ML083540614

NUREG-1437, Suppl. 38, Vol. 2, Dfc, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 38, Regarding Indian Point Nuclear Generating, Unit Nos. 2 and 3, Appendices

ML083540614
Person / Time
Site:	Indian Point
Issue date:	12/01/2008
From:	Office of Nuclear Reactor Regulation
To:
Beltz G
References
NUREG-1437 S38 V2 DFC
Download: ML083540614 (321)

Text

NUREG-1437, Vol. 2 Supplement 38 Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 38 Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3 Draft Report for Comment Appendices Office of Nuclear Reactor Regulation

AVAILABILITY OF REFERENCE MATERIALS IN NRC PUBLICATIONS NRC Reference Material Non-NRC Reference Material As of November 1999, you may electronically access Documents available from public and special technical NUREG-series publications and other NRC records at libraries include all open literature items, such as NRC=s Public Electronic Reading Room at books, journal articles, and transactions, Federal http://www.nrc.gov/reading-rm.html. Register notices, Federal and State legislation, and Publicly released records include, to name a few, congressional reports. Such documents as theses, NUREG-series publications; Federal Register notices; dissertations, foreign reports and translations, and applicant, licensee, and vendor documents and non-NRC conference proceedings may be purchased correspondence; NRC correspondence and internal from their sponsoring organization.

memoranda; bulletins and information notices; inspection and investigative reports; licensee event reports; and Commission papers and their Copies of industry codes and standards used in a attachments. substantive manner in the NRC regulatory process are maintained atC NRC publications in the NUREG series, NRC The NRC Technical Library regulations, and Title 10, Energy, in the Code of Two White Flint North Federal Regulations may also be purchased from one 11545 Rockville Pike of these two sources. Rockville, MD 20852B2738

1. The Superintendent of Documents U.S. Government Printing Office Mail Stop SSOP These standards are available in the library for Washington, DC 20402B0001 reference use by the public. Codes and standards are Internet: bookstore.gpo.gov usually copyrighted and may be purchased from the Telephone: 202-512-1800 originating organization or, if they are American Fax: 202-512-2250 National Standards, fromC

2. The National Technical Information Service American National Standards Institute nd Springfield, VA 22161B0002 11 West 42 Street www.ntis.gov New York, NY 10036B8002 1B800B553B6847 or, locally, 703B605B6000 www.ansi.org 212B642B4900 A single copy of each NRC draft report for comment is available free, to the extent of supply, upon written request as follows: Legally binding regulatory requirements are stated only Address: U.S. Nuclear Regulatory Commission in laws; NRC regulations; licenses, including technical Office of Administration specifications; or orders, not in Mail, Distribution and Messenger Team NUREG-series publications. The views expressed in Washington, DC 20555-0001 contractor-prepared publications in this series are not E-mail: DISTRIBUTION@nrc.gov necessarily those of the NRC.

Facsimile: 301B415B2289 The NUREG series comprises (1) technical and Some publications in the NUREG series that are administrative reports and books prepared by the staff posted at NRC=s Web site address (NUREGBXXXX) or agency contractors http://www.nrc.gov/reading-rm/doc-collections/nuregs (NUREG/CRBXXXX), (2) proceedings of conferences are updated periodically and may differ from the last (NUREG/CPBXXXX), (3) reports resulting from printed version. Although references to material found international agreements (NUREG/IABXXXX), (4) on a Web site bear the date the material was brochures (NUREG/BRBXXXX), and (5) compilations accessed, the material available on the date cited may of legal decisions and orders of the Commission and subsequently be removed from the site. Atomic and Safety Licensing Boards and of Directors=

decisions under Section 2.206 of NRC=s regulations (NUREGB0750).

NUREG-1437, Vol. 2 Supplement 38 Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 38 Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3 Draft Report for Comment Appendices Manuscript Completed: December 2008 Date Published: December 2008 Office of Nuclear Reactor Regulation

1 COMMENTS ON DRAFT REPORT 2 Any interested party may submit comments on this report for consideration by the NRC staff.

3 Comments may be accompanied by additional relevant information or supporting data. Please 4 specify the report number NUREG-1437, Supplement 38, draft, in your comments, and send 5 them by March 11, 2009, to the following address:

6 Chief, Rules Review and Directives Branch 7 U.S. Nuclear Regulatory Commission 8 Mail Stop TWB-05-B01 9 Washington, DC 20555-0001 10 Electronic comments may be submitted to the NRC by e-mail at 11 IndianPoint.EIS@nrc.gov.

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

13 Drew Stuyvenberg 14 Project Manager 15 U.S. Nuclear Regulatory Commission 16 Mail Stop O-11E19 17 Washington, DC 20555-0001 18 Phone: 301-415-4006 19 E-mail: andrew.stuyvenberg@nrc.gov

1 ABSTRACT 2 The U.S. Nuclear Regulatory Commission (NRC) considered the environmental impacts of 3 renewing nuclear power plant operating licenses for a 20-year period in NUREG-1437, 4 Volumes 1 and 2, Generic Environmental Impact Statement for License Renewal of Nuclear 5 Plants (hereafter referred to as the GEIS),(1) and codified the results in Title 10, Part 51, 6 Environmental Protection Regulations for Domestic Licensing and Related Regulatory 7 Functions, of the Code of Federal Regulations (10 CFR Part 51). In the GEIS (and its 8 Addendum 1), the NRC staff identified 92 environmental issues and reached generic 9 conclusions related to environmental impacts for 69 of these issues that apply to all plants or to 10 plants with specific design or site characteristics. Additional plant-specific review is required for 11 the remaining 23 issues. These plant-specific reviews are to be included in a supplement to the 12 GEIS.

13 This supplemental environmental impact statement (SEIS) has been prepared in response to an 14 application submitted by Entergy Nuclear Operations, Inc. (Entergy), Entergy Nuclear Indian 15 Point 2, LLC, and Entergy Nuclear Indian Point 3, LLC (all applicants will be jointly referred to as 16 Entergy) to the NRC to renew the operating licenses for Indian Point Nuclear Generating Unit 17 Nos. 2 and 3 (IP2 and IP3) for an additional 20 years under 10 CFR Part 54, Requirements for 18 Renewal of Operating Licenses for Nuclear Power Plants. This draft SEIS includes the NRC 19 staffs analysis which considers and weighs the environmental impacts of the proposed action, 20 the environmental impacts of alternatives to the proposed action, and mitigation measures 21 available for reducing or avoiding adverse impacts. It also includes the NRC staffs preliminary 22 recommendation regarding the proposed action.

23 Regarding the 69 issues for which the GEIS reached generic conclusions, neither Entergy nor 24 the NRC staff has identified information that is both new and significant for any issues that 25 applies to IP2 and/or IP3. In addition, the NRC staff determined that information provided 26 during the scoping process was not new and significant with respect to the conclusions in the 27 GEIS. Therefore, the NRC staff concludes that the impacts of renewing the operating licenses 28 for IP2 and IP3 will not be greater than the impacts identified for these issues in the GEIS. For 29 each of these issues, the NRC staffs conclusion in the GEIS is that the impact is of SMALL(2) 30 significance (except for the collective offsite radiological impacts from the fuel cycle and high-31 level waste and spent fuel, which were not assigned a single significance level).

32 Regarding the remaining 23 issues, those that apply to IP2 and IP3 are addressed in this draft 33 SEIS. The NRC staff determined that several of these issues were not applicable because of 34 the type of facility cooling system or other reasons detailed within this SEIS. For the remaining 35 applicable issues, the NRC staff concludes that the significance of potential environmental 36 impacts related to operating license renewal is SMALL, with four exceptionsentrainment, (1) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the GEIS include the GEIS and its Addendum 1.

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

December 2008 iii Draft NUREG 1437, Supplement 38

Abstract 1 impingement, heat shock from the facilitys heated discharge, and impacts to aquatic 2 endangered species. Overall effects from entrainment and impingement may be SMALL to 3 LARGE, depending on the species affected. Impacts from heat shock likely range from SMALL 4 to MODERATE depending on the conclusions of thermal studies proposed by the New York 5 State Department of Environmental Conservation (NYSDEC). NRC staff did not find data that 6 suggest the effect of heat shock is likely to rise to LARGE. Given the uncertainties in the data 7 NRC staff reviewed, impacts to the endangered shortnose sturgeon could range from SMALL to 8 LARGE.

9 The NRC staffs preliminary recommendation is that the Commission determine that the adverse 10 environmental impacts of license renewals for IP2 and IP3 are not so great that preserving the 11 option of license renewal for energy planning decisionmakers would be unreasonable. This 12 recommendation is based on (1) the analysis and findings in the GEIS, (2) the environmental 13 report submitted by Entergy, (3) consultation with other Federal, State, and local agencies; (4) 14 the NRC staffs own independent review, and (5) the NRC staffs consideration of public 15 comments received during the scoping process.

16 Paperwork Reduction Act Statement 17 This NUREG does not contain information collection requirements and, therefore, is not subject 18 to the requirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). These 19 information collections were approved by the Office of Management and Budget, approval 20 numbers 3150-0004, 3150-0155, 3150-0014, 3150-0011, 3150-0021, 3150-0132, and 21 3150-0151.

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

Draft NUREG 1437, Supplement 38 iv December 2008

1 Table of Contents 2 ABSTRACT.................................................................................................................................. iii 3 Appendix A: Comments Received on the Environmental Review ............................................ A-1 4 Appendix B: Contributers to the Supplement............................................................................ B-1 5 Appendix C: Chronology of NRC Staff Environmental Review Correspondence Related to the 6 Entergy Nuclear Operations, Inc. Application for License Renewal of Indian Point 7 Nuclear Generating Unit Nos. 2 and 3 .......................................................................... C-1 8 Appendix D: Organizations Contacted...................................................................................... D-1 9 Appendix E: Indian Point Nuclear Generating Unit Numbers 2 and 3 Compliance Status and 10 Consultation Correspondence....................................................................................... E-1 11 Appendix F: GEIS Environmental Issues Not Applicable to Indian Point Nuclear Generating 12 Station Unit Nos. 2 and 3 .............................................................................................. F-1 13 Appendix G: U.S. Nuclear Regulatory Commission Staff Evaluation of Severe Accident 14 Mitigation Alternatives for Indian Point Nuclear Generating Unit Nos. 2 and 3 in Support 15 of License Renewal Application Review .......................................................................G-1 16 Appendix H: U.S. Nuclear Regulatory Commission Staff Evaluation of Environmental Impacts of 17 Cooling System ............................................................................................................. H-1 18 Appendix I: Statistical Analyses Conducted for Chapter 4 Aquatic Resources and 19 Appendix ........................................................................................................................I-1 December 2008 v Draft NUREG 1437, Supplement 38

1 Appendix A 2

3 4 Comments Received on the Environmental Review

1 Appendix A 2 Comments Received on the Environmental Review 3 Comments Received During Scoping and Scoping Summary Adoption 4 In this appendix, the NRC staff adopts the Scoping Summary Report for Indian Point Nuclear 5 Generating Unit Nos. 2 and 3 as prepared by the NRC staff in response to comments received 6 on the scope of the environmental review. The NRC staff issued the scoping summary report 7 on December 12, 2008. The Scoping Summary Report is available for public inspection in the 8 NRC Public Document Room (PDR), located at One White Flint North, 11555 Rockville Pike, 9 Rockville, Maryland, 20852, or from the NRCs Agencywide Documents Access and 10 Management System (ADAMS).

11 The ADAMS Public Electronic Reading Room is accessible at http://www.nrc.gov/reading-12 rm/adams/web-based.html. The scoping summary report is listed under Accession No.

13 ML083360115.

14 Persons who do not have access to ADAMS or who encounter problems in accessing the 15 documents located in ADAMS should contact the NRCs PDR reference staff by telephone at 1-16 800-397-4209, or 301-415-4737, or by e-mail at pdr@nrc.gov.

17 On August 10, 2007, the NRC published a Notice of Intent in the Federal Register (72 FR 18 45075) to notify the public of the Staffs intent to prepare a plant-specific supplement to the 19 GEIS (SEIS) regarding the renewal application for the IP2 and IP3 operating license. As 20 outlined by NEPA, the NRC initiated the scoping process with the issuance of the Federal 21 Register Notice. The NRC invited the applicant, federal, state, local, and tribal government 22 agencies, local organizations, and individuals to participate in the scoping process by providing 23 oral comments at scheduled public meetings and/or submitting written suggestions and 24 comments no later than October 12, 2007.

25 The scoping process included two public scoping meetings, which were both held on September 26 19, 2007, at Colonial Terrace, 119 Oregon Road, Cortlandt Manor, New York. The NRC issued 27 press releases and distributed flyers locally. Both sessions began with NRC staff members 28 providing a brief overview of the license renewal process and the NEPA process. Following the 29 NRCs prepared statements, the meetings were open for public comments. Approximately 50 30 attendees provided oral comments that were recorded and transcribed by a certified court 31 reporter.

32 The meeting summary, which was issued on October 24, 2007, and the associated transcripts 33 can be found in the NRC PDR or in ADAMS at Accession No. ML072851079. The transcripts of 34 the meetings can be found in ADAMS at Accession Numbers ML072830682 and ML072890209.

December 2008 A-1 Draft NUREG 1437, Supplement 38

Appendix A 1 The scoping summary contains all comments received on the review, as well as the NRC staffs 2 responses to those comments. Comments received on the draft SEIS will be included in this 3 Appendix of the final SEIS.

Draft NUREG 1437, Supplement 38 A-2 December 2008

Appendix B Contributers to the Supplement

1 Appendix B 2 Contributors to the Supplement 3 The Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, had overall 4 responsibility for the preparation of this supplement, assisted by staff from other NRC 5 organizations, AECOM, and Pacific Northwest National Laboratory.

Name Function or Expertise U.S. Nuclear Regulatory Commission Andrew Stuyvenberg Environmental Project Manager/Alternatives Rani Franovich Branch Chief David Wrona Branch Chief Bo Pham Branch Chief Dennis Beissel Hydrology/Water Use Elizabeth Wexler Ecology Dennis Logan Ecology Briana Balsam Ecology Jeffrey Rikhoff Socioeconomics/Land Use/Env. Justice Jennifer Davis Historical/Archeological Resources Steve Klementowicz Radiation Protection/Human Health Andrew Carrera Radiation Protection/Human Health Ekaterina Lenning Air Quality Robert Palla Severe Accident Mitigation Alternatives Earth Tech, Inc.

Roberta Hurley Project Manager Kevin Taylor Alternatives Stephen Duda Ecology Stephen Dillard Terrestrial Ecology Ed Kaczmarczyk Air Quality Matthew Goodwin Historical/Archeological Resources Robert Dover Alternatives/Nuclear Fuel Cycle Katie Broom Project Coordinator December 2008 B-1 Draft NUREG-1437, Supplement 38

Appendix B Name Function or Expertise Nicole Spangler Project Support Bonnie Freeman Administrative Support Pacific Northwest National Laboratory Jeffrey A. Ward Aquatic Ecology Valerie Cullinan Aquatic Ecology Lance W. Vail Hydrology/Water Use 1

Draft NUREG-1437, Supplement 38 B-2 December 2008

Appendix C Chronology of NRC Staff Environmental Review Correspondence Related to the Entergy Nuclear Operations, Inc.

Application for License Renewal of Indian Point Nuclear Generating Unit Nos. 2 and 3

1 Appendix C 2 Chronology of NRC Staff Environmental Review Correspondence 3 Related to the Entergy Nuclear Operations, Inc.,

4 Application for License Renewal of Indian Point Nuclear Generating 5 Unit Nos. 2 and 3 6 This appendix contains a chronological listing of correspondence between the U.S. Nuclear 7 Regulatory Commission (NRC) and Entergy Nuclear Operations, Inc., (Entergy) and other 8 correspondence related to the NRC staffs environmental review, under Title 10, Part 51, 9 Environmental Protection Regulations for Domestic Licensing and Related Regulatory 10 Functions, of the Code of Federal Regulations (10 CFR Part 51), of Entergys application for 11 renewal of the operating licenses for Indian Point Nuclear Generating Unit Nos. 2 and 3. All 12 documents, with the exception of those containing proprietary information, have been placed in 13 the NRCs Public Document Room, at One White Flint North, 11555 Rockville Pike (first floor),

14 Rockville, Maryland, and are available electronically from the Public Electronic Reading Room 15 found on the Internet at http://www.nrc.gov/reading-rm.html. From this site, the public can gain 16 access to the NRCs Agencywide Documents Access and Management System (ADAMS),

17 which provides text and image files of NRCs public documents in the Publicly Available 18 Records component of ADAMS. The ADAMS accession numbers for each document are 19 included below.

20 April 23, 2007 Letter to NRC from Entergy forwarding the application for renewal of 21 operating licenses for Indian Point Nuclear Generating Units 2 and 3, 22 requesting extension of operating licenses for an additional 20 years.

23 (Accession No. ML071207512) 24 April 23, 2007 Letter to NRC from Entergy forwarding a copy of reference documents 25 used in preparing the Environmental Report (Appendix E) for the 26 Indian Point Nuclear Generating Units 2 and 3 license renewal 27 application. (Accession No. ML071210108) 28 May 7, 2007 Letter to Entergy from NRC, Receipt and Availability of the License 29 Renewal Application for Indian Point Nuclear Generating Unit Nos. 2 30 and 3. (Accession No. ML071080133) 31 May 7, 2007 Letter to Ms. Patricia Thorsen, White Plains Public Library, from NRC, 32 Maintenance of Reference Materials at the White Plains Public 33 Library Related to the Review of the Entergy Nuclear Operations, Inc.,

34 License Renewal Application. (Accession No. ML071070518) 35 May 7, 2007 Letter to Ms. Resa Getman, Hendrick Hudson Free Library, from 36 NRC, Maintenance of Reference Materials at the Hendrick Hudson December 2008 C-1 Draft NUREG-1437, Supplement 38

Appendix C 1 Free Library Related to the Review of the Entergy Nuclear 2 Operations, Inc., License Renewal Application. (Accession 3 No. ML071080080) 4 May 7, 2007 Letter to Ms. Susan Thaler, The Field Library, from NRC, 5 Maintenance of Reference Materials at The Field Library Related to 6 the Review of the Entergy Nuclear Operations, Inc., License Renewal 7 Application. (Accession No. ML071080122) 8 July 25, 2007 Letter to Entergy from NRC transmitting Determination of 9 Acceptability and Sufficiency for Docketing, Proposed Review 10 Schedule, and Opportunity for a Hearing Regarding the Application 11 from Entergy Nuclear Operations, Inc. for Renewal of Operating 12 Licenses for Indian Point Nuclear Generating Unit Nos. 2 and 3."

13 (Accession No. ML071900365) 14 August 6, 2007 Letter to Entergy from NRC, Notice of Intent to Prepare an 15 Environmental Impact Statement and Conduct Scoping Process for 16 License Renewal for Indian Pont Nuclear Generating Unit Nos. 2 and 17 3, and forwarding Federal Register notice. (Accession 18 No. ML071840939) 19 August 9, 2007 Memorandum on Forthcoming Meeting to Discuss Environmental 20 Scoping Process for Indian Point Nuclear Generating Unit Nos. 2 and 21 3 License Renewal Application. (Accession No. ML072180296) 22 August 9, 2007 Letter to New York State Office of Parks, Recreation, and Historic 23 Preservation from NRC, Indian Point Nuclear Generating Unit Nos. 2 24 and 3 (Indian Point) License Renewal Application Review (SHPO 25 No. 06PR06720). (Accession No. ML072130333) 26 August 9, 2007 Letter to Advisory Council on Historic Preservation from NRC, Indian 27 Point Nuclear Generating Unit Nos. 2 and 3 License Renewal 28 Application Review. (Accession No. ML072130367) 29 August 16, 2007 Letter to Mr. David Stillwell, U.S. Fish and Wildlife Service (USFWS),

30 Request for List of Protected Species Within the Area Under 31 Evaluation for the Indian Point Nuclear Generating Unit Nos. 2 and 3 32 License Renewal Application Review. (Accession 33 No. ML072130211) 34 August 16, 2007 Letter to Mr. Peter Colosi, National Marine Fisheries Service (NMFS),

35 Request for List of Protected Species and Essential Fish Habitat 36 Within the Area Under Evaluation for the Indian Point Nuclear 37 Generating Unit Nos. 2 and 3 License Renewal Application Review.

38 (Accession No. ML072130388) 39 August 24, 2007 Letter to Mr. Andy Warrior, Absentee Shawnee Tribe of Oklahoma, Draft NUREG-1437, Supplement 38 C-2 December 2008

Appendix C 1 Request for Comments Concerning the Indian Point Nuclear 2 Generating Unit Nos. 2 and 3 License Renewal Application Review.

3 (Accession No. ML072250103) 4 August 24, 2007 Letter to The Honorable Maurice John, Cattaraugus Reservation, 5 Seneca Nation, Request for Comments Concerning the Indian Point 6 Nuclear Generating Unit Nos. 2 and 3 License Renewal Application 7 Review. (Accession No. ML072250171) 8 August 24, 2007 Letter to Mr. Clint Halftown, Cayuga Nation, Request for Comments 9 Concerning the Indian Point Nuclear Generating Unit Nos. 2 and 3 10 License Renewal Application Review. (Accession 11 No. ML072250394) 12 August 24, 2007 Letter to Ms. Nikki Owings-Crumm, Delaware Nation, Request for 13 Comments Concerning the Indian Point Nuclear Generating Unit 14 Nos. 2 and 3 License Renewal Application Review. (Accession 15 No. ML072250459) 16 August 24, 2007 Letter to The Honorable Jerry Douglas, Delaware Tribe of Indians, 17 Request for Comments Concerning the Indian Point Nuclear 18 Generating Unit Nos. 2 and 3 License Renewal Application Review.

19 (Accession No. ML072250488) 20 August 24, 2007 Letter to The Honorable C.W. Longlow, Echota Chickamauga 21 Cherokee Tribe of New Jersey, Request for Comments Concerning 22 the Indian Point Nuclear Generating Unit Nos. 2 and 3 License 23 Renewal Application Review. (Accession No. ML072250534) 24 August 24, 2007 Letter to The Honorable Michael Thomas, Mashantucket Pequot 25 Tribe, Request for Comments Concerning the Indian Point Nuclear 26 Generating Unit Nos. 2 and 3 License Renewal Application Review.

27 (Accession No. ML072260033) 28 August 24, 2007 Letter to Ms. Jeanne Schbotte, Mohegan Tribe, Request for 29 Comments Concerning the Indian Point Nuclear Generating Unit 30 Nos. 2 and 3 License Renewal Application Review. (Accession 31 No. ML072260047) 32 August 24, 2007 Letter to Mr. Ray Halbritter, Oneida Indian Nation of New York, 33 Request for Comments Concerning the Indian Point Nuclear 34 Generating Unit Nos. 2 and 3 License Renewal Application Review.

35 (Accession No. ML072260201) 36 August 24, 2007 Letter to Council of Chiefs, Onondaga Nation, Request for Comments 37 Concerning the Indian Point Nuclear Generating Unit Nos. 2 and 3 38 License Renewal Application Review. (Accession 39 No. ML072260245)

December 2008 C-3 Draft NUREG-1437, Supplement 38

Appendix C 1 August 24, 2007 Letter to The Honorable Dwaine Perry, Ramapough Lenape, Request 2 for Comments Concerning the Indian Point Nuclear Generating Unit 3 Nos. 2 and 3 License Renewal Application Review. (Accession 4 No. ML072260491) 5 August 24, 2007 Letter to Mr. Mike John, Seneca Nation of Indians, Request for 6 Comments Concerning the Indian Point Nuclear Generating Unit 7 Nos. 2 and 3 License Renewal Application Review. (Accession 8 No. ML072260519) 9 August 24, 2007 Letter to Mr. Randy Kind, Shinnecock Tribe, Request for Comments 10 Concerning the Indian Point Nuclear Generating Unit Nos. 2 and 3 11 License Renewal Application Review. (Accession 12 No. ML072270070) 13 August 24, 2007 Letter to The Honorable Harry B. Wallace, Unkechaug Nation, 14 Request for Comments Concerning the Indian Point Nuclear 15 Generating Unit Nos. 2 and 3 License Renewal Application Review.

16 (Accession No. ML072270113) 17 August 24, 2007 Letter to The Honorable Leo Henry, Tuscarora Nation, Request for 18 Comments Concerning the Indian Point Nuclear Generating Unit 19 Nos. 2 and 3 License Renewal Application Review. (Accession 20 No. ML072270548) 21 August 24, 2007 Letter to The Honorable Roger Hill, Tonawanda Band of Senecas, 22 Request for Comments Concerning the Indian Point Nuclear 23 Generating Unit Nos. 2 and 3 License Renewal Application Review.

24 (Accession No. ML072270590) 25 August 24, 2007 Letter to Ms. Sherry White, Stockbridge-Munsee Community Band of 26 Mohican Indians, Request for Comments Concerning the Indian Point 27 Nuclear Generating Unit Nos. 2 and 3 License Renewal Application 28 Review (Accession No. ML072270615) 29 August 24, 2007 Letter to Mr. Ken Jock, St. Regis Mohawk Tribal Council, Request for 30 Comments Concerning the Indian Point Nuclear Generating Unit 31 Nos. 2 and 3 License Renewal Application Review. (Accession 32 No. ML072280045) 33 August 29, 2007 Letter to NRC from USFWS, Indian Point Nuclear Generating Unit 34 Nos. 2 and 3 Protected Species Response. (Accession 35 No. ML0732307840) 36 October 4, 2007 Letter to NRC from NMFS regarding endangered species near Indian 37 Point Nuclear Generating Unit Nos. 2 and 3. (Accession No.

38 ML073340068)

Draft NUREG-1437, Supplement 38 C-4 December 2008

Appendix C 1 October 5, 2007 Letter to NRC from New York State Department of Environmental 2 Conservation (NYSDEC), Indian Point Units 2 and 3 Relicensing 3 Extension Request for Scoping Comments on SEIS. (Accession 4 No. ML072820746) 5 October 10, 2007 Letter to NRC from NYSDEC, Indian Point Units 2 and 3 Relicensing 6 Extension Request for Scoping Comments on SEIS. (Accession 7 No. ML072900470) 8 October 11, 2007 Letter to NYSDEC from NRC regarding extension request for scoping 9 comments. (Accession No. ML072840275) 10 October 24, 2007 Meeting Summary of Public Environmental Scoping Meetings 11 Related to the Review of the Indian Point Nuclear Generating Unit 12 Nos. 2 and 3, License Renewal Application (TAC nos. MD5411 and 13 MD5412). (Accession No. ML072851079) 14 November 8, 2007 Summary of Site Audit Related to the Review of the License Renewal 15 Application for Indian Point Nuclear Generating Unit Nos. 2 and 3.

16 (Accession No. ML073050267) 17 November 14, 2007 Letter to NRC from Entergy, Supplement to License Renewal 18 Application (LRA) Environmental Report References. (Accession 19 No. ML073330590) 20 November 27, 2007 Letter to NYSDEC from NRC, Request for List of State Protected 21 Species Within the Area Under Evaluation for the Indian Point Nuclear 22 Generating Unit Nos. 2 and 3 License Renewal Application Review.

23 (Accession No. ML073190161) 24 December 5, 2007 Letter to Entergy from NRC, Request for Additional Information 25 Regarding Environmental Review for Indian Point Nuclear Generating 26 Unit Nos. 2 and 3 License Renewal (TAC nos. MD5411 and 27 MD5412). (Accession No. ML073330931) 28 December 7, 2007 Letter to Entergy from NRC, Request for Additional Information 29 Regarding Severe Accident Mitigation Alternatives for Indian Point 30 Nuclear Generating Unit Nos. 2 and 3 License Renewal (TAC 31 nos. MD5411 and MD5412). (Accession No. ML073110447) 32 December 20, 2007 Letter to NRC from Entergy, Supplement to License Renewal 33 Application (LRA)Environmental Report References. (Accession 34 No. ML080080205) 35 December 28, 2007 Letter to NRC from NYSDEC regarding rare or State-listed animals 36 and plants, significant natural communities, and other habitats on or in 37 the vicinity of the Indian Point site. (Accession No. ML080070085, 38 withheld from public disclosure per request by NYSDEC)

December 2008 C-5 Draft NUREG-1437, Supplement 38

Appendix C 1 January 4, 2008 Letter to NRC from Entergy, Reply to Request for Additional 2 Information Regarding Environmental Review for License Renewal 3 Application. (Accession No. ML080110372) 4 January 10, 2008 Letter to NRC from Entergy, Supplemental Response to Request for 5 Additional Information Regarding Environmental Review for License 6 Renewal Application. (Accession No. ML080220165) 7 January 30, 2008 Letter to NRC from Entergy, Supplemental Response to Request for 8 Additional Information Regarding Environmental Review for License 9 Renewal Application. (Accession No. ML080380096) 10 February 20, 2008 Letter to NRC from Entergy, Document Request for Additional 11 Information Regarding Environmental Review for License Renewal 12 ApplicationElectronic Copy of Impingement DataTables 4-1 and 13 4-2 of the 1990 Annual Report (EA 1991). (Accession 14 No. ML080580408) 15 February 28, 2008 Letter to NRC from NMFS, Essential Fish Habitat Information 16 Request for Docket Nos. 50-247 and 50-286; Indian Point Nuclear 17 Generating Unit Nos. 2 and 3 License Renewal; at the Village of 18 Buchanan, Town of Cortlandt, Westchester County, NY. (Accession 19 No. ML080990403) 20 March 7, 2008 Letter to NRC from Entergy, Document Request for Additional 21 Information Regarding Environmental Review for License Renewal 22 ApplicationHudson River Fisheries Program Data (Year Class 23 Report). (Accession No. ML080770457) 24 April 9, 2008 Letter to Entergy from NRC, Request for Additional Information 25 Regarding the Review of the License Renewal Application for Indian 26 Point Nuclear Generating Unit Nos. 2 and 3 (TAC nos. MD5411 and 27 MD5412). (Accession No. ML080880104) 28 April 14, 2008 Letter to Entergy from NRC, Request for Additional Information 29 Regarding the Review of the License Renewal Application for Indian 30 Point Nuclear Generating Unit Nos. 2 and 3 (TAC nos. MD5411 and 31 MD5412). (Accession No. ML080940408) 32 April 23, 2008 Letter to Entergy from NRC, Revision of Schedule for the Review of 33 the Indian Point Nuclear Generating Unit Nos. 2 and 3 License 34 Renewal Application (TAC nos. MD5411 and MD5412). (Accession 35 No. ML081000441) 36 April 23, 2008 Letter to NRC from Entergy, Reply to Document Request for 37 Additional Information Regarding Site Audit Review of License 38 Renewal Application for Indian Point Nuclear Generating Unit Nos. 2 39 and 3. (Accession No. ML081230243)

Draft NUREG-1437, Supplement 38 C-6 December 2008

Appendix C 1 May 14, 2008 Letter to NRC from Entergy, Reply to Request for Additional 2 Information Regarding License Renewal ApplicationRefurbishment.

3 (Accession No. ML081440052) 4 May 22, 2008 Letter to NRC from Entergy, Supplemental Reply to Request for 5 Additional Information Regarding License Renewal Application 6 Severe Accident Mitigation Alternatives Analysis. (Accession 7 No. ML081490336)

December 2008 C-7 Draft NUREG-1437, Supplement 38

Appendix D Organizations Contacted

1 Appendix D 2 Organizations Contacted 3 The U.S. Nuclear Regulatory Commission contacted the following Federal, State, regional, and 4 local agencies, and Native American Tribes, during its independent review of the environmental 5 impacts related to the application by Entergy Nuclear Operations, Inc., for renewal of the 6 operating licenses for Indian Point Nuclear Generating Unit Nos. 2 and 3:

7 Absentee Shawnee Tribe of Oklahoma 8 Cattaraugus Reservation, Seneca Nation 9 Cayuga Nation 10 Delaware Nation 11 Delaware Tribe of Indians 12 Echota Chickamauga Cherokee Tribe of New Jersey 13 National Marine Fisheries Service 14 New York State Department of Environmental Conservation 15 New York State Office of Parks, Recreation and Historic Preservation, Historic Preservation 16 Field Services Bureau 17 Oneida Indian Nation of New York 18 Onondaga Nation 19 Ramapough Lenape, Ramapough Tribal Office 20 Seneca Nation of Indians 21 Seneca Nation Tribal Historic Preservation 22 Shinnecock Tribe 23 St. Regis Mohawk Tribal Council 24 Stockbridge-Munsee Community Band of Mohican Indians, Tribal Historic Preservation Office 25 The Mashantucket Pequot Tribe (CT) 26 The Mohegan Tribe (CT) 27 Tonawanda Band of Senecas 28 Tuscarora Nation 29 Unkechaug Nation 30 U.S. Environmental Protection Agency, Region 2 31 U.S. Fish and Wildlife Service December 2008 D-1 Draft NUREG-1437, Supplement 38

Appendix E Indian Point Nuclear Generating Unit Numbers 2 and 3 Compliance Status and Consultation Correspondence

1 Appendix E 2 Indian Point Nuclear Generating Unit 3 Nos. 2 and 3 4 Compliance Status 5 and Consultation Correspondence 6 Consultation correspondence related to the evaluation of the application for renewal of the 7 operating licenses for Indian Point Nuclear Generating Units 2 and 3 (IP2 and IP3, respectively) 8 is identified in Table E-1. Copies of the correspondence are included in this appendix.

9 The licenses, permits, consultations, and other approvals obtained from Federal, State, 10 regional, and local authorities for SSES are listed in Table E-2.

11 Table E-1. Consultation Correspondence Source Recipient Date of Letter U.S. Nuclear Regulatory State Historical Preservation Office August 9, 2007 Commission (R. Franovich) (Office of Parks, Recreation, and Historic Preservation, R. L. Pierpont)

U.S. Nuclear Regulatory Advisory Council on Historic Preservation August 9, 2007 Commission (R. Franovich) (D. Klima)

U.S. Nuclear Regulatory U.S. Fish and Wildlife Service (D. August 16, 2007 Commission (R. Franovich) Stillwell)

U.S. Nuclear Regulatory National Marine Fisheries Commission August 16, 2007 Commission (R. Franovich) (P. Colosi)

U.S. Nuclear Regulatory Absentee Shawnee Tribe of Oklahoma August 24, 2007 Commission (R. Franovich) (A. Warrior)

U.S. Nuclear Regulatory Cattaraugus Reservation, Seneca Nation August 24, 2007 Commission (R. Franovich) (The Hon. M. John)

U.S. Nuclear Regulatory Cayuga Nation August 24, 2007 Commission (R. Franovich) (C. Halftown)

U.S. Nuclear Regulatory Delaware Nation (N. Owings-Crumm) August 24, 2007 Commission (R. Franovich)

U.S. Nuclear Regulatory Delaware Tribe of Indian (The Hon. J. August 24, 2007 Commission (R. Franovich) Douglas)

December 2008 E-1 Draft NUREG-1437, Supplement 38

Appendix E Source Recipient Date of Letter U.S. Nuclear Regulatory Echota Chickamauga Cherokee Tribe of August 24, 2007 Commission (R. Franovich) New Jersey (The Hon. C.W. Longlow)

U.S. Nuclear Regulatory Mashantucket Pequot Tribe (The Hon. M. August 24, 2007 Commission (R. Franovich) Thomas)

U.S. Nuclear Regulatory Mohegan Tribe (J. Schbotte) August 24, 2007 Commission (R. Franovich)

U.S. Nuclear Regulatory Oneida Indian Nation of New York (R. August 24, 2007 Commission (R. Franovich) Halbritter)

U.S. Nuclear Regulatory Onondaga Nation (Council of Chiefs) August 24, 2007 Commission (R. Franovich)

U.S. Nuclear Regulatory Ramapough Lenape (The Hon. D. Perry) August 24, 2007 Commission (R. Franovich)

U.S. Nuclear Regulatory Seneca Nation of Indians (M. John) August 24, 2007 Commission (R. Franovich)

U.S. Nuclear Regulatory Shinnecock Tribe (R. Kind) August 24, 2007 Commission (R. Franovich)

U.S. Nuclear Regulatory Unkechaug Nation (The Hon. H. B. August 24, 2007 Commission (R. Franovich) Wallace)

U.S. Nuclear Regulatory Tuscarora Nation (The Hon. L. Henry) August 24, 2007 Commission (R. Franovich)

U.S. Nuclear Regulatory Tonawanda Band of Senecas (The Hon. August 24, 2007 Commission (R. Franovich) R. Hill)

U.S. Nuclear Regulatory Stockbridge-Munsee Community of August 24, 2007 Commission (R. Franovich) Mohican Indians (S. White)

U.S. Nuclear Regulatory St. Regis Mohawk (K. Jock) August 24, 2007 Commission (R. Franovich)

U.S. Nuclear Regulatory New York State Dept. of Environmental November 11, 2007 Commission (R. Franovich) Conservation (J. Pietrusiak)

U.S. Fish and Wildlife Service (M. U.S. Nuclear Regulatory Commission (R. August 29, 2007 VanDonsell and R. Niver) Franovich)

Delaware Nation (D. Nieto) U.S. Nuclear Regulatory Commission September 5, 2007 National Marine Fisheries Service U.S. Nuclear Regulatory Commission (R. October 4, 2007 (M. A. Colligan) Franovich)

Draft NUREG-1437, Supplement 38 E-2 December 2008

Appendix E Source Recipient Date of Letter New York State Department of U.S. Nuclear Regulatory Commission (R. December 28, 2007 Environmental Conservation (T. Franovich)

Seoane)

National Marine Fisheries Service U.S. Nuclear Regulatory Commission (R. February 28, 2008 (P. Colosi) Franovich) 1 Table E-2. Federal, State, Local, and Regional Licenses, Permits, Consultations, and Other 2 Approvals for the Indian Point site Issue Expiration Agency Authority Description Number Date Date Remarks NRC 10 CFR Part 50 Possession License, DPR-5 09/28/13 Authorizes Indian Point Unit 1 SAFSTOR for Unit 1 NRC 10 CFR Part 50 Operating license, IP2 DPR-26 09/28/13 Authorizes operation of IP2 NRC 10 CFR Part 50 Operating license, IP3 DPR-64 12/10/15 Authorizes operation of IP3 DOT 49 CFR 107 IP2 Hazardous Materials 062706552061 06/30/09 Radioactive Certificate of 0Q and Registration hazardous materials shipments DOT 49 CFR 107 IP3 Hazardous Materials 062706552069 06/30/09 Radioactive Certificate of 0Q and Registration hazardous materials shipments EPA 40 CFR Part 264 IP2 Hazardous Solid NYD991304411 10/14/02 Accumulation Waste Amendment and temporary Permit onsite storage of mixed waste for >90 days EPA 40 CFR Part 264 IP3 Hazardous Solid NYD085503746 10/17/01 Accumulation Waste Amendment and temporary Permit onsite storage of mixed waste for >90 days December 2008 E-3 Draft NUREG-1437, Supplement 38

Appendix E Issue Expiration Agency Authority Description Number Date Date Remarks NYSDE 6 NYCRR Part 325 IP2 Pesticide Application 12696 04/30/09 Pesticide C Business Registration application NYSDE 6 NYCRR Part 325 IP3 Pesticide Application 13163 04/30/09 Pesticide C Business Registration application NYSDE 6 NYCRR Parts 704 IP1, 2, and 3 SPDES NY 000 4472 10/01/92 Discharge of C and 750 Permit wastewaters and stormwaters to waters of the State NYSDE 6 NYCRR Part 704 Simulator Transformer NY 025 0414 03/01/08 Discharge of C Vault SPDES Permit wastewaters to waters of the State NYSDE 6 NYCRR Part 704 Tank Farm SPDES NY 025 1135 02/10/10 Discharge of C Permit wastewaters to waters of the State NYSDE 6 NYCRR Part 704 Buchanan Gas Turbine NY 022 4826 03/01/08 Discharge of C SPDES Permit wastewaters to waters of the State NYSDE 6 NYCRR Part 750 ISFSI Stormwater NYR 10H166 NA Stormwater C SPDES General Permit discharge for Construction during Activities construction of dry cask spent fuel storage NYSDE 6 NYCRR Parts 200 IP2 Air Permit 3-5522- NA Operation of C and 201 00011/00026 air emission sources (boilers, turbines and generators)

NYSDE 6 NYCRR Parts 200 IP3 Air Permit 3-5522- NA Operation of C and 201 00105/00009 air emission sources (boilers, turbines and generators)

NYSDE 6 NYCRR Part 596 IP2 Hazardous 3-000107 09/04/07 Onsite bulk C Substance Bulk Storage storage of Registration Certificate hazardous substances NYSDE 6 NYCRR Part 596 IP3 Hazardous 3-000071 08/16/08 Onsite bulk C Substance Bulk Storage storage of Registration Certificate hazardous substances Draft NUREG-1437, Supplement 38 E-4 December 2008

Appendix E Issue Expiration Agency Authority Description Number Date Date Remarks NYSDE 6 NYCRR Part 610 IP2 Major Oil Storage 3-2140 -- Onsite bulk C Facility storage of

>400,000 gallons of petroleum products NYSDE 6 NYCRR Part 372 IP2 Hazardous Waste NYD000765073 NA Hazardous C Generator Identification waste generation NYSDE 6 NYCRR Part 372 IP3 Hazardous Waste NYD000765073 NA Hazardous C Generator Identification waste generation NYSDE 6 NYCRR Part 373 IP2 Hazardous Waste NYD991304411 02/28/07 Accumulation C Part 373 Permit and temporary onsite storage of mixed waste for >90 days WCDO Chapter 873, Article IP2 Gas Turbine 1 Air #00021 NA 12/31/06 Operation of H XIII, Section Permit an air 873.1306.1 of the contamination Laws of Westchester source County WCDO Chapter 873, Article IP2 Gas Turbine 2 Air #00022 NA 12/31/06 Operation of H XIII, Section Permit an air 873.1306.1 of the contamination Laws of Westchester source County WCDO Chapter 873, Article IP2 Gas Turbine 3 Air #00023 NA 12/31/06 Operation of H XIII, Section Permit an air 873.1306.1 of the contamination Laws of Westchester source County WCDO Chapter 873, Article IP2 Boiler Permit 52-4493 NA Operation of H XIII, Section an air 873.1306.1 of the contamination Laws of Westchester source County WCDO Chapter 873, Article IP2 Vapor Extractor Air 52-5682 12/31/06 Operation of H XIII, Section Permit an air 873.1306.1 of the contamination Laws of Westchester source County WCDO Chapter 873, Article IP3 Boiler Permit 52-6497 NA Operation of H XIII, Section an air 873.1306.1 of the contamination Laws of Westchester source County December 2008 E-5 Draft NUREG-1437, Supplement 38

Appendix E Issue Expiration Agency Authority Description Number Date Date Remarks WCDO Chapter 873, Article IP3 Training Center 52-6498 NA Operation of H XIII, Section Boiler Permit an air 873.1306.1 of the contamination Laws of Westchester source County WCDO Chapter 873, Article IP3 Vapor Extractor Air -- -- Operation of H XIII, Section Permit an air 873.1306.1 of the contamination Laws of Westchester source County WCDO Westchester County IP3 Petroleum Bulk 3-166367 09/10/07 Onsite Bulk H Sanitary Code, Article Storage Registration Storage of XXV Certificate Petroleum Products SCDHE Act No. 429 of 1980, IP2 South Carolina 0019-31-07 12/31/07 Transportation C South Carolina Radioactive Waste of radioactive Radioactive Waste Transport Permit waste into the Transportation and State of South Disposal Act Carolina.

SCDHE Act No. 429 of 1980, IP3 South Carolina 0072-31-07 12/31/07 Transportation C South Carolina Radioactive Waste of radioactive Radioactive Waste Transport Permit waste into the Transportation and State of South Disposal Act Carolina.

TDEC Tennessee IP2 Tennessee T-NY-010-L07 12/31/07 Shipment of Department of Radioactive Waste- radioactive Environment and License-for-Delivery material into Conservation Tennessee to Regulations a disposal/proce ssing facility.

TDEC Tennessee IP3 Tennessee T-NY-005-L07 12/31/07 Shipment of Department of Radioactive Waste- radioactive Environment and License-for-Delivery material into Conservation Tennessee to Regulations a disposal/proce ssing facility.

Draft NUREG-1437, Supplement 38 E-6 December 2008

Appendix E Issue Expiration Agency Authority Description Number Date Date Remarks (a)

Application pending.

CFR = Code of Federal Regulations DOT = U.S. Department of Transportation NA = not applicable NRC = U.S. Nuclear Regulatory Commission NYCRR = New York Codes, Rules, and Regulations NYSDEC = New York State Department of Environmental Conservation SCDHEC = South Carolina Department of Health and Environmental Control SPDES = State Pollutant Discharge Elimination System TDEC = Tennessee Department of Environment and Conservation USC = United States Code WCDOH = Westchester County Department of Health December 2008 E-7 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-8 December 2008

Appendix E December 2008 E-9 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-10 December 2008

Appendix E December 2008 E-11 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-12 December 2008

Appendix E December 2008 E-13 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-14 December 2008

Appendix E December 2008 E-15 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-16 December 2008

Appendix E December 2008 E-17 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-18 December 2008

Appendix E December 2008 E-19 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-20 December 2008

Appendix E December 2008 E-21 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-22 December 2008

Appendix E December 2008 E-23 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-24 December 2008

Appendix E December 2008 E-25 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-26 December 2008

Appendix E December 2008 E-27 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-28 December 2008

Appendix E December 2008 E-29 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-30 December 2008

Appendix E December 2008 E-31 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-32 December 2008

Appendix E December 2008 E-33 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-34 December 2008

Appendix E December 2008 E-35 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-36 December 2008

Appendix E December 2008 E-37 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-38 December 2008

Appendix E December 2008 E-39 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-40 December 2008

Appendix E December 2008 E-41 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-42 December 2008

Appendix E December 2008 E-43 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-44 December 2008

Appendix E December 2008 E-45 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-46 December 2008

Appendix E December 2008 E-47 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-48 December 2008

Appendix E December 2008 E-49 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-50 December 2008

Appendix E December 2008 E-51 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-52 December 2008

Appendix E December 2008 E-53 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-54 December 2008

Appendix E December 2008 E-55 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-56 December 2008

Appendix E December 2008 E-57 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-58 December 2008

Appendix E December 2008 E-59 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-60 December 2008

Appendix E December 2008 E-61 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-62 December 2008

Appendix E December 2008 E-63 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-64 December 2008

Appendix E December 2008 E-65 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-66 December 2008

Appendix E December 2008 E-67 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-68 December 2008

Appendix E December 2008 E-69 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-70 December 2008

Appendix E December 2008 E-71 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-72 December 2008

Appendix E December 2008 E-73 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-74 December 2008

Appendix E December 2008 E-75 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-76 December 2008

Appendix E December 2008 E-77 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-78 December 2008

Appendix E December 2008 E-79 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-80 December 2008

Appendix E December 2008 E-81 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-82 December 2008

Appendix E Enclosure (report containing a list of rare or State-listed plants and animals) withheld by NRC as sensitive information per New York Natural Heritage Program request.

December 2008 E-83 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-84 December 2008

Appendix E December 2008 E-85 Draft NUREG-1437, Supplement 38

Appendix E Draft NUREG-1437, Supplement 38 E-86 December 2008

Appendix E 1 Biological Assessment 2

3 Indian Point Nuclear Generating Plant Unit Nos. 2 and 3 4 License Renewal 5

6 December 2008 7 Docket Nos. 50-247 and 50-286 8

9 U.S. Nuclear Regulatory Commission 10 Rockville, Maryland December 2008 E-87 Draft NUREG-1437, Supplement 38

Appendix E 1 Biological Assessment of the Potential Effects on Federally Listed 2 Endangered or Threatened Species from the Proposed Renewal of 3 Indian Point Nuclear Generating Plant, Unit Nos. 2 and 3 4 1.1 Introduction and Purpose 5 The U.S. Nuclear Regulatory Commission (NRC) prepared this biological assessment (BA) to 6 support the draft supplemental environmental impact statement (SEIS) for the renewal of the 7 operating licenses for Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3), located 8 on the shore of the Hudson River in the Village of Buchanan, in upper Westchester County, NY.

9 The current 40-year licenses expire in 2013 (IP2) and 2015 (IP3). The proposed license 10 renewal for which this BA has been prepared would extend the operating licenses to 2033 and 11 2035 for IP2 and IP3, respectively.

12 The NRC is required to prepare the draft SEIS as part of its review of a license renewal 13 application. The draft SEIS supplements NUREG-1437, Volumes 1 and 2, Generic 14 Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), (NRC 1996, 15 1999)c for the license renewal of commercial nuclear power plants. The draft SEIS covers 16 specific issues, such as the potential impact on endangered and threatened species, that are of 17 concern at IP2 and IP3 and that could not be addressed on a generic basis in the GEIS.

18 Pursuant to Section 7 of the Endangered Species Act of 1973 (ESA), as amended, the NRC 19 staff requested, in a letter dated August 16, 2007 (NRC 2007), that the National Marine 20 Fisheries Service (NMFS) provide information on federally listed endangered or threatened 21 species, as well as on proposed or candidate species, and on any designated critical habitats 22 that may occur in the vicinity of IP2 and IP3. In its response, dated October 4, 2007 23 (NMFS 2007), NMFS expressed concern that the continued operation of IP2 and IP3 could have 24 an impact on the shortnose sturgeon (Acipenser brevirostrum), an endangered species that 25 occurs in the Hudson River. NMFS also noted that a related species that also occurs in the 26 Hudson River, the Atlantic sturgeon (Acipenser oxyrinchus), is a candidate species for which 27 NMFS has initiated a status review to determine if it should be listed as threatened or 28 endangered.

29 Under Section 7, the NRC is responsible for providing information on the potential impact that 30 the continued operation of IP2 and IP3 could have on the federally listed species, the shortnose 31 sturgeon. In addition, the NRC has prepared information regarding the potential impact on 32 important species, including the Atlantic sturgeon; this information can be found in Chapters 2 33 and 4 of the draft SEIS.

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

Draft NUREG-1437, Supplement 38 E-88 December 2008

Appendix E 1 2.0 Proposed Action 2 The current proposed action considered in the SEIS is the renewal of the operating licenses for 3 IP2 and IP3 for an additional 20-year term beyond the period of the existing licenses. The 4 applicant has indicated that it may replace reactor vessel heads and control rod drive 5 mechanisms during the period of extended operation. (For a description of these activities and 6 potential environmental effects, see Chapter 3 of the draft SEIS.) If the NRC grants the 7 operating license renewals, the applicant can operate and maintain the nuclear units, the 8 cooling systems, and the transmission lines and corridors as they are now until 2033 and 2035.

9 3.0 Site Description 10 IP2 and IP3 are located on a 239-acre (97-hectare) site on the eastern bank of the Hudson 11 River in the Village of Buchanan, Westchester County, NY, about 24 miles (mi) (39 kilometers 12 [km]) north of New York City, NY (Figures 1 and 2). Privately owned land bounds the north, 13 south, and east sides of the property (Figure 3). The area is generally described as an eastern 14 deciduous forest, dominated by oak (Quercus), maple (Acer), and beech (Fagus) species. The 15 lower Hudson River is a tidal estuary, flowing 152 miles (244 km) from the Federal Dam at Troy, 16 NY, to the Battery in New York City. IP2 and IP3 are located at River Mile (RM) 43 (RKM 69),

17 where the average depth is 40 feet (ft) (12 meters [m]), and the average width of the river is 18 4500 ft (1370 m). The Hudson River is tidal all the way to the Federal Dam, and the salinity 19 zone in the vicinity of the facility is described as oligohaline (low salinity, ranging from 0.5 to 20 5 parts per thousand (ppt)), with the salinity changing with the level of freshwater flow. Water 21 temperature ranges from a winter minimum of 34 degrees F (1 degree Celsius (C)) to a summer 22 maximum of 77 degrees F (25 degrees C) (Entergy 2007a).

23 The mid-Hudson River provides the cooling water for four other power plants: Roseton 24 Generating Station, Danskammer Point Generating Station, Bowline Point Generating Station, 25 and Lovett Generating Station; all four stations are fossil-fueled steam electric stations, located 26 on the western shore of the river, and all use once-through cooling. Roseton consists of two 27 units and is located at RM 66 (RKM 106), 23 mi (37 km) north of IP2 and IP3. Just 0.5 mi 28 (0.9 km) north of Roseton is Danskammer, with four units. Bowline lies about 5 mi (8 km) south 29 of IP2 and IP3 and consists of two units (Entergy 2007a; CHGEC 1999). Lovett, almost directly 30 across the river from IP2 and IP3, is no longer operating.

December 2008 E-89 Draft NUREG-1437, Supplement 38

Appendix E 1 Source: Entergy 2007a 2 Figure 1. Location of IP2 and IP3, 50-mile (80-km) radius Draft NUREG-1437, Supplement 38 E-90 December 2008

Appendix E 1

2 Source: Entergy 2007a 3 Figure 2. Location of IP2 and IP3, 6-mile (10-km) radius December 2008 E-91 Draft NUREG-1437, Supplement 38

Appendix E 1 Source: Entergy 2007a 2 Figure 3. IP2 and IP3 property boundaries and environs Draft NUREG-1437, Supplement 38 E-92 December 2008

Appendix E 1 3.1.1 Description of Plants and Cooling Systems 2 IP2 and IP3 are pressurized-water reactors with turbine generators that produce a net output of 3 6432 megawatts-thermal and approximately 2158 megawatts-electrical. Both IP2 and IP3 use 4 water from the Hudson River for their once-through condensers and auxiliary cooling systems.

5 Each unit has seven intake bays (Figure 4), into which the river water flows, passing under the 6 floating debris skimmer wall and through Ristroph traveling screens (Figure 5). IP2 has six 7 dual-speed circulating water pumps that can each pump 140,000 gallons per minute (gpm) 8 (8.83 cubic meters per second [m3/s]) at full speed and 84,000 gpm (5.30 m3/s) at reduced 9 speed; at full speed, the approach velocity is approximately 1 foot per second (fps) (0.30 meters 10 per second [m/s]) and at reduced speed, the approach velocity is 0.6 fps (0.2 m/s). IP3 also has 11 six dual-speed circulating water pumps. The full speed flow rate of each of these pumps is 12 140,000 gpm (8.83 m3/s), with a 1 fps (0.30 m/s) approach velocity; the reduced speed is 13 64,000 gpm (4.04 m3/s), with a 0.6 fps (0.2 m/s) approach velocity (Entergy 2007a).

14 Source: Entergy 2007a 15 Figure 4. IP2 intake structure (left) and IP3 intake structure (right) 16 The traveling screens employed by IP2 and IP3 are modified vertical Ristroph-type traveling 17 screens installed in 1990 and 1991 at IP3 and IP2, respectively. The screens were designed in 18 concert with the Hudson River Fishermens Association, with screen basket lip troughs to retain 19 water and minimize vortex stress (CHGEC 1999). Studies indicated that, assuming the screens 20 continued to operate as they had during laboratory and field testing, the screens were the 21 screening device most likely to impose the least mortalities in the rescue of entrapped fish by December 2008 E-93 Draft NUREG-1437, Supplement 38

Appendix E 1 mechanical means (Fletcher 1990). The same study concluded that refinements to the screens 2 would be unlikely to greatly reduce fish kills.

3 4

5 Source: Entergy 2007a 6

7 Figure 5. IP2 intake system (left) and IP3 intake system (right) 8 There are two spray-wash systemsthe high-pressure spray wash removes debris from the 9 front of the traveling screen mechanism; the low-pressure spray washes fish from the rear of the 10 mechanism into a fish sluice system to return them to the river. A 0.25 x 0.5-inch (in.)

11 (0.635 x 1.27-centimeter [cm]) clear opening slot mesh on the screen basket panels was 12 included to minimize abrasion as the fish were washed into the collection sluice. The sluice 13 system is a 12-in.-diameter (30.5-cm-diameter) pipe that discharges fish into the river at a 14 depth of 35 ft (10.7 m), 200 ft (61 m) from shore (CHGEC 1999).

15 4.0 Status Review of Shortnose Sturgeon 16 4.1 Life History 17 The shortnose sturgeon (Acipenser brevirostrum, family Acipenseridae) is amphidromous, with 18 a range extending from the St. Johns River, FL, to the St. John River, Canada. Unlike 19 anadromous species, shortnose sturgeons spend the majority of their lives in freshwater and 20 move into salt water periodically without relation to spawning (Collette and Klein-21 MacPhee, 2002). From colonial times, shortnose sturgeons have rarely been the target of 22 commercial fisheries but have frequently been taken as incidental bycatch in Atlantic sturgeon 23 and shad gillnet fisheries (NEFSC 2006; Dadswell et al. 1984). The shortnose sturgeon was 24 listed on March 11, 1967, as endangered under the ESA. In 1998, NMFS completed a recovery 25 plan for the shortnose sturgeon (NMFS 1998).

Draft NUREG-1437, Supplement 38 E-94 December 2008

Appendix E 1 Shortnose sturgeons can grow up to 143 cm (56 in.) in total length and can weigh up to 2 23 kilograms (kg) (51 pounds [lb]). Females are known to live up to 67 years, while males 3 typically do not live beyond 30 years. As young adults, the sex ratio is 1:1; however, among fish 4 larger than 90 cm (35 in.), measured from nose to the fork of the tail, the ratio of females to 5 males increases to 4:1. Throughout the range of the shortnose sturgeon, males and females 6 mature at 45 to 55 cm (18 to 22 in.) fork length, but the age at which this length is achieved 7 varies by geography. At the southern extent of the sturgeons range, in Florida, males reach 8 maturity at age 2, and females reach maturity at 6 years or younger; in Canada, males can 9 reach maturity as late as 11 years, and females, 13 years. In 1 to 2 years after reaching 10 maturity, males begin to spawn at 2-year intervals, while females may not spawn for the first 11 time until 5 years after maturing and, thereafter, spawn at 3- to 5-year intervals 12 (Dadswell et al. 1984).

13 Shortnose sturgeons migrate into freshwater to spawn during late winter or early summer. Eggs 14 sink and adhere to the hard surfaces on the river bottom, hatching after 4 to 6 days. Larvae 15 consume their yolk sac and begin feeding in 8 to 12 days, as they migrate downstream away 16 from the spawning site, remaining close to the river bottom (Kynard 1997; Collette and Klein-17 MacPhee 2002). The juveniles, which feed on benthic insects and crustaceans, do not migrate 18 to the estuaries until the following winter, where they remain for 3 to 5 years. As adults, they 19 migrate to the near-shore marine environment, where their diet consists of mollusks and large 20 crustaceans (Dadswell 1984).

21 4.2 Status of Shortnose Sturgeon in Hudson River 22 Shortnose sturgeons inhabit the lower Hudson; the Federal Dam creates a physical barrier 23 preventing the species from swimming farther north. They are found dispersed throughout the 24 river-estuary from late spring to early fall and then congregate to winter near Sturgeon Point 25 (RM 86). Spawning occurs in the spring, just downstream of the Federal Dam at Troy, between 26 RM 118 and 148 (between Coxsackie and Troy) (Bain et al. 2007; NMFS 2000). According to 27 the NMFS environmental assessment (2000) for a permit for the incidental take of shortnose 28 sturgeons at the nearby power plants, Roseton and Danskammer, larvae are typically found 29 upstream of the intakes of all five power plants along the mid-Hudson.

30 The Hudson River population of the shortnose sturgeon was estimated to be approximately 31 13,000 adults in 1979-1980. Based on population studies done in the mid-1990s, the 32 population has apparently increased 400 percent since then, up to almost 57,000 adult fish.

33 Additional data suggest that the total population of the shortnose sturgeon in the Hudson River 34 is approximately 61,000, including juveniles and nonspawning adults (Bain et al. 2007). The 35 population growth has been ascribed to several strong year-classes, as well as 2 decades of 36 sustained annual recruitment (Woodland and Secor 2007). Bain et al. (2007) maintains that the 37 annual trawl surveys conducted by the electric utilities (CHGEC 1999) show an increase in 38 abundance between the mid-1980s and mid-1990s, supporting the finding that the Hudson 39 River population has increased. Staff assessed the population trend for yearling and older 40 shortnose sturgeons in the fall juvenile survey data provided by the applicant and found an 41 overall increase in the catch-per-unit-effort from 1975 to 2005.

December 2008 E-95 Draft NUREG-1437, Supplement 38

Appendix E 1 4.3 Impact Assessment of Indian Point on the Shortnose Sturgeon 2 Population 3 4.3.1 Entrainment 4 The southern extent of the shortnose sturgeon spawning area in the Hudson River is 5 approximately RM 118 (RKM 190), about 75 RM (121 RKM) upstream of the intake of IP2 and 6 IP3 (NMFS 2000). The eggs of shortnose sturgeons are demersal, sinking and adhering to the 7 bottom of the river, and, upon hatching, the larvae in both yolk-sac and post-yolk-sac stages 8 remain on the bottom of the river, primarily upstream of RM 110 (RKM 177) (NMFS 2000).

9 Shortnose sturgeon larvae grow rapidly, and, after a few weeks, they are too large to be 10 entrained by the cooling intake (Dadswell 1979). Because the egg and larval life stages of the 11 shortnose sturgeon (the life stages susceptible to entrainment) are not found near the intake for 12 IP2 and IP3, the probability of their entrainment at IP2 and IP3 is low.

