ML072390278

Final Environmental Statement for Indian Point, Unit 2, Volume II

ML072390278
Person / Time
Site:	Indian Point
Issue date:	09/30/1972
From:	Consolidated Edison Co of New York
To:	US Atomic Energy Commission (AEC)
References
FOIA/PA-2009-0166
Download: ML072390278 (293)

Text

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   -tteen related to operation of INDIAN POINT NUCLEAR GENERATING PLANT UNIT NO. 2 CON! $OLIDATED EDISON COMPANY OF NEW YORK,           INC.

DOCKET NO. 50-247 September 1972 Volume II UNITED STATES ATOMIC ENERGY COMMISSION DIRECTORATE OF LICENSING

APPENDIX XII-I Page No. Comments from Federal, State, and Local Agencies, the Applicant, and Interested Persons on the Draft Detailed Statement of April 13, 1972 ........ . ..... A-XII-1

1. Advisory Council on Historic Preservation, May 10, 1972 .......... .................. . .. A-XII-I

2. Department of Agriculture, May 25, 1972 and August 16, 1972 ......... ................. .. A-XII-5

3. Department of the Army, May 24, 1972 .. ...... .. A-XII-8

4. Department of Commerce, May 15, 1972 .. ...... .. A-XII-11

5. Environmental Protection Agency, June 3, 1972 A-XII-15

6. Federal Power Commission, May 10, 1972 and August 1, 1972 .................. ........ A-XII-37

7. Department of Health, Education, and Welfare July 3, 1972 ............ .................. A-XII-44

8. Department of the Interior, June 29, 1972 . . . . A-XII-45

9. Department of Transportation, May 25, 1972 .... A-XII-53

10. New York State Historic Trust, May 12, 1972 . . . A-XII-54

11. New York State Department of Environmental Conservation, June 1, 1972 ..... ............ .. A-XII-55

12. New York State Office of Attorney General, June 2, 1972 ............ .................. A-XII-88

13. Westchester County Department of Planning, May 12, 1972....... . . . ................ .. A-XII-96

14. Natural Resources Defense Council, Inc. and Hudson River Fishermen's Association, April 19, 1972, June 29, 1972 and August 22, 1972 ......... A-XII-97 XII-I

APPENDIX XII-1 (cont'd) Page No.

15. Environmental Defense Fund, June 2, 1972 and June 8, 1972 ............. ................... .. A-XII-130

16. Citizens Committee for the Protection of the Environment, June 21, 1972 ....... ............ .. A-XII-132

17. Scenic Hudson Preservation Conference, June 12, 1972 ............ ................... .. A-XII-134

18. Committee to End Radiological Hazards, May 19, 1972 . . . ........... ..... .......... A-XII-137

19. Congressman Jonathan B. Bingham, May 30, 1972 . A-XII-142

20. Congressman John G. Dow, June 1, 1972 ......... ... A-XII-144

21. Congressman William F. Ryan, May 31, 1972 ........ A-XII-146

22. J. M. Burns, III, June 1, 1972 ..... .......... .. A-XII-148

23. R. L. Ottinger, May 26, 1972 .................. A-XII-152

24. Consolidated Edison Company of New York, Inc.,

May 30, 1972 ...... ............ ..... ... A-XII-153 XII-2

A1)VISORlY COUNCIL WI 2j IIISTOIXIC i'I'ESF.ItVATI ON WASHINGTON. D.C. 20240 MAY1-MAY 1-1

Dear Mr. Rogers:

RE: Indian Point No. 2 Consolidated Edison Company This is in response to your request for comments on the environmental impact statement identified by a copy of your cover letter attached to this document. The staff of the Advisory Council has reviewed the submitted impact statement and suggests the following, identified by checkmark on this form: The final statement should contain (1) a sentence indicating that the National Register of Historic Places has been consulted and that no National Register properties will be affected by the project, or (2) a listing of the properties to be affected, an analysis of the nature of the effects, a discussion of the ways in which the effects were taken into account, and an account of steps taken to assure compliance with Section 106 of the National Historic Preservation Act of 1966 (80 Stat. 915) in accordance with procedures of the Advisory Council on Historic Preservation as they appear in the Federal Register, March 15, 1972. In the case of properties under the control or jurisdiction of the United States Government, the statement should show evidence of contact with the official appointed by your agency to act as liaison for pur-poses of Executive Order 115.93 of May 13, 1971, and include a discussion of steps taken to comply with Section 2(b) of the Executive Order. I The final statement should contain evidence of contact with the Historic Preservation Officer for the State involved and a copy of his comments concerning the effect of the undertaking upon-historical and archeological resources. Specific comments attached. Comments on environmental impact statements are not to be considered as comments of the Advisory Council in Section 106 matters. Sincerely your 03 {tW Robert R. Garvey, Jr. Executive Secretary cc: Dr. Louis C. Jones, Chairman, New York State Historic Trust, Parks and Recreation, Building - 2 state campus, Albany, New York 1226 w/inc. TIMK 0 .i1111ii. is ha- tq.d 1,,, th, .1it of Or), hii I.;. ii;i;* aith adrisi,,q th I'tideot aid Coipr,'esa in Ih, fip ld of Ilistoir . 1 r.,,rr'nti.. eoi rero., rdlin .,' iii',,s loiiiidiiati r, ht 'ith privatc ar'tivitiun, adri.ýhl

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UNiTED STATES

      .                      ATOMIC ENZRGY COMMISSION WASHINGTON, D.C. 20545 S i Docket No. 50-247                             APR 14 M Mr. Robert. Garvey, Executive Director Advisory Council on Historic Preservation Suite 1100 801 19th Street, N.W.

Washington, D.C. 20006

Dear Mr. Garvey:

I am forwarding for your review and comment 1 copy of the environmental impact documentation identified in the enclosure to this letter. The draft environmental statement was prepared by my staff in accordance with the statement of general policy and procedure on implementation of the National Environmental Policy Act of 1969, as set out in Appendix D of the Commission's regulations 10 CFR Part 50. All comments on this draft environmental statement must be received by this office by May 13, 1972. Recent delays in the receipt of comments on draft environmental statements from several agencies have resulted in significant delays in preparation of final environmental statements. We desire your comments but must emphasize the need for timeliness. Please contact me or my staff regarding any problens which may be encountered in these matters. Mr. Gene A. Blanc of my staff has been designated for day-to-day contact in this area. Sincerely, Lester Rogers, Director Division of Radiological and Environmental Protection

Enclosure:

List of Documents Transmitted 04 cc: Chairman New York State Historic Trust, Parks and Recreation Building 2, State Campus Albany, New York 12226

DEPARTMENT OF AGRICULTURE OFFICE OF THE SECRETARY WASHINGTON, D. C. 20250 May 25, 1972 50-247 Mr. Lester Rogers Director, Division of Radiological and Environmental Protection U. S. Atomic Energy Commission Washington, D. C. 20545

Dear Mr. Rogers:

We have had the draft environmental statement for the Consolidated Edison Company of New York Indian Point Unit No. 2 reviewed in the relevant agencies of the Department of Agriculture. Comments from the Soil Conservation Service, an agency of the Department, are enclosed. The Forest Service has not yet completed its review and will communicate directly with you at a later date if they have any comments. Sincerely, T. C. BYERLY Assistant Di ector Science and ducatio7n Enclosure G-5

SOIL CONSERVATION SERVICE, USDA Comments on Draft Environmental Statement Prepared by U. S. Atomic Energy Commission on the Proposed Issuance of an Operating License for Indian Point Unit No. 2, Nuclear Generating Plant Chapter IV In a number of places this chapter mentions site preparation and landscaping. This section could be improved by saying prompt vegetative measures, land-scaping work, etc., will be done to reduce erosion in the area disturbed and denuded in the construction operations. Page IV Paragraph B last sentence From at least one standpoint, the information in this sentence can be improved by stating whether the 275 employees needed to operate and maintain the facilities will be imported or made up of local employment forces. Page VII-8 The last two sentences in paragraph 5 seem to have a redundant wording on observable effects. Page X-ll - first paragraph under C This paragraph brings out good points. The question occurs to the reviewer, "what are the average monthly homeowners' cost for such delays?" Page XI-l - last paragraph The first sentence in this paragraph is a little difficult to understand. It sounds like "gas operation of the Indian Point Unit No. Z should be financially pre-ferred over the older oil-fired plants." Perhaps the of in this sentence is not needed. Inthe next sentence, should the words, lesser adverse, be followed by effects. Page XI-Z On the first line, "latter" would appear to be more appropriate than "later." Page XI paragraph g. Employment Here it would be well to mention whether employee will come from the local force or will they be imported from outside this region. OG

50-247

           !-.UNITED  STATES DEPARTMENT OF AGRICULTURE FOREST SERVICE
        -                  Washington,   D. C.
                                                           .IG 1 6 1972 1940 Mr. Lester Rogers, Director Division of Radiological & Environmental Protection Atomic Energy Commission Washington, D. C.        20545

Dear Mr. Rogers:

We have reviewed the draft environmental statement related to the Proposed Issuance of an Operating License to the Consolidated Edison Company of N.Y. for the Indian Point Unit No. 2 Nuclear Generating Plant - Docket No. 50-247. Our comments follow: The primary concern to land vegetation will be from production of sulfur dioxide (S02) by the burning of fossil fuels. Apparently, pollution from this source will be reduced once the Plant begins operation. No mention is made of the possible effects of Chlorine gas on nearby vegetation, when Chlorine is added to incoming water. It may be of benefit to know if there is damage from this gas near the Plant site. The problem of noise pollution seems to have been considered since the applicant plans to use land vegetation in noise reduction and visual enhancement of the Plant. The applicant seemingly has made plans to carry out a continuous monitoring program to detect any adverse effects from the Plant operation on the surrounding environment. This effort should be a primary requirement in keeping the Plant in operation. Sincerely, THOMAS C. NELSON Deputy Chief 07

DEPARTMENT OF THE ARMY NEW YORK DISTRICT, CORPS OF ENGINEERS 26 FEDERAL PLAZA NEW YORK. N.Y. 10007 REPLY TO ATTENTION OF: NANEN-E 24 may 1972 Mr. Lester Rogers, Director Division of Radiological and Environmental Protection N United States Atomic Energy Commission Washington, D. C. 20545

Dear Mr. Rogers:

This is in reply to your letter of 14 April 1972, requesting comments on the draft environmental statement prepared by your staff for Indian Point 2. Comments concerning the statement are as follows:

a. Page ii - item e. According to the application submitted by.Consolidated Edison for a Section 13 Permit under the Refuse Act of 1899, submitted on 24 June 1971 and revised 27 October 1971, the total average flow for units 1 and 2 is 1,954 cfs. However, the value reported in the statement is 2600 cfs.

This discrepancy should be clarified. In addition, the permit application reveals temperature differentials during summer and winter of l4t and 280 F respectively. Throughout the statement, reference is made to a temperature differential of 15°"F.. Itis suggested that this value be clarified to indicate whether it represents an average value throughout the operating year or for the summer months only.

b. Page 111-12, Second paragraph. Con Edison's application for a Section 10 permit to modify the discharge structure and install a steel outfall section consisting of 12 submerged openingwas approved on 24 November 1970.

Application for a Section 13 permit under the Refuse Act Permit Program was made on 24 June 1971 and was revised on 27 October 1971. The applicant was requested by EPA to provide additional information on various environmental aspects which were deemed necessary to properly evaluate their application. The estimated date for final action on the Section 13 Permit is 31 December 1972.

c. Page 1-4 (See attached Sheet).

d. Page 1-5 (See attached Sheet).

C8

NANEN-E 24 May 1972 Mr. Lester Rogers, Director

e. Page V-4. The flow of 1,200,000 gpm appears to be based upon the maximum design flow of 2600 cfs and not average conditions (i.e. 877,000 gpm).

f. Page VII-4. Throughout the discussion on this page, reference is made to a maximum flow of 840,000 gpm and 30,000 gpm service water. However, on page V-4, reference is made to a flow of 1,200,000 gpm, which although be-ing greater than the previous flow, is not considered maximum. It is sug-gested that description of flow be prefaced by maximum, minimum or average conditions to avoid confusion.

Sincerely yours, Engineering Division 09

1-4 AGENCY DATE OF ISSUANCE PERMIT, LICENSE, ETC. Federal 4-3-57 Section 10 Permits Department of the Army Permit No. 5236 to construct New York District wharf, screenwells and dis-Corps of Engineers charge tunnel, to install pipes, to dredge and place fill. Permit No. 5891. to construct a 1-8-60 dike in Lents Cove, Hudson R. 2-23-66 Permit No. 7184 to place fill. 3-15-66 Permit No. 7184-.A to approve revised plans and to construct a discharge channel extension wall and a screenwell structure, to place fill and to dredge. 1-19-67 Permit No. 7184-B to approve revised plans to supersede plans approved by Permit No. 7184 and 7184-A. 9-29-67 Permit*No. 7562 to construct a screenweil, bulkheads and a discharge channel,/to dredge, to place dredged material be-hind bulkheads and to install temporary dolphins. 11-24-70 Permit No. 7562-A to approve revised plans to supersede plans approved by Permit No. 7562. Additionally to install a steel outfall section consisting of 12

                                            .submerged openings.

12-11-67 Permit No. 7589 to dredge flota-tion channel and to construct ramp in Lents Cove, Hudson.R.

                        .Applied 6-24-71     Section 13 permits to authorize Estimated Date of    discharge and control thermal, Issuance 12-31-72   chemical and other waste dis-charges.

10

THE SSISTANiT Washington, SECRETARY OF CO IiERCE D.C. 26230 May 15, 1972 Mr. Lester Rogers, Director. Division of Radiological & , ," Environmental Protection ' U.S. Atomic Energy Commission Washington, D. C. 20545 '/J21ii2->

Dear Mr. Rogers:

The draft detailed statement on the Environmental Considerations by the U.S. Atomic Energy Commission Related to the Proposed Issuance of an Operating License for the Indian Point Unit Number 2 Nuclear Generating Plant, Docket Number 50-247, which accompanied your letter of April 14, 1972, has been received by the Department of Commerce for review and comment. In order to give you the benefit of the Department's analysis, the following comments are offered for your consideration. In our opinion, the statement addresses a number of environmental topics and is candid in its appraisal of possible impact and probable adverse effects upon the Hudson River estuary and associated aquatic life. There are several references to the Hudson River Policy and Technical Committees that require clarification. The state-ment gives the impression that the Policy and Technical Com-mittees provide firm guidelines and direction to those research activities on the Hudson River that are paid for by the appli-cant. Such is not the case. In regard to the above comment, we offer the following suggestions. The first paragraph on Page 1-9 states that "the Ecological Studies . . . are directed by the Hudson River Technical and Policy Committees . . .". It would be more accurate to note that the ecological studies are usually coordinated with these 1,1.

2 committees, or that opinions on the design and conduct of the studies are solicited from these committees. The same para-graph implies that the Bureau of Sport Fisheries and Wildlife is concerned only with non-commercial fish and that the National Marine Fisheries Service is concerned only with commercial fish. This delineation has no factual basis, and any reference that suggests such a dichotomy of responsibilities and interest should be eliminated. The first paragraph on Page V-57 again states that ecological studies are directed by the Hudson River Policy and Technical Committees. Additionally, it is stated that the "Committees outline and supervise the studies . . ." The committees do not outline the studies, although as mentioned previously, their opinions and suggestions may be solicited by the appli-cant. Use of the verb "supervise" denotes a direct association and degree of guidance that does not accurately reflect the actual situation. The true situation should be described. The first paragraph on Page V-59 states that "These studies will be directed by the Hudson River Policy and Technical Committees " Again, this does not reflect the factual situation. A more adequate reference to the Technical and Policy Committees than employed elsewhere in the statement appears in the first paragraph on Page VIII-5, where it is noted that "The appli-cant uses the advice of the Hudson River Policy and Technical Committees . . . to plan for fish protection and for types of environmental monitoring programs In the second paragraph on Page XI-26, it is said that " the company has asked the Hudson River Policy and Technical Committee to conduct a ten-million dollar 5-year study . " So far as we are aware, the Policy Committee will not be con-ducting any studies on the Hudson River. On this same page (last paragraph) we note that an expression of opinion by a Dr. Gerald Lauer is attributed to the many aquatic biologists that have been consulted by the company. If this opinion is endorsed by all those to whom it is, at least by implication, attributed, it should be so stated. 12

3 Anadromous fishes that may be significantly affected by plant operation are listed on Page VII-7. The American shad is not listed, even though it is a fairly important commercial species and spawns upstream from the plant. If for some reason this species is not jeopardized during its migrations past the plant, an explanation for this lack of effect should be of interest. With regard to environmental radioactivity, the frequency of sample collection (at least every 6 months) should be mentioned, and benthic animals should be analyzed for radioactivity.

• On Page 11-19, benthic organisms mentioned as being common in the Indian Point area include barnacles, clams, polychaete worms and amphipods. Clams are good biological indicators for radio-activity and would be the preferred organism in this instance.

Fish species should be selected on the basis of their feeding habits so that both herbivores and carnivores are represented. We find that we are unable to make a technical evaluation of the AEC staff's statement of the radiological consequences of gaseous releases to the atmosphere. No meteorological assump-tions are listed nor can they be inferred from the references. For example, the discussion in the first paragraph on V-64 concerning average annual concentrations in the atmosphere references the document, "Meteorology and Atomic Energy -1968", as the source of an atmospheric transport computer program. We do not find any such computer program in the document. Also on page V-64 in the discussion on gaseous effluents and their average ground level concentration in each of 16 wind sectors, no mention is made of what specific wind statistics were used to make the concentration estimates and, more importantly, what the effect of river valley air channelling would be, especially since the population centers tend to be in the valley. The accidental releases are equally vague with regard to meteorological assumptions, although we understand from the "proposed Annex to Appendix D" that these assumptions are 1/10 as conservative as found in the AEC Safety Guides Nos3 and 4 for Boiling Water and Pressured Water Reactors, respec-tively. No rationale is given for such an assumption. 13

4 From the discussion on Page 111-45 regarding 4 large decay tanks which. are, filled one at a time with gaseous effluents and which have a capacity to permit a holdup time of at least 45 days, it appears that releases from these tanks will be at very irregular and infrequent times. The annual diffusion model which is customarily used in evaluating long-term consequences is only applicable if the release is routine and not biased toward any particular time or over any particular period. We concur with the AEC analysis expecting no substantive weather modification from the facility's once-through cooling system involving heat dissipation into the atmosphere by the heated river water. 'The facility is also not expected to have any~significant hydrological interactions., In section II-8E,.the last paragraph, it might be pointed out that an earthquake of intensity VII (a modified Mercalli scale) occured in New York City in 1884. In section 11-14, the 5th line reads "Tornadoes are almost unknown in New York, . . ." This is not quite true although New York State has a low incidence of tornadoes. The proba-bility of a tornado striking a point in the area of the proposed nuclear plant is approximately .00048. We hope these comments will be of assistance to you in the preparation of the final, statement. Sincerely, ';dE yR1 Galler Deputy,ssistant Secretary for Environmental Affairs 14

ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 50-247 OFFICE OF THE

                                            ./. .... ~. - :-- :-ADmINISTRATOR Mr. L. Manning Muntzing                   -

Director of Regulation " U.S. Atomic Energy Commission .Washington, D.C. 20545

Dear Mr. Muntzing:

The Environmental Protection Agency has reviewed the draft environmental statement for the Indian Point-2 Nuclear Plant and we are pleased to provide our cormments to you. The major potential environmental impact of operating the Indian Point-2 Nuclear Plant involves the effects of the once-through cooling system on aquatic biota. We agree with the Atomic Energy Commission that the potential for severe environmental effects exists for this facility and, therefore, are recommending implementation of a closed-cycle cooling system at the earliest date practicable. Where the evidence indicates that once-through cooling will damage the aquatic environment, a plant under construc-tion may be permitted to operate, but with a commitment to offstream cooling (provided that the environmental impact of the offstream cooling technique adopted is acceptable). In circumstances of substantial environmental impact, the backfitting may have to be done under an implementation schedule that requires reduced heat discharge and restricted operating levels during the times of peak environmental stress. Where the discharger can demonstrate that there is no substantial evidence of damage from once-through cooling, the plant should receive a permit to operate, but with a commitment to perform environmental monitoring and to go to offstream cooling if this monitoring produces evidence of substantial damage. 15

                             --2--

With respect to the radiological aspects of the facility, more information should be presented regarding proposed additions to waste treatment systems, and assumptions used in certain dose evaluations should be substantiated. We will be pleased to discuss our comments with you or members of your staff. Sincerely, Sheldon Meyers Director Office of Federal Activities Enclosure 1C

EPA#r'D-AEC-00047-07 TAD# 0026-72 ENVIRON*MENTAL PROTECTION AGENCY Washington, D.C. 20460 June 1972 E'71OT" TAT

                       .TMTNT      ri.            flOlMMTTC Indian Point         Nuclear Generating Plant TABLE OF CONTENTS PAGE INTRODUCTION AND CONCLUSIONS                                       1 RADIOLOGICAL ASPECTS Radioactive Waste Manage..en.                                2 Dose Assessment                                              6 Transportation and Reactor Accidents                         7 Site Meteorology                                             9 NON-RADIOLOGICAL ASPECTS
    .Water Quality and Biological Effects                        10 COST BENEFIT ANALYSIS                                             15 ADDITIONAL COMENTS Radiological Aspects                                        17 Non-Radiological Aspects                                    18 17

INTRODUCTION AND CONCLUSIONS The Environmental Protection Agency has reviewed the draft environmental impact statement for the Indian Point-2 Power Plant prepared by the U.S. Atomic Energy Commission and issued April 13, 1972. Following are our major conclusions:

1. We agree with the conclusion of the AEC that the present once-through cooling system has a potential for causing significant long-term damage to aquatic biota in the Hudson River. Thus, we recommend the adoption of a closed-cycle cooling system at the earliest date practicable.

    *2. Should the AEC determine that operation of the plant is essent *il to meet critical power demands,    we believe that power output should be limited to the lowest level necessary to satisfy that demand. We agree that monitoring be performed by the discharger,    and believe that a commitment must be made to further limit power output and go to offstream cooling if       this monitoring produces evidence of substantial damage.       We recommend that estimated environmental damage for various levels of power output be included in    the final statement.

3. In order to achieve lowest practicable radwaste dis-charge levels the present waste treatment system and all proposed modifications should be utilized to their full capabilities.

4. The proposed modifications to the treatment systems should be described in detail in the final statement.

5. The site metorology and all areas of consideration which utilize the diffusion climatology analysis should be reevaluated using more complete on-site data collected during the past 10 years of operation oi&ndian Point-l.

2 Radioactive Waste Management The draft detailed statement evaluates the radioactive waste treatment systems based on the equipment which will be used during the first fuel cycle. The statement indicates that by the end of this first cycle the applicant will have installed additional waste charges below the levels estimated in the statement. These modifica-tions include a bloeadown treatment system consisting of a filter-demineralizer; an additional demineralizer on the waste disposal system evaporator condensate line; and charcoal filters on the pliant vent to reduce radioactive iodine concentrations from auxiliary build-ing and containment purging. We are unable, from the information presented in the statement, to determine if these modifications will, in fact, reduce the effluents from Indian Point-2 to the lowest practicable levels. Therefore, the final statement should describe these modifications in detail, including proposed operating procedures and estimated time schedule of installation and operation. The anticipated effectiveness of reducing the effluents should also be described. A description of the type of demineralizers used in the blowdown treatment system is especially im-portant, since blowdown is indicated as the major source of radioactive liquid effluents. For example, 137Cs, 134Cs and 99Mo contribute the bulk of the blowdown activity, and it may be necessary to employ a special demineralizer, which is particularly effective in removing 13

3 these radionuclides, to achieve the anticipated decontamination factor (DF)., Dissolved solids in the blowdown may result in rapid loading of the demineralizer and loss of DF. If it will be necessary to re'enerate these demineralizers, the regenerant solution should be processed by the evaporator or solidified .t the drumming station. If the deminer-alizers are not re ~eracii, -ciX~iuad increase to the solid waste dispnosal facility should Lz discussed as we.i as the impact on solid waste transportation. In the final statement, the discussion of these modifications should include the possibility of alternate or additional techniques of treating radioactive blowdown. Many PWR's are installing evaporator capability to treat steam generator blowdown, and we believe that this alternative is a feasible one that could at least be considered in a cost-benefit analysis. The liquid waste system diagram in Figure 111-14 of the statement shows bypasses of the various treatment systems. A commitment should be made by the applicant to utilize the waste treatment systems it has provided. The commitment is especially important regarding the steam generator blowdown which the statement has shown to be the greatest contributor to liquidradioactive waste in the environment. The appli-cant should routinely utilize the blowdown treatment system during conditions mhere.primary-to-secondary leakage occurs. According to the statement, under conditions of primary-to-secondary leakage, steam releases from the blowdown flash tank will contain significant amounts of iodine-131. Recognizing that the amount estimated 20

4 by the AEC is 0.62 Ci/yr, which exceeds the facility's technical specifications limit and, according to the applicant's meteorology, appears to exceed 10 CFR 50 Apperdix I limits for iodine at the site boundary, the venting of this steam should be avoided. We note that Figure 111-15 -- .Iustrates a connection between the blowdon flash tank and the main condenser, for the purpose of routing the steam flash. We suggest that routine employment of this path would achieve the desired reduction in the release of 131I to meet the aforementioned standards and specifications. Experience gained at other PWR's has shown that the magnitude of leakage from the secondary system is comparable to steam generator blow-down. During periods of prin2rry-to-secondary leakage, secondary system leakage will also be contaminated. The draft detailed statement, however, does not provide an estimate of the volume or radionuclide concentrations associated with this leakage. Further, it is not clear from the FSAR or the Environmental Report whether secondary system leakage can be routed to the waste treatment system. The FSAR does indicate, from the anticipated volumes of liquid to be processed by the waste treatment system (Table 11-1.4), that this source has probably not been considered for such treatment. The final detailed statement should provide complete estimates of liquid and gaseous sources of radioactivity from secondary system leakage during primary-to-secondary leakage conditions. The holdup-capacity for the gaseous waste treatment system, which consists of four decay tanks serving Units 1 and 2, is not clearly expressed in the 'statement for the situation where both units are in operation simultaneously. It is stated that the system has 21.

5 the capability "...to permit a holdup time of 45 days for Unit-2, and up to 60 days holdup for Unit-l." This can be interpreted to mean that the system has either 45 days capacity for Unit-2 alone or 60 days capacity for Unit-i alone. Clarification of the combined capability of Lhis . -.. '%*i units are operating simultaneously, should b. r-de in the finnl stat:.-.t. Tha aj~1ýic*Lc's rechnica+/- specifications for Unit-2 requires a minimum holdup time of only 20 days, even though the capability of the system is stated as 45 days for Unit-2. To be consistent with the intent of "low as practic-able," the applicant should utilize the gaseous decay system to the full extent of its capability. This is especially significant since most of the radioactivity (as estimated both by the applicant in his environLmental report and the AEC in the statement) is due to xenon-133 with a 5.27 day half-life. 22

6 Dose Assessment The dose estimates for the ingestion of *fish as presented in the statement are not consistent with the liquid effluent discharge estimates given. It appears that effluents due to the discharge of steam generator blowIdownm, a:* -. ......

                              -"              leakage,  have been neglected   in computing this ingestion dose.        The, final statement should discuss the assumptions      for liquid effluent levels and concentration factors used to calculate the dose due to the ingestion of fish.

The doses computed from release of liquid effluents assume a dilution flow from the cooling system of approximately 1.06 gal/min. Considering the problems of fish kills due to the high condenser cooling flow and the possibility of the neces.It- to reduce the cooling flow considerably to avoid or reduce these fish kills, the statement should discuss the effect of such reduced flow on the doses involved both on individual and man-rem bases. A limited number of measurements made at operating pressurized water reactors have indicated that direct external radiation exposure from large outdoor water storage tanks (such-as the condensate storage tank) could be a significant contributor to the radiation dose received by people living close to the plant. Neither the applicant nor the AEC has estimated the potential radiation exposure from this source; such estimates should be included in the final statement. The location of the tanks in-relation to the nearest residence and the visitor's information center should be indicated. Although the period of exposure 23 I

7 is short, the applicant expects the number of visitors to the center to be large. Because of the proximity of the information center to the plant (as compared to off-site population groups), estimates of the population rad_-'_*^-*.. ....t as man-rem/yr) should be made, including the exnected number of visitor- iPpr vr pd t-1nen, external radiation dose race from olant effluents and direct shine at the visitors center. Transportation and Reactor Accidents In its review of nuclear power plants, EPA has identified a need for additional information on two types of accidents which could result in radiation exposure to the public; (1) those involving transportation of spent fuel and radioactive wastes and (2) in-plant accidents in-volving reactor systems. Many of the factors in accident analysis are common to all nuclear power plants; the environmental risk for each type of accident is there-fore amenable to a general analysis. Although the AEC has done con-siderable work for a number of years on the safety aspects of such accidents, we believe that a thorough analysis of the probabilities of occurrence and the expected consequences of such accidents is necessary. A general study would result in a better understanding of the environ-mental risks than would a less-detailed examination of the questions on a case-by-case basis. An understanding has been reached with the AEC that they will conduct such analyses, with EPA participation, con-current with reviews of impact statements for individual facilities and 24

8 will make the results public in the near future. We believe that any changes in equipment or operating procedures for individual plants, required as a result of these analyses, could be included without ap-preciably changing the overall plant design. If major redesign of the plants to include engineering changes were expected, or if an immediate public or environmental risk were being taken while these two issues were being resolved, we will, of course, make our concerns known and an updated impact statement may be necessary. The statement concludes "... jtat the environmental risks due to postulated radiological accidents are exceedingly small." The con-clusion is based on the standard accident assumptions and guidance issued by the AEC for light-water-cooled reactors as a proposed amend-ment to Appendix D of 10 CFR Part 50 on December 1, 1971. EPA commented on this proposed amendment in a letter to the Commission of January 13, 1972, indicating the necessity for a detailed discussion of the technical bases of the assumptions involved in determining the various classes of accidents and expected consequences. We believe that the general analysis of accidents mentioned above will be adequate to resolve these points and that the AEC will apply the results to all licensed facilities.

9 Site Meteorology We note that the AEC stated it has used the applicant's meteoro-logical data from the environmertal report supplement to estimate doses due to the discharge of gaseous effluents at Indian Point. We feel that use of this data is questionable, since it appears to be based primarily on 1955-1957 work done by New York University and some intermittent data gathered since that tine. Although the applicant began meteorological monitoring in 1955, and this monitoring has been more or less continuous since that time, the data used to establish the climatology is only partial data from the years 1955, 1956, 1957, 1969, and 1970. The period of record of this data is not clearly defined, but it appears to vary from ten months to as little as two months in any given year. Since Consolidated Edison has had an operating nuclear power reactor at this site since 1962, at least ten years of continuous on-site meteorological data should be available. We feel that this data should be employed to establish the climatology for the site, and that the results of the meteorological analysis using this data should be utilized to establish the various dose estimates for the operations at the site. The reevaluation should be presented in the final environmental statement. 26

1(0 NON-rADIOLOGTCAL ASPECTS Water Quality and Biological Effects In general, the draft environmental impact statement properly identifies and assesses most of the probable significant water quality and biological effects that will arise as a consequence of power generation at the Indian Point nuclear plant and indicates areas where additional in-formation is necessary. Thus, after consideration of these factors, we agree with the conclusion of the AEC that, in the operation of this plant, there is "...potential for long-term environmental impact on the aquatic biota inhabiting the Hudson River..." This impact, due to the operational characteristics of the once-through cooling system, will arise primarily because of impingement on the protective screens of the intake structure; chemical, mechanical, and thermal effects of entrainment; and the excessive heat loads in the river created by the cooling water discharge. Also, we agree with the AEC that this impact on aquatic biota may result in "...permanent damage to the fish population in the Hudson River, Long Island Sound, the adjacent New Jersey coast, and the New York Bight." New York State classifies the Hudson River at Indian Point as Type SB. Under state water quality standards for SB waters thermal discharges may not be injurious to "...edible fish or shellfish or the culture or propagation thereof." Since fish 27

11 will be killed, clearly state water quality standards will be violated. We commend the AEC for their forthright expression of the probable environmental impacts and identification of areas where information is lacking. Thus, we support their com-mitment to protect the environment by requiring the applicant to initiate additional studies of alternate cooling systems and to design and implement a comprehensive monitoring program to determine the practicality and need of a closed-cycle cooling system. We believe, however, that, based on currently available information, if the Indian Point plant is to operate within applicable New York State standards and in a manner adequate to protect aquatic biota, a closed-cycle cooling system will be necessary. We appreciate the difficulty in balancing the objective to protect the environment with that of supplying needed additional electrical power in the New York City area. In response to this demand, the AEC suggests it will be beneficial to operate the Indian Point plant while the additional studies are being conducted and while monitoring data is being collected. From an environmental standpoint, however, we cannot support operation of this plant unless it can be demonstrated that such operation will not result in a violation of New York State water quality standards or lead to a significant adverse impact on aquatic biota. The final statement should describe any measures 28

12 that will be taken to attain these goals, should it prove necessary to operate the plant before resolution of current environmental problems. Should the AEC determine that electrical energy needs of the region override environmental considerations, the final statement should predict the extent of both short- and long-term environmental damage expected at 25, 50, 75, and 100% of full power. Our analysis of the engineering aspects of the Indian Point plant, the hydrologic characteristics of the Hudson River at the plant site, and the biological system of the lower Hudson indicates that in order to adequately protect the aquatic biota, the following thermal criteria should be applied: I. Passageway a) Maximum Temperature 83'F October-June 86 0 F July-September b) Increase in Temperature AT October-June T = 40 to max of 83'F July-September T = 1.5 0 F to max of 83*F, if T norm is 'e 83'F T = 1.5'F to max of 86 0 F, if T norm is - 830 F c) Passageway to be 50% of cross-section and/or volumetric passageway or artificial fishway; in addition 1/3 of surface from water edge to water edge. 2)9

13 II Non-Passageway a) Maximum Temperature 90'F b) Mixing Zone Dimensions No standards as to dimensions Note: (1) Temperature measurements applicable to any part in stream. (2) Increase in temperature based on elevation above monthly average of daily maximum temperature. These criteria embody the strictest standards from the Federally approved New York State standards as published in "Technical Bulletin No. 36 - Thermal Aspects of Discharges on Water Resources "and New York'State promulgated standards as described in "Criteria Governing Thermal Discharges (Heated Liquids)." We recommend that the ability to meet these criteria be considered in the evaluation of various alternative cooling systems. The draft statement indicates that fish kills due to impingement will probably be higher for Unit 2 than that experienced for Unit 1. Although operating the Indian Point plant on a load-following basis will probably reduce such kills during some periods, the AEC should consider requiring the applicant to modify the intake structure and/or install mid-stream protective screens. The final statement should describe any such measures that will be taken to prevent excessive impingement during the period when the once-through cooling system is to be used. 30

14 Since excessive amounts of residual chlorine are extremely toxic to aquatic life, it is suggested that, either the quantities of sodium hypochlorite used be reduced to a safe level, or alternative means of condenser cleaning be explored. In the past, EPA has recommnended that levels of chlorine in the receiving water should not exceed 0.1 mg/l for more than 30 minutes/day or 0.05 mg/l for more than 2 hours/ day. The final statement should specify the procedures to be used to assure that the discharges of chlorine are below levels that would cause significant environmental damage. The draft statement indicates that a number of chemicals will be discharged from the Indian Point plant. Although the toxic levels of most of these will not be exceeded routinely, the final statement should consider the synergistic effect of two or more chemicals that are present at concentrations near -their respective toxic levels. Also, the effect of water temperature in the discharge plume on the toxic effects of the various chemicals should be discussed. 31

15 COST-BENEFIT ANALYSIS This statement is the first to incorporate the AEC proposed guidelines for cost-benefit analyses. This approach is helpful in. P... . la*......r format for comparing environ-mental effects. Its-application in this statement, however, points out several major weaknesses. The environmental cost tabular format does not allow for estimating the combined effects of thermal, mechanical', and chemical effects on aquatic life. The format does not provide for the incorporation of the time variable, making it virtually impossible to separate short and long term effects (assuming the data were available). Several of the items are difficult to relate to environmental costs. For example, the evaluations of cooling capacity in units of BTU/hr (or acre-ft. of elevated temperature) and consumption of water in millions of gallons per day are not meaningful numbers per se. Several other items--for example, salt deposition and fogging--require considerably more analysis to be meaningful indicators of environmental costs. To date, a meaningful measure of the principal benefits of electric power has not been identified. The statement does not providean adequate base of infor-mation to choose between the six proposed alternate coolant systems. In fact, the practicality and availability of brack-ish water cooling towers are questioned by the AMC (p. XI-O). 32

16 A spray pond, on the other hand, is estimated to exert severe adverse environmental effects .in the form of salt deposition, water consumption, fogging, and icing. Estimates of chemical discharges from cooling tow.,.ers, how.,ever, are "...not available at this time." It is recommended that the costs and benefits cf the various alternative cooling systems be described in scme detail, since these alternatives will be considered to reduce the environmental impact of the operation of Indian Point-2. The statement points out the need for a broader perspective in environmental considerations than current procedures provide. By the end of the decade, the electric generating capacity on the Hudson River within five miles of the Indian Point site will increase from the current 800 Mwe to over 6000 Mwe. The Bowline Unit I will be operational within the next few months and the Lovett Plant, already in service, is situated less than a mile downstream from Indian Point. Yet the statement only considers the combined impact of Indian Point Units I and II. There should be an analysis of the combined impact of Indian Point I, II, and III as well as'the previously'mentioned plants on nearby sites. 33

17 ADDITIONAL COY.AENTS During the review we noted in certain instances that the statement does not present sufficient information to substantiate the conclusions nre- tAccnize that much of this information is not of major imuuLuL* ru-vaiaiing the environmental impact of tLi ludin £CiIk-2 Uclear . ine cumulative eizec, however, could be significant. it would, therefore, be helpful in determining the impact of the plant if the folloTing information were included in the final statement: Radiolo~ical Aspects

1. In estimating radioactivity releases from the liquid waste disposal system, a decontamination factor (DF) of 10,000 for all radionuclides, except iodine and tritium is assumed for the waste evaporator. Actual experience, however, has shown much lower DF's. The bases for such a high DF should be presented in the final statement.

2. Table 111-7 indicates conditions at Unit-2 may result in operation at 1311 discharge levels which would exceed the technical specifications limit of 0.18 Ci/yr for 131I, if not controlled.

It should be noted, however, that even at this limit, using the applicant's meteorological diffusion parameters for the site boundary and the AEC's suggested deposition velocity, it appears the 10 CFR 50 Appendix I guidelines would be exceeded. The final statement should discuss this problem. 31

18

3. The dose from the ingestion of fish presented in the state-ment could not be verified using the various effluent levels and concentration factors presented in the statement. The assumptions and sources used to evaluate this dose should be given in Non-Radioloical Asoects

1. Ozone is an air pollutant w.*hich has been included in the National Primary and Secondary Ambient Air Quality Standards, therefore, the production of ozone by the high voltage trans-mission lines constructed to distribute electricity generated at this facility should be discussed. Concentrations of ozone in the vicinity of t0-'. 2"_'-.T should be estimated for various atmospheric conditions, and related to potential effects on man and wildlife.

2. The'AEC states that 'the Bludson River has a high buffering capacity for sodium hydroxide, lithium hydroxide, and sulfuric acid. According to the Raytheon Report, however, the discharge of ion exchange resins caused p1l changes of up to 2 units. The AEC should provide additional information which shows that discharge of sodium hydroxide, lithium hydroxide, and sulfuric acid will not alter the pH.

3. The septic tank system appears inadequate to meet secondary effluent quality. This condition will deteriorate completely when Unit No. 3 goes on line. Therefore, we recommend re-evaluation of provisions for the handling of sanitary and

                 ,                      ~35:

19 laundry wastes. The final statement should include information on septic tank sludge disposal.

4. The effects of soda ash and potassium chromate (toxic to some organisms in the discharge canal) should be evaluated in con-junction with the effects of other chemicals.

5. As imping-emnt on the intake screens has resulted in significant fish losses, detailed reference should be included on the proposed disposition of those organisms impinged.

6. An oil spill prevention, containment, and countermeasure plan should be included in the statement.

FEDERAL POWER COMMISSION WASHINGTON, D.C. 20426 IN REPLY REFER TO: PWR/ER May 10, 1972 1/4 Mr. Lester Rogers , Director, Division of Radiological 71 and Environmental Protection U. S. Atomic Energy Commission Washington, D. C. 20545

Dear Mr. Rogers:

This is in response to your letter of April 14, 1972, requesting comments on the Draft Detailed Statement on the Environmental Considerations Related to the Proposed Issuance of an Operating License to the Consolidated Edison Company of New York for the Indian Point Unit No. 2 Nuclear Generating Plant, dated April 13, 1972. The Federal Power Commission's Bureau of Power.has previously commented on the need for the Indian Point. Unit No. 2 nuclear generating plant in its letter dated December 22, 1971. These comments were included in a Bureau of Power staff report made in response to AEC's letter dated December 7, 1971, requesting comments on the Consolidated Edison Company1 s application for interim authorization to operate the Indian Point Unit No. 2 at 50 percent of full power. It is noted that the basic data included in the capacity-demand-reserve margin evaluation made by the FPC Bureau of Power staff in its December 1971 report is that used in Table X-1 of your April 13, 1972 Draft Detailed Statement; therefore, the following comments will update those made in our December 22, 1971 letter. The FPC Bureau of Power staff completed an analysis of the 1972 sunmmer load-power supply situation for the contiguous United States on April 17, 1972. As of that date, based on available data from the AEC, it appeared that the Indian Point Unit 2 might be able to achieve a significant level of power sometime in the summer, but would not be commercially available on May 31, 1972, our cut-off date for determination of firm summer resources. The Company reported its expected June 1, 1972 power resources to be 9,293 megawatts (8,823 dependable generating capacity plus 470. megawatts firm purchases) and its estimated stumner peak demand to be 37

Mr. Lester Rogers 8,400 megawatts. The resulting reserve margin is 893 megawatts, or 10.6 percent. This margin is less than the size of its largest unit, and only 45 percent of the median 1,977 megawatts of forced outages and deratings the Company experienced at the time of the weekly peaks for a fifteen week 1971 summer period. The Company expects to improve its position with the installation of 174 megawatts of barge mounted gas turbines in June and a like amount in July, but it also plans to retire 243 megawatts of old fossil fired capacity in July which, if carried out, would have an offsetting effect. The Company is also continuing its efforts to increase its firm purchases for the period. For the New York Power Pool, including the Consolidated Edison Company, the situation is only slightly better. As of June 1, 1972, the Pool's resources are projected to be 22,474 megawatts with an estimated peak demand of 19,510 megawatts, resulting in a reserve margin of 2,964 megawatts or 15.2 percent. For the Pool, a median of 3,056 megawatts of forced outages and deratings at time of weekly peak was experienced for the 1971 fifteen week summer period. In the light of the foregoing and even though the Indian Point No. 2 nuclear unit was not considered as firm capacity in the summer load forecast, the staff of the Bureau of Power, concludes that all reasonable efforts should continue to bring this unit into service at the earliest possible date. The need for added capacity to safeguard against the contingencies of forced outages, as well as the desirability of implementing scheduled preventive maintenance programs, is self evident. Very truly yours, Chief, Bureau of Power 38

FEDERAL ?OWER COMMISSION WASHINGTON, D.C. 20426 IN REPLY REFER TO: August 1, 1972

                                                             .-       ,         50-247 Mr. Daniel R. Muller                               /

Assistant Director for / . ) \ Environmental Projects Directorate of Licensing . U. S. Atomic Energy Commission Washington, D. C. 20545  % "

Dear Mr. Muller:

This is in response to your letter of July 24, 1972, requesting comment on the need for the Indian Point Unit No. 2 of the Consolidated Edison Company at both 50 percent and 100 percent power ratings for the 1972-73 winter and 1973 sumnmer peak load periods on both the Applicant's system and that of the New York Power Pool. The. Federal. Power Commission's Bureau of Power has previously commented on the need for the indian Poin.at Unit No. 2 nuclear generating plant in its letters dated September 24i, 1970, December 22, 1971 and May 10, 1972. Since the commercial operating date of this unit now is forecasted for fall and winter ,of 1972-1973, the following cotiments will update the comnents sub-mitted previously. These comments are directed to a review of the need for the facilities as concerns the adequacy and reliability of the affected bulk power systems and matters related thereto. These comments, prepared by the Bureau of Power staff, are in accordance with the National Environmental Policy Act of 1969 and the Guidelines of the President's Council on Environmental Quality dated April 23, 1971. In preparing these comments, the staff has considered the AEC Draft Detailed Statement dated April 13, 1972, the Applicant's Environmental Report and supplements thereto; related reports made. in response to the Commission's Statement of Policy on Reliability and Adequacy of Electric Service (Order No. 383-2); and the FPC staff's independent analysis of these documents together with related information from other FPC reports. The staff of the Bureau of Power generally bases its evaluation of the need for a specific bulk power facility upon the load-supply situation for the critical peak load period immediately following the availability of the facility. However, the useful lives of such facilities are generally 30 years or longer, and they will continue to serve the needs of the utility's customers during their service lives. 39

Mr. Daniel R. Muller Need for the Facility The 873-megawatt Indian Point No. 2 nuclear generating unit is now scheduled for commercial operation in the fall of 1972 or winter of 1972-73 and to be available to meet the 1972-73 winter and the 1973 summer peak periods. The Unit had been scheduled to be in commercial service prior to the 1972 sui'mmer peak and to be available to assist in meeting the Applicant's system demands during that period but suffered delays which prohibited its availability by that time. The Applicant based its need for the Indian Point Unit No. 2 on the capacity resources available to meet the 1972 summer peak loads, and the reserve margins available to provide a margin of safety against normal electric system operating contingencies. The Coimnission's letter of May 10, 1972 reported a 1972 sumaer peak reserve margin of 893 megawatts or 10.6 percent of peak load. The capacity of the Indian Point Unit No. 2 was not included in the Applicant's capacity resources since cominercial operation was not expected until after the beginning of the peak load period on June 1, 1972. Subsequently, the critical reserve margin conditions forecast for the Applicant's system did occur during the week of July 17-21, 1972 when voltage reductions of three and five percent were effected due to shortages of generating capacity. The Applicant's need for the capacity of Indian Point Unit No. 2 during the 1972-73 winter peak and the 1973 sumnier peak load periods to meet the electric loads of its system and also that of the New York Power Pool in which the Applicant is a member, is indicated by the following tabulations which have been prepared to show the relationship of the total electric resources available to meet the system's loads and the reserve margins expected to be available at those times. T'hese gross reserve margins provide for such contingencies as scheduled maintenance, unscheduled outages of equipment, and errors in load forecasting. 4~ 0

                                     -3  -

Mr. Daniel R. Muller Estimated 1972-73 Winter Peak Ioad-Sulnplv Situation Consolidated New York Edison Co. Power Pool Conditions for 100 Percent Power Rating (873 Megawatts) Total Resources - Megawatts 11,394 1/ 26,681 Net Peak Load - Megawatts 6,425 18,540 2/ Reserve Margin - Megawatts 4,969 8,141 Reserve Margin - Percent of Peak Load 77.3 43.9 Conditions for 50 Percent Power Rating (436 Megawatts) Total Resources - Megawatts 10,957 1/ 26,244 Net Peak Load - Megawatts 6,425 18,540 2/ Reserve Margin - Megawatts 4,532 7,704 Reserve Margin - Percent of Peak Load 70.5 41.6 Conditions for 20 Percent Power Rating (175 Megawatts) ...... Total Resources - Megawatts 10,696 1/ 25,983 Net Peak Load - Megawatts 6,425 18,540 0/ Reserve Margin - Megawatts 4,271 7,443 Reserve Margin - Percent of Peak Load 66.5 40.1 1/ Includes net firm purchases of 40 MW 2!/ Includes net firm sales of 22 MW 41.

