ML071420019

NUREG-1437, Supp 31, Dfc Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding James A. FitzPatrick Nuclear Power Plant Draft for Comment

ML071420019
Person / Time
Site:	FitzPatrick
Issue date:	06/30/2007
From:	Muir J NRC/NRR/ADRO/DLR
To:
Beltz G
References
NUREG-1437 S31 DFC
Download: ML071420019 (370)

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NUREG-1437 Supplement 31 Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 31 Regarding James A. FitzPatrick Nuclear Power Plant Draft Report for Comment Manuscript Completed: May 2007 Date Published: June 2007

Division of License Renewal Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

COMMENTS ON DRAFT REPORT Any interested party may submit comments on this report for consideration by the NRC staff. Comments may be accompanied by additional relevant information or supporting data. Please specify the report number NUREG-1437, Supplement 31, draft, in your comments, and send them by September 05, 2007 to the following address:

Chief, Rulemaking, Directives and Editing Branch U.S. Nuclear Regulatory Commission Mail Stop T6-D59

Washington, DC 20555-0001

Electronic comments may be submitted to the NRC by the Internet at FitzPatrickEIS@nrc.gov.

For any questions about the material in this report, please contact:

J. Muir OWFN 11-F1 U.S. Nuclear Regulatory Commi ssion Washington, DC 20555-0001

Phone: 301-415-0491 E-mail: JMM7@nrc.gov

June 2007 iii Draft NUREG-1437, Supplement 31 ABSTRACT 1 The U.S. Nuclear Regulatory Commission (NRC) considered the environmental impacts of 2 renewing nuclear power plant operating licenses (OLs) for a 20-year period in its Generic 3 Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, 4 Volumes 1 and 2, and codified the results in Part 51 of Title 10 of the Code of Federal 5 Regulations (10 CFR Part 51). In the GEIS (and its Addendum 1), the NRC staff identifies 6 92 environmental issues and reaches generic conclusions related to environmental impacts for 7 69 of these issues that apply to all plants or to plants with specific design or site characteristics.

8 Additional plant-specific review is required for the remaining 23 issues. These plant-specific 9 reviews are to be included in a supplement to the GEIS.

10 This draft supplemental environmental impact statement (draft SEIS) has been prepared in 11 response to an application submitted to the NRC by Entergy Nuclear FitzPatrick, LLC, and 12 Entergy Nuclear Operations, Inc. (Entergy) to renew the OL for James A. FitzPatrick Nuclear 13 Power Plant (JAFNPP) for an additional 20 years under 10 CFR Part 54. This draft SEIS 14 includes the NRC staff's analysis that considers and weighs the environmental impacts of the 15 proposed action, the environmental impacts of alternatives to the proposed action, and 16 mitigation measures available for reducing or avoiding adverse impacts. It also includes the 17 NRC staff's preliminary recommendation regarding the proposed action.

18 Regarding the 69 issues for which the GEIS reached generic conclusions, neither Entergy nor 19 the NRC staff has identified information that is both new and significant for any issue that 20 applies to JAFNPP. In addition, the NRC staff determined that information provided during the 21 scoping process did not call into question the conclusions in the GEIS. Therefore, the NRC staff 22 concludes that the impacts of renewing the JAFNPP OL would not be greater than impacts 23 identified for these issues in the GEIS. For each of these issues, the NRC staff's conclusion in 24 the GEIS is that the impact is of SMALL(1) significance (except for collective offsite radiological 25 impacts from the fuel cycle and high-level waste and spent fuel, which were not assigned a 26 single significance level).

27 Regarding the remaining 23 issues, those that apply to JAFNPP are addressed in this draft 28 SEIS. For each applicable issue, the NRC staff c oncludes that the significance of the potential 29 environmental impacts of renewal of the OL would be SMALL. The NRC staff also concludes 30 that additional mitigation measures are not likely to be sufficiently beneficial as to be warranted.

31 The NRC staff determined that information provided during the scoping process did not identify 32 any new issue with a significant environmental impact.

33 (1) Environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource.

Abstract Draft NUREG-1437, Supplement 31 iv June 2007 The NRC staff's preliminary recommendation is that the Commission determine that the adverse 1 environmental impacts of license renewal for JAFNPP are not so great that preserving the 2 option of license renewal for energy-planning decision makers would be unreasonable. This 3 recommendation is based on (1) the analysis and findings in the GEIS; (2) the Environmental 4 Report submitted by Entergy; (3) consultation with Federal, State, and local agencies; (4) the 5 NRC staff's own independent review; and (5) the NRC staff's consideration of public comments 6 received during the scoping process.

7 8 9 10 11 12 13 14 15 16 17 Paperwork Reduction Act Statement 18 This NUREG contains information collection requirements that are subject to the 19 Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). These information 20 collections were approved by the Office of Management and Budget, approval numbers 21 3150-0004; 3150-0155; 3150-0014; 3150-0011; 3150-0132; 3150-0151.

22 23 Public Protection Notification 24 The NRC may not conduct or sponsor, and a person is not required to respond to, a 25 request for information or an information collection requirement unless the requesting 26 document displays a currently valid OMB control number.

27 28 June 2007 v Draft NUREG-1437, Supplement 31 Contents Abstract.........................................................................................................................................iii Executive Summary..............................................................................................................

......xiv Abbreviations/Acronyms.............................................................................................................xix 1.0 Introduction........................................................................................................................1-1 1.1 Report Contents ......................................................................................................1-2 1.2 Background..............................................................................................................1-3 1.2.1 Generic Environmental Impact Statement....................................................1-3 1.2.2 License Renewal Evaluation Process .........................................................1-4 1.3 The Proposed Federal Action...................................................................................1-7 1.4 The Purpose and Need for the Proposed Action......................................................1-7 1.5 Compliance and Consultations.................................................................................1-8 1.6 References ..............................................................................................................1

-8 2.0 Description of Nuclear Power Plant and Site and Interaction with the Environment..........................................................................................................2

-1 2.1 Facility and Site Description and Proposed Facility Operation During the Renewal Term ...................................................................................................2-1 2.1.1 External Appearance and Setting.................................................................2-1 2.1.2 Reactor Systems .........................................................................................2-5 2.1.3 Cooling and Auxiliary Water Systems .........................................................

2-5 2.1.4 Radioactive Waste Management Systems and Effluent Control Systems ..........................................................................................2-7 2.1.4.1 Liquid Waste Processing Systems and Effluent Controls ..............2-8 2.1.4.2 Gaseous Waste Processing Systems and Effluent Controls .........2-9 2.1.4.3 Solid Waste Processing ...............................................................2-10 2.1.5 Nonradioactive Waste Systems..................................................................

2-1 0 2.1.5.1 Nonradioactive Waste Streams....................................................2-10 2.1.5.2 Pollution Prevention and Waste Minimization...............................2-13 2.1.6 Facility Operation and Maintenance...........................................................2-13 2.1.7 Power Transmission System......................................................................2-14 2.2 Facility Interaction with the Environment................................................................2-17 2.2.1 Land Use .................................................................................................. 2-17 2.2.2 Water Use...................................................................................................2-17 2.2.3 Water Quality..............................................................................................2-18 Contents Draft NUREG-1437, Supplement 31 vi June 2007 2.2.4 Climate, Meteorology, and Air Quality........................................................2-22 2.2.4.1 Climate..........................................................................................2-22 2.2.4.2 Meteorology .................................................................................2-22 2.2.4.3 Air Quality.....................................................................................2-23 2.2.5 Aquatic Resources ....................................................................................2-23 2.2.6 Terrestrial Resources ................................................................................

2-3 0 2.2.6.1 Terrestrial Resources at the JAFNPP Site....................................

2-3 0 2.2.6.2 Terrestrial Resources in Transmission Corridors..........................2-33 2.2.6.3 Terrestrial Species of Concern.....................................................2-34 2.2.7 Radiological Impacts .................................................................................2-38 2.2.8 Socioeconomic Factors .............................................................................2-39 2.2.8.1 Housing.........................................................................................2-39 2.2.8.2 Public Services............................................................................

2-4 0 2.2.8.3 Offsite Land Use ..........................................................................2-42 2.2.8.4 Visual Aesthetics and Noise.........................................................2-43 2.2.8.5 Demography.................................................................................2-44 2.2.8.6 Economy ......................................................................................2-46 2.2.9 Historic and Archaeological Resources......................................................2-48 2.2.9.1 Cultural Background.....................................................................2-49 2.2.9.2 Historic and Archaeological Resources at JAFNPP.....................2-51 2.2.10 Related Federal Project Activities and Consultations.................................2-53 2.2.10.1 Coastal Zone Management Act....................................................2-53 2.2.10.2 Clean Water Act Section 401 Water Quality Certification ............2-54 2.3 References ................................................................................................................

2-55 3.0 Environmental Impacts of Refurbishment..........................................................................3-1 3.1 References ..............................................................................................................3-4 4.0 Environmental Impacts of Operation .................................................................................4-1 4.1 Cooling System........................................................................................................4-2 4.1.1 Entrainment of Fish and Shellfish in Early Life Stages...............................4-10 4.1.2 Impingement of Fish and Shellfish.............................................................4-15 4.1.3 Heat Shock.................................................................................................4-21 4.2 Transmission Lines................................................................................................4-24 4.2.1 Electromagnetic Fields-Acute Effects......................................................4-28 4.2.2 Electromagnetic Fields-Chronic Effects ..................................................4-29 4.3 Radiological Impacts of Normal Operations ..........................................................4-30 4.4 Socioeconomic Impacts of Plant Operations During the License Renewal Term .......................................................................................................4-32 Contents June 2007 vii Draft NUREG-1437, Supplement 31 4.4.1 Housing Impacts.........................................................................................4-34 4.4.2 Public Services: Public Utility Impacts........................................................4-35 4.4.3 Offsite Land Use.........................................................................................4-36 4.4.3.1 Population-Related Impacts..........................................................4-36 4.4.3.2 Tax-Revenue-Related Impacts.....................................................4-37 4.4.4 Public Services: Transportation Impacts....................................................4-37 4.4.5 Historic and Archaeological Resources......................................................4-37 4.4.6 Environmental Justice ...............................................................................4-39 4.4.6.1 Minority Population in 2000..........................................................4-40 4.4.6.2 Low-Income Population in 2000...................................................4-40 4.4.6.3 Analysis of Impacts ......................................................................4-42 4.5 Groundwater Use and Quality ...............................................................................4-44 4.6 Threatened or Endangered Species......................................................................4-44 4.6.1 Aquatic Species..........................................................................................4-46 4.6.2 Terrestrial Species......................................................................................4-46 4.7 Evaluation of New and Potentially Significant Information on Impacts of Operations During the Renewal Term..................................................4-47 4.8 Cumulative Impacts................................................................................................4-47 4.8.1 Cumulative Impacts on Aquatic Resources................................................4-47 4.8.2 Cumulative Impacts on Terrestrial Resources............................................4-50 4.8.3 Cumulative Impacts on Human Health.......................................................4-52 4.8.3.1 Cumulative Impacts Resulting from Continued Operation of the Transmission Lines ............................................................4-52 4.8.3.2 Cumulative Radiological Impacts..................................................4-52 4.8.4 Cumulative Socioeconomic Impacts...........................................................4-53 4.8.5 Conclusions Regarding Cumulative Impacts..............................................4-53 4.9 Summary of Impacts of Operations During the Renewal Term .............................4-53 4.10 References.............................................................................................................4-5 4 5.0 Environmental Impacts of Postulated Accidents

................................................................5-1 5.1 Postulated Plant Accidents.......................................................................................

5-1 5.1.1 Design-Basis Accidents................................................................................

5-1 5.1.2 Severe Accidents..........................................................................................5-3 5.2 Severe Accident Mitigation Alternatives ..................................................................5-5 5.2.1 Introduction...................................................................................................5-5 5.2.2 Estimate of Risk............................................................................................5-6 5.2.3 Potential Plant Improvements.......................................................................5-8 5.2.4 Evaluation of Risk Reduction and Costs of Improvements...........................5-8 Contents Draft NUREG-1437, Supplement 31 viii June 2007 5.2.5 Cost-Benefit Comparison---------------------.5-9 5.2.6 Conclusions................................................................................................5-10 5.3 References.............................................................................................................5-1 0 6.0 Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management ..........................................................................................................6-1 6.1 The Uranium Fuel Cycle...........................................................................................6-2 6.2 References ..............................................................................................................6

-9 7.0 Environmental Impacts of Decommissioning.....................................................................7-1 7.1 Decommissioning.....................................................................................................7-2 7.2 References...............................................................................................................7

-4 8.0 Environmental Impacts of Alternatives to License Renewal .............................................8-1 8.1 No-Action Alternative................................................................................................8-1 8.2 Alternative Energy Sources......................................................................................8-6 8.2.1 Coal-Fired Generation..................................................................................8-8 8.2.1.1 Once-Through Cooling System.......................................................8-9 8.2.1.2 Closed-Cycle Cooling System......................................................8-18 8.2.2 Natural Gas-Fired Generation ...................................................................8-19 8.2.2.1 Once-Through Cooling System.....................................................8-20 8.2.2.2 Closed-Cycle Cooling System......................................................8-29 8.2.3 Nuclear Power Generation ........................................................................8-29 8.2.3.1 Once-Through Cooling System.....................................................8-31 8.2.3.2 Closed-Cycle Cooling System......................................................8-38 8.2.4 Purchased Electrical Power........................................................................8-38 8.2.5 Other Alternatives.......................................................................................8-39 8.2.5.1 Oil-Fired Generation.....................................................................8-39 8.2.5.2 Wind Power..................................................................................8-39 8.2.5.3 Solar Power..................................................................................8-40 8.2.5.4 Hydropower..................................................................................8-41 8.2.5.5 Geothermal Energy.......................................................................8-42 8.2.5.6 Wood Waste.................................................................................8-42 8.2.5.7 Municipal Solid Waste..................................................................8-42 8.2.5.8 Other Biomass-Derived Fuels.......................................................8-44 8.2.5.9 Fuel Cells......................................................................................8-44 8.2.5.10 Delayed Retirement .....................................................................8-44 8.2.5.11 Utility-Sponsored Conservation....................................................8-45 8.2.6 Combination of Alternatives........................................................................8-46 8.3 Summary of Alternatives Considered ....................................................................8-46 Contents June 2007 ix Draft NUREG-1437, Supplement 31 8.4 References ............................................................................................................8-5 1 9.0 Summary and Conclusions................................................................................................9-1 9.1 Environmental Impacts of the Proposed Action-License Renewal...........................9-4 9.1.1 Unavoidable Adverse Impacts......................................................................9-5 9.1.2 Irreversible or Irretrievable Resource Commitments....................................9-5 9.1.3 Short-Term Use Versus Long-Term Productivity..........................................9-6 9.2 Relative Significance of the Environmental Impacts of License Renewal and Alternatives.........................................................................................9-6

9.3 NRC Staff Conclusion

s and Recommendations.......................................................9-8 9.4 References ..............................................................................................................9

-8 Appendix A Comments Received on the Environmental Review.......................................A-1 Appendix B Contributors to the Supplement.......................................................................B-1 Appendix C Chronology of NRC Staff Environmental Review Correspondence Related to Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc., Application for License Renewal of James A. FitzPatrick Nuclear Power Plant........................................................................................C-1 Appendix D Organizations Contacted.................................................................................D-1 Appendix E Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc., Compliance Status and Consultation Correspondence ..................................E-1 Appendix F GEIS Environmental Issues Not Applicable to James A. FitzPatrick Nuclear Power Plant.........................................................................................F-1 Appendix G NRC Staff Evaluation of Severe Accident Mitigation Alternatives for James A. FitzPatrick Nuclear Power Plant.................................................G-1 Figures Draft NUREG-1437, Supplement 31 x June 2007 Figures Figure 2-1. Location of JAFNPP, 50-mi Region .......................................................................2-2 Figure 2-2. Location of JAFNPP, 6-mi Region .........................................................................2-3 Figure 2-3. JAFNPP Approximate Site Boundary.....................................................................2-4 Figure 2-4. JAFNPP Transmission Lines................................................................................2-15 Figure 4-1. Minority Block Groups in 2000 within a 50-mi Radius of JAFNPP.......................4-41 Figure 4-2. Low-Income Block Groups within a 50-mi Radius of JAFNPP ............................4-43 Tables June 2007 xi Draft NUREG-1437, Supplement 31 Tables Table 2-1. JAFNPP Transmission Lines, Substations, and Corridors...................................2-15 Table 2-2. Selected Water Quality Parameters of Lake Ontario...........................................2-20 Table 2-3. Aquatic Species Listed as Endangered, Threatened, or a Species of Special Concern by New York State, Potentially Occurring in Oswego and Onondaga Counties......................................................................................2-29 Table 2-4. Federally Listed and New York State-Listed Terrestrial Species Potentially Occurring in the Vicinity of JAFNPP and in Associated Transmission Line Corridors................................................................................2-34 Table 2-5. JAFNPP Permanent Employee Residence by County in 2006............................2-39 Table 2-6. Number of Occupied, Vacant, and Total Housing Units in Oswego and Onondaga Counties, New York, in 2000 and 2005.......................................2-40 Table 2-7. Major Public Water Supply Systems in Oswego County, Average Daily Use, and Maximum Daily Capacity.............................................................2-41 Table 2-8. Land Use in Oswego and Onondaga Counties....................................................2-43 Table 2-9. Population Growth in Oswego and Onondaga Counties, New York, from 1970 to 2000 and Projected for 2010 and 2020...........................................2-45 Table 2-10. Major Employers in Oswego County in 2006 ......................................................2-47 Table 2-11. Oswego County, Town of Scriba, and Mexico Central Schools Tax Revenues, 2002 to 2005; JAFNPP Property Tax, 2002 to 2005; and JAFNPP Property Tax as a Percentage of Tax Revenues...................................2-48 Table 3-1. Category 1 Issues for Refurbishment Evaluation...................................................3-2 Table 3-2. Category 2 Issues for Refurbishment Evaluation...................................................3-3 Table 4-1. Category 1 Issues Applicable to the Operation of the JAFNPP Cooling System During the Renewal Term ...........................................................4-3 Table 4-2. Category 2 Issues Applicable to the Operation of the JAFNPP Cooling System During the Renewal Term .........................................................4-10 Table 4-3. Results of Impingement Monitoring at JAFNPP from 1976 through 1997 (Corrected for Flow and Traveling Screen Efficiencies)..............................4-17 Table 4-4. Results of Impingement Monitoring at JAFNPP, 2004 (Corrected for Flow and Traveling Screen Efficiencies)..............................................................4-19 Table 4-5. Category 1 Issues Applicable to the JAFNPP Transmission Lines During the Renewal Term ...................................................................................4-25 Contents Draft NUREG-1437, Supplement 31 xii June 2007 Table 4-6. Category 2 and Uncategorized Issues Applicable to the JAFNPP Transmission Lines During the Renewal Term....................................................4-28 Table 4-7. Category 1 Issues Applicable to Radiological Impacts of Normal Operations During the Renewal Term .................................................................4-31 Table 4-8. Category 1 Issues Applicable to Socioeconomics During the Renewal Term......................................................................................................4-32 Table 4-9. Category 2 Issues Applicable to Socioeconomics and Environmental Justice During the Renewal Term .......................................................................4-34 Table 4-10. Category 2 Issue Applicable to Threatened or Endangered Species During the Renewal Term ...................................................................................4-45 Table 5-1. Category 1 Issues Applicable to Postulated Accidents During the Renewal Term .......................................................................................................5-3 Table 5-2. Category 2 Issues Applicable to Postulated Accidents During the Renewal Term .......................................................................................................

5-5 Table 5-3. JAFNPP Core Damage Frequency........................................................................5-7 Table 5-4. Breakdown of Population Dose by Containment Release Mode............................

5-8 Table 6-1. Category 1 Issues Applicable to the Uranium Fuel Cycle and Solid Waste Management During the Renewal Term ....................................................6-2 Table 7-1. Category 1 Issues Applicable to the Decommissioning of JAFNPP Following the Renewal Term..................................................................................7-2 Table 8-1. Summary of Environmental Impacts of the No-Action Alternative..........................8-3 Table 8-2. Summary of Environmental Impacts of Coal-Fired Generation at an Alternate Site Using Once-Through Cooling........................................................8-10 Table 8-3. Summary of Environmental Impacts of Coal-Fired Generation at an Alternate Site with Closed-Cycle Cooling ............................................................8-19 Table 8-4. Summary of Environmental Impacts of Natural Gas-Fired Generation at the JAFNPP Site and an Alternate Site Using Once-Through Cooling.................................................................................................................8-21 Table 8-5. Summary of Environmental Impacts of Natural Gas-Fired Generation at Either the JAFNPP Site or an Alternate Site with Closed-Cycle Cooling.................................................................................................................8-30 Table 8-6. Summary of Environmental Impacts of New Nuclear Power Generation at the JAFNPP Site and an Alternate Site Using Once-Through Cooling...................................................................................................8-32 Table 8-7. Summary of Environmental Impacts of a New Nuclear Power Plant Sited at an Alternate Site with Closed-Cycle Cooling ..........................................8-38 Table 8-8. Summary of Environmental Impacts of an Assumed Combination of Generation-Does Not Include Impacts from Purchased Generation Once-Through Cooling Alternative.......................................................................8-47 Contents June 2007 xiii Draft NUREG-1437, Supplement 31 Table 9-1. Summary of Environmental Significance of License Renewal, the No-Action Alternative, and Alternative Methods of Power Generation.........................9-7 Table A-1. Individuals Providing Comments During Scoping Comment Period.....................A-3 Table E-1. Consultation Correspondence ..............................................................................E-1 Table E-2. Federal, State, Local, and Regional Licenses, Permits, and Other Approvals for the James A. FitzPatrick Nuclear Power Plant (JAFNPP)..............E-2 Table F-1. GEIS Environmental Issues Not Applicable to James A. FitzPatrick Nuclear Power Plant...............................................................................................F-1 Table G-1. JAFNPP Core Damage Frequency for Internal Events.........................................G-3 Table G-2. Breakdown of Population Dose by Containment Release Mode...........................G-4 Table G-3. JAFNPP PSA Historical Summary........................................................................G-6Table G-4. Fire Areas and Their Contribution to the Fire CDF..............................................G-10 Table G-5. SAMA Cost/Benefit Screening Analysis for JAFNPP..........................................G-21 June 2007 xiv Draft NUREG-1437, Supplement 31 EXECUTIVE

SUMMARY

1 By letter dated July 31, 2006, Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear 2 Operations, Inc. (Entergy) submitted an application to the U.S. Nuclear Regulatory Commission 3 (NRC) to renew the operating license (OL) for the James A. FitzPatrick Nuclear Power Plant 4 (JAFNPP) for an additional 20-year period. If the OL is renewed, State regulatory agencies and 5 Entergy will ultimately decide whether the plant will continue to operate based on factors such 6 as the need for power or other matters within the State's jurisdiction or the purview of the 7 owners. If the OL is not renewed, then the plant must be shut down on or before the expiration 8 date of the current OL, which is October 17, 2014.

9 The NRC has implemented Section 102 of the National Environmental Policy Act (NEPA), 10 Title 42, Section 4321, of the United States Code (42 USC 4321) in Part 51 of Title 10 of the 11 Code of Federal Regulations (10 CFR Part 51). In 10 CFR 51.20(b)(2), the Commission 12 requires preparation of an Environmental Impact Statement (EIS) or a supplement to an EIS for 13 renewal of a reactor OL. In addition, 10 CFR 51.95(c) states that the EIS prepared at the OL 14 renewal stage will be a supplement to the Generic Environmental Impact Statement for License 15 Renewal of Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2.(a) 16 Upon acceptance of the Entergy application, the NRC began the environmental review process 17 described in 10 CFR Part 51 by publishing a Notice of Intent to prepare an EIS and conduct 18 scoping. The NRC staff held public scoping meetings on October 12, 2006, in Oswego, New 19 York, and conducted a site audit at JAFNPP on December 5 and 6, 2006. In the preparation of 20 this draft supplemental environmental impact st atement (SEIS) for JAFNPP, the NRC staff 21 reviewed the Entergy Environmental Report (ER) and compared it to the GEIS, consulted with 22 other agencies, conducted an independent review of the issues following the guidance set forth 23 in NUREG-1555, Supplement 1, Standard Review Plans for Environmental Reviews for Nuclear 24 Power Plants, Supplement 1: Operating License Renewal, and considered the public 25 comments received during the scoping process. The public comments received during the 26 scoping process that were considered to be within the scope of the environmental review are 27 provided in Appendix A of this draft SEIS.

28 The NRC staff will hold two public meetings in Oswego, New York, in August 2007, to describe 29 the preliminary results of the NRC environmental review, to answer questions, and to provide 30 members of the public with information to assist them in formulating comments on this draft 31 (a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" include the GEIS and its Addendum 1.

Executive Summary Draft NUREG-1437, Supplement 31 xv June 2007 SEIS. When the comment period ends, the NRC staff will consider and address all of the 1 comments received. These comments will be addressed in Appendix A of the final SEIS.

2 This draft SEIS includes the NRC staff's prelim inary analysis that considers and weighs the 3 environmental effects of the proposed action, the environmental impacts of alternatives to the 4 proposed action, and mitigation measures for reducing or avoiding adverse effects. It also 5 includes the NRC staff's preliminary recommendation regarding the proposed action.

6 The Commission has adopted the following statement of purpose and need for license renewal 7 from the GEIS:

8 The purpose and need for the proposed action (renewal of an operating license) 9 is to provide an option that allows for power generation capability beyond the 10 term of a current nuclear power plant oper ating license to meet future system 11 generating needs, as such needs may be determined by State, utility, and, where 12 authorized, Federal (other than NRC) decision makers.

13 The evaluation criterion for the NRC staff's environmental review, as defined in 10 CFR 14 51.95(c)(4) and the GEIS, is to determine 15 ... whether or not the adverse environmental impacts of license renewal are so 16 great that preserving the option of license renewal for energy planning decision 17 makers would be unreasonable.

18 Both the statement of purpose and need and the evaluation criterion implicitly acknowledge that 19 there are factors, in addition to license renewal, that will ultimately determine whether an 20 existing nuclear power plant continues to operate beyond the period of the current OL.

21 NRC regulations (10 CFR 51.95[c][2]) contain the following statement regarding the content of 22 SEISs prepared at the license renewal stage:

23 The supplemental environmental impact statement for license renewal is not 24 required to include discussion of need for power or the economic costs and 25 economic benefits of the proposed action or of alternatives to the proposed 26 action except insofar as such benefits and costs are either essential for a 27 determination regarding the inclusion of an alternative in the range of alternatives 28 considered or relevant to mitigation. In addition, the supplemental environmental 29 impact statement prepared at the license renewal stage need not discuss other 30 issues not related to the environmental effects of the proposed action and the 31 alternatives, or any aspect of the storage of spent fuel for the facility within the 32 scope of the generic determination in § 51.23(a) ["Temporary storage of spent 33 fuel after cessation of reactor operation-generic determination of no significant 34 environmental impact"] and in accordance with § 51.23(b).

35 Executive Summary June 2007 xvi Draft NUREG-1437, Supplement 31 The GEIS contains the results of a systematic evaluation of the consequences of renewing an OL 1 and operating a nuclear power plant for an additional 20 years. It evaluates 92 environmental 2 issues using the NRC's three-level standard of significance-SMALL, MODERATE, or LARGE-3 developed using the Council on Environmental Quality guidelines. The following definitions of the 4 three significance levels are set forth in footnotes to Table B-1 of 10 CFR Part 51, Subpart A, 5 Appendix B:

6 SMALL-Environmental effects are not detectable or are so minor that they will 7 neither destabilize nor noticeably alter any important attribute of the resource.

8 MODERATE-Environmental effects are sufficient to alter noticeably, but not to 9 destabilize, important attributes of the resource.

10 LARGE-Environmental effects are clearly noticeable and are sufficient to 11 destabilize important attributes of the resource.

12 For 69 of the 92 issues considered in the GEIS, the analysis in the GEIS reached the following 13 conclusions:

14 (1) The environmental impacts associated with the issue have been determined to apply either 15 to all plants or, for some issues, to plants having a specific type of cooling system or other 16 specified plant or site characteristics.

17 (2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to the 18 impacts (except for collective offsite radiological impacts from the fuel cycle and from high-19 level waste and spent fuel disposal).

20 (3) Mitigation of adverse impacts associated with the issue has been considered in the analysis, 21 and it has been determined that additional plant-specific mitigation measures are not likely 22 to be sufficiently beneficial to warrant implementation.

23 These 69 issues were identified in the GEIS as Category 1 issues. In the absence of new and 24 significant information, the NRC staff relied on conclusions in the GEIS for issues designated as 25 Category 1 in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B.

26 Of the 23 issues that do not meet the criteria set forth above, 21 are classified as Category 2 27 issues requiring analysis in a plant-specific supplement to the GEIS. The remaining two issues, 28 environmental justice and chronic effects of electromagnetic fields, were not categorized.

29 Environmental justice was not evaluated on a generic basis and must be addressed in a plant-30 specific supplement to the GEIS. Information on the chronic effects of electromagnetic fields 31 was not conclusive at the time the GEIS was prepared.

32 This draft SEIS documents the NRC staff's c onsideration of all 92 environmental issues 33 identified in the GEIS. The NRC staff consider ed the environmental impacts associated with 34 Executive Summary Draft NUREG-1437, Supplement 31 xvii June 2007 alternatives to license renewal and compared the environmental impacts of license renewal and 1 the alternatives. The alternatives to license renewal that were considered include the no-action 2 alternative (not renewing the OL for JAFNPP) and alternative methods of power generation.

3 Based on projections made by the U.S. Department of Energy's Energy Information 4 Administration (DOE/EIA), gas- and coal-fired generation appear to be the most likely power-5 generation alternatives if the power from JAFNPP is replaced. These alternatives are evaluated 6 assuming that the replacement power generation plant is located at either the JAFNPP site or 7 some other unspecified alternate location.

8 Entergy and the NRC staff have established independent processes for identifying and 9 evaluating the significance of any new inform ation on the environmental impacts of license 10 renewal. Neither Entergy nor the NRC staff has identified information that is both new and 11 significant related to Category 1 issues that would call into question the conclusions in the 12 GEIS. Similarly, neither the scoping process nor the NRC staff has identified any new issue 13 applicable to JAFNPP that has a significant environmental impact. Therefore, the NRC staff 14 relies upon the conclusions of the GEIS for all of the Category 1 issues that are applicable to 15 JAFNPP. 16 Entergy's license renewal application presents an analysis of the Category 2 issues plus 17 environmental justice and chronic effects from electromagnetic fields. The NRC staff has 18 reviewed the Entergy analysis for each issue and has conducted an independent review of each 19 issue. Six Category 2 issues are not applicable because they are related to plant design 20 features or site characteristics not found at JAFNPP. Four Category 2 issues are not discussed 21 in this draft SEIS because they are specifically related to refurbishment. Entergy has stated that 22 its evaluation of structures and components, as required by 10 CFR 54.21, did not identify any 23 major plant refurbishment activities or modifications as necessary to support the continued 24 operation of JAFNPP for the license renewal period. In addition, any replacement of 25 components or additional inspection activities are within the bounds of normal plant operation 26 and are not expected to affect the environment outside of the bounds of the plant operations 27 evaluated in the U.S. Atomic Energy Commission's 1973 Final Environmental Statement 28 Related to Operation of James A. FitzPatrick Nuclear Power Plant.

29 Eleven Category 2 issues related to operational impacts and postulated accidents during the 30 renewal term, as well as environmental justice and chronic effects of electromagnetic fields, are 31 discussed in detail in this draft SEIS. Four of the Category 2 issues and environmental justice 32 apply to both refurbishment and to operation during the renewal term and are only discussed in 33 this draft SEIS in relation to operation during the renewal term. For all 11 Category 2 issues 34 and environmental justice, the NRC staff concludes that the potential environmental effects are 35 of SMALL significance in the context of the standards set forth in the GEIS. In addition, the 36 NRC staff determined that appropriate Federal h ealth agencies have not reached a consensus 37 on the existence of chronic adverse effects from electromagnetic fields. Therefore, no further 38 evaluation of this issue is required. For severe accident mitigation alternatives (SAMAs), the 39 NRC staff concludes that a reasonable, compr ehensive effort was made to identify and evaluate 40 Executive Summary June 2007

xviii Draft NUREG-1437, Supplement 31 SAMAs. Based on its review of the SAMAs for JAFNPP and the plant improvements already 1 made, the NRC staff concludes that none of the candidate SAMAs is cost-beneficial.

2 Mitigation measures were considered for each Ca tegory 2 issue. Current measures to mitigate 3 the environmental impacts of plant operation were found to be adequate, and no additional 4 mitigation measures were deemed sufficiently beneficial to be warranted.

5 Cumulative impacts of past, present, and reasonably foreseeable future actions were 6 considered, regardless of what agency (Federal or non-Federal) or person undertakes such 7 other actions. For purposes of this analysis, where the JAFNPP license renewal impacts are 8 deemed to be SMALL, the NRC staff concluded that these impacts would not result in significant 9 cumulative impacts on potentially affected resources.

10 If the JAFNPP OL is not renewed and the plant ceases operation on or before the expiration of 11 its current OL, then the adverse impacts of likely alternatives would not necessarily be smaller 12 than those associated with continued operation of JAFNPP. The impacts may be greater in 13 some areas, depending on the alternatives selected.

14 The preliminary recommendation of the NRC staff is that the Commission determine that the 15 adverse environmental impacts of license renewal for JAFNPP are not so great that preserving 16 the option of license renewal for energy planning decision makers would be unreasonable. This 17 recommendation is based on (1) the analysis and findings in the GEIS; (2) the ER submitted by 18 Entergy; (3) consultation with other Federal, State, and local agencies; (4) the NRC staff's own 19 independent review; and (5) the NRC staff's consi deration of public comments received during 20 the scoping process.

21 Draft NUREG-1437, Supplement 31 x i xJune 2007 ABBREVIATIONS/ACRONYMS 1 T temperature difference 2 ° degree 3 ac acre(s) 4 AC alternating current 5 ACC averted cleanup and decontamination costs 6 AEC Atomic Energy Commission 7 ALARA as low as reasonably achievable 8 AOC averted offsite property damage costs 9 AOE averted occupational exposure costs 10 AOSC averted onsite costs 11 ATWS Anticipated transient without scram 12 13 BACT Best available control technology 14 BTU British thermal unit(s) 15 BWR boiling-water reactor 16 BWROG boiling-water reactor owner group 17 18 C Celsius 19 CDF core damage frequency 20 CEQ Council on Environmental Quality 21 CET containment event tree 22 CFR Code of Federal Regulations 23 Ci curie(s) 24 CMP coastal management program 25 COE cost of enhancement 26 CRD control rod drive 27 CST condensate storage tank 28 CWA Clean Water Act 29 CWD chronic wasting disease 30 CZMA Coastal Zone Management Act 31 32 DC direct current 33 DCH direct containment heating 34 DBA design-basis accident 35 DSM demand-side management 36 DOC U.S. Department of Commerce 37 June 2007 xx Draft NUREG-1437, Supplement 31 DOE U.S. Department of Energy 1 2 ECCS emergency core cooling system 3 EDG emergency diesel generator 4 EIA Energy Information Administration 5 EIS environmental impact statement 6 Entergy Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc.

7 EPA U.S. Environmental Protection Agency 8 EPRI Electric Power Research Institute 9 EPZ emergency planning zone 10 ER environmental report 11 ESA Endangered Species Act 12 ESW emergency service water 13 ETE evacuation time study 14 15 F Fahrenheit 16 FDS fish deterrence system 17 FES Final Environmental Statement 18 FSAR Final Safety Analysis Report 19 ft foot (feet) 20 ft 3 cubic foot (feet) 21 ft/m foot (feet) per minute 22 ft/s feet (feet) per second 23 FWS U.S. Fish and Wildlife Service 24 25 gal gallon(s) 26 GE General Electric 27 GEIS generic environmental impact statement 28 GLFC Great Lakes Fishery Commission 29 GLWQA Great Lakes Water Quality Agreement 30 gpd gallon(s) per day 31 gpm gallons per minute 32 33 ha hectare(s) 34 HCLPF high confidence low probability of failure 35 HLW high-level waste 36 HPCI high pressure coolant injection 37 38 I&C instrumentation and control 39 Draft NUREG-1437, Supplement 31 xxi June 2007 IJC International Joint Commission 1 IGLD International Great Lakes Datum 2 in. inch(es) 3 IPE individual plant examination 4 IPEEE individual plant examination of external events 5 ISFSI independent spent fuel storage installation 6 ISLOCA interfacing system loss of coolant accident 7 ISLRBC International St. Lawrence River Board of Control 8 9 J Joule 10 JAFNPP James A. FitzPatrick Nuclear Power Plant 11 12 km kilometer(s) 13 Kr krypton 14 kt(s) knot(s) 15 kV kilovolt 16 kWh kilowatt-hour 17 18 L liter 19 LAER Lowest achievable emissions rate 20 lb pound(s) 21 LERF large early release frequency 22 LLMW low-level mixed waste 23 LOCA loss of coolant accident 24 LOSP loss of offsite power 25 LPCI low pressure coolant injection 26 27 m meter(s) 28 mA milli-ampere(s) 29 MAAP Modular Accident Analysis Program 30 MACCS2 MELCOR Accident Consequence Code System 2 31 m/s meter(s) per second 32 m 3 cubic meter(s) 33 mg/L milligram(s) per liter 34 mi mile(s) 35 min minute(s) 36 ml milliliter 37 mph mile(s) per hour 38 mrem millirem 39 June 2007 xxii Draft NUREG-1437, Supplement 31 m/s meter per second 1 MSA metropolitan statistical area 2 MSIV main steam isolation valvue 3 mSv milliSievert 4 MT metric ton(s) 5 MTHM metric ton of heavy metal 6 MWB Metropolitan Water Board 7 MWd/MTU megawatt days per metric ton of uranium 8 MWe megawatts-electric 9 MWh megawatt hour 10 MWt megawatts-thermal 11 12 NAS National Academy of Sciences 13 NEPA National Environmental Policy Act of 1969 14 NESC National Electrical Safety Code 15 ng/J nanogram(s) per Joule 16 NHPA National Historic Preservation Act of 1966 17 NIEHS National Institute of Environmental Health Sciences 18 NMPNS Nine Mile Point Nuclear Station 19 NO x nitrogen oxides 20 NOAA National Oceanic and Atmospheric Administration 21 NPDES National Pollutant Discharge Elimination System 22 NRC U.S. Nuclear Regulatory Commission 23 NYCRR New York State Codes Rules and Regulations 24 NYISO New York Independent System Operator 25 NYNHP New York Natural Heritage Program 26 NYPA New York Power Authority 27 NYPSC New York Public Service Commission 28 NYSDEC New York State Department of Environmental Conservation 29 NYSDOS New York State Department of State 30 NYSERDA New York State Energy Research and Development Authority 31 NYSHPO New York State Office of Parks, Recreation, and Historic Preservation 32 33 OCWA Onondaga County Water Authority 34 ODCM Offsite Dose Calculation Manual 35 OL operating license 36 OMNR Ontario Ministry of Natural Resources 37 OWS Oswego Water System 38 39 Draft NUREG-1437, Supplement 31 xxi iiJune 2007 PBT persistent, bioaccumulative, and toxic 1 PCB polychlorinated biphenyls 2 PCS power conversion system 3 PDS plant damage status 4 PGA peak ground acceleration 5 PM 10 particulate matter with an aerodynamic diameter less than or equal to 10 microns 6 ppm parts per million 7 PSA probabilistic safety assessment 8 PSD prevention of significant deterioration 9 10 radwaste radioactive waste 11 RAI request for additional information 12 rem Roentgen Equivalent Man 13 RCIC reactor core isolation cooling 14 RCRA Resource Conservation and Recovery Act 15 REMP Radiological Environmental Monitoring Program 16 RHR residual heat removal 17 RHRSW residual heat removal service water 18 ROW right-of-way 19 RPC replacement cost 20 RRW risk reduction worth 21 22 SAMA severe accident mitigation alternative 23 SAR Safety Analysis Report 24 SBO station blackout 25 SCOL Salmonid Communities in Oligotrophic Lakes 26 SCR selective catalytic reduction 27 SEIS supplemental environmental impact statement 28 SER Safety Evaluation Report 29 SHPO State Historic Preservation Office 30 SLCS Standby Liquid Control System 31 SMA seismic margin assessment 32 SO x sulfur oxides 33 SPDES State Pollutant Discharge Elimination System 34 SQUG Seismic Qualification User Group 35 SRV safety relief valves 36 SUNY State University of New York 37 Sv Sievert 38 39 June 2007 xx i vDraft NUREG-1437, Supplement 31 TMDL total maximum daily load 1 TRC total residual chlorine 2 TSCA Toxic Substance Control Act 3 TSDF Treatment, Storage, or Discharge Facility 4 5 USACE U.S. Army Corps of Engineers 6 USC United States Code 7 USCB U.S. Census Bureau 8 USGS U.S. Geological Survey 9 USI Unresolved Safety Issue 10 11 VOC volatile organic compound 12 13 Xe xenon 14 June 2007 1-1 Draft NUREG-1437, Supplement 31

1.0 INTRODUCTION

1 Under the U.S. Nuclear Regulatory Commission's (NRC's) environmental protection regulations 2 in Part 51 of Title 10 of the Code of Federal Regulations (10 CFR Part 51), which implement the 3 National Environmental Policy Act of 1969 (NEPA), renewal of a nuclear power plant operating 4 license (OL) requires the preparation of an environmental impact statement (EIS). In preparing 5 the EIS, the NRC staff is required first to issue the statement in draft form for public comment 6 and then issue a final statement after considering public comments on the draft. To support the 7 preparation of the EIS, the NRC staff has prepared a Generic Environmental Impact Statement 8 for License Renewal of Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2 (NRC 1996; 9 1999).(1) The GEIS is intended to (1) provide an understanding of the types and severity of 10 environmental impacts that may occur as a result of license renewal of nuclear power plants 11 under 10 CFR Part 54, (2) identify and assess the impacts that are expected to be generic to 12 license renewal, and (3) support 10 CFR Part 51 to define the number and scope of issues that 13 need to be addressed by the applicants in plant-by-plant license renewal proceedings. Use of 14 the GEIS guides the preparation of complete plant-specific information related to the OL 15 renewal process.

16 Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy) operate the 17 James A. FitzPatrick Nuclear Power Plant (JAFNPP) in northern New York under OL DPR-59, 18 which was issued by the NRC. This OL will expi re in October 2014. By letter dated July 31, 19 2006, Entergy submitted an application to the NRC to renew the JAFNPP OL for an additional 20 20 years under 10 CFR Part 54. Entergy is a licensee for the purposes of its current OL and an 21 applicant for the renewal of the OL. Pursuant to 10 CFR 54.23 and 51.53(c), Entergy submitted 22 an Environmental Report (ER; Entergy 2006b), in which Entergy analyzed the environmental 23 impacts associated with the proposed license renewal action, considered alternatives to the 24 proposed action, and evaluated mitigation measures for reducing adverse environmental 25 effects. 26 This report is the plant-specific supplement to the GEIS (the supplemental EIS [SEIS]) for the 27 Entergy license renewal application. This draft SEIS is a supplement to the GEIS because it 28 relies, in part, on the findings of the GEIS. The NRC staff will also prepare a separate safety 29 evaluation report in accordance with 10 CFR Part 54.

30 (1) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" include the GEIS and its Addendum 1.

Introduction Draft NUREG-1437, Supplement 31 1-2 June 2007 1.1 Report Contents 1 The following sections of this introduction (1) describe the background for the preparation of this 2 draft SEIS, including the development of the GEIS and the process used by the NRC staff to 3 assess the environmental impacts associated with plant operations during license renewal; 4 (2) describe the proposed Federal action to renew the JAFNPP OL; (3) discuss the purpose and 5 need for the proposed action; and (4) present the status of Entergy's compliance with 6 environmental quality standards and requirement s that have been imposed by Federal, State, 7 regional, and local agencies that are responsible for environmental protection.

8 The ensuing chapters of this draft SEIS closely parallel the contents and organization of the 9 GEIS. Chapter 2 describes the site, power plant, and interactions of the plant with the 10 environment. Chapters 3 and 4, respectively, discuss the potential environmental impacts of 11 plant refurbishment and plant operation during the renewal term. Chapter 5 contains an 12 evaluation of potential environmental impacts of plant accidents and includes consideration of 13 severe accident mitigation alternatives. Chapter 6 discusses the uranium fuel cycle and solid 14 waste management. Chapter 7 discusses decommissioning, and Chapter 8 discusses 15 alternatives to license renewal. Finally, Chapter 9 summarizes the findings of the preceding 16 chapters and draws conclusions about the adverse impacts that cannot be avoided, the 17 relationship between short-term uses of man's environment and the maintenance and 18 enhancement of long-term productivity, and the irreversible or irretrievable commitment of 19 resources. Chapter 9 also presents the NRC staff's preliminary recommendation with respect to 20 the proposed license renewal action.

21 Additional information is included in appendixes. Appendix A contains public comments related 22 to the environmental review for license renewal and NRC staff responses to those comments.

23 Appendixes B through G, respectively, list the following:

24 The preparers of the supplement, 25 The chronology of NRC staff's environmental review correspondence related to this draft 26 SEIS, 27 The organizations contacted during the development of this draft SEIS, 28 Entergy's compliance status in Table E-1 (this appendix also contains copies of 29 consultation correspondence prepared and sent during the evaluation process), 30 GEIS environmental issues that are not applicable to JAFNPP, and 31 Severe accident mitigation alternatives (SAMAs).

32 Introduction June 2007 1-3 Draft NUREG-1437, Supplement 31 1.2 Background 1 Use of the GEIS, which examines the possible environmental impacts that could occur as a 2 result of renewing individual nuclear power plant OLs under 10 CFR Part 54, and the 3 established license renewal evaluation process support the thorough evaluation of the impacts 4 of renewal of OLs.

5 1.2.1 Generic Environmental Impact Statement 6 The NRC initiated a generic assessment of the environmental impacts associated with the 7 license renewal term to improve the efficiency of the license renewal process by documenting 8 the assessment results and codifying the results in the Commission's regulations. This 9 assessment is provided in the GEIS, which serves as the principal reference for all nuclear 10 power plant license renewal EISs.

11 The GEIS documents the results of the systematic approach that was taken to evaluate the 12 environmental consequences of renewing the licenses of individual nuclear power plants and 13 operating them for an additional 20 years. For each potential environmental issue, the GEIS 14 (1) describes the activity that affects the environment, (2) identifies the population or resource 15 that is affected, (3) assesses the nature and magnitude of the impact on the affected population 16 or resource, (4) characterizes the significance of the effect for both beneficial and adverse 17 effects, (5) determines whether the results of the analysis apply to all plants, and (6) considers 18 whether additional mitigation measures would be warranted for impacts that would have the 19 same significance level for all plants.

20 The NRC's standard of significance for impacts was established using the Council on 21 Environmental Quality (CEQ) terminology for "significantly" (40 CFR 1508.27, which requires 22 consideration of both "context" and "intensity"). Using the CEQ terminology, the NRC 23 established three significance levels-SMALL, MODERATE, or LARGE. The definitions of the 24 three significance levels are set forth in the footnotes to Table B-1 of 10 CFR Part 51, 25 Subpart A, Appendix B, as follows:

26 SMALL - Environmental effects are not detectable or are so minor that they will neither 27 destabilize nor noticeably alter any important attribute of the resource.

28 MODERATE - Environmental effects are sufficient to alter noticeably, but not to destabilize, 29 important attributes of the resource.

30 LARGE - Environmental effects are clearly noticeable and are sufficient to destabilize 31 important attributes of the resource.

32 The GEIS assigns a significance level to each environmental issue, assuming that ongoing 33 mitigation measures would continue.

34 Introduction Draft NUREG-1437, Supplement 31 1-4 June 2007 The GEIS includes a determination of whether the analysis of the environmental issue could be 1 applied to all plants and whether additional mitigation measures would be warranted. Issues 2 are assigned a Category 1 or a Category 2 designation. As set forth in the GEIS, Category 1 3 issues are those that meet all of the following criteria:

4 (1) The environmental impacts associated wi th the issue have been determined to apply 5 either to all plants or, for some issues, to plants having a specific type of cooling system 6 or other specified plant or site characteristics.

7 (2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 8 the impacts (except for collective offsite radiological impacts from the fuel cycle and from 9 high-level waste and spent fuel disposal).

10 (3) Mitigation of adverse impacts associated with the issue has been considered in the 11 analysis, and it has been determined that additional plant-specific mitigation measures 12 are likely not to be sufficiently beneficial to warrant implementation.

13 For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 14 required in this draft SEIS unless new and significant information is identified.

15 Category 2 issues are those that do not meet one or more of the criteria of Category 1, and 16 therefore, additional plant-specific review for these issues is required.

17 In the GEIS, the NRC staff assessed 92 environmental issues and determined that 69 qualified 18 as Category 1 issues, 21 qualified as Category 2 issues, and 2 issues were not categorized.

19 The two uncategorized issues are environmental justice and chronic effects of electromagnetic 20 fields. Environmental justice was not evaluated on a generic basis in the GEIS and must be 21 addressed in the draft SEIS. Information on the chronic effects of electromagnetic fields was 22 not conclusive at the time the GEIS was prepared.

23 Of the 92 issues, 11 are related only to refurbishment, 6 are related only to decommissioning, 24 67 apply only to operation during the renewal term, and 8 apply to both refurbishment and 25 operation during the renewal term. A summary of the findings for all 92 issues in the GEIS is 26 codified in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B.

27 1.2.2 License Renewal Evaluation Process 28 An applicant seeking to renew its OL is required to submit an ER as part of its application. The 29 license renewal evaluation process involves careful review of the applicant's ER and assurance 30 that all new and potentially significant informati on not already addressed in or available during 31 the GEIS evaluation is identified, reviewed, and assessed to verify the environmental impacts of 32 the proposed license renewal.

33 Introduction June 2007 1-5 Draft NUREG-1437, Supplement 31 In accordance with 10 CFR 51.53(c)(2) and (3), the ER submitted by the applicant must 1 Provide an analysis of the Category 2 issues in Table B-1 of 10 CFR Part 51, Subpart A, 2 Appendix B, in accordance with 10 CFR 51.53(c)(3)(ii), and 3 Discuss actions to mitigate any adverse impacts associated with the proposed action 4 and environmental impacts of alternatives to the proposed action.

5 In accordance with 10 CFR 51.53(c)(2), the ER does not need to 6 Consider the economic benefits and costs of the proposed action and alternatives to the 7 proposed action except insofar as such benefits and costs are either (1) essential for 8 making a determination regarding the inclusion of an alternative in the range of 9 alternatives considered, or (2) relevant to mitigation 10 Consider the need for power and other issues not related to the environmental effects of 11 the proposed action and the alternatives 12 Discuss any aspect of the storage of spent fuel within the scope of the generic 13 determination in 10 CFR 51.23(a) in accordance with 10 CFR 51.23(b) 14 Contain an analysis of any Category 1 issue unless there is significant new information 15 on a specific issue-this is pursuant to 10 CFR 51.23(c)(3)(iii) and (iv) 16 New and significant information is (1) information that identifies a significant environmental issue 17 not covered in the GEIS and codified in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, or 18 (2) information that was not considered in the analyses summarized in the GEIS and that leads 19 to an impact finding that is different from the finding presented in the GEIS and codified in 20 10 CFR Part 51.

21 In preparing to submit its application to renew the JAFNPP OL, Entergy developed a process to 22 ensure that information not addressed in or available during the GEIS evaluation regarding the 23 environmental impacts of license renewal for JAFNPP would be properly reviewed before 24 submitting the ER, and to ensure that such new and potentially significant information related to 25 renewal of the license would be identified, reviewed, and assessed during the period of NRC 26 review. Entergy reviewed the Category 1 issues that appear in Table B-1 of 10 CFR Part 51, 27 Subpart A, Appendix B, to verify that the conclusions of the GEIS remained valid with respect to 28 JAFNPP. This review was performed by personnel from Entergy and its support organizations 29 involved in the preparation of a license renewal ER.

30 The NRC staff also has a process for identifying new and significant information. That process 31 is described in detail in Standard Review Plans for Environmental Reviews for Nuclear Power 32 Plants, Supplement 1: Operating License Renewal NUREG-1555, Supplement 1 (NRC 2000).

33 Introduction Draft NUREG-1437, Supplement 31 1-6 June 2007 The search for new information includes (1) review of an applicant's ER and the process for 1 discovering and evaluating the significance of new information, (2) review of public comments, 2 (3) review of environmental quality standards and regulations, (4) coordination with Federal, 3 State, and local environmental protection and resource agencies, and (5) review of the technical 4 literature. New information discovered by the NRC staff is evaluated for significance using the 5 criteria set forth in the GEIS. For Category 1 issues where new and significant information is 6 identified, reconsideration of the conclusions for those issues is limited in scope to the 7 assessment of the relevant new and significant information; the scope of the assessment does 8 not include other facets of the issue that are not affected by the new information.

9 Chapters 3 through 7 discuss the environmental issues considered in the GEIS that are 10 applicable to JAFNPP. At the beginning of the discussion of each set of issues, a table 11 identifies the issues to be addressed and lists the sections in the GEIS where the issue is 12 discussed. Category 1 and Category 2 issues are listed in separate tables. For Category 1 13 issues for which there is no new and significant information, the table is followed by a set of 14 short paragraphs that state the GEIS conclusion codified in Table B-1 of 10 CFR Part 51, 15 Subpart A, Appendix B, followed by the NRC staff's analysis and conclusion. For Category 2 16 issues, in addition to the list of GEIS sections where the issue is discussed, the tables list the 17 subparagraph of 10 CFR 51.53(c)(3)(ii) that describes the analysis required and the draft SEIS 18 sections where the analysis is presented. The draft SEIS sections that discuss the Category 2 19 issues are presented immediately following the table.

20 The NRC prepares an independent analysis of the environmental impacts of license renewal 21 and compares these impacts with the environmenta l impacts of alternatives. The evaluation of 22 the Entergy license renewal application began with publication of a Notice of Acceptance for 23 docketing and opportunity for a hearing in the Federal Register (FR; 71 FR 55032 [NRC 2006])

24 on September 20, 2006, which also included a Notice of Intent to prepare an EIS and conduct 25 scoping. Two public scoping meetings were held on October 12, 2006, in Oswego, New York.

26 Comments received during the scoping period were summarized in the Environmental Scoping 27 Summary Report Associated with the Staff's Review of the Application by Entergy for Renewal 28 of the Operating License for James A. FitzPatrick Nuclear Power (NRC 2007). Comments that 29 are applicable to this environmental review are presented in Appendix A.

30 The NRC staff followed the review guidance contained NUREG-1555, Supplement 1 (NRC 31 2000). The NRC staff and contractors retained to assist the staff conducted a site audit at the 32 JAFNPP site on December 5 and 6, 2006, to gather information and to become familiar with the 33 site and its environs. The NRC staff also reviewed the comments received during scoping and 34 consulted with Federal, State, regional, and local agencies. A list of the organizations consulted 35 is provided in Appendix D. Other documents related to JAFNPP were reviewed and are 36 referenced in this draft SEIS.

37 This draft SEIS presents the NRC staff's analysis that considers and weighs the environmental 38 effects of the proposed renewal of the OL for JAFNPP, the environmental impacts of 39 Introduction June 2007 1-7 Draft NUREG-1437, Supplement 31 alternatives to license renewal, and mitigation measures available for avoiding adverse 1 environmental effects. Chapter 9, "Summary and Conclusions," provides the NRC staff's 2 preliminary recommendation to the Commission on whether or not the adverse environmental 3 impacts of license renewal are so great that pr eserving the option of license renewal for energy-4 planning decision makers would be unreasonable.

5 A 75-day comment period on this draft SEIS will begin on the date of publication of the U.S.

6 Environmental Protection Agency Notice of Filing of the draft SEIS to allow members of the 7 public to comment on the preliminary results of the NRC staff's review. During this comment 8 period, two public meetings will be held in Oswego, New York, in August 2007. During these 9 meetings, the NRC staff will describe the preliminary results of the NRC environmental review 10 and answer questions to provide members of the public with information to assist them in 11 formulating their comments.

12 1.3 The Proposed Federal Action 13 The proposed Federal action is renewal of the OL for JAFNPP. JAFNPP is located in northern 14 New York on the south shore of Lake Ontario, approximately 7 miles (mi) northeast of Oswego, 15 New York, 36 mi north-northeast of Syracuse, New York, and 65 mi east of Rochester, New 16 York. The plant has a single boiling water reactor (BWR) designed by the General Electric 17 Company with a rated power level of 2536 megawatts thermal (MWt) and a gross power output 18 of 881 megawatts electric (MWe). Plant cooling is provided by a once-through cooling system 19 that discharges heated water back to Lake Ontario through a discharge structure. The current 20 OL for JAFNPP expires on October 17, 2014. By letter dated July 31, 2006, Entergy submitted 21 an application to the NRC (Entergy 2006a) to r enew this OL for an additional 20 years of 22 operation (i.e., until October 17, 2034).

23 1.4 The Purpose and Need for the Proposed Action 24 Although a licensee must have a renewed license to operate a reactor beyond the term of the 25 existing OL, the possession of that license is just one of a number of conditions that must be 26 met for the licensee to continue plant operation during the term of the renewed license. Once 27 an OL is renewed, State regulatory agencies and the owners of the plant will ultimately decide 28 whether the plant will continue to operate based on factors such as the need for power or other 29 matters within the State's jurisdiction or the purview of the owners.

30 Thus, for license renewal reviews, the NRC has adopted the following definition of purpose and 31 need (GEIS Section 1.3):

32 The purpose and need for the proposed action (renewal of an operating license) 33 is to provide an option that allows for power generation capability beyond the 34 Introduction Draft NUREG-1437, Supplement 31 1-8 June 2007 term of a current nuclear power plant oper ating license to meet future system 1 generating needs, as such needs may be determined by State, utility, and where 2 authorized, Federal (other than NRC) decision makers.

3 This definition of purpose and need reflects the Commission's recognition that, unless there are 4 findings in the safety review required by the Atomic Energy Act of 1954 or findings in the NEPA 5 environmental analysis that would lead the NRC to reject a license renewal application, the 6 NRC does not have a role in the energy-planning decisions of State regulators and utility 7 officials as to whether a particular nuclear power plant should continue to operate. From the 8 perspective of the licensee and the State regulatory authority, the purpose of renewing an OL is 9 to maintain the availability of the nuclear plant to meet system energy requirements beyond the 10 current term of the plant's license.

11 1.5 Compliance and Consultations 12 Entergy is required to hold certain Federal, State, and local environmental permits, as well as 13 meet relevant Federal and State statutory requirements. In its ER, Entergy provided a list of the 14 authorizations from Federal, State, and local authorities for current operations as well as 15 environmental approvals and consultations as sociated with JAFNPP license renewal.

16 Authorizations and consultations relevant to the proposed OL renewal action are included in 17 Appendix E.

18 The NRC staff has reviewed the list and consulted with the appropriate Federal, State, and local 19 agencies to identify any compliance or permit issues or significant environmental issues of 20 concern to the reviewing agencies. These agencies did not identify any new and significant 21 environmental issues. The ER states that Entergy is in compliance with applicable 22 environmental standards and requirements for JAFNPP. The NRC staff has not identified any 23 environmental issues that are both new and significant.

24 1.6 References 25 10 CFR Part 51.

Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 26 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

27 10 CFR Part 54.

Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for 28 Renewal of Operating Licenses for Nuclear Power Plants."

29 40 CFR Part 1508.

Code of Federal Regulations , Title 40, Protection of Environment , 30 Part 1508, "Terminology and Index."

31 Atomic Energy Act of 1954 (AEA). 42 USC 2011, et seq.

32 Introduction June 2007 1-9 Draft NUREG-1437, Supplement 31 Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2006a.

1 James A. FitzPatrick Nuclear Power Plant - License Renewal Application.

Lycoming, 2 New York. Accessible at ML062160494.

3 Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2006b.

4 James A. FitzPatrick Nuclear Power Plant - License Renewal Application, Appendix E:

5 Applicant's Environmental Report, Operating License Renewal Stage.

Lycoming, New York.

6 Accessible at ML062160557.

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

8 U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement 9 for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2. Office of Nuclear 10 Regulatory Research, Washington, D.C.

11 U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement 12 for License Renewal of Nuclear Plants Main Report, "Section 6.3 - Transportation, Table 9.1, 13 Summary of findings on NEPA issues for license r enewal of nuclear power plants, Final Report."

14 NUREG-1437, Volume 1, Addendum 1. Office of Nuclear Regulatory Research, Washington, 15 D.C. 16 U.S. Nuclear Regulatory Commission (NRC). 2000. Standard Review Plans for Environmental 17 Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal. NUREG-1555, 18 Supplement 1. Office of Nuclear Reactor Regulation, Washington, D.C.

19 U.S. Nuclear Regulatory Commission (NRC). 2006. "Notice of Acceptance for Docketing of the 20 Application, Notice of Opportunity for a Hearing and Notice of Intent to Prepare an 21 Environmental Impact Statement and Conduct Scoping Process for Facility Operating License 22 No. DPR-59 for an Additional 20-Year Period, Entergy Nuclear Operations, Inc., James A.

23 Fitzpatrick Nuclear Power Plant." Federal Register: Vol. 71, No. 182, pp. 55032-55035.

24 September 20, 2006.

25 U.S. Nuclear Regulatory Commission (NRC). 2007. Environmental Scoping Summary Report 26 Associated with the Staff's Review of the Application by Entergy for Renewal of the Operating 27 License for JAFNPP. Washington, D.C. Accessible at ML070440393.

28

June 2007 2-1 Draft NUREG-1437, Supplement 31

2.0 DESCRIPTION

OF NUCLEAR POWER PLANT AND SITE AND 1 INTERACTION WITH THE ENVIRONMENT 2 James A. FitzPatrick Nuclear Power Plant (JAFNPP) is located in the town of Scriba, New York.

3 The plant consists of one unit, a boiling water reactor (BWR), which employs a once-through 4 cooling system. JAFNPP is operated by Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear 5 Operations, Inc. (Entergy). The plant and its environs are described in Section 2.1, and the 6 environment in which the plant is located is presented in Section 2.2.

7 2.1 Facility and Site Description and Proposed Facility Operation During the 8 Renewal Term 9 JAFNPP is located on approximately 702 acres (ac) of land on the south shore of Lake Ontario, 10 at a location known as Nine Mile Point. The plant is in a rural area, approximately seven miles 11 (mi) northeast of Oswego, 36 mi north-northwest of Syracuse, and 65 mi east of Rochester, 12 New York. The largest town within a 50-mi radius is Syracuse. Nine Mile Point Nuclear Station, 13 Units 1 and 2, operated by Nine Mile Point Nuclear Station, LLC, is immediately west of 14 JAFNPP. Figures 2-1 and 2-2 show the site location and features within 50 mi and 6 mi, 15 respectively (Entergy 2006c).

16 2.1.1 External Appearance and Setting 17 The area surrounding JAFNPP is generally flat, rising gently from Lake Ontario to the 18 Appalachian Uplands on the south, and bounded on the east by the Tug Hill Upland. The plant 19 is at an elevation of 270 feet (ft) above mean sea level. Elevation rises to 310 ft at the 20 property's southern edge 1 mi away. The JAFNPP site is partially wooded and surrounded 21 primarily by residential and recreational areas except for the Nine Mile Point Nuclear Station.

22 There is no residential, agricultural, or industrial development (other than JAFNPP) on the 23 JAFNPP site. The nearest residence is outside the site boundary approximately 0.7 mi to the 24 east-southeast.

25 The buildings associated with JAFNPP lie on the northwest part of the site (See Figure 2-3).

26 The plant consists of a reactor building, turbine building with electrical and heater bays, 27 administration building and control room, radioactive waste building, screenwell-pumphouse 28 building with intake and discharge tunnels and structures, diesel generator building, auxiliary 29 boiler building, main stack, independent spent fuel storage installation (ISFSI), sewage 30 treatment plant, interim radioactive waste storage building, switchyard, shooting ranges, and 31 associated transmission lines. The facility is enclosed by a security fence and access to the site 32 is controlled. Although the plant structures can be seen by recreational users on Lake Ontario, 33 JAFNPP is not visible to local communities due to the surrounding forest cover.

34 Plant and the Environment Draft NUREG-1437, Supplement 31 2-2 June 2007 1 Figure 2-1. Location of JAFNPP, 50-mi Region (Entergy 2006c) 2 Plant and the Environment June 2007 2-3 Draft NUREG-1437, Supplement 31 1 Figure 2-2. Location of JAFNPP , 6-mi Region (Entergy 2006c) 2 Plant and the Environment Draft NUREG-1437, Supplement 31 2-4 June 2007 1 Figure 2-3. JAFNPP Approximate Site Boundary 2 The plant is accessed by Lake Road, which connects to Oswego County Route 29. A spur of 3 Conrail Railroad is currently blocked for security purposes but could be re-opened to provide rail 4 service to the plant. JAFNPP can also be reached by barge on Lake Ontario.

5 Plant and the Environment June 2007 2-5 Draft NUREG-1437, Supplement 31 Within a 50-mi radius of JAFNPP there are 17 state parks, 20 state wildlife management areas, 1 and one national wildlife refuge. The closest public park, Sunset Bay Park, is approximately 2 1 mi east of JAFNPP on the shore of Lake Ontario. This park has 48 ac of mostly woods and 3 brush land, a boat launch, nature trail, and picnic area. The next closest public park, 4 Independence Park, is approximately 2 mi southwest and also on Lake Ontario. This park has 5 50 ac of wooded land, walking trails, and an observation deck. Scriba Town Park is 5 mi south 6 of Scriba and includes a picnic area, playground, and swimming facilities.

7 2.1.2 Reactor Systems 8 JAFNPP is a single-cycle, forced-circulation BWR that produces steam for direct use in the 9 steam turbine. The rated thermal output of the unit is 2536 megawatts-thermal (MWt), 10 corresponding to an electrical output of approximately 881 megawatts-electric (MWe). JAFNPP 11 achieved commercial operation in 1975 (Entergy 2006c).

12 The JAFNPP facility is depicted in Figure 2-3. The reactor building is designed as a low 13 in-leakage, elevated release secondary containment system that houses the primary 14 containment system, refueling facilities, and most of the components of the nuclear steam 15 supply system. The secondary containment system provides secondary containment when the 16 primary containment system is closed and in service, and provides primary containment when 17 the primary containment system is open, as in refueling. The secondary containment system 18 consists of the reactor building, standby gas treatment system, reactor building isolation control 19 system, and main stack.

20 In the event of a postulated pipe break inside the drywell or a fuel handling accident, the reactor 21 building is isolated by the reactor building isolation control system to provide a low leakage 22 barrier. The standby gas treatment system, which is initiated by the same conditions that isolate 23 the reactor building, exhausts air from the reactor building to maintain a reduced pressure within 24 the reactor building relative to the outside atmosphere, treats the air to remove particulates and 25 iodines, and releases the air through the elevated release point, the main stack. These safety 26 features function to localize, control, mitigate, and terminate such events to limit the public's 27 exposure levels to below applicable dose guidelines.

28 The fuel for the reactor core consists of slightly enriched uranium dioxide pellets contained in 29 sealed Zircaloy-2 tubes that were evacuated, backfilled with helium, and sealed with Zircaloy 30 end plugs welded in each end. The core is designed to permit the energy extraction of 31 19,000 megawatt-days per metric ton of uranium averaged over the initial core load (Entergy 32 2006c). 33 2.1.3 Cooling and Auxiliary Water Systems 34 JAFNPP uses water from Lake Ontario for station cooling. Approximately 91 percent of the 35 water withdrawn from the lake is used for the circulating water system to cool the station's main 36 condenser. Approximately 9 percent of the water withdrawn from the lake is used for the station 37 Plant and the Environment Draft NUREG-1437, Supplement 31 2-6 June 2007 service water system and other plant systems including the emergency service water system, 1 the residual heat removal system, and the fire protection system.

2 Water is withdrawn from the lake from an offshore submerged intake structure and through the 3 intake tunnel to the screenwell-pumphouse building. Water is eventually returned to the lake by 4 way of a discharge tunnel and an in-lake diffuser system. The cooling and auxiliary water 5 systems for JAFNPP include the intake structure, intake tunnel, screenwell and pumphouse 6 building, discharge tunnel, and diffuser. Neither the intake or discharge diffuser structures are 7 in the shipping lanes of the lake and therefore do not constitute a hazard to commercial 8 shipping.

9 The offshore intake structure is a reinforced concrete structure located approximately 900 ft 10 from the shoreline in approximately 25 ft of water. Water is drawn from lower levels of the lake 11 to prevent the formation of vortices at the surface and minimize the possibility of interactions 12 with floating ice and the lake fishery. The structure is approximately 14 ft high and the top of the 13 intake structure is approximately 10 ft below the lake surface. The fan-shaped intake is located 14 on the shoreward side of the structure. Water is drawn through four openings with a total intake 15 area of approximately 8 ft by 70 ft. The intake velocity at the intake structure is approximately 16 1.6 feet per second (ft/s).

17 The intake opening also includes a bar rack, with bars placed 1 foot apart, to prevent large 18 debris from entering the intake. The bars are heated by induction coils to minimize the 19 probability of frazil ice adhering to the bars and blocking the intake. The heaters are normally 20 kept energized except during maintenance. Duri ng maintenance, any frazil ice that is drawn 21 past the intake racks is tempered in the screenwell structure with water from the circulating 22 water discharge chamber. In the unlikely event that the intake is blocked and the volume of 23 water needed for normal shutdown cannot be drawn, the flow in the discharge structure can be 24 reversed using a series of gates, and cooling water can be drawn through the discharge tunnel 25 to the screenwell-pumphouse building.

26 JAFNPP has installed a high-frequency/high-amplitude acoustic fish deterrence system (FDS) 27 on the intake structure. The JAFNPP FDS consists of nine overlapping, wide-beam, high-28 frequency transducers mounted on the top of the intake structure. The transducers produce a 29 sound field designed to deter alewifes from entering the intake structure and eventually 30 becoming impinged on the intake screens.

31 From the intake structure, the lake water drops 60 feet below lake level to a tunnel connecting 32 the intake structure to the onshore screenwell-pumphouse building. The D-shaped tunnel has a 33 flat bottom, vertical sides, and round top; average water velocity in the tunnel is 4.7 ft/s. From 34 the intake tunnel, the water rises into the forebay of the screenwell-pumphouse building.

35 The screenwell-pumphouse building, which is the structure immediately north of the turbine 36 building, houses the trash racks, traveling screens, pumps for the circulating water, services 37 Plant and the Environment June 2007 2-7 Draft NUREG-1437, Supplement 31 water, emergency service water, residual heat removal, and fire protection systems. The 1 screenwell-pumphouse also houses the water treatment tanks and associated biofouling control 2 equipment.

3 From the intake tunnel, water enters the screenwell-pumphouse forebay, travels through vertical 4 trash bars that excludes debris greater than 3 1/8-inches, then through the vertical traveling 5 screens with a 3/8-inch mesh. The screenwell behind the vertical traveling screens houses 6 three circulating water pumps each with a rated flow of 120,000 gpm. The design circulating 7 water flow is 352,600 gpm through the main condenser.

8 Discharge from the main condenser and service water system is returned to Lake Ontario 9 through the discharge tunnel and diffuser system in the lake. The design effluent flow rate to 10 the discharge tunnel is 388,600 gpm, including the design service water pumps discharge of 11 36,000 gpm. The discharge tunnel starts from the screenwell-pumphouse building and extends 12 approximately 1400 ft northward into the lake to a junction with the diffuser branch tunnels, 13 which are generally parallel to the shoreline. The discharge diffuser consists of six diffuser 14 heads, three on each diffuser branch and spaced approximately 150 feet apart. On top of each 15 riser is a diffuser head consisting of two horizontal discharge nozzles separated by an included 16 angle of 42 degrees. Each nozzle is 2.5 ft in diameter and discharges water at an exit velocity 17 of 14 ft/s in the offshore direction. The centerline of the nozzles is five to six feet above the lake 18 bottom. 19 Discharges from the cooling water and service water systems are regulated by the New York 20 State Department of Environmental Conservation (NYSDEC) under State Pollutant Discharge 21 Elimination System (SPDES) Discharge Permit NY-0020109 (Entergy 2006c).

22 2.1.4 Radioactive Waste Management Systems and Effluent Control Systems 23 JAFNPP radioactive waste (radwaste) systems are designed to collect, treat, and dispose of the 24 radioactive and potentially radioactive wastes that are byproducts of plant operations. The 25 byproducts are activation products resulting from the irradiation of reactor water and impurities 26 therein (principally metallic corrosion products) and fission products resulting from defective fuel 27 cladding or uranium contamination within the reactor coolant system. Operating procedures for 28 radwaste systems ensure that radioactive wastes are safely processed and discharged from the 29 plant within the limits set forth in Part 20 of Title 10 of the Code of Federal Regulations (10 CFR 30 Part 20), 10 CFR Part 50, the plant's technical specifications, and JAFNPP's Offsite Dose 31 Calculation Manual or ODCM (Entergy 2004c, 2006c).

32 Radioactive wastes resulting from plant operations are classified as liquid, gaseous, or solid.

33 Liquid radioactive wastes are generated from liquids received directly from portions of the 34 reactor coolant system or were contaminated by contact with liquids from the reactor coolant 35 system. Gaseous radioactive wastes are generated from gases or airborne particulates vented 36 from reactor and turbine equipment containing radioactive material. Solid radioactive wastes 37 Plant and the Environment Draft NUREG-1437, Supplement 31 2-8 June 2007 are solids from the reactor coolant system, solids that came into contact with reactor coolant 1 system liquids or gases, or solids used in the reactor coolant system or steam and power 2 conversion system operation or maintenance (Entergy 2006c).

3 Reactor fuel that has exhausted a certain percentage of its fissile uranium content is referred to 4 as spent fuel. Spent fuel assemblies are removed from the reactor core and replaced with fresh 5 fuel assemblies during routine refueling outages, typically every 24 months. Spent fuel 6 assemblies are then stored for a period of time in the spent fuel pool in the reactor building and 7 may later be transferred to dry storage at an onsite ISFSI. JAFNPP also provides for onsite 8 storage of mixed wastes, which contain both radioactive and chemically hazardous materials 9 (Entergy 2006c).

10 JAFNPP's ODCM contains the methodology and parameters used to calculate offsite doses 11 resulting from radioactive gaseous and liquid effluents, and the gaseous and liquid effluent 12 monitoring alarm and trip set points used to verify that the radioactive material being discharged 13 meets regulatory limits (Entergy 2004c). The ODCM also contains the radioactive effluent 14 controls and radiological environmental monitoring activities and descriptions of the information 15 that should be included in the annual Radiological Environmental Operating Report and annual 16 Radioactive Effluent Release Report required by 10 CFR Part 50, Appendix I, and 17 10 CFR 50.36a, respectively.

18 2.1.4.1 Liquid Waste Processing Systems and Effluent Controls 19 The liquid waste processing system collects, holds, treats, processes, and monitors all liquid 20 radioactive wastes for reuse or disposal. The system is divided into several subsystems so that 21 liquid wastes from various sources can be segregated and processed separately. Cross 22 connections between the subsystems provide additional flexibility for processing the wastes by 23 alternate methods. The wastes are collected, treated, and disposed of according to their 24 conductivity and/or radioactivity (Entergy 2006c).

25 Liquid waste is collected in sumps and drain tanks and transferred to the appropriate subsystem 26 collection tanks for subsequent treatment, disposal, or recycle. The subsystems provide for 27 filtration, demineralizing, dewatering, and resin filtration; and include a modular fluidized transfer 28 demineralization and sluice system. Following treatment and batch sampling, the liquid waste is 29 normally returned to condensate storage tanks for reuse in the plant. Liquid releases to the lake 30 are infrequent, and limited to the maximum extent possible to satisfy the design objectives of 10 31 CFR Part 50, Appendix I. Liquid discharges to the lake occur only when radioactive material 32 activity concentration in the storage tank is equal to or less than 5 x 10

-4 curies per milliliter 33 (Ci/ml) (Entergy 2006c). Liquid discharge concentrations are further reduced by dilution water 34 before any release to the lake. Chemical waste is dewatered and sent offsite to an approved 35 disposal site. Controls for limiting the release of radiological liquid effluents are described in the 36 ODCM (Entergy 2004c).

37 Plant and the Environment June 2007 2-9 Draft NUREG-1437, Supplement 31 The NRC staff reviewed the JAFNPP radioactive effluent release reports for 2001 through 2005 1 for liquid effluents (Entergy 2006a, 2005a, 2004a, 2003, 2002a, 2002b). In 2005, 3 million liters 2 (L) of radiological liquid effluents diluted with 921 million L of water and a total of 1.34 x 10

-2 Ci 3 of tritium diluted to concentrations below 2 x 10

-6 µCi/ml were released (Entergy 2006a). The 4 releases contained no other fission or activation products, gross alpha radioactivity, or dissolved 5 and entrained gases. In the fourth quarter of 2002, a total of 2.75 10

-3 Ci of fission and 6 activation products and 3.62 x 10

-7 Ci of gross alpha radioactivity were released.

7 Based on the liquid waste processing systems and effluent controls and performance from 2001 8 through 2005, similar small quantities of radioactive liquid effluents are expected from JAFNPP 9 and are not expected to increase during the renewal period. These releases would result in 10 doses to members of the public that are well below the as low as reasonably achievable 11 (ALARA) dose design objectives of 10 CFR Part 50, Appendix I, as discussed in Section 2.2.7.

12 2.1.4.2 Gaseous Waste Processing Systems and Effluent Controls 13 The gaseous radwaste processing system processes and disposes of condenser off-gases via 14 the main stack. Non-radioactive gland seal gas and gases from the start-up mechanical pump 15 are also discharged via the stack. During routine reactor operation, condenser off-gas is the 16 major contributor to the activity in the off-gas release. Condenser off-gas entering this system 17 consists of non-condensables from the main condenser, which consist of hydrogen and oxygen 18 formed in the reactor by the radiolytic decomposition of water, air in-leakage to the turbine-19 condenser, water vapor, and a negligible volume of fission gases. The most important sources 20 of radioactive gases are activation gases in the reactor coolant and fission gases that leak 21 through the fuel cladding (Entergy 2006c).

22 The gaseous radwaste processing system controls, filters, and removes radioactive particulates 23 and iodine from off-gas stream, recombines radiolytic hydrogen and oxygen, provides adequate 24 holdup time for decay of short-lived radionuclides, and uses charcoal beds for the hold-up and 25 partial decay of xenon (Xe) and krypton (Kr) gases. The stack design ensures prompt mixing of 26 gas inlet streams at its base, thereby providing prompt dilution of hydrogen and allowing the 27 location of sample points as near the base as possible.

28 JAFNPP maintains gaseous in accordance with the procedures and methodology described in 29 the ODCM. The gaseous radwaste system is used to reduce radioactive materials in gaseous 30 effluents before discharge to meet the ALARA dose design objectives in 10 CFR Part 50, 31 Appendix I. Radioactive effluent gases are released at a typical rate of 24 to 28 cubic feet per 32 minute (ft 3/min). Two air dilution fans are in the base of the stack, both rated at 3000 ft 3/min. 33 One dilution fan operates continuously while the other fan is on standby. The flow from the 34 operating stack dilution fan also ensures that hydrogen is diluted to less than 4 percent by 35 volume. In addition, the limits in the ODCM are designed to prevent members of the public in 36 unrestricted areas from being exposed to radioactive materials in excess of the limits specified 37 in 10 CFR Part 20, Appendix B (Entergy 2006c).

38 Plant and the Environment Draft NUREG-1437, Supplement 31 2-10 June 2007 The NRC staff reviewed the JAFNPP radioactive effluent release reports for 2001 through 2005 1 for gaseous effluents (Entergy 2006a, 2005a, 2004a, 2003, 2002a, 2002b). In 2005, the total 2 fission and activation products released was 4370 Ci; iodine-131 was 9.35 x 10

-3 Ci; particulates 3 were 3.52 x 10

-36 Ci; and tritium was 17.1 Ci. These activities are typical of past years and are 4 not expected to increase during the renewal period. See Section 2.2.7 for a discussion of the 5 theoretical doses to the maximally exposed individual as a result of these releases.

6 2.1.4.3 Solid Waste Processing 7 The solid radwaste processing equipment is located in the radioactive waste building with the 8 exception of the cleanup phase separator tanks, which are located in the reactor building. Both 9 wet and dry radioactive solid wastes are processed. Wet solid wastes include backwash sludge 10 wastes from the reactor water cleanup system, waste from floor drain filters, the fuel pool filter-11 demineralizers, spent resins from the waste and condensate demineralizers, and spent media 12 from modular fluidized transfer demineralization and sluice system. Dry solid wastes include 13 rags, contaminated clothing, paper, small equipment parts, and solid laboratory wastes (Entergy 14 2006c). 15 Contaminated waste such as demolished piping, equipment, and components from facility 16 radiological-controlled areas are first processed at an onsite decontamination unit. If the 17 material is below the acceptable release limits and after additional cleaning shows no further 18 reduction of contamination levels, the material may be returned to use or released from the 19 radiological-controlled area. If the material is not below the release limits and after additional 20 cleaning shows no further reduction of contamination levels, it will be disposed of as radioactive 21 waste. In some instances, the solid material is sent to a vendor for decontamination. This 22 material may be returned for reuse or disposed of as radioactive waste per the vendor's process 23 (Entergy 2006c).