13 IP2 and IP3 monitored entrainment from 1972 through 1987. Entrainment monitoring became 14 more intensive at Indian Point from 1981 through 1987, and sampling was conducted for nearly 15 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 4 to 7 days per week, during the spawning season in the spring 16 (NMFS 2000). Entrainment monitoring reports list no shortnose sturgeon eggs or larvae at IP2 17 and IP3. NMFS (2000) lists only eight sturgeon larvae collected at any of the mid-Hudson 18 power plants (all eight were collected at Danskammer, and four of the eight may have been 19 Atlantic sturgeons). Entrainment sampling data supplied by the applicant (Entergy 2007b) 20 include large numbers of larvae for which the species could not be determined, and, therefore, 21 one cannot conclude that there was no entrainment of shortnose sturgeons at IP2 and IP3.

22 Entergy Nuclear Operations, Inc. (Entergy) currently conducts no monitoring program to record 23 entrainment at IP2 and IP3, and any entrainable life stages of the shortnose sturgeon taken in 24 recent years would go unrecorded.

25 Based on the life history of the shortnose sturgeon, the location of spawning grounds within the 26 Hudson River, and the patterns of movement for eggs and larvae, the number of shortnose 27 sturgeons in early life stages entrained at IP2 and IP3 is probably low or zero. The available 28 data from past entrainment monitoring do not indicate that entrainment was occurring.

29 Therefore, the staff concludes that the continued operation of Indian Point for an additional 30 20 years is not likely to adversely affect the population of shortnose sturgeons in the Hudson 31 River through entrainment.

32 4.3.2 Impingement 33 IP2 and IP3 monitored impingement daily until 1981, reduced collections to a randomly selected 34 schedule of 110 days per year until 1991, and then ceased monitoring in 1991 with the 35 installation of the modified Ristroph traveling screens. As described in Section 2.1, these 36 screens were designed in a collaborative effort with the Hudson River Fishermens Association 37 to minimize the mortality of impinged fish.

38 In 2000, NMFS prepared an environmental assessment (EA) for the incidental take of shortnose 39 sturgeons at Roseton and Danskammer (NMFS 2000). The EA included the estimated total 40 number (Table 1) of shortnose sturgeons impinged at Roseton, Danskammer, Bowline Point, Draft NUREG-1437, Supplement 38 E-96 December 2008

Appendix E 1 Lovett, and IP2 and IP3, with adjustments to include the periods when sampling was not 2 conducted.

3 Table 1. Estimated Total and Average Shortnose Sturgeon Impinged by Mid-Hudson 4 River Power Plants, Adjusted for Periods Without Sampling 1972-1998 1989-1998 Average No. Average No.

Power Plant Total Impinged/Year Total Impinged/Year Bowline Point 23 0.9 0 0 Lovett 0 0 0 0 IP2 37 1.4 8 0.8 IP3 26 1.0 8 0.8 Roseton 49 1.8 15 1.5 Danskammer 140 5.2 44 4.4 Point Total 275 10.2 75 7.5 Source: Adapted from NMFS 2000.

5 Impingement data provided by Entergy (2007b), which are available through the NRCs online 6 Agencywide Documents Access and Management System (ADAMS), include the raw number of 7 shortnose sturgeons collected at IP2 and IP3 during impingement monitoring (Table 2). Some 8 blank entries in historical results do not differentiate between no samples analyzed and 9 samples analyzed but no individuals found. Since it is unknown if there were any impinged 10 shortnose sturgeons for those time periods, counts must be considered minimal. The NRC staff 11 notes, however, that data submitted by Entergy indicate that a larger number of shortnose 12 sturgeons were impinged at IP2 and IP3 in the 7 years with reported data (1974-1979, 1984, 13 and 1987 for IP2; 1977-1980, 1984, 1987, and 1988 for IP3) than NMFS data indicate were 14 impinged by all mid-Hudson power plants from 1972 through 1998. The NRC staff finds that the 15 numbers provided by NMFS (2000) in its EA for IP2 and IP3 cannot be accurate. In this case, 16 the applicant-supplied data indicate a greater effect than the NMFS-supplied data.

17 An increase in the population of shortnose sturgeons in the Hudson River would most likely 18 result in an increase in impinged shortnose sturgeons at IP2 and IP3. If the population data 19 presented by Bain et al. (2007) and Woodland and Secor (2007) are accurate, then a four-fold 20 increase in population between the mid-1980s and mid-1990s could result in a similar increase 21 in impingement rates. However, this population increase would also mean that the impact of 22 taking an individual shortnose sturgeon would decrease. Without current impingement data, the 23 NRC staff cannot determine how changes in the shortnose sturgeon population have affected 24 impingement rates.

25 When considering the effects of impingement, it is important to consider the affected species 26 impingement mortality rate. For IP2 and IP3, however, there are few data regarding the survival 27 of the shortnose sturgeon after impingement. In 1979, NMFS issued a biological opinion (BO) 28 relating to the take of shortnose sturgeons at Indian Point (Dadswell 1979). At the time, there 29 was only 1 year in which records describing the status of impinged shortnose sturgeons were 30 kept. In that year, 60 percent of collected impinged shortnose sturgeons were dead when December 2008 E-97 Draft NUREG-1437, Supplement 38

Appendix E 1 collected. The BO assumes both that all dead sturgeons died as a result of the impingement 2 and that no impingement-related mortality occurred after the impinged sturgeons were released.

3 Table 2. Numbers of Shortnose Sturgeons Collected During Impingement Monitoring at 4 Indian Point Units 2 and 3 Year Unit 2 Unit 3 1975 3 -

1976 2 -

1977 11 2 1978 5 5 1979 4 3 1980 - 2 1981 - -

1982 - -

1983 - -

1984 176 154 1985 - -

1986 - -

1987 116 55 1988 - 186 1989 - -

1990 - -

Total 317 407 Source: Enclosure 3 to NL-07-156 5 The BO estimated that, in a worst-case scenario, 35 shortnose sturgeons would be impinged at 6 IP2 and IP3 per year, and that 60 percent (21 individuals) would die on the impingement 7 screens. At the time, the population of adult shortnose sturgeons in the Hudson River was 8 estimated to be 6,000, and this level of mortality would result in a 0.3 to 0.4 percent death rate 9 caused by impingement at IP2 and IP3 (Dadswell 1979).

10 Because all monitoring of impingement ceased after the Ristroph screens were installed in 11 1991, no updated mortality rate estimates for impinged shortnose sturgeons exist at IP2 and 12 IP3. The NRC staff does not know the current level of impingement or the level of mortality.

13 Although the laboratory and field tests (Fletcher 1990) performed on the modified Ristroph 14 screens were not conducted using the shortnose sturgeon, the tests did show that injury and 15 death were reduced for most species when compared to the first version of screens that were 16 proposed (and rejected, based on their unexceptional performance) (Fletcher 1990). If the 17 NRC staff assumes that the modified Ristroph screens performed as well as the Fletchers 1990 18 results indicated, then mortality and injury from impingement would be lower than reported by 19 the NMFS in its BO (Dadswell 1979), and the impact to the species would be less. Without 20 current monitoring, however, the NRC staff cannot confirm this.

21 Based on the limited amount of data from the years before the installation of modified Ristroph 22 screens at IP2 and IP3, and the lack of data from the years following screen installation, 23 including any potential changes in rates of mortality caused by impingement, the NRC staff Draft NUREG-1437, Supplement 38 E-98 December 2008

Appendix E 1 concludes that the continued operation of IP2 and IP3 for an additional 20 years could adversely 2 affect the population of shortnose sturgeons in the Hudson River through impingement but 3 cannot assess the extent to which the installation of modified Ristroph screens might reduce the 4 impact.

5 4.3.3 Thermal Impacts 6 The discharge of heated water into the Hudson River can cause lethal or sublethal effects on 7 resident fish, influence food web characteristics and structure, and create barriers to migratory 8 fish moving from marine to freshwater environments.

9 State Pollution Discharge Elimination System (SPDES) permit NY-0004472 regulates thermal 10 discharges associated with the operation of IP2 and IP3. This permit imposes effluent 11 limitations, monitoring requirements, and other conditions to ensure that all discharges are in 12 compliance with Article 17 of the Environmental Conservation Law of New York State, Part 704 13 of the Official Compilation of the Rules and Regulations of the State of New York, and the Clean 14 Water Act. Specific conditions of the SPDES permit related to thermal discharges from IP2 and 15 IP3 are specified in NYSDEC (2003) and include the following:

16

• The maximum discharge temperature is not to exceed 110 degrees F (43 degrees C).

17

• The daily average discharge temperature between April 15 and June 30 is not to exceed 18 93.2 degrees F (34 degrees C) for an average of more than 10 days per year during the 19 term of the permit, beginning in 1981, provided that it not exceed 93.2 degrees F 20 (34 degrees C) on more than 15 days during that period in any year.

21 The final environmental impact statement (FEIS) associated with the SPDES permit for IP2 and 22 IP3 (NYSDEC 2003) concludes that Thermal modeling indicates that the thermal discharge 23 from Indian Point causes water temperatures to rise more than allowed. The thermal modeling 24 referred to in the FEIS appears to represent a worst-case scenario. Available modeling 25 indicates the potential for the discharges from IP2 and IP3 to violate the conditions of the IP2 26 and IP3 SPDES permit, which could result in a negative impact on the shortnose sturgeon. IP2 27 and IP3 have not performed any triaxial thermal studies to completely assess the size and 28 nature of the thermal plume created by the discharge from IP2 and IP3 and the possible impact 29 on the sturgeon.

30 According to the NMFS Final Recovery Plan for the Shortnose Sturgeon (NMFS 1998), During 31 summer months, especially in southern rivers, shortnose sturgeons must cope with the 32 physiological stress of water temperatures that often exceed 82 degrees F (28 degrees C).

33 Although the area closest to the discharge from IP2 and IP3 can exceed these temperatures, 34 the summer maximum temperature of the Hudson River in the area of IP2 and IP3 is 35 77 degrees F (25 degrees C) (Entergy 2007a). The combined discharge from both Indian Point 36 units is about 1.75 million gpm (110 m3/s), including the service water (Entergy 2007a). Table 3 37 presents the net downstream flows caused by freshwater inflow. From these data, it can be 38 seen that 20 percent of the time, the discharge from IP2 and IP3 would be, at most, 15 percent 39 of the net flow; however, 98 percent of the time, the discharge would be, at most, 97 percent of 40 the net flow. This means that, at given times, the discharge from IP2 and IP3 would not 41 necessarily be well mixed into the Hudson River.

December 2008 E-99 Draft NUREG-1437, Supplement 38

Appendix E 1 Table 3. Cumulative Frequency Distribution of Net Downstream Flows of Hudson River 2

Million gallons per Cumulative minute (gpm) percentile 11.7 20 6.8 40 4.71 60 3.1 80 1.8 98 Adapted from Entergy 2007a 3 The NRC staff cannot determinebased on available informationwhether a shortnose 4 sturgeon in the Hudson River would experience any prolonged physiological stress from the 5 thermal plume caused by the discharge from IP2 and IP3. Shortnose sturgeons could be forced 6 to seek refuge from elevated water temperatures as they are forced to do in southern rivers, and 7 this could limit their available habitat. If studies reveal that the plume is buoyant, shortnose 8 sturgeons could pass underneath the plume on their passage past the facility, but there are no 9 data to indicate that this is the case.

10 As noted earlier, the NYSDEC thermal modeling of the Hudson River suggests that the 11 discharge from IP2 and IP3 could exceed the limits specified in the SPDES permit, but without a 12 triaxial thermal study, the exact size and nature of the thermal plume is unknown. Information 13 about the species, based on the NMFS recovery plan, suggests to the NRC staff that increased 14 temperatures can have a significant effect on the shortnose sturgeon. Therefore, the NRC staff 15 concludes that the continued operation of IP2 and IP3 for an additional 20 years could adversely 16 affect the population of shortnose sturgeons in the Hudson River through thermal discharge, but 17 the staff is unable to determine the extent to which the population would be affected.

18 5.0 Conclusion 19 Renewal of the operating licenses of IP2 and IP3 to include another 20 years of operation could 20 adversely affect the population of shortnose sturgeon in the Hudson River through impingement 21 and thermal impacts. At this time, the NRC staff cannot quantify the extent to which the 22 population could be affected.

23 6.0 References 24 Bain, M.B., Haley, N., Peterson, D.L., Arend, K.K., Mills, K.E., and Sullivan, P.J. 2007.

25 Recovery of a US Endangered Fish, PLoS ONE 2(1): e168. Accessed at:

26 http://www.plosone.org/article/info%3Adoi%2F10.1371%2Fjournal.pone.0000168#s3 on 27 December 11, 2007.

28 Central Hudson Gas and Electric Corporation (CHGEC), Consolidated Edison Company of New Draft NUREG-1437, Supplement 38 E-100 December 2008

Appendix E 1 York, Inc., New York Power Authority, and Southern Energy New York. 1999. Draft 2 Environmental Impact Statement for State Pollutant Discharge Elimination System Permits for 3 Bowline Point, Indian Point 2 and 3, and Roseton Steam Electric Generating Stations. ADAMS 4 Accession No. ML083400128.

5 Collette, B.B. and Klein-MacPhee, G., eds. 2002. Short-nosed sturgeon, Bigelow and 6 Schroeders Fishes of the Gulf of Maine, Third Edition, Smithsonian Institution Press:

7 Washington, DC.

8 Dadswell, M.J. 1979. Testimony on behalf of the National Marine Fisheries Service, presented 9 before the U.S. Environmental Protection Agency, Region II, May 14, 1979. ADAMS Accession 10 No. ML083430546.

11 Dadswell, M.J., Taubert, B.D., Squiers, T.S., Marchette, D., and Buckley, J. 1984. Synopsis of 12 Biological Data on Shortnose Sturgeon, Acipenser brevirostrum LeSueur 1818, NOAA 13 Technical Report NMFS-14, FAO Fisheries Synopsis No. 140. Accessed at:

14 http://www.nmfs.noaa.gov/pr/pdfs/species/shortnosesturgeon_biological_data.pdf on 15 December 11, 2007.

16 Entergy Nuclear Operations, Inc. (Entergy). 2007a. Applicants Environmental Report, 17 Operating License Renewal Stage (Appendix E to Indian Point, Units 2 & 3, License Renewal 18 Application), April 23, 2007, ADAMS Accession No. ML071210530. ADAMS Accession No. ML19071210530.

20 Entergy Nuclear Northeast (Entergy). 2007b. Letter from F. Dacimo, Vice President, Entergy 21 Nuclear Northeast, to U.S. Nuclear Regulatory Commission Document Control Desk.

Subject:

22 Entergy Nuclear Operations, Inc., Indian Point Nuclear Generating Unit Nos. 2 & 3, Docket Nos.

23 50-247 and 50-286, Supplement to License Renewal Application (LRA)Environmental Report 24 References. ADAMS Accession Nos. ML080080205, ML080080209, ML080080213, 25 ML080080214, ML080080216, ML080080291, ML080080298, ML080080306.

26 Fletcher, R.I. 1990. Flow dynamics and fish recovery experiments: water intake systems, 27 Transactions of the American Fisheries Society 119:393-415.

28 Kynard, B. 1997. Life history, latitudinal patterns, and status of the shortnose sturgeon 29 Acipenser brevirostrum, Environmental Biology of Fishes 48: 319-334.

30 National Marine Fisheries Service (NMFS). No date. :Shortnose Sturgeon (Acipenser 31 brevirostrum), Office of Protected Resources (OPR). Accessed at 32 http://www.nmfs.noaa.gov/pr/species/fish/shortnosesturgeon.htm on December 11, 2007.

33 ADAMS Accession No. ML083430566.

34 National Marine Fisheries Service (NMFS). 1998. Recovery Plan for the Shortnose Sturgeon 35 (Acipenser brevirostrum), prepared by the Shortnose Sturgeon Recovery Team for the National 36 Marine Fisheries Service, Silver Spring, Maryland. Accessed at:

37 http://www.nmfs.noaa.gov/pr/pdfs/recovery/sturgeon_shortnose.pdf on December 11, 2007.

38 National Marine Fisheries Service (NMFS). 2000. Environmental Assessment of a Permit for 39 the Incidental Take of Shortnose Sturgeon at the Roseton and Danskammer Point Generating 40 Stations. ADAMS Accession No. ML083430553.

41 December 2008 E-101 Draft NUREG-1437, Supplement 38

Appendix E 1 National Marine Fisheries Service (NMFS). 2007. Letter from M. Colligan, Assistant Regional 2 Administrator for Protected Resources, National Marine Fisheries Service to Chief, Rules and 3 Directives Branch, U. S. Nuclear Regulatory Commission.

Subject:

Response to request for 4 information regarding threatened and endangered species in the vicinity of Indian Point.

5 October 4, 2007. ADAMS Accession No. ML073340068.

6 New York State Department of Environmental Conservation (NYSDEC). 2003. Final 7 Environmental Impact Statement Concerning the Applications to Renew New York State 8 Pollutant Discharge Elimination System (SPDES) Permits for the Roseton 1and 2 Bowline 1 and 9 2 and IP2 and IP3 2 and 3 Steam Electric Generating Stations, Orange, Rockland and 10 Westchester Counties, Hudson River Power Plants FEIS, June 25, 2003. ADAMS Accession 11 No. ML083360752..

12 Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement for 13 License Renewal of Nuclear Power Plants, NUREG-1437, Volumes 1 and 2, Washington, DC.

14 Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement for 15 License Renewal of Nuclear Plants, Main Report, Section 6.3, Transportation, Table 9.1, 16 Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, NUREG-17 1437, Volume 1, Addendum 1, Washington, DC.

18 Nuclear Regulatory Commission (NRC). 2007. Letter from R. Franovich to Mr. Peter Colosi, 19 National Marine Fisheries Service, Gloucester, Massachusetts, Re: Request for List of 20 Protected Species and Essential Fish Habitat Within the Area under Evaluation for the Indian 21 Point Nuclear Generating Unit Nos. 2 and 3 License Renewal Application Review, 22 August 16, 2007. ADAMS Accession No. ML072130388.

23 Shepherd, G. 2006 Shortnose Sturgeon (Acipenser brevirostrum), National Marine Fisheries 24 Service (NOAA), Office of Protected Resources (OPR).. Last updated in December, 2006.

25 http://www.nefsc.noaa.gov/sos/spsyn/af/sturgeon/archives/42_Atlantic_ShortnoseSturgeons_20 26 06.pdf. Accessed at: on December 11, 2007. ADAMS Accession No,ML083430573.

27 Woodland, R.J. and Secor, D.H. 2007. Year-class strength and recovery of endangered 28 shortnose sturgeon in the Hudson River, New York, Transactions of the American Fisheries 29 Society 136:72-81.

Draft NUREG-1437, Supplement 38 E-102 December 2008

Appendix F GEIS Environmental Issues Not Applicable to Indian Point Nuclear Generating Station Unit Nos. 2 and 3

Appendix F GEIS Environmental Issues Not Applicable to Indian Point Nuclear Generating Unit Nos. 2 and 3 Table F-1 lists those environmental issues identified in NUREG-1437, Volumes 1 and 2, Generic Environmental Impact Statement for License Renewal of Nuclear Plants (hereafter referred to as the GEIS), issued 1996 and 1999,(4) and in Table B-1 of Appendix B to Subpart A of Title 10, Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, of the Code of Federal Regulations (10 CFR Part 51), that are not applicable to Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3) because of plant or site characteristics.

Table F-1. GEIS Environmental Issues Not Applicable to IP2 and IP3 ISSUE10 CFR Part 51, Subpart A, Category GEIS Appendix B, Table B-1 Sections Comment SURFACE WATER QUALITY, HYDROLOGY, AND USE (FOR ALL PLANTS)

Altered thermal stratification of lakes 1 4.2.1.2.3, IP2 and IP3 do not 4.4.2.2 discharge into a lake.

Water use conflicts (plants with 1 4.3.2.1, IP2 and IP3 have a once-cooling pond or cooling towers using 4.4.2.1 through cooling system.

makeup water from a small river with low flow)

Water use conflicts (plants with 2 4.3.2.1 This issue is related to cooling towers and cooling ponds 4.4.2.1 heat-dissipation systems using make-up water from a small that are not installed at IP2 river with low flow) and IP3.

AQUATIC ECOLOGY (FOR ALL PLANTS)

AQUATIC ECOLOGY (FOR PLANTS WITH COOLING TOWER-BASED HEAT DISSIPATION SYSTEMS)

Entrainment of fish and shellfish in 1 4.2.2.1.2, This issue is related to early life stages 4.4.3 heat-dissipation systems that are not installed at IP2 and IP3.

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

December 2008 F-1 Draft NUREG-1437, Supplement 38

Appendix F ISSUE10 CFR Part 51, Subpart A, Category GEIS Appendix B, Table B-1 Sections Comment Impingement of fish and shellfish 1 4.2.2.1.3, This issue is related to 4.4.3 heat-dissipation systems that are not installed at IP2 and IP3.

Heat shock 1 4.2.2.1.4, This issue is related to 4.4.4 heat-dissipation systems that are not installed at IP2 and IP3.

GROUND WATER USE AND QUALITY Ground water use conflicts (potable 1 4.8.1.1, IP2 and IP3 do not use and service water, and dewatering; 4.8.1.2 ground water for any plants that use <100 gpm) purpose.

Ground water use conflicts (potable 2 4.8.1.1, IP2 and IP3 do not use and service water, and dewatering; 4.8.1.2 ground water for any plants that use >100 gpm) purpose.

Ground water use conflicts (plants 2 4.8.1.3 This issue is related to using cooling towers withdrawing heat-dissipation systems makeup water from a small river) that are not installed at IP2 and IP3.

Ground water use conflicts (Ranney 2 4.8.1.4 IP2 and IP3 do not have or wells) use Ranney wells.

Ground water quality degradation 1 4.8.2.2 IP2 and IP3 do not have or (Ranney wells) use Ranney wells.

Ground water quality degradation 1 4.8.2.1 IP2 and IP3 do not use for (saltwater intrusion) any purpose.

Ground water quality degradation 1 4.8.3 IP2 and IP3 do not use (cooling ponds in salt marshes) cooling ponds.

Ground water quality degradation 2 4.8.3 IP2 and IP3 do not use (cooling ponds at inland sites) cooling ponds.

Draft NUREG-1437, Supplement 38 F-2 December 2008

Appendix F ISSUE10 CFR Part 51, Subpart A, Category GEIS Appendix B, Table B-1 Sections Comment HUMAN HEALTH Microbial organisms (occupational 1 4.3.6 This issue is related to a Health) heat-dissipation system that is not installed at IP2 and IP3.

Microbiological organisms (public 2 4.3.6 This issue is related to a health; plants lakes or canals, cooling heat-dissipation system towers, or cooling ponds that that is not installed at IP2 discharge to a small river) and IP3.

TERRESTRIAL RESOURCES Cooling tower impacts on crops and 1 4.3.4 This issue is related to a ornamental vegetation heat-dissipation system that is not installed at IP2 and IP3.

Cooling tower impacts on native 1 4.3.5.1 This issue is related to a plants heat-dissipation system that is not installed at IP2 and IP3.

Bird collisions with cooling towers 1 4.3.5.2 This issue is related to a heat-dissipation system that is not installed at IP2 and IP3.

Cooling pond impacts on terrestrial 1 4.4.4 This issue is related to a resources heat-dissipation system that is not installed at IP2 and IP3.

December 2008 F-3 Draft NUREG-1437, Supplement 38

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

U.S. Nuclear Regulatory Commission, NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Volumes 1 and 2, May 1996.

U.S. Nuclear Regulatory Commission, NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Main Report, Section 6.3, Transportation, Table 9.1, Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final Report, Volume 1, Addendum 1, August 1999.

Draft NUREG-1437, Supplement 38 F-4 December 2008

Appendix G U.S. Nuclear Regulatory Commission Staff Evaluation of Severe Accident Mitigation Alternatives for Indian Point Nuclear Generating Unit Nos. 2 and 3 in Support of License Renewal Application Review

1 Appendix G 2 U.S. Nuclear Regulatory Commission Staff Evaluation of 3 Severe Accident Mitigation Alternatives for 4 Indian Point Nuclear Generating Unit Nos. 2 and 3 in 5 Support of License Renewal Application Review 6 G.1 Introduction 7 Entergy Nuclear Operations, Inc. (Entergy) submitted an assessment of severe accident 8 mitigation alternatives (SAMAs) for Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and 9 IP3) as part of the environmental report (ER) (Entergy 2007). Entergy based its assessment on 10 the most recent probabilistic safety assessment (PSA) for IP2 and IP3 (a site-specific offsite 11 consequence analysis performed using the MELCOR Accident Consequence Code System 2 12 (MACCS2) computer code), and on insights from the Individual Plant Examination (IPE) (Con 13 Ed 1992 and NYPA 1994) and the Individual Plant Examination of External Events (IPEEE) 14 (Con Ed 1995 and NYPA 1997) for each unit. In identifying and evaluating potential SAMAs, 15 Entergy considered SAMAs that addressed the major contributors to core damage frequency 16 (CDF) and large early release frequency (LERF) at IP2 and IP3, as well as SAMA candidates 17 for other operating plants that have submitted license renewal applications. Entergy identified 18 231 candidate SAMAs for IP2 and 237 SAMAs for IP3. This list was reduced to 68 (IP2) and 62 19 (IP3) unique SAMAs by eliminating SAMAs that are not applicable at IP2 and IP3 because they 20 have design differences, they have already been implemented at IP2 and IP3, or they are 21 similar in nature and could be combined with another SAMA candidate. Entergy assessed the 22 costs and benefits associated with each of the potential SAMAs and concluded in the ER that 23 several of these were potentially cost beneficial.

24 Based on a review of the SAMA assessment, the U.S. Nuclear Regulatory Commission (NRC) 25 issued requests for additional information (RAIs) to Entergy by letters dated December 7, 2007 26 (NRC 2007), and April 2, 2008 (NRC 2008). Key questions concerned major changes to the 27 internal flood model in each of the PSA updates; PSA peer review comments and their 28 resolution; MACCS2 input data and assumptions (including core inventory, evacuation 29 modeling, and offsite economic costs); assumptions used to quantify the benefits for certain 30 SAMAs; reasons for unit-to-unit differences for certain risk contributors and estimated SAMA 31 benefits; and further information on several specific candidate SAMAs and low-cost alternatives, 32 including SAMAs related to steam generator tube rupture (SGTR) events. Entergy submitted 33 additional information by letters dated February 5, 2008 (Entergy 2008a), and May 22, 2008 34 (Entergy 2008b). In response to the RAIs, Entergy provided clarification of the internal flooding 35 analysis changes in each PSA model version; additional information regarding the peer review 36 process and comment resolution; details regarding the MACCS2 input data, including results of 37 a sensitivity analysis addressing loss of tourism and business; additional explanation and 38 justification for the assumptions in each analysis case; descriptions of plant-specific features December 2008 G-1 Draft NUREG-1437, Supplement 38

Appendix G 1 that account for differences in risk and SAMA benefits between units; and additional information 2 regarding several specific SAMAs, including SGTR-related SAMAs. Entergys responses 3 addressed the NRC staffs concerns and resulted in the identification of several additional 4 potentially cost-beneficial SAMAs and the elimination of one previously identified cost-beneficial 5 SAMA.

6 An assessment of SAMAs for IP2 and IP3 is presented below.

7 G.2 Estimate of Risk for IP2 and IP3 8 Entergys estimates of offsite risk at IP2 and IP3 are summarized in Section G.2.1. The 9 summary is followed by the NRC staffs review of Entergys risk estimates in Section G.2.2.

10 G.2.1. Entergys Risk Estimates 11 The two distinct analyses that are combined to form the basis for the risk estimates used in the 12 SAMA analysis are (1) the IP2 and IP3 Level 1 and Level 2 PSA models, which are updated 13 versions of the IPE (Con Ed 1992 and NYPA 1994) and IPEEE (Con Ed 1995 and NYPA 1997) 14 for each unit, and (2) supplemental analyses of offsite consequences and economic impacts 15 (essentially a Level 3 PSA model) developed specifically for the SAMA analysis. The SAMA 16 analysis is based on the most recent IP2 and IP3 Level 1 and Level 2 PSA models available at 17 the time of the ER, referred to as the IP2 Revision 1 PSA model (April 2007) for IP2 and the IP3 18 Revision 2 PSA model (April 2007) for IP3. The scope of the PSA models does not include 19 external events.

20 The baseline CDF for the purpose of the SAMA evaluation is approximately 1.79x10-5 per year 21 for IP2 and 1.15x10-5 per year for IP3. The CDF is based on the risk assessment for internally 22 initiated events, including internal flooding. Entergy did not include the contributions from 23 external events within the IP2 and IP3 risk estimates; however, it did perform separate 24 assessments of the CDF from external events and did account for the potential risk reduction 25 benefits associated with external events by multiplying the estimated benefits for internal events 26 by a factor of approximately 3.8 for IP2 and 5.5 for IP3. This is discussed further in Sections 27 G.2.2 and G.6.2.

28 The breakdown of CDF by initiating event is provided in Table G-1 for IP2 and IP3. For IP2, 29 loss of offsite power sequences, including station blackout (SBO) events, and internal flooding 30 initiators are the dominant contributors to CDF. For IP3, internal flooding initiators, loss-of-31 coolant accidents (LOCAs), SGTR events, and anticipated transient without scram (ATWS) 32 events are the dominant contributors to CDF.

33 There are several significant differences between the two Indian Point units that account for 34 differences in the risk contributions shown in Table G-1. These differences include:

35 The pressurizer PORV block valves are normally closed in Unit 2, and normally open in Unit 3.

36 Thus, the ability to use the PORVs for feed and bleed cooling in LOOP and partial power loss 37 events is greater at Unit 3, resulting in a lower CDF for LOOP events in Unit 3.

Draft NUREG-1437, Supplement 38 G-2 December 2008

Appendix G 1 There are differences in the internal flooding sources and building configurations (e.g., ingress 2 and egress paths). These physical differences together with differences in the method for 3 calculating failure frequencies result in higher flood CDF frequencies in Unit 2.

4 In Unit 2, DC control power for EDGs and other loads on emergency 480 VAC busses is 5 supplied from either normal or emergency backup supplies, with automatic switching between 6 supplies. Unit 3 does not have this backup capability. This results in a lower CDF contribution 7 from loss of DC power events in Unit 2.

8 Table G-1. IP2 and IP3 Core Damage Frequency IP2 IP3 Initiating Event  % CDF  %

CDF Contribution (Per Year) Contribution (Per Year) to CDF to CDF loss of offsite power 1 6.7x10-6 38 1.2x10-7 1 internal flooding 4.7x10-6 26 2.2x10-6 20 LOCA 1.5x10-6 8 2.2x10-6 19 transients 1 1.2x10-6 7 8.5x10-7 7 ATWS 9.9x10-7 6 1.5x10-6 13 SBO SGTR 8.5x10-7 5 7.2x10-7 6 loss of component cooling water 7.2x10-7 4 1.6x10-6 14 (CCW) loss of nonessential service water 5.8x10-7 3 1.1x10-7 <1 interfacing systems LOCA (ISLOCA) 3.0x10-7 2 2.8x10-7 2 reactor vessel rupture loss of 125 volts (V) direct current 1.5x10-7 <1 1.5x10-7 1 (dc) power total loss of service water system 1.0x10-7 <1 1.0x10-7 <1 loss of essential service water 5.8x10-8 <1 1.0x10-6 9 4.4x10-8 <1 5.4x10-7 5 1.9x10-10 <1 1.9x10-8 <1 Total CDF (internal events) 1.79x10-5 100 1.15x10-5 100 1

Contributions from SBO and ATWS events are noted separately and are not included in the reported values for loss of offsite power or transients.

9 The current Level 2 PSA models are based on the IPE models, with updates to reflect changes 10 to the plant and modeling techniques, including a 3.3 percent and 4.8 percent power uprate for 11 IP2 and IP3, respectively; inclusion of additional plant damage states (PDSs) to improve the 12 Level 1-Level 2 PSA interface; and updated accident progression and source term analyses 13 using a later version of the Modular Accident Analysis Program (MAAP) computer code. The 14 Level 1 core damage sequences are placed into one of 57 PDS bins that provide the interface 15 between the Level 1 and Level 2 analyses. The Level 2 models use a single containment event 16 tree (CET) with functional nodes representing both systemic and phenomenological events.

17 CET nodes are evaluated using supporting fault trees and logic rules.

18 The result of the Level 2 PSA is a set of nine release categories with their respective frequency 19 and release characteristics. The results of this analysis for IP2 and IP3 are provided in Tables December 2008 G-3 Draft NUREG-1437, Supplement 38

Appendix G 1 E.1-9 (IP2) and E.3-9 (IP3) of the ER. The frequency of each release category was obtained by 2 summing the frequency of the individual accident progression CET endpoints binned into the 3 release category. Source terms were developed for each of the nine release categories using 4 the results of MAAP 4.04 computer code calculations. The release characteristics for each 5 release category were obtained by frequency-weighting the release characteristics for each 6 CET endpoint contributing to the release category (Entergy 2007).

7 The offsite consequences and economic impact analyses use the MACCS2 code to determine 8 the offsite risk impacts on the surrounding environment and public. Inputs for these analyses 9 include plant-specific and site-specific input values for core radionuclide inventory, source term 10 and release characteristics, site meteorological data, projected population distribution (within an 11 80-kilometer (50-mile) radius) for the year 2035, emergency response evacuation modeling, and 12 economic data. The magnitude of the onsite impacts (in terms of cleanup and decontamination 13 costs and occupational dose) is based on information provided in NUREG/BR-0184 (NRC 14 1997a).

15 In the ER, Entergy estimated the dose to the population within 80 kilometers (50 miles) of the 16 IP2 and IP3 site to be approximately 0.22 person-sievert (Sv; 22 person-rem) per year for IP2, 17 and 0.24 Sv (24 person-rem) per year for IP3. The breakdown of the total population dose by 18 containment failure mode is summarized in Table G-2, based on information provided in 19 response to an RAI (Entergy 2008a). SGTR events and late containment failures caused by 20 gradual overpressurization by steam and noncondensable gases dominate the population dose 21 risk at both units.

22 Table G-2. Breakdown of Population Dose by Containment Failure Mode IP2 IP3 Population Population Containment Failure Mode Dose (Person- Percent Dose Percent Rem1 Per Contribution (Person Contribution Year) Rem1 Per Year) intact containment <0.1 <1 <0.1 <1 basemat meltthrough 1.1 5 0.6 3 gradual overpressure 7.4 34 4.4 18 late hydrogen burns 0.9 4 0.6 2 early hydrogen burns 2.1 10 0.8 3 invessel steam explosion 0.1 1 0.1 0 reactor vessel rupture 1.0 5 0.4 2 ISLOCA 1.6 7 1.1 4 SGTR 7.7 35 16.6 68 Total 22.0 100 24.3 100 1

One person-rem = 0.01 Sv.

Draft NUREG-1437, Supplement 38 G-4 December 2008

Appendix G 1

2 Review of Entergys Risk Estimates 3 Entergys determination of offsite risk at IP2 and IP3 is based on the following four major 4 elements of analysis:

5 (1) the Level 1 and Level 2 risk models that form the bases for the IPE submittals (Con Ed 6 1992 and NYPA 1994) and the IPEEE submittals (Con Ed 1995 and NYPA 1997) 7 (2) the major modifications to the IPE models that have been incorporated in the IP2 and 8 IP3 2007 PSA updates 9 (3) adjustments to the IPEEE seismic and fire risk results to represent recent plant changes, 10 updated failure probabilities, and more realistic assumptions 11 (4) the MACCS2 analyses performed to translate fission product source terms and release 12 frequencies from the Level 2 PSA model into offsite consequence measures 13 Each of these analyses was reviewed to determine the acceptability of Entergys risk estimates 14 for the SAMA analysis, as summarized below.

15 The NRC staffs reviews of the IP2 and IP3 IPE submittals are described in the NRC reports 16 dated August 14, 1996 (NRC 1996) and October 20, 1995 (NRC 1995), for IP2 and IP3, 17 respectively. Based on its review of the IPE submittals and responses to RAIs, the NRC staff 18 concluded that the IPE submittals met the intent of Generic Letter (GL) 88-20; that is, the 19 licensees IPE process is capable of identifying the most likely severe accidents and severe 20 accident vulnerabilities. Although no vulnerabilities were identified in the IPE, several plant 21 improvements were identified. These improvements have either been implemented at the site 22 or addressed by a SAMA in the current evaluation (Entergy 2007). These improvements are 23 discussed in Section G.3.2.

24 There have been three revisions to the IP2 PSA model and two revisions to the IP3 PSA model 25 since the respective IPE submittals. A comparison of the internal events CDF between the IPE 26 submittals and the current PSA models indicates a decrease of approximately 45 and 75 27 percent for IP2 and IP3, respectively (from 3.13x10-5 per year to 1.79x10-5 per year for IP2 and 28 from 4.40x10-5 per year to 1.15x10-5 per year for IP3). A description of those changes that 29 resulted in the greatest impact on the internal-event CDF is provided in Sections E.1.4 and 30 E.3.4 of the ER (Entergy 2007) and in response to a staff RAI (Entergy 2008a) and is 31 summarized in Tables G-3a and G-3b for IP2 and IP3, respectively.

December 2008 G-5 Draft NUREG-1437, Supplement 38

Appendix G 1 Table G-3a. IP2 PSA Historical Summary PSA Summary of Changes from Prior Model CDF Version (per year) 1992 IPE submittal (excluding internal flooding) (RISKMAN) 3.13x10-5 Update 5/2003 PSA Update (RISKMAN) 2.19x10-5

- credited recovery of feedwater and condensate

- added treatment of cross-header common-cause failure (CCF) for essential and nonessential service water headers

- updated equipment performance and unavailability data

- revised human error probabilities based on thermal-hydraulic calculations

- updated reactor coolant pump (RCP) seal LOCA model

- added treatment of internal flooding events Rev. 0 3/2005 PSA update (Computer-Aided Fault-Tree Analysis code (CAFTA)) 1.71x10-5

- updated initiating event, component failure, and unavailability databases

- updated offsite power recovery data per EPRI 1009889

- revised internal flooding analysis, including pipe-break frequencies and human error probabilities

- changed CCF model from multiple Greek letter to Alpha method

- updated human reliability analysis (HRA) method to the EPRI HRA method

- updated RCP seal LOCA model to WCAP-16141 (WOG2000)

- updated ISLOCA model to address ISLOCAs inside containment, to credit mitigation only for small LOCAs outside containment, and to remove credit for makeup to the refueling water storage tank (RWST)

Rev. 1 2/2007 PSA update 1.79x10-5

- updated selected initiating event frequencies

- updated offsite power recovery model per NUREG/CR-6890

- included CCF for plugging service water pump strainers

- revised model to reflect that normal offsite power feeds to the 480-V ac safeguards buses do not trip on a safety injection (SI) signal without a concurrent loss of offsite power

- added credit for Indian Point Unit 1 (IP1) station air compressors for scenarios that do not involve loss of offsite power

- revised auxiliary feedwater (AFW) success criterion to require flow to two (rather than one) steam generators for normal (non-ATWS) response Draft NUREG-1437, Supplement 38 G-6 December 2008

Appendix G 1 Table G-3b IP3 PSA Historical Summary PSA Summary of Changes from Prior Model CDF Version (per year) 1994 IPE submittal (including internal flooding CDF of 6.5x10-6) 4.40x10-5 Rev. 1 6/2001 PSA Update 1.35x10-5

- updated initiating event, component failure, and unavailability databases

- updated offsite power recovery model per NUREG/CR-5496

- revised and added CCF component groups consistent with the most recent probabilistic risk assessment (PRA) practices, and updated CCF data

- revised HRA to reflect EOP changes

- updated RCP seal LOCA model per Brookhaven model, including credit for qualified high-temperature RCP seals

- incorporated major plant design changes, including:

• replacement of power-operated relief valves (PORVs) to eliminate leakage and allow operation with the block valve open

• reassignment of power supplies to emergency diesel generator (EDG) room exhaust fans to eliminate dependencies

• modification of backup battery charger 35 to be able to be powered from 480-V MCC 36C, 36D, or 36E

• installation of a diesel-driven station air compressor.

• installation of temperature detectors to provide control room alarm if high temperature on the 15 and 33 feet (ft) elevation of the control building

• installation of a waterproof door to the deluge valve station Rev. 2 2/2007 PSA Update 1.15x10-5

- added a total loss of service water initiating event

- updated offsite power recovery model per NUREG/CR-6890

- changed CCF model from modified Beta method to Alpha method

- updated RCP seal LOCA model to WCAP-16141 (WOG2000)

- revised AFW success criterion to require flow to two (rather than one) steam generators for normal (non-ATWS) response

- modified success criteria for cooling of internal recirculation pumps to remove credit for cooling by redundant systems

- removed the credit for an offsite gas turbine (which is no longer maintained)

December 2008 G-7 Draft NUREG-1437, Supplement 38

Appendix G 1 The CDF values from the IP2 and IP3 IPE submittals (3.13x10-5 per year and 4.40x10-5 per 2 year, respectively) are near the average of the CDF values reported in the IPEs for pressurized-3 water reactors (PWRs) with dry containments. Figure 11.2 of NUREG-1560 shows that the IPE-4 based total internal events for these plants range from 9x10-8 to 8x10-5 per year, with an 5 average CDF for the group of 2x10-5 per year (NRC 1997b). The NRC staff recognizes that 6 other plants have updated the values for CDF subsequent to the IPE submittals to reflect 7 modeling and hardware changes. The current internal event CDF results for IP2 and IP3 8 (1.79x10-5 per year and 1.15x10-5 per year, respectively) are comparable to those for other 9 plants of similar vintage and characteristics.

10 The NRC staff considered the peer reviews performed for the IP2 and IP3 PSAs and the 11 potential impact of the review findings on the SAMA evaluation in order to reach a conclusion 12 regarding adequacy of the PRA to support SAMA evaluation. In the ER, Entergy described the 13 peer review by the (former) Westinghouse Owners Group (WOG) of the IP2 PSA model, 14 conducted in May 2002, and of the IP3 PSA model, conducted in January 2001. The IP2 model 15 reviewed was an updated version of the IPE that predated the May 2003 version described in 16 Table G-3a. Similarly, the IP3 model reviewed was an updated version of the IPE that predated 17 the June 2001 version described in Table G-3b.

18 For both IP2 and IP3, the ER states that all of the technical elements were graded as sufficient 19 to support applications requiring the capabilities defined for grade 2 (e.g., risk-ranking 20 applications). In addition, most of the elements were further graded as sufficient to support 21 applications requiring the capabilities defined for grade 3 (e.g., risk-informed applications 22 supported by deterministic insights).

23 For IP2, the ER states that there were no Level A findings (for which immediate model changes 24 would have been appropriate) from the peer review. Although a number of minor model 25 corrections were made following the peer review, no significant changes were made to the 26 model structure or underlying assumptions in the May 2003 PSA update. The IP2 model was 27 subsequently converted from the support-state RISKMAN model to a linked-fault-tree CAFTA 28 model. Entergy indicates that the conversion effort included a number of modeling changes for 29 consistency with other Entergy models and addressed the remaining findings and observations 30 (F&Os) from the IP2 Peer Review (i.e., Level B, C, and D F&Os), where appropriate. In 31 addition, the issues raised during the peer review of the IP3 model were also examined for 32 applicability to IP2; all applicable issues were addressed consistent with the treatment used for 33 IP3. For IP3, the ER states that all Level A and B F&Os from the IP3 peer review were 34 addressed in the final version of the Revision 1 PSA model for IP3, which was issued in 35 June 2001, and that less significant (Level C & D) F&Os were addressed, where appropriate.

36 Entergy indicates that the model changes incorporated in the IP2 Revision 1 and the IP3 37 Revision 2 PSA models also underwent an internal independent review by Entergy PSA staff 38 and plant personnel and were subjected to a focused self-assessment to demonstrate technical 39 quality in preparation for the NRC Mitigating Systems Performance Indicator (MSPI) program in 40 2006. In addition, the IP2 model was also subjected to a weeklong review by a team of industry 41 peers from outside the Entergy staff in July 2005. Finally, the ER indicates that the model 42 changes in the IP2 Revision 1 and the IP3 Revision 2 PSA models were peer reviewed for 43 accuracy and consistency by members of the Entergy Nuclear Systems Analysis Group not 44 directly involved in their implementation (Entergy 2007).

Draft NUREG-1437, Supplement 38 G-8 December 2008

Appendix G 1 Given that the IP2 and IP3 internal events PSA models have been peer reviewed and the peer 2 review findings were either addressed or judged to have no adverse impact on the SAMA 3 evaluation, and that Entergy has satisfactorily addressed the NRC questions regarding the PSA 4 (NRC 2007, NRC 2008, Entergy 2008a, Entergy 2008b), the NRC staff concludes that the 5 internal events Level 1 PSA model for the plants is of sufficient quality to support the SAMA 6 evaluation.

7 Section E.1.4 of the ER states that, for IP2, internal flooding was examined as part of the 8 IPEEE, while Section E.3.4 indicates that internal flooding was included in the IP3 IPE. Internal 9 flooding was later incorporated into the IP2 May 2003 PSA update, resulting in the consistent 10 treatment of internal flooding for the two units.

11 The IP2 IPEEE analysis of internal flooding yielded a CDF of 6.6x10-6 per year while the IP3 IPE 12 internal flooding analysis yielded a CDF of 6.5x10-6 per year. For each plant, three scenarios 13 accounted for more than 80 percent of the flood CDF. All these scenarios result in a reactor trip 14 and the nonrecoverable loss of safety-related switchgear from flooding sources located in or 15 adjacent to the each units 480-V switchgear room.

16 The internal flooding analysis was included in the WOG peer review. In response to an RAI, 17 Entergy provided a detailed discussion on the incorporation of peer review comments for IP2 18 and IP3. For IP2, the licensee indicated that there were only two WOG peer review findings 19 associated with the internal flooding analysis.

20 The first finding related to use of a flooding event screening criterion of 1x10-6 per year in the 21 analysis. That criterion, however, was only applied to a scenario involving the potential for 22 intercompartmental flooding from the EDG building to the electrical tunnel and involved leakage 23 that could be accommodated by existing plant drains rather than catastrophic failure. Therefore, 24 it was determined that screening of this scenario was appropriate and a model change was not 25 needed.

26 The second finding was a general concern that the flooding study had not been updated since 27 1993. The IP2 internal flooding analysis was subsequently updated in 2005 (Entergy 2008a).

28 For IP3, the licensee indicated that the IP3 WOG peer review concluded that the internal 29 flooding analysis demonstrated a superior combination of industry data and models to obtain 30 plant-specific piping rupture frequencies. The peer review identified four F&Os related to the 31 internal flooding analysis. One F&O was a strength that warranted no change to the model.

32 The other findings related to incorporation of historical data, assembly of walkdown records, and 33 consideration of applicable draft American Society of Mechanical Engineers (ASME) standards 34 to enhance the flooding analysis. The findings related to the incorporation of historical data and 35 to the assembly of walkdown records were resolved during preparation of the final version of 36 Revision 1 of the IP3 PSA model. The draft ASME standards identified by the review team were 37 reviewed, and no modeling changes were warranted. Therefore, all internal flooding review 38 comments that affect the model were addressed in the model used for the SAMA analysis 39 (Entergy 2008a).

40 As indicated above, the current IP2 and IP3 PSA models do not include external events. In the 41 absence of such an analysis, Entergy used the IP2 and IP3 IPEEEs, in conjunction with minor 42 adjustments in fire and seismic scenarios, to identify the highest risk accident sequences and 43 the potential means of reducing the risk posed by those sequences, as discussed below.

December 2008 G-9 Draft NUREG-1437, Supplement 38

Appendix G 1 The IP2 and IP3 IPEEEs were submitted in December 1995 (Con Ed 1995) and September 2 1997 (NYPA 1997), in response to Supplement 4 of GL 88-20 (NRC 1991). These submittals 3 included a seismic PRA analysis, a fire PRA, a high-wind risk model, and a screening analysis 4 for other external events. While no fundamental weaknesses or vulnerabilities to severe 5 accident risk in regard to the external events were identified, several opportunities for risk 6 reduction were identified and implemented, as discussed below. In letters dated August 13, 7 1999, and February 15, 2001, the NRC staff concluded that the submittals for IP2 and IP3 8 generally met the intent of Supplement 4 to GL 88-20, and that the licensees IPEEE process is 9 capable of identifying the most likely severe accidents and severe accident vulnerabilities (NRC 10 1999 and 2001). For IP3, the NRC staff identified an issue related to misdirection of manual fire 11 suppression, which can fail equipment, but decided to resolve that issue separately from the 12 IPEEE.

13 The IPEEE seismic analyses employed a seismic PSA following the guidance of NUREG-1407.

14 The IPEEE estimated a seismic CDF of 1.46x10-5 and 4.4x10-5 per year for IP2 and IP3, 15 respectively. Components related to decay heat removal were modeled in the seismic PSA for 16 both units. No unique decay-heat removal vulnerabilities were found for either unit based on the 17 quantitative risk results. Seismic-induced flooding and fires were examined as part of the 18 IPEEE process for both units. Specific seismic-fire interactions were identified by Entergy, as 19 listed in Table 2.12 of NUREG-1742 (NRC 2002). However, upon further consideration, the 20 NRC staff concluded that the contribution to the CDF is small because the conditional 21 probability of a fire, given an earthquake, is small (NRC 2001). For IP2 and IP3, the IPEEEs 22 also addressed the issue of relay chattering through a detailed examination of the relays used in 23 IP2 against the low-capacity relay list found in Appendix D of Electric Power Research Institute 24 (EPRI) NP-7148-SL. A list of the dominant contributors to the seismic CDF for IP2 and IP3 is 25 provided in Tables G-4a and G-4b, based on the information provided in response to an RAI 26 (Entergy 2008a).

27 In Section 4.21.5.4 of the ER, Entergy noted that conservative assumptions were used in the 28 seismic analyses, including the use of a single, conservative surrogate element to model the 29 most seismically rugged components, the assumption that redundant components are 30 completely correlated in determining the probability of seismic-induced failure, and the 31 assumption that seismic-induced ATWS events are not recoverable. For purposes of the SAMA 32 evaluation, Entergy performed a reevaluation of the seismic CDF, as discussed below. For IP2, 33 as a result of an IPEEE recommendation, the CCW surge tank hold-down bolts were upgraded.

34 This effectively eliminated the contribution from the failure of the CCW surge tank, reducing the 35 seismic CDF for IP2 from 1.46x10-5 per year to approximately 1.06x10-5 per year. For IP3, no 36 seismic improvements were recommended. However, Entergy reevaluated the seismic PSA to 37 reflect updated random component failure probabilities and to model recovery of onsite power 38 and local operation of the turbine-driven AFW pump. This reduced the seismic CDF for IP3 39 from 4.4x10-5 per year to 2.65x10-5 per year. These reduced CDF values were used in 40 developing the external events multipliers in the SAMA benefit analysis, as discussed later.

Draft NUREG-1437, Supplement 38 G-10 December 2008

Appendix G 1 Table G-4a. IP2 Seismic Scenarios and Their Contribution to Seismic CDF CDF (per year)

Seismic Scenario Description Percent Frequency Contribution failure of CCW, primarily caused by failure of surge tank hold- 4.2x10-6 29 down bolts failure of the turbine building frame and consequential failure of 3.5x10-6 24 control building collapse of IP1 super heater stack onto control building 3.0x10-6 21 loss of 480 V emergency power 1.3x10-6 9 loss of service water (seismic failure of service water pumps) 1.3x10-6 9 seismic-induced loss of offsite power 4.4x10-7 3 Other 7.4x10-7 5 Total Seismic CDF from Dominant Scenarios 1.46x10-5 100 2 Table G-4b IP3 Seismic Scenarios and Their Contribution to Seismic CDF CDF (per year)

Seismic Scenario Description Percent Frequency Contribution loss of 480-V ac electric power with consequential RCP seal 1.9x10-5 43 LOCA loss of CCW with consequential RCP seal LOCA 1.0x10-5 23 loss of offsite power with seismic failures of the RHR heat 9.2x10-6 21 exchangers, the condensate stage tank, containment instrument racks, and AFW surrogate element (represents screened out, rugged 3.5x10-6 8 components and structures, where failure leads to core damage) seismic-induced ATWS 2.2x10-6 5 Total Seismic CDF from Dominant Scenarios 4.4x10-5 100 December 2008 G-11 Draft NUREG-1437, Supplement 38

Appendix G 1 The IPEEE fire analyses employed a combination of PRA with the EPRIs fire-induced 2 vulnerability evaluation methodology. The evaluation was performed in four phases:

3 (1) qualitative screening 4 (2) quantitative screening 5 (3) fire damage evaluation screening 6 (4) fire scenario evaluation and quantification 7 Each phase focused on those fire areas that did not screen out in the prior phases. The final 8 phase involved using the IPE model for internal events to quantify the CDF resulting from a fire-9 initiating event. Each fire area that remained after screening was then treated as a separate 10 initiating event and was propagated through the model with the appropriate model modifications, 11 as necessary. The CDF for each area was obtained by accounting for the frequency of a fire in 12 a given fire area; the conditional core damage probability associated with that fire scenario in 13 the fire area, including, where appropriate, the impact of fire suppression; and fire propagation.

14 The potential impact on containment performance and isolation was evaluated following the 15 core damage evaluation. The total fire CDF from the IPEEE was estimated to be 1.8x10-5 per 16 year for IP2 (Con Ed 1995) and 5.6x10-5 per year for IP3 (NYPA 1997).

17 In Section 4.21.5.4 of the ER, Entergy noted that conservative assumptions were used in the 18 IPEEE fire analyses, including overestimation of the frequency and severity of fires; 19 conservative treatment of open, hot short, and short-to-ground circuits; and assumption of a 20 plant trip for all fires. For purposes of the SAMA evaluation, Entergy performed a reevaluation 21 of the fire CDF, as discussed below.

22

• For IP2, Section E.1.3.2 of the ER notes that the IP2 IPEEE fire model had the following 23 known conservatisms:

24

• The main feedwater and condensate systems were assumed to be unavailable in all 25 scenarios, even when their power source was not affected by the fire scenario.

26

• The pressurizer PORV block valves were assumed to be in the limiting position (open or 27 closed) to maximize the impact of the fire.

28

• All sequences involving RCP seal LOCAs were assumed to lead to complete seal 29 failure.

30 For the purpose of the SAMA evaluation, Entergy reevaluated the dominant IPEEE fire 31 sequences (sequences with CDF contributions greater than 1x10-7 per year) to reduce the 32 conservatisms associated with main feedwater and condensate unavailability and PORV block 33 valve assumptions and to reflect updated modeling associated with RCP-seal LOCAs. In 34 response to a RAI, Entergy explained that other portions of the fire analysis methodology and 35 modeling were not revised as part of the SAMA update. Entergy also noted that preliminary fire 36 analysis results were inadvertently included in the ER and provided a corrected, revised IP2 fire 37 CDF value of 8.4x10-6 per reactor year (Entergy 2008a). These revised results are included in 38 Table G-5a and were used in developing the external events multiplier in the SAMA benefit 39 analysis.

40 Similarly, for IP3, Section E.3.3.2 of the ER notes that the IP3 IPEEE fire model had known 41 conservatisms in estimating the fire ignition frequency (e.g., an air compressor ignition Draft NUREG-1437, Supplement 38 G-12 December 2008

Appendix G 1 frequency did not take into account that the compressor would operate only for a total of about 2 5 days per year). Also, at the time of IPEEE, the automatic suppression systems in some plant 3 areas were placed in manual mode because of concerns with seismic interactions.

4 Subsequently, some fire suppression systems were extensively modified so that the 5 suppression mode could have been returned to automatic. As part of the update for the 6 purpose of SAMA evaluations, Entergy performed a reanalysis of the fire CDF and provided a 7 revised IP3 fire CDF value of 2.55x10-5 per year (Entergy 2007). These revised results are 8 included in Table G-5b and were used to develop the external events multiplier in the SAMA 9 benefit analysis.

10 Table G-5a. IP2 Fire Areas and Their Contribution to Fire CDF CDF (per year)

Fire Area Area Description IPEEE Fire Reanalysis 1A electrical tunnel/pipe penetration area 9.2x10-7 6.6x10-7 2A primary water makeup area 1.1x10-6 5.1x10-7 11 cable spreading room 4.3x10-6 2.0x10-6 14 switchgear room 3.8x10-6 1.4x10-6 15 Control room 7.1x10-6 3.0x10-6 74A electrical penetration area 1.1x10-6 7.3x10-7 6A Drumming and storage station 1.5x10-9 1.5x10-9 32A cable tunnel 9.6x10-8 9.6x10-8 1 CCW pump room 2.2x10-9 2.2x10-9 22/63A Service water intake 7.5x10-9 7.5x10-9 23 AFW pump room 6.2x10-9 6.2x10-9 Total Fire CDF from Major Fire Areas 1.8x10-5 8.4x10-6 11 Table G-5b. IP3 Fire Areas and Their Contribution to Fire CDF CDF (per year)

Fire Area Area Description IPEEE Fire Reanalysis 14 480-V switchgear room 3.5x10-5 1.3x10-5

-6 11 cable spreading room 6.8x10 5.3x10-6

-6 15 Control room 3.7x10 3.7x10-6 480-V switchgear room/south turbine 14/37A 4.5x10-6 1.8x10-7 building 10 diesel generator 31 2.1x10-6 2.0x10-6 102A diesel generator 33 1.9x10-6 4.7x10-9 60A upper electrical tunnel 7.1x10-7 7.1x10-7 101A diesel generator 32 3.4x10-7 5.2x10-9 7A lower electrical tunnel 2.8x10-7 2.8x10-7 December 2008 G-13 Draft NUREG-1437, Supplement 38

Appendix G 1 Table G-5b (continued)

CDF (per year)

Fire Area Area Description IPEEE Fire Reanalysis 23 AFW pump room 2.3x10-7 2.3x10-7

-8 37A south turbine building elevation 15 ft 3.8x10 3.8x10-8

-8 17A primary auxiliary building (PAB) corridor 3.2x10 3.2x10-8

-5 Total Fire CDF from Major Fire Areas 5.6x10 2.6x10-5 2 For high-wind and tornado events, the ER noted that IP2 structures and systems predate the 3 1975 Standard Review Plan (SRP) criteria. Therefore, a detailed PRA was developed as part of 4 the IPEEE analysis to address the impact of high-wind events at IP2. The equipment of 5 concern includes that located within sheet metal clad structures (e.g., the gas turbine and AFW 6 components) and equipment in the yard, including the condensate storage tank (CST) and 7 service water pumps. The CDF for high-wind events was estimated in the IPEEE to be 8 3.03x10-5 per year. In Section E.1.3.3.1 and E.1.4.3 of the ER, Entergy noted that its planned 9 removal of the gas turbines from service would reduce the probability of recovering power from 10 the offsite gas turbine location (as modeled in the PRA), but as shown by a sensitivity analysis 11 this impact would be offset by the increased reliability and ruggedness of the new IP2 12 SBO/Appendix R diesel generator relative to that of the gas turbines. Accordingly, Entergy used 13 the IPEEE high-wind CDF of 3.03x10-5 per year in determining the external event multiplier for 14 IP2, as discussed later.

15 The IP3 structures and systems also predate the SRP criteria, but the IPEEE found the 16 estimated CDF for high-wind events to be below the 10-6 per year screening criterion (from 17 NUREG-1407). This conclusion is based in part on the assumption that high water levels are 18 maintained in the condensate storage and city water storage tank, thus preventing significant 19 wind load and pressure differential damage to the tanks that provide water to the AFW system 20 (NYPA 1997). Because of the low CDF value, the IP3 external-event multiplier does not 21 explicitly account for risks associated with high-wind and tornado events.

22 The IP2 and IP3 IPEEE submittals examined a number of other external hazards, including 23 external flooding, ice formation, and accidents involving hazardous chemicals, transportation 24 (e.g., accidental aircraft impacts), or nearby industrial facilities. These evaluations followed the 25 screening and evaluation approaches specified in Supplement 4 to GL 88-20 (NRC 1991). No 26 risks to the plant from external floods, ice formation, or accidents involving hazardous 27 chemicals, transportation, or nearby facilities, were identified that might lead to core damage 28 with a predicted frequency in excess of 10-6 per year (Con Ed 1995 and NYPA 1997). For IP3, 29 scenarios involving hydrogen explosions within the turbine building, the pipe trench between the 30 PAB and containment, the hydrogen shed area in the containment access facility, and the pipe 31 chase on the 73-ft elevation of the northeast corner of the PAB were identified that, in total, 32 could result in core damage with an estimated frequency slightly above 10-6 per year. As a 33 result, Phase II SAMA 53 was identified to evaluate the change in plant risk from plant 34 modifications to install an excess flow valve to reduce the risk associated with hydrogen 35 explosions inside the turbine building or PAB. Entergy noted that the risks from deliberate 36 aircraft impacts were explicitly excluded, since this was being considered in other forums, along 37 with other sources of sabotage.