Mr. Daniel R. Muller Estimated 1973 Summer Peak Load-Supply Situation Consolidated New York Edison Co. Power Pool Conditions for 100 Percent Power Rating (873 Megawatts) Total Resources - Megawatts 11,008 1/ 27,490 Net Peak Load - Megawatts 8,850 20,840 2/ Reserve Margin - Megawatts 2,158 6,650 Reserve Margin - Percent of Peak Load 24.4 31.9 Conditions for 50 Percent Power Rating (436 Megqawatts) Total Resources - Megawatts 10,531 1/ 27,053 Net Peak Load - Megawatts 8,850 20,840 2/ Reserve Margin - Megawatts 1,681 6,213 Reserve Margin Percent of Peak Load 19.0 29.8 Conditions for 20 Percent Power Rating (175 Mega,*atts_ Total Resources - Megawatts 10,270 1/ 26,792 Net Peak Load - Megawatts 8,850 20,840 2/ Reserve Margin - Megawatts 1,420 5,952 Reserve Margin - Percent of Peak Load 16.0 28.6 1/ Includes net firm purchases of 40 MW 2/ Includes net firm sales of 22 MW. The Applicant states that the minimum reserve margin criteria for it, as a member of the New York Power Pool, is currently 14 percent of the peak load and all members of the Pool have committed themselves to increasing their reserve margins capacity to 18 percent of peak load by 1975. The reserve margins for both the Applicant's system and the New York Power Pool for the 1972-73 winter peak and the 1973 summer peak load period more than meet the 14 percent criteria. The Applicant has maintained a reserve margin of 20 percent on its system which it feels is necessary to meet the operating 4~2

Mr. Daniel R. Muller problems of the Consolidated Edison Company's system. In order to meet this reserve margin in the 1973 summer peak load period, the 100 percent power rating of 873 megawatts for the Indian Point Unit No. 2 is needed. Furthermore, the Consolidated Edison system has experienced problems in meeting peak loads in the past when the theoretical reserve margins have been substantially above 20 percent of forecast peak. The capacity of the Indian Point Unit No. 2 is not critical to the Applicant's reserve capacity for the 1.972-73 winter peak period, however, the availability of this capacity can allow maintenance of other operating units not now possible. Delays are frequently experienced in bringing large new units of this size into commercial operation, and thorough testing and maturing of this unit prior to the summer peak period should improve reliability substantially. 1,1hile the 16.0 percent reserve associated with Indian Point No. 2 at 20 percent power may not appear to be critically low, the deterioration between the summer of 1972 and the summer of 1973 inability of the Consolidated Edison Company to import power must be considered. The new fossil-fired station at Proseton accounts for 480 megawatts of Con Edison's capacity d-ring the summer of 1973. Hoevever. due to litigation in the New York State courts the Rock Tavern-Ramapo 345-kilovolt circuit associated with this new generating capacity will not be in service during the summer of 1973.. The unavailability of the Rock Tavern-R]amapo circuit will reduce the ability of Applicant to import power from the winter-peaking upstate menbers of the New York Power Pool, Ontario and New England from the present value of 1,200 megawatts to 720 megawatts. This reduction in import capacity is particularly serious since during the past several sunumers during peak load periods Con Edison has regularly purchased power to the limit of its transmission capacity. Transmission Facilities A single 345-kilovolt overhead transmission line will deliver the output of the Indian Point Unit No. 2 to the Buchanan Substation. The line will parallel an existing 138-kilovolt line and will use the same right-of.-way. Line design and construction conforms to guidelines for minimal impact on the environment including the Federal Power Commission's Order No. 414 dated November 27, 1970.

                                               '43

DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE 50-247 OFFICE OF THE SECRETARY WASHINGTON. D.C. 20201 JUL 1 3 1972 Mr. Lester Rogers, Director Division of Radiological and *, Environmental Protection U. S. Atomic Energy Commission Washington, D. C. 20545

Dear Mr. Rogers:

This is in response to your letter dated April 14, 1972, wherein you requested comments on the draft environmental impact statement for Indian Point No. 2, Consolidated Edison Company. This Department has reviewed the health aspects of the above project as presented in the documents submitted. We offer no comments. The opportunity to review the draft environmental impact statement is appreciated. Sincerely yours, Merlin K. DuVal, M.D. Assistant Secretary for Health and Scientific Affairs 44L

50-247 >~2 United States Department of the Interior'3 --- OFFICE OF THE SECRETARY - .. WASHINGTON, D.C. 20240 JUN 29 1972

Dear Mr. Muntzing:

This is in response to Mr. Rogers' letter of April 14, 1972, requesting our comments on the Atomic Energy Commission's draft statement dated April 13, 1972, on environmental considerations for Indian Point Nuclear Generating Plant, Unit No. 2, Westchester County, New York. General The statement seriously questions, as do we, the validity of some data presented by the applicant. In several places in the statement the AEC staff has disagreed with the computations and conclusions provided by the applicant. It appears that the exact quantification of many of the probable environmental impacts cannot be made at this time. However, the data presented on Indian Point No. 1 (Chapter V) leaves no question that Indian Point No. 1 has a serious environmental effect on aquatic life in the river, especially fish. The statement presents a rather convincing analysis of the probable impacts of Unit No. 2 on aquatic life, especially as a threat to fish. In addition, the statement in Table III-1 and on page 111-7 and at other points recognizes the operation by sometime in 1974 of additional fossil and nuclear generating units, not now operating, on the Hudson River. These include Bowline Nos. 1 and 2, five miles below Indian Point, Roseton Nos. 1 and 2, 22 miles above, and Indian Point No. 3 at the site of Indian Point Nos. 1 and 2. 1 The environmental impacts of these five units are not included in the environmental impact assessments of this statement, although Indian Point No. 3 was apparently included in heat dissipation models by the applicant (page 111-34) and the electric generating capacity of all five is included in the assessments of power supply available. 45

When operational, these five units will increase the daily discharge of heat to the Hudson River between Albany and 59th Street by about 113 percent over discharges when Indian Point No. 2 is operating. Heat discharge will be increased about 260 percent over present discharge levels listed in Table IIl-1, when Indian Point No. 2 and the other five units go into operation. ) The additional 415 billion BTU/day discharge of those five units in a 28-mile reach of river, in addition to the 310 billion to be discharged by Indian Point Nos. 1 and 2 and the Danskammer and Lovett Units, suggests that damages of Indian Point Units 1 and 2 will likely be but a small part of the damages occurring to aquatic resources during the next two to four years. Therefore, the opportunity to evaluate the operation of Indian Point Units 1 and 2 over the next two to four years, and to determine the effects of those operations on the Hudson River conditions considered in the statement is foreclosed by the imminent addition of these five units to the Hudson River. There is no assurance that the effects of any given unit may not be significantly greater when considered simul-taneously with the others. It appears a virtual certainty that significant impacts on the biota can be expected from the operation of Indian Point Nos. 1 and 2 with once-through cooling. These include entrainment of planktonic organisms including egg, larval, and fry stages of important fish, along with zooplankton and phytoplankton. Major losses may continue from impingement of large fish on screen structures. Toxic conditions from use of anti-fouling chemicals appear a certainty, and adverse impacts of huge quantities of heat discharged to the river are predictable as are probable conditions of lower dissolved oxygen levels. Significant impacts are predictable on the fishery resources not only of the Hudson River but also of the New Jersey and Long Island coastlines., It appears necessary to correct the problems of Indian Pdnt Nos. 1 and 2 and prevent additional problems at the other stations if the fishery resources of the Hudson River are to be managed and used for the public good. 2

Despite the extensive efforts undertaken in the past by the applicant to solve the problems of Unit No. 1 and to avoid problems in Unit No. 2, it does not appear that there is yet a basis to conclude that the efforts promise com-plete success short of discontinuation of pumping operations. Nevertheless it seems reasonable to accept the staff's conclusion (page XI-55) that the short-term (2-4 years) operation of Unit No. 2 would not be expected to cause irreversible environmental damage to the aquatic biota. However, the Department of the Interior is acutely aware of the likelihood of significant irreversible damage to the aquatic life should Unit No. 2 be operated as now proposed. The probable loss of fish eggs, larvae, and juveniles due to entrainment, and impingement at the Indian Point facilities in the magnitudes estimated, together with the related loss of faunal and floral plankton forms is unacceptable to this Department on a long-term basis. The AEC proposal given in item S.f page v to postpone a decision on corrective measures until the second year after steady state operation is achieved, suggests that any meaningful action to prevent significant environmental damage would not begin until three or more years from now. Construction time of one to three years could postpone effective preventative actions for up to six years. We consider this unacceptable since the predictable "short-term" damage to aquatic resources is of a sufficient magnitude to justify the best available corrective action now. Further quantification of the damage to the aquatic resources seems irrelevant to the basic objective of preventing the significant damage to these resources. We presume that during the last several years the applicant has made meaningful studies of the alternative cooling systems in order to prepare the alternative section of the environ-mental statement. With these studies as a base, the design of an effective closed cycle cooling system within six months seems reasonable. Construction of the facilities within 12 to 30 months, depending on the system selected, should also be possible under a priority construction program. 3 1,7

Therefore, this Department recommends that the operating license for the Indian Point. No. 2 should contain the following stipulations:

1. Within six months, the applicant shall present to the Atomic Energy Commission completed plans for a closed-cycle cooling system which will eliminate the need to withdraw cooling water from or discharge it into the Hudson River, except for quantities necessary as makeup water and blowdown discharges, respectively, from a closed-cycle cooling system. The plan shall include appropriate measures to minimize the effects of those limited withdrawals and discharges upon aquatic life.

2. The applicant shall construct and place in operation at the earliest possible time, and in no case later than July 1, 1975, the closed-cycle cooling system required in stipulation number 1 above.

3. During the interim period, any operation of Indian Point No. 1 and No. 2 with a once-through cooling system should be held to t12 minimum by drawing on other sources of power available to the applicant's system, and by publicly discouraging all unnecessary uses of electric energy within its service area, consistent with existing authorities.

4. The applicant should be required to adopt and employ all practical measures which may be developed in order to minimize any significant adverse impacts of the plant operation on the biota during the interim period.

5. The environmental study program outlined on page V-59 should be conducted as proposed, except that there should be no decrease in sampling efforts until an appropriate study interval after the closed-cycle cooling system becomes operational.

6. The proposed studies should include constant monitoring of the operations of Indian Point Nos. 1 and 2 in order to determine when s~vere adverse impacts are occurring and, where possible, operation of the plant should be shut down or reduce generation when major fish kills or other serious impacts are occurring at the plant.

4 4 C9

7. The applicant will consult with the Bureau of Sport Fisheries and Wildlife on the development of the above studies as well as any plan which has the purpose of minimizing environmental degradation.

Comments addressing specific topics follow. Land Use The reference to the applicant's Supplement No. 1, which shows the layout of the buildings, park and lake area, should be page 2.3.1-2 instead of 2.21-2 as given on page V-1. Cumulative Impacts The statement pertains primarily to Unit No. 2, with some considerations being given to the cumulative effects of both Units Nos. 1 and 2. Since the construction of Unit No. 3 is about 70 percent complete and is scheduled to be operational in 1973, we believe that AEC would be remiss in meeting its obligation under P.L. 91-190 if the final statement were not expanded to include the effects of Unit No. 3. It further appears that a more detailed discussion of the heat dissipation capacity of the entire Hudson River com-pared to the total heat load imposed by the various heat sources should be included in the statement. It appears that the cumulative thermal loading could appropriately be considered at this time. The New York Department of Environmental Conservation published an article in the New York Fish and Game Journal entitled, "Thermal Load-ing in the Marine District" in the July 1970 issue. This article pointed out the need to understand the ecology of the marine waters and the limits of tolerance of the member organisms in order to assess the environmental effects resulting from the operation of steam electric plants. Impingement on Travelling Screens Fish kills occurring on the travelling screens in the cooling water intake ar6 discussed on page V-30 and V-46; however, the method of disposition of fish, and other accumulations on the screens is not described. The method of disposal of these solid wastes should be described in the final environmental statement. U

Plant Dismantling and Decommissioning The disposition of the site after the end of the useful life of the reactors needs to be clarified. It is stated on pages V-75 and V-76 that the reactor will be entombed with associa-ted highly radioactive components and it is anticipated that this action would have no significant radiological impact on the environment. However, a basis for this conclusion is not given. We suggest that the statement include infor-mation on the anticipated quantities and longevities of the radioactive materials to be buried, the expected integrity of the entombing structures, and data on ground water. The burial of highly radioactive materials on the banks of the Hudson River would be a questionable action, particularly if long-lived radionuclides are involved. Environmental Impact of Postulated Accidents Section VI gives an adequate evaluation of impacts resulting from postulated accidents through Class 8 for airborne emissions. However, the environmental effects of accidental releases to water is lacking. Some of the accidents described in Table VI-I could result in releases to the Hudson River and the effects could last for centuries. As we have stated in comments on previous environmental statements, we do not think that an analysis of only air-borne emissions constitutes a complete evaluation of the possible impacts resulting from a major accident. We also think that Class 9 accidents resulting in both air and water releases should be described and the impact on human life and the remaining environment discussed as long as there is any possibility of occurrence. Alternative Fuels and Sources The statement on page XI-3 refers to recent studies which indicate that coal-fired plants may lead to a radiation dose exposure to the general public similar to or greater than exposures derived from operation of powerplants using pressurized water reactors. We do not believe that there is uncontestable evidence to support this statement. If AEC retains this information in the final environmental 6

statement, we suggest that the radiological impact of Unit No.. 2 should only be compared with modern fossil-fuel steam-electric plants with current emission control equipment. Recreation We believe that assessment of the impacts on recreational water for both primary and secondary contact activities should be expanded. The transfer of 14 acres to the Village of Buchanan to be developed by the Village as a public marina should increase the recreational value of boating; however, little or no mention is made of the effects of other water associated recreational activities. Planned Environmental Studies As we have stated previously, we believe sampling intensity, as mentioned on page V-59, should not be decreased until the effects of Units 1, 2, and 3 have been determined. Entrainment studies should also be continued until such time as definitive informnation has been gathered. These stipulations should be placed in the study plan outlines and included in the study discussions in the statement. We recommend that the operating license require the appli-cant to consult with the Bureau of Sport Fisheries and Wildlife on the development & the detailed plan to mini-mize environmental harm. We also request that this Depart-ment be advised of the plan when completed and review and comment on it in regard to our expertise and jurisdiction. Benefit Description of Alternative Plant Designs The benefits claimed on page XI-57 from research, local taxes and employment should be separated from other benefits in this table. The AEC's "Guide for Submission of Infor-mation on Costs and Benefits," dated May 1972, correctly distinguishes between these items and the generation of electricity and the production of other products. We also concur with the statement on page 4 of that report "that the calculation of indirect benefits is a complex and controversial matter, frequently involving a large number of assumptions." As further pointed out, the claiming of such benefits could result in multiple accounting. It appears that this statement has shown benefits for the 7 51

additional local taxes and employment without indicating that there would also be attendant increases in taxes paid by local and regional customers and that there would also be some increase in local services for the approxi-mately 400 people expected to work at the plant. Although significant benefits may be realized by the local community, these funds are ultimately paid by the local community and the other customers of the applicant, there-fore, from a regional viewpoint taxes are essentially a transfer of funds and should not be indicated as benefits. We appreciate this opportunity to comment on the statement. We hope these comments will be useful to you in the prepara-tion of the final environmental statement. Sicrly ours Deputy Ass stant Secretary of the In erior Mr. L. Manning Muntzing Director of Regulation U. S. Atomic Energy Commission Washington, D. C. 20545 8 52

DEPARTMENT OF TRANSPORTATION MAILING ADDRESS: U.S. COAST GUARD(S UNITED STATES COAST GUARD 40 SEVETSTREE SW) WASHINGTON. D.C. 20590 PHONE: 202-426-2262 50-247

                                                             '2 5 MAY 1972 Mr. Lester Rogers, Director Division of Radiological and Environmental Protection U. S. Atomic Energy Commission Washington, D. C. 20545

Dear Mr. Rogers:

This is in response to your letter of 14 April 1972 addressed to Mr. Herbert F. DeSimone, Assistant Secretary for Environment and Urban Systems, concerning the revised draft statement, environmental report and other pertinent papers on the Indian Point Unit No. 2 Nuclear Generating Plant, Westchester County, New York. The concerned operating administrations and staff of the Department of Transportation have reviewed the material submitted and we have no com-ments to offer. It is our determination that the impact of this project upon transportation is minimal and we have no objections to the project. This Department previously reviewed this project as indicated' in our letter dated 25 January 1971 to Mr. Harold L. Price of the Atomic Energy Commission. The opportunity to review and comment on the Indian Point Unit No. 2 Nuclear Generating Plant is appreciated. Sincerely,

                                                     ....iL _:

53

NEW YORK STATE HISTORIC TRUST Parks & Recreation 9 State Campus

• Albany, N.Y. 12226 e 518 457-4194

   *   ..j  Louis C. Jones Chairman V'   Conrad L. Wirth Vice-Chairman                                                                  "    ' -         ,   ,

t* Ewald B. Nyquist .. ,. - Seymour H. Knox John H. G. Pell n ,." VV'" Laurance S. Rockefeller I '"4 7 , . ._ Mildred F. Taylor . C. Mark Lawton P,' May 12, 1972 Mr. Lester Rogers, Director Division of Radiological and Environmental Protection U. S. Atomic Energy Commission Washington, D. C. 205215 Docket No. 50-247 (Indian Point #2, N. Y.)

Dear Mr. Rogers:

The New York State Historic Trust has carefully examined the environmental statement prepared for this project. I am pleased to reply on behalf of the State Liaison Officer for Historic Preservation, the Chairman of the New York State Historic Trust. In general, the New York State Historic Trust agrees with the Historical Imp8t Statement on Page V-2 of the Draft Statement on the Environmental Considerations and the sites mentioned in the Appendix at 2.1.3-2. However, the New York State Historic Trust regrets the already unsatisfactory visual impact of the Indian Point Construction on the historic environment of the Stony Point Battlefield and of the Palisades Interstate Park, both of which are Registered National Historic Landmarks. The New York State Historic Trust further hopes there will be no additional damaging effects in those sur-roundings. I hope this information will be useful. Very truly yours, Mark Lawton:> Director ML:WGT:ve 5P ." State of New York

• Nelson A. Rockefeller. Governor
• Parks & Recreation
• Alexander Aldrich, Commissioner

               ..A        ,-.STATE            OF NEW YORK DEPARTMENT OF ENVIRONMENTAL CONSERVATION               "

RONALD W. PEDERSEN ALBANY FIRST DEPUTY COMMISSIONER' 50-2447 June 1, 1972

Dear Sir:

The State of New York has completed its review of the "Draft Detailed Statement on the Environmental Considerations Related to the Proposed Issuance of an Operating License to the Consolidated Edison Company of New York for the Indian Point Unit No. 2 Nuclear Generating Plant" Docket No. 50-247, by the U. S. Atomic Energy Commission, Division of Radio-logical and Environmental Protection, Issued April 13, 1972. In preparing the attached comments, we have taken info consideration the views of all appropriate State agencie's including the New York State Atomic Energy Council. Many of the comments are quite detailed and directed to very specific points in the statement with the aim of clarifying and improving the final statement. The statement is commendable in that it has identified the environmental impacts and adverse effects of the operation of Unit No. 2. It does not, however, fully discuss the relation-ship of Indian Point with respect to the cumulative and synergistic effect of its operation and that of. a number of other power plants in a relatively short section of the Hudson River. It is also important to note that a number of observations in the statement are based upon operation of Unit No. 2 beginning in the summer of 1972. However, because of various delays, earliest operation would be beyond the summer 1972 peak demand period. 55

The attached comments are illustrative of our concerns and we request that they be given your utmost consideration. Thank you for the opportunity to review and comngent upon this document. Sincerely,

                              .C     . I United States Atomic Energy Commission Washington D. C. 20545 Attention: Director, Division of Radiological and Environmental Protection Enclosure 56

STATE OF NEW YORK

                          - COMMENTS    -

on the "Draft Detailed Statement on the Environmental Considerations Related to the Proposed Issuance of an Operating License to the Consolidated Edison ii Company of New York for the Indian Point Unit No. 2 Nuclear Generating Plant" Docket No. 50-247 by the United States Atomic Energy.Commission, Division of Radiological and Environmental Protection Issued: Aptil 13, 1972

1. General Comment. - On the thirty mile stretch of the Hudson River extending north and south from Indian Point there are ten power generating stations either operating, under construction or planned for the future. Those presently operating include Indian Point No. 1, Lovett and Danskammer. Five stations are under construction at the present time and these include Indian Point Nos. 2 and 3, Bowline 1 and 2 and Roseton. Two additional plants have been proposed by Con Edison known as Verplank 1 and 2. At least six of these stations will be located within a one and one-half mile section of the River (Indian Point 1, 2, and 3, Lovett and Verplank 1 and 2). Although it is recognized that all of those plants are not the subject of the environmental statement under consideration, it is quite difficult to obtain a valid appraisal of Indian Point No. 2 without the 57

                                    -2   -

recognition of the cumulative and synergistic effect of the operation of possibly ten plants in such a short section of the river.

2. Page i-3. - While the applicants' declared intent to develop a portion of the property for recreational and educational purposes and the grant of 14 acres of property to the municipality for the development of a marine facility at Lent's Cove is commendable, the project does detract from the view of the shoreline and upland area as seen from the river. This fact should be indicated.

3. Page i-3.c. - In connection with the area used in trans-mission line rights-of way, there is a statement that the trans-mission towers were architecturally designed in accordance with State and Federal guidelines. There is no State guideline on the architectural design of transmission towers. The type of tower most appropriate for use will vary with topography, vegetative cover, background and exposure of the right-of-way. For purposes of minimizing aesthetic insults there is no "best" design. The Statement should describe the design contemplated and discuss the visual impact expected.

4. Page ii, 3.f., 111-6 thru III-39,XI-l-2.-The AEC states that "The conclusions reached by the applicantin regard to the thermal discharges from Units Nos. 1 and 2 in meeting the New York State thermal criteria throughout the entire year have not been adequately demonstrated by the applicant, especially since the submerged jet depth is being changed from 18 feet to 12 feet below mean water level." It is assumed that the AEC will pursue this question further with the applicant prior to approval of an operating license. While there may be questions about the actual dispersion patterns, the model studies, calculations, and field studies 58

represent a reasonable effort at appraising likely river conditions. Further modifications, if needed, may be required by the State. Since the New York. State Department of Environmental Conservation has stated that there is reasonable assurance the criteria will be met and has adequate follow-up procedures following issuance of the permit, the U.S.A.E.C. assertion on p. ii, 3.f. is questionable. The AEC review of the mathematical and model predictions by the u ility (p. 111-6 thru 111-39) questions the adequacy of the data available and the resulting conclusions drawn by them and likewise by the N.Y.S. Dept. of Environmental Conservation (since the State has issued a construction permit and has given a certificate of reasonable assurance). However, the USAEC comment is based on an evaluation assuming the discharge from all three units operating and not just Units #1 and #2 (p. 111-39). There is no doubt that there are serious concerns already identified by the N.Y.S. -D.E.C. in regard to the ability of the approved diffuser facilities to adequately satisfy thermal criteria with all three units operating.

5. Page ii-3.j and p. V-53 - AEC estimates that "the total yearly recruitment loss for each subsequent year loss in the (striped bass) population may be as high as 15-20% from direct effects of 59

plant operation". Their analysis is based in part on the prediction that 25% or more of the fish eggs and larvae passing the plant will be entrained and lost. This prediction is only meaningful in terms of the proportion of the total number of eggs and larvae produced annually in the Hudson River which actually do pass by the plant. AEC assumes that a large proportion of the annual production will pass the plant. Insufficient documentation is provided in the statement to validate the use of this assumption.

6. Page iii-3.n - This paragraph states that the operation of Unit No. 2 will permit the applicant to shut down or reduce the use of "older coal-burning plants." The last unit in the Consolidated Edison system using coal was at the Arthur Kill Plant. This unit was shut down by conversion to oil on February 25, 1972. Therefore the phase "older coal burning plants" should be changed to "older oil burning plants" since there are no longer any coal fired plants

   -in the Con Edison system.

7. Page iv-5.c. - The AEC conclusion that the benefits of meeting an urgent short term need for power in New York City outweighs the

   ,corresponding environmental costs is      only justified to the extent that there will be no irreparable and irreversible effects on the environment.

8. Page iv-5.d. - The name of the agency (s) to whom "the comprehensive

  .program" should be acceptable should be identified.

9. Page v-5-f. - It is felt that the Commission should discuss any proposed action to be imposed on the applicant to minimize environmental GO

impact with the State before such actions are actually imposed.

10. Pages 1-3 thru 1-8. - Comments on*Permits Issued - The first permit issued to the Con Edison Company was dated August 22, 1966 and applied to the construction of an outfall and the discharge of cooling water resulting from the operation of Unit #1 only. This permit expired five (5) years later on August 22, 1971. Therefore, it is no longer in effect. A construction permit was issued on May.19, 1970 with the understanding that the effluent channel and diffuser, although hydraulically capable of discharging ihe cooling water from all three (3) units, would only be approved for the eventual discharge of Unit #1 until sufficient ecological and temperature studies could prove adequacy for Units #2 and #3. A modified construction permit was issued on December 10, 1970 for the same basic structure. However, our concerns for not allowing the discharge of Unit #2 were alleviated after having received additional information regarding the proposed discharges from Units #1 and #2. The proposed relocation of the intake structures by Con Edison was a significant improvement and entered into this decision. The USAEC is urged to require Consolidated Edison to establish a firm schedule for implementing this proposed modification.

A third modified construction p~rmit was issued on November 4, 1971 because of changes in the design of the adjustable discharge ports and slide gates. The permit conditions were otherwise the same as for the previous permit. Recent inspections indicate that the structure is nearly complete with approximately half of the slide gates installed. The company has been informed that an operation permit to discharge the cooling water et om Units #1 and #2 through

the discharge structure will be withheld until all construction called for in the construction permit issued November 4, 1971 is comiplete and in accordance with the approved plans. Therefore, no permit has been issued nor is one in effect to discharge through the diffuser structure. The permits listed through the Introduction in the report are accurate except that the November 4, 1971 construction permit is not listed. The permits listed under Chemical Discharges on page 1-6 are incidental to the project. One was for the disposal of domestic sewage (6-10-59), while the other two (11-13-70 and 2-10-71) were for the release of cleaning solutions from pipe cleaning operations and were only temporary in nature. They are no longer in effect since the cleaning operations have ceased.

11. Page 1 The last sentence of the first full paragraph provides a list of the organizational members on the Fish Advisory Board.

This list should be modified to indicate that there is a non-voting member from the New York State Department of Public Service.

12. Page II-I - The importance of the estuarine nature of the Hudson

_River, which is described in paragraph 3 is that the upward extent of salt water varies strongly with the input of fresh water into the river and that it may actually be nearly fresh near the river mouth after a heavy rain. This is a misleading statement since this effect can only occur after protracted high flows of fresh water and in most circumstances can only occur during high flows 62

                                     -7  -

that are characteristic of the spring runoff.

13. Page 11 Statements in regard to the geology of the site appear to be little more than a review of the content of the Preliminary Safety Analysis Report rather than a critique of the possible environmental dangers which might be possible, because of the geological circumstances present there. The terminology used, such as:

         "...no truly major faults on or near the site."
         "...no danger of a destructive earthquake."

are not sufficiently precise statements. The following statements are suggested as alternatives to those quoted above:

a. No faults are known to exist on the proposed site. A major fault has been mapped extending into the Hudson River from the eastern shore in a line approximately 3000 feet northwest of the site. This fault extends over twenty miles to the northeast of the site and may join faults west of the River which extend into New Jersey to the southwest. One of these faults to the southwest, the Ramapo Fault, separates rocks of Precambrian age (over 800 million years old) from Triassic age (approximately 200 million years old) rocks and represents considerable displacement. On the east side of the river within three miles both north and south of the site are several faults with at least several hundred feet of mappable offset.

b. As presented in the Preliminary Safety Analysis Report, a Modified Mecalli intensity of VI is considered possible in the area on the basis of study of the seismic history of the region.

Using the criteria tentatively proposed by the U. S. Atomic Energy Commission for siting of nuclear power plants in 10 CFR, Part 100, Appendix A, it may be necessary-in the future to determine which faults in the area are "active"; active meaning one movement within the last 35,000 years or more than one movement within the last 500,000 years. There is seismic activity in southeastern New York, adjacent Connecticut and New Jersey. Only one focal mechanism has been worked out which shows possible correlation to a known fault. This fault is a Triassic basin border fault in New Jersey. Thus, for further power plant siting an investigation involving a seismic monitoring program with analyses of focal mechanisms to determine whether the motions observed c~orre~la~te.both geographically and geometrically with known faults. If faults are found which appear to be related to seismic activity, they will have to be mapped in detail. Such a mapping program could involve the entire south-eastern portion of New York and adjacent Connecticut and New Jersey.

                                                         -It can be anticipated that this kind of study will be required for future site investigations and that more detailed geologic mapping will be required.

The original reports by T. W. Fluhr, P.E., and S. Paige, besides their own field work, rely on quoted geologic information no younger than 1936 and mostly as old as 1919 and 1901. With the decision to build still another plant near this site, environmental statements should include detailed geologic investigations of the entire region be synthesized and analyzed and new investigations be undertaken to fill in the gaps in existing data. The geologic reports by T. W. Fluhr, P.E., and S. Paige are not sufficient for basing decisions on future power plant siting in the region around Indian Point.

14. Page 11 The discussion of surface water including tidal effects is important but it doesn't give proper recognition to the efforts to regulate flow by the use of headwater reservoirs. It should be noted that reference 9 includes a discussion that states in part "controlled releases ... are designed to keep the minimum flow of the Hudson River downstream from Hadley at the highest possible level, generally about 3,000 cfs ..... " (page 7 of Reference 9).

Green Island and Rensselaer do not draw any of their water from the Hudson River any longer and probably will not in the future except for emergency purposes.

15. Page II The first full paragraph contains a statement that peak tidal flow is more than 30 times the input of fresh water. While true, it is probably even more important that the peak tidal flow is about 100 times the fresh water flow at which the river is generally regulated.

16. Page 11-19 - The first full paragraph dealing with "Special Ecological Considerations" implies that the Hudson is a major spawning area for striped bass that live in Long Island Sound and the Atlantic Ocean near New York. The importance- of the Hudson River as a fishery in and of itself is quite well known, but the implication that this is

   *amajor striped bass spawning area for areas other than the western end of Long island Sound is    questionable.

17. Page 111 The last two sentences of the first paragraph in section E.l.a. indicates that once-through cooling systems are the simplest and most economical means for cooling. It should also be noted that, with the exception of dry-cooling towers, not in general use, these systems cause less evaporation and generally consume less water during their operation. They also avoid the physical intrusion of towers and they add less visible vapor to the air in the vicinity of a thermal plant.

18. Page 111 The status-of Technical-Bulletin No. 36, "Thermal Aspects of Discharges on Water Resources," has been the subject of much discussion. After New York filed Bulletin No. 36 with the Interior J

Department, that.Department approved New York State standards. When the State formally adopted thermal criteria essentially as previously transmitted to the Department.,of the Interior, EPA raised questions and has not approved or disapproved them.

19. Page III-11 -. !'Recommended-revisions"'should have no place in an evaluation of requirements forapproval under existing regulations.

Adoption is highly speculative. If new criteria are subsequently adopted, their applicability to, and effect on, the facility would C

have to be evaluated at that time.

20. Page 111 The first paragraph mentions a control weir in the discharge canal to control jet velocity. This is incorrect, as velocity can only be controlled by port opening adjustment, which controls head on the open ports. Further., the head requirements on the circulating water pumps were partially determined by the water elevation in the discharge canal. The weir could only function as a relief to avoid excess head and backpressure.

21. Page 111 The first paragraph contains an expressed concern for raising the port depth from '18 to 12 feet in terms of meeting a 90°F maximum surface temperature restriction. This assumption fails to recognize, for the 12 foot depth, jet development by bottom entrainment that was restrained by the river bed at the 18 foot depth, and verification by hydraulic model studies of better initial dispersion and lower maximum surface temperatures than shown by the same model with an 18 foot port depth. It is believed this concern is not warranted and the maximum surface temperature criterion will be satisfied.

22. Page 111-35 -- The third paragraph discusses maximum river ambient temperatures and indicates that a maximum river temperature of 81°F has been observed opposite Indian Point in August. The company's analysis takes into account some recirculation. It is necessary to clarify whether the 81OF temperature was a local surface temperature or is average and representative as background ambient across the river. Since these observations were made when Indian Point No. 1 was running, it is expected that slack tide periods 67

would show slight temperature elevations off shore from the plant. Effects of Unit I are accounted for in the combined analysis for I and 2 together, and should not be superimposed on the combined analysis. To suggest adding 20 F to the analyses for heat dissipation presumes such a temperature w6uld be uniformly present throughout the cross-section to the depth from which water is withdrawn. This is rejected as without foundation.

23. Pages 111-35 In the first paragraph on the submerged discharge math model, there is a discussion of the zone of flow establishment, and an assertion of improper approach. The development of the coefficient for the length of the zone of flow establishment was also based on undistorted hydraulic model studies. Since the length is a constant times width, there seems to be no basis for stating the constant in error, but rather that a different equivalence parameter might have been used to establish the zone distance. It does not appear, as correlated in hydraulic model studies, that this would appreciably change the final length.

24. Page 111-36 - The first full paragraph suggests that maximum surface temperatures are not properly evaluated. While the assumptions of distribution in an assumed equivalent plume may not be verifiable, the undistorted hydraulic model gives data for maximum temperature at any point on the surface, and demonstrates ability to meet the maximum surface temperature criterion.

25. Page 111 The second complete paragraph deals with the question of interference between jets. While important, it must be recognized

that the nature of these jets is such that most dilution will come from top and bottom, and lateral interference between jets is of less significance. The applicants selected operating mode of alternate ports, with edge to edge spacing of 25 feet, should obviate further discussion of a possible inappropriate equivalence analysis and assumed vs. actual port spacing of 11.25 and 5 feet respectively. Further, if the statement analysis were carried on to no lateral port spacing (a slot), the conclusion seeming to be drawn would be no dilution.. This is incorrect; a slot can function as an effective diffuser. The correct conclusion is that considerable additional dilution will occur after jet interference. The primary reliance must be placed on undistorted hydraulic model studies and field verification. The company has acknowledged that extensive field evaluations and verification are required and will be conducted. There is sufficient flexibility in the diffuser designed for three units to operate various port groupings to determine port inter-relationships and dilution effects.

26. Page 111-36 - The final sentence of the second full paragraph,.

indicating that the jet interference temperature and the surface temperature are synonymous must be refuted. The 81°F temperature, as discussed above, is also rejected as being.a temperature which could occur across the entire intake. Significant dilution, as also discussed above, will occur after jet interference. The compounding of two assumptions in error to indicate surface temperature criteria violation must be questioned. The average intake temperature 69

will not reach 81°F, nor will the maximum surface temperature at 0 the discharge be elevated 12.4 F, as stated. With primary reliance on the undistorted hydraulic model studies, it must be reiterated that the 90°F surface criterion-will be satisfied.

27. Page 111 In the first paragraph, questions are raised about operation of the jets. The diffuser design, to allow the restriction

   *or closing of some port openings allows a design jet velocity prior to unit three operation, and also at any combination of operating units and circulating water flows.       With this flexibility, there should be no cause for concern.       The applicant has initially selected alternate ports for operation, but it will be desirable to investigate other combinations. The applicant will be restricted by state discharge permit condition to maintain design velocity at all times during plant operation.

28. Page III.'.. .The second paragraph discusses factors which, it is presumed, invalidate the applicant's review analysis. While the mathematical models do not take the port elevation shift into account, the hydraulic model studies do. The 12 foot discharge configuration has been modeled, with results of a lower maximum surface temperature and a better isothermal pattern than the original 18 foot depth. The primary reason is removal of the interference of bottom impingement by the plume, overcoming drag, and better entrainment under the jets. The jet would not now interdict the bottom, and this should be considered in evaluating ability of free swimming fish to move under the discharge and along' the bottom in the vicinity of the discharge.

70

The question of increased temperature is correctly stated, in terms of less flow and higher temperatures. However, this should not be equated to maximum surface temperature criteria violation, as this mode of operation has been selected for winter use when ambient temperatures are very low.

29. Page 111 The discussion of near and far field dissipation mathematical models indicates the need for field verification of model correction factors over a broader range of conditions and temperatures than possible with Indian Point No. i alone. It will only be possible to verify at higher flows and heat discharge when Indian Point No. 2 is on line.

The mathematical models are a reasonable approach to describe the phenomena associated with heat discharge and dissipation. They require refinement, and must be correlated'to hydraulic model studies and actual field verification. From the data available, and analyses and studies done, it can. be concluded with assurance that the Indian Point No. 1 and 2 discharges can be accommodated in the Hudson River within constraints of adopted thermal regulations and water quality requirements. Both mathematical and hydraulic model studies will be reworked as field data is available. The mathematical model assumptions will be re-evaluated in light of operating experience to move to a more confident basis to predict effects of adding Unit No. 3.

30. Page 111 The discussion under cross-section temperature distri-bution model again, as for the dissipation model, criticizes extrapolation outside of confidence limits, of limited data. While 71

not desirable, use of available data must be made to check theoretical assumptions. As noted above, continued refinement of models will be made as new data is available, but the ability of Unit No. 1 and 2 discharges to meet criteria can be accepted at this time. The hydraulic model studies give balance to the mathematical approach,. and have been conducted over a wide range of operating conditions to observe changes. Extensive verification tests will be conducted.

31. Page III--The paragraph on net-nontidal flow recognizes the phenomena, and its usefulness in describing mixing and dilution aspects not accounted for in other ways. HoVever, it is believed, in light of the admitted lack of definitive data to quantify the phenomena, that conclusions should not be drawn on which segments of the flow region participate, and to what extent. Its beneficial effect should be recognized, with qualification and quantification left to field verification studies.

NOTE: While the comments in Nos. 18 through 31 were generated primarily in response to the section on heat in the statement, IIIE.,I., pages 111-6 to 111-39, they should be used throughout the entire statement where questions of thermal discharge arise. ..

32. Page 111 The total calculated liquid release other than H-3 from Units 1 and 2 of 81 Ci will be reduced to 8 Ci when all plant modifications are complete. These modifications are listed in Con Edison's Environmental Report Supplement on page 2.3.7-9 as being the following:

a) modify reciprocating charging pumps and return leakage to C.V.C.S. 7 27

b) modify pressurizer spray values. c) modify waste disposal evaporators. d) install a polishing demineralizer/filter for waste evaporator condensate. e) intertie between Units 1 and 2 steam generator blow-down purification system. There is no schedule given for the completion of these modifications. After all plant modifications are effective, the estimated liquid releases other than H-3 would still exceed the guide of 5 Ci per year given in 10 CFR 50 Appendix I. A statement regarding these modifications should be included, and schedules discussed, as fully as possible. This is particularly important in regard to the steam generator blow-down purificator system as 85% of the anticipated annual release of radio activity from Unit #2 originates from this system and by-passes the existing radwaste system.

33. Page 111-46-47 - The report considers the environmental impact of Units 1 and 2 operating simultaneously. On page 111-46 the calculated radiological releases from Unit I are listed amounting to 40 Ci. On page 111-47 the past actual releases are listed and they are close to this level. However, this table omits available data for the last half of 1970 and all of 1971 which should be included. During 1971 the releases reported by Con Edison amounted to 78.5 Ci due mainly to the waste evaporative system being inoperative.

73

34. Page 111 The statement is made that AEC estimates of 1-131 releases to the atmosphere are 0.64 Ci, which exceeds the Technical Specifications limit of 0.18 Ci/year. The plant modification listed in the Supplement calls for a -charcoal filter in the plant vent but no schedule is given when this will be complete. If the iodine release the AEC is referring to originates from volatile iodine in the steam generator blow-down system there is some question about this by-passing the plant vent. This point should be clarified.

Estimated releases after. the. charcoal filter is installed and the scheduling for installation of the filter should be discussed.

35. Page 111 Consideration of the environmental effects of the emission of fossil-fuel contaminants is not adequately covered.

In Section III, E 4, it is correctly shown that the plant complies with the applicable emission standards. However, in Section V, C or Section VII, B 2, it is not sufficient to state only that the operation of the plant, would not greatly increase the level of nonradioactive air pollutants in the area. On the basis of results of diffusion analyses conducted by the Utility for the Fossil-fuel contaminants, the expected contributions by Units 1 and 2 to the pollutant levels can be stated and compliance with the applicable air quality standards can be shown. This should be done. 36,. age V-4 -- The end of the first paragraph discusses the need to carefully evaluate the discharges from Units 1 and 2 so that the facilities needed at other or new plants can be evaluated. This is a reminder that observations of plant operation would be essential to an accurate appraisal of what Unit 3 is likely to do to river 7.4

34. Page 111 The statement is made that AEC estimates of 1-131 releases to the atmosphere are 0.64 Ci, which exceeds the Technical Specifications limit of 0.18 Ci/year. The plant modification listed in the Supplement calls for a -charcoal filter, in the plant vent but no schedule is given when this will be complete.* If the iodine release the AEC is referring to originates from volatile iodine in the steam generator blow-down system there is some question about this by-passing the plant vent. This point should be clarified.

Estimated releases after the, charcoal :filter is installed and the scheduling for installation of £he filter should be discussed.

35. Page 111 Consideration of the environmental effects of the "mission of fossil-fuel contaminants is not adequately covered.

In Section III, E 4, it is correctly shown that the plant complies with the applicable emission standards. However, in Section V, C or Section VII, B 2, it is not sufficient to state only that the operation of the plant would not greatly increase the level of nonradioactive air pollutants in the area. On the basis of results of diffusion analyses conducted by the Utility for the Fossil-fuel contaminants, the expected contributions by Units 1 and 2 to the pollutant levels can be stated and compliance with the applicable air quality standards can be shown. This should be done. 36.. -Page-V.-4 -- The..end of the first paragraph discusses the need to carefully evaluate the discharges from Units 1 and 2 so that the facilities needed at other or new plants can be evaluated. This. is a reminder that observations of plant operation would be essential to an accurate appraisal of what Unit 3 is likely to do to river 75

temperatures. The criticism of the limited background sampling gives even more weight to permitting observations of the effects of Units 1 and 2 while there ib still a chance to use the observations to modify Indian Point 3 before it is ready to come on line. The applicant is alreAdy required to monitor all discharges. The important question now is the frequency and location of sampling to assure that they will represent the mixing of the plant discharge with the river water.

37. Page V The second paragraph indicates that the applicant's studies can be expected to answer some of the ecological questions raised by operation of Indian Point I and 2 but that other studies should be undertaken and that these needed studies are discussed in Part D-4 (Page V-60). However, review of the "Needed Information" outlined under Part D-4 does not clearly reveal who will carry out the needed studies. A similar problem exists on Page IX-4, Part F, where reference is made to a proposed radiological and non-radiological surveillance program. A clear proposal as to what additional information should be collected, and by whom, should be presented.

In addition, the discussion on Page XI-55 of technical specifications to be provided with the operating license does not specify the ecological monitoring surveillance program and-necessary administrative controls recommended to assure that adequate data will be collected to assess the biological impact of the operation of this facility. Again the question arises as to what additional information should be obtained to assure an adequate appraisal, and what further 71

administrative control should be imposed to enforce the program? The environmental monitoring activities are now being carried out through contract studies evaluated by the State and Federal fisheries agencies. If these programs are to be effective, they must be clarified and coordinated with the on-going studies under the Federal and State agencies.

38. Page V The third paragraph indicates that "large numbers of fish may be killed through impingement on the screens that protect the condensers." The expected losses should be further quantified by reference to past and current operating experience.

39. Page V-lI - Chlorine discharge problems discussed in paragraph 2 merit very serious consideration. Mechanisms for controlling biological growth in the condenser while keeping the chlorine discharge concen-tration as low as possible would be highly desirable. Chlorinating when the condenser flow is reduced and on half a condenser section at a time would appear to be a desirable practice.. By keeping the quantity of chlorine discharged to the river as small as possible, sensitive forms would be subject to chlorine for a short period until current and wind action reduced levels below thresholds for entrained non-mobile species.

77

40. Page V-17.- In connection with the observation made in the fourth paragraph, it would appear that survival in the zone of thermal resistance would become shorter rather than longer as the temperature appraoches the lethal temperature.

41. Page V-36 and 37 - The table V-3 on pages V-36 and V-37 of the report appears to contain a number of errors, particularly the totai dose to invertebrates. The concentration values in this table were obtained by dividing the estimated releases by the total yearly flow in the discharge canal. Calculations of the average yearly concentration result in about 25 pCi/l. This will be reduced when plant modifications are complete. The data in table V-3 should be corrected and refined.

