ML101440286

Salem, Units 1 & 2 and Hope Creek, Unit 1 - Response to NRC Request for Additional Information Dated 04/16/2010 Related to the Environmental Review, License Renewal Application, Ecology, Appendix F, Attachment 5

ML101440286
Person / Time
Site:	Salem, Hope Creek
Issue date:	04/29/2010
From:	Public Service Enterprise Group
To:	Office of Nuclear Reactor Regulation
References
LR-N10-0152, NJ0005622, FOIA/PA-2011-0113
Download: ML101440286 (375)

Text

{{#Wiki_filter:PSE&G Pnim \pplication 4 Match I9Q9 Appendix F Attachment 5 APPENDIX F, ATTACHMENT 5-SEASONAL FLOW REDUCTION SPONSORED BY: JAMES M. NICHOLSON STONE & WEBSTER ENGINEERING CORPORATION PSE&G RENEWAL APPLICATION SALEM GENERATING STATION PERMIT NO. NJ0005622 4 MARCH 1999 S TABLE OF CONTENTS P-AGE 1. NTRODUCTION ............................................................... ............ .. If. CONDITIONS AFFECTING SEASONAL FLOW REDUCTIONS ....................... 4 A. PHYSICAL CON-DITIONS .............................................................................................. 4B .H Y D RA U L IC C O N D IT IO N S ............................................................................................... 5 C. THERMAL PERFORMANCE ......................................................................................... 7 D. STATION CONSIDERATIONS .................................................................................... 8 III, ANALYSIS OF OPERATIONAL METHODS TO ACHIEVE SEASONAL FLOW R E D U C T IO N S ................................................................................................................................ 8 A. REDUCING THE NUMBER OF OPERATING CIRCULATORS ...................................... 8 B. THROTTLING THE CIRCULATOR DISCHARGE FLOW ................................................ 9 C. OPENING CIRCULATOR BYPASS LINES .................................................................. 9 D. COMBINATION OF THROTTLING AND BYPASSING .......................................... 10 E. REGULATING ELECTRICAL OUTPUT ..................................................................... 10 IV. ANALYSIS OF DESIGN MODIFICATIONS TO ACHIEVE SEASONAL FLOW R E D U C T IO N S .............................................................................................................................. I I A. VARIABLE SPEED CIRCULATORS ........................................................................................... 1 1 B .T W O SPEED C IRC ULA TO RS .................................................................................................... 1 C .T w o P A SS C O N D EN SER ......................................................................................................... 1 I D .H ELPER T O W ER ..................................................................................................................... 12 V. MODIFICATION COSTS ................................................................................................ 13 A. REDUCING NUMBER OF OPERATING CIRCULATORS ...................................... 13B. THROTTLING CIRCULATORS .............................................................................................. 14 C. OPENING CIRCULATING WATER PUMP BYPASS LINES ...................................... ......... 14 D. COMBINATION OF THROTTLING AND BYPASSING ............................................................. 14 E. REGULATION OF THERMAL ELEVATIONS ......................................... 14 F. VARIABLE SPEED CIRCULATORS ...................................................................... 14 G. Two SPEED CIRCULATORS ................................................... 14 H .T w o PASS C OND EN SER ......................................................................................................... 14 I. HELPER TOWER ............................................... ........ I .............................. 14 VI. PERFORMANCE IMPACTS ............................................................................................... is A .PO W ER RE D UCTIO N ............................................................................................................... t5 B. PERFORMANCE REDUCTION .............................................................................................. 16 C .L O ST R E V EN U ES .................................................................................................................... 16 VII. MAINTENANCE IMPACTS .......................................................................................... 16 A .IN C REA SED FO U LIN G ............................................................................................................. 16 B .P u m p F A T IG U E ...................................................................................................................... 16 S'i r:i2 ':: \ : :s .7,'C. INCREI-\SED MONITORING .1.D. POTENTIAL CIRCULLATING WATER PIPING FAILURE ..................................... 6..... l V IIl. O P E R A T IO N S IM P A C T S ................................................................................................... 16 A .E FFIC IE N C Y ......................................................................... .. ............................ 17 B .D ISC H A R G E ............................................................. ..................................... 17 C. INCREASED PROCEDURES/MANNING ................................................................................ 1 7 D .T U RBIN E B YP.ASS ............................................................................................. ...... 17 E. OPERATING OUTSIDE DESIGN ........................ .................... .............................. 17 R e fe re n c e s ................................ ...................................................................................................... is TABLES T ABLE I C W S FLOW T RANSIT T IM E .............................................................................................. TABLE 2 HEAT BALANCE RESULTS............................................................................................ TABLE 3 POWER REDUCTION PENALTIES ...................................................................................... TABLE 4 "ORDER OF MAGNITUDE" COST ESTIMATE FOR INSTALLING VARIABLE SPEED C IR C U LA T O R S ................................................................................................................................. TABLE 5 COST ESTIMATE FOR INSTALLING A Two PASS CONDENSER ............................................ TABLE 6 COST ESTIMATE ASSOCIATED WITH CLOSED-CYCLE COOLING..: .................................... F IG U R E S ...........................................................................................................................................

1. Existing C irculating W ater System .............................................................................................

2. Circulating Water Intake Structure............................................

3. Circulating Water Pump Performance Curve ...........................................

4. Typical Main Condenser Backpressure Correction Curve ...........................................................

5. Typical Pressure/Temperature/Time Profile ...............................................................................

6. Main Condenser.Tube Rise vs. Flow ............................................................

..................

7. Main Condenser Outlet Temperature and Turbine Backpressure vs. Flow .................................

8. Effect of CWS Temperature

& Flow Variations on Generator Output .......................................

9. Variable Speed Drive Building Location Drawing ..............

.........................................

10. Helper Tower Independent Waterbox ..........................................................................................

iI. Simplified Flow Diagram Helper Tower ....................................................................................

12. H elper Tow er Location D raw ing .................................................................................................

2 7.-: d ' } ::" \, v. ." I. INTRODUCTION Salem Generating Station's (Salem or the Station) circulating water system, including its cooling water intake structure (CWIS). condensers and piping, was designed and constructed to operate with once through cooling water. Salem was designed to operate at a continuous 100% power level referred to as a "base load unit". The design goal was to provide an efficient water system while minimizing effects on the fish and other aquatic organisms of the Delaware Estuary.Throughout the years. Public Service Electric and Gas Company (PSE&G) has reviewed advances in cooling water intake systems and intake technology.and, when practical, has implemented additional fish protection options to further reduce the effects on the fish and other aquatic organisms. Flow reduction alternatives, such as seasonal flow reductions and closed-cycle cooling, have also been extensively evaluated. These evaluations concluded that retrofitting closed-cycle cooling or implementing seasonal flow reductions would be very costly and would result in decreased station performance. Retrofitting of a closed-cycle cooling water system is addressed separately in Appendix F, Attachment 7, Closed-Cycle Cooling.This attachment addresses seasonal flow reduction alternatives. The objective of any seasonal flow reduction is to reduce the circulating water intake volume and velocity, thereby reducing the number of organisms that become impinged or entrained. The flow reductions considered were 10, 20 and 45 percent of the current circulating water system operating flow rate of 1,050,000 gpm.This range was selected to establish the relationship between the effect of flow reduction on 'ration output and the reduction in mortalities of aquatic organisms. As discussed in F-IX, greater flow reductions result in greater reductions in fish mortality but increased replacement power costs.Moreover, the ratio of mortality reductions to replacement power costs increases with reduction in flow.Flow reduction methods considered in this attachment fall into two major categories: (1) system operational changes that could be implemented without major retrofits and/or replacement of any key circulating water system components, and (2) system design modifications that would require major changes to the system. Listed below, by category, are the specific options that are addressed in this attachment. Changes in the system operations that were considered include:* reducing the number of circulators which would require taking the respective condenser waterboxes out of service, since each circulator discharges directly through a separate waterbox;o throttling circulator flow which would require throttling the motor-operated valve downstream of the condenser which would increase system resistance, and would reduce the circulator flow rate;" opening circulator bypass lines which would reduce the flow into the Station by diverting a portion of the flow to the intake bay;3 N- :: \.* p > .it,* combining throttling the circulators and opening the b\pass lines which would reduce flow to the station: and* regulating electrical output which would result in a reduction of steam flow thereby allowing a reduction in circulator water flow.System design modification that were considered include:* installing two-pass condensers which would require replacing the existing single pass condenser tube bundles with a modular two-pass two bundle condenser which would reduce flow but .increase circulating water system discharge temperatures;" installing partial closed-cycle cooling with helper towers which would reduce the amount of intake flow;* installing dual speed circulators; and* installing variable speed drive controls*The latter two system design modifications would require replacing motors and/or drive controls.thereby allowing the circulators to operate at different flow rates.The potential biological benefit achievable with these types of fish protection options depends on being able to implement the flow reductions at a biologically significant period. Based on a review of relevant biological data, PSE&G determined June and July are the periods of peak biological activity in the Estuary. Given that Salem operates on an eighteen month fuel cycle, outages would have to be scheduled for summer and winter. These outage periods would coincide with periods of peak electrical demand. The timing of the.flow reduction periods and the environmental benefits associated with those reductions are also discussed in Appendix F-VIII and JX.This Attachment evaluates the engineering feasibility and costs of these flow reduction alternatives. Engineering feasibility includes an alternative's practicality, compatibility with other Station systems, its ability to provide safe and reliable operation, and its reasonable maintenance characteristics. II. CONDITIONS AFFECTING SEASONAL FLOW REDUCTIONS A. PHYSICAL CONDITIONS The circulating water system was one of the first systems designed and constructed at Salem. The majority of the circulating water system piping is buried, and most of the Station systems and structures are built over and around it; any modifications would therefore be a costly and complex engineering effort.The Station circulating water system is described in detail in Appendix B. In summary, the intake for the circulat-ing water system is located at the riverfront on the eastern shore of the Delaware Estuary. The intake is located approximately 850 ft. and 1400 ft. from the Unit I and Unit 2 turbine buildings and their associated condensers. Each of the two generating units has six intake bays, each approximately 11 ft (3.4 m) wide and 50 ft (15 m) high. Each bay is dedicated to a 34 circulator that pumps water through its individual 7-ft (2.1 m) diameter buried concrete pipe to its individual condenser waterbox (F-5 Figure 1). Immediately ahead of each of the six inlet water boxes the water passes through an 84 by 108 inch diameter transition piece and a 108 inch diameter exrmsion joint. The water passes through the 1 inch OD by 22 BW\G 45 foot long condenser tubes at ... average velocity of 8 fps, then the six waterboxes are paired into three interconnected sections of the condenser (or shells). In each section. the circulating water flows through the condenser tubes vhhile the steam exhaust from the low-pressure turbines is condensed on the outside of the tubes. After exiting the condenser, the warmed circulating water flows through a 90 inch diameter expansion joint, a 90 by 84 inch reducing elbow, and an 84 inch ON-OFF butterfly valve and then through six discharge pipes 84 inches in diameter each that merge into three 120 in internal diameter concrete discharge pipes. These buried pipes return the circulating water to the Delaware River at a point approximately 500 ft offshore at a submerged elevation of 58'-2" Public Service Datum (PSD) (approximately 30 ft below the surface at mean low tide). The discharge pipes are designed to maintain discharge velocity at 10.5 feet per second. The discharge velocity, location and arrangement have been designed to minimize the degree of thermal recirculation back into the intake, and to promote rapid mixing of the heated discharge with the water in the river to minimize the thermal plume area in the river.Any reduction in discharge velocity would have a serious impact on the discharge plume. The major impact of the reduction in flow rate will be an increase in the AT associated with the Salem discharge. Increase in AT could be detrimental to the need to be protective of the Balanced Indigenous Population of the Estuary. For any seasonal flow reduction alternative, flow measurement and monitoring of individual circulators would be necessary to set and control the flow to the circulators to ensure that the overall system flow rate is maintained. However, direct measurement of Station flow rate in the intake or discharge pipes is a difficult technical challenge and one which often results in relatively large errors (a 5-10% normal expected error). Sinceeach condenser is served by three 10-ft diameter discharge pipes direct measurement would require the examination of six pipes, increasing the level of effort without any certaintude of a dramatic improvement in the quality of the data.Any attempt to obtain accurate and repeatable flow measurement would typically require a total of 10 diameters of straight piping. Salem's circulating water intake piping is 7 feet in diameter, thus requiring 70 feet of straight pipe for monitoring purposes; the 10-ft diameter discharge piping would require 100 feet of straight pipe. Because the majority of the system's piping is buried, the current pipe routing does not have the accessible straight runs required to provide the proper measurement of the flow.B. HYDRAULIC CONDITIONS The CWIS is designed to operate at river levels ranging between El. 81.0 feet and El. 100.5 feet PSD. Public Service Datum is an arbitrarily assigned scale where Station grade is set at El. 100.0 feet PSD. River levels in relation to PSD are: High high-water El. 97.5 ft PSD Mean high tide El. 92.2 ft PSD Mean tide and mean sea level El. 89.3 ft PSD 5 Mean low tide El. 86.4 ft PSD Low low-water El. 81.0 ft PSD Design low water El. 76.0 ft PSD The circulating water system for each Salem unit includes six vertical, wet-pit, axial flow 84 inch diameter circulators or circulating pumps, located in the CWIS (F-5 Figure 2). Each pump is located in an individual bay (wet-pit) behind the traveling screens to minimize pump-to-pump hydraulic interactions. The individual bays can be isolated and drained for maintenance. As indicated on the pump performance curve (F-5 Figure 3), each pump is rated at 185.000 gpm at 27 feet total developed head (TDH). However, because of system losses associated with the piping configuration and pipe friction, the nominal flow rate for each pump is 175,000 gpm for a total unit operating flow rate of 1,050,000 gpm. This flow is also the current NJPDES Permit limit. The type of circulators installed at Salem have an area of instability between a flow of 80,000 gpm to 120,000 gpm. Operation at these lower flow rates is not recommended by the pump manufacturer and could lead to premature pump failure due to excessive pump vibration. The flow rate in the circulating water system is based on removing waste heat from the condenserat a sufficient rate to maintain condenser shell side vacuum at no less than approximately

1.3 inches

of Hg absolute pressure at full turbine load. (F-5 Figure 4).The main condenser is designed to remove 7.7x 10 9 BTU/hr of waste heat and dissipate that heat to the environment at a sufficient rate to maximize station efficiency. To accomplish this designfunction, the circulators must deliver the required flow for a given river water temperature and condenser cleanliness. For example, at the condenser design inlet temperature of 61.8°F and cleanliness factor 77.5% a circulating water flow of 1,110,000 gpm per unit is required.The transit time is a function of the CWS flow rate and the length of the path traveled. The cleanliness of the system and the number of pumps operating per loop influence the flow rate. The transit time in a given CWS loop can vary from a minimum of 3.7 minutes for the shortest loop(Salem Unit 1, Loop 13B), with both pumps operating in that loop, to a maximum of approximately

7.8 minutes

for the longest loop (Salem Unit 2 Loop 23B), with only one pump operating in that loop (F-5 Table 1).The average transit times for Salem Unit 1 and 2 with a circulator flow of 175,000 gpm and all 6 pumps in each unit operating are 3.9 minutes and 5.1 minutes, respectively. The transit time is important because the longer the transit time, the longer organisms entrained in the circulating water system will be subjected to the pressure and temperature conditions of the system.Debris in the form of sand and silt which passes through the traveling water screens will typically remain in solution if circulatory water system velocity is maintained at 8 ft/sec or greater (Mark's Standard Handbook for Mechanical Engineers, Ninth Edition, 1987). However, over time, some debris will collect in the condenser resulting in a higher-pressure drop throughout the system and causing the pump to run at a higher pressure, resulting in a reduced flow through the pump which affects condenser performance. During these periods when the flow drops below optimum levels, the associated pump will be shut down and the waterbox isolated, drained and cleaned. Any 86 decreases in system velocity would increase the rate at w\hich debris settles out and consequently increase the frequency of cleaning.C. THERMAL PERFORMANCE Each reactor is designed to operate at the licensed thermal power of 3,411 megawatts thermal (MWt) or a Nuclear Steam Supply System (NSSS) power level of 3,423 MWt. which includes reactor coolant pump heat. The turbine generators are rated at a gross electrical output of 1162 megawatts electric (MWe), resulting in a design energy transfer to the circulating water system of 7.7 x I0'BTUihr. This value may vary by approximately 10 percent with variations in operatingefficiency, river temperature, condenser backpressure, or flow rate degradation. At a circulating water inlet temperature of 60'F and a normal system flow of 1,050,000 gpm or 175,000 gpm per circulator, this load results in a circulating water temperature increase of approximately 157F.Other heat loads discharging through the circulating water discharge paths, such as service water, are minor in comparison to the condenser heat load and have negligible impacts on the discharge temperature. The performance of the condensers in accomplishing cooling of the turbine exhaust steam depends on the volume of circulating water flow and the initial temperature of the circulating water (which varies with river water temperature). The need to maintain the turbine backpressure or condenser vacuum (i.e., the pressure of the turbine exhaust steam inside the condenser shell) within the operational range of the turbines is critical to Station operation. Turbine performance is dependent upon condenser performance, which is affected by turbine backpressure. An increase in turbine backpressure results in a decrease in turbine efficiency and electrical output from the generators (F-5 Figure 4).Temperature and flow are complimentary elements of the circulating water system. The Salem Units are operated as base loaded units at full power operation; consequently the amount of heatrejected into the cooling water is essentially constant. Therefore, as the flow through the.condensers either increases or decreases, the temperature differential (AT) between the water entering the circulating water system and the water discharged from the circulating water system will either decrease or increase accordingly. For instance, when the condenser tubes become plugged with debris that passes through the screens, flow is impeded, resulting in an increase in the AT.Because of the interaction between flow and AT, an analysis was conducted to determine the effects of flow reduction under two different assumptions: (1) allowing AT to vary with flow, up to a limit of 27' F, and (2) holding A T constant at 15' F by reducing power levels to minimize increases in entrainment losses from increased temperature. F-5 Table 2 and F-5 Figures 5 through 8 show the effects of CWS flow on Station performance, AT, turbine backpressure, and discharge temperature (Stone and Webster Letter, PS-93-351. Dated January 18, 1991).These analyses show that Station performance and electrical output are directly affected by the temperature and flow rate of the circulating water system. The greatest impact to PSE&G, its customers, and PJM members of implementing seasonal flow reductions would occur during the ,2 N : "" summer months, when electrical demand is at its peak. This is because the cost of replaccment power, due to demand, is also at a peak.The circulating water system flow is particularly critical to electrical output during the summer when peak electrical demand occurs simultaneously with high ambient Delaware River water temperatures. With high ambient water temperatures, a reduction in circulating water flov. reduces the thermal capacity of the condenser, decreasing turbine efficiency and electrical output. A flow reduction increases the turbine backpressure to its operating limit which in turn requires the Station to reduce electrical output to maintain the turbine backpressure within the operating range. In addition, flow reduction results in increases in the AT and absolute temperature of the discharge water.During the summer, any incremental increase in discharge water temperature due to flow reduction would result in maximum discharge water temperatures that exceed levels currently specified by the Permit. To prevent such increases in discharge water temperature, Station power levels would have to be reduced. Thus, the flow reduction would result in a Station derating at peak summer electrical load periods. The lost capacity at the Station would have to be replaced by other sources that have their own environmental effects.D. STATION CONSIDERATIONS Implementation of seasonal flow reductions would impact Station operations. Construction activities could require shutdown of the units. Some technologies would require additional power to operate. All of the technologies would require additional, training of personnel, revision -o Station procedures, and increased man hours to perform additional routine inspection and maintenance activities. III. ANALYSIS OF OPERATIONAL METHODS TO ACHIEVE SEASONAL FLOW REDUCTIONS A. REDUCING THE NUMBER OF OPERATING CIRCULATORS Limiting the number of circulators in operation to reduce flow would require taking the respective unit condenser waterboxes out of service, since each circulator discharges directly through separate waterboxes. Operating with more than one circulator/waterbox out of service or operating with one out of service for an extended time would result in an increased condenser load because of the increase in turbine back pressure resulting in reduced efficiency. This condition is currently addressed in Salem operating procedures, which treat this operating condition as a malfunction.(Units 1 and 2 S 1/S2.OP- AB.CW-000 I[Q], Circulating Water System Malfunction). Taking a unit condenser waterbox out of service to achieve seasonable flow reductions would create the potential for two circulators to be out of service. The Station already operates for short periods with one circulator-and its associated waterbox out of service whenever a waterbox is fouled and requires cleaning, a process that can normally be accomplished in an eight-hour shift. If an additional unit condenser were out of service to achieve flow reductions, there would be two pumps off, one pump off in support of reduced flow and the additional pump off to support the* waterbox cleaning. Salem operating procedures consider this situation a circulating water systemmalfunction requiring compensatory operator actions. Specifically. Station operators are required.depending on Station conditions, to perform actions ranging from reducing electrical output until the 5ýh pump is restored, to tripping the reactor. Therefore, operating in this configuration would not provide the Station with a sufficient operating margin to overcome Station transients, and would result in additional stresses on Station equipment and systems and possibly jeopardize Station safety. Because flow reduction may be achieved through safer and more reliable means, this alternative is not recommended for further consideration. B. THROTTLING THE CIRCULATOR DISCHARGE FLOW Circulating water pump flow can be reduced by throttling the motor- operated valve downstream of the condenser, increasing the system resistance and resulting in reduced pump flow.This option requires a physical modification to the circulating water system which would include changing the valve control scheme for each of the 12 valves from an on/off control to an on/offcontrol with throttle capability. A review of the pump curve (F-5 Figure 3) shows that throttling of the circulating water pumps beyond 75% of design flow (i.e., a 25 percent flow reduction) puts the pump operating point at the unstable region on the pump curve, limiting the pump's capability to substantially reduce circulating water system flow rate. Operating a pump at reduced levels will cause the pump to oscillate/vibrate, which can quickly result in pump damage or even failure. If the pumps were operated at the reduced flow, no margin would exist between the operating point and the unstable region. If fouling in the condenser were to increase, the pump could fail in arelatively short period of time. This would also result in increased pump and valve maintenance requirements due to the additional stress placed on these components. In addition, the pumphorsepower requirements increase would result in increased operating costs. Due to is limited flow reduction capability, this alternative is not recommended for future consideration. C. OPENING CIRCULATOR BYPASS LINES Each circulator has a 42 in diameter bypass line which could be used to bypass pump flow and reduce flow into the intake (F-5 Figure 2). The bypass line could be used to divert a portion of the flow back to the intake bay downstream of the intake screens to reduce the intake flow into the Station. The existing motor-operated valves in the bypass lines could be used to perform this function. Although this strategy would allow the circulators to operate near its current design point; the circulating water system flow would be decreased, allowing more sediment and debris to settle out in the piping and condensers because of the lower velocities, further impacting performance and increasing maintenance requirements. At a minimum, a modification to each of the 12 bypass valves would be required. The modification would include changing the valve control scheme for each of the 12 valves from an on/off control to an on/off control with throttle capability. The design capability of using the bypass lines and valves for long periods of time would have to be evaluated in detail.9 D. COMBINATION OF THROTTLING AND BYPASSING Although it would be undesirable from an engineering, system reliability, and operations standpoint, a combination of throttling the circulation and bypassing the circulation could be used to achieve reduced flow rates. However it would be very difficult to maintain control of the system flow rate without varyin g the flow rate of the circulator as the system tries to reach a stable point oh operation. In addition, due to the current piping configuration, installing a flow sensing element at a location where it would work properly would be difficult at best. When throttling andlor bypassing, the circulator horsepower requirements would remain the same or increase, resulting in increased operating costs to facilitate reduced flow.The system's ability to rapidly respond to Station upsets and transients would be greatly impaired.For example, during a loss of electrical load or a turbine trip, the Turbine Bypass System. upon.se.,ing the event, rapidly opens its dump valves to allow steam flow to reach the condenser. Theis condensed and returned to the steam generators while the Station safety systems gain control of the event and bring the Station to a safe shutdown condition. Further investigation is required to determine the impacts and limitations throttling and bypassing could have on the system and components. Therefore, this alternative is not recommended for further consideration. E. REGULATING ELECTRICAL OUTPUT Seasonal flow reductions could also be achieved operationally by curtailing operation of the Salem units in response to thermal elevations. This curtailment could range from operating at reduced power to shutting down the Station for a period of time. Operating at reduced power produces less steam and reduces the electrical output of the units. A reduction in steam flow would permit the circulating water system flow rate to be reduced, by one of the concepts discussed above, to maintain the condenser vacuum within prescribed limits. If the discharge temperature approaches the Permit limits, the reactor power could be further reduced to maintain operation within those limits.As previously noted, the Salem units are designed to operate continuously at the licensed power rating of 3423 MWe as baseloaded electrical generating units. Therefore, the operation of Salem atlower power levels would place additional stress on other Station systems, which could cause premature component failure and result in a forced outage or trip. Tripping of the unit in this fashion would unnecessarily challenge the Station safety systems. Nuclear plants by the way of their design and controls require days to weeks in order to safely shutdown and then restart. Operation at reduced power for extended periods of time may require prior Nuclear Regulatory Commission (NRC) approval. Therefore, because of the operational and safety issues, this alternative is not recommended for further consideration. 8 10 IV. ANALYSIS OF DESIGN MODIFICATIONS TO ACHIEVE SEASONAL FLOW REDUCTIONS A. Variable Speed Circulators Installation of variable frequency drive (VFD) controls for each existing circulator would allow .ic pumps to be operated at a reduced flow during periods of high impingement and/or entrainment.The lower pumping capacity would also allow for a lower approach velocity at the traveling screens.This alternative, originally evaluated in 1988 (Stone & Webster letter dated May 6, 1988). would use a General Electric GTO induction motor drive, an adjustable speed control system that uses solid-state, gate turnoff thyristors to control the circulator motor speed. With this technology it would be possible to vary the frequency of the motor from 60Hz to 6Hz to control the motor speed.A reduction in motor speed results in a corresponding reduction of pump flow. Operation at the slowest speed corresponds to a 45 percent reduction in flow providing a minimum flow capacity for each pump of 92,500 gpm. The variable speed drives would be housed in a new enclosure, directly connected between the existing motors and power supply. The location of the new enclosure building for this alternative is shown in F-5 Figure 9. Due to the age of the existing motors, new motors would be required.The original cost estimate to retrofit variable speed circulators at Salem has been updated for this submittal, and is estimated to be approximately $10,700,000. As with any alternative that reduces the circulating water system flow rate, there would be a reduction of Station electrical output during the summer months when power demand is highest and replacement power is most costly.B. Two Speed CirculatorsInstalling two speed circulators would require replacing the existing circulator motors and changing the circulators' logic and control circuits. Because the River temperature varies over the course of the year, finding and operating at an effective single lower pump speed could potentially reduce Station output when the reduction in flow is not matched to the River temperatures and operating conditions. This would result in the Station not operating at its maximum output for a given River water temperature. Therefore, this option provides less operating flexibility and is thus less desirable than the variable speed circulators described above.C. Two Pass Condenser Another means of reducing flow would be using a two-pass condenser. This option would require replacing the existing single pass condenser tube bundles with a modular two-pass tube bundle design. A two-pass design arrangement would require less flow than a single pass design but would restlt in a higher discharge temperature. It also would create higher pressure drops across the condenser tube bundles, potentially requiring the circulator to be replaced and increasing the cost of the alternative. Replacing the pumps would increase the system operating pressure, which in turn would require the system piping to be upgraded to accommodate the high operating I I pressures. There is over 3,000 feet of existing 7 ft. cooling water inlet piping located east of and under portions of the Turbine and Administrative buildings. Because this pipe is embedded within the turbine foundation, pipe replacement would be very expensive and time consuming, impacting both project cost and outage duration. To reuse the existing piping, extensive reinforcing would be necessary to accommodate the much higher pressures associated with a two-pass system. This would require an outage for welding in and grouting a corrosion-resistant steel liner inside these 7-ft diameter steel reinforced concrete pipes. Although this alternative would be less difficult and costly than replacing the piping, it is still very labor-intensive, time-consuming, and costly. As this alternative is more complex to design and install than the variable speed circulators discussed above, it is not recommended for further consideration. D. Helper Tower A helper tower system would withdraw a portion of the circulating water system condenser outlet water and direct it to a cooling tower, typically a mechanical draft type tower. Cooled water from the tower(s) would be returned to the circulating water system, where it mixes with the outlet flow.(See Appendix F, Attachment 7 for discussion on cooling tower design).An engineering evaluation (Stone & Webster letter, PS-91-T-500) was performed in order to determine the feasibility, benefits, and order-of-magnitude cost estimate for retrofitting a helper tower at Salem. To the maximum extent possible, a helper tower needs to be compatible with existing circulating water system performance and condenser and circulating water piping design.Because the Salem cooling water system contains no open channel flow, or adequate open spaceavailable near the existing circulating water system to accommodate it, a hard-piped system would be required. Based on the existing circulating water piping layout, the most practical and cost-effective helper tower system would be one that is connected to Unit 2. This would be in the form of an independent waterbox design (F-5 Figures 10 and 11).Implementation of an independent waterbox design would require the following modifications: A 280-fl diameter, counterflow, round concrete multi-fan mechanical draft cooling tower 65 feet high with 18 large diameter fans of 200 brake horsepower each would be installed. The tower's design point would be a 130 F range with an 8' F approach at a 780 F wet bulb temperature. This design would allow the cooling tower to meet the heat load requirements imposed upon the other condensers. The tower system would be located about 1,000 feet east of the switch yard between the transmission lines as shown on F-5 Figure 12.The tower system would include:* two 50 percent capacity cooling water pumps with a combined capacity of 2 10,000 gpm;* the addition of makeup, blowdown, and chemical treatment systems;* 4,000 feet of 96-inch diameter concrete cylinder piping to/from the cooling tower to condenser waterbox 23B with a single trench for the supply and return piping;0 an average of 6,500 gpm of cooling tower makeup from the river to make up for the 4,300 gpm blowdown and 2,200 gpm cooling water evaporation;

