

18 (NMC 2008b).

19 Tritium activity was below the lower level of detection in all drinking water samples taken from

20 the City of Red Wing well, and no measurable tritium activity was detected in river water. Well

21 water data for 2007 showed no radiological effects from plant operation (NMC 2008b).

22 Upstream and downstream recreational area shoreline sediments were sampled and analyzed

23 for isotopes. With the exception of naturally occurring potassium-40, all gamma-emitting

24 isotopes were below their respective detection limits. There was no indication of a plant effect

25 (NMC 2008b).

26 According to PINGP 1 and 2 REMP, milk samples are collected monthly from six farms (five

27 indicator and one control) and analyzed for iodine-131 and gamma-emitting isotopes. The milk

28 is collected biweekly during the growing season (May - October), when milk animals may be on

29 pasture. Green leafy vegetables (cabbage) are collected annually and analyzed for gamma30 emitting isotopes, including iodine-131. Corn is collected annually only if fields are irrigated with

31 river water and analyzed for gamma-emitting isotopes. Well water and ground water are

32 collected quarterly from four locations near the plant and analyzed for tritium and gamma33 emitting isotopes (NMC 2008b).

34 Iodine-1 31 and cesium-1 37 results were below the lower levels of detection in all milk samples.

35 No other isotopes, except naturally-occurring potassium-40, were detected. The milk sampling

36 data for 2007 is consistent with previous results and show no radiological effects from plant

37 operation (NMC 2008b).

38 Three samples of broadleaf vegetation, cabbage leaves, were collected and analyzed for

39 gamma-emitting isotopes, including iodine-131. With the exception of naturally-occurring

40 potassium-40, all other isotopes were below their respective detection limits. There was no

41 indication of a plant effect (NMC 2008b).

42 The results of the 2007 REMP demonstrate that the routine operation at PINGP 1 and 2 had no

43 significant or measurable radiological impact on the environment. No elevated radiation levels

44 were detected in the offsite environment as a result of plant operations and the storage of

45 radioactive waste. The results of the REMP continue to demonstrate that the operation of

46 PINGP 1 and 2 did not result in a significant measurable dose to a member of the general

47 population or adversely impact the environment as a result of radiological effluents. The REMP

Draft NUREG-1437, Supplement 39 4-40 October 2009
Environmental Impacts of Operation

1 continues to demonstrate that the dose to a member of the public from the operation of PINGP

2 1 and 2 remains significantly below the federally required dose limits specified in 10 CFR 20, 10

3 CFR 72, and 40 CFR 190.

4 The Minnesota Department of Health (MDH), Radioactive Materials Unit in the Indoor

5 Environments and Radiation Section monitors environmental radioactivity in Minnesota.

6 Minnesota has maintained a radioactivity monitoring program since 1953. The MDH Radiation

7 Control Unit currently maintains off-site environmental radiation monitoring programs around

8 two nuclear power plants in Minnesota including PINGP 1 and 2.

9 Each year, MDH's Radiation Control Unit collects dosimetry, air, river water, milk, food crop, and

10 sediment samples in the vicinity of PINGP 1 and 2. Samples of apples and cow feed were

11 collected by MDH in the vicinity of PINGP 1 and 2 from 2004 through 2006. MDH found no

12 reactor-related radioisotopes in milk and food crop samples collected from 2004 through 2006

13 (MDH Undated).

14 Based on recent monitoring results, concentrations of contaminants in native leafy vegetation,

15 soils and sediments, surface water, and fish in areas surrounding PINGP 1 and 2 have been

16 quite low (at or near the threshold of detection) and seldom above background levels.

17 Consequently, no disproportionately high and adverse human health impacts would be

18 expected in special pathway receptor populations in the region as a result of subsistence

19 consumption of fish and wildlife.

20 The Prairie Island Indian Community's Analysis of Environmental Justice

21 As discussed in Chapter 1, the PIIC is a Cooperating Agency for developing four areas of the

22 PINGP 1 and 2 SEIS: historic and archaeological resources, socioeconomics, land use, and

23 environmental justice. While these four areas are important to the Tribe, a tenet of Dakota

24 culture is the belief that all things are related, "Mitakuye Oyasin," and that one cannot separate

25 one aspect of the environment from another. Mitakuye Oyasin, literally translated, means "to all

26 my relations" or "we are all related." Mitakuye Oyasin is a prayer, an acknowledgement that

27 honors the sacredness of all people and of all life. In other words, the community's health and

28 well-being and culture are dependent upon the health of the natural environment-the water,

29 the fish, the birds, the air, the plants, cultural sites, that are all interrelated as part of an

30 ecosystem that is Prairie Island.

31 The following discussion is provided by the PIIC (PIIC 2008).

32 Most members of the Prairie Island Indian Community believe that PINGP 1 and

33 2 was built at its location because, at that time, the Tribe was in no position to

34 fight it. In the late 1960s members of the tribe were quite poor and totally

35 disenfranchised. The City of Red Wing fully supported the $200 million project,

36 as the city would benefit tremendously from it. The city quickly annexed the-then

37 NSP land (exclusive of the Prairie Island Indian Community) so that PINGP 1 and

38 2 would become part of its tax base. Jobs were promised, but very few Tribal

39 members have ever worked at PINGP 1 and 2.

40 PINGP 1 and 2 were built right next to the Tribe's land. This land was acquired

41 for the Prairie Island Indian Community by the United States government for the

42 common benefit of all tribal members, in perpetuity. This was the only land the

43 tribe had, the land promised to them by the Federal government, the land that

44 would allow the Prairie Island Indian Community to maintain its traditions and

45 culture. If members started leaving, how could the Prairie Island Indian

46 Community continue to function as an Indian tribe?

October 2009 4-41 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

1 The Tribal Council believes that the impacts to Tribal members are

2 disproportionately high and adverse. That is, the Tribe assumes all of the risks

3 associated with the operation of PINGP 1 and 2, including the Independent Spent

4 Fuel Storage Installation (ISFSI) and the high-voltage transmission lines, and

5 receives virtually no benefit. The Prairie Island Indian Community is subjected to

6 a number of impacts that have a potential integrated and cumulative effect:

7 Human health impacts

8 Due to the Prairie Island Indian Community's close proximity to PINGP 1 and 2

9 (within 0.5 mi [0.8 km]), Tribal members believe that they are at an increased risk

10 for health effects (such as increased cancer vulnerability). The Tribal Council

11 believes that the health of tribal members has not been adequately studied.

12 Members of the Prairie Island Indian Community may have exposure pathways

13 (water, food, air) that may be different from the typical or "average" consumer,

14 thereby placing the tribal consumer at a greater risk. For example, many tribal

15 members consume native plants for traditional purposes (direct consumption,

16 medicines, teas, ceremonies) that are not typically part of the Radiological

17 Environmental Monitoring Program (REMP). Many of our Tribal members have

18 been living on Prairie Island since the plant went on-line. Tribal members

19 typically do not move in and out of the community. We are concerned about the

20 human health effects from 60 years of low-level exposure, as many of our tribal

21 members already have compromised health.

22 The annual REMP reports and Radioactive Effluent Reports are insufficient to

23 establish baselines for radiological effluent releases, exposure pathways, and

24 dose estimates. Consequently, the analysis of the cumulative and integrated

25 impacts on the Tribe, its members and its environment caused by the PINGP's

26 operation is deficient.

27 The following paragraph is from the National Academy of Sciences Institute of

28 Health, Toward Environmental Justice: Research, Education, and Health Policy

29 Needs (National Academy Press 1999), p. 11.

30 "The premise of environmental justice is that communities with high

31 concentrations of racial or ethnic minorities or low-income families are

32 disproportionately exposed to a variety of environmental burdens and hazards.

33 Of particular interest for this report is the specific claim that such exposures

34 produce adverse health outcomes that are also borne disproportionately by these

35 populations. An assessment of baseline data is therefore essential to

36 ascertaining the relative role of environmental exposure in determining the health

37 of a population."

38 Just one of the radioactive nuclides released by the PINGP, tritium, can be

39 analyzed as a tracer for all radioactive emissions. Based on available

40 information, annual liquid tritium emissions at PINGP have steadily increased

41 during the 35 years of plant operation by approximately 1.2 Ci per year, with a

42 peak liquid tritium emission of 800 Ci in 2006 (2006 PINGP Annual Radioactive

43 Effluent Report).

44 Tritium has also been found in the Tribe's drinking water. In the late-1980

45 through early-1 990 time frame, above-normal background levels of tritium were

46 detected in wells around PINGP 1 and 2. Although the detected levels of tritium

47 were below the EPA standard of 20,000 picocuries per liter (pCi/L), the range

Draft NUREG-1437, Supplement 39 4-49 October 2009
Environmental Impacts of Operation

1 detected (1,300 - 1,500pCi/L) was above what was detected in other wells (300

2 - 400 pCi/L). At that time, all community members were utilizing individual wells.

3 In response, the Community developed its current central water system in 1992,

4 which utilizes a deep well (500 ft [150 ml). The detected tritium levels are below

5 the EPA drinking water standard of 20,000 pCi/L. The BEIR VII 2006 on

6 radiation health effects, however, states that the Linear-No-Threshold standard

7 should apply to chronic low dose exposure for potential cause of cancer and

8 other radiation-induced diseases.

9 Review and analysis of PINGP's Annual Radioactive Effluent Reports reveals the

10 results of the ongoing efforts to monitor tritium, including disturbing spikes and

11 fluctuations. For example, the 2006 Annual Radioactive Effluent Report (May

12 2007) disclosed tested tritium levels for the year in Well P-10 fluctuating from a

13 low of 432 pCi/L to a peak of 3,773 pCi/L in September 2006. The 2008 Annual

14 Radioactive Effluent Report (May 2009) showed that there were abnormal

15 releases of tritium from the turbine building sump water discharge in July of 2008.

16 As well, there seem to be corresponding increases in tritium detected in nearby

17 (on-site) monitoring wells (2008 PINGP REMP Report). The detected level in July

18 2008 sample (at well P-10) was 2,060 pCi/L, when most other samples were <19

19 to 112 pCi/L; one sample contained 412 pCi/L. The abnormal spikes and

20 fluctuations have not been satisfactorily explained, and the problem of tritium

21 entering the groundwater does not seem to have been resolved.

22 Radiological releases from PINGP 1 and 2 and gamma radiation from the ISFSI

23 are a concern to tribal members. Tribal members reside within 600 yds (550 m)

24 of the PINGP 1 and 2 site. The Tribal Council is concerned about the health

25 impacts from chronic exposure to low levels of radiation. Moreover, the

26 proposed extended power uprate for PINGP 1 and 2 is expected to increase

27 radiological releases by 10 percent.

28 Most tribal members believe that the spent fuel stored at PINGP 1 and 2 will

29 never leave. Each day the "temporary" waste storage at PINGP 1 and 2

30 becomes more permanent. It is expected that up to 98 casks will be in use at

31 PINGP 1 and 2, once the plant is decommissioned. Furthermore, under

32 proposed changes to the waste confidence rule, the 98 casks could conceivably

33 be on Prairie Island until 2094. This is an unacceptable and untenable situation.

34 In 2005, we commissioned a public health study (conducted by the University of

35 Minnesota), which documented that many of our youth experience increased

36 levels of stress and anxiety because of health and safety fears related to the

37 power plant. These are the same youth who will be our future leaders, the

38 people with whom future NSP and NRC representatives will be working over the

39 re-licensing period (McGovern, et al. 2006). We do not believe that children in

40 any other communities worry about whether they will have a home to go to, if an

41 accident were to occur.

42 There are a number of homes within 100 ft (30 m) of the north-south 345 Kv

43 transmission lines coming from PINGP 1 and 2. The lines are located on the

44 east side of Edoka Street and the homes are located on the west side of Edoka

45 Street. We understand that there is no consensus among scientists whether the

46 electromagnetic energy emanating from the power lines would have a

47 measurable human health impact. Some studies suggest exposure to EMF's

48 increases the risk for certain diseases.

October 2009 4-43 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

1 Since there is no scientific consensus on whether human health is compromised,

2 however, the Tribe believes that there is NO assurance that there are NO

3 adverse health effects (i.e., chronic health effects, increased risks to cancer).

4 There have been accidents or events at PINGP 1 and 2 that have undermined

5 our confidence in plant operations. In 1979, there was an accident at PINGP 1

6 and 2 which released radioactive gas into the atmosphere. The cause of the

7 accident was a rupture of a 1-in (2.54-cm) tube in Unit l's steam generator. The

8 accident happened at 2:30 in the afternoon; no one from the Community was

9 notified of the event nor told to shelter in place. It was not until community

10 members noticed workers from the PINGP 1 and 2 site leaving the island, or

11 later, watching the news, did any one from the tribe know about the event.

12 After NSP loaded its first dry cask (after a very controversial and protracted State

13 approval process) in the spring of 1995, the cask was left dangling over the spent

14 fuel pool for several hours because of a malfunctioning crane. In addition, a

15 Notice of Violation (NOV) was issued to NSP by the NRC because of problems

16 with the manufacturing of the first casks.

17 In 2006, several outage workers were unexpectedly exposed to radiation. This

18 was not reported to the media or anyone else. A journalist with one of the local

19 papers spotted the notice of the event on the NRC's website. The Governor of

20 Minnesota had not been informed of the event and learned about it through the

21 media. In fact, the Tribal Council President and the Governor were at the same

22 meeting when the news broke.

23 Most recently, the NRC has identified declining human performance as

24 substantive cross cutting issue at the PINGP 1 and 2. This was noted by the

25 NRC during the May 2009 Performance Assessment meeting and the September

26 1, 2009 Mid-Cycle Performance Review letter. That the PINGP is also in the

27 NRC's Regulatory Response Column instead of the Licensee Response column

28 is also cause for concern. These recent developments are sending us a

29 troubling signal about future performance at the PINGP.

30 These recent developments only serve to heighten existing concerns regarding

31 the future performance and safety at the PINGP 1 and 2. At a time when Xcel is

32 seeking approval from the NRC to extend the operation of the PINGP 1 and 2

33 another 20 years, and also seeking approval from the Minnesota Public Utilities

34 Commission to increase the output of PINGP 1 and 2 by 10%, the declining

35 human performance finding is especially disconcerting. The public, and

36 especially PINGP's closest neighbors, have significant concerns about the

37 operation of PINGP's aging systems and equipment at increased temperatures,

38 pressures, stresses and tolerances for an additional 20 years when human

39 performance is declining.

40 Socioeconomic impacts

41 As discussed above, the Prairie Island Indian Community bears the greatest risk,

42 yet receives virtually no benefit from the operation of PINGP 1 and 2. As

43 discussed in Chapter 2, the tribe signed an agreement with NSP in 2003, but the

44 amount of funding received by the Tribe pales in comparison to the amount that

45 has been provided to the City of Red Wing or Goodhue County, via taxes, since

46 PINGP 1 and 2 went on-line.

Draft NUREG-1437, Supplement 39 4-44 October 2009
Environmental Impacts of Operation

1 The Tribe has spent substantial amounts of money in legal and consultant fees in

2 order to protect its interests and participate in various NSP proceedings at either

3 the State or Federal level. There is no other governmental entity (e.g., City of

4 Red Wing, Goodhue County, or the State of Minnesota) that participates in these

5 proceedings at the same level as the Tribe. This is money that could be used for

6 other community purposes; the Tribe believes that this impact must be

7 considered.

8 There is only one primary access route (Sturgeon Lake Road) to and from the

9 reservation. Sturgeon Lake Road is also crossed by railroad lines. Twenty to

10 thirty trains (and their hazardous commodities) and maintenance equipment (and

11 crews) cross this intersection daily and occasionally block this only access road

12 for up to 30 minutes. Many people are fearful that, in the vent of a radiological

13 emergency, tribal members would be trapped on the island.

14 As discussed in Chapter 3, there will be traffic impacts to the Community during the

15 refurbishment period. NSP will hire as many as 750 additional workers for PINGP 1 and

16 2, Unit 2, steam generator replacement project. The NRC staff has determined that the

17 Prairie Island Indian Community will be disproportionately impacted by the project,

18 because of the Community's proximity to the PINGP 1 and 2 site.

19 The tribe has also had to develop its own radiological emergency preparedness

20 (REP) program, with little outside.financial assistance. As mentioned previously,

21 the tribe has only recently begun to receive limited funding from NSP for REP

22 planning, but it can only be used for training, travel, and supplies. The tribe

23 covers salary and related costs.

24 Subsistence Consumption of Fish and Wildlife

25 Most members of the Community do not consume fish from the Mississippi River

26 (Sturgeon Lake) because of pollution concerns (either from PINGP 1 and 2 or

27 from other upstream dischargers). There are tribal members who hunt on tribal

28 lands, but to the best of our knowledge, there are no longer any subsistence29 level consumers.

30 In addition, the tribe does not have any information pertaining to wildlife or game

31 sampling or testing conducted by state agencies either before or after the plant

32 was constructed.

33 In the past, the tribe has collaborated with the US Fish and Wildlife Service

34 (USFWS) and the US Environmental Protection Agency (US EPA) to collect and

35 test Sturgeon Lake fish and turtle samples for heavy metals, PCB's and

36 radionuclides.

37 Because of the aforementioned impacts, the PIIC believes that environmental

38 and human health impacts to the PIIC from the relicensing of PINGP 1 and 2 are

39 disproportionately high and adverse. Further, the PIIC believes that no other

40 minority or low income community will be affected by these issues over the 20

41 year extended operating period.

42 Environmental Justice Summary

43 As previously stated, the views presented in the sections above represent the different analyses

44 used by the NRC staff and PIIC in addressing environmental justice. The NRC staff based its

45 determination on, among other considerations, the individual impact analyses discussed in

46 Chapter 4 of this DSEIS, particularly regarding Radiological Impacts (Section 4.8.1),

October 2009 4-45 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

1 Electromagnetic Fields (Sections 4.8.4), Socioeconomics (Section 4.9), and Historic and

2 Archeological Resources (Section 4.9.6) to conclude that there exists no disproportionate high

3 and adverse impacts to the PIIC or any other minority and low-income populations from the

4 continued operation of PINGP 1 and 2 during the license renewal period.

5 4.10 Evaluation of New and Potentially Significant Information

6 New and significant information is (1) information that identifies a significant environmental issue

7 not covered in the GElS and codified in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, or

8 (2) information that was not considered in the analyses summarized in the GElS and that leads

9 to an impact finding that is different from the finding presented in the GElS and codified in 10

10 CFR Part 51.

11 In preparing to submit its application to renew the PINGP 1 and 2 operating license, NSP

12 developed a process to ensure that information not addressed in or available during the GElS

13 evaluation regarding the environmental impacts of license renewal for PINGP 1 and 2 would be

14 properly reviewed before submitting the ER, and to ensure that such new and potentially

15 significant information related to renewal of the operating license for PINGP 1 and 2 would be

16 identified, reviewed, and assessed during the period of NRC review. NSP reviewed the

17 Category 1 issues that appear in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, to verify

18 that the conclusions of the GElS remained valid with respect to PINGP 1 and 2. This review was

19 performed by personnel from PINGP 1 and 2 and its support organization who were familiar with

20 NEPA issues and the scientific disciplines involved in the preparation of a license renewal ER.

21 The NRC staff also has a process for identifying new and significant information. That process is

22 described in detail in NUREG-1 555, Supplement 1, Standard Review Plans for Environmental

23 Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal (NRC 2000).

24 The search for new information includes (1) review of an applicant's ER and the process for

25 discovering and evaluating the significance of new information; (2) review of records of public

26 comments; (3) review of environmental quality standards and regulations; (4) coordination with

27 Federal, state, and local environmental protection and resource agencies; and (5) review of the

28 technical literature. New information discovered by the NRC staff is evaluated for significance

29 using the criteria set forth in the GElS. For Category 1 issues where new and significant

30 information is identified, reconsideration of the conclusions for those issues is limited in scope to

31 the assessment of the relevant new and significant information; the scope of the assessment

32 does not include other facets of the issue that are not affected by the new information.

33 The NRC staff has not identified any new and significant information on environmental issues

34 listed in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, related to the operation of PINGP

35 1 and 2 during the period of license renewal. The NRC staff also determined that information

36 provided during the public comment period did not identify any new issues that require site37 specific assessment. The NRC staff reviewed the discussion of environmental impacts in the

38 GElS (NRC 1996) and conducted its own independent review (including the public scoping

39 meetings held in July 2008) to. identify new and significant information.

40 4.11 Cumulative Impacts

41 The NRC staff considered potential cumulative impacts in the environmental analysis of

42 continued operation of PINGP 1 and 2. For the purposes of this analysis, past actions are those

43 related to the resources at the time of the power plant licensing and construction, present

44 actions are those related to the resources at the time of current operation of the power plant,

45 and future actions are considered to be those that are reasonably foreseeable through the end

Draft NUREG-1437, Supplement 39 4-46 October 2009
Environmental Impacts of Operation

1 of plant operation including the period of extended operation. Therefore, the analysis considers

2 potential impacts through the end of the current license terms as well as the 20-year renewal

3 license term. The geographic area over which past, present, and future actions would occur is

4 dependent on the type of action considered and is described below for each impact area.

5 The impacts of the proposed action, as described in Sections 4.1-4.9, are combined with other

6 past, present, and reasonably foreseeable future actions regardless of what agency (Federal or

7 non-Federal) or person undertakes such other actions.

8 4.11.1 Cumulative Impacts on Aquatic and Water Resources

9 This section addresses past, present, and future actions that together could result in adverse

10 cumulative impacts to aquatic and water resources, including water use, water quality, shoreline

11 and river conditions, fish and shellfish populations, and invasive species. For the purposes of

12 this analysis, the geographic area considered includes the section of the river adjacent to

13 PINGP 1 and 2, Pool 3, as well as Pools 2 and 4, which lie upstream and downstream of PINGP

14 1 and 2, respectively.

15 The character and nature of the Upper Mississippi River was significantly and permanently

16 changed by the construction of the Lock and Dam system in the 1930s to achieve 9-ft (3-m)

17 navigation channels. The operation and continued maintenance involved with this system

18 continues to affect the aquatic and water resources and alters sedimentation and resuspension

19 of sediments; bottom type; flow and channelization; season patterns of flow that cue many

20 biological processes; habitat diversity that provides areas for fish to spawn, rest, reproduce,

21 feed, and grow; fish movements and migrations; and distribution of mussels and other aquatic

22 resources. USACE continues to undertake projects that have both negative and positive effects

23 on the ecology and hydrology of the Mississippi River.

24 The upper Mississippi River was significantly and permanently changed by the construction of

25 the Lock and Dam system in the 1930s, which created 9-ft (2.7-m) navigation channels along

26 the river. The operation and continued maintenance of this system continues to affect the

27 aquatic resources by alterting sedimentation, flow, channelization, fish movements, and mussel

28 distribution.

29 As mentioned previously in Section 2.1.7.3, nitrogen enrichment is an important water quality

30 issue in the upper Mississippi River. The influx of nitrogen from the Mississippi into the Gulf of

31 Mexico creates a zone of decreased dissolved oxygen (hypoxia), and the Minnesota area

32 contributes an estimated five to six percent of that nitrogen (EPA 2006).

33 A 2000 study (Stark et al. 2000) found that water quality in the upper Mississippi River is

34 primarily influenced by agricultural and urban pesticides and fertilizers, wastewater treatment

35 facility discharges, agricultural and urban runoff, stream modifications and artificial drainage

36 routes, loss of riparian cover, and contamination from precipitation. Fertilizer and agricultural

37 animal waste in particular are thought to be major nitrogen contributors to the Mississippi. Stark

38 et al. (2000) also indicated that the main influences on groundwater contamination are

39 pesticides and fertilizers, urban contaminants, and naturally occurring radon gas. The study also

40 highlighted the influence of confining units and water depth. Because the aquifer utilized at

41 PINGP 1 and 2 is shallow and largely confined from the main aquifer used by both the Prairie

42 Island Indian Community (PIIC) and the city of Red Wing, Stark et al. (2000) concluded that

43 cross contamination interaction between these two water sources should be minimal.

44 The MPCA developed a Basin Plan for the Upper Mississippi to reduce river pollution (MPCA

45 2008). The plan includes best management practices to reduce nitrogen and phosphorus

46 discharges into the river. It also includes several local water quality studies, the largest of which

October 2009 4-47 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

1 are the National Water Quality Assessment Program in the Upper Mississippi River Basin and

2 the USACE Upper Mississippi River Reconnaissance Study. The purpose of these water quality

3 studies is to gather more information about the pollution problems in the Upper Mississippi so

4 action can be taken to solve some of the problems (MPCA 2000). The MPCA also directs large

5 water quality studies by the Minnesota River Basin Data Center (MRBDC). In 2000, the MRBDC

6 concluded that the Upper Mississippi is severely impaired by high concentrations of both

7 nutrients and sediment (MRBDC 2000). Efforts are underway to consider regulations that would

8 improve water and sediment quality and reduce hypoxia in the Mississippi River and its

9 discharge in the Gulf of Mexico. For example, the Upper Mississippi River Basin Association

10 (2007) Water Quality Task Force is investigating sediment-related water quality criteria for the

11 Upper Mississippi River, and EPA is considering a petition for rulemaking to replace narrative

12 water quality criteria for nutrients in the Mississippi River Basin with numerical criteria (USEPA

13 2008, Anon. 2009). These efforts could have a positive effect on cumulative impact.

14 PINGP 1 and 2 are located next to the PIIC. Based on information gathered during the site visit,

15 the PIIC has a water treatment plant onsite that appears to discharge to the Mississippi River.

16 NRC staff was unable to determine if this discharge was permitted by the MPCA. The

17 community also has a large marina that brings a high frequency of boat traffic to the area. The

18 increase in recreational boat traffic over the past few decades has contributed to increased

19 erosion on the bottom of the river. Some small islands that used to exist near PINGP 1 and 2

20 are now almost completely submerged. The PIIC frequently dredges the main channel of

21 Sturgeon Lake in order to maintain a navigable water depth for the marina traffic. Such dredging

22 may disturb or destroy benthic communities.

23 PINGP 1 and 2 are located along Sturgeon Lake, a side slough connected to Navigation Pool 3,

24 which is created by the upstream Lock and Dam 3. In late 2007, the USACE drafted a proposal

25 to improve the quality of the water and emergent aquatic vegetation disturbed by the high

26 elevations of water created by Lock and Dam 3. The project plans to use a seasonal summer

27 drawdown of the water elevations in Sturgeon Lake. The hydrologic goal of the project is to

28 improve water quality by way of sediment consolidation, reducing fetch, improving water clarity,

29 and reducing nitrogen levels. The drawdown would also return the hydrologic cycle to a more

30 natural state to induce the growth of aquatic vegetation. Based on information gathered at the

31 site audit, including the observation that the pool elevation drop is not severe enough to

32 significantly reduce the flow of the river at PINGP 1 and 2, the NRC believes the implementation

33 of this project is unlikely to hinder water intake operations at PINGP 1 and 2, and would be

34 beneficial to the water and aquatic resources of the area. (USACE 2007)

35 Pool 4, which is located downstream of PINGP 1 and 2, contains Lake Pepin. The USACE

36 monitor ice coverage in the area. Along with other contributing factors, thermal effluent from

37 PINGP 1 and 2 could in part be responsible for the deterioration of the ice cover in Lake Pepin.

38 NSP has indicated that they are planning to submit an application for a power uprate in the

39 future, which could increase the amount of thermal effluent. In a letter to the Minnesota

40 Department of Commerce, MNDNR expressed concern that, unless appropriate measures are

41 taken, the thermal plume could have an increased negative effect on the ice cover of Lake

42 Pepin (MNDNR 2008a). NRC assumes that changes in ice cover would impact biological

43 communities. If in the future NSP does move forward with a power uprate application, the

44 potential impacts associated with that action would be addressed by the NRC at that time.

45 The spread of an invasive species, the zebra mussel (Dreissena polymorpha), throughout the

46 Mississippi River has had a devastating impact on native mussel populations in the area.

47 Currently, zebra mussels have not infiltrated Pool 3 as they have other pools. As discussed in

48 Section 2.2.7 and 4.7.1, the FWS, the USACE, and the Mussel Coordination Team are engaged

49 in a relocation project to aid in the recovery of the endangered Higgins eye pearlymussel. One

Draft NUREG-1437, Supplement 39 4-43 October 2009
Environmental Impacts of Operation

1 of the relocation sites is in Pool 3, just half a mile upstream of the cooling water intake structure

2 of PINGP 1 and 2. As of 2005, the project has reported "good recovery" in Pool 3 (Mussel

3 Coordination Team 2005).

4 The NRC staff concludes that the minimal impacts of the continued operation of PINGP 1 and 2

5 to aquatic and water resources would not contribute to an overall decline in the current condition

6 of these resources. However the impacts of other past, present, and future actions, including

7 dredging by the PIIC, water quality issues arising from agricultural and urban runoff, and most

8 notably, the creation of the Lock and Dam system have had and will continue to have a

9 significant impact on the Upper Mississippi River, including Pools 2, 3, and 4; therefore, the

10 cumulative impacts on these resources are MODERATE to LARGE.

11 4.11.2 Cumulative Impacts on Terrestrial Resources

12 This section addresses past, present, and future actions that could result in adverse cumulative

13 impacts to terrestrial resources, including wildlife populations, upland habitats, wetlands,

14 riparian zones, invasive species, protected species, and land use. For purposes of this analysis,

15 the geographic area considered in the evaluation includes the PINGP 1 and 2 site and in-scope

16 transmission line ROWs.

17 Approximately 60 ac (24 ha) of the 578 ac (234 ha) of land on the PINGP 1 and 2 site are

18 developed and maintained for operation of PINGP 1 and 2 (NMC 2008). The site is situated on

19 a floodplain on the western bank of the Mississippi River. Before PINGP 1 and 2 were

20 constructed, the majority of the site's land was cultivated with some interspersed lowland forests

21 and swamp areas near the site (AEC 1973). Goodhue County, in which PINGP 1 and 2 is

22 located, and Dakota County, through which the Blue Lake and Red Rock 2 transmission lines

23 travel, are mostly rural, and soybeans, corn, oats, and hay are the predominately cultivated

24 crops (NMC 2008).

25 Construction of the transmission lines maintained by NSP and Great River Energy for PINGP 1

26 and 2 resulted in subsequent changes to the wildlife and plant species present within the vicinity

27 of PINGP 1 and 2. Due to the fragmentation of previously contiguous forested and swamp

28 areas, edge effects such as changes in light, wind, and temperature, changes in abundance and

29 distribution of interior species, reduced habitat ranges for certain species, and an increased

30 susceptibility to invasive species may have occurred in these areas. ROW maintenance has

31 likely had past impacts and is likely to have present and future impacts on the terrestrial habitat.

32 These impacts may include bioaccumulation of chemicals, prevention of the natural

33 successional stages of the surrounding vegetative communities in and around the ROWs, and

34 increase in abundance of edge species, a decrease in abundance of interior species, and an

35 increase in invasive species populations.

36 Protected terrestrial species, which are discussed in Section 2.2.7, are not expected to be

37 adversely affected due to future actions during the renewal term. Numerous wildlife refuges and

38 scientific and natural areas are located in the vicinity of the PINGP 1 and 2 site, and these will

39 continue to provide habitat to protected species and other wildlife. Habitat restoration efforts by

40 the FWS in the Upper Mississippi River National Wildlife and Fish Refuge will support

41 improvement of riverine habitat and native grass prairie.

42 The USACE, in conjunction with the MNDNR, Wisconsin Department of Natural Resources

43 (WDNR), and other Federal and state agencies are considering a 1 to 2 ft (0.3 to 0.6 m)

44 drawdown of Pool 3 for the purposes of improving aquatic habitat along this portion of the

45 Mississippi River (WDNR 2008). Drawdown of Pool 3 would expose more of the small islands

46 between the side and main channels of the river, which would create more riparian and wetland

47 habitat in these areas.

October 2009 4-49 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

1 The Treasure Island Resort and Casino is located about 1 mi (1.6 km) upstream of PINGP 1

2 and 2. The resort and casino is owned by the PIIC and includes a hotel, casino, and marina.

3 Additionally, the PIIC operate a wastewater treatment facility. Initial construction of the resort

4 and casino resulted in the loss of natural terrestrial habitat and fragmentation of previously

5 contiguous areas of prairie grasslands. Increased boating traffic in Pool 3 of the Mississippi

6 River as a result of the marina may cause increased erosion to riparian and wetland habitat

7 along the shorelines. The wastewater treatment plant discharges to the Mississippi River. Those

8 discharges may have current and future impacts on the surrounding vegetation, wetlands, and

9 wildlife. Bioaccumulation and food web transfer of chemicals throughout the terrestrial

10 environment also poses a threat to these habitats, as well as to riparian zones and wildlife

11 species.

12 The cities of Minneapolis and St. Paul lie 39 and 32 mi (63 and 52 km), respectively, northwest

13 of PINGP 1 and 2 (NMC 2008). Development of suburban housing and numerous interstate

14 roads in northern Goodhue County in the 1970s and 1980s spurred subsequent commercial and

15 industrial growth of the area in the 1990s (NMC 2008). Continued development of this area in

16 the future may result in additional runoff from roads and impervious surfaces, development

17 adjacent to wetlands and riparian zones, and an increase in waste releases, all of which could

18 have future impacts on the terrestrial habitat.

19 The NRC staff examined the cumulative effects of forest fragmentation, the spread of invasive

20 species, impacts to protected species, effects of neighboring facilities, and continued land

21 development in the Minnepolis-St.Paul area. The NRC staff concludes that the minimal

22 terrestrial impacts on the continued PINGP 1 and 2 operations would not contribute to the

23 overall decline in the condition of terrestrial resources. The NRC staff believes that the

24 cumulative impacts of other and future actions during the term of license renewal on terrestrial

25 habitat and associated species, when added to past, present, and reasonably foreseeable

26 future actions, would be SMALL.

27 4.11.3 Cumulative Human Health Impacts

28 The Radiological dose limits for protection of the public and workers have been developed by

29 the EPA and NRC to address the cumulative impact of acute and long-term exposure to

30 radiation and radioactive material. These dose limits are codified in 40 CFR Part 190 and 10

31 CFR Part 20. For the purpose of this analysis, the area within a 50-mi (80-km) radius of the

32 PINGP 1 and 2 site is considered. The REMP conducted by NSP in the vicinity of the PINGP 1

33 and 2 site measures radiation and radioactive materials from all sources, including the

34 Mississippi River; therefore, the monitoring program measures cumulative radiological impacts.

35 Monitoring results for the 5-year period from 2003 to 2007 were reviewed as part of the

36 cumulative impacts assessment. In Sections 2.2.7 and 4.3 of this draft SEIS, the staff concluded

37 that impacts of radiation exposure from operation of PINGP 1 and 2 during the renewal term to

38 the public and workers (occupational) are SMALL. The NRC and the State of Minnesota would

39 regulate any future actions in the vicinity of the PINGP 1 and 2 site that could contribute to

40 cumulative radiological impacts.

41 NSP does not intend to construct any additional reactors on the PINGP 1 and 2 site. However,

42 NSP is planning to replace the Unit 2 steam generators during the period of extended operation.

43 Such an action is not likely to result in a significant increase of liquid and gaseous radioactive

44 effluents being discharged than what is discharged during normal plant operations. Based on a

45 historical evaluation of the Unit 1 steam generator replacement, similar quantities of radioactive

46 gaseous effluents are expected to be generated during replacement activities. The replacement

47 of the PINGP Unit 2 steam generators is likely to result in a small increase in the amount of solid

Draft NUREG-1437, Supplement 39 4-50 October 2009
Environmental Impacts of Operation

1 radioactive waste generated. This is based on a temporary increase in the number of personnel

2 working at the plant which will result in more solid waste being generated during the outage and

3 any other associated related work. During an outage of this type, there will be an increased use

4 of protective clothing, safety equipment, increased use of filters, and a general increase in

5 generation of debris that will have to be disposed of as radioactive waste. However, the

6 increased volume is expected to be short-termed and within the range of solid waste that can be

7 safely handled by PINGP 1 and 2 during the period of extended operation. Therefore, the NRC

8 staff concludes that cumulative radiological impacts of continued operations of PINGP 1 and 2

9 are SMALL, and that no further mitigation measures are warranted.

10 The NRC staff determined that the electric-field-induced currents from the PINGP 1 and 2

11 transmission lines are well below the National Electric Safety Code recommendations for

12 preventing electric shock from induced currents. Therefore, the PINGP 1 and 2 transmission

13 lines do not appreciably affect the overall potential for electric shock from induced currents

14 within the analysis area. With respect to chronic effects of electromagnetic fields, although the

15 NRC staff considers the GElS finding of "not applicable" to be appropriate in regard to PINGP 1

16 and 2, the PINGP 1 and 2 transmission lines are not likely to contribute to the regional exposure

17 to extremely low frequency-electromagnetic fields (ELF-EMFs). Therefore, the NRC staff has

18 determined that the cumulative impacts of the continued operation of the PINGP 1 and 2

19 transmission lines would be SMALL.

20 4.11.4 Cumulative Socioeconomic Impacts

21 As discussed in Section 4.4 of this draft SEIS, continued operation of PINGP 1 and 2 during the

22 license renewal term would have no impact on socioeconomic conditions in the region beyond

23 what is currently being experienced. Since NSP has no plans to hire additional workers during

24 the license renewal term, overall expenditures and employment levels at PINGP 1 and 2 would

25 remain relatively constant with no additional demand for permanent housing and public

26 services. In addition, since employment levels and the value of PINGP 1 and 2 would not

27 change, there would be no population or tax revenue-related land use impacts. There would

28 also be no disproportionately high and adverse health and environmental impacts on minority

29 and low-income populations in the region. Based on this and other information presented in

30 Chapter 4 of this draft SEIS, there would be no cumulative socioeconomic impacts from the

31 continued operation of PINGP 1 and 2 during the license renewal term beyond what is currently

32 being experienced.

33 NSP indicated in their environmental report that the PINGP 1 and 2, Unit 2, steam generators

34 would be replaced prior to the license renewal term. NSP estimates that steam generator

35 replacement would require a one-time increase in the number of refueling outage workers for up

36 to 80 days at PINGP 1 and 2 (NMC 2008). These additional workers would create a one-time

37 short-term increase in the demand for temporary (rental) housing, and increased use of public

38 water and sewer services, and transportation impacts on access roads in the immediate vicinity

39 of PINGP 1 and 2. Given the short amount of time needed to replace the steam generators, the

40 additional number of refueling outage workers and truck material deliveries needed to support

41 this one-time replacement of the PINGP 1 and 2, Unit 2, steam generators could have a

42 temporary cumulative affect on socioeconomic conditions in the vicinity of the nuclear plant.

43 However, there would be no long-term cumulative socioeconomic impacts from the PINGP 1

44 and 2, Unit 2, steam generator replacement in the region.

45 Any ground disturbing activities in support of PINGP 1 and 2 during the license renewal term in

46 addition to offsite ground disturbing activities could result in the cumulative loss of

47 archaeological resources on Prairie Island. Archaeological resources are non-renewable;

48 therefore, the loss of archaeological resources is cumulative. The continued operation of

October 2009 4-51 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

1 PINGP 1 and 2 during the license renewal term has the potential to impact archaeological

2 resources.

3 As discussed in Section 4.4.5, continued operation of PINGP 1 and 2 during the license renewal

4 term would have a MODERATE impact on archaeological resources at the PINGP 1 and 2 site.

5 NSP has no plans to alter the PINGP 1 and 2 site for license renewal. Any land disturbing

6 activities would be carried out under corporate procedures. Should plans change, further

7 consultation would be initiated by NSP with the NRC, MHS, OSA, BIA, and the PIIC. NSP is in

8 the process of revising corporate procedures to protect archaeological resources along with

9 detailed instructions to follow in the case of accidental discovery of archaeological resources

10 (Xcel 2009). NSP is currently seeking comment from the MHS, BIA, OSA, and the PIIC on its

11 revised procedures. Because impacts to important resources from the continued operation of

12 PINGP I and 2 are MODERATE, the cumulative environmental impacts to archaeological

13 resources would be MODERATE.

14 4.11.5 Cumulative Environmental Justice Impacts

15 NRC staff does not typically include a cumulative impact analysis on environmental justice;

16 however, the following information is the PIIC's analysis of cumulative impacts associated with

17 environmental justice.

18 As discussed above, the Prairie Island Indian Community believes that it will be

19 impacted disproportionately and adversely over the twenty year license renewal

20 period. No other community is as close to PINGP 1 and 2 as the Prairie Island

21 Indian Community. No other community is impacted, in as many ways, as the

22 Prairie Island Indian Community. Furthermore, these impacts will have a

23 cumulative environmental justice impact on our community.

24 No other minority community or federally-recognized Indian tribe is impacted the

25 way the Prairie Island Indian Community is.

26 No other community (within a 50-mi [80-km] radius) is so close to a nuclear

27 power plant and a nuclear waste storage facility.

28 No other community is subjected to chronic radiological releases from PINGP 1

29 and 2 and gamma radiation from the ISFS I. This will also increase once the

30 anticipated extended power uprate is approved by the NRC and NSP is allowed

31 to expand the ISFSI to 64 casks and eventually to 98 casks once PINGP 1 and 2

32 is decommissioned. For many of our members, their exposure to low levels of

33 radiation is for their entire lifetime.

34 Our youth are worrying about the effects of an accident on their community and

35 their futures; no other other community has documented the same concerns.

36 High-voltage power lines from the PINGP 1 and 2 site are located immediately

37 next to several of our homes.

38 No other community has tritium leaching into its groundwater from PINGP 1 and

39 2.

40 Our community would be devastated by an accident-our homeland would be

41 gone, our culture would be decimated, our means of providing services to tribal

42 members would be gone, and our tribal members' primary income would be

43 gone. No other community faces this undesirable prospect.

Draft NUREG-1437, Supplement 39 4-52 October 2009
Environmental Impacts of Operation

1 No other community (within the 50-mi [80-km] radius) has the emergency

2 planning concerns the tribe does (i.e., only one access road).

3 No other community participates in state or federal proceedings (using its own

4 resources) to the extent that the Prairie Island Indian Community does.

5 As we stated earlier, we believe that all things are related and that you cannot

6 affect one thing without affecting another. We know there are impacts to our

7 community from the continued operation of the PINGP 1 and 2 and the ISFSI.

8 We do not look at the ISFSI as separate from the reactor. We do not look at

9 accidents as credible or non-credible, we believe that an accident could happen

10 and it will devastate our community. We know that NSP plans to amend its

11 operating license to operate at a higher level and that this action (and its impacts

12 are considered to be out of scope for this SEIS). Nevertheless, we know that

13 there will be an increase in radiological and thermal emissions resulting from the

14 uprate. We know tritium is in our groundwater and that we did not ask for it to be

15 there. We know that our youth feel that they have an uncertain future (because of

16 the PINGP 1 and 2) and that affects the future of the tribe.

17 Taken together, we believe that these issues have an integrated and cumulative

18 negative impact on our community that will continue impact our community well

19 after the twenty-year extended operating period.

20 4.11.6 Summary of Cumulative Impacts

21 We considered the potential impacts resulting from operation of PINGP 1 and 2 during the

22 period of extended operation and other past, present, and future actions in the vicinity of PINGP

23 1 and 2. The impacts to individual resource areas range from SMALL to LARGE. The

24 preliminary determination is that the potential overall cumulative impacts resulting from PINGP 1

25 and 2 operation during the period of extended operation would be SMALL to MODERATE.

26 Table 4-13. Summary of Cumulative Impacts on Resources Areas

Resource Area Impact Discussion

Aquatic and Water MODERATE to Impacts to aquatic resources fromcontinued operation

Resources LARGE of PINGP 1 and 2 would have small cumulative

impacts. Past impacts to the Mississippi River,

specifically creation of a Lock and Dam system have

had significant impacts on the aquatic environment.

Nutrient enrichment from agricultural and urban runoff,

land development, and sedimentation, as well as

dredging of the Lake Sturgeon portion of the river by

the PIIC, will also continue to affect water and aquatic

resources.

Terrestrial Resources SMALL ROW maintenance, invasive species, chemical

discharges from nearby wastewater treatment plants,

and development of neighboring areas have all

impacted terrestrial habitat and species in the vicinity of

PINGP 1 and 2, and would likely continue in the future.

Human Health SMALL The cumulative human health impacts of continued

operation of PINGP 1 and 2 from radiation exposure to

the public and electric-field-induced currents from the

PINGP 1 and 2 transmission lines would be small.

October 2009 4-53 Draft NUREG-1437, Supplement 39
Environmental Impacts of Operation

Resource Area Impact Discussion

Socioeconomics MODERATE There would be MODERATE cumulative impacts to

socioeconomics during the license renewal period, and

no long-term cumulative impacts from refurbishment.

There would be MODERATE cumulative impacts to

historic and archaeological resources during the license

renewal period, including refurbishment.

1 4.12 References

2 10 CFR 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for Protection

3 Against Radiation."

4 10 CFR 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of

5 Production and Utilization Facilities."

6 10 CFR 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental Protection

7 Regulations for Domestic Licensing and Related Regulatory Functions."

8 36 CFR 60. Code of Federal Regulations. Title 36, Parks, Forests, and Public Property. Part 60,

9 "National Register of Historic Places."

10 36 CFR 800. Code of Federal Regulations. Title 36, Parks, Forests, and Public Property, Part

11 800, "Protection of Historic Properties."

12 40 CFR 190. Code of Federal Regulations. Title 40, Protection of the Environment, Part 190,

13 "Environmental Radiation Protection Standards for Nuclear Power Operations."

14 59 FR 7629. Executive Order 12898. Federal Actions to Address Environmental Justice in

15 Minority Populations and Low-Income Populations. February 16, 1994.

16 69 FR 52040. U.S. Nuclear Regulatory Commission. Treatment of Environmental Justice

17 Matters in NRC Regulatory and Licensing Actions. August 24, 2004.

18 69 FR 41575. U.S. Environmental Protection Agency. National Pollutant Discharge Elimination

19 System - Final Regulations to Establish Requirements for Cooling Water Intake Structures at

20 Phase II Existing Facilities: Final Rule. July 9, 2004.

21 72 FR 37109. U.S. Environmental Protection Agency. National Pollutant Discharge Elimination

22 System - Suspension of Regulations to Establish Requirements for Cooling Water Intake

23 Structures at Phase II Existing Facilities: Final Rule. July 09, 2007.

24 33 USC 1326 (Title 33, Section 1326 of the United States Code). Thermal Discharges.

25 ACHP (Advisory Council on Historic Preservation). 2008. "National Register Evaluation Criteria."

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27 ML082880723.

28 AEC (Atomic Energy Commission). 1973. Final Environmental Statement Related to the

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30 ML081840311.

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33 (accessed January 14, 2009). ADAMS No. ML080230326.

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21 EPA (U.S. Environmental Protection Agency). 2006. "Mississippi River Basin & Gulf of Mexico

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29 FWS (U.S. Fish and Wildlife Service). 2004. Higgins Eye Pearlymussel (Lampsilis higginsil)

30 Recovery Plan: First Revision. Ft. Snelling, Minnesota. 126 pp. Available URL:

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32 FWS (U.S. Fish and Wildlife Service). 2008. Letter from T. Sullins, U.S. Fish and Wildlife

33 Service, Twin Cities Ecological Services Office, to R. Franovich, Branch Chief, Division of

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36 Renewal Application Review. August 13, 2008. ADAMS No. ML082470303.

37 Goddard, S.V. 1977. "Prairie Island Nuclear Generating Plant Environmental Monitoring

38 Program 1976 Annual Report, Ecological Studies, Special Studies: Number and Composition of

39 Bird Killed by Striking Transmission Lines from the Prairie Island Nuclear Generating Plant."

40 Prepared for Northern States Power Company. ADAMS No. ML08312228.

41 Goddard, S.V. 1978. "Prairie Island Nuclear Generating Plant Environmental Monitoring

42 Program 1977 Annual Report, Ecological Studies, Special Studies: Number and Composition of

43 Bird Killed by Striking Transmission Lines from the Prairie Island Nuclear Generating Plant."

44 Prepared for Northern States Power Company. ADAMS No. ML08312228.

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1 Goddard, S.V. 1979. "Prairie Island Nuclear Generating Plant Environmental Monitoring

2 Program 1978 Annual Report, Ecological Studies, Special Studies: Number and Composition of

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4 Prepared for Northern States Power Company. ADAMS No. ML08312228.

5 Hendriks, C.W. 1972. "Enteric Bacterial Growth Rates in River Water." Applied Mircobiology,

6 24(2):168-174.

7 HDR (Henningson, Durham, and Richardson, Inc.). 1978. Section 316(a) Demonstration for the

8 Prairie Island Generating Plant on the Mississippi River near Red Wing, Minnesota. Prepared

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10 Hildebrandt, Emily. 2008. Literature Search and Assessment of Historical and Archaeological

11 Resources Impacted by Construction and Operations Activities at the Prairie Island Nuclear

12 Plant, Goodhue County, Minnesota. Final Report. Submitted to Nuclear Management

13 Company. Welch, Minnesota. Minnesota State University, Mankato. August. Non-public

14 reference per 36 CFR 800.11 (c), NHPA § 304[16 U.S.C. 470w-3(a) - Confidentiality of the

15 location of sensitive historic resources], and Minnesota Statute 307.08, Sub. 11.

16 IEEE (Institute of Electrical and Electronics Safety Code) 2007. National Electric Safety Code

17 2007 Edition.

18 Janss, G. F. E. and M. Ferrer. 1998. Rate of Bird Collision with Power Lines: Effects of

19 Conductor-marking and Static Wire-marking. Journal of Field Ornithology. 69(1):8-17.

20 Joklik, W. K, and H. P. Willet. 1976. Zinsser Microbiology, 16th ed. New York: Appleton21 Century-Crofts.

22 MDH (Minnesota Department of Health). 2006. 2006 Environmental Radiation Data Report.

23 Available URL: http://www.health.state.mn.usldivslehlradiation/monitor/annual2006.pdf

24 (accessed December 8, 2008).

25 MDH (Minnesota Department of Health). 2007. 2006 Environmental Radiation Data Report.

26 January. Available URL:

27 http://www.health.state.mn.usldivs/eh/radiation/monitor/annual2006.pdf (accessed July 29,

28 2009).

29 MDH (Minnesota Department of Health). 2008. "Reports for the Prairie Island Independent

30 Spent Fuel Storage Installation." Available URL:

31 http://www.health.state.mn.us/divs/ehlradiationlmonitor/pilindex.html (accessed December 8,

32 2008).

33 MNDNR (Minnesota Department of Natural Resources). 2008a. Letter from H. Cyr, Minnesota

34 Department of Natural Resources, to R. Franovich, Branch Chief, Division of License Renewal.

35 Subject: Reply to Request for Natural Heritage Information in the Vicinity of the Prairie Island

36 Nuclear Generating Plant. August 26, 2008. ADAMS No. ML083290584.

37 MPCA (Minnesota Pollution Control Agency). 1981. National Pollutant Discharge Elimination

38 System, Permit MN0004006, Prairie Island Nuclear Generating Plant.

39 MPCA (Minnesota Pollution Control Agency). 2000. "Upper Mississippi River Basin Information

40 Document." Available URL: http:/lwww.pca.state.mn.us/waterlbasins/uppermiss/bid41 uppermiss.pdf (accessed October 10, 2008). ADAMS No. ML083380233.

42 MPCA (Minnesota Pollution Control Agency). 2006. National Pollutant Discharge Elimination

43 System, Permit MN0004006, Prairie Island Nuclear Generating Plant. June.

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1 MPCA (Minnesota Pollution Control Agency). 2008. "Upper Mississippi River Basin." Available

2 URL: http://www.pca.state.mn.us/water/basins/uppermiss/index.html (accessed October 10,

3 2008). ADAMS No. ML083380243.

4 MRBDC (Minnesota River Basin Data Center). 2000. "State of the Minnesota River: Summary of

5 Surface Water Quality Monitoring, 2000." Available URL:

6 http://mrbdc.mnsu.edu/reports/basin/statemr00.html (accessed November 15, 2008). ADAMS

7 No. ML083380246.

8 Migratory Bird Treaty Act of 1998, as amended. 16 USC 703-712.

9 Mussel Coordination Team. 2005. Status of Implantation of Higgins Eye Pearlymussel

10 (Lampsilis higginsli) Reasonable and Prudent Alternatives and Reasonable and Prudent

11 Measures and Winged Mapleleaf (Quadrula fragosa) Reasonable and Prudent Measures.

12 November 2005. Available URL:

13 http://www.fws.gov/Midwest/mussel/documents/statushigginseye-wingedmapleleaf_2005. pd

14 f (accessed December 12, 2008).

15 NIEHS (National Institute of Environmental Health Sciences). 1999. NIEHS Report on Health

16 Effects from Exposure to Power Line Frequency and Electric and Magnetic Fields. Publication

17 No. 99-4493, Research Triangle Park, NC.

18 NMC (Nuclear Management Company, LLC). 2004a. Prairie Island Nuclear Generating Plant -

19 Units 1 and 2, Operating License No. DPR-42, DPR-60. Annual Radioactive Effluent Release

20 Report and Offsite Dose Calculation Manual, Enclosure 2, "Annual Radioactive Effluent Report.

21 Supplemental information. January 1 through December 31, 2003." Goodhue County,

22 Minnesota. ADAMS No. ML041420504.

23 NMC (Nuclear Management Company, LLC). 2004b. Prairie Island Nuclear Generating Plant -

24 Units 1 and 2, Operating License No.DPR-42, DPR-60 and SNM-2506. Annual Radiological

25 Environmental Monitoring Program Report. January 1 through December 31, 2003. Goodhue

26 County, Minnesota. ADAMS No. ML041410077.

27 NMC (Nuclear Management Company, LLC). 2005a. Prairie Island Nuclear Generating Plant -

28 Units 1 and 2, Operating License No.DPR-42, DPR-60. Annual Radioactive Effluent Release

29 Report and Offsite Dose Calculation Manual, Enclosure 2, "Annual Radioactive Effluent Report.

30 Supplemental information. January 1 through December 31, 2004." Goodhue County,

31 Minnesota. ADAMS No. ML051360426.

32 NMC (Nuclear Management Company, LLC). 2005b. Prairie Island Nuclear Generating Plant -

33 Units 1 and 2, Operating License No.DPR-42, DPR-60 and SNM-2506. Annual Radiological

34 Environmental Monitoring Program Report. January 1 through December 31, 2004. Goodhue

35 County, Minnesota. ADAMS No. ML061280040.

36 NMC (Nuclear Management Company, LLC). 2006a. Prairie Island Nuclear Generating Plant -

37 Units 1 and 2, Operating License No.DPR-42, DPR-60. Annual Radioactive Effluent Release

38 Report and Offsite Dose Calculation Manual, Enclosure 2, 'Annual Radioactive Effluent Report.

39 Supplemental information. January 1 through December 31, 2005." Goodhue County,

40 Minnesota. ADAMS No. ML061370092.

41 NMC (Nuclear Management Company, LLC). 2006b. Prairie Island Nuclear Generating Plant -

42 Units 1 and 2, Operating License No.DPR-42, DPR-60 and SNM-2506. Annual Radiological

43 Environmental Monitoring Program Report. January 1 through December 31, 2005. Goodhue

44 County, Minnesota. ADAMS No. ML061280040.

45 NMC (Nuclear Management Company, LLC). 2007a. Prairie Island Nuclear Generating Plant -

46 Units 1 and 2, Operating License No.DPR-42, DPR-60. Annual Radioactive Effluent Release

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Environmental Impacts of Operation

1 Report and Offsite Dose Calculation Manual, Enclosure 2, "Annual Radioactive Effluent Report.

2 Supplemental information. January 1 through December 31, 2006." Goodhue County,

3 Minnesota. ADAMS No. ML071370287.

4 NMC (Nuclear Management Company, LLC). 2007b. Prairie Island Nuclear Generating Plant -

5 Units 1 and 2, Operating License No.DPR-42, DPR-60 and SNM-2506. Annual Radiological

6 Environmental Monitoring Program Report. January 1 through December 31, 2007. Goodhue

7 County, Minnesota. ADAMS No. ML071350517.

8 NMC (Nuclear Management Company, LLC). 2007c. Prairie Island Nuclear Generating Plant -

9 Units I and 2, Operating License No.DPR-42, DPR-60 and SNM-2506. Annual Radiological

10 Environmental Monitoring Program Report. January 1 through December 31, 2006. Appendix E,

11 "Special Well and Surface Water Samples." Goodhue County, Minnesota. ADAMS No.

12 ML071350517.

13 NMC (Nuclear Management Company, LLC). 2008. Prairie Island Nuclear Generating Plant,

14 Units 1 and 2, License Renewal Application, Appendix E - Applicant's Environmental Report,

15 License Renewal Operating Stage. Redwing, Minnesota. April 2008. ADAMS Nos.

16 ML081130677, ML081130681, and ML081130684.

17 NMC (Nuclear Management Company, LLC). 2008a. Prairie Island Nuclear Generating Plant -

18 Units 1 and 2, Operating License No.DPR-42, DPR-60 and SNM-2506. 2007 Annual

19 Radioactive Effluent Release Report and Offsite Dose Calculation Manual, Enclosure 2, "Annual

20 Radioactive Effluent Report. Supplemental information. January 1 through December 31, 2007."

21 Goodhue County, Minnesota. ADAMS No. ML081370317.

22 NMC (Nuclear Management Company, LLC). 2008b. Prairie Island Nuclear Generating Plant -

23 Units 1 and 2, Operating License No.DPR-42, DPR-60 and SNM-2506. Annual Radiological

24 Environmental Monitoring Program Report. January 1 through December 31, 2007. Goodhue

25 County, Minnesota. ADAMS No. ML081370083.

26 NMC (Nuclear Management Company, LLC). 2008c. Prairie Island Nuclear Generating Plant -

27 Units 1 and 2, Operating License No.DPR-42, DPR-60 and SNM-2506. Annual Radiological

28 Environmental Monitoring Program Report. January 1 through December 31, 2007. Appendix E,

29 "Special Well and Surface Water Samples." Goodhue County, Minnesota. ADAMS No.

30 ML081370083.

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

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

33 ADAMS Nos. ML040690705 and ML040690738.

34 NRC (U.S. Nuclear Regulatory Commission). 1999. Generic Environmental Impact Statement

35 for License Renewal of Nuclear Plants, Main Report, "Section 6.3 -Transportation, Table 9.1,

36 Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report."

37 NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

38 NRC (U.S. Nuclear Regulatory Commission). 2000. Standard Review Plan for Environmental

39 Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal. NUREG-1 555,

40 Supplement 1, Washington, D.C.

41 NRC (U.S. Nuclear Regulatory Commission). 2008a. Letter from U.S. Nuclear Regulatory

42 Commission to L. Joyal, Minnesota Department of Natural Resources, Natural Heritage and

43 Nongame Research Program. Subject: Request for List of State-Protected Species Within the

44 Area Under Evaluation for the Prairie Island Nuclear Generation Plant, Units 1 and 2, License

45 Renewal Application Review. July 22, 2008. Accessible at ML081890395.

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1 NRC (U.S. Nuclear Regulatory Commission). 2008b. Letter from U.S. Nuclear Regulatory

2 Commission to T. Sullins, U.S. Fish and Wildlife, Twin Cities Ecological Services Office.

3 Subject: Request for List of Federally Protected Species Within the Area Under Evaluation for

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7 Environmental Monitoring Program 1985 Annual Report. Northern States Power Company,

8 Minneapolis, MN. ADAMS No. ML083390825.

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10 Plant - Units 1 and 2, Operating License No.DPR-42, DPR-60 and SNM-2506. 'Revisions to the

11 Environmental Report Regarding Application for Renewed Operating Licenses". Letter. March 4,

12 2009. ADAMS No. 090690683.

13 NUS Corporation. 1976. Section 316(b) Demonstration for the Prairie Island Generating Plant

14 on the Mississippi River near Read Wing, Minnesota. December. ADAMS No. ML0831202223.

15 PIIC (Prairie Island Indian Community). 2008. Information provided by the Prairie Island Indian

16 Community (PIIC) will aid NRC staff in the preparation of the Supplemental EIS (SEIS). PIIC

17 Supplemental Information. Non-public reference per 36 CFR 800.11(c).

18 PIIC (Prairie Island Indian Community). 2009. Information provided by the Prairie Island Indian

19 Community (PIIC). PIIC Supplemental Information. Non-public reference per 36 CFR 800.11(c).

20 Stark, J.R., Hanson, P.E., Goldstein, R.M., Fallon, J.D., Fong, K.E., Lee, A.L., Kroening, S.E.,

21 and Andrews, W.J. 2000. Water Quality in the Upper Mississippi River Basin, Minnesota,

22 Wisconsin, South Dakota, Iowa, and North Dakota, 1995-98. US Geological Survey Circular

23 1211. Available URL: http://pubs.water.usgs.gov/circ1211/ (accessed October 16, 2008).

24 Stone and Webster (Stone and Webster Engineering Corp.). 1983. Modify Circulating Water

25 Intake and Discharge: System Description and Design Criteria. Prepared for Northern States

26 Power Co. Denver. April 1, 1983. ADAMS No. ML0831202223.

27 Todar, K. 2007. Todar's Online Textbook of Bacteriology. Available URL:

28 http://www.textbookofbacteriology.net (accessed January 14, 2009).

29 TtNUS (Tetra Tech NUS, Inc.). 2006. Calculation Package Water Use, 2000 through 2005.

30 August. ADAMS No. ML083120233.

31 Tyndall, R. L., K. S. Ironside, P. L. Metier, E. L. Tan, T. C. Hazen, and C. B. Fliermans. 1989.

32 Effect of thermal additions on the density and distribution of thermophilic amoebae and

33 pathogenic Naegleria fowleri in a newly created cooling lake. Applied Environmental

34 Microbiology 55:722-732.

35 USACE (US Army Corps of Engineers). 2002. Final July 2002 Definite Project Report and

36 Environmental Assessment for Relocation Plan for the Endangered Higgins' Eye Pearlymussel

37 (Lampsilis higginsil), Upper Mississippi River and Tributaries, Minnesota, Wisconsin, Iowa, and

38 Illinois. In cooperation with the Mussel Coordination Team. July. Available URL:

39 http://www.fws.gov/Midwest/mussel/documents/ dprrelocationplan finaljuly_2002.pdf

40 (accessed August 27, 2008).

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42 Water Level Management. Navigation and Ecosystem Sustainability Program (NESP).

43 November 2007.

44 USDOJ (U.S. Department of Justice). 2002. "Historic Agreement Between United States and

45 Xcel Energy to Save Raptors From Electrocution in 12 States." Available URL:

October 2009 4-59 Draft NUREG-1437, Supplement 39
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1 http://www.usdoj.gov/opa/pr/2002/April/02_enrd_240.htm (accessed September 16, 2008).

2 ADAMS No. ML082760112.

3 USCB (U.S. Census Bureau). 2003. LandView 6 - Census 2000 Profile of General

4 Demographic Characteristics DP-1 (100%) and Census Profile of Selected Economic

5 Characteristics DP-3, Summary of Census Block Groups in a 50-mi (80-km) radius around the

6 PINGP 1 and 2 (44.621667 Lat., -92.631667 Long.). December.

7 USBC (U.S. Census Bureau). 2008. American FactFinder, Census 2000 Information and State

8 and County QuickFacts on Goodhue, Dakota, and Pierce Counties. Available URLs:

9 http://factfinder.census.gov and http://quickfacts.census.gov (accessed October 30, 2008).

10 WDNR (Wisconsin Department of Natural Resources). 2008. Letter from T. Lovejoy, Wisconsin

11 Department of Natural Resources, to N. Goodman, Project Manager, Division of License

12 Renewal. Subject: Prairie Island (MN) Nuclear Generating Plant (PINGP) License Renewal -

13 EIS Issue Scoping. September 8, 2008. ADAMS No. ML083080277.

14 WHO (World Health Organization). 2007. Extremely Low Frequency Fields Environmental

15 Health Criteria Monograph No.238. Geneva, Switzerland. Available URL:

16 http://www.who.int/peh-emf/publications/elfehc/en/index.html (accessed October 14, 2008.

17 ADAMS No. ML082880728.

18 WIDHS (Wisconsin Department of Health Services) 2008a. "Environmental Monitoring of

19 Nuclear Power Plants for Radiological Emissions." Available URL:

20 http://dhs.wisconsin.gov/dph-beh/EnvMonitoring/EnvironmentalMonitoringNuclear.htm

21 (accessed December 8, 2008).

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25 (accessed December 8, 2008).

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27 Plant, Impingement Mortality and Entrainment Characterization Study. Submitted in Accordance

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30 ML0831202212.

31

32

Draft NUREG-1437, Supplement 39 4-60 October 2009
Postulated Accidents

1 5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS

2 This chapter describes the environmental impacts from postulated accidents that might occur

3 during the period of extended operation. The term "accident" refers to any unintentional event

4 outside the normal plant operational envelope that results in a release or the potential for

5 release of radioactive materials into the environment. Two classes of postulated accidents are

6 evaluated in NUREG-1437, Generic Environmental Impact Statement for License Renewal of

7 Nuclear Power Plants (GELS), and are listed in Table 5-1 below. These are design-basis

8 accidents (DBAs) and severe accidents.

9 Table 5-1. Issues Related to Postulated Accidents. Two issues related to postulated

10 accidents are evaluated under NEPA in the license renewal review, design-basis accidents and

11 severe accidents.

Issues GElS Sections Category

Design-basis accidents 5.3.2; 5.5.1 1

Severe accidents 5.3.3; 5.3.3.2; 2

5.3.3.3; 5.3.3.4;

5.3.3.5; 5.4; 5.5.2

12 5.1 Design Basis Accidents

13 In order to receive U.S. Nuclear Regulatory Commission (NRC) approval to operate a nuclear

14 power facility, an applicant for an initial operating license must submit a safety analysis report

15 (SAR) as part of its application. The SAR presents the design criteria and design information for

16 the proposed reactor and comprehensive data on the proposed site. The SAR also discusses

17 various hypothetical accident situations and the safety features that are provided to prevent and

18 mitigate accidents. The NRC staff reviews the application to determine whether the plant design

19 meets the Commission's regulations and requirements and includes, in part, the nuclear plant

20 design and its anticipated reponse to an accident.

21 DBAs are those accidents that both the licensee and the NRC staff evaluate to ensure that the

22 plant can withstand normal and abnormal transients, and a broad spectrum of postulated

23 accidents, without undue hazard to the health and safety of the public. A number of these

24 postulated accidents are not expected to occur during the life of the plant, but are evaluated to

25 establish the design basis for the preventative and mitigative safety systems of the facility. The

26 acceptance criteria for DBAs are described in 10 Code of Federal Regulations (CFR) 50 and 10

27 CFR 100.

28 The environmental impacts of DBAs are evaluated during the initial licensing process, and the

29 ability of the plant to withstand these accidents is demonstrated to be acceptable before

30 issuance of the operating license. The results of these evaluations are found in license

31 documentation such as the applicant's final safety analysis report (FSAR), the safety evaluation

32 report (SER), the final environmental impact statement (FEIS), and Section 5.1 of this draft

33 supplemental environmental impact statement (SEIS). A licensee is required to maintain the

34 acceptable design and performance criteria throughout the life of the plant, including any

35 extended-life operation. The consequences for these events are evaluated for the hypothetical

36 maximum exposed individual; accordingly, changes in the plant environment will not affect these

37 evaluations. Because of the requirements that continuous acceptability of the consequences

38 and aging management programs be in effect for the period of extended operation, the

October 2009 5-1 Draft NUREG-1437, Supplement 39
Postulated Accidents

1 environmental impacts as calculated for DBAs should not differ significantly from initial licensing

2 assessments over the life of the plant, including the period of extended operation. Accordingly,

3 the design of the plant relative to DBAs during the period of extended operation is considered to

4 remain acceptable and the environmental impacts of those accidents were not examined further

5 in the GELS.

6 The Commission has determined that the environmental impacts of DBAs are of SMALL

7 significance for all plants because the plants were designed to successfully withstand these

8 accidents. Therefore, for the purposes of license renewal, DBAs are designated as a Category 1

9 issue. The early resolution of the DBAs makes them a part of the current licensing basis of the

10 plant; the current licensing basis of the plant is to be maintained by the licensee under its

11 current license and, therefore, under the provisions of 10 CFR 54.30, is not subject to review

12 under license renewal.

13 The NRC did not identify any new and significant information related to DBAs during the review

14 of the applicant's ER (NMC 2008), the staffs site audit, the scoping process, or the evaluation of

15 other available information. Therefore, there are no impacts related to these issues beyond

16 those discussed in the GELS.

17 5.2 Severe Accidents

18 Severe nuclear accidents are those that are more severe than DBAs because they could result

19 in substantial damage to the reactor core, whether or not there are serious offsite

20 consequences. In the GELS, the staff assessed the impacts of severe accidents during the

21 license renewal period using the results of existing analyses and site-specific information to

22 conservatively predict the environmental impacts of severe accidents for each plant during the

23 renewal period.

24 Severe accidents initiated by external phenomena such as tornadoes, floods, earthquakes,

25 fires, and sabotage have not traditionally been discussed in quantitative terms in FESs and

26 were not specifically considered for the Prairie Island Nuclear Generating Plant, Units 1 and 2,

27 (PINGP 1 and 2) site in the GELS. However, the GElS did evaluate existing impact assessments

28 performed by NRC and the industry at 44 nuclear plants in the United States and concluded that

29 the risk from beyond design basis earthquakes at existing nuclear power plants is SMALL. The

30 GElS for license renewal performed a discretionary analysis of sabotage acts in connection with

31 license renewal and concluded that the core damage and radiological release from such acts

32 would be no worse than the damage and release expected from internally initiated events. In the

33 GELS, the Commission concludes that the risk from sabotage at existing nuclear power plants is

34 small and additionally, that the risks from other external events are adequately addressed by a

35 generic consideration of internally initiated severe accidents (NRC 1996).

36 Based on the information in the GELS, the Commission found that

37 The probability weighted consequences of atmospheric releases, fallout onto

38 open bodies of water, releases to ground water, and societal and economic

39 impacts from severe accidents are small for all plants. However alternatives to

40 mitigate severe accidents must be considered for all plants that have not

41 considered such alternatives.

42 The NRC did not identify any new and significant information related to severe accidents during

43 the review of the applicant's ER (NMC 2008), the staff's site audit, the scoping process, or the

44 evaluation of other available information. Therefore, there are no impacts related to these issues

45 beyond those discussed in the GELS. However, in accordance with 10 CFR 51.53(c)(3)(ii)(L),

Draft NUREG-1437, Supplement 39 5-2 October 2009
Postulated Accidents

1 the NRC staff has reviewed severe accident mitigation alternatives (SAMAs) for PINGP 1 and 2.

2 The results of the review are discussed in Section 5.3.

3 5.3 Severe Accident Mitigation Alternatives

4 10 CFR Section 51.53(c)(3)(ii)(L) requires that license renewal applicants consider alternatives

5 to mitigate severe accidents if the staff has not previously evaluated SAMAs for the applicant's

6 plant in an environmental impact statement (EIS) or related supplement or in an environmental

7 assessment. The purpose of this consideration is to ensure that plant changes (i.e., hardware,

8 procedures, and training) with the potential for improving severe accident safety performance

9 are identified and evaluated. SAMAs have not been previously considered for PINGP 1 and 2;

10 therefore, the remainder of Chapter 5 addresses those alternatives.

11 5.3.1 Introduction

12 This section presents a summary of the SAMA evaluation for PINGP 1 and 2 conducted by

13 Northern States Power Company (NSP) and the NRC staffs review of that evaluation. The NRC

14 staff performed its review with contract assistance from Information Systems Laboratories, Inc.

15 The NRC staff=s review is available in full in Appendix G; the SAMA evaluation is available in

16 full in NSP=s ER.

17 The SAMA evaluation for PINGP 1 and 2 was conducted with a four-step approach. In the first

18 step, NSP quantified the level of risk associated with potential reactor accidents using the

19 plant-specific probabilistic risk assessment (PRA) and other risk models.

20 In the second step, NSP examined the major risk contributors and identified possible ways

21 (SAMAs) of reducing that risk. Common ways of reducing risk are changes to components,

22 systems, procedures, and training. NSP identified 25 potential SAMAs for each unit. NSP

23 performed an initial screening in which they eliminated SAMAs that are not applicable to PINGP

24 1 and 2 due to design differences, have already been implemented at PINGP 1 and 2, have no

25 significant benefit or have benefits which have been achieved by other means, or require

26 extensive changes that would involve implementation costs known to exceed any possible

27 benefit. This screening reduced the list of potential SAMAs to nine for each unit.

28 In the third step, NSP estimated the benefits and the costs associated with each of the

29 remaining SAMAs. Estimates were made of how much each SAMA could reduce risk. Those

30 estimates were developed in terms of dollars in accordance with NRC guidance for performing

31 regulatory analyses (NRC 1997). The cost of implementing the proposed SAMAs was also

32 estimated.

33 Finally, in the fourth step, the costs and benefits of each of the remaining SAMAs were

34 compared to determine whether the SAMA was cost-beneficial, meaning the benefits of the

35 SAMA were greater than the cost (a positive cost-benefit). NSP concluded in its ER that several

36 of the SAMAs evaluated are potentially cost-beneficial (NMC 2008). However, in response to

37 NRC staff inquiries regarding the treatment of consequential steam generator tube rupture

38 (SGTR) in the baseline PRA, the approach used to estimate uncertainty, and the consideration

39 of lower cost alternatives, several additional potentially cost-beneficial SAMAs were identified

40 (NSP 2009a and 2009b).

41 The potentially cost-beneficial SAMAs do not relate to adequately managing the effects of aging

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

43 license renewal pursuant to 10 CFR Part 54. NSP's SAMA analyses and the NRC's review are

44 discussed in more detail below.

October 2009 5-3 Draft NUREG-1437, Supplement 39
Postulated Accidents

1 5.3.2 Estimate of Risk

2 NSP submitted an assessment of SAMAs for PINGP 1 and 2 as part of the ER (NMC 2008).

3 This assessment was based on the most recent PINGP 1 and 2 PRA available at that time, a

4 plant-specific offsite consequence analysis performed using the MELCOR Accident

5 Consequence Code System 2 (MACCS2) computer program, and insights from the PINGP 1

6 and 2 Individual Plant Examination (IPE) (NSP 1994) and Individual Plant Examination of

7 External Events (IPEEE) (NSP 1998).

8 The baseline core damage frequency (CDF) for the purpose of the SAMA evaluation is

9 approximately 9.79 x 10- per year for Unit 1 and 1.21 x 10.5 per year for Unit 2. The CDF values

10 are based on the risk assessment for internally initiated events. NSP did not include the

11 contributions from external events within the PINGP 1 and 2 risk estimates; however, it did

12 account for the potential risk reduction benefits associated with external events by increasing

13 the estimated benefits for internal events by a factor of two. The breakdown of CDF by initiating

14 event for Units 1 and 2 is provided in Table 5-2.

15 Table 5-2. PINGP 1 and 2 Core Damage Frequency

Unit I Unit 2

Initiating Event CDF % Contribution CDF % Contribution

(per year) to CDF (per year) to CDF

Small LOCA 4.8 x 10-6 49 5.4 x 10-6 45

Loss of Cooling Water 1.8 x 10-6 18 1.8 x 10-6 15

Loss of Offsite Power 1.0 x 10-6 11 1.2 x 10-6 10

Loss of Main Feedwater 3.9 x 10-7 4 4.1 x 10-7 3

Medium LOCA 3.4 x 10-7 3 5.4 x 10-7 4

Loss of Component Cooling 2.9 x 10-7 3 2.9 x 10-7 2

Water

Large LOCA 2.8 x 10-7 3 3.1 x 10-7 3

Internal Flooding 2.4 x 10-7 2 2.4 x 10-7 2

Normal Transient 2.4 x 10-7 2 2.8 x 10-7 2

Steam Generator Tube Rupture 1.9 x 10-7 2 1.1 x 10-6 9

(STGR)

Loss of Train A DC 3.8 x 10-8 <1 4.0 x 10-7 3

Other 2.1 x 10-7 2 1.7 x 10-7 1

Total CDF (internal events) 9.79 x 10-6 100 1.21 x 10-5 100

16 As shown in Table 5-2, events initiated by small loss of coolant accident (LOCA), loss of cooling

17 water and loss of offsite power are the dominant contributors to internal event CDF for each

18 unit. The differences in the CDF contributions result largely from several differences between

19 the two PINGP 1 and 2 units.

20 NSP estimated the dose to the population within 80 km (50 mi) of the PINGP 1 and 2 site to be

21 approximately 0.0294 person-sievert (Sv) (2.94 person-rem) per year for Unit 1 and 0.0843

22 person-Sv (8.43 person-rem) per year for Unit 2 (NMC 2008). The breakdown of the total

23 population dose by containment release mode is summarized in Table 5-3. Releases due to

24 SGTR events, interfacing system loss-of-coolant accidents (ISLOCAs), and late containment

25 failures dominate the population dose risk at PINGP 1 and 2.

26

27

Draft NUREG-1437, Supplement 39 5-4 October 2009
Postulated Accidents

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

Unit I Unit 2

Population Percent Population Percent

Containment Release Modes Dose Contribu Dose Contribu

(person- tion (person- tion

rem(a) rem(a)

per per

year) year)

Intact Normal 0.01 0.4 0.01 0.2

Containment Leakage

Early Containment Over-pressure 0.12 4.1 0.14 1.7

Failure Failure

Isolation <0.01 0.1 <0.01 <0.1

Failure

Late Containment Basemat 0.63 21.4 0.76 9.0

Failure Failure

Over-pressure 0.12 4.1 0.12 1.4

Failure

Containment SGTR 1.32 44.9 6.66 79.0

Bypass ISLOCA 0.74 25.0 0.74 8.7

Total 2.94 100 8.43 100

2 The NRC staff has reviewed NSP's data and evaluation methods and concludes that the quality

3 of the risk analyses is adequate to support an assessment of the risk reduction potential for

4 candidate SAMAs. Accordingly, the staff based its assessment of offsite risk on the CDFs and

5 offsite doses reported by NSP.

6 5.3.3 Potential Plant Improvements

7 Once the dominant contributors to plant risk were identified, NSP searched for ways to reduce

8 that risk. In identifying and evaluating potential SAMAs, NSP considered insights from the plant9 specific PRA, and SAMA analyses performed for other operating plants that have submitted

10 license renewal applications. NSP identified 25 potential risk-reducing improvements (SAMAs)

11 to plant components, systems, procedures and training.

12 NSP removed 16 SAMAs from further consideration because they are not applicable to PINGP

13 1 and 2 due to design differences, have already been implemented at PINGP 1 and 2, have no

14 significant benefit or have benefits which have been achieved by other means, or require

15 extensive changes that would involve implementation costs known to exceed any possible

16 benefit. A detailed cost-benefit analysis was performed for each of the nine remaining SAMAs.

17 The staff concludes that NSP used a systematic and comprehensive process for identifying

18 potential plant improvements for PINGP 1 and 2, and that the set of potential plant

19 improvements identified by NSP is reasonably comprehensive and, therefore, acceptable.

20 5.3.4 Evaluation of Risk Reduction and Costs of Improvements

21 NSP evaluated the risk-reduction potential of the remaining nine SAMAs. The SAMA

22 evaluations were performed using realistic assumptions with some conservatism.

23 NSP estimated the costs of implementing the candidate SAMAs through the application of

24 engineering judgment, use of other licensee's estimates for similar improvements, and site25 specific cost estimates. The cost estimates conservatively did not include the cost of

October 2009 5-5 Draft NUREG-1437, Supplement 39
Postulated Accidents

1 replacement power during extended outages required to implement the modifications, nor did

2 they include contingency costs associated with unforeseen implementation obstacles.

3 The staff reviewed NSP=s bases for calculating the risk reduction for the various plant

4 improvements and concludes that the rationale and assumptions for estimating risk reduction

5 are reasonable and somewhat conservative (i.e., the estimated risk reduction is similar to or

6 somewhat higher than what would actually be realized). Accordingly, the staff based its

7 estimates of averted risk for the various SAMAs on NSP=s risk reduction estimates.

8 The staff reviewed the bases for the applicant=s cost estimates. For certain improvements, the

9 staff also compared the cost estimates to estimates developed elsewhere for similar

10 improvements, including estimates developed as part of other licensees= analyses of SAMAs

11 for operating reactors and advanced light-water reactors. The staff found the cost estimates to

12 be reasonable, and generally consistent with estimates provided in support of other plants=

13 analyses.

14 The staff concludes that the risk reduction and the cost estimates provided by NSP are sufficient

15 and appropriate for use in the SAMA evaluation.

16 5.3.5 Cost-Benefit Comparison

17 The cost-benefit analysis performed by NSP was based primarily on NUREG/BR-0184 (NRC

18 1997) and was executed consistent with this guidance. NUREG/BR-0058 has recently been

19 revised to reflect the agency=s revised policy on discount rates. Revision 4 of NUREG/BR-0058

20 states that two sets of estimates should be developed B one at 3 percent and one at 7 percent

21 (NRC 2004). NSP provided both sets of estimates (NMC 2008).

22 In the baseline analysis contained in the ER (using a 3 percent discount rate), NSP identified

23 one potentially cost-beneficial SAMA for Unit 1 and two potentially cost-beneficial SAMAs for

24 Unit 2. The potentially cost-beneficial SAMAs are:

25 SAMA 9 (Unit 1 and Unit 2) - Implement procedure or plant modification to

26 improve ventilation for safeguards equipment in the Screenhouse.

27 SAMA 22 (Unit 2 only) - Provide compressed air backup for instrument air to

28 containment.

29 NSP performed additional analyses to evaluate the impact of parameter choices and

30 uncertainties on the results of the SAMA assessment (NMC 2008). If the benefits are based on

31 use of the 95 th percentile CDF results rather than the point estimate for CDF (to account for

32 uncertainties) one additional SAMA candidate was determined to be potentially cost-beneficial

33 for Unit 1. This is SAMA 22, which had already been shown to be cost-beneficial for Unit 2.

34 As a result of additional analyses in response to NRC staff requests, NSP identified three

35 additional potentially cost-beneficial SAMAs (NSP 2009a and 2009b):

36 SAMA 3 - provide alternate flow path from refueling water storage tank (RWST)

37 to charging pump suction (for Units 1 and 2)

38 SAMA 19a - provide a reliable backup water source for replenishing the RWST

39 (for Unit 2)

40 An unnumbered SAMA regarding purchase of a gagging device for closing a

41 stuck-open steam generator safety valve in SGTR events (for Units 1 and 2)

42 In addition, NSP has indicated that as a result of an identified internal flood modeling limitation,

43 two internal flood related enhancements previously identified in the IPE have also been entered

Draft NUREG-1437, Supplement 39 5-6 October 2009
Postulated Accidents

1 into the Corrective Action Program for further evaluation after the PRA has been updated with

2 improved methodology for modeling pipe breaks (NSP 2009b).

3 The staff concludes that, with the exception of the potentially cost-beneficial SAMAs discussed

4 above, the costs of the SAMAs evaluated would be higher than the associated benefits.

5 5.3.6 Conclusions

6 The staff reviewed NSP=s analysis related to SAMAs and concluded that the methods used and

7 the implementation of those methods were sound. The treatment of SAMA benefits and costs

8 support the general conclusion that the SAMA evaluations performed by NSP are reasonable

9 and sufficient for the license renewal submittal.

10 Based on its review of the SAMA analysis, the staff concurs with NSP=s identification of areas

11 in which risk can be further reduced in a cost-beneficial manner through the implementation of

12 all or a subset of potentially cost-beneficial SAMAs. Given the potential for cost-beneficial risk

13 reduction, the staff considers that further evaluation of these SAMAs by NSP is warranted.

14 However, none of the potentially cost-beneficial SAMAs relate to adequately managing the

15 effects of aging during the period of extended operation. Therefore, they need not be

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

17 5.4 Environmental Justice Issues Related to Severe Accidents, as submitted

18 by the PIIC

19 The following information is provided by the Prairie Island Indian Community (PIIC). The

20 information below does not represent the opinion of the NRC staff.

21 The evaluation of severe accidents, within the environmental justice analysis is of

22 paramount importance to the Prairie Island Indian Community.

23 The Prairie Island Indian Community believes that the NRC, as part of its

24 environmental justice review, should evaluate the potential risk associated with

25 accidents that may have a disproportionate impact on minority populations. The

26 Prairie Island Indian Community is the closest community to the PINGP 1 and 2.

27 This concept of risk includes the potential consequences of a reactor accident.

28 Mitigation of severe accidents is an integral part of the NRC's Severe Accident

29 Mitigation Alternatives (SAMA) analysis. The Tribe does not believe, however,

30 that the SAMA process can provide a realistic or acceptable treatment of the risk

31 to the Tribe's unique status as an Indian Tribe and minority Community.

32 Therefore, the Tribe believes that the risk from an accident and mitigating

33 measures must be specifically analyzed by the NRC as part of its Environmental

34 Justice analysis. In the case of the continued operation of PINGP, the

35 consequences of an accident would have a disproportionate impact on the Tribe,

36 given its close proximity to PINGP 1 and 2 and its unique identity as a federally37 recognized Indian tribe.

38 Members of our community and our ancestors have lived on Prairie Island for

39 countless generations. There is also a unique relationship between our culture

40 and this specific location. Prairie Island is our only home and the location of our

41 business (which can only be located on our reservation), which is our primary

42 means of providing services (including income) to our community. Not all

43 impacts to the tribe would be economic-if there was an accident at PINGP, our

October 2009 5-7 Draft NUREG-1437, Supplement 39
Postulated Accidents

1 culture would be significantly impacted, if not decimated, as it is inextricably

2 linked to this unique and irreplaceable resource called Prairie Island.

3 If there was a severe reactor accident, 801 current tribal members would also

4 lose a primary source of income and the Tribal government could no longer

5 provide benefits or services to tribal members. Of course, non-Indians would be

6 also be affected by severe accidents as well. Non-Indian residents in the region

7 of the PINGP 1 and 2, however, could simply buy individual parcels of land

8 outside the region in the event of contamination from a reactor accident. The

9 Tribe, however, would face the daunting task of re-locating and re-establishing

10 the entire tribal community (which includes an adequate land base that would

11 meet the needs of tribal members). In addition, the Treasure Island Resort and

12 Casino cannot be easily re-located. Federal laws and regulations govern not

13 only how a Tribal gaming facility operates, but where a Tribal gaming facility can

14 be located. Therefore this disproportionate impact on the Community would be

15 high and adverse.

16 Although NRC regulations reduce the probability of accidents, these high and

17 adverse disproportionate impacts would still call for the implementation of

18 mitigating measures to reduce, as much as practicable, the impacts on the Tribe.

19 Such mitigating measures would include the requirement that NSPM must

20 implement all SAMAs found to be cost-beneficial, both age-related and non-age

21 related. An appropriate finding of a high and adverse disproportionate impact on

22 the PIIC, would also substantially enable the Tribe to begin a dialogue with

23 appropriate entities of the Untitled States government to ensure that adequate

24 replacement land would be provided to the Community.

25 5.5 References

26 NMC (Nuclear Management Company, LLC). 2008. Prairie Island Nuclear Generating Plant,

27 Units 1 and 2, License Renewal Application, Appendix E - Applicant's Environmental Report,

28 License Renewal Operating Stage. Redwing, Minnesota. April 2008. ADAMS Nos.

29 ML081130677, ML081130681, and ML081130684.

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

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

32 ADAMS Nos. ML040690705 and ML040690738.

33 NRC (U.S. Nuclear Regulatory Commission). 1997. Regulatory Analysis Technical Evaluation

34 Handbook. NUREG/BR-0184, Washington, D.C.

35 NRC (U.S. Nuclear Regulatory Commission). 2004. Regulatory Analysis Guidelines of the U.S.

36 Nuclear Regulatory Commission. NUREG/BR-0058, Rev. 4, Washington, D.C

37 NSP (Northern States Power Company). 1994. Prairie Island Nuclear Generating Plant

38 Individual Plant Examination (IPE), NSPLMI-94001, Rev. 0, March 1, 1994.

39 NSP (Northern States Power Company). 1998. PINGP Individual Examination of External

40 Events (IPEEE), NSPLMI-96001, Rev. 1, October 19, 1998.

41 NSP (Northern States Power Company - Minnesota). 2008. Letter from M. Wadley, Site Vice

42 President, Northern States Power Company - Minnesota, to U.S. Nuclear Regulatory

43 Commission. Subject: Response to NRC Request for Additional Information Dated October 23,

44 2008 Regarding Application for Renewed Operating Licenses. November 21, 2008. ADAMS No.

45 ML083370505.

Draft NUREG-1437, Supplement 39 5-8 October 2009
Postulated Accidents

1 NSP (Northern States Power Company - Minnesota). 2009a. Letter from M. Wadley, Site Vice

2 President, Northern States Power Company - Minnesota, to U.S. Nuclear Regulatory

3 Commission. Subject: Response to NRC Requests for Additional Information Dated December

4 24, 2008 Regarding Application for Renewed Operating Licenses. January 23, 2009. ADAMS

5 No. ML090260290.

6 NSP (Northern States Power Company - Minnesota). 2009b. Letter from M. Wadley, Site Vice

7 President, Northern States Power Company - Minnesota, to U.S. Nuclear Regulatory

8 Commission. Subject: Supplemental Information Regarding Application for Renewed Operating

9 Licenses. March 4, 2009. ADAMS No. ML090690684.

10

October 2009 5-9 Draft NUREG-1437, Supplement 39

Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

1

2 6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE AND

3 SOLID WASTE MANAGEMENT

4 6.1 The Uranium Fuel Cycle

5 This chapter addresses issues related to the uranium fuel cycle and solid waste management

6 during the period of extended operation. The uranium cycle includes uranium mining and

7 milling, the production of uranium hexafluoride, isotopic enrichment, fuel fabrication,

8 reprocessing of irradiated fuel, transportation of radioactive materials and management of low9 level wastes and high-level wastes related to uranium fuel cycle activities. The generic potential

10 impacts of the radiological and nonradiological environmental impacts of the uranium fuel cycle

11 and transportation of nuclear fuel and wastes are described in detail in the Generic

12 Environmental Impact Statement for License Renewal of Nuclear Power Plants (GElS) (NRC

13 1996; 1999) based, in part, on the generic impacts provided in 10 CFR 51.51(b), Table S-3,

14 "Table of Uranium Fuel Cycle Environmental Data," and in 10 CFR 51.52(c), Table S-4,

15 "Environmental Impact of Transportation of Fuel and Waste to and from One Light-Water16 Cooled Nuclear Power Reactor." The GElS also addresses the impacts from radon-222 and

17 technetium-99.

18 No new and significant information related to the uranium fuel cycle was identified during the

19 review of the Northern State Power Co. (NSP) environmental report (ER; NMC 2008), the site

20 audit, or the scoping process. Therefore, there are no impacts related to these issues beyond

21 those discussed in the GElS. For these category 1 issues, the GElS concludes that the impacts

22 are SMALL except for the collective offsite radiological impacts from the fuel cycle and from

23 high-level waste and spent fuel disposal, which are site-specific, category 2 analysis.

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

25 Management. There are nine generic issues related to the fuel cycle and waste

26 management. There are no site-specific issues.

Issues GElS Sections Category

6.1; 6.2.1; 6.2.2.1;

Offsite radiological impacts (individual effects from other 6.2.2.3; 6.2.3;

than the disposal of spent fuel and high-level waste) 6.2.4; 6.6 1

6.1; 6.2.2.1; 6.2.3;

Offsite radiological impacts (collective effects) 6.2.4; 6.6 1

Offsite radiological impacts (spent fuel and high-level 6.1; 6.2.2.1; 6.2.3;

waste disposal) 6.2.4; 6.6 1

27

October 2009 6-1 Draft NUREG-1437, Supplement 39
1

Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

Table 6-1 (continued)

Issues GElS Sections Category

6.1; 6.2.2.6;

6.2.2.7; 6.2.2.8;

6.2.2.9; 6.2.3;

Nonradiological impacts of the uranium fuel cycle 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; 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;

Low-level waste storage and disposal 6.4.4.6;6.6

6.4.5.1; 6.4.5.2;

6.4.5.3; 6.4.5.4;

6.4.5.5; 6.4.5.6;

6.4.5.6.1; 6.4.5.6.2;

6.4.5.6.3; 6.4.5.6.4;

Mixed waste storage and disposal 6.6

6.1; 6.4.6; 6.4.6.1;

6.4.6.2; 6.4.6.3;

6.4.6.4; 6.4.6.5;

Onsite spent fuel 6.4.6.6; 6.4.6.7; 6.6

6.1; 6.5; 6.5.1;

Nonradiological waste 6.5.2; 6.5.3; 6.6

6.1; 6.3.1; 6.3.2.3;

6.3.3; 6.3.4; 6.6,

Transportation Addendum 1

2 6.2 Greenhouse Gas Emissions

3 6.2.1 Introduction

4 The NRC staff received comments during the scoping period from individuals and groups

5 regarding the impact of the proposed reclicensing of PINGP 1 and 2 on the release of carbon

6 dioxide (C0 2) and other greenhouse gas (GHG) emissions relative to potential alternative

7 energy sources, including fossil fuels, renewable energy sources, and conservation programs.

8 6.2.2 PINGP 1 and 2

9 The NRC staff has not indentified any studies specifically addressing GHGs produced by

0 PINGIP 1 and 2 or their fuel cycles.

1 6.2.3 GElS

2 The GElS provided only qualitative discussion regarding the GHG impacts of the nuclear fuel

3 cycle. In the analysis of potential alternatives to nuclear power plant relicensing, the GElS

1

1

1

1

Draft NUREG-1437, Supplement 39 6-2 October 2009
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

1 referenced C02 emissions as one of the substantial operating impacts associated with new

2 coal-fired and oil-fired power plants, although no direct quantitative assessment of GHG

3 emissions was presented. The GElS also did not address GHG impacts of the nuclear fuel cycle

4 relative to other potential alternatives, such as natural gas, renewable energy sources, or

5 conservation programs.

6 6.2.4 Other Studies

7 Since the development of the GELS, extensive further research into the relative volumes of

8 GHGs emitted by nuclear and other electricity generating methods has been performed. In

9 support of the analysis for this draft SEIS, the NRC staff performed a survey of the recent

10 literature on the subject. Based on this survey, the NRC staff found that estimates and

11 projections of the carbon footprint of the nuclear power lifecycle vary widely, and considerable

12 debate exists regarding the relative impacts of nuclear and other electricity generation methods

13 on GHG emissions. These recent studies take two different forms:

14 3) qualitative discussions of the potential use of nuclear power to address GHG

15 emissions and global warming

16 4) technical analysis and quantitative estimates of the actual amount of GHGs

17 generated by the nuclear fuel cycle

18 6.2.5 Qualitative

19 The qualitative studies primarily consist of broad, large-scale public policy or investment

20 evaluations of whether an expansion of nuclear power is likely to be a technically, economically,

21 and/or politically feasible means of achieving global GHG reductions. Examples of the studies

22 that the NRC staff identified during the subsequent literature search include the following:

23 • Studies conducted to evaluate whether investments in nuclear power in

24 developing countries should be accepted as a flexibility mechanism to assist

25 industrialized nations in achieving their GHG reduction goals under the Kyoto

26 Protocols (Schneider 2000; IAEA 2000; NEA 2002; and NIRS/WISE 2005).

27 Ultimately, the parties did not approve nuclear power as a component under

28 the Clean Development Mechanism (CDM), but not because of concerns

29 about GHGs from the nuclear fuel cycle (NEA 2002). Instead, it was

30 eliminated from consideration for the CDM because it was not considered to

31 meet the criterion of helping developing nations achieve sustainable

32 development because of safety and waste disposal concerns (NEA 2002).

33 * Analyses developed to assist governments (including the U.S. Government)

34 in making long-term investment and public policy decisions in nuclear power

35 (Keepin 1988; Hagen et al. 2001; MIT 2003).

36 Although the qualitative studies sometimes reference and critique the rationale contained in the

37 existing quantitative estimates of GHGs produced by the nuclear fuel cycle, their conclusions

38 generally rely heavily on discussions of other aspects of nuclear policy decisions and

39 investment such as safety, cost, waste generation, and political acceptability. Therefore, these

40 studies are not directly applicable to the evaluation of GHG emissions that will be associated

41 with the proposed relicensing of PINGP 1 and 2.

October 2009 6-3 Draft NUREG-1437, Supplement 39
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

1 6.2.6 Quantitative

2 A large number of technical studies, including calculations and estimates of the amount of

3 GHGs emitted by nuclear and other power generation options, are available in the literature.

4 Examples of these studies include Mortimer (1990), Andseta et al. (1998), Spadaro (2000),

5 Storm van Leeuwen and Smith (2005), Fritsche (2006), POST (2006), AEA (2006), Weisser

6 (2006), Fthenakis and Kim (2007), and Dones (2007).

7 Comparison of the different studies is difficult because the assumptions and components of the

8 lifecycles included within each study vary widely. Examples of differing assumptions that make

9 comparability between the studies difficult include the following:

10 • the type of energy source that may be used to mine uranium deposits in the

11 future

12 * the amount of reprocessing of nuclear fuel that will be performed in the future

13 * the type of energy source and process that might be used to enrich uranium

14 in the future

15 0 different calculations regarding the grade and volume of recoverable uranium

16 deposits in the world

17 * different estimates regarding the GHG emissions associated with declining

18 grades of recoverable coal, natural gas, and oil deposits

19 * the release of GHG gases other than C0 2, including the conversion of the

20 masses of these gases into grams of CO2 equivalents per kilowatt-hour (g Ceq

21 /kWh)

22 * the technology to be used for future fossil fuel power systems, including

23 cogeneration systems

24 * the projected capacity factors assumed for the different generation

25 alternatives

26 * the different types of nuclear reactors used currently and in the projected

27 future (light water reactor, pressurized-water reactor, Canadian deuterium28 natural uranium reactor, breeder)

29 In addition, studies are inconsistent in their application of full lifecycle analyses, including plant

30 construction, decommissioning, and resource extraction (uranium ore, fossil fuel). For instance,

31 Storm van Leeuwen and Smith (2005) present comparisons of GHG emissions from nuclear

32 versus natural gas that incorporate GHG emissions associated with nuclear plant construction

33 and decommissioning in the values used for comparison.

34 In the case of the proposed PINGP 1 and 2 relicensing, the relicensing action will not involve

35 additional GHG emissions associated with construction because the facility already exists. In

36 addition, the proposed relicensing action will not involve additional GHG emissions associated

37 with facility decommissioning, because that decommissioning must occur whether the facility is

38 relicensed or not. Some emissions will occur as a result of construction associated with

39 refurbishment activities; however, as discussed in Chapter 3 of this draft SEIS, these impacts

40 are expected to be short-term and minimal. In many of these studies, the contribution of GHG

41 emissions from facility construction and decommissioning cannot be separated from the other

42 lifecycle GHG emissions that would be associated with PINGP 1 and 2 relicensing. Therefore,

43 these studies overestimate the GHG emissions attributed to the proposed PINGP 1 and 2

44 relicensing action.

Draft NUREG-1437, Supplement 39 6-4 October 2009
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

1 In an early study on the subject, Dr. Nigel Mortimer conducted an analysis of the GHG

2 emissions resulting from the nuclear fuel cycle in 1990 (Mortimer 1990). In this study, Mortimer

3 stressed that the GHG implications of the nuclear fuel cycle were substantially related to the ore

4 grade of uranium that must be mined to support nuclear power generation. Using ore grades

5 that were current as of 1990, this study concluded that nuclear power offered a dramatic

6 reduction in GHG emissions over conventional coal-fired power plants over an estimated

7 35-year lifecycle. The analysis estimated that a nuclear power plant would generate 230,000

8 tons (209,000 metric tonnes [MT]) of CO 2 over a 35-year life span, or about 3.9 percent of the

9 5,912,000 tons (5,363,000 MT) that an equivalent coal-fired plant would generate (Mortimer

10 1990). The study also projected that most of this 230,000 tons (209,000 MT) of C02 resulted

11 from the use of a coal-fired plant to perform uranium enrichment by gaseous diffusion, and that

12 using nuclear power and alternative enrichment methods in the future could reduce the amount

13 to 21,000 tons (19,000 MT) (Mortimer 1990).

14 Mortimer's study went on to demonstrate that the GHG impact of the nuclear fuel cycle would

15 increase as the grade of uranium ore mined dropped, and that the net emissions of CO 2 from

16 the nuclear and coal-fired alternatives would become equal once uranium ore grades reached

17 0.01-percent uranium oxide. However, Mortimer does not address differences in energy

18 consumption from future extraction and enrichment methods, the potential for higher grade

19 resource discovery, and technology improvements. Based on his cutoff ore grade and

20 projections of ore reserves, Mortimer estimated GHG emissions of nuclear and natural gas

21 generation would have the same emissions after a period of 23 years (Mortimer 1990). The

22 analysis also compared GHG emissions associated with the nuclear fuel cycle with other

23 electricity generation and efficiency options, including hydroelectric, wind, tidal power, and new

24 types of insulation and lighting (but not including natural gas). The conclusion was that nuclear

25 power had lower GHG emissions compared to coal, but that GHG emissions associated with the

26 nuclear fuel cycle still exceeded those for renewable generation and conservation options

27 (Mortimer 1990).

28 The Mortimer (1990) study is not presented here to support a definitive conclusion regarding

29 whether nuclear energy produces fewer GHG emissions than other alternatives and similar

30 discussions will not be presented in this draft SEIS for each of the available studies. Instead, the

31 NRC staff presents the Mortimer (1990) study to provide an example of the types of

32 considerations underlying the calculations and arguments presented by the various authors.

33 Almost every existing study has been critiqued, and its assumptions challenged, by later

34 authors. Therefore, no single study has been selected to represent definitive results in this draft

35 SEIS. Instead, the results from a variety of the studies are presented in Tables 6-2, 6-3, and 6-4

36 to provide a weight-of-evidence argument comparing the relative GHG emissions resulting from

37 the proposed PINGP 1 and 2 relicensing compared to the potential alternative use of coal-fired

38 plants, natural gas-fired plants, and renewable energy sources.