42. Page V The first complete paragraph discusses the possible effects of the destruction of large number of Neomysis on the food chain.

While Neomysis may be killed by passage through the plant, they may still serve to feed other fish that frequent the discharge plume; therefore they may still contribute to the food chain. Consideration of this item should also be included in the AEC statement.

43. Page V-54 - The first two paragraphs discuss factors associated with the movement of larvae through the area where they are susceptible to withdrawal by the Indian Point intake. If some of the larvae move through the area at a higher than average rate as a result of longitudinal dispersion, it would seem logical that others would be held in the area longer resulting in no net change in exposure to withdrawal for the entire populatio78

44. Page V-54 -. The third paragraph discusses the vertical migration of larvae. A review of the Hudson River Fisheries Investigation's report indicates that the larvae are definitely more concentrated near the bottom during the daytime as indicated in the impact report.

A more appropriate interpretation of nighttime conditions, however, appears to be that the larvae are uniformly distributed rather than concentrated toward the top. The statement in the Impact Report is therefore questionable. If the shift were from the bottom during the day to the top at night then the average movement through the Indian Point area would be approximately as though the larvae were unifromly distributed. Since the larvae are uniformly distributed at night however, then a portion will continue to be carried upstream and the average number of exposures of the population would appear to be still greater than estimated by U.S.A.E.C. The concentration of larvae subject to withdrawl by virtue of being in the surface waters would be halved, however, since the larvae will be distributed through the cross section rather than concentrated in the surface waters.

45. Page V The third paragraph should clarify in its reference to page VII-8 whether it is referring to the 5 mrem/yr site boundary dose or the 5 curies per year and 20 pCi/liter limit as meeting the IOCFR50 requirements for "as low as practicable."

46. Page VII If the sixth of the factors listed as important is believed to be a result of plant operation then the introductory

   .words should be changed to read "Reduction of dissolved oxygen . . .

73

47. Page VII The section relating to "Air Use" should be changed.

Bringing Indian Point Unit No. 2 on line would probably not result in the immediate retirement of existing fossil-fired plants since reserve capacity will still be marginal. On the other hand the availability of a base load nuclear power 'plant should permit reduced operation of these plants and in the long run the addition of Indian Point Unit No. 2 will contribute to the total capacity needed to meet increased demands and to eventually replace the older fossil fired plants that should have been retired some time ago.

48. Page VII The section on heat dissipation contains an evaluation of expected temperatures based on condenser flow and service water additions. Evaluation of the numerical values given indicates that the mean temperature would be 25 0 F. (considering condenser flow only) 0 rather than 32.5 F. Although the near field mixing requirements are greater with reduced condenser flow, the far field heat dissipation requirements will remain the same. Since the initial water temperature will be lower when reduced condenser flows will be applied, it should be expected that the 90 0 F. limit can readily be met. The 40 F. rise limit will then be the controlling requirement. Consolidated Edison Company has acknowledged that further field observations are needed.

The effects of port elevation changes have been discussed previously in comments on thedsubmerged discharge model (p. 111-37 para. 2). These comments apply here also.

49. Page VIII,-l - The third paragraph should be expanded to deal explicitly with the question of whether it should be necessary to meet all of the electrical demands of customers. Certainly the basic needs mentioned 80

in the' report should be met but a careful examination should also be made of the necessity of meeting all other use demands, especially at all times and at low cost.

50. Page VIII-2 - The first paragraph should be expanded to note that while Indian Point 2 would significanly contribute to Consolidated Edison's nominal reserve margins, it is of perhaps even more importance that it would be expected to have greater reliability than many of the older units counted in the reserve, thus further contributing to the ability of the system to meet peak demands.

51. Page VIII The section dealing with "Water Usage" note that use of Hudson River water for cooling Indian Point 2 would limit or preclude its use for cooling for other purposes. The statement should also indicate that an immediate use for cooling may have a greater social value than an uncertain future use and an expanded discussion of this should be included.

52. Page VIII In the third paragraph, "the ultimate impact on the fishery was not evaluated because the effect of Indian Point is still problematical." The contribution of the Hudson to the commercial and sports fisheries is basic to a determination of the potential overall costs to society. Furthermore, the purpose of the Statement is to describe and project, to the fullest extent possible, the ultimate effect on the fishery.

53. Table X This table should be modified to reflect the latest load and capacity estimates made by Consolidated Edison and the New York Power Pool. It has been retyped to permit the comparison of the new data, which is underlined, and the original data, which has been placed in parentheses. Certain items, which have been difficult to verify either as to the basis for their use or their accuracy, 81

have been marked. The Consolidated Edison Company capacity estimates for 1972 include the output of Bowline No. 1 (600 MW(e)), 348 MW (e) of barge-mounted gas turbines, and 270 1W (e) of firm power to be purchased from Rochester Gas and Electric. On this basis the estimated reserves without Indian Point No. 2 are 1,921 MW (e) or 22.9%. However, delays in completion of Bowline No. 1 and the barge-mounted gas turbines and the occurrence of peak loads between June 15 and July 15 would reduce these estimated reserves to 503 MW(e) or 11.5% of peak load, which is below the desired reserve margin of 20%. In addition, Consolidated Edison, due to delays in development of new facilities has been forced to maintain on line a large number of old generating plants that would normally have been retired, and as a result an average of 2,350 MW(e) (See footnote 2. Table X-1). of generating equipment is expected to be unavailable for the coming summer. It should be noted that this is approximately 429 MW(e) more than the C estimated reserve capacity 1,921 MW(e). If, in addition, Bowline No. 1 is delayed, Consolidated Edison Company could incur a generating capacity deficit of 1,029 MW(e) on any given day. Actually, the amount of unavailable capacity could be much greater. Consolidated Edsion estimates that for this summer equipment unavailability could range between 1,450 MW(e) and 3,250 MW(e) on __any given day. The revised table also explores the effect of having Indian Point No. 2 available at half and full power. In light of recent developments, it appears that the earliest date for commercial operation of Indian Point No. 2 would be beyond the summer 1972 peak demand period. 82

                                                          - 26 T TIL13LE X-1   F'ORECAS'TmD      1972 SMý!ER PEAK SITUATION Consolidated                  New York Edison Company               Power Pool Conditions Without Indian Point Unl:        No. 2 Net Dependable Capability - MW(e)                                      * (9,448)1/       10,321        (24,026)      23,727 Net Peak Load -                                                          (8,550)         8,400        (20,040)      19, 510 Reserve Margin - -.       W (e)                                             (898)        1,921          (3,986)       3 197.

7 Reserve Marcin - Percent of Peak Load (10.5) 22.9 (19.6) Reserve Deficiency - ,fd(e) (812) (22) 185 Conditiors W'ith Indjan Poinz Unit No. 2 (436 M.;(e))* Net Dependable Capability - r5l(e) (9, 884)1/ 10,757 (24,462) 24,163 NetPeak Load - %..*I(e) (8,550) 8,400 (20,040) 19,510 Reserve Margin - :':W(e) (1,334) 2,357 (4,422) 21.53Ž (15.6) 28.0 (22.1) 21.3 Reserve Margin - Percent of Peak Load Needed Reserve Margin Based on Criteria of 20 Percent of Peak Load - MW(e) (1,710) (4,008) Indian Point Unit No. 2 (436 .W(e)) "4/ Capability as Percent of Needed Reserves (25.5) (10.9) 4/ Reserve Deficiency - KW(e) (376) Indian Point Unit No. 2 (873 MW(e)) Net Dependable Capability - MW(e) (10,321) 11, 194 (24,899) 24,600 Net Peak Load - 7W(e) (8,550) 8,400 (20,040) 19,510 .3 R'eserve Marain - MW(e) (1,771) 2,794 (4,859) Reserve -arcin - Percent. of Peak Load (20.7) (23.8) 23.5Z/ Needed Reserve Margin Based on Criteria of 20 Percent of Peak Load - MW(e) (1,710) T3-. / (4,008) Indian Point Unit No. 2 (873 MS--(e)) Capability as Percent of NZeeded Reserves (51.0) (44.2) 4/

                                                                            *(61.)                         (851)

Reserve Deficiency - MWi(e) Even with oneration of Indian Point Unit No. 2 at 50% power, a reserve deficiency of 376 K,-;(e) in the applicant's system results.

 / Includes    325 151(e)       of firm power purchases.

Reserve martin must consider the arount of ceneratina capacitv that will be unavailab e b ec au e 7 .c -:Z t . :nr

                                                               .-=:c    ca -,,cv z-s bc yon. no r ai re.z renent age. M:un of zn- reserve cmnac::v crnncz he cx>-nec:en to be avaiiaoie.                                tased  on N et         r'.s      .:- _nc-a i_7:: a-s es    zi..,       that an averace of 2,250 M e) will be unavailabie because oz u"5scnecu1Žz outaces.                         This represents 429 MW(e) more than ehe estir.ated reserve o: i,921 "i;Ie) y    Includes   deduction of 500 ,W(e)            down for scheduled maintenance.

Y/ A 20% ninimuri as a reserve marain canacitv is an aopropriate general rule in ri-any s*tulv:n:. t :n:- an o run1z:u. zro:*rin.o

                                                                                   -or ConsollaTe-C    ncF-Ison because of reasons alreacv outlined in footnote 2.

63

                                                     - 27 TABLE X-3 PROJECTED ELECTRIC LOADS ;ND SUPPLY CONDITIONS WITHIN THE NORTHEAST AREA XDD THE NEW YORK POWER POOL (WITH AND WITHOUT INDIA POINT UNIT NO. 2)

Summer 1972 Winter 1972-73 Northeast Power Coordinating Cincil* Planned Capability, 'M(e) (54,763) 54,7111/ (57,488) 59,8572/ Anticipated Reserves, MW(e) (13,334) 10,3372/ (12,062) 13,3051/ Percent of Projected Peak Load (32) 25.1 (27) 29.4 Planned Nuclear (2,824) 1,386 2,835 2,835

     ,Percent of Anticipated Reserve,                                  (21)        10.4         (24)        21.2 New Y6rklPower Pool**

Planned Capability, MW(e) (Including net of transactions and 873 MW(e) from Unit No. 2) (24,247) 24,600 (25,733) 26,681+/-/ Peak Load, HW(e)- (20,040) 19,510 (20,040) 18,540 Anticipated Reserves, MW(e), (4,207) 4,5901/ (6,683) 7,241-/

    .Percent of Projected Peak Load                                    (21)       23.5         (35)        39.1 Necessary Reserve at 20%(1)         M4(e)                   (4,008)        3,902     (3,810)        3,708 Surplus (Deficiency) MW(e)                                     (199)          688    (2,873)        3,533 Without Indian Point Unit No.           2 J Nuclear, Azrii 1972)                                                -873                      --873 (Consolidated Edison Co.       -

Buchanan, New York) Net Capability Z4W(e) (23,374) .23,727 (24,860) 25,808 Peak Load MW(e) (20,040) 19,510 (19,050) 13540

-Reserve                           "       MW(e)                  (3,334)        3,7173/   (5,810)        6,3681/

Peak Load  % (16.6) 19.0 (30) 34.4 Necessary Reserve at 20%1/ 4W( (4,008) 3,902 (3,810) 3,708 Surplus (Deficiency) MW(e) (674) 185 (2,000) 2,660

• Includes New York, New England, and Canadian members.

 *,     Includes net of sale transactions.

1 FPC Staff Estimate. -2/ Vith Indian Point -:o. 2 at 873 2%1(e)

      / Inclucfs   du.:on       Zor sc::cdulerA raintehance.

R fiinter ca=cit:': nlch-r .bcauze oz inz.ro'.cd cooling efficiency.

*ourcor Letter to J. .R. Scicsincer,              Cnairm.an or the Atomlc Energy Commission, from J. N. Nassikas, Chairman of the Federal Power Cormission, October 15, 1971 and evaluteion of New York.State Denartment of Public Service made on May I, 1L72,r          en    Consolidna*d rciason ioad and caoacitv estimates dated narch 2S, 1972 and reort          oz :.'CC dated ;Aoril 1, 1972.

814

                                    -   28 -

54. Table X This table has also been updated to reflect the load and capacity information received from the Northeast Power Coordinating Council on April 1, 1972, and to reflect the changes that were made in Table X-1. This has been retyped to permit comparison of the new information (which has been underlined) and the original information (which has been put in parentheses).

55. Page XI There does not appear to be adequate recognition that older plants which were originalyy coal-fired have been converted to oil to eliminate fly ash and coal handling problems. At the time these conversions were initiated, they were considered important steps to reduce soot emissions. As new environmental problems have been identified, ilowever, further efforts for improve-ment have been found necessary.

56. Page XI The section dealing with purchased power is now out of date. Recent information from Consolidated Edison indicates that they will receive the output from Bowline No. I of 600 MW(e) and have firm purchase commitments for 270 MW(e) from Rochester Gas and Electric and an additional 150 MW(e) from PASNY. Negotiations were still underway for 300 MW(e) from Ontario Hydro.

57. Page XI A statement is made in connection with "Wet Cooling Towers" that all the heat rejected to the wet cooling tower is transferred via evaporation. One hundred percent evaporation takes place only during certain ambient conditions, and these conditions very seldom occur. In actual practice heat is dissipated by a combination of evaporation and sensible heat transfer.

85

58. Page XI Table XI-3 includes sections titled "Effects on Water Body of Intake Structure and Condenser Cooling System, 2.1 Primary Producers Consumers and 2.2 Fisheries." The effects of open cycle cooling systems would appear to be the same as, if nor more than, those for the once-through alternative. Since the same volume of water would be withdrawn, but mechanical impact and holding time at elevated temperatures would be increased, it would seem that the onshore effects of these alternatives would be similar to those for the once-through approach. On the other hand, the time the discharge would be above ambient temperatures would be substancially reduced.

Thus, all four approaches should be either "Potentially Large" or the 2nd, 3rd, and 4th should be "Equal or Greater than for once through." The text (Pages XI-23ff) does not appear to cover these alternatives. Line 3.2 on the effects of chemical discharges on aquatic biota seems questionable. Cleaning requirements would be greater in connection with natural draft and mechanical draft open-cycle cooling alternatives than with once-through cooling. This, of course, would have a slightly greater effect on aquatic biota. A spray pond should have equal or larger effects than once-through cooling. For the closed cycle systems the blow down shquld have higher chemical concentrations but would be of much smaller volume. While minor, they certainly wouldn't be zero. The items in Table XI-3 that are identified as "Same" might be interpreted to mean the same as above or the same as once through. All use of the term "Same" should be replaced with an appropriate number and all blanks should be ýj led in with either a zero or a

statement that the impact is minor, major or unevaluated, as appropriate..

59. On page 1-9 and elsewhere in the Statement it is indicated that "ecological studies" are "directed" or are being "supervised" by the Hudson River Technical and Policy Committees. These Committees are advisory and can only make recommendations regarding procedures, etc.

60. The statement gives a great amount of consideration to meeting New York State standards however does not give any consideration to New York State Law (Section 275 of the Conservation Law) which deals with the protection of fish.

87

                                                          -D/

Comments on the Draft Detailed Statement on Environmental Considerations Related to the Proposed Issuance of An Operating License to the Consolidated Edison Company of New York for the Indian Point Unit No. 2 Nuclear Generating Plant

                         -Docket No. 50-247 LOUIS J. LFFKOWITZ 80 Centre Street New York, New York  10013 Attorney General of the State of Nev, York Dated: June 2, 1972 88

The draft detailed statement prepared by the Division of Radiological and Environmental Protection of the Atomic Energy Commission contains, in our judgment, substantial errors 6f analysis in three specific areas:

1. Indian Point II's effect on fish and other aquatic life,

2. The feasibility of natural draft closed cycle cooling towers at Indian Point; and

3. The alleged immediate necessity for the power to be generated by Indian Point II.

1. Indian Point II's effect on fish and aquatic life.

In evaluating the effect of Indian Point II on the Hudson River ecosystem, the draft statement treats the effects of the plant in a vacuum, totally ignorina the future presence of two sizable generating stations to be located near Indian Point II -- the Bowline Point and Roseton plants -- in addition to the existing Danskammer and Lovett plants. The cumulative effect of these generating stations will place considerable stress on the Hudson River even before it feels the effects of Indian Point II. None of these stations has undergone or will undergo a NEPA review. In view of the fact that the license beina applied for here will 83

extend for 40 years, the failure of the draft statement to relate the effects of Indian Point II to the present and future adjoining stresses on the Hudson River renders the draft statement, with its single-minded focus on Indian Point II, myopic and violative of the teaching of the Calvert Cliffs decision. Further, the State of Kew York totally rejects the premise that, in an area of this magnitude, where the entire fate of the Hudson River ecosystem is at stake, future research and analysis of the detrimental effects of this massive power plant should be entrusted to the applicant alone. This amounts to posting a wolf to guard the sheepfold. The inherent conflict of interest which would result from employing the licensee as its own policeman, is underscored by its history of haphazard investigation of fish kills and repeated refusal to gather and supply relevant data concerning fish larvae and other aquatic life. This policy will inevitably cast a shadow over any future conclusions of the Commission regarding the adverse effects of the plant on the River, based as they would inevitably be on studies drawn up, conducted and evaluated by an applicant which has a vested interest in the results of such studies. Any future study of the effects of Indian Point II must be assicrned to an aqency or organization which will not have the huge pecuniary stake in the ultimate results of such a study which Con Edison has. g0 It is also relevant to note that New York Conservation Law § 275 dictates that "No person shall take fish . . . by shutting or drawing off water." The Attorney General has filed suit against Con Edison to recover $1.6 million in penalties, pursuant to Sections 275 and 389(4) of the Conservation Law, resulting from massive fish kills at Indian Point II which occurred during recent testing operations in February 1972. In addition, Con Edison has signed a consent order with the New York State Commissioner of Environmental Conservation under which it is mandated to take affirmative steps designed to prevent such kills. Pursuant to 10 CFR Part 50, App. D, S A.13, the Commission's license should be conditioned on the applicant's meetinq all State requirements relating to the protection of Hudson River marine life.

2. The feasibility of natural draft closed cycle cooling towers at Indian Point II.

The draft statement states:

               "The principal objection to using evaporative cooling towers [e.g. natural draft closed cycle coolina toweFrs at the Indian Point site is the hiah range of salinity content of the Hudson River (100 to 7000 ppm). The damaging effects of the salt-water drift on metallic objects and plant life could be detrimental. Until such a time as research can produce brackish water cooling towers with very low drift and environmental impact, this use is not practical.     (DFS, XI-9)."

91

But nowhere does the draft statement support that conclusion with any data. Its conclusion directly contradicts both the applicant's own analysis and those of the State of New York and the Hudson River Fishermen's Association. It is beyond dispute that natural draft closed cycle cooling towers at the Indian Point II plant would reduce intake water demand at the site by at least 95%, with attendant enormous reduction of the severe ecological impact on river life inherent in Con Edison's system as presently designed. The construction of this alternative to once-through cooling will assure protection of the vital ecosystem now thriving in the Hudson River. The applicant itself has stated that cooling towers will not cause problems relating to fogging or saline drift. While they do object to the expense, attendant downtime resulting from connection, and the vapor plume above the towers, Con Fdison does acknowledge that brackish-water cooling towers are commercially available (see Comments, Con Edison, C-164), contary to the draft statement. 32

Ecodyne Cooling Products Co. of Santa Rosa, California, reports that in fact they have officially guaranteed Con Edison and the New York State Public Service Commission that it can provide cooling towers with a drift loss rate of .004-.008% of circulating water flow. At this level of drift loss, Ecodvne has calculated through atmospheric dispersion formulas that there will be "minimal local adverse impact from brackish water natural draft cooling towers." By placing an air-cooled heat exchanger atop conventional cross-flow natural draft cooling towers, Ecodyne has succeeded in greatly reducing saline drift and nearly eliminating the fog heretofore characteristic of this type of cooling device. Not only will this system eliminate the adverse effects moist, salty air might otherwise have on trees and plants, equipment, roads and homes, but it will also reduce the vapor plume which might otherwise accompany these towers. The General Public Utilities Service at Morristown, New Jersey, has, like Ecodyne, conducted a year long in-depth study aimed at evaluating the environmental effects of salt water cooling towers. This study proceeded with electrical industry funding and appeared in the environmental report prepared by 93 Jersey Central Power and Light for its Forked River I plant. Submitted to the A.E.C. in January, this report concluded that salt water cooling towers generate minimal adverse impact on property adjacent to cooling towers. It appears that much of the material in the draft statement was written prior to the submission of the Forked River I environmental report, and did not benefit from the conclusions reached there. All available information indicates a need for the A.E.C. to reevaluate its position regarding the feasibility of salt water cooling towers, especially in view of the lack of available alternatives to once-through cooling for the protection of the Hudson River ecosystem.

3. The alleged immediate necessity for the power Indian Point II will generate.

As the analysis presented by the Hudson River Fishermen's Association (Comments, pp. 20-23) indicates, there is no authoritative evidence showing the alleged necessity for Indian Point II's power in the immediate future. The plant cannot be put into operation in time for the summer months, when the power demand is greatest. And even for that period, the Federal Power Commission has determined that the 1972 reserve margin of the 9t

New York Power Pool without Indian Point II will be 19.6%, almost double that of a year ago. A 40-year license to operate a massive generating station without adequate environmental safeguards should not be granted on the basis of an alleged but unproven power crisis, where reasonable alternatives exist, such as natural draft cooling towers. PHILIP WEINBPRG PAUL S. SHEMIN Assistant Attorneys General of Counsel 95

WESTCHESTER COUNTY PLANNING BOARD EDWARD FLEAGLE YONKERS WILLIAM N. CASSELLA. JR. DOBBS FERRY VICE CHAIRMAN CHAIRMAN P. M. FREEMAN BEDFORD EDWARD J. MORTOLA NEW ROCHELLE J. BOYD HENSON WHITE PLAINS BERTRAN F. WALLACE HASTINGS-ON-HUDSON WARREN T. LINDQUIST hORTH CASTLE MRS. THOMAS M. WALLER BEDFORD ROBERT A. DENNISON EX OFFICIO CHARLES E. FOUND EX OFFICIO COMMR. OF PUBLIC WOR KS COMMR. OF PARKS, RECREATION & CONSERVATION WILLIAM G. BORGHARD EX OFFICIO COMMR. OF EINVIRONMENTAL FACILITIES WESTCHESTER COUNTY DEPARTMENT OF PLANNING PETER Q. ESCHWEILER. A.I.P. 910 COUNTY OFFICE BUILDING WHITE PLAINS. N. Y. 10601 914 WHITE PLAINS 9-1300 COMMISSIONER JOSEPH R. POTENZA, A.I.P. May 12, 1972 DEPUTY COMMISSIONER Mr. Lester Rogers, Director Atomic Energy Commission Washihgton, D. C. 20545 Re: Docket Number: 50-247 Indian Point No. 2

Dear Mr. Rogers:

This is to acknowledge receipt by the Westchester County Department of Planning of your letter of transmittal and attachments comprising the above-cited draft environmental impact statement. This department has no comments to add to the statement at this time. However, we may wish to have the opportunity to become a party of interest in future proceedings, and to comment at that time. Sincerely,

                                                                                  /        *1/.

PQE:mb Peter Q./Eschweiler Commissioner 38

Natural Resources Defense Council, Inc. 36 WEST 44TH STRIEET NEW YORK, N.Y. 10036 50-247 212 986-8310 Washington Office BOARD OF TRUSTEES 16OO TWENTIETH STREET, N.W. Stephen P. Duggan, Esq. Chairman WASHINGTON, D.C. 20009 Mrs. Louis Auchincloss 202 387-2855 Boris I. Bittker, Esq. April 19, 1972 John T. Booth Thomas Cashel, Esq. Dr. Rene J. Dubos Robert W. Gilmore Dr. Joshua Lederberg James Marshall, Esq. Mr. A. Giambusso Ruby G. Martin, Esq. John B. Oakes Division of Radiological and Ehvironmental Protection The Rev. Charming E. Phillips U.S. Atomia 1hergy Commission Dr. Gifford B. Pinchot Charles A. Reich, Esq. Washington, D.C. 20545 John R. Robinson, Esq. Laurance Rockefeller J. Willard Roosevelt

Dear Mr. Giambusso:

David Sive, Esq. Dr. George M. Woodwell Edwin M. Zimmerman, Esq. With reference to your letter of March 21 (Dock.50-247) and subsequent telcons, I have now reviewed trhe draft detailed environmental statement and I am ready to meet with ORNL and AEC staff personnel at an early date. The principal subject for discussion is predicted effects upon the populations of Hudson fishes of operation of nuc-lear power plants at Indian Point. We will be patticularly interested to discuss the basis for predictions relating to the following points and such related aspects as may be pertinent:population estimates and mortality rates; comp-ensatory effects; vulnerability to entainment at various stages; quantitative effects upon the population of im-pingement, and susceptability of various stages to im-pingement; relation of velocities through screen to im-pingemnt to mortality effects; effects of the thermal plume on fish behavior; effects of oxygen depletion and chlorine on behavior and mortality; and acceptable limits of mortality at various stages in light of present know-ledge. In addition to myself and Mr. Habicht, please plan on at-tendence of Mr. Pete Skinner, technical expert for the N.Y. Attorney's office. You can reach me by telephone at 683 7971. Thank you. Sincerely, / 97 ~ J,6aR. Clark apO North Washington St. Alexandria, Va. 22314

Natural Resources Defense Council, Inc. 36 WEST 44TH STREET NEW YORK, N.Y. 10036 50-247 212.986-8310 BOARD OF TRUSTEES JWashisngfor OI15ce Stephen P. Duggan, Esq. 000o TWE/NTIETHt STREET, N.W. Chairman June 29, 1972 WAASHIINGT ON, D.C. 20009 Mrs. l.ouis Auchincloss 8 202 38772 55 Boris I. LJiuker, Esq. John T. Booth Thomas C.sshcl, Esq. Dr. Rene J. l)uhbs Robert W. (;il.ore Dr. Joshua LcLdrrberg James Marshall, Esq. Rub), G. Mat in, Esq. Johu 11. Oakes The Rv. Charming E. Phillips Dr. GiCford i'. hinchot I Myron Karman, Esq. Charles A. RVich, Esq. Counsel, Regulatory Staff John R. Robinsoi. Esq. Laurancc Rocki:fllcer U.S. Atomic Energy Commission J. ' ,'illa d R o ose v elt David Si,:e, Esq. Washington, D.C. 20545 Dr. GentgeNf. WVoodwell Edwin N1. Zimn vmian, Esq.

Dear 1.r. Karman:

John 11. Adams, Esq. Executive Dirertor Mary Jane Oestmanm informed me that you had not received the Comments submitted to the Atomic Energy Comnmission, dated June 1, 172. I enclose the same. Yours sincerely, Angus Macbeth As/j s Enclosures Cc: Mr. Daniel Muller 98

I ,, Comments Submitted to the Atomic Energy Co-,mmission on Behalf of the Hudson River Fishermen's Association on the Draft Detailed Statement on the Environmental Considerations Related to the Proposed Issuance of An Operating License to the Consolidated Edison Company of New York for the Indian Point Unit No. 2 Nuclear Generating Plant Docket No. 50-247 99 Submitted by Angus Macbeth (Natural Resources Defense Council, Inc. )° 36 West 44~th Street New York, N.Y. 10036 Attorney for Hudson River Fishermen' s Association Dated: June 1, 1972

The interest and concern of the Hudson River Fishermen's Association in the environmental impact of Con Edison's Indian Point 2 nuclear plant has focussed primarily on three issues:

1. The effect Indian Point 2 will have on the fish and aquatic biota of the Hudson.

2. The environmental effects of operating natural draft closed cycle cooling towers at indian Point - a cooling alternative which would save the Hudson River fishery.

3. The need for the power which would be generated by Indian Point 2.

In the draft environmental statement on Indian Point 2, "Draft Detailed Statement on the Environmental Considerations Related to the Proposed Issuance of an Opearating License to the Consolidated Edison Company of New York for the Indian Point Unit No. 2 Nuclear Generating Plant, Docket No. 50-247," the staff deals with these issues with varying degrees of realism and rigor. The report is comprehensive but nevertheless there are major flaws in the analysis of each issue. The AEC staff analysis of each of the three major issues will be discussed in turn and a final section will deal with the cost-benefit analysis. iUL

I. The Effect of Indian Point 2 on the Fish and Aquatic Biota of the Hudson River The draft statement predicts the possibility of a major 'impact on the Hudson River fishery:

      "In Unit No. 2, aquatic biota impinged on the intake structure or entrained in the cooling water will be exposed to severe mechanical, chemical (chlorine),

and thermal conditions; as a conseauence, up to 25%b of the average number of eggs and larvae of certain species of fish that annually pass by the Plant may be killed; under the most adverse conditions, up to 100% of some of the entrained planktonic species may be killed; and fish kills of a magnitude two or three times greater than those caused by Unit lio. 1 miay occur." [Draft Environmental Statement, p. ii] In reviewing the first 100 months of operation at Indian Point 1, the AEC concluded that "Indications are that several million fish were killed." (DES, XI-7). In other words, the draft environmental statement contemplates annual kills at Indian Point 2 by impingement alone of a million fish or more. Thus the percentage of fish killed by entrainment and the absolute numbers of fish killed by impingement will be very substantial indeed. Discussing the effect of both entrainment and impingement on the striped bass, the best studied and economically most important fish in the Hudson, the AEC staff concluded:

      "...the total yearly recruitment loss for each subsequent year class in the population may be as high as 15% to 2T, from direct effects of Plant operation. Sustained reporductive losses of this magnitude over a long period of time would result in substantial reductions of the striped bass populations that spawn in the Hudson, including those of both the Hudson itself    and the area from the south New Jersey coast to Long Island Sound.'

(DES, V-53) 101

The staff also pointed out that its analysis of the striped bass will apply to other fish as well:

       "These same arguments apply to other species that spawn in the area and may cause important losses of recruitment to local populations of the alewife, blueback herring, bay anchovy, tomcod, smelt and Atlantic silversides, as well as striped bass.

(DES, V-55)* This analysis has the basic comprehensive approach which is essential to a discussion of the effect of the operation of Indian Point 2 on the Hudson and its biota. But there are major flaws in the analysis. These are discussed below. A. Failure to give a coherent account of the striped bass life cycle and population data which relates entrainment to imoingement The draft statement provides an analysis of the impingement problem which cites a number of absolute figures on past fish kills (DES, V-29 to V-33; V-46 to 47). The heart of the entrainment analysis discusses the effect on the fish in terms of percentages of the fish population (DES, V-52 to 55). In order to develop a coherent analysis of the effect of the operation of Indian Point 2 on the Hudson fishery it is essential that the impingement and entrainment figures be treated in similar terms, either absolute or percentage. The staff should attempt to develop an analysis along these lines. John R. Clark, the expert consultant to the-Hudson River Fishermen's Association on fish biology, has performed an analysis of this sort for HRFA and it is appended to these comments both for the value of the information it contains and as a pointed example of the kind of discussion which allows ______102

• The omission of white perch from this list appears to be an obvious typographical error and should be corrected.

a full analysis of the effect of plant operation on the Hudson. A coherent analysis of the type suggested will require fuller discussion of two other items. First, there must be a critical appraisal of the fish impingement data from Indian Point 1 and 2. The most obvious issue raised is the trustworthiness of Con Edison's figures in light of the Raytheon statistics cited in the draft statement which show both much larger total kills than comparative Con Edison figures and a much larger percentage of striped bass in the total kill (DES, V-31). Second, a discussion of the life cycle of striped bass touching on the rate of natural mortality and the period of vulnerability to the Indian Point plants is important to an understanding of the assumptions which underlie the analysis. At the present time figures describing the total effect on the fish population are given with little or no explanation of how those figures were arrived at. Both of these pointg should be developed and clarified in the final statement. B. Unsupported reliance on density-dependent and compensatoryj factors The draft statement discusses the possible compensatory factors involved in density-dependent influences on the mortal-ity rate (DES,V-53 to 55). .This discussion contains very little evidentiary support for the theory that throughout the first year of life striped bass mortality is not density independent. In fact, the evidence suggests that after the fourth 103

or fifth week after spawning the striped bass mortality is density independent. Recent studies from California suggest this. Sommani, P., "A Study On the Population Dynamics of Striped Bass. (Morone Saxatilis W1albaum) In the San Francisco Bay Estuary", University of Washington Abstract; Turner, Jerry L. and Harold K. Chaduwick,"Distribution and Abundance of Young-of-the-year Striped Bass, Morone Saxatilis, In Relation to River Flow in the Sacramento-San Joaquin Estuary" (to be published in Trans. Am. Fish Soc.). In Chesapeake Bay the fishery has been found to vary an order of magnitude depending on the strength of the recruitment. (Mansueti, R.J. & E.H. Hollis. 1963. U. of Md. Nat. Res. Mgt. Edut. Sci. (61); Hollis, E. H., Md. Dept. Ches. Bay Affairs. Final Rep. 1967; Koo, Ches. Sci - These studies all indicate that striped bass mortality is density independent beginning at a very early stage of life, probably in the second month after spawning. Striped bass appear to be a year class dominant species. Another major indicator of compensatory factors is the growth rate. Stunted gro.th might indicate that thinning of the fish population would result in the same weight of fish per acre being spread among~fewer, larger fish. There is no indication of stunted growth in the Hudson in comparison to other estuaries. Hudson striped bass at the end of 15 weeks (Carlson, F. T. & J. A. McCann, Hudson River Fishery Investiga-tions 1965 - 1968, Table 24; Rathgen-Miller. 1957. N.Y. F. & G. 104

Journ. 4 (1)) are the same length as striped bass in the Chesapeake (Mansueti, R. 1958. Md. Dept. Res. & Ed. Contr. No. 112; Hollis, E.H. 1967. Md. Dept. Ches. Bay Affairs. Final Rep. 1967.) and t1e San Joaquin-Sacramento (Sasaki, S. 1966. Cal. Dept. F. & G. Fish Bull. (136)). They are larger than those in Albemarle Soiud. (Trent W.L. 1962. Master's Thesis, N.C. State Col. Dept. of Zoology.) Comparativedata for the early stages of white perch are not available, but at the end of the first year Hudson River white perch (Lauer, McFadden, Raney, Testimony of April 5, 1972 in this proceeding.) are about equal to those in the Chesapeake (Mansueti, R.J. 1961. Ches. Sei. 2 (3-4)) and the Delaware (Wallace, D.C. 1971. Ches. Sci. 12 (4))* At the end of three years Hudson River white perch (Lauer, McFadden, Raney, Testimony of April 5, 1972 in this proceeding) are again equal to those in the Chesapeake (Mansueti, R.J. 1961. Ches. Sci..2 (3-4)) and the Delaware (Wallace, D.C. 1971. Ches. Sci. 12 (4)). Finally, there are no indications of overcrowding of the fish population in the Hudson which might also indicate stunted growth and the likely presence of compensatory factors. (Compare Environmental Repoit Supplement No. 3, S3-25 to 30 with HcHugh, J.L. 1967. Estuaries, AAAS Pub. No. 83).

                                     .105 TE1s-ITiates       for conversion between standard length, total length and fork length must be made,

Both the data on mortality and the data on growth suggest that very early in the life cycle of the striped bass- probably some time in the second month - the killing of striped bass larvae and juveniles begins to have a direct effect on the number of striped bass which survive to the end of the first year. Moreover, the thinning of the larval ýnd juvenile population will not be compensated for by an increased growth rate among the remaining fish. The staff should re-analyze its position on density-\ dependent mortality and compensatory effects,' taking into account all the available data on the subject. If a case is to be made for the position suggested by the staff in the draft statement, it should be spelled out with much more evidentiary support than appears in the draft statement. C. Failure to consider the effect of other electrical plants presently operating on the Hudson and scheduled to begin operation in the immediately foreseeable future Fish kills due to entrainment through power plant condenser systems are a function of the volume of water withdrawn from the River, the degree to which it is heated and the abundance of eggs, larvae and young juveniles in the area where the plant is sited. Indian Point Units 1 and 2 will withdraw 1,140,000 gpm from the Hudson. (DES, 111-6, 111-12). The water will be heated 15'F (DES, 111-8) and then discharged to the River. Indian Point is situated at River Mile 43, an area which is of very high abundance in striped bass eggs, larvae and young Juveniles. (DES, V-45). 106

The Bowline Point plant of which the first unit is scheduled to go on line in July 1972 and the second unit by 1974 (DES, 111-7), will withdraw 768,000 gpm from the Hudson 13.5 0 F before discharge to the River (DES, 111-8). and heat it Bowline Point is at River Mile 38, 5 miles from Indian Point, and there is an abundance there of'striped bass eggs, and a great abundance of larvae and young juveniles. The Roseton plant, of which the first unit is scheduled to begin operation in November 1972 and the second in May 1973 (DES, 111-7), will withdraw 650,000 gpm from the Hudson and heat it 15.4*F before discharge. (DES, 111-8). The Roseton plant is located at River Mile 65, 22 miles north of Indian Point in a reach of the River where the eggs and larvae of striped bass are abundant. The Danskarner plant, presently in operation (DES, 111-7), withdraws 308,000 gpm from the Hudson and heats it 14.50 before discharge (DES, 111-8). The Danskarnmer plant is located at River Mile 66 and the aquatic biota is the same as that at the Roseton plant. The Lovett plant, presently in operation (DES, 111-7), withdraws 323,000 gpm from the Hudson and heats it 14.8 0 before discharge (DES, 111-8). The Lovett plant is located one mile downstream from Indian Point and the aquatic biota is the same as that at Indian Point. It is obvious that this total array of plants will have a very significant impact on the Hudson River fishery. The staff has estimated that Indian Point Units 1 and 2 may kill 107

off 25% of the striped bass eggs and larvae which pass the plant. Bowline Point and Roseton together will withdraw a third again as much water as Indian Point 1 and 2 and heat it approximately the same amount. It is conservative to estimate that Bowline Point and Roseton will annihilate an additional 15% of the striped bass eggs and larvae in the Hudson. In addition the Danskaner and Lovett plants are already operating on the Hudson and using substantial amounts of river water for cooling thus adding to the total stress on the River system. The combined effect of the operation of all these plants will decimate the Hudson fish population in a fantastic manner-more than 40%S of the striped bass eggs and larvae in the River will be entrained annually. Con Edison has requested a license to operate the Indian Point 2 plant for a period of forty years. It is, of course, clearly foreseeable that some or all of these four plants will operate during any period for which Indian Point 2 is licensed. Thus Indian Point 2 will operate in an environment on which Bowline Point, Roseton, Danskammer and Lovett will have a significant effect. Bowline Point and Roseton are not scheduled to undergo a N.E.PA. review. Danskammer and Lovett have not undergone a N.E.P.A. review. Thus these plants cannot be viewed as producing increments of environmental impact which have been or will be reviewed before they are allowed to 108

begin operation... In these circumstances the impact of Indian Point 2 must be weighed in light of the knowledge that within a few years the total impact of the Bowline Point, Roseton, Danskammer, Lovett and Indian Point 1 and 2 cooling systems will be thrust on the Hudson and its biotic life. The AEC must reach a decision as to whether the present cooling system planned for Indian Point 2 is acceptable not only in Mlay or June of 1972, but also in July 1972 when Bowline Unit 1 is operating and two years from now when all the units at Bowline Point and REceton are withdrawing their vast quantities of water from the Hudson and discharging their heated load to the River with the attendant effects of impingement and entrain-ment. Not to consider the clearly foreseeable effects of Bowline Point and Roseton is tantamount to not considering winter operations on the ground tiat the license was applied for in the spring. The only rational procedure in analyzing the impact of this facility is to take into account the present and the foreseeable future plant operations which are not themselves subject to a similar review under NEPA. The law follows this rational line and instructs Federal agencies to take a wide and comprehensive view of their duties under the National Environmental Policy Act, 42 U.S.C. §4321, et.seg. In Section 102 of NEPA, federal agencies are directed that "to the fullest extent possible" the policies of NEPA are to be carried out in all of the agency's activities, including, but not limited to, the preparation of environmental impact 109

statements. The term "to the fullest extent possible" has been the subject of both Congressional and judicial interpretation. The Senate and House conference, which vrote the phrase into NEPA, stated: The purpose of the new language is to make it clear that each agency of the Federal Government shall comply with the directives set out in [Section 102(2)) unless the existing law applicable to such agency's operations does not make complience possible.... Thus, it is the intent of the conferees that the provision "to the fullest extent possible" shall not be used by any Federal agency as a means to avoiding compliance with the directives set out in Section 102. Rather, the language in Section 102 is intended to assure that all agencies of the Federal Government shall comply with the directives set out in said section "to the fullest extent possible"tunder their statutory authorizations and that no agency shall seek to construe its existing statutory authorizations in a manner designed to avoid compliance. 115 Cong. Rec. 40417-40418. In Ely v. Velde, __F.72d-_, 3ERC 1280, 1285 (4th Cir. 1971), the Court of Appeals for the Fourth Circuit held that the phrase is "an injunction to all federal agencies to exert utmost efforts to apply NEPA to their operations. in short, the phrase 'to the fullest extent possible' reinforces rather than dilutes the strength of the prescribed obligations." In Calvert Cliffs' Coordinating Committee v. AEC, __F.2d_, 2 ERC 1779 (D.C. Cir 1971), the Court of Appeals for the District of Columbia carefully considered the phrase, "to the fullest extent possible" and concluded that Section 102 must be complied with (2 ERC at 1782): "unless there is a clear conflict of statutory authority" and further explicitly instructed the Ajomic Energy Commission that "the requirement of environmental 110

consideration 'to the fullest extent possible' sets a high standard for the agencies, a standard which must be rigorously enforced by the reviewing courts." (mbid.) In the revised Appendix D to 10 C1R Part 50 the Commission has set out to apply the instructions of the Court in Calvert Cliffs. There can be little question that if the environmental effects of the operation of Ihdian Point 2 are considered "to the fullest extent possible" that consideration will include analysis of the impact which may be foreseen and calculated over the next few years when Indian Point 2 will be operating on the same stretch of river with Bowline Point, Roseton, Danskaxmor and Lovett which have not and are not sche-duled to undergo 1EPA review. of these plants when it includes The staff obviously recognizes the relevance and importmnce / in the draft statement on Indian Point 2 an analysis of the plants' physical relation to the Indian Point site (DES, 11-7), their contribution to the heat load on the Hudson (DES, 111-7 et seq.) and their importance to the future power supply in the area (e.g. DES, XI-5). The only logical step to take is to consider the impact of Bowline Point, Roseton, Danskammer and Lovett on the fish and aquatic life of the Hudson as well. In addition, putting off consideration of these plants to any later date will only fragment consideration of a single problem into a multitude of small pieces. Such fragmentation does not make sense in scientific terms or in terms of admini-strative efficiency. John R. Clark has analyzed the probable effect of Bowline Point and Roseton when they are operating il

in conjunction with Indian Point 1 and 2. That analysis is appended to these comments for the use of the staff in expanding their analysis to take those plants as well as Danskammer and Lovett into account in developing the final. statement. sense, the Cor 1 on/language of ITEPA, the legislative history of the Act and the judicial decisons under the Act all require that the NEPA' review on the application for an operating license for Indian Point 2 take into consideration the environmental impact of present or foreseeable actions which are not themselves subject to B`EPA review. Nothing less can implement the Act's requirement that its policies and procedures be followed "to the fullest extent possible." D. Failure to consider relevant law of the State of bf ,New York The AEC's regulations on the licensing of nuclear power plants state that: The Commission will incorporate in all ... operating licenses ... a condition ... to the effect that the licensee shall observe such standards and requirements for the protection of the environment as are validly imposed pursuant to authority established under Federal and State law and as are deternined by the Conmmission to be applicable to the facility that is subject to the licensing action involved. 10 CFR Part 50, App. D, § A.13. Pursuant to that regulation and the Federal Water Quality Act of 1965,the staff included in the draft environmental statement a careful discussion of the thermal discharge standards of New York State and the status of Con Edison's application for a Refuse Act discharge permit. (DES, III 7-12). In discussing alternatives to the present plant at Indian Point, the staff also rejects the possibility of not providing 112

power "in view of the applicant's obligation under its charter from the State." (DES, XI-1). The draft statement is totally silent on those elements of state law which deal with the protection of fish. Section 275 of the New York Conservation Law states: "No person shall take fish ... by shutting or drawing off water." Section 389(4) of the Conservation Law sets a specific civil penalty for violation of Section 275, $500 and "an additional penalty of ten dollars for each fish taken." These statutes involve no weighing and balancing. Section 275 is a simple and direct prohibition and Section 389 is a straight-forward civil penalty. These sections of the law are being actively enforced. In late February approximately 160,000 fish were killed at Indian Point 2 when 2 of the 6 pumps were put through a test run. (DES, V-31). As a result of those kills, the N.Y.S. Commissioner of Environmental Conservation has asked the Attorney General to sue Con Edison for $1.6 million. That suit has been filed and relies on Sections 275 and 389 of the Conservation Law. Under both the Commission's regulations and in view of the actions taken by the New York State authorities, the AEC should give careful consideration in its statement to possible violation of New York law and require that Con Edison operate the plant within the standards set by the New York legislature for the protection of fish. 113

In light of the suit by the Attorney General future fines must also be taken into account in the cost-benefit analysis. Present staff estimates indicate that millions of fish will be killed at Indian Point 3. The AEC must recognize that this will cost Con Edison and perhaps its consumers tens of millions of dollars. E. Proposal to request Con Edison to conduct research on Hudson fish and biota. Rather than requiring Con Edison to begin imnediately the construction of an alternate cooling system at Indian Point, the draft statement proposes that Con Edison undertake a research program on the basis of which future action would be decided: An operating license would permit the applicant ... to establish an effective environmental monitoring programi in conjunction with an alternative plan to limit the effects on the aquatic system. The applicant shall be required to evaluate and assess the data collected from the monitoring program in order to design and implement an alternative plan or plans to minimize the long-term potential damage to the aquatic biota in the Hudson River. The applicant shall be required to submit to the Commission within the next 6 months a plan or plans of specific detailed design of the best alternative system that it can determine which will result in an optimization of Plant operation and minimal envirormental damage.... The Technical Specifications to be provided with an operating license will specify the limitations of specific effluent discharges and the ecological moni-toring surveillance program recuired with the necessary administrative controls, to assure adecuate data iill be collected for use to assess the biological impact of operation of Indian Point Unit No. 2 on the environment*. (DES, XI-55). There are two major failings in this suggestion. First, it turns over the research function to a party which has been shown to be incompetent in the past and which has a clear and 114

unmistakable interest in the outcome of the research, Second, it fails to set any standard by which damage to the Hudson will'be measured. The staff itself recognizes Con Edison's past incompetence in conducting and reporting research on the Hudson. Speking generally, the staff has concluded that: "It is apparent that many of Con Edison's conclusions are not consistent with the data acquired by its consultants." (DES, V-55). The staff drives the point home with an illustration of a Con Edison statement that the eggs and larvae of six key Hudson River fish are not vulnerable to the intake and thermal plume at Indian Point,"Extensive data gathered by the Raytheon Company and. by Northeastern Biologists, both of which are con-sultants for the applicant [Con Edison] clearly show that larvae of the striped bass, alewife, and blueback herring are susceptible to the intake and thermal plume." (DES, V-56). The self-interest which will pernmeate Con Edison's research effort is patent and obvious. Common sense dictates that giving Con Edison control of this research project is ridiculous. Moreover the courts have found conditions of this sort in licenses to be absurd. The N.Y.S. Commissioner of Environmental Conservation attached conditions of the same kind to the water quality certificate for Con Edison's Storm King project and they have been struck down by the state court: [T]hese conditions would require Consolidated Edison immediately to terminnte the operation of its project upon evidence of "violations or contravention of the 115

water quality standards assigned to the Hudson River" ... The monitoring of the project to assure that these conditions were fulfilled was delegated to Consolidated Edison. ... It is also urged that in operation the conditions were impractical to the point of being ridiculous in the light of human experience. Consolidated Edison is by these conditions called upon to police itself and if it finds itself violative of the Commissioner's conditions to abandon immediately its multi-million dollar project. This Court hearing no sound contrary argument and failing to imagine any concludes the conditions to be meaningless in law and fact, ,In the Matter of DsRham v. Diazmond

        - N.YoS. 2d-,

• T9 - .Sup. t.g-)-

The same arguments hold true in this case. Con Edison's interest in Indian Point 2 is just as great as that in Storm King. The whole research effort is further flawed by the failure to establish any-firm criteria by which the results can be measured. This is an abdication of the AEC's duty under NEPA to reach a judgment on the plant. The Commission must put in the scale some level of fish destruction which it finds unacceptable. Any other course fails to focus the controversy over this plant in such a way that it may be resolved. Since it will take at least three years to build an alternate cooling system, there must also be a strict time limit on when the results of. research will be evaluated. It is all too likely that the Hudson fishery will be decimated before Con Edison is ready to accept responsibility for the environmental damage it will cause at Indian Point. It may also be true that the necessary research cannot yield the knowledge which is sought. In discussing the indirect effects of plant operation, the AEC staff says: 116

     "At Indian Point, the complexity of the interactions of the biota with each other and through natural cycles of salinity and temperature is very difficult.