• 12
• miscellaneous piping for makeup. blowdown, chemical treatment.

etc.:* pilings for cooling tower structure. pump strcture. circulating water piping, and thrust blocks: and" associated electrical and controls systems.The waterboxes and tube bundle 23B would be subjected to 55 psig hydraulic pressure due to the modification from a once-through to a closed cooling cycle. The existing waterboxes were designed for 17 psig. Also, the water velocity through the condenser tubes would be increased to 8.4 fps. These changes would require several sections of pipe bracing across the span of the waterbox and the addition of a large number of heavy longitudinal support members at the periphery of tube bundle 23B on the condenser steam side.Other Station impacts include the following: " an increased auxiliary load of 6 MW due to the cooling tower fans and pumps;* additional maintenance, inspection, and operation of related mechanical equipment;

• a new chemical treatment system for treating the cooling tower water with associated costs and personnel requirements; and" relocation of existing facilities and added security measures.Retrofit of this type of alternative would be difficult and costly.The difference between the temperature of the cooled water discharged from a cooling tower and the ambient air wet bulb temperature is called the cooling tower "approach." The approach that is actually attainable at a particular installation depends on the type and size of the cooling tower, the quantity of water flow to be cooled and the change in water temperature to be achieved through cooling, and the local wet bulb temperature.

The wet bulb temperature is the lowest temperature atwhich evaporation can occur for the specific conditions of the atmosphere. All of the approachfactors, except those related to climate (i.e., local wet bulb temperature), are essentially fixed.Since climatic factors are outside an operator's control, an approach temperature can only be used by engineers as a design criterion, and cannot be applied as an operating requirement. Accordingly, because of differences in temperature between the river temperature and the ambient air wet bulb temperature, a helper tower's ability to achieve seasonal flow reductions cannot be assured.V. MODIFICATION COSTSThis section establishes the modification costs for the alternatives discussed above. For some alternatives that were not recommended for further consideration a cost estimate has not been provided.A. Reducing Number of Operating Circulators Not recommended for further consideration. 13 .1\l.2rcbli~L' B. Throttling Circulators This modification would include changing the valve control scheme for each of the 12 valves from on off control to on/off with throttle capability. This alternative would also require changes to station operating procedures and additional operating changes. The estimated order of magnitude cost to design and install the modifications, and to provide additional training is approximately S 500,000 for each unit, for a total of S 1,000,000. C. Opening Circulating Water Pump Bypass Lines The modifications required for this alternative are similar to the throttling of the circulating water flow. The estimated order of magnitude cost for each unit is S500,000 for each unit, for a total of$1,000,000. D. Combination of Throttling and Bypassing The estimated order of magnitude cost for this alternative is 31,000,000. E. Regulation of Thermal Elevations No physical station modifications are necessary to implement this alternative. Costs are limited to training, procedure changes, and increased maintenance issues. The estimated order of magnitude cost for this alternative is approximately $75,000.F. Variable Speed Circulators The 1988 order of magnitude cost estimate to retrofit variable frequency drives including new motors and a new building to house the equipment was updated for 1998 as provided in F-5 Table 4.G. Two Speed Circulators Although this option is not considered further, the cost to implement two speed circulator controls would be about the same as the variable speed option.H. Two Pass Condenser This modification includes the installation of new tube bundles, pumps, and 3,000 feet of concrete piping. The budgetary capital cost of this option is $123,429,000; component costs are presented in F-5 Table 5.I. Helper Tower The total present day budgetary capital cost of this alternative is $36,000,000. F-6 Table 6 presents a detailed breakdown of this cost.14 VI. PERFORIMANCE IMPACTS Seasonal flow reductions could be accomplished by several means including both operational and design modifications, but would, at a minimum, result in the following impacts on performance. A. Power Reduction The Station power level would be reduced to maintain turbine backpressure to an acceptable level.During peak summer electrical demand periods, power production could be reduced by as much as 340 MW with a 45 percent flow restriction. There is a power reduction penalty associated with reduced flow. To determine the power reduction penalty, SWEC performed heat balance calculations at the following reduced circulating flows and the average .weekly summer and winter inlet temperatures. The evaluation assessed the impact of reducing circulating water flow up to approximately 45% of the NJPDES Permit flow limit. The evaluation reviewed the technical feasibility of alternatives to accomplish 45% flow reduction and determined the power reduction penalty as a result of the reduced flows. The circulating water operating flow rate per reactor unit is 1,050,000 gallons per minute (gpm) and 175,000 gpm per circulating water pump. The following reduced flow rates were reviewed: FLOW per PUMP FLOW per UNIT APPROX. FLOW REDUCTION175,000 gpm 1,050,000 gpm BASE 157,250 gpm 943,500 gpm 10%138,750 gpm 832,500 gpm 20%92,500 gpm 555,000 gpm 45%Where the results indicated that at a particular power level the circulating water temperature rise exceeded the NJPDES permit thermal discharge limits of 21.67F (from October through May) and 27.07F (from June through September), the reactor power was reduced to limit the temperature rise.In addition, if the condenser pressure exceeded the turbine backpressure limit, the reactor power was reduced. The heat balance calculations also incorporate the increased tube fouling that would occur as a result of the lower velocities at the reduced flow rates. The increased fouling was used in the determination of the tube cleanliness factors used in the heat balance calculations. The calculated power reduction penalties are summarized in F-5 Table 3 and listed in detail in F-5 Table 2.As seen in Tables 2 and 3, the power reduction penalties in the summer weeks will vary depending on inlet temperature but could range as high as 132 MWe with a temperature rise limited to 27.0°F, and 340 MWe with a temperature rise limited to 21.6'F. The largest power reduction penalty occurs due to limiting the temperature rise to 12'C (21.6°F) and reducing the circulating water flow by 45 percent of current permit flow rate. The NJPDES Permit flow maximum is 1,050,000 gpm per uhit(approx. 95 percent of design flow of 1,110,000 gpm) which represents a calculated power penalty as high as 3.65 Mwe 15 B. Performance Reduction Reduced flow velocities will result in an increase in condenser fouling. which in turn will impact plant performance, and could result in higher electrical output reductions than assessed above.C. Lost Revenues The reduction in power production and performance would result in a significant revenue loss toPSE&G which cannot be recaptured due to the fixed licensing record for a Nuclear Power Plant.Costs associated with this impact are discussed in Appendix F, Section LX.VII. MAINTENANCE IMPACTS Provided below is a discussion of the maintenance impacts that result from operating at a reduced flow. These impacts.are common to all reduced flow alternatives; however, the severity of the impact increases with greater flow reductions. A. Increased Fouling Reduction in circulating water inlet flow velocities would result in an increase in macrofouling of the condenser tubes. For example, if condenser tube velocity is reduced to below 3 ft/sec, fouling could be increased by a factor of two (Standards for Tubular Exchanger Manufacturer's Assoc., 1978). This would, in turn, result in increased maintenance costs for cleaning the condensers or require the installation of a continuous cleaning system (e.g., debris filters and condenser tube ball cleaning systems). Also, reduced flow would increase the ability of organisms to adhere to and grow in circulating water pipes, condenser tubes, and other system components, thus further hindering flow, decreasing condenser performance, potentially increasing corrosion rates, and requiring increased maintenance. B. Pump FatigueCirculating water pump operation at reduced flow rates may result in increased pump maintenance. Operation of these pumps at less than design capacities may result in increased fatigue and potential failure of the pumps, particularly at flows less than recommended by the manufacturer. C. Increased Monitoring Additional instrumentation will be necessary in order to monitor and maintain the reduced flows, as well as to prevent possible pump damage.D. Potential Circulating Water Piping Failure If flow reduction is achieved by throttling the condenser outlet valves or some other similar method, then a potential exists for premature failure of the circulating water piping at the higheroperating pressure. VIII. OPERATIONS IMPACTS Operations impacts are those impacts which affect the Station's ability to generate electricity safely and efficiently. A cost estimate for these impacts has not been developed; however, a qualitative discussion is provided below. 81 A. Efficiency A reduction in circulating water flow rate would reduce the capacity of the condenser, increase the backpressure, and in turn result in a turbine efficiency decrease and decrease in plant electricaloutput. During summer peak load periods (when Delaware River temperature is at its highest), an adequate circulating water flow rate is critical to maintaining electrical output and to ensuring an adequate cooling margin in the event of a plant load rejection or turbine trip.B. Discharge As discussed in Appendix B. both the circulating water and service water systems discharge through six 10-ft diameter pipes which extend 500 feet into the Estuary. The discharge pipes are designed to maintain discharge velocity at 10 feet per second. Any reduction in discharge velocity would have a serious impact on the temperature of the discharge plume. The major impact of the reduction in flow rate will be an increase in the AT associated with the discharge. Increase in AT could be detrimental to the need to be protective of the Balanced Indigenous Population of the Estuary.C. Increased Procedures/Manning Flow reduction requirements would increase the workload of the operating staff. New parameters would require monitoring, and new seasonal operating procedures would need to be developed andfollowed. This would result in added complexity of station operations, including emergencyresponse procedures to facilitate recovery from abnormal operating conditions. D. Turbine Bypass At reduced flow conditions, with the accompanying increase in backpressure, the ability of the condenser to absorb a turbine bypass would require analysis and possible modifications to the bypass valves and condenser. The condenser provides the needed cooling water to condense steam dumped via the turbine dump system. In the event adequate cooling water is not present, over-pressurization and possible failure of the condenser may result.E. Operating Outside Design The circulating water system including the circulator, condenser, and other piping components atSalem were designed, tested, and calibrated to operate at specific operating conditions. Reductions in flow would result in operating in an off-normal condition, increased equipment wear and fatigue failure, and lost efficiency. Operating equipment outside its intended design may lead to increased component aging and premature failure.17 "UM \i j'.;:ii\pDC!1d:X F References I. Units I and 2 Operating Procedures SI/S2.OP.AB.CW-OOOl(Q) Circulating Water System Malfunction

2. Stone & Webster Letter Dated May 6, 1988 Independent Economic Salem Analysis of Selected316(b) Alternatives.

3. Stone & Webster Letter PS-93-35 1, Dated October 18, 1993.4. Standards for Tubular Exchanger Manufacturers' Assoc., Sixth Ed. 1978.5. Marks' Standard Handbook for Mechanical Engineers, 91h Edition, 1987.6. Stone & Webster Letter, PS-91-T-500, Dated January 18, 1991.18 PSE&G Permit Application 4 March 1999 APt3endix F Attachmcnt 5 F TABLE 1 CWS FLOW TRANSIT TIME Unit Pump Path Length No. Pumps Flow Transit Time No. (feet) Operating (OEM) (min.)1 I3B River to Condenser Inlet 866 1 187.000 1.3 2 175.000 1.4 2 140.000 1.8 Condenser Inlet to Outlet 45 I 187,000 (0.01 -0.2 2 175,000 included in Outlet 2 140.000 to River)Condenser Outlet to 1297 1 187,000 4.2 River 1 175,000 4.5 I 140,000 5.6 Condenser Outlet to 1297 2 350.000 2.3 River 2 280,000 2.8 I IA River to Condenser Inlet 993 1 187.000 1.5 2 175,000 1.6 2 140,000 2.0 Condenser Inlet to Outlet 45 1 187,000 (0.01 -0.2 2 175,000 included in Outlet 2 140.000 to River)Condenser Outlet to 1414 1 187,000 4.6 River I 175,00H 4.9 I 140,000 6.1 Condenser Outlet to 1414 2 350,000 2.4 River 2 280.000 3.1 2 21A River to Condenser Inlet 1246 I 184,000 1.9 2 175,000 2.0 2 140,000 2.6 Condenser Inlet to Outlet 45 I 184,000 (0.01 -0.2 included 2 175,000 in Outlet to River)2 140,000 Condenser Outlet to 1618 1 184,000 5.3 River 1 175,000 5.6 1 140,000 7.0 Condenser Outlet to 1618 2 350,000 2.8 River 2 280,000 3.5 2 23B River to Condenser inlet 1413 1 184,000 2.2 2 175,000 2.3 2 140,000 2.9Condenser Inlet to Outlet 45 1 184,000 (0.01 -0.2 included 2 175,000 in Outlet to River)2 140,000 Condenser Outlet to 1726 1 184,000 5.6 River 1 175,000 5.9 I 140,000 7.4 Condenser Outlet to 1726 2 350,000 3.0 River 2 280,000 3.7 PSE&G Permit Appiicaion 4 March 19qQ Appendix F Artachment

_F-5 TABLE 2 HEAT BALANCE RESULTS Cooling System Performance at 3,423 MWt NSSS Power 175,000 gpm per cooling water pump CWIT Tube R CWOT Tsat Condensing Press Cond Duty NSSS MW Gen MW GHR-F C F C F C I F C inHaa aa Bt/hr BtuAkWh 35 2 15 8 50 10 73 23 0.8 0,4 7,68E+09 3423 1159 10078 40 4 15 8 55 13 76 24 0.9 0.4 7.68E+09 3423 1159 10075 45 7 15 8 60 15 79 26 1 0.5 7.68E+09 3423 1160 10072 50 10 15 8 65 18 83 28 1.1 0.6 7.68E+09 3423 1160 10068 55 13 15 8 70 21 87 30 1.3 0.6 7.68E+09 3423 1160 10067 60 16 15 8 75 24 90 32 1.4 0.7 7.68E1+09 3423 1160 10066 65 18 15 8 80 26 95 35 1.6 0.8 7.68E+09 3423 1160 10068 70 21 15 8 85 29 99 37 1.9 0.9 7.68E+09 3423 1159 1008175 24 15 8 90 32 103 40 2.1 1.1 7.70E+09 3423 1153 10126 80 27 15 8 95 35 108 42 2.5 1.2 7.73E+09 3423 1145 1019885 29 15 8 100 38 113 45 2.8 1.4 7.76E+09 3423 1135 10287 Cooling System Performance at 3.423 MWt NSSS Power 166,000 gpm per cooling water pump CWIT Tube R CWOT Tsat Condensing Press Cond Duty INSSS MW GenMW GHR F C I F C I F F C IF inHga psia IBtu/hr I I I Btu/kWh 35 2 15 9 50 10 74 23 0.8 0.4 7.68E+09 3423 1159 10077 40 4 15 9 55 13 77 25 0.9 0.5 7.68E+09 3423 1159 10074 45 7 15 9 60 16 80 27 1 0.5 7.68E+09 3423 1160 10071 50 '10 15 9 65 19 84 29 1.2 0.6 7.68E+09 3423 1160 10067 55 13 15 9 70 21 88 31 1.3 0.6 7.68E+09 3423 1160 10067 60 16 15 9 75 24 92 33 1.5 0.7 7.68E+09 3423 1160 10066 65 18 15 9 80 27 96 35 1.7 0.8 7.68E+09 3423 1160 10070 70 21 15 9 85 30 100 38 1.9 0.9 7.69E+09 3423 1158 10088 75 24 15 9 90 32 105 40 2.2 1.1 7.71E+09 3423 1152 10140 80 27 16 9 96 35 109 43 2.5 1.2 7.74E+09 3423 1143 1021685 29 16 9 101 38 114 46 2.9 1.4 7.77E+09 3423 1133 10309 Cooling System Performance at 3,423 MWt NSSS Power 140,000 gpm per cooling water pump CWIT Tube R I CWOT Tsat Condensing Press Cond Duty INSSS MW Gen MW GHR F .C I F C I F C I F C inHga psia Btu/hr I I Btu/kWh 35 2 40 4 45 7 50 10 55 13 60 16 65 18 70 21 75 24 80 27 85 29 18 18 18 18 18 18 18 18 18 18 19 10 53 12 78 26 1 10 58 15 81 27 1.1 10 63 17 84 29 1.2 10 68 20 88 31 1.3 10 73 23 91 33 1.5 10 78 26 95 35 1.7 10 83 28 99 37 1.9 10 88 31 104 40 2.2 10 93 34 108 42 .2.5 10 98 37 113 45 2.8 10 104 40 118 .48 3.2 0.5 7.68E+09 0.5 7.68E+09 0.6 7.68E+09 0.7 7.68E+09 0.7 7.68E+09 0.8 7.68E+09 0.9 7.68E+09 1.1 7.70E+09 1.2 7,73E+09 1.4 716E+09 1.6 7.80E+09 3423 3423 3423 3423 3423 3423 3423 3423 3423 3423 3423 1160 10073 1160 10070 1160 100681160 10067 1160 10066 1160 10069 1158 10083 1153 10128 1145 10197 1136 10285 1124 1038C Basis: Legend: 1 Unit thermal performance calculated using S&W program ME-141 (Salem).2 Condenser performance per HEI, *Standards for Steam Surface Condensers", 3 Steam turbine performance per original Westirghouse turbine thermal kit. (Not 4 No condenser tube plugging.5 Condenser cleanliness at 85%, constant.6 Steam generator pressure 805 psia, constant.7 Performance shown is based on Unit 1.1 CWIT -CW Inlet Temp.2 CWOT -CW Outlet temp. 3 Tsat -Condensate Saturated Tern 4 GHR -Gross Heat Rate 5 Tube R -Condenser Tube Temp.Notes: I Modifications have been made to the Units since the heat balance model was prepared. The net effect of these modifications was to improve the steam cycle efficiency while maintaining the licensed reactor power unchanged. Since the effect of increasing the efficiency is to increase the portion of the reactors thermal output which is converted into electrical energy. using the old plant model is conservative for outlet cooling water temperature purposes.I PSE&G Permit Application 4 March 1999 Appendix F Attachment 5 TABLE 3 POWER REDUCTION PENALTIES CW Flow (gpm)Winter 1,050,000 832,500 Summer 1,050,000 943,500 832,500 555,000 Flow Reduction %(1)CW Inlet Temp. 'F CW Temp. Power Rise 'F Penalty KW (2)0 20 0 10 20 45 35.3 35.7 66.2 82.7 66.2 82.7 66.2 82.7 66.2 82.7 66.2 82.7 14.6 18.5 14.6 14.8 16.3 16.5 18.5 18.8 21.6 21.6 27.0 27.0 0-469 0 0 2,521 9,525 9,640 21,745 309,733 341,478 92,549 132,670 RemarksBase Case Temperature rise limited to 21.6°F and 27.0°F Notes: I. The flow reduction is the percentage of the current operating flow (6 pumps x 175,000 gpm/pump) of 1,050,000 gpm.2. The power penalty is the output power reduction from the power produced at 1,050,000 gpm. PSE&G Permit Application 4 March 1999 Appendix F Attachment 5 SF-5 Table 4. "Order of Magnitude" Cost Estimate for Installing Variable Speed Circulators Item Estimated Cost Mobilization/Demobilization 565,000 Install New Pump Motors 5,652,000 Distributable Costs [11 833,000 Indirect Costs 121 705,000 PSE&G Costs (31 705,000 Allowance for lndeterrninates/Contingencies 2,240,000 Total Estimated Project Costs(1998 dollars) 10,700,000

1. distributable costs for site non-manual supervision, temporary facilities, equipment rental, and support services incurred during construction (assumed to be 85 percent of the labor portion ofthe direct costs)2. indirect costs are for labor and related expenses for engineering services to prepare drawings, specifications, and design documents (assumed to be 10 percent of the direct costs)3. PSE&G costs are for administration of project contracts and for engineering and construction management (assumed to be 10 percent of the direct costs)S PSE&G Permit Application 4 March 1999 Appendix F Attachment 5 F-5 Table 5. Costs Estimate for Installing a Two Pass Condenser Turbine Building Condenser Modifications Modular Two Pass Condenser Condenser Structural Mods Large Pipe Modifications Small Pipe Modifications Instrumentation and Controls Supports and Penetrations Rigging / Reinforcements CT Pump Motor; Valves Sub-total Turb Bldg / Cond Modifications Engineering Contingency Total Estimated Project Cost (1998 dollars)1998 dollars S 74,100,000 S 3,420,000$ 8,208,000 S 2.052,000$ 2,052,000 S 3,420,000$ 3,420,000 S 2,080,000$ 98,750,000

$ 9,875,200$ 14,800,000 $ 123,429,000 PSE&G Permit Application 4 March 1999 Appendix F Attachment 5 F-5Tabie 6. Cost Estimate Associated with Closed Cycle Cooling (Helper Tower)Cooling Tower Installed Cooling Tower S20,640.000 CT Pump Motors, Valves $ 2,180.000 Circulating Water Piping and Tie-ins S 5.630,000 Make-up, Blowdown and Chemical Treatment System S 270.000Condenser Shell and Waterbox Bracing S 1,210.000 Other Engineering Contingency S 2,430,000 S 3,640,000Total Estimated Project Costs (1998 dollars) S36,000,000 Costs are Stone & Webster estimates with manufacturer input, as necessary. Notes: 1. Outage time, indirect cost, licensing, added maintenance or operation costs are not included in these total costs.2. The equivalent present worth cost of the added auxiliary load is not included in these total costs.