24 In 2005, JAFNPP made a total of 35 shipments of solid waste to offsite vendors. The solid 25 waste volumes were 623 cubic meters (m

3) of dry compressible waste, contaminated 26 equipment, and spent resins, with an activity of 131 Ci (Entergy 2006a). No irradiated 27 components or control rods were shipped. The solid waste volumes and radioactive material 28 activity levels are typical of annual waste shipments for JAFNPP and are not expected to 29 increase during the renewal period.

30 2.1.5 Nonradioactive Waste Systems 31 JAFNPP generates solid waste, hazardous and universal waste, mixed waste, and wastewaters 32 from routine facility operations and maintenance activities.

33 2.1.5.1 Nonradioactive Waste Streams 34 Solid waste is waste that is neither radioactive nor hazardous as defined by the Resource 35 Conservation and Recovery Act (RCRA) (40 CFR Part 260). JAFNPP generates solid waste, 36 Plant and the Environment June 2007 2-11 Draft NUREG-1437, Supplement 31 such as office trash, as part of routine plant maintenance, cleaning activities, and plant 1 operations. A contract service collects office trash and disposes of the waste offsite. JAFNPP 2 has an active recycling program for office paper, aluminum cans, and plastic.

3 Hazardous waste is nonradioactive waste that is listed by the U.S. Environmental Protection 4 Agency (EPA) as hazardous waste or that exhibits characteristics of ignitability, corrosivity, 5 reactivity, or toxicity (40 CFR Part 261). RCRA regulates the treatment, storage, and/or 6 disposal of hazardous waste and requires a hazardous waste permit for facilities that treat or 7 store large quantities of hazardous waste for more than 90 days and for entities that dispose of 8 hazardous waste at the facility. RCRA regulations are administered in New York State by 9 NYSDEC. 10 JAFNPP generates a variety of hazardous waste streams including broken fluorescent lamps, 11 mercury, off-specification or expired chemicals, oil lab wastes, oils and solvents, paint waste, 12 photographic waste, and polychlorinated biphenyls (PCBs). JAFNPP is a small-quantity 13 generator of hazardous waste, meaning the plant generates less than 1000 kilograms (kg) of 14 non-acute hazardous waste in a month and stores less than 6000 kg of this waste at any one 15 time. A small-quantity generator can also be classified as generating less than 1 kg of acute 16 hazardous waste in a month and storing less than 1 kg of this waste at one time. In 2004, 17 JAFNPP generated 5266 kg of hazardous waste. Most of the waste was associated with the 18 demolition of buildings. Approximately 318 kg of hazardous waste was generated in 2005 and 19 626 kg in 2006. During 2004 to 2006, NYSDEC conducted two regulatory compliance 20 inspections of JAFNPP's RCRA program. No hazardous waste permit violations were noted.

21 Universal waste is hazardous waste that has been specified as universal waste by the EPA.

22 Universal waste, including mercury-containing equipment, batteries, lamps, and pesticides, has 23 specific regulations (40 CFR Part 273) to ensure proper collection and recycling or treatment.

24 States may modify the universal waste rule and add additional wastes to their list of universal 25 wastes. New York State classifies batteries, pesticides, mercury-containing thermostats, and 26 lamps as universal wastes, which are therefore subject to specific universal waste regulations 27 (6 NYCRR Subpart 374).

28 JAFNPP generates pesticides, batteries, and fluorescent lamps as universal wastes from 29 normal facility operations. The batteries and lamps are accumulated in satellite areas and then 30 moved to a locked storage building, in accordance with State universal waste regulations. The 31 wastes are disposed of offsite by a contract service. In 2005, JAFNPP generated approximately 32 7193 kg of spent batteries and 843 kg of spent fluorescent bulbs. In 2006, 2749 kg of spent 33 batteries and 843 kg of spent bulbs were generated. During the 2004 RCRA inspection, one 34 universal waste program violation related to the management of spent fluorescent bulbs was 35 noted but fixed immediately by site personnel (Entergy 2006g).

36 The Toxic Substance Control Act (TSCA) of 1976 (15 USC s/s 2601 et seq.) implemented 37 regulations for EPA to track specific toxic chemicals used in the U.S. PCBs, a TSCA chemical 38 Plant and the Environment Draft NUREG-1437, Supplement 31 2-12 June 2007 is found at JAFNPP in limited quantities in transformer oil, lighting ballasts, and capacitors. In 1 2005, JAFNPP received a fine from EPA for improper ly identifying a drum of used oil as non-2 hazardous instead of PCB-waste and not disposing of the drum at a TSCA disposal facility. As 3 a result, Entergy created a fleet-wide TSCA management plan that has been implemented at 4 JAFNPP. 5 Low-level mixed waste (LLMW) is waste that exhibits hazardous characteristics and contains 6 low levels of radioactivity. LLMW has been regulated under multiple authorities. EPA or state 7 agencies regulate the hazardous component of LLMW through RCRA, and either the U.S.

8 Department of Energy (DOE) or NRC regulates the radioactive component. New York State 9 has adopted the EPA rule (6 NYCRR Part 374), which provides for a conditional exemption of 10 LLMW storage, to eliminate dual regulation of LLMW. Storage of LLMW at JAFNPP is 11 permitted under its NYSDEC Treatment, Storage, or Discharge Facility (TSDF) permit 12 (No. NYD000765073). The permit was issued in November 1995 and expired in January 2000.

13 New York Power Authority (NYPA), the owner of JAFNPP at the time, submitted a letter to 14 NYSDEC (NYPA 2000) with its intention to operate under the conditional exemption.

15 Subsequently, NYSDEC allowed the existing permit to continue under the State Administrative 16 Procedures Act (Section 401) until the EPA rule was finalized (NYSDEC 2000a). JAFNPP 17 submitted a letter to NYSDEC in November 2005 stating that JAFNPP qualified for the LLMW 18 exemption and would, therefore, like to terminate its Part 373 Permit (Entergy 2005d). The 19 permit is still pending termination by NYSDEC.

20 JAFNPP generates oil and solvent wastes, off-specification chemicals, and paint wastes (solids 21 and liquids) from normal facility operation and maintenance. These wastes, when generated, 22 are stored in locked, marked containment buildings specifically for LLMW. JAFNPP last 23 shipped LLMW offsite for disposal in 2005. JAFNPP generates small amounts of LLMW at 24 several accumulation areas in the facility but does not have any stored in the mixed waste 25 storage building (Entergy 2006g).

26 JAFNPP generates two types of wastewater: sanitary liquid wastes and industrial effluents.

27 Radioactive liquid waste is addressed in Section 2.1.4. Section 2.2.3 provides more information 28 on JAFNPP's SPDES permit.

29 JAFNPP operates a sewage treatment plant to treat sanitary wastewater generated by the plant.

30 The treated water is discharged into a drainage ditch that flows into Lake Ontario and is 31 regulated as Outfall 012 in the SPDES permit (No. NY-0020109) issued by NYSDEC. Sanitary 32 sludge from the sewage treatment plant is placed in covered sludge drying beds. The sludge is 33 removed by a contractor as needed and disposed of at an offsite treatment facility.

34 Industrial effluents are typically combined with cooling water discharges in accordance with 35 SPDES permit requirements. There are five SPDES-permitted outfalls (Outfalls 001 through 36 005). Circulating cooling water, service water, intake screen backwash, clarifier blowdown, filter 37 backwash, clearwell overflow, waste tank discharges, borated water, and emergency diesel 38 Plant and the Environment June 2007 2-13 Draft NUREG-1437, Supplement 31 generator cooling water are discharged at Outfall 001. Combined storm water and oil-water 1 separator wastewater are discharged at Outfall 002. Storm water runoff is discharged at 2 Outfalls 003, 004, and 005. Overflow from the sedimentation containment pond is also 3 discharged from Outfall 005. JAFNPP's SPDES permit requires specific monitoring and/or 4 sampling at each of the outfalls.

5 The Emergency Planning and Community Right-t o-Know Act (EPCRA) requires applicable 6 facilities to provide information on hazardous and toxic chemicals to emergency planning 7 authorities and the EPA. JAFNPP is subject to EPCRA Section 312 reporting and therefore 8 submits annual reports to local emergency agencies on the following chemicals: carbon dioxide, 9 diesel fuel, electrohydraulic fluid, fuel oil, gasoline, hydrogen, lube oils, nitrogen, oxygen, resins, 10 sodium hypochlorite, and transformer oil (Entergy 2006g).

11 2.1.5.2 Pollution Prevention and Waste Minimization 12 Currently, JAFNPP has several waste minimization measures in place. JAFNPP recycles 13 grease from the onsite cafeteria, as well as aluminum, office paper, and used oil. Another 14 waste minimization measure is the use of shock absorbing concrete (SACON) blocks as 15 backstops for firing activities at the firing ranges. The SACON blocks capture expended rounds, 16 preventing potential groundwater or soil lead contamination. The block supplier removes the 17 spent SACON blocks and recycles them into other concrete products (Entergy 2007a).

18 Entergy has a corporate policy and plan for waste minimization at its nuclear power plants, 19 including JAFNPP (Entergy 2006b). The plan provides a hierarchy of waste minimization 20 options that emphasize source reduction, reuse/recycling, treatment to reduce volume and/or 21 toxicity, and disposal, in that order. A fleet-wide focus group meets to discuss opportunities for 22 waste minimization and information sharing among the Entergy nuclear facilities. There are 23 also fleet-wide programs for Waste Management and Chemical Control. It is expected that 24 Entergy would continue to implement its waste minimization policy and programs during the 25 license renewal period for JAFNPP. The EPA's O ffice of Pollution Prevention and Toxics has 26 established a clearinghouse that provides information regarding management, technical, and 27 operational approaches to pollution prevention. The EPA's clearinghouse can provide 28 additional opportunities for waste minimization and pollution prevention at JAFNPP.

29 2.1.6 Facility Operation and Maintenance 30 Maintenance activities conducted at JAFNPP include inspection, testing, and surveillance to 31 maintain the current licensing basis of the facility and to ensure compliance with environmental 32 and safety requirements. Various programs and activities currently exist at JAFNPP to 33 maintain, inspect, test, and monitor the performance of facility equipment. These maintenance 34 activities include inspection requirements for reactor vessel materials, boiler and pressure 35 vessel in-service inspection and testing, maintenance structures monitoring program, and 36 maintenance of water chemistry.

37 Plant and the Environment Draft NUREG-1437, Supplement 31 2-14 June 2007 Additional programs include those implemented to meet technical specification surveillance 1 requirements, those implemented in response to the U.S. Nuclear Regulatory Commission 2 (NRC) generic communications, and various per iodic maintenance, testing, and inspection 3 procedures. Certain program activities are performed during the operation of the unit, while 4 others are performed during scheduled refueling outages. Entergy refuels JAFNPP on a 5 nominal 24-month interval.

6 2.1.7 Power Transmission System 7 Two single-circuit, 345-kilovolt (kV) transmission lines, the Edic and Scriba lines, were 8 constructed to connect JAFNPP to the grid. Both of these lines are owned by NYPA. The Edic 9 line (Table 2-1) is approximately 70 mi long and was constructed to connect the JAFNPP to the 10 New York Power Pool transmission grid. This line runs southeasterly from the plant 345-kV 11 switchyard to the Edic Substation located near Utica, New York (Figure 2-4). NYPA has owned 12 and operated the transmission line since it was constructed in the early 1970s. A 400-ft wide 13 right-of-way (ROW) was acquired by NYPA for the Edic 345-kV transmission line although a 14 width of only 150 ft, totaling 1273 ac, was actually cleared for the line. The remaining ROW was 15 acquired for the possible construction of future transmission lines. The Edic transmission line 16 was constructed with steel self-supporting towers spaced about 1200 ft apart. When the ROW 17 was acquired, about 65 percent of the ROW passed through forests, 29 percent through 18 agricultural lands, and 6 percent through wetlands. Most of ROW land remains in private 19 ownership and is used for a variety of compatible purposes.

20 A second single circuit, 345-kV transmission line was also constructed to connect JAFNPP to 21 the grid. The Scriba line (Table 2-1) is approximately 4900 ft (0.9 mi) in length and runs 22 southward from the plant's 345-kV switchyard to the National Grid Scriba Substation where it 23 connects to the 345-kV transmission system.

24 The two 345-kV lines for JAFNPP have transmission capacity in excess of the JAFNPP 25 generating unit, so either line can be out of service without curtailing the output from the plant.

26 Both lines exceed the requirements of the National Electric Safety Code for heavy loading 27 districts, Grade B (Entergy 2006c).

28 Plant and the Environment June 2007 2-15 Draft NUREG-1437, Supplement 31 Table 2-1. JAFNPP Transmission Lines, Substations, and Corridors 1 Substation Owner Number of LineskV Approximate Distance in miles Corridor Width in feet Corridor Area in acres Within Scope of License RenewalEdic NYPA 1 345 70 150 1273 Yes Scriba NYPA 1 345 0.9 NA NA Yes Lighthouse Hill National Grid 1 115 26 NA NA No Nine Mile Point Nuclear Station Constellation 1 115 0.7 NA NA No Source: Entergy 2006c 2 Figure 2-4. JAFNPP Transmission Lines 3

Plant and the Environment Draft NUREG-1437, Supplement 31 2-16 June 2007 1 In addition to the two 345-kV transmission lines for power distribution, offsite power is provided 2 to JAFNPP by two single-circuit 115-kV transmission lines connected to the plant's 115-kV bus.

3 One 115-kV line (Table 2-1) runs southward from the site and connects to the National Grid 4 115-kV transmission line that extends to the Lighthouse Hill Hydroelectric Station located about 5 26 mi east of JAFNPP. In addition to being a hydroelectric generating station and an integral 6 part of the National Grid 115-kV system, the Lighthouse Hill facility also serves as the 7 switchyard for several other hydroelectric facilities in the area. The other JAFNPP 115-kV line 8 (Table 2-1) is approximately 3700 ft in length and is connected to the 115-kV bus at 9 Constellation Nuclear Nine Mile Point Nuclear Station. The 115-kV bus at Constellation Nuclear 10 Nine Mile Point Nuclear Station Unit 1 is also connected via a 115-kV transmission line to the 11 South Oswego Substation (Entergy 2006c).

12 Ownership of the four JAFNPP transmission lines is as follows: (1) Edic Substation 345-kV 13 transmission line: from 345-kV switchyard to approximately the site property line, JAFNPP owns 14 the line; from the JAFNPP property line to the Edic Substation, NYPA owns the line; (2) Scriba 15 Substation 345-kV transmission line: from 345-kV switchyard to approximately the site property 16 line, JAFNPP owns the line; from the JAFNPP property line to the Scriba Substation, NYPA 17 owns the line; (3) Lighthouse Hill Hydroelectric Station 115-kV transmission line: from 115-kV 18 Switchyard to approximately the site property line, JAFNPP owns the line; from the JAFNPP 19 property line to the Lighthouse Hill Hydroelectric Station, National Grid owns the line; and (4) 20 Constellation Nuclear Nine Mile Point Nuclear Station 115-kV transmission line: from 115-kV 21 switchyard to approximately the site property line, JAFNPP owns the line; from the JAFNPP 22 property line to the Constellation Nuclear Nine Mile Point Nuclear Station 115-kV bus, 23 Constellation Nuclear Nine Mile Point Nuclear Station owns the line.

24 For the two 345-kV transmission line ROWs, NYPA uses a vegetation management plan 25 approved by the New York State Public Service Commission. NYPA uses an integrated 26 vegetation management computer application, which employs geographic information system 27 technology. The vegetation management program is designed to control tall-growing tree 28 species and to enhance the abundance of lower-growing desirable vegetation. Field inventories 29 are conducted annually for the ROW scheduled for clearing the following year. Inventories and 30 treatment recommendations are reviewed and approved by the NYPA forestry staff. The 31 majority of clearing is performed using mechanical methods. Herbicide applications are applied 32 to selected plant species by licensed contractors, and a safe buffer is maintained around 33 wetlands, and stream and river crossings. A safe buffer is also used around wells and springs 34 that are used for residential water supplies. Areas where herbicides are used are posted with 35 information regarding the chemicals that were used and when they were applied. Herbicides 36 are not applied on NYPA ROWs using aerial application methods (Entergy 2006c).

37 Plant and the Environment June 2007 2-17 Draft NUREG-1437, Supplement 31 2.2 Facility Interaction with the Environment 1 Sections 2.2.1 through 2.2.8 provide general descriptions of the environment near JAFNPP as 2 background information. They also provide detailed descriptions where needed to support the 3 analysis of potential environmental impacts of refurbishment and operation during the renewal 4 term, as discussed in Chapters 3 and 4. Section 2.2.9 describes the historic and archaeological 5 resources in the area, and Section 2.2.10 describes possible impacts associated with other 6 Federal project activities.

7 2.2.1 Land Use 8 JAFNPP is located in an unincorporated and pr imarily rural area approximately seven mi 9 northeast of Oswego, New York. Syracuse is the largest city within 50 mi of JAFNPP. Lake 10 Road (County Road 1A) provides road access to the site and transverses JAFNPP property in 11 an east-west direction just south of the plant. Exclusion distances for the JAFNPP site are 12 approximately 3000 ft to the east, over 1 mi to the west, and about 1.5 mi to the southern site 13 boundary. The nearest location with public access to the reactor building and any points of 14 potential gaseous effluents, with the exception of the lake shoreline, are at the northeast corner 15 of the property. The nearest residence lies outside the site boundary to the east-southeast at 16 0.71 miles (Entergy 2006c). See Figure 2-2.

17 JAFNPP features include the reactor building, turbine building, administration building and 18 control room, ISFSI, and several support facilities. The most prominent feature on the site is the 19 off-gas stack, which is 385 ft high. Only 3 percent of the site is occupied by JAFNPP structures, 20 with the remainder consisting of forest shrub, grasslands, and wetlands or ponds (Entergy 21 2006c). See Figure 2-3.

22 The site lies mainly within the Erie-Ontario Lowlands physiographic province. This province 23 consists of a relatively flat plain that rises gently from Lake Ontario to the Appalachian Uplands, 24 which form the province's southern border. Erie-Ontario Lowlands are bounded on the east by 25 Tug Hill Upland, through which small portions of the transmission line pass. The site is a 26 generally flat and featureless plain. It has an elevation of 270 ft rising to 310 ft 1 mi away at the 27 southern extremity. The surface soils are deriv ed from bouldery-ablation tills that immediately 28 overlay a compact basal till lying on bedrock (AEC 1973).

29 2.2.2 Water Use 30 Water use associated with the operation of JAFNPP consists of fresh water drawn from Lake 31 Ontario used primarily for cooling. Water from Lake Ontario is used for the cooling and auxiliary 32 systems. JAFNPP receives its potable water from the City of Oswego. JAFNPP is not a direct 33 user of groundwater, and there are no plans for direct groundwater use in the future. There are 34 no production wells onsite (Entergy 2006c).

35 Plant and the Environment Draft NUREG-1437, Supplement 31 2-18 June 2007 2.2.3 Water Quality 1 JAFNPP is located on the southeastern shore of Lake Ontario, which is the furthest downstream 2 and smallest of all the Great Lakes, having a surface area of 7340 square miles. It is an 3 international body of water with the border of the United States and Canada being 4 approximately midway across the width of the lake. It has an average depth of 283 ft with a 5 maximum depth of 802 ft (EPA 2006d).

6 The combination of prevailing west-northwest winds over the lake area and the eastern flow of 7 water from Lake Erie results in the lake being dominated by a counterclockwise horizontal 8 circulation pattern. Although winds can play a major role in affecting localized lake water flow 9 patterns, currents on the southern shore of the lake often move in an easterly direction in a 10 relatively narrow band. Because Lake Ontario is the furthest downstream of all the Great 11 Lakes, its water quality is influenced not only by human activities on its own shores, but by 12 impacts on all the other Great Lakes as well. Approximately 80 percent of the influx of water to 13 Lake Ontario comes directly from Lake Erie via the Niagara River. The remaining 20 percent of 14 the influx comes from basin tributaries, groundwater and precipitation. Approximately 15 93 percent of Lake Ontario's water flows out through the St. Lawrence River with the remaining 16 7 percent being lost to evaporative processes. The estimated water retention time is 6 years 17 (EPA 2006d).

18 Changes in wind speed and direction on Lake Ontario can also contribute to vertical mixing of 19 lake water. Strong winds can cause upwelling and sudden oscillations of thermocline depth.

20 Strong easterly winds along the east-west axis of Lake Ontario will cause a surface drift to the 21 right, which can result in tilting of the thermocline. When the tilted thermocline is pushed along 22 the nearshore zone it can become so intense that an outbreak of cold hypolimnion water will 23 upwell to the surface in the nearshore environment and create a steep temperature gradient in 24 the lake center. An increase in longshore current velocity can be associated with these events 25 as well, increasing the dispersion of both pollutants and nutrients from the lake bottom along the 26 shore (EC 2000).

27 Both meteorological and hydrological processes are responsible for a seasonal thermal 28 response on the lake. Incoming solar radiation heats the surface waters of the lake, more so in 29 the summer, while changes in wind speed and direction aid in the mixing of these heated waters 30 to lower depths in the lake. The mean summer ambient temperature of Lake Ontario in the Nine 31 Mile Point area is approximately 67° Fahrenheit (F). Most of the lake is vertically stratified 32 during the summer (June through September) with warm surface waters (epilimnion) averaging 33 nearly 70°F and cool deeper waters (hypolimnion) ranging between 38.8 and 39.2°F. Mixing of 34 these strata begins as the thermocline breaks down during September as a result of surface 35 water cooling and continues until water temperatures are the same throughout the water column 36 (EC 2000). The date of this overturn varies annually due to short term weather patterns and 37 storms. The isotherms following the overturn tend to be parallel to the shore resulting in a 38 freezing of nearshore waters with the deeper offshore waters remaining open.

39 Plant and the Environment June 2007 2-19 Draft NUREG-1437, Supplement 31 Lake Ontario outflows, and thus lake water levels, are controlled by a series of dams on the 1 St. Lawrence River under the authority of the International St. Lawrence River Board of Control 2 (ISLRBC). The ISLRBC requires that Lake Ontario water levels be maintained within a target 3 range of 243 to 247 ft International Great Lakes Datum to support lake navigation and to provide 4 water for power production facilities on the lake. The target level of 243 ft is maintained from 5 April through November when lake water evaporation rates would be highest and the 6 St. Lawrence River is likely close to low-flow conditions (ISLRBC 2004).

7 Once an oligotrophic system, by 1970 Lake Onta rio was almost entirely eutrophic, caused by 8 high levels of anthropogenic nutrients (primarily phosphorous) and uncontrolled pollutant 9 discharge to the lake. The eutrophication of Lake Ontario was recognized as a serious water 10 quality problem by the U.S. and Canada and led to the creation of the bi-national Great Lakes 11 Water Quality Agreement (GLWQA) in 1972. Since then the lake has seen dramatic 12 improvement in water quality. Much of this improvement can be attributed to stricter controls on 13 land use in the Lake Ontario basin and lake-wide management plans sponsored by the GLWQA 14 that reduced levels of non-point source pollution entering the lake. However, changes in lake 15 water quality since the 1970s have altered the biological landscape within Lake Ontario.

16 Nutrient supplies and other environmental pressures have had direct effects on all trophic levels 17 within the lake ecosystem (Stewart et al. 1999).

18 The New York State Department of Environmental Conservation (NYSDEC) conducted a study 19 of water quality throughout New York State over the past 30 years, including selected basic 20 water quality parameters of Lake Ontario; this information is summarized in Table 2-2. Data 21 was collected in the Nine Mile Point area in 1972 and 1978, the City of Oswego water intake 22 (approximately 8 mi southwest of JAFNPP) in 1998 and 1999, and at the Monroe County water 23 intake (approximately 50 mi west of JAFNPP) in 2000 (NYSDEC 2000b).

24 Today, the largest source of pollutants and nutrients (including phosphorous and nitrogen) 25 entering Lake Ontario is through the Niagara River, which drains Lake Erie. As in the past, 26 additional nutrients also still enter the lake through runoff from agricultural lands, urban areas, 27 sewage outflows, and erosional processes. The NYSDEC water quality study indicated that 28 although over the past 30 years there have been general reductions in some pollutants, such as 29 phosphorous and dissolved solids, nitrogen inputs to Lake Ontario have increased. Runoff from 30 agricultural lands and atmospheric deposition are likely significant contributors to lake nitrogen 31 levels. 32 In another bi-national effort, in 1989 the U.S. and Canada developed the Lake Ontario Toxics 33 Management Plan. The plan addressed persistent bioaccumulative and toxic chemicals (PBTs), 34 which include mirex, polychlorinated biphenyls (PCBs) and dioxins (NYSDEC 2000b). PBTs 35 enter Lake Ontario through various tributaries and have historically accumulated in sediments at 36 the bottom of the lake. Several portions of Lake Ontario's New York shoreline are classified by 37 the NYSDEC as "impaired," requiring total maximum daily load (TMDL) development in order to 38 reduce the input of the specific pollutants (NYSDEC 2006g). Some Lake Ontario biota saw 39 Plant and the Environment Draft NUREG-1437, Supplement 31 2-20 June 2007 reductions in toxic chemical concentrations from the 1960s through the 1980s that were 1 generally attributed to restrictions placed on the manufacture and use of PBTs, but those 2 declines have since leveled off. This may be due in part to the sequestration of chemicals in the 3 benthic lake sediments. Consumption advisories for certain lake fish species continue to be 4 issued by NYSDEC based on PBT levels found in some fish samples (NYSDEC 2000b).

5 Table 2-2. Selected Water Quality Parameters of Lake Ontario 6 Year Parameter 1972(a) 1978(b) 1998-99 (c) 2000(e) pH 8.0 8.4 7.96 7.6 Total alkalinity (mg/L) 72-90 94.2 92 83 Total phosphorus (mg/L) 0.01-0.28 0.027 0.006 (d) 0.005 (d) Total dissolved solids (mg/L) 107-186 202 NA 160 Total nitrates (mg/L) 0.04-0.40 < 0.18 NA 0.34 Turbidity 2-6 JTU 3.0 NTU 0.5 NTU 0.09 NTU mg/L = milligram(s) per liter JTU = Jackson Turbidity Unit(s) NTU = Nephelometric Turbidity Unit(s) (a) Source: AEC 1974 (b) Source: NMPC 1985 (c) Source (except total phosphorus): Heritage Power 2000 (d) Source: EPA 2005 (e) Source (except total phosphorus): MCWA 2001; pH and alkalinity data are from water distribution system and not from ambient lake water 7 JAFNPP uses a Betz Clam-Trol CT-1 (a chlorine-based molluscicide) program within their 8 service and cooling water systems to control zebra mussels (Dreissena polymorpha) and 9 quagga mussels (D. bugensis). The site-specific SPDES permit limits the administration of the 10 molluscicide program to a maximum of four times per year and includes special conditions for 11 outfall monitoring during applications and strict discharge limitations (Entergy 2006c). Biofouling 12 control at JAFNPP is achieved through the applicat ion of sodium hypochlorite in the service 13 water system and the condenser waterboxes. Sodium hypochlorite injection occurs 14 continuously, but at a concentration and volume that does not result in the exceedance of the 15 SPDES limit of 0.2 parts per million (ppm) total residual chlorine (TRC), as measured in the 16 discharge canal. Waterbox chlorination is limited to two hours per day, not to exceed a total of 17 nine hours per week, and during daytime hours only when ichthyoplankton entrainment levels 18 are historically low. The JAFNPP SPDES permit also prescribes a waterbox chlorination 19 limitation of 0.2 ppm TRC (Entergy 2006a).

20 Plant and the Environment June 2007 2-21 Draft NUREG-1437, Supplement 31 Treated effluent from the sanitary waste wate r treatment system is regulated as Outfall 012 1 before discharging into a drainage ditch that flows into Lake Ontario. The effluent is monitored 2 for flow, biochemical oxygen demand, suspended solids, settable solids, fecal coliform, pH, and 3 total residual chlorine. Maximum permitted flow is 60,000 gpd as a 30-day average. During 4 2006, daily flow ranged from 400 to 25,000 gpd (Entergy 2006c).

5 JAFNPP operates in accordance with applicable local, State, and Federal discharge limitations 6 (Entergy 2006c). The NRC staff review of the past five years of JAFNPP SPDES reports found 7 no notices of violation.

8 Groundwater is available in the Nine Mile Point area from both confined and unconfined 9 aquifers. There are four hydrostratigraphic units in existence within the JAFNPP site area: non-10 lithified sediments and soils, the Oswego Sandstone, the Pulaski Formation and the Whetstone 11 Gulf Formation, in descending order. The unconfined aquifer is composed of clay-rich soils 12 derived from glacial till and the uppermost portion of the Oswego Sandstone. Due to the 13 increase of interbedded silts and clays within the Oswego Sandstone at depth, the sandstone 14 becomes relatively impermeable at 20 ft. The first confined aquifer lies in both the lower portion 15 of the Oswego sandstone and uppermost portion of the Pulaski Formation, which is composed 16 of sandstone, siltstone and shale. An additional confined aquifer lies within the Pulaski 17 Formation at depth within a sandstone unit bounded by siltstone and shale. The underlying 18 Whetstone Gulf Formation has a low permeability as it is dominated by black shales with 19 interbedded sandstone and siltstones. All three aquifers are confined under pressure and would 20 result in artesian wells if utilized at the surface.

21 Within a two mile radius of JAFNPP, the local water table elevation varies from 300 to 246 ft 22 National Geodetic Vertical Datum with an average gradient of 0.7 percent to the north-northwest 23 (toward Lake Ontario). The normal groundwater level within the site boundary is approximately 24 255 ft and can have annual variations of up to 2 ft.

25 Groundwater recharge in this area occurs as a result of precipitation and localized seepage 26 from ponds and swamps through the surface soils into the unconfined aquifer. Due to the low 27 permeability of the clay-rich soils in the immediate vicinity of the site, most of the precipitation 28 runs off toward surface culverts or directly toward Lake Ontario. Groundwater recharge to the 29 Oswego Sandstone most commonly occurs through filtration of water through the unsaturated 30 zone of the unconfined aquifer and can also occur directly through local outcrops located to the 31 south and southeast of JAFNPP. Recharge to the lower confined aquifers occurs through 32 fractures in the Oswego Sandstone or directly through surface outcrops upgradient of the site.

33 Due to a permeability of 1 x 10

-5 cm/s and an average gradient of 0.7 percent, groundwater 34 velocity within the unconfined aquifer is estimated at a few yards per year.

35 Plant and the Environment Draft NUREG-1437, Supplement 31 2-22 June 2007 2.2.4 Climate, Meteorology, and Air Quality 1 2.2.4.1 Climate 2 The climate of western New York State is repres entative of the humid continental type, warm 3 summer subtype. The climate is designated Dfb in the Koeppen system and is sometimes 4 referred to as hemiboreal. Typical of the Dfb climate zone, weather changes between summer 5 and winter are very large around the JAFNPP site with cold, snowy winters and long, warm (not 6 hot) summers. Latitude, topography, and proximity to large bodies of water such as Lake 7 Ontario have a profound effect on the climate and short-term weather.

8 JAFNPP's proximity to Lake Ontario makes it subject to locally extreme amounts of precipitation 9 in the winter. This phenomenon, called "lake effect snow," is produced when cold arctic air 10 crosses the warmer lake, absorbing water vapor, which then falls as precipitation on the 11 adjacent shore. The elevated areas south and east of JAFNPP frequently set daily records for 12 snowfall in the Untied States because the lake effect snow is enhanced by orographic uplift.

13 The following climatological data is based on 30 years of observations (from 1971 to 2000) from 14 the nearest National Oceanic and Atmospheric Administration (NOAA) station in Oswego, New 15 York (NOAA 2004a). Average minimum temperature in January was 16.7°F, and average 16 maximum temperature in July was 80.0°F. Month-long average temperatures ranged from 17 23.6°F in January to 70.8°F in July. Average monthly precipitation ranged from 2.83 in. in 18 February to 4.47 in. in November. Average annual precipitation was 42.9 in. Precipitation 19 occurred almost uniformly throughout the year, caused by advancing polar fronts in the winter 20 and advection of tropical moisture in the summer.

21 2.2.4.2 Meteorology 22 Meteorological measurements for JAFNPP are collected nearby at the Nine Mile Point Nuclear 23 Station through an agreement between the two managing companies (Entergy and 24 Constellation Nuclear, respectively). Measurements are made from a 200-ft main tower and 25 also at a nearby shorter tower (approximately 100 ft). At the main tower, winds and temperature 26 are measured at three levels-at 30, 100, and 200 ft. The Nine Mile Point meteorological 27 system determines atmospheric stability by using the EPA-approved Delta-T method. More 28 information on the main tower and the data collected there is in the Nine Mile Point 29 Environmental Impact Statement(NRC 2006, Section 2.2.4).

30 Severe thunderstorms with winds exceeding 58 mph and/or property damage occur an average 31 of five days per year in Oswego County (2001 through 2006) (NOAA 2004b). Since 1950, eight 32 tornadoes have been reported in Oswego County (NOAA 2004b). The strongest tornado 33 Plant and the Environment June 2007 2-23 Draft NUREG-1437, Supplement 31 reached F3 (1) strength near the town of Phoenix on May 2, 1983, and resulted in no injuries.

1 The other seven tornadoes were categorized as F1 or lower. One of these struck a mobile 2 home, resulting in minor injuries to three people. The probability of a tornado striking JAFNPP 3 is estimated to be 3 x 10

-3 in a reactor's licensing period of 40 years (Entergy 2001).

4 Wind resources are expressed in terms of wind power classes ranging from Class 1 to Class 7.

5 Each class represents a range of mean wind power density or approximate mean wind speed at 6 specified heights above the ground. The wind energy resource for most of the Lake Ontario 7 shoreline of Oswego County is rated between Class 3 and 4 (Renewable Resource Data Center 8 2004, Figure 3-25). Areas designated as Class 3 or greater are suitable for most wind energy 9 applications.

10 2.2.4.3 Air Quality 11 JAFNPP is located in Oswego County which is part of the Central Air Quality Control Region 7 12 of the New York State Department of Environmental Conservation. With the exception of 13 ozone, Region 7 is designated as being in attainment of or as unclassifiable for all criteria 14 pollutants, as defined in 40 CFR 81.333. Jefferson County, northeast of Oswego County, is 15 designated as a nonattainment area for ozone and classified as moderate for the 8-hour ozone 16 National Ambient Air Quality Standards and marginal for the 1-hour. The Clean Air Act 17 established Class 1 Federal Areas where visibility is important. No areas designated as 18 Prevention of Significant Deterioration Class I are within 62 mi of JAFNPP.

19 There are four emergency diesel generators, two diesel fire pumps, and two auxiliary boilers on 20 the JAFNPP site. The emergency generators and fire pumps are exempt from air permitting 21 due to the small size and limited usage of these units. Emission from the boilers is regulated 22 under a Certificate to Operate an Air Contamination Source (7-3556-00020/00012) issued by 23 NYSDEC. This certificate limits fuel usage, fuel type, and hours of operation of the boilers.

24 2.2.5 Aquatic Resources 25 Lake Ontario is the source of water for the circulating and service water system at JAFNPP.

26 Station discharge from both the main condenser and service water system is returned to the 27 lake. Site drainage includes two offsite ditches on either side of the plant and two onsite storm 28 sewer outfalls; all ditches and outfalls discharge to Lake Ontario and are regulated under the 29 plant's SPDES permit (Entergy 2006c). There are no natural watercourses onsite. Associated 30 transmission corridors cross 60 watercourses of which seven are classified by the New York 31 State Water Resources Commission as suitable for water supplies and 27 for agriculture and 32 industry (AEC 1973).

33 (1) The Fujita six-point scale (F0 to F5) is used to rate the intensity of a tornado based on the damage it inflicts to structures and vegetation. Lowest intensity is F0; highest is F5.

Plant and the Environment Draft NUREG-1437, Supplement 31 2-24 June 2007 Lake Ontario, the source and the receiving water body for JAFNPP, is last in the chain of Great 1 Lakes. It is the smallest of the five Great Lakes and with a watershed of 24,720 mi 2 , Lake 2 Ontario has the highest ratio of watershed land area to lake surface area of all the Great Lakes 3 (EPA 2006a). The lake's drainage basin is almost evenly split between the province of Ontario 4 and the state of New York. Approximately 7 percent of the drainage basin is urbanized: major 5 industrial centers on the lake shore include Hamilton and Toronto in Ontario and Rochester in 6 New York. Although not categorized as urban, the Syracuse-Oswego area in New York is 7 relatively densely populated. Forests cover about 49 percent of the basin, with agriculture 8 practiced over approximately 39 percent. In general, the New York shoreline is less urbanized 9 than the Canadian shoreline and is not intensively farmed (Stewart et al. 1999).

10 Shipping is a major activity on Lake Ontario and has encouraged the development of 11 manufacturing industry and port cities. The Port of Oswego, approximately 6 mi west of 12 JAFNPP, had an overall annual tonnage of 457,770 in 2002. The port has a main channel 13 depth of 27 ft, and its primary cargoes include aluminum, potash, urea, limestone, salt, cement, 14 and petroleum products (GLSLSS 2006). Lake Ontario also supports a minor commercial 15 fishing industry, grossing just $46,000 in 2004. Recreational fishing is much more important to 16 the Lake Ontario area, with the total economic value to coastal communities estimated to range 17 from $100 million to more than $200 million per year (EPA 2006c).

18 Lake Ontario has two major basins: Kingston Basin, which is shallow and in the northeastern 19 corner of the lake, and a deeper main basin that covers the majority of the lake. The bottom of 20 Lake Ontario is relatively smooth with the exception of the sill that separates the Kingston and 21 main basins. The main basin is further split into three sub-basins: Rochester, Mississauga, and 22 Niagara (from east to west). With the majority of the lake's water coming in from the Niagara 23 River and the prevailing west-southwest winds, circulation in Lake Ontario flows in an easterly 24 direction along the southern and eastern shores and within sub-basins of the lake (EPA 2006b).

25 Being a relatively deep lake, Lake Ontario experiences seasonally dependent horizontal and 26 vertical thermal stratification. Stratification occurs when different water temperatures create 27 different water densities, which prevents mixing. Horizontal stratification occurs in the main 28 basin between near-shore and offshore zones and lasts from mid-autumn until approximately 29 mid-June when offshore waters finally warm and mixing can occur. For the remainder of the 30 summer, main basin waters are vertically stratified, meaning that warm surface waters do not 31 mix with cool, deeper waters. The vertical stratification begins to break down during September 32 when surface waters begin to cool and slowly sink and mix with deeper waters. Mixing 33 continues until an isothermal condition prevails throughout the winter (EPA 2006b). During the 34 winter months, inshore areas of Lake Ontario freeze, but of all the Great Lakes, Lake Ontario 35 has the least amount of ice cover, with typically 85 percent of the lake ice-free throughout the 36 winter. In general, waters are warmer in the southeastern portion of the lake and cooler in the 37 northwestern portion. Lake water temperatures typically range from 32 to 39.2°F in January and 38 from 53.6 to 68°F in July (PC 2006).

39 Plant and the Environment June 2007 2-25 Draft NUREG-1437, Supplement 31 Lake Ontario is oligotrophic with low primary productivity-roughly half that of Lake Erie. Lake 1 water clarity ranges from 16.4 to 32.8 ft. Over the years, the trophic status of Lake Ontario has 2 continually been influenced by human activities, including point-source pollution from industry 3 and waste disposal and non-point source pollution from agriculture and urban development.

4 The lake is affected not only by its drainage basin but also by being the most downstream Great 5 Lake. Thus, pollution sources in the upper Great Lakes impact Lake Ontario as well (EPA 6 2006b). 7 Since the first Euro-Americans arrived in the Great Lakes area, Lake Ontario has experienced 8 ecological stress that included overfishing, anthropogenic eutrophication, land-use changes, 9 contaminant discharge, loss and degradation of critical habitat, colonization of invasive species, 10 and substantial declines and profound changes in fish communities (NYSDEC 2004).

11 Lake Ontario was an oligotrophic system prior to European colonization of the Great Lakes 12 area. However, with increasing industrial development on the northern shore of the lake and 13 the subsequent increase in nutrient inputs (anthropogenic sources of phosphorous and 14 nitrogen), the lake experienced excess algal growth and became mesotrophic with inshore 15 areas becoming eutrophic. Phosphorous levels peaked in the 1960s and 1970s until water 16 pollution controls were implemented throughout the Great Lakes. Since then, nutrient levels in 17 the lake have declined, and the lake has returned to a more balanced oligotrophic state (Mills et 18 al. 2005; EPA 2006b).

19 Although water quality has improved over the last 20 years in response to lake-wide 20 management plans, the Lake Ontario ecosystem is still very much in transition. NYSDEC and 21 the Ontario Ministry of Natural Resources (OMNR) annually stock the lake with salmonids to 22 support a lucrative sport fishery. Non-native fish populations such as the alewife (Alosa 23 pseudoharengus) are highly dynamic with large fluctuations in population from year to year, and 24 pelagic zooplankton production is continually declining. Oligotrophic fish populations are slowly 25 recovering, and invasive species such as quagga mussels (Dreissena bugensis) and the 26 cladoceran waterflea (Cercopagis pengoi) are thriving (NYSDEC 2004; OMNR 2006).

27 There have been a series of milestones in the management of Lake Ontario. In 1955, the 28 Canadian/U.S Convention on Great Lakes Fisheries created the Great Lakes Fishery 29 Commission (GLFC). The GLFC is a bi-nati onal cooperative agency that coordinates fisheries 30 research and facilitates cooperative fishery management among the state, provincial, tribal, and 31 federal agencies. The GLFC is responsible for implementing the Joint Strategic Plan for 32 Management of Great Lakes Fisheries (GLFC 1994). Eight states bordering the Great Lakes, 33 the Province of Ontario, two intertribal agencies, and several federal agencies are signatory to 34 this management plan, working together and leveraging each others' resources to rehabilitate 35 native lake species, control exotic species, prevent and manage fishery diseases, coordinate 36 law enforcement, produce new research, publish state-of-the-lake reports, and determine total 37 allowable catch and allocation agreements and fish stocking levels (GLFC 2006).

38 Plant and the Environment Draft NUREG-1437, Supplement 31 2-26 June 2007 The GLFC also funded the 1971 Salmonid Communities in Oligotrophic Lakes (SCOL-1) 1 symposium, which examined the effects of cultural eutrophication, exploitation, and exotic 2 species introduction on salmonid communities in the five Great Lakes. In 2004, these issues 3 were revisited in a second symposium (SCOL-2) with an emphasis on linkages between trophic 4 levels (GLFC 2007).

5 In 1972, the first Great Lakes Water Quality Agreement (GLWQA) was signed between the 6 International Joint Commission (IJC) of Canada and the United States. Both countries pledged 7 to address the deterioration of Great Lakes water quality from point source and non-point 8 source pollution. A new GLWQA was signed in 1978 that outlined a commitment to restoring 9 and maintaining the "chemical, physical, and biological integrity" of the Great Lakes. In 1987, 10 the IJC drafted a protocol that focused on the overall human and aquatic ecosystem health of 11 the Great Lakes. Remedial action plans and lake-wide management plans were developed that 12 implemented an ecosystem approach to improving the Great Lakes waters. The plans are 13 designed to work in concert with local resource management plans, such as those that address 14 a specific fishery (IJC 2004).

15 Close to JAFNPP, the Little Salmon and Oswego rivers are two of the ten major tributaries that 16 feed Lake Ontario. Both rivers have been designated by the NYSDOS Division of Coastal 17 Resources as "Significant Coastal Fish and Wildlife Habitats." Little Salmon River empties into 18 Lake Ontario at Mexico Point near the town of Mexico, approximately 10 mi east of JAFNPP.

19 The river provides an important fish spawning and nursery area and supports large 20 concentrations of warmwater species including northern pike (Esox lucius

), largemouth bass 21 (Micropterus salmoides), rock bass (Ambloplites rupestris), white sucker (Catostomus 22 commersonii

), and brown bullhead (Ameiurus nebulosus). Little Salmon River is one of the 23 primary salmonid habitats in eastern Lake Ontario. As a result of NYSDEC's ongoing sport 24 fishery stocking program, Chinook salmon (Oncorhynchus tshawytscha

), coho salmon 25 (Onchorhynchus kisutch

), brown trout (Salmo trutta), and steelhead trout (Oncorhynchus 26 mykiss) can also be found in Little Salmon River during spawning periods (NYSDOS 2006).

27 The Oswego River is located in the city of Oswego, approximately 4 mi west of JAFNPP. Land 28 along this river has been impacted by extensive human disturbance, including a number of locks 29 and dams that impede or act as barriers to fish migrating upriver to spawn. However, the river 30 is still an important habitat for warmwater fish species including alewife, gizzard shad (Dorsoma 31 cepedianum

), brown bullhead, white perch (Morone americana

), yellow perch (Perca 32 flavescens), smallmouth bass (Micropterus dolomieu), largemouth bass, walleye (Sander 33 vitreus), pumpkinseed (Lepomis gibbosus), and black crappie (Pomoxis nigromaculatus

). The 34 river is the primary spawning and nursery area for walleye in the Oswego County area, and in 35 1982, lake sturgeon (Acipenser fulvescens) were also spotted in the river, making it the only 36 Lake Ontario tributary that historically supported this species. Stocked salmonids also attempt 37 to use this river for spawning (NYSDOS 2006).

38 Plant and the Environment June 2007 2-27 Draft NUREG-1437, Supplement 31 Lake Ontario offshore waters have been dominated historically by lake trout (Salvelinus 1 namaycush), Atlantic salmon (Salmo salar), deepwater sculpin (Myoxocephalus thompsoni

), 2 coregonids (Coregonus spp.), and burbot (Lota lota). By the 1970s, Lake Ontario's major native 3 fish stocks were near extinction as a result of cumulative ecological stressors including 4 overfishing, anthropogenic eutrophication, industrial pollution, degradation and loss of habitat, 5 and colonization of invasive species.

6 The external parasite, sea lamprey (Petromyzon marinus), was also seriously impacting fish 7 populations. Populations of the sea lamprey, an invasive species, sharply increased in the early 8 1900s, coincident with high numbers of lake trout. It is believed that commercial fishing and sea 9 lampreys acted together to drive large piscivores in Lake Ontario to near extinction (Mills et al.

10 2005). Atlantic salmon, deepwater sculpin, lake trout, burbot, and coregonids all but 11 disappeared, while non-native fish such as alewife, rainbow smelt (Osmerus mordax

), and white 12 perch proliferated. Alewife, a planktivore fish that is prey for large piscivores, first appeared in 13 Lake Ontario by the late 1800s, and in the absence of abundant piscivores, the alewife 14 population exploded. Rainbow smelt experienced significant increases around the same time 15 and were implicated in the decline of native cisco (Coregonus artedii) populations (Jackson 16 1997). 17 In 1968, the first year of what were to become annual releases, brown trout, Chinook salmon, 18 coho salmon, and steelhead trout were stocked to reduce alewife populations and create a sport 19 fishery. Between 1968 and the late 1980s, salmonid stocking rates rose steadily to more than 8 20 million individuals per year. Concurrently, water conditions were improving and Lake Ontario 21 returned to an oligotrophic system, but by 1990, the high rates of salmonid stocking and the low 22 lake nutrient levels were affecting the Lake Ontario food web-including decreases in the size of 23 salmon returning to spawn and reduced angler harvest rates, likely due to a reduction in prey.

24 Current combined NYSDEC and OMNR salmonid stocking rates have been maintained 25 between 4.0 and 5.5 million individuals per year. Improvements in habitat and water quality 26 have resulted in the decline of Lake Ontario's carrying capacity at all levels. Food web studies 27 of the lower trophic levels conducted in the 1980s and 1990s indicated declines in algal 28 abundance (phytoplankton) and zooplankton biomass and production. Because phytoplankton 29 and zooplankton rely on the very nutrients that impact water quality, the effect of nutrient 30 reductions extends into the food web (Jackson 1997; Mills et al. 2003).

31 Currently, growth of stocked salmonids is sustained primarily by alewife populations and to a 32 lesser degree by rainbow smelt and slimy sculpin (Cottus cognatus

). Salmonid predation has 33 been so excessive that the present alewife population has been reduced almost entirely to pre-34 reproductive individuals: from the early 1980s to the 1990s, the alewife population declined 35 42 percent (Jackson 1997).

Alewives are the primary planktivores in Lake Ontario, and 36 historically, intense feeding pressure on large plankton species by the alewife population has 37 selected for smaller species. The precipitous alewife population decline has subsequently 38 changed the Lake Ontario plankton community-there has been a shift from smaller to larger 39 zooplankton species. Zooplankton have an intermediate position in the Lake Ontario food web 40 Plant and the Environment Draft NUREG-1437, Supplement 31 2-28 June 2007 and are an important link between phytoplankton and fish. Larger zooplanktons also feed on 1 smaller zooplankton species, and the presence of large zooplankton therefore competes with 2 other invertebrates and fish for smaller zooplankton prey (NYSDEC 2004).

3 The lower food web declines in Lake Ontario were likely exacerbated by the new presence of 4 exotic (invasive) species. By the 1990s, exotic species, including the zebra mussel; the quagga 5 mussel; the amphipod Echinogammarus ischmus, a non-native cladoceran; the round goby 6 (Neogobius melanostomus); and the bloody red shrimp (Hemimysis anomala) had been 7 introduced to the Great Lakes via transoceanic shipping. Through their efficient phytoplankton 8 grazing and ability to cover any available substrate quickly and entirely, zebra and quagga 9 mussels significantly increased water clarity throughout the 1990s, causing profound impacts 10 throughout the food web. Historically, the native amphipod Diporeia spp. accounted for 60 to 80 11 percent of Lake Ontario's benthic community. However, the spread of dreissenid mussels 12 altered Lake Ontario's benthic habitat. Diporeia spp. declined after dreissenid introduction, 13 impacting bottom fish species including native lake whitefish (Coregonus clupeaformis) (Mills et 14 al. 2003). More recent benthic studies indicate that quagga mussels have largely replaced 15 zebra mussels in all benthic habitats of Lake Ontario; this transition may have occurred due to 16 round goby predation on zebra mussels. Since first appearing in Lake Ontario in 1998, the 17 round goby, an aggressive, bottom-dwelling fish, has established itself in Lake Ontario and is 18 expected to trigger further changes in the bent hic community. Additionally, where round gobies 19 have become abundant, numbers of native bottom-dwelling fish have declined, such as 20 tessellated darters (Etheostoma olmstedi) and sculpins (Cottidae spp.) (Stewart et al. 1999).

21 Despite other improvements in the Lake Ontario ecosystem, the unintentional introduction of 22 non-native species to the benthic, planktonic and fish communities will likely prevent Lake 23 Ontario from ever returning to its original state.

24 The reduction in available nutrients combined with the increased penetration of light and 25 extended, seasonal, warm water periods, has also resulted in the return and increased growth 26 of submerged aquatic vegetation, primarily filamentous Cladophora spp. The vegetation 27 coverage provides protection and nursery areas for a number of invertebrate and fish species 28 (NYSDEC 2003). However, the increasing clarit y of Lake Ontario water may cause a shift of 29 some light-sensitive fish species, such as the walleye, to relocate into deeper waters (Stewart et 30 al. 1999).

31 There are no aquatic species Federally listed as threatened or endangered under the 32 Endangered Species Act (ESA) in the vicinity of JAFNPP (Entergy 2006b). Through 33 consultation with the U.S. Fish and Wildlife Service (FWS), no aquatic species (fish, molluscs, 34 or aquatic plants) were identified as potentially occurring at the site or in watercourses along or 35 across the associated transmission corridors.

36 Five aquatic species that have been designated by New York State as threatened, endangered, 37 or a species of special concern and that may occur in the vicinity of JAFNPP are listed in Table 38 2-3. There were no reported takings of these fish at JFNPP in 2004 (EA 2005).

39 Plant and the Environment June 2007 2-29 Draft NUREG-1437, Supplement 31 Table 2-3. Aquatic Species Listed as Endangered, Threatened, or a Species of Special 1 Concern by New York State, Potentially Occurring in Oswego and Onondaga Counties 2 Scientific Name Common Name Federal StatusState Status Acipenser fulvescens lake sturgeon

- T Erimyzon sucetta lake chubsucker

- T Lythrurus umbratilis redfin shiner

- S Myoxocephalus thompsoni deepwater sculpin

- E Prosopium cylindraceum round whitefish

- E - = No listing E = Endangered S = Species of Special Concern T = Threatened Source: Entergy 2006c 3 State-threatened lake sturgeon (Acipenser fulvescens) are found primarily in freshwater lakes 4 and large rivers in northeastern North America. In New York, lake sturgeon have been found in 5 the St. Lawrence River, Lake Ontario, Lake Erie, the Niagara River, Lake Champlain, Cayuga 6 Lake, the Seneca Canals, and in the Grasse, Oswego, and Oswegatchie rivers. The Oswego 7 River is a historic spawning ground for lake sturgeon and is the only Lake Ontario tributary 8 where lake sturgeon have been found in recent years. One of New York's largest freshwater 9 fish, mature adults are between 3 and 5 ft long and weigh between 10 and 80 pounds (lb). Lake 10 sturgeon subsist primarily on small organisms: leeches, snails, clams and other invertebrates, 11 small fish, and algae. They spawn from May to June in areas with clean, large rubble such as 12 along windswept rocky shores and in the rapids of streams. Young fish grow rapidly but have a 13 slow reproductive cycle: females do not reach sexual maturity until they are 14 to 23 years old, 14 and they spawn only every four to six years during their 80-year lifespan. Lake sturgeon were 15 historically abundant, but as their value increased, population levels decreased significantly due 16 to overfishing. Other threats to lake sturgeon include the construction of dams that cut off 17 upstream spawning grounds, channelization, and pollution (NYSDEC 1999e; WSG 2006).

18 Lake chubsuckers (Erimyzon sucetta), a State-threatened species, are medium-sized with an 19 average length of 8 to 10 in. They are found only in quiet, clear, well-vegetated waters because 20 they are intolerant of turbid or silty conditions. Lake chubsuckers feed along the water bottom 21 on copepods, cladocerans, and aquatic insect larvae. In New York, lake chubsuckers were 22 historically found in embayments along the south shore of Lake Ontario and the eastern shore 23 of Lake Erie. No lake chubsuckers have been caught in New York for more than 60 years.

24 Siltation, wetland drainage, increased water turbidity, and pollution have likely caused the 25 decline or extirpation of this species (ROM 2006; NYSDEC 1999b).

26 The redfin shiner (Lythrurus umbratilis), a State species of special concern, occurs in the Great 27 Lakes and Mississippi River Basin, western New York to Minnesota, south to Louisiana, and 28 Gulf drainages west to Texas. The redfin shiner is essentially a pool dweller but can also be 29 Plant and the Environment Draft NUREG-1437, Supplement 31 2-30 June 2007 found in moderate- to low-gradient streams with some vegetation and sand or gravel bottoms.

1 Within New York, the redfin shiner has been found only at a few sites in Tonawando Creek, the 2 Niagara River, and Johnson Creek. Redfin shiners are found in schools feeding on filamentous 3 algae, bits of higher plants, and aquatic and terrestrial insects. They become sexually mature in 4 their second or third summer and spawn from early June to mid-August in nests within sunfish 5 nesting territories. One reason for their low occurrence may be that they require clear water 6 during spawning, but the rest of the year they can tolerate siltation (NYSDEC 1999d; WSG 7 2006). 8 The State-endangered deepwater sculpin (Myoxocehalus thompsoni) is the largest of New 9 York's freshwater sculpins; they can be up to 9 in. long but average length is 2 to 5 in.

10 Deepwater sculpin are found in deep, cool lake waters at depths ranging from 240 to 300 ft.

11 Found in all the Great Lakes except for Erie, the deepwater sculpin was once prolific in Lake 12 Ontario. Competition with alewife and rainbow smelt, as well as alewife and rainbow smelt 13 predation on sculpin eggs and larvae, may have caused a decline in the deepwater sculpin 14 population-the species was thought to be extirpated until catches were reported from 1996 to 15 1999. The deepwater sculpin is a bottom feeder, so continual exposure to contaminated 16 sediments may be another possible cause for their decline. NYSDEC identified the non-native 17 round goby as another potential source of competition for this species (NYSDEC 1999a; OME 18 1999). 19 The State-endangered round whitefish (Psosopium cyclindraceum) has an average length of 20 8 to 12 in., occasionally reaching 22 in. This species feeds primarily at or near the bottom on 21 small aquatic organisms, including eggs of lake trout and other fish. Round whitefish were 22 historically found in all the Great Lakes except Lake Erie; only seven New York State waters are 23 known to contain round whitefish populations. Lake Ontario once supported a small round 24 whitefish commercial fishery, but the last commercial catch was in 1942. Round whitefish are 25 now protected from harvest or possession by the State of New York Endangered Species Law.

26 Reasons for the species' decline may include predation by yellow perch on round whitefish eggs 27 and fry, loss or degradation of spawning sites, siltation, and lake acidification (WSG 2006; 28 NYSDEC 1999c).

29 2.2.6 Terrestrial Resources 30 2.2.6.1 Terrestrial Resources at the JAFNPP Site 31 JAFNPP is on a flat plain 20 ft above the shore of Lake Ontario, with hills to the immediate 32 south of the property (USGS 1982). As part of the Erie and Ontario Lake Plain ecoregion, this 33 area was shaped by glacial erosion and deposition processes (NYSDEC 2006d). After the last 34 glacial period, which ended between 19,000 and 11,000 years ago (PRI 2006), the region was 35 colonized by vegetation that probably consisted of upland forest and wetland communities (NRC 36 2006). 37 Plant and the Environment June 2007 2-31 Draft NUREG-1437, Supplement 31 Typical natural communities in this area vary, depending on the underlying geology and soils, 1 but include beech-maple, maple-basswood, and hemlock-northern hardwood forests; 2 grasslands; shrub lands; and wetland communities (SUNY Oswego 2006a). When the property 3 was purchased by Entergy, it was partially forested and being used for recreation and 4 residential purposes (Entergy 2006). The area was once used as an artillery range (AEC 1973).

5 Currently, the area immediately around the plant is maintained in a landscaped condition. The 6 majority of the property (600 ac) is not landscaped and is expected to develop to climax 7 communities unless further disturbed.

8 Dominant communities on the site include 66 percent forest, 21 percent open grasslands, and 9 10 percent wetlands and ponds (Entergy 2006c). These areas are in various states of 10 succession, ranging from early grassland/meadow communities in recently disturbed areas to 11 secondary growth hardwood forests (Entergy 2006c). Common tree species include sugar 12 maple (Acer saccharum

), American beech (Fagus grandifolia

), Canadian hemlock (Tsuga 13 canadensis

), white ash (Fraxinus amerincana), basswood/American linden (Tilia americana

), 14 black birch / sweet birch (Betula lenta), yellow poplar/tulip poplar (Liriodendron tulipifera

), and 15 oaks (Quercus spp.), including chestnut (Q. prinus), red (Q. rubra), black (Q. velutina), white 16 (Q. alba), and bur oaks (Q. macrocarpa) (AEC 1973). Surveys for rare plants have not been 17 performed at the site.

18 The FWS National Wetlands Inventory database indicates that there are wetland areas on site 19 (FWS 2006c). While no formal wetland delineation activities have been performed, Entergy 20 estimates that there are approximately 70 ac of wetlands and ponds on the property (Entergy 21 2006c). Swamps and arborvitae and cattail marshes are scattered throughout the area near the 22 site (AEC 1973).

23 A variety of mammals, birds, reptiles, amphibians, and insects are commonly seen at the 24 JAFNPP site and in the surrounding area. Reptiles including snakes, turtles, and tortoises may 25 be found in the area, as well as amphibians including frogs, toads, salamanders, and newts 26 (SUNY Oswego 2006c).

27 Migratory waterfowl frequent the site and congregate near the discharge area offshore. These 28 include greater scaup (Aythya marila

), golden eye (Bucephala clangula), merganser (Mergus 29 merganser), canvasback (A. valisineria

), and oldsquaw (Clangula hyemalis) (Entergy 2006).

30 The discharge area has been designated by the New York State Natural Heritage Program as 31 part of a waterfowl winter concentration area. Impingement of diving ducks has not been 32 observed at JAFNPP but has been an issue at the Nine Mile Point Nuclear Station just west of 33 JAFNPP (NRC 2006). Removal of zebra mussels (Dreissena polymorpha) and other food 34 sources from intake structures is considered an effective method of reducing the chances of 35 diving duck injury and mortality.

36 Other birds that may breed in the area include the red-shouldered hawk (Buteo lineatus

), sharp-37 shinned hawk (Accipiter striatus), Cooper's hawk (A. cooperii

), common nighthawk (Chordeiles 38 Plant and the Environment Draft NUREG-1437, Supplement 31 2-32 June 2007 minor), red-headed woodpecker (Melanerpes erthrocephalus), horned lark (Eremophila 1 alpestris), golden-winged warbler (Vermivora chrysoptera

), cerulean warbler (Dendroica 2 cerulean), vesper sparrow (Pooecetes gramineus), and grasshopper sparrow (Ammodramus 3 savannarum) (NRC 2006).

4 Common small mammal species in the area include the white-footed mouse (Peromyscus 5 leucopus), deer mouse (P. maniculatus), woodchuck (Marmota monax), meadow jumping 6 mouse (Zapus hudsonius

), meadow vole (Microtus pennsylvanicus), red squirrel (Tamiasciurus 7 hudsonicus

), raccoon (Procyon lotor), and cottontail rabbit (Sylvilagus floridanus) (NMPC 1985).

8 Larger mammals include red and gray foxes (Vulpes vulpes, Urocyon cinereoargenteus

), 9 coyotes (Canis latrans), and white-tailed deer (Odocoileus virginianus) (SUNY Oswego 2006b).

10 No wildlife management plans currently exist for the JAFNPP property. The site likely provides 11 productive habitat for wildlife, and hunting is not allowed on the property. Some animal mortality 12 may occur from vehicle collisions. Migratory bird collisions with buildings have been rare and 13 are not anticipated to be a significant source of in jury during the renewal term. Surveys for rare 14 animals have not been performed at the site.

15 The area around the plant is maintained through a combination of mowing and herbicide 16 application. Lawns are mowed as needed. Two drainage swales are vegetated with low-17 growing herbaceous cover, which should help to reduce and absorb runoff and protect water 18 quality while providing some habitat for small animals (EPA 2006c). No maintenance activities 19 occur around wetlands or Lake Ontario. RoundupŽ herbicide is used for weed control in 20 isolated locations by licensed applicators using hand sprayers. Entergy is required to submit 21 annual pesticide use reports to NYSDEC, listing qualified applicators. These reports estimate 22 herbicide use at 33 gallons (gal) in 2003, 30 gal in 2004, and 17 gal in 2005 (Entergy 2004b, 23 2005c, 2006d). When used according to label directions, such herbicide applications are not 24 expected to have significant environmental impacts.

25 Important terrestrial habitats near JAFNPP include Teal Marsh 4 mi west of the site, a rare 26 shrub fen 4 mi south of the site, and Butterfly Creek Wetlands 6 mi east of the site (NRC 2006).

27 Local parks where wildlife may comprise important recreational attractions include Selkirk 28 Shores State Park five mi east of the site, Fairhaven Beach State Park 20 mi southwest of the 29 site, and Beaver Lake Nature Center 25 mi south of the site (NYSHPO 2006a; NYSHPO 2006c; 30 Onondaga County Parks 2006). Little environmental interaction occurs between these areas 31 and the JAFNPP site, with the exception of bird travel between the site and these locations.

32 Ecological issues of statewide concern include chronic wasting disease (CWD) in white-tailed 33 deer (NYSDEC 2006a), botulism in shore birds (NYSDEC 2006e), and vegetation damage 34 resulting from caterpillars (NYSDEC 2006b) and wood wasps (NYSDEC 2006f). The NRC staff 35 is not aware of any linkage between continued operation of JAFNPP and these issues.

36 Plant and the Environment June 2007 2-33 Draft NUREG-1437, Supplement 31 2.2.6.2 Terrestrial Resources in Transmission Corridors 1 There are four transmission lines that connect JAFNPP to other facilities and substations 2 (Entergy 2006c). See Table 2-1. Two of the transmission lines, the Edic and Scriba 345-kV 3 lines, are within the scope of license renewal. The Edic transmission line runs approximately 4 70 mi southeast to the Edic Substation near Utica, New York. The corridor associated with this 5 line is 150-ft wide and crosses Erie-Ontario Lake plain and fringe areas of Tug Hill plateau and 6 the Mohawk Valley (AEC 1973). These areas are predominantly forested, with some 7 agricultural, low-density residential, and wetland areas (AEC 1973). Important resource areas 8 crossed by this line include Catfish Creek, Butterfly Creek, the Little Salmon River, Mohawk 9 River, Nine Mile Creek, numerous wetlands, and various state wildlife management areas 10 (Microsoft 2005).

11 The Edic line is owned and maintained by NYPA (Entergy 2006c). The NRC staff met with 12 NYPA personnel on December 4, 2006, to discuss t heir transmission line maintenance program.

13 NYPA maps land use and vegetative cover within the transmission corridor using a geographic 14 information system. This information is used to develop a maintenance plan for each mapped 15 parcel to remove only tall-growing species that may interfere with line operations, while allowing 16 other species to grow. Dead trees that may fall into the lines are removed from the edges of the 17 ROW by corridor maintenance personnel (NYPA 1998). Herbicides are applied to individual 18 plants by licensed applicators only as needed to ensure that that tall-growing vegetation does 19 not interfere with line operations. Maintenance personnel follow the NYPA Systemwide Right-20 of-Way Management Plan (NYPA 1998).

21 The transmission line towers are constructed of weathering steel, which requires little 22 maintenance and is less reflective than galvanized steel (AEC 1973). There is evidence that 23 some portions of the transmission line corridor are used by off-road vehicles and hunters, but 24 these activities appear to be limited in area and intensity.

25 Two invasive exotic plant species, common reed (Phragmites australis) and Japanese 26 knotweed (Polygonum cuspidatum), have been noted by NYPA personnel as occurring within 27 the Edic transmission corridor. Common reed is a threat to wetland areas because it crowds 28 out native vegetation and may negatively alter wildlife habitat. It is commonly controlled to 29 protect native species of plants and animals and promote a balanced, productive native 30 ecosystem. This is typically performed using herbicides, but mowing and controlled burns may 31 be effective in removing it (PCA 2006a). Japanese knotweed is an introduced species that can 32 rapidly crowd out native plant species and alter native ecosystems. It is commonly controlled 33 with diluted pesticides applied to a cut stem or to the leaves (PCA 2006b).

34 The eastern portion of the Edic transmission line passes near the towns of Annesville, Lee, 35 Western, Floyd, Trenton, and Marcy, where chronic wasting disease (CWD) in white-tailed deer 36 is an issue of concern (NYSDEC 2006c). This disease is contagious between deer and leads to 37 severe weight loss and death, but there is no evidence that it is transmissible to humans or 38 livestock (NYSDEC 2006a). NYSDEC is working to control the spread of CWD in this area.

39 Plant and the Environment Draft NUREG-1437, Supplement 31 2-34 June 2007 Continued operation and maintenance of the lines is not anticipated to contribute appreciably to 1 the spread of this disease among the white-tailed deer population.

2 The second transmission line within the scope of this license renewal review is the 345-kV 3 Scriba line. The Scriba line is approximately 4900 feet in length and runs southward from the 4 JAFNPP 345-kV switchyard over Entergy property, then turns westward, crossing a portion of 5 the Nine Mile Point Nuclear Station site and enters the Scriba substation. The portion of the 6 transmission corridor that is not on the JAFNPP site is maintained by NYPA, the owner of the 7 line. The Scriba line crosses forested and landscaped areas maintained by JAFNPP and NYPA 8 using periodic mowing and vegetation control procedures.

9 2.2.6.3 Terrestrial Species of Concern 10 Terrestrial species that are listed by the FWS or the State of New York and have the potential to 11 occur on or in the vicinity of the JAFNPP site or along the Edic and Scriba transmission 12 corridors are presented in Table 2-4.

13 The NRC staff met with NYPA on December 4, 2006. At this meeting, the NRC staff was 14 informed that no threatened or endangered species have been reported by maintenance 15 personnel as occurring in or near the transmission corridor. Corridor maintenance personnel 16 are trained in identifying endangered species and are expected to take measures to avoid 17 damage to these species if they are identified within the transmission line corridor during the 18 renewal period.

19 Consultation with New York Natural Heritage Program (NYNHP) revealed the existence of two 20 important natural heritage areas near the Edic transmission line corridor. The areas consist of 21 State-listed upland sandpiper (Bartramia longicauda) habitat and a rare fen. In addition, the 22 NYNHP staff identified the area immediately offshore from the JAFNPP site as an important 23 State-recognized waterfowl winter concentration area. The pied-billed grebe (Podilymbus 24 podiceps) and least bittern (Ixobrychus exilis) are known to forage nearby. Both species are 25 listed as threatened by the State of New York.

26 Table 2-4. Federally Listed and New York State-Listed Terrestrial Species Potentially 27 Occurring in the Vicinity of JAFNPP and in Associated Transmission Line Corridors 28 Scientific Name Common Name Federal Status State Status Reptiles Ambystoma jeffersonianum Jefferson salamander

- S Ambystoma laterale blue-spotted salamander

- S Clemmys guttata spotted turtle

- S Clemmys insculpta wood turtle

- S Plant and the Environment June 2007 2-35 Draft NUREG-1437, Supplement 31 Clemmys muhlenbergii bog turtle T E Crotalus horridus timber rattlesnake

- T Sisturus catenatus catenatus massasauga rattlesnake C E Birds Accipiter cooperli Cooper's hawk

- S Accipiter striatus sharp-shinned hawk

- S Ammodramus henslowli Henslow's sparrow

- T Ammodramus savannarum grasshopper sparrow

- S Aquila chrysaetos golden eagle

- E Asio flammeus short-eared owl

- E Bartramia longicauda upland sandpiper

- T Buteo lineatus red-shouldered hawk

- S Charadrius melodius piping plover E E Chlidonias niger black tern

- E Chordeiles minor common nighthawk

- S Circus cyaneus northern harrier

- T Cistothorus platensis sedge wren

- T Dendroica cerulean cerulean warbler

- S Eremophila alpestris horned lark

- S Falco peregrinus peregrine falcon

- E Gavia immer common loon

- S Haliaeetus leucocephalus bald eagle T - Ixobrychus exilis least bittern

- T Table 2-4 (cont.) Scientific Name Common Name Federal Status State Status Birds (cont.) Lanius ludovicianus loggerhead shrike

- E Melanerpes erythrocephalus red-headed woodpecker

- S Pandion haliaetus osprey - S Podilymbus podiceps pied-billed grebe

- T Sterna hirundo common tern

- T Vermivora chrysoptera golden-winged warbler

- S Mammals Myotis leibii small-footed bat

- S Myotis sodalis Indiana bat E E Plant and the Environment Draft NUREG-1437, Supplement 31 2-36 June 2007 Plants Carex chordorrhiza creeping sedge

- T Eleocharis quadrangulata angled spikerush

- E Eleocharis obtuse var. ovata blunt spikerush

- E Lycopodium complanatum northern running pine

- E Polygonum setaceum var. interjectum swamp smartweed

- E Polystichum archostichoides Christmas fern

- S Thelypteris noveboracensis New York fern

- S Trillium flexipes nodding trillium

- E Trillium sessile toad-shade

- E Trillium spp. trillium

- S - = No listing C = Candidate for federal listing E = Endangered S = Species of Special Concern (New York State) T = Threatened Source: Entergy 2006c (except creeping sedge) NYSDEC 2006g (creeping sedge) 1 Federally Protected Species 2 The endangered Indiana bat (Myotis sodalis

) is a chestnut-brown, medium-sized bat that 3 forages for insects near streamside and upland forests (FWS 2006b). These bats roost and 4 hibernate in caves or mines, known as hibernacula, or under the loose bark of recently dead 5 trees. Reasons for the decline of this species include natural mortality, human disturbance of 6 hibernating bats, and deforestation, especially the removal of dead standing trees and trees 7 near streams (FWS 1983). Indiana bats may be utilizing large dead trees with loose bark either 8 onsite or along the margins of the Edic or Scribal transmission corridors. There have been no 9 reports of Indiana bats using dead trees along the transmission corridors; however, there has 10 been no systematic survey of this potential habitat.

11 The threatened bog turtle (Clemmys muhlenbergii) is a very small black turtle that lives in open 12 sedge meadows and fens bordered by wooded areas (FWS 2001). The bog turtle's diet 13 consists primarily of insects but also includes plants, frogs, and carrion (Bury 1979). The 14 greatest threats to the bog turtle include the degradation and destruction of open wetland 15 habitat and illegal collection (Groombridge 1982). Two potential sources of habitat loss within 16 the transmission corridor, if such habitat is present, are the colonization by common reed and 17 the natural progression by trees. The common reed establishes a dense monoculture that is 18 unsuitable for many wetland species, including bog turtles (FWS 2001). Because the bog turtle 19 depends on open wetlands without any tree cover, the current transmission corridor 20 maintenance program may preserve potential bog turtle habitat. The NRC staff is unaware of 21 Plant and the Environment June 2007 2-37 Draft NUREG-1437, Supplement 31 any reported occurrences of bog turtles inhabiting wetlands along the Edic or Scriba 1 transmission corridors; however, there has not been a systematic survey of these lines for this 2 species. 3 Federally protected species identified in the review of Nine Mile Point include the massasauga 4 rattlesnake, bald eagle, and piping plover. The massasauga rattlesnake (Sisturus catenatus 5 catenatus) is a candidate species for Federal protection. It lives in wet prairies, sedge 6 meadows, and early successional fields, and natural succession of woody vegetation may 7 cause habitat deterioration (NRC 2006). It is not known to occur near the JAFNPP site.

8 The threatened bald eagle (Haliaeetus leucocephalus) is a large bird of prey that is usually 9 found near large bodies of water. The bald eagle is a transient species and is not found in the 10 vicinity of JAFNPP or associated transmission line rights-of-way.

11 The endangered piping plover (Charadrius melodius

) is a small, stocky sandy-colored bird 12 resembling a sandpiper. Like the bald eagle, it may migrate through the area, but are not found 13 in the vicinity of the JAFNPP site or associated transmission line rights-of-way (NRC 2006).

14 State-Protected Species 15 The NRC staff consulted with NYNHP on December 7, 2006 to determine which State-listed 16 species were known to occur near JAFNPP and the Edic and Scriba transmission lines. The 17 NYNHP identified three State-threatened bird species and one State-threatened plant species.

18 No other State-listed species were identified as occurring near the site on along the Edic and 19 Scriba transmission corridors.

20 The State-threatened upland sandpiper (Bartramia longicauda) is a small brown-and-white 21 mottled bird that inhabits open, grassy areas, including pastures, upland meadows, and fallow 22 fields. This species feeds on invertebrates and grains. It has declined due to excessive hunting 23 in the past and has not recovered from this historical stress (CDEP 2004b). One area of known 24 upland sandpiper habitat was identified by the NYNHP as occurring near the JAFNPP site.

25 The State-threatened pied-billed grebe (Podilymbus podiceps) is a diving duck that forages in 26 an area near the JAFNPP site. It lives in marshes and ponds and feeds mostly on aquatic 27 invertebrates, occasionally eating fish, reptiles and amphibians. Although this species is found 28 throughout North America, it is rare in New York (Cornell Laboratory of Ornithology 2003).

29 The State-threatened least bittern (Ixobrychus exilis) is found in emergent vegetation in 30 freshwater marshes not far from the JAFNPP site. It feeds on small fish, amphibians, insects, 31 invertebrates, and occasionally shrews and mice. Its decline is attributed to the destruction of 32 wetland habitat (CDEP 2004a).

33 The State-threatened creeping sedge (Carex chordorrhiza) is a wetland plant known to occur 34 near the JAFNPP site.

35 Plant and the Environment Draft NUREG-1437, Supplement 31 2-38 June 2007 2.2.7 Radiological Impacts 1 JAFNPP conducts an annual Radiological Environmental Monitoring Program (REMP) in which 2 radiological impacts to employees, the public, and the environment in and around the JAFNPP 3 site are monitored, documented, and compared to the appropriate standards. The objectives of 4 the REMP are to:

5 Measure and evaluate the effects of facility operation on the environs and verify the 6 effectiveness of the controls on radioactive material sources 7 Monitor natural radiation levels in the environs of the JAFNPP site 8 Demonstrate compliance with the requirements of applicable Federal regulatory 9 agencies, including technical specifications and the ODCM 10 Radiological releases are summarized in two JAFNPP reports: the Annual Radiological 11 Environmental Operating Report (Entergy 2005b) and Annual Radioactive Effluent Release 12 Report (Entergy 2006a; 2005a; 2004a; 2003; 2002a; 2002b). Limits for all radiological releases 13 are specified in the JAFNPP ODCM (Entergy 2004c) and used to meet Federal standards and 14 requirements. The REMP includes monitori ng of the waterborne environment (surface, 15 sediment from shoreline); airborne environment (radioiodine and particulates, direct radiation);

16 and ingestion pathways (milk, fish, food products). During 2005, 2318 analyses were performed 17 on collected samples of environmental media and showed no significant or measurable 18 radiological impact from the operations at JAFNPP (Entergy 2005b).

19 The New York State Department of Health also measures the levels of radiation exposure and 20 concentration of radioactive material at locations surrounding Nine Mile Point and JAFNPP.

21 The State measures direct radiation and radioactivity in air, milk, water, sediments, vegetation, 22 and fish. The State's 10-year monitoring data from 1995 through 2004 shows radiation levels 23 typical for background levels for air, water, milk, fish, sediment samples, vegetation, and direct 24 radiation (New York State Department of Health 2007).

25 Historical data on releases from JAFNPP and the resultant dose calculations demonstrate that 26 the calculated doses to maximally exposed individuals in the vicinity of JAFNPP were a small 27 fraction of the limits specified in the JAFNPP ODCM (Entergy 2004c) to meet 10 CFR Part 20; 28 10 CFR Part 50, Appendix I; and EPA radiation standards in 40 CFR Part 190. For 2005, dose 29 estimates were calculated based on actual liquid and gaseous effluent release data and 30 conservative models to simulate the transport mechanisms. The results are described in the 31 2005 Annual Radioactive Effluent Release Report (Entergy 2006a). A summary of the 32 calculated maximum dose to an individual located at the JAFNPP boundary from liquid and 33 gaseous effluents released during 2005 is as follows:

34 Plant and the Environment June 2007 2-39 Draft NUREG-1437, Supplement 31 The maximum whole-body dose to an offsite member of the general public from liquid 1 effluents was 1.68 10

-5 millirem (mrem), well below the 3-mrem-dose criteria in 10 CFR 2 Part 50, Appendix I.

3 The maximum whole-body dose to the likely most-exposed member of the general public 4 from gaseous effluents was 4.39 mrem, below the 5-mrem-dose criteria in 10 CFR 5 Part 50, Appendix I.

6 The applicant does not anticipate any significant changes to the radioactive effluent releases or 7 exposures from JAFNPP operations during the renewal period and, the impacts to the 8 environment are therefore not expected to change.

9 2.2.8 Socioeconomic Factors 10 The NRC staff reviewed the JAFNPP Environmental Report (ER) (Entergy 2006c) and 11 information obtained from County, City, school district, and local economic development staff.

12 The following sections describe the housing market, community infrastructure, population, and 13 economy in the region surrounding the JAFNPP site.

14 2.2.8.1 Housing 15 JAFNPP employs a permanent workforce of 716 employees (Entergy 2006c). Approximately 16 78 percent live in Oswego County, New York, and 18 percent in Onondaga County, New York 17 (Table 2-5). Both counties are in the Syracuse metropolitan statistical area (MSA), which also 18 includes Cayuga and Madison counties. Given the residential locations of JAFNPP employees, 19 the most significant impacts of plant operations are likely to occur in Oswego and Onondaga 20 counties. The focus of the analysis in this draft environmental impact statement (draft SEIS) is 21 therefore on the impacts of JAFNPP in these two counties.

22 23 Table 2-5. JAFNPP Permanent Employee 24 Residence by County in 2006 25 County Number of JAFNPP Personnel Percentage of Total Oswego 556 77.7% Onondaga 127 17.7% Other 33 4.6% Total 716 100.0% Source: Entergy 2006c Plant and the Environment Draft NUREG-1437, Supplement 31 2-40 June 2007 1 JAFNPP schedules refueling outages at 24-month intervals. During refueling outages, site 2 employment increases by 700 to 900 workers for approximately 30 days. These workers are 3 assumed to be from the same geographic areas as the permanent JAFNPP staff.

4 The number of housing units and housing vacancies in Oswego and Onondaga counties in 5 2000 and 2005 are shown in Table 2-6. In Oswego County, the total number of housing units 6 and occupied units grew at an average annual rate of 0.34 and 0.64 percent, respectively, from 7 2000 to 2005. With an annual average population growth rate of 1.1 percent during this period, 8 the number of units available grew mo re slowly than the demand for housing.