Draft NUREG-1437, Supplement 38 G-14 December 2008

Appendix G 1 Based on the aforementioned results, Entergy estimated that the external event CDF is 2 approximately 2.8 and 4.52 times that of the internal-event CDF for IP2 and IP3, respectively.

3 For IP2, this factor was based on an internal event CDF of 1.79x10-5 per year, a seismic CDF of 4 1.06x10-5 per year, a fire CDF of 8.4x10-6 per year, and a high-wind CDF contribution of 5 3.03x10-5 per year. For IP3, this factor was based on an internal-event CDF of 1.15x10-5 per 6 year, a seismic CDF of 2.65x10-5 per year, and a fire CDF of 2.55x10-5 per year. Accordingly, 7 the total CDF from internal and external events would be approximately 3.8 times the internal-8 event CDF for IP2 and 5.5 times the internal event CDF for IP3.

9 In the SAMA analysis submitted in the ER, Entergy increased the benefit that was derived from 10 the internal-event model by a factor 3.8 and 5.5 to account for the combined contribution from 11 internal and external events for IP2 and IP3, respectively. For SAMA candidates that address 12 only a specific external event and have no bearing on internal-event risk (e.g., IP2 SAMA 66 13 Harden EDG Building Against High Winds), Entergy derived the benefit directly from the 14 external-event risk model and then increased the benefit by the multipliers identified earlier.

15 This resulted in a bounding benefit for the SAMA candidates addressing a specific external 16 event. The NRC staff agrees with the licensees overall conclusion concerning the impact of 17 external events and concludes that the licensees use of a multiplier of 3.8 and 5.5 for IP2 and 18 IP3, respectively, to account for external events is reasonable for the purposes of the SAMA 19 evaluation. This is discussed further in Section G.6.2.

20 The NRC staff reviewed both the general process used by Entergy to translate the results of the 21 Level 1 PSA into containment releases and the results of the Level 2 analysis, as described in 22 the ER and in response to the NRC staff RAIs (Entergy 2007 and 2008a). The containment 23 designs and the Level 2 analyses are similar for IP2 and IP3. The NRC staff notes that, after 24 reviewing information provided by Entergy, the current Level 2 PSA models are based on the 25 IPE models, with updates to reflect changes to the plant and modeling techniques, including a 26 3.3 percent and 4.8 percent power uprate for IP2 and IP3, respectively; inclusion of additional 27 PDSs to improve the Level 1-Level 2 PSA interface; and updated accident progression and 28 source term analyses using a later version of the MAAP computer code.

29 The Level 1 core damage sequences are placed into one of 57 PDS bins that provide the 30 interface between the Level 1 and Level 2 analyses. The PDSs are defined by a set of 31 functional characteristics for system operation that are important to accident progression, 32 containment failure, and source-term definition. The Level 2 models use a single CET with 33 functional nodes representing both systemic and phenomenological events. The CET is used to 34 determine the appropriate release category for each Level 2 sequence. CET nodes are 35 evaluated using supporting fault trees and logic rules.

36 Entergy characterized the releases for the spectrum of possible radionuclide release scenarios 37 using a set of nine release categories, defined based on the timing and magnitude of the 38 release and whether the containment remains intact, fails, or is bypassed. The frequency of 39 each release category was obtained by summing the frequency of the individual accident 40 progression CET endpoints binned into the release category. The release characteristics for 41 each category were obtained by frequency weighting the release characteristics for each CET 42 endstate contributing to the release category. The source-term release fractions for the CET 43 endstates were estimated based on the results of plant-specific analyses of the dominant CET 44 scenarios using the MAAP (Version 4.04) computer program. The release categories and their 45 frequencies and release characteristics are presented in Tables E.1-10 and E.3-10 of the ER.

December 2008 G-15 Draft NUREG-1437, Supplement 38

Appendix G 1 During the review of the Level 2 analysis, the NRC staff could not determine the modeling 2 approach used to assess the likelihood of a thermally induced SGTR (TI-SGTR) following core 3 damage in the current IP2 and IP3 PSAs. Entergy explained that TI-SGTR events are 4 considered in the Level 2 analyses for two conditions:

5 (1) high reactor cooling system (RCS) pressure and steam generators dry (no secondary-6 side cooling) 7 (2) high RCS pressure and steam generators initially dry, with recovery of secondary-side 8 cooling before challenging the steam generator tubes 9 The first condition applies to transient event sequences in which RCS pressure is at the 10 pressurizer PORV setpoint at the time of core damage. No credit is taken for recovery of 11 secondary-side cooling in these sequences. Entergy states that a TI-SGTR probability of 0.01 12 is used for this case, based on Table 2-1 of NUREG/CR-4551, Volume 2, Revision 1, Part 1, 13 which shows a distribution that ranges from 10-5 to 0.1208 and a mean value of 0.018. The 14 second condition applies to SBO sequences in which RCS pressure is at the pressurizer PORV 15 setpoint at the time of core damage. Entergy states that a TI-SGTR probability of 5x10-4 is used 16 for this SBO case, based on the expectation that the steam generators will not dry out until after 17 battery depletion and that secondary-side cooling and other mitigating system functions could 18 be recovered before that time. The value is stated as being derived from the transient case 19 value of 0.01 combined with the human error probability of 5.2x10-2 for failure to align AFW 20 following ac power recovery. Entergy explained that a stuck-open main steam safety valve or 21 other secondary-side depressurization event is required to create the large differential pressure 22 needed for the conditional TI-SGTR probabilities assumed above and that the Level 2 analyses 23 conservatively did not account for the probability that these additional failures do not occur 24 (Entergy 2008b). A sensitivity analysis that increases the probability of the TI-SGTR was 25 developed at the staffs request and is described in Section G.6.2.

26 The NRC staffs reviews of the Level 2 IPEs for IP2 and IP3 concluded that the analyses 27 addressed the most important severe accident phenomena normally associated with large dry 28 containments and identified no significant problems or errors (NRC 1995 and 1996). It should 29 be noted, however, that the current Level 2 models are revisions to those of the IPE. The Level 30 2 PSA models were included in the WOG peer reviews mentioned previously. The changes to 31 the Level 2 models to update the methodology and to address the peer review 32 recommendations are described in Sections E.1.4 and E.3.4 of the ER (Entergy 2007) and in 33 response to an RAI concerning peer review findings related to the Level 2 PSA model (Entergy 34 2008a).

35 In the RAI response, Entergy provided a detailed discussion of all the changes that resulted 36 from the incorporation of the WOG peer review of the Level 2 PRA. For IP2, the licensee 37 indicated that there were two Level C F&Os related to the Level 2 analysis. One issue dealt 38 with treatment of containment failure from energetic events (e.g., direct containment heating, 39 hydrogen combustion, in-vessel steam explosions, and ex-vessel steam explosions). The other 40 issue related to treatment of a stuck-open main steam safety valve following an SGTR core 41 damage event. Entergy indicated that all peer review recommendations associated with the 42 WOG review were incorporated in Revision 0 of the IP2 PSA (3/2005).

43 For IP3, Entergy indicated that there were six F&Os from the WOG peer review team related to 44 the Level 2 analysis:

Draft NUREG-1437, Supplement 38 G-16 December 2008

Appendix G 1

• One F&O was related to the containment strength that was considered for a plant-2 specific containment structural analysis.

3

• One Level A F&O recommended that the LERF definition include the release of iodine 4 as well as cesium and tellurium.

5

• Two Level B F&Os were related to justification for the value used for ex-vessel 6 explosions, and an overestimation of the Alpha mode-induced containment failure 7 probability.

8

• One Level C F&O recommended crediting repair and recovery of systems that affect 9 containment performance.

10

• One Level D F&O was related to documentation.

11 Entergy indicated that all Level A and B F&Os were resolved and that changes were 12 incorporated as necessary in Revision 1 of the IP3 PSA (6/2001). Entergy also stated that the 13 Level C and D F&Os were addressed, as appropriate, in the next revision of the model 14 (Revision 2, 2/2007).

15 Based on the NRC staffs review of the Level 2 methodology, the fact that the Level 2 model 16 was reviewed in more detail as part of the WOG peer review and updated to address peer 17 review findings, and Entergys responses to the RAIs, the NRC staff concludes that the Level 2 18 PSAs for IP2 and IP3 are technically sound and provide an acceptable basis for evaluating the 19 benefits associated with various SAMAs.

20 As indicated in the ER, the estimated IP2 and IP3 reactor core radionuclide inventories used in 21 the MACCS2 input are based on the current core configuration and a power level of 3216 22 megawatt thermal (MWt). The information was derived from Westinghouse Electric Company, 23 Core Radiation Sources to Support IP2 and IP3 2 Power Uprate Project, and Westinghouse 24 Electric Company, Core Radiation Sources to Support IP2 and IP3 3 Stretch Power Uprate 25 (SPU) Project, CN-REA-03-40 (3/7/2005). In response to an RAI, Entergy confirmed that the 26 current core design and operational practice are consistent with this analysis and that there are 27 no planned future changes to reactor power level or fuel management strategies that would 28 affect the reactor core radionuclide inventory used in the MACCS2 analysis (Entergy 2008a).

29 The NRC staff reviewed the process used by Entergy to extend the containment performance 30 (Level 2) portion of the PSA to an assessment of offsite consequences (essentially a Level 3 31 PSA). This included consideration of the source terms used to characterize fission product 32 releases for the applicable containment release categories and the major input assumptions 33 used in the offsite consequence analyses. The MACCS2 code was used to estimate offsite 34 consequences. Plant-specific input to the code includes the source terms for each release 35 category and the reactor core radionuclide inventory (both discussed above), site-specific 36 meteorological data, projected population distribution within an 80-kilometer (50-mile) radius for 37 the year 2035, emergency evacuation modeling, and economic data. This information is 38 provided in Sections E.1.5 and E.3.5 of the ER for IP2 and IP3, respectively (Entergy 2007).

39 Entergy used site-specific meteorological data for the 5 years, 2000 through 2004, as input to 40 the MACCS2 code. Entergy averaged the data over this interval for this study. The 5-year data 41 included 43,848 consecutive hourly values of windspeed, wind direction, precipitation, and 42 temperature recorded at the IP2 and IP3 meteorological tower from January 2000 to December 2008 G-17 Draft NUREG-1437, Supplement 38

Appendix G 1 December 2004. Missing data were estimated using data substitution methods. These 2 methods include substitution of missing data with valid data from the previous hour and 3 substitution of valid data collected from other elevations on the meteorological tower. The NRC 4 staff notes that previous SAMA analyses have shown little sensitivity to year-to-year differences 5 in meteorological data and concludes that the approach taken for collecting and applying the 6 meteorological data in the SAMA analysis is reasonable.

7 The population distribution the licensee used as input to the MACCS2 analysis was estimated 8 for the year 2035 based on information from the New York Statistical Information System from 9 2000 to 2030, the New Jersey Department of Labor and Workforce Development from 2000 to 10 2025, the Connecticut State Data Center from 2000 to 2020, and the Pennsylvania State Data 11 Center from 2000 to 2020. These data were used to project county-level resident populations to 12 the year 2035 using regression analysis. The 2035 transient population was assumed to be the 13 2004 transient-to-permanent population ratio multiplied by the extrapolated permanent 14 population. The 2004 transient data were obtained from State tourism agencies. The NRC staff 15 notes that Entergys projected 2035 population within a 50-mile radius of IP2 and IP3 reported in 16 Tables E.1-12 and E.3-12 of the Entergy ER (19.2 million people) is approximately 15 percent 17 greater than the 50-mile population obtained from NRC SECPOP2000 code (16.8 million) for 18 the year 2003 (NRC 2003). This represents an average annual growth rate of 0.4 percent, 19 which comports with Entergys estimated growth rates reported in section 2.6.1 of the Entergy 20 ER. The NRC staff considers the methods and assumptions for estimating population 21 reasonable and acceptable for the purposes of the SAMA evaluation.

22 Entergy did not credit evacuation either as part of the base-case analysis or for estimating the 23 benefit from SAMA cases. Entergy assumed a no evacuation scenario to conservatively 24 estimate the population dose. In response to a RAI, Entergy clarified that the no evacuation 25 scenario assumes that individuals within the 10-mile evacuation zone continue normal activity 26 following a postulated accident without taking emergency response actions such as evacuation 27 or sheltering. Relocation actions within a 50-mile radius of the plant are still modeled in the no 28 evacuation scenario. As such, individuals within hot spots or high-radiation areas anywhere 29 within the 50-mile zone are assumed to be relocated outside the 50-mile zone until long-term 30 protective actions reduce radiation levels (Entergy 2008a). As used in the MACCS2 code, 31 evacuation refers to the prompt movement of the population out of an affected region (e.g.,

32 certain sectors of the EPZ) during the emergency-phase time period immediately following an 33 accident, in accordance with the emergency evacuation plan. Relocation refers to the 34 movement of the population out of an affected region (e.g., within hot spots or high radiation 35 areas) during the intermediate phase or long term phase based on longer-term dose 36 considerations. The NRC staff concludes that the evacuation and relocation assumptions and 37 analysis are generally conservative and acceptable for the purposes of the SAMA evaluation.

38 Much of the site-specific economic data was obtained from the 2002 Census of Agriculture 39 (USDA 2002). These include the value of farm and nonfarm wealth. Other data, such as 40 population relocation cost, daily cost for a person who is relocated, and cost of farm and 41 nonfarm decontamination were obtained from the Code Manual for MACCS2 (NRC 1997c).

42 The data from the MACCS2 Code Manual were inflation-adjusted using the consumer price 43 index corresponding to the year 2005. Information on regional crops was obtained from the 44 2002 Census of Agriculture. Crops for each county were mapped into the seven MACCS2 crop 45 categories.

Draft NUREG-1437, Supplement 38 G-18 December 2008

Appendix G 1 MACCS2 requires an average value of nonfarm wealth (identified as VALWNF in MACCS2).

2 The county-level nonfarm property value was used as a basis for deriving VALWNF and 3 resulted in a value of $163,631 per person. This does not explicitly account for the economic 4 value associated with tourism and business. In the ER, Entergy assessed the impact of 5 including tourism and business losses using a sensitivity case. This sensitivity case assumed a 6 loss of $208,838 per person in the affected region, as opposed to $163,631 per person in the 7 base case. The NRC staff questioned the basis for the modified VALWNF value ($208,838 per 8 person) and the rationale for treating the loss of tourism and business in a sensitivity case rather 9 than in the baseline analysis (NRC 2007). In response, Entergy described the basis for the 10 modified VALWNF value and explained that the impact of lost tourism and business was not 11 modeled in the baseline analysis because the level of tourism and business activity can be 12 reestablished in time. Nevertheless, Entergy provided the results of a revised uncertainty 13 analysis using the modified VALWNF value (Entergy 2008a). As a result, three additional 14 potentially cost-beneficial SAMAs were identified (SAMAs 9 and 53 for IP2 and SAMA 53 for 15 IP3). In response to an RAI, Entergy indicated that these SAMAs have been submitted for 16 engineering project cost-benefit analysis to obtain a more detailed examination of their viability 17 and implementation costs (Entergy 2008b). As described in Section G.6.2, the NRC staff has 18 adopted the case incorporating lost tourism and business as its base case, given that it may 19 take years to re-establish the level of tourism and business activity following a severe accident.

20 The NRC staff concludes that the methodology used by Entergy to estimate the offsite 21 consequences for IP2 and IP3 provides an acceptable basis from which to proceed with an 22 assessment of the risk reduction potential for candidate SAMAs because the key elements of 23 the methodology are consistent with standard practice. Accordingly, the NRC staff based its 24 assessment of offsite risk on the CDF and offsite doses reported by Entergy.

25 G.3 Potential Plant Improvements 26 This section discusses the process for identifying potential plant improvements, an evaluation of 27 that process, and the improvements evaluated in detail by Entergy.

28 G.3.1. Process for Identifying Potential Plant Improvements 29 Entergys process for identifying potential plant improvements (SAMAs) consisted of the 30 following elements:

31

• review of the most significant basic events from the current, plant-specific PSA 32

• review of potential plant improvements identified in the IP2 and IP3 IPE and IPEEE 33

• review of Phase II SAMAs from license renewal applications for nine other pressurized 34 water reactors 35

• review of dominant contributors to seismic and fire events in the current seismic and fire 36 analyses 37

• review of other NRC and industry documentation discussing potential plant 38 improvements December 2008 G-19 Draft NUREG-1437, Supplement 38

Appendix G 1 Based on this process, an initial set of 231 candidate SAMAs for IP2 and 237 candidate SAMAs 2 for IP3, referred to as Phase I SAMAs, was identified. In Phase I of the evaluation, Entergy 3 performed a qualitative screening of the initial list of SAMAs and eliminated SAMAs from further 4 consideration using one of the following criteria:

5

• The SAMA is not applicable at IP2 and IP3 because of design differences.

6

• The SAMA has already been implemented at IP2 and IP3.

7

• The SAMA is similar in nature and could be combined with another SAMA candidate.

8 Based on this screening, 163 IP2 SAMAs and 175 IP3 SAMAs were eliminated, leaving 68 9 unique SAMAs for IP2 and 62 unique SAMAs for IP3. The remaining SAMAs, referred to as 10 Phase II SAMAs, are listed in Tables E.2-2 and E.4-2 of the ER (Entergy 2007). In Phase II, a 11 detailed evaluation was performed for each of the remaining SAMA candidates, as discussed in 12 Sections G.4 and G.6 below. To account for the potential impact of external events, the 13 estimated benefits based on internal events were multiplied by a factor of 3.8 for IP2 and 5.5 for 14 IP3, as previously discussed.

15 G.3.2. Review of Entergys Process 16 Entergys efforts to identify potential SAMAs focused primarily on areas associated with internal 17 initiating events but also included explicit consideration of potential SAMAs for seismic and fire.

18 The initial list of SAMAs generally addressed the accident sequences considered to be 19 important to CDF from functional, initiating event, and risk-reduction worth (RRW) perspectives 20 at IP2 and IP3 and included selected SAMAs from prior SAMA analyses for other plants.

21 Entergy provided a tabular listing of the PSA basic events, sorted according to their RRW for 22 CDF (Entergy 2007). SAMAs affecting these basic events would have the greatest potential for 23 reducing risk. Entergy used an RRW cutoff of 1.005, which corresponds to about a 0.5-percent 24 change in CDF, given the 100 -percent reliability of the SAMA. This equates to a benefit of 25 approximately $7,000 for IP2 and IP3 (based on a total benefit of about $1.3 million for each unit 26 for eliminating all severe accidents caused by internal events). Entergy also provided and 27 reviewed the LERF-based RRW events down to an RRW of 1.005. Entergy correlated the top 28 CDF and LERF events with the SAMAs evaluated in Phase I or Phase II and showed that, with 29 a few exceptions, all of the significant basic events are addressed by one or more SAMAs 30 (Entergy 2007). Of the basic events of high-risk importance that are not addressed by SAMAs, 31 each is closely tied to other basic events that had been addressed by one or more SAMAs.

32 Entergy considered the potential plant improvements described in the IPE and IPEEE in the 33 identification of plant-specific candidate SAMAs for internal and external events. As a result of 34 the IPE, four major procedural/hardware improvements were identified for each unit. The IP2 35 enhancements are to (1) upgrade IP2 gas turbine black-start capability, (2) install an additional 36 EDG building fan, (3) monitor changes in the operating position of PORV block valves, and (4) 37 implement periodic testing of all the EDG building fans. The IP3 enhancements are to (1) revise 38 emergency operating procedures (EOPs) to instruct operators to align the backup city water 39 supply to the AFW pumps, should the CST outlet valve fail as indicated by a low-suction-flow 40 alarm, (2) revise the alarm response procedure for a high AFW pump room temperature, to 41 direct operators to open the rollup door to the AFW pump room for ventilation, (3) install a 42 switchgear room high-temperature alarm and implement an associated procedure to direct Draft NUREG-1437, Supplement 38 G-20 December 2008

Appendix G 1 operators to block open doors to the 480-V ac switchgear room, and (4) revise EOPs to 2 emphasize the need to align the safe-shutdown equipment to MCC 312A during events 3 involving the loss of all 480-V ac safeguard buses while offsite power is available, as well as 4 during fire-related events. These improvements have all been implemented and therefore were 5 not considered further in the SAMA analysis.

6 As a result of the IPEEEs, several improvements were identified for external events. The IP2 7 enhancements are to (1) replace the hold-down bolts for the CCW surge tank with higher tensile 8 strength bolts, (2) add surveillance of the control building drain flapper valve flow, (3) add 9 weather stripping to doors between the transformer area and the switchgear room, and (4) add 10 screens on the 480-V switchgear room equipment. The IP3 enhancements are to (1) restore 11 the carbon dioxide (CO2) suppression system to automatic mode within the switchgear room, 12 (2) reroute the EDG exhaust fans and the auxiliary cables so that a fire in a single EDG cell 13 would not affect multiple EDGs, and (3) install an excess flow valve to reduce the risk 14 associated with hydrogen explosions inside the turbine building or PAB. With the exception of 15 the last item, all of these improvements have been implemented and therefore were not 16 considered further in the SAMA analysis. As noted in Section E.3.3.3 of the ER, IP3 SAMA 53 17 (install an excess flow valve to reduce the risk associated with hydrogen explosions) was 18 proposed as a result of the IPEEE analysis and retained for the Phase II evaluation.

19 Several concerns were raised in the IPEEE regarding the seismic-induced failures of fire 20 protection equipment (primarily for IP3). As mentioned above, these seismic-fire interactions 21 were judged to be of little risk significance (NRC 2001). One plant improvement identified in 22 Table 2.4 of NUREG-1742 (NRC 2002) addressed the potential spurious operation of the EDG 23 rooms CO2 system and subsequent shutdown of the EDG ventilation system during a seismic 24 event. Entergy subsequently installed a quality assurance Category I, seismic class I actuation 25 permission auxiliary control panel for CO2 discharge into the EDG building. Since shutdown of 26 EDG ventilation caused by spurious operation of the CO2 system during a seismic event is not 27 considered in the seismic PSA model, the seismic CDF was not affected by this modification.

28 As noted in Section E.1.3.3.1 of the ER, the IP2 CDF for SBO events with gas turbines 29 unavailable could be reduced by (1) aligning the IP3 Appendix R diesel to IP2, (2) installing an 30 IP2 Appendix R diesel, (3) upgrading the EDG building for high winds, and (4) protecting the 31 alternate power source from tornadoes and high winds. However, with the exception of the third 32 item, these modifications were not evaluated as candidate SAMAs because a modification to 33 replace the existing gas turbines with an IP2 SBO/Appendix R diesel generator capable of being 34 used to recover power to the vital buses following an SBO is planned for the near future. The 35 planned modification includes provisions for aligning the IP3 Appendix R generator to IP2 and 36 for protecting the new alternate power source from tornadoes and high winds.

37 For a number of the Phase II SAMAs listed in the ER, the NRC staff found that information 38 provided did not sufficiently describe the proposed modifications or other considerations that 39 might have been taken into account in estimating the benefit and implementation cost.

40 Therefore, the NRC staff requested, and the licensee provided, more information on certain 41 proposed modifications listed for the Phase II SAMA candidates (NRC 2007, Entergy 2008a).

42 For several SAMA candidates, the staff questioned if lower cost alternatives could have been 43 considered, including:

December 2008 G-21 Draft NUREG-1437, Supplement 38

Appendix G 1

• the implementation of improved instrumentation and procedures to help cool down and 2 depressurize the RCS before RWST depletion 3

• the implementation of a procedure for recovery of steam dump to condenser from the 4 unaffected steam generator 5

• the implementation of a procedure for recovery of the main feedwater valve/condensate 6 post-SI actuation 7

• the purchase or manufacture of a gagging device that could be used to close a stuck-8 open steam generator safety value on an SGTR before core damage occurred 9

• The reactivation of the IP3 postaccident containment venting system (a system that is 10 still active on IP2 but was deactivated on IP3) 11 In response, Entergy indicated that most of the low-cost alternatives to aid in the mitigation of an 12 SGTR (4 out of the 5 alternatives dismissed above) have been already implemented and 13 provided specific reasons why the cost of these alternative SAMA candidates would be high 14 enough that the decision on the final SAMA selection would not have been affected. However, 15 the alternative associated with the gagging device was found to be potentially cost beneficial 16 (Entergy 2008a and 2008b). The evaluation of these SAMAs is discussed further in Section 17 G.6.2.

18 The NRC staff notes that the set of SAMAs submitted is not all inclusive, since additional, 19 possibly even less expensive, design alternatives can always be postulated. However, the NRC 20 staff concludes that the benefits of any additional modifications are unlikely to exceed the 21 benefits of the modifications evaluated and that the alternative improvements would not likely 22 cost less than the least expensive alternatives evaluated, when the subsidiary costs associated 23 with maintenance, procedures, and training are considered.

24 The NRC staff concludes that Entergy used a systematic and comprehensive process for 25 identifying potential plant improvements for IP2 and IP3 and that the set of SAMAs evaluated in 26 the ER, together with those identified in response to the NRC staff inquiries, is reasonably 27 comprehensive and therefore acceptable. The search included reviewing insights from the 28 plant-specific risk studies and reviewing plant improvements considered in previous SAMA 29 analyses. While explicit treatment of external events in the SAMA identification process was 30 limited, the NRC staff recognizes that the prior implementation of plant modifications for seismic 31 and fire events, and the absence of external-event vulnerabilities, reasonably justifies examining 32 primarily the internal-event risk results for this purpose.

33 G.4 Risk-Reduction Potential of Plant Improvements 34 Entergy evaluated the risk-reduction potential of the remaining 68 IP2 and 62 IP3 SAMAs. The 35 SAMA evaluations were performed using realistic assumptions with some conservatism. On 36 balance, such calculations overestimate the benefits and are conservative.

37 For all of the SAMAs, Entergy used model requantification to determine the potential benefits.

38 The CDF and population-dose reductions were estimated using the latest version of the IP2 and 39 IP3 PSA models. The changes made to the models to quantify the impact of the SAMAs are 40 detailed in Tables E.2-2 and E.4-2 of the ER (Entergy 2007). Table G-6 lists the assumptions Draft NUREG-1437, Supplement 38 G-22 December 2008

Appendix G 1 considered to estimate the risk reduction for each of the evaluated SAMAs, the estimated risk 2 reduction in terms of the percentage of reduction in CDF and population dose, and the 3 estimated total benefit (present value) of the averted risk. The estimated benefits reported in 4 Table G-6 reflect the combined benefit for both internal and external events. The determination 5 of the benefits for the various SAMAs is further discussed in Section G.6.

6 The NRC staff questioned the assumptions used in evaluating the benefits or risk-reduction 7 estimates of a number of SAMAs provided in the ER (NRC 2007). For example, the NRC staff 8 requested information regarding the plant features or modeling assumptions that result in the 9 CCW pumps having limited risk importance. In response, Entergy stated that both units are 10 unique in that the capability exists to initiate backup cooling to key components in the event the 11 primary CCW cooling function is lost. The use of backup city water cooling to the charging 12 pumps enables continued seal injection and therefore reduces the likelihood of an RCP seal 13 LOCA. In IP2, city water backup or primary water can be used to cool the safety injection and 14 residual heat removal (RHR) pumps. In IP3, city water backup is available to cool RHR 15 Pump 31. Also, CCW is not required in either plant during the injection phase of the response 16 to a LOCA. The NRC staff considers the explanation of the plant features, as clarified, to be 17 reasonable and therefore acceptable for the purposes of the SAMA evaluation.

18 For a number of the Phase II SAMAs listed in the ER, the description of the improvement and 19 the associated analyses appeared either inconsistent between the two units or were unclear.

20 Therefore, the NRC staff asked the applicant to provide more detailed descriptions of the 21 modifications for several of the Phase II SAMA candidates (NRC 2007). In response, Entergy 22 provided additional information on those SAMA candidates that further explained the SAMA 23 modifications and the differences between units that account for the different analysis 24 assumptions for each unit (Entergy 2008a). Entergy also provided further clarifications and 25 discussion regarding the analysis assumptions and their bases. As an example, the licensee 26 clarified a major difference in operation of a turbine-driven AFW pump between the two units 27 that affects the disposition of several SAMA candidates. In its response, Entergy indicated that 28 the units respond differently upon depletion of the station batteries. IP2 has pneumatic level 29 and pressure instruments that allow operators to monitor key parameters and effectively control 30 AFW flow after the batteries are depleted, whereas IP3 does not have this instrumentation.

31 Although it is still possible for the operators to manipulate AFW flow, the current IP3 model does 32 not credit this manual operation.

33 In the SAMA analysis submitted in the ER, Entergy increased the benefit that was derived from 34 the internal-event model by factors of 3.8 and 5.5 to account for the combined contribution from 35 internal and external events for IP2 and IP3, respectively. The NRC staff agrees with the 36 licensees overall conclusion concerning the impact of external events and concludes that the 37 licensees use of a multiplier of 3.8 and 5.5 for IP2 and IP3, respectively, to account for external 38 events is reasonable for the purposes of the SAMA evaluation. This is discussed further in 39 Section G.6.2.

40 For SAMA candidates that only address a specific external event and have no bearing on 41 internal-event risk (e.g., IP2 SAMA 66Harden EDG Building Against High Winds), Entergy 42 derived the benefit directly from the external-event risk model and then increased the benefit by 43 the multipliers identified earlier. The NRC staff notes that the use of multipliers for these 44 SAMAs (conceptually, to account for additional benefits in internal events) is unnecessary, since December 2008 G-23 Draft NUREG-1437, Supplement 38

Appendix G 1 these SAMAs have no bearing on internal events. However, use of the multipliers adds 2 conservatism to the benefit estimate for these SAMA candidates.

3 IP3 SAMA 53 (install an excess-flow valve to reduce the risk associated with hydrogen 4 explosions) was identified to reduce the risk associated with hydrogen explosions inside the 5 turbine building or PAB. The proposed plant modification involves the installation of a 6 nonelectric excess-flow valve. The benefit of this SAMA is also calculated in a bounding 7 manner. As discussed in Section G.6.2, this SAMA was found to be potentially cost beneficial, 8 based on revised analyses submitted in response to an NRC request.

9 The NRC staff has reviewed Entergys bases for calculating the risk reduction for the various 10 plant improvements and concludes that the rationale and assumptions for estimating risk 11 reduction are reasonable and generally conservative (i.e., the estimated risk reduction is higher 12 than what would actually be realized). Accordingly, the NRC staff based its estimates of averted 13 risk for the various SAMAs on Entergys risk reduction estimates.

14 G.5 Cost Impacts of Candidate Plant Improvements 15 Entergy estimated the costs of implementing the candidate SAMAs through the application of 16 engineering judgment and use of other licensees estimates for similar improvements. The ER 17 stated that the cost estimates conservatively did not include the cost of replacement power 18 during extended outages required to implement the modifications, nor did they include 19 contingency costs associated with unforeseen implementation obstacles. The cost estimates 20 provided in the ER also did not account for inflation, which is considered another conservatism.

21 The NRC staff reviewed the bases for the licensees cost estimates. For certain improvements, 22 the NRC staff also compared the cost estimates to estimates developed elsewhere for similar 23 improvements, including estimates developed as part of other licensees analyses of SAMAs for 24 operating reactors and advanced light-water reactors. The NRC staff reviewed the costs and 25 found them to be reasonable and generally consistent with estimates provided in support of 26 other licensees analyses.

Draft NUREG-1437, Supplement 38 G-24 December 2008

1 Table G-6. Final Potentially Cost-Beneficial SAMAs for IP2 and IP3 1

% Risk Total Benefit

($)

December 2008 Reduction Cost SAMA Assumptions 2 ($)

Population Baseline (Int Baseline With CDF Dose + Ext Events) Uncertainty IP2 SAMAs 9 - Create a reactor cavity flooding Eliminate containment failure 0 48 1.8M 3.8M 3.7M system. caused by concrete-core interaction.

28 - Provide a portable diesel-driven Eliminate failure of local operation 5 10 441K 928K 494K battery charger. of the turbine-driven AFW pump during SBO scenarios.

44 - Use fire water system as backup Eliminate failure of the turbine- 33 15 1.0M 2.1M 1.7M for steam generator inventory. driven AFW pump and local operation of AFW during SBO.

G-25 53 - Keep both pressurizer PORV Eliminate failure of PORV block 18 4 386K 812K 800K block valves open. valves to open.

54 - Install flood alarm in the 480-V ac Reduce control folding initiator 20 40 1.8M 3.8M 200K switchgear room frequencies by a factor of 3.

56 - Keep RHR heat exchanger Eliminate failure of RHR heat 2 18 45K 94K 82K discharge MOVs normally open. exchanger discharge MOVs to open.

60 - Provide added protection against Eliminate flood initiated by a break 5 9 408K 860K 216K flood propagation from stairwell 4 in fire protection piping in into the 480-V ac switchgear room. stairwell 4.

61 - Provide added protection against Eliminate flood initiated by a break 10 20 898K 1.8M 192K flood propagation from the deluge in the 10 fire protection piping in room into the 480-V ac switchgear the deluge room at elevation 15.

room.

65 - Upgrade the ASSS to allow timely Eliminate control building flooding 20 20 1.8M 3.8M 560K restoration of seal injection and initiators.

cooling.

Appendix G Draft NUREG-1437, Supplement 38

1 Table G-6 (continued)

% Risk Total Benefit Reduction ($) Cost Assumptions 2 ($)

December 2008 SAMA Population Baseline (Int Baseline With CDF Dose + Ext Events) Uncertainty IP3 SAMAs 30 - Provide a portable diesel-driven Reduce internal switchgear room 43 13 100K 3 145K 3 494K battery charger. floods 5% and increase the time available to recover offsite power before local operation of AFW is required from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during SBO scenarios.

52 - Open city water supply valve for Eliminate loss of the normal suction 1 1 71K 103K 50K alternative AFW pump suction. path to the AFW system.

53 - Install an excess flow valve to Eliminate hydrogen ruptures inside 2 2 160K 232K 228K reduce the risk associated with the turbine building.

hydrogen explosions.

G-26 55 - Provide the capability of Eliminate operator failure to align 16 18 1.3M 2.0M 1.3M powering one SI pump or RHR MCC 312A.

pump using the Appendix R bus (MCC 312A).

61 - Upgrade the ASSS to allow timely Eliminate control building flooding 17 20 1.4M 2.1M 560K restoration of seal injection and initiators.

cooling.

62 - Install flood alarm in the 480-V ac Eliminate control building flooding 17 20 1.4M 2.1M 197K switchgear room. initiators.

1 2 The information reproduced by combining the information from ER Tables E.2-2 and E.4-2 and Entergys response to RAI 4e 3 (Entergy 2008a).

2 4 Reported benefit values account for risk reduction in both internal and external events and include the economic impact of lost 5 tourism and business following a severe accident. The values do not account for analysis uncertainties.

3 6 SAMA 30 was identified as cost beneficial in the ER. However, an error in the original benefit calculation was discovered 7 subsequent to the ER, as described in Entergys response to RAI 5g (Entergy 2008a). Reported values in Table G-6 reflect 8 correction of the calculational error. SAMA 30 is no longer cost beneficial after corrections.

Draft NUREG-1437, Supplement 38 Appendix G

Appendix G 1 The NRC staff questioned the high cost estimate ($800,000) for changing the pressurizer PORV 2 block valves from normally closed to normally open in conjunction with IP2 SAMA 53 (NRC 3 2008a). In response, Entergy clarified that a modification had been previously implemented 4 allowing closure of the block valves when operating pressure is less than 2235 pounds per 5 square inch gauge (psig). If the reactor coolant pressure increases to 2300 psig, the current 6 circuitry alarms and sends a signal to open the block valves. The SAMA would reverse this 7 operating approach and may require adding or changing the auto-open feature to a lower value.

8 Entergy provided a breakdown of the estimated cost, which included a $236,000 contingency 9 cost. As Section 4.21 of the ER states that contingency costs are excluded, the staff requested 10 clarification of this apparent inconsistency. In response, Entergy stated that the site-specific 11 implementation cost estimates include some contingency costs to account for the high degree of 12 uncertainty associated with the preliminary cost estimates and that, given the bounding nature 13 of the benefit analysis, it is reasonable to include contingency costs in these estimates. To 14 eliminate the confusion between Section 4.21 of the ER and the stated practice above, Entergy 15 revised Section 4.21, eliminating the contingency exclusion clause (Entergy 2008b).

16 Considering that this SAMA has been added to the list of potentially cost-beneficial SAMAs (see 17 Section G.6), the staff finds the cost estimate for SAMA 53 to be acceptable. In addition, no 18 other improvement cost estimates were identified as outliers. Therefore, the impact of including 19 contingency costs does not appear to be consequential.

20 The NRC staff concludes that the cost estimates provided by Entergy are sufficient and 21 appropriate for use in the SAMA evaluation.

22 G.6 Cost-Benefit Comparison 23 Entergys cost-benefit analysis and the NRC staffs review are described in the following 24 sections.

25 G.6.1. Entergys Evaluation 26 The methodology used by Entergy was based primarily on the NRCs guidance for performing a 27 cost-benefit analysis (i.e., NUREG/BR-0184, Regulatory Analysis Technical Evaluation 28 Handbook (NRC 1997a). The guidance involves determining the net value for each SAMA 29 according to the following formula:

30 Net Value = (APE + AOC + AOE + AOSC) - COE, where 31 APE = present value of averted public exposure ($)

32 AOC = present value of averted offsite property damage costs ($)

33 AOE = present value of averted occupational exposure costs ($)

34 AOSC = present value of averted onsite costs ($)

35 COE = cost of enhancement ($)

36 If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the 37 benefit associated with the SAMA, and it is not considered cost beneficial. Entergys derivation 38 of each of the associated costs is summarized below.

December 2008 G-27 Draft NUREG-1437, Supplement 38

Appendix G 1 NUREG/BR-0058 has recently been revised to reflect the agencys policy on discount rates.

2 Revision 4 of NUREG/BR-0058 states that two sets of estimates should be developedone at 3 3 percent and one at 7 percent (NRC 2004). Entergy performed the SAMA analysis using 4 7 percent and provided a sensitivity analysis using the 3 percent discount rate in order to 5 capture SAMAs that may be cost-effective using the lower discount rate, as well as the higher, 6 baseline rate (Entergy 2007). This analysis is sufficient to satisfy NRC policy in Revision 4 of 7 NUREG/BR-0058.

8 Averted Public Exposure (APE) Costs 9 The APE costs were calculated using the following formula:

10 APE = Annual reduction in public exposure (person-rem/year) 11 x monetary equivalent of unit dose ($2000 per person-rem) 12 x present value conversion factor (10.76 based on a 20-year period with 13 a 7 percent discount rate) 14 As stated in NUREG/BR-0184 (NRC 1997a), the monetary value of the public health risk after 15 discounting does not represent the expected reduction in public health risk caused by a single 16 accident. Rather, it is the present value of a stream of potential losses extending over the 17 remaining lifetime (in this case, the renewal period) of the facility. Thus, it reflects the expected 18 annual loss caused by a single accident, the possibility that such an accident could occur at any 19 time over the renewal period, and the effect of discounting these potential future losses to 20 present value. For the purposes of initial screening, which assumes elimination of all severe 21 accidents caused by internal events, Entergy calculated an APE of approximately $474,000 for 22 IP2 and $527,000 for IP3 for the 20-year license renewal period.

23 Averted Offsite Property Damage Costs (AOC) 24 The AOCs were calculated using the following formula:

25 AOC = Annual CDF reduction 26 x offsite economic costs associated with a severe accident (on a per-27 event basis) 28 x present value conversion factor 29 For the purposes of initial screening, which assumes all severe accidents caused by internal 30 events are eliminated, Entergy calculated an annual offsite economic cost of about $45,000 for 31 IP2 and $53,000 for IP3 based on the Level 3 risk analysis. This results in a discounted value 32 of approximately $483,000 for IP2 and $568,000 for IP3 for the 20-year license renewal period.

33 Averted Occupational Exposure (AOE) Costs 34 The AOE costs were calculated using the following formula:

35 AOE = Annual CDF reduction 36 x occupational exposure per core damage event 37 x monetary equivalent of unit dose 38 x present value conversion factor Draft NUREG-1437, Supplement 38 G-28 December 2008

Appendix G 1 Entergy derived the values for AOE from information provided in Section 5.7.3 of the regulatory 2 analysis handbook (NRC 1997a). Best estimate values that provided for immediate 3 occupational dose (3300 person-rem) and long-term occupational dose (20,000 person-rem 4 over a 10-year cleanup period) were used. The present value of these doses was calculated 5 using the equations provided in the handbook, in conjunction with a monetary equivalent of unit 6 dose of $2000 per person-rem, a real discount rate of 7 percent, and a time period of 20 years 7 to represent the license renewal period. For the purposes of initial screening, which assumes 8 all severe accidents caused by internal events are eliminated, Entergy calculated an AOE of 9 approximately $7,000 for IP2 and $4,000 for IP3 for the 20-year license renewal period.

10 Averted Onsite Costs 11 Averted onsite costs (AOSC) include averted cleanup and decontamination costs and averted 12 power replacement costs. Repair and refurbishment costs are considered for recoverable 13 accidents only and not for severe accidents. Entergy derived the values for AOSC based on 14 information provided in Section 5.7.6 of NUREG/BR-0184, the regulatory analysis handbook 15 (NRC 1997a).

16 Entergy divided this cost element into two partsthe onsite cleanup and decontamination cost, 17 also commonly referred to as averted cleanup and decontamination costs (ACC), and the 18 replacement power cost (RPC).

19 ACCs were calculated using the following formula:

20 ACC = Annual CDF reduction 21 x present value of cleanup costs per core damage event 22 x present value conversion factor 23 The total cost of cleanup and decontamination subsequent to a severe accident is estimated in 24 NUREG/BR-0184 to be $1.5x109 (undiscounted). This value was converted to present costs 25 over a 10-year cleanup period and integrated over the term of the proposed license extension.

26 For the purposes of initial screening, which assumes all severe accidents caused by internal 27 events are eliminated, Entergy calculated an ACC of approximately $208,000 for IP2 and 28 $133,000 for IP3 for the 20-year license renewal period.

29 Long-term RPCs were calculated using the following formula:

30 RPC = Annual CDF reduction 31 x present value of replacement power for a single event 32 x factor to account for remaining service years for which replacement 33 power is required 34 x reactor power scaling factor 35 Entergy based its calculations on the value of 1071 megawatt electric (MWe) and scaled up 36 from the 910 MWe reference plant in NUREG/BR-0184 (NRC 1997b). Therefore, Entergy 37 applied a power-scaling factor of 1071/910 to determine the RPCs. For the purposes of initial 38 screening, which assumes all severe accidents caused by internal events are eliminated, 39 Entergy calculated an RPC of approximately $166,000 for IP2 and $107,000 for IP3, and an December 2008 G-29 Draft NUREG-1437, Supplement 38

Appendix G 1 AOSC of approximately $374,000 for IP2 and $240,000 for IP3 for the 20-year license renewal 2 period.

3 Using the above equations, Entergy estimated the total present dollar-value equivalent 4 associated with completely eliminating severe accidents caused by internal events at IP2 and 5 IP3 to be about $1.3 million for each unit. Use of a multiplier of 3.8 for IP2 and 5.5 for IP3 to 6 account for external events increases the value to $5.1 million for IP2 and $7.4 million for IP3 7 and represents the dollar value associated with completely eliminating the risk of severe 8 accidents caused by all internal and external events at IP2 and IP3, respectively.

9 Entergys Results 10 If the implementation costs for a candidate SAMA exceeded the calculated benefit, the SAMA 11 was considered by Entergy not to be cost beneficial. In the baseline analysis (using a 7 percent 12 discount rate) and the sensitivity analysis (using a 3 percent discount rate) contained in the ER, 13 Entergy identified 10 potentially cost-beneficial SAMAs (five for IP2 and five for IP3). Based on 14 consideration of analysis uncertainties, Entergy identified two additional potentially cost-15 beneficial SAMAs for IP2 in the ER (IP2 SAMAs 44 and 56).

16 In response to an NRC staff request, Entergy provided the results of a revised uncertainty 17 analysis in which the impact of lost tourism and business was accounted for in the baseline 18 analysis (rather than as a separate sensitivity case). The revised uncertainty analysis resulted 19 in the identification of two additional potentially cost-beneficial SAMAs for IP2 (IP2 SAMAs 9 20 and 53) and one additional potentially cost-beneficial SAMA for IP3 (IP3 SAMA 53).

21 The potentially cost-beneficial SAMAs for IP2 are the following:

22

• SAMA 9Create a reactor cavity flooding system to reduce the impact of core-concrete 23 interaction from molten core debris following core damage and vessel failure (cost 24 beneficial in revised analysis, with uncertainties).

25

• SAMA 28Provide a portable diesel-driven battery charger to improve dc power 26 reliability. A safety-related disconnect would be used to charge a selected battery. This 27 modification would enhance the long-term operation of the turbine-driven AFW pump on 28 battery depletion.

29

• SAMA 44Use fire water as a backup for steam generator inventory to increase the 30 availability of the steam generator water supply to ensure adequate inventory for the 31 operation of the turbine-driven AFW pump during SBO events (cost beneficial with 32 uncertainties).

33

• SAMA 53Keep both pressurizer PORV block valves open. This modification would 34 reduce the CDF contribution from loss of secondary heat sink by improving the 35 availability of feed and bleed (cost beneficial in revised analysis, with uncertainties).

36

• SAMA 54Install a flood alarm in the 480-V ac switchgear room to mitigate the 37 occurrence of internal floods inside the 480-V ac switchgear room.

38

• SAMA 56Keep RHR heat exchanger discharge valves, motor-operated valves 746 39 and 747, normally open. This procedure change would reduce the CDF contribution from 40 transients and LOCAs (cost beneficial with uncertainties).

Draft NUREG-1437, Supplement 38 G-30 December 2008

Appendix G 1

• SAMA 60Provide added protection against flood propagation from stairwell 4 into the 2 480-V ac switchgear room to reduce the CDF contribution from flood sources within 3 stairwell 4 adjacent to the 480-V ac switchgear room.

4

• SAMA 61Provide added protection against flood propagation from the deluge room 5 into the 480-V ac switchgear room to reduce the CDF contribution from flood sources 6 within the deluge room adjacent to the 480-V ac switchgear room.

7

• SAMA 65Upgrade the alternate safe shutdown system (ASSS) to allow timely 8 restoration of RCP-seal injection and cooling from events that cause a loss of power 9 from the 480-V ac vital buses.

10 The potentially cost-beneficial SAMAs for IP3 are the following:

11

• SAMA 30Provide a portable diesel-driven battery charger to improve dc power 12 reliability. A safety-related disconnect would be used to charge a selected battery. This 13 modification would enhance the long-term operation of the turbine-driven AFW pump on 14 battery depletion.

15

• SAMA 52Institute a procedure for opening the city water supply valve for alternative 16 AFW system pump suction to enhance the availability of the AFW system.

17

• SAMA 53Install an excess flow valve to reduce the risk associated with hydrogen 18 explosions inside the turbine building or PAB (cost beneficial in revised analysis, with 19 uncertainties).

20

• SAMA 55Provide the capability of powering one safety injection pump or RHR pump 21 using the Appendix R diesel (MCC 312A) to enhance RCS injection capability during 22 events that cause a loss of power from the 480-V ac vital buses.

23

• SAMA 61Upgrade the ASSS to allow timely restoration of RCP-seal injection and 24 cooling from events that cause a loss of power from the 480-V ac vital buses.

25

• SAMA 62Install a flood alarm in the 480-V ac switchgear room to mitigate the 26 occurrence of internal floods inside the 480-V ac switchgear room.

27 In response to an NRC staff inquiry regarding estimated benefits for certain SAMAs and lower 28 cost alternatives, one additional potentially cost-beneficial SAMA was identified (applicable to 29 SGTR events in both units), and one SAMA that was previously identified as potentially cost 30 beneficial was found no longer cost beneficial based on correction of an error in the ER (IP3 31 SAMA 30). The potentially cost-beneficial SAMAs and Entergys plans for further evaluation of 32 these SAMAs are discussed in more detail in Section G.6.2.

33 6.1.1 Review of Entergys Cost-Benefit Evaluation 34 The cost-benefit analysis performed by Entergy was based primarily on NUREG/BR-0184 (NRC 35 1997a) and was implemented consistent with this guidance.

36 SAMAs identified primarily on the basis of the internal events analysis could provide benefits in 37 certain external events, in addition to their benefits in internal events. To account for the 38 additional benefits in external events, Entergy multiplied the internal event benefits for each 39 internal event SAMA by an amount equal to the ratio of the sum of the internal and external December 2008 G-31 Draft NUREG-1437, Supplement 38

Appendix G 1 event CDF to the internal event CDF. This ratio is approximately 3.8 for IP2 and 5.5 for IP3.

2 Potential benefits in external events were estimated in this manner, since the external-event 3 models are generally less detailed than the internal-event models and do not lend themselves to 4 quantifying the benefits of the specific plant changes associated with internal-event SAMAs.

5 For example, the benefits of a procedural change associated with an important internal event 6 sequence cannot be readily assessed using the seismic-risk model if that operator action or 7 system is not represented in the seismic-risk model. The use of a multiplier on the benefits 8 obtained from the internal events PSA to incorporate the impact of external events implicitly 9 assumes that each SAMA would offer the same percentage reduction in external-event CDF 10 and population dose as it offers in internal events. While this provides only a rough 11 approximation of the potential benefits, such an adjustment was considered appropriate, given 12 the large risk contribution from external events relative to internal events and the lack of 13 information on which to base a more precise risk reduction estimate for external events. In view 14 of the remaining conservatism in the external events CDF, and the licensees further evaluation 15 of the impacts of the use of a multiplier on the SAMA screening (as part of the uncertainty 16 assessment discussed below), the NRC staff agrees that the use of these multipliers for 17 external events is reasonable.

18 For SAMA candidates that only address a specific external event and have no bearing on 19 internal-event risk, Entergy derived the benefit directly from the external-event risk model and 20 then increased the benefit by the multipliers identified earlier. The NRC staff notes that the use 21 of multipliers for these SAMAs (conceptually, to account for additional benefits in internal 22 events) is unnecessary, since these SAMAs have no bearing on internal events. However, use 23 of the multipliers adds conservatism to the benefit estimate for these SAMA candidates.

24 Entergy considered the impact that possible increases in benefits from analysis uncertainties 25 would have on the results of the SAMA assessment. In the ER, Entergy presents the results of 26 an uncertainty analysis of the internal-event CDF for IP2 and IP3, which indicates that the 95th 27 percentile value is a factor of 2.1 times the mean CDF for IP2 and 1.4 times the mean CDF for 28 IP3. Entergy assessed the impact on the SAMA screening if the estimated benefits for each 29 SAMA were further increased by these uncertainty factors. For purposes of this assessment, 30 Entergy applied a multiplier of 8 to the internal-event benefits for each unit to account for both 31 internal and external events, with analysis uncertainty. The multiplier of 8 slightly exceeds the 32 product of the external-event multiplier and the uncertainty factor for each unit (i.e., 3.8x2.1=8.0 33 for IP2, and 5.5x1.4=7.7 for IP3) and adds a small amount of additional conservatism. Although 34 not cost beneficial in the baseline analysis, Entergy included any additional SAMAs identified as 35 potentially cost beneficial in the uncertainty analysis within the set of potentially cost-beneficial 36 SAMAs that it intends to examine further for implementation.

37 Entergy also provided the results of additional sensitivity analyses in the ER, including use of a 38 3 percent discount rate, use of a longer plant life, and the consideration of economic losses by 39 tourism and business (which were not included in the baseline analysis). These analyses did 40 not identify any additional potentially cost-beneficial SAMAs beyond those already identified 41 through the uncertainty analysis.

42 The NRC staff questioned the rationale for treating the loss of tourism and business in a 43 sensitivity case rather than in the baseline analysis (NRC 2007). Incorporation of tourism and 44 business losses within the baseline analysis could result in identification of additional cost-45 beneficial SAMAs, particularly when the baseline benefits are multiplied to account for Draft NUREG-1437, Supplement 38 G-32 December 2008

Appendix G 1 uncertainties. In response, Entergy explained that the impact of lost tourism and business was 2 not modeled in the baseline analysis because the level of tourism and business activity can be 3 reestablished in time. Nevertheless, Entergy provided the results of an additional uncertainty 4 case showing the impact of lost tourism and business combined with analysis uncertainty. This 5 uncertainty case resulted in the identification of two additional potentially cost-beneficial SAMAs 6 for IP2 (IP2 SAMAs 9 and 53) and one additional potentially cost-beneficial SAMA for IP3 (IP3 7 SAMA 53). Given that it may take years to reestablish the level of tourism and business activity 8 following a severe accident, the NRC staff has conservatively adopted the case incorporating 9 lost tourism and business as its base case and has reflected the results of that case in 10 Table G-6.

11 In responding to an NRC RAI, Entergy identified and corrected an error in the benefit analysis 12 for IP3 SAMA 30 (provide a portable battery charger for monitoring instrumentation necessary to 13 allow manual operation of the turbine-driven AFW pump), which results in this SAMA no longer 14 being potentially cost beneficial. As indicated in ER Section E.4.3, the benefit of this SAMA was 15 estimated based on the assumption that the SAMA would increase the time available to recover 16 offsite power before local operation of AFW is required from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and would also 17 reduce internal switchgear room floods by 5 percent (which bounds the benefit of using a 18 portable diesel-driven battery charger in switchgear flood events). According to Entergy, the 19 original analysis inadvertently reduced the contribution from internal switchgear room floods by 20 more than 5 percent (Entergy 2008a). Entergys reevaluation of the benefits for this SAMA, 21 consistent with the intended bounding case, resulted in a reduction in the baseline benefit to 22 about $146,000, including the impacts of lost tourism and business and analysis uncertainties.

23 As such, this SAMA is no longer cost beneficial. The revised benefit estimate is reflected in 24 Table G-6. The NRC staff notes that the benefit associated with several other SAMA 25 candidates that could increase the time available to recover offsite power before local operation 26 of AFW is required from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (e.g., IP3 SAMA 24 (provide additional dc battery 27 capacity) was estimated at about $51,000, including the impacts of lost tourism and business 28 and analysis uncertainties. Therefore, a revised benefit estimate of $145,000 for IP3 SAMA 30, 29 which also includes the additional benefit from reducing the contribution of internal switchgear 30 room floods by 5 percent, appears reasonable. Entergy indicates that the implementation cost 31 associated with IP3 SAMA 30 (i.e., $494,000) was specifically estimated for IP3. The proposed 32 plant modification involves purchasing, installing, and maintaining a diesel-driven generator to 33 charge the 125-V dc batteries. Safety-related quick-disconnects would be used to charge the 34 selected battery. The diesel generator would be installed in a weather enclosure outside the 35 turbine or control building, requiring fire barrier penetration sealing. Calculation of cable size, as 36 well as procedure development and training, would be required (Entergy 2007). In view of the 37 scope of these modifications and the fact that the modifications involve a safety-related dc 38 system, the estimated costs appear reasonable. Accordingly, the staff agrees that this SAMA 39 would not be cost beneficial for IP3.

40 The NRC-sponsored severe accident analyses performed subsequent to the time of the IPE 41 suggest that the probability of a TI-SGTR, given a core-damage event with high primary-side 42 pressure and a depressurized, dry secondary side, may be higher than the value used in the 43 IP2 and IP3 PSAs. In response to an NRC request, Entergy provided the results of a sensitivity 44 study in which it increased the conditional TI-SGTR probability from 0.01 (used in the baseline 45 analysis) to 0.25, which is comparable to the values reported in NUREG-1570 (NRC 1998).

46 Entergy identified the candidate SAMAs potentially affected by the TI-SGTR assumption and December 2008 G-33 Draft NUREG-1437, Supplement 38

Appendix G 1 reassessed the benefits for these SAMAs, subject to the increased conditional failure probability 2 and the impact of analysis uncertainties. Entergy identified no additional cost-beneficial SAMAs 3 as a result of this reassessment. Entergy also noted that the IP2 and IP3 steam generators 4 have only 0.19 percent and 0.12 percent of the tubes plugged for IP2 and IP3, respectively, and 5 would be classified as pristine, in accordance with the Westinghouse criteria for categorizing 6 steam generator tube integrity. With no observed corrosion, Entergy concludesand the NRC 7 staff concursthat this sensitivity study is conservative relative to the application of the 8 NUREG-1570 results for pristine generators (Entergy 2008b).

9 The NRC staff noted that for certain SAMAs considered in the ER, there may be alternatives 10 that could achieve much of the risk reduction at a lower cost. The NRC staff asked the licensee 11 to evaluate several lower cost alternatives to the SAMAs considered in the ER, including 12 SAMAs that had been found to be potentially cost beneficial at other PWR plants. These 13 alternatives were (1) implementation of improved instrumentation and/or procedures to aid in 14 the mitigation of a SGTR, (2) implementation of a procedure for recovery of steam dump to 15 condenser from the unaffected steam generator to aid the mitigation of a SGTR, 16 (3) implementation of a procedure for recovery of the main feedwater/condensate postsafety 17 injection actuation to aid in the mitigation of a SGTR, (4) reactivation of the IP3 postaccident 18 containment venting system, and (5) purchase or manufacture of a gagging device that could 19 be used to close a stuck-open steam generator safety valve on a faulted steam generator 20 before core damage occurs (NRC 2007a and NRC 2007b). Entergy provided a further 21 evaluation of these alternatives, as summarized below.

22

• Improve SGTR instrumentation and/or valve procedures. Operator actions to cool and 23 depressurize the RCS to cold shutdown conditions following and SGTR before depleting 24 RWST inventory are already contained in EOPs. EOPs also direct plant personnel to 25 initiate RWST makeup, given a low RWST level without a corresponding increase in the 26 containment recirculation sump water level, or if the ruptured steam generator narrow-27 range level indication is high.

28

• Institute a procedure for recovery of steam dump to condenser. Procedures for recovery 29 of steam dump to condenser from the unaffected steam generator are currently available 30 at both units.

31

• Recover main feedwater/condensate. For IP2, the operators are currently directed to 32 attempt to establish a secondary heat sink with AFW, main feedwater, or condensate, 33 should the AFW system initially not function or subsequently fail during implementation 34 of the EOPs. For IP3, procedural guidance currently exists for reestablishing 35 condensate flow, but there is no guidance to use main feedwater following a loss of the 36 secondary heat sink. Thus, the development of guidance on aligning main feedwater for 37 secondary heat removal was evaluated as a potential SAMA for IP3.

38

• Reactivate the IP3 containment venting system. IP3 has three alternate methods of 39 containment depressurization and combustible gas control. These methods are 40 backflow to the steam ejector line, containment pressure relief line, and the containment 41 purge system. All of the venting functions require similar operator actions. Given these 42 various alternatives, failure to vent would be dominated by human error and would not 43 be substantially reduced by providing an additional means of venting.

Draft NUREG-1437, Supplement 38 G-34 December 2008

Appendix G 1 With regard to the steam generator safety gagging device, which was found to be potentially 2 cost beneficial at another pressurized-water reactor seeking license renewal, Entergy provided 3 a separate assessment of the benefits and implementation costs. Entergy estimated the benefit 4 associated with successfully gagging a stuck-open main steam safety valve following an SGTR 5 by assuming all early steam generator isolation failures and all TI-SGTRs would be eliminated.

6 The total benefits were estimated to be about $2.9 million for IP2 and $4.4 million for IP3. The 7 implementation cost, including purchasing and storing a dedicated gagging devise, revising 8 procedures, and providing training, was estimated to be about $50,000 for each unit. As such, 9 the results indicate that this SAMA is potentially cost beneficial for both units. Entergy indicates 10 that this additional SAMA has been submitted for an engineering project cost-benefit analysis 11 for a more detailed examination of its viability and implementation cost (Entergy 2008b). The 12 NRC staff concurs with Entergys findings regarding these alternative SAMAs because the NRC 13 staff finds the additional information provided by Entergy for the aforementioned alternative 14 SAMAs to be technically sound.

15 The NRC staff notes that all nine potentially cost-beneficial SAMAs for IP2 (IP2 SAMAs 9, 28, 16 44, 53, 54, 56, 60, 61, and 65) and five potentially cost-beneficial SAMAs for IP3 (IP3 SAMAs 17 52, 53, 55, 61, and 62), identified in either Entergys baseline analysis or supplemental analyses 18 provided in response to the NRC requests, as well as the additional SAMA regarding a 19 dedicated gagging device for SGTR events (applicable to both units), are included within the set 20 of SAMAs that Entergy will consider further for implementation. The NRC staff concludes that, 21 with the exception of the potentially cost-beneficial SAMAs discussed above, the costs of the 22 other SAMAs would be higher than the associated benefits (i.e., no additional SAMAs appear to 23 be cost-beneficial).

24 G.7 Conclusions 25 Entergy compiled a list of 231 candidate SAMAs for IP2 and 237 SAMAs for IP3, based on a 26 review of the most significant basic events from the current plant-specific PSA, insights from the 27 plant-specific IPE and IPEEE, and a review of other industry documentation. An initial 28 screening removed SAMA candidates that (1) were not applicable at IP2 and IP3, (2) were 29 already implemented or their intent had been met, or (3) were similar in nature and could be 30 combined with another SAMA candidate. Based on this screening, 163 IP2 and 175 IP3 31 SAMAs were eliminated, leaving 68 IP2 and 62 IP3 candidate SAMAs for evaluation.