39 6.2.7 Summary of Nuclear Greenhouse Gas Emissions Compared to Coal

40 Because coal is the fuel most commonly used to generate electricity in the U.S., and the burning

41 of coal results in the largest emissions of GHGs for any of the likely alternatives to nuclear

42 power, most of the available quantitative studies have focused on comparisons of the relative

43 GHG emissions of nuclear to coal-fired generation. The quantitative estimates of the GHG

44 emissions associated with the nuclear fuel cycle, as compared to an equivalent coal-fired plant,

45 are presented in Table 6-2.

October 2009 6-5 Draft NUREG-1437, Supplement 39
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

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

Source GHG Emission Results

Mortimer 1990 Nuclear-230,000 tons C02

Coal-5,912,000 tons C02

Note: Future GHG emissions from nuclear to increase because of declining

ore grade

Andseta et al. Nuclear energy produces 1.4 percent of the GHG emissions compared to

1998 coal.

Note: Future reprocessing and use of nuclear-generated electrical power in

the mining and enrichment steps are likely to change the projections of

earlier authors, such as Mortimer (1990).

Spadaro 2000 Nuclear-2.5 to 5.7 g Ceq/kWh

Coal-264 to 357 g Ceg/kWh

Fritsche 2006 Nuclear-33 g Ceq/kWh

(values estimated Coal-950 g Ceq/kWh

from graph in

Figure 4)

POST 2006 Nuclear-5 g Ceq/kWh

(Nuclear

calculations from Coal->1000 g Ceq/kWh

AEA 2006) Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 6.8 g

Ceq /kWh. Future improved technology and carbon capture and storage

could reduce coal-fired GHG emissions by 90 percent.

Weisser 2006 Nuclear-2.8 to 24 g Ceq/kWh

(compilation of

results from other Coal-950 to 1250 g Ceq/kWh

studies)

2 6.2.8 Summary of Nuclear Greenhouse Gas Emissions Compared to Natural Gas

3 The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle, as

4 compared to an equivalent natural gas-fired plant, are presented in Table 6-3.

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

Source GHG Emission Results

Spadaro 2000 Nuclear-2.5 to 5.7 g Ceq/kWh

Natural Gas-i120 to 188 g Ceg/kWh

Storm van Nuclear fuel cycle produces 20 to 33% of the GHG emissions compared to

Leeuwen and natural gas (at high ore grades).

Smith 2005 Note: Future nuclear GHG emissions to increase because of declining ore

grade.

Fritsche 2006 Nuclear-33 g Ceq/kWh

Draft NUREG-1437, Supplement 39 6-6 October 2009
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

(values estimated

from graph in

Fiqure 4)

Cogeneration Combined Cycle Natural Gas-i150 g Ceq/kWh

POST 2006 Nuclear-5 g Ceq/kWh

(Nuclear

calculations from Natural Gas-500 g Ceq/kWh

AEA 2006) Note: Decrease of uranium ore grade to 0.03% would raise nuclear to

6.8 g Ceq/kWh. Future improved technology and carbon capture and

storage could reduce natural gas GHG emissions by 90%.

Weisser 2006 Nuclear-2.8 to 24 g Ceq/kWh

(compilation of

results from other Natural Gas-440 to 780 g Ceq/kWh

studies)

Dones 2007 Author critiqued methods and assumptions of Storm van Leeuwen and

Smith (2005), and concluded that the nuclear fuel cycle produces 15 to 27%

of the GHG emissions of natural gas.

6.2.9 Summary of Nuclear Greenhouse Gas Emissions Compared to Renewable Energy

Sources

The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle, as

compared to equivalent renewable energy sources, are presented in Table 6-4. Calculation of

GHG emissions associated with these sources is more difficult than the calculations for nuclear

energy and fossil fuels because the efficiencies of the different energy sources vary so much by

location. For instance, the efficiency of solar and wind energy is highly dependent on the

location in which the power generation facility is installed. Similarly, the range of GHG emissions

estimates for hydropower varies greatly depending on the type of dam or reservoir involved.

Therefore, the GHG emissions estimates for these energy sources have a greater range of

variability than the estimates for nuclear and fossil fuel sources.

1

2

3

4

5

6

7

8

9

10

11

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

Source GHG Emission Results

Mortimer 1990 Nuclear-230,000 tons C02

Hydropower-78,000 tons C02

Wind power-54,000 tons C02

Tidal power-52,500 tons C02

Note: Future GHG emissions from nuclear to increase because of declining

ore grade.

Spadaro 2000 Nuclear-2.5 to 5.7 g Ceq/kWh

Solar PV-27.3 to 76.4 g Ceq/kWh

Hydroelectric-1.1 to 64.6 g Ceq/kWh

Biomass-8.4 to 16.6 g Ceq/kWh

Wind-2.5 to 13.1 g Ceq/kWh

Fritsche 2006 Nuclear-33 g Ceq/kWh

October 2009 6-7 Draft NUREG-1437, Supplement 39
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

Source GHG Emission Results

(values estimated Solar PV-125 g Ceq/kWh

from graph in

Figure 4) Hydroelectric-50 g Ceq/kWh

Wind-20 g Ceg/kWh

POST 2006 Nuclear-5 g Ceq/kWh

(Nuclear

calculations from Biomass-25 to 93 g Ceq/kWh

AEA 2006) Solar PV-35 to 58 g Ceq/kWh

Wave/Tidal-25 to 50 g Ceq/kWh

Hydroelectric-5 to 30 g Ceq/kWh

Wind-4.64 to 5.25 g Ceq/kWh

Note: Decrease of uranium ore grade to 0.03% would raise nuclear to

6.8 g Ceg/kWh.

Source GHG Emission Results

Weisser 2006 Nuclear-2.8 to 24 g Ceq/kWh (compilation of resuplatsrom 

results from other othr Solar PV-43 to 73 g Ceq/kWh

studies) Hydroelectric-1 to 34 g Ceq/kWh

Biomass-35 to 99 g Ceq/kWh

Wind-8 to 30 g Ceg/kWh

Fthenakis and Kim Nuclear-16 to 55 g Ceq/kWh

(2007) Solar PV-17 to 49 g Ceg/kWh

Dones 2007 Author did not evaluate nuclear versus renewable energy sources.

1

2 6.2.10 Conclusions

3 Estimating the GHG emissions associated with current nuclear energy sources is challenging

4 because of differing assumptions and noncomparable analyses performed by the various

5 authors. The differences and complexities in these assumptions and analyses increase when

6 using them to project future GHG emissions. However, even with these differences, the NRC

7 staff can draw several conclusions.

8 First, the studies indicate a consensus that nuclear power currently produces fewer GHG

9 emissions than fossil-fuel-based electrical generation. Based on the literature review, the

10 lifecycle GHG emissions from the complete nuclear fuel cycle currently range from 2.5 to

11 55 g Ceq/kWh. The comparable lifecycle GHG emissions from the current use of coal range from

12 264 to 1250 g Cec/kWh, and GHG emissions from the current use of natural gas range from 120

13 to 780 g Ceq/kWh. The existing studies also provided estimates of GHG emissions from five

14 renewable energy sources, based on current technology. These estimates included solar15 photovoltaic (17 to 125 g Ceq/kWh), hydroelectric (1 to 64.6 g Ceq/kWh), biomass (8.4 to 99 g

16 Ceq/kWh), wind (2.5 to 30 g Ceq/kWh), and tidal (25 to 50 g Ceq/kWh). The range of these

17 estimates is very wide, but the general conclusion is that the current GHG emissions from the

Draft NUREG-1437, Supplement 39 6-8 October 2009
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

1 nuclear fuel cycle are of the same order of magnitude as those for these renewable energy

2 sources.

3 Second, the studies indicate no consensus on future relative GHG emissions from nuclear

4 power and other sources of electricity. There is substantial disagreement among the various

5 authors regarding the GHG emissions associated with declining uranium ore concentrations,

6 future uranium enrichment methods, and other factors, including changes in technology. Similar

7 disagreement exists regarding future GHG emissions associated with coal and natural gas

8 electricity generation. Even the most conservative studies conclude that the nuclear fuel cycle

9 currently produces fewer GHG emissions than fossil-fuel-based sources, and are expected to

10 continue to do so in the near future. The primary difference between the authors is the projected

11 cross-over date (the time at which GHG emissions from the nuclear fuel cycle exceed those of

12 fossil-fuel-based sources) or whether cross-over will actually occur at all.

13 Considering the current estimates and future uncertainties, it appears that GHG emissions

14 associated with the proposed PINGP 1 and 2 relicensing action are likely to be lower than those

15 associated with fossil-fuel-based energy sources. The NRC staff bases this conclusion on the

16 following rationale:

17 1) The current estimates of GHG emissions from the nuclear fuel cycle are far

18 below those for fossil-fuel-based energy sources.

19 2) PINGP 1 and 2 license renewal will involve continued GHG emissions due to

20 uranium mining, processing, and enrichment, but will not result in increased

21 GHG emissions associated with plant construction or decommissioning (as

22 the plant will have to be decommissioned at some point whether the license

23 is renewed or not).

24 3) Few studies predict that nuclear fuel cycle emissions will exceed those of

25 fossil fuels within a timeframe that includes the PINGP 1 and 2 periods of

26 extended operation. Several studies suggest that future extraction and

27 enrichment methods, the potential -for higher grade resource discovery, and

28 technology improvements could extend this timeframe.

29 With respect to comparison of GHG emissions between the proposed PINGP 1 and 2 license

30 renewal action and renewable energy sources, it appears likely that there will be future

31 technology improvements and changes in the type of energy used for mining, processing, and

32 constructing facilities in both areas. Currently, the GHG emissions associated with the nuclear

33 fuel cycle and renewable energy sources are within the same range. Because nuclear fuel

34 production is the most significant contributor to possible future increases in GHG emissions

35 from nuclear power, and because most renewable energy sources lack a fuel component, it is

36 likely that GHG emissions from renewable energy sources would be lower than those

37 associated with PINGP 1 and 2 at some point during the period of extended operation.

38 6.3 References

39 10 CFR 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental Protection

40 Regulations for Domestic Licensing and Related Regulatory Functions."

41 10 CFR 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for Renewal

42 of Operating Licenses for Nuclear Power Plants."

43 10 CFR Part 63. Code of Federal Regulations, Title 10, Energy, Part 63, "Disposal of High-Level

44 Radioactive Wastes in a Geologic Repository at Yucca Mountain, Nevada."

October 2009 6-9 Draft NUREG-1437, Supplement 39
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

1 40 CFR Part 191. Code of Federal Regulations, Title 40, Protection of Environment, Part 191,

2 "Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear

3 Fuel, High-Level and Transuranic Radioactive Waste."

4 AEA (AEA Technology). 2006. "Carbon Footprint of the Nuclear Fuel Cycle, Briefing Note."

5 Prepared for British Energy. March 2006.

6 Andseta, S., M.J. Thompson, J.P. Jarrell, and D.R. Pendergast. 1998. "CANDU Reactors and

7 Greenhouse Gas Emissions." Canadian Nuclear Association, 1 1th Pacific Basin Nuclear

8 Conference, Banff, Alberta, Canada. May 1998.

9 DOE (Department of Energy). 1980. "Final Environmental Impact Statement: Management of

10 Commercially Generated Radioactive Waste." DOE/EIS-0046F, Washington, DC.

11 Dones, R. 2007. "Critical Note on the Estimation by Storm Van Leeuwen J.W. and Smith P. of

12 the Energy Uses and Corresponding CO 2 Emissions for the Complete Nuclear Energy Chain."

13 Paul Sherer Institute. April 2007.

14 Fritsche, U.R. 2006. "Comparison of Greenhouse-Gas Emissions and Abatement Cost of

15 Nuclear and Alternative Energy Options from a Life-Cycle Perspective." Oko-Institut, Darmstadt

16 Office. January 2006.

17 Fthenakis, V.M., and H.C. Kim. 2007. Greenhouse-gas emissions from solar electric- and

18 nuclear power: A life cycle study. Energy Policy, Volume 35, Number 4.

19 Hagen, R.E., J.R. Moens, and Z.D. Nikodem. 2001. "Impact of U.S. Nuclear Generation on

20 Greenhouse Gas Emissions." International Atomic Energy Agency, Vienna, Austria. November

21 2001.

22 IAEA (International Atomic Energy Agency). 2000. "Nuclear Power for Greenhouse Gas

23 Mitigation under the Kyoto Protocol: The Clean Development Mechanism (CDM)." November

24 2000.

25 Joint Resolution 87, 2002. Public Law 107-200, 116 Stat 735.

26 Keepin, B. 1988. "Greenhouse Warming: Efficient Solution of Nuclear Nemesis?" Rocky

27 Mountain Institute. Joint Hearing on Technologies for Remediating Global Warming,

28 Subcommittee on Natural Resources, Agriculture Research and Environment and

29 Subcommittee on Science, Research and Technology, United States House of Representatives.

30 June 1988.

31 MIT (Massachusetts Institute of Technology). 2003. "The Future of Nuclear Power: An

32 Interdisciplinary MIT Study."

33 Mortimer, N. 1990. World warms to nuclear power. SCRAM Safe Energy Journal. December

34 1989 and January 1990. Available at URL:

35 http://www.no2nuclearpower.org.uk/articles/mortimerse74.php. Accessed February 29, 2007.

36 NAS (National Academy of Sciences). 1995. "Technical Bases for Yucca Mountain Standards."

37 Washington, DC.

38 NEA (Organization for Economic Co-Operation and Development, Nuclear Energy Agency).

39 2002. Nuclear Energy and the Kyoto Protocol.

40 NEPA (National Environmental Policy Act of 1969). 42 U.S.C. 4321, et seq.

41 NIRS/WISE (Nuclear Information and Resource Service and World Information Service on

42 Energy). 2005. Nuclear power: No solution to climate change. Nuclear Monitor, Numbers 621

43 and 622. February 2005.

Draft NUREG-1437, Supplement 39 6-10 October 2009
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

1 NMC (Nuclear Management Company, LLC). 2008. Prairie Island Nuclear Generating Plant,

2 Units 1 and 2, License Renewal Application, Appendix E - Applicant's Environmental Report,

3 License Renewal Operating Stage. Redwing, Minnesota. April 2008. ADAMS Nos.

4 ML081130677, ML081130681, and ML081130684.

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

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

7 ML040690705 and ML040690738.

8 NRC. (U.S. Nuclear Regulatory Commission). 1999. Generic Environmental Impact Statement

9 for License Renewal of Nuclear Plants, Main Report, "Section 6.3 - Transportation, Table 9.1.,

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

11 Report." NUREG-1437, Volume 1, Addendum 1, Washington, DC.

12 POST (Parliamentary Office of Science and Technology). 2006. "Carbon Footprint of Electricity

13 Generation." Postnote, Number 268. October 2006.

14 Schneider, M. 2000. Climate Change and Nuclear Power. World Wildlife Fund for Nature. April

15 2000.

16 Spadaro, J.V., L. Langlois, and B. Hamilton. 2000. "Greenhouse Gas Emissions of Electricity

17 Generation Chains: Assessing the Difference." IAEA Bulletin 42/2/2000, Vienna, Austria.

18 Storm van Leeuwen, J.W., and P. Smith. 2005. Nuclear Power-The Energy Balance. August

19 2005.

20 Weisser, D. 2006. "A Guide to Life-Cycle Greenhouse Gas (GHG) Emissions from Electric

21 Supply Technologies." Available at URL:

22 http://www.iaea.org/OurWork/ST/NE/Pess/assets/GHGmanuscript-pre23 print versionDanielWeisser.pdf. Accessed May 19, 2009.

October 2009 6-11 Draft NUREG-1437, Supplement 39
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

S1

Draft NUREG-1437, Supplement 39 6-12 October 2009
Environmental Impacts of Decommissioning

1 7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING

2 Decommissioning is defined as the safe removal of a nuclear facility from service and the

3 reduction of residual radioactivity to a level that permits release of the property for unrestricted

4 use and termination of the license. The U.S. Nuclear Regulatory Commission (NRC) issued the

5 Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities (NRC 2002)

6 that evaluated the environmental impacts from the activities associated with the

7 decommissioning of any reactor before or at the end of an initial or renewed license.

8 The NRC staff has not identified any new and significant information during the review of the

9 Northern State Power Co. (NSP) environmental report (ER; NMC 2008), the site audit, or the

10 scoping process. Therefore, there are no impacts related to these issues beyond those

11 discussed in the GElS (NRC 1996, 1999). For the issues listed in table 7-1 below, the GElS

12 concluded that the impacts are SMALL.

13 Plant shutdown will likely have no noticeable impacts on historic and archaeological resources

14 at the PINGP 1 and 2 site. NRC requirements ensure that the decommissioning activities for

15 PINGP 1 and 2 would be subject to a Section 106 review in accordance with the National

16 Historic Preservation Act (NHPA). In Chapter 4, the NRC concluded that the impacts of

17 continued plant operation on historic and archaeological resources could be MODERATE.

18 Since plant shutdown would not involve any land disturbance, the NRC concludes that the

19 impacts on historic and archaeological resources from plant shutdown would be SMALL.

20 Table 7-1. Issues Related Decommissioning. Decommissioning would occur

21 regardless of whether Three Mile Island Nuclear Station, Unit 1, is shut down at the end

22 of its currect operating license or at the end of the period of extended operation. There

23 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

24 7.1 References

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

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

27 Nos. ML040690705 and ML040690738.

28 NRC (U.S. Nuclear Regulatory Commission). 1999. Generic Environmental Impact Statement

29 for License Renewal of Nuclear Plants, Main Report, "Section 6.3, Transportation, Table 9.1,

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

31 Report." NUREG-1437, Volume 1, Addendum 1. Washington, D.C.

October 2009 7-1 Draft NUREG-1437, Supplement 39
Environmental Impacts of Decommissioning

1 NRC (U.S. Nuclear Regulatory Commission). 2002. Generic Environmental Impact Statement

2 on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of

3 Nuclear Power Reactors. NUREG-0586, Supplement

4 NMC (Nuclear Management Company, LLC). 2008. Prairie Island Nuclear Generating Plant,

5 Units 1 and 2, License Renewal Application, Appendix E - Applicant's Environmental Report,

6 License Renewal Operating Stage. Redwing, Minnesota. April 2008. ADAMS Nos.

7 ML081130677, ML081130681, and ML081130684.

8

Draft NUREG-1437, Supplement 39 7-2 October 2009
Alternatives

1 8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES

2 The National Environmental Policy Act of 1969 (NEPA) mandates that each environmental

3 impact statement (EIS) consider alternatives to any proposed major federal action. NRC

4 regulations implementing NEPA for license renewal require that a supplemental EIS "considers

5 and weighs the environmental effects of the proposed action [license renewal]; the

6 environmental impacts of alternatives to the proposed action; and alternatives available for

7 reducing or avoiding adverse environmental impacts," [10 CFR 51.71(d)]. In this case, the

8 proposed Federal action is issuing renewed licenses for Prairie Island Nuclear Generating Plant,

9 Units 1 and 2 (PINGP 1 and 2), which will allow the plant to operate for 20 years beyond their

10 current license expiration dates.

11 In this chapter, we examine the potential environmental impacts of alternatives to issuing

12 renewed operating licenses for PINGP 1 and 2, as well as alternatives that may reduce or avoid

13 adverse environmental impacts from license renewal, when and where these alternatives are

14 applicable.

15 While the Generic Environmental Impact Statement for License Renewal of Nuclear Plants,

16 NUREG-1437 (GELS; NRC 1996; 1999), reached generic conclusions regarding many

17 environmental issues associated with license renewal, it did not determine which alternatives

18 are reasonable or reach conclusions about site-specific environmental impact levels. Therefore,

19 the NRC staff must evaluate environmental impacts of alternatives on a site-specific basis.

20 In accordance with the GELS, alternatives to the proposed action of issuing renewed PINGP 1

21 and 2 operating licenses must meet the purpose and need for issuing a renewed license; they

22 must:

23 provide an option that allows for power generation capability beyond the term of

24 a current nuclear power plant operating license to meet future system generating

25 needs, as such needs may be determined by State, utility, and, where

26 authorized, Federal (other than NRC) decisionmakers.

27 The NRC staff ultimately make no decision regarding which alternative, or whether the proposed

28 action, is implemented, since that decision falls to utility, State, or other Federal officials.

29 Comparing the environmental effects of these alternatives will assist the NRC staff in deciding

30 whether the environmental impacts of license renewal are so great that preserving the option of

31 license renewal for energy-planning decisionmakers would be unreasonable [10 CFR

32 51.95(c)(4)]. If the NRC acts to issue a renewed license, all of the alternatives, including the

33 proposed action, will be available to energy-planning decisionmakers. If the NRC decides not to

34 renew the license (or takes no action at all), then energy-planning decisionmakers may no

35 longer elect to continue operating PINGP 1 and 2 and will have to resort to another alternative,

36 which may or may not be one of the alternatives the NRC staff considers in this section, in order

37 to meet their energy needs.

38 In addition to evaluating alternatives to the proposed action, when appropriate, the NRC staff

39 also examine alternatives that may reduce or avoid environmental impacts of the proposed

40 action; the staff does so to illustrate how such alternatives may act to mitigate potential impacts

41 of license renewal.

42 In evaluating alternatives to license renewal, the NRC staff first selects energy technologies or

43 options currently in commercial operation as well as some technologies not currently in

44 commercial operation but likely to be commercially available by the time the current PINGP 1

45 and 2 operating licenses expire.

October 2009 8-1 Draft NUREG-1437, Supplement 39
Alternatives

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

Second, the NRC staff screens the alternatives to remove In

those that cannot meet future system needs. Then, the

NRC staff screens the remaining options to remove those

for which the cost or benefits do not justify inclusion in the

range of reasonable alternatives. Any alternatives

remaining, then, constitute alternatives to the proposed

action that the NRC staff evaluates in-depth throughout

this section. At the end of the section, the NRC staff briefly

addresses each alternative that was removed during

screening.

The NRC staff initially considered 14 discrete potential

alternatives to the proposed action and narrowed the list to

one single-source alternative and two combination O0

alternatives considered in this chapter. In addition, the C

NRC staff considered purchased power, but not as a

discrete alternative to license renewal, because the power

sources for purchased power would likely be similar to

those considered in this section, but may include older,

less clean and efficient power plants. Also, Minnesota's

Next Generation Energy Act of 2007 (136-S.F.No. 145)

restricts importation of power from certain power plants,

including essentially any new coal-fired power plant.

Once the NRC staff identified the in-depth alternatives, it

referred to generic environmental impact evaluations in the

GELS. The GElS provides overviews of some energy

technologies available at the time of its publishing in 1996,

though it does not reach any conclusions regarding which

alternatives are most appropriate, nor does it precisely

categorize impacts for each site. Since 1996, many energy

technologies have evolved significantly in capability and

cost, while regulatory structures have changed to either promote

particular alternatives.

-Depth Alternatives:

" Natural-gas-fired

combined-cycle

* Combination

including natural gas,

wind, wood-fired

generation

* Combination

,including one nuclear

unit, natural gas, and

wind

ther Alternatives

onsidered:

* Wind Power

* Wood Waste

* Conservation

" Solar Power

" Conventional

Hydroelectric Power

* Geothermal Power

* Biofuels

• New nuclear

* Coal-fired power

• Oil-fired Power

* Fuel Cells

* Municipal Solid Waste

o Delayed Retirement

or impede development of

Where applicable, the NRC staff uses information in the GElS and includes updated information

from the Energy Information Administration (EIA), other organizations within the Department of

Energy (DOE), the U.S. Environmental Protection Agency (EPA), industry sources and

publications, and information submitted by Northern States Power Co. (NSP) in the

environmental report (ER).

For each in-depth analysis, the NRC staff analyzes environmental impacts across seven impact

categories: air quality, groundwater use and quality, surface water use and quality, ecology,

human health, socioeconomics, and waste management. As in earlier chapters of this draft

supplemental environmental impact statement (SEIS), the NRC staff uses the NRC's three-level

standard of significance - SMALL, MODERATE, or LARGE - to indicate the intensity of

environmental effects for each alternative that the NRC staff evaluates in-depth.

Draft NUREG-1437, Supplement 39 8-2 October 2009
Alternatives

1 By placing the detailed alternative analyses in Enerhgy Outlook: Each year the Energy

2 this order, the NRC staff does not imply which Infomation Administration (EIA), part of the

3 alternative would have the least impact, or U.S. Departmentof Energy (DOE), issues

4 which alternative an energy planning its updatedAnnual Energy Outlook (AEO).

5 decisionmaker would be most likely to "-AEO 2I008indicates that coal and natural

6 implement. Whenever possible, the NRC staff g.as are likely to fuel most new electrical

7 considers effects from locating the alternative capacity tough 23wt nifican

8 at the existing site, as well as at an alternate capacity through 2030, with significant 9 site. contributions from new renewable sources,

and some growth in nuclear capacity (EIA

10 Sections 8.1 through 8.3, include the NRC 2008a), though all projections are subject

11 staff's analysis of environmental impacts of to future developments in fuel price or

12 alternatives to license renewal. These include electricity demand:

13 a gas-fired alternative located both at the

14 PINGP 1 and 2 site and at a different site ."Natural-gas-fired plants generally have

15 (8.1), a combination alternative including gas- 'lower capacity costs but higher fuel

16 fired capacity at the PINGP 1 and 2 site as costs than coal-fired plants. As a result,

17 well as renewable capacity at other sites and coal-fired plants account for 40 percent

18 conservation (8.2), and a combination of total "capacity additions from 2006 to

19 alternative that includes continued operation of .,2030, compared with a 36-percent share

20 one PINGP 1 and 2 unit as well as renewables 'for natural gas. Renewable and nuclear.

21 and conservation (8.3). In section 8.4, the plants tend to have high investment

22 NRC staff briefly discusses purchased power. c.Pdosts and relatively low operating costs..

23 In section 8.5, the NRC staff addresses . -.•EPACT,2005and State RPS programs

24 alternatives excluded from in-depth analysis ,are expected to stimulate generation

25 and addresses why they were excluded. from renewable and nuclear plants,

26 Finally, in section 8.6, the NRC staff considers 'which represent 18 percent and 6

27 the environmental effects that occur if NRC perceentf total additions, respectively.

28 takes no action and does not issue renewed -,The quantity and mix of capacity

29 licenses for PINGP 1 and 2. additions can also be affected by different fuel price paths or growth rates

30 Notably, the NRC staffs alternatives analysis for electricity demand."

31 for PINGP 1 and 2 license renewal excludes forelectricitydemand."

32 several alternatives the NRC staff typically

33 analyzes for license renewal. As discussed in greater depth in Section 8.4, the NRC staff found

34 that Minnesota regulations restricting greenhouse gas emissions would make building a coal35 fired alternative difficult regardless of combustion technology used. The NRC staff also found

36 that the lead time remaining prior to the expiration of current PINGP 1 and 2 licenses make it

37 unlikely that a replacement nuclear plant could be permitted and constructed prior to license

38 expiration. The alternatives that NRC staff considered in depth, then, focus primarily on natural

39 gas-fired generation, wind, wood waste biomass, and conservation resources.

40 8.1 Gas-fired Generation

41 In this section, the NRC staff evaluates the environmental impacts of natural gas-fired

42 generation at both the PINGP 1 and 2 site and at an alternate site.

43 Natural gas fueled 20 percent of electric generation in the U.S. in 2006, the most recent year for

44 which data are available, accounting for the second greatest share of electrical power after coal

45 (EIA 2007a). Like coal-fired power plants, natural-gas-fired plants may be affected by perceived 46 or actual action to limit greenhouse gas emissions, though they produce markedly fewer

47 greenhouse gases per unit of electrical output than coal-fired plants. Natural gas-fired power

October 2009 8-3 Draft NUREG-1437, Supplement 39
Alternatives

1 plants are feasible, commercially-available options for providing electrical generating capacity

2 beyond the current license terms for PINGP 1 and 2.

3 Combined-cycle power plants differ significantly from power plants that generate electricity

4 solely from a steam cycle, as almost all coal-fired and all existing nuclear power plants do.

5 Combined-cycle power plants derive the majority of their electrical output from a gas-turbine

6 cycle, and then generate additional power - without burning any additional fuel - through a

7 second, steam-turbine cycle. The first, gas-turbine stage (similar to a large jet engine) burns

8 natural gas that turns a driveshaft to power an electric generator. Ducts carry the hot exhaust

9 from the turbine to a heat recovery steam generator, which then produces steam to drive

10 another turbine and produce additional electrical power. The combined-cycle approach is

11 significantly more efficient than any one cycle on its own; efficiencies can exceed 60 percent.

12 Natural gas combined-cycle generation requires significantly less cooling water and smaller

13 cooling towers than the existing PINGP 1 and 2 units, partly because of greater thermal

14 efficiency and partly because gas turbines do not require condenser cooling like steam turbines

15 do.

16 In order to replace the 1044 megawatts electrical (MWe) that PINGP 1 and 2 currently supply,

17 the NRC staff selected a gas-fired alternative that uses two General Electric Company (GE)

18 S207FB combined-cycle generating units. While any number of commercially-available

19 combined-cycle units could be installed in a variety of combinations to replace the power

20 currently produced by PINGP 1 and 2, the S207FB is an efficient model that operates at a heat

21 rate of 5940 British thermal units per kilowatt hour (Btu/kWh), or 57.4 percent thermal efficiency

22 (GE 2007). GE and other manufacturers, like Siemens, offer similar high efficiency models,

23 including several that slightly exceed the thermal efficiency of this model. The NRC staff

24 selected this particular configuration because it is able to provide almost the same amount of

25 electricity as PINGP 1 and 2. This gas-fired alternative produces 562.5 MWe per unit. Two units

26 produce a total of 1125 MWe - or, after accounting for 4 percent onsite usage including site

27 lighting, cooling towers, and emissions controls - nearly the same output as PINGP 1 and 2.

28 Cooling towers for this alternative would likely be mechanical draft-type towers approximately

29 65 ft (20 m) in height and similar in appearance and function to the existing PINGP 1 and 2

30 cooling towers.

31 In addition to cooling towers, other visible structures onsite would include the turbine buildings

32 and heat recovery steam generators (which may be enclosed in the turbine building), two

33 exhaust stacks, an electrical switchyard, and, possibly, equipment associated with a natural gas

34 pipeline, like a compressor station. The GElS estimated that a 1000 MWe gas-fired alternative

35 would require 110 ac (40 ha), meaning this 1125-MWe plant would require 129 ac (52 ha). In

36 their ER, NSP (NMC 2008) indicated that the plant would require 41 ac (17 ha), a number more

37 consistent with minimum utility needs as demonstrated by existing power plants (including

38 Dominion Resources' Fairless Energy Works located in Falls Township, Pennsylvania). The

39 NRC staff uses NSP's estimate for the purposes of the following analysis.

40 This 1125-MWe power plant would consume 50.2 billion ft3 (1.4 billion Mi) of natural gas

41 annually, assuming an average heat content of 1,033 Btu/ft3 (EIA 2006). Natural gas would be

42 extracted from the ground through wells, then treated to remove impurities (like hydrogen

43 sulfide), and blended to meet pipeline gas standards, before being piped through the interstate

44 pipeline system to the power plant site. This gas-fired alternative would produce relatively little

45 waste, which would primarily be in the form of spent catalysts used for emissions controls.

46 Environmental impacts from the gas-fired alternative will be greatest during construction. Site

47 crews will clear vegetation from the site, prepare the site surface, and begin excavation before

48 other crews begin actual construction on the plant and any associated infrastructure, including a

Draft NUREG-1437, Supplement 39 8-4 October 2009
Alternatives

1 pipeline spur to serve the plant and electricity transmission infrastructure connecting the plant to

2 existing transmission lines.

3 Constructing the gas-fired alternative on the PINGP 1 and 2 site would allow the gas-fired

4 alternative to make use of the site's existing transmission system, as well as take advantage of

5 partially cleared areas of the site.

6 A gas-fired unit constructed offsite may cause additional construction-related impacts depending

7 on the nature of the site selected. A site that has never been developed will likely experience

8 greater impacts than a site that was previously industrial; a site near other power plants or

9 industrial facilities will likely experience smaller impacts than a site surrounded by farmland or

10 relatively natural surroundings.

11 Table 8-1. Summary of Environmental Impacts of Gas-Fired Combined-Cycle Generation

12 Compared to Continued PINGP 1 and 2 Operation

Gas-fired combined-cycle Continued

At PINGP I and 2 site At alternate site PINGPerationd 2

Air Quality MODERATE MODERATE SMALL

Groundwater SMALL SMALL SMALL

Surface Water SMALL SMALL SMALL

Ecology SMALL SMALL TO MODERATE SMALL

Human Health SMALL SMALL SMALL

Socioeconomics SMALL TO MODERATE SMALL TO MODERATE SMALL TO

MODERATE

Waste Management SMALL SMALL SMALL

13 8.1.1 Air Quality

14 With the exception of Olmstead County, all Minnesota counties within the Southeast Minnesota15 La Crosse (Wisconsin) Interstate Air Quality Control Region are in attainment for all Clean Air

16 Act (CAA) criteria pollutants. Olmsted County, which is located approximately 30 mi (48 km) to

17 the south of PINGP 1 and 2, is a maintenance county for sulfur dioxide (SO2) and particulate

18 matter (PM10).

19 A new gas-fired generating plant, would qualify as a new major-emitting industrial facility and

20 require a New Source Review and a Title V permit under the CAA (EPA 2008). The New Source

21 Review program requires that a permit be obtained before construction of a new major-emitting

22 industrial facility (42 U.S.C. §7475(a)). The permit will be issued only if the new plant includes

23 pollution control measures that reflect the Best Available Control Technology standard

24 mandated by the CAA. The natural gas-fired plant would need to comply with the standards of

25 performance for electric utility steam generating units set forth in 40 CFR Part 60, Subpart D,

26 "Standards of Performance for New Stationary Sources." Additionally, in order to address

27 climate change issue and greenhouse gas emissions with the effort to maximize energy

28 efficiency and minimize greenhouse gas emissions, the Minnesota Pollution Control Agency

29 (MPCA) requires submission of an Air Emission Risk Analysis for proposed electric production

30 facilities greater than or equal to 25 MWe and completion of the Greenhouse Gas Emissions

31 Evaluation in conjunction with the application for a Title V permit, as required per 40 CFR Part

32 70.

33 Emissions sources constructed in attainment or unclassified areas that may have an effect on

34 visibility in designated Federal Class I areas, as defined by Protection of Visibility provisions (40

35 CFR Part 51, Subpart P), must complete a new source review. The closest Federal Class I

October 2009 8-5 Draft NUREG-1437, Supplement 39
Alternatives

1 areas to the PINGP 1 and 2 site are Boundary Waters Canoe Area Wilderness Area, located

2 approximately 230 mi (370 km) north-northeast of the PINGP 1 and 2 site, and Voyageurs

3 National Park, located 260 mi (420 km) north-northwest of the PINGP 1 and 2 site. If the gas4 fired alternative were constructed near or at the PINGP 1 and 2 site, it is unlikely that this

5 additional requirement would apply, as the nearest Federal Class I areas in Minnesota would

6 not be significantly affected due to the distance from the site.

7 The projected emissions from this natural gas-fired alternative based on published EIA data,

8 EPA emission factors, performance characteristics for this alternative, and implemented

9 emission controls are as follows:

10 Sulfur dioxide (S02)- 88.11 tons (79.94 MT) per year;

11 Nitrogen oxides (NO,) - 282.48 tons (256.27 MT) per year;

12 Carbon monoxide (CO) - 58.72 tons (53.28 MT) per year;

13 Total suspended particles/PM10 - 49.24 tons (44.67 MT) per year;

14 Carbon dioxide (C0 2) - 3,031,481.84 tons (2,750,160.32 MT) per year.

15 The new natural gas-fired plant would have to comply with Title IV of the CAA reduction

16 requirements for SO2 and NO,. These compounds are precursors of acid rain and are major

17 contributors to reduced visibility. Title IV establishes maximum SO2 and NOx emission rates

18 from existing plants and a system of the S02 emission allowances that can be used, sold, or

19 saved for future use by the new plants.

20 As stated above, the new natural gas-fired alternative would produce 88.11 tons (79.94 MT) per

21 year of SO2 and 282.48 tons (256.27 MT) per year of NO, based on the use of the dry-low NO,

22 combustion technology and the use of the selective catalytic reduction in order to significantly

23 reduce NOx emissions.

24 The new plant would be subject to the continuous monitoring requirements of S021 NO,, and CO

25 specified in 40 CFR Part 75. The natural gas-fired plant would emit approximately 2.9 million

26 tons (approximately 2.6 million MT) per year of unregulated CO 2 emissions. Minnesota Statute

27 §216H (added as part of the Next Generation Energy Act of 2007) stipulates greenhouse gas

28 emissions reporting requirements and statewide adoption of a climate change action plan, which

29 requires a reduction in greenhouse gases. Minnesota also voluntarily participates in the Climate

30 Registry which establishes and endorses a greenhouse gas emissions inventory across North

31 America. The inventory contains verified and accurate data available to the public and is

32 published as general reporting protocol.

33 This alternative would emit 49.24 tons (44.67 MT) per year of particulate matter having an

34 aerodynamic diameter less than or equal to 10 pm (PM10) (40 CFR 50.6a). All suspended

35 particles emitted by this alternative are PM10.

36 Activities associated with the construction of the new natural gas-fired plant onsite or offsite of

37 the PINGP 1 and 2 site would cause some additional air effects as a result of equipment

38 emissions and fugitive dust from operation of the earth-moving and material handling

39 equipment. Exhaust emissions from workers' vehicles and construction equipment would be

40 temporary. The construction crews would employ dust-control practices in order to control and

41 reduce fugitive dust, which would be temporary in nature. The NRC staff concludes that the

42 impact of vehicle exhaust emissions and fugitive dust from operation of the earth-moving and

43 material handling equipment would be SMALL.

44 The overall air-quality impacts of a new natural gas-fired plant located at the PINGP 1 and 2 site

45 or at an alternate site would be MODERATE.

Draft NUREG-1437, Supplement 39 8-6 October 2009
Alternatives

1 8.1.2 Groundwater Use and Quality

2 The use of groundwater for a gas-fired plant in Minnesota would likely be limited to supply wells

3 for drinking water, pump and valve cooling, filtered service water for system cleaning purposes,

4 and landscaping. The number, depth, and location of the wells would be specific to the site

5 selected for the plant. One onsite plant located on the PINGP 1 and 2 site with two units would

6 use the same shallow alluvial aquifer and the bedrock Franconia formation as the existing

7 nuclear plant for sources of groundwater supply. The average pumping rate would likely range

8 from 75 to 100 gpm which is less than the current use of ground water.

9 A gas-fired plant at an offsite location would require wells, which would vary in depth depending

10 on groundwater and aquifer resources at the site. Generally, Minnesota has abundant ground

11 water supplies, but the aquifer(s) selected for use at a given location will depend on

12 groundwater quality requirements and the location of existing water supply wells with higher

13 water appropriation priorities.

14 The amount of groundwater needed to service the alternative natural gas-fired plants is

15 relatively low and the impact of groundwater use would be SMALL. No effects on groundwater

16 quality would be apparent, except during the construction phase when possible dewatering and

17 run-off controls are used. The construction phase should implement best management practices

18 to minimize any potential construction impacts.

19 8.1.3 Surface Water Use and Quality

20 Consumptive surface water use for either an onsite or offsite natural gas-fired alternative would

21 be approximately half the volume needed for PINGP 1 and 2 because of a higher efficiency of

22 cooling water used per given unit of energy production. Waste water discharge at the gas-fired

23 plant would be minimal. If the alternative is placed on the existing site, all intakes and

24 discharges would be on the Mississippi River, and the impact on surface water resources, both

25 in quantity and quality, would be SMALL. An offsite location would have different intake and

26 discharge points that would require a National Pollutant Discharge Elimination System (NPDES)

27 permit from the MPCA, but the scale of water use would be the same as for the onsite plant.

28 Therefore, the impact of the offsite plant on surface water use and quality would also be

29 SMALL.

30 8.1.4 Aquatic and Terrestrial Ecology

31 Impacts to aquatic ecology would be minimal, as the consumptive water use of a natural gas32 fired plant would be less than half that of the current consumption rate of PINGP 1 and 2.

33 Additionally, the onsite natural gas-fired plant could use parts of the existing cooling system,

34 which would reduce potential impacts to aquatic resources. Impacts of the offsite alternative to

35 aquatic resources would depend on location, the ecology of the site and the source and

36 receiving water body. Construction in a previously disturbed area would have lower impacts to

37 the aquatic resources than construction in an undisturbed area. Overall, the impacts to aquatic

38 resources from a natural gas-fired plant would be SMALL for an onsite natural gas-fired plant,

39 but could range from SMALL to MODERATE for an offsite plant, depending on the ecological

40 conditions of the alternate site.

41 As indicated in previous sections, constructing the natural gas-fired alternative will require 41 ac

42 (17 ha) of land, according to calculations presented in the ER (NMC 2008). Impacts to terrestrial

43 ecology from the onsite alternative will be minor because the selected site has been previously

44 disturbed. Buildings and structures associated with PINGP 1 and 2 occupy approximately 60 ac

45 (24 ha) of the site (NMC 2008); therefore, some areas of previously disturbed land may return to

October 2009 8-7 Draft NUREG-1437, Supplement 39
Alternatives

1 natural habitat as a result of this alternative because less land would be required than is

2 currently in use for PINGP 1 and 2. Buffer areas and surrounding wetland habitat on or in the

3 vicinity of the site may remain undeveloped and would continue to provide habitat for terrestrial

4 species, though site lighting, noise, and activities may degrade the value of these neighboring

5 habitats. Construction of additional transmission line rights-of-way (ROWs) is unlikely because

6 existing transmission capacity at the PINGP 1 and 2 site could be used. Any lengthy pipelines or

7 additional roads on undisturbed or less-disturbed areas could adversely impact terrestrial

8 ecology by fragmenting or destroying habitats. However, a pipelined fuel source and a small

9 workforce would help to minimize the need for additional transportation infrastructure. Gas

10 extraction and collection will also affect terrestrial ecology in offsite gas fields, although much of

11 this land is likely already disturbed by gas extraction, and the incremental effects of this

12 alternative on gas field terrestrial ecology are difficult to gauge. Deposition of air pollutants from

13 this alternative may affect terrestrial ecology, but it is unlikely to be noticeable. Impacts to

14 terrestrial resources from a natural gas-fired alternative at the PINGP 1 and 2 site would likely

15 be SMALL.

16 Impacts of the offsite alternative to terrestrial resources would depend on location and whether

17 the land was previously disturbed or located near any unique natural habitats. Construction in

18 previously disturbed areas would have lower impacts than construction in an undisturbed area.

19 Because impacts may vary widely based on the natural habitat of an alternate site, impacts to

20 terrestrial resources from an offsite natural gas-fired alternative would range from SMALL to

21 MODERATE.

22 8.1.5 Human Health

23 A natural gas-fired alternative would release a variety of air pollutants. EPA establishes National

24 Ambient Air Quality Standards (NAAQS) for six criteria pollutants (40 CFR Part 50) under the

25 CAA. The CAA recognizes two types of national air quality standards for particle pollution:

26 primary standards set limits to protect public health, including the health of "sensitive"

27 populations such as asthmatics, children, and the elderly; secondary standards set limits to

28 protect public welfare, including protection against visibility impairment, damage to animals,

29 crops, vegetation, and buildings.

30 Human health risks of a gas-fired alternative are generally low, although Table 8-2 of the GElS

31 identifies cancer and emphysema as potential risks from the operation of the natural gas-fired

32 plant. However, the current Federal and Minnesota State air emission standards adequately

33 protect the occupational workers and the members of the public. Therefore, the NRC staff has

34 adopted applicable Federal and state air quality regulations as the thresholds for determining

35 the human health risks associated with the operation of a new natural gas-fired power plant.

36 Natural gas-fired plants emit total suspended particulates mostly in a form of PM10. Fine particle

37 pollution, especially particulate matter less than 2.5 pm in diameter (PM2.5), is linked to a variety

38 of lung and cardiovascular diseases (EPA 2008). Industrial fabric filters or electrostatic

39 precipitators would be used to control and significantly minimize emissions.

40 NOx emissions contribute to formation of ground-level ozone (03) and participate in chemical

41 reactions with other air particles to form nitrate particles, acid aerosols, and NO2, all of which are

42 known to have adverse impacts on human health. If the new natural gas-fired plant employed

43 the latest technology for NO, emission control systems and implemented emission-trading or

44 offset requirements, it would not contribute to an overall increase in NO) in the region. The NRC

45 staff concludes that the impacts on human health of the onsite and offsite natural gas-fired

46 alternative are likely to be SMALL.

Draft NUREG-1437, Supplement 39 8-8 October 2009
Alternatives

1 8.1.6 Socioeconomics

2 Land Use

3 The GElS generically evaluates the impacts of operations on land use both onsite and offsite.

4 The analysis of land use impacts focuses on the amount of land area that would be affected by

5 the construction and operation of a natural gas-fired power plant at the PINGP 1 and 2 site and

6 at an alternate site. Land use impacts would vary depending on where the plant is located and

7 whether construction would take place on undeveloped land or within a previously disturbed

8 (brownfield) site.

9 As stated in the introduction of the natural gas-fired alternative, NSP indicated that

10 approximately 41 ac (17 ha) would be necessary to support a natural gas-fired alternative

11 capable of replacing PINGP 1 and 2. There is a possibility that additional land would be

12 necessary for a buffer zone around plant structures or to support transmission lines at an

13 alternate site and gas pipelines at both PINGP 1 and 2 and at an alternate site. Land use

14 impacts from construction would be SMALL. Impacts could be further reduced if the power plant

15 is collocated at an alternate site with another generating station or on a previously industrial site

16 like PINGP 1 and 2.

17 In addition to onsite land requirements, land would be required offsite for natural gas wells and

18 collection stations. The GElS estimates that 3600 ac (1500 ha) would be required for wells,

19 collection stations, and pipelines to bring the gas to a 1000-MWe generating facility. If this land

20 requirement were scaled with generating capacity, an alternative to PINGP 1 and 2 could

21 require approximately 4220 ac (1710 ha). Most of this land requirement would occur on land

22 where gas extraction already occurs. In addition, some natural gas could come from outside of

23 the U.S. and be delivered as liquefied gas.

24 The elimination of uranium fuel for PINGP 1 and 2 could partially offset offsite land

25 requirements. In the GELS, the NRC staff estimated that, if the need for uranium fuel were

26 eliminated, approximately 1000 ac (405 ha) would not be needed for mining and processing

27 uranium for the operating life of a 1 000-MWe nuclear power plant. For PINGP 1 and 2, roughly

28 1044 ac (423 ha) of uranium mining area would no longer be needed.

29 Overall land use impacts from a gas-fired power plant would be SMALL to MODERATE,

30 depending on whether the gas-fired plant is located at the PINGP 1 and 2 site, local land use if

31 the gas-fired plant is located at a different site, the percentage of gas extraction that takes place

32 where gas extraction already occurs, and the availability of previously disturbed land near the

33 proposed site.

34 Socioeconomics

35 Socioeconomic impacts are defined in terms of changes to the demographic and economic

36 characteristics and social conditions of a region. For example, the number of jobs created by the

37 construction and operation of a new natural gas-fired power plant could affect regional

38 employment, income, and expenditures. Job creation is characterized in two ways: (1)

39 construction-related jobs, which are transient, short in duration, and less likely to have a long40 term socioeconomic impact; and (2) operation-related jobs in support of power plant operations,

41 which have the greater potential for permanent, long-term socioeconomic impacts. Workforce

42 requirements of power plant construction and operations for the natural gas-fired power plant

43 alternative were examined in order to measure their possible effect on current socioeconomic

44 conditions.

October 2009 8-9 Draft NUREG-1437, Supplement 39
Alternatives

1 NSP projected a maximum construction workforce of 629 (NMC 2008). The GElS projects a

2 workforce of 1200 to 2500 for a 1000-MWe plant (when extrapolated, a lower-end workforce of

3 approximately 1400 for an 1125-MWe plant).

4 During construction, the communities surrounding the power plant site would experience

5 increased demand for rental housing and public services, although these effects would be

6 moderated if the power plant construction site is located near an urban area with many skilled

7 workers. The relative economic effect of these workers on local economy and tax base would

8 vary over time.

9 After construction, local communities may be temporarily affected by the loss of construction

10 jobs and associated loss in demand for business services, and the rental housing market could

11 experience increased vacancies and decreased prices. As noted in the GElS, the

12 socioeconomic impacts at a ruralconstruction site could be larger than at an urban site,

13 because of an increased likelihood that the workforce would have to move to be closer to the

14 construction site. The impact of construction on socioeconomic conditions could range from

15 SMALL to MODERATE depending on the socioeconomic characteristics of communities near

16 the new gas-fired plant. The socioeconomic impacts of power plant construction could be

17 reduced if the power plant is located near an urban area with many skilled workers. Impacts are

18 likely to be SMALL at the current plant site given proximity to areas with skilled workers.

19 NSP estimated a gas-fired power plant operations workforce of 35 (NMC 2008), or up to 166

20 workers based on an extrapolated GElS estimates. The NSP estimate appears reasonable and

21 is consistent with trends toward lowering labor costs by reducing the size of power plant

22 operations workforces. Depending on location, the small number of operations workers would

23 likely not have a noticeable effect on socioeconomic conditions in the region.

24 This alternative would lead to the shutdown of the PINGP 1 and 2. This shutdown would have

25 an impact on socioeconomic conditions in the region. Plant shutdown would eliminate

26 approximately 700 jobs and would reduce tax revenue in the region. The loss of these

27 contributions, which may not occur until after decommissioning, could have a SMALL to

28 MODERATE local impact. Appendix J to NUREG-0586, Supplement 1 (NRC 2002) discusses

29 the potential socioeconomic impacts of plant decommissioning.

30 Overall, socioeconomic impacts associated with operation of a gas-fired power plant would be

31 SMALL to MODERATE.

32 Transportation

33 Construction and operation of a two unit natural gas-fired power plant would increase the

34 number of vehicles on roads in the vicinity of the plant. During construction, cars and trucks

35 would deliver workers, materials, and equipment to the worksite. The increase in vehicular traffic

36 would peak during shift changes resulting in temporary levels of service impacts and delays at

37 intersections. Pipeline construction and modification to existing natural gas pipeline systems

38 could also have an impact.

39 During plant operations, transportation impacts would almost disappear. According to NSP,

40 approximately 35 workers would be needed to operate the gas-fired power plant. Because fuel

41 is transported by pipeline, most transportation infrastructure would experience little increased

42 use from plant operations.

43 The gas-fired alternative would have a SMALL impact on transportation conditions in the region

44 around the PINGP 1 and 2 site and a SMALL to MODERATE impact at an alternate site,

45 depending on the location of the alternative site and what the roadway capacity and average

46 daily volumes are at that site location.

Draft NUREG-1437, Supplement 39 8-10 October 2009
Alternatives

1 Aesthetics

2 Aesthetic resources are the natural and manmade features that give a particular landscape its

3 character and aesthetic quality. The aesthetics impact analysis focuses on the degree of

4 contrast between the power plant and the surrounding landscape and the visibility of the power

5 plant.

6 The two gas-fired units could be approximately 100 ft (30 m) tall, with two exhaust stacks at

7 least 175 ft (53 m) tall or taller depending on the topography at an alternate site. Some

8 structures may require aircraft warning lights. If the plant is located near the existing PINGP 1

9 and 2 site some of the impacts may be reduced because higher elevations and vegetation along

10 the Mississippi river valley could make it difficult to see or hear the plant outside of the river

11 valley. Power plant infrastructure would generally be smaller and less noticeable than PINGP 1

.12 and 2 containments. Mechanical draft cooling towers would generate condensate plumes and

13 operational noise, though smaller cooling requirements will mean smaller (or fewer) towers,

14 which should generate less noise and smaller plumes than the existing facility. Noise during

15 power plant operations would be limited to industrial processes and communications. Pipelines

16 delivering natural gas fuel could be audible off site near compressors.

17 In addition to new power plant structures, the alternate plant site may require the construction of

18 transmission lines and natural gas pipelines. Although the pipelines would be buried, the

19 transmission lines would have a lasting visual effect on the landscape.

20 In general, aesthetic changes would be limited to the immediate vicinity of PINGP 1 and 2 or an

21 alternate site. The gas-fired alternative would have a SMALL impact on aesthetics if the location

22 was at the existing PINGP 1 and 2 site, and a possible SMALL to MODERATE impact, of the

23 location was at a different site location. If a new site is selected for the gas-fired alternative,

24 impacts to aesthetics could be reduced by choosing a site where a plant is already located and

25 where transmission lines are already in place.

26 Historic and Archaeoloqical Resources

27 Historic property, as defined in 36 CFR Part 800, means any prehistoric or historic district, site,

28 building, structure, or object included in, or eligible for inclusion in, the National Register of

29 Historic Places (NRHP) maintained by the Secretary of the Interior. This term includes artifacts,

30 records, and remains that are related to and located within such properties. Historic and

31 archaeological resources are the indications of human occupation and use of the landscape as

32 defined and protected by a series of Federal laws, regulations, and guidelines. Prehistoric

33 resources are physical remains of human activities that predate written records; they generally

34 consist of artifacts that may alone or collectively yield information about the past. Historic

35 resources consist of physical remains that postdate the emergence of written records; in the

36 U.S., they are architectural structures or districts, archaeological objects, and archaeological

37 features dating from 1492 and later. Ordinarily, sites less than 50 years old are not considered

38 eligible for listing on the NRHP, but exceptions can be made for such properties if they are of

39 particular importance, such as structures associated with the development of nuclear power

40 (e.g., Shippingport Atomic Power Station) or Cold War themes. American Indian resources are

41 sites, areas, and materials important to American Indians for religious or heritage reasons. Such

42 resources may include geographic features, plants, animals, cemeteries, battlefields, trails, and

43 other environmental features. The power plant site and adjacent areas that could potentially be

44 disturbed by the construction and operation of alternative power plants constitutes the area of

45 potential effect (APE).

46 Chapter 2 of this draft SEIS discusses the affected environment in terms of cultural and

47 archeological resources in the vicinity of the PINGP 1 and 2 site. As noted in Chapter 4, impacts

October 2009 8-11 Draft NUREG-1437, Supplement 39
Alternatives

1 to historic and archeological resources are a MODERATE impact; therefore, impacts from a

2 gas-fired plant located on the PINGP 1 and 2 site could be MODERATE. However, these

3 impacts could be mitigated if the utility commitments discussed in Chapter 4 of this draft SEIS

4 were implemented for the gas-fired plant as well. Impacts to historic and archeological

5 resources from a gas-fired plant located at an alternative site would vary depending on the

6 location of the site. Given the relatively small amount of land required for this alternative, and

7 the commitments discussed in Chapter 4, impacts to historic and archeological resources would

8 be SMALL to MODERATE.

9 The following information is provided by the Prairie Island Indian Community.

10 Depending on the location and timing of this alternative, there could be

11 MODERATE impacts to archaeological sites within the boundaries of the PINGP.

12 For instance, if this alternative was implemented before the PINGP was

13 decommissioned, there may be impacts to archaeological sites, as the facility

14 would require approximately 40 acres of land that has not been previously

15 developed. It is presumed that the existing PINGP infrastructure (parking lots,

16 buildings, etc.) would be needed until the PINGP was fully decommissioned.

17 Therefore, this alternative would need land that had not been previously

18 disturbed and likely to contain archaeological resources.

19 This alternative would have less or no impact on archaeological sites if it were to be

20 developed after PINGP decommissioning, as the entire former site could be utilized.

21 The NRC would have to ensure that archaeological sites are not impacted during

22 decommissioning. As well, the developer of the gas-fired alternative would have to

23 ensure that all archaeological sites were protected during construction.

24 Environmental Justice

25 Section 4.9.7 of this draft SEIS addresses the purpose and content of an environmental justice

26 impact analysis. In this section, the NRC staff evaluates the potential for disproportionately high

27 and adverse human health and environmental effects on minority and low-income populations

28 that could result from the construction and operation of a new natural gas-fired power plant.

29 Minority and low-income populations could be affected by the construction and operation of a

30 new natural gas-fired power plant. Some of these effects have been identified in other resource

31 areas discussed in this section. The extent of disproportionate effect is difficult to determine

32 since it would depend on the location of the natural gas-fired power plant. If the natural gas-fired

33 plant were located on the PINGP 1 and 2 site, the PIIC would be disproportionately affected. In

34 addition, increased demand for rental housing during construction could disproportionately

35 affect low-income populations. However, demand for rental housing could be mitigated if the

36 alternate plant site is constructed near a metropolitan area.

37 Impacts on minority and low-income populations from the construction and operation of a

38 natural gas-fired power plant alternative could range from SMALL to MODERATE. Because an

39 on-site gas-fired plant located on the current PINGP 1 and 2 site would only require a small

40 number of workers, effects are unlikely to be adverse, and any that are disproportionate are

41 likely to be SMALL. An off-site gas-fired plant could have SMALL to MODERATE environmental

42 justice impacts; however these effects could be reduced if the plant was located near a

43 metropolitan area or on a previously disturbed site.

44 The following information is provided by the Prairie Island Indian Community.

45 As stated above, if the 1000 MWe gas-fired plant were to be located within the

46 boundaries of the PINGP, the Prairie Island Indian Community would be

Draft NUREG-1437, Supplement 39 8-12 October 2009
Alternatives

1 disproportionately impacted. The Tribe believes that the MODERATE air quality

2 impacts would also have a MODERATE impact on the health of tribal members,

3 particularly the children and elders, who would be reside next to the gas-fired

4 plant. The winds do not always blow from the west to the east (i.e., away from

5 the community). Our research has shown that the often prevailing winds are out

6 of the S, SE, SW, or E. In addition, because of our location within the floodplain

7 of the Mississippi River valley, there are days when we experience air inversions.

8 The result of these air inversions is that particulate matter is trapped closer to the

9 ground and not dispersed in the atmosphere, thereby potentially impacting

10 human health.

11 There would be a significant increase in the number of vehicles driving through

12 the community, as part of constructing the 1000 MWe gas-fired plant and,

13 possibly, decommissioning the PINGP. This also has air quality implications,

14 safety concerns related to increases in traffic burdens for tribal members,

15 employees and guests at the Treasure Island Resort and Casino, and noise

16 impacts

17 In addition, if the PINGP were to be decommissioned, the Independent Spent

18 Fuel Storage Installation (ISFSI) would still be operational. Depending on when

19 the PINGP shutdown, there could be between 68 and 98 dry casks stranded

20 indefinitely on Prairie Island. The 2003 Settlement agreement between the tribe

21 and NSPM, related to the dry cask storage, would still be in effect.

22 8.1.7 Waste Management

23 Spent selective catalytic reduction catalysts, which are used to control NOx emissions from the

24 natural gas-fired plants, would make up the majority of the waste generated by this alternative.

25 Land clearing and other construction activities, associated with the construction of the gas-fired

26 plant would generate waste that can be recycled, disposed of onsite, or shipped to an offsite

27 waste disposal facility. If the alternative were constructed at the PINGP 1 and 2 site or any

28 previously disturbed site, the amounts of waste produced by land-clearing during construction

29 would be reduced.

30 In the GElS, NRC staff concluded that a natural gas-fired alternative located either onsite or

31 offsite of an existing nuclear facility would generate minimal waste and that the waste impacts

32 would be SMALL..

33 8.2 Combination Alternative 1

34 In this section, we evaluate the environmental impacts of an alternative that makes use of

35 several different means of power generation as well as power conservation. This alternative

36 includes a 400-MWe gas-fired unit on the existing PINGP 1 and 2 site, 300 MWe of wind power

37 capacity offsite, 100 MWe of wood-fired generation offsite, and 250 MWe of electricity offset by

38 conservation measures.

39 The gas-fired portion of this alternative would be similar in function to the gas-fired alternative in

40 Section 8.1. It would also use combined-cycle technology, but would be slightly more efficient

41 than the units used in Section 8.1. An existing 400-MWe combined-cycle unit currently available

42 from GE (GE 2007) operates at 5690 Btu/kWh, or 60 percent thermal efficiency.

43 Wind power portions of this alternative would likely be located offsite, as insufficient land is

44 available on the PING 1 and 2 site to support a wind-powered alternative. While wind power

October 2009 8-13 Draft NUREG-1437, Supplement 39
Alternatives

1 installations require substantial amounts of land to achieve adequate turbine spacing, only a

2 small amount of land is actually disturbed during construction and occupied by turbines and

3 infrastructure during operation. In many areas, surrounding land can be used for agriculture.

4 Wood-fired portions of this alternative would also likely be located offsite, and would likely

5 consist of a number of small (approximately 50-MWe) installations. Wood-fired generation tends

6 to be most economical when located near wood resources, especially mills or areas that

7 generate forest wastes during logging operations. Generation fired by wood wastes tends to be

8 more environmentally benign than installations fired by wood harvested specifically for power

9 generation. For purposes of this analysis, the NRC staff has assumed that wood waste would

10 power the wood-fired portion of this alternative. Construction impacts from a wood waste facility

11 would likely be similar to an equivalently-sized coal-fired facility.

12 Energy conservation (or energy efficiency), while not a generation alternative per se, is a

13 component of established energy policy in Minnesota. The Next Generation Energy Act of 2007

14 established a goal of a 1.5 percent annual reduction in retail electric sales for utilities and

15 associations in Minnesota. As noted in Section 8.4.3, this reduction in energy consumption

16 would not be sufficient to offset the full capacity of PINGP 1 and 2 by the time its licenses

17 expire, but it is sufficient to contribute to a combination alternative. The GElS notes that

18 environmental impacts of conservation tend not be well-established.

19 Table 8-2. Summary of Environmental Impacts of Combination Alternative 1 Compared to

20 Continued PINGP I and 2 Operation

Continued PINGP 1 and1

Combination Alternative 1 Con erationd 2 Operation

Air Quality MODERATE SMALL

Groundwater SMALL SMALL

Surface Water SMALL to MODERATE SMALL

Ecology MODERATE SMALL

Human Health MODERATE SMALL

Socioeconomics SMALL to LARGE SMALL TO MODERATE

Waste Management SMALL SMALL

21 8.2.1 Air Quality

22 As discussed in Section 8.1.2, a new gas-fired generating plant, proposed to be built in

23 Goodhue County, would require a New Source Review and a Title V permit under the CAA and

24 would need to submit an Air Emission Risk Analysis as required by the MPCA and a

25 Greenhouse Gas Emissions Evaluation as required by 40 CFR Part 70. As discussed in Section

26 8.1.2, it is unlikely that' Protection of Visibility provision (40 CFR Part 51, Subpart P)

27 requirements would apply as the nearest Federal Class I areas in Minnesota would not be

28 significantly affected due to the distance from the site.

29 The projected emissions from the one-unit natural gas-fired component of the alternative based

30 on published EIA data, EPA emission factors, performance characteristics for this alternative,

31 and implemented emission controls are as follows:

32 Sulfur dioxide (SO 2) - 30.01 tons (27.23 MT) per year;

33 Nitrogen oxides (NO,) - 96.21 tons (87.28 MT) per year;

34 Carbon monoxide (CO)- 20 tons (18.15 MT) per year;

Draft NUREG-1437, Supplement 39 8-14 October 2009
Alternatives

1 Total suspended particles/PM10- 16.77 tons (15.21 MT) per year;

2 Carbon dioxide (C02) - 1,032,495.72 tons (936,680.12 MT) per year.

3 The new natural gas-fired plant would have to comply with Title IV of the CAA reduction

4 requirements for SO2 and NOx. These compounds are precursors of acid rain and are major

5 contributors to reduced visibility. Title IV establishes maximum SO 2 and NO, emission rate from

6 the existing plants and a system of the SO2 emission allowances that can be used, sold' or

7 saved for future use by the new plants.

8 As stated above, the new natural gas-fired alternative would produce 30.01 tons (27.23 MT) per

9 year of SO 2 and 96.21 tons (87.28 MT) per year of NO, based on the use of the dry low NO,

10 combustion technology and the use of the selective catalytic reduction, which allow significant

11 reduction of NO, emissions.

12 The new plant would be subjected to the continuous monitoring requirements of SO2 , NO., and

13 CO specified in 40 CFR Part 75. The natural gas-fired plant as a part of this alternative would

14 emit 1,032,495.72 tons (936,680.12 MT) per year of unregulated C02 emissions. Minnesota

15 Statute §216H stipulates greenhouse gas emissions reporting requirements and statewide

16 adoption of climate change action plan, which requires a reduction in greenhouse gases.

17 This alternative would emit 16.77 tons (15.21 MT) per year of PM10 (40 CFR 50.6a). All

18 suspended particles emitted by the gas-fired portion of this alternative are PM10.

19 As discussed in section 8.1.2, the EPA Administrator found that "regulation of hazardous air

20 pollutant emissions from natural gas-fired electric utility steam generating units is not

21 appropriate or necessary."

22 The projected emissions from the wood-fired component of this combination alternative based

23 on published EIA data, EPA emission factor, performance characteristics for this alternative,

24 and implemented emission controls are as follows:

25 Sulfur dioxide (SO2 ) - 124.10 tons (112.58 MT) per year;

26 Nitrogen oxides (NOx) - 608.09 tons (551.66 MT) per year;

27 Carbon monoxide (CO) - 744.60 tons (675.50 MT) per year;

28 TSP (filtered) - 496.40 tons (450.33 MT) per year;

29 PM, 0 (filtered) - 367.34 tons (333.25 MT) per year;

30 PM2.

5 (filtered) - 322.66 tons (292.72 MT) per year;

31 Carbon dioxide (C02) - 967,980 tons (878,151.46 MT) per year.

32 The wood-fired combustion facility would be subjected to Federal and state air emissions

33 regulations described above for the natural gas-fired component of this alternative. This plant

34 would also produce 496.55 tons (450.33 MT) per year of PM, 0 (40 CFR §50.6a) and 322.66

35 tons (292.72 MT) per year of PM25, which have to meet the national primary and secondary

36 ambient air quality standards (40 CFR §50.7a).

37 There would be no emissions from the wind-powered component of this combination alternative.

38 The energy conservation component of this alternative reduces direct fuel use and causes

39 reduction in environmental emissions from workers' vehicle exhaust, plant fuel cycles, and

40 operation and maintenance of the plant. Improvements in efficiency may also reduce

41 consumption of fuels that are used for space and water heating purposes.

October 2009 8-15 Draft NUREG-1437, Supplement 39
Alternatives

1 Activities associated with the construction of the new natural gas-fired plant onsite or offsite of

2 PINGP 1 and 2 as well as construction of a wood-fired combustion facility and a wind farm

3 would cause some additional air effects as a result of equipment emissions and fugitive dust

4 from operation of the earth-moving and material handling equipment. Exhaust from workers'

5 vehicles and motorized construction equipment would be temporary. If construction crews

6 employ dust control practices, impacts from fugitive dust could be minimized. The NRC staff

7 concludes that the impact of vehicle exhaust emissions and fugitive dust from operation of the

8 earth-moving and material handling equipment would be SMALL.

9 The overall air quality impacts from the implementation of this combination alternative would be

10 MODERATE.

11 8.2.2 Groundwater Use and Quality

12 The use of groundwater for an onsite gas-fired unit would likely be limited to supply wells for

13 drinking water, landscaping, non-condenser cooling, and filtered service water. The existing

14 permitted onsite supply wells could continue to be used with a range of total average discharge

15 from 75 to 100 gpm. The impact on ground water use and quality would be SMALL. The offsite

16 wind farm and biomass combustion units would also use a limited amount of groundwater.

17 Water appropriation permits would be required, but the impact on groundwater use and quality

18 in the area would also be SMALL.

19 8.2.3 Surface Water Use and Quality

20 An onsite 400-MWe gas-fired unit would use less than half the amount of surface water from the

21 Mississippi River as the current plant. The consumptive use of surface water would be SMALL

22 compared to the average flow of the river in the vicinity of PINGP 1 and 2, and the impact would

23 be SMALL. The offsite biomass combustion units, totaling 100-MWe, would also have relatively

24 small consumptive use of surface water. The waste water discharge from the biomass plant,

25 including runoff, would have to be permitted by the MPCA, and the impact on receiving waters

26 could potentially be MODERATE depending on the location of the plant.

27 8.2.4 Aquatic and Terrestrial Ecology

28 Impacts to aquatic ecology from this combination alternative would be minimal, as the

29 consumptive water use of a natural gas-fired plant would be significantly less than the water

30 consumption of PINGP 1 and 2. Additionally, the onsite natural gas-fired plant could use parts of

31 the existing cooling system, which would reduce potential impacts to aquatic resources. Impacts

32 of the offsite wind and biomass facilities would depend on location and the ecology of the site,

33 but would likely be minimal. Construction in a previously disturbed area would have lower

34 impacts to the aquatic resources than construction in an undisturbed area. Energy conservation

35 would have no impacts on aquatic ecology. Overall, the impacts to aquatic resources from this

36 combination of alternatives would be SMALL.

37 As indicated in previous sections, the onsite one-unit natural gas-fired component of this

38 alternative will require 16 ac (7 ha) of land, according to calculations presented in the ER (NMC

39 2008). Impacts to terrestrial ecology from this portion of the alternative will be minor because

40 the selected site has been previously disturbed. Buildings and structures associated with PINGP

41 1 and 2 occupy approximately 60 ac (24 ha) of the site (NMC 2008); therefore, some areas of

42 previously disturbed land may return to natural habitat as a result of this alternative because

43 less land would be required than is currently in use for PINGP 1 and 2. Buffer areas and

44 surrounding wetland habitat on or in the vicinity of the site may remain undeveloped and would

45 continue to provide habitat for terrestrial species, though site lighting, noise, and activities may

Draft NUREG-1437, Supplement 39 8-16 October 2009
Alternatives

1 degrade the value of these neighboring habitats. Construction of additional transmission line

2 ROWs is unlikely because existing transmission capacity at the PINGP 1 and 2 site could be

3 used. Any lengthy pipelines or additional roads on undisturbed or less-disturbed areas could

4 adversely impact terrestrial ecology by fragmenting or destroying habitats. However, a pipelined

5 fuel source and a small workforce would help to minimize the need for additional transportation

6 infrastructure. Gas extraction and collection will also affect terrestrial ecology in offsite gas

7 fields, although much of this land is likely already disturbed by gas extraction, and the

8 incremental effects of this alternative on gas field terrestrial ecology are difficult to gauge.

9 The offsite two-unit biomass combustion component of this alternative will require 192 ac (78

10 ha) of land, according to calculations presented in the GElS for coal-fired units. The GElS

11 estimates that the overall level of construction impacts from biomass combustion unit impacts

12 are expected to be similar to coal-fired units of similar size. Because biomass combustion units

13 require large areas for buildings and structures associated with fuel and processing,

14 construction activities may fragment or destroy natural habitats. Construction of additional

15 transmission line ROWs, railways, or roads would further fragment natural habitat beyond the

16 192-ac (78-ha) site. Impacts from logging slash and forest thinning to provide fuel for this

17 alterative may alter terrestrial habitats by allowing edge effects to permeate a greater portion of

18 the disturbed land, which may change the abundance and distribution of interior species and

19 increase the area's susceptibility to invasive species. Deposition of air pollutants may affect

20 terrestrial ecology, but are expected to be minimal. Ash disposal is not likely to adversely affect

21 terrestrial ecology and may enrich soils if deposited at lower pH levels.

22 The offsite windpower installation component of this alternative will require approximately

23 64,000 ac (25,900 ha) of land, of which approximately 250 ac (100 ha) would be used for actual

24 towers and infrastructure. Construction disturbances associated with the windpower installation

25 may significantly impact terrestrial ecology, and some erosion and sedimentation may result.

26 However, because the windpower installations would be dispersed among a total area of

27 approximately 64,000 ac (25,900 ha), and the potential exists to spread the installations among

28 several locations, wildlife corridors resulting from construction and undisturbed buffer zones

29 would continue to provide habitat for terrestrial species. No air pollutant deposition would result

30 from this component of the alternative.

31 Impacts to terrestrial resources from this combination of alternatives at both the PINGP 1 and 2

32 site and offsite locations are expected to be MODERATE.

33 8.2.5 Human Health

34 EPA establishes NAAQS for six criteria pollutants (40 CFR Part 50) under the CAA. The CAA

35 recognizes two types of national air quality standards for particle pollution: primary standards

36 set limits to protect public health, including the health of "sensitive" populations such as

37 asthmatics, children, and the elderly; and secondary standards set limits to protect public

38 welfare, including protection against visibility impairment, damage to animals, crops, vegetation,

39 and buildings.

40 CO, NOx, and particulate matter are the major emissions during operation of the wood-fired

41 plant, as concluded in the GELS. In Table 8-2 of the GELS, the NRC staff identified that

42 occupational risks are high (same as agricultural) during the operation of the wood-fired

43 electricity generating plant. However, the current Federal and state air emission standards

44 adequately protect the occupational workers and the members of the public. Therefore, the

45 NRC staff has adopted applicable Federal and state air quality regulations as the thresholds for

46 determining the human health risks associated with the operation of a new natural gas-fired

47 power plant.

October 2009 8-17 Draft NUREG-1437, Supplement 39
Alternatives

1 Wood-fired plants would emit PM10 and PM2.

5. Fine particle pollution, PM2 .5 , is linked to a variety

2 of lung and cardiovascular diseases (EPA 2008). Industrial fabric filters or electrostatic

3 precipitators could be used to control and significantly minimize emissions.

4 NO, emissions contribute to formation of ground-level ozone and participate in chemical

5 reactions with other air particles to form nitrates, acid aerosols, and NO2, which are known to

6 have adverse impacts on human health. The new natural gas-fired plant would have latest

7 technology NO, emission control systems installed and implemented emission-trading or offset

8 requirements, and therefore, a new plant would not increase overall NO, in the region. The NRC

9 staff concludes that the impacts on human health of this combination alternative are likely to be

10 MODERATE.

11 8.2.6 Socioeconomics

12 Land Use

13 The GElS generically evaluates the impacts of nuclear power plant operations on land use both

14 onsite and offsite of a power plant site. The analysis of land use impacts for this combination

15 alternative focuses on the amount of land area that would be affected by the construction and

16 operation of a single natural gas-fired unit power plant at PINGP 1 and 2 and an offsite wind and

17 biomass energy generating power plant.

18 Land use impacts for the gas-fired component of this alternative would take place on the

19 existing PINGP 1 and 2 site and will likely require no additional land. Most land on the PINGP 1

20 and 2 site has been previously disturbed. Construction impacts could be further reduced by

21 reusing the cooling towers and other existing support facilities, like the switchyard. Therefore,

22 land use impacts for the construction of the gas-fired portion of this alternative would be SMALL.

23 In addition to onsite land requirements for the gas-fired plant, land would be required offsite for

24 natural gas wells and collection stations. The GElS estimates that 3600 ac (1500 ha) would be

25 required for wells, collection stations, and pipelines to bring the gas to a 1 000-MWe generating

26 facility. If this land requirement were scaled directly with generating capacity for this alternative,

27 up to 1500 ac (600 ha) of land could be required. Most of this land requirement would occur on

28 land where gas extraction already occurs. In addition, some natural gas could come from

29 outside of the U.S. and be delivered as liquefied gas. Effects from gas extraction are generally

30 small, as most land around a gas extraction site would remain undisturbed, except for roads and

31 collection pipe network. Therefore, impacts to land use from offsite gas wells and collection

32 stations would be SMALL.

33 The wind farm component of this combination alternative would produce 300 MWe of electricity

34 and require approximately 64,000 ac (26,000 ha) spread over several locations. Turbine towers

35 and infrastructure would only occupy roughly 5% of this area, while the remainder would be

36 available for complementary land uses, like agriculture. The wood-fired biomass component

37 would produce 100 MWe of electricity and require 190 ac (78 ha) for plant facilities, though

38 wood fuel may be collected over a much larger area. Because the wood-fired portion of this

39 alternative uses wood waste for fuel, the wood-fired plants should have little other effect on land

40 use.

41 Regarding the conservation portion of this alternative, quickly replacing and disposing of old

42 inefficient equipment could generate waste material and potentially increase the size of landfills.

43 Roughly 4 to 5 years remain, respectively, before PINGP 1 and 2 licenses expire, thus some

44 equipment may be replaced prior to the end of its expected life span in exchange for more

45 efficient equipment, depending on how authorities ultimately structure a conservation program.

46 Some programs may provide incentives for replacing less efficient equipment. In general,

Draft NUREG-1437, Supplement 39 8-18 October 2009
Alternatives

1 though, the cost of replacements and the average life of electrical equipment should allow for a

2 somewhat gradual replacement process that favors replacement of older or shorter-lived

3 equipment by more efficient equipment as it fails (especially in the case of frequently replaced

4 items, like light bulbs). In addition, many items (like home appliances or industrial items) have

5 substantial recycling value and would likely not be disposed of in landfills.

6 The elimination of uranium fuel for PINGP 1 and 2 could partially offset this alternative's offsite

7 land requirements. In the GELS, the NRC staff estimated that approximately 1000 ac (405 ha)

8 would not be needed for mining and processing uranium during the operating life of a 1000-

9 MWe nuclear power plant. For PINGP 1 and 2, roughly 1044 ac (423 ha) of uranium mining

10 area would no longer be needed.

11 Overall impacts to land use from this combination alternative would be SMALL to LARGE,

12 depending on the locations selected for wind farms and the location for offsite gas wells and

13 collection stations. Some of these impacts could be reduced by locating the wind farms on

14 previously disturbed areas, or locations that have existing land uses-like agriculture-that can

15 coexist with wind farms. Land use impacts can also be minimized by using existing transmission

16 lines.

17 Socioeconomics

18 As previously discussed, socioeconomic impacts are defined in terms of changes to the

19 demographic and economic characteristics and social conditions of a region. For example, the

20 number of jobs created by the construction and operation of a new single natural gas-fired

21 power plant, wind farm, and wood-fired biomass generating plant could affect regional

22 employment, income, and expenditures. Job creation is characterized in two ways: (1)

23 construction-related jobs, which are transient, short in duration, and less likely to have a long24 term socioeconomic impact; and (2) operation-related jobs in support of power plant operations,

25 which have the greater potential for permanent, long-term socioeconomic impacts. Workforce

26 requirements of power plant construction and operations for this combination alternative were

27 determined in order to measure their possible effect on current socioeconomic conditions.

28 NSP projected a peak construction workforce of 237 workers for the gas-fired plant (NMC

29 2008). The GElS projects a workforce of 1200 to 2500 for a 1000-MWe plant (when

30 extrapolated, a workforce of approximately 500 for a 400-MWe plant). NRC staff will use the

31 NSP estimate of 237 workers for reasons discussed in 8.1.

32 This alternative would lead to the shutdown of the PINGP 1 and 2. This shutdown would have

33 an impact on socioeconomic conditions in the region. Plant shutdown would eliminate

34 approximately 700 jobs and would reduce tax revenue in the region. The loss of these

35 contributions, which may not occur until after decommissioning, could have a SMALL to

36 MODERATE local impact. Appendix J to NUREG-0586, Supplement 1 (NRC 2002) discusses

37 the potential socioeconomic impacts of plant decommissioning.

38 Additional estimated construction workforce requirements for this combination alternative would

39 include 300 workers for the wind farm and 133 to 278 workers for the wood-fired biomass

40 energy plant. The number of additional workers would cause a short-term increase in the

41 demand for services and temporary (rental) housing in the region around the construction sites.

42 After construction of the wind farm and wood-fired plant, and depending on the size of the

43 affected communities, some local communities may be temporarily affected by the loss of the

44 construction jobs and associated loss in demand for business services. The local rental housing

45 markets could also experience increased vacancies and decreased prices. The impact of

46 construction from the wind farm and the wood-fired plant on socioeconomic conditions would be

47 SMALL, given the relatively low levels of employment associated with the wind power and wood

October 2009 8-19 Draft NUREG-1437, Supplement 39
Alternatives

1 waste components of this alternative. Further, employment effects from the wind power portion

2 of this alternative are likely to be spread over a larger area, as the wind farms may be

3 constructed in more than one location.

4 Following construction, a single unit gas-fired combination alternative could provide up to 13

5 jobs, based on NSP estimates, or up to 63 jobs based on an extrapolated estimate from the

6 GELS. Additional estimated operations workforce requirements for this combination alternative

7 would include 50 workers for the wind farm and 28 workers for the wood-fired biomass energy

8 plant. Given the small numbers of operations workers at these facilities, socioeconomic impacts

9 associated with the operation of the natural gas-fired power plant at PINGP 1 and 2, as well as

10 the wind farm and wood-fired biomass energy plant, would be SMALL.

11 Socioeconomic effects of an energy efficiency program would be SMALL. As noted in the GELS,

12 the program would likely employ additional workers. Lower-income families could benefit from

13 weatherization and insulation programs. This effect would be greater than the effect for the

14 general population because low-income households experience home energy burdens more

15 than four times larger than the average household (OMB 2007).

16 Overall, operational impacts to socioeconomics for this combination alternative would be

17 SMALL, due to the small numbers of additional workers required to run the gas-fired, wind farm,

18 and wood-fired portions of the alternative.

19 Transportation

20 Construction and operation of a natural gas-fired power plant, wind farm, and wood-fired

21 biomass generating plant would increase the number of vehicles on roads in the vicinity of these

22 facilities. During construction, cars and trucks would deliver workers, materials, and equipment

23 to the worksites. The increase in vehicular traffic would peak during shift changes resulting in

24 temporary levels of service impacts and delays at intersections. Transporting components of

25 wind turbines could have a noticeable impact, but are likely to be spread over a large area.

26 Pipeline construction and modification to existing natural gas pipeline systems could also have

27 an impact. Any transportation effects from the energy conservation portion of this alternative

28 would be widely distributed across the state, and would be SMALL to MODERATE.

29 During plant operations, transportation impacts would almost disappear, excepting

30 transportation of wood waste to the wood-fired power plants. Given the small numbers of

31 operations workers at these facilities, overall operational impacts on transportation associated

32 with this combination alternative would be SMALL.

33 Aesthetics

34 As previously discussed, aesthetic resources are the natural and manmade features that give a

35 particular landscape its character and aesthetic quality. The aesthetics impact analysis focuses

36 on the degree of contrast between the components of this alternative and the surrounding

37 landscape, as well as the aesthetic value of the surrounding landscape (e.g., areas near parks

38 or recreation areas may be more sensitive).

39 A single natural gas-fired unit located at PINGP 1 and 2 could be approximately 100 ft (30 m)

40 tall, with an exhaust stack of at least 175 ft (53 m) tall. The impact would be moderated as

41 higher elevations and vegetation along the Mississippi River valley could make it difficult to see

42 or hear the power plant outside of the river valley. Power plant infrastructure would generally be

43 smaller and less noticeable than PINGP 1 and 2 containment structures. The mechanical draft

44 cooling tower or towers - much smaller than the existing onsite towers - would generate

45 condensate plumes and operational noise. Noise during power plant operations would be limited

46 to industrial processes and communications. In addition to the power plant structures,

Draft NUREG-1437, Supplement 39 8-20 October 2009
Alternatives

1 construction of natural gas pipelines would have a short-term impact. Noise from the pipelines

2 could be audible offsite near compressors.

3 The wind farm would have a greater aesthetic effect than the other elements of this combination

4 alternative. Compared to a single power plant unit on 46 to 190 ac (19 to 77 ha), 500 turbines

5 300 ft (100 m) in height spread over,64,000 ac (26,000 ha) acres could have significant impacts

6 and, in the absence of larger topographic features, would be the major focus of viewer attention

7 as the most readily-visible structures around. Insome areas where aesthetics are an important

8 value, this may be objectionable.

9 Impacts from the energy conservation efficiency programs portion of this alternative would be

10 SMALL. Because one of the PINGP 1 and 2 units would continue to operate, NSP would

11 continue to use the existing onsite transmission lines, which would also support the onsite gas12 fired plant. Traffic to the existing PINGP 1 and 2 would decrease as would noise and emissions.

13 Some noise impacts could occur in instances of energy efficiency upgrades to major building

14 systems, though this impact would be intermittent and short-lived, and would be scattered

15 across many sites.

16 Most of the aesthetic impacts of this alternative would be a result of the wind farm. Overall the

17 aesthetic impacts associated with this combination alternative would be categorized as

18 MODERATE to LARGE if the wind farm is built at a site where aesthetics are an important

19 element of the natural environment, and SMALL to MODERATE at other locations.

20 Historic and Archaeological Resources

21 Historic property as defined in 36 CFR Part 800 is described above in Section 8.1.7.

22 Chapter 2 of this draft SEIS discusses the affected environment in terms of cultural and

23 archeological resources in the vicinity of the PINGP 1 and 2 site. Impacts to historic and

24 archeological resources from a single unit gas-fired plant located on the PINGP 1 and 2 site

25 could be MODERATE; however, these impacts could be mitigated if the utility commitments

26 discussed in Chapter 4 of this draft SEIS are implemented for the gas-fired plant as well.

27 Regarding the wind farm portion of this alternative, impacts to cultural and archeological

28 resources could be significant; however, selecting a site where survey results indicate low

29 sensitivity or where land has already been disturbed would minimize the overall impacts.

30 Impacts to cultural and archeological resources from the conservation portion of this alternative

31 would be minimal.

32 Overall, the impacts to historic and archeological resources could range from SMALL to

33 MODERATE due mostly to uncertainty regarding the location of the wind farm, the effect on

34 archeological resources at that site and whether the provisions discussed in 8.1.7 are used to

35 determine the location of the offsite wind farm.

36 The following information is provided by the Prairie Island Indian Community.

37 Depending on the location and timing of this alternative, there could possibly be

38 impacts to archaeological sites within the boundaries of the PINGP. For

39 instance, if this alternative was implemented before the PINGP was

40 decommissioned, there may be impacts to archaeological sites, as the facility

41 would require approximately 16 acres of land that has not been previously

42 developed. It is presumed that the existing PINGP infrastructure (parking lots,

43 buildings, etc.) would be needed until the PINGP was fully decommissioned.

44 Therefore, this alternative would need land that had not been previously

45 disturbed and likely to contain archaeological resources.

October 2009 8-21 Draft NUREG-1437, Supplement 39
Alternatives

1 This alternative would have less or no impact on archaeological sites if it were to

2 be developed after PINGP decommissioning, as the entire former site could be

3 utilized. The NRC would have to ensure that archaeological sites are not

4 impacted during decommissioning. As well, the developer of the gas-fired

5 alternative would have to ensure that all archaeological sites were protected

6 during construction.

7 Environmental Justice

8 Section 4.9.7 of this draft SEIS addresses the purpose and content of an environmental justice

9 impact analysis. In this section, the NRC staff evaluates the potential for disproportionately high

10 and adverse human health and environmental effects on minority and low-income populations

11 that could result from the construction and operation of a combination alternative.

12 Minority and low-income populations could be affected by the construction and operation of a

13 new natural gas-fired power plant, wind farm, and wood-fired biomass generating plant. Some

14 of these effects have been identified in resource areas discussed earlier in this section. The

15 extent of disproportionate effects is difficult to determine since it would depend on the location of

16 the wind farm and wood-fired portions of this alternative. The PIIC, because it is located next to

17 the PINGP 1 and 2 site, would be disproportionately affected from the gas-fired portion of this

18 alternative because the location will be on the PINGP 1 and 2 site. Increased demand for rental

19 housing during construction could disproportionately affect low-income populations. However,

20 demand for rental housing could be mitigated if the gas-fired plant, wind farm, and wood-fired

21 plants are constructed near a metropolitan area.

22 Weatherization programs could target low-income residents as a cost-effective energy efficiency

23 option since low-income populations tend to spend a larger proportion of their incomes paying

24 utility bills and also tend to live in structures that are less well insulated or have less-efficient

25 appliances. According to the Office of Management and Budget, low income populations

26 experience energy burdens more than four times as large as those of average households

27 (OMB 2007). Impacts to minority and low-income populations from energy conservation

28 efficiency programs portion of this alternative would be SMALL, though actual levels would

29 depend on program design and enrollment.

30 Overall disproportionate and adverse impacts on minority and low-income populations from this

31 combination alternative could range from SMALL to MODERATE depending on location of the

32 off-site wind farm and wood-fired plants. Disproportionate effects such as increased demand for

33 rental housing, are likely to be SMALL. The offsite wind farm and wood-fired plant could have

34 MODERATE environmental justice impacts depending on location of the wind farm and wood35 fired plants.

36 The following information is provided by the Prairie Island Indian Community.

37 If the 400 MWe gas-fired plant were implemented within the boundaries of the

38 PINGP, the Prairie Island Indian Community would be disproportionately

39 affected. The Tribe believes that implementing the 400 MWe gas-fired plant will

40 have a SMALL to MODERATE impact on air quality. In addition, these SMALL to

41 MODERATE air quality impacts would also have a SMALL to MODERATE

42 impact on the health of tribal members, particularly the children and elders, who

43 would reside next to the 400 MWe gas-fired plant. As discussed in Section 8.1.7,

44 the winds do not always blow from the west to the east (i.e., away from the

45 community); often the prevailing winds ,are out of the S, SE, SW, or E. In

46 addition, because of our location within the floodplain of the Mississippi River

47 valley, there are days when we experience air inversions. The result of these air

Draft NUREG-1437, Supplement 39 8-22 October 2009
Alternatives

1 inversions is that particulate matter is trapped closer to the ground, and therefore

2 not dispersed in the atmosphere.

3 There would be also be an increase in the number of vehicles driving through the

4 community, as part of constructing the 400 MWe gas-fired plant and, possibly,

5 decommissioning the PINGP. This also has air quality implications, additional

6 traffic burdens for tribal members, employees and guests at the Treasure Island

7 Resort and Casino, and noise impacts

8 Like Alternative 1 (the gas-fired plant), if this alternative were implemented, the

9 PINGP would be decommissioned and the Independent Spent Fuel Storage

10 Installation (ISFSI) would still be operational. Depending on when the PINGP

11 shut-down, there could be between 68 and 98 dry casks, stranded indefinitely on

12 Prairie Island. The 2003 Settlement agreement between the tribe and NSPM,

13 related to the dry cask storage, would still be in effect.

14 8.2.7 Waste Management

15 Spent selective catalytic reduction catalysts, which are used to control NO, emissions from the

16 natural gas-fired plants, would be the primary waste component from the natural gas-fired

17 alternative.

18 Land clearing and other construction activities, associated with the construction of the gas-fired

19 plant, would generate waste that can be recycled, disposed onsite, or shipped to an offsite

20 waste disposal facility. If the alternative were constructed at the PINGP 1 and 2 site or any

21 previously disturbed site, the amounts of wastes produced during land clearing would be

22 reduced.

23 An increase in wastes would be experienced during installation or implementation of

24 conservation measures such as appropriate disposal of old appliances, installation of control

25 devices, and building modifications. Implementation of recycling programs would help to

26 minimize the amount of generated waste.

27 As stated in the GELS, the wood-fired component of this alternative would produce considerable

28 amount of fly ash, which could be recycled for use as a beneficial fertilizer and soil conditioner.

29 The NRC staff concludes that overall waste impacts from this combination alternative are

30 SMALL.

31 8.3 Combination Alternative 2

32 In this section, the NRC staff evaluates the environmental impacts that may occur from a

33 combination of alternatives that includes continued operation of one PINGP 1 and 2 unit (either

34 Unit 1 or Unit 2), 300 MWe of wind capacity, and 250 MWe of capacity offset by conservation.

35 Impacts from wind and conservation portions of this alternative are the same as those

36 addressed in Section 8.2 for Combination Alternative 1. Impacts from continued operation of

37 one PINGP 1 and 2 unit will be similar to - though for some resource areas it may be less than

38 - continued operation of PINGP 1 and 2.

39

October 2009 8-23 Draft NUREG-1437, Supplement 39
Alternatives

1

2 Table 8-3. Summary of Environmental Impacts of Combination Alternative 2 Compared to

3 Continued PINGP l and 2 Operation

Continued PINGP 1 and 2

Combination Alternative 2 o ped ati o n

Operation

Air Quality SMALL SMALL

Groundwater SMALL SMALL

Surface Water SMALL SMALL

Ecology SMALL SMALL

Human Health SMALL SMALL

Socioeconomics SMALL to LARGE SMALL TO MODERATE

Waste Management SMALL SMALL

4 8.3.1 Air Quality

5 The nuclear component of this combination alternative would have very limited effects on air

6 quality and would produce less pollution than the natural gas-fired alternative or Combination

7 Alternative 1. The major source of air pollution during continued operation of one PINGP 1 and

8 2 unit would be testing and usage of the diesel generators, which run a permitted amount of

9 time, ranging from several hours to several days per year.

10 The energy conservation component of the alternative reduces direct fuel use and causes

11 reduction in environmental emissions from workers' vehicle exhaust, plant fuel cycles, and

12 operation and maintenance of the plant. Improvements in efficiency may also reduce

13 consumption fuels that are used for space and water heating purposes.

14 Exhaust emissions resulting from workers' vehicles and motorized construction equipment in

15 conjunction with construction of wind capacity would be temporary. Implementation of dust

16 control practices would minimize air quality impacts. Once constructed, no emissions would

17 result from operation of the wind power units.

18 The NRC staff concludes that this combination alternative would have a SMALL overall impact

19 on air quality.

20 8.3.2 Groundwater Use and Quality

21 Impacts on groundwater use and quality of the continued operation of one PINGP 1 and 2 unit

22 onsite would remain SMALL. The total use of groundwater from the onsite wells would be less

23 than the current annual use of approximately 115 gpm. The effects on groundwater quality

24 would also be SMALL because waste management and discharge procedures would be

25 maintained as at present.

26 8.3.3 Surface Water Use and Quality

27 Operation of one PINGP 1 and 2 unit instead of two will reduce the consumptive use of surface

28 water by approximately half. The impact of this reduced use of surface water would remain

29 SMALL because the consumptive use would be negligible compared to flow in the Mississippi

30 River near the PINGP 1 and 2 site, as it is with both units operating.

Draft NUREG-1437, Supplement 39 8-24 October 2009
Alternatives

1 8.3.4 Aquatic and Terrestrial Ecology

2 Impacts to aquatic ecology will be minimal, as the consumptive water use of a single PINGP 1

3 and 2 unit would be less than the consumptive water use of a two-unit nuclear plant. Impacts of

4 an offsite wind facilities on aquatic resources would depend on location and the ecology of the

5 site, but would likely be minimal. Construction in a previously disturbed area would have less

6 impacts to the aquatic resources than construction in an undisturbed area. Energy conservation

7 would also result in less water withdrawal and discharge corresponding to a decreased demand

8 for power generation. Overall, the impacts to aquatic resources from this combination of

9 alternatives would be SMALL.

10 The continued operation of one PINGP 1 and 2 unit would result in no additional impacts to

11 terrestrial resources than those discussed in Chapter 4 of this draft SEIS, as no additional land

12 disturbances onsite or offsite would occur. The Unit 2 steam generator replacement project may

13 not be necessary under this alternative; therefore, no temporary construction or ground14 disturbing activities would occur onsite. Maintenance of transmission line ROWs would

15 continue. No additional impacts to terrestrial resources are expected as a result of shutdown of

16 one of the two units.

17 The offsite windpower installation component of this alternative will require approximately

18 64,000 ac (25,900 ha) of land, of which approximately 250 ac (101 ha) would be used.

19 Construction disturbances associated with the windpower installation may significantly impact

20 terrestrial ecology, and some erosion and sedimentation may result due to the location of

21 windpower installations in mountainous, plains, or higher elevation areas where wind velocities

22 are highest. However, because the windpower installations would be dispersed among a total

23 area of approximately 64,000 ac (25,900 ha), and the potential exists to spread the installations

24 among several locations, wildlife corridors resulting from construction and undisturbed buffer

25 zones would continue to provide habitat for terrestrial species. No air pollutant deposition would

26 result from this component of the alternative.

27 Impacts to terrestrial resources from this combination of alternatives at both the PINGP 1 and 2

28 site and offsite locations are expected to be SMALL.

29 8.3.5 Human Health

30 EPA establishes NAAQS for six criteria pollutants (40 CFR Part 50) under the CAA. The CAA

31 recognizes two types of national air quality standards for particle pollution: primary standards

32 set limits to protect public health, including the health of "sensitive" populations such as

33 asthmatics, children, and the elderly; secondary standards set limits to protect public welfare,

34 including protection against visibility impairment, damage to animals, crops, vegetation, and

35 buildings.

36 The NRC established human health impacts for operating nuclear power reactors in 10 CFR

37 Part 51, Subpart A, Appendix B, Table B-i, which would apply to the continued operation of one

38 PINGP 1 and 2 unit.

39 No human health impacts would be caused by operation of wind power units. The increase in air

40 emissions during the construction stage would be temporary in nature and could be minimized

41 by use of appropriate air pollution reduction management practices.

42 An energy efficiency program is unlikely to have a significant effect on human health. Changes

43 to most building appliances would not affect health, though upgrades to HVAC systems,

44 insulation, and weatherization (including windows) may affect indoor air quality. The GElS noted

45 that this issue has not been sufficiently studied, but that mitigation measures would be available

October 2009 8-25 Draft NUREG-1437, Supplement 39
Alternatives

1 to correct problems. The GElS also noted that hazardous chemicals in the waste stream would

2 not affect human health. Accordingly, the NRC staff determined that these effects would be

3 SMALL.

4 The implementation of the conservation portion of this alternative would have a minimal impact

5 on the human health. Implementation of energy conservation measures such as sealing drafts

6 and windows to be more air tight could cause an increase in radon, which can cause lung

7 cancer. However, installation of more efficient ventilation systems, sealing cracks in basements,

8 and other mitigative measures can reduce the concentration of radon in homes. The NRC staff

9 concludes that the human health risks to members of the public from the conservation portion of

10 this alternative would be SMALL.

11 The overall human health impacts from the combination 2 alternative would be SMALL.

12 8.3.6 Socioeconomics

13 Land Use

14 The GElS generically evaluates the impacts of nuclear power plant operations on land use both

15 onsite and offsite of a power plant site. The analysis of land use impacts for this combination

16 alternative focuses on the amount of land area that would be affected by the construction and

17 operation of an offsite wind farm, which would be similar to the discussion on land use impacts

18 in section 8.2.7 of this draft SEIS.

19 The wind farm component of this combination alternative would produce 300 MWe of electricity

20 and require approximately 64,000 ac (26,000 ha) spread over several locations. Turbine tower

21 footings and infrastructure would only occupy roughly 5% of this area, while the remainder

22 would be available for complementary land uses, like agriculture. The elimination of uranium

23 fuel for one of the two PINGP 1 and 2 units could partially offset offsite land requirements. In the

24 GELS, the NRC staff estimated that approximately 1,000 ac (405 ha) would not be needed for

25 mining and processing uranium during the operating life of a 1000-MWe nuclear power plant.

26 For operating only one unit at PINGP 1 and 2, roughly 552 ac (223 ha) of uranium mining area

27 would no longer be needed. Overall land use impacts from this combination alternative would be

28 SMALL to MODERATE, depending on local land use and the availability of land near the

29 proposed sites.

30 Regarding the conservation portion of this alternative, quickly replacing and disposing of old

31 inefficient appliances could generate waste material and potentially increase the size of landfills.

32 Roughly 4 to 5 years remain, respectively, before PINGP 1 and 2 licenses expire, thus some

33 equipment may be replaced prior to the end of its expected life span in exchange for more

34 efficient equipment, depending on how authorities ultimately structure a conservation program.

35 Some programs may provide incentives for replacing less efficient equipment. In general,

36 though, the cost of replacements and the average life of electrical equipment should allow for a

37 somewhat gradual replacement process that favors replacement of older or shorter-lived

38 equipment by more efficient equipment as it fails (especially in the case of frequently replaced

39 items, like light bulbs). In addition, many items (like home appliances or industrial equipment)

40 have substantial recycling value and would likely not be disposed of in landfills.

41 Impacts from continued operation of one PINGP 1 and 2 unit would remain a SMALL impact on

42 land use as concluded in Chapter 4.9 of this draft SEIS. Overall impacts to land use from this

43 combination alternative would be SMALL to LARGE depending on the location of the wind farm

44 portion of this alternative. Some of these impacts could be reduced by locating the wind farms

45 on previously disturbed areas, or locations that have existing land uses-like agriculture-that

Draft NUREG-1437, Supplement 39 8-26 October 2009
Alternatives

1 can coexist with wind farms. Land use impacts can also be minimized by using existing

2 transmission lines.

3 Socioeconomics

4 As previously discussed, socioeconomic impacts are defined in terms of changes to the

5 demographic and economic characteristics and social conditions of a region. For example, the

6 number of jobs created by the construction and operation of a wind farm could affect regional

7 employment, income, and expenditures. Job creation is characterized in two ways: (1)

8 construction-related jobs, which are transient, short in duration, and less likely to have a long9 term socioeconomic impact; and (2) operation-related jobs in support of power plant operations,

10 which have the greater potential for permanent, long-term socioeconomic impacts. Workforce

11 requirements of power plant construction and operations for this combination alternative were

12 determined in order to measure their possible effect on current socioeconomic conditions.

13 Plant shutdown of one of the two PINGP 1 and 2 units would have an impact on socioeconomic

14 conditions in the region. Plant shutdown would eliminate approximately 342 jobs and would

15 reduce tax revenue in the region. The loss of these contributions, which may not entirely cease

16 until after decommissioning, could have a SMALL to MODERATE impact in reductions of tax

17 revenues. Appendix J to NUREG-0586, Supplement 1 (NRC 2002) discusses of the potential

18 socioeconomic impacts of plant decommissioning.

19 Estimated construction workforce requirements for this combination alternative would include

20 300 workers for the wind power unit. The number of additional workers would cause a short21 term increase in the demand for services and temporary (rental) housing in the region around

22 the construction sites.

23 After construction, and depending on the size of the community, some local communities may

24 be temporarily affected by the loss of the construction jobs and associated loss in demand for

25 business services. The rental housing market could also experience increased vacancies and

26 decreased prices. The impact of construction on socioeconomic conditions would be SMALL.

27 Estimated operations workforce requirements for this combination alternative would include 50

28 workers for the wind power unit. Given the small numbers of operations workers at these

29 facilities, socioeconomic impacts associated with the operation of the wind farm would be

30 SMALL.

31 Socioeconomic effects of the energy conservation efficiency program portion of this alternative

32 would be SMALL. As noted in the GELS, the program would likely employ additional workers.

33 Lower-income families could benefit from weatherization and insulation programs. This effect

34 would be greater than the effect for the general population because low-income households

35 experience home energy burdens more than four times larger than the average household

36 (OMB 2007).

37 Overall, impacts to socioeconomics for this combination alternative would be SMALL, due to the

38 relatively small numbers to additional workers required to run the one remaining nuclear reactor

39 and wind portions of the alternative.