9 Table 2-6. Number of Occupied, Vacant, and Total Housing Units 10 in Oswego and Onondaga Counties, New York, in 2000 and 2005 11 Year County Housing Units 2000 2005 Approximate Change Oswego Occupied 45,522 46,964 +3.2%

Vacant 7,309 6,766 -7.4%

Total 52,831 53,730 +1.7% Onondaga Occupied 181,153 183,032 +1.0%

Vacant 15,480 17,704 +14.4%

Total 196,633 200,736 +2.1% Source: USCB 2006a 12 In Onondaga County, the total number of housing units grew at an annual average rate of 13 0.42 percent from 2000 to 2005, while average annual growth of occupied units was slightly less 14 at 0.20 percent (USCB 2006a).

15 2.2.8.2 Public Services 16 This section contains a discussion of public services including water supply, education, and 17 transportation.

18 Water Supply 19 Slightly more than half of Oswego County's population receives potable water from one of the 20 county's 29 public water districts, with the remaining population receiving water from private 21 groundwater wells (NRC 2006). Public water districts in the county obtain water from Lake 22 Ontario or a variety of groundwater aquifers and springs and the Onondaga County Water 23 Plant and the Environment June 2007 2-41 Draft NUREG-1437, Supplement 31 Authority (OCWA) (OCDPCD 1997). Public water suppliers draw water from three principal 1 groundwater aquifers (Sand Ridge, Fulton, and Tug Hill) with substantial groundwater resources 2 available from other local or regional aquifers that have been largely unused (OCDPCD 1997).

3 The three major public water supply systems in Oswego County are the Oswego Water System, 4 the City of Fulton, and the Metropolitan Water Board.

5 Table 2-7 lists the daily water consumption and maximum daily capacity for the three major 6 public water supply systems in Oswego County.

7 Table 2-7. Major Public Water Supply Systems in Oswego County, 8 Average Daily Use, and Maximum Daily Capacity 9 Water Supplier Average Daily Use in million gpd Maximum Daily Capacity in million gpd Oswego Water System 8.0 20.1 City of Fulton 2.4 2.4 Metropolitan Water Board 25.0 62.5 Source: NRC 2006 10 The Oswego Water System (OWS) provides water service to approximately 23,950 customers 11 in the communities of Oswego, Minetto, Scriba, and Volney, and potable water to JAFNPP 12 (OCDPCD 1997). Current JAFNPP usage is approximately 137,500 gpd with no restrictions on 13 supply (Entergy 2006g).

While the OWS could potentially withdraw up to approximately 14 62.5 million gpd from Lake Ontario, the design capacity of the water plant is only 20.1 million 15 gpd (NRC 2006). County planning officials estimate that the capacity of the OWS is adequate 16 to meet the demands of an additional 4000 to 8000 residential customers (OCDPCD 1997).

17 The City of Fulton water supplier serves approximately 12,900 customers. The City has 18 10 groundwater wells extracting up to 2.4 million gpd. As average daily demand exceeds 19 supply in the city, the City of Fulton has an agreement with the OCWA to obtain up to 3 million 20 gpd to cover the extra demand (OCDPCD 1997).

21 The Metropolitan Water Board (MWB) functions as a potable water wholesaler to public water 22 districts and water authorities in both Oswego and Onondaga counties. Most of the MWB's 23 water is sold to the OCWA, with 25 percent of its pipeline capacity available to Oswego County.

24 While the capacity of MWB is 60 million gpd, the MWB withdrew an average of only 25 million 25 gpd in 1998, of which 200,000 gpd was provided to communities in Oswego County. The MWB 26 therefore has large excess capacity to support future growth in the county (OCDPCD 1997).

27 Plant and the Environment Draft NUREG-1437, Supplement 31 2-42 June 2007 Education 1 JANFPP is located in the Mexico Central School District, which had an enrollment of 2 2682 students in 2005. Including the Mexico Central School District, Oswego County contains 3 9 school districts. In 2000, there were 35,240 students enrolled in schools in the county with an 4 average class size of 21 students. The average expenditure per student in low-need districts in 5 New York is approximately $15,000. Onondaga County has a total of 18 school districts. Total 6 enrollment in the district is approximately 132,240 students based on data from the 2000 7 Census Bureau (Entergy 2006g).

8 Transportation 9 The road structure in the immediate vicinity of JAFNPP consists primarily of smaller county 10 roads rather than state or interstate highways. JAFNPP is accessed from the east by Lake 11 Road, a two-lane paved road east of the intersection of County Route 1A and Lakeview Road 12 (see Figure 2-2). According to the Oswego County Planning and Community Development 13 Department, the average daily traffic count for County Route 1A from County Route 1 to Lakeview 14 Road was 4900 vehicles in 1995 (NRC 2006).

15 Due to the rural nature of JAFNPP's location, there is no state level of service determination for 16 the county roads that service JAFNPP and the immediate area. The Oswego County 17 Department of Public Works reviewed traffic patterns for the major roads around the JAFNPP as 18 part of a reconstruction project for County Route 1A. The County determined that traffic counts 19 were within acceptable levels (NRC 2006).

20 2.2.8.3 Offsite Land Use 21 In order to accommodate and regulate growth and development, Oswego and Onondaga 22 counties have developed county-specific comprehensive growth management plans 23 characterizing current conditions and setting standards, regulations, and goals for land use and 24 development. Land-use planning and zoning regulations have been developed by towns, 25 villages, and municipalities within Oswego and Onondaga counties. Therefore, land use 26 standards may vary greatly in different regions within the counties. Neither county has 27 implemented growth control measures that would limit residentia l housing development.

28 Agriculture remains the predominant land use in the county, but rural residential development 29 has increased. In all or parts of many towns, residential development surrounding major 30 employment centers has reached or is approaching suburban density. Most towns in Oswego 31 County have developed some type of land-use regulation, either zoning or subdivision 32 regulations. Although elements of the rural landscape remain, the community character is 33 clearly residential (OCDPCD 1997). Residential growth has been strongest in towns in southern 34 Oswego County and the town of Scriba in northern Oswego County. Commercial and industrial 35 land uses, particularly energy production, such as the Nine Mile Point Nuclear Station and Sithe 36 Industries, which operates a natural gas fueled power plant, have centered near the cities of 37 Oswego and Fulton and their surrounding areas. State-regulated wetlands account for 38 Plant and the Environment June 2007 2-43 Draft NUREG-1437, Supplement 31 13 percent of the total land area in Oswego County, and development is restricted in these 1 areas (OCDPCD 1999).

2 Onondaga County is somewhat more developed, with an increase of both residential and 3 commercial land uses in towns and villages near Syracuse. Growth has been steady 4 throughout northern and central Onondaga County. County planning officials expect residential 5 growth to continue in northern and central Onondaga County following the Onondaga County 6 Settlement Plan (Syracuse-Onondaga County Planning Agency 2001). This plan proposes to 7 control growth within the county by guiding county infrastructure investments only to developed 8 areas. 9 Seventeen state parks, 20 state wildlife management areas, and one national wildlife refuge are 10 located within a 50-mi radius of JAFNPP. The Montezuma National Wildlife Refuge is north of 11 Cayuga Lake in Seneca County, approximately 44 mi southwest of the site (NRC 2006).

12 Land use in Oswego and Onondaga counties is listed in Table 2-8.

13 2.2.8.4 Visual Aesthetics and Noise 14 The area around JAFNPP is generally flat, forested, and rural. The most prominent features on 15 the site are the reactor building and the off-gas stack, which is 385 ft high. Due to the forest 16 cover in the area, the physical plant is not visible from local communities. However, plant 17 structures can be seen by recreational boaters and fishermen on Lake Ontario.

18 Table 2-8. Land Use in Oswego and Onondaga Counties 19 Percentage of Total Land Use Oswego County (1995) Onondaga County (2006) Agriculture, forested, vacant 55% 51% Residential 36% 29% Public 6% 10% Commercial 3% 10% Total 100% 100% Sources: Oswego County: OCPCD 1997; Onondaga County: Syracuse-Onondaga County Planning Agency 2006 20 Currently, there are no reports of noise complaints from the areas surrounding JAFNPP or from 21 recreational users of Lake Ontario. Additionally, noise concerns have not been considered a 22 Plant and the Environment Draft NUREG-1437, Supplement 31 2-44 June 2007 problem at the site due to the plant's distanc e from local communities (Entergy 2006c). EPA 1 recommends that noise levels for residential areas near the boundary of an industrial facility not 2 exceed an annual equivalent sound level of 55 decibels. There is no expected increase in noise 3 levels associated with the proposed license renewal activities.

4 2.2.8.5 Demography 5 In 2000, approximately 109,440 persons lived within a 20-mi radius of JAFNPP, which equates 6 to a population density of 87 persons per mi

2. This density translates to a Category 3 (60 to 7 120 persons per mi 2 or fewer than 60 persons per mi 2 with at least one community of 25,000 or 8 more persons within 20 mi) using the generic environmental impact statement (GEIS) measure 9 of sparseness (Entergy 2006c). At the same time, there were approximately 914,668 persons 10 living within a 50-mi radius of the plant, for a density of 117 persons per mi

2. The Syracuse 11 MSA, located within 50 mi of the site, had a total population in 2000 of 732,117. Therefore, 12 JAFNPP falls into Category 3 (one or more cities with 100,000 or more persons and fewer than 13 190 persons per mi 2 within 50 mi) of the NRC sparseness and proximity matrix. A Category 3 14 value indicates that JAFNPP is in a medium density population area (NRC 2006).

15 Table 2-9 shows population growth rates and projections from 1970 to 2020 in Oswego and 16 Onondaga counties. Oswego County grew at a relatively slow annual rate of less than 17 0.1 percent for the period of 1990 to 2000. The average annual growth rate for New York for 18 this period was 0.5 percent. Only slight increases in population are expected for the period 19 2000 through 2020. The population declined in Onondaga County during the 1990s and this 20 trend is expected to continue during the period 2000 to 2020 (NRC 2006).

21 In 2000, Oswego, the largest city in Oswego County, located approximately 5 mi southwest of 22 JAFNPP had a population of 17,954 persons (USCB 2006a). The second largest city, Fulton, 23 located approximately 12 mi south of JAFNPP had a population of 11,855 persons. The town of 24 Scriba had an estimated population of 7331 persons. The U.S. Census Bureau lists 21 other 25 towns in Oswego County, all of which have populations between 500 and 9000 persons (USCB 26 2006a). Most of the remaining population lives in unincorporated rural areas (OCDPCD 1997).

27 Although some towns and municipalities surrounding Syracuse have experienced modest 28 growth, Onondaga County and Syracuse declined in population from 1990 to 2000. In 2000 the 29 Onondaga Reservation in southern Onondaga County had an estimated population of 30 1473 persons (NRC 2006).

31 Plant and the Environment June 2007 2-45 Draft NUREG-1437, Supplement 31 Table 2-9. Population Growth in Oswego and Onondaga Counties, 1 New York, from 1970 to 2000 and Projected for 2010 and 2020 2 Oswego County Onondaga County Year Population Annual Growth Percent (a) Population Annual Growth Percent (a) 1970 100,897

- 472,835 - 1980 113,931 +1.2 463,920 -0.2 1990 121,771 +0.7 468,973 +0.01 2000 122,377

+0.05 458,336 -0.02 2010 123,400

+0.08 442,531 -0.4 2020 123,591

+0.02 423,235 -0.4 - = No data available.

(a) Annual percent growth rate is calculated over the previous decade. Sources: Population data for 1970 through 2000 (USCB 2006); projected population data for 2010 and 2020 (NRC 2006a) 3 Transient Population 4 Within 50 mi of JAFNPP, colleges and recreational opportunities attract daily and seasonal 5 visitors who create demand for temporary housing and services. In Oswego County, 6 6.6 percent of all housing units are considered temporary housing for seasonal, recreational, or 7 occasional use. By comparison, temporary housing accounts for only 1.0 percent and 8 3.1 percent of total housing units in Onondaga County and the State of New York, respectively 9 (NRC 2006).

10 Migrant Farm Workers 11 Migrant farm workers are individuals whose employment requires travel to harvest agricultural 12 crops. These workers may or may not have a permanent residence. Some migrant workers 13 may follow the harvesting of crops, particularly fruit, throughout the northeastern U.S. rural 14 areas. Others may be permanent residents near JAFNPP who travel from farm to farm 15 harvesting crops.

16 Migrant workers may be members of minority or low-income populations. Because they travel 17 and can spend a significant amount of time in an area without being actual residents, migrant 18 workers may be unavailable for counting by census takers. If uncounted, these workers would 19 be "underrepresented" in USCB minority and low-income population counts.

20 Plant and the Environment Draft NUREG-1437, Supplement 31 2-46 June 2007 Onondaga and Oswego counties host relatively small numbers of migrant workers. According 1 to 2002 Census of Agriculture estimates, 1745 temporary farm laborers (those working fewer 2 than 150 days per year) were employed on 170 farms in Onondaga County, and 718 were 3 employed on 93 farms in Oswego County (Entergy 2006g).

4 2.2.8.6 Economy 5 This section contains a discussion of the economy, including employment and income, 6 unemployment, and taxes.

7 Employment and Income 8 Between 1990 and 2004, total employment in Oswego County increased 2.5 percent (24,396 to 9 25,011 persons) and decreased in Onondaga County by 3.6 percent (232,120 to 223,649 10 persons) (USCB 2006b). Government and health care sectors employed the largest number of 11 people in both counties followed closely by retail, manufacturing, and the service industry. The 12 largest employer in Oswego County in 2006 was the State University of New York at Oswego 13 (SUNY Oswego) with 3934 employees (Table 2-10). The majority of jobs in Oswego County are 14 located in the cities of Oswego and Fulton (Oswego County 2006).

15 Personal income in Oswego County totaled $2.9 million in 2004, with a per capita personal 16 income of $23,481. In Onondaga County, personal income totaled $14.7 million, with a per 17 capita income of $32,122. Both are lower than the state's per capita personal income in 2004, 18 which was $38,364 (FedStats 2006).

19 Unemployment 20 The unemployment rate in Oswego and Onondaga counties in October 2006 was 4.3 and 21 3.7 percent, respectively. Although there have been fluctuations, the overall rates in both 22 counties have remained about the same over the past decade. The current rate for the state 23 (November 2006) is 4.0 percent (NYSDOL 2006).

24 Taxes 25 JAFNPP is assessed annual property taxes by Oswego County, the Town of Scriba, and Mexico 26 Central Schools. Property taxes paid to Oswego County and the Town of Scriba fund services 27 such as transportation, education, public health, and public safety. See Table 2-11.

28 The continued availability of JAFNPP and the associated tax base is an important feature in the 29 ability of the Town of Scriba and Oswego County communities to continue to invest in 30 infrastructure and to draw industry and new residents.

31 32 Plant and the Environment June 2007 2-47 Draft NUREG-1437, Supplement 31 Table 2-10. Major Employers in Oswego County in 2006 1 Firm Number of Employees SUNY Oswego 3934 County of Oswego 1048 Constellation Energy Group 900 Central Square School District 841 Oswego Health 730 Oswego City School District 723 Novelis Corporation 714 Fulton School District 647 Huhtamaki Packaging 630

Wal-Mart 620 Oswego Opportunities (non-profit) 604 Oswego County Bringing Our Community Education Solutions (BOCES) 569 Entergy Nuclear Northeast 560 Source: Oswego County 2006 2 In 2005, Entergy paid approximately $7.2 million in taxes for JAFNPP. It is estimated that a 3 minimum of $38.1 million in taxes will be paid by Entergy for JAFNPP through the original 4 license period (Entergy 2006c). These property taxes, and other local taxes, along with 5 JAFNPP operating payroll and locally purchased goods and services, aid the local economy.

6 The energy market in the state of New York has been deregulated to encourage the 7 development of competition in the production and sale of electricity. A study performed by the 8 New York State Board of Real Property Services concluded that the value of many power-9 generating plants is likely to decline in a deregulated market. Therefore, Entergy expects that 10 future property taxes assessed through the license renewal term should be similar to or may be 11 less than the estimated in lieu payments (NRC 2006).

12 Plant and the Environment Draft NUREG-1437, Supplement 31 2-48 June 2007 Table 2-11. Oswego County, Town of Scriba, and Mexico Central Schools Tax Revenues, 1 2002 to 2005; JAFNPP Property Tax, 2002 to 2005; and JAFNPP Property Tax 2 as a Percentage of Tax Revenues 3 Entity Year Tax Revenues (in millions of dollars) Property Tax Paid by JAFNPP (in millions of dollars) JAFNPP Property Tax as Percentage of Tax Revenues Oswego County 2002 $152.9 $2.9 1.9%

2003 $156.1 $2.9 1.9%

2004 $172.5 $2.9 1.7%

2005 $162.4 $2.9 1.8%

2006 $161.0 $2.9 1.8% Town of Scriba 2002 $4.0 $0.4 10.9%

2003 $4.9 $0.4 9.0%

2004 $4.3 $0.4 10.3%

2005 $5.1 $0.4 8.6%

2006 $4.6 $0.4 9.4%

2002 $32.4 $3.9 12.1%

Mexico Central Schools 2003 $32.7 $3.9 12.0%

2004 $34.1 $3.9 11.5%

2005 $34.0 $3.9 11.4%

2006 $34.0 $3.9 11.6% Source: Entergy 2006c (years 2002-2005) Entergy 2006g (year 2006) 4 2.2.9 Historic and Archaeological Resources 5 This section discusses the cultural background and the known historic and archaeological 6 resources at the JAFNPP site and in the surrounding area.

7 Plant and the Environment June 2007 2-49 Draft NUREG-1437, Supplement 31 2.2.9.1 Cultural Background 1 The region around JAFNPP contains prehistoric and historic Native American and Euro-2 American cultural resources. There are 43 properties listed in the National Register of Historic 3 Places within approximately 10 mi of JAFNPP (Entergy 2006c). The nearest National Register 4 site is the Riverside Cemetery in Scriba; none are located in areas affected by operation of 5 JAFNPP. 6 Paleo Indians occupied North America from 12,000 to 10,000 years ago, subsisting on hunting 7 game and gathering plant material. In the New York area, Paleo Indians migrated into an 8 environment changed by retreating glacial ice. Evidence from archaeological work in the state 9 suggests that small game and plants played a significant role in the lives of the people. Stone 10 tools show little variability over wide areas of North and South America, but raw material for 11 these tools often have sources far from where archaeologists find the tools. Known Paleo-12 Indian sites near JAFNPP include the Potts Site southeast of Scriba (Ritchie 1994).

13 During the Archaic Period, from approximately 10,000 years ago to about 3500 years ago, 14 people underwent local changes to adapt to resources. In the New York area, as forests 15 evolved from spruce and pine to mixed deciduous communities, populations near present day 16 JAFNPP probably were low in density to begin with but steadily increased in density as both 17 resource quality and the cultural means to access resources improved. Archaeologists find 18 evidence of more occupation by the end of the Archaic Period when climate reached its modern 19 condition. They interpret the settlement patterns they find as suggestive of an increase in 20 breadth of resources sought by prehistoric people as they lived in smaller territories. Archaic 21 people collected, hunted, and gathered most of what they needed for survival in their home 22 territory. Large base camps found near major water sources provided a focal point for groups 23 during the hard months. During other seasons, camps divided and people engaged in more 24 mobile foraging activities. Primary areas of occupation were along the Oswego River about 25 7 mi to the west of JAFNPP. Small hunting parties may have crossed the JAFNPP site and 26 hunting encampments could be present. One late Archaic archaeological deposit near the 27 JAFNPP area is the Oberlander 1 site in Oswego County on the Oneida River (Ritchie 1994).

28 The Transitional Period, from approximately 3500 years ago to about 1000 years ago, is viewed 29 by New York archaeologists as representing a continuum of change in adaptation by prehistoric 30 peoples. The central defining characteristic of the period is the introduction of stone (steatite) 31 vessels at the beginning and the first production of pottery at the end (Ritchie and Funk 1973).

32 Over the same period, burial treatment became more elaborate, and people once again got 33 some materials for making stone tools from distant sources (Ritchie and Funk 1973).

34 The "Woodland" culture occupied the region between 3000 years ago until the time of European 35 contact. In the Woodland culture, Native Americans became regionally distinct cultural entities.

36 Woodland people ultimately became dependent on maize agriculture, lived in villages, used the 37 bow and arrow in hunting, and began to regularly make and use pottery. Known examples of 38 prehistoric sites are rare on the shore of Lake Ontario. Known archaeological resources found 39 Plant and the Environment Draft NUREG-1437, Supplement 31 2-50 June 2007 in Oswego County are concentrated along the Oswego River, Oneida Lake, along the Salmon 1 River, and at the mouth of the Salmon River.

2 JAFNPP is situated within a region bordered by Lake Ontario to the north. No major drainage 3 occurs within 5 mi. Any large prehistoric sites would most likely be found along major 4 waterways away from JAFNPP. Since JAFNPP is not within the daily foraging radius of any 5 major river valley, prehistoric people visiting the area could have made overnight camps along 6 minor streams as they hunted and collected local resources. The terrain to the south and east 7 of JAFNPP consists of glacial kettle ponds and wetlands surrounded by small knolls and hills.

8 Paleo-Indian and Archaic Period peoples could have foraged for resources in and around these 9 kettle ponds. Later prehistoric groups could have used this area for hunting and foraging on a 10 reduced scale. JAFNPP is also situated on a rocky coastal bluff. This, along with the lack of a 11 beach, would not have been attractive for fishing. Any archaeological sites found in the vicinity 12 of the JAFNPP would consist of small scatters of stone tools and debris from making stone 13 tools, associated with cooking hearths.

14 The Native American societies in the region shared several important characteristics at the time 15 they were first contacted by Europeans. These included an economic base that combined 16 hunting and gathering with growing domesticated plants; and an annual settlement that varied in 17 population size between semi-permanent river-side villages in summer, large camps in winter, 18 and population dispersal among scattered camps in the spring and fall.

19 The JAFNPP site is located on Onondaga Indian Nation's eighteenth century lands, although 20 the territorial boundaries between Native American groups were in flux throughout the historic 21 period and until the mid-nineteenth century. Treaties between New York Indians and the United 22 States government in 1794 and 1838 eroded tribal territorial holdings in the state of New York.

23 European settlement and exploration of the region occurred slowly with most of the settlement 24 activity concentrated away from JAFNPP near the mouth of the Oswego River near Forts 25 Ontario and Oswego.

26 In 1788, the state purchased large tracts of land from the Onondaga, Oneida, and Cayuga 27 nations; the lands, which were divided into parcels, included Scriba's Patent, and that included 28 the JAFNPP. George Scriba, a resident of Holland, New York, took possession of nearly 29 0.5 million ac of land in the patent. The patent was divided into 16 townships in Oswego 30 County, and George Scriba began to sell portions to speculators and settlers (Kozub and Carter 31 2003). 32 The town of Scriba was created in 1811, although settlers in the area arrived as early as 1798.

33 The scene for the first non-Indian settlement was at "Scriba Corners." The township of Scriba 34 flourished throughout the nineteenth century with small farms, apple orchards, and a booming 35 cider industry. Seven homesteads, a railroad line, and a stave factory (for cider barrels) existed 36 on the JAFNPP tract in 1867 (Stone 1867).

37 Plant and the Environment June 2007 2-51 Draft NUREG-1437, Supplement 31 The early economy was based on timber harvesting and lumber production. As forests were 1 cut, residents moved to farming, especially dairy and fruit production (Churchill 1895). The 2 Oswego Canal opened in 1828 and the Syracuse & Oswego Railroad opened in 1848. The 3 canal and railroad precipitated surges in the lumber industry and in agriculture (Churchill 1895).

4 By 1855 more than half of the county's workers were farmers (Wellman 1987). However, by the 5 late 1800s, the shipping industry in Oswego collapsed, as did agriculture, and farmers began to 6 leave. It took Oswego County 90 years to return to the population level of 1870. By 1900, at 7 least 12 residences had located in the JAFNPP area (USGS 1900). The number of farms and 8 homes remained relatively stable until 1955, when there were 14 residences (USGS 1955).

9 Camp Oswego, also known as the Camp Drum Anti-Aircraft Artillery Firing Range, was located 10 immediately to the west of JAFNPP on property now occupied by Nine Mile Point Nuclear 11 Station (USGS 1955). The camp was established during World War II and continued to operate 12 well into the 1950s as a summer training base. Sometime after 1956, the camp was closed and 13 the land was later purchased by Niagara-Mohawk Electric Company for construction of the Nine 14 Mile Point Nuclear Station.

15 2.2.9.2 Historic and Archaeological Resources at JAFNPP 16 During preparation and review of the Final Environmental Statement Related to Operation of 17 James A. Fitzpatrick Nuclear Power Plant (AEC 1973), it was determined that no known historic 18 places and archaeological sites existed within the plant site or in the ROW for the transmission 19 line. The New York State Historic Preservation Office (SHPO) was contacted during the early 20 stages of site construction for information about archaeological resources in the vicinity of 21 JAFNPP and received certification that the plant would not have a harmful effect on any sites of 22 historic and archaeological importance (AEC 1973). Subsequently, Entergy contacted the New 23 York State Office of Parks, Recreation, and Historic Preservation (NYSHPO) regarding license 24 renewal for JAFNPP in February 2006 (Entergy 2006c). In April 2006, NYSHPO responded to 25 Entergy stating that they consider the project area to be "sensitive for archaeological resources" 26 (NYSHPO 2006b).

27 The JAFNPP site is generally flat, with the area surrounding the plant largely forested and rural 28 (Entergy 2006c). Aerial photographs show that a considerable portion (approximately one-third) 29 of the site has been disturbed due to the construction of JAFNPP. After a review of NYSHPO 30 site files, NRC staff confirmed that no known archaeological and historic architectural sites have 31 been recorded at JAFNPP. In addition, according to NYSHPO records, there have been several 32 archaeological studies and surveys conducted in the vicinity of JAFNPP and one actual study of 33 the site. The results of these studies are summarized chronologically below.

34 The first known archaeological survey in the vicinity of JAFNPP was conducted in 1977 by Pratt 35 and Pratt Archaeological Associates, Inc., for Niagara Mohawk Power Corporation. This report 36 consisted of a literature search and survey for siting a power line and substation (Nine Mile 37 Point Nuclear Station Unit 2-Volney 765-kV line) that crossed JAFNPP property. The literature 38 Plant and the Environment Draft NUREG-1437, Supplement 31 2-52 June 2007 review found no recorded prehistoric archaeological sites or National Register properties within 1 the proposed substation site and corridor area. However, the report indicated there was a high 2 potential for finding historic sites within the project corridor but only a moderate potential that 3 these sites would be impacted by the proposed project. In 1983, Pratt and Pratt Archaeological 4 Associates, Inc., published an addendum to the 1977 report, which did not change the 5 conclusions of the earlier report.

6 In 1987, a comprehensive literature review and cultural resource inventory was conducted at the 7 JAFNPP site by Hartgen Archeological Associates, Inc. Again, the literature review found no 8 recorded prehistoric or historic archaeological sites on file at the New York State Museum or 9 SHPO. However, Hartgen noted that due to environmental conditions, the JAFNPP site and 10 surrounding area could have been used for fo raging and hunting by limited numbers of 11 prehistoric peoples for short durations, and concluded that there was a low to moderate 12 probability of prehistoric sites being found on the plant site. The survey also reported that 13 historic development within the JAFNPP site consisted primarily of scattered homes along North 14 Lake Road and Oswego County Route 29. As late as 1955, the number of structures identified 15 on maps within the JAFNPP property was only 16. Given that these historic structures once 16 stood on the JAFNPP site, the potential for finding historic resources on the site is high.

17 Most of the other archaeological studies and surveys conducted between 1987 and 2004 18 consisted of literature searches for water and electric transmission line and roadway projects.

19 These studies and surveys found no significant prehistoric or historic sites within their project 20 areas. 21 In October 2006, Entergy contracted Enercon Services, Inc., to perform a phase 1A literature 22 review and archaeological sensitivity assessment for the JAFNPP site. The assessment 23 included a walk-over of selected undeveloped portions of the JAFNPP site that were identified 24 as being potentially sensitive for cultural resources. As stated in previous archaeological 25 reviews, Enercon also concluded that there is a potential for finding prehistoric sites on the 26 small knolls and hills next to kettle ponds across the eastern and southern portions of the 27 JAFNPP property. The assessment also concluded that since the site was mostly orchard 28 farmland prior to the construction of JAFNPP, it is very likely that historic resources associated 29 with those farms exist on the site.

30 A walk-over of selected undeveloped portions of the JAFNPP site by NRC staff confirmed the 31 existence of historic resources on the plant site. Early maps of the JAFNPP area indicate that a 32 number of structures, mostly of nineteenth-century origin, existed on the JAFNPP site prior to 33 construction.

Most of these sites today consist of foundations and probable associated historic 34 artifact scatters. Prehistoric cultural resources could also be present in the relatively 35 undisturbed southern and eastern portions of the JAFNPP site in areas next to kettle ponds.

36 Plant and the Environment June 2007 2-53 Draft NUREG-1437, Supplement 31 2.2.10 Related Federal Project Activities and Consultations 1 The NRC staff reviewed the possibility that activities of other Federal agencies might impact the 2 renewal of the operating license for JAFNPP. Any such activity could result in cumulative 3 environmental impacts and the possible need for a Federal agency to become a cooperating 4 agency in the preparation of the JAFNPP SEIS.

5 The 7068-ac Montezuma National Wildlife Refuge, located approximately 44 mi southwest of 6 JAFNPP serves as a major resting area for waterfowl and other waterbirds on their journeys to 7 and from nesting areas in northeastern and east-central Canada. This refuge is also in the 8 middle of one of the most active flight lanes in the Atlantic Flyway (FWS 2006a).

9 The Onondaga Reservation, a 5953-ac Indian reservation, is located in Onondaga County. As 10 of the 2000 census, the Indian reservation had a population of 1473 (Answers.com 2006).

11 JAFNPP shares an eastern boundary with the Nine Mile Point Nuclear Station, a two-unit 12 electricity-generating nuclear power plant operated by Nine Mile Point Nuclear Station, LLC.

13 There are also approximately 25 hydropower electricity-generating facilities within 50 mi of the 14 JAFNPP site.

15 NRC is required under Section 102 of the National Environmental Policy Act of 1969 (NEPA) to 16 consult with and obtain the comments of any Federal agency that has jurisdiction by law or 17 special expertise with respect to any environmental impact involved. Federal agency comment 18 correspondence is included in Appendix E.

19 2.2.10.1 Coastal Zone Management Act 20 The Coastal Zone Management Act of 1972 (CZMA) grants the National Oceanic and 21 Atmospheric Administration (NOAA) the authority to encourage and assist states and territories 22 with developing management programs that pres erve, protect, develop, and, when possible, 23 restore coastal zone resources. A "coastal zone" is generally described as the coastal waters 24 and the adjacent shore lands strongly influenced by each other and includes islands, transitional 25 and intertidal areas, salt marshes, wetlands, beaches, and Great Lakes waters (NOAA 2007).

26 Federal activities that are reasonably likely to affect coastal use or resources, such as license 27 renewal of nuclear power plants, must be consistent with the approved State coastal 28 management program (CMP). The federal consistency provision is promulgated in Section 29 307(c)(3)(a) of the CZMA and requires applicants for Federal licenses or permits to certify that 30 any proposed activity in the coastal zone is consistent with the enforceable policies of the State 31 CMP (NOAA 2007). A copy of the applicant's consistency certification, as submitted to the 32 Federal agency, is provided to the State agency responsible for conducting consistency 33 reviews. Upon receipt of all necessary information, the State has six months to notify the 34 applicant and Federal agency of whether it concurs with or objects to the applicant's 35 Plant and the Environment Draft NUREG-1437, Supplement 31 2-54 June 2007 certification. The Federal license or permit being sought by the applicant cannot be granted 1 without State approval of the consistency certification (DOC 2003).

2 In 1982, NOAA certified New York State's CMP, as codified in 19 NYCRR Parts 600-601.

3 Implementation of the CMP and a consistency review are performed by the New York State 4 Department of State Division of Coastal Resources (NYSDOS 2007). JAFNPP is located on a 5 Great Lakes coastline that falls under the jurisdiction of the CZMA, and license renewal is a 6 Federal activity that requires a consistency determination. As such, Entergy submitted a copy 7 of its New York State CMP certification, as contained within Attachment D of the ER (Entergy 8 2006c), to the State on July 31, 2006. New York State requires review of the draft SEIS prior to 9 making a consistency determination. To ensure the six-month review time frame is maintained, 10 upon request of the State, Entergy withdrew its consistency certification and will resubmit the 11 certification closer to the date of the draft SEIS issuance (Entergy 2006e).

12 2.2.10.2 Clean Water Act Section 401 Water Quality Certification 13 Under Section 401 of the Clean Water Act of 1977 (CWA), an applicant for a Federal license or 14 permit to conduct any activity that may result in discharge into navigable waters must obtain 15 certification from the appropriate state pollution control agency verifying compliance with the 16 CWA. A license or permit cannot be granted by the Federal agency until this certification has 17 been obtained or waived by the State. Furthermore, a license or permit cannot be granted if 18 certification has been denied by the State, interstate agency, or the EPA Administrator. The 19 401 Water Quality Certification sets forth applicable effluent limitations and prescribes 20 monitoring requirements to ensure that the applicant remains in compliance with those 21 limitations. Any Federal license or permit for a 401 Water Quality Certification that has been 22 obtained may be suspended or revoked by the issuing Federal agency upon judgment that the 23 facility or licensed activity has violated its certification or any applicable provisions of the CWA.

24 In New York, the NYSDEC Department of Water reviews and issues Section 401 Water Quality 25 Certifications. JAFNPP's original 401 Certification and Initial Reporting Requirements is dated 26 June 1, 1973, and accompanied the original licensing action by the NRC. In accordance with 27 Section 401 regulations, Entergy submited a Section 401 Water Quality Certification application 28 to NYSDEC in April 2007 (Entergy 2007b) to accompany the request for license renewal. Upon 29 receipt of the application, NYSDEC will have 12 months to review the application and grant or 30 deny a certification. NYSDEC anticipates issuing a decision for JAFNPP in March 2008, 31 approximately three months prior to the NRC's expected license renewal decision in May 2008 32 (assuming the standard 22-month NRC license renewal review timeline). Until NYSDEC has 33 issued a Section 401 Water Quality Certification for JAFNPP, the NRC will not be able to grant 34 the license renewal.

35 Plant and the Environment June 2007 2-55 Draft NUREG-1437, Supplement 31 2.3 References 1 6 NYCRR Part 374. Title 6 of the Codes, Rules, and Regulations of the State of New York , Part 2 374.3. "Management of Specific Hazardous Wastes - Standards for Universal Waste."

3 10 CFR Part 20.

Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for 4 Protection Against Radiation."

5 10 CFR Part 50.

Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of 6 Production and Utilization Facilities."

7 19 NYCRR Parts 600-601. Title 19 of the Codes, Rules, and Regulations of the State of New 8 York Chapter XIII: Waterfront Revitalization of Coastal Areas and Inland Waterways, Parts 600 -

9 603: Local Government Waterfront Revitalization Programs.

10 40 CFR Part 81.

Code of Federal Regulations, Title 40, Protection of Environment, Part 81, 11 "Designation of Areas for Air Quality Planning Purposes."

12 40 CFR Part 190.

Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 13 "Environmental Radiation Protection Standards for Nuclear Power Operations."

14 40 CFR Part 260.

Code of Federal Regulations, Title 40, Protection of Environment, Part 260 15 "Hazardous Waste Management System: General."

16 40 CFR Part 261.

Code of Federal Regulations, Title 40, Protection of Environment, Part 261, 17 "Identification and Listing of Hazardous Waste."

18 40 CFR Part 273.

Code of Federal Regulations, Title 40, Protection of Environment, Part 273, 19 "Standards for Universal Waste Management."

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11

June 2007 3-1 Draft NUREG-1437, Supplement 31 3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT 1 Environmental issues associated with refurbishment activities are discussed in the Generic 2 Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, 3 Volumes 1 and 2 (NRC 1996; 1999).

(1) The GEIS includes a determination of whether the 4 analysis of the environmental issues could be applied to all plants and whether additional 5 mitigation measures would be warranted. Issues are then assigned a Category 1 or a 6 Category 2 designation. As set forth in the GEIS, Category 1 issues are those that meet all of 7 the following criteria:

8 (1) The environmental impacts associated wi th the issue have been determined to apply 9 either to all plants or, for some issues, to plants having a specific type of cooling system 10 or other specified plant or site characteristics.

11 (2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 12 the impacts (except for collective offsite radiological impacts from the fuel cycle and from 13 high-level waste and spent fuel disposal).

14 (3) Mitigation of adverse impacts associated with the issue has been considered in the 15 analysis, and it has been determined that additional plant-specific mitigation measures 16 are likely not to be sufficiently beneficial to warrant implementation.

17 For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 18 required in this draft supplemental environmental impact statement (SEIS) unless new and 19 significant information is identified.

20 Category 2 issues are those that do not meet one or more of the criteria for Category 1 and, 21 therefore, additional plant-specific review of these issues is required.

22 License renewal actions may require refurbishment activities for the extended plant life. These 23 actions may have an impact on the environment that requires evaluation, depending on the type 24 of action and the plant-specific design. Environmental issues associated with refurbishment 25 determined to be Category 1 issues are listed in Table 3-1.

26 Environmental issues related to refurbishment considered in the GEIS for which these conclu-27 sions could not be reached for all plants, or for specific classes of plants, are Category 2 issues.

28 These are listed in Table 3-2.

29 (1) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" include the GEIS and its Addendum 1.

Environmental Impacts of Refurbishment Draft NUREG-1437, Supplement 31 3-2 June 2007 Table 3-1. Category 1 Issues for Refurbishment Evaluation 1 ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections SURFACE-WATER QUALITY , HYDROLOGY , AND U SE (FOR ALL PLANTS) Impacts of refurbishment on surface-water quality 3.4.1 Impacts of refurbishment on surface-water use 3.4.1 AQUATIC ECOLOGY (FOR ALL PLANTS) Refurbishment 3.5 G ROUND-WATER USE AND QUALITY Impacts of refurbishment on ground-water use and quality 3.4.2 LAND U SE Onsite land use 3.2 HUMAN HEALTH Radiation exposures to the public during refurbishment 3.8.1 Occupational radiation exposures during refurbishment 3.8.2 SOCIOECONOMICS Public services: public safety, social services, and tourism and recreation 3.7.4; 3.7.4.3; 3.7.4.4; 3.7.4.6 Aesthetic impacts (refurbishment) 3.7.8 2 Category 1 and Category 2 issues related to refurbishment that are not applicable to James A.

3 FitzPatrick Nuclear Power Plant (JAFNPP) because they are related to plant design features or 4 site characteristics not found at the James A FitzPatrick site are listed in Appendix F.

5 The potential environmental effects of refurbishment actions would be identified, and the 6 analysis would be summarized within this section, if such actions were planned. Entergy 7 Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy) indicated that it has 8 performed an evaluation of structures and components pursuant to Section 54.21 of Title 10 of 9 the Code of Federal Regulations (10 CFR 54.21) to identify activities that are necessary to 10 continue operation of JAFNPP during the requested 20-year period of extended operation.

11 These activities include replacement of certain components as well as new inspection activities 12 and are described in the Environmental Report (ER; Entergy 2006).

13 However, Entergy stated that the replacement of these components and the additional 14 inspection activities are within the bounds of normal plant component replacement and 15 inspections; therefore, they are not expected to affect the environment outside the bounds of 16 Environmental Impacts of Refurbishment June 2007 3-3 Draft NUREG-1437, Supplement 31 Table 3-2. Category 2 Issues for Refurbishment Evaluation 1 ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections 10 CFR 51.53(c)(3)(ii)

Subparagraph TERRESTRIAL R ESOURCES Refurbishment impacts 3.6 E THREATENED OR ENDANGERED S PECIES (FOR ALL PLANTS) Threatened or endangered species 3.9 E A IR QUALITY Air quality during refurbishment (nonattainment and maintenance areas) 3.3 F SOCIOECONOMICS Housing impacts 3.7.2 I Public services: public utilities 3.7.4.5 I Public services: education (refurbishment) 3.7.4.1 I Offsite land use (refurbishment) 3.7.5 I Public services, transportation 3.7.4.2 J Historic and archaeological resources 3.7.7 K ENVIRONMENTAL J USTICE Environmental justice Not addressed (a) Not addressed (a)(a) Guidance related to environmental justice was not in place at the time the GEIS and the associated revision to 10 CFR Part 51 were prepared. If an applicant plans to undertake refurbishment activities for license renewal, environmental justice must be addressed in the applicant's environmental report and the NRC staff's environmental impact statement.

2 plant operations as evaluated in the Final Environmental Statement Related to Operation of 3 James A. FitzPatrick Nuclear Power Plant (AEC 1973). In addition, Entergy's evaluation of 4 structures and components as required by 10 CFR 54.21 did not identify any major plant 5 refurbishment activities or modifications necessary to support the continued operation of 6 JAFNPP beyond the end of the existing operating license. Therefore, refurbishment is not 7 considered in this draft SEIS.

8 Environmental Impacts of Refurbishment Draft NUREG-1437, Supplement 31 3-4 June 2007 3.1 References 1 10 CFR Part 51.

Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 2 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

3 10 CFR Part 54.

Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for 4 Renewal of Operating Licenses for Nuclear Power Plants."

5 Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2006.

6 James A. FitzPatrick Nuclear Power Plant - License Renewal Application, Appendix E: -

7 Applicant's Environmental Report, Operating License Renewal Stage.

Lycoming, New York.

8 Accessible at ML062160557.

9 U.S. Atomic Energy Commission (AEC). 1973. Final Environmental Statement Related to 10 Operation of James A. FitzPatrick Nuclear Power Plant.

Power Authority of the State of New 11 York. Docket No. 50-333. Washington, D.C. Accessible at ML062360088.

12 U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement 13 for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2. Office of Nuclear 14 Regulatory Research, Washington, D.C.

15 U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement 16 for License Renewal of Nuclear Plant. NUREG-1437, Volume 1, Addendum 1. Office of 17 Nuclear Regulatory Research, Washington, D.C.

18 June 2007 4-1 Draft NUREG-1437, Supplement 31 4.0 ENVIRONMENTAL IMPACTS OF OPERATION 1 Environmental issues associated with operation of a nuclear power plant during the renewal 2 term are discussed in the Generic Environmental Impact Statement for License Renewal of 3 Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2 (NRC 1996a; 1999).

(1) The GEIS 4 includes a determination of whether the analysis of the environmental issues could be applied to 5 all plants and whether additional mitigation measures would be warranted. Issues are then 6 assigned a Category 1 or a Category 2 designation. As set forth in the GEIS, Category 1 issues 7 are those that meet all of the following criteria:

8 (1) The environmental impacts associated wi th the issue have been determined to apply 9 either to all plants or, for some issues, to plants having a specific type of cooling system 10 or other specified plant or site characteristics.

11 (2) A single significance level (i.e., SMALL, MODERATE, OR LARGE) has been assigned to 12 the impacts (except for collective offsite radiological impacts from the fuel cycle and from 13 high-level waste and spent fuel disposal).

14 (3) Mitigation of adverse impacts associated with the issue has been considered in the 15 analysis, and it has been determined that additional plant-specific mitigation measures 16 are likely not to be sufficiently beneficial to warrant implementation.

17 For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 18 required unless new and significant information is identified.

19 Category 2 issues are those that do not meet one or more of the criteria for Category 1, and 20 therefore, additional plant-specific review of these issues is required.

21 This chapter addresses the issues related to operation during the renewal term that are listed in 22 Table B-1 of Part 51 of Title 10 of the Code of Federal Regulations (10 CFR Part 51), Subpart A, 23 Appendix B and are applicable to the James A. FitzPatrick Nuclear Power Plant (JAFNPP).

24 Section 4.1 addresses issues applicable to the JAFNPP cooling system. Section 4.2 addresses 25 issues related to transmission lines and onsite land use. Section 4.3 addresses the radiological 26 impacts of normal operation, and Section 4.4 addresses issues related to the socioeconomic 27 impacts of normal operation during the renewal term. Section 4.5 addresses issues related to 28 groundwater use and quality, while Section 4.6 discusses the impacts of renewal-term operations 29 on threatened and endangered species. Section 4.7 addresses potential new information that 30 was raised during the scoping period, and Section 4.8 discusses cumulative impacts. The results 31 1 The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" include the GEIS and its Addendum 1.

Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-2 June 2007 of the evaluation of environmental issues related to operation during the renewal term are 1 summarized in Section 4.9. Finally, Section 4.10 lists the references for Chapter 4. Category 1 2 and Category 2 issues that are not applicable to JAFNPP because they are related to plant-design 3 features or site characteristics not found at JAFNPP are listed in Appendix F.

4 4.1 Cooling System 5 Category 1 issues in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, that are applicable to 6 the JAFNPP cooling system operation during the renewal term are listed in Table 4-1. Entergy 7 Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy) stated in its 8 Environmental Report, James A. FitzPatrick Nuclear Power Plant - License Renewal 9 Application, Appendix E: Applicant's Environmental Report, Operating License Renewal Stage 10 (JAFNPP ER) (Entergy 2006a), that it is not aware of any new and significant information 11 associated with the renewal of the JAFNPP operating license (OL). The NRC staff has not 12 identified any new and significant information during its independent review of the JAFNPP ER 13 (Entergy 2006a), the staff's site audit, the scoping process, or its evaluation of other available 14 information. Therefore, the NRC staff concludes that there are no impacts related to these 15 issues beyond those discussed in the GEIS. For all of the issues, the NRC staff concluded in 16 the GEIS that the impacts are SMALL, and additional plant-specific mitigation measures are not 17 likely to be sufficiently beneficial to be warranted.

18 A brief description of the NRC staff's review and the GEIS conclusions, as codified in Table B-1, 19 for each of these issues follows:

20 Altered current patterns at intake and discharge structures. Based on information in the 21 GEIS, the Commission found that 22 Altered current patterns have not been found to be a problem at operating 23 nuclear power plants and are not expected to be a problem during the license 24 renewal term.

25 The NRC staff has not identified any new and significant information during its independent 26 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 27 evaluation of other available information.

Therefore, the NRC staff concludes that there 28 would be no impacts of altered current patterns at intake and discharge structures during the 29 renewal term beyond those discussed in the GEIS.

30 Environmental Impacts of Operation June 2007 4-3 Draft NUREG-1437, Supplement 31 Table 4-1. Category 1 Issues Applicable to the Operation of the JAFNPP 1 Cooling System During the Renewal Term 2 ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section SURFACE WATER QUALITY , HYDROLOGY , AND U SE (FOR ALL PLANTS) Altered current patterns at intake and discharge struct ures 4.2.1.2.1 Altered thermal stratification of lakes 4.2.1.2.3 Temperature effects on sediment transport capacity 4.2.1.2.3 Scouring caused by discharged cooling water 4.2.1.2.3 Eutrophication 4.2.1.2.3 Discharge of chlorine or other biocides 4.2.1.2.4 Discharge of sanitary wastes and minor chemical spills 4.2.1.2.4 Discharge of other metals in wastewater 4.2.1.2.4 Water use conflicts (plants with once-through cooling systems) 4.2.1.3 AQUATIC ECOLOGY (FOR ALL PLANTS) Accumulation of contaminants in sediments or biota 4.2.1.2.4 Entrainment of phytoplankton and zooplankton 4.2.2.1.1 Cold shock 4.2.2.1.5 Thermal plume barrier to migrating fish 4.2.2.1.6 Distribution of aquatic organisms 4.2.2.1.6 Premature emergence of aquatic insects 4.2.2.1.7 Gas supersaturation (gas bubble disease) 4.2.2.1.8 Low dissolved oxygen in the discharge 4.2.2.1.9 Losses from predation, parasitism, and disease among organisms exposed to sublethal stresses 4.2.2.1.10 Stimulation of nuisance organisms 4.2.2.1.11 HUMAN HEALTH Microbiological organisms (occupational health) 4.3.6 Noise 4.3.7 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-4 June 2007 Altered current patterns at intake and discharge structures.

Based on information in the 1 GEIS, the Commission found that 2 Altered current patterns have not been found to be a problem at operating 3 nuclear power plants and are not expected to be a problem during the license 4 renewal term.

5 The NRC staff has not identified any new and significant information during its independent 6 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 7 evaluation of other available information.

Therefore, the NRC staff concludes that there 8 would be no impacts of altered current patterns at intake and discharge structures during the 9 renewal term beyond those discussed in the GEIS.

10 Altered thermal stratification of lakes.

Based on information in the GEIS, the Commission 11 found that 12 Generally, lake stratification has not been found to be a problem at operating 13 nuclear power plants and is not expected to be a problem during the license 14 renewal term.

15 The NRC staff has not identified any new and significant information during its independent 16 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 17 evaluation of other available information.

Therefore, the NRC staff concludes that there 18 would be no impacts of altered thermal stratification of lakes during the renewal term beyond 19 those discussed in the GEIS.

20 Temperature effects on sediment transport capacity.

Based on information in the GEIS, the 21 Commission found that 22 These effects have not been found to be a problem at operating nuclear power 23 plants and are not expected to be a problem during the license renewal term.

24 The NRC staff has not identified any new and significant information during its independent 25 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 26 evaluation of other available information.

Therefore, the NRC staff concludes that there 27 would be no impacts of temperature effects on sediment transport capacity during the 28 renewal term beyond those discussed in the GEIS.

29 Scouring caused by discharged cooling water. Based on information in the GEIS, the 30 Commission found that 31 Scouring has not been found to be a problem at most operating nuclear power 32 plants and has caused only localized effects at a few plants. It is not expected to 33 be a problem during the license renewal term.

34 Environmental Impacts of Operation June 2007 4-5 Draft NUREG-1437, Supplement 31 The NRC staff has not identified any new and significant information during its independent 1 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 2 evaluation of other available information.

Therefore, the NRC staff concludes that there 3 would be no impacts of scouring caused by discharged cooling water during the renewal 4 term beyond those discussed in the GEIS.

5 Eutrophication. Based on information in the GEIS, the Commission found that 6 Eutrophication has not been found to be a problem at operating nuclear power 7 plants and is not expected to be a problem during the license renewal term.

8 The NRC staff has not identified any new and significant information during its independent 9 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 10 evaluation of other available information including plant monitoring data and technical 11 reports. Therefore, the NRC staff concludes that there would be no impacts of 12 eutrophication during the renewal term beyond those discussed in the GEIS.

13 Discharge of chlorine or other biocides.

Based on information in the GEIS, the Commission 14 found that 15 Effects are not a concern among regulatory and resource agencies, and are not 16 expected to be a problem during the license renewal term.

17 The NRC staff has not identified any new and significant information during its independent 18 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 19 evaluation of other available information including the State Pollutant Discharge Elimination 20 System (SPDES) permit for JAFNPP. Therefore, the NRC staff concludes that there would 21 be no impacts of discharge of chlorine or other biocides during the renewal term beyond 22 those discussed in the GEIS.

23 Discharge of sanitary wastes and minor chemical spills.

Based on information in the GEIS, 24 the Commission found that 25 Effects are readily controlled through [National Pollutant Discharge Elimination 26 System] NPDES permit and periodic modifications, if needed, and are not 27 expected to be a problem during the license renewal term.

28 The NRC staff has not identified any new and significant information during its independent 29 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 30 evaluation of other available information including the SPDES permit for JAFNPP.

31 Therefore, the NRC staff concludes that there would be no impacts of discharges of sanitary 32 wastes and minor chemical spills during the renewal term beyond those discussed in the 33 GEIS. 34 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-6 June 2007 Discharge of other metals in wastewater.

Based on information in the GEIS, the 1 Commission found that 2 These discharges have not been found to be a problem at operating nuclear 3 power plants with cooling-tower-based heat dissipation systems and have been 4 satisfactorily mitigated at other plants. They are not expected to be a problem 5 during the license renewal term.

6 The NRC staff has not identified any new and significant information during its independent 7 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 8 evaluation of other available information including the SPDES permit for JAFNPP.

9 Therefore, the NRC staff concludes that there would be no impacts of discharges of other 10 metals in wastewater during the renewal term beyond those discussed in the GEIS.

11 Water-use conflicts (plants with once-through cooling systems).

Based on information in the 12 GEIS, the Commission found that 13 These conflicts have not been found to be a problem at operating nuclear power 14 plants with once-through heat dissipation systems.

15 The NRC staff has not identified any new and significant information during its independent 16 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 17 evaluation of other available information.

Therefore, the NRC staff concludes that there 18 would be no impacts of water-use conflicts for plants with once-through cooling systems 19 during the renewal term beyond those discussed in the GEIS.

20 Accumulation of contaminants in sediments or biota. Based on information in the GEIS, the 21 Commission found that 22 Accumulation of contaminants has been a concern at a few nuclear power plants 23 but has been satisfactorily mitigated by replacing copper alloy condenser tubes 24 with those of another metal. It is not expected to be a problem during the license 25 renewal term.

26 The NRC staff has not identified any new and significant information during its independent 27 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 28 evaluation of available information. Therefore, the NRC staff concludes that there would be 29 no impacts of accumulation of contaminants in sediments or biota during the renewal term 30 beyond those discussed in the GEIS.

31 Entrainment of phytoplankton and zooplankton. Based on information in the GEIS, the 32 Commission found that 33 Environmental Impacts of Operation June 2007 4-7 Draft NUREG-1437, Supplement 31 Entrainment of phytoplankton and zooplankton has not been found to be a 1 problem at operating nuclear power plants and is not expected to be a problem 2 during the license renewal term.

3 The NRC staff has not identified any new and significant information during its independent 4 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 5 evaluation of other available information.

Therefore, the NRC staff concludes that there 6 would be no impacts of entrainment of phytoplankton and zooplankton during the renewal 7 term beyond those discussed in the GEIS.

8 Cold shock. Based on information in the GEIS, the Commission found that 9 Cold shock has been satisfactorily mitigated at operating nuclear plants with 10 once-through cooling systems, has not endangered fish populations or been 11 found to be a problem at operating nuclear power plants with cooling towers or 12 cooling ponds, and is not expected to be a problem during the license renewal 13 term. 14 The NRC staff has not identified any new and significant information during its independent 15 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 16 evaluation of other available information, including JAFNPP's original CWA Section 316(a) 17 demonstration report (NYPA 1976). Therefore, the NRC staff concludes that there would be 18 no impacts of cold shock during the renewal term beyond those discussed in the GEIS.

19 Thermal plume barrier to migrating fish. Based on information in the GEIS, the Commission 20 found that 21 Thermal plumes have not been found to be a problem at operating nuclear power 22 plants and are not expected to be a problem during the license renewal term.

23 The NRC staff has not identified any new and significant information during its independent 24 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 25 evaluation of other available information, including JAFNPP's original CWA Section 316(a) 26 demonstration report (NYPA 1976). Therefore, the NRC staff concludes that there would be 27 no impacts of thermal plume barriers to migrating fish during the renewal term beyond those 28 discussed in the GEIS.

29 Distribution of aquatic organisms. Based on information in the GEIS, the Commission found 30 that 31 Thermal discharge may have localized effects but is not expected to affect the 32 larger geographical distribution of aquatic organisms.

33 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-8 June 2007 The NRC staff has not identified any new and significant information during its independent 1 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 2 evaluation of other available information, including JAFNPP's original CWA Section 316(a) 3 demonstration report (NYPA 1976). Therefore, the NRC staff concludes that there would be 4 no impacts on distribution of aquatic organisms during the renewal term beyond those 5 discussed in the GEIS.

6 Premature emergence of aquatic insects. Based on information in the GEIS, the 7 Commission found that 8 Premature emergence has been found to be a localized effect at some operating 9 nuclear power plants but has not been a problem and is not expected to be a 10 problem during the license renewal term.

11 The NRC staff has not identified any new and significant information during its independent 12 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 13 evaluation of other available information.

Therefore, the NRC staff concludes that there 14 would be no impacts of premature emergence of aquatic insects during the renewal term 15 beyond those discussed in the GEIS.

16 Gas supersaturation (gas bubble disease). Based on information in the GEIS, the 17 Commission found that 18 Gas supersaturation was a concern at a small number of operating nuclear 19 power plants with once-through cooling systems but has been satisfactorily 20 mitigated. It has not been found to be a problem at operating nuclear power 21 plants with cooling towers or cooling ponds and is not expected to be a problem 22 during the license renewal term.

23 The NRC staff has not identified any new and significant information during its independent 24 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 25 evaluation of other available information. Ther efore, the NRC staff concludes that there are 26 no impacts of gas supersaturation during the renewal term beyond those discussed in the 27 GEIS. 28 Low dissolved oxygen in the discharge.

Based on information in the GEIS, the Commission 29 found that 30 Low dissolved oxygen has been a concern at one nuclear power plant with a 31 once-through cooling system but has been effectively mitigated. It has not been 32 found to be a problem at operating nuclear power plants with cooling towers or 33 cooling ponds and is not expected to be a problem during the license renewal 34 term. 35 Environmental Impacts of Operation June 2007 4-9 Draft NUREG-1437, Supplement 31 The NRC staff has not identified any new and significant information during its independent 1 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 2 evaluation of other available information.

Therefore, the NRC staff concludes that there 3 would be no impacts of low dissolved oxygen during the renewal term beyond those 4 discussed in the GEIS.

5 Losses from predation, parasitism, and disease among organisms exposed to sublethal 6 stresses. Based on information in the GEIS, the Commission found that 7 These types of losses have not been found to be a problem at operating nuclear 8 power plants and are not expected to be a problem during the license renewal 9 term. 10 The NRC staff has not identified any new and significant information during its independent 11 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 12 evaluation of other available information.

Therefore, the NRC staff concludes that there 13 would be no impacts of losses from predation, parasitism, and disease among organisms 14 exposed to sublethal stresses during the renewal term beyond those discussed in the GEIS.

15 Stimulation of nuisance organisms. Based on information in the GEIS, the Commission 16 found that 17 Stimulation of nuisance organisms has been satisfactorily mitigated at the single 18 nuclear power plant with a once-through cooling system where previously it was 19 a problem. It has not been found to be a problem at operating nuclear power 20 plants with cooling towers or cooling ponds and is not expected to be a problem 21 during the license renewal term.

22 The NRC staff has not identified any new and significant information during its independent 23 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 24 evaluation of other available information.

Therefore, the NRC staff concludes that there 25 would be no impacts of stimulation of nuisance organisms during the renewal term beyond 26 those discussed in the GEIS.

27 Microbiological organisms (occupational health). Based on information in the GEIS, the 28 Commission found that 29 Occupational health impacts are expected to be controlled by continued 30 application of accepted industrial hygiene practices to minimize worker 31 exposures.

32 The NRC staff has not identified any new and significant information during its independent 33 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 34 evaluation of other available information.

Therefore, the NRC staff concludes that there 35 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-10 June 2007 would be no impacts of microbiological organisms during the renewal term beyond those 1 discussed in the GEIS.

2 Noise. Based on information in the GEIS, the Commission found that 3 Noise has not been found to be a problem at operating plants and is not 4 expected to be a problem at any plant during the license renewal term.

5 The NRC staff has not identified any new and significant information during its independent 6 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 7 evaluation of other available information.

Therefore, the NRC staff concludes that there 8 would be no impacts of noise during the renewal term beyond those discussed in the GEIS.

9 The Category 2 issues related to cooling system operation during the renewal term that are 10 applicable to JAFNPP are listed in Table 4-2 and discussed in the sections that follow.

11 Table 4-2. Category 2 Issues Applicable to the Operation of the JAFNPP 12 Cooling System During the Renewal Term 13 ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section 10 CFR 51.53(c)(3)(ii) Subparagraph SEIS Section AQUATIC ECOLOGY (FOR PLANTS WITH ONCE

-THROUGH AND COOLING POND HEAT

-DISSIPATION SYSTEMS) Entrainment of fish and shellfish in early life stages 4.2.2.1.2 B 4.1.1 Impingement of fish and shellfish 4.2.2.1.3 B 4.1.2 Heat shock 4.2.2.1.4 B 4.1.3 14 4.1.1 Entrainment of Fish and Shellfish in Early Life Stages 15 For power plants with once-through cooling systems, the entrainment of fish and shellfish in 16 early life stages into cooling water systems associated with nuclear power plants is considered 17 a Category 2 issue that requires site-specific assessment before license renewal. Applicable 18 Category 2 issues are listed in Table 4-2. The NRC staff reviewed the JAFNPP ER (Entergy 19 2006a) and related documents, including Entergy's Proposal for Information Collection dated 20 January 31, 2006 (Entergy 2006b), and the 2004 SPDES Biological Monitoring Report for the 21 James A. FitzPatrick Nuclear Power Plant, dated May 2005 (EA 2005), and visited the JAFNPP 22 site several times. The NRC staff also reviewed the applicant's most current SPDES permit 23 (NY-0020109) and the accompanying fact sheet, the State of New York Best Technology 24 Available (BTA) determination letter dated March 1, 1996, and the State of New York 401 25 Certification letter dated November 5, 1975 (Entergy 2006a).

26 Environmental Impacts of Operation June 2007 4-11 Draft NUREG-1437, Supplement 31 Section 316(b) of the Clean Water Act of 1977 (CWA), common name of the Federal Water 1 Pollution Control Act, requires that the location, design, construction, and capacity of cooling 2 water intake structures reflect the best available technology for minimizing adverse 3 environmental impacts (33 U.S.C. 1326). Entrainment of fish and shellfish into the cooling water 4 system is a potential adverse environmental impact that can be minimized by the use of best 5 available technology. Licensees may be required as part of the NPDES renewal to alter the 6 intake structure, redesign the cooling system, modify facility operation, or take other mitigative 7 measures. Licensees must comply with Section 316(b) of the CWA. However, EPA's Phase II 8 Rule has been suspended and compliance with the rule is based on EPA's best professional 9 judgment.

10 JAFNPP has a once-through heat dissipation system that uses water from Lake Ontario for 11 condenser cooling and service water. Under normal operating conditions at JAFNPP, all three 12 circulating water pumps are operating to produce a combined intake flow of 352,600 gallons per 13 minute (gpm) (518 million gallons per day [gpd]), as measured through the condensers. Three 14 50 percent-capacity service water pumps also draw water from the intake bay, downstream of 15 the traveling screens, at a rate of 36,000 gpm (52 million gpd). At the submerged offshore 16 intake structure, water velocity at the outer face of the bar racks is 1.2 feet per second (ft/s) and 17 1.6 ft/s through the bar racks. Once in the D-shaped intake tunnel, average water velocity is 18 4.7 ft/s. Reinforced invert paving and wire mesh-reinforced gunite lining provides for hydraulic 19 smoothness throughout the tunnel (Entergy 2006a). Once in the screenwell-pumphouse intake 20 bay, the water flows through the trash bars and traveling screens. Each traveling screen has a 21 design capacity flow rate of 125,000 gpm and design approach velocity of 1.2 ft/s; the screens 22 rotate from 10 to 20 feet per minute (ft/m). Screen wash pumps operate periodically and in 23 response to pressure differentials to remove debris from the traveling screens. Screen wash 24 pumps take water from the service water system and spray the traveling screens at a rate of 25 720 gpm/screen, at a minimum of 80 pounds per square inch (lb/in

2) gauge pressure (Entergy 26 2006b). 27 The maximum allowable temperature rise of the cooling system water through the main 28 condenser is 32.4 degrees Fahrenheit (°F) above am bient water temperature (Entergy 2006a).

29 Organisms entrained in the intake flow that are small enough to pass through the vertical 30 traveling screens enter the station cooling system where they are subjected to thermal stress 31 and mechanical and hydraulic forces. In a study of the Haddam Neck Plant, a nuclear power 32 plant with a once-through cooling system that formerly operated on the Connecticut River, it was 33 found that mechanical damage is the main cause of entrainment mortality, while thermal shock 34 was responsible for only about 20 percent of mortality (Marcy 2004). While some entrainment 35 survival may occur, for this review NRC staff conservatively assumed that 100 percent of 36 entrained organisms die.

37 During periods of cold weather, when inlet water temperature is below 45°F, warm discharge 38 water is recirculated from the discharge tunnel into the intake bay by a tempering gate-the 39 amount of raw intake water is reduced approximately 16 to 18 percent during this mode of 40 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-12 June 2007 operation. Total entrainment loss is directly proportional to both the density of ichthyoplankton 1 in the nearfield source of water and to the raw water intake flow during the period of 2 consideration. JAFNPP has compiled monthly actual intake flow data from January 1998 3 through July 2005, and actual pumping rates have historically been lower than plant-design 4 flows. This is because the circulating water pumps operate at various head differentials and the 5 plant's cooling water needs vary in response to reduced generation, environmental conditions, 6 and periodic maintenance outages. This historical operation is considered representative of the 7 current and expected future cooling water intake flow operations at JAFNPP (Entergy 2006b).

8 In the late 1960s, the New York Power Authority (NYPA) and the Niagara Mohawk Power 9 Corporation conducted ecological studies in the nearshore vicinity of the Nine Mile Point 10 promontory to determine the potential impact of power plants on the Lake Ontario aquatic 11 ecosystem. Part of this program included weekly monitoring of the distribution of fish eggs and 12 larvae at contour depths from 20 to 100 ft, from April through December of 1973 through 1979.

13 Egg collections consisted primarily of alewife (Alosa pseudoharengus) and rainbow smelt 14 (Osmerus mordax); larval samples were also dominated by alewife. Alewife were the primary 15 component of the ichthyoplankton community, followed by rainbow smelt, white perch (Morone 16 americana), sculpin (Cottidae spp.), and tessellated darter (Etheostoma olmstedi). Low 17 numbers of other species were collected, including yellow perch (Perca flaverscens), rainbow 18 smelt, and Morone spp., but overall, the data indicated that the Nine Mile Point vicinity was a 19 significant spawning habitat for only alewife and rainbow smelt. A study of species composition 20 and distribution of fish larvae collected in the Nine Mile Point area published in 1975 concluded 21 the area is not a desirable spawning or nursery habitat because of extensive nearshore wave 22 action and unsuitable bedrock and rubble substrate (TI 1979).

23 The ecological studies revealed that the temporal distribution of eggs and larvae in the Nine 24 Mile Point vicinity is generally characterized by two spawning groups: those that spawn from 25 winter to early spring (burbot [Lota lota], Coregonus spp., rainbow smelt, and yellow perch), and 26 those that spawn from late spring through summer (alewife, white perch, and carp [

Cyprinus 27 carpio]). Subsequently, eggs and larvae from these groups are most abundant from April to 28 June and from July to August, respectively. Eggs and larvae were most abundant at the 20-ft 29 contour depth; their numbers were lower at deeper contours (TI 1979).

30 Because Nine Mile Point Nuclear Station (NMPNS) Unit 1 is so close to JAFNPP and NMPNS's 31 intake and cooling systems are similar to JAFNPP's, entrainment data from NMPNS were 32 reviewed for this analysis. NMPNS sampled water directly from the Unit 1 intake forebay once 33 or twice a month from 1973 through 1978. The species composition of the intake water was 34 generally very similar to the species composition of Lake Ontario, except that intake water 35 ichthyoplankton densities were lower than lake water ichthyoplankton densities and species that 36 occurred at low frequencies in the lake samples were not detected at all in the intake water 37 samples. Temporal abundance was also similar (Entergy 2006b).

38 Environmental Impacts of Operation June 2007 4-13 Draft NUREG-1437, Supplement 31 The first year NMPNS Unit 1 entrainment data were collected when both NMPNS Unit 1 and 1 JAFNPP were operating was 1976. Burbot and Coregonus spp. were most frequently entrained 2 at NMPNS Unit 1 in the early spring, rainbow smelt in mid-spring, and alewife in late spring and 3 summer. Abundance of entrained fish was highest in the summer due to the large alewife 4 population: weekly average alewife densities were 0 to 34.4 eggs per cubic meter (m

3) and 0 to 5 0.5 larvae per m

3. Weekly average rainbow smelt densities were 0 to 0.15 eggs per m 3 and 0 to 6 0.02 larvae per m

3. Conservatively assuming the maximum weekly density and that NMPNS 7 Unit 1 was running at full capacity, weekly entrainment totals were estimated at 350 million 8 alewife eggs and 4.9 million alewife larvae; and 1.5 million rainbow smelt eggs and 205,000 9 rainbow smelt larvae. For perspective, these numbers were extrapolated using alewife 10 fecundity data and compared to the estimated standing stock number of alewife in the U.S.

11 waters of Lake Ontario (12.56 billion in 1976), resulting in an estimated loss of approximately 12 0.0002 percent of alewife population females and 0.014 percent alewife larvae. An estimated 13 0.00001 percent female rainbow smelt population loss was calculated for egg entrainment and 14 0.025 percent for larval entrainment (Entergy 2006b).

15 A 1997 NMPNS entrainment study showed much lower total entrainment numbers than the 16 1977 data: corrected for flow into the plant, an estimated 86.6 million ichthyoplankton were 17 entrained from April through August at NMPNS Unit 1. Alewife represented 90.7 percent of the 18 ichthyoplankton entrainment, followed by the tessellated darter at 4.2 percent (3.6 million) and 19 the threespine stickleback (Gasterosteus aculeatus) at 2.8 percent (2.4 million). Rainbow smelt 20 accounted for only 0.1 percent. The difference in the 1977 and 1997 entrainment numbers is 21 likely due primarily to the difference in abundance of alewife and rainbow smelt lake-wide 22 (Entergy 2006b). Both alewife and rainbow smelt populations throughout Lake Ontario have 23 likely declined due to excessive salmonid predation and lake-wide food web changes that 24 occurred primarily in response to Dreissenid spp. invasion and lake water quality improvements 25 (Mills et al. 2003).

26 The status of Lake Ontario's alewife population is of particular concern. As prey fish for stocked 27 salmonids, alewife support the lake's major sport fisheries, which are strong contributors to local 28 economies. To put the 1997 alewife entrainment data into perspective, NRC staff calculated 29 alewife fecundity loss in a similar manner to the 1976 calculations above. In performing these 30 calculations, NRC used a 1997 Lake Ontario (U.S.

waters) alewife standing stock population of 31 941,300,000 (Entergy 2006a); assumed a 1:1 sex ratio; assumed an alewife average lifetime 32 fecundity of 26,272 eggs (Entergy 2006b); and conservatively assumed the entire percentage of 33 entrained alewife ichthyoplankton was composed of eggs. In estimating total entrainment for all 34 of 1997, NRC staff also conservatively assumed that the April to August rate of entrainment was 35 maintained throughout the entire year, which due to the spawning habits of alewife and lower 36 intake flows during winter months, is highly unlikely. By multiplying the number of female 37 alewife by fecundity and dividing this number by entrainment, the estimated loss of population 38 fecundity in the U.S. waters of Lake Ontario caused by NMPNS Unit 1 was 0.0015 percent for 39 1997. This minor percentage of ichthyoplankton loss would not result in a detectable impact on 40 the lake's alewife population.

41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-14 June 2007 On January 24, 2006, JAFNPP applied for a renewal of its New York SPDES permit, which was 1 scheduled to expire on August 1, 2006. Until this renewal permit is finalized, the existing permit 2 (NY-0020109) remains in effect. As stated earlier, no entrainment studies have been completed 3 by JAFNPP since the original Nine Mile Point promontory baseline ecology studies done in the 4 1970s. On July 9, 2004, the EPA published a final rule that addressed cooling water intake 5 structures at existing facilities with flow levels that exceed a minimum threshold value of 50 6 million gpd (316(b) Phase II regulations). Owners of such facilities that did not utilize closed 7 cycle cooling were provided a number of compliance alternatives to demonstrate compliance 8 with the new regulations. The demonstration is implemented through the NPDES permitting 9 program. To demonstrate compliance, JAFNPP is currently conducting a one-year entrainment 10 sampling program that was approved by the New York State Department of Environmental 11 Conservation (NYSDEC). The program began in April 2006 and will conclude in March 2007. A 12 second year of entrainment sampling may occur to verify the 2006 results. An entrainment 13 survival study may also be undertaken if it appears there is a high survival rate for 14 ichthyoplankton. The goal of the entrainment program is to estimate the seasonal and annual 15 total abundance of fish eggs and larvae that flow into the cooling water intake system. The goal 16 of the survival study, if undertaken, would be to determine the effects the cooling water intake 17 system has on entrained organisms (Entergy 2006b). The majority of fish, fish larvae, and eggs 18 are not expected to survive passage through the JAFNPP cooling system, as cooling water 19 temperature rises up to 32.4°F above ambient intake water temperature and organisms would 20 experience significant hydrodynamic changes and mechanic forces (AEC 1973).

21 In the 2006 JAFNPP entrainment sampling program, intake water was sampled weekly from 22 April to November of 2006 and every two weeks from November 2006 through March 2007.

23 One daytime and one nighttime sample were taken on the same day each week from the 24 forebay at two sample depths, 14 ft and 20 ft below the water surface, for a total of 160 25 entrainment samples. The sampling was conducted using a pump with 3-inch (in.) intake and 26 discharge hoses and a plankton net suspended in a tank. Each sample was at least 100 m 3 27 (26,417 gallons) as calibrated by an in-line flow meter (Entergy 2006b). As of the date of 28 publication of this draft SEIS, the results of the one year study are not available. Nevertheless, 29 the NRC staff did review preliminary (unpublished) study data to support this analysis.

30 In reviewing the historical entrainment data at NMPNS Unit 1, it appears that the primary factor 31 influencing entrainment rates is the abundance of eggs and larvae in the water near the plant 32 intake. Potential entrainment losses at JAFNPP, when compared to the standing stock of the 33 lake's fish species, are not likely to adversely affect the Lake Ontario fish community. A study 34 on entrainment and impingement rates at a nuclear power plant located on the Upper 35 Mississippi River (LaJeone and Monzingo 2000) concluded that naturally occurring 36 environmental conditions have a greater effect on fish populations than plant operations, and 37 fluctuations in the annual impingement and entrainment numbers reflect primarily river 38 conditions and fish populations' responses to them. The estimated 0.0015 percent fecundity 39 loss of the female alewife in Lake Ontario (U.S. waters) standing stock from NMPNS Unit 1 in 40 1997 was a conservative estimate of the potential entrainment impact that is possible at 41 JAFNPP and would not result in a detectable impact on the alewife fishery. Until the results of 42 Environmental Impacts of Operation June 2007 4-15 Draft NUREG-1437, Supplement 31 the 2006 entrainment study are finalized, there can be no definitive quantification of the current 1 entrainment impacts on Lake Ontario at JAFNPP. However, based on the results of historical 2 entrainment studies, similar operations at NMPNS Unit 1, and no change in operations at 3 JAFNPP during the license renewal term, there is no evidence to suggest that past, current, or 4 future entrainment of eggs, larvae, or juvenile forms of these species would destabilize or 5 noticeably alter any important attribute of Lake Ontario. The preliminary data from the recent 6 entrainment study at JAFNPP supports this conclusion. Therefore, the NRC staff has 7 determined that the potential impacts of entrainment of fish and shellfish by JAFNPP during the 8 20-year renewal period would be SMALL. The NRC staff identified potential mitigation 9 measures, including closed cycle cooling, and derating the facility and scheduling outages 10 during historic periods of high ichthyoplankton density. However, the NRC staff concluded that 11 none of the mitigation measures considered would be beneficial enough to reduce the 12 significance of the adverse entrainment impacts to the Lake Ontario fishery. Under the 13 provisions of the state NPDES permitting program, however, NYSDEC may impose further 14 restrictions or require modifications to the cooling system to reduce the impact of entrainment.

15 4.1.2 Impingement of Fish and Shellfish 16 For plants with once-through cooling systems, the impingement of fish and shellfish on debris 17 screens associated with plant cooling systems is considered a Category 2 issue, which requires 18 a site-specific assessment before license r enewal. The NRC staff reviewed the JAFNPP ER 19 (Entergy 2006a) and related documents, including Entergy's Proposal for Information Collection 20 dated January 31, 2006 (Entergy 2006b), and the 2004 SPDES Biological Monitoring Report for 21 the James A. FitzPatrick Nuclear Power Plant, dated May 2005 (EA 2005), and visited the 22 JAFNPP site several times. The NRC staff also reviewed the applicant's most current SPDES 23 permit (NY-0020109) and the accompanying fact sheet, the State of New York Best Technology 24 Available (BTA) determination letter dated March 1, 1996, and the 401 Certification letter dated 25 November 5, 1975 (Entergy 2006a).

26 Section 316(b) of the CWA, requires that the location, design, construction, and capacity of 27 cooling water intake structures reflect the best available technology for minimizing adverse 28 environmental impacts (33 U.S.C. 1326). Impingement of fish and shellfish into the cooling 29 water system is a potential adverse environmental impact that can be minimized by the use of 30 best technology available. Licensees may be required as part of the NPDES renewal to alter 31 the intake structure, redesign the cooling system, modify facility operation, or take other 32 mitigative measures. Licensees must comply with Section 316(b) of the CWA. However, EPA's 33 Phase II Rule has been suspended and compliance with the rule is based on EPA's best 34 professional judgment.

35 JAFNPP does not have a fish return system for fish impinged on the traveling screens.

36 Therefore, impinged fish are not returned to the lake and do not survive (Entergy 2006a).

37 JAFNPP operates a high-frequency/high-amplitude acoustic fish deterrence system (FDS) 38 annually from April through October that is specifically designed to deter alewife. Historical 39 studies have shown that 97 percent of alewife impingement occurs during these months (Ross 40 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-16 June 2007 and Dunning 1996). The JAFNPP FDS consists of nine overlapping, wide-beam, high-1 frequency transducers mounted on top of the submerged intake structure. The transducers 2 produce an array sound field, ensuring 360° coverage from the water surface to the lake bottom 3 and extending at least 33 ft from the perimeter of the intake structure. Per the JAFNPP SPDES 4 permit, the FDS is dewinterized and operational by the first week of April each year and is 5 removed from service (winterized) each October. The FDS was put into long-term operation in 6 1998 (EA 2005).

7 Impingement of fish was monitored at JAFNPP annually from 1976 to 1997 and again in 2004.

8 In issuing the most recent SPDES permit, NYSDEC determined that JAFNPP's impingement 9 database was adequate to support a transition to a long-term, less intensive monitoring 10 program, requiring the plant to conduct only one, one-year impingement program during the 11 five-year permit period from 2001 to 2006 (Entergy 2006a). The results of JAFNPP 12 impingement monitoring from 1976 to 1997 are summarized in Table 4-3. Generally, alewife 13 and rainbow smelt account for the majority of individuals impinged from 1976 through 1994.

14 The threespine stickleback is the third-most frequently impinged species, but larger 15 impingement numbers did not occur until 1995 to 1997 and 2004 with one anomaly year in 1978 16 (EA 2005). These impingement trends reflect lake-wide conditions. The abundance of alewife 17 and rainbow smelt has declined over the past decade due to ecological stressors, invasive 18 species, and increasing predatory pressure; concurrently the threespine stickleback population 19 has greatly increased. Fish population studies of Lake Ontario suggest that the lake pelagic fish 20 community may be undergoing a change (Schaner and Prindle 2004).

21 The 2004 SPDES Biological Monitoring Report for JAFNPP also suggests that weather 22 conditions can dramatically affect impingement rates, with other studies supporting this 23 observation. An exceptionally high number of alewife were impinged in 1976 (almost 4 million 24 fish) as compared to the rest of the data from 1977 to 1997 and 2004; the latter data is more 25 representative than the 1976 data of impingement abundance observed during the past two 26 decades. Although annual die-offs of alewife occur every year, a catastrophic die-off of alewife 27 occurred in the winter and early spring of 1977, resulting in an estimated 60 to 75 percent loss 28 of the adult alewife population, explaining the high 1976 impingement numbers (EA 2005).

29 The alewife was the most common species taken during the entire 22-year impingement study.

30 Rainbow smelt were most abundant in 1978, 1979, 1987, 1990, and 1992, and typically the 31 second-most abundant species impinged each year. Comparing impingement rates to lake-32 wide population estimates for U.S. waters, in 1997 alewife and rainbow smelt impingement at 33 JAFNPP represented only 0.0015 percent and 0.0012 percent of the populations, respectively 34 (EA 2005).

35 Environmental Impacts of Operation June 2007 4-17 Draft NUREG-1437, Supplement 31 Table 4-3. Results of Impingement Monitoring at JAFNPP from 1976 through 1997 1 (Corrected for Flow and Traveling Screen Efficiencies) 2 Fish Impingement, 1976-1997 Scientific Name Common Name Total Number Fish Impinged (a) Range of Annual Number of Fish Impinged (a) Percentage of Fish Impinged, Average Over 22-Year Period (1976-1997)

Alosa pseudoharengus alewife 7,546,639 1,312-3,916,717 58.73% Cottus spp. sculpins 35,232 747-4,916 0.27% Dorosoma cepedianum gizzard shad 116,239 26-26,173 0.90% Etheostoma olmstedi tessellated darter34,423 68-6,708 0.27% Gasterosteus aculeatus threespine stickleback 3,114,822 78-1,392,763 24.24% Morone americana white perch 69,669 53-13,353 0.54% Notropis atherinoides spottail shiner 82,245 282-11,683 0.64% Osmerus mordax rainbow smelt 1,780,388 1,527-282,373 13.86% Percopsis omiscomaycus trout perch 70,120 180-12,183 0.55% Source: EA 2005 (a) Number of fish taken on the intake screens over a one year period.

3 The alewife is of special concern because Lake Ontario's valuable salmonid sport fishery is 4 primarily dependent on this single-forage species. Alewife populations show high mortality rates 5 after especially cold winters and have historically experienced mass die-offs. Alewife are easily 6 stressed and during peak population levels, stress can result in large spring die-offs.