32 For the remaining SAMA candidates, more detailed evaluation was performed as shown in 33 Table G-6. The cost-benefit analyses in the ER showed that five IP2 and five IP3 SAMA 34 candidates were potentially cost beneficial in either the baseline analysis or sensitivity analysis 35 using a 3 percent discount rate. Entergy performed additional analyses to evaluate the impact 36 of parameter choices and uncertainties on the results of the SAMA assessment. As a result, 37 four additional IP2 SAMAs and one additional IP3 SAMA were identified as potentially cost 38 beneficial. In addition, a SAMA regarding a dedicated gagging device for SGTR events was 39 identified as potentially cost beneficial for both units. Correction of an error in the benefit 40 analysis for IP2 SAMA 30 resulted in it no longer being considered cost beneficial. Entergy has 41 indicated that all nine potentially cost-beneficial SAMAs for IP2 (IP2 SAMAs 9, 28, 44, 53, 54, 42 56, 60, 61, and 65) and five potentially cost-beneficial SAMAs for IP3 (IP3 SAMAs 52, 53, 55, December 2008 G-35 Draft NUREG-1437, Supplement 38

Appendix G 1 61, and 62), as well as the additional SAMA regarding a dedicated gagging device for SGTR 2 events, will be considered further for implementation at IP2 and IP3.

3 The NRC staff reviewed the Entergy analysis and concludes that the methods used and the 4 implementation of those methods were sound. The treatment of SAMA benefits and costs 5 support the general conclusion that the SAMA evaluations performed by Entergy are reasonable 6 and sufficient for the license renewal submittal. Although the treatment of SAMAs for external 7 events was somewhat limited, the likelihood of there being cost-beneficial enhancements in this 8 area was minimized by improvements that have been realized as a result of the IPEEE process 9 and inclusion of a multiplier to account for external events.

10 The NRC staff concurs with Entergys identification of areas in which risk can be further reduced 11 in a cost-beneficial manner through the implementation of the identified, potentially cost-12 beneficial SAMAs. Given the potential for cost-beneficial risk reduction, the NRC staff agrees 13 that further evaluation of these SAMAs by Entergy is warranted. However, these SAMAs do not 14 relate to adequately managing the effects of aging during the period of extended operation.

15 Therefore, they need not be implemented as part of license renewal pursuant to Title 10 of the 16 Code of Federal Regulations, Part 54, Requirements for Renewal of Operating Licenses for 17 Nuclear Power Plants (10 CFR Part 54).

18 G.8 References 19 Consolidated Edison (Con Ed). 1992. Letter from Stephen B. Bram to U.S. NRC,

Subject:

20 Generic Letter 88-20, Supplement 1: Individual Plant Examination (IPE) for Severe Accident 21 Vulnerabilities10 CFR 50.54, IP2 and IP3 Unit No. 2, August 12, 1992.

22 Consolidated Edison (Con Ed). 1995. Letter from Stephen E. Quinn to U.S. NRC,

Subject:

23 Final Response to Generic Letter 88-20, Supplement 4: Submittal of Individual Plant 24 Examination of External Events (IPEEE) for Severe Accident Vulnerabilities, IP2 and IP3 Unit 25 No. 2, December 6, 1995.

26 Entergy Nuclear Operations, Inc. (Entergy). 2007. Letter from Fred Dacimo to U.S. NRC, 27

Subject:

IP2 and IP3 Energy Center Licensee Renewal Application, NL-07-039, April 23, 2007.

28 ADAMS Accession No. ML071220512.

29 Entergy Nuclear Operation (Entergy). 2008a. Letter from Fred R. Dacimo to U.S. NRC, 30

Subject:

Reply to Request for Additional Information Regarding License Renewal Application 31 Severe Accident Mitigation Alternatives Analysis, NL-08-028, February 5, 2008. ADAMS 32 Accession No. ML080420264.

33 Entergy Nuclear Operation (Entergy). 2008b. Letter from Fred R. Dacimo to U.S. NRC, 34

Subject:

Supplemental Reply to Request for Additional Information Regarding License Renewal 35 ApplicationSevere Accident Mitigation Alternatives Analysis, NL-08-086, May 22, 2008.

36 ADAMS Accession No. ML081490336.

37 New York Power Authority (NYPA). 1994. Letter from William A. Josiger to U.S. NRC,

Subject:

38 IP2 and IP3 3 Nuclear Power Plant Individual Plant Examination for Internal Events, June 30, 39 1994.

Draft NUREG-1437, Supplement 38 G-36 December 2008

Appendix G 1 New York Power Authority (NYPA). 1997. Letter from James Knubel to U.S. NRC,

Subject:

2 IP2 and IP3 3 Nuclear Power Plant Individual Plant Examination of External Events (IPEEE),

3 September 26, 1997.

4 Nuclear Regulatory Commission (NRC). 1990. Severe Accident Risks: An Assessment for 5 Five U.S. Nuclear Power Plants. NUREG-1150, Washington, DC, December 1990. ADAMS 6 Accession No. ML040140729.

7 Nuclear Regulatory Commission (NRC). 1991. Generic Letter 88-20, Supplement 4, Individual 8 Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities, June 28, 9 1991.

10 Nuclear Regulatory Commission (NRC). 1995. Letter from Jefferey F. Harold to William J.

11 Cahill, Jr.,

Subject:

Staff Evaluation of IP2 and IP3 Nuclear Generating Unit No. 3Individual 12 Plant Examination (TAC No. M74423), December 11, 1995.

13 Nuclear Regulatory Commission (NRC). 1996. Letter from Barry Westreich to Stephen E.

14 Quinn,

Subject:

Staff Evaluation of IP2 and IP3 Nuclear Generating Unit No. 2Individual Plant 15 Examination (TAC No. M74422), August 14, 1996.

16 Nuclear Regulatory Commission (NRC). 1997a. Regulatory Analysis Technical Evaluation 17 Handbook. NUREG/BR-0184, Washington, DC, January 1997.

18 Nuclear Regulatory Commission (NRC). 1997b. Individual Plant Examination Program:

19 Perspectives on Reactor Safety and Plant Performance. NUREG-1560, Washington, DC, 20 December 1997.

21 Nuclear Regulatory Commission (NRC). 1997c. Code Manual for MACCS2: Volume 1, User's 22 Guide. NUREG/CR-6613, Washington, DC, May 1998.

23 Nuclear Regulatory Commission (NRC). 1998. Risk Assessment of Severe Accident-Induced 24 Steam Generator Tube Rupture. NUREG-1570, Washington, DC, March 1998.

25 Nuclear Regulatory Commission (NRC). 1999. Letter from Jefferey F. Harold to A. Alan Blind, 26

Subject:

Review of IP2 and IP3 Nuclear Generating Unit No. 2Individual Plant Examination of 27 External Events (IPEEE) Submittal (TAC No. M83631), August 13, 1999.

28 Nuclear Regulatory Commission (NRC). 2001. Letter from George F. Wunder to Michael 29 Kansler,

Subject:

Review of Individual Plant Examination of External EventsIP2 and IP3 30 Nuclear Generating Unit No. 3 (TAC No. M83632), February 15, 2001. ADAMS Accession No.

31 ML010080273.

32 Nuclear Regulatory Commission (NRC). 2002. Perspectives Gained From the Individual Plant 33 Examination of External Events (IPEEE) Program," Volume 1 & 2, Final Report. NUREG-1742, 34 Washington, DC, April 2002.

35 Nuclear Regulatory Commission (NRC). 2004. Regulatory Analysis Guidelines of the U.S.

36 Nuclear Regulatory Commission. NUREG/BR-0058, Washington, DC, September 2004.

37 ADAMS Accession No. ML042820192.

38 Nuclear Regulatory Commission (NRC). 2007. Letter from Jill Caverly to Entergy,

Subject:

39 Request for Additional Information Regarding Severe Accident Mitigation Alternatives for IP2 40 and IP3 Nuclear Generating Unit Nos. 2 and 3 Licensee Renewal (TAC Nos. MD5411 and 41 MD5412), December 7, 2007. ADAMS Accession No. ML073110447.

December 2008 G-37 Draft NUREG-1437, Supplement 38

Appendix G 1 Nuclear Regulatory Commission (NRC). 2008. Letter from Bo M. Pham to Entergy,

Subject:

2 Request for Additional Information Regarding the Review of the License Renewal Application for 3 IP2 and IP3 Nuclear Generating Unit Nos. 2 and 3 (TAC Nos. MD5411 and MD5412), April 9, 4 2008. ADAMS Accession No. ML080880104.

5 U.S. Department of Agriculture (USDA). 2002. Census of Agriculture. Accessed at:

6 http://www.nass.usda.gov/census/ on April 26, 2005.us/ on April 26, 2005.

Draft NUREG-1437, Supplement 38 G-38 December 2008

Appendix H U.S. Nuclear Regulatory Commission Staff Evaluation of Environmental Impacts of Cooling System

1 Appendix H 2 U.S. Nuclear Regulatory Commission 3 Staff Evaluation of 4 Environmental Impacts of Cooling System 5 H.1 Environmental Impacts of Cooling System 6 Environmental issues associated with the operation of a nuclear power plant during the renewal 7 term are discussed in the U.S. Nuclear Regulatory Commission (NRC) document, 8 NUREG-1437, Volumes 1 and 2, Generic Environmental Impact Statement for License 9 Renewal of Nuclear Plants (hereafter referred to as the GEIS) (NRC 1996, 1999).(a) The GEIS 10 includes a determination of whether the analysis of the environmental issues could be applied to 11 all plants and whether additional mitigation measures would be warranted. Issues are then 12 assigned a generic (Category 1) or site-specific (Category 2) designation. As set forth in the 13 GEIS, generic issues are those that have the following characteristics:

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

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

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

23 No additional plant-specific analysis is required for generic issues unless new and significant 24 information is identified. Site-specific issues do not have all the above characteristics, and a 25 plant-specific review is required.

26 This appendix addresses the issues that are listed in Table B-1, Appendix B, Subpart A, of 27 Title 10 of the Code of Federal Regulations (CFR), Part 51, Environmental Protection 28 Regulations for Domestic Licensing and Related Regulatory Functions, and that are related to 29 the operation of the cooling systems of Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 30 and IP3) during their renewal term. Section H.1 addresses the impingement of fish and shellfish 31 applicable to the IP2 and IP3 cooling systems. Section H.2 addresses the entrainment of fish 32 and shellfish applicable to the IP2 and IP3 cooling systems. Section H.3 addresses the 33 combined effects of impingement and entrainment, and Section H.4 discusses cumulative 34 impacts. Finally, Section H.5 lists the references for Appendix H. Category 1 and Category 2 December 2008 H-1 Draft NUREG-1437, Supplement 38

Appendix H 1 issues that are not applicable to IP2 and IP3, because they are related to plant design features 2 or site characteristics not found at IP2 and IP3, are listed in Appendix F.

3 H.1.1. Impingement of Fish and Shellfish 4 Impingement occurs when organisms are trapped against cooling water intake screens or racks 5 by the force of moving water. Impingement can kill organisms immediately or gradually, by 6 exhaustion, suffocation, injury, or exposure to air when screens are rotated for cleaning. The 7 potential for injury or death is generally related to the amount of time an organism is impinged, 8 its susceptibility to injury, and the physical characteristics of the screenwash and fish return 9 system that is employed. Studies of impingement losses associated with the operation of IP2 10 and IP3 cooling systems were conducted annually from 1975 to 1990. Before the installation of 11 modified Ristroph screen systems in 1991, impingement mortality was assumed to be 12 100 percent. Beginning in 1985, studies were conducted to evaluate whether the addition of 13 Ristroph screens would decrease impingement mortality for representative species. The final 14 design (Version 2), as reported in Fletcher (1990), appeared to reduce impingement mortality, 15 based on a pilot study, in comparison to the existing (original) system in place at IP2 and IP3 16 (Table H-1). The impingement survival estimates reported in Fletcher (1990) were not 17 validated, however, after the new Ristroph screens were installed at IP2 and IP3 in 1991.

18 Table H-1 Assumed Cumulative Mortality and Injury of Selected Fish Species after 19 Impingement on Ristroph Screens Percent Species Dead and Injured Alewife 62 American Shad 35 Atlantic Tomcod 17 Bay Anchovy 23 Blueback Herring 26 Hogchoker 13 Striped Bass 9 Weakfish 12 White Catfish 40 White Perch 14 Source: Fletcher 1990 20 H.1.1.1. Summary of Impingement Monitoring Studies 21 The former owners of IP2 and IP3 conducted impingement monitoring between 1975 and 1990 22 using a variety of techniques. Between January 1975 and June 1981, fish were collected and 23 sorted during a daily intake screen washing between 0800 and 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> (hr). In July 1981 Draft NUREG-1437, Supplement 38 H-2 December 2008

Appendix H 1 and continuing through October 1990, fish were collected during intake screen washings 2 between 0800 and 1200 hr on selected days determined from a stratified random design 3 intended to reduce the overall sampling effort without affecting data use and utility. Between 4 October and December 1990, IP2 was sampled every Tuesday, and IP3 was not sampled 5 because of a plant outage. During all collections, the wash water was circulated to draw a 6 portion of the fish and debris into the forebay, where it was drained through a sluice containing a 7 1-millimeter (mm) (0.375-inch (in.)) square mesh screen. Collection efficiency was estimated in 8 1974, 1975, and 1977 at IP2. The results of these studies suggested that the collection 9 efficiency was highly variable (ranging from 2 percent to 45 percent based on the recovery of 10 dyed fish) and averaged 29 percent (Con Edison 1976; Con Edison 1979). Collection efficiency 11 at IP3 in 1976 and 1977 ranged from 58 percent to 86 percent recovery of dyed fish with an 12 average of 71 percent (Con Edison 1977, 1979). The difference in the collection efficiency at 13 the two units was associated with the differences in the type of screens (fixed versus traveling 14 screens) and the method used for screen washing. To estimate the total number of fish 15 impinged, the total number of fish collected was multiplied by an adjustment factor representing 16 the inverse of the collection efficiency. From 1975 to 1978, adjustment factors of 3.5 and 1.4 17 were used for IP2 and IP3, respectively (Con Edison 1980).

18 Analysis of variance and the correlation of environmental and IP2 and IP3 operation variables 19 were employed to explain the variation in collection efficiency. Early studies suggested that 20 collection efficiency increased during periods of low water temperature. In 1979, the adjustment 21 factor became a function of the time of year, based on the increase in collection efficiency when 22 water temperatures were less than 15 degrees Celsius (C) (59 degrees Fahrenheit (F)). Thus, 23 cool water adjustment factors of 2.1 and 1.2 were adopted to estimate the number of fish 24 impinged at IP2 and IP3, respectively, during January through April, November, and December.

25 For May to October, the adjustment factor was 3.8 for IP2 and 1.5 for IP3. In 1981, the 26 collection efficiency was estimated with a regression relationship with temperature:

27 IP2 efficiency= E2 = -0.00945 (Temperature degrees C) + 0.54708; and 28 IP3 efficiency= E3 = -0.00792 (Temperature degrees C) + 0.71640 (Con Edison 29 1984).

30 These regression relationships were updated in 1982, and screen-specific adjustments were 31 devised from studies conducted in 1985 and 1986 (Table H-2).

32 Impingement monitoring designs changed through time (Con Edison 1980, 1984; Con Edison 33 and NYPA 1986, 1987, 1988, and 1991) as follows. In 1979, the daily variation in impingement 34 counts was analyzed to determine its effect on the precision and accuracy of reduced sampling 35 plans. Starting in July 1981, a sampling plan employing a seasonally stratified random sample 36 developed from these results was used for all further impingement studies except the last 37 quarter of 1990. Instead of sampling daily, IP2 and IP3 were sampled a total of 110 days per 38 year (a 30-percent sampling fraction with approximately 92-percent accuracy) (Con Edison 39 1984). Days were selected at random within four calendar strata defined by similar water 40 temperatures and variance in the number of fish impinged (January-March, April-June, July-41 September, and October-December). The number of days sampled per stratum was 42 proportional to the number of days available and the variance in impingement for all taxa 43 combined (Table H-3) (Con Edison 1984). The number of days allocated to strata was updated 44 in 1985 to take advantage of current data trends and again in 1990 because of known plant December 2008 H-3 Draft NUREG-1437, Supplement 38

Appendix H 1 outages. Even though IP2 and IP3 had different numbers of samples allocated to each stratum, 2 sampling was conducted on the same day at both units to the extent possible.

3 During 1981, the New York State Department of Environmental Conservation (NYSDEC) 4 required daily sampling when total impingement counts were greater than 10,000 fish. Daily 5 sampling was required to continue until the total was below 10,000 fish. Because these 6 sampling dates were not part of the stratified design, they were used in place of random dates 7 that were associated with unplanned unit outages. Outages were defined as circulating pump 8 outages and were not necessarily associated with cessation of power generation. In 1981, 9 randomly selected days that fell on planned outages were not replaced. From 1982 to 10 October 1990, to minimize the effect of planned and unplanned outages on the selected days 11 for collection, a randomly selected replacement day within the given stratum was sampled. In 12 October 1990, a systematic sampling design was employed that required sampling at IP2 each 13 Tuesday. No sampling was conducted at IP3 from October 1990 to December 1990 because of 14 an extended outage.

15 Sampling for blue crabs began in April 1983 and continued though December 1990. Sampling 16 was conducted on all days of plant operation. The total number of impinged crab and their total 17 weight were obtained for each sampling. In addition, the carapace width, total weight, and 18 observed condition were recorded for each collected individual.

19 Table H-2 Estimates of Collection Efficiency Based on Temporal Averages, Regressions 20 as a Function of Temperature, and Specific Screens IP2 Conventional IP3 Conventional Ristroph Screen Year Screen Screen Version1 1975-1978 29 percent 71 to 73 percent None installed Jan.-April and Jan.-April and Nov.-Dec. = 48 Nov.-Dec. = 83 percent 1979-1980 percent None installed May-Oct. = 26 May-Oct. = 66 percent percent E2 = -0.00945 T + E3 = -0.00792 T +

1981 None installed 0.54708 0.71640 E2 = -0.00871 T + E3 = -0.00792 T +

1982-1985 None installed 0.51858 0.71640 Draft NUREG-1437, Supplement 38 H-4 December 2008

Appendix H 1 Table H-2 (continued)

IP2 Conventional IP3 Conventional Ristroph Screen Year Screen Screen Version1 Jan.-Mar. = 70.8 percent Apr.-June = E2 or E3 E2 = -0.00871 T + E3 = -0.00792 T +

1986 July-Aug. = 18.7 0.51858 0.71640 percent Sept. = 29.6 percent Oct.-Dec. = E2 or E3 Jan.-Mar. = 74.4 percent Apr.-June = E2 or E3 E2 = -0.00871 T + E3= -0.00792 T +

1987-1990 July-Aug. = 18.7 0.51858 0.71640 percent Sept. = 29.6 percent Oct.-Dec. = E2 or E3 1

Number of Ristroph Screens at IP2. In 1986, a Ristroph Screen E2 - Collection Efficiency at IP2 was installed on Intake Bay 26.

E3 = Collection Efficiency at IP3 T = Temperature in degrees C Sources: Con Edison 1980, 1984; Con Edison and NYPA 1986, 1987, 1988, and 1991 2 Table H-3 Number of Days Allocated to Each Quarter Based on the Stratified Random 3 Sampling Design Allocation to IP2 Allocation to IP3 Total Stratum Dates in 1981; 1982-84; in 1981; 1982-84; Days 1985-89; and 1990 1985-89; and 1990 Winter Jan. 1-Mar. 31 90 N/Aa; 30; 23; 23 N/A; 27; 35; 35 Spring Apr. 1-June 30 91 N/A; 10; 8; 8 N/A; 18; 20; 20 Summer July 1-Sept. 30 92 11; 11; 11; 11 31; 31; 31; 31 Fall Oct. 1-Dec. 31 92 59; 59; 68; 13 34; 34; 24; 0 4 a N/A = Not Applicable, the reduced sampling began July 1, 1981 (Con Edison 1984) 5 Sources: Con Edison 1984; Con Edison and NYPA 1986, 1987, 1988, and 1991 6 For all impingement studies, fish were sorted and counted completely if either the identified 7 species was white perch, striped bass, or tomcod, or the total number collected for a given 8 species was less than 100 individuals (with heads). All other sorted samples were enumerated 9 by subsampling and weighing to four general length classes. This information was used to 10 determine the total sample size. To estimate the number of fish impinged, the estimated daily 11 counts (taken before July 1981) were multiplied by the collection efficiency adjustment factor 12 (Con Edison 1984). During the period of stratified random sampling (July 1981-1990), the December 2008 H-5 Draft NUREG-1437, Supplement 38

Appendix H 1 mean of the estimated number of fish counted within a stratum was multiplied by the collection 2 efficiency adjustment factor and the number of days of plant operation (Con Edison 1984).

3 H.1.1.2. Historic Assessment of Impingement Impacts 4 As discussed in the previous section, numerous studies have been conducted to evaluate the 5 effects of impingement associated with the Indian Point cooling systems. Studies have also 6 been conducted to evaluate the trends of fish populations in the Hudson River. Entergy Nuclear 7 Operations, Inc. (Entergy, or the applicant) and NYSDEC have used the results of these studies 8 to evaluate the potential for adverse effects associated with the operation of the Indian Point 9 cooling systems., The results of these assessments are described below. Nongovernmental 10 groups and members of the public have also evaluated publicly available information and data 11 associated with the Hudson River and have expressed the opinion that many species of fish in 12 the river are in decline and that the entrainment of juvenile and adult fish at Indian Point is 13 contributing to the decline, destabilization, and ultimate loss of these important aquatic 14 resources.

15 Applicant Assessment 16 In the draft environmental impact statement (DEIS) (CHGEC 1999) and environmental report 17 (ER) (Entergy 2007), the applicant acknowledged that some impinged fish survive and others 18 die. Mortality can be immediate or occur at a later time (latent or long-term mortality), and 19 mortality rates depend on the species, the size of the fish, the waters temperature and salinity, 20 the design of the screens, the water velocity through the screen, the length of time the fish was 21 impinged, and the design and operation of the fish return system. Impingement effects were 22 examined by evaluating conditional mortality rates (CMRs) and trends associated with 23 population abundance for eight selected taxa representing 90 percent of those fish species 24 collected from screens at IP2 and IP3, including striped bass, white perch, Atlantic tomcod, 25 American shad, bay anchovy, alewife, blueback herring, and spottail shiner. Estimates of the 26 CMR, defined as the fractional reduction in the river population abundance of the vulnerable age 27 group caused by one source of mortality only, were assumed to be the same as or lower than 28 that which occurred in past years, caused by the installation of Ristroph screens and fish return 29 systems at IP2 and IP3. For species exhibiting low impingement mortality (e.g., striped bass, 30 white perch, and Atlantic tomcod), future impingement effects were expected to be substantially 31 lower than they were before the installation and use of the present protective measures.

32 Central Hudson Gas and Electric Corporation (CHGEC) (1999) concluded that the maximum 33 expected total impingement CMR was 0.004 for white perch and less for all other taxa. The ER 34 (Entergy 2007) stated that the results of in-river population studies performed from 1974 to 1997 35 have not shown any negative trend in overall aquatic river species populations attributable to 36 plant operations:

Draft NUREG-1437, Supplement 38 H-6 December 2008

Appendix H 1 More than 30 years of extensive fisheries studies of the Hudson River in the 2 vicinity of IP2 and IP3 support current operations. The results of the studies 3 performed from 1974 to 1997, the period of time covered in the DEIS, are 4 referenced and summarized in the DEIS, and have not shown any negative 5 trend in overall aquatic river species populations attributable to plant 6 operations...

7 The ER also stated that ongoing studies continue to support these conclusions. Thus, the 8 applicant determined impingement impacts to be small, suggesting that the withdrawal of water 9 from the Hudson River for the purposes of once-through cooling for IP2 and IP3 did not have 10 any demonstrable negative effect on representative Hudson River fish populations, nor did it 11 warrant further mitigation measures.

12 To support this assessment, the applicant provided two reviews, Barnthouse et al. (2002) and 13 Barnthouse et al. (2008). These reviews addressed the status and trends of fish populations 14 and communities of the Hudson River estuary in relation to the operation of Bowline Point, IP2 15 and IP3, and Roseton generating stations, which currently share a State Pollutant Discharge 16 Elimination System (SPDES) permit. Barnthouse et al. (2002) was based on a review of the 17 DEIS, comments on the DEIS abundance indices though 2000 (CHGEC 1999), and the annual 18 Year Class Report (ASA 2000). Barnthouse et al. (2008) was based on abundance indices 19 through 2005, the spawning stock biomass-per-recruit model (SSBR), and CMR estimates.

20 Although both reviews recognized that the long-term population trends reflected the combined 21 effects of entrainment and impingement, the 2008 report focused on entrainment and suggested 22 that the existing retrofits (Ristroph screens and fish returns) have resolved the concerns 23 regarding impingement. Additional discussions concerning the results of the Barnthouse et al.

24 (2008) analyses are provided in Section H.2.

25 NYSDEC Assessment 26 With respect to the operation of the IP2 and IP3 cooling systems, the NYSDEC regulatory role 27 includes protecting aquatic resources from impacts associated with impingement, entrainment, 28 and thermal and chemical discharges. Based on activities conducted under the Hudson River 29 Settlement Agreement (HRSA), subsequent Consent Orders, and existing agreements with the 30 operators of IP2 and IP3, Roseton, and Bowline Point power generation stations, NYSDEC has 31 concluded that IP2 and IP3 have achieved some reductions in intake volumes through the use 32 of dual-speed and variable-flow pumps and have improved impingement survival through the 33 installation of modified Ristroph traveling screens (NYSDEC 2003a). However, NYSDEC states 34 that while these represent some level of improvement compared to operations with no 35 mitigation or protection, there are still significant unmitigated mortalities from entrainment and 36 impingement at all three of the HRSA facilities. In a petition submitted to the NRC, dated 37 November 30, 2007, the NYSDEC stated the following:

December 2008 H-7 Draft NUREG-1437, Supplement 38

Appendix H 1 The plants outdated design and operation have caused significant adverse 2 environmental impacts to the Hudson River. These impacts include 3 impingement, entrainment, and heat shock to numerous fish species in the 4 Hudson, including the endangered sturgeon In the alternative, even if the 5 NRC were to grant the license renewal application, it could only do that by 6 conditioning the renewal on the construction and use of closed-cycle cooling 7 water intake systems at IP2 and IP3. As was stated in the above contention on 8 impingement and entrainment, the perpetuation of once-through cooling here, 9 with its long history of massive injury and destruction of tens of millions of 10 Hudson River fish, is simply no longer tenable, either in fact or in law.

11 NYSDEC stated further that the applicant would need a Clean Water Act Section 316(b) 12 determination, a demonstration that the current cooling water intake structure reflects the best 13 technology available for minimizing adverse environmental impacts (NYSDEC 2007). However, 14 the NYSDEC states the following:

15 Entergy has not and could not demonstrate that its once-through cooling water 16 intake structures at IP2 and IP3 reflects the best technology available for 17 minimizing adverse environmental impacts. Indeed, the New York State 18 Department of Environmental Conservation has determined in the pending 19 SPDES permit renewal proceeding that closed-cycle cooling, and not once-20 through cooling, represents the best technology available for minimizing adverse 21 environmental impacts.

22 H.1.1.3. NRC Staff Assessment of Impingement Impacts 23 To assess impingement impacts, the NRC staff evaluated weekly estimated impingement 24 numbers at IP2 and IP3 from January 1975 to November 1980, and seasonally estimated 25 impingement numbers from January 1981 and December 1990. The combined numbers of 26 young of year (YOY), yearling, and older fish were used for analysis since these data were 27 available for all years of sampling.

28 A total of 127 identified fish taxa and blue crab were collected at IP2 and IP3 during this 15-year 29 period. At IP2, the estimated number of representative important species (RIS) fish (as defined 30 in Table 2-4 in the main text) impinged made up greater than 85 percent of all impinged taxa 31 (Figure H-1, solid lines). Until 1984, the RIS fish made up greater than or equal to 95 percent of 32 all impinged taxa. This percentage has significantly decreased at a rate of 0.8 percent per year 33 (linear regression; n = 16; p = 0.002) from 1985 to 1990. When blue crab are included with the 34 RIS fish, the estimated number impinged made up greater than 90 percent of all impinged taxa 35 for all but one year. Total impingement trends for all fish and blue crab are presented in 36 Figure H-1 (dashed line) and show impingement approached or exceeded 4 million in 1977 and 37 1981. Impingement of all fish and blue crab was lowest in 1984 ( about 0.5 million) and 1990 38 (about 1 million (Figure H-1, dashed line).

Draft NUREG-1437, Supplement 38 H-8 December 2008

Appendix H 100% 5.0 95% 4.5 Total Impinged at Unit 2 Percent of Total Impingement 90% 4.0 3.5 85%

3.0 80%

2.5 (millions of Fish and Blue Crab) 75%

2.0 70%

1.5 65% 1.0 60% 0.5 55% 0.0 1974 1976 1978 1980 1982 1984 1986 1988 1990 1992 RIS Fish RIS Fish + Blue Crab Total Impinged Unit 2 1 Figure H-1 Percentage of impingement comprised of RIS fish and RIS fish plus blue crab 2 in relation to the total estimated impingement at IP2 (data from Entergy 2007b) 3 At IP3, the estimated number of RIS fish impinged made up greater than or equal to 95 percent 4 of all impinged taxa except for the last 3 years (Figure H-2, solid lines). A significant decrease 5 in this percentage was observed during that time at a rate of 1.7 percent per year (linear 6 regression; n = 15; p = 0.005). When blue crabs are included with the RIS fish, the estimated 7 number impinged was greater than 85 percent for all but one year. Except for 1983, which had 8 extensive outages, IP2 had, on average, 2.6 times greater numbers of fish and crab impinged 9 annually than IP3. The highest total impingement occurred in 1976 at just over 1.8 million fish 10 and blue crab; the lowest occurred in 1983 at less than 0.1 million (Figure H-2, dashed line).

11 Total impingement trends at IP2 and IP3 suggest that the total number of fish and blue crab 12 impinged tended to decrease between 1977 and 1982, then leveled off between 1982 and 1990.

13 From 1975 to 1990, the number of days of operation at IP2 and IP3 has shown a general 14 increase of 8 days per year for IP2 and 5 days per year for IP3 (linear regression, p = 0.004 and 15 p = 0.286 for IP2 and IP3, respectively). The total volume circulated at IP2 and IP3 combined 16 has also shown a general increase of 26.2 106 cubic meters (m3) (linear regression, p = 0.164).

17 If the IP2 and IP3 cooling systems are considered a relatively constant sampler of Hudson River 18 aquatic biota (recognizing the slight increase in frequency and volume of water circulated), then 19 the decrease in the percent of RIS impinged and total impingement would suggest that RIS and 20 all other taxa within the vicinity of IP2 and IP3 have decreased from a high in 1977 to a relatively 21 constant lower level of impingement between 1984 and 1990. This will be explored further in 22 Section H.3.

23 To determine trends in RIS impingement, NRC Staff examined quarterly data from IP2 and IP3 24 from 1975 to 1990 (Table H-4). The two major time periods (1975-1980) and (1981-1990)

December 2008 H-9 Draft NUREG-1437, Supplement 38

Appendix H 100% 5.0 95% 4.5 Total Impinged at Unit 3 Percent of Total Impingement 90% 4.0 3.5 85%

3.0 80%

2.5 (millions of Fish and Blue Crab) 75%

2.0 70%

1.5 65% 1.0 60% 0.5 55% 0.0 1974 1976 1978 1980 1982 1984 1986 1988 1990 1992 RIS Fish RIS Fish + Blue Crab Total Impinged Unit 3 1 Figure H-2 Percentage of impingement comprised of RIS fish and RIS fish plus blue crab 2 in relation to the total estimated impingement at IP3 (data from Entergy 2007b) 3 were analyzed separately to account for the differences in impingement sampling strategies 4 discussed above. Summed over all years, six RIS fish species accounted for 93 percent (IP2) 5 and 89 percent (IP3) of the total number of RIS impinged, including contributions from blue crab.

6 During January to March sampling events for both units and all years, white perch were the 7 most commonly impinged species, accounting for 89 to 96 percent of the RIS impinged.

8 Impingement of RIS was more variable during other sampling periods but was generally 9 dominated by four species (white perch, Atlantic tomcod, bay anchovy, blueback herring). The 10 notable exception to this pattern occurs between 1981 and 1990, when the percentage of 11 hogchoker and weakfish increased near both units during spring and summer sampling periods 12 compared to estimates obtained from 1975 to 1980 (Table H-4). Greenwood (2008) suggested 13 that cooling systems associated with IP2 and IP3 are considered an efficient environmental 14 sampler. Impingement data suggest that a change in the species composition in the vicinity of 15 IP2 and IP3 may have occurred in the 1980s.

16 As a result of the HRSA, operational measures were implemented to reduce the loss of aquatic 17 resources to impingement. These measures included the installation of dual-speed intake 18 pumps at IP2 in 1984, installation of variable-speed pumps at IP3 in 1985, and the installation of 19 modified Ristroph screens and fish return systems in 1991. The plant operators also developed 20 programs to employ flow-reduction measures and scheduled outages to reduce impingement 21 and entrainment impacts. Flow rates are dependent on intake water temperature, with 22 increased flow required when water temperatures rise above 15 degrees C. For example, the 23 average monthly water temperatures taken near Poughkeepsie, New York from 1992 to 2006 24 (Figure H-3) suggest to NRC Staff that greater flow would be required during the months of May 25 through October. This roughly corresponds to the second and third quarters of impingement 26 sampling (April-September timeframes in Table H-4). Although the seasonal percentage of 27 annual impingement of RIS fish was not significantly different between seasons (analysis of 28 variance (ANOVA), p = 0.095 with a coefficient of variation (CV) = 68 percent and p = 0.27 with Draft NUREG-1437, Supplement 38 H-10 December 2008

Appendix H 1 a CV = 84 percent for IP2 and IP3, respectively), they were generally lower between April and 2 June and similar across the remaining three quarters (Figure H-4). Thus, even though there is a 3 greater volume of water used between May and October (analysis of variance (ANOVA), p =

4 0.02 with a CV = 41 percent and p = 0.53 with a CV = 61 percent for IP2 and IP3, respectively),

5 impingement does not increase during these periods. Instead, the seasonal pattern of 6 impingement may be a reflection of when susceptible fish are present near the facility.

7 Table H-4 Average Percentage Impingement of RIS Compared to Total Impingement per 8 Season for 1975-1980 and 1981-1990 for Selected Taxa (data from Entergy 2007b)

IP2 COOLING SYSTEM 1975-1980 1981-1990 Percent RIS Species Jan- Apr- Jul- Oct- Jan- Apr- Jul- Oct- of Mar Jun Sep Dec Mar Jun Sep Dec RISTaxa1 White Perch 96 35 17 39 92 38 13 55 48 Atlantic 1 55 27 1 1 38 27 4 16 Tomcod Bay Anchovy 0 2 32 7 0 7 21 10 11 Blueback 0 0 10 46 0 1 2 13 14 Herring Hogchoker 0 3 4 3 0 9 13 4 2 Weakfish 0 0 3 0 0 0 12 4 2 Percent of 96 95 94 95 93 92 89 88 93 RIS Fish IP3 COOLING SYSTEM 1975-1980 1981-1990 Percent RIS Species Jan- Apr- Jul- Oct- Jan- Apr- Jul- Oct- of Mar Jun Sep Dec Mar Jun Sep Dec RISTaxa1 White Perch 95 55 10 43 89 54 19 52 50 Atlantic 0 23 40 2 0 17 19 3 17 Tomcod Bay Anchovy 0 3 23 2 0 7 18 5 8 Blueback 0 3 6 38 0 4 3 27 10 Herring Hogchoker 0 0 8 1 1 7 16 3 3 Weakfish 0 0 3 0 0 0 10 2 1 Percent of 96 84 89 86 91 89 86 91 89 RIS Fish 1

RIS Taxa include Blue Crab December 2008 H-11 Draft NUREG-1437, Supplement 38

Appendix H 30 Monthly Average Water Temperature (°C) 25 20 15 below Poughkeepsie, NY 10 5

0 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 1

2 Source: U.S. Geological Survey Surface Water Data, http://waterdata.usgs.gov/usa/nwis/uv?site_no=01372058 3 Figure H-3 Average monthly water temperature taken from below Poughkeepsie, NY, 4 from 1992 to 2006 35%

30%

25%

Percent of Annual Total 20%

15%

10%

5%

0%

Jan-Mar Apr-Jun Jul-Sep Oct-Dec Unit 2 Impingement Unit 3 Impingement Unit 2 Flow Unit 3 Flow 5

6 Figure H-4 Seasonal percentage of RIS fish impinged out of the annual total taxa 7 impinged and the seasonal percentage of the volume circulated out of the annual total 8 volume circulated from 1975-1990 (data from Entergy 2007b) 9 Based on the above NRC Staff analyses, the species with the highest percentage of 10 impingement at IP2 and IP3 from 1975 to 1990 were white perch, Atlantic tomcod, blueback 11 herring, bay anchovy, and hogchoker. Impingement trends for both units show that each of Draft NUREG-1437, Supplement 38 H-12 December 2008

Appendix H 1 these species was impinged during at least one sampling season in quantities representing at 2 least 10 percent of the total impingement counts for that period. During some sampling 3 seasons, a single species represented over 90 percent of the total impingement (e.g., white 4 perch during January to March). Impingement magnitude does not appear to be directly related 5 to flow; rather, the available information suggests that the frequency of impingement is 6 associated with seasonal patterns of fish and their proximity to IP2 and IP3. The environmental 7 significance of impingement is explored further in Section H-3.

8 H.1.2. Entrainment of Fish and Shellfish in Early Life Stages 9 Entrainment occurs when small aquatic life forms are carried into and through the cooling 10 system as water is withdrawn for use in the plants cooling system. Entrainment can affect 11 organisms smaller than the screen mesh (0.25 to 0.5 in.) that are carried into the plant with the 12 pumped water mass and have limited swimming ability to escape. This includes phytoplankton, 13 microzooplankton, and macrozooplankton. Entrained organisms also include the young life 14 stages of fish (eggs, larvae, post-yolk-sac larvae (YSL), and juveniles) and shellfish.

15 Entrained organisms pass through the circulating pumps and are carried with the flow through 16 the intake conduits toward the condenser units. They are then drawn through one of the many 17 condenser tubes used to cool the turbine exhaust steam and enter the discharge canal for 18 return to the water. As entrained organisms pass through the intake, they may be injured from 19 abrasion or compression. Within the cooling system, they encounter physical impacts in the 20 pumps and condenser tubing, pressure changes, sheer stress, thermal shock, and chemical 21 exposure to chlorine and residual industrial chemicals discharged at the diffuser ports (Mayhew 22 et al. 2000). Death can occur immediately (direct effect) or after being discharged (indirect 23 effect) from an inability to escape predators, a reduced ability to forage, or other factors.

24 The former owners of IP2 and IP3 conducted studies of entrainment loss associated with IP2 25 and IP3 in 1981 and then annually from 1983 to 1987. Entrainment survival is a particularly 26 controversial subject. The U.S. Environmental Protection Agency (EPA) assumes that the 27 mortality associated with entrainment is 100 percent (NYSDEC 2003a). Consolidated Edison 28 Company of New York (Con Edison) and New York Power Authority (NYPA 1984) assume that, 29 for the more delicate species (bay anchovy, American shad, clupeids), mortality was 100 30 percent. However, for other species, mortality could be separated into thermal and mechanical 31 components and overall was less than 100 percent. By 1987, Con Edison estimated the 32 survival of entrained bay anchovy up to 52 percent (EA 1989). This assessment recognizes that 33 96-hr survival of fish following entrainment is not a measure of the potential reduction in ability 34 to forage and avoid predation within hours or days of being discharged at the diffuser ports.

35 Thus, indirect losses for a given species from entrainment for the purpose of this assessment 36 are unknown.

37 H.1.2.1. Summary of Entrainment Survival Monitoring Studies 38 Entrainment studies to evaluate the survival of entrainable aquatic organisms (eggs, larvae, 39 YSL, small juveniles) have been conducted at IP2 and IP3 since the early 1970s. A variety of 40 sampling gear has been employed. Study endpoints included estimates of immediate and latent 41 mortality by monitoring collected organisms for up to 96 hr. Initial monitoring efforts were based December 2008 H-13 Draft NUREG-1437, Supplement 38

Appendix H 1 on the assumption that survival of organisms collected by nets was the same from intake canal 2 samples as it was from discharge canal samples. It was discovered, however, that differences 3 in water velocity at intake and discharge sampling stations may have affected ichthyoplankton 4 survival, and subsequent studies demonstrated that the survival of striped bass eggs and larvae 5 collected using fixed nets were velocity dependent. Based on these results, entrainment 6 survival sampling at IP2 and IP3 in 1977 and 1978 was expanded to include new sampling gear 7 designed to reduce or eliminate the effects of intake and discharge water velocity on apparent 8 postcollection survival. The primary change involved the use of centrifugal pumps to transport 9 water into a flume and larval collection table, where water quality conditions could be optimized 10 and samples concentrated for survival and latent mortality analyses. In spite of these 11 refinements, entrainment survival estimates derived from the pump/larval table collection 12 system were again compromised by poor ichthyoplankton survival in control samples collected 13 in front of intakes representing initial larval conditions before passage through the IP2 and IP3 14 cooling systems.

15 Subsequent revisions to sampling gear have been employed in 1979, 1980, and 1989, and are 16 discussed below. Because the survival estimates conducted before 1979 were significantly 17 compromised by sampling gear design and choice, NRC staff focused on the later studies to 18 evaluate entrainment mortality at IP2 and IP3. Sampling was also conducted in 1985 to 19 determine the effects of entrainment mortality resulting from an upgrade to the pumping system 20 associated with IP2. The results of this study are not directly comparable to the 1979 and 1980 21 studies, because a different sampling design was employed.

22 Details of the 1979 entrainment survival and related studies are presented in EA (1981a).

23 Entrainment survival studies were conducted during two separate sampling periods, the late 24 winter season from March 12-22, 1979, to evaluate the larvae of Atlantic tomcod (M. tomcod),

25 and in the spring-summer season from April 30 to August 14, 1979, to evaluate early life-stages 26 of striped bass (M. saxatilis), white perch (M. americana), herring (Clupeidae), and anchovies 27 (Engraulidae). During the winter season, sampling with a pump/larval table collection system 28 was conducted at the intakes associated with IP2 and IP3, in the IP3 effluent before it enters the 29 discharge canal, and in portions of the discharge canal containing effluent water from both units.

30 The shutdown of IP3 from March 20-22 provided an opportunity to evaluate Atlantic tomcod 31 larval survival under one- and two-unit operation. During the spring-summer season, a raft-32 mounted flume collection was used for the first time at IP2 and IP3. This system was designed 33 to reduce sampling stress on target organisms by taking advantage of head pressure created 34 caused by a difference between water levels on either side of the flume apparatus. The 35 shutdown of IP2 after June 16, 1979, provided an opportunity to assess the survival of other 36 species during both one- and two-unit operation.

37 For the Atlantic tomcod study during the winter of 1979, sampling was initiated upon notification 38 of the first occurrence of tomcod larvae and conducted on 4 consecutive nights per week over 39 the 2-week sampling period from March 12-22, for a total of 8 sampling days. Sampling 40 occurred between 1700 and 0200 hr to coincide with the diel period of peak larval abundance.

41 At the beginning of the study, both IP2 and IP3 units were operating, but an unscheduled 42 shutdown of IP3 occurred on March 20 and continued through the remainder of the study.

43 Although the unit did not generate power, two circulating water pumps continued to operate.

44 Thus, for the tomcod study, a total of 11 circulating pumps were operating from March 12-19 (6 45 at IP2, 5 at IP3), and a total of 8 pumps were operating from March 20-22 (6 at IP2, 2 at IP3).

Draft NUREG-1437, Supplement 38 H-14 December 2008

Appendix H 1 The pump/larval table collection system used for the tomcod study consisted of a modular two-2 screen collection flume that allowed collection of larval samples with minimal sampling stress 3 associated with turbulent flow or temperature changes. Sample water was delivered to the table 4 by two centrifugal pumps equipped with flowmeters. Collected entrainment samples were 5 transferred to an onsite laboratory for sorting, where icthyoplankton were sorted and classified 6 as live (fish, eggs), stunned (fish only), or dead (fish and eggs). Dead eggs and larvae were 7 preserved; live or stunned fish or eggs were transferred to holding facilities to determine latent 8 effects on survival at 3, 6, 12, 24, 48, 72, and 96 hr. Specific sampling procedures are 9 discussed in EA (1981a).

10 The spring-summer sampling to evaluate entrainment survival of striped bass, white perch, 11 herrings, and anchovies was conducted from April 30 to August 14, 1979, coincident with the 12 primary spawning and nursery seasons of these species. Samples were collected on 13 2 consecutive nights each week for a total of 32 sampling days from 1800 to 0200 hr that 14 coincided with maximum abundance. As described above, a pumpless, rear-draw plankton 15 sampling flume mounted on rafts was employed during this study to minimize stress associated 16 with the use of centrifugal pumps. The volume of water samples collected from all samplers 17 was measured with integrated flowmeters, and vertical 505-micron (m) mesh screens were 18 employed to divert entrained organisms into collection boxes, where they were concentrated 19 and processed to determine latent survival as described for the tomcod study.

20 Details of the 1980 entrainment survival and related studies are presented in EA (1982). In 21 1980, entrainment survival sampling at IP2 and IP3 was conducted from April 30 to July 10.

22 Sampling was focused on entrainable life stages of striped bass (M. saxatilis), white perch (M.

23 americana), herrings (Clupeidae), and anchovies (Engraulidae). Juvenile Atlantic tomcod (M.

24 tomcod) were also collected. To correct possible sources of gear-related effects on study 25 results, the rear-draw and pumpless plankton flumes used in 1979 were modified with flow 26 diffusion panels and slotted standpipes installed behind the angled diversion screens. These 27 refinements were intended to more evenly distribute the water across the surface of the screens 28 and eliminate localized areas of high-velocity flow that may have caused impingement. This, 29 along with other improvements to the sampling system, was expected to decrease the gear-30 related mortality observed in control samples from the intakes at IP2 and IP3.

31 Entrainment survival sampling for striped bass, white perch, herring and anchovies was 32 conducted from April 30 to July 10, 1980, coinciding with the primary spawning and nursery 33 seasons of these taxa. Samples were collected on 4 consecutive nights each week for a total of 34 44 sampling days between the hours of 1600 and 0200. Sampling was conducted at discharge 35 canal station DP and at the IP3 intake using the modified real-draw plankton sampling flumes.

36 Live and dead icthyoplankton collected during the study were sorted at the onsite laboratory 37 immediately after sample collection and classified as live (fish and eggs), stunned (fish only), or 38 dead (fish and eggs). Dead eggs and larvae were preserved; live or stunned fish or eggs were 39 transferred to holding facilities to determine latent effects with checks at 3, 6, 12, 24, 48, 72, and 40 96 hr.

41 During the summer and early fall of 1984, dual-speed cooling water pumps were installed at 42 IP2. In 1985, variable-speed pumps were installed at IP3. The specific objectives of the 1988 43 entrainment studies were to (1) estimate the initial and extended survival of ichthyoplankton 44 entrained at IP2 and IP3 and compare the results to those from previous years, (2) determine 45 whether live and dead ichthyoplankton are randomly dispersed in the IP2 and IP3 discharge December 2008 H-15 Draft NUREG-1437, Supplement 38

Appendix H 1 canal at sampling station D2, and (3) assess whether the thermal and mechanical components 2 of entrainment stress are independent. The study description that follows was obtained from EA 3 (1989).

4 The 1988 study EA (1989) was designed to sample 180 m3 per day with each flume system.

5 One flume was deployed at intake Station I3; two flumes were deployed at discharge station D2.

6 The original design required that flumes be operated 3 days per week from May 23 to June 30, 7 1989, resulting in 18 total sampling days. Specific daily volume requirements and numbers of 8 sampling days were developed to ensure sufficient numbers of organics were collected.

9 Because of a number of logistical challenges, the actual number of sampling days was 13, from 10 June 8-30. The flume design and collection procedures employed in 1988 were consistent with 11 previous studies described above. Average daily sample volumes collected at the intake were 12 143.3 m3, and the daily combined volume sampled by both flumes in the discharge canal was 13 271.2 m3. The sampling program was conducted during afternoon and evening hours (1300-14 2300). Live and dead icthyoplankton collected during the study were sorted at the onsite 15 laboratory immediately after sample collection and classified as described above. Other studies 16 conducted in 1988 included sampling stress evaluations to provide a better understanding of 17 mortality caused by sampling stress at intake versus discharge sampling locations, direct 18 release studies to augment entrainment studies based on wild animal captures, and net studies 19 in the discharge canal to provide additional information on icthyoplankton distribution.

20 The results of entrainment survival from the 1977-80, 1985, and 1988 studies are presented in 21 EA (1989) for initial intake survival (EA 1989, Figure 4-8), initial discharge survival (EA 1989, 22 Figure 4-9), and overall entrainment survival (EA 1989, Figure 4-10). Summary information for 23 the 1979, 1980, and 1988 study years are summarized in Table H-5 below:

24 Table H-5 Entrainment Survival Estimates for Study Years 1979, 1980, and 1988 Estimated Initial Intake Initial Discharge Entrainment Species Proportion Proportion Proportion Survival Survival Survival Bay Anchovy PYSL ~0.09-0.32 ~0.01-0.05 ~0.12-0.52 Striped Bass YSL ~0.52-0.95 ~0.61 ~0.62-0.72 Striped Bass PYSL ~0.50-0.95 ~0.70-0.78 ~0.68-0.80 White Perch PYSL ~0.15-0.95 ~0.19-0.85 ~0.30-0.92 Alosa spp. PYSL ~0.25-0.90 ~0.30-0.60 ~0.30-0.65 Adapted from Figures 4-8-4-10 in EA (1989) 25 H.1.2.2. Summary of Entrainment Abundance Monitoring Studies 26 During 1981, EA employed an Automated Abundance Sampler (AUTOSAM) to 27 collect icthyoplankton samples from IP2 and IP3. Middepth water samples were 28 collected twice a week during May-August from discharge station D2. Each 29 sampling effort consisted of collecting 90-minute (min) composite samples within 30 eight 3-hr sampling intervals extending over a 24-hr period. Ichthyoplankton 31 samples were sorted, identified to species and life stage, and counted (EA Draft NUREG-1437, Supplement 38 H-16 December 2008

Appendix H 1 1981b). In 1983, entrainment abundance samples were again collected at 2 discharge canal station D2 from May 3 to August 13, 1983, using the AUTOSAM 3 collector. From May 3-18, each sample consisted of a 90-min composite 4 sample within eight 3-hr sampling periods. From May 19 to August 13, the 90-5 min composites reflect a shorter collection time to reduce clogging caused by 6 the presence of detritus. Ichthyoplankton samples were sorted, identified to 7 species and life stage, and counted (EA 1984). In 1984, icthyoplankton samples 8 were collected from discharge canal station D2 from May 3 to August 11, 1984.

9 Sampling equipment, collection procedures, and sample processing were 10 consistent with past sampling efforts described above (EA 1985).

11 In 1985, ichthyoplankton samples were taken continuously (24 hr/day) from May 1 to August 11.

12 Each sample consisted of one 3-hr period, resulting in eight samples per day. Total sample 13 volumes were 150 m3. Replicate sampling to determine variance estimates was conducted on 14 Wednesdays and Thursdays of each week. Samples were collected by pumping water through 15 a 10-centimeter (cm) (4-in.) diameter pipe submerged to a depth of 3 m at discharge canal 16 Station D2 and passing the collected water into a plankton net with a codend cup. The collected 17 sample was transferred to a sample jar, preserved, and transferred to a laboratory for sorting, 18 identification to species and life stage, and enumeration (Normandeu 1987a). Pump samples to 19 quantify ichthyoplankton entrained at IP2 and IP3 were collected from May 1 to August 10, 20 1986, at discharge canal station D2. Sampling duration was 3 hr without replication from May 1 21 to May 14, and 2 hr from May 15 to August 10 to increase the number of collected samples.

22 Replicate sampling to provide variance estimates were collected 5 days per week from May 16 23 through August 10. Sampling equipment and processing were consistent with the 1985 24 sampling study (Normandeu 1987b). In 1987, pump samples to determine ichthyoplankton 25 entrainment abundance were collected 24 hr per day from May 6 to August 10 from discharge 26 canal station D2. Sample duration was 2 hr, which allowed a large number of samples to be 27 collected. Replicate sampling to provide variance estimates was collected 5 days per week 28 from May 6 to August 7 (Normandeu 1988).

29 H.1.2.3. Historic Assessment of Entrainment Impacts 30 As discussed in Sections 4.1.2.1 and 4.1.2.2, numerous studies have been conducted to 31 estimate the quantity of RIS that are entrained by the Indian Point cooling systems and evaluate 32 the survival of these species after entrainment occurs. Studies have also been conducted to 33 evaluate the trends of fish populations in the Hudson River. The applicant and NYSDEC have 34 used the results of these studies to evaluate the potential for adverse effects associated with the 35 operation of the Indian Point cooling systems. The results of these assessments are described 36 below. As described in Section 4.1.1.2, nongovernmental groups and members of the public 37 have also evaluated publicly available information and data associated with the Hudson River 38 and have expressed the opinion that many species of fish in the river are in decline and that 39 entrainment of eggs, larval, and juvenile fish at Indian Point is contributing to the decline, 40 destabilization, and ultimate loss of these important aquatic resources.

41 Applicant Assessment 42 In the environmental report for IP2 and IP3 (Entergy 2007), the applicant presents estimates of 43 CMR for American shad, Atlantic tomcod, bay anchovy, river herring, striped bass, and white December 2008 H-17 Draft NUREG-1437, Supplement 38

Appendix H 1 perch and discusses the results of the assessment conducted by Barnthouse et al. (2002). The 2 conclusions of the ER are as follows:

3 More than 30 years of extensive fisheries studies of the Hudson River in the 4 vicinity of IP2 and IP3 support current operations. The results of the studies 5 performed from 1974 to 1997, the period of time covered in the DEIS, are 6 referenced and summarized in the DEIS, and have not shown any negative 7 trend in overall aquatic river species populations attributable to plant operations.

8 Ongoing studies continue to support these conclusions [ASA]. In addition, 9 current mitigation measures implemented through the HRSA and retained in the 10 four Consent Orders, the current agreements with NYSDEC, and the outcome of 11 the draft SPDES Permit proceeding, will ensure that entrainment impacts remain 12 SMALL during the license renewal term. Therefore, withdrawal of water from 13 the Hudson River for the proposes of once-through cooling at the site does not 14 have any demonstrable negative effect on representative Hudson River fish 15 populations, nor does it warrant further mitigation measures.

16 Additional impact assessment information was also provided to the NRC staff in Barnthouse 17 et al. (2008) that used environmental risk-assessment techniques to evaluate the potential for 18 adverse impacts to Hudson River RIS from a variety of natural and anthropogenic stressors, 19 including the operation of the IP2 and IP3 cooling water intake system (CWIS), fish pressure, 20 the presence of zebra mussels, predation by striped bass, and water temperature. Summary 21 results available in Barnthouse et al. (2008) are presented in Table H-6. Using this information, 22 the authors concluded the following:

23 Considered together, the evidence evaluated in this report shows that the 24 operation of IP2 and IP3 has not caused effects on early life stages of fish that 25 reasonably would be considered adverse by fisheries scientists and/or 26 managers. The operation of IP2 and IP3 has not destabilized or noticeably 27 altered any important attribute of the resource.

Draft NUREG-1437, Supplement 38 H-18 December 2008

Appendix H 1 Table H-6 Summary of Impact Assessment for IP2 and IP3 Species Suspected Cause of Apparent Hudson River Decline CWIS and zebra mussel hypothesis rejected.

American Shad Most likely cause: fishing, with striped bass predation a potential contributing factor. (Barnthouse et al. 2008, Table 5)

CWIS hypothesis rejected.

Atlantic Tomcod Temperature a significant influence, but cannot explain post-1990 decline. Most likely cause of decline: striped bass predation. (Barnthouse et al. 2008, Table 6)

CWIS hypothesis rejected.

Bay Anchovy Striped bass predation most likely cause of change.

(Barnthouse et al. 2008, Table 8).

CWIS and zebra mussel hypothesis rejected.

River Herring Most likely cause: striped bass predation. (Barnthouse et al. 2008, Table 7).

CWIS and zebra mussel hypothesis rejected. Most likely Striped Bass cause: fishing. (Barnthouse et al. 2008, Table 3)

CWIS hypothesis rejected.

Zebra mussel and striped bass predation may have White Perch contributed to declines occurring in later years, but other unknown causes were responsible for declines occurring between 1975 and 1985. (Barnthouse et al. 2008, Table 4)

Source: Entergy 2008, adapted from Barnthouse et al. 2008 2 NYSDEC Assessment 3 In 2003, NYSDEC developed a Final Environmental Impact Statement (FEIS) (NYSDEC 2003a) 4 in response to the DEIS submitted by the operators of IP2 and IP3, Roseton, and Bowline Point 5 (CHGEC 1999). In the FEIS, NYSDEC noted that while the DEIS was acceptable as an initial 6 evaluation and assessment, it was not sufficient to stand as the final document, and additional 7 information as to alternatives and evaluation of impacts must be considered. The Public 8 Comment Summary portion of the FEIS presents a summary of comments received on the 1999 9 DEIS (CHGEC 1999); a subsequent section, Responses to Comments, provides the NYSDEC 10 reply. In response to comments associated with the cropping of fish populations by power 11 plants, NYSDEC provided a detailed response. The following excerpt is from pages 53 and 54 12 of the document:

13 Rather than selective cropping, the impacts associated with power plants are 14 more comparable to habitat degradation; the entire natural community is 15 impacted. These once-through cooling power plants do not selectively harvest December 2008 H-19 Draft NUREG-1437, Supplement 38

Appendix H 1 individual species. Rather, impingement and entrainment and warming of the 2 water impact the entire community of organisms that inhabit the water column.

3 For example, these impacts diminish a portion of the forage base for each 4 species that consumes plankton (drifting organisms in the water column) or 5 nekton (mobile organisms swimming through the water column) so there is less 6 food available for the survivors. In an intact ecosystem, these organisms serve 7 as compact packets of nutrients and energy, with each trophic (food chain) level 8 serving to capture a diffuse resource and make it more concentrated.

9 Ichthyoplankton (fish eggs, larvae and very small fish which drift in the water 10 column) and small fish feed on a base of zooplankton (drifting animal life) and 11 phytoplankton (drifting plant life). The loss of these small organisms in the 12 natural community may be a factor that leads to harmful algal blooms. The 13 small fish themselves serve as forage for the young of larger species, which 14 serve as forage for larger individuals, and so on up the food chain, more 15 correctly understood as a trophic pyramid. Once-through cooling mortality 16 short-circuits the trophic pyramid and compromises the health of the natural 17 community. For example, while an individual bay anchovy might ordinarily serve 18 as food for a juvenile striped bass or even for a common tern, entrainment and 19 passage through a power plants cooling system would render it useful only as 20 food to lower trophic level organisms. It could no longer provide its other 21 ecosystem functions of consuming phytoplankton, digesting and concentrating it 22 into its tissues, and ranging over a wide area, distributing other nutrients as 23 manure. This is just a single example from a very complex natural system, 24 where the same basic impact is multiplied millions of times over more than one 25 hundred fish species.

26 NYSDEC also expressed concern about entrainment in the 2003 Fact Sheet pertaining to 27 SPDES license renewal at IP2 and IP3 (NYSDEC 2003b, Attachment B, 1. Biological Effects):

28 1. Biological Effects 29 Each year Indian Point Units 2 and 3 (collectively Indian Point) cause the 30 mortality of more than a billion fish from entrainment of various life stages of 31 fishes through the plant and impingement of fishes on intake screens.

32 Entrainment occurs when small fish larvae and eggs (with other aquatic 33 organisms) are carried into and through the plant with cooling water, causing 34 mortality from physical contact with structures and thermal stresses.

35 Impingement occurs when larger fish are caught against racks and screens at 36 the cooling water intakes, where these organisms may be trapped by the force 37 of the water, suffocate, or otherwise be injured. Losses at Indian Point are 38 distributed primarily among 7 species of fish, including bay anchovy, striped 39 bass, white perch, blueback herring, Atlantic tomcod, alewife, and American 40 shad. Of these, Atlantic tomcod, American shad, and white perch numbers are 41 known to be declining in the Hudson River (ASA Analysis and Communications 42 2002). Thus, current losses of various life stages of fishes are substantial.