40 Transportation

41 Traffic volumes on the roads in the vicinity of PINGP 1 and 2 would be reduced after one of the

42 two units terminated operations. Most of the reduction in traffic volume would be associated with

43 the loss of jobs at the plant. Deliveries to the plant would be reduced until decommissioning.

44 Transportation impacts associated with the shutdown of one reactor portion of this alternative

45 would be SMALL.

October 2009 8-27 Draft NUREG-1437, Supplement 39
Alternatives

1 Construction and operation of a wind farm would increase the number of vehicles on roads in

2 the vicinity of the facility. During construction, cars and trucks would deliver workers, materials,

3 and equipment to the worksite. The increase in vehicular traffic would peak during shift changes

4 resulting in temporary levels of service impacts and delays at intersections. Transporting

5 components of wind turbines could have a noticeable impact, but are likely to be spread over a

6 large area. Any transportation effects from the energy conservation portion of this alternative

7 would be widely distributed across the state, and would be SMALL to MODERATE.

8 During plant operations, transportation impacts would almost disappear. Given the small

9 numbers of operations workers at the wind farm, overall impacts on transportation associated

10 with this combination alternative would be SMALL.

11 Aesthetics

12 As previously discussed, aesthetic resources are the natural and manmade features that give a

13 particular landscape its character and aesthetic quality. The aesthetics impact analysis focuses

14 on the degree of contrast between the power generating plant and the surrounding landscape

15 and the visibility of the power plant.

16 Plant structures and other facilities would remain in place until decommissioning. Noise caused

17 by plant operation would be reduced. Aesthetic impacts of reactor shutdown of one of the two

18 units at PINGP 1 and 2 would be SMALL.

19 The wind farm would have a greater aesthetic effect than the other elements of this combination

20 alternative. Compared to a single power plant unit on 46 to 190 ac (19 to 77 ha), 500 turbines

21 300 ft (100 m) in height spread over 64,000 ac (26,000 ha) acres could have significant impacts

22 and, in the absence of larger topographic features, would be the major focus of viewer attention

23 as the most readily-visible structures around. In some areas where aesthetics are an important

24 value, this may be objectionable.

25 Impacts from the energy conservation efficiency programs portion of this alternative would be

26 SMALL. NSP would continue to use the existing transmission lines. Traffic to the plant would

27 decrease, however, as would noise and emissions. Some noise impacts could occur in

28 instances of energy efficiency upgrades to major building systems, though this impact would be

29 intermittent and short-lived.

30 Most of the aesthetic impacts of this alternative would be a result of the wind farm. Overall the

31 aesthetic impacts associated with this combination alternative would be categorized as

32 MODERATE to LARGE if the wind farm is built at a site where aesthetics are an important

33 element of the natural environment, and SMALL to MODERATE at other locations.

34 Historic and Archaeoloqical Resources

35 Historic property as defined in 36 CFR Part 800 is described above in Section 8.1.7.

36 Chapter 2 of this draft SEIS discusses the affected environment in terms of cultural and

37 archeological resources in the vicinity of the PINGP 1 and 2 site. Impacts to historic and

38 archeological resources from operation of one unit at the PINGP 1 and 2 site could be

39 MODERATE; however, these impacts could be mitigated if the utility commitments discussed in

40 Chapter 4 of this draft SEIS are implemented for continued operation of one unit. Regarding the

41 wind farm portion of this alternative, impacts to cultural and archeological resources could be

42 significant; however, selecting a site where survey results indicate low sensitivity or where land

43 has already been disturbed would minimize the overall impacts. Impacts to cultural and

44 archeological resources from the conservation portion of this alternative would be minimal.

45 Overall, the impacts to historic and archeological resources would be SMALL to MODERATE

46 due to the relatively small amount of land required for the use of one nuclear reactor portion of

Draft NUREG-1437, Supplement 39 8-28 October 2009
Alternatives

1 this alternative, and if the provisions discussed in 8.1.7 are used for the location of the offsite

2 wind farm.

3 Environmental Justice

4 Section 4.9.7 of this draft SEIS addresses the purpose and content of an environmental justice

5 impact analysis. In this section, the NRC staff evaluates the potential for disproportionately high

6 and adverse human health and environmental effects on minority and low-income populations

7 that could result from the construction and operation of this combination alternative.

8 Impacts associated with the reactor shutdown of one PINGP 1 and 2 unit portion of this

9 alternative would disproportionately affect the Prairie Island Indian Community (PIIC), due to the

10 proximity of the PIIC and the PINGP 1 and 2 site. Appendix J of NUREG-0586, Supplement 1

11 (NRC 2002) provides additional discussion of these impacts.

12 Minority and low-income populations could be affected by the construction and operation of

13 wind power units. Some of these effects have been identified in resource areas discussed in this

14 section. For example, increased demand for rental housing during construction could

15 disproportionately affect low-income populations.

16 Weatherization programs could target low-income residents as a cost-effective energy efficiency

17 option since low-income populations tend to spend a larger proportion of their incomes paying

18 utility bills. According to the Office of Management and Budget, low income populations

19 experience energy burdens more than four times as large as those of average households

20 (OMB 2007). Impacts to minority and low-income populations from energy conservation

21 efficiency programs portion of this alternative would be SMALL, depending on program design

22 and enrollment.

23 Overall impacts on minority and low-income populations from this combination alternative could

24 range from SMALL to MODERATE. Because reactor shutdown of one PINGP 1 and 2 unit

25 would only require a small number of workers after the initial shutdown and the reduced number

26 of employees required for two reactors at the PINGP 1 and 2 site, disproportionate effects such

27 as increased demand for rental housing, are likely to be SMALL. The offsite wind farm could

28 have MODERATE environmental justice impacts; however these effects could be reduced if the

29 plant was located near a metropolitan area or on a previously disturbed site.

30 The following information is provided by the Prairie Island Indian Community.

31 Implementing this alternative would disproportionately impact the PIIC, as one of

32 the two reactors would continue to operate for an additional twenty years.

33 No other community is as close to the PINGP as the Prairie Island Indian

34 Community. No other community is impacted, in as many ways, as the Prairie

35 Island Indian Community. Furthermore, these impacts will have a cumulative

36 environmental justice impact on our community.

37 No other minority community or federally recognized Indian tribe is impacted the

38 way the Prairie Island Indian Community is..

39 Even though only one PINGP unit would be operating, spent fuel will still

40 accumulate at the ISFSI. No other community (within a 50 mile radius) is so

41 close to a nuclear power plant and a nuclear waste storage facility.

42 No other community would be subjected to chronic radiological releases from

43 one unit of the PINGP and gamma radiation from the ISFSI. For many of our

44 members, their exposure to low levels of radiation is for their entire lifetime.

October 2009 8-29 Draft NUREG-1437, Supplement 39
Alternatives

1 One unit of the PINGP would continue to transmit electricity via the high-voltage

2 power lines located immediately next to several of our homes.

3 One unit of the PINGP would continue to release tritium, which leaches into

4 groundwater on the tribe's land.

5 Our youth are worrying about the effects of an accident on their community and

6 their futures. Even if one unit were operating, there is still the possibility of an

7 accident.

8 An accident at one unit could still devastate our community. The consequences

9 would be the same-our homeland would be gone, our culture would be

10 decimated, our means of providing services to tribal members would be gone,

11 and our tribal members' primary income would be gone. No other community

12 faces this undesirable prospect.

13 No other community (within the 50 mile radius) has the emergency planning

14 concerns the tribe does (i.e., only one access road). Operating with one unit

15 would not alleviate emergency preparedness concerns.

16 No other community participates in state or federal proceedings (using its own

17 resources) to the extent that the Prairie Island Indian Community does. Even with

18 one unit operating, the tribe would still need to participate in state and federal

19 proceedings.

20 We believe that all things are related and that you cannot affect one thing without

21 affecting another. Taken together, we believe that the operation of even one unit

22 of the PINGP will have an integrated and cumulative negative impact on our

23 community that will continue impact our community well after the twenty-year

24 extended operating period.

25 8.3.7 Waste Management

26 The waste impacts associated with the continued operation of one PINGP 1 and 2 unit are

27 outlined in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B. Wastes related to

28 refurbishment and routine maintenance projects would be disposed in a permitted manner,

29 either onsite or offsite at an authorized disposal facility.

30 The quantity of wastes generated during installation or implementation of conservation

31 measures, which would depend on a number of factors, including appropriate disposal of old

32 appliances, installation of control devises, and building modifications, would increase, but

33 implementation of recycling programs could help minimize the amount of generated waste.

34 There would be minimal waste associated with the routine maintenance of the wind generating

35 units.

36 The NRC staff concludes that waste impacts from this combination alternative would be SMALL.

37 8.4 Purchased Power

38 In the ER (NMC 2008), NSP indicated that purchased power would likely come from a variety of

39 sources, most of which have already been considered in this section, though it could also

40 include older, coal-fired power plants. Further, NSP. indicated that relying on purchased power

41 to replace PINGP 1 and 2 would likely result in construction of new facilities elsewhere in the

42 region, given existing regional supply and demand, and would also require the construction of

43 additional 500-kilovolt (kV) or 345-kV transmission lines. In other words, purchased power may

Draft NUREG-1437, Supplement 39 8-30 October 2009
Alternatives

1 incur similar construction-related impacts to the alternatives already considered, while requiring

2 additional impacts for new transmission projects. In the ER, NSP assumed that 100 mi (160

3 km) of new transmission line in a new corridor 150 ft (46 m) wide may be necessary. The NRC

4 staff notes that purchased power could serve as an alternative to license renewal, but the

5 impacts would likely be larger than those for the alternatives already considered in this draft

6 SEIS because substantial new transmission lines would likely be necessary. As a result, the

7 NRC staff has not separately evaluated purchased power as an alternative to license renewal.

8 8.5 Alternatives Considered but Dismissed

9 In this section, we discuss the energy alternatives that we initially considered, but that we

10 determined either would not individually meet the purpose and need identified in the GElS or

.11 whose costs preclude consideration in greater depth. As you'll note, we considered several of

12 these alternatives in the combination alternatives in Sections 8.2 and 8.3.

13 8.5.1 Wind Power

14 The American Wind Energy Association indicates that Minnesota currently ranks 4 th among the

15 states in installed wind power capacity with 1752 MWe wind-powered electricity (AWEA

16 Undated). Resource evaluations by Minnesota's Department of Commerce indicate that wind

17 project in most of western and southern Minnesota can operate at capacity factors from 36 to

18 nearly 45 percent (MNDOC 2006a). Roughly one-third of the state has wind resources in power

19 classes 4 through 7 (MNDOC 2006b). Generally, wind power classes 4 and above are

20 considered adequate for wind power production. Further, Xcel Energy indicated in its 2007

21 Minnesota Resource Plan (Xcel 2007xx) that it would need to add 2600 MW of wind capacity by

22 2020 to comply with Minnesota's Renewable Energy Standard (RES).

23 Despite Minnesota's excellent wind power potential and Xcel's potentially large capacity

24 additions, windpower is not yet suitable for stand-alone large baseload capacity. When paired

25 with energy storage or a readily dispatchable power source like hydropower, wind could serve

26 as a means of providing baseload power. While Xcel Energy indicates that is about to begin

27 testing of a large-scale battery backup for wind power (Xcel 2008), the potential for large-scale

28 implementation of battery backup is not yet clear. In addition, hydropower resources in

29 Minnesota (addressed in 8.4.5) are too small to provide backup for a wind power alternative.

30 Further, Xcel Energy staff indicated at the NRC site audit that it is not currently possible to

31 expand hydropower purchases from Manitoba Hydro.

32 Given wind power's intermittency and the lack of available backup, NRC staff will not consider

33 wind power as a stand-alone alternative to license renewal. However, given Minnesota's

34 significant wind resource and Xcel's large potential capacity additions, the NRC staff will

35 consider wind power as a portion of a combination alternative.

36 8.5.2 Wood Waste

37 In 1999, DOE researchers estimated that Minnesota has biomass fuel resources consisting of

38 urban, mill, agricultural, and forest residues, as well as speculative potential for energy crops.

39 Excluding potential energy crops, DOE researchers projected that Minnesota had 15,464,325

40 tons (14,028,999 MT) of plant-based biomass available at $50 per ton delivered (Walsh et al.

41 2000; costs are in 1995 dollars). The Bioenergy Feedstock Development Program at Oak Ridge

42 National Laboratory estimated that each air-dry pound of wood residue produces approximately

43 6400 Btu of heat (ORNL 2007). Assuming a 33 percent conversion efficiency, using all plant44 based biomass available in Minnesota at $50 per ton (the maximum price the researchers

October 2009 8-31 Draft NUREG-1437, Supplement 39
Alternatives

1 considered) would generate roughly 29 terawatt hours of electricity. This is roughly three and a

2 half times the electricity PINGP 1 and 2 generated in 2006. However, most of this potential

3 comes from agricultural residues. Excluding agricultural residues (many of which are

4 traditionally left on fields following harvest and provide fertilization for the following years crops),

5 the total potential is 6.6 terawatt-hours.

6 Walsh et al. (2000) go on to note that these estimates of biomass capacity contain substantial

7 uncertainty and that potential availability does not mean biomass will actually be available at the

8 prices indicated or that resources will be usably free of contamination. Some of these plant

9 wastes already have reuse value and would likely be more costly to deliver because of

10 competition. Others, such as forest residues, may prove unsafe and unsustainable to harvest on

11 a regular basis.

12 As a result of limited resource availability, NRC staff will not consider wood waste as a stand13 along alternative to license renewal. NRC staff will, however, consider wood waste a portion of a

14 combination alternative.

15 8.5.3 Energy Conservation

16 The Minnesota Next Generation Energy Act of 2007 set energy reduction goal of 1.5 percent of

17 annual retail sales per year for each utility in the state (Chapter 136-S.F.No. 145). By the time

18 the current license for PINGP 1 and 2, Unit 2, expires, the reduction goal would have all utilities

19 in the state reduce sales by approximately 10 percent. In 2006, total retail sales of electricity

20 were roughly 67 terawatt-hours of electricity (EIA 2007b), while PINGP 1 and 2 produced

21 approximately 8.1 terrawatt-hours of electricity in the same year (NMC 2008). PINGP 1 and 2's

22 generation accounted for roughly 12 percent of electricity sold in the state of Minnesota. The

23 conservation goals of Minnesota statute, then, appear unable to replace the power generated by

24 PINGP 1 and 2.

25 The NRC staff had difficulty identifying further studies on conservation of energy efficiency

26 potential in Minnesota. Given the size of the state's goal and apparent lack of other estimates of

27 conservation potential in the state, the NRC staff will not evaluate conservation as a stand-along

28 alternative. The NRC staff will, however, consider it as a portion of a combination alternative,

29 given its potential for low environmental impacts.

30 8.5.4 Solar Power

31 Solar technologies use the sun's energy to produce electricity. Minnesota receives between 4

32 and 5 kWh per square meter per day, or approximately 0.4 to 0.5 kWh of solar radiation per

33 square foot per day, for solar collectors oriented at an angle equal to the installation's latitude

34 (NREL 2009). At this level of incident solar radiation, photovoltaics are likely to be more

35 effective than solar thermal power plants. Because flat-plate photovoltaics tend to be roughly 25

36 percent efficient, a solar-powered alternative would require 4390 to 5480 ac (1780 to 2220 ha)

37 of collectors to provide an amount of electricity equivalent to that generated by PINGP 1 and 2.

38 Space between collectors and associated infrastructure increase this land requirement. This

39 amount of land, while large, is consistent with the land required for coal and natural gas fuel

40 cycles.

41 In the GELS, the NRC staff noted that, by its nature, solar power is intermittent (i.e., it does not

42 work at night and cannot serve baseload), and the efficiency of collectors varies greatly with

43 weather conditions. A solar-powered alternative will require energy storage or a backup power

44 supply to provide electric power at night. As noted in the wind energy section, 8.4.1, energy

Draft NUREG-1437, Supplement 39 8-32 October 2009
Alternatives

1 storage technologies are in early stages of development and not yet large enough to backup

2 enough capacity to replace PINGP 1 and 2.

3 Given the challenges in meeting baseload requirements, the NRC staff did not evaluate solar

4 power as an alternative to license renewal of PINGP 1 and 2.

5 8.5.5 Hydroelectric Power

6 According to researchers at Idaho National Energy and Environmental Laboratory, Minnesota

7 has an estimated 225.9 MWe of technically available, undeveloped hydroelectric resources at

8 40 project sites throughout the state (INEEL 1996). This amount occurs almost entirely in small

9 installations, with only one site capable of generating more than 15 MWe.

10 The NRC staff notes that the total available hydroelectric potential is much smaller than the

11 capacity of PINGP 1 and 2, and will not consider hydroelectric power as an alternative to license

12 renewal.

13 8.5.6 Geothermal Power

14 Geothermal energy has an average capacity factor of 90 percent and can be used for baseload

15 power where available. However, geothermal electric generation is limited by the geographical

16 availability of geothermal resources (NRC 1996). As illustrated by Figure 8.4 in the GELS, no

17 feasible location for geothermal capacity exists to serve as an alternative to PINGP 1 and 2. The

18 NRC staff concluded that geothermal energy is not a reasonable alternative to license renewal

19 of PINGP 1 and 2.

20 8.5.7 Biofuels

21 In addition to wood and municipal solid-waste fuels, there are other concepts for biomass-fired

22 electric generators, including direct burning of energy crops (crops grown specifically as fuel or

23 feedstock for fuel), conversion to liquid biofuels, and biomass gasification. In the GElS, the NRC

24 staff indicated that none of these technologies had progressed to the point of being competitive

25 on a large scale or of being reliable enough to replace a baseload plant such as PINGP 1 and 2.

26 After reevaluating current technologies, the NRC staff finds that other biomass-fired alternatives

27 are still unable to reliably serve as an alternative to the continued operation of PINGP 1 and 2

28 and does not consider biofuels to be a viable alternative to PINGP 1 and 2 license renewal.

29 8.5.8 New Nuclear Power

30 Sources in the nuclear industry have recently indicated that reactor projects currently under

31 development are likely eight or nine years from completion, or possibly online in the 2016-2017

32 timeframe (Nucleonics Week 2008). This is two to three years after the expiration of the license

33 for PINGP 1 and 2, Unit 2, and three to four years after the expiration of the license for PINGP 1

34 and 2, Unit 1. Further, potential plant owners or operators wishing to submit a new proposal

35 specifically to offset the capacity of PINGP 1 and 2 would require additional time to develop an

36 application. Given the relatively short time remaining on the current PINGP 1 and 2 operating

37 licenses compared to the time to license and construct a new nuclear power plant, the NRC

38 staff has not evaluated new nuclear generation as an alternative to license renewal.

39 8.5.9 Coal-fired Power

40 Minnesota's Next Generation Energy Act explicitly caps utility-sector emissions of carbon

41 dioxide and places a moratorium on constructing "new large energy facilities" as of August 1,

October 2009 8-33 Draft NUREG-1437, Supplement 39
Alternatives

1 2009 (Chapter 136-S.F.No. 145). While the definition of "new large energy facility" excludes

2 gas-fired and other turbine or combined-cycle plants, it includes coal-fired facilities. The law also

3 prevents Minnesota utilities from purchasing power from new coal-fired power plants located

4 outside of Minnesota. Given legal restrictions on the construction of new coal-fired power plants

5 in the state and the purchase of power from outside the state, the NRC staff will not consider

6 coal-fired power as an alternative to PINGP 1 and 2 license renewal.

7 8.5.10 Oil-fired Power

8 EIA's 2008 Annual Energy Outlook, in contrast to past years' projections, no longer indicates

9 that oil-fired power will account for any additions to capacity in the U.S. (EIA 2008a). The

10 variable costs of oil-fired generation tend to be greater than those of the nuclear or coal-fired

11 options, and oil-fired generation tends to have greater environmental impacts than natural gas12 fired generation. The high cost of oil (even prior to the record-high prices of 2008) has prompted

13 a steady decline in its use for electricity generation. Thus the NRC staff did not consider oil-fired

14 generation as an alternative to PINGP 1 and 2 license renewal.

15 8.5.11 Fuel Cells

16 Fuel cells oxidize fuels without combustion and related environmental side effects. Power is

17 produced electrochemically by passing a hydrogen-rich fuel over an anode and air (or oxygen)

18 over a cathode and separating the two by an electrolyte. The only byproducts (depending on

19 fuel characteristics) are heat, water, and CO 2. Hydrogen fuel can come from a variety of

20 hydrocarbon resources by subjecting them to steam under pressure. Natural gas is typically

21 used as the source of hydrogen.

22 At the present time, fuel cells are not economically or technologically competitive with other

23 alternatives for baseload electricity generation. EIA projects that fuel cells may cost $5,374 per

24 installed kW (total overnight costs), or 3.5 times the construction cost of new coal-fired capacity

25 and 7.5 times the cost of new, advanced gas-fired, combined-cycle capacity (EIA 2008b). In

26 addition, fuel cell units are likely to be small in size (the EIA reference plant is 10 MWe). While it

27 may be possible to use a distributed array of fuel cells to provide an alternative to PINGP 1 and

28 2, it would be extremely costly to do so. Accordingly, the NRC staff does not consider fuel cells

29 as an alternative to PINGP 1 and 2 license renewal.

30 8.5.12 Municipal Solid Waste

31 Municipal solid waste combustors incinerate waste to produce steam, hot water, or electricity.

32 Combustors use three types of technologies-mass burn, modular, and refuse-derived fuel.

33 Mass burning is currently the method used most frequently in the U.S. and involves little to no

34 sorting, shredding, or separation. Consequently, toxic or hazardous components present in the

35 waste stream are combusted, and toxic constituents are exhausted to the air or become part of

36 the resulting solid wastes. Currently, approximately 89 waste-to-energy plants operate in the

37 U.S. These plants generate approximately 2700 MWe, or an average of approximately 30 MWe

38 per plant (IWSA 2007). Approximately 35 average-sized plants will be necessary to provide the

39 same level of output as the other alternatives to PINGP 1 and 2 license renewal.

40 The GElS indicates that the overall level of construction impact from a waste-fired plant will be

41 similar to that for a coal-fired power plant. The GElS also indicates that waste-fired plants have

42 the same or greater operational impacts than coal-fired technologies (including impacts on the

43 aquatic environment, air, and waste disposal). The initial capital costs for municipal solid-waste

44 plants are greater than for comparable steam-turbine technology at coal-fired facilities or at

Draft NUREG-1437, Supplement 39 8-34 October 2009
Alternatives

1 wood-waste facilities because of the need for specialized waste separation and handling

2 equipment (NRC 1996).

3 Regulatory structures that once supported municipal solid waste incineration no longer exist.

4 For example, the Tax Reform Act of 1986 made capital-intensive projects such as municipal

5 waste combustion facilities more expensive relative to less capital-intensive waste disposal

6 alternatives such as landfills. Also, the 1994 Supreme Court decision C&A Carbone, Inc. v.

7 Town of Clarkstown, New York, struck down local flow control ordinances that required waste to

8 be delivered to specific municipal waste combustion facilities rather than landfills that may have

9 had lower fees. Additionally, environmental regulations have increased the capital cost

10 necessary to construct and maintain municipal waste combustion facilities.

11 Given the small average installed size of municipal solid waste plants and the unfavorable

12 regulatory environment, the NRC staff does not consider municipal solid waste combustion to

13 be a feasible alternative to PINGP 1 and 2 license renewal.

14 8.5.13 Delayed Retirement

15 In the PINGP 1 and 2 ER, NSP indicated that any plans to upgrade older baseload plants are

16 already included in its plans to meet future energy needs (NMC 2008). NSP did not indicate that

17 it had plans to retire any of its currently-operating plants. As a result, the NRC staff will not

18 consider delayed retirement as an alternative to PINGP 1 and 2 license renewal.

19 8.6 No-Action Alternative

20 This section will examine the environmental effects that occur if NRC takes no action. No action

21 in this case means that NRC does not issue renewed operating licenses for PINGP 1 and 2 and

22 the licenses simply expire at the end of the current license term, in 2013 and 2014, respectively.

23 If NRC takes no action, the plant will shutdown at or before the end of the current license. After

24 shutdown, plant operators will initiate decommissioning according to 10 CFR 50.82.

25 The NRC staff notes that no action is the only alternative considered in-depth that does not

26 satisfy the purpose and need for this draft SEIS, as it does not provide power generation

27 capacity. The no-action alternative would not meet the energy needs currently met by PINGP 1

28 and 2 or that the alternatives evaluated in sections 8.1 through 8.3 would satisfy. Assuming that

29 a need currently exists for the power generated by PINGIP 1 and 2, the no-action alternative

30 would require the appropriate energy planning decisionmakers to rely on another alternative or

31 conservation to replace or offset PINGP 1 and 2's capacity.

32 In this section, the NRC staff addresses only those impacts that arise directly as a result of plant

33 shutdown. The NRC staff has already addressed environmental impacts from decommissioning

34 and related activities in several other documents. These documents include the Final Generic

35 Environmental Impact Statement on Decommissioning of Nuclear Facilities, N U REG-0586,

36 Supplement 1 (NRC 2002); the license renewal GElS (Chapter 7; NRC 1996); and Chapter 7 of

37 this draft SEIS. These analyses either directly address or bound the environmental impacts of

38 decommissioning whenever NSP ceases operating PINGP 1 and 2.

39 The NRC staff notes that, even with a renewed operating license, PINGP 1 and 2 will eventually

40 shut down, and the environmental effects addressed in this section will occur at that time. Since

41 these effects have not otherwise been addressed in this draft SEIS, the NRC staff will address

42 the impacts in this section. As with decommissioning effects, it is likely that shutdown effects will

43 be similar whether they occur at the end of the current license or at the end of a renewed

44 license.

October 2009 8-35 Draft NUREG-1437, Supplement 39
Alternatives

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

2 PINGP I and 2 Operation

Continued PINGP l and 2

Operation

Air Quality SMALL SMALL

Groundwater SMALL SMALL

Surface Water SMALL SMALL

Ecology SMALL SMALL

Human Health SMALL SMALL

Socioeconomics SMALL to MODERATE SMALL TO MODERATE

Waste Management SMALL SMALL

3 8.6.1 Air Quality

4 If PINGP 1 and 2 are shut down, there would be a reduction in emissions from activities related

5 to plant operation such as use of diesel generators and employees vehicles. In Chapter 4, NRC

6 staff determined that these emissions would have a SMALL impact on air quality during the

7 renewal term. Therefore, if the plant shuts down and emissions decrease, the impact to air

8 quality would remain SMALL.

9 8.6.2 Groundwater Use and Quality

10 If PINGP 1 and 2 are shut down, the use of groundwater would diminish as plant personnel are

11 removed from the site and operations cease. Some groundwater consumption would continue

12 as a result of the limited staff remaining onsite to maintain facilities prior to decommissioning.

13 Impacts to groundwater use and quality would remain SMALL.

14 8.6.3 Surface Water Use and Quality

15 The rate of consumptive use of surface water would decrease as the plant is shut down and the

16 reactor cooling system continues to remove decay heat. Wastewater discharges would also be

17 reduced considerably. Shutdown would have SMALL impacts on surface water resources,

18 which would continue to decrease over the decommissioning phase.

19 8.6.4 Aquatic and Terrestrial Resources

20 Plant shutdown will minimally affect terrestrial resources. In Chapter 4 of this draftSEIS, the

21 NRC staff concluded that the impacts of continued operation on terrestrial resources will be

22 SMALL. No additional land disturbances onsite or offsite would occur. Maintenance of

23 transmission line ROWs would continue, regardless of plant operation. Shutdown would reduce

24 the already SMALL impacts to terrestrial ecology. Accordingly, the NRC staff concludes that

25 impacts to terrestrial resources as a result of plant shutdown would be SMALL.

26 Because plant shutdown would result in less water withdrawal and discharge, the no-action

27 alternative would reduce the already SMALL impacts to aquatic ecology; therefore, impacts to

28 aquatic resources as a result of plant shutdown would be SMALL.

29 8.6.5 Human Health

30 Human health risks would decrease following plant shutdown. The plant, which is currently

31 operating within regulatory limits, would emit less gaseous and liquid radioactive material to the

32 environment. Also, after shutdown, the variety of potential accidents at the plant (radiological or

33 industrial) would be reduced to a limited set associated with shutdown events and fuel handling

Draft NUREG-1437, Supplement 39 8-36 October 2009
Alternatives

1 and storage. In Chapter 4 of this draft SEIS, the NRC staff concluded that the impacts of

2 continued plant operation on human health would be SMALL. In Chapter 5, the NRC staff

3 concluded that the impacts of accidents during operation were SMALL. Therefore, as

4 radioactive emissions to the environment decrease, and as the likelihood and variety of

5 accidents decrease following shutdown, the NRC staff concludes that the impacts to human

6 health following plant shutdown would be SMALL.

7 8.6.6 Socioeconomics

8 Land Use

9 Plant shutdown would not affect onsite land use. Plant structures and other facilities would

10 remain in place until decommissioning. Transmission lines connected to PINGP 1 and 2 would

11 remain in service after the plant stops operating, and maintenance of these transmission lines

12 would continue as before. Impacts on land use from plant shutdown would be SMALL.

13 Socioeconomics

14 Plant shutdown would have an impact on socioeconomic conditions in the region around PINGP

15 1 and 2. Plant shutdown would eliminate approximately 685 jobs and would reduce tax revenue

16 in the region. The loss of these contributions, which may not entirely cease until after

17 decommissioning, would have a SMALL to MODERATE impact. Appendix J to NUREG 0586,

18 Supplement 1 (NRC 2002) provides additional discussion of the potential socioeconomic

19 impacts of plant decommissioning.

20 Transportation

21 Traffic volumes on the roads in the vicinity of PINGP 1 and 2 would be reduced after plant

22 shutdown. Most of the reduction in traffic volume would be associated with the loss of jobs at

23 the plant. Deliveries to the plant would be reduced until decommissioning, at which point they

24 would cease. Transportation impacts would be SMALL as a result of plant shutdown.

25 Transportation impacts would increase if a new energy facility were constructed on the PINGP 1

26 and 2 site, as described in the alternatives above.

27 Aesthetics

28 Plant structures and other facilities would remain in place until decommissioning, but plumes

29 from the plant's cooling towers would disappear entirely. Noise caused by plant operation would

30 cease. Aesthetic impacts of plant closure would be SMALL.

31 Historic and Archaeologqical Resources

32 Plant shutdown will likely have no noticeable immediate impacts on historic and archaeological

33 resources. Decommissioning methods would be described in a post-shutdown decommissioning

34 activities report, which is required to be submitted to NRC within two years following cessation

35 of operations. NRC requirements ensure that the decommissioning activities would be subject to

36 a Section 106 review in accordancewith the National Historic Preservation Act (NHPA).

37 Additionally, if NSP's commitments outlined on 4.9.6 of this draft SEIS are implemented,

38 impacts from decommissioning would be reduced. It is unlikely that plant staff will begin

39 deconstruction or remediation before decommissioning. Because existing transmission lines will

40 remain energized, transmission line ROW maintenance would continue. In Chapter 4 of this

41 draft SEIS, the NRC concluded that the impacts of continued plant operation on historic and

42 archaeological resources could be MODERATE. Given the high potential for resources in the

43 area, the NRC concludes that the impacts on historic and archaeological resources from plant

44 shutdown could also be MODERATE.

October 2009 8-37 Draft NUREG-1437, Supplement 39
Alternatives

1 The Following information is provided by the Prairie Island Indian Community.

2 If this alternative is implemented, the PINGP 1 and 2 would shut down and

3 decommissioning would commence. Given the number of recorded

4 archaeological sites and the high potential to encounter unrecorded sites within

5 the PINGP 1 and 2 boundaries, the tribe agrees with the NRC's conclusion that

6 impacts could be MODERATE. It is expected that the Prairie Island Indian

7 Community would be involved in the archaeological reconnaissance work

8 associated with decommissioning.

9 Environmental Justice

10 Plant shutdown could disproportionately affect the PIIC, but would not disproportionately affect

11 other minority and low-income populations outside of the immediate vicinity of PINGP 1 and 2.

12 Impacts to all the other resource areas pertaining to environmental justice are SMALL to

13 MODERATE regarding the no-action alternative. Minority and low-income populations are

14 generally concentrated in the urban area of Minneapolis-St. Paul. Thus, overall impacts to

15 environmental justice from plant shutdown would be SMALL to MODERATE. Appendix J of

16 NUREG 0586, Supplement 1 (NRC 2002), provides additional discussion of these impacts.

17 The following information is provided by the Prairie Island Indian Community.

18 As stated above, plant shut down could disproportionately affect the Prairie

19 Island Indian Community. The tribe, however, views the disproportionate

20 impacts in a positive way:

21 Health risks from chronic exposure to low levels of radiation from the PINGP 1

22 and 2 would decrease.

23 Risk to the community from accidents would be reduced.

24 Risks to the community from the operation of the PINGP 1 and 2 would

25 decrease.

26 Tritium contamination from plant operations would cease, thereby reducing

27 health risks.

28 NSPM will not apply for a license amendment for an extended power uprate,

29 thereby eliminating all environmental and health impacts associated with the

30 uprate.

31 The risk of cumulative and integrated health and safety impacts would be

32 reduced.

33 Cumulative and integrated environmental impacts would decrease.

34 Overall, the long-term Environmental Justice impacts to the Prairie Island Indian

35 Community from the implementation of the No Action alternative would be

36 LARGE and positive.

37 Traffic impacts associated with decommissioning the PINGP 1 and 2 would be

38 MODERATE. The impacts, however, would be of a short-duration.

39 Even if the PINGP 1 and 2 were to shut down, spent fuel stored at the ISFSI

40 would remain indefinitely stranded on Prairie Island. It is not clear whether there

41 be any plant personnel who would monitor the ISFSI operation and respond to

42 any emergencies. The 2003 Settlement agreement between the tribe and

43 NSPM, related to the dry cask storage, would still be in effect.

Draft NUREG-1437, Supplement 39 8-38 October 2009
Alternatives

1 8.6.7 Waste Management

2 If the no-action alternative were implemented, the generation of high-level waste would cease

3 and generation of low-level and mixed waste would decrease. Impacts from implementation of

4 the no-action alternative are expected to be SMALL.

5 8.7 Alternatives Summary

6 In this chapter, we considered the following alternatives to PINGP 1 and 2 license renewal:

7 • a gas-fired combined-cycle plant at the PINGP 1 and 2 site and an

8 undetermined alternate site

9 0 a combination including a gas-fired unit, wind power, conservation, and

10 wood-waste biomass, and

11 * a combination including continued operation of one of the two PINGP 1 and 2

12 unit, wind power, and conservation.

13 Finally, the NRC staff considered the effects of no action by the NRC and the effects it would

14 have. Impacts for all alternatives are summarized in Table 8.5. The impacts of license renewal

15 for PINGP 1 and 2 are similar to or smaller than the impacts of the alternatives considered in

16 this chapter in all resource areas.

October 2009 8-39 Draft NUREG-1437, Supplement 39
Alternatives

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

PINGP 1 and 2

License Renewal

Gas-fired at PINGP Gas-fired at Combination Combination No-Action

1 and 2 Site Alternate Site Alternative 1 Alternative 2 Alternative

Air Quality SMALL MODERATE MODERATE MODERATE SMALL SMALL

Groundwater SMALL SMALL SMALL SMALL SMALL SMALL

Surface Water SMALL SMALL SMALL SMALL to SMALL SMALL

MODERATE

Ecology SMALL SMALL SMALL to SMALL to SMALL SMALL

MODERATE MODERATE

Human Health SMALL SMALL SMALL MODERATE SMALL SMALL

Socioeconomics SMALL TO SMALL to SMALL to SMALL to SMALL to SMALL to

MODERATE MODERATE MODERATE LARGE LARGE MODERATE

Waste Management SMALL SMALL SMALL SMALL SMALL SMALL

2

October 2009 8-40 Draft NUREG-1437, Supplement 39
Alternatives

1 8.8 References

2 10 CFR 51. U.S. Code of Federal Regulations, Title 10 "Environmental Protection Regulations

3 for Domestic Licensing and Related Regulatory Functions," Part 51, "Energy."

4 40 CFR 50. U.S. Code of Federal Regulations, Title 40, Protection of Environment, Part 50,

5 "Domestic Licensing of Production and Utilization Facilties."

6 40 CFR 51. U.S. Code of Federal Regulations, Title 40, Protection of Environment, Part 51,

7 "Requirements for Preparation, Adoption, and Submittal of Implementation Plans."

8 40 CFR 60. U.S. Code of Federal Regulations, Title 40, Protection of Environment, Part 60,

9 "Standards of Performance for New Stationary Sources."

10 42 U.S.C. §7475. United States Code. Title 42, "The Public Health and Welfare"; Section 7475,

11 "Preconstruction Requirements."

12 136-S.F.No. 145. Laws of Minnesota for 2007. "Next Generation Energy Act of 2007." Available

13 URL: https://www.revisor.leg.state.mn.us/data/revisor/law/2007/0/2007-136.pdf (accessed

14 January 6, 2009).

15 AWEA (American Wind Energy Association). Undated. "Resources: Wind Energy Projects (As

16 of 12/31/2008)." Available URL: http://www.awea.org/projects/ (accessed February 4, 2009).

17 CAA (Clean Air Act. 42 U.S.C. 7401, et seq.). United States Code, Title 42, The Public Health

18 and Welfare, Chapter 85, "Air Pollution Prevention and Control."

19 EIA (Energy Information Administration). 2006. "Cost and Quality of Fuel for Electric Plants,

20 2004 and 2005." DOE/EIA 0191(2006). Washington, D.C. Available URL:

21 http://www.eia.doe.gov/cneaf/electricity/cq/cqa2005.pdf (accessed March 16, 2007). ADAMS

22 No. ML082880730.

23 EIA (U.S. Department of Energy, Energy Information Administration). 2007a. "Summary 24 Statistics for the United States." Table ES1 from Electric Power Annual with data for 2006.

25 Accessed at: http://www.eia.doe.gov/cneaf/electricity/epa/epates.html (accessed June 11,

26 2008). ADAMS No. ML082880730.

27 EIA (U.S. Department of Energy, Energy Information Administration). 2007b. State Energy

28 Profiles 2006. DOE/EIA-0348(01)/2. Washington, D.C. Available URL:

29 http://www.eia.doe.gov/cneaf/electricity/st-profiles/sep2006.pdf (accessed January 22, 2009).

30 EIA (U.S. Department of Energy, Energy Information Administration). 2008a. Annual Energy

31 Outlook 2008 With Projections to 2030. DOE/EIA 0383(2008). Washington, D.C. Available URL:

32 http://tonto.eia.doe.gov/FTPROOT/forecasting/0383(2008).pdf (accessed January 6, 2009).

33 ADAMS No. ML082880730.

34 EIA (Energy Information Administration. 2008b. Assumptions to the Annual Energy Outlook

35 2008 With Projections to 2030. DOE/EIA 0554(2008). Washington, D.C. Available URL:

36 http://tonto.eia.doe.gov/FTPROOT/forecasting/0554(2007).pdf (accessed July 22, 2008).

37 ADAMS No. ML082880730.

38 EPA (U. S. Environmental Protection Agency). 2008. "Particulate Matter: Health Effects."

39 Available URL: http://www.epa.gov/air/particlepollution/health.html (accessed December 12,

40 2008). ADAMS No. ML083470281.

41 GE (General Electric Company). 2007. "Gas Turbine and Combined Cycle Products." May

42 2007. Available URL: http://www.gepower.com/prodserv/products/gasturbinescc/

October 2009 8-41 Draft NUREG-1437, Supplement 39
Alternatives

1 en/downloads/gasturbine cc products.pdf (accessed January 6, 2009). ADAMS No.

2 ML082880731.

3 INEEL (Idaho National Engineering and Environmental Laboratory). 1996. "U.S. Hydropower

4 Resource Assessment for .Minnesota." DOE/ID-1 0430(MN). Idaho Falls, ID. Available URL:

5 http://hydropower.inl.gov/resourceassessment/pdfs/states/mn.pdf (accessed January 22, 2009).

6 July.

7 IWSA (Integrated Waste Services Association). 2007. "Waste-to-Energy and the Production Tax

8 Credit." Washington, DC. Available URL: http://www.wte.org/docs/FactSheetPTC.pdf (accessed

9 May 24, 2007). ADAMS No. ML083050223.

10 MNDOC (Minnesota Department of Commerce). 2006a. "Minnesota's Wind Resource by

11 Capacity Factor at 80 Meters." Available URL: http://www.state.mn.us/mn/externalDocs/

12 Commerce/80_MeterCapacityFactor_013106115407_8OMeterCF.pdf (accessed February 4,

13 2009). January.

14 Minnesota Department of Commerce (MNDOC). 2006b. "Minnesota's Wind Resource by Wind

15 Speed at 80 Meters." Available URL: http://www.state.mn.us/mn/externalDocs/Commerce/

16 80_MeterWindSpeed_013106115153_8oMeterWindSpeed.pdf (accessed February 4, 2009).

17 January.

18 NMC (Nuclear Management Company, LLC). 2008. Prairie Island Nuclear Generating Plant,

19 Units 1 and 2, License Renewal Application, Appendix E - Applicant's Environmental Report,

20 License Renewal Operating Stage. Redwing, Minnesota. April 2008. ADAMS Nos.

21 ML081130677, ML081130681, and ML081130684.

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

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

24 ADAMS Nos. ML040690705 and ML040690738.

25 NRC (U.S. Nuclear Regulatory Commission). 1999. Generic Environmental Impact Statement

26 for License Renewal of Nuclear Plants, Main Report, "Section 6.3 -Transportation, Table 9.1,

27 Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report."

28 NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

29 NRC (U.S. Nuclear Regulatory Commission). 2002. Generic Environmental Impact Statement

30 on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of

31 Nuclear Power Reactors. NUREG-0586, Supplement 1, Volumes 1 and 2. Washington, DC.

32 NREL (National Renewable Energy Laboratory). 2009. "United States Atlas of Renewable

33 Resources." Interactive Map. Available URL: http://mapserve2.nrel.gov/website/ResourceAtlas/

34 viewer.htm (accessed February 4, 2009).

35 Nucleonics Week. 2008. U.S. New Reactors More Likely Online in 2016 and Beyond, NEI

36 Official Says. Vol. 49, No. 15. April 10, 2008.

37 OMB (U.S. Office of Management and Budget). 2007. "Detailed Information on the Low Income

38 Home Energy Assistance Program Assessment." Available URL:

39 http://www.whitehouse.gov/omb/expectmore/detail/10001059.2003.html (accessed July 10,

40 2007). ADAMS No. ML082880730.

41 ORNL (Oak Ridge National Laboratory). 2007. "Bioenergy Conversion Factors." Available URL:

42 http://bioenergy.ornl.gov/papers/misc/energyconv.html (accessed November 6, 2007). ADAMS

43 No. ML083050223.

44 Walsh, M.E., R.L. Perlack, A. Turhollow, D. de la Torre Ugarte, D.A. Becker, R.L. Graham, S.A.

45 Slinsky, and D.E. Ray. 2000. "Biomass Feedstock Availability in the United States: 1999 State

Draft NUREG-1437, Supplement 39 8-42 October 2009
Alternatives

1 Level Analysis." Available URL: http://bioenergy.ornl.gov/resourcedata/index.html (accessed

2 May 22, 2007). ADAMS No. ML083050223.

3 Xcel Energy (Xcel). 2007. 2007 Minnesota Resource Plan. Available URL:

4 http://www.xcelenergy.com/Company/About-Energy-and-Rates/Resource%2band%2ORenewa

5 ble%20Energy%20Plans/Pages/2007_MinnesotaResourcePlan.aspx. Accessed 28 August

6 2009.

7 Xcel Energy. 2008. "Wind-to-Battery Project." Available URL:

8 http://www.xcelenergy.com/SiteCollectionDocuments/docs/wind-to-battery.pdf (accessed

9 February 4, 2009).

10

11

October 2009 8-43 Draft NUREG-1437, Supplement 39

Conclusion

1 9.0 CONCLUSION

2 This draft supplemental environmental impact statement (SEIS) contains the preliminary

3 environmental review of Northern State Power Co. (NSP) application for a renewed operating

4 license for Prairie Island Nuclear Generating Plant, Units 1 and 2 (PINGP 1 and 2) as required

5 by Part 51 of Title 10, of the Code of Federal Regulations (10 CFR Part 51), the NRC's

6 regulations that implement the National Environmental Policy Act of 1969 (NEPA). Chapter 9

7 presents the conclusions and recommendations from the site-specific environmental review of

8 PINGP 1 and 2 and summarizes site-specific environmental issues of license renewal that were

9 identified during the review. The environmental impacts of license renewal are summarized in

10 Section 9.1; a comparison of the environmental impacts of license renewal and energy

11 alternatives is presented in Section 9.2; unavoidable impacts of license renewal and energy

12 alternatives and resource commitments are discussed in Section 9.3; and conclusions and NRC

13 staff recommendations are presented in Section 9.4.

14 9.1 Environmental Impacts of License Renewal

15 Our review of site-specific environmental issues in this draft supplemental EIS leads us to

16 conclude that issuing a renewed license would have SMALL impacts for 20 of the 21 Category 2

17 issues applicable to license renewal and refurbishment at PINGP 1 and 2, and MODERATE for

18 1 Category issue applicable to license renewal and refurbishment at PINGP 1 and 2, as well as

19 environmental justice and chronic effects of electromagnetic fields.

20 Mitigation measures were considered for each Category 2 issue, as applicable. For ground

21 water and surface water use issues, current measures to mitigate the environmental impacts of

22 plant operation were found to be adequate. Potential mitigation measures for reducing impacts

23 from thermophilic microbiological organisms resulting from PINGP 1 and 2 thermal discharge

24 include periodically monitoring for thermophilic microbiological organisms in the water and

25 sediments near the discharge, and prohibiting recreational use near the discharge plume. The

26 staff identified a variety of measures that could mitigate potential acute electromagnetic field

27 impacts resulting from continued operation of the PINGP 1 and 2 transmission lines, including

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

29 increasing transmission line clearances.

30 For aquatic resources issues, current measures to mitigate the environmental impacts of plant

31 operation were found to be adequate including using closed and helper cycle cooling, fine-mesh

32 screens, and flow limitations. Additional mitigative measures that PINGP 1 and 2 could add

33 include operating in closed cycle more often, using the fine-mesh screens for a longer period of

34 time, reducing intake velocities, and operating under reduced intake flows.

35 Mitigation measures that could reduce impacts to the terrestrial environment, as well as to the

36 threatened and endangered species during refurbishment activities, include undertaking the

37 steam generator replacement outside of the peregrine falcon breeding season, minimizing

38 activities that may cause significant noise during midday hours when peregrine falcons are more

39 likely to hunt for food, the use of best management practices, and restoring cleared land that

40 remains after completion of construction. Mitigation measures to reduce potential air quality

41 impacts resulting from refurbishment activities include implementation of a dust control plan to

42 minimize emissions from construction activities, and the use of multiperson vans and workforce

43 shift changes to reduce the number of vehicles on the road at any one given time.

44 Impacts to known historic and archaeological resources are potentially expected from the

45 continued operation of PINGP 1 and 2 during the license renewal term; however, with the

October 2009 9-1 Draft NUREG-1437, Supplement 39
Conslusion

1 committmetns proposed by NSP, these impacts could be mitigated. These commitments would

2 serve to integrate cultural resource considerations with ongoing PINGP 1 and 2 activities.

3 Additionally, training of NSP staff in the Section 106 process would ensure that informed

4 decisions are made when considering the effects of future projects on historic and

5 archaeological resources. As previously discussed, lands not previously surveyed should be

6 investigated by a professional archaeologist prior to any ground disturbance.

7 The NRC also considered cumulative impacts of past, present, and reasonably foreseeable

8 future actions, regardless of what agency (Federal or non-Federal) or person undertakes them.

9 The staff concluded that cumulative impacts of PINGP 1 and 2 license renewal and

10 refurbishment would be SMALL to LARGE for potentially affected resources.

11 9.2 Comparison of Environmental Impacts of License Renewal and

12 Alternatives

13 In the conclusion to Chapter 8, we determined that impacts from license renewal are generally

14 less than the impacts of alternatives to license renewal, with the exception of energy

15 conservation and energy efficiency. In comparing likely environmental impacts from a gas-fired

16 combined-cycle plant at the PINGP 1 and 2 site and an undetermined alternate site, a

17 combination including a gas-fired unit, wind power, conservation, and wood-waste biomass, and

18 a combination including continued operation of one of the two PINGP 1 and 2 unit, wind power,

19 and conservation, and environmental impacts from license renewal, we found that the energy

20 conservation and energy efficiency alternative would result in the lowest environmental impact.

21 Based on our analysis, we found that the impacts of license renewal are reasonable in light of

22 the impacts from alternatives to the license renewal of PINGP 1 and 2.

23 9.3 Resource Commitments

24 9.3.1 Unavoidable Adverse Environmental Impacts

25 Unavoidable adverse environmental impacts are impacts that would occur after implementation

26 of all feasible mitigation measures. Implementing any of the energy alternatives considered in

27 this supplemental EIS, including the proposed action, would result in some unavoidable adverse

28 environmental impacts.

29 Minor unavoidable adverse impacts on air quality would occur due to emission and release of

30 various chemical and radiological constituents from power plant operations. Nonradiological

31 emissions resulting from power plant operations are expected to comply with U.S.

32 Environmental Protection Agency (EPA) emissions standards, though the alternative of

33 operating a fossil-fueled power plant in some areas may worsen existing attainment issues.

34 Chemical and radiological emissions would not exceed the National Emission Standards for

35 Hazardous Air Pollutants.

36 During nuclear power plant operations, workers and members of the public would face

37 unavoidable exposure to radiation and hazardous and toxic chemicals. Workers would be

38 exposed to radiation and chemicals associated with routine plant operations and the handling of

39 nuclear fuel and waste material. Workers would have higher levels of exposure than members

40 of the public, but doses would be administratively controlled and would not exceed any

41 standards or administrative control limits. In comparison, the alternatives entailing the

42 construction and operation of a non-nuclear power generating facility would also result in

43 unavoidable exposure to hazardous and toxic chemicals to workers and the general public.

Draft NUREG-1437, Supplement 39 9-2 October 2009
Conclusion

1 The generation of spent nuclear fuel and waste material, including low-level radioactive waste,

2 hazardous waste, and nonhazardous waste would also be unavoidable. In comparison,

3 hazardous and nonhazardous wastes would also be generated at non-nuclear power generating

4 facilities. Wastes generated during plant operations would be collected, stored, and shipped for

5 suitable treatment, recycling, or disposal in accordance with applicable Federal and State

6 regulations. Due to the costs of handling these materials, power plant operators would be

7 expected to conduct all activities and optimize all operations in a way that generates the

8 smallest amount of waste practical.

9 9.3.2 Relationship Between Local Short-Term Uses of the Environment and the

10 Maintenance and Enhancement of Long-Term Productivity

11 The operation of power generating facilities would result in short-term uses of the environment

12 as described in Chapters 4, 5, 6, 7, and 8. "Short term" is the period of time during which

13 continued power generating activities would take place.

14 Power plant operations would necessitate short-term use of the environment and commitments

15 of resources, and would also commit certain resources (e.g., land and energy) indefinitely or

16 permanently. Certain short-term resource commitments would be substantially greater under

17 most energy alternatives, including license renewal, than under the No Action Alternative due to

18 the continued generation of electrical power as well as continued use of generating sites and

19 associated infrastructure. During operations, all energy alternatives would entail similar

20 relationships between local short-term uses of the environment and the maintenance and

21 enhancement of long term productivity.

22 Air emissions from power plant operations would introduce small amounts of radiological and

23 nonradiological constituents to the region around the plant site. Over time, these emissions

24 would result in increased concentrations and exposure, but are not expected to impact air

25 quality or radiation exposure to the extent that public health and long-term productivity of the

26 environment would be impaired.

27 Continued employment, expenditures, and tax revenues generated during power plant

28 operations would directly benefit local, regional, and State economies over the short term. Local

29 governments investing project-generated tax revenues into infrastructure and other required

30 services could enhance economic productivity over the long term.

31 The management and disposal 'of spent nuclear fuel, low-level radioactive waste, hazardous

32 waste, and nonhazardous waste would require an increase in energy and would consume

33 space at treatment, storage, or disposal facilities. Regardless of the location, the use of land to

34 meet waste disposal needs would reduce the long-term productivity of the land.

35 Power plant facilities would be committed to electricity production over the short term. After

36 decommissioning these facilities and restoring the area, the land could be available for other

37 future productive uses.

38 9.3.3 Irreversible and Irretrievable Commitments of Resources

39 This section describes the irreversible and irretrievable commitments of resources that have

40 been identified in this supplemental EIS. Irreversible resources refer to when primary or

41 secondary impacts limit the future options for a resource. An irretrievable commitment refers to

42 the use or consumption of resources that are neither renewable nor recoverable for future use.

43 Irreversible and irretrievable commitment of resources for electrical power generation would

44 include the commitment of land, water, energy, raw materials, and other natural and man-made

October 2009 9-3 Draft NUREG-1437, Supplement 39
Conslusion

1 resources required for power plant operations. In general, the commitment of capital, energy,

2 labor, and material resources would also be irreversible.

3 The implementation of any of the energy alternatives considered in this supplemental EIS would

4 entail the irreversible and irretrievable commitment of energy, water, chemicals, and, in some

5 cases, fossil fuels. These resources would be committed during the license renewal term and

6 over the entire life cycle of the power plant and would essentially be unrecoverable.

7 Energy expended would be in the form of fuel for equipment, vehicles, and power plant

8 operations and electricity for equipment and facility operations. Electricity and fuels would be

9 purchased from offsite commercial sources. Water would be obtained from existing water supply

10 systems. These resources are readily available, and the amounts required are not expected to

11 deplete available supplies or exceed available system capacities.

12 The irreversible and irretrievable commitment of material resources includes materials that

13 cannot be recovered or recycled, materials that are rendered radioactive and cannot be

14 decontaminated, and materials consumed or reduced to unrecoverable forms of waste.

15 However, none of the resources used by these power generating facilities are in short supply,

16 and, for the most part, are readily available.

17 Various materials and chemicals, including acids and caustics, would be required to support

18 operations activities. These materials would be derived from commercial vendors, and their

19 consumption is not expected to affect local, regional, or national supplies.

20 The treatment, storage, and disposal of spent nuclear fuel, low-level radioactive waste,

21 hazardous waste, and nonhazardous waste would require the irretrievable commitment of

22 energy and fuel and would result in the irreversible commitment of space in disposal facilities.

23 9.4 Recommendations

24 Based on (1) the analysis and findings in the GELS, (2) information provided in the

25 environmental report (ER) submitted by NSP, (3) consultation with Federal, State, and local

26 agencies, (4) a review of pertinent documents and reports, and (5) consideration of public

27 comments received during scoping, the preliminary recommendation of the NRC staff is that the

28 Commission determine that the adverse environmental impacts of license renewal for PINGP 1

29 and 2 are not so great that preserving the option of license renewal for energy planning decision

30 makers would be unreasonable.

Draft NUREG-1437, Supplement 39 9-4 October 2009
Preparers

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 and the Prairie Island Indian Community provided expertise

in Land Use, Socioeconomics, Cultural Resources, and Environmental Justice,

presented in Chapters 2, 3, 4, 5, and 8.

Name Affiliation Function or Expertise

Nuclear Regulatory Commission

Briana Balsam Nuclear Reactor Regulation

Dennis Beissel Nuclear Reactor Regulation

Jennifer Davis Nuclear Reactor Regulation

Nathan Goodman Nuclear Reactor Regulation

Stephen Klementowicz Nuclear Reactor Regulation

Ekaterina Lenning Nuclear Reactor Regulation

Dennis Logan Nuclear Reactor Regulation

Sarah Lopas Nuclear Reactor Regulation

Terrestrial Ecology; Project

Support

Hydrology

Historic and Archaeological

Resources

Project Manager

Radiation Protection

Air Quality; Radiation

Protection; Human Health

Ecology

Project Support;

Nonradiological Waste; TMO;

EMF

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

Elizabeth Wexler Nuclear Reactor Regulation Aquatic Ecology

Prairie Island Indian Community

SAMA Contractors(a)

Steve Short Pacific Northwest National Laboratory Severe Accidents Mitigation

Alternatives

Bruce Schmitt Pacific Northwest National Laboratory Severe Accidents Mitigation

Alternatives

Tye Blackburn Pacific Northwest National Laboratory Severe Accidents Mitigation

Alternatives

(a) Pacific Northwest National Laboratory is operated by Batelle for the U.S. Department of Energy

Draft NUREG-1437, Supplement 39 10-1 October 2009

Appendix A

Comments Received on the Prairie Island Nuclear Generating Station,

Units 1 and 2, Environmental Review

Draft NUREG-1437, Supplement 39 October 2009

Appendix A

A. Comments Received on the Prairie Island Nuclear Generating

Station, Units 1 and 2, Environmental Review

Introduction

On April 11, 2008, the Nuclear Regulatory Commission (NRC) received an application from

Northern States Power Co. (NSP) [formerly Nuclear Management Company, LLC (NMC)] for

renewal of the operating license of Prairie Island Nuclear Generating Plant, Units 1 and 2

(PINGP 1 and 2). PINGP 1 and 2 are located in Red Wing, Minnesota, which is in Goodhue

County on the west bank of the Mississippi River. As part of the application, NSP submitted an

environmental report (ER) prepared in accordance with the requirements of 10 CFR Part 51.

10 CFR Part 51 contains the NRC requirements for implementing the National Environmental

Policy Act (NEPA) of 1969 and the implementing regulations promulgated by the Council on

Environmental Quality (CEQ). Section 51.53 outlines requirements for preparation and submittal

of environmental reports to the NRC.

Section 51.53(c)(3) was based upon the findings documented in NUREG-1437, "Generic

Environmental Impact Statement for License Renewal of Nuclear Power Plants," (GELS). The

GELS, which identified and evaluated the environmental impacts associated with license

renewal, was first issued as a draft for public comment. The staff received input from Federal

and State agencies, public organizations, and private citizens before developing the final

document. As a result of the assessments in the GELS, a number of impacts were determined to

be small and to be generic to all nuclear power plants. These were designated as Category 1

impacts. An applicant for license renewal may adopt the conclusions contained in the GElS for

Category 1 impacts, absent new and significant information that may cause the conclusions to

fall outside those of the GELS. Category 2 impacts are those impacts that have been determined

to be plant-specific and are required to be evaluated in the applicant's ER.

The Commission determined that the NRC does not have a role in energy planning decisionmaking for existing plants, which should be left to State regulators and utility officials. Therefore,

an applicant for license renewal need not provide an analysis of the need for power, or the

economic costs and economic benefits of the proposed action. Additionally, the Commission

determined that the ER need not discuss any aspect of storage of spent fuel for the facility that

is within the scope of the generic determination in 10 CFR 51.23(a) and in accordance with

10 CFR 51.23(b). This determination was based on the Nuclear Waste Policy Act of 1982 and

the Commission's Waste Confidence Rule, 10 CFR 51.23.

On July 22, 2008, the NRC published a Notice of Intent in the Federal Register (73 FR 42628),

to notify the public of the staff's intent to prepare a plant-specific supplement to the GElS (SEIS)

regarding the renewal application for the PINGP 1 and 2 operating license. The plant-specific

supplement to the GElS will be prepared in accordance with NEPA, CEQ guidelines, and

10 CFR Part 51. As outlined by NEPA, the NRC initiated the scoping process with the issuance

of the Federal Register Notice. The NRC invited the applicant, federal, state, local, and tribal

government agencies, local organizations, and individuals to participate in the scoping process

by providing oral comments at scheduled public meetings, which were held at the Red Wing

Public Library, in Red Wing, Minnesota on July 30, 2008, and/or submitting written suggestions

and comments no later than September 22, 2008. The NRC issued press releases, placed ads

in the local paper, and distributed flyers locally to advertise the public meetings. Approximately

75 people attended the meetings. Both sessions began with NRC staff members providing a

brief overview of the license renewal process and the NEPA process. Following the NRC's

prepared statements, the meetings were open for public comments. Several attendees

Draft NUREG-1437, Supplement 39 A-1 October 2009
Appendix A

submitted written comments, others provided oral comments, which were transcribed by a

certified court reporter. The transcripts of the meetings were issued on September 3, 2008 for

the afternoon session and September 5, 2008 for the evening session. The transcripts are

available for public inspection in the NRC Public Document Room (PDR), located at One White

Flint North, 11555 Rockville Pike, Rockville, Maryland, 20852, or from the NRC's Agencywide

Documents Access and Management System (ADAMS). The ADAMS Public Electronic Reading

Room is accessible at http:/Iwww.nrc.qov/readinc-rm/adams/web-based.html. The transcripts

for the public meeting can be found in ADAMS at accession numbers ML082470336 and

ML082490514. Persons who do not have access to ADAMS, or who encounter problems in

accessing the documents located in ADAMS, should contact the NRC's Public Document Room

Reference staff by telephone at 1-800-397-4209, or 301-415- 4737, or by e-mail at

pdr.resource0.nrc.qov.

The scoping process provides an opportunity for public participation to identify issues to be

addressed in the SEIS and highlight public concerns and issues. The Federal Register Notice of

Intent identified the following objectives of the scoping process:

* Define the proposed action

* Determine the scope of the SEIS and identify significant issues to be

analyzed in depth

* Identify and eliminate peripheral issues

* Identify any environmental assessments and other environmental impact

statements being prepared that are related to the SEIS

* Identify other environmental review and consultation requirements

* Indicate the schedule for preparation of the SEIS

* Identify any cooperating agencies

• Describe how the SEIS will be prepared.

Scoping Comment Period Summary

During the scoping period, the NRC staff received six letters and three e-mails containing

comments related to the environmental review for the proposed license renewal of PINGP 1 and

2. Additionally, thirteen people provided oral comments or comments in writing during the July

30, 2008, scoping meetings.

Individuals and/or groups and their affiliation (if applicable) that provided comments during the

scoping period are identified in Table 1. A numerical commenter identification code (1-18) was

assigned to each commenter for purposes of categorizing the comments.

Table 1. Individuals and/or Groups Providing Comments during Scoping Period.

Commenters appear in alphabetical order, and each commenter has been

given a unique commenter identification number.

Commenter

Commenter Affiliation (if stated) ID Number

Arneson, Scott Goodhue County Administrator 1

Betcher, Steve Goodhue County Attorney 2

October 2009 A-2 Draft NUREG-1437, Supplement 39
Appendix A

Crocker, George Executive Director, North American Water Office 3

CURE Communities United for Responsible Energy 4

Eide-Tollefson, Kristen Resident, Florence Township MN 5

Foushee, Lea Environmental Justice Director, North American Water Office 6

Himanga, Katie Mayor, Lake City, Minnesota 7

Jackson, Mary Senior Planner, Dakota County Office Of Planning and 8 Analysis

Johnson, Ron President, Prairie Island Tribal Council & Indian Community 9

Lemon, Gina Leech Lake Band of Ojibwe 10

Lovejoy, Tom Environmental Impact Coordinator, Wisconsin Department of 11

Natural Resources

Marshman, Joan Chair, Florence Township Board of Supervisors 12

Muller, Alan Executive Director, Green Delaware 13

Overland, Carol none provided 14

PIIC Tribal Council Prairie Island Indian Community (PIIC) 15

Schultz, Michael Red Wing City Council 16

Vukmir, Andrija none provided 17

Wadley, Mike PINGP Site Vice President, Nuclear Management Company 18 (NMC)

In order to evaluate the comments, the NRC staff gave each comment a unique identification

code that categorizes the comment by technical issue and also allows each comment or set of

comments to be traced back to the commenter and original source (transcript, letter, or e-mail)

from which the comments were submitted.

Comments were placed into one of twenty-eight technical issue categories, which are based on

the topics that will be contained within the staff's draft supplemental environmental impact

statement (SEIS) for PINGP 1 and 2, as outlined by the GELS. These technical issue categories

and their abbreviation codes are presented in Table 2.

Table 2. Technical Issue Categories. Comments were divided into one of the 28

categories below, each of which has a unique abbreviation code.

Abbreviation

Code Technical Issue

Abbreviation

Code Technical Issue

AMkd1

AS

AR

CI

CR

EJ

Aging Management

Alternative Energy Sources

Aquatic Resources

Cumulative Impacts

Cultural Resources

Environmental Justice

NW`'

ON(a)

OR(a)

OS

PA

RW

Non-radiological Waste

Opposition to Nuclear Power

Opposition to License Renewal

Outside of Scope(c)

Postulated Accidents

Radioactive Waste

Draft NUREG-1437, Supplement 39 A-3 October 2009
Appendix A

Abbreviation

Code Technical Issue

ER Environmental Report(b)

GW Groundwater

HH Human Health

HP NRC Hearing Process

License Renewal and its

Process

LU(a) Land Use

NO(a) Noise

NS Nuclear Safety

Abbreviation

Code Technical Issue

SD Shutdown and

Decommissioning

SE Socioeconomics

SN Support of Nuclear Power

SR Support for License Renewal

SW Surface Water

Threatened and Endangered

TE Species and Essential Fish

Habitat

TR Terrestrial Resources

UR Uranium Fuel Cycle

(a) No comments specific to the categories of aging management, land use, noise, non-radiological

waste, opposition to nuclear power, or opposition to license renewal were submitted during the

PINGP 1 and 2 scoping period.

(b) Comments contained in this category pertain to general quality or content of the applicant's

Environmental Report

(c) Outside of Scope are those comments that pertain to issues that are not evaluated during the

environmental review of license renewal and include, but are not limited to, issues such as need for

power; emergency preparedness; security; terrorism; and spent nuclear fuel storage and disposal.

Presentation of Comments and Responses

Comments Received During the Scoping Period

This document contains a copy of each commenters' submission(s) during the scoping period.

For those that provided oral comments at the scoping meetings, comments are taken from the

meeting transcripts. Each comment is bracketed and labeled with a unique comment

identification number. Note that only those transcript pages on which each individual's

comments are contained are included in this document; however, the complete meeting

transcripts can be accessed online or in-person from ADAMS at accession numbers

ML082470336 and ML082490514. Please refer to the description of ADAMS above for an

explanation of how to access these documents.

Responses to Comments Received During the Scoping Period

The NRC staffs responses to each comment received during the scoping period are organized

by technical issue. Each response is prefaced by a summary of the issue to which the

comment(s) pertain and a list of the unique identification codes of the comments to which the

response applies. Similar comments within a technical issue area may be considered together

in the provided response. Some comments applied to more than one technical issue category

(indicated by a "/" in the comment identification code), and are, therefore, addressed in more

than one section of the staff's responses. For example, the 3-c-ER/HH pertains to both the

Environmental Report and Human Health and is, thus, addressed under both Environmental

Report and Human Health in the staff's responses.

October 2009 Draft NUREG-1437, Supplement 39
Appendix A

Table 3 provides a complete list of comments received during the scoping period, along with the

commenter, comment source (transcript, letter, or e-mail), page number(s) on which the

comment and correlating response(s) appears in this document, and ADAMS accession number

for the original source of the comment.

The preparation of the SEIS will take into account all the relevant issues raised during the

scoping process. The SEIS will address both Category 1 and 2 issues, along with any new

information identified as a result of scoping. The SEIS will rely on conclusions supported by

information in the GElS for Category 1 issues, and will include the analysis of Category 2 issues

and any new and significant information. The draft SEIS will be made available for public

comment. The comment period will offer the next opportunity for the applicant, interested

Federal, State, local, and tribal government agencies, local organizations, and members of the

public to provide input to the NRC's environmental review process. The comments received on

the draft SEIS will be considered in the preparation of the final SEIS. The final SEIS, along with

the staffs Safety Evaluation Report (SER), will be considered by the NRC in reaching a decision

on the PINGP 1 and 2 license renewal application.

Table 3. Comments Received during Scoping Period. Comments are listed

alphabetically by commenter, and each comment has a unique comment

identification code.

Comment Comment ~Response PageAceso ADAMS

Comment ID Commenter Soucent Page No(s). Accession Source No(s). Number

1-a-SR Arneson, S. transcript~al 13 163 ML082470336

2-a-SR Betcher, S. transcript 15-16 163 ML082470336

3-a-LR Crocker, G. transcript 18 157 ML082490514

3-b-HH

3-c-ER/HH

4-a-AS

4-b-AR/SW

4-c-SE

4-d-AR/H H

4-e-HH

4-f-SW

5-a-ER

5-b-GW/SW

5-c-LR

5-d-SE

5-e-AR

5-f-EJ/RW

5-g-CI/LR

5-h-Cl

5-i-OS

Crocker, G.

Crocker, G.

CURE

CURE

CURE

CURE

CURE

CURE

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

transcript

transcript

letter

letter

letter

letter

letter

letter

letter

letter

letter

letter

letter

letter

letter

letter

letter

19-20

20-22

25

26-27

27

27

27

27-28

31

31

31-32

32

32

32

33

33-34

34

154

153,154,156

148, 149

149, 163

163

150, 154

154, 156

163

153

153, 164

158

163

150

152, 161

151, 157

151

159

ML082490514

ML082490514

ML083220369

ML083220365

ML083220365

ML083220365

ML083220365

ML083220365

ML083220377

ML083220377

ML083220377

ML083220377

ML083220377

ML083220377

ML083220377

ML083220377

ML083220377

Draft NUREG-1437, Supplement 39 A-5 October 2009
Appendix A

Comment

Comment ID Commenter Soure Source

Comment

5-j-RW

5-k-OS/RW

5-1-OS

5-m-CI/RW

5-n-RW

5-o-CI/RW

5-p-RW

5-q-CI/LR

5-r-CI/LR

5-s-AS

5-t-AS

5-u-LR/OS

5-v-LR

5-w-CI

5-x-Cl

5-y-OS/RW

5-z-NS

5-aa-RW

6-a-HH

6-b-EJ/UR

6-c-HH

6-d-HH

6-e-HH

6-f-EJ/RW/UR

6-g-LR

6-h-HH/LR

6-i-ER/HH

7-a-ARIRW/SW

7-b-AR/CR/SW

7-c-RW

7-d-AR/CR/SW

8-a-AR/PA/SW

9-a-LR

10-a-CR

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

Eide-Tollefson, K.

Foushee, L.

Foushee, L.

Foushee, L.

Foushee, L.

Foushee, L.

Foushee, L.

Foushee, L.

Foushee, L.

Foushee, L.

Himanga, K.

Himanga, K.

Himanga, K.

Himanga, K.

Jackson, M.

Johnson, R.

Lemon, G.

letter

letter

letter

letter

letter

letter

letter

letter

letter

letter

letter

letter

letter

letter

transcript

transcript

transcript

transcript

e-mail

e-mail

e-mail

e-mail

e-mail

e-mail

transcript

transcript

transcript

letter

letter

transcript

transcript

e-mail

transcript

letter

Page

No(s).

34-35

35

35

35

35

35

36

36

36-38

38

38

38-39

39

39-42

44

44-45

45

45-47

49

49

49-50

51-52

52

52-53

55-56

57-61

62-63

65

65-66

68-69

69

71-72

74-75

77

ADAMS Response Page Accession No(s). Number

161 ML083220377

159, 161 ML083220377

159 ML083220377

151, 161 ML083220377

161 ML083220377

151,161 ML083220377

161 ML083220377

151,158 ML083220377

151, 152, 158 ML083220377

148 ML083220377

148 ML083220377

158 ML083220377

158 ML083220377

151 ML083220377

151 ML082490514

159, 161 ML082490514

159 ML082490514

161 ML082490514

154 ML083220386

152,165 ML083220386

154 ML083220386

154 ML083220372

154 ML083220372

152, 161,165 ML083220372

157 ML082490514

154,158 ML082490514

153,154 ML082490514

149,161,163 ML082660657

149, 151, 163 ML082660657

161 ML082470336

149, 151, 163 ML082470336

150, 160, 164 ML083220385

157 ML082470336

151 ML082660601

October 2009 A-6 Draft NUREG-1437, Supplement 39
Appendix A

Comment Comment ADAMS

Comment ID Commenter Source Page Response Page Accession No(s). No(s). Number

11-a-AR Lovejoy, T. letter 79 149 ML083080277

11-b-NS Lovejoy, T. letter 79 159 ML083080277

11-c-AR/SW Lovejoy, T. letter 79 149, 163 ML083080277

11-d-EJ/SW Lovejoy, T. letter 80 152, 163 ML083080277

11-e-AR Lovejoy, T. letter 80 149 ML083080277

11-f-CI Lovejoy, T. letter 80 151 ML083080277

12-a-RW Marshman, J. transcript 82-83 161 ML082490514

13-a-HH

13-b-LR

13-c-ER/LR

13-d-LR

13-e-SD

13-f-OS

13-g-UR

13-h-RW

13-i-AS

13-j-HH

14-a-LR

14-b-AS

14-c-LR

15-a-ER

15-b-LR

15-c-LR

15-d-HH/EJ

15-e-GW

15-f-HH/EJ

15-g-ER

15-h-HH

15-i-RW

15-j-RW

15-k-AS

15-1-TR

15-m-CR

15-n-TE

Muller, A.

Muller, A.

Muller, A.

Muller, A.

Muller, A.

Muller, A.

Muller, A.

Muller, A.

Muller, A.

Muller, A.

Overland, C.

Overland, C.

Overland, C.

PIIC Tribal Council

PIIC Tribal Council

PIIC Tribal Council

PIIC Tribal Council

PIIC Tribal Council

PIIC Tribal Council

PIIC Tribal Council

PIIC Tribal Council

PIIC Tribal Council

PIIC Tribal Council

PIIC Tribal Council

PIIC Tribal Council

PIIC Tribal Council

PIIC Tribal Council

transcript

transcript

transcript

transcript

transcript

transcript

transcript

transcript

transcript

transcript

transcript

transcript

transcript

letter

letter

letter

letter

letter

letter

letter

letter

letter

letter

letter

letter

letter

letter

85

86-87

88-89

89-90

90

90-92

93

93-94

94-95

95

97-98

98-99

99

103-104

104-105

105

105

105-108

108

108

108-110

110-112

112

112

112-114

114-117

117-119

154

158

153, 158

158

162

159

165

161

148

154

158

148

157

153

157

157

152,154,156

153

152, 154

153

154, 156

161

161

148

164

151

165

ML082490514

ML082490514

ML082490514

ML082490514

ML082490514

ML082490514

ML082490514

ML082490514

ML082490514

ML082490514

ML082490514

ML082490514

ML082490514

ML083200029

ML083200029

ML083200029

ML083200029

ML083200029

ML083200029

ML083200029

ML083200029

ML083200029

ML083200029

ML083200029

ML083200029

ML083200029

ML083200029

Draft NUREG-1437, Supplement 39 A-7 October 2009
Appendix A

t Comment ADAMS

Comment ID Commenter Comment Page No(s). Accession

No(s). Number

15-o-SE PIIC Tribal Council letter 119-120 163 ML083200029

15-p-OS PIIC Tribal Council letter 120 159 ML083200029

15-q-SE PIIC Tribal Council letter 120 163 ML083200029

15-r-EJ PIIC Tribal Council letter 120-121 152 ML083200029

15-s-EJ PIIC Tribal Council letter 121 152 ML083200029

15-t-HH PIIC Tribal Council letter 121 157 ML083200029

15-u-PA PIIC Tribal Council letter 122 160 ML083200029

15-v-CI/OS/RW PIIC Tribal Council letter 123 151, 159, 161 ML083200029

15-w-OS/RW PIIC Tribal Council letter 123 159, 161 ML083200029

15-x-ER PIIC Tribal Council letter 123 153 ML083200029

15-y-ERJLR PIIC Tribal Council letter 123-124 153, 158 ML083200029

15-z-CI/ER PIIC Tribal Council letter 125 151, 153 ML083200029

15-aa-EJ PIIC Tribal Council letter 125 152. ML083200029

15-bb-EJ PIIC Tribal Council letter 125-126 152 ML083200029

15-cc-AS PIIC Tribal Council letter 126 148 ML083200029

15-dd-SW PIIC Tribal Council letter 126 164 ML083200029

15-ee-OS/SW PIIC Tribal Council letter 126 159, 164 ML083200029

15-ff-OS PIIC Tribal Council letter 127 159 ML083200029

15-gg-HH PIIC Tribal Council letter 127 155 ML083200029

15-hh-OS PIIC Tribal Council letter 127 160 ML083200029

16-a-SR Schultz, M. transcript 132-134 163 ML082470336

17-a-SN

17-b-SR

17-c-SN

17-d-RW

17-e-SR

18-a-SR

18-b-NS

18-c-NS

18-d-SR

18-e-SR

18-f-SR

Vukmir, A.

Vukmir, A.

Vukmir, A.

Vukmir, A.

Vukmir, A.

Wadley, M.

Wadley, M.

Wadley, M.

Wadley, M.

Wadley, M.

Wadley, M.

transcript

transcript

transcript

transcript

transcript

transcript

transcript

transcript

transcript

transcript

transcript

136

136

136-137

138

138

140-142

142-144

145

145-146

146

146-147

163

163

163

161

163

163

159

159

163

163

163

ML082470336

ML082470336

ML082470336

ML082470336

ML082470336

ML082470336

ML082470336

ML082470336

ML082470336

ML082470336

ML082470336

,a, Comments were received orally during one of two scoping meetings held on July 30, 2009, and

transcribed by a certified court reporter.

October 2009 A-8 Draft NUREG-1437, Supplement 39
Appendix A

The following pages contain the original comment letters, e-mail messages,

and public meeting transcripts pertaining to the PINGP 1 and 2 scoping

summary report. Each commented is labeled and identified by a unique

comment identification code.

Draft NUREG-1437, Supplement 39 A-9 October 2009
Appendix A

The following pages contain the comments

made by Scott Arneson during the

NRC public scoping meetings held on July 30, 2008

October 2009 A-10 Draft NUREG-1437, Supplement 39
Appendix A

[~~~ . .. . . . .. ....... . . ... ...... - -............. ..... . . . ... . . ... . ....... .. ........ 3_2 1

Administrator. With me is Steve Betcher, Goodhue

County Attorney.

I just wanted to say a few things for the

4 record today, that Goodhue County is very pleased

with the economic impact that Xcel Energy has on the

6 City of Red Wing and Goodhue County and the entire

area. We've appreciated the relationship that we

have with Xcel.

Just in the past couple of years we've 1-a-SR

1 worked through a rate stabilization agreement with

11 them, and we have a great relationship with them.

12 On August llth they will be coming to the

13 County Board and having a committee of the whole on

14 the renewal application, after which point the County

15 Board will be considering a resolution supporting the

16 relicensure.

1I STEVE BETCHER: And as Goodhue County

18 Attorney, I'd just like to put on the record that

19 we've had a multi-faceted relationship with Xcel

20 Energy over the years; and from the time the nuclear

21 plants opened, that we work closely with them on

22 security issues, we work closely with them on

23 continuing economic support in the tax base of this

24 community, and we believe it's been a very successful

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

Q323 RHODE ISLAND AVE., N.W

(202) 2344433 YMSHINGTOrs D.C. 20005-3701

Draft NUREG-1437, Supplement 39 A-1 1 October 2009
Appendix A

The following pages contain the comments

made by Steve Betcher during the

NRC public scoping meetings held on July 30, 2008

October 2009 A-12 Draft NUREG-1437, Supplement 39
Appendix A

_32'

Administrator. With me is Steve Betcher, Goodhue

County Attorney.

I just wanted to say a few things for the

4 record today, that Goodhue County is very pleased

with the economic impact that Xcel Energy has on the

City of Red Wing and Goodhue County and the entire

area. We've appreciated the relationship that we

have with Xcel.

Just in the past couple of years we've

1 worked through a rate stabilization agreement with

i1 them, and we. have a great relationship with them.

12 On August 1lth they will be coming to the

13 County Board and having a committee of the whole on

14 the renewal application, after which point the County

1i Board will be considering a resolution supporting the

16 relicensure.

17 STEVE BETCHER- And as Goodhue County

18 Attorney, I'd just like to put on the record that

19 we've had a multi-faceted relationship with Xcel

20 Energy over the years; and from the time the nuclear

2-a-SR

21 plants opened, that we work closely with them on

22 security issues, we work closely with them on

23 continuing economic support in the tax base of this

24 community, and we believe it's been a very successful

NEAL R. GROSS

COURT REPORTERS AND TRANSCRBERS

1323 RHODE ISLAND AM, N.W.

(202 2344433 RSM•'NGTON. D.t, 20005-3701

Draft NUREG-1437, Supplement 39 A-13 October 2009
Appendix A

_3*3

collaboration up to this point, and we believe that

the necessity of energy to our community has

certainly been recognized by the plants that we've

had here up to this time.

And I believe the County Board will be

considering the full impact of the relationship and

offering their opinions on the future and also their

opinions on any concerns that may be identified, and

we will be reporting back to them on the comments

that we're hearing here today as well.

Thank you.

MR. RAKOVAN: Thank you, gentlemen.

The last person that I have in terms of

filling out the yellow cards is Mike Wadley from Xcel

Energy.

MIKE WADLEY: Thank you.

Good afternoon. My name's Mike Wadley.

I'm the site vice president for the Prairie Island

Nuclear Generating Plant, and I'm here today to

provide Xcel Energy's support and perspective of our

request for renewal of the operating license for

Prairie Island Units 1 and 2.

The mission of everyone that works at

Prairie Island is clear: It's safe, clean, reliable,

2-a-SR (continued)

-j

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AME N W.

(202) 2344433 VSHINGTON D.C. 20005-3701 -w nuakgmsc.,=

October 2009 A-14 Draft NUREG-1437, Supplement 39
Appendix A

The following pages contain the comments

made by George Crocker during the

NRC public scoping meetings held on July 30, 2008

Draft NUREG-1437, Supplement 39 A-15 October 2009
Appendix A

......-...-... ... .3 3 .

GEORGE CROCKER: George Crocker,

Executive Director of the North American Water

3 Office.

4 I've had several people from Wisconsin

tell me that they didn't receive notice of this

meeting, and I'm wondering if -- if such notice did

3-a-LR

go out to people on the other side of the river and,

if so, when? Or if there could -- if not, if there

could be efforts to include people on the Wisconsin

1 side.

11 MS. FRANOVICH: I'll have to go back to

12 my project managers to know exactly who was contacted

13 with a formal letter, who was contacted perhaps with

14 some phone calls and get back to you, Mr. Crocker.

1 I'm not sure off the top of my head.

1 PREMA CHANDRATHIL: Hi. My name is Prema

17 Chandrathil. I'm a public affairs officer out in

1e Region III, which is located down by Chicago.

19 As soon as we received the press release,

20 we went ahead and -- we went ahead and distributed it

21 to the local media in this area. That does also

22 include folks in Wisconsin.

23 We also followed up with a couple phone

24 calls, and we did speak to a couple reporters to go

NEAL R. GROSS

COURT REPORTERS A/,,) TRANSCRIBERS

133 FMOOE ISLAND A~E. NW.

(202) 2344433 WIAS'OGTON D.C 20005-3701

October 2009 A-16 Draft NUREG-1437, Supplement 39
Appendix A

1 So Andrew -- you'd better take a page

2 from young Andrew. He knows how to treat the public.

3 Thank you.

4 MR. RAKOVAN: Okay. Next, George

5 Crocker.

6 And again, after George we'll go to Alan

7 Muller.

8 GEORGE CROCKER: Thank you. My name is

George Crocker. I'm with the North American Water

i Office, and I have a comment for the scope of your

1i environmental review relative to considering

12 analyzing, disclosing environmental impacts of

13 continued plant operation.

14 And the comment that I have relates to

15 the story you just heard about routine releases,

16 because I think that the NRC should require Prairie 3-b-HH

17 Island and all of the other commercial reactors to

18 document where reported released radionuclides go.

19 Where do they go? I know that you do

2C monitoring. You do a lot of monitoring. If you

21 don't really know what you're looking at when you see

22 all of the little thermal luminescent dosimeter

23 mappings and where the pics are, why you say "Aha,

24 there's monitoring."

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

Q323 *I4OE ISLAND AVE, RNW.

(202 2344433 ,RSH'NGTOR O.C. 20005-3701 ,.nkra, on

Draft NUREG-1437, Supplement 39 A-17 October 2009
Appendix A

-4 1

where the

care about

not there.

But, you see, that monitoring tells us

released radiation isn't. And we don't

that for the very simple reason that it's

We want to know where it is. We want to

know the isoplats. Like you look at a map of

geography and you can see the terrain, we want to see

the dispersion pattern for the routine releases.

And we know you can do it.

Remember the Russian spy who died of

plutonium 210 and they tracked him months later with

minute amounts of radionuclides that they tracked all

over Europe?

Remember how the United States busted

North Korea a week later from 50,000 feet because of

minute quantities of radioactive material?

We know how to track radiation, in

exquisite detail. But, you see, we're not applying

that ability to the routine releases.

So my comment is that any environmental

report that does not include the primary routine

environmental impactor is bogus.

And you may fool most of the people all

of the time about it, but there are some of us that

3-b-HH (continued)

3-c-ER/HH

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

t323 RHODE ISLAND AVE, N.W.

(202) 2344433 ASHANG5ON D.C. 20005-3701 ý.Mwkgwmtcwn

October 2009 A-18 Draft NUREG-1437, Supplement 39
Appendix A

... ..... . ... .... ... ... ... ... ...... 4 8 ,

you're not fooling, and sooner or later we're going

to get some traction on it.

3 We did pass a bill through the Minnesota

4 House not last year but the year before. We lost it

in conference. But it would require Minnesota

authority to track the radiation, where does it go,

so we can specify the isoplat, the dispersion

pattern.

Now, I'm not challenging the NRC's or the

1 federal government's preemption right to say whether

11 or not it's safe. That's not the point. You have

12 the authority to determine what's inspect and what's 3-C-ERIH (continued)

13 not.

14 But the public has the right to know

15 where it goes. And the reason that's important is

16 because the National Academies of Science in its BEIR

17 VII report -- that stands for the Biological Effects

18 of Ionizing Radiation, which came out in June of 2005

19 -- states clearly and unequivocally that there is no

20 safe dose of radiation, that every exposure to

21 radionuclide increases the risk of deleterious

22 effect.

23 And because of that the public has a

24 right to know where the hot spots are, where the

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS

1323 IM4ODE ISLAND AW., NW.

(202) 2344433 MNSHNGTOR D.C. 20005-3701 n.n s e."

Draft NUREG-1437, Supplement 39 A-19 October 2009
Appendix A

concentration points may be, what is the dispersion

pattern, are they living within that pattern.

And so, please, let's get serious. If

this is going to be a technology that's going to be

with us for a while -- I have no illusions that until

something heads south real fast, which could happen

anytime, that we're going to continue living with

this threat, but let's at least inform ourselves

about what it is. You do not have the right to

conceal from the public where the routine reported )

emissions go. Thank you very much.

MR. RAKOVAN: Thank you, sir.

Next we'll go to Alan Muller and then to

Carol Overland.

ALAN MULLER: I brought these

(indicating) up because these are the paper copies of

the license renewal, at least that which has been

released to the public. It's not particularly light

reading, but I have had a chance to review some of

it, and it seems to me that what is in here raises a

great many more questions than are answered.

And in fact it answers a lot of rather --

if you look in the index, you can see many references

to electrical connections and other design and

3-c-ER/HH (continued)

NEAL R. GROSS COURT REPORTERS AND TRANSCRI1ERS

1323 RHODE ISLAND AE., NW

(202) 234-4433 MSNAGTOK D.C. 20005-3701 w.nakg.ssc•

October 2009 A-20 Draft NUREG-1437, Supplement 39
Appendix A

The following pages contain the written comments

submitted by the Communities for

Responsible Energy during the scoping period

for the Prairie Island Nuclear Generating Plant

license renewal

Draft NUREG-1437, Supplement 39 A-21 October 2009
Appendix A

CURE

Communities United for Responsible Energy

PO Box 8

Frontenac, MN 55026

September 22, 2008

Comments in Response to XCEL Energy's Application for Certificates of

Need for Additional Dry Cask Storage and Extended Power Uprate at the

Prairie Island Nuclear Generating Plant

Appendix D: Alternative Technologies Screening

Preamble:

Communities United for Responsible Energy (CURE) is an association of

citizens, established in 1996 in response to the selection of Florence Township,

Goodhue County, MN as the location for an off-site Nuclear Spent Fuel Storage

Facility. CURE members have studied the Issues surrounding the operation of

nuclear power plants for more than a decade.

The recent recognition that the world faces serious climate change and

environmental disruptions chiefly due to the rapid infusion of fossil carbon into

the earth's atmosphere by human activities coupled with the need to replace an

aged generation and distribution infrastructure poses a serious problem for

planners, regulators and the electric generation industry, The decisions and

choices made by a relatively few people in Minnesota within the next few years

will have enormous impact on coming generations and the environment they will

inhabit. Reduction of energy demand driven by a significant conservation

ethic and dramatically increased product and system efficiencies are the

essential component for reducing the impact of energy generation on the

environment. Choosing the best "bridge" technologies to carry us through to 4-a-AS

the ultimate, truly clean renewable energy sources will be critical. The long lead

times to build and high capital costs associated with nuclear power and "clean

coal/carbon sequestration" technologies suggest that decisions to commit to

such system my be overwhelmed by "carbon tax" regulations or simply nonavailability of sufficient investment capital to complete a project. A better

approach may be to combine shorter lead time existing renewable technologies

with short lead time, high efficiency, natural gas fired equipment. This more

nimble approach should allow a faster, more cost effective transition to verging

energy generation and storage technologies avoiding the pitfalls of "obsolete

before completion" stranded costs.

October 2009 A-22 Draft NUREG-1437, Supplement 39
Appendix A

Proposal for Alternative Technology : Composite Resource Technology

Southern and Southeastern Minnesota and the eastern bank of the Mississippi

River have wind resources equal or better than most sites that have been

developed in Northern Europe. The geography is very well suited to "cluster"

installations of 3 to 10 utility scale wind turbines. These turbine" clusters" will

soon have access to the transmission and distribution grid presently being

upgraded in the area. The wind turbines are a logical match with contemporary

combined cycle and/or combined heat/power turbines fueled with natural gas

(from Canada and the mid-West US). Other niche technologies (solar, biofuel,

methane digester, etc.) may be combined or integrated to the transitioning

generation mix. Pumped hydro might be explored to augment peak -demand

capacity.

4-a-AS (continued)

Draft NUREG-1437, Supplement 39 A-23 October 2009
Appendix A

CURE

Communities United for Responsible Energy

PO Box 8

Frontenac, MN 55026

September 22, 2008

Comments in Response to XCEL Energy's Application for Certificates of

Need for Additional Dry Cask Storage and Extended Power Uprate at the

Prairie Island Nuclear Generating Plant

Preamble:

Communities United for Responsible Energy (CURE) is an association of

citizens, established in 1996 in response to the selection of Florence Township,

Goodhue County, MN as the location for an off-site Nuclear Spent Fuel Storage

Facility.

CURE members have studied the issues surrounding the operation of nuclear

power plants and the storage and transport of radioactive materials for more than

a decade. During the earlier debates about nuclear plant operation and storage,

industry and state officials continuously assured us that the risk of harm to the

environment, animals and people from resulting from operation of the nuclear

generating plant and the spent fuel storage facility was minimal and should not

be a concern to us. We continue to maintain a healthy suspicion of that

assurance.

We have observed that many modern industrial nations, particularly Scandinavia

and the 23-country European Union, have established regulations that require

government entities and corporations to demonstrate that their actions and

products will not harm the environment or the public, now or in the future. We

American citizens, on the other hand, are burdened with the requirement to prove

that a government or corporate action is harmful to the environment, ourselves or

our progeny.

I. Impact on Regional Waters.

Citizens and communities located downstream from Prairie Island have

observed the changes that have occurred on the River and Lake Pepin

since the PI Plant began operation in the 1970's. They are expressing

concern about increased adverse seasonal impact to the character of the 4-b-AR/SW

river valley and it's ecology.

---- During a recent public meeting, representatives.ofXCEL.and the-State-of__ . .

Minnesota indicated that the proposed 15% uprate of the Prairie Island

October 2009 A-24 Draft NUREG-1437, Supplement 39
Appendix A

plant would require a significant increase in the volume of Mississippi

River water used to cool plant systems. They also indicated that the

temperature of the water returned to River would be increased by

approximately 30F. There is concern about the impact of seasonal

thermal plumes on the nearby and down stream aquatic environment and

on the expanse, quality and duration of the ice cover on Lake Pepin. The

long tradition of commercial and recreational activities (fishing,

snowmobiling and ice boating) on River and Lake ice will surely be

threatened by a further increase in water temperature.

Concern was also voiced about the potential increased intentional or

unplanned releases of radioactive water or chemicals into the River and

the risk of subtle/long-term impacts on the aquatic biome.

Impact on Regional Atmosphere

Documented and un-documented releases of radioactive gases from

Prairie Island facilities continues to be a serious concern for people living

in the ellipse southeast of Prairie Island and lying downstream along the

Hiawatha Valley. The absence of monitoring for radiation plus lack of a

public health base line survey fuel anecdotal rumors of cancer clusters

and worry citizens in this zone.

4-b-AR/SW (continued)

4-c-SE

} 4-d-AR/HH

} 4-e-HH

Ill. Proposal for Monitoring

The recently opened 35W river crossing bridge in Minneapolis establishes

a new precedent for collaborative inspection and continuous independent

monitoring of a facility that poses a demonstrated potential risk to the

public.

CURE proposes that a similar monitoring program be established to -

continuously monitor the discharges from the Prairie Island Plant to

surrounding environment.

We propose that the National Center for Earth-surface Dynamics (NCED -

a research facility established by the National Science Foundation (NSF)

and based at the University of Minnesota's St. Anthony Falls Laboratory)

be engaged to design an appropriate program and instrumentation system

to monitor the PI plant's releases to the environment.

Investigations should include but not be limited to the following:

• Thermal energy added to the river.

" Mapping of thermal plumes and their cycles

* Seasonal anomalies

" Observations of changes to the aquatic biome

ý 4-f-SW

Draft NUREG-1437, Supplement 39 A-25 October 2009
Appendix A

" Continuous monitoring to detect intentional and unplanned

airborne release events of radioactive gasses and particles;

mapping of distribution, concentration and duration of release of

contaminants.

" Monitoring of area Karst formations that are at risk for potential

radioactive contamination of ground water.

" Monitoring of run-off water from the plant and spent fuel storage

sites.

It is proposed that the monitoring program be a collaborative effort guided

by NCED working in cooperation with and supported by XCEL Energy, MN

DNR, MN PCA, area governments, businesses and citizen groups. The

data and analysis of the monitoring systems should be accessible to a

broad spectrum of government, academic, public health and public

interest organizations.

Monitoring equipment should be cost effective and data collection and

transmission automated at an appropriate scale.

t 4-f-SW (continued)

j

October 2009 A-26 Draft NUREG-1437, Supplement 39
Appendix A

The following pages contain the written comments

submitted by Kristen Eide-Tollefson during the scoping period

for the Prairie Island Nuclear Generating Plant

license renewal

Draft NUREG-1437, Supplement 39 A-27 October 2009
Appendix A

PUBLIC COMMENTS: On NRC Environmental Review of Relicensing of

The Prairie Island Nuclear Generating Plant (PING); and Xcels

Environmental Report (ER) - Operating License Renewal Stage PING

(NMC), Units 1 and 2, Docket No. 50-282 and 50-306, License Nos. DPR42 and DPR-60.

DG-1149

To: Rulemaking, Directives and Editing Branch,

Office of Administraton, U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

From: Kristen Eide-Tollefson, Ilealingsystems@ea rthi nk.net,

P.O. Box 130, Frontenac, MN 55026 651-345-5488

Dear Sir,

I am using the CEQ EIS guidelines to fraame my comments. My oral

comments can be found in the evening transcript for the Red Wing

public hearings. The outline of my comments is as follows:

I. Affected Environments

II. Interdisciplinary Approach

Ill.Connected Actions and Cumulative Effects

IV. Baselines

V. Recommended Alternatives

VI. Mitigation and Monitoring

VII. Additional Citations

Thank you for your attention to my comments to the scope of

environmental review.

Kristen Eide-Tollefson

October 2009 A-28 Draft NUREG-1437, Supplement 39
Appendix A

Sec. 1502.15 Affected environment. Th..• envonmenhal inrpact st.te...tsh.ill .orc..ctly

describe the enmlrol enotolthe irea(s) to be affected or created fry the alternatives underconsiderahon. 'he descriptions

S hall he no lon|gerthan is neressary to understand the oft'ecs ni the alterntiuves. Dtata and inalyses In a statementf shall be

IrnrrIren I e 01sruf , thlIe ihhon anras:e ofthl Inllo . witll Ies - lb ~ortla l matenial sun1ali•i ed., c:osors ldaWl , or slinsly

rolerrocd. Ag,• ncies shall avoid useless bulk in statemients and sllal conceotrate e, cortand atlention on ihpohlrtartissue'.

Verbose descriphions of the affected onvironment are thomnslves no mneasure of hbo adoquacy of uan onviromental impact

I. Affected Environment. Defining theiscope of the affected environment is

the foundation of the EIS. The defining of the affected environment either adequate

captures, or inadequately constrains considerations in the EIS. This act of defining

and describing, impacts interested and affected communities and persons. It is

important to interested and potentially affected communities and persons, to be

included in the scope and to have their economic, social and natural resource bases

identified. See also IV. BASELINES.

The scope of the description of the affected environment should not be constrained 5aER

by the requirement for succinctness in the description itself. Succinctness of

description refers to length, not to content.

Prairie Island: The description of the affected environment should adequately

describe the social, environmental, economic and health situation of the Prairie

Island Indian Community. Xcel's ER is inadequate in this description.

Neighboring Communities/Counties: The scope should also adequately describe

the social, environmental, economic and health characteristics of the affected

counties listed in Xcel's ER under 2.6.

Xcel's discussion of the Area Economic Base under 2.6 in its ER is entirely

inadequate to describe the affected social, economic and natural environments of

the directly affected river communities in the listed counties.

2.9 adequately describes planning concerns for Goodhue County. The county is

increasingly looking to the special characteristics of its natural resource base to

define its identity and guide future planning. Many of these resources are sensitive

and require special consideration and planning treatment. The entire river valley 5-b-GW/SW

ledge is highly susceptible to groundwater contamination. Surface water protections

are increasingly important as well, as noted in 2.8. J

50 Mile Impact zone: In addition, the NRC EIS should also either describe or say

why it does not consider communities/counties within the 50 mile potential impact

radius of the plant. Communities are very aware of this radius.

Hiawatha Valley: 'ilhe EIS should particularly concern itself with the affected 5-c-LR

environment -- the environmental, social, economic and natural resource bases--

that are common to the river communities, across and downriver from Prairie

Island. The ecologies and economies of the river valley communities are deeply

Draft NUREG-1437, Supplement 39 A-29 October 2009
Appendix A

interconnected - both between the shoresand along the Great River Road which

runs along both sides of the river, Wisconsin (lHwy 35) and Minnesota (Hlwy 61).

Area Economy: The area's economy is based in large part on tourism, recreational

fishing and other water resource attractions. These economies a re year round, and

are affected by water quality, ice qualities and other features of the river/lake

ecology. The scope of affected environments should extend to the southern end of

Lake Penin at least.

Some of the important common features of the Hiawatha Valley can be found in

materials on:

9 Iliawatha Valley Partnership

vivA /.nextstep.state.mn.us/resdetail.cfm?id=2380 - 14k

o The Great River Road, http://www.mnmississippiriver.com/

* The Mississsippi River Commission

http://www.mvd.usace.army.mnil/mrc/index.php,

" Mississippi River Regional Planning Commission -http://www.mrrpc.com/;

" Minnesota Mississippi River Parkway Commission

www. mnomississippiriver.com Caarol.Zofi@dotLstate.mn,us; and the

* Mississippi Valley Partners business literature.

http://www.city-iinage.com/index.pbp?page=Mississippi-Valley-Partners

Natural resource and waters information, is available from the Department of

Natural Resources (Lake City office), and other commenting agencies.

Sec. 1502.6 Interdisciplinary preparation eironmea• impact statermntU hall be prepared using

all in [oIr- dliscplinary appn-aa stwhich i will Irisrl dil. ill rierated use of the ariaral aid social scierrres arid tire envir lnetld

dusigi acts (ection ie02(2)A] olf the A,11...

II. Interdisciplinary approach. Evaluation of the interdependence of the local

river community economies and ecologies -- the natural and "human environments"

-- requires a fully interdisciplinary approach (see also connected actions and

cumulative effects). The affected river communities should be extended. at least, to

the southern border of Lake Pepin. which is directly impacted by PI.

Special characteristics of PIIC: Analysis must in particular include the effects of

the continued operation of the plant and expansion of the ISFSI upon the special

characteristics of the of the Native American community at Prairie Island. This

includes effects upon spiritual traditions, traditional diet, medicines, psychological

well being and other categories, as defined by the Prairie Island Indian Community.

Sec. 1508.8 Effects. 'l-nyIs" incluhde () Dircmld effect(s rjildi nec csaund ly the action mid ocraur at the smie time rid

place. b) Ildirci cldrccir . wlhiclt nrc cartaci by lire nwlion stil arc lalcir ii rime or finlha remorcd in distiuce, bill mec still recasoiably fore-eatlel. Ildirc eleffcds -aay inclitc eewIlh inrduhcing eficct, arid other c1Te"s-t rl*cld IHo induceii chlnngc, in lir le i•eni oflaued

use. pxoprlalin dtenstly or goereli rate. aind mIrled ehfetinm air midsvrder a i mid dtc ha uratu systenms, incluiding ecosy"tels.

EffeCts and i[npoas as used in Ihma reculationsearc sryntonymusaiarr. 'fl'ls iliclieh ecological irndi sri lire eftfccts n ultirrl rcsoltrcc

ard on tre cornupounnlr . •rucltur-n. mid ftrntlioihg i of alTn ciedcco•n•icmros aenlhetic. hisloric. alti t.l, enouotuic socuilt, t•r hlaltl.

%silier direct indirect. or cumutlative. Eticcts way nIdw uinclude thoree reaultine froni actioes whidi moay have bilth hertictcial mid

detrimental efcn, everen iroi Walatnce [tie ugeurcy elieves that the effct will be hetncficinl.