Unfortunately, even if all of the relationships were knovm, reliable biological predictions of the indirect effects of the operation of the facility could not be developed with the present state of the art." (DES, V-35) If this is true of other research areas as well, then the research program should be dismissed as useless and a judgment made on the plant on the basis of present knowledge. The AEC is proposing a voyage into complex research with no particular port in mind and on a ship skippered by a captain who has no interest in ever arriving. In the light of human experience this is ridiculous. It may also be scienti-fically fruitless. The plan should be rejected and the require-ment of an alternative cooling system should be imposed immediately. II. The Effect of Onerating Closed Cycle Natural Draft Cooling Towers at Indian Point 2 The installation of natural draft closed cycle cooling towers at Indian Point 2 would reduce withdrawal of water from the Hudson by 95% or more. In consequence there would be similar massive reductions of the harm caused the fish and aquatic biota of the Hudson. Various objections to this solution have been raised. Con Edison has come to tlP conclusion that aesthetics and costs are the major objections and it has rejected the notion that saline drift or fogging will cause any serious adverse 117 C

impact. (Environmental Report Supplement 3). The draft statement includes statements which support the conclusion that saline drift from natural draft closed cycle cooling towers will be negligible or Unimportant. In discussing the effects on people the staff concluded: "...any salts from the natural-draft cooling towers that might reach underground wells will have negligible effect on the water supply.' (DES, XI-32). The same conclusion held for effects on plant life: "Since the data show no salt deposition rates in excess of 500-1,000 lbs/acre/year, there will be no environmental costs to plant life in the area associated with these alternatives." (DES, XI-33). With regard to property the AEC concluded that"salt deposition rates are relatively low" and estimated the environmental cost at 0 dollars. (DES, XI-34). These conclusions are the same as those of Con Edison and the Hudson River Fishermen's Association and Environmental Defense Fund (Eric Aynsley, Testimony of April 5, 1972.in this proceeding). In fact at one point the report specifically states that "The staff accepts the applicant's salt deposition rates" (DES, A-78). Nevertheless, the draft statement includes the following unsupported statement: The principal objection to using evaporative cooling towers [e.g. natural draft closed cycle cooling towers] at the Indian Point site is the high range ofsalinity content of the Hudson River (100 to 7,000 gpm). The damaging effects of the salt-water drift on metallic objects and plant life could be detrimental. Until such a tLme as research can produce brackish water cooling towers with very low drift and environmental 118

impact, their use is not practical.(DES, XI-9). This surprising statement is supported by no data and is in direct contradiction to the other analysis contained in the draft statement. The AEC must either support this statement with hard data or abandon it. All the evidence from Con Edison, the Inter-venors and the rest of the draft statement suggests that the AEC should abandon this position. Cooling towers at Indian Point are practical. Saline drift is not a major problem. The AEC should focus on the practical problems at the plant, primarily the cost of cooling tower construction, and not reintroduce the discredited issue of saline drift.. III. Indian Point 2 and Con Edison's power crisis On April 1, 1972 Con Edison informed the AEC that Indian Point 2 would not be ready to go critical until late June 1972. In October, 1971 Con Edison gave the AEC a schedule of the testing procedures which it must complete at Indian Point 2 before the plant can operate .at full capacity (Con Edison, Testimony of October 19, 1971 in this proceeding, at 1-2). Con Edison also stated that this was a "best circumstances" schedule and that a realistic schedule would double the time for testing. Con Edison'requires.69 days for testing under best circumstances and 138 under a realistic schedule. Both realism and the past history of Indian Point 2 indicate that a schedule of 138 days is the only one that can be used with 119

any confidence. Assuming that Indian Point 2 is ready to begin testing on July 1, 1972, the testing schedule would be completed on November 15, 1972. In other words, Indian Point 2 will be ready for operation during the winter of 1972 at the earliest. It is obvious that the staff's analysis of the demands on the Con Edison system was written before Con Edison's announce-ment of April 1, 1972. Throughout the section on power demand, the statement again and again emphasizes the situation in the summer of 1972 (DES, X-1 to 13). In light of Con Edison's own estimates of its testing schedule, this analysis is simply irrelevant to Con Edison's license application. The plant will not be operating during the stummer of 1972. Moreover, this focus on the immediate future is a major flaw in'a report prepared for a 40 year operating license. A long-range project needs long-range analysis. This is something which the staff should cure in its final statement. The analysis of power demand must be undertaken independently by the AEC and not be simply adopted from Con Edison or other goverrnmental agencies. Other agencies and the applicant cannot be relied on for the simple reason that they disagree among themselves to the point where no coherent discussion of the power demand situation can be developed by simply collating agency or Con Edison statements. This can be demonstrated by the figures provided by the FFC, the New York PSC and Con Edison for summer 1972: 120

Summer 1972 oo 0P0 Total Available Capacity (MW) 10031 8758 9884 9448 (FPC-Net-Dependable Capability) Reserves (MWJ) 1481 208 1334 898 Reserves as % of Peak Load 17.3 2.4 15.6 10.5

    *   "The New York Power System Generation and Transmission Plans 1971-1980", System Planning Section, Powrer Division of the New York Dept. of Public Service (12/71) at 10. The Con Ed figures represent a forecast based on all plans being implemented on schedule. The Staff estimate represents staff estimates of delays. Cited in DES at X-13
    **  DES,  X-3. Bureau of Powier, FF0 (12/71).

These estimates were all made in December, 1971. They vary widely among themselves. They also vary widely from the actual facts as they are known today. In testimony submitted in the Indian Point 2 proceeding on May 18, 1972, Bertram Schwartz, a Vice President of Con Edison, stated that subsequent to July 15, 1972, Con Edison's installed reserves "will reach 24.9% (2095 MW)." (Schwartz testimony at 4). This figure does not include Indian Point 2 or a possible purchase of 95 1, from Long Sault, Inc. These figures are utterly different from any of the predictions. We are thus left with a chaotic jumble of figures most 121

of which seem to'bear little relation to the facts. In this situation the AEC staff cannot simply adopt the figures of one agency or another. It must perform its own analysis of the power demand situation. That is the only way in which an accurate and factual description of the situation can be arrived at. The analysis must, of course, address itself to the constituent elements of power supply and demand: monthly variation of power demand, retirement and maintanance schedules, purchasing opportunities, power pool agreements, voltage reduction procedures, variations in thermal efficiency, alternative sources of supply to consumers such as the Fitzpatrick plant. This list is suggestive but not exhaustive. No final judgnent the about/power supply and demand situation can be made without this kind of analysis of the facts. No reliable cost-benefit analysis is possible without this kind of factual foundation. The applicant and the state and federal agencies can provide useful information with which to commence the power supply and demand analysis, but under NEPA it is the AEC which must make the judgments and that can only be done on the basis of facts which have been independently analyzed. That is the teaching of Greene County Planning Board v. FPC, -F.2d-, 1595 3 ERC/(2d Cir. 1972). It is also the teaching of common sense. 122

IV. The Cost-benefit snalsis The cost-benefit analysis in the draft statement is remarkable for its lack of any coherent relationship to the analysis which proceeds it. The cost-benefit analysis is largely a summarj of the position taken by Con Edison and not that developed by the staff in its own analysis. This is true even at places where the earlier analysis of the draft statement differes markedly from Con Edison's analysis. Typically, in dealing with the fishery the applicant' s estimate of environmental cost of 0 fish/year is set forth and a paragraph of staff comment is follo-;ed by three pages of (DES, XI-23 to 27). quotation from Con Edison/ Since the staff analysis utterly disagrees with Con Edison's estimate it is difficult to see why any of the Con Edison statement is quoted. It is particu-larly distreesing that the staff supplies no estimate of its own of the environmental cost. In effect, the staff appears to have abandoned. its task of reaching an independent conclusion based on the analysis which it has undertaken. Throughout the cost-benefit chapter there is an ambiguity and confusion in the writing i.,hich indicates a fundamental uncertainty on the part of the staff as to what its task is. For instance the paragraphs on environmental costs which appear at DES, XI-18 to 28 repeatedly give the Con Edison's estimate of the environmental cost and follow.r it with an explanation or commentary from the staff. The tone consistently suggests that the staff feels that its task is to explicate the company's position or, at most, tinker with Con Edison's estimates. This 123

is entirely the wrong procedure. The cost-benefit analysis must grow out of the analysis of the impact of the plant which has been undertaken by the s/taff. Just as the analysis of the first ten chapters is an independent one which uses Con Edison information but does not treat it as having a special status of unquestionable veracity, so the cost-benefit discussion must also treat Con Edison's presentation as nothing more than useful. The cost-benefit analysis must flow out of the earlier analysis of the staff and not out of the Con Edison analysis, much of which the staff has discredited and dis-carded. There are a number of points at which the conclusions of the cost-benefit analysis misstate or ignore the basic analysis performed by the staff. One of the most shocking failures to integrate the cost-benefit analysis to the rest of the statement occurs in the discussion of the Indian Point 2 cooling system where the section on cost-benefit states: The staff's analysis of the effects of the present cooling system on the Hudson River indicates that the complex estuarine environment could be irreversibly damaaged from long-tern operation of Unit Uo. 2. The staffis analysis was appropriately conservative, in accord with the nature of the environmental risk, and may therefore overestimate the long-term cost. (DES, XI-55) The cooling system will, of course, have two major effects - the impingement and entrainment of fish. There is nothing to suggest that the broad and general statements on irmpingement are in any way conservative. The statement on entrainment is explicitly realistic (DES, A-69) and the analysis of compensatory factors and density-dependence probably un'ler-estimates the effect on the fish population considerably. 124

(See comments at I - B above). There is simply no basis for the conclusion that the staff analysis on the effects of Indian Point 2 on the Hudson biota is conservative. Contradictions of this sort between the factual analysis and the conclusions of the cost-benefit analysis must be rooted out in the final statement. The cost-benefit analysis must flow directly and coherently from the factual analysis. Finally, the cost-benefit analysis must take into account the fines for the killing of fish which the Attorney General of New York is now seeking from Con Edison and tlh likli-hood of the plant being ordered to cease operation if the fish kills continue. The question of fines for fish kills is discussed fully at I1D above. The staff must estimate the number of larvae, juveniles and adults v.hich will be killed annually at Indian Point 2 and figure into the cost-benefit analysis the fact that Con Edison is incurrring a liability of ten times as many dollars. In other words, if, say, 3 million larvae, juveniles and adults of any species are taken at Indian Point by the drawing off of water, Con Edison will be liable for fines of $30 million under the Conservation Law of the State of New York. This spring Con Edison was ordered by the New York State Department of Environmental Conservation to cease operation of its pumps at Indian Point 2, an order which remained in effect for at least 2 1/2 months and may not yet be dissolved. This order was based on the illegal fish kills which took place at Indian Point 2 in February. In estimating the possible 125

benefits from the plant, the staff must estimate the liklihood of similar orders in the future. In other words, if the staff believes that substantial fish kills will take place at Indian Point 2, it must include in its calculation of the benefits from the plant the liklihood that the plant will not be allowed to operate for substantial portions of the year. Con Edison is in an awkward position. It has obligations to provide power to its customers, but if it does so by killing Hudson River fish it makes itself liable for fines at the rate of $10 per fish and it courts the real possibility that the state will order the plant closed dowrn. The AEC cannot blind itself to these difficulties by pretending that the conservation laws of New York do not apply to Con Edison. The State Department of Environmental Conservation and the State Attorney General have made it clear that that is not the case. in weighing the costs and benefits of Indian. Point 2 the AEC must take full account of the vast costs which will be imposed on Con Edison if it continues to make the killing of fish a:part of the ordinary business of supplying power. Conclusion When a complete analysis of the impact of Indian Point 2 on the Hudson fishery is undertaken in the context of the other power plants on the River and with proper attention to the laws of the state of New York, the inevitable conclusion emerges that the Indian Point 2 plant can only operate if 126

closed cycle natural draft cooling towers are installed. The Hudson River Fishermen's Association urges the AEC to perform its duty under NEPA by carrying out the full analysis of the plant which is required by the Act, particularly covering the points spelled out in these comments, and at the end of that analysis *HRFA respectfully submits that the AEC should condition the operaticnof Indian Point 2 on the construction of an alternate cooling system, in particular natural draft closed-cycle cooling towers. 127

Natural Resources Defense Council, Inc. 36 WEST 44TH STREET NEW YORK, N.Y. 10036 212 986-8310 BOARD OF TRUSTEES Washington Office Stephen P. Duggan, Esq. 1600 TWENTIETH STREET, N.W. Chairman , WASHINGTON, D.C. 20009 Mrs. Louis Auchincloss Boris I. Rittker, Esq.  !,, /.t- , . 202 387--01855 John T. Ilooth Thomas Cashel, Esq. Dr. Rene J. Dubos Robert W. Gilmore Dr. Joshua Lederberg James Marshall, Esq. Ruby G. Martin, Esq. S John B. Oakes The Rev, Channing E. Phillips 5 Dr. Gifford B. Pinchot Charles A. Reich, Esq. John R. Robinson, Esq. Lauranct Rockefeller J. Willard Roosevelt August 22, 1972 David Sive, Esq. Dr. George M. Woodwell Edwin M. Zimmerman, Esq. John H. Adams, E*q. ExecutiveDirector Mr. Daniel R. Muller, Assistant Director for Environmental Projects Directorate of Licensing U. S. Atomic Energy Commission Washington, D. C. 20545 In re: Consolidated Edison (Indian Point 2) AEC Docket No. 50-247

Dear Mr. Muller:

I have received a copy of Con Edison's response to the comments of the Hudson River Fishermen's Association on the draft environmental impact statement on the Indian Point 2 facility. There are various inaccurate representations of the position taken by HRFA contained in the Con Edison docu-ment which I think are sufficiently obvious to go without comment at this time. I do, however, feel that it is necessary to comment on the contention that Bowline Point and Roseton are being given sufficient review by the Army Corps of Engineers to meet the terms of the National En-vironmental Policy Act. In February 1971, the Corps of Engineers circulated to other governmental agencies, but apparently not to the public, an environmental statement submitted to it by Orange and Rockland Utilities, the operator of the Bowline Point plant. No final environmental statement appears to have been issued. 128

Mr. Daniel R. Muller, Assistant Director for Environmental Projects Washington, D. C. 20545 August 22, 1972 This procedure, which substitutes the analysis 6f the applicant for that of the agency, is not adequate to meet the requirements of NEPA. The Federal Power Commission attempted the same abdication of its duties in considering an application from the Power Authority of the State of New York. The procedure was challenged by the Greene County Planning Board and condemned by the Second Circuit as failing to meet the requirements of the Act. Greene County Planning Board v. FPC, 3 ERC 1595, 1599-1600 (2d Cir. 1972). The Corps of Engineers has not even attempted this much with regard to the Roseton plant. It is equally important that the substantive material included in the Bowline Point reports is of a generalized and unquantified nature that falls far below the reasonable standard which the AEC showed itself striving toward in its draft impact statement on Indian Point 2. Examination of the statements by the AEC will rapidly make their weaknesses apparent and if the AEC staff has any inclination to rely on the material, I urge the staff to undertake'a thorough review of it. The fundamental point remains - the AEC must look at the particular receiving environment in which the Indian Point 2 facility will be placed. This requires that the Commission consider the present and the reasonably foreseeable effects on the estuary which are being or will be caused by other installations. Any other course fails to analyse the impact on the environment as it in fact is and will be. Finally, as a general matter, I think it is impera-tive that the Commission adopt a procedure which will allow all parties to a licensing proceeding equal opportunity to respond to thp comments which are submitted on a draft environ-mental impact statement. The counsel for the Regulatory Staff has made the comments in this proceeding available to me from time to time, but that is not a sufficient substitute for a regular communication which provides equal access to documents for all the parties to the proceeding and thus assures that the views of all parties will be fairly represented to the AEC staff. 123 Yous sincerb*l aceth Attorney for Hudson River AM/sD .... w Fishermen's Association

BEFORE THE UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION In the Matter of

                                 )

CONSOLIDATED EDISON CO. ) Docket No. 50-247 OF NEW YORK (Indian Point, Unit No. 2) COMýMENTS ON DRAFT DETAILED STATEMENT ON THE ENVIRONMENTAL CONSIDERATIONS RELATED TO TIlE PROPOSED ISSUANCE OF AN OPERATING LICENSE TO THE

           'CONSOLIDATED EDISON COMPANY OF NEW YORK FOR THE INDIAN POINT UNIT NUMBER TWO NUCLEAR GENERATING PLANT We adopt the comments on the Draft Detailed Statement         on the Environmental Considerations      submitted by the Hudson River Fisherman's Association.

Respectfully submitted,

                                      -                    7..-.,.

Gladys Kessler Counsel for Citizens Committee for the Protection of the Environment June 2, 1972 130

B13trLINi. ROISMAN AND HICSSL,,ER 1712 N STREET. NORTHWEST WASHINGTON. 0. C. 20036 EDWARD BERLIN AREA CODE 202 ANTHONY Z. ROISMAN PHONE 833-9070 GLADYS KESSLIMR DAVID R. CASHPAN KARIN P. SHELDON June 8,1972 Samuel W. Jensch,Esq. Chairman Atomic Safety and Licensing Board U.S. Atomic Energy Commission Washington, D.C. 20545 In the Matter of: Indian Point,

Dear Mr. Jensch:

Unit No. 2,Docket No. 50-247 The statement of intent to adopt the comments on environmental considerations prepared by the Hudson River Fisherman's Association which was submitted on June 2, 1972 by Gladys Kessler mistakenly noted Ms. Kessler as Counsel for the Citizens Committee for the Protection of the Environment. This should be corrected to read Counsel for the Environmental Defense Fund. Sincerely, Karin P. Sheldon KPS/pq c.c. All parties of record 131

BEFORE THE UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION In the Matter of ) No. 50-247 CONSOLIDATED EDISON COMPANY ) OF NEW YORK (Indian Point, Unit No. 2) ) CITIZENS COMMITTEE FOR THE PROTECTION OF THE ENVIRONMENT COMMENTS ON DRAFT ENVIRONM.ENTAL IMPACT STATEMENT As previously indicated in CCPE's brief in support of 4 2 ), its Proposed Findings of Fact and Conclusions of Law (pp.140-1 the AEC has erroneously interpreted NEPA by providing for an evaluation of radiological risks using standards that differ from those applied to the safety review. This results in "stacking the deck" in favor of the license without adequately considering the adverse consequences of an accident. We incorporate herein by reference the comments on pp.140-142 of our Proposed Findings of Fact and Conclusions of Law. The error is compounded by the fact that the Staff utilizes compliance with the ECCS interim criteria as evidence that in the event of a LOCA, doses to the public will be low. The facts as revealed in the pending National'ECCS hearing are to the contrary. Certainly thq impact statement should include 132

2 the views of those experts who differ with the Staff view with respect to the effectiveness of the ECCS system for this plant (Committce for Nuclear Responsibility v. Seaborg, F. 2d (CA D.C., 1971) 3 ERC 1126) and should explain the. basis for their conclusion regarding the level of risk and the radio-activity predicted for each accident, particularly the class 8 loss of coolant accident. Failure to correct these defects leaves the impact state-ment incomplete and legally deficient. Respectfully submitted,

                               ý.nthony Z. Roisman BERLIN, ROISIMAN XAD KESSLER 1712 N Street, i1.W.

Washirgton,. D. C. Counsel for the Citizens Cortmittee for the Protection of the Environment 133 June 21, 1972

DOCKET NUMBER 2iR0D. & 1~1L.f£C.S2q 7 Scenic Hudson Preservation Conference 500 Firm AvE.NuE, SurrE 1625 0 NEw Yong, N.Y. 10036 0 212 OXr-oR 5-6204 Officers and Executive Board June 12, 1972 Carl Carmer, Honorary Chairman Alexander Saunders, Chairman Mrs. Willis Reese, Co-Chairman Robert I. Boyle, Vice-Chairman M"rs. Stephen P. Duggan, Vice-Chairman Benjnamin W. Frazier, Vice-Chairman David Sire, Vice-Chairman Richard D. deRham, Treasurer

   ,Mrs. Carl S. Rowe, Secretary          Atomic     Energy Commission Mrs. Terry Rotola, Executive Secretary 1717 H.       Street, N.W.

Stephen P. Duggan Washl.ington, D.C. W. Barton Eddison James R. Hamilton Richard H1. Pough Matter of Consolidated Edison Mrs. JamesJ. Rorimer Company Indian Point Plant No. 2 Miss Helen Lee Sherwood Chauncey Stillman Docket No. 50-247 Esty Stowell Statement of Scenic Hudson Pre-Mrs. Charles E. Tilton Rod Vandivert, Environmental Consultant servation Conference Advisory Committee Peter Blake This statement is submitted by Scenic Hudson Preserva-Dr. Walt-er S. Boardman tion Conference in connection with the current Atomic Safety Jacqu:s Ch. Boutinon

  \Irs. Marcella Brett                    and Licensing Board proceedings relating to Consolidated Edison Mrs. Jane Burdick                       Company's proposed Indian Point No. 2 nuclear power station.

James -gney - Chari . Callison The,'statement is submitted because Scenic Hudson's name has ap-Mrs. Juan K. Davidson parently been interjected into the proceedings in a fashion Mrs. J. Dennis Delafield Charles Eggert which does not accurately reflect its views. Robert A. Fox Mrs. Benjamin W. Frazier Mrs. P. Dana Gibson As is well known, Scenic Hudson has long been concerned Mrs. Eliot D. Hawkins with the environment and ecology of the Hudson River. In this Dr. & .Mrs. Albert R. Lamb, Jr. irving Like connection, it has been especially concerned with (1) the scenic Mrs. Cyrus McCormick values of the Hudson, particularly as it flows through the High-Harry F. Nees Charles P. Noyes III lands a few miles north of Indian Point, and (2) the impact of Stewart M. Ogilvy power plants and other industrial installations on the fisheries Mrs. Antonio G. Olivibri NMrs..Stanley Plowden resources and general water quality of the River. These are the

• R. WVatsonPomeroy areas of Scbnic Hudson's expertise, and they define the scope of Mrs. Robert L. Reed Mrs. John R. Reese this statement. As to matters of nuclear safety, radioactive re-Mrs. John Reurs leases and the handling of radioactive wastes, Scenic Hudson has Mrs. Nathaniel Roe Mrs. Raymond A. Ruge no special knowledge; and it neither endorses nor opposes the Mrs. Alexander Saunders Indian Point plant on thp basis of such consideration.

Richard B. Sichel Cornelia Otis Skinner Mrs. Esty Stowell Scenic Hudson is, however, deeply concerned by the Lonasdale F. Stowell Mkis Helen Thompson potential impact of the plant on the River's fisheries. In this Maxwell C. Wheat, Jr. regard, we point out that the Hudson has been and remains a highly productive estuary, supporting from 35 to 50 species of fish and the necessary food chain and habitat to make these species viable. 134-

                                                ":*"*.,                     ?      .:  .:
                                                                  ;ib - ...    ..
                                                                              -..                            t,

Atomic Energy Commission June 12, 1972 Within the entire range of fisheries, each species has both commercial and recreational importance in that each is part of a complex and interrelated biological system which supports fish for Hudson River sportsmen and for sport and commercial fisheries in offshore waters for several surrounding states, each with an important marine economy. Any serious damage to the fishery can be the basis of permanent and irrevo-cable damage to the River and a broad segment of the population. of the. Middle Atlantic region, relying on the estuary or its productivity for recreation or for income. Our concern over the Indian Point plants stems from the fact that the waters of the Hudson are or will be drawn upon for cooling purposes, and that the intake of water, combined with mechanical abrasion and thermal discharges, appears to threaten the River's fisheries with major damage. We understand, for example, that with the open cooling system that it utilizes Indian Point No. 1 draws up to 300,000 gallons per minute of River water for cooling, and further, that approximately 840,000 gallons per minute would be drawn by Indian Point No. 2, Utilizing a similar open cooling system. Recent history inthe testing of Indian Point No. 2, and the continuing problem re-lated to fish kills at Indian Point No. i, indicate that these withdrawals alone can be regarded as a major threat to marine life in the Hudson -- and an unnecessary threat since closed-cycle cooling is possible in today's tech-nology. The problems of the past in the operation of the Indian Point No. I plant have at times been related to thermal effects, and the most recent fish kills at Indian Point No. 2 have been attributed to mechanical problems having to do with intake. The numbers of fish killed or subject to future kills have been thoroughly covered by the Hudson River Fishermen's Association and the Atomic Energy Commission staff report. The net effect forecast by both as a result of the operation of the Indian Point No. 2 represents a serious loss to the fisheries of the Hudson. Contrary to the statements issuec by Con Edison regarding size, species and survival, the mortality is important in that each marine organism is either a predator or a food for a predator -- hence part of the cycle which cannot reasonably be sacrificed; nor can it be reasonably tolerated in the face of an alternative method of cooling that is clearly available. This alternative method of cooling is, of course, closed cycle cooling. As applied to Indian Point, this would probably involve cooling towers; and it is in this connection that Scenic Hudson's name has apparently been interjected into the proceeding -- it being suggested that we would never stand for cooling towers on the grounds of esthetic objections. This mis-represents our position. Scenic Hudson is deeply concerned with scenic valbes along the Hud-son and, as such, it vigorously opposes the use of cooling towers (and, for that matter, the construction of power plants altogether), where special scenic qualities are involved. But Indian Point, as it presently stands is not such a case. The site has already been despoiled by Indian Point No. 1 unit and 135

Atomic Energy Commission June 12, 1972 its high stack; by the completed plant structures of Indian Point No. 2; by the hulk of Indian Point No. 3 as it nears completion; by the huge towers and supported wires which cross the Hudson at this point; and by the general maze of transmission towers and wires which serve as a back drop for the plants. Under the foregoing circumstances, the addition of cooling towers at Indian Point, while no esthetic enhancement, will hardly re-sult in ir-revocable scenic damage since the damage has already been-done by the vast industrial complex which already exists there. On the other hand, the ad-dition of cooling towers and a closed cycle cooling system would provide at least some protection for the fisheries of the Hudson and, as a consequence, and under the circumstances described, is clearly to be preferred to the open cycle system currently proposed by Con Edison. We do not mean to suggest, however, that cooling towers and closed cycle cooling are a complete.answer to the dangers threatened to the fish-eries. In this regard, it is our belief that any analysis of the damage to fisheries resources must be related in measurement to the operation of all plants now existing or under construction within the spawning and nursery areas of striped bass and other Hudson River fish, Furthermore, there are many other users of Hudson River water within immediate and "jearby areas. No meaningful evaluation can be drawn without a consideration of the impact on the entire Hudson River fishery of the total of its water users. Single project or plant projections tend to be totally self-serving for the applicant or for the licensing agency and can in no way indicate the point at which the River will be unable to support a continuing and surviving production. Equally unsatisfactory is any offer to produce a hatchery to re-place mortalities since many of the species subject to impingement or thermal effect have never been successfully produced under controlled conditions; and certainly there is no history of success in the replacement of these species in an estuarine environment. Therefore, any such offer, no matter how sincerely made, must be considered simply good public relations. Respectfully submitted SCENIC HUDSON PRESERVATION CONIFERENCE 500 Fifth Avenue, Suite 1625 New York, New York 10036

                                                /u/

1By: Mrs. Theresa Rotola Executive Secretary

N"

                                                -NL--@1             *'

Committee 1o End Radiological Hazards "/ Mary Hays Weik Secretary 166 Second Avenue CCeGR 7-5935 New York, New York 10003 Director, Division of Radiological Res Invited Citizens' Comments on the and Environmental Protection Environmental Impact of the Propos U.S. Atomic Energy CorLission Issuance of an AEC Operating Licen Washington, D.C. 2M545 - May 19,1972,-- to Con-Ed's Indian Pt.Nucloar Reaci Dear Sir s DeaaSirsDOCKET X0.50-24' I. -hank you for sending at.my request the AEC's "Draft Detailed Statement" prepared by your department on the subject named above. It is obvious that such a rope from an independent agency having no connection, actual or implied, with the Atomic Energy Commission - which itself both sited and regulates the project concerned - woul have been more convincing. Our comments on the Statement's contents follows In issuing this evaluation of the environmental impact of a proposed second nuclear reactor at Indian Point, the U.S.Atomic Energy Commission has placed on the public rec an amazing collection of irrelevant, useless,and deliberately confusing items, which do little to throw any light on the situation involvedi

1) Its concern for the fate of Hudson River fish entirely overshadows any concern foj the area's human residents. While infinite details are given on the reactions of various aquatic organisms - the "thermal tolerance" of macroinvertebrates, the

      'reproductive habits of zooplankton species," etc., etc. - no reference is made t6 the alarming mortality record found among residents of nearby local communities directly downwind to the plant, as shown.)in local statistics         of the region recordo in the enclosed Chart of Deaths from Brain & Breast Cancers and Leukemia- foundi*

the same "Cortlandt Towi',area bofore arn after the nu*leoar plant was built. CA

2) The Report's figures on "low-level" radioactive releases from the plant are of little significance, since it ignores completely the well-known facts on cerious internal damage by "contact radiation" from chronic low-level doses ingested or inhaled, as pointed out on the enclosed page of comments by the Viennese physicist Dr. Karl Nowak. Those omitted facts make the Report's alleged '.Wninimal and harmles, plant releases, both deceptive and absurde

3) Since the "radiation limits" permitted in the Indian Point area by the AEC's "lGCFR0O" and I"10CFR00" standards are fantastically high (44,000 curios a day, 16 million curies a year, a possible 3,000 rads in individual tt oid doses, as cited in the AEC's "Initial Docision" on the 1969 Construction Permit for Indian Point 3), even the "low percentages" of those Limits presently alleged in use in the Draft Environnental Statoment would be themselves quite substantial and damagi (I doubt that the Thousands of dead fish found in a-recent Indian Point "fish kill actually needilthe "impingement" on metal screening grates to finish them offl)

4) It seems obvious that the alarming escalation shown almost a year ago on the enclosed sheet of official mortality records for the surrounding Cortlardt Town region, demands - far from a now permit for operation of an additional second Nucle Plant, 4 times larger than Indian Point I - an irmediate shutdown of all Indian Po nucleax ficilities, t.*ith the '*---,ntli and cntzrb=-nt" o& this de y c=nt-*iin-ated instaihaiion doscribod on pages V-75 and V-76 of your Draft Report,. to prever a problem of unprecedented disaster for populations of this area for centuries to c, Surely there must be a better way of reclaiming a wasteful and ruinous investment in nuclear power than by ki.ling off the helpless citizens of the Indian Point area%

CopmIs To OTHR mTER ?ATis JA-L Sincerely, Mary Hays We

THE YORKTOWNEk, ,it., PTEMZ..R*B, 8, 1971 r, . , ,. . . 8 1 li E __ Th~ Committee Chief Note Spurt In Mortality by Mary Hays Weik Near Nuclear Plant A significant new report has just been issued by show that 3 out of the 4 brain cancer deaths reported the CommitteeT2_EZId_-E.-adiQloaical Hazards of Nc:,ý in 1903-67 for this Cortlandt area of 22,000 wp-e York City, on health conditions around the Indian Point actually registered from the Montrose section I de-atbmic plant. The report shows percentage of increase scribed in "The Montrose Catastrophe" - population, in death, by Brain and Breast Cancers and Leukemia less than 50U! in the Cortlandt Town area directly surrounding the Unfortunatel e who prepared the delusive beeVlt' atomic plant, during the S years 1963-67, after the State report mane one false step: In making thei: plant began to operate in August '62, as compared with report, they revealed local statistics not available the .S years, 1957-61, just before its start. Included to the general public or reported in "U. S. Vital population figures for 1960 and 1965 show that cancer Statistics" (because the communities involved are increase has far outstripped population growth. too small for individual mention). In other words, The report is based on figures contained in the the report brought into the open statistics heretofore N.Y. State Health Dept. report, "Review of Mortality available only to the two Health Departments. These Statistics In the Northwestern Section of Westchester ,figures happen to be most significant. County." The State report is a curious document. It was published shortly after this writer revealed, as The cancer deaths shown in the New York com-a citizen intervenor at the 1969 Indian Point Hearing rnittee's statement (taken from Tables VII and Table an unusual number of Cancer Deaths in an area of VII A of the State "Review of N W Westchester Montrose downwind to the atomic plant. The State County" cited above) though damning as evidence, report shows an obvious intention to confuse and mis- would apar to be small in number. They will lead the public; for the local map it includes so certainly be labeled as such and called "unimportant" confuses the boundaries of the area invo&ved in the by AEC and Con-Edison attorneys. But this is far Montrose cancer deaths as to make difficulta localized from true, as any honest statistician knows. For: study of the problem. 1) By the State figures, Peekskill, Buchanan, and Neither Staft, nor County Health Department seems Croton-on-Hudson are now implicated in the Indian -worried by the situation shown by their own figures. Point cancer problem. (What about other - unnamed - I was surpried to receive a "personal copy" of the Weschester communities?) report kfom State Commissioner of Health Dr. HOLLIS 2) In 11 out of 12 community situations named, an S. INGUAHAM, who had refused to honor my citizen's unbroken increase of cancer deaths is shown. In the subpoena to testify at the 1969 Indian Point Hearings. 12th, Peekskill, the number oJ brain cancers remained In a, letter to the AEC sent me with the report, Dr. the same in the two periods covered. Yet, even Ingraham said: "We find no evidence of increase in.. there, unreported 1968-71 figures may now have cancer mortality in the vicinity of Indian Point;" changed the picture. and DR. DONALD R. REED, President of the West-chester County Board of Health, in a letter to a local 3) If such an 'increase could occtu. with only the citizen listing figures which amounted to an.incr'ase 265-megawatt Indian Point I reactor in operation of 221 in MONTROSE and an increase of 150' in what would result with the addition of the 873-meg. BUCHANAN, wrote : "These figures would indicate Reactor 11-4 times as large as Indian Point I? to me that the cancer deaths have not increased in the 4) If such an increase could occur with only villages of Buchanan or Montrose(W)." Indian Point I's"Pressurized Watei0265-n'g. reactor, imagine the effect of adding, as planned, Ri~actors [11, The latest (1971) Rand-McNally Commercial Atlas IV and V (of 1100-meg, each) all oi:'ciing WVarcr" shows Montrose population as 2200. But tlhe State typL - since airborne radioactive releases from this report cited submerges the Montrose village igure in type of reactor are known to be enormously larger.. a vague total, numbering 22,000, called the "Rest of What will be the effect downwind then? Cortlandt Town." (Tnis greatly dilutes, of course, the Montrose cancer moi~alities.) Yet local recc'ds - Copyright 1971, Mary H. Welk-138

CANCER DEATH RECORD IN "CORTWLAMX TOWN" AREA SU 0UNDING INIAN POINT, NYIATOMIC PLANT, BEFORE & AFMER PAINT'S START IN I962 From Official Mortality Statistics in 1959 Nsw York State Dept. of Health Publication, Review of Moirt.lity St-.tistic- in ...... Sct Q*tih on of W,'stchest-r County - TabIc3VI1&A: "Number of Deaths (Brain and Lreast Cancers & Lc'.kcnia) for Cortlar;dt Town (Including) Poekskill City, 1957 - 1967"1** A r e a s CANCER of BRAIN BREAST CANCER LEUKEMIA P o p u 1 a t i o n and N3rvous System (193)jIHO International Code 170 (Internatioral Code 204)

                            ý57-'61 '63-'67 % Incroase     '57-'61 '63-'67 P"Increase    q7-'61 '63-'67 % Increase      1960     1965     Increase lPýksidll                      4        4                      20        25     25 %        4       10        150 %     18,737   3,*1*h.ol.drop) 6        6 Croton-on-Hudson                -      6        600 %          7        10     43 %        3        6         100 %       ,812     ,94J3I1-: 2%

Buchanan __- 1 100 % - 2 200 % 1 100 % 2,019 2,16S 7% Rost of Cortlardt Tour *

               -          ,    -       4

• 400 % 4 12 200 % 2 5 150 % :17,505 22,23 1 " 27%

 )TOTALCortlandt Town          4      15        275 %         31      49       58%         9       22          44I%. 45,07349,844"             1%

• Three of these 4 doaths w-re recorded for a small section (c. 500 population) of 11ONTROSE dixez*t:y dowrrwind to the Indian Point atomnic plant.

F" ** MO*TPOSE total population was on2y 2200 in 1970 (Rand NMoNdly 1971 Coimiercial Atlas & Marketi!E Guide). CD

• Conclusions issued by State ard Co£nv Realth Ponerds are in curious contradiction to thoir own recoids In slite of t ho incicasos s~hoi in thN,eYSt1/2t 7--th > Dt, figures reported above, State Hnalt.t Con-.

r H JS S. ri.ýýJ in his jaron-A o:GR'A, on 2ntt-r to the U.S.Atorc Bnergy Coz"dsion of F-ch 23, 1970 nccompanyirn tho abcove report, sazids "1h find no evid-nrze of an irnreaso in .

• cancer morta]ity in the vicinity of Indian Point;" ard Dr. DOI-L D R. REED, President of the W-stohester County Board of H-nlth, in a Mareh 18, 1970 letter ans*. ring a loczl citizen's intwuiry, in which Dr. RI-D himself cited a rise in All Caneor Death figumres in tho 4 yo--s:f;hr Indian Point's start (1963-1966) dhich, compared to tho 4 years prz;codira its start (1958-1961),a uiz*d to an inlrotaso of 22% in MONTROSE and an inorcsac of 15:% in BUCMU^N, wrote: "eose figures would indicate to wc that the cancer deaths have not increased in the villagos of Buchanan or Ybntrose (C).".

GCopyright 1971, Mar'y H. kbik

14,

                                             .1 "~rs~'.

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                                                        '4ý6el L)f cancer cajes
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B I L I N G UA L FROM: Committee To End. Radiological Hazards 166 Second Avenue, New YorkJf 10003,USA Q U 0 T E S Mary Hays Weik, Secretary (CIR 7-5935) ATOMIC PLANT RELEASES CANTNOT BE FAIRLY COPAIRED TO NATLRA-L BACKGRONO ROADIATION (English translation) .

"A nuclear power plant releases radioactivity to its environment through its chimney and cooling-water. i~en in undisturbed normal operation, the chimnrey emits radioactive gases and particulate matter which are distributed through the surroundings.
"Company 'experts' claim that the amount released is. minimal.          They calculate high piantreleases by comparing them with natural background radiation.            Actually, the effect of radioactive material taken into the body, as is that from the plant's chimney and cooling-water, through inhalation, or by way of the food chain and drinking-water, is significantly higher (than company figures show),and impossible to measure exactly.
 "If a (radioactive) particle merely lies on the ground, then its effect is minimal al-though its radiation may be dangerously high. If the particle, however, is deposited on a mucous membrane by inhalation or ingestion, or if it settles in an organ due to its chemical nature, then as a result of contact radiation. its effect will be increas-ed to the square of its ownvaaue and give an Extr-aorinar Ty strong dose of radiation to its direct surroundings, leading to death of the cells contacted or severe damage to those it touches.
 '!Especially effective in this connection are Alpha and Beta rays, whose effect would otherwise be screened out by the atmosphere.         These inner effects cannot be controlled from without.      Thus numbers of Cancers and 6ther damages can arise; above all,           genetic damage and d'c         if the reproductive organs are affected.      Moreover, this radioactive matter--storeo    up in the body increases with time, and the damages build up .           .   ."

(From. Der Skandal Atomkraftwerk by Ing.-'KAL -NOWK Vienna physicist and editor of 1iNoue Physik", in an article in ,,1ber~sterreich. Wochenpost," Austria) (Original- Goi'ran) i

    ,Ein Kernkraftwerk gibt "ulber Schornstein und K01hlwasser Radioaktivitgt an die Umgeb-ung ab. Der Schornstein auch im ungest'rten       Normalbetrieb laufend radioaktive Gase und Schwebstoffe ausst)szt und in der Umgebung verteilt.

'iVon den bezahlten Experten' wird es so dargestellt, als soi das minimal. Ian rechnet mit der erhjhten Umgebungsstrahlung und vergleicht sic mit der nat-Erlichen Strahlenbe-lastung. Tats-!chlich ist die Wirkung in- radioaktiver Stoffe, wie sol"he aus Schornstein und lO!Ihlwasser "!1ber Atomluft, Iahringskette und Trinkwa-asser in don K6rper gelangen, ganz bedeutend h6her und nicht exakt messbar.