7 Susceptibility to cold is related to inadequate lipid reserves, and in spring, alewife are in a 8 weakened condition due to lack of forage in the winter and by the stress related to spawning 9 (Eshenroder at al. 1995). They are affected by both osmotic stress associated with life in fresh 10 water and exposure to fluctuating water temperatures when they move to inshore waters (e.g., 11 exposure to colder waters during an upwelling event can cause the fish to die). Stressed fish 12 are more susceptible to impingement because they exhibit little or no motility and are passively 13 drawn into the intake (UWSGI 2002).

14 This alewife population instability has been compounded by excessive salmonid predation-in 15 1991 the predator demand was estimated to be equal to the total prey production, and modeling 16 suggested that a die-off of more than 25 percent above average would cause the alewife 17 population to crash (Stewart and Schaner 2002). U.S. Geological Survey (USGS) data indicate 18 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-18 June 2007 that Lake Ontario alewife numbers are moderate and have remained stable since the mid-1 1990s. Abundance is considerably less than it was in the 1980s, but as discussed in 2 Section 2.2.5 of this draft SEIS, the alewife population decrease was likely caused by excessive 3 salmonid predation and changes in the Lake Ontario food web (O'Gorman et al. 2005). In 4 response to the decreasing alewife population, New York State and Ontario, Canada, both 5 reduced their salmonid stocking programs in 1993. However, in 1997 the stocking rates were 6 increased slightly again. Additionally, since 1997, increasing natural reproduction of Chinook 7 salmon (Oncorhynchus tshawytscha) has been observed, so predation pressure continues on 8 the alewife (Schaner and Prindle 2004). O'Gorman et al. (2005) report that although the 2004 9 alewife population in the U.S. waters of Lake Ontario is well below the long-term (19-year) 10 average, the wet weight condition of adult alewife in the fall of 2004 was higher than in any year 11 since 1980, indicating the population was more in balance with the productivity of Lake Ontario.

12 This recent population stabilization may be occurring because of fewer individuals to compete 13 for food, a switch in alewife diet from the zebra muscle-decimated amphipod Diporeia sp. to the 14 possum shrimp (Mysis sp.), and the population's subsequent movement toward deeper lake 15 waters, where they avoid the intake structure altogether (EA 2005).

16 Rainbow smelt impingement rates appear to be influenced by meteorological conditions (strong 17 winds and increased wave action) and lake-wide population changes due to cannibalism of 18 young smelt by adult smelt and salmonid predation on adult smelt (EA 2005). Similar to the 19 alewife population, changes in the Lake Ontario ecosystem brought on by improvements in 20 water quality and invasive species have altered the distribution of the rainbow smelt population 21 away from the area of the intake structure and to deeper portions of the Lake where food is 22 more plentiful (Mills et al. 2005).

23 Impingement abundance of other fish, including white perch, yellow perch, smallmouth bass 24 (Micropterus dolomieu), and salmonids also appears to fluctuate with regard to population 25 dynamics and short-term meteorological events that influence the impingement process.

26 Results from the JAFNPP impingement monitoring program in 1976 to 1997 and 2004 indicate 27 that late fall and winter storms tend to increase impingement of the young-of-year fish for these 28 species. During the 2004 impingement monitoring, no rare, threatened, or endangered species 29 were collected at JAFNPP (EA 2005). Data from the 2004 impingement monitoring are 30 summarized in Table 4-4. The total impingement at JAFNPP in 2004 was 230,534 organisms, 31 of which threespine stickleback comprised 87.44 percent of total impingement, alewife 32 7.29 percent, rainbow smelt 0.66 percent, smallmouth bass 0.48 percent, white perch 33 0.21 percent, yellow perch 0.17 percent, salmonids 0.06 percent, and all others species 34 3.69 percent (EA 2005).

35 Environmental Impacts of Operation June 2007 4-19 Draft NUREG-1437, Supplement 31 Table 4-4. Results of Impingement Monitoring at JAFNPP, 2004 1 (Corrected for Flow and Traveling Screen Efficiencies) 2 Fish Impingement, 2004 Scientific Name Common Name Total Number of Fish Impinged (a) Average Monthly Number of Fish Impinged (a) Percentage of Fish Impinged, Annual Average, 2004 Alosa Pseudoharengus alewife 9,203 767 21.40% Cottus spp. sculpins 432 36 1.00% Dorosoma cepedianum gizzard shad 35 3 0.08% Etheostoma olmstedi tessellated darter18 2 0.04% Gasterosteus aculeatus threespine stickleback 32,543 2,712 75.66% Morone americana white perch 71 6 0.17% Notropis atherinoides spottail shiner 118 10 0.27% Osmerus mordax rainbow smelt 315 26 0.73% Percopsis omiscomaycus trout perch 275 23 0.64% Source: EA 2005 (a) Total number of fish taken on the intake screens during 2004.

3 The 2004 alewife and rainbow smelt impingement rates comprise just 0.0074 percent and 4 0.0001 percent of estimated lake-wide populations, respectively, when compared to 2005 lake-5 wide standing stock estimates of alewife and rainbow smelt. These represent very minor losses 6 to the populations. The 2005 standing stock numbers were estimated by a joint pelagic 7 planktivore monitoring program conducted by the NYSDEC and the Ontario Ministry of Natural 8 Resources(OMNR). The NYSDEC/OMNR report indicated that the 2005 alewife population was 9 the lowest since the bi-national pelagic planktivore monitoring program began in 1997, making 10 0.0074 percent a conservative estimate; however, the rainbow smelt population had increased 11 in 2005 from two previous low years (Schaner and LaPan 2005). Threespine stickleback is an 12 invasive species that has been prominent in the Lake Ontario ecosystem since the early 1990s.

13 There is no formal monitoring program conducted for this species, but monitoring programs for 14 pelagic fish of interest (alewife and rainbow smelt) have noted that threespine stickleback have 15 been the dominant catch in most lake tows (Schaner and Prindle 2004).

16 Since the inception of the JAFNPP impingement monitoring program, a total of 2966 salmonids 17 (corrected for intake flow and traveling screen efficiencies) have been impinged from 1976 18 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-20 June 2007 through 1997, and in 2004. In 2005 alone, the NYSDEC salmonid stocking program stocked 1 3,554,745 salmonids in Lake Ontario and its tributaries (Eckert 2005). OMNR also conducts its 2 own stocking program. Concentrated stocking efforts began in 1980, with Ontario and New 3 York limiting stocking to a total of 8 million salmonids per year. In response to the prey fish 4 population concerns, current combined stocking levels have been maintained between 4 and 5 5.5 million salmonids per year since 1993 (Mills et al. 2003).

6 A number of biological, environmental, and meteorological factors may work in concert to 7 influence yearly variations in impingement species abundance. The recent increase in 8 threespine stickleback impingements may be partly caused by the lake-wide decrease in alewife 9 and the dominating presence of zebra mussels. Impingement rates are highest in the spring 10 and peak in May when approximately 35 percent of all impingement occurs. This corresponds 11 with fish migrating toward warmer inshore waters to spawn. The timing of the migration may 12 vary according to meteorological conditions. Impingement rates then begin to fall again in June 13 as fish migrate back to deeper waters after spawning. Impingement rates once again increase 14 from October through December, when 21 percent of all impingement occurs. This is thought to 15 occur because at this time, young-of-year fish, especially alewife and rainbow smelt, grow to a 16 size that is particularly susceptible to impingement. Certain meteorological conditions, such as 17 strong westerly and northwesterly winds, wave height, and water temperature, also appear to 18 influence young-of-year impingement at this time of year (EA 2005).

19 Other factors impacting impingement include the timing and duration of station outages for 20 refueling and maintenance. During maintenance or refueling outages, typically only one or two 21 of the three main circulating water pumps are operational, significantly reducing the flow of lake 22 water into the plant. The reduced flow through the intake generally results in reduced 23 impingement. In recent years, plants outages have become less frequent and shorter in 24 duration due to improvements in plant operational efficiency, so outage reduction effects on 25 impingement are less than those that occurred in the 1980s and 1990s (EA 2005). Warm 26 discharge water is also recirculated during periods of cold weather, reducing lake water flow into 27 the plant. JAFNPP has compiled monthly actual intake flow data from January 1998 through 28 July 2005, and actual pumping rates have historically been lower than plant-design flows. This 29 is because the circulating water pumps operate at various head differentials and the plant's 30 cooling water needs vary in response to reduced generation, environmental conditions, and 31 periodic maintenance outages. These historical data are considered representative of the 32 current and expected future cooling water intake flow operations at JAFNPP (Entergy 2006b).

33 Generally, meteorological conditions that change fish populations appear to have the most 34 profound effect on impingement rates at JAFNPP. Periodic die-offs of populations occur due to 35 a combination of climatic conditions and the physical condition of population individuals. As 36 mentioned above, this was most prominently seen in the winter/spring 1977 alewife die-off: the 37 alewife impingement rate dropped from 3,916,717 fish in 1976 to 187,305 in 1977 (EA 2005).

38 Environmental Impacts of Operation June 2007 4-21 Draft NUREG-1437, Supplement 31 Historically, changes in fish populations around JAFNPP have likely been the result of naturally 1 occurring fluctuations. When the changes are profound (such as a mass winter die-off of 2 alewife), they are easily observed in the annual estimates of fish impinged at JAFNPP.

3 However, when the changes are subtle and over a longer period of time, it is difficult to 4 differentiate between meteorological conditions and daily plant operations, the two main factors 5 in fish impingement.

6 Due to the susceptibility of alewife to be impinged in the intake area, the delicate nature of 7 alewife, and the strong fright response to high frequency sound that alewife demonstrate, at the 8 time of JAFNPP's last SPDES permit issuance, NYSDEC determined the FDS installed at 9 JAFNPP was the best technology available for reducing impingement impacts (Entergy 2006a).

10 This determination is documented in a letter from the NYSDEC dated March 1, 1996. Testing of 11 the FDS occurred in spring of 1991 and 1993, and it was shown to reduce alewife impingement 12 by over 87 percent. Another deterrence system test was conducted in 1997, and preliminary 13 results confirmed the FDS reduced alewife impingement by 87 percent (EA 2005).

The FDS 14 has only been proven to deter alewife; no studies have been done to document its effectiveness 15 on other pelagic species. Since the FDS was installed, there have been no significant alewife 16 impingement events at JAFNPP.

17 In the JAFNPP Proposal for Information Collection dated January 31, 2006 (Entergy 2006b), 18 submitted to the NYSDEC to satisfy 316(b) Phase II regulations, JAFNPP proposed to obtain no 19 new impingement data because a recent annual impingement study had been completed in 20 2004. Since plant operations will not change significantly, these 2004 impingement rates are 21 indicative of future impingement rates, and are considered by the NRC staff to be too small to 22 have any observable impact on the lake-wide populations and biomass. Based on the results of 23 past impingement studies and the operating history of the JAFNPP intake structure and FDS, 24 the NRC staff concludes that the potential impacts of impingement for fish and shellfish at 25 JAFNPP are SMALL. The NRC staff identified pot ential mitigation measures, including installing 26 a fish return system, closed cycle cooling, and derating the facility and scheduling plant outages 27 during historic peak impingement periods. However, the NRC staff concluded that none of the 28 mitigation measures considered would be beneficial enough to reduce the significance of 29 adverse impingement impacts to the Lake Ontario fishery. Under the provisions of the state 30 NPDES permitting program, however, NYSDEC may impose further restrictions or require 31 modifications to the cooling system to reduce the impact of impingement.

32 4.1.3 Heat Shock 33 Heat shock can be defined as acute thermal stress caused by exposure to a sudden elevation 34 of water temperature that adversely affects the metabolism and behavior of fish and can lead to 35 death. Heat shock is most likely to occur when an offline unit returns to service or when a 36 station has a discharge canal, effectively trapping fish in the flow of the heated discharge from 37 the plant. For plants with once-through cooling systems, the effects of heat shock are listed as 38 a Category 2 issue, requiring a plant-specific assessment before license renewal. In the GEIS, 39 the NRC made impacts on fish and shellfish resources resulting from heat shock a Category 2 40 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-22 June 2007 issue for once-through plants because of continuing concerns about thermal-discharge effects 1 and the possible need to modify thermal discharges in the future in response to changing 2 environmental conditions. Information to be considered includes (1) the type of cooling system 3 (whether once-through or cooling pond) and (2) evidence of a CWA Section 316(a) variance or 4 equivalent State documentation. To perform this evaluation, the NRC staff visited the JAFNPP 5 site several times, reviewed the JAFNPP ER (Entergy 2006a), reviewed JAFNPP's original 6 CWA Section 316(a) demonstration report (NYPA 1976), and reviewed JAFNPP's most current 7 SPDES permit (NY-0020109), which was issued on August 1, 2001, and is in force until a new 8 permit is issued by NYSDEC (Entergy 2006a).

9 Section 316(a) of the CWA establishes a process whereby the applicant can demonstrate that 10 the established thermal discharge limitations are more stringent than necessary to protect 11 balanced indigenous populations of fish and wildlife and obtain facility-specific thermal 12 discharge limits (33 U.S.C. 1326). The JAFNPP CWA Section 316(a) demonstration was 13 submitted to the NYSDEC in 1976 by NYPA, the former owner of JAFNPP. The demonstration 14 was based on pre-operational and post-operational engineering, hydrological, and ecological 15 data, and concluded that thermal discharge from the plant would not result in any long-term 16 adverse impacts to the Lake Ontario ecosystem. The JAFNPP CWA Section 316(a) 17 demonstration followed procedures prescribed by the EPA during meetings between NYPA and 18 EPA, and as outlined in the draft EPA document, 316(a) Technical Guidance Manual and Guide 19 for Thermal Effects Sections of Nuclear Facilities Environmental Impact Statements , dated 20 May 1, 1977 (EPA 1977). The 316(a) demonstration included a description of the plant, 21 baseline hydrographic characteristics of Lake Ontario and the site, plant thermal discharge 22 characteristics, a description of the biological community in the Nine Mile Point vicinity and a 23 selection of representative fish species, and an evaluation of potential impacts of the plant's 24 thermal discharge. The potential thermal discharge effects were based on thermal tolerance 25 and behavior data for the representative fish species, field data collected in the vicinity of 26 JAFNPP, and a review of literature on the effect of thermal discharges. It was concluded that 27 the multi-port diffuser design of the JAFNPP discharge structure would prevent the thermal 28 discharge from harming the biological community in the Nine Mile Point vicinity (NYPA 1976).

29 NYSDEC accepted the conclusions of the 316(a) demonstration in their first issuance of the 30 JAFNPP SPDES permit containing the CWA Section 316(a) variance specifying alternative 31 thermal effluent limitations for the plant, and subsequently in renewed permits issued thereafter.

32 JAFNPP's SPDES permit states that thermal discharge from the plant ensures the "protection 33 and propagation of a balanced indigenous population of shellfish, fish, and wildlife in Lake 34 Ontario" and as such, the plant is allowed alternative effluent limitations. These limitations are 35 included in Part 1, Condition 8 of the plant's SPDES permit and state that the water temperature 36 at the surface of the lake shall not be raised more than 3°F over the ambient temperature of the 37 water, with the exception of a 35-acre (ac) (1.524.6 x 10 6 ft 2) mixing zone from the point of 38 discharge. To ensure this condition is met, the permit allows a maximum discharge temperature 39 of 112°F as measured at the discharge outlet in the screenwell-pumphouse, with a maximum 40 allowable intake-discharge temperature difference (T) of 32.4°F. The net addition of heat 41 Environmental Impacts of Operation June 2007 4-23 Draft NUREG-1437, Supplement 31 rejected to Lake Ontario is limited to 6.00 x 10 9 British thermal units per hour (BTU/hr) (Entergy 1 2006a). Total heat rejected to the lake is a function of electrical load-heat rejection increases 2 with an increase in electrical load. When JAFNPP is operating at full power, the heat rejection 3 rate is calculated to be 5.714 x 10 9 BTU/hr (NYPA 1976).

4 Because of the proximity of NMPNS (3200 ft we st of JAFNPP), the U.S. Atomic Energy 5 Commission (AEC) in its 1973 Final Environmental Statement Related to the Operation of 6 James A. FitzPatrick Nuclear Power Plant determined that under certain conditions JAFNPP 7 discharge could exceed New York State thermal criteria (AEC 1973). As such, and as a 8 condition of the plant SPDES permit, JAFNPP conducts a thermal monitoring program 9 consisting of continual discharge temperature and T recording, and has proposed mitigation 10 measures, such as flow reductions, should corrective action be needed to maintain compliance 11 with the New York State thermal criteria. To date, no additional mitigation measures have been 12 necessary. JAFNPP submits quarterly reports to NYSDEC that contain information on daily 13 electrical output, water use, and intake and discharge water temperatures (Entergy 2006a; 14 AEC 1973).

15 Heat shock to fish is a function of the temperature increase that the fish are subjected to in the 16 discharge flow area and the residence time of the fish in the heated discharge flow (Fry 1971; 17 Dean 1973). Cold shock can occur when fish acclimated to warm effluents are abruptly 18 exposed to very low ambient temperatures. This may occur during plant outages when 19 discharge flow is lower than during normal operation (NYPA 1976). According to JAFNPP 20 personnel, to date, there have been no heat or cold shock events during station operation that 21 have resulted in the immediate distress or acute mortality of fish. If such an event were 22 observed by JAFNPP personnel, the incident would have to be reported to NYSDEC as a 23 condition of the SPDES permit (Section 5b[1][iv]) (Entergy 2006a).

24 The multi-port diffuser design and offshore location of JAFNPP's discharge structure have likely 25 prevented heat and cold shock events. Analysis of the JAFNPP diffuser design in the 1976 26 NYPA 316(a) demonstration indicated that the disc harge plume (before surfacing) decreases in 27 T from 31.5°F to 13.5°F in one second and further decreases to 9°F four seconds after 28 discharge. Additionally, hydrothermal field surveys confirmed the rapid dilution of the thermal 29 effluent: the 3°F isotherm would cover a maximum surface area of 27.5 ac (1196 x 10 3 ft 2), well 30 within the maximum 35-ac mixing zone allowed in the JAFNPP SPDES permit Section 316(a) 31 variance (NYPA 1976).

32 The 316(a) demonstration study reported that voluntary exposure to the heated effluent by 33 representative fish species would not likely cause mortalities because the velocity of the 34 discharge stream would not allow fish to maintain themselves long enough in an area where the 35 discharge water temperature would be lethal. Fish behavior studies have indicated that when 36 given a range of temperatures, fish demonstrate avoidance responses to unsuitable 37 temperatures; the offshore, open area location of the JAFNPP discharge structure allows fish to 38 avoid the heated discharge stream. The design of the multi-port diffuser discharge structure 39 could entrain fish into the high-velocity discharge jet stream, but it was demonstrated that fish 40 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-24 June 2007 entrained at the point of discharge would be in safe water temperatures in less than one 1 second, making plume entrainment mortality unlikely. Regarding cold shock, acclimation to 2 elevated temperatures is a precondition for cold shock mortality. The diffuser jets at JAFNPP 3 preclude this acclimation as fish are not able to maintain themselves in the area of heated 4 discharge. Additionally, during plant outages, because of JAFNPP's proximity to NMPNS 5 (providing another source of heated discharge) and the location of the discharge structure, cold 6 shock would not be expected to impact fish in the JAFNPP vicinity (NYPA 1976).

7 The NRC staff has reviewed the available information, including that provided by the applicant, 8 visited the site, and reviewed other public sources of information on heat shock. Plant operating 9 conditions have not changed significantly since the original 316(a) demonstration, and it can 10 therefore be reasonably concluded that the extent and distribution of JAFNPP's thermal plume 11 has remained relatively unchanged. The NRC staff evaluated the potential impacts to aquatic 12 resources due to heat shock during continued operation and determined that thermal impacts 13 were unlikely because of the design and location of the JAFNPP discharge structure.

14 Furthermore, there have been no observable impacts related to plant thermal discharges.

15 Therefore, it is the NRC staff's conclusion that the potential impacts to fish and shellfish due to 16 heat shock during the renewal term are SMALL. The NRC staff identified potential mitigation 17 measures, including closed cycle cooling, helper cooling towers, derating the plant, and certain 18 operational procedures. However, the NRC staff concluded that none of the mitigation 19 measures considered would be beneficial enough to reduce the significance of heat shock 20 impacts to Lake Ontario.

21 4.2 Transmission Lines 22 The JAFNPP ER (Entergy 2006a) describes two 345-kilovolt (kV) and two 115-kV transmission 23 lines that connect JAFNPP with the transmission system (see Section 2.1.7 of this draft SEIS for 24 a description of the transmission lines). Two of the limes, the Edic and the Scriba 345-kV lines, 25 are within the scope of the license renewal review. Offsite line maintenance for both lines is 26 accomplished by the lines' owner, NYPA. For the two 345-kV transmission line right-of-ways 27 (ROWs), NYPA uses a vegetation management pl an approved by the New York State Public 28 Service Commission. NYPA uses an integrated vegetation management computer application, 29 which employs geographic information syst em technology. The vegetation management 30 program is designed to control tall-growing tree species and to enhance the abundance of lower 31 growing desirable vegetation. Field inventories are conducted annually for the ROW scheduled 32 for clearing the following year. The inventories and treatment recommendations are reviewed 33 and approved by the NYPA forestry staff. The majority of clearing is performed using 34 mechanical methods. Herbicide applications are individually applied to selected plant species 35 by licensed contractors, and a safe buffer is maintained around wetlands, and stream and river 36 crossings. A safe buffer is also used around wells and springs that are used for residential 37 water supplies. Areas where herbicides are used are posted with information regarding the 38 Environmental Impacts of Operation June 2007 4-25 Draft NUREG-1437, Supplement 31 chemicals used and when they were applied. Herbicides are not applied on NYPA ROWs using 1 aerial application methods.

2 Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, that are applicable to 3 transmission lines from JAFNPP are listed in Table 4-5. Entergy stated in the JAFNPP ER that 4 it was not aware of any new and significant information associated with the renewal of the 5 JAFNPP OL. The NRC staff has not identified any new and significant information during its 6 independent review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping 7 process, or its evaluation of other available information. Therefore, the NRC staff concludes 8 that there are no impacts related to these issues beyond those discussed in the GEIS. For all of 9 those issues, the NRC staff concluded in the GEIS that the impacts would be SMALL, and 10 additional plant-specific mitigation measures are not likely to be sufficiently beneficial to be 11 warranted.

12 Table 4-5. Category 1 Issues Applicable to the JAFNPP Transmission 13 Lines During the Renewal Term 14 ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section TERRESTRIAL R ESOURCES Power line right-of-way management (cutting and herbicide application) 4.5.6.1 Bird collisions with power lines 4.5.6.2 Impacts of electromagnetic fields on flora and fauna (plants, agricultural crops, honeybees, wildlife, livestock) 4.5.6.3 Floodplains and wetland on power line right of way 4.5.7 A IR QUALITY Air quality effects of transmission lines 4.5.2 LAND U SE Onsite land use 4.5.3 Power line right of way 4.5.3 15 A brief description of the NRC staff's review and GEIS conclusions, as codified in 10 CFR 16 Part 51, Subpart A, Appendix B, Table B-1, for each of these issues follows:

17 Power line ROW management (cutting and herbicide application). Based on information in 18 the GEIS, the Commission found that 19 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-26 June 2007 The impacts of right-of-way maintenance on wildlife are expected to be of small 1 significance at all sites.

2 The NRC staff has not identified any new and significant information during its independent 3 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 4 evaluation of other information. Therefore, the NRC staff concludes that there would be no 5 impacts of power line ROW maintenance during the renewal term beyond those discussed 6 in the GEIS.

7 Bird collisions with power lines. Based on information in the GEIS, the Commission found 8 that 9 Impacts are expected to be of small significance at all sites.

10 The NRC staff has not identified any new and significant information during its independent 11 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 12 evaluation of other information. Therefore, the NRC staff concludes that there would be no 13 impacts of bird collisions with power lines during the renewal term beyond those discussed 14 in the GEIS.

15 Impacts of electromagnetic fields on flora and fauna (plants, agricultural crops, honeybees, 16 wildlife, livestock). Based on information in the GEIS, the Commission found that 17 No significant impacts of electromagnetic fields on terrestrial flora and fauna 18 have been identified. Such effects are not expected to be a problem during the 19 license renewal term.

20 The NRC staff has not identified any new and significant information during its independent 21 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 22 evaluation of other information. Therefore, the NRC staff concludes that there would be no 23 impacts of electromagnetic fields on flora and fauna during the renewal term beyond those 24 discussed in the GEIS.

25 Floodplains and wetland on power line ROW.

Based on information in the GEIS, the 26 Commission found that 27 Periodic vegetation control is necessary in forested wetlands underneath power 28 lines and can be achieved with minimal damage to the wetland. No significant 29 impact is expected at any nuclear power plant during the license renewal term.

30 The NRC staff has not identified any new and significant information during its independent 31 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 32 evaluation of other information. Therefore, the NRC staff concludes that there would be no 33 Environmental Impacts of Operation June 2007 4-27 Draft NUREG-1437, Supplement 31 impacts of power line ROWs on floodplains and wetlands during the renewal term beyond 1 those discussed in the GEIS.

2 Air quality effects of transmission lines. Based on the information in the GEIS, the 3 Commission found that 4 Production of ozone and oxides of nitrogen is insignificant and does not 5 contribute measurably to ambient levels of these gases.

6 The NRC staff has not identified any new and significant information during its independent 7 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 8 evaluation of other information. Therefore, the NRC staff concludes that there would be no 9 air quality impacts of transmission lines during the renewal term beyond those discussed in 10 the GEIS.

11 Onsite land use. Based on the information in the GEIS, the Commission found that 12 Projected onsite land use changes required during the renewal period would be a 13 small fraction of any nuclear power plant site and would involve land that is 14 controlled by the applicant.

15 The NRC staff has not identified any new and significant information during its independent 16 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 17 evaluation of other information. Therefore, the NRC staff concludes that there would be no 18 onsite land-use impacts during the renewal term beyond those discussed in the GEIS.

19 Power line ROW.

Based on information in the GEIS, the Commission found that 20 Ongoing use of power line right of ways would continue with no change in 21 restrictions. The effects of these restrictions are of small significance.

22 The NRC staff has not identified any new and significant information during its independent 23 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 24 evaluation of other information. Therefore, the NRC staff concludes that there would be no 25 impacts of power line ROWs on land use during the renewal term beyond those discussed 26 in the GEIS.

27 One issue related to transmission lines is a Category 2 issue, and another issue related to 28 transmission lines is being treated as a Category 2 issue. These issues are listed in Table 4-6 29 and are discussed in Sections 4.2.1 and 4.2.2.

30 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-28 June 2007 Table 4-6. Category 2 and Uncategorized Issues Applicable to the 1 JAFNPP Transmission Lines During the Renewal Term 2 ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section10 CFR 51.53(c)(3)(ii) Subparagraph SEIS Section HUMAN HEALTH Electromagnetic fields-acute effects (electric shock) 4.5.4.1 H 4.2.1 Electromagnetic fields-chronic effects 4.5.4.2 NA 4.2.2 3 4.2.1 Electromagnetic Fields-Acute Effects 4 Based on the GEIS, the Commission found that electric shock resulting from direct access to 5 energized conductors or from induced charges in metallic structures has not been found to be a 6 problem at most operating plants and generally is not expected to be a problem during the 7 license renewal term. However, site-specific review is required to determine the significance of 8 the electric shock potential along the portions of the transmission lines that are within the scope 9 of this draft SEIS.

10 In the GEIS, the NRC staff found that without a review of the conformance of each nuclear plant 11 transmission line with National Electrical Safety Code (NESC) criteria, it was not possible to 12 determine the significance of the electric shock potential. Evaluation of individual plant 13 transmission lines is necessary because the issue of electric shock safety was not addressed in 14 the licensing process for some plants. For other plants, land use in the vicinity of transmission 15 lines may have changed, or power distribution companies may have chosen to upgrade line 16 voltage. To comply with 10 CFR 51.53(c)(3)(ii)(H), the applicant must provide an assessment of 17 the potential shock hazard if the transmission lines that were constructed for the specific 18 purpose of connecting the plant to the transmission system do not meet the recommendations 19 of the NESC for preventing electric shock from induced currents.

20 As described in Section 2.1.7 of this draft SEIS, two single-circuit 345-kV lines exiting the 21 switchyard connect JAFNPP to the transmission grid. One line, approximately 70 miles (mi) 22 long, connects to the transmission system at NYPA's Edic Substation. The other line, 23 approximately 4900 ft (0.9 mi) long, connects to the transmission system at the National Grid 24 Scriba Substation located on the NMPNS site. Although JAFNPP owns the lines within the site 25 property boundary, lines exiting the property boundary are owned and maintained by NYPA.

26 These two lines were evaluated concerning adherence to the NESC steady-state limit 27 (Entergy 2006a).

28 As stated above, the NESC specifies minimum vertical clearances to the ground for electric 29 lines. For electric lines operating at voltages exceeding 98-kV alternating current (AC) to 30 Environmental Impacts of Operation June 2007 4-29 Draft NUREG-1437, Supplement 31 ground, the clearance provided must limit the steady-state current due to electrostatic effects to 1 5 milliamperes (mA) if the largest anticipated vehicle were short-circuited to ground. The largest 2 vehicle anticipated under JAFNPP's 345-kV lines is a tractor-trailer that is 65 ft long and13.5 ft 3 tall, parked along a roadway. The 5-mA design standard limits electric fields within the ROW to 4 7 to 8 kV/meter (Entergy 2006a).

5 According to the NYPA Transmission Engineering Department, the two 345-kV transmission 6 lines at JAFNPP are operated and maintained in a manner consistent with the design criteria 7 listed in the GEIS, Section 4.5.4.1. Specifically, these lines meet a more stringent induced 8 shock standard than the 5-mA design criterion of NESC (1981). The State of New York Public 9 Service Commission (NYPSC) requires that transmi ssion lines in New York be designed so that 10 the short-circuit current to ground, produced from the largest anticipated vehicle or object, is 11 limited to less than 4.5 mA. This allows no more than 7.0 kV/meter electric field levels on the 12 ROWs. In 1991, NYPA demonstrated to the NYPSC that its transmission lines, including the 13 two 345-kV lines associated with JAFNPP, do not exceed safety levels of 6.5 kV/meter for 14 electric fields or 4.5 mA for induced shocks (Entergy 2006a).

15 Nuisance shocks are further controlled through NYPA's annual routine inspection of ROWs for 16 land intrusion, along with its program of informing landowners about induced shock hazards and 17 assisting them with grounding any metallic structures in or near a ROW.

18 Entergy's assessment concluded that electric shock is of SMALL significance for the JAFNPP 19 345-kV transmission lines (Entergy 2006a). The lines are operated within their original design 20 specifications, the ROWs are routinely monitored for any land-use changes, and NYPA has 21 demonstrated that the 345-kV transmission lines meet the NESC (1981) requirements for 22 preventing induced shock hazards. Due to the small significance of the issue, mitigation 23 measures such as installing warning signs at road crossings or increasing clearances are not 24 warranted.

25 Based on a review of the available information, including that provided by the applicant (Entergy 26 2006a), the NRC staff's site audit, the scoping process, and an evaluation of other information, 27 the staff concludes that the potential impacts for electric shock during the renewal term are 28 SMALL. The NRC staff identified potential mitigation measures, including installing road signs 29 at road crossings and increased clearances. However, the NRC staff concluded that none of 30 the mitigation measures considered would be beneficial enough to reduce the significance of 31 the adverse impacts to people.

32 4.2.2 Electromagnetic Fields-Chronic Effects 33 In the GEIS, the chronic effects of 60-Hz electromagnetic fields from power lines are not 34 designated as Category 1 or 2 and will not be until a scientific consensus is reached on the 35 health implications of these fields.

36 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-30 June 2007 The potential for chronic effects from these fields continues to be studied and is not known at 1 this time. The National Institute of Environmental Health Sciences (NIEHS) directs related 2 research through the U.S. Department of Energy (DOE). An NIEHS report (NIEHS 1999) 3 contains the following conclusion:

4 The NIEHS concludes that ELF-EMF (extremely low frequency-electromagnetic field) 5 exposure cannot be recognized as entirely safe because of weak scientific evidence that 6 exposure may pose a leukemia hazard. In our opinion, this finding is insufficient to warrant 7 aggressive regulatory concern. However, because virtually everyone in the United States 8 uses electricity and therefore is routinely exposed to ELF-EMF, passive regulatory action is 9 warranted such as a continued emphasis on educating both the public and the regulated 10 community on means aimed at reducing exposur es. The NIEHS does not believe that other 11 cancers or non-cancer health outcomes provide sufficient evidence of a risk to currently 12 warrant concern.

13 This statement is not sufficient to cause the NRC staff to change its position with respect to the 14 chronic effects of electromagnetic fields. Footnote 4 to Table B-1 of 10 CFR Part 51, Subpart A, 15 Appendix B, states 16 If in the future, the Commission finds that, contrary to current indications, a consensus has 17 been reached by appropriate Federal health agencies that there are adverse health effects 18 from electromagnetic fields, the Commission will require applicants to submit plant-specific 19 reviews of those health effects as part of their license renewal applications. Until such time, 20 applicants for license renewal are not required to submit information on this issue.

21 The NRC staff considers the GEIS finding of "Uncertain" still appropriate and will continue to 22 follow developments on this issue.

23 4.3 Radiological Impacts of Normal Operations 24 Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, that are applicable to 25 JAFNPP in regard to radiological impacts are listed in Table 4-7. Entergy stated in its ER 26 (Entergy 2006a) that it is not aware of any new and significant information associated with the 27 renewal of the JAFNPP OL. The NRC staff has not identified any new and significant 28 information during its independent review of the JAFNPP ER, the staff's site audit, the scoping 29 process, or its evaluation of other available information. Therefore, the NRC staff concludes 30 that there are no impacts related to these issues beyond those discussed in the GEIS. For 31 these issues, the NRC staff concluded in the GEIS that the impacts are SMALL, and additional 32 plant-specific mitigation measures are not likely to be sufficiently beneficial to be warranted.

33 Environmental Impacts of Operation June 2007 4-31 Draft NUREG-1437, Supplement 31 Table 4-7. Category 1 Issues Applicable to Radiological Impacts 1 of Normal Operations During the Renewal Term 2 ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section HUMAN HEALTH Radiation exposures to public (license renewal term) 4.6.2 Occupational radiation exposures (license renewal term) 4.6.3 3 A brief description of the NRC staff's review and the GEIS conclusions, as codified in 10 CFR 4 Part 51, Subpart A, Appendix B, Table B-1, for each of these issues follows:

5 Radiation exposures to public (license renewal term).

Based on information in the GEIS, the 6 Commission found that 7 Radiation doses to the public will continue at current levels associated with 8 normal operations.

9 The NRC staff has not identified any new and significant information during its independent 10 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 11 evaluation of other available information.

Therefore, the NRC staff concludes that there 12 would be no impacts of radiation exposures to the public during the renewal term beyond 13 those discussed in the GEIS.

14 Occupational radiation exposures (license renewal term). Based on information in the 15 GEIS, the Commission found that 16 Projected maximum occupational doses during the license renewal term are 17 within the range of doses experienced during normal operations and normal 18 maintenance outages, and would be well below regulatory limits.

19 The NRC staff has not identified any new and significant information during its independent 20 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 21 evaluation of other available information.

Therefore, the NRC staff concludes that there 22 would be no impacts of occupational radiation exposures during the renewal term beyond 23 those discussed in the GEIS.

24 There are no Category 2 issues related to radiological impacts of routine operations.

25 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-32 June 2007 4.4 Socioeconomic Impacts of Plant Operations During the License Renewal Term 1 Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, that are applicable to 2 socioeconomic impacts during the renewal term are listed in Table 4-8. JAFNPP stated in its 3 ER (Entergy 2006a) that it is not aware of any new and significant information associated with 4 the renewal of the JAFNPP OL. The NRC staff has not identified any new and significant 5 information during its independent review of the JAFNPP ER, the staff's site audit, the scoping 6 process, or its evaluation of other available information. Therefore, the NRC staff concludes 7 that there are no impacts related to these issues beyond those discussed in the GEIS. For 8 these issues, the NRC staff concluded in the GEIS that the impacts are SMALL, and additional 9 plant-specific mitigation measures are not likely to be sufficiently beneficial to be warranted.

10 Table 4-8. Category 1 Issues Applicable to Socioeconomics During the Renewal Term 11 ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section SOCIOECONOMICS Public services: public safety, social services, and tourism and recreation 4.7.3; 4.7.3.3; 4.7.3.4; 4.7.3.6 Public services: education (license renewal term) 4.7.3.1 Aesthetic impacts (license renewal term) 4.7.6 Aesthetic impacts of transmission lines (license renewal term) 4.5.8 12 A brief description of the NRC staff's review and the GEIS conclusions, as codified in Table B-1 13 of 10 CFR Part 51, Subpart A, Appendix B, for each of these issues follows:

14 Public services: public safety, social services, and tourism and recreation.

Based on 15 information in the GEIS, the Commission found that 16 Impacts to public safety, social services, and tourism and recreation are expected to be of small significance at all sites. The NRC staff has not identified any new and significant information during its independent 17 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 18 evaluation of other available information.

Therefore, the NRC staff concludes that there 19 would be no impacts on public safety, social services, and tourism and recreation during the 20 renewal term beyond those discussed in the GEIS.

21 Environmental Impacts of Operation June 2007 4-33 Draft NUREG-1437, Supplement 31 Public services: education (license renewal term).

Based on information in the GEIS, the 1 Commission found that 2 Only impacts of small significance are expected. The NRC staff has not identified any new and significant information during its independent 3 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 4 evaluation of other available information.

Therefore, the NRC staff concludes that there 5 would be no impacts on education during the renewal term beyond those discussed in the 6 GEIS. 7 Aesthetic impacts (license renewal term).

Based on information in the GEIS, the 8 Commission found that 9 No significant impacts are expected during the license renewal term. The NRC staff has not identified any new and significant information during its independent 10 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 11 evaluation of other available information.

Therefore, the NRC staff concludes that there 12 would be no aesthetic impacts during the renewal term beyond those discussed in the GEIS.

13 Aesthetic impacts of transmission lines (license renewal term). Based on information in the 14 GEIS, the Commission found that 15 No significant impacts are expected during the license renewal term. The NRC staff has not identified any new and significant information during its independent 16 review of the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its 17 evaluation of other available information.

Therefore, the NRC staff concludes that there 18 would be no aesthetic impacts of transmission lines during the renewal term beyond those 19 discussed in the GEIS.

20 Table 4-9 lists the Category 2 socioeconomic issues, which require plant-specific analysis, and 21 environmental justice, which was not addressed in the GEIS.

22 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-34 June 2007 Table 4-9. Category 2 Issues Applicable to Socioeconomics 1 and Environmental Justice During the Renewal Term 2 ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section 10 CFR 51.53(c)(3)(ii) Subparagraph SEIS Section SOCIOECONOMICS Housing impacts 4.7.1 I 4.4.1 Public services: public utilities 4.7.3.5 I 4.4.2 Offsite land use (license renewal term) 4.7.4 I 4.4.3 Public services: transportation 4.7.3.2 J 4.4.4 Historic and archaeological resources 4.7.7 K 4.4.5 Environmental justice Not addressed (a)Not addressed (a) 4.4.6 (a) Guidance related to environmental justice was not in place at the time the GEIS and the associated revision to 10 CFR Part 51 were prepared. Therefore, environmental justice must be addressed in the NRC staff's environmental impact statement.

3 4.4.1 Housing Impacts 4 In determining housing impacts, the applicant chose to follow Appendix C of the GEIS, which 5 presents a population characterization method that is based on two factors, sparseness and 6 proximity (GEIS, Section C.1.4). Sparseness measures population density within 20 mi of the 7 site, and proximity measures population density and city size within 50 mi. Each factor has 8 categories of density and size (GEIS, Table C.1). A matrix is used to rank the population 9 category as low, medium, or high (GEIS, Figure C.1).

10 In 2000, approximately 109,440 persons lived within a 20-mi radius of JAFNPP (Entergy 11 2006a), which equates to a population density of 87 persons per square mile (mi 2). This density 12 translates to Category 3 (60 to 120 persons per mi 2 or fewer than 60 persons per mi 2 with at 13 least one community of 25,000 or more persons within 20 mi) using the GEIS sparseness factor.

14 At the same time, there were approximately 914,668 persons living within a 50-mi radius of the 15 plant, for a density of 117 persons per mi

2. The Syracuse MSA, located within 50 mi of the site, 16 had a total population in 2000 of 732,117. Therefore, JAFNPP falls into Category 3 (one or 17 more cities with 100,000 or more persons and fewer than 190 persons per mi 2 within 50 mi) 18 using the GEIS proximity factor. A Category 3 value indicates that JAFNPP is in a medium-19 density population area (NRC 2006a).

20 Environmental Impacts of Operation June 2007 4-35 Draft NUREG-1437, Supplement 31 Refurbishment activities and continued operations could result in housing impacts due to 1 increased staffing. However, there are no major refurbishment activities required for JAFNPP 2 license renewal. Therefore, there would be no refurbishment-related impacts to area housing.

3 Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, states that impacts on housing availability 4 are expected to be of small significance at plants located in a medium-density population area 5 where growth-control measures are not in effect. Oswego County is not subject to growth-6 control measures that would limit housing development, and Entergy does not anticipate a need 7 for additional full-time workers during the license renewal period.

8 Since Entergy has no plans to add employees to support plant operations during the license 9 renewal period, there would be no increase in demand for housing in the vicinity of the JAFNPP 10 site. Therefore, there would be no housing impacts during the license renewal period and no 11 mitigation would be required.

12 4.4.2 Public Services: Public Utility Impacts 13 Impacts on public utility services are considered SMALL if there is little or no change in the 14 ability of the system to respond to demand and thus there is no need to add capital facilities.

15 Impacts are considered MODERATE if service capabilities are overtaxed during periods of peak 16 demand. Impacts are considered LARGE if services (e.g., water, sewer) are substantially 17 degraded and additional capacity is needed to meet ongoing demand. The GEIS indicates that, 18 in the absence of new and significant information to the contrary, the only impacts on public 19 utilities that could be significant are impacts on public water supplies.

20 Analysis of impacts on the public water s upply system considered both plant demand and plant-21 related population growth. Section 2.1.8.1 of this draft SEIS describes the JAFNPP permitted 22 withdrawal rate and actual use of water. The Oswego Water System (OWS) provides potable 23 water to JAFNPP (OCDPCD 1997). Current plant usage averages 137,500 gpd with no 24 restrictions on supply. The OWS serves approximately 23,950 customers in the Oswego, 25 Minetta, Scriba, and Volney. The water plant obtains its water from Lake Ontario and has an 26 allowable withdrawal allocation of approximately 62.5 million gpd. The full design capacity of 27 the water plant is 20.1 million gpd, although 8 million gpd is reserved for Sithe Energies, Inc., 28 with the remaining 12 million gpd available for other industrial, residential, and commercial 29 customers. In 2001, consumptive daily demand averaged 8 million gpd, and peak demand was 30 approximately 10 million gpd (NRC 2006a).

31 Since Entergy has no plans to add employees to support plant operations during the license 32 renewal period, there would be no increase in demand for public water. Therefore, there would 33 be no impacts to public water supply during the license renewal period and no mitigation would 34 be required.

35 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-36 June 2007 4.4.3 Offsite Land Use 1 Offsite land use during the license renewal term is a Category 2 issue (10 CFR 51, Subpart A, 2 Appendix B, Table B-1). Table B-1 of 10 CFR 51 Subpart A, Appendix B notes that "significant 3 changes in land use may be associated with population and tax revenue changes resulting from 4 license renewal." 5 Section 4.7.4 of the GEIS defines the magnitude of land-use changes as a result of plant 6 operation during the license renewal term as follows:

7 SMALL - Little new development and minimal changes to an area's land-use pattern.

8 MODERATE - Considerable new development and some changes to the land-use pattern.

9 LARGE - Large-scale new development and major changes in the land-use pattern.

10 Tax revenue can affect land use because it enables local jurisdictions to provide the public 11 services (e.g., transportation and utilities) necessary to support development. Section 4.7.4.1 of 12 the GEIS states that the assessment of tax-driven land-use impacts during the license renewal 13 term should consider (1) the size of the plant's payments relative to the community's total 14 revenues, (2) the nature of the community's existing land-use pattern, and (3) the extent to 15 which the community already has public services in place to support and guide development. If 16 the plant's tax payments are projected to be small relative to the community's total revenue, tax-17 driven land-use changes during the plant's license renewal term would be SMALL, especially 18 where the community has pre-established patterns of development and has provided adequate 19 public services to support and guide development. Section 4.7.2.1 of the GEIS states that if tax 20 payments by the plant owner are less than 10 percent of the taxing jurisdiction's revenue, the 21 significance level would be SMALL. If the plant's tax payments are projected to be medium to 22 large relative to the community's total revenue, new tax-driven land-use changes would be 23 MODERATE. If the plant's tax payments are projected to be a dominant source of the 24 community's total revenue, new tax-driven land-use changes would be LARGE. This would be 25 especially true where the community has no pre-established pattern of development or has not 26 provided adequate public services to support and guide development.

27 4.4.3.1 Population-Related Impacts 28 Since Entergy has no plans to add employees to support plant operations during the license 29 renewal period; there would be no change in land use conditions in the vicinity of the JAFNPP 30 site. Therefore, there would be no population-related land use impacts during the license 31 renewal period and no mitigation would be required.

32 Environmental Impacts of Operation June 2007 4-37 Draft NUREG-1437, Supplement 31 4.4.3.2 Tax-Revenue-Related Impacts 1 JAFNPP is assessed annual property taxes by Oswego County, the Town of Scriba, and Mexico 2 Central Schools. Property taxes paid to Oswego County and the Town of Scriba fund such 3 services as transportation, education, public health, and public safety.

4 Entergy has entered into an agreement with Oswego County, the Town of Scriba, and the 5 Mexico Central Schools regarding property taxes paid to those entities for JAFNPP. The 6 agreement stipulates that Entergy, instead of paying property taxes for JAFNPP based on the 7 assessed value of the plant, will make standardized annual payments in lieu of taxes to the 8 taxing entities.

9 Since Entergy has indicated that there would be no major plant refurbishment or license 10 renewal-related construction activities necessary to support the continued operation of the 11 JAFNPP beyond the end of the existing operating license term during the license renewal 12 period, there would be no increase in the assessed value of JAFNPP and annual payments to 13 the Town of Scriba, the Mexico Central Schools, and Oswego County would remain constant 14 throughout the license renewal period. Based on this information, there would be no tax 15 revenue-related land-use impacts during the license-renewal period and no mitigation would be 16 required.

17 4.4.4 Public Services: Transportation Impacts 18 Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, states 19 Transportation impacts (level of service) of highway traffic generated during the term of the 20 renewed license are generally expected to be of small significance. However, the increase 21 in traffic associated with additional workers and the local road and traffic control conditions 22 may lead to impacts of moderate or large significance at some sites.

23 All applicants are required by 10 CFR 51.53(c)(3)(ii)(J) to assess the impacts of highway traffic 24 generated by the proposed project on the level of service of local highways during the term of 25 the renewed license.

26 Since Entergy has no plans to add employees to support plant operations during the license 27 renewal period, there would be no change in traffi c volume and levels of service on roadways in 28 the vicinity of the JAFNPP site. Therefore, there would be no transportation impacts during the 29 license renewal period and no mitigation would be required.

30 4.4.5 Historic and Archaeological Resources 31 The National Historic Preservation Act of 1966 (NHPA), as amended, requires Federal agencies 32 to take into account the potential effects of their undertakings on historic properties. The 33 historic-review process mandated by Section 106 of the NHPA is outlined in regulations issued 34 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-38 June 2007 by the Advisory Council on Historic Preservation in 36 CFR Part 800. The renewal of an OL for 1 a nuclear power plant is an undertaking that could possibly affect either known or potential 2 historic properties that may be located on or near the plant site. In accordance with the 3 provisions of the NHPA, the NRC is required to make a reasonable effort to identify historic 4 properties in the areas of potential effect. If no historic properties are present or affected, the 5 NRC is required to notify the State Historic Preservation Office (SHPO) before proceeding. If it 6 is determined that historic properties are present, the NRC is required to assess and resolve 7 possible adverse effects of the undertaking.

8 As discussed in Section 2.2.9.2 of this draft SEIS, Entergy contacted the New York State Office 9 of Parks, Recreation, and Historic Preservation (NYSHPO) on February 9, 2006, regarding 10 preparation of its application for the license renewal of JAFNPP (Entergy 2006a). In 11 accordance with 36 CFR 800.8(c), the NRC contac ted the NYSHPO (NRC 2006b), the Advisory 12 Council on Historic Preservation (NRC 2006c), and the appropriate Federally recognized Native 13 American Tribes with current and historical ties to the region on September 15, 2006.

14 On December 4, 2006, NRC staff conducted a search of the NYSHPO files for the region 15 around JAFNPP. Although no prehistoric or historic archaeological sites have been recorded on 16 the JAFNPP property or along the associated transmission line corridors, literature reviews, 17 surveys, and sensitivity assessments of the JAFNPP site demonstrate there is a potential for 18 historic and archaeological resources on undisturbed portions of the site. The potential exists 19 for prehistoric sites to be found in and around the kettle ponds and associated wetland areas.

20 Early maps of the JAFNPP site indicate that a number of structures, most from the nineteenth 21 century, existed on the JAFNPP site prior to construction.

Most of these structures today 22 consist of foundations and have probable associated historic artifact scatters. Prehistoric 23 cultural resources could also be present in the relatively undisturbed southern and eastern 24 portions of the JAFNPP site next to kettle ponds. A walk-over of selected undeveloped portions 25 of the JAFNPP site by NRC staff confirmed the existence of historic resources on the plant site.

26 Camp Oswego (also known as Camp Drum Anti-Aircraft Artillery Firing Range) was established 27 during World War II immediately west of JAFNPP on property that is now occupied by Nine Mile 28 Point Nuclear Station (USGS 1955). The camp operated well into the 1950s as a summer 29 training base and closed sometime after 1956. The Niagara-Mohawk Electric Company later 30 purchased the land for construction of the Nine Mile Point Nuclear Station.

31 Continued operations at JAFNPP during the renewal term would likely protect any 32 archaeological sites present within the JAFNPP site boundary by protecting the site from 33 development and providing secured access. However, because there is the potential for 34 cultural resources to be present at the site, the applicant should take care during normal 35 operations and maintenance activities related to operations not to inadvertently affect cultural 36 resources. To avoid such adverse impacts, environmental review procedures have been put in 37 place at JAFNPP regarding undertakings that involve land-disturbing construction or operational 38 activities in undisturbed areas. Entergy has no plans to alter current operations during the 39 Environmental Impacts of Operation June 2007 4-39 Draft NUREG-1437, Supplement 31 license renewal period. Additionally, Entergy states that any maintenance activities necessary 1 to support license renewal would be limited to previously disturbed areas onsite. There is no 2 planned expansion of the existing facilities and there are no planned refurbishment activities to 3 support license renewal (Entergy 2006a).

4 Based on the NRC staff's review of NYSHPO files, archaeological reviews, surveys, 5 assessments, and other information, the NRC st aff concludes that the potential impacts on 6 historic and archaeological resources during the license renewal term would be SMALL. This 7 conclusion is based on the following: (1) no new ground disturbance or refurbishment activities 8 would occur during the renewal period, (2) the applicant understands that archaeological and 9 historic resources could be present at the JAFNPP site, and (3) the applicant has administrative 10 controls in place to ensure that if cultural resources are found at JAFNPP, they will be protected.

11 The NRC staff has determined that the impact of license renewal on historic and archaeological 12 resources would be SMALL, and additional mitigation is not warranted.

13 4.4.6 Environmental Justice 14 Under Executive Order 12898 (59 FR 7629), Federal agencies are responsible for identifying 15 and addressing potential disproportionately high and adverse human health and environmental 16 impacts on minority and low-income populations. Although the Executive Order is not 17 mandatory for independent agencies such as the NRC, the NRC has voluntarily committed to 18 undertake environmental justice reviews. In 2004, the Commission issued a Policy Statement 19 on the Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions 20 (NRC 2004).

21 The Council of Environmental Quality (CEQ) provides the following information in Environmental 22 Justice: Guidance Under the National Environmental Policy Act (1997): 23 Disproportionately High and Adverse Human Health Effects. Adverse health effects are 24 measured in risks and rates that could result in latent cancer fatalities, as well as other fatal 25 or nonfatal adverse impacts on human health. Adverse health effects may include bodily 26 impairment, infirmity, illness, or death. Disproportionately high and adverse human health 27 effects occur when the risk or rate of exposure to an environmental hazard for a minority or 28 low-income population is significant (as defined by NEPA [National Environmental Policy 29 Act]) and appreciably exceeds the risk or exposure rate for the general population or for 30 another appropriate comparison group (CEQ 1997).

31 Disproportionately High and Adverse Environmental Effects. A disproportionately high 32 environmental impact that is significant (as defined by NEPA) refers to an impact or risk of 33 an impact on the natural or physical environment in a low-income or minority community that 34 appreciably exceeds the environmental impact on the larger community. Such effects may 35 include ecological, cultural, human health, economic, or social impacts. An adverse 36 environmental impact is an impact that is determined to be both harmful and significant (as 37 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-40 June 2007 defined by NEPA). In assessing cultural and aesthetic environmental impacts, impacts that 1 uniquely affect geographically dislocated or dispersed minority or low-income populations or 2 American Indian tribes are considered (CEQ 1997).

3 The environmental justice analysis assesses the potential for disproportionately high and 4 adverse human health or environmental effects on minority and low-income populations that 5 could result from the operation of JAFNPP during the renewal term. In assessing the impacts, 6 the following CEQ (1997) definitions of minority individuals and populations and low-income 7 population were used:

8 Minority individuals.

Individuals who identify themselves as members of the following 9 population groups: Hispanic or Latino, American Indian or Alaska Native, Asian, Black or 10 African American, Native Hawaiian or Other Pacific Islander, or two or more races meaning 11 individuals who identified themselves on a Census form as being a member of two or more 12 races, for example, Hispanic and Asian.

13 Minority populations.

Minority populations are identified when (1) the minority population of 14 an affected area exceeds 50 percent or (2) the minority population percentage of the 15 affected area is meaningfully greater than the minority population percentage in the general 16 population or other appropriate unit of geographic analysis.

17 Low-income population.

Low-income populations in an affected area are identified with the 18 annual statistical poverty thresholds from the Census Bureau's Current Population Reports, 19 Series PB60, on Income and Poverty.

20 4.4.6.1 Minority Population in 2000 21 According to 2000 census data, 11.5 percent of the population (approximately 109,350 22 individuals) residing with a 50-mi radius of JAFNPP were minority individuals. The largest 23 minority group was Black or African American (57,308 or 6 percent), followed by Hispanic or 24 Latino (10,034 or about 1 percent). About 3.5 percent of Oswego County were minorities, with 25 Hispanics the largest minority group (1.3 percent). Hispanics resided throughout the 50-mi 26 radius, but most were in Jefferson County (USCB 2006).

27 Census block groups with minority populations exceeding 20 percent were considered minority 28 block groups. Based on 2000 census data, Figure 4-1 shows minority block groups within a 29 50-mi radius of JAFNPP in which more than 20 percent of the block group population is minority 30 (USCB 2006).

31 4.4.6.2 Low-Income Population in 2000 32 According to 2000 census data, approximately 45,007 individuals (approximately 4.7 percent) 33 residing within a 50-mi radius of JAFNPP were identified as living below the Federal poverty 34 threshold. The 1999 Federal poverty threshold was $17,029 for a family of four. The median 35 Environmental Impacts of Operation June 2007 4-41 Draft NUREG-1437, Supplement 31 1 Figure 4-1. Minority Block Groups in 2000 within a 50-mi Radius of JAFNPP (USCB 2006).

2 3 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-42 June 2007 household income for New York in 1999 was $43,393, while 14.6 percent of the state population 1 was determined to be living below the 1999 Federal poverty threshold.

2 Oswego County had one of the lowest median incomes ($36,598) and the highest percentage 3 (14 percent) of individuals living below the poverty level when compared to the other counties in 4 the area. Conversely, Onondaga County had one of the highest median incomes ($40,847) and 5 the lowest percentage (7.3 percent) of individuals living below the poverty level when compared 6 to other counties in the area.

7 Census block groups were considered low-income block groups if the percentage of the 8 population living below the Federal poverty threshold exceeded 14 percent. Based on 2000 9 Census data, Figure 4-2 shows low-income block groups within a 50-mi radius of JAFNPP 10 (USCB 2006).

11 4.4.6.3 Analysis of Impacts 12 Consistent with the impact analysis for the public and occupational health and safety, the 13 affected populations are defined as minority and low-income populations who reside within a 14 50-mi radius of JAFNPP. Based on the analysis of impacts for other resource areas, NRC 15 expects no high and adverse impacts from the operation of JAFNPP during the renewal term.

16 However, if impacts occur, NRC expects the impacts to affect all populations in the area equally.

17 NRC also analyzed the risk of radiological ex posure through the consumption patterns of 18 special pathway receptors, including subsistence consumption of fish, native vegetation, surface 19 waters, sediments, and local produce; absorption of contaminants in sediments through the 20 skin; and inhalation of plant materials. The special pathway receptors analysis is important to 21 the environmental justice analysis because consumption patterns may reflect the traditional or 22 cultural practices of minority and low-income populations in the area.

23 Subsistence Consumption of Fish and Wildlife 24 Section 4-4 of Executive Order 12898 (1994) directs Federal agencies, whenever practical and 25 appropriate, to collect and analyze information on the consumption patterns of populations who 26 rely principally on fish and/or wildlife for subsistence and to communicate the risks of these 27 consumption patterns to the public. In Section 2.2.8.5 of this draft SEIS, NRC considered 28 whether there were any means for minority or low-income populations to be disproportionately 29 affected by examining impacts to American Indian, Hispanic, and other traditional lifestyle 30 special pathway receptors. Special pathways that took into account the levels of contaminants 31 in native vegetation, crops, soils and sediments, surface water, fish, and game animals on or 32 near the JAFNPP site were considered.

33 Entergy has a comprehensive Radiological Environmental Monitoring Program (REMP) at 34 JAFNPP to assess the impact of site operations on the environment. Samples are collected 35 from the aquatic and terrestrial pathways applicable to the site. The aquatic pathways include 36 Environmental Impacts of Operation June 2007 4-43 Draft NUREG-1437, Supplement 31 1 Figure 4-2. Low-Income Block Groups within a 50-mi Radius of JAFNPP (USCB 2006).

2 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-44 June 2007 Lake Ontario fish, surface waters and lakeshore sediment. The terrestrial pathways include 1 airborne particulates and radioiodine, milk, food products and direct radiation. During 2005, 2 2318 analyses were performed on collected samples of environmental media as part of the 3 required REMP and showed no significant or measurable radiological impact from JAFNPP 4 operations. Cesium-137 was detected in one aquatic sample (shoreline sediment) at very low 5 levels and was attributed to fallout from past weapons testing. The 2005 results for all samples 6 are consistent with the previous five-year historical results and exhibit no adverse trends 7 (Entergy 2005).

8 The results of the 2005 REMP demonstrate that the routine operation at the JAFNPP site had 9 no significant or measurable radiological impact on the environment. No elevated radiation 10 levels were detected in the offsite environment as a result of the hydrogen injection program, 11 storage of radioactive waste, or implementation of the Independent Spent Fuel Storage 12 Installation. The results of the REMP continue to demonstrate that the operation of the plant did 13 not result in a significant measurable dose to a member of the general population or adversely 14 impact the environment as a result of radiological effluents (Entergy 2005). REMP continues to 15 demonstrate that the dose to a member of the public from the operation of JANFPP remains 16 significantly below the federally required dose limits specified in 10 CFR Part 20, 40 CFR Part 190, 17 and 10 CFR Part 72.

18 Based on recent monitoring results, concentrations of contaminants in native vegetation, crops, 19 soils and sediments, surface water, fish, and game animals in areas surrounding JAFNPP have 20 been quite low (at or near the threshold of detection) and seldom above background levels 21 (Entergy 2005). Consequently, no disproportionately high and adverse human health impacts 22 would be expected in special pathway receptor populations in the region as a result of 23 subsistence consumption of fish and wildlife.

24 4.5 Groundwater Use and Quality 25 No Category 1 or Category 2 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, are 26 potentially applicable to JAFNPP groundwater use and quality during the renewal term. The 27 NRC staff has not identified any new and significant information during its independent review of 28 the JAFNPP ER (Entergy 2006a), the staff's site audit, the scoping process, or its evaluation of 29 other available information. Therefore, the NRC staff concludes that there are no impacts 30 related to these issues beyond those discussed in the GEIS.

31 4.6 Threatened or Endangered Species 32 Threatened or endangered species are listed as a Category 2 issue in 10 CFR Part 51, 33 Subpart A, Appendix B, Table B-1. This issue is listed in Table 4-10.

34 Environmental Impacts of Operation June 2007 4-45 Draft NUREG-1437, Supplement 31 Table 4-10. Category 2 Issue Applicable to Threatened 1 or Endangered Species During the Renewal Term 2 ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section 10 CFR 51.53(c)(3)(ii) Subparagraph SEIS Section THREATENED OR ENDANGERED S PECIES (FOR ALL PLANTS) Threatened or endangered species 4.1 E 4.6 3 Entergy contacted the U.S. Fish and Wildlife Service (FWS) on February 9, 2006, regarding 4 threatened and endangered species at the JAFNPP site (Entergy 2006a). No information 5 regarding the transmission lines was provided in this letter. In its response letter to Entergy, 6 dated May 19, 2006, the FWS (Entergy 2006a) identified the Federally and State-listed Indiana 7 bat (Myotis sodalis) and the Federally and State-listed bog turtle (Clemmys muhlenbergii) as 8 potentially occurring within the transmission corridor. The Indiana bat is known to roost within 9 11 mi of the site, and the bog turtle is known to occur within 12 mi of the site. The bog turtle 10 was also identified in the JAFNPP Final Environmental Statement (FES) for operation as 11 probably occurring within the marshes that are crossed by JAFNPP to the Edic transmission line 12 (AEC 1973).

13 On December 7, 2006, NRC staff met with New York Natural Heritage Program (NYNHP) to 14 discuss potential impacts of continued operation on State-listed species. The NYNHP found 15 that upland sandpiper (Bartramia longicauda) habitat has been identified near the JAFNPP-to-16 Edic transmission line corridor. No other State-listed species are known to occur near the 17 JAFNPP facility or transmission corridors. The NYNHP staff have not identified any significant 18 foreseeable impacts on State-protected species or areas that would result from continued 19 operation or maintenance activities during the renewal term.

20 The NRC staff met with the New York Power Authority (NYPA) on December 4, 2006. At this 21 meeting, the NRC staff was informed that no threatened or endangered species have been 22 reported by maintenance personnel as occurring in or near the transmission corridor. Corridor 23 maintenance personnel are trained in identifying endangered species and are expected to take 24 measures to avoid damage to these species if they are identified within the transmission line 25 corridor during the renewal period.

26 This Category 2 issue requires consultation with appropriate agencies to determine whether 27 threatened or endangered species are present and whet her they would be adversely affected by 28 continued operation of JAFNPP during the license renewal term. The characteristics and 29 habitat of threatened or endangered species in the vicinity of the JAFNPP site are discussed in 30 Sections 2.2.5 and 2.2.6 of this draft SEIS. The NRC initiated informal consultation with the 31 FWS on September 19, 2006, to determine which species may be affected by continued 32 operations and maintenance procedures at the JAFNPP site and the associated transmission 33 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-46 June 2007 lines (NRC 2006d). NRC submitted a Biological Asse ssment to the FWS, thus consultation with 1 the FWS in ongoing (NRC 2007).

2 4.6.1 Aquatic Species 3 No Federally listed or proposed threatened or endangered aquatic species, with the exception 4 of transient individuals, are known to exist in the vicinity of JAFNPP or the aquatic habitats 5 crossed by the transmission lines associated with JAFNPP (FWS 2007). There are no plans to 6 conduct refurbishment or construction activities at JAFNPP during the license renewal term 7 (Entergy 2006a). The NRC staff's conclusion is that there would be no impacts on threatened 8 and endangered aquatic species from operation of JAFNPP during the renewal term, and 9 mitigation is therefore not warranted.

10 4.6.2 Terrestrial Species 11 Currently, no threatened or endangered species are known as occurring at the JAFNPP site or 12 within the Edic or Scriba transmission corridors. The State-protected upland sandpiper is 13 known to occur near the transmission corridor, but no impacts to this species are expected as a 14 result of continued use or maintenance of the lines. The Federally protected bog turtle and 15 Indiana bat have the potential to occur at the JAFNPP site.

16 The NRC staff encourages NYPA to report the existence of any Federally or State-listed 17 endangered species within or near the transmission corridors to NYSDEC and/or FWS if any 18 such species are identified during the renewal term. If any evidence of injury or mortality of 19 migratory birds or threatened or endangered species is seen within the corridor during the 20 renewal period, NYPA is encouraged to promptly report this to the appropriate wildlife 21 management agencies. Care should also be taken to ensure that the corridor does not provide 22 a path for invasive plant species to colonize wetland areas that would not otherwise be 23 colonized without the corridor. In particular, common reed (Phragmites australis) may colonize 24 and degrade undocumented bog turtle habitat (FWS 2001). Likewise, transmission corridor 25 maintenance activities should be conducted in a manner that avoids damage to wetlands within 26 and near the corridor. Maintenance personnel should be aware of the foraging and roosting 27 needs of Indiana bats, and the removal of standing dead trees and trees harboring Indiana bats 28 should be avoided during times of the year when bats may be present.

29 The NRC staff, after discussions with the FWS, finds that the Indiana bat and the bog turtle may 30 be present on the JAFNPP site or along the Edic and Scriba transmission corridors. The NRC 31 staff has determined that the continued operation of the JAFNPP may affect, but is not likely to 32 adversely affect, either species. Therefore, the NRC staff's preliminary conclusion is that the 33 potential impacts on Federally protected specie s of an additional 20 years of JAFNPP operation 34 would be SMALL. The NRC staff has initiated informal Section 7 consultation under the 35 Endangered Species Act of 1972 with the FWS for both the Indiana bat and the bog turtle. The 36 Environmental Impacts of Operation June 2007 4-47 Draft NUREG-1437, Supplement 31 consultation is ongoing and may result in additional requirements to ensure protection of these 1 two species.

2 4.7 Evaluation of New and Potentially Significant Information on Impacts of 3 Operations During the Renewal Term 4 The NRC staff has not identified new and significant information on environmental issues listed 5 in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, related to plant operation during the 6 renewal term. The NRC staff also determined that information provided during the public 7 comment period did not identify any new issue that requires site-specific assessment. The NRC 8 staff reviewed the discussion of environmental impacts associated with operation during the 9 renewal term in the GEIS and has conducted its own independent review, including public 10 scoping meetings, to identify issues with new and significant information. Processes for 11 identification and evaluation of new information are described in Section 1.2.2.

12 4.8 Cumulative Impacts 13 The NRC staff considered potential cumulative impacts on the environment resulting from the 14 incremental impact of license renewal when added to other past, present, and reasonably 15 foreseeable future actions. For the purposes of this analysis, past actions are related to the 16 resources when JAFNPP was licensed and constructed, present actions are related to the 17 resources during current operations, and future actions are those that are reasonably 18 foreseeable through the end of plant operations including the license renewal term. The 19 geographic area over which past, present, and future actions are assessed is dependent on the 20 affected resource.

21 The impacts of the proposed action, license renewal, as described in this chapter of the draft 22 SEIS, are combined with other past, present, and reasonably foreseeable future actions 23 regardless of which agency (Federal or non-Federal) or entity is undertaking the actions. The 24 combined impacts are defined as "cumulative" in 40 CFR 1508.7 and include individually minor 25 but collectively significant actions taking place over a period of time. It is possible that an 26 impact that may be SMALL by itself could result in a MODERATE or LARGE impact when 27 considered in combination with the impacts of other actions on the affected resource. Likewise, 28 if a resource is regionally declining or imperiled, even a SMALL individual impact could be 29 important if it contributes to or accelerates the overall resource decline.

30 4.8.1 Cumulative Impacts on Aquatic Resources 31 This section assesses the impacts of the proposed action that relate to the withdrawal and 32 discharge of lake water by the JAFNPP once-through cooling system, combined with other past, 33 present, and reasonably foreseeable future actions that occur within the defined geographic 34 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-48 June 2007 area of Lake Ontario. The geographic area considered for the analysis of cumulative impacts 1 on aquatic resources focuses on the southeastern portion of Lake Ontario within a 50-mi radius 2 of the Nine Mile Point promontory. This area is large enough to encompass the ecological 3 resources and potential cumulative impacts of concern but is not too large as to make the 4 analysis impractical.

5 Like the other Great Lakes, Lake Ontario has experienced significant changes in the structure 6 and functioning of its aquatic ecosystem since the beginning of the Euro-American historical 7 period, and the cumulative impacts of past actions have resulted in the existing water quality 8 and aquatic resource conditions near JAFNPP. Lake Ontario is a dynamic aquatic ecosystem 9 and over the years has evolved in response to ecological stressors such as overfishing, 10 contaminant releases from industry, cultural eutrophication, land-use changes, and the 11 introduction of non-native species. These stressors have profoundly changed the species 12 composition and abundance of organisms from almost all trophic levels lake-wide. It is likely 13 these changes to Lake Ontario's aquatic resources have not stabilized, and continuing changes 14 in this complex ecosystem can be expected in the future. Furthermore, potential impacts of 15 climate change on Lake Ontario cannot be quantified at this time but could include changes in 16 water temperature, summer stratification, water quality, water level, productivity, and 17 subsequently, aquatic species composition and abundance (UCS 2003).

18 Since the 1970s, there have been a number of bi-national management efforts between the 19 U.S. and Canada to restore the ecological integrity of Lake Ontario, including the creation of the 20 Great Lakes Fishery Commission (GLFC) and the International Joint Commission, and the 21 signing of three Great Lakes Water Quality Agreements (Mills et al. 2005). The most recent 22 agreement took place in 1987 and committed Canada and the U.S. to developing lake-wide 23 management plans for each of the Great Lakes. Part of this effort includes the creation of 24 remedial action plans that address areas of concern and sources of 11 lake-wide critical 25 pollutants. The plans coordinate localized efforts throughout Lake Ontario by other groups such 26 as the GLFC and State and Province fishery management programs (EPA 1998).

27 While Lake Ontario water quality has vastly improved since the implementation of these bi-28 national efforts, the status of its fisheries is still considered to be the most damaged of the five 29 Great Lakes (USGS 2002). Lake researchers believe there is an incongruity between the goals 30 of the fishery stakeholders and what Lake Ontario ecosystem can actually support (Stewart et 31 al. 1999). Furthermore, the colonization of non-native species has so fundamentally changed 32 the lake's ecosystem that it is unlikely to ever return to its original state. Management of 33 invasive species at the local level, where resource uses are affected by their presence, is a 34 major activity by Lake Ontario management groups and a foreseeable continuing focus of these 35 groups. Contributions to cumulative impacts on Lake Ontario aquatic resources during the 36 license renewal period can be reasonably expected to be similar to those currently impacting 37 the lake. However, given the emphasis on lake-wide management plans and remedial action 38 plans to collaboratively protect and restore the lake and its resources, potential cumulative 39 effects will likely be carefu lly assessed and managed over time.

40 Environmental Impacts of Operation June 2007 4-49 Draft NUREG-1437, Supplement 31 Future use of Lake Ontario likely includes its continued use for water supply, waste water 1 disposal, cooling water for power plants, shipping, and recreational fishing and boating.

2 Additionally, future continued development of the southeastern Lake Ontario watershed may 3 impact the lake's water quality. However, the State of New York has a comprehensive water 4 resources management program, and with coordinated efforts between State agencies and the 5 above-mentioned bi-national groups, such activities would be regulated to avoid adverse 6 impacts to the lake. Port Oswego, approximately 6 mi west of JAFNPP, will likely continue to 7 receive cargo ships. The discharge of ballast water from foreign ships, the primary vector for 8 invasive species, has become an issue of special importance for lake managers. According to 9 the National Oceanic and Atmospheric Administration (NOAA), approximately 183 aquatic non-10 indigenous species have populated the five Great Lakes (NOAA 2006). In response, when 11 ships enter the St. Lawrence Seaway, ballast water is now carefully monitored by the U.S.

12 Coast Guard, the St. Lawrence Seaway Development Corporation, and Transport Canada 13 Marine Safety (GLSLSS 2007).

14 In addition to JAFNPP, four power-generating facilities near JAFNPP withdraw water from and 15 discharge water to Lake Ontario-Constellation Energy Group's two-unit Nine Mile Point 16 Nuclear Station, immediately west of and adjacent to JAFNPP; Dynegy Independence Station, a 17 1064-MW natural gas-fired combined-cycle cogeneration plant approximately 7 mi southwest of 18 JAFNPP; NRG Energy, Inc., Oswego Steam Station, an oil and natural gas-fired 1700-MW 19 peaking plant approximately 7.5 mi southwest of JAFNPP; and Indeck-Oswego Energy Center, 20 a 50-MW gas-turbine combined-cycle cogeneration facility approximately 6.5 mi southwest of 21 JAFNPP (Dynegy 2007; NRG 2007; Indeck 2007). It can be reasonably assumed that these 22 facilities will remain in operation throughout the JAFNPP license renewal period, and water 23 withdrawals and discharges from these facilities will be regulated by the NYSDEC under the 24 SPDES permitting process.

25 Additional impacts to the Lake Ontario fishery could occur due to the number of dams on Lake 26 Ontario tributaries. Brookfield Power operates eight hydroelectric facilities along the Oswego 27 and Salmon rivers. It is expected that these dams will remain in operation for the duration of the 28 JAFNPP license renewal period (Brookfield 2006). Dams generally impact fish populations:

29 migration and other fish movements can be impeded or blocked entirely; quantity, quality, and 30 access to essential habitat can be affected; and fish may suffer mortality or morbidity while 31 passing through the turbines or over spillways. Additionally, changes in river discharge regime, 32 water quality, and primary and secondary productivity caused by the dams may indirectly impact 33 fish populations (Larinier 2000).

34 A study of species composition and distribution of fish larvae collected in the Nine Mile Point 35 nearshore waters published in 1975 concluded the coastline area of Lake Ontario was not a 36 desirable fish spawning or nursery habitat because of extensive nearshore wave action and 37 unsuitable bedrock and rubble substrate (TI 1979). However, Lake Ontario offshore waters are 38 important forage areas for the lake's valuable salmonid populations and their prey species, the 39 alewife and rainbow smelt. Recent studies have suggested that prey fish populations are 40 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-50 June 2007 moving offshore in response to changes in Lake Ontario's food web, which have occurred 1 mostly from the introduction of invasive species to the lake in the early 1990s. Alewife in 2 particular may be moving to deeper waters to escape forage competition from round goby, a 3 thriving and aggressive Lake Ontario invasive species (USGS 2002).

4 As discussed in Section 4.1 of this draft SEIS, the NRC staff found no new and significant 5 information to indicate that the conclusions regarding any of the Category 1 issues related to the 6 cooling system at JAFNPP are inconsistent with the GEIS (NRC 1996). Assuming no future 7 changes in station cooling system design or operation, the NRC staff determined that potential 8 losses of aquatic resources resulting from these Category 2 issues during the license renewal 9 term would not alter any important attribute of Lake Ontario. Furthermore, the NYSDEC may 10 impose further restrictions or require modifications to the JAFNPP cooling system to reduce 11 impacts of entrainment and impingement. The temperature and volume of heated effluent 12 discharged by JAFNPP to Lake Ontario will continue to be monitored daily by plant personnel 13 and regulated by the NYSDEC. Additionally, the transmission line ROW maintenance activities 14 in the vicinity of stream and river crossings employ procedures to minimize erosion and 15 shoreline disturbance while encouraging veget ative cover. Therefore, impacts from 16 maintenance of transmission lines associated with JAFNPP would have negligible impact on 17 aquatic resources related to the Lake Ontario basin.

18 Because Lake Ontario and the Nine Mile Point promontory area are influenced by many 19 controlling factors, the impact of JAFNPP operations during the license renewal term can only 20 be qualitatively described with some degree of certainty. The NRC staff concludes, however, 21 that the SMALL impacts of the JAFNPP cooling system, including entrainment and impingement 22 of fish and shellfish, heat shock, or any of the cooling system-related Category 1 issues are not 23 contributing to an overall decline in Lake Ontario water quality or its aquatic resources.

24 Therefore, the NRC staff concludes that the contribution of impacts associated with the 25 continued operation of JAFNPP during the renewal period to the cumulative impacts likely to be 26 experienced in the southeastern portion of Lake Ontario would be SMALL.

27 4.8.2 Cumulative Impacts on Terrestrial Resources 28 This section analyzes past, present, and future actions that could result in adverse cumulative 29 impacts on terrestrial resources, including wildlife population, upland habitat, wetlands, 30 floodplains, invasive species, land use, and protected species. For the purposes of this 31 analysis, the geographic area that encompasses the past, present, and foreseeable future 32 actions that could contribute to adverse cumulative impacts on terrestrial resources includes 33 Oswego and Oneida counties, which contain JAFNPP and its associated transmission corridors 34 that are within the scope of the license renewal review.

35 Since the initial construction of JAFNPP and the associated transmission line, there have been 36 changes in land use and land cover with resulting changes on terrestrial ecosystems both at the 37 JAFNPP site and along the transmission corridor.

38 Environmental Impacts of Operation June 2007 4-51 Draft NUREG-1437, Supplement 31 Initial construction of JAFNPP resulted in a change in land use for part of the property from 1 residential to industrial. Most of the property was left undeveloped and allowed to mature from 2 secondary growth forests toward old-growth forests, with some areas continuing as wetlands 3 and ponds (Entergy 2006b). Construction of the transmission lines to the Edic Substation and 4 the Lighthouse Hill Hydroelectric Station converted a portion of forested land to low shrubby and 5 herbaceous cover, with resulting changes in the wildlife and plant species present. In some 6 locations, this caused a forested area to be fragmented. This effect increases habitat for 7 species that live on forest edges and reduces habitat for species that live in the interior of forest 8 parcels. Some species, particularly insects and small mammals, have difficulty crossing 9 transmission corridors (Forman 2001). Other contributors to forest fragmentation in this region 10 include construction of the transmission lines associated with Nine Mile Point Nuclear Station, 11 clearing and continued use of land for farming, road construction and maintenance, and 12 commercial and residential development. In some areas, abandoned farms adjacent to forests 13 are developing into forests, reducing the impacts of fragmentation. The NRC staff has not 14 identified any interior species populations that have significantly decreased in the region as a 15 result of the cumulative impacts of forest fragmentation. The NRC staff has not found any 16 information to conclude that continued operation or maintenance activities of JAFNPP or the 17 associated transmission lines would have significant negative impacts on any non-protected 18 plant or animal species, including interior species populations. Therefore, the NRC staff 19 believes that the incremental impact of license renewal on terrestrial species and habitat, would 20 be minor.

21 NRC staff identified two invasive species in the area that may degrade terrestrial habitat. Their 22 spread could be accelerated by present and future actions. Common reed is thought to have 23 been introduced by accident in the late 1700s or early 1800s and has spread across North 24 America (PCA 2006a). Japanese knotweed (Polygonum cuspidatum) was introduced 25 intentionally in the U.S. in the late 1800s, probably as an ornamental plant, and has spread 26 throughout the eastern U.S. (PCA 2006b). These two species are spreading throughout New 27 York at various rates due to natural and human processes, resulting in habitat loss for native 28 species (PCA 2006a, 2006b). Both species are spread by the wind; Japanese knotweed 29 usually grows in streamside areas, while common reed colonizes wetlands (PCA 2006a, 30 2006b). Open areas like transmission corridors have lower wind resistance than forests 31 (Forman 2001), potentially allowing wind-borne seeds to spread farther through transmission 32 corridors than adjacent forests. Construction and maintenance of the transmission line corridor 33 has created a potential pathway for the spread of these species. Potential preventative and 34 mitigative measures include surveys and programs for monitoring and removing these species 35 within the corridor and at the JAFNPP site. Given the ability of these species to drastically alter 36 local ecosystems, the impacts of the introduction and spread of these species could over time 37 significantly alter the habitat. NRC staff does not believe, however, that the continued operation 38 and maintenance of the JAFNPP transmission lines contribute significantly to this impact.

39 The FWS has identified the Federally protected Indiana bat and the bog turtle as potentially 40 occurring near or within the project area, which includes the Edic and Scriba transmission 41 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-52 June 2007 corridors. The NRC staff has initiated informal consultation under Section 7 of the Endangered 1 Species Act of 1972 with the FWS. As part of that consultation the FWS will assess the 2 cumulative impacts to both species. The NRC st aff has preliminarily determined that continued 3 operation of the JAFNPP for an additional year may affect but is not likely to adversely affect the 4 Indiana bat and the bog turtle. The consultation with the FWS is ongoing and may result in 5 additional requirements to ensure protection of these two species.

