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Calvert Cliffs Attachments: Hlnchapter 9 Alternatives.Doc CCNPP3COLA NPEmails From: Nash, Harriet Sent: Tuesday, February 02, 2010 12:15 PM To: Bruner, Douglas Cc: Quinn, Laura; Moser, Michelle; CCNPP3COL Resource; Willingham, Michael Subject: RE: Chapter 9 - Calvert Cliffs Attachments: HLNChapter 9 Alternatives.doc Doug, I deleted that column. Attached is my edited ch9 since it looks like all the changes weren't made or understood. You might want to look at my other comments to see if they were incorporated correctly. I'll have to get back to you on the land use comment. Looks like I'll have to write something or get PNNL to write something. H From: Bruner, Douglas Sent: Tuesday, February 02, 2010 11:55 AM To: Nash, Harriet Cc: Quinn, Laura; Moser, Michelle Subject: FW: Chapter 9 - Calvert Cliffs Harriet, As part of Andy's review of Chapter 9 for the Calvert EIS, he had a couple of comments in Section 9.3 regarding T & E and Land Use. The comments are provided below, and the page numbers are provided for reference on the attached document. If at all possible, it would be appreciated if you could respond COB today. Thanks, Doug 9.3.4.3 Terrestrial and Wetland Resources (page 9-90, line 30, Table 9-9) Table 9-9. State-Listed Terrestrial Species that Occur in Frederick County and May Occur on the Eastalco Site (MDNR 2007b) Scientific Name Common Name Federal Status State Status Bartramia longicauda Upland Sandpiper Endangered Cicindela patruela Green‐patterned Tiger Beetle Endangered Dendroica fusca Blackburnian Warbler Threatened Haliaeetus leucocephalus Bald Eagle Threatened 9.3.5.1 Land Use (page 9-123, line 28) The nearest dedicated land (Federal, State, or Tribal)… 1 Hearing Identifier: CalvertCliffs_Unit3Cola_NonPublic_EX Email Number: 3506 Mail Envelope Properties (7DCCA810A55FEC4B8822CD43063A4942147E80FADB) Subject: RE: Chapter 9 - Calvert Cliffs Sent Date: 2/2/2010 12:14:38 PM Received Date: 2/2/2010 12:15:15 PM From: Nash, Harriet Created By: [email protected] Recipients: "Quinn, Laura" <[email protected]> Tracking Status: None "Moser, Michelle" <[email protected]> Tracking Status: None "CCNPP3COL Resource" <[email protected]> Tracking Status: None "Willingham, Michael" <[email protected]> Tracking Status: None "Bruner, Douglas" <[email protected]> Tracking Status: None Post Office: HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 1962 2/2/2010 12:15:15 PM HLNChapter 9 Alternatives.doc 23226362 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received: Calvert Cliffs 1 9.0 Environmental Impacts of Alternatives 2 This chapter describes alternatives to the proposed NRC action for a combined license (COL) 3 and the U.S. Army Corps of Engineers’ (Corps or USACE) action for a Department of Army (DA) 4 Individual Permit and discusses the environmental impacts of those alternatives. Section 9.1 5 discusses the no-action alternative. Section 9.2 addresses alternative energy sources. Section 6 9.3 reviews UniStar’s region of interest (ROI), its site -selection process, issues that are 7 common to all of the alternative sites, and summarizes and compares the environmental 8 impacts for the proposed and alternative sites and for the no-action alternative. UniStar 9 selected the State of Maryland as its ROI (UniStar 2009a). Section 9.4 examines plant design 10 alternatives. , and Section 9.5 describes onsite alternatives. Section 9.6 lists the references 11 cited in this chapter. Field Code Changed 12 The need to compare the proposed action with alternatives arises from the requirement in 13 Section 102(2)(c)(iii) of the National Environmental Policy Act of 1969, as amended (NEPA) 14 (42 USC 4321) that environmental impact statements (EIS) include an analysis of alternatives to 15 the proposed action. The U.S. Nuclear Regulatory Commission (NRC) implements this 16 comparison through its Environmental Standard Review Plan (ESRP) (NRC 2000a). The 17 environmental impacts of the alternatives are evaluated using the NRC’s three-level standard of 18 significance— – SMALL, MODERATE, or LARGE— – developed using Council on 19 Environmental Quality (CEQ) guidelines (40 CFR 1508.27) and set forth in the footnotes to 20 Table B-1 of Title 10 of the Code of Federal Regulations (CFR) Part 51, Subpart A, Appendix B. 21 The issues evaluated in this chapter are the same as those addressed in the Generic 22 Environmental Impact Statement for License Renewal of Nuclear Plants, NUREG-1437, 23 Volumes 1 and 2 (NRC 1996, 1999a)(a) with the additional issue of environmental justice. The 24 NRC issues a site-specific supplemental EIS, adding to determinations already made in the 25 NUREG-1437, for each proposed action of license renewal for a nuclear plant. Although 26 NUREG-1437 was developed for license renewal, it provides useful information for this review 27 and is referenced throughout this chapter. 