5-c-LR (continued)

5-d-SE

} 5-e-AR

} 5-f-EJ/RW

October 2009 A-30 Draft NUREG-1437, Supplement 39
Appendix A

See. 1508.14 Humntan end•nri inenat. -innmrrn sirosreit Shall Ir isterprel eros retteasivelyto isirlrl

natural and physical esironmeral andtherel at iosmlip of people with that ertvieonnll . (See the deftnitiot rrf "'efect" (Sec. 150o8.8.)

"nis neantin Ibtrerrori, Iocial t Mr c tfects •se nrt intlended by I htmstnlvcr Io rcipiire peqraraisar of an cnvirtinmcnial intipa.t

statement. Wlen an atviron•enntal impact statement is prepared And econorsic or social and natauI or physical cevironmcnta) effects

are itlicirelatea. dhan the enviroIttmenita inmpact datlcnernt will distarr all of thlc effctUs on the I nll, i 1 ea11 irlaneit

See. 1508.25 Scope: connected. cumulative nd l sinmilar actions. Soopeconsisis of trt ranec of a.cions. alternaties, and irpac, s h0 Ie ottsridetsrd itt sit civironimttln limpact 41idettt1 . Me, rhscorpi oflan indivshtal lalctllntl itay

depend on.its relationlships to other utlatentsri (S¢ta.l 502.20 and 1508.28), To dleTertiate the scope of civimoorl1ntal impact

Msanmamls, agcncies dhall 3 types of actions. 3 types or alter-natices, and 3 types of implats. nthe include:

(a) (a)Actlons (othir lhat uncrmtcclecd single actios) which may becon.nected atlonsn whiclt means ltha they are closely

related And dicrcfort slltcld 1. discussed itl the surtc inipacl s1atencritl. Actlons are coinr read If they: (I) Atloll•talillsy

Irigget ol htr aciIonr which may reqaptre r•alron•reatatl hnap1 A alatrtes, (. t ) a .lt ra . will nat prn•ceed tthts

oltrti actIons are takeln previously or stularatt osly. (1tt) Are trl~rtirmrteper |rarts oa A larr, action nitd tiepelnI

ar the larger action for their jatslltnllon.

(b) Crmiinaut1na actions. which whaht iewed witt oher proposed actions i]ave cumulatively significant imapacts And shonid

therefore be discussed in th t sam ao itmpact statement.

(c) Shlrllhr arltions. whinch hMis.ed en wilt other re-ably forcsenahle o prrorposcd agency acliotin, have similarities Ihal

provide a basis for eraluatlie tchir environmental consequan.mrics together. such as commntna timing or •eognmphy. Ail

agency may wish to arrnlaze these actions in the sam, impact sratlcretat. It shoald do so wttn ire best way to assess

rdelrlrrtey Ibt ¢rnhirncrtid irmrpacts of similar actions or renorr atillaialives lor sltt nciorirs is to treat the•t ill a single

itmpact statemaent

(d) (b) Aiertnattves. whidt include: i. No action thernative. ii. Other reasonable courses of adisas iii. Mititation measures

(,lot itt tire prpolcdtaim)t.

{tr) (r Irmparls., hiv h may be: (i) DIrer): (2) ttdrrert: 13) rrrumulals.

See. 1508.7 Cumulative impact. "Cumulative ipptict" is thI impact on the etivii(attent which results bonm the

nacrunrnlal inma of Ihli action simi wklh IArto r stte , p. rsti. aNrd rlably firesesaile fut-re acliont regardle•s of wlrat

agency (F;ederal or oImi-Feodcli or pers•ns atndertale•e arch other actioni. Cututalative impacts can resli from indtictually minsor tar

collar.1ively stiguificsrl actiorat laking plice over a prMii Iof lime.

Ill. Connected Actions and Cumulative Effects: There are at least 4

pending actions which constitute connected actions and have cumulative effects

upon these interdependent systems. These are identified below, and should be

analyzed accordingly, We will need to depend upon the expertise of others to clarify

the relationship of these actions to the 3 types of actions, impacts and alternatives

listed in 1508.25, and addressed in the handbooks. The following chart gives an

example: www.seeda co.uk,'RES for the South East 2006-2016/docs!Ann•exF-031106.doc -

The scope of these particular comments should not limit definition and analysis of

cumulative impacts, nor the definition and scope of the connected actions, They are

merely a starting point which the affected and interested local governments should 5-g-Cl/LR

expand upon. Please confirm that there will be an onoortunity in the comment

process for these affected communities to address cumulative effects and connected.

cumulative and/or similar actions as defined in Sec. 1508.25. Please clarify how that

will work.

A. Connected, Cumulative or Similar Actions affected by the PING application.

linvirontmental review under NEPA requires that the potential impacts of related

actions present or future, and their cumulative effects, be described and analyzed. 5-h-Cl

These actions need not be permitted by the same agency. The following actions, I

Draft NUREG-1437, Supplement 39 A-31 October 2009
Appendix A

specifically, are connected to the relicensing of Prairie Island and will be reviewed

by both state and federal governments.

Our argument is that the timing of these reviews and the "departmentalization" of

the actions is harmful, and blocks adequate EIS analysis of these federal actions, and 5-h-Cl (continued)

undermines adequacy of the SI.ER for relicensing. The connected, cumulative and/or

similar actions listed below need to he evaluated as connected/cumulative or

similar actions and their cumulative effects upon the affected environments must be

evaluated. All are dependent upon and interconnected with the NRC relicensing

review and permit:

1. UPRATE - Certificate of Need Extended Power Uprate - PlJC Docket E002/Cn-08-

509. Without the extended license there will be no uprate. The license renewal

safety review and aging reactor review MUST consider the cumulative effects of the

uprate temperatures and pressures upon: a) thle safety of the aging reactor, over

time, and b) the cumulative environmental and socio-economic effects of increased

temperatures on the ecology of the lake; c) new fuel types; d) additional emissions

(if any) and timing and frequency of those emissions; e) other concerns raised by

other parties, particularly the Prairie Island Indian Community (PIIC).

Scenarios: These assessments should be done for various water level scenarios on SiOS

the ecology of the lake, and consider potential cumulative effects of warming

temperatures (global climate change), with heat and emission factors from the

uprate. Climate change effects, including temperature and water, are likely within

the period of relicensing. This analysis should expand upon water demand, quality

and shortage concerns for the area in addressing these scenarios.

2. Site Permit Extended Power Uprate - PtIC Docket Eoo2/GS-08-690. Without

relicensing, there would be no site permit process. And it is the location of the

uprate, at the PI facility, that creates the context for the connected actions and their

cumulative effects upon the affected environments.

3. Additional Dry Cask Storage Certificate of Need PUC Docket E002/CN-08-510.

Additional dry cask storage is needed to accommodate waste from relicensed

reactors. There is no federal plan for this waste. It is therefore, reasonably speaking,

beyond the reach of the confidence decision, regardless of its wording. Even if NRC

judges, as it must, the adequacy of the confidence ruling, this does not eliminate the

need to address the effects, as connected/cumulative/similar actions in the F.IS.

There are a number of related actions that reach beyond the current license and 5+RW

relicensing period that involve decommissioning, long term storage of wastes at the

reactor site, and an unspecified set of scenarios including federal actions (take title;

regional interim storage etc) that impact the affected communities and local

governments. While we have no illusions that we will significantly change the way

in which NRC has delt with this issue in the past, there are specific impacts that we

October 2009 A-32 Draft NUREG-1437, Supplement 39
Appendix A

would like addressed in the EIS that have to do with future funding, land use, and

responsibility for at reactor site waste management. These socio-economic factors

directly affect local governments, and it is not reasonable that they should not be

addressed at the point of relicensing. Others may have other requests.

Commitment of Resources: Local governments have ultimate responsibility for

the safety and well being of their communities. They must define and defend their

interests, as it relates to any actions or non-actions affecting their economic, social

and natural environments. The lack of resolution of the storage issue, in the context

of NRC extension of uprate, license and cask storage permits, creates significant

burdens for these local governments, including but not limited to PIIC. These

impacts include lobbying, time, money and expertise needed to provide adequate

local oversight of the issues and respond to utility, state and federal initiatives.

Local Government Impacts: Most importantly, where these local governments are

unable or unwilling to commit resources to provide for the representation and

defense of these interests, the intention of NFPA for public involvement, and a

number of other NRC, state and federal principles - is undermined.

Funding scenarios: Like NRC, the ability of local governments to 'do their job'

depends upon funding. Should NRC's or DOE's funding continue to be reduced, or

should fail - or their ability to perform adequately to their mandate be undermined

by funding shortages, the primary burdens for protecting the safety and well being

of the affected communities falls to their local government. It is in the context of die

cumulative effects of current, and future actual and potential failures of funding

(this includes Yucca Mountain) for the NRC/DOE mandates related to waste

management, that the unresolved waste issue must be addressed in the EIS. See:

www.naruc.org/Resolutions/Nuclear%20Waste%2ODisposal.pdf

Xcel's responsibility: While Xcel, under the federal waste contract, is responsible

for the waste until the federal government takes it, Xcel has provided for no

mechanisms to ensure the responsible management, monitoring, or funding of

indefinite storage; nor has Xcel done contingency planning in the event of federal

funding shortages or failure. In fact, Xcel has continued to claim in related dockets

that the waste storage is temporary and that their responsibility is subordinate to

that of the federal government, despite the clear terms of the contract title. Neither

PIJC, nor NRC, nor DOE has addressed this gap in responsibility. And none of the

'responsible' entities has provided a reasonable set of factors, funding or timeline

for the facility and cask replacement recommended by DOE, at each 50 to 100 years.

No-Action: Because there is no federal plan for waste from relicensed reactors,

there is no timeline for removal, no specified place for the waste to go, and no

known facilities/cask replacement timeline, tihe cumulative effects of indefinite

storage should be assessed.

5-j-RW (continued)

}5-k-OS/RW

5-1-OS

5-m-CI/RW

5-n-RW

5-o-CI/RW

Draft NUREG-1437, Supplement 39 A-33 October 2009
Appendix A

Deterioration factor Impacts line up for Ph. The engineering studies for the Yucca

Mountain D/EIS use 3 factors to evaluate the vulnerability ofthe designated regions

to the effects of the no action (indefinite at reactor site storage) alternatives:

proximity to populations, amount of precipitation, and the freeze thaw cycle, which

are the primary factors in cask and facility deterioration rates. All three of these

factors are present at Prairie Island.

Impact on commitment of resources, land use: The waste from the original

license period is scheduled (in the YM queue) to be gone @2045. At this point the

casks with waste from the initial license period/ISFSI will he between 40 and 50

years old. According to the Yucca Mountain DEIS timeline, this is also the point at

which breakdown of containment could begin. The pool will be @ 70 years old.

With the casks gone, the site could be restored as early as @2045. If the plant is

relicensed, then the site cannot he restored. Because it is so close to the business

and residential environments of PIIC, the condition of the site will affect the quality

of the environment in which they are doing business and residing. Indefinite storage

creates an unacceptable level of unknowns and will not only deprive the Community

of a restored environment, but will require expenditures related to due diligence

and necessary vigilance in overseeing and responding to conditions at the storage

site, These burdens threaten the quality of life and economic vitality of present and

future generations.

NEPA requirements: While NRC Rules allows these actions to be analyzed in a

vacuum, NEPA and CEQ rules (arguably) do noL These actions can have significant,

ongoing and cumulative effecLs upon the economies and ecologies, security and

health of the area; and particularly upon future generations.

IV. BASEL] NES [7 oefine a baseline condition for the resources, ecosystems, and

human communities. ]. The following baselines (at least) need to be established for the

assessment of cumulative impacts, and to allow for meaningful monitoring of the

affected environment into the future. These comments should in no way limit the

work of EIS analysts, or the types and numbers of baselines to be established.

Blaselines need to be identified and represented in an accessible way; the data and

analysis should be understandable to community members and local officials.

A. Groundwater baseline: Minnesota statute provides parameters for

groundwater protection, that require a baseline to he established.

116C.76 NUCLEAR WASTE DEPOSITORY RELEASE INTO GROUNDWATER.

Subdivision 1. Radionuclide release levels. Radioactive waste management, tacilities for

spent nuclear fuel or high-level radioactive wastes mnust be designed to provide a reasonable

expectation that the undisturbed performance of the radioactive waste management facility

will not cause the radionuclide concentrations, averaged over any year, in groundwater to

exceed:

5-p-RW

} 5-q-CI/LR

5-r-CI/LR

October 2009 A-34 Draft NUREG-1437, Supplement 39
Appendix A

(1) five picociries per liler of radiuni-22r, atnd radiuin-228;

2) 15 picucLries per liter of alpha-emitting radionuclides including radiunt-226 and

raditunt-228, but excluding radon; or

(3) the combined concentrations of radionuclides that emit either beta or gamina radiation

that would produce an anntal dose equivalent to the total body of any internal organ greater

than (our miillireins per year if an individual consumed two liters per day of drinking water

front dte groundwater.

StboI 2. Disposal restricted. The location or construction of a radioactive waste

management facility for high-level radioactive waste is prohibited where the average annual

radionuclide concentrations in groundwater before constnrction of the facility exceed the

limits in

subdivisionu 1.

Subd. 3. Protection against radionuclide release. Radioactive waste management facilities

roust be selected, located, and designed to keep any allowable radionuclide releases to the

groundwater as low as reasonably achievable.

History: 1986 c 425 s II

Epri: "Groundwater Protection Guidelines for Nuclear Power Plants,

2008." www.epriweb.com/public/000000000001016099.pdf

B. Historic cancer rates for Goodbue Dakota, Peirce, arid Wabasha

Counties through 2006. We have been unable to access these statistics.

C. Thermal conditions south of Pl to the southern border of lake Pepin.

D. Fish populations south of PI to the southern border of Lake Pepin 5-r-CI/LR (continued)

In addition, the following information would be useful to local communities in

understanding the 'baseline' trajectory and flux of emissions/releases over time.

Without historic information, current information can be unduly alarming, and

difficult to evaluate:

LAir emission releases (See CURE comments), historic, through 2007

2. Thermal discharges, historic through 2007

3. Effluent discharges - type, timing and frequency, historic through 2007

4. Tritium discharges, historic through 2007.

Table 1-5. Steps in cumulative effects analysis (CEA)

to be addressed in each component of environmental impact assessment (EIA)

Scopina

1. Identify the significant cumulative effects Issues associated with the

proposed action and define the assessment goals.

2. Establish the geographic scope for the analysis.

3. Establish the ttme frame for the analysis.

4. Identify other actions affecting the resources, ecosystems, and

human communities of concern.

Describino the Affected Environment 5. characterize the resources, ecosystems, and human communities

Draft NUREG-1437, Supplement 39 A-35 October 2009
Appendix A

Environment identified In scoping In terms of their response to change and capacity to withstand stresses.

6, Characterize the stresses affecting these resources, ecosystems, and

human communities and their relation to regulatory thresholds,

7. Define a baseline condition for the resources, ecosystems, and

human communities.

Determining the Environmental

8. Identify the important cause-and-effect relationships between human Consequences activities and resources, ecosystems, and human communities.

9. Deternine the mognitude and significance of cumulative effects.

10, Modify or add alternatives to avoid, minimize, or mitigate significant

cumulative effects.

1t. Monitor the cumulative effects of the selected alternative and adapt

management.

httr/xorf~od nin aov/Envirornmental+Protection/NEPA.EnvironmentalAssessments hitn

5-r-CI/LR (continued)

V. Recommended Alternatives:

1. Replacement Option: Combined technologies, specifically wind paired with

existing/refurbished eas facilities should be the primary haseload alternative

evaluated by Xcel. Xcel's gas fleet is aging. Its assessment of refurbishment should

maximize opportunities for gas/wind combinations, optimizing flexible use of these

facilities and avoiding the costs and climate impacts of new gas plants.

2. Conversion option: An energy and R&D park at Prairie Island, would he a

conversion option for the P1 site and plant. It would utilize existing equipment, add

modular generation and take advantage of the transmission at Ph. Ilydrogen could

be generated during off peak hours and P1 could become a hydrogen fueling and

experimental station, among other R&D projects. This would bring an alternative

selection of high paing 'green' jobs into the area, develop new capacities and provide

opportunities to capture funding opportunities as new federal energy initiatives

unfold.

1502.22 - Incomplete or unavailable information.

When on egency is evaluating reasonably foreseeable significant adverse effects on the humen environment in an

environmental impact statement and there is incomplete or unavailable information, the agency shall always make clear

that such information is lacking.

(lo lithe incomplete information relevant to reasonably foreseeable significant adverse impacts is essential to o reasoned choice among alternatives and the overall costs of obtaining iloare nol exorbitani, the agency shall include the

information in the environmental impact statement.

*(b) If the information relevant to reasonably foreseeable significant adverse impacts cannot be obtained because the overall costs of obtaining it are exorbitant or the means to obtain it are not known, the agency shall include within the

environmental impacr statement: (1) A statement that such information is incomplete oa unavailable: 12) a statement of the relevance of the incomplete or unavailable information to evaluating reasonably foreseeable significant adverse impacts

on the human environment: (3) a summary of existing credible scientific evidence which is relevant to evaluating the reasonably foreseeable significant adverse impacts on the human environment, and (4) the agency's evaluation of such impacts based upon theoretical approaches or research methods generally accepted in the scientific community. For the

} 5-s-AS

f 5-t-AS

5-u-LR/OS

October 2009 A-36 Draft NUREG-1437, Supplement 39
Appendix A

purposes of this section. reasonably foreseeable includes impacts which have catastrophic consequences. even if their

probability of occurrence is low. provided that the analysis of the impacts is supported by credible scientific esidence, i%

not based on pure conjecture. and is within the rule of reason.

(c) The amended regulation will be applicable to all environmental impact statements for which a Notice of Intent (40

CFR 1508.22) is published in the Federal Register on or after May 27, 1986. For environmental impact statements in

Progress, agencies may choose to comply with the requirements of either the original or amended regulation.

While the "foreseeable future" is difficult to define with nuclear waste, the scope of 5-u-LR/OS

incomplete and missing information regarding the fate of waste from relicensed (continued

reactors is significant. There is no rational plan, no maintenace or facility

replacement schedule for relicensed reactors at Monticello or Prairie Island. There

is no contingency planning; no scenario development. The missing information is

not only factual, but procedural. This situation should be described, and elaborated,

under this section of the EIS.

VI. 1508.20 Mitigation and Monitoring: rtbiinaa, nrincd let Avoidirg IlIr inrpucl ll0unther Iy aI takirg, a •C•r1io autior W 1 f lu - rur II arc-r f.

(h !Mirlirnizmrlur inrpaor by liertirnrg due dt•rec Ior nAnitrlde ortl Rfaw aind iti irrpll rurntlrtiuur

(o Rmliltyirn tireh iaupart b refpairoing. rrchabililarinn. un rcuurrum din uffact cmru inrortl.

( dl K h ,l) rr, n fu lin'irlting tim imr1 -1t ,,or ima b, lvrum•.m','al 1r rI il- teflcbifynlriuf b . til Ih t lbe actimu

lt fuai-IlR tor dit impact hyreplirinr lw pr•- idinr Alidilturto rm•-arceu re cr-undi nllrtl

From the perspective of a planning commission member in a downriver community

that is part of the affected environment of the PING, the most useful kind of

mitigation to consider in conjunction with relicensing the plant, is an exploration of

long term joint stakeholder mechanisms would allow affected communities and

local governments to participate meaningfully in the ongoing decisions involving 5-v-LR

PING. Several references are included below.

"Stepwise approach to decision-making for long ternm radioactive waste'.

www.nea.frllltmlirwý!i/relorts/20041/tea4429-stepwise.pdf

"Uncertainty, innovation, and dynamic sustainable development (applied to nuclear

waste)" Lenore Newman School of Environment and Sustainability, Victoria, B.C.,

Canada V9B 5YZ(e-mail: letnore.newman@royalroads.ca) http:!!ejournal nbii or?/archtives/voll ia-s2/OlSO1-.111newmctn htrnl

VII. Citations: The following set of citations from CEQ rules is included for the

benefit of other public commentators. For NRC, the inclusion ofthese sections

creates a framework of our expectations regarding the importance and scope of

connected/cumulative effects analysis (CEA). We have used primarily CEQ 5-w-CI

references since this is the standard that NRC uses:

Table 1-2 Principles of Cumulative Effects Analysis

Draft NUREG-1437, Supplement 39 A-37 October 2009
Appendix A

Curuatcive Imlpacts ore caused by the aecreeme of past. presentL mid reasonably foreseeable fdture ictimos.

The effects of a proposed action on a given resource, ecosystem, and human community include the present and

future effects added to the effects that have taken place in the past. Such cumulative effects must also be added to

effects (past, present, and future) caused by all other actions that affect the same resource.

2. C"mntleativc effucts are thI trotai effect, tcitu•ing both direct aud indirect c•[cei&ols a given resource,

ecosyree ant. eat hitllrull cau1ulluiiy of oil aodions taken. IsO tou'c Who (ifedeioi, soutfednert. or privarc) lis rakesi fhl acdtios.

Individuaf effects from disparael activities may add up or interact to cause additional effects not apparent when

cutting at the individual effects one at a time. The additional effects contributed by actions "uelated to the peoposec

action must be included in the analysis of cumtlative effects.

3. Clroislative feLucet irced is lie mttlyvzcdt i. feors or filre .ir-cifrc recsolrce. cc•eyorr, rm. d itt hrrinr conisirity hicing, alftetcd.

Environmental effects are often evaluated from the perspective oa tue proposed action. Analyzing cumulative effects

requires focusing on the resource, ecosystem, and human community that may be affected and developing an

adequate understanding of how the resources are susceldible to effects.

4. it IS nost itrcal to droslys tic atmulasise cffccLts of or action otn the tjnive•rs; file ils of cnvirnr•ental ctTeov muist

stocs mri thoe thalt e truly mcstimticli.

For cumulative effects analysis to help the decisionmaker and isform interested parties, it must be limited through

scoping to effects that can be evaluated meaningfully. The boundaries for evaluatng cumulative effects should be

expanded to the point at which the resource is no longer affected significantly w the effects are no longer of interest

to affected parties,

5. Cululadtive effects oiv a given resource, crnzsilsc, aes hitmhman coriarunity e-c surdy aligned wiih political or admunistrativc

htvtruiotscs..

Resources typically am demarcated according to agency responsibilities, county lines, gorting allotments, or other

admtinistrative boundaries. Because natural and sociocultural resources am not usually so aligned, each political

entity actually manages only a piece of the affected resource (W ecosystem. Cumulative effects analysis on natural

systems muot one natural ecological boundaries and analysis af human comnritties must use actual sociocdhtural

boundaries to ensure including all effects,

S. CurIilI•ative effects iay resill t•ror tfie accirltrrtiatriol or simliar effects or dle tv11mieiic inlteractionr of

differen effect. 5-w-CI

Repeated actions may cause effects to build up through simple addition (more and more of the same type of effect)

and the sam, or different actions may produce effects that interact to produce cumulatiue effects greater than the sum (continued) of the effects.,

7. Crimulative oects may ted for mrisny ars, ieysruitd tire lift of the ecdio thatsl cused the effects.

Some actiono cause damage lasting far longer than the life of the action itself (e.g., acid mine drainage, radioactive

waste rontamination, species extinctions). Cumulative effects analysis needs to apply the best science and

forecasting techniques to assess potential catastrophic consequences in the future.

B. Each affected resource, eccoystent, and humanot comanilltity siUrs be atey)rtcd ils rerms of hc capacity

iO acconteodtate oildilitioeel effects, hased ren its crusl time ant space parm•llrcrs,

Analysts tend te think in terms of how the resource, ecosystem, and human comimunty wit be modified given the

action's development needs. The mast effective cumulative effects analysis focuses on what is needed to esoure longterm productivity or sultability of the resource,

Table 1-4 Types of Cumulative Effects

In simplesi terms. cumulative effects may sytncrgistic-where the net adverse cumulative

arise from single or multiple actions and may effect is greater than the stui of the individual

result in additive otr interactive effects. Interac- effects. This combination of two kinds of

tive effects may be either countervailing- actions with two kinds of processes leads to four

where the net adverse cumulative effect is lesu basic types of cumulative effects (Table I-31 see

than the sum of the individual ciTecta-r Peterson et ld. 1987 for a similar typology).

Type 1 - Additive - Repeated "additive" effects from a

single proposed protect.

Example: Construction of a new road through a

national park, resulting In continual draining of

road salt onto nearby vegetation.

Type 2 - Interactive • Stressuors from a single source that Interact with receiving blota to have at "Interactlve"

October 2009 A-38 Draft NUREG-1437, Supplement 39
Appendix A

(nonlinear) net effect. Example: Organic compounds, Including PCBS, that

blomagnify up food chains and exert disproportionate

toxicity on raptors and large mamnals.

t)1re 3 - Additive - Effects arising from multiple sources

(prolects, point 

sources, or general effects

associated with development) that affect

environmental resources additively.

Example: Agricultural Irrigation, domestic consumption, and Industrial cooling activities

that all contribute to drawing down a

groundwater aquifer.

Type 4- Interactive - Effects arising fram multiple sources that

affect environmental resources In an Interactive (I.e.,

countervailing or synergistic) fashion.

Example: Discharges of nutrients and heated water to

a ifver that combine to cause an algal bloom and subsequent loss of dissolved oxygen that is greater than the additive effects of each pollutant.

Criteria. in determining whether a proposed action will or will not 'signsricantty affect the quality of the human

environment." OPOlVs/STAFFDIVs should evaluate the expected environmental consequences oie proposed action by

means of the following steps, utilizing the guidance provided in 40 CFR 1508.27:

Step One -- Identify those things that will happen as a result ofthe proposed action. An action normally produces a

number of consequences. Fur example, a grant to construct a hospital may terminate human services; will Involve

destruction and construction; will provide a service. Actions may be connected, cumulative, or surniner (see 40 CFR

1508.25(a)).

Step Two - Identify the "human environments" that the proposed action will affect. In accordance with 40 CFR

1508.27. the significance of an action must be analyzed In several contexts, such as society as a whole (humsn. nationel).

the affected region, the affected interests, end the locality. The significance of an action will vary with the setting of the

proposed action. Environments may include terrestrial, aquatic, subterranean, and serial environments, such as islands.

cities, rivers or pads thereof.

Step Three - Ideetify the kinds of effects that the proposed action will cause on these "human environmenits "A

change occurs when a proposed action causes the "humen environment" to be different In the future than it would have

been. absent the proposed action. These changes involve the introduction of various "resources" (including those ofen chermcterizedas waste).

Example: A decrease in the amount of soil entering a stream: the introduction of a new chemicat compound to

natural environments.

In addition to organisms, substances, and compounde, the term "resources" include energy (in various forms).

elements. structures, and systems (such es a trash collection service in a city). Present environmental impacts and

reasonably foreseeable future environmental impacts must be considered.

In Identifying changes caused by the proposed action. OPDIVs/STAFFDIVs should identity the magnitude of the

changes likely to be caused within smaller and larger "human environments" affected (e.g.. part of a city, the whole city,

the metropolitan area).

The Impacts resulting from the proposed action may be direct. indirect, or cumulative (see 40 CFR 1508.2Slc)).

Step Four - Idenlify whether these changes are significant. The following points should be considered In conjunction

with 40 CFR 1508.8 (effects). 40 CFR 1508.14 (human environmenl). and 40 CFR 1508.27 ("significantly") in making a

decision concerning significance:

* A change in the characterization of an environment is significant (e.g.. from terrestrial to aquatic.

The establishment of a species in or removal of a species from an environment may be significant

The more dependent an environment becomes on external resources, the larger the magnitude of change

(end the more likely it is to be significant): * The larger the environment under consideration, the lower the amount of change needed before the change may be significant.

The CEO regulations in 40 CFR 1508.27 describe a number of factors that should be considered in evaluating severity

(intensity) of en impact. OPOIVs/STAFFDIVs should consider the cumulative effect of the proposed action. An action may

5-w-CI

(continued)

J

Draft NUREG-1437, Supplement 39 A-39 October 2009
Appendix A

be individualty insignificant but cumulatively significant when the action is related to other echons. Significance exists if it

is reasonable to anticipate a cumulatively significant impact on the environment. Significance cannot be avoided by

terming an action temporary or by breaking it down into small component parts

Sec. 1508.27 SI gnificantly. "s, ifricalry a.o scd irs NtitA rctflirmc considernlions oftih s•ontext and iclcusily:

(a) Context. This mean ltiht the siecitticance of •o nction inti be analyzed in rcver t contets such as diciy asr a whole (human.

national). the affectd rcgiaciL the affecd interests, and the tocaliry. Significance varices vith the seling of theproposed action. For

insncon, in ite case of a sie-sccific aictio, aigriificunce wuild usually deq)ped spurt tite efcts i Ire loalcu reitmo thou in itti world

a.e w .le. 1.• stror-oh sAid Isloit-eti Tle trct, ure .am irt-.

(t) eltnity•. this rcfors to lie m'cmity of irriorasl. Rcsp1 'siblc msfciohs erri boler in nerd liha nimonethan r oe a•1'. Icy may r'ilc

dtsiisers ntsons partial atiicicd ofitmajor ectislo Thre following otou dh co•side'od in es,'atuatoig irretsity:

i titpacts thrt may ble bith benefitcial and adhvers. A sionifficant effect may e•ist even if die Federal agency believes tlia on balance

the effect will he hereficialt

tire sdegree to which e prsr•yrr•se action attiest public health cc safety.

* Unigie claranctristics of the geograplhic aeal sli as proximily to historic or culural resouirces. park lai•d,. prime larnmlrands,

welands, wild and steric rivers, or ecologically critical areas.

STlhe iegree• io which she effctasm the clialityoft•delIiumn envirinmeni are likely to be highly controversial.

P tie d-egree to which stie possible elfects on the hune i envriro•mnel arehighly incrIsain w Ivorlve uiqiue w onkirrmn tin*s. 5-w-CI * The degree to hich tre acicii .. ay estanlisht a rece•leit for titirre actionswiib significart etftelc or represents a decision iii (contnued)

principle about a future considernation.

SWrethertie actimo in relnted to oiher actionswiti indivNiiahy inrigtnricam but cumulativelysipnificit inifacts. Sigiificance

exists ifit is reasrtable to anticipate a su.leratirvely significanr ontact on ade onvironrmmt. Siatifiti•nce cairmno be avoided by

terning air actioni tcnptnTary or by brr•aking it doni ariao small comntinort puts.

* The de•ree to wnhids dh. ats ise mnay aidts ly affect districts, sites. htigm ayn. sinisutrrs oir oliject liste l oirn cliiillc for liting

inl rIse Nationlo Register or Histriric Places or may caosin It or din eenirtion of signfri•lui ioiljtific. criltirl. or historical

rescurces.

* The degree to whets the action tray adversely affect ar endangeriedt oir thiroamonertspecies ort? haebitat lint Iras hew itletennird ito be cilicatl under the Dndsairgered Species Act of 1973.

* Whether the actim hrlatcrs a violation of Fedecra. Sta•e• or tocal law or iesprirectrs imposed for the potectioni of the

envilontei.

Respectfully submitted,

Kristen Eide-Tollefson

II cealine gSystcrnssTheatrltir krtel

P.O. Box 130 Frontenac, MN 55026

651-345-5438/612-33 1-1430

About the commentator: Eide-Tollefson served on the MN Environmental Quality

Board Citizen's Site Advisory Committee for the Goodhue Storage Facility exercise in

1995. After the Florence Township sites were eliminated from consideration, she

continued to work as a citizen advocate in state regulatory and legislative arenas.,

submitting numerous comments on integrated resource planning, and other nuclear

and energy resource proposals.

In 2006 she graduated from the Humphrey Institute MPA program with a

concentration in "Public litgagement in Energy Policy, Planning and Infrastructure

Development". She has served on Environmental and legislative stakeholder and

advisory committees and from 1999-2003, was active in the Nuclear Waste Strategy

Coalition. She is currently a planning commissioner for Florence Township,

Goodhue County. She is, however, not an environmental lawyer or professional and

must depend upon the expertise of NRC professionals in evaluating and acting upon

her comments and recommendations.

October 2009 A-40 Draft NUREG-1437, Supplement 39
Appendix A

The following pages contain the comments

made by Kristen Eide-Tollefson during the

NRC public scoping meetings held on July 30, 2008

Draft NUREG-1437, Supplement 39 A-41 October 2009
Appendix A

MR. RAKOVAN: That was the last card that

I had for comments. If someone else has a comment

that they'd like to make, if you could just come on

up to the mike, and if you could please introduce

yourself.

KIRSTEN EIDE TOLLEFSON: I am Kirsten

Eide Tollefson, and I live in Florence Township, just

down the road a little bit.

I've been reading nuclear documents for

about 12 years and have not, I have to admit, made my

way all the way through this one; but I do have a

pretty fundamental concern that I would appreciate

being addressed by the environmental review.

Under NEPA and environmental review in

general, the consideration of connected actions and

cumulative effects are very important elements to be

reviewed, and there are a number of processes

concurrently happening.

There is the application for the

relicensing; there is the fuel change that was

mentioned; and then there's a fuel upgrade

application, and there's also an extended storage

application. And all of these are being

simultaneously considered by NRC and by the Minnesota

)

5-x-CI

5-y-OS/RW

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS

1323 eIlODE ISLAND AV., N.W.

(20Z 2344433 MLSH-NGTON. D,C. 20005-3701

October 2009 A-42 Draft NUREG-1437, Supplement 39
Appendix A

Public Utilities Commission.

I'm extremely concerned about the timing

of the fuel uprate application. It seems to me that

if the plant is going to be run longer and hotter and

to a greater capacity, that's going to affect -- and

with a different fuel type, that's going to affect

both the operations and the pool storage; it's going

to affect the safety of the pool; it's of course

going to affect the particulars on the long-term

storage of the waste at the reactor site, and I'm

very, very concerned that that fuel uprate be part of

the review of the safety analysis.

And it seems very inappropriate for there

to be significant factors like heat that are not

included in the safety review of an aging reactor.

I'm just very, very concerned about that and, again,

how that also may affect the pool safety.

I'm -- the pool is in the plant, so I'm

hoping we consider that part of operations. But I

realize we might have cordoned it off into storage

areas -- into storage.

I also have a question that I wish I had

asked earlier. It's a concern about what seems to me

to be a changed circumstance in the storage of

5-y-OS/RW (continued)

5-z-NS

5-aa-RW

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND ME, NW

(202) 234-4433 -SHINGTOU D.C, 20053-3701 w.nflkgwstcr

Draft NUREG-1437, Supplement 39 A-43 October 2009
Appendix A

_. 6 2.

nuclear wastes at the reactor site.

If someone would like to explain this to

me later, that would be great, but it seems to me

that the difference in waste -- in the confidence

.decision that waste is safe at a reactor site for 30

years after the closure of the plant, which would, of

course, put it out into the '70s somewhere -- or -- I

have -- I'm not going to add that right now -- there

is -- the difference that it makes is that there's

not a federal plan that I'm aware of for the waste

for the relicensed reactors, and so that confidence

has -- doesn't to me have the same bases as the

confidence that the waste that has already been

generated which is the in queue will have a place to

go.

So none of the waste for the relicensed

reactors has a queue that's in to go anywhere, and I

think that's a significant changed circumstance that

should be considered in this proceeding.

I read the background documents for the

EIS for Yucca Mountain for the no-action alternative.

And these are the engineering studies upon which they

base the recommendation for the no-action

alternative.

)

5-aa-RW (continued)

ii

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RIODE ISLAND AVE., N W.

(20Z 2344433 MSHINGTO, D,C, 20005-3701 w.nIgrossco

October 2009 A-44- Draft NUREG-1437, Supplement 39
Appendix A

The no-action alternative recommended

that any site where the waste -- the no-action

alternative assumed that waste would not be removed

from the site but that it would be there for -- it

may have been 10,000 years. I think that was the

basis. I didn't bring it.

But the three factors that were

considered in that review that made -- that were the

factors for the breakdown of the storage containment

which the EIS recommended be replaced fully every 50

years, there were three factors in the engineering

studies: Precipitation, freeze/thaw cycle, and

proximity to populations.

And I believe that in Minnesota the

precipitation, the freeze/thaw cycle, and the

proximity to populations are an extremely critical

factor.

And so if we have waste that has nowhere

to go, isn't in a queue, and doesn't have a federal

plan for its removal, I would submit that this is a

serious cumulative issue and would like to understand

more how that's going to be handled.

Thank you.

MR. RAKOVAN: Any other comments tonight?

5-aa-RW (continued)

.1

NEAL R. GROSS

COURT REPORTERS AND TRANSCRBERS

1323 RIFOOE ISLAND AE., N.W.

(202) 2344433 SFSUINGTON, D.C20005-3701 ýw.wMkgo.-vwo

Draft NUREG-1437, Supplement 39 A-45 October 2009
Appendix A

The following pages contain the written comments

submitted by Lea Foushee during the scoping period

for the Prairie Island Nuclear Generating Plant

license renewal

October 2009 A-46 Draft NUREG-1437, Supplement 39
Appendix A

From: Lea F'oushee [lfousheeknawvo.orgJ

Sent: Friday- August 22, 2008 4:43 PM

To: PrairielshuidElS Resource

Subject: Testimony additions

I was unable to access the Annual 2007 Radioactive Eflluent Release Reports for Prairie

Island

Nuclear Reactors a timely fashion for the Public Hearing in Red Wing on July 30th. even

after

calling the Minnesota Department of lealth, the Nuclear Management Company, and the

Office

of Public Assistance at the Nuclear Regulatoiy Commission.

I have been told a multiple of excuses of why these "routine"

documents were not posted on the ADIAMS electronic website, perhaps the most

disturbing is

sensitivity screening or scrubbing. The VP of Plant Operations. Mike Wadley sent them

to ne

immediately "the morning aller" the Public Hearing was over. After reviewing the

actual

documents. I realize the "why" of their lateness and lack ofavailability. There was an

undetected

gaseous radioactive leak that went on for six months. There was an additiond failure that

caused

a liquid release in 2007. The ntdioactive efflUents reported in both abnonnal releases to

the

environment were extrapolations. NMC

Engineering staffcalculations. In 2006 during a routine refuLeling

cycle there were 10 abnomial releases of radioactive effluents due to breaking reactor

parts.

lThe NRC stalTprofessed that no number scnubbing would ever be done by them, but if

Utility

staft'has to make them up. the numbers are effectively scrubbed, and we will not know

what

the real releases to the public health and environmenl may have been.

Additionally I was assured (Nathan Goodman) that a real Envirotunental Justice analysis

would

be performed for the plant specific EIS. If this is in fact correct the point of origin ofthe

uranium

ore and its fabrication into futel, and the ultimate disposal of all radioactive w\vastes

generated

nunst be included.

Furthemliore we were assured.promnised (Brian -- Our Regional Director) specific

monitoring of

6-a-HH

6-b-EJ/UR

6-c-HH

Draft NUREG-1437, Supplement 39 A-47 October 2009
Appendix A

the routine radiation effluent releases would be done, including isopleths dispersion to

detennine

where tie hundreds and sometimes thousands odcuries of radiation actually goes in our

envi ronment.

Lea Fousthee

North American Water Office

Lake Elmo. MN 55042

} 6-c-HH (continued)

October 2009 A-48 Draft NUREG-1437, Supplement 39
Appendix A

From: Lea Fouishee [lfoushee&Nawo.org]

Sent: Monday. September 22, 2008 11:52 AM

To: Prairielshdlud'IS Resource

Subject: Fwd: DG- 1149 Prairie Island FIS scoping

Sorry if this is a duplicate submission there was no advisory sent to me when the broken

linkpwas

repaired. I have however added additional points in this submission from the earlier

email that

was sent.

Begin forwarded message:

From: Lea Foushee <lfousheed;Nawo.org>

Date: September 21, 2008 9:05:27 PM CDT

To: NRCREP:',•'nrc.gov

Subject: Fwd: DG-1 149 Prairie Island EIS

lBegin forwarded message:

From: Lea Foushee <lfoushleel•nawo.org:-

Date: September 21, 2008 8:11:43 PM CIYI'

To: NRCREPqnrc.gov

Subject: DG-1149 Prairie Island EIS

These comments are in addition to the verbal testimony given on

July 30. 2008 at the Red Wing Public Hearing on the Relicensing

of the Prairie Island Nucular Phuit as well as a written information

sheet that NAWO was requested to produce by the public on

Tritium. The document was given to the Ilearing Record Court

Reporter, and is titled Health Risks of Tritium.

I was unable to access the Annual 2007 Routine Radioactive Effluent Release

Reports for Prairie Island Nuclear Reactors in a timely fashion for the Public

Hearing in Red Wing on July 30th, even after calling the Minnesota Department

of Health. George Johns. the Nuclear Management Company staff person, Amy

Hass, both her office line and cell phone. and the Office of Public Assistance at 6-d-HH

the Nuclear Regulatory Commission. Scott Bumell. I have been told multiple

excuses why these "routine" documents were not posted ott tile ADAMS

electronic website in advance of the Relicensing Hearing. perhaps the most

disturbing was sensitivity screening or scnrbbing. It was made abundantly clear

Draft NUREG-1437, Supplement 39 A-49 October 2009
Appendix A

that I would not be given access to this document before the Public Ilearing was

over.

The VP of Plant Operations. Mike Wadley sent them to me immediately "tlie

morning after" the Public Hearing was over. too late for questions or media

coverage of the contents. Afler reviewing the actual documents, I realize the

"why" of their lateness and lack of availability. There was an undetected gaseous

radioactive leak that went on for six months that released 3.000 cubic feet of

radioactive gas (extrapolation). '[here was an additional failure that caused a

liquid release in 2007. The radioactive effluents reported in both abnonnal

releases to the environment were extrapolations, NNIC Engineering stall'

calculations. The NRC staff professed that no number scrubbing would ever be

done by them, but if Utility staffhas to make them up, the numbers are

effectively scrubbed, and we will not know wshat the real releases to the public

health and environment may have been. In 2006 during a routine refueling cycle

there were 10 abnormal releases of radioactive effluents due to breaking reactor

parts.

It is also disturbing that there is no longer a total number calculated for number of

curies per year from the reactors in question of all isotopes released in the annual

radioactive effluent release report document contrary to previous years. A lay

person must calculate scientific notation across all releases and quarters to get a

total number of euries released. A site specific EIS must contain total curies for

all Routine Radioactive Effluent Releases (solid, liquid and gaseous) since the

opening of the facility and projections for potential minimum and mnaximumn

releases for the additional yezus that the facility is requesting operations into

the future. There must be a discussion about the total radioactivity released that is

remaining, still circulating in the environment from those historic releases, and

where the concentrations of slich releases have been deposited. Without this

information provided the document is inadequate in tem.s of identifying health

risk to the public ,as well as other living creatures. Furthennore we were

assuredipromised (Brim I lolian. Our Regional Director) specific monitoring of

the routine radiation effluent releases would be done in a site specific EIS for

Prairie Island. including dispersion isopleths to determine where the hundreds and

sometimes thousands of curies of radiation actually go in our environment.

Additionally I was assured (Nathan Goodman) that a real Environmental Justice

analysis would be perfomied for the Prairie Island plant specific EIS. If this is in

fact correct, the entire nuclear fuel chain must be assessed for the specific

additional exposure risks including the point of origin of the uranium ore and its

enrichment and fabrication into fuel, transportation of the fuel. and the ultimate

transportation and disposal of all radioactive wastes generated throughout the

relicense period. TIhe risk of radiation exposure to Indigenous Peoples. other

6-d-HH (continued)

6-e-HH

+

6-f-EJ/RW/UR

October 2009 A-50 Draft NUREG-1437, Supplement 39
Appendix A

Communities of Color. and economically disadvantaged individuals from this

expansion far exceeds the fifty mile radius proposed for such an analysis. The

filly mile limitation biases the Environmental Justice analysis and excludes many

impacted EJ Communities whose health will be affected by this proposal.

Lea FoLshee

North American Water Office

Lake Elmo, MN 55042

} 6-f-EJ/RW/UR (continued)

Draft NUREG-1437, Supplement 39 A-51 October 2009
Appendix A

The following pages contain the comments

made by Lea Foushee during the

NRC public scoping meetings held on July 30, 2008

October 2009 A-52 Draft NUREG-1437, Supplement 39
Appendix A

have.

CAROL OVERLAND: Then what can I say?

LEA FOUSHEE: I'm Lea Foushee. I work

with the North American Water Office, and we've been

involved with this Prairie Island process for over 25

years, and we did not receive a notice either.

Just to make it very clear that those of

us that have been working on this reactor site

historically have not received notice from the NRC

period.

I got a copy of the NRC notice from

another anti-nuclear organization in Washington, D.C.

They said, "Hey, do you know about this?"

And I said, "Well, yeah, I do, but not

because they told me about it."

MS. FRANOVICH: You're talking about the

notice for the public meeting?

LEA FOUSHEE: I'm talking about the

notice for this meeting, this --

MS. FRANOVICH: For the meeting.

LEA FOUSHEE: This -- right.

MS. FRANOVICH: I understand.

LEA FOUSHEE: And we are in the 50-mile

zone for an environmental justice notification, and

6-g-LR

K 6-g-LR (continued)

NEAL R. GROSS COULRT REPORTERS AND TRANSCRIBERS

1323 ROODE ISLAND ME, NW.

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Draft NUREG-1437, Supplement 39 A-53 October 2009
Appendix A

------- 39ý

I'm the Director of Environmental Justice for my

organization and I did not receive any kind of notice 6-g-LR (continued)

3 whatsoever.

4 MS. FRANOVICH: Okay. Thank you.

MR. RAKOVAN: Any further questions?

6 Okay. You want me to come to you or --

JEFF ERPINE: Jeff Erpine. I'm just a

resident.

I was wondering as far as Units 1 and 2

1 are concerned, will there be any talk about the

11 critical components they're talking about as far as,

12 like, the aging process, you know, what's being done

13 to manage it?

14 MS. FRANOVICH: Okay. Can you repeat

15 your question? I'm not quite sure I understood you.

16 JEFF ERPINE: Oh, I'm sorry. Will there

1 be a meeting to discuss the critical components?

is MS. FRANOVICH: The critical components

19 that are being evaluated?

2C JEFF ERPINE: Yes, and what's being done

21 to manage the aging process there?

22 MS. FRANOVICH: Right. We just received

23 the application in mid April, and so we're going

24 through the process now of evaluating what's called

NEAL R. GROSS

COURT REPORTERS AND TRANSCRBERS

1323 RHODE SLAND A*e, p.W.

(202) 2344433 eRSHINGTON[ D.Q 20005-3701

October 2009 A-54 Draft NUREG-1437, Supplement 39
Appendix A

42.

I'm Lea Foushee. I'm the Environmental

Justice Director for the North American Water Office.

About two months ago I received an

anonymous letter telling me that the Routine

Radioactive Effluent Release Report for Prairie

Island was not available to the public as it

ordinarily is in May of the following year that the

emissions have been generated.

And I said, "Well, you know, maybe it

will come out later," and so I didn't do anything

about it.

N"

48 hours ago I got a request to update a

flyer that we produced on Monticello when the

Monticello nuclear reactor was being relicensed and

make it specific for Prairie Island instead of

Monticello, and I said, "Well, okay."

And so I went and looked for those

reports thinking that by now it's got to be there,

it's two months later.

It wasn't there. It wasn't there.

Every other year it was there, 2008 -- or

2006 all the way back to 1999. So I downloaded all

those, and so I have all those and it's on my hard

drive.

6-h-HH/LR

I)

NEAL R. GROSS

COURT REPORTERS AND TRANSCRBERS

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Draft NUREG-1437, Supplement 39 A-55 October 2009
Appendix A

...................................... . ..... .................. ............... ............. ...............-. ... 3.

And I said, "Well, you know, let's go see

if we can find the missing report."

So I called the Health Development; they

of course are totally unavailable. And kept calling

them.

And I called and they gave me the name of

the worker at the plant that supposedly deals with

those sort of things, Amy -- Amy what? I can't

remember Amy's last name.

She didn't answer her phone. I left her

a message. She still didn't answer her phone two

days later. I called her cell phone; she didn't

answer that either.

So I called the NRC themselves after

looking over and over again for the missing

information, and I called the Office of Public

Assistance finally and got a warm body. And I was

really surprise, because you ordinarily don't get a

warm body, you get an answering machine.

And they said that I should send them an

email with the request for the information and they'd

send me a link and give me that information that

afternoon.

6-h-HH/LR (continued)

And I thought, "Well, great. Great.

J

NEAL R. GROSS

COURT REPORTERS AND) TRANSCRIBRS

1323 RP005 ISLAND ME, NW

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October 2009 A-56 Draft NUREG-1437, Supplement 39
Appendix A

... . ..................... . . 4 4

Talk about service."

And lo and behold the afternoon came and

went, of course no email. Of course no email.

So I called them back in the morning, and

they of course said that they would have to forward

that request to a man named Scott Burnell.

And said, "Well, how about a" -- "Can I

talk to a warm body? Can I really talk to the guy?"

They put him on the phone. And so I

talked to him, and he said he would talk to the staff

of the project and see what he could do, but there

was -- he was surprised that it wasn't there,

obviously, but there was nothing he could do anyway.

So I ended up talking to J.P. Leous. I

don't -- I don't know who J.P. is, but he told me

that the report was being put through a sensitivity

review.

Now, I don't know what that means or why

the document is two months late and has to go through

a sensitivity review, but in 2006, when it was down

for refueling, there were ten abnormal releases. Ten

abnormal releases.

And the routine radioactive effluent

releases were over 800 curies when they're ordinarily

6-h-HH/LR (continued)

) NEAL R. GROSS

COURT REPORTERS AND TRANSCRUERS

1323 R1ODE ISLhAN AVE-, NW

(202) 2344433 MWS'NGTOND.r, 20m05.3701 ýw .r k~tlrgt=,¢

Draft NUREG-1437, Supplement 39 A-57 October 2009
Appendix A

.......... ....... .. .. ... .. .... .. .. .. ..... .. ...... .... .. .. .. .. . .... .. .. . 4 .5.s

around 500. Some years they have --

have been in the thousands of curies.

So my question is what are

up? What are you covering up? Why

releasing it in a routine manner if

releases?

historically

you covering

aren't you

it's routine

Monticello is already up there, no

problem. Prairie Island, sensitivity scrubbing.

Sensitivity scrubbing.

So that means one of two things to me.

Now, speculation, obviously, but if 2006

was several orders of magnitude more radioactive

effluent releases than normal, I can only hazard to

think what your refusal to release that to the public

in a timely fashion might mean.

I was summarily told that I was not going

to get that information. And there was probably some

not-so-happy feelings about that, but nonetheless I

think I was denied a public document because of where

I work and my history of long-term opposition to this

facility.

Now Andrew, he told me he would get it to

me right away. He was very nice. He said he'd send

me a CD and he'd send me the entire thing.

6-h-HH/LR (continued)

) NEAL R. GROSS

COURT REPORTERS *4O TRANSCRBERS

1323 F1ODE ISLAND AVE., RW.

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October 2009 A-58 Draft NUREG-1437, Supplement 39
Appendix A

So Andrew -- you'd better take a page

2 from young Andrew. He knows how to treat the public. 6-h-HH/LR (continued)

3 Thank you.

4 MR. RAKOVAN: Okay. Next, George

5 Crocker.

6 And again, after George we'll go to Alan

Muller.

a GEORGE CROCKER: Thank you. My name is

$ George Crocker. I'm with the North American Water

I1 Office, and I have a comment for the scope of your

11 environmental review relative to considering

12 analyzing, disclosing environmental impacts of

13 continued plant operation.

14 And the comment that I have relates to

15 the story 'you just heard about routine releases,

16 because I think that the NRC should require Prairie

17 Island and all of the other commercial reactors to

18 document where reported released radionuclides go.

19 Where do they go? I know that you do

20 monitoring. You do a lot of monitoring. If you

21 don't really know what you're looking at when you see

22 all of the little thermal luminescent dosimeter

23 mappings and where the pics are, why you say "Aha,

24 there's monitoring."

NEAL R. GROSS COLIRT REPORTERS AND TRANSCRBERS

1323 *40E ISLAND AVE., N.W.

(202) 234-4433 WASHINSTON D.,. 20005-3701 .wekgus,.we

Draft NUREG-1437, Supplement 39 A-59 October 2009
Appendix A

1 in the same timeframe we had hoped. We were looking

2 to start it around June 30th; it didn't actually

3 start until I believe it was July 22nd. And so we

4 have extended the scoping period to give the public a

5 full 60 days, so I think we've already accommodated

6 that request.

7 And so with that, I just wanted to remind

8 everyone Lance had indicated that there are public

9 meeting feedback forms that were provided when the

i1 meeting first started, so if there are ways we can

11 improve our meetings, make them better, do them

1 differently, please do fill out one of these feedback

13 forms and leave it on the table, or you can mail it

14 to us. The postage is pre-paid. And I know a couple

15 of you have questions; what I'd like to do is go on

16 and close the meeting and then get with you to talk

17 about your questions.

18 LEA FOUSHEE: I want this on the record.

19 MR. RAKOVAN: She wants something on the

2C record.

21 LEA FOUSHEE: The document is Routine

22 Radioactive Effluent Releases.

23 MS. FRANOVICH: Okay. 6-i-ER/HH

24 LEA FOUSHEE: That document -- the

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COURT REPORTERS AND TRANSCRBERS

1323 R4M0O ISLAND AVE., N.W.

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October 2009 A-60 Draft NUREG-1437, Supplement 39
Appendix A

results of that document, the radiation that is

contained in that document is nowhere in the

application to demonstrate that there is anything

relating with radiation and health impact.

MS. FRANOVICH: I understand. Okay.

LEA FOUSHEE: It needs to be in there,

the routine radiation releases from Prairie Island 1

and 2 must be in the environmental impact statement,

and they are not.

And in fact there should be a historical

record, because the radiation doesn't just go away in

a year.

MS. FRANOVICH: I'm thinking that the

plants are required to submit effluent reports

annually to the NRC, so --

LEA FOUSHEE: Yes, but the application

should have a summary of at least the last 10 years,

and certainly the last 20, if possible.

MS. FRANOVICH: Point noted. But just so

you're -- I just want to --

LEA FOUSHEE: But it's not there.

MS. FRANOVICH: I just want to assure you

that the NRC staff, when we go through the

application, the environmental report is a starting

>. 6-i-ER/HH (continued)

6-i-ER/HH (continued)

>- 6-i-ER/HH (continued)

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AV.-, N.W.

(204 2"433 MSHINGTOA, D., 20005-3701 w- nm.Iagm$ ac

Draft NUREG-1437, Supplement 39 A-61 October 2009
Appendix A

The following pages contain the written comments

submitted by Katie Himanga during the scoping period

for the Prairie Island Nuclear Generating Plant

license renewal

October 2009 A-62 Draft NUREG-1437, Supplement 39
Appendix A

Liake City

205 West Center Street

Lake City, Minnesota 55041

(6S[) 345-5383

Fax: (651) 345-3208

wvw.c.lake-cIty.mn,.us

September 10, 2008

Chief; Rules, Directives, and Editing Branch

Division of Administrative Services

Mailstop T-6D59

U.S. Nuclear Regulatory Commission

Washington, DC 20555

0

Chief:

This letter supplements my remarks made at the License Renewal and Environmental Scoping

Review Process meeting for the proposed license renewal at Prairie Island Nuclear Generating

Plant, Units 1 and 2, held July 30, 2008 in Red Wing, Minnesota.

Concerns for the Lake City community that emerged from conversation at meetings of both the

Lake City Utility Board and Lake City Common Council are a follows:

I. Long-term storage of nuclear waste,

2. Thermal impact 'of service water discharge on theMississippi River and Lake Pepini.

We ask thai thebest available water dispersion modeling be used to assess. the natural ecosystem

and cultural impacts of thermal discharge and that there be a plan put in place io mitigate adverse

impacts. What follows is expanded development of our concerns related to thermal impacts. We

recognize Lake Pepin, the Mississippi River, and its tributaries as interacting components of the

world's third largest river system. The thermal plume of any water discharge has potential to

impact:

Vertebrates andjnyArtebgrat_, A thermal plume can have direct impacts such as changes

in distribution of aquatic organisms (e.g. attracting fish to warmer water during winter), or

cause indirect impacts such as increased exposure to predators (e.g. through concentrating

prey fish in warmer waters during winter).

Ice. A thermal plume can affect the characteristics of ice or the length of the ice cover

season on Lake Pepin. It is a. safety consideration, but also cultural. in that recreation on

the ice is a long-standing community tradition that could be altered~because bf safety

concerns.

Distriution of Sediment, A thermnal plume can affect the hydrodyamics of a'river which

}

7-a-AR/RW/SW

7-b-AR/CR/SW

Birthplace of Waterskiing - 1922

-A10IV)

Draft NUREG-1437, Supplement 39 A-63 October 2009
Appendix A

City of Lake City Letrer

September 10, 2008

Page 2

then affect the distribution ofsediment in the immediate channel and downstream. Water

temperature affects the ability of water to carry sediment (colder water can carry more).

The Pollution Control Agency, acting as it is legally required to do under the federal Clean

Water Act, is working to develop a Total Maximum Daily Load (TMDL) for Lake Pepin.

It is a restoration project with set goals for the dose of pollution that the river system can

a adsti ndl 5 bc .scd for spccifik pUIposCs sucL as .:iikilng Wltcr, fishing or swiltlilg.-

Dissolved Oxygen. Water temperature affects dissolved oxygen levels. Increasing water

temperature decreases water's ability to carry oxygen.

Endocrine Disruotors. If a thermal plume interacts with a municipal wastewater discfiarge

plume, organisms (e.g. catfish, smallmouth bass) congregating in the warmer water may be

subject to prolonged exposure to chemicals such as those found in birth control pills. 7-b-AR/CR/SW

Phytoplankton and Zooplankton. Heat can result in increased production of organisms (continued)

that ultimately can lead to a decrease in light and oxygen in the river and in Lake Pepin.

Parasites, Thermal effluent has been reported to influence the prevalence and abundance

of parasites of fish.

As a result of these potential impacts and affects, we ask that changes in seasonal mean

temperature be assessed related to the facility upgrade for the entire dispersion plume, both in the

main channel of the Mississippi River and on each shore of Lake Pepin.

Please feel-freecto contactw.e if-youuhave'any questibns. I can be reached-art(651)34t-5383,

extension 118 or at khimanga@embarqmail.com.

Sincerely,

Katie Himanga

Mayor

October 2009 A-64 Draft NUREG-1437, Supplement 39
Appendix A

The following pages contain the comments

made by Katie Himanga during the

NRC public scoping meetings held on July 30, 2008

Draft NUREG-1437, Supplement 39 A-65 October 2009
Appendix A

. . . . . . . . . . . . .. . . . . .. .. .. . . .. .. ...... . ... . ... ........ . . .. . . . . . . . .

federally-recognized Indian tribe, and as such we

expect to work with the federal agencies, including

the Nuclear Regulatory Commission, on a government4 to-government basis, and we are pleased that the NRC

has approved our request for a cooperating agency for

6 purposes of preparing parts of the -- for the

environmental impact statement for the license

renewal.

We look forward to working with the NRC

1 -over the next two years on this important issue. We

11 will be submitting extensive written comments to the

12 NRC relative to environmental and safety concerns.

13 And I thank you for this opportunity to

14 speak in front of you today. Thank you.

15 MR. RAKOVAN: Thank you, sir.

16 Next will go to Katie Himanga.

17 KATIE HIMANGA: Good afternoon. My name

18 is Katie Himanga. I'm the mayor of the City of Lake

19 City. We're located about 15 miles down river.

20 Thank you for the opportunity to say a

21 few words. The community of Lake City is impacted by

7-c-RW

22 the Prairie Island Nuclear Plant, just as other

23 communities in the area are.

24 The Lake City Utility Board had an

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS

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(202) 2344433 WASHINGTON. DC. 20005-3701

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Appendix A

I............. . .. .- -- _ -- I.........I........I......... .-........... . . . . .1--.1- _ - ... --... ..... .. ._- _- -..- - _- 3.1

opportunity to talk about the license renewal at its

last meeting, and my City Council spoke about it very

briefly this past Monday evening.

And I bring to you the top two concerns,

environmental concerns related to operation of the

nuclear plant and ask that they be considered in

plans for mitigation through this process.

First and foremost the item of concern

for us is the long-term storage of nuclear waste.

The second concern for us is the thermal

impacts of the discharge of water, warm water into

the Mississippi River, and we ask that it be

considered, both the impacts on the Mississippi River

and on the Lake Pepin ecosystem, and also its

cultural impacts such as how it might affect ice, for

example.

And we would ask that the best available

modeling be used to determine what those impacts are

and plans made for mitigation.

Thank you.

MR. RAKOVAN: Thank you.

Next we'll go to Scott Arneson.

SCOTT ARNESON: Thank you.

I'm Scott Arneson, Goodhue County

7-c-RW (continued)

7-d-AR/CR/SW

2

NEAL R. GROSS

COURT REPORTERS AND TRANSCR1E-RS

1323 SIODE ISLAND AVE, N.W

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Draft NUREG-1437, Supplement 39 A-67 October 2009
Appendix A

The following pages contain the written comments

submitted by Mary Jackson during the scoping period

for the Prairie Island Nuclear Generating Plant

license renewal

October 2009 A-68 Draft NUREG-1437, Supplement 39
Appendix A

From: Jackson, Mary [M\ary.Jackson(@CO. DAKOTA.MN.US]

Sent: Monday, September22, 2008 5:19 PM

To: PrairielslandEIS Resource

Ce: Beeman. Michelle: Welsch. Heidi: Chatfield. Kurt

Subject: Prairie Island Relicensing SEIS scoping comments

RE.: Prairie Island Nuclear Generating Plant (PINGP) Re-licensing EIS Scoping

Comments

To Whom It May Concern,

Staff from D)akota County, Minnesota prepared the following comment for the NRC's

consideration,

based on review of the required SEIS scope for relicensing nuclear generation facilities

and the Prairie

Island Environmental Report prepared by Neel Energy.

1) No additional SEIS scope items are suggested.

2) Additional NRC evaluation within the pre-defined SEIS scope is suggested related to

PINGP's

reliance on Mississippi River water for cooling (circulation) water. Xcel E'nergy's

Enviromnental Report

refers to a future federal project near PINGP to correct a long standing navigation safety

issue at Lock

and I)am 3. Ibis lock-and-damn complex is one mile downstream of PINGP and fomnis

Upper Mississippi

River Pool 3. The navigation safely issue is described on the U.S. Army Corps of

Engineers website as

follows:

Lock and Dam 3 is a navigation dam and lock on the Mississippi River 6 miles upstream

from Red Wing. Minnesota. Its position on a bend in the river makes down bound

navigation difficult because of an out drall current that tends to sweep towboats and

barges away from the lock toward the galed part of the dain. The out drall current lha,

resulted in many accidents, including II incidents since 1968 when tows collided with

the

gated part ofthe dam. A related problem is with the low and weak embankments on the

Wisconsin side.

Navigation accidents can render the four roller gates inoperable, resulting in overtopping

and erosion of the embankments. The three Wisconsin side embankments divide the 8-

fool head at the dam into three steps and work together as part of Lock and Dam 3.

Failure

of the embankmient system could result in accidental drawdown of Pool 3 with significant

econonmic and environmental consequences.

The Corps has stated that without repair, the Wisconsin embankments at Lock and Dam 3

are

likely to fail within the decade. causing a rapid drawdown of Pool 3. The project to

correct the

8-a-AR/PA/SW

J

Draft NUREG-1437, Supplement 39 A-69 October 2009
Appendix A

Lock 3 approach hazard and strengthen the enibmikinents currenty is in design and is

partially

funded. Ilie Corps' websile indicates that the project is programmed for 2010-2017

eontstruction,

Although Ncel's Environmental Report notes the existence of this issue and the Corps*

repair

project, it did not identify impacts of an accidental loss of its Pool 3 cooling water supply

to

PlNGP. how these impacts wotuld be addressed, and possible subsequent impacts to local

comrtttunities and the region.

"lhank y'ou for the opportunity to comment on the relicensing process.

Sincerely.

NMary Jackson

Senior Planner

Dakota County Office of Planning and Analysis

952-891-7039

8-a-AR/PA/SW

(continued)

October 2009 A-70 Draft NUREG-1437, Supplement 39
Appendix A

The following pages contain the comments

made by Ron Johnson during the

NRC public scoping meetings held on July 30, 2008

Draft NUREG-1437, Supplement 39 A-71 October 2009
Appendix A

of Minnesota's electric power supply system for

another 20 years; and

3 "Be it further resolved that the City of

4 Red Wing will present a copy of this resolution to

the Nuclear Regulatory Commission.,,

Thank you.

MR. RAKOVAN: Thank you, sir.

Next we'll go to Ron Johnson, followed by

Katie Himanga and Scott Arneson.

1 RON JOHNSON: Good afternoon. My name is

1i Ron Johnson. I'm president of the Prairie Island

12 Tribal Council and the Prairie Island Indian

13 Community.

14 I've represented my community for several

1i years, and as president I have the obligation to

16 ensure the health and welfare of the community, which

17 includes also the environment down there. 9-a-LR

18 I'm here today as the continuing

19 operation of the Prairie Island Nuclear Generating

20 Plant is one of our most important issues for our

21 community. In fact, most community members have had

22 concerns about the plant since it went online in

23 1973.

24 The Prairie Island Indian Community is a

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 lOODE ISLAND AW., N.W

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October 2009 A-72 Draft NUREG-1437, Supplement 39
Appendix A

federally-recognized Indian tribe, and as such we

expect to work with the federal agencies, including

the Nuclear Regulatory Commission, on a governmentto-government basis, and we are pleased that the NRC

has approved our request for a cooperating agency for

purposes of preparing parts of the - - for the

environmental impact statement for the license

renewal.

We look forward to working with the NRC

over the next two years on this important issue. We

will be submitting extensive written comments to the

NRC relative to environmental and safety concerns.

And I thank you for this opportunity to

speak in front of you today. Thank you.

MR. RAKOVAN: Thank you, sir.

Next will go to Katie Himanga.

KATIE HIMANGA: Good afternoon. My name

is Katie Himanga. I'm the mayor of the City of Lake

City. We're located about 15 miles down river.

Thank you for the opportunity to say a

few words. The community of Lake City is impacted by

the Prairie Island Nuclear Plant, just as other

communities in the area are.

The Lake City Utility Board had an

9-a-LR (continued)

2

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIERS

1323 IRIODE ISLAND AVE., NW.

(2o2) 2344433 ASl'NGTON. D.C 20005-3701 ý.Mkgmwc_

Draft NUREG-1437, Supplement 39 A-73 October 2009
Appendix A

The following pages contain the written comments

submitted by Gina Lemon during the scoping period

for the Prairie Island Nuclear Generating Plant

license renewal

October 2009 A-74 Draft NUREG-1437, Supplement 39
Appendix A

Leech Lake Band of Ojibwe

Arthur "Archie" Larose, Chairman

Mike Bongo, Secretary/Treasurer

District I Representative District II Representative District IIl Representative

Robbie Howe Lyman L. Lash Eugene "Ribs Whitebird

September 9, 2008

Chief, Rules and Directives Branch "73 ]/ ,

Division of Administrative Services, MS T-6D59

US Nuclear Regulatory Commission -- :-

Washington, DC 20555-0001

RE: Proposed License Renewal for Prairie Island Nuclear Gen•rating Plant

Goodhue County, Minnesota -

LL-THPO Number: 08-169-NCRI

To Whom It May Concern:

Thankyou for the opportunity to comment on the above-referenced project. It has been reviewed

pursuant to the responsibilites given the Tribal Historic Preservaticin Officer (THPIO) by the National'"

Historic Preservation Act of 1966, as amended in 1992 and the Procedures of the Advisory Council on

Historic Preservation (38CFR800).

I have reviewed the documentation; after careful consideration of our records, I have

determined that the Leech Lake Band of Ojibwe does not have any concerns regarding

sites of religiousor cultural importance In this area. Please keep In dose contact with the

Prairie Island Community.

Should any human remains or suspected human remains be encountered, all work shafl cease and the 1 0-a-CR

following personnel should be notified immediately in this order: County Sheriff's Office and Office of

the State Archaeologist. If any human remains or culturally affiliated objects be inadvertently

discovered this will prompt the process to which the band will become informed.

Please note: The above determination does not "exempt" future projects from Section 106 review. In

the event of any other tribe notifying us of concerns for a specific project, we may re-enter into the

consultation process.

You may contact me at (218) 335-2940 If you have questions regarding our review of this project.

Please refer to the LL-THPO Number as stated above In all correspondence with this project.

ReSp - Ily submitted',: • •~~~~~~~~~~...... . ":..'.......... (, .:,''. ' .. £:".: ,L :. .. "',::T"'.3'..

in M. Le on

Tribal'Histoc Pireservabhon Officer

.Leech Lake Tribal Historic Preservation Office Establishedin 1996 .

An offier within the Division ot R-,ourcc Managcrentt

115 Sixth Street NW, Suite Ei Cass Lake. Minnesota 56633 A A- 3

(218) 335-2940 * FAX (218) 335-2974

,~ ~ ~ (CaAona nsivcem no wwwnalhJstra (Memnbers; since 1998)

Draft NUREG-1437, Supplement 39 A-75 October 2009
Appendix A

The following pages contain the written comments

submitted by Tom Lovejoy during the scoping period

for the Prairie Island Nuclear Generating Plant

license renewal

October 2009 A-76 Draft NUREG-1437, Supplement 39
Appendix A

State of Wisconsin X DEPARTMENT OF NATURAL RESOURCES

West Central Region Headquarters Jim Doyle, Governor 1300 W. Clairemont Avenue

Matthew J. Frank, Secretary PO Box 4001

Scott Humrlckhouse, Regional Director Eau Claire, Wisconsin 547024001

Telephone 715-839"3700

FAX 715-839-6076

TTY Access via relay- 711

September 8, 2008

Nathan Goodman

US Nuclear Regulatory Commission

Mail Stop: 0-1IFI

Washington, DC 20555-0001

Subject: Prairie Island (MN) Nuiclear Generating Plant (PINGP) License Renewal - EIS Issue Scoping

Dear Mr. Goodman:

Thank you for inviting Wisconsin Department of Natural Resources (WDNR) to the Nuclear Regulatory Commission (NRC)

relicensing "audit" at the PINGP plant on August 20, 2008. It was very informative. At that meeting you invited WDNR to

prepare and submit a list of issues we feel should be addressed in NRC's Environmental Impact Statement prepared as part of

PINGP relicensing process.

I. Fish Impingement and Entrainment at Water Intake

Information should be provided describing the extent of fish cntrainment and impingement at the water

intake and associated fish mortality. What is the incremental effect on fish populations? What measures are

in place or proposed to minimize losses?

2. Upper Mississippi River Navigation Pool 3 Drawdowns for Habitat Enhancement

A consortium of federal and state agencies is considering use of temporary Pool 3 water level

manipulations (i.e. I-2' drawdowns) for purposes of improving aquatic habitat conditions, We have heard

there may be PINGP concerns, such as for fire control or design limits of water intake structure(s), that may

conflict with the idea of pool drawdowns. Please describe any such concerns and identify measures that are

proposed or could be employed to prevent conflicts with any such drawdowns.

3. Cooling Water Discharge Thermal Effects to:

A. Mississippi River Biological Resources

Describe past fish kills, particularly those associated with effluent thermal mixing during cold water

conditions, resulting from past plant operations. Describe the make-up and extent of other biological

resources (i.e. mussel community, etc.) in the discharge canal and Mississippi River mixing zone. What

studies/monitoring has been done in effort to document thermal discharge impacts to aquatic organisms?

What design and/or operational measures have been employed to minimize adverse effects and how

successful have they been? What additional remedial measures are proposed or could be used to further

avoid or minimize adverse impacts?

} 11-a-AR

+ 1 1-b-NS

} 11-c-AR/SW

dnr.wi.gov

wisconsin.gov I OP•

Draft NUREG-1437, Supplement 39 A-77 October 2009
Appendix A

B. Mississippi River Public RecreationUse Opportunities

We have routinely received seasonal complaints from the ice fishing public that access to historic fishing

areas in upper Lake Pepin is adversely impacted by warm water discharges, resulting in delayed ice

formation at winter's onset and more rapid ice deterioration before spring ice-out. The EIS shousddeseribe

PINGP discharge effects on winter ice cover and usability of traditional ice fisherman access points.

Feasible measures to offset adverse impacts should be identified and incorporated as license conditions.

4. Zebra Mussel Control Impacts to Native Mussels and Other Aquatic Resources

Best management practices for control ofbiofouling from zebra mussels and other exotic species continues

to evolve. What measures (molluscicides, other) are currently employed to control zebra mussels and has

there been any monitoring to determine if such practices result in impacts to native mussels or other aquatic

life? Measures to minimize adverse impacts should be identified. Given the evolving identification ofrbest

management practice control technology the license should provide for a periodic re-assessment and an

adaptive management approach to exotic species management and remedial methods.

5. Identification of Planned or Foreseeable Future (over new NRC license term) Physical Improvements (i.e.

new/upgraded transmission lines, new/modified water intake structures, etc.) and Any Associated Impacts

in Wisconsin

Would relicensing set a precedent that would result in an interest by Xcel in constructing new or upgraded

transmission lines or other physical improvements that directly or indirectly impact Wisconsin? At our

meeting it was explained that no such improvements are proposed or expected and that a license condition

would be incorporated indicating no such improvements would be authorized as pan of relicensing. We

interpret this to mean that any such unforeseen future improvements would be subject to applicable federal

and/or state regulations, including NEPA if appropriate, as a separate action. Please confirm this in the EIS.

As stated at our meeting I am currently the primary WI)NR contact person for this project and that Mr. Nick Schaff will

serve in that capacity starting in April 2009. If there are any questions regarding the above I would be happy to discuss them.

I'm also available to make arrangements for WDNR fisheries, water quality or other program experts to meet with you or

other NRC staff, Xcel personsel or representatives from other resource management agencies, to discuss issues of common

interest.

1 1-d-EJ/SW

11-e-AR

11-f-Cl

Thank you for the opportunity to submit WDNR scoping commaents for this projecL

Sincerely,

TL 9/8/08

Tom Lovejoy

Environmental Impact Coordinator

cc:

Dave Sieben - Director, WDNR Office of Energy/Environmental Analysis

Nick Schaff- WCR

Gretchen Benjamin, John Sullivan. Ron Benajmin - LaX, WI

Gary Wege - US FWS, Bloomington, MN

Dan Wilcox - Corps of Engineers, St. Paul, MN

Matt Langan - MDNR, St. Paul, MN

Tim Schiagenhaft - MDNR, Lake City. MN

2

October 2009 A-78 Draft NUREG-1437, Supplement 39
Appendix A

The following pages contain the comments

made by Joan Marshman during the

NRC public scoping meetings held on July 30, 2008

Draft NUREG-1437, Supplement 39 A-79 October 2009
Appendix A

...................... ..... . ... . .. -.. ............ .. ......................... ... .. ... ._ 7 7 ,2

I (The following text was submitted prior to

2 the meeting:

3 "Permanency or Term of Storage.

4 "Good evening. I am Joan K. Marshman of

5 Frontenac Station, Minnesota. I am the

6 chair of the Florence Township Board of

7 Supervisors and have had ongoing concerns

8 pertaining to the permanency issues with

9 the cask storage at the Prairie Island

1 Nuclear Plant.

11 "As I stated in testimony before the

12 Minnesota Environmental Quality Board on

13 January 18, 1996, 'The permanency issue is

14 a major concern for many residents of

15 Florence Township, as it should be for the 12-a-RW

16 rest of the State of Minnesota.' This has

17 been my concern for the past 12 years.

1 "High-level radioactive waste storage

i1 must

2C be sited away from growing centers of

21 population, major highways, and waterways.

22 Waste management is the responsibility of

23 this generation. Centralized off-site

24 storage such as the Yucca Mountain

NEAL R. GROSS

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133 RHODE ISLAND A., N.W.

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October 2009 A-80 Draft NUREG-1437, Supplement 39
Appendix A

. . ..... .... . . .. .... .... . . . . . ................... -.......... . ............... ..... .........-- .. ..... ............ ... ........... .. . . ...... ............................... . . ... . .. . . . .. . ....

repository is by far preferable to on-site

storage at reactor reactor sites throughout

the United States.

"The question of permanency is still

unresolved. To date, the Yucca Mountain

repository is ten years past due in

accepting the first shipment of irradiated

fuel. The Department of Energy (DOE) had a

responsibility to remove spent fuel from

reactors beginning in 1998. Now the DOE

must take immediate action to ensure that

the necessary infrastructure is in place to

accept the spent fuel that is now in

storage on-site at all the nuclear plants

across the country.

"Thank you for considering my concerns.

"Joan K. Marshman, resident of Frontenac

Station, Goodhue County, Minnesota; Chair,

Florence Township Board of Supervisors.")

.78

12-a-RW (continued)

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AW, NW

(20Z 2344433 VWASINGTON. DC. 20005-3701 ,.n.,kgvostmcom

Draft NUREG-1437, Supplement 39 A-81 October 2009
Appendix A

The following pages contain the comments

made by Alan Muller during the

NRC public scoping meetings held on July 30, 2008

October 2009 A-820 Draft NUREG-1437, Supplement 39
Appendix A

1 And I might mention that -- and I might

2 be there, but I'm here -- a study has been carried

3 out in the vicinity of the Salem nuclear complex and

4 other places in the country where baby teeth were

5 collected, the teeth of babies who were born and

6 lived some stage of their lives in the vicinity of

7 the reactor; and people took a look to see if there

1 3-a-HH a was more -- were more radioactive elements in those

9 teeth than in the teeth of babies who lived further

10 away, and the answer appears to be yes.

11 I haven't seen the raw data, but this is

12 certainly something that the NRC ought to take a very

13 close look at, because it would not be appropriate to

14 relicense a facility if doing that was going to have

15 major negative health impacts.

16 Okay. That's what I have to say. Thank

17 you.

18 MR. RAKOVAN: I think she's following me

19 up here, but Carol Overland.

20 CAROL OVERLAND: That's correct.

21 Well, I'm Carol Overland, and I don't

22 have all that much to say other than it is correct

23 that it was really hard to get a copy of this

24 application, and I do want to make sure for the

NEAL R. GROSS COURT REPORTERS AND TRANSCRBERS

$323 RHODE ISLAND AVE, N.W.

(202) 2344433 NSHIENGTON D. 20005-3701 w~Egrns.,©

Draft NUREG-1437, Supplement 39 A-83 Octob4er 2009
Appendix A

and so because license renewal involves the aging of

a facility, our concern really is managing of that

3 aging.

4 And so recognizing that there are

performance issues that occur at these plants, we

have the reactor oversight process that evaluates the

significance of those and characterizes the findings

in a process by which the regulatory response is

determined.

1 Because of that and because we're

11 confident that that process is working to ensure that

12 the plants are operating safely today, we can just

13 focus on aging for license renewal.

14 BRIAN 14OLIAN: Can you mention operating

15 experience?

16 MS. FRANOVIC1: We also apply that

17 operating experience that we glean from those

18 performance issues to the extent they're relevant to

i1 aging management. We incorporate that into our aging

20 management reviews for relicense renewal.

21 Thank you, Brian.

22 ALAN MULLER: Well, I'm not particularly

23 familiar with the operating history of these two 13-b-LR

24 reactors, but it does seem to me what you said has

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AW., N.W.

(202) 234-4433 MSHINSTON. D.C 20005-3701

- October 2009 A-84 Draft NUREG-1437, Supplement 39
Appendix A

the effect of inappropriately narrowing the

re-licensing proceeding almost to the point of

tending to render it meaningless.

MS. FRANOVICH: I understand your view.

I understand your view on that.

ALAN MULLER: Okay. Thank you.

MS. FRANOVICH : Unhum.

MR. RAKOVAN: Any other --

Yeah, sure. Why not.

Unfortunately, I don't have a handheld,

so I have to use this lapel.

Please introduce yourself.

KIRSTEN EIDE TOLLEFSON: I'm Kirsten Eide

Tollefson, and I live down in Frontenac, which is

about 10 miles down river, 10, 15 miles down river.

And I'm a little confused as to whether

or not I am part of the scope. I mean I've been

involved in Prairie Island reactors. In Frontenac we

had our own review process down there for waste, and

we had a very difficult time being recognized for

notice. Our newspaper, the Lake City Graphic, which

is one of closest newspapers, was not on the notice

list in the application and in fact never received

notice.

13-b-LR (continued)

NEAL R. GROSS

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(202) 234-4433 ASI'NGTON D.C. 20005-3701 - n.akgntocor

Draft NUREG-1437, Supplement 39 A-85 October 2009
Appendix A

concentration points may be, what is the dispersion

pattern, are they living within that pattern.

And so, please, let's get serious. If

this is going to be a technology that's going to be

with us for a while -- I have no illusions that until

something heads south real fast, which could happen

anytime, that we're going to continue living with

this threat, but let's at least inform ourselves

about what it is. You do not have the right to

conceal from the public where the routine reported

emissions go. Thank you very much.

MR. RAKOVAN: Thank you, sir.

Next we'll go to Alan Muller and then to

Carol Overland.

ALAN MULLER: I brought these

(indicating) up because these are the paper copies of

the license renewal, at least that which has been

released to the public. It's not particularly light

reading, but I have had a chance to review some of

it, and it seems to me that what is in here raises a

great many more questions than are answered.

And in fact it answers a lot of rather --

if you look in the index, you can see many references

to electrical connections and other design and

. 13-c-ER/LR

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

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(202) 234-4433 AfSHINGTON D.C. 20005-3701 ýWkrn~grostxm~

October 2009 A-86 Draft NUREG-1437, Supplement 39
Appendix A

engineering details; but if you look for something

like health effects, this application is silent. At

least it's silent to me. Perhaps I missed something.

But as Ms. Overland commented, it has not

been particularly easy to obtain copies of this. It

certainly required some agitation on her part to

obtain this one, which I borrowed.

And I'm wondering -- and I guess this is

question -- if the applicant is expected by the NRC

to provide copies of the applications to interested

citizens, you might want to --

Can I -- is it appropriate for me to pose

that as a question?

MR. RAKOVAN: We're kind of taking

comments right now.

ALAN MULLER: Okay.

MR. RAKOVAN: I mean if you want, we can

handle that after the period, but we were -- I think

we're just looking for specific comments right now,

if you don't mind, sir.

ALAN MULLER: Okay. My comment, then, is

that the applicant ought to provide copies of the

application to anybody who wants one. I suppose it

costs a few bucks to reproduce these two books, but

13-c-ER/LR (continued)

13-d-LR

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

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Draft NUREG-1437, Supplement 39 A-87 October 2009
Appendix A

.......... ...... .................. ......... ................................. .................................... . .. . . .. . . . ... . .. 5

there are other prices that will be paid by the

residents of the world for the continued operation of > 13-d-LR (continued)

3 this facility.

4 Now, one of the interesting things in

this book is that the one operating license expired

in 2013 and the other one in 2014. That's not very

far from now, and it's difficult not to form the

impression that the license renewal is regarded as a

done deal, because it's a little bit hard to believe

1 that in fact if there was a serious possibility that

11 that wasn't to be approved, that NSP is actually

12 prepared to carry out the process of shutting the 13-e-SD

13 facility down and obtaining substitute sources of

14 power.

15 I have looked at the filed resource plan

16 of Xcel, and there was no mention of the possibility

17 that the facility might not be allowed to continue to

18 operate. In fact, contained in their resource plans

1 are the assumption that the electrical output is

2C going to be increased by some tens of megawatts from

21 each reactor.

22 Now, I also noticed an interesting item

23 in here, and this is page 2.1-9, and it's section 13-f-OS

24 2.1.1.5.2. It says "Fuel transition." And I'll read

NEAL R. GROSS

COURT REPORTERS AND 1RANSCRIBERS

1323 RHODE ISLAND A'V, NW.

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October 2009 A-83 Draft NUREG-1437, Supplement 39
Appendix A

this paragraph to you:

"A licensed amendment request requesting

NRC approval for the transition to a new fuel type

for use in Prairie Island Units 1 and 2 reactors is

expected to be submitted concurrent with the NRC

review of the license renewal application. A review

of the effect of the transition to a new fuel type on

the LRA has been completed with the following

results;

"Scoping the transition to a new fuel

type will have no effect on the application of the

system scoping criteria or the results of system

scoping," and so on and so forth, which to me says in

nuclear regulatory lingo that this is another major

aspect relating to the continued operation of this

plant that is being handled in isolation from the

license renewal, and that's not appropriate.

If anyone is going to make an informed

judgment about whether this facility ought to

continue to operate, that ought to include the future

plans for changes there. How do we know that a,

quote/unquote, "new fuel type" doesn't pose

additional hazards or whatever that we don't know

anything about?

13-f-OS (continued)

)

(202) 24"33

* NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE IS1AND AVE, N.W.

AASHNTON, DC, 20005-3701

Draft NUREG-1437, Supplement 39 A-89 October 2009
Appendix A

Very likely that might involve, you know,

the use of plutonium in the plant, plutonium mixed

with something else, and that has a whole range of

implications of its own.

So I think as always seems to me to be

the case with the NRC, there's sort of a blinders-on

proceeding here, which, unless one is very

persistent, has more the effect of obscuring what's

going on than shedding light on it.

Now, just a couple of comments and then

I'll shut up.

There's mention here of environmental

justice as something to be considered within a

50-mile radius of the site.

Now, in my world, in my concept of this,

it seems obvious that if the plant is going to

operate for 20 more years, that's going to result in

the mining and processing of more uranium; and the

doing of that is going to have major health impacts

that are far beyond 50 miles.

It's going to have impacts in Navajo

communities many hundreds of miles away from here. It

may have impacts in the state of Virginia, where

uranium mining is being proposed. And anybody who

2

13-f-OS (continued)

13-g-UR

di

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AM., NW.

WASHINGTON. D.C 2M5-3701 (20'4 2344433 wvna.wnealr$$.s €cW,'

October 2009 A-90 Draft NUREG-1437, Supplement 39
Appendix A

knows thing anything about uranium mining knows that

it's left a trail of sick and dying people behind it.

So my suggestion is that the NRC ought to

forget about this 50-mile business and look at the

actual impacts of the continued operation of these

two nuclear reactors.

Now, looking a little bit further down

the fuel cycle, it's obvious that more nuclear waste

is going object generated by 20 more years of

operation and that something is going to happen to

that.

If in fact, as seems unlikely to me, what

happens is that it ends up in Nevada at a proposed

nuclear waste dump there, that will certainly have an

impact on people in that area. And there are many

opinions about that that have been expressed by the

State of Nevada's Nuclear Projects Office, the

congressional delegation from that state and so on.

Also, by the western Shoshone, who live in the area

and whose concerns have been disregarded by the

federal agencies that are trying to permit that

nuclear dump.

So my testimony to you now is that those

impacts in additional nuclear waste disposal ought to

)

13-g-UR (continued)

13-h-RW

-A

NEAL R. GROSS

COURT REPORTERS AND TRAN$CRBERS

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(202) 234.4433 MaSHNG~TON. 0 C 20005-3701 WM.WkM3grusC=

Draft NUREG-1437, Supplement 39 A-91 October 2009
Appendix A

be fully considered in the relicensing proceeding for 13-h-RW (continued)

Prairie Island.

3 Now, maybe that's all that I should take

4 the time to say, but another interesting aspect of

this application is the consideration of

6 alternatives, which is something that's required

under the National Environmental Policy Act. And the

alternatives that are brought forth by NSP or Xcel in

the application are burning gas, burning coal, and

1 purchased power.

11 But that does not strike me as an

12 appropriate scope of alternatives to be considered.

13 The investment that would go into the continued

14 operation of this plant could go into demand side 13-i-AS

15 management activities such as load response and

16 conservation and efficiency programs; it could go

17 into solar-thermal electricity-generating facilities;

18 it could go into electrical storage facilities to be

19 associated with the growing wind industry in

2C Minnesota.

21 There are lots of alternatives, all of

22 which would make more sense -- or many of which would

23 make more sense than coal and gas and purchased

24 power; and the impression one gets from reading the

NEAL R. GROSS COURT REPORTERS AND TRANSCRIERS

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October 2009 A-92 Draft NUREG-1437, Supplement 39
Appendix A

discussion of alternatives is that the applicant has

chosen his alternatives carefully in order to support

the conclusion that the plant should continue to

operate.

But I think the NRC has broader

responsibilities to the public and should extend the

scope of the review of alternatives far beyond what

we've seen in the application.

I mentioned earlier that there's little

or nothing in here said about health effects; but as

Mr. Crocker. pointed out, quite rightly, there is a

continuous release of radioactivity from this kind of

a facility, particularly release of radioactivity

into the Mississippi River and also into the air

breathed by the community, the host community for the

facility.

So there ought to be a full evaluation of

the cumulative health impacts of an additional 20

years of radioactive releases from these two

reactors, and it ought to be a real review, not a

review carried out by a certain establishment of

tamed scientists who believe with religious intensity

that radiation is either harmless or perhaps it's

even good for you.

13-i-AS (continued)

13-j-HH

2

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE, NW.

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Draft NUREG-1437, Supplement 39 A-93 October 2009
Appendix A

The following pages contain the comments

made by Carol Overland during the

NRC public scoping meetings held on July 30, 2008

October 2009 A-94 Draft NUREG-1437, Supplement 39
Appendix A

And I might mention that -- and I might

be there, but I'm here -- a. study has been carried

out in the vicinity of the Salem nuclear complex and

other places in the country where baby teeth were

collected, the teeth of babies who were born and

lived some stage of their lives in the vicinity of

the reactor; and people took a look to see if there

was more -- were more radioactive elements in those

teeth than in the teeth of babies who lived further

away, and the answer appears to be yes.

I haven't seen the raw data, but this is

certainly something that the NRC ought to take a very

close look at, because it would not be appropriate to

relicense a facility if doing that was going to have

major negative health impacts.

Okay. That's what I have to say. Thank

you.

MR. RAKOVAN: I think she's following me

up here, but Carol Overland.

CAROL OVERLAND: That's correct.

Well, I'm Carol Overland, and I don't

have all that much to say other than it is correct

that it was really hard to get a copy of this

application, and I do want to make sure for the

14-a-LR

.NEAL R. GROSS

COURT REPORTERS AND TRANSCREIERS

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W00t1NGTON. D.C. 20005-3701

)

(202) 234-."33 .nnkg,~$s.eu11

Draft NUREG-1437, Supplement 39 A-95 October 2009
Appendix A

record that everyone who requests an application

should get an application.

There aren't that many of us odd people

that like to read this stuff, and if we really want

to put the time in, give us the application. It will

make your lives a lot easier.

And actually, you know, Alan Muller

addressed many of the things I wanted to raise, but

as far as replacement power goes, there was this

great study a while back -- Kirsten Eide Tollefson

will remember it -- of the Prairie Island replacement

power using a wind/gas combo.

Was that wind/gas? It was. Right?

Anyway -- right.

KIRSTEN EIDE TOLLEFSON: I t was a

conversion, a gas conversion.

CAROL OVERLAND: Right.

KIRSTEN EIDE TOLLEFSON: It was an

integrated resource plant.

CAROL OVERLAND: So it was strictly gas?

MR. RAKOVAN: Miss, if you're going to

talk, I'm going to have to get you on the transcript.

I'm sorry.

>' 14-a-LR (continued)

t 14-b-AS

CAROL OVERLAND: Oh. Well, I'm just --

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October 2009 A-96 Draft NUREG-1437, Supplement 39
Appendix A

I'm trying to make sure -- I referred to -- I thought

it was a wind/gas combo, but maybe I'm not right.

Maybe it was just gas conversion. But we'll get a

copy of that into the record, so that will show one

more alternative that is possible.

And speaking of wind/gas conversions, I

also want to bring up that that is a very real

possibility, and the state of Delaware has just

ordered an off-shore wind project, and that's to have

gas back-up to make it for power. If Delaware can do

it, Minnesota can do it. You know, there are things

that we can do that are alternatives to this.

And I'll submit further comments by the

deadline.

And as far as notice goes, you know, this

obviously is a problem. Many of us did not get

notice who have been participating in nuclear issues

for a long time.

And because of that, the comment period

should be extended at least as long as the defective

-- the notice was defective. So if notice didn't go

out until the 25th and should have gone out when,

extend it the other way. That only fair.

Thank you.

14-b-AS (continued)

14-c-LR

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE, NW.

(202) 234-4433 WASHINGTON. D.C. 205-3701 -.- natgost.ewM

Draft NUREG-1437, Supplement 39 A-97 October 2009
Appendix A

The following pages contain the written comments

submitted by the Prairie Island

Indian Community during the scoping period

for the Prairie Island Nuclear Generating Plant

license renewal

October 2009 A-98 Draft NUREG-1437, Supplement 39
Appendix A

Ronald Johnson Johnny Johnson

President Vice President

Lucy Taylor Victoria Winfrey

cretary Treasurer

Shelley Buck-Yeager

Assistant Secretary/Treasurer

September 22, 2008

Chief, Rulemaking, Directives and Editing Branch

Division of Administrative Services

Office of Administration

Mailstop T-6D 59

US Nuclear Regulatory Commission

Washington, DC 20555-0001

RE: Environmental scoping for the relicensing of the Prairie Island Nuclear

Generating Plant, Units 1 and 2

Dear Rulemaking, Directives, and Editing Branch Chief:

The Prairie Island Indian Community (Community or Tribe) would like to offer the

following suggestions and comments regarding the scope of the draft Supplemental

Environmental Impact Statement (SEIS) that will be prepared by the US Nuclear

Regulatory Commission (NRC) for a 20-year operating license extension, as required by

the National Environmental Policy Act (NEPA). The comments are offered in response

to the notice in the Federal Register on July 22, 2008 (73 FR 42628).

It should be noted that views expressed in this document are the views of the Tribal

Council, on behalf of the Community. Individual community members, of course, are

free to express their own views, which may or may not be the same. Individual tribal

members may express their concerns in writing.

Community Backround

The Prairie Island Indian Reservation is located on Prairie Island, which is formed at the

confluence of the Vermillion and Mississippi Rivers in southeastern Minnesota

(approximately 35 miles SE of the Twin Cities of Minneapolis and St. Paul, MN). The

size of the Prairie Island Indian Community has grown through several federal

reorganization acts and direct purchases by the Tribal Council, and now totals over 3,000

acres (land and water) (Figure 1).

The United States Congress passed "The Prairie Island Land Conveyance Act of 2005,"

which transferred an additional 1300 acres of US Army Corps of Engineers land

(approximately 485 acres of forested wetlands and prairie and approximately 819 acres of

5636 Stirgeon Lake Road * Welch, MN 55089

(651) 385-2554 * 800-554-5473 , Fax (651) 385-4180 T T'Y 800-627-3529 Deaf of Hearing Impaired

Draft NUREG-1437, Supplement 39 A-99 October 2009
Appendix A

open water) to the Prairie Island Indian Community. These tribal lands provide a diverse

habitat for fish and wildlife, including open prairie, forested wetlands, shrub swamps, and

many other palustrine wetland types. In addition, this area is part of the Mississippi River

flyway that provides resting and feeding areas for many migratory bird species.

J• Prairie Island Indian Community

Land in Trust = Approxlmatiy 1,988 acres

Legend - Lm",3 "' ' ..

W.1 R:•IB ., .

. ,. ,0%-

i - "M .

Figure 1

2

October 2009 A-100 Draft NUREG-1437, Supplement 39
Appendix A

The Mdewakanton, "those who were born of the waters," have lived on Prairie Island for

countless generations.' Archaeological evidence, including village sites and burial

mounds, conclusively demonstrate that Prairie Island has been a place of historical and

cultural significance for thousands of years. In more recent times, descendants of those

earliest known inhabitants, the members of the Mdewakanton Dakota (Sioux),

traditionally used Prairie Island as a summer encampment for fishing, hunting and raising

crops. At least by the late 1880s, a small permanent Mdewakanton settlement was

established. Congress appropriated funds and purchased land for the Mdewakanton on

Prairie Island in the late 1880s. The Prairie Island Indian Community was formally

organized under the Indian Reorganization Act of 1934, additional lands were acquired,

and a formal reservation established. A tribal constitution and bylaws were approved by

the Secretary of the Interior in 1936. The Prairie Island Indian Community is governed by

the Community Council (sometimes referred to as the "Tribal Council"), which is

comprised of five elected tribal members who each serve a two-year term.

Our community has grown substantially since the plant first went on-line in 1973. There

are now 767 enrolled band members; approximately 250 members reside on tribal lands

within 2 miles of the PINGP. We expect our enrollment to double over the relicensing

period. The Prairie Island Indian Community owns and operates the Treasure Island

Resort and Casino, which employs more than 1,500 people. In addition, the Community

owns and operates a RV Park and a Marina, which attract many hundreds of visitors

during the summer months. On any given day there may be as many as 9,000 visitors to

our Community.

General Environmental Report Comments

We understand that the NRC will be developing a Supplemental Environmental Impact ]

Statement (SEIS), as part of its review of the application to renew the operating licenses

of the Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2. The starting point 15-a-ER

for the SEIS is the Environmental Report (ER) submitted by the Nuclear Management

Company (NMC) with the application for license renewal. The Community is deeply

The Prairie Island people are part of a larger group called the "Dwellers of the Spirit

Lake;" in the Dakota language the Mde wakan ed otunwahe. Over the years this name

has been shortened to Mdewakantonwan or Mdewakanton (pronounced M'DAY-wahkahn-tahn). The Mdewakanton are one of the seven sub-tribes who make up the alliance

called Oceti Sakowin - the Seven Council Fires. Most of the world knows our alliance as

the Sioux, which comes from an Ojibwe word nadowessi - "Little snakes." The French

changed it to Nadowesioiux or simply Sioux. We call ourselves Dakota, Lakota, or

Nakota, a word that means "allies" or "friends" in all three dialects. The

Dakota/Lakota/Nakota have reservations in the states of Minnesota, Nebraska, South

Dakota, North Dakota, and Montana, and in the Canadian provinces of Manitoba and

Saskatchewan.

3

Draft NUREG-1437, Supplement 39 A-101 October 2009
Appendix A

concerned about the general lack of attention given to the Community in the ER by NMC

and its parent company Xcel Energy.

Overall, the ER minimizes the presence of the Tribe, tribal land-holdings, the tribal

population, and tribal resources. For example, Section 2.1 of the ER (General Site

Description) makes no mention of the Community but mentions other governmental

units. The Community is mentioned in Section 2.1.2, PINGP Site Features. The Prairie

Island Indian Community, however, is not a feature of the PINGP. Our lands and people

pre-date the existence of the PINGP. Furthermore, no detail is provided on Community

land holdings, water supply system, home sites, and population, Figure 2.1-2 does not

correctly show the Community's lands. We have included Figure 1 that more accurately

identifies the Tribe's land holdings.. Other examples of the lack of data on impacts to the

Community are the absence of information on Community demographics, including

population growth, the tourist population related to the Community's casino, hotel, and

marina. The fact that Treasure Island is Goodhue County's largest employer is also

overlooked. Moreover, there is no treatment of the Community's land use planning

activities, although the land use plans of other governmental units (Goodhue and Dakota

Counties in Minnesota and Pierce County in Wisconsin) in the vicinity of the site were

evaluated.

15-a-ER

(continued)

Trust Responsibility of the Fedeial Government

Although it was written in 1996, at a time when most federal agencies had welldeveloped and well-implemented Indian policies, the Generic Environmental Impact

Statement (GEIS, NUREG-1437), the basis of the SEIS, does not recognize or mention

Tribes or tribal sovereignty. Federally recognized Indian Tribes are governments, with

unique legal and political standing and rights. Indian Tribes enjoy a Government-toGovernment relationship with the Federal Government, including the NRC.

In June of this year, the Prairie Island Indian Community entered into a Memorandum of

Understanding (MOU) with the NRC that established a cooperating agency relationship

for the purpose of preparing the SEIS for the renewal of the licenses for the PINGP, Units

I and 2. The Community's Cooperating Agency status, as it relates to the development

of the SEIS, is limited to four areas: Historic and Archeological Resources;

Socioeconomics; Land Use; and Environmental Justice. The tribe recognizes that the

agreement is the first of its kind within the NRC and would not have been developed had

the NRC not taken its Trust responsibility to the Prairie Island Indian Community

seriously.

Although most of the comments and suggestions in this letter are outside our four areas

of the MOU, they are just as important to the Prairie Island Indian Community. We

believe that all things are related, "Mitakuye Oyasin," 2 and that one cannot separate one

2 Mitakuye Oyasin, literally translated, means "to all my relations" or "we are all

related." Mitakuye Oyasin is a prayer, an acknowledgement, that honors the sacredness

of all people and of all life.

4

15-b-LR

J

October 2009 A-102 Draft NUREG-1437, Supplement 39
Appendix A

aspect of the environment from another. In other words, our Community's health and

well-being are dependent upon the health of the natural environment-the water, the fish,

the birds, the air, the plants, are all interrelated as part of an ecosystem that is Prairie

Island.

We believe that the NRC's SEIS should clearly set forth the scope and role of the NRC's

Trust responsibilities to the Community in the license renewal process, including, among

other things, and whether and to what extent the NRC believes that the Trust

responsibility applies to both Category One and Category Two issues.

Category One Issues

While Category 1 issues are generally excluded from disclosure by NRC regulations, the

Community continues to be concerned about the future impacts of these issues. The

Community has provided some "new and significant" information relative to the storage

of spent fuel and health impacts.

Human Health and Radiological Exposure

The Community recognizes that radiological exposure is a GEIS Category 1 issue.

Nevertheless, community members remain concerned about their chronic exposure to

low-level radiation. Many of our community members have been living on Prairie Island

since the plant went on-line in 1973. Community members typically do not move in and

out of the community. We are concerned about the human health effects from 60 years

of low-level exposure (the original licensing period and the extended licensing period).

In addition, community members may have exposure pathways (water, food, air) that

may be different from typical or "average" population in the area surrounding the plant,

thereby placing the tribal population at greater risk. For example, many tribal members

consume native plants for traditional purposes (direct consumption, medicines, teas,

ceremonies) that are not typically part of Xcel's or the State of Minnesota's monitoring

programs.

The ER does not address the issue of tritium contamination of the Community's wells.

According to the 2007 Annual Radiological Monitoring Program (REMP) report (for

PINGP) submitted to the NRC (May 13, 2008), wells PIIC-02 (1773 Buffalo Slough Rd.)

and PIIC-26 (1771 Buffalo Slough Rd.) had Tritium concentrations of 65 pCi/L and 62

pCi/L, respectively (sampled July 2007). Well P-24D (Sueter residence) has tritium

concentrations less than 23 pCi/L and all other off-site wells have tritium concentration

less than 19 pCi/L.