6 The NRC staff examined the cumulative effects of forest fragmentation, the spread of invasive 7 species, and impacts to Federally protected species as they relate to terrestrial resources within 8 the project area. The NRC staff finds that the impacts could be MODERATE, depending on the 9 extent of alteration of habitat within the project area due to the spread of invasive Japanese 10 knotweed and the common reed. However, the NRC staff finds that the direct impacts of 11 continued operation of JAFNPP and the maintenance of the transmission corridors on terrestrial 12 resources to be SMALL.

13 4.8.3 Cumulative Impacts on Human Health 14 4.8.3.1 Cumulative Impacts Resulting from Continued Operation of the Transmission Lines 15 Cumulative impacts resulting from continued operation of the electrical transmission lines 16 associated with JAFNPP were evaluated to determine whether there was the potential for 17 adverse cumulative impacts to terrestrial resources, wetlands, floodplains, or aquatic resources.

18 Other than the existing power transmission lines from JAFNPP and the Nine Mile Point Nuclear 19 Station, the NRC staff is unaware of any planned activities within the area that could have 20 additional cumulative impacts. Furthermore, the NRC staff concluded in Section 4.2.1 of this 21 draft SEIS that the potential impacts for electric shock from existing transmission lines during 22 the renewal period are SMALL and that no addi tional mitigation measures are warranted.

23 Therefore, the NRC staff has determined that the cumulative impacts of the continued operation 24 of the JAFNPP transmission lines are also SMALL and that no additional mitigation is 25 warranted.

26 4.8.3.2 Cumulative Radiological Impacts 27 The radiological dose limits for protection of the public and workers were developed by the EPA 28 and NRC to address the cumulative impact of acute and long-term exposure to radiation and 29 radioactive material. The dose limits are codified in 40 CFR Part 190 and 10 CFR Part 20. For 30 the purpose of this analysis, the area within an 80-km (50-mi) radius of the JAFNPP site was 31 included. The Radiological Environmental Monitoring Program (REMP) conducted by Entergy 32 in the vicinity of the JAFNPP site measures radiation and radioactive materials from all sources, 33 including JAFNPP and the adjacent Nine Mile Point Nuclear Station (owned by Constellation 34 Nuclear). Results for 2001 through 2005 were reviewed as part of the cumulative impacts 35 assessment. Additionally, in Sections 2.2.7 and 4.3 of this draft SEIS, the NRC staff concluded 36 that impacts of radiation exposure to the public and workers (occupational) from operation of 37 Environmental Impacts of Operation June 2007 4-53 Draft NUREG-1437, Supplement 31 JAFNPP during the renewal term would be SMALL. Therefore, both REMP and the NRC staff's 1 conclusion considered cumulative impacts. The NRC and the State of New York would regulate 2 any future actions in the vicinity of the JAFNPP site that could contribute to cumulative 3 radiological impacts.

4 4.8.4 Cumulative Socioeconomic Impacts 5 The continued operation of JAFNPP during the license renewal term would not add to any 6 socioeconomic impacts beyond those already bei ng experienced in the region. The NRC staff 7 determined that there would be no impacts on housing, public utilities, public services, and 8 environmental justice. There would also be no impact on offsite land use because no 9 refurbishment actions are planned at JAFNPP and no incremental sources of plant-related tax 10 payments are expected. There are no reasonably foreseeable scenarios that would alter these 11 conclusions in regard to cumulative impacts. Therefore, the NRC staff concludes that there 12 would be no cumulative socioeconomic impacts from continued operations at JAFNPP and 13 mitigation would not be required.

14 4.8.5 Conclusions Regarding Cumulative Impacts 15 The NRC staff considered the potential impacts resulting from the operation of JAFNPP during 16 the license renewal term and other past, present, and future actions in the vicinity of JAFNPP.

17 The NRC staff's preliminary determination is that t he potential cumulative impacts resulting from 18 JAFNPP operation during the license renewal term would generally be SMALL. The NRC will 19 work with the FWS to determine whether the impacts of license renewal on protected terrestrial 20 species would significantly add to these impacts.

21 4.9 Summary of Impacts of Operations During the Renewal Term 22 Neither JAFNPP nor the NRC staff is aware of information that is both new and significant 23 related to any of the applicable Category 1 issues associated with the JAFNPP operation during 24 the renewal term. Consequently, the NRC staff concludes that environmental impacts 25 associated with these issues are bounded by the impacts described in the GEIS. For each of 26 these issues, the GEIS concluded that the impacts would be SMALL and that additional plant-27 specific mitigation measures are not likely to be sufficiently beneficial to warrant implementation.

28 Plant-specific environmental evaluations were conducted for 11 Category 2 issues applicable to 29 JAFNPP operation during the renewal term and for environmental justice and chronic effects of 30 electromagnetic fields. For these 11 issues and environmental justice, the NRC staff concluded 31 that the potential environmental impact of renewal term operations of JAFNPP would be of 32 SMALL significance in the context of the standards set forth in the GEIS and that additional 33 mitigation would not be warranted. In addition, the NRC staff determined that a consensus has 34 not been reached by appropriate Federal health agencies regarding chronic adverse effects 35 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-54 June 2007 from electromagnetic fields. Therefore, the NRC staff did not conduct an evaluation of this 1 issue. 2 4.10 References 3 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for 4 Protection Against Radiation."

5 10 CFR Part 51.

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Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 11 Part 800, "Protection of Historic Properties."

12 40 CFR Part 190.

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15 40 CFR Part 1508.

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25 Schaner, T. and S.R. LaPan. 2005. Pelagic Planktivores.

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//ecos.fws.gov/tess_public/StateListing.do?status 5 =listed&state=NY (accessed April 9, 2007). Accessible at ML071000492 6 U.S. Geological Service (USGS), Great Lakes Science Center. 2002. "Preyfish Population 7 Assessment." Available URL: http://

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26 U.S. Nuclear Regulatory Commission (NRC). 2006b. Letter from Rani Franovich, Branch Chief 27 Division of License Renewal, to Don Klima, Director, Office of Federal Agency Programs 28 Advisory Council on Historic Preservation.

Subject:

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30 Environmental Impacts of Operation Draft NUREG-1437, Supplement 31 4-60 June 2007 U.S. Nuclear Regulatory Commission (NRC). 2006c. Letter from Rani Franovich, Branch Chief 1 Division of License Renewal, to Bernadette Castro, Commissioner, New York State Office of 2 Parks, Recreation, and Historic Preservation.

Subject:

James A. Fitzpatrick Nuclear Power 3 Plant License Renewal Review. (Project Review OPRHP No. 06PR0982). September 15, 4 2006. Accessible at ML062480220.

5 U.S. Nuclear Regulatory Commission (NRC). 2006d. Letter from Rani Franovich, Branch Chief 6 Division of License Renewal, to Marvin Moriarty, U.S. Fish and Wildlife Service, Northeast 7 Regional Office.

Subject:

Request for list of protected species within the area under evaluation 8 for the James A. FitzPatrick Nuclear Power Plant license renewal application review.

9 September 19, 2006. Accessible at ML062630292.

10 U.S. Nuclear Regulatory Commission (NRC). 2007. Letter from Rani Franovich, Branch Chief 11 Division of License Renewal, to Marvin Moriarty, U.S. Fish and Wildlife Service, Northeast 12 Regional Office.

Subject:

Biological Assessment for Proposed License Renewal of James A.

13 FitzPatrick Nuclear Power Plant

. May 16, 2007. Accessible at ML071310069.

14 Wilke, C.J. 2006. "Mephitis mephitis (striped skunk)." Available URL: http://animaldiversity 15 .ummz.umich.edu/site/accounts/information/Mephitis_mephitis.html (accessed December 28, 16 2006). Accessible at ML070120348.

17 June 2007 5-1 NUREG-1437, Supplement 31 5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS 1 2 Environmental issues associated with postulated accidents are discussed in the Generic 3 Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, 4 Volumes 1 and 2 (NRC 1996; 1999).

(1) The GEIS includes a determination of whether the 5 analysis of the environmental issue could be applied to all plants and whether additional 6 mitigation measures would be warranted. Issues are then assigned a Category 1 or a 7 Category 2 designation. As set forth in the GEIS, Category 1 issues are those that meet all of 8 the following criteria:

9 10 (1) The environmental impacts associated with the issue have been determined to apply either to all plants or, for some issues, to plants having a specific type of cooling system or other specified plant or site characteristics.

(2) Single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to the impacts (except for collective off-site radiological impacts from the fuel cycle and from high level waste and spent fuel disposal).

(3) Mitigation of adverse impacts associated with the issue has been considered in the analysis, and it has been determined that additional plant-specific mitigation measures are likely not to be sufficiently beneficial to warrant implementation.

11 For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 12 required unless new and significant information is identified.

13 14 Category 2 issues are those that do not meet one or more of the criteria for Category 1, and 15 therefore, additional plant-specific review of these issues is required.

16 17 This chapter describes the environmental impacts from postulated accidents that might occur 18 during the license renewal term.

19 20 5.1 Postul ated Plant Accidents 21 22 Two classes of accidents are evaluated in the GEIS. These are design-basis accidents (DBAs) 23 and severe accidents, as discussed below.

24 25 5.1.1 Design-Basis Accidents 26 (1) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" include the GEIS and Addendum 1.

Postulated Accidents Draft NUREG-1437, Supplement 31 5-2 June 2007 1 In order to receive NRC approval to operate a nuclear power facility, an applicant for an initial 2 operating license must submit a safety analysis report (SAR) as part of its application. The SAR 3 presents the design criteria and design information for the proposed reactor and comprehensive 4 data on the proposed site. The SAR also discusses various hypothetical accident situations and 5 the safety features that are provided to prevent and mitigate accidents. The NRC staff reviews 6 the application to determine whether the plant design meets the Commission's regulations and 7 requirements and includes, in part, the nuclear plant design and its anticipated response to an 8 accident.

9 10 DBAs are those accidents that both the licensee and the NRC staff evaluate to ensure that the 11 plant can withstand normal and abnormal transients, and a broad spectrum of postulated 12 accidents, without undue hazard to the health and safety of the public. A number of these 13 postulated accidents are not expected to occur during the life of the plant, but are evaluated to 14 establish the design basis for the preventive and mitigative safety systems of the facility. The 15 acceptance criteria for DBAs are described in 10 CFR Part 50 and 10 CFR Part 100.

16 17 The environmental impacts of DBAs are evaluated during the initial licensing process, and the 18 ability of the plant to withstand these accidents is demonstrated to be acceptable before 19 issuance of the operating license (OL). The results of these evaluations are found in license 20 documentation such as the applicant's final safety analysis report (FSAR), the staff's safety 21 evaluation report (SER), the final environmental statement (FES), and Section 5.1 of this 22 supplemental environmental impact statement (SEIS). A licensee is required to maintain the 23 acceptable design and performance criteria throughout the life of the plant, including any 24 extended-life operation. The consequences for these events are evaluated for the hypothetical 25 maximum exposed individual; as such, changes in the plant environment will not affect these 26 evaluations. Because of the requirements that continuous acceptability of the consequences 27 and aging management programs be in effect for license renewal, the environmental impacts as 28 calculated for DBAs should not differ significantly from initial licensing assessments over the life 29 of the plant, including the license renewal period. Accordingly, the design of the plant relative to 30 DBAs during the extended period is considered to remain acceptable and the environmental 31 impacts of those accidents were not examined further in the GEIS.

32 33 The Commission has determined that the environmental impacts of DBAs are of SMALL 34 significance for all plants because the plants were designed to successfully withstand these 35 accidents. Therefore, for the purposes of license renewal, design-basis accidents are 36 designated as a Category 1 issue in 10 CFR Part 51, Subpart A, Appendix B, Table B-1. The 37 early resolution of the DBAs makes them a part of the current licensing basis of the plant; the 38 current licensing basis of the plant is to be maintained by the licensee under its current license 39 and, therefore, under the provisions of 10 CFR 54.30, is not subject to review under license 40 Postulated Accidents June 2007 5-3 Draft NUREG-1437, Supplement 31 renewal. This issue, applicable to the James A. FitzPatrick Nuclear Power Plant (JAFNPP), is 1 listed in Table 5-1.

2 3 Table 5-1. Category 1 Issue Applicable to Postulated Accidents During the Renewal Term 4 5 ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections POSTULATED ACCIDENTS Design basis accidents 5.3.2; 5.5.1 6 Based on information in the GEIS, the Commission found that 7 8 The NRC staff has concluded that the environmental impacts of design basis accidents are of small significance for all plants.

9 Entergy stated in its Environmental Report (ER; Entergy 2006a) that it is not aware of any new 10 and significant information associated with the renewal of the JAFNPP OL. The staff has not 11 identified any new and significant information during its independent review of the JAFNPP ER 12 (Entergy 2006a), the staff's site audit, the scoping process, or its evaluation of other available 13 information. Therefore, the staff concludes that there are no impacts related to design basis 14 accidents beyond those discussed in the GEIS.

15 16 5.1.2 Severe Accidents 17 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 conse-20 quences. In the GEIS, the staff assessed the impacts of severe accidents during the license 21 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 25 Severe accidents initiated by external phenomena such as tornadoes, floods, earthquakes, 26 fires, and sabotage have not traditionally been discussed in quantitative terms in FESs and 27 were not specifically considered for JAFNPP in the GEIS (NRC 1996). However, in the GEIS 28 the staff did evaluate existing impact assessments performed by NRC and by the industry at 29 44 nuclear plants in the United States and concluded that the risk from beyond design basis 30 earthquakes at existing nuclear power plants is SMALL. Also, the GEIS for license renewal has 31 already "performed a discretionary analysis of terrorist acts in connection with license renewal, 32 and concluded that the core damage and radiological release from such acts would be no worse 33 Postulated Accidents Draft NUREG-1437, Supplement 31 5-4 June 2007 than the damage and release to be expected from internally initiated events." The GEIS 1 contains an analysis of terrorist acts in connection with license renewal, and concluded that the 2 core damage and radiological release from such acts would be no worse than the damage and 3 release to be expected from internally initiated events. (Amergen Energy, Co. LLC., License 4 Renewal for Oyster Creek Nuclear station), CLI-07-08, 65 NRC --. (slip op.) (Feb. 26, 2007).

5 Based on the above, the Commission concludes that the risk from sabotage and beyond design 6 basis earthquakes at existing nuclear power plants is small and additionally, that the risks from 7 other external events are adequately addressed by a generic consideration of internally initiated 8 severe accidents.

9 10 Based on information in the GEIS, the Commission found that 11 12 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.

13 Therefore, the Commission has designated mitigation of severe accidents as a Category 2 issue 14 in 10 CFR Part 51, Subpart A, Appendix B, Table B-1. This issue, applicable to JAFNPP, is 15 listed in Table 5-2.

16 17 The NRC staff has not identified any new and significant information with regard to the 18 consequences from severe accidents during its independent review of the JAFNPP ER (Entergy 19 2006a), the staff's site audit, the scoping process, and its evaluation of other available 20 information and public comments on the draft SEIS. Therefore, the NRC staff concludes that 21 there are no impacts of severe accidents beyond those discussed in the GEIS. However, in 22 accordance with 10 CFR 51.53(c)(3)(ii)(L), the staff has reviewed severe accident mitigation 23 alternatives (SAMAs) for JAFNPP. The results of its review are discussed in Section 5.2.

24 Postulated Accidents June 2007 5-5 Draft NUREG-1437, Supplement 31 Table 5-2. Category 2 Issue Applicable to Postulated Accidents During the Renewal Term 1 2 ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections 10 CFR 51.53(c)(3)(ii) Subparagraph SEIS Section POSTULATED ACCIDENTS Severe Accidents 5.3.3; 5.3.3.2; 5.3.3.3; 5.3.3.4; 5.3.3.5; 5.4; 5.5.2 L 5.2 3 4 5.2 Severe Accident Mitigation Alternatives 5 6 Section 51.53(c)(3)(ii)(L) requires that license renewal applicants consider alternatives to 7 mitigate severe accidents if the staff has not previously evaluated SAMAs for the applicant's 8 plant in an environmental impact statement (EIS) or related supplement or in an environmental 9 assessment. The purpose of this consideration is to ensure that plant changes (i.e., hardware, 10 procedures, and training) with the potential for improving severe accident safety performance 11 are identified and evaluated. SAMAs have not been previously considered for JAFNPP; 12 therefore, the remainder of Chapter 5 addresses those alternatives.

13 5.2.1 Introduction 14 This section presents a summary of the SAMA evaluation for JAFNPP conducted by Entergy 15 Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy), and described in the 16 ER, and the NRC's review of this evaluation. The details of the review are described in the NRC 17 staff evaluation that was prepared with contract assistance from Pacific Northwest National 18 Laboratory. The entire evaluation for JAFNPP is presented in Appendix G.

19 The SAMA evaluation for JAFNPP was conducted with a four-step approach. In the first step 20 Entergy quantified the level of risk associated with potential reactor accidents using the plant-21 specific probabilistic safety assessment (PSA) and other risk models.

22 In the second step Entergy examined the major risk contributors and identified possible ways 23 (SAMAs) of reducing that risk. Common ways of reducing risk are changes to components, 24 systems, procedures, and training. Entergy initially identified 293 potential SAMAs for JAFNPP.

25 Entergy screened out 230 SAMAs from further consideration because they are not applicable at 26 JAFNPP due to design differences, have already been implemented at JAFNPP, or are 27 addressed by a similar SAMA. The remaining 63 SAMAs were subjected to further evaluation.

28 Postulated Accidents Draft NUREG-1437, Supplement 31 5-6 June 2007 In the third step Entergy estimated the benefits and the costs associated with each of the 1 remaining SAMAs. Estimates were made of how much each SAMA could reduce risk. Those 2 estimates were developed in terms of dollars in accordance with NRC guidance for performing 3 regulatory analyses (NRC 1997). The cost of implementing the proposed SAMAs was also 4 estimated.

5 Finally, in the fourth step, the costs and benefits of each of the remaining SAMAs were 6 compared to determine whether the SAMA was cost-beneficial, meaning the benefits of the 7 SAMA were greater than the cost (a positive cost-benefit). Entergy found five SAMAs to be 8 potentially cost-beneficial (Entergy 2006a). However, based on further consideration of 9 potentially cost-beneficial SAMAs at other plants, Entergy identified one additional potentially 10 cost-beneficial SAMA (Entergy 2006b).

11 The potentially cost-beneficial SAMAs do not relate to adequately managing the effects of aging 12 during the period of extended operation; theref ore, they need not be implemented as part of 13 license renewal pursuant to 10 CFR Part 54. Entergy's SAMA analyses and the NRC's review 14 are discussed in more detail below.

15 5.2.2 Estimate of Risk 16 Entergy submitted an assessment of SAMAs for JAFNPP as part of the ER (Entergy 2006a).

17 This assessment was based on the most recent JAFNPP PSA available at that time, a plant-18 specific offsite consequence analysis performed using the MELCOR Accident Consequence 19 Code System 2 (MACCS2) computer program, and insights from the JAFNPP Individual Plant 20 Examination (IPE) (NPA 1991) and Individual Plant Examination of External Events (IPEEE) 21 (NPA 1996).

22 The baseline core damage frequency (CDF) for the purpose of the SAMA evaluation is 23 approximately 2.74 x 10

-6 per year. This CDF is based on the risk assessment for internally-24 initiated events. Entergy did not include the cont ribution to risk from external events within the 25 JAFNPP risk estimates; however, it did account for the potential risk reduction benefits 26 associated with external events by increasing the estimated benefits for internal events by a 27 factor of 4. The breakdown of CDF by initiating event is provided in Table 5-3.

28 As shown in Table 5-3, events initiated by station blackout (SBO) and transients are the 29 dominant contributors to the CDF. Anticipated transient without scram (ATWS) sequences are 30 not significant contributors to the CDF.

31 32 Entergy estimated the dose to the population within 50 mi of the JAFNPP site to be 33 approximately 0.0163 person-Sv (1.63 person-rem) per year. The breakdown of the total 34 population dose by containment release mode is summarized in Table 5-4. Containment 35 failures within the late time frame (greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following event initiation) and the early 36 Postulated Accidents June 2007 5-7 Draft NUREG-1437, Supplement 31 time frame (0 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following event initiation) dominate the population dose risk at 1 JAFNPP, contributing about equally to the population dose risk.

2 3 The NRC staff has reviewed Entergy's data and evaluation methods and concludes that the 4 quality of the risk analyses is adequate to support an assessment of the risk reduction potential 5 for candidate SAMAs. Accordingly, the staff based its assessment of offsite risk on the CDFs 6 and offsite doses reported by Entergy.

7 8 Table 5-3. JAFNPP Core Damage Frequency 9 10 Initiating Event CDF (per year)

Percent Contribution to CDF Station Blackout 1.27 x 10-6 46 Transients with loss of containment heat removal 7.78x 10-7 28 Transients with loss of all emergency core cooling system (ECCS) injection 2.66 x 10-7 10 ATWS 1.38x 10

-7 5 Loss of a 4.16kv alternate current (AC) safeguard bus 1.18 x 10-7 5 Loss of both direct current (DC) divisions 9.55 x 10-8 3 Loss of coolant accident (LOCAs) 2.83 x 10-8 1 Loss of a division of DC power 2.60 x 10-8 1 Relay room flooding 2.53 x 10-8 1 Total CDF (from internal events) 2.74 x 10-6 100 11 Postulated Accidents Draft NUREG-1437, Supplement 31 5-8 June 2007 Table 5-4. Breakdown of Population Dose by Containment Release Mode 1 2 Containment Release Mode Population Dose (Person-Rem 1 Per Year) Percent Contribution Late Containment Failure 0.87 53 Early Containment Failure 0.76 47 Intact Containment negligible negligible Total 1.63 100 1One person-Rem = 0.01 person-Sv 3 4 5 5.2.3 Potential Plant Improvements 6 7 Once the dominant contributors to plant risk were identified, Entergy searched for ways to 8 reduce that risk. In identifying and evaluating potential SAMAs, Entergy considered insights 9 from the plant-specific PSA and SAMA analyses performed for other operating plants that have 10 submitted license renewal applications. Entergy identified 293 potential risk-reducing 11 improvements (SAMAs) to plant components, systems, procedures and training.

12 Entergy removed 230 SAMAs from further cons ideration because they are not applicable at 13 JAFNPP due to design differences, have already been implemented at JAFNPP, or are 14 addressed by a similar SAMA. A detailed cost-benefit analysis was performed for each of the 15 63 remaining SAMAs.

16 The staff concludes that Entergy used a systematic and comprehensive process for identifying 17 potential plant improvements for JAFNPP, and that the set of potential plant improvements 18 identified by Entergy is reasonably comprehensive and, therefore, acceptable.

19 5.2.4 Evaluation of Risk Reduction and Costs of Improvements 20 Entergy evaluated the risk-reduction potential of the remaining 63 SAMAs. The majority of the 21 SAMA evaluations were performed in a bounding fashion in that the SAMA was assumed to 22 completely eliminate the risk associated with the proposed enhancement.

23 Entergy estimated the costs of implementing the 63 candidate SAMAs through the application of 24 engineering judgment, and use of other licensees' estimates for similar improvements. The cost 25 estimates conservatively did not include the cost of replacement power during extended 26 outages required to implement the modifications, nor did they include contingency costs 27 associated with unforeseen implementation obstacles.

28 Postulated Accidents June 2007 5-9 Draft NUREG-1437, Supplement 31 The staff reviewed Entergy's bases for calculating the risk reduction for the various plant 1 improvements and concludes that the rationale and assumptions for estimating risk reduction 2 are reasonable and generally conservative (i.e., the estimated risk reduction is similar to or 3 somewhat higher than what would actually be realized). Accordingly, the staff based its 4 estimates of averted risk for the various SAMAs on Entergy's risk reduction estimates.

5 The staff reviewed the bases for the applicant's cost estimates. For certain improvements, the 6 staff also compared the cost estimates to estimates developed elsewhere for similar 7 improvements, including estimates developed as part of other licensees' analyses of SAMAs for 8 operating reactors and advanced light-water reactors. The staff found the cost estimates to be 9 consistent with estimates provided in support of other plants' analyses.

10 The staff concludes that the risk reduction and the cost estimates provided by Entergy are 11 sufficient and appropriate for use in the SAMA evaluation.

12 5.2.5 Cost-Benefit Comparison 13 The cost-benefit analysis performed by Entergy was based primarily on NUREG/BR-0184 (NRC 14 1997) and was conducted consistent with this guidance. NUREG/BR-0058 has recently been 15 revised to reflect the agency's revised policy on discount rates. Revision 4 of NUREG/BR-0058 16 states that two sets of estimates should be developed - one at three percent and one at seven 17 percent (NRC 2004). Entergy provided both sets of estimates (Entergy 2006a and 2006b).

18 19 Entergy identified five potentially cost-beneficial SAMAs in the baseline analysis contained in 20 the ER (using a seven percent discount rate, and considering the combined impact of both 21 external events and uncertainties). The potentially cost-beneficial SAMAs are:

22 23

• SAMA 26 - provide additional DC battery capacity to ensure longer battery capability 24 during the station blackout event, which would extend high pressure coolant injection 25 (HPCI)/ reactor core isolation cooling (RCIC) operability and allow more time for AC 26 power recovery.

27 28

• SAMA 30 - modify plant equipment to provide 16-hour SBO injection to improve 29 capability to cope with longer SBO scenarios.

30 31

• SAMA 36 - modify plant equipment to extend DC power availability in an SBO event, 32 which would extend HPCI/RCIC operability and allow more time for AC power recovery.

33 34

• SAMA 61 - modify plant procedures to allow use of a portable power supply for battery 35 chargers, which would improve the av ailability of the DC power system.

36 37 Postulated Accidents Draft NUREG-1437, Supplement 31 5-10 June 2007

• SAMA 62 - modify plant procedures to open the doors of the emergency diesel 1 generator (EDG) buildings upon receipt of a high temperature alarm, which improves the 2 reliability of the EDGs following high temperatures in the EDG buildings.

3 4 In supplemental information to the ER, Entergy provided a revised assessment based on a 5 separate accounting of uncertainties (Entergy 2006b). The revised assessment resulted in 6 identification of the same potentially cost-beneficial SAMAs. However, based on further 7 consideration of potentially cost-beneficial SAMAs at other plants, Entergy identified one 8 additional potentially cost-beneficial SAMA (Entergy 2006b). This alternative involves use of a 9 portable generator (to power battery chargers) to extend the coping time in loss of AC power 10 events. 11 12 The NRC staff concludes that, with the exception of the potentially cost-beneficial SAMAs 13 discussed above, the costs of the SAMAs evaluated would be higher than the associated 14 benefits.

15 5.2.6 Conclusions 16 The NRC staff reviewed Entergy's analysis and concluded that the methods used and the 17 implementation of those methods were sound. The treatment of SAMA benefits and costs 18 support the general conclusion that the SAMA evaluations performed by Entergy are reasonable 19 and sufficient for the license renewal submittal. Although the treatment of SAMAs for external 20 events was somewhat limited by the unavailabilit y of an external event PSA, the likelihood of 21 there being cost-beneficial enhancements in this area was minimized by improvements that 22 have been realized as a result of the IPEEE process and increasing the estimated SAMA 23 benefits for internal events by a multiplier to account for potential benefits in external events.

24 Based on its review of the SAMA analysis, the staff concurs with Entergy's identification of 25 areas in which risk can be further reduced in a cost-beneficial manner through the 26 implementation of all or a subset of potentially cost-beneficial SAMAs. Given the potential for 27 cost-beneficial risk reduction, the staff considers that further evaluation of these SAMAs by 28 Entergy is warranted. However, none of the potentially cost-beneficial SAMAs relate to 29 adequately managing the effects of aging during the period of extended operation. Therefore, 30 they need not be implemented as part of the license renewal pursuant to 10 CFR Part 54.

31 32 5.3 References 33 34 Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2006a.

35 James A. FitzPatrick Nuclear Power Plant --- License Renewal Application, Appendix E:

36 Applicant's Environmental Report, Operating License Renewal Stage.

Lycoming, New York.

37 Accessible at ML062160557.

38 39 Entergy Nuclear Operations, Inc. (Entergy). 2006b. Letter from P. Dietrich, Entergy, to NRC 40 Document Control Desk.

Subject:

"Entergy Nuclear Operations, Inc., James A. FitzPatrick 41 Postulated Accidents June 2007 5-11 Draft NUREG-1437, Supplement 31 Nuclear Power Plant, Docket No. 50-333, License No. DPR-59, License Renewal Application, 1 Amendment 1," JAFP-06-0167, Lycoming, New York, dated December 6, 2006. Accessible at 2 ML063480624.

3 4 U.S. Nuclear Regulatory Commission (NRC). 1997. Regulatory Analysis Technical Evaluation 5 Handbook. NUREG/BR-0184, Washington, D.C.

6 U.S. Nuclear Regulatory Commission (NRC). 2004. Regulatory Analysis Guidelines of the U.S.

7 Nuclear Regulatory Commission. NUREG/BR-0058, Rev. 4, Washington, D.C.

8 New York Power Authority (NYPA). 1991. "James A. FitzPatrick Nuclear Power Plant Docket 9 No. 50-333, Individual Plant Examination,"(JPN-91-048), September 1991.

10 11 New York Power Authority (NYPA). 1996. "James A. FitzPatrick Nuclear Power Plant Individual 12 Plant Examination for External Events," (JAF-RPT-MISC-02211), June 1996, Revision 0.

13 14

June 2007 6-1 Draft NUREG-1437, Supplement 31 6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE 1 AND SOLID WASTE MANAGEMENT 2 Environmental issues associated with the uranium fuel cycle and solid waste management are 3 discussed in the Generic Environmental Impact Statement for License Renewal of Nuclear 4 Plants (GEIS), NUREG-1437, Volumes 1 and 2 (NRC 1996; 1999).

(1) The GEIS includes a 5 determination of whether the analysis of the environmental issue could be applied to all plants 6 and whether additional mitigation measures would be warranted. Issues are then assigned a 7 Category 1 or a Category 2 designation. As set forth in the GEIS, Category 1 issues are those 8 that meet all of the following criteria:

9 (1) The environmental impacts associated wi th the issue have been determined to apply 10 either to all plants or, for some issues, to plants having a specific type of cooling system 11 or other specified plant or site characteristics.

12 (2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 13 the impacts (except for collective offsite radiological impacts from the fuel cycle and from 14 high-level waste [HLW] and spent fuel disposal).

15 (3) Mitigation of adverse impacts associated with the issue has been considered in the 16 analysis, and it has been determined that additional plant-specific mitigation measures 17 are likely not to be sufficiently beneficial to warrant implementation.

18 For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 19 required unless new and significant information is identified.

20 Category 2 issues are those that do not meet one or more of the criteria for Category 1, and 21 therefore, additional plant-specific review of these issues is required. There are no Category 2 22 issues related to the uranium fuel cycle and solid waste management.

23 This chapter addresses the issues that are related to the uranium fuel cycle and solid waste 24 management during the license renewal term that are listed in Table B-1 of 10 CFR Part 51, 25 Subpart A, Appendix B, and are applicable to James A. FitzPatrick Nuclear Power Plant 26 (JAFNPP). The generic potential impacts of the radiological and non-radiological environmental 27 impacts of the uranium fuel cycle and transportation of nuclear fuel and wastes are described in 28 detail in the GEIS based, in part, on the generic impacts provided in 10 CFR 51.51(b), 29 Table S-3, "Table of Uranium Fuel Cycle Environmental Data," and in 10 CFR 51.52(c),

30 Table S-4, "Environmental Impact of Transportation of Fuel and Waste to and from One Light-31 (1) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" include the GEIS and its Addendum 1.

Fuel Cycle Draft NUREG-1437, Supplement 31 6-2 June 2007 Water-Cooled Nuclear Power Reactor." The U.S. Nuclear Regulatory Commission (NRC) staff 1 also addresses the impacts from radon-222 and technetium-99 in the GEIS.

2 6.1 The Uranium Fuel Cycle 3 Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1 that are applicable to 4 JAFNPP from the uranium fuel cycle and solid waste management are listed in Table 6-1.

5 Table 6-1. Category 1 Issues Applicable to the Uranium Fuel Cycle and 6 Solid Waste Management During the Renewal Term 7 ISSUE- 10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section URANIUM FUEL CYCLE AND WASTE MANAGEMENT Offsite radiological impacts (individual effects from other than the disposal of spent fuel and high level waste) 6.1; 6.2.1; 6.2.2.1; 6.2.2.3; 6.2.3; 6.2.4; 6.6 Offsite radiological impacts (collective effects) 6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6 Offsite radiological impacts (spent fuel and high level waste disposal) 6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6 Nonradiological impacts of the uranium fuel cycle 6.1; 6.2.2.6; 6.2.2.

7; 6.2.2.8; 6.2.2.9; 6.2.3; 6.2.4; 6.6 Low-level waste storage and disposal 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; 6.4.4.6;6.6 Mixed waste storage and disposal 6.

4.5.1; 6.4.5.2; 6.

4.5.3; 6.4.5.4; 6.4.5.5; 6.4.5.6; 6.

4.5.6.1; 6.4.5.6.2; 6.4.5.6.3; 6.4.5.6.4; 6.6 Onsite spent fuel 6.1; 6.4.6; 6.4.6.1; 6.4.6.2; 6.4.6.3; 6.4.6.4; 6.4.6.5; 6.

4.6.6; 6.4.6.7; 6.6 Nonradiological waste 6.1; 6.5; 6.5.1; 6.5.2; 6.5.3; 6.6 Transportation 6.1; 6.3.1; 6.3.2.3; 6.3.3; 6.3.4; 6.6, Addendum 1 8 Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy), which 9 operate JAFNPP, stated in its Environmental Report (ER) for JAFNPP (Entergy 2006) that it is 10 not aware of any new and significant information associated with the renewal of the JAFNPP 11 operating license. The NRC staff has not identified any new and significant information during 12 Fuel Cycle June 2007 6-3 Draft NUREG-1437, Supplement 31 its independent review of the JAFNPP ER (Entergy 2006), the staff's site audit, the scoping 1 process, or its evaluation of other available information. Therefore, the NRC staff concludes 2 that there are no impacts related to these issues beyond those discussed in the GEIS. For 3 these issues, the NRC staff concluded in the GEIS that the impacts are SMALL except for the 4 collective offsite radiological impacts from the fuel cycle and from HLW and spent fuel disposal, 5 as discussed below, and that additional plant-specific mitigation measures are not likely to be 6 sufficiently beneficial to be warranted.

7 A brief description of the NRC staff's review and the GEIS conclusions, as codified in Table B-1, 8 10 CFR Part 51, for each of these issues follows:

9 Offsite radiological impacts (individual effects from other than the disposal of spent fuel and 10 high level waste). Based on information in the GEIS, the Commission found that 11 Offsite impacts of the uranium fuel cycle have been considered by the 12 Commission in Table S-3 of this part [10 CFR 51.51(b)]. Based on information in 13 the GEIS, impacts on individuals from radioactive gaseous and liquid releases 14 including radon-222 and technetium-99 are small.

15 The NRC staff has not identified any new and significant information during its independent 16 review of the JAFNPP ER (Entergy 2006), the staff's site audit, the scoping process, or its 17 evaluation of other available information. Ther efore, the NRC staff concludes that there are 18 no offsite radiological impacts of the uranium fuel cycle during the renewal term beyond 19 those discussed in the GEIS.

20 Offsite radiological impacts (collective effects). Based on information in the GEIS, the 21 Commission found that 22 The 100-year environmental dose commitment to the U.S. population from the 23 fuel cycle, high level waste and spent fuel disposal excepted, is calculated to be 24 about 14,800 person rem [Roentgen Equivalent Man], or 12 cancer fatalities, for 25 each additional 20-year power reactor operating term. Much of this, especially 26 the contribution of radon releases from mines and tailing piles, consists of tiny 27 doses summed over large populations. This same dose calculation can 28 theoretically be extended to include many tiny doses over additional thousands of 29 years as well as doses outside the U.S. The result of such a calculation would 30 be thousands of cancer fatalities from the fuel cycle, but this result assumes that 31 even tiny doses have some statistical adverse health effect which will not ever be 32 mitigated (for example no cancer cure in the next thousand years), and that 33 these doses projected over thousands of years are meaningful. However, these 34 assumptions are questionable. In particular, science cannot rule out the 35 possibility that there will be no cancer fatalities from these tiny doses. For 36 Fuel Cycle Draft NUREG-1437, Supplement 31 6-4 June 2007 perspective, the doses are very small fractions of regulatory limits and even 1 smaller fractions of natural background exposure to the same populations.

2 Nevertheless, despite all the uncertainty, some judgment as to the regulatory 3 NEPA [National Environmental Policy Act of 1969] implications of these matters 4 should be made and it makes no sense to repeat the same judgment in every 5 case. Even taking the uncertainties into account, the Commission concludes that 6 these impacts are acceptable in that these impacts would not be sufficiently large 7 to require the NEPA conclusion, for any plant, that the option of extended 8 operation under 10 CFR Part 54 should be eliminated. Accordingly, while the 9 Commission has not assigned a single level of significance for the collective 10 effects of the fuel cycle, this issue is considered Category 1.

11 The NRC staff has not identified any new and significant information during its independent 12 review of the JAFNPP ER (Entergy 2006), the staff's site audit, the scoping process, or its 13 evaluation of other available information. Ther efore, the NRC staff concludes that there are 14 no offsite radiological impacts (collective effects) from the uranium fuel cycle during the 15 renewal term beyond those discussed in the GEIS.

16 Offsite radiological impacts (spent fuel and high level waste disposal). Based on information 17 in the GEIS, the NRC found that 18 For the high level waste and spent fuel disposal component of the fuel cycle, 19 there are no current regulatory limits for offsite releases of radionuclides for the 20 current candidate repository site. However, if we assume that limits are 21 developed along the lines of the 1995 National Academy of Sciences (NAS) 22 report, "Technical Bases for Yucca Mountain Standards," and that in accordance 23 with the Commission's Waste Confidence Decision, 10 CFR 51.23, a repository 24 can and likely will be developed at some site which will comply with such limits, 25 peak doses to virtually all individuals will be 100 millirem [1 mSv] per year or less.

26 However, while the Commission has reasonable confidence that these 27 assumptions will prove correct, there is considerable uncertainty since the limits 28 are yet to be developed, no repository application has been completed or 29 reviewed, and uncertainty is inherent in the models used to evaluate possible 30 pathways to the human environment. The NAS report indicated that 100 millirem 31 [1 mSv] per year should be considered as a starting point for limits for individual 32 doses, but notes that some measure of consensus exists among national and 33 international bodies that the limits should be a fraction of the 100 millirem [1 mSv]

34 per year. The lifetime individual risk fr om 100 millirem [1 mSv] annual dose limit 35 is about 3 x 10

-3. 36 Estimating cumulative doses to populations over thousands of years is more 37 problematic. The likelihood and consequences of events that could seriously 38 Fuel Cycle June 2007 6-5 Draft NUREG-1437, Supplement 31 compromise the integrity of a deep geologic repository were evaluated by the 1 Department of Energy in the "Final Environmental Impact Statement:

2 Management of Commercially Generated Radioactive Waste," October 1980 3 [DOE 1980]. The evaluation estimated the 70-year whole-body dose 4 commitment to the maximum individual and to the regional population resulting 5 from several modes of breaching a reference repository in the year of closure, 6 after 1,000 years, after 100,000 years, and after 100,000,000 years.

7 Subsequently, the NRC and other federal agencies have expended considerable 8 effort to develop models for the design and for the licensing of a high level waste 9 repository, especially for the candidate repository at Yucca Mountain. More 10 meaningful estimates of doses to population may be possible in the future as 11 more is understood about the performance of the proposed Yucca Mountain 12 repository. Such estimates would involve very great uncertainty, especially with 13 respect to cumulative population doses over thousands of years. The standard 14 proposed by the NAS is a limit on maximum individual dose. The relationship of 15 potential new regulatory requirements, based on the NAS report, and cumulative 16 population impacts has not been determined, although the report articulates the 17 view that protection of individuals will adequately protect the population for a 18 repository at Yucca Mountain. However, EPA's [Environmental Protection 19 Agency's] generic repository standards in 40 CFR Part 191 generally provide an 20 indication of the order of magnitude of cumulative risk to population that could 21 result from the licensing of a Yucca Mountain repository, assuming the ultimate 22 standards will be within the range of standards now under consideration. The 23 standards in 40 CFR Part 191 protect the population by imposing "containment 24 requirements" that limit the cumulative amount of radioactive material released 25 over 10,000 years. Reporting performance standards that will be required by 26 EPA are expected to result in releases and associated health consequences in 27 the range between 10 and 100 premature cancer deaths with an upper limit of 28 1,000 premature cancer deaths world-wide for a 100,000 metric tonne [of heavy 29 metal] (MTHM) repository.

30 Nevertheless, despite all the uncertainty, some judgment as to the regulatory 31 NEPA implications of these matters should be made and it makes no sense to 32 repeat the same judgment in every case. Even taking the uncertainties into 33 account, the Commission concludes that these impacts are acceptable in that 34 these impacts would not be sufficiently large to require the NEPA conclusion, for 35 any plant, that the option of extended operation under 10 CFR part 54 should be 36 eliminated. Accordingly, while the Commission has not assigned a single level of 37 significance for the impacts of spent fuel and high level waste disposal, this issue 38 is considered Category 1.

39 On February 15, 2002, based on a recommendation by the Secretary of the Department of 40 Energy, the President recommended the Yucca Mountain site for the development of a 41 Fuel Cycle Draft NUREG-1437, Supplement 31 6-6 June 2007 repository for the geologic disposal of spent nuclear fuel and high-level nuclear waste. The 1 U.S. Congress approved this recommendation on July 9, 2002, in House Joint Resolution 2 87, which designated Yucca Mountain as the repository for spent nuclear waste. On 3 July 23, 2002, the President signed House Joint Resolution 87 into law; Public Law 107-200, 4 116 Stat. 735 (2002) designates Yucca Mountain as the repository for spent nuclear waste.

5 This development does not represent new and significant information with respect to the 6 offsite radiological impacts from license renewal related to disposal of spent nuclear fuel and 7 high-level nuclear waste.

8 EPA developed Yucca Mountain-specific repository standards, which were subsequently 9 adopted by the NRC in 10 CFR Part 63. In an op inion, issued July 9, 2004, the U.S. Court 10 of Appeals for the District of Columbia Circuit (the Court) vacated EPA's radiation protection 11 standards for the candidate repository, which required compliance with certain dose limits 12 over a 10,000-year period. The Court's decision also vacated the compliance period in 13 NRC's licensing criteria for the candidate repository in 10 CFR Part 63. In response to the 14 Court's decision, EPA issued its proposed revised standards on August 22, 2005 15 (70 Federal Register [FR] 49014). In order to be consistent with EPA's revised standards, 16 NRC proposed revisions to 10 CFR Part 63 on September 8, 2005 (70 FR 53313).

17 Therefore, for the high-level waste and spent fuel disposal component of the fuel cycle, 18 there is some uncertainty with respect to regulatory limits for offsite releases of radioactive 19 nuclides for the current candidate repository site. However, prior to promulgation of the 20 affected provisions of the Commission's r egulations, we assumed that limits would be 21 developed along the lines of the 1995 NAS report, Technical Bases for Yucca Mountain 22 Standards (NAS 1995), and that in accordance with the Commission's Waste Confidence 23 Decision, 10 CFR 51.23, a repository that would comply with such limits could and likely 24 would be developed at some site.

25 Despite the current uncertainty with respect to these rules, some judgment as to the 26 regulatory NEPA implications of offsite radiological impacts of spent fuel and high-level 27 waste disposal should be made. The NRC st aff concludes that these impacts are 28 acceptable in that the impacts would not be sufficiently large to require the NEPA conclusion 29 that the option of extended operation under 10 CFR Part 54 should be eliminated.

30 The NRC staff has not identified any new and significant information during its independent 31 review of the JAFNPP ER (Entergy 2006), the staff's site audit, the scoping process, or its 32 evaluation of other available information. Ther efore, the NRC staff concludes that there are 33 no offsite radiological impacts related to spent fuel and HLW disposal during the renewal 34 term beyond those discussed in the GEIS.

35 Fuel Cycle June 2007 6-7 Draft NUREG-1437, Supplement 31 Nonradiological impacts of the uranium fuel cycle. Based on information in the GEIS, the 1 Commission found that 2 The nonradiological impacts of the uranium f uel cycle resulting from the renewal 3 of an operating license for any plant are found to be small.

4 The NRC staff has not identified any new and significant information during its independent 5 review of the JAFNPP ER (Entergy 2006), the staff's site audit, the scoping process, or its 6 evaluation of other available information. Ther efore, the NRC staff concludes that there are 7 no nonradiological impacts of the uranium fuel cycle during the renewal term beyond those 8 discussed in the GEIS.

9 Low-level waste storage and disposal. Based on information in the GEIS, the Commission 10 found that 11 The comprehensive regulatory controls that are in place and the low public doses 12 being achieved at reactors ensure that the radiological impacts to the 13 environment will remain small during the term of a renewed license. The 14 maximum additional on-site land that may be required for low-level waste storage 15 during the term of a renewed license and associated impacts will be small.

16 Nonradiological impacts on air and water will be negligible. The radiological and 17 nonradiological environmental impacts of long-term disposal of low-level waste 18 from any individual plant at licensed sites are small. In addition, the Commission 19 concludes that there is reasonable assurance that sufficient low-level waste 20 disposal capacity will be made available when needed for facilities to be 21 decommissioned consistent with NRC decommissioning requirements.

22 The NRC staff has not identified any new and significant information during its independent 23 review of the JAFNPP ER (Entergy 2006), the staff's site audit, the scoping process, or its 24 evaluation of other available information. Ther efore, the NRC staff concludes that there are 25 no impacts of low-level waste storage and disposal associated with the renewal term 26 beyond those discussed in the GEIS.

27 Mixed waste storage and disposal. Based on information in the GEIS, the Commission 28 found that 29 The comprehensive regulatory controls and the facilities and procedures that are 30 in place ensure proper handling and storage, as well as negligible doses and 31 exposure to toxic materials for the public and the environment at all plants.

32 License renewal will not increase the small, continuing risk to human health and 33 the environment posed by mixed waste at all plants. The radiological and 34 nonradiological environmental impacts of long-term disposal of mixed waste from 35 Fuel Cycle Draft NUREG-1437, Supplement 31 6-8 June 2007 any individual plant at licensed sites are small. In addition, the Commission 1 concludes that there is reasonable assurance that sufficient mixed waste 2 disposal capacity will be made available when needed for facilities to be 3 decommissioned consistent with NRC decommissioning requirements.

4 The NRC staff has not identified any new and significant information during its independent 5 review of the JAFNPP ER (Entergy 2006), the staff's site audit, the scoping process, or its 6 evaluation of other available information. Ther efore, the NRC staff concludes that there are 7 no impacts of mixed waste storage and disposal associated with the renewal term beyond 8 those discussed in the GEIS.

9 Onsite spent fuel. Based on information in the GEIS, the Commission found that 10 The expected increase in the volume of spent fuel from an additional 20 years of 11 operation can be safely accommodated on site with small environmental effects 12 through dry or pool storage at all plants if a permanent repository or monitored 13 retrievable storage is not available.

14 The NRC staff has not identified any new and significant information during its independent 15 review of the JAFNPP ER (Entergy 2006), the staff's site audit, the scoping process, or its 16 evaluation of other available information. Ther efore, the NRC staff concludes that there are 17 no impacts of onsite spent fuel associated with license renewal beyond those discussed in 18 the GEIS.

19 Nonradiological waste. Based on information in the GEIS, the Commission found that 20 No changes to generating systems are anticipated for license renewal. Facilities 21 and procedures are in place to ensure continued proper handling and disposal at 22 all plants.

23 The NRC staff has not identified any new and significant information during its independent 24 review of the JAFNPP ER (Entergy 2006), the staff's site audit, the scoping process, or its 25 evaluation of other available information. Ther efore, the NRC staff concludes that there are 26 no nonradiological waste impacts during the renewal term beyond those discussed in the 27 GEIS. 28 Transportation. Based on information contained in the GEIS, the Commission found that 29 The impacts of transporting spent fuel enriched up to 5 percent uranium-235 with 30 average burnup for the peak rod to current levels approved by NRC up to 31 62,000 MWd/MTU [megawatt days per metric ton of uranium] and the cumulative 32 impacts of transporting high-level waste to a single repository, such as Yucca 33 Mountain, Nevada are found to be consistent with the impact values contained in 34 10 CFR 51.52)(c), Summary Table S-4-Environmental Impact of Transportation 35 Fuel Cycle June 2007 6-9 Draft NUREG-1437, Supplement 31 of Fuel and Waste to and from One Light-Water-Cooled Nuclear Power Reactor.

1 If fuel enrichment or burnup conditions are not met, the applicant must submit an 2 assessment of the implications for the environmental impact values reported in 3 §51.52. 4 JAFNPP meets the fuel-enrichment and burnup conditions set forth in Addendum 1 to the 5 GEIS (NRC 1999). The NRC staff has not identified any new and significant information 6 during its independent review of the JAFNPP ER (Entergy 2006), the staff's site audit, the 7 scoping process, or its evaluation of other available information. Therefore, the NRC staff 8 concludes that there are no impacts of transportation associated with license renewal 9 beyond those discussed in the GEIS.

10 6.2 References 11 10 CFR Part 51.

Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 12 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

13 10 CFR Part 54.

Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for 14 Renewal of Operating Licenses for Nuclear Power Plants."

15 10 CFR Part 63.

Code of Federal Regulations, Title 10, Energy, Part 63, "Disposal of High-16 Level Radioactive Wastes in a Geologic Repository at Yucca Mountain, Nevada."

17 40 CFR Part 191.

Code of Federal Regulations, Title 40, Protection of Environment, Part 191, 18 "Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear 19 Fuel, High-Level and Transuranic Radioactive Waste."

20 70 FR 53313. 70 Federal Register 53313. 2005, September 8. "Implementation of a Dose 21 Standard After 10,000 Years; Proposed Rule."

22 70 FR 49014. 70 Federal Register 49014. 2005, August 22. "Public Health and Environmental 23 Radiation Protection Standards for Yucca Mountain, Nevada; Proposed Rule."

24 Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2006.

25 James A. FitzPatrick Nuclear Power Plant - License Renewal Application, Appendix E:

26 Applicant's Environmental Report, Operating License Renewal Stage.

Lycoming, New York.

27 Accessible at ML062160557.

28 National Academy of Sciences (NAS). 1995. Technical Bases for Yucca Mountain Standards.

29 National Academy Press, Washington, D.C.

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

31 Fuel Cycle Draft NUREG-1437, Supplement 31 6-10 June 2007 Public Law 107-200, 116 Stat. 735. 2002. "Approving the site at Yucca Mountain, Nevada, for 1 the development of a repository for the disposal of high-level radioactive waste and spent 2 nuclear fuel, pursuant to the Nuclear Waste Policy Act of 1982."

3 U.S. Department of Energy (DOE). 1980. Final Environmental Impact Statement: Management 4 of Commercially Generated Radioactive Waste. DOE/EIS-0046F, Washington, D.C.

5 U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement 6 for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2. Office of Nuclear 7 Regulatory Research, Washington, D.C.

8 U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement 9 for License Renewal of Nuclear Plants NUREG-1437, Volume 1, Addendum 1. Office of 10 Nuclear Regulatory Research, Washington, D.C.

11 June 2007 7-1 Draft NUREG-1437, Supplement 31 7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING 1 Environmental impacts from the activities associated with the decommissioning of any reactor 2 before or at the end of an initial or renewed license are evaluated in the Generic Environmental 3 Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the 4 Decommissioning of Nuclear Power Reactors, NUREG-0586, Supplement 1 (NRC 2002). The 5 NRC staff's evaluation of the environmental impacts of decommissioning presented in NUREG-6 0586, Supplement 1, identifies a range of impacts for each environmental issue.

7 The incremental environmental impacts associated with decommissioning activities resulting 8 from continued plant operation during the renewal term are discussed in the Generic 9 Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, 10 Volumes 1 and 2 (NRC 1996; 1999).

(1) The GEIS includes a determination of whether the 11 analysis of the environmental issue could be applied to all plants and whether additional 12 mitigation measures would be warranted. Issues were then assigned a Category 1 or a 13 Category 2 designation. As set forth in the GEIS, Category 1 issues are those that meet all of 14 the following criteria:

15 (1) The environmental impacts associated wi th the issue have been determined to apply 16 either to all plants or, for some issues, to plants having a specific type of cooling system 17 or other specified plant or site characteristics.

18 (2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 19 the impacts (except for collective off-site radiological impacts from the fuel cycle and 20 from high level waste and spent fuel disposal).

21 (3) Mitigation of adverse impacts associated with the issue has been considered in the 22 analysis, and it has been determined that additional plant-specific mitigation measures 23 are likely not to be sufficiently beneficial to warrant implementation.

24 For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 25 required unless new and significant information is identified.

26 Category 2 issues are those that do not meet one or more of the criteria for Category 1, and 27 therefore, additional plant-specific review of these issues is required. There are no Category 2 28 issues related to decommissioning.

29 (1) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" include the GEIS and its Addendum 1.

Environmental Impacts of Decommissioning Draft NUREG-1437, Supplement 31 7-2 June 2007 7.1 Decommissioning 1 Category 1 issues in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B that are applicable to 2 James A. FitzPatrick Nuclear Power Plant (JAFNPP) decommissioning following the renewal 3 term are listed in Table 7-1. Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operation, 4 Inc. (Entergy) stated in its Environmental Report (ER; Entergy 2006) that it is aware of no new 5 and significant information regarding the environmental impacts of JAFNPP license renewal.

6 The NRC staff has not identified any new and significant information during its independent 7 review of the JAFNPP ER (Entergy 2006), the staff's site audit, the scoping process, or its 8 evaluation of other available information. Ther efore, the NRC staff concludes that there are no 9 impacts related to these issues beyond those discussed in the GEIS. For all of these issues, 10 the NRC staff concluded in the GEIS that the impacts are SMALL, and additional plant-specific 11 mitigation measures are not likely to be sufficiently beneficial to be warranted.

12 Table 7-1. Category 1 Issues Applicable to the Decommissioning of JAFNPP 13 Following the Renewal Term 14 ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section DECOMMISSIONING Radiation Doses 7.3.1; 7.4 Waste Management 7.3.2; 7.4 Air Quality 7.3.3; 7.4 Water Quality 7.3.4; 7.4 Ecological Resources 7.3.5; 7.4 Socioeconomic Impacts 7.3.7; 7.4 15 A brief description of the NRC staff's review and the GEIS conclusions, as codified in Table B-1, 16 for each of the issues follows:

17 Radiation doses. Based on information in the GEIS, the Commission found that 18 Doses to the public will be well below applicable regulatory standards regardless 19 of which decommissioning method is used. Occupational doses would increase 20 no more than 1 man-rem caused by buildup of long-lived radionuclides during the 21 license renewal term.

22 The NRC staff has not identified any new and significant information during its independent 23 review of the JAFNPP ER (Entergy 2006), the staff's site audit, the scoping process, or its 24 evaluation of other available information. Ther efore, the NRC staff concludes that there are 25 Environmental Impacts of Decommissioning June 2007 7-3 Draft NUREG-1437, Supplement 31 no radiation dose impacts associated with decommissioning following the license renewal 1 term beyond those discussed in the GEIS.

2 Waste management. Based on information in the GEIS, the Commission found that 3 Decommissioning at the end of a 20-year license renewal period would generate 4 no more solid wastes than at the end of the current license term. No increase in 5 the quantities of Class C or greater than Class C wastes would be expected.

6 The NRC staff has not identified any new and significant information during its independent 7 review of the JAFNPP ER (Entergy 2006), the staff's site audit, the scoping process, or its 8 evaluation of other available information. Ther efore, the NRC staff concludes that there are 9 no impacts from solid waste associated with decommissioning following the license renewal 10 term beyond those discussed in the GEIS.

11 Air quality. Based on information in the GEIS, the Commission found that 12 Air quality impacts of decommissioning are expected to be negligible either at the 13 end of the current operating term or at the end of the license renewal term.

14 The NRC staff has not identified any new and significant information during its independent 15 review of the JAFNPP ER (Entergy 2006), the staff's site audit, the scoping process, or its 16 evaluation of other available information. Ther efore, the NRC staff concludes that there are 17 no impacts on air quality associated with decommissioning following the license renewal 18 term beyond those discussed in the GEIS.

19 Water quality. Based on information in the GEIS, the Commission found that 20 The potential for significant water quality impacts from erosion or spills is no 21 greater whether decommissioning occurs after a 20-year license renewal period 22 or after the original 40-year operation period, and measures are readily available 23 to avoid such impacts.

24 The NRC staff has not identified any new and significant information during its independent 25 review of the JAFNPP ER (Entergy 2006), the staff's site audit, the scoping process, or its 26 evaluation of other available information. Ther efore, the NRC staff concludes that there are 27 no impacts on water quality associated with decommissioning following the license renewal 28 term beyond those discussed in the GEIS.

29 Ecological resources. Based on information in the GEIS, the Commission found that 30 Decommissioning after either the initial operating period or after a 20-year 31 license renewal period is not expected to have any direct ecological impacts.

32 Environmental Impacts of Decommissioning Draft NUREG-1437, Supplement 31 7-4 June 2007 The NRC staff has not identified any new and significant information during its independent 1 review of the JAFNPP ER (Entergy 2006), the staff's site audit, the scoping process, or its 2 evaluation of other available information. Ther efore, the NRC staff concludes that there are 3 no impacts on ecological resources associated with decommissioning following the license 4 renewal term beyond those discussed in the GEIS.

5 Socioeconomic Impacts. Based on information in the GEIS, the Commission found that 6 Decommissioning would have some short-term socioeconomic impacts. The 7 impacts would not be increased by delaying decommissioning until the end of a 8 20-year relicense period, but they might be decreased by population and 9 economic growth.

10 The NRC staff has not identified any new and significant information during its independent 11 review of the JAFNPP ER (Entergy 2006), the staff's site audit, the scoping process, or its 12 evaluation of other available information. Ther efore, the NRC staff concludes that there are 13 no socioeconomic impacts associated with decommissioning following the license renewal 14 term beyond those discussed in the GEIS.

15 7.2 References 16 10 CFR Part 51.

Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 17 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

18 Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2006.

19 James A. FitzPatrick Nuclear Power Plant - License Renewal Application, Appendix E: -

20 Applicant's Environmental Report, Operating License Renewal Stage.

Lycoming, New York.

21 Accessible at ML062160557.

22 U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement 23 for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Office of Nuclear 24 Regulatory Research, Washington, D.C.

25 U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement 26 for License Renewal of Nuclear Plants, Main Report. NUREG-1437, Volume 1, Addendum 1.

27 Office of Nuclear Regulatory Research, Washington, D.C.

28 U.S. Nuclear Regulatory Commission (NRC). 2002. Generic Environmental Impact Statement 29 on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of 30 Nuclear Power Reactors. NUREG-0586, Supplement 1, Volumes 1 and 2. Washington, D.C.

31 June 2007 8-1 Draft NUREG-1437, Supplement 31 8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES 1 TO LICENSE RENEWAL 2 This chapter examines the potential environmental impacts associated with denying the renewal 3 of an operating license (OL) (i.e., the no-acti on alternative) and the potential environmental 4 impacts from electric power generating sources other than the James A. FitzPatrick Nuclear 5 Power Plant (JAFNPP); the possibility of purchasing electric power from other sources to 6 replace power generated by JAFNPP and the associated environmental impacts; the potential 7 environmental impacts from a combination of generation and conservation measures; and other 8 generation alternatives that were deemed unsuitable for complete replacement of power 9 generated by JAFNPP. The environmental impacts are evaluated using the U.S. Nuclear 10 Regulatory Commission's (NRC's) three-level standard of significance-SMALL, MODERATE, 11 or LARGE-developed using the Council on Environmental Quality guidelines and set forth in 12 the footnotes to Table B-1 of Part 51 of Title 10 of the Code of Federal Regulations (10 CFR 13 Part 51), Subpart A, Appendix B:

14 SMALL - Environmental effects are not detectable or are so minor that they will neither 15 destabilize nor noticeably alter any important attribute of the resource.

16 MODERATE - Environmental effects are sufficient to alter noticeably, but not to destabilize 17 important attributes of the resource.

18 LARGE - Environmental effects are clearly noticeable and are sufficient to destabilize 19 important attributes of the resource.

20 The impact categories evaluated in this chapter are the same as those used in the Generic 21 Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS) NUREG-1437, 22 Volumes 1 and 2 (NRC 1996; 1999)

(1) with the additional impact category of environmental 23 justice. 24 8.1 No-Action Alternative 25 The NRC's regulations implementing the National Environmental Policy Act (NEPA) of 1969 26 specify that the no-action alternative be discussed in an NRC environmental impact statement 27 (EIS); see 10 CFR Part 51, Subpart A, Appendix A(4). For license renewal, the no-action 28 alternative refers to a scenario in which the NRC would not renew the JAFNPP OL and JAFNPP 29 (1) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" include the GEIS and its Addendum 1.

Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-2 June 2007 would then cease facility operations by the end of the current license and initiate the 1 decommissioning of the power plant.

2 JAFNPP will eventually be required to shut down and to comply with NRC decommissioning 3 requirements in 10 CFR 50.82 whether or not the OL is renewed. If the JAFNPP OL is 4 renewed, shutdown of the unit and decommissioning activities will not be avoided but will be 5 postponed for up to an additional 20 years.

6 The environmental impacts associated with decommissioning following a license renewal period 7 of up to 20 years or following the no-action alternative would be bounded by the discussion of 8 impacts in Chapter 7 of the GEIS; Chapter 7 of this draft supplemental environmental impact 9 statement (draft SEIS); and the Final Generic Environmental Impact Statement on 10 Decommissioning of Nuclear Facilities, NUREG-0586, Supplement 1 (NRC 2002). The impacts 11 of decommissioning after 60 years of operation ar e not expected to be significantly different 12 from those occurring after 40 years of operation.

13 Impacts from the decision to permanently cease operations are not considered in NUREG-0586, 14 Supplement 1 (NRC 2002).

(2) Therefore, immediate impacts that occur between power plant 15 shutdown and the beginning of decommissioning are considered here. These impacts will occur 16 when the unit shuts down regardless of whether the license is renewed or not. These impacts 17 are discussed below, with the results presented in Table 8-1. Power plant shutdown will result 18 in a net reduction in power production capacity. The power not generated by JAFNPP during 19 the license renewal term would likely be replaced by (1) power purchased from other electricity 20 providers, (2) generating alternatives other than JAFNPP, (3) demand-side management and 21 energy conservation, or (4) some combination of these options. The environmental impacts of 22 these options are discussed in Section 8.2.

23 Land Use 24 In Chapter 4 of this draft SEIS, the NRC staff concluded that there would be no impacts of 25 continued power plant operation on land use. Onsite land use would not be affected 26 immediately by the cessation of operations. Power plant structures and other facilities are 27 likely to remain in place until decommissioning. The transmission lines associated with the 28 project are expected to remain in service after the power plant stop operating. As a result, 29 maintenance of the rights-of-way (ROWs) would continue as before. Therefore, there would 30 be no impacts on land use from power plant shutdown.

31 (2) NUREG-0586 Supplement 1 discusses the socioeconomic impacts of plant closure, but the results of the analysis in Appendix J are not incorporated in the analysis presented in the main body of the NUREG.

Environmental Impacts of Alternatives June 2007 8-3 Draft NUREG-1437, Supplement 31 Table 8-1. Summary of Environmental Impacts of the No-Action Alternative 1 Impact Category Impact Comment Land Use NO IMPACT No impacts because power plant shutdown is not expected to result in changes to onsite or offsite land use. Ecology SMALL Impacts are expected to be SMALL because there would be a reduction in cooling water flow and the thermal plume from the power plant, and terrestrial impacts are not expected because there would not be any land-use changes. Water Use and Quality -

Surface Water SMALL Impacts are expected to be SMALL because surface water intake and discharges would decrease. Water Use and Quality -

Groundwater NO IMPACT There is no groundwater use at the site. Air Quality SMALL Impacts are expected to be SMALL because discharges related to power plant operation and worker transportation would decrease. Waste SMALL Impacts are expected to be SMALL because generation of high-level waste would stop, and generation of low-level and mixed waste would decrease. Human Health SMALL Impacts are expected to be SMALL because radiological doses to workers and members of the public, which are within regulatory limits, would be reduced. Socioeconomics MODERATE to LARGE Impacts are expected to be MODERATE to LARGE because of a decrease in employment and tax revenues to local jurisdictions. Transportation SMALL Transportation impacts would be SMALL because the decrease in employment would reduce traffic. Aesthetics NO IMPACT No impacts are expected because power plant structures would remain in place. Historic and Archaeological Resources SMALL Impacts are expected to be SMALL because shutdown of the power plant would not change land use. Environmental Justice SMALL to LARGE Economic impacts are expected to be SMALL to LARGE because loss of employment opportunities is expected.

Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-4 June 2007 Ecology 1 In Chapter 4 of this draft SEIS, the NRC staff concluded that the ecological impacts of power 2 plant operation were SMALL. Cessation of operations would be accompanied by a 3 reduction in cooling water flow and the thermal plume from the power plant.

4 The impact of power plant closure on the terrestrial ecosystem would be negligible because 5 the transmission lines to the power plant would remain energized. Therefore, the NRC staff 6 concludes that ecological impacts from shutdown of the power plant would be SMALL.

7 Water Use and Quality-Surface Water 8 In Chapter 4 of this draft SEIS, the NRC staff concluded that impacts of power plant 9 operation on surface water use and quality were SMALL. When the power plant stops 10 operating, there would be an immediate reduction in the consumptive use of water because 11 of reduction in cooling water flow and in the amount of heat transferred to Lake Ontario.

12 Therefore, the NRC staff concludes that the impacts on surface water use and quality from 13 power plant shutdown would be SMALL.

14 Water Use and Quality-Groundwater 15 In Chapter 4 of this draft SEIS, the NRC staff concluded that there would be no impacts on 16 groundwater use, availability, and quality. Ther efore, the NRC staff concludes that there 17 would be no impact on groundwater use and quality from shutdown of the power plant.

18 Air Quality 19 In Chapter 4 of this draft SEIS, the NRC staff found the impacts of power plant operation on 20 air quality were SMALL. When the power plant stops operating, there would be a reduction 21 in emissions from activities related to power plant operation such as use of diesel 22 generators and worker transportation. Therefore, the NRC staff concludes that the impact 23 on air quality from shutdown of the power plant would be SMALL.

24 Waste 25 The impacts of waste generated by power plant operation are discussed in Chapter 6 of this 26 draft SEIS. The impacts of low-level and mixed waste from power plant operation would be 27 SMALL. When the power plant stops operating, the power plant would stop generating 28 high-level waste, and the generation of low-level and mixed waste associated with power 29 plant operation and maintenance would be reduced. Therefore, the NRC staff concludes 30 that the impact of waste generated after shutdown of the power plant would be SMALL.

31 Environmental Impacts of Alternatives June 2007 8-5 Draft NUREG-1437, Supplement 31 Human Health 1 In Chapter 4 of this draft SEIS, the NRC staff concluded that the impacts of power plant 2 operation on human health were SMALL. After the cessation of operations, the amount of 3 radioactive material released to the environment in gaseous and liquid forms would be 4 reduced. Therefore, the NRC staff concludes that the impact of shutdown of the power plant 5 on human health would be SMALL. In addition, the variety of potential accidents at the 6 power plant would be reduced to a limited set associated with shutdown events and spent 7 fuel handling. In Chapter 5 of this draft SEIS, the NRC staff concluded that the impacts of 8 accidents during operation were SMALL. Ther efore, the NRC staff concludes that the 9 impacts of potential accidents following shutdown of the power plant would be SMALL.

10 Socioeconomics 11 In Chapter 4 of this draft SEIS, the NRC staff concluded that there would be no 12 socioeconomic impacts of continued power plant operation. Conversely, there would be 13 immediate socioeconomic impacts associated with the shutdown of the power plant because 14 of the reduction in power plant staff. There would also be an immediate reduction in 15 property tax revenues for Oswego County. The NRC staff concludes that the 16 socioeconomic impacts of power plant shutdown would range from MODERATE to LARGE.

17 Some of these impacts would be offset if new power-generating facilities were built at or 18 near the current site. See Appendix J of NUREG-0586, Supplement 1 (NRC 2002), for 19 additional discussion of the potential impacts of power plant shutdown.

20 Transportation 21 In Chapter 4 of this draft SEIS, the NRC staff concluded that the impacts of continued power 22 plant operation on transportation would be SMALL. Cessation of operations would be 23 accompanied by a reduction in traffic in the vicinity of the power plant. Most of the reduction 24 would be associated with a reduction in the power plant workforce but there would also be a 25 reduction in shipment of material to and from the power plant. Therefore, the NRC staff 26 concludes that the impacts of power plant closure on transportation would be SMALL.

27 Aesthetics 28 In Chapter 4 of this draft SEIS, the NRC staff concluded that there would be no aesthetic 29 impacts of continued power plant operation. Power plant structures and other facilities 30 would remain in place until decommissioning. Therefore, there would be no aesthetic 31 impacts from power plant closure.

32 Historic and Archaeological Resources 33 In Chapter 4 of this draft SEIS, the NRC staff concluded that the impacts of continued power 34 plant operation on historic and archaeological resources would be SMALL. Onsite land use 35 Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-6 June 2007 would not be affected immediately by the cessation of operations. Power plant structures 1 and other facilities are likely to remain in place until decommissioning. The transmission 2 lines associated with the project are expected to remain in service after the power plant 3 stops operating. As a result, maintenance of transmission line ROWs would continue as 4 before. Therefore, the NRC staff concludes that the impacts on hist oric and archaeological 5 resources from power plant shutdown would be SMALL.

6 Environmental Justice 7 In Chapter 4 of this draft SEIS, the NRC staff concluded that there would be no 8 disproportionately high and adverse impacts on minority and low-income populations from 9 the continued operation of the power plant. Shutdown of the power plant would have 10 disproportionately high and adverse economic impacts on minority and low-income 11 populations because of the loss of employment opportunities at the site. The NRC staff 12 concludes that the impacts of power plant shutdown on minority and low-income populations 13 could range from SMALL to LARGE. Some of these impacts would be offset if new power-14 generating facilities are built at or near the current site. See Appendix J of NUREG-0586, 15 Supplement 1 (NRC 2002), for additional discussion of these impacts.

16 8.2 Alternative Energy Sources 17 This section discusses the environmental impacts associated with alternative sources of electric 18 power to replace the power generated by JAFNPP, assuming that the OL is not renewed. The 19 order of presentation of alternative energy sources in this section does not imply which 20 alternative would be most likely to occur or would have the least environmental impact.

21 The following power generation alternatives are considered in detail:

22 Coal-fired generation at an alternate site (Section 8.2.1) 23 Natural gas-fired generation at the JAFNPP site and an alternate site (Section 8.2.2) 24 New nuclear generation at the JAFNPP site and an alternate site (Section 8.2.3) 25 The alternative of purchasing power from other sources to replace power generated at JAFNPP 26 is discussed in Section 8.2.4. Other power-generation alternatives and conservation 27 alternatives considered by the NRC staff and found not to be reasonable replacements for 28 JAFNPP baseload power is discussed in Section 8.2.5. Section 8.2.6 discusses the 29 environmental impacts of a combination of generation and conservation alternatives.

30 Each year the Energy Information Administration (EIA), a component of the U.S. Department of 31 Energy (DOE), issues an Annual Energy Outlook. The Annual Energy Outlook 2007 with 32 Projections to 2030 was issued in February 2007 (DOE/EIA 2007). EIA projects that natural 33 Environmental Impacts of Alternatives June 2007 8-7 Draft NUREG-1437, Supplement 31 gas-fired and coal-fired electricity generation will constitute approximately 90 percent of 1 electrical capacity additions between 2006 and 2030. Natural gas-fired generation is typically 2 based on combined-cycle (3) or combustion turbine technology, which can supply peak and 3 intermediate capacity and can also be used to meet baseload (4) requirements. Coal-fired power 4 plants are generally used to meet baseload requirements. Renewable energy sources, 5 including conventional hydroelectric, geothermal, wood, wood waste, municipal solid waste, 6 landfill gas, other biomass, solar and wind power are projected by EIA to account for 6 percent 7 of capacity additions (DOE/EIA 2007).

8 EIA projects that oil-fired generation will continue to decrease in the U.S. through 2030 because 9 high world oil prices encourage switching from oil-fired generation to natural gas and nuclear 10 power and reinforce coal's important role in world electric power generation. Similarly, the 11 relatively high fossil fuel prices of recent years are raising renewed interest in nuclear power 12 and making renewable energy sources more compet itive economically. EIA's projections are 13 based on the assumption that providers of new generating capacity will seek to minimize cost 14 while meeting applicable environmental requirements. The cost of new oil-fired generation is 15 not expected to be competitive with that of coal, natural gas, or renewable energy sources 16 (DOE/EIA 2007).

17 EIA also projects a small increase in nuclear power generation through 2030, accounting for 18 0.6 percent of the generation growth (DOE/EIA 2007). The projected growth in nuclear power 19 generation is not higher because natural gas and coal-fired power plants are projected to be 20 more economical. In spite of this projection, since 1997, the NRC has certified four new 21 standard designs for nuclear power plants under procedures in 10 CFR Part 52, Subpart B.

22 Therefore, a new nuclear power plant alternative for replacing power generated by JAFNPP is 23 considered in Section 8.2.3. The submission to the NRC of these three applications for 24 certification indicates continuing interest in the possibility of licensing new nuclear power plants.

25 The NRC has established a new organization to prepare for and manage future reactor and site 26 licensing applications.

27 JAFNPP has a gross rating of 881 megawatts-electric (MWe). For the coal alternative, the NRC 28 staff assumed construction of an 816-MWe power plant. For the natural gas alternative, the 29 NRC staff assumed construction of an 816-MWe power plant, which is consistent with the 30 James A. FitzPatrick Nuclear Power Plant - License Renewal Application, Appendix E:

31 Applicant's Environmental Report, Operating License Renewal Stage (JAFNPP ER) (Entergy 32 (3) In a combined-cycle unit, hot combustion gas in a combustion turbine rotates the turbine to generate electricity. The hot exhaust from the combustion turbine is routed through a heat-recovery boiler to make steam to generate additional electricity. (4) A baseload plant normally operates to supply all or part of the minimum continuous load of a system and consequently produces electricity at an essentially constant rate. Nuclear power plants are commonly used for baseload generation, i.e., these units generally run near full load.

Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-8 June 2007 2006). For the new nuclear alternative, the NRC staff assumed construction of a 1000-MWe 1 power plant. This assumption will overstate the environmental impacts of replacing the 881 2 MWe from JAFNPP by roughly 13.5 percent.

3 8.2.1 Coal-Fired Power Generation 4 The NRC staff believes that the JAFNPP site would not be a viable location for a representative 5 coal-fired power plant. The primary consideration pertinent to this determination is the size of 6 the JAFNPP site. Use of the site would necessitate offsite disposal of combustion waste.

7 Therefore, the NRC staff assumes that the r epresentative coal-fired power plant would be 8 located at an alternate site.

9 Consistent with the JAFNPP ER, the NRC staff assumes construction of two 408-MWe units for 10 a combined capacity of 816 MWe as a potential replacement for JAFNPP. The assumption of 11 816 MWe is slightly less generating capacity than JAFNPP's capacity of 881 MWe, but the NRC 12 staff concludes that the differences are not significant and would not change the standard of 13 significance (SMALL, MODERATE, or LARGE) of any impacts.

14 Unless otherwise indicated, the assumptions and numerical values used in Section 8.2.1 are 15 from the JAFNPP ER (Entergy 2006). The NRC st aff reviewed this information and compared it 16 to environmental impact information in the GEIS. Although the OL renewal period is only 17 20 years, the impact of operating the coal-fired alternative for 40 years is considered as a 18 reasonable projection of the operating life of a coal-fired power plant.

19 The coal-fired power plant would consume approximately 2.36 million tons per year (tons/yr) of 20 pulverized bituminous coal with an ash content of approximately 7.11 percent (Entergy 2006).

21 JAFNPP assumes a heat rate (5) of 10,200 BTU/kWh and a capacity factor (6) of 0.85 in its ER 22 (Entergy 2006). After combustion, 99.9 percent of the ash would be collected and disposed at 23 either an onsite or offsite landfill. In addition, approximately 136,995 tons of scrubber sludge 24 would be disposed of at the power plant site based on annual limestone usage of approximately 25 46,241 tons. Limestone is used in the scrubbing process for control of sulfur dioxide (SO

2) 26 emissions.

27 (5) Heat rate is measure of generating station thermal efficiency. In English units, it is generally expressed in British thermal units (BTUs) per net kilowatt-hour (kWh). It is computed by dividing the total BTU content of the fuel burned for electric generation by the resulting kWh generation. The corresponding metric unit for energy is the Joule (J). (6) The capacity factor is the ratio of electricity generated, for the period of time considered, to the energy that would have been generated at continuous full-power operation during the same period.

Environmental Impacts of Alternatives June 2007 8-9 Draft NUREG-1437, Supplement 31 8.2.1.1 Once-Through Cooling System 1 For purposes of this section, the NRC staff assu med that a coal-fired power plant located at an 2 alternate site would use a once-through cooling system. The overall impacts of the coal-fired 3 generating system using once-through cooling are discussed in this section and summarized in 4 Table 8-2. The extent of impacts at an alternate site would depend on the location of the site.

5 In Section 8.2.1.2, the NRC staff evaluates the im pacts of using a closed-cycle cooling system 6 at an alternate site.

7 Land Use 8 Development of the coal-fired power plant would require approximately 1387 acres (ac) of 9 land for the power plant site. Additional land would be necessary to allow for an onsite and 10 peripheral buffer. The NRC estimates that 1700 ac would be required for a 1000-MWe 11 power plant. Depending on the location of the power plant, additional land would be 12 required for offsite infrastructure, particularly transmission lines to connect the power plant to 13 the grid and facilities for coal and limestone delivery, most likely including a rail spur and 14 possibly some upgrades to existing or recently abandoned rail lines. Construction of a 15 barge terminal would also be a reasonable option for a power plant located on Lake Ontario.

16 Land-use changes would also occur offsite in an undetermined coal-mining area to supply 17 coal for the power plant. In the GEIS, the NRC staff estimated that approximately 22 ac of 18 land per MWe would be affected for mining the coal and disposing of the waste to support a 19 coal-fired power plant during its operational life. Therefore, the 816-MWe power plant 20 proposed in this analysis would require approximately 17,592 ac of land to support the entire 21 fuel cycle.

22 The location and design of coal-fired power plant facilities at an alternate site would be 23 subject to substantial regulatory scrutiny and that a reasonable potential exists for the 24 eventual restoration of disposal areas and the development of compatible uses that would 25 not affect landfill integrity (e.g., recreation). Under these assumptions, the NRC staff 26 expects that land-use impacts would be noticeable but would not affect land-use 27 characteristics at an existing industrial site. Depending particularly on transmission line and 28 rail line routing, this alternative would result in MODERATE to LARGE land-use impacts.

29 Ecology 30 Impacts on ecological resources from construction and from operation of the representative 31 coal-fired power plant would be highly site-specific. However, as much as 1387 ac of 32 terrestrial habitat would be displaced by the power plant and onsite landfill, and additional 33 terrestrial habitat would be adversely affected from development of offsite infrastructure 34 (e.g., transmission line connection, rail spur construction). Impacts would depend on 35 Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-10 June 2007 Table 8-2. Summary of Environmental Impacts of Coal-Fired Generation 1 at an Alternate Site Using Once-Through Cooling 2 Impact Category Impact Comments Land Use MODERATE to LARGE Would use approximately 1387 ac for the power plant roads, parking areas, office buildings, and transmission line. There would be additional land impacts for coal and limestone mining. The total impact would depend on whether the alternate site had been previously disturbed or had existing infrastructure. Ecology MODERATE to LARGE Impacts would depend on whether the site had been previously developed. Factors to consider include location and ecology of the site, transmission line route, and rail spur route. In total, impacts would include habitat degradation, fragmentation, or loss as a result of construction activities and conversion of land to industrial use. Ecological communities might experience reduced productivity and biological diversity from disturbing previously intact land. Water Use And Quality

-Surface Water SMALL to MODERATE Impacts would depend on the volume of water withdrawn and discharged and the characteristics of the surface water body. Water Use and Quality -Groundwater SMALL to MODERATE Impacts would depend on the volume of water withdrawn and discharged and the characteristics of the aquifer. Air Quality MODERATE Sulfur oxides: 2514 tons/yr Nitrogen oxides: 591 tons/yr Particulates: 19 tons/yr of PM 10 Carbon monoxide: 591 tons/yr Small amounts of mercury and other hazardous air pollutants and naturally occurring radioactive materials- mainly uranium and thorium. Total suspended particulates: 84 tons/yr Waste MODERATE Total waste volume would be approximately 136,995 tons/yr of ash and scrubber sludge requiring approximately 161 ac for disposal during the 40-year life of the power plant. Human Health SMALL Impacts are uncertain but considered SMALL in the absence of more quantitative data.