3. An outage of two months would likely be necessary to perform this installation.

Much of the work can be accomplished during normal operation; therefore, replacement power costs due to the tie in outage are not likely to be substantial. 81 P .: & Jkr ? ,,-mT lt A p p i zat o n 4 .March !Q99 Appendix F Attachment 84 in (Typ) 90 in (Typ)108 in (Typ) 84 in (Typ)IJ[ ~ ~~120 in1I(Tp 11 ri *( -{?2J (Z2 1B) To___ lie____ Delaware (215)River (Typ)((ZZA)[ 1Z TRASH 133 RACKS C (239)] 1 ... .84 IN MOTOR OPERATED TRAVELING CIRCULATING CONDENSERS "ON-OFF" BUTTERFLY VALVE SCREENS -WATER PUMPS IN INDIVIDUAL INTAKE BAY F-5 Figure 1. Existing Circulating Water System Appendix F Attachment S TYPIM CA TAKE BAY MORMWffAL SE=TON (EL MV1 w-z mo Tu'Ir Note: All elevations referenced to PSE&G Datum F-5 Figure 2.Circulating Water Intake Structure S Appendix F Arjaji~w,:ic CIRCULATING WATER PUMP PERFORMANCE CURVE 80 w:60 U.0"40 a.20 0 I i GUIARANTEE

1 l5.DOO@27 FT M70 I IN 0 50 100 150 200 PUMP FLOW -1000GPM F-5 Figure 3. Circulating Water Pump Performance Curve S LP TURBINE EXHAUST PRESSURE CORRECTION TO LOAD C, 4, 16 14 12 I0 S 6 4 2 0-2-4-6-a-10-12 16-18-20-22-24-Ti C.4..C 1.6 1.8 2.0 2.2 2.4 2.6 2.8 3,0 3.2 3.4 3.6 3.8 4.0 4.2 4.4 4.6 4.8 5.0 5.2 5.4 5.6 5.8 6.0 6.2 6.4 6.6 6.8 7.0 7.2 7.4 7.6 M.8 8.0 8.2 8.4 Total LP Exhaust Steam Flow -1 06 lb/hr WV-05 27 Westinghouse Electric Corporation CAG 2/21/96 F-5 Figure 4.

I j Condenser Inlet Pt Circulating Water Pump / t Condenser Oullet Inlet Water Pipe -1 ft _70ft Discharge Pipe--1,270 ft -.-590ft*---540ft --l, -500ff I-S i3 19l~.s 1 3: E CWSAbsolute Water Pressure (CmHg)A 121 B 141 C 128 D 157 E 35 F 94 G 107 H 147 H SALEM GENERATING STATION TYPICAL PRESSUREITEMPURATUREITIME PROFILE NJPDES PERMIT NO. NJ005622 Approximate Time of Passage (Seconds)E!.F-5 Figure 5.0 0 Salem Cooling System Performance (Tube Rise) 3423 MW NSSS Power 175,000, 166,000, & 140,000 gpm per Circulator 00 19 18 17 1 140,000 gpm/pump U.e 20 I-16-I 3 S -O------------ I p 15 14 166,000 gpm/pump 175,000 gpm/pump 90* a m 60 100 30 40 50 70 80 Inlet Temperature, F F-5 Figure 6. Condenser Differential Temperature as a Function of Flow and Ambient Temperature Salem Cooling System Performance (CWOT, Condenser T & P)3423 MW NSSS Power 175,000, 166,000, & 140,000 gpm per Circulator 140 120 100 II80~E 60 40 20 0 30 F-5 Figure 7.6.000 5.000 140,000 gpm/pump 166,000 gpm/pump 175,000 gpm/pump 4.000 £3.000 4 0~C ai 2.000 1.000 90 100-o .-~ m~.o--10 '~3 Inlet Temperature, F--- CWOT --U- Tsat -Psat-"Hga Main Condenser Outlet Temperature an rbine Backpressure vs Flow 00.-a 0 3.50%3.00%2.50%2.00%1.50%1.00%0.50%0.00%Effect of Circ Water Temperature & Flow Variations on Generator Output 3423 MW NSSS Power 175,000, 166,000, & 140,000 gpm per Circulator /..140,0 166,0 175,0.1 00 gpm/pump 00 gpm/pump 00 gpm/pump-U.OJU-O I I 30 40 50 60 70 80 Inlet Temperature, F F-5 Figure 8. Effect of CWS Temperature and Flow Variations on Generator Output 90 100m 0 PSE&G Permit Application 4 March 1999 Appendix F Attachment 5 LEGEND 1 BARGE SLIP 2 SERVICE WATER INTAKE 3 SALEM FUEL OIL STORAGE TANK 4 SECURITY CENTER 5 TURBINE BUILDING 6 REACTOR BUILDING 7 AUXILIARY BUILDING 8 #1 OIL/WATER SKIM TANK 9 #2 OIL/WATER SKIM TANK 10 #3 OIL/NATER SKIM TANK 11 NON-RAD LIQUID WASTE DISPOSAL SYSTEM 12 OIL WATER SEPARATOR 13 PROPOSED VSD BUILDING oc 10 DSN 487B DSN A SECURITY FENCE N-.CQ OSN 491 F-5 Figure 9. Site Location Map Showing VSD Building PSE&G Permit .Application 4 March 1999 Appendix F Attachment 5 ZIA K-'.B> To Oischarge CTYP Of 5)21A---I- -----------23A 23B To Cooling Towe MakeM~1. Cooling tower for one Unar ONlY-TO Mtchan:'".al Draft Cooling From~WcianCal DfaftCooling lowmr &asin Cooling TovwS Pumpsg (105.000 Qp"/eaCh).F-5 Figure 10. Helper Tower Independent Water Box t4uctwical Oraft cocdin", Tower SOWadown to Cwira;uM WSWv Dlscwgs 4300 GPM F-5 FIGURE 11 Helper Tower System Flow Diagram M>--E3 P..0 ob 9j/MECHANICAL DRAFT COOLING TOWER M~if Elln'tinocs, 11-200 SHP Fir HW anin WaE 500 KY A-A 500 KV UNLE L LTUMBNE BLDG I F-5 FIGURE 12 Proposed Helper Tower Location APPENDIX F, ATTACHMENT 6 REVISED OUTAGE SCHEDULE SPONSORED BY: JAMES M. NICHOLSON STONE & WEBSTER ENGINEERING CORPORATION PSE&G RENEWAL APPLICATION SALEM GENERATING STATION PERMIT NO. NJ0005622 4 MARCH 1999 Appendix\ F. Artnachment týWTABLE OF CONTENTS I. INTRODUCTION

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1--[I. SHIFTING REFUELING OUTAGES TO SUMMER/WINTER

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2 III. 24-MONTH FUEL CYCLE

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3 IV, IMPACTS ASSOCIATED WITH SHIFTING REFUELING OUTAGES TO SUMMER/WINTER

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4 REFERENCES

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5 0i S Appendix F. Attachment3

1. INTRODUCTION Nuclear reactor systems heat water contained In the reactor coolant system by a process referred to as nuclear fission. Fission is the division (or splitting) of an atomic nucleus.such as uranium,. into parts of comparable mass. The nuclear fission process takes place in the reactor vessel inside the fuel assemblies (Mark's-Standard Handbook for Mechanical Engineers, ninth Edition, 1987). Unlike most conventional fossil fueled plants which "bum" their fuel, a nuclear plant must periodically shutdown to replace the fuel assemblies once an assembly can no longer maintain the nuclear reaction.

Thereplacement period for the fuel assemblies is commonly referred to as a "refueling"outage. These refueling outages are typically scheduled to occur at either 18 or 24 month intervals (Nuclear Energy Institute-Nuclear Fuel Resource Book). These intervals are carefully selected for each station and are based on many factors, including reactor design, replacement power costs, fuel costs, electric power demand, and maintenancetesting requirements. During the refueling process one-third of the fuel assemblies arereplaced while two-thirds of the fuel assemblies are typically moved to a new location in the reactor. The new fuel assemblies that are added to the reactor are typically loaded toward the outer section of the core to ensure that the power distribution across and along the reactor core is optimum (not too high and not too low) throughout the next fuel cycle.The refueling takes place at specific intervals and may take anywhere from five to, 10 weeks.Electric generating stations including nuclear power plants also require periodic inspection, instrument calibration, maintenance, repair, and replacement of equipment and materials in order to ensure reliable and safe production of electricity for consumers.Most nuclear plants schedule this work to occur during a scheduled refueling outage.The Salem Units are on an 18-month fuel cycle, which means that each unit operates continuously for up to 18 months before it must be shut down to refuel. The fuel cycle is scheduled so that the refueling outages occur during either the spring or fall period, when electrical load demands and replacement power costs are lower. However, fuel nucleonics, scheduled maintenance activities, unplanned outages, and other factors preclude a guaranteed refueling outage alternating spring and fall periods. A scheduled outage may be advanced in the event of a station trip during the final weeks of a fuel cycle when restarting the unit is not practical. A refueling outage may be delayed if one or more unscheduled outages occurred during the fuel cycle. This would be required in order to use up the remaining fuel. The impacts associated with rescheduling the Salem refueling outages to occur at a different frequency or to occur during a fixed different time period than would otherwise be scheduled are addressed in this attachment. The management of generating station outages and generating capacity to ensure adequate electrical production, satisfy PJM interconnection commitments, ensure efficient use of available fuel, avoid penalties associated with unused fuel, and meet plant-specific maintenance requirements is a complex, multi-faceted process. At Salem, this task is even more complex because the two units share resources. 1 Appendix F. ALtachment n 1W Rescheduling Salem's outages is also made more complex because of Salem's role in the PJM. The PJM Interconnection, L.L.C. (or PJM) is a limited liability company responsible for the operation and control of the bulk electric power system throughout major portions of Pennsylvania, and Virginia, the states of New Jersey, Delaware, and Maryland, and the District of Columbia. PJM is the largest centrally-dispatched electric control area in North America and the fourth largest in the world. PJM is one of the most liquid and active energy markets in the country and the PJM staff centrally forecasts,schedules and coordinates the operation of generating units, bilateral transactions, and thespot energy market. PJM's objectives are to ensure reliability of the bulk power transmission system and to facilitate an open, competitive wholesale electric market.PSE&G and other utilities in the PJM attempt to schedule maintenance on their efficient, baseload units for off-peak months. Practical considerations (including slower than anticipated nuclear fuel consumption) may change plans in the near term, but efficient long-range planning requires Salem's two unit output to be available during the peak summer and winter demand months. When Salem is not operating, the electricity it would have produced must be generated elsewhere. This means increasing operation of other facilities or bringing inactivegenerating capacity on line to provide needed power. This could have different environmental consequences, depending upon the locations and type of generating stations that are used to satisfy the power deficit. Effects could include any of the possible environmental effects of electrical generating stations, including increased emissions of pollutants to the air if fossil-powered stations are used. These costs are quantified in Attachment F-10.II. SHIFTING REFUELING OUTAGES TO SUMMERIWINTER MONTHSAltering the 18-month schedule so that the refueling outages would occur in the summer and winter would reduce cooling water impacts to fish and other organisms in the summer/winter months, but would increase them during the spring/fall months when refueling normally would have occurred. (Section F-VIII). Although keeping an 18-month fuel cycle and shifting the refueling outages to the summer/winter would have minimal impact associated with maintenance time intervals, it would make repairs of the portion of the turbine located on the open turbine deck more difficult due to harsher weather conditions. The major cost impact of shifting to a summer/winter refueling period is the increased costs associated with energy losses from Salem. Thus the analysis of the costs associated with rescheduling the refueling outages was limited to the increased costs of energylosses during the summer peak period. PSE&G's estimate of the present value of energycosts associated with this strategy are found in Attachment F-9.U2 Appendix F. Artachmerm o III. 24-MONTH FUEL CYCLE While most plants operate on an 18-month fuel cycle, a few have recently shifted to a 24-month cycle to improve the plant's competitive position. To maintain their high poweroutput with the 24-month strategy, plants are required to modify the fuel design parameters to increase the fuel enrichment levels.Changing a plant from an 18-month to a 24-month refueling cycle requires Nuclear Regulatory Commission (NRC) approval and changes to the Station's technical specifications, programs, and procedures pursuant to 10 CFR 50.59. These changes would include accident reanalysis, instrument calibration setpoint reanalysis, and changes to the Station's Preventive Maintenance Program. Since 1994, a number of fuel related industry events have occurred which are prohibitive to 24-month cycle operating strategies, primarily for high energy/high power PWRs such as the Salem units. Such industry events include the following:

• unanticipated mechanical distortion of PWR fuel assemblies resulting from high burn-up;" unanticipated chemistry effects associated with PWR cores designed for extended cycles which affects the full management program; and* elevated boron concentrations associated with PWR cores designed for extended cycles.These fuel-related industry events, among other types of events related to longer fuel cycles and higher-energy output cores, prompted the Institute of Nuclear Power Operations to issue Significant Operating Experience Report (SOER) 96-2. SOER 96-2 summarized that these events "illustrate how existing weakhesses in core design and reload analysis methods may adversely affect plant operations and may become furthermagnified in loss of operating margin with more advanced core designs and operating strategies."Although the NRC has previously granted several license changes for 24 month refuelingoutages, they are now discouraging such license change requests and even re-considering the previously granted license changes.

As a result of these events, the NRC has not authorized Westinghouse, the vendor of the Salem PWRs, to modify the current fuel design to accommodate a 24-month refueling cycle. Consequently, a fuel design to support a 24-month fuel cycle is currently not available for Salem.3 Appendix F, AaachmentIV. IMPACTS ASSOCIATED WITH SHIFTING REFUELING OUTAGES TO SUMMERIWINTER The PJM Interconnection experiences winter and summer peaks in electrical demand.Consequently, the cost of this alternative, relative to retaining the present outage schedule, is the cost associated with energy losses during the summer and winter outages, at times when energy is more costly. The price of electricity produced by Salem is as little as one-quarter the cost of electricity generated by oil-fired stations at times of peak electrical demand (Attachment F-9). Moreover, Salem is capable of producing large amounts of electricity. As a result of these factors, scheduling refueling outages for Salem for five to ten weeks during summer and winter demand peaks would be very costly.The cost of scheduling the current 18-month cycle of spring and fall outages to an 18-month cycle of summer and winter outages would be reflected in the added cost of replacement energy during the outages, and in a Salem capacity deficiency charge that would be owed to PJM as provided in Attachment F-9.If PSE&G were required to schedule summer/winter refueling outages, additional outages might none the less be necessary before and/or after the scheduled outage to accommodate any change in scope or priority of the maintenance work to be accomplished during the refueling outage. Early refueling might also be required as a result of better-than-forecast performance of the unit, or a later refueling due to poorer-than-forecast performance. These additional outages would substantially increase the costs estimated in Attachment F-9.Assuming that only the timing of scheduled outages would change, there would be no increases in station operating and maintenance costs. The facility would not require additional derating during non-outage periods.4 Append[( F, Atiachment b REFERENCES Code of Federal Regulations, Title 10 -Energy, Part 50.59, 1998 Institute of Nuclear Power Operations Significant Operating Experience Report (SOER), 96-2 Mark's -Standard Handbook for Mechanical Engineers, ninth Edition, 1987. Chapter 9.Nuclear Energy Institute -Nuclear Fuel Resource Book 5 APPENDIX F, ATTACHMENT 7 CLOSED-CYCLE COOLING SPONSORED BY: JAMES M. NICHOLSON STONE & WEBSTER ENGINEERING CORPORATION RENEWAL APPLICATION SALEM GENERATING STATION PERMIT NO. NJ0005622 4 MARCH 1999 8 PSE&G Permit Application 4 March 1909 Appendix F Attachment 7 TABLE OF CONTENTS 1. EX ECUTIVE SUM M ARY ....................................................................................... 1 11. IN TROD UCTION ......................................................................................................... 2 III. EXISTIN G FACILITIES ....................................................................................... 3 III.A .Salem Description .................................................................................................... 3 III.B. Intake Structure ................................................................................................... 4 II.C. Open-Cycle Cooling ............................................................................................ 4 IV .CLO SED-CYCLE COOLIN G SYSTEM S ........................................................... 5 IV.A. Technical Issues for Closed-Cycle Cooling ......................... 5 IV .B. Cooling Tower Design ....................................................................................... 7 IV .C. System and Equipm ent Design ........................................................................... 8 IV .D .Engineering Issues ........................................................................................... 10 IV .D .1. General ..................................................................................................... 10 IV .D .2. CW S Piping Installation/Dem olition ......................................................... 10 IV .D .3. Condenser M odifications ............................................................................ 12 IV .D .4. Cooling Tower M ake-up ............................................................................ 13 IV .D .5. Cooling Tower Blowdown .......................................................................... 14 IV .D .6 Additional Considerations ........................................................................... 14 IV .E. Construction Issues ........................................................................................... 15 IV .F. Uncertainties and Risks ..................................................................................... 16 V .LICEN SIN G / PERM ITTIN G ................................................................................ 17 VI. STATION CAPACITY DERATING AND ENERGY LOSS ............... 18 VII. PROJECT SCHEDULE ....................................................................................... 19 VII.A .Schedule Basis ................................................................................................. 19 VII.B. Cooling Towers ............................................................................................... 20 VII.C. Condenser M odifications ................................................................................. 20 VII.D .Circulating W ater Piping and Pum p House ..................................................... 21 VII.E. Contracting Strategy ......................................................................................... 21 VII.F. Outage Schedules .............................................................................................. 21 VI.G .Critical Path .................................................................................................... 22 VI.H .Uncertainties and Contingencies ....................................................................... 22 VIII. CO ST ISSUES ................................................................................................... 23 VIII.A .General ........................................................................................................... 23 VIII.B. Capital Cost of Installation .............................................................................. 24 VIII.C. Operating and M aintenance ............................................................................ 25 IX. ALTERNATIVE CLOSED-CYCLE COOLING SYSTEM DESIGNS ............... 26 IX .A .Spray Canals ..................................................................................................... 26 IX .B. Cobling Lake ........................................................................................................... 27 IX .C. Unconventional System s .................................................................................. 27 V i i PSE&G Permit Application 4 March 1999 Appendix F Attachment "7 LIST OF TABLES F-7 Table 1 F-7 Table 2 F-7 Table 3 Preliminary Assessment of Environment Permitting Requirements for Construction and Operating of Cooling Towers Natural Draft Cooling Tower Generating Capacity Comparison (Gross and Net Electrical Power Per Unit)Mechanical Draft Cooling Tower Generating Capacity Comparison (Gross and Net Electrical Power Per Unit)Plant Performance Comparison Cooling Tower -Overall Summary Schedule Natural Draft Cooling Tower Costs Mechanical Draft Cooling Tower Costs Cooling Tower -Annual Operating and Maintenance Costs F-7 F-7 F-7 F-7 F-7 Table 4 Table 5 Table 6 Table 7 Table 8 LIST OF FIGURES F-7 F-7 F-7 F-7 F-7 Figure 1 Figure 2 Figure 3 Figure 4 Figure 5 Site LayoutNatural Draft Cooling Tower General Arrangement Conceptual Natural Draft Cooling Tower Schematic Mechanical Draft Cooling Tower General Arrangement Conceptual Mechanical Draft Cooling Tower Schematic i ii PSE&G Permit Appiication 4 March 1999 Appendix F Attachment 7 I. EXECUTIVE