28 As part of the evaluation of permit applications subject to Section 404 of the Clean Water Act, 29 the U.S. Army Corps of Engineers (must define the Corps, also abbreviated USACE) overall 30 project purpose in addition to the basic project purpose. The overall project purpose establishes 31 the scope of the alternatives analysis and is required by regulation to apply the criteria set forth 32 inused for evaluating practicable alternatives under the Environmental Protection Agency’s 33 (EPA)EPA’s) Clean Water Act 404(b)(1) gGuidelines (40 CFR Part 230). These guidelines 34 establish criteria that must be met in order for the proposed activities to be permitted pursuant to (a) NUREG-1437 was originally issued in 1996. Addendum 1 to NUREG-1437 was issued in 1999 (NRC 1999a). Hereafter, all references to NUREG-1437 include NUREG-1437 and its Addendum 1. March 2010January 2010 9-1 Draft NUREG-XXXX Environmental Impacts of Alternatives Calvert Cliffs 1 In accordance with the Guidelines and USACE Headquarters guidance (HQUSACE 1989), the 2 overall project purpose must be specific enough to define the applicant’s needs, but not so 3 narrow and restrictive as to preclude a proper evaluation of alternatives. The Corps is 4 responsible for controlling every aspect of the Guidelines analysis. In this regard, defining the 5 overall project purpose is the sole responsibility of the Corps. While generally focusing on the 6 applicant’s statement, the Corps will, in all cases, exercise independent judgment in defining the 7 purpose and need for the project from both the applicant’s alternatives and the public’s 8 perspective [33 CFR Part 325 Appendix B (9)(c)(4); see also 53 FR 3136 (February 3, 1988)]. 9 Section 404, which governs disposal sites for dredged or fill material. Specifically, these 10 guidelines state, in part, that 230.10(a) of the Guidelines requires that “no discharge of dredged 11 or fill material shall be permitted if there is a practicable alternative to the proposed discharge 12 thatwhich would have less adverse impact on the aquatic ecosystem provided , so long as the 13 alternative does not have other significant adverse environmental consequences. An.” Section 14 230.10(a)(2) of the Guidelines states that “an alternative is practicable if it is available and 15 capable of being done after taking into consideration cost, existing technology, and logistics in 16 light of overall project purposes. If it is otherwise a practicable alternative, an area not presently 17 owned by the applicant which could reasonably be obtained, utilized, expanded, or managed in 18 order to fulfill the basic purpose of the proposed activity may be considered if it is otherwise a 19 practicable alternative.” Thus, this analysis is necessary to determine which alternative is the 20 Least Environmentally Damaging Practicable Alternative (LEDPA) that meets the project 21 purpose and need. The UniStar onsite and offsite LEDPA Analysis is included in Appendix J. 22 Where the activity associated with a discharge is proposed for a special aquatic site (as defined 23 in 40 CFR Part 230, Subpart E), and does not require access or proximity to or siting within 24 these types of areas to fulfill its basic project purpose (i.e., the project is not “water dependent”), 25 practicable alternatives that avoid special aquatic sites are presumed to be available, unless 26 clearly demonstrated otherwise [40 CFR 230.10(a)(3)]. 27 9.1 No-Action Alternative 28 For purposes of an NRCapplication for a combined license (COL) application,), the no-action 29 alternative refers to a scenario in which the NRC would deny UniStar’s application for athe COL. 30 The requested by UniStar. Likewise, the Corps could also take no action or deny the Corps 31 permitDA Individual Permit request. Upon such a denial by NRC, the construction and 32 operation of a new nuclear generating unit at the Calvert Cliffs site in accordance with 10 CFR 33 Part 52 would not occur. There would be no environmental impacts at the Calvert Cliffs site 34 associated with not issuing the COL, except thePreconstruction impacts associated with 35 activities not within the definition of construction atin 10 CFR 50.10(a) and 51.4. However, 36 notwithstanding the interest of the Corps, preconstruction impacts are not reviewed as a direct 37 effect of may occur. The no-action alternative would result in the proposed NRC actionfacility Draft NUREG-XXXX 9-2 March 2010January 2010 Calvert Cliffs Environmental Impacts of Alternatives 1 not being built. The predicted environmental impacts from the project would not occur if the 2 facility were not built. If no other power plant were built or electrical power supply strategy 3 implemented to take its place, the electrical capacity to be provided by the project would not 4 become available. At the same time, the benefits (electricity generation) associated with the 5 proposed action would not occur.
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