According to the report, in July 2007, many onsite wells have Tritium concentration

greater than 65 pCiIL. We understand that the levels of tritium found in our groundwater

are below the US Environmental Protection Agency (EPA) standard of 20,000 pCi/L.

Nevertheless, the tritium is there and we did not ask for it to be there.

}

}

15-b-LR (continued)

15-c-LR

15-d-HH/EJ

15-e-GW

5

Draft NUREG-1437, Supplement 39 A-103 October 2009
Appendix A

Figure 2, below, represents a simulated groundwater modeling showing the movement of

tritium from the PINGP towards the Prairie Island Indian Community. The Community

respectfully demands a full and complete disclosure of the monitoring data for all tritium

and other radiological contaminants for each well or other monitoring location, and not

simply monthly, quarterly or annual averages for individual wells. This data is critical to

identify and baseline accidental and planned releases of tritium and other radiological

contaminants, and to facilitate the Community's preparation of exposure scenarios,

scenario analysis, and computer modeling of all environmental pathways for tritium

contamination.

Scenario 3:

Simulated Geology-Driven Groundwater Contamination

' 15-e-GW (continued)

U~i.u. PJ-NP

Figure 2.

Other concerns related to site-specific observations and review of past annual REMP

reports for the PINGP include the following:

* There was no REMP made available to PIIC for 2006. This was also stated by a

participant at the July 30, 2008 evening EIS scoping meeting (see meeting

transcript, ADAMS ML0824900514);

* No information on tritium concentrations in the onsite and off-site wells was

provided in the years prior to 2007;

No follow-upsampling of PIIC wells was performed; ) 6

October 2009 A-104 Draft NUREG-1437, Supplement 39
Appendix A

" Proximity of PIlC wells to the plant merits their regular sampling for tritium

concentration amongst others;

* Closeness of wells PIIC-02 and PIIC-26 appears to confirm the consistency of the

tritium concentration at the order of 100 pCi/L, which is slightly less than the

level of tritium concentration found in onsite wells reported in the range of 100

pCi/L to 2200 pCi/L for P-2, P-109, P-7, P-11, PZ-2, SW-4, and especially P-10•

reported for every month of 2007 in the range of 390 pCi/L to 2258 pCi/L;

" The lower limit of detection (LLD) for analysis seems to vary from year-to-year

(What is the reason for the fluctuation and increase of the LLD? How can it be

that as technology improves the LLD would increase?);

" The higher tritium concentration in onsite wells indicate that PINGP is the tritium

source of PHC wells (see Figure 2);

* No explanation was provided for off-site residence well contamination of tritium

since 1989;

* Even though the REMP report states that the tritium results are far below the EPA

drinking water standard of 20,000 pCiIL, BEIR VII 2006 on radiation health

effects state that Linear No Threshold standard should apply to chronic low dose

exposure for potential cause of cancer and other radiation-induced diseases; 15-e-GW (continued)

* Even though the REMP report states that the tritium results are far below the EPA

drinking water standard of 20,000 pCi/L, new and significant studies and analysis

(discussed more fully below) raise significant concerns about the safety of even

low dose exposure, raising the question of what NMC and the NRC are doing to

"continuously evaluat[e] the latest radiation protection recommendations from

international and scientific bodies to ensure the adequacy of the standards the

agency uses," in accordance with the US NRC Fact Sheet of July 2006;

The problems of tritium contamination of nearby water reported in the PINGP

REMP 2007 may be similar to tritium contamination observed at other aging US

nuclear power plants, raising the concern that these tritium leaks will increase in

frequency and severity (see "Leaks at nuclear plants a growing trend? Regulators

to hear concerns about water tainted by low-lever radiation," Miguel Llanos,

April 5, 2006, available at http://www.msnbc.msn.com/id/I 1996239/); and

Whether and to what extent NMC and the NRC have modified or improved their

respective programs and procedures to inspect and assess the equipment and

structures at PINGP that have the potential to leak tritium in response to the US

NRC Fact Sheet of July 2006;

7

Draft NUREG-1437, Supplement 39 A-105 October 2009
Appendix A

Whether and to what extent NMC and the NRC have modified or improved their

ability to evaluate NMC's abilities to analyze for additional discharge pathways,

such as groundwater, as a result of a spill or leak in response to the US NRC Fact

Sheet of July 2006.

Given the above information, the EIS scope must be expanded to disclose the possible

impacts of PINGP to the Community, especially as it relates to health effects, particularly

the exposed critical subpopulations such as children and pregnant women.

Section 4.2.5 of Appendix E - ER for the PINGP license renewal application must be

regarded at best as incomplete at this time pending additional information and further

investigation.

The SEIS must include an accurate quantification of radiological impacts to the members

of the Prairie Island Indian Community-from all sources. At a minimum, the SEIS

should include all data associated with all tritium and other radiological releases

(accidental and planned), and all of the data for each well or other monitoring location

(and not simply monthly, quarterly or annual averages for individual wells). This data is

critical to identify and baseline accidental and planned releases of tritium and other

radiological contaminants, and to facilitate the Community's preparation of exposure

scenarios, scenario analysis, and computer modeling of all environmental pathways for

tritium contamination.

New and Significant Information - Increased Risk of Cancer

The current and continued operation of the PINGP is one the most, if not the most

important environmental and health concerns for the Prairie Island Indian Community.

Past and current Tribal Council members have voiced their concerns about health impacts

stemming from planned and unplanned radioactive releases. As set forth below, the

Community is already conducting its own examination of current peer reviewed studies

pertaining to nuclear power plants and health impacts.

A number of studies have reported elevated rates and/or risks for cancer experienced by

populations residing proximal to nuclear facilities. Many of these studies were completed

subsequent to the release of the GEIS (NUREG 1437) and can be considered as new and

significant information.

In particular, elevated rates of leukemia have been observed among populations in

England (Gardner et al, 1987), Spain (Silva-Mato et al, 2003) and Germany (Hoffmann et

al, 2007; Spix et al, 2008; Kaatsch P, Spix C, Schulze-Rath R, et al, 2008).

The most recent of the above studies involving populations residing in the vicinity of 16

German nuclear power plants (the Kikk study) are among the methodologically strongest

studies that have to date been completed (BFS 2007).

}15-e-GW (continued)

t 15-f-HH/EJ 15-g-ER

15-h-HH

8

October 2009 A-106 Draft NUREG-1437, Supplement 39
Appendix A

The KiKK study included all 16 large reactor locations where 20 nuclear power plants in

Germany were in operation during the 24-year period of study (1980 - 2003).

The distance between the children's homes and the power plants was precisely

determined to within 25 meters (or approximately 82 feet). The main questions posed by

the study were: "Do children under five years of age more frequently develop cancer

when living near a nuclear power plant?" and "is there a negative distance trend?" (In

other words: is the risk greater the nearer the child lives to the plant?) The results

showed not only a 60% increase in the cancer rate and a 117% increase in leukemia in

infants within the 5 km radius (or approximately 3 miles), but also a significant increase

in the risk of cancer and leukemia the closer one lived to the nuclear power plant.

In the second part of the study, which covered a shorter period of time and a selection of

* diagnoses (leukemia, lymphomas and tumors of the central nervous system), it was tested

whether other risk factors (confounders) could have had any appreciable effect on the

main result of the study - the negative distance trend. This proved not to be the case for

any of the studied risk factors. The proximity of residence to the nuclear power plant

remains the only plausible explanation at this time.

Recently, results were also reported for a comprehensive meta-analysis (Baker and Hoel,

2007) concerning leukemia in children living near nuclear power plants contained in 17

international studies carried out in Germany, Spain, France, Japan and North America

during the period between 1984 and 1999. Distance dependent increased risks of 14%-

21% for leukemia in children under nine years of age were observed. When age was 15-h-HH (continued)

expanded to include the population up to 25 years of age, an increased probability of

morbidity of 7-10% and increased mortality of 2-18% were observed.

Taken together, these studies are consistent with the hypothesis that children who live

near nuclear power plants develop cancer and leukemia more frequently that those living

further away. If emissions have been correctly measured by monitoring the areas

surrounding nuclear installations, as has been claimed by both the plant operators and the

regulatory authorities, then either the currently accepted calculation models for

determining radiation exposure of local residents are incorrect, or the biological effects of

incorporated radionuclides have been badly underestimated, at least for young children

and embryos (human fetuses).

The indications over many years that there are increased levels of morbidity near to

nuclear power plants are given added support by results of the KiKK study. The

possibility of an increased risk for older children and adults living near nuclear power

plants cannot be ruled out. It is important to point out that the radiation health standards

established by BEIR VII are consistent with the above research findings regarding both

cancer and non-cancer health outcomes given any level of low dose exposures.

Furthermore, the BEIR VII committee also concludes "that the current scientific evidence

is consistent with the. hypothesis that there is a linear, no-threshold dose-response

relationship between exposure to ionizing radiation and the development of cancer in

humans." In other words, there exists general consensus on the radiation health risks by

9

Draft NUREG-1437, Supplement 39 A-107 October 2009
Appendix A

exposure and living near nuclear power plants. Consequently, the most effective

mitigation of such risks will rely on either 1) avoiding the area surrounding the plant, or

2) reducing the nuclear energy operational level, or 3) implementing risk management

options based on the mechanistic understanding of cancer or non-cancer epidemiology.

A number of studies have observed that risk of leukemia for children under the age of 5

increases with decreasing distance of residence from nuclear power plants in Germany,

the United Kingdom and in the United States (Hoffman, et al, 2007 and Kaatsch, et al,

2007).

The KiKK & USC studies are among the strongest methodologically speaking and utilize

state-of-the-art epidemiological methods.

The methodology of modeling the continuous distance variables is adequate. Models

applied in the studies show good adaptation to the collected data. The models permit an

assessment of the incidence risks associated with distance of the home to the nearest

nuclear power plant site. 15-h-HH (continued)

The risk to contract childhood cancer and leukemia significantly and continuously

increases with increasing vicinity of the home to a nuclear power plant. The studies are

the methodically most elaborate and comprehensive investigation of this interrelation

worldwide. The association between vicinity of the home and increased risk of leukemia

has been observed repeatedly in well-designed studies in Germany, the USA and UK.

The causal role of ionizing radiation in these studies remains to be investigated using

state-of-the-art genomic, molecular and cellular diagnostics and testing technologies that

have only recently become available for medical and healthcare research. The estimated

exposures are far below those levels that are known to be leukemogenic or carcinogenic.

Some of the associations are ecologic in nature, individual dosimetry is lacking and

potentially important confounders such as competing risks (exposure and disease), length

of residence, etc., are not measured. These factors can be further examined for sitespecific information and data to improve on recent research findings concerning the

PINGP operations and on-site'waste management practice.

Waste and Waste Confidence

The Prairie Island Indian Community remains concerned about the on-going operation of

the PINGP and Independent Spent Fuel Storage Installation (ISFSI). We recognize that

the NRC licenses these two facilities separately and that spent fuel storage is beyond the

scope of the license extension application. We believe that the two issues are, however,

linked.

The Commission's GElS on the License Renewal of Nuclear Plants, NUREG-1437, 1 5-i-RW

states that "...the original target date for opening the repository will not be met ... DOE

now expects that a geologic repository will be ready no sooner than 2010." (NUREG1437). This target has, unfortunately, been pushed back considerably. The Commission

10

October 2009 A-108 Draft NUREG-1437, Supplement 39
Appendix A

has only recently docketed the Department of Energy (DOE) application for a license for

the repository. The NRC has three years from the date of docketing, and an 'additional

year if necessary, to evaluate the DOE license application. It is almost certainly going to

take this long, given the complexity and controversial nature of the repository licensing

decision. If the Commission reaches a favorable decision on the license application, it

will be several more years before the repository is constructed and ready to receive

shipments of spent fuel for disposal. This assumes that there will not be the substantial

delays that often occur in large-scale construction projects. In addition, the upcoming

Presidential election could have a significant impact on the project. As DOE noted in its

recent Congressional testimony "...significant reductions in appropriated funding for

FY2007 and FY2008 had negated DOE's ability to meet the March 2017 best achievable

opening date [for the Yucca Mountain repository]." (emphasis added). Testimony of

Edward F. Sproat III, Director of DOE's Office of Civilian Radioactive Waste

Management (OCRWM), House and Senate Appropriations Hearing, April 9 - 10, 2008.

The end result of all of this uncertainty is that the Community may have to live with the

onsite storage of spent fuel at PINGP for decades, especially if the license for PINGP is

renewed. It is time for the Commission to revisit its Waste Confidence Decision and to

seriously explore whether there other alternatives to Yucca Mountain for removing the

spent fuel from PINGP. This falls into the category of "new and significant" information,

although it is certainly not "new" anymore. Concerned citizens and governments have

been raising this issue for a number of years in regard to many reactor license renewal

applications. Both the Waste Confidence Decision and the GEIS conclusions are

seriously in question and should be revisited before any Commission decision on whether 15-i-RW (continued)

to renew the license for PINGP.

As the GEIS noted, the total accumulated amount of spent fuel after an additional 20

years of operation at an individual reactor would amount to 50% more fuel than at the

end of 40 years of operation. (NUREG-1437) Even with this large increase, the NRC

has determined in its Waste Confidence Decision that spent fuel can be stored on-site for

at least 30 years beyond the licensed (and license renewal) operating life of nuclear

power plants safely and with minimal environmental impact. However, the GEIS also

notes that a second repository will be necessary because of the statutory limitation of

70,000 metric tons uranium (MTU) for the first repository. The GEIS concluded that

"...[a]ssuming that the first repository is available by 2025, additional disposal capacity

would probably not be needed before about the year 2040 to avoid storing spent fuel at a

reactor for more than 30 years after the expiration of operating licenses." NUREG1437). The 2025 date matches the Commission's second finding in the Waste

Confidence Decision, i.e., that the Commission finds reasonable assurance that at least

one mined geologic repository will be available within the first quarter of the 2 1" century

and that sufficient repository capacity will be available within 30 years beyond the

licensed life for operation (which may include the term of a revised or renewed license)

of any reactor to dispose of the commercial high-level radioactive waste or spent fuel

originating in that reactor and generated up to that time. Given the difficulties associated

with docketing the application for the first repository, this finding no longer appears to be

reasonable and should be re-examined, either in the EIS for the PINGP license renewal,

1

11

Draft NUREG-1437, Supplement 39 A-109 October 2009
Appendix A

or in a re-opening of the Waste Confidence Decision. It is conceivable, if the Yucca

Mountain repository does not survive the Commission's license evaluation, that a

repository may not be available until 2060. This would approach or exceed the "thirty

years after the expiration of the operating license" for many plants.

If the Commission does not see fit to re-open the Waste Confidence Decision, the

Community will take the lead, in coordination with other governmental entities

concerned about this issue, in submitting a petition for rulemaking to re-open the Waste

Confidence Decision. If the Commission does re-open the Waste Confidence Decision,

either on its own, or in response to a Petition for Rulemaking or some similar stimulus,

the Community requests that the PINGP license renewal be proceeding be suspended

until the Commission issues a new Waste Confidence Decision. It would not be prudent

to renew any operating license during the pendency of an evaluation of the Waste

Confidence decision that might reach a conclusion apposite to the present findings. If the

present findings are re-affirmed, the license renewal proceeding could be re-opened with

little impact on the license applicant.

In addition, the NRC SEIS on the license renewal application must develop alternatives,

including a no action alternative, as contingencies, in case NMC either does not receive

approval from the Minnesota Public Utilities Commission (PUC) for the expansion of the

Independent Fuel Storage Installation (ISFSI), or does not receive approval for an

amendment of its license from the NRC for the same purpose. (Note: the needed statelevel approvals are discussed later in this letter).

Avian Mortality and Transmission Lines

Section 3.1.6.3 of the ER discusses avian mortalities that have resulted from the

collisions from transmission lines. The ER noted that over a five-year period (1973-

1978) 453 bird carcasses, representing 53 species, were found along portions of the

transmission lines from the PINGP. Sixty-four percent of those carcasses were found

along the 2,500 foot east-west portions of the transmission lines. About one-half of these

transmission lines are on the boundary between the Community's land (east-west

boundary separating Sections 5 and 32, Til3North, R15 West) from Xcel's property.

Since there is no information regarding species composition for this time period, nor any

data to definitively indicate that avian mortality has not been reduced since the

conclusion of the five-year study, it is difficult to ascertain whether the continued

operation of the PINGP will not have a negative impact on avian populations.

No explanation was offered in the ER as to why avian mortality was so high at the

PINGP, other than to quote the NRC statement that "no relatively high collision mortality

is known to occur along transmission lines associated with nuclear power plants in the

United States other than the Prairie Island Plant in Minnesota." (NRC GEIS, 1996).

Similarly, there is no information as to whether operations at the PINGP have changed

any way, since 1978, to reduce mortalities over the license renewal term. Moreover,

there is a disturbing statement on page 3-13 of the ERthat "very few bird carcasses have

been observed at PINGP or along associated transmission lines since 1978, but

15-i-RW (continued)

15-j-RW

} 15-k-AS

15-I-TR

j

12

October 2009 A-1 10 Draft NUREG-1437, Supplement 39
Appendix A

systematic searches or formal avian collision studies have not been conducted." This

statement leads the reader of the ER to believe that PINGP personnel just stopped looked

for dead birds.

Because there is no information regarding any past operational changes that have been

made (or will be made during the relicensing period) that have resulted in the reduction

of avian mortalities, no information to suggest that formal searches or studies of avian

mortality are being conducted, and that nowhere else in the country is avian mortality so

high (according to NUREG 1437), the Community believes that, for the reasons outlined

below, avian mortality should be a Category 2 issue for the PINGP SEIS. The

Community is especially concerned about avian mortality as it relates to potential impacts

to threatened or endangered avian species, as the PINGP sits in the Mississippi River

flyway.

The Mississippi River is recognized as a Globally Important Bird Area and Migratory

"Flyway" for birds. The Mississippi flyway is heavily utilized because it is uninterrupted

by mountains or hills that would interfere with the movements of migrating birds

(Couleeaudubon.org). The Upper Mississippi River and associated ecosystem is very

important to birds that are year-round residents and those who are migratory. About 40%

of all North American waterfowl use the river as a migratory flyway, and 326 species of

birds (about 1/3 of all species in North America) use the river corridor as a flyway in

their spring and fall migrations (couleeaudubon.org). The Mississippi River is a wellknown migration corridor for millions of waterfowl, including dabbling ducks,

canvasbacks, and scaup that pass through this flyway annually. The bottomland forests

also provide wintering and migration habitat for mallards, black ducks, wood ducks,

northern pintails and Canada geese (Ducks Unlimited). Parts of the Mississippi River

also provide habitat for breeding and wintering birds such as the bald eagle (USGS

2007).

The associated floodplain forests and wetlands of the Upper Mississippi River have

become increasingly important because of losses of these habitats throughout the upper

Midwest. Higher species abundance is found in the floodplain as opposed to adjacent

upland, and many species, such as the prothonotary warbler, brown creeper, yellow-billed

cuckoo, yellow-bellied sapsucker and great flycatcher, show a clear preference for

floodplain forest. A study done in 1993 found 150 species of birds between Pools 4-8

during spring migration and 20% of these were neotropical migratory birds. A few

declining species such as the red-shoulder hawk, cerulean warbler, Louisiana

waterthrush, northern waterthrush, and prothonotary warbler are dependent on these

forests. Because of the importance of the Mississippi flyway, resource management and

other human activities within the flyway should be conducted carefully to protect the

• health of this important ecosystem and the birds and other wildlife that depend on it

(USGS 1993).

There is passing reference in the ER to the Mississippi River as a bird migration route

and how these particular lines (east-west corridor) are perpendicular to the river and that

"studies have found that transmission lines at right angles to avian flight paths are

13

15-I-TR (continued)

I

Draft NUREG-1437, Supplement 39 A-1 11 October 2009
Appendix A

associated with greater collisions." ER at 3-13. The ER also states, "this section of the

(transmission) corridors is perpendicular to the bird migration corridor along the

Mississippi River." The mere mention of the "bird migration corridor along the

Mississippi River" understates the importance of the Mississippi River as an annual

flyway for millions of migratory birds and the possibility that threatened or endangered

species may be affected.

It is interesting to note that NMC/Xcel devoted two paragraphs to the importance of the

Mississippi River Flyway in its application to the State of Minnesota Public Utility

Commission (PUC) for permission to use additional dry casks and to operate the PINGP

at a higher rate (PUC application dated May 16, 2008, page 7-21). (Note these state

proceedings are also discussed later in this letter).

Prairie Island and PINGP are also right in the middle of the Vermillion River and Lower

Cannon River Important Bird Area. This is an area of high biodiversity significance

within Minnesota harboring diverse bird communities unique to the Upper Mississippi

River. This is one of the top 4 sites in Minnesota for rare forest birds and it contains the

highest number of records for two special concern species-the Red-shouldered Hawk

and Cerulean Warbler (Dunevitz 2001).

The ER mentions that Xcel has entered into a Memorandum of Understanding (MOU)

with the US Fish and Wildlife Service (FWS) in 2002 to establish policies and procedures

for dealing with migratory birds that may be on Xcel property and for the development of

an Avian Protection Plan. The ER further states that the Avian Protection Plan is in

development, although reports covering activities related to the MOU are submitted to

the FWS. Since the plan is still in development, there appears to no current plan to

protect birds.

Because of the PINGP's location within the Mississippi River flyway and the reasons

stated above, Avian Mortality impacts should be treated as a Category 2 issue and

evaluated in the SEIS. We do not know why the incidence of avian mortality was so high

at the PINGP (during the only documented study period), we not know which species had

the highest mortality rates, whether these mortalities had an impact on populations, and

whether any threatened or endangered species were involved. There simply is not

enough information provided.

Category 2 Issues

Archaeological Impacts (National Historic Preservation Act)

One of the most important issues for the Prairie Island Indian Community is the condition

of the many archaeological sites within the PINGP.

We have learned that there have been some impacts to at least two archaeological sites

within the plant boundaries. One site, 21GD207, a habitation site, is under a service road.

Another site, 21GD59, a human burial mound site, impacted by the construction of the

15-I-TR (continued)

15-m-CR

14

October 2009 A-1 12 Draft NUREG-1437, Supplement 39
Appendix A

cooling towers, may now be under 12 feet of fill or may have been destroyed. This burial

site contains the remains of our ancestors.

We are well aware that the EIS scoping process does not provide a remedy for past

damage or disturbance to archaeological sites. The process, however, exists to ensure

that the full extent environmental impacts of the proposed action are fully understood and

disclosed. It is because of past damage or destruction of archaeological sites that we have

concerns about how the steam generator replacement project, and other future

construction (such as the expansion of the ISFSI, proposed for 2020) might impact

previously unrecorded archaeological resources.

Section 3.2 of the ER (Refurbishment Activities) discusses the replacement of Unit 2

steam generator (proposed for September 2013). The ER states that several temporary

buildings will be constructed, as well as office space for construction workers and a

decontamination building. In addition, warehouses will be built and will remain after the

project. It is mentioned that these buildings will be constructed on previously disturbed

land. No location information or maps, however, are provided. No mention is made of

water systems, sanitation facilities, or other infrastructure for the office space and how

these would be constructed.

In the 1960s Northern States Power (NSP), then the owner and operator of the PINGP,

contracted with Dr. Eldon Johnson (State Archaeologist) to conduct an archaeological

survey of the project area, which included excavations of existing burial mound sites, two

of which were well-outside the project area (Birch Lake Mounds and Bartron Village).

A Final Environmental Statement (FES), prepared by the United States Atomic Energy

Commission (AEC), for the original operating licenses for the PINGP, was released in

May of 1973. In the FES there is some discussion about impacts to archaeological sites.

A table lists some of the sites within the PINGP, but not all of the sites within the PINGP.

Most notably, there is no discussion regarding the archaeological site near the cooling

towers (21GD59). Correspondence from the Advisory Council on Historic Preservation

(ACHP) (March 1973) indicated that the AEC's draft environmental statement did not

contain sufficient information in order to allow the Council to comment substantively. In

response to the ACHP's letter, the FES stated concluded "that only the Barton site is

sufficiently close to the plant that an impact is possible." The FES goes on to state that

the Barton site is beyond the limits of plant construction and was not disturbed. There is

no mention whatsoever of whether a burial mound site much closer to the plant

(21GD59) that was impacted in any way. This site was actually outlined on a map

provided in the FES. (FES page 11-30)

We bring these issues up because that original survey work (late 1960s) appears to be the

basis for all other work within the plant boundaries, including the steam generator

replacement project. The circa 1990 EA for the ISFSI states that "an archaeological

survey was conducted in 1967, and nothing significant in the immediate area of the

power plant or ISFSI was found." Past archaeological work (i.e., 1960s investigations by

Dr. Johnson) is no guarantee that the area is clear of archaeological sites. In fact, two

15

15-m-CR (continued)

I

Draft NUREG-1437, Supplement 39 A-1 13 October 2009
Appendix A

previously unrecorded sites were discovered subsequent to the early site work, thus

demonstrating that it is still possible to identify previously unrecorded sites with the

PINGP boundaries. There is no evidence to suggest that Dr. Johnson's original site

survey work went beyond previously recorded sites.

XceI/NMC provided the Community with a copy of the report developed by its

contractor, the 106 Group (Boden 2008). The report is concluded with the statement that

the study area (the PINGP site) has a high potential to contain intact archaeological

remains." This strongly suggests the need to do a field assessment before any "construction" (i.e., steam generator replacement project buildings, etc.) activities occur.

As previously mentioned, the assessment conducted by the 106 Group did not involve

any field work, but involved an extensive review of the collected site files, reports, and

other literature, aerial photographs, historical plat maps, General Land Survey maps,

USGS topographic maps. The study area was the entire area within the boundaries of the

PINGP plant and grounds.

Further on the report states "Despite the construction of the PINGP and associated

features, there remains undisturbed land within the study area. Because the remaining

portions of the study area are in proximity to significant bodies of water and appear to be

undisturbed, they are considered to have inherently very high potential to contain intact

precontact archaeological sites. Further there is also the potential for finding intact burial

because four precontact mound sites, some of which have yielded human remains, have

been recorded in the study area." The report is concluded with the statement that "no

construction activities are planned under the new 20-year operating license." This leads

one to conclude that the 106 Group was not aware that Xcel/NMC planned to construct

several temporary buildings, as well as office space for construction workers, warehouses

and a decontamination building as part of the steam generator replacement project.

It is the responsibility of the NRC to assure compliance with the National Historic

Preservation Act, which states that all Federal agencies are required to give appropriate

consideration to the environmental effects of their proposed actions in their decisionmaking and to prepare detailed environmental statements on recommendations or reports

on proposals for legislation and other major Federal actions significantly affecting the

quality of the human environment (36CFR805.1).

It was the responsibility of the AEC (predecessor to the NRC) to ensure that the

environment (which includes cultural and archaeological resources) would not be

adversely impacted by the construction and operation of the PINGP. In fact, in the

forward of the FES, it is stated that, according to the National Environmental Policy Act

of 1969, it is the responsibility of the Federal government to, among other things:

Preserve important historic, cultural, and natural aspects of our national

heritage, and maintain, wherever possible, an environment which supports

diversity and a variety of individual choice.

16

15-m-CR (continued)

di)

October 2009 A-1 14 Draft NUREG-1437, Supplement 39
Appendix A

Part of our heritage (and culture) was lost when NSP destroyed burial mounds in the

1970s because no one was protecting these important cultural, historic, and religious

monuments.

The scope of the EIS must include a Phase I archaeological site survey to locate any

previously unrecorded sites within the steam generator project area and ascertain the

current status of all known sites within the boundaries of the PINGP to ensure that all of 15-m-CR (continued)

culturally-significant sites can be protected and respectfully managed. NMC/Xcel should

develop a Cultural Resource Management Plan (CRMP) to ensure that all of the

archaeological sites within the PINGP will be protected and respectfully managed.

We understand that the Midwest Region of the Bureau of Indian Affairs requested in

writing that they be allowed to participate in the EIS process as a Consulting Party,

pursuant to 36CFR800.2(c)(5) (letter to Rani Franovich, Branch Chief, from Kevin

Bearquiver, Acting Regional Director, B/A, August 18, 2008). We support this request.

Threatened and Endangered Species

Under provisions of section 7(a)(2) of the Endangered Species Act (ESA), a Federal

agency that carries out, that permits, licenses, funds, or otherwise authorizes activities.

must consult with the US Fish and Wildlife Service (USFWS) as appropriate, to ensure

that its actions are not likely to jeopardize the continued existence of any listed species.

Section 7 of the ESA requires the NRC to ensure that, if it grants a license, its action will

not jeopardize the existence of a regulated species.

Section 2.3.3 of the ER (Threatened and Endangered Species) notes the presence of the

Higgins eye pearlymussel (Lampsilis higginsil), an endangered species listed by both the

USFWS and the MN Department of Natural Resources (MN DNR). The ER also notes

the efforts of the USFWS and the MN DNR to re-introduce into Pool 3 of the Mississippi

River. Because Sturgeon Lake is historic habitat for the Higgins eye pearly mussel, the

Community has also been involved in this effort. The re-location area is located just 0.5

miles upstream of PINGP's intake screenhouse (this area is located in tribal waters). In 15-n-TE

fact over, 5,000 sub-adults have been placed in Sturgeon Lake since 2003.

Section 4.4 of the ER (Entrainment of Fish and Shellfish in Early Life Stages) discusses

entrainment of fish species from the condenser cooling system. No mention is made of

shellfish, other than to note that entrainment of fish and shellfish in early life stages is "a

potential adverse environmental impact that can be minimized by the best available

technology." ER at 4-12.

The ER concludes "impacts of entrainment of fish and shellfish at PINGP are SMALL

and warrant no mitigation beyond that already in place and required by the current

NPDES permit." The NPDES permit is attached, information related to NMC's Clean

water Act Section 316 (b) determination is discussed, but the report is not attached. Most

importantly, impacts to the Higgins eye pearlymussel is not discussed in this section. The

NPDES permit states that NMC must submit the results of a required Impingement

17

Draft NUREG-1437, Supplement 39 A-1 15 October 2009
Appendix A

Mortality and Entrainment Study, which shall provide information to support the

development of a calculation baseline for evaluating impingement mortality and

entrainment consistent with the 316(b) rule. This report was to have been submitted to

the Minnesota Pollution Control Agency by October 26, 2006, as required by 10 C.F.Rl §

51.53(c)(3)(ii)(B). The required report was not attached to the ER.

Section 4.7 of the ER (Threatened and Endangered Species) discusses the fact that

impacts to threatened and endangered species is a Category 2 issue and that site-specific

assessment would be required to determine whether continued plant operations of

refurbishment would be affected.

As noted in Section 2.3.3, efforts are underway to re-introduce the Higgins eye

pearlymussel to Pool 3 (Sturgeon Lake). According to the USFWS:

the current range for the Higgins eye mussel is about 50 percent of its

historic distribution, which extended as far south as St. Louis, Missouri,

and in several additional tributaries of the Mississippi River. The Higgins

eye pearlymussels depend on deep, free-flowing rivers with clean water.

Much of their historic habitat was changed from free-flowing river

systems to impounded river systems. This resulted in different water flow

patterns, substrate characteristics, and host fish habitat and movement that

affects how the Higgins eye feed, live, and reproduce. To reproduce, male

Higgins eye release sperm into the river current and downstream females

siphon in the sperm to fertilize their eggs. After fertilization, the females

store the developing larvae (glochidia) in their gills until they're expelled

into the river current. Some of the glochidia are able to attach themselves

to the gills of host fish, where they develop further. After a few weeks, the

juvenile mussels detach from the gills of the fish and settle on the river

bottom, where they can mature into adult mussels and possibly live up to

50 years. The sauger, walleye, yellow perch, largemouth and smallmouth

bass, and freshwater drum are considered suitable hosts for Higgins eye

glochidia. (USFWS 2008)

There is mention of these fish species in the ER, but there is no specific discussion

connecting the entrainment of larval Higgins eye or impingement of fish species (the

host for the mussel's early life stage, the giochidia) with impacts to the survival of the

Higgins eye pearlymussel in Section 4.7, Threatened and Endangered Species. The

discussion of impacts to the Higgins eye is simply summed up by stating, "it is

conceivable that some larval higginsii will be carried downstream into the power plants

intake screenhouse." No quantification of losses or further assessment, is provided, as

required by 10 C.F.R. § 51.53(c)(3)(ii)(E). These impacts seem to be negated or

minimized by the later statement in the paragraph, that even under the best of

circumstances, the mortality rate of the early life stages (of the Higgins eye) is very high

and the glochidia (early larval stage) that do not attach themselves to a host quickly have

a low probability of survival. This does not seem to meet the requirement that "the

applicant shall assess the impact of the proposed action on threatened or endangered

18

15-n-TE (continued)

J

October 2009 A-1 16 Draft NUREG-1437, Supplement 39
Appendix A

species in accordance with the Endangered Species Act (10 C.F.R. § 51.53(c)(3)(ii)(E).

NMC contacted the USFWS by letter dated January 25, 2008, requesting information

relative to concerns about possible impacts to threatened and endangered species arising

from license renewal. No reply was included in the April 15, 2008 ER. The NRC also

corresponded with the US FWS on July 22, 2008 regarding the presence of Threatened or

Endangered Species in the project. On August 13, 2008 the USFWS responded to the

NRC inquiry, stating that the only known endangered species in the project area was the

Higgins eye mussel and to also provide information relative to efforts to establish a viable

population.

The Community is concerned about how the cooling system in use at PINGP affects

survival of the Higgins eye larval stage. According to the ER, the PINGP can operate in 15-n-TE (continued) one of three modes: 1) open cycle, once through without the cooling towers; 2) helper

cycle, once-through with cooling towers; and 3) closed cycle. There is no discussion of

the cooling system and its three cycles and how any of them relate to species survival.

The matter is summed up by stating that "because current operational practices will be

affected by license renewal, NMC concludes that impacts to threatened or endangered

species from license renewal would be SMALL and do not warrant mitigation. " ER at 4-

27.

There was no discussion about how current operational practices are currently impacting

the survival of Higgins eye mussel beyond stating, "it is conceivable that some larval

higginsi! will be carried downstream into the power plants intake screenhouse." The EIS

must include a disclosure of how a the extended operating period will affect the survival

of this endangered species.

Socioeconomic Impacts

Taxes

Section 2.7 of the ER (Taxes) discusses the annual property taxes for the PINGP by

Goodhue County, the City of Red Wing, and School District 256. According to Table

2.7-1 of the ER, Goodhue County has received $26,223,326, Red Wing has received

$27,034,951 and School District 256 has received $17,041,750 for the time period of

2001 to 2006 (for a total sum of $70,300,027).

In contrast, Xcel has only paid the Tribe a sum of $2.3 million annually as a result of a 15-o-SE

Settlement Agreement between the Community and Xcel/NMC entered into in 2003.

Over the last. several years, the tribe was spent several million dollars in legal and

consultant fees in order to participate in various Xcel/NMC proceedings, either at the

state or federal levels. The money we have spent, in order to participate in these

proceedings, is money that we could have used for other community purposes. In

addition, the Tribe has also established the Prairie Island Police Department. And

although the Tribe receives no funding from XceI/NMC for its Police Department, PIPD

19

Draft NUREG-1437, Supplement 39 A-1 17 October 2009
Appendix A

is and will most likely always be the first responder for any incident at PINGP. The

settlement monies paid to the Tribe by Xcel/NMC are far less than the costs and expenses

the Community has incurred as a result of the PINGP.

The negative socioeconomic impacts to the Prairie Island Indian Community cannot be 15-o-SE (continued)

overlooked and must be disclosed in the SEIS. As the tax information shows the

egregious disparity between the tribe and Red Wing, the school district, and the county.

The Community bears the greatest risk and receives the least amount of benefit.

Electricity Supply and Transmission

Electricity produced at PINGP is sent out on the highest capacity 345 kV lines right along "

the PINGP-PIIC property line, directly across the road from several Community I 15-p-OS

residences, and away from the Community. Remarkably, the Community receives its

electricity from power generation facilities hundreds of miles away, with the associated

problems of delivery and quality.

Traffic Concerns

Section 2.8.2 of the ER (Transportation) discusses the number of employees traveling to

the PINGP and the various routes they might take. The ER states that all employees

travel east on Sturgeon Lake Road and then take a right onto the plant access road, just

west of the reservation boundary. It is further stated that employees leave the plant via

the same roadways. This is not accurate. Many employees exit the plant at 3PM via

Wakonade to Sturgeon Lake Road, though the reservation, because they do not want to

stop at the intersection of the service road and Sturgeon Lake Road (a 4-lane road) and

make a left-hand turn across two lanes of traffic. Again, this serves to underestimate the 1 5-q-SE

traffic impacts to the Prairie Island Indian Community from plant activities.

During the steam generator replacement project, 750 workers (in addition to the 700 or so

outage workers and the 685 PINGP permanent and long-term contract staff) will be

coming to Prairie Island, using the one primary access road, Sturgeon Lake Road. The

SEIS scope should be expanded to disclose how this additional traffic to the PINGP,

related to the steam generator project, would impact the Prairie Island Indian Community.

Environmental Justice

Section 2.5.3.1 of the ER (Minority Populations) discusses minority or low-income

populations within a 50-mile radius. Section 2.5.3.1 describes how the ER identified

minority populations using NRC guidance. The section concludes with the statement that

"Except for the Prairie Island Indian Community, the census block groups containing

minority populations are[] predominately in the Minneapolis area and more than thirty 15-r-EJ

miles from PINGP." (ER at 2-23)

Chapter 2, Site and Environmental Interfaces, is concluded with the statement that

"Having evaluated environmental conditions in the vicinity of the PINGP site in this

20

October 2009 A-1 18 Draft NUREG-1437, Supplement 39
Appendix A

section and assessed potential impacts of license renewal in Chapter 4, NMC has not

identified any obvious cumulative impacts and has not extended the discussion of

potential cumulative impacts into Chapter 4, Environmental Consequences of the

Proposed Action and Mitigating Actions." ER at 2-41.

In Section 4.1.3 of the ER ("NA" License Renewal Issues), states, "the NRC does not

require information from applicants, but noted that it will be addressed in individual

reviews (I0CFR51). Environmental justice demographic information is provided in

Section 2.5.3. ER at 4-3

No analysis of impacts to minority populations from license renewal was disclosed in the

ER, other than to identify the Prairie Island Indian Community as a minority community.

The ER's very limited discussion of environmental justice does not contain any valuation

of impacts on the minority or disadvantaged communities identified in the ER.

Regulatory Guide 4.2S1, Section 4.22 (Environmental Justice) states that the need for and

the content of an analysis of environmental justice will be addressed in plant-specific

reviews (Table B-i). It is clear from NRC Regulatory Guide 4.2S1 that the NRC expects

the ER to analyze environmental justice issues. Therefore, the Community believes that

the ER is deficient with regard to environmental justice.

Even though radiation protection in general may be a Category 1 issue, the Category 2

issue of environmental justice is an overarching site specific issue, and if there is a

disproportionate impact on a minority group from license renewal activities, including

radiation protection, it must be evaluated. In summary, the Community is raising two

issues about the adequacy of the ER's environmental justice analysis. One is the absolute

lack of any evaluation of impact in the ER on minority groups. The ER has not disclosed

the information the Community believes it is expected to disclose, so that Commission

may properly consider, and publicly disclose, environmental factors that may cause harm

to minority and low-income populations that would be disproportionate to that suffered

by the general population.

The second issue is the absence of any analysis in the ER on the potential impacts of

radiation on a potentially predisposed cancer minority group, the Prairie Island Indian

Community. In this regard, the Community believes that the proposed action may have

significant adverse impacts on the minority group identified in the ER, that is the Prairie

Island Indian Community, because the impacts to the Community were not adequately

evaluated.

The EIS scope must consider non-radiological health effects. In 2005, we commissioned

a public health study (conducted by the University of Minnesota), which documented that

many of our youth experience increased levels-of stress and anxiety because of health and

safety fears related to the power plant. These are the same youth who will be our leaders

in the future, the people with whom future Xcel and NRC representatives will be working

over the re-licensing period (McGovern, et al. 2006).

15-r-EJ (continued)

15-s-EJ

1 5-t-HH

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Draft NUREG-1437, Supplement 39 A-1 19 October 2009
Appendix A

Severe Accidents

If a severe accident were to occur, the Prairie Island Indian Community would be

financially devastated. The Tribe's primary source of revenue could not be easily

replaced and would have a severely detrimental economic impact to the Tribe. The

impacts to the Tribe's culture would be immeasurable and irreparable. Because of these

concerns, the Community is particularly interested in the sufficiency of the severe

accident mitigation alternatives (SAMA) analysis.

According to the NRC GEIS, "the generic analysis of severe accidents applies to all

plants and that the probability weighted consequences of atmospheric releases, fallout

onto open bodies of water, releases to groundwater, and societal and economic impacts of

severe accidents are of small significance for all plants. However, alternatives to mitigate

severe accidents must be considered for all plants that have not considered such

alternatives."

The ER explains how the SAMA analysis includes modeling to determine which SAMA

would be the most cost beneficial. The ER however, does not describe the modeling in

sufficient detail for the Community to understand how the benefits of the SAMA were

calculated. The Prairie Island Indian Community is very unique and will not readily fit

into a conventional model of averted risks. In particular, the lost revenue from the

Treasure Island Resort represents a unique "cost" for an averted severe accident that will

not fit well in a conventional model of radiological impacts.

We request that the NRC to evaluate site-specific -economic data in the SAMA discussion 15-u-PA

of the SEIS. Prairie Island is our only home; our business (which can only be located on

our reservation) is our primary means of providing benefits and services to our

Community. If there was a severe accident, the Tribe would lose its primary revenue

source, many members would lose their primary income source (that does not include

future members), over 1,600 people would lose their jobs, several hundred vendors would

lose lucrative contracts, and the Tribe could no longer provide benefits and services to

our Community. Our largest business, the Treasure Island, is not easily re-located.

Federal laws and regulations govern not only how a Tribal gaming facility operates, but

also where a Tribal gaming facility can be located. See 25 U.S.C. § 2719 (provisions

governing tribal gaming on lands acquired after 1988).

Economic data must also include the value of our Community's buildings, facilities and

infrastructure, as well as the value of our tribal members' home sites (I acre), the value of

their homes, and the costs of re-establishing an Indian Tribe (which includes land

acquisition, legal costs, and infrastructure development). Since tribal land cannot be sold

(or bought) it may be difficult to place a monetary value on tribal members' homes and

property. One cannot simply re-establish an Indian Tribe elsewhere; Federal law also

governs the transfer of land into Trust for non-gaming purposes. See 25 U.S.C. § 465 and

25 C.F.R. § 151.

This issue is of paramount importance to our community.

22

October 2009 A-120 Draft NUREG-1437, Supplement 39
Appendix A

Connected Actions and Cumulative Impacts

The Community believes that there are "connected" actions that must be included in the

scope of the SEIS, which were not included in the ER. The SEIS must go beyond the

narrow scope of the continued operation of the two reactors at the PINGP and the steam

generator replacement project to include the extended power uprate and dry cask storage

expansion proposed by Xcel/NMC. In addition, the cumulative effects of the actions

(proposed action and connected actions) must be included in the SEIS scope. Connected,

similar, or cumulative actions generate direct, indirect, and cumulative impacts.

Dry Cask Storage Expansion and Extended Power Uprate

On May 16, 2008, Xcel/NMC filed a Certificate of Need (CON) application with the

Minnesota Public Utilities Commission (PUC) requesting the use of 35 additional dry

casks, so the PINGP can operate another twenty years beyond its currently licensed life.

In its CON application to the PUC, Xcel/NMC states that the current Independent Spent

Fuel Storage Installation (ISFSI), currently licensed by the NRC under a Part 72 sitespecific license to use/store up to 48 casks until 2013, would have to be expanded to

accommodate the additional casks. It is expected that Xcel will request a license

amendment from the NRC to increase the allowed storage beyond 48 casks sometime in

2018. To accommodate the increased number of casks, the storage pad will have to be

expanded. Xcel/NMC anticipates constructing two new concrete storage pads, designed

for a single row of casks, adjacent to the south side of the existing storage pads. When

completed (sometime in 2020), the new storage pad will hold up to 98 casks (license

renewal term plus decommissioning).

In the above-mentioned CON application, NMC/Xcel also requested that the PINGP be

allowed to operate at a higher rate (i.e., extended power uprate). The PINGP is licensed

by the NRC for an output of 1044 MW (522 MW each unit); the uprate will add 164 MW

for a total of 1208 MW.

The ER for the license renewal application contains no information about the

environmental impacts of the uprate. The Safety Analysis Report (SAR) for the license

renewal application contains some information about the uprate.

State EIS Scoping

On August 25, 2008 the MN Department of Commerce (DOC) issued a draft

environmental scoping document, which describes impacts (i.e., health, safety, and

environmental) from both the extended power uprate and dry cask storage expansion that

will be evaluated in the state EIS. In addition, the DOC held a public meeting on

September 10, 2008 to solicit comments and suggestions regarding the scope of the

environmental review that the DOC will conduct.

15-v-CI/OS/RW

15-w-OS/RW

15-x-ER

15-y-ERILR

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Draft NUREG-1437, Supplement 39 A-121 October 2009
Appendix A

According to the CON application, Xcel/NMC, expects that the dry cask storage

expansion will increase radiation levels (expected to be 0.36 mrem) and the extended

power uprate will increase water use (both surface and ground water) by up to 10 percent,

increase the temperature of the circulating water outfall, and also increase radioactive

releases by 10 percent. Individually these impacts are expected to be within their

respective permitted limits, but there is no information regarding the cumulative impacts.

Cumulative impacts are generally limited to what is foreseeable. The NRC's Regulatory

Guide 4.2S1, Preparation of Supplemental Environmental Reports for Applications to

Renew Nuclear Power Plant Operating Licenses (Regulatory Guide 4.2S 1), requires that

Chapter 2 of the ER (Site and Environmental Interfaces) identify and describe "known

and reasonably foreseeable Federal and non-Federal projects and other actions in the

vicinity of the site that may contribute to the cumulative environmental impacts of license

renewal and extended plant operation."

Section 2.11 of the ER (Known or Reasonably Foreseeable Projects in Site Vicinity)

discusses the status of industrial facilities in the three counties, such as projects related to

Lock and Dam No. 3, Treasure Island Resort and Casino and a couple of hydro-electric

plants nearby. There is no disclosure, however, of the Certificate of Need for the

extended power uprate, the increase in casks, or the planned expansion of the ISFSI, even

though these applications were submitted one month after the PINGP license renewal

application was submitted to the NRC. It seems that one month into the future (from the

submission of the license renewal application) is both reasonable and foreseeable.

Without expanded dry cask storage, the PINGP cannot continue to operate. Although the

PINGP does not need to operate at a higher power, it does not seem likely that

Xcel/NMC would invest resources in the uprate project unless the company was sure of a

favorable decision from the NRC relative to relicensing for an additional 20 years.

There is mention in Chapter 9 (Status of Compliance) of the need to get approval from

the MN Public Utilities Commission (PUC) for additional dry cask storage, but there is

no disclosure of the extended power uprate proposal or how either relates to cumulative

impacts at the PINGP.

According to 40 CFR 1508.25, connected actions are "actions that are closely related and

therefore should be discussed in the same impact statement." Furthermore, actions are

connected if they "i) automatically trigger other actions which may require environmental

impact statements; ii) cannot or will not proceed unless other actions are taken previously

or simultaneously; and iii) are interdependent parts of a larger action and depend on the

larger action for their justification.

The NRC's EIS scope must include all of these projects-the relicensing of the PINGP,

the extended power uprate of the PINGP, the expansion of dray cask storage at the

PINGP, and the steam generator replacement activities--and a disclosure of all the

related impacts. These projects are all currently proposed by NMC/Xcel and are

expected to occur in the very near future.

15-y-ER/LR (continued)

I

24

October 2009 A-1 22 Draft NUREG-1437, Supplement 39
Appendix A

Cumulative Impacts

As mentioned above, connected, similar, or cumulative actions generate direct, indirect,

and cumulative impacts. Cumulative effects or impacts are neither discussed nor

considered in the ER. According to Regulatory Guide 4.2Sl, Chapter 2 of the ER must

identify and describe "known and reasonably foreseeable Federal and non-Federal

projects and other actions in the vicinity of the site that may contribute to the cumulative

environmental impacts of license renewal and extended plant operation." Also as

discussed above, there are pending NMC/Xcel projects that the Community believes

contributes to the cumulative impact (i.e., dry cask storage expansion and extended

power uprate).

Chapter 2 of the ER is concluded with the statement "NMC has not identified any

obvious cumulative impacts and has not extended the discussion of potential cumulative

impacts into Chapter 4, Environmental Consequences of Proposed Actions and

Mitigating Actions." ER at 2-41. To the Community, this seems like a faulty conclusion,

given that connected actions are not discussed and that the Prairie Island Indian

Community, its land, resources, and people are barely mentioned.

The Prairie Island Indian Community is subjected to a number of impacts that have a

potential cumulative effect:

" Health effects (stress, increased cancer vulnerability)

* Operational radiological releases

• Operation of the ISFSI and increased levels of radiation

• High-voltage power lines immediately adjacent to homes

" Disregard of cultural impacts(i.e., burial mounds)

" Emergency preparedness concerns (one entrance/exit road)

" Socio-economic impacts (impacts on the tribe's culture, traffic, possible water

impacts)

• Cost to the tribe of being involved in (or opposing) proceedings

* Cost to tribe to educate members of Congress on PINGP issues, and waste issues

Mitigations measures to eliminate or reduce the level of adverse impacts should be

considered for each Category 2 issue. No mitigation was offered or discussed.

As mentioned previously, members of the Prairie Island Indian Community may have

exposure pathways (water, food, air) that may be different from typical or "average"

consumer, thereby placing the tribal consumer at a greater risk. For example, many

1 5-z-CI/ER

15-aa-EJ

15-bb-EJ

25

Draft NUREG-1437, Supplement 39 A-123 October 2009
Appendix A

tribal members consume native plants for traditional purposes (direct consumption,

medicines, teas, ceremonies) that are not typically part of any monitoring program. Many

of our community members have been living on Prairie Island since the plant went online. Tribal members typically do not move in and out of the community. We are

concerned about the human health effects from 60 years of low-level exposure, as many

of our community members already have compromised health.

The scope of the SEIS Environmental Justice disclosure must include all of these factors.

Alternatives to Relicensing the PINGP

It must be noted that if the "No Action" alternative (i.e., the NRC does not renew the

license for the PINGP, PINGP ceases operation and is decommissioned) would have a

LARGE POSITIVE impact on the Prairie Island Indian Community. As mentioned

previously, our community derives no financial (or other) benefit from the presence of

the PINGP, other than provisions outlined in the limited 2003 Settlement Agreement, and

yet we bear the greatest risks. This aspect was not evaluated in Chapter 7 of the ER.

Therefore the scope of the EIS must also include an evaluation of all-the positive impacts

that might arise from the No Action alternative.

Other Issues

Water Issues

It is noted that the gaging station at Prescott, WI (13 miles away) just south of Hastings,

MN, where the St. Croix River enters the Mississippi, is cited and used by the PINGP to

show annual mean flow values for the Mississippi River (Section 2.2.1.1). The Prairie

Island Indian Community, in coordination with the US Geological Survey (USGS),

operates a gaging station just .5 miles north of the plant (at the marina). The tribe's

gaging station may be useful in depicting more accurate mean flow values. The scope of

the SEIS and future modeling efforts should utilize data from this closer gaging station,

as it more accurately reflects the Mississippi River conditions.

Army Corps of Engineers Projects

There is no information about the Army Corps of Engineers (ACE) planned drawdown of

Pool 3 in an effort to restore native vegetation in Sturgeon Lake. This must be included

in the scope of the EIS, especially with regard to the possibility of low flow or drought

conditions, and the proposed uprate (which is expected to draw an additional 10 percent

from the Mississippi River).

15-bb-EJ (continued)

15-cc-AS

15-dd-SW

15-ee-OS/SW

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October 2009 A-124 Draft NUREG-1437, Supplement 39
Appendix A

Temperature Increases

As noted above, the proposed extended power uprate will increase the temperature of the

PINGP's cooling water discharge water. This temperature increase must be evaluated as

it relates to the proposed action (i.e., 20 year extended operation period).

Electromagnetic Fields

We understand that there is no consensus among scientists whether the electromagnetic

energy emanating from the power lines would have a measurable human health impact.

Some studies suggest exposure to EMF's increases the risk for certain diseases.

Since there is no scientific consensus on whether human health is compromised, there is

NO assurance that there are NO adverse health effects (i.e., chronic health effects,

increased risks to cancer). In fact, the United States EPA's Office of Radiation and

Indoor Air offers only two recommendations for people who want to protect themselves

from possible risks from power lines to reduce their exposure: "[ilnereasing the distance

between you and the source" and "[1]imiting the time spent around the source." (See

"Electric and Magnetic Field (EMF) Radiation from Power Lines," available at

www.ena.gov/radtown/power-lines.htm l. Needless to say, these are severe options for a

people whose ancestors have lived on Prairie Island for generations. We recommend that

the scope of the EIS include health impacts to members of the Prairie Island Indian

Community resulting from exposure to electromagnetic energy and radiation emanating

from the PINGP's transmission lines. Members of our community live extremely close

to the power lines.

Terrorism

Though not mentioned (and certainly not imagined), the 1996 GElS does not discuss

potential environmental and health impacts resulting from a terrorist attack on a nuclear

power plant must be part of the EIS scope. This is now a very real and very credible

threat to the health and safety of our people, since the PINGP is right next door to us.

The Community believes that the scope of the EIS must include an analysis of the

environmental impacts from a terrorist attacks to the PINGP.

15-ff-OS

15-gg-HH

15-hh-OS

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Draft NUREG-1437, Supplement 39 A-125 October 2009
Appendix A

Conclusion

The Prairie Island Indian Community is the largest, most diverse and culturally significant

population adjacent to the Prairie Island Nuclear Generating Plant. Since we bear the greatest

risks from PINGP operation, with less benefit than other populations in the vicinity, it is our

responsibility to ensure that the adverse impacts of continued operation of PINGP on our

Community and the surrounding environmental resources are adequately disclosed and

mitigated.

We appreciate this opportunity to provide these comments on the scope of the EIS that will be

prepared by the NRC to disclose and evaluate impacts from the relicensing of the PINGP. This

issue, the PINGP and its associated waste storage facility is the most important environmental

issue for our community.

Respectfully,

Ro'nald Johnso

Tribal Counci resident

Lucy Tayld

Tribal Council Secretary

Johnny Johnson

Tribal Council Vice-President

ictoria ilfTeasurer "Wi-e

Tribal Council Treasurerv .

Tribal Council Assistant Secretary/Treasurer

Cc: Terry Virden, BIA

28

October 2009 A-126 Draft NUREG-1437, Supplement 39
Appendix A

References

American Cancer Society. 2006. Minnesota Cancer Facts and Figures 2006. Available

at: http://www.cancerplanni.orz/Minnesota Cancer Facts and Figures.html.

Baker PJ, Hod DG. Meta-analysis of standardized incidence and mortality rates of

childhood leukemia in proximity to nuclear facilities. European Journal of Cancer

Care2007;16:355-363.

Birdnature.com. 2008. "North American Migration flyways." Available at:

www.birdnature.com/flywavs.html.

BFS (German Federal Office of Radiation Protection). 2007. Background information on

the KiKK Study. Available at:

http://www.bfs.de/en/kerntechnik/kinderkrebs/kikk.htmi/printversion.

Boden, P. January 2008. Cultural Resources Assessment for the Prairie Island Nuclear

Generating Plant, Goodhue County, MN).

Couleeaudubon.org. 2006. "Mississippi Flyway Birding Festival." Available at:

http://www.couleeaudubon.ora-festival06 checklist.html.

Ducks Unlimited. 2008. "Upper Mississippi River." Available at:

http://www.ducks.org/conservation/initiativel 9.aspx.

Duvevitz, H. 2001. An evaluation of the ecological significance of the Vermillion

Bottoms and Lower Cannon River area. Unpublished report. MN Department of Natural

Resources.

Espey, D., MD, Xiao-Cheng Wu, MD, MPH; et al. 2007. Annual Report to the Nation on

the Status of Cancer, 1975-2004, Featuring Cancer in American Indians and Alaska

Natives. Available at:

http://www3.interscience.wiley. eom/ceii-bin/fulltext/ 11633062 1/HTMLSTART.

Gardner, MJ, Hall, AJ, Downes S, et al. Follow-up of children born to mothers resident

in Seascale, West Cumbria (birth cohort). BMJ 1986;295:822-827.

Hoffmann, W., Terschueren, C., and Richardson, D. Childhood Leukemia in the Vicinity

of the Geesthacht Nuclear Establishments near.Hamburg, Germany. Environmental

Health Perspectives, 2007, Vol. 115(6): 947-952.

Kaatsch, P, Spix, C., Schulze-Rath, R., Schmiedel, S., and Blettner, M. 2007. Leukemia

in young children living in the vicinity of German nuclear power plants. International

Journal of Cancer 2007; 122: 721-736.

29

Draft NUREG-1437, Supplement 39 A-127 October 2009
Appendix A

McGovern, P.M., Stedman-Smith, M., Alexnader, B. 2006. Prairie Island Indian

Community, Feasibility Health Study, Final Report.

Minnesota Department of Health. 2005. Cancer in Minnesota, 1988-2002. Available at:

http://www.health.state.mn.us/divs/hNcd/cdee/mcss/camn2005index.html.

Silva-Mato A., Viana, D., Fernandez-San Martin, M.I. 2003. Cancer risk around the

nuclear power plants of Trillo and Zorita (Spain). Occup Environ Med 2003; 60:521-

527.

Spix, C., Schmiedel, S., Kaatsch, P. Case-control study on childhood cancer in the

vicinity of nuclear power plants in Germany 1980-2003. European Journal of Cancer

2008, 44:275-284.

US Atomic Energy Commission (AEC). May 1973. Final Environmental Statement

related to the Prairie Island Nuclear Generating Plant, Northern States Power Company,

Docket Nos. 50-282, 50-306.

US Geological Survey. 2007. "About the Upper Mississippi River System." Available at:

http://www.umesc.usgs.gov/umesc about/about umrs.html.

US Geological Survey. 2007. Abundance, Diversity, and Productivity of

SongbirdsONesting in Upland and Floodplain Forests of the flUpper Mississippi River

Basin. " Available at:

http://www.umesc.usgs.gov/terrestrial/migratory birds/mknutson 5002534.html.

US Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement for

License Renewals of Nuclear Plants (NUREG-1437).

US Fish and Wildlife Service. July 2008. "Higgins Pearly Eye Mussel." Available at:

http://www. fws.Rov/midwest/endangered/clams/higminseve/higzins fs.html.

Xcel Energy, Application to the MN Public Utilities Commission for Certificate of Need

for the Prairie Island Nuclear Generating Plant. May 16, 2008. Available at:

http://energyfacilities.puc.state.mn.us/Docket.html?ld=19602.

30

October 2009 A- 128 Draft NUREG-1437, Supplement 39
Appendix A

The following pages contain the comments

made by Michael Schultz during the

NRC public scoping meetings held on July 30, 2008

Draft NUREG-1437, Supplement 39 A-129 October 2009
Appendix A

Wing.

MICHAEL SCHULTZ: My name is Michael

3 Schultz. I'm a member of the Red Wing City Council.

4 This past week we passed a resolution

supporting Prairie Island Nuclear Generating Plant

license renewal, and we would like to read into the

record our resolution.

"Whereas, the Prairie Island Nuclear

Generating Plant became operational with the start-up

1 of Unit . reactor in December 1973 and Unit 2 reactor

11 in December 1974; and

12 "Whereas, Prairie Island has operated

13 safely and efficiently for more than 30 years,

14 generated a record 8.89 million megawatt hours of 16-a-SR

15 electricity in 2007, and its 100 megawatts of

16 electrical generating capacity remain vital to

17 Minnesota's economy; and

1e "Whereas Xcel Energy has continually

19 reinvested in the Prairie Island facility to assure

2C the continued safe, clean, reliable and affordable

21 production of electricity for Minnesota-s homes,

22 businesses, and factories; and

23 "Whereas, the 700 permanent jobs at

24 Prairie Island and the extensive use of contractors

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October 2009 A-130 Draft NUREG-1437, Supplement 39
Appendix A

..28.

for ongoing maintenance and special projects are

recognized as vitally important to the economies of

the City of Red Wing and Goodhue County; and

"Whereas, Xcel Energy announced in the

fall of 2004 that it intended to renew the license of

both units at Prairie Island for an additional 20

years; and

"Whereas, Xcel Energy submitted an.

application to renew Prairie Island's operating

licenses for its two units to the United States

Nuclear Regulatory Commission on April 15, 2008; and

"Whereas, Nuclear Regulatory Commission

is the Federal agency charged with oversight of our

nation's nuclear facilities and encourages public

input and comment on license renewal proceedings; and

"Whereas, the Prairie Island Nuclear

Generating Plant has been a good neighbor to the

communities located in Goodhue County and Pierce

County for more than three decades;

"Now, therefore, be it resolved that the

City of Red Wing City Council supports the renewal of

the licenses for the nuclear generating facilities at

Prairie Island to assure their continued operation of

safe, affordable and integrally important component

16-a-SR (continued)

)

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Draft NUREG-1437, Supplement 39 A-1 31 October 2009
Appendix A

of Minnesota' s electric power supply system for

another 20 years; and

"Be it further resolved that the City of

Red Wing will present a copy of this resolution to

the Nuclear Regulatory Commission."

Thank you.

MR. RAKOVAN: Thank you, sir.

Next we'll go to Ron Johnson, followed by

Katie Himanga and Scott Arneson.

RON JOHNSON: Good afternoon. My name is

Ron Johnson. I'm president of the Prairie Island

Tribal Council and the Prairie Island Indian

Community.

I've represented my community for several

years, and as president I have the obligation to

ensure the health and welfare of the community, which

includes also the environment down there.

I'm here today as the continuing

operation of the Prairie Island Nuclear Generating

Plant is one of our most important issues for our

community. In fact, most community members have had

concerns about the plant since it went online in

16-a-SR (continued)

1973.

The Prairie Island Indian Community is a

NEAL R.GROSS

COURT REPORTERS AND TRANSORGERS

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October 2009 A-132 Draft NUREG-1437, Supplement 39
Appendix A

The following pages contain the comments

made by Andrija Vukmir during the

NRC public scoping meetings held on July 30, 2008

Draft NUREG-1437, Supplement 39 A-133 October 2009
Appendix A

...................................................... 24.

we' re certainly not going to say you can't just

because you didn't fill out a yellow card, but we're

going to start with the yellow cards that we have.

4 The first card that I have is Andi

* Vukmir. From there we'll be going to Michael Schultz,

and then, third, Ron Johnson.

So Andy?

ANDRIJA VUKMIR: Good afternoon, the NRC,

Xcel, and also public concerned.

1 I've lived here in Red Wing for the past

11 25 years. I'm a strong advocate in support of the - 17-a-SN

12 nuclear energy.

1i At this time I urge you, the NRC, and

14 support from the public to support both a license

i renewal process for existing nuclear plants as well > 17-b-SR

16 as to work putting policies in place to support

17 building of new power plants in the future.

1 Nuclear energy keeps American business

19 competitive, and the plants themselves are incredible

2C job resources for the Red Wing and the neighboring

21 communities. 17-c-SN

22 As a nation, the U.S. Department of

23 Energy projects that the U.S. electrical demand will

24 rise about 25 percent by the year 2030. This means

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October 2009 A-134 Draft NUREG-1437, Supplement 39
Appendix A

_.25;

that our nation will need hundreds of new power

plants to provide electricity for homes and continued

economic growth here in Red Wing and the neighboring

communities, and of course Goodhue County is included

there, in all.

Nuclear power plants are the lowest-cost

producers of electricity by providing a reliable and

affordable source of electricity, and nuclear energy

helps to keep American businesses competitive.

Nuclear plants are sources of local job

growth here in Red Wing.

And nuclear power plants, which do not

emit any carbon dioxide, account for the majority of

voluntary reduction in greenhouse gas emissions in

the electrical power sector, according to a 2007

report from Power Partners, a partnership between the

electric power industry and the U.S. Department of

Energy.

The nation's nuclear power plants are

among the safest, secure individual facilities in the

United States. Multiple layers of physical security

together with high levels of operating performance

protect plant workers, the public, and the

environment.

)

17-c-SN (continued)

'I

NEAL R. GROSS COURT REPORTERS AND TRANSORIERS

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Draft NUREG-1437, Supplement 39 A-135 October 2009
Appendix A

The recent Bird Island Nuclear Plant

emergency drill conducted last week was a successful

exercise and part of the support team.

4 The primary concern of Xcel is the health

and safety of the public. The spent fuel is not a

6 threat to the public. Under an integrated management

approach, spent fuel remains safely stored in the

1 7-d-RW

nuclear power plants until being moved to consolidate

in long-term storage facilities.

1 Eventually the United States will follow

1 France, Japan, England, and other places and will

12 recycle the spent fuel to extract the energy there

13 and place the remaining usable end product at a

14 repository at Yucca Mountain, Nevada.

15 And in closing, I am thankful for the

16 opportunity of having clean nuclear power to produce

11 electricity. I urge the NRC and the public, working

18 together as a team with Xcel, to support the license 1 7-e-SR

I renewal process for Prairie Island's Units 1 and 2

2C and to put policies in place to promote building new

21 power plants in order to meet the projected

22 electrical demands.

23 MR. RAKOVAN: Thank you, sir.

24 Michael Schultz from the city of Red

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

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October 2009 A-136 Draft NUREG-1437, Supplement 39
Appendix A

The following pages contain the comments

made by Mike Wadley during the

NRC public scoping meetings held on July 30, 2008

Draft NUREG-1437, Supplement 39 A-137 October 2009
Appendix A

1 collaboration up to this point, and we believe that

2 the necessity of energy to our community has

3 certainly been recognized by the plants that we've

4 had here up to this time.

5 And I believe the County Board will be

6 considering the full impact of the relationship and

offering their opinions on the future and also their

8 opinions on any concerns that may be identified, and

9 we will be reporting back to them on the comments

10 that we're hearing here today as well.

1i Thank you.

12 MR. RAKOVAN: Thank you, gentlemen.

13 The last person that I have in terms of

14 filling out the yellow cards is Mike Wadley from Xcel

15 Energy.

16 MIKE WADLEY: Thank you.

17 Good afternoon. My name's Mike Wadley.

18 I'm the site vice president for the Prairie Island

19 Nuclear Generating Plant, and I'm here today to

20 provide Xcel Energy's support and perspective of our

18-a-SR

21 request for renewal of the operating license for

22 -Prairie Island Units 1 and 2.

23 The mission of everyone that works at

24 Prairie Island is clear: It's safe, clean, reliable,

NEAL R. GROSS

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October 2009 A-138 Draft NUREG-1437, Supplement 39
Appendix A

34:2

and affordable operation with the health and safety

of the public and our employees being number one

priority.

Two of our key values include being a

good neighbor and a steward of the environment in

which we operate.

Our 700 employees are highly experienced,

well-trained, committed to the safe and continuing

operation of Prairie Island. All of our employees go

through a rigorous training to continuously hone

their skills and learn new procedures and

information.

We continuously improve our training

based on advances in technology, best practices

learned through benchmarking of the industry and

feedback from our employees as they identify better

ways to gain the skills and knowledge that are needed

to operate the plant safely.

An example of this high-quality training

is our control room simulator that is used to train

and update our operators and staff members.

The NRC, Nuclear Regulatory Commission,

requires that employees undergo extensive

qualification programs utilizing this simulator to

N)

18-a-SR (continued)

I)

NEAL R. GROSS

COURT REPORTERS AND TRANSCRBERS

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Appendix A

-3-5.

receive a Nuclear Regulatory Commission operator

license, which qualifies an employee to work in the

plant's control room.

Once an operator receives their initial

license, they are required to spend five to six weeks

each year maintaining that qualification.

We also have extensive processes and

detailed procedures that are continuously reviewed

and modified to cover every aspect of our operation.

We have an exhaustive set of procedures that cover

operation, maintenance, engineering, training,

security, and emergency response.

Our emergency response procedures and

drills, for example, examine just how well our

employees react to an event of an emergency. The

emergency plan focuses on health and safety, health

and safety of the public, health and safety of our

employees, and safety of the plant.

Emergency response drills are conducted

several times a year to test our abilities and to

carefully analyze areas in which we can improve.

The rigorous standards we abide by are

set and reviewed through both the Nuclear Regulatory

Commission and the Federal Emergency Management

18-a-SR (continued)

18-b-NS

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October 2009 A-140 Draft NUREG-1437, Supplement 39
Appendix A

Agency.

We have a collaborative approach to

emergency planning at Prairie Island which results in

a team effort between employees, Goodhue and Dakota

Counties of Minnesota, Pierce County in Wisconsin,

and the states of Minnesota and Wisconsin, the

Nuclear Regulatory Commission, and other federal

agencies.

All told, more than 2,000 people are part

of the emergency response teams throughout these

organizations.

We have consistently demonstrated our

ability to protect the health and safety of the

public and our employees. We will continue to do so

as we partner with the NRC to maintain the highest

standards of safety excellence.

The Prairie Island plant has been well

maintained over its lifetime. Approximately every 18

months we perform refueling outages on each unit.

During these outages, the plant staff, with the help

of hundreds of contractors, complete more than 1300

maintenance activities and replace one-third of the

plant's reactor core fuel, this in addition to

ongoing maintenance, inspection, and regular testing

18-b-NS (continued)

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Draft NUREG-1437, Supplement 39 A-141 October 2009
Appendix A

...........

activities that are performed during the period in

which the plant is operating at full power.

Over the years we've continued to make

capital improvements to a wide range of equipment to

.take advantage of technology and improve materials to

ensure safe and reliable operation.

For example, Unit l's steam generators

were replaced in the fall of 2004, and both reactor

vessel heads were replaced as well.

As computer training methods evolve,

we're able to broaden the range of training to our

work force. As we move forward, we continue to

upgrade and improve equipment and technology at the

Prairie Island Nuclear Generating Plant.

Since the plant began operating Unit 1 in

1973 and Unit 2 in 1974, there have been many changes

showing the nuclear industry's dedication and

commitment to an improved record of safety and

security.

I. would add that the regulations set

forth by the Nuclear Regulatory Commission that we

abide by and which we're held accountable to are the

most stringent of any industry, and the inspections

are more rigorous to maintain this record of safe and

18-b-NS (continued)

)

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE, N.W

(202) 2344433 MSHINGTON. D.C. 20005-3701 w.Mnakuss m.'

October 2009 A-142 Draft NUREG-1437, Supplement 39
Appendix A

1 reliable operation.

2 One example is. security at all U.S.

3 nuclear plants. Security at nuclear plants across

4 the nation has received increased emphasis and

5 scrutiny since -the tragic events of September 11th,

6 2001.

Security at Prairie Island is no

a exception, and we have taken extensive precautions

9 and implemented new policies and procedures to ensure

10 the safety and well being of the community and our

11 employees is maintained. This includes several 1 8-c-NS

12 million dollars in additional resources and new

13 equipment.

14 We continue to work with the Nuclear

15 Regulatory Commission to review and evaluate our

16 security procedures to make certain that the most

17 effective methods are being utilized.

18 Prairie Island is a strong supporter of

19 the environment. We take great care in our daily

20 activities to ensure that the environment is well

21 protected.

22 Our employees feel fortunate that the

23 location of the Prairie Island plant rests on the 18-d-SR

24 banks of the Mississippi River. The site is home to

NEAL R. GROSS

COURT REPORTERS AND TRANSCRSERS

023 RJIODE ISLAND AVE, N.W.

(202) 234-4433 MSHINGTON, D.C 20005-3701

Draft NUREG-1437, Supplement 39 A-143 October 2009
Appendix A

... . ... .. . . ...... . . . ... ............ . .. . .... ... ......... .. .... ..... . . . . ... _3 9 .

1 numerous wildlife, aquatic species, and plant life.

2 Our efforts have made Prairie Island a safe and sound

18-d-SR (continued)

3 habitat for many years and will continue in the

4 future.

5 On a different note, Prairie Island is

more than a power plant operated by highly-skilled

workers; it is part of the community. Not only does

8 the plant rely upon local companies for goods and

9 services, but our employees live in and contribute to

I1 the surrounding communities.

11 We are very proud of our participation

12 and our willingness to give back to the community in

1 8-e-SR

13 a variety of ways, including serving on city and town

14 boards, leaders in civic and community organizations,

15 as sports coaches, on church committees, boards, and

16 councils as well as members of charitable

17 organizations.

18 Our employees also raise money for local

19 United Way campaigns, American Cancer Society as well

20 as Make-A-Wish of Minnesota, to name a few.

21 In conclusion, the Prairie Island plant

22 has been a productive contributor to the energy needs

23 in Minnesota and a valuable asset and good neighbor 18-f-SR

24 to the surrounding communities. We remain committed

NEAL R. GROSS

COURT REPORTRS AND TRANSCGRGRS

1323 WODE ISLAND AV. N.W.

(202) 234-4433 ,SHINGTON- DC 20005-3701

October 2009 A-144 Draft NUREG-1437, Supplement 39
Appendix A

........... ... ............ ............. ........... .... ....... ..... 4........................................................ .0

to operating safely, reliably, economically and

2 focused on being a good neighbor and a steward to the

3 environment. •"18-f-SR (continued)

4 I and the employees of Prairie Island

look forward to serving you and meeting the needs of

6 the community for many years to come.

Thank you.

MR. RAKOVAN: At this point that is all

the yellow cards that I had filled out for people who

1 knew that they wanted to make a comment when they

11 first came into the meeting.

12 At this point I just want to make sure

13 that there's nobody else who wanted to come give

14 comments or if anybody else has a question that they

15 would like to ask in a public forum.

16 (No response.)

17 Okay. Just keep in mind pretty much

1 anybody with one of these name tags on is probably an

19 NRC employee. We're all going to be hanging around

2C after the meeting, so if you have a question or a

21 topic that you'd like to address with them, grab one

22 of them; and if they're not the right person to have

23 that conversation, they can hopefully find the person

24 who is the right person.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRBERS

1323 RHODE ISLAND AME, N.W.

(20Z 234-4433 WASHINGTON. D,C 200M543701 Owigm1to

Draft NUREG-1437, Supplement 39 A-145 October 2009
Appendix A

Prairie Island Nuclear Generating Plant,

Units 1 and 2

Public Scoping Process

Comments and Responses

A.1. Alternative Energy Sources

The following comment pertains to the no-action alternative outlined by NEPA:

15-cc-AS

The NRC staff will address alternatives to the continued operation of PINGP 1 and 2,

including the no-action alternative (not renewing the licenses) in Chapter 8 of the SEIS.

The following comments pertain to the scope of alternatives to be discussed in the

DSEIS:

13-i-AS;15-k-AS

The NRC staff will evaluate environmental impacts associated with various reasonable

alternatives to the continued operation of PINGP 1 and 2 in Chapter 8 of the SEIS.

The following comments pertain to using either natural gas or a combination of wind and

natural gas to power an alternative to PINGP 1 and 2:

4-a-AS; 5-s-AS; 14-b-AS

The NRC staff will evaluate environmental impacts associated with various reasonable

alternatives to the continued operation of PINGP 1 and 2 in Chapter 8 of the SEIS.

The following comment pertains to using the PINGP site for an alternate industrial

purpose:

5-t-AS

The comment describes the potential conversion of the PINGP 1 and 2 site to an energy

and research facility that would produce hydrogen in addition to providing electricity. The

NRC staff's examination of alternatives in Chapter 8 of the SEIS will be limited to energy

alternatives that can replace or offset the capacity currently provided by PINGP 1 and 2.

As PINGP 1 and 2 do not currently produce hydrogen or provide a site for energy

research and development efforts, alternatives to continued operation of PINGP 1 and 2

will not need to fulfill these roles.

The following comment pertains to the greenhouse gas emissions and efficiency of

energy generation technologies:

4-a-AS

The NRC staff will provide a comparison of greenhouse gas emissions from a variety of

energy generation technologies in Chapter 6 of the SEIS. The NRC staff analysis of

alternatives in Chapter 8 will also address relative levels of greenhouse gas emissions

for alternatives.

The following comment pertains to policy or planning considerations in meeting future

energy needs:

4-a-AS

October 2009 A-146 Draft NUREG-1437, Supplement 39
Appendix A

The NRC does not play a role in energy planning or energy policy development, though

the NRC staff does take into account existing policies and regulations when evaluating

energy alternatives.

A.2. Aquatic Resources

The following comment pertains to the impacts to aquatic resources from the

impingement and entrainment of fish and shellfish:

11-a-AR

The comment is related to aquatic ecology, specifically impingement, entrainment, and

heat shock analysis. As part of its environmental review process and SEIS, NRC will

review and assess pertinent information regarding impingement, entrainment, and heat

shock in Chapters 2 and 4 of the SEIS.

The following comment pertains to fish kills related to the cooling and intake systems of

PINGP 1 and 2:

11-c-AR/SW

The comment is related to operation of the plant's cooling system, and its effects in

terms of fish kills and other thermal impacts. Potential impacts associated with the

plant's cooling system will be discussed in Chapter 4 of the SEIS. Additionally, NRC will

identify potential mitigation measures to limit fish kill impacts in Chapter 4 of the SEIS.

The State, not the NRC, manages thermal impacts through the National Pollutant

Discharge Elimination System (NPDES) permitting process.

The following comments pertain to impacts from thermal discharges of the PINGP 1 and

2 cooling systems:

4-b-AR/SW; 7-a-ARJRW/SW; 7-b-AR/CRPSW; 7-d-AR/CRPSW

These comments are related to operation of the plants cooling system, specifically the

effects of the thermal discharge, on aquatic and other resources. NRC will discuss the

potential impacts associated with the plant's thermal discharge will be presented in

Chapter 4 of the SEIS. The State, not the NRC, regulates thermal discharges through

the NPDES permitting process.

The following comment pertains to impacts to aquatic resources from exotic species:

11-e-AR

The comment is related to aquatic ecology. Invasive and exotic species as well as other

impacts will be discussed in Chapters 2 and 4 of the SEIS. The State, not the NRC,

regulates discharge contaminants through the NPDES permitting process. Additionally,

Chapter 2 will provide a description of measures undertaken to control biofouling at

PINGP 1 and 2.

The following comments pertain to the area of consideration for the aquatic ecology

review and analysis provided in the SEIS:

5-e-AR; 8-a-AR/PA/SW

Issues pertaining to the area of consideration for review of aquatic ecology impacts are

site specific, or Category 2 issues, and will be discussed in Chapters 2 and 4 of the

SEIS.

Draft NUREG-1437, Supplement 39 A-147 October 2009
Appendix A

The following comment pertains to potential releases of radioactive materials into the

water:

4-d-AR/HH

All nuclear plants were licensed with the expectation that they would release small

quantities of 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 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 through the ADAMS electronic reading room

through the NRC website. The NRC routinely inspects all licensees to ensure their

compliance with these regulatory limits.

Additionally, in the spring of 2006, the National Research Council of the National

Academies published, "Health Risks from Exposure to Low Levels of Ionizing Radiation,

BEIR VII Phase 2." The major conclusion of the report is that current scientific evidence

is consistent with the hypothesis that there is a linear, no-threshold dose response

relationship between exposure to ionizing radiation and the development of cancer in

humans. This conclusion is consistent with the system of radiological protection that the

NRC uses to develop its regulations. The NRC evaluated the BEIR VII report and

discussed its findings in a report to the Commission (SECY 05-0202; Accession Number

ML052640532). The NRC concluded that the BEIR VII report does not support the need

for fundamental revision to the International Commission on Radiological Protection

recommendations. Therefore, it is the NRC's position that the NRC's regulations

continue to be adequately protective of public health and safety and the environment

and that none of the findings in the BEIR VII report warrant changes to the NRC

regulations. The BEIR VII report does not say there is no safe level of exposure to

radiation; it does not address "safe versus not safe." It does continue to support the

conclusion that there is some amount of cancer risk associated with any amount of

radiation exposure and that risk increases with exposure and exposure rate. It does

conclude that risk of cancer induction at the dose levels in NRC's and EPA's radiation

standards is very small. Similar conclusions have been made in all of the associated

BEIR reports since 1972 (BEIR 1, 111, and V). The comment does not provide any new

and significant information and will not be evaluated further.

A.3. Cultural Resources

The following comments pertain to issues regarding potential impacts to.cultural

resources surrounding the PINGP 1 and 2 site and compliance with the National Historic

Preservation Act:

7-b-AR/CR/SW; 7-d-AR/CR/SW; 10-a-CR; 15-m-CR;

The comments are related to the potential impacts. to cultural, archaeological, and

historical resources. NRC staff is aware of the Prairie Island Indian Community's

concern for the archaeological sites both on and within the vicinity of the PINGP 1 and 2

facilities. The comments are noted, and the impacts of extended operation of the PINGP

October 2009 A-14.8 Draft NUREG-1437, Supplement 39
Appendix A

1 and 2 on cultural, archaeological, and historical resources will be assessed and

discussed in Chapters 2 and 4 of the SEIS. Additionally, the PRIC is a cooperating

agency and will assist the NRC staff in its review. Several other tribes, the Bureau of

Indian Affairs, and the Minnesota State Historic Preservation Office have been contacted

by, and may provide their views to, the NRC under Section 106 of the National Historic

Preservation Act.

A.4. Cumulative Impacts

The following comments pertain to the assessment of a cumulative impacts analysis in

the SEIS:

5-g-CI/LR; 5-h-Cl; 5-r-CI/LR; 5-q-CI/LR; 5-w-CI; 5-x-CI; 11-f-CI; 15-z-CI/ER

As part of the environmental review process, the NRC evaluates the potential for

cumulative impacts of operations (as defined in 40 CFR 1508.7) during the renewal

term. Chapter 4 of the SEIS will analyze the impacts of the proposed action in

conjunction with other past, present, and reasonably foreseeable future actions at

PINGP 1 and 2 and the activities of other industrial facilities and/or Federal agency

actions in the area. As part of NRC's environmental review and SEIS, all pertinent

information pertaining to cumulative impacts will be reviewed and assessed.

The following comments pertain to the cumulative impacts of spent fuel storage and

spent fuel waste:

5-m-CI/RW; 5-o-CI/RW; 15-v-CI/OS/RW

Onsite storage of spent nuclear fuel is a Category 1 issue. Additionally, waste

management issues were evaluated in the GElS and determined to be a Category 1

issue. Issues classified as Category 1 in Table B-1 of 10 CFR Part 51 have been

determined in the GElS to have similar impacts across all sites and are, therefore, not

reevaluated in the SEIS unless new and significant information is identified that would

lead the NRC staff to reevaluate the GEIS's conclusions. During the environmental

review, the NRC staff makes a concerted effort to determine whether any new and

significant information exists for the specific site being evaluated that would change the

generic conclusion for a Category 1 issue into a Category 2 issue. Category 2 issues are

site specific issues which must be thoroughly analyzed by the applicant as part of its

submittal and included in detail in its environmental report. The NRC staff then

independently evaluates the issue as part of its SEIS.

While cumulative impacts are site specific issues for some resources, these comments

pertaining to cumulative impacts of spent fuel storage and spent fuel waste are not

within the scope of the environmental review and will not be evaluated further.

The following comments pertain to establishing a baseline for cumulative impacts in the.

areas of groundwater and hydrologic resources, human health, and aquatic resources:

5-r-CI/LR

Cumulative impacts on each of these resource areas are a Category 2 issue and will be

addressed in Chapter 4 of the SEIS under cumulative impacts.

Draft NUREG-1437, Supplement 39 A-149 October 2009
Appendix A

A.5. Environmental Justice

The following comments pertain to the analysis of environmental justice within the SEIS:

6-b-EJ/UR; 6-f-EJ/RW/UR; 11-d-EJ/SW

The comments are noted. Environmental justice is an issue specific to the plant and will

be addressed in Chapter 4 of the SEIS. To perform a review of environmental justice in

the vicinity of the nuclear power plant, the NRC staff examines the geographic

distribution of minority and low-income populations within 50 miles (80 km) of the site

being evaluated. The staff uses the most recent census data available. Once the

locations of minority and low-income populations are identified, the staff determines the

extent to which these populations may be disproportionately affected.

The environmental impacts of various individual operating uranium fuel cycle facilities

are outside the scope of license renewal but are addressed in separate EISs prepared by NRC. These documents include analyses that address human health and

environmental impacts to minority and low-income populations. Electronic copies of

these EISs are available through the NRC's public Web site under Publications Prepared

by NRC Staff document collection of the NRC's Electronic Reading Room at

http://www.nrc.gov/readinq-rm/doc-collections/; and the NRC's Agency wide Documents

Access and Management System (ADAMS) at http://www.nrc.-ov/readingrm/adams.html.

The following comments pertain specifically to the Prairie Island Indian Community

(PIIC), and the inclusion of the PIIC in the analysis of environmental justice within the

SEIS:

5-f-EJ/RW; 15-d-HH/EJ; 15-f-HH/EJ; 15-r-EJ; 15-s-EJ; 15-aa-EJ; 15-bb-EJ;

The PIIC is a minority population living within the 50 mile (80 kin) radius of PINGP 1 and

2. PIIC will be included in the environmental justice analysis in Chapter 4 of the SEIS.

Additionally, the PIIC is a cooperating agency and will assist the NRC staff in its review

of environmental justice issues.

A.6. Environmental Report

The following comments raise concerns pertaining to the information included within the

Environmental Report submitted by the applicant:

3-c-ER/HH; 5-a-ER; 6-i-ER/HH; 13-c-ER/LR; 15-a-ER; 15-g-ER; 15-x-ER; 15-y-ER/LR; 15-zCI/ER

The comments assert that the Environmental Report failed to include information

regarding the impacts of routine releases of radioactive effluents, the effects of

continued operations on the health and on the Prairie Island Indian Community, the

effects of the plant's requested power uprate, the expansion of dry cask storage, and the

replacement of the steam generator. The comments will be considered, as appropriate,

during the environmental review for the license renewal of PINGP 1 and 2.

A.7. Groundwater

The following comments pertain indirectly and cumulatively to impacts to the

groundwater resources, mostly from tritium, surrounding PINGP 1 and 2:

October 2009 A-150 Draft NUREG-1437, Supplement 39
Appendix A

5-b-GW/SW; 15-e-GW

Groundwater is a Category 2 issue and discussed in Chapters 2 and 4 of the SEIS. The

comments, in general, are related to the public concerns regarding potential leaks at

PINGP 1 and 2 and the PIIC's as well as the public's request for additional information

and monitoring data on the level and extent of potential environmental impacts. The

requirement to obtain additional data and information on known leaks is part of the

ongoing operating license and is currently being addressed by NRC and the applicant.

The comments, as they pertain to requiring additional environmental data, are not within

the scope of the environmental review. However, the environmental impacts of identified

leaks are within the scope of the environmental review and will be addressed in

Chapters 2 and 4 of the SEIS.

In addition, NRC regulations require licensees to make surveys, as necessary, to

evaluate the potential hazard of radioactive material released in order to assess doses to

members of the public and workers, recent discoveries of releases at other plants

indicate that undetected leakage to groundwater from facility structures, systems, or

components can occur resulting in unmonitored and unassessed exposure pathways to

members of the public. The NRC has identified several instances of unintended tritium

releases, and all available information shows no threat to the public. Nonetheless, the

NRC is inspecting each of these events to identify the cause, verify the impact on public

health and safety, and review licensee plans to remediate the event. The NRC also

established a lessons learned task force to address inadvertent, unmonitored liquid

radioactive releases from U.S. commercial nuclear power plants. This task force

reviewed previous incidents to identify lessons learned from these events and determine

what, if any, changes are needed to the regulatory program. Detailed information and

updates on these liquid releases can be found on the NRC public website at

http://www.nrc.gov/reactors/operating/ops-experience/grndwtr-contam-tritium.htm.

A.8. Human Health

The following comments pertain to the assessment of human health impacts in the SEIS:

3-c-ER/HH; 4-d-AR/HH; 6-a-HH; 6-c-HH; 6-d-HH; 6-e-HH; 6-h-HH/LR; 13-a-HH; 13-j-HH; 15-dHH/EJ; 15-f-HH/EJ; 15-h-HH

The NRC staff will address the radiological impacts to human health during its evaluation

of the PINGP 1 and 2 license renewal application. However, this issue is a Category 1

issue. Issues classified as Category 1 in Table B-1 of 10 CFR Part 51 have been

determined in the GElS to have similar impacts across all sites and are, therefore, not

reevaluated in the SEIS unless new and significant information is identified that would

lead the NRC staff to reevaluate the GEIS's conclusions. During the environmental

review, the NRC staff makes a concerted effort to determine whether any new and

significant information exists for the specific site being evaluated that would change the

generic conclusion for a Category 1 issue into a Category 2 issue. Category 2 issues are

site specific issues which must be thoroughly analyzed by the applicant as part of its

submittal and included in detail in its Environmental Report. The NRC staff then

independently evaluates these issues as part of its SEIS.

Draft NUREG-1437, Supplement 39 A-151 October 2009
Appendix A

The following comments pertain to the monitoring of radioactive effluents:

3-b-HH; 3-c-ER/HH 4-e-HH; 6-a-HH; 6-c-HH; 6-d-HH; 6-e-HH; 6-h-HH/LR; 6-i-ER/HH; 13-j-HH;

15-h-HH

The applicant's current operating license requires it to conduct environmental monitoring

programs. Upon identification of a new pathway of potential radiological release, the

applicant is required by 10 CFR Part 20 to perform radiological surveys to evaluate the

radiological hazard from the release. While current operating issues are outside of the

scope of the environmental review of this license renewal application, the NRC staff will

consider the radioactive effluents monitoring and release points as part of its evaluation

of the PINGP license renewal application. The staff will perform a historical review of the

radioactive effluents released from the plant and of the data from the applicant's

radiological environmental monitoring program to determine if there are any significant or

unusual trends that warrant additional evaluation. NRC's environmental review is

confined to environmental matters relevant to the extended period of operation

requested by the applicant. Radiological data relevant to the environmental review will

be discussed as appropriate in Chapters 2 and 4 of the SEIS.

This issue is a Category 1 issue. Issues classified as Category 1 in Table B-1 of 10 CFR

Part 51 have been determined in the GElS to have similar impacts across all sites and

are, therefore, not reevaluated in the SEIS unless new and significant information is

identified that would lead the NRC staff to reevaluate the GEIS's conclusions. During the

environmental review, the NRC staff makes a concerted effort to determine whether any

new and significant information exists for the specific site being evaluated that would

change the generic conclusion for a Category 1 issue into a Category 2 issue. Category

2 issues are site specific issues which must be thoroughly analyzed by the applicant as

part of its submittal and included in detail in its Environmental Report. The NRC staff

then independently evaluates these issues as part of its SEIS.

NRC regulations require licensees to control and limit releases 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 to

unrestricted areas during normal operation as low as is reasonably achievable (as

described in the NRC's regulations in 10 CFR Part 50.34a) and comply with radiation

dose limits for the public as given in the regulations in 10 CFR Part 20.

In addition, NRC regulations require licensees to have various effluent and

environmental monitoring programs so that the impacts from plant operations are

minimized and the extent of releases are accurately recorded and reported. The NRC

requires licensees to report plant discharges and results of environmental monitoring

around their plants to ensure that potential impacts are detected and reviewed.

Licensees must also participate in an interlaboratory comparison program, which

provides an independent check of the accuracy and precision of environmental

measurements. Licensees are required to keep accurate records on releases to the air

and water. In annual reports, licensees identify the amount of liquid and airborne

radioactive effluents discharged from plants and calculateassociated doses. Licensees

also must report environmental radioactivity levels around their plants annually. These

reports, which are available to the public, include sampling from thermoluminescent

dosimeters (which measure radiation dose levels); airborne radioiodine and particulate

samplers; samples of surface, groundwater, and drinking water and downstream

shoreline sediment from existing or potential recreational facilities; and samples of

ingestion sources such as milk, fish, invertebrates, and broad-leaf vegetation. The NRC

October 2009 A-1 52 Draft NUREG-1437, Supplement 39
Appendix A

conducts periodic onsite inspections of each licensee's effluent and environmental

monitoring programs to ensure compliance with NRC requirements. The NRC

documents licensee effluent releases and the results of their environmental monitoring

and assessment effort in inspection reports that are available to the public.

The following comments pertain to exposure from electromagnetic fields (EMF):

15-gg-HH

The NRC staff will evaluate the actions taken by PINGP to ensure that the impacts from

acute electromagnetic fields from their power lines adhere to safety standards issued by

the National Electrical Safety Code. These safety standards are designed to ensure that

any impacts remain within acceptable limits. This is a Category 2 issue that every plant

seeking license renewal must address in its Environmental Report. The NRC staff will

include a discussion of PINGP 1 and 2's program to manage acute electromagnetic

fields in Chapters 2 and 4 of the SEIS.

For impacts related to the chronic exposure to electromagnetic fields, biological and

physical studies of 60-Hz electromagnetic fields have not found consistent evidence

linking harmful effects with field exposures. There is currently no scientific consensus on

this issue. Therefore, the NRC staff will not perform a specific health assessment for

chronic exposure to EMF in the SEIS.

The following comments pertain to human health issues generically associated with

nuclear power generating facilities:

3-b-HH; 3-c-ER/HH; 15-h-HH

The GElS evaluated human health issues and determined them to be a Category 1

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 are noted but provide no new

and significant information and will not be evaluated further.

The following comments pertain to added risk due to proximity to PINGP 1 and 2:

4-e-HH; 15-d-HH/EJ

Human health issues were evaluated in the GElS and were determined to be Category 1

issues. The GElS evaluated radiation exposures to the public for all plants including

PINGP 1 and 2, and concluded that the impact was small. The information regarding

increases in the population around PINGP 1 and 2, possible changes in the age

distribution of that population, and increased radio-sensitivity of older people and other

sensitive populations does not change this evaluation. The maximum dose to any

member of the public living or working near PINGP 1 and 2 is well below one millirem

per year, which is well below the radiation standards set by EPA and NRC. These

comments provide no new and significant information regarding human health issues

and therefore will not be evaluated further.

The following comment pertains to the BEIR VII Phase 2 report:

3-c-ER/HH

Draft NUREG-1437, Supplement 39 A-153 October 2009
Appendix A

In the spring of 2006, the National Research Council of the National Academies

published, "Health Risks from Exposure to Low Levels of Ionizing Radiation, BEIR VII

Phase 2." The major conclusion of the report is that current scientific evidence is

consistent with the hypothesis that there is a linear, no-threshold dose response

relationship between exposure to ionizing radiation and the development of cancer in

humans. This conclusion is consistent with the system of radiological protection that the

NRC uses to develop its regulations. The NRC evaluated the BEIR VII report and

discussed its findings in a report to the Commission (SECY 05-0202; ADAMS No.

ML052640532). The NRC concluded the BEIR VII report does not support the need for

fundamental revision to International Commission on Radiological Protection

recommendations. Therefore, the NRC's regulations continue to be adequately

protective of public health and safety and the environment. None of the findings in the

BEIR VII report warrant changes to the NRC regulations. The BEIRVII report does not

say there is no safe level of exposure to radiation; it does not address "safe versus not

safe." It does continue to support the conclusion that there is some amount of cancer

risk associated with any amount of radiation exposure and that risk increases with

exposure and exposure rate. It does conclude that risk of cancer induction at the dose

levels in NRC's and EPA's radiation standards is very small. Similar conclusions have

been made in all of the associated BEIR reports since 1972 (BEIR 1, 111, and V). The

comment does not provide any new and significant information and will not be evaluated

further.

The following comment pertains to non-radiological human health concerns:

15-t-HH

The GElS evaluated human health issues related to plant operations during the period of

extended operations and determined that the issues are generic Category 1 issues.

These issues include both radiological and non-radiological health effects. The comment

is noted but because it provides no new and significant information, it will not be

evaluated further.

A.9. License Renewal and its Processes

The following comments pertain to the MOU between the NRC and the PIIC:

9-a-LR; 15-b-LR; 15-c-LR

The NRC and the PIIC signed an MOU pursuant to which the PIIC is a cooperating

agency and the NRC is the lead agency in four specific resource areas: environmental

justice, land use, cultural resources, and historic and archeological resources. The MOU

can be accessed through the NRC's Electronic Reading Room via ADAMS at accession

number ML081710160. These scoping comments are general in nature and do not

provide new information. Therefore, the comments will not be evaluated further.

The following comments pertain to the public's ability to provide public comments and

the time allotted for the public to do so:

3-a-LR; 5-g-CI/LR; 6-g-LR; 9-a-LR; 14-c-LR

The NRC has established an open process to permit all members of the public to

participate in the environmental scoping process. The NRC published a Federal Register

Notice (FRN) of its intent to conduct environmental scoping pertaining to the PINGP 1

and 2 license renewal application on July 22, 2008. The environmental scoping period

lasted for two months and closed on September 22, 2008. In this time, the NRC staff

October 2009 A-154 Draft NUREG-1437, Supplement 39
Appendix A

held two public meetings on July 30, 2008, to receive comments on the scope of the

environmental review. These meetings were advertised on the NRC public website, in

local newspapers, on notices posted throughout Red Wing, and by letter to individuals

and groups on the NRC's most current distribution list.

The NRC makes every effort to inform interested persons or parties of their opportunity

to be involved in the NEPA process. After the draft SEIS is published, the NRC staff will

issue a FRN of the availability of the document, and this FRN will also open a 75-day

period to comment on the draft SEIS. Additionally, the NRC staff will hold a public

meeting to receive comments on the draft SEIS. Comments can be provided to the NRC

in person, by mail, and by e-mail. These scoping comments identified above are general

in nature and do not provide new information. Therefore, the comments will not be

evaluated further.

The following comments pertain to the regulations and procedures regarding NRC staff's

review of information, assessment, and analysis during the environmental review

process, as well as the availability of information to the public:

5-q-CI/LR; 6-h-HH/LR; 13-b-LR

Pertaining to the staffs regulations on the environmental review process under NEPA,

10 CFR 51 contains the NRC regulations that implement NEPA. These regulations

define the NRC staff's scope of review and its analysis of information in the SEIS.

Regarding the availability of information to the public, the NRC is required to protect

information deemed sensitive. Before any NRC- or licensee-generated materials can be

released for public inspection, the NRC must complete a sensitivity review to ensure the

documents do not contain information that should be designated sensitive.

The following comments pertain to the environmental review process, how it determines

impacts on the environment, and how NRC staff should prepare its SEIS:

5-c-LR; 5-r-CI/LR; 5-u-LR; 5-v-LR; 15-y-ER/LR

As part of the environmental review process, the NRC evaluates site-specific data

provided by the applicant, other Federal agencies, State agencies, tribal and local

governments, as well as information from members of the public. In addition, the NRC

performs independent reviews of the plant-specific environmental impacts of license

renewal in accordance with NEPA and the NRC's requirements in 10 CFR Part 51. The

following technical areas are commonly included in the review: land use, ground and

surface water use, ground and surface water quality, air quality, aquatic resources,

terrestrial resources, threatened and endangered species, radiological impacts,

socioeconomic factors, environmental justice issues, historical and archaeological

resources, related federal project activities, postulated accidents, uranium fuel cycle and

solid waste management, decommissioning, alternatives to license renewal, and

irreversible or irretrievable resource commitments. Site specific Category 2 impacts will

be discussed in Chapter 4 of the SEIS. Other areas may be included as a result of

information obtained during the NRC staff's review or from public comments during or

following meetings that are held in the vicinity of the nuclear power reactor.

The following comments pertain to the availability of the applicant's license renewal

application:

13-c-ER/LR; 13-d-LR; 14-a-LR

10 CFR 51.66 specifies the requirements for availability and distribution of the

applicant's environmental reports required by the applicant. In addition to providing

Draft NUREG-1437, Supplement 39 A-155 October 2009
Appendix A

copies to the NRC, applicants must maintain the capability to generate additional copies

of the environmental report for distribution to Federal, State, and local officials, and any

affected Indian tribes. Applicants are not required to provide copies of the application to

other interested persons or parties. However, once a license renewal application is

accepted for review by the NRC, the publicly available portions of the application are

included on the NRC's website on the license renewal webpage at

http://www.nrc.gov/reactors/operatingq/licensing/renewal.html under the link entitled,

"Status of Current Applications and Industry Initiatives." Applications are also available

for public inspection in the NRC Public Document Room (PDR), located at One White

Flint North, 11555 Rockville Pike, Rockville, Maryland, 20852, or from the NRC's

ADAMS. The ADAMS Public Electronic Reading Room is accessible at

http://www.nrc.gov/reading-rm/adams/web-based.html. Copies of the application are

also available at the Red Wing public library.

A.10. Nuclear Safety

The following comments pertain to nuclear safety, the safety of operations at PINGP 1

and 2, and the safety of fuel storage:

5-z-NS; 11-b-NS; 18-b-NS; 18-c-NS

The NRC's environmental review is confined to environmental matters relevant to the

20-year period of extended period of operation requested by the applicant. Operational

safety issues and issues related to the safety of fuel storage are outside the scope of

10 CFR Part 51 and Part 54 and will not be evaluated further in the SEIS. The

comments provide no new information and, therefore, will not be evaluated further in the

context of the environmental review.

A.11. Outside of Scope

The following comment pertains to general background information about the NEPA

process:

5-1-OS

The comment provides general background information and is outside of the scope of

the environmental review process and, therefore, will not be evaluated further.

The following comments pertain to a proposed license amendment request regarding

transition to a new fuel type at PINGP 1 and 2:

5-y-OS/RW; 13-f-OS

License amendment requests completed during the original 40 year term or during the

term of extended operation if the license renewal is granted are reviewed by the NRC for

any environmental or safety concerns at the time of the amendment. These comments

are outside of the scope of the environmental review process and, therefore, will not be

evaluated further.

October 2009 A-1 56 Draft NUREG-1437, Supplement 39
Appendix A

The following comments pertain to the extended power uprate proposal by NSP and

issues of electricity supply:

5-i-OS; 5-k-OS/RW; 5-y-OS/RW; 15-p-OS; 15-v-CI/OS/RW; 15-w-OS/RW; 15-ee-OS/SW; 15-ffoS

The purpose and need for the proposed action (renewal of an operating license) is to

provide an option that allows for power generation capability beyond the term of the

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 does not assess the need for power as part of its

license renewal environmental review, and 10 CFR 51.95(c)(2) provides that the SEIS is

not required to discuss such need.