 ,lLiegt ein Staubk6rnchen am Boden, so ist seine Wirkung minimal, mag es auch ein gefkhr-licher starker Strahler sein. Gelangt das Teilchen aber mit Atomluft oder Nahrung auf eine Schleimhaut odor wird es gar infolge seiner chemischen Beschaffenheit in ein Organ eingelagert so kann es infolge Kontaktbestrah.lunu, da die Wirkung mit dem abnehm-enden Abstand quadratisch zuninmt, an seine ur*itte.Cb-are Umgebung auszorordentlich starke Strahlungsdosen abgeben und so sogar zu Nekrose (Zelltod) odor schweren Zell-schiden AnLasz geben.

viBesonders wirksam sind dabei Alpha- und Betastrahler, deren Wirkung sonst durch die liuft abgeschirmt wird. Diese inneren Vorgi1nge sind von auszen i-Uerhaupt nicht kontroll-ierbar. So klnnen Krebsherde und andere Sch!digungen entstehen, vor allem auch Erbschgd-on und Erbkrankheiten, soweit die Fortpflanzungsorgane beeinfluszt werden. Auch speich-ern sich radioaktive Stoffe im Kirper und die Sch-!digungen summieren sich . 141

COMMITEES: J0bATHAN B. BINGHAM 2*o D,*RIL,. New YORK FOREIGN AFFAIRS HOUSE ADMINISTRATION (g WASHNGTN ~ OFICE ~ 4~~ 7I~*tfd~I1 C~A.E4.~I~DISTRICT OFFICE, 33 ANNON HOUSE OFFICE BUILDIN ONE FAST FORDHAM ROAD TELEPHONE: (202) 225-4411 BRONX NEWE YORK W 0468 R. ROGER MAJAK n

                                             . ouge of S

eprezentatiI1Z TE..O. (21) WE 3,o ADMINISTRATIVE ASSISANT ahington, D.C. 20515 May 30, 19,72 U.S. Atomic Energy Commission 1717 H Street, N. W. Washington, D. C. In re: Consolidated Edison Company of New York, Inc. (Indian Point Unit No. 2) Docket No. 50-247 Gentlemen: As a Congressman representing a district which lies within the Consolidated Edison service area as well as being adjacent to the Hudson River, I am writing to comment on the Commission's draft NEPA statement on Indian Point 2 as it relates to an important environmental issue - the protection and enhancement of the natural aquatic life of the Hudson. The state of New York has sought to protect its fisheries by legislation, imposing a $10 civil penalty for the taking of fish by the drawing off of water. Recently the Attorney General of New York filed suit against Con Edison for $1.6-million for fish killed at Indian Point 2. This is the second major legal action which the Attorney General has launched in the effort to protect fish at the Indian Point site. These are important actions, but the answer to fish protection does not lie in fines and damage actions. They do nothing to im-prove the Hudson fishery and if the sums are in any way passed on to the consumers they will increase electrical bills with little direct gain to the River or the people of New York. A very important part of the real work of protecting the great and productive fishery of the Hudson lies with the AEC. In these circumstances I was shocked to read in the draft statement that the annual loss of striped bass "may be as high as 15% to 20% from the direct effects of Plant operation." Similar figures would hold true for other fish species as well. Fish destruction of this magnitude - or anything close to it - is an unacceptable assault on both the fishery and the general environment of the Hudson. If these kills are accompanied by fines levied by the State, the situation will also be intoler-able for the citizens of New York City whose electrical bills are decided by the fate of Co Q dison. Rec'i (Y{. Lit. udi i% Da'e 41/6/Date Time____ THIS STATIONERY PRINTED ON PAPER MADE WITH RECYCLED FIBERS

Environmentally, the situation will also be made worse when the Bowline Point and Roseton plants go on line in the course of the next two years. The draft statement does not address itself to these plants. I consider this a major flaw in the statement. Those plants will have an effect on the Hudson similar to that of the Indian Point plant. It is impossible to judge fully the damage on the River unless we see Indian Point 2 as part of the total array of plants which will be operating on the Hudson in the course of the next few years. It was precisely to produce analyses of this sort that the Congress passed the National Environmental Policy Act. As part of its duty under the Act, the Commission should con-sider the full impact of the power plants now under construc-tion on the Hudson. From the draft statement, it appears that the only solution to the fish kill problem will be an alternate cooling system. This may be expensive, but it has the clear advantage that money spent would actually go toward the protection of the Hudson fishery and would not be drained away in law suits with their consequent fines and damages. Yours sincerely, Jonathan B. Bingham JBB:AJD 14'~3

e niteb akateg fontre Rouae of 31epressentatibeg% M-40ington, ýD.C. 20515 June 1, 1972 U. S. Atomic Energy Commission 1717 H Street, N. W. Washington, D. C. 20545 Re: Consolidated Edison Company of New York Inc. (Indian Point Unit No. 2) Docket No. 50-247 Gentlemen: As a Congressman representing a District which lies along the Hudson River, I am writing to comment on the AEC's draft environmental impact statement on Indian Point No. 2. I was shocked to see that the annual loss of striped bass "may be as high as 15% to 20% from direct effects of plant operation." These figures become more startling when the draft points out that they will apply to other fish as well as the striped bass. Losses of fish from the Hudson of this magnitude are simply unacceptable. The Hudson is a great estuarine fishery. It is invaluable for the recreational pleasure which it gives to the millions who live along its banks. It has great commercial value as the spawning and nursery ground for fish, most particularly the striped bass, which populate Long Island Sound, and the Atlantic waters from Montauk to Cape May. All government agencies must make every effort to maintain and enhance that fishery. I am also perturbed that the draft statement gives only a partial picture of the situation in the Hudson. The AEC when writing impact statements must take into account the entire environment on which the proposed plant will have an effect. This was clearly the intent of Congress in passing 'the National Environmental Policy Act: each project is to be. analyzed in terms of the particular environment on which it will have an impact. 144

In the case of Indian Point No. 2, this requires an analysis of the other plants which will be operating on the River' in the next two years -- Bowline Point and Roseton. These plants will also withdraw large quantities of water from the Hudson -- hundreds of tliousands of gallons a minute and heat it substantially before discharging it again into the River. This will add to the devastating effect on the Hudson fishery which the draft environmental statement foresees at Indian Point. If the AEC fails to consider these effects it will be doing a disservice to the public as well as failing to address a major threat to the Hudson River in coherent and common sense terms. How can we talk about Indian Point No. 2 as if the other plants did not exist? It seems to me inevitable that Con Edison will be required to build cooling towers at Indian Point. We must accept that as the price for saving the Hudson and its fishery. The alternative is to treat one of the great rivers of America as a cooling sluice for a utility and in the process sacrifice the vast natural resource of the Hudson's aquatic life. That is not an acceptable solution. I urge the AEC to require that Con Edison install cooling towers on the fastest practicable scheduled. Moreover, it is important that such towers be constructed with silhouette as low as possible so that we do not have more towers in the environs of the Hudson Highlands that break the horizon line. Everyone is concerned to see that we protect the environment as well as provide power. It is imperative that the AEC pursue its environmental mandate with the same vigor with which it has promoted nuclear power. Sincerely, JOHN G. ýDOW Meimber of Congress JGD:kjs 145

DOCKET NUMBER t.- . WILLIAM F. RYAN 303 CANNON IuIIN . 20TH DISTRICT. NEW YORK ERO D. &UIIL. Ea1. JJWASHINGTON. D.C. 20515 225-4616 COMMITTEES: JUDICIARY A 378TRICT

                                                                                                   .      ROwA..

INTERIOR AND INSULAR AFFAIRS (AT 157TH STREET) 3ýluze of Vepwentatibeg03-60 NEW YORK. New YORK 10032

                                                *[n*n*1n,    .C.20515 May 31, 1972 The Honorable W. B. McCool Secretary of the Commission Atomic Energy Commission 1717 H Street, NW`

Washington, D.C. 20545 Re: Consolidated Edison Company of New York Indian Point Unit No. 2 Nuclear Generating Plant Docket No. 50-247

Dear Mr. McCool:

I wish to stibmit this statement as a protest to the Atomic Energy Commission's "Draft Detailed Statement on the Environmental Consider-ations Related to the Proposed Issuance of an Operating License to the Consolidated Edison Company of New York for the Indian Point Unit. No. 2 Nuclear Generating Plant, Docket No. 50-247." I request that this study be reevaluated on the" basis of the following points:

1. that the possibility of a substantially harmful impact on the fish in the area needs further study;

2. that such a study should not be conducted by Consolidated Edison on the basis of a conflict of interest;

3. that guidelines be drawn upon which to base such a study;

4. that the potential for Closed Cycle Natural Draft Cooling Towers at Indian Point No. 2 should not be dismissed without a more complete study as to its long run cost-benefit relationship as compared to the present plans.

Mr. McCool May 31, 1972 I feel that without reconsideration of these points the Commission will have failed to provide adequate, effective protection to the Hudson River environment and could result in higher costs, physically and financially, than alternate designs proposed. With kindest regards. Sincerely, Member of Coýg~ress WFR/jgsp

                                         '147

DOCKET NLJMRF*

 /K,                                                  EM a0DD. &,UT1Lj. t 63 WALL STREET NEW YORK
              ~ ,CZJune               1, 1972 Atomic Energy Commission 1717 H Street, N.W.

Washington, D. C. 20545 Re: Petition of Consolidated Edison Company of New York to allow operation of its Indian Point Number 2 facility. Docket No. 50-247

Dear Sirs:

This letter of comment respecting the above facility ig submitted in response to your request for coniments and in my capacity as the Democratic nominee for Representative in Congress from the new 25th Congressional District of New York in which the above facility is situated. The above application should be denied subject to the condition that it be reconsidered upon Consolidated Edison's undertaking to install and operate appropriate facilities to cool its cooling waters prior to returning them to the Hudson River and to minimize the quantity of these waters to be returned to the Hudson. This action should be taken because: (1) The immediate licensing of this facility will not solve any imperative power needs; (2) The proposed thermal discharges pose a serious threat to the quality of the Hudson and to its water life; (3) Inadequate consideration has been given to the impact upon the quality of the Hudson and upon its water life of the proposed discharge and other existin thermal discharges into the Hudson; and 14

Atomic Energy Commission June 1, 1972 Page Two (4) Appropriate cooling facilities can be installed without violating reasonable esthetic standards and without undue expense. (1) The immediate licensing of this facility will not solve any imperative power needs. Consolidated Edison's proposed testing schedule indicates that it does not intend to use this facility to provide power during the summer of 1972. Since Consolidated Edison now has a 35% reserve capacity over anticipated winter peak load, there is no urgent need to operate this facility before adequate con-sideration has been given to the threats posed to the Hudson by its proposed-operation. (2) The proposed thermal discharges pose a serious threat to the quality of the Hudson and to its water life. The proposed facility will withdraw from the Hudson between one-half million and one million gallons of water per minute, heat it approximately 15'F, and discharge it into the Hudson. The discharge of this heated water will remove substantial dissolved oxygen and may cause increased evaporation leading to sedimentation. This thermal discharge will diminish the capacity of the Hudson to assimilate other wastes presently discharged in undue quantities into the Hudson and increase the toxic effects of pollutants presently in these waters. The thermal discharge will have the effect of altering diet, reproductive activities, disease resistance, migration patterns and other considerations affecting the life cycle of the various species of fish now found in abundance in the Hudson. The effect may be to wipe out entire species of fish. 149

Atomic Energy Commission Jura,~ I , 11!72 Paey Three Even fish species which. adjust to the new

 .emn-peratures of the Hudson to be created by the inteanded thermal discharge can be destroyed in the event that a failure of operation of this facility resýIts in a sudden dec_-ease in water temperature.

Moreover, it is to be anticipated that sIustantial numbers of fish will be entrained and kiiled upon screening equipment during dh- intake vwater from the Hudson by. this facility; During one-t day last February, approximately 150,000

.rh were killed when just two :of the six propcsed c> t this facility were put through a test run.

  *.::._..               scientists csimate that the ope:-,tion ofi          acility       may destroy 25% of the fisli in e hi.dson per year.                        If such destruction continues re number o-," years at this annual rate, it is obvious that the number of fish in the Hudson would qu;*chy approach zero.

(3) Inadequate consideration has been

       .ven     to the impact upon the quality of the 'Hudson its water life of the proposed discharge existinq thermal discharges into tile
                 .      'ho roposed 'L.cility and the nearby
                   . .ointUnit NuLr-er 1 will together withdraw
              , J0 gallons of water per minute from the CormIencing in 1974, the proposed Bowline
                 -a ilities          will withdraw 768,000 gallons of per minute from the Hudson, heat it to 13.51F discharge the heated water into the Hudson.

Lhese facilities are only 5 miles from the subject ility. Comtencing in 1973, the proposed Roseton facilities will withdraw 650,000 gallons of water prminute from the Hudson, heat it to 15.4 0 F and di.zýharge the heated ueater into the Hudson. These its a,*e only 2: ,i:e1. £:co the subluc.-h

                    .      T..he-,   a,    :.O*:.-s to        bcue~n no aeuate Of        thee         n1'ou             ..                         . Nor 1i.j   Ltcre been             rny consid rai.c-                L;    . L:tclrous therma.. dis-charges rjeser.tjp ....                              *f               ar,"a     the

-uds o-.. 150

A? rL*(.:-rgy c Commisý.ion S...1, 197"12 P!'age Your (4) A propriate cooling facilities can be installed without violating reasonable esthetic s-7"7.0-s and without undue ezpense. .iam advised vn: . Scenic. Hudson Preservation Conference dpes not object on esthetic grounds to the installation of appropriate cooling towers. Compared to the. costs of losing the present life in the Hudson, the cost of iicstalling adequate cooling towers is minimal. The obvious conclusion is that no

         . c)n should, be granted to Consolidated Edison to ope..te the proposed facility until appropriate closed looped cooling towers have been installed and are in operation.           Consolidated Edison should not le permitted to monitor the impact of its disc.harges upon the Hudson.           The preservation of

,--y ýing* life in the Hudson and the future reha*.Dii-atioh of the Hudson depend upon imnediate st..ps to limit further intrusions into the Hudson of the t-ype prcposed in the present petition. Vcý ry truly yours,

                                        /    M. 7N   !!

JpOHN 14. BURNS, 112 151

UUGKLT NUMBfER RICHARD L. OTTfNGER ~fU.iILU.LA.' 3!% [FAR RIDGE ROAD P LEASANTVILLE,N.Y. May 26, 1972 United States Atomic Energy Commission 1717 H Street NW Washington, D.C. 20545 Re: Docket No. 50-247

Dear Sirs:

I am writing today to urge that the Atomic Energy Com-mission require that Consolidated Edison begin immediate construction of cooling towers at its Indian Point 2 nucle-ar plant. The alternative to construction of these towers is the possible destruction of the fish population of the Hudson River. Although your staff has determined that there will be only a 15 to 20 per-cent destruction of the fish population caused by the operation of Indian Point 2, we must consider that tbis station is only of several which are proposed for construction along the river. While Con Edison continues to experiment with elabo-raLe, yet ineffectual fish protection devices, all evi-dence indicates that cooling towers will reduce the with-drawal of water, and therefore also fish life, from the river by 95 to 98 per-cent. We cannot afford to waste time on further research, especially since it will take considerable time to put any protection plan into operation. The solution is available; cooling towers will work, and their effect on the environmet will be small. Sincerely, ai RLO/jm 152

Harry G. Woodbuiy Consolid:ated [Edison Company of New Yoik, Inc. 4 living Place, New York, N Y 10003 Tclephoie (212) 460-6001 May 30, 1972 U. S. Atomic Energy Commission Washington, D. C. 20545 Attention: Director, Division of Radiological and Environmental Protection 1 JUN8 Vfb 1972. Re: Indian Point Unit No. 2 U&;C a~y Docket No. 50-247

Dear Sirs:

Consolidated Edison Company of New York, Inc. (Con Edison) respectfully submits its comments on the Draft Detailed Statement (the Statement) on the environmental considerations related to the proposed issuance of an operating license to Con Edison for the Indian Point Unit No. 2 nuclear generating plant, dated April 13, 1972, prepared by the Atomic Energy Commission's Regulatory Staff. These comments are submitted pursuant to notices in the Federal Register on April 20, 1972 and May 2, 1972. This letter contains comments on the major features of the Statement. Enclosed are nine appendices. Appendix A consists of suggested detailed corrections to the Statement. Appendices B-1 to H are detailed analyses in support of the positions indicated in this letter.

1. Conclusions Con Edison agrees with the conclusions contained in the Statement that Indian Point should be allowed to operate subject to an operational monitoring program. Con Edison be-lieves that this conclusion represents the best approach to satisfy the public interest in light of all relevant factors.

It is difficult to predict with accuracy the quanti-tative environmental impacts of a major facility such as Indian Point 2 on the complex aquatic ecosystem of the Hudson River. The Statement notes that, "Existing information is insufficient to accurately predict the degree to which the potential damage 153 2987

will eventually take place during operation." Con Edison agrees with the basic point that additional data and analyses are desirable to provide a better basis for professional opin-ions. The only way all such data can be obtained is to com-mence operations and study the actual impacts. Con Edison will cooperate with the Commission's Staff, the. Hudson River Policy Committee and the Hudson River Fishermen's Association in mon-itoring and study programs sufficient to obtain the information required by the Commission. A general description of these pro-grams was set forth in Supplement 1 to our Environmental Report. More detailed information was furnished to the Staff on March. 8, 1972. A further description is enclosed as Exhibit G. Some of the desired data have already been obtained but were not available to the Commission in written form when the Statement was prepared. Most of this material was intro-duced into evidence at the hearing conducted by the Atomic Safety and Licensing Board (ASLB) on April 5, 1972. The Commission should utilize these new data in the preparation of the Final Detailed Statement. Many of the comments contained herein are based on these data. Enclosed as Exhibit H is this testimony which is referenced in this letter. The body of the Statement appears to be written on the basis that the Statement should maximize estimates of environmental damage and minimize estimates of lack of such damage. Con Edison believes that this approach is contrary to law. The National Environmental Policy Act of 1969 calls for a detailed statement on the environmental impact of the proposed Federal action, i.e., the issuance of an operating license for Indian Point 2. The derivative requirement is thus an impartial objective analysis of environmental impacts. The Statement, however, describes the conceivable potentials for harm - in effect a speculative maximum damage rather than an impartial objective assessment. The Statement does not indicate either a minimum or likely damage level. The basis which apparently guidedthe preparation of the Statement leads to biased estimates of environmental dam-age and renders it impossible to perform an objective analysis of benefits and costs. The undue emphasis on potential environ-mental damage without a corresponding analysis of potential lack of damage weights the scales unevenly so that a balance of bene-fits and costs" is not practicable. The most fundamental- decision which must be made in this case is whether the economic and 154

environmental costs of major changes to the plant are worth the benefits to be derived in environmental improvements. If the potential for environmental damage has been overstated, a cor-rect evaluation is impossible, and the public interest is not served. The most significant example of this is that an admit-tedly rudimentary mathematical model has been used to compute, on the basis of limited information on but a few of the natural influences on fish populations, an entrainment of 25% of the young-of-the-year fish each year. This might have been described as a small percent of the natural mortality to put the number in perspective. And, although the number neglects diurnal move-ments, natural migrations, transport and avoidance mechanisms, it is mentioned time and again throughout the Statement implying that the 25% loss due to entrainment will be a fact. Other examples of the lack of objective analysis in-elude omission from the Statement of several important facts. As noted in the Statement, Indian Point 1 has experienced over several years a problem of the collection of fish on the intake screens. Con Edison has successfully eliminated collections of large fish, and collections are now limited to fish approxi-mately two inches in length which are generally immature, young-of-the-year fish. The only reference to size is a sentence that the fish are generally larger than 45-50 millimeters in length (V-33). The actual size is not given nor is there any state-ment as to the biological significance and natural mortality of the small size of these fish. Nor is there any mention of the findings of the AEC in their "Report of Inquiry Into Alle-gations Concerning Operation of Indian Point 1 Plant of Con-solidated Edison Company" dated October 1971. Another error concerns the temperature rise of cir-culating water passing through the plant. Con Edison intends to reduce the rate of flow during cold weather in order to re-duce the problem of fish collections. The reduced rate of flow will produce a higher temperature rise, a AT of about 24 0 F. This does not present any problem with respect to thermal cri-teria because this mode of operation will occur only when river temperatures are low. The Statement does not clearly state that reduced flow will only occur during cold weather. Accord-ingly, the higher temperature rise during reduced flow might erroneously be added to summer temperatures and lead to the 155

erroneous conclusion that a problem of excessive thermal dis-charges exists. The Statement implies that this problem could exist (111-37).

2. Thermal Criteria The Statement concludes that Con Edison has not ade-quately demonstrated compliance with New York State criteria for thermal discharges. Con Edison refers the Commission to the testimony of Dr. John P. Lawler on The Effect of Indian Point Units 1 and 2 Cooling Water Discharge on Hudson River Tempera-ture Distribution which was submitted to the ASLB on April 5, 1972 (see Appendix H). Enclosed as Appendix B-1 is an analysis of Con Edison's differences with the Statement and an explanation of why Con Edison believes its analysis is correct. The Com-mission was also furnished with additional information on this subject in a report of Quirk, Lawler & Matusky Engineers entitled "Supplemental Study of Effect of Submerged Discharge of Indian Point Cooling Water on Hudson River Temperature Discharge" dated May 1972. This report is enclosed as Appendix B-2.

If the Commission should nevertheless conclude that thermal discharges may not meet State criteria at all times, the Statement shbuld then include an analysis of the extent the criteria will be exceeded and the ecological significance of that fact. The Statement indicates that the Commission is pri-marily concerned with the standard of a 90°F maximum surface temperature at any point. This statement may result from a misunderstanding of our planned use of the circulating pump by-pass or from the misleading temperature data in the Raytheon Report. Peak temperatures fluctuate from year to year. The Commission's analysis is based on peak temperatures which, if seen at all, would be seen rarely -- certainly not every year. The Statement should indicate the expected frequency and the extent of the surface area heated in excess of 90°F and the environmental impact of such an occurrence. The post-operational data that Con Edison proposes to collect will provide hard data with which to verify predictions. The concern expressed by the Staff appears to be associated with the use of uncontrolled data collected for other purposes. See Appendix B-1. The Staff uses a maximum river temperature at the plant intake of 81°F (111-35). The tem-perature at the Indian Point 1 intake is monitored continuously. 15.G

In view of the voluminous data available on this subject, Con Edison considers 791F (without recirculation) to be the high-est water ambient temperature that can be experienced by the Indian Point intake at any time. The Statement references data contained in the Report of Inquiry on Indian Point Unit No. 1 submitted by the Com-mission's Division of Compliance in October 1971. These data show three readings at 81OF and the balance of the readings are consistent with Con Edison's analysis. These three read-ings were not at the plant intake but were out in the river where they were influenced by the thermal plumes from Indian Point and Lovett. The same Report of Inquiry had data on intake temperatures which is not referred to by the Statement. (See Appendix B-1 for further details.) The Statement contains a considerable discussion of the concept of net non-tidal flow (111-22 to 26). The Com-mission appears to agree with Con Edison that this phenomenon exists but hesitates to make a quantitative determination. Since the phenomenon exists, it is important to provide some quantitative statement of its effects. As is indicated in Ap-pendix B-1, Con Edison has used the most conservative manner of estimating the effect of net non-tidal flow.

3. Dissolved oxygen Con Edison disagrees with the Statement concerning dissolved oxygen. Con Edison thought that its testimony before the ASLB and information which had been furnished to the Com-mission's Staff had removed any concerns about this question.

In view of the comments contained in the Statement, Con Edison now submits as Appendix C a report of Quirk, Lawler & Matusky Engineers entitled "Effect of Indian Point Plant on the River Dissolved Oxygen." This report contains data on actual dis-solved oxygen measurements taken at the intake and discharge of Indian Point* 1 and a detailed analysis of this problem under varying conditions. The commission's concern on dissolved oxygen appears to be based on a few data points in a report of Raytheon Com-pany. These data are inconsistent with other data obtained by Con Edison and data gathered at other power plants and is also .inconsistent with predictions based on plant engineering design. 157

Con Edison examined the Raytheon data and found that it was incorrect due to faulty instrumentation. The Staff appears to agree with Con Edison's opinion on the Raytheon data (V-10), but nevertheless says that it is "not yet satisfied." Con Edison proposes to obtain post-operational data additional to that which it already has in order to satisfy the Commission on this point.

4. Chlorination The Statement contains considerable discussion about the possible damage to aquatic organisms from chlorination.

Con Edison has established procedures to minimize harmful ef-fects, and indications are that it has succeeded. Attached as Appendix D is an analysis of the chlo-rination program for Indian Point 1 and 2 and an explanation of the basis for Con Edison's disagreement with some of the matters discussed in the Statement. Con Edison also refers the Com-mission to the testimony of Dr. Gerald J. Lauer on the Effects of Chemical Discharges from Indian Point Units 1 and 2 on Biota and River Chemistry which was submitted to the ASLB on April 5, 1972 (see Appendix H). Dr. Lauer found by sampling at Indian Point 1 that entrained organisms generally are not destroyed by Con Edison's chlorination procedures at Indian Point 1. He states that this is probably due to the fact that the exposure time to high levels of chlorine is very brief as compared to the exposure time of the target organisms on the condenser tubes. He. also reports that bioassay studies show survival of organisms at exposures comparable to those experienced by entrained organisms. Much of the discussion of chlorination problems con-tained in the Statement appears to relate to an environment and species foreign to the Hudson River. Con Edison believes that observations in the Hudson River with Hudson River species are necessary before a determination can be made that a problem exists. The observations to date have indicated no problem. More data will be obtained as part of the continuing ecological studies when Indian Point 2 commences operation. The Statement suggests that the discharge concentration of residual chlorine will be 0.5 ppm. Extensive data from op-erations at Indian Point 1 show a discharge concentration of 158

0.1 ppm or less. There is no reason for the residual levels at Indian Point 2 to be significantly different (see Appendix D). Under New York State rules 0.5 ppm is a legal maximum. Furthermore, the discussion of potential toxic ef-fects at low chlorine levels is based on a small portion of the literature and on long periods of exposure and deals prin-cipally with fresh water fish. The Statement should note that other portions of the literature show no toxicity at the levels expected from Indian Point operations (see Appendix D). Con Edison has commenced a program to establish a further reduction in the frequency of chlorination. This pro-gram is described in Appendix D.

5. Entrainment The principal difference between the Staff and Con Edison in regard to the potential adverse impact of Indian Point 2 on marine aquatic organisms is the Staff's estimate of the entrainment of nonscreenable fish eggs, larvae and fingerlings.

Con Edison's position is set forth in Appendix E. In summary, Con Edison agrees that we should seek to quantify the effect of this entrainment, but disagrees with the Staff in the following respects: A. The crux of the Staff's analysis is its calcu-lation that approximately 25% of the planktonic forms of various fishes using the estuary will be entrained by the plant. The Staff has computed this number by the use of erroneous equations. The Commission's analysis of estuary dilution flow is based on a report of B. H. Ketchum, and the bulk of the literature in the field establishes that this analysis cannot properly be used for this purpose. B. Tihe Commission understates the significance of the diurnal movement of larvae. Thd Statement does recognize that this phenomenon exists but states that the effect it main-tains is slight. It does so on the basis of an hypothesis which if true suggests a net upstream movement of planktonic larvae which would produce negligible entrainment. Con Edison believes that the diurnal effect may reduce entrainment to one-third to one-half of the Commission's prediction based on the 159

proportion of daylight hours to darkness during the planktonic stage. In conjunction with proper estimates of estuary dilu-tion flows, the entrainment would be further reduced to one-fifth to one-eighth of the Staff's prediction. C., The Staff also bases its analysis on the conclu-sion that 75% to 90% of the young juveniles which reach Haver-straw Bay below Indian Point pass Indian Point in an entrainable stage and are uniformly subject to entrainment. Eggs only exist for approximately two days so that only eggs spawned in close proximity to the plant could be susceptible to entrain-ment. Furthermore, larvae are fully planktonic for only a few days. Juveniles are known to move toward shallows and shoal areas as well as deep waters unlike the area near the Indian Point intake and thus do not randomly reach Indian Point based on total mixing. These same juveniles also have a capability to avoid entrainment. D. Con Edison shares the view that based upon cur-rent data and analytical techniques the impact of entrainment and impingement on the total fish population cannot be sat-isfactorily quantified. We share the view that a determined attempt to obtain some quantification should be made in the early years of plant operation. In our opinion it will take five years rather than two years to accomplish such a unique task. In the meantime it is the considered opinion of Con Edison that the operation of the plant during the study period will not cause irreversible or irretrievable damage to the fishery. It is to be noted that the intervenor which is raising the question of damage to the fishery is the same one which has been making similar claims for the past eight years concerning the operation of Indian Point 1. And yet the principals of that organization have in the recent past published articles claiming that bass fishing is excellent and improving. Glowka, "117,000,000 Stripers", The Salt Water Fisherman, August 1971.

6. Radiological Impacts Con Edison believes that the Staff, in computing the possible radiological impact of Indian Point 2, failed to take into account certain systems presently installed or to be in-stalled shortly which it can properly consider. These are 160

described in Appendix F. Con Edison hopes that these comments and the enclosed appendices will be of use to the Commission in preparing the Final Detailed Statement. Very truly yours, Harry G. Woodbury Executive Vice P sident Encs. 161

Appendix A Detailed Comments

1. Page i, Item 3c :First reference to Unit 2 should also include Unit 1.

2. Page ii, Item 3f :AEC conclusion is not supported by evidence in the Draft Statement. Refer to testimony of John P. Lawler on The Effect of Indian Point Units 1 and 2 Cooling Water Discharge on Hudson River Temperature Distribution submitted at April 5, 1972 hearing session of ASLB and re-sponses to AEC Staff questions dated May 11, 1972.

3. Page ii, Item 3f, :Change "mean low water" to "U. S. Coast and Geodetic Survey Sea Level Datum." This is the standard reference point for construction in the Hudson River. This was previously des-cribed incorrectly as "mean low water." Mean low water is one foot below the standard refer-ence point. The applicable studies which were used to determine the location of the ports were done on the basis of 12 feet below the standard reference point. Accordingly, the ports are correctly located but were incorrectly described.

4. Page ii, Item 3g. :See Appendix C.

5. Page ii, Item 3i. Conclusion contrary to evidence submitted at hearings on January 11, 1972 and April 5, 1972 in testimony by Gerald J. Lauer and Walter Stein which indicated a concentration of less than .1 ppm at the point of injection into the river because of tli chlorine demand of the water passing through the half of the condensers not being chlorinated. (See Appen-dix D).

6. Page ii, Item 3i, :The term "may be toxic" should be defined.

line 5. Bioassays reporting contrary results submitted into evidence in testimony of Gerald J. Lauer on Effects of Chemical Discharges from Indian Point Units 1 and 2 on Biota and River Chemistry. Testimony submitted at hearing session of April 5, 1972. 162

7. Page ii, Item 3j. :This statement should be clarified to in-dicate that it constitutes a maximum environ-mental impact without taking into account unquantifiable phenomena each of which would serve to reduce the 25%.

8. Page iii, Item 3n, line 2:Change "coal" to "oil".

9. Page vi, Item 5f :Two years is an inadequate period for an ade-quate biological study. Our present study is planned for five years.

10. Page xxi, Last para. :This paragraph should be amended to reflect additional documents on which the Final Environmental Statement will be based. This particularly should be expanded to include all evidence submitted at the hearings of the ASLB, including especially the evidence submitted on April 5, 1972 and the enclosures hereto.

11. Page 1-2, Third para., "slecting' should be "selecting" line 6.

Item should be deleted. See tiem 6 on page

12. Page 1-5, Item 2.

1-7.

13. Page 1-6. :Add permit for new outfall (copy attached).

14. Page 11-3, fig. 11-2. :Sde attached figure for new locaticn of Visitors' Center.

15. Page 11-4, first para., :No Indian Point buildings can presently be be seen from Peekskill, only IP-I stack and tip of Unit 2 and Unit 3 containment can be seen.

Ira Page 11-8, line 3. :Change "St. Peter's Church" to St. Patrick's Church."

17. Page II-11, Third para.,  :"29 million cubic feet" should be "29 billion line 5. cubic feet."

18. Pages II-11 and 12, :Refer to Appendix B and documents indicated last line et seq. in Comment 1 for discussion of thermal dis-charges and intake temperatures.

19. Page 11-12, Second para. :See Appendix C for discussion of river dis-solved oxygen levels.

20. Page 11-12, Second para.,:Delete "locations near population centers" line 6. and insert "in the vicinity of municipal wastes outfalls." 163

21. Page III-l, First para.,:Indian Point Unit No. 3 is scheduled for completion by the sunmer of 1974.

22. Page 111-2, Fig. III-1 :Transmission lines not correctly shown (see next comment).

23. Page 111-4, Sect. C, :Last sentence should read: "The double circuit First para. structures are designed to carry the Unit No.

2 output of 873 MW(e) at 345 KV to the appli-cant's system at the Buchanan Substation 2,100 feet away from the Turbine Building, plus the 138 KV input for the Unit No. 2 light and power facilities or the 138 KV output from Indian Point Unit No. 1."

24. Page 111-5, fig. 111-3. :Should show a double circuit steel pole and not a single circuit steel pole (photograph attached).

25. Page 111-6, First para.,:See Comment 21.

line 6.

26. Page 111-6, Second para.:There is no demineralizer in the feed water line 18. path to the steam generator.

27. Page 111-7, First para. :Insert between sentences: "fossil plants discharge a significant portion of their waste heat to the atmosphere in the plant and up the stack, while nuclear plants discharge virtually all waste heat to the cooling body."

28. Page 111-7, Second para.:"9.35 x 109,, should be "6.38 x 109" based line 12. on Table III-1 and Page 111-19.

29. Page 111-8, Table III-1 :"Tp" in Column 6 and footnote should be " Tp".

Total for Column 5 should be "10,294" not "10,295." Total for Column 7 should be "783" not "782".

30. Page III-11, Sixth para.:Delete from "On November 10, 1971 ... " through line 6. end of quote on page 111-12 and insert "The disaqreements have not as vet been resolved."

31. Page 111-12, Second para:April 24 has passed. We have no indication when we can expect action on our sction-13 permit application to the Army Engineers because of current litigation *ith the Army Engineers in the Federal District Court, District of Columbia.

32. Page 111-12, Third para.:Change "300,000" to "319,000".

33. Page 111-12, Last para. :Add to last sentence: "and is adding control gates to 1@4plate discharge velocities."

34. Page 111-13, First para.,:Add after bar screens: "fixed fine screens."

line 11.

35. Page 111-13, First para.,:Change "inlet" to "outlet."

line 12.

36. Page III-13,Second pa'ra.,:Change "30 feet" to "12 feet, 4 inches."

line 2. 37, Page III-13,Second para.,:Change "6" to "7". line 3.

38. Page 111-13, Second para.:Omits reference to recirculation system.

See Applicant's Environmental Report, Supplement 1, page 2.3.6;25.

39. Page 111-14, fig. 111-4 :Fixed fine screens not shown. Should be between curtain wall and de-icing spray.

Screen cleaning water rate varies from 324 to 358 gpm per section.

Mean low water is at Elevation -1' -0".

Change "Tidal Flow to 300,000 cfs" to agree with values on Page 111-22, Third paragraph, lines 5 and 6.

Change "5,000 ft. wide" to "4,000 ft. wide."

Change "temp 320 F to 800 F " to "temp 320 F to 790 F."

40. Page 111-15, fig. 111-5 :Charge Unit No. 1 Cooling Water from "300,000 gpm" to "280,000 gpm".

Change,Service Water from "60,000 gpm" to "69,000 gpm" .

4L Page 111-16, Third para. :Discussion would be more relevant if it des-cribed velocities in front of screens which fish experience.

42. Page 111-16, footnote*** :Change "1,157,000 gpm" to 1,188,000 qpm."

43. Page 111-17, Table III-2,:Change Discharge gpm from "300,000" to "319,0001.

line 1. :Change Daily Heat Loss to River (Btu) from "4.6 x 100" to "4.7 x 101011.

Change Daily Average *t, OF from "13011 to 1114_°".

446 Page 111-17, Table III-2,:Change Daily HeI8 Loss to River (Btu) Line 2. from "15.2 x 10 " to "15.3 x 10l0". Change Daily Average at, OF from "11501, to

                                ",15.10".

165

45. Page 111-18, Fig. 111-6 :Mean low water is at Elevation - iP-01

Head in the canal is 1.5 feet not 5 feet as shown.

46. Page 111-19, First para., line 9 :Change "1,157,000 gpm" to "1,188,000 gpm".

47. Page 111-19, Second para. :The primary function of the level control weir in the discharge open channel is to provide the required jet v~locity for thermal diffusion; it is not intended to

                            -usn- to control the head requirements on the intake pumps. However, a second level control weir, which is installed in the discharge tunnel between Units 1 and 2 is for the purpose of regulating the water level upstream (the section serving Indian Point Unit No. 2) according to daily tidal conditions and thus, stabilize the head requirements on Indian Point Unit No. 2's circulating water pumps.

48. Page 111-19, First para., line 9 :Change "1,157,000 gpm" to "1,188,000 qpm".

49. Page 111-19, Fourth :Change Reference from "14" to "4".

para., line 5

50. Page 111-19, Sixth :Delete " may be helpful in approximating" para., line 8 and insert "is used to determine".

51. Page 111-22, First para., lines 1 & 5 :Delete "in excess of 19,000 cfs" and insert "20,800 cfs".

52. Page 111-22, Second para., line 3 :Change " 155,000 square feet" to "160,000 square feet".

53. Page 111-22, Second para., line 6 :Change Reference from "15" to "9".

54. Page 111-27, Third :Delete last sentence and insert "Reference para., line 4 11 reports a theoretical estimate of 2 7,000 ft /sec at Indian Point for an assumed salt profile corresponding to a fresh water flow of 3,000 cfs".

166

55 Page 111-27, para., :Change Mile Point from "85" to "82". line 4

56. Page 111-30, Second :Change "18-foot depth" to "12-foot depth".

para., line 3

57. Page 111-31, Second .Delete "considered uniform in" and insert para., Line 10 "analyzed for its average".

58. Page 111-33, Item (3), :Change "external" to "subsurface".

line 3 59 Page 111-33, def. "b" :Change "equals or exceeds" to "equal and exceed". 60 Page 111-33, Second :Change " (9) and (10)" to "(5) and (6)". para., line 1

61. Page 111-33, Third :Refer to Chapter V of Reference 4, para.

62 Page III-33,Item (4) :Delete last sentence and insert "The model line 3. is used to calculate the cross section averaged temperature excess. The mathe-matical expression for the cross section area average temperature at the plane of the discharge is 63 Page 111-34, Item (5) :Change "Model III" to"The Third Model" Third para., line 1

64. Page 111-35, Second :Applicant has never assumed that 5% of the para., line 3. heat generated in the reactor would be "in-plant losses." The in-plant losses for In-dian Point Unit No. 2 are more like 3%.

65. Page 111-35, Third para.:See Appendix B-2 (Thermal Discharge in this submission).

66. Page 111-36, Second para:Delete "assumes a uniform: and insert line 1. "calculates".

67, Page 111-36, Third para.:Ports are centered 21 feet apart and not line 3 and 5. 20 feet, and the spacing between the ports is 6 feet and not 5 feet. 167

68. Page 111-37, First :Method of initial port operation was sub-para. mitted to the AEC in a letter dated April 13, 1972. It-is important to note that the ports have been designed with sufficient flexibility so that the method of operating the ports can be adjusted to achieve the 10 fps jet velocity.

69. Page 111-37, Second :Reference is made to the testimony of Dr.

para. John P. Lawler submitted to the ASLB on April 5, 1972 and responses to AEC Staff questions dated May 11, 1972 for support-ing data concerning the submerged discharge. The discharge ports were changed from - 18 feet to -12 feet in order to achieve more rapid decay in surface temperatures with distance from the outfall. This will reduce the surface area covered by ele-vated temperatures. Hydraulic model stu-dies showed that this did not present any significant problem with respect to maxi-mum surface temperature. Furthermore, operation with reduced flow will only occur when temperatures in the river are low so that this mode of operation can have no effect on the maximum surface tempera-ture limit.

70. Page 111-40, Second The CVCS is not normally considered as part para. of the liquid waste system. This CVCS is expected to recycle all primary coolant and will thus not be a source of radioactive release. In supplement 15 of the FSAR, there is mention of an expected release from the CVCS of four primary coolant volumes per year. This figure was determined as a means of tritium control based on 30%/ dif-fusion of tritium through zircaloy fuel cladding. Recent operating experience at RG&E, Wisconsion and Carolina indicates much less ("1%) diffusion and so there be-comes no necessity for tritium control and no monitor tank releases are to be expected under normal operation.

168

71. Page 111-40, Third para. :The effluent from these demineralizers lines 14 and 15. is not directly sent to the monitor tanks.

The description is correct if stated "The effluent from both demineralizers will'be filtered and returned to the volume control tank for reuse. When necessary, the ef-fluent can be routed to the holdup tanks for processing through the boric acid evaporator. On this path, the concentrate is sent to the monitor tanks for reuse or, under conditions other than normal, can be sent to the discharge canal.?

72. Page 111-40, Fourth para. :The first sentence should read, "The second part of the CVCS will process primary water for dilution or borating especially during load follow operation, excess coolant let-down during reactor startup, and liquids that drain from reactor coolant pump seals, accumulators, pressurizer relief tanks:-and valve and flange leakoffs."

73. Page 111-40, Fourth para., :The evaporator feed demineralizers are catio last sentence. demineralizers and reduce the concentration of Cs and Li only, and not all isotopes except H3 as stated.

74. Page 111-41, Fig. 111-13. :See attached Figure (Figure 2) for more accurate description.

75. Page 111-42, First para., :Two demineralizers are provided. Normally line 2. neither is used until toward the end-of-core life, then one or both may be used.

76. Page 111-42, line 9. :See comment 70.

77. Page 111-42, Fourth para. :Laundry and shower wastes are processed in the Indian Point Unit No. 1 system.

78. Page 111-43, Fig. 111-14. :There is no Laundry and Shower Tank in Unit No. 2.

79. Page 111-45, First para., :The Unit No. 2 evaporator is equipped line 1. with alkaline treatment and hence should be crddited with a DF greater than the DF of 100 shown.

169

80. Page 111-45, First :should read: "6 curies per year".

para., line 3

81. Page 111-45, Second :Waste is collected in 75,000 gallon para., line 3 tank until it is full, regardless of the period it takes to fill the tank.

82. Page 111-46, Table :Credit for the Indian Point Unit No. 1 111-5 waste evaporator should be given. This will substantially reduce these releases.

83. Page 111-47, Table :Activitv releases for 100% Plant Factor 111-6 are inappropriate. A 100% Plant Factor is unrealistic; thus, column so headed should be omitted.

84. Page 111-49, Third :Applicant has committed to installing para. charcoal absorbers in the exhaust of the.

containment and PAB by the end of the first refueling outage (See Appendix F).

85. Page 111-49, Fourth :There is provision for diverting air para. ejectors to the containment in the event of high activity. Upon completion of the blowdown intertie, steam from blowdown will be routed to the Indian Point Unit No. 1 condenser. Essentially all the iodine would be retained in the condenser.

Any releases would be through the Indian Point Unit No. 1 condenser air ejector which exhausts to the Indian Point Unit No. 1 stack. When the Unit No. 1 con-denser. is not operating, the gases from the flash tank divert to an already-existing vent and go directly to atmosphere via a vent on the roof. 170

86. Page 111-49, Fifth :Since our Tech. Specs. set firm limits, para., line 6 there is no basis for calculating a higher release.

87, Page 111-51, Table :See comment93 111-8

88. Page 111-52, First para. :Estimates shown should incorporate effects of new design changes which applicant has committed to install (See Appendix F).

°89 Page 111-52, Second para., line 3  :"mixed with a solidifying agent such as vermiculite and cement." 90, Page 111-52, Fourth :Effluents will not be monitored for para., line 4 chemicals other than chlorine.

91. Page 111-54, Table :Should be revised as per attached table.

111-9

92. Page 111-55, First :The expected concentration is less than para., line 6 0.0001 ppm Li.

93. Page 111-55, Second :A maximum of 2000 ppm boron as boron not para., line 1 boric acid.

94. Page 111-55, Second :50 ppm of boric acid is the proposedconcentratc para., line 5 Concentration with 100,000 gpm is 0.3 ppm boron from each unit.

95. Page 111-55, Fourth :Waste not wasted.

para., line 1i

96. Page 111-55, Fourth :The 10 ppm is not the expected concen-para., line 15 tration, it is the proposed maximum con-centration. The expected concentration is 1.2 ppm.

97- Page 111-55, Fifth :We use 3 pounds detergent per day not the para., line 1 6 pounds per day stated.

98. Page 111-56, Second :0.1 ppm is the proposed maximum concen-para., line 4 tration. The expected concentration is 0.006 ppm.

171

99. Page 111-56, Third :0.1 ppm is the proposed maximum concen-para., line 8 tration. The expected concentration is 0.0007 ppm.

100. Page 111-57, First :10 ppm is the maximum proposed concentra-para., line 3 tion. The expected concentration is 3 ppm. Sulfuric acid from cation regenera-tions will not be neutralized by sodium hydroxide before release. 101. Page 111-57, Second :5 ppm is the maximum concentration. A para., line 2 2% solution is used for 12 hours and is discharged continuously at a concentration of 1% during this period at a rate of 17 gpm. 102. Page 111-59, Third :In a report on Unit No. 2 it seems inappro-para. priate to comment on air emissions from Unit No. 1 fossil boiler. Further it is stated in essence that our NOx emission factor of 0.36 lbs/10 6 BTU is 20% in excess of that specified in 42 CFR 466. It should be noted: (1) 42 CFR 466 contained proposed and not adopted "Standards for New Stationary Sources". (2) The adopted standards for new stationary sources are cited in 40 CFR 60 and (3) 40 CFR 60 is not applicable to Indian Point because it is not a new plant, and also because the superheaters do not fall under the defi-nition of a fossil-fuel fired steam gene-rator. A fossil-fuel generating unit is described as a "furnace or boiler used in the process of burning fossil fuel for the primary purpose of producing steam by heat transfer." Further, the New York City air pollution code has no relevance to a discussion of effluent systems at Indian Point. As applied to Con Edison, this code requires a reduction of sulfur content in residual fuel oil from 1% to an annual average of 0.55% from October 1, 1971 to October 1, 1972, and to 0.30% thereafter. 172

103. Page IV-2, Fourth :Mean low water is -1'-0". (See comment 3). para., line 8 104. Page V-I, Third para., :should be page 2.3.1-2 not 2.2.1-2. line 15. 105. Page V-2, First para., :Trap Rock not Trapp. line 7. 106. Page V-6, Third para. :This paragraph is highly speculative and seems less than objective as required by NEPA and Calvert Cliffs. 107. Page V-9, Table V-I. :Concentration factors are for fresh water and therefore do not apply. 108. Page V-10, Fifth para. :See Appendix C regarding minimum DO. l0o *Page V-lI, Second para. :See Appendix D. The discussion of rainbow trout is irrelevant and should be deleted as not referring to the Hudson River at Indian Point. 110. Page V-12, Second para. :Penultimate sentence is without basis. See Applicant's bioassay results report in testimony of Dr. Gerald J. Lauer submitted to ASLB on April 5, 1972. 111. Page V-21 :See testimony of Dr. Gerald J. Lauer on Effects of Elevated Temperature and En-trainment on Hudson River Biota submitted to ASLB on April 5, 1972 for discussion of Applicant's temperature tolerance studies. 112. Page V-23, Third para. :The discussion of fish in the discharge canal is irrelevant since the 10 foot/sec. discharge velocity is sufficient to keep fish from entering the canal. This dis-cussion should be deleted, or it should be noted that Indian Point does not have a canal of the type discussed in the refer-enced literature. 113. Page V-28, Second para.,  :"No" survivals of larval or juvenile fish line 9 is not correct. Report says "most" were dead, not all. Statement should indicate that most data involved canal temperatures greater than 95 0 F, which are not expected at Indian Point. 173

114. Page V-29, Fourth para. :See document referred to in Comment 111, 115 . Page V-31, First para. :fish are not ordinarily netted in front of fixed screens. This paragraph indicates a misunderstanding of the function of the fixed screens. These screens, installed in front of the intake openings at Units 1 and 2, serve the purpose of barring the entry of relatively large fish into the intake forebays where they could be come trapped. During a brief period of testing at Unit 1 in April 1970, the fixed screens were removed from two of the four bays for a period of six days. During this period, the mean length of fish collected from the open bays was greater than the mean length of fish from the screened bays. The in-

                                *crease in mean length was due to the col-lection of relatively large fish which are rarely caught on the fixed screens.

116. Page V-31, Fourth para., :The intake velocity is not high but is lines 1 and 2 a customary design. 117. Page V-33, First para. :The statement is correct but over 90% would' be more accurate. 118. Page V-33, First para. :The size of the collected fish is not indicated. The vast majority of fish collected at the intakes at Indian Point are approximately 50 mm. in length. Oc-casionally, larger specimens of tomcod, catfish, white perch and eel are caught. 119. Page V-33, Second para. :Staff has failed to take into account changes made in Units 1 and 2 regarding intake velocity. See Section 2.3.6.4 of Unit 2 Environmental Report, Supple-ment 1.

The total for Invertebrates Dose is 12a Pages V-36 & 37, Table V-3 incorrect.