SUMMARY

Stone & Webster Engineering Corporation (SWEC) concluded in 1990, confirmed in 1993, and reconfirms in this Application that retrofitting Salem Units I and 2 with a closed-cycle cooling system would require an unprecedented and complex construction effort. Retrofitting a once-through cooling water system for closed-cycle cooling would.require the construction of cooling towers, supporting systems and structures such as pump houses, and sufficient circulating water piping to form a closed loop system. The retrofit would require the construction of either two natural draft cooling towers or six mechanical draft cooling towers. The minimum space required for the cooling towers would be an area of approximately 18 acres.The construction of the cooling towers would require the installation of over 10,000, 100-ft long piles to support the cooling towers, piping and other structures. More than four miles of new 7 foot diameter circulating water piping would be required to connect the cooling towers to the existing cooling water system. In order to install this piping, a trench approximately 140 feet wide, 16 feet deep, and 2,000 feet long would have to be dug. In addition, several transformers and miscellaneous buildings would have to be relocated. The condensers in each unit would have to be replaced. This would require the removal and replacement of the west wall of the turbine buildings along with numerous pipes, electrical cables, and other equipment. A de-chlorinating system, makeup and blowdown system, electric substation and substantial electrical cabling would also need to be installed to provide support for the closed-cycle cooling system operation. In addition, there are costly uncertainties involved in retrofit work of this magnitude, due to the large number of simultaneous modifications at both Salem units, plus the need to work double shifts on critical path engineering and construction activities. Licensing and permitting requirements pose a major source of uncertainty. It has been assumed that the regulatory authorities will approve the designs used as a basis for the cost estimates and schedules provided here. If not, there will be cost impacts that have not been included in these estimates. In addition, depending upon the particular permit and schedule, there is a potential for very significant schedule impacts due to delays inobtaining permits. After assessing the complex issues of technical feasibility, installation cost, operating and maintenance costs, station capacity de-rating, and energy loss, SWEC concludes that retrofitting cooling towers at Salem would impose immense cost penalties with significant reductions in station output.If closed-cycle cooling were required at Salem, natural draft towers would be preferable to mechanical draft towers. This is primarily due to the high maintenance costs associated with the large number of fans required for mechanical draft towers.I PSE&G Permit Applaic an 4 March 1 99)Appendix F Attachment 7 II. INTRODUCTION This report assumes an orderly effort to permit, engineer, procure, and construct a closed-cycle cooling system for each Salem unit. It utilizes a moderate risk schedule approach to assess the economic impact of the project. The approach is intended to estimate the costs of converting the Salem Generating Station to a closed-cycle cooling system in a manner that optimizes both schedule and cost. To that end, a moderate level of risk is assumed to support the permit application/approval cycle. This risk results from the up-front financial expenditure associated with accelerated engineering during the initial phase of the process, some of which will be conducted prior to receipt of required permits The risk is considered moderate due to the level of engineering expenditures vs. total required expenditures and the fact that no equipment orders would be placed prior to permitapprovals being obtained. This section provides the basis and assumptions used in developing an overall project costlbenefit analysis. The schedule provides, in some cases, an optimistic activity time period and de-couples many normally required licensing, engineering, and construction constraints. This approach will ensure that estimates of the cost of lost power during the extended unit outages are conservative. The existing circulating water system is designed to dissipate the maximum condenser thermal heat duty of 7.7x 10' Btu/hr (per unit). The system is designed to pump approximately 1,1,10,000 gpm of Delaware River water through each of Salem's main condensers prior to returning it to the river. The circulating water discharge from each unit is continuously monitored for temperature increase before returning to the Delaware River via three submerged 120-inch diameter discharge pipes (per unit).Because there is no large body of water available to Salem for cooling purposes other than the River, the installation of a closed-cycle cooling water system at Salem wouldneed to be one that includes a cooling tower. Cooling towers dissipate heat by the evaporation of some of the water sprayed into the air circulated through the tower. The installation of cooling towers would require several major modifications to Salem's circulating water system: " A cooling tower is intended to cool the hot water in the tower to as near as possible to ambient air wetbulb temperatures. Lower cooling tower efficiencies result in higher condenser circulating water return temperatures than are available from a singlepass circulating water open cycle system. To optimize cooling tower design the coolingwater temperature leaving the condenser should be increased above that normally used in an open cycle system. Therefore, the condenser would need to be modified to accommodate two circulating water passes. This would require extensive modification to the condensers and demolition of piping and components associated with the existing circulating water system and result in higher circulating water system pressure." The existing system piping and components were intended to be permanently installed and are buried in the ground and supported on reinforced concrete 2 PSE&CI Permit Application 4 March 1999 Appendix F Attachment foundations. To gain access for the demolition of existing piping and the installation of cooling towers, presently installed plant equipment would need to be removed and either relocated or reinstalled after construction." Any cooling tower installation would be monitored, controlled, and regulated by m 'any permitting agencies. Resulting regulatory constraints, especially approval of the air quality permits, could be time-consuming and delay the start of the project.* Installing cooling towers at Salem would be a major construction activity requiring a construction schedule extending over a six-year period to complete the installation at both units.* Numerous tie-ins to existing Salem hydraulic and electrical systems would be required in order to implement the changes associated with the installation of the cooling towers." Replacement electrical generation capacity would be required which would add significantly to the costs associated with a cooling tower back-fit.This section attempts to accurately depict the scope and complexity of the proposed cooling tower back-fit. The duration of key activities and the interrelating logic between specific activities have been adjusted so that the estimated project length does not result in overly conservative cost estimates. The schedule includes major activities associated with the cooling towers. It utilizes sequencing that typifies a fast-track engineering and construction effort of this magnitude. The schedule does not attempt to address other non-cooling tower activities, such as permitting, that could be manpower-intensive and costly to PSE&G. Moreover, because of the seasonal nature of many of the construction activities, the timing of most of the critical activities would be dependent on the planned outages as well as the completion of the preceding activities. Thus, while the cooling tower schedule and costs shown provide a rough estimate of magnitude, the actual costs and duration of construction activities would be more complex and would require a level of detail far in excess of that presented here.III. EXISTING FACILITIES III.A. Salem Description Salem is located in Lower Alloways Creek Township, Salem County, New Jersey, at river mile 50 on the Delaware River, eighteen (18) miles south of the Delaware Memorial Bridge (F-7 Figure 1). Salem is bordered by the Delaware River on two sides and by extensive marshes and uplands on the other two sides. Together with the neighboring Hope Creek Generating Station, the site covers 740 acres of land. There is little natural vegetation on the site, except for common reed.Salem Units 1 and 2 are essentially identical, each consisting of a Westinghouse pressurized-water reactor ("PWR!) with a licensed thermal rating of 3,423 MWt. The Unit I and 2 turbines are rated at a gross electrical output of 1, 162 MWe (nameplate rating). Actual output will vary somewhat under different operating conditions. Often the units are referred to as 1,160 megawatt units.3 PSE&G Permit Application 4 March 1999 Appendix F Attachment Unit Nos. 1 and 2 are designed to operate continuously at the licensed thermal power rating as baseload electrical generating units. The Salem Units were proposed in 1966.The Atomic Energy Commission (AEC) issued construction licenses for Unit Nos. 1 and 2 on September 25, 1968 and operating licensing for Unit Nos. 1 and 2 on August 13, 1976 and April 18, 1980, respectively. Unit 1 began operating in 1977 and has a license to operate through year 2017. Unit 2 began operation in 1981 and has a license to operate through year 2021.III.B. Intake Structure The intake for the CWS is located at the southwestern side of the Site and consists of 12 separate intake bays (six for each unit), approximately 11 feet wide and 50 feet high. The Circulating Water Intake Structure (CWIS) is located at the riverfront (shoreline). The CWIS is provided with an enclosure for weather protection with a removable roof sectionfor access and maintenance. The enclosure has a ventilation system for summer cooling and a heating system to prevent freezing during the winter.The intake structure contains a fish return system and facilities to count fish that are caught on the intake screens. The fish counting pools are located at both the north and south ends of the intake structure to facilitate use when the fish trough is discharging in either direction. Each of the 12 bays (6 per unit) contains a Circulating Water Pump (CWP). Each pumpdraws water by suction from its own intake bay. Stop logs can be inserted upstream of each traveling screen and in the fish-escape openings to empty water from the bays and permit maintenance. A detailed description of the intake structure and traveling screens is provided in Appendix B.ILC. Open-Cycle Cooling In an open-cycle circulating water system, the cooling water typically enters the plant through an intake bay located at the shore of the natural water body. The water passes through the main condenser and then is directed back to the water body. In a closed-cycle cooling water system the cooling water is constantly recycled through a heat sink, typically a cooling tower. The only water taken from the natural water body is to replace any water evaporated in the cooling tower and the blow-down discharged back to thewater body. The Salem circulating water system is an open-cycle cooling water system. It supplies cooling water to the main condenser to condense turbine exhaust steam and dissipate that heat to the Delaware River. As the heat sink for the main steam turbine and associated auxiliary'equipment, the circulating water system is designed to maximize steam power cycle efficiency while minimizing any adverse impact on the Delaware River.4 PSE&G Permit Application 4 March 1999 Appendix F Attachment 7River water enters the circulating water system intake bay through fixed bar racks (trash racks) designed to prevent large floating or submerged debris from entering the system.The racks are cleaned periodically with a clam-shell type mechanical rake device, thus preventing a significant build-up which would affect system operation. Intake flow then passes through the second filter barrier, the circulating water traveling screens, which remove finer materials before the water enters the circulating water pump. The screens are designed to remove fish- and debris via troughs that are too large to pass through the system without causing pump damage or clogging the condenser tubes, and to return marine life to the river. Two fish counting pools are provided to evaluate the impact of the circulating water intake on marine life.The six circulating water pumps for each unit at Salem dra w water by suction from dedicated wet-pits downstream of the screens, and discharge into individual lines for delivery to the main condenser inlet waterboxes. One circulating water pump provides flow to each main condenser water box.. Each of the six pumps per unit is located in an individual bay within the circulating water intake structure, which minimizes pump-to-pump hydraulic interactions and allows individual pumps to be isolated and drained for maintenance.Upon leaving the respective main condenser section, the two outlet waterbox discharge lines combine into a single 120-inch diameter discharge pipe. The service water system and non-radioactive liquid waste system discharge flow is also directed to two of the three 120-inch discharge pipes, which provide the required dilution of chlorine before discharge back to the river. The three discharges for each Salem Unit are located approximately 500 feet offshore. Each discharge is situated to minimize thermal re-circulation to the intake structure and to promote rapid mixing with the river water to minimize the thermal plume in the river.IV. CLOSED-CYCLE COOLING SYSTEMS IV.A. Technical Issues for Closed-Cycle Cooling In an electric generating station the main cooling water system is one of the first systems to be designed and installed. Careful consideration is given to the availability of areliable source of cooling water condensing the exhaust steam from the steam turbine(s) and removing heat from other equipment. The design of many of a station's major capital cost components are related to the cooling water supply system's capability. Therefore, any subsequent change to the cooling water system would have a significant impact on the plant's ability to perform at expected design conditions. Even minor changes to the cooling water supply (for example a temperature increase of a few degrees above designor a reduction in flow) can result in a large decrease in the plant's ability to achieve its rated capacity. In addition, because cooling water systems are one of the first systems to be installed during plant construction, many other plant systems, structures and components are built around and over the system, making retrofitting complicated and expensive. 5 PSE&G Permit Application 4 March 199tQ Appendix F Attachment 7 Construction of two or more cooling towers and retrofitting to a closed-cycle cooling system would require construction of new pump houses and chemical controlsystem structures, as well as the following: " complex foundation structures for the cooling towers, piping, and other major structures;" replacement of existing single-pass condensers with two-pass modular units;" a new major electrical power distribution system;," excavation of over 1/4 million cubic yards of soil;" demolition or abandonment of over three miles of existing 7-foot and 10-foot diameter system piping and supports which were permanently installed without consideration of later retrofitting of closed-cycle cooling;" installation of over four miles of 7 foot diameter steel reinforced concrete pipe;" installation of over 3,000 feet of corrosion-restraint steel liner approximately 7 feet in diameter to reinforce the existing buried piping from the closed-cycle pipe tie-in points to the condenser (a large portion of which is located under the Turbine and Administration Buildings);" installation of approximately 10,000, 100-ft long steel and concrete piles to support foundations for the new piping, cooling towers, and miscellaneous new structures; and" temporary removal and sometimes demolition of permanent structures.Two scenarios were developed in order to derive a cost estimate for retrofitting Salem with closed-cycle cooling.. They are:* Scenario 1 -one natural draft cooling tower per unit with a design objective of a 14°F approach (F-7 Figures 2 and 3)," Scenario 2 -three concrete mechanical draft cooling towers per unit with a design objective of a 7 0 F approach (F-7 Figures 4 and 5).The station capacity de-rating and energy loss associated with these scenarios is discussed in this Section in subsection VI. The capital costs and annual operation and maintenance costs are presented in subsection VIII.If closed-cycle cooling were required at Salem, natural draft towers would be preferable to mechanical draft towers for the following reasons: Because mechanical draft cooling towers have large numbers of fans, their maintenance costs are very high compared to natural draft coolingtowers. The mechanical draft cooling towers would use 66 multi-bladed 40 foot diameter fans, each of which would require 300 hp motors, whereas natural draft towers have no moving parts. Also, maintenance costs for a mechanical draft tower are over two million dollars per year per unit greater than for a natural draft tower.6 PSE&G Permit Application 4 March 1~9q Appendix F Attachment" Switch gear, starters, controls, circuit breakers, and a gear box transmitting the power to the fan blade assembly would also be necessary and contribute to operation and maintenance costs." A mechanical draft cooling tower has more severe local environmental effects.including higher noise levels and a vapor discharge plume that is lower to the ground.o There is also a higher potential for forced power reduction associated with mechanicaldraft cooling towers because of the inherently lower reliability of the moving parts.While three mechanical draft towers per unit would slightly improve Salem's cooling performance over natural draft towers they would increase environmental impacts in terms of intake effect. Mechanical towers require a slightly larger makeup flow from the river due to higher evaporative losses associated with the mechanical draft tower. Although mechanical draft towers can be built somewhat faster than natural draft towers a shorter cooling tower construction time, in actuality, will not significantly lessen the total time period necessary to complete the closed-cycle cooling retrofit. IV.B. Cooling Tower DesignThe difference between the temperature of the cooled water discharged from a cooling tower and the ambient air wet bulb temperature is called the cooling tower "approach." (The wet bulb temperature is the lowest temperature at which evaporation can occur for the specific conditions of the atmosphere.) The approach that is actually attainable at a particular installation depends on the type and size of the cooling tower, the quantity of water flow to be cooled, the change in water temperature to be achieved through cooling, and the local wet bulb temperature. All of the approach factors, except those related to climate (i.e., local wet bulb temperature) are essentially fixed. Since climatic factors are outside an operator's control, an approach temperature can only be used by engineers as a design criterion, and cannot be applied as an operating requirement. Considering the heat load rejected from Salem and the design weather conditions that must be factored into the cooling tower design, a natural draft cooling tower cannot be designed that would satisfy the present design requirement or operating performance of the current once-through cooling water system at Salem. Estimates performed by SWECsuggest that in order to achieve a 1 0*1 approach temperature under ideal (design)meteorological conditions, a natural draft tower would need to be approximately 900 feet tall. Current cooling tower technology is not proven for this hypothetical size; the tallest hyperbolic tower now installed in the world is only 550 feet. A 1 4'F approach, natural draft tower 500 feet tall is essentially state-of-the-art for Salem, and was installed at Hope Creek. Hence, a I 0 0 F-design approach is requirement for a natural draft tower. Rather, even with multiple draft towers for each Salem unit, only design approach temperatures of 12 0 F could be achieved.Using a similar analysis, it can be shown that a 5 0 F-design approach also cannot be achieved with 'mechanical draft towers. A mechanical tower can attain a slightly lower 7 PSE&G Permit A-pplicationl 4 March 1999 Appendix F Attachment 7 approach temperature than a natural draft tower because of its greater ability to develop higher cooling air flows through use of huge mechanical fans. Even so, the actual attainable design approach of a mechanical draft tower at Salem is limited to 7'F. While mechanical draft towers could in theory be designed to I10 0 F approach, they cannot achieve a I O 0 F approach as an operating requirement. For either a natural or mechanical draft cooling tower, the ambient air, which provides the cooling in either type of tower, varies in its capacity to hold moisture. The colder the wetbulb temperature, the less moisture it can hold. Since the major heat transfer in the tower is evaporative cooling, the lower ability of colder ambient air to absorb moisture causes the approach of a cooling tower to increase appreciably as the weather becomes colder.This is fortunate, since it helps to prevent icing of the towers as temperatures decrease.As a result, however, in practice a mechanical draft tower sized for a 7'F approach to the design condition of a 76"F wetbulb temperature exhibits a 1 07 approach to the design condition of a 767F wet bulb temperature, and about a 257F approach at a 32'F wet bulb temperature. Therefore, even multiple mechanical draft towers for each Salem Unit designed to a 7*F approach temperature would only meet a I 0 0 F approach during certain limited periods of the year, i.e., when the wet bulb temperature is 70*F or higher.IV.C. System and Equipment Design Retrofitting Salem for a closed-cycle cooling system would not simply mean the addition of cooling towers. It would require other major physical changes as well. In contrast to a once-through (or open-cycle) cooling system design, the use of cooling towers in a closed-cycle system requires the designer to reduce the circulated water quantity in order for the cooling towers to be efficient, economic and cost-effective. Each unit at Salem was originally designed for 1, 100,000 gallons per minute (GPM) of circulating water flow; a closed-cycle system, however, would be designed for 50 percent of that flow.A number of factors would make any attempted retrofit both technically difficult andcostly. These factors include: " The existing single-pass, divided triple-shell surface condensers are comprised of over 68,000, 1 -inch diameter, 22 gauge AL-6X tubes (equivalent to > 1 100 miles for thetwo units). Each condenser shell is approximately 20 feet high, 30 feet wide, and 65feet long and consists of two tube bundles; each tube bundle (six per unit) weighs about 160 tons and would require wholesale change-out with a new design to accommodate two-passes and a considerably higher tube side-pressure. This would require extensive renovations even to gain access, including temporary bracing and demolition of piping and components associated with the existing condensers." The existing system was intended to be permanently installed. Most of the piping and components are supported on (if not embedded in) reinforced concrete foundations. Removal of existing plant equipment would be required to gain access for demolition of existing piping, and of thrust blocks (concrete pipe supports), approximately 14 feet high, 10 feet wide and 140 feet long, so as to facilitate installation of new piping 8 PSE&G Permit Application 4 March 1999 Appendix F Attachment 7 to and from the cooling towers. Preliminary engineering evaluations for two conventional natural draft towers suggest the retrofit would require excavating more than 250,000 cubic yards of soil and installing more than four miles of 7-ft diameter pipe.* Cooling tower construction is regulated, monitored, and controlled by many permitting agencies. Regulatory constraints (e.g., air quality permit approvals) could delay the start of any project, even assuming that permits can be obtained, which is by no means certain.* Because Salem is a nuclear power plant, the documentation, review requirements and revision to procedures associated with any changes would be very extensive and stringent.

• Continuous chlorination of the circulating water and de-chlorination of the blowdown would be required." If the existing single-pass condenser configuration were to be reused at this lower circulating water flow, the condenser tube water velocities would be so low that tube fouling deposits would be promoted and poor heat transfer would occur, resulting in a decrease in plant efficiency.

Consequently, the existing condensers would have to be modified from a single-pass to a two-pass design in order improve their efficiency. At Salem, this modification would impose a 29°F temperature rise on water that previously underwent a 141F rise, and would cause about 70 percent of the total steam to be condensed in the first or inlet pass while only 30 percent would be condensed in the second pass. This produces major shifts in the steam condensation patterns, steam space and velocity patterns, side flows, and the flow direction/sizing of the air coolerinternals. Basically, the steam flows to the first pass are doubled while those to the second pass are halved. This extreme modification in heat transfer, steam velocity,air removal, and condensation patterns mandates that tube bundle spacing and design be changed to specifically accommodate two-pass conditions. Another major consequence of the retrofit is that the circulating water would be at asignificantly higher hydraulic pressure. The higher operating pressure is needed to overcome the added condenser tube pressure loss, the friction loss of approximately 4,000 feet of pipe (going back and forth to the cooling tower), and the static energy to overcome the height to the hot water distribution headers of the tower. At Salem, this would impose a significant design change on the condenser waterboxes. The waterboxes presently operate slightly below atmospheric pressure and are only designed for a positive pressure of 20 psig. The retrofit condenser would be required to withstand an increased operating pressure range of 30 psig to 75 psig at pump shutoff. Though the pressures do not seem particularly high, when multiplied by the large surface areas involved, the loads become enormous.Based on-these concerns, SWEC selected a closed-cycle cooling system design with a conventionally located single pumping station at the discharge of the cooling tower.Three large pumps for each unit would be designed to convey the circulating water from the tower through the condenser and back to the tower. This system design utilizing a 9 PSE&G Permit Application 4 March 19 QQ Appendix F Attachment single pumping station will ensure stable, reliable operation. All analyses indicate that a modular tube bundle replacement would be the most cost-and schedule-effective approach to replacing more than 500 miles of I-inch diameter corrosion-restraint stainless steel tubing in each unit. IV.D. Engineering Issues IV.D.I. General The cost analysis assumes that all initial engineering activities will be performed on an accelerated basis, commencing immediately upon the issuance of a permit requiring retrofit of Salem Units 1 and 2 with cooling towers. The accelerated schedule would require additional engineering man-power staffing and a work schedule of six ten-hour days per week to expedite purchase order placement and contract awarding and allow an early completion date. Tasks associated with these efforts are:* Cooling tower optimization study* Engineering to support the permit application

• The design and general contract specifications covering the installation, construction, and erection of:* Circulating water piping/foundations
• Circulating water pump house/foundations
• Motor control centers* Service water system modification
• Decommissioning of unused circulating water lines and intake structure* Relocation of security fence in the area of the circulating water system
• Electrical distribution system* Cooling tower specifications
• Cooling tower pump/motor specifications
• Revised service water system return path designs* Cooling tower makeup/dilution system design" Modular condenser tube bundle replacement specifications" Circulating water pump motor/cooling tower fan motor switchgear specification IV.D.2. CWS Piping Installation/Demolition The conceptual design of the closed-loop circulating water system specifies the use of theexisting system piping whenever possible.