With respect to power uprates or any modifications made to increase power, these

actions are not within the scope of license renewal and they require a separate licensing

action. The NRC staff would prepare an Environmental Assessment (EA), or an EIS, if

needed, for the power uprate application. These comments provide no new and

significant information and will not be evaluated further.

The following comment pertains to issues surrounding security and terrorism:

15-hh-OS

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 license. Security issues are periodically reviewed and updated (and extended)

at every operating plant. These reviews will continue throughout the period of any

extended license. If issues related to security are discovered at a nuclear plant, they

would be addressed immediately, and any necessary changes reviewed and

incorporated under the operating license, rather than waiting for the period of extended

operation. 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 emergency and safeguard

contingency plans related to terrorist events will be incorporated and reviewed under the

operating license. The comments provide no new information and do not pertain to the

scope of license renewal as defined under 10 CFR Part 51 and 54. Therefore, the

comment will not be evaluated further.

A.12. Postulated Accidents

The following comments pertain to the severe accident mitigation alternatives (SAMA)

analysis:

8-a-AR/PA/SW; 15-u-PA

The comments are related to the impacts of design basis accidents and severe

accidents. The impacts of design basis accidents and severe accidents were evaluated

in the GElS and determined to be small for all plants; therefore, they are Category 1

issues. Technical issues classified as Category 1 in Table B-1 of 10 CFR Part 51 have

been generically evaluated in the GElS and are not reevaluated in the SEIS unless new

and significant information is identified that would lead the NRC staff to reevaluate the

GEIS's conclusions. During the environmental review, the NRC staff makes a concerted

effort to determine whether any new and significant information exists for the specific site

Draft NUREG-1437, Supplement 39 A-157 October 2009
Appendix A

being evaluated that would change the generic conclusion for a Category 1 issue into a

Category 2 issue. Category 2 issues are site specific issues which must be thoroughly

analyzed by the applicant as part of its submittal and included in detail in its

environmental report. The NRC staff then independently evaluates the issue as part of

its SEIS.

However, alternatives to mitigate severe accidents must be considered for all plants that

have not considered such alternatives. During the plant-specific environmental review of

PINGP 1 and 2, the NRC will determine whether there is any new and significant

information bearing on the previous analysis in the GELS. The applicant provided a

severe accident mitigation alternatives (SAMA) analysis as part of the license renewal

application for PINGP 1 and 2. The NRC staffs review of the SAMA analysis will be

discussed in Chapter 5 and Appendix F of the SEIS for PINGP 1 and 2.

Concerning the potential for accidental drawdown at Lock and Dam 3, this scenario is

outside the scope of the environmental review and will not be considered further.

Concerning the effects of a severe accident on the Prairie Island Indian Community

specifically, socioeconomic issues, including disproportionate effects to minority or lowincome communities,will be dicussed in Chapters 2 and 4 of the SEIS.

A.13. Radioactive Waste

The following comments pertain to long term storage of spent fuel:

5-j-RW; 5-k-OS/RW; 5-m-CI/RW; 5-n-RW; 5-o-CI/RW; 5-p-RW; 5-y-OS/RW; 5-aa-RW; 6-fEJ/RW/UR; 7-a-AR/RW/SW; 7-c-RW; 12-a-RW; 13-h-RW; 15-i-RW; 15-j-RW; 15-v-CI/OS/RW;

17-d-RW

Onsite storage of spent nuclear fuel is a Category 1 issue and the safety and

environmental effects of long-term storage of spent fuel onsite has been evaluated by

the NRC in the Waste Confidence Rule. The Commission believes there is reasonable

assurance that at least one mined geologic repository will be available within the first

quarter of the twenty-first century, and sufficient repository capacity will be available

within 30 years beyond the licensed life for operation of any reactor to dispose of the

commercial high-level waste and spent fuel originating in such reactor and generated up

to that time. In its Statement of Considerations for the 1990 update of the Waste

Confidence Rule (55 FR 38472), the Commission addressed the impacts of the disposal

of spent fuel discharged from the current fleet of reactors operating under existing and

renewed licenses and from a new generation of operating reactors. The rule was last

reviewed by the Commission in 1999 when it reaffirmed the findings in the rule (64 FR

68005). The rule is currently the subject of a notice of proposed rulemaking (73 FR

59547) that proposes to simplify the rule to state that spent fuel can be "stored safely

and without significant environmental impacts beyond the licensed life for operation

(which may include the term of a revised or renewed license) of that reactor at its spent

fuel storage basin or at either onsite or offsite ISFSIs until a disposal facility can

reasonably be expected to be available." Because the issue of spent fuel storage is a

Category 1, generic issue, comments regarding spent fuel storage are not within the

scope of the environmental review and will not be evaluated further.

The following comments pertain to the Independent Spent Fuel Storage Installation

(ISFSI) system in place at PINGP 1 and 2:

5-f-EJ/RW; 5-k-OS/RW; 5-y-OS/RW; 15-i-RW; 15-v-CI/RW; 15-w-OS/RW

October 2009 A- 1 58 Draft NUREG-1437, Supplement 39
Appendix A

The comments relate to spent fuel management and storage issues specifically those

regarding the PINGP 1 and 2 independent spent fuel storage installation (ISFSI). Waste

management issues and onsite storage of spent nuclear fuel were evaluated in the GElS

and determined to be a Category 1 issue. In addition, the safety and environmental

effects of long-term, onsite, storage of spent fuel onsite was addressed by the NRC, in

the Waste Confidence Rule (10 CFR 51.23). In the Waste Confidence Rule, Finding 4,

the Commission determined that spent fuel can be stored onsite for at least 30 years

beyond the licensed operating life, which may include the term of a renewed license. At

or before the end of that period, the rule asserts that spent fuel will be moved to a

permanent repository. In October 2008, the NRC proposed to revise Finding 4 in the

Waste Confidence Decision so that it reads as follows: "The Commission finds

reasonable assurance that, if necessary, spent fuel generated in any reactor can be

stored safely without significant environmental impacts for at least 60 years beyond the

licensed life for operation (which may include the term of a revised or renewed license)

of that reactor in a combination of storage in its spent fuel storage basin and either

onsite or offsite independent spent fuel storage installations."

The GElS is based on the assumption that storage of the spent fuel onsite is not

permanent. The SEIS for PINGP 1 and 2, is based on the same assumption.

With respect to the PINGP 1 and 2 ISFSI, specifically, any modifications to the ISFSI

pad or containers themselves may require separate licensing actions. NRC regards

these actions as part of the current operating licenses and thus they fall outside of the

scope of license renewal. These comments provide no new and significant information

and will not be evaluated further.

A.14. Shutdown and Decommissioning

The following comment pertains to how much time is budgeted for relicensing, and

whether or not PINGP 1 and 2 should be decommissioned:

13-e-SD

The NRC makes its decision whether or not to renew the license based on safety and

environmental considerations. The final decision on whether or not to decommission the

nuclear plant will be made by the utility, state, and federal (non-NRC) decision makers.

This final decision may be based on economics, energy reliability goals, environmental

considerations and potential impacts, and other objectives over which the other entities

may have jurisdiction.

The environmental review generally takes 22 months to complete if no hearing is

granted and 30 months if a hearing is granted.

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 GElS

and in NUREG-0586, Generic Environmental Impact Statement for Decommissioning

Nuclear Facilities, Supplement 1, Regarding the Decommissioning of Nuclear Power

Reactors, published in 2002. The findings from these two documents are used to

support the findings in the SEIS by the use of tiering. Tiering is a process by which

agencies eliminate repetitive discussions and focus on the more pertinent issues. The

effect of license renewal on the impacts of decommissioning will be discussed in

Chapter 7 of the SEIS.

Draft NUREG-1437, Supplement 39 A-159 October 2009
Appendix A

A.15. Socioeconomics

The following comments pertain to NRC staff's assessment of socioeconomics:

4-c-SE; 5-d-SE; 15-o-SE; 15-q-SE

The comments are related to the socioeconomic impacts associated with the continued

operation or closure of PINGP 1 and 2. Socioeconomic impacts such as housing,

transportation, taxes, employment, and land use are Category 2 issues. These issues

will be addressed in Chapters 2 and 4 of the SEIS.

A.16. Support for License Renewal

The following comments pertain to the support of PINGP 1 and 2 license renewal:

16-a-SR; 17-b-SR; 17-e-SR

The comments are in support of license renewal of PINGP 1 and 2, and are general in

nature. In addition, 10 CFR 51.95(c)(2) discussed the need for power, which is outside of

the scope of license renewal. These comments provide no new and significant

information and will not be evaluated further.

The following comments pertain to the support of Xcel Energy and NMC:

1-a-SR; 2-a-SR; 16-a-SR; 18-a-SR; 18-d-SR; 18-e-SR; 18-f-SR

The comments are in support of Xcel/NSP (formerly NMC/Xcel) and/or their

philanthropic activities. The comments are outside of the scope of the staff's

environmental review and will not be evaluated further.

A.17. Support for Nuclear Power

The following comments are in support of nuclear power, generally:

17-a-SN; 17-c-SN

The need for power is outside of the scope of license renewal and pursuant to 10 CFR

51.95(c)(2), need not be addressed in this SEIS. The purpose and need for the

proposed action (renewal of the PINGP 1 and 2 operating license) is to provide an option

that allows for power generation capability beyond the term of the current operating

licenses and thereby meet future system generating needs, as such needs may be

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

decisionmakers. These comments are outside the scope of the staffs environmental

review and will not be evaluated further.

A.18. Surface Water

The following comments pertain to the effects of thermal discharge on the Mississippi

River and other surface waterbodies:

4-b-AR/SW; 4-f-SW; 7-a-AR/RW/SW; 7-b-AR/CR/SW; 7-d-AR/CR/SW; 11-c-AR/SW; 11-dEJ/SW

The comments are related to operation of the plants' cooling system, specifically the

effects of thermal discharge on surface water, and aquatic and other resources. A

discussion of the potential impacts associated with the plants thermal discharge will be

presented in Chapter 4 of the SEIS.

October 2009 A-160 Draft NUREG-1437, Supplement 39
Appendix A

The following comments pertain to protecting the surface water resources as well as

assessing impacts to surface water resources near PINGP 1 and 2:

4-b-AR/SW; 5-b-GW/SW; 15-dd-SW

Water use and water quality issues are Category 2 issues and will be addressed in

Chapters 2 and 4 of the SEIS.

The following comments pertain to Lock and Dam 3, a U.S. Army Corps of Engineers

owned and operated facility and associated erosion impacts:

8-a-AR/PA/SW; 15-ee-OS/SW

Issues pertaining to the construction and safety of Lock and Dam 3 are not within the

scope of review for license renewal. However, concerns relating to the Mississippi River

and other surface waterbodies near PINGP 1 and 2 will be addressed in Chapter 4 of the

SEIS. Issues pertaining to water use and quality, including erosion, are Category 2

issues and will be addressed in Chapters 2 and 4 of the SEIS.

A.19. Terrestrial Resources

The following comment pertains to impacts to avian mortality within the transmission

line corridors surrounding PINGP 1 and 2:

15-1-TR

Impacts from bird collisions with transmission lines was determined to be a Category 1

issue in the GELS. Technical issues classified as Category 1 in Table B-1 of 10 CFR Part

51 have been generically evaluated in the GElS and are not reevaluated in the SEIS

because the conclusions reached would be the same as in the GELS, unless new and

significant information is identified that would lead the NRC staff to reevaluate the

GEIS's conclusions. During the environmental review, the NRC staff makes a concerted

effort to determine whether any new and significant information exists for the specific site

being evaluated that would change the generic conclusion for a Category 1 issue into a

Category 2 issue. This study, as well as other pertinent information concerning this

issue, will be discussed in Chapter 4 of the SEIS. However, this issue will remain

Category 1 unless the NRC staff finds new and significant information during the

environmental review.

Impacts to terrestrial ecology and non-threatened and endangered species are a

Category 1 issue. Impacts to threatened and endangered species, including any

protected avian species, is a Category 2 issue and will be addressed in Chapters 2 and

4 of the SEIS.

A.20. Threatened and Endangered Species and Essential Fish Habitat

The following comment pertains to the threatened and endangered Higgins eye

pearlymussel:

15-n-TE

The potential impacts of the continued operation of PINGP 1 and 2 on threatened and

endangered species is a site specific, or Category 2 issue and will be addressed in

Chapters 2 and 4 of the SEIS under aquatic resources. Further, NRC staff will issue a

Biological Assessment on the Higgins eye pearlymussel, which can be found in

Appendix D of the draft SEIS.

Draft NUREG-1437, Supplement 39 A-161 October 2009
Appendix A

A.21. Uranium Fuel Cycle

The following comments pertain to the uranium fuel cycle and waste management:

6-b-EJ/UR; 6-f-EJ/RW/UR; 13-g-UR

The NRC evaluated the impacts of the uranium fuel cycle which comprises uranium

mining and milling, the production of uranium hexafluoride, isotopic enrichment, fuel

fabrication, reprocessing of irradiated fuel, transportation of radioactive materials and

management of low level wastes and high level wastes related to uranium fuel cycle

activities. The wide range of activities associated with the uranium fuel cycle are

geographically located throughout the United States and affect a diverse population. The

impacts on the environment of the uranium fuel cycle is a Category 1 issue. Technical

issues classified as Category 1 in Table B-1 of 10 CFR Part 51 have been generically

evaluated in the GElS and are not reevaluated in the SEIS because the conclusions

reached would be the same as in the GELS, unless new and significant information is

identified that would lead the NRC staff to reevaluate the GEIS's conclusions. During the

environmental review, the NRC staff makes a concerted effort to determine whether any

new and significant information exists for the specific site being evaluated that would

change the generic conclusion for a Category 1 issue into a Category 2 issue. Category

2 issues are site-specific issues which must be thoroughly analyzed by the applicant as

part of its submittal and included in detail in its Environmental Report. The NRC staff

then independently evaluates the issue as part of its SEIS.

The NRC has conducted several transportation studies to evaluate the risk of

transportation of radioactive material. NUREG-0170 (NRC 1977b), supported NRC's

10 CFR Part 71, "Packaging and Transportation of Radioactive Material" rulemaking.

Based on this study, the Commission concluded that the transportation regulations are

adequate to protect the public against unreasonable risks from the transportation of

radioactive materials, including spent fuel. The NRC sponsored another study in the

1980s entitled, "Shipping Container Response to Severe Highway and Railway Accident

Conditions," NUREG/CR-4829 (Fischer et al. 1987), or the "Modal Study." Based on the

results of this study, the NRC staff concluded that NUREG-0170 overestimated spent

fuel accident risks by about a factor of three. In March 2000, the NRC initiated another

spent fuel study, "Reexamination of Spent Fuel Shipment Risk Estimates," NUREG/CR6672 (Sprung et al. 2000). This study focused on risks of a modern spent fuel transport

campaign from reactor sites to possible interim storage sites and/or permanent geologic

repositories. This study concluded that accident risks were much less than those

estimated in NUREG-0170 and that more than 99 percent of transportation accidents are

not severe enough to damage NRC-certified spent fuel casks. While very severe

accidents could cause cask damage, the studies show that releases of material would

be small and pose little risk to the local population/public. The most severe accidents

might cause greater releases, but their likelihood is so remote that the NRC considers

the risk to public health to be low. The comments are noted. However, they do not

provide any new and significant information and will not be evaluated further

October 2009 A-162 Draft NUREG-1437, Supplement 39
APPENDIX B

NEPA Issues for License Renewal of Nuclear Power Plants

October 2009 Draft NUREG-1437, Supplement 39

Appendix B

NEPA Issues for License Renewal of Nuclear Power Plants

Table B-1. Summary of Issues and Findings. This table is taken from Table B-1 in

Appendix B, Subpart A, to 10 CFR Part 51. Data supporting this table are

contained in NUREG-1437, Generic Environmental Impact Statement for

License Renewal of Nuclear Plants. Throughout this report, "Generic" issues

are also referred to as Category 1 issues, and "Site-specific" issues are also

referred to as Category 2 issues.

Issue Type of Issue Finding

Surface Water Quality, Hydrology, and Use

Impacts of Generic SMALL. Impacts are expected to be negligible during

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

Eutrophication.

Generic

Generic

Generic

Generic

Generic

Generic

Generic

refurbishment because best management practices are

expected to be employed to control soil erosion and

spills.

SMALL. Water use during refurbishment will not increase

appreciably or will be reduced during plant outage.

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.

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.

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.

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.

SMALL. Eutrophication has not been found to be a

problem at operating nuclear power plants and is not

expected to be a problem during the license renewal

term.

Discharge of

chlorine or other

biocides

Generic SMALL. Effects are not a concern among regulatory and

resource agencies, and are not expected to be a problem

during the license renewal term.

Draft NUREG-1437, Supplement 39 B-1 October 2009
Appendix B

Issue Type of Issue Finding

Discharge of Generic SMALL. Effects are readily controlled through NPDES

sanitary wastes and permit and periodic modifications, if needed, and are not

minor chemical expected to be a problem during the license renewal

spills term.

Discharge of other Generic SMALL. These discharges have not been found to be a

metals in problem at operating nuclear power plants with coolingwastewater tower-based heat dissipation systems and have been

satisfactorily mitigated at other plants. They are not

expected to be a problem during the license renewal

term.

Water use conflicts Generic SMALL. These conflicts have not been found to be a

(plants with once- problem at operating nuclear power plants with oncethrough cooling through heat dissipation systems.

systems)

Water use conflicts Site-specific SMALL OR MODERATE. The issue has been a concern

(plants with cooling at nuclear power plants with cooling ponds and at plants

ponds or cooling with cooling towers. Impacts on instream and riparian

towers using make- communities near these plants could be of moderate

up water from a significance in some situations. See § 51.53(c)(3)(ii)(A).

small river 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.

Accumulation of Generic SMALL. Accumulation of contaminants has been a

contaminants in concern at a few nuclear power plants but has been

sediments or biota satisfactorily mitigated by replacing copper alloy

condenser tubes with those of another metal. It is not

expected to be a problem during the license renewal

term.

Entrainment of Generic SMALL. Entrainment of phytoplankton and zooplankton

phytoplankton and has not been found to be a problem at operating nuclear

zooplankton power plants and is not expected to be a problem during

the license renewal term.

Cold shock Generic SMALL. Cold shock has been satisfactorily mitigated at

operating nuclear plants.with once-through cooling

systems, has not endangered fish populations or been

found to be a problem at operating nuclear power plants

with cooling towers or cooling ponds, and is not expected

to be a problem during the license renewal term.

Thermal plume

barrier to migrating

fish

Generic SMALL. Thermal plumes have not been found to be a

problem at operating nuclear power plants and are not

expected to be a problem during the license renewal

term.

October 2009 B-2 Draft NUREG-1437, Supplement 39
Appendix B

Issue

Distribution of

aquatic organisms

Type of Issue

Generic

Finding

SMALL. Thermal discharge may have localized effects

but is not expected to affect the larger geographical

distribution of aquatic organisms.

Premature

emergence of

aquatic insects

Generic

Gas

supersaturation

(gas bubble

disease)

Low dissolved

oxygen in the

discharge

Losses from

predation,

parasitism, and

disease among

organisms exposed

to sublethal

stresses

Stimulation of

nuisance organisms

(e.g., shipworms)

Generic

Generic

Generic

Generic

SMALL. Premature emergence has been found to be a

localized effect at some operating nuclear power plants

but has not been a problem and is not expected to be a

problem during the license renewal term.

SMALL. Gas supersaturation was a concern at a small

number of operating nuclear power plants with oncethrough 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.

SMALL. Low dissolved oxygen has been a concern at

one nuclear power plant with a once-through cooling

system but has been effectively mitigated. It has not been

found to be a problem at operating nuclear power plants

with cooling towers or cooling ponds and is not expected

to be a problem during the license renewal term.

SMALL. These types of losses have not been found to be

a problem at operating nuclear power plants and are not

expected to be a problem during the license renewal

term.

SMALL. Stimulation of nuisance organisms has been

satisfactorily mitigated at the single nuclear power plant

with a once-through cooling system where previously it

was a problem. It has not been found to be a problem at

operating nuclear power plants with cooling towers or

cooling ponds and is not expected to be a problem during

the license renewal term.

Aquatic Ecology (for plants with once-through and cooling pond heat dissipation systems)

Entrainment of fish

and shellfish in

early life stages

Site-specific SMALL, MODERATE, OR LARGE. The impacts of

entrainment are small at many plants but may be

moderate or even large at a few plants with once-through

and cooling-pond cooling systems. Further, ongoing

efforts in the vicinity of these plants to restore fish

populations may increase the numbers of fish susceptible

to intake effects during the license renewal period, such

that entrainment studies conducted in support of the

original license may no longer be valid. See §

51.53(c)(3)(ii)(B).

Draft NUREG-1437, Supplement 39 B-3 October 2009
Appendix B

Issue Type of Issue Finding

Impingement of fish Site-specific SMALL, MODERATE, OR LARGE. The impacts of

and shellfish impingement are small at many plants but may be

moderate or even large at a few plants with once-through

and cooling-pond cooling systems. See §

51.53(c)(3)(ii)(B).

Heat shock Site-specific SMALL, MODERATE, OR LARGE. Because of

continuing concerns about heat shock and the possible

need to modify thermal discharges in response to

changing environmental conditions, the impacts may be

of moderate or large significance at some plants. See §

51.53(c)(3)(ii)(B).

Aquatic Ecology (for plants with cooling-tower-based heat dissipation systems)

Entrainment of fish Generic SMALL. Entrainment of fish has not been found to be a

and shellfish in problem at operating nuclear power plants with this type

early life stages of cooling system and is not expected to be a problem

during the license renewal term.

Impingement of fish Generic SMALL. The impingement has not been found to be a

and shellfish 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 Generic SMALL. Extensive dewatering during the original

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)

Ground water use

conflicts (plants

using cooling

towers withdrawing

make-up water from

a small river)

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.

SMALL. Plants using less than 100 gpm are not expected

to cause any ground water use conflicts.

Generic

Site-specific

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).

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).

October 2009 B-4 Draft NUREG-1437, Supplement 39
Appendix B

Issue

Ground water use

conflicts (Ranney

wells)

Type of Issue

Site-specific

Ground water

quality degradation

(Ranney wells)

Generic

Finding

SMALL, MODERATE, OR LARGE. Ranney wells can

result in potential ground water depression beyond the

site boundary. Impacts of large ground water withdrawal

for cooling tower makeup at nuclear power plants using

Ranney wells must be evaluated at the time of application

for license renewal. See § 51.53(c)(3)(ii)(C).

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.

SMALL. Nuclear power plants do not contribute

significantly to saltwater intrusion.

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.

SMALL, MODERATE, OR LARGE. Sites with closedcycle 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).

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

Generic

Site-specific

Terrestrial Ecology

Refurbishment

impacts

Site-specific

Cooling tower

impacts on crops

and ornamental

vegetation

Cooling tower

impacts on native

plants

Bird collisions with

cooling towers

Generic

Generic

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.

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.

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.

Draft NUREG-1437, Supplement 39 B-5 October 2009
Appendix B

Issue Type of Issue Finding

Cooling pond Generic SMALL. Impacts of cooling ponds on terrestrial ecological

impacts on resources are considered to be of small significance at all

terrestrial resources sites.

Power line right of Generic SMALL. The impacts of right-of-way maintenance on

way management wildlife are expected to be of small significance at all

(cutting and sites.

herbicide

application)

Bird collisions with Generic SMALL. Impacts are expected to be of small significance

power lines at all sites.

Impacts of Generic SMALL. No significant impacts of electromagnetic fields

electromagnetic on terrestrial flora and fauna have been identified. Such

fields on flora and effects are not expected to be a problem during the

fauna license renewal term.

Floodplains and Generic SMALL. Periodic vegetation control is necessary in

wetland on power forested wetlands underneath power lines and can be

line right of way 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 expected

species 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 impacts

refurbishment (non- from plant refurbishment associated with license renewal

attainment and are expected to be small. However, vehicle exhaust

maintenance areas) emissions could be cause for concern at locations in or

near nonattainment or maintenance areas. The

significance of the potential impact cannot be determined

without considering the compliance status of each site

and the numbers of workers expected to be employed

during the outage. See § 51.53(c)(3)(ii)(F).

Air quality effects of Generic SMALL. Production of ozone and oxides of nitrogen is

transmission lines insignificant and does not contribute measurably to

ambient levels of these gases.

Land Use

Onsite land use Generic SMALL. Projected onsite land use changes required

during refurbishment and the renewal period would be a

small fraction of any nuclear power plant site and would

involve land that is controlled by the applicant.

October 2009 B-6 Draft NUREG-1437, Supplement 39
Appendix B

Issue Type of Issue Finding

Power line right of Generic SMALL. Ongoing use of power line right of ways would

way continue with no change in restrictions. The effects of

these restrictions are of small significance.

Human Health

Radiation Generic SMALL. During refurbishment, the gaseous effluents

exposures to the

public during

refurbishment

Occupational

radiation exposures

during

refurbishment

Microbiological

organisms

(occupational

health)

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)

Electromagnetic

fields - chronic

effects

Radiation

exposures to public

(license renewal

term)

Generic

Generic

Site-specific

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.

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.

SMALL. Occupational health impacts are expected to be

controlled by continued application of accepted industrial

hygiene practices to minimize worker exposures.

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).

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.

Generic

Site-specific

Uncategorized

Generic

Draft NUREG-1437, Supplement 39 B-7 October 2009
Appendix B

Issue Type of Issue Finding

Occupational Generic SMALL. Projected maximum occupational doses during

radiation exposures the license renewal term are within the range of doses

(license renewal experienced during normal operations and normal

term) maintenance outages, and would be well below

regulatory limits.

Socioeconomic Impacts

Housing impacts Site-specific SMALL, MODERATE, OR LARGE. Housing impacts are

expected to be of small significance at plants located in a

medium or high population area and not in an area where

growth control measures that limit housing development

are in effect. Moderate or large housing impacts of the

workforce associated with refurbishment may be

associated with plants located in sparsely populated

areas or in areas with growth control measures that limit

housing development. See § 51.53(c)(3)(ii)(I).

Public services:

public safety, social

services, and

tourism, and

recreation

Public services:

public utilities

Public services:

education

(refurbishment)

Public services:

education (license

renewal term)

Offsite land use

(refurbishment)

Offsite land use

(license renewal

term)

Public services:

transportation

Generic

Site-specific

Site-specific

Generic

Site-specific

Site-specific

Site-specific

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 on site- and projectspecific factors. See § 51.53(c)(3)(ii)(I).

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).

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).

October 2009 B-8 Draft NUREG-1437, Supplement 39
Appendix B

Issue Type of Issue Finding

Historic and Site-specific SMALL, MODERATE, OR LARGE. Generally, plant

archaeological refurbishment and continued operation are expected to

resources 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 Generic SMALL. No significant impacts are expected during

(refurbishment) refurbishment.

Aesthetic impacts Generic SMALL. No significant impacts are expected during the

(license renewal license renewal term.

term)

Aesthetic impacts of Generic SMALL. No significant impacts are expected during the

transmission lines license renewal term.

(license renewal

term)

Postulated Accidents

Design basis Generic SMALL. The NRC staff has concluded that the

accidents environmental impacts of design basis accidents are of

small significance for all plants.

Severe accidents Site-specific SMALL. The probability weighted consequences of

atmospheric releases, fallout onto open bodies of water,

releases to ground water, and societal and economic

impacts from severe accidents are small for all plants.

However, alternatives to mitigate severe accidents must

be considered for all plants that have not considered such

alternatives. See § 51.53(c)(3)(ii)(L).

Uranium Fuel Cycle and Waste Management

Offsite radiological Generic SMALL. Offsite impacts of the uranium fuel cycle have

impacts (individual

effects from other

than the disposal of

spent fuel and high

level waste)

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 technetium-99 are small.

Draft NUREG-1437, Supplement 39 B-9 October 2009
Appendix B

Issue Type of Issue Finding

Offsite radiological Generic

impacts (collective

effects)

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 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].

October 2009 B-10 Draft NUREG-1437, Supplement 39
Appendix B

Issue Type of Issue Finding

Offsite radiological Generic

impacts (spent fuel

and high level

waste disposal)

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 yetto be developed, no

repository application has been completed or reviewed,

and uncertainty is inherent in the models used to evaluate

possible pathways to the human environment. The NAS

report indicated that 100 millirem per year should be

considered as a starting point for limits for individual

doses, but notes that some measure of consensus exists

among national and international bodies that the limits

should be a fraction of the 100 millirem per year. The

lifetime individual risk from 100 millirem annual dose limit

is about 3 x 10-3.

Estimating cumulative doses to populations over

thousands of years is more problematic. The likelihood

and consequences of events that could seriously

compromise the integrity of a deep geologic repository

were evaluated by the Department of Energy in the "Final

Environmental Impact Statement: Management of

Commercially Generated Radioactive Waste," October

1980. The evaluation estimated the 70-year whole-body

dose commitment to the maximum individual and to the

regional population resulting from several modes of

breaching a reference repository in the year of closure,

after 1,000 years, after 100,000 years and after

100,000,000 years.

Draft NUREG-1437, Supplement 39 B-1 1 October 2009
Appendix B

Issue Type of Issue Finding

Subsequently, the NRC and other federal agencies have

expended considerable effort to develop models for the

design and for the licensing of a high level waste

repository, especially for the candidate repository at

Yucca Mountain. More meaningful estimates of doses to

population may be possible in the future as more is

understood about the performance of the proposed

Yucca Mountain repository. Such estimates would involve

very great uncertainty, especially with respect to

cumulative population doses over thousands of years.

The standard proposed by the NAS is a limit on maximum

individual dose. The relationship of potential new

regulatory requirements, based on the NAS report, and

cumulative population impacts has not been determined,

although the report articulates the view that protection of

.individuals will adequately protect the population for a

repository at Yucca Mountain. However, EPA's generic

repository standards in 40 CFR Part 191 generally

provide an indication of the order of magnitude of

cumulative risk to population that could result from the

licensing of a Yucca Mountain repository, assuming the

ultimate standards will be within the range of standards

now under consideration. The standards in 40 CFR Part

191 protect the population by imposing amount of

radioactive material released over 10,000 years. The

cumulative release limits are based on EPA's population

impact goal of 1,000 premature cancer deaths worldwide

for a 100,000 metric ton (MTHM) repository.

Nevertheless, despite all the uncertainty, some judgment

as to the regulatory NEPA implications of these matters

should be made and it makes no sense to repeat the

same judgment in every case. Even taking the

uncertainties into account, the Commission concludes

that these impacts are acceptable in that these impacts

would not be sufficiently large to require the NEPA

conclusion, for any plant, that the option of extended

operation under 10 CFR Part 54 should be eliminated.

Accordingly, while the Commission has not assigned a

single level of significance for the impacts of spent fuel

and high level waste disposal, this issue is considered in

Category 1 [Generic].

Nonradiological Generic SMALL. The nonradiological impacts of the uranium fuel

impacts of the cycle resulting from the renewal of an operating license

uranium fuel cycle for any plant are found to be small.

Decommissioning

Radiation doses Generic SMALL. Doses to the public will be well below applicable

regulatory standards regardless of which

decommissioning method is used. Occupational doses

would increase no more than 1 man-rem caused by

buildup of long-lived radionuclides during the license

renewal term.

October 2009 B-12 Draft NUREG-1437, Supplement 39
.Appendix B

Issue Type of Issue Finding

Waste management Generic SMALL. Decommissioning at the end of a 20-year license

renewal period would generate no more solid wastes than

at the end of the current license term. No increase in the

quantities of Class C or greater than Class C wastes

would be expected.

Air quality Generic SMALL. Air quality impacts of decommissioning are

expected to be negligible either at the end of the current

operating term or at the end of the license renewal term.

Water quality Generic SMALL. The potential for significant water quality impacts

from erosion or spills is no greater whether

decommissioning occurs after a 20-year license renewal

period or after the original 40-year operation period, and

measures are readily available to avoid such impacts.

Ecological Generic SMALL. Decommissioning after either the initial operating

resources period or after a 20-year license renewal period is not

expected to have any direct ecological impacts.

Socioeconomic Generic SMALL. Decommissioning would have some short-term

impacts 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 of

Justice environmental justice will be addressed in plant-specific

reviews.

Draft NUREG-1437, Supplement 39 B-13 October 2009

Appendix C

Applicable Regulations, Laws, and Agreement

October 2009 Draft NUREG-1437, Supplement 39

Appendix C

C. Applicable Regulations, Laws, and Agreements

The Atomic Energy Act of 1954 (AEA) authorizes States to establish programs to assume NRC

regulatory authority for certain activities. For example, through section 274b of the AEA, as

amended, beginning on January 13, 2006, Minnesota assumed regulatory authority for: (1)

byproduct materials as defined in 1 le.(1) of the Act; (2) source materials; and (3) special

nuclear materials in quantities not sufficient to form a critical mass. The Minnesota Radiation

Control Unit (RCU) is responsible for implementing State nuclear regulations. Minnesota did not

seek authority to: (a) conduct safety evaluations of sealed sources and devices manufactured in

Minnesota and distributed in interstate commerce; (b) regulate the disposal of low-level

radioactive waste at a land disposal site as described in 10 CFR Part 61; or (c) regulate 1 le.(2)

byproduct material resulting from the extraction or concentration of source material from ore

processed primarily for its source material content, and its management and disposal.

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 as stringent 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 U.S. Environmental

Protection Agency (EPA) to the State. The primary mechanism to control water pollution is the

requirement for direct dischargers to obtain an NPDES permit. In Minnesota, the Minnesota

Pollution Control Agency (MPCA) 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.

Draft NUREG-1437, Supplement 39 C-1 October 2009
Appendix C

Table C-1. State Environmental Requirements. PINGP I and 2 is subject to numerous

State requirements regarding their environmental program. Those

requirements are briefly described below. See Section 1.9 for PINGP I and

2's compliance status with these requirements.

Law/Regulation Requirements

Air Quality Protection

Air Pollution Control Act, Minnesota All emission sources at PINGP 1 and 2, must obtain a

Administrative Rules and Laws, Chapter 7007, Synthetic Minor Operating Permit prior to operation;

Air Emission Permits, Section 1450 the MPCA issues and enforces permits.

Water Resources Protection

Clean Water Act (CWA) (33 U.S.C. Section The NPDES permit is required for plant industrial,

1251 et seq.); Minnesota Stat. § 115.03, subd. sanitary, and stormwater discharges to the Mississippi

1(e)(10) "Requiring that applicants for River. The NPDES permit requires the compliance of

wastewater discharge permits evaluate in their each point source with authorized discharge levels,

applications the potential reuses of the monitoring requirements, and other appropriate

discharged wastewater." requirements. The MPCA is the responsible State

agency for NPDES permitting.

CWA (33 U.S.C. Section 401) The CWA 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

Minnesota, State issuance of an NPDES permit

constitutes 401 Certification.

2008 Minnesota State Statutes 103G.265, Subd. 3. requires a permit to cover consumptive water

Laws regarding Water Supply Management use over 2,000,000 gallons per day (gpd) (over a 30-

day average) of surface and ground water; the

Minnesota Department of Natural Resources (MNDNR)

is the regulatory agency that issues and enforces

consumptive water use permits.

2008 Minnesota State Statutes 103G.265, Subd. 3. requires a permit to cover ground water

Laws regarding Water Supply Management withdrawals over 100,000 gpd or more (over a 30-day

average) of surface water, ground water, or a

combination of the two; the MNDNR is the regulatory

agency that issues and enforces ground water

withdrawal permits.

Minnesota State Statutes 103G.127 Permit The U.S. Army Corps of Engineers in cooperation with

Program MNDNR issues maintenance dredging permits for

maintenance dredging of the area around PINGP 1

and 2.

Minnesota State Statutes 103G.127 Permit Maintenance dredging of the PIINGP, Units 1 and 2

Program intake canal in the Mississippi River also requires a

maintenance dredging permit issued by the MNDNR.

Minnesota Safe Drinking Water Act (40 CFR The MNDNR issues and enforces public water supply

141 and 142); 2008 Minnesota Statutes permits for operation of the PINGP 1 and 2, plant site

103G.291 Public Water Supply Plans; drinking water systems.

Appropriation During Deficiency.

October 2009 C-2 Draft NUREG-1437, Supplement 39
Appendix C

Law/Regulation Requirements

Minnesota 2008 State Statutes 282.0195 Subd. The State of Minnesota issues storage tank registration

2. Storage tank sites for state laws and and permit certificates, which establish annual

regulations; Chapter 7150 Minnesota Pollution registration requirements for underground storage

Control Agency Underground Storage Tanks tanks containing petroleum or other regulated

Program for state permitting and registration substances. The MPCA, Industrial Division is the State

requirements. contact for obtaining permits, as well as issuing any

fines and/or performance measures.

Minnesota 2008 State Statute 7150.0100 These laws regulate flammable and combustible liquid

Performance standards for underground storage tanks as well as the approval to construct or

storage tank systems; Minnesota 2008 State operate an underground storage tank containing

Statute 7150.0215 Operation and Maintenance flammable or combustible liquids.

of Cathodic Protection.

Minnesota 2008 State Statute 458D.07 Sewage The State of Minnesota and the MPCA issues sewage

Collection and Disposal; 2008 State Statute sludge disposal agreements, which are required for the

458D.07 Subd. 6. deals specifically with disposal of sewage sludge. The MPCA also issues ondischarge of treated sewage. lot sewage disposal system permits, and permit

modifications for approvals of additional flows to on-lot

sewage treatment systems.

Draft NUREG-1437, Supplement 39 C-3 October 2009
Appendix C

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.

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

2, is subject to other requirements regarding various aspects of their

environmental program. Those requirements are briefly described below.

License, Permit, or Other Responsible

Required Approval Agency Authority Relevance and Status

Air Quality Protection

Approval (operating permit) MPCA Clean Air Act, Title V, NSP may need to modify its

for construction or Sections 501-507 (42 existing operation of air

modification of an air U.S.C. 7661-7661f); emissions system for an

pollutant source. Minn. Stat. § 116.07 electric utility power generation

system permit, or apply for a

new permit for temporary

emissions associated with

refurbishment.

Water Resources Protection

NPDES permit for MPCA CWA (33 U.S.C. 1251 NSP may need to modify the

construction site storm water et seq.); 40 CFR Part existing PINGP 1 and 2

and other project-specific 122; Minn Stat. § 7090 NPDES permit, or otherwise

discharges. obtain authorization for

temporary discharges

associated with refurbishment.

Review and approval of any MNDNR 2008 Minnesota Modifications to the existing

project that will result in Statutes 103G.265 PINGP 1 and 2 consumptive

consumptive use of water Water Supply water use permit may be

from the Mississippi River Management. necessary to supply water for

within the State of refurbishment activities.

Minnesota.

Appropriations permit MNDNR Minn Stat. § 103G.271 Refurbishment activities at

required for any user PINGP 1 and 2 may require

withdrawing more than additional water withdrawal or

10,000 gpd or 1 million an increased pumping rate; the

gallons of per year. existing PINGP 1 and 2

surface and/or groundwater

appropriation permit(s) may

require modification.

Permit required before MNDNR "The Flood Plain NSP is reviewing flood plain

construction, modification, Management Law;" elevations associated with

removal, destruction, or Minnesota Statute refurbishment activities; if

abandonment of an 103F.101 - 103F. avoidance is not possible, NSP

obstruction in a floodplain. may be required to apply for

appropriate permits.

October 2009 C-4 Draft NUREG-1437, Supplement 39
Appendix C

License, Permit, or Other Responsible

Required Approval Agency Authority Relevance and Status

A Spill Prevention Control MNDNR and CWA (33 U.S.C. 1251 A SPCC Plan is required at

and Countermeasures EPA Region et seq.); 40 CFR Part nuclear power plants storing

(SPCC) Plan is required for 5 112; large volumes of diesel fuel or

any facility that could other petroleum products. NSP

discharge diesel fuel in may need to modify its existing

harmful quantities into SPCC Plan, or develop a new

navigable waters or onto plan to cover activities

adjoining shorelines. associated with refurbishment.

New Underground Storage MPCA Resource Conservation Required if new underground

Tanks System Registration and Recovery Act storage tank systems would be

is required within 30 days of (RCRA), as amended, installed during refurbishment.

bringing a new underground Subtitle 1(42 U.S.C.

storage tank system into 6991a-6991i); 40 CFR

service. §280.22; Storage Tank

and Spill Prevention (35

P.S. 6021.101-

6021.2104); Minnesota

2008 State Statutes

7150.0100 - 7150.0210

Waste Management and Pollution Prevention

Registration and Hazardous MPCA and RCRA, as amended (42 Generators of hazardous

Waste Generator EPA Region U.S.C. 6901 et seq.), waste must notify EPA that the

Identification Number are 5 Subtitle C; Minnesota wastes exist and require

required before a facility that State Statute management in compliance

generates over 100 kg (220 7045.0125 Hazardous with RCRA. NSP is required to

Ib) per calendar month of Waste Generator's characterize wastes generated

hazardous waste ships the License by refurbishment to determine

hazardous waste offsite. proper disposal procedures

and permit requirements.

Emergency Planning and Response

Submission of a list of State and Emergency Planning Nuclear power plant operators

Material Safety Data Sheets local and Community Right- are required to submit a List of

is required for hazardous emergency to-Know Act of 1986 Material Safety Data Sheets to

chemicals (as defined in 29 planning (EPCRA), Section 311 State and local emergency

CFR Part 1910) that are agencies (42 U.S.C. 11021); 40 planning agencies.

stored onsite in excess of CFR §370.20

their threshold quantities.

Transportation of U.S. HMTA (49 U.S.C. 1501 When shipments of radioactive

Radioactive Wastes and Department et seq.); Atomic Energy materials are made, nuclear

Conversion Products of Act (AEA), as amended power plant operators are

Packaging, Labeling, and Transportatio (42 U.S.C. 2011 et required to comply with U.S.

Routing Requirements for n seq.); 49 CFR Parts Department of Transportation

Radioactive Materials is 172, 173, 174, 177, and packaging, labeling, and

required for packages 397 routing requirements.

containing radioactive

materials that will be shipped

by truck or rail.

Biotic Resource Protection

Draft NUREG-1437, Supplement 39 C-5 October 2009
Appendix C

License, Permit, or Other Responsible

Required Approval Agency Authority Relevance and Status

Threatened and Endangered U.S. Fish and Endangered Species NRC will consult with FWS and

Species Consultation is Wildlife Act of 1973, as State agencies regarding the

required between the Service amended (16 U.S.C. impact of license renewal on

responsible Federal (FWS) and 1531 et seq.) threatened or endangered

agencies and affected States State species or their critical

to ensure that the project is agencies habitats.

not likely to: (1) jeopardize

the continued existence of

any species listed at the

Federal or State level as

endangered or threatened;

or (2) result in destruction of

critical habitat of such

species.

CWA Section 404 (Dredge U.S. Army CWA (33 U.S.C. 1251 Any dredging or placement of

and Fill) Permit is required to Corps of et seq.); 33 CFR Parts fill material at a nuclear power

place dredged or fill material Engineers 323 and 330 plant into wetlands within the

into waters of the U.S., jurisdiction of the U.S. Army

including areas designated Corps of Engineers would

as wetlands, unless such require a Section 404 permit.

placement is exempt or

authorized by a nationwide

permit or a regional permit; a

notice must be filed if a

nationwide or regional permit

applies.

Cultural Resources Protection

Archaeological and Historical Minnesota National Historic NRC will consult with the State

Resources Consultation is Office of the Preservation Act of and Tribal Historic

required before a Federal State 1966, as amended (16 Preservation Officers and

agency approves a project in Archeologist U.S.C. 470 et seq.); representative Indian tribes

an area where Archaeological and regarding the impacts of

archaeological or historic Historical Preservation license renewal and the results

resources might be located. Act of 1974 (16 U.S.C. of archaeological and

469-469c-2); Antiquities architectural surveys of

Act of 1906 (16 U.S.C. nuclear power plant sites.

431 et seq.);

Archaeological

Resources Protection

Act of 1979, as

amended (16 U.S.C.

470aa-mm)

October 2009 C-6 Draft NUREG-1437, Supplement 39
1

2

3

4

APPENDIX D

CONSULTATION CORRESPONDENCE

5

6

October 2009 Draft NUREG-1437, Supplement 39

Appendix D

1

1

1

1

1

1

1 D. Consultation Correspondence

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

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

4 require that Federal agencies consult with applicable State and Federal agencies and groups

5 prior to taking action that may affect threatened and endangered species, essential fish habitat,

6 or historic and archaeological resources, respectively. This appendix contains consultation

7 documentation.

8 The Prairie Island Indian Community (PIIC) submitted a petition to intervene on August 18,

9 2008. Any correspondence related to this petition and not specifically to the PINGP 1 and 2

0 license renewal application review are not listed in the following table or included in this

1 appendix. The documents related to this petition that have been submitted to a hearing file,

2 which can be found in ADAMS under the adjudicatory process for Prairie Island Nuclear

3 Generating Plant, Docket Nos. 050-282 and 050-306.

4 Table D-1. Consultation Correspondences. This is a list of the consultation

5 documents sent between the NRC and other agencies we are required to

6 consult with based on NEPA requirements.

Author Recipient Date of Letter

Prairie Island Indian

Community (Tribal Council)

U.S. Nuclear Regulatory

Commission (J. Dyer)

U.S. Nuclear Regulatory

Commission (P.T. Kuo)

Prairie Island Indian

Community (R. Johnson)

Prairie Island Indian

Community (Tribal Council)

U.S. Nuclear Regulatory

Commission (J. Dyer)

Prairie Island Indian

Community (H. Westra)

U.S. Nuclear Regulatory

Commission (E. Leeds)

U.S. Nuclear Regulatory

Commission (Staff)

Prairie Island Indian

Community (P. Mahowald)

U.S. Nuclear Regulatory

Commission (R. Franovich)

U.S. Nuclear Regulatory

Commission (R. Franovich)

U.S. Nuclear Regulatory

Commission (R. Franovich)

U.S. Nuclear Regulatory

Commission (L. Reyes)

Prairie Island Indian Community

(R. Johnson)

Prairie Island Indian Community

(Tribal Council)

U.S. Nuclear Regulatory

Commission (S. Lee)

Bureau of Indian Affairs (T.

Verdin)

Prairie Island Indian Community

(R. Johnson)

U.S. Nuclear Regulatory

Commission (N. Le)

Prairie Island Indian Community

(R. Johnson)

Prairie Island Indian Community

(Tribal Council)

U.S. Nuclear Regulatory

Commission (R. Plasse)

Advisory Council on Historic

Preservation (D. Kilma)

Prairie Island Indian Community

(P. Mahowald)

Bureau of Indian Affairs

(T. Verdin)

January 29, 2008

February 23, 2008

March 21, 2008

April 14, 2008

May 1,2008

May 2, 2008

May 15, 2008

June 14, 2008

June 14, 2008

June 17, 2008

July 10, 2008

July 21, 2008

July 22, 2008

Draft NUREG-1437, Supplement 39 D-1 October 2009
Appendix D

Author

U.S. Nuclear Regulatory

Commission (R. Franovich)

U.S. Nuclear Regulatory

Commission (R. Franovich)

U.S. Nuclear Regulatory

Commission (R. Franovich)

U.S. Nuclear Regulatory

Commission (R. Franovich)

U.S. Nuclear Regulatory

Commission (R. Franovich)

U.S. Nuclear Regulatory

Commission (R. Franovich)

U.S. Fish and Wildlife Service

(T. Sullins)

Bureau of Indian Affairs

(T. Verdin)

Minnesota Department of

Natural Resources (H. Cyr)

Wisconsin Department of

Natural Resources (T. Lovejoy)

U.S. Nuclear Regulatory

Commission (R. Franovich)

U.S Nuclear Regulatory

Commission

Recipient

Prairie Island Indian Community

(H. Westra)

Minnesota Department of Natural

Resources (L. Joyal)

U.S. Fish and Wildlife Service

(T. Sullins)

Wisconsin Department of Natural

Resources (E. Rusch)

State Historic Preservation Office

(D. Gimmestad)

Prairie Island Indian Community

(R. Johnson) (a)

U.S. Nuclear Regulatory

Commission (R. Franovich)

U.S. Nuclear Regulatory

Commission (R. Franovich)

U.S. Nuclear Regulatory

Commission (R. Franovich)

U.S. Nuclear Regulatory

Commission (N. Goodman)

Bureau of Indian Affairs (K.

Bearquiver)

U.S. Fish and Wildlife Service

Date of Letter

July 22, 2008

July 22, 2008

July 22, 2008

July 22, 2008

July 22, 2008

July 24, 2008

August 13, 2008

August 18, 2008

August 26, 2008

September 8, 2008

October 23, 2008

September 2009

(a)Similar letters went to twenty eight other Native American Tribes listed in Section 1.8.

1 D.1. Consultation Correspondence

2 The following pages contain copies of the letters listed in Table D-1. Figures contained in the

3 July, 21, 2008, letter (D-26 and D-27) were included with all letters following this date sent by

4 the NRC.

October 2009 D-2 Draft NUREG-1437, Supplement 39
Appendix D

Ronald Johnson Johnny Johnson

President Vice President

Lucy Taylor Victoria Winfrey

Secretary Treasurer

Shelley Buck-Yeager

Assistant Secretary/Treasurer

January 29, 2008

Mr. Luis Reyes

Executive Director for Operations

United States Nuclear Regulatory Commission

Washington D.C. 20555

Dear Mr. Reyes:

As a follow-up to our October 24, 2007, meetings with Chairman Klein and other

representatives of the NRC, the Prairie Island Indian Community respectfully requests.

several further actions from the NRC that will enable the Community to adequately

prepare for a potential application by Xcel to renew the license for the Prairie Island

Nuclear Generating Plant. We are appreciative of the long history of cooperative

relations between the NRC and the Community. We believe that this cooperation is a

continuing affirmation of the December 2, 1996, Commission letter to the Community

stating týat it would direct the NRC staff to continue to implement the spirit and Ietter of

the presidential executive memorandum ofApril 29, 1994 to ensure that the rights of.

sovereign Tribal governments are fully respected and to operate within a government-togovernment relationship with Federally-recognized Native American Tribes.

Accordingly, the Community would request the following:

1. Members of the Tribal Council and staff will be in the Washington area during the

week of February 24, 2008. We would like to meet with the license renewal staff

in the Office of Nuclear Reactor Regulation to discuss the details of the safety and

environmental issues that the N-RC will evaluate when reviewing any license

renewal application from Xcel for the Prairie Island Plant. The NRC staff has

already given us an overview of the license renewal evaluation process and we

would now like to learn more in order to properly prepare for our role in the NRC

process. We could make ourselves available any time on February 27 and 28,

2009, for this purpose.

2. We would request that the NRC consider designating the Community as a "cooperating agency" in the preparation of the Environmental Impact Statement

(EIS) for the license renewal application in accordance with 10 CFR 51.4 and

* 51.29(aX7) of the Commission's regulations. We believethat this is not only

consistent with the Commission's policy of cooperation and consultation with

Native American Tribes, but also will be of assistance to the NRC in its

evaluation of the environmental impacts from the facility.

5636 Sturgeon Lake Road * Welch, MN 55089

(651) 385-2554 . 800-554-5473 . Fax (651) 385-4180 * TTY 800-627-3529 Deaf of Hearing Impaired

EDO -- G20080088

2

2

Draft NUREG-1437, Supplement 39 D-3 October 2009
Appendix D

Mr. Luis Reyes

January 29, 2008

Page 2

3. Finally, we would request that our environmental specialist be able to accompany

the NRC staff team when it conducts its initial environmental audit of the Prairie

Island Plant in preparation for the evaluation of environmental impacts from a

proposed renewal of the Plant license. This will not only be helpful to the

Community to enable us to adequately comment on the scope and substance of

the environmental review, but also, we believe, helpful to the NRC, particularly

in regard to the historic and religious cultural impacts of the review.

Thank you for your consideration of these requests. I will look forward to hearing from

you.

Sincerely,

Ronal Jono

Tribal Council President

Tribal Council Secretary

Johnny Offon .0"

Tribal Council Vice President

Tiba Win rey

Tribal Council Treasurer

Tribal Council As. tant Secretary)Treasurer

0c: Bruce Mallett

Martin Virgilio

James Dyer

P.T. Kuo

Dennis Rathbun

1

2

October 2009 D-4 Draft NUREG-1437, Supplement 39
Appendix D

February 23, 2008

Mr. Ronald Johnson

Tribal Council President

Prairie Island Indian Community

5636 Sturgeon Lake Road

Welch, MN 55089

Dear Mr. Johnson:

The U.S. Nuclear Regulatory Commission (NRC) received the letter from you and the Prairie

Island Indian Community dated January 29, 2008. We appreciate your interest in the

anticipated license renewal review for Prairie Island Nuclear Generating Plant (PINGP).

I understand that the Tribal Council and the Council's staff will be in the Washington area during

the week of February 24, 2008, and that the Council would like to meet with the NRC license

renewal staff to discuss the details of the safety and environmental reviews for license renewal

(LR). The staff will be available that week to meet with you.

The NRC staff appreciates your interest in participating in the LR environmental review as a

cooperating agency and looks forward to exploring that option with you. We also are very

receptive to your request to have the Council's environmental specialist accompany the NRC

staff team when the team conducts its initial environmental site audit of the PINGP. We will

inform you of the NRC staff's schedule in a timely manner so that the Council's staff can

prepare to participate.

Again, we appreciate your interest in the PINGP LR review and look forward to further dialogue

on the opportunity for cooperative assessment of the environmental impacts.

Sincerely,

IRA/

J. E. Dyer, Director

Office of Nuclear Reactor Regulation

1

2

Draft NUREG-1437, Supplement 39 D-5 October 2009
Appendix D

March 21, 2008

Mr. Ronald Johnson

Tribal Council President

Prairie Island Indian Community

5636 Sturgeon Lake Road

Welch, MN 55089

Dear President Johnson:

This is in follow-up to the February 27, 2008, meeting with you and Ms. Heather Westra at

U.S. Nuclear Regulatory Commission (NRC) headquarters in Rockville, Maryland. The staff

very much appreciates the opportunity to discuss the Prairie Island Indian Community's (the

Community) interest in the Prairie Island Nuclear Generating Plant (PINGP) license renewal

application, which the staff expects to receive in April 2008.

The staff works with Native American Tribal governments on a government-to-government basis

to ensure that the rights of sovereign Tribal governments are fully respected. In keeping with

this relationship, the NRC staff appreciates the offer of assistance in the environmental review

of the proposed action (license renewal) In accordance with the National Environmental Policy

Act of 1969. The staff understands that the Community is evaluating its options for participating

In the staff's review and will notify NRC if It wishes to pursue status as a cooperating agency.

The staff requests that, as you explore the option of cooperating agency status, you consider

the "Factors for Determining Whether to Invite, Decline or End Cooperative Agency Status,"

enclosed for your convenience. These factors can be accessed at

http:l/wwvwnenpa.ov/nepa/reqs/cooperating/cooperatingagenciesmemorandum.htmr. Should

the Community decide to pursue cooperating agency status, the NRC staff requests that the

Community notify the NRC by letter and address each of the "Factors' therein for staff

consideration.

As stated in the February 23, 2008, letter from J. E. Dyer to you, the staff is receptive to your

request to have the Community's environmental specialist accompany the NRC staff during its

environmental site audit of the PINGP. Should the NRC staff accept the PINGP license renewal

application for review, we will contact you with the dates of the environmental site audit so your

environmental specialist can make necessary arrangements.

Please direct all correspondence related the PINGP license renewal review to Mr. Ngoc

(Tommy) Le, Senior Project Manager. He can be reached by phone at (301) 415-1458 and by

email at nbl(@nrc.cqov. Similarly, the NRC staff requests the name and contact information of a

point of interface from the Community.

The staff remains committed to continue working with the Community on a government-togovernment basis and will be available to meet with representatives of the Community at

meeting facilities located on the reservation, if such a meeting would be beneficial.

1

2

October 2009 D-6 Draft NUREG-1437, Supplement 39
Appendix D

R. Johnson -2-

Thank you again for your interest in PINGP license renewal and your offer to assist the staff in

conducting the associated environmental review. We look forward to hearing from the

Community regarding the options it wishes to pursue for participation in the staff's

environmental review.

Sincerely,

IRA\ Sam Lee for

Pao-Tsin Kuo, Director

Division of License Renewal

Office of Nuclear Reactor Regulation

cc: Heather J. Westra, Interim Director

Land and Environment Department

5636 Sturgeon Lake Road

Welch, MN 55089

Enclosure:

As stated

1

2

Draft NUREG-1437, Supplement 39 D-7 October 2009
Appendix D

-2-

7. Can the cooperating agency provide resources to support scheduling and critical

milestones such as:

* Personnel? Consider all forms of assistance (e.g., data gathering; surveying;

compilation; research.

* Expertise? This includes technical or subject matter expertise.

* Funding? Examples include funding for personnel, travel and studies.

Normally, the cooperating agency will provide the funding; to the extent

available funds permit, the lead agency shall fund or include in budget

requests funding for an analyses the lead agency requests from cooperating

agencies. Alternatives to travel, such as telephonic or video conferencing,

should be considered especially when funding constrains participation.

" Models and databases? Consider consistency and compatibility with lead

and other cooperating agencies' methodologies.

* Facilities, equipment and other services? This type of support is especially

relevant for smaller governmental entities with limited budgets.

8. Does the agency provide adequate lead-time for review and do the other agencies

provide adequate time for review of documents, issues and analyses? For example, are

either the lead or cooperating agencies unable or unwilling to consistently participate in

meetings in a timely fashion after adequate time for review of documents, issues and

analyses?

9. Can the cooperating agency(s) accept the lead agency's final decision-making authority

regarding the scope of the analysis, including authority to define the purpose and need

for the proposed action? For example, is an agency unable or unwilling to develop

information/analysis of alternatives they favor and disfavor?

10. Are the agency(s) able and willing to provide data and rationale underlying the analyses

or assessment of alternatives?

11. Does the agency release predecisional information (including working drafts) in a

manner that undermines or circumvents the agreement to work cooperatively before

publishing draft or final analyses and documents? Disagreeing with the published draft

or final analysis should not be a ground for ending cooperating status. Agencies must

be alert to situations where state law requires release of information.

12. Does the agency consistently misrepresent the process or the findings presented in the

analysis and documentation?

1

2

October 2009 D-8 Draft NUREG-1437, Supplement 39
Appendix D

Ronald-Johnson

President

Lucy Taylor

Secretary

Johnny Johnson

" Vice President

Victoria Wlnfrey

Treasurer

Shelley Buck-Yeager

Assistant Secrelary/Treasurer

April 14, 2008

Mr. Sam Lee

Acting Director

Division of License Renewal

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555

VIA FACSIMILE

(301) 415-2002 &

FEDERAL EXPRESS

RE: Request for Cooperating Agency Status

Dear Mr. Lee:

On behalf of the Prairie Island Indian Community, we wanted to thank the NRC staff for

devoting the time to meet with Community representatives on February 27, 2008, to

discuss the anticipated application from the Xcel Corporation to renew the license for the

Prairie Island Nuclear Generating Plant (PINGP). We particularly appreciate the efforts

of Ms. Rosetta Virgilio in arranging these meetings. As noted in Mr. P.T. Kuo's letter of

March 21, 2008, we also appreciate the willingness of the NRC to have the Community's

environmental specialist accompany the NRC staff during its environmental site audit of

the PINGP. By this letter, we are also formally requesting that the Community be invited

to participate as a "cooperating agency" in the preparation of the environmental impact

statement on the anticipated license renewal application for the PINGP. As requested in

the letter of March 21, 2008, we are providing information on the factors the NRC should

consider in determining whether to invite a governmental entity to be a cooperating

agency (see attached).

The Prairie Island Indian Community in the State of Minnesota (also known as the Prairie

Island Mdewakanton Dakota Community) is a federally recognized Tribe organized

under 25 U.S.C. § 476, and is governed under the terms of the Constitution and Bylaws

adopted by the Tribal Members on May 23, 1936, and approved by the Secretary of the

Interior on June 20, 1936, as amended. Article IV, Section I of the Constitution provides

that the Community Council (sometimes referred to as the Tribal Council) shall be the

5636 Slurgeon Lake Road * Welch, MN 55089

(651) 365-2554 * 800-554-5473 * Fax (651) 3854180 * TrY 800-627-3529 Deaf of Hearing Impaired 413,ý

1

2

Draft NUREG-1437, Supplement 39 D-9 October 2009
Appendix D

Mr. Sam Lee

April 14, 2008

Page 2

governing body for the Prairie Island Indian Community. Pursuant to Article V of the

Constitution, the Tribal Council has the authority to, among other things: consider

various legal matters that fall within the authority of a federally recognized Indian tribe;

safeguard and promote the peace, safety, morals, and general welfare of the Community;

and protect and preserve the property, wildlife and natural resources of the Community.

By way of background, the Council on Environmental Quality (CEQ) regulations in 40

CFR 1501.6 provide for early and significant involvement by cooperating agencies in the

preparation of an EIS. The CEQ regulations permit a federal agency to invite other

agencies and governments to assume a cooperating agency role. The NRC regulations in

10 CFR Part 51 recognize the role of cooperating agencies. In a January 20, 2002,

memorandum to federal agency heads, including the NRC, CEQ Chairman James

Connaughton cited the many benefits of using cooperating agencies and encouraged

agencies to make greater use of cooperating agency arrangements.

We are hopefbl that the NRC will invite the Community to participate as a cooperating

agency. We believe that our environmental staff could contribute significantly to your

review, both on issues unique to the Community, and also on broader environmental

issues. Our environmental staff has a longstanding knowledge of local environmental

conditions which could greatly enhance the collection and analysis of information

required for your environmental review. In addition, we believe that cooperating agency

status would be an expeditious and convenient way for the NRC to implement the

agency's obligations for government-to-government consultation, as reflected in

Executive Order 13175. As the only federally recognized tribal entity in close proximity

to an NRC-licensed reactor, cooperating agency status for the Community would be

entirely appropriate. We have reason to believe that Xcel will submit its application for

the renewal of the PINGP license within the next few weeks. We believe that

involvement of the Community as early as possible in the NRC review of the Xcel

application will make the most productive use of the cooperating agency designation.

Consequently, we would appreciate your expedited consideration of our request.

R full s b mmed

Ronald Johns6f Jo hn

Tibal C cil Pr ide t Tribal Council Vice President

Lu Tiylor Victoria Wini'"-

Tribal Council Secretary Tribal Council Treasurer 61)

Tribal Council 'isistant Secr"et'iy/Treasurer

Attachment: Cooperating Agency Factors - Prairie Island Indian Community

2

October 2009 D-1 0 . Draft NUREG-1437, Supplement 39
Appendix D

Mr. Sam Lee

April 14, 2008

Page 3

cc: Luis Reyes, EDO, NRC

Bruce MaileR, DEDO, NRC

MartinVirgilio,DEDO,NRC

James Wiggins, NRR, NRC

Charles Miller. FSME, NRC

Bill Borchardt, NRO, NRC

Chairman Klein, NRC

Commissioner Lyons, NRC

Commissioner Jacksco, NRC

Commissioner Svinicki, NRC

Chairman Connaughton. CEQ

1

2

Draft NUREG-1437, Supplement 39 D-1 1 October 2009
Appendix D

Attachment to Prairie Island

Indian Community letter of

April 14, 2008

PRAIRIE ISLAND INDIAN COMMUNITY ("COMMUNITY") DISCUSSION OF

FACTORS TO BE CONSIDERED IN THE UNITED STATES NUCLEAR

REGULATORY COMMISSION ("NRC") DETERMINATION ON WHETHER TO

INVITE COOPERATING AGENCY STATUS IN REGARD TO THE PREPARATION

OF THE ENVIRONMENTAL IMPACT STATEMENT (EIS) ON THE APPLICATION

TO RENEW THE LICENSE FOR THE PRAIRIE ISLAND NUCLEAR GENERATING

PLANT

I. Jurisdiction by Law

Not Applicable.

2. Special Expertise

"Spýcial expertise" provides a broad opportunity for cooperating agency status,

recognizing the relevant capabilities or knowledge that a tribal government can contribute

to the preparation of an EIS. The CEQ regulations in 40 CFR 1508.5 specifically

addresses tribal eligibility, specifying that tribes are eligible "when the effects [of a

proposed action] are on a reservation." This criterion has been broadly applied to

include effects on tribal "interests." The Community has the expertise on the issues that

the NRC will have to consider to meet its obligations under the National Environmental

Policy Act. These issues include the effects of the proposed action on unique tribal

cultural interests, the relationship of Tribal planning objectives to State, regional, and

local government land use and energy plans, as well the effects of the proposed action. on

tribal economic interests. Our environmental expert has been with the Community for

many years and is cognizant of Community resources and information, and also

experienced in the preparation of environmental review documents relevant to the

Community. The Community's environmental expert has full access to any of the

Community's information that may be relevant to the preparation of the NRC EIS.

The Community has had environmental monitoring programs in place for many years.

With support from the US Environmental Protection Agency (EPA), the Community has

developed a Land and Environment Department, responsible for all aspects of

environmental quality. The Community has also retained the services of environmental

consulting firms to conduct special investigations, such as a plant and bird inventory on Prairie Island. The Community has an Engineer, Emergency Manager, legal staff, and

community members (cultural experts) who are ready to assist the tribe in the

development of the environmental documents for the relicensing proceeding.

1

2

October 2009 D-1 2 Draft NUREG-1437, Supplement 39
Appendix D

3. Understanding of Cooperating Agency Statts

The Community is fully aware of the roles and responsibilities of a cooperating agency

and the Tribal Council possesses the requisite authority to enter into an agreement with

the NRC as a cooperating agency.

4. Participation during scoping

The Community is fully prepared to participate effectively throughout the entire process

of preparing the EIS, including scoping. The Tribal Council has authorized the

participation of Community staff in the EIS process fully recognizing the resources that

may be required to meet its responsibilities as a cooperating agency.

5. Timely action

The Community believes that it can identify significant environmental issues, identify

minor issues to eliminate from further study, alert the NRC to previous studies that are

relevant to the EIS, and identify the proposed action's relationship to the Community's

long range plans, as well as the relationship to the plans of other governmental entities.

In fact, without the Community's participation as a cooperating agency, it would be

difficult for the NRC to develop this type of comprehensive information in a timely

manner.

6. Assistance in preparation

The Community is fully prepared to assist in preparing portions of the review. In fact, if

the cooperating agency status is provided, the Community would suggest for NRCP

consideration, that the Community staff prepare the portion of the analysis on the impacts

of the proposed action on Community cultural interests. The Community fully

anticipates providing any assistance necessary fully consistent with the NRC schedule.

7. Provision of resources to support scheduling and critical milestones

The Community will provide all of the necessary resources to support the NRC schedule

and milestones. The Community's environmental expert will coordinate all necessary

analysis and data gathering in support of the Community's portion of the EIS. The

Community will provide all funds for travel assistance for Community personnel

participating in the preparation of the EIS under the cooperating agency agreement.

8. Adequate lead time

The Community is fully able to consistently participate in meetings and document review

in a timely fashion given reasonable notice.

9. NRC final decision-making authority

1

2

Draft NUREG-1437, Supplement 39 D-13 October 2009
Appendix D

The Community accepts the fact that the NRC is the final decision-making authority on

the scope of the analysis, including the authority to define the purpose and need for the.

proposed action10. Provision of data

Any conclusions offered by the Community will be based on a rationale and analysis

provided in support of those conclusions.

11. Pre-decisional information

The Community is not required under state or Tribal law to release any pre-decisional

data. Any release of information shall not be done in a manner that undermines or circumvents the agreement to work cooperatively before publishing draft or final

analyses or documents.

12. Misrepresentation

The Community will act with the highest degree of integrity in implementing cooperating

agency status. Nothing will be misrepresented.

2

2

October 2009 D-14 Draft NUREG-1437, Supplement 39
Appendix D

Ronald Johnson Johnny Johnson

President Vice President

Lucy Taylor Victoria Winfrey

Secretary Treasurer

Shelley Buck-Yeager

Assistant Secretary/Treasurer

May 1, 2008

Terry Virden

Regional Director

Midwest Regional Office

Bureau of Indian Affairs

United States Depaitmenttof Interior

Bishop Henry Whipple Federal Building

One Federal Drive, Room 550

Ft. Snelling, Minnesota 55111

Re: Prairie Island Nuclear Generating Plant

Dear Mr. Virden:

On behalf of the Prairie Island Indian Community in the State of Minnesota, we are writing to

express our ongoing concerns about the Prairie Island Nuclear Generating Plant (PINGP), which

is located adjacent to our Community here on Prairie Island, and to request the Bureau of Indian

Affairs' assistance in connection with Xcel Energy's application to relicense the PINGP for an

additional 20 years of operation. As you are aware, the PINGP's continued operation and the

storage of nuclear waste storage just 600 yards from our Community are matters of critical

concern to. our Community. Although we will continue to monitor and participate in the

relicensing process to the fullest extent possible to protect our Community's interests, we

respectfully request the BIA's assistance and involvement in the process.

Xcel Energy's Application to Relicense the PINGP

On April 15, 2008, Xcel Energy filed its application with the Nuclear Regulatory Commission

(NRC) to renew the operating licenses for the two reactors at the PINGP for an additional 20

years. The PINGP's current 40-year licenses will expire in 2013 and 2014.

Xcel Energy is also expected to file in the near future a Certificate of Need application with the

Minnesota Public Utilities Commission to increase the number of used fuel storage containers at

5636 Sturgeon Lake Road * Welch, MN 55089

(651) 385-2554 * 800-554-5473 * Fax (651) 385-4180 TTY 800-627-3529 Deaf of Hearing Impaired

2

2

Draft NUREG-1437, Supplement 39 D-15 October 2009
Appendix D

Terry Virden

May 1, 2008

Page 2

Prairie Island and a Certificate of Need Application seeking to increase the generating capacity

of each Prairie Island reactor by approximately 80 megawatts.

Xcel Energy's Dry Cask Storage Facility

The concrete pad on the storage site was designed to hold 48 casks and was licensed by the NRC

to hold 48 casks. The 5.5 acre used storage facility on the plant site currently has 24 containers.

Xcel is authorized for enough containers to accommodate the plant operation through expiration

of the current licenses, which Xcel estimates to total about 29. According to Xcel, the

application will seek to add 35 containers (for a total of 64) within the existing storage site

boundaries to support plant operations during the license renewal period.

Each storage cask contains 40 spent fuel assemblies, which represents approximately 25 tons of

nuclear waste. Accordingly, there are approximately 600 tons of nuclear waste currently stored

on Prairie Island. If Xcel's request to for 64 total casks is approved, then roughly. 1600 tons of

nuclear waste will be stored indefinitely on Prairie Island within 600 yards of our Community

and along the banks of the Mississippi River.

The Prairie Island Indian Community has very serious concerns about Xcel's proposed relicensing and the potential increase in the amount of nuclear waste to be stored indefinitely near

our tribal community: With no concrete solution to the storage problem, we question the wisdom

of extending the life of this or any nuclear power plant.

We are extremely concerned about the prospect of re-licensing the PINGP, or any nuclear power

plant, at this time. Until the federal government makes good on its promise to solve the nuclear

waste storage issue, it is irresponsible to consider expanding the use of nuclear power in

Minnesota or any state. According to the Department of Energy, there are 125 temporary

nuclear waste storage sites throughout the country with more than 169 million Americans living

within 75 miles of one of these temporary facilities. Prairie Island is among the closest.

Twenty-five years after Congress passed the Nuclear Waste Policy Act and mandated the

establishment of a national repository, the-future of the nation's nuclear waste disposal program

remains very much.in doubt. The NRC's Waste Confidence Rule (10 CFR 51.52) allows for onsite storage of spent fuel for 30 years beyond licensed life (up until 2063/2064 at PINGP) and

states a repository will be available by 2025. Because of numerous delays and setbacks with

Yucca Mountain, it is getting less likely that a repository will be available by 2025, if ever. Just

because the rule says its so, doesn't make it so. No one in our tribe wants to live next to spent

nuclear fuel for the rest of his or her lives.

1

2

October 2009 D-16 Draft NUREG-1437, Supplement 39
Appendix D

Terry Virden

May 1, 2008

Page 3

Trust Roles and Responsibilities

The Bureau of Indian Affairs has been a trustee of our Community and its lands since our Tribe

was organized in 1936. Planning for the PINGP took place throughout the 1960s. Northern

States Power (Xcel Energy's predecessor-in-interest) applied for a construction permit in March

1967, a construction permit was issued for the PINGP in 1968, and construction was commenced

shortly thereafter. NSP filed a request for operating licenses for PINGP's two reactors in

February 1971. On or about January 22, 1973, the United States Atomic Energy Commission's

(AEC) transmitted it Draft Environmental Statement, with a request for comment to various state

and federal government entities, including the Minnesota Agency of the U.S. Department of

Interior's Bureau of Indian Affairs. According to the AEC's Final Environmental Statement

related to the Prairie Island Nuclear Generating Plant dated May 1973, tCs Minnesota Agency of

the U.S. Department of Interior's Bureau of Indian Affairs did not submit hny comments. This is

extremely troubling given that the Final Environmental Statement makes only passing reference

to our Community, and because the statement identifies burial mounds and an Indian village site

on the PINGP site that were potentially disturbed during construction.

Benefits and Costs

It is worth noting that although tens of millions of dollars were spent to construct both the

PINGP, the.transmission infrastructure for the electricity generated at the plant, and the dry cask

storage facility for the nuclear waste, apparently no effort was even made to provide our

immediately-adjacent Community with access to the electricity generated by the PINGP. At a

time when our Community was mired in poverty and a large percentage of our homes were

without electricity or running water, the electricity generated by the PINGP was routed along the

highest capacity power lines across the road from our homes and away from the Community:

And while we receive no benefit from the electricity generated at the plant, the costs imposed on

our Community have been great. The fear, uncertainty and potential adverse health effects

related to our close proximity to a nuclear power plant, high-voltage power lines and stored

nuclear waste are costs that cannot be quantified. Our Conmunnity also bears costs associated

with public safety, emergency planning, and the transportation of plant personnel, materials and

equipment across our reservation.

In stark contrast, the City of Red Wing promptly annexed the PINGP site. The City of Red Wing

and Goodhue County have received the benefit of millions of dollars in property taxes from Xcel

during the PINGP's operation. And while our Community receives electricity that has been

generated hundreds of miles away in the Dakotas (along with the service and quality problems

that result from being so far away from the power source), here at Prairie Island the transmission

lines carry the electricity generated by PINGP to homes and businesses in Red Wing and beyond.

2

Draft NUREG-1437, Supplement 39 D-17 October 2009
Appendix D

Terry Virdet,

May 1, 2008

Page 4

Understanding the Past to Protect Our Community's Future

Based on this abbreviated history, and in connection with Xcel Energy's recent filing to relicense

the PINGP, it is prudent to clarify the scope of the federal government's trust obligations to our

Community vis-i-vis the construction and operation of the PINGP. Among other things, we are

seeking to understand and chronicle any involvement the Bureau of Indian Affairs has had in the

past that relates to the planning, construction and operation of the PINGP. Accordingly, we

respectfully request that the Bureau of Indian Affairs provide answers to the following questions:

1. What involvement, f any, did the Minnesota Agency or the BIA have in the planning,

construction, or licensing of the PINGP?

2. What efforts, if any, did the Minnesota Agency or the BIA make to advise or assist the

Prairie Island Indian Community in connection with the planning, construction or

licensing of the PINGP?

3. Did the Minnesota Agency or the BIA receive the AEC s transmittal and request for

comments on the AEC's Draft Environmental Statement for the PINGP on or about

January 22, 1973?

4. Did the Minnesota Agency or the BIA respond to the AEC's request for comments on the

Draft Environmental Statementfor the PfIVGP in 1973?

5. if the Minnesota Agency or the BLI did respon4 can you please provide us with a copy of

the response?

6. If the Minnesota Agency or the BIA did not respond, can you please provide us with an

explanation, if any, of the Minnesota Agency's inaction or decision not to comment on the

Draft Environmental Statement for the PIhTGP?

In addition to responses to these questions, we further request copies of all documents and

records regarding the involvement, if any, of the Minnesota Agency or the BIA, during the

planning, construction and opening of the PINGP.

Finally, we respectfully request the Bureau of Indian Affairs, as trustee for this Community and

its lands, advise us what'it intends to do to fulfill its trust obligations in connection with Xcel's

application to relicense the PINGP's two reactors for an additional 20 years of operation, Xcel's

Certificate of Need application for additional dry cask storage, and Xcel's Certificate of Need

Application to increase the generating capacity of each Prairie Island reactor.

1

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October 2009 D-18 Draft NUREG-1437, Supplement 39
Appendix D

:1 Terry Virden

May 1, 2008

Page 5

We appreciate your consideration of this request for information and assistance.

Sincerely,

RoadJohsi

Tribal Council President

Lucy s.yayljr //

Tribal Council Secretary

Tr2bal Counlf Vice-President

Victoria.. Wincf•y Trea

Tribal Council Treasurer

Tribal Council Assistant Secretary/Treasurer

cc: Carl J. Artman, Assistant Secretary - Indian Affairs

Jerry Gidner, Director of Bureau of Indian Affairs 7

Dale E. Klein, Chairman, Nuclear Regulatory Commission/

Norm Coleman, U.S. Senator

Amy Klobuchar, U.S. Senator

John Kline, U.S. Congressman

Michele Bachmann, U.S. Congresswoman

Keith Ellison, U.S. Congressman

Betty McCollum, U.S. Congresswoman

James Oberstar, U.S. Congressman

Collin Peterson, U.S. Congressman

Jim Ramstad,-U.S. Congressman

Timothy Walz, U.S. Congressman

John S. Roberts, Special Assistant to the President for Intergovernmental Affairs

1

Draft NUREG-1437, Supplement 39 D-19 October 2009
Appendix D

May 2. 2008

Mr. Ronald Johnson

Tribal Council President

Prairie Island Indian Community

5636 Sturgeon Lake Road

Welch, MN 55089

Dear Mr. Johnson:

This is in response to your April 14, 2008, letter to Dr. Samson Lee of the U.S. Nuclear

Regulatory Commission (NRC or staff) and your request to participate as a cooperating agency

in the environmental review for Prairie Island Nuclear Generating Plant (PINGP) license

renewal.

To establish a framework for cooperation and coordination between the NRC and the Prairie

Island Indian Community (PIIC), the staff has prepared the enclosed draft Memorandum of

Understanding (MOU), which is being provided to you for review and comment. The draft MOU

describes the respective roles and responsibilities of the NRC and the PIIC. It also defines the

areas of special expertise and information that could be provided by the PIIC to assist the staff

in its environmental review.

After mutual agreement to the terms of the PIIC's participation in the staff's environmental

review process for the PINGP license renewal application (LRA) as described in the MOU and

subsequent signature by both parties, cooperating agency status for the PIIC would become

effective. To ensure that the MOU can be finalized before the staff completes its acceptance

review of the PINGP application, we request your comments by May 15, 2008.

Thank you again for your interest in participating in the environmental review for PINGP license

renewal. We look forward to receiving your comments on the enclosed draft MOU and future

dialogue with the PIIC. If you need further assistance in this matter, please contact Mr. Tommy

Le of my staff at 301-415-1458.

Sincerely,

\RA Catherine Haney for\

J. E. Dyer, Director

Office of Nuclear Reactor Regulation

Enclosure:

As stated

cc: Heather J. Westra

1

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October 2009 D-20 Draft NUREG-1437, Supplement 39
Appendix D

From: Heather Westra [hwestra@piic.org]

Sent: Thursday, May 15, 2008 2:58 PM

To: Ngoc Le

Cc: Rani Franovich

Subject: Draft MOU

Attachments: Draft MOU markup 051408.doc

Hi Tommy and Rani

We have been working on the draft MOU and attached you will find our

suggestions (we have

used red, as you will see). As of Wednesday, we had not received the

official letter transmitting

the MOU. Perhaps you could fax it to (651) 385-4180

I also wanted to let you know that the Prairie Island Pow Wow will be

held July 11, 12, and 13.

The hotel at Prairie Island will be full, and many other area hotels

will be full, in case you were

planning to conduct the Environmental Audit around that time.

Please feel free to call me with any questions regarding our suggestions

for the MOU.

Best regards,

Heather

Heather Westra

Prairie Island Indian Community

5636 Sturgeon Lake Road

Welch, MN 55089

(651) 329-5796

hwestra@piic.org

The information contained in this email message is privileged and

confidential information

intended only for the use of the individual or entity named above. If

the reader of this message is

not the intended recipient, you are hereby notified that any

dissemination, distribution or copying

of this communication is strictly prohibited. If you have received this

communication in.error,

please immediately notify us by telephone at 800-554-5473, ext. 4136 or

by email to

legal@piic.org.

Thank you.

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Draft NUREG-1437, Supplement 39 D-21 October 2009
Appendix D

June 14, 2008

Mr. Ronald Johnson

Tribal Council President

Prairie Island Indian Community

5636 Sturgeon Lake Road

Welch, MN 55089

Dear Mr. Johnson:

By letter dated April 14, 2008, to Dr. Samson Lee of the U.S. Nuclear Regulatory Commission

(NRC or staff), you requested to participate as a cooperating agency in the environmental

review for Prairie Island Nuclear Generating Plant (PINGP) license renewal. On May 2, 2008,

the staff forwarded to you a proposed memorandum of understanding (MOU) to establish a

framework for cooperation and coordination between the NRC and the Prairie Island Indian

Community (PIIC). Ms. Heather Westra subsequently suggested changes to the staffs

proposed MOU, which the staff took into consideration in finalizing the document.

Enclosed for your signature is the final MOU, which has been signed by me. Once you have

signed the MOU, you may wish to retain a copy for your records. I request that you return the

original to Mr. Richard Plasse of my staff.

Thank you again for your interest in participating as a Cooperating Agency in the environmental

review for PINGP license renewal, The NRC recognizes that close cooperation with the PIIC

will lead to a more effective and complete environmental review, and we look forward to this

collaborative process. If you need further assistance in this matter, please contact Mr. Richard

Plasse of my staff at 301-415-1427.

Sincerely,

IRAI

Eric J. Leeds, Director

Office of Nuclear Reactor Regulation

Enclosure:

As stated

cc: Heather J. Westra

1

2

October 2009 D-22 Draft NUREG-1437, Supplement 39
Appendix D

Memorandum of Understanding Between

The U.S. Nuclear Regulatory Commission

and

The Prairie Island Indian Community as a Cooperating Agency

I. Introduction

This Memorandum of Understanding (MOU) establishes a cooperating agency relationship

between the U.S. Nuclear Regulatory Commission (NRC) and the Prairie Island Indian

Community (PIlC) for the purpose of preparing the Supplemental Environmental Impact

Statement (SEIS) for renewing the licenses for the Prairie Island Nuclear Generating Plant,

Units I and 2 (PINGP).

The NRC shall be the lead federal agency, and shall supervise the preparation of the PINGP

SEIS. The NRC acknowledges that the PIIC requested to be a Cooperating Agency for

preparation of the PINGP SEIS. The NRC grants the PIIC's request and recognizes the PIIC

has special expertise in the following areas listed in Section IV B. of this document. This MOU

describes responsibilities and procedures agreed to by the PIIC, as a Cooperating Agency, and

the NRC, as the Lead Agency; the PIIC and the NRC are the Parties to this MOU.

The cooperating agency relationship established through this MOU shall be governed by all

applicable statutes, regulations, and policy, including the NRC's regulations (in particular

10 C.F.R. Part 51).

II. Purpose

The purposes of this MOU are:

A. To designate the PIIC as a Cooperating Agency in the PINGP SEIS process.

B. To provide a framework for cooperation and coordination between the NRC and the PIIC

that will aid in the successful completion of the PINGP SEIS in a timely, efficient, and

thorough manner.

C. To recognize that the NRC is the lead agency with responsibility for the completion of

the PINGP SEIS.

D. To describe the respective responsibilities, jurisdictional authority, and expertise of each

of the Parties in the planning process.

-1-

1

2

Draft NUREG-1437, Supplement 39 D-23 October 2009
Appendix D

III. Authorities for the MOU

A. The authorities of the NRC to enter into and engage in the activities described within this

MOU include, but are not limited to:

1. National Environmental Policy Act of 1969 (NEPA) (42 U.S.C. 4321 etseq.)

2. The Atomic Energy Act (42 U.S.C. 2011 etseq.)

3. The NRC regulations (10 C.F.R. Part 51 - Code of Federal Regulations, Title 10,

Energy, Part 51, "Environmental Protection Regulations for Domestic Licensing and

Related Regulation Functions.')

B. The authorities of the PIIC to enter Into and engage in the activities described within this

MOU include, but are not limited to:

1. The Department of Interior regulations (25 U.S.C. Section 476bb -.United States

Code, Title 25, Indians, Chapter 14, Miscellaneous, Subchapter II, Indian SelfDetermination and Education Assistance, Part D - Tribal Self-Governance).

2. The Constitution and Bylaws adopted by the Tribal Members on May 23, 1936, and

approved by the Secretary of the Interior on June 20, 1936, as amended.

IV. Roles and Responsibilities

A. The NRC Responsibilities:

1. As lead agency, the NRC retains final responsibility for the content of all documents,

which include the Draft PINGP SEIS and the Final PINGP SEIS. The NRC's

responsibilities include identifying the purpose of and need for the PINGP SEIS;

selecting alternatives for analysis; determining effects of the proposed alternatives;

making recommendations on the proposed action; evaluating appropriate mitigation

measures; and preparing the draft and final SEIS for PINGP's license renewal. In

meeting these responsibilities, the NRC will follow the guidance set forth in NUREG1555, Supplement 1, Standard Review Plans for Environmental Reviews for Nuclear

Power Plants, Supplement 1: Operating License Renewal; and all applicable

statutory and regulatory requirements.

2. To the fullest extent consistent with its responsibility as lead agency, the NRC will

utilize the comments, recommendations, data, andlor analyses provided by the PIIC

in the PINGP SEIS process, giving particular weight to those topics on which the

PIIC is acknowledged to possess special expertise.

3. The NRC will provide the PIIC with copies of documents underlying the PINGP SEIS

relevant to the PIIC's responsibilities, including technical reports, data, analyses,

comments received, and sections of substantive working drafts of the Draft and Final

SEIS specific to the PIIC's areas of special expertise, subject to the NRC's

Information handling requirements.

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1

2

October 2009 D -24 Draft NUREG-1437, Supplement 39
Appendix D

4. The.NRC staff will identify milestones in the standard license renewal review

schedule to incorporate activities listed in Attachment B to this MOU.

B. Cooperating Agency Responsibilities:

1. The PIIC is a Cooperating Agency for developing the PINGP SEIS and is recognized

to have special expertise In the following areas as they relate to the PIIC:

a. Historic and Archeological Resources

b. Socloeconomics

c. Land Use

d. Environmental Justice

2. The PIIC will work with the NRC to mutually coordinate, prioritize, identify and

manage tasks to provide information, comments, and technical expertise to the NRC regarding those topics, and the data and analyses supporting them, in which it has

special expertise or for which the PIIC requests its participation. The NRC and the

PIIC will identify staff to implement and coordinate these activities. In particular, the

PIIC may provide information on the following topics:

a. Identification and preservation of the PIIC historic, cultural and archaeological

Indian tribe resources

b. Socioeconomic data and analysis directly related to the P1iC c. Land use data and analysis directly related to the P0IC

d. Environmental justice data and analysis directly related to the PIIC

3. W•thin its areas of expertise, the PIIC may participate In any of the activities identified

in Attachment A. These activities include, but are not limited to: identifying data

needs, identifying effects of alternatives, identifying cumulative impacts, suggesting

mitigation measures, and providing written comments on sections of substantive

working drafts of the Draft and Final SEIS and supporting documents.

4. When the PIIC provides information, technical analyses, data sets or comments, it

will provide the data and other information to be used in developing the PINGP SEIS,

within the schedule identified in Attachment B.

C. Responsibilities of the Parties:

1. The Parties agree to participate in this planning process in good faith and make

all reasonable efforts to resolve disagreements.

2. The Parties agree to comply with the review schedule, which incorporates specific

milestones provided in Attachment B and includes dates for PINGP SEIS milestones

and timeframes for PIIC's reviews and submissions,

3. Each Party agrees to fund its own expenses and costs associated with the PINGP

SEIS process.

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2

Draft NUREG-1437, Supplement 39 D-25 October 2009
Appendix D

V. Other Provisions

A. Authorities Not Altered. Nothing in this MOU alters, limits, or supersedes the

authorities and responsibilities of any Party on any matter within their respective

jurisdictions. Nothing in this MOU shall require any of the Parties to perform beyond its

respective authority.

B. Financial Obligations. Nothing in this MOU shall require any of the Parties to assume

any obligation or expend any sum in excess of authorization and appropriations

available. This MOU does not obligate any funding.

C. Immunity and Defenses Retained. Each Party retains all immunities and defenses

provided by law with respect to any action based on or occurring as a result of this

MOU. The PIIC does not waive sovereign immunity by entering into this MOU and

specifically retains immunity and all defenses available to it as a sovereign identity

and all other applicable laws.

0. Conflict of Interest. The Parties agree not to utilize any individual for purposes of

environmental analysis, or the PIIC representation, including officials, employees, or

third party contractors, having a financial interest in the outcome of the PINGP SEIS.

E. Documenting Disagreement or Inconsistency. As described in IV.B.3 above, the

NRC staff will provide an opportunity for the PRIC to review sections of substantive

working drafts of the Draft and Final SEIS specific to the PIIC's areas of special

expertise: Where the NRC and the PIIC disagree on significant elements of the PINGP

SEIS (such as designation of the alternatives to be analyzed or analysis of effects), and

these disagreements cannot be resolved, the PIIC may document its views and submit

them as comments to the Draft and Final SEIS.

F. Management of Information. The PIIC acknowledges that all data and information

provided will become part of the NRC's official record and will be available for public

review, except that NRC may withhold information from the public that is exempt from

disclosure under the Freedom of Information Act and other applicable statutory

authorities. The PIIC agrees that internal working draft documents for the development

of the PINGP SEIS will not be made available for review by individuals or entities other

than the Parties to this MOU.

Information the PIIC considers confidential, proprietary, Sensitive Unclassified NonSafeguards Information or protected under NRC regulations will be labeled according to

requirements in 10 C.F.R. § 2.390. In particular, all signatories and concurring parties

shall ensure that shared data, including data concerning the precise location and nature

of historic properties and properties of religious and cultural significance are protected

from public disclosure to the greatest extent permitted by law, including conformance to

Section 304 of the National Historic Preservation Act, as amended and Section 9 of the

Archaeological Resources Protection Act and Executive Order No. 13007 on Indian

Sacred Sites (Federal Register, Vol. 61 No. 104, May 24, 1996).

In cases where the license applicant provides information it considers confidential or

proprietary, PIIC agrees that such information is to be held confidential and kept

separate from the information necessary for the environmental analysis. Should the

PIIC cause any distribution of confidential or proprietary information to occur, the PIIC

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2

October 2009 D-26 Draft NUREG-1437, Supplement 39
Appendix D

will return the information to the NRC and the PIIC may have its cooperating agency

status terminated.

The PIIC agrees that in order to allow full and frank discussion of preliminary analysis

and recommendations, meetings to review such pre-decisional and deliberative

documents will not be open to the public.

G. Responsibility for Decision Making. While the Parties agree to make reasonable

efforts to resolve procedural and substantive disagreement, they acknowledge that the

NRC retains final responsibility for the decisions identified in the PINGP SEIS.

H. MOU Limitations. Nothing in this MOU is intended to confer a binding or enforceable

right of action on any party.

I. Retention of Rights. Cooperating agency status for the PINGP SEIS does not preclude

the PIIC from participating in the NEPA process according to the provisions in 10 C.F.R.

Part 51.

VI. Agency Representatives

Each Party will designate a representative and alternate representative, as described in

Attachment C, to ensure coordination between the PIIC and the NRC during the

planning process. Each Party may change its representative at will by providing written

notice to the other Party.

Vii. Administration of the MOU

A. Approval. This MOU becomes effective upon signature by the authorized officials of all

the Parties.

B. Amendment. This MOU may be amended through written agreement of all signatories.

C. Termination. If not terrninated earlier, this MOU will end when the Final PINGP SEIS is

issued by the NRC. Any Party may end its participation in this MOU by providing written

notice to the other Party.

D. Entirety of Agreement. This MOU, including Attachments A, B, and C, consisting of

nine (9) pages represents the entire and integrated MOU between the parties and

supersedes all prior negotiations, representations, and agreements, whether written or

oral.

-5.

2

Draft NUREG-1437, Supplement 39 D-27 October 2009
Appendix D

VIII. Signatures

The Parties hereto have executed this MOU on the dates shown below.

/Original signed by R. Johnson/

Ronald Johnson, Tribal Council President

Prairie Island Indian Community (Cooperating Agency)

5636 Sturgeon Lake Road

Welch, MN 55089

/Original signed by E. Leeds/

Eric Leeds, Director

Office of Nuclear Reactor Regulation

U. S. Nuclear Regulatory Commission (Lead Agency)

11545 Rockville Pike

Rockville, Maryland 20852

June 17, 2008

Date

June 14, 2008

Date

-6-

1

2

October 2009 D-28 Draft NUREG-1437, Supplement 39
Appendix D

Attachment A

Opportunities for Cooperating Agency Participation In the PINGP SEIS

PINGP SEIS

Stage

1 Conduct scoping and

1 identify issues

Potential Activities of the Prairie Island Indian Community

(PIIC) within its acknowledged areas of special expertise

Identify significant issues; identify relevant local and regional

organizations and interest groups.

2 Collect inventory data Identify data needs; provide data and technical analyses within

the PIIC's areas of special expertise.

3 Estimate effects of Provide effects analysis and/or comments within the PIIC's

alternatives areas of special expertise; identify effects within the PIIC's areas of special expertise.

4 Propose mitigation Suggest mitigation measures to reduce impacts of proposed

measures action and alternatives. Decision to select mitigation

measures for analysis is reserved to the NRC.

5 Select the preliminary Collaborate with the NRC project manager in evaluating

recommendation 1 alternatives and in developing criteria for selecting the

regarding the proposed preliminary recommendation regarding the proposed action;

action; issue Draft provide input on sections of substantive working drafts of the

PINGP SEIS Draft SEIS specific to the PIIC's areas of special expertise,

subject to the NRC's information handling requirements. The

PIIC may provide written, public comments on the Draft SEIS,

if desired. Decision to select the preliminary recommendation

is reserved to the NRC.

6 Respond to comments Review comments within the PIIC's areas of special expertise

and assist in preparing responses, as appropriate.

7 Working draft of the NRC staff will provide sections of substantive working drafts of

Final PINGP SEIS the Final SEIS specific to the PIIC's areas of special expertise

for its review in accordance with this MOU.

8 Select the final Action reserved to the NRC.

recommendation

i regarding the proposed

action; issue Final

PINGP SEIS

-7-

1

2

Draft NUREG-1437, Supplement 39 D-29 October 2009
Appendix D

Attachment B

Schedule

Potential Activities of Cooperating Agency (PIIC) within its Input to NRC needed by

acknowledged areas of expertise

Provide data and information identified under Section IV(B)(2) of WiWthin 60 calendar days of

the MOU to NRC. MOU signing by NRC.and

PIIC representatives

2 Provide review comments on sections of substantive working Within 15 business days of

drafts of the Draft SEIS specific to the PIIC's areas of special receiving applicable sections

expertise before it is sent to publishing as an official Draft SEIS of the working draft of the

for public comments; attend draft SEIS review meeting. Draft SEIS for review

3 Provide comments on the Draft SEIS, as appropriate. Within the time period

identified in the Federal

Register Notice for publication

of the Draft SEIS for public

comrme nt

4 Provide comments on sections of substantive working drafts of Within 10 business days of

proposed responses to public comments on the Draft SEIS, receiving draft compilation of

specific to the PIIC's areas of special expertise. . I comments and responses

5 Provide comments on sections of substantive working drafts of

the Final SEIS, specific to the PIIC's areas of special expertise.

i t~hin 15 business days of

receiving applicable sections

of the working draft of the

Final SEIS for review

-8-

1

2

October 2009 D-30 Draft NUREG-1437, Supplement 39
Appendix D

Attachment C

Agency Representatives

U.S. Nuclear Regulatory Commission

Primary Representative: Richard Plasse, Project Manager

(301) 415-1427

Backup Representative: To Be Determined

Prairie Island Indian Community

Primary Representative: Heather J. Westra, Interim Director

Land and Environment Department

(651) 329-5796

Backup Representative: Philip R. Mahowald, General Counsel

(651) 267-4006

29.

1

2

Draft NUREG-1437, Supplement 39 D-31 October 2009
Appendix D

PRAIRIE ISLAND INDIAN COMMUNITY

LEGAL DEPARTMENT*

June 17, 2008

Mr. Richard Plasse, Project Manager

U.S. Nuclear Regulatory Commission

11555 Rockville Pike

Rockville, MD 20852-2746

Via Federal Express

Re: Memorandum of Understanding

Dear Mr. PlasseEnclosed please find the fully executed Memorandum of Understanding between the U.S.

Nuclear Regulatory Commission (NRC) and the Prairie Island Indian Community (Community) as a cooperating agency in the environmental review for the Prairie Island Nuclear Generating

Plant license renewal. The Community looks forward to collaborating with the NRC to complete

the environmental review.

Sincerely,

Philip KR Mahowald

General Counsel for the

Prairie Island Indian Community

PRMvnj

Enc.

5638 Sturgeon Lake Road *Welch. MN 55089 IRA I) ,aQ.Ai . R(VCASAAAI. A- IR eI I 1flC..7RA *Rr dt71 OflfLJ... 1

2

October 2009 D -32' Draft NUREG-1437, Supplement 39
Appendix D

July 10, 2008

Mr. Don L. Klima, Director

Advisory Council on Historic Preservation

Office of Federal Agency Programs

1100 Pennsylvania Ave, NW, Suite 803

Washington, DC 20004

SUBJECT: PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2,

LICENSE RENEWAL APPLICATION REVIEW

Dear Mr. Klima:

The U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing an application to

renew the operating licenses for the Prairie Island Nuclear Generating Plant, Units 1 and 2

(PINGP), located in Red Wing, Minnesota, approximately 39 miles southeast of Minneapolis.

PINGP is operated by Nuclear Management Company, LLC (NMC). The application for renewal

was submitted by NMC in a letter dated April 11, 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 staffs review of any nuclear power plant license

renewal action, a site-specific Supplemental Environmental Impact Statement (SEIS) to its

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

NUREG-1437, will be prepared under the provisions of 10 CFR Part 51, the NRC's regulation

that implements the National Environmental Policy Act of 1969. In accordance with

36 CFR 800.8(c), the SEIS will include analyses of potential impacts to historic and cultural

resources.

The NRC has signed a Memorandum of Understanding (MOU) with the Prairie Island Indian

Community (PIIC) for the PINGP license renewal environmental review (Enclosure). The MOU

establishes a cooperating agency relationship between the NRC and the PIIC, with the NRC as

lead agency responsible for preparing the SEIS.

On July 30, 2008, the NRC will conduct two public meetings. The first session will be held in the

afternoon and an identical session will be held later that evening. Both sessions will be held at

the Red Wing Public Library, 225 East Avenue, Red Wing, MN 55066. 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. You and your staff are

invited to attend the public meetings. In addition, during the week of August 18, 2008, the NRC

staff plans to conduct a site audit at PINGP. 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

March 2009.

1

2

Draft NUREG-1437, Supplement 39 D-33 October 2009
Appendix D

D. Klima -2-

If you have any questions or require additional information, please contact the License Renewal

Project Manager, Mr. J.P. Leous, at 301-415-2864 or Justin.Leous (•nrc.gov.

Sincerely,

VAI

Rani Franovich, Branch Chief Projects Branch 2

Division of License Renewal

Office of Nuclear Reactor Regulation

Docket Nos. 50-282 & 50-306

Enclosure:

As stated

cc: See next page

1

2

October 2009 D-34 Draft NUREG-1437, Supplement 39
Appendix D

July 21, 2008

Mr. Philip R. Mahowald

General Counsel

Prairie Island Indian Community

5636 Sturgeon Lake Road

Welch, MN 55089

SUBJECT: REQUEST FOR SCOPING COMMENTS CONCERNING THE PRAIRIE ISLAND

NUCLEAR GENERATING PLANT, UNITS 1 AND 2, LICENSE RENEWAL

APPLICATION REVIEW

Dear Mr. Mahowald:

As you know, the U.S. Nuclear Regulatory Commission (NRC or the staff) recently received an

application from Nuclear Management Company, LLC (NMC), for the renewal of the operating

licenses for the Prairie Island Nuclear Generating Plant, Units 1 and 2 (PINGP), located near

Red Wing. Minnesota, approximately 39 miles southeast of Minneapolis.

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 licenses for PINGP will expire in August 9, 2013 and

October 29. 2014. The proposed license renewal for PINGP Units 1 and 2 would include the

use and continued maintenance of existing plant facilities and transmission lines. For the

purpose of license renewal, NMC plans to replace the PINGP steam generators. As part of this

refurbishment activity, NMC also plans to establish a temporary construction area approximately

100 yards northwest of the turbine building and to build permanent warehouses within existing

plant boundaries. NMC states that there will be no clearing of previously-undisturbed areas.

Provided for your information is the PINGP site boundary map (Enclosure 1) and transmission

system map (Enclosure 2).

The N RC has established that, as part of the staff's review of any nuclear power plant license

renewal action, a site-specific Supplemental Environmental Impact Statement (SEIS) to its

"Generic Environmental Impact Statement for License Renewal of Nuclear Plants" (GELS),

NUREG-1 437, will be prepared under the provisions of Title 10 of the Code of Federal

Regulations, Part 51, the NRC's regulation that implements the National Environmental Policy

Act of 1969 (NEPA). Additionally. as outlined in Section 51.28(b), the NRC's process includes

an opportunity for public and inter-governmental participation. In accordance with 36 CFR

800.8(c). the SEIS will include analyses of potential impacts to historic and cultural resources,

The NRC recognizes the Prairie Island Indian Community's (PIIC) expertise in historic and

archeological resources, land use, socioeconomics and environmental justice. As outlined in our Memorandum of Understanding, the PIIC has offered to contribute to staff's analysis in

these areas.