43 Finally, in the petition submitted to the NRC on November 30, 2007, regarding the relicensing of 44 IP2 and IP3 (NYSDEC 2007), the agency comments on impingement and entrainment impacts:

Draft NUREG-1437, Supplement 38 H-20 December 2008

Appendix H 1 Impingement and Entrainment Contention 2 The operation of Indian Point consumes and returns approximately 2.5 billion 3 gallons of Hudson River water each day. The River is an important estuarine 4 ecosystem, and this operation has significant adverse impacts to the fish that 5 call the Hudson home. Large fish are impinged on screens at the water intake 6 where they are severely stressed and then suffocated. Smaller fish are 7 entrained in the water intake, pulled through the operating plant and killed. This 8 relentless process has continued relatively unabated for almost 40 years, and 9 the applicant now seeks 20 more years. This must not continue because the 10 environmental costs are too high. The NRC must fully consider the alternative of 11 closed cycle cooling to mitigate these significant adverse impacts in this license 12 renewal proceeding.

13 H.1.2.4. NRC Staff Assessment of Entrainment Impacts 14 Entergy (2007b) provided to NRC weekly average densities of entrained taxa for a given life 15 stage for IP2 and IP3 for analysis. The data were collected from May to August in 1981 and 16 1983 through 1985, from January to August in 1986, and from May to August in 1987. The sum 17 of the mean densities of all life stages for a given taxon and season (January-March, April-18 June, July-September, and October-December) times the volume of circulated water was used 19 to estimate the mean number entrained per taxon and season.

20 NRC found a total of 66 taxa identified during entrainment monitoring in the data supplied.

21 There were no blue crabs, shortnose or Atlantic sturgeon, or gizzard shad identified in the 22 1981-1987 entrainment data. Because of the difficulty in identification of early life stages, RIS 23 included those taxa identified only to family or genera (herring family, Alosa spp., anchovy 24 family, and Morone spp.). The percent RIS fish entrained and total fish entrained were 25 compared to the total estimated mean number (Figure H-5). Except for 2 weeks in 1984 and 26 1985 (1 week in May and June) for which amphipods (Gammarus sp.) were recorded, the 27 percentage RIS fish entrained was greater than 90 percent of entrained taxa. The number of 28 amphipods collected in 2 weeks in 1984 was two times greater than identified fish collected over 29 15 weeks within the same year. Linear regression (n = 6; p = 0.02) indicated that the number of 30 identified fish entrained decreased at a rate of 1.6 billion fish per year, a result consistent with 31 the decrease observed in the number of fish impinged.

December 2008 H-21 Draft NUREG-1437, Supplement 38

Appendix H 100% 50 90% 45 Percent Entrained out of Total Taxa

)

80% 40 12 Total Taxa Entrained (x 10 70% 35 60% 30 50% 25 40% 20 30% 15 20% 10 10% 5 0% 0 1980 1981 1982 1983 1984 1985 1986 1987 1988

% RIS Fish  % Total Fish Total Taxa Entrained 1

2 Figure H-5 Percentage of entrainment comprised of RIS fish and total fish in relation to 3 the total estimated entrainment at IP2 and IP3 combined (data from Entergy 2007b) 4 A seasonal pattern in the percentage entrainment of each RIS out of the total RIS fish entrained 5 was evaluated (Table H-7). Entrainment of herring, American shad, Alosa spp., white perch, 6 and striped bass was mainly observed in the second quarter (April-June). Entrainment of 7 weakfish and hogchoker was mainly observed in the third quarter (July-September). Rainbow 8 smelt and Atlantic tomcod were observed in entrainment samples only in the first quarter 9 (January-March) of 1986. Based on the available information, species representing 10 percent 10 or greater of total RIS entrained for at least one sampling period were alewife, bay anchovy, 11 American shad, rainbow smelt, striped bass, Atlantic tomcod, and white perch (Table H-7).

12 Entrainment losses may affect populations directly by reducing the number of individuals 13 available for recruitment and indirectly through the removal of potential food for predators. The 14 environmental significance of entrainment is explored further in Section H.3.

15 H.1.3. Combined Effects of Impingement and Entrainment 16 The combined effects of impingement and entrainment were evaluated by the applicant in the 17 DEIS (CHGEC 1999) by estimating CMR, which is intended to represent the fractional reduction 18 in abundance of the vulnerable age groups (primarily those fish hatched during the current year) 19 from a single source. The CMR is model-dependent and has been a source of controversy 20 since it was developed. The NRC Staff analysis presented here will instead rely on the 21 extensive fishery datasets collected under the direction and oversight of the NYSDEC.

Draft NUREG-1437, Supplement 38 H-22 December 2008

December 2008 1 Table H-7 Percentage Entrainment of RIS by Year and Season (data from Entergy 2007b)

Year/ 1981 1983 1984 1985 1986 1987 Season 2 3 2 3 2 3 2 3 1 2 3 2 3 Herring Family 2.2 <0.05 40 <0.05 24 <0.05 0.3 -a - 31 <0.05 1.2 -

Blueback Herring - <0.05 <0.05 0.1 <0.05 <0.05 - <0.05 - <0.05 <0.05 - -

Alewife - - - <0.05 <0.05 - - - - <0.05 <0.05 American Shad 0.1 <0.05 0.1 <0.05 3.9 <0.05 <0.05 - - 0.1 - <0.05 <0.05 Alosa Species 7.4 <0.05 30 <0.05 36 <0.05 0.6 - 0.4 <0.05 - <0.05 -

Atlantic Menhaden - - - - - - 0.1 - - 0.3 - - -

Anchovy Family 3.1 8.2 <0.05 43 1.1 8.4 - - - - - -

Bay Anchovy 46 91 0.1 53 16 86 73 99 - 4.0 99 47 99 H-23 Rainbow Smelt - - <0.05 - 0.2 <0.05 <0.05 <0.05 64 2.0 0.2 0.8 0.1 White Catfish - - - - - <0.05 - - 0.1 <0.05 - - -

Atlantic Tomcod 0.9 - 0.1 <0.05 1.2 0.1 6.8 <0.05 34 1.8 - 1.4 <0.05 White Perch 15 0.1 14 0.6 6.0 0.4 5.8 0.1 2.3 27 0.4 8.6 0.3 Striped Bass 25 <0.05 8.0 0.8 9.4 3.0 11 <0.05 - 31 0.2 38 0.3 Morone Species - - 6.6 0.2 1.2 0.1 2.7 <0.05 - 2.9 <0.05 2.9 <0.05

- - - - - <0.05 - <0.05 - - - - -

Bluefish Weakfish - 0.3 - 1.2 - 2.2 0.1 0.7 - - 0.4 <0.05 <0.05 Hogchoker - - - <0.05 - <0.05 - - - - - - -

<0.0 Spottail Shiner 0.3 <0.05 0.6 <0.05 0.2 <0.05 0.3 - <0.05 0.3 <0.05 0.1 5

2 (a) Season 1 is January-March, 2 is April-June, 3 is July-September.

3 (b) - indicates no identified observation.

4 Units = percent Draft NUREG-1437, Supplement 38 Appendix H

Appendix H 1 The purpose of this analysis is to determine the potential for adverse impacts to the aquatic 2 resources of the Hudson River estuary associated with the operation of IP2 and IP3 once-3 through cooling systems during the relicensing period. The National Environmental Policy Act, 4 as amended (NEPA), requires an ecologically relevant analysis of potential impacts that is more 5 holistic than a general fisheries biology approach. Fisheries biology tends to focus on single 6 species issues, such as sustaining a harvest rate, no matter what the effect may be on other 7 species within the system. Thus, although still simplistic, this analysis considers potential 8 impacts across trophic levels.

9 The operation of the IP2 and IP3 cooling systems can directly affect the aquatic communities of 10 the Hudson River through impingement, entrainment, or thermal releases. Loss of YOY, 11 yearling and older fish, blue crabs (Callinectes sapidus), and other aquatic species can occur 12 from impingement against intake screens. Eggs, YSL, post-yolk-sac larvae (PYSL), and 13 juvenile fish and invertebrates small enough to pass through the intake screens (9.5-mm or 14 0.375-in. square mesh) may become entrained within the intake units of the once-through 15 cooling system and experience adverse effects associated with mechanical, chemical, and 16 thermal stressors. Releases of heated noncontact cooling water through subsurface diffuser 17 ports into the Hudson River can result in heat- or cold-shock effects. Cooling system operation 18 can also result in indirect effects to aquatic resources. Impingement may injure, stun, or 19 debilitate an organism, reducing its ability to avoid predation, capture prey, or grow and 20 reproduce in a normal manner. Entrainment of larval or small juvenile forms not resulting in 21 death may reduce viability or survival success. Entrainment can also create an indirect adverse 22 impact to estuarine food webs by removing potential prey items from predators, or altering and 23 redistributing the aquatic organic carbon represented by entrained organisms. In addition, the 24 release of heated water can result in sublethal effects, including changes in reproduction or 25 development, increased susceptibility to other environmental stressors, or behavioral changes 26 associated with avoiding thermal plumes.

27 Evaluating the potential for adverse impacts of the IP2 and IP3 cooling systems to the aquatic 28 resources of the Hudson River estuary presents a significant challenge for a variety of reasons.

29 First, the potential stressor of interest (the IP2 and IP3 cooling systems) occupies a fixed 30 position on the Hudson River, while RIS associated with the Hudson River generally have large 31 spatial and temporal distributions that can change for each life stage. Thus, evaluation of 32 causal relationships between potential stressors and receptors is difficult and requires a 33 systems-level understanding that may not be possible with existing environmental information.

34 Second, the Hudson River estuary represents a dynamic, open-ended system containing a 35 complex food web that is hydrologically connected from freshwater locations near the Troy Dam 36 to the Atlantic Ocean. Detectible trends at population levels that suggest adverse effects may 37 be attributable to a variety of anthropogenic and natural stressors, including the activities at IP2 38 and IP3. Finally, because the Hudson River estuary represents a complex system with 39 hundreds of aquatic species, it is necessary to focus primarily on a subset of RIS. While this 40 simplifies the assessment of impact, it also introduces additional uncertainties that must be 41 acknowledged and addressed.

42 The GEIS defines impingement, entrainment, and heat shock from cooling system operation as 43 Category 2 issues requiring site-specific review. Levels of impact associated with these issues 44 are defined as potentially SMALL, MODERATE, or LARGE, consistent with the criteria that the 45 NRC established in Footnote 3 to Table B-1, Appendix B, 10 CFR Part 51, as follows:

Draft NUREG-1437, Supplement 38 H-24 December 2008

Appendix H 1

• SMALLEnvironmental effects are not detectable or are so minor that they will neither 2 destabilize nor noticeably alter any important attribute of the resource.

3

• MODERATEEnvironmental effects are sufficient to alter noticeably, but not to 4 destabilize, any important attributes of the resource.

5

• LARGEEnvironmental effects are clearly noticeable and are sufficient to destabilize 6 any important attributes of the resource.

7 To evaluate whether the operation of the IP2 and IP3 cooling systems adversely affects RIS, 8 NRC Staff employed a modified weight-of-evidence (WOE) approach as represented in Figure 9 H-6. The approach used impingement and entrainment monitoring data obtained from the IP2 10 and IP3 facilities, data from the lower Hudson River collected during the Long River Survey 11 (LRS), Fall Juvenile/Fall Shoals Survey (FJS/FSS), and Beach Seine Survey (BSS), as 12 described in Table 2-3 in the main text, and coastal fishery trend data, when available. Lines of 13 evidence (LOE) associated with the population trends and strength of connection were 14 developed. The WOE is a technique used to integrate multiple LOE, or types of variables, to 15 make a single decision concerning the magnitude of impact and its association with a potential 16 stressor (IP2 and IP3 cooling systems). The WOE approach employed was based on Menzie et 17 al. (1996) and consisted of the following steps depicted in Figure H-7:

18 (1) Identify the environmental component or value to be protected.

19 (2) Develop LOE and quantifiable measurements to assess the potential for adverse 20 environmental effects and evaluate whether the IP2 and IP3 cooling systems are 21 contributing to the effect.

22 (3) Quantify the use and utility of each measurement for supporting the impact assessment.

23 (4) Develop quantifiable decision rules for interpreting the results of each measurement.

24 (5) Use the WOE to integrate the results, assign a level of potential impact, and determine if 25 adverse effects in RIS populations, if present, are related to the operation of the IP2 and 26 IP3 cooling systems.

27 December 2008 H-25 Draft NUREG-1437, Supplement 38

Appendix H 18 Representative Important Species River Data for Each Species In-Plant Data for Each Species

1) Monitoring Surveys (LRS, FJS, BSS) 1) Impingement of RIS

-River Segment Measurements 2) Impingement of Prey

-River-wide Measurements 3) Entrainment of RIS

2) Coastal Assessment (Literature) 4) Entrainment of Prey Line of Evidence: Line of Evidence:

Population Trend Strength of Connection of for Each Species Indian Point to Each Species Evaluate Data Evaluate Data To Determine WOE Score To Determine WOE Score Decision for Level of Impact to Population of Each Species Attributable to IP Cooling System Operation 1

2 Figure H-6 General weight-of-evidence approach employed to assess the level of impact 3 to population trends attributable to IP cooling system operation 4 These steps are discussed below in more detail. Supporting information for the statistical 5 analyses used in this determination is presented in Appendix I. A WOE approach was not used 6 to evaluate thermal effects, because recent monitoring or modeling data were not available.

Step 1: Identify Value to Be Protected:

Aquatic Resources as Represented by 17 RIS Step 2: Develop Lines of Evidence and Associated Measurements Step 3:Assess Use and Utility of measurement Assign Score Use and Utility type Define 7 Attributes Take Average Score Weight of Evidence Integrate Score Step 4: Determine Decisions Rules Evaluate data Result Score for each measurement Per rules Step 5: Assign Impact Category for Both Line of Evidence Integrate Impact Categories Impact of Indian Point For Each Population of for Both Lines of Evidence Cooling System on Representative Important Species Each RIS Species 7

8 Figure H-7 Steps used to conduct the weight-of-evidence assessment Draft NUREG-1437, Supplement 38 H-26 December 2008

Appendix H 1 Step 1: Identify the Environmental Component or Value To Be Protected 2 For this assessment, the environmental component to be protected is the Hudson River aquatic 3 resources as represented by the 18 RIS identified in Table 2-4 in the main text. These species 4 represent a variety of feeding strategies and food web classifications and are considered 5 ecologically, commercially, or recreationally important. The WOE approach focuses primarily on 6 the potential impacts to YOY and yearling fish and their food sources. Although eggs, larvae, 7 and PYSL are important components to the food web, the natural mortality to these life stages is 8 high, as noted by Barnthouse et al. (2008) and Secor and Houde (1995). In contrast, fish 9 surviving to YOY and older are more likely to add to the adult breeding population and are at 10 greater risk from the cooling system operation. Any factor that increases (or decreases) the 11 survival of those fish during juvenile and yearling stages can affect the sustainability of the 12 population.

13 The conceptual model considers that the dynamics of the system are subject to large changes 14 based on a wide variety of controlling factors. Phytoplankton and zooplankton communities 15 form the basis of the food web and are used by a variety of fish and invertebrates during their 16 development from larvae to adults. Plankton abundances generally increase during the spring 17 and summer, coinciding with the emergence of larval and juvenile forms of fish and 18 invertebrates after spawning. For some species, such as striped bass, PYSL and juvenile forms 19 initially eat small, planktonic prey, then switch to larger prey as they grow. For other species, 20 such as herring and alosids, adults remain planktivores. Predator-prey relationships within the 21 estuary are complex and are influenced by a variety of physical, chemical, spatial, and temporal 22 factors. Within this system, predation may be inter- or intraspecific, and operate at a variety of 23 levels simultaneously. There are also a variety of controlling factors that may exert influence on 24 the estuarine food web and inhabitants of the estuary. Physical and chemical fluctuations can 25 serve as cues for reproduction and promote or inhibit growth, the nature and extent of predation 26 can result in shifts in food web dynamics, and the influence of invasive or exotic species and 27 anthropogenic activities can affect year-classes or result in long-term changes to populations.

28 After reviewing available information, the NRC staff could not determine if the operation of the 29 IP2 and IP3 cooling systems is adversely affecting the RIS through the phytoplankton and 30 zooplankton populations present near the facilities. It is possible, however, that the entrainment 31 of these food web constituents can alter or influence the food web by removing potential prey 32 items from the water column and reintroducing and redistributing them in the river in an altered 33 state. As a result, the form and distribution of organic carbon can be fundamentally changed, 34 even though the overall mass-balance remains the same. A similar effect may exist for larval 35 forms that experience entrainment and are thus unavailable in their natural state for predation.

36 Impingement losses may also alter the food web by removing potential predator or prey items 37 from the system or by changing the dynamics of the relationships at critical periods. At the 38 higher levels of the food web, large predators such as bluefish, weakfish, and striped bass may 39 be affected by alterations to the food web in ways that are not always obvious. For instance, 40 work by Baird and Ulanowicz (1989) suggested that, even though striped bass and bluefish in 41 the Chesapeake Bay ecosystem were both piscivorous predators, 63 percent of the bluefish 42 intake depended indirectly on benthic organisms, whereas striped bass depended mainly on 43 planktonic organisms.

44 Within this food web context, the IP2 and IP3 cooling systems can be viewed as hybrid 45 predators. Although the operation of the cooling water systems exerts a predatory effect at December 2008 H-27 Draft NUREG-1437, Supplement 38

Appendix H 1 multiple levels within the estuarine food web, the fixed position of the plants in the environment, 2 their relatively continuous operation, and their lack of sensitivity to traditional environmental 3 stressors that affect predators place them in a unique position within the estuarine system. The 4 cooling system also functions as an environmental sampling device through impingement and 5 entrainment. To fully explore the potential adverse impacts of cooling system operation to the 6 aquatic resources of the Hudson River estuary, it is necessary to examine both the direct 7 impacts associated with losses caused by impingement, entrainment, and heat, and the indirect 8 impacts of these potential stressors that may work through the food web and contribute to 9 detectible long-term changes to RIS populations.

10 Step 2: Identify Lines of Evidence and Quantifiable Measurements 11 The LOE and measurements used by NRC Staff to assess the impacts of the IP2 and IP3 12 cooling systems on RIS in the Hudson River estuary are presented in Table H-8. The first LOE 13 (LOE-1) was a population-trend analysis using data from the three surveys conducted for the 14 Hudson River utilities and from recent coastal fisheries information, when available. Population 15 trends over time are often used to assess long-term changes in population abundance or 16 species composition and to provide information on sustainability.

17 For Measure 1-1, the river-segment trends were based on the fish caught within River 18 Segment 4 (IP2 and IP3) or, if this sampling area had a consistently low catch, an adjoining 19 segment (River Segments 2 through 6), whichever had a greater catch (Figure 2-6 in the main 20 text). The river-segment data were the weekly catch-per-unit-effort (CPUE) and catch density 21 from the FJS, BSS, and LRS. The annual estimate of the population response was the 75th 22 percentile of the weekly data for a given year, because it was not as sensitive as the mean to 23 the few large observations collected each year.

24 For Measure 1-2, riverwide population trends were based on the annual CPUE and the annual 25 abundance index derived by the applicant. Commercial harvest data were used to represent 26 coastal population trends. Population trends also formed the basis of the WOE analysis used 27 by the NRC staff to assess the cumulative impacts of IP2 and IP3 activities, as well as other 28 anthropogenic and natural environmental stressors, including the potential effects of zebra 29 mussels in the freshwater portion of the Hudson River.

30 Table H-8 Lines of Evidence and Measurements Used To Assess Cooling System 31 Impacts LOE-1: ASSESSMENT OF POPULATION TRENDS OF RIS River-segment RIS population trends from FSS and BSS Measurement 1-1 (and LRS for tomcod)

Riverwide RIS population trends from FSS and BSS (and Measurement 1-2 LRS for tomcod)

Coastal population trends from State or Federal regulatory Measurement 1-3 agency databases Draft NUREG-1437, Supplement 38 H-28 December 2008

Appendix H 1 Table H-8 (continued)

LOE-2: ASSESSMENT OF STRENGTH OF CONNECTION Measurement 2-1 Impingement of RIS Measurement 2-2 Entrainment of RIS Measurement 2-3 Impingement of RIS prey Measurement 2-4 Entrainment of RIS prey 2 The second LOE (LOE-2) measures the strength of the connection between the operation of the 3 IP2 and IP3 cooling systems and the aquatic resources in the Hudson River. NRC Staff derived 4 measurements of connection strength from monitoring data at IP2 and IP3 from 1975-1990 that 5 provide information on impingement and entrainment rates for RIS and prey of RIS. As 6 discussed above, the operation of the cooling system can result in direct mortality of RIS or may 7 debilitate or damage organisms in a manner that causes latent mortality.

8 Impingement and/or entrainment can also remove and reintroduce RIS prey into the aquatic 9 system in a manner that alters food web dynamics and produces indirect effects that may result 10 in decreased recruitment, changes in predator-prey relationships, changes in population feeding 11 strategies, or movements of populations closer to or farther away from the cooling system 12 intakes or discharges. Staff based the analysis of impingement on the concordance of two 13 ranked proportions. The first proportion was the ratio of the number of YOY and yearling fish of 14 each species impinged in relation to the sum of all fish impinged. The second proportion was 15 the ratio of each species abundance in the river near IP2 and IP3 relative to the total abundance 16 of all 18 RIS. A large rank for both proportions would mean that the proportion impinged for the 17 given RIS and the proportion abundance in the river were both large. The ratio of these two 18 ranks would then be close to 1, suggesting that the stationary sampler was sampling 19 proportionately to the abundance in the river (a medium strength of connection).

20 Likewise, NRC Staff based the effects of entrainment on the concordance of two ranked 21 proportions. The first proportion was the estimated number entrained for all life stages for a 22 given species in relation to the abundance of all fish entrained. The second proportion was the 23 ratio of each species abundance in the river near IP2 and IP3 relative to the total abundance of 24 all RIS. The estimated number entrained was the sum of the mean density for each life stage 25 and sampling date within a given quarter of the year multiplied by the volume of circulated water 26 (flow). Staff also considered potential food web impacts to RIS associated with the loss of prey 27 caused by impingement or entrainment, based on the relationship presented in the conceptual 28 model.

December 2008 H-29 Draft NUREG-1437, Supplement 38

Appendix H 1 Step 3: Quantify the Use and Utility of Each Measurement 2 The following attributes of each measurement within each LOE were adapted from Menzie et al.

3 (1996) and were assigned an ordinal score corresponding to a ranking of its use and utility as 4 low (1), medium (2), or high (3).

5 (1) Strength of Association Between the Measured Parameter and the Aquatic 6 Communitythe extent to which the measurement parameter is representative of, 7 correlated with, or applicable to the assessment of the target fish community 8 (2) Stressor-specificitythe extent to which the measurement parameter is associated with 9 the specific stressor (e.g., impingement mortality) 10 (3) Site-specificitythe extent to which data, media, species, environmental conditions, and 11 other factors relate to the site of interest 12 (4) Sensitivity of the Measurement Parameter for Detecting Changesthe ability to detect a 13 response in the measurement parameter 14 (5) Spatial Representativenessthe degree of compatibility between the study area, 15 location of measurements or samples, locations of stressors, and locations of biological 16 receptors and their points of exposure 17 (6) Temporal Representativenessthe temporal compatibility between the measurement 18 parameter and the period during which effects of concern would occur 19 (7) Correlation of Stressor to Responsethe degree to which a correlation is observed 20 between levels of response, and the strength of that correlation 21 Staff then calculated overall use and utility scores for each measurement within each LOE as 22 the average of the individual attribute scores. For a given LOE, the average score for all 23 attributes was used to characterize the overall use and utility of the measurement as low, 24 medium, or high, using the following definitions:

25

• low use and utilityoverall score of <1.5 (questionable for decision-making) 26

• medium use and utilityoverall score of 1.5 and 2 (adequate for decision-making) 27

• high use and utilityoverall score of >2 (very useful for decision-making) 28 The results of these evaluations are presented for each LOE and supporting measurements in 29 Tables 4-2 and 4-3. For LOE-1, RIS population trends, measurements with the highest use and 30 utility are those that provide information on long-term trends in RIS populations at river-segment 31 and riverwide scales (Table H-9). Comprehensive data sets extending over 30 years yield high 32 use and utility for assessing impacts. As measurements of populations become more spatially 33 distributed, the ability to use the measurement to assess impacts associated with IP2 and IP3 34 decreases.

35 When assessing the strength of the connection between the IP2 and IP3 cooling systems and 36 the aquatic environment (i.e., the ability of the IP2 and IP3 cooling systems to affect RIS 37 populations in the Hudson River estuary), measurements associated with loss of prey caused 38 by entrainment have the highest use and utility values (Table H-10) because stressor-specificity 39 is higher than for the other measures. Even though the sensitivity of the measure is lower 40 because of food web complexities, the loss of a food base for YOY predators has a greater Draft NUREG-1437, Supplement 38 H-30 December 2008

Appendix H 1 impact on more individuals than the direct loss of single individuals. While the evaluation of 2 food-web impacts associated with the impingement and entrainment of RIS prey is complex, 3 other investigators have found that alterations to lower levels of complex food web relationships 4 result in measurable impacts at higher trophic levels. For instance, work by Ulanowicz (1995) 5 suggests that when ecosystems are disturbed or stressed, the resulting changes in carbon flow 6 can result in the disappearance of higher trophic-level predators or a reallocation of trophic 7 positioning at the higher levels. Frank et al. (2007) report the potential for a top-down 8 response that can affect lower trophic level prey items, though the existence of this 9 phenomenon is debatable.

10 Table H-9 Use and Utility of Each Measurement Type To Evaluate RIS Population Trends 11 Potentially Associated with IP2 and IP3 Cooling System Operation River-Riverwide Coastal Segment RIS RIS Use and Utility Attribute RIS Community Community Community Trends Trends Trends Strength of Association between 3 2 1 Measurement and Community Response Stressor-specificity 2 1 1 Site-Specificity of Measurement in 2 1 1 Relation to the Stressor Sensitivity (Variability) of Measurement 2 2 1 Spatial Representativeness 3 2 1 Temporal Representativeness 3 3 3 Correlation of Stressor to Response 2 1 1 Overall Utility Score 2.4 1.7 1.3 (a)

Overall Assessment High Medium Low (a) Overall Assessment: scores <1.5: low utility (questionable use for decision-making); 1.5 scores 2.0: medium utility (adequate for decision-making); scores >2.0: high utility (very useful for decision-making)

December 2008 H-31 Draft NUREG-1437, Supplement 38

Appendix H 1 Table H-10 Use and Utility of Each Measurement Type To Evaluate the Strength of 2 Connection between the IP2 and IP3 Cooling Systems and Hudson River RIS Populations RIS RIS RIS Prey RIS Prey Use and Utility Attribute Impinged Entrained Impinged Entrained Strength of Association between Measurement and Community 1 1 1 3

Response

Stressor-Specificity 2 2 2 3 Site-Specificity of Measurement in 2 2 2 2 Relation to the Stressor Sensitivity (Variability) of 2 1 2 1 Measurement Spatial Representativeness 3 3 3 3 Temporal Representativeness 2 1 2 1 Correlation of Stressor to Response 1 1 2 2 Overall Utility Score 1.9 1.6 2.0 2.1 (a)

Overall Assessment Medium Medium Medium High (a) Overall Assessment: scores <1.5: low utility (questionable use for decision-making); 1.5 scores 2.0: medium utility (adequate for decision-making); scores >2.0: high utility (very useful for decision-making) 3 Step 4: Develop Quantifiable Decision Rules for Interpreting the Results of Each Measurement 4 For all population trend assessments in the first LOE, NRC Staff used a two-step process to 5 assign the level of potential for an adverse impact suggested by a given measurement. The first 6 step was to evaluate the shape of the resulting best-fit model and the second step was to 7 evaluate the annual variability in the data to determine whether or not the abundance data could 8 support a claim of potential adverse impact. The shape of the trend data was evaluated using 9 simple linear regression and segmented regression as a function of time with a single join point 10 (see the statistical approach below and Appendix I for specific details). The segmented 11 regression analysis allowed a delayed response and two time periods to evaluate trends. The 12 model with the smallest error mean square was chosen as the better fit and used to assess the 13 level of potential adverse impact. In the second step, staff used the proportion of data outside a 14 defined level of noise to assess whether the potential adverse impact could be supported.

15 Based on four possible outcomes, the following decision rules were used to evaluate RIS 16 population trend data. A population trend result score of either 1, 2, or 4 is assigned as follows:

17

• A SMALL potential for an adverse impact to an RIS population was determined if 18 population trends had slopes that were not significantly different from zero (i.e., no 19 detectable slope) and had 40 percent annual abundances falling outside a 20 predetermined level of noise (defined here as +/-1 standard deviation from the mean of 21 the first 5 years of data). This suggested that the RIS population had not changed 22 detectably over time, and adverse environmental impacts were unlikely. Measurements 23 satisfying this description were assigned a result score of 1.

Draft NUREG-1437, Supplement 38 H-32 December 2008

Appendix H 1

• A MODERATE potential for an adverse impact to an RIS population was determined if 2 population trends had slopes that were not significantly different from zero (i.e., no 3 detectable slope) but had greater than 40 percent of abundance observations outside 4 the defined level of noise. If this response was observed, an adverse environmental 5 impact was probable. Measurements satisfying this description were assigned a result 6 score of 2.

7

• A MODERATE potential for an adverse impact to an RIS population was determined if 8 population trends with slopes that were significantly different from zero (i.e., detectable 9 slope) but had 40 percent annual abundances falling outside a predetermined level of 10 noise. If this response was observed, an adverse environmental impact was probable 11 but estimated below the detection limit set by the annual variability. Measurements 12 satisfying this description were assigned a result score of 2.

13

• A LARGE potential for an adverse impact to an RIS population was determined if 14 population trends had slopes that were significantly different from zero (i.e., detectable 15 slope) and had greater than 40 percent of annual abundance outside the defined level of 16 noise (i.e., support for potential impact). This response was considered clearly 17 noticeable, and an adverse environmental impact was likely. Measurements satisfying 18 this description were assigned a result score of 4.

19 This 1224 ranking is sometimes called standard competition ranking.

20 To evaluate the strength of connection between the operation of the IP2 and IP3 cooling 21 systems and the observed RIS population declines, decision rules were developed for 22 assessing the influence of impingement and entrainment directly on RIS and the potential 23 effects on RIS food web dependencies caused by loss of prey to impingement and entrainment.

24 Details of the development of the ratio of ranked proportions are discussed in the statistical 25 approach below and in Appendix I. A strength-of-connection result score of 1, 2, or 4 is 26 assigned as follows:

27

• Low Strength of Connection: The ratio of ranked proportions of impinged or entrained 28 RIS or RIS prey relative to total impingement or entrainment and the ranked proportion 29 of the population size in the river relative to the total RIS abundance is less than 0.5.

30 The species is considered underrepresented in the cooling system impingement or 31 entrainment samples, and thus, there is minimal evidence to suggest the IP2 and IP3 32 cooling systems are affecting the RIS. Measurements satisfying this description were 33 assigned a result score of 1.

34

• Medium Strength of Connection: The ratio of ranked proportions of impinged or 35 entrained RIS or RIS prey relative to total impingement or entrainment and the ranked 36 proportion of the population size in the river relative to the total RIS abundance is greater 37 than or equal to 0.5 and less than 1.5. The species is considered proportionally 38 represented in the cooling system impingement or entrainment samples, and thus, there 39 is some evidence to suggest the IP2 and IP3 cooling systems are affecting aquatic 40 resources. Measurements satisfying this description were assigned a result score of 2.

41

• High Strength of Connection: The ratio of ranked proportions of impinged or entrained 42 RIS or RIS prey relative to total impingement or entrainment and the ranked proportion 43 of the population size in the river relative to the total RIS abundance is greater than or December 2008 H-33 Draft NUREG-1437, Supplement 38

Appendix H 1 equal to 1.5. The species is considered overrepresented in the cooling system 2 impingement or entrainment samples, and thus, there is strong evidence to suggest the 3 IP2 and IP3 cooling systems are affecting the RIS. Measurements satisfying this 4 description were assigned a result score of 4.

5 Step 5: Integrate the Results and Assess Impact 6 NRC Staff derived separate WOE scores for the population trend LOE and the strength of 7 connection LOE. The above decision rules enabled the NRC to assign levels of impact to RIS 8 populations and strength of connection between the IP2 and IP3 cooling systems and the 9 observed RIS population declines with the weighted mean equation:

(overall utility score )(decision rule result score )

i i 10 WOE Score = i

,

overall utility score i

i 11 where i = 1 to the number of measurements; the overall utility score i is defined in Tables H-9 12 and H-10; and the result score i equals 1, 2, or 4, based on the above decision rules.

13 For population trend analyses, impact categories were defined as follows:

14

• small impact: WOE score <1.5 15

• small-moderate impact: WOE score = 1.5 16

• moderate impact: WOE score >1.5 but <2.0 17

• moderate-large: WOE score = 2.0 18

• large: WOE score >2 19 Staff used a similar scaling system to evaluate the strength of connection between the operation 20 of the IP2 and IP3 cooling systems and the observed RIS population decline, using the primary 21 scaling terms low, medium, and high.

22 The resulting impact categories for the population trend and strength of connection LOE were 23 then integrated by applying the logic developed by EPA for evaluating the ecological effects of 24 environmental stressors (EPA 1998). Ecological risk assessment (EPA 1998) requires a 25 connection between the stressor and the response to assign any level of impact. For the 26 purpose of this assessment, the stressor is the IP2 and IP3 cooling systems, while the receptor 27 is the aquatic community, as represented by the RIS populations, and the degree of exposure is 28 quantified by the strength of connection.

29 Statistical Approach for Each Line of Evidence 30 The decision rules developed above to determine the level of adverse impact to the aquatic 31 resources of the Hudson River estuary associated with the operation of the IP2 and IP3 once-32 through cooling systems use (1) population trend data to provide a measure of potential impacts 33 to the aquatic resources, and (2) impingement and entrainment data to provide a measure of 34 the strength of connection between IP2 and IP3 operations and the aquatic environment. The 35 statistical approach used to evaluate each measurement is described below. Results were Draft NUREG-1437, Supplement 38 H-34 December 2008

Appendix H 1 compared to the decision rules to assign a result score that was then integrated using the 2 weighted mean presented above. WOE was then used to integrate the measures of potential 3 impact with the measures of strength of connection to assign a level of impact attributable to the 4 operation of the IP2 and 3 cooling systems.

5 Statistical Approach to Assessing Long-Term RIS Population Trends: Simple linear regression 6 and segmented regression with a single join point were statistically fit to an annual measure of 7 abundance (y) for each RIS using Prism Version x, 2005. The form of the segmented 8 regression model was:

a + S1 x for x < J p 9 y=

a + J p ( S1 S 2 ) + S 2 x for x J p 10 where x was the year, a was the intercept, S1 and S2 were early (associated with years < Jp) and 11 recent slopes of the line, and Jp was the estimated point in time when the slope changed 12 (i.e., the join point). The model with the smallest mean squared error (MSE) was chosen as the 13 better fit to the data. If the best-fit model was the simple linear regression and the slope was 14 statistically significant (negative or positive, = 0.05), a population trend was detected. If the 15 slope was not significantly different from zero, then a population trend was not detected. If the 16 best-fit model was the segmented regression and either slope, S1 or S2, was statistically 17 significant ( = 0.05), then a population trend was considered detected. If both slopes S1 and 18 S2 were not significantly different from zero ( = 0.05), then the trend was not considered 19 detected. Note that an NRC impact level of small (value = 1) was defined as the lowest level of 20 potential adverse impact.

21 To evaluate whether abundance data were indicative of potential aquatic impacts, staff 22 standardized all data by subtracting the mean of the first 5 years of data and then dividing by 23 the standard deviation based on all years of data. The first 5 years (1979-1983) were chosen 24 as the standard because the CV of abundance either leveled out at n = 5, or it was preceded by 25 a rapid change in direction (Figure H-8). For density and CPUE data, staff compared population 26 trends between the BSS and FJS to determine if the shift from the epibenthic sled to the beam 27 trawl in 1985 was influencing the shape of the response. If the FJS data had standardized 28 observations consistently less than the standardized BSS data after 1985, then the FJS data 29 were split into pre- and post-1985 for analysis.

December 2008 H-35 Draft NUREG-1437, Supplement 38

Appendix H 160%

140%

120%

100%

CV 80%

60%

40%

20%

0%

n=3 n=4 n=5 n=6 n=7 n=8 n=9 n=10 Number of Years of Data Alewife Bay Anchovy American Shad Bluefish Hogchoker Blueback Herring Rainbow Smelt Spottail Shiner Stripped Bass Atlantic Tomcod White Catfish White Perch Weakfish 1

2 Figure H-8 Coefficient of variation of the abundance index for an increasing number of 3 data points (data from Entergy 2007b) 4 An assessment of adverse impact was only supported if greater than 40 percent of the 5 standardized observations were outside the bounds of +/- 1. For a normal bell-shaped 6 distribution with a mean of zero and a standard deviation of one, 32 percent of the observations 7 are outside the bounds of +/- 1 standard deviation (Snedecor and Cochran 1980). Thus, 8 observations outside the boundaries of +/-1 standard deviation from the mean of the first 5 years 9 were considered outside of the natural variability (noise). If greater than 40 percent of the 10 standardized observations were outside this defined level of noise, then a potential for adverse 11 impact was considered supported. Table H-11 provides an overview of the eight possible 12 outcomes for the assessment.

13 Table H-11 Comparison of Possible Outcomes When Assessing Population Trends of 14 RIS in the Hudson River Studies Statistical Outcome Potential for Impact Best-fit Model Significant Slope(s) Noise 1 and Result Score No No Small1 Simple Linear No Yes Moderate2 Regression Yes No Moderate2 Yes Yes Large3 Neither No Small1 Segmented Neither Yes Moderate2 Regression Either or Both No Moderate2 Either or Both Yes Large3 1

Noise: Absolute values for 40 percent of standardized observations greater than 1.

Draft NUREG-1437, Supplement 38 H-36 December 2008

Appendix H 1 Statistical Approach to Assessing Strength of Connection: To determine the strength of 2 connection between the operation of the IP2 and IP3 cooling systems and the RIS that exist in 3 the Hudson River near the facility, NRC Staff evaluated the two types of environmental 4 samplers: (1) impingement and entrainment data obtained from the operators of IP2 and IP3 (a 5 stationary environmental sampler along the shore of the Hudson) and (2) long-term aquatic 6 resource studies conducted in the river by power plant operators under the supervision of State 7 agencies (e.g. LRS, FJS, BSS). The null hypothesis was that the proportional representation of 8 RIS obtained from the fishery studies should be equal to the proportional representation evident 9 from the impingement and entrainment samples. The nature of this relationship was explored 10 for each RIS, and the overall strength of connection was evaluated by comparing concordance 11 of ranks as described below.

12 When evaluating the proportional representation, the focus is on comparing the results obtained 13 from impingement and entrainment samples at the IP2 and IP3 facilities with the representation 14 observed in the aquatic community near the facility. Using entrainment as an example, Table 15 H-12 provides an overview of the three possible outcomes for the comparison.

16 Table H-12 Comparison of Possible Outcomes When Assessing Proportional 17 Representation of RIS in Cooling System and Fishery Studies Outcome Result The proportional representation of a given RIS in the cooling system entrainment samples ( E i ) is equal to the proportional E RIS Ei Si

= representation obtained from the fishery studies ( Si ),

E RIS S RIS S RIS suggesting the RIS is equally represented in both the cooling system samples and fishery studies.

The proportional representation in the cooling system entrainment Ei < Si samples is less than the representation observed in the fishery E RIS S RIS studies, suggesting the cooling system sampler is underrepresenting the Hudson River population near IP2 and IP3.

The proportional representation in the cooling system entrainment Ei > Si samples is greater than the representation observed in the fishery E RIS S RIS studies, suggesting the cooling system sampler is overrepresenting the Hudson River population near IP2 and IP3.

18 An estimate of the population abundance of a given species (Si) in the vicinity of IP2 and IP3 19 was the maximum of the annual density of a given species caught (sum of FJS and BSS 75th 20 percentile of weekly densities) in the river segment near IP2 and IP3 over all years (1975-21 1990). The estimate of the total RIS community abundance (SRIS) caught in the vicinity of IP2 22 and IP3 was the sum of the maximum densities of each species. The estimated density of each 23 species impinged or entrained was the 75th percentile of the annual density impinged or 24 entrained over all years and the estimated density of all RIS impinged or entrained was the sum 25 over all species. An estimate of E i was the ratio of the density of an individual species E RIS December 2008 H-37 Draft NUREG-1437, Supplement 38

Appendix H 1 collected by the plant to the IP2 and IP3 river-segment CPUE plus the density entrained of that 2 individual species. Because of the error and bias in estimating each of these parameters, only 3 the ranks of each ratio were considered a reliable measure of connection. Thus, to estimate the 4 overall strength of connections between the IP2 and IP3 cooling systems and the RIS in the 5 Hudson River near the facility, the estimates of E i and Si for each species were ranked E RIS S RIS 6 from 1 to 18, and then the ratio of the ranks was compared to the decision rules.

7 H.1.3.1. Assessment of Population Trends 8 Studies Used To Evaluate Population Trends 9 The Hudson River utilities conducted the LRS from 1974 to 2005 and targeted fish eggs, YSL, 10 and PYSL from the George Washington Bridge (river mile (RM) 12) to the Federal Dam at Troy 11 (RM 152), a total of 140 miles (CHGEC et al. 1999). Sampling was conducted during the 12 spring, summer, and early fall, using a stratified random design based on 13 regions and three 13 strata within each region (channel, shoal, and bottom). A 1-m2 Tucker trawl was used to sample 14 the channel strata; an epibenthic sled-mounted 1-m2 net similar in design to the Tucker trawl 15 was used to sample the bottom strata, and both gear types were used to sample the shoal 16 strata. Because this survey targeted younger life stages, staff did not use the LRS in this 17 analysis except for YOY Atlantic tomcod data.

18 The utilities FJS, also known as the FSS, was conducted from 1974 to 2005 and targeted 19 juveniles, yearlings, and older fish (CHGEC et al. 1999). Samples were collected on alternate 20 weeks from the BSS between Manhattan (RM 0) and the Troy Dam (RM 152) using a stratified 21 random design. Data were used to estimate the abundance of YOY and older fish in offshore 22 habitats. Approximately 200 samples were collected each week from July to December.

23 Between 1974 and 1984, a 1- m2 Tucker trawl with a 3-mm mesh was used to sample the 24 channel and a 1-m2 epibenthic sled with a 3-mm mesh was used to sample the bottom and 25 shoal strata. From 1985 to 2005, a 3-m beam trawl with a 38-mm mesh on all but the cod-end 26 replaced the epibenthic sled. Bay anchovy, American shad, and weakfish were sampled with 27 less efficiency with the beam trawl (NYPA 1986). Further, the number and volume of samples 28 in the bottom and shoal strata were generally greater than 2.5 times those in the channel. Thus, 29 all data were evaluated to determine if a shift in the gear type was affecting the observed trend.

30 When the standardized FJS data were consistently less than the standardized BSS data after 31 1985, staff analyzed the pre- and post-1985 data separately.

32 The utilities BSS was conducted from 1974 to 2005 and targeted YOY and older fish in the 33 shore-zone (extending from the shore to a depth of 10 ft) (CHGEC et al. 1999). Samples were 34 collected from April to December but generally every other week from mid-June through early 35 October between the George Washington Bridge (RM 12) and the Troy Dam (RM 152). A 36 100-ft bag beach seine was used to collect 100 samples during each sampling period from 37 beaches selected according to a stratified random design. A completed tow covers an area of 38 approximately 450 m2.

39 NRC Staff obtained coastal population trends for striped bass, American shad, Atlantic 40 sturgeon, river herring, bluefish, Atlantic menhaden, and weakfish from commercial and 41 recreational harvest statistics gathered by the Atlantic States Marine Fisheries Commission 42 (ASMFC). Currently, the ASMFC Interstate Fisheries Management Program coordinates the Draft NUREG-1437, Supplement 38 H-38 December 2008

Appendix H 1 conservation and management of 22 Atlantic coastal fish species or species groups. For 2 species that have significant fisheries in both State and Federal waters, the Commission works 3 cooperatively with the relevant East Coast Regional Fishery Management Councils to develop 4 fishery management plans. The Commission also works with the National Marine Fisheries 5 Service to develop compatible regulations for Federal waters. For each of the managed 6 species, the Commission conducts periodic stock assessments. Information on each of the 7 managed species can be found at http://www.asmfc.org/.

8 Data from all three field surveys from the Hudson River Estuary Monitoring Program (LRS, FJS, 9 and BSS) were provided for this analysis. The three data sets included the annual abundance 10 index per taxon and life stage from 1974 through 2005, the annual total catch and volume 11 sampled per taxon from 1974 through 2005, and the weekly total volume sampled, catch 12 density, and total catch for each river segment and life stage for the 17 RIS fish from 1979 13 through 2005. The weekly volume, total catch, and catch density were the combined results of 14 each gear type. Analysis of the river-segment and riverwide trends provided a measure of 15 potential injury. Assessment of coastal harvest data obtained through the literature was 16 conducted visually, using the same decision rules derived for the Hudson River data.

17 Metrics Used by NRC Staff To Evaluate Population Trends 18 Abundance Index 19 The abundance index for YOY for each species was based on the catch from a selected 20 sampling program and used by the applicant and its contractors to estimate riverwide mean RIS 21 abundances. The selection process considered the expected location of each species in the 22 river, based on life-history characteristics and the observed catch rates from previous sampling.

23 The abundance index was constructed to account for the stratified random sampling design 24 used by each of the surveys. For the LRS and the FSS, sampling within a river segment was 25 further stratified by river depth and sampled with a separate gear type. For blueback herring, 26 alewife, bay anchovy, hogchoker, weakfish, and rainbow smelt, the YOY abundance index was 27 based on the catch from a single gear type.

28 The LRS (LA) and the FJS abundance index (FA) were similarly constructed and provided 29 unbiased estimates of the total and mean riverwide population abundance for selected species, 30 respectively (Cochran 1997). For Atlantic tomcod, weeks 19 through 22 of the LRS samples 31 were used to calculate the abundance index. The LA is strictly a sum of the weighted average 32 species densities over sampling weeks (w) instead of an average over weeks as for the FA.

33 For the FJS and each gear type, FA is constructed as a weighted mean of the average species 34 density ( d rsw ) for a given river segment (r = 0 to 12), sampling stratum (s = 1 to 3), and week v rs d rsw 1 r s 35 (w = 33 to 40), i.e., FA = I(0,1) for n equal to the number of weeks n w v rs r s 36 sampled, vrs equal to the volume of the given river segment and strata sampled, and the 37 indicator function I(0,1) equaling 1 if a given week was sampled and 0 otherwise (CHGEC 38 1999). For the FJS, strata sampled were the channel, bottom, and shoal for a given river 39 segment. Poughkeepsie and West Point river segments had the greatest channel volume, 40 Poughkeepsie and Tappan Zee had the greatest bottom volume, and Tappan Zee had the December 2008 H-39 Draft NUREG-1437, Supplement 38

Appendix H 1 greatest shoal volume. Because the river segment associated with IP2 and IP3 did not have 2 large bottom or shoal volumes, the abundance index would not be sensitive to changes in 3 population trends within the vicinity of IP2 and IP3.

4 The construction of the BSS abundance index (BA) provided an unbiased estimate of the mean 5 riverwide population abundance for striped bass, white perch, American shad, bluefish, spottail 6 shiner, and white catfish. A single gear type was used for all years; thus, BA was constructed as 7 a weighted average density or catch per haul ( c rw ) for a given river segment (r = 0 to 12) and Wr c rw 1

8 week (w = 33 to 40), i.e., B A = r I(0,1) for n equal to the number of weeks n w Wr r

9 sampled, Wr equaled the number of beach segments in the sampling design for a given river 10 segment, and the indicator function I(0,1) equaled 1 if a given week was sampled and 0 11 otherwise (CHGEC 1999).

12 Catch-Per-Unit-Effort 13 NRC Staff used the CPUE to evaluate riverwide and river-segment population trends and was 14 defined for a given species as the sum of the fish caught within a given year divided by the total 15 volume sampled. The CPUE for a given region is a biased (by the ratio of vs/V) estimate of the 16 population abundance, i.e.,

ys vs 17 E(CPUE) = E s = s vs s V s

18 where ys is the number of fish caught in a given stratum (s = 1 to 3),

19 s is the mean density of fish in a given stratum, 20 vs is the volume sampled in the given stratum, and 21 V is the total volume sampled).

22 For the LRS and FJS, a greater fraction of the volume sampled was from the bottom and shoal 23 strata; therefore, the CPUE from each river segment is not sensitive to changes in abundance 24 associated with fish sampled in the channel. For the BSS, there was only one gear type (beach 25 seine); thus, the CPUE from each river segment was equivalent to the density ( d rsw ) from the 26 BSS. The river-segment CPUE from the BSS was not used in the analysis.

27 Staff assumed that the river-segment densities for each of the surveys provided by the applicant 28 were the same average species densities, d rsw and c rw , used to derive the abundance indices.

29 Because multiple gear types were used in the LRS and FJS, the NRC staff assumes that the 30 densities for each gear type probably represented a weighted average.

31 Analysis of Population Impacts Draft NUREG-1437, Supplement 38 H-40 December 2008

Appendix H 1 To assess potential impacts to RIS populations near the IP2 and IP3 facility and within the lower 2 Hudson River, the NRC staff evaluated environmental data from FSS, BSS, and LRS studies, 3 and coastal trends, when available. Detailed information is presented in Appendix I.

4 River Segment 4 5 To assess potential impacts to RIS populations near the IP2 and IP3 facilities, the NRC staff 6 evaluated environmental data from FSS, BSS, and LRS studies for River Segment 4, which is 7 located at river kilometers (RKM) 63-76 (RM 39-46) (Figure 2-6 in the main text). The two 8 measurement metrics evaluated using the environmental data were density (estimated number 9 of RIS per given volume of water provided by the applicant) and CPUE (number of RIS captured 10 by the sampler for a given volume of water, derived by the NRC staff). Using these two metrics, 11 the staff determined that potential moderate-to-large adverse population impacts were possible 12 for many RIS, including alewife, bay anchovy, American shad, bluefish, hogchoker, blueback 13 herring, rainbow smelt, spottail shiner, Atlantic tomcod, and white perch (Table H-13). A small 14 potential for adverse population impacts was predicted for striped bass, white catfish, and 15 weakfish. An impact determination for populations of Atlantic menhaden, Atlantic and shortnose 16 sturgeon, gizzard shad, and blue crab could not be made, because these species were not 17 routinely caught in the studies. As described above, the NRC staff defined a large population 18 impact for this river segment and a given RIS as a statistically significant negative slope in 19 population abundance, using regression analyses and an observation of greater than 40 percent 20 of the abundance outside of the defined level of environmental noise, defined as +/- 1 standard 21 deviation from the mean of the first 5 years of data. The decision rules for this analysis are 22 found at the beginning of Section H-3; the complete analysis is presented in Appendix I.

December 2008 H-41 Draft NUREG-1437, Supplement 38

Appendix H 1 Table H-13 Assessment of Population Impacts for River Segment 4 2 Lower Hudson River Density Catch-per-Unit Effort River Species Segment FJS BSS LRS FJS LRS Assessment a

Alewife Large Large N/A Large N/A Large Moderate to Bay Anchovy Large Small N/A Small N/A Large American Shad Large Large N/A Large N/A Large Bluefish Small Large N/A Large N/A Large Hogchoker Moderate Large N/A Moderate N/A Large Atlantic Menhaden N/A N/A N/A N/A N/A Unknown Moderate to Blueback Herring Moderate Moderate N/A Moderate N/A Large Rainbow Smelt Moderate N/A N/A Large N/A Large Shortnose Sturgeon N/A N/A N/A N/A N/A Unknown Spottail Shiner N/A Large N/A N/A N/A Large Atlantic Sturgeon N/A N/A N/A N/A N/A Unknown Striped Bass Small Small N/A Small N/A Small Atlantic Tomcod Moderate N/A Moderate Small Moderate Moderate White Catfish Small N/A N/A N/A N/A Small White Perch Small Large N/A Large N/A Large Weakfish Small N/A N/A Small N/A Small Gizzard Shad N/A N/A N/A N/A N/A Unknown Blue Crab N/A N/A N/A N/A N/A Unknown (a) N/A: not applicable; YOY not present in samples 3 To assess potential population-level impacts to RIS for the lower Hudson River (RKM 0-245, 4 RM 0-152) (Figure 2-6 in the main text), the NRC staff evaluated abundance index data 5 provided by the applicant and CPUE data obtained from FJS, BSS, and LRS studies. Analysis 6 of abundance index data suggested a large potential for adverse population impacts for three 7 RIS (American shad, white catfish, white perch) and a moderate potential for adverse impacts 8 for bay anchovy, blueback herring, Atlantic tomcod, and weakfish. A small potential for adverse 9 population impacts was predicted for alewife, bluefish, hogchoker, rainbow smelt, spottail 10 shiner, and striped bass (Table H-14). An assessment of impacts could not be made for Atlantic 11 menhaden, Atlantic and shortnose sturgeon, gizzard shad, and blue crab, because few were 12 caught during the monitoring studies. Assessment of population-level impacts using CPUE 13 predicted a potential for moderate-to-large impacts for most RIS. The exceptions were small 14 impacts for spottail shiner, striped bass, and weakfish (Table H-14). As described above, staff 15 could not determine population-level impacts for five RIS.

Draft NUREG-1437, Supplement 38 H-42 December 2008

Appendix H 1 Table H-14 Assessment of Population Impacts for the Lower Hudson River Abundance CPUE Riverwide Species Index FJS BSS LRS Assessment Alewife Small Moderate Moderate N/Aa Moderate Bay Anchovy Moderate Small Moderate N/A Moderate American Shad Large Large Small N/A Large Bluefish Small Large Moderate N/A Large Hogchoker Small Moderate Moderate N/A Moderate Atlantic Menhaden N/A N/A N/A N/A Unknown Blueback Herring Moderate Large Large N/A Large Rainbow Smelt Small N/A Large N/A Large Shortnose N/A N/A N/A N/A Unknown Sturgeon Spottail Shiner Small Small Small N/A Small Atlantic Sturgeon N/A N/A N/A N/A Unknown Striped Bass Small Small Small N/A Small Atlantic Tomcod Moderate Moderate Large Moderate Large White Catfish Large N/A Large N/A Large White Perch Large Large Large N/A Large Small to Weakfish Moderate N/A Small N/A Moderate Gizzard Shad N/A N/A N/A N/A Unknown Blue Crab N/A N/A N/A N/A Unknown (a) N/A: not applicable; YOY not present in samples 2 WOE Summary of Population Impacts 3 To integrate all of the available RIS population data for IP2 and IP3 and the lower Hudson River, 4 the NRC staff used a WOE analysis. An overview of this analysis is presented at the beginning 5 of Section H-3; detailed information is presented in Appendix I. The results for this analysis are 6 presented in Table H-15 and predict a moderate-to-large potential for adverse impacts for 13 of 7 the 18 RIS. For two of these (Atlantic menhaden and Atlantic sturgeon), the moderate-to-large 8 potential impact determination was based on only one LOE (coastal trends). A small potential 9 for adverse population-level impacts is predicted for blue crab, based on only one LOE (coastal 10 trends). An impact conclusion regarding the population impacts could not be reached for 11 shortnose sturgeon because of a lack of available data. As described above, the conclusion of 12 a large population impact is based on the detection of a significant negative slope using 13 regression analyses and the observation that greater than 40 percent of the abundance 14 observations were outside the defined level of noise. The decision rules for these analyses are 15 found at the beginning of Section H-3; the complete analysis is presented in Appendix I.

December 2008 H-43 Draft NUREG-1437, Supplement 38

Appendix H 1 Table H-15 Weight of Evidence Results for the Population Trend Line of Evidence River Riverwide Coastal Segment WOE Impact Measurement Assessment Assessment Assessment Score(b) Conclusion Score Score Score Utility Score(a) 2.4 1.7 1.3 Alewife 4.0 1.7 2 2.8 Large Bay Anchovy 2.0 1.7 N/A(c) 1.9 Moderate American Shad 4.0 3.0 4 3.7 Large Bluefish 3.0 2.3 2 2.5 Large Hogchoker 2.7 1.7 N/A 2.3 Large Atlantic Moderate Unknown Unknown 2 2(d)

Menhaden to Large Blueback 2.0 3.3 2 2.4 Large Herring Rainbow Smelt 3.0 2.5 N/A 2.8 Large Shortnose Unknown Unknown N/A Unknown Unknown Sturgeon Spottail Shiner 4.0 1.0 N/A 2.8 Large Atlantic (d)

Unknown Unknown 4 4 Large Sturgeon Striped Bass 1.0 1.0 1 1 Small Atlantic 1.8 2.5 N/A 2.1 Large Tomcod White Catfish 1.0 4.0 N/A 2.2 Large White Perch 3.0 4.0 1 2.8 Large Weakfish 1.0 1.5 2 1.4 Small Gizzard Shad Unknown Unknown N/A Unknown Unknown Blue Crab Unknown Unknown 1 1(d) Small (a) Overall Use and Utility Score: Low = < 1.5, Medium = 1.5 but 2.0, High = >2.0 (b) WOE Score: Small = <1.5; Small-Moderate = 1.5; Moderate = >1.5 but <2.0; Moderate-Large = 2.0; Large =

>2.0 (c) N/A: Not applicable (d) Impact assessment based only on coastal trends Draft NUREG-1437, Supplement 38 H-44 December 2008

Appendix H 1 H.1.3.2. Analysis of Strength of Connection 2 To determine whether the operation of the IP2 and IP3 cooling systems had the potential to 3 influence RIS populations near the facility or within the lower Hudson River, the NRC staff 4 conducted a strength-of-connection analysis. A summary of this analysis can be found at the 5 beginning of Section H-3; detailed information on the analysis is presented in Appendix I. The 6 strength-of-connection analysis assumes the IP2 and IP3 cooling systems can affect aquatic 7 resources directly through impingement or entrainment and indirectly by impinging and 8 entraining potential food (prey). By comparing the rank order of RIS caught in the river to the 9 order observed in impingement and entrainment samples, it is possible to evaluate how efficient 10 the IP2 and IP3 cooling systems are at removing RIS from the river (e.g., how strongly it is 11 connected to the RIS of interest). The results of this analysis are presented in Table H-16 and 12 show that a high strength of connection was observed for only two species (bluefish and striped 13 bass). For those species, the IP2 and IP3 cooling systems were removing either the species or 14 its prey at levels that were proportionally higher than those observed in the river studies. This 15 suggests that there is strong evidence that the operation of the cooling systems is affecting 16 these species. For the remaining RIS, the strength of connection ranged from low (minimal 17 evidence of connection) to medium (some evidence of connection). The strength of connection 18 was unknown for five species (Atlantic menhaden, Atlantic and shortnose sturgeon, gizzard 19 shad, and blue crab, because of a lack of available data (Table H-16).

20 Table H-16 Weight of Evidence for the Strength-of-Connection Line of Evidence WOE Strength of Impingement Entrainment Measurement Scoreb Connection RIS Prey RIS Prey a

Use and Utility 1.9 2.0 1.6 2.1 Alewife 2c 1 2 1 1.5 Low to Medium Bay Anchovy 2 1 2 1 1.5 Low to Medium American Shad 2 1 2 1 1.5 Low to Medium Bluefish 4 2 2 2 2.5 High Hogchoker 4 1 2 1 2.0 Medium to High Atlantic Menhaden Unknown 1 Unknown 1 Unknown Unknown Blueback Herring 2 1 2 1 1.5 Low to Medium Rainbow Smelt 2 1 4 1 1.9 Medium Shortnose Sturgeon Unknown 1 Unknown 1 Unknown Unknown Spottail Shiner 1 2 1 2 1.5 Low to Medium Atlantic Sturgeon Unknown 1 Unknown 1 Unknown Unknown Striped Bass 2 4 2 2 2.5 High December 2008 H-45 Draft NUREG-1437, Supplement 38

Appendix H 1 Table H-16 (continued)

WOE Strength of Impingement Entrainment Measurement Scoreb Connection RIS Prey RIS Prey Atlantic Tomcod 2 1 2 1 1.5 Low to Medium White Catfish 2 1 2 1 1.5 Low to Medium White Perch 2 2 2 2 2.0 Medium to High Weakfish 2 2 2 2 2.0 Medium to High Gizzard Shad Unknown 1 Unknown 1 Unknown Unknown Blue Crab Unknown 1 Unknown 1 Unknown Unknown (a) Overall Use and Utility Score: Low = <1.5, Medium = 1.5 but 2.0, High = >2.0 (b) WOE Score: Low = <1.5; Low-Medium = 1.5; Medium = >1.5 but <2.0; Medium-High = 2.0; High = >2.0 (c) 1 indicates a low strength of connection, 2 indicates a medium potential, and 4 indicates a high potential 2 H.1.3.3. Impingement and Entrainment Impact Summary 3 The final integration of population-level and strength-of-connection LOE is presented in 4 Table H-17. This table shows the final conclusions for both LOEpopulation trends and 5 strength of connection. Assignment of an NRC level of impact (small, moderate, or large) 6 requires information on both a measurable response in the RIS population and clear evidence 7 that the RIS is influenced by the operation of the IP2 and IP3 cooling systems. Thus, when the 8 strength of connection is low, it is not possible to assign an impact level greater than small, 9 because of little evidence that a relationship between the cooling system and RIS exists.