However, piping connections would be required to tie the new piping into the existing system. These tie-ins would require extensive excavation, demolition of the existing CWS piping and the associated large concrete reinforced foundations used to support the existing piping (Class A bedding).Additionally, extensive demolition of the existing anchor block and pipe foundations would be required. Reinforcement of over 3,000 feet of 7-ft diameter cooling water pipe with corrosion-resistant steel liners would be required. In the area of the tie-ins, approximately 400 linear feet of concrete pipe foundation would need to be removed, a difficult and time-consuming demolition. 10 PSE&G Permit Application 4 March 199Q Appendix F Anachment 7 To minimize the required demolition, piping replacement, and construction costs, the existing 84-in inlet lines to the east of the turbine building would remain in place and be connected to the new piping in the area of the existing thrust blocks at the southeast corner of the turbine building. However, because the existing piping is not designed for the higher pressures associated with the closed-cycle system, extensive modification would be required. The existing thrust blocks and CWS pipe foundations would be removed in this area. In conjunction with the condenser modifications, the configuration and function of the existing system inlet lines (six per unit) would be changed such that three of the existing inlet lines would function as discharge lines. The existing operating pressure for the circulating water system is approximately 12 psig. Because of the longer piping runs to and from the tower and the increases in the required pumping pressure necessitated by the height of the distribution piping at the cooling tower, the once-through circulating water system operating and design pressure would be increased to approximately 30-45 psig and 60-75 psig, respectively. The schedule assumes that all system piping would be placed on piles and utilize large reinforced concrete foundations (Class A bedding). This is required because of the poor soil conditions and the high sub-surface water table. The driving of the piles would be complicated in some areas by the proximity of surrounding structures, components and other subsurface services such as electrical duct lines and cables and piping. Avoiding damage to these sub-surface services and surrounding structures demands extreme caution. In some areas, excavation may need to be performed by hand or with small equipment to locate below grade utilities prior to pile-driving. Such work could result in significant time delays.To minimize outage time, prior to the outage for the respective unit tie-ins, all new circulating water line pipe placement from the cooling towers to the tie-in point wouldhave been performed.The schedule duration is based on all excavation material being temporarily stored on site. If material removal and storage is required off site it could impact the excavation or construction activities as they progress from the cooling tower/pump house location to the tie-in points. It has been further assumed that all excavation material is uncontaminated and would not need special handling or disposal as hazardous waste. If hazardous waste were found during the soil boring or construction phase, construction activities could be severely impacted.It is assumed that the removal of the existing system piping and thrust blocks can be performed without interference from the condensate polisher building. However, sheet piling and shoring may be required at this interface. Further, it is also assumed that the removal cof the existing piping would not interfere with or be hindered by the main transformers east of the turbine building.11 0 PSE&G Permit Applicatien 4 March 1999 Appendix F Atuachment An additional assumption is that the majority of the existing discharge piping and un-reused portions of the intake structure would be abandoned in place. Any circulating water lines that would not be used would be capped and abandoned in place.The existing guard house and several other buildings at the southeast comer of the job site would have to be removed or relocated to facilitate the installation of the new piping.All construction work east of the guardhouse is assumed to be performed in an unsecured area. After the installation of the new circulating water piping up to the area east of the existing security area boundary, the security fence/security area boundary would need to be relocated for work to proceed. To minimize the impact on security and reduce the associated construction delays; all material used for the tie-ins to the existing circulating water system lines are assumed to be stored inside the security area. Note that the removal and relocation of the security fence will require prior approval by the Nuclear Regulatory Commission. In order for the installation, testing and back-filling of the new circulating water lines toprogress rapidly enough to meet the schedule, the new circulating water piping would be double-gasketed and provided with connections to facilitate testing. The double-gasketing would allow air testing of the installed sections as the construction progresses. The testing would ensure the piping joint integrity and allow the back-filling of the installed pipe to immediately follow installation. IV.D.3. Condenser Modifications Because of the extensive piping modifications required by the increased pressure in a closed-loop system and the converting of the existing single pass condenser to a two-pass design, an extended outage and numerous uncertainties in the final design are expected.To minimize the impact of these concerns, modular tube bundle replacements, including new condenser waterboxes, are included in lieu of the re-engineering, demolition, and modification of the existing condensers. The waterboxes, condenser tubes and tube.sheets would be removed from the existing condenser. New condenser tube bundles consisting of tubes and tube sheets would be inserted into the existing condenser and new, higher pressure waterboxes would replace the existing waterboxes. The replacement of the condenser tube bundles includes more than 500 miles of 1-in diameter, 22-gauge tubes necessary to accommodate the two-pass design. Note that each condenser shell (three per unit) is approximately 20 feet high, 30 feet wide, and 65 feet long; eachtube bundle (six per unit) weighs about 160 tons. Therefore, a modular two-pass condenser tube bundle replacement is assumed for the schedule to minimize the duration and extent of the modifications during the outage and to increase the water temperaturerise across the condenser. The modular condenser design would eliminate many of thetime consuming activities associated with the condenser modifications. With the proposed two-pass condenser required for the new cooling closed-cycle system, the circulating water system piping would enter and exit the condenser at the east end of the condenser. This would require the removal and capping of one of the two existing 12 PSE&G Permit Application 4.March 1999 Appenldix~ F Attachment 7 air/vapor lines in each condenser shell/tube bundle. A new air/vapor connection would be required in each condenser shell in order for the modified condenser to function properly. The additional air/vapor line would require modifications to the internal air/vapor distribution piping, and the addition of a new outlet air/vapor line connection. Because of the location of the existing circulating water system isolation valves on the discharge side of the condenser, the two-pass arrangement would require relocation of system isolation valves to the inlet side of the waterboxes to enable tube bundle isolation for periodic maintenance. Because the engineering has not been developed fully, it has been assumed that the existing condenser foundation will be adequate to support the two-pass modular condenser loading.IV.D.4. Cooling Tower Make-up Although other options are available. to reduce Salem's dependence on the Delaware River, this analysis assumes that the water for the cooling tower make-up will be supplied from the service water system which currently draws from the River. The service water system is designed to supply cooling water to the reactor safeguard and auxiliary equipment. There are six service water pumps for each unit that supply water from the Delaware River. The conceptual design would require the existing service water discharges lines (which currently discharge to the 84-inch CWS discharge piping at the turbine building) to be rerouted to tie-in to the new CWS. The service water system is typically required to operate even during a station shutdown. To perform the required modifications, the service water system operational requirements will require cross-connecting the Salem Unit 1 and 2 service water systems such that either system can provide the required cooling and discharge for the other unit during the modification and tie-in work for the service water system.Using the service water system as the primary make up supply would require a detailed review of various aspects of final design during the engineering phase. For example, the integrity of the circulating water system make-up lines during a seismic event would need to be reviewed to ensure that the failure of the system piping would not compromise the capability of the nuclear safety-related service water system. Designing and installing piping to withstand a seismic event would be difficult and expensive. Additionally, during period~s when the towers are not operating, an alternate service water discharge path must be available. Make-up flow to the cooling tower would be required to replace the blow-down flow, evaporative losses, and drift losses. The blow-down flow could range from approximately -25,000 gpm to approximately 72,000 gpm per tower depending on what concentration factor was used for the final design. The evaporative losses would range from 10,000 to 18,000 gpmn depending on winter/summer operation. The drift losses would be approximately 300 gpm. The total service water flow rate varies between the 13 PSE&G Permit Application 4 March 19W9 Appendix F Attachment 7 winter and summer (20,000 gpmiunit -winter operation and 40,000 gpmiunit -summer operation). Because the total service water flow could be less than the required make-up flow rate to the cooling towers by approximately 15,000 -50,000 gpm per unit, this analysis assumes that the cooling tower make-up would be supplemented from the River.This could result in the need for a total site influent requirement of approximately 260 million gallons on a particular day.. This additional cooling tower make-up flow would be provided from four new cooling tower make-up pumps (two pumps per unit). The new make-up pumps would be located in the existing circulating water intake bays 23A and 23B, thus requiring continued use of the present fish return system and traveling water screen system. The supplemental cooling tower make-up flow would be routed through the abandoned 84-inch circulating water line 23B to an area where the new circulating water lines to and from the cooling towers join the existing inlet at the southeast comer of the turbine btiilding. IV.D.5. Cooling Tower Blowdown The blowdown lines from each cooling tower would be routed in the circulating water system trench with the new circulating water lines. This new blowdown piping wouldalso be routed through an abandoned 84-inch circulating water line and discharged at the shoreiine. If a shoreline discharge were not allowed, then the blowdown system would require extensive changes to those assumed for this study. The velocity through the discharge piping must be high enough to preclude the voluntary penetration of the warmest discharge region of the discharge plume by fish and other motile organisms.New cooling tower blowdown pumps and a small diameter discharge pipe would be required to maintain the exit velocities high enough during the various modes of station operation. The installation of the cooling tower blowdown pumps and new discharge lines could adversely impact the outage schedule depending on the extent of the modifications. IV.D.6 Additional Considerations It is anticipated that two 4,600 Manitowoc cranes would be used for most picking andplacements during the installation phase. Dunnage (wood cribbing to spread the heavy load from the-cranes) is assumed to be required in all areas of construction for any crane work. The transmission line clearance in some of the areas would impact the construction activities. Smaller hydraulic/rough terrain cranes would be used in these areas as well as other congested areas. The use of the smaller cranes might limit the ability to move heavy loads during construction and would also require the cranes to operate in the excavated trench near the circulating water system piping because of their limited boom length.It is assumed that the removal of the access road near the location for the installation of the new circulating water lines would not adversely affect site access to the south side of the station.* 14 PSE&G Permit Application 4 March 99QQ Appendix F Attachment7 Because of the major electrical power requirements associated with the new circulatingwater pumps and (if mechanical draft towers were installed) the cooling tower fans, and their remote location relative to the existing station electrical distribution system, a separate distribution system, powered from the existing 500 kV switchyard, would be required.The design and construction schedule for the new pump house is based on the assumption that the cooling tower pumps would be installed via outside cranes, Therefore, no scheduled activity was included for a bridge crane.The above assumptions minimize outage times and avoid extended dual unit outages by scheduling the Unit 1 and 2 tie-in outages in series. Similarly it is assumed that the NJDEP final Permit would allow Salem to continue operation during construction and that tie-in outages will coincide with scheduled refueling outages.The tie-outages have been chosen to support the most timely completion of the retrofit work and are not predicated on waiting to coincide with previously scheduled refueling outages. The Unit 2 tie-in outage is scheduled to begin once the cooling tower is erected and ready for tie-in to the new system piping. The Unit 1 outage will proceed upon completion of the Unit 2 outage following a brief two-month slack period. This slack period will allow Unit I to remain operational during the peak sunmmer demand period.This series approach to construction outages will require the rescheduling of the existing Salem refueling schedule.Finally, the use of the brackish water from the River in a cooling water system requires special corrosion-resistant materials. Once the retrofit is complete, continuous chemical treatment of the recirculating cooling water would be required during Salem's operation to inhibit the corrosion that would otherwise occur.IV.E. Construction Issues There are several site conditions at Salem that would materially affect the retrofit. The cooling towers require an area of approximately 18 acres. Additionally, the cooling towers would need to be placed in an area at the station that would minimize impacts to other station equipment, such as switchyard equipment and transmission lines. Thenearest open area of sufficient size that satisfies these requirements is located approximately 2,000 feet east of the station, beyond the switchyard and between the main transmission lines.A closed-cycle cooling system retrofit would also require extensive excavation and subsurface construction. Artificial Island is flat and is elevated only a few feet above the River. Groundwater is encountered at a depth ranging from 4 to 10 feet below the surface throughout the site. Due to the depths of the subsurface construction activity (about 16 feet), groundwater would continuously infiltrate the excavations and would have to be continuously pumped out of the excavated areas during construction. 15 PSE&G Permit Application 4 March 19QP Appendix F Attachment 7 The composition of site soils would similarly affect design and construction. The firsttwo layers, consisting of dredge spoils and naturally occurring sand, gravel and clay, would provide inadequate support for the structures and facilities needed for the retrofit.The third layer of the soil, encountered at a depth of approximately 70 feet below the surface, called the Vincentown Formation, would provide adequate structural support. As a result, 200-foot long steel and concrete piles would have to be driven through the non-load bearing soils reaching approximately 30 feet into the load-bearing formation to support the structures and facilities needed for the retrofit. SWEC estimates that retrofitting Salem with closed-cycle' cooling would require the installation of over 20,000 of these 100-foot long piles.Large amounts of excavation and construction would be required in a highly congested area with a need to assure safety considering the adjacent 500,000-volt transmission lines.Many underground commodities would need to be avoided or rerouted. The majority of construction work would be outdoors and, therefore, the schedules and estimates are at risk for weather impacts. The schedules have been built around the requirement that concrete would not be placed during an assumed period of below freezing weather conditions. If freezing conditions are longer than assumed, there would be a schedule impact. Above normal precipitation would also delay the schedule due to, among other reasons, safety considerations and excessive dewatering requirements for excavation. For the reasons noted above, costs could be underestimated by up to an additional 20 percent, above the allowance for indeterminates applied, especially when judged against a"fixed price" contract standard. Any schedule duration increases would also result in higher replacement power costs than estimated. IV.F. Uncertainties and RisksThe scale of the required cooling system is a major factor in the projected difficulty. This scale is reflected in the quantity and size of piping, the depth and size (length and width)of the pipe trenches, number and length of supporting piles, the size and number of cooling towers, and the amount of reinforced concrete required. Another important factor that significantly exacerbates the complexity of retrofitting Salem with closed-cycle cooling is the inherent permanence and site-specific design of the original cooling system.There are no allowances for unexpected and unpredicted problems. It is not unusualduring fast-tracked projects to have increased rework since some activities are being started and even completed before all of the engineering and design is completed. With a fast track schedule with many simultaneous tasks work must proceed based on assumptions that may not be borne out when the engineering is complete. Construction problems, especially during the tie-in outage, would have significant cost and schedule impacts. Due to the unprecedented nature and the inherent difficulties of this type of* 16 0 PSE&G Permit Application 4 March I 99 Appendix F Attachment 7 work, the risks are large that there would be unanticipated impacts on the cost estimatesand schedules. Labor and equipment shortages also pose a significant source of uncertainty. This source of uncertainty has not been included in the schedules. This may also impact the cost estimates, due to the necessity to pay premium rates for labor and equipment during delays not accounted for in the original estimates. Due to the large quantity of material and equipment needed to install cooling towers, there is uncertainty regarding whether materials and equipment would be able to be obtained in a timely manner in order to meet schedule requirements. Procurement problems could also increase cost estimates due to the necessity to pay higher rates for expedited deliveries or make substitutions in favor of more expensive items to meet schedule requirements. V. LICENSING / PERMITTING The major environmental factors that would influence the permitting cycle and approvals required to convert Salem I and 2 to closed-cycle cooling are:* The height and visual obtrusion of the towers;" The impacts of the make-up and blowdown systems on marine biota and populations;

• Tower vapor plume effects due to size, frequency, or trajectory, including icing and fogging effects;" Local weather pattern influences resulting from the aggregate tower plumes of HopeCreek and Salem 1 and 2;" Salt drift from the towers on the nearby surroundings;, Noise impacts on neighbors;" Impacts of particulate emissions on air quality, including a PSD incremental analysis to determine whether emissions growth can be accommodated in the project and a PSD "additional impacts analysis" to assess the project's impact on soils, vegetation, and visibility.

Licensing the operation of Salem with cooling towers would require a number of local, state and federal approvals. The most significant of these are represented by the Coastal Area Facility Review Act (CAFRA) and the air pollution control permit.Regarding the air permit, a Prevention of Significant Deterioration (PSD) permit will be required if the addition of a cooling tower is considered a "modification" to an existing major source of air pollution under PSD regulations (40) CFR §52.21). Additional analysis of air contaminant emissions from the cooling tower would be required, but if potential emissions of Particulate Matter (PM) or PM- 10 (i.e. fine particulates) from the cooling tower exceed 25 tons per year (tpy) or 15 tpy, respectively, PSD would apply. It is likely that these thresholds would be exceeded even assuming low cooling tower drift 17 PSE&G Permit Application 4 March 1991 Appendix F Attachment rates and water constituent contents, given the large volume of flow through the tower.Therefore, this analysis assumes that a PSD permit will be required.The following approval times would be reasonable and have been assumed for this scenario: " Completion of the Environmental Impact Statement (EIS) four months after authorization to proceed with the overall project;" CAFRA approval 12 months after submittal; and" PSD approval 18 months following submittal. Licensing and permitting requirements pose a major source of uncertainty. It has been assumed that the designs used as a basis for the cost estimates and schedules provided here will be approved by the regulatory authorities. If not, there would be a cost impact which has not been included in the estimate. In addition, depending upon the particular permit and schedule, there is the potential for very significant schedule impacts due to delays in obtaining permits.See F-7 Table 1 for details of an assessment of the environmental permitting requirements for construction and operation of any new cooling towers.VI. STATION CAPACITY DERATING AND ENERGY LOSS Retrofitting a closed-cycle cooling system at Salem will reduce the Station's energy output. This is due to the increased back pressure on the turbihe exhaust as a result of increasing the cooling water temperature as well as the increased electrical loads associated with the operation of the closed-cycle cooling system. Note that the low pressure turbine-blade path is not optimized for the exhaust conditions would be associated with a cooling tower. The specific capacity penalties expected will fluctuate during the year for both assumed tower configurations as indicated in F-7 Tables 2 and 3.The capacity loss for natural draft and mechanical draft cooling tower systems at winter and summer peaks as defined by the PJM are described in F-7 Table 4. The data contained in the F-7 Tables 2-4 were used as the basis for the analysis of the value of lost power presented in Section F-IX.The added (auxiliary) power required to operate the circulating water pumps and (in the case of installed mechanical draft towers) fans will also result in a decrease in plant generation output capability. Compared to the existing once-through system these decreases would cause an important loss in station generation. Finally, the costs of the resulting station energy losses and capacity de-rating after the retrofit of 127,800 kW (net summer rating) and 4,800 kW (net winter rating) (natural draft scenario).and of 87,600 kW (net summer rating) and 21,000 kW (net winter rating)(mechanical draft scenario) are assessed in Appendix F-TX.18 PSE&G Permit Application 4 March 1~99 Appendix F Attachment V11. PROJECT SCHEDULE Based upon previous similar construction jobs, a realistic schedule duration has been assumed throughout (F-7 Table 5). However, in some cases, this duration may be somewhat optimistic. For example, special considerations have not been given to the construction and demolition activities that could be affected by buried commodities. In addition, based on previous experience at Salem, it is probable that below grade utilities exist in the construction areas that have not been identified. These underground interferences will complicate and slow down the construction progress.The cooling tower schedule assumes orderly efforts to permit, engineer, and construct a closed-cycle cooling system on a retrofit basis for each Salem unit. This approach allows engineering activities to start prior to PSE&G and co-owner funding and permit approval.This will allow equipment specifications to be prepared, proposals to be solicited and evaluated, and the successful contractors/equipment suppliers chosen. These activities would then allow the award of contracts to coincide with the receipt of the CAFRA and PSD permits. Several other schedule scenarios were evaluated in 1993 and it was concluded that this schedule scenario, although containing financial risk to PSE&G, was the most likely schedule that would be followed if closed-cycle cooling were to be retrofitted at Salem.This schedule scenario requires a duration of approximately five years, and avoids extended dual unit outages by scheduling the Unit I and 2 tie-in outages in series. It assumes that the Salem Units I and 2 refueling outages would be rescheduled to coincide with the construction tie-in outages. This scenario minimizes lost power costs but willincur some impact on system availability since one of the unit tie-in outages will coincide with the peak summer load period. It assumes a project authorization in January 2000, receipt of permits by July 200 1, and completion of the cooling retrofit project with the Salem Unit I startup in April 2006.This scenario represent a compliance-based schedule approach to retrofitting closed-cyclecooling utilizing natural draft cooling towers at Salem assuming an imposed compliance schedule from the NJDEP. This scenario selected two natural draft cooling towers (one per Salem generating unit) with a 14"F approach design to be installed over an engineering and construction period designed to complete the retrofit project in an expeditious time period with little opportunity for schedule slippage recovery.VILA. Schedule Basis The expected compliance schedule is based upon receipt of the CAFRA and PSD permits by July 2001. Several additional permits are required as listed in F-7 Table I but are not assumed to impact the schedule. All material purchase order awards and construction activities -would not begin until these permits are received.To maintain clarity or because of the unavailability of adequate design development, the following non-critical path activities are not included in the schedule: 19 PSE&G Permit Application 4 March 19gQ Appendix F Attachment 7* Licenses and permits other than the CAFRA and PSD permits a Design change package preparation and approval 0 Procurement and engineering of the required security system modifications

• CWS tie-ins, for example service water and yard drainage modifications" Control room and main control board modifications and other I&C work" Cooling tower blowdown Chemical Control System (new system required)These activities will not affect the schedule length; however, they do add to the complexity and overall cost of the engineering and construction effort.The durations which were developed for the major project activities assume a double shift of ten hours per day and six days per week and, as discussed below, around the clock coverage on the cooling pipe reinforcement.

The tie-in outages have scheduled to support the most timely completion of the retrofit work and are not predicated on waiting to coincide with previously scheduled refueling. outages. The Unit 1 tie-in outage would be scheduled to begin once the cooling tower erection is complete and ready for tie-in to the new system piping. The Unit 2 outage would proceed upon completion of the Unit I outage following a brief two-month slack period. This slack period would allow Unit 2 to remain operational during the peak summer demand period. This series approach to construction outages would require the rescheduling of the existing Salem refueling schedule.VII.B. Cooling Towers The cooling tower erection schedule is based on actual data from a previous project and manufacturer recommendations. The erection of the natural draft cooling tower shell is a weather dependent activity, so a winter shutdown from December 1 through March 1 is included.VII.C. Condenser Modifications The condenser modification is not a critical path outage activity and therefore, work would be performed on a 70-hour work week basis. Some work would be required during a prior outage to relocate interfering items such as piping, cable tray and ventilation ducts to provide access for the'condenser work. The installation of the condenser tube bundles would also require removal of the turbine building west side wall panels and shoring of platform steel.*20 PSE&G Permit Application 4 March 1999 Appendix F Attachment7 VII.D. Circulating Water Piping and Pump House The schedule duration for the new circulating water pipe installation, from the cooling tower to the tie-in location (with the existing pipe) and the pump house structural work were developed by assigning estimated man-hours to activities, developing crew sizes and calculating the resulting duration. The cooling tower pumps have a long lead time (approximately three years) for vendor engineering and fabrication. VIL.E. Contracting Strategy All required plant modifications and construction activities are assumed to be completed under three contracts:

1) Furnishing and erecting the Unit I and 2 cooling towers;2) Condenser modifications; and 3) A general construction contract for the piping and pump house.The schedule is based on a single general construction contract awarded immediately upon receipt of the CAFRA and PSD permits. The contract could be lump sum (fixed price) for the circulating water system pipe installation; however, all other work would have to be either unit price or cost reimbursable depending upon the completion of the.design at the time of contract award.The general construction contract provides the most efficient and cost effective methodfor the construction.

More importantly, however, the general construction contract approach offers greater assurance of meeting the project schedule.VII.F. Outage Schedules To ensure that all of the necessary work would be completed during the circulating water systemt/condenser modification outages, some construction and modification activities to relocate interfering items, etc. would have to be completed during the immediately preceding refueling outage. Further investigation would be needed to determine if these prior outages would have to be extended. For purposes of this schedule, these prior outages are assumed to be of sufficient length. Outages for each unit circulating watersystem tie-in, circulating water system pipe reinforcement, and condenser modifications would be approximately six months, including two months for testing and start-up.Because of the extent of the required demolition, pile driving, new circulating watersystem pipe foundations, existing piping reinforcement, and new piping installations, the Unit 1 and 2 outage tie-ins would have to be staffed with two shifts working six-days/week at ten hours/day and around the clock in the case of the pipe reinforcement. Adjustment to the station fuel cycles are assumed in this scenario so as not to incur additional fuel penalties due to shutting a unit down before all of its fuel is depleted.21 PSE&G Permit Application 4 March 1990 Appendix F Attachment 7 VI.G. Critical Path The critical activities for the outage preparation work would be obtaining the CAFRA permit, pile driving, cooling tower erection, installation of the circulating water piping from the pump house to the tie-in area, excavation for the tie-in area at the existing circulating water pipe, and material fabrication and delivery. The excavation of the tie-in area would be a time consuming operation, posing a large uncertainty in the constructionschedule, due to the interference of the underground utilities in the vicinity of the switchyard and the close proximity of the condensate polisher building. A trench approximately 140-ft. wide and 16-ft. deep is required. Because the site is only a few feet above the Delaware River, water would continuously infiltrate the trench requiring continuous removal.The outage duration is based on the time required to remove or demolish existing tie-in area piping, reinforce over 3,000 feet of existing circulating water pipe with corrosion resistant steel liners, drive piles to support tie-in pipe, build new pipe saddles and thrust blocks, remove existing condensers, and install new modular condensers. The tie-in work is located in the southeast comer of the plant yard area and is constrained by limited construction access due to existing buildings, underground and overhead power lines, underground pipes and transformers. VI.H. Uncertainties and Contingencies The schedule would likely either slip or advance depending upon station performance and when the refueling outages actually occur. Because of the seasonal nature of many of the construction activities, the timing of most of the critical activities would be dependent on the planned outages as well as the completion of the preceding activities. Delays in any of the permitting, engineering or construction work could ripple through the entire schedule resulting in quite lengthy delays in the entire project.Installation of the more than 4 miles of new 84-inch circulating water system piping and reinforcement of over 3,000 feet of existing piping, both pre-outage, are the mostuncertain area of the schedule. The combination of de-watering, no allowance for weather delays, and working one marshy soil with heavy construction equipment might significantly increase the duration of the pre-outage circulating water pipe installation. The system outage tie-ins could impact the schedule due to the limited access available in the area and probable difficulties in removing the existing circulating water system pipe sections. A detailed material handling study and schedule would need to be developed toconfirm the outage time periods.The potential for other building and component interference could cause constructiondelays and affect the overall schedule. Although site walk-downs and drawing reviews during the engineering phase might eliminate some of the potential problems, experience indicates that numerous unforeseen interferences and below grade utilities could adversely affect the schedule.22 PSE&G Permit Application 4 March 1990 Appendix F Att-chment 7 Chemical treatment of the cooling tower blowdown water and the other Salem waste streams (e.g., non-radioactive liquid waste) to meet allowable discharge requirements would require a new chemical treatment system and structure for each unit.All of these considerations might result in permitting, engineering and construction delays not currently addressed in the schedule.VIII. COST ISSUES VIII.A. GeneralVendor cost data have been used to estimate capital costs, operating and maintenance costs, and to develop a comparative cash flow analysis for each scenario. The data presented was selected based upon SWEC's experience with cooling tower construction, excavation, piping takeoff quantities adjusted for the Salem site, and operating and maintenance costs, including the natural draft cooling tower currently operating at Hope Creek. Plant capacity de-rating and energy loss that would result from retrofitting closed-cycle cooling was calculated by SWEC from a detailed computerized model of the Station's power cycle.An allowance for indeterminates was applied separately to each item in the cost estimate to account for the level of engineering/design that was performed to develop each activity and the pricing structure on which the estimate is based. The allowance reflects moneys which will be expended during the course of the retrofit for activities that have not been explicitly developed. In 1993, PSE&G requested Sargent & Lundy (S&L) to perform an independent assessment of the 1990 SWEC study. S&L evaluated the SWEC retrofit construction schedule and developed its own 1993 capital cost estimates. S&L verified the results as discussed in its report, which was included as Exhibit 8 to the 1993 Appendix K. The description and schedule information and costs developed by SWEC in 1993 for the various scenarios form the basis for most of the costs data used in this report.This schedule assumed would require "overmight" capital costs of more than $550 million (1998 dollars), and operating and maintenance costs of more than $5 million per year, and would require at least five years for permitting, engineering, procurement, and construction. The capital costs were developed by SWEC by contacting equipment suppliers, or where appropriate, various 1993 capital cost values were escalated to 1998 using a total combined escalation of 14 percent for the period 1993 to 1998. This retrofit would also involve additional lost power costs as set forth in Appendix F-IX and Attachments F-9 and F-10.23 PSE&G Permit Application 4 March 1999 Appendix F Attachment 7 VIII.B. Capital Cost of Installation Using the arrangements illustrated in F-7 Figures 2 through 5, SWEC developed capital cost estimates. These cost estimates are presented in F-7 Tables 6 and 7. Quantity estimates for piping, excavation and backfill, dredging, concrete, and similar items were developed. Material and labor prices were developed using in-house unit prices (e.g., dollars/cubic yards of concrete) and labor rates for the Salem area. Capital equipment costs. pumps, valves, cooling towers, etc., were developed from available vendor prices.The estimate of an "overnight" construction cost based on 1993 dollars escalated to 1998 dollars is provided for each alternative. Allowances for indirect expenses are based on percentages developed by PSE&G and include allowances for PSE&G and outside engineering services.Retrofitting a once-through cooling water system for closed-cycle cooling would require the construction of cooling towers, supporting systems and structures such as pump houses, and sufficient circulating water piping to form a closed loop system. Retrofitting Salem for closed-cycle cooling would be wide-scale and complicated for the following reasons:* The minimum space required for the cooling towers would be an area of approximately 18 acres. The nearest open area of sufficient size that satisfies these requirements is located approximately 2,000 feet east of Salem, beyond the switchyard and between the main transmission lines.* The retrofit would require extensive excavation and subsurface construction. Artificial Island is flat and only a few feet above the Delaware River. Groundwater would have to be continuously pumped out of the excavated areas during construction.