1

2

Draft NUREG-1437, Supplement 39 D-35 October 2009
Appendix D

P. Mahowald - 2 -

The GElS considered the environmental impacts of renewing nuclear power plant operating

licenses for a 20-year period on all currently operating sites. In the GElS the NRC staff

identified 92 environmental issues and developed generic conclusions related to environmental

impacts'for 69 of these issues that apply to all plants or to plants with specific design or site

characteristics. For the remaining 23 issues, plant-specific analyses will be documented in a SEIS. As part of its environmental review, staff considers any new and significant information

related to Category 1 issues dispositioned generically in the GELS. If new and significant

information is identified that calls into question conclusions reached in the GELS, staff's analysis

will be documented within the SEIS for PINGP.

The SEIS will document the staff's review of environmental impacts related to land use,

environmental justice, terrestrial ecology, aquatic ecology, hydrology, cultural resources, and

socioeconomic issues (among others), and will contain a recommendation regarding the

environmental acceptability of the license renewal action.

In addition to the PIIC's involvement in the NRC's technical review of land use, socioeconomics,

cultural resources and archeology and environmental justice, we are soliciting your comments

on the full scope of the environmental review. Please submit any comments that you may have

to offer on the scope of the environmental review by September 22, 2008. Written comments

should be submitted by mail to the Chief, Rules and Directives Branch, Division of

Administrative Services, Mail Stop T-6D59, U.S. Nuclear Regulatory Commission, Washington

D.C. 20555-0001. Electronic comments may be submitted to the NRC by e-mail at

Prairielsland ElSonrc.gov.

To accommodate interested members of the public, the NRC will hold two public scoping

meetings for the PINGP license renewal environmental review on July 30, 2008. The first

session will be held in the afternoon and an identical session will be held later that evening.

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.

Additionally, the NRC staff will host informal discussions one hour before the start of each

session. Both sessions will be held at the Red Wing Public Library, 225 East Avenue, Red

Wing, MN 55066.

The PINGP license renewal application and the GElS are available on the internet at

http://wvw.nrc.gov/reactors/operating/licensing/renewal/applications/prairie-island.htrrd. In

addition, the Red Wing Public Library has agreed to make the license renewal application and

the GElS available for public inspection; 225 East Avenue, Red Wing, MN 55066. The staff

expects to publish the draft SEIS In March 2009. Although the PIIC will be involved in preparing

specific sections of the SEIS related to areas of its specialized expertise, a copy of the

document will be sent to you for your review and comment on the entire draft SEIS. The NRC

will hold another set of public meetings in the site vicinity to solicit comments on the draft SEIS.

1

2

October 2009 D-36 Draft NUREG-1437, Supplement 39
Appendix D

P. Mahowald .3-

After consideration of public comments received, and collaborative work with the PIIC to resolve

comments under the framework of the MOU. the N RC will prepare a final SEIS, which is

scheduled to be issued in October, 2009. If you need additional information regarding the

license renewal review process, please contact Mr. J.P. Leous, License Renewal Project

Manager, at 301-415-2864 or at Justin. Leous@nrc.gov.

Sincerely,

IA Andrew Stuyvenberg fori

Rani Franovich, Branch Chief

Projects Branch 2

Division of License Renewal

Office of Nuclear Reactor Regulation

Docket Nos. 50-282 & 50-306

Enclosures:

As stated

cc w/encls.: See next page

1

2

Draft NUREG-1437, Supplement 39 D-37 October 2009
Appendix D

Leg..~d

3~* beg P0Mfl, B .

I, ytr flit flitCbt -'flri.za,

Nuclear Management Company

Prairie Island Nuclear Generating Plant

License Renewal Environmental Report

Figure 2.1.3 Exclusion Area Boundary

ENCLOSURE 1

1

2

October 2009 D-38 Draft NUREG-1437, Supplement 39
Appendix D

ENCLOSURE 2

1

2

Draft NUREG-1437, Supplement 39 D-39 October 2009
Appendix D

July 22 2008

Mr. Terrance Virden

Midwest Regional Director

U.S. Bureau of Indian Affairs

1 Federal Drive

Room #550

Fort Snelling, MN 55111

SUBJECT: PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2,

LICENSE RENEWAL APPLICATION REVIEW

Dear Mr. Virden:

The U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing an application to

renew the operating licenses for the Prairie Island Nuclear Generating Plant, Units 1 and 2

(PINGP), located near Red Wing, Minnesota, approximately 39 miles southeast of Minneapolis.

PINGP is operated by Nuclear Management Company, LLC (NMC). The application for renewal

was submitted by NMC in a letter dated April 11, 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 staffs review of any nuclear power plant license

renewal action, a site-specific Supplemental Environmental Impact Statement (SEIS) to its

"Generic Environmental Impact Statement for License Renewal of Nuclear Plants," NUREG1437, will be prepared under the provisions of 10 CFR Part 51, the NRC's regulation that

implements the National Environmental Policy Act of 1969 (NEPA). In accordance with 36 CFR

800.8(c), the SEIS will include analyses of potential impacts to historic and cultural resources.

In the context of the National Historic Preservation Act of 1966, as amended, the NRC staff has

determined that 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 action.

The APE may extend beyond the immediate environs in those instances where post- license

renewal land-disturbing operations or projected refurbishment activities specifically related to

license renewal may potentially have an effect on known or proposed historic sites. This

determination is made irrespective of ownership or control of the lands of interest. For the

purpose of license renewal, NMC plans to replace the PINGP steam generators. As part of this

refurbishment activity, NMC also plans to establish a temporary construction area approximately

100 yards northwest of the turbine building and to build permanent warehouses within existing

plant boundaries. NMC states that there will be no clearing of previously-undisturbed areas.

The NRC has signed a Memorandum of Understanding (MOU) with the Prairie Island Indian

Community (PIIC) for the PINGP license renewal environmental review (Enclosure). The MOU

establishes a cooperating agency relationship between the NRC and the PIIC, with the NRC as

lead agency responsible for preparing the SEIS.

1

2

Oc tober 2009 D-40 Draft NUREG-1437, Supplement 39
Appendix D

T. Virden -2-

On July 30, 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. Both

sessions will be held at the Red Wing Public Library, 225 East Avenue, Red Wing, MN 55066.

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.

You and your staff are invited to attend. Your office will receive a copy of the draft SEIS along

with a request for comments. The staff expects to publish the draft SEIS in March 2009.

If you have any questions or require additional information, please contact Mr. J.P. Leous,

License Renewal Project Manager, by phone at 301-415-2864 or by e-mail at

Justin. Leous(c•nrc.gov.

Sincerely,

IRA by AStuyvenberg for/

Rani Franovich, Branch Chief

Projects Branch 2

Division of License Renewal

Office of Nuclear Reactor Regulation

Docket Nos. 50-282 & 50-306

Enclosure:

As stated

cc w/encl: See next page

1

2

Draft NUREG-1437, Supplement 39 D-41 October 2009
Appendix D

July 22, 2008

Ms. Heather Westra

Prairie Island Indian Community

5636 Sturgeon Lake Road

Welch, MN 55089

SUBJECT: REQUEST FOR SCOPING COMMENTS CONCERNING THE PRAIRIE ISLAND

NUCLEAR GENERATING PLANT, UNITS 1 AND 2, LICENSE RENEWAL

APPLICATION REVIEW

Dear Ms. Westra:

As you know, the U.S. Nuclear Regulatory Commission (NRC or the staff) recently received an

application from Nuclear Management Company, LLC (NMC), for the renewal of the operating

licenses for the Prairie Island Nuclear Generating Plant, Units 1 and 2 (PINGP), located near

Red Wing, Minnesota, approximately 39 miles southeast of Minneapolis.

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 licenses for PINGP will expire in August 9, 2013 and

October 29, 2014. The proposed license renewal for PINGP Units 1 and 2 would include the

use and continued maintenance of existing plant facilities and transmission lines. For the

purpose of license renewal, NMC plans to replace the PINGP steam generators. As part of this

refurbishment activity, NMC also plans to establish a temporary construction area approximately

100 yards northwest of the turbine building and to build permanent warehouses within existing

plant boundaries. NMC states that there will be no clearing of previously-undisturbed areas.

Provided for your information is the PINGP site boundary map (Enclosure 1) and transmission

system map (Enclosure 2).

The N RC has established that, as part of the staff's review of any nuclear power plant license

renewal action, a site-specific Supplemental Environmental Impact Statement (SEIS) to its

"Generic Environmental Impact Statement for License Renewal of Nuclear Plants" (GELS),

NUREG-1437, will be prepared under the provisions of Title 10 of the Code of Federal

Regulations, Part 51, the NRC's regulation that implements the National Environmental Policy

Act of 1969 (NEPA). Additionally, as outlined in Section 51.28(b), the NRC's process includes

an opportunity for public and inter-governmental participation. In accordance with 36 CFR

800.8(c), the SEIS will include analyses of potential impacts to historic and cultural resources.

The NRC recognizes the Prairie Island Indian Community's (PIIC) expertise in historic and

archeological resources, land use, socioeconomics and environmental justice. As outlined in

our Memorandum of Understanding, the PIIC has offered to contribute to staff's analysis in

these areas.

2

2

October 2009 D-42 Draft NUREG-1437, Supplement 39
Appendix D

H. Westra -2-

The GElS considered the environmental impacts of renewing nuclear power plant operating

licenses for a 20-year period on all currently operating sites. In the GElS the NRC staff

identified 92 environmental issues and developed generic conclusions related to environmental

impacts for 69 of these issues that apply to all plants or to plants with specific design or site

characteristics. For the remaining 23 issues, plant-specific analyses will be documented in a

SEIS. As part of its environmental review, staff considers any new and significant information

related to Category 1 issues dispositioned generically in the GELS. If new and significant

information is identified that calls into question conclusions reached in the GELS, staff's analysis

will be documented within the SEIS for PINGP.

The SEIS will document the staff's review of environmental impacts related to land use,

environmental justice, terrestrial ecology, aquatic ecology, hydrology, cultural resources, and

socioeconomic issues (among others), and will contain a recommendation regarding the

environmental acceptability of the license renewal action.

In addition to the PIIC's involvement in the NRC's technical review of land use, socioeconomics,

cultural resources and archeology and environmental justice, we are soliciting your comments

on the full scope of the environmental review. Please submit any comments that you may have

to offer on the scope of the environmental review by September 22, 2008. Written comments

should be submitted by mail to the Chief, Rules and Directives Branch, Division of

Administrative Services, Mail Stop T-6D59, U.S. Nuclear Regulatory Commission, Washington

D.C. 20555-0001. Electronic comments may be submitted to the NRC by e-mail at

PrairlelslandElS.nrc.qov.

To accommodate interested members of the public, the NRC will hold two public scoping

meetings for the PINGP license renewal environmental review on July 30, 2008. The first

session will be held in the afternoon and an identical session will be held later that evening. 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.

Additionally, the NRC staff will host informal discussions one hour before the start of each

session. Both sessions will be held at the Red Wing Public Library, 225 East Avenue, Red

Wing, MN 55066.

The PINGP license renewal application and the GElS are available on the internet at

http://www.nrc.gov/reactors/operatingAicensing/renewal/applications/prairie-island.htrrd. In

addition, the Red Wing Public Library has agreed to make the license renewal application and

the GElS available for public inspection; 225 East Avenue, Red Wing, MN 55066. The staff

expects to publish the draft SEIS in March 2009. Although the PIIC will be involved in preparing

specific sections of the SEIS related to areas of its specialized expertise, a copy of the

document will be sent to you for your review and comment on the entire draft SEIS. The NRC

will hold another set of public meetings in the site vicinity to solicit comments on the draft SEIS.

1

2

Draft NUREG-1437, Supplement 39 D-43 October 2009
Appendix D

H. Westra -3-

After consideration of public comments received, and collaborative work with the PIIC to resolve

comments under the framework of the MOU, the NRC will prepare a final SEIS, which is

scheduled to be issued in October, 2009. If you need additional information regarding the

license renewal review process, please contact Mr. J.P. Leous, License Renewal Project

Manager, at 301-415-2864 or at Justin.Leous@nrc.gov.

Sincerely,

VRA Andrew Stuyvenberg for I

Rani Franovich, Branch Chief

Projects Branch 2

Division of License Renewal

Office of Nuclear Reactor Regulation

Docket Nos. 50-282 & 50-306

Enclosures:

As stated

cc w/encls: See next page

1

2

October 2009 D-44 Draft NUREG-1437, Supplement 39
Appendix D

July 22, 2008

Ms. Lisa A. Joyal

Endangered Species Environmental Review Coordinator

Natural Heritage and Nongame Research Program

Minnesota Department of Natural Resources

500 Lafayette Road

Box 25

St. Paul, MN 55155

SUBJECT: REQUEST FOR LIST OF STATE-PROTECTED SPECIES AND IMPORTANT

HABITATS WITHIN THE AREA UNDER EVALUATION FOR THE PRAIRIE

ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2, LICENSE

RENEWAL APPLICATION REVIEW

Dear Ms. Joyal:

The U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing an application

submitted by Nuclear Management Company, LLC (NMC), for the renewal of the operating

licenses for the Prairie Island Nuclear Generating Plant, Units 1 and 2 (PINGP). PINGP is

located near Red Wing, Minnesota, approximately 39 miles southeast of Minneapolis. As part

of the review of the license renewal application (LRA), the NRC is preparing a Supplemental

Environmental Impact Statement (SEIS) to its "Generic Environmental Impact Statement for

License Renewal of Nuclear Plants," NUREG-1437, 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 PolicyAct (NEPA) of 1969. The SEIS includes an analysis of pertinent

environmental issues, impacts to endangered or threatened species and other fish and wildlife.

NMC is requesting renewal of its operating licenses for PINGP for a period of 20 years beyond

the expiration of the current license terms of August 9, 2013, and October 29, 2014,

respectively. This proposed action would include the use and continued maintenance of

existing plant facilities and transmission lines. For the purpose of license renewal, NMC plans

to replace the PINGP steam generators. As part of these refurbishment activities, NMC also

plans to establish a temporary construction area approximately 100 yards northwest of the

turbine building and to build permanent warehouses within existing plant boundaries. NMC

states there will be no clearing of previously-undisturbed areas.

The PINGP site encompasses approximately 578 acres, and is located on the western shore of

Sturgeon Lake. Prairie Island, upon which PINGP is located, is a low island terrace in the

Mississippi River; please see the attached site boundary map (Enclosure 1). The Prairie Island

Indian Reservation is directly north of the site.

One 161-kilovolt (kV) and four 345-kV transmission lines connect Prairie Island to the regional

transmission system; please see the attached Prairie Island transmission system map

(Enclosure 2). To support the 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 PINGP and its associated

2

2

Draft NUREG-1437, Supplement 39 D-45 October 2009
Appendix D

L. Joyal -2-

transmission line corridors. In addition, please provide any information you consider appropriate

under the provisions of the Fish and Wildlife Coordination Act.

The NRC staff plans to hold two public NEPA scoping meetings on July 30, 2008. The first

session will be held in the afternoon and an identical session will be held later that evening.

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. Both

sessions will be held at the Red Wng Public Library, 225 East Avenue, Red Wing, MN 55066.

In addition, during the week of August 18, 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 March 2009.

If you have any questions concerning the NRC staffs review of this license renewal application,

please contact Mr. J.P. Leous, License Renewal Project Manager, at 301-415-2864 or by

e-mail at Justin.Leous(,nrcoqov.

Sincerely,

IRA by AStuyvenberg for/

Rani Franovich, Branch Chief

Projects Branch 2

Division of License Renewal

Office of Nuclear Reactor Regulation

Docket Nos. 50-282 & 50-306

Enclosures:

As stated

c w/encls: See next page

1

2

October 2009 D-46 Draft NUREG-1437, Supplement 39
Appendix D

July 22, 2008

Mr. Tony Sullins

Field Supervisor

U.S. Fish & Wildlife Service

Twin Cities Ecological Services Office

4101 East 8 0 th Street

Bloomington, MN 55425

SUBJECT: REQUEST FOR LIST OF FEDERALLY PROTECTED SPECIES WiTHIN THE

AREA UNDER EVALUATION FOR THE PRAIRIE ISLAND NUCLEAR

GENERATING PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION

REVIEW

Dear Mr. Sullins:

The U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing an application

submitted by Nuclear Management Company, LLC (NMC), for the renewal of the operating

licenses for Prairie Island Nuclear Generating Plant, Units 1 and 2 (PINGP). PINGP is located

near Red Wing, Minnesota, approximately 39 miles southeast of Minneapolis. 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 impacts to endangered or threatened species and other fish and

wildlife. This letter is being submitted under the provisions of the Endangered Species Act of

1973, as amended, and the Fish and Wildlife Coordination Act of 1934, as amended.

NMC is requesting renewal of its operating licenses for PINGP for a period of 20 years beyond

the expiration of the current license terms of August 9, 2013, and October 29, 2014,

respectively. This proposed action would include the use and continued maintenance of

existing plant facilities and transmission lines. For the purpose of license renewal, NMC plans

to replace the PINGP steam generators. As part of this refurbishment activity, NMC also plans

to establish a temporary construction area approximately 100 yards northwest of the turbine

building and to build permanent warehouses within existing plant boundaries. NMC states there

will be no clearing of previously-undisturbed areas.

The PINGP site encompasses approximately 578 acres and is located on the western shore of

Sturgeon Lake. Prairie Island, upon which PINGP is located, is a low island terrace in the

Mississippi River; please see the enclosed site boundary map (Enclosure 1). The Prairie Island

Indian Reservation is directly north of the site.

PINGP has three cooling system operating modes: once-through, once-through with "helper"

(mechanical draft) cooling towers in operation, and closed cycle (mechanical draft cooling

towers only). The circulating water and service water systems withdraw water from the

Mississippi River. Three groundwater wells are used to meet domestic water needs. River

water moves into the intake screenhouse, where the circulating water pumps are housed,

through eight intake bays, each equipped with a trash rack, a traveling screen, and high/low

1

2

Draft NUREG-1437, Supplement 39 D-47 October 2009
Appendix D

T. Sullins -2 -

pressure wash systems. Four circulating water pumps supply water to the condensers for

cooling. Each pump has a design capacity of 147,000 gpm, with a total circulating water flow of

approximately 588,000 gpm. Conditions outlined in NMC's National Pollutant Discharge

Elimination System permit specify requirements for use of the cooling towers to minimize effects

on local aquatic resources.

One 161-kilovolt (kV) and four 345-kV transmission lines connect PINGP to the regional

transmission system; please see the enclosed PINGP transmission system map (Enclosure 2).

To support the SEIS preparation process and to ensure compliance with Section 7 of the

Endangered Species Act, the NRC requests information on federally-listed, proposed, and

candidate species and critical habitat that may be in the vicinity of PINGP and its associated

transmission line corridors. In addition, please provide any information you consider appropriate

under the provisions of the Fish and Wildlife Coordination Act.

The NRC staff plans to hold two public NEPA scoping meetings on July 30, 2008. The first

session will be held in the afternoon and an identical session will be held later that evening.

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. Both

sessions will be held at the Red Wng Public Library, 225 East Avenue, Red Wng, MN 55066.

In addition, during the week of August 18, 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 March 2009.

If you have any questions concerning the NRC staffs review of this LRA, please contact

Mr. J.P. Leous, License Renewal Project Manager, at 301-415-2864 or Justin.Leouso-nrc.gov.

Sincerely,

IRA by AStuyvenberg for/

Rani Franovich, Branch Chief

Projects Branch 2

Division of License Renewal

Office of Nuclear Reactor Regulation

Docket Nos. 50-282 & 50-306

Enclosures:

As stated

cc w/encls: See next page

1

2

October 2009 D-48 Draft NUREG-1437, Supplement 39
Appendix D

July 22, 2008

Emily Rusch, Environmental Review Assistant

Wisconsin Department of Natural Resources

Bureau of Endangered Species

PO Box 7921

Madison, Wi 53707

SUBJECT: REQUEST FOR LIST OF STATE-PROTECTED SPECIES WiTHIN THE AREA

UNDER EVALUATION FOR THE PRAIRIE ISLAND NUCLEAR GENERATING

PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION REVIEW

Dear Ms. Rusch:

The U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing an application

submitted by Nuclear Management Company, LLC (NMC), for the renewal of the operating

licenses for Prairie Island Nuclear Generating Plant, Units 1 and 2 (PINGP). PINGP is located

near Red Wing, Minnesota, approximately 39 miles southeast of Minneapolis. 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 (N EPA) of 1969. The SEIS includes an analysis of pertinent

environmental issues, including impacts to endangered or threatened species and fish and

wildlife. This letter is being submitted under the provisions of the Endangered Species Act of

1973, as amended, and the Fish and Wildlife Coordination Act of 1934, as amended.

NMC is requesting renewal of its operating licenses for PINGP for a period of 20 years beyond

the expiration of the current license terms of August 9, 2013, and October 29, 2014. This

proposed action would include the use and continued maintenance of existing plant facilities

and transmission lines. For the purpose of license renewal, NMC plans to replace the PINGP

steam generators. As part of this refurbishment activity, NMC also plans to establish a

temporary construction area approximately 100 yards northwest of the turbine building and to

build permanent warehouses within existing plant boundaries. NMC states there will be no

clearing of previously-undisturbed areas.

The PINGP site encompasses approximately 578 acres, and is located on the western shore of

Sturgeon Lake. Prairie Island, upon which PINGP is located, is a low island terrace in the

Mississippi River; please see the enclosed site boundary map. The Prairie Island Indian

Reservation is directly north of the site.

PINGP has three cooling system operating modes: once-through, once-through with "helper'

(mechanical draft) cooling towers in operation, and closed cycle (mechanical draft cooling

towers only). The circulating water and service water systems withdraw water from the

Mississippi River. River water moves into the intake screenhouse, where the circulating water

pumps are housed, through eight intake bays, each equipped with a trash rack, a traveling

screen, and high/low pressure wash systems. Four circulating water pumps supply water to the

1

2

Draft NUREG-1437, Supplement 39 D-49 October 2009
Appendix D

E. Rusch -2-

condensers for cooling. Each pump has a design capacity of 147,000 gpm, with a total

circulating water flow of approximately 588,000 gpm. Conditions outlined in NMC's National

Pollutant Discharge Elimination System permit specify requirements for use of the cooling

towers, in order to minimize effects on local aquatic resources. Three groundwater wells are

used to meet domestic water needs.

One 161-kilovolt (kV) and four 345-kV transmission lines connect PINGP to the regional

transmission system; please see the enclosed PINGP transmission system map.

To support the 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 PINGP and its associated

transmission line corridors. In addition, please provide any information you consider appropriate

under the provisions of the Fish and Wildlife Coordination Act.

The NRC staff plans to hold two public NEPA scoping meetings on July 30, 2008. The first

session will be held in the afternoon and an identical session will be held later that evening.

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. Both

sessions will be held at the Red Wing Public Library, 225 East Avenue, Red Wing, MN 55066.

In addition, during the week of August 18, 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 March 2009.

If you have any questions concerning the NRC staffs review of this LRA, please contact

Mr. J.P. Leous, License Renewal Project Manager, at 301-415-2864 or Justin.Leousft.nrc.gov.

Sincerely,

IRA by AStuyvenberg for/

Rani Franovich, Branch Chief

Projects Branch 2

Division of License Renewal

Office of Nuclear Reactor Regulation

Docket Nos. 50-282 & 50-306

Enclosures:

As stated

cc w/encls: See next page

1

2

October 2009 D-50 Draft NUREG-1437, Supplement 39
Appendix D

July 22, 2008

Mr. Dennis A. Gimmestad

Government Programs and Compliance Officer

State Historic Preservation Officer

Minnesota Historical Society

345 Kellogg Boulevard West

Saint Paul, MN 55102-1903

SUBJECT: PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2,

LICENSE RENEWAL APPLICATION REVIEW

Dear Mr. Gimmestad:

The U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing an application to

renew the operating licenses for Prairie Island Nuclear Generating Plant, Units 1 and 2

(PINGP), located near Red Wing, Minnesota, approximately 39 miles southeast of Minneapolis.

PINGP is operated by Nuclear Management Company, LLC (NMC). The application for renewal

was submitted by NMC in a letter dated April 11, 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 staffs review of any nuclear power plant license

renewal action, a site-specific Supplemental Environmental Impact Statement (SEIS) to its

"Generic Environmental Impact Statement for License Renewal of Nuclear Plants," NUREG1437, will be prepared under the provisions of 10 CFR Part 51, the NRC's regulation that

implements the National Environmental Policy Act of 1969 (NEPA). In accordance with 36 CFR

800.8(c), the SEIS will include analyses of potential impacts to historic and archaeological

resources.

In the context of the National Historic Preservation Act of 1966, as amended, the staff has

determined that 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 action.

The APE may extend beyond the immediate environs in those instances where post- license

renewal land-disturbing operations, transmission line right-of-ways, or projected refurbishment

activities specifically related to license renewal may potentially have an effect on known or

proposed historic sites. This determination is made irrespective of ownership or control of the

lands of interest.

For the purpose of license renewal, NMC plans to replace the PINGP steam generators. As

part of the refurbishment activity, NMC also plans to establish a temporary construction area

approximately 100 yards northwest of the turbine building and to build permanent warehouses

within existing plant boundaries. NMC states that there will be no clearing of previouslyundisturbed areas.

1

2

Draft NUREG-1437, Supplement 39 D-51 October 2009
Appendix D

D. Gimmestad -2-

The NRC has signed a Memorandum of Understanding (MOU) with the Prairie Island Indian

Community (PIIC) for the PINGP license renewal environmental review (Enclosure). The MOU

establishes a cooperating agency relationship between the NRC and the PIIC, with the NRC as

lead agency responsible for preparing the SEIS.

On July 30, 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. Both

sessions will be held at the Red Wing Public Library, 225 East Avenue, Red Wing, MN 55066.

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.

You and your staff are invited to attend. Your office will receive a copy of the draft SEIS along

with a request for comments. The staff expects to publish the draft SEIS in March 2009.

If you have any questions or require additional information, please contact Mr. J.P. Leous,

License Renewal Project Manager, by phone at 301-415-2864 or by e-mail at

Justin. Leous(.nrc.gov.

Sincerely,

IRA by AStuyvenberg for/

Rani Franovich, Branch Chief

Projects Branch 2

Division of License Renewal

Office of Nuclear Reactor Regulation

Docket Nos. 50-282 & 50-306

Enclosure:

As stated

cc: See next page

1

2

October 2009 D-52 Draft NUREG-1437, Supplement 39
Appendix D

July 24, 2008

Ronald Johnson, President

Prairie Island Indian Community

5636 Sturgeon Lake Road

Welch, MN 55089

SUBJECT: REQUEST FOR SCOPING COMMENTS CONCERNING THE PRAIRIE ISLAND

NUCLEAR GENERATING PLANT, UNITS 1 AND 2, LICENSE RENEWAL

APPLICATION REVIEW

Dear President Johnson:

The U.S. Nuclear Regulatory Commission (NRC or the staff) has recently received an

application from Nuclear Management Company, LLC (NMC), for the renewal of the operating

licenses for the Prairie Island Nuclear Generating Rant, Units 1 and 2 (PINGP), located near Red Wing, Minnesota, approximately 39 miles southeast of Minneapolis. The NRC is in the

Initial stages of developing a Supplemental Environmental Impact Statement to the "Generic

Environmental Impact Statement for License Renewal of Nuclear Plants" (GElS), NUREG-1 437,

which will document the impacts associated with the renewal of PINGP. 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 (10 CFR 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 1966 through the requirements of the National

Environmental Policy Act of 1969. An identical letter has been sent to other tribal organizations

with historic ties to the project area.

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 licenses for PINGP will expire on August 9, 2013 and October

29, 2014. The proposed action (license renewal for PINGP Units 1 and 2) would include the

use and continued maintenance of existing plant facilities and transmission lines. For the

purpose of license renewal, NMC plans to replace the PINGP steam generators. As part of this

refurbishment activity, NMC also plans to establish a temporary construction area approximately

100 yards northwest of the turbine building and to build permanent warehouses within existing

plant boundaries. NMC states there will be no clearing of previously-undisturbed areas.

Provided for your information is the PINGP site boundary map (Enclosure 1) and transmission

system map (Enclosure 2).

1

2

Draft NUREG-1437, Supplement 39 D-53 October 2009
Appendix D

-2-

The GElS considered the environmental impacts of renewing nuclear power plant operating

licenses for a 20-year period on all currently operating sites. In the GElS the NRC staff

identified 92 environmental issues and developed generic conclusions related to environmental

impacts for 69 of these issues that apply to all plants or to plants with specific design or site

characteristics. For the remaining 23 issues, plant-specific analyses will be documented in a

supplement to the GEIS.

A supplemental environmental impact statement will be prepared for PINGP to document the

staff's review of environmental impacts related to land use, environmental justice, terrestrial

ecology, aquatic ecology, hydrology, cultural resources, and socioeconomic issues (among

others), and will contain a recommendation regarding the environmental acceptability of the

license renewal action.

Please submit any comments that you may have to offer on the scope of the environmental

review by September 22, 2008. Written comments should be submitted by mail to the Chief,

Rules and Directives Branch, Division of Administrative Services, Mail Stop T-6D59, U.S.

Nuclear Regulatory Commission, Washington, DC 20555-0001. Electronic comments may be

submitted to the NRC by e-mail at PrairielslandEIS(onrc.aov. At the conclusion of the scoping

process, the NRC staff will prepare a summary of the significant issues identified and the

conclusions reached, and mail a copy to you.

To accommodate interested members of the public, the NRC will hold two public scoping

meetings for the PINGP license renewal supplement to the GElS on July 30, 2008. The first

session will be held in the afternoon and an identical session will be held later that evening.

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.

Additionally, the NRC staff will host informal discussions one hour before the start of each

session. Both sessions will be held at the Red Wiing Public Library, 225 East Avenue, Red

Wing, MN 55066.

The PINGP license renewal application and the GElS are available on the internet at

http://wwvv.nrc.go v/reactors/operating/licensing/renewal/applications/prairie-island~htrr.

In addition, the Red Wing Public Library has agreed to make the license renewal application and

the GElS available for public inspection; 225 East Avenue, Red Wing, MN 55066.

2

2

October 2009 D-54. Draft NUREG-1437, Supplement 39
Appendix D

-3-

The staff expects to publish the draft supplemental environmental impact statement in March

2009. A copy of the document will be sent to you for your review and comment. The NRC will

hold another set of public meetings in the site vicinity to solicit comments on the draft

supplemental environmental impact statement. After consideration of public comments

received, the NRC will prepare a final supplemental environmental impact statement, which is

scheduled to be issued in October 2009. If you need additional information regarding the

license renewal review process, please contact Mr. J.P. Leous, License Renewal Project

Manager, at 301-415-2864 or at Justin. Leous•,nrc.gov.

Sincerely,

IRA by A. Stuyvenberg for/

Rani Franovich, Branch Chief

Projects Branch 2

Division of License Renewal

Office of Nuclear Reactor Regulation

Docket Nos. 50-282 & 50-306

Enclosures:

As stated

cc w/encls.: See next page

2

Draft NUREG-1437, Supplement 39 D-55 October 2009
Appendix D

United States Department of the Interior

FISH AND WILDLIFE SERVICE

Twin Cities Field Office

•4101 American Blvd E.

Bloomington, Minnesota 55425-1665

August 13, 2008

Mr. Rani Frinovich

Branch Chief

U.S. Nuclear Regulatory Conmission

Projects Branch 2

Division of License Renewal

Office of Nuclear Reactor Regulation Washington, D.C. 20555-0001

Subject: Request for list of federally protected species within the area under evaluation

for the PrairieIsland Nuclear Generating Plant, Units I and 2, license renewal application

review.

This concerns your July 22, 2008,. letter requesting a list of federally threatened and

endangered species from the U.S. Fish and Wildlife Service that may occur in the vicinity

of the Prairie Island Nuclear Generating Plant near Red Wing in Goodhue County,

Minnesota.

The following federally-listed endangered (E) species is present in this portion of the

Upper Mississippi River:

S'ecies Scientific Name Habitat

Higgins eye pearly Lampsilis higginsii Mississippi River

musscl.(E)

There is no designated critical habitat for the above species, nor any candidate species

listed for Goodhue County. Sturgeon Lake, located upstream from the Prairie Island Nuclear Generating Plant, is a Population Establishment Site for Higgins eye. The St.

Paul District Corps of Engineers in association with the interagency Mussel Coordination

Team has placed several -thousand Higgins eye in Sturgeon Lake to establish a viable

population. They are also using Sturgeon Lake to propagate Higgins eye in cages for use

in.establishing additional 'populations in Minnesota, Wisconsin and Iowa. Additional

information on these activities can be obtained at the following website:

htil://www.nivp.usace.armnainil/enviroruilentldefault.asp?pageid=663.

lnatidcrdanice.with Section 7(c) of the Endanigired Species Act of 1973, as amended, it is

the responsibility of the Federal agency to determine if its actions "may affect" listed

1

2

October 2009 D-56 Draft NUREG-1437, Supplement 39
Appendix D

species or. critical habitat. We recommend that your assessment of project effects on

federally-listed species be included in any environmental documentation required for the

proposed license renewal.

We also recommend that you contact the Minnesota Department of Natural Resources

concerning any state-listed species which may occur within the vicinity of the project.

We appreciate. the opportunity to comment and look forward to workingwith you in the

future. If you have questions regarding our comments, please call Mr. Gary Wege of my

staff at (612) 725-3548, extension 207.

Si cerely

ny Su s

Field Supervisor

cc: Minnesota Department of Natural Resources, St. Paul, MN

_PrairieIsland Indian Community, Red Wing. Mi.N

1

2

Draft NUREG-1437, Supplement 39 D-57 October 2009
Appendix D

.41? UNITED STATES

DEPARTMENT OF 7THE INTERIOR TAKE PRIDE

BURýE.AU .OF IN ID .A .N .AFFAIRS A ERC

INWREPLY .REFER TO: Bishop Henry Whlppl Fe Buildig

Servir.,es O Fedr D ,Room 5150

Sew Frt Sne91i1ng, MN 551.11

AUG8za

Rani Franovich, Branch Chief

P ets ranch 2, :.D in of Lk • Renewal -se 

Office of License Renewal

US. NucleaiecýatorY.Commission

Washington, D.C. 20520

Dear Branch Chief Franovich:

This is in respons .e to Your lietter re~ques ting- B[A attendance a t a, scopigm etn fo license

renewal'at the P~rairie Island Niuceair Gen~emri*ng PAnb Juy3l f thiyiar -

Un" U nft eately yourrcj.Wt w'ceivcd by 'thi• fficeT'oilJuiy31" ig -i-ibpdiblcfor

us to atted. .This •isuwnfootunate as -the Departmentof tisteror isde fedher :tzustee for'

lands held in trust for the be'neficial use of thei Praiise IA*A~d TlnCnisiyn

teeoehas a vest~ed interest n dhe pr~o'cess. Ou0 usoscnersaeflos

How are the innmediate envylons defined as peart of the'APE? HaveSwpe~cif~Iic.atons been

idniidfort~te "post-lies renewalz laddisturbinig operation *or projete

refurish#.nt activities"• -tr.nainu• r of-- s ed inyul etter týertod to 

in'n'esot&.SHPO? Is therm a map showing the boun~daries of the APE?ý Have you

consul 6ted Iote 'sintribes?

Can you tebus where. In the Section, 106 process -the N14kc is curesiy

the Bureau of India Afi" (61k) has an'interest in the undertaing and. its efct to the

pv u . o . ... • . .. , -b" 

P ,Isii sl~d Inia Co unry. .. a•ndon.hitoicto .' 1 Bie . .b . •,,0flt Ot ega .. .

and economic relations wh the Commrniiv, and te O.re'q pate s.s

consulting par• y • CF'8 OO.2( c)(5)Adi on-ulting c p -.. r.•• . . .

What idance will be used in the analysis of Environmental Justice?

Do you anicipatcaiy. earth disturbing actividies'occurrin'on tribal trust lands?'

S B partpaonin this proc ess u n .b c c with

1

2

October 2009 D-58 Draft NUREG-1437, Supplement 39
Appendix D

-2- Augut 18, 2008

occur with each of those tribes on a goverrzment-to-government leveL The BlIA would be

happy to assist you in determining which tribes may be affected;

If you have any further questions the enviuonmental staff contact is Sort Doig at 612-725-

4514

Sincerely,

Sitne/Kevin BeaD•rUI'•

ActingRkcionsil Director

1

2

Draft NUREG-1437, Supplement 39 D-59 October 2009
Appendix D

/vMiinncsota i.)cpartnient of Natural Rcso urccs

Division ofEcologcal Resources, Box 25

Phone: (651) 259-5107 Far. (651) 296-1811 E-mail: heidi.xyr@dnr.state.mn us

August 26, 2008

Mr. Ram Franovich

United States Nuclear Regulatory Commission

Washington, D.C. 20555-0001

Re: Request for Natural Heritage infonnation in the vicinity of the Prairie Island Nuclear Generating Plant

Correspondence #: ERDB 20070820-0003

Dear Mr. Franovich,

As requested, the Minnesota Natural Heritage Information System has been queried to determine if any rare

species or other significant natural features are known to occur within an approximate one-mile radius of the proposed

project. Based on this query, several rare features have been documented within the search area. Fordetails, please see

the enclosed database reports.

The Natural Heritage Information System (NHIS). a collection of databases that contains information about

Minnesota's rare natural features, is maintained by the Division of Ecological Resources, Department of Natural

Resources. The NHIS is continually updated as new information becomes available, andis the most complete source of

data on Minnesota's rare or otherwise significant species, native plant communities, and other natural features.

However, the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features

within the state. Therefore, ecologically significant features for which we have no records may exist within the prcj ect

area.

The enclosed results include an Index Report and a Detailed Report of records in the Rare Features Database,

the main database of the NHIS. To control the release of specific location information, which might result in the

destruction of a rare feature, both reports are copyrighted.

The Index Report provides rare feature locations only to the nearest section, and may be reprinted, unaltered, in

an environmental review document (e.g., EAW or EIS), municipal natural resource plan, or report compiled by your

company for the project listed above. Ifyou wish to reproduce the index report for any other purpose, please contact me

to request written permission. The Detailed Report may Include specific location Information, and Is for your

personal use only. If you wish to reprint or publish the detailed report for any purpose, please contact me to

request written permission.

Please be aware that this letter focuses only on potential effects to rare naturalfeaturer, there may be other

natural resource concems associated with the proposed project. This letter does not constitute review or approval by the

Department of Natural Resources as a whole. If you would like further information on the environmental review

process, please contact your Regional Environmental Assessment Ecologist, Wayne Barstad, at (651) 259-5738. Thank

you for consulting us on this matter, and for your interest in preserving Minnesota's rare natural resources.

Sincerely,

Heidi Cyr

Endangered Species Environmental Review Specialist

enc. Rare Features Database: Index Report

Rare Features Database: Detail Report

Rare Features Database Reports: An Explanation of Fields

October 2009 D-60 Draft NUREG-1437, Supplement 39
Appendix D

NI' Ap 008

Nfinn~.ota Natural I leritage InforsnalIon Syvslern: Rare Features Dalahue

Index ReportI of records witinI)f mifle radIus of.

Prairie Islod Nuclcar (3encruting I'lanI

Plant Site

Pape of 5

F

Elstneal Nan*. and Occurencre Number

Dakota. Coodisut. Wabasha County, MNI

Polvdoonqmhu~la WI'ddlfi~hi 1-2

Lmfien DcripticrrTII12N RI9W S 1.1.T I I3N R I4W S19. T I IONKIOWS3.T II I NR I OW s33.T

Dakota. ;oodtsun. Waschington Contl, MNI

LWI114,c1MU (Blacuk Sandch~0I 1105

I1."aou Da9-nrAipi:. T 1 14 R I AVS.M. T I 13N R3 15"S4. T I I N R I7 S!5. TI 15N R I-W S23- T .

Icco~lionl.[5 nil-lon: r2IIN 82WSI 12. T0Nr 2O II I NRo 5c.iIN RISW S5. FI

Itoodhue Cnc-ty %.IN

I., c;Iion D~I.-ixt T I 13N RI5W 59, TI 13N RIM\ S1

ANI~0Ib,~t8, (ola ~m~fI 151

1,,valicll [1k-rit~imi T] 1N RMV9.*1 51.3N RISW 510

55131crm filv,ýcens ([Akeliuem #Iaa~r 206

L.,Xafion Du6,Iicrpfa TI IIN RI5W S29,TII.IN RI WS32

AtnAiaript rgoaflinan~ (Nluckcti 0115

Lc-cticn DnIpfi~orr T113N RIAWS9. T1I3N R15.\SII.TI )-IN RI5WOS1O.TI 13N RISWSIOT

AcdinmaisliaoiL0 nq.IIuam \ttkiIe) oI 58

Ix~rie TIINRI5S-I f9anlo T SNRI\(''I TISNRI5W SOTISN R15WS5_TI...j

Ab1_-'lIIII814 ljftIIWJLW,0 IEkI0c #116i

Locaioa~ucooon II I 81W SSTI IIN ISWSOT 1-N RISWS32,1II3N R15W SIO.T

I.,-f.icII 139 ripfi-AA 1I N RI 5WST 5131 RN RIMSW10

AlIIipaaPriiila 6-lyolal WLF~) 1123

Iinalioe I) 6plro TI I3N RI.SW SO),TI I N WWSWSIO

51iI8nIju(Smoet4h So(Maell) d 13

Location [)mrci1 *icnTI 13N R13W SI0

'edffral .NIN State Global

Statu Status Rank Rank

1I1IR S2 G4

Last Ohwnvd

Date vO ID

2000-10 16507

SPC

1118

TIOR

THR

TIIR

six:

S IK:

S3

S3

S2

S3

S2

S2

1S3

S3

2006-06-21

2000--05-21

2001.07-09

1080-09-17

2004-08-02

33850

16529

201.15

277.AS

310098

21135

30151

30177

G5

(GS

G25

1 Copyr Igh 2008. DhdWon of Ecologiical Resources, Sntit of MiInneoto DN R

Draft NUREG-1437, Supplement 39 D-61 October 2009
Appendix D

Mintnesola Natural I lerilage InformatIon System: Rare Fealures I-atiahise

Index Reporl of records within I mile radius oa:

Prairie Jsland Nuclear Oereraling Planl

Plano Sie

P.gR 2 of.I

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Appendix D

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Draft NUREG-1437, Supplement 39 D-63 October 2009
Appendix D

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October 2009 D-64 Draft NUREG-1437, Supplement 39
Appendix D

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Draft NUREG-1437, Supplement 39 D-65 October 2009
Appendix D

State of Wisconsin \ DEPARTMENT OF NATURAL RESOURCES

West Central Region Headquarters SJim Doyle, Governor 1300 W. Clairemont Avenue

Matthew J. Frank, Secretary PO Box 4001 ACOSNScott Humtrckhouse, Regional Director Eau Claire, Wisconsin 54702,4001

(DEPT. 1 OF NATURAL RESOURCES Telephone 715-839-3700 .9 FAX M1-039-6076 TTY Access via relay- 711

September 8, 2008

Nathan Goodman

US Nuclear Regulatory Commission

Mail Stop: 0-t 1iF

Washington, DC 20555-0001

Subject: Prairie Island (MN) Nuclear Generating Plant (PINGP) License Renewal - EIS Issue Scoping

Dear Mr. Goodman:

Thank you for inviting Wisconsin Department of Natural Resources (WDNR) to the Nuclear Regulatory Commission (NRC)

relicensing "audit" at the P[NGP plant on August 20, 2008. It was very informative. At that meeting you invited WDNR to

prepare and submit a list of issues we feel should he addressed in NRC's Environmental Impact Statement prepared as part of

PINGP relicensing process.

I. Fish Impingement and Entrainment at Water Intake

Information should be provided describing the extent of fish entrainment and impingement at the water

intake and associated fish mortality. What is the incremental effect on fish populations? What measures are

in place or proposed to minimize losses?

2. Upper Mississippi River Navigation Pool 3 Drawdowns for Habitat Enhancement

A consortium of federal and stale agencies is considering use of temporary Pool 3 water level

manipulations (i.e. 1-2' drawdowns) for purposes of improving aquatic habitat conditions. We have heard

there may be PINGP concerns, such as for fire control or design limits of waler intake structure(s), that may

conflict with the idea of pool drawdowns. Please describe any such concerns and identify measures that are

proposed or could be employed to prevent conflicts with any such drawdowns.

3. Cooling Water Discharge Thermal Effects to:

A. Mississippi River Biological Resources

Describe past fish kills, particularly those associated with efmuent thermal mixing during cold water

conditions, resulting from past plant operations. Describe the make-up and extent ofother biological

resources (ie. mussel community, etc.) in the discharge canal and Mississippi River mixing zone. What

studies/monitoring has been done in effort to document thermal discharge impacts to aquatic organismts?

What design and/or operational measures have been employed to minimize adverse effects and how

successfiul have they been? What additional remedial measures are proposed or could be used to further

avoid or minimize adverse impacts?

dnr.wigov .

wisconsin.gov

1

2

October 2009 D-66 Draft NUREG-1437, Supplement 39
Appendix D

B. Mississippi River Public Recreation Use Opporstnities

We have routinely received seasonal complaints from the ice fishing public that access to historic fishing

areas in upper Lake Pepin is adverscly impacted by warm water discharges, resulting in delayed ice

formation at winter's onset and more rapid ice deterioration before spring icc-out. The EIS should describe

P[NGP discharge effects on winter ice cover and usability of traditional ice fisherman access points.

Feasible measures to offset adverse impacts should be identified and incorporated as license conditions.

4. Zebra Mussel Control Impacts to Native Mussels and Other Aquatic Resources

Best management practices for control ofbiofouling from zebra mussels and other exotic species continues

to evolve. What measures (molluscicides, other) are currently employed to control zebra mussels and has

there been any monitoring to determine if such practices result in impacts to native mussels or other aquatic

life? Measures to minimize adverse impacts should be identified. Given the evolving identification of best

management practice control tcchnology the license should provide for a periodic re-assessment and an

adaptive management approach to exotic species management and remedial methods.

5. Idnctificationr of Planned or Foreseeable Future (over new NRC license term) Physical Improvements (i.e,

new/upgraded transmission lines, new/modified water intake structures, etc.) and Any Associated Impacts

in Wisconsin

Would relicensing set a precedent that would result in an interest by Xcel in constructing new or upgraded

transmission lines or other physical improvements that directly or indirectly impact Wisconsin? At our

meeting it was explained that no such improvements are proposed or expected and that a license condition

would be incorpeorated indicating no such improvements would be authorized as part of relicensing.- We

interpret this to mean that any such unforeseen future improvements would be subject to applicable federal

and/or state regulations, including NEPA if appropriate, as a separate action. Please confirm this in the EIS.

As stated at our meeting I am currently the primary WDNP, contact person for this project and that Mr. Nick Schaff will

serve in that capacity starting in April 2009. If there are any questions regarding the above I would be happy todiscuss them.

I'm also available to make arrangements for WDNR fisheries, water quality or other program experts to meet with you or other NRC staff, Xcel personnel or representatives from other resource management agencies, to discuss issues of common interest.

Thank you for the opportunity to submit WDNR scoping comments for this project.

Sincerely,

TL 9/8/08

Tom Lovejoy

Environmental Impact Coordinator

cc:

Dave Siebert - Director, WDNR Office ofEnergy/Envirotnmental Analysis

Nick Schaff- WCR

Gretchen Benjamin, John Sullivan, Ron Benajmin. - LaX, WI

Gary Wege- US FWS, Bloomington. MN

Dan Wilcox - Corps of Engineers, St. Paul. MN

Man Langan - MDNR, St. Paul. MN

Tim Schlagenhafi - MDNR, Lake City, MN

1

2

Draft NUREG-1437, Supplement 39 D-67 October 2009
Appendix D

October 23, 2008

Mr. Kevin Bearquiver

Midwest Regional Director

U.S. Bureau of Indian Affairs

1 Federal Drive

Room #550

Fort Snelling, MN 55111

SUBJECT: RESPONSE TO LETTER FROM K. BEARQUIVER REGARDING PRAIRIE

ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND-2, LICENSE

RENEWAL APPLICATION REVIEW

Dear Mr. Bearquiver,

This letter responds to your letter dated August 18, 2008, regarding the U.S. Nuclear Regulatory

Commission's (NRC) environmental review for the Prairie Island Nuclear Generating Plant

(PINGP) license renewal. We regret that you were unable to attend the July 30, 2008, public

scoping meeting. Justin Leous, the previous project manager for the PINGP license renewal,

left a telephone message for Mr. Terrance Virden the week of July 14, 2008, to notify the

Bureau of Indian Affairs (BIA) of the upcoming public scoping meeting. Additionally, NRC staff

sent BIA a letter addressed to Mr. Terrance Virden dated July 22, 2008: The NRC also sent a general meeting notice letter on July 17, 2008, to interested and/or affected parties, and BIA was included on the distribution of this letter.

In regard to your questions specifically concerning the NRC letter to the Minnesota State

Historic Preservation Office, NRC staff conducts scoping in order to gather information for the

scope of its environmental review. The deadline to submit scoping comments was September

22, 2008. Nathan Goodman, Project Manager, tried on several occasions to reach the contact

given in your letter, Scott Doig, and left several messages in hopes of reaching Mr. Doig

regarding any questions the BIA might have had concerning NRC staff's scoping process prior

to closing of the scoping period.

Additionally, Nuclear Management Company submitted an Environmental Report as part of its

application for the license renewal of PINGP, which is available on the NRC public website. The

Environmental Report addresses many of the questions you have identified in your letter.

Concerning your question about environmental justice, under Executive Order 12898 (59 FR

7629), Federal agencies are responsible for identifying and addressing potential

disproportionately high and adverse human health and environmental impacts on minority and

low-income populations. The Council on Environmental Quality (CEQ) has oversight of the

Federal government's compliance with Executive Order 12898 and the National Environmental

Policy Act (NEPA), and in consultation with the Environmental Protection Agency and other

affected agencies, CEO developed guidance to ensure that environmental justice concerns are

effectively identified and addressed in the NEPA procedures of Federal agencies. This

guidance is presented in Environmentat Justice: Guidance Under the National Environmental

PolicyAct (1997). NRC staff uses this guidance as it applies to NRC license reviews.

1

2

October 2009 D-68 Draft NUREG-1437, Supplement 39
Appendix D

K. Bearquiver 2 -

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 to the general goals set forth in E.O. 12898, and strives to meet those

goals as part of its NEPA review process. For determining the impacts to minority and lowincome populations, NRC staff follows the Commission's Policy Statement on Environmental

Justice as well as guidance set forth in NRR Office Instruction LIC-203, Revision 1, Appendix D

- 'Environmental Justice Guidance and Flow Chart."'

As noted in NRC staff's letter to the BIA regarding scoping, the NRC has signed a Memorandum

of Understanding (MOU) with the Prairie Island Indian Community for the environmental portion

of the PINGP license renewal review. The MOU establishes a cooperating agency relationship

between the NRC and the PIIC, with the NRC as lead agency responsible for preparing a

supplemental environmental impact statement.

In regards to the BIA being a consulting party for the Section 106 process under 36CFR800.2,

the NRC granted BIA consulting party status by including them on the NRC's distribution list,

which enables BIA to receive all related documents throughout the environmental review

process for the proposed PINGP license renewal. Currently, the NRC is in the identification

phase of the Section 106 process.

NRC staff looks forward to werking with the BIAthroughout the relicensing process. If you have

any questions, please contact Mr. Nathan Goodman, License Renewal Project Manager, by

phone at 301-415-2703 or by e-mail at nathan.,goodmancb~nrc.gov.

Sincerely,

IRAI

Ranl Franovich, Branch Chief

Projects Branch 2

Division of License Renewal

Office of Nuclear Reactor Regulation

Docket Nos. 50-282 and 50-306

Enclosures:

As stated

cc w/encls: See next page

1

2

Draft NUREG-1437, Supplement 39 D-69 October 2009
Appendix D

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

Biological Assessment

Prairie Island Nuclear Generating Plant, Units 1 and 2

License Renewal

October 2009

Docket Nos. 50-282 and 50-2306

U.S. Nuclear Regulatory Commission

Rockville, Maryland

October 2009 D-70 Draft NUREG-1437, Supplement 39
Appendix D

1 Biological Assessment of the Potential Effects on Federally Listed

2 Endangered or Threatened Species from the Proposed License Renewal for

3 Prairie Island Nuclear Generating Plant, Units 1 and 2

4 1.0 Introduction and Purpose

5 The U.S. Nuclear Regulatory Commission (NRC) prepared this biological assessment to

6 support the draft supplemental environmental impact statement (SEIS) for the renewal of the

7 operating licenses for Prairie Island Nuclear Generating Plant Units 1 and 2 (PINGP 1 and 2),

8 located on the west bank of the Mississippi River in Goodhue County, Minnesota. The current

9 40-year licenses for PINGP 1 and 2 expire on August 9, 2013 (DPR-42) and October 29, 2014

10 (DPR-60), respectively. The proposed license renewal for which this biological assessment has

11 been prepared would extend the operating licenses to 2033 and 2034.

12 The NRC is required to prepare the draft SEIS as part of its review of a license renewal

13 application. The draft SEIS supplements NUREG-1437, Volumes 1 and 2, "Generic

14 Environmental Impact Statement for License Renewal of Nuclear Plants (GELS)," (NRC 1996,

15 1999) for the license renewal of commercial nuclear power plants. The draft SEIS covers

16 specific issues, such as the potential impact on endangered and threatened species, that are of

17 concern at PINGP 1 and 2 and that NRC could not address on a generic basis in the GELS.

18 Pursuant.to Section 7 of the Endangered Species Act of 1973 (ESA), as amended, the NRC

19 staff requested, in a letter dated July 22, 2008 (NRC 2008b), that the U.S. Fish and Wildlife

20 Service (FWS) provide information on Federally listed endangered or threatened species, as

21 well as on proposed or candidate species, and on any designated critical habitats that may

22 occur in the vicinity of PINGP 1 and 2. In its response, dated August 13, 2008 (FWS 2008), the

23 FWS indicated that the Higgins eye pearlymussel (Lampsilis higginsii) is present in Upper

24 Mississippi River within the vicinity of PINGP 1 and 2, though no designated critical habitat is

25 present for the species in Goodhue County. Currently, no Federally listed threatened or

26 endangered terrestrial species are known to occur on the PINGP 1 and 2 site or within the in27 scope transmission line right-of-ways.

28 Under ESA Section 7, the NRC is responsible for providing information on the potential impact

29 that the continued operation of PINGP 1 and 2 could have on the Federally listed species, the

30 Higgins eye pearlymussel. The potential affect of relicensing PINGP 1 and 2 on Higgins eye

31 pearlymussels occurs through the extending for an additional 20 years the operation of the

32 cooling water system, which can affect the mussels and the species on which they depend

33 through entrainment, impingement, and changes to the thermal environment. Additional

34 information can be found in Chapters 2 and 4 of the draft SEIS.

35 2.0 Proposed Action

36 Northern State Power Co. (NSP) submitted an application for license renewal of PINGP 1 and 2,

37 for which the existing licenses expire in 2013 and 2014, respectively. The Federal action is

38 NRC's decision to renew or not renew the licenses for an additional 20 years beyond the

39 original 40-year term of operation. Nuclear power plant owners or operators may need to

40 undertake or, for economic or safety reasons, may choose to perform refurbishment activities in

41 anticipation of license renewal or during the license renewal term. NSP plans to replace two of

42 the four steam generators at PINGP 1 and 2, Unit 2, with new, once-through, enhanced steam

43 generators to support the extended life of PINGP 1 and 2 through the renewed license period.

44 NSP replaced the steam generators on Unit 1 in 2004, and so would replace steam generators

Draft NUREG-1437, Supplement 39 D-71 October 2009
Appendix D

1 only on Unit 2 during the period of extended operation. In Chapter 3 of the draft SEIS, NRC

2 analyzed steam generator replacement as a refurbishment activity as part of license renewal.

3 3.0 Site Description

4 PINGP 1 and 2 are located on Prairie Island on the Mississippi River (Figures 2-1 and 2-22).

5 The Mississippi is the longest river in North America and spans 2302 miles (mi; 3705 kilometers

6 [km]) from its source at Lake Itasca in Minnesota to the Gulf of Mexico, where it empties. The

7 river drains approximately 189,000 mi2 and 31 different states. The Mississippi can be divided

8 into six sub-basins (EPA 2006), and the PINGP 1 and 2 site is located in the Upper Mississippi

9 Sub-basin. The Upper Mississippi Sub-basin encompasses over 20,000 mi2 and has 12 major

10 tributaries, the most notable being the Missouri River, the Illinois River, the Wisconsin River,

11 and the Iowa River (MPCA 2008).

12 Prairie Island itself is low-lying and located in a 1- to 3 mi- (1.6- to 4.8 km)-wide section of the

13 Mississippi River Valley, with the majority of the island being less than 25 feet (ft; 7.6 meters

14 [m]) above the river surface. On either side of the valley are 360-ft (110-m) high bluffs

15 composed of Paleozoic limestones and sandstones (Cowdery 1999). Prairie Island is located

16 between the Mississippi River and the Vermillion River, with the confluence of the two rivers at

17 the downstream end of the island (EPA 2006). About 1.5 mi (2.4 km) downstream from the

18 island is Lock and Dam Number 3, which controls the water level and flow of this stretch of the

19 Mississippi (USGS 2006).

20 Prairie Island itself is located on Sturgeon Lake (Figure 2), an area of the Mississippi created by

21 the rise in water elevation by Lock and Dam Number 3 and the subsequent flooding of sections

22 of the floodplain. The PINGP 1 and 2 cooling system withdraws from and discharges to the main

23 stem of the Mississippi River 13 river miles below the confluence of the St. Croix River and 4

24 river miles north of where the Vermillion River joins the Mississippi (AEC 1973). Lock and Dam

25 3, about 1.5 mi (2.4 km) downstream and Lock and Dam 2, upstream, bound the area of the

26 river adjacent to PINGP 1 and 2 known as Pool 3. The two dams lie about 18 river miles (29

27 river kilometers) apart (NMC 2008). Immediately northeast of the plant is Sturgeon Lake, a side

28 slough or impoundment that would be considered a marsh if it were not associated with the

29 main stem of the river (AEC 1973). The Vermillion River borders the southwest portion of the

30 site.

31

2 Figures 2-1 and 2-2 are taken from Chapter 2 of the draft SEIS for PINGP 1 and 2.

October 2009 D-72 Draft NUREG-1437, Supplement 39
Appendix D

Sheqbrbw7,N onh

Wildide Re( 0 

BCorro0t /le

National 6 Scni Rit. 

Mississippi arw

And Rg e?

*I C1,41uj

-. 4 ~j~ CL

STeb AI/,7r NY ALLoLnQ HO 

Legend

* Lod, aWd Dam

" FINGP

r ,e 5 10 if) 20 

• P'vi 0.jnflInia -Jfl tnocyty

Pmo 'tjMaw" Figure 2-1. Location of Prairie Island

r=I• Hv.r.A.,.i. Nuclear Generating Plant, Units I and 2,

r-ocy ,•.c,.y 50-mi (80-km) Region (Source: NMC 2008)

1

2

Draft NUREG-1437, Supplement 39 D-73 October 2009
Appendix D

Legend

. XRI '.g on

P1lnt Feau'eý D Excfnýo Afea Boircar; -Pyarrie Is±ar Indsflig

LOC3T Neqr'ZWOW, Q RW~f RODU

Rai-cad

I 0 50 1,000 2Zi00 3000 4.00

Figure 2-2. PINGP General Site Layout

and Exclusion Area Boundary

(Source: NMC 2008)

1

2

October 2009 D -74 Draft NUREG-1437, Supplement 39
Appendix D

1 3.1. Cooling and Auxiliary Water Systems

2 The Mississippi River is the source for cooling water for the main condenser at PINGP 1 and 2.

3 Cooling river water can be circulated through the station in one of three modes of operation:

4 open cycle (once-through cooling, with no cooling towers in operation), helper cycle (once5 through cooling, with mechanical draft cooling towers in operation), and closed cycle (using

6 cooling towers to recirculate up to 95 percent of the cooling water). The mode of operation is

7 selected by NSP to limit the heat discharged to the river to ensure compliance with the thermal

8 limits of the NPDES permit No. MD0004006 (MPCA 2006; NMC 2008).

9 The components of the current cooling water system are the eight intake bays, the Intake

10 Screenhouse, trash racks, traveling screens, high/low pressure wash systems, fish return

11 system, bypass gates, intake canal, Plant Screenhouse, circulating water pumps, condensers,

12 discharge basin, mechanical draft cooling towers, discharge canal, and distribution basin. (NMC

13 2008)

14 The Final Environmental Statement (FES) for Operation of PINGP 1 and 2 (AEC 1973)

15 describes the original cooling water system. Water was withdrawn from the Mississippi River

16 into the 750-ft (230-m)-long intake canal, and into what is now called the Plant Screenhouse.

17 Inside the screenhouse, the water passed through trash racks and coarse-mesh traveling

18 screens to remove fish and debris before supplying the condensers. The plant could operate in

19 each of the three modes described above, and so the heated effluent from the plant was either

20 pumped to the cooling towers or released to the river, via an 800-ft (240-m)-long canal. In the

21 early 1980s, the State of Minnesota directed PINGP I and 2 to modify the cooling system to

22 reduce impacts to aquatic communities by installing the Intake Screenhouse, equipped with

23 trash racks, coarse- and fine-mesh traveling screens, variable pressure wash systems, and a

24 fish return system, described below (Stone and Webster 1983).

25 With the current cooling water system in place, water flows from the river, under a skimmer wall,

26 and into the eight intake bay openings, each 18.5 by 11.2 ft (5.6 by 3.4 m), of the Intake

27 Screenhouse. The intake bays each have a trash rack, a traveling screen, and high/low

28 pressure wash systems, and a fish return system. After passing through the Intake

29 Screenhouse, water flows down the intake canal to the Plant Screenhouse, where four 147,000-

30 gallon-per-minute (gpm; 9.3-cubic meters per second [m3/s]) circulating water pumps supply

31 water to the condensers for a total flow for both units of approximately 588,000 gpm (37.1 m3/s).

32 (NMC 2008)

33 After leaving the condensers, the cooling water then enters the discharge basin, and from there

34 the final path of the cooling water is determined by the operating mode of the plant. In open

35 cycle, the cooling water flows from discharge basin, through the distribution basin, into the

36 discharge canal, ultimately returning to the Mississippi River. In helper and closed cycles, the

37 water is pumped from discharge basin to the cooling towers, and from there returns to the intake

38 canal for recirculation (closed cycle) or flows through the distribution basin, into the discharge

39 canal, and out to the Mississippi River (helper cycle). A small amount of warm water from the

40 discharge canal is pumped to the intake structure to prevent ice formation on trash racks,

41 traveling screens, and bypass gates. (NMC 2008)

42

43

44 Intake Screenhouse and Fish Return

45 Within the Intake Screenhouse are the trash racks and traveling screens. The trash rack in each

46 bay is made of 3/8-inch (in.) by 3-in. (0.95-centimeter [cm] by 7.6-cm) steel bars, mounted on an

Draft NUREG-1437, Supplement 39 D-75 October 2009
Appendix D

1 incline 1.5 in. (3.8 cm) apart; a trash rake clears accumulated debris (NMC 2008; Stone and

2 Webster 1983). After passing through the trash rack, the water flows through the traveling

3 screens.

4 The NPDES permit No. MD0004006, issued June 30, 2006, by the Minnesota Pollution Control

5 Agency (MPCA), dictates that from September 1 through March 31, PINGP 1 and 2 may

6 operate with up to 3/8-in. (0.95-cm) mesh traveling screens, and that from April 1 through

7 August 31, the traveling screens must be 0.5 millimeters (mm; 0.02 in.) fine mesh screens

8 (MPCA 2006). Before the cooling water system was modified in 1983, the approach velocity to

9 the existing traveling screens was 1.3 feet per second (fps; 0.40 meters per second [m/s]) at

10 normal water levels and 1.4 fps (0.43 m/s) at low water levels. The design criteria for the

11 average face velocity through the gross area of the screen material for the fine mesh screens

12 should not exceed 0.5 fps (0.15 m/s) at low water level and a discharge rate of 800 cubic feet

13 per second (cfs; 22.6 m3

/s). Flow measurements taken in 1983 and 1984 were less than 0.2 m/s

14 (0.66 fps), and most were below 0.1 m/s (0.33 fps). Intake velocities were again studied in 2003

15 during coarse mesh screen operation. The authors of the study concluded that the actual intake

16 velocities were not outside those design requirements. (Xcel Energy Environmental Services

17 2006)

18 To remove larvae and fish from the upward travel side of the screen, a low pressure spray is

19 used at 10 pounds per square inch (psi; 0.7 kilograms per square centimeter [kg/cm 2

]) from the

20 inside for the fine mesh screen (larval screenwash), and at 20 psi (1.4 kg/cm 2) from the outside

21 when the coarse mesh screen is in use (fish screenwash) (Stone and Webster 1983; NMC

22 2008). On the downward travel side of the screen, a high pressure spray from the inside is used

23 to remove debris from the screens, at 50 psi (3.5 kg/cm 2) for the fine mesh screen and 100 psi

24 (7 kg/cm 2) for the coarse mesh screen (NMC 2008). The fine mesh screens rotate continuously

25 between 3 and 20 feet per minute (fpm; 1 and 6 meters per minute [m/min]), based on the

26 amount of debris collected; the coarse mesh screens rotate at the same range of speeds when

27 the screen differential is higher than 4 in. (10 cm) or if the screens have not rotated for 8 hours

28 (Xcel Energy Environmental Services 2006; NMC 2008).

29 Fish are washed off the upward travel side of the screens into a trough and debris is washed

30 from the downward travel side into a separate trough. The troughs combine into a common

31 trough and are transported back to the river via a 2200-ft-(670-m)-long, buried pipe, which

32 discharges into the river 1500 ft (460 m) south of the Intake Screenhouse, below mean water

33 elevation, and at a depth below any ice cover. Fish and debris travel through the pipe at

34 velocities between 3 to 5 ft/s (1 to 1.5 m/s), but may speed up in sections of the pipe. (Stone

35 and Webster 1983; Xcel Energy Environmental Services 2006; NMC 2008)

36 If the screens are clogged, the head differential across the traveling screens or across the

37 intake screenhouse can become too high and trigger the opening of bypass gates to allow water

38 to circumvent the intake screenhouse. The plant screenhouse (part of the original cooling

39 system) is still equipped with 3/8-in. screens that remove debris before the water enters the

40 condensers, and the intake screens are cleared to minimize the time the bypass gates are

41 open. (Stone and Webster 1983)

42 Discharge and Cooling Tower System

43 The discharge basin receives all of the cooling water from the condensers. The path that the

44 water takes next is dependent on the operating mode of the cooling system. During open cycle,

45 the water flows through the distribution basin, into the discharge canal, and out to the

46 Mississippi River. During closed and helper cycles, the water is pumped to the cooling towers.

47 The cooled water (blowdown) from the cooling towers then moves via the cooling tower return

48 canal to the distribution basin. In closed cycle, the distribution basin returns the water to the

October 2009 D-76 Draft NUREG-1437, Supplement 39
Appendix D

1 intake canal to recycle through the condensers. In helper cycle, the distribution basin routes the

2 water to the discharge canal and into the river. (NMC 2008)

3 Water enters the discharge canal through four 10- by 11-ft (3- by 3.4-m) openings to four sluice

4 gates operated by motors. The sluice gates lead to four pipes, which vary in diameter [5, 6, 7,

5 and 8 ft (1.5, 1.8, 2.1, and 2.4 m)] and are used in different combinations to achieve the desired

6 discharge rate. If only the smallest pipe is in use, the discharge rate is 150 cfs (4 m3

/s). If all four

7 pipes are used (all sluice gates are open), the maximum discharge rate is 1390 cfs (39 m3

/s),

8 and the velocity of the discharging water is 10.17 ft/s (3.1 m/s). (Stone and Webster 1983)

9 The mechanical draft cooling tower system includes four cooling towers, fans, water distribution

10 headers, and basins. Each tower, made up of a bank of 12 sections cells, includes a cooling

11 tower pump, which pumps water from the discharge basin through distribution pipes to the top

12 of the cooling tower. Spray nozzles disperse the water, which drops through a maze of "fill" to

13 the basin at the base of the cooling towers. Fans blow air up through the falling water,

14 evaporating water and allowing the heat to disperse out the top of the cooling towers into the

15 atmosphere. The water in the cooling tower basin flows through the cooling tower return canal

16 to the distribution basin, where it can either be routed back through the facility's condensers by

17 way of the intake canal (closed cycle) or sent to the discharge canal to return to the Mississippi

18 River (helper cycle). The cooling towers can be used for the total circulating water flow of

19 588,000 gpm (37.1 m3/s) and can remove up to 96 percent of the waste heat created by the

20 facility. (NMC 2008)

21 Requirements Under NPDES Permit

22 In accordance with the Federal Water Pollution Control Act (or the Clean Water Act [CWA]),

23 PINGP 1 and 2 effluent discharges are regulated by the NPDES and State Disposal System

24 Permit No. MN0004006 issued and enforced by the MPCA. Section 402 of the CWA states that

25 "NPDES prohibits [discharges] of pollutants from any point source into the nation's waters

26 except as allowed under an NPDES permit." The purpose of this permit is to regulate

27 wastewater discharge to preserve the water quality of the surrounding water bodies. As of the

28 most recent permit issued, there have been no notices of violation for the PINGP 1 and 2 site.

29 Information in this section was obtained from the most recent PINGP 1 and 2 NPDES permit, a

30 copy of which is included in the applicant's license renewal environmental report. The most

31 recent renewal of this permit occurred in June 2006 and expires August 2010.

32 In order to minimize the impacts from the PINGP 1 and 2 cooling system on entrainment and

33 impingement of fish and shellfish, the NPDES permit dictates the screen size the plant must use

34 during the spring and summer. Additionally, the NPDES permit imposes limits on the discharge

35 of cooling water from April to June, in order to minimize the impacts of entrainment and

36 impingement of fish and shellfish. This indirectly restricts the withdrawal rates, as the discharge

37 rate approximates the withdrawal rate.

38 To minimize the impacts the heated discharge from the PINGP 1 and 2 cooling system, the

39 NPDES permit specifies the times and trigger points when the plant must switch the operating

40 mode of the cooling system. The permit defines the fall trigger point as when the daily average

41 upstream ambient river temperature falls below 43 degrees Fahrenheit (OF; 6 degrees Celcius

42 [°C]) for five consecutive days. (MPCA 2006)

43 The only surface discharge aside from the discharge canal outfall (SD 001) that discharges

44 directly to the Mississippi is SD 012. SD 012 discharges the plant intake screen backwash as

45 well as the fish return system of any impinged fish, aquatic organisms, or debris directly to the

46 river.

Draft NUREG-1437, Supplement 39 D-77 October 2009
Appendix D

1 The cooling water discharge restrictions are as follows. From April 15 to April 30 discharge is

2 restricted to 194 million gallons per day (mgd; 7.34 x 105 cubic meters per day [m3

/day]) if the

3 flow of the Mississippi River is at or above 15,000 cfs (424.8 m3

/s). If the river flow is below this

4 level, discharge is limited to 97 mgd (3.67 x 105 m3

/day). From May 1 to May 31 discharge is

5 restricted to 194 mgd (7.34 x 105 m3

/day), from June 1 to June 15 it raises to 259 mgd (9.80 x

6 105 m3/day), and from June 16 to 30 is raises again to 517.5 mgd (1.96 x 106 m3/day). Outfall

7 SD 001 is permitted to exceed these discharge limitations only in the event that it is necessary

8 in order to prevent temperatures from exceeding 85 OF (29 'C).

9 Thermal limitations require temperature monitoring at five different locations: the discharge

10 canal outfall (SD 001), the plant intake (SW 002), a specified point in the main river channel

11 (SW 003), a specified point in Sturgeon Lake (SW 004), and a point directly downstream of Lock

12 and Dam No. 3 (SW 001) which is to be monitored using three different temperature probes.

13 The permit states that the daily average temperature should under no circumstances exceed 86

14 OF (30 0C) and that the temperature of the receiving water should not raise over 5 OF (2.8 'C)

15 above the ambient water temperature. The permit specifies that if the ambient water

16 temperature reaches 78 OF (26 °C) for two consecutive days, all cooling towers should operate

17 to their maximum extent.

18 4.0 Assessment of Listed Species and Critical Habitat

19 Life History of Higgins Eye Pearlymussel

20 The Higgins eye pearlymussel was Federally listed as an endangered species on June 14, 1976

21 (41 FR 24064). Although the historical range is not completely known, the Higgins eye was

22 never abundant. The current distribution, which includes the Upper Mississippi River above

23 Lock and Dam 19 and the St. Croix, Wisconsin, and Rock Rivers, is about half the historical

24 range (FWS 2000a). Although FWS (2004a) lists no critical habitat for the species, it has

25 designated 10 Essential Habitat Areas for the Higgins eye: Six in the Mississippi River, 3 in the

26 St. Croix River, and 1 in the Wisconsin River. The closest Essential Habitat Area to PINGP 1

27 and 2 is in the St. Croix River, just upstream of the junction with the Mississippi River, near

28 Prescott, Wisconsin (FWS 2004a).

29 Higgins eye pearlymussels are typically found in large, stable, species-diverse mussel beds in

30 medium to large rivers with firm substrate ranging from sand to boulders (FWS 2000a; 2004a).

31 Water current velocities typical of Higgins eye habitat range from 0.5 to 1.5 fps (1.5 to 4.5 cm/s),

32 and depths range from 3.3 to 19.7 ft (1-6 m) (FWS 2000a). To reproduce, males release sperm

33 into the water column. As females siphon water for food, they also take in the sperm to fertilize

34 eggs in gill sacs (marsupia), where the fertilized eggs mature into glochidia (a larval stage). The

35 ribbon-like mantle edge near the posterior of the female acts as a lure to attract fish; when the

36 fish attack the mantle, glochidia are released into the water and attach to the gills of the host

37 fish. If the glochidia successfully attach to fish gills, they can mature into juvenile mussels

38 (typically 3 weeks), excyst from the gills, settle to suitable substrate, and mature into adults.

39 Some studies suggest glochidia remain in the marsupia through winter and are released in

40 spring or summer. (FWS 2000a; FWS 2004a)

41 Fish known to be suitable hosts for the glochidia of the Higgins eye pearlymussel include

42 freshwater drum (Aplodinotus grunniens), largemouth bass (Micropterus salmoides),

43 smallmouth bass (M. dolomieu), yellow perch (Perca falvescens), sauger (Stizostedion

44 canadense), and walleye (S. vitreum vitreum); marginal fish hosts include northern pike (Esox

45 lucius), bluegill (Lepomis macrochirus), and green sunfish (L. cyanellus) (FWS 2004a).

46 Status of Higgins Eye Pearlymussel in the Vicinity of PINGP Units 1 and 2

October 2009 D-78 Draft NUREG-1437, Supplement 39
Appendix D

1 Currently, the major threat to the Higgins eye pearlymussel, like most other native mussels in

2 the Upper Mississippi River, is the invasion of zebra mussels (Dreissena polymorpha), which

3 compete for food and space, and even colonize on native mussels. The subfamily Lampsilinae

4 to which the Higgins eye belongs is among the most sensitive groups of mussels to zebra

5 mussel invasion (FWS 2000a). Researchers have not developed effective and practical

6 measures to control zebra mussel populations without harming native aquatic organisms

7 (WDNR 2004).

8 Other threats to the survival of native mussel species, including Higgins eye pearlymussel,

9 include dredging, the disposal of dredged material, channelization, and commercial navigation.

10 The creation of the lock and dam system in the Upper Mississippi River caused pools to replace

11 once-flowing water, and the movement of fish species that serve as hosts to native mussel

12 species and participate in their distribution are now restricted. Damming the upper Mississippi

13 may have favored Higgins eye populations in some pools, because low velocity waters provide

14 favorable habitat for the species. Yet some observations indicate that populations of Higgins

15 eye in some pools have decreased, possibly due to conditions such as increased

16 sedimentation. The net effect of damming the Mississippi River on Higgins eye populations

17 therefore remains uncertain. Few documented reports of the commercial harvest of Higgins eye

18 exist. (FWS 2000a)

19 In 1993, the USACE began a consultation with the FWS under Section 7 of the ESA for the

20 operation and maintenance of the 9-foot Navigation Project on the Upper Mississippi River. The

21 Higgins eye pearlymussel was included in this consultation. As a result, FWS (2000a) issued a

22 biological opinion with a jeopardy determination for the Higgins eye. FWS provided reasonable

23 and prudent alternatives to allow for the project while offsetting adverse impacts to the species

24 involved, including the alternative that USACE develop a Higgins' eye pearlymussel relocation

25 action plan and conduct a study to control the spread of zebra mussels.

26 The USACE (2002), in cooperation with the Mussel Coordination Team, an interagency team of

27 biologists, issued an environmental assessment for a relocation plan of the Higgins eye, with a

28 proposal to establish five new populations of the Higgins eye by moving adults from zebra

29 mussel-infested areas into sections of the river that had no or low levels of zebra mussels, as

30 well as raising juvenile mussels at hatcheries and stocking areas of the river (USACE 2002).

31 State and Federal agencies, including the FWS, determined that an area within Pool 3, 0.5 mi

32 (0.8 km) upstream of the PINGP 1 and 2 intake structure, was a suitable habitat for a relocation

33 project for subadult Higgins eye. In 2002, USACE, in cooperation with the Mussel Coordination

34 Team, prepared an environmental assessment for the relocation plan for the Higgins eye, in

35 which they report "good recovery of mussels" following the relocation of 100 adult Higgins eye

36 by the Minnesota Department of Natural Resources (MNDNR), the Wisconsin Department of

37 Natural Resources (WDNR), and the FWS (USACE 2002). The environmental assessment also

38 identified the location as a good relocation site based on the 2000 Minnesota 305(b) water

39 quality status report, which listed Pool 3 as providing "full support" for aquatic life (USACE

40 2002). Over 4000 sub-adults have been relocated to the Sturgeon Lake section of Pool 3, as of

41 the 2005 Status Report (Mussel Coordination Team 2005). The Mussel Coordination Team

42 (2005) reported "good recovery" for Pool 3 subadults after conducting monitoring in 2003.

43 Effects of PINGP Units 1 and 2 on Higgins Eye Pearlymussel

44 The cooling water intake structure of a power plant can pose a threat to fish and shellfish, and

45 mussels have the potential to be impinged on screens or entrained by the cooling system. The

46 life cycle of the Higgins eye pearly mussel renders it unlikely that individuals of this species

47 would be at risk of impingement or entrainment. Gravid females carry fertilized eggs until they

48 mature into glochidia. The female uses a lure to attract host fish and releases the glochidia into

Draft NUREG-1437, Supplement 39 D-79 October 2009
Appendix D

1 the water column, where they can attach to the gills of the fish; if they fail to attach to the host,

2 glochidia are unlikely to attach later and mature into juveniles. Glochidia that successfully attach

3 to fish gills mature into juveniles, drop from the gills to the river bottom, and settle on the river

4 bottom. Juveniles that settle On suitable substrate mature into adults. Because juveniles and

5 adults do not live in the water column, their likelihood of entrainment is very low.

6 The one period of the life cycle during which the Higgins eye could be at risk from the cooling

7 system of a power plant is when the glochidium is attached to the fish host. If the host fish is

8 impinged and killed on the screens of the cooling system, the glochidium would be unlikely to be

9 able to mature into a juvenile; if it had already matured into a juvenile and dropped off the fish

10 while the fish was impinged, it would be swept into the cooling system and entrained. FWS

11 (2004) reported that suitable fish hosts for the glochidia of the Higgins eye pearlymussel include

12 freshwater drum (Aplodinotus grunniens), largemouth bass (Micropterus salmoides),

13 smallmouth bass (Micropterus dolomieu), yellow perch (Perca falvescens), sauger (Sander

14 canadense), and walleye (S. vitreus vitreus); marginal fish hosts include northern pike (Esox

15 lucius), bluegill (Lepomis macrochirus), and green sunfish (Lepomis cyanellus). In its

16 Impingement Mortality and Entrainment Characterization Plan, Xcel Energy Environmental

17 Center (2006) reported impingement or entrainment of these species during various life stages.

18 The biology of some life stages of some of these host species limits their susceptibility to

19 impingement and entrainment by PINGP 1 and 2. The centrarchids (largemouth and smallmouth

20 bass, bluegill, and green sunfish) build nests where they spawn and the males guard the eggs

21 and larvae for weeks to months, depending on the species. The eggs of the centrarcheds and

22 percids (yellow perch, sauger, and walleye) are demersal and sticky, and so are not particularly

23 vulnerable to entrainment. The larvae of these percids, however, are planktonic, and vulnerable

24 to entrainment. Only the freshwater drum has planktonic eggs and larvae, and Xcel Energy

25 (2006) reports high numbers of these impinged on the PINGP 1 and 2's fine-mesh screens. Xcel

26 Energy (2006) also reported that immediate impingement survival of prolarvae and postlarve of

27 all fish species is low, averaging 7.2 and 5.5 percent, respectively, and but did not measure or

28 estimate the more meaningful, longer-term incipient survival, which would be even lower.

29 Juvenile freshwater drum, sunfish, and percids are impinged, but the average immediate

30 survival of all juvenile fish impinged on the fine-mesh screens is relatively high (71.5 percent

31 (Xcel Energy 2006), although incipient survival is unknown. The adults of the host fish species

32 typically can swim fast enough to have low vulnerability, although Xcel Energy (2006) reports

33 impingement of some adult percids and centrarchids on the fine-mesh screens. When taken

34 together, these results suggest that populations of fish species that serve as hosts for Higgins

35 eye pearlymussel have some limited vulnerability to entrainment and impingement at PINGP 1

36 and 2, at least locally, that might result in somewhat reduced population numbers. NRC staff

37 finds that any such reductions, if they occur, would not adversely affect Higgins eye

38 pearlymussels, however, because no population of the Higgins eye has been reported in the

39 vicinity of the plant.

40 5.0 Conclusion

41 In order to assess the potential adverse affects on the Higgins eye pearlymussel, the NRC staff

42 considered the life cycle of the Higgins eye, the limited time the mussel spends in the water

43 column during which it could be subject to entrainment, and the low probability of the primary

44 fish hosts for the species being impinged (and therefore the even lower probability of a fish host

45 being impinged while carrying Higgins eye glochidia). In addition, Higgins eye pearlymussels

46 were not found in the area around Lock and Dam 3 in studies conducted in 1986, 1999, 2000,

October 2009 D-80 Draft NUREG-1437, Supplement 39
I

Appendix D

1 and 2003. The NRC staff concludes that renewal of the PINGP Units 1 and 2 licenses to

2 operate for an additional 20 years is not likely to adversely affect Higgins eye pearlymussel.

3 NRC staff also recognizes that the FWS determined that the area just upstream of the PINGP 1

4 and 2 intake structure is a suitable site for the Higgins eye relocation project. If that project is

5 successful in establishing a reproducing population of Higgins eye during the renewal term of

6 the licenses, impingement and entrainment at PINGP 1 and 2 of suitable fish hosts may

7 adversely affect the mussel population. Therefore, NRC may have to re-assess the potential for

8 adverse effects at some time in the future.

9 6.0 References

10 AEC (Atomic Energy Commission). 1973. Final Environmental Statement Related to the

11 Operation of Prairie Island Nuclear Generating Plant. Washington, D.C. ADAMS No.

12 ML081840311.

13 Cowdery, T.K. 1999. Water Resources of the Prairie Island Indian Reservation, Minnesota,

14 1994-1997. Water-Resources Investigation Report 99-4069. U.S. Geological Survey. Available

15 URL: http://mn.water.usgs.gov/pubs/99-4069.pdf (accessed October 10, 2008).

16 EPA (U.S. Environmental Protection Agency). 2006. Mississippi River Basin & Gulf of Mexico

17 Hypoxia Upper Mississippi, Background on Upper Mississippi River Basin. Available URL:

18 http://www.epa.gov/msbasin/subbasins/upper/index.htm (accessed on October 10, 2008).

19 ADAMS No. ML083120233.

20 FWS (U.S. Fish and Wildlife Service). 2000a. Biological Opinion for the Operation and

21 Maintenance of the 9-Food Navigation Channel on the Upper Mississippi River System. U.S.

22 Fish and Wildlife Service, Division of Endangered Species, Fort Snelling, Minnesota. Available

23 URL: http://www.fws.gov/midwest/endangered/section7/umrbofinal.pdf (accessed September

24 25, 2008).

25 FWS (U.S. Fish and Wildlife Service). 2004a. Higgins Eye Pearlymussel (Lampsilis higginsil)

26 Recovery Plan: First Revision. Ft. Snelling, Minnesota. 126 pp. Available URL:

27 http://ecos.fws.gov/docs/recoveryplans/2004/040714.pdf (accessed August 27, 2008).

28 FWS (U.S. Fish and Wildlife Service). 2008. Letter from T. Sullins, U.S. Fish and Wildlife

29 Service, Twin Cities Ecological Services Office, to R. Franovich, Branch Chief, Division of

30 License Renewal. Subject: Request for List of Federally Protected Species Within the Area

31 Under Evaluation for the Prairie Island Nuclear Generating Plant, Units 1 and 2, License

32 Renewal Application Review. August 13, 2008. ADAMS No. ML082470303.

33 MPCA (Minnesota Pollution Control Agency). 2006. National Pollutant Discharge Elimination

34 System, Permit MN0004006, Prairie Island Nuclear Generating Plant. June. ADAMS No.

35 MPCA (Minnesota Pollution Control Agency). 2008. Upper Mississippi River Basin. Available

36 URL: http://www.pca.state.mn.us/water/basins/uppermiss/index.html (accessed October 10,

37 2008). ADAMS No. ML083380243.

38 Mussel Coordination Team. 2005. Status of Implantation of Higgins Eye Pearlymussel

39 (Lampsilis higginsil) Reasonable and Prudent Alternatives and Reasonable and Prudent

40 Measures and Winged Mapleleaf (Quadrula fragosa) Reasonable and Prudent Measures.

41 November 2005. Available URL:

42 http://www.fws.gov/Midwest/mussel/documents/statushiggins-eye-winged-mapleleaf-2005.pd

43 f (accessed December 12, 2008).

Draft NUREG-1437, Supplement 39 D-81 October 2009
Appendix D

1 NMC (Nuclear Management Company, LLC). 2008. Prairie Island Nuclear Generating Plant,

2 Units 1 and 2, License Renewal Application, Appendix E - Applicant's Environmental Report,

3 License Renewal Operating Stage. Redwing, Minnesota. April 2008. ADAMS Nos.

4 ML081130677, ML081130681, and ML081130684.

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

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

7 ADAMS Nos. ML040690705 and ML040690738.

8 NRC (U.S. Nuclear Regulatory Commission). 1999. Generic Environmental Impact Statement

9 for License Renewal of Nuclear Plants, Main Report, Section 6.3 - Transportation, Table 9.1,

10 Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report.

11 NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

12 NRC (U.S. Nuclear Regulatory Commission). 2008b. Letter from U.S. Nuclear Regulatory

13 Commission to T. Sullins, U.S. Fish and Wildlife, Twin Cities Ecological Services Office.

14 Subject: Request for List of Federally Protected Species Within the Area Under Evaluation for

15 the Prairie Island Nuclear Generation Plant, Units 1 and 2, License Renewal Application

16 Review. July 22, 2008. Accessible at ML081850485.

17 Stone and Webster (Stone and Webster Engineering Corp.). 1983. Modify Circulating Water

18 Intake and Discharge: System Description and Design Criteria. Prepared for Northern States

19 Power Co. Denver. April 1, 1983. ADAMS No. ML0831202223.

20 USACE (US Army Corps of Engineers). 2002. Final July 2002 Definite Project Report and

21 Environmental Assessment for Relocation Plan for the Endangered Higgins' Eye Pearlymussel

22 (Lampsilis higginsil), Upper Mississippi River and Tributaries, Minnesota, Wisconsin, Iowa, and

23 Illinois. In cooperation with the Mussel Coordination Team. July. Available URL:

24 http://www.fws.gov/Midwest/mussel/documents/ dprrelocationplan final july_2002.pdf

25 (accessed August 27, 2008).

26 USGS (U.S. Geological Survey). 2006. Water Resources Data, Minnesota, Water Year 2005:

27 Water Data Report MN-05-051. April 5, 2006. ADAMS No. ML028806950

28 WDNR (Wisconsin Department of Natural Resources). 2004. Zebra Mussels (Dreissena

29 polymorpha). Available URL: http://dnr.wi.gov/invasives/factl zebra.htm (accessed September

30 11, 2008). ADAMS No. ML083380525.

31 Xcel Energy Environmental Services. 2006. Xcel Energy Prairie Island Nuclear Generating

32 Plant, Impingement Mortality and Entrainment Characterization Study. Submitted in Accordance

33 with the NPDES Final Regulations to Establish Requirements for Cooling Water Intake

34 Structures at Phase II Existing Facilities, NPDES Permit MN0004006. October 12. ADAMS No.

35 ML0831202.

October 2009 D-82 Draft NUREG-1437, Supplement 39
Appendix E

Chronology of Environmental Review Correspondence

October 2009 Draft NUREG-1437, Supplement 39

Appendix E

E. Chronology of Environmental Review Correspondence

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

2 Regulatory Commission (NRC) and external parties as part of its environmental review for

3 Prairie Island Nuclear Generating Plant, Units 1 and 2. All documents, with the exception of

4 those containing proprietary information are available electronically from the NRC's Public

5 Electronic Reading Room found on the Internet at the following Web address:

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

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

8 image files of NRC's public documents in ADAMS. The ADAMS accession number for each

9 document is included below.

10 EA1 Environmental Review Correspondence

January 29, 2008

February 23, 2008

March 21, 2008

April 11, 2008

April 14, 2008

April 28, 2008

May 1,2008

May 2, 2008

Letter from the Prairie Island Indian Community, regarding

potential application to renew the license for the Prairie

Island Nuclear Generating Plant, Units 1 and 2 (ADAMS

Accession No. ML080390402).

Letter to Ronald Johnson, Prairie Island Indian Community,

regarding anticipated license renewal review for Prairie

Island Nuclear Generating Plant, Units 1 and 2 (ADAMS

Accession No. ML080460246).

Letter to Ronald Johnson, Prairie Island Indian Community,

regarding request for cooperating agency status for the

Prairie Island Nuclear Generating Plant, Units 1 and 2,

license renewal environmental review (ADAMS Accession

No. ML080710522).

Letter from NMC forwarding the application for renewal of

operating license for Prairie Island Nuclear Generating

Plant, Units 1 and 2, requesting an extension of operating

license for an additional 20 years (ADAMS Accession No.

ML0811130666).

Letter from the Prairie Island Indian Community, "Re: Request

for Cooperating Agency Status" (ADAMS Accession No.

ML081080036).

Letter to NMC, "Receipt and Availability of the License Renewal

Application for the Prairie Island Nuclear Generating Plant,

Units 1 and 2" (ADAMS Accession No. ML081050091).

Letter from the Prairie Island Indian Community to Terry Virden,

Bureau of Indian Affairs, regarding Prairie Island Nuclear

Generating Plant, Units 1 and 2, license renewal review

(ADAMS Accession No. ML08114006650).

Letter to Ronald Johnson, Prairie Island Indian Community,

regarding request to participate as a cooperating agency

(ADAMS Accession No. ML081200867).

Draft NUREG-1437, Supplement 39 E-1 October 2009
Appendix E

May 6, 2008

May 13, 2008

May 15, 2008

May 19, 2008

June 10, 2008

June 14, 2008

June 14, 2008

June 17, 2008

June 17, 2008

Federal Register notice, "Nuclear Management Company, LLC;

Notice of Receipt and Availability of Application for Renewal

of Prairie Island Nuclear Generating Plant, Units 1 and 2,

Facility Operating License Nos. DPR-42 and DPR-60 for an

Additional 20-Year Period" (73 FR 25034).

NRC press release announcing the availability of the license

renewal application for Prairie Island Nuclear Generating

Plant, Units 1 and 2, for public inspection (ADAMS

Accession No. ML081340103).

Email from Heather Westra, Prairie Island Indian Community,

transmitting the markup of the draft Memorandum of

Understanding (ADAMS Accession Nos. ML081630551 and

ML081630555).

Letter to NMC forwarding the correction to notice of receipt and

availability of the license renewal application for the Prairie

Island Nuclear Generating Plant, Units 1 and 2" (ADAMS

Accession No. ML081330711).

Letter to NMC, "Determination of Acceptability and Sufficiency

for Docketing, Proposed Review Schedule, and Opportunity

for a Hearing Regarding the Application from Nuclear

Management Company, LLC, for Renewal of the Operating

Licenses for the Prairie Island Nuclear Generating Plant,

Units 1 and 2" (ADAMS Accession No. ML081370273).

Letter to Ronald Johnson, Prairie Island Indian Community,

transmitting the Memorandum of Understanding between

the U.S. Nuclear Regulatory Commission and the Prairie

Island Indian Community as a Cooperating Agency for the

Prairie Island Nuclear Generating Plant, Units 1 and 2,

license renewal environmental review (ADAMS Accession

No. ML081610245).

Memorandum of Understanding between the U.S. Nuclear

Regulatory Commission and the Prairie Island Indian

Community as a Cooperating Agency (ADAMS Accession

No. ML081610273).

Federal Register notice, "Nuclear Management Company, LLC,

Prairie Island Nuclear Generating Plant, Units 1 and 2,

Notice of Acceptance for Docketing of the Application and

Notice of Opportunity for Hearing Regarding Renewal of

Facility Operating License Nos. DPR-42 and DPR-60 for

and Additional 20-Year Period" (73 FR 34355).

Letter from Philip R. Mahowald, Prairie Island Indian

Community, transmitting the fully executed Memorandum of

Understanding between the U.S. Nuclear Regulatory

Commission and the Prairie Island Indian Community as a

Cooperating Agency (ADAMS Accession No.

ML081710160).

October 2009 E-2 Draft NUREG-1437, Supplement 39
Appendix E

June 26, 2008

June 26, 2008

July 10, 2008

July 15, 2008

July 17, 2008

July 21, 2008

July 22, 2008

July 22, 2008

July 22, 2008

July 22, 2008

Letter to NMC, "Notice of Intent to Prepare and Environmental

Impact Statement and Conduct Scoping Process for

License Renewal for the Prairie Island Nuclear Generating

Plant, Units 1 and 2" (ADAMS Accession No.

ML081620382).

NRC press release, "NRC and Prairie Island Indian Community

Sign First-of-a-Kind Memorandum of Understanding"

(ADAMS Accession No. ML081780445).

Letter to Don L. Klima, Advisory Council on Historic

Preservation, inviting participation in scoping process

related to NRC's environmental review of the license

renewal application for Prairie Island Nuclear Generating

Plant, Units 1 and 2 (ADAMS Accession No.

ML081850189).

Letter to NMC, "Notice of Intent to Prepare and Environmental

Impact Statement and Conduct Scoping Process for

License Renewal for the Prairie Island Nuclear Generating

Plant, Units 1 and 2" (ADAMS Accession No.

ML081970679).

Memoradum to Rani Franovich, NRC, "Forthcoming Meeting to

Discuss the License Renewal and Environmental Scoping

Process for the Prairie Island Nuclear Generating Station,

Units 1 and 2, License Renewal Application" (ADAMS

Accession No. ML081910743).

Letter to Philip R. Mahowald, Prairie Island Indian Community,

"Request for Scoping Comments Concerning the Prairie

Island Nuclear Generating Plant, Units 1 and 2, License

Renewal Application Review" (ADAMS Accession No.

ML081850414).

Federal Register notice, "Nuclear Management Company, LLC,

Prairie Island Nuclear Generating Plant, Units 1 and 2,

Notice of Intent to Prepare an Environmental Impact

Statement and Conduct Scoping Process" (73 FR 42628).

Letter to Terrance Virden, U.S. Bureau of Indian Affairs, inviting

participation in scoping process related to NRC's

environmental review of the license renewal application for

Prairie Island Nuclear Generating Plant, Units 1 and 2

(ADAMS Accession No. ML081930470).

Letter to Heather Westra, Prairie Island Indian Community,

inviting participation in scoping process related to NRC's

environmental review of the license renewal application for

Prairie Island Nuclear Generating Plant, Units 1 and 2

(ADAMS Accession No. ML081850178).

Letter to Lisa A. Joyal, Minnesota Department of Natural

Resources, "Request for List of State-Protected Species

and Important Habitats Within the Area Under Evaluation

Draft NUREG-1437, Supplement 39 E-3 October 2009
Appendix E

July 22, 2008

July 22, 2008

July 22, 2008

July 22, 2008

July 24, 2008

July 25, 2008

July 30, 2008

July 30, 2008

August 13, 2008

for the Prairie Island Nuclear Generating Plant, Units 1 and

2, License Renewal Application Review" (ADAMS

Accession No. ML081890395).

Letter to NMC, "Revision of Schedule for the Review of the

Prairie Island Nuclear Generating Plant, Units 1 and 2,

License Renewal Application" (ADAMS Accession No.

ML081980353).

Letter to Tony Sullins, U.S. Fish and Wildlife Service, "Request

for List of Federally Protected Species Within the Area

Under Evaluation for the Prairie Island Nuclear Generating

Plant, Units 1 and 2, License Renewal Review Application"

(ADAMS Accession No. ML081850485).

Letter to Emily Rusch, Wisconsin Department of Natural

Resources, "Request for List of State-Protected Species

Within the Area Under Evaluation for the Prairie Island

Nuclear Generating Plant, Units 1 and 2, License Renewal

Application Review" (ADAMS Accession No.

ML081930340).

Letter to Dennis A. Gimmestad, State Historic Preservation

Officer, Minnesota Historical Society, inviting participation in

scoping process related to NRC's environmental review of

the license renewal application for Prairie Island Nuclear

Generating Plant, Units 1 and 2 (ADAMS Accession No.

ML081840682).

Letter to Ronald Johnson, Prairie Island Indian Community,(a)

inviting participation in scoping process related to NRC's

environmental review of the license renewal application for

Prairie Island Nuclear Generating Plant, Units 1 and 2

(ADAMS Accession No. ML082070095).

NRC press release, "NRC Seeks Public Input on Environmental

Impact Statement for Prairie Island License Renewal

Review" (ADAMS Accession No. ML0820701 10).

Letter to NMC, "Environmental Site Audit Regarding Prairie

Island Nuclear Generating Plant, Units 1 and 2, License

Renewal Application" (ADAMS Accession No.

ML082040527).

Summary of telephone conference call held on July 2, 2008,

between the NRC and the Prairie Island Indian Community,

concerning the license renewal of Prairie Island Nuclear

Generating Plant, Units 1 and 2 (ADAMS Accession No.

ML082050652).

Letter from Tony Sullins, U.S. Fish and Wildlife Service,

regarding request for list of Federally protected species

within the area under evaluation for the Prairie Island

Nuclear Generating Plant, Units 1 and 2, license renewal

application review (ADAMS Accession No. ML082470303).

October 2009 E-4 Draft NUREG-1437, Supplement 39
Appendix E

August 18, 2008

August 26, 2008

September 8, 2008

September 8, 2008

September 26, 2008

September 29, 2008

October 23, 2008

October 23, 2008

October 23, 2008

Letter from Kevin Bearquiver, U.S. Bureau of Indian Affairs,

regarding invitation to participate in scoping process related

to NRC's environmental review of the license renewal

application for Prairie Island Nuclear Generating Plant,

Units 1 and 2 (ADAMS Accession No. ML0811470304).

Letter from Heidi Cyr, Minnesota Department of Natural

Resources, "Re: Request for Natural Heritage Information

in the Vicinity of the Prairie Island Nuclear Generating

Plant" (ADAMS Accession Nos. ML083290584 and

ML083290592).

Letter from Tom Lovejoy, Wisconsin Department of Natural

Resources, "Prairie Island Nuclear Generating Plant

License Renewal - EIS Scoping Issues" (ADAMS

Accession No. ML083080277).

Letter from Xcel Energy transmitting "Prairie Island Nuclear

Generating Plant License Renewal Environmental Report

Additional Information: Documents Requested During NRC

Environmental Review" (ADAMS Accession No.

ML083120219).

Letter from Xcel Energy, "Submittal of Documents for Public

Disclosure as Requested During NRC License Renewal

Environmental Audit" (ADAMS Accession No.

ML0831120218).

Letter from Xcel Energy, "Submittal of Archaeological

Documents Requested During NRC License Renewal

Environmental Audit" (ADAMS Accession No.

ML082880304).

Letter to Kevin Bearquiver, U.S. Bureau of Indian Affairs,

"Response to Letter from K. Bearquiver Regarding Prairie

Island Nuclear Generating Plant, Units 1 and 2, License

Renewal Application Review" (ADAMS Accession No.

ML082820382).

Letter to NMC, "Request for Additional Information for the

Review of the Prairie Island Nuclear Generating Plant,

Units 1 and 2, License Renewal Application (ADAMS

Accession No. ML0829505510).

Attachment to letter to NMC, "Request for Additional

Information for the Review of the Prairie Island Nuclear

Generating Plant, Units 1 and 2, License Renewal

Application" (ADAMS Accession No. ML082950604).

(a)Similar letters went to twenty eight other Native American Tribes listed in Section 1.8.