10 Conversely, for an RIS with a high strength of connection to the IP2 and IP3 cooling system 11 operation but evidence of no population decline, the final determination must be small.

12 Based on the final WOE assessment, a small potential for adverse impacts was predicted for 13 two species (striped bass and weakfish), because there was no evidence of a population 14 decline, even though the strength of connection was medium or high. A small-to-moderate 15 impact was predicted for seven species (alewife, bay anchovy, American shad, blueback 16 herring, spottail shiner, Atlantic tomcod, and white catfish). A moderate impact was predicted 17 for rainbow smelt, and a moderate-to-large impact level was predicted for the hogchoker and 18 white perch. A large impact level was predicted for only one species, the bluefish, based on 19 observed population declines and an apparent high strength of connection to the IP2 and IP3 20 cooling systems. The level of impact could not be restricted to less than the full range of from 21 small to large for Atlantic menhaden, Atlantic and shortnose sturgeon, gizzard shad, and blue 22 crab, because of a lack of data.

Draft NUREG-1437, Supplement 38 H-46 December 2008

Appendix H 1 Table H-17 Impingement and Entrainment Impact Summary for Hudson River RIS Impacts of IP2 and 3 Population Strength of Connection Species Cooling Systems on Line of Evidence Line of Evidence Aquatic Resources Alewife Large Low to Medium Small to Moderate Bay Anchovy Moderate Low to Medium Small to Moderate American Shad Large Low to Medium Small to Moderate Bluefish Large High Large Hogchoker Large Medium to High Moderate to Large Atlantic Menhaden Moderate to Large Unknown(b) Unknown(c)

Blueback Herring Large Low to Medium Small to Moderate Rainbow Smelt Large Medium Moderate Shortnose Sturgeon Unknown(a) Unknown(b) Unknown(c)

Spottail Shiner Large Low to Medium Small to Moderate Atlantic Sturgeon Large Unknown(b) Unknown(c)

Striped Bass Small High Small Atlantic Tomcod Large Low to Medium Small to Moderate White Catfish Large Low to Medium Small to Moderate White Perch Large Medium to High Moderate to Large Weakfish Small Medium to High Small Gizzard Shad Unknown(a) Unknown(b) Unknown(c)

Blue Crab Small Unknown(b) Unknown(c)

(a) Population LOE could not be established using WOE; therefore, population LOE could range from small to large.

(b) Strength of connection could not be established using WOE; therefore, strength of connection could range from low to high.

(c) Conclusion of impact could not be established using WOE, therefore, impacts could range from small to large.

2 As described above, an impact determination of moderate, moderate to large, or large was 3 attributed to four speciesbluefish, hogchoker, rainbow smelt, and white perch, which are 4 discussed below. What follows is a discussion of the analysis that supports this determination 5 and the potential implications of the small determination of impact for the striped bass, a species 6 believed to be in recovery, caused by fishing restrictions imposed in the mid-1980s.

7 Bluefish: Large Potential for Adverse Impact 8 The analysis of YOY bluefish population trends at IP2 and IP3 and the lower Hudson River, 9 using data from FJS and BSS studies and a recent assessment by the National Oceanic and 10 Atmospheric Administration (NOAA) for coastal trends, resulted in a determination of large 11 impact (Table H-15). For the IP2 and IP3 population assessment (Table H-13), the BSS density 12 metric and the FJS CPUE metric suggested a population decline that has persisted through 13 time. For these metrics, a significant negative slope was observed, based on segmented December 2008 H-47 Draft NUREG-1437, Supplement 38

Appendix H 1 regression, and more than 40 percent of the observations were outside the defined level of 2 environmental noise (+/- 1 standard deviation from the mean of the first 5 years of data). Based 3 on the decision rules developed for population data, this was considered a large impact. The 4 only LOE inconsistent with this finding was the small impact associated with FJS density. This 5 LOE predicted a small population impact because there was not a significant negative slope and 6 only a small number of observations (7 percent) were outside the defined level of environmental 7 noise. The population assessment for the lower Hudson River (Table H-14) again showed 8 moderate and large impacts based on BSS and FJS CPUE evaluations and a small potential for 9 impact using the abundance index provided by the applicant. The latter conclusion was based 10 on nonsignificant slopes from the segmented regression and a small number of observations 11 outside the range of environmental noise. Coastal trend data provided by NOAA (Shepherd 12 2006) suggest that recreational catches have declined precipitously since the late 1980s. This 13 appears to be consistent with the population-level impact assessment for the Hudson River 14 conducted by the NRC staff.

15 Based on a comparison of FJS and BSS data with impingement and entrainment samples from 16 IP2 and IP3, the rank-order analyses suggest the cooling system is removing a disproportionate 17 number of bluefish from the Hudson River. Thus, the strength of connection for entrainment 18 and impingement was medium and high, respectively (Table H-16). Juvenile bluefish feed on a 19 variety of other fish, including bay anchovy, Atlantic silverside, striped bass, blueback herring, 20 Atlantic tomcod, and American shad. To evaluate the strength-of-connection LOE, bay anchovy 21 and Atlantic tomcod were assumed to be the primary prey. The rank order of these species in 22 impingement and entrainment samples suggested the cooling system was removing an equally 23 proportional number from the river relative to the proportion observed in the river near IP2 and 24 IP3 that could affect YOY bluefish.

25 Combining the two LOE, the NRC staff arrived at a large potential for adverse impact for 26 Hudson River bluefish from the operation of the IP2 and IP3 cooling systems. This assessment 27 is based, in part, on the losses of bluefish from impingement. Based on the work conducted by 28 Fletcher (1990) on field testing of the Ristroph screen system that was eventually installed at 29 IP2 and IP3 in the early 1990s, impingement survival of bluefish is probably similar to that 30 observed for striped bass ( about 9 percent). Because studies to estimate impingement 31 mortality were not conducted after Ristroph screen installation, it is not possible to confirm the 32 assessments of Fletcher (1990). Thus, the staffs conclusion of impact for this species should 33 be considered a conservative assessment.

34 White Perch: Moderate-to-Large Potential for Adverse Impact 35 To assess population-level impacts to the white perch near IP2 and IP3 and for the lower 36 Hudson River, the NRC staff evaluated data from FJS and BSS river studies and coastal trends.

37 For the assessment of the Hudson River population near IP2 and IP3, an analysis of BSS 38 density and FJS CPUE data indicated a large potential for adverse impact (Table H-13). Both 39 metrics produced a significant negative slope using segmented regression analysis. The 40 percentage of observations outside the environmental noise was 70 percent for BSS density 41 and 56 percent for FJS CPUE (Appendix I). The population assessment for the lower Hudson 42 River (Table H-14) showed large impacts based on BSS and FJS CPUE evaluations and the 43 abundance index provided by the applicant. The strength of connection assessment 44 (Table H-16) for white perch indicated a medium-to-high degree of connection for all LOE 45 (impingement and entrainment of YOY, impingement and entrainment of perch prey). This Draft NUREG-1437, Supplement 38 H-48 December 2008

Appendix H 1 suggests that the IP2 and IP3 cooling systems are removing both YOY and perch prey items 2 (primarily bay anchovy) at levels that are equally proportional relative to their rank order in FJS 3 and BSS environmental samples near IP2 and IP3. Because there was a large potential for 4 adverse effects at the population level and a medium-to-high level of connection between the 5 resource and the IP2 and IP3 cooling systems, the NRC staff concluded that the overall impact 6 of the IP2 and IP3 cooling systems was moderate to large.

7 As described above, this assessment is based, in part, on the losses of white perch caused by 8 impingement and entrainment. Based on the work conducted by Fletcher (1990), impingement 9 survival of white perch was estimated to be 14 percent based on field-testing of the Ristroph 10 screen system that was eventually installed at IP2 and IP3 in the early 1990s. Work by EA 11 (1989) suggested entrainment mortality of white perch PYSL ranged from 30-92 percent 12 (Table H-5). Because studies to estimate impingement mortality were not conducted after the 13 Ristroph screen installation, it is not possible to confirm the assessments of Fletcher (1990).

14 Thus, the staffs conclusion of impact for this species should be considered a conservative 15 assessment.

16 Hogchoker: Moderate-to-Large Potential for Adverse Impact 17 Analysis of population data for YOY hogchoker near IP2 and IP3 (Table H-13) indicated a large 18 potential for adverse impact. River-segment BSS density data had a significant negative slope, 19 based on segmented regression and 78 percent of observations outside the defined level of 20 environmental noise (Appendix I). River-segment FJS density and CPUE data suggested a 21 moderate potential for adverse impact, based on the presence of a significant negative slope 22 from the segmented regression and less than 40 percent of the observations outside the defined 23 level of environmental noise (15 percent for both metrics). As described above, the 24 environmental noise was defined as (+/- 1 standard deviation from the mean of the first 5 years 25 of data). Trend analyses for the lower Hudson River produced a less pronounced effect in YOY 26 populations, resulting in a moderate potential for impact based on Hudson River studies 27 (Table H-14). Coastal trend data were not available.

28 The strength-of-connection analysis for hogchoker, using the rank order technique, indicated the 29 proportion impinged by the IP2 and IP3 cooling systems was higher than would be expected, 30 based on the densities observed in FJS and BSS studies (Table H-16). The proportion 31 entrained was estimated to be equally proportional to the rank order in FJS and BSS 32 environmental samples near IP2 and IP3. This resulted in an assessment of a medium-to-high 33 strength of connection to the IP2 and IP3 cooling systems. Because hogchokers feed primarily 34 on benthic invertebrates for which no sampling data are available, there was minimal evidence 35 to suggest a connection between hogchoker prey species and the IP2 and IP3 cooling systems.

36 In the final analyses, the NRC staff concluded that there was a moderate-to-large potential for 37 adverse impacts to the hogchoker from the operation of the IP2 and IP3 cooling systems. This 38 assessment is due, in part, to the losses of this species from impingement. Work by Fletcher 39 (1990) has suggested that impingement mortality for this species is approximately 13 percent 40 for the Ristroph screen system installed at IP2 and IP3 in the early 1990s. Because studies to 41 estimate impingement mortality were not conducted after Ristroph screen installation, it is not 42 possible to confirm the assessments of Fletcher (1990). Thus, the conclusion of impact for this 43 species should be considered a conservative assessment.

44 Rainbow Smelt: Moderate Potential for Adverse Impact December 2008 H-49 Draft NUREG-1437, Supplement 38

Appendix H 1 Population data for areas near IP2 and IP3 (River Segment 4) and the lower Hudson River were 2 obtained from the FJS and BSS studies, using density and CPUE metrics and the abundance 3 index provided by the applicant. For the area of the river near the IP2 and IP3 facilities, NRC 4 analysis of FJS YOY data indicated a moderate (FJS density) and large (FJS CPUE) potential 5 for adverse impacts (Table H-13). The moderate impact was determined from a significant 6 negative slope from the segmented regression; however, less than 40 percent of the density 7 observations were outside the defined environmental noise. The large impact observed with the 8 FJS CPUE data was based on both a significant negative slope from the segmented regression 9 and 78 percent of the observations outside the defined level of environmental noise 10 (Appendix I). These findings are consistent with the disappearance of this species from the 11 lower Hudson River beginning in 1995 (Daniels et al. 2005) and the listing of rainbow smelt as a 12 Species of Concern by NOAA (2007). Evaluation of population trends for this species for the 13 lower Hudson River (Table H-14) suggests a large impact based on BSS CPUE and a small 14 impact based on the abundance index. Because the abundance index (derived for this species 15 from the FJS channel data) may be more heavily influenced by population trends from the river 16 segment near Poughkeepsie, because of a 1-to-2 times greater channel volume than other river 17 segments with relatively greater populations of smelt (IP2 and IP3 to Cornwall), the NRC staff 18 considers the CPUE metric to reflect the more biologically relevant result.

19 The staff finds the strength of connection between rainbow smelt and the IP2 and IP3 cooling 20 systems is moderate for impingement and high for entrainment (Table H-16). Based on a rank-21 order comparison of catch statistics from FSS and BSS studies with entrainment sampling 22 results, the proportion of rainbow smelt early life stages entrained at IP2 and IP3 is higher than 23 would be expected from the catch statistics. YOY rainbow smelt feed on smaller fish but 24 primarily on copepods, small crustaceans, and benthic invertebrates; thus, a low connection 25 was determined for the impingement and entrainment of prey species. Because there is a large 26 potential for adverse population impacts, coupled with an overall medium strength of 27 connection, the NRC staff concluded that the impacts of the IP2 and IP3 cooling systems on this 28 species are moderate. As described above, this assessment is caused, in part, by losses 29 associated with impingement and entrainment. Fletcher (1990) does not report impingement 30 mortality (Table H-5). Entrainment survival estimates are not available for this species.

31 Because true impingement and entrainment mortality cannot be determined, the conclusion of 32 impact for this species should be considered a conservative assessment.

33 Striped Bass: Small Potential for Adverse Impact 34 As described in Section 2 of the main text, striped bass appear to spend extended periods in the 35 Hudson River. Based on concerns related to polychlorinated biphenyls (PCB) body burdens, 36 the Hudson River commercial fishery was closed in 1976 (CHGEC 1999). As a result of 37 commercial restrictions on harvesting supported by the Atlantic Striped Bass Conservation Act 38 (1984), the fishery was declared to be in full recovery by 1995 (ASMFC 2006), and abundance 39 levels have continued to increase in the Atlantic population. Although restrictions on both 40 commercial and recreational fisheries have been relaxed because of the recovery of the 41 population, the fisheries continue to be limited to State waters (within 3 nm of land), and the 42 New York States commercial fishery remains completely closed. While commercial landings 43 have remained lower than the levels seen in the early 1970s, recreational landings have 44 increased and, in 2004, made up 72 percent of the total weight harvested from the Atlantic stock 45 (Shepherd 2006b).

Draft NUREG-1437, Supplement 38 H-50 December 2008

Appendix H 1 Based on the above, one would expect that the population of YOY striped bass in the Hudson 2 River would have increased from 1995 to the present. Riverwide analysis of YOY population 3 trend data from FJS and BSS surveys (Table H-14 and Appendix I) indicate that YOY 4 populations have increased only slightly above the environmental noise within the last few years 5 of the studies and resulted in a small level of impact based on a WOE analysis. This trend is 6 not evident elsewhere along the Atlantic seaboard, where YOY striped bass populations have 7 increased since fishing restrictions were established (ASMFC 2006). Although the YOY 8 population trends in the Hudson River do not represent a moderate or large adverse impact, the 9 high strength of connection observed, caused by the impingement and entrainment of this 10 species, and the loss of its prey, suggests that the IP2 and IP3 cooling systems may be 11 inhibiting or limiting the abundance of YOY bass in the Hudson River, despite the apparent 12 increase in adults elsewhere in the region.

13 H.2 Cumulative Impacts on Aquatic Resources 14 In addition to the potential impacts associated with the IP2 and IP3 CWIS described in 15 Section H.3, it is possible that other natural or anthropogenic factors unrelated to the relicensing 16 of Indian Point could influence the aquatic resources of the lower Hudson River. In this section, 17 the NRC staff discusses and evaluates potential stressors that could contribute to the total 18 impacts to the aquatic resources during the license renewal period. Potential stressors include 19 other Hudson River facilities that withdraw water, the presence of zebra mussels in the 20 freshwater portions of the river, fishing pressure associated with commercially and recreationally 21 important species, habitat loss, interactions with other invasive species, and impacts associated 22 with changes to water and sediment quality caused by short-term anthropogenic activities or 23 long-term influences associated with global climate change.

24 Population trends should, in theory, reflect cumulative effects of all impacts on the population.

25 Impacts attributable to the Indian Point cooling systems have already been analyzed. This 26 section of the appendix concentrates on effects associated with the invasion of zebra mussels, 27 using a WOE approach, as discussed in Section H.3. A qualitative assessment of effects 28 associated with fishing pressure was also explored.

29 The NRC staff evaluated potential population-level impacts to RIS for the lower Hudson River 30 (RKM 0-245, RM 0-152) (Figure 2-6 in the main text) in Section H.3.1. Riverwide data used in 31 the analysis included the abundance index provided by the applicant and CPUE data obtained 32 from FJS, BSS, and LRS studies. The results of this analysis were presented in Table H-14 and 33 showed a large potential for adverse impacts for 7 of the 18 RIS caused by the CWIS.

34 An analysis conducted on behalf of Entergy (Barnthouse et al. 2008) used environmental risk-35 assessment techniques to evaluate the potential for adverse impacts to Hudson River RIS from 36 a variety of natural and anthropogenic stressors, including the operation of the IP2 and IP3 37 CWIS, fishing pressure, the presence of zebra mussels, predation by striped bass, and water 38 temperature. Barnthouse et al. (2008) concluded that the Indian Point CWIS had no effect on 39 all seven of the RIS included in their study. Instead, the authors hypothesized that observed 40 population declines in selected RIS were influenced by striped bass predation, mortality 41 imposed by fishing, water temperature, and zebra mussel invasion.

December 2008 H-51 Draft NUREG-1437, Supplement 38

Appendix H 1 Strayer et al. (2004) concluded that the abundance of juvenile American shad and white perch 2 declined following the zebra mussel invasion. Further, the authors found that juvenile alewife 3 abundance increased following the zebra mussel invasion. The NRC Staffs analysis follows.

4 Zebra Mussels 5 To evaluate the effects of zebra mussels, the NRC staff applied a WOE approach. It is 6 important to note, however, that the Hudson River monitoring surveys used in these analyses 7 were designed to evaluate the population abundance of selected species. They were not 8 designed to evaluate competing and confounded factors affecting population abundance.

9 Coincident measures of zebra mussel abundance through time, water quality, changes to 10 thermal discharges, changes in fishing pressure, and predator-prey interactions would be a 11 minimal requirement to begin to rank stressor effects on each population. These measures are 12 not available, and so the remaining analyses should be viewed as the development of 13 hypotheses of potential impacts associated with zebra mussels.

14 The NRC staff analyzed the impact of zebra mussels on RIS populations that were caught in 15 River Segment 12 (Albany). The NRC staff analyzed the 75th percentile of the weekly FJS and 16 BSS density and CPUE data from this river segment and used this information to evaluate the 17 population trend LOE for these species. Data for white perch, blueback herring, alewife, 18 American shad, white catfish, spottail shiner, and striped bass were used in the analysis 19 because all have high densities of YOY within this region. Only weeks 27 to 43 were used in 20 the analysis for the FJS and weeks 22 to 43 for the BSS survey so that most years contained 21 observations from the months July through October and June through October for each survey, 22 respectively. Effects associated with changes in gear type for the FJS (1985) were also 23 considered. Details of the analysis are presented in Appendix I.

24 Simple linear regression and segmented regression with a single join point were fit to the annual 25 measure of abundance for each RIS, as described in Section H.3. If the estimated slope from 26 the linear regression or either slope from the segmented regression, whichever was determined 27 to be the better fitting model, was significantly less than zero, then an adverse population impact 28 was considered detected. An assessment of adverse impact was only supported if more than 29 40 percent of the standardized observations were outside the bounds of +/-1 standard deviation.

30 The strength of connection to a potential impact associated with a zebra mussel invasion was 31 determined by the temporality of the observed change in population trends and the year 32 associated with invasion of the zebra mussels in the Hudson River (1991) based on work by 33 Strayer et al. (2004). For any stressor to be considered a potential cause of an impact, the 34 stress must occur before the response (Adams 2003). For the assessment of the observed 35 response, the year associated with a change in population trend was estimated by the join point 36 from the segmented regression or was considered pre-1991, if the linear model was the better 37 fit to the density and CPUE data collected from Region 12 (Albany area). If the join point was 38 before 1991, then the strength of connection was defined as low. If the segmented regression 39 did not converge or was not the better fitting model, the linear regression was used to suggest 40 that there was no change in slope following invasion; thus, the strength of connection was low.

41 If the join point from the segmented regression was after 1991, then the strength of connection 42 was defined as high.

43 Based on the WOE analysis (see Appendix I for details) and the decision rules presented in 44 Section H.3, the NRC staff determined potential moderate-to-large population impacts within Draft NUREG-1437, Supplement 38 H-52 December 2008

Appendix H 1 River Segment 12 (Albany) were possible for many RIS, including American shad, blueback 2 herring, spottail shiner, white catfish, and white perch (Table H-18). A small potential for 3 adverse population impacts was predicted for alewife and striped bass. The data tables for 4 which the results of the strength of connection between adverse population impacts and the 5 zebra mussel invasion are drawn are presented in Appendix I. None of the RIS evaluated had a 6 statistically significant increase in population abundance in River Segment 12. The strength-of-7 connection analysis assumes that zebra mussels can affect aquatic resources indirectly by 8 reducing potential food resources (prey) or by altering habitat (e.g. shelter). The results of the 9 strength-of-connection analysis are presented in Table H-19 and show that a medium-to-high 10 strength of connection was observed for all fish except white catfish.

11 Table H-18 Population Trends Postinvasion of Zebra Mussels in 1991 for Density and 12 CPUE of YOY Collected from River Segment 12 (Albany)

Hypothesized Level Species FJS Density BSS Density FJS CPUE WOE of Impact to Population Trend Alewife 1 2 1 1.3 Small American Shad 2 4 2 2.7 Large Blueback Herring 2 2 2 2.0 Moderate to Large Spottail Shiner 2 1 2 1.7 Moderate Striped Bass 1 1 1 1.0 Small White Catfish 1 N/A 4 2.5 Large White Perch 2 2 2 2.0 Moderate to Large N/A is not applicable; YOY are not present in samples.

13 Table H-19 Strength of Connection between Population Trends and Zebra Mussel 14 Invasion Hypothesized Strength Species FJS Density BSS Density FJS CPUE WOE of Connection Alewife 1 1 4 2.0 Medium to High American Shad 4 1 1 2.0 Medium to High Blueback Herring 1 4 1 2.0 Medium to High Spottail Shiner 4 1 1 2.0 Medium to High Striped Bass 1 1 4 2.0 Medium to High White Catfish 1 N/A 1 1.0 Low White Perch 1 4 1 2.0 Medium to High N/A is not applicable; YOY are not present in samples.

15 The final integration of population-level and strength-of-connection LOE is presented in 16 Table H-20. This table shows the final conclusions for both LOEpopulation trends and 17 strength of connection. For an adverse impact to occur, there needs to be a measurable 18 response in the RIS population and clear evidence that the RIS is influenced by the zebra 19 mussel invasion. When the strength of connection is low, it is not possible to arrive at an impact 20 level greater than small, because there is litle evidence that a relationship between the mussel 21 invasion and population trends exists. Conversely, for an RIS with a high strength of connection December 2008 H-53 Draft NUREG-1437, Supplement 38

Appendix H 1 to the zebra mussel invasion but evidence of no population decline, the final determination must 2 be small.

3 Based on the final WOE assessment, a small potential for adverse impacts from the zebra 4 mussel invasion was predicted for three species (alewife, striped bass, and white catfish).

5 Alewife and striped bass had no evidence of a population decline, even though the strength of 6 connection was medium to high, while white catfish displayed a population decline but had a low 7 strength of connection. A moderate or moderate-to-large impact was predicted for the 8 remaining species (American shad, blueback herring, spottail shiner, and white perch).

9 Table H-20 Weight of Evidence Associated with Potential Negative Impacts on 10 Population Trends from Zebra Mussel Invasion Hypothesized Hypothesized Level of Hypothesized Impact to Population Species Impact to Strength of Trends from Zebra Population Trends Connection Mussel Alewife Small Medium to High Small American Shad Large Medium to High Moderate to Large Blueback Herring Moderate to Large Medium to High Moderate to Large Spottail Shiner Moderate Medium to High Moderate Striped Bass Small Medium to High Small White Catfish Large Low Small White Perch Moderate to Large Medium to High Moderate to Large 11 The NRC staff analysis predicted a moderate-to-large potential adverse impact on the decline in 12 American shad associated with the zebra mussel invasion. The NRC staff WOE analysis was 13 based on the post-1985 FJS data, since the catch efficiency of the beam trawl for YOY 14 American shad was less than the epibenthic sled. Based on the riverwide abundance index, 15 Strayer et al. (2004) also concluded that the abundance of American shad was affected by 16 zebra mussels. Much of the decline in population abundance, however, was observed before 17 the mussel invasion (Figure H-9). Unlike both the NRC staff and Strayer et al. (2004),

18 Barnthouse et al. (2008) rejected the hypothesis that zebra mussels were a potential cause of 19 the decline.

Draft NUREG-1437, Supplement 38 H-54 December 2008

Appendix H 3 3 Zebra Mussel Zebra Mussel 2 2 BSS Density 1

FJS Density 1

0 0

-1 -1

-2 -2

-3 -3 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey 3

Zebra Mussel 2

1 American Shad FJS CPUE 0

American Shad RS12

-1

-2

-3 0 5 10 15 20 25 30 Years of Survey 1 Source: Normandeau 2008 2 Figure H-9 American shad standardized population trend data for the Riverwide and 3 River Segment 12 (RS12), Fall Juvenile, and Beach Seine Surveys (Normandeau 2008) 4 The NRC staff analysis predicted a moderate-to-large potential adverse impact to juvenile 5 blueback herring abundance associated with the zebra mussel invasion. Again, unlike both the 6 NRC staff and Strayer et al. (2004), Barnthouse et al. (2008) rejected the hypothesis that zebra 7 mussels were a potential cause in the decline of blueback herring. The relative population 8 response between the effect of the zebra mussel invasion and the combined riverwide impacts 9 are presented in Figure H-10. Population trend data for River Segment 12 tend to be slightly 10 below the riverwide observations and, for the BSS density, suggest a further decrease following 11 the mussel invasion. This suggests to NRC Staff that the relative effects of the zebra mussel 12 invasion may be slightly greater than the riverwide effects.

December 2008 H-55 Draft NUREG-1437, Supplement 38

Appendix H 4

Zebra Mussel 4 Zebra Mussel 3 3 2 2 FJS Density BSS Density 1 1 0 0

-1 -1

-2 -2

-3 -3

-4 -4 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey 4

Zebra Mussel 3

2 Blueback Herring FJS CPUE 1

0 Blueback Herring RS12

-1

-2

-3

-4 0 5 10 15 20 25 30 Years of Survey 1 Source: Normandeau 2008 2 Figure H-10 Blueback herring standardized population trend data for the Riverwide and 3 River Segment 12 (RS12), Fall Juvenile, and Beach Seine Surveys 4 The NRC staff analysis predicted a moderate potential adverse impact to juvenile spottail shiner 5 abundance associated with the zebra mussel invasion. Strayer et al. (2004) concluded that 6 there was no change in spottail shiner abundance, and Barnthouse et al. (2008) did not 7 evaluate spottail shiner population trends. The relative population response between the effect 8 of the zebra mussel invasion and the combined riverwide impacts is presented in Figure H-11.

9 The impact on white perch population trends from zebra mussels was estimated to be moderate 10 to large. Figure H-12 presents white perch riverwide density and CPUE for River Segment 12.

11 White perch population trends obtained from the FJS were not affected by gear changes (year 6 12 of the survey) and yet, an early decline in fish density and CPUE in River Segment 12 can be 13 observed from both the FJS and the BSS. For the BSS density, riverwide and each river-14 segment population trend overlap. Overall, the riverwide and River Segment 12 data overlap 15 often and show a decline from the early population abundance. This suggests to NRC Staff that 16 a combination of stressors acting on the riverwide population is associated with a relatively 17 greater adverse impact than the impact from the zebra mussel invasion.

Draft NUREG-1437, Supplement 38 H-56 December 2008

Appendix H 5

Zebra Mussel 5 Zebra Mussel 4 4 3 3 FJS Density BSS Density 2 2 1 1 0 0

-1 -1

-2 -2 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey 5

Zebra Mussel 4

3 Spottail Shiner FJS CPUE 2

Spottail Shiner RS12 1

0

-1

-2 0 5 10 15 20 25 30 Years of Survey 1 Source: Normandeau 2008 2 Figure H-11 Spottail Shiner standardized population trend data for the Riverwide and 3 River Segment 12 (RS12), Fall Juvenile, and Beach Seine Surveys 4 Water Quality and Climate Change 5 Sewage Treatment System Upgrades As discussed in Section 2.2.5, the increasing populations along the river and within the watershed resulted in an increased discharge of sewage into the Hudson River and an overall degradation of water quality. Beginning in 1906 with the creation of the Metropolitan Sewerage Commission of New York, a series of studies were conducted to formulate plans to improve water quality within the region (Brosnan and OShea 1996). In the freshwater portion of the lower Hudson River, the most dramatic improvements in wastewater treatment were made between 1974 and 1985, resulting in a decrease in the discharge of suspended solids by 56 percent. Improvements in the brackish portion of the river were even greater. In the New York City area, the construction and upgrading of water treatment plants reduced the discharge of untreated wastewater from 450 million gallons per day (mgd) in 1970 to less than 5 mgd in 1988 (CHGEC 1999). The discharge of raw sewage was further reduced between 1989 and 1993, caused by the implementation of additional treatment programs (Brosnan and OShea 1996).

December 2008 H-57 Draft NUREG-1437, Supplement 38

Appendix H 3 3 Zebra Mussel Zebra Mussel 2 2 1 1 FJS Density BSS Density 0 0

-1 -1

-2 -2

-3 -3

-4 -4 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey 3

Zebra Mussel 2

1 FJS CPUE 0 W hite Perch

-1

-2 W hite Perch RS12

-3

-4 0 5 10 15 20 25 30 Years of Survey 1 Source: Normandeau 2008 2 Figure H-12 White perch standardized population trend data for the Riverwide and River 3 Segment 12 (RS12), Fall Juvenile, and Beach Seine Surveys 4 During the 1990s, three municipal treatment plants located in the lower Hudson River converted 5 to full secondary treatmentNorth River (1991), North Bergen MUA-Woodcliff (1991), and 6 North Hudson Sewerage Authority West New York (1992). In addition, the North Hudson 7 Sewerage Authority-Hoboken plant, located on the western bank of the Hudson River opposite 8 Manhattan Island, went to full secondary treatment in 1994 (CHGEC 1999). Upgrades to the 9 Yonkers Joint Treatment Plant in 1988 and the Rockland County Sewer District #1 in 1989 also 10 resulted in improvements in water quality in the brackish portion of the Hudson River. In the 11 mid-1990s, the Rockland County Sewer District #1 and Orangetown Sewer District plants were 12 also upgraded. (CHGEC 1999) 13 Trends in Dissolved Oxygen 14 A review of long-term trends in dissolved oxygen (DO) and total coliform bacteria concentrations 15 by Brosnan and OShea (1996) has shown that improvements to water treatment facilities have 16 improved water quality. The authors noted that, between the 1970s and 1990s, DO 17 concentrations in the Hudson River generally increased. The increases coincided with the Draft NUREG-1437, Supplement 38 H-58 December 2008

Appendix H 1 upgrading of the 170 million mgd North River plant to secondary treatment in the spring of 1991.

2 DO, expressed as the average percent saturation, exceeded 80 percent in surface waters and 3 60 percent in bottom waters during summer in the early 1990s. DO minimums also increased 4 from less than 1.5 milligrams per liter (mg/L) in the early 1970s to more than 3.0 mg/L in the 5 1990s, and the duration of low DO (hypoxia) events was also reduced (Brosnan and OShea 6 1996). Similar trends showing improvements in DO were noted by Abood et al. (2006) from an 7 examination of two long-term data sets collected by NYCDEP in the lower reaches of the river.

8 Brosnan and OShea (1996) also noted a strong decline in total coliform bacteria concentrations 9 that began in the 1970s and continued into the 1990s, coinciding with sewage treatment plant 10 upgrades.

11 Chemical Contaminants 12 As discussed in Section 2.2.5, the lower Hudson River currently appears on the EPA 303-d list 13 as an impaired waterway, because of the presence of PCBs and the need for fishing restrictions 14 (EPA 2004). Contamination of the sediment, water, and biota of the Hudson River estuary 15 resulted from the manufacture of capacitors and other electronic equipment in the towns of Fort 16 Edward and Hudson Falls, New York, from the 1940s to the 1970s. Investigations conducted by 17 the EPA and others over the past 25 years have delineated the extent and magnitude of 18 contamination, and numerous cleanup plans have been devised and implemented. Recently, 19 EPA Region 2 released a Fact Sheet describing a remedial dredging program designed to 20 remove over 1.5 million cubic yards of contaminated sediment covering 400 acres, extending 21 from the Fort Edwards Dam to the Federal Dam at Troy (EPA 2008). Concentrations of PCBs in 22 river sediments below the Troy Dam are much lower. Work summarized by Steinberg et al.

23 (2004) suggests the sediment-bound concentrations of PCBs and dioxins have generally 24 declined in the lower Hudson River since the 1970s and are now at or below ER-M limits.

25 Chemical contaminants present in the tissues of fish in the Hudson River estuary have been 26 extensively studied for many years and resulted in the posting of consumption advisories by the 27 States of New York and New Jersey. Current information summarized in Steinberg et al. (2004) 28 suggests that many recreationally and important fish and shellfish still contain levels of metals, 29 pesticides, PCBs, and dioxins above the Food and Drug Administration (FDA) guidance values 30 for commercial sales. Tissue concentrations of mercury were of concern only for striped bass; 31 other fish, and shellfish, including flounder, perch, eels, blue crab, and lobster, contained 32 concentrations of mercury in their tissues well below the FDA limit of 2 parts per million (ppm) 33 for commercial sale. Concentrations of chlordane in white perch, American eels, and the 34 hepatopancreas (green gland) of blue crabs were also above FDA guidelines. DDT 35 concentrations in the tissues of most recreationally and commercially valuable fish and shellfish 36 in the estuary were below the 2 ppm FDA limit with the exception of American eel.

37 Unfortunately, the concentrations of 2,3,7,8-TCDD (a dioxin compound) and total PCBs in fish 38 and shellfish tissues were often above FDA guidance limits, suggesting fish and shellfish 39 obtained from some locations within the estuary should be eaten in moderation or not at all.

40 The results described above suggest that, although a wide variety of contaminants still exist in 41 sediment, water, and biota in the lower Hudson River, the overall levels appear to be decreasing 42 because of the imposition of strict discharge controls by Federal and State regulatory agencies 43 and improvements in wastewater treatment. These trends appear to be confirmed, based on 44 the results of a NOAA-sponsored toxicological evaluation of the estuary in 1991, as described in 45 Wolfe et al. (1996). There is continuing concern, however, that legacy PCB waste may still December 2008 H-59 Draft NUREG-1437, Supplement 38

Appendix H 1 pose a threat to invertebrate, fish, and human populations. A study by Achman et al. (1996) 2 suggested that PCB concentrations in sediment measured at several locations in the lower 3 Hudson River from the mouth to Haverstraw Bay are above equilibrium with overlying water and 4 may be available for transfer within the food web. The implications of this study are that, in 5 some locations within the lower river, the sediments could act as a source of PCBs and pose a 6 long-term chronic threat. The authors concluded, however, that fate and transport modeling 7 would be required to fully understand the implications of this potential contaminant source.

8 Based on the above information, it appears that the overall water quality in the lower Hudson 9 River is generally improving, although the presence of legacy contaminants still presents a 10 concern to regulatory agencies. Based on the information reviewed, the NRC staff concludes 11 that the cumulative impact of water quality on RIS should decline if efforts continue to address 12 point- and non-point pollution and legacy waste removal and treatment.

13 Climate Change 14 The potential cumulative effects of climate change on Hudson River RIS could result in a variety 15 of fundamental changes to watersheds that would affect aquatic resources. The environmental 16 factors of significance identified by Kennedy (1990) that would affect estuarine systems included 17 sea level rise, temperature increase, salinity changes, and wind and water circulation changes.

18 Changes in sea level could result in dramatic effects on nearshore communities, including the 19 reduction or redistribution of submerged aquatic vegetation, changes to marsh communities, 20 and influences to wetland areas adjacent to nearshore systems. Water temperature increases 21 could affect spawning patterns or success, or influence the distribution of key RIS when cold-22 water species move poleward while warm-water species become established in new habitats.

23 Changes to river salinity and the presence of the salt front could influence the spawning and 24 distribution of RIS, and the range of exotic or nuisance species. Fundamental changes in 25 precipitation could profoundly influence water circulation and change the nature of 26 allochothonous and autochothonous inputs to the system. This could result in fundamental 27 changes to primary production and influence the estuarine food web on many levels. Kennedy 28 (1990) also concluded that some fisheries and aquaculture enterprises and communities might 29 benefit from the results of climate change, while others would suffer extensive economic losses 30 that could lead to population shifts.

31 The extent and magnitude of climate change impacts to the aquatic resources of the lower 32 Hudson River are an important component of the cumulative assessment analyses. This 33 assessment is beyond the scope of this review and will need to be explored and evaluated by 34 others. A minimal evaluation of shifts in the distribution of RIS standardized mean density for 35 1979 to 1983 and for 2001 to 2005 was explored in Appendix H. Several RIS (striped bass, 36 alewife, spottail shiner, hogchoker, and white perch) may be shifting their distribution slightly 37 upriver while bay anchovies may be shifting their distribution seaward. This analysis attempts 38 only to explore hypotheses about potential redistribution of fish; definitive statements cannot be 39 made because of data limitations. Thus, the NRC staff has concluded that the cumulative 40 effects of climate change cannot be determined.

41 H.3 References Draft NUREG-1437, Supplement 38 H-60 December 2008

Appendix H 1 10 CFR Part 51. U.S. Code of Federal Regulations, Environmental Protection Regulations for 2 Domestic Licensing and Related Regulatory Functions, Part 51, Chapter 1, Title 10, Energy.

3 Abood, K.A., T.L. Englert, S.G. Metzger, C.V. Beckers, Jr., T.J. Groninger, and S. Mallavaram.

4 2006. Current and Evolving Physical and Chemical Conditions in the Hudson River Estuary.

5 American Fisheries Society Symposium 51, pp. 39-61.

6 Achman, D.R., B.J. Brownawell, and L. Zhang. 1996. Exchange of Polychlorinated Biphenyls 7 Between Sediment and Water in the Hudson River Estuary. Estuaries 19:4, pp. 950-965.

8 Adams, S.M. 2003. Establishing Causality Between Environmental Stressors and Effects on 9 Aquatic Ecosystems. Human and Ecological Risk Assessment, Vol. 9, No.1, pp. 17-35.

10 Atlantic States Marine Fisheries Commission (ASMFC). 2006. Species profile: Atlantic striped 11 bass, the challenges of managing a restored stock.

12 http://www.asmfc.org/speciesDocuments/stripedBass/speciesprofile.pdf. Accessed 13 December 10, 2007.

14 Atlantic Striped Bass Conservation Act of 1984. 16 USC 5151-5158, et seq.

15 Baird, D., and R.E. Ulanowicz. 1989. The Seasonal Dynamics of the Chesapeake Bay 16 Ecosystem. Ecological Monographs 59(4), pp. 329-364.

17 Barnthouse, L.W., C.C. Coutant, and W. Van Winkle. 2002. Status and Trends of Hudson 18 River Fish Populations and Communities Since the 1970s: Evaluation of Evidence Concerning 19 Impacts of Cooling Water Withdrawals. January 2002.

20 Barnthouse, L.W., D.G. Heimbuch, W. Van Winkle, and J. Young. 2008. Entrainment and 21 Impingement at Indian Point: A Biological Impact Assessment. January 2008.

22 Brosnan, T.M. and M.L. OShea. 1996. Long-term Improvements in Water Quality Due to 23 Sewage Abatement in the Lower Hudson River. Estuaries 19:4, pp. 890-900.

24 Central Hudson Gas and Electric Corporation (CHGEC). 1999. Draft Environmental Impact 25 Statement for State Pollutant Discharge Elimination System Permits for Bowline Point, Indian 26 Point 2 and 3, and Roseton Steam Electric Generating Stations. Consolidated Edison Company 27 New York, Inc. New York Power Authority and Southern Energy New York. December 1999.

28 Clean Water Act of 1977 (CWA). 33 USC 1326 et seq. (common name of the Federal Water 29 Pollution Control Act of 1977).

30 Cochran, W.G. 1997. Sampling Techniques, John Wiley and Sons, New York.

31 Consolidated Edison Company of New York (Con Edison). 1976. Indian Point Impingement 32 Study Report for the Period 1 January 1975-31 December 1975. Prepared by Texas 33 Instruments, Inc.

34 Consolidated Edison Company of New York (Con Edison). 1977. Hudson River Ecological 35 Study in the Area of Indian Point 1976 Annual Report. Prepared by Texas Instruments, Inc.

36 Consolidated Edison Company of New York (Con Edison). 1979. Hudson River Ecological 37 Study in the Area of Indian Point 1977 Annual Report. Prepared by Texas Instruments, Inc.

38 Consolidated Edison Company of New York (Con Edison). 1980. Hudson River Ecological 39 Study in the Area of Indian Point 1979 Annual Report. Prepared by Texas Instruments, Inc.

December 2008 H-61 Draft NUREG-1437, Supplement 38

Appendix H 1 Consolidated Edison Company of New York (Con Edison). 1984a. Hudson River Ecological 2 Study in the Area of Indian Point 1981 Annual Report.

3 Consolidated Edison Company of New York (Con Edison). 1984b. Precision and Accuracy of 4 Stratified Sampling to Estimate Fish Impingement at Indian Point Unit No. 2 and Unit No. 3.

5 Prepared by Normandeau Associates, Inc.

6 Consolidated Edison Company of New York (Con Edison) and New York Power Authority 7 (NYPA). 1986. Hudson River Ecological Study in the Area of Indian Point 1985 Annual 8 Report. Prepared by Normandeau Associates, Inc.

9 Consolidated Edison Company of New York (Con Edison) and New York Power Authority 10 (NYPA). 1987. Hudson River Ecological Study in the Area of Indian Point 1986 Annual 11 Report. Prepared by Normandeau Associates, Inc.

12 Consolidated Edison Company of New York (Con Edison) and New York Power Authority 13 (NYPA). 1988. Hudson River Ecological Study in the Area of Indian Point 1987 Annual 14 Report. Prepared by EA Science and Technology.

15 Consolidated Edison Company of New York (Con Edison) and New York Power Authority 16 (NYPA). 1991. Hudson River Ecological Study in the Area of Indian Point 1990 Annual 17 Report. Prepared by EA Science and Technology.

18 Daniels, R.A., K.E. Limburg, R.E. Schmidt, D.L. Strayer, and R.C. Chambers. 2005. Changes 19 in Fish Assemblages in the Tidal Hudson River, New York. American Fisheries Society 20 Symposium 45: pp. 471-503. Accessed at 21 http://www.ecostudies.org/reprints/daniels_et_al_2005.pdf on March 13, 2008 22 Ecological Analyses, Inc. (EA). 1981a. Indian Point Generating Station Entrainment Survival 23 and Related Studies. 1979 Annual Report. Prepared for Consolidated Edison Company of New 24 York, Inc., and Power Authority of the State of New York. Ecological Analysts, Inc.

25 January 1982.

26 Ecological Analyses, Inc. (EA). 1981b. 1981 Con Edison Automated Abundance Sampling 27 (AUTOSAM) and Laboratory Processing Standard Operating Procedures. Prepared for 28 Consolidated Edison Company of New York, Inc. Ecological Analysts, Inc. May 1981.

29 Ecological Analyses, Inc. (EA). 1982. Indian Point Generating Station Entrainment Survival 30 and Related Studies. 1980 Annual Report. Prepared for Consolidated Edison Company of New 31 York, Inc., and Power Authority of the State of New York. Ecological Analysts, Inc. April 1981.

32 Ecological Analyses, Inc. (EA). 1984. Indian Point Generating Station Entrainment Abundance 33 and Outage Evaluation, 1983 Annual Report. Prepared for Consolidated Edison Company of 34 New York, Inc., and Power Authority of the State of New York. EA Engineering, Science and 35 Technology, Inc. September 1984.

36 Ecological Analyses, Inc. (EA). 1985. Indian Point Generating Station Entrainment Abundance 37 and Outage Evaluation, 1983 Annual Report. Prepared for Consolidated Edison Company of 38 New York, Inc., and Power Authority of the State of New York. EA Engineering, Science and 39 Technology. July 1985.

40 Ecological Analyses, Inc. (EA). 1989. Indian Point Generating Station 1988 Entrainment 41 Survival Study. Prepared for Consolidated Edison Company of New York, Inc., and Power Draft NUREG-1437, Supplement 38 H-62 December 2008

Appendix H 1 Authority of the State of New York. EA Engineering, Science and Technology, Northeast 2 Regional Operations, Report No. 10648.03. August 1989.

3 Entergy Nuclear Operations Inc. (Entergy). 2003. Indian Point Nuclear Power Plant, Units No.

4 1, 2, and 3Annual Radiological Environmental Operating Report [for 2002]. Docket Numbers 5 50-03, 50-247, and 50-286, Buchanan, New York. Agencywide Documents Access and 6 Management System (ADAMS) Accession No. ML031220085.

7 Entergy Nuclear Operations Inc. (Entergy). 2004. Indian Point Nuclear Power Plants, Units 1, 8 2, and 3Indian Points Annual Radiological Environmental Operating Report for 2003. Docket 9 Numbers50-003, 50-247, and 50-286, Buchanan, New York. Adams Accession 10 No. ML041340492.

11 Entergy Nuclear Operations Inc. (Entergy). 2005. Indian Point Units 1, 2, and 32004 Annual 12 Radiological Environmental Operating Report. Docket Numbers 50-3, 50-247, and 50-286, 13 Buchanan, New York. ADAMS Accession No. ML051220210.

14 Entergy Nuclear Operations Inc. (Entergy). 2006. Indian Point Nuclear Power Plants, Units 1, 2 15 and 3Annual Radiological Environmental Operating Report for 2005. Docket Numbers 50-3, 16 50-247, and 50-286, Buchanan, New York. ADAMS Accession No. ML061290085.

17 Entergy Nuclear Operations, Inc. (Entergy). 2007. Applicants Environmental Report, 18 Operating License Renewal Stage. (Appendix E of Indian Point Units 2 and 3, License 19 Renewal Application.) April 23, 2007. ADAMS Accession No. ML071210530.

20 Entergy Nuclear Operations, Inc. (Entergy). 2008. Letter from F. Dacimo, Vice President, 21 Entergy Nuclear Operations, to U.S. Nuclear Regulatory Commission Document Control Desk.

22

Subject:

Reply to Document Request for Additional Information Regarding Site Audit Review of 23 License Renewal Application for Indian Point Nuclear Generating Unit Nos. 2 and 3. April 23, 24 2008.

25 Environmental Protection Agency (EPA). 1992. Framework for Ecological Risk Assessment.

26 EPA/630/R-92-001. Risk Assessment forum, Washington, D.C. 41 pp. Accessed at 27 http://rais.ornl.gov/homepage/FRMWRK_ERA.PDF 28 Environmental Protection Agency (EPA). 2004. Total Maximum Daily Loads, Listed Water 29 Information, Cycle: 2004. Hudson River, Lower Hudson River. Accessed at 30 http://oaspub.epa.gov/tmdl/enviro.control?p_list_id=NY-1301-0002andp_cycle=2004 on 31 February 23, 2008.

32 Environmental Protection Agency (EPA). 2008. Hudson River PCB Superfund Site, Dredge 33 Area 2 Delineation Fact Sheet, 2008.

34 Accessed at http://www.epa.gov/hudson/factsheet_2nd_phaselow.pdf on February 4, 2008.

35 Fish and Wildlife Service (FWS). 2007. Letter from R. A. Niver, Endangered Species Biologist, 36 to Rani Franovich, Branch Chief, Projects Branch 2, Division of License Renewal, Office of 37 Nuclear Reactor Regulation, NRC, Washington, DC. Response to letter from NRC requesting 38 information on federally listed, proposed, and candidate species and critical habitat in the 39 vicinity of Indian Point Nuclear Generating Station Unit Nos. 2 and 3. August 29.

40 Fletcher, R.I. 1990. Flow dynamics and fish recovery experiments: Water intake systems.

December 2008 H-63 Draft NUREG-1437, Supplement 38

Appendix H 1 Transactions of the American Fisheries Society, 119:393-415.

2 Frank, K.T., B. Petrie, and N.L. Shackell. 2007. The Ups and Downs of Trophic Control in 3 Continental Shelf Ecosystems. Trends in Ecology and Evolution 22:5, pp. 236-242.

4 Greenwood, M.F.D. 2008. Trawls and Cooling-water Intakes as Estuarine Fish Sampling 5 Tools: Comparisons of Catch Composition, Trends in Relative Abundance, and Length 6 Selectivity, Estuarine, Coastal and Shelf Science 76:121-130.

7 Mayhew, D.A., L.D. Jensen, D.F. Hanson, and P.H. Muessig, 2000. A Comparative Review of 8 Entrainment Survival Studies at Power Plants in Estuarine Environments, Environmental 9 Science and Policy 3, pp. 295-301.

10 Menzie, C., M. H. Henning, J. Cura, K. Finkelstein, J. Gentile, J. Maughan, D. Mitchell, S.

11 Petron, B. Potocki, S. Svirsky, and P. Tyler. 1996. Report of the Massachusetts Weight-of-12 Evidence Workgroup: A Weight-of-Evidence Approach for Evaluating Ecological Risks.

13 Human and Ecological Risk Assessment 2:277-304.

14 New York Power Authority (NYPA). 1986. Size selectivity and relative catch efficiency of a 3-15 m beam trawl and a 1-m2 epibenthic sled for sampling young of the year striped bass and other 16 fishes in the Hudson River estuary. Prepared by Normandeau Associates, Inc. January 1986.

17 (HR Library #7180) 18 New York State Department of Environmental Conservation (NYSDEC). 2003a. Final 19 Environmental Impact Statement Concerning the Applications to Renew New York State 20 Pollutant Discharge Elimination System (SPDES) Permits for the Roseton 1and2 Bowline 1and2 21 and IP2 and IP3 2and3 Steam Electric Generating Stations, Orange, Rockland and Westchester 22 Counties. Hudson River Power Plants FEIS. June 25, 2003.

23 New York State Department of Environmental Conservation (NYSDEC). 2003b. Fact Sheet.

24 New York State Pollutant Discharge Elimination System (SPDES) Draft Permit Renewal with 25 Modification, IP2 and IP3 Electric Generating Station, Buchanan, NY November 2003.

26 Accessed at http://www.dec.ny.gov/docs/permits_ej_operations_pdf/IndianPointFS.pdf on 27 July 12, 2007.

28 New York State Department of Environmental Conservation (NYSDEC). 2007. State of New 29 York Petition submitted to the U.S. Nuclear Regulatory Commission, November 30, 2007, on 30 the Application of Entergy Nuclear Operations, Inc., for the 20-year Relicensing of Indian Point 31 Nuclear Power Plants 1 and 2, Buchanan, New York. Summary of Some of the Key 32 Contentions. Accessed at http://www.dec.ny.gov/permits/40237.html on March 18, 2008.

33 Normandeu Associates (Normandeu). 1987a. IP2 and IP3 Generating Station Entrainment 34 Abundance Program, 1985 Annual Report. Prepared for Consolidated Edison Company of New 35 York, Inc., and New York Power Authority. Prepared by Normandeu Associates, Inc.

36 Report R-332-1062. April 1987.

37 Normandeu Associates (Normandeu). 1987b. IP2 and IP3 Generating Station Entrainment 38 Abundance Program, 1986 Annual Report. Prepared for Consolidated Edison Company of New 39 York, Inc., and New York Power Authority. Prepared by Normandeu Associates, Inc.

40 Report R-220. June 1987.

41 Normandeu Associates (Normandeu). 1988. IP2 and IP3 Generating Station Entrainment 42 Abundance Program, 1987 Annual Report. Prepared for Consolidated Edison Company of New Draft NUREG-1437, Supplement 38 H-64 December 2008

Appendix H 1 York, Inc., and New York Power Authority. Prepared by Normandeu Associates, Inc.

2 Report R-1110. May 1988.

3 Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement for 4 License Renewal of Nuclear Power Plants. NUREG-1437, Volumes 1 and 2, Washington, DC.

5 Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement for 6 License Renewal of Nuclear Plants Main Report, Section 6.3Transportation, Table 9.1, 7 Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants.

8 NUREG-1437, Volume 1, Addendum 1, Washington, DC.

9 Secor, D.H. and E D. Houde. 1995. Temperature Effects on the Timing of Striped Bass Egg 10 Production, Larval Viability, and Recruitment Potential in the Patuxent River (Chesapeake 11 Bay). Estuaries 18, pp. 527-533.

12 Shepherd G. 2006. Atlantic Striped Bass. Accessed at 13 http://www.nefsc.noaa.gov/sos/spsyn/af/sbass/archives/40_StripedBass_2006.pdf on 14 December 10, 2007.

15 Shepherd G. 2006. Bluefish. Accessed at 16 http://www.nefsc.noaa.gov/sos/spsyn/op/bluefish/archives/25_Bluefish_2006.pdf.

17 Snedecor G.W. and W.G. Cochran. 1980. Statistical Methods. The Iowa State University 18 Press, Ames, Iowa.

19 Steinberg, N., D.J. Suszkowski, L. Clark, and J. Way. 2004. Health of the Harbor: The First 20 Comprehensive Look at the State of the NY, NY Harbor Estuary. A Report to the New 21 York/New Jersey Harbor Estuary Program. Hudson River Foundation, New York.

22 Strayer, D.L., K.A. Hattala, and A.W. Kahnle. 2004. Effects of an Invasive Bivalve (Dreissena 23 polymorpha) on Fish in the Hudson River Estuary. Canadian Journal of Fisheries and Aquatic 24 Sciences 61, pp. 924-941.

25 Ulanowicz, R.E. 1995. Trophic Flow Networks as Indicators of Ecosystem Stress. In: G.A.

26 Polis and K.O. Winemiller (eds). Food Webs: Integration of Patterns and Dynamics, Chapman 27 and Hall, NY, pp. 358-368.

28 Wolfe, D.A., E.R. Long, and G.B. Thursby. 1996. Sediment Toxicity in the Hudson-Raritan 29 Estuary: Distribution and Correlations with Chemical Contamination. Estuaries 19:4, pp. 901-30 912.

December 2008 H-65 Draft NUREG-1437, Supplement 38

Appendix I Statistical Analyses Conducted for Chapter 4 Aquatic Resources and Appendix H

1 Appendix I 2 Statistical Analyses Conducted for Chapter 4 Aquatic Resources and 3 Appendix H 4 Supporting analyses and data tables are presented by section as referenced in the Aquatic 5 Resources sections of Appendix H. Major section headings are maintained to allow mapping 6 between appendices. This appendix includes supporting information for the U.S. Nuclear 7 Regulatory Commission (NRC) staff assessment of impingement impacts (Appendix H, 8 Section 1.3), the assessment of population trends (Appendix H, Section 3.1), the analysis of 9 strength of connection (Appendix H, Section 3.2), and the cumulative impacts on aquatic 10 resources (Appendix H, Section 4).

11 I.1 Impingement of Fish and Shellfish 12 I.1.1. NRC Staff Assessment of Impingement Impacts 13 Staff conducted simple linear regression over years on the number of days of operation and the 14 combined volume of water discharged for Indian Point Nuclear Generating Station Unit Nos. 2 15 and 3 (IP2 and IP3) between 1975 and 1990 (Table I-1). Days of operation from 1975 to 1981 16 were obtained from impingement data provided by Entergy Nuclear Operations, Inc. (the 17 applicant) (Entergy 2007b). Days of operation for the remaining years and the combined 18 volume discharged were compiled from the annual reports for the Hudson River Ecological 19 Study in the area of IP2 and IP3 (Con Edison 1980; Con Edison 1984, 1986-1991). The 20 number of days of operation at IP2 and IP3 had a general increase of 8 days per year for IP2 21 and 5 days per year for IP3 (linear regression, p = 0.004 and p = 0.286 for IP2 and IP3, 22 respectively). The total volume circulated at IP2 and IP3 combined also had a general increase 23 of 26.2 106 cubic meters (m3; linear regression, p = 0.164).

December 2008 I-1 Draft NUREG-1437, Supplement 38

Appendix I 1 Table I-1 Number of Days of Operation at IP2 and IP3 and Combined Discharge Combined Volume Year Days of Operation (millions m3)

IP2 IP3 1975 307 1119 1976 176 239 1329 1977 265 259 2159 1978 234 270 2030 1979 246 227 1935 1980 263 261 1822 1981 276 297 1617 1982 304 135 1273 1983 340 48 1286 1984 238 306 1710 1985 365 266 1977 1986 285 357 1892 1987 346 265 1815 1988 357 352 2322 1989 302 301 1748 1990 365 272 1902 2 Source: Days of Operation: Entergy 2007b; Con Edison 1984, 1986-1991 3 Volume Discharged: Con Edison 1980, 1991 4 I.2 Combine Effects of Impingement and Entrainment 5 I.2.1. Assessment of Population Trends 6 Studies Used To Evaluate Population Trends 7 The Hudson River utilities conducted the Fall Juvenile Shoals Survey (FSS) from 1974 to 2005 8 and targeted juveniles, yearlings, and older fish. Between 1974 and 1984, a 1-square meter 9 (m2) Tucker trawl with a 3-millimeter (mm) mesh was used to sample the channel and a 1-m2 10 epibenthic sled with a 3-mm mesh was used to sample the bottom and shoal strata. From 1985 11 to 2005, a 3-meter (m) beam trawl with a 38-mm mesh on all but the cod-end replaced the 12 epibenthic sled. Size selectivity and relative catch efficiency between gear types was tested 13 during nocturnal samplings between August and September 1984. Bay anchovy, American 14 shad, and weakfish were sampled with less efficiency with the beam trawl (Table I-2) (NYPA 15 1986). Further, the number and volume of samples in the bottom and shoal strata were 16 generally greater than 2.5 times those in the channel (Table I-3).

17 The Beach Seine Survey (BSS) was conducted from 1974 to 2005 and targeted young of the 18 year (YOY) and older fish in the shore-zone (extending from the shore to a depth of 10 feet (ft)).

19 Samples were collected from April to December but generally every other week from mid-June 20 through early October (Table I-4). For all years, a 100-ft bag beach seine was used to collect 21 100 samples during each sampling period from beaches selected according to a stratified Draft NUREG-1437, Supplement 38 I-2 December 2008

Appendix I 1 random design. Even though the catch-per-unit-effort (CPUE) for representative important 2 species (RIS) differed in magnitude between the BSS and FSS (Table I-5), standardizing the 3 data (observed CPUE minus the mean CPUE and divided by the standard deviation across 4 years) allowed a comparison of the shape of the data over time. Thus, NRC staff conducted a 5 visual comparison of the standardized BSS and FSS data determine if a shift in gear types was 6 affecting the observed FSS trend. When the standardized FSS data were consistently less than 7 the standardized BSS data after 1985, the pre- and post-1985 data were evaluated separately.

8 Table I-2 Catch by Gear or Gear Efficiency (catch per 1000 m2) 9 from August to September 1984 Young of the Year Yearling and Older 1-m2 Epibenthic 3-m Beam Trawl Sled 3-m Beam Trawl 1-m2 Epibenthic (n = 257) (n = 322) (n = 257) Sled (n = 322)

Mean Standard Mean Standard Mean Standard Mean Standard Species Density Error Density Error Density Error Density Error Bay Anchovy 29.0 3.0 1261 61.9 0.6 0.1 11.2 1.2 American Shad 0.4 0.1 4.4 3.0 0.0 0.0 0.0 0.0 Bluefish 0.1 <0.1 0.3 0.1 0.0 0.0 0.0 0.0 Hogchoker 0.1 <0.1 0.1 <0.1 5.4 0.4 1.5 0.2 Striped Bass 13.3 0.8 3.4 0.4 0.2 <0.1 0.1 <0.1 White Catfish 0.0 0.0 0.0 0.0 1.6 0.2 1.0 0.1 White Perch 1.3 0.2 0.1 <0.1 22.1 1.6 6.4 1.3 Weakfish 0.7 0.1 1.9 0.3 0.0 0.0 0.0 0.0 10 Source: NYPA 1986 December 2008 I-3 Draft NUREG-1437, Supplement 38

Appendix I 1 Table I-3 Changes to the Design and Gear Used During the Fall Juvenile Survey Number Samples per Gear of Epibenthic Tucker Beam Sample Collection 3

Year Volume (m ) Samples Sled Trawl Trawl Dates 1974 728083 1690 100/wk Weekly, Aug-Dec 1975 317749 901 100/wk Biweekly, Aug-Dec 1976 365903 881 100/wk Biweekly, Aug-Dec 1977 368134 826 100/wk Biweekly, Aug-Dec 1978 352420 900 100/wk Biweekly, Aug-Dec 1979 1,006,411 2387 150/wk 50/wk Biweekly, July-Dec 1980 771291 2103 150/wk 50/wk Biweekly, July-Dec 1981 479591 1199 150/wk 50/wk Biweekly, Aug-Oct 1982 400969 1000 150/wk 50/wk Biweekly, Aug-Oct 1983 477057 1199 150/wk 50/wk Biweekly, Aug-Oct 1984 601459 1601 150/wk 50/wk Biweekly, July-Oct 1985 1886754 1802 ~500 ~1,500 Biweekly, July-Nov 1986 2,298,395 2098 549 1,549 Biweekly, July-Dec 1987 2035472 1891 495 1,396 Biweekly, July-Nov 1988 1826692 1680 440 1,240 Biweekly, July-Oct 1989 1590118 1679 439 1,240 Biweekly, July-Oct 1990 1252994 1680 439 1,241 Biweekly, July-Oct 1991 1707319 1678 440 1,238 Biweekly, July-Oct 1992 1865451 1680 440 1,240 Biweekly, July-Oct 1993 2010222 1680 440 1,240 Biweekly, July-Oct 1994 2018494 1681 440 1,241 Biweekly, July-Oct 1995 1782199 1680 440 1,240 Biweekly, July-Oct 1996 1824802 1669 484 1,185 Biweekly, July-Oct 1997 1995519 2015 826 1,189 Biweekly, July-Nov 1998 2214707 2130 825 1,305 Biweekly, July-Dec 1999 2160009 2085 823 1,262 Biweekly, July-Dec 2000 2174896 2113 816 1,297 Biweekly, July-Nov 2001 2097877 2084 818 1,266 Biweekly, July-Oct 2002 2105272 2128 821 1,307 Biweekly, July-Dec 2003 1891135 2131 825 1,306 Biweekly, July-Dec 2004 2106874 2128 823 1,305 Biweekly, July-Dec 2005 2063654 2128 824 1,304 Biweekly, July-Dec 2 Note: Compiled from the annual Year Class Reports for the Hudson River Estuary Monitoring Program; ASA 1999, 3 2001a, 2001b, 2003, 2004a, 2004b, 2005-2007; Battelle 1983; ConEd undated a, undated b, 1996; EA 1990, 1995, 4 1991; LMS 1989, 1991, 1996; MMES 1983; Versar 1987; TI 1977-1981; NAI 1985a, 1985b, 2007.