• Continuous chemical treatment of the brackish Delaware River water would be required during station operations to inhibit the corrosion that would otherwise occur." Retrofitting Salem with closed-cycle cooling would require the installation of over 10,000 100-ft long piles to support the cooling towers, piping and other structures." The retrofit would involve two phases -a new construction phase and a demolition and reconstruction phase -and require the construction of either two natural draft cooling towers or six mechanical draft cooling towers.

Several other structures including pump houses and chemical treatment buildings would also need to be constructed.

• The retrofit project would also require the installation of over 4 miles of new 7-ft diameter circulating water piping to connect the cooling towers to the existing cooling water system to complete the closed-cycle loop." The installation would require the excavation of a trench approximately 140 feet wide, 16 feet deep, and 2,000 feet long, and the relocation of several transformers and miscellaneous buildings." A de-chlorination system, makeup and blow-down system, electric station, and substantial electrical cabling would also need to be installed to provide support for the closed-cycle cooling system operation.

24 PSE&G Permit Application 4 March 1999 Appendix F Attachment 7" A section of the existing piping would have to be demolished and reconstructed to connect the new piping from cooling towers to the existing circulating water system. Over 3,000 feet of existing circulating water piping would be reinforced by welding corrosion-resistant steel plates inside the pipe.* The condenser in each unit would be replaced, requiring the removal and replacement of the west wall of the turbine buildings along with numerous pipes, electrical cables, and other equipment.

• Piping reinforcement and condenser replacement would be needed to accommodate the higher water pressures associated with the closed-loop system.Retrofitting Salem for closed-cycle cooling would not simply involve adding cooling towers to the existing cooling wate 'r system. Rather, it would require substantial new construction and demolition and reconstruction activities that would result in replacing, reinforcing, or abandoning the entire existing system. Such a project would be wide-scale and complicated and would be unprecedented in an operating nuclear plant the size of Salem.Capital cost estimates for the retrofit range from approximately

$500 to $700 million dollars alone depending on the cooling tower technology used and the permit requirements. Lost power costs would also be incurred during the demolition and reconstruction outages and over the remaining life of the plant, due to the decreased plant efficiency. VIII.C. Operating and Maintenance This section identifies and discusses the major categories of recurring annual operating and maintenance costs associated with both natural and mechanical draft tower designs.Estimates of these costs are from several sources. Where possible, the experience of the Hope Creek cooling tower has been utilized; lacking that, the general cooling tower experience of the utility industry is employed as a basis. F-7 Table 8 summarizes all cost results.There are several facets of operating costs. Both cooling tower schemes require 4,000 kW of additional energy (compared to existing once-through) to pump a total of about 550,000 gpm, per unit through the lengthy piping network to and from the two-pass condensers and up to the top of the hot water distribution systems on the towers.Considerably more pumping power will be expended than used by the existing system because of the greater length of the circuit and the static head which must be overcome at the cooling tower. Further, the mechanical draft cooling towers for each unit require an additional 8,000 kW of energy to power the 66 fans (40-foot diameter each) which provide the necessary ambient cooling air.Other operating costs would be associated with: 25 PSE&G Permit Application 4 March 1999 Appendix F Attachment 7.The frequent detailed inspections of the internal, external and air moving equipment* (applicable to mechanical draft tower design only); and The operation, sampling, testing and cost of chemicals to provide continuous chemical control of the over 1.5 billion gallons of water that wouldbe circulated through the cooling towers each day.Maintenance costs would be appreciable because of the large quantity of materials and equipment associated with what would be an immense installation of cooling equipment. These costs would be expended in upkeep, repairs and modifications to the structure, fill section, lighting, chemical control systems, hot water spray distribution system, fans, motors, switchgear, drift eliminators and basin. Make-up and blowdown system components which serve the tower complex would also require periodic upkeep and repair.Estimated operating and maintenance costs are shown in F-7 Table 8. It is expected that there would be no reduction in any existing operating and maintenance costs resulting from the retrofitting of closed-cycle cooling. In addition, even though station electrical output is lower with closed-cycle cooling, there would be no savings in fuel costs due tothe cited losses in efficiencies and higher expenditure of auxiliary power. The information contained in F-7 Table 8 is used in developing the revenue requirementanalysis (Appendix F-IX). The 1990 operating and maintenance estimates have been appropriately escalated by a 21.4 percent compound escalation factor for 1998.IX. ALTERNATIVE CLOSED-CYCLE COOLING SYSTEM DESIGNS There are several alternative closed-cycle cooling systems in addition to natural and mechanical draft towers. As discussed below, however, none of these are appropriate for installation at Salem.IX.A. Spray Canals Spray canals use the same cooling principle as cooling towers -- that is, evaporative cooling. In a spray canal, the cooling water flows through a series of canals that contain a system of pumps and piping that spray a mist of water into the air. The water is cooled by evaporation and falls back into the canal. Spray canals have been used at some plants for supplemental cooling, usually with a cooling lake or once-through cooling. Spray canals are not used at any large plant for complete cooling. They have several disadvantages. First, the thermal performance of spray canals has been poor. Cooling performance is sensitive to droplet size, wind speed, and interference effects between adjacent sprays. All of these factors are difficult to control. Second, drift losses are higher than with a cooling tower. Third, spray canals create a low fog. Fourth, a large amount of land is required to provide adequate cooling. Currently there are no reliable models f6r predicting spray canal performance that would support application of this system at Salem.26 PSE&G Permit Application 4 March 19Q9 Appendix F Attachment 7 IX.B. Cooling Lake Where adequate land is available, a man-made lake is a common source of cooling for large nuclear units. Approximately 2 acres of cooling lake per megawatt of capacity isrequired. The actual size depends on local weather conditions, lake configuration, lake depth, and heat load. For the two Salem units, a lake with approximately 4,400 acres would be required. There is not an adequate amount of land available at Artificial Island to further consider this alternative. IX.C. Unconventional Systems Unconventional designs could possibly be suggested to lower the initial capital and operating costs. However, the uncertainties associated with such designs are large and increase the risk that the system may not perform adequately. Because the circulating water system is a very large system, subsequent modifications to install anunconventional design would be difficult, could require a long outage, and could be verycostly. The performance of the circulating water system directly affects the performance of the turbine and the electrical output of the unit. A small loss in cooling tower or condenser performance has a large impact on plant output. A significant failure in this iystem would shut the unit down. Consequently, only proven system designs were considered in order to ensure the availability and operability of the units. 27 PSE&G Permit Application 4 March 1999 Appendix F Attachment 7 F-7 Table 1. Preliminary Assessment Of Environmental Permitting Requirements For Construction and Operation Of Cooling Towers.CONSTRUCTION RELATED APPLICATION AGENCY TOTAL TIME TO PERMIT/APPROVAL AGENCY PREPARATION REVIEW TIME OBTAIN PERMIT CAFRA Permit NJDEP 4-6 months 6-12 months 10-18 months Waterfront Development NJDEP 2-3, months 2-6 months 5-9 months Permit Freshwater Wetland Permit NJDEP 3-4 months 6-12 months -16 months USACOE Permit NJDEP 1-2 months 2-4 months 3-6 months NJPDES Permit NJDEP 1-2 months 2-4 months 306 months Modifications NJPDES Stage 2 Treatment NJDEP 1-2 months 2-4 months 3-6 months Works Approval Air Pollution Control NJDEP 3-4 months 12-14 months 15-18 months Permit to Construct -Assumes No PSDDRBC Docket Approval DRBC 1-2 months 3-6 months 4-8 monthsNote: Most of these permit applications require that at least a portion of the project engineering be complete in order to have sufficient information for preparation of the permit applications. The construction schedule must allow time for this engineering and design work to be completed prior to preparation of the permit applications. OPERATION RELATED APPLICATION AGENCY TOTAL TIME TO AGENCY PREPARATION REVIEW TIME OBTAIN PERMIT NJPDES Stage 3 Treatment NJDEP 1-2 months 2-4 months 3-6 months Works Approval NJPDES Permit NJDEP 1-2 months 2-4 months 3-6 months ModificationsNote: The stage 3 Treatment Works Approval requires submittal of complete as-built drawings.

• PSE&G Permit Application 4 March 1999 Appendix F Attachment 7 F-7 Table 2. Natural Draft Cooling Tower Generating Capacity Comparison (Gross and Net Electrical Power per Unit).-Single Unit Generating Capacity (kW) -Natural Draft Tower Once-Through DifferenceJanuary- Gross Gen. 1,159,342 1,158,712

+630 February Net Gen. 1,112,342 1,115,712 -3,370 March-April Gross Gen. 1,151,796 1,160,034 -8,238 Net Gen. 1,104,796 1,117,034 -12,238 May-June Gross Gen. 1,130,567 1,159,523 -28,956 Net Gen. 1,083,567 1,116,523 -32,956 July-August Gross Gen. 1,118,071 1,145,462 -27,391 Net Gen. 1,071,071 1,102,462 -31,391 September- Gross Gen. 1,135,068 1,159,792 -24,724 October Net Gen. 1,088,068 1,116,792 -28,724 November- Gross Gen. 1,155,848 1,159,574 -3,726 December Net Gen. 1,108,848 1,116,574 -7,726 PSE&G Permit Application 4 March 1999 Appendix F Attachment 7 F-7 Table 3. Mechanical Draft Cooling Tower Generating Capacity Comparison (Gross and Net Electrical Power per Unit).-Single Unit Generating Capacity (kW) -Mechanical Draft Tower Once-Through Difference January- Gross Gen. 1,160,360 1,158,712 +1,648 February Net Gen. 1,105,360 1,115,712 -10,352 March-April Gross Gen. 1,159,650 1,160,034 -384 Net Gen. 1,104,650 1,117,034 -12,384 May-June Gross Gen. 1,147,417 1,159,523 -12,106 Net Gen. 1,092,417 1,116,523 -24,106 July-August Gross Gen. 1,136,785 1,145,462 -8,677 Net Gen. 1,081,785 1,102,462 -20,677 September-Gross Gen. 1,152,392 1,159,792 -7,400 October Net Gen. 1,097,392 1,116,792 -19,400 November-Gross Gen. 1,160,206 1,159,574 -632 December Net Gen. 1,105,206 1,116,574 -11,368 PSE&G Permit Application 4 March 1999 Appendix F Attachment 7 F-7 Table 4. Plant Performance Comparison (All performance values are for a single 3423 MWt unit).Summer Rating Winter Rating Rating Natural Mechanical Existing Natural Mechanical Existing Draft Draft Tower Once Draft Draft Parameters Once Tower (1 (3 per Unit) Through Tower Tower (3 Through per unit) (1 per unit) per unit)Temperature (OF)CW Supply/Tower 77 77 77 39 39 39 Makeup CW Return/Tower 91 93 83 53 51 49 Blowdown Ambient Air-Dry Bulb N/A 94 94 N/A 15 15Ambient Air-Wet Bulb N/A 76 76 N/A 13 13Condenser Inlet 77 93 83 39 51 49 Condenser Outlet 91 122 111 53 79 77 Average Condenser Back 2.08 4.31 3.27 0.77 1.38 1.32 PressureGross Electrical Output 1,155,100 1,095,200 1,123,300 1,158,700 1,160,300 1,160,200 (kW)Hotel Loads (kW) 43,000 47,000 55,000 43,000 47,000 55,000 Circ. Water Pumps 6,700 10,700 10,700 6,700, 10,700 10,700 (kW)Cooling Tower Fans N/A N/A 8,000 N/A N/A 8,000 (kW)Net Electrical Output (kW) 1,112,100 1,048,200 1,068,300 1,115,700 1,113,300 1,105,200 Net Output Diff. (kW) (1) Base - 63,900 -43,800 Base -2,400 -10,500 Station Heat Rate 10,500 11,140 10,933 10,470 10,490 10,568 (BTU/KW-HR) ..IHeat Rate Diff. (BTU/kW- Base 640 430 Base 20 100 HR) 6S Activlty Descripotion START ENGINEERING AUTHORIZATION ro PROCEED UNIT 20UTAGE/CWS TESTING .sTARTUP UNIT 2 OUTAGEICWS TESTING & STARTUP CAFRA PERMIT SUBMISSION & APPROVAL PSD PERMIT SUBMISSION & APPROVAL COMPLETE ENVIRONMENTAL STATEMENT PILING -SPEC 3ID/EVAIUAWARD CONDENSER MODIFICATION -EVALUATION CONDENSER CONDENSER MODIFICATION VENDOR CONDENSER MODIFICATION-FABMI2ELIVER-UNIT 211 CONDENSER TUBES-SPEC BIDMEVAUAWARD CONDENSER TUBES -FAa/DELIVER -UNIT 211 RELOCATE INTERFERENCES -UNIT 2 RELOCATE INTERFERENCES -UNIT 1 CONDENSER MODIFICATION -UNIT 2 CONDENSER MODIFICATION -UNIT 1 OPTIMIZATION STUDY/PILOTISOIL BORING PLANAWARD SOIL BORING CONTRACTISOIL BORINGSCOOLING TOWER -SPEC/BID(EVAIJAWAROCOOLING TOWER -VENDOR ENGINEERING FOUNDATION DESIGNDEWATER AREA PROCURE PILES DRIVE PILES -UNIT 2"r T 1It LL H M 1 1M L 1 1 1 1 1 111 11-J-11111111 I FT j1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 i 0 i i i i A i 0 2 1 P 1 1 1 1 1 1 1 I ' l l ' ' I ' l l-4 4 1 1 1 1 1 i i ; 1 1 1 1 1 i ff m 1 1 1 ] 1 1 1...... ..... .... ... .. ...............= I I I I I I I I ---W1111111111 III :11 :1;;I -I ý I -I ..1 1 1 1 .1 1 .....I l .............1 M J , k il ii I ii iii I II I~I COOLtNG TO WERIC W RETROFIT PUBLIC SERVICE ELECTRIC A GASOVERALL

SUMMARY

SCHEDULE 1-........ im-" I I F-7 Table 5. Overall Summary Schedule~1>T F-7 Table 5. (continued) 0 NATURAL DRAFT CO( S TOWERCASH FLOW ESTIMATt ANALYSIS 1998 OVERNIGHT COST FOR TWO UNIT PROJECT EXPECTED COMPLIANCE SCHEDULE r r U ESTIMATED DESCRIPTION OF COST ELEMENTS COSTS 1998 $'s TOTAL AFI$TOTAL $INCL.AFI YEAR OF EXPENDITURE ($ x 1,000)20012002 2003 2004 2005 2006 TOTAL 4 9 I II 2005 t10 NATURAL DRAFT COOLING TOWER ( 2 EACH)1.1 TOWERS, BASINS & DEEP PILE FNDNS 1.2 TOWER DEPOSITION $1,113$228$$82,0601$28,842 $ 110,902 2,2371 $ 2,237$0$o$16,635$0$33,269$0$49,905$o$9,981$2,009$110,902$2,237 TOTAL COOLING TOWER 2.0 CIRCL WATER PUMPS & STRUCTURES 2.1 STRUCTURE, INCL. BLDG SVC 2 2 CIRCULATING WATER PUMPS 2.3 AUXIL POWER FEED -PUMPS 2.4 ELECTRICAL SUPPORT SYSTEMS TOTAL CIRCL WATER PPS & STRUCTURES

3.0 CIRCULATING

WATER PIPING 3.1 PIPE SADDLES ( INCL. THR. BLKS & EXCAV)3.2 CIVIL WORK INTERFACE 3.3 PIPING 3.4 PIPE ROUTING INTERFACES

3.5 MOD'S

TO EXISTING YARD PIPING 3.6 CIRC WATER VALVES 3.7 REMOVE AND RELOCATE GUARDHOUSE 3.8 SITE CONSTRUCTION DRAINAGE 3.9 MASTER PLAN 3.10 VALVE PITS 3.11 LIFT STATIONS 312 SAFETY RELATED COMPONENTS 3.13 DEWATERING 3.14 AFFECTS OF DEWATERING 3.15 CAP ABANDONED PIPE 3.16 OFFSITE SOIL DISPOSAL 3.17 REINFORCE EXISTING PIPE TOTAL CIRCULATING WATER PIPING$ 82,060 $ 31.079 $ 113,139 $0 $16,635 $33,269 $49,905 $11,990 $1,341 $113,139$ 22,374 $ 6.712 $ 29,086 $0 $0 $0 $13,035 $14,592 $1,459 $29,086$ 8,182 $ 818 $ 9,000 $0 $0 $907 $5,399 $2,694 $0 $9,000$ 7,969 $ 1,594 $ 9,562 $0 $0 $0 $9,562 $0 $0 $9,562$ 435 $ 108 $ 544 $0 $0 $0 $544 $0 $0 $544$ 38,960 $ 9,233 $ 48.192 $0 $0 $907 $28,540 $17,286 $1,459 $48,192$ 35.502 $ 9,363 $ 44,865 $0 $0 $15,732 $18,012 $9,297 $1,824 $44,865$ 8,127 $ 4,063 $ 12,190 $0 $0 $3,648 $6,125 $2,018 $399 $12,190$ 21,587 $ 4,617 $ 26,204 $0 $7,866 $6,482 $5,244 $5,472 $1,140 $26,204$ 10,160 $ 5.080 $ 15,240 $0 $0 $4,560 $7,488 $2,622 $570 $15,240$ 803 $ 207 $ 1,010 $0 $57 $353 $399 $166 $34 $1,010$ 2,350 $ 235 $ 2,584 $0 $0 $513 $2,071 $0 $0 $2,584$ 223 $ 44 $ 268 $0 $0 $80 $188 $0 $0 $268$ 106 $ 21 $ 127 $0 $34 $34 $35 $17 $6 $127$ -$ 4,475 $ 4,475 $0 $1,824 $2,651 $0 $0 $0 $4,475$ 1,118 $ 559 $ 1,677 $0 $0 $1,368. $309 $0 $0 $1,677$ 1,118 $ 1,118 $ 2,237 $0 $0 $1,824 $413 $0 $0 $2,237$ 2,822 $ 1,129 $ 3,950 $0 $0 $0 $3,152 $661 $137 $3,950$ 5,841 $ 1,460 $ 7,302 $0 $2,166 $2,166 $2,166 $667 $137 $7,302$ -$ 2,068 $ 2,068 $0 $0 $1,034 $1,034 $0. $0 $2,068$ 1,678 $ 839 $ 2,517 $0 $0 $0 $0 $2,095 $422 $2,517$ 2,586 $ 516 $ 3,102 $0 $0 $2,326 $310 $386 $80 $3,102 $ -$ 4,459 $ 4;459 $0 $0 $0 $0 $3,706 $752 $4,459 2-.'V$$$42,771$134,273 9 94,020 1 $40,252 134,273$0$11,947$46,946$27,108$5,501 t 9 F-7 'Table 6. NATURAL DRAFT COC ; TOWER CASH FLOW ESTIMAIt ANALYSIS1998 OVERNIGHT COST FOR TWO UNIT PROJECT EXPECTED COMPLIANCE SCHEDULE*w.