174

121. Page V-38, First para., :See comment 107. line 1 122. Page V-39, Third para. :First sentence needs to be qualified by substituting "maybe" for "are". 123. Page V-40, Table V-4 :The table is not supported by evidence and is inconsistent in part with the text. For example, Table V-4 lists the equilibrium concentration of boron as 4.85 ppm while paragraph C(l) on page V-39 gives 0.055 ppm as concentration in the river due to maximum sustained releases. Further, the minimum toxic level of 0.0034 ppm for chlorine is based on a chronic ex-posure for 15 weeks (Page V-ll). See Appendix D. 124. Page V-42, Second and ;See document referred to in Comment 103. Third para. Xf the staff nevertheless anticipates some thermal effects, those effects should be quantified. 125. Page V-45, Table V-6 ;See corrections to Staff's 50% draft statement as submitted to ASLB on January 11, 1972 (Tr. 4363). 126. Page V-47, First para., ;The intake velocity is not dependent on line 6 the number of pumps operating. The state-ment does not refer to the recirculation loops which will be used to reduce intake velocities. 127. Page V-47, Second para. ;This statement is incorrect. Two pumps lines 1-3 were operated at full flow for one day and one pump at full flow for the remaining four days. 128. Page V-49, Fourth para. -See document referred to in comment 103 for discussion of entrainment and entrain-ment mortality. 175

129. Page V-51, Section (b) :Neomysis' presence in the vicinity of Indian Point appears to be dependent upon intrusion of salt water upstream to that area. Studies have shown that increases in fresh water flow which push the salt "front" downstream have made Neomysis virtually unavailable at Indian Point. For further discussion see document re-ferred to in comment ill. 130. Page V-52 Section (c) :See Appendix E. 131. Page V"53, First para. :The conclusion is based upon a great many more assumptions than stated. See Appendix 5 and April 5 testimony of Dr. Lawler on entrainment. 132. Page V-56, Fifth para., :Applicant is seeking to identify by the 5-year ecological study if there is any adverse effect due to thermal discharges. New York State established its thermal standards, after extensive hearings, at levels which will assure no significant adverse effects. Further evidenc on this subject was submitted to the ASLB on April 5, 1972. See document referred to in Comment lli. 133. Page V-60, Section (e) :It is recommended that Applicant and Staff discuss the Staff's recommendations as soon. as possible. A copy of the contract scopes for the studies is attached as Appendix G. 134. Page V-61, Section 8 :It is not possible to count fish on the fixed screens. When the fixed screens are washed, impinged fish fall into the water and are carried by the intake flow onto the traveling screens. The traveling screens pick up the fish and transfer them to a sluice where they can be collected and counted. 135. Page V-64, Fourth para. :Present height of stack is 113m above local ground elevation. After truncation, the stack will be 88m above this elevation. 176

136. Page V-65, Table V-8 :Doses given are for 0.5 miles south of the site. This is not the site boundary nor is it located in the worst meteorologi-cal sector (SSW of the site). The site boundary is 520 meters. The dose for the closest resident is twice that indicated in the table. 137. Page V-71, Fourth para., :and will contain about 30 to 50 percent line 2 of the original -235 (which is recover-able). 138. Page V-71, Fourth para., :Change "varies" to "decreases". line 6 139- Page V-71, Fifth para., :Change "3 fuel elements per cask" to "2 line 6 fuel elements per cask". 140. Page V-72, Second para., :Delete "Specification 17-H drums," and line 5 insert "containers"'. 141- Page V-72, Third para., :Change "other non-radioactive cargo" to line 7 "other non-radioactive hazardous cargo". 142.. Page V-73, First para., :Change last sentence as follows: "For fresh and irradiated fuel, the shipper must also provide under both normal and design basis damage conditions a specified margin of criticality safety. 143. Page VI-7, Second par4, :Change first sentence as follows: "The packaging is design with specific safety margin to prevent..." 144. Page VI-7, Third para., :The phrase "extremely remote" does not line 2 adequately convey the probability in question. Criticality of new fuel under these conditions has always been regarded as impossible for all meaningful purposes. 177

145. Page VI-8, Second para., :Change first sentence as follows: "In lines 2 and 3 such an accident, the amount of radioactive material released could be limited to the number of fuel "rods which were ruptured or became perforated. This material con-sists of noble gases in the void spaces in the fuel pins and some fraction of the low level contamination in the coolant". .146. Page VII-1, Section B, :add "simulator" , delete marina. line 6 i47. Page VII-4, Third para., :See comment69 . 32.5 is incorrect for a 40% re-, line 6 duction in flow. Should read 23.9. See attacl ed table. 148. Page VII-5, First para. :The Staff appears to have disregarded physical model studies performed for the Applicant by Alden.Research Laboratories and appended to Applicant's Environmental Report. See documents referred to in comment 2. 149. Page VII-5, Second para. :Staff appears to havq passed judgment on what they characterize as insufficient data. See testimony of Dr. Gerald J. Lauer on Effects of Chemical Discharges and Effects of Elevated Temperature and Entrainment submitted to ASLB on April 5, 1972. 150. Page VII-5, Fourth para. :See Appendix C. 151. Page VII-6, Fourth para. :See document referred to in comment 103 and Appendix E. The staff again appears to have passed judgment on insufficient data. 152. Chapter X :Reference is made throughout Chapter X to the 40 year expected life of Indian Point No. 2. In Applicant's economic eval-uations, a 30 year service life has been used. 153. Page X-1, First para.  :"Save-a-watt" campaign was introduced in 1971. 178

154. Page X-1, Second para., :Reference is made to the high ratio of line 14 maximum to minimum loads during any 24 hour period which requires that much of the capacity needed to meet the daytime peak will be idle or unloaded a good part of thetime. It should be made clear that while this will be true of gas turbine peaking plants and some base load fossil plants, it does not accurately reflect the use of our nuclear plants. For the fore-seeable future, these will be base-loaded when available. 155. Page X-4, Second para. :Con Edison does not use a fixed 20% re-serve criteria to establish levels of installed capacity. Rather, installed capacity requirements, and consequently levels of planned reserve, vary from

                            'year to year as a function of the size and age of units installed, the past '_

experience and projections of forced out-ages and daily deratings and the charac-teristics of the load distribution. At the present time, Con Edison has a relative-ly high percentage of older and less relia-ble generating units and is dependent on the timely completion of new generating resources for much of its planned reserve. Consequently, a planned installed re-serve of 20% is not adequate. This has been demonstrated in the recent past when planned reserves varied from 21% to 27%, and we experienced numerous days of voltage re-duction. 156. Page X-6, Third para., :Change 1584 megawatts to 1833 megawatts. line 8 15Z Page X-11, First para. :In view of the passage of time since the preparation of the environmental report, new information is available concerning the details of power supply during the summer of 1972 and'the winter of 1972-73, and Con Edison has made a new calcu-lation of costs of delay taking into account current cost information. This 179

data is contained in the testimony of Mr. Bertram Schwartz submitted to the ASLB on May 18, 1972. It does not alter the basic conclusions contained in the State-ment. 158. Page XI-II, Second para.,:See Appendix D. See Comment 5. line 9 159. Page XI-ll, Second para.,:See comment-hl. Reference refers to line 14 species of fish not found in Hudson River and is therefore irrelevant. 160. Page XI-16, Fourth para., :New Visitor's Center will be started be-lines 5 and 6 foreý and not after completion of Indian Point Unit No. 3. 161. Page XI-22 & 23, Item 21 Staff conclusions are not supported and contrary to evidence submitted on April 5, 1972. See comment 108. 162. Page XI-35, Item 7.2 :See Appendix D. 163. Page XI-8, Second para'., :See comment 40. line 7 164. Page XI-9, First para., :Brackish water cooling towers are com-lines 12-14 mercially available but there has, as yet, been little operating experience with them. 165. Page XI-16, para. F :Include simulator which will be located in the area just east of Unit No. 2. This facility will be used for training reactor oper ators. 166. Pages XI-46 and 47, Item :This appears to present an inconsistent 13.1, Subalt. 2B 7 2E discussion of the noise problems from cooling towers. It estimates that noise from natural draft cooling towers "will be in the unac-ceptable region for a distance of 2,500 feet from the center of the tower complex". The Staff then concludes "that the noise in this fge is probably negligible."

167, Page XI-54, Last para. :Add the poor visual impact of cooling towers on environs, particularly hyperbolics which would be visible for miles. 168 Page A-4, :Change "32 ppt" to "35 ppt". definition for "Vs" 169. Page A-42 :The width of the intake openings increase from 13'-4" to 14'-10" at the fixed fine screens. Therefore, the velocity is 0.81 fps instead of 0.9 fps.

Mean low water = 26' depth, therefore velocity through trash racks becomes 1.05 fps instead of 1.01 fps.

170. Page A-43 :Fixed fine screens are at forward side of intake where bay is 14'-10" wide and is 26' at mean low water. Therefore, velocity is 1.34 fps instead of 1.44 fps. 171. Page A-44, Item lb :Only 1/3 of the liquid in the flash tank would flash to steam in the absence of any cooling. It shouldbe noted that the blow-down flash tank is equipped with a spray system-from the city water supply header. Cool water will be sprayed into the tank to condense flashing blowdown. This will result in a significant reduction in the quantity of steam released and hence in the amount of iodine released. In addi-tion, after completion of the blowdown in-tertie, flashing steam would be routed to the Indian Point Unit No. 1 condenser. Since the partition factor for iodine in the condenser is very high, this would essentially eliminate this source of acti-vity whenever the Unit No. 1 co.ndenser is in operation. 172. Page A-45 :See Comment 68. 173. Page A-45, Item 2a :Reference should be to Supplement 15, Page Q11.1-19, not Supplement 5. 174. Page A-49 :References not listed. 175. A-77, Altern. 2c, line 3 :Drift for mechanical draft tower should be

0. 1%.

176. All reference lists should be modified to reflect the added references used as a result of this reportl 8 l

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A^,ry..12. Y. 12201 DIVISJION' OFi PURE 1.1ATrlP.S C o. e-Rovermber 4,1 1971 Mr. Harry G. Woodbory Executive Vice President Consolidated Edison Company of New York, Inc. 4 Irving Piee. 1Vew York, Ne,,' York 10003

Dear Sir:

C- Re: Outfal]. Construction Indian Point Nuclear Station Buchanan (V), Westchester Co. Transmittal The consttruction permit for this proaect, dated Aovcmb-r 4, 19l71, ip attachied. This permLit shall superscdc a~l prcvlo',zs permits and the instructicns below: for operating' permit issuance provide the basis for futui'e discharge control. One approved copy of the plans is enclosed. Permit to Construct 0 This permit carries qualifying conditions:

1. Permit filing

2. Revocability and modification

3. Construction conformance

4. Start of operation

5. Construction supervision

6. Construction certification

7. Constriction time limitations The attached construction permit does not constitute authority to operate the epproved facilities. Please note instructions below regarding operation permit.

182

m.r. Harry G. .'ocdbur-, Novaii-ibcr 4, 1973-Perml-.i -o O;)_erate Pursuant to 1,rovisions of Part: 73 of Title 10 of the official compilation of Codes,-Rules and Regulatioons e` the State of New.. York, a permit to operate the cons:truction f,-- ..ities is required.

           )competion of the facilities,         application for the permit to Upon co      .                                                        1 operate should be subm-itted to the Bureau of Industrial Wastes of the Ve*w? Yorl, State Department of Enviroinmental Conservation, 50 Wolf Road, Albany, New York 12201, acco:Lpanied by a certificate of construcLioa compliance, executed by the New York State. licensed professional engineer supervising construction.

The Bureau of Industrial Wastes has previously contacted you to provide applic.ti.on fors and instructions for the ope'ating permit. The attached permnit authorizes const-ruction of an effluent cha;nnel and diffuser whose hydraulic capacity is rated at 3,020,000,000 gall.ons per day. It shall not be inferred that this authority to construct commnmits the Department to allow operation at the ratfed cap*.ciLy. Seriodos queS.tilns concerning the accectabiliity of d is-Oa-r--z of heatr-d waters from the operation of all threeunits at -raidi,., Poi-nt remain , cz. Destruction of the previously approved outfalls for"units one and two to facil.itate construction of the intake and outfall for unit three is noted. The Deoartment will, upon completion of thes.e faciliLies, mnd receipt of your application, issue an operating permit for units one and two. To obtain an operating permit for unit three, it musC b6 conclusively demonstrated by Consolidated Edison Company that the "thernmal criteria relating to limits and distribution of temperature andthe thermal standard relating to conditions non-injurious to fish life will. be satisfied. It is also necessary to define and verify predictions made from mathematical and hydraulic models to correlate actual. operations of units one and two to conditions postulated for unit three. The conclusions drawn by your consultants from studies done to date cannot be accepted as representative of conditions that will prevail after operation is established. 183

M4r. Harry G. Woodbury November 43, 1971 Field work to assess actual c-rxditions and effects of units one and two, to supplement theoretical projections is essential. To this end, it is requirek that extensive temperature and ecological studies, on a programr to be agreed to by the company ard the vari-ous agencies involved, be conducted and reported to establish the basis for the un'it three operating permit. The Department of Environ-mental Conservatiouns Bureau of %lvterQuality lManagement in the, Division of Pure Wlaters, and the Division of Fish and Vildlife, will providce details of sdrveillance to satisfy the Departament on physical/chemical and ecological parameters respectively. An analysis of existing and projected thermal loadings on the Hudson River estuary portion, which includes you. existing Indian Point site and the proposed Verplanck site, have indicated a future heat load which would be unaccepiable. Therefore, you are formally advised that any further units proposes for Indian Point or for Verplanck will require cooling facilitics to reduce cooling water temperature to essentially intake arabient temperattire. The basis of approval at this'time is the conrnittment by Consoli-dated E6ison to:

1. Provide installation of adjustable gates, prior to unit tw.o operation, which will be controlled to maintain, under all sequences of unit one and/or two operation an average discharge velocity of not less than ten feet per sccond, and

2. Investigate, design and construct a new intake struc-ture for all units, with intake screens upstreamn of all units, as proposed in the environmental. report, as expeditiously as possible.,

Number one is incorporated in plans approved herewith, and the construction completiorn dhte considers that comnmercial operations will not take place for unit two before completion of approved facilities. The intake completion and a demonstration of its efficiency must precede coinnercial operation of unit three. The instream verification studies required above to support a unit three operating permit application must include data on the new intake structure. 184

Mr. Harry G. Woodbury Nlovember 4,1 1971 The requiren-ints for followatp, testing, and irieasuicment programs are consistant with those which have been and will be Lnyosed on other utilities to det-ermi,.e complia,1 ce with criteria and standards and verification and refinement of mnathemnatical and hydraulic model studies. Consolidatbd Edison has not been singled for any special restrictions nor is any more exý.cc ted frczn the company than of any other discharger, which is, compliance with all applicable laws, standards, criteria and rules and regulations officially adopted by New York State. The above por:tions contain that material from the May 19, 1970 and December 10, 1970 approval letters ,-jich are considered pertinent and applicable, adjusted as necessary to reflect accoimnodation of unit two in the approval and the basis of operating permit therefore. Acceptance of the enclosed permit and initiation of construction will constitute agreement by Consolidated Edison Company to the. conditions of approval, including the :-estrictions intended to be imposed on its future operations. Very. truly yours-, '// Thomas E. Quinn P., Chief Industrial FacilitySection TEQ :It t" Attachment cc: New Paltz Region 173 Bureau of Water Quality Nanagement Division of Fish and Wildlife 185

5I...IJ .. JX\ +/-i .r nl1.1 . .%r I. JJY;,jA'J '. .L:.iVpi+/-  ; PERMIT TO CONSI'fUCT A WASTE DISPOSAL SYSTEM ,M5 pdtM4 unse theŽ of tiiU2 12 of th'e Pic el lf.ýMlaw n.,i NYCIMT71. ~ Consolidated Edison Indinan Po r.nt Company of N*ew York, Buchanan (V) Westchaster Pox.;tr Vucl':ar Inc.Iplw y, inlitiati; co~n:ruct;on of the approved .vo*-ks, the permitree accepts ind agrees to abide by arid conform withe followVing: 1, THAT the consrruction permir shall be maintained on file by the pcrrmhItee. A

2. TIIAT the permit is revoc--,ble or subject to ,::odification or chang-e pursnant to Article 12 of the Public licalhh Law.

3. THAT the f:cilicies sh0ll be ful!y construtted and comp!eted in complirance wvih the enpinecring rel oil, plans -"nd specifications a*s app:ovcd.

     .. TIAT the facilikics shall not i-c placed in o,-erstion until construction has been copletcd aA. an op*.ation                      i, has been issucd, o. unless ordered to be ocrated by the Commissioner or by a Court.

THAT t!,e construction of the facilities shall be'under Ote swpe'rvisi.n of a person or fir n. ' !.;ic'J to pC ctice pro-fcssional engineering in the State of Ncw York under the Education Lgw"of the State of N.w Yo:l:, "'henver cngineer-ing services are eqpiired. by such law fr'r such purpnses.

6. THAT where such faciliries are under -he supc-rvisiorr of a professional eu:gineer., he shall ceriify to the f);,.ittent and to the pertrirtee that the constructed facilities ha'c been undevhis supervision and that the works ',ai. 1:cn fully cc'rn'lltcd in accorda.nce vi:h the approved engineering reports, plans, sjecificfztio;is and permit.

7. t THAT th')' consicucion of the focilities shal l com*,-ene.Ly DCCCtI*L1 1971 r.r.d be fully ccmpte-.d by Ma.__ 1972 , but in any case shall be u~fp1.L p,:i3Z to CCz~zcz=Ca*'-ýroi .. 1(.al. P.*..L UL;LL;.L i~i I.. 186 ISSUrD I'?'TflE STATE'CM-.15',;SSIOI':,! OF DATE Env iyo.-,iental -Consec-rvat ion -

                                                                          -,at~ -       .,         " "l-t",        'LO t/4/71L  *-,"

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6. T)'po & 1-tu- of Construccio.:

[] 2 Alii: cr Alterations ,r-2 Add:tic- or Altorcti-ns T. E zlirnotod Coilt M Cc,nitruticJn: Co!.cti-n SY:1-m Treotmoni ond/u; Dispoaol r'. Type. of V'fc!:tc: [71Se%'0;, *EiIJ c~r~striy_ O. o oJ er_ Specify - .pcf-o  !, -a e

r. Pc~roa ~t ~rrctnt:

Y. 1e, Croeo f T c ~ -nt: 0 1 N n [2] I Son L[- 3 Pri4nory 11s Scondery Q-- . Conp'ole. LIII Spiic S Tcoic *J nA ntormodicte L6 6 Torliory

10. Point of Dischzrao: Maoier Dr: .:*e, Locclion (C,.V.T),-uTchanan _N) Basin Lower ].lu-Oon Surloce Watoer: Nomne of Y'.orcc*u;se Surface Wto:er Class. SB' Ground Wotcr: W4crne of W.'ctcrcourse lo which Srourn water is triL.ctory Ground W!oter Class I Rc.-ce_*-in; Teo..nnt W0 .*: 12- Mrod, rf PInnt Ope rotor 13. Dishi- ift-tionR.,~rX Required:

1\1/A __ ___ N/A [t- Conin.ous "T] 2 .,*-.,on X Noo

14. D-sign Flow (Gols./doy}: 15. .esin, Equiv.alent Popu~ction 16. Desion Plont l.*fhcio;,cy (ý. DOD +cr,*ovol):

(BOD U:sis): 1N/A 3,020,000,000 N/A Description or wor*s, such os nu ea}cr, no:ne crnd spity oura;1I$: one effluent channel with submerged diffuser: 252' side open channel with twelve (12) submerged openings, six. (6) by fifteen (15) feet each, with thirtee n (13) foot ceifterline depth submergence, including eleven (11) adju stable ports, as detailed on C]; drawings "A1080436-4, A183340-1 and AlS 3339-1 of Consoli4dtcc Edison Cd" Company, with control gates adjustable to any intermediate stop position in such ports. 187

"ConsolidJted El;son Cc .:pany of flew York. Inc. 4 Irving PM-c. New Yck. N Y 10003 Tc:lphoner (212) 460-001 October 15, 1971 Mr. Thomas E. Quinn Lhief, Industrial Facility Section New York State Department of Environmental Conservation 50 W.olf Road, Room 308 Albany, New York 12201

Dear Mr. Quinn,

In reply to your request (October 8, 1971) for justification of the proposed Indian Point outfall modif.ication this description and these model results are provided for your review. In early 1971 review of the previous undistorted model tests, and recent theoretical results indicated that .tho earlier tests should be rerun to verify that the design was cptimized. This was done in an expanded undistorted Outfall iModel simulating half the River's width and nearly a mile of its length. A numJber of variations on the present design concept were tested. The changes incliuded raising the ports above the discharge canal floor, increasing the port spacing, increasing the exit velczity, and dredging below the river side of the dis-charge canal bulkhead; The test series clearly showed that raising the ports resulted in more rapid decay in surface temperatures with distance from the outfall. Dye observations in the model showed that th-is effect results from the entrainment of cool deeper water into the jets from below. Model isotherms for both the original scheme and that for raised ports at two different tidal velocities are attached. 188

The outfall design now proposed would consist of twelve raised ports (centerline submergence - 12 feet) each measuring about 4' x 15' when opened (see "Gate Assembly" on Dwg. A183339-1). Closable gates are provided for the. i0 openings along the northern portion of the discharge canal. The southern-most two openings have removable gates allow-ing each opening to be either-4' x 15' 6z) 9' x 15' (see "Removable Gate" on Dwg. A180436-4). This combination of adjustable openings allows complete flexibility in the discharge operation. For two unit operation the circulating plus service water flow will be approximately 2600 cfs. This effluenc will initially be discharged at 10 fps. "contracta" exit velocity through seven 4' x 15' ports. The seven ports will be numbers 1, 3, 5, 7, 9, 11, 12 listed north to south. Field measurements of the thermal plume rý-3ulting from such operations will be made in the sursacer of 1972 and compared to the model results. The various port openings will then be adjusted by trial so as to minimize the surface plume extent. On the basis of the model tests described above my letter of Supt-_,'-cr 29, 1971 roiruests issuance of an amended con-struction permit. We believe that th'i1 description of model tests and planned operation justifies our decision but should any questions arise please call on us for a prompt reply. We request a technical meeting with the Departienr of Envirornental Conservation in the near future to discuss the followzing points: (1) How the initial field measurements will be made. (2) What numerical parameters will be used to compare the field measurements with the model results.' (3) What procedure will be used to "fine tune" thegate* openings, and (4) What mode of discharge will be used in winter. We appreciate your prompt action on behalf of this request. Very truly yours, 189 zr Harry G. Wcodbury TEP/lo bce. Carl L Newman William J Talbott 3-A. P"~ L

I3L

                                                             )AN POC'[1,T Hi1. I/5      0   .
                                    .-    - "    CHA GE,                           SCALE        1"-250' "           .,'..

Si ( S-F"4-CY TEST CON'1TIONS 1.: DIJC'4AAGf *(~f* CO'DZNSm RISI 't

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r'el % - I? 1 3 Ii S SCALE 1"-250' 1*1

                                                                                                 /

1~ I TEST CONDITIONS TtSI NO. _24 CA1E .. _7_ .19'1 U;: TS , O;SCXAAIE c!s , CONO:NS'.. RISE 'F R;V.a CURENT - O.4-,r (Ps t:H A * - T, I. SSA LYDDAULiC MODEL STUO:.,s 7,N, -t- CON-SOLIDATED E D'ISON C0,',Ap 8', 05 ~W Yo,-'

f V)

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               ~ITA:TS                               ',, c                                         ISCALE   l'"250' 2z TEST CON'DITIONS NO. OOATC
               .                          .   ,       .71                                                                                         e*

U';T !Cý;- clit CONDTNSER RISE 7F ~IvIv R CU7:PEý4 .0. 4- Ic' A V'I EMP. E C' .,F 0:,H A*TA'TF A~rl ~ HYflAtJCMODEL SiUýýiS bS / ., .... .*, ,,., .. .. . CO

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                                                                                              -. r CD sTEST CONDITIONS U'4.: TS . DIS.AGE        CfS . CONOENS.R RISE 'F A.%4IENT TEMP.        _7j.:'j_.'

P00i ...;P* Ar'/bý '76. 4.*'F CfF:. O YDRAULTC MED O0L CO* t,. '.:YS L:zN.Z'CONSOL;OATED EDSON COtiPANY COF NEW -Y0%

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      '~"                        AT~

Fig 011-Indian Point Site

tB CD

                             'I I

( i li-; -' h

       -              46 I- -

AVERAGE TEMPERATURE RISE UNDER VARIOUS FLOW CONDITIONS

                        % of                % of          Total     Average Total Flow            Total Flow  Discharged Temperature Units Operating                                                            0 Through Condenser      Recirculated      Flow     Rise;, F 1    2    3        1     2    3           1      2  3      g-pm x     -   -       100                    0       -  -    280,000      12.6 x    -             60    -               0       -  -    168,000      21.0 x    -             60    -           .1-u        -  -    140,000      25.2

- x - 100 0, - 840,000 14.9

 -  x             -     60                      0  -    504,000      24.8
 -  x             -     60                     LO  -    420,000      29.8
 -  x    -
                  -     60             -     4  0  -    336,000      37.2 x    x    -       100   100          C           0  -  1,120,000      14.3 x    x    -        60    60          C           0  -    672,000      23.9 x    x    -        60    60         ic          LO  -    560,000      28.7 x    x    -        60    60         iC           0  -    476,000      33.7 195

Appendix B-I Detailed Comments on Thermal Discharge Aspects of AEC Draft Statement, April 13, 1972 The Draft Statement addresses the environmental aspects of the com-bined thermal discharge from Indian Point Units Nos. 1 and 2. This appen-dix clarifies several misconceptions in the Statement, apparently engendered by earlier, less comprehensive analyses which had been submitte to the AEC Staff. These comments are supplied in support of the applicant's contentions that the Statement is erroneous in its evaluation of the following four topics:

1. Net nontidal flow

a. The Staff states on page 111-35 "The magnitude of the net nontidal flow for different freshwater flows needs to be determined." Simi-lar and sometimes contradictory remarks are made in sections III E 1 d(3), III E 1 f(4), III E 1 g(5), and Appendix II-1.

b. The Applicant has demonstrated through extensive analyses using several independent methods (see Chapter V, reference 9), how the nontidal flow depends on freshwater flow. The final two unit predictions (reference Ui) use the minimum -most conservative) estimates of the nontidal flow that can be obtained. The efforts of the applicant's consultants represent a significant advancement in methods of modeling such estuaries.

2. Maximum river ambient temperature

a. Staff concludes on page 111-35 "the maximum river temperature can be above 810 F in August." This conclusion Is subsequently used to imply probable noncompliance with 900 F maximum surface tempera-ture criterion.

b. Applicant has demonstrated and will outline in these comments:

(1) The source of error in the Staff analysis. (2) The applicant's consultant statistical analyses of ambient tem-perature.

3. Far-field heat dissipation

a. Staff maintains on page 111-37 "The adjustments made to the original model by arbitrarily using correction factors so that the results will agree with only one set of observed data from operation of Indian Point Unit 1 and extrapolating the model to predict the effects of Units Nos. 1, 2, and 3 together is unjustified."

19G

b. Applicant used all available data to calibrate the models presented.

The models have now been tested in numerous applications and have been verified. The model development and verification has at all time been beyond the "state-of-the-art". The summary analyses inre-ferencellemploy no empirical adjustments; they are theoretical predictive models which show remarkable agreement with the inde-pendent physical models.

4. Physical model .results

a. Staff makes reference to the extensive physical modeling program only in twelve lines on page III-34, apparently disregarding those results.

b. Applicant maintains, as in the original 1969 report, that the mathe-matical and physical models are independent, illustrate remarkable agreement and should be reviewed and interpreted as complimentary predictions.

197

1. Net Nontidal Flow The Draft Statement, in its discussion of Net Nontidal Flow, attempts to summarize and evaluate the application of this concept to the Hudson River at Indian Point. The Statement does not convey a consistent evaluation as to how the concept should be applied.

Table 1 summarizes results of the density induced circulation studies detailed in references 8 and 9. The table compares the velocity and salinity approaches. In general, the salt approach exhibits several favorable charac-teristics such as relatively more stable and predictable distribution, more independence of temporary meteorological and local eddy conditions, simpli-city and availability of more precise detection instruments. The end result of these advantages is, of course, a more reliable measurement which makes the use of salt more attractive from a practical standpoint. The salt approach results were also used to introduce some degree of perspective to the problem and to determine seasonal variation of upper layer flows since most of the available current observations were made during the summer months. When the freshwater flow exceeds 20,800 cfs at Indian Point, the river changes from a two-layer to one-layer system having a net flow in the down-stream direction from top to bottom. This flow value represents the incipi-ent salt flow at Indian Point and may occur during May during certain years. This critical value of freshwater flow may be obtained from Figure 1. The long term monthly average upper layer flows are shown in Figure 2. In conclusion several methods of estimating the net nontidal flow have been evaluated. The Staff recommends use of salinity data on page 111-27 of the Draft Statement and the applicant concurs. Statistical analyses using different methods of interpreting salinity data lead to estimates of upper layer flow from 35,000 to 92,000 cfs. Since the less accurate velocity method resulted in lower values of upper layer flow, the applicant has used this most conservative value obtained, approximately 21,000 cfs in their evalu-ation. The applicant's methods of analyses have employed established princi-ples to advance the scientific state of estuarine prediction techniques. 198

TVi0 MD1D BED DEM1JjTERKJJIZERS OlE CATION 41 TrMEE CVCS HOLD-UP TANK - 8,500 CU FT EAI -- JFOUR FVAFORATOR FEED DMITUNERALIZES j I

          -m2DRLIZ.R 75-0 DEB3ORATIri;G D*j:L'-,M-AL-ZE.S CD CD                                                                  BORIC CCNC,.ElT,7, 1O        TANK
                                                                              ,:TN,,- - 800 GLC TMREE ,'.OrITOR VOLU1,E CONTROL -                                           I TV-O  BORIC ACID T2ANT3Y       TAMMh3 - 7,500 TA!NK - 40O CUFT                                              8,000 GAL EACH           I      GAL EACH IDmARGE Cti1AL PRIUfluY WATER STORAGE TANI - 165,000 GAL 75 TO 120 GF74 PRIl.ARY COOLANT PURIFICATION IN 4-ICAL NDIN VPOL      COINTROL 53YST24 - In!IAN POINi MUIT, NO. 2                                             G     E2 F IGUR*E 2

TABLE 1 COMPARISON OF LOWER HUDSON UPPER LAYER FLOW USING SALI1NITY AND CURRENT OBSERVATIONS Upper Layer Flow, Thousand cfs

                                         -- Summer Conditicns    --

Reference 8 Method Figure No. Indian Point

1. Current Observations 7 21.5

2. Salinity Surveys a) Salt Budget Method 1961 22 90.0 1967 23 92.0 b) 'Two Layer Flow Method All Salinity Surveys 24 35.0 Generalized Salinity 26 35.4 200

Tw~o Layer System oeLyrSsm (Salt Present at Bowline)-ý 71<~ N alt at BowlieTI

                ...              .             ...                                                                ..... I        ,     .
                                           -                                                    117 0.
                                                                -- 1-~~-
                                                                                                                                                   *

• I I. -

J m 77

                                                                                                                                                                  *.... 77
                                                                                                                                                                        . 77.. 1. ...

or: 7: HUDSON RIVER UPPER LAYER FLOW - .0

                 - rESHWATER FLOW RELATIONSHIP                                                   L- V rI.
                                         , I,               -'I         +

4.4 t - __ I*-

                                                                      -       + -   I - + -~--4         -~
    . 2                      it*
                                                                                                                                                                               -:77 7:1 7           :      --    -- -.

I I -

         -Salt                   present at Indian Point II                       "              Freshwater I             ..  -        No salt at Indian Point'
                                   "'" '- ' Observred Freshwater nge
      ..      "       I I

.I - .. .--

                                   -         9     " -
     ' I+             + +

i+ C 15 20 25 -30 35 I-Lower Hudson River Freshwater Flow in Thousand cfs

FIGURE 2 1 r~r T-:.:i' I~iivJ r I .- Il j I1J1-HUDSON . RIVER

                                                                                             @BOWLINE               "*
                                                                                                                            .    .     ..I

_______ I J I I.!j SEASONAL VARIATION IN-i7 FRESHWATER FRESHWATE R-FLOW AND .- II K 7 -- J

• K'i1I'17'L] ( UPPER LAYER FLOW I:

I: I.:I :BASED UPON LONG TERM MONTHLY. I..

 ~j   2
            ,  T                            .   .
                                              ~d.

AVERAGE FLOW (1918 1964) I. SI. w.. . w ELIt-I !_ ttL ff- -I---

1 f4il _L;i RiEla ... ... .... .... ..

                                                                         -.-. ~            -     i I     i d  (
         '41 I -         -      +-    &-      -    +  -  .4-    - * ~..

I'EW/-RD FLOW-@ BOWLINE ( , 7~~:1;j1 _J777 I, j a. j JI 32 w6 1_`__ :I ,~i .- 26 -.. _ ___ 77:Ij _ 0 124* _ _ ___ E-4 0 NIE L. 1_ .. .....__ 16:~i _ 444H2L JAN FEB MARCH APR MAY JUNE JULY AUG SEPT OCT NOV " DEC --. I--. ; 1~~1~1i I l

2. Maximum River Ambient Temperature The Draft Statement maintains that "Report of Inquiry into Allegation Concerning Operation of Indian Point 1 Plant of Consolidated Edison Company" shows river ambient temperatures of 810 F. Certainly it is clear that an extensive body of temperature data exists beyond this simple source. Our consultants have analyzed all existing data and these analyses have been described in Dr. Lawler's Supplemental Study dated May 1972 (reference 12, pages 1-3 through 1-5). The comments below are, in part, based on that re-port.

The New York State regulations define ambient temperature implicitly in NYCRR 704.1 where estuarine thermal criteria are specified. With regard to the 40 F heating limitation that section reads in part: "...shall not be raised to more than 4 F over the temperature that existed before the addition of heat of artifical origin..." The data presented in the Staff reference indicating a temperature of 810 F were obtained while Lovett and Indian Point were operating and were not measured at the Indian Point site. Thus, these temperatures measure thermal plume effects not ambient intake temperature. Furthermore, the data were accumulated with uncalibrated thermometers normally accurate to only 110 F at best. By contrast the appli-cants' consultants' data analysis in reference 12 was based on measurements using Bureau of Standards calibrated thermometers and employed statistical methods in documenting the use of the 790 F maximum ambient river tempera-ture at the site. The Draft Statement references Attachment B-3 of the Report of Inquiry referred to above for its finding of the 810 F intake temperature. The same report contains an exhibit designated Attachment B-2 which shows tem-peratures specifically at the intake of Indian Point 1 for the summer periods of 1967 and 1968. The highest temperature indicated is 800 F which occurred on six days in 1967 and no days in 1968. Since the present outfall structure had not been constructed, recirculation effects would be greater at that time than would be expected from the present configuration. The Draft Statement makes no mention of Attachment B-2. The Draft Statement uses the 810 F hypothetical ambient temperature to criticize the applicant's conclusions that the 900 F maximum surface tem-perature criterion will not be exceeded. The applicant's submerged discharge model is fully explained and documented in the Supplemental Study of May 1972 (reference 12). We understand that this document was not available to the Staff when it prepared the Draft Statement. The model is conservative, uses published parameters where needed, and agrees with physical model results, from the undistorted model of the outfall. The physical model tests are more fully described in the comments below. (See #4). The models predict a maximum surface temperature of 880 F. In summary, the applicant maintains (1) that the maximum ambient river temperature is 790 F, based on statistical analyses of available data; and (2) that the effluent will be diluted to aa 4 y meet the 900 F maximum surface temperature limit. 203

3. Far-Field Heat Dissimation The Staff Draft Statement critically reviews one of the applicant's first generation models used to predict the expected temperature distri-bution associated with three unit operation. The Lawler Testimony submitted to the ASLB on April 5 (reference 11) is a much more concise and complete description of the essence of these models. We understand that this docu-ment was not available to the Staff when it prepared the Draft Statement.

In fact, the April testimony employs no empirical corrections to arrive at predictions that two units will meet the 40 F New York State Thermal Cri-teria. In point of fact, the applicant has supported the extensive development of the heat dissipation model by the consultant, QLM. Subsequent to the 1969 reports, apparently used by the Staff in their preparation, the model has been applied to numerous other outfalls and has been verified using field data as outlined below. A. Applicability of the Overall Mathematical Models to Thermal Discharges The heat dissipation mathematical models, and in some cases modified versions of these models, have been used to evaluate a number of existing and planned effluents and waterbodies, including the following:

1. Existing Plants

         " Albany Steam Station
         " Danskammer Station
         " Lovett Unit 1-5
         " Indian Point Unit 1

• Arthur Kill Plant

         " Astoria Units 1-5

• Ravenswood Plant

2. Proposed Plants

         " Roseton

• Indian Point Units 2 and 3

         " Standard Brands, Inc.

• Astoria Unit 6

         " Bowline Point

• a number of other future generation sites

3. Water Quality Models

• The Hudson River - NYSDEC

         " The New York - New Jersey Estuarine Complex   - ISC, NYC, NJDH
         " The East River - NYC

• several waterbodies outside New York State In addition, subsequent analysis, summarized in Table 2, of available temperature measurements in the vicinity of other Hudson River existing plants indicated existence of upper layer flows close to those computed using the above described tidal current and salinity approaches. These results support the capability of the density induced circulation concept to explain temperature observations.

204

0 TABLE 2 Observed Heat Load, Upper Layer* Plant Survey ATo, -F BBTU/Da7 flow, cfs Danskar7er 1969 QL&M 0.146 47.3 32,000 Lovett 1969 QL&M 0.152 57.0 37,800 Lovett 1970 QL&M 0.175 41.7 26,200 Indian Pt. 1 1966 NBI 0.200 37.4 20,900

• Computed using temperature observations 205

B. Presentation of Study Results In order to select the most severe set of hydrology and meteorology that can occur in the vicinity of Indian Point and to compare results of the various models used in this study, a plane of discharge counterpart of the mathematical model may be used. For a given location outfall design and known fluid characteristics, this model reduces to: AT =H = _H 0 -F2- R--E Qd in which: AT = Area-average temperature rise at the plane of discharge, OF. It 0 is used here as a measure of the response of the Hudson River to thermal discharges. H = Thermal discharge, BBTU/Day

             =  Heat transfer coefficient, BTU/sq. ft. day 0 F. It is used in this model to define the influence of meteorological conditions on the distribution of temperature.

Q = River freshwater flow, thousand cu.-ft./sec. E = Longitudinal dispersion coefficient, sq.- miles/day Qd A heat dissipation parameter reflecting the influence of flow availa-ble for dilution of thermal discharges and of heat transfer to the atmosphere. In the case of the convection-dispersion mathematical models, Qd combines the influence of Q, K and E. In dealing with a tidal smoothed temperature rise averaged over the entire cross-section within a salt-intruded reach of an estuary, Qd reflects the influence of the seaward directed upper layer flow, Qu' and landward directed lower layer flow, QL" This definition of Qd has been selec-ted to insure consistent comparison of the convection-dispersion and density induced circulation model results. However, since an inherent-ly stratifying discharge, such as is a thermal effluent, rises to the surface and tends to stay in the upper layer, only the upper layer flow may be used to predict the distribution of temperature in the seaward directed layer.

d. & f Constants defining the influence of river geometry (A,B), outfall design (TSF), and water quality (P,Cp). At indian Point, use of A, B, TSF, P, C of 160,000 sq. ft. , 4,000 ft., 1.5, 62.4 lb/cu. ft.

and 1 BTU/#OF respectively, yields &= 0.185 and ý= 0.23. A comparison between the various hydrological and meteorological conditions and models presented using this equation is given in Table 3. The study results of Table 3 indicate that an incipient salt flow condition occurring during certain winter months represents the most severe set of hydrology and meteorology that can be expected at Indian Point. The thermal effect is less critical during the other months due to availability of high freshwater flow and heat transfer rate and/or density induced circulation associated with ocean-derived salt intrusion. In order to predict the maximum expected effect, the incipient salt flow condi-20G

TABLE 3 COMPARISON BETWEEN VARIOUS HYDROLOGICAL & METEOROLOGICAL CONDITIONS AT INDIAN POINT & STUDY MODELS Q Qu E 0T Condition Model tcfs tcf s smd BTU/ft2 *Fday OF/100BBTU/day A. Indian Point within Salt-Intruded Reach 2 Drought-Fall Conditions C-D 4.0 12 90 0.84 DICC 21.5 0 0.48 DICS 35.4 0 0.28 Average... . .. 0.53 3 Summer Conditions C-D 4.0 12 -135 0.69 DICC 21.5 0 0.48 DICS 35.4 0 0.28 HYD 4.0 0.2 130 0.58 Average.... .. 0.51 B. Indian Point outside Salt-

    .Intruded Reach Incipient salt flow           C-D          20.8       -        6          120               0.76 C-D          20.8       -        6           90               0.78 Winter or Spring flow          C-D          28.0       -        6           90               0.62 C-D = Convection-Dispersion model                       2 Based upon Table 10 of Reference 3 DICC. Density induced circulation model -'upper         3 Based upon Table 12 of Reference 3 DICS layer flow computed using tidal current and salinity measurements, respectively.

HYD = Indian Point hydraulic model

tions were used in this study. The combined effect of rated capacity operation of Lovett Units 1 through 5 and of Indian Point Unit 1 and 2 is expressed in terms of and compared with the New York State thermal discharge criteria in Table 4. These values have been computed using an overall convection-disper-sion model capable of handling variable system parameters, including heat loads, within a number of consecutive river segments. To convert the overall response to near field behavior and to permit evaluation in terms of the NYSDEC thermal discharge criteria, the exponential decay model (from reference 3) has been employed. The surface width criterion, that no more than 67% of the river's sur-face width may experience temperature rises in excess of 40 F, is the most difficult of the criteria to meet. This conclusion has been found to be valid in numerous cases including Albany, Danskammer, Roseton, Lovett, Bowline, Arthur Kill, Ravenwood and Astoria Plants. The results of Table 4 indicate that in all cases, the predictions are substantially less than the New York State thermal discharge criteria. Table 4 results correspond to rated capacity operation of Indian Point Units 1 and 2 as well as the existing Lovett Units 1 through 5. 208

TABLE 4 PREDICTION OF 40F AREA AND SURFACE BOUNDARIES AT INDIAN POINT FOR THE MAXIMUM SEVERE CONDITIONS A. Conditions Incipient Salt Flow 20,800 cfs Heat Transfer coefficient 2 90 BTU/ft day °F Dispersion coefficient 6 sq. miles/day Thermal Stratification factor 1.5 Critical tidal phase to tidal average location ratio ... 1.35 Heat Load (Rated Capacity) Indian Point Unit 1 ... 265 MIE or 47 BBTU/Day Indian Point Unit 2 ... 873 ME or 153 BBTU/Day Lovett Units 1 - 5 ... 503 MWE or 57 BBTU/Day B. Study Results Percentage at Indian NYSDEC Parameter Tidal Phase Lovett Point Criterion

   % Width bounded          Tidal Average          24          23           67 by 4°F               Critical Tidal Phase       32*         31
   % Area bounded           Tidal Average          16          15           50 by 4*F               Critical Tidal Phase       22          21 Maximum surface      Critical Tidal Phase              87                90 Temperature, OF Area average             Tidal Average        1.79         1.75 Temp. rise, OF Surface average          Tidal Average        2.69         2.62 Temp. rise, OF This value is based upon a maximum surface temperature rise (ATsm) of 8 0 F.

To generalize the results, other rises have been investigated. Use of ATsm of 6, 7, 9 & 10*F would yield a maximum critical tidal phase % width bounded by 4 0 F of 28, 30, 33 and 33.5%, respectively. 209

4. Physical Model Results The Draft Statement refers to the existence of a physical model (on page III - 34), but does not interpret the results or critically review the data. Significant aspects of the physical model program are outlined below.

In the winter of 1967-68 a model ( Model I1) of the Hudson River simu-lating 9000 feet above, and below Indian Point was constructed at Alden Re-search Laboratories, Worchester, Massachusetts. The layout of Model II which was scaled 1:250 in horizontal dimension and 1:60 in the vertical, is shown in Figure 3. In order to optimize the outfall design, an Outfall Model was constructed at Alden. The Model was undistorted, scaled 1:50 and simulated 900 feet along the east shore and 400 feet of the river's 4,000 foot width. Tests of various outfall designs were conducted using the model through the Fall of 1968 and Spring of 1969. The current thermal criteria led to selection of the outfall with 18 feet submergence. The predicted temperature distribution created by the plant dis-charge through the outfall is presented in Figure 4. The expected near-field dilution, at the point where the plume reaches the surface was shown by this model to be approximately 1:2. Tests in the distorted Model II were conducted with this submerged out-fall. These tests simulated two unit and three unit plant operation and in-dicated that the transient thermal plume would comply with the thermal cri-teria. The model results are presented in the Alden Report: "Indian Point Cooling Water Studies, Model No. 2" (May 1969), reference 10. A subsequent critical review of the results, however, suggested a need to confirm the near-field results in that they appeared to indicate less than theorectically predicted mixing from the submerged discharge, and hence dis-tortion in the results observed in Model II. The undistorted model was ex-panded in 1971 to simulate 1800 feet of the river's width including 2500 feet downstream from the Indian Point outfall and 1400 feet.upstream at a scale of 1:50 including the features of bottom topography. Recent re-testing in the expanded model of the outfall with 18 feet sub-mergence confirmed the 1:2 dilution which had been measured in the smaller Outfall Model. In an effort to further improve the efficiency of the outfall, tests were run simulating a wide variety of new outfall configurations. As a result of these tests the decision was made to raise the ports to a sub-mergence of 12 feet, to improve effluent dilution. The near-field tempera-ture distribution for the raised port scheme, according to the Outfall Model tests, is shown in Figures 5. The mechanism by which this increased jet efficiency occurs is entrainment of cool water from beneath the ports. Whereas previously entrainment was limited by the presence of the bottom, the outfall design with raised ports indicates substantially increased dilution, especially at points several hundred feet from the outfall. Figure 5 shows that the dilution affected by the raised port outfall scheme will result in a maximum surface temperature approximately 80 F above the intake temperature. With recirculation amounting to 10 F average, and a maximum river ambient temperature of 790 F, the maximum surface temperature is not expected to exceed 880 F. It should also be noted that the surface area of maximum water temperature is exceedingly small, approximately 0.1 acres. 210

INDIAN POINT Ill MODEL GENERAL ARRANGEMENT MODEL RATIO FROM POND 1:250O 0 10 20 FT. HEAD TANK TIDE CONTROL TIDE GATE HEAD TANK TIDE CONTR( TIDE GATE Figure - ;3 Indian Point II Mod-l - general arrangement.