Environmental Impacts of Alternatives June 2007 8-11 Draft NUREG-1437, Supplement 31 1 Table 8-2 (cont.) Impact Category Impact Comments Socioeconomics SMALL to LARGE Impacts are expected to be SMALL to LARGE because of a decrease in employment and tax revenues to local jurisdictions. Transportation SMALL to LARGE Transportation impacts associated with construction could be MODERATE to LARGE. Transportation impacts associated with power plant operations would also be site-dependent and would be SMALL to MODERATE. For rail transportation of coal and lime, the impact would be MODERATE to LARGE. For barge transportation, the impact would be SMALL. Aesthetics SMALL to LARGE Impacts would include visual impairment, construction of new transmission lines, and infrastructure for the delivery of coal and limestone. The impact severity would be dependent on location. Historic and Archaeological

Resources SMALL to MODERATE Building a coal-fired power plant and other support facilities would require cultural resource studies. Impacts would vary depending on location and presence of historic and archaeological resources. Environmental

Justice SMALL to LARGE Impacts to minority and low-income populations would vary depending on the site location of the power plant and other support facilities.

2 whether the site had been previously developed. Factors to consider include location and 3 ecology of the site, transmission line route, and rail spur route. In total, impacts would 4 include habitat degradation, fragmentation, or loss as a result of construction activities and 5 conversion of land to industrial use. Ecological communities might experience reduced 6 productivity and biological diversity from disturbing previously intact land.

7 Impact to aquatic communities as a result of construction would include some permanent 8 alteration of habitat, particularly if a barge terminal were developed for delivery of coal and 9 limestone. Fish and benthic communities would be initially disrupted but would be expected 10 to reestablish with accompanying localized changes in species composition and distribution 11 in response to changes in bottom substrate availability, water depth, and other factors.

12 Potential for some adverse impact on aquatic communities would persist through the 13 operational period as a result of large boat traffic, periodic maintenance dredging, and 14 potential for spills of coal, petroleum products, or other materials. However, construction 15 and maintenance dredging would be conducted in accordance with the provisions of 16 applicable permits from the U.S. Army Corps of Engineers (USACE) and the New York State 17 Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-12 June 2007 Department of Environmental Conservation (NYSDEC). Similarly, spill prevention measures 1 would be effective during the operational period. Once-through cooling water withdrawal 2 and discharge would have adverse aquatic resource impacts.

3 Given this information, the NRC staff concludes that development of the representative coal-4 fired power plant at an alternate site in upstate New York would have a MODERATE to 5 LARGE impact on ecological communities.

6 Water Use and Quality-Surface Water 7 Construction phase impacts on water quality of greatest potential concern at an alternate 8 site would include (1) erosion and sedimentation associated with land-clearing operations, 9 and (2) suspension of bottom sediments during construction of cooling water intake and 10 discharge structures and, if the option were chosen, from construction of barge delivery 11 facilities. However, land-clearing activities are subject to storm-water protections in 12 accordance with the State Pollutant Discharge Elimination System (SPDES) program. Work 13 in waterways would be regulated by the USACE under the Clean Water Act of 1977, 14 Section 404, and the Rivers and Harbors Appropriation Act of 1899, Section 10, by the 15 NYSDEC via permits and by the New York Department of State (NYSDOS) under the 16 State's Coastal Zone Management program (if located within the coastal zone). In addition, 17 these adverse effects would be localized and temporary. The NRC staff concludes that 18 impacts on surface water quality associated with construction of the representative power 19 plant would be SMALL.

20 Potential impacts on water quality and use associated with operation of the representative 21 power plant would be to some extent site-specific. Cooling water and other wastewater 22 discharges would be regulated by a SPDES permit regardless of location. The impact on 23 surface water would depend on the volume of water withdrawn and discharged and the 24 characteristics of the surface water body. The NRC staff concludes that the impacts of 25 surface water use and quality from the operation of a representative power plant located at 26 an alternate site would be SMALL to MODERATE.

27 Water Use and Quality-Groundwater 28 Use of groundwater for a coal-fired power plant at an alternate site is possible.

29 Groundwater withdrawal would require a permit. Overall, the impact to groundwater at an 30 alternate site is considered SMALL to MODERATE and would depend on the volume of 31 water that is withdrawn and discharged and the characteristics of the aquifers.

32 Air Quality 33 The air-quality impacts of coal-fired generation vary considerably from those of nuclear 34 generation due to emissions of sulfur oxides (SO x), nitrogen oxides (NO x), particulates, 35 Environmental Impacts of Alternatives June 2007 8-13 Draft NUREG-1437, Supplement 31 carbon monoxide, hazardous air pollutants such as mercury, and naturally occurring 1 radioactive materials.

2 Oswego County is designated as unclassifiable or in attainment with all criteria pollutants.

3 The nearest area of non-attainment is Jefferson County, which is classified as marginal for 4 ozone. Onondaga County, where Syracuse is located, is a maintenance area for carbon 5 monoxide and classified as moderate, i.e., less than or equal to 12.7 parts per million (ppm).

6 A new coal-fired generating power plant in upstate New York would likely need a prevention 7 of significant deterioration (PSD) permit and an operating permit under the Clean Air Act of 8 1970. The power plant would need to comply with the new source performance standards 9 for such power plants set forth in 40 CFR 60, Subpart D(a). The standards establish limits 10 for particulate matter and opacity (40 CFR 60.42[a]), SO 2 (40 CFR 60.43[a]), and NO x 11 (40 CFR 60.44[a]). The facility would be designed to meet best available control technology 12 (BACT) or lowest achievable emissions rate (LAER) standards, as applicable, for control of 13 criteria air emissions.

14 The U.S. Environmental Protection Agency (EPA) has various regulatory requirements for 15 visibility protection in 40 CFR 51, Subpart P, including a specific requirement for review of 16 any new major stationary source in an area designated as attainment or unclassified under 17 the Clean Air Act.

18 Section 169A of the Clean Air Act (42 USC 7491) establishes a national goal of preventing 19 future and remedying existing impairment of visibility in mandatory Class I Federal areas 20 when impairment results from man-made air pollution. The EPA issued a new regional haze 21 rule in 1999 (64 FR 35714; July 1,1999 [EPA 1999]). The rule specifies that for each 22 mandatory Class I Federal area located within a State, the State must establish goals that 23 provide for reasonable progress towards achi eving natural visib ility conditions. The 24 reasonable progress goals must provide for an improvement in visibility for the most-25 impaired days over the period of the implementation plan and ensure no degradation in 26 visibility for the least-impaired days over the same period [40 CFR 51.308(d)(1)]. If a coal-27 fired power plant were located close to a mandatory Class I Federal area, additional air 28 pollution control requirements would be imposed. It is assumed that an alternate site would 29 not be chosen near a mandatory Class I Federal area.

30 In 1998, the EPA issued a rule requiring 22 Eastern states, including New York, to revise their 31 state implementation plans to reduce NO x emissions, which contribute to violations of the 32 national ambient air quality standard for ozone (EPA 1998). The total amount of NO x that can 33 be emitted by each of the 22 Eastern states in the year 2007 ozone season (May 1 to 34 September 30) is set out at 40 CFR 51.121(e). For New York, the amount is 190,360 tons.

35 Impacts for particular pollutants are as follows:

36 Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-14 June 2007 Sulfur oxides emissions. A new coal-fired power plant would be subject to the 1 requirements in Title IV of the Clean Air Act. Title IV was enacted to reduce emissions of 2 SO 2 and NO x, the two principal precursors of acid rain, by restricting emissions of these 3 pollutants from power plants. Title IV caps aggregate annual power plant SO 2 emissions 4 and imposes controls on SO 2 emissions through a system of marketable allowances. EPA 5 issues one allowance for each ton of SO 2 a unit is allowed to emit. New units do not receive 6 allowances but are required to have allowances to cover their SO 2 emissions. Owners of 7 new units must therefore acquire allowances from owners of other power plants by 8 purchasing them or reducing SO 2 emissions at other power plants they own. Allowances 9 can be banked for use in future years. Thus, a new coal-fired power plant would not add to 10 net regional SO 2 emissions, although it might do so locally. Regardless, SO 2 emissions 11 would be greater for the coal alternative than the OL renewal alternative because a nuclear 12 power plant releases negligible amounts of SO 2 during normal operations.

13 Entergy estimates that by using the BACT to minimize SO x emissions, the total annual stack 14 emissions would be approximately 2514 tons of SO x (Entergy 2006).

15 Nitrogen oxides emissions. Section 407 of the Clean Air Act establishes technology-16 based emission limitations for NO x emissions. The market-based allowance system used 17 for SO 2 emissions is not used for NO x emissions. A new coal-fired power plant would be 18 subject to the new source performance standards for such power plants in 40 CFR 19 60.44a(d)(1). This regulation, issued on September 16, 1998 (63 FR 49453 [EPA 1998]), 20 limits the discharge of any gases that contain nitrogen oxides (expressed as NO

2) in excess 21 of 200 nanograms per Joule (ng/J) of gross energy output (1.6 pounds per megawatt hour 22 [lb/MWh]), based on a 30-day rolling average.

23 Entergy estimates that by using NO x burners with overfire air and selective catalytic 24 reduction (SCR), the total annual NO x emissions for a new coal-fired power plant would be 25 approximately 591 tons. Regardless of the control technology, this level of NO x emissions 26 would be greater than the OL renewal alternative because a nuclear power plant releases 27 negligible amounts of NO x during normal operations.

28 Particulate emissions. Entergy estimated that for coal-fired generation, the total annual 29 stack emissions would include 84 tons of total suspended particulates and 19 tons of 30 particulate matter with an aerodynamic diameter of less than or equal to 10 microns (PM 10). 31 Fabric filters or electrostatic precipitators would be used for control. In addition, coal-32 handling equipment would introduce fugitive particulate emissions. Particulate emissions 33 would be greater under the coal alternative than the OL renewal alternative because nuclear 34 power plants release few particles during normal operation.

35 During the construction of a coal-fired power plant, fugitive dust would be generated. In 36 addition, exhaust emissions would come from vehicles and motorized equipment used 37 during the construction process.

38 Environmental Impacts of Alternatives June 2007 8-15 Draft NUREG-1437, Supplement 31 Carbon monoxide emissions. Entergy estimated that for a coal-fired power plant, the total 1 carbon monoxide emissions would be approximately 591 tons/yr. This level of emissions is 2 greater than the OL renewal alternative.

3 Hazardous air pollutants including mercury. In December 2000, the EPA issued 4 regulatory findings on emissions of hazardous air pollutants from electric utility steam-5 generating units (EPA 2000b). The EPA determined that coal- and oil-fired electric utility 6 steam-generating units are significant emitters of hazardous air pollutants. Coal-fired power 7 plants were found by the EPA to emit arsenic, beryllium, cadmium, chromium, dioxins, 8 hydrogen chloride, hydrogen fluoride, lead, manganese, and mercury (EPA 2000b). The 9 EPA concluded that mercury is the hazardous air pollutant of greatest concern. The EPA 10 found that (1) there is a link between coal consumption and mercury emissions, (2) electric 11 utility steam-generating units are the largest domestic source of mercury emissions, and 12 (3) certain segments of the U.S. population (e.g., the developing fetus, subsistence fish-13 eating populations) are believed to be at potential risk of adverse health effects due to 14 mercury exposures resulting from consumption of contaminated fish (EPA 2000b).

15 Accordingly, the EPA added coal- and oil-fired electric utility steam-generating units to the 16 list of source categories under Section 112(c) of the Clean Air Act for which emission 17 standards for hazardous air pollutants will be issued (EPA 2000b).

18 Uranium and thorium. Coal contains uranium and thorium. Uranium concentrations are 19 generally in the range of 1 to 10 ppm. Thorium concentrations are generally about 2.5 times 20 greater than uranium concentrations (Gabbard 1993). One estimate is that a typical coal-21 fired power plant released roughly 5.2 tons of uranium and 12.8 tons of thorium in 1982 22 (Gabbard 1993). The population dose equivalent from the uranium and thorium releases 23 and daughter products produced by the decay of these isotopes has been calculated to be 24 significantly higher than that from nuclear power plants (Gabbard 1993).

25 Carbon dioxide. A coal-fired power plant would have unregulated carbon dioxide 26 emissions that would contribute to global warming. The level of emissions from a coal-fired 27 power plant would be greater than the OL renewal alternative.

28 Summary. The GEIS analysis did not quantify emissions from coal-fired power plants but 29 implies that air impacts would be substantial. The GEIS also mentions global warming from 30 unregulated carbon dioxide emissions and acid rain from SO x and NO x emissions as 31 potential impacts. Adverse human health effects such as cancer and emphysema have 32 been associated with the products of coal combustion.

33 The NRC staff concludes that the overall impact on air quality from a coal-fired power plant, 34 located at an alternate site in upstate New York, would be MODERATE. The impacts would 35 be clearly noticeable but would not destabilize air quality.

36 Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-16 June 2007 Waste 1 Coal combustion generates waste in the form of ash, and equipment for controlling air 2 pollution generates additional ash and scrubber sludge. The representative coal-fired power 3 plant would generate approximately 136,995 tons of this waste annually for 40 years. The 4 waste would be disposed of onsite, accounting for approximately 161 ac of land area over 5 the 40-year power plant life. Waste impacts to groundwater and surface water would extend 6 beyond the operating life of the power plant if leachate and runoff from the waste storage 7 area occurred. Disposal of the waste would noticeably affect land use and groundwater 8 quality, but with appropriate management and monitoring, it would not destabilize any 9 resources. After closure of the waste site and revegetation, the land would be available for 10 other uses. Debris would be generated during construction activities.

11 In 2000, the EPA issued a "Notice of Regulatory Determination on Wastes From the 12 Combustion of Fossil Fuels" (EPA 2000b). The EPA concluded that some form of national 13 regulation is warranted to address coal combustion waste products because (1) the 14 composition of these wastes could present danger to human health and the environment 15 under certain conditions, (2) the EPA has identified 11 documented cases of proven 16 damages to human health and the environment by improper management of these wastes 17 in landfills and surface impoundments, (3) present disposal practices are such that, in 1995, 18 these wastes were being managed in 40 to 70 percent of landfills and surface 19 impoundments without reasonable controls in place, particularly in the area of groundwater 20 monitoring, and (4) the EPA identified gaps in state oversight of coal combustion wastes.

21 Accordingly, the EPA announced its intention to issue regulations for disposal of coal 22 combustion waste under Subtitle D of the Resource Conservation and Recovery Act of 23 1976. 24 For all of the preceding reasons, the appropriate characterization of impacts from waste 25 generated from burning coal is MODERATE. The impacts would be clearly noticeable but 26 would not destabilize any important resource.

27 Human Health 28 Coal-fired power generation introduces worker risks from fuel and limestone mining, fuel and 29 lime/limestone transportation, and disposal of coal combustion waste. In addition, there are 30 public risks from inhalation of stack emissions. Emission impacts can be widespread, and 31 health risks can be difficult to quantify. The coal alternative also introduces the risk of coal-32 pile fires and attendant inhalation risks.

33 In the GEIS, the NRC staff stated that there would be human health impacts (cancer and 34 emphysema) from inhalation of toxins and particulates, but the NRC staff did not identify the 35 significance of these impacts. In addition, uranium and thorium discharges from coal-fired 36 power plants can potentially produce radiological doses in excess of those arising from 37 nuclear power plant operations (Gabbard 1993).

38 Environmental Impacts of Alternatives June 2007 8-17 Draft NUREG-1437, Supplement 31 Regulatory agencies, including the EPA and state agencies, set air emission standards and 1 requirements based on human health impacts. These agencies also impose site-specific 2 emission limits as needed to protect human heal th. As discussed previously, the EPA has 3 recently concluded that certain segments of the U.S. population (e.g., the developing fetus, 4 subsistence fish-eating populations) are believed to be at potential risk of adverse health 5 effects due to mercury exposures from sources such as coal-fired power plants. However, 6 in the absence of more quantitative data, human health impacts from radiological doses and 7 inhaling toxins and particulates generated by burning coal are characterized as SMALL.

8 Socioeconomics 9 It is estimated that the 816-MWe coal-fired power plant would take approximately four years 10 to construct with a workforce ranging from 979 to 2040 workers (Entergy 2006). The extent 11 of socioeconomic impacts from the construction of the coal-fired power plant would depend 12 on its location. As the NRC notes in the GEIS, socioeconomic impacts are expected to be 13 larger at a rural site than at an urban site because more of the peak construction workforce 14 would need to move to the area to work. Socioeconomic impacts at a rural site would be 15 LARGE, while impacts at a site in the vicinity of a more populated metropolitan area (e.g., 16 Syracuse) would be SMALL to MODERATE. Impacts during construction would consist of 17 short-term increased demand for rental housing and public services that could temporarily 18 offset the loss of jobs and tax revenue from the closure of JAFNPP. Communities in 19 Oswego County in particular would experience MODERATE to LARGE impacts due to 20 losses in employment and tax revenues from the closure of JAFNPP, especially if the coal-21 fired power plant is constructed outside the area.

22 Overall, the socioeconomic impacts of a coal-fired power plant at an alternate site would be 23 SMALL to LARGE depending on the location of the plant.

24 Transportation 25 Transportation-related impacts associated with construction at an alternate site are site-26 dependent but would be MODERATE to LARGE. Transportation impacts related to power 27 plant operations would also be site-dependent and would be SMALL to MODERATE.

28 Coal and lime/limestone would likely be delivered to the site by rail or barge.

29 Socioeconomic impacts associated with rail transportation would likely be MODERATE to 30 LARGE. For example, there would be highway traffic delays as trains pass road crossings.

31 Barge delivery of coal and lime/limestone woul d likely have SMALL socioeconomic impacts.

32 Aesthetics 33 Potential aesthetic impacts of construction and operation of the coal-fired power plant at an 34 alternate site would include visual impairment from a large industrial facility. There would 35 also be an aesthetic impact associated with construction of a new transmission line. Noise 36 Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-18 June 2007 and light from the power plant would be detectable offsite. Aesthetic impacts at the power 1 plant site would be mitigated if the coal-fired power plant were located in an industrial area 2 or adjacent to other power plants. Noise impacts from a rail spur, if required, would be most 3 significant for residents living in the immediate vicinity of the power plant and along the rail 4 route. 5 These impacts are highly site-specific. Therefore, the NRC staff concluded that depending 6 on location aesthetic and noise impacts associated with the development and operation of a 7 coal-fired power plant at an alternate site would range from SMALL to LARGE.

8 Historic and Archaeological Resources 9 Before construction at an alternate site, historic and archaeological studies would be needed 10 to identify, evaluate, and address the potential impacts of new power plant construction on 11 cultural resources. These studies would be needed for all areas of potential disturbance at 12 the proposed power plant site and other support facilities, and along associated corridors 13 where new construction would occur (e.g., roads, transmission corridors, rail lines, other 14 ROWs). Historic and archaeological resource impacts can generally be effectively managed 15 and as such are considered SMALL to MODERATE depending on location and presence of 16 cultural resources.

17 Environmental Justice 18 Impacts on minority and low-income populations associated with a replacement coal-fired power 19 plant built at an alternate site in New York State would depend on the location of the site and 20 population distribution. Impacts on housing availability and prices during power plant 21 construction could disproportionately affect minority and low-income populations. Closure of 22 JAFNPP would result in the loss of approximately 716 jobs causing economic conditions that 23 could affect employment prospects for minority or low-income populations. Depending on plant 24 location, overall impacts would vary between SMALL and LARGE.

25 8.2.1.2 Closed-Cycle Cooling System 26 The environmental impacts of constructing a coal-fired generation system at an alternate site 27 using closed-cycle cooling with cooling towers would be essentially the same as for a coal-fired 28 power plant using a once-through cooling system. However, there are some environmental 29 differences between the closed-cycle and once-through cooling systems. Table 8-3 30 summarizes the incremental differences.

31 Environmental Impacts of Alternatives June 2007 8-19 Draft NUREG-1437, Supplement 31 Table 8-3. Summary of Environmental Impacts of Coal-Fired Generation 1 at an Alternate Site with Closed-Cycle Cooling 2 Impact Category Change in Impacts from Once-Through Cooling System Land Use 25 to 30 additional ac would be required for cooling towers and associated support infrastructure. Ecology Impact would depend on ecology at the site. Reduced impact to aquatic ecology. Water Use and Quality- Surface Water Discharge of cooling tower blowdown containing dissolved solids. Discharge would be regulated by the State. Decreased water withdrawal and less thermal load on the receiving body of water. Consumptive use of water due to evaporation from cooling towers. Water Use and Quality-Groundwater No change Air Quality No change Waste No change Human Health No change Socioeconomics No change Transportation No change Aesthetics Introduction of cooling towers and associated plume. Natural draft towers would be up to 520 ft tall. Mechanical draft towers would be up to 100 ft tall and would have an associated noise impact. Historic and Archaeological Resources No change Environmental Justice No change 3 8.2.2 Natural Gas-Fired Generation 4 The environmental impacts of a natural gas-fired alternative are examined in this section. The 5 NRC staff reviewed Entergy's ER and compared it to environmental impact information in the 6 GEIS. Although the OL renewal period is only 20 years, the impact of operating the natural gas-7 fired alternative for 40 years is considered as a reasonable projection of the operating life of a 8 natural gas-fired power plant.

9 Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-20 June 2007 Entergy assumed that a replacement natural gas-fired power plant would use combined-cycle 1 technology. In a combined-cycle unit, hot combustion gases in a combustion turbine rotate the 2 turbine to generate electricity. Waste combustion heat from the combustion turbine is routed 3 through a heat-recovery boiler to make steam to generate additional electricity.

4 For operation of a gas-fired facility at the existing JAFNPP site, an additional 25 miles (mi) of 5 pipeline for gas supply would need to be constructed. Offsite infrastructure needed to locate the 6 power plant at an alternate site is conjectural but would reasonably include a natural gas supply 7 pipeline, transmission line, and makeup water and discharge pipelines. The extent to which 8 such infrastructure would be required is location-specific, but such needs would be considered 9 in siting the facility and would be subject to regulatory scrutiny under New York's Public Service 10 Law, Articles VII and X, or comparable process (Entergy 2006).

11 The natural gas-fired alternative is analyzed for both the existing JAFNPP site and for an 12 unnamed alternate site. Siting a new natural gas-fired power plant at the site of an existing 13 nuclear power plant would reduce environmental impacts by allowing the new facility to take 14 advantage of existing infrastructure, including transmission facilities, roads, parking areas, office 15 buildings, and the existing cooling system (to the extent needed). Approximately 90 ac would 16 be required to locate the gas-fired power plant at an alternative site.

17 The NRC staff assumed that construction of the gas-fired units would be scheduled to coincide 18 with the expiration date of the JAFNPP OL. Consistent with the JAFNPP ER (Entergy 2006), 19 the NRC staff assumed a combined-cycle natural gas facility based on two 408-MWe combined-20 cycle units for a total facility size of 816 MWe. This assumption slightly understates the 21 environmental impacts of replacing the 881 MWe from JAFNPP. As a rough estimate, if a 22 natural gas-fired power plant of exactly 881 MWe were built, any numerical impacts in this 23 section, e.g., quantities of air pollutants, might simply be adjusted upward accordingly.

24 However, given these adjustments, the NRC staff has determined that the differences in 25 impacts between 816 MWe and 881 MWe of natural gas-fired generation would not be 26 significant and would not change the standard of significance (SMALL, MODERATE, or LARGE) 27 of any impacts.

28 The NRC staff assumed that the power plant would use a once-through cooling system. The 29 impacts of using a closed-cycle cooling system are evaluated in Section 8.2.2.2.

30 8.2.2.1 Once-Through Cooling System 31 The overall impacts of the natural gas-generating system using a once-through cooling system 32 are discussed in this section and summarized in Table 8-4. The extent of impacts at an 33 alternate site would depend on the location of the site.

34 Environmental Impacts of Alternatives June 2007 8-21 Draft NUREG-1437, Supplement 31 Table 8-4. Summary of Environmental Impacts of Natural Gas-Fired Generation at the 1 JAFNPP Site and an Alternate Site Using Once-Through Cooling 2 JAFNPP Site Alternate Site Impact Category Impact Comments Impact Comments Land Use SMALL to MODERATE The natural gas-fired power plant would be constructed on undeveloped portions of the JAFNPP site. It would require upwards of 90 ac for power block, roads, parking areas, and a gas pipeline ROW. It would use existing infrastructure, minimizing new land requirements.

SMALL to MODERATE Land-use requirements would be larger at the alternate site than at the JAFNPP site because of the need for additional

infrastructure such as transmission facilities, roads, parking areas, office buildings, and cooling system. The total impact would depend on whether the alternate site had been previously disturbed. Ecology MODERATE The natural gas-fired alternative at the JAFNPP site would be constructed partly on previously disturbed areas and would disturb relatively little acreage at the site.

However, a 25-mi gas supply line would need to be constructed, which, assuming a construction ROW of 75 ft, would disrupt up to 230 ac of terrestrial habitat. Ecological impacts would include impacts on threatened or endangered species, wildlife habitat loss and reduced productivity, habitat fragmentation, and a local reduction in biological diversity.

SMALL to MODERATE Impacts would depend on whether the alternate site is previously developed. Factors to consider include location and ecology of site and transmission line route.

Ecological impacts would include impacts on threatened or endangered species, wildlife habitat loss and reduced productivity, habitat fragmentation, and a local reduction in biological diversity.

Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-22 June 2007 1 Table 8-4 (cont.) JAFNPP Site Alternate Site Impact Category Impact Comments Impact Comments Water Use and Quality-Surface Water SMALL Combined-cycle units have lower water requirements than nuclear and coal-fired power plants. The natural gas-fired alternative would use the existing once through cooling system.

SMALL to MODERATE Combined-cycle units have lower water requirements than nuclear and coal-fired power plants. Total impacts would depend on the volume and other characteristics of the receiving body of water. Water Use and Quality-Groundwater NO IMPACT JAFNPP does not have onsite pumpable groundwater wells.

Potable water is supplied by the Town of Scriba.

SMALL to MODERATE The impact to groundwater would depend on the site characteristics, including the amount of groundwater available. Air Quality MODERATE SO x: 85 tons/yr NO x: 272 tons/yr Carbon monoxide: 57 tons/yr PM 10 particulates: 47 tons/yr Other: (1) hazardous air pollutants, including arsenic, formaldehyde, and nickel and (2) carbon dioxide emissions, which contribute to global warming MODERATE The impacts at an unnamed alternate site would be the same as those for the

JAFNPP site. Waste SMALL Minimal waste product from fuel combination SMALL The impacts at an unnamed alternate site would be the same as those for the JAFNPP site. Human Health SMALL Impacts would be minor. SMALL The impacts at an unnamed alternate site would be the same as those for the

JAFNPP site.

Environmental Impacts of Alternatives June 2007 8-23 Draft NUREG-1437, Supplement 31 Table 8-4 (cont.) JAFNPP Site Alternate Site Impact Category Impact Comments Impact Comments Socioeconomics SMALL to LARGE Impacts are expected to be SMALL to LARGE because of a decrease in employment and tax revenue to local jurisdictions.

SMALL to LARGE The impacts at an alternate site would be the same as those for the JAFNPP site. Transportation MODERATE Transportation impacts associated with construction would be MODERATE. MODERATE Transportation impacts associated with construction would be MODERATE. Aesthetics SMALL Construction and operation of a natural gas-fired power plant at JAFNPP would not alter the overall aesthetic characteristics of the site.

SMALL to LARGE Construction and operation of a natural gas-fired power plant at an alternate site would change the aesthetic characteristics of the site. Historic and Archaeological

Resources SMALL to MODERATE Constructing a natural gas-fired power plant would require cultural resource studies. Impacts would vary depending on the location of the plant on the undeveloped portions of the JAFNPP site and the presence of historic and archaeological resources.

SMALL to MODERATE The impacts at an alternate site would be the same as those for the JAFNPP site. Environmental Justice SMALL to MODERATE Impacts to minority and low-income populations would vary depending on the location of the power plant site and other support facilities SMALL to MODERATE The impacts at an alternate site would be the same as those for the JAFNPP site.

1 Land Use 2 For siting at JAFNPP, existing facilities and infrastructure would be used to the extent 3 possible, limiting the amount of new construction that would be required. Specifically, the 4 NRC staff assumed that the natural gas-fired replacement power plant alternative would 5 require approximately 90 ac of land and would make use of existing transmission facilities, 6 roads, and parking areas. Operation of a new combined-cycle facility at the JAFNPP site 7

Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-24 June 2007 would require the construction of approximately 25 mi of natural gas pipeline. It is estimated 1 that the pipeline would require approximately 230 ac for an easement. The onsite facilities 2 would represent expansion of an existing industrial land use.

3 For construction at an alternate site, the full land-area requirement for a natural gas-fired 4 facility would be necessary because no existing infrastructure would be available. Additional 5 land would be impacted by construction of a transmission line and natural gas pipelines to 6 serve the power plant. The gas line requirements at an alternate site would depend on the 7 characteristics and location of the alternate site.

8 Regardless of where the gas-fired power plant was built, additional land would be required 9 for natural gas wells and collection stations. Partially offsetting these offsite land 10 requirements would be the elimination of the need for uranium mining to supply fuel for 11 JAFNPP. In the GEIS, the NRC staff estimated that approximately 1000 ac would be 12 affected for mining the uranium and processing it during the operating life of a nuclear power 13 plant. 14 Overall, the land-use impacts of constructing the natural gas-fired power plant at the 15 JAFNPP site would be SMALL to MODERATE. Overall, the land-use impacts of siting the 16 natural gas-fired power plant at an alternate site would depend on the chosen site and are 17 characterized as SMALL to MODERATE.

18 Ecology 19 Entergy expects that development of the gas-fired alternative power plant at the JAFNPP 20 site would be constructed partly on previously disturbed areas and would disturb relatively 21 little acreage at the site. However, to accommodate a gas-fired power plant at the JAFNPP 22 site, a 25-mi gas supply line would need to be constructed, which, assuming a construction 23 ROW of 75 ft, would disrupt up to 230 ac of terrestrial habitat. Ecological impacts to the 24 power plant site and utility easements would include impacts on threatened or endangered 25 species, wildlife habitat loss and reduced productivity, habitat fragmentation, and a local 26 reduction in biological diversity.

27 The GEIS noted that land-dependent ecological impacts from construction would be SMALL 28 unless site-specific factors indicated a particular sensitivity and that operational impact 29 would be smaller than for other fossil fuel technologies of equal capacity. The connection to 30 a gas pipeline approximately 25 mi from the JAFNPP site is a site-specific factor that would 31 make the gas-fired alternative's ecological impacts larger than those of license renewal.

32 Therefore, in this case, ecological impacts of siting a natural gas-fired power plant at the 33 JAFNPP site would be MODERATE.

34 Impact on ecological resources from construction and operation of the representative natural 35 gas-fired power plant and associated offsite infrastructure at an alternate site is conjectural.

36 Environmental Impacts of Alternatives June 2007 8-25 Draft NUREG-1437, Supplement 31 However, ecological resources throughout much of the area would be similar to those for the 1 JAFNPP site alternative. The NRC staff concludes that the associated impact on ecological 2 resources would be SMALL to MODERATE.

3 Water Use and Quality-Surface Water 4 Overall, water requirements for combined-cycle generation are much less than for 5 conventional generators such as nuclear generators and coal-fired generators. A natural 6 gas-fired power plant sited at JAFNPP is assumed to use the existing once-through cooling 7 system. Surface water impacts would be expected to remain SMALL.

8 A natural gas-fired power plant at an alternate site is assumed to use a once-through 9 cooling system. The impact on surface water would depend on the volume and other 10 characteristics of the receiving body of water. The impacts would be SMALL to 11 MODERATE.

12 The NRC staff noted in the GEIS that at either the JAFNPP site or an alternate site, some 13 erosion and sedimentation probably would occur during construction. Water-quality impacts 14 from sedimentation during construction are characterized in the GEIS as SMALL. The NRC 15 staff also noted in the GEIS that operational water quality impacts would be similar to, or 16 less than, those from other generating technologies.

17 Water Use and Quality-Groundwater 18 JAFNPP does not have onsite pumpable groundwater wells. Potable water is supplied by 19 the Town of Scriba and cooling water is taken from Lake Ontario. Therefore, there would be 20 no groundwater impacts at the JAFNPP site.

21 For a natural gas-fired power plant at an alternate site, any groundwater withdrawal would 22 require a permit from the local permitting authority. The impact to groundwater would 23 depend on the site characteristics, including the amount of groundwater available. The 24 impacts would range between SMALL and MODERATE.

25 Air Quality 26 Natural gas is a relatively clean-burning fuel. The gas-fired alternative would release similar 27 types of emissions but in lesser quantities than the coal-fired alternative. Hence, the gas-28 fired alternative would be subject to the same type of air-quality regulations as a coal-fired 29 power plant, discussed in Section 8.2.1. The greatest concerns from combined-cycle 30 facilities are the emissions of ozone precursors, NO x, and volatile organic compounds 31 (VOCs). 32 Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-26 June 2007 JAFNPP projects the following emissions for the natural gas-fired alterative (Entergy 2006):

1 o Sulfur oxides: 85 tons/yr 2 o Nitrogen oxides: 272 tons/yr 3 o Carbon monoxide: 57 tons/yr 4 o PM 10 particulates: 47 tons/yr 5 A natural gas-fired power plant would also have unregulated carbon dioxide emissions that 6 would contribute to global warming. While these emissions have not traditionally been an 7 important environmental concern, they are becoming increasingly relevant at both the 8 national and international levels.

9 In December 2000, the EPA issued regulatory findings on emissions of hazardous air 10 pollutants from electric utility steam-generating units. Natural gas-fired power plants were 11 found by the EPA to emit arsenic, formaldehyde, and nickel (EPA 2000b). Unlike coal and 12 oil-fired power plants, the EPA did not determine that emissions of hazardous air pollutants 13 from natural gas-fired power plants should be regulated under Section 112 of the Clean Air 14 Act. 15 Construction activities would result in temporary fugitive dust. Exhaust emissions would 16 also come from vehicles and motorized equipment used during the construction process and 17 by employee and delivery vehicles during operations.

18 The preceding emissions would likely be the same at JAFNPP or at an alternate site.

19 Impacts from the above emissions would be clearly noticeable but would not be sufficient to 20 destabilize air resources as a whole. The overall air-quality impact for a new natural gas-21 fired power plant sited at JAFNPP or at an alternate site is considered MODERATE.

22 Waste 23 There would be spent catalyst from NO x emissions control and small amounts of solid-waste 24 products (i.e., ash) from burning natural gas fuel. In the GEIS, the NRC staff concluded that 25 waste generation from gas-fired technology would be minimal. Gas firing results in very few 26 combustion by-products because of the clean nature of the fuel. Waste-generation impacts 27 would be so minor that they would not noticeably alter any important resource attribute.

28 Construction-related debris would be generated during construction activities.

29 In the winter, it might become necessary for a replacement baseload natural gas-fired power 30 plant to operate on fuel oil due to lack of gas supply. Oil combustion generates waste in the 31 form of ash, and equipment for controlling air pollution generates additional ash and 32 scrubber sludge. The amount of ash and sludge generated would depend on the type and 33 quantity of fuel oil combusted. Number 2 fuel oil does not produce any appreciable ash.

34 Environmental Impacts of Alternatives June 2007 8-27 Draft NUREG-1437, Supplement 31 Overall, the waste impacts would be SMALL for a natural gas-fired power plant sited at 1 JAFNPP or at an alternate site.

2 Human Health 3 In Table 8-2 of the GEIS, the NRC staff identifies cancer and emphysema as potential 4 health risks from gas-fired power plants. The risk may be attributable to NO x emissions that 5 contribute to ozone formation, which in turn contribute to health risks. Emissions of NO x 6 from any gas-fired power plant would be regulated. For a power plant sited in New York, 7 NO x emissions would be regulated by the NYSDEC. Human health effects would not be 8 detectable or would be sufficiently minor that they would neither destabilize nor noticeably 9 alter any important attribute of the resource. Overall, the impacts on human health of the 10 natural gas-fired alternative sited at JAFNPP or at an alternate site would be SMALL.

11 Socioeconomics 12 Construction of a natural gas-fired power plant would take approximately two years. In the 13 GEIS, peak employment is determined to be approximately 1200 workers. The NRC staff 14 assumed that construction would take place while JAFNPP continued operation and would 15 be completed by the time it permanently ceased operations. During construction, the 16 communities surrounding the JAFNPP site would experience demands on housing and 17 public services that would have SMALL impacts. These impacts would be tempered by 18 construction workers commuting from other parts of Oswego and Onondaga counties. After 19 construction, the communities would be impacted by the loss of jobs. The current JAFNPP 20 workforce (716 workers) would decline through a decommissioning period to a minimal 21 maintenance size. The gas-fired power plant would introduce a replacement tax base at 22 JAFNPP or an alternate site and approximately 50 new permanent jobs. Impacts in Oswego 23 and Onondaga counties resulting from decommissioning of JAFNPP might be offset to some 24 degree by potential job opportunities in the Syracuse area.

25 In the GEIS, the NRC staff concluded that so cioeconomic impacts from constructing a 26 natural gas-fired power plant would not be very noticeable and that the small operational 27 workforce would have the lowest socioeconomic impacts of any nonrenewable technology.

28 Compared to the coal-fired and nuclear alternatives, the smaller size of the construction 29 workforce, the shorter construction time frame, and the smaller size of the operations 30 workforce would minimize socioeconomic impacts. For these reasons, socioeconomic 31 impacts associated with the construction and operation of a natural gas-fired power plant 32 would be MODERATE for siting at JAFNPP.

33 The extent of socioeconomic impacts from constructing and operating a natural gas-fired 34 power plant at an alternate site in upstate New York would depend on its location. Impacts 35 near large population centers (i.e., Syracuse) would likely be small, with moderate impacts 36 possible in more rural areas. Communities in Oswego County in particular would 37 Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-28 June 2007 experience MODERATE to LARGE impacts due to losses in employment and tax revenues 1 from the closure of JAFNPP, especially if the natural gas-fired power plant is constructed 2 outside the area. Overall, the socioeconomic impacts of a natural gas-fired power plant at an 3 alternate site would be SMALL to LARGE depending on the location of the plant.

4 Transportation 5 Transportation-related impacts associated with construction and operations would depend 6 on the population density and transportation infrastructure in the vicinity of the site. The 7 impacts can be classified as MODERATE for siting at the JAFNPP site or an alternate site.

8 Aesthetics 9 The turbine buildings (106-ft tall) and exhaust stacks (approximately 225-ft tall) would be 10 visible during daylight hours from offsite. The gas pipeline compressors would also be 11 visible. However, development of the natural gas-fired power plant at the JAFNPP site 12 would represent an incremental addition to an existing power plant with similar 13 characteristics. A forest buffer provides a visual screen to residential developments 14 bordering the site. Overall, the NRC staff concludes that aest hetic impacts from 15 development of a natural gas-fired power plant at the JAFNPP site would be SMALL.

16 At an alternate site, the buildings and associated transmission line and gas pipeline 17 compressors would be visible offsite. The visual impact of a new transmission line would be 18 especially significant. Aesthetic impacts would be mitigated if the power plant were located 19 in an industrial area adjacent to other power plants. Overall, the aesthetic impacts 20 associated with an alternate site are categorized as MODERATE to LARGE. The greatest 21 contributor to this categorization is the aesthetic impact of the new transmission line.

22 Natural gas generation would introduce mechanical sources of noise that would be audible 23 offsite. Sources contributing to total noise produced by power plant operation are classified 24 as continuous or intermittent. Continuous sources include the mechanical equipment 25 associated with normal power plant operations. Intermittent sources include the use of an 26 outside loudspeaker and the commuting of power plant employees. However, it is expected 27 that the power plant would comply with all applicable noise ordinances and standards.

28 Therefore, the noise impacts of a natural gas-fired power plant at the JAFNPP site would be 29 SMALL. At an alternate site, these noise impacts would be SMALL to LARGE depending on 30 the location of the site.

31 Historic and Archaeological Resources 32 At both JAFNPP and an alternate site, a cultural resource inventory would be needed for 33 any undeveloped portions of the site that had not been previously surveyed. Other 34 properties, if any, which would be acquired to support the power plant, would also need to 35 Environmental Impacts of Alternatives June 2007 8-29 Draft NUREG-1437, Supplement 31 be surveyed for cultural resources prior to ground-disturbing activities at the power plant 1 site. 2 Before construction at JAFNPP or an alternate site, historic and archaeological studies 3 would be needed to identify, evaluate, and address the potential impacts of new power plant 4 construction on cultural resources. These studies would likely be needed for all areas of 5 potential disturbance at the proposed power plant site, other support facilities, and along 6 associated corridors where new construction would occur (e.g., roads, transmission and 7 pipeline corridors, other ROWs). Historic and archaeological resource impacts can 8 generally be effectively managed and as such are considered SMALL to MODERATE 9 depending on the location and presence of cultural resources.

10 Environmental Justice 11 Impacts on minority and low-income populations associated with a replacement natural gas-12 fired power plant built at JAFNPP or an alternate site in New York State would depend on 13 the location of the site and population distribution. Impacts on housing availability and prices 14 during power plant construction could disproportionately affect minority and low-income 15 populations. Closure of JAFNPP would result in the loss of approximately 716 jobs causing 16 economic conditions that could affect employment prospects for minority or low-income 17 populations. Depending on plant location, overall impacts could vary between SMALL and 18 MODERATE.

19 8.2.2.2 Closed-Cycle Cooling System 20 This section discusses the environmental impacts of constructing a natural gas-fired generation 21 system at either the JAFNPP site or an alternate site using closed-cycle cooling. The impacts 22 (SMALL, MODERATE, or LARGE) of this option are the same as for a natural gas-fired power 23 plant using the once-through cooling system. However, there are minor environmental 24 differences between the closed-cycle and once-through cooling systems. Table 8-5 25 summarizes the incremental differences.

26 8.2.3 Nuclear Power Generation 27 Since 1997, the NRC has certified four new standard designs for nuclear power plants under 28 10 CFR 52, Subpart B. These designs are the 1300 MWe U.S. Advanced Boiling Water 29 Reactor (10 CFR 52, Appendix A), the 1300 MWe System 80+ Design (10 CFR 52, 30 Appendix B), the 600 MWe AP600 Design (10 CFR 52, Appendix C), and AP 1000 (10 CFR 52, 31 Appendix D). All of these power plants are light-water reactors. Although no applications for a 32 construction permit or a combined license based on these certified designs have been 33 submitted to NRC, the submission of the design certification applications indicates continuing 34 interest in the possibility of licensing new nuclear power plants. Consequently, construction of a 35 new nuclear power plant at both the JAFNPP site and an alternate site is considered in this 36 Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-30 June 2007 section. The NRC staff assumed that the new nuclear power plant would have a 40-year 1 lifetime.

2 Table 8-5. Summary of Environmental Impacts of Natural Gas-Fired Generation at Either 3 the JAFNPP Site or an Alternate Site with Closed-Cycle Cooling 4 Impact Category Change in Impacts from Once-Through Cooling System Land Use 25 to 30 additional ac required for cooling towers and associated support infrastructure. Ecology Impact would depend on ecology at the site. Additional impact to terrestrial biota from cooling towe r drift. Reduced impact to aquatic ecology. Water Use and Quality- Surface Water Discharge of cooling tower blowdown containing dissolved solids.

Discharge would be regulated. Decrease water withdrawal and less thermal load on receiving body of water. Increase in consumptive use of water due to evaporation. Water Use and Quality-Groundwater No change Air Quality No change Waste No change Human Health No change Socioeconomics No change Transportation No change Aesthetics Introduction of cooling towers and associated plume with noise impacts from operation of cooling towers. Historic and Archaeological Resources No change Environmental Justice No change 5 NRC has summarized environmental data associated wi th the uranium fuel cycle in Table S-3 of 6 10 CFR 51.51. The impacts listed in Table S-3 are representative of the impacts that would be 7 associated with a replacement nuclear power plant built to one of the certified designs and sited 8 at JAFNPP or an alternate site. The impacts shown in Table S-3 are for a 1000-MWe reactor.

9 The environmental impacts associated with transpor ting fuel and waste to and from a light-water 10 cooled nuclear power reactor are summarized in Table S-4 of 10 CFR 51.52. The summary of 11 Environmental Impacts of Alternatives June 2007 8-31 Draft NUREG-1437, Supplement 31 NRC's findings on NEPA issues for license renewal of nuclear power plants in Table B-1 of 1 10 CFR 51 Subpart A, Appendix B, is also relevant, although not directly applicable, for 2 consideration of environmental impacts associated with the operation of a replacement nuclear 3 power plant. Additional environmental impact information for a replacement nuclear power plant 4 using once-through cooling is presented in Section 8.2.3.1 and closed-cycle cooling in 5 Section 8.2.3.2.

6 8.2.3.1 Once-Through Cooling System 7 The overall impacts of a nuclear generating system using a once-through cooling system are 8 discussed in this section. The impacts are summarized in Table 8-6. The extent of impacts at 9 an alternate site would depend on the location of the site.

10 Land Use 11 The existing facilities and infrastructure at the JAFNPP site would likely be used, limiting the 12 amount of new construction that would be required. Existing transmission facilities, roads, 13 parking areas, and cooling system would be used. According to the GEIS, light-water 14 reactors require approximately 500 to 1000 ac excluding transmission lines (these estimates 15 are not scaled to any particular facility size). Much of the land that would be used has been 16 previously disturbed. The JAFNPP site consists of approximately 700 ac and would be 17 adequate to support a new nuclear facility. There would be no net change in land needed 18 for uranium mining because land needed to supply the new nuclear power plant would 19 replace the land no longer needed to supply uranium for fueling the existing reactors at 20 JAFNPP. Overall, the land use impact of a replacement nuclear power plant at the existing 21 JAFNPP site would be SMALL. However, the impact would be greater than the OL renewal 22 alternative.

23 Land-use requirements at an alternate site would be similar to siting at JAFNPP except for 24 the possible need for additional land for a new transmission line. In addition, it might be 25 necessary to construct a rail spur to bring in equipment during construction. Depending on 26 transmission line routing, siting a new nuclear power plant at an alternate site would result in 27 MODERATE to LARGE land-use impacts.

28 Ecology 29 Locating a replacement nuclear power plant at the JAFNPP site would alter ecological 30 resources because of construction and the need to convert currently unused land to 31 industrial use. In total, impacts would include habitat degradation, fragmentation, or loss as 32 a result of construction activities and conversion of land to industrial use. Ecological 33 communities would experience reduced productivi ty and biological diversity from disturbing 34 previously intact land. Overall, the ecological impacts of the nuclear alternative at the 35 Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-32 June 2007 JAFNPP site would be SMALL. The impact would be greater than the OL renewal 1 alternative.

2 Table 8-6. Summary of Environmental Impacts of New Nuclear Power Generation at the 3 JAFNPP Site and an Alternate Site Using Once-Through Cooling 4 JAFNPP Site Alternate Site Impact Category Impact Comments Impact Comments Land Use SMALL Would require approximately 500 to 1000 ac for the power plant. The new nuclear power plant would require the use of previously disturbed undeveloped portions of the JAFNPP site. Would use the existing infrastructure to the extent possible. MODERATE to LARGE Land use requirements would be larger at the alternate site than at the JAFNPP site because of the potential need for land for a transmission line.

Overall, impacts would depend on whether the alternate site had been previously disturbed.Ecology SMALL Would use undeveloped areas at current Nine Mile Point site. MODERATE

to LARGE Impact depends on location and ecology of the site, surface water body used for intake and discharge, and transmission line route; potential habitat loss and fragmentation; and reduced productivity and biological diversity. Water Use and Quality-Surface Water SMALL The nuclear alternative would use the existing once-through cooling system.

SMALL to MODERATE Impacts would depend on the volume of water withdrawn and the characteristics of the surface body of water. Water Use and Quality-Groundwater SMALL Groundwater is not used at the JAFNPP site.

SMALL to MODERATE Impacts would depend on the volume of water withdrawn and the characteristics of the groundwater source. Air Quality SMALL Fugitive emissions and emissions from vehicles and equipment during construction. Small amount of emissions from diesel generators and possibly other sources during operation. SMALL Same impacts as JAFNPP site.

June 2007 8-33 Draft NUREG-1437, Supplement 31 Table 8-6 (cont.) JAFNPP Site Alternate Site Impact Category Impact Comments Impact Comments Waste SMALL Waste impacts for an operating a nuclear power plant are set out in 10 CFR 51, Appendix B, Table B-1. Debris would be generated and removed during construction. SMALL Same impacts as JAFNPP site. Human Health SMALL Human health impacts for an operating nuclear power plant are set out in 10 CFR 51, Appendix B, Table B-1. SMALL Same impacts as JAFNPP site. Socioeconomics SMALL to MODERATE During construction, impacts would be MODERATE. Up to 2500 workers during peak period of the five-year construction period. During operation, employment levels would be similar to those for JAFNPP. Overall, socioeconomic impacts from operation would be SMALL.

SMALL to LARGE The characteristics of the construction period and operation at an alternate site would be similar to those at JAFNPP. Socioeconomic impacts to the local community would depend on the location of the alternate site and would vary from SMALL to LARGE. Transportation SMALL to LARGE Transportation impacts associated with construction would be MODERATE to LARGE. Transportation impacts associated with operations would be SMALL.

SMALL to

LARGE Transportation impacts associated with construction would be MODERATE to LARGE. Transportation impacts associated with operations would be SMALL to MODERATE. Aesthetics SMALL to MODERATE There would be visual aesthetic impacts associated with power plant buildings and structures. There would be both intermittent and continuous noise impacts from the power plant during construction and operations.

SMALL to LARGE The significance of the impacts would depend on the location of the alternate site. An alternate site could require transmission lines, with aesthetic impacts.

Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-34 June 2007 Table 8-6 (cont.) JAFNPP Site Alternate Site Impact Category Impact Comments Impact Comments Historic and Archaeological

Resources SMALL to MODERATE Construction of a new nuclear power plant would require cultural resource studies. Impacts could vary depending on the location of the plant on undeveloped portions of the JAFNPP site and presence of historic and archaeological resources.

SMALL to MODERATE The impacts at an alternate site would be the same as those for the JAFNPP site. Environmental

Justice SMALL to MODERATE Impacts to minority and low-income populations would vary depending on the location of the power plant site and other support

facilities.

SMALL to MODERATE The impacts at an alternate site would be the same as those for the JAFNPP site.

1 At an alternate site, there would be construction impacts and new incremental operational 2 impacts. Even assuming siting at a previously disturbed area, the impacts might alter the 3 ecology. Impacts would include habitat degradation, fragmentation or loss, reduced 4 ecosystem productivity (i.e., including wildlife species), and a reduction in biological 5 diversity. Construction and maintenance of transmission lines, a rail spur, or a barge 6 offloading facility would result in the same types of ecological impacts. Overall, the impacts 7 of the nuclear alternative at an alternate site would be MODERATE to LARGE.

8 Water Use and Quality-Surface Water 9 It is assumed that the replacement nuclear power plant alternative at the JAFNPP site would 10 use the existing once-through cooling system, which would minimize incremental water-use 11 and quality impacts. Surface-water impacts would be expected to remain SMALL. The 12 impacts would be sufficiently minor that they would not noticeably alter any important 13 attribute of the resource.

14 For an alternate site, the cooling water would likely be drawn from a surface body of water.

15 The impact on the surface water would depend on the volume of water needed and the 16 characteristics of the body of water. The impacts would be SMALL to MODERATE.

17 Environmental Impacts of Alternatives June 2007 8-35 Draft NUREG-1437, Supplement 31 Water Use and Quality-Groundwater 1 No groundwater is currently used for operation of JAFNPP, and it is unlikely that 2 groundwater would be used for an alternative nuclear power plant sited at JAFNPP. Use of 3 groundwater for a nuclear power plant sited at an alternate site would be a possibility. Any 4 groundwater withdrawal would require a permit from the local permitting authority.

5 Overall, the impacts of the nuclear alternative at the JAFNPP site would be SMALL. The 6 impacts of the nuclear alternative at an alternate site would be SMALL to MODERATE.

7 Air Quality 8 Construction of a new nuclear power plant sited at JAFNPP or an alternate site would result 9 in fugitive emissions during the construction process. Exhaust emissions would also come 10 from vehicles and motorized equipment used during the construction process. An operating 11 nuclear power plant would have minor air emissions associated with diesel generators and 12 other minor intermittent sources. These emissions would be regulated by NYSDEC.

13 Overall, emissions and associated impacts to air quality of a nuclear power plant at either 14 the JAFNPP site or an alternate site would be SMALL.

15 Waste 16 The waste impacts associated with operation of a nuclear power plant are set out in 17 Table B-1 of 10 CFR 51, Subpart A, Appendix B. Construction-related debris would be 18 generated during construction activities and removed to an appropriate disposal site.

19 Overall, waste impacts of a new nuclear power plant at either the JAFNPP site or an 20 alternate site would be SMALL.

21 Human Health 22 Human health impacts for an operating nuclear power plant are set out in 10 CFR 51 23 Subpart A, Appendix B, Table B-1. Overall, human health impacts of a new nuclear power 24 plant at either the JAFNPP site or an alternate site would be SMALL.

25 Socioeconomics 26 Construction of the new nuclear power plant would be conducted over a period of five years 27 with a peak workforce of 2500. Construction would take place while the existing nuclear unit 28 would continue operation and would be completed by the time JAFNPP permanently ceased 29 operation.

30 If the new nuclear power plant were constructed at the JAFNPP site, the construction 31 workers would be in addition to the employees who currently work at the site. Surrounding 32 communities would experience significant demands on rental housing and public services.

33 Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-36 June 2007 After construction, the local communities would be impacted by the loss of the construction 1 jobs. In addition, the large construction workforce and delivery of construction materials 2 would put significant pressure on existing highways near the JAFNPP site. The construction 3 workforce would also add to the local tax base. In total, the socioeconomic impacts during 4 the construction period for the nuclear alternative at the JAFNPP site would be MODERATE.

5 At an alternate site, the construction impacts would be similar to those at the JAFNPP site.

6 Impacts would be SMALL to LARGE, depending on the location of the alternate site to a 7 large population center.

8 It is assumed that the replacement nuclear unit would have an operating workforce 9 comparable to the 716 workers currently working at JAFNPP. The replacement nuclear unit 10 would provide a new tax base to offset the loss of tax base associated with 11 decommissioning JAFNPP. For all of these reasons, the socioeconomic impacts for 12 operating a new nuclear power plant at JAFNPP would be SMALL.

13 The impacts of operating a new nuclear power plant at an alternate site would be generally 14 larger than those at the JAFNPP site, depending on the proximity of the alternate site to a 15 large population center. Impacts would be SMALL to LARGE, depending on the location of 16 the alternate site.

17 Transportation 18 During the five-year construction period, up to 2500 construction workers would be working 19 at the JAFNPP site in addition to the 716 workers who operate JAFNPP. The addition of the 20 construction workers and the delivery of c onstruction materials and equipment would place 21 significant pressure on existing highways. Impacts would be MODERATE to LARGE.

22 Transportation impacts associated with the operation of JAFNPP would be SMALL.

23 Transportation-related impacts associated with commuting construction workers and the 24 delivery of construction materials and equipment at an alternate site would be site-25 dependent and would be MODERATE to LARGE. Transportation impacts associated with 26 operations would also be site-dependent and would be SMALL to MODERATE.

27 Aesthetics 28 The nuclear alternative would result in both visual and noise aesthetic impacts. Visual 29 impacts would result from several structures, including, most prominently, the containment 30 building. The replacement nuclear units would also likely be visible at night because of 31 outside lighting. Visual impacts at night would be mitigated by reduced lighting and 32 appropriate shielding. Overall, the visual aesthetic impacts of the nuclear alternative at the 33 JAFNPP site would be MODERATE.

34 Environmental Impacts of Alternatives June 2007 8-37 Draft NUREG-1437, Supplement 31 At an alternate site, the aesthetic impacts would be larger. There would also be aesthetic 1 impacts associated with the need for new transmission lines. Light from the new nuclear 2 power plant would be detectable offsite. The impact of light could be mitigated if the power 3 plant were located in an industrial area adjacent to other power plants. Overall, the 4 aesthetic impacts associated with an alternate site would be MODERATE to LARGE 5 including the aesthetic impact of a new transmission line.

6 Nuclear generation would introduce continuous and intermittent sources of noise from power 7 plant operations. Continuous sources of noise include the mechanical equipment 8 associated with normal power plant operations. Intermittent sources include the use of 9 outside loudspeakers and those associated with the workforce. At the JAFNPP site, power 10 plant-operation noises would be similar to existing noise levels from current power plant 11 operations. Noise impacts of the nuclear alternative at JAFNPP would be SMALL. At an 12 alternate site, noise impacts would be SMALL to LARGE, depending on the location of the 13 site. 14 Historic and Archaeological Resources 15 At both JAFNPP and an alternate site, a cultural resource inventory would be needed for 16 any undeveloped portions of the site that had not been previously surveyed. Other 17 properties, if any, that were acquired to support the power plant would also need to be 18 surveyed for cultural resources, prior to ground-disturbing activities at the power plant site.

19 Before construction at JAFNPP or an alternate site, studies would be needed to identify, 20 evaluate, and address the potential impacts of new power plant construction on cultural 21 resources. These studies would be needed for all areas of potential disturbance at the 22 proposed power plant site, other support facilities, and along associated corridors where 23 new construction would occur (e.g., roads, transmission corridors, rail lines, other ROWs).

24 Historic and archaeological resource impacts would generally be effectively managed and 25 as such would be SMALL to MODERATE depending on location and presence of cultural 26 resources.

27 Environmental Justice 28 Impacts on minority and low-income populations associated with a replacement nuclear 29 power plant at JAFNPP or an alternate site in New York State would depend on the location 30 of the site and population distribution. Impacts on housing availability and prices during 31 power plant construction could disproportionately affect minority and low-income 32 populations. Closure of JAFNPP and construction of a replacement nuclear power plant at 33 an alternate site would result in the loss of approximately 716 jobs causing economic 34 conditions that could affect employment prospects for minority or low-income populations in 35 the vicinity of JAFNPP. Depending on the plant location, overall impacts could vary 36 between SMALL and MODERATE.

37 Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-38 June 2007 8.2.3.2 Closed-Cycle Cooling System 1 This section discusses the environmental impacts of constructing at an alternate site a nuclear 2 power plant that uses a closed-cycle cooling syst em with a cooling tower. The impacts (SMALL, 3 MODERATE, or LARGE) of this option would be similar to the impacts for a nuclear power plant 4 using a once-through cooling system. However, there would be minor environmental 5 differences between the closed-cycle and once-through cooling systems. Table 8-7 6 summarizes the incremental differences.

7 Table 8-7. Summary of Environmental Impacts of a New Nuclear Power Plant Sited at an 8 Alternate Site with Closed-Cycle Cooling 9 Impact Category Change in Impacts from Once-Through Cooling System Land Use 20 to 30 ac of land would be required on previously disturbed undeveloped land for cooling towers and associated infrastructure. Ecology Impacts would depend on ecology at the site. Additional impact to terrestrial ecology from cooling tower drift. Reduced impact to aquatic ecology. Water Use and Quality- Surface Water Discharge of cooling tower blowdown containing dissolved solids. Discharge would be regulated by the State of New York. Decreased water withdrawal and less thermal load on receiving body of water. Consumptive use of water due to evaporation from cooling towers. Water Use and Quality-Groundwater No change Air Quality No change Waste No change Human Health No change Socioeconomics No change Transportation No change Aesthetics Introduction of cooling towers and associated plume. Natural draft towers would be up to 520 ft tall. Mechanical draft towers would be up to 100 ft tall and would have an associated noise impact. Historic and Archaeological

Resources No change Environmental Justice No change 8.2.4 Purchased Electrical Power 10 If available, purchased power from other sources would potentially obviate the need to renew 11 the JAFNPP OL. The New York State energy plan (NYSERDA 2002) is designed to promote 12 competition in energy supply markets by facilitating participation by non-utility suppliers. A 13 Environmental Impacts of Alternatives June 2007 8-39 Draft NUREG-1437, Supplement 31 regulatory structure is in place to appropriately anticipate and meet electricity demands. The 1 New York Independent System Operator (NYISO) anticipates that adequate supplies of 2 electricity will be available to meet anticipated future demands through at least 2021. In theory, 3 purchased power is a feasible alternative to JAFNPP license renewal. There is no assurance, 4 however, that sufficient capacity or energy would be available during the entire time frame of 5 2014 to 2034 to replace the approximately 881 MWe of baseload generation from JAFNPP. For 6 example, EIA projects that total gross U.S. imports of electricity from Canada and Mexico will 7 gradually increase from 38.4 billion kWh in year 2001 to 48.9 billion kWh in year 2005 and then 8 gradually decrease to 24.4 billion kWh in year 2020 (DOE/EIA 2004). On balance, it appears 9 unlikely that electricity imported from Canada or Mexico would be able to replace JAFNPP's 10 generating capacity.

11 If power to replace JAFNPP capacity were purchased from sources in the U.S. or from a foreign 12 country, the generating technology would likely be one of those described in this draft SEIS and 13 in the GEIS (i.e., coal, natural gas, or nuclear). The description of the environmental impacts of 14 other technologies in Chapter 8 of the GEIS is representative of the purchased electrical power 15 alternative to renewal of the JAFNPP OL. Thus, the environmental impacts of imported power 16 would still occur but would be located elsewhere within the region, nation, or in another country.

17 For these reasons, the NRC staff does not believe that purchasing power to make up for the 18 generation at JAFNPP is a meaningful alternative that requires independent analysis.

19 8.2.5 Other Alternatives 20 Other generation technologies considered by NRC are discussed in Sections 8.2.5.1 through 21 8.2.5.11.

22 8.2.5.1 Oil-Fired Generation 23 EIA projects that oil-fired power plants will account for very little of the new generation capacity 24 in the U.S. through the year 2030 because of higher fuel costs and lower efficiencies (DOE/EIA 25 2007). Oil-fired operation is more expensive than nuclear or coal-fired operation. Future 26 increases in oil prices are expected to make oil-fired generation increasingly more expensive 27 than coal-fired generation. The high cost of oil has prompted a steady decline in its use for 28 electricity generation. Increasing domestic concer ns over oil security will only exacerbate the 29 move away from oil-fired electricity generation. Therefore, the NRC staff does not consider oil-30 fired generation by itself a feasible alternative to the baseload generation of JAFNPP.

31 8.2.5.2 Wind Power 32 Wind power, by itself, is not suitable for large baseload capacity. As discussed in Section 8.3.1 33 of the GEIS, wind has a high degree of intermittency, and average annual capacity factors for 34 wind power plants are relatively low (less than 30 percent). Wind power, in conjunction with 35 energy storage mechanisms, might serve as a m eans of providing baseload power. However, 36 Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-40 June 2007 current energy storage technologies are too expensive for wind power to serve as a large 1 baseload generator.

2 Most of western New York is in wind-power Class 2 or 3, in which the average wind speed is 4.4 3 to 5.6 meters per second (m/s) (Elliott et al. 1986). There is a narrow band of Class 3 and 4 4 areas along Lake Ontario. Wind turbines are economical in Class 3 through 7 areas, in which 5 the average wind speeds are 7.0 to >8.8 m/s (DOE 2005). Wind turbines typically operate at 25 6 to 35 percent capacity factor compared to 80 to 95 percent for a baseload power plant (NWPPC 7 2000). Because the largest commercially available wind turbines produce in the range of 1 MW 8 to 3 MW, 294 to 881 units would be required to replace the JAFNPP generating capacity.

9 As of September 2006, there were approximately 280 MW of grid-connected wind-power 10 facilities in New York State, with an additional 255 MW of additional capacity in various stages 11 of planning (AWEA 2006). The New York State Energy Research and Development Authority 12 (NYSERDA) estimates there is a statewide potential for approximately 17,000 MW of installed 13 capacity, of which approximately 3200 MW would be available for the peak summer load 14 (NYSERDA 2002). Access to many of the best wind-power sites would require extensive road 15 building, clearing (for towers and blades), and leveling (for the tower bases and associated 16 facilities) in steep terrain. Also, many of the best quality wind sites are on ridges and hilltops 17 that would have greater archeological sensitivity than surrounding areas. For these reasons, 18 development of large-scale, land-based wind-power facilities are likely to be costly and would 19 have MODERATE to LARGE impacts on aesthetics, archaeological resources, land use, and 20 terrestrial ecology.

21 The offshore wind speeds on Lake Ontario are higher than those onshore and would thus 22 support greater energy production than onshore facilities. Development of an offshore wind-23 power facility would impact shipping lanes, may disrupt the aquatic ecology, and would be 24 visible for many miles, resulting in considerable aesthetic impacts. These impacts would be 25 MODERATE to LARGE.

26 For these reasons, the NRC staff concludes that wi nd power alone is not a feasible substitute at 27 this time for the baseload generation from JAFNPP. However, the NRC staff recognizes that 28 wind power projects are being developed in areas with significant wind potential. Therefore, it is 29 reasonable to include wind power in a combination of alternatives that would replace the 30 generation from JAFNPP. Combined alternat ives are discussed in Section 8.2.6.

31 8.2.5.3 Solar Power 32 Solar technologies use the sun's energy and light to provide heat, cooling, light, hot water, and 33 electricity for homes, businesses, and industry. Solar-power technologies, both photovoltaic 34 and thermal, cannot currently compete with conventional fossil-fuel technologies in grid-35 connected applications due to higher capital costs per kilowatt of capacity. The average 36 capacity factor for photovoltaic cells is approximately 25 percent and for solar thermal systems, 37 Environmental Impacts of Alternatives June 2007 8-41 Draft NUREG-1437, Supplement 31 25 to 40 percent. These capacity factors are low because solar power is an intermittent 1 resource, providing power when the sun is strong, whereas JAFNPP provides constant 2 baseload power. Solar technologies simply cannot make up for the capacity from JAFNPP 3 when the sun is not shining.

4 There can be substantial impacts to natural resources (e.g., wildlife habitat, land use, 5 aesthetics) from construction of solar-generating facilities. As stated in the GEIS, land 6 requirements are high. Based on the land requirement of 14 ac for every 1 MWe generated, 7 over 12,000 ac would be required to replace the approximately 881 MWe produced by JAFNPP.

8 There is not enough land for either type of solar electric system at the existing JAFNPP site, and 9 both would have large environmental impacts at an alternate site.

10 The construction impacts would be similar to those associated with a large wind farm, as 11 discussed in Section 8.2.5.2. The operating fa cility would also have considerable aesthetic 12 impact. 13 Because of the natural resource impacts (land, ecological, and aesthetic), and high technology 14 costs, solar power is not deemed a feasible baseload alternative to license renewal of JAFNPP.

15 However, the NRC staff recognizes that distributed solar power does provide generation and 16 that during the license renewal period, generation from solar power could continue to grow.

17 Therefore, it is reasonable to include solar power in combinations of alternatives to replace the 18 generation from JAFNPP. Combined alternat ives are discussed in Section 8.2.6.

19 8.2.5.4 Hydropower 20 New York State has a technical potential for 2527 MW of additional installed hydroelectric 21 capacity by the year 2022, only 909 MW of which represents summer peak capacity. If all this 22 capacity were developed, it would be enough to replace the 881-MW generating capacity of 23 JAFNPP. However, as stated in Section 8.3.4 of the GEIS, hydropower's percentage of U.S.

24 generating capacity is expected to decline because hydroelectric facilities have become difficult 25 to site as a result of public concern about flooding, destruction of natural habitat, and alteration 26 of natural river courses. DOE/EIA states that potential sites for hydroelectric dams have already 27 been largely established in the U.S., and environmental concerns are expected to prevent the 28 development of any new sites (DOE/EIA 2002).

29 The NRC staff estimates in the GEIS that land requirements for hydroelectric power are 30 approximately 1 million ac per 1000 MWe. Replacement of JAFNPP generating capacity would 31 require flooding slightly less than this amount of land. Due to the large land-use and related 32 environmental and ecological resource impacts associated with siting hydroelectric facilities 33 large enough to replace JAFNPP, the NRC staff concludes that local hydropower is not a 34 feasible alternative to JAFNPP OL renewal on its own. Any attempts to site hydroelectric 35 facilities large enough to replace JAFNPP would result in LARGE environmental impacts.

36 Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-42 June 2007 8.2.5.5 Geothermal Energy 1 Geothermal energy has an average capacity factor of 90 percent and can be used for baseload 2 power where available. However, the NRC staff states in the GEIS that geothermal technology 3 is not widely used as baseload generation because of the limited geographical availability of the 4 resource and immature status of the technology. As illustrated by Figure 8.4 in the GEIS, 5 geothermal power plants are most likely to be sited in the western continental U.S., Alaska, and 6 Hawaii where geothermal reservoirs are prev alent. A study commissioned by NYSERDA and 7 the DOE, completed in 1996, found that there is some potential for geothermal electric power 8 production in western upstate New York but that high cost inhibits its development (NRC 2006).

9 Therefore, the NRC staff concludes that geothermal energy is not a feasible alternative to 10 renewal of the JAFNPP OL.

11 8.2.5.6 Wood Waste 12 The use of wood waste to generate electricity is limited largely to states with significant wood 13 resources, such as California, Georgia, Maine, Michigan, Minnesota, Oregon, and Washington.

14 Electric power is generated in these states by the pulp, paper, and paperboard industries, which 15 consume wood and wood waste for energy, benefiting from the use of waste materials that 16 would otherwise represent a disposal problem.

17 The NRC staff states in the GEIS that a wood-burning facility can provide baseload power and 18 operate with an average annual capacity factor of around 70 to 80 percent and with 20 to 19 25 percent efficiency. The required fuels are variable and site-specific. A significant barrier to 20 using wood waste to generate electricity is the high delivered-fuel cost and high construction 21 cost per MW of generating capacity. The larger wood-waste power plants generate only 40 to 22 50 MWe. The overall construction impact per MW of installed capacity is estimated in the GEIS 23 to be approximately the same as that for a coal-fired power plant, although facilities using wood 24 waste for fuel would be built on smaller scales. Like coal-fired power plants, wood-waste power 25 plants require large areas for fuel storage and processing and involve the same type of 26 combustion equipment.

27 Due to uncertainties associated with obtaining sufficient wood and wood waste to fuel a 28 baseload generating facility, ecological impacts of large-scale timber cutting (e.g., soil erosion, 29 loss of wildlife habitat), and high inefficiency, the NRC staff has determined that wood waste is 30 not a feasible alternative to renewing the JAFNPP OL.

31 8.2.5.7 Municipal Solid Waste 32 Municipal waste combustors incinerate waste and use the resultant heat to generate steam, hot 33 water, or electricity. The combustion process can reduce the volume of waste by up to 34 90 percent and the weight of the waste by up to 75 percent (EPA 2006). Municipal waste 35 combustors use three basic types of technologies: mass burn, modular, and refuse-derived fuel 36 (DOE/EIA 2001). Mass burning technologies are most commonly used in the U.S. This group 37 Environmental Impacts of Alternatives June 2007 8-43 Draft NUREG-1437, Supplement 31 of technologies process raw municipal solid waste "as is," with little or no sizing, shredding, or 1 separation before combustion.

2 Growth in the municipal waste combustion industry slowed dramatically during the 1990s after 3 rapid growth during the 1980s. The slower growth was due to three primary factors: (1) the Tax 4 Reform Act of 1986, which made capital-intensive projects such as municipal waste combustion 5 facilities more expensive relative to less capital-intensive waste disposal alternative such as 6 landfills; (2) the 1994 Supreme Court decision C&A Carbone, Inc. v. Town of Clarkstown, New 7 York, 511 U.S. 383, which struck down local flow control ordinances that required waste to be 8 delivered to specific municipal waste combustion facilities rather than landfills that may have 9 had lower fees; and (3) increasingly stringent environmental regulations that increased the 10 capital cost necessary to construct and maintain municipal waste combustion facilities 11 (DOE/EIA 2001).

12 The decision to burn municipal waste to generat e energy is usually driven by the need for an 13 alternative to landfills rather than by energy considerations. The use of landfills as a waste 14 disposal option is likely to increase in the near term, but it is unlikely that many landfills will 15 begin converting waste to energy because of unfavorable economics, particularly with electricity 16 prices declining in real terms.

17 Municipal solid waste combustors generate an ash residue that is buried in landfills. The ash 18 residue is composed of bottom ash and fly ash. Bottom ash is the portion of unburned waste 19 that falls to the bottom of the grate or furnace. Fly ash is the small particles that rise from the 20 furnace during combustion. Fly ash is generally removed from flue-gases using fabric filters 21 and/or scrubbers (DOE/EIA 2001).

22 Currently there are approximately 89 waste-to-energy power plants operating in the U.S. These 23 power plants generate approximately 2800 MWe or an average of 31.5 MWe per power plant 24 (IWSA 2006), which is much smaller than needed to replace the 881 MWe of JAFNPP.

25 The NRC staff states in the GEIS that the initial capital costs for municipal solid-waste power 26 plants are greater than for comparable steam-turbine technology at wood-waste facilities, due to 27 the need for specialized waste-separation and -handling equipment for municipal solid waste.

28 Furthermore, the overall construction impact from a waste-fired power plant is estimated in the 29 GEIS to be approximately the same as that for a coal-fired power plant. Additionally, waste-30 fired power plants have the same or greater operational impacts (including impacts on the 31 aquatic environment, air, and waste disposal). Some of these impacts would be MODERATE 32 but still larger than the environmental effects of license renewal of JAFNPP. Therefore, 33 municipal solid waste would not be a feasible alternative to renewal of the JAFNPP OL, 34 particularly at the scale required.

35 Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-44 June 2007 8.2.5.8 Other Biomass-Derived Fuels 1 In addition to wood and municipal solid-waste fuels, there are several other concepts for fueling 2 electric generators, including burning crops, converting crops to a liquid fuel such as ethanol, 3 and gasifying crops (including wood waste). In the GEIS, the NRC staff points out that none of 4 these technologies has progressed to the point of being competitive on a large scale or of being 5 reliable enough to replace a baseload power plant such as JAFNPP. For these reasons, such 6 fuels do not offer a feasible alternative to renewal of the JAFNPP OL.

7 8.2.5.9 Fuel Cells 8 Fuel cells work without combustion and therefore do not have the environmental impacts of 9 combustion. Power is produced electrochemical ly by passing a hydrogen-rich fuel over an 10 anode and air over a cathode and separating the two by an electrolyte. The only by-products 11 are heat, water, and carbon dioxide. Hydrogen fuel can come from a variety of hydrocarbon 12 resources by subjecting them to steam under pressure. Natural gas is typically used as the 13 source of hydrogen.

14 Phosphoric acid fuel cells are generally considered first-generation technology. These fuel cells 15 are commercially available at approximately $4500 per kW of installed capacity (DOE 2006).

16 Higher-temperature second-generation fuel cells achieve higher fuel-to-electricity and thermal 17 efficiencies. The higher temperatures contribute to improved efficiencies and give the second-18 generation fuel cells the capability to generate steam for cogeneration and combined-cycle 19 operations.

20 DOE has launched a major initiative, the Solid State Energy Conversion Alliance, to bring about 21 dramatic reductions in fuel cell costs. The goal is to cut the cost to as low as $400 per kW by 22 2010, which would make fuel cells competitive for virtually every type of power application (DOE 23 2006). For comparison, the installed capacity cost for a natural gas-fired, combined-cycle 24 power plant is about $400 per kW (DOE 2006). At present, fuel cells are not economically or 25 technologically competitive with other alternatives for baseload electricity generation and are 26 consequently not a feasible alternative to renewal of the JAFNPP OL.

27 8.2.5.10 Delayed Retirement 28 As noted in the GEIS, extending the lives of existing non-nuclear generating power plants 29 beyond the time they were originally scheduled to be retired represents another potential 30 alternative to license renewal. Even without retiring any generating units, Entergy expects to 31 require additional capacity in the near future. Thus, even if substantial capacity were scheduled 32 for retirement and would be delayed, some of the delayed retirement would be needed just to 33 meet load growth.

34 Older power plants that may be candidates for retirement tend to use less efficient generation 35 and pollution control technologies than modern power plants. Therefore, substantial upgrades 36 Environmental Impacts of Alternatives June 2007 8-45 Draft NUREG-1437, Supplement 31 are typically required to achieve efficiencies necessary to cost effectively extend operations and 1 meet applicable environmental standards.

2 The GEIS states that NYISO load and capacity projections assume that nuclear generating units 3 in the State will cease operation upon expiration of their current OLs but do not acknowledge 4 retirement of any non-nuclear generating units in the State from 2005 through 2021. Therefore, 5 any such retirements that do occur in this period would merely act to further increase projected 6 demand. 7 Based on this information, the NRC staff concluded that delayed retirement of other Entergy 8 generating units would not be a feasible alternative to renewal of the JAFNPP OL.

9 8.2.5.11 Utility-Sponsored Conservation 10 The utility-sponsored conservation alternative refers to a situation in which JAFNPP ceases to 11 operate, no new generation is brought online to meet the lost generation, and the lost 12 generation is replaced by more efficient use of electricity. More efficient use would arise from 13 utility-sponsored conservation programs, potentially including energy audits, incentives to install 14 energy-efficient equipment, and informational programs to inform electricity consumers of the 15 benefits of, and possibilities for, electricity conservation.

16 Demand-side management resource strategies aimed at increasing energy efficiency on the 17 customer side of the electric meter generally fall under the following categories:

18 Energy efficiency-selecting equipment that performs the same work with less energy input 19 Load response-customers who agree to respond to utility requests to reduce use during 20 times of utility peak demand 21 Load management, which encourages customers to reduce their usage during peak times 22 of day and peak season through the use of time-of-use rates, seasonal rates, and 23 interruptible contracts 24 Direct load control, in which a utility interrupts power supply to customer equipment 25 Typically, demand-side management induced load reductions are acknowledged in load 26 forecasts and cannot therefore be used as credits to offset the power generated by JAFNPP.

27 As a practical matter, it would be impossible to increase the energy savings by an additional 28 881 MWe to replace the JAFNPP generating capability, particularly in upstate New York, which 29 represents a relatively small fraction of electrical load in the State.

30 Therefore, the NRC staff does not consider energy efficiency, by itself, a feasible alternative to 31 license renewal. However, the NRC staff recognizes that energy conservation is promoted and 32 that increases in energy efficiency occur as a normal result of replacing older equipment with 33 Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-46 June 2007 modern equipment. It is reasonable to include conservation in a combination of generation 1 sources that would replace JAFNPP. Combined alternatives are discussed in Section 8.2.6.

2 8.2.6 Combination of Alternatives 3 Even though individual alternatives to JAFNPP might not be sufficient on their own to replace 4 JAFNPP capacity due to the small size of the resource or lack of cost-effective opportunities, it 5 is conceivable that a combination of alternatives might be cost-effective.

6 There are many possible combinations of alternatives. As discussed previously, these 7 combinations would include baseload gas-fired or coal-fired power plants, purchased power, 8 alternative and renewable technologies, and conservation. For the purpose of this discussion, 9 one combination of alternatives has been assumed: 600 MWe of generation from a combined-10 cycle facility at the JAFNPP site, 81 MWe of energy conservation, and 200 MWe purchased 11 from other generators. The impacts of other combinations, such as those from combinations 12 that include wind or solar power, would be different and possibly less than the assumed 13 combination. In some areas, such as the aesthetic impact of solar panel or wind turbines, the 14 impacts would be at least as large as the impact of the assumed combination of alternatives. In 15 other areas, such as waste, impacts would be smaller for these alternative technologies.

16 Table 8-8 contains a summary of the environmental impacts of an assumed combination. The 17 impacts associated with the combined-cycle natural gas-fired units are based on the gas-fired 18 generation impact assumptions discussed in Section 8.2.2, adjusted for the reduced generation 19 capacity. While the demand-side management measures would have few environmental 20 impacts, operation of the new natural gas-fired power plant would result in increased emissions 21 and environmental impacts. The environmental impacts associated with power purchased from 22 other generators would still occur but would be located elsewhere within the region or nation, as 23 discussed in Section 8.2.4. The impacts of purchased power are not shown in Table 8-8. The 24 NRC staff concludes that it is very unlikely that the environmental impacts of any reasonable 25 combination of generating and conservation options would be reduced to the level of impacts 26 associated with renewal of the JAFNPP OL.

27 8.3 Summary of Alternatives Considered 28 As indicated in Chapter 4 of this draft SEIS, the environmental impacts of the proposed action, 29 license renewal of JAFNPP, are SMALL for all impact categories (except collective offsite 30 radiological impacts from the fuel cycle and from high-level waste and spent fuel disposal, for 31 which a single significance level was not assigned). The alternative actions, i.e., no-action 32 alternative (discussed in Section 8.1), new generation alternatives (from coal, natural gas, and 33 nuclear discussed in Sections 8.2.1 through 8.2.3, respectively), purchased electrical power 34 (discussed in Section 8.2.4), alternative technologies (discussed in Section 8.2.5), and the 35 combination of alternatives (discussed in Section 8.2.6) were considered.

36 Environmental Impacts of Alternatives June 2007 8-47 Draft NUREG-1437, Supplement 31 Table 8-8. Summary of Environmental Impacts of an Assumed Combination of Generation-1 Does Not Include Impacts from Purchased Generation Once-Through Cooling Alternative 2 JAFNPP Site Alternate Site Impact Category Impact Comments Impact Comments Land Use SMALL to MODERATE The natural gas-fired power plant would be constructed on undeveloped portions of the JAFNPP site. It would require upwards of 110 ac for power block, offices, roads, parking areas, and a gas pipeline ROW. It would use existing infrastructure, minimizing new land requirements. There would be additional land impacts for construction of an underground gas pipeline.