Draft NUREG-1437, Supplement 38 I-4 December 2008

Appendix I 1 There were four basic combinations of sampling intensities, duration, and gear types used 2 during the FSS (Table I-3). Likewise, there were roughly three levels of sampling intensity used 3 during the BSS (Table I-4). Thus, for data provided on a weekly basis, only weeks 27 to 43 4 were used in the analysis for the FSS and weeks 22 to 43 for the BSS survey, so that most 5 years contained observations from the months of July through October and June through 6 October for each survey, respectively.

7 Table I-4 Number of Weeks Sampled Each Month During the BSS Year April May June July August September October November December 1974 4 4 4 5 4 5 4 4 3 1975 5 4 4 5 4 5 4 4 3 1976 5 4 4 5 4 5 4 4 2 1977 4 4 4 5 4 5 4 4 3 1978 4 4 4 5 4 5 4 4 4 1979 5 4 4 5 4 5 4 4 2 1980 5 4 4 5 4 2 2 2 1 1981 0 0 0 0 2 3 2 0 0 1982 0 0 0 0 1 3 1 0 0 1983 0 0 0 0 2 3 1 0 0 1984 0 0 0 1 2 2 2 1 0 1985 0 0 0 2 2 2 2 2 0 1986 0 0 0 2 2 2 2 2 0 1987 0 0 1 2 2 3 2 1 0 1988 0 0 1 3 2 2 2 1 0 1989 0 0 1 3 2 2 2 1 0 1990 0 0 1 3 2 2 2 0 0 1991 0 0 1 2 2 3 2 0 0 1992 0 0 1 2 2 3 2 0 0 1993 0 0 0 3 2 2 2 1 0 1994 0 0 0 3 2 2 2 1 0 1995 0 0 1 2 2 3 2 0 0 1996 0 0 1 3 2 2 2 0 0 1997 0 0 1 3 2 2 2 0 0 1998 0 0 1 3 2 2 2 0 0 1999 0 0 1 3 2 2 2 0 0 2000 0 0 1 3 2 2 2 0 0 2001 0 0 1 3 2 2 2 0 0 2002 0 0 1 3 2 2 2 0 0 2003 0 0 1 3 2 2 2 0 0 2004 0 0 1 3 2 2 2 0 0 2005 0 0 1 3 2 2 2 0 0 8 Source: NRC Request for Sampling Effort and Abundance Data from Three Hudson River Sampling Programs for 16 9 Selected Fish Species from 1974 through 2005, Normandeau Associates Inc., February 25, 2008 December 2008 I-5 Draft NUREG-1437, Supplement 38

Appendix I 1 Metrics Used To Evaluate Population Trends 2 Abundance Index 3 The abundance index for YOY for each species was based on the catch from a selected 4 sampling program and used by the applicant and its contractors to estimate riverwide mean RIS 5 abundances. The selection process considered the expected location of each species in the 6 river, based on life-history characteristics and the observed catch rates from previous sampling.

7 The abundance index was constructed to account for the stratified random sampling design 8 used by each of the surveys. For the Long River Survey (LRS) and the FSS, sampling within a 9 river segment was further stratified by river depth and sampled with separate gear types. For 10 blueback herring, alewife, bay anchovy, hogchoker, weakfish, and rainbow smelt, the YOY 11 abundance index was based on the catch from a single gear type (Table I-5).

12 The construction of the LRS (LA) and the FSS abundance index (FA) were similar and provided 13 an unbiased estimate of the total and mean riverwide population abundance for selected 14 species, respectively (Cochran 1997). For the FSS and each gear type, FA was constructed as 15 a weighted mean of the average species density with weight given by the volume of each 16 stratum for a given river segment. For the FSS, strata sampled were the channel, bottom, and 17 shoal for a given river segment. Poughkeepsie and West Point river segments had the greatest 18 channel volume, Poughkeepsie and Tappan Zee had the greatest bottom volume, and Tappan 19 Zee had the greatest shoal volume (Table I-6). Because the river segment associated with IP2 20 and IP3 did not have large bottom or shoal volumes, the abundance index was not sensitive to 21 changes in population trends within the vicinity of IP2 and IP3.

22 Table I-5 Sampling Program Used To Calculate the Abundance Index for YOY and 23 Yearling Fish and the Median Catch-per-Unit-Effort Over Time Riverwide FSS Median Riverwide BSS YOY Catch-per- Median YOY Catch-Species Sampling Program Unit-Effort per-Unit-Effort Alewife FSS-Channel 4.35E-04 1.05 Bay Anchovy FSS-Channel 2.61E-02 6.70 American Shad BSS 8.12E-04 9.17 Bluefish BSS 3.18E-05 3.36E-01 Hogchoker FSS-Bottom 1.03E-02 2.30E-01 Blueback Herring FSS-Channel 1.12E-02 2.86E+01 Rainbow Smelt FSS-Channel N/Aa < 0.0001 Spottail Shiner FSS-Channel 1.10E-04 7.25 Stripped Bass BSS 2.47E-03 6.47 Atlantic Tomcod LRS 2.69E-03 6.70E-02 White Catfish BSS N/A 2.50E-02 White Perch BSS 5.89E-03 10.4 Weakfish FSS-Channel N/A 5.00E-03 a

24 N/A = not applicable; YOY not present in samples 25 Source: CHGE 1999 Draft NUREG-1437, Supplement 38 I-6 December 2008

Appendix I 1 Table I-6 Volume of Sampling Strata by River Segment River Volume (m3) Area (m2)

Region Segment Channel Bottom Shoal Region Shore Zone Battery 0 141,809,822 48,455,129 18,747,833 209,012,784 N/A Yonkers 1 143,452,543 59,312,978 26,654,767 229,420,288 3,389,000 Tappan Zee 2 138,000,768 62,125,705 121,684,992 321,811,465 20,446,000 Croton-Haverstraw 3 61,309,016 32,517,633 53,910,105 147,736,754 12,101,000 Indian Point 4 162,269,471 33,418,632 12,648,163 208,336,266 4,147,000 West Point 5 178,830,022 25,977,862 2,647,885 207,455,769 1,186,000 Cornwall 6 94,882,267 36,768,629 8,140,123 139,791,019 4,793,000 Poughkeepsie 7 228,975,052 63,168,132 5,990,260 298,133,444 3,193,000 Hyde Park 8 131,165,041 32,012,000 2,307,625 165,484,666 558,000 Kingston 9 93,657,021 35,479,990 12,332,868 141,469,879 3,874,000 Saugerties 10 113,143,296 42,845,077 20,307,338 176,295,711 7,900,000 Catskill 11 83,924,081 42,281,206 34,526,456 160,731,743 8,854,000 Albany 12 32,025,080 13,517,183 25,606,842 71,149,105 6,114,000 2 N/A - not applicable. Data from Entergy 2007b.

3 Analysis of Population Impacts 4 As discussed in Section H.3, the analysis was based on YOY fish to assess the population 5 trends. For the river-segment analysis, the median and the 75th percentile of the densities of 6 YOY caught within a given year in the vicinity of IP2 and IP3 (River Segment 4) were used to 7 bound population trends for a visual representation. The median and 75th percentile are less 8 sensitive to extreme values than the mean. Fish population sizes and the chance of catching 9 fish were highly variable, and a few large catches can influence the mean and potentially distort 10 a trend analysis. For example, the mean density for alewives caught during the FSS in the 11 vicinity of IP2 and IP3 tended to be equal to or greater than the 75th percentile of the density for 12 most years because of the relatively fewer large observations (Figure I-1). Further, seasonal 13 and interannual differences in the salt front position may influence the pattern of trends in total 14 or mean abundance between river segments. Evaluating the 75th percentile of the weekly data 15 removed the influence from any given week associated with potentially extreme environmental 16 characteristics.

17 River-segment data collected from 1979-2005 (n = 27 for each RIS) was standardized by 18 subtracting the first 5-year mean and dividing by the standard deviation based on all years.

19 Because of the large variability between years (coefficients of variation (CVs) ranging from 67 to 20 247 percent), a 3-year moving average was used to smooth the river-segment data before the 21 trend analysis. Two competing models, simple linear regression and segmented regression 22 with a single join point, were statistically fit to the smoothed and standardized 75th percentile of 23 the annual observed densities for each taxon. The model with the smallest mean square error 24 (MSE) was chosen as the better fitting model and used to determine the level of potential injury.

25 Extreme outliers (values greater than 2 standard deviations from the mean) were removed from 26 the analysis if the segmented regression was unable to converge; results with and without 27 outliers were recorded. All data (1979-2005) from the FSS were compared to the BSS to 28 determine if changes in the gear type affected the observed trend. When the standardized FSS December 2008 I-7 Draft NUREG-1437, Supplement 38

Appendix I 1 data were consistently less than the standardized BSS data after 1985, the pre- and post-1985 2 data were evaluated separately.

3 Figure I-1 Relationship among the mean, the median, and the 75th percentile of the fish 4 density for alewives caught during the FSS in River Segment 4 5

6 Note: The value 0.001 was added to all numbers so that the log scale could be used for plotting.

7 For the riverwide data collected from 1979-2005 (n = 27 for each RIS), the FSS CPUE, the BSS 8 CPUE, and the abundance index for the YOY were used to assess the population trends.

9 Riverwide data consisted of a single number per year for a given taxon and life stage. CVs 10 ranged from 60 percent to 154 percent for the FSS, 41 percent to 302 percent for the BSS, and 11 49 percent to 319 percent for the abundance index. Simple linear regression and segmented 12 regression with a single join point were fit to the standardized data (using the first 5-year mean 13 and the standard deviation based on all years). Extreme outliers were removed from the 14 analysis if the segmented regression was unable to converge; results with and without outliers 15 were recorded. The model with the smallest MSE was chosen as the best-fit model and used to 16 determine the level of potential injury. All data (1979-2005) from the FSS were compared to the 17 BSS to determine if changes in the gear type affected the observed trend. When the Draft NUREG-1437, Supplement 38 I-8 December 2008

Appendix I 1 standardized FSS data were consistently less than the standardized BSS data after 1985, NRC 2 staff evaluated the pre- and post-1985 data separately.

3 The FSS density and CPUE for a given RIS can be highly correlated when nearly all of the fish 4 are caught from a single habitat (channel, shoal, or bottom) for the majority of sampling events.

5 For these RIS, the weight-of-evidence (WOE) analysis was conducted both with and without the 6 FSS CPUE results. Because of the slight variation in response between the two measures of 7 population trend, different result scores can occur. However, for all RIS, the final determination 8 of the level of impact associated with the IP2 and IP3 cooling systems was the same by either 9 method. Thus, the correlation between measures was ignored.

10 For each data set, the results of the linear and segmented regression were presented in a 11 series of two tables and a figure if a conclusion of potential large impact to any RIS population 12 was made. The statistics displayed in the first table included the MSE for each model; the 13 estimate of the linear slope and associated 95 percent confidence interval; the p-value 14 associated with the significance test of the null hypothesis that the slope (S) associated with the 15 simple linear model equals zero; the 95 percent confidence interval (CI) of the two slopes from 16 the segmented regression (Slope 1=S1 and Slope 2=S2); and the estimated join point. For the 17 segmented regression, slopes were defined as significant if the CI did not include zero.

18 The best-fit model (defined as the model with the smaller MSE) was then characterized in a 19 second table, based on the general trend depicted by the direction of the estimated slopes. If 20 the slope was significantly different from 0, the trend was represented by either the statement 21 S >0 for a positive slope or S <0 for a negative slope. If the slope was not significant, the 22 statement depicting the lack of a trend was S = 0. This table also included the assessment of 23 the percentage of observations outside the defined level of environmental noise, defined as 24 +/- 1 standard deviation from the mean. A percentage greater than 40 percent outside this 25 defined level of noise was assumed to provide support for a potential impact, based on the 26 assumption that the proportion of extreme observations was a measure of stability. A level of 27 potential negative impact was then determined, based on the decision rules presented in 28 Section 4.1 of the draft Supplemental Environmental Impact Statement (SEIS). If a large 29 potential for a negative impact was concluded for any RIS, a figure of the data and the best-fit 30 model was presented.

31 IP2 and IP3 River Segment 4 32 As stated above, there were two different gear types used during the FSS to sample the bottom 33 and shoal habitats. From 1979 to 1984, an epibenthic sled was used, and from 1985 to 2005, a 34 beam trawl was used. Because there were not enough annual observations from the 1979-35 1984 time period to conduct a segmented regression, a simple linear regression was conducted 36 to assess the slope of the density of fish near IP2 and IP3. These data were standardized to 37 the average of the first 2 years and divided by the standard deviation of all six observations.

38 Only white perch had a significant negative slope (n = 6, p = 0.01; Figure I-2). Hogchoker and 39 rainbow smelt appeared to have negative trends, but they were not significant (p= 0.15 and 0.33 40 respectively). Rainbow smelt and white perch had 67 percent of their observations less than -1.

December 2008 I-9 Draft NUREG-1437, Supplement 38

Appendix I 3

Standardized FJS Density Hogchoker 2 Rainbow Smelt 1 W hite Perch 0

-1

-2

-3 0 1 2 3 4 5 6 Years of Survey 1

2 Figure I-2 River Segment 4 population trends based on the first 6 years (1979-1984) of 3 FSS standardized density data for selected RIS 4 Data collected between 1985 and 2005 were temporally disconnected from the mid-1970s, 5 when operation began at IP2 and IP3. There was a potential that fish populations responded 6 earlier and stabilized to a lower abundance level. For this analysis, data were standardized with 7 the average of 1985 to 1989 and the standard deviation of all data between 1985 and 2005.

8 This analysis was used only when the observed response from all data was biologically different 9 from the BSS population density trend and had a decline associated with the gear change.

10 A visual comparison of the river-segment FSS standardized density with the BSS standardized 11 density suggested that the trends were not biologically different for American shad, Atlantic 12 tomcod, blueback herring, and striped bass (Figure I-3). Observations from the two surveys 13 overlap and cross over each other. The post-1985 FSS observations for bluefish, white perch, 14 and alewife were greater than the BSS observations and did not show a decline associated with 15 the gear change (Figure I-4). Thus, for these RIS, all of the FSS data (1979-2005) were used 16 in the regression analysis. The FSS density data for bay anchovy and weakfish, however, did 17 show a potential gear effect (Figure I-5), and a pre- and post-1985 analysis was conducted.

Draft NUREG-1437, Supplement 38 I-10 December 2008

Appendix I 2 FJS gear change FJS gear change 2 Standardized Density Standardized Density 1

1 0

0

-1

-1

-2 0 5 10 15 20 25 30 -2 0 5 10 15 20 25 30 Years of Survey Years of Survey American Shad-D-BSS Atlantic tomcod R2-D-BSS American Shad-D-FJS Atlantic Tomcod-D-FJS FJS gear change FJS gear change 2 2 Standardized Density Standardized Density 1 1 0 0

-1 -1

-2 -2 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey Blueback Herring-D-BSS Striped Bass-D-BSS Blueback Herring-D-FJS Striped Bass-D-FJS 1 Note: All data were used in WOE analysis; R2 = River Segment 2, Yonkers 2 Figure I-3 River Segment 4 population trends based on the BSS and FSS standardized 3 density (D) not considered biologically different December 2008 I-11 Draft NUREG-1437, Supplement 38

Appendix I 2 FJS gear change 2 FJS gear change Standardized Density Standardized Density 1 1 0 0

-1 -1

-2 -2

-3 -3 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey Bluefish-D-BSS W hite Perch-D-BSS Bluefish-D-FJS W hite Perch-D-FJS 2 FJS gear change Standardized Density 1

0

-1

-2 0 5 10 15 20 25 30 Years of Survey Alewife-D-BSS Alewife-D-FJS 1 Note: All data were used in WOE analysis.

2 Figure I-4 River Segment 4 population trends based on the BSS and FSS standardized 3 density (D) for which the FSS density is greater Draft NUREG-1437, Supplement 38 I-12 December 2008

Appendix I FJS gear change 2

Standardized Density 1

0

-1

-2

-3 0 5 10 15 20 25 30 Years of Survey Bay Anchovy-D-BSS Bay Anchovy-D-FJS 2 FJS gear change Standardized Density 1

0

-1

-2 0 5 10 15 20 25 30 Years of Survey W eakfish R2-D-BSS W eakfish-D-FJS 1 Note: All years were analyzed separately for WOE analysis; R2 = River Segment 2, Yonkers 2 Figure I-5 River Segment 4 population trends based on the BSS and FSS standardized 3 density (D) for which the FSS may indicate a gear difference December 2008 I-13 Draft NUREG-1437, Supplement 38

Appendix I 1 The following tables are the intermediate analyses for the assessment of population trends 2 associated with fish density sampled from River Segment 4. Results of these river-segment 3 trend analyses are compiled in Table H-13 in Section H.3 of the draft SEIS. The data used in 4 this analysis, in order of appearance, were the standardized 75th percentile of the weekly fish 5 density for a given year collected from the FSS (Table I-7, Table I-8, and Figure I-6), BSS 6 (Table I-9, Table I-10, and Figure I-7), and LRS for Atlantic tomcod only (Table I-11 and Table I-7 12).

8 Two FSS alewife density observations, not extreme outliers, were removed from the regression 9 analysis to allow the segmented regression to converge (Tables I-7 and I-8). These 10 observations corresponded to the peaks in two sporadic increases. Three FSS white catfish 11 density observations, also not extreme outliers, were removed from the regression analysis to 12 allow the segmented regression to converge. The results of both regression models with the 13 observations removed were considered more conservative and were used for the trend 14 analysis.

Draft NUREG-1437, Supplement 38 I-14 December 2008

Appendix I 1 Table I-7 Competing Models Used To Characterize the Standardized River Segment 4 2 FSS Population Trends of YOY Fish Density Using a 3-Year Moving Average Linear Regression Segmented Regression 95 percent CI Join 95 percent CI Species MSE Slope p-value MSE Slope 1 Point Slope 2 Alewife (All data) 0.58 -0.035 +/- 0.016 0.040 Did Not Converge Alewife (2 values -3.93e+008 to removed) 0.47 -0.041 +/- 0.014 0.007 0.50 -0.070 to -0.007 2004 3.93e+008 Bay Anchovy 1979-1984 1.10 -0.102 +/- 0.262 0.716 Not Fit Bay Anchovy 1985-2005 0.96 -0.058 +/- 0.035 0.113 0.91 -0.174 to 0.473 1986 -0.285 to -0.002 American Shad (All data) 0.35 -0.079 +/- 0.010 < 0.001 0.36 -0.106 to -0.031 1997 -0.226 to 0.008 Bluefish (All data) 0.52 -0.019 +/- 0.014 0.194 0.54 -0.081 to 0.039 1996 -0.178 to 0.153 Hogchoker (All data) 0.58 -0.034 +/- 0.016 0.047 0.43 0.038 to 0.268 1988 -0.150 to -0.053 Blueback Herring (All data) 0.49 -0.055 +/- 0.014 0.001 0.51 -0.154 to 0.002 1992 -0.120 to 0.056 Rainbow Smelt (All data) 0.52 0.036 +/- 0.028 0.220 0.35 0.041 to 0.167 1993 -0.793 to -0.119 Striped Bass (All data) 0.46 0.034 +/- 0.013 0.013 0.44 -0.014 to 0.241 1988 -0.045 to 0.053 Atlantic Tomcod (All data) 0.49 -0.040 +/- 0.014 0.007 0.49 -0.510 to 0.691 1983 -0.085 to -0.012 White Catfish (All data) 0.57 0.014 +/- 0.016 0.37 Did Not Converge White Catfish (3 values removed) 0.10 0.007 +/- 0.003 0.030 0.10 -0.025 to 0.070 1986 -0.006 to 0.013 White Perch (All data) 0.62 -0.014 +/- 0.017 0.413 0.63 -2.43 to 1.27 1981 -0.047 to 0.035 Weakfish 1979-1984 0.88 0.328 +/- 0.211 0.195 Not Fit Weakfish 1985-2005 1.02 0.013 +/- 0.037 0.732 1.07 -11.6 to 10.1 1980 -0.071 to 0.117 3 CI = confidence interval December 2008 I-15 Draft NUREG-1437, Supplement 38

Appendix I 1 Table I-8 River Segment Assessment of the Level of Potential Negative Impact Based on 2 the Standardized FSS Density Using a 3-Year Moving Average Support for Level of Percent Outside Best General Possible Potential Species Defined Level of Noise Fit Trend Negative Negative (percent)

Impact Impact Alewife LR S<0 48 Yes 4 (All data)

Alewife (2 values LR S<0 48 Yes 4 removed)

Bay Anchovy LR S=0 50 1979-1984 Yes 4 Bay Anchovy S1 = 0 SR 43 1985-2005 S2 < 0 American Shad LR S<0 56 Yes 4 Bluefish LR S=0 7 No 1 Hogchoker S1 > 0 SR 15 No 2 (All data) S2 < 0 Blueback Herring LR S<0 11 No 2 Rainbow Smelt S1 > 0 SR 7 No 2 (All data) S2 < 0 S1 = 0 Striped Bass SR 26 No 1 S2 = 0 Atlantic Tomcod LR S<0 15 No 2 White Catfish LR S=0 4 No 1 (All data)

White Catfish (3 values LR S>0 4 No 1 removed)

White Perch LR S=0 19 No 1 Weakfish LR S=0 33 1979-1984 No 1 Weakfish LR S=0 29 1985-2005 3 LR = Linear Regression; SR = Segmented Regression Draft NUREG-1437, Supplement 38 I-16 December 2008

Appendix I 1

Alewife 3 Bay Anchovy 79-84 Outlier Aw FJS 3rd Q Density 2 Bay Anchovy 89-05 FJS 3rd Q Density 0

1 0

-1 -1

-2

-2 -3 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey 1

American Shad FJS 3rd Q Density 0

-1

-2

-3 0 5 10 15 20 25 30 Years of Survey 1 Figure I-6 River Segment 4 population trends based on the FSS standardized density 2 assigned a large level of potential negative impact 3 Table I-9 Competing Models Used To Characterize the Standardized River Segment 4 4 BSS Population Trends of YOY Fish Density Using a 3-Year Moving Average Linear Regression Segmented Regression 95 percent CI Join 95 percent CI Species MSE Slope p-value MSE Slope 1 Point Slope 2 Alewife 0.57 -0.030 +/- 0.016 0.065 0.39 -0.459 to -0.156 1986 -0.010 to 0.063 Bay Anchovy 0.44 0.056 +/- 0.012 0.000 0.39 -0.095 to 0.058 1991 0.055 to 0.161 American Shad 0.35 -0.069 +/- 0.010 < 0.001 0.34 -0.724 to 0.270 1983 -0.083 to -0.036 Bluefish 0.58 -0.038 +/- 0.016 0.027 0.48 -0.146 to -0.047 1996 -0.021 to 0.287 Hogchoker 0.52 -0.059 +/- 0.014 < 0.001 0.40 -0.250 to -0.092 1991 -0.034 to 0.076 Blueback Herring 0.53 -0.024 +/- 0.015 0.120 0.42 -0.005 to 0.100 1994 -0.235 to -0.042 Spottail Shiner 0.43 -0.017 +/- 0.012 0.176 0.35 -0.469 to -0.004 1985 -0.014 to 0.043 Striped Bass 0.42 0.040 +/- 0.012 0.002 0.43 -0.287 to 0.221 1985 0.013 to 0.087 White Perch 0.61 -0.062 +/- 0.017 0.001 0.40 -0.247 to -0.122 1992 -0.007 to 0.133 December 2008 I-17 Draft NUREG-1437, Supplement 38

Appendix I 1 Table I-10 River Segment 4 Assessment of the Level of Potential Negative Impact Based 2 on the Standardized BSS Density Using a 3-Year Moving Average Percent Outside Defined Level of Support for Best General Noise Possible Negative Final Species Fit Trend (percent) Impact Decision S1 < 0 Alewife SR S2 = 0 74 Yes 4 S1 = 0 Bay Anchovy SR S2 > 0 11 No 1 S1 = 0 American Shad SR S2 < 0 63 Yes 4 S1 < 0 Bluefish SR S2 = 0 52 Yes 4 S1 < 0 Hogchoker SR S2 = 0 78 Yes 4 Blueback S1 = 0 Herring SR S2 < 0 11 No 2 S1 < 0 Spottail Shiner SR S2 = 0 74 Yes 4 Striped Bass LR S>0 30 No 1 S1 < 0 White Perch SR S2 = 0 70 Yes 4 3 LR = Linear Regression; SR = Segmented Regression Draft NUREG-1437, Supplement 38 I-18 December 2008

Appendix I 2

Alewife 1

BSS 3rd Q Density American Shad 1

BSS 3rd Q Density 0

0

-1 -1

-2 -2 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey 1 1 Bluefish Hogchoker BSS 3rd Q Density BSS 3rd Q Density 0

0

-1

-1

-2

-3 -2 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey 1 1 Spottail Shiner W hite Perch BSS 3rd Q Density BSS 3rd Q Density 0

0

-1

-1

-2

-2 -3 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey 1 Figure I-7 River Segment 4 population trends based on the BSS standardized density 2 assigned a large level of potential negative impact December 2008 I-19 Draft NUREG-1437, Supplement 38

Appendix I 1 Table I-11 Competing Models Used To Characterize the Standardized River Segment 4 2 LRS Population Trends of YOY Atlantic Tomcod Density Using a 3-Year Moving Average Linear Regression Segmented Regression 95 percent CI Join 95 percent CI Species MSE Slope p-value MSE Slope 1 Point Slope 2 Atlantic Tomcod 0.53 -0.074 +/- 0.015 < 0.001 0.49 -0.187 to -0.067 1982 -0.098 to 0.124 3 Table I-12 River Segment 4 Assessment of the Level of Potential Negative Impact Based 4 on the Standardized LRS Atlantic Tomcod YOY Density Using a 3-Year Moving Average Support for Level of Percent Outside Possible Potential General Defined Level of Noise Negative Negative Species Best Fit Trend (percent) Impact Impact S1 < 0 Atlantic Tomcod SR S2 = 0 33 No 2 5 SR = Segmented Regression 6 A visual comparison of the river-segment FSS standardized CPUE with the BSS standardized 7 density suggested that the trends for alewife, American shad, Atlantic tomcod, bluefish, and 8 striped bass were not biologically different (Figure I-8). Observations from both surveys overlap 9 and cross over each other. The post-1985 FSS CPUE observations for hogchoker and white 10 perch were greater than the BSS observations and did not show a decline associated with the 11 gear change (Figure I-9). Thus, for these RIS, all of the FSS CPUE data (1979-2005) were 12 used in the regression analysis. The FSS density data for bay anchovy, blueback herring, and 13 weakfish, however, did show a potential gear effect (Figure I-10), and a pre- and post-1985 14 analysis was conducted.

Draft NUREG-1437, Supplement 38 I-20 December 2008

Appendix I Standardized Density or CPUE 2

Standardized Density or CPUE FJS gear change FJS gear change 2

1 1

0 0

-1

-1

-2

-2 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey Alewife-D-BSS American Shad-D-BSS Alewife-C-FJS American Shad-C-FJS Standardized Density or CPUE Standardized Density or CPUE FJS gear change FJS gear change 2 2 1

1 0

0

-1

-1

-2

-2 -3 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey Atlantic tomcod R2-D-BSS Bluefish-D-BSS Atlantic Tomcod-C-FJS Bluefish-C-FJS Standardized Density or CPUE FJS gear change 2

1 0

-1

-2 0 5 10 15 20 25 30 Years of Survey Striped Bass-D-BSS Striped Bass-C-FJS 1 Note: All data were used in WOE analysis; R2 = River Segment 2, Yonkers.

2 Figure I-8 River Segment 4 population trends based on the FSS standardized CPUE (C) 3 and BSS density (D) not considered biologically different December 2008 I-21 Draft NUREG-1437, Supplement 38

Appendix I Standardized Density or CPUE FJS gear change 2

1 0

-1

-2

-3 0 5 10 15 20 25 30 Years of Survey Hogchoker-D-BSS Hogchoker-C-FJS FJS gear change Standardized Density or CPUE 3

2 1

0

-1

-2

-3 0 5 10 15 20 25 30 Years of Survey W hite Perch-D-BSS W hite Perch-C-FJS 1 Note: All data were used in WOE analysis.

2 Figure I-9 River Segment 4 population trends based on the FSS standardized CPUE (C) 3 and BSS density (D) for which the FSS density is greater Draft NUREG-1437, Supplement 38 I-22 December 2008

Appendix I Standardized Density or CPUE Standardized Density or CPUE FJS gear change FJS gear change 2 2 1

1 0

0

-1

-1

-2

-3 -2 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey Bay Anchovy-D-BSS Blueback Herring-D-BSS Bay Anchovy-C-FJS Blueback Herring-C-FJS Standardized Density or CPUE 2 FJS gear change 1

0

-1

-2 0 5 10 15 20 25 30 Years of Survey W eakfish R2-D-BSS W eakfish-C-FJS 1 Note: Years were analyzed separately for WOE analysis; R2 = River Segment 2, Yonkers.

2 Figure I-10 River Segment 4 population trends based on the FSS standardized CPUE (C) 3 and BSS density (D) for which the FSS may indicate a gear difference 4 The following tables were the intermediate analyses for the assessment of population trends 5 associated with fish CPUE sampled from River Segment 4 (IP2 and IP3). Results of these river-6 segment trend analyses were compiled in Table H-13 in Section H.3 of the draft SEIS (Entergy 7 2007). The data used in this analysis, in order of appearance, were the standardized 8 75th percentile of the weekly fish CPUE for a given year collected from the FSS (Table I-13, 9 Table I-14, and Figure I-11) and LRS for Atlantic tomcod only (Table I-15and Table I-16).

December 2008 I-23 Draft NUREG-1437, Supplement 38

Appendix I 1 Table I-13 Competing Models Used To Characterize the Standardized River Segment 4, 2 FSS Population Trends of YOY Fish CPUE Linear Regression Segmented Regression Species 95 percent CI Join 95 percent CI MSE Slope p-value MSE Slope 1 Point Slope 2 Alewife 0.92 -0.055 +/- 0.023 0.022 0.79 -0.839 to -0.058 1984 -0.058 to 0.060 Bay Anchovy 0.80 -0.373 +/- 0.191 0.123 Not Fit 1979-1984 Bay Anchovy 1.00 0.034 +/- 0.036 0.360 0.96 -0.022 to 0.248 1999 -0.596 to 0.172 1985-2005 American 0.76 -0.085 +/- 0.019 < 0.001 0.57 -0.717 to -0.159 1985 -0.067 to 0.018 Shad Bluefish 0.84 -0.072 +/- 0.021 0.002 0.82 -0.374 to -0.002 1988 -0.106 to 0.061 Hogchoker 1.00 -0.025 +/- 0.025 0.332 0.92 -0.101 to 0.368 1988 -0.184 to 0.000 (All data)

Hogchoker (2 outliers 0.47 -0.021 +/- 0.012 0.087 0.44 -0.049 to 0.211 1987 -0.097 to -0.008 removed)

Blueback Herring 1.11 -0.059 +/- 0.266 0.835 Not Fit 1979-1984 Blueback Herring 0.38 -0.022 +/- 0.015 0.152 Did Not Converge 1985-2005 Rainbow Smelt 0.89 -0.062 +/- 0.022 0.009 0.45 -4.95 to -2.33 1980 -0.049 to 0.002 (All data)

Striped 1.01 -0.013 +/- 0.025 0.599 1.00 -0.089 to 0.178 1993 -0.259 to 0.076 Bass Atlantic Tomcod 0.95 -0.046 +/- 0.024 0.063 0.99 -6.78 to 6.63 1980 -0.102 to 0.012 (All data)

Atlantic Tomcod 0.66 -0.028 +/- 0.017 0.106 Did Not Converge (1 outlier removed)

White Perch 0.95 -0.047 +/- 0.023 0.055 0.87 -3.97 to 1.12 1981 -0.071 to 0.029 (All data)

White Perch (1 outlier 0.72 -0.047 +/- 0.024 0.038 0.51 -2.02 to -0.538 1981 -0.037 to 0.026 removed)

Weakfish 0.83 0.357 +/- 0.199 0.148 Not Fit 1979-1984 Weakfish

-4.66 e+007 to 1985-2005 1.00 0.035 +/- 0.036 0.349 1.03 1986 -0.036 to 0.133 4.66e+007 (All data)

Weakfish 1985-2005 0.62 -0.003 +/- 0.025 0.892 Did Not Converge (3 values removed) 3 Two extreme outliers (both values greater than 3 standard deviations from the mean) were 4 removed from the FSS hogchoker CPUE regression analysis because of their influence on the 5 regression (Tables I-13 and I-14). One extreme outlier (value greater than 3 standard 6 deviations from the mean) was removed from the FSS Atlantic tomcod CPUE regression 7 analysis, and one extreme outlier (value greater than 2 standard deviations from the mean) was Draft NUREG-1437, Supplement 38 I-24 December 2008

Appendix I 1 removed from the FSS white perch CPUE regression analysis. These extreme outliers had a 2 great influence on the regression results. One value (not an extreme outlier) and two extreme 3 outliers (both greater than 2 standard deviations from the mean) were removed from the FSS 4 weakfish CPUE regression analysis because of the influence these data had on the regression 5 results. The results of the regression models with the observations removed were more 6 conservative and were used for the trend analysis.

7 Table I-14 River Segment 4 Assessment of the Level of Potential Negative Impact 8 Based on the Standardized FSS CPUE Percent Level of Gener Outside Support for Best Potential Species al Defined Level Possible Negative Fit Negative Trend of Noise Impact Impact (percent)

S1 < 0 Alewife SR 89 Yes 4 S2 = 0 Bay Anchovy LR S=0 33 1979-1984 No 1 Bay Anchovy S1 = 0 SR 33 1985-2005 S2 = 0 S1 < 0 American Shad SR 74 Yes 4 S2 = 0 S1 < 0 Bluefish SR 78 Yes 4 S2 = 0 S1 = 0 Hogchoker (All data) SR 15 No 1 S2 = 0 Hogchoker S1 = 0 SR 15 No 2 (2 outliers removed) S2 < 0 Blueback Herring LR S=0 17 1979-1984 Yes 2 Blueback Herring LR S=0 71 1985-2005 Rainbow Smelt (All S1 < 0 SR 78 Yes 4 data) S2 = 0 S1 = 0 Striped Bass SR 26 No 1 S2 = 0 Atlantic Tomcod LR S=0 7 No 1 (All data)

Atlantic Tomcod LR S=0 7 No 1 (1 outlier removed)

S1 = 0 White Perch (All data) SR 56 Yes 2 S2 = 0 White Perch S1 < 0 SR 56 Yes 4 (1 outlier removed) S2 = 0 Weakfish 1979-1984 LR S=0 33 Weakfish 1985-2005 LR S=0 24 No 1 (All data)

Weakfish 1985-2005 LR S=0 24 (3 values removed) 9 LR = Linear Regression; SR = Segmented Regression December 2008 I-25 Draft NUREG-1437, Supplement 38

Appendix I 3 2 Alewife American Shad 2

1 FJS 3rd Q CPUE FJS 3rd Q CPUE 1

0 0

-1

-1

-2 -2

-3 -3 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey 3 5 Bluefish Rainbow Smelt 2 4 FJS 3rd Q CPUE FJS 3rd Q CPUE 1 3 2

0 1

-1 0

-2

-1

-3 -2 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey 3

W hite Perch 2 Outlier W P FJS 3rd Q CPUE 1

0

-1

-2 0 5 10 15 20 25 30 Years of Survey 1 Figure I-11 River Segment 4 population trends based on the FSS standardized CPUE 2 assigned a large level of potential negative impact 3 Table I-15 Competing Models Used To Characterize the Standardized River Segment 4 4 LRS Population Trends of YOY Atlantic Tomcod CPUE Using a 3-Year Moving Average Linear Regression Segmented Regression 95 percent CI 95 percent CI Join Species MSE Slope p-value MSE Slope 1 Point Slope 2 Atlantic Tomcod 0.57 -0.069 +/- 0.022 0.006 0.28 -0.873 to -0.338 1989 -0.031 to 0.034 Draft NUREG-1437, Supplement 38 I-26 December 2008

Appendix I 1 Table I-16 River Segment 4 Assessment of the Level of Potential Negative Impact Based 2 on the Standardized LRS Atlantic Tomcod YOY CPUE Using a 3-Year Moving Average Support for Percent Outside Level of Possible Potential General Defined Level of Noise Negative Negative Species Best Fit Trend (percent) Impact Impact S1 < 0 Atlantic Tomcod SR S2 = 0 22 No 2 3 SR = Segmented Regression 4 The results of the two measurement metricsdensity (estimated number of RIS per given 5 volume of water provided by the applicant) and CPUE (number of RIS captured by the sampler 6 for a given volume of water derived by the NRC staff) were combined for the assessment of 7 population impacts potentially associated with the IP2 and IP3 cooling systems. Table I-17 8 presents the numeric results compiled from Tables I-8, I-10, I-12, I-14, and I-16 above and used 9 to derive Table H-13 in Section H.3 in the draft SEIS.

10 Table I-17 Assessment of Population Impacts for IP2 and IP3 River Segment 4 Density CPUE River-Species Segment FSS BSS LRS FSS LRS Assessment a

Alewife 4 4 N/A 4 N/A 4.0 Bay Anchovy 4 1 N/A 1 N/A 2.0 American Shad 4 4 N/A 4 N/A 4.0 Bluefish 1 4 N/A 4 N/A 3.0 Hogchoker 2 4 N/A 2 N/A 2.7 Atlantic N/A N/A N/A N/A N/A Menhaden Unknown Blueback Herring 2 2 N/A 2 N/A 2.0 Rainbow Smelt 2 N/A N/A 4 N/A 3.0 Shortnose N/A N/A N/A N/A N/A Sturgeon Unknown Spottail Shiner N/A 4 N/A N/A N/A 4.0 Atlantic Sturgeon N/A N/A N/A N/A N/A Unknown Striped Bass 1 1 N/A 1 N/A 1.0 Atlantic Tomcod 2 N/A 2 1 2 1.8 White Catfish 1 N/A N/A N/A N/A 1.0 White Perch 1 4 N/A 4 N/A 3.0 Weakfish 1 N/A N/A 1 N/A 1.0 Gizzard Shad N/A N/A N/A N/A N/A Unknown Blue Crab N/A N/A N/A N/A N/A Unknown 11 (a) N/A: not applicable; YOY not present in samples December 2008 I-27 Draft NUREG-1437, Supplement 38

Appendix I 1 Lower Hudson River 2 A visual comparison of the riverwide FSS standardized CPUE with the BSS standardized CPUE 3 suggested that the trends were not biologically different for blueback herring, striped bass, white 4 perch, and hogchoker (Figure I-12). Observations from both surveys overlap and cross over 5 each other. The post-1985 FSS observations for Atlantic tomcod were greater than the BSS 6 observations and did not show a decline associated with the gear change (Figure I-13). For 7 these RIS, all of the FSS data (1979-2005) were used in the regression analysis. The FSS 8 density data for alewife, American shad, bay anchovy, and bluefish, however, did show a 9 potential gear effect (Figure I-14), and a pre- and post-1985 analysis was conducted.

FJS gear change FJS gear change 3 5 2 4 Standardized CPUE Standardized CPUE 3

1 2

0 1

-1 0

-2

-1

-3 -2 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey Blueback Herring-BSS Striped Bass-BSS Blueback Herring-FJS Striped Bass-FJS FJS gear change FJS gear change 2 4 1

Standardized CPUE 3

Standardized CPUE 0 2

-1 1

-2 0

-3 -1

-4 -2 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey W hite Perch-BSS Hogchoker-BSS W hite Perch-FJS Hogchoker-FJS 10 Note: All data were used in WOE analysis.

11 Figure I-12 Riverwide population trends based on the FSS and BSS standardized CPUE 12 not considered biologically different Draft NUREG-1437, Supplement 38 I-28 December 2008

Appendix I FJS gear change 5

4 Standardized CPUE 3

2 1

0

-1

-2 0 5 10 15 20 25 30 Years of Survey Atlantic Tomcod-BSS Atlantic Tomcod-FJS 1 Note: All data were used in WOE analysis.

2 Figure I-13 Riverwide population trends based on the FSS and BSS standardized CPUE 3 for which the FSS density is greater December 2008 I-29 Draft NUREG-1437, Supplement 38

Appendix I FJS gear change 3 FJS gear change 3

2 Standardized CPUE 2

Standardized CPUE 1

1 0

0

-1

-1

-2

-2

-3

-3 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey Alewife-BSS American Shad-BSS Alewife-FJS American Shad-FJS FJS gear change 2

FJS gear change 5

Standardized CPUE 1 4 Standardized CPUE 3

0 2

-1 1 0

-2 -1

-2

-3

-3 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey Bay Anchovy-BSS Bluefish-BSS Bay Anchovy-FJS Bluefish-FJS 1 Note: Years were analyzed separately for WOE analysis.

2 Figure I-14 Riverwide population trends based on the FSS and BSS standardized CPUE 3 for which the FSS may indicate a gear difference 4 The following tables are the intermediate analyses for the riverwide assessment of population 5 trends associated with annual fish CPUE and the abundance index. Results of these riverwide 6 trend analyses are compiled in Table H-14 in Section H.3 of the draft SEIS. The data used in 7 this analysis, in order of appearance, were the standardized annual fish CPUE for a given year 8 collected from the FSS (Table I-18, Table I-19, and Figure I-15), BSS (Table I-20, Table I-21, 9 and Figure I-16), LRS for Atlantic tomcod only (Table I-22 and Table I-23), and the annual fish 10 abundance index (Table I-24, Table I-25, and Figure H-17).

11 One extreme outlier (value greater than 4 standard deviations away from the mean) was 12 removed from the abundance index for the bluefish regression analysis (Tables I-24 and I-25).

Draft NUREG-1437, Supplement 38 I-30 December 2008

Appendix I 1 One extreme outlier was also removed from the abundance index for both the rainbow smelt 2 (value greater than 5 standard deviations away from the mean) regression analysis and the 3 white catfish (value greater than 2 standard deviations away from the mean) regression 4 analysis, because of the influence these data had on the regression results. The results of the 5 regression models with the observations removed were more conservative and were used for 6 the trend analysis.

7 Table I-18 Competing Models Used To Characterize the Standardized Riverwide FSS 8 Population Trends of YOY Fish CPUE Linear Regression Segmented Regression Species 95 percent CI Join 95 percent CI MSE Slope p-value MSE Slope 1 Point Slope 2 Alewife 0.833 -0.357 +/- 0.199 0.148 Not Fit 1979-1984 Alewife -1.90e+007 to 0.628 0.025 +/- 0.023 0.286 0.633 1986 -0.015 to 0.090 1985-2005 1.90e+007 Bay Anchovy 1.08 0.135 +/- 0.259 0.629 Not Fit 1979-1984 Bay Anchovy 0.764 -0.002 +/- 0.028 0.949 0.749 -0.082 to 0.328 1993 -0.216 to 0.073 1985-2005 American Shad 0.983 -0.254 +/- 0.235 0.340 Not Fit 1979-1984 American Shad 0.873 -0.085 +/- 0.031 0.015 0.831 -0.362 to 0.746 1989 -0.222 to -0.031 1985-2005 Bluefish 0.918 0.305 +/- 0.219 0.236 Not Fit 1979-1984 Bluefish 0.915 -0.073 +/- 0.033 0.039 0.899 -0.778 to 1.90 1987 -0.193 to -0.021 1985-2005 Hogchoker 0.916 -0.055 +/- 0.023 0.022 0.645 0.114 to 0.526 1986 -0.198 to -0.086 Blueback 0.704 -0.091 +/- 0.017 < 0.001 0.563 -0.454 to -0.153 1987 -0.079 to 0.027 Herring Spottail Shiner 0.875 -0.035 +/- 0.022 0.125 0.859 -0.295 to 0.675 1984 -0.132 to 0.003 (All data)

Striped 1.019 -0.003 +/- 0.025 0.902 0.931 -0.085 to 0.389 1988 -0.162 to 0.025 Bass Atlantic 0.607 -0.028 +/- 0.015 0.083 0.595 -0.089 to 0.183 1989 -0.124 to -0.002 Tomcod White Perch 0.647 -0.097 +/- 0.016 < 0.001 Did Not Converge December 2008 I-31 Draft NUREG-1437, Supplement 38

Appendix I 1 Table I-19 Riverwide Assessment of the Level of Potential Negative Impact Based on the 2 Standardized FSS CPUE Percent Outside Support for Best General Final Species Defined Level of Noise Possible Negative Fit Trend Decision (percent) Impact Alewife LR S=0 50 1979-1984 Yes 2 Alewife LR S=0 14 1985-2005 Bay Anchovy LR S=0 33 1979-1984 No 1 Bay Anchovy S1 = 0 SR S2 = 0 24 1985-2005 American Shad LR S=0 50 1979-1984 Yes 4 American Shad S1 = 0 SR S2 < 0 52 1985-2005 Bluefish LR S=0 33 1979-1984 Yes 4 Bluefish S1 = 0 SR S2 < 0 48 1985-2005 S1 > 0 Hogchoker SR S2 < 0 22 No 2 Blueback S1 < 0 SR S2 = 0 81 Yes 4 Herring S1 = 0 Spottail Shiner SR S2 = 0 26 No 1 S1 = 0 Striped Bass SR S2 = 0 30 No 1 S1 = 0 Atlantic Tomcod SR S2 < 0 7 No 2 White Perch LR S<0 56 Yes 4 3 LR = Linear Regression; SR = Segmented Regression Draft NUREG-1437, Supplement 38 I-32 December 2008

Appendix I 3 3 American Shad 79-84 Bluefish 79-84 Standardized FJS CPUE Standardized FJS CPUE 2 2 American Shad 85-05 Bluefish 85-05 1

1 0

0

-1

-1

-2

-3 -2

-4 -3 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey 2

Blueback Herring Standardized FJS CPUE 2

1 W hite Perch Standardized FJS CPUE 0 1

-1 0

-2

-1

-3

-2

-4 0 5 10 15 20 25 30 -3 Years of Sampling 0 5 10 15 20 25 30 Years of Sampling 1

2 Figure I-15 Riverwide population trend based on the FSS standardized CPUE assigned a 3 large level of potential negative impact December 2008 I-33 Draft NUREG-1437, Supplement 38

Appendix I 1 Table I-20 Competing Models Used To Characterize the Standardized Riverwide BSS 2 Population Trends of YOY Fish CPUE Linear Regression Segmented Regression 95 percent CI Join 95 percent CI Species MSE Slope p-value MSE Slope 1 Point Slope 2 Alewife 0.996 0.027 +/- 0.025 0.281 0.944 -0.417 to 0.087 1987 -0.001 to 0.177 Bay Anchovy 0.971 -0.038 +/- 0.024 0.123 0.927 -0.631 to 0.094 1986 -0.063 to 0.085 American Shad 0.991 -0.030 +/- 0.025 0.235 0.981 -0.103 to 0.198 1992 -0.240 to 0.029 Bluefish 0.478 -0.019 +/- 0.012 0.121 0.439 -0.103 to -0.013 1995 -0.038 to 0.165 Hogchoker 0.969 -0.039 +/- 0.024 0.113 0.913 -0.212 to 0.983 1983 -0.141 to -0.014 Blueback Herring 0.937 -0.050 +/- 0.023 0.042 0.940 -0.429 to 0.091 1987 -0.101 to 0.075 Spottail Shiner 0.965 0.041 +/- 0.024 0.101 0.928 -0.448 to 0.145 1987 0.012 to 0.172 Striped Bass 0.908 0.057 +/- 0.022 0.017 0.941 -0.347 to 0.373 1986 -0.010 to 0.147 Atlantic Tomcod 0.802 -0.078 +/- 0.020 0.001 0.787 -0.232 to -0.038 1993 -0.135 to 0.137 White Perch 0.859 -0.068 +/- 0.021 0.004 0.737 -0.208 to -0.070 1997 -0.036 to 0.358 Rainbow Smelt 0.875 -0.065 +/- 0.022 0.006 0.327 -1.54 to -0.939 1982 -0.022 to 0.021 White Catfish 0.642 -0.098 +/- 0.016 < 0.001 0.668 -2.02 to 1.89 1980 -0.138 to -0.061 Weakfish 1.01 -0.021 +/- 0.025 0.407 0.996 -0.514 to 1.33 1982 -0.111 to 0.018 Draft NUREG-1437, Supplement 38 I-34 December 2008

Appendix I 1 Table I-21 Riverwide Assessment of the Level of Potential Negative Impact 2 Based on the BSS CPUE Percent Outside Support for Best General Defined Level of Noise Possible Negative Final Species Fit Trend (percent) Impact Decision S1 = 0 Alewife SR S2 = 0 41 Yes 2 S1 = 0 Bay Anchovy SR S2 = 0 56 Yes 2 S1 = 0 American Shad SR S2 = 0 37 No 1 S1 < 0 Bluefish SR S2 = 0 11 No 2 S1 = 0 Hogchoker SR S2 < 0 19 No 2 Blueback Herring LR S<0 93 Yes 4 S1 = 0 Spottail Shiner SR S2 > 0 26 No 1 Striped Bass LR S>0 33 No 1 S1 < 0 Atlantic Tomcod SR S2 = 0 74 Yes 4 S1 < 0 White Perch SR S2 = 0 81 Yes 4 S1 < 0 Rainbow Smelt SR S2 = 0 96 Yes 4 White Catfish LR S<0 67 Yes 4 S1 = 0 Weakfish SR S2 = 0 11 No 1 3 LR = Linear Regression; SR = Segmented Regression December 2008 I-35 Draft NUREG-1437, Supplement 38

Appendix I 3 3 Atlantic Tomcod Standardized BSS CPUE Blueback Herring Standardized BSS CPUE 2 2 1 1 0 0

-1 -1

-2 -2

-3 -3 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Sampling Years of Sampling 2 4 W hite Perch Standardized BSS CPUE Rainbow Smelt Standardized BSS CPUE 1 3 0 2 1

-1 0

-2

-1

-3 -2

-4 -3 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Sampling Years of Sampling 2

W hite Catfish Standardized BSS CPUE 1

0

-1

-2

-3

-4 0 5 10 15 20 25 30 Years of Sampling 1 Figure I-16 Riverwide population trends based on the BSS standardized CPUE assigned 2 a large level of potential negative impact 3 Table I-22 Competing Models Used To Characterize the Standardized Riverwide LRS 4 Population Trend of YOY Atlantic Tomcod CPUE Linear Regression Segmented Regression 95 percent CI Join 95 percent CI Species MSE Slope p-value MSE Slope 1 Point Slope 2 Atlantic Tomcod 1.02 -0.006 +/- 0.025 0.826 0.96 -2.38 to 0.439 1980 -0.037 to 0.081 Draft NUREG-1437, Supplement 38 I-36 December 2008

Appendix I 1 Table I-23 Riverwide Assessment of the Level of Potential Negative Impact Based on the 2 Standardized LRS CPUE of Atlantic Tomcod Support for Best General Percent Outside Possible Negative Final Species Fit Trend Defined Level of Noise Impact Decision Atlantic S1 = 0 Tomcod SR S2 = 0 44 Yes 2 3 SR = Segmented Regression 4 Table I-24 Competing Models Used To Characterize the Standardized Riverwide YOY 5 Abundance Index Trends Linear Regression Segmented Regression 95 percent CI Join 95 percent CI Species MSE Slope p-value MSE Slope 1 Point Slope 2 Alewife 1.00 -0.024 +/- 0.025 0.334 1.03 -0.200 to 0.075 1993 -0.149 to 0.195 Bay Anchovy 0.952 -0.045 +/- 0.024 0.067 0.890 -0.137 to 0.317 1988 -0.192 to -0.014 American Shad 0.924 -0.053 +/- 0.023 0.028 0.934 -0.163 to 0.221 1989 -0.199 to 0.010 Bluefish (All data) 1.00 0.023 +/- 0.025 0.355 1.03 -0.274 to 0.195 1989 -0.053 to 0.158 Bluefish (1 outlier removed) 0.378 0.003 +/- 0.009 0.775 0.359 -0.074 to 0.015 1994 -0.014 to 0.111 Hogchoker 0.992 -0.029 +/- 0.025 0.244 0.964 -0.143 to 0.349 1988 -0.179 to 0.015 Blueback Herring 0.978 -0.036 +/- 0.024 0.152 0.896 -0.077 to 0.380 1988 -0.200 to -0.020 Rainbow Smelt (All data) 1.02 -0.008 +/- 0.025 0.759 Did Not Converge Rainbow Smelt (1 outlier removed) 0.269 -0.008 +/- 0.007 0.253 0.265 -0.038 to 0.104 1987 -0.047 to 0.004 Spottail Shiner 0.972 0.038 +/- 0.024 0.125 0.960 -0.164 to 0.100 1993 -0.025 to 0.270 Striped Bass 0.952 0.045 +/- 0.024 0.067 0.970 -0.081 to 0.114 1996 -0.126 to 0.369 Atlantic Tomcod 0.969 -0.039 +/- 0.024 0.112 0.852 -0.051 to 0.323 1989 -0.223 to -0.036 White Catfish (All data) 0.854 -0.069 +/- 0.021 0.003 Did Not Converge White Catfish (1 outlier removed) 0.495 -0.062 +/- 0.012 < 0.001 Did Not Converge White Perch 0.964 -0.041 +/- 0.024 0.096 0.795 -0.286 to -0.068 1993 -0.007 to 0.237 Weakfish 0.900 -0.059 +/- 0.022 0.013 0.854 -0.329 to 0.689 1984 -0.153 to -0.028 December 2008 I-37 Draft NUREG-1437, Supplement 38

Appendix I 1 Table I-25 Riverwide Assessment of the Level of Potential Negative Impact 2 Based on the Abundance Index Percent Outside Support for General Best Defined Level of Noise Possible Negative Final Trend Species Fit (percent) Impact Decision Alewife LR S=0 33 No 1 S1 = 0 Bay Anchovy SR S2 < 0 30 No 2 American Shad LR S<0 52 Yes 4 Bluefish (All data) LR S=0 7 No 1 Bluefish S1 = 0 (1 outlier removed) SR S2 = 0 7 No 1 S1 = 0 Hogchoker SR S2 = 0 15 No 1 S1 = 0 Blueback Herring SR S2 < 0 19 No 2 Rainbow Smelt (All data) LR S=0 4 No 1 Rainbow Smelt S1 = 0 (1 outlier removed) SR S2 = 0 4 No 1 S1 = 0 Spottail Shiner SR S2 = 0 26 No 1 Striped Bass LR S=0 30 No 1 S1 = 0 Atlantic Tomcod SR S2 < 0 19 No 2 White Catfish (All data) LR S<0 63 Yes 4 White Catfish (1 outlier removed) LR S<0 63 Yes 4 S1 < 0 White Perch SR S2 = 0 70 Yes 4 S1 = 0 Weakfish SR S2 < 0 15 No 2 3 LR = Linear Regression; SR = Segmented Regression Draft NUREG-1437, Supplement 38 I-38 December 2008

Appendix I 2 3 American Shad W hite Catfish 2 Outlier-W C Standardized 1

Standardized 1

0 0

Abundance Index Abundance Index

-1

-1

-2 -2

-3 -3 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Sampling Years of Sampling 2

W hite Perch 1

Standardized 0

-1 Abundance Index

-2

-3

-4 0 5 10 15 20 25 30 Years of Sampling 1 Figure I-17 Riverwide population trends based on the abundance index assigned a large 2 level of potential negative impact 3 The results of the two measurement metricsCPUE (number of RIS captured by the sampler 4 for a given volume of water derived by the NRC staff) and the abundance index provided by the 5 applicantwere combined for the assessment of riverwide population impacts. Table I-26 6 presents the numeric results compiled from Tables I-19, I-21, I-23, and I-25 above and used to 7 derive Table H-14 in Section H.3 in the draft SEIS.

December 2008 I-39 Draft NUREG-1437, Supplement 38

Appendix I 1 Table I-26 Assessment of Riverwide Population Impacts CPUE Abundance Riverwide Species FSS BSS LRS Index Assessment Alewife 2 2 N/Aa 1 1.7 Bay Anchovy 1 2 N/A 2 1.7 American Shad 4 1 N/A 4 3.0 Bluefish 4 2 N/A 1 2.3 Hogchoker 2 2 N/A 1 1.7 Atlantic N/A Menhaden N/A N/A N/A Unknown Blueback Herring 4 4 N/A 2 3.3 Rainbow Smelt N/A 4 N/A 1 2.5 Shortnose N/A Sturgeon N/A N/A N/A Unknown Spottail Shiner 1 1 N/A 1 1.0 Atlantic Sturgeon N/A N/A N/A N/A Unknown Striped Bass 1 1 N/A 1 1.0 Atlantic Tomcod 2 4 2 2 2.5 White Catfish N/A 4 N/A 4 4.0 White Perch 4 4 N/A 4 4.0 Weakfish N/A 1 N/A 2 1.5 Gizzard Shad N/A N/A N/A N/A Unknown Blue Crab N/A N/A N/A N/A Unknown 2 I.2.2. Analysis of Strength of Connection 3 To determine whether the operation of the IP2 and IP3 cooling systems has the potential to 4 influence RIS populations near the facilities or within the lower Hudson River, the NRC staff 5 conducted a strength-of-connection analysis. Measurements used for this analysis include 6 monitoring data at IP2 and IP3 from 1975-1990 that provide information on impingement and 7 entrainment rates for RIS and prey of RIS, as well as River Segment 4 (IP2 and IP3) population-8 density data from the FSS and BSS.

9 The analysis of effects of impingement was based on the concordance of ranked proportions of 10 the number of YOY and yearling fish of each species impinged in relation to the sum of all fish 11 impinged and the ranked proportions of each species abundance in the river near IP2 and IP3 12 relative to the total abundance of the18 RIS. Likewise, the effects of entrainment were based 13 on the concordance of ranked proportions of the estimated number entrained for all life stages 14 for a given species in relation to the abundance of all fish entrained and the ranked proportion of 15 each species abundance in the river near IP2 and IP3 relative to the total abundance of the RIS.

16 An estimate of the population abundance (Si) for a given species in the vicinity of IP2 and IP3 17 was estimated as the maximum over all years (1979-1990) of the annual 75th percentile of 18 weekly density measures from all habitats. Thus, Si for each species was the maximum annual 19 sum of the FSS and BSS 75th percentile of weekly densities from the river segment near IP2 Draft NUREG-1437, Supplement 38 I-40 December 2008

Appendix I 1 and IP3 (Table I-27). The estimate of the total RIS community abundance (SRIS) caught in the 2 vicinity of IP2 and IP3 was the sum of the maximum densities of each species.

3 The density of each species impinged (Impi) was estimated by the 75th percentile of the annual 4 (1975-1990) density impinged at IP2. IP2 typically had 2.8 times more fish impinged than IP3.

5 The annual density impinged was the sum of the seasonal (January-March, April-June, July-6 September, October-December) densities calculated as the estimated number impinged 7 divided by the number of samples taken (Table I-28). The estimate of the total density of RIS 8 impinged (ImpRIS) was the 75th percentile of the annual sum of all RIS densities impinged at IP2.