OUTFALL CONFIGURATION CHANNEL DEPTH BELOW M.S.L.20' NO OF OPENINGS 12 DIMENSIONS 4'x f5'

                              -suryrm    cffTc               DISCHARGE TEMPERATURE ÷44 RIVER VELOCITY .0.4fps AWL CHANNEL TO RIVER f.5
                                                ý40 RATIO  ATMAx(RIVER)   = O.so
                                      ý2                            ATDISCH II 111*1]1         -1 T
                   =.TITI GUIDE VANES                x PROBE POSITION No                                                            ALDEN    RESEARCH LABORATORIES WORCESTER POLYTECHNIC        INSTITUTE No INDIAN POINT II SUB-MODEL MODEL   SCALE    1:50  (UNDISTORTED)

SURFACE ISOTHERMS TEST DATE MAR ' 69 Figure 4 - Outfall Model - surface isotherms with ports at 18' submergence

                                     'A'
      +/-    +               4 /        -I-
                                      "t       +
                                               + 1.
           "+/-      +      +/-           +

SURFACE I

     /

O, 750' /00"

ý-/0                                                  A7iT   14.4 *F 30'                                                     Vo 0      "foP,5

.40' _'SECT/ONi A-A"

.50' 60'     Figure 5 -

TEMPERA TJRE PA T TERN - RE VISED DESIGN A 70.4 F 7TSEC CURREN 71 f50 SCA L E MODEL 213 " HYDROTHERMAL STUDIES FCR ZAlý=ýLqlq'D75 INDIAN POINT UNITS 1 & 2 CONSOLIDATED EDISON CO.

TA7LE 11"-9 (N)

                                  -KE DISCHARGE OF C'hZYMICALS TO          MhLE            :"      ,      INDTAN POINT U.T            NOS.         I Ch as'I. c-.a 1                           M,-:.       Sustaihc@              .ix.      C-nc. at Dishar':e                  Max Release', from            NYS     w!ic-abiac Cone. c.

Releases. lhai/d'r, P,".t : Muc'on t 0 .... ,r' (n ) Žo~ LItser.erm U ChrmzalDfscnares Unit "C). 1 Uni.. .*o. 2 Lithium hydroxi:eid 2.52. 4-7),- 9Oi"C'. o o*

                                                                                                          -0,-      o.c:c. 0 3cric acicd (&oron)                        600                -00 156                 12             1.2                                                                                     0 450                                          5 Sodium,       ?:oshate           (P0 4 )    --2", 15         . -7,--Z 4-
                                                                                                                                           -'--C,    03 C-04 24                 5             (,006                     -*.- -&:ŽC,003 a c., oo 5 12" Cy        la-.
                     !cine                        2.5            12                C-'00 2-60.   "                                *-G-;-          o 7..

2.5 12 -&r.Y- 0-CCJ I Sco".iu sulfate ur a liz atnion predIuct cf 1VaOH and S0d-; un carbonate C1 otA/" 2 42.. 3 0 tc .5 0 to 0.5i 0.5 0.5 1"41 i't**;; *=chrorate

                'Cr Vi)                                                                                                                                                                a-
                                       *!        [*- .tte:,*

z := 30 0.05. NJ D.2tzr:;cntg~ --1-.-{- 0,o3 4 -)*CO aSulftace, caustic sbda, and soda ash together reprcs ýnt 5 to 10. of thc permissible concentrations of the total dissolvcd s'c.li (inS) that co-7 d icharg.d into receiving t.tcr;, sCc,..r,,;) during.fl 1 0Cor operation with 300,C00  :;pm for Un:t No. 1 and 870,000 gpm flow for Unit No. 2 of condenser c~ic:, t in the "i "Cha"gc canal.

   'alu,_s       normalized to a nominal flow of condenser coclant in tl.e discharge canal of 100,000 gpm.

I-hsf relcases wou1d occur only in the event of cva: orator breakdcwn. Sreersc*at the conc :.tration cf dissolvad solics tuat can 'o dischargvd i.to the river. f*, caa* u'.*e -in a 2% solu;ion for 3 hours to wash the Unit *o. I flue ga.*) "ssages of the superheatcrs, economizers and

                 ,    ts, 4 tinzs per ye ir and discharged ccntinucusly during the cleaning period at-;-.m                                            into a flow of 20,000 gpm of!

c olingZa;cr during U nit" No. 1 shutdcwn b,.,..zcne sulfC-erte.

     "'Coratio                treatment for 30 ninutes of-each inlet water box 3 times per week.

Intozraitent discha rge - I hour, 3 tines per week for L 30 minute treatment of each water box of 3 condensers.

In summary, the physical model results cannot be ignored in any realistic evaluation of the thermal discharge from units I and 2. The far field data presented in the Alden Report (reference 10) constitute an accepted engineering prediction of the plume. It is a tribute to the veracity of both the physical and the mathematical heat dissipation models that their agreement is excellent. With respect to the accuracy of the near-field temperatures associated with the raised port design, the expanded Outfall Model is the most accepted method in the field of hydraulic engineering for evaluation of such schemes. The Staff is correctly aware of the assumptions required in the mathematical model, yet does not recognize the significance, accuracy and simplicity of the physical model results for both near and far field temperature distributions. 215

APPENDIX A LIST OF REFERENCES *

1. Quirk, Lawler & Matusky Engineers. "Effect of Contaminant Discharge at Indian Point on Hudson River Water Intake at Chelsea, New York,"

Report to Consolidated Edison of New York, Inc., May 1966.

2. Quirk, Lawler & Matusky Engineers. "Effect of Indian Point Cooling Water Discharge on Hudson River Temperature Distribution," Report to Con-solidated Edison Company of New York, Inc., January 1968.

3. Quirk, Lawler & Matusky Engineers. "Effect of Indian Point Cooling Water Dishcarge on Hudson River Temperature Distribution," Report to Con-solidated Edison Company of New York, Inc., February 1969.

4. Quirk, Lawler & Matusky Engineers. "Effect of Submerged Discharge of Indian Point Cooling Water Discharge on Hudson River Temperature Dis-tribution," Report to Consolidated Edison Company of New York, Inc.,

October 1969.

5. Quirk, Lawler & Matusky Engineers. "Influence of Hudson River Net Non-Tidal Flow on Temperature Distribution," Report to Consolidated Edison Company of New Yorlk, Inc., October 1969.

6. Quirk, Lawler & Matusky Engineers. "Hudson River Water Quality and Waste Assimilative Capacity Study," 'Report to the State of New York Department of Environmental Conservation, Division of Pure Waters, December 1970.

7. Quirk, Lawler & Matusky Engineers. "Hudson River Assimilation Capacity Study," Report to the New York State Department of Health, March 1970.

8. Quirk, Lawler & Matusky Engineers. "Circulation in the Hudson Estuary,"

a technical bulletin prepared by QL&M in 1971.

• References 1, 2, 3, 4, 5, and 10 appear in Con Ed's Environmental Report as Appendices A, I, J, L, M and N respectively.

216

9. Quirk, Lawler and Matusky, Engineers, "Environmental Effects of Bowline Generating Station on the Hudson River," Volume I-IV, QL&M Project No. 169-1, March 1971.

10. Alden Research Laboratories. "Indian Point Cooling Water Studies:

Model No. 2," May 1969.

11. Quirk, Lawler and Matusky, Engineers, "Testimony of John P. Lawler, The Effect of Indian Point Units 1 and 2 Cooling Water Discharge on the Hudson River Temperature Distribution," April 5, 1972.

12. Quirk, Lawler and Matusky, Engineers, "Supplemental Study of Effect of Submerged Discharge of Indian Point Cooling Water on Hudson River Temperature Distribution," May 1972.

217

CONSOLIDATED EDISON COMPANY OF NEW YORK, INC. Appendix B-2 SUPPLEMENTAL STUDY OF EFFECT OF SUBMERGED DISCHARGE OF INDIAN POINT COOLING WATER ON HUDSON RIVER TEMPERATURE DISTRIBUTION MAY, 1972 QL&M Project No.  : 115-17 (Report Submitted to the ASL Board for the Licensing Hearings)

                             -218

Appendix C General Comments on Dissolved Oxygen QLM's measurements of dissolved oxygen in the vicinity of the Lovett Power Plant during summer in 1969 and 1970 and in the vicinity of Bowline Point during summer 1970 indicate that the majority of observed dissolved oxygen concentrations are above 5.0 mg/l (see attached table). QLM analyzed the data and procedures of dissolved oxygen (D. 0.) measurement by the Automatic Environmental System at Indian Point. This analysis indicated that the D. 0. measure-ment systems from the intake and discharge were not calibrated at the same time, and the calibration was made approximately onc( a month. This is probably the reason for large differences be-tween the intake and discharge readings of D. 0. concentrations. QLM made careful simultaneous measurements of the intake and disc'arge dissolved oxygen concentrations at Indian Point Unit #1 in December 1971. The tests and analytical determina-tions of D. 0. were made in accordance with the most recent edi-tion of Standard Methods for the Examination of Water and Waste Water. Water temperatures were measured using precision thermo-meters certified by the National Bureau of Standards. 219

                          -  2 -

During the survey, Unit No. 1 was operating at rated capacity and the cooling water flow was 204,000 gpm, i.e., throttled to about 85% design flow and 0 F. average cooling water temperature rise was 16.4 The observed average intake concentration of D.O. was 10.48 mg/l and corresponding discharge concentration was 10.3 mg/l. This indicated average loss of D.O. of 0.18 mg/l in the Unit #1 cooling system. These mea-surements and QLM's mathematical model for D.O. were used for prediction of the dissolved oxygen loss in the Indian Point Unit No. 1 & 2 cooling system. The results of calculations indicate that the loss Of oxygen in the system increases with increasing intake concentra-tion of D.O. while the intake temperature is hold con-stant. For example, during severe summer conditions, ,Ahen ambient temperature is 79 0 F', the loss of oxygen in the water cooling system would be as follows: Loss of D.O. Intake D.O. in the system mg/fl mg/l 5.0 0.05 6.0 0.13 7.0 0.21 The response of the river to such a "sink" of dissolved oxygen was simulated by a mathematical model 220

                          -  3 -

which included all major mechanisms affecting the river dissolved oxygen concentrations. Results of this model work were reported in a document entitled, "Effect of Indian Point Plant on Hudson River Dissolved Oxygen." A copy of this report is attached. It was determined, for example, that during summer conditions, with the river temperature of 79 0 F and D.O. concentration of 6.5 mg/l, the loss of dissolved oxygen in the Indian Point Unit

1. 1 & 2 system would be 0.17 mg/l. This loss of oxygen would decrease the river D.O. at Indian Point by about 0.02 mg/l. If the Hudson River concentration is less than 6.5 mg/l, the loss in the system will be less than 0.17 mg/l and decrease of the river D.O. would be lower than 0.02 mg/l. Such an effect of the plant on D.O. is practically undetectable, using accepted proce-dures for D.O. measurements in flowing streams and can be neglected.

Besides the loss of D.O. in the plant water cool-ing system, the heat rejected to the river can affect the river concentrations cf D.O. The analysis presented in QLM report entitled "Effect of Indian Point Cooling Water Discharge on Hudson River Temperature Distribution, January 1968" indicate that the river D.O. concentration for the heated condition can be expected to be approxi-mateiy 0.3 mg/l lower than that for the unheated condi-tion.

More detailed discussion of the dissolved oxygen effects of plant operation are included in testimony on this subject presented by Dr. Lawler to the ASLB on January 11, 1972, (Tr. 4428-4430). 222

HUDSON RIVER DISSOLVED OXYGEN CONCENTRATIONS OBSERVED BY QUIRK, LAWLER AND MATUSKY ENGINEERS A) OBSERVATIONS AT LOVETT DURING AUGUST AND SEPTEMBER 1969 INTERVAL OF DISSOLVED NUMBER PERCENT OF OXYGEN OF TOTAL Ambient Temperature CONCENTRATION OBSERVAT IONS OBSERVATIONS range: 77.5°F-68.3°F mq/i  % 4.0 0 0 4.0-5.0 0 0 Observed maximum 9.1 mg/i 5.0-6.0 11 25.50 Observed minimum 5-1 mg/l 6.0-7.0 20 46.50 7.0 12 28.00 TOTAL 43 100.00 B) OBSERVATIONS AT LOVETT DURING AUGUST THROUGH SEPTEMBER 1970 INTERVAL OF DISSOLVED NUMBER PERCENT OF OXYGEN OF TOTAL Ambient Temperature CONCENTRATION OBSERVATIONS OBSERVATIONS range: 79.0°F-71.0°F mg/l 4.0 3 3.65 4.0-5.0 10 12.15 Observed maximum 7.7 mg/l 5.0-6.0 39 47.5.5 Observed minimum 3.3 mg/l 6.0-7.0 19 23.20 7.0 11 13.45 TOTAL 82 100.00 C) OBSERVATIONS AT BOWLINE DURING JULY THROUGH SEPTEMBER 1970 INTERVAL OF DISSOLVED NUMBER PERCENT OF OXYGEN OF TOTAL Ambient Temperature CONCENTRATION OBSERVATIONS OBSERVATIONS range: 80.0OF-69.5OF mg/l 4.0 0 0 4.0-5.0 18 17.50 Observed maximum 6.6 mg/l 5.0-6.0 71 68.90 Observed minimum 4.3 mg/l 6.0-7.0 14 13.60 7.0 0 0 TOTAL 103 1i00.00 r2 2-3

Consolidated Edison Company of New York, Inc. EFFECT OF INDIAN POINT PLANT ON HUDSON RIVER DISSOLVED OXYGEN QL&M Job No. 115-19 February 1972 (Report Submitted to the ASL Board for the Licensing Hearing) 224

Appendix D CHLORINATION AT INDIAN POINT A sodium hypochlorite system is provided at Indian Point Units 1 and 2 for the specific purpose of preventing the growth of fouling slimes on the inner surfaces of the condenser cooling water system. When sodium hypochlorite is dissolved in water, it dissociates to form sodium ions and hypochlorite ions. The hypochlorite ions then react to form hypochlorous acid. The ratio of hypochlorous acid to hypochlorite ion depends upon the pH of the solution. Since it is hypochlorous acid that is the principal disinfectant in chlorine solutions, the efficiency of disinfection will be substantially greater at low pH values where the hypochlorous acid content is greater. If ammonia is present, chloramines will be formed upon the addi-tion of sodium hypochlorite to the water. The disinfecting properties of chloramines are only a few percent of that of hypochlorous acid. Increasing the amount of ammonia decreases the acid concentration, increases the pH and thus decreases the rate of kill. Chloramines are more persistent in the natural environment than hypochlorous acid but are not necessarily more toxic. Chlorine is dissipated in water by reacting with reducing agents as well as with organic substances and organisms. This loss represents the "chlorine demand" of the water. Hypochlorous acid is also decomposed to exposure to daylight (ultra violet rays from the sun). 225

The Unit No. 1 condenser at Indian Point has four condenser sections. Chlorine , as sodium hypochlorite, is introduced by manually starting a pump injecting a sodium hypochlorite solution into the cooling water at a point between the travelling screens and the circulating pumps. It is first introduced into two sections of the condenser for one-half hour during the daylight hours. The chlorine is then similarly introduced into the remaining two sections for one-half hour, so that only one-half of the cooling water is chorinated at a given time. Control of the amount of chlorine in-jected is achieved by adjustment of the hypochlorite pump stroke and observation of the tank level. The water fromthe chlorinated and un-chlorinated sections mix within seconds after3 leaving the condenser resulting in a 1i1 diiution. The chlorine residual dissipates quickly from exposure to daylight and the chlorine demand so that the discharge concentrations have usually been 0.1 ppm or less. This is based upon actual measurements taken during chlorinations since 1968. The overall time during which chlorine is added to the condenser is one hour. This procedure is repeated as required on alternate days for a maximum of 3 days each week. The Unit No. 2 condenser has six sections. The chlorination procedure will be similar to Unit No. 1. That is, one-half of the condenser (3 sections) will be chlorinated manually during the 226

                                   -  3 -

daylight hours for one-half hour, followed by chlorination of the other three sections for one-half hour. Since the procedures for chlorination on Unit No. 2 are similar to those used on Unit No. 1, the discharge concentrations during chlorination of Unit No. 2 should also be 0.1 ppm or less. Flow of sodium hypochlorite will be regulated by adjustment of flow control valves and observation of tank level. Chemical tests are performed on the condenser outlet as a basis of cbntrdlingchlorination levels in the condenser sections. Tests are also performed on the discharge canal to insure that compliance with the concentration limit of 0.5 ppm is maintained. Present plans call for chlorination of Unit No. 1 and Unit No. 2 condensers on alternate days so that chlorine would be introduced into the cooling waters of either Units No. 1 or No. 2 for a maximum of six days of the week for one hour each day. During full capacity operation the volumes of water treated with chlorine at a given time would be 140,000 GPM from Unit No. 1 and 420,000 GPM from Unit No. 2. The targets of the chlorine are the fouling organisms growing on the inner surfaces of the condenser cooling system. An exposure time of one-half hour, three days per week has effectively controlled such growths at Indian Point Unit No. 1. In comparison with the target fouling organisms, the organisms passing through the condensers in the cooling water at the time of 227

chlorination are exposed to full application concentration in the condensers for less than 15 seconds, and exposure to the decreasing concentrations in the cooling water discharge for an additional few minutes, the exact concentration and time depending upon the effective dilution and dissipation rates. While it is expected that some of these non-target organisms in the cooling water are killed during the chlorination period, studies of the phytoplankton and zooplankton populations have -no indicat~d that chlorination had m discernible effect on these populations in the river. Of the data in McKee and Wolf (1) on toxicity of free chlorine residual compiled from many sources, 13 of 18 concentrations reported to be harmful exceeded 0.2 ppm. The five reports of concentrations less than 0.2 ppm that were harmful involved exposure times of 7 to 23 days. Three of those reports involved trout and salmon. McKee and Wolf report on thirteen additional observations where concentrations from 0.1 to 5.0 ppm caused no fish mortality. The reported exposure times for these observations ranged from 2 to 100 hours. Laboratory bioassay tests on fish found in the Hudson River near Indian Point by New York University resulted in 100% survival of small white perch and striped bass for three hours when exposed to 0.75 ppm and 0.60 ppm initial chlorine residuals that dissipated to undetectable 228 limits within one and one-half hours.

                              -  5 -

Although other references quoted in the USAEC Detailed Statement, dated April 13, 1972 '(Merkens (2)., Zillich (3), Basch (4), Arthur and Eaton (5) ) indicated toxic effects at concentrations below 0.1 ppm, the exposure times encountered were in the order of 96 hours to 15 weeks. Times of exposure in the Hudson River at Indian Point will be much lower.- In addition the species quoted by the AEC are not found in the Hudson River near Indian Point and moreover bioassay tests of the species at Indian Point resulted in no mortality. Since chlorination practices have not and are not expected to cause any measureable damage to the environment, other programs for maintaining condenser cleanliness have not been investigated in detail. Mechanical and thermal cleaning systems have been used at some locations but only with limited success. In addition, the alternate systems will not prevent growth on the cooling water pipes and on the walls of the condenser water boxes. At the present time however, a program is underway to reduce further the frequency and duration of chlorination. The Indian Point Unit No. 1 condensers have not been chlorinated since January 11, 1972. Inspection of the condensers have been performed regularly to determine the effect of the reduction in chlorination frequencies. Preliminary results show no appreciable growth of fouling slimes during this winter period. Indications are, therefore, that chlorina-tion frequencies can be reduced during the winter months. 229

This program will continue throughout 1972. After completion of this program, the minimum effective amount of hypochlorite per dose will be determined and new operating instructions will be issued for both Indian Point 1 and 2. 2n,?

References:

(1) Water Quality Criteria. J.E. McKee and H.W. Wolf, Editors. The Resources Agency of California State Water Quality Control Board Publ. No. 3-A (2) Merkens, J. C., "Studies on the Toxicity of Chlorine and Chloramines to the Rainbow Trout, " J. Water Waste Treat. 7, 150-151 (1958) (3) Zillich, J. A., "A Discussion of the Toxicity of Combined Chlorine to Lotic Fish Populations, "Michigan Water Resorces Commission Report, l3pp. (unpublished), 1970. (4) Basch, R. E., "In-situ Investigations of Toxicity of Chlorinated Municipal Waste Water Treatment Plant Effluents to Rainbow Trout (Salmo gairdneri) and Fathead Minnows (Pimephales promelas), "Completed report Grant 38050G22 Environmental Protection Agency, National Water Quality Office, 50pp. (1971). (5) Arthur, J. W., and Eaton, J. G., "Chloramine Toxicity to the Amphipod. Gammarus pseudolimneaus, and the Fathead Minnow, Pimephales promelas," Environmental Protection Agency, National Water Quality Laboratory, Duluth, Minn. (1971). 231

COMMlENTS ON STATE11ENTS ON ENTRAINMENT AS PRESENTED BY THE AEC STAFF IN DRAFT DETAILED STATEMENT ON THE ENVIRON1ENITAL CONSIDERATIONS RELATED TO THE PROPOSED ISSUANCE OF AN OPERATING LICENSE TO THE CONSOLIDATED EDISON COMPANY OF NEW YORK FOR THE INDIAN POINT UNIT NO. 2 NUCLEAR GENERATING PLANT DOCKET NO. 50-247 MAY 14, 1972 QUIRK, LAWLER & MATUSKY ENGINEERS ENVIRONMENTAL SCIENCE & ENGINEERING CONSULTANTS 415 ROUTE 303, TAPPAN, NEW YORK 10983 232

The AEC Staff, in the Draft Detailed Statement of April 13, 1972, has addressed itself to the question of entrain-ment of fish eggs and larvae at Indian Point. Detailed analysis of the possible effects of such entrainment have been presented. Conclusions to these analyses appear in a number of locations. Pertinent quotations are as follows:

1. In Summary and Conclusions, page ii In Unit No. 2, aquatic biota impinged on the intake structure or entrained in the cooling water will be exposed to severe mechanical, chemical (chlorine), and thermal conditions; as a consequence, up to 25% of the average number of eggs and larvae of certain species of fish that annually pass by the Plant may be killed; under the most adverse conditions, up to 100% of some of the entrained planktonic species may be killed; and fish kills of a magnitude two or Chree times greater than those caused by Unit No. 1 may occur.

2. In the Summary of Conclusions, page iv From review and evaluation of the applicant's Environmental Report and Supplements thereto, and from independent observa-tions and analyses discussed in this Statement, the regulatory staff has reached the following conclusions concerning the environmental impact of the Plant's operation:

a. The operations of Units Nos. I and 2 with the present once-through cooling system has the potential for long-term environmental impact on the aquatic biota inhabiting the Hudson River which could result in permanent damage to the fish population in the Hudson River, Long Island Sound, the adjacent New Jersey coast, and the New York Bight The potential impact is due to possible damage to aquatic biota (including fish eggs, larvae, and plankton) from entrainment in the cooling water system resulting in exposure of the biota to severe mechanical, chemical (chlorine) and thermal conditions and impingement on the intake structure.

b. The estimate of potential environmental impact identified above and discussed in this Statement is based on inconclusive and incomplete data from the applicant. Existing information is insufficient to accurately predict the degree to which the potential damage will eventually take place during operation.

233

3. In Chaoter V, "Environmental Imracts of Indian Point Unit No. 2 with Unit No. 1 Operation", Section D-2-e, "Bioloaical imoact of Station Operation of Unit Nos.

1 and 2, Sources of Potential Biological Damage, - Entrainment.", page V-42 Large numbers of planktonic organisms will pass through the condensers during Plant operation, and, more importantly, a considerably large proportion of the biota will be withdrawn with the addition of Unit No. 2 (Fig. V-5). These organisms will include bacteria, planktonic algae, many invertebrate species, fish eggs and larvae. Table V-6 lists the fish species in the area whose eggs and larvae are known to be vulnerable to entrainment. During their passage through the Plant, these organisms will be exposed to mechanical, thermal and chemical damage. High mortality may result, especially for fragile species or during periods of chlorination. The methods used to determine the fraction of organisms entrained are presented in Appendix V-l. The monthly average probability of randomly distributed plankton moving downstream to be withdrawn varies from a low of about 6% in April to a high of 31% in August, although during drought conditions withdrawal may exceed 45%. Plankton that migrate via density flows to maintain their position in the river will be the most susceptible to entrain-ment, since they may remain in the area for several weeks.

4. In Chapter V, "Environmental Imoact of Indian Point Unit No. 2 with Unit No. 1 Ooeration," Section D-3-a, "Biological Impact of Station Operation of Units No. 1 and 2, - Probable Bioloqical Effects, - Direct Effects of Plant and-Station Operation on Biota." page V-52 The striped bass is the best-studied species in the area that appears to be vulnerable to population changes and will be used to illustrate possible Station impact. Adult striped bass migrate upstream in the spring and spawn upstream from Indian Point. The eggs and larvae drift with the currents in a net downstream direction; large numbers pass the Plant. Several studies have indicated that the principal nursery area for the species is below Indian Point in Haverstraw Bay but that there are some less extensive nursery areas upstream. High entrainment mortality of larvae and eggs as they drift past Indian Point.

Units Nos. 1 and 2 could result in a loss of 25% or more of the larvae and eggs that pass the Plant en route to their nursery area (see Appendix V-II). Based on the sizes and numbers of the young of the year in the estuary in late July and August, it appears that 75% to 90% of the surviving portion of the total yearly reproduction is below Indian Point. If we assume: (1) that all those fish migrated past the Plant during a life stage which was susceptible to entrainment; (2) that density-independent 234

factors are responsible for mortality in the populations; and (3) that entrairzment mortality is 100%, then the operation of Indian Point Units 1,os. 1 and 2 will effectively reduce recruit-ment resulting from reproduction by about 19% to 22%. This is a maximum estimated loss of recruitment which would result from entrainment of 25% of the striped bass eggs and larvae that pass the Plant and would not likely be reached. However, losses of the young of the year and 1-year age classes from impingement on the intake screens will add to the actual entrainment mortality and could offset the increases in survival during entrainment, so that the total yearly recruitment loss for each subsequent year class in the population may be as high as 15% to 20% from direct effects of Plant operation. Sustained reproductive losses of this magnitude over a long period of time would result in substantial reductions of the striped bass populations that spawn in the Hudson, including those of both the Hudson itself and the area from the south New Jersey coast to Long Island Sound. This statement is followed by a discussion of numerous factors that may partially offset the estimates given above. The section is then concluded: These same arguments apply to other species that spawn in the area and may cause important losses of recruitment to local populations of the alewife, blueback herring, bay anchovy, tomcod, smelt, and Atlantic silversides, as well as striped bass.

5. Chapter VII, "Adverse Environmental Effects which cannot be Avoided," Section A, "Factors Responsible for Adverse Effects, page VII-I.

Several factors associated with the operation of Indian Point Units Nos. 1 and 2 are capable of producing adverse effects. The more important of these factors in the order of their importance include:

1. Entrainment of large numbers of planktonic organism in the once-through system .....

235

6. Chapter VII, "Adverse Environmental Effects which cannot be Avoided,"Section B-4, "Probable Adverse Effects -

Biological Impact," page VII-6. The entrainment of planktonic organisms appear to be the most serious threat to the aquatic community. Entrained organisms will be exposed to mechanical, thermal, and chemical damage. Most species of the aquatic organisms in the area will be subject to entrainment at some life stage. These include phytoplankton, planktonic crustaceans, and larval stages of benthic invertegrates and of many of the estuarine fishes which use the area for spawning. The species of fish which appear most likely to be affected include the striped bass, alewife, blueback herring, tomcod, smelt and white perch.

7. Chapter VIII, "The Relationship Between Local Short Term Usage on Man's Environment and Naintenance and Enhancement of Lonq Term Productivity," Section B-2, "Uses of Adverse to Productivity - Water Uses," Page VIII-4.

In consideration of the impacts and alternatives discussed in detail in Chapters IV, V, VI, VII, X and XI, the staff has concluded that the only effect of the operation possibly inimical to the objectives of NEPA with respect to productivity is the potential for further degradation of the Hudson River estuary, which is Used as the spawning and nursery area in the life cycle of many marine aquatic organisms that spend much of their adult life in the coastal areas of northern New Jersey, New York and Long Island. Such degradation would, indeed, over the long-term diminish the productivity of the area to an extent that can-not be stated in precise terms at present. Only the yearly cost of replacing the estimated number of fish that might be killed has been calculated (see Chapter XI). The ultimate impact on commercial and sport fishing has not been estimated, since the decline of the Hudson River fishery is problematical at this time.

8. Chapter IX, "Irreversible and Irretrievable Commitments of Resources," Section B, "Water and Air Resources,"

page IX-4 The proposed action when taken has a potential of affecting the aquatic organisms essential to maintaining a fish population of the Hudson River as well as that along the Long Island Sound, 236

New Jersey coast and the New York Bight so that the population could deteriorate beyond the point of rehabilitation. In this event, operation of the Plant could entail an irreversible commitment of the river as a resource.

9. Chapter XI, "Alternatives to Prooosed Action and Cost Benefit Analysis of Environm-ental Effects," Section B,

     ,Summary      of Alternatives,"      page XI-12.

The important areas of disagreement between the applicant's analysis and that of the staff are the following: (2) Environmental effects from operation of the intake-discharge structure have a potential for long-term significant biological damage to aquatic bioto not only in the localized area in the vicinity of Indian Point Unit No. 2, but also in the Hudson River estuary, New Jersey coast and New York Bight. (see Chapter V.D. 3) There are other areas of difference which are relatively minor. The staff feels that there are insufficient data available to make a reasonably accurate estimate on long-term effects on biota. Of the major differences between the staff and the applicant in the analysis and evaluation of available information, the entrain-ment of nonscreenable fish eggs, larval, and fingerlings and the impingement of fish on the intake structure appear to be the major impacts on the aquatic ecosystem. Although the staff does not feel that the impacts can be quantified at this time, the staff does not agree with the small impact of about 2-3% damage to eggs larval made by the applicant. Details of the staff's disagreements are given in Chapters V.D., and Appendices II-1, V-2, and XI-l.

10. Appendix V-2, "Entrainment," page A-69 Thus, the probability that a larval striped bass migrating down-stream would be entrained is about 25%. Comparison of the freshwater inflows used in these calculations with inflows during the period from 1944 to 1964 indicates that these values were similar to the median conditions.

A discussion of various offsetting factors then follows: The Staff then concludes: Consequently, the Staff believes that the total average probability of withdrawal of larval striped bass migration downstream past the Station is approximated by the 25% figure, and that this fraction is the best estimate than can be made using available information. 237

In conclusion, based on these considerations, about 25% of the larval striped bass may be entrained as-they migrate downstream past the Indian Point site. The Staff supposition of damage to the Hudson River fishery and to the population in the offshore waters thus appears to be primarily based on its calculation that some 25% of the planktonic forms of many of the various fishes using the estuary will be entrained and presumably destroyed. Our approach in these comments is directed first at a critical evaluation of the procedures employed by the Staff to obtain the 25% factor, and then will address the numerous non-quanti-tative statements made by the Staff regarding possible offsetting mechanisms. The critique to follow will include the following items:

1. A demonstration that the Staff calculation of available dilution flow at Indian Point, as given by Equations 1 and 2 and Figure A-II-6, in Appendix II-1, entitled "Characteristics of Hudson River Circulation at Indian Point, in Relation to Dilution," employs an inaccurate and theoretically unsupportable methodology, and in the Hudson seriously underestimates available dilution flow at Indian Point.

2. Modification of the probability model given by Equations 1 through 12, Appendix V-2. This probability model was employed by the Staff to compute entrainment loss. The modification includes the quantification of the influence of vertical diurnal movement and estuary density flow on entrain-ment.

The Staff's calculation of a 25% entrainment loss is then revised, employing a theoretically and experimentally supportable means of estimating dilution flow in the Hudson River, and the modifications made on the probability model. 238

1. Criticism of Staff Calculations of Available Dilution Flow at Indian Point Pages A-4 through A-7 state clearly the Staff's belief that the flow available for dilution in an estuary is given by:

                                 .*QF T     1=S/S 0
                                                                * ..   (1) in   which:

QT = total dilution flow at point in the estuary QF = net freshwater discharge S = the section average salt concentration at a given point along the estuary's longitudinal axis So = the ocean salt concentration Equation (1) above is identical to Equation (2) (Page A-4), provided that the salinity of the freshwater is zero, and that volume is replaced by volume per unit time, or flow rate (Q). The assumption of zero salinity in the freshwater dis-charge is quite valid for the Hudson River. The staff replaces volume by flow in constructing Figure A-II-6. Freshwater flow and salinity data taken from the applicant's Environmental Report Supplement are then reproduced in Figure A-II-5. These data are then employed in conjunction with Staff Equation (2) to obtain the relationship between freshwater flow and dilution flow at Indian Point in Figure A-II-6. 239

Ile submit that this procedure is generally invalid in pre-dicting estuary dilution flows. We will show that this method of predicting estuary dilution flow defies analytical development, and has been discounted by most investigators shortly after its appearance in the literature in the early 1950s. The Staff's reference for their Equations (1) and (2) is a paper by Ketchum, entitled "Eutrophication of Estuaries", which appeared in 1969 in the proceedings of a symposium on eutrophication.1 Pertinent excerpts from this reference follow: I will mention a few of the essential characteristicsof estuarine circulation as they relate to the distribution of pollutants. I will not go into detail because this is covereý by Carpenter, Pritchard and Whaley in this volume (page 210). The estuary offers advantages not offered by the river in its ability to dilute and disperse added con-taminants. In the river itself, the volume of water available to dilute a pollutant is furnished simply by the river flow, which carries the contaminant downstream at a rate determined solely by the river flow and the geometry of the river bed. In the estuary, the circulation is more complex, although the net seaward flow is also determined by the rate of river flow. If no mixing were involved, this fresh river water would merely flow seaward as a layer on top of undiluted seawater. Mixing is involved, however, and salinity gradually increases down the estuary as river water mixes with more and more seawater. Seawater must flow into the estuary to provide the salt needed to balance the system. In a steady-state condition, the volume of seawater entering the estuary in a given unit of time equals the volume flowing out; there is no augmentation of the net seaward flow. The seawater thus entrained with the freshwater does, however, increase the diluting cavacit' of the mixed water that is escaping from the estuary. This effect can be evaluated by using the distribution of salt water and freshwater in the estuary. 1 Ketchum, B.H. 'Eutrophication of Estuaries". Eutrophication: Causes, Consequences, Correctives. National Academy of Sciences, Washington, 1969. p. 197 2,4

The amount of freshwater contained in any given sample of brackish water can be calculated from the salinity, since F =I - S a in which F is the fraction of freshwater in the sample, S is the salinity of the sample, and 0 is the salinity of the "source" seawater. If the averaae freshwater content of a complete cross section is known, the volume available for the dilution of the pollutant at that location can be approximated. To obtain the fraction of freshwater in a complete cross section of the estuary, it is necessary to integrate the values from top to bottom and from bank to bank. The volume available for the dilution of the vol-lutant in a aiven veriod is determined aDDroximately by dividing the rate of river flow by the fraction of fresh-water in the cross section.* If the section is 50 percent freshwater, two volumes must move seaward: to move one volume of river water seaward. Closer to the mouth of the estuary, where the amount of freshwater has been reduced to 10 percent, ten volumesý must move seaward to remove the river water. A more precise determination of the diluting volume reauires detailed knowledge of the cir-culation. But this simple calculation shows that the total volume available for dilution increases in the sea-ward direction. The underlined statements show clearly that Ketchum's estimate of dilution flow is given by Equation (1) above, or Equation (2) in Appendix A-2 of the AEC Draft Detailed Statement. Note that the last section of the excerpt suggests that Ketchum him-self could be viewing this calculation as merely an indication of a trend toward increased dilution as one moves seaward in an estuary, rather than a hard and fast quantitative estimate of dilution flow. This last statement is made recognizing that Ketchum introduced this method of computation of dilution flow in the early i950s.2 Note: Underlining added for purposes of this reviewer.

• This statement, combined with Ketchum's expression for the fraction of freshwater, is precisely equivalent to Equation (1) above.

2 Ketchum, B.H. "The Flushing of Tidal Estuaries". Sewaae and Industrial Wastes, Vol. 23, No. 2, February 1951. pp. 198-209 241

Before presenting various comments from the literature on this computation procedure for estimating dilution flow in an estuary, a few statements on the calculation are in order. The calculation of the fraction of freshwater flow at any point in the estuary, given by Ketchum's definition of "F", above, or by the denominator of Equation (1), above, is generally accepted as correct. This merely states that at any point in the estuary a certain percentage of the water there is of freshwater origin, and the remainder is of ocean origin. This split can be obtained by recognizing that the total volume is the sum of the volume of ocean water origin, containing salt of ocean concentration, and the volume of freshwater origin, containing no salt. The problem arises when one attempts to show that this percentage split can'be employed, along with the fresh-water flow, to calculate movement or dilution flow. Ketchum, for example, in the excerpt given above, simply states; The volume available for the dilution of the pollutant in a given period is determined approximately be dividing the rate of river flow by the fraction of freshwater in the cross section. After presentation of the literature comments on Ketchum's work, we shall show the problems which arise when one tries to demonstrate the validity of Ketchum's procedure analytically. 242

In 1953, Stommel, a coworker of Ketchum's at the Woods Hole Oceanographic Institute, presented a paper 3 in which his intent was to provide a method of estuary pollution analysis that would avoid the difficulties that had been observed in employing Ketchum's methods since its intro-duction in 1950. It should be noted at this point, that Ketchum's major contribution was not the computational procedure given above, but rather a-modification of the "Tidal Prism" concept, a procedure that had been employed to estimate dilution flow, but which was shown by Ketchum to overestimate that flow very grossly. Ketchum merely employed the computational procedure discussed above as a means of verifying his prediction., via the'modified tidal prism, of dilution flow. Stommel's introductory remarks are excerpted below: Papers recently published by Ketchum (1) and Arons and Stomel (2) have presumed to give a theoretical account of the distri-bution of freshwateŽ in an estuary. Pritchard (3), however, justly has pointed out that these treatments are at best appli-cable only to estuaries so intensely tidally mixed that they exhibit no vertical stratification. In such cases the salt is carried upstream against the main river flow by turbulence. Ketchum proposed a mixing process, which he called "exchange ratio", and was able to compute the salinity distribution in the Raritan. Using the published data (4) on the Severn estuary, the author and Harlow G. Farmer found that the method of the "exchange ratio" gave a grossly incorrect salinity distribution. Inasmuch as the Severn is unstratified, and appear to fit all the recuirements of Ketchum's analysis, it is quite clear that the method of the exchance ratio is not nearly so aeneral as was proposed. 3 Stommel, Henry. "Computation of Pollution in a Vertically Mixed Estuary". Contribution #640 from-the Woods Hole Oceanographic Institution. Sewaae and Industrial Wastes, Vol. 25, No. 9, September 1953. pp. 1065-1071. 243

Pritchard 4 ',5,6 has discussed, on a number of occasions, the various procedures employed by Ketchum. Reference 4 is a written discussion of a paper by Todd and Lau, in which Pritchard disagrees strongly with the manner in which these authors' propose that estuarine salinity pro-files be employed to estimate freshwater flow. The proposed method employs an approach similar to Ketchum's. Excerpts from this discussion follow: The estuary offers many interesting and important problems to the physical hydrographer, and it is encouraging to find that hydrologists are extending their work into this intermediate. zone between the river and the ocean. It is unfortunate, how-ever, that this paper by Todd and Lau exhibits a lack of under-standing of the mechanisms of circulation and mixing in a tidal estuary. To a casual reader the concepts presented by these authors are disarmingly clear and simple. Unfortunately, they have not used the basic hydrodynamic concept of continuity in its complete form which has led them to misinterpret the equations they develop, particularly their Equ. (1). The error results from the assumption that sea water on the one hand and freshwater on the other can be considered as the two species involved in the mixing processes'in an estuary, when in-fact, the two separate species which are involved are the salt and the water. The processes of turbulent diffusion, or 'mixing', can lead to a net upstream transport of salt without a net upstream trans-port of water.... 4 Pritchard, D.W. "Discussion of 'On Estimating Stream Flow into Tidal Estuaries," by David K. Todd and Leung-Ku Lau." which appears in Transactions, American Geophysical Union, Vol. 37, 1956, pp. 468-473. Pritchard's discussion appeared in Vol. 38, No. 4, August 1957. pp. 581-584. 5 Pritchard, D.W. "The Equation of Mass Continuity and Salt Continuity in Estuaries". Journal of Marine Research, Vol. 17, 1958. pp. 412-423 6 Pritchard, D.W.. "Estuarine Hydrography". Recent-Advances in Geophysics, Vol. 1, 1952. 244

                                                                                   .. The error results from an incomplete use of continuity concepts which presents a continuity argument for fresh water only. Actually there are two species to which the continuity concepts apply in the estuary: the water (actually mass) and the salt. Other investigators have made this same error. An apparent reasonable argument is frequently presented along lines something like      the following: A certain amount of fresh water flows into the estuary from the river. In order to-maintain continuity an equal amount of fresh water must be carried through each section, and since, as one proceeds down the estuary, the salt       content increases, it is evident (?) that only a portion of the volume can be fresh water, and so the seaward directed flow must increase in proportion to the decreasing fraction of fresh water. The correct application of continuity concepts recognizes that it is the mass of water on the one hand, and the salt    on the other that is conserved over one or more tidal    cycles, not the 'fresh water'....
    ... It mzight be appropriate to point out that Ketchumr (1950) made the same questionable assumption that Todd and Lau did when he defined a non-tidal drift    (TITD) as NTD = R/F x A.

Ketchum's arguments parallel the disarmingly simple but erroneous presentation given earlier in this critique. We interpret the authors (Todd and Lau) closure to Pritchard's discussion, as a circumlocution of Pritchard's arguments, rather than a direct statement of disagreement, suggesting their recognition of the accuracy of Pritchard's analysis. The following statement appears in a very extensive analysis 7 of the effect of pollution on the Thames Estuary. 7 "Effects of Polluting Discharges on the Thames Estuary". Department of Scientific and Industrial Research, Water Pollution Research. Technical Paper No. 11, Chapter 14, 'Tidal Mixing', under Section entitled" 'Theories of Estuarine Mixing', 1964. p. 392 245

KETCIIUM'S ThtEORY Ketchum'- divides an estuary into zcgrnents such that the length of each is equal to the average excursiol of a particle of watcr on the flood tide. The position of the landward boundary of the first segment is determincd by the river flow and the cross-sectional areas at high and low watcr. In one paper' he considers the mixing process may be represented by assuming that, during each tidal cycle, the water is conpletelV mixed within each segment at high water, and that there is an exchange of water between adjacent segments during the ebb-the amount of water removed from a segment being given by the ratio of the difference between the volumes ofthe segment at high and low water to the volume at high water. The final equations express the proportion of fresh 'Vater in each segment solely in terms of the river flow and the volumes of the segments at high and low water. However, these eouations do not follow riizdlv from thc- theoretical model and, althotwh the methýod has Zl'erv co'7.derable meret o1 s~ "-t*, t us e~c,. cc:*t (, t:-'C~mixim% i<- undouncdlv over-simn-iiicd, and it is; evident inrv I:.,i Iton I'L' I" ,pr. *j., lo ad e' tuariCs even tmlou2II it hias been used successIuhiv in parit.Ular cs, It is sonicni.t nll.ci to inuicaic tuit it cannot be used in the case ul the I h1allmCS si'a-v:'}tlcnon tfound that his method (lid not at*lv to the I)elaware Estuary, and he was not suryrised to h'arn that it 6!d td-6;i-ii.v ' . -- in i"~ig.J22 the continuous. curve sows the approximate observed equilibrium distribution of salinity for a flowv at Tcddington of 1-500 mn.g.d. (derived from several \years' records of the London Count\, Council), and the broken curve is the distribution calculated (for average tidal,conditions) by means of Ketchum's theory. There ii; a similar disparity between the observed and calculated distributions for flows of 500 and 3000 m.g.d.

                               ,30                                                    -

0 0 0' ZA . Ll 1 010Ab'v.z0 *'Clo., 10 20 30 40 MILES FROM LONDON BRIDGE AT HALF- TIDE Fic. 220. Equilibrium distribution of salinity in Thames Estuary when flow at Tcddington is 1500 m.g.d. (A) Observed (B) Calculatedusing Ketchiin's representationof mixing Ketchum references taken from Reference 7

4. Khn'cium, B. H. J. mar. Res., 1951, 10, 18.

5. KrTrcjiu.i, B. H. The Exchanges of Fresh and Salt WVaters in Tidal Estuaries. Woods Hole Oceanographic Institution, Colloquium on Flushing of Estuaries, 1950, p. 1.

6. Krnrcit'i, 13.II. Sev'ae,indusir. lIfastes, 1951, 23, 198. 246

         '7. K'rciu.o, 13. H1. Personal communication, 1957.

Thus, it is clear that the methodology employed by the Staff to estimate estuary dilution flow has not met with general acceptance by the field, and, in general, has been discarded in favor of models which recognize more details of observed physical behavior in estuaries, particularly that of salinity-induced circulation. Before going on to a theoretical presentation as to why the Staff method is unacceptable, and while on this topic of behavior in the Thames River, it should be noted that several investigators including Bowden 8 , Preddy & Webber9 and Inglis & Allenl 0 have concluded that the Thames River, like the Hudson, falls into the class of partially stratified estuaries. Similarity between the Thames and Hudson 'River circulation patterns and mixing characteristics is supported by field obser-vations which established existence of density induced circula-10 1 tion in the Thames and the HudsonI, relatively high dispersion coefficients (33.8 x 105 cm2 /sec or about 10 square miles per day in the salt intruded reaches of both estuaries) and comparable circulation and mixing classification criteria, such as the ratio of tidal amplitude to freshwater used by 8 Bowden , the ratio of the flood tide to freshwater volumes used by Pritchard, or the vertical stratification factor (VSF) employed by QL&MII. 8 Bowden, K.F. "Circulation and Diffusion." Estuaries, Publication #83, American Assoc. for the Advancement of Science, Wash., D.C. 1967. p. 20 9 Preddy, W.S. and B. Weber. "The calculation of Pollution of the Thames Estuary by a Theory of Quantized Mixing," International Conference on Water Pollution, Paper No. 42, September 1962. 10 Inglis, Sir Claude and F.H. Allen. "The Regimen of the Thames Estuary." Porc. Inst. Civil Engineers (London), 7:827-868. 1957 It Quirk, Lawler & Matusky Engineers. "Environmental Effects of Bowline Generating Station on the Hudson River" ,V l. 1-4, QL&M Project No. 169-1, March 1971.