SMALL to LARGE Land-use requirements would be larger at an alternate site than at the JAFNPP site because of the need for additional infrastructure such as transmission facilities, roads, parking areas, office buildings, and cooling system. The total impact would depend on whether the alternate site had been previously disturbed. Ecology SMALL to MODERATE The natural gas-fired alternative would use undeveloped areas at the JAFNPP site. There would be potential for significant habitat loss and fragmentation and reduced productivity and biological diversity.

SMALL to LARGE Impacts would depend on whether the alternate site had been previously developed. Factors to consider include location and ecology of the site and transmission line route. In total, impacts would include habitat degradation, fragmentation or loss as a result of construction activities and conversion of land to industrial use. Ecological communities might experience reduced productivity and biological diversity from disturbing previously intact land.

Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-48 June 2007 1 Table 8-8 (cont.) JAFNPP Site Alternate Site Impact Category Impact Comments Impact Comments Water Use and

Quality-Surface Water SMALL Combined-cycle units have lower water requirements than nuclear and coal-fired power plants. The natural gas-fired alternative would use existing once-through cooling system to the degree necessary.

SMALL to MODERATECombined-cycle units have lower water requirements than nuclear and coal-fired power plants. The natural gas-fired alternative would use closed-cycle cooling to the degree necessary. Total impacts would depend on the volume of water withdrawal, the constituents of the discharge water, the characteristics of the surface water or groundwater source, and the required new intake

structures. Water Use and Quality-Groundwater SMALL Use of groundwater is very unlikely.

SMALL to MODERATEImpact depends on volume of water withdrawal and discharge. Air Quality MODERATE Sulfur oxides: 34 tons/yr Nitrogen oxides: 109 tons/yr Carbon monoxide: 7 tons/yr PM 10 particulates: 126 tons/yr Other: (1) hazardous air pollutants, including arsenic, formaldehyde, and nickel and (2) carbon dioxide emissions, which contribute to global warming. MODERATEThe impacts at an unnamed alternate site would be the same as those for the JAFNPP site.

Environmental Impacts of Alternatives June 2007 8-49 Draft NUREG-1437, Supplement 31 1 Table 8-8 (cont.) JAFNPP Site Alternate Site Impact Category Impact Comments Impact Comments Waste SMALL Minimal waste product from fuel combination. SMALL The impacts at an unnamed alternate site would be the same as those for the JAFNPP site. Human Health SMALL Impacts would be minor. SMALL The impacts at an unnamed alternate site would be the same as those for the JAFNPP site. Socioeconomics SMALL to MODERATE During power plant construction, impacts would

be MODERATE. Construction activities would place noticeable burdens on

existing infrastructure, including housing and transportation. During plant operations, employment would decrease from 716 permanent workers to approximately 50. Impacts on housing and vitality of the local economy would be negative. Overall, socioeconomic impacts from operation would be SMALL.

SMALL to LARGE Construction and operation impacts at an alternate site would be similar to those at the JAFNPP site. Socioeconomic impacts to the local community would depend on the location of the alternate site and would vary from SMALL to MODERATE.

Transportation MODERATE Construction-related transportation impacts would be MODERATE. MODERATE Transportation impacts of the natural gas-fired alternative at an alternate site would be similar to those at the JAFNPP site.

Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-50 June 2007 1 Table 8-8 (cont.) JAFNPP Site Alternate Site Impact Category Impact Comments Impact Comments Aesthetics SMALL There would be visual aesthetic impacts associated with power plant buildings and structures. There would be both continuous and intermittent noise impacts from power plant operation. MODERATE to LARGE Visual aesthetic impacts would be similar to the JAFNPP site, but the significance of the impacts would depend on the location of the alternate site. The natural gas-fired power plant at an alternate site could require transmission lines, with attendant aesthetic

impacts. Historic and Archeological

Resources SMALL to MODERATE Cultural resource studies would be needed to identify, evaluate, and address the mitigation of potential cultural resource impacts from the construction of a new power

plant. SMALL to MODERATE The historic and archaeological resource impacts of the natural gas-fired power plant at an alternate site would be similar to those at the JAFNPP site. Environmental

Justice SMALL to MODERATE Impacts to minority and low-income populations would vary depending on the location of the power plant site and other support facilities.

SMALL to MODERATE The impacts at an alternate site would be the same as those for

the JAFNPP site.

2 The no-action alternative would require the replacement of electrical generating capacity by 3 (1) demand-side management and energy conserva tion, (2) power purchased from other 4 electricity providers, (3) generating alternatives other than JAFNPP, or (4) some combination of 5 these options. For each of the new generation alternatives (coal, natural gas, and nuclear), the 6 environmental impacts would not be less than the impacts of license renewal. For example, the 7 land-disturbance impacts resulting from construction of any new facility would be greater than 8 the impacts of continued operation of JAFNPP. The impacts of purchased electrical power 9 (imported power) would still occur but would occur elsewhere. Alternative technologies are not 10 considered feasible at this time for complete power replacement, and it is very unlikely that the 11 environmental impacts of any reasonable combination of generation and conservation options 12 would be reduced to the level of impacts associated with renewal of the JAFNPP OL.

13 Environmental Impacts of Alternatives June 2007 8-51 Draft NUREG-1437, Supplement 31 The NRC staff concludes that the alternative acti ons, including the no-action alternative, may 1 have environmental effects in at least some of the impact categories that would reach 2 MODERATE or LARGE significance.

3 8.4 References 4 10 CFR Part 50.

Code of Federal Regulations, Title 10 , Energy, Part 50, "Domestic Licensing of 5 Production and Utilization Facilities."

6 10 CFR Part 51.

Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 7 Protection Regulations for Domestic Licensing and Related Functions."

8 10 CFR Part 52.

Code of Federal Regulations, Title 10, Energy, Part 52, "Early Site Permits; 9 Standard Design Certifications; and Combined Licenses for Nuclear Power Plants."

10 40 CFR Part 51.

Code of Federal Regulations, Title 40, Protection of Environment, Part 51, 11 "Requirements for Preparation, Adoption, and Submittal of Implementation Plans."

12 40 CFR Part 60.

Code of Federal Regulations, Title 40, Protection of Environment, Part 60, 13 "Standards of Performance for New Stationary Sources."

14 American Wind Energy Association (AWEA). 2006. New York State Wind Energy 15 Development. Available URL: http://www.awea.org/projects/newyork.html. (Accessed 16 December 28, 2006.)

17 C&A Carbone, Inc. v. Town of Clarkstown, New York.

511 U.S. 383. 1994. U.S. Supreme 18 Court Reports.

19 Clean Air Act of 1970. 42 USC 7401, et seq.

20 Clean Water Act of 1977. Federal Water Pollution Control Act of 1977. 33 USC 1251, et seq.

21 Elliott, D.L., C.G. Holladay, W.R. Barchet, H.P. Foote, and W.F. Sandusky. 1986.

Wind Energy 22 Resource Atlas of the United States. DOE/CH 10093-4, U.S. Department of Energy, 23 Washington, D.C. Available URL: http://rredc.nrel.gov/wind/pubs/atlas (accessed December 28, 24 2006). 25 Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2006.

26 James A. FitzPatrick Nuclear Power Plant - License Renewal Application, Appendix E:

27 Applicant's Environmental Report, Operating License Renewal Stage.

Lycoming, New York.

28 Accessible at ML062160557.

29 Environmental Impacts of Alternatives Draft NUREG-1437, Supplement 31 8-52 June 2007 Gabbard, A. 1993. "Coal Combustion: Nuclear Resource or Danger."

Oak Ridge National 1 Laboratory Review. Oak Ridge National Laboratory: Oak Ridge, Tennessee. Available URL:

2 http://www.ornl.gov/info/ornlreview/rev26-34/text/colmain.html (accessed October 18, 2004.)

3 Integrated Waste Services Association (IWSA). 2006. "America's Own Energy Source."

4 Available URL: http://www.wte.org/aoes.shtml (accessed December 28, 2006.) Accessible at 5 ML071130360.

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

7 New York State Energy Research and De velopment Authority (NYSERDA). 2002.

2002 State 8 Energy Plan and Final Environmental Impact Statement. Available URL: http://www.nyserda 9 .org/sep.html (accessed October 18, 2004.)

10 Northwest Power Planning Council (NWPPC). 2000. "Northwest Power Supply 11 Adequacy/Reliability Study Phase I Report." Available URL: http://www.nwcouncil.org/library/

12 2000/2000-4.pdf (accessed December 28, 2006.)

13 Resource Conservation and Recovery Act of 1976. 42 USC 6901, et seq.

14 Rivers and Harbors Appropriation Act of 1899. 33 USC 403, et seq.

15 U.S. Department of Energy (DOE). 2005. "U.S. Wind Energy Resource Potential Map."

16 Available URL: http://www1.eere.energy.gov/windandhydro/wind_potential.html (accessed 17 December 28, 2006.) Accessible at ML071130366.

18 U.S. Department of Energy (DOE). 2006. "Future Fuel Cells R&D." Available URL:

19 http://www.fossil.energy.gov/programs/powersystems/fuelcells (accessed December 28, 2006.)

20 U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2001.

Renewable 21 Energy 2000: Issues and Trends. DOE/EIA-0628 (2000). Washington, D.C. Available URL:

22 http://tonto.eia.doe.gov/ftproot/renewables/06282000.pdf (accessed December 28, 2006.)

23 U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2002.

International 24 Energy Outlook 2002. DOE/EIA-0484 (2002). Washington, D.C. Available URL:

25 http://www.eia.doe.gov/pub/pdf/international/0484(2002).pdf (accessed December 28, 2006.)

26 U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2004.

Annual 27 Energy Outlook 2004 with Projections to 2025. Washington, D.C.

28 U.S. Department of Energy/Energy Information Administration (DOE/EIA). 2007.

Annual 29 Energy Outlook 2007 with Projections to 2030. Washington, D.C., February, 2007. Available 30 URL: http://www.eia.doe.gov/oiaf/aeo/i ndex.html (accessed April 12, 2007).

31 Environmental Impacts of Alternatives June 2007 8-53 Draft NUREG-1437, Supplement 31 U.S. Environmental Protection Agency (EPA). 1 998. "Revision of Standards of Performance for 1 Nitrogen Oxide Emissions From New Fossil-Fuel Fi red Steam Generating Units; Revisions to 2 Reporting Requirements for Standards of Performance for New Fossil-Fuel Fired Steam 3 Generating Units, Final Rule."

Federal Register Vol. 63, No. 179, pp. 49442-49455.

4 Washington, D.C. (September 16, 1998.)

5 U.S. Environmental Protection Agency (EPA). 1 999. "Regional Haze Regulations, Final Rule."

6 Federal Register Vol. 64, No. 126, pp. 35714-3577. Washington, D.C. (July 1, 1999.)

7 U.S. Environmental Protection Agency (EPA). 2000a. "Notice of Regulatory Determination on 8 Wastes From the Combustion of Fossil Fuels."

Federal Register, Vol. 65, No. 99, pp. 32214-9 32237. Washington, D.C.

10 U.S. Environmental Protection Agency (EPA). 2000b. "Regulatory Finding on the Emissions of 11 Hazardous Air Pollutants from Electric Utility Steam Generating Units." Federal Register. 12 Vol. 65, No. 245, pp. 79825-79831. Washington, D.C. (December 20, 2000.)

13 U.S. Environmental Protection Agency (EPA). 2006. "Municipal Solid Waste Disposal."

14 Available URL: http://www.epa.gov/epaoswer/non-hw/muncpl/disposal.htm (accessed 15 December 28, 2006).

16 U.S. Nuclear Regulatory Commission (NRC). 1988. Final Generic Impact Statement on 17 Decommissioning of Nuclear Facilities. NUREG-0586. Washington, D.C.

18 U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement 19 for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2. Washington, D.C.

20 U.S. Nuclear Regulatory Commission (NRC). 1999.

Final Generic Environmental Impact 21 Statement for License Renewal of Nuclear Plants: Main Report. NUREG-1437, Volume 1, 22 Addendum 1. Washington, D.C.

23 U.S. Nuclear Regulatory Commission (NRC). 2002. Generic Environmental Impact Statement 24 on Decommissioning of Nuclear Facilities, Supplement 1, Regarding the Decommissioning of 25 Nuclear Power Reactors. NUREG-0586, Supplement 1, Volumes 1 and 2. Washington, D.C.

26

June 2007 9-1 Draft NUREG-1437, Supplement 31 9.0

SUMMARY

AND CONCLUSIONS 1 By letter dated July 31, 2006, Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear 2 Operations, Inc. (Entergy) submitted an application to the U.S. Nuclear Regulatory Commission 3 (NRC) to renew the operating license (OL) for James A. FitzPatrick Nuclear Power Plant 4 (JAFNPP) for an additional 20-year period (Entergy 2006a). If the OL is renewed, State 5 regulatory agencies and Entergy will ultimately decide whether the plant will continue to operate 6 based on factors such as the need for power or other matters within the State's jurisdiction or 7 the purview of the owners. If the OL is not renewed, then the plant must be shut down on or 8 before the expiration of the current OL, which expires on October 17, 2014.

9 Section 102 of the National Environmental Policy Act (NEPA) (42 USC 4321) directs that an 10 environmental impact statement (EIS) is required for major Federal actions that significantly 11 affect the quality of the human environment. The NRC has implemented Section 102 of NEPA 12 in Part 51 of Title 10 of the Code of Federal Regulations (10 CFR Part 51). Part 51 identifies 13 licensing and regulatory actions that require an EIS. In 10 CFR 51.20(b)(2), the Commission 14 requires preparation of an EIS or a supplement to an EIS for renewal of a reactor OL; 10 CFR 15 51.95(c) states that the EIS prepared at the OL renewal stage will be a supplement to the 16 Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), 17 NUREG-1437, Volumes 1 and 2 (NRC 1996; 1999).

(1) 18 Upon acceptance of the Entergy application, the NRC began the environmental review process 19 described in 10 CFR Part 51 by publishing on September 20, 2006, a Notice of Intent to prepare 20 an EIS and conduct scoping (NRC 2006a). The NRC staff held public scoping meetings on 21 October 12, 2006, in Oswego, New York (NRC 2006b), and conducted a site audit in 22 December 2006 (NRC 2007b). The NRC staff reviewed Entergy's environmental report (ER) for 23 JAFNPP (Entergy 2006b) and compared it to the GEIS, consulted with other agencies, and 24 conducted an independent review of the issues following the guidance set forth in NUREG-25 1555, Supplement 1, Standard Review Plans for Environmental Reviews for Nuclear Power 26 Plants, Supplement 1: Operating License Renewal (NRC 2000). The NRC staff also 27 considered the public comments received during the scoping process for preparation of this 28 draft supplemental environmental impact statement (draft SEIS) for JAFNPP (NRC 2007a). The 29 public comments received during the scoping process that were considered to be within the 30 scope of the environmental review are provided in Appendix A of this draft SEIS.

31 The NRC staff will hold two public meetings in Oswego, New York, in August 2007, to describe 32 the preliminary results of the NRC environmental review, to answer questions, and to provide 33 members of the public with information to assist them in formulating their comments on this draft 34 (1) The GEIS was issued in 1996, and Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to GEIS include Addendum 1.

Summary and Conclusions Draft NUREG-1437, Supplement 31 9-2 June 2007 SEIS. When the comment period ends, the NRC staff will consider and address all of the 1 comments received. These comments will be addressed in Appendix A of the final SEIS.

2 This draft SEIS includes the NRC staff's prelim inary analysis that considers and weighs the 3 environmental effects of the proposed action, including cumulative impacts, the environmental 4 impacts of alternatives to the proposed action, and mitigation measures available for reducing or 5 avoiding adverse effects. This draft SEIS also includes the NRC staff's preliminary 6 recommendation regarding the proposed action.

7 The NRC has adopted the following statement of pur pose and need for license renewal from the 8 GEIS: 9 The purpose and need for the proposed action (renewal of an operating license) is to 10 provide an option that allows for power generation capability beyond the term of a current 11 nuclear power plant operating license to meet future system generating needs, as such 12 needs may be determined by State, utility, and, where authorized, Federal (other than NRC) 13 decision makers.

14 The evaluation criterion for the NRC staff's environmental review, as defined in 10 CFR 15 51.95(c)(4) and the GEIS, is to determine 16 ... whether or not the adverse environmental impacts of license renewal are so great that 17 preserving the option of license renewal for energy planning decision makers would be 18 unreasonable.

19 Both the statement of purpose and need and the evaluation criterion implicitly acknowledge that 20 there are factors, in addition to license renewal, that will ultimately determine whether an 21 existing nuclear power plant continues to operate beyond the period of the current OL.

22 NRC regulations [10 CFR 51.95(c)(2)] contain the following statement regarding the content of 23 SEISs prepared at the license renewal stage:

24 The supplemental environmental impact statement for license renewal is not required to 25 include discussion of need for power or the economic costs and economic benefits of the 26 proposed action or of alternatives to the proposed action except insofar as such benefits 27 and costs are either essential for a determination regarding the inclusion of an alternative in 28 the range of alternatives considered or relevant to mitigation. In addition, the supplemental 29 environmental impact statement prepared at the license renewal stage need not discuss 30 other issues not related to the environmental effects of the proposed action and the 31 alternatives, or any aspect of the storage of spent fuel for the facility within the scope of the 32 generic determination in § 51.23(a) and in accordance with § 51.23(b).

33 The GEIS contains the results of a systematic evaluation of the consequences of renewing an 34 OL and operating a nuclear power plant for an additional 20 years. It evaluates 35 Summary and Conclusions June 2007 9-3 Draft NUREG-1437, Supplement 31 92 environmental issues using the NRC's three-level standard of significance-SMALL, 1 MODERATE, or LARGE-developed using the Council on Environmental Quality guidelines.

2 The following definitions of the three significance levels are set forth in the footnotes to 3 Table B-1 of 10 CFR Part 51, Subpart A, Appendix B:

4 SMALL - Environmental effects are not detectable or are so minor that they will neither 5 destabilize nor noticeably alter any important attribute of the resource.

6 MODERATE - Environmental effects are sufficient to alter noticeably, but not to destabilize, 7 important attributes of the resource.

8 LARGE - Environmental effects are clearly noticeable and are sufficient to destabilize 9 important attributes of the resource.

10 For 69 of the 92 issues considered in the GEIS, the NRC staff analysis in the GEIS shows the 11 following:

12 (1) The environmental impacts associated wi th the issue have been determined to apply 13 either to all plants or, for some issues, to plants having a specific type of cooling system 14 or other specified plant or site characteristics.

15 (2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 16 the impacts (except for collective off-site radiological impacts from the fuel cycle and 17 from high-level waste [HLW] and spent fuel disposal).

18 (3) Mitigation of adverse impacts associated with the issue has been considered in the 19 analysis, and it has been determined that additional plant-specific mitigation measures 20 are likely not to be sufficiently beneficial to warrant implementation.

21 These 69 issues were identified in the GEIS as Category 1 issues. In the absence of new and 22 significant information, the NRC staff relied on conclusions in the GEIS for issues designated 23 Category 1 in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B. The NRC staff also 24 determined that information provided during the public comment period did not identify any new 25 issue that requires site-specific assessment.

26 Of the 23 issues that do not meet the criteria set forth above, 21 are classified as Category 2 27 issues requiring analysis in a plant-specific supplement to the GEIS. The remaining two issues, 28 environmental justice and chronic effects of electromagnetic fields, were not categorized.

29 Environmental justice was not evaluated on a generic basis in the GEIS and must be addressed 30 in the draft SEIS. Information on the chronic effects of electromagnetic fields was not 31 conclusive at the time the GEIS was prepared.

32 This draft SEIS documents the NRC staff's c onsideration of all 92 environmental issues 33 identified in the GEIS. The NRC staff consider ed the environmental impacts associated with 34 Summary and Conclusions Draft NUREG-1437, Supplement 31 9-4 June 2007 alternatives to license renewal and compared the environmental impacts of license renewal and 1 the alternatives. The alternatives to license renewal that were considered include the no-action 2 alternative (not renewing the OL for JAFNPP) and alternative methods of power generation.

3 These alternatives were evaluated assuming that the replacement power generation plant is 4 located at either the JAFNPP site or some other unspecified location.

5 9.1 Environmental Impacts of the Proposed Action-License Renewal 6 Entergy and the NRC staff have established independent processes for identifying and 7 evaluating the significance of any new inform ation on the environmental impacts of license 8 renewal. Neither Entergy nor the NRC staff has identified information that is both new and 9 significant related to Category 1 issues that would call into question the conclusions in the 10 GEIS. Similarly, neither the scoping process, Entergy, nor the NRC staff has identified any new 11 issue applicable to JAFNPP that has a significa nt environmental impact. Therefore, the NRC 12 staff relies upon the conclusions of the GEIS for all Category 1 issues that are applicable to 13 JAFNPP. 14 Entergy's license renewal application presents an analysis of the Category 2 issues that are 15 applicable to JAFNPP, plus environmental justice (Entergy 2006b). The NRC staff has 16 reviewed the Entergy analysis for each issue and has conducted an independent review of each 17 issue plus environmental justice. Six Category 2 issues are not applicable because they are 18 related to plant design features or site characteristics not found at JAFNPP. Four Category 2 19 issues are not discussed in this draft SEIS because they are specifically related to 20 refurbishment. Entergy has stated that its evaluation of structures and components, as required 21 by 10 CFR 54.21, did not identify any major plant refurbishment activities or modifications as 22 necessary to support the continued operation of JAFNPP, for the license renewal period 23 (Entergy 2006b). In addition, any replacement of components or additional inspection activities 24 are within the bounds of normal plant component replacement and, therefore, are not expected 25 to affect the environment outside of the bounds of the plant operations evaluated in the Final 26 Environmental Statement Related to Operation of James A. FitzPatrick Nuclear Power Plant 27 (AEC 1973).

28 Eleven Category 2 issues related to operational impacts and postulated accidents during the 29 renewal term, as well as environmental justice and chronic effects of electromagnetic fields, are 30 discussed in detail in this draft SEIS. Four of the Category 2 issues and environmental justice 31 apply to both refurbishment and to operation during the renewal term and are only discussed in 32 this draft SEIS in relation to operation during the renewal term. For all 11 Category 2 issues 33 and environmental justice, the NRC staff concludes that the potential environmental effects are 34 of SMALL significance in the context of the standards set forth in the GEIS. For severe accident 35 mitigation alternatives (SAMAs), the NRC sta ff concludes that a reasonable, comprehensive 36 effort was made to identify and evaluate SAMAs. Based on its review of the SAMAs for 37 Summary and Conclusions June 2007 9-5 Draft NUREG-1437, Supplement 31 JAFNPP, and the plant improvements already m ade, the NRC staff concludes that none of the 1 candidate SAMAs are cost-beneficial.

2 Mitigation measures were considered for each Ca tegory 2 issue. Current measures to mitigate 3 the environmental impacts of plant operation were found to be adequate, and no additional 4 mitigation measures were deemed sufficiently beneficial to be warranted.

5 Cumulative impacts of past, present, and reasonably foreseeable future actions were 6 considered, regardless of what agency (Federal or non-Federal) or person undertakes such 7 other actions. For purposes of this analysis, where JAFNPP license renewal impacts are 8 deemed to be SMALL, the NRC staff concluded that these impacts would not result in significant 9 cumulative impacts on potentially affected resources.

10 The following sections discuss unavoidable adverse impacts, irreversible or irretrievable 11 commitments of resources, and the relationship between local short-term use of the 12 environment and long-term productivity.

13 9.1.1 Unavoidable Adverse Impacts 14 An environmental review conducted at the license renewal stage differs from the review 15 conducted in support of a construction permit because the plant is in existence at the license 16 renewal stage and has operated for a number of years. As a result, adverse impacts associated 17 with the initial construction have been avoided, have been mitigated, or have already occurred.

18 The environmental impacts to be evaluated for license renewal are those associated with 19 refurbishment and continued operation during the renewal term.

20 The adverse impacts of continued operation identified are considered to be of SMALL 21 significance, and none warrants implementation of additional mitigation measures. The adverse 22 impacts of likely alternatives if JAFNPP ceases operation at or before the expiration of the 23 current OL will not be smaller than those associated with continued operation of this unit, and 24 they may be greater for some impact categories in some locations.

25 9.1.2 Irreversible or Irretrievable Resource Commitments 26 The commitment of resources related to construction and operation of the JAFNPP during the 27 current license period was made when the plant was built. The resource commitments to be 28 considered in this draft SEIS are associated with continued operation of the plant for an 29 additional 20 years. These resources include materials and equipment required for plant 30 maintenance and operation, the nuclear fuel used by the reactors, and ultimately, permanent 31 offsite storage space for the spent fuel assemblies.

32 The most significant resource commitments related to operation during the renewal term are the 33 fuel and the permanent storage space. JAFNPP replaces approximately one third of its fuel 34 assemblies during routine refueling outages, typically every 24 months (Entergy 2006b).

35 Summary and Conclusions Draft NUREG-1437, Supplement 31 9-6 June 2007 The likely power-generation alternatives if JAFNPP ceases operation on or before the expiration 1 of the current OL will require a commitment of resources for construction of the replacement 2 plants as well as for fuel to run the plants.

3 9.1.3 Short-Term Use Versus Long-Term Productivity 4 An initial balance between short-term use and long-term productivity of the environment at the 5 JAFNPP site was set when the plant was approved and construction began. That balance is 6 now well established. Renewal of the OL for JAFNPP and continued operation of the plant will 7 not alter the existing balance but may postpone the availability of the site for other uses. Denial 8 of the application to renew the OL will lead to shutdown of the plant and will alter the balance in 9 a manner that depends on subsequent uses of the site. For example, the environmental 10 consequences of turning the JAFNPP site into a park or an industrial facility are quite different.

11 9.2 Relative Significance of the Environmental Impacts of License Renewal 12 and Alternatives 13 The proposed action is renewal of the OL for JAFNPP. Chapter 2 describes the site, power 14 plant, and interactions of the plant with the environment. As noted in Chapter 3, no 15 refurbishment and no refurbishment impacts are expected at JAFNPP. Chapters 4 through 7 16 discuss environmental issues associated with renewal of the OL. Environmental issues 17 associated with the no-action alternative and alternatives involving power generation and use 18 reduction are discussed in Chapter 8.

19 The significance of the environmental impacts from the proposed action (approval of the 20 application for renewal of the OL), the no-action alternative (denial of the application), 21 alternatives involving nuclear or gas- or coal-fired generation of power at the JAFNPP site and 22 an unspecified "alternate site," and a combination of alternatives are compared in Table 9-1.

23 Continued use of a closed-cycle cooling system for JAFNPP is assumed for Table 9-1.

24 Substitution of once-through cooling for the recirculating cooling system in the evaluation of the 25 nuclear and gas- and coal-fired generation alternatives would result in somewhat greater 26 environmental impacts in some impact categories.

27 Table 9-1 shows that the significance of the environmental effects of the proposed action is 28 SMALL for all impact categories (except for collective offsite radiological impacts from the fuel 29 cycle and from HLW and spent fuel disposal, for which a single significance level was not 30 assigned [see Chapter 6]). The alternative actions, including the no-action alternative, may 31 have environmental effects in at least some impact categories that reach MODERATE or 32 LARGE significance.

33

Table 9-1. Summary of EnvironmentalSignificance of License Renewal, 1 the No-Action Alternative, and Alternative Methods of Power Generation 2 Proposed Action No-Action Alternative Coal-Fired Generation Natural-Gas-Fired Generation New Nuclear Generation Combination of Alternatives Impact Category License Renewal Denial of Renewal Alternate Site JAFNPP site Alternate Site JAFNPP Site Alternate Site JAFNPP Site Alternate Site Land Use SMALL NO IMPACT MODERATE to LARGE SMALL to MODERATE SMALL to MODERATE SMALL MODERATE to LARGE SMALL to MODERATE SMALL to LARGEEcology SMALL SMALL MODERATE to LARGE MODERATE SMALL to MODERATE SMALL MODERATE to LARGE SMALL to MODERATE SMALL to LARGE Water Use and Quality-Surface Water SMALL SMALL SMALL to MODERATE SMALL SMALL to MODERATE SMALL SMALL to MODERATE SMALL SMALL to MODERATE Water Use and Quality-Groundwater SMALL SMALL SMALL to MODERATE NO IMPACT SMALL to MODERATE SMALL SMALL to MODERATE SMALL SMALL to MODERATE Air Quality SMALL SMALL MODERATE MODERATE MODERATE SMALL SMALL MODERATE MODERATE Waste SMALL SMALL MODERATE SMALL SMALL SMALL SMALL SMALL SMALL Human Health SMALL(a) SMALL SMALL SMALL SMALL SMALL SMALL SMALL SMALL Socioeconomics SMALL MODERATE to LARGE SMALL to LARGESMALL to LARGESMALL to LARGE SMALL to MODERATE SMALL to LARGESMALL to MODERATE SMALL to LARGETransportation SMALL SMALL SMALL to LARGEMODERATE MODERATE SMALL to LARGE SMALL to MODERATE MODERATE MODERATE Aesthetics SMALL NO IMPACT SMALL to LARGESMALL SMALL to LARGE SMALL to MODERATE SMALL to LARGESMALL MODERATE to LARGE Historic and Archaeological Resources SMALL SMALL SMALL to MODERATE SMALL to MODERATE SMALL to MODERATE SMALL to MODERATE SMALL to MODERATE SMALL to MODERATE SMALL to MODERATE Environmental Justice SMALL SMALL to LARGESMALL to LARGESMALL to MODERATE SMALL to MODERATE SMALL to MODERATE SMALL to MODERATE SMALL to MODERATE SMALL to MODERATE (a) Except for collective offsite radiological impacts from the fuel cycle and from HLW and spent-fuel disposal, for which a significance level was not assigned. See Chapter 6 for details.

3 Summary and Conclusions Draft NUREG-1437, Supplement 31 9-8 June 2007

9.3 NRC Staff Conclusion

s and Recommendations 1 Based on (1) the analysis and findings in the GEIS, (2) the ER submitted by Entergy (Entergy 2 2006b), (3) consultation with Federal, State, and local agencies, (4) the NRC staff's own 3 independent review, and (5) the NRC staff's consideration of public comments received, the 4 preliminary recommendation of the NRC staff is that the Commission determine that the 5 adverse environmental impacts of license renewal for JAFNPP are not so great that preserving 6 the option of license renewal for energy planning decision makers would be unreasonable.

7 9.4 References 8 10 CFR Part 51.

Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 9 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

10 10 CFR Part 54.

Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for 11 Renewal of Operating Licenses for Nuclear Power Plants."

12 Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2006a.

13 James A. FitzPatrick Nuclear Power Plant License Renewal Application. Lycoming, New York.

14 Accessible at ML062160494.

15 Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2006b.

16 James A. FitzPatrick Nuclear Power Plant - License Renewal Application, Appendix E:

17 Applicant's Environmental Report, Operating License Renewal Stage.

Lycoming, New York.

18 Accessible at ML062160557.

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

20 U.S. Atomic Energy Commission (AEC). 1973. Final Environmental Statement Related to 21 Operation of James A. FitzPatrick Nuclear Power Plant Power Authority of the State of New 22 York. Docket No. 50-333. Washington, D.C. Accessible at ML062360088.

23 U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement 24 for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, D.C.

25 U.S. Nuclear Regulatory Commission (NRC). 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 r enewal of nuclear power plants, Final Report."

28 NUREG-1437, Volume 1, Addendum 1. Office of Nuclear Regulatory Research, Washington, 29 D.C. 30 Summary and Conclusions June 2007 9-9 Draft NUREG-1437, Supplement 31 U.S. Nuclear Regulatory Commission (NRC). 2000. Standard Review Plans for Environmental 1 Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal. NUREG-1555, 2 Supplement 1, Washington, D.C.

3 U.S. Nuclear Regulatory Commission (NRC). 2006a. "Notice of Acceptance for Docketing of 4 the Application, Notice of Opportunity for Hearing and Notice of Intent to prepare an 5 Environmental Impact Statement and Conduct Scoping Process of Facility Operating License 6 No. DPR-59 for an Additional 20-Year Period, Entergy Nuclear Operations, Inc., James A.

7 FitzPatrick Nuclear Power Plant." Federal Register: Vol. 71, No. 182, pp. 55032-55035.

8 Washington, D.C.

9 U.S. Nuclear Regulatory Commission (NRC). 2006b. NRC press release announcing Public 10 License Renewal Process and Environmental Scoping Meeting Associated with the Application 11 to Renew the Operating License for JAFNPP. Accessible at ML062760465 12 U.S. Nuclear Regulatory Commission (NRC). 2007a. Letter to M. Kansler, Entergy.

Subject:

13 Environmental Scoping Summary Report. March 2, 2007. Accessible at ML070440393.

14 U.S. Nuclear Regulatory Commission (NRC). 2007b. Environmental Scoping Summary Report 15 Associated with the Staff's Review of the Application by Entergy for Renewal of the Operating 16 License for JAFNPP. Washington, D.C. Accessible at ML070440393.

17 18

Appendix A Comments Received on the Environmental Review

June 2007 A-1 Draft NUREG-1437, Supplement 31 Appendix A:

1 Comments Received on the Environmental Review 2 On September 20, 2006, the U.S. Nuclear Regulatory Commission (NRC) published a Notice of 3 Intent in the Federal Register (71 FR 55032) to notify the public of the NRC staff's intent to 4 prepare a plant-specific supplement to the Generic Environmental Impact Statement for License 5 Renewal of Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2 (NRC 1996; 1999), (1) 6 related to the renewal application for the James A. FitzPatrick Nuclear Power Plant (JAFNPP) 7 operating license and to conduct scoping. The plant-specific supplement to the GEIS has been 8 prepared in accordance with the National Environmental Policy Act (NEPA), Council on 9 Environmental Quality (CEQ) guidance, and Title 10 of the Code of Federal Regulations , Part 10 51 (10 CFR Part 51). As outlined by NEPA, the NRC initiated the scoping process with the 11 issuance of the Federal Register Notice. The NRC invited the applicant; Federal, State, and 12 local government agencies; Native American tribal organizations; local organizations; and 13 individuals to participate in the scoping process by providing oral comments at the scheduled 14 public meetings and/or submitting comments by November 14, 2006.

15 The scoping process included two public scoping meetings, which were held at the Town of 16 Scriba Municipal Building in Oswego, New Yo rk, on October 12, 2006. The NRC issued press 17 releases and distributed flyers locally. Approximately 14 members of the public attended the 18 meetings. Both sessions began with NRC staff members providing a brief overview of the 19 license renewal process. Following the NRC's prepared statements, the meetings were open 20 for public comments. Three attendees provided either oral comments or written statements that 21 were recorded and transcribed by a certified court reporter, and written comments were 22 appended to the transcript. The transcripts of the meetings are an attachment to the meeting 23 summary, which was issued on October 30, 2006 (meeting transcripts, ML063030195 and 24 ML063030209; meeting summary, ML062980148). The documents are publicly available and 25 can be found at the Agencywide Documents Access and Management System (ADAMS) at 26 http://adamswebsearch.nrc.gov/dologin.html or through the NRC's Electronic Reading Room 27 link at http://www.nrc.gov. Persons who do not have access to ADAMS or who encounter 28 problems in accessing the documents located in ADAMS should contact the NRC's Public 29 Document Room staff at 1-800-397-4209 or 301-415-4737, or by email at pdr@nrc.gov.

30 At the conclusion of the scoping period, the NRC staff reviewed the transcripts and all written 31 material received and identified individual comments. Each set of comments from a given 32 commenter was given a unique alpha identifier (Commenter ID letter), allowing each set of 33 comments from a commenter to be traced back to the transcript, letter, or email in which the 34 comments were submitted. Specific comments were numbered sequentially within each 35 comment set. All of the comments received and the NRC staff responses are included in the 36 JAFNPP Scoping Summary Report dated March 2, 2007 (ML070440393).

37 Appendix A Draft NUREG-1437, Supplement 31 A-2 June 2007 Comments were consolidated and categorized according to the topic within the proposed 1 supplement to the GEIS or according to the general topic if outside the scope of the GEIS.

2 Comments with similar specific objectives were combined to capture the common essential 3 issues that had been raised in the source comments. Once comments were grouped according 4 to subject area, the NRC staff determined the appropriate action for the comment.

5 Table A-1 identifies the individuals who provided comments applicable to the environmental 6 review and the Commenter ID associated with each person's set(s) of comments. The 7 individuals are listed in the order in which they spoke at the public meeting, and in the 8 alphabetical order for the comments received by letter. To maintain consistency with the 9 Scoping Summary Report, the unique identifier used in that report for each set of comments is 10 retained in this appendix. The Commenter ID is preceded by FNP, which stands for James A.

11 FitzPatrick Nuclear Power Plant scoping. Accession numbers indicate the location of the written 12 comments in ADAMS.

13 Specific comments were categorized and consolidated by topic. Comments with similar specific 14 objectives were combined to capture the common essential issues raised by the commenters.

15 The comments fall into one of the following general groups:

16 Specific comments that address environmental issues within the purview of the NRC 17 environmental regulations related to license renewal. These comments address 18 Category 1 or Category 2 issues or issues that were not addressed in the GEIS. They 19 also address alternatives and related Federal actions.

20 General comments (1) in support of or opposed to nuclear power or license renewal or 21 (2) on the renewal process, the NRC's regulations, and the regulatory process. These 22 comments may or may not be specifically related to the JAFNPP license renewal 23 application.

24 Questions that do not provide new information.

25 Specific comments that address issues that do not fall within or are specifically excluded 26 from the purview of NRC environmental regulations related to license renewal. These 27 comments typically address issues such as the need for power, emergency 28 preparedness, security, current operational safety issues, and safety issues related to 29 operation during the renewal period.

30 Comments applicable to this environmental review and the NRC staff's responses are 31 summarized in this appendix. The parenthetical alpha-numeric identifier after each comment 32 refers to the comment set (Commenter ID) and the comment number. This information, which 33 was extracted from the JAFNPP Scoping Summary Report, is provided for the convenience of 34 those interested in the scoping comments applicable to this environmental review. The 35 comments that are general or outside the scope of the environmental review for JAFNPP are 36 Appendix A June 2007 A-3 Draft NUREG-1437, Supplement 31 not included here. More detail regarding the disposition of general or inapplicable comments 1 can be found in the summary report. The ADAMS accession number for the Scoping Summary 2 Report is ML070440393. This accession number is provided to facilitate access to the document 3 through the Public Electronic Reading Room (ADAMS) at http://www.nrc.gov/reading-rm.html

. 4 Comments in this section are grouped into the following categories:

5 A.1.1 Aquatic Ecology 6 A.1.2 Socioeconomics 7 A.1.3 Postulated Accidents 8 A.1.4 Uranium Fuel Cycle and Waste Management 9 10 Table A-1. Individuals Providing Comments During Scoping Comment Period 11 Commenters' ID Commenter Affiliation (If stated) Comment Source, ADAMS Accession Number (a) FNP-A Ed Putnam Candidate, New York State Assembly Afternoon Scoping Meeting FNP-B Tim Judson Citizens Awareness Network (CAN) Evening Scoping Meeting FNP-C Tom Dellwo CAN Evening Scoping Meeting FNP-D Joseph J. Heath General Counsel, Onondaga Nation Letter (ML063240283)

FNP-E Christopher M. Hogan Project Manager, New York State Department of Environmental Conservation Letter (ML063240331) (a) The afternoon and evening transcripts can be found under accession numbers ML063030195 and ML063030209, respectively.

Comments Received During Scoping 12 A.1.1 Aquatic Ecology Issues 13 Comment: [Environmental Report] Appendix E; Section 4.2: Entrainment of Fish and Shellfish 14 in Early Life Stages, and Section 4.3: Impingement of Fish and Shellfish Statements regarding 15 previous Departmental Best Technology Available (BTA) decisions for FitzPatrick are 16 overstated. While in 1996 and 2001 the Department determined that the high frequency/high 17 amplitude acoustic fish deterrent system (FDS) was BTA for reducing impingement, the 18 Department did not state that the FDS was BTA for reducing entrainment. In fact, the letter 19 Entergy used as a reference specifically states, "Moreover, the fish deterrent system has not 20 been evaluated as an entrainment mitigative device..." In addition, while the State Pollution 21 Discharge Elimination System (SPDES) Permit Fact Sheet that accompanied the 1996 and 22 Appendix A Draft NUREG-1437, Supplement 31 A-4 June 2007 2001 SPDES permits discussed the potential benefit of the FDS for reducing alewife 1 entrainment, it referenced the need for studies to determine the effectiveness of the FDS 2 system on larval life stages of alewives. Requirements for these studies were made part of the 3 SPDES permit, but Department records indicate that the study was never conducted.

4 Even if the study had been completed and the Department had made a BTA determination 5 regarding entrainment, documented changes in the fish community in Lake Ontario (as 6 described in Appendix E, Section 2.2.4 of the license renewal application) compel a review of 7 previous determinations to determine if changes are warranted. To that end, Entergy is 8 currently conducting biological sampling at FitzPatrick to determine the extent of current 9 impacts. Data from this sampling will be included in a Comprehensive Demonstration Study 10 that Entergy must submit to the Department in early 2008. A new BTA decision will be based, in 11 part, on the Comprehensive Demonstration Study. Thus, conclusory statements that 12 entrainment impacts do not warrant mitigation are premature. Decisions regarding the need for 13 mitigation will be addressed via the SPDES permit process. (FNP-E-1) 14 Comment: [Environmental Report] Section 6.2 Mitigation. Entergy's contention that "the current 15 permits, practices, and programs that mitigate the environmental impacts of plant operations are 16 adequate (page 6-1)" are not necessarily accurate. For example, the decision regarding 17 adequacy of mitigative measures for addressing impacts from impingement and entrainment will 18 be addressed via the SPDES permit process. That permit process will address the adequacy of 19 current practices and, if necessary, will result in requirements for additional measures to reduce 20 impacts. In addition and as explained above, statements in Table 6-1 regarding past BTA 21 determinations are overstated. (FNP-E-2) 22 Comment: Counter to statements contained in Section 4.2.6, Section 4.3.6, and Table 6-23 1,federal regulations do not require limiting the focus of mitigation requirements to impacts on 24 fish populations (see 10 CFR 51.53(c) and 10 CFR 51.45(c)). In fact, the federal regulations 25 dealing with impingement and entrainment at power plants focus on the reduction in the 26 numbers of individual organisms (see 40 CFR 125-Subparts I and J). (FNP-E-3) 27 Response: These comments are related to information regarding entrainment and impingement 28 of fish and shellfish, as provided in the applicant's Environmental Report. Aquatic ecology will 29 be discussed in Chapters 2 and 4 of the SEIS.

30 A.1.2 Socioeconomic Issues 31 Comment: One of the economic factors which affects the retention of current industry in central 32 New York and which also affects the attraction of new industry to this region is the provision of 33 inexpensive, trustworthy, and accessible power.

We need this company to be a player in this 34 attempt to bolster the economy of central New York. The Oswego County Public Utility Service 35 offers "low cost electrical energy" to new and expanding business in Oswego County, in the 36 hope that it will inspire new jobs and retain existing jobs through the low-cost electricity provided 37 Appendix A June 2007 A-5 Draft NUREG-1437, Supplement 31 by Entergy at the FitzPatrick plant. This is a positive initiative, which has begun to be shared 1 with the local economic community.

2 A similar form of utility incentive for domestic usage would be a welcome message to the 3 residents of this region. It seems inconsistent that this community, which houses nuclear power 4 plants, does not experience significant benefit from the presence. The economic downturn in 5 this region is desperately in need of signs of recovery, and thus nuclear power industry has the 6 capability of leading the way. (FNP-A-10) 7 Response: The comments are related to the socioeconomic impacts specific to JAFNPP.

8 Socioeconomic impacts such as taxes are Category 2 issues and will be addressed in Chapters 9 2 and 4 of the SEIS.

10 A.1.3 Postulated Accidents 11 Comment: The operation of nuclear power plants is not without the potential for accidents, with 12 serious consequences for both short and long term health in surrounding communities.

13 (FNP-D-3) 14 Response: The GEIS evaluated severe accidents and design basis accidents, and concluded 15 the impact was small. During the environmental review of JAFNPP, the NRC will determine 16 whether there is any new and significant information bearing on the previous analyses in the 17 GEIS. Section 5.1.2 of the plant-specific SEIS for JAFNPP will address this issue. In addition, 18 alternatives to mitigate severe accidents must be considered on a plant-specific basis for all 19 plants that have not previously considered such alternatives. The applicant provided a severe 20 accident mitigation alternatives (SAMA) analysis as part of the license renewal application for 21 JAFNPP. The NRC staff's review of the SAMA analysis will discussed in Section 5.2 and 22 Appendix G of the SEIS for JAFNPP.

23 A.1.4 Uranium Fuel Cycle and Waste Management Issues 24 Comment: From start to finish, the production of nuclear energy is fraught with hazards. The 25 mining and enrichment of uranium produces radioactive isotopes that contaminate and degrade 26 the surrounding environment. (FNP-D-2) 27 Comment: Finally, creation of nuclear energy leads to the accumulation of extremely 28 hazardous, radioactive material that persists in the environment for tens of thousands of years.

29 Additionally, this process creates byproducts, which, in a worst-case scenario, could be 30 obtained and used to create dangerous weapons. (FNP-D-4) 31 Response: Environmental impacts associated with the uranium fuel cycle were addressed in 32 the GEIS. The GEIS concluded those impacts including the off-site radiological impact of 33 Appendix A Draft NUREG-1437, Supplement 31 A-6 June 2007 storage, transportation, and disposal of spent fuel and other radioactive waste are Category 1 1 issues. The impact of these Category 1 issues was judged to be small in the GEIS. During the 2 environmental review of JAFNPP, the NRC determine whether there is any new and significant 3 information bearing on the previous analysis.

4 Appendix B Contributors to the Supplement

June 2007 B-1 Draft NUREG-1437, Supplement 31 Appendix B:

1 Contributors to the Supplement 2 The overall responsibility for the preparation of this supplement was assigned to the Office of 3 Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission (NRC). The supplement 4 was prepared by members of the Office of Nuclear Reactor Regulation with assistance from 5 other NRC organizations, Lawrence Livermore National Laboratory, and Pacific Northwest 6 National Laboratory.

7 Name Affiliation Function or Expertise NUCLEAR REGULATORY C OMMISSION Rani L. Franovich Nuclear Reactor Regulation Branch Chief Jessie M. Muir Nuclear Reactor Regulation Project Manager, Nonradiological Waste Samuel Hernandez Nuclear Reactor Regulation Backup Project Manager, Alternatives Jeffrey Rikhoff Nuclear Reactor Regulation Socioeconomics, Cultural Resources, Environmental Justice Richard Emch Nuclear Reactor Regulation Radiation Protection Stephen Klementowicz Nuclear Reactor Regulation Radiation Protection Jennifer A. Davis Nuclear Reactor Regulation Cultural Resources Scott Werts Nuclear Reactor Regulation Hydrology, Air, Alternatives Michael Masnik Nuclear Reactor Regulation Aquatic and Terrestrial Ecology Sarah Lopas Nuclear Reactor Regulation Aquatic Ecology Evan Keto Nuclear Reactor Regulation Terrestrial Ecology, Threatened and Endangered SpeciesRobert Palla Nuclear Reactor Regulation Severe Accident Mitigation Alternatives LAWRENCE LIVERMORE NATIONAL LABORATORY(a) Bruce McDowell Team Leader Lily Baldwin Deputy Team Leader, Hydrology, Water Use and Quality Hank Khan Health Physics Crystal Quinly Land Use Diana Burke Lead Editor Lisa Crawford Socioeconomics, Alternatives Frank Gouveia Meteorology, Air Quality Appendix B Draft NUREG-1437, Supplement 31 B-2 June 2007 Name Affiliation Function or Expertise PACIFIC NORTHWEST NATIONAL LABORATORY (b) Steve Short Severe Accident Mitigation Alternatives Bruce Schmitt Severe Accident Mitigation Alternatives Fred Leverenz Severe Accident Mitigation Alternatives (a) Lawrence Livermore National Laboratory is operated for the U.S. Department of Energy by the University of California. (b) Pacific Northwest National Laboratory is operated for the U.S. Department of Energy by Battelle.

1 Appendix C Chronology of NRC Staff Environmental Review Correspondence Related to Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc., Application for License Renewal of James A. FitzPatrick Nuclear Power Plant

June 2007 C-1 Draft NUREG-1437, Supplement 31 Appendix C:

1 Chronology of NRC Staff Environmental Review Correspondence 2 Related to Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear 3 Operations, Inc., Application for License Renewal of 4 James A. FitzPatrick Nuclear Power Plant 5 This appendix contains a chronological listing of correspondence between the U.S. Nuclear 6 Regulatory Commission (NRC) and Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear 7 Operations, Inc. (Entergy) and other correspondence related to the NRC staff's environmental 8 review, under Title 10 of the Code of Federal Regulations , Part 51 (10 CFR Part 51), of the 9 Entergy application for renewal of the James A. FitzPatrick Nuclear Power Plant (JAFNPP) 10 operating license. All documents, with the excepti on of those containing proprietary information, 11 are publicly available at the NRC Public Docum ent Room (PDR), located at One White Flint 12 North, 11555 Rockville Pike, Rockville, Maryland, 20852, or from the NRC's Agencywide 13 Documents Access and Management System (A DAMS). The ADAMS Public Electronic 14 Reading Room is accessible at http://adamsw ebsearch.nrc.gov/dologin.htm. The ADAMS 15 accession numbers for each document are included below. Persons who do not have access to 16 ADAMS, or who encounter problems in accessi ng the documents located in ADAMS, should 17 contact the NRC's PDR reference staff by telephone at 1-800-397-4209 or 301-415-4737, or by 18 e-mail at pdr@nrc.gov.

19 July 27, 2006 Summary of meeting held on June 26, 2006, between NRC and 20 Entergy to discuss submittal of JAFNPP license renewal application.

21 (Accession No. ML062090176) 22 July 31, 2006 Letter from P. Dietrich, Entergy, submitting the application for renewal of 23 the operating license for the JAFNPP. (Accession No. ML062160491) 24 July 31, 2006 James A. FitzPatrick Nuclear Power Plant - License Renewal 25 Application, Appendix E: Applicant's Environmental Report, Operating 26 License Renewal Stage. (Accession No. ML062160557) 27 August 4, 2006 NRC press release announcing the availability of the license renewal 28 application for JAFNPP. (Accession No. ML062160240) 29 August 7, 2006 Letter to P. Dietrich, Entergy, Receipt and Availability of the License 30 Renewal Application for JAFNPP. (Accession No. ML062190106) 31 Appendix C Draft NUREG-1437, Supplement 31 C-2 June 2007 August 11, 2006 Federal Register Notice of Receipt and Availability of Application for 1 Renewal of JAFNPP (Operating License No. DPR-59) for an Additional 2 20-Year Period (71 FR 55032). (Accession No. ML071000081) 3 September 7, 2006 Letter to M. Bennett, Penfield Library, regarding the maintenance of 4 reference material at the SUNY Oswego-Penfield Library, related to 5 the JAFNPP license renewal application. (Accession No.

6 ML062500286) 7 September 7, 2006 Letter to C. Ferlito, Oswego Public Library, regarding the maintenance 8 of reference material at the Oswego Public Library, related to the 9 JAFNPP license renewal application. (Accession No. ML062500247) 10 September 14, 2006 Determination of Acceptability and Sufficiency for Docketing, Proposed 11 Review Schedule, and Opportunity for a Hearing Regarding the 12 Application from Entergy Nuclear Operations, Inc., for the renewal of 13 the operating license for JAFNPP. (Accession No. ML062570127) 14 September 15, 2006 Letter to D. L. Kilma, Advisory Council on Historic Preservation 15 (ACHP), the JAFNPP License Renewal Application Review.

16 (Accession No. ML062480229) 17 September 15, 2006 Letter to B. Castro, New York State Historic Preservation Office, 18 Request for Comments Concerning the JAFNPP License Renewal 19 Application Review. (Accession No. ML062480220) 20 September 15, 2006 Letter to L. Henry, Tuscarora Nation, Request for Comments 21 Concerning the JAFNPP License Renewal Application Review.

22 (Accession No. ML062480205) 23 September 15, 2006 Letter to W. Jacobs, Cayuga Nation, Request for Comments 24 Concerning the JAFNPP License Renewal Application Review.

25 (Accession No. ML062480069) 26 September 15, 2006 Letter to R. Halbritter, Oneida Indian Nation, Request for Comments 27 Concerning the JAFNPP License Renewal Application Review.

28 (Accession No. ML062480063) 29 30 Appendix C June 2007 C-3 Draft NUREG-1437, Supplement 31 September 15, 2006 Letter to I. Powless, Jr., Onondaga Indian Nation, Request for 1 Comments Concerning the JAFNPP License Renewal Application 2 Review. (Accession No. ML062480057) 3 September 15, 2006 Letter to B. Snyder, Seneca Nation of Indians, Request for Comments 4 Concerning the JAFNPP License Renewal Application Review.

5 (Accession No. ML062480035) 6 September 15, 2006 Letter to J. Ransom, S

t. Regis Mohawk Tribe, Request for Comments 7 Concerning the JAFNPP License Renewal Application Review.

8 (Accession No. ML062480053) 9 September 15, 2006 Letter to R. Hill, Tonawanda Band of Senecans, Request for 10 Comments Concerning the JAFNPP License Renewal Application 11 Review. (Accession No. ML062480044) 12 September 19, 2006 Letter to M. Moriarty, U.S. Fish and Wildlife Service Northeast 13 Regional Office, Request for List of Protected Species Within the Area 14 Under Evaluation for the JAFNPP License Renewal Application 15 Review. (Accession No. ML062630292) 16 September 20, 2006 Notice of Acceptance for Docketing of the Application, Notice of 17 Opportunity for Hearing and Notice of Intent To Prepare an 18 Environmental Impact Statement and Conduct Scoping Process for 19 Facility Operating License No. DPR-59 for an Additional 20-Year 20 Period, Entergy Nuclear Operations, Inc., James A. FitzPatrick Nuclear 21 Power Plant (71 FR 55032). (Accession No. ML071000085) 22 September 20, 2006 NRC press release announcing the opportunity to request a hearing on 23 application to renew operating license for JAFNPP. (Accession No.

24 ML062630056) 25 September 25, 2006 Meeting Notice, Forthcoming Meeting to Discuss the License Renewal 26 Process and Environmental Scoping for JAFNPP License Renewal 27 Application Review. (Accession No. ML062680355) 28 September 26, 2006 Notice of Intent to Prepare an Environmental Impact Statement and 29 Conduct Scoping Process for License Renewal for JAFNPP.

30 (Accession No. ML062480235) 31 32 Appendix C Draft NUREG-1437, Supplement 31 C-4 June 2007 October 3, 2006 NRC press release announcing Public License Renewal Process and 1 Environmental Scoping Meeting Associated with the Application to 2 Renew the Operating License for JAFNPP. (Accession No.

3 ML062760465) 4 October 3, 2006 Transcripts of the Proceedings of the JAFNPP Public Scoping 5 Meetings. (Accession Nos. ML063030195 [afternoon], ML063030209 6 [evening])

7 October 30, 2006 Summary of Public Environmental Scoping Meetings Related to the 8 Review of the JAFNPP License Renewal Application. (Accession No.

9 ML062980148) 10 November 7, 2006 Letter to K. Lynch, New York State Department of Environmental 11 Conservation (NYSDEC) Region 7, Request for List of State Protected 12 Species Within the Area Under Evaluation for the JAFNPP License 13 Renewal Application Review. (Accession No. ML062960276) 14 November 7, 2006 Letter to P. Dietrich, Entergy, Request for Additional Information 15 Regarding the Review of the License Renewal Application for 16 JAFNPP. (Accession No. ML062850382) 17 November 13, 2006 Letter from J. Heath, General Council for the Onondaga Nation, 18 concerning the JAFNPP license renewal application. (Accession No.

19 ML063240283) 20 November 14, 2006 Letter from C. Hogan, NYSDEC, in response to request for comments 21 on the JANFPP License Renewal Environmental Report. (Accession 22 No. ML063240331) 23 November 27, 2006 Letter to M. Kansler, Entergy, Environmental Site Audit Regarding the 24 JAFNPP License Renewal Application. (Accession No. ML063250406) 25 November 29, 2006 Letter to M. Kansler, Entergy, Request for Additional Information 26 Regarding Severe Accident Mitigation Alternatives for JAFNPP.

27 (Accession No. ML063060257) 28 29 Appendix C June 2007 C-5 Draft NUREG-1437, Supplement 31 November 30, 2006 Letter from T. Seoane, NYDEC Natural Heritage Program, Report on 1 Rare or State-Listed Animals, Significant Natural Communities, and 2 Other Habitats in Regards to the JAFNPP License Renewal 3 Application Review. (Not publicly available) 4 December 6, 2006 Letter from P. Dietrich, Entergy, JAFNPP License Renewal 5 Application, Amendment 1. (Accession No. ML063480585) 6 December 6, 2006 JAFNPP License Renewal Application Amendment 1 Attachments.

7 (Accession No. ML063480596) 8 December 7, 2006 Letter from A. Wonderley, Oneida Indian Nation, in response to 9 JAFNPP Environmental Review of License Renewal Application.

10 (Accession No. ML063480314) 11 January 8, 2007 Letter to M. Kansler, Entergy, Environmental Project Manager and 12 Schedule Change for the License Renewal Environmental Review of 13 JAFNPP. (Accession No. ML063550121) 14 January 26, 2007 Summary of Site Audit Related to the Review of the License Renewal 15 Application for JAFNPP. (Accession No. ML070220055) 16 January 29, 2007 Letter from P. Dietrich, Entergy, License Renewal Application 17 Amendment 4 Concerning SAMA Request of Additional Information.

18 (Accession No. ML070370170) 19 March 2, 2007 Letter to M. Kansler, Entergy, Environmental Scoping Summary Report 20 (Accession No. ML070440393) 21 March 7, 2007 Letter to E Alkiewicz, NYPA, Information Regarding Transmission Line 22 Corridor Inspection for the JAFNPP License Renewal Application 23 Review. (Accession No. ML070400200) 24 May 21 , 200 7 Letter to M. Moriarty, USFWS, regarding the Biological Assessment fo r 25 Proposed License Renewal of James A. FitzPatrick Nuclear Power 26 Plant. (Accession No. ML071310069) 27

Appendix D Organizations Contacted

June 2007 D-1 Draft NUREG-1437, Supplement 31 Appendix D:

1 Organizations Contacted 2 During the course of the U.S. Nuclear Regulatory Commission staff's independent review of 3 environmental impacts from operations during th e renewal term, the following Federal, State, 4 regional, local, and Native American Tribal agencies were contacted:

5 Advisory Council on Historic Preservation, Washington, DC 6 Cayuga Nation, Akron, New York 7 City of Oswego, Oswego, New York 8 County of Oswego, Oswego, New York 9 New York Department of State, Albany, New York 10 New York Power Authority, White Plains, New York 11 New York State Department of Environmental Conservation, Albany, New York 12 New York State Department of Health, Albany New York 13 New York State Energy Research and Development Authority, Albany, New York 14 New York State Historic Preservation Office, Waterford, New York 15 Onondaga Indian Nation, Nedrow, New York 16 Oneida Indian Nation, Verona, New York 17 Seneca Nation of Indians, Irving, New York 18 St. Regis Mohawk Tribe, Akwesasne, New York 19 Tonawanda Band of Senecans, Basom, New York 20 Town of Scriba, Scriba, New York 21 Tuscarora Indian Nation, Lewiston, New York 22 US Fish and Wildlife Service, Northeast Regional Office, Hadley, New York 23

Appendix E Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc., Compliance Status and Consultation Correspondence

June 2007 E-1 Draft NUREG-1437, Supplement 31 1Appendix E: Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc., Compliance Status and Consultation Correspondence Consultation correspondence related to the evaluation of the application for renewal of the operating license for James A. FitzPatrick Nuclear Power Plant (JAFNPP) is identified in Table E-1. Copies of the consultation correspondence are included at the end of this appendix. The licenses, permits, and other approvals obtained from Federal, State, regional, and local authorities for JAFNPP, are listed in Table E-2.

Table E-1. Consultation Correspondence Source Recipient Date of Letter U.S. Nuclear Regulatory Commission (R. Franovich) New York State Historic Preservation Office (B. Castro) September 15, 2006 U.S. Nuclear Regulatory Commission (R. Franovich)(a) Onondaga Indian Nation (I. Powless, Jr.) September 15, 2007 U.S. Nuclear Regulatory Commission (R. Franovich) U.S. Fish and Wildlife Service Northeast Regional Office (M. Moriarty) September 19, 2006 U.S. Nuclear Regulatory Commission (R. Franovich) New York State Department of Environmental Conservation (K. Lynch) November 7, 2006 New York State Department of Environmental Conservation Natural Heritage Program (T. Seoane)(b) U.S. Nuclear Regulatory Commission (S. Hernandez) November 30, 2006 U.S. Nuclear Regulatory Commission (R. Franovich) U.S. Fish and Wildlife Service Northeast Regional Office (M. Moriarty)

May 21, 2007 (a) Similar letters were sent to other Native American Tribes listed in Appendix C. (b) Not publicly available.

Table E-2. Federal, State, Local, and Regional Licenses, Permits, and Other Approvals for the James A. FitzPatrick Nuclear Power Plant (JAFNPP) Agency Authority Requirement Number Expiration Date Authorized Activity NRC Atomic Energy Act, 10 CFR 50 License to operate DPR-59 October 17, 2014 Authorization to operate JAFNPP. DOT 49 CFR 107, Subpart G Hazardous Materials Certificate of Registration 051706600001O June 30, 2007 Authorization to ship radioactive and hazardous materials. NYSDEC 6 NYCRR Part 201 Certificate to Operate an Air Contamination Source 7-3556-0020/00012 Not Applicable Authorization to operate air emission sources (diesel generators and boilers). NYSDEC 6 NYCRR Part 372 Hazardous Waste Generator Identification NYD000765073 Not Applicable Authorization for hazardous waste generation. NYSDEC 6 NYCRR Part 675 Water Withdrawal Registration NYGLWR-4004 November 20, 2008 Authorization to withdraw water from Lake Ontario. NYSDEC 6 NYCRR Part 596 Hazardous Substance Bulk Storage Registration Certificate 7-000117 August 16, 2008 Authorization for onsite bulk storage of hazardous substances. NYSDEC 6 NYCRR Part 750 State Pollutant Discharge Elimination System (SPDES) Permit NY-0020109 August 1, 2006 (a) Permit to discharge wastewaters to waters of the State. NYSDEC 6 NYCRR Part 612 Petroleum Bulk Storage Registration Certificate 7-140600 November 20, 2010 Authorization for onsite bulk storage of petroleum products. NYSDEC 6 NYCRR Part 373 Hazardous Waste Part 373 Permit 7-3556-0020/0004-0 Not Applicable Authorization to the accumulation and temporary storage onsite of mixed waste for >90 days.

Table E-2. (cont.) Agency Authority Requirement Number Expiration Date Authorized Activity NYSDEC 6 NYCRR Part 325 Pesticide Application Business Registration 79632 July 31, 2008 Authorization to apply pesticide. CVDEM Title 44, Code of Virginia, Chapter 3.3, Section 44-146.30 Application for Registration to Transport Hazardous Radioactive Materials EF-S0083107 August 31, 2007 Authorization to transport radioactive waste into the Commonwealth of Virginia. SCDHEC Act No.429 of 1980, South Carolina Radioactive Waste Transportation and Disposal Act South Carolina Radioactive Waste Transport Permit 0031-31-07 December 31, 2007 Authorization to transport radioactive waste into the State of South Carolina. TDEC Tennessee Department of Environment and Conservation Regulations Tennessee Radioactive Waste-License-for-Delivery T-NY003-L07 December 31, 2007 Authorization for the shipment of radioactive material into Tennessee to a disposal/processing facility. CFR Code of Federal Regulations CVDEM Commonwealth of Virginia (Department of Emergency Management) DOT U.S. Department of Transportation JAFNPP James A. FitzPatrick Nuclear Power Plant NRC Nuclear Regulatory Commission NYCRR New York State Codes Rules and Regulations NYSDEC New York State Department of Environmental Conservation SCDHEC South Carolina Department of Health and Environmental Control TDEC Tennessee Department of Environment and Conservation (a) JAFNPP continues to operate under the existing permit while NYSDEC completes the SPDES permit renewal.

Appendix E Draft NUREG-1437, Supplement 31 E-4 June 2007

Appendix E June 2007 E-5 Draft NUREG-1437, Supplement 31

Appendix E Draft NUREG-1437, Supplement 31 E-6 June 2007

Appendix E June 2007 E-7 Draft NUREG-1437, Supplement 31

Appendix E Draft NUREG-1437, Supplement 31 E-8 June 2007

Appendix E June 2007 E-9 Draft NUREG-1437, Supplement 31

Appendix E Draft NUREG-1437, Supplement 31 E-10 June 2007

Appendix E June 2007 E-11 Draft NUREG-1437, Supplement 31

Appendix E Draft NUREG-1437, Supplement 31 E-12 June 2007

Appendix E June 2007 E-13 Draft NUREG-1437, Supplement 31

Appendix E Draft NUREG-1437, Supplement 31 E-14 June 2007

Appendix E June 2007 E-15 Draft NUREG-1437, Supplement 31

Appendix E Draft NUREG-1437, Supplement 31 E-16 June 2007

Appendix E June 2007 E-17 Draft NUREG-1437, Supplement 31

Appendix E Draft NUREG-1437, Supplement 31 E-18 June 2007

Appendix E June 2007 E-19 Draft NUREG-1437, Supplement 31

Appendix E Draft NUREG-1437, Supplement 31 E-20 June 2007

Appendix E June 2007 E-21 Draft NUREG-1437, Supplement 31

Appendix E Draft NUREG-1437, Supplement 31 E-22 June 2007

Appendix E June 2007 E-23 Draft NUREG-1437, Supplement 31

Appendix E Draft NUREG-1437, Supplement 31 E-24 June 2007

Appendix E June 2007 E-25 Draft NUREG-1437, Supplement 31

Appendix E Draft NUREG-1437, Supplement 31 E-26 June 2007

Appendix E June 2007 E-27 Draft NUREG-1437, Supplement 31

Appendix E Draft NUREG-1437, Supplement 31 E-28 June 2007

Appendix E June 2007 E-29 Draft NUREG-1437, Supplement 31

Appendix E Draft NUREG-1437, Supplement 31 E-30 June 2007

Appendix E June 2007 E-31 Draft NUREG-1437, Supplement 31

Appendix E Draft NUREG-1437, Supplement 31 E-32 June 2007

Appendix F GEIS Environmental Issues Not Applicable to James A. FitzPatrick Nuclear Power Plant

Draft NUREG-1437, Supplement 31 F-1 June 2007 Appendix F:

1 GEIS Environmental Issues Not Applicable 2 to James A. FitzPatrick Nuclear Power Plant 3 Table F-1 lists those environmental issues identified in the Generic Environmental Impact 4 Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2 5 (NRC 1996; 1999), (1) and Title 10 of the Code of Federal Regulations, Part 51 (10 CFR Part 51), 6 Subpart A, Appendix B, Table B-1, that are not applicable to James A. FitzPatrick Nuclear 7 Power Plant (JAFNPP) because of plant or site characteristics.

8 Table F-1. GEIS Environmental Issues Not Applicable 9 to James A. FitzPatrick Nuclear Power Plant 10 ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 Category GEIS Sections Comment SURFACE WATER QUALITY , HYDROLOGY , AND U SE (FOR ALL PLANTS) Altered salinity gradients 1 4.2.1.2.2; 4.4.2.2 The JAFNPP cooling system does not discharge to an estuary.Water-use conflicts (plants with cooling ponds or cooling towers using makeup water from a small river with low flow) 2 4.3.2.1: 4.4.2.1 The JAFNPP cooling system does not use makeup water from a small river with low flow.

AQUATIC ECOLOGY (FOR PLANTS WITH COOLING TOWER BASED HEAT DISSIPATION SYSTEMS) Entrainment of fish and shellfish in early life stages 1 4.3.3 This issue is related to heat-dissipation systems that are not installed at JAFNPP. Impingement of fish and shellfish 1 4.3.3 This issue is related to heat-dissipation systems that are not installed at JAFNPP. Heat shock 1 4.3.3 This issue is related to heat-dissipation systems that are not installed at JAFNPP.

(1) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" include the GEIS and its Addendum 1.

Appendix F Draft NUREG-1437, Supplement 31 F-2 June 2007 ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 Category GEIS Sections Comment Groundwater use conflicts (potable and service water, and dewatering; plants that use <100 gallons per minutes

[gpm]) 1 4.8.1.1; 4.8.1.2 JAFNPP does not use groundwater. Groundwater use conflicts (potable and service water, and dewatering; plants that use >100 gpm) 2 4.8.1.1; 4.8.2.1 JAFNPP does not use groundwater. Groundwater-use conflicts (plants using cooling towers withdrawing makeup water from a small river) 2 4.8.1.3; 4.4.2.1 This issue is related to heat-dissipation systems that are not installed at JAFNPP. Groundwater-use conflicts (Ranney wells) 2 4.8.1.4 JAFNPP do not have or use Ranney wells. Groundwater quality degradation (Ranney wells) 1 4.8.2.2 JAFNPP do not have or use Ranney wells. Groundwater quality degradation (saltwater intrusion) 1 4.8.2.1 The JAFNPP cooling system does not discharge to an estuary.Groundwater quality degradation (cooling ponds in salt marshes) 1 4.8.3 This issue is related to heat-dissipation systems that are not installed at JAFNPP. Groundwater quality degradation (cooling ponds at inland sites) 2 4.8.3 This issue is related to heat-dissipation systems that are not installed at JAFNPP.

TERRESTRIAL R ESOURCES Cooling tower impacts on crops and ornamental vegetation 1 4.3.4 This issue is related to heat-dissipation systems that are not installed at JAFNPP. Cooling tower impacts on native plants 1 4.3.5.1 This issue is related to heat-dissipation systems that are not installed at JAFNPP. Bird collisions with cooling towers 1 4.3.5.2 This issue is related to heat-dissipation systems that are not installed at JAFNPP. Cooling pond impacts on terrestrial resources 1 4.4.4 This issue is related to heat-dissipation systems that are not

installed at JAFNPP.

Appendix F June 2007 F-3 Draft NUREG-1437, Supplement 31 ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 Category GEIS Sections Comment HUMAN HEALTH Microbial organisms (public health) (plants using lakes or canals, or cooling towers or cooling ponds that discharge to a small river).

2 4.3.6 The JAFNPP cooling system does not discharge to a small river. F.1 References 1 10 CFR Part 51.

Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 2 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

3 U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement 4 for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, D.C.

5 U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement 6 for License Renewal of Nuclear Plants: Main Report , Section 6.3, Transportation, Table 9.1, 7 Summary of findings on NEPA issues for license renewal of nuclear power plants

, Final Report. 8 NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

9

Appendix G NRC Staff Evaluation of

Severe Accident Mitigation Alternatives for

James A. FitzPatrick Nuclear Power Plant

June 2007 G-1 Draft NUREG-1437, Supplement 31 Appendix G:

1 NRC Staff Evaluation of Severe Accident Mitigation Alternatives for 2 James A. FitzPatrick Nuclear Power Plant 3 4 G.1 Introduction 5 Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy) submitted an 6 assessment of severe accident mitigation alternatives (SAMAs) for the James A. FitzPatrick 7 Nuclear Power Plant (JAFNPP) as part of the environmental report (ER) (Entergy 2006a).

8 Supplemental information on the SAMA assessment was provided in Amendment 1 to the 9 license renewal application (Entergy 2006b). This assessment was based on the most recent 10 JAFNPP probabilistic safety assessment (PSA) available at that time, a plant-specific offsite 11 consequence analysis performed using the MELCOR Accident Consequence Code System 2 12 (MACCS2) computer code, and insights from the JAFNPP individual plant examination (IPE) 13 (NPA 1991) and individual plant examination of external events (IPEEE) (NPA 1996). In 14 identifying and evaluating potential SAMAs, Entergy considered SAMA candidates that 15 addressed the major contributors to core damage frequency (CDF) and population dose at 16 JAFNPP, as well as SAMA candidates for other operating plants which have submitted license 17 renewal applications. Entergy identified 293 potential SAMA candidates. This list was reduced 18 to 63 unique SAMA candidates by eliminating SAMAs that: are not applicable to JAFNPP due 19 to design differences, have already been implemented at JAFNPP, or are similar in nature and 20 could be combined with another SAMA candidate. Entergy assessed the costs and benefits 21 associated with each of the potential SAMAs, and concluded in the ER that several of the 22 candidate SAMAs evaluated are potentially cost-beneficial.

23 Based on a review of the SAMA assessment, the U.S. Nuclear Regulatory Commission (NRC) 24 issued a request for additional information (RAI) to Entergy, by letter dated November 29, 2006 25 (NRC 2006). Key questions concerned: major plant and modeling changes incorporated within 26 each evolution of the PSA model; source term and release time category assumptions used in 27 the Level 2 analysis; justification for the multiplier used for external events; identification of 28 SAMAs to reduce the fire CDF; and further information on several specific candidate SAMAs 29 and low cost alternatives. Entergy submitted additional information by letters dated December 30 6, 2006 (Entergy 2006b) and January 29, 2007 (Entergy 2007). In the responses, Entergy 31 provided: a summary of the major changes made to each PSA model version and resultant 32 changes to dominant risk contributors to CDF; a discussion of the Level 2 analysis and the 33 process for assigning severe accident source terms and binning release categories; a revised 34 assessment of the baseline SAMA benefits considering a multiplier to account for external 35 events exclusive of uncertainties; a discussion of measures that have been taken to reduce risk 36 in dominant fire zones and why the fire CDF for those zones cannot be further reduced in a cost 37 effective manner; and additional information regarding several specific SAMAs. Entergy's 38 responses addressed the NRC staff's concerns.

39 Appendix G Draft NUREG-1437, Supplement 31 G-2 June 2007 G.2 Estimate of Risk for JAFNPP 1 Entergy's estimates of offsite risk at JAFNPP are summarized in Section G.2.1. The summary 2 is followed by the NRC staff's review of Entergy's risk estimates in Section G.2.2.

3 G.2.1 Entergy's Risk Estimates 4 Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA 5 analysis: (1) the JAFNPP Level 1 and 2 PSA model, which is an updated version of the IPE 6 (NPA 1991), and (2) a supplemental analysis of offsite consequences and economic impacts 7 (essentially a Level 3 PSA model) developed specifically for the SAMA analysis. The SAMA 8 analysis is based on the most recent JAFNPP Level 1 and Level 2 PSA model available at the 9 time of the ER, referred to as the JAFNPP PSA (Revision 2, October 2004 model). The scope 10 of the JAFNPP PSA does not include external events.

11 The baseline CDF for the purpose of the SAMA evaluation is approximately 2.74 x 10

-6 per year.

12 The CDF is based on the risk assessment for internally-initiated events. Entergy did not include 13 the contribution from external events within the JAFNPP risk estimates; however, it did account 14 for the potential risk reduction benefits associated with external events by multiplying the 15 estimated benefits for internal events by a factor of 4.

(1) This is discussed further in Sections 16 G.2.2 and G.6.2.

17 The breakdown of CDF by initiating event is pr ovided in Table G-1 (Entergy 2006a). As shown 18 in this table, events initiated by station blackout and transients are the dominant contributors to 19 the CDF. Anticipated transient without scram (ATWS) sequences are insignificant contributors 20 to the CDF.

21 The Level 2 JAFNPP PSA model that forms the basis for the SAMA evaluation represents an 22 updated version of the original IPE Level 2 model. The current Level 2 model utilizes a single 23 containment event tree (CET) containing both phenomenological and systemic events. The 24 Level 1 core damage sequences are binned into one of 48 Plant Damage State (PDS) bins 25 which provide the interface between the Level 1 and Level 2 CET analysis. CET nodes are 26 evaluated using supporting fault trees and logic rules.

27 The result of the Level 2 PSA is a set of 7 release categories with their respective frequency 28 and release characteristics. The results of this analysis for JAFNPP are provided in 29 Table E.1-10 of the ER (Entergy 2006a). The frequency of each release category was obtained 30 by summing the frequency of the individual accident progression CET endpoints binned into the 31 release category. Source terms were developed for each of the 7 release categories using the 32 (1) In the ER, Entergy bounded the combined impact of external events and uncertainties by applying a multiplier of 16 to the estimated SAMA benefits for internal events. In supplemental information to the ER, Entergy revised the analysis to include a multiplier of 4 to account for potential SAMA benefits in both internal and external events, and provided a separate accounting of uncertainties.

Appendix G June 2007 G-3 Draft NUREG-1437, Supplement 31 results of Modular Accident Analysis Program (MAAP 4.04) computer code calculations. These 1 release categories and source terms were further collapsed into three distinct source term bins 2 to represent no containment failure, early releases, and late releases.

3 Table G-1. JAFNPP Core Damage Frequency for Internal Events 4 Initiating Event CDF (per year)

Percent Contribution to CDF Station Blackout 1.27 x 10-6 46 Transients with loss of containment heat removal 7.78x 10

-7 28 Transients with loss of all emergency core cooling system (ECCS) injection 2.66 x 10-7 10 ATWS 1.38x 10

-7 5 Loss of a 4.16kv alternating current (AC) safeguard bus 1.18 x 10-7 5 Loss of both direct current (DC) divisions 9.55 x 10

-8 3 Loss of coolant accidents (LOCAs) 2.83 x 10

-8 1 Loss of a division of DC power 2.60 x 10

-8 1 Relay room flooding 2.53 x 10

-8 1 Total CDF (internal events) 2.74 x 10-6 100 5 The offsite consequences and economic impact analyses use the MACCS2 code to determine 6 the offsite risk impacts on the surrounding environment and public. Inputs for these analyses 7 include plant-specific and site-specific input values for core radionuclide inventory, source term 8 and release characteristics, site meteorological data, projected population distribution (within a 9 50-mile radius) for the year 2034, emergency response evacuation modeling, and economic 10 data. The core radionuclide inventory is derived from a reference core inventory for a boiling 11 water reactor (BWR) in MACCS2. Core inventory was scaled to account for the JAFNPP-12 specific power level, and long-lived radionuclide inventory was increased by 25 percent to 13 reflect the expected core exposure and fuel management practices at JAFNPP (Entergy 2007).

14 The magnitude of the onsite impacts (in terms of clean-up and decontamination costs and 15 occupational dose) is based on information provided in NUREG/BR-0184 (NRC 1997a).

16 In the ER, Entergy estimated the dose to the population within 50 miles of the JAFNPP site to 17 18 Appendix G Draft NUREG-1437, Supplement 31 G-4 June 2007 be approximately 1.63 person-rem per year. The breakdown of the total population dose by 1 containment release mode is summarized in Table G-2. Containment failures within the late 2 time frame (greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following event initiation) and the early time frame (0 to 24 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> following event initiation) dominate the population dose risk at JAFNPP, contributing 4 about equally to the population dose risk.

5 Table G-2. Breakdown of Population Dose by Containment Release Mode 6 Containment Release Mode Population Dose (Person-Rem 1 Per Year) Percent Contribution Late Containment Failure 0.87 53 Early Containment Failure 0.76 47 Intact Containment negligible negligible Total 1.63 100 1One person-Rem = 0.01 person-Sv 7 G.2.2 Review of Entergy's Risk Estimates 8 Entergy's determination of offsite risk at JAFNPP is based on the following three major elements 9 of analysis:

10

• The Level 1 and 2 risk models that form the bases for the 1991 IPE submittal (NPA 11 1991), and the external event analyses of the 1996 IPEEE submittal (NPA 1996), 12

• The major modifications to the IPE model that have been incorporated in the JAFNPP 13 PSA, and 14

• The MACCS2 analyses performed to translate fission product source terms and release 15 frequencies from the Level 2 PSA model into offsite consequence measures.

16 Each of these analyses was reviewed to determine the acceptability of Entergy's risk estimates 17 for the SAMA analysis, as summarized below.

18 The NRC staff's review of the JAFNPP IPE is described in an NRC report dated May 9, 1994 19 (NRC 1994). Based on a review of the IPE submittal and responses to RAIs, the NRC staff 20 concluded that the IPE submittal met the intent of GL 88-20 (NRC 1988); that is, the licensee's 21 IPE process is capable of identifying severe accident risk contributors or vulnerabilities.

22 No vulnerabilities were identified in the IPE. However, the licensee noted that a number of 23 actions were under evaluation as a result of the IPE process that would reduce the risk of core 24 damage and loss of containment function. Specific improvements identified for implementation 25 26 Appendix G June 2007 G-5 Draft NUREG-1437, Supplement 31 included: increasing the reactor core isolation cooling (RCIC) turbine exhaust set points, 1 repowering the RCIC enclosure exhaust fans from AC to DC, and fire protection system 2 modifications to provide emergency diesel generator (EDG) jacket water cooling directly or 3 through the emergency service water (ESW) system. Over 10 additional items were identified 4 for follow-on evaluation by the licensee (NRC 1994).

5 There have been two revisions to the IPE model since the 1991 IPE submittal, specifically, a 6 complete revision of the model in 1998 (Revision 1) in partial response to the boiling-water 7 reactor owner group (BWROG) peer review, and a revision in October 2004 (Revision 2) 8 completing the response to the BWROG peer review. The Revision 2 model reflects the 9 JAFNPP configuration and design as of December 2003 and uses component failure and 10 unavailability data as of December 2002.