9 The estimate of Impi was the ratio of the density of an individual species impinged to the Imp RIS 10 total RIS density.

11 The density of each species entrained for a given season and year (1981-1987) was calculated 12 as the mean number entrained divided by the number of samples taken (Table I-29). Density 13 estimates were based on the combined entrainment from IP2 and IP3. The estimate of E i E RIS 14 was the maximum over years of the ratio of the density of an individual species entrained to the 15 total RIS density.

16 Because of the error and bias in estimation of each of these parameters, only the ranks of each 17 ratio were considered a reliable measure of connection. Thus, to estimate the overall strengths 18 of connection between the IP2 and IP3 cooling systems and the RIS in the Hudson River near 19 the facilities, the estimates of Impi , Ei , and Si for each species were ranked from Imp RIS E RIS S RIS 20 1 (low proportion) to 18 (high proportion), and then the ratio of the ranks were compared as a 21 measure of the strength of connection for impingement (Table I-30) and entrainment 22 (Table I-31).

23 Potential food web impacts on RIS associated with the loss of prey caused by impingement or 24 entrainment, based on the relationship presented in the conceptual model (Section 4.1.3 in the 25 main text), were also considered. Indirect impacts on predator fish (bluefish, spottail shiner, 26 striped bass, white perch, and weakfish) were based on the largest observed strength of 27 connection associated with their prey. Thus, for YOY bluefish, which preys on juvenile bay 28 anchovy and Atlantic tomcod, a loss of prey associated with impingement was estimated as 29 1.33 (the maximum of 0.88 for anchovy and 1.33 for tomcod) (Table I-31). The remaining YOY 30 predator-prey relationships were YOY spottail shiner prey on YOY striped bass; YOY striped 31 bass prey on YOY bay anchovy, hogchoker, Atlantic tomcod, and weakfish; YOY white perch 32 prey on YOY bay anchovy; and YOY weakfish prey on YOY bay anchovy. All remaining YOY 33 RIS eat plankton, zooplankton, benthic invertebrates, and amphipods. These prey were 34 assumed to be unaffected by the cooling systems, and a low strength of connection was 35 concluded. The results of this analysis are presented in Table H-16 in Section H.3 of the draft 36 SEIS and in Table I-32.

December 2008 I-41 Draft NUREG-1437, Supplement 38

Appendix I 1 Table I-27 Sum of the FSS and BSS 75th Percentiles of the Weekly Density Caught at 2 River Segment 4 Maximum Year 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990

= Si Alewife 1.01 0.55 6.94 2.86 2.36 0.21 1.31 1.28 0.36 0.93 1.42 0.87 6.94 Bay 96.33 198.05 342.15 391.41 82.03 194.88 106.25 77.11 73.54 153.21 303.60 48.77 391.41 Anchovy American 5.49 4.90 19.04 8.42 7.77 7.00 6.59 13.68 5.33 4.62 23.27 5.33 23.27 Shad Bluefish 0.52 1.23 1.03 1.06 1.66 1.30 1.41 0.52 0.63 0.20 0.30 1.64 1.66 Hogchoker 0.56 1.31 1.69 1.20 0.16 0.53 0.83 1.94 3.09 4.27 0.44 1.14 4.27 Atlantic 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Menhaden Blueback 10.39 3.31 38.43 3.56 8.94 24.15 24.46 5.25 17.82 29.09 8.52 10.71 38.43 Herring Rainbow 3.12 0.63 0.00 0.12 0.00 0.65 0.00 0.97 0.58 0.39 0.00 1.36 3.12 Smelt Shortnose 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Sturgeon Spottail 3.20 0.20 0.60 5.80 1.19 0.25 0.20 0.75 0.20 0.73 1.80 3.10 5.80 Shiner Atlantic 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Sturgeon Stripped 4.28 4.60 15.24 15.15 12.47 12.17 3.09 6.83 13.42 12.64 9.15 12.58 15.24 Bass Atlantic 2.34 1.12 4.09 3.85 0.67 11.94 1.65 5.68 2.20 2.76 2.04 1.60 11.94 Tomcod White 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.03 0.00 0.00 0.00 0.03 Catfish White 16.51 14.90 18.74 15.69 7.36 8.19 10.82 22.56 13.16 10.83 2.94 4.38 22.56 Perch Weakfish 0.90 1.72 2.21 9.21 1.36 11.11 1.76 0.76 0.45 3.17 1.42 1.00 11.11 Gizzard 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Shad Draft NUREG-1437, Supplement 38 I-42 December 2008

Table I-28 Annual Density of RIS Impinged at IP2 Year 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 Alewife 97.1 23.4 231.5 305.9 40.6 79.2 2300.1 269.4 750.0 148.3 181.1 224.8 441.7 169.7 92.5 221.6 Bay 2394.4 304.6 1838.3 2871.8 2308.8 2677.7 47136.1 11429.7 11474.6 242.9 441.8 9285.6 2740.3 2343.0 166.1 1363.5 December 2008 Anchovy American 26.2 38.5 52.4 421.7 129.2 331.7 8859.3 191.9 909.3 15.1 36.9 629.5 440.2 122.7 202.8 165.5 Shad Bluefish 37.1 0.8 185.5 32.5 3.0 85.6 399.2 638.2 2599.2 7.9 47.3 762.0 1883.8 501.8 114.4 1031.6 Hogchoker 441.7 149.2 216.0 564.3 469.7 372.4 513.3 6088.4 2200.4 345.2 388.1 4253.9 3835.6 6687.7 4051.7 3071.9 Atlantic 1.2 1.6 3.4 4.0 0.6 2.0 244.4 34.2 77.5 4.4 37.3 769.7 352.4 144.0 144.4 166.3 Menhaden Blueback 2902.9 4213.6 4930.9 5214.0 2157.9 290.2 5193.5 191.3 4361.3 176.9 157.8 395.3 3129.3 689.2 505.1 2424.5 Herring Rainbow 111.9 59.8 290.7 519.7 390.2 180.4 25.2 274.0 413.3 48.9 82.5 1189.4 832.4 1868.3 50.2 140.7 Smelt Shortnose 0.0 0.0 0.1 0.0 0.0 0.0 0.0 0.0 0.0 17.6 0.0 0.0 5.0 0.0 0.0 0.0 Sturgeon Spottail 45.4 93.4 67.4 31.2 79.4 45.4 35.6 30.2 93.9 60.3 33.7 23.7 128.4 89.6 218.4 290.6 Shiner Atlantic 2.2 0.2 1.2 0.4 1.0 0.2 3.5 21.7 2.5 9.4 5.3 44.0 0.0 0.0 0.0 0.0 I-43 Sturgeon Stripped 111.3 110.7 268.3 469.5 828.5 252.5 1439.9 341.7 1048.5 304.3 457.2 827.8 2116.3 3226.0 1021.1 1766.7 Bass Atlantic 1808.4 657.1 11399.8 4920.4 1294.0 5458.4 7694.2 14207.7 13612.1 294.6 1723.5 13925.4 162126.7 1414.7 400.4 14222.0 Tomcod White 175.9 202.1 148.4 41.0 39.0 14.7 36.1 101.1 139.1 118.2 73.0 159.7 171.8 580.7 255.8 488.7 Catfish White 54654.3 4598.9 6594.8 14043.3 6720.4 25784.8 10473.8 25537.3 25264.5 12479.6 13704.1 6513.9 13729.8 31258.0 33257.3 19242.0 Perch Weakfish 225.6 16.5 135.5 369.4 194.0 352.8 2325.6 3487.6 19315.7 47.9 175.4 769.6 290.9 2388.5 997.6 297.9 Gizzard 15.0 30.5 33.1 11.1 12.7 1.2 19.1 25.7 86.8 126.0 34.2 131.9 71.6 206.2 355.9 427.5 Shad RIS Total 12995 12497 33846 22497 33734 20618 101762 62597 69564 15672 10389 47122 209824 53689 27818 80733 Draft NUREG-1437, Supplement 38 Appendix I

Table I-29 Annual Density of RIS Entrained at IP2 and IP3 Combined Appendix I Year 1981 1981 1983 1983 1984 1984 1985 1985 1986 1986 1986 1987 1987 Season Apr-June July-Sep Apr-June July-Sep Apr-June July-Sep Apr-June July-Sep Jan-Mar Apr-June July-Sep Apr-June July-Sep Herring 5.27E+08 3.80E+06 4.01E+09 1.02E+07 2.67E+09 2.03E+05 6.70E+06 -- -- 7.78E+08 1.02E+05 1.25E+07 --

Family December 2008 Blueback

-- 1.40E+07 3.58E+05 2.99E+07 2.49E+05 8.25E+05 -- 6.22E+05 -- 4.95E+04 9.93E+04 -- --

Herring Alewife -- -- -- 5.46E+06 1.08E+05 -- -- -- -- 6.61E+05 -- 4.40E+04 --

American 2.68E+07 4.47E+06 9.50E+06 2.36E+05 4.26E+08 2.18E+05 4.87E+05 -- -- 2.12E+06 -- 6.53E+04 9.60E+04 Shad Alosa 1.78E+09 1.55E+07 2.99E+09 2.06E+06 4.01E+09 6.57E+05 1.54E+07 -- 2.14E+06 9.90E+05 -- 2.19E+04 --

Species Atlantic

-- -- -- -- -- -- 2.48E+06 -- -- 7.99E+06 -- -- --

Menhaden Anchovy 7.47E+08 7.50E+09 1.95E+06 9.73E+09 1.24E+08 2.11E+09 -- -- -- -- -- -- --

Family Bay 1.12E+10 8.30E+10 6.51E+06 1.20E+10 1.79E+09 2.15E+10 1.79E+09 1.37E+10 -- 1.01E+08 3.81E+09 4.80E+08 5.20E+09 Anchovy Rainbow

-- -- 2.88E+04 -- 1.98E+07 3.59E+06 7.58E+05 1.54E+05 3.49E+08 5.06E+07 7.77E+06 8.59E+06 3.25E+06 Smelt Spottail

-- -- -- 5.00E+05 -- 2.18E+05 -- -- -- -- -- -- --

I-44 Shiner White

-- -- -- -- -- 1.96E+05 -- -- 5.33E+05 2.37E+04 -- -- --

Catfish Atlantic 2.15E+08 -- 5.18E+06 9.13E+05 1.32E+08 1.34E+07 1.66E+08 5.48E+05 1.84E+08 4.48E+07 -- 1.48E+07 1.18E+06 Tomcod White 3.72E+09 7.31E+07 1.43E+09 1.33E+08 6.60E+08 1.10E+08 1.42E+08 9.95E+06 1.27E+07 6.77E+08 1.42E+07 8.81E+07 1.80E+07 Perch Striped 5.92E+09 1.22E+07 8.00E+08 1.82E+08 1.04E+09 7.58E+08 2.65E+08 7.15E+05 -- 7.64E+08 7.54E+06 3.88E+08 1.67E+07 Bass Morone

-- -- 6.53E+08 4.27E+07 1.33E+08 3.31E+07 6.71E+07 3.29E+05 -- 7.34E+07 1.02E+06 2.96E+07 9.27E+05 Species Perch

-- -- 4.28E+07 -- 1.29E+07 -- 4.36E+04 -- -- 5.34E+05 4.96E+04 4.20E+04 --

Family Bluefish -- -- -- -- -- 2.15E+05 -- 1.07E+06 -- -- -- -- --

Weakfish -- 2.62E+08 -- 2.64E+08 -- 5.53E+08 1.96E+06 1.03E+08 -- -- 1.44E+07 1.52E+05 2.35E+06 Hogchoker 3.32E+06 2.70E+08 5.84E+05 1.37E+08 2.82E+06 4.81E+07 3.45E+04 3.90E+07 -- 2.35E+04 1.33E+07 1.30E+05 4.61E+06 Total RIS 2.42E+10 9.11E+10 9.95E+09 2.26E+10 1.10E+10 2.51E+10 2.46E+09 1.39E+10 5.48E+08 2.50E+09 3.86E+09 1.02E+09 5.25E+09

-- = Not identified in sample Draft NUREG-1437, Supplement 38

December 2008 Table I-30 Assessment of Impingement 75th Percentile Rank of Si Rank of Fish Max Density Rank of Impingement :

Species of Imp i Impingement S RIS Density in River Caught in River Rank of Fish Density Impingement Imp RIS Ratio (percent) Segment 4 Alewife 279 0.43 percent 7 6.94 1.30 10 0.70 Bay 4475 6.96 percent 15 391.41 73.05 17 0.88 Anchovy American 426 0.66 percent 8 23.27 4.34 15 0.53 Shad Bluefish 669 1.04 percent 10 1.66 0.31 6 1.67 Hogchoker 3890 6.05 percent 13 4.27 0.80 8 1.63 Atlantic 150 0.23 percent 5 0.00 0.00 1 Not Calculable Menhaden Blueback 4251 6.61 percent 14 38.43 7.17 16 0.88 Herring Rainbow 440 0.68 percent 9 3.12 0.58 7 1.29 I-45 Smelt Shortnose 0 0.00 percent 1 0.00 0.00 1 Not Calculable Sturgeon Spottail 94 0.15 percent 3 5.80 1.08 9 0.33 Shiner Atlantic 4 0.01 percent 2 0.00 0.00 1 Not Calculable Sturgeon Striped 1146 1.78 percent 11 15.24 2.84 13 0.85 Bass Atlantic 13690 21.28 percent 16 11.94 2.23 12 1.33 Tomcod White 182 0.28 percent 6 0.03 0.01 5 1.20 Catfish White 25599 39.79 percent 17 22.56 4.21 14 1.21 Perch Weakfish 1330 2.07 percent 12 11.11 2.07 11 1.09 Gizzard 127 0.20 percent 4 0.00 0.00 1 Not Calculable Shad Total RIS 64339 535.77 NUREG-1437, Supplement 38

Appendix I 1 Table I-31 Assessment of Entrainment Si Ei Rank of Entrainment S RIS Rank of Fish Density Rank of Entrainment:

Species E RIS Proportion (percent) in River Segment 4 Rank of Fish Density Alewife 40.28 percent 13 1.30 10 1.3 Bay Anchovy 99.10 percent 17 73.05 17 1.0 American Shad 40.28 percent 13 4.34 15 0.9 Bluefish 0.01 percent 5 0.31 6 0.8 Hogchoker 0.61 percent 8 0.80 8 1.0 Atlantic Menhaden 0.32 percent 7 0.00 1 Not Calculable Blueback Herring 40.28 percent 13 7.17 16 0.8 Rainbow Smelt 63.72 percent 16 0.58 7 2.3 Shortnose Sturgeon 0.00 percent 1 0.00 1 Not Calculable Spottail Shiner 0.00 percent 4 1.08 9 0.4 Atlantic Sturgeon 0.00 percent 1 0.00 1 Not Calculable Striped Bass 37.94 percent 11 2.84 13 0.8 Atlantic Tomcod 33.47 percent 10 2.23 12 0.8 White Catfish 0.10 percent 6 0.01 5 1.2 White Perch 37.94 percent 11 4.21 14 0.8 Weakfish 2.20 percent 9 2.07 11 0.8 Gizzard Shad 0.00 percent 1 0.00 1 Not Calculable Draft NUREG-1437, Supplement 38 I-46 December 2008

Appendix I 1 Table I-32 Weight of Evidence for the Strength-of-Connection Line of Evidence Based on 2 the Result Scores of Low = 1, Medium = 2, and High = 3 Impingement Entrainment Measurement Result Score Result Score WOE Strength of RIS Prey RIS Prey Scoreb Connection Use and Utilitya 1.9 2.0 1.6 2.1 Alewife 2 1 2 1 1.5 Low to Medium Bay Anchovy 2 1 2 1 1.5 Low to Medium American Shad 2 1 2 1 1.5 Low to Medium Bluefish 4 2 2 2 2.5 High Hogchoker 4 1 2 1 2.0 Medium to High Atlantic Menhaden Unknown 1 Unknown 1 Unknown Unknown Blueback Herring 2 1 2 1 1.5 Low to Medium Rainbow Smelt 2 1 4 1 1.9 Medium Shortnose Sturgeon Unknown 1 Unknown 1 Unknown Unknown Spottail Shiner 1 2 1 2 1.5 Low to Medium Atlantic Sturgeon Unknown 1 Unknown 1 Unknown Unknown Striped Bass 2 4 2 2 2.5 High Atlantic Tomcod 2 1 2 1 1.5 Low to Medium White Catfish 2 1 2 1 1.5 Low to Medium White Perch 2 2 2 2 2.0 Medium to High Weakfish 2 2 2 2 2.0 Medium to High Gizzard Shad Unknown 1 Unknown 1 Unknown Unknown Blue Crab Unknown 1 Unknown 1 Unknown Unknown (a) Use and Utility: Low = <1.5, Medium = 1.5 but 2.0, High = >2.0 (b) WOE Score: Small = <1.5; Small-Moderate = 1.5; Moderate = >1.5 but <2.0; Moderate-Large = 2.0; Large = >2.0 3 I.3 Cumulative Impacts on Aquatic Resources 4 Zebra Mussels 5 For this analysis, the 75th percentile of the weekly FSS and BSS density and CPUE data from 6 Region 12 (Albany) were used to evaluate the population trend LOE for impacts associated with 7 a zebra mussel invasion. Data for white perch, blueback herring, alewife, American shad, white 8 catfish, spottail shiner, and striped bass were used in the analysis because all have high 9 densities of YOY within this region. The data were standardized based on the first 5-year mean 10 and the standard deviation of all annual results (1979 to 2005). Only weeks 27 to 43 were used 11 in the analysis for the FSS and weeks 22 to 43 for the BSS survey, so that most years 12 contained observations from the months of July through October and June through October for 13 each survey, respectively. Effects associated with changes in gear types for the FSS (1985) 14 were also considered.

15 Simple linear regression and segmented regression with a single join point were fit to the annual 16 measure of abundance for each RIS, as described in Section H.3. The model with the smallest 17 MSE was chosen as the better fit to the data. If the best-fit model was the simple linear 18 regression and the slope was statistically significantly less than 0 ( = 0.05), a negative 19 population trend was considered detected. If the slope was not significantly different from 0, December 2008 I-47 Draft NUREG-1437, Supplement 38

Appendix I 1 then a population trend was not considered detected. If the best-fit model was the segmented 2 regression and either slope, S1 or S2, was statistically significantly less than 0 ( = 0.05), then a 3 negative population trend was considered detected. If both slopes S1 and S2 were not 4 significantly different from 0 ( = 0.05), then the trend was not considered detected.

5 An assessment of adverse impact was only supported if more than 40 percent of the 6 standardized observations were outside the bounds of +/- 1. For a normal bell-shaped 7 distribution with a mean of 0 and a standard deviation of 1, 32 percent of the observations are 8 outside the bounds of +/- 1 standard deviation. Thus, observations outside the boundaries of +/-1 9 standard deviation from the mean of the first 5 years were considered outside the natural 10 variability (noise). If more than 40 percent of the standardized observations were outside this 11 defined level of noise, then a potential for adverse impact was considered supported.

12 Data collected between 1985 and 2005 are not temporally disconnected from the1991 invasion 13 of zebra mussels. However, because of earlier impacts, there is a potential that fish populations 14 stabilized pre-1985 to a lower abundance level. If changes in gear types have affected the 15 observed population response, only data post-1985 were used. For this analysis, data were 16 standardized with the average of 1985 to 1989 and the standard deviation of all data between 17 1985 and 2005. This analysis was used only when the observed response from all data was 18 biologically different from the BSS population density trend and had a decline associated with 19 the gear change.

20 A visual comparison of the river-segment FSS standardized density with the BSS standardized 21 density suggested that the trends for blueback herring, spottail shiner, striped bass, and white 22 perch were not biologically different (Figure I-18). Observations from both surveys overlap and 23 cross over each other. Thus, for these RIS, all of the FSS data (1979-2005) were used in the 24 regression analysis. The FSS density data for alewife and American shad, however, did show a 25 potential gear effect (Figure I-19), and a post-1985 analysis was conducted.

Draft NUREG-1437, Supplement 38 I-48 December 2008

Appendix I FJS gear change FJS gear change 3 3 Standardized Density Standardized Density 2 2 1 1 0 0

-1 -1

-2 -2

-3 -3 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey Blueback Herring BSS-D Spottail Shiner BSS-D Blueback Herring FJS-D Spottail Shiner FJS-D FJS gear change FJS gear change 3 3 Standardized Density Standardized Density 2 2 1 1 0 0

-1 -1

-2 -2

-3 -3 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey Striped Bass BSS-D W hite Perch BSS-D Striped Bass FJS-D W hite Perch FJS-D 1 Note: All data were used in WOE analysis.

2 Figure I-18 River Segment 12 population trends based on the BSS and FSS standardized 3 density (D) not considered biologically different December 2008 I-49 Draft NUREG-1437, Supplement 38

Appendix I FJS gear change FJS gear change 3 3 Standardized Density Standardized Density 2 2 1 1 0 0

-1 -1

-2 -2

-3 -3 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey Alewife BSS-D American Shad BSS-D Alewife FJS-D American Shad FJS-D 1 Note: Post-1985 data were analyzed for WOE analysis.

2 Figure I-19 River Segment 12 population trends based on the BSS and FSS standardized 3 density (D) for which the FSS may indicate a gear difference 4 The following tables are the intermediate analyses for the assessment of population trends 5 associated with fish density sampled from River Segment 12 (Albany). Results of these river-6 segment trend analyses are compiled in Table H-18 in Section H.4 of the draft SEIS. The data 7 used in this analysis, in order of appearance, were the standardized 75th percentile of the 8 weekly fish density for a given year collected from the FSS (Table I-33, Table I-34, and 9 Figure I-20) and BSS (Table I-35, Table I-36, and Figure I-21).

10 Two extreme outliers (values greater than 2 standard deviations away from the mean) were 11 removed from the FSS spottail shiner density regression analysis (Tables I-33 and I-34). Three 12 extreme outliers were also removed from the FSS striped bass density (values greater than 13 2 standard deviations away from the mean) regression analysis and one extreme outlier from 14 the FSS white catfish density (value greater than 2 standard deviations away from the mean) 15 regression analysis because of the influence these data had on the regression results. The 16 results of the regression models with the observations removed were more conservative and 17 were used for the trend analysis.

18 One extreme outlier (value greater than 2 standard deviations away from the mean) was 19 removed from the BSS alewife density regression analysis (Tables I-35 and I-36). One value 20 was also removed from the BSS American shad density (value greater than 1.6 standard 21 deviations away from the mean) regression analysis, one extreme outlier from the BSS spottail 22 shiner density (value greater than 3 standard deviations away from the mean) regression 23 analysis, and two extreme outliers from the BSS striped bass density (values greater than 24 2 standard deviations away from the mean) regression analysis because of the influence these 25 data had on the regression results. The results of the regression models with the observations 26 removed were more conservative and were used for the trend analysis.

Draft NUREG-1437, Supplement 38 I-50 December 2008

Appendix I 1 Table I-33 Competing Models Used To Characterize the Standardized River Segment 12 2 (Albany) Fall Juvenile Survey Population Trends of YOY Fish Density Linear Regression Segmented Regression 95 percent CI Join 95 percent CI Species MSE Slope p-value MSE Slope 1 Point Slope 2 Alewife (1985-2005) 1.01 0.031 +/- 0.036 0.409 0.95 -5.66 to 2.00 1986 -0.028 to 0.139 American Shad (1985-2005) 0.95 -0.059 +/- 0.034 0.102 0.90 -0.216 to 0.475 1992 -0.271 to -0.0001 Blueback Herring 0.73 -0.088 +/- 0.018 < 0.001 0.44 -0.520 to -0.238 1987 -0.042 to 0.034 Spottail Shiner (All data) 1.02 -0.007 +/- 0.025 0.777 1.05 -0.553 to 0.695 1984 -0.095 to 0.059 Spottail Shiner (2 outliers removed) 0.65 -0.025 +/- 0.017 0.158 0.59 -0.041 to 0.160 1991 -0.188 to -0.010 Striped Bass (All data) 0.975 0.037 +/- 0.024 0.139 0.94 0.004 to 0.155 1999 -0.568 to 0.171 Striped Bass (3 outliers removed) 0.40 0.012 +/- 0.010 0.253 0.42 -1.20 to 1.30 1980 -0.014 to 0.037 White Catfish (All data) 0.982 -0.034 +/- 0.024 0.171 1.00 -0.118 to 0.123 1994 -0.283 to 0.096 White Catfish (1 outlier -1.15e+006 to removed) 0.88 -0.022 +/- 0.022 0.327 0.92 1.15e+006 1979 -0.070 to 0.026 White Perch 0.84 -0.071 +/- 0.021 0.002 0.58 -0.972 to -0.212 1984 -0.049 to 0.031 December 2008 I-51 Draft NUREG-1437, Supplement 38

Appendix I 1 Table I-34 River Segment 12 (Albany) Assessment of the Level of Potential Negative 2 Impact Based on the Standardized FSS Density Support for Level of Possible Potential Best General Percent Outside Negative Negative Species Fit Trend Defined Level of Noise Impact Impact S1 = 0 Alewife SR S2 = 0 19 percent No 1 S1 = 0 American Shad SR S2 < 0 14 percent No 2 S1 < 0 Blueback Herring SR S2 = 0 78 percent Yes 4 Spottail Shiner (All data) LR S=0 22 percent No 1 Spottail Shiner (2 outliers S1 = 0 removed) SR S2 < 0 22 percent No 2 Striped Bass S1 > 0 (All data) SR S2 = 0 19 percent No 1 Striped Bass (3 outliers removed) LR S=0 19 percent No 1 White Catfish (All data) LR S=0 33 percent No 1 White Catfish (1 outlier removed) S=0 LR 33 percent No 1 S1 < 0 White Perch SR S2 = 0 78 percent Yes 4 3 LR = Linear Regression; SR = Segmented Regression 2 3 Blueback Herring W hite Perch 2

FJS 3rd Q Density 1

FJS 3rd Q Density 1

0 0

-1

-1

-2 -2

-3 -3 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey 4

5 Note: Design Restricted 6 Figure I-20 River Segment 12 (Albany) population trends based on the FSS standardized 7 density assigned a large level of potential negative impact 8

Draft NUREG-1437, Supplement 38 I-52 December 2008

Appendix I 1 Table I-35 Competing Models Used To Characterize the Standardized River Segment 12 2 (Albany) Beach Seine Survey Population Trends of YOY Fish Density Linear Regression Segmented Regression 95 percent CI Join 95 percent CI Species MSE Slope p-value MSE Slope 1 Point Slope 2 Alewife (All data) 1.01 -0.020 +/- 0.025 0.440 1.03 -0.877 to 0.472 1984 -0.073 to 0.071 Alewife (1 outlier removed) 0.78 -0.018 +/- 0.019 0.373 0.74 -0.310 to 0.027 1989 -0.039 to 0.120 American Shad (All data) 0.91 -0.056 +/- 0.023 0.020 Did Not Converge American Shad (1 value removed) 0.81 -0.055 +/- 0.020 0.012 Did Not Converge Blueback Herring 0.87 -0.066 +/- 0.022 0.005 0.78 -0.221 to -0.060 1996 -0.078 to 0.279 Spottail Shiner (All data) 1.02 0.007 +/- 0.025 0.769 1.05 -1.23 to 0.765 1982 -0.050 to 0.087 Spottail Shiner (1 outlier removed) 0.66 -0.021 +/- 0.017 0.232 0.68 -1.06 to 0.704 1982 -0.059 to 0.032 Striped Bass (All data) 0.99 0.030 +/- 0.025 0.226 1.02 -0.787 to 0.544 1984 -0.024 to 0.117 Striped Bass (2 outliers removed) 0.61 0.020 +/- 0.015 0.211 0.59 -0.483 to 0.148 1984 -0.003 to 0.088 White Perch 0.94 -0.048 +/- 0.023 0.048 0.92 -0.229 to -0.003 1994 -0.100 to 0.216 December 2008 I-53 Draft NUREG-1437, Supplement 38

Appendix I 1 Table I-36 River Segment 12 (Albany) Assessment of the Level of Potential Negative 2 Impact Based on the Standardized BSS Density Support for Level of Percent Outside Possible Potential Best General Defined Level of Noise Negative Negative Species Fit Trend (percent) Impact Impact Alewife (All data) LR S=0 44 Yes 2 Alewife (1 outlier S1 = 0 removed) SR S2 = 0 44 Yes 2 American Shad (All data) LR S<0 41 Yes 4 American Shad (1 value removed) LR S<0 41 Yes 4 S1 < 0 Blueback Herring SR S2 = 0 85 Yes 4 Spottail Shiner (All data) LR S=0 7 No 1 Spottail Shiner (1 outlier removed) LR S=0 7 No 1 Striped Bass (All data) LR S=0 15 No 1 Striped Bass (2 outliers S1 = 0 removed) SR S2 = 0 15 No 1 S1 < 0 White Perch SR S2 = 0 63 Yes 4 3 LR = Linear Regression; SR = Segmented Regression Draft NUREG-1437, Supplement 38 I-54 December 2008

Appendix I 2 2 American Shad Blueback Herring Outlier AS BSS 3rd Q Density 1 1 BSS 3rd Q Density 0

0

-1

-1

-2

-2

-3

-3 -4 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey 2

W hite Perch BSS 3rd Q Density 1

0

-1

-2

-3 0 5 10 15 20 25 30 Years of Survey 1

2 Note: Design Restricted 3 Figure I-21 River Segment 12 (Albany) population trends based on the BSS standardized 4 density assigned a large level of potential negative impact 5 A visual comparison of the river-segment FSS standardized CPUE with the BSS standardized 6 density suggested that the trends were not biologically different for blueback herring, spottail 7 shiner, striped bass, and white perch (Figure I-22). Observations from both surveys overlap and 8 cross over each other. Thus, for these RIS, all of the FSS data (1979-2005) were used in the 9 regression analysis. The FSS density data for alewife and American shad, however, did show a 10 potential gear effect (Figure I-23), and a post-1985 analysis was conducted.

December 2008 I-55 Draft NUREG-1437, Supplement 38

Appendix I FJS gear change FJS gear change Standardized Density or CPUE Standardized Density or CPUE 3 3 2 2 1 1 0 0

-1 -1

-2 -2

-3 -3 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey Blueback Herring BSS-D Spottail Shiner BSS-D Blueback Herring FJS-C Spottail shiner FJS-C FJS gear change FJS gear change Standardized Density or CPUE Standardized Density or CPUE 3 3 2 2 1 1 0 0

-1 -1

-2 -2

-3 -3 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey Striped Bass BSS-D W hite Perch BSS-D Stripped Bass FJS-C W hite Perch FJS-C 1

2 Note: All data were used in WOE analysis.

3 Figure I-22 River Segment 12 population trends based on the FSS standardized CPUE 4 (C) and BSS density (D) not considered biologically different Draft NUREG-1437, Supplement 38 I-56 December 2008

Appendix I FJS gear change FJS gear change Standardized Density or CPUE Standardized Density or CPUE 3 3 2 2 1 1 0 0

-1 -1

-2 -2

-3 -3 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey Alewife BSS-D American Shad BSS-D Alewife FJS-C American Shad FJS-C 1

2 Note: Post-1985 data were analyzed for WOE analysis.

3 Figure I-23 River Segment 12 population trends based on the FSS standardized CPUE 4 (C) and BSS density (D) for which the FSS may indicate a gear difference 5 The following tables are the intermediate analyses for the assessment of population trends 6 associated with fish CPUE sampled from River Segment 12 (Albany). Results of these river-7 segment trend analyses are compiled in Table H-18 in Section H.4 of the draft SEIS. The data 8 used in this analysis were the standardized 75th percentile of the weekly fish CPUE for a given 9 year collected from the FSS (Table I-37, Table I-38, and Figure I-23).

10 One extreme outlier (value greater than 3 standard deviations away from the mean) was 11 removed from the FSS spottail shiner CPUE regression analysis (Tables I-37 and I-38), and one 12 extreme outlier was removed from the FSS white catfish CPUE (value greater than 2 standard 13 deviations away from the mean) regression analysis because of the influence these data had on 14 the regression results. The results of the regression models with the observations removed 15 were more conservative and were used for the trend analysis.

December 2008 I-57 Draft NUREG-1437, Supplement 38

Appendix I 1 Table I-37 Competing Models Used To Characterize the Standardized River Segment 12 2 (Albany) Fall Juvenile Survey Population Trends of YOY Fish CPUE Linear Regression Segmented Regression 95 percent CI Join 95 percent CI Species MSE Slope p-value MSE Slope 1 Point Slope 2 Alewife (1985-2005) 1.00 0.033 +/- 0.036 0.371 0.96 -0.185 to 0.083 1999 -0.108 to 0.656 American Shad (1985-2005) 0.94 -0.066 +/- 0.034 0.064 0.96 -0.342 to 0.385 1992 -0.247 to 0.046 Blueback Herring 0.72 -0.089 +/- 0.018 < 0.001 0.38 -0.484 to -0.282 1987 -0.035 to 0.037 Spottail Shiner (All data) 0.91 -0.057 +/- 0.023 0.018 Did Not Converge Spottail Shiner (1 outlier removed) 0.52 -0.038 +/- 0.013 0.008 0.53 -2.89 to 2.14 1980 -0.066 to -0.002 Striped Bass 0.98 0.034 +/- 0.024 0.168 0.95 -0.010 to 0.162 1997 -0.415 to 0.180 White Catfish (All data) 0.91 -0.056 +/- 0.023 0.020 Did Not Converge White Catfish (1 outlier removed) 0.72 -0.042 +/- 0.018 0.031 0.68 -0.325 to 1.14 1982 -0.111 to -0.018 White Perch 0.67 -0.095 +/- 0.017 < 0.001 0.64 -0.391 to -0.052 1987 -0.116 to 0.003 Draft NUREG-1437, Supplement 38 I-58 December 2008

Appendix I 1 Table I-38 River Segment 12 (Albany) Assessment of the Level of Potential Negative 2 Impact Based on the Standardized FSS CPUE Support for Level of Percent Outside Possible Potential Best General Defined Level of Noise Negative Negative Species Fit Trend (percent) Impact Impact S1 = 0 Alewife SR S2 = 0 10 No 1 American Shad LR S=0 52 Yes 2 Blueback S1 < 0 Herring SR S2 = 0 78 Yes 4 Spottail Shiner (All data) LR S<0 4 No 2 Spottail Shiner (1 outlier removed) LR S<0 4 No 2 S1 = 0 Striped Bass SR S2 = 0 15 No 1 White Catfish (All data) LR S<0 41 Yes 4 White Catfish (1 outlier S1 = 0 removed) SR S2 < 0 41 Yes 4 S1 < 0 White Perch SR S2 = 0 81 Yes 4 3 LR = Linear Regression; SR = Segmented Regression December 2008 I-59 Draft NUREG-1437, Supplement 38

Appendix I 2 1.5 American Shad Blueback Herring 1.0 1 0.5 FJS 3rd Q CPUE FJS 3rd Q CPUE 0.0 0 -0.5

-1.0

-1

-1.5

-2 -2.0

-2.5

-3 -3.0 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey 3 2 W hite Catfish W hite Perch 2 Outlier W C 1 FJS 3rd Q CPUE FJS 3rd Q CPUE 0

1

-1 0

-2

-1 -3

-2 -4 0 5 10 15 20 25 30 0 5 10 15 20 25 30 Years of Survey Years of Survey 1

2 Note: Design Restricted 3 Figure I-24 River Segment 12 (Albany) population trends based on the FSS standardized 4 CPUE assigned a large level of potential negative impact 5 The WOE analysis for River Segment 12, Albany, for all population trend data post-1991 is 6 presented in Table I-39. This table is a compilation of Tables I-34, I-36, and I-38 and was used 7 to derive Table H-18 in Section H.3 in the draft SEIS.

Draft NUREG-1437, Supplement 38 I-60 December 2008

Appendix I 1 Table I-39 River Segment 12 (Albany) Assessment of the Level of Potential Negative 2 Impact Following Zebra Mussel Invasion in 1991 Based on the Standardized FSS and 3 BSS Density and FSS CPUE Percent Outside Level of Potential Support for Species Trend Post-1991 Defined Level of Noise Negative Impact Possible Negative Impact (percent) Post- 1991 FSS Density Alewife S2 = 0 20 No 1 American Shad S2 < 0 13 No 2 Blueback Herring S2 = 0 100 Yes 2 Spottail Shiner S2 < 0 20 No 2 Stripped Bass S=0 33 No 1 White Catfish S=0 40 p No 1 White Perch S2 = 0 87 Yes 2 BSS Density Alewife S2 = 0 47 Yes 2 American Shad S<0 53 Yes 4 Blueback Herring S2 = 0 93 Yes 2 Spottail Shiner S=0 13 No 1 Stripped Bass S2 = 0 27 No 1 White Perch S2 = 0 87 Yes 2 FSS CPUE Alewife S2 = 0 7 No 1 American Shad S=0 53 Yes 2 Blueback Herring S2 = 0 100 Yes 2 Spottail Shiner S<0 0 No 2 Stripped Bass S2 = 0 27 No 1 White Catfish S2 < 0 53 Yes 4 White Perch S2 = 0 93 Yes 2 4 Water Quality and Temperature 5 Both water quality and water temperature can act to shift RIS densities into adjacent river 6 segments based on specific life stage needs. Water quality changes have been occurring over 7 the past decade (Section 2.2.5 of the draft SEIS), and water temperatures have been increasing 8 over the last 100 years (Figure I-36). An analysis of RIS distributional change within the 9 Hudson River was conducted by comparing the first and last 5-year mean densities from the 10 survey that was most efficient at catching a given RIS. Striped bass (Figure I-37), alewife 11 (Figure I-38), spottail shiner (Figure I-39), hogchoker (Figure I-40), and white perch (Figure I-41) 12 all appear to have shifted slightly upriver, while the bay anchovy has shifted slightly downriver 13 (Figure I-42). All other RIS that could be evaluated (American shad, Atlantic tomcod, blueback 14 herring, bluefish, and weakfish) did not show a change in their distributions. It is not possible 15 from these data to determine what might have influenced these shifts.

December 2008 I-61 Draft NUREG-1437, Supplement 38

Appendix I 1

2 Source: Hansen et al. 2006 3 Figure I-36 Historical trend in global land and ocean temperature Striped bass 3

2 Standardized Mean Density 1

0

-1

-2

-3 0 1 2 3 4 5 6 7 8 9 10 11 12 River Segment 1st 5-yr mean Last 5-yr Mean 4

5 Figure I-37 Relative density of YOY striped bass from the BSS 1979-1983 and 2001-2005.

6 data within each river segment of the Hudson River Draft NUREG-1437, Supplement 38 I-62 December 2008

Appendix I Alewife 3

2 Standardized Mean Density 1

0

-1

-2

-3 0 1 2 3 4 5 6 7 8 9 10 11 12 River Segment 1st 5-yr mean Last 5-yr Mean 1

2 Figure I-38 Relative density of YOY alewife from the BSS 1979-1983 and 2001-2005; 3 data within each river segment of the Hudson River Spottail shiner 3

2 Standardized Mean Density 1

0

-1

-2

-3 0 1 2 3 4 5 6 7 8 9 10 11 12 River Segment 1st 5-yr mean Last 5-yr Mean 4

5 Figure I-39 Relative density of YOY spottail shiner from the BSS 1979-1983 and 2001-6 2005; data within each river segment of the Hudson River December 2008 I-63 Draft NUREG-1437, Supplement 38

Appendix I Hogchoker 3

2 Standardized Mean Density 1

0

-1

-2

-3 0 1 2 3 4 5 6 7 8 9 10 11 12 River Segment 1st 5-yr mean Last 5-yr Mean 1

2 Figure I-40 Relative density of YOY hogchoker from the FSS 1979-1983 and 2001-2005; 3 data within each river segment of the Hudson River W hite perch 3

2 Standardized Mean Density 1

0

-1

-2

-3 0 1 2 3 4 5 6 7 8 9 10 11 12 River Segment 1st 5-yr mean Last 5-yr Mean 4

5 Figure I-41 Relative density of YOY white perch from the BSS 1979-1983 and 2001-2005; 6 data within each river segment of the Hudson River Draft NUREG-1437, Supplement 38 I-64 December 2008

Appendix I Bay anchovy 3

2 Standardized Mean Density 1

0

-1

-2

-3 0 1 2 3 4 5 6 7 8 9 10 11 12 River Segment 1st 5-yr mean Last 5-yr Mean 1

2 Figure I-42 Relative density of YOY bay anchovy from the FSS 1979-1983 and 2001-3 2005; data within each river segment of the Hudson River December 2008 I-65 Draft NUREG-1437, Supplement 38

Appendix I 1 I.4 References 2 Applied Science Associates (ASA). 1999. 1996 Year Class Report for the Hudson River 3 Estuary Monitoring Program. Prepared for Consolidated Edison Company of New York, Inc.;

4 Orange and Rockland Utilities, Inc.; Central Hudson Gas and Electric Corporation; New York 5 Power Authority; and Niagara Mohawk Power Corporation. December 1999. ADAMS 6 Accession No. ML083420045.

7 Applied Science Associates (ASA). 2001a. 1997 Year Class Report for the Hudson River 8 Estuary Monitoring Program. Prepared for Consolidated Edison Company of New York, Inc.;

9 Orange and Rockland Utilities, Inc.; Central Hudson Gas and Electric Corporation; New York 10 Power Authority; Niagara Mohawk Power Corporation; and Southern Energy New York.

11 January 2001. ADAMS Accession No. ML083420045.

12 ASA Analysis and Communication (ASA). 2001b. 1998 Year Class Report for the Hudson 13 River Estuary Monitoring Program. Prepared for Consolidated Edison Company of New York, 14 Inc.; Central Hudson Gas and Electric Corporation; Dynegy Roseton LLC; Entergy Indian Point 15 3 LLC; Mirant Bowline LLC; New York Power Authority; and Niagara Mohawk Power 16 Corporation. July 2001.

17 ASA Analysis and Communication (ASA). 2002. 1999 Year Class Report for the Hudson River 18 Estuary Monitoring Program. Prepared for Dynegy Roseton L.L.C.; Entergy Nuclear Indian 19 Point 2 L.L.C.; Entergy Nuclear Indian Point 3 L.L.C.; and Mirant Bowline L.L.C. August 2002.

20 ADAMS Accession No. ML083420076.

21 ASA Analysis and Communication (ASA). 2003. 2000 Year Class Report for the Hudson River 22 Estuary Monitoring Program. Prepared for Dynegy Roseton L.L.C.; Entergy Nuclear Indian 23 Point 2 L.L.C.; Entergy Nuclear Indian Point 3 L.L.C.; and Mirant Bowline L.L.C. June 2003.

24 ADAMS Accession No. ML083420089.

25 ASA Analysis and Communication (ASA). 2004a. 2001 Year Class Report for the Hudson 26 River Estuary Monitoring Program. Prepared for Dynegy Roseton L.L.C.; Entergy Nuclear 27 Indian Point 2 L.L.C.; Entergy Nuclear Indian Point 3 L.L.C.; and Mirant Bowline L.L.C.

28 April 2004.

29 ASA Analysis and Communication (ASA). 2004b. 2002 Year Class Report for the Hudson 30 River Estuary Monitoring Program. Prepared for Dynegy Roseton L.L.C.; Entergy Nuclear 31 Indian Point 2 L.L.C.; Entergy Nuclear Indian Point 3 L.L.C.; and Mirant Bowline L.L.C.

32 October 2004.

33 ASA Analysis and Communication (ASA). 2005. 2003 Year Class Report for the Hudson River 34 Estuary Monitoring Program. Prepared for Dynegy Roseton L.L.C.; Entergy Nuclear Indian 35 Point 2 L.L.C.; Entergy Nuclear Indian Point 3 L.L.C.; and Mirant Bowline L.L.C. February 2005.

36 ASA Analysis and Communication (ASA). 2006. 2004 Year Class Report for the Hudson River 37 Estuary Monitoring Program. Prepared for Dynegy Roseton L.L.C.; Entergy Nuclear Indian 38 Point 2 L.L.C.; Entergy Nuclear Indian Point 3 L.L.C.; and Mirant Bowline L.L.C. January 2006.

39 ADAMS Accession No. ML083420103.

Draft NUREG-1437, Supplement 38 I-66 December 2008

Appendix I 1 ASA Analysis and Communication (ASA). 2007. 2005 Year Class Report for the Hudson River 2 Estuary Monitoring Program. Prepared for Dynegy Roseton L.L.C.; Entergy Nuclear Indian 3 Point 2 L.L.C.; Entergy Nuclear Indian Point 3 L.L.C.; and Mirant Bowline L.L.C. January 2007.

4 ADAMS Accession No. ML073331067.

5 Battelle. 1983. 1980 and 1981 Year Class Report for the Hudson River Estuary Monitoring 6 Program. Prepared for Consolidated Edison Company of New York, Inc.; Orange and Rockland 7 Utilities, Inc.; Central Hudson Gas and Electric Corporation; New York Power Authority; and 8 Niagara Mohawk Power Corporation. December 15, 1983. ADAMS Accession No.

9 ML083420045.

10 Cochran, W.G. 1997. Sampling Techniques, John Wiley & Sons, New York, New York.

11 Consolidated Edison Company of New York, Inc. (Con Edison). Undated a. 1993 Year Class 12 Report for the Hudson River Estuary Monitoring Program. Prepared for Consolidated Edison 13 Company of New York, Inc.; Orange and Rockland Utilities, Inc.; Central Hudson Gas and 14 Electric Corporation; New York Power Authority; and Niagara Mohawk Power Corporation.

15 ADAMS Accession No. ML083420045.

16 Consolidated Edison Company of New York, Inc. (Con Edison). Undated b. 1994 Year Class 17 Report for the Hudson River Estuary Monitoring Program. Prepared for Consolidated Edison 18 Company of New York, Inc.; Orange and Rockland Utilities, Inc.; Central Hudson Gas and 19 Electric Corporation; New York Power Authority; and Niagara Mohawk Power Corporation.

20 ADAMS Accession No. ML083420045.

21 Consolidated Edison Company of New York, Inc. (Con Edison). Undated c. 1995 Year Class 22 Report for the Hudson River Estuary Monitoring Program. Prepared for Consolidated Edison 23 Company of New York, Inc.; Orange and Rockland Utilities, Inc.; Central Hudson Gas and 24 Electric Corporation; New York Power Authority; and Niagara Mohawk Power Corporation.

25 ADAMS Accession No. ML083420045.

26 Consolidated Edison Company of New York (Con Edison). 1980. Hudson River Ecological 27 Study in the Area of Indian Point 1979 Annual Report. ADAMS Accession No. ML083420045.

28 Consolidated Edison Company of New York (Con Edison). 1983. Hudson River Ecological 29 Study in the Area of Indian Point 1982 Annual Report. ADAMS Accession No. ML083420045.

30 Consolidated Edison Company of New York (Con Edison). 1984. Hudson River Ecological 31 Study in the Area of Indian Point 1981 Annual Report. ADAMS Accession No. ML083420045.

32 Consolidated Edison Company of New York (Con Edison) and New York Power Authority.

33 1984. Hudson River Ecological Study in the Area of Indian Point 1983 Annual Report. Prepared 34 by Normandeau Associates, Inc. ADAMS Accession No. ML083420045.

35 Consolidated Edison Company of New York (Con Edison) and New York Power Authority.

36 1986. Hudson River Ecological Study in the Area of Indian Point 1985 Annual Report. Prepared 37 by Normandeau Associates, Inc. ADAMS Accession No. ML083420045.

38 Consolidated Edison Company of New York (Con Edison) and New York Power Authority.

39 1987. Hudson River Ecological Study in the Area of Indian Point 1986 Annual Report. Prepared 40 by Normandeau Associates, Inc. ADAMS Accession No. ML083420045.

December 2008 I-67 Draft NUREG-1437, Supplement 38

Appendix I 1 Consolidated Edison Company of New York (Con Edison) and New York Power Authority.

2 1988. Hudson River Ecological Study in the Area of Indian Point 1987 Annual Report. Prepared 3 by EA Science and Technology. ADAMS Accession No. ML083420045.

4 Consolidated Edison Company of New York (Con Edison) and New York Power Authority.

5 1991. Hudson River Ecological Study in the Area of Indian Point 1990 Annual Report. Prepared 6 by EA Science and Technology. ADAMS Accession No. ML083420045.

7 Consolidated Edison Company of New York, Inc. (Con Edison). 1996. 1992 Year Class Report 8 for the Hudson River Estuary Monitoring Program. Prepared for Consolidated Edison Company 9 of New York, Inc.; Orange and Rockland Utilities, Inc.; Central Hudson Gas and Electric 10 Corporation; New York Power Authority; and Niagara Mohawk Power Corporation. April 1996.

11 ADAMS Accession No. ML083420045.

12 EA Engineering, Science, and Technology (EA). 1988. 1987 Year Class Report for the Hudson 13 River Estuary Monitoring Program. Prepared for Consolidated Edison Company of New York, 14 Inc.; Orange and Rockland Utilities, Inc.; Central Hudson Gas and Electric Corporation; New 15 York Power Authority; and Niagara Mohawk Power Corporation. July 1988. ADAMS Accession 16 No. ML083420045.

17 EA Engineering, Science, and Technology (EA). 1990. 1988 Year Class Report for the Hudson 18 River Estuary Monitoring Program. Prepared for Consolidated Edison Company of New York, 19 Inc.; Orange and Rockland Utilities, Inc.; Central Hudson Gas and Electric Corporation; New 20 York Power Authority; and Niagara Mohawk Power Corporation. August 1990. ADAMS 21 Accession No. ML083420045.

22 EA Engineering, Science, and Technology (EA). 1991. 1989 Year Class Report for the Hudson 23 River Estuary Monitoring Program. Prepared for Consolidated Edison Company of New York, 24 Inc.; Orange and Rockland Utilities, Inc.; Central Hudson Gas and Electric Corporation; New 25 York Power Authority; and Niagara Mohawk Power Corporation. March 1991. ADAMS 26 Accession No. ML083420045.

27 EA Engineering, Science, and Technology (EA). 1991. 1990 Year Class Report for the Hudson 28 River Estuary Monitoring Program. Prepared for Consolidated Edison Company of New York, 29 Inc.; Orange and Rockland Utilities, Inc.; Central Hudson Gas and Electric Corporation; New 30 York Power Authority; and Niagara Mohawk Power Corporation. October 1991. ADAMS 31 Accession No. ML083420045.

32 EA Engineering, Science, and Technology (EA). 1995. 1995 Year Class Report for the Hudson 33 River Estuary Monitoring Program. Prepared for Consolidated Edison Company of New York, 34 Inc.; Orange and Rockland Utilities, Inc.; Central Hudson Gas and Electric Corporation; New 35 York Power Authority; and Niagara Mohawk Power Corporation. ADAMS Accession No.

36 ML083420045.

37 Entergy Nuclear Operations, Inc. (Entergy). 2007. Applicant's Environment Report, Operating 38 License Renewal Stage. (Appendix E of Indian Point, Units 2 and 3, License Renewal 39 Application). April 23, 2007. (Agencywide Documents Access and Management System) 40 ADAMS Accession No. ML071210530 41 Entergy Nuclear Operations, Inc. (Entergy). 2007b. Letter from F.R. Dacimo, Vide President, 42 Entergy Nuclear Operations, Inc. to Document Control Desk, U.S. Nuclear Regulatory 43 Commission.

Subject:

Entergy Nuclear Operations, Inc., Indian Point Nuclear Generating Unit Draft NUREG-1437, Supplement 38 I-68 December 2008

Appendix I 1 Nos. 2 & 3; Docket Nos. 50-247 and 50-286; Supplement to License Renewal Application (LRA) 2 - Environmental Report References. ADAMS Nos. ML080080205, ML0800080209, 3 ML080080214, ML0800802161, ML0800080291, ML080080298, ML080080306, and 4 ML080080313.

5 Hansen J., M. Sato, R. Ruedy, K. Lo, D.W. Lea, and M. Medina-Elizade. 2006. Global 6 Temperature Change. PNAS 103: 14288-14293. Accessed at 7 http://pubs.giss.nasa.gov/docs/2006/2006_Hansen_etal_1.pdf on April 21, 2008.

8 Lawler, Matusky & Skelly Engineers (LMS). 1989. 1986 and 1987 Year Class Report for the 9 Hudson River Estuary Monitoring Program. Prepared for Consolidated Edison Company of 10 New York, Inc.; Orange and Rockland Utilities, Inc.; and Central Hudson Gas and Electric 11 Corporation. June 1989. ADAMS Accession No. ML083420045.

12 Lawler, Matusky & Skelly Engineers (LMS). 1991. 1990 Year Class Report for the Hudson 13 River Estuary Monitoring Program. Prepared for Consolidated Edison Company of New York, 14 Inc.; Orange and Rockland Utilities, Inc.; Central Hudson Gas and Electric Corporation; New 15 York Power Authority; and Niagara Mohawk Power Corporation. January 1991. ADAMS 16 Accession No. ML083420045.

17 Lawler, Matusky & Skelly Engineers (LMS). 1996. 1991 Year Class Report for the Hudson 18 River Estuary Monitoring Program. Prepared for Consolidated Edison Company of New York, 19 Inc.; Orange and Rockland Utilities, Inc.; Central Hudson Gas and Electric Corporation; New 20 York Power Authority; and Niagara Mohawk Power Corporation. January 1996. ADAMS 21 Accession No. ML083420045.

22 Martin Marietta Environmental Systems (MMES). 1986. 1984 Year Class Report for the 23 Hudson River Estuary Monitoring Program. Prepared for Consolidated Edison Company of 24 New York, Inc.; Orange and Rockland Utilities, Inc.; Central Hudson Gas and Electric 25 Corporation; New York Power Authority; and Niagara Mohawk Power Corporation. May 1986.

26 ADAMS Accession No. ML083420045.

27 New York Power Authority (NYPA). 1986. Size Selectivity and Relative Catch Efficiency of a 28 3-m Beam Trawl and a 1-m2 Epibenthic Sled for Sampling Young of the Year Striped Bass and 29 Other Fishes in the Hudson River Estuary. Prepared by Normandeau Associates, Inc. January 30 1986. (HR Library #7180). ADAMS Accession No. ML083360641.

31 Normandeau Associates, Inc. (Normandeau). 1985a. 1982 Year Class Report for the Hudson 32 River Estuary Monitoring Program. Prepared for Consolidated Edison Company of New York, 33 Inc.; Orange and Rockland Utilities, Inc.; Central Hudson Gas and Electric Corporation; New 34 York Power Authority; and Niagara Mohawk Power Corporation. February 1985. ADAMS 35 Accession No. ML083420045.

36 Normandeau Associates, Inc. (Normandeau). 1985b. 1983 Year Class Report for the Hudson 37 River Estuary Monitoring Program. Prepared for Consolidated Edison Company of New York, 38 Inc.; Orange and Rockland Utilities, Inc.; Central Hudson Gas and Electric Corporation; New 39 York Power Authority; and Niagara Mohawk Power Corporation. April 1985. ADAMS 40 Accession No. ML083420045.

41 Normandeau Associates, Inc. (Normandeau). 1986. 1985 Year Class Report for the Hudson 42 River Estuary Monitoring Program. Prepared for Consolidated Edison Company of New York, 43 Inc.; Orange and Rockland Utilities, Inc.; Central Hudson Gas and Electric Corporation; New December 2008 I-69 Draft NUREG-1437, Supplement 38

Appendix I 1 York Power Authority; and Niagara Mohawk Power Corporation. September 1986. ADAMS 2 Accession No. ML083420045.

3 Normandeau Associates, Inc. (Normandeau). 1987. 1986 Year Class Report for the Hudson 4 River Estuary Monitoring Program. Prepared for Consolidated Edison Company of New York, 5 Inc.; Orange and Rockland Utilities, Inc.; Central Hudson Gas and Electric Corporation; New 6 York Power Authority; and Niagara Mohawk Power Corporation. August 1987. ADAMS 7 Accession No. ML083420045.

8 Texas Instruments Inc. (TI). 1977. 1974 Year Class Report for the Multiplant Impact Study of 9 the Hudson River Estuary. Prepared for Consolidated Edison Company of New York, Inc.;

10 Orange and Rockland Utilities, Inc.; and Central Hudson Gas and Electric Corporation.

11 May 1977. ADAMS Accession No. ML083420045.

12 Texas Instruments Inc. (TI). 1978. 1975 Year Class Report for the Multiplant Impact Study of 13 the Hudson River Estuary. Prepared for Consolidated Edison Company of New York, Inc.;

14 Orange and Rockland Utilities, Inc.; Central Hudson Gas and Electric Corporation; and Power 15 Authority of the State of New York. June 1978. ADAMS Accession No. ML083420045.

16 Texas Instruments Inc. (TI). 1979. 1976 Year Class Report for the Multiplant Impact Study of 17 the Hudson River Estuary. Prepared for Consolidated Edison Company of New York, Inc.;

18 Orange and Rockland Utilities, Inc.; Central Hudson Gas and Electric Corporation; and Power 19 Authority of the State of New York. May 1979. ADAMS Accession No. ML083420045.

20 Texas Instruments Inc. (TI). 1980. 1977 Year Class Report for the Multiplant Impact Study of 21 the Hudson River Estuary. Prepared for Consolidated Edison Company of New York, Inc.;

22 Orange and Rockland Utilities, Inc.; Central Hudson Gas and Electric Corporation; and Power 23 Authority of the State of New York. July 1980. ADAMS Accession No. ML083420045.

24 Texas Instruments Inc. (TI). 1980. 1978 Year Class Report for the Multiplant Impact Study of 25 the Hudson River Estuary. Prepared for Consolidated Edison Company of New York, Inc.;

26 Orange and Rockland Utilities, Inc.; Central Hudson Gas and Electric Corporation; and Power 27 Authority of the State of New York. September 1980. ADAMS Accession No. ML083420045.

28 Texas Instruments Inc. (TI). 1981. 1979 Year Class Report for the Multiplant Impact Study of 29 the Hudson River Estuary. Prepared for Consolidated Edison Company of New York, Inc.;

30 Orange and Rockland Utilities, Inc.; Central Hudson Gas and Electric Corporation; and Power 31 Authority of the State of New York. March 1981. ADAMS Accession No. ML083420045.

32 Versar, Inc. (Versar). 1987. 1985 Year Class Report for the Hudson River Estuary Monitoring 33 Program. Prepared for Consolidated Edison Company of New York, Inc.; Orange and Rockland 34 Utilities, Inc.; Central Hudson Gas and Electric Corporation; New York Power Authority; and 35 Niagara Mohawk Power Corporation. October 1987. ADAMS Accession No. ML083420045.

Draft NUREG-1437, Supplement 38 I-70 December 2008

NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER (9-2004) (Assigned by NRC, Add Vol., Supp., Rev.,

NRCMD 3.7 and Addendum Numbers, if any.)

BIBLIOGRAPHIC DATA SHEET NUREG-1437, Supplement 38, (See instructions on the reverse)

Vol. 2

2. TITLE AND SUBTITLE 3. DATE REPORT PUBLISHED Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS) MONTH YEAR Supplement 38 Regarding Indian Point Nuclear Generating Unit Numbers 2 and 3 December 2008 Draft Report for Comment 4. FIN OR GRANT NUMBER Appendices

5. AUTHOR(S) 6. TYPE OF REPORT See Appendix B of this Report Technical

7. PERIOD COVERED (Inclusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address; if contractor, provide name and mailing address.)

Division of License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, type "Same as above"; if contractor, provide NRC Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address.)

Same as 8 Above

10. SUPPLEMENTARY NOTES Docket Nos. 05000247 and 05000286

11. ABSTRACT (200 words or less)

This supplemental environmental impact statement (SEIS) has been prepared in response to an application submitted by Entergy Nuclear Operations, Inc. (Entergy), Entergy Nuclear Indian Point 2, LLC, and Entergy Nuclear Indian Point 3, LLC (all applicants will be jointly referred to as Entergy) to the NRC to renew the operating licenses for Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3) for an additional 20 years under 10 CFR Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants." This draft SEIS contains the NRC staff's analysis that considers and weighs the environmental impacts of the proposed action, the environmental impacts of alternatives to the proposed action, and mitigation measures available for reducing or avoiding adverse impacts. It also includes the NRC staff's preliminary recommendation regarding the proposed action.

The NRC staff's preliminary recommendation is that the Commission determine that the adverse environmental impacts of license renewal for IP2 and IP3 are not so great that preserving the option of license renewal for energy planning decisionmakers would be unreasonable. This recommendation is based on (1) the analysis and findings in the GEIS, (2) the environmental report submitted by Entergy, (3) consultation with other Federal, State, and Local agencies; (4) the NRC staff's own independent review, and (5) the NRC staff's consideration of public comments received during the scoping process.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.) 13. AVAILABILITY STATEMENT Indian Point Nuclear Generating Unit Numbers 2 and 3 unlimited

14. SECURITY CLASSIFICATION IP2 IP3 (This Page)

IPEC unclassified Supplement to the Generic Environmental Impact Statement (This Report)

DSEIS unclassified National Environmental Policy Act NEPA 15. NUMBER OF PAGES License Renewal GEIS 16. PRICE NUREG-1437, Supplement 38 NRC FORM 335 (9-2004) PRINTED ON RECYCLED PAPER