Rejection of the Staff's methodology via theoretical reasoning follows. Transport phenomenon such as the volume rate of flow available for dilution in an estuary, should always be derivable by application of one or more of the equations of mass) momentum and energy to the system in question. When the system is viewed macroscopically, a conventional means of applying these basic and quantitative laws of physics is control volume analysis. In this method, a finite and typical volume segment of the system is drawn, and rates at which mass momentum or energy flow through, and are produced and or consumed within the segmentý, are written down. Each entry is then assigned its proper position in an inventory or "balance" equation and a result obtained. This procedure is applied below to illustrate the development of the two layer estuary model, and then employed to demon-strate the difficulty in deriving the intuitive formulation of estuary dilution flow employed by the Staff. Consider the typical estuary segment shown below. Freshwater flows into the segment at a rate QF" In an attempt to F recognize its dilution by salt water, as evidenced by a continually increasing salinity concentration as one moves seaward in the estuary, ocean water is assumed to flow into the estuary, predominantly along the bottom half of the estuary, due to its greater density. 248

I I II UPPER LAYER ..4--F I -I FROM THE SISUX UPLANDS i *VERTICAL I _HANG I*EXCHANGE E I I I I LOWER LAYER I FROM OC E/ THE QLX 8-I- I X + AX FIGUREAl - Two Layer Exchange of Water in an Estuary A steady-state condition is assigned, so that there can be no net transport of salt either into or out of the estuary. in the real world, tidal average behavior approaches this steady condition when external factors controlling movement in the estuary, such as ocean tide, winds, etc., and in particular, river freshwater discharge, remain constant, or nearly so, for extended periods. ' 249

Note that the long term condition is a quasi-steady condition. Freshwater discharge undergoes a yearly cycle of high and low water flows, preventing any long term net landward flux of salt. The estuaries salt profile oscillates about some mean position, just as a freshwater discharge oscillates throughout the year about a yearly average runoff value. Since there is no net flux of salt, a mechanism must be provided for returning the salt introduced to the estuary in the landward directed underflow, shown by QL in Figure 1. To provide such a return mechanism, water is assumed to be mixed vertically by some means and then returned to the ocean by a seaward movement which takes place predominantly i' the upper layer. Note that a physical rationale is available to explain the postulated movement. This rationale includes the notion of density current development occuring in a system in which waters of different density are brought in contact with each other, and the notion of vertical mixing via tide-induced turbulence. The notion of vertical mixing is necessary to permit continuous transfer of the heavier seawater up into the layer in which the lighter freshwater is presumed to be moving. Without this, only shear at the salt water-freshwater interface would be available to affect the transfer. This would result in only a fraction of the transfer which can be expected in the presence of tidal turbulence, and in fact describes the stratified, or "salt wedge" type of estuary. 250

At this point, we have succeeded in developing a conceptual model of estuary water movement. Note that since a macroscopic view is the objective, details of the mixing and transfer process are not required at this point. We are simply attempting to structure an overall view of the estuary, with the objective of writing a statement to describe in a quanti-tative fashion, the observation that freshwater discharge is diluted by ocean water as it moves down the estuary. The Law of Conservation of Mass is applied to both the water and the salt in the estuary. This is done by writing a material balance over the volume segments shown in Figure 1. Since there is no loss or gain of either salt or water within the segment, due to generation or decay processes, and since we are dealing with a steady condition, so that no accumulation of either material can occur over time within the segment, the required balance can be struck across any cross-section of the segment to describe the behavior at that section. This is done first, before striking a balance over the whole volume segment. Consider Section X in Figure 1. Since there is no net flux of salt, the salt moving into the estuary across the lower portion of the section must balance that moving out of the estuary across the upper half. This is written: 251

U ' .§UI x = QLL SLIx

                                                                 ...    (2) in which:

QU' QL = the total upper and lower layer flows, respectively Sup = the average upper and lower layer salt concentrations, respectively Since the net overall movement is out of the estuary (seaward), and is given simply by QF' the freshwater flow, the upper layer flow, Qu, must exceed the kower layer flow, QL, by this amount. This is written: Qu - QL = 0F

                                                                  ...    (3)

Substitution of Equation 13) into Equation (2) yields: QU - F S -S L U

                                                                   ...   (4)

Subscript "X" has been dropped since the section location was arbitrary and Equation(4) is the so-called "salt budget" equation and is described by a number of authors. (see, for example,Reference 8.) 252

A material balance may now be struck over the whole volume segment. Upper and lower layer flows are entering and leaving the segment at sections X and X + AX. The general inventory equation for mass is written: Rate of Mass - Rate of Mass + Rate of Production - Rate of Loss Input Output of Mass of Mass Rate of Accumulation of Mass

                                                                       ...     (5)

In applying Equation (5) to the system in Figure 1, the last three terms are all zero, for both water and salt. There is no produiction or loss of either water or salt within the segment, and, since the system is at steady-state, no accumulation of either material occurs. Application of Equation (5) to salt movement through the segment AX yields: Input - Output =0

                                                                    =      0 OQU)UIX+Ax +        L L-g  x          U .Sul        j Lf ) k*AX
                                                                           ...   (6)

Rearrangement and division by AX yields: [Qu.0 ux+Ax - [fXI X- QL§L} [rA L

                                                                    =0 L        AX           x~                  XAxx 253

The limit of this Equation as AX 4 0 yields: d(Qu-Su - QL SL)

                           =    0 dX
                                                            ...    (7)

Integration yields: QU- iTU - Cý: ýýL = Constant Consideration of the no net salt flux condition requires that the integration constant be zero. The result is identical to Equation 12). Application of Equation (5) to water movement through the segment AX yields: Input - Output - 0 QUIx+Ax+ QL}X - Qu - QL}x+Ax - 0 Rearrangement, division by AX and taking the limit as AX 0 yields: d [Q-QL] dX 0 254 S... (8)

Integration yields: QU - QL = Constant Consideration of the fact that the net overall movement across any section in the segment is given by QF' the freshwater flow requires that this integration constant be given by QF" The result is identical to Equation 3. Thus, by use of material balances with salt and water across either an arbitrary cross-section or volume segment of the estuary, we have succeeded in. establishing an overall quantitative relation between freshwater flow, estuary dilution flow and observed salt concentration. This relationship is given by Equation (4), iii which QU' the upper layer flow, is the estuary dilution flow. Equation (4) suggests that the estuary dilution flow can be c&lculated, provided one knows the location of the interface between the upper and lower layer and has accurate vertical salt profiles. QL&M has shown that, for for the Hudson, vertical salt profiles tend to follow an "S" shaped distribution with the inflection point near the 11 half depth. This inflection point can be used to estimate the location of the upper-layer - lower layer interface as follows. The equation of continuity in two dimensions is written: 255

Du av

                   --    +    Y
                              --          0
                                                                ...  (9) in which:

U = horizontal water velocity at the point X,Y" V = vertical water velocity at the point X,Y In the two layer system, the vertical distribution of horizontal velocity moves through zero at the upper layer-lower layer interface. Thus, since the interface is roughly horizontal, at the interface , aU/aX = 0. From Equation 9 the vertical velocity is seen to be a maximum at the interface. The rate of vertical salt transport by vertical turbulence is proportional to the vertical velocity, and should be a maximum at the interface. This vertical salt flux can alsd be shown to be essentially proportional to the vertical salinity gradient, so that the point at which this gradient is a maximum can be used to estimate the location in the interface. In an "S"-shaped vertical salt profile, such as those observed on the Hudson, the Vertical salinity gradient is a maximum at the inflection point. This is just one means of estimating the location of the interface in using Equation (4) to estimate estuary dilution flow. Knowledge of the velocity distribution is another. In any event, the whole thrust of the work referred to in Reference 11, is directed at a valid estimate of the dilution flow, in which the role vertical salinity gradients play in this estimating process is discussed in detail. It should 256

be noted that this reference is Reference 4, page 111-61, to Chapter III in the AEC Draft Detailed Statement. The use of Equation 4 and vertical salinity profiles to estimat density flow is recognized by the Staff in Chapter III, pages 111-22 to 111-27. In this regard, the Staff concludes on 111-27: The presence of a net nontidal seaward flow in the salt-intrusion zone of the Hudson is clearly established by means of (1). observed vertical salinity gradients, (2) direct velocity measurements, (3) high computed values for the longitudinal dispersion coefficient. Of these three means of detection, it is thought that only method I may be reliably used to obtain a reasonably accurate direct deter-mination. The foregoing shows clearly that a model of estuary dilution flow can be developed by application of the Equation of Continuity (Law of Conservation of Mass) to the estuary. To do this, recognition is given to the fact that a Vertical density difference exists in any section in the estuary. No sudh similar analysis appears to exist which will generate the formulation used by the Staff to estimate estuary dilution flow (Equation (1) above, or Equation (2), page A-4 in the Draft Detailed Statement). To show this, refer to Figure 1. Since the ultimate f6htulation (Equation (1)) contains only *, the area- &veraged salt concentration and S,# the ocean salt concentra-tion, we presume that mixing across the Section is assumed 257

for whatever derivation technique one can conceive of. Actually, no such assumption has to be made; the major point is that since the final expression contains only S to represent section salinity behavior, the deriver must use this, and only this value in developing his model. Due to the observed dilution of QF, a seaward flow is assumed to exist and to be larger than QF" Use the notation Qu to define the total seaward flow. Define a landward flow QL- QL is the makeup flow necessary to permit the existence of Qu and still maintain a net water flux of QF. Application of a material balance on water across the section X shows that Equation (3) still holds; i.e., that: Qu = QL + QF Write a salt balance across section X. Since no attempt. is made to define vertical variation of salinity and the investigator is apparently working only with S the area-averaged salt concentration, this balance yields: Ou* - QLS = net section salt flux The net section salt flux must be zero at steady-state. However, substitution of the preceeding equation for Qu yields: o F S= = net section salt flux

                                       -258

This is clearly a contradiction and arises because the investi-gator has not distinguished between the concentrations of salt being carried landward by QL and seaward by Qu. The presumption of landward and seaward flows is clearly necessary if one is to explain dilution of QL. This fact is acknowledged by many investigators. Care must be taken, however, to recognize that the actual points within the estuary section at which such flows are crossing, must see flow going in one direction or the other. No one point can see two way flow at the same time. Since this must be the case, one must also realize that the concentrations of salt seen by each flow may (and in fact, must) be different. Therefore, application of Svto all flows is incorrect. Proliferation of this error over the years seems to be asso-ciated with the assumption of the sectionally homogemeous estuary. Ketchum, for example, ignored vertical variation, assuming complete and immediate mixing with each of his segments. In using salinity, therefore, to "verify" his model, only section average salinities were used. In discussing Todd and Lau's paper, Pritchard 4 states: The authors have stated certain limitations on their development. A fundemental requirement is that the estuary be sectionally homogeneous, that is, it shall have no vertical or lateral salinity gradients. This is an unfortunate restriction to place on estuarine studies, since the ra-oritu of estuaries do exhibit scre dearee of vertical or lateral stratification, wiith accom-anuing circulation patterns related to the mass distribution. 259

The characteristiccirculation patterns in the various types of coastal plain estuaries have been discussed by Stommel (1953) and by Pritchard (1952, 1955). However, an adeauate study of even this most simple of estuarine types would be welcome so that one should'not be unduly critical of this aspect. Pritchard's point in the discussion, as described previously, is that if the assumption of vertical homogeneity is going to be made, presumably for the purposes of simplifying a complex system, then it should be done with great care, recognizing that the existence of vertical salinity variation is part and parcel of what makes the estuary "go". Witness, for example, his comment in Reference 5, as he introduces the one-dimensional analysis of an estuary: The Case of One Spatial Dimension. Because of the complexity of the general three-dimensional equations, and even of the more restricted two-dimensional equations given above, many investigators have attempted to reduce kinematic and dynamic problems in estuaries to a single spatial dimension. It is in these treatments that the most frecuent misuse of continuity concepts has occurred. That the assumption of vertical homogeneity is an idealization is again suggested by Pritchard 1 2 in a discussion of estuary classification: It is, in fact, quite possible that the verticallu homoaeneous estuary does not exist. Our observational methods may not be sufficiently sophisticated to show the slight degree of vertical stratification which might, on the average, exist in such systems. Only a small vertical stratification would be reauired to remove some of the a7c2:alous fac:ors mentioned above which are associated with this class of estuaru. 12 Contribution No. 64 of Chesapeake Bay Institute and the Department of Oceanography, The John Hopkins University, Reproduced by permission from The Sea, vol. 2, Interscience Publishers, 1963. 10

Bowden suggests that density-induced circulation must exist, even in cases where vertical mixing is intense and the tendency 13 A pertinent would be simply to assume vertical homogeneity. except from this reference follows: Where the tidal currents are most effective, there is an increase in the intensity of vertical turbulent mixing, which is an exchange process, mixing the fresher water downwards as well as the salter water upwards. In this type of estuary, with moderate mixing, a state of dynamic equilibrium is set up, with a two-layer flow and the salinity along a given vertical increasing with depth. The volume of water involved in the density current flow may be many times the river discharge, e.g., the seaward flow in the upper layer may be 40 times the river flow while the upstream flow below it is 39 times the river flow. With very strong tidal currents, the vertical mixing predominates and a third type of estuary has been described, which is so intensely mixed that there is no vc..tical variation in salinity and the density current flow is no longer present. It would seem, however, that a tendencu to differential flow must persist,'even under these extreme ccnditicns, since the primary driving force, the longitudinal density gradient, is still present. Comparison of Equations (1) and (4) show that estuary dilution flow calculated by each, will be the same when: S0 SL T-ese ratios will approach each other close to the true mouth of the estuary, as all values approach the ocean salt concentration. However, the validity of either equation is questionable at this point. Ketchum recognizes this in 261 13 Bowden, Y F. "The Mixing Process in a Tidal Estuary." presented at the International Conference on Water Pollution Research, Paper No. 33, of Section 3. September 3-7, 1962. Pergamon Press.

Reference 2 above, and the two-layer model presented previously is an idealization of actual estuary circulation. The simple idealization given tends to be inaccurate as one approaches the estuary mouth. The foregoing literature review and analysis demonstrate clearly that the staff method of estimating estuary dilution flow, for use in its evaluation of entrainment, is highly questionable, if not categorically in error. We submit that a far more accurate estimate of estuary dilution flow in the Hudson River is that given in Reference 11 (Reference 4, Chapter III, draft detailed Statement. As noted previously, the staff does recognize the existence of density flow in the Hudson in its Chapter III, Section E-ld entitled "The Hudson River Estuary and its Cooling Capacity." The salt budget equation, identical to Equation 4 above, is presented (Equation 1, page 111-22) and the Staff goes on to state: The mixing flow calculated in Equation (1) is the upper layer flow in the downstreamrdirection. This should not be confused with what is called dilution flow in Appendix II-1 and Appendix V-2. (This dilution flow is defined by Equation (1) in Appendix I1-1). These two appendices deal with the ecological effects of the Hudson River which are better described by the dilution flow concept mentioned above. However, no indication is given at this point or in either Appendix as to why "ecological effects ....... are better described" by the Staff concept of dilution flow, as given by Equation 1, page 8 of these comments. 262

2. COMMENTS ON THE STAFF'S CALCULATION OF ENTRAINMENT LOSS On pages A-62 through A-64, the Staff presents a model of entrainment loss. On pages A-68 and A-69, this model is used to calculate the percentage of larval striped bass entrained by Units 1 and 2 at Indian Point.

This model presents a very conservative view of entrainment in the river. A number of factors are ignored, the consideration of each one of which will result in reduced estimate of the percentage entrained. These considerations include:

1. The role of density induced circulation.

2. The role of vertical diurnal movement of the organisms.

3. Susceptibility to entrainment These comments are directed toward showing how the factors of density flow and vertical diurnal movement can be introduced to the Staff's model, and how the notions of planktonic movement and uniform distribution make the entrainment models employed by the staff quite conservative.

The Staff's model is based on the concept of the probability of capture of an organism as it passes Indian Point in the flow. The probability of capture per pass is given as Qc/QT, the ratio of the station cooling water flow to the average tidal flow. The oscillating motion of the tide is recognized so the number of passes, or possible times capture can occur, is 263

greater than once. The number of nasses is shown to be given by QT/QD' the ratio of 'the average tidal flow to the estuary dilution flow. Very simply, but approximately stated, the total probability of capture is given by the product of the probability of capture on a single pass times the total number of passes, or P = QT QC QT QD QD ...... (10) Equation 10 is only close to being accurate when the probability of capture on a single pass is low. Otherwise, recognition must be given to the fact that after each pass, a certain number of organisms has been removed from the system, reducing the number of the original batch, and therefore the number available for capture on the next pass. The Staff model recognizes this and presents a careful treatment of the probability notion. The probability of withdrawal per pass is shown to be very small and the Staff concludes that an appropriate expression, given by their Equation 12, is: PT QC QD 1-V 1-1/2 (1-v) Q* QD. 1 in which: v = the fraction of particles which have passed the condenser and are re-exposed due to recirculation. 264 Q ixrk, Lav Icr:-' 9\at tisI(y E ngineccrs

The cooling water recirculation ratio, v, is obtained using model and prototype data as a tracer and is estimated to be on the order of 1 4 %j QC/QD is also relatively small, and for ease of explanation in this section, we will use the simple QC/QD as the staff's estimator of entrainment, recognizing that in the actual case, their actual model will give somewhat lower value since the recirculation and higher order probability terms are not dropped. Note the Staff's statement after presentation of Equation 12. Equation 12 shows that the total probability of being withdrawn is proportional mainly to the ratio of cooling water flow to the river freshwater flow. It is almost independent of the tidal characteristics, although these characteristicsare important in that they provide the mixing and dilution which must be met in order for this model to be accurate. We disagree with the last sentence of this statement. When higher Qrder terms are neglected, the model the Staff presents can be obtained just as readily by assuming a plug flow non-tidal river moving at the rate QE. From this standpoint is virtually "independent of the tidal characteristics." It is true that the tidal-characteristics are important and important from the viewpoint of mixing and dilution, but this mixing and dilution is not recognized by the Staff. No attempt has been made to include estuary flushing or exchange characteristics, the real means by which an estuary mixes and dilutes, other than the previously demonstrated erroneous estimate of estuary dilution flow. 265 Quirk, Latvlcr S`Nlatusk- Engineers

Consider first the role of diurnal migration of the organisms. The Staff addresses itself to this on page A-69, saying: These values are based on area-averagesusceptibility. However, it is known that the larval striped bass make vertical diurnal migrations in the water column and are most concentrated from mid-depth to the surface at night but from mid-depth to the bottom during the day. These distributional patterns are important since the cooling water is taken from mid-depth to the surface. Thus, there would a significant difference in the day vs. nighttime susceptibility of the larvae, i.e., lower during the day and higher at night. Since the length of day and night are not equal at this time of year, these organisms may be slightly less susceptible to entrainment than predicted using this technique, provided that the deeper water is moving seaward. We object to the use of the word "slightly" in the last sentence of the above statement, as well as to the !tatement that the organisms "are most concentrated from mid-depth to the surface at night." A more accurate description would be to say that the organisms are known to move up from the bottom during the night, and tend to spread out into a relatively uniform distribution throughout the water column during the night, as opposed to being concentrated in the bottom during the day. An estimate of the reduced impact of entrainment, due to recognizition of this diurnal movement, can be obtained by computing the average probability of capture throughout the day. During the period of the year when this activity occurs, (+/- 3 weeks about June 21), daylight hours represent roughly two-thirds of the day and darkness roughly one-third of the day. 266 Quirk, Lawvlor -7NIatuskx- Engineers

Assume that the upper layer larval concentration is zero during the daylight hours, and at night that the concentration of larval organisms-is uniform throughout the water column. Actually, there will probably be some organisms in the upper layer during the day but this should be offset by only a tendency to approach uniformity from the bottom up. The longer daylight period will allow a greater period of time over which the organisms are "programmed" to seek the deeper layers. This suggests that the description of concentration below mid-depth during daylight hours is the more stable condition, and that the diurnal upward movement, since it has less time in which to equilibrate, is stable for a shorter percentage of its total period Since the cooling water "is taken from mid-depth to the surface," the probability of withdrawal of organisms during the day is zero, and at night is QC/QT, as before. Thus, the average probability of capture per pass is 1/3 (QC/QT). The total number of passes is still given approximately by QT/QD, so that the fraction entrained is now given by I/ 3 (QC/QD), or one-third the original estimate, haraly worthy of the state-ment "slightly less susceptible to entrainment." The Staff suggests, however, that this technique is only valid "provided that the deeper water is moving seaward." In the next paragraph on page A-69, the Staff goes on to say: 267 Quirk, Lawler "YlatuskyEngineers

However, if the density flow is well developed, then these diurnal migrations will cause them to occupy an inland-moving zone during the day and a seaward moving zone at night. Since their occupancy within the water mass moving inland would be of longer duration than within the watbr mass moving seaward on the surface, the length of time which they are susceptible to entrainment may be much longer than predicted in the above calculations. This is an important consideration in that the probability that they will be withdrawn is. related to the number of exposures. A single week of exposure would increase the likelihood of withdrawal to about 34% and 10 days would result in about 45% of the larvae being entrained (assuming random distribution in the water column).. These time periods do not seem unrealistic based on the behavior of larval striped bass and the high probability for the occurrence of density flows at Indian Point. As a consequence, the staff believes that the 25% estimate derived by the above calculations is probably somewhat low. However, the increased residence time within the volume of water which passes back and forth in front of Indian Point may be partly offset by a reduction in the average probability of withdrawal per pass, which results from the non-random distribution within the water column. Consequently, the staff believes that the total average probability of withdrawal of larval striped bass migrating downstream past the Station is approximated by the 25% figure, and that this fraction is the best estimate that can be made using avaialble infbrmation. We disagree with the Staff's analysis of the influence of the density flow on entrainment. As presented previously in the two layer flow model, the upper layer flow, QU, exceeds the lower layer flow, QL, by an amount equal to the freshwater runoff. In Reference (11),,QL&M shows that the upper layer flow corresponding to freshwater runoff of 7500 cfs (used by the Staff in their analysis on page A-68) is 35,000 cfs. The corresponding lower layer flow is 28,000 cfs. More careful analysis of this shows that if the daylight-darkness factor is taken into account, there will be a substantial net transfer in the landward direction rather than seaward. This suggests that if the organisms were subject to the density flows in the manner in which the Staff suggests they are, then the net 268 Quirk, Lawlcr t2'.Niattusky Engin(*ers

movement of all organisms will be upstream, and for some (that portion which remains in the lower layer during the night-time hours) this will be the only movement. Note that, in the model used by the Staff, entrainment only occurs during actual passage past the plant. The influence of density flows as suggested by the Staff would therefore expose only organisms whose origin is below the plant to potential capture by the plant. What we are saying here is that the staff is using a Lagrangian form of reference; i.e., is following the motion of a typical sample of organisms as they move back and forth in the general vicinity of the plant. Simultaneous super-. position of the density flow and organism diurnal movement on the Staff's probability model results in a net upstream motion of the organism. Therefore, only those whose origin is below the plant will have an opportunity for capture.* Simplify the analysis by recognizing that the net effect of the tide is to yield a total probability of capture equal to approx-imately QC/QD, when density flow and diurnal movements are not present. By analogy, for a two layer density flow tidal system, in which, for the moment, vertical diurnal movement is neglected, the fraction of entrained organisms is given by Qc/QU, the ratio of the plant flow to the upper layer flow. Recognize also that in this case this capture applies only to those organisms appearing in the upper layer.

• When tidal motion is included, this statement should be modified to include those organisms whose origin is with a tidal excursion above the plant. 269 Quirk, La-v'ier7Iatuskj- Engineers

Now introduce diurnal movement and recognize that,- just as in the tidal analysis, the alternating seaward-landward movement will expose some of the organisms to more than one pass by the plant. Those that will be exposed will be those whose origin is below the plant, and which move up into the upper layer after they have moved landward in the lower layer, past the plant, and then prior to the end of darkness, will move back in the seaward direction past the plant. The probability of capture per pass, recognizing that roughly half of the organisms reach the upper layer during the darkness hours, will be given by Qp/ 2 Qu. The number of passes is equal to the number of times the organisms introduced into the seaward directed upper layer pass the plant between the time the particle of water in the lower landward directed layer first reaches the plant from below to the time it finally reaches a point above the plant, at which point the seaward return remains above the plant. This is given as follows: Number of passes past the - Qu plant in the upper layer QL - 2T - Qu-T

                                   =       Qu
                                       -QL   - Qu T is  the period of darkness and 2T the daylight period.           The denominator   [QL - 2T - Qu - TI is    simply the net upstream move-ment that takes place each 24 hour day.

270 Quirk, Lawler *M'Matuskv Engineers

To derive the numerator, consider a particle in the lower layer, just QL

• 2T distance seaward of the plant, at the onset of daylight. On a Aet, or daily cyclic basis, it must move upstream this distance, less one net translation (QL
• 2T - Qu
• T) before it can be said to have reached a point such that its organisms, during their sojourn in the return flow, will still be above the plant, and therefore no longer susceptible to entrainment. This net distance is equal to I[QL'2T] - [QL-2T - Qu.T]lor Qu.T, the numerator of the above expression. The ratio of this net upstream movement required to push the particle out of the entrainment zone to the net translation each day, yields the number of passes to which the organisms in the particle are subject.

Following the Staff's probability notation, the formula for entrain-ment for this case is given: PT 1 - l -Pe )n in which: PT = total fraction entrained Pe = entrainment per pass, = Q0 I ) 2 Qu n = number of passes, = Qu 2 QL-Qu For the case of density flow corresponding to a runoff of 7500 cfs, we have: 271 Quirk, Lawler .YN.atuskyEnginecrs

Qc = 2,500 cfs Qu = 35,500 cfs QL = 28,000 cfs v= 0.14 (page A-64) Pe= 0.03 PT= 0.05 or 5% entrainment loss Summarizing, we believe that three cases may be viewed as possible: Percentage Loss by Condition Entrainment

1. Density flow only 3%

2. Diurnal movement only 8%

3. Density flow with diurnal movement 5%

These estimates have been computed employing the Staff model for entrainment loss, modified for either density flow, diurnal movement or both. They show clearly that the Staff opinion that these two mechanisms offset each other is in error, and that the Staff estimate of 25% entrainment loss is not "the best estimate that can be made using available information." Actually, we believe that all of these models yield conservative estimates of the actual effect. As shown above, the model in which diurnar movement and density flow is introduced, applies essentially to larval organisms originating seaward of the plant. Using the Staff's notion of the interaction between these two mechanisms, it is seen that all organisms originating above 272 Quirk, 1-rwltr latixsky Engineers

a point between Qu.T and a tidal excursion above the plant, will not be exposed to entrainment during the planktonic stage. The foregoing has been presented primarily to indicate that relatively simple models, of the type presented by the Staff in the draft detailed statement, must be interpreted extremely carefully. These models are clearly very conservative and note of this fact should be made. Statements such as:

     "In conclusion, based on these considerations,,about 25% of the larval striped bass may be entrained as they migrate downstream past the Indian Point site.

(Reference A-69, Draft Detailed Statement) are misleading, when care is not taken to demonstrate, in a similar quantitative fashion, how known river and biological behavior can alter these conclusions. In its discussion of probable biological effects in Chapter V, "Environmental Impact of Indian Point Unit #2 Operation with Unit #1 Operation", the Staff, on pages V-52 through V-55, discusses the probable impact of its conclusion that 25% of the larval striped bass may be entrained by the plant. The statement is made that:

     "The eggs and larvae drift with the currents in a net downstream direction; large numbers pass the plant."

The Staff then states that data show that 75 to 90% of the young juveniles are below Indian Point by late July and August and 273 Qxirk, Lawler EV.latinkv Engineer:

then go on to state:

      "If we assume: (1) that all these fish migrated past the plant during the life  stage which is susceptible to to entrainment; (2) that density independent factors are responsible for mortality in the population; and (3) that entrainment mortality is 100%, then the operation of Indian Point Units #1 & will effectively reduce recruitment resulting from reproduction by about 19% to 22%,"

We take strong exception to the thrust of these statements. First of all, it is not at all clear just how the eggs and larvae drift with the currents and for how long. The analysis above shows that if purely planktonic behavior, other than diurnal vertical movement is assumed, then only a small portion of the estuaries larval population is even susceptibel to entrainment (those below or just above the plant). None of the immature stages are purely planktonic. Even the eggs have a density different than water and tend to settle in the absence of any current. Furthermore, the eggs only exist on the order of two days, before hatching; only those eggs spawned in close proximity to the plant could be susceptible to entrainment by the plant as eggs. The larvae are sometimes described as planktonic, but by as early as the sixth or seventh day of their existence, are reported to absorb the yolk sac and begin diurnal movement. From this time forward their swimming ability increases, suggesting that the description of drifting with the current is not accurate. Furthermore, the presumption that susceptibility to entrainment is controlled by flow ratio is also highly questionable, since 274

the swimmers may very well avoid the intake. Studies do show that by September, most of the young striped bass have reached Haverstraw Bay. To assume that this means they are susceptible to entrainment as they pass Indian Point in the manner assumed in the draft detailed statement is misleading. It is true that their passage through the river section bordered on the east by Indian Point probably occurs when they are less than 3 inches long, and in many cases less than 2 inches long, and that fish of 2.inch size or less may be entrained. This does not mean, however, that the entire population passing is planktonic, is subject to tidal and other current drift, is distributed uniformly acrbss the cross-section and, therefore, is subject to 25% entrainment. These young striped bass are known to seek the bottom as well as shallows and shoal areas, none of which describes the source of the major volume of water passing the Indian Point intake. In conclusion, we state that the assumptions of uniform distri-bution across the section, and of downstream drift and planktonic behavior of all entrainable forms are not supportable by the known behavior of the immature fish at many stages of their development. Therefore, the percentage entrainment should be substantially less than the values given above in the modified entrainment model (3 to 8%) and in no way even close to the 25% estimate given by the AEC. 275

Appendix F RADIOLOGICAL DISCHARGES Although Con Edsion concurs with the general conclusions with respect to the radiological discharges and the resulting anticipated doses to man and to biota, there is, however, disagreement with several of the assumptions util-ized in arriving at these conclusions. Those areas where major differences exist are discussed below: I. No credit was given for the blowdown intertie system and the filtration systems which Con Edison has committed to installing prior to the com-pletion of the first refueling outage. Since the release:estimates stated should reflect equilibrium operation averaged over the life of the plant, credit should be given for these systems in estimating releases because they will be in-service over the remaining years of the plant life and because the releases prior to their installation should be less than the average because of the time required for (crud) activity to build up and for performance degradation and leakage to occur. A brief functional description of these new systems follows: (1) Blowdown Intertie System Thd intertie between the Indian Point Unit No. 2 steam generator blowdown lines and the new Indian Point Unit No. 1 secondary puri-fication system is shown in Figure .2.3-14 of the Indian Point Unit No. 2 Environmental Report. In the event that the leakage from the primary to secondary side of the Indian Point Unit No. 2 steam generators is radioactive, the secondary blowdown which normally would have gone to the steam generator blwodown tank is diverted to the Indian Point Unit No. 1 blowdown flash tank to be treated prior to being discharged to the river. Only 1/3 of the liquid ifthe flash tank would flash to

2. steam in the absence of any cooling. From the blowdown flash tank, the flashed steam is sent to the Indian Point Unit No. 1 main condenser flash tank and becomes Indian Point Unit No. I feedwater. The reduction in the amount of steam vented plus the very high partition factor for iodine in the condenser would essentially eliminate this source of ac-tivity whenever the Unit No. i condenser is in operation. Any releases would be through the Indian Point Unit No. 1 condenser air ejector which exhausts to the Indian Point Unit No. 1 stack. When the Unit No. 1 con-denser is not operating, gases from the flash tank divert to an already-existing vent and go directly to atmosphere via a vent on the roof. The blowdown flash tank condensate is cooled by river water in a heat exchanger, processed through a filter and demineralizer, and then discharged to the river. In addition, in the event of high activity in the demineralizer effluent, this effluent can be rerouted to the waste collection tanks for recirculation through the filter and demineralizer or for processing through the existing.liquid waste disposal system. There are two 66,000 lb/hr in-line booster pumps to overcome the head required to complete the flow path through the filters, demineralizers and overboard piping; two identical 132,000 lb/hr CUNO cartridge-type CG-S filters with pressure differential gauges which will be read peri-odically to assure changing of cartridges when required and two identi-cal 66,000 lb/hr Illinois Water Treatment 36" x 60" 150 psig ASME code demineralizers, each with 21 cubic feet of IWT NR-6 non-regenerable nuclear grade mixed-bed resin. Available operating experience to date indicates a minimum decon-tamination factor of 10 for the demineralizers. (Page 111-4, Top). 277

3. (2) Filtration System A simplified diagram of Indian Point Unit No. 2 Air Exhaust Filtration Systems is shown in Figure I. There are five filtration systems, each of which consists of three filters- roughing, HEPA and charcoal. The roughing filters remove the large particles from the air stream to preserve the operating life of the HEPA filters. Their construction is fire resistant with the mdeia composed of a glass fiber mat reinforced with stainless steel wire cloth. The high efficiency particulate air (HEPA) filters are designed and tested for greater than 99% removal efficiency for 0.3 microns or larger particles. The filter media is made of glass fiber with asbestos. Filter frames are made of stainless steel, and asbestos separators re-sistant to mositure and high temperature are used. The charcoal filters are fabricated with stainless steel frames filled with activated char-coal. Experiments have demonstrated that the iodine removal efficiencies of at least 99% can be expected. Each charcoal filter plenum is provided with a water dousing system which is designed to drench the absorbers in the extremely unlikely event of a charcoal filter fire. The HEPA and charcoal filters will be tested in place after instal-lations to insure overall filter design capability is achieved. There are two Containment Building (CB) purge and/or Primary Auxiliary Building (PAB) exhaust fans in the fan room. Each fan can provide a flow rate of 55,000 cfm. During normal operation (i.e., no CB purging), one fan is operating for PAB exhaust and the other is on standby. 278

4. The air streams from the CB purge and the CB pressure felief each pass through their own set of roughing, HEPA and charcoal filters. The other three streams, the PAB exhaust, the Boric Acid Evaporator Building exhaust and the vents from the waste holdup tank pit and the blowdown tank area also each have their own set of roughing, HEPA and charcoal filters. In the case of these three streams, there is a bypass line around the charcoal filter. For these three streams, the roughing and HEPA filter will always be used, but the charcoal may be bypassed if there is no significant iodine in those streams. (Page 111-40; Top). II. Credit should have been given for the Indian Point Unit No. 1 evaporator in estimating the releases from that unit. The evaporator has been opera-ting since March 1, 1972 at about half of its rated 12 gpm capacity with an overall decontamination factor of approximately 100 and an operating factor of about 40 to 50 percent. The capacity of this system is more than sufficient to process all liquids currently going to the liquid waste system at Indian Point Unit No. 1. (Page 111-45) III. Based upon the modifications being made to the Indian Point Unit No. 2 waste disposal system including the addition of a polishing demineralizer, the applicant believes that 104 is a conservative estimate of the overall inlet to outlet decontamination factor for all isotipes including radioac-tivity but excluding tritium. A brief description of the modifications presently being made to the liquid waste disposal system is presented below: The main modification to the Indian Point Unit No. 2 liquid waste disposal system is the addition of a distillate cooler, a demineralizer and a filter. The addition of these items will result in a reduction in the activity released 279 from the plant. The distillate is pumped from the waste evaporator distillate tank, cooled by component cooling water in the heat exchanger (distillate cooler)

5. before being processed through the demineralizer and the filter, and then collected in the waste condensate tanks. The demineralizer contains 2.5 cubic feet of IRN 150 ROHM-HAAS non-regenerable mixed bed resin. The filter is CUNO Model No. 51044, and is expected to remove particulate and demineralizer cakry-over down to approximately 510 micron particles. A pressure gauge at the inlet of the filter will indicate plugging of the filter. In addition, Ginna-type modifications have been made to the evaporator internals. Available operating experience demonstrates that a decontamination factor (ratio of inlet to outlet concentration) of ten is the lowest limit to be expected (due solely to the demineralizer) in this kind of a system. Both the modification of the waste evaporator and the addition of the demineralizer and the filter to.the liquid waste disposal system have been completed except for some testing, and both are scheduled for availability by initial criticality. (Page 111-42, Bottom; Page 111-42, Top; Page A-45, b). 280

BU:7/I:*tDva DZSCHARG, DUCT CONTAI.\SENT BUILDING PURGE &/or-PAP EXHAUST FANS 55,500 CFkl EACH B-.LIC A."D H L.PLDINO FILTERSt R... ROUGHItG R~J i - HPARCOA C - CH~kRCOAL

                                               .1 FROM LIQUID WASTE HOLDUP TANK CFM  VE'$NT AND CVCS HOLDUiP TALINS PIT 2,000 CFM FROet *3WODOW4N TANK AREA ps"1DL.LRY rN)                                                             ABUJ LfLGY CO                                                                B'JILDING IMT)'I!l POINT M".IT # 2 AIR EXHAUST' FILTRATION SYSTEM SINILUFIZD FLOW DIAGRAM

APPENDIX G Scope of Work for Ecological Studies at Indian Point 282

INDIAN POINT FIVE YEAR ECOLOGICAL STUDY PROJECT SCOPE The proposed five year ecological study will begin at full intensity on April 1, 1972. Thescope of work is proposed to accomplish the following major objectives: (i) Evaluate the biological significance of impinging fishes at our intakes. (2) Evaluate the biological significance of passing non-screenable organisms through the plants. (3) Evaluate the biological changes in the Hudson River ecosystem due to thermal and chemical discharge. Objective 1 - will be accomplished by estimating popftlation density, natural mortality, age distribution of the population, food habits, movements and migration routes, growth rates, exploitation rate on the screens, etc. These estimates will be made by mark-recapture procedures, aging of the population, etc. from the Haverstraw Bay area to the Beacon Bridge by collecting fish with trawls, seines, fish traps, gill nets, etc. Objective 2 - will be accomplished by determining the mortality rate of all nonscreenable organisms passing through the plants and predicting the biological significance of such a mortality rate on the Hudson River fishery. Objective 3 - will be accomplished by a biological survey of all acquatic organisms, physical and chemical measurements at the Indian Point area compared with control regions and determining species diversity and biomass per area in each region. These studies were recommended to Con Edison by the Lower Hudson River Policy Committee which is composed of members from agencies with regulatory responsibilities for the natural resources of the Hudson River. The studies will yield pertinent data necessary to evaluate the con-tinuing environmental impact of Units No. 1, 2, and 3. 283

Radiological Investigation of the Aquatic Habitat of Hudson River Project Scope: To determine radiological effects of Indian Point operation on the ecosystem. This is a continuing study, which originally commenced July 1969, which traces the fate of radio-nuclides released from the plant through the aquatic environment. This study, which commenced in July 1971 and continues through April 1973, consists of the following major study areas:

1. Routine sampling and analysis of water and sediment, rooted vascular plants and fish for radionuclides.

2. Provide an inventory of major long lived gamma emitting radionuclides.

3. Study the effect of salinity variation on the removal of radionuclides for the sediment4

4. Study of radionuclide content of phytoplankton and zoo-plankton.

More specifically, the radionuclide studies !( above) conducted over the past two years have provided important information concerning the fate of radionuclides released to the Hudson River from the operation of the Indian Point facility. This current program will provide a continuing record of radionuclide levels which can be compared with past sampling results and will serve to provide baseline data for evaluating releases from Units 2 and 3 as they go into operation. The remaining three portions of the study are considered exploratory as opposed to monitoring. These three studies are expected to provide answers to the following questions:' 284

1. What is the total inventory of radionuclides in the sediments of the lower Hudson River estuary? What fraction of Indian Point liquid radionuclide dis-charges deposit in the sediments, and in which loca-tion does most of this deposition occur?

2. What is the variation in radionuclide inventory of the bottom sediments along a longitudinal section of the river? Can quantitative differences in sediment radioactivity at points along this long-itudinal section be correlated with difference in salinity?

3. To what extent do the phytoplankton and zooplankton of the estuary accumulate radionuclides of nAtural and artificial origin? How do such accumulated levels in the plankton relate to radionuclide concentrations in higher links in the food chain, and especially in fish which may be consumed by man?

This program has provided considerable information on the fate of radio-nuclides released to the Hudson River from the operation of the Indian Point facility. In particular, the studies have given perspectives to the relatively small quantities of these operational releases com-pared to radionuclides from weapons testing fallout and natural sources. A continuation of this program is necessary for two reasons. Foremost, the monitoring phase of this program is necessary to determine compliance with the Atomic Energy Commission radionuclide release limits as put forth in 10 CFR Part 20. Second, far more information is necessary of the pathway of radionuclides to man and the ultimate potential exposure to man from releases at Indian Point. 285

The information from this program is considered to be essential in preparing for AEC hearings upcoming of Unit 3 and conversion of the provisional Unit 1 license to a permanent license. The importance of the information to date has already been shown in Unit 2 hearings where, based on information from these studies, the intervenors did not raise the question of radiological releases., It is essential, therefore, that this program be continued. Fathometer Studies at Indian Point Project Scope: The proposed study is a continuation of a survey of the density and distribution of fish in the vicinity of Indian Point. The specific objectives of the study are:

1. Describe and quantify the distribution of fish in relation to the termal discharge and infake screens.

2. To compare the density of fish in the vicinity of the plant with the quantity of fish removed from the intake.

3. To attempt to monitor the density of fish in the vicinity of the intakes during specific fish tests.

The echosounder will also be used by Texas Instruments in their five year ecological study so that fish density can be monitored during the sampling of fish with trawls. Objectives 1 and 2 will be accomplished by surveying a set pattern of transects which include the entire plant site. The fish recorded on the echosounder tape are counted by areas and then a fish density figure is computed based on the area covered by the echosounder. A density of fish by volume will be computed and compared with the number of fish per volume 286

removed to the intake screens. Objective 3 will be accomplished by mounting the transducer of the echo-sounder to beam across an intake structure and to record fish approach-ing the intake. Part 1 - Analysis of Fish Mortality Data at Indian Point Project Scope: Data has been collected on fish impingement at Indian Point since April 1970 under the direction of the Office of Environmental Affairs. The number of fish caught on the screens has fluctuated over a wide range. The variables that could have affected the number of fish caught are various parameters of plant operation, such as flow, tempearature rise through the condensers, number of pumps and condensers in use, etc., and various environmental factors such as the influence of night versus day, the influence of tidal conditions, fresh water flow and aqsociated salt water intrusion, temperature, etc. It is likely that some or several of these factors may have highly significant bearing on the fish impingement at Indian Point. The fish impingement data will be analyzed in accordance with standard statistical procedures using the facilities of a computer. Part 2 - Fish Sampling at Indian Point Intakes Project Scope:

1. Gather data on the seasonal occurrence, species composition, and size composition of the fish collected at the intakes.

2. Conduct tests of various fish protection devices and modes of operation.

3. Monitor fish at the intakes in order to document the rate of withdrawal.

4. Recover marked fish from the intake screens to establish a rate of exploitation by the intakes on selected fish populations.

287

Monitoring of fishes impinged at our intakes at Indian Point has been requested by the New York Department of Environmental Conservation. Also, to estimate the exploitation rate of fishes on our screens, the number of marked fishes (part of study A) collected on the screens has to be determined. The fish monitoring on the screens is also a pertinent part of the overall testing procedure, which is needed to determine the best intake design and mode of plant operation to reduce the impact of plant operations on fish populations. Part 3 - Indian Point Flume Study The proposed flume study at Indian Point is designed to investigate the behavior of white perch and other species in relation to water flows and fish protection devices. Scope of Work: I. Evaluate the behavior of white perch in relation to fixed and traveling screens.

2. Study the behavior of white perch at various velocities in order to predict behavior of fish at proposed common intake.

3. Evaluate the fish protection value of various devices proposed.

for Indian Point: a) horizontal traveling screen b) air bubbler c) sound Objective (1) will be accomplished by exposing test groups of white perch (and other species) to various screen arrangements and observing (and recording on video tape) their avoidance responses. Factors which may influence the behavior of fish such as water temperature, diurnal activity cycle, salinity and size of fish will be tested. The high percentage of white perch collected at the screens indicates that they

may display some unique behavioral problems. Objective (2) will be accomplished by exposing test fish to a series of approach velocities (velocity immediately in front of screens) to determine if the fish will avoid the screens at the proposed common intake structure. Objective (3) will be accomplished by exposing test fish to various fish protection devices and recording their avoidance responses. The study of the fish problem at Indian Point has revealed thus far that a reduction in approach velocity is an effective way of reducing the number of fish impinged on the intake screens. However, velocity reduction has not eliminated the problem and is only available as a method of fish pro-tection during the winter months. Laboratory tests of the swimming ability of white perch have indicated that the fish, in sizes caught in the intake screens, can swim at a speed in excess of the approach velocity now existing at Unit 1. This indicates that there is a behavioral problem since the fish does not exercise its ability to escape. Attempts have been made to observe the behavior of fish in front of the screens with a diver and using underwater television. In both cases the turbidity of the water prevented visual observation of the fish. A test device (the flume) is designed to permit observation and recording of fish behavior. 289

APPENDIX H Testimony of Gerald J. Lauer, Ph. D., New York University on "Effects of Chemical Discharges from Indian Point Units 1 and 2 on Biota and on River Chemistry," April 5, 1972. Testimony of Gerald J. Lauer, Ph. D., New York University on "Effects of Elevated Temperature and Entrainment on Hudson River Biota," April 5, 1972. Testimony of John P. Lawler, Ph. D., Quirk, Lawler, and Matusky Engineers on "The Effect of Indian Point Units 1 and 2 Cooling Water Discharge on Hudson River Temperature Distribution," April 5, 1972. Testimony of John P. Lawler, Ph. D., Quirk, Lawler, and Matusky Engineers on "The Effect of Entrainment at Indian Point on the Population of the Hudson River Striped Bass," April 5, 1972. All testimonies presented in the Licensing Hearings before the ASLB Board. 290

Applicant's Responses to the Comments from Federal, State and Local Agencies and Interested Persons and Groups made on June 9, June 27, July 5, July 6, July 27, and August 1, 1972 are in the Docket File (Docket No. 50-247) in the Public Document Rooms.}}