1

2

3

4

Draft NUREG-1437, Supplement 39 E-5 October 2009

1

2 APPENDIX F

3 U.S Nuclear Regulatory Commission Staff Evaluation of Severe

4 Accident Mitigation Alternatives (SAMAs) for Prairie Island Nuclear

5 Generating Plant, Units 1 and 2, in Support of License Renewal

6 Application Review

7

October 2009 Draft NUREG-1437, Supplement 39

Appendix F

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

2 Accident Mitigation Alternatives (SAMAs) for Prairie Island Nuclear

3 Generating Plant, Units 1 and 2, in Support of License Renewal

4 Application Review

5 F.1. Introduction

6 Northern States Power Company (NSP) submitted an assessment of severe accident mitigation

7 alternatives (SAMAs) for Prairie Island Nuclear Generating Plant, Units 1 and 2, (PINGP 1 and

8 2) as part of the Environmental Report (ER) (NMC 2008). This assessment was based on the

9 most recent PINGP 1 and 2 Probabilistic Risk Assessment (PRA) available at that time, a plant10 specific offsite consequence analysis performed using the MELCOR Accident Consequence

11 Code System 2 (MACCS2) computer code, and insights from the PINGP 1 and 2 Individual

12 Plant Examination (IPE) (NSP 1994) and Individual Plant Examination of External Events

13 (IPEEE) (NSP 1998). In identifying and evaluating potential SAMAs, NSP considered SAMAs

14 that addressed the major contributors to core damage frequency (CDF) and large early release

15 frequency (LERF) at PINGP 1 and 2, as well as SAMA candidates for other operating plants that

16 have submitted license renewal applications. NSP identified 25 potential SAMA candidates for

17 each unit. This list was reduced to nine unique SAMA candidates for each unit by eliminating

18 SAMAs that: are not applicable at PINGP 1 and 2 because of design differences, have already

19 been implemented, have no significant benefit or have benefits which have been achieved by

20 other means, or require extensive changes that would involve implementation costs known to

21 exceed any possible benefit. NSP assessed the costs and benefits associated with each of the

22 potential SAMAs and concluded that several of these would be potentially cost-beneficial.

23 Based on a review of the SAMA assessment, the U.S. Nuclear Regulatory Commission (NRC)

24 issued requests for additional information (RAI) to NSP by letters dated October 23, 2008 (NRC

25 2008a) and December 24, 2008 (NRC 2008b). Key questions concerned: unit-to-unit differences

26 and their treatment in the PRA model, PRA peer review and quality controls, treatment of

27 reactor coolant pump (RCP) seal LOCA and induced steam generator tube rupture (SGTR)

28 events in the PRA, justification for the multiplier used for external events, the identification and

29 screening of internal flood related enhancements, and further information on several specific

30 candidate SAMAs and potential lower-cost alternatives. NSP submitted additional information by

31 letters dated November 21, 2008 (NSP 2008), and January 23, 2009 (NSP 2009a). In the

32 responses, NSP provided: descriptions of unit-to-unit differences and how they were reflected in

33 the PRA, further information regarding the PRA peer review and self-assessments, additional

34 analyses of the impact of alternative RCP seal LOCA model and induced SGTR model

35 assumptions on SAMA results, additional information regarding external event SAMAs and

36 justification for the treatment of external events, additional information regarding internal flood

37 related enhancements and their screening, and additional information regarding several specific

38 SAMAs. NSP's responses addressed the NRC staff's concerns and resulted in the identification

39 of several additional potentially cost-beneficial SAMAs.

40 An assessment of SAMAs for PINGP 1 and 2 is presented below.

41 F.2. Estimate of Risk for PINGP 1 and 2

42 NSP's estimates of offsite risk at PINGP 1 and 2 are summarized in Section F.2.1. The

43 summary is followed by the NRC staff's review of NSP's risk estimates in Section F.2.2.

Draft NUREG-1437, Supplement 39 F-1 October 2009
Appendix F

1 F.2.1. NSP's Risk Estimates

2 Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA

3 analysis: (1) the PINGP 1 and 2 Level 1 and Level 2 PRA model, which is an updated version of

4 the IPE (NSP 1994), and (2) a supplemental analysis of offsite consequences and economic

5 impacts (essentially a Level 3 PRA model) developed specifically for the SAMA analysis. The

6 SAMA analysis is based on the most recent PINGP 1 and 2 Level 1 and Level 2 PRA model

7 available at the time of the ER, referred to as the Rev. 2.2 (SAMA) model. The scope of the

8 PINGP 1 and 2 PRA does not include external events.

9 The baseline CDF for the purpose of the SAMA evaluation is approximately 9.79 x 10-6 peryear

10 for Unit 1 and 1.21 x 105 per year for Unit 2. The CDF is based on the risk assessment for

11 internally initiated events including internal flooding. NSP did not include the contribution from

12 external events within the PINGP 1 and 2 risk estimates; however, it did account for the

13 potential risk reduction benefits associated with external events by doubling the estimated

14 benefits for internal events. This is discussed further in Sections F.2.2 and F.6.2.

15 The breakdown of CDF by initiating event is provided in Table F-i. As shown in this table,

16 events initiated by small LOCA, loss of cooling water and loss of offsite power are the dominant

17 contributors to internal event CDF for each unit. Although not separately reported, station

18 blackout sequences contribute about 9 percent and 8 percent for Unit 1 and 2, respectively, of

19 the total internal events CDF, while anticipated transient without scram (ATWS) sequences

20 contribute about 2 percent and 1 percent for Unit 1 and 2, respectively (NSP 2008). The

21 differences in the CDF contributions result largely from several differences between the two

22 PINGP 1 and 2 units. Section F.2.2 discusses these differences in greater detail.

23 Table F-I. PINGP Core Damage Frequency

Unit I Unit 2

Initiating Event CDF % CDF % Contribution

(per year) Contribu (per year) to CDF

tion

to CDF

Small LOCA 4.8 x 10-6 49 5.4 x 10-6 45

Loss of Cooling Water 1.8 x 10-6 18 1.8 x 10-6 15

Loss of Offsite Power 1.0 x 10-6 11 1.2 x 10-6 10

Loss of Main Feedwater 3.9 x 10-7 4 4.1 x 10-7 3

Medium LOCA 3.4 x 10-7 3 5.4 x 10-7 4

Loss of Component Cooling 2.9 x 10-7 3 2.9 x 10-7 2

Water

Large LOCA 2.8 x 10-7 3 3.1 x 10-7 3

Internal Flooding 2.4 x 10-7 2 2.4 x 10-7 2

Normal Transient 2.4 x 10-7 2 2.8 x 10-7 2

Steam Generator Tube Rupture 1.9 x 10-7 2 1.1 x 10-6 9

(STGR)

Loss of Train A DC 3.8 x 10-8 <1 4.0 x 10-7 3

Other 2.1 x 10-7 2 1.7 x 10-7 1

Total CDF (internal events) 9.79 x 10-6 100 1.21 x 10-5 100

24 The current PINGP 1 and 2 Level 2 PRA model is based on the IPE models with updates to

25 reflect changes to the plant and modeling techniques, including the steam generator

26 replacement for Unit 1. The Level 1 core damage sequences are assigned to core damage bins

27 (plant damage states) that provide the interface between the Level 1 and Level 2 analyses. The

28 Level 2 models use containment event trees (CETs) with functional nodes representing both

October 2009 F-2 Draft NUREG-1437, Supplement 39
Appendix F

1 systemic and phenomenological events. CET nodes are evaluated using supporting fault trees

2 and event trees.

3 The result of the Level 2 PRA is a set of 18 release categories with their respective frequency

4 and release characteristics. The frequency of each release category was obtained by summing

5 the frequency of the CET endstates assigned to each release category. Source terms were

6 developed for each of the release categories using the results of Modular Accident Analysis

7 Program (MAAP) 3.0B computer code calculations. The 18 release categories were collapsed

8 into 10 bounding release categories used for the SAMA analysis. The release categories and

9 their release characteristics are presented in Tables F.3-5 and F.3-6 of the ER.

10 The offsite consequences and economic impact analyses use the MACCS2 code to determine

11 the offsite risk impacts on the surrounding environment and public. Input for these analyses 12 includes plant-specific and site-specific values for core radionuclide inventory, source term and

13 release characteristics, site meteorological data, projected population distribution (within an 80-

14 km [50-mi] radius) for the year 2034, emergency response evacuation modeling, and economic

15 data. The magnitude of the onsite impacts (in terms of cleanup and decontamination costs and

16 occupational dose) is based on information provided in NUREG/BR-0184 (NRC 1997a).

17 NSP estimated the dose to the population within 50 mi of the PINGP 1 and 2 site to be

18 approximately 2.94 person-rem per year for Unit 1 and 8.37 person-rem per year for Unit 2. The

19 breakdown of the total population dose by containment release mode is summarized in Table F20 2. This table reflects minor corrections to several entries provided by NSP in response to an RAI

21 (NSP 2008). Releases due to steam generator tube rupture (SGTR) events, interfacing system

22 loss-of-coolant accidents (ISLOCAs), and late containment failures dominate the population

23 dose risk at PINGP 1 and 2.

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

Unit I Unit 2

Population Percent Population Percent

Containment Release Modes Dose Contribu Dose Contribu

(person- tion (person- tion

rem(a) rem(a)

per per

year) year)

Intact Normal 0.01 0.4 0.01 0.2

Containment Leakage

Early Over-pressure 0.12 4.1 0.14 1.7

Containment Failure

Failure Isolation <0.01 0.1 <0.01 <0.1

Failure

Late Basemat 0.63 21.4 0.76 9.0

Containment Failure

Failure Over-pressure 0.12 4.1 0.12 1.4

Failure

Containment SGTR 1.32 44.9 6.66 79.0

Bypass ISLOCA 0.74 25.0 0.74 8.7

Total 2.94 100 8.43 100

25 F.2.2. NRC Staff's Review of NSP's Risk Estimates

26 NSP's determination of offsite risk at PINGP 1 and 2 is based on the following three major

27 elements of analysis:

Draft NUREG-1437, Supplement 39 F-3 October 2009
Appendix F

1 0 the Level 1 and 2 risk models that form the basis for the 1994 IPE submittal

2 (NSP 1994) and the external events analyses of the 1998 IPEEE submittal

3 (NSP 1998),

4 0 the major modifications to the IPE model that have been incorporated into the

5 PINGP 1 and 2 PRA, and

6 0 the MACCS2 analyses performed to translate fission product source terms

7 and release frequencies from the Level 2 PRA model into offsite

8 consequence measures.

9 Each of these analyses was reviewed to determine the acceptability of NSP's risk estimates for

10 the SAMA analysis, as summarized below.

11 The NRC staffs review of the PINGP 1 and 2 IPE is described in an NRC report dated May 16,

12 1997 (NRC 1997b). On the basis of a review of the IPE submittal, the staff concluded that the

13 IPE submittal met the intent of Generic Letter (GL) 88-20; that is, the IPE was of adequate

14 quality to be used to look for design or operational vulnerabilities. Although no vulnerabilities

15 were identified in the IPE, several plant improvements were identified. These improvements

16 have either been implemented at the site or addressed by a SAMA in the current evaluation.

17 These improvements are discussed in Section F.3.2.

18 There have been over five revisions to the Level 1 model since the 1994 IPE submittal. A

19 comparison of the internal events CDF between the IPE and the Rev. 2.2 (SAMA) PRA model

20 indicates a decrease of approximately 80 percent for both units (from 5.0 x 10-5 per year to 9.79

21 x 10-6 per year for Unit 1 and from 5.1 x 10-5 per year to 1.21 x 10- per year for Unit 2). A

22 comparison of the contributors to the total CDF indicates that the frequency of each major

23 contributor (e.g., LOCAs, loss of offsite power (LOOP), internal flooding) has decreased by

24 factors of 2 to 10 since the IPE. A description of those changes that resulted in the greatest

25 impact on the internal events CDF is provided in Section F.2.1 of the ER (NMC 2008) and in

26 response to an RAI (NSP 2008a), and is summarized in Table F-3.

27 Table F-3. PINGP 1 and 2 PRA Historical Summary

PRA Version Summary of Changes from Prior Model Unit I CDF Unit 2 CDF

(per (per

year) year)

1994 (Rev. 0) IPE submittal 5.0 x 10-5 5.1 x 10-5

Rev. 1.0 1996 Update 2.4 x 10-5 NA

" Added selected balance-of-plant systems

" Updated the plant safeguards electrical

systems

" Updated component failure and

unavailability data for six key systems .Reanalyzed LOCA frequencies

Rev. 1.1 1999 Update 2.4 x 10-5 NA

* Changed PRA quantification to a single

top fault tree approach

Rev. 1.2 2001 Update 2.2 x 10-5 NA

" Resolved selected Westinghouse Owners

Group PRA Certification Team Review

comments

" Updated component failure rates

Rev. 2.0 2002 Update 2.2 x 10-5 2.5 x 10-5

* Developed a Unit 2 PRA model from Unit

October 2009 F-4 Draft NUREG-1437, Supplement 39
Appendix F

PRA Version

Rev. 2.1

Rev. 2.2

Rev. 2.2

(SAMA)

Summary of Changes from Prior Model

1

* Removed boric acid storage tank input to

the safety injection pumps suction logic

" Enhanced existing quantification

methodology

" Modified charging pump system fault tree

logic to include an operator action to restart

the pumps after a LOOP event

* Modified RHR to include the same

common cause failure event in the injection,

recirculation and shutdown cooling modes

* Added operator action to prevent load

sequencer failure

" Updated logic modeling for the

supply/exhaust fans

2005 Update

* Updated LOOP initiating frequency

* Updated various system fault trees

* Upgraded the human reliability analysis

(HRA)

* Correctedthe process used to model preinitiator latent errors

" Added modeling of 120 V AC panel faults

* Updated failure and common cause data

for EDG and AFW systems

" Updated internal flooding analysis

2006 Update

* Closed all remaining Level B WOG Peer

Certification Review findings

* Updated initiating event frequency to

reflect the installation of new steam

generators (for Unit 1 only)

2006 Update

" Corrected.Units 1 and 2 Level 1 core

damage sequence success logic for the

small LOCA event

Unit I CDF

(per

year)

Unit 2 CDF

(per

year)

1.5 x10-5 1.6 x10-5

9.8 x 10-6 1.1 x 10-5

9.8 x10-6 1.2 x10-5

1

2

3

4

5

6

7

8

9

10

11

12

13

The IPE CDF value for PINGP 1 and 2 was the lowest CDF value reported in the IPE for

Westinghouse two-loop plants. Figure 11.6 of NUREG-1560 shows that the IPE-based total

internal events CDF for Westinghouse two-loop plants ranges from 5 x 105to 1.2 x 10-4 per

reactor-year (NRC 1997c). It is recognized that other plants have updated the values for CDF

subsequent to the IPE submittals because of modeling and hardware changes. The internal

events CDF based on the latest PRA (9.79 x 1 0- per year and 1.21 x 10-5 per year for Units 1

and 2, respectively) remains lower than the latest CDF values reported in the license renewal

applications for other two-loop Westinghouse plants, which are in the range of 3 x 10-5 to 4 x 10-

5 per year. The NRC staff concludes that although lower than for the other two-loop plants, the

current internal events CDF results for PINGP 1 and 2 are still reasonably consistent with that

for plants of similar vintage and characteristics.

The ER identifies several design differences between Unit 1 and Unit 2. The NRC staff

requested additional information on how the differences between the units impacted core

Draft NUREG-1437, Supplement 39 F-5 October 2009
Appendix F

1 damage frequency and release frequencies. In its response, NSP identified the following unit

2 differences and their estimated impacts (NSP 2008):

3 As the result of a motor-driven Auxiliary Feedwater (MDAFW) pump control

4 power asymmetry, the Loss of Train A DC initiating event contributes more

5 significantly to the Unit 2 CDF (4.0 x 10-7 per year) than it does to the Unit 1

6 CDF (3.8 x 10.8 per year) because the loss of this bus results in the loss of

7 main feedwater and the loss of breaker control power for the Unit 2 MDAFW

8 pump. The Unit 1 pump is not impacted. The control power asymmetry also

9 contributes to a higher potential for induced SGTR on Unit 2 due to the

10 inability of one AFW pump to automatically start on loss of Train A DC power

11 increasing the potential for the event to degrade into a core damage event at

12 high pressure due to loss of heat sink.

13 . The Unit 1 emergency diesel generators (EDGs) are the original EDGs that

14 provided backup power to both units, while the Unit 2 EDGs were added in

15 response to the Station Blackout (SBO) Rule and differ in manufacturer,

16 design, capacity, and in the external systems required to support their

17 operation. Due to the independent design of the EDGs between units

18 combined with the ability to cross-tie the 4kV buses across units, the

19 contribution to the CDF from a loss of all AC power is less than 10 percent for

20 both units.

21 ° A Unit 1 steam generator replacement project was completed in 2004, while

22 the replacement of the Unit 2 steam generators has not yet been completed.

23 Therefore, there is a lower potential for an SGTR-initiated core damage event

24 at Unit 1. The licensee notes that the Level 2 PRA analysis does not credit a

25 possibly lower potential for pressure- and temperature-induced SGTR events

26 on Unit 1.

27 The NRC staff considered the peer review performed for the PINGP 1 and 2 PRA, and the

28 potential impact of the review findings on the SAMA evaluation. In the ER (NMC 2008) and in

29 response to NRC staff RAIs (NSP 2008 and 2009), NSP described the peer review by the

30 (former) Westinghouse Owners Group (WOG) of the 1994 PRA model (i.e., the IPE) conducted

31 in September 2000. NSP states that the WOG review concluded that the PINGP 1 and 2 PRA

32 can be effectively used to support applications involving relative risk significance. NSP further

33 states that all Level A (important and necessary to address before the next regular PRA update)

34 and Level B (important and necessary to address, but disposition may be deferred until the next

35 PRA update) facts and observations (F&Os) from the peer review have been resolved.

36 In response to an RAI (NSP 2008), NSP noted that one of the F&Os involved the PRA

37 maintenance and update process, and had been subsequently resolved. In a follow-up

38 response (NSP 2009a), NSP described two procedures that were developed to address this

39 F&O. One procedure addresses the maintenance and update process to ensure that the PRA

40 represents the as-built, as-operated plant such that it is sufficient to support applications for

41 which the PRA is being used. The other provides instructions on how to structure the

42 quantification of the PRA model following a periodic or maintenance update of the PRA model,

43 and prescribes reviews that should be performed (e.g., of cutsets, recovery actions, mutually

44 exclusive events, circular logic, asymmetries, initiating event distributions, and important

45 operator actions). NSP states that the PRA model quantification procedure/guideline was

46 created to meet the model quantification element in the ASME PRA standard.

47 In addition to the WOG Peer Certification review, NSP stated that the PINGP 1 and 2 PRA

48 model has been reviewed three times as part of the self-assessment process (NSP 2009a).

October 2009 F-6 Draft NUREG-1437, Supplement 39
Appendix F

1 These three reviews were: (1) the PRA Program Snapshot Evaluation, in April 2007, that

2 benchmarked the PINGP 1 and 2 PRA against Regulatory Guide 1.200, Revision 1, "An

3 Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for

4 Risk-Informed Activities," (2) the PRA Program Focused Self-Assessment, in May 2004, that

5 assessed the PRA Program against the NMC Fleet PRA Standard and industry best practices,

6 and (3) the Nuclear Oversight Observation Report, in June 2003, that reviewed the PINGP 1

7 and 2 PRA Risk Assessment Program against NUMARC 93-01, "Industry Guideline for

8 Monitoring the Effectiveness of Maintenance Activities at Nuclear Power Plants."

9 The NRC staff noted that the PINGP 1 and 2 PRA uses a Westinghouse reactor coolant pump

10 seal loss-of-coolant accident (LOCA) model that pre-dates the WOG 2000 model approved by

11 the NRC in 2003 for plants using high-temperature O-rings. In addition, the WOG Peer Review,

12 discussed above, occurred prior to the approval of the WOG 2000 model, and as such would

13 not have identified the use of an older model as an issue. In response to an RAI (NSP 2009a),

14 NSP stated that all four of the Prairie Island's installed RCPs have been updated with high

15 temperature O-rings, that high temperature O-rings and hard seal parts manufactured by Areva

16 have been evaluated and accepted as interchangeable with the same parts manufactured by

17 Westinghouse, and that Westinghouse and Areva O-rings and hard seal parts are installed in

18 various combinations in all four RCPs. NSP states that although the Areva O-rings have been

19 qualified for the same high temperature service as the Westinghouse O-rings, there may be a

20 difference in the beyond design basis failure pressure characteristics. As this difference has not

21 been resolved, NSP performed a sensitivity analysis using the Rhodes model (as presented in

22 WCAP-16141) with a bounding 480-gpm per pump leakage rate. In conjunction with this

23 sensitivity analysis, NSP integrated the impact of migrating from MAAP 3.0B (on which the

24 current model is based) to MAAP 4.0.6. NSP stated that this change was made because MAAP

25 3.0B is known to be significantly conservative with respect to the timing of core uncovery and

26 core damage following initiation of RCP seal LOCA events. The results of this sensitivity

27 analysis showed an estimated 22 percent (1.9 x 10- per year) increase in CDF for SBO events.

28 However, NSP argued that when sufficient plant-specific MAAP analysis case runs are available

29 to allow modeling of the lower leakage rates specified in the Rhodes model, it is anticipated that

30 the contribution to overall CDF will actually be lower than currently calculated. In consideration

31 of the above factors, the NRC staff concludes that NSP's use of its current RCP model is

32 reasonable for the purposes of the SAMA evaluation.

33 In response to an NRC inquiry into the bases for not implementing two IPE-identified internal

34 flooding enhancements, NSP identified a potential model limitation associated with the use of

35 deterministic arguments to address an estimate of the probabilistic pipe break frequency

36 associated with a Cooling Water System flood in the Auxiliary Feedwater Pump/Instrument Air

37 Compressor Room. In response to this issue, NSP has entered into their Corrective Action

38 Program the re-evaluation of selected flooding enhancements to be performed after the PRA

39 limitation has been corrected (NSP 2009b). This issue is fully discussed in Section F.3.2. As

40 NSP's actions directly address the identified model limitation by including the previously

41 screened improvements in their Corrective Action Program for future evaluation, the NRC staff

42 finds that NSP actions adequately address the impact of this model limitation on the SAMA

43 evaluation.

44 Given that the PINGP 1 and 2 Level 1 internal events PRA model has been both peer reviewed

45 and subjected to an extensive self-assessment process and the review findings have been

46 resolved or judged to have no adverse impact on the SAMA evaluation, and that NSP has

47 satisfactorily addressed NRC staff questions regarding the PRA, the NRC staff concludes that

48 the Level 1 PRA model is of sufficient quality to support the SAMA evaluation.

Draft NUREG-1437, Supplement 39 F-7 October 2009
Appendix F

1 As indicated above, the current PINGP 1 and 2 PRA models do not include external events. In

2 the absence of such an analysis, NSP used the PINGP 1 and 2 IPEEE in conjunction with minor

3 adjustments in fire and seismic scenarios to identify the highest risk accident sequences and the

4 potential means of reducing the risk posed by those sequences, as discussed below.

5 The PINGP 1 and 2 IPEEE was submitted in December 1996, in response to Supplement 4 of

6 GL 88-20 (NSP 1996). NSP did not identify any vulnerabilities to severe accident risk in regard

7 to the external events related to seismic, fire, or other external events. This submittal included a

8 seismic margins analysis, a fire-induced vulnerability evaluation, and a screening analysis for

9 other external events. In a letter dated February 8, 2001, the NRC staff concluded that the

10 submittal met the intent of Supplement 4 to GL 88-20, and that the licensee's IPEEE process is

11 capable of identifying the most likely severe accidents and severe accident vulnerabilities (NRC

12 2001b).

13 The PINGP 1 and 2 IPEEE details how NSP had originally planned to respond to GL 88-20,

14 Supplement 4, by performing a seismic PRA for Prairie Island, but changed the approach of

15 completing the seismic IPEEE from a seismic PRA to a Seismic Margins Assessment (SMA).

16 This change was based on information incorporated in Supplement 5 of GL 88-20, regarding

17 large reductions in the seismic hazard estimates for sites in the eastern United States. The

18 seismic margin assessment follows the NRC guidance (NRC 1991) and Electric Power

19 Research Institute (EPRI) guidance (EPRI 1991) and was completed in conjunction with the

20 Seismic Qualification User Group (SQUG) program (SQUG 1992). This method is qualitative

21 and does not provide the means to determine the numerical estimates of the CDF from.seismic

22 initiators. The conclusions of the PINGP 1 and 2 IPEEE seismic margin analysis found that all

23 components included in the SAMA have high confidence low probability of failure (HCLPFs)

24 greater than or equal to 0.3 g with the exception of the component cooling water heat

25 exchangers. As the component cooling water heat exchangers have HCLPFs of 0.28g, the

26 PINGP 1 and 2 IPEEE states that they are considered to be adequate. The IPEEE findings also

27 included one recommendation to restrain or remove wall hung ladders and scaffolding located

28 near safety related equipment and 22 outliers designated for resolution under the A-46 program

29 where each outlier represents one or more like components (NSP 1996, NSP 2000 and NRC

30 2001a). All A-46 outliers were either resolved or scheduled for resolution by the May 1999 Unit

31 1 outage (NRC 1998b).

32 In response to a NRC staff request for information regarding the seismic contribution to risk,

33 NSP stated that a bounding estimate of seismic risk was developed in support of another NRC

34 submittal using a methodology known as the "Simplified Hybrid Method" (Kennedy 1999). Using

35 this method NSP provided a seismic core damage frequency estimate of 7.8 x 106 per year

36 (NSP 2008). An independent estimate of 2.5 x 106 per year was developed by NRC staff based

37 on the simplified seismic methodology and 2008 updated U. S. Geological Survey (USGS)

38 seismic hazard information (USGS 2008), which confirms the bounding nature of NSP's

39 estimate.

40 The PINGP 1 and 2 IPEEE fire analysis employed a combination of classical PRA techniques

41 with EPRI's Fire Induced Vulnerability Evaluation (FIVE) methodology. The FIVE methodology

42 was used to establish fire boundaries and to evaluate the probability and the timing of damage

43 to components located in a compartment involved in a fire. Each fire area that remained after an

44 initial qualitative screening was evaluated for fire detection and suppression, and fire growth and

45 propagation. Fire scenarios that were found to have the potential to spread beyond the initiating

46 compartment were examined and addressed. All remaining fire areas were assessed using a

47 bounding estimate ("all-engulfing fire") against a screening criterion of 1 x 106 per year. The

48 remaining fire areas were subjected to a more detailed fire analysis. The CDF for each of these

49 areas was obtained by accounting for the frequency of a fire in a given fire area, conditional

October 2009 F-8 Draft NUREG-1437, Supplement 39
Appendix F

1 core damage probability associated with that fire scenario in the fire area including, and where

2 appropriate, the impact of fire suppression. The potential impact on containment performance

3 and isolation was evaluated following the core damage evaluation. The total fire CDF from the

4 IPEEE was estimated to be less than 5 x 10-5 per year (NSP 1998). The dominant fire scenarios

5 and their contributions to the fire CDF are listed in Table F-4.

6 Table F-4. Significant Fire Areas for PINGP 1 and 2

Fire Area Description CDF (per year)

FA 13 Control Room 3.22 x 10-5

FA 32 Train "B" Hot Shutdown Panel and Air Compressor/AFW 8.23 x 10-6

Room

FA 80 480V Safeguards Switchgear Room-Bus 111 2.24 x 10-6

FA 20 4160V Safeguards Switchgear Room-Bus 16 1.74 x 10-6

FA 59 Aux Building Mezzanine 1.45 x 10-6

FA 73 Aux Building Ground Floor 1.28 x 10-6

FA 18 Relay & Cable Spreading Room 1.08 x 10-6

FA 69 Turbine Building Ground and Mezzanine Floor 1.08 x 10-6

7 The NRC staff notes that the fire results are based on the Unit 1 fire analysis. An evaluation of

8 the applicability of the Unit 1 results to Unit 2 is included in the PINPG IPEEE (NSP 1998). This

9 evaluation notes that there are potentially significant asymmetries between the units including:

10 • The Unit 2 4160 V safeguard bus rooms have been identified in the Appendix

11 R Shutdown Analysis as being of concern for loss of offsite power to Unit 2.

12 This is not expected for the corresponding Unit 1 rooms.

13 0 The emergency buses (Buses 25 and 26) for Unit 2 are located in fire areas

14 that are not separated by Appendix R-credited fire barriers from the diesel

15 generators. This separation exists for Unit 1.

16 0 Cooling Water pump power supply asymmetries result in: a greater impact of

17 a fire on Pump 121 for Unit 2 than Unit 1, greater electrical separation

18 between diesel and motor-driven pumps for Unit 2, and a lesser impact of

19 Unit 2 switchgear fires on Pumps 11 and 21.

20 The IPEEE states that the asymmetries associated with Unit 2's increased potential for loss of

21 offsite power has the impact of raising the Unit 2 fire risk, while the independence of the

22 operation of the two diesel cooling water pumps from Unit 2 AC power tends to offset this risk

23 increase. Based on this, the NRC staff concludes that the use of the Unit 1 fire risk results to

24 support the SAMA analysis for both units is reasonable.

25 In the ER (NMC 2008), the licensee noted that a number of conservative assumptions were

26 used in the fire analysis. Further, in response to staff RAIs, NSP stated that the IPEEE Fire

27 analysis was performed in order to meet GL 88-20 requirements (identify vulnerabilities to

28 severe accidents initiated by internal fires), that the analysis was not intended to determine the

Draft NUREG-1437, Supplement 39 F-9 October 2009
Appendix F

1 internal fires CDF to a high degree of accuracy, and that it is not appropriate to compare a

2 conservative CDF estimate for fire hazards to the present-day internal events CDF (NSP 2008).

3 The conservatisms identified by NSP include:

4 . All fires were assumed to result in shutdown of both units therefore limiting

5 the ability to credit system cross-ties.

6 0 Credit for automatic and manual suppression was limited to cutsets

7 representing less than 13 percent of the internal fires CDF.

8 ° No credit was given to the ability of fire brigade to extinguish local fires before

9 shutdown of the plant.

10 0 Credit for manual suppression was only applied to the Control Room, Relay

11 Room, and certain AFW pump room fires. Credit for automatic fire

12 suppression was only applied in the AFW pumps rooms.

13 0 No credit was given to the availability of the RCS pressure operated relief

14 valve (PORV) passive air accumulators. Any fire that impacted the instrument

15 air system was assumed to result in the loss of the ability to perform RCS

16 bleed and feed.

17 ° Detailed fire modeling was not performed in a number of fire areas that did

18 not screen out.

19 In response to a follow-up request to better clarify the identified conservatisms, NSP provided

20 additional rationale as to why the fire CDF would be lower. This included quantitative estimates

21 of the extent to which the fire results would be reduced through the use of updated fire ignition

22 frequencies and conditional core damage probabilities, and additional credit for automatic and

23 manual fire suppression. NSP indicated that based on the more recent methodology of

24 NUREG/CR-6850, the fire ignition frequencies for the Control Room and the AFW/Instrument

25 Air Compressor Room would be approximately 40 percent lower than calculated in the IPEEE.

26 They also noted that relative to the Level 1 Revision 1 internal events model used for the fire

27 IPEEE analysis, the conditional core damage probability (CCDP) based-on the updated internal

28 events PRA model (Rev 2.2 SAMA) has been reduced by 46 percent for normal (or general)

29 plant transient initiated events (NSP 2008), 32 percent for loss of main and auxiliary feedwater

30 initiated events, and 81 percent for loss of offsite power initiated events. With respect to the

31 credit for fire suppression, NSP stated that within the control room, manual suppression was

32 only credited in fires that were large enough to propagate beyond the boundaries of the initiating

33 Control Room panel zone, and that this credit for successful fire suppression was limited to

34 cutsets representing less than 13 percent of the internal fires CDF (NSP 2009a). Based on the

35 quantitative information provided by NSP, the NRC staff estimates that use of the updated fire

36 ignition frequencies and conditional core damage probabilities, and additional credit for fire

37 suppression would result in about a factor of 3 reduction in the fire CDF.

38 The NRC staff finds that NSP provided reasonable justification that that the ignition frequency

39 for risk significant fire areas would be less than previously analyzed and that the CCDP for fire

40 sequences is also lower. NRC staff also agrees that the assumption that any fire initiated in a

41 Control Room panel zone (regardless of intensity, location or other factors) damages all

42 equipment within the zone appears conservative for the purposes of the SAMA evaluation and

43 that only limited credit was given to fire suppression. The NRC staff concludes that when all the

44 qualitative and quantitative factors are taken into consideration, a realistic estimate of the

45 PINGP 1 and 2 fire CDF would likely be in the range of 1 x 10.' per year.

October 2009 F-10 Draft NUREG-1437, Supplement 39
Appendix F

1 The IPEEE analysis of other external events (NSP 1998) followed the screening specified in

2 Supplement 4 to GL 88-20 (NRC 1991) and did not identify any unduly significant sequences or

3 vulnerabilities. The plant design was reviewed to determine if it met 1975 Standard Review Plan

4 design criteria for high winds, floods, and other external events. If it met these criteria and a

5 walkdown did not identify any unique vulnerabilities, then the CDF from the external hazard was

6 considered to be less than 1 x 10-6 per year. If it did not meet the criteria, then additional

7 analysis was performed to evaluate the specific concern. Since the plant design for high wind

8 effects did not conform fully to the criteria specified in the 1975 SRP, high winds and tornadoes

9 could not be screened out. Further analysis summarized in the IPEEE SER (NRC 2001b)

10 indicated that the CDF due to high winds and tornadoes is less than 1 x 10' per year.

11 In the ER, NSP estimated that the external events CDF is comparable to the internal events

12 CDF. Accordingly, the total CDF from internal and external events would be approximately 2

13 times the internal events. In the SAMA analysis, NSP doubled the benefit that was derived from

14 the internal events model to account for the combined contribution from internal and external

15 events (NMC 2008). In response to an RAI requesting justification for increasing the benefits by

16 only a factor of 2, NSP provided additional information regarding the estimated CDF for seismic

17 events and the conservatisms in the CDF, as described above. In consideration of this

18 additional information, the NRC staff concurs that the external event CDF is comparable to that

19 for internal events at PINGP 1 and 2 (based on a seismic CDF of 2.5 x 106 per year, a fire CDF

20 of 1 x 10.5 per year, and a CDF of 1 x 10.6 per year for other external events), and concludes

21 that the licensee's use of a multiplier of 2 to account for external events is reasonable for the

22 purposes of the SAMA evaluation.

23 The NRC staff reviewed both the general process used by NSP to translate the results of the

24 Level 1 PRA into containment releases and the results of the Level 2 analysis, as described in

25 the ER and in response to the NRC staff RAIs (NSP 2008 and 2009). The current PINGP 1 and

26 2 Level 2 PRA model is based on the IPE models with updates to reflect changes to the plant

27 and modeling techniques, including the steam generator replacement for Unit 1. The Level 1

28 core damage sequences are assigned to core damage bins (plant damage states) that provide

29 the interface between the Level 1 and Level 2 analyses. The Level 2 models use CETs with

30 functional nodes representing both systemic and phenomenological events. CET nodes are

31 evaluated using supporting fault trees and event trees. The result of the Level 2 PRA is a set of

32 18 release categories with their respective frequency and release characteristics. The frequency

33 of each release category was obtained by summing the frequency of the CET endstates

34 assigned to each release category. Source terms were developed for each of the release

35 categories using the results of MAAP 3.0B computer code calculations. The 18 release

36 categories were collapsed into 10 bounding release categories used for the SAMA analysis. The

37 release categories and their release characteristics are presented in Tables F.3-5 and F.3-6 of

38 the ER.

39 The NRC staff's review of the Level 2 IPE for PINGP 1 and 2 concluded that it addressed the

40 most important severe accident phenomena normally associated with a large, freestanding steel

41 shell containment, and identified no significant problems or errors (NRC1997b). The Level 2

42 PRA model was included in the PINGP 1 and 2 peer review mentioned previously. NSP states

43 that all Level A and B F&Os have been resolved. As noted above, additional reviews have been

44 performed since the completion of the WOG peer review. It also should be noted, however, that

45 the current Level 2 model is a revision to the version that was peer reviewed. The changes to

46 the Level 2 model are described in Section F.2.1.3 of the ER and in response to an RAI (NMC

47 2008, NSP 2008). The PINGP 1 and 2 Level 2 PRA is based on Revision 2.2 which was

48 developed in 2006, and incorporates several changes that were implemented subsequent to the

49 peer review. These changes to the model include: the elimination of induced SGTR events in

Draft NUREG-1437, Supplement 39 F-1 1 October 2009
Appendix F

1 Revision 1 of the Level 2 PRA model, but re-introduction of these events in the Revision 2.2

2 model update used for the SAMA analysis; changes to the human error probability for failure to

3 cool down and depressurize the RCS following a SGTR; and the addition of a containment

4 isolation fault tree for each unscreened containment penetration to model the failure of

5 containment isolation.

6 During the review of the Level 2 analysis, the NRC staff could not determine the modeling

7 approach used to assess the likelihood of a thermally-induced SGTR following core damage in

8 the current PRA. In response to an RAI, NSP stated that the treatment of induced SGTR events

9 follows the guidance of WCAP-16341-P, "Simplified Level 2 Modeling Guidelines." WCAP10 16341-P was developed by the WOG with the intent that Level 2 models developed using its

11 methodology would meet requirements of the ASME PRA standard (ASME 2002). Additional

12 discussion on NSP modeling of induced SGTR is provided in Section F.6.2 including the results

13 of a sensitivity analysis in which the conditional probability of an induced SGTR was increased.

14 Based on the NRC staffs review of the Level 2 methodology, the fact that the Level 2 model

15 was reviewed in more detail as part of the WOG peer review and updated to address peer

16 review findings, the staff's review of the subsequent Level 2 model changes, and NSP's

17 responses to the RAIs, the NRC staff concludes that the PINGP 1 and 2 Level 2 PRA provides

18 an acceptable basis for evaluating the benefits associated with various SAMAs.

19 As indicated in the ER, the reactor core radionuclide inventory used in the consequence

20 analysis is based on a plant-specific calculation and corresponds to end-of-cycle values (core

21 average exposure of 50,000 MWD/MTU). All releases were modeled as occurring at the top of

22 the Containment Building. The thermal content of each of the releases is assumed to be 107

23 watts based on values provided in Sample Problem A in the MACCS2 user's manual (NRC

24 1998a) and NUREG/CR-4551 (NRC 1990). NSP assessed the impact of alternatively assuming

25 either a ground level release or an ambient (non-buoyant) plume. The results of these sensitivity

26 cases showed that reducing the release height to ground level results in about a 2 percent

27 increase in the 50-mile population dose risk and a 6 percent decrease in offsite economic cost

28 risk, and reducing the thermal plume heat content to ambient conditions results in a negligible

29 change in population dose risk and a 6 percent decrease in offsite economic cost risk.

30 The NRC staff reviewed the process used by NSP to extend the containment performance

31 (Level 2) portion of the PRA to an assessment of offsite consequences (essentially a Level 3

32 PRA). This included consideration of the source terms used to characterize fission product

33 releases for the applicable containment release categories and the major input assumptions

34 used in the offsite consequence analyses. The MACCS2 code was utilized to estimate offsite

35 consequences. Plant-specific inputs to the code includes the source terms for each release

36 category and the reactor core radionuclide inventory (both discussed above), site-specific

37 meteorological data, projected population distribution within a 50-mi radius for the year 2034,

38 emergency evacuation modeling, and economic data. This information is described in Section

39 F.3 of the ER (NMC 2008).

40 NSP used site-specific meteorological data for the 2003 calendar year as input to the MACCS2

41 code. The data were collected from the onsite meteorological tower. Data from 2004 and 2005

42 were also considered, but the 2003 data were chosen because they were the most complete

43 and because results of a MACCS2 sensitivity analyses indicated that the 2003 data produced

44 more conservative results than the data sets for the other years. Small data voids (five gaps of

45 less than six consecutive hours) were filled using interpolation between data points. Larger data

46 voids (three gaps of six or more consecutive hours) were filled using data from the same time of

47 day from the day just before or after the missing data. The NRC staff notes that previous SAMA

October 2009 F-12 Draft NUREG-1437, Supplement 39
Appendix F

1 analyses results have shown little sensitivity to year-to-year differences in meteorological data

2 and concludes that the use of the 2003 meteorological data in the SAMA analysis is reasonable.

3 The population distribution the licensee used as input to the MACCS2 analysis was estimated

4 for the year 2034, based on the U.S. Census Bureau population data for 2000, as provided by

5 the SECPOP2000 program (NRC 2003), and the expected annual population growth rate. The

6 baseline population was determined for each of sixteen directions and each of ten concentric

7 rings (total of 160 sectors) out to a radius of 50 miles (80 km) surrounding the site. U.S Census

8 block-group level population data was allocated to each sector based on the area fraction of the

9 census block-groups in that sector. The 1990 and 2000 census data from SECPOP2000 were

10 used to estimate an annual average population growth rate for each of the 50-mile (80 km)

11 radius rings. The annual growth rate estimate for each ring was applied uniformly to all sectors

12 in the ring to calculate the year 2034 population distribution. Population sensitivity cases were

13 performed in which the baseline 2034 population was increased by 30 percent, and then

14 decreased to the year 2000 population data rather than the projected year 2034 population. The

15 resulting population dose and offsite economic cost risk increased by approximately 30 percent

16 and decreased by approximately 40 percent, respectively. The NRC staff considers the methods

17 and assumptions for estimating population reasonable and acceptable for purposes of the

18 SAMA evaluation.

19 The emergency evacuation model was modeled as a single evacuation zone extending out 10

20 miles (16 km) from the plant. NSP assumed that 95 percent of the population would evacuate.

21 This assumption is conservative relative to the NUREG-1 150 study (NRC 1990), which

22 assumed evacuation of 99.5 percent of the population within the emergency planning zone. The

23 evacuees were assumed to begin evacuating 90 minutes after a General Emergency has been

24 declared and to evacuate at an average radial speed of 3.35 miles per hour (1.5 meters per

25 second). This speed is the time weighted value accounting for season, day of the week, time of

26 day, weather conditions, and special events. A sensitivity analysis was performed in which the

27 evacuation speed was decreased by a factor of two (to 0.75 meters per second). The result was

28 a 2 percent increase in the total population dose. The NRC staff concludes that the evacuation

29 assumptions and analysis are reasonable and acceptable for the purposes of the SAMA

30 evaluation.

31 Much of the site-specific economic data were provided from SECPOP2000 (NRC 2003) by

32 specifying the data for each of the counties surrounding the plant to a distance of 50 miles.

33 SECPOP2000 utilizes economic data from the 1997 Census of Agriculture (USDA 1998) and

34 from other 1998 and 1999 data sources. Generic economic data that applies to the region as a

35 whole was taken from the MACCS2 sample problem input and revised when better information

36 was available. Revised values included daily living expenses for people who have been

37 evacuated and relocated, and the value of farm and non-farm wealth. The economic data were

38 inflation-adjusted to the year 2006 using the consumer price index.

39 NSP addressed the impact on the SAMA analysis of three recently reported problems with

40 SECPOP2000. These problems involved: (1) an inconsistency in the format in which several

41 economic parameters were output from the SECPOP2000 code and input to the MACCS2 code,

42 (2) an error that resulted in use of agricultural/economic data for the wrong counties in the

43 SECPOP2000 calculations, and (3) an error that resulted in the economic data for some

44 counties being handled incorrectly. NSP states in Section F.3.1 of the ER that all three errors

45 have been addressed in the PINGP 1 and 2 analyses provided in the ER via industry-developed

46 formatting fixes, and that the MACCS2 outputs used to quantify economic impacts have been

47 verified to be correct (NMC 2008).

Draft NUREG-1437, Supplement 39 F-13 October 2009
Appendix F

1 The NRC staff concludes that the methodology used by NSP to estimate the offsite

2 consequences for PINGP 1 and 2 provides an acceptable basis from which to proceed with an

3 assessment of risk reduction potential for candidate SAMAs. Accordingly, the NRC staff based

4 its assessment of offsite risk on the CDF and offsite doses reported by NSP.

5 F.3. Potential Plant Improvements

6 The process for identifying potential plant improvements, an evaluation of that process, and the

7 improvements evaluated in detail by NSP are discussed in this section.

8 F.3.1. Process for Identifying Potential Plant Improvements

9 NSP's process for identifying potential plant improvements (SAMAs) consisted of the following

10 elements:

11 0 Review of the most significant basic events from the Rev. 2.2 (SAMA) version

12 of the PINGP 1 and 2 Level 1 and 2 PRA for each unit,

13 0 Review of potential plant improvements identified in the PINGP 1 and 2 IPE

14 and IPEEE,

15 * Review of dominant contributors to seismic and fire events in the current

16 external event risk models,

17 0 Review of Phase II SAMAs from license renewal applications for eleven other

18 U.S. nuclear sites, and

19 * Input from PINGP 1 and 2 Group during the PRA update process and the

20 development of the SAMA list.

21 On the basis of this process, an initial set of 25 candidate SAMAs, referred to as Phase I

22 SAMAs, was identified for Unit 1 and Unit 2. In Phase I of the evaluation, NSP performed a

23 qualitative screening of the initial list of SAMAs and eliminated SAMAs from further

24 consideration using one of the following criteria:

25 0 The SAMA is not applicable at PINGP 1 and 2 because of design differences;

26 0 The SAMA has already been implemented at PINGP 1 and 2;

27 0 The SAMA has no significant benefit in PWRs such as PINGP 1 and 2;

28 • The SAMA has benefits which have been achieved by other means; and

29 * The SAMA requires extensive changes that would involve implementation

30 costs known to exceed any possible benefit.

31 Based on this screening, 16 SAMAs were eliminated, leaving nine for further evaluation. The

32 remaining SAMAs, referred to as Phase II SAMAs, are listed in Table F.5-3 of the ER (NMC

33 2008). In Phase II, a detailed evaluation was performed for each of the nine remaining SAMA

34 candidates, as discussed in Sections F.4 and F.6 below. To account for the potential impact of

35 external events, the estimated benefits based on internal events were multiplied by a factor of 2,

36 as previously discussed.

October 2009 F-14 Draft NUREG-1437, Supplement 39
Appendix F

1 F.3.2. Review of NSP's Process

2 NSP's efforts to identify potential SAMAs focused primarily on areas associated with internal

3 initiating events, but also included explicit consideration of potential SAMAs for seismic, fire, and

4 high wind events. The initial list of SAMAs generally addressed the accident sequences

5 considered to be important to CDF from functional, initiating event, and risk reduction worth

6 (RRW) perspectives at PINGP 1 and.2, and included selected SAMAs from other plants.

7 NSP provided a tabular listing of the PRA basic events sorted according to their RRW (NMC

8 2008). SAMAs impacting these basic events would have the greatest potential for reducing risk.

9 NSP used a RRW cutoff of 1.02, which corresponds to about a 2 percent change in CDF given

10 100-percent reliability of the SAMA. This equates to a benefit of approximately $22,000 for Unit

11 1 and $58,000 for Unit 2 (after the benefits have been doubled to account for external events).

12 NSP also provided and reviewed the LERF-based RRW events down to an RRW of 1.02. NSP

13 correlated the top CDF and LERF events with the SAMAs evaluated in Phase I or Phase II and

14 showed that, with a few exceptions, all of the significant basic events are addressed by one or

15 more SAMAs (NMC 2008). Of the basic events of high risk importance that are not addressed

16 by SAMAs, each is closely tied to other basic events that had been addressed by one or more

17 SAMAs.

18 The NRC staff noted that the top two events in the Level 1 importance listing shown in Table

19 F.5-1 a of the ER, involve failure of operator actions (Operator Fails to Perform RCS Cooldown

20 and Depressurization on Small LOCA, and Operator Fails to Initiate High Head Recirculation

21 (conditional on failure of the first action)). Improvements for these actions were dismissed by

22 NSP due to the large uncertainty regarding the operator failure probability estimates. The NRC

23 requested additional clarification on the characteristics of these actions that prevents further

24 improvement in operator performance (and lower calculated human error probability values).

25 NSP stated that both of these operator actions are emergency operating procedure-driven and

26 are trained on at least once during a 2-year training cycle (NSP 2008). In a follow-up response,

27 NSP included a detailed discussion on the critical role timing plays for these actions showing

28 that there is limited time available for recovery and that the second action is questioned on

29 failure of the first therefore lowering its success likelihood (NSP 2009a). In consideration of the

30 above factors, the NRC staff concludes that improvements in these actions are unlikely for the

31 purposes of the SAMA evaluation.

32 The NRC staff noted that the description of the screening criteria provided in Section 4.17.1 of

33 the ER (and summarized in Section F.3.1 above), is different than that provided in Section F.5.2

34 of the ER. In response to an NRC staff request for clarification regarding the actual screening

35 criteria used, NSP provided a mapping of the screened candidate SAMAs to the two sets of

36 criteria. For most screened SAMAs, the "no significant benefit" criterion of Section 4.17.1 was

37 equated to the engineering judgment criterion found in Section F.5.2. Although the approach of

38 listing two sets of screening criteria and the inclusion of an "engineering judgment" criterion was

39 found to be confusing, the NRC staff did not identify any candidate SAMAs as being

40 inappropriately screened.

41 For a number of the Phase II SAMAs listed in the ER, the information provided did not

42 sufficiently describe the proposed modifications or other considerations that might have been

43 taken into account in estimating the benefit and implementation cost. Therefore, the NRC staff

44 requested and the licensee provided more information on certain proposed modifications listed

45 for the Phase II SAMA candidates. The requested information included clarification of the $300K

46 implementation cost for SAMA 2-(Install alternate cooling water supply), description of the basis

47 for the $2M per unit cost for SAMA 6a (Segregate Auxiliary Building flooding zones), and

48 clarification of the $1 00K life-cycle cost for SAMA 20 (Close low head injection motor operated

Draft NUREG-1437, Supplement 39 F-15 October 2009
Appendix F

1 valves (MOVs) to prevent RCS backflow to safety injection system) (NRC 2008a, NSP 2008).

2 The responses to these requests are discussed in Section F.5.

3 For several SAMA candidates, the NRC staff questioned if lower cost alternatives could have

4 been considered, and identified a number of specific alternatives for further consideration by

5 NSP. In response, NSP addressed the lower cost alternatives and gave specific reasons why

6 the cost of most of these alternative SAMA candidates would be high enough that the decision

7 on final SAMA selection would not have been affected. However, NSP found that one

8 alternative associated with the purchase of a gagging device that could be used to close a

9 stuck-open SG safety valve would be potentially cost-beneficial (NSP 2008). The evaluation of

10 these SAMAs is discussed further in Section F.6.2.

11 NSP considered the potential plant improvements identified in the IPE and IPEEE in the

12 identification of plant-specific candidate SAMAs for internal and external events, as summarized

13 below.

14 As a result of the PINGP 1 and 2 IPE, nine modifications to plant procedures, operator training,

15 or plant hardware were identified. These enhancements are listed in the Section F.5.1.5 of the

16 ER. Based on information provided in the ER and in response to NRC staff RAIs (NSP 2008,

17 2009a and 2009b), all but two of these items have been implemented by either procedure

18 modifications, operator training revisions, or hardware modifications. The two unresolved items

19 involve procedure and/or plant modifications related to internal flooding events, specifically, a

20 procedure change to crosstie Cooling Water System Headers A and B in order to supply the

21 MFW pumps' lube oil coolers following a break in one of the headers (referred to as

22 Enhancement 2), and modifications to promote water flow out of the Auxiliary Feedwater

23 Pump/Instrument Air Compressor Room following a break in the Cooling Water System or to

24 segregate the room into two compartments (referred to as Enhancement 3). For these items,

25 the ER credits an engineering calculation (ENG-ME-148, Revision 0, "Cooling Water Header

26 Pipe Failure Causing Flooding in the Auxiliary Feedwater Pump/Instrument Air Compressor

27 Room") for providing confidence that the probability of a double-ended guillotine break is

28 negligible and that leak-before-break detection will provide sufficient warning for the

29 accomplishment of mitigation actions. This calculation, in conjunction with the 1992 installation

30 of 33 percent thicker walled piping, was provided as the present resolution for these internal

31 flooding enhancements. The calculation and piping modification were also used as the bases for

32 reducing the significance of the Cooling Water Header flood in the PRA. After reviewing the

33 engineering calculation, the NRC staff noted that it used deterministic arguments to address a

34 probabilistic pipe break frequency issue. The NRC staff also noted that two SAMAs, SAMA 6a

35 (Segregate Flooding Zones) and SAMA 13 (Install Automatic Sump Pump for Zone 7 Auxiliary

36 Building Flooding), are improvements that address Cooling Water floods and their significance

37 could have been underestimated as a result of the above method. In response to a follow-up

38 RAI, NSP stated that the method used to resolve these issues was not consistent with current

39 PRA practices and that its use could have caused the value of Enhancements 2 and 3 to be

40 understated. As a result, NSP has entered IPE Potential Enhancements 2 and 3 into their

41 Corrective Action Program for further evaluation after the PRA has been updated with improved

42 methodology for modeling pipe breaks (NSP 2009b).

43 Based on this information, the NRC staff concludes that the set of SAMAs evaluated in the ER,

44 together with those identified in supplemental information to the ER and in response to NRC

45 staff RAIs, addresses the major contributors in internal event CDF.

46 NSP did not identify PINGP 1 and 2-specific candidate SAMAs for seismic events. In the IPEEE

47 analysis, a total of 10 potential enhancements were identified to address external events. These

48 enhancements are:

October 2009 F-16 Draft NUREG-1437, Supplement 39
Appendix F

1 ° Add fire wrap or other fire barrier material to exposed control power cable for

2 Bus 16.

3 0 Add instructions to locally start the available roof exhaust fan to Fire Safety

4 Procedure F5.

5 0 Add instructions to manually open a suction supply valve to the 12 Auxiliary

6 Feedwater pump on a fire in Fire Area 32.

7 0 Ensure fire brigade training includes a discussion of the risk significance

8 associated with manual fire suppression for control room and relay room

9 fires.

10 0 Ensure operator training includes a discussion of the risk significance

11 associated with plant shutdown from outside the control room in accordance

12 with Fire Safety Procedure F5.

13 0 Ensure operator training includes a discussion of the risk significance

14 associated with bleed and feed cooling of the RCS due to internal fires.

15 0 Ensure operator training is implemented to perform DC panel switching in the

16 battery and relay rooms for a fire in Fire Area 59.

17 • Verify cable separation between trains in the G-panel.

18 ° Upgrade the anchorage for the main Cardox tank associated with the Relay

19 Room automatic fire suppression system.

20 * Upgrade the battery and fuel oil day tank anchorages for the diesel driven fire

21 water pump.

22 The above list of potential plant improvements is primarily related to fire events and seismic/fire

23 interactions. As noted in the ER, all identified improvements have either been implemented or

24 otherwise resolved, and therefore were not considered further in the SAMA analysis.

25 The IPEEE seismic margin analysis identified 22 outliers, where each outlier represents one or

26 more like components (NSP 1996, NSP 2000 and NRC 2001a). These were designated for

27 resolution under the A-46 program. As stated in the NRC's A-46 safety evaluation report, all A28 46 outliers were either resolved or scheduled for resolution by the May 1999 Unit 1 outage

29 (NRC 1998b).

30 In addition to the 22 outliers discussed above, NSP identified several potential seismic outliers

31 that were dispositioned through an analysis process described in the IPEEE that concluded that

32 the impacted function was not required or could be recovered, or that an alternate means for

33 performing the associated function was available. The outliers include: turbine-driven AFW

34 pump trip and throttle valves, diesel generator fuel oil storage tanks 122 and 124, the boric acid

35 transfer pumps, charging pumps 12 and 23, panel 117, cooling water pump 121, condensate

36 storage tanks 11, 12 and 13, component cooling water pressure switches, and diesel-driven

37 cooling water pump pressure switches. NRC staff requested that NSP demonstrate for these

38 selected outliers that enhancing the ruggedness of the associated components is not cost39 beneficial. NSP provided a detailed discussion of each of the selected outliers. No additional

40 SAMAs were identified as a result of this further evaluation. (NSP 2008). The NRC staff

41 reviewed the rationale used to disposition each of these seismic-related outliers and found the

42 rationale to be reasonable.

43 The NRC staff also noted that the PINGP 1 and 2 IPEEE seismic margin analysis found the

44 component cooling water heat exchangers to have a HCLPF of 0.28g which is below the 0.3 g

Draft NUREG-1437, Supplement 39 F-17 October 2009
Appendix F

1 screening value. In response to a NRC request to assess whether increased seismic capacity

2 would be cost-beneficial, NSP stated that the component cooling heat exchangers were

3 considered to be very close to the 0.3g threshold, and were thus considered to be adequate.

4 NSP also stated that the component cooling function which is to provide cooling to the RCP

5 seals, can be accomplished by the Chemical and Volume Control System (CVCS) therefore

6 reducing the significance of the heat exchanger seismic capacity (NSP 2008).

7 The NRC staff noted that the PINGP 1 and 2 IPEEE seismic margin analysis included a

8 recommendation to restrain or remove wall hung ladders and scaffolding located near safety

9 related equipment. In response to an NRC staff request for information regarding this

10 recommendation, NSP stated that during a recent field walkdown it was noted that ladders are

11 still located near safety-related equipment such as 4160 VAC Bus 25 and D2 and that an

12 investigation determined that there was no clear guidance for the location and construction of

13 ladder storage. NSP stated that this condition has been entered into the PINGP 1 and 2

14 Corrective Action Program to further investigate the issue and to determine whether current

15 ladder storage standards are adequate (NSP 2008).

16 Based on the licensee's efforts to identify and address seismic outliers and the expected cost

17 associated with further seismic risk analysis and potential plant modifications, the NRC staff

18 concludes that the opportunity for seismic-related SAMAs has been adequately explored and

19 that it is unlikely that there are additional potentially cost-beneficial, seismic-related SAMA

20 candidates.

21 NSP did not identify PINGP 1 and 2-specific candidate SAMAs for fire events. In order to better

22 understand the process used to identify fire-related SAMAs, the NRC staff requested that NSP

23 demonstrate that no viable SAMA candidates exist for each fire scenario included in the IPEEE.

24 In response, NSP stated that the IPEEE fire analysis has not been updated, contains significant

25 conservative assumptions, and does not include the plant modifications, procedure changes

26 and changes in risk analysis methodology that have occurred in the twelve years since its

27 completion. Notwithstanding the above considerations, NSP provided a list of additional SAMAs

28 that specifically address the risk from internal fires. These SAMAs were either implemented

29 (e.g., enhanced control of transient combustibles and ignition sources, enhanced fire brigade

30 awareness, upgraded fire comportment barriers) or considered not to be cost-beneficial (e.g.,

31 relocate instrument air compressors out of the AFW pump rooms, re-route cables that currently

32 run through risk significant fire areas). For each identified SAMA candidate, they provided a

33 disposition that resulted in the elimination of these fire-related SAMAs from further consideration

34 (NSP 2008). The NRC staff reviewed the rationale used to disposition each of these fire-related

35 SAMAs and found the rationale to be reasonable.

36 The NRC staff concludes that the opportunity for fire-related SAMAs has been adequately

37 explored and that it is unlikely that there are additional potentially cost-beneficial, fire-related

38 SAMA candidates.

39 The NRC staff notes that the set of SAMAs submitted is not all inclusive, since additional,

40 possibly even less expensive, design alternatives can always be postulated. However, the staff

41 concludes that the benefits of any additional modifications are unlikely to exceed the benefits of

42 the modifications evaluated and that the alternative improvements would not likely cost less

43 than the least expensive alternatives evaluated, when the subsidiary costs associated with

44 maintenance, procedures, and training are considered.

45 The NRC staff concludes that NSP used a systematic and comprehensive process for

46 identifying potential plant improvements for PINGP 1 and 2, and that the set of SAMAs

47 evaluated in the ER, together with those identified in response to the NRC staff inquiries, is

48 reasonably comprehensive and therefore acceptable. This search included reviewing insights

October 2009 F-18 Draft NUREG-1437, Supplement 39
Appendix F

1 from the plant-specific risk studies, reviewing plant improvements considered in previous SAMA

2 analyses, and using the knowledge and experience of its PRA personnel. While explicit

3 treatment of external events in the SAMA identification process was limited, it is recognized that

4 the prior implementation of plant modifications for seismic and fire events and the absence of

5 external event vulnerabilities reasonably justifies examining primarily the internal events risk

6 results for this purpose.

7 F.4. Risk Reduction Potential of Plant Improvements

8 NSP evaluated the risk-reduction potential of the nine remaining SAMAs that were applicable to

9 PINGP 1 and 2. The SAMA evaluations were performed by using realistic assumptions with

10 some conservatism. On balance, such calculations overestimate the benefit and are

11 conservative.

12 For all of the SAMAs, NSP used model re-quantification to determine the potential benefits. The

13 CDF and population dose reductions were estimated using the Rev. 2.2 (SAMA) model version

14 of the PINGP 1 and 2 PRA. The changes made to the model to quantify the impact of the

15 SAMAs are detailed in Section F.6 of Attachment F to the ER (NMC 2008). Table F-6 lists the

16 assumptions considered to estimate the risk reduction for each of the evaluated SAMAs, the

17 estimated risk reduction in terms of percent reduction in CDF and population dose, and the

18 estimated total benefit (present value) of the averted risk. The estimated benefits reported in

19 Table F-6 reflect the combined benefit in both internal and external events. The determination of

20 the benefits for the various SAMAs is further discussed in Section F.6.

21 In the SAMA analysis submitted in the ER, NSP increased the benefit that was derived from the

22 internal events model by a factor of 2 to account for the combined contribution from internal and

23 external events. The NRC staff agrees with the licensee's overall conclusion concerning the

24 impact of external events and concludes that the licensee's use of a multiplier of 2 is adequate.

25 This is discussed further in Section F.6.2.

26 Based on the description in the ER, the dominant internal flooding sequence (involving cooling

27 water header rupture) would result in core damage to both units. In response to a NRC staff

28 question, NSP explained that the dominant internal flooding sequences involved flooding of the

29 695' elevation of the Auxiliary Building from a rupture of a Cooling Water system header. If the

30 operators fail to identify and isolate the rupture prior to submergence of the component water

31 pumps, then residual heat removal pumps, containment spray pumps as well as motor control

32 centers supporting the charging pumps and other safeguards equipment will be lost. This results

33 in the loss of reactor coolant pump seal cooling and eventually leads to an unrecoverable RCP

34 seal LOCA. As this flooding event impacts both units (NSP 2008), the NRC requested

35 clarification as to the basis for the $2M per unit estimated cost for installation of flood barriers

36 shown in Table F.5.3 of the ER. NSP stated that at least 22 (11 per unit) individual, custom37 designed enclosures would be required and that the estimated cost for the design, fabrication,

38 installation and maintenance of these enclosures could reach $200,000 each. In a follow-up

39 question, staff requested an evaluation of a less extensive, alternative that would limit water

40 damage to single unit. In response, NSP stated that the room impacted by this flood is located

41 in the basement of the Auxiliary Building between the two units and the equipment within the

42 room is not separated by unit. Therefore a wall or other flood-limiting barrier would not be

43 practical.

44 The NRC staff has reviewed NSP's bases for calculating the risk reduction for the various plant

45 improvements and concludes that the rationale and assumptions for estimating risk reduction

46 are reasonable and somewhat conservative (i.e., the estimated risk reduction is similar to or

Draft NUREG-1437, Supplement 39 F-19 October 2009
Appendix F

1 somewhat higher than what would actually be realized). Accordingly, the staff based its

2 estimates of averted risk for the various SAMAs on NSP's risk reduction estimates

3

October 2009 F-20 Draft NUREG-1437, Supplement 39
Appendix F

1 Table F-6. SAMA Cost/Benefit Screening Analysis for PINGP 1 and 2 (a)

% Risk Reduction Total Benefit ($)

SAMA Modeling Assumptions Unit CDF Population Using 7% Using 3% Cost ($)

Dose discount discount per

rate rate (b) Unit

2- Install alternate An independent, diverse, auto- 1 21.2 6.8 88,000 123,000 1.2M (c)

cooling water start diesel-driven alternate

supply cooling water pump was 2 17.1 2.5 88,200 123,000

added to the models. Pump

failure rates were assumed

to be the same as existing

pumps.

3 - Provide A bypass line for each unit that 1 13.0 3.4 53,700 75,000 250K

alternate flow contains a normally closed,

path from fail closed air-operated valve 2 10.7 1.3 54,900 76,700

RWST to that opens on low VCT level

charging pump was added. The valve was

station (d) assumed to have no air

dependency and to have a

failure rate of a typical airoperated valve.

5- Install additional An independent, diverse, auto- 1 0.3 18.4 54,300 76,000 1.5M

diesel-driven start diesel-driven pump was

HPI pump added. The pump was 2 0.8 12.6 159,000 223,000

assumed to have no

common cause coupling

with the existing safety

injection (SI) pumps. Pump

failure rates were assumed

to be the same as one of the

existing diesel-driven

cooling water pumps.

9 - Analyze room The safeguards vertical cooling 1 10.7 3.4 45,000 62,700 62.5K

heat-up for water pump (12, 121 and

natural / forced 22) were assumed to not fail 8.6 1.3 45,100 62,900

circulation due to Screenhouse

(Screenhouse Ventilation system failures.

Ventilation)

12 - Alternate The cooling water upgrade from 1 30.1 8.9 133,000 186,000 900K

component SAMA 2 has been

cooling water performed, and an 2 25.2 8.2 216,000 302,000

supply (e) automatic means of

supplying water on loss of

component cooling flow

using motor-operated valves

was added with typical valve

failure rates.

15 - Provide A dedicated DC backup supply 1 0 0 0 0 130K

portable DC for 21 AFW pump breaker

power source control power was added 2 2.8 0.3 13,800 19,300

with a typical battery failure

on demand probability.

2

Draft NUREG-1437, Supplement 39 F-21 October 2009
Appendix F

1 F.5. Cost Impacts of Candidate Plant Improvements

2 NSP estimated the costs of implementing the nine candidate SAMAs through the application of

3 engineering judgment, use of other licensees' estimates for similar improvements, and

4 development of site-specific cost estimates. The cost estimates do not include the cost of

5 replacement power during extended outages required to implement the modifications. In

6 response to an RAI, NSP stated that the implementation costs also did not include contingency

7 costs associated with unforeseen implementation obstacles, nor do they include any inflation

8 adjustments (NSP 2008). Neglecting these factors is conservative.

9 The NRC staff reviewed the bases for the applicant's cost estimates. For certain improvements, 10 the staff also compared the cost estimates with estimates developed elsewhere for similar

11 improvements, including estimates developed as part of other licensees' analyses of SAMAs for

12 operating reactors and advanced light-water reactors. The NRC staff reviewed the costs and

13 found them to be reasonable, and generally consistent with estimates provided in support of

14 other plants' analyses.

15 The NRC staff requested additional information regarding the estimated costs for certain

16 SAMAs, as summarized below.

17 For SAMA 2 (Install alternate cooling water supply), the NRC staff requested

18 clarification on the $300K implementation cost for each unit. In response,

19 NSP stated that the estimate was for procedure changes as implementation

20 of this SAMA credits a potable fire pump connected to the cooling water

21 system and utilizes existing connections. NSP further noted that additional

22 analysis now indicates that the portable fire pump capacity was not adequate

23 and that a diesel-driven pump would be required with an estimated cost of

24 $2.4 million shared between the two units. This estimate is stated as being

25 comparable to cost of a similar installation at another power plant (NSP 2008)

26 For SAMA 6a (Segregate Auxiliary Building flooding zones), the NRC staff

27 requested additional information on the description of the proposed

28 modification to better understand the cost estimate of $2M per unit. In

29 response, NSP stated that the modification would have to consist of a series

30 of enclosures that surround individual equipment. Some enclosures would

31 only consist of walls to protect from rising water while others would need to

32 provide full covered enclosures to protect from spray. At least 22 (11 per unit)

33 individual, custom-designed enclosures would be required. In response to a

34 follow-up question to consider a less extensive alternative that would limit

35 water damage to the systems, structures and components for a single unit,

36 NSP stated that the equipment is separated not by unit, but by train.

37 Therefore, a wall or other flood-limiting barrier to protect one unit is not

38 practical (NSP 2008 and 2009)

39 For SAMA 20 (Close low head injection MOVs to prevent RCS backflow to

40 safety injection system), staff requested clarification of the $1 00K life-cycle

41 cost component of the cost estimate, since this SAMA simply changes the

42 operation of an existing valve. In response, NSP stated that additional review

43 revealed the life-cycle cost would be inherent to maintaining these valves

44 whether the valves are normally open or closed. Therefore, NSP removed the

45 $100K life cycle cost from the cost estimate for SAMA 20 (NSP 2009a). Table

46 F-6 reflects this corrected value.

October 2009 F-22 Draft NUREG-1437, Supplement 39
Appendix F

1 The NRC staff also requested clarification as to the treatment of candidate

2 SAMAs that have a positive risk benefit to both units. In response, NSP

3 stated that the costs were evenly apportioned between the two units (NSP

4 2009a). This is appropriate since the risk reduction benefit for each unit is

5 determined separately.

6 The NRC staff reviewed the additional information provided by NSP and found it to be

7 reasonable. The NRC staff concludes that the cost estimates provided by NSP are sufficient

8 and appropriate for use in the SAMA evaluation.

9 F.6. Cost-Benefit Comparison

10 NSP's cost-benefit analysis and the NRC staff's review are described in the following sections.

11 F.6.1. NSP's Evaluation

12 The methodology used by NSP was based primarily on NRC's guidance for performing cost13 benefit analysis, i.e., NUREG/BR-01 84, Regulatory Analysis Technical Evaluation Handbook

14 (NRC 1997a). The guidance involves determining the net value for each SAMA according to the

15 following formula:

16 Net Value = (APE + AOC + ACE + AOSC) - COE where,

17 APE = present value of averted public exposure ($)

18 AOC = present value of averted offsite property damage costs ($)

19 ACE = present value of averted occupational exposure costs ($)

20 AOSC = present value of averted onsite costs ($)

21 COE = cost of enhancement ($).

22 If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the

23 benefit associated with the SAMA, and it is not considered cost-beneficial. NSP's derivation of

24 each of the associated costs is summarized below.

25 NUREG/BR-0058 was revised in 2004 to reflect the agency's policy on discount rates. Revision

26 4 of NUREG/BR-0058 states that two sets of estimates should be developed: one at 3 percent

27 and one at 7 percent (NRC 2004b). NSP provided both sets of estimates (NMC 2008).

28 Averted Public Exposure (APE) Costs

29 The APE costs were calculated by using the following formula:

30 APE = Annual reduction in public exposure (Aperson-rem per year)

31 x monetary equivalent of unit dose ($2000 per person-rem)

32 x present value conversion factor (15.04 based on a 20-year period with a

33 3-percent discount rate).

34 As stated in NUREG/BR-0184 (NRC 1997a), it is important to note that the monetary value of

35 the public health risk after discounting does not represent the expected reduction in public

36 health risk due to a single accident. Rather, it is the present value of a stream of potential losses

37 extending over the remaining lifetime (in this case, the renewal period) of the facility. Thus, it

38 reflects the expected annual loss due to a single accident, the possibility that such an accident

39 could occur at any time over the renewal period, and the effect of discounting these potential

40 future losses to present value. For the purposes of initial screening, which assumes elimination

Draft NUREG-1437, Supplement 39 F-23 October 2009
Appendix F

1 of all severe accidents due to internal events, NSP calculated an APE of approximately $88,000

2 for Unit 1 and $254,000 for Unit 2 for the 20-year license renewal period.

3 Averted Offsite Property Damage Costs (AOC)

4 The AOCs were calculated by using the following formula:

5 AOC = Annual CDF reduction

6 x offsite economic costs associated with a severe accident (on a per-event basis)

7 x present value conversion factor.

8 For the purposes of initial screening, which assumes all severe accidents due to internal events

9 are eliminated, NSP calculated an annual offsite economic risk of about $16,000 for Unit 1 and

10 $63,000 for Unit 2 based on the Level 3 risk analysis. This results in a discounted value of

11 approximately $238,000 for Unit 1 and $953,000 for Unit 2 for the 20-year license renewal

12 period.

13 Averted Occupational Exposure (AOE) Costs

14 The AOE costs were calculated by using the following formula:

15 AOE = Annual CDF reduction

16 x occupational exposure per core damage event

17 x monetary equivalent of unit dose

18 x present value conversion factor.

19 NSP derived the values for averted occupational exposure from information provided in Section

20 5.7.3 of the regulatory analysis handbook (NRC 1997a). Best estimate values provided for

21 immediate occupational dose (3300 person-rem) and long-term occupational dose (20,000

22 person-rem over a 10-year cleanup period) were used. The present value of these doses was

23 calculated by using the equations provided in the handbook in conjunction with a monetary

24 equivalent of unit dose of $2000 per person-rem, a real discount rate of 3 percent, and a time

25 period of 20 years to represent the license renewal period. For the purposes of initial screening,

26 which assumes all severe accidents due to internal events are eliminated, NSP calculated an

27 AOE of approximately $6,100 for Unit 1 and $7,500 for Unit 2 for the 20-year license renewal

28 period.

29 Averted Onsite Costs (AOSC)

30 Averted onsite costs (AOSC) include averted cleanup and decontamination costs (ACC) and

31 averted power replacement costs. Repair and refurbishment costs are considered for

32 recoverable accidents only and not for severe accidents. NSP derived the values for AOSC

33 based on information provided in Section 5.7.6 of NUREG/BR-0184, the regulatory analysis

34 handbook (NRC 1997a).

35 NSP divided this cost element into two parts: the onsite cleanup and decontamination cost, also

36 commonly referred to as averted cleanup and decontamination costs, and the replacement

37 power cost.

38 Averted cleanup and decontamination costs were calculated by using the following formula:

39 ACC = Annual CDF reduction

40 x present value of cleanup costs per core damage event

41 x present value conversion factor.

42 The total cost of cleanup and decontamination subsequent to a severe accident is estimated in

43 the regulatory analysis handbook to be $1.5 x 109 (undiscounted). This value was converted to

44 present costs over a 10-year cleanup period and integrated over the term of the proposed

October 2009 F-24 Draft NUREG-1437, Supplement 39
Appendix F

1 license extension. For the purposes of initial screening, which assumes all severe accidents due

2 to internal events are eliminated, NSP calculated an ACC of approximately $191,000 for Unit 1

3 and $235,000 for Unit 2 for the 20-year license renewal period.

4 Long-term replacement power costs (RPC) were calculated using the following formula:

5 RPC = Annual CDF reduction

6 x present value of replacement power for a single event

7 x factor to account for remaining service years for which replacement power is

8 required

9 x reactor power scaling factor

10 NSP based its calculations on the value of 560 megawatt electric (MW(e)). Therefore, NSP

11 applied a power scaling factor of 560/910 (the ratio of the actual power level to the "generic"

12 power plant level in NUREG/BR-01 84) to determine the replacement power costs. For the

13 purposes of initial screening, which assumes all severe accidents due to internal events are

14 eliminated, NSP calculated an RPC of approximately $33,000 for Unit 1 and $41,000 for Unit 2,

15 and an AOSC of $224,000 for Unit 1 and $276,000 for Unit 2.

16 By using the above equations, NSP estimated the total present dollar value equivalent

17 associated with completely eliminating severe accidents due to internal events at PINGP 1 and

18 2 to be about $557,000 for Unit 1 and $1.49 million for Unit 2. The higher baseline risk for Unit 2

19 is attributed to the higher CDF and LERF resulting from the fact that Unit 2 has not yet replaced

20 its steam generators. To account for additional risk reduction in external events, NSP doubled

21 this value (to $1.11 million for Unit 1 and $2.98 million for Unit 2) to provide the modified

22 maximum averted cost risk (MMACR), which represents the dollar value associated with

23 completely eliminating all internal and external event severe accident risk at PINGP 1 and 2.

24 The total site MMACR for PINGP 1 and 2 is then $4.09 million.

25 NSP's Results

26 If theimplementation costs for a candidate SAMA were greater than the MMACR of $1.11

27 million for Unit 1 and $2.98 million for Unit 2, then the SAMA was screened from further

28 consideration. A more refined look at the costs and benefits was performed for the remaining

29 SAMAs. If the implementation costs for a candidate SAMA exceeded the calculated benefit, the

30 SAMA was considered not to be cost-beneficial. In the baseline analysis contained in the ER

31 (using a 3 percent discount rate), NSP identified one potentially cost-beneficial SAMA for Unit 1

32 and two potentially cost-beneficial SAMAs for Unit 2. The potentially cost-beneficial SAMAs are:

33 SAMA 9 (Unit 1 and Unit 2) - Implement procedure or plant modification to

34 improve ventilation for safeguards equipment in the Screenhouse. This would

35 be achieved by either performing a best-estimate room heat-up analysis to

36 show that procedural practices (opening doors, installing portable fans) would

37 allow safeguards cooling water pumps to run for at least 24 hours without

38 forced ventilation following a loss of the safeguard ventilation system serving

39 those rooms, or improving Screenhouse ventilation reliability via hardware

40 modifications.

41 SAMA 22 (Unit 2 only) - Provide compressed air backup for instrument air to

42 containment. This would be achieved by either qualifying the existing

43 accumulator air supply for bleed and feed cooling when the normal supply of

44 instrument air to the PORVs is unavailable, or providing a backup to the

45 accumulators to support feed and bleed operation.

Draft NUREG-1437, Supplement 39 F-25 October 2009
Appendix F

1 NSP performed additional analyses to evaluate the impact of parameter choices and

2 uncertainties on the results of the SAMA assessment (NMC 2008). If the benefits are based on

3 use of the 9 5 th percentile CDF results rather than the point estimates for CDF, one additional

4 SAMA candidate was determined to be potentially cost-beneficial for Unit 1. This is SAMA 22,

5 which had already been shown to be cost-beneficial for Unit 2.

6 In response to NRC staff inquiries regarding the treatment of consequential SGTR in the

7 baseline PRA, the approach used to estimate uncertainty, and the consideration of lower cost

8 alternatives, NSP identified three additional potentially cost-beneficial SAMAs. In addition, in

9 response to NRC questions regarding modeling of internal floods, NSP entered two

10 unimplemented IPE enhancements into the PINGP 1 and 2 Corrective Action Program for

11 further evaluation after the PRA has been updated with improved methodology for modeling

12 pipe breaks.

13 The potentially cost-beneficial SAMAs and NSP's plans for further evaluation of these SAMAs

14 are discussed in more detail in Section F.6.2.

15 F.6.2. Review of NSP's Cost-Benefit Evaluation

16 The cost-benefit analysis performed by NSP was based primarily on NUREG/BR-0184 (NRC

17 1997a) and was implemented consistent with this guidance.

18 SAMAs identified primarily on the basis of the internal events analysis could provide benefits in

19 certain external events, in addition to their benefits in internal events. To account for the

20 additional benefits in external events, NSP multiplied the internal event benefits for each internal

21 event SAMA by a factor of 2. Potential benefits in external events were estimated in this manner

22 since the external events models are generally less detailed than the internal events models

23 and do not lend themselves to quantifying the benefits of the specific plant changes associated

24 with internal event SAMAs. For example, the benefits of a procedure change associated with an

25 important internal event sequence can not be readily assessed using the seismic risk model if

26 that operator action or system is not represented in the seismic risk model. The use of a

27 multiplier on the benefits obtained from the internal events PRA to incorporate the impact of

28 external events implicitly assumes that each SAMA would offer the same percentage reduction

29 in external event CDF and population dose as it offers in internal events. While this provides

30 only a rough approximation of the potential benefits, such an adjustment was considered

31 appropriate given the risk contribution from external events relative to internal events and the

32 lack of information on which to base a more precise risk reduction estimate for external events.

33 As the IPEEE results indicate an external events contribution that is about 4 to 5 times the

34 internal events CDF, additional information and analysis was provided by NSP in response to

35 NRC staff questions regarding the basis for the use of a multiplier of 2 for external events. As

36 discussed in Section F.2.2, NSP demonstrated that the PINGP 1 and 2 fire risk would be in the

37 range of 1 x 10.5 per year rather than the fire CDF of about 5 x 10-5 per year from the IPEEE.

38 NSP also estimated the seismic contribution by using what they referred to as a bounding

39 "Simplified Hybrid Method" to quantify the results of the seismic margin analysis. This method

40 resulted in a CDF of 7.8 x 10.6 per year. A corresponding NRC staff estimate using updated

41 USGS seismic hazard information is 2.5 x 10B per year. For other external hazards (i.e., high

42 winds, tornadoes, external flooding, transportation and nearby industrial facility accidents), NSP

43 stated that PINGP 1 and 2 meets the applicable Standard Review Plan requirements, and

44 therefore has an acceptably low risk with respect to these hazards. In conclusion, NSP stated

45 that no higher multiplier is believed to be warranted (NSP 2008). In view of the additional

46 justification provided by NSP, including the remaining conservatism in the external events CDF,

47 and the licensee's further evaluation of the impacts of uncertainty on SAMA results (discussed

October 2009 F-26 Draft NUREG-1437, Supplement 39
Appendix F

1 below), the NRC staff agrees that the internal and external event CDF values would be

2 comparable, and that use of a multiplier of 2 for external events is reasonable for the purposes

3 of the SAMA evaluation.

4 NSP considered the impact that possible increases in benefits from analysis uncertainties would

5 have on the results of the SAMA assessment. In the ER, NSP presents the results of an

6 uncertainty analysis of the internal event CDF for Units 1 and 2. The NSP approach quantified

7 the Level 1 model uncertainty and uncertainty multiplier for each SAMA. (In previous license

8 renewal uncertainty analyses, licensees determined and applied a single uncertainty multiplier

9 based on the uncertainty distribution in the baseline risk model.) In response to a NRC staff

10 question on the uncertainty analysis, NSP provided additional justification on their approach.

11 However, in reviewing the application of their uncertainty approach, NSP did find that the 9 5th

12 percentile result for each SAMA had been incorrectly divided by the baseline CDF value as

13 opposed to the estimated CDF value for the SAMA. Corrected uncertainty multipliers were

14 provided (NSP 2008). The factor by which the 95th percentile CDFs exceed the point estimate

15 CDFs ranged from 1.8 to 2.9 over the set of SAMAs (NMC 2008).

16 NSP reexamined the initial set of SAMAs to determine if any additional Phase I SAMAs would

17 be retained for further analysis if the benefits (and MMACR) were increased by the 9 5 th

18 percentile uncertainty factor for each SAMA. Five such Phase I SAMAs were identified: SAMA 1

19 - Automate the swap-over of ECCS from the RWST to the containment sump, SAMA 10 -

20 Automate the transfer of charging pump suction from the VCT to the RWST on low VCT level,

21 SAMA 17 - Provide a bypass line around the RHR Loop B return valve to reduce the risk

22 associated with failure of the return valve to open, SAMA 19a - Upgrade equipment and

23 procedures for replenishing RWST inventory from a large water source, and SAMA 21 - 24 Increase the reliability of PORV closure. These SAMAs were further evaluated as described

25 below.

26 NSP also considered the impact on the Phase II screening if the estimated benefits were

27 increased by the 9 5 th percentile uncertainty factor for each SAMA. NSP reported in the ER that

28 one additional SAMA could be cost-beneficial for Unit 1. This additional SAMA is SAMA 22,

29 which was already shown to be cost-beneficial for Unit 2 in the baseline analysis. However, the

30 results of the revised uncertainty assessment show that SAMA 19a (Upgrade equipment and

31 procedures for replenishing RWST inventory from a large water source) is also potentially cost32 beneficial for Unit 2. SAMA 19a which improves the SGTR mitigation capability is not cost33 beneficial for Unit 1 as this unit had its steam generators replaced in 2004. NSP has entered

34 SAMA 19a into the PINPG Corrective Action Program for further evaluation for Unit 2 (NSP

35 2008 and 2009a). The NRC staff finds that the updated uncertainty analysis and the application

36 of this analysis to the SAMA screening process to be adequate for the identification of potential

37 SAMAs.

38 The NRC noted that, for certain SAMAs considered in the ER, there may be lower-cost

39 alternatives that could achieve much of the risk reduction at a lower cost. Several of these

40 alternatives were evaluated by NSP subsequent to the ER, and described in the supplemental

41 information to the ER (NSP 2008). These alternatives include:

42 • Procedure for manually controlling the degree of SG depressurization and

43 reclosing the SG PORVs in the event core damage is imminent

44 • Procedure for enhancing manual operation of turbine-driven Auxiliary

45 Feedwater pumps including the consideration of alternate water sources and

46 operator aids for using local flow indication

Draft NUREG-1437, Supplement 39 F-27 October 2009
Appendix F

1 * Procedure and equipment for using a portable pump to provide Feedwater to

2 the SGs with suction from either the external fire ring header or intake canal

3 0 Procedure for recovering emergency diesel generators D-1 and D-2 by

4 supplying alternate cooling from well water

5 0 Reconfiguring the non-safety main feedwater loads to be powered from DC

6 Bus B (as an alternative to SAMA 15)

7 0 Modifying the charging pumps electrical connections to enable re-powering

8 from alternate 480 power supply using pre-staged cables

9 * Installing a connection flange and valve on safety injection pump flow test

10 return line to the refueling water storage tank to. enable cross-connection of

11 SI pumps to AFW piping

12 0 Modifying the charging and volume control system to allow cross-tie of the

13 charging pumps from the opposite unit

14 * Purchase of a gagging device that could be used to close a stuck-open SG

15 safety valve on the ruptured steam generator prior to core damage in SGTR

16 events

17 In response, NSP indicated that for some of the above candidate SAMAs plant guidance

18 currently exists, and for others, their implementation would not be cost-beneficial. The

19 disposition is summarized as follows. Procedures for manually controlling the degree of SG

20 depressurization, manual operation of the turbine-driven pumps, use of a portable pump to

21 provide feedwater to the SGs, and the recovery of cooling water for emergency diesel

22 generators D-1 and D-2 were stated as already being in place. The alternate to SAMA 15 was

23 estimated to have a higher implementation cost than SAMA 15 as it would involve modifications

24 to a larger set of components. The alternative that suggested re-powering the charging pumps

25 using alternate 480V power and pre-staged cables was stated as not being cost-beneficial due

26 to the ability to cross-tie the 4kV buses between units, the availability of dedicated EDGs for

27 each 4kV safeguards bus, and the design differences between each unit's EDG sets which

28 limits the likelihood of common cause failure of all the site EDGs. The alternative of enabling

29 cross-connection of SI to AFW pumps was stated as likely to be ineffective as such a

30 connection would require a long length of hose able to withstand high pressures and that other

31 alternative means have already been implemented. The alternative to modify the charging and

32 volume control system to allow it to be cross-tied from the opposite unit was stated as having an

33 implementation cost that would be greater than that of SAMA 3 (Provide alternate flow path form

34 RWST to charging pump suction) as the piping for this alternative is longer. However, NSP

35 concluded that the last alternative identified above, purchase of a gagging device for closing a

36 stuck-open steam generator safety valve, may be cost-beneficial at PINGP 1 and 2 (for both

37 units). NSP has entered this SAMA into the PINPG Corrective Action Program for a more

38 detailed examination of its viability and implementation cost (NSP 2008).

39 As discussed in Section F.2.2, the NRC staff could not clearly establish the modeling approach

40 used to assess the likelihood of a thermally-induced SGTR following core damage in the current

41 PRA. In response to an RAI, NSP stated that the treatment of induced SGTR events follows the

42 guidance of WCAP-16341-P, "Simplified Level 2 Modeling Guidelines." However, this guidance

43 has not been submitted to or reviewed by the NRC. NSP stated that all accident sequences

44 where core damage occurs at high reactor pressure and the steam generators are dry at the

45 time of core damage are assumed to have the potential to lead to pressure-induced SGTR. In

46 addition, all high reactor pressure, dry steam generator sequences in which the RCS is not

47 depressurized prior to vessel failure are assumed to have the potential to lead to temperatureOctober 2009 F-23 Draft NUREG-1437, Supplement 39
Appendix F

1 induced SGTR. In order to progress to an induced SGTR, NSP assumed that the secondary

2 side must be depressurized, either through failure of a relief valve upstream of the MSIV, or

3 through a main steam or feedwater line break. However, implementation details were not

4 provided or reviewed.

5 In order to demonstrate the sensitivity of the SAMA analysis results to this issue, the NRC staff

6 requested that NSP assess the impact on results if an induced SGTR conditional probability of

7 0.25 were used in the baseline analysis (i.e., a 0.25 probability of an induced SGTR given core

8 damage with high primary side pressure and a dry secondary side at low pressure). A

9 conditional probability of 0.25 is consistent with the base case results of an NRC study of

10 induced SGTR events documented in NUREG-1570 (NRC 1998c) and cited in the ASME PRA

11 Standard (ASME 2002). NSP's sensitivity analysis identified one additional cost-beneficial

12 SAMA. i.e., SAMA 3 - Provide alternate flow path from RWST to charging pump suction.

13 Although NSP stated that it does not feel the 0.25 conditional probability assumption is valid for

14 Prairie Island, they agreed to add SAMA 3 to the list of SAMAs that will be further evaluated for

15 possible implementation (NSP 2009b).

16 As discussed in Section F.3.2, two unimplemented IPE enhancements were found to have been

17 inappropriately dismissed, i.e., IPE Enhancement 2 - Procedure change to crosstie Cooling

18 Water System Headers A and B in order to supply the MFW pumps' lube oil coolers following a

19 break in one of the headers, and IPE Enhancement 3 - Modifications to promote water flow out

20 of the Auxiliary Feedwater Pump/Instrument Air Compressor Room following a break in the

21 Cooling Water System or to segregate the room into two compartments. As a result, NSP has

22 entered IPE Enhancements 2 and 3 into their Corrective Action Program for further evaluation

23 after the PRA has been updated with improved internal flood methodology.

24 Finally, as discussed in Section F.3.2, one previously identified IPEEE improvement associated

25 with restraining wall hung ladders was also found to not have been implemented. As a result,

26 NSP has entered the ladder storage issue into their Corrective Action Program.

27 The NRC staff concludes that, with the exception of the potentially cost-beneficial SAMAs

28 discussed above, the costs of the SAMAs evaluated would be higher than the associated

29 benefits.

30 F.7. Conclusions

31 NSP compiled a list of 25 SAMAs based on a review of the most significant basic events from

32 the plant-specific PRA, insights from the plant-specific IPE and IPEEE, and Phase II SAMAs

33 from license renewal activities for other plants. An initial screening removed SAMA candidates

34 that (1) were not applicable at PINGP 1 and 2 because of design differences, (2) had already

35 been implemented at PINGP 1 and 2, (3) had no significant benefit, or had benefits which have

36 been achieved by other means, or (4) required extensive changes that would involve

37 implementation costs known to exceed any possible benefit (i.e., more than $1.11 million for

38 Unit 1 and $2.98 million for Unit 2). Based on this screening, sixteen SAMAs were eliminated,

39 leaving nine candidate SAMAs for evaluation.

40 For the remaining SAMA candidates, a more detailed evaluation was performed as shown in

41 Table F-6. The cost-benefit analyses in the ER showed that two SAMA candidates were

42 potentially cost-beneficial in the baseline analysis (SAMA 9 for Units 1 and 2, and SAMA 22 for

43 Unit 2). NSP performed additional analyses to evaluate the impact of parameter choices and

44 uncertainties on the results of the SAMA assessment. As a result, SAMA 22 was identified as

45 potentially cost-beneficial for Unit 1. (This SAMA was already shown to be cost-beneficial for

46 Unit 2.) Based on additional analysis, three additional SAMAs were identified as potentially costDraft NUREG-1437, Supplement 39 F-29 October 2009
Appendix F

1 beneficial, i.e., SAMA 3 - provide alternate flow path from RWST to charging pump suction (for

2 Units 1 and 2), SAMA 19a - provide a reliable backup water source for replenishing the RWST

3 (for Unit 2), and a SAMA regarding purchase of a gagging device for closing a stuck-open

4 steam generator safety valve in SGTR events (for Units 1 and 2). NSP has indicated that these

5 potential cost-beneficial SAMAs have been entered into the PINGP 1 and 2 Corrective Action

6 Program to be further evaluated for possible implementation (NSP 2009a and 2009b). NSP has

7 also indicated that as a result of an identified internal flood modeling limitation, two internal flood

8 related enhancements previously identified in the IPE have also been entered into the

9 Corrective Action Program for further evaluation after the PRA has been updated with improved

10 methodology for modeling pipe breaks (NSP 2009b). Additionally, the lack of clear guidance for

11 the location and construction of ladder storage has been entered into the PINGP 1 and 2

12 Corrective Action Program to further investigate the issue and to determine whether current

13 ladder storage standards are adequate for seismic events (NSP 2008).

14 The NRC staff reviewed the NSP analysis and concluded that the methods used and the

15 implementation of those methods were sound. The treatment of SAMA benefits and costs

16 support the general conclusion that the SAMA evaluations performed by NSP are reasonable

17 and sufficient for the license renewal submittal. Although the treatment of SAMAs for external

18 events was somewhat limited, the likelihood of there being cost-beneficial enhancements in this

19 area was minimized by improvements that have been realized as a result of the IPEEE process,

20 and inclusion of a multiplier to account for external events.

21 The NRC staff concurs with NSP's identification of areas in which risk can be further reduced in

22 a cost-beneficial manner through the implementation of the identified, potentially cost-beneficial

23 SAMAs. Given the potential for cost-beneficial risk reduction, the staff agrees that further

24 evaluation of these SAMAs by NSP is warranted. However, these SAMAs do not relate to

25 adequately managing the effects of aging during the period of extended operation. Therefore,

26 they need not be implemented as part of license renewal which is submitted pursuant to Title 10

27 of the Code of Federal Regulations, Part 54, "Requirements for Renewal of Operating Licenses

28 for Nuclear Power Plants" (10 CFR Part 54).

29 F.8. References

30 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental

31 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

32 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for

33 Renewal of Operating Licenses for Nuclear Power Plants."

34 ASME (American Society of Mechanical Engineer). 2002. "Standard for Probabilistic Risk

35 Assessment for Nuclear Power Plant Applications," ASME RA-S-2002, April 5, 2002.

36 EPRI (Electric Power Research Institute). 1991. A Methodology for Assessment of Nuclear

37 Power Plant Seismic Margin, EPRI NP-6041-SL, Revision 1, Palo Alto, CA, August 1991.

38 Kennedy, Robert P. 1999. "Overview of Methods for Seismic PRA and Margin Analysis

39 Including Recent Innovations". Proceedings of the OECD-NEA Workshop on Seismic Risk,

40 Tokyo, Japan, August 1999.

41 NMC (Nuclear Management Company, LLC). 2008. Prairie Island Nuclear Generating Plant,

42 Units 1 and 2, License Renewal Application, Appendix E - Applicant's Environmental Report,

43 License Renewal Operating Stage. Redwing, Minnesota. April 2008. ADAMS Nos.

44 ML081130677, ML081130681, and ML081130684.

October 2009 F-30 Draft NUREG-1437, Supplement 39
Appendix F

1 NRC (U.S. Nuclear Regulatory Commission). 1990. Severe Accident Risks: An Assessment for

2 Five U.S. Nuclear Power Plants. NUREG-1 150, Washington, D.C.

3 NRC (U.S. Nuclear Regulatory Commission). 1991. Procedural and Submittal Guidance for the

4 Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities.

5 NUREG-1407, Washington, D.C.

6 NRC (U.S. Nuclear Regulatory Commission). 1997c. Individual Plant Examination Program:

7 Perspectives on Reactor Safety and Plant Performance. NUREG-1 560, Washington, D.C.

8 NRC (U.S. Nuclear Regulatory Commission). 1997a. Regulatory Analysis Technical Evaluation

9 Handbook. NUREG/BR-0184, Washington, D.C.

10 NRC (U.S. Nuclear Regulatory Commission). 1997b. Staff Evaluation of the Prairie Island

11 Nuclear Generating Plant Individual Plant Examination (IPE) Submittal - Internal Event. Letter

12 to Northern States Power Co., May.

13 NRC (U.S. Nuclear Regulatory Commission). 1998a. Code Manual for MACCS2: User's-Guide.

14 NUREG/CR-6613, Volume 1, SAND 97-0594. May 1998.

15 NRC (U.S. Nuclear Regulatory Commission). 1998b. Resolution of Unresolved Safety Issue

16 (USI) A-46 for Prairie Island Nuclear Generating Plant, Units 1 and 2 (TAC NOS M69474 and

17 M69475). Letter to Northern States Power Co., August 5, 1998.

18 NRC (U.S. Nuclear Regulatory Commission). 1998c. Risk Assessment of Severe Accident19 Induced Steam Generator Tube Rupture. NUREG-1 570, March 1998.

20 NRC (U.S. Nuclear Regulatory Commission). 2001a. Perspectives Gained From the Individual

21 Plant Examination of External Events (IPEEE) Program. NUREG-1 742, Vol. 2, Washington,

22 D.C.

23 NRC (U.S. Nuclear Regulatory Commission). 2001 b. Prairie Island Nuclear Generating Plant,

24 Units I and 2 - Review of Individual Plant Examination of External Events (IPEEE) (TAC Nos.

25 M83663 and M83664). Letter to NMC, May 29, 2001.

26 NRC (U.S. Nuclear Regulatory Commission). 2003. SECPOP2000: Sector Population, Land

27 Fraction, and Economic Estimation Program. NUREG/CR-6525, Rev. 1, Washington, D.C.

28 NRC (U.S. Nuclear Regulatory Commission). 2004a. An Approach for Determining the

29 Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities,

30 Regulatory Guide 1.200 for Trial Use. (February 2004).

31 NRC (U.S. Nuclear Regulatory Commission). 2004b. Regulatory Analysis Guidelines of the U.S.

32 Nuclear Regulatory Commission. NUREG/BR-0058, Rev. 4, Washington, D.C.

33 NRC (U.S. Nuclear Regulatory Commission). 2008a. Request for Additional Information for the

34 Review of the Prairie Island Nuclear Generating Plant, Units 1 & 2, License Renewal Application

35 (TAC Nos. MD8513 and MD8514). Letter to NMC, October 23, 2008.

36 NRC (U.S. Nuclear Regulatory Commission). 2008b. Request for Additional Information for the

37 Review of the Prairie Island Nuclear Generating Plant, Units 1 & 2, License Renewal Application

38 (TAC Nos. MD8513 and MD8514). Letter to NMC, December 24, 2008.

39 NSP (Northern States Power Company). 1994. Prairie Island Nuclear Generating Plant

40 Individual Plant Examination (IPE), NSPLMI-94001, Rev. 0, March 1.

41 NSP (Northern States Power Company). 1996. PINGP Individual Examination of External

42 Events (IPEEE), NSPLMI-96001, December 14, 1996.

Draft NUREG-1437, Supplement 39 F-31 October 2009
Appendix F

1 NSP (Northern States Power Company). 1998. PINGP Individual Examination of External

2 Events (IPEEE), NSPLMI-96001, Rev. 1, October 19, 1998.

3 NSP (Northern States Power Company). 2000. Response to Request for Additional Information

4 Regarding Report NSPLMI-96001, Individual Plant Examination of External Events (IPEEE),

5 Letter to NRC, February, 28 2000.

6 NSP (Northern States Power Company - Minnesota). 2008. Letter from M. Wadley, Site Vice

7 President, Northern States Power Company - Minnesota, to U.S. Nuclear Regulatory

8 Commission. Subject: Response to NRC Request for Additional Information Dated October 23,

9 2008 Regarding Application for Renewed Operating Licenses. November 21, 2008. ADAMS No.

10 ML083370505.

11 NSP (Northern States Power Company - Minnesota). 2009a. Letter from M. Wadley, Site Vice

12 President, Northern States Power Company - Minnesota, to U.S. Nuclear Regulatory

13 Commission. Subject: Response to NRC Requests for Additional Information Dated December

14 24, 2008 Regarding Application for Renewed Operating Licenses. January 23, 2009. ADAMS

15 No. ML090260290.

16 NSP (Northern States Power Company - Minnesota). 2009b. Letter from M. Wadley, Site Vice

17 President, Northern States Power Company - Minnesota, to U.S. Nuclear Regulatory

18 Commission. Subject: Supplemental Information Regarding Application for Renewed Operating

19 Licenses. March 4, 2009. ADAMS No. ML090690684.

20 SQUG (Seismic Qualification Users Group). 1992. Generic Implementation Procedure (GIP) for

21 Seismic Verification of Nuclear Plant Equipment, Revision 2, Corrected, February 14, 1992

22 USCB (U.S. Census Bureau). 2000. "Census 2000 Summary File 1 (SF 1) - 100 Percent Data."

23 Available URL: http://www.census.gov/Press-Release/www/2001/SumFile1.html.

24 USGS (U.S. Geological Survey). 2008. Documentation for the 2008 Update of the U. S. National

25 Seismic Hazard Maps, Open-File Report 2008-1128.

October 2009 F-32 Draft NUREG-1437, Supplement 39
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, Supplement 39

2. TITLE AND SUBTITLE 3. DATE REPORT PUBLISHED

Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GELS) MONTH YEAR

Supplement 39

Regarding Prairie Island Nuclear Generating Plant, Units 1 and 2 October 2009

4. FIN OR GRANT NUMBER

Draft Report for Comment

5. AUTHOR(S) 6. TYPE OF REPORT

See Chapter 10 of this 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 above

10. SUPPLEMENTARY NOTES

Docket Nos. 05000282 and 050000306

11. ABSTRACT (200 words or less)

This Supplemental Environmental Impact Statement (SEIS) has been prepared in response to an application submitted by

Northern States Power Co. (NSP) to the NRC to renew the operating licenses for Prairie Island Nuclear Generating Plant, Units

1 and 2 (PINGP 1 and 2) for an additional 20 years under 10 CFR Part 54, "Requirements for Renewal of Operating Licenses

for Nuclear Power Plants." This draft SEIS contains the NRC staffs analysis that considers and weighs the environmental

impacts of the proposed action, the environmental impacts of alternatives to the proposed action, and mitigation measures available for reducing or avoiding adverse impacts. It also includes the NRC staffs preliminary recommendations regarding the

proposed action.

The NRC staffs preliminary recommendation is that the Commission determine that the adverse environmental impacts of

license renewal for PINGP 1 and 2 are not so great that preserving the option of license renewal for energy planning decsionmakers would be unreasonable. This recommendation is based on (1) the analysis and findings in the GELS, (2) the

environmental report submitted by NSP, (3) consultation with other Federal, State, and Local agencies, (4) the NRC staffs own independent review, and (5) the NRC's staffs consideration of public comments received during the scoping period.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.) 13. AVAILABILITY STATEMENT

Prairie Island Nuclear Generating Plant, Units 1 and 2 unlimited

PINGP 1 and 2 14. SECURITY CLASSIFICATION

Supplement to the Generic Environmental Impact Statement (This Page)

DSEIS unclassified

National Environmental Policy Act (This Report)

NEPA unclassified

GElS

NUREG-1437, Supplement 39 15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (9-2004) PRINTED ON RECYCLED PAPER
F.doral R.oyc'Ing Program

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

OFFICIAL BUSINESS