A comparison of internal events CDF between the 11 1991 IPE and the current PSA model indicates an increase of about 40 percent in the total CDF 12 (from 1.9 x 10

-6 per year to 2.7 x 10

-6 per year). A listing of those changes that resulted in the 13 greatest impact on the internal events CDF was provided by Entergy in supplemental 14 information to the ER (Entergy 2006b) and in response to an RAI (Entergy 2007) and is 15 summarized in Table G-3.

16 The CDF value from the 1991 IPE (1.92 x 10

-6 per year) is near the lower end of the range of 17 the CDF values reported in the IPEs for other BWR 3/4 plants. Figure 11.2 of NUREG-1560 18 shows that the IPE-based total internal events CDF for BWR 3/4 plants ranges from 9 x 10

-8 per 19 year to 8 x 10

-5 per year, with an average CDF for the group of 2 x 10

-5 per year (NRC 1997b).

20 It is recognized that other plants have updated the values for CDF subsequent to the IPE 21 submittals to reflect modeling and hardware changes. The current internal events CDF results 22 for JAFNPP are comparable to that for other plants of similar vintage and characteristics.

23 The NRC staff considered the peer reviews performed for the JAFNPP PSA, and the potential 24 impact of the review findings on the SAMA evaluation. In the ER (Entergy 2006a) and in 25 response to an NRC staff RAI (Entergy 2007), Entergy described the previous peer reviews, 26 including independent consultant team reviews of draft versions of the IPE and Revision 1, as 27 well as the BWROG Peer Review of a draft of Revision 1 conducted in December 1997. The 28 BWROG review concluded that the JAFNPP PSA can be effectively used to support risk ranking 29 of systems, structures, and components, and to support applications involving risk significance 30 determinations when supported by deterministic analyses and when noted items are addressed.

31 Entergy stated that all major issues and observations from the BWROG Peer Review have been 32 addressed and incorporated into the current PSA (Revision 2).

33 Given that the JAFNPP internal events PSA model has been peer-reviewed and the peer review 34 findings were all addressed, and that Entergy has satisfactorily addressed NRC staff questions 35 regarding the PSA, the NRC staff concludes that the internal events Level 1 PSA model is of 36 sufficient quality to support the SAMA evaluation.

37 Appendix G Draft NUREG-1437, Supplement 31 G-6 June 2007 Table G-3. JAFNPP PSA Historical Summary 1 PSA Version Summary of Changes from Prior Model CDF (per year) 1991 IPE Submittal 1.92 x 10

-6 1998 (Revision 1) - Incorporated impact of design changes (supply EDG jacket cooling water through the ESW system cross-tie, bonnet vents on the low-pressure coolant injection (LPCI) and core spray injection valves, keylock bypass switches, normal position of residual heat removal (RHR) minimum flow bypass valve, and RCIC enclosure fan power supply changed to an AC inverter feed from a DC power

source) - Revised model to include catastrophic common cause failure of both 125V DC battery control boards, and other common cause

equipment failures - Revised model to assume loss of all AC power in the same division in which there is a loss of DC power - Revised internal flooding analysis to include a relay room flooding scenario - Revised transient sequences to directly result in core damage if manual depressurization of the reactor vessel fails - Revised model to assume core damage occurs given failure to initiate Standby Liquid Control System (SLCS) - Updated initiating event frequencies and component failure and unavailability database 2.44 x 10-6 June 2007 G-7 Draft NUREG-1437, Supplement 31 Table G-3. JAFNPP PSA Historical Summary (cont.)

1 PSA Version Summary of Changes from Prior Model CDF (per year) 2004 (Revision 2) - Reduced station battery depletion time from 8 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, and updated non-recovery probabilities for loss of offsite power - Revised model to include additional accident initiators: loss of non-safeguard 4.16kV AC Buses, loss of condensate system, loss of instrument air system, loss of ultimate heat sink, and loss of reactor water level instrumentation - Revised model to assume loss of both high-pressure coolant injection (HPCI) and RCIC during accidents involving a loss of

containment heat removal - Revised system fault tree models to include additional electrical and instrumentation and control (I&C) component common cause

failures - Reevaluated dependencies between post-initiator human actions and recovery actions - Updated initiating event frequencies and component failure data for instrument, master and slave trip units 2.74 x 10-6 2 As indicated above, the current JAFNPP PSA does not include external events. In the absence 3 of such an analysis, Entergy used the JAFNPP IPEEE to identify the highest risk accident 4 sequences and the potential means of reducing the risk posed by those sequences, as 5 discussed below.

6 The JAFNPP IPEEE was submitted in June 1996 (NPA 1996), in response to Supplement 4 of 7 Generic Letter 88-20 (NRC 19961b). While no fundamental weaknesses or vulnerabilities to 8 severe accident risk in regard to the external events were identified, a listing of improvement 9 opportunities was developed as discussed below. In a letter dated September 21, 2000, the 10 NRC staff concluded that the submittal met the intent of Supplement 4 to Generic Letter 88-20, 11 and that the licensee's IPEEE process is capable of identifying the most likely severe accidents 12 and severe accident vulnerabilities (NRC 2000a).

13 14 15 Appendix G Draft NUREG-1437, Supplement 31 G-8 June 2007 The JAFNPP IPEEE seismic analysis (NPA 1996) utilized a seismic margin assessment (SMA) 1 approach following NRC guidance (NRC 1991) and Electric Power Research Institute (EPRI) 2 guidance (EPRI 1991). This method is qualitative and does not provide numerical estimates of 3 the CDF contributions from seismic initiators. The seismic analysis was completed in 4 conjunction with the Seismic Qualification User Group (SQUG) program (SQUG 1992). The 5 overall seismic approach employed plant walkdowns to identify vulnerabilities, development of 6 seismic fragility values for components and structures, and quantification of high confidence low 7 probability of failure (HCLPF) for initiating events. A relay chatter evaluation was performed 8 using the standard approach for an Unresolved Safety Issue (USI) A-46 (NRC 2000b) program 9 plant. The conclusions of the JAFNPP IPEEE seismic margin analysis are:

10

• The overall plant HCLPF capacity at JAFNPP is 0.22g peak ground acceleration (PGA). This 11 value reflects implemented improvements to strengthen block walls in the Emergency Diesel 12 Generator Building, which increased the plant HCLPF value from 0.17g to 0.22g. Several 13 buildings and structures have HCLPF values at the 0.22g level. Thus, further increases in 14 seismic capacity would require multiple plant modifications.

15

• A vulnerability to fire or explosion as a result of the seismic-induced failure of the hydrogen line 16 in the turbine building was identified. A note was added to procedure AOP-14, "Earthquake,"

17 stating that the piping can be isolated by closing the hydrogen supply valve 89A-H2HAS-1.

18 Based on this procedure change, the applicant concludes that seismic-induced flooding and 19 fires do not pose major risks.

20

• No unique decay heat removal vulnerabilities to seismic events were found.

21

• No unique seismic-induced containment failure mechanisms were identified.

22 The NRC review and closeout of USI A-46 for JAFNPP is documented in a letter dated April 12, 23 2000 (NRC 2000b). Based on the information provided by the applicant, the NRC staff finds 24 that seismic risks are not dominant contributors to external event risk and that the treatment of 25 seismic events is reasonable for the purposes of the SAMA analysis.

26 The JAFNPP IPEEE fire analysis employed EPRI's fi re-induced vulnerability evaluation (FIVE) 27 methodology to perform a qualitative and quantitative screening review and then a probabilistic 28 risk analysis to estimate the CDF contribution for the areas that did not screen out. After 29 qualitative screening, fire event initiation frequencies were determined for the unscreened areas 30 for use in quantitative screening along with the assumption that all equipment in a compartment 31 was damaged by the fire. Using results from the IPE, a conservative CDF for the compartment 32 was determined and areas with a CDF of less than 1 x 10

-6 per year (or 1 x 10

-7 per year if 33 containment bypass may result) were screened out. Fire propagation and suppression analysis 34 was then conducted on the unscreened compartments. Fire-induced CDFs were determined by 35 propagating the fire initiating events and associated equipment failures determined by the fire 36 propagation and suppression analysis through event tr ees similar to those in the IPE. The 37 38 June 2007 G-9 Draft NUREG-1437, Supplement 31 potential impact on containment performance and isolation was evaluated following the core 1 damage evaluation. The JAFNPP fire CDF results are presented in Table E.1-12 of the ER for 2 the ten fire areas considered in the analysis, and the fire zones/compartments within each fire 3 area. The total fire CDF, found by summing the values for all compartments, is 2.56 x 10

-5 per 4 year. The ten fire areas and their contributions to the fire CDF are listed in Table G-4.

5 In the IPEEE, three opportunities for improvements with respect to fire events were identified.

6 These improvements involve: (1) addition of a bypass switch to allow opening of the LPCI and 7 core spray injection valves and an associated procedure for use of these switches during plant 8 fires, (2) changes to administrative procedures to impose strict limitations on unattended 9 combustible materials in the cable spreading room, and (3) relocation of heat detectors in the 10 cable spreading room to limit contribution from transient fires. In supplemental information to 11 the ER, Entergy indicated that the first two of these improvements have been implemented as 12 recommended in the IPEEE. The third improvement is considered to be addressed by the 13 changes to administrative procedures to limit unattended combustible material loading in the 14 room. Entergy stated that none of these improvements are credited in the IPEEE fire CDF 15 (Entergy 2006b).

16 In the ER, Entergy states that the IPEEE CDF values are screening values and that a more 17 realistic fire CDF may be about a factor of three lower (or 8.53 x 10

-6 per year) based on 18 conservatisms in several areas as qualitatively assessed in the ER. In supplemental 19 information, Entergy presented the results of a sensitivity analysis to quantitatively justify the 20 factor of three reduction (Entergy 2006b). The sensitivity analysis included the following: (1) 21 lower probability of occurrence of spurious actuation or failure due to hot shorts and open 22 circuits within cable jackets in the Cable Spreading Room, Reactor Building East Crescent, and 23 Relay Room and (2) lower ignition frequency for a fire in the Main Control Room. The results of 24 this sensitivity analysis are shown for the four impacted areas in the last two columns of the 25 table below. These reductions would quantitatively justify a reduction in the fire CDF by a factor 26 of 2.3. 27 Entergy noted that this fire CDF would be further reduced by IPEEE improvements not included 28 in the CDF estimate, including monitoring and controlling the quantity of combustible materials 29 in critical process areas. These measures would reduce the fire CDF in all dominant fire zones.

30 Based on the results of the sensitivity analysis and the existence of remaining conservatisms, 31 the NRC staff finds the use of a fire CDF of 8.53 x 10

-6 per year to be reasonable for the 32 purposes of the SAMA analysis.

33 The NRC staff inquired about additional steps taken to reduce fire risk and the possibility of 34 additional SAMAs that might be feasible to reduce the fire risk. Entergy provided a listing of fire-35 related SAMAs that have been implemented. Most of these SAMAs are improvements in the 36 fire protection program, which would decrease the fire risk, but are not explicitly credited in the 37 fire risk analysis. In addition, all but one of the six dominant fire zones (i.e., zones within the 38 above-mentioned fire areas with a compartment frequency greater than 1.0 x 10

-6 per year) are 39 40 Appendix G Draft NUREG-1437, Supplement 31 G-10 June 2007 1 2 3 Table G-4. Fire Areas and Their Contribution to the Fire CDF 4 CDF (per year)

Fire Area Description IPEEE Sensitivity Analysis (a) Cable Spreading Room 6.71 x 10-6 4.66 x 10

-7 Relay Room 5.81 x 10

-6 6.8 x 10-7 Reactor Building 3.43 x 10

-6 2.46x 10-6 Control Room 3.00 x 10

-6 7.17x 10-7 Cable Tunnels 1.96 x 10

-6 no change Diesel Generator Building 1.93 x 10

-6 no change Battery Room 1.45 x 10

-6 no change Turbine Building 1.29 x 10

-6 no change Standby Gas Treatment Building 3.72 x 10-8 no change Electric Bays 8.98 x 10

-10 no change TOTAL 2.56 x 10

-5 1.10 x 10

-5 (a) Source: Entergy 2006b 5 equipped with fire detection systems, three of the six dominant fire zones have fire suppression 6 systems, and the Main Control Room, which has neither fire detection or fire suppression 7 systems, is always occupied ensuring prompt fire detection and manual suppression. Entergy 8 stated that no further cost-effective changes were identified to reduce CDF in the dominant fire 9 zones (Entergy 2006b). The NRC staff concludes that the opportunity for fire-related SAMAs 10 has been adequately explored and that it is unlikely that there are any potentially cost-beneficial, 11 fire-related SAMA candidates.

12 The IPEEE analysis of high winds, floods and other external events followed the screening and 13 evaluation approaches specified in Supplement 4 to GL 88-20 (NRC 1991b) and did not identify 14 any sequences or vulnerabilities that exceeded the 1.0 x 10

-6 per year criterion (NPA 1996).

15 However, the licensee identified a condition where low pressures associated with hurricanes, 16 tornadoes, and high winds could threaten the integrity of the air intake duct work supplying the 17 June 2007 G-11 Draft NUREG-1437, Supplement 31 EDG room. Operating procedures were developed to open switchgear room doors or to open 1 damaged duct work if necessary to ensure adequate ventilation of the switchgear room and 2 adequate supply of combustion air to the EDGs. Based on this result, Entergy concluded that 3 these other external hazards would not be expected to impact the conclusions of the SAMA 4 analysis and did not consider them further.

5 Based on the aforementioned results, the external events CDF is approximately 3.1 times the 6 internal events CDF (based on a fire CDF of 8.53 x 10

-6 per year and an internal events CDF of 7 2.74 x 10-6 per year). Accordingly, the total CDF (from internal and external events) would be 8 approximately 4.1 times the internal events CDF. In revised SAMA analyses submitted in 9 response to an RAI, Entergy multiplied the benefit that was derived from the internal events 10 model by a factor of 4 to account for the combined contribution from internal and external 11 events. The NRC staff agrees with the applicant's overall conclusion concerning the impact of 12 external events and concludes that the applicant's use of a multiplier of 4 to account for external 13 events is reasonable for the purposes of the SAMA evaluation.

14 The NRC staff reviewed the general process used by Entergy to translate the results of the 15 Level 1 PSA into containment releases, as well as the results of the Level 2 analysis, as 16 described in the ER and in response to NRC staff requests for additional information (Entergy 17 2006a, 2007). The current Level 2 model utilizes a single CET containing both 18 phenomenological and systemic events. The Level 1 core damage sequences are binned into 19 one of 48 PDS bins based on binning criteria reflecting the state of the reactor, containment and 20 cooling systems as the accident progresses. Th e PDSs provide the interface between the Level 21 1 and Level 2 analysis. CET nodes are evaluated using supporting fault trees and logic rules.

22 Entergy characterized the releases for the spectrum of possible radionuclide release scenarios 23 using a set of 7 release categories based on the timing and magnitude of the release and 24 whether or not the containment remains intact. The frequency of each release category was 25 obtained by summing the frequency of the individual accident progression CET endpoints 26 binned into the release category. The release characteristics for each release category were 27 developed by grouping the hundreds of source terms generated for internal initiators into the 7 28 categories based on similar properties. Source term release fractions were developed for each 29 of the 7 release categories using the results of Modular Accident Analysis Program (MAAP 30 4.04) computer code calculations. The release categories, their frequencies, and release 31 characteristics are presented in Tables E.1-8, E.1-10, and E.1-11 of the ER, respectively 32 (Entergy 2006a). These release categories and source terms were further collapsed into three 33 distinct source term bins to represent no containment failure, early releases, and late releases.

34 The NRC staff noted that in collapsing the 7 release categories into three source term bins, 35 releases occurring between 0 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and between 8 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> were grouped into one bin.

36 In response to an RAI, Entergy performed a sensitivity study that showed that this simplification 37 results in less than a 2 percent change on population dose (Entergy 2007). Based on these 38 results the NRC staff concludes that the applicant's characterization of releases is adequate for 39 the purposes of the SAMA evaluation.

40 Appendix G Draft NUREG-1437, Supplement 31 G-12 June 2007 The NRC staff's review of the Level 2 IPE concluded that it addressed the most important 1 severe accident phenomena normally associated with the Mark I containment type, and 2 identified no significant problems or errors (NRC 1994). It should be noted, however, that the 3 current Level 2 model is a revision to that of the IPE. The Level 2 PSA model was included in 4 the independent consultant and BWROG peer reviews mentioned previously. The changes to 5 the Level 2 model to update the methodology and to address peer review recommendations are 6 described in Section E.1.4.2.2 of the ER. Based on the NRC staff's review of the Level 2 7 methodology, and the fact that the Level 2 model was reviewed in more detail as part of the 8 BWROG peer review, and updated to address the review findings, the NRC staff concludes that 9 the Level 2 PSA provides an acceptable basis for evaluating the benefits associated with 10 various SAMAs.

11 Entergy used the MACCS2 code and scaled the reference BWR core inventory for the JAFNPP 12 plant-specific power level. Entergy also increased the long-lived radionuclide core inventory by 13 25 percent to address JAFNPP specific fuel enrichment and burnup. In response to an NRC 14 staff RAI, Entergy identified that the 25-percent increase was based on a best estimate 15 inventory of long-lived isotopes (such as Sr-90, Cs-134 and Cs-137) from an ORIGEN computer 16 code calculation assuming 4.66 percent enrichment and average burnup based on expected 17 fuel management practices (Entergy 2007). The best-estimate evaluation resulted in an 18 increase of approximately 25 percent in the inventories of the aforementioned radionuclides.

19 The NRC staff considers the methods and assumptions for power scaling and 25 percent 20 increase in long-lived inventory reasonable and acceptable for purposes of the SAMA 21 evaluation.

22 The NRC staff reviewed the process used by Entergy to extend the containment performance 23 (Level 2) portion of the PSA to an assessment of offsite consequences (essentially a Level 3 24 PSA). This included consideration of the source terms used to characterize fission product 25 releases for the applicable containment release categories and the major input assumptions 26 used in the offsite consequence analyses. The MACCS2 code was utilized to estimate offsite 27 consequences. Plant-specific input to the code includes the source terms for each release 28 category and the reactor core radionuclide inventory (both discussed above), site-specific 29 meteorological data, projected population distribution within a 50-mile radius for the year 2034, 30 emergency evacuation modeling, and economic dat

a. This information is provided in 31 Attachment E to the ER (Entergy 2006a).

32 Entergy used site-specific meteorological data for the 1994 calendar year as input to the 33 MACCS2 code. The data were collected from the onsite meteorological monitoring system and 34 regional National Weather System (NWS) stations. In response to an NRC staff RAI, Entergy 35 identified the location of the National Weather System stations as being at Fulton-Oswego 36 County Airport and NWS Station No. 14733 in Buffalo, NY (Entergy 2007). Based on a review 37 of meteorological data between 1985 and 2001, Entergy stated that it considered the year 1994 38 data to be the most representative set of data because it contained no significant extremes and 39 reflected average meteorological conditions at the site (Entergy 2006a). Missing data was 40 obtained from either the upper elevation on the met tower or from estimates based on adjacent 41 valid measurements of the missing hour. The NRC staff notes that previous SAMA analyses 42 June 2007 G-13 Draft NUREG-1437, Supplement 31 results have shown little sensitivity to year-to-year differences in meteorological data and 1 concludes that the use of the 1994 meteorological data in the SAMA analysis is reasonable.

2 The population distribution the applicant used as input to the MACCS2 analysis was estimated 3 for the year 2034, based on the New York Statistical Information System projections from year 4 2000 to 2030 (Brown 2005). The 2000 population was adjusted to account for transient 5 population. These data were used to project county-level resident populations to the year 2034 6 using a least squares fit method. The NRC staff considers the methods and assumptions for 7 estimating population reasonable and acceptable for purposes of the SAMA evaluation.

8 The emergency evacuation model was modeled as a single evacuation zone extending out 16 9 kilometers (10 miles) from the plant. Entergy assumed that 100 percent of the population would 10 move at an average speed of approximately 2.0 meters per second (4.4 miles per hour) with a 11 delayed start time of 2.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> (Entergy 2006a). This assumption is similar to the model used 12 in NUREG-1150 study (NRC 1990), which assumed evacuation of 99.5 percent of the 13 population within the emergency planning zone (EPZ). Sensitivity analyses were performed in 14 which the evacuation delay time was increased to 4.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, and the evacuation speed was 15 decreased to 1.0 meters per second. The results were less than a one percent increase in the 16 total population dose. The NRC staff questioned why the evacuation speed of 2.0 meters per 17 second (4.4 miles per hour) was different than that used for the Nine Mile Point SAMA analysis 18 (NRC 2006). In response, Entergy stated that the JAFNPP evacuation speed was based on 19 evacuation times provided in the 2003 version of the evacuation time study (ETE) (KLD 20 Associates 2003), whereas the Nine Mile Point evacuation time estimate was based on an ETE 21 study performed in 1993 (Entergy 2007). The NRC staff also asked Entergy to address the 22 potential impact on the population dose if 5 percent of the population fails to evacuate the EPZ 23 (NRC 2006). In response, Entergy performed a sensitivity analysis that showed only a slight 24 increase in population dose (less than 1 percent for the late release) would result (Entergy 25 2007). The NRC staff concludes that the evacuation assumptions and analysis are reasonable 26 and acceptable for the purposes of the SAMA evaluation.

27 Much of the site-specific economic data was provided from the 2002 Census of Agriculture 28 (USDA 2002). These included the value of farm and non-farm wealth. Other data such as daily 29 cost for an evacuated person, population relocation cost, daily cost for a person who is 30 relocated, cost of farm and non-farm decontamination, and property depreciation were provided 31 from the Code Manual for MACCS2 (NRC 1997c).

The data from the default values given in the 32 MACCS2 code manual were adjusted using the consumer price index of 179.9, the average 33 value for 2002. Information on regional crops were obtained from the 2002 Census of 34 Agriculture. Crops for each county were mapped into the seven MACCS2 crop categories.

35 The NRC staff concludes that the methodology used by Entergy to estimate the offsite 36 consequences for JAFNPP provides an acceptable basis from which to proceed with an 37 assessment of risk reduction potential for candidate SAMAs. Accordingly, the NRC staff based 38 its assessment of offsite risk on the CDF and offsite doses reported by Entergy.

39 Appendix G Draft NUREG-1437, Supplement 31 G-14 June 2007 G.3 Potential Plant Improvements 1 The process for identifying potential plant improvem ents, an evaluation of that process, and the 2 improvements evaluated in detail by Entergy are discussed in this section.

3 G.3.1 Process for Identifying Potential Plant Improvements 4 Entergy's process for identifying potential plant improvements (SAMAs) consisted of the 5 following elements:

6

• Review of the most significant basic events from the current, plant-specific PSA, 7

• Review of potential plant improvements identified in the JAFNPP IPE and IPEEE, 8

• Review of SAMA candidates identified for license renewal applications for six other U.S.

9 General Electric (GE) plants, and 10

• Review of other NRC and industry documentation discussing potential plant 11 improvements. 12 Based on this process, an initial set of 293 candidate SAMAs, referred to as Phase I SAMAs, 13 was identified. In Phase I of the evaluation, Entergy performed a qualitative screening of the 14 initial list of SAMAs and eliminated SAMAs from further consideration using the following 15 criteria:

16

• The SAMA is not applicable at JAFNPP due to design differences, 17

• The SAMA has already been implemented at JAFNPP, or 18

• The SAMA is similar in nature and could be combined with another SAMA candidate.

19 Based on this screening, 230 SAMAs were eliminated leaving 63 for further evaluation. The 20 remaining SAMAs, referred to as Phase II SAMAs, are listed in Table E.2-1 of the ER (Entergy 21 2006a). In Phase II, a detailed evaluation was performed for each of the 63 remaining SAMA 22 candidates, as discussed in Sections G.4 and G.6 below. To account for the potential impact of 23 external events, the estimated benefits based on internal events were multiplied by a factor of 4, 24 as previously discussed.

25 G.3.2 Review of Entergy's Process 26 Entergy's efforts to identify potential SAMAs focused primarily on areas associated with internal 27 initiating events. The initial list of SAMAs generally addressed the accident sequences 28 considered to be important to CDF from functional, initiating event, and risk reduction worth 29 (RRW) perspectives at JAFNPP, and included selected SAMAs from prior SAMA analyses for 30 other plants.

31 June 2007 G-15 Draft NUREG-1437, Supplement 31 Entergy provided a tabular listing of the PSA basic events sorted according to their RRW 1 (Entergy 2006a). SAMAs impacting these basic events would have the greatest potential for 2 reducing risk. Entergy used a RRW cutoff of 1.005, which corresponds to about a one-half 3 percent change in CDF given 100-percent reliability of the SAMA. This equates to a benefit of 4 approximately $2,500 (after the benefits have been multiplied to account for external events).

5 Entergy also provided and reviewed the large early release frequency (LERF)-based RRW 6 events down to a RRW of 1.005. Entergy correlated the top Level 1 and Level 2 events with the 7 SAMAs evaluated in the ER, and showed that all of the significant basic events are addressed 8 by one or more SAMAs (Entergy 2006a).

9 NRC staff noted that no Phase II SAMAs were recommended for event NR-LOSP-7HR, non-10 recovery of offsite power in seven hours, which is the highest risk reduction worth non-initiator 11 event. The NRC staff asked the applicant to id entify and evaluate SAMAs for this event (NRC 12 2006). In response to the RAI, Entergy stated that procedure and training improvements for 13 restoring power to vital equipment following a recovery of the offsite power supply have been 14 implemented, but that hardware improvements that could facilitate recovery of offsite power 15 would merely shift NR-LOSP-7HR to a slightly later time on the power recovery curve and 16 therefore would have little impact on the RRW of the event (Entergy 2007). Entergy further 17 noted that other Phase II SAMAs (26 through 36 and 62), if implemented, would reduce the 18 CDF contribution from this basic event. These SAMAs would enhance AC or DC system 19 reliability or otherwise cope with loss of offsite power and SBO events. These Phase II SAMAs 20 were evaluated in the ER.

21 NRC staff also noted that no Phase I or Phase II SAMAs were recommended for event IE-22 RRFLOOD, transient caused by internal flooding in the relay room, although a procedure 23 change has been implemented to address the event. In an NRC staff RAI, the applicant was 24 asked to provide justification for why no SAMAs were identified to address internal flooding 25 events (NRC 2006). Entergy responded that additional methods of mitigating this flood event 26 would entail either moving the fire protection line or installing a guard pipe to channel floodwater 27 out of the relay room, both of which were judged to be costly relative to the risk significance of 28 the related flood scenarios (Entergy 2007). The remaining flood scenarios are not risk-29 significant (i.e., above the 1.005 RRW threshold for SAMA identification).

30 For a number of the Phase II SAMAs listed in the ER, the information provided did not 31 sufficiently describe the proposed modification. Therefore, the NRC staff asked the applicant to 32 provide more detailed descriptions of the modifications for several of the Phase II SAMAs 33 candidates (NRC 2006). In response to the RAI, Entergy provided the requested information 34 (Entergy 2007).

35 The NRC staff questioned the ability of some of the candidate SAMAs to accomplish their 36 intended objectives (NRC 2006a). In response to the RAIs, Entergy addressed the NRC staff's 37 concerns by either re-evaluating the existing SAMA using revised modeling assumptions, or by 38 evaluating an alternative (additional) SAMA (Entergy 2007). This is discussed further in Section 39 G.6.2. 40 Appendix G Draft NUREG-1437, Supplement 31 G-16 June 2007 The NRC staff also questioned Entergy about lower cost alternatives to some of the SAMAs 1 evaluated, including: the use of a redundant diesel fire pump to address event FXT-ENG-FR-2 76PI (failure of diesel driven fire pump 76P-1), the use of a local hand wheel or gas bottle 3 supplies for manual venting of containment, and the use of a portable generator to provide 4 alternate DC power feeds (NRC 2006). In supplemental information and in response to the 5 RAIs, Entergy addressed the suggested lower cost alternatives, some of which are covered by 6 an existing procedure, or are addressed by a new SAMA (Entergy 2006b, 2007). This is 7 discussed further in Section G.6.2.

8 In the ER, Entergy states that in both the IPE and IPEEE, several enhancements related to 9 severe accident insights were recommended and implemented, and that these enhancements 10 were included in the comprehensive list of Phase I SAMA candidates. However, the list of 11 Phase I SAMA candidates was not provided in the ER. Therefore, the NRC staff requested that 12 the applicant indicate whether the enhancement has been implemented, and whether credit for 13 the enhancement is taken in the current PSA model (used for the SAMA analysis) (NRC 2006).

14 In supplemental information to the ER, Entergy indicated that Phase I SAMAs 253, 256, 262, 15 and 280 through 293 include enhancements recommended in the IPE and IPEEE (Entergy 16 2006b). Entergy further indicated that most of these SAMAs have been implemented and that 17 SAMA 280 was determined to be unnecessary. Those enhancements that have not been 18 implemented or determined to not be necessary (SAMAs 281 through 284) were retained for 19 consideration during Phase II. In response to the RAI, Entergy noted that except for Phase I 20 SAMAs 94, 101, 120, and 267, the implemented Phase I SAMAs mentioned in the ER have 21 been credited in the current PSA model (Entergy 2007). The absence of these four 22 implemented modifications from the PSA model adds conservatism to the benefit estimates for 23 Phase II SAMAs.

24 Based on this information, the NRC staff concludes that the set of SAMAs evaluated in the ER, 25 together with those identified in supplemental information to the ER and in response to NRC 26 staff RAIs, addresses the major contributors to internal event CDF.

27 Entergy did not identify JAFNPP-specific candidate SAMAs for seismic events. In the JAFNPP 28 IPEEE seismic analysis, the overall plant HCLPF value was determined to be 0.22g. This value 29 reflects implemented improvements to strengthen block walls EGB-272-6, 7, 9, and 10 in the 30 Emergency Diesel Generator Building, which increased the plant HCLPF value from 0.17g to 31 0.22g. Several buildings and structures have HCLPF values at the 0.22g level. Thus, further 32 increases in seismic capacity would require multiple plant modifications. The JAFNPP IPEEE 33 also identified that there is a fire-induced seismic vulnerability due to failure of the hydrogen line 34 in the turbine building. The NRC staff requested t hat the applicant provide details on actions 35 taken to reduce this risk and whether a SAMA to further reduce this risk is cost-beneficial (NRC 36 2006). In their response, Entergy stated the hydrogen supply is protected by excess flow valves 37 outside the turbine building that are intended to limit hydrogen release in the event of a line 38 break (Entergy 2007). Entergy also indicated that this event has already been further mitigated 39 by making a modification to plant abnormal procedure AOP-14, "Earthquake," to require that 40 41 June 2007 G-17 Draft NUREG-1437, Supplement 31 plant operators close hydrogen supply valve 89A-H2HAS-1 following a seismic event (Phase I 1 SAMA 286). Finally, Entergy notes that the turbine building fire risk provided in the ER (which 2 does not reflect the implemented plant procedure) is less than 1 x 10

-6 per year, and cannot be 3 further reduced in a cost-effective manner. Based on the licensee's IPEEE, the A-46 efforts to 4 identify and address seismic outliers, the modifications that have already been implemented, 5 and the expected cost associated with further seismic risk analysis and potential plant 6 modifications, the NRC staff concludes that the opportunity for seismic-related SAMAs has been 7 adequately explored and that it is unlikely that there are any cost-beneficial, seismic-related 8 SAMA candidates.

9 Entergy also did not identify any JAFNPP-specific candidate SAMAs for fire events. The fire 10 risk at JAFNPP is dominated by ten fire areas, eight of which have fire CDF contributions in 11 excess of 1 x 10

-6 per year, with the largest contributor being the Cable Spreading Room. The 12 NRC staff asked the applicant to explain what measures were taken to further reduce risk and 13 why the fire risk cannot be further reduced in a cost-effective manner (NRC 2006). In 14 supplemental information to the ER, Entergy stated that the fire area CDFs are conservative 15 and presented the results of a sensitivity analysis that reduced modeling conservatisms 16 (Entergy 2006b). This analysis, as discussed previously in Section G.2.2, reduced the 17 individual CDF contributions for three of the top four dominant fire areas to below the 18 1 x 10-6 per year threshold. Entergy also noted that the fire CDF is further reduced by IPEEE 19 improvements not included in the CDF estimate, such as restraining or relocating flammables 20 cabinets, monitoring and controlling the quantity of combustible materials in critical process 21 areas, and monitoring and control of pre-staging of outage materials (Phase I SAMAs 287 22 through 289). These measures would reduce the fire CDF in all dominant fire zones.

23 Therefore, modifications to further reduce the fire CDF are unlikely to be cost-beneficial 24 (Entergy 2006b). Entergy also stated that all but one of the six dominant fire zones are 25 equipped with fire detection systems, three of the six dominant fire zones have fire suppression 26 systems, and the Main Control Room, which has neither fire detection or fire suppression 27 systems, is always occupied ensuring prompt fire detection and manual suppression (Entergy 28 2006b). Therefore, no cost-effective hardware changes or other modifications were identified.

29 As stated earlier, other external hazards (high winds, external floods, and transportation and 30 nearby facility accidents) are below the threshold screening frequency and are not expected to 31 impact the conclusions of the SAMA analysis. However, the licensee identified a condition 32 where low pressures associated with hurricanes, tornadoes, and high winds could threaten the 33 integrity of the air intake duct work supplying the EDG room. Operating procedures were 34 developed to open switchgear room doors or to open damaged duct work if necessary to ensure 35 adequate ventilation of the switchgear room and adequate supply of combustion air to the 36 EDGs. No plant modifications were identified for these external hazards. The NRC staff 37 concludes that the applicant's rationale for eliminating fire and other external hazards 38 enhancements from further consideration is reasonable.

39 40 41 Appendix G Draft NUREG-1437, Supplement 31 G-18 June 2007 The NRC staff notes that the set of SAMAs submi tted is not all inclusive, since additional, 1 possibly even less expensive, desig n alternatives can always be postulated. However, the NRC 2 staff concludes that the benefits of any additional modifications are unlikely to exceed the 3 benefits of the modifications evaluated and that the alternative improvements would not likely 4 cost less than the least expensive alternatives evaluated, when the subsidiary costs associated 5 with maintenance, procedures, and training are considered.

6 The NRC staff concludes that Entergy used a systematic and comprehensive process for 7 identifying potential plant improvements for JAFNPP, and that the set of potential plant 8 improvements identified by Entergy is reasonably comprehensive and, therefore, acceptable.

9 This search included reviewing insights from the plant-specific risk studies, and reviewing plant 10 improvements considered in previous SAMA analyses. While explicit treatment of external 11 events in the SAMA identification process was limited, it is recognized that the prior 12 implementation of plant modifications for fire risks and the absence of external event 13 vulnerabilities reasonably justifies examining primarily the internal events risk results for this 14 purpose. 15 G.4 Risk Reduction Potential of Plant Improvements 16 Entergy evaluated the risk-reduction potential of the 63 remaining SAMAs that were applicable 17 to JAFNPP. The majority of the SAMA evaluations were performed in a bounding fashion in 18 that the SAMA was assumed to completely eliminate the risk associated with the proposed 19 enhancement. Such bounding calculations overestimate the benefit and are conservative.

20 Entergy used model re-quantification to determine the potential benefits. The CDF and 21 population dose reductions were estimated using the JAFNPP PSA model. The changes made 22 to the model to quantify the impact of SAMAs are detailed in Section E.2.3 of Attachment E to 23 the ER (Entergy 2006a). Table G-5 lists the assumptions considered to estimate the risk 24 reduction for each of the evaluated SAMAs, the estimated risk reduction in terms of percent 25 reduction in CDF and population dose, and the estimated total benefit (present value) of the 26 averted risk. The estimated benefits reported in Table G-4 reflect the combined benefit in both 27 internal and external events, as well as a number of changes to the analysis methodology 28 subsequent to the ER. The determination of the benefits for the various SAMAs is further 29 discussed in Section G.6.

30 The NRC staff questioned the assumptions used in evaluating the benefits or risk reduction 31 estimates of certain SAMAs provided in the ER (NRC 2006). SAMAs 8, 14, and 22 were each 32 modeled by assuming that reactor building failures were completely eliminated, yet the results 33 presented in the ER indicated no reduction in offsite dose. In response to the RAI, Entergy 34 revised the estimated benefit values submitted in the ER for these SAMAs and all other SAMAs 35 which directly impact the containment event tree model and alter the distribution of releases 36 within a release bin (Entergy 2007). In response to this RAI, Entergy also changed the CDF 37 reductions for Phase II SAMAs 11, 16, 17, and 39 to 0 percent to correct erroneous entries in 38 the ER. The CDF reduction values for these SAMAs are now consistent with that for SAMA 25, 39 which resolves another NRC staff RAI questioning that the benefit estimates for these SAMAs 40 June 2007 G-19 Draft NUREG-1437, Supplement 31 should not have been different (NRC 2006). Table G-4 reflects all of these revisions. Revision 1 of these benefit estimates had no impact on the original conclusions.

2 For SAMA 57, control containment venting within a narrow band of pressure, the staff noted that 3 the analysis assumptions were not directly related to the impact of the SAMA on CDF. In 4 supplemental information to the ER, Entergy described a sensitivity analysis to assure that the 5 benefit values reported for this SAMA are conservative. The sensitivity analysis resulted in a 6 decrease in the assessed benefit; Entergy thus concluded that the benefit values reported in 7 Table S-1 of the supplemental submittal (and in Table G-4) are conservative (Entergy 2006b).

8 For SAMA 61, develop a procedure to use a portable power supply for battery chargers, the 9 staff noted that the events eliminated in the analysis were not included in the list of risk 10 significant events in ER Table E.1-2. In response to an NRC staff RAI, Entergy reevaluated the 11 benefit by eliminating the failures of both DC battery chargers and both 125-V DC battery 12 control boards, which resulted in an increase in the assessed benefit (Entergy 2007).

13 The NRC staff has reviewed Entergy's bases for calculating the risk reduction for the various 14 plant improvements and concludes that the rationale and assumptions for estimating risk 15 reduction are reasonable and generally conservative (i.e., the estimated risk reduction is higher 16 than what would actually be realized). Accordingly, the NRC staff based its estimates of averted 17 risk for the various SAMAs on Entergy's risk reduction estimates.

18 G.5 Cost Impacts of Candidate Plant Improvements 19 Entergy estimated the costs of implementing the 63 candidate SAMAs through the application of 20 engineering judgment, and use of other licensees' estimates for similar improvements. The cost 21 estimates conservatively did not include the cost of replacement power during extended 22 outages required to implement the modifications, nor did they include contingency costs 23 associated with unforeseen implementation obstacles. The cost estimates provided in the ER 24 did not account for inflation. For those SAMAs whose implementation costs were originally 25 developed for severe accident mitigation design alternative analyses (i.e., during the design 26 phase of the plant), additional costs associated with performing design modifications to the 27 existing plant were not included.

28 The NRC staff reviewed the bases for the applicant's cost estimates (presented in Section E.2.3 29 of Attachment E to the ER), in supplemental information to the ER (Entergy 2006b), and in 30 response to NRC staff RAIs (Entergy 2007). For certain improvements, the NRC staff also 31 compared the cost estimates to estimates developed elsewhere for similar improvements, 32 including estimates developed as part of other applicant's analyses of SAMAs for operating 33 reactors and advanced light-water reactors. The NRC staff noted that several of the cost 34 estimates provided by the applicant were drawn from previous SAMA analyses for a dual-unit 35 site. For those cost estimates that were taken from a dual-unit SAMA analysis, Entergy reduced 36 the estimated costs by half. The staff reviewed the costs and found them to be reasonable, and 37 generally consistent with estimates provided in support of other plants' analyses.

38 Appendix G Draft NUREG-1437, Supplement 31 G-20 June 2007 The NRC staff questioned the estimated cost of $400,000 for implementation of SAMA 57, 1 control containment venting within a narrow band of pressure, for what appears to be a 2 procedure and training issue (NRC 2006). In su pplemental information to the ER, Entergy 3 further described this modification as requiring detailed engineering studies, potential hardware 4 modifications, procedure changes, simulator changes, and training (Entergy 2006b). Based on 5 this additional information, the NRC staff cons iders the estimated cost to be reasonable and 6 acceptable for purposes of the SAMA evaluation.

7 The NRC staff concludes that the cost estimates provided by Entergy are sufficient and 8 appropriate for use in the SAMA evaluation.

9 Table G-5. SAMA Cost/Benefit Screening Analysis for JAFNPP (a) 1  % Risk Reduction SAMA Assumptions CDF Population Dose Total Benefit Using 7% Discount Rate ($) (b) Total Benefit Using 3% Discount Rate ($) (b) Cost ($) Common cause failures of the SW system CDF contribution due to common cause failure of ESW pumps was eliminated 1 1 5,000 6,000 1 - Add a service water pump 5,900,000 Decay Heat Removal Capability - Torus Cooling Completely eliminate loss of torus cooling mode of RHR system events 8 9 40,000 52,000 2 - Install an independent method of suppression pool cooling 5,800,000 15 - Dedicated suppression pool cooling 5,800,000 Decay Heat Removal Capability - Drywell Spray 10 - Install a passive containment spray system Completely eliminate loss of drywell spray mode of RHR system events 8 9 40,000 51,000 5,800,000 Table G-5. SAMA Cost/Benefit Screening Analysis for JAFNPP (cont.)

1  % Risk Reduction SAMA Assumptions CDF Population Dose Total Benefit Using 7% Discount Rate ($) (b) Total Benefit Using 3% Discount Rate ($) (b) Cost ($) Filtered Vent Reduce successful torus venting accident progression source terms by a factor of two 0 4 16,000 23,000 3 - Install a filtered containment vent to provide fission product scrubbing. Option 1: Gravel bed filter Option 2: Multiple venturi scrubber 1,500,000 20 - Install a filtered vent 1,500,000 Containment Vent for ATWS Decay Heat Removal Completely eliminate ATWS sequences associated with containment bypass 3 8 28,000 38,000 4 - Install a containment vent large Entergyugh to remove anticipated transient without scram (ATWS) decay heat >1,000,000 52 - Install an ATWS sized vent >1,000,000 Table G-5. SAMA Cost/Benefit Screening Analysis for JAFNPP (cont.)

1  % Risk Reduction SAMA Assumptions CDF Population Dose Total Benefit Using 7% Discount Rate ($) (b) Total Benefit Using 3% Discount Rate ($) (b) Cost ($) Molten Core Debris Removal(c) Completely eliminate containment failures due to core-concrete interaction (not including liner failure) 0 64 34,000 48,000 5 - Create a large concrete crucible with heat removal potential under the base mat to contain molten core debris >100,000,000 6 - Create a water cooled rubble bed on the pedestal. 19,000,000 9 - Create a core melt source reduction system >5,000,000 24 - Install a reactor cavity flooding system 8,750,000 Flooding the Rubble Bed (c) 23 - Provide a means of flooding the rubble bed Completely eliminate dry core-concrete interactions 0 22 12,000 16,000 2,500,000 Table G-5. SAMA Cost/Benefit Screening Analysis for JAFNPP (cont.)

1  % Risk Reduction SAMA Assumptions CDF Population Dose Total Benefit Using 7% Discount Rate ($) (b) Total Benefit Using 3% Discount Rate ($) (b) Cost ($) Base Mat Melt-Through (c) 12 -Increase the depth of the concrete base mat or use an alternative concrete material to ensure melt-through does not occur Completely eliminate containment failures due to base mat melt-through 0 ~0 ~0 ~0 >5,000,000 Reactor Vessel Exterior Cooling (c) 13 - Provide a reactor vessel exterior cooling system Reduce probability of vessel failure by a factor of two 0 3 2,000 2,000 2,500,000 Drywell Head Flooding Completely eliminate drywell head failures due to high temperature 0 0 0 0 7 - Provide modification for flooding the drywell head >1,000,000 19 - Increase the temperature margin for seals 12,000,000 Table G-5. SAMA Cost/Benefit Screening Analysis for JAFNPP (cont.)

1  % Risk Reduction SAMA Assumptions CDF Population Dose Total Benefit Using 7% Discount Rate ($) (b) Total Benefit Using 3% Discount Rate ($) (b) Cost ($) 21 - Provide a method of drywell head flooding >1,000,000 Reactor Building Effectiveness (c) Completely eliminate reactor building failures 0 31 17,000 24,000 8 - Enhance fire protection system and SGTS hardware and procedures >2,500,000 14 - Construct a building connected to primary containment that is maintained at a vacuum >1,000,000 22 - Use alternate method of reactor building spray >2,500,000 Strengthen Containment (c) Completely eliminate all energetic containment failure modes (Direct containment heating [DCH], steam explosions, late over-pressurization) 0 28 13,000 19,000 11 - Strengthen primary and secondary containment 12,000,000 Table G-5. SAMA Cost/Benefit Screening Analysis for JAFNPP (cont.)

1  % Risk Reduction SAMA Assumptions CDF Population Dose Total Benefit Using 7% Discount Rate ($) (b) Total Benefit Using 3% Discount Rate ($) (b) Cost ($) 16 - Create a larger volume in containment 8,000,000 17 - Increase containment pressure capability (sufficient pressure to withstand severe accidents) 12,000,000 25 - Add ribbing to the containment shell 12,000,000 Vacuum Breakers

18 - Install improved vacuum breakers (redundant valves in each line) Completely eliminate vacuum breaker failures ~0 7 22,000 31,000 >500,000 DC Power Increase time available to recover offsite power (before HPCI and RCIC are lost) from 14 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during SBO scenarios 39 44 209,000 270,000 26 - Provide additional DC battery capacity 500,000 Table G-5. SAMA Cost/Benefit Screening Analysis for JAFNPP (cont.)

1  % Risk Reduction SAMA Assumptions CDF Population Dose Total Benefit Using 7% Discount Rate ($) (b) Total Benefit Using 3% Discount Rate ($) (b) Cost ($) 27 - Use fuel cells instead of lead-acid batteries

>1,000,000 30 - Provide 16-hour SBO injection 500,000 34 - Install fuel cells >1,000,000 36 - Extended SBO provisions 500,000 Improved DC System 28-Incorporate an alternate battery charging capability Completely eliminate loss of DC battery chargers 3 ~0 8,000 10,000 90,000 29 - Modification for improving DC bus reliability Completely eliminate loss of 125 VDC bus B initiator 1 1 5,000 6,000 500,000 61 - power supply for battery chargers (d) Completely eliminate loss of DC battery chargers and battery control boards 2 2 10,000 13,000 10,000 Dedicated DC Power and Additional Batteries and Divisions Completely eliminate loss of DC battery control board BCB-2A 1 1 5,000 6,000 32 - Add a dedicated DC power supply 3,000,000 Table G-5. SAMA Cost/Benefit Screening Analysis for JAFNPP (cont.)

1  % Risk Reduction SAMA Assumptions CDF Population Dose Total Benefit Using 7% Discount Rate ($) (b) Total Benefit Using 3% Discount Rate ($) (b) Cost ($) 33 - Install additional batteries or divisions 3,000,000 35-Install DC Buss cross-ties. 300,000 Alternate Pump Power Source 31 - Provide an alternate pump power source Completely eliminate SBO diesel generator failures 1 1 3,000 4,000 >1,000,000 Locate RHR Inside Containment

37 - Locate RHR inside containment Completely eliminate all RHR ISLOCA sequences 1 1 3,000 4,000 >500,000 Interfacing System Loss of Coolant

Accident (ISLOCA) 38 - Increase frequency of valve leak testing Completely eliminate all ISLOCA events 1 2 7,000 10,000 100,000 Table G-5. SAMA Cost/Benefit Screening Analysis for JAFNPP (cont.)

1  % Risk Reduction SAMA Assumptions CDF Population Dose Total Benefit Using 7% Discount Rate ($) (b) Total Benefit Using 3% Discount Rate ($) (b) Cost ($) Main Steam Isolation Valve (MSIV) Design 39 - Improve MSIV design (c) Completely eliminate containment bypass due to MSIV leakage failures 0 20 9,000 13,000 >1,000,000 Main Feedwater Completely eliminate loss of feedwater initiator 1 1 3,000 4,000 40-Install a digital feedwater upgrade 1,500,000 Backup Water for feedwater/condensate injection 41-Create ability to connect to existing or alternate water sources to feedwater/condensate Completely eliminate contribution due to failure of alternate injection from feedwater/condensate 1 1 3,000 4,000 170,000 43-Install motor driven feedwater pump Completely eliminate the failure of feedwater turbine driven pumps ~0 0 0 0 1,650,000 Table G-5. SAMA Cost/Benefit Screening Analysis for JAFNPP (cont.)

1  % Risk Reduction SAMA Assumptions CDF Population Dose Total Benefit Using 7% Discount Rate ($) (b) Total Benefit Using 3% Discount Rate ($) (b) Cost ($) Diesel to condensate storage tank (CST)

Makeup Pumps

42 - Install an independent diesel for the CST makeup pumps Completely eliminate switchover from CST to torus failures 2 ~0 2,000 3,000 135,000 High Pressure Injection System HPCI system is always available 3 1 8,000 10,000 44 - Provide an additional high pressure injection pump with independent diesel >1,000,000 45 - Install independent AC high pressure injection system >1,000,000 46 - Install a passive high pressure system >1,000,000 48 - Install an additional active high pressure system >1,000,000 49 - Add a diverse injection system >1,000,000 Table G-5. SAMA Cost/Benefit Screening Analysis for JAFNPP (cont.)

1  % Risk Reduction SAMA Assumptions CDF Population Dose Total Benefit Using 7% Discount Rate ($) (b) Total Benefit Using 3% Discount Rate ($) (b) Cost ($) Improve the Reliability of High Pressure Injection System

47 - Improved high pressure systems Reduce HPCI system failure probability by a factor of 3 2 ~0 6,000 7,000

>1,000,000 Increase reliability of instrument air after loss of offsite power (LOSP) Reduce probability of failure of normal electric power supply to air compressors by a factor of 10 ~0 0 0 0 50-Modify EOPs for ability to align diesel power to more air compressors 1,200,000 Safey relief valve (SRVs) Reseat 51 - Increase SRV reseat reliability Completely eliminate stuck open SRV events 4 4 18,000 23,000 2,200,000 Table G-5. SAMA Cost/Benefit Screening Analysis for JAFNPP (cont.)

1  % Risk Reduction SAMA Assumptions CDF Population Dose Total Benefit Using 7% Discount Rate ($) (b) Total Benefit Using 3% Discount Rate ($) (b) Cost ($) Diversity of Explosive Valves 53 - Diversify explosive valve operation Completely eliminate common cause failures of SLC explosive

valves ~0 0 0 0

>200,000 Prevent catastrophic containment failure Reduce CDF contribution in scenarios where containment venting is successful by a factor of 2 2 2 10,000 14,000 54-Implement passive overpressure relief >500,000 Improve control rod drive (CRD) reactor vessel injection reliability Eliminate failure of CRD reactor vessel injection ~0 0 0 0 55-Change CDR flow control valve failure position to the "fail-safest" position >140,000 Large Break LOCA 56 - Provide digital large break LOCA protection Completely eliminate large break LOCAs ~0 0 0 0 >100,000 Table G-5. SAMA Cost/Benefit Screening Analysis for JAFNPP (cont.)

1  % Risk Reduction SAMA Assumptions CDF Population Dose Total Benefit Using 7% Discount Rate ($) (b) Total Benefit Using 3% Discount Rate ($) (b) Cost ($) Controlled Containment Venting 57 - Control containment venting within a narrow band of pressure Reduce probability of operator to recognize the need to vent the torus by a factor of 3 14 16 74,000 95,000 400,000 RHR heat removal Completely eliminate CDF contribution from failure of cross-tie from fie protection to RHR heat exchanger "A"~0 1 2,000 3,000 58-Provide tap from fire protection to RHR heat exchanger "B" via RHRSW header B 150,000 Injection and containment heat removal Complete eliminate failure from residual heat removal service water (RHRSW )loop B 11 12 56,000 73,000 59- Provide a cross-tie between RHRSW trains downstream of the RHRSW pump discharge valves 400,000 Table G-5. SAMA Cost/Benefit Screening Analysis for JAFNPP (cont.)

1  % Risk Reduction SAMA Assumptions CDF Population Dose Total Benefit Using 7% Discount Rate ($) (b) Total Benefit Using 3% Discount Rate ($) (b) Cost ($) Turbine Bypass Eliminate CDF contribution due to loss of power conversion system (PCS) initiator 10 7 42,000 52,000 60-Improve turbine bypass valve capability 745,000 Emergency Diesel Generators 21 24 116,000 149,000 62-Develop a procedure to open the doors of the EDG buildings upon receipt of a high temperature alarm Reduce probability of EDG to run failures by a factor of three. 10,000 Reactor Vessel Instrumentation Completely eliminate CDF contribution due to loss of reactor vessel water level reference leg 2 2 7,000 9,000 63-Provide additional reactor vessel monitoring and actuation system 1,200,000 (a) SAMAs in bold are potentially cost-beneficial 2 (b) Unless noted otherwise by Footnote (c) or (d), estimated benefits taken from Table S-1 in the supplemental information to the ER (Entergy 2006b) 3 (c) Estimated benefits taken from a revised assessment provided in response to RAI 5.7 (Entergy 2007) 4 (d) Estimated benefits taken from a revised assessment provided in response to RAI 5.1 (Entergy 2007) 5 Appendix G June 2007 G-35 Draft NUREG-1437, Supplement 31 G.6 Cost-Benefit Comparison 1 Entergy's cost-benefit analysis and the NRC staff's review are described in the following 2 sections.

3 G.6.1 Entergy's Evaluation 4 The methodology used by Entergy was based primarily on NRC's guidance for performing cost-5 benefit analysis, i.e., NUREG/BR-0184, Regulatory Analysis Technical Evaluation Handbook 6 (NRC 1997a). The guidance ivolves determining the net value for each SAMA according to the 7 following formula:

8 Net Value = (APE + AOC + AOE + AOSC) - COE where, 9 APE = present value of averted public exposure ($)

10 AOC = present value of averted offsite property damage costs ($)

11 AOE = present value of averted occupational exposure costs ($)

12 AOSC = present value of averted onsite costs ($)

13 COE = cost of enhancement ($).

14 If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the 15 benefit associated with the SAMA and it is not considered cost-beneficial. Entergy's derivation 16 of each of the associated costs is summarized below.

17 NUREG/BR-0058 has recently been revised to refl ect the agency's policy on discount rates.

18 Revision 4 of NUREG/BR-0058 states that two sets of estimates should be developed, one at 3 19 percent and one at 7 percent (NRC 2004).

20 Averted Public Exposure (APE) Costs 21 The APE costs were calculated using the following formula:

22 APE = Annual reduction in public exposure (person-rem/year) 23 x monetary equivalent of unit dose ($2000 per person-rem) 24 x present value conversion factor (10.76 based on a 20-year period with a 25 7-percent discount rate).

26 As stated in NUREG/BR-0184 (NRC 1997a), it is important to note that the monetary value of 27 the public health risk after discounting does not represent the expected reduction in public 28 Appendix G Draft NUREG-1437, Supplement 31 G-36 June 2007health risk due to a single accident. Rather, it is the present value of a stream of potential 1 losses extending over the remaining lifetime (in this case, the renewal period) of the facility.

2 Thus, it reflects the expected annual loss due to a single accident, the possibility that such an 3 accident could occur at any time over the renewal period, and the effect of discounting these 4 potential future losses to present value. For the purposes of initial screening, which assumes 5 elimination of all severe accidents due to internal events, Entergy calculated an APE of 6 approximately $35,000 for the 20-year license renewal period.

7 Averted Offsite Property Damage Costs (AOC) 8 The AOCs were calculated using the following formula:

9 AOC = Annual CDF reduction 10 x offsite economic costs associated with a severe accident (on a per-event basis) 11 x present value conversion factor.

12 For the purposes of initial screening, which assumes all severe accidents due to internal events 13 are eliminated, Entergy calculated an annual offsite economic risk of about $3,300 based on the 14 Level 3 risk analysis. This results in a discounted value of approximately $36,000 for the 20-15 year license renewal period.

16 Averted Occupational Exposure (AOE) Costs 17 The AOE costs were calculated using the following formula:

18 AOE = Annual CDF reduction 19 x occupational exposure per core damage event 20 x monetary equivalent of unit dose 21 x present value conversion factor.

22 Entergy derived the values for averted occupational exposure from information provided in 23 Section 5.7.3 of the regulatory analysis handbook (NRC 1997a). Best estimate values provided 24 for immediate occupational dose (3300 person-rem) and long-term occupational dose (20,000 25 person-rem over a 10-year cleanup period) were used. The present value of these doses was 26 calculated using the equations provided in the handbook in conjunction with a monetary 27 equivalent of unit dose of $2000 per person-rem, a real discount rate of 7 percent, and a time 28 period of 20 years to represent the license renewal period. For the purposes of initial screening, 29 which assumes all severe accidents due to internal events are eliminated, Entergy calculated an 30 AOE of approximately $1,000 for the 20-year license renewal period.

31 Averted Onsite Costs 32 June 2007 Draft NUREG-1437, Supplement 31 G - 37 Averted onsite costs (AOSC) include averted cleanup and decontamination costs and averted 1 power replacement costs. Repair and refurbishment costs are considered for recoverable 2 accidents only and not for severe accidents. Entergy derived the values for AOSC based on 3 information provided in Section 5.7.6 of NUREG/BR-0184, the regulatory analysis handbook 4 (NRC 1997a).

5 Entergy divided this cost element into two parts - the onsite cleanup and decontamination cost, 6 also commonly referred to as averted cleanup and decontamination costs, and the replacement 7 power cost.

8 Averted cleanup and decontamination costs (ACC) were calculated using the following formula:

9 ACC = Annual CDF reduction 10 x present value of cleanup costs per core damage event 11 x present value conversion factor.

12 The total cost of cleanup and decontamination subsequent to a severe accident is estimated in 13 the regulatory analysis handbook to be $1.5 x 10 9 (undiscounted). This value was converted to 14 present costs over a 10-year cleanup period and integrated over the term of the proposed 15 license extension. For the purposes of initial screening, which assumes all severe accidents 16 due to internal events are eliminated, Entergy calculated an ACC of approximately $32,000 for 17 the 20-year license renewal period.

18 Long-term replacement power costs (RPC) were calculated using the following formula:

19 RPC = Annual CDF reduction 20 x present value of replacement power for a single event 21 x factor to account for remaining service years for which replacement power is 22 required 23 x reactor power scaling factor 24 For the purposes of initial screening, which assumes all severe accidents due to internal events 25 are eliminated, Entergy calculated an RPC of approximately $22,000 for the 20-year license 26 renewal period.

27 Using the above equations, Entergy estimated the total present dollar value equivalent 28 associated with completely eliminating severe accidents from internal events at JAFNPP to be 29 about $125,000. Use of a multiplier of 4 to account for external events increases the value to 30 $500,000 and represents the dollar value associated with completely eliminating all internal and 31 external event severe accident risk at JAFNPP.

32 Appendix G Draft NUREG-1437, Supplement 31 G-38 June 2007Entergy's Results 1 If the implementation costs for a candidate SAMA exceeded the calculated benefit, the SAMA 2 was considered not to be cost-beneficial. In the baseline analysis contained in the ER (using a 3 7 percent discount rate, and considering the combined impact of both external events and 4 uncertainties), Entergy identified five potentially cost-beneficial SAMAs. The potentially cost-5 beneficial SAMAs are:

6

• SAMA 26 - provide additional DC battery capacity to ensure longer battery capability 7 during the station blackout event, which would extend HPCI/RCIC operability and allow 8 more time for AC power recovery.

9

• SAMA 30 - modify plant equipment to provide 16-hour SBO injection to improve 10 capability to cope with longer SBO scenarios.

11

• SAMA 36 - modify plant equipment to extend DC power availability in an SBO event, 12 which would extend HPCI/RCIC operability and allow more time for AC power recovery.

13

• SAMA 61 - modify plant procedures to allow use of a portable power supply for battery 14 chargers, which would improve the av ailability of the DC power system.

15

• SAMA 62 - modify plant procedures to open the doors of the EDG buildings upon 16 receipt of a high temperature alarm, which improves the reliability of the EDGs following 17 high temperatures in the EDG buildings.

18 Entergy performed additional analyses to evaluate the impact of alternative discount rates and 19 remaining plant life on the results of the SAMA assessment. No additional SAMA candidates 20 were determined to be potentially cost-beneficial (Entergy 2006a). In supplemental information 21 to the ER, Entergy provided a revised assessment based on a separate accounting of 22 uncertainties. The revised assessment resulted in identification of the same potentially cost-23 beneficial SAMAs. However, based on further consideration of potentially cost-beneficial 24 SAMAs at other plants, Entergy identified one additional potentially cost-beneficial SAMA for 25 JAFNPP (Entergy 2006b). The potentially cost-beneficial SAMAs, and Entergy's plans for 26 further evaluation of these SAMAs are discussed in more detail in Section G.6.2.

27 G.6.2 Review of Entergy's Cost-Benefit Evaluation 28 The cost-benefit analysis performed by Entergy was based primarily on NUREG/BR-0184 (NRC 29 1997a) and was conducted consistent with this guidance.

30 In the ER, Entergy evaluated the reduction in risk for each SAMA in the context of an upper 31 bound analysis which combined the impact of external events with the impact of uncertainty.

32 The impact of external events was considered by applying a multiplier of 4.1 to the estimated 33 SAMA benefits in internal events (1 + [fire CDF of 8.53 x 10

-6 per year] / [internal events CDF of 34 June 2007 Draft NUREG-1437, Supplement 31 G - 39 2.74 x 10-6 per year]). The impact of uncertainties was considered by applying an additional 1 multiplier of 3.83, which represents the ratio of the 95th percentile CDF to the mean CDF for 2 internal events. Entergy bounded the combined impact of external events and uncertainties by 3 applying a multiplier of 16 to the estimated SAMA benefits in internal events.

4 In an RAI, the NRC staff requested that the baseline evaluation be revised to include only the 5 impact of internal and external events (without uncertainties), and that the impact of analysis 6 uncertainties on the SAMA evaluation results be considered separately (NRC 2006). In 7 supplemental information to the ER, Entergy revised the baseline benefit values by applying a 8 multiplier of 4 to the estimated SAMA benefits in internal events to account for potential SAMA 9 benefits in both internal and external events (Entergy 2006b).

10 As a result of the revised baseline analysis (using a multiplier of 4 and a 7 percent real discount 11 rate), Entergy found that the same five SAMA candidates (mentioned above) remained 12 potentially cost-beneficial. No additional SAMA candidates were found to be potentially cost-13 beneficial. When benefits were evaluated using a 3 percent discount rate, as recommended in 14 NUREG/BR-0058, Revision 4 (NRC 2004), no additional SAMAs were determined to be 15 potentially cost-beneficial.

16 Entergy considered the impact that possible increases in benefits from analysis uncertainties 17 would have on the results of the SAMA assessment. In the ER, Entergy presents the results of 18 an uncertainty analysis of the internal events CDF which indicates that the 95 percentile value is 19 a factor of 3.83 times the mean CDF. Entergy re-examined the Phase II SAMAs to determine if 20 any would be potentially cost-beneficial if the revised baseline benefits were increased by an 21 additional factor of 4. No additional SAMAs were identified.

22 The NRC staff questioned the ability of several of the candidate SAMAs identified in the ER to 23 accomplish their intended objectives or provide the estimated risk reductions (NRC 2006). In 24 response to the RAI, Entergy provided revised or new evaluations as discussed below.

25

• Phase II SAMA 57, control containment venting within a narrow pressure band, was 26 identified as a potential SAMA to further reduce the risk contribution from basic event 27 NVP-XHE-FO-LVENT, operator fails to vent containment using the direct torus vent.

28 This SAMA would be subject to the same failure-to-vent human error as in the basic 29 event. The NRC staff questioned both the risk reduction estimate provided by Entergy 30 for this SAMA, as well as whether an alter native SAMA to create a passive vent system 31 might be more effective in reducing the risk from this event and be cost-beneficial (NRC 32 2006). 33 In the ER, Entergy estimated the benefit of controlling containment venting within a 34 narrow pressure band by reducing the probability of operator failure to vent by a factor of 35 3. In supplemental information to the ER, Entergy included a sensitivity analysis in 36 which continued vessel injection from LPCI or Core Spray was credited for those 37 sequences in which torus venting is successful and alternative injection systems fail after 38 torus venting (Entergy 2006b). Since the available net positive suction head (NPSH) is 39 Appendix G Draft NUREG-1437, Supplement 31 G-40 June 2007likely to be less than the required NPSH with the vent open, a failure probability of 0.9 1 was assigned for this new success path. The PSA model change resulted in about a 2 0.5-percent reduction in CDF, a 0.6-percent reduction in population dose, and a benefit 3 (including the impact of uncertainties) of approximately $10,000. Entergy concluded that 4 the original benefit values reported for SAMA 57 (and reported in Table G-4) are more 5 conservative (Entergy 2006b). Therefore, this SAMA continues to not be cost-beneficial 6 at JAFNPP.

7 The NRC staff also asked the applicant to provide an evaluation of the costs and 8 benefits of converting the vent system to a passive design. In response, Entergy 9 evaluated a new SAMA that would convert the ex isting torus vent to a passive torus vent 10 (Entergy 2007). The benefit of this SAMA was conservatively estimated by removing 11 operator failure to implement torus venting (NVP-XHE-FO-LVENT was set to zero).

12 Entergy estimated that this modification would result in a CDF reduction of about 18 13 percent, a population dose reduction of about 20 percent, and a benefit (7 percent 14 baseline with uncertainty) of approximately $377,000. However, Entergy estimated the 15 cost of implementing this SAMA to be greater than $1M. Therefore, this SAMA 16 alternative would not be cost-beneficial at JAFNPP.

17 Phase II SAMA 61, develop a procedure to use a portable power supply for battery 18 chargers, was identified as a potential SAMA to improve DC system reliability. The staff 19 questioned the risk reduction estimate provided by Entergy for this SAMA since the 20 events identified as being eliminated for the analysis were not included in the list of risk 21 significant events in ER Table E.1-2. In response to an NRC staff RAI, Entergy 22 performed a revised evaluation by eliminating failures of both DC battery chargers and 23 both 125-V DC battery boards. The PSA mode l change resulted in about a 2-percent 24 reduction in CDF, a 2-percent reduction in population dose, and a benefit (including the 25 impact of uncertainties) of approximately $40,000. Entergy concluded that this SAMA 26 remains potentially cost-beneficial (Entergy 2007).

27 The NRC staff noted that for certain SAMAs considered in the ER, there may be alternatives 28 that could achieve much of the risk reduction at a lower cost. Several of these alternatives were 29 evaluated by Entergy subsequent to the ER, and described in the supplemental information to 30 the ER (Entergy 2006b). One such alternative involves use of a portable generator to extend 31 the coping time in loss of AC power events (to power battery chargers). Based on a bounding 32 analysis in which the probability of non-recovery of offsite power for 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> was changed to 24 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> for SBO scenarios, this alternative was estimated to result in a CDF reduction of about 39 34 percent, a population reduction of 44 percent, and a benefit (including impact of uncertainties) of 35 $838,000. Since the estimated cost of implementing and using the portable generator is 36 $712,000, Entergy concluded that this SAMA is potentially cost-beneficial to JAFNPP.

37 The NRC staff asked the applicant to evaluate several additional lower cost alternatives to the 38 SAMAs considered in the ER. These alternatives included: (1) use a portable generator to 39 provide alternate DC feed to panels supplied only by the DC bus, (2) addition of a redundant 40 diesel fire pump to address event FXT-ENG-FR-76P1, diesel driven fire water pump 76P-1 fails 41 June 2007 Draft NUREG-1437, Supplement 31 G - 41to continue to run (an alternative to SAMA 49, which involves addition of an entire new injection 1 system), and (3) several additional alternatives (NRC 2006). Entergy provided a further 2 evaluation of these alternatives, as summarized below.

3

• Use of a portable generator to provide power to an individual 125 VDC Motor Control 4 Center (MCC), which would support returning HPCI to service in the event its bus was to 5 fail -- Based on a bounding analysis in which failure of the HPCI system was eliminated, 6 this alternative was estimated to result in a CDF reduction of about 3 percent, a 7 population dose reduction of 1 percent, and a benefit (including impact of uncertainties) 8 of $34,000 (Entergy 2006b). However, Entergy estimated the cost of implementing this 9 alternative to be approximately $700K. Therefore, this alternative would not be cost-10 beneficial at JAFNPP.

11

• Use of a third redundant diesel fire pump to address event FXT-ENG-FR-76PI -- Based 12 on a bounding analysis in which events FXT-EG-FR-76PI and FPS-MAI-MA-P4 are set 13 to zero in the PSA model, this alternative was estimated to result in a CDF reduction of 14 about 1 percent, a population dose reduction of 1 percent, and a benefit (including the 15 impact of uncertainties) of $20,000. However, Entergy estimated the cost of 16 implementing this alternative to be approximately $2M (Entergy 2007). Therefore, this 17 alternative would not be cost-beneficial at JAFNPP.

18 Entergy indicated that the remaining low cost alternatives identified in the RAI are 19 already implemented or already addressed by existing plant procedures.

20 21 In response to an NRC staff RAI, Entergy indicated that the five potentially cost-beneficial 22 SAMAs identified in the ER plus the one additional potentially cost-beneficial SAMA identified in 23 the supplemental information to the ER have all been entered into the licensee's engineering 24 request process to be evaluated for implementation (Entergy 2007). SAMAs 26, 30, 36 and the 25 one additional SAMA were combined into a single engineering request to determine and 26 implement the best approach to extend station battery capacity. SAMA 61 has been approved 27 as a minor modification and is scheduled for installation for late 2007. SAMA 62 was 28 implemented in November 2006 by revising applicable annunciator response procedures.

29 The NRC staff notes that all of the potentially cost-beneficial SAMAs identified in either 30 Entergy's baseline analysis or uncertainty analysis are included within the set of SAMAs that 31 Entergy plans to further evaluate. The NRC staff concludes that, with the exception of the 32 potentially cost-beneficial SAMAs discussed above, the costs of the other SAMAs evaluated 33 would be higher than the associated benefits.

34 G.7 Conclusions 35 Entergy compiled a list of 293 SAMAs based on a review of: the most significant basic events 36 from the plant-specific PSA, insights from the plant-specific IPE and IPEEE, Phase II SAMAs 37 Appendix G Draft NUREG-1437, Supplement 31 G-42 June 2007 from license renewal applications for other plants, and review of other NRC and industry 1 documentation. A qualitative screening removed SAMA candidates that (1) were not applicable 2 at JAFNPP due to design differences, (2) had already been implemented at JAFNPP, or (3) 3 were similar and could be combined with another SAMA. Based on this screening, 230 SAMAs 4 were eliminated leaving 63 candidate SAMAs for evaluation.

5 For the remaining SAMA candidates, a more detailed design and cost estimate were developed 6 as shown in Table G-4. The cost-benefit analyses showed that five of the SAMA candidates 7 were potentially cost-beneficial in the baseline analysis (Phase II SAMAs 26, 30, 36, 61, and 8 62). Entergy performed additional analyses to evaluate the impact of parameter choices and 9 uncertainties on the results of the SAMA assessment. No additional SAMAs were identified as 10 potentially cost-beneficial in the ER. However, as a result of additional analysis, Entergy 11 concluded that one additional SAMA is potentially cost-beneficial, i.e., use of a portable 12 generator to extend the coping time in loss of AC power events. Entergy has indicated that the 13 potentially cost-beneficial SAMAs have been entered into the engineering request process to be 14 evaluated for implementation. The NRC staff concluded that all of these SAMAs are potentially 15 cost-beneficial.

16 The NRC staff reviewed the Entergy analysis and concludes that the methods used and the 17 implementation of those methods was sound. The treatment of SAMA benefits and costs 18 support the general conclusion that the SAMA evaluations performed by Entergy are reasonable 19 and sufficient for the license renewal submittal. Although the treatment of SAMAs for external 20 events was somewhat limited, the likelihood of there being cost-beneficial enhancements in this 21 area was minimized by improvements that have been realized as a result of the IPEEE process, 22 and inclusion of a multiplier to account for external events.

23 The NRC staff concurs with Entergy's identification of areas in which risk can be further reduced 24 in a cost-beneficial manner through the implementation of the identified, potentially cost-25 beneficial SAMAs. Given the potential for cost-beneficial risk reduction, the NRC staff agrees 26 that further evaluation of these SAMAs by Entergy is warranted. However, these SAMAs do not 27 relate to adequately managing the effects of aging during the period of extended operation.

28 Therefore, they need not be implemented as part of license renewal pursuant to Title 10 of the 29 Code of Federal Regulations, Part 54.

30 G.8 References 31 Brown, W. 2005. "Baseline Population Projections Nysis Projects SEP02," New York Statistical 32 Information System, Ithaca, New York, available online at:

33 http://www.nysis.cornell.edu/data.html/ [accessed May 12, 2005].

34 Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2006a.

35 James A. FitzPatrick Nuclear Power Plant --- License Renewal Application, Appendix E:

36 Applicant's Environmental Report, Operating License Renewal Stage.

Lycoming, New York.

37 Accessible at ML062160557.

38 June 2007 Draft NUREG-1437, Supplement 31 G - 43Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2006b.

1 Letter from Pete Dietrich, Entergy, to NRC Document Control Desk.

Subject:

"Entergy Nuclear 2 Operations, Inc., James A. FitzPatrick Nuclear Power Plant, Docket No. 50-333, License No.

3 DPR-59, License Renewal Application, Amendment 1," JAFP-06-0167, Lycoming, New York, 4 dated December 6, 2006. Accessible at ML063480624.

5 Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2007. Letter 6 from Pete Dietrich, Entergy, to NRC Document Control Desk.

Subject:

"Entergy Nuclear 7 Operations, Inc., James A. FitzPatrick Nuclear Power Plant, Docket No. 50-333, License No.

8 DPR-59, License Renewal Application, Amendment 4," JAFP-07-0013, Lycoming, New York, 9 dated January 29, 2007. Accessible at ML070370170.

10 Electric Power Research Institute (EPRI). 1991 "A Methodology for Assessment of Nuclear 11 Power Plant Seismic Margin," EPRI NP-6041-SL, Revision 1, Palo Alto, CA, August 1991.

12 KLD Associates, Inc. 2003. "Nine Mile Point/JA Fitzpatrick Nuclear Facility Development of 13 Evacuation Time Estimates," Report KLD TR 370.359, Commack, New York, August 2003.

14 New York Power Authority (NYPA). 1991. "James A. FitzPatrick Nuclear Power Plant Docket 15 No. 50-333, Individual Plant Examination,"(JPN-91-048), September 1991.

16 New York Power Authority (NYPA). 1996. "James A. FitzPatrick Nuclear Power Plant Individual 17 Plant Examination for External Events," (JAF-RPT-MISC-02211), June 1996, Revision 0.

18 New York Power Authority (NYPA). 2004. Utility Participation and Internal Review Team James 19 A. Fitzpatrick PSA, Revision 2, October 2004.

20 Seismic Qualification Users Group (SQUG). 1992. "Generic Implementation Procedure (GIP) for 21 Seismic Verification of Nuclear Plant Equipment," Revision 2, Corrected, February 14, 1992.

22 U.S. Department of Agriculture (USDA). 2002. "2002 Census of Agriculture." Available online 23 at: http://www.nass.usda.gov/Census_of_Agriculture/index.asp. (Accessed April 26, 2005).

24 Accessible at ML071200083.

25 U.S. Nuclear Regulatory Commission (NRC). 1988. Generic Letter 88-20, "Individual Plant 26 Examination for Severe Accident Vulnerabilities," November 23, 1988.

27 U.S. Nuclear Regulatory Commission (NRC). 1990. Severe Accident Risks: An Assessment 28 for Five U.S. Nuclear Power Plants. NUREG-1150, Washington, D.C.

29 U.S. Nuclear Regulatory Commission (NRC). 1991. "Procedural and Submittal Guidance for the 30 Individual Plant Examination of External Event s (IPEEE) for Severe Accident Vulnerabilities,"

31 NUREG-1407, Washington, D.C., June 1991.

32 Appendix G Draft NUREG-1437, Supplement 31 G-44 June 2007U.S. Nuclear Regulatory Commission (NRC). 1991b. Generic Letter No. 88-20, Supplement 4, 1 "Individual Plant Examination of External Events for Severe Accident Vulnerabilities," NUREG-2 1407, Washington, D.C., June 28,1991.

3 U.S. Nuclear Regulatory Commission (NRC). 1994. "Staff Evaluation of the FitzPatrick 4 Individual Plant Examination (IPE) (Internal Events Only), (TAC No. M74411)," Washington, 5 D.C., May 9, 1994.

6 U.S. Nuclear Regulatory Commission (NRC). 1997a. Regulatory Analysis Technical Evaluation 7 Handbook. NUREG/BR-0184, Washington, D.C.

8 U.S. Nuclear Regulatory Commission (NRC). 1997b. Individual Plant Examination Program:

9 Perspectives on Reactor Safety and Plant Performance. NUREG-1560, Washington, D.C.

10 U.S. Nuclear Regulatory Commission (NRC). 1997c. Code Manual for MACCS2: Volume 1, 11 User's Guide. NUREG/CR-6613, Washington, D.C.

12 U.S. Nuclear Regulatory Commission (NRC). 2000a. "James A. FitzPatrick Nuclear Power 13 Plant - Review of Individual Plant Examination of External Events (IPEEE) Submittal (TAC No.

14 M83622)," Washington, D.C., September 21, 2000. Not publicly available.

15 U.S. Nuclear Regulatory Commission (NRC). 2000b. Letter from Guy S. Vissing, U.S. NRC, to 16 James Knubel, JAFNPP.

Subject:

James A. FitzPatrick Nuclear Power Plant - Plant-Specific 17 Safety Evaluation Report for Unresolved Safety Issue (USI) A-46 Program Implementation at 18 FitzPatrick Nuclear Power Plant (TAC No. M69446), April 12, 2000. Accessible at 19 ML003702154.

20 U.S. Nuclear Regulatory Commission (NRC). 2004. Regulatory Analysis Guidelines of the U.S.

21 Nuclear Regulatory Commission. NUREG/BR-0058, Rev. 4, Washington, D.C.

22 U.S. Nuclear Regulatory Commission. 2006. Letter from Samuel Hernandez, U.S. NRC, to 23 Michael Kansler, Entergy.

Subject:

Request for Additional Information Regarding Severe 24 Accident Mitigation Alternatives for James A. FitzPatrick Nuclear Power Station (TAC No.

25 MD2667), November 29, 2006. Accessible at ML063060257.

26 BIBLIOGRAPHIC DATA SHEET (See instructions on the reverse)

NRC FORM 335 (9-2004)NRCMD 3.7U.S. NUCLEAR REGULATORY COMMISSION

1. REPORT NUMBER (Assigned by NRC, Add Vol., Supp., Rev., and Addendum Numbers, if any.)

NUREG-1437, Supplement 31

3. DATE REPORT PUBLISHED MONTH June YEAR 2007 4. FIN OR GRANT NUMBER

2. TITLE AND SUBTITLE Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 31

Regarding James A. FitzPatrick Nuclear Power Plant

Draft Report

5. AUTHOR(S)

See Appendix B of Report

6. TYPE OF REPORT Technical 7. PERIOD COVERED (Inclusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address; if contractor,Division of License Renewal, Office of Nuclear Reactor Regulations, U.S. Nuclear Regulatory Commission, 9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, type "Same as above"; if contractor, provide NRC Division, Office or Region, U.S. Nuclear Regulatory Commission, Same as 8 above.

p rovide name and mailing address.)

and mailing address.)

10. SUPPLEMENTARY NOTES Docket No. 50-333; Operation License No. DPR-59

11. ABSTRACT (200 words or less)This draft supplemental environmental impact statement (SEIS) has been prepared in response to an application submitted to the NRC by Entergy Nuclear FitzPatrick, LLC and Enerty Nuclear Operations, Inc. (Entergy) to renew the operating licenses for James A. FitzPatrick Nuclear Power Plant (JAFNPP) for an additional 20 years under 10 CFR Part 54. The draft SEIS includes the NRC staff's analysis that considers and weighs the environmental impacts of the proposed action, the environmental impacts of alternatives to the proposed action, and mitigation measures available for reducing or avoiding adverse impacts. It also

includes the staff's preliminary recommendation regarding the proposed action.The NRC staff's preliminary recommendation is that the Commission determine that the adverse environmental impacts oflicense renewal for JAFNPP are not so great that preserving the option of license renewal for energy-planning decision makers would be unreasonable. This recommendation is based on (1) the analysis and f i ndings in the GEIS; (2) the EnvironmentalReport submitted by Entergy; (3) consultation with Federal, State, and local agencies; (4) the staff's own independent review;and (5) the staff's consideration of public comments received during the scoping process.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.)

James A. FitzPatrick Nuclear Power Plant, FitzPatrick,

JAFNPP, GEIS,

SEIS, EIS, Environmental Impact Statement

14. SECURITY CLASSIFICATION

13. AVAILABILITY STATEMENT unlimited (This Page) unclassified (This Report) unclassified

15. NUMBER OF PAGES

16. PRICE NRC FORM 335 (9-2004)PRINTED ON RECYCLED PAPER Washington, DC 20555-0001 P r i n t e d o n r e c y c l e d p a p e r F e d e r a l R e c y c l i n g P r o g r a m