4.0 DESCRIPTION

OF COST ELEMENTS ESTIMATED COSTS 1998 $'s TOTAL AFI$TOTAL $INCL.AFI YEAR OF EXPENDITURE ($ x 1,000)I I 1 I 2001 2002 2003 2004 2005 2006 TOTAL t w +MAKEUP & BLOWDOWN SYSTEM 4.1 PIPE SADDLES INCLUDING CIVIL WORK 4.2 PIPING 43 MOD'S TO EXIST PPG/INTERFERENCES

4.4 FOULING

CONTROL PROGRAM TOTAL MAKEUP & BLOWDOWN SYSTEM$$$$827 3,264 1,601$$$$206 933 686 5,719$$$$1,033 4,196 2,287 5,719$0$0$0$0$0$0$0$0$516$1,050$573$0$516$1,049$573$4,575$0$1,892$1,026$858$0$205$114$286$1,033$4,196$2,287$5,719 5.0 SECURITY, INCL. FENCING 6.0 TURBINE BLDG/CONDENSER MODIFICATIONS

6.1 MODULAR

TWO PASS CONDENSER 6.2 CONDENSER STRUCTURAL MOD'S 6.3 LARGE PIPE MODIFICATION

6.4 SMALL

PIPE MODIFICATION 6.5 I&C 6.6 SUPPORTS AND PENETRATIONS 6.7 RIGGING/REINFORCEMENT TOTAL TURB BLDG/COND MODIFICATIONS

7.0 DILUTION

PUMPIING SYSTEM 7.1 REROUTE RADWASTE TO CW DISCHARGE 7.2 REROUTE CW INLET TO DISCHARGE 7.3 CHEMICAL CONTROL SYSTEM TOTAL DELUTION PUMPING SYSTEM$ 5,691 $ 7.545 $ 13,235 $0 $0 $2,140 $6,713 $3,777 $605 $13,235$ 447 $ 112 $ 559 $0 $0 $171 $388 $0 $0 $559$ 65,166 $ 11,848 $ 77,014 $0 $2,622 $27,574 $23,712 $20,826 $2,280 $77,014$ 2,307 $ 1,154 $ 3,461 $0 $0 $0 $342 $2,663 $456 $3,461$ 6,694 $ 1,338 $ 8,032 $0 $0 $0 $0 $6,892 $1,140 $8,032$ 1,674 $ 334 $ 2,008 $0 $0 $0 $0 $1,723 $285 $2,008$ 1.702 $ 340 $ 2.042 $0 $0 $0 $0 $1,757 $285 $2,042$ 2,307 $ 1,154 $ 3,461 $0 $0 $0 $0 $2,891 $570 $3,461$ 2,307 $ 1,154 $ 3,461 $0 $0 $0 $0 $2,891 $570 $3,461$ 82,158 $ 17,321 $ 99,479 $0 $2,622 $27,574 $24,054 $39,642 $5,586 $99,479$ 1.154 $ 577 $ 1,731 $0 $0 $0 $513 $1,218 $0 $1,731$ 1,154 $ 577 $ 1.731 $0 $0 $0 $513 $1,218 $0 $1,731$ 5,216 $ 2,607 $ 7,823 $0 $0 $0 $5,258 $2,337 $228 $7,823$ 7,5231 $ 3,761 $ 11,284 $0 $0 $0 $6,284 $4,772 $228 $11,284 TOTAL DIRECT COSTS$ 310,858$ 109,302$ 420,160$o$31.204$106,832$162,830$104,575$14,720$420,160 F-7 Tabilontinued)

• 3 NATURAL DRAFT CO( 3 TOWER CASH FLOW ESTIMAT- ANALYSIS 1998 OVERNIGHT COST FOR TWO UNIT PROJECT EXPECTED COMPLIANCE SCHEDULE 00 ESTIMATED TOTAL TOTAL $ YEAR OF EXPENDITURE DESCRIPTION OF COST ELEMENTS COSTS AFI INCL. ($ x 1,000)1998 $'s $ AFI 2001 2002 2003 2004 2005 2006 TOTAL 8.0 ENGINEERING

8.1 ENGINEERING

AND DESIGN $ 61,736 $ 12,347 $ 74,083 $11,112 $32,399 $17,696 $6,032 $3,828 $3,016 $74,083 82 TESTING $ 1,213 $ 120 $ 1.333 $0 $0 $0 $0 $969 $364 $1,333 8.3 INSUR. FUNDING, LICENSES, & PERMITS $ 4,853 $ 2,426 $ 7,279 $1,080 $2,282 $1,255 $855 $855 $952 $7,279 TOTAL ENGINEERING $ 67,802 $ 14,893 $ 82,695 $12,192 $34,681 $18,951 $6,887 $5,652 $4,332 $82,695 TOTAL DIRECTS AND ENGINEERING $ 378,660 $ 124,195 $ 502,855 $12,192 $65,886 $125,783 $169,717 $110,227 $19.052 $502,855 90 DISTRIBUTABLE COSTS $ 36,341 $ 18,170 $ 54,511 $0 $3,960 $13,807 $21,055 $13,751 $1,938 $54,511 TOTAL EST -CAPITAL COSTS $ 415,001 $ 142,365 $ 557.366 $12,192 $69,846 $139,589 $190,772 $123,978 $20,990 $557,366 Notes: I. Based on Expected Compliance Schedule dated January 1, 1999 2. Includes changes in total construclion costs due to premium work and shift work 3. Include revised cooling lower quotation costs 4. Present day costs as of 1998, excludes escalation beyond that date F-7 TIable 6. (continued) PSE&G Permit Application 4 March 1999 Appendix F Attachment 7 0 MECHANICAL DRAFT COOLING TOWER ESTIMATE ANALYSIS 1998 OVERNIGHT COST FOR TWO UNIT PROJECT ACCELERATED SCHEDULE 1993 $'S 1998 $'S DESCRIPTION OF COST ELEMENTS ESTIMATED TOTAL TOTAL $ ESTIMATED TOTAL TOTAL $COSTS AFI INCL. COSTS AFR INCL.$ $ AFS $ AFI 1.0 [MECHANICAL DRAFT TOWERS 1.1 TOWERS, BASINS & DEEP PILE FNDNS $ 145,000 $ 36,000 $ 181,000 $ 150,400 $ 37,341 $ 187,7401.2 TOWER DEPOSITION $ -$ 2,000 $ 2.000 $ $ 2,280 $ 2,280 1.2 AUXILIARY POWER FEED $ 15,500 $ 2,500 $ 18,000 $ 17,670 $ 2,850 $ 20,520 TOTAL COOLING TOWER $ 160,500 $ 40,500 $ 201,000 $ 168,070 $ 42,471 S 210,540 2.0 ICIRCL WATER PUMPS & STRUCTURES 2.1 STRUCTURE, INCL. BLDG SVC $ 20,000 $ 6,000 $ 26,000 $ 22,800 $ 6,840 $ 29,640 1 2.2 CIRCULATING WATER PUMPS $ 7,000 $ 700 $ 7,700 $ 8,182 $ 818 $ 9,000 2.3 AUXIL POWER FEED'- PUMPS s 7.500 $ 1,500 $ 9,000 $ 8,550 $ 1,710 $ 10,260i 2.4 ELECTRICAL SUPPORT SYSTEMS $ 400 $ 100 $ 500 $ 456 $ 114 $ 570 1TOTAL CIRCL WATER PPS & STRUCTURES $ 34,900 $ 8,300 $ 43,200 $ 39,988 $ 9,482 $ 49,470 3.0 ]CIRCULATING WATER PIPING 3.1 PIPE SADDLES (INCL. THR. BLKS & EXCAV) $ 36,400 $ 9,600 $ 46,000 $ 41,496 $ 10,944 $ 52,440 3.2 CIVIL WORK INTERFACE $ 7,200 $ 3,600 $ 10,800 $ 8,208 $ 4,104 $ 12,312 3.3 PIPING $ 18,700 $ 4,000 $ 22,700 $ 21,318 $ 4,560 $ 25,878 3.4 PIPE ROUTING INTERFACES $ 9,000 $ 4,500 $ 13,500 $ 10,260 $ 5,130 $ 15,390 3.5 MOD'S TO EXISTING YARD PIPING $ 715 $ 185 $ 900 $ 815 $ 211 $ 1,026 3.6 CIRC WATER VALVES $ 2,000 $ 200 $ 2,200 $ 2,280 $ 228 $ 2,508 3.7 REMOVE AND RELOCATE GUARDHOUSE $ 200 $ 40 $ 240 $ 228 $ 46 $ 274 3.8 SITE CONSTRUCTION DRAINAGE $ 100 $ 20 S 120 $ 114 $ 23 $ 137 3.9 MASTER PLAN $ $ 4,000 $ 4,000 $ -$ 4,560 $ 4,560 3.110 VALVE PITS $ 1,000 $ 500 $ 1,500 $ 1,140 $ 570 $ 1,710 3.11 LIFT STATIONS $ 1,000 $ 1,000 $ 2,000 $ 1,140 $ 1,140 $ 2,280 3.12 SAFETY RELATED COMPONENTS $ 2,500 $ 1,000 $ 3,500 $ 2,850 $ 1,140 $ 3,990 3.13 DEWATERING $ 5,600 $ 1,400 $ 7,000 $ 6,384 $ 1,596 $ 7,980!S3.14 AFFECTS OF DEWAT-ING $ -$ 2,000 $ 2,000 $ $ 2,280 $ 2,280 3.15 CAP ABANDONED PIPE $ 1,500 $ 750 $ 2,250 $ 1,710 $ 855 $ 2,565 3.16 OFFSITE SOIL DISPOSAL $ 2,500 $ 500 $ 3,000 $ 2,850 $ 570 $ 3,420:TOTAL CIRCULATING WATER PIPING $ 88,415 $ 33.295 $ 121,710 $ 100,793 $ 37,956 $ 138,749 4.0 MAKEUP & BLOWDOWN SYSTEM 4.1 PIPE SADDLES INCLUDING CIVIL WORK $ 800 $ 200 $ 1,000 $ 912 $ 228 $ 1,140 4.2 PIPING $ 2,800 $ 800 $ 3,600 $ 3,192 $ 912 $ 4,104 4.3 MOD'S TO EXIST PPG/INTERFERENCES $ 1,400 $ 600 $ 2,000 $ 1,596 $ 684 $ 2,280 4.4 FOULING CONTROL PROGRAM S -$ 5,000 $ 5,000 $ -$ 5,700 $ 5,700 F-7 T: I- '. + I. .1-F'%;f- 7. MECHANICAL DRAFT COOLING TOWER ESTIMATE ANALYSIS 1998 OVERNIGHT COST FOR TWO UNIT PROJECT ACCELERATED SCHEDULE 1993 $S 1998 $'S DESCRIPTION OF COST ELEMENTS ESTIMATED TOTAL TOTAL $ ESTIMATED TOTAL TOTAL $COSTS AFI INCL. COSTS AFI INCL.$ $ AFI $ $ AFI!TOTAL MAKEUP & BLOWDOWN SYSTEM $ 5,000 $ 6,600 $ 11,600 $ 5,700 $ 7,524 $ 13,224-i 5.0 SECURITY, INCL. FENCING $ 400 $ 100 $ 500 $ 456 $ 114 $ 570 6.0 ITURBINE BLDG/CONDENSER MODIFICATIONS 1 6.1 MODULAR TWO PASS CONDENSER $ 55,000 $ 10,000 $ 65,000 $ 62,700 $ 11,400 $ 74,100 1 6.2 CONDENSER STRUCTURAL MOD'S $ 2,000 $ 1.000 $ 3,000 $ 2,280 $ 1,140 $ 3,420 6.3 LARGE PIPE MODIFICATION $ 6,000 $ 1,200 $ 7,200 $ 6,840 $ 1,368 $ 8,208 6.4 SMALL PIPE MODIFICATION $ 1,500 $ 300 $ 1,800 $ 1,710 $ 342 $ 2,052 6.5 I&C $ 1,500 $ 300 $ 1,800 $ 1,710 $ 342 $ 2,052 1 6.6 SUPPORTS AND PENETRATIONS $ 2,000 $ 1,000 $ 3,000 $ 2,280 $ 1,140 $ 3,420 6.7 RIGGING/REINFORCEMENT $ 2,000 $ 1,000 $ 3,000 $ 2,280 $ 1,140 $ 3,420!TOTAL TURB BLDG/COND MODIFICATIONS $ 70,000 $ 14,800 $ 84,800 $ 79,800 $ 16,872 $ 96,672 7,0 DILUTION PUMPIING SYSTEM 7.1 REROUTE RADWASTE TO CW DISCHARGE $ 1,000 $ 500 $ 1,500 $ 1,140 $ 570 $ 1,710 I 7.2 REROUTECWINLETTO DISCHARGE $ 1,000 $ 500 $ 1,500 $ 1,140 $ 570 $ 1,710 I 7.3 CHEMICAL CONTROL SYSTEM $ 4,600 $ 2,300 $ 6,900 $ 5,244 $ 2,622 $ 7,866 iTOTAL DELUTION PUMPING SYSTEM $ 6,600 $ 3,300 $ 9,900 $ 7,524 $ 3,762 $ 11,286 TOTAL DIRECT COSTS $ 365,815 $ 106,895 $ 472,710 $ 402,331 $ 118,181 $ 520,512 8.0 !ENGINEERING

8.1 ENGINEERING

AND DESIGN $ 61,599 $ 12,320 $ 73.919 $ 71.455 $ 14.291 $ 85,746* 8.2TESTING $ 1.371 $ 137 $ 1.508 $ 1,563 $ 156 $ 1.7198.3 INSUR, FUNDING, LICENSES, & PERMITS $ 5,482 $ 2,741 $ 8,223 $ 6,249 $ 3,125 $ 9,374 TOTAL ENGINEERING $ 68,452 $ 15,198 $ 83,650 $ 79,267 $ 17,572 $ 96,839 TOTAL DIRECTS AND ENGINEERING $ 434,267 $ 122,093 $ 556,360 $ 481,598 $ 135,753 S 617,351 9.0 'DISTRIBUTABLE COSTS 9.1 CONSTRUCTION DISTRIBUTABLES $ 43,427 $ 21,713 $ 65,140 $ 49,507 $ 24,753 $ 74,260 9.2 SHIFT DIFFERENTIAL $ 4,000 $ 1,000 $ 5,000 $ 4,560 $ 1,140 $ 5,700 TOTAL DISTRIBUTABLES $ 47,427 $ 22,713 $ 70,140 $ 54,067 $ 25,893 $ 79,960 TOTAL EST -CAPITAL COSTS $ 481,694 S 144,806 $ 626,500 $ 535,665 $ 161,646 $ 697,311 Notes: 1. Based on Expected Compliance Schedule dated January 1, 1999 F-7 Table 7. (continued) MECHANICAL DRAFT COOLING TOWER ESTIMATE ANALYSIS 1998 OVERNIGHT COST FOR TWO UNIT PROJECT ACCELERATED SCHEDULE 1993 $'S 1998 $'S DESCRIPTION OF COST ELEMENTS ESTIMATED TOTAL TOTAL $ ESTIMATED TOTAL TOTAL $COSTS API INCL. COSTS AFI INCL.$ $ AFI $ AFI 2. Includes changes in total construction costs due to premium work and shift work 3, Include revised cooling tower quotation costs 4. Present day costs as of 1998, excludes escalation beyond that date F-7 Table 7. (continued) PSE&G Permit Application 4 March 1999 Appendix F Attachment 7 F-7 Table 8. Cooling Tower Annual Operating & Maintenance Costs (All Cost Data is for Two Units).Costs in 1998 x 1,000 I. Operating Natural Draft Mechanical Draft Circulating Water Pumping Power Net 1,493 1,493 Increase (Assumes 70%Unit Capacity Factor)*Cooling Tower Fan Power (Assumes 70% Unit N/A 2,986 Capacity Factor)*Periodic Operator Checks 109 164 Chemical Control System 1,922 1,922 Total Operating Costs 3,524 6,565 Costs in 1998 x 1,000 II. Maintenance Natural Draft Mechanical Draft Structural Members & Fill Repairs/Replacement 1,457 3,156 Electrical Equipment N/A 647 Tower Sludge Removal 62 140 Chemical Control System 152 152 Total Maintenance Costs 1,671 4,095 Total O&M Costs 5,195 10,660*These operating costs are considered as part of Salem's de-rating and are not included with the O&M costs -in Appendix F-IX.0) PSE&G Permi[ Application 4 Maicb 1999 Appendix F Attachment 7 LEGEND 1 BARGE SLIP 2 SERVICE WATER INTAKE 3 SALEM FUEL OIL STORAGE TANK 4 SECURITY CENTER 5 TURBINE BUILDING 6 REACTOR BUILDING 7 AUXILIARY BUILDING 8 #1 OIL/WATER SKIM TANK9 #2 OIL/WATER SKIM TANK 10 #3 OIL/WATER SKIM TANK 11 NON-RAD LIQUID WASTE DISPOSAL SYSTEM 12 OIL WATER SEPARATOR CN-qg DSN 49113 PROPOSED VSD BUILDING SECURITY FENCE F-7 Figure 1. Site Layout PSE&G. Permit Application 4 March 1999 Appendix F Attachment 7 PROPOSED ROUTING NEW CW PIPING-GUARD HOUSE-LOCATION OF CW SYSTEM TIE-INS CONDENSATE POUSHING BUILDING -UNIT I EXISTING CW INTAKE PIPING-EXISTING INTAKE STRUCTURE-EXISTING CW DISCHARGE PIPING SERVICE WATER INTAKE STRUCTURE DELAWARE RNIER S SALEM GENERATING STATION NATURAL DRAFT COOLING TOWER GENERAL ARRANGEMENT NJPDES PERMIT NO. NJ0005622 F-7 FIGURE 2 0-A'0 0 PSE&G Permit Application 4 March ]999 Aovrendix F Attachment 7 S SALEM GENERATING STATION MECHANICAL DRAFT COOLING TOWERGENERAL ARRANGEMENT NJPDES PERMIT NO. NJ0005622 F-7 FIGURE 4 0 APPENDIX F ATTACHMENT 8 SCHEDULE FOR MODELING UNIT OUTAGES AND FLOW REDUCTIONS SPONSOR: DAVID HARRISON, Jr.NATIONAL ECONOMIC RESEARCH ASSOCIATES PSE&G RENEWAL APPLICATION SALEM GENERATING STATION PERMIT NO. NJ0005622 4 MARCH 1999 S PSE&G Pe,-n A pc2it!,)on 4 March !49L Apper.dix F TABLE OF CONTENTS I. PLANNED REFUELING OUTAGES ........................................................................ 2 11. REVISED REFUELING OUTAGE SCHEDULE ............................................... 3 III. SEASONAL FLOW REDUCTION ALTERNATIVE .................. 3 IV. CONSTRUCTION OUTAGES ........................................................................... 3 I PSE&G Perm,: .P~ohcauon March ')')Appendix F ATTACHMENT F-8 SCHEDULE FOR MODELING UNIT OUTAGES AND FLOW REDUCTIONS The analysis of the costs and benefits of fish protection alternatives in Section IX of Appendix F includes plant outages or reductions in intake flows that occur for severalreasons. Plant outages are required for refueling as well as during construction of certain fish protection alternatives. Seasonal reductions in intake flows would .protect fish during the most biologically productive periods. The analyses of the costs and benefits of fish protection alternatives assume that these outages and flow reductions are scheduled to occur on specific future days. This attachment reports the schedules used for the purposes of modeling potential station outages and reductions in intake flows under the following conditions: " Planned (refueling) outages (under normal station operations)." Revised refueling outage schedules." Seasonal flow reduction alternatives.

• Construction outages (for closed-cycle natural and mechanical draft cooling alternatives).

These schedules are used for planning purposes to evaluate the costs and benefits of fish protection alternatives. During station outages (refueling, revised fueling, and construction of closed-cycle cooling towers), one unit of the two units would cease power production, and five of the six intake pumps would be shut off. During flow reductions,both units would reduce their intake flows.The descriptions below provide further details on each of these operating conditions and their schedules. Further details on the methodology used to determine the timing of the revised refueling outage schedule and seasonal flow reductions can be found in Attachment F-4. Attachment F-7 discusses the feasibility and constraints in shifting refueling outage schedules. I. PLANNED REFUELING OUTAGES Planned refueling outages are periods during which the plant shuts down to undergo refueling. The refueling outage schedule is provided by PSE&G and presented below in F-8 Table 1. This schedule is used in modeling the value of lost power and the quantity of fish protected for all alternatives except for the revised refueling outage schedule. Eachunit undergoes refueling every 18 months. The duration of these scheduled outages typically lasted 60 days; however, Salem has set a target of 39 days beginning in 2002.For purposes of calculating losses associated with Station outages, 39 days is the moreconservative estimate, (i.e., it projects higher losses) and is therefore used in this analysis.Thus, the outages schedule includes one 60-day outage and five 39-day outages over an eight-yeap-cycle. Outages are timed so that they occur in either the spring or fall, with at least one unit operating at all times. After 2009, the outage schedule is replicated, withthe year 2001 schedule being used in year 2010. Units do not generate any energy during refueling, although one of the six intake pumps operates.* PSE&G P.rit ,i:)plicIavon 4 March :99 Appendix F II. REVISED REFUELING OUTAGE SCHEDULE The revised refueling outage schedule changes the timing of the planned outage schedule to coincide with the most biologically productive period of the year. The schedule is determined by choosing the outage schedule that maximizes the quantity of fish protectedwhile meeting several constraints. First, refueling for each unit must occur every 18 months. Second, there must be a 6-month (26-week) separation betveen the outages at each unit. Thus, outages for Units I and 2 cannot be placed back-to-back. Third, the length of each outage must be consistent with the original planned outage schedule. Thus, all outages are 39 days in length, except for a 60-day outage occurring once every eight years. The 60-day outage for each unit is placed in the same year as the 60-day outage in the base case. The schedule appears in F-8 Table 2. After 2009, the outage schedule is replicated, with the year 2001 schedule being used in year 2010.I11. SEASONAL FLOW REDUCTION ALTERINATIVE The 13-week flow reduction period is chosen to coincide with the most biologically productive periods of the year. Attachment F-4 provides details on the methodology for determining this schedule. The period of reduced flow, which is presented below in F-8 Table 3, is in addition to the planned outage schedule in F-8 Table 1.IV. CONSTRUCTION OUTAGES With the exception of the two tower alternatives-mechanical draft and natural draft closed-cycle cooling-all construction outages necessary for installing the alternativescan be scheduled to coincide with normal refueling outages. However, the two cooling tower options would require construction outages in addition to normal refueling outages.This outage is projected to occur during 2005 and 2006. This construction outage period, which is presented in F-8 Table 4, is in addition to the planned outage schedule in F-8 Table 1. PSE&G Permit Applicatiorn 4 March 1999 Appendix F Attachment 8 Tables F-8 Table 1. Outage Schedule for Planned RefuelinmgOutage Period Year Unit 1 Unit 2 2001 Day 123 to 182 2002 Day 285 to 323 Day 61 to 99 2003 Day 249 to 308 2004 Day 100 to 138 2005 Day 281 to 319 Day 78 to 116 2006 Day 252 to 290 2007 Day 97 to 135 2008 Day 277 to 315 Day 128 to 166 2009 Day 252 to 290 Schedule is presented in annual cumulative days (i.e., the "xl" day of the year, often called Julian days).F-8 Table 2. Outage Schedule for Revised Planned Refueling'Outage Period Year Unit 1 Unit 2 2001 Day 162 to 221 2002 Day 344 to 17 (of2003) Day 162 to 200 2003 Day 344 to 38 (of 2004)2004 Day 162 to 200 2005 Day 344 to 17 (of2006) Day 162 to 200 2006 Day 344 to 17 (of 2007)2007 Day 162 to 200 2008 Day 344 to 17 (of2009) Day 162 to 200 2009 Day 344 to 17 (of 2010)a Schedule is presented in annual cumulative days (i.e., the "xh' day of the year, often called Julian days).F-8 Table 3. Schedule for Seasonal Flow Reductions (10 Percent, 20 Percent and 45 Percent)'Outage Period Year Unit I Unit 2 2001 -2023 Day 162 to 252 Day 162 to 252 Schedule is presented in annual cumulative days (i.e., the "xth'" day of the year, often called Julian days).F-8 Table 4. Outage Schedule for Cooling Tower Construction' Outage Period Year Unit 1 Unit 2 2005 Day 274 to 365 Day 1 to 212 2006 Day I to 120 Schedule is presented in annual cumulative days (i.e., the "xth day of the year, often called Julian days). .APPENDIX F ATTACHMENT 9 THE VALUE OF LOST ENERGY AND CAPACITY SPONSOR: DAVID HARRISON, Jr.NATIONAL ECONOMIC RESEARCH ASSOCIATES PSE&G RENEWAL APPLICATION SALEM GENERATING STATION PERMIT NO. NJ0005622 MARCH 4,1999 PSE&G -ý:ct:on 4 nMarc-, 1z9F 9 TABLE OF CONTENTS I.THE VALUE OF LOST POWER: AN OVERVIEW ................................................. 2 I.THE VALUE OF LOST CAPACITY .......................................................................... 2 II.A.The Value of Lost Capacity: Construction Outages .................................... 3 II.B.The Value of Lost Capacity: Changes in Continuing Operation ................ 3 III.THE VALUE OF LOST ENERGY ................................ 4 III.A.The Value of Lost Energy: Construction Outages ..................................... 4 III.B.The Value of Lost Energy: Changes in Continuing Operation ....................... 5 III.C.The Value of Lost Energy: Seasonal Flow Reductions and Revised Refueling O utage Schedule ...................................................................................... 5 REFERENCES ........................................................................................................ 6 ENDNOTES ............................................................................................................ 7 8 PSE&G Permit ApplI:cation 4 March 1999 Appendix F ATTACHMENT F-9 THE VALUE OF LOST ENERGY AND CAPACITY Implementation of fish protection alternatives would reduce the quantity of energy and capacity that Salem could produce. Section IX includes the value of lost power as one component of the costs of fish protection alternatives. This attachment provides background and methodologies for estimating the value of lost power.I. THE VALUE OF LOST POWER: AN OVERVIEW Electricity generation units are valued for both the total amount of energy they generate and the capacity they provide to meet peak power demands. Energy generation is valued since it enables economic activity and provides consumer benefits. Capacity is valued for helping to maintain a reliable supply of electricity that insures critical energy demands are met at all times. The value of lost power includes the value of the lost energy and capacity, as well as the costs associated with changes in air emissions that occur when the lost power is produced at other fossil-fuel generating plants. This attachment discusses the value of lost capacity energy. Attachment F-Il discusses the value of air emissions.This study considers capacity and energy losses resulting from a number of actions, including:

1. Construction outages; and 2. Reductions in potential station output after.the installation of an alternative, due to: (a) energy needed to operate auxiliary equipment

("hotel" loads);(b) annual reductions in station efficiency;'(c) seasonal reductions in station efficiency (due to flow reductions); and (d) shifts in planned station outages.The following two sections describe the methodologies for estimating the value of lost capacity and energy.II. THE VALUE OF LOST CAPACITY The methodology used to estimate the value of lost capacity is based on the operations of the Pennsylvania-New Jersey-Maryland (PJM) power pool. PJM currently imposes capacity obligations on load serving entities, such as PSE&G. The capacity obligation is defined as the amount of installed capacity necessary to meet the annual peak load plus a reserve component, which is typically 20 percent. Electric utilities currently must pay penalties if they do not meet their capacity obligations. PJM has two separate seasonal periods during which different penalties are applied. The peak period encompasses thirteen weeks of the summer months. During the peak period, the capacity shortfall from a unit outage (other than a forced outage) must be replaced, or else PJM charges the company a Capacity Deficiency Rate (CDR), expressed in $/MW-day. Historically, companies have found that purchasing capacity from another company in PJM is more cost-effective than paying PJM, since capacity can usually be purchased at a lower price than the CDR. We assume that PSE&G would purchase capacity from another company at the market rate for peak period capacity, rather than pay the CDR penalty. We further 2 PSE&G Permit Application 4 March 9199 Appendix assume that month to month variations of the market rate will be small. This is a reasonable assumption since the obligations for all capacity market participants are determined annually. An average monthly capacity price is then estimated by taking the PJM annual capacity price and dividing by twelve. The non-peak period includes the remaining days of the year. PJM currently does not require that a company compensate for capacity shortfalls due to planned outages during this period. However, we foresee that in the future PRM will penalize companies for capacity shortages outside of the peak period. We assume that the value of capacity associated with reductions in the non-peak period will be based on half of the nominal megawatts, but at the same PJM monthly capacity price.All estimates of the value of lost capacity.through the year 2011 are based on PSE&G's forecast of the PJM market price of peak period capacity as reported in the recent PSE&G Energy Master Plan (Response to Staff Request, S-PS-SC-13). These prices are presented in F-9 Table 1. Beyond 2011, PSE&G forecasts capacity prices to increase at a rate of 1.5 percent per year (in nominal dollars).II.A. The Value of Lost Capacity: Construction Outages The monthly value of lost capacity for construction outages is estimated by multiplying the Salem unit's monthly rating (in MW) by the relevant capacity price (in S/MW-month) for each of the days during the outage. Annual capacity value is calculated by adding the monthly capacity value over the outage's duration. The total value is calculated by summing the annual values, with appropriate discounting. The timing and duration of outages are presented in Attachment F-8.II.B. The Value of Lost Capacity: Changes in Continuing Operation The value of lost capacity for changes in continuing operations are made under two different conditions:

1. Reductions in capacity; or 2. Scheduled outages on specific dates.The methodology for estimating the value of lost capacity under each of these conditions is described below.1. Permanent Reductions in Capacity A permanent increase in load and/or decreased efficiency in a unit represents an effective change in the unit's capacity rating. If a company faces a decrease in the rating of any of its units, currently it must acquire the equivalent amount of megawatts lost to maintain its capacity obligation as defined by PJM. As with construction outages, we assume that PSE&G will purchase capacity at the PJM capacity market if capacity is required to compensate for permanent rating changes. Consistent with PJM's capacity accounting, we estimate the monthly value of lost capacity for each alternative by multiplying the forecasted PJM annual capacity price by the effective monthly derate. Since PJM S PSE&G Permit Application4 March 1999 Appendix Fdetermines a company's annual installed capacity based on summer tests of unit ratings, the summer derates are assumed constant throughout the year for this calculation.

2. Outages and Reductions on Specific Dates The value of lost capacity for seasonal flow reductions and for the revised refuelingoutage schedule depends on the value of capacity on certain dates affected by alternatives.

For the seasonal flow reductions, lost capacity value is estimated using the same approach as the value of lost capacity for construction outages. The capacity lost due to flow reductions in each month is multiplied by the relevant capacity prices. For the revised refueling outage schedule, the value of lost capacity is the net value of shifting the outagefrom the regular schedule to the revised schedule. Consequently, the net capacity value isthe difference between the value of capacity for the planned outage schedule and revised refueling outage schedule. The value of capacity for each of these outages is estimated using the same approach as for construction outages.II. THE VALUE OF LOST ENERGYThe value of lost energy is obtained by using results from PROMOD, a computer model that simulates the future operation of the PJM system and calculates production costs.PROMOD is a detailed, industry-standard computer simulation model licensed from Energy Management Associates of Atlanta, Georgia and used by PSE&G and most members of PJM. Runs are consistent with PSE&G's Energy Master Plan (see Response to Staff Request, S-PS-SC- 11).The value of lost energy for each alternative is based on forecasts of monthly energy costs. These monthly forecasts are generated using two simulation runs. The first assumes normal operating conditions of the PJM energy market. (Note that normal Salem refueling outages are not included in this simulation.) The second simulation is the alternative case that assumes one of the Salem units would be removed from service while still meeting the same level of demand. (For a unit removed from service, the model simulates no electric energy production and no fuel or variable O&M costs.)Subtracting the total PJM production costs for the two cases yields monthly lost energyvalues for one of the Salem units. We refer to this estimate as the PJM system value of a Salem unit. A PJM system cost per MWh ($/MWh) can be calculated by dividing the PJM system cost impact by the unit's expected energy output (in MWh) from the first run when both Salem units are available. F-9 Table 2 shows the monthly PJM system cost per MWh when a Salem unit is out from 2001-2021. II.A. THE VALUE OF LOST ENERGY: CONSTRUCTION OUTAGES The monthly value of lost energy during an outage is estimated by adding the relevant PJM monthly system costs (when one Salem unit is out) for all months in which there is a construction outage. The total value is calculated by summing annual energy values across years, with appropriate discounting. The PJM system cost of one of the Salem units is used, since the other unit would produce energy while one was out for construction. 4** PSE&G Permit Application 4 March 1999 Appendix F III.B. The Value of Lost Energy: Changes in Continuing Operation The value of lost energy for changes to continuing operation is estimated for every month by multiplying the energy loss in each month (in MWh) due to the changes in continuing operation by the monthly PJM system cost per MWh. The annual value of lost energy for each year is estimated by summing costs across months. Monthly energy losses are calculated assuming normal operations, including planned outages for refueling. The magnitudes of the energy losses for each alternative depend on these auxiliary power requirements and reductions in plant efficiency, which are reported in Section VIII.III.C. The Value of Lost Energy: Seasonal Flow Reductions and Revised Refueling Outage Schedule The value of lost energy for Seasonal Flow Reductions is calculated for every month by multiplying the energy loss in each month due to seasonal flow reductions by the monthly PJM system cost per MWh. The annual value of lost energy for each year is estimated by summing costs across months. Monthly energy losses are calculated assuming normal operations, including planned outages for refueling. The value of lost energy for the revised refueling outage schedule is calculated by taking the difference between the PJM system costs with the original and revised schedules. The schedules for these outages and flow reductions are provided in Attachment F-8. The estimates of energy loss for the seasonal flow reductions are presented in Section VHI.5* PSF&G Permit Application 4 March 1999 Appendix F REFERENCES -Attachment F-9 Public Service Electric & Gas Company. "PSE&G Production Cost Analysis to Estimate Energy Revenues," Response to Staff Request S-PS-SC-11. Public Service Electric & Gas Company. "Market Value of Power," Response to Staff Request S-PS-SC-13. 6 6

• PSE-.G Apoilcaton 4 NIarch i999 Appendix F ENDNOTES iFor example, in the case of cooling towers, there is loss of efficiency due to increased turbine backpressure.

7 PSE&G Permit Application 4 March 1999 Appcndix F Attachment 9 Tables F-9 Table 1. PJM Capacity Price Forecasts Year 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 Market Value ($/kW-Yr)$30$33$34 $34$35$36$36$37$37$38$38$39$39$40 $41$41$42$42$43$44$44$45$46$46 Notes: All values are in nominal dollars. Values after 2011 are escalated at 1.5 percent annually.Source: PSE&G Energy Master Plan*g 2

• PSE&G Permit Application 4 March 1999 Appendix F F-9 Table 2. Forecasts of Value of Lost Energy per MWh (Monthly PJM System Energy Cost per MWh)Value of Lost Energy ($IMWh)Year 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 Jan$22$24$24$25$27$27$27$29

$31$30$35$35$35$35$34$34$34$34$34$33$33 Feb$27$31$31$27$34$33$32$34$37$37$39$38$38$38$38$37$37$37$37$37$36 Mar$23$23$24$24$24$22$25$27$26$27$28$28$27$27$27$27$27$27$27$26 $26 Apr$17$14$20$14$14$16 $15$16$19$15$15$15$15$15$15$15$15$15$14$14$14 May$10$10$12$11$11$13$12$12$13$13$13$13$13$13 $12$12$12$12$12$12$12 Jun$12$14$15$14$15$15$16$16$17$16$17$16$16$16$16$16$16$16$16$16$16 Jul$20$20$20$19$19$20$21$22$24$26$26$26 $26$26$26$25$25$25$25$25$25 Aug$17$19 $19 $18 $18 $19 $19$21 $21$22$22$22$22$22$22 $22$22 $22$21$21$21 Sep$16$18$19$18$20$18$18$19$21$21$23$23 $23$23$22$22$22$22$22$22$22 Oct$20$16$19$18$18$17$21$19$21$21$22$22$22$21$21$21$21$21$21$21$21 Nov$18$15$21$20$18$18$24$24$23$26$26$25$25$25$25$25$25$24$24$24$24 Dec$18$19$22$20$20$22$23$25$25$26$28$28$27$27$27$27$27 $27$26$26$26 Average$18$18$20$19$20$20$21$22$23$23$24$24$24.$24$24$24$24$23$23$23$23 Notes: All values are in 1998 dollars.Source: PSE&G Energy Master Plan

• A 3 APPENDIX F ATTACHMENT 10 THE VALUE OF INCREASED AIR EMISSIONS COSTS DUE TO LOST POWER SPONSOR: DAVID HARRISON, Jr.NATIONAL ECONOMIC RESEARCH ASSOCIATES PSE&G RENEWAL APPLICATION SALEM GENERATING STATION PERMIT NO. NJ0005622 4 MARCH 1999 0 TABLE OF CONTENTS I.CONCEPTUAL BACKGROUND

................................................................................. 2 I.A.No Regulation, Emission Standards, or Technology Standards ....................... 2 I.B.Emissions Cap with Tradeable Permits ......................................................... 3 II.SULFUR DIOXIDE (SO,) ........................................................................................ 3 II.A.Regulation ....................................................................................................... 3II.B.How the Values for SO, Emissions are Modeled ......................................... 4 II.C.Projection of SO 2 Allowance Prices ............................................................ 4 III.OXIDES OF NITROGEN (NOx) ......................................................................... 4 III.A.Regulation .................................................................................................... 4 III.B.How Cost Impacts are Modeled ......................................................................... 5 III.C.Projection of NOx Allowance Prices ................................................................. IV.CARBON DIOXIDE (CO,) ........................................................................................ 5 IV.A.Regulation ....................................................................................................... 5 IV.B.How Cost Impacts are Modeled ..................................................................... 6 IV.C.Projections of Marginal Environmental Impacts and Allowance Prices for CO 2 ...................................................................................................................... 6 REFERENCES .................................................................................................................. 7 ENDNOTES ........................................................................................................... 8 1 ATTACHMENT F-10 THE VALUE OF INCREASED .IR EMISSIONS COSTS DUE TO LOST POWVER Implementation of fish protection alternatives at Salem would lead to increases in power generation at PSE&G and other generating plants, including fossil fuel plants that emit SO,. NOx, and CO 2.The Salem facility does not produce these emissions. Thus, increases in emissions due to increased production at these other plants constitute part of the costs of the fish protection alternatives. This attachment outlines the methodology used to estimate the value of these air emission costs.I. CONCEPTUAL BACKGROUND Changes in air emissions can impose two types of costs on society: 1. Environmental impacts; and 2. Added pollution control costs.Which of these two types of costs are imposed depends upon the nature of the regulatory requirements imposed on emitters. There are two cases." Case A: No regulation, emission standards or technology-based standards. If no regulations are imposed or if the regulations are based upon emission standards (e.g., maximum emissions per unit of input or output) or technology-based standards (i.e., requirements to adopt a particular emission control technology), increased emissions from one facility can add costs associated with environmental impacts." Case B: Emissions cap with tradable allowances. In contrast, if the regulations establish an emissions cap and allow emitters to trade allowances (i.e., right to emit) among themselves, increased emissions from one facility lead to added pollution control costs rather than environmental impacts.The following subsections explain these two cases in more detail.I.A. No Regulation, Emission Standards, or Technology Standards Under these regulatory approaches, increased emissions from one facility may not be offset by reductions elsewhere, which would result in an increase in total emissions. When total emissions increase, the potential social costs also increase. For example, the New Jersey Department of Environmental Protection has cited potential social costs such as the marginal effects of increased emissions on the health of individuals, possible increased health care costs, lost productivity due to illness, property damage, and damage to natural resources. Marginal costs, which measure the damage of the next increment of emissions given current levels, are more relevant than average costs, because marginalcosts measure the increase in costs given existing emission levels from all sources. In other woids, increases in emissions from fossil-fueled generators could potentiallyincrease social environmental impact under these regulatory approaches. I.B. Emissions Cap with Tradeable Permits If pollutants are regulated by an emissions trading program in which total emissions are capped (known as a "cap-and-trade" progran), increased emissions from one facility would not increase the total emissions from all facilities included in the program.Increased emissions from one facility would be offset by reductions at other facilities, leaving total emissions from facilities within the program constant. As a result, the implementation of fish loss reduction alternatives would not create additional environmental impact costs due to an increase in total emissions. Although total emissions within the program would not change, the cost of keeping total emissions below the emissions cap would increase. The change in cost could be estimated by calculating the difference between the total cost of achieving the cap with and without the Salem power affected by each alternative. Because Salem generates no emissions, however, a simpler approach is available. To offset the additional emissions from other power, additional emissions reductions would need to come from existing sources. The cost of achieving additional abatement of air emissions would be equal to the marginal cost of emissions reductions from existing facilities. The total costs of abating emissions from other sources can therefore be calculated as the marginal cost of abatement times the quantity of additional emissions from the other power.Determining the marginal cost of abatement is typically a complex and detailed process.However, if the trading program operates efficiently, the market price of allowances would equal the marginal cost of abatement. Thus, emission allowance prices can be used to estimate marginal abatement costs. The additional air emission costs of the power can be estimated as the allowance prices times the quantity of additional emissions. The remainder of this attachment describes the specific methodologies used to estimate the costs for SO2, NOx and CO 2, the three air pollutants for which costs are calculated.(These calculations ignore other pollutants that may increase, such as particulate matter and mercury when fossil fuel generation increases.) These descriptions include a summary of current regulations, the approach used to model cost impacts, and the data sources.II. SULFUR DIOXIDE (SO 2)II.A. Regulation Title IV of the 1990 Clean Air Act mandates an allowance trading system for SO, emissions from electric utilities (see Ellerman et al. 1997 for details on the SO2 tradingprogram). The program caps the allowable utility SO 2 emissions and allows utilities to trade SO 2 allowances. (An allowance gives the owner the right to emit one ton of SO 2.)The progiam aims for a 50 percent reduction in emissions from the electric utilitygenerating sector from 1980 levels. Over the implementation period, the size of the cap isgradually constrained and the number of utilities affected is expanded. The cap on Phase I plants (263 units) starts at 7.1 million tons in 1995 and drops to 6 million tons in 1999. In 2000, Phase 1I plants are added, making virtually every fossil-fuel fired electric 8 3 generating unit subject to the cap. The eventual cap on annual emissions is 8.95 Mt SO, per year in the year 2010. Firms are allowed to trade emissions allowances. Allowances also may be banked for use or. trade in future years. II.B. How the Values for SO, Emissions are Modeled By 2001, SO 2 emissions from virtually all electric generation facilities in the United States will be capped. Additional SO2 emissions from other units, therefore, will not increase total SO 2 emissions. The added emissions, however, will carry an additionalcost, since complying with the emissions cap will be more costly. The cost of increased SO 2 emissions attributed to each alternative is calculated by multiplying forecast allowance prices per ton of emissions times the quantity of additional tons of SO, emissions that result from other power. The quantity of additional SO 2 emissions is provided by PSE&G as a part of their forecasts. II.C. Projection of S02 Allowance Prices Allowance price forecasts are based on current allowance price indexes from CantorFitzgerald Environmental Brokerage Services (1998a) and Fieldston Publications (1994-1998). These indexes are based on the price of actual trades and current buyer and seller offers. An average of the two sources for the most recent two months (December 1998 and January 1999) is used to form a 1998 base year allowance price. This 1998 base year price is S199 per ton of SO 2.For allowance prices in future years, vintage allowance prices are used. Vintage allowances can be purchased today, but are not valid for use until the allowance's vintage year, at which time they can be used for compliance or banked.ý' The final values forallowance prices used in each year are included in F-10 Table 1. Future year prices are estimated by multiplying the base year allowance price by the vintage price adjustments from Cantor Fitzgerald."' III. OXIDES OF NITROGEN (NOx)III.A. Regulation In 1994, a group of northeastern states participating in the Ozone Transport Commission (OTC) committed themselves to achieving region-wide NOx emission reduction targets by 1999 and 2003 through an emissions trading program. (See NESCAUM/MARAMA (1996) for details on the NOx Budget Program.) The NOx Budget Program is a "cap and trade" program that allows large generators of NOx emissions to trade allowances to meet the emission targets in a cost-effective manner. Emission targets are limited to a five-month control period from May to September. A number of states in the OTC, including New Jersey, have proposed and passed rules implementing the cap-and-trade program.The analysis assumes that all participating states will have passed laws by 2001.The participating states have committed to achieving a 75 percent reduction from 1990 levels in NOx emissions (55 percent in Northern areas) by the year 2003. The target willbe achieved in two stages, one in 1999 and the second more stringent stage coming into 4'A effect in 2003. Allowances are distributed based upon the allocation formulas established in each state's implementing rule. Firms are allowed to trade emissions allowances, so long as they hold enough allowances to cover actual emissions. Allowances may be banked, though their value may be diminished if the quantity of banked allowances in the region is high.III.B. How Cost Impacts are Modeled Starting in 1999, NOx emissions during the months of May to September from virtually all electricity generation facilities in New York, New England, and some mid-Atlantic states will be capped under the OTC NOx Budget Program. Assuming that additional power generation in response to reductions at Salem occurs in facilities subject to the cap,the added power would produce no net increase in total emissions in the region. The added power, however, would result in added costs, since more pollution control wouldbe necessary for total emissions to remain under the cap. The additional cost of complying with the NOx cap is estimated by multiplying forecast NOx Budget allowance prices times the quantity of added tons of NOx emissions that result from replacement power during the months. of May to September. Information on the additional NOx emissions is provided by PSE&G as a part of their replacement power data.NOx emissions outside of the May to September period could in theory result in additional environmental impacts, since these emissions are not regulated by the cap-and-trade program. However, the principal impacts from NOx result from ground-level ozone formation. Since in the Northeast there are virtually no exceedances of the federal ambient air quality standards for ozone outside of the five-month control period, the analysis assumes the environmental impacts from NOx outside of the May to September period are zero.III.C. Projection of NOx Allowance Prices While the emissions cap is not in force until the 1999 ozone season, trade in NOx budget allowances began in late 1997. Since there is still significant uncertainty in the NOx allowance market, the average of prices for vintage 1999, 2000, and 2001 allowances is estimated over the most recent two-month period (December 1998 and January 1999).Allowance market index values from Cantor Fitzgerald Environmental Brokerage Services (1998b) and Natsource (1998) are used. The base year value for 1999 is S3,333per ton of NOx. No vintage adjustment for NOx allowance prices is used. The final values for allowances prices used in each year are included in F-10 Table 1.IV. CARBON DIOXIDE (CO 2)IV.A. Regulation No regul~itions currently constrain emissions of carbon dioxide (C0 2). However, the Kyoto Protocol initiated in December 1997 calls for significant reductions of greenhouse gas (GHG) emissions from Annex 1 countries (mainly developed countries) by the period 2008-2012. The U.S. Kyoto target is to reduce emissions by 7 percent below 1990 levels.3~5. Although the Protocol has not been ratified, this analysis assumes that the Kyoto Protocol will be implemented in its current form.IV.B. How Cost Impacts are Modeled Before the proposed Kyoto implementation dates, the analysis assumes no regulation of CO, emissions. Replacement power generates additional CO2 emissions that are valued based upon the marginal impacts they generate. Impacts are calculated by multiplying the annual CO2 emissions from other power by an estimate of the dollar value of the marginal impacts generated by C00 emissions based on the literature.The analysis assumes that starting in 2008, emission levels would be capped based upon the commitments made at Kyoto. This analysis assumes that the U.S. will adopt a national allowance program to meet its Kyoto target. Added power therefore would not lead to additional emissions, since there would be a cap on total emissions. The costs of remaining under the emissions cap would increase, however, because power will generate higher C02 emissions. The cost of C02 emissions is estimated by multiplying forecast allowance prices per ton of emissions times the quantity of additional tons of C02 emissions as the result of power. The quantity of additional C02 emissions is provided by PSE&G as a part of their power data. IV.C. Projections of Marginal Environmental Impacts and Allowance Prices for CO2To arrive at a marginal impact value, an average is taken of studies estimating the social costs resulting from climate change, summarized in the IPCC's Climate Change 1995 (IPCC 1996) monographiv The report summarizes the marginal estimates at different future dates, assuming a "business as usual" policy where no additional regulations are instituted. Marginal estimates for years in between those presented are estimated by a linear interpolation of the marginal value for the two closest years.Prices for C02 allowances after 2008 are based upon a recent study by the Energy Information Agency ("EIA'"), an agency of the U.S. Department of Energy. This study estimates the costs of complying with the Kyoto Protocol and expected permit prices using the National Energy Model System ("NEMS"). The EIA report presents two estimates based upon the amount of reductions that would need to be achieved domestically given international trading in C02 allowances. We choose the case that generates lower costs (14 percent above 1990 emissions levels), which has permit prices of 536 per ton of CO2 in 2010, and $34 per ton of CO2 in 2020.' To calculate values between 2008 and 2021, a linear extrapolation of the 2010 and 2020 values is made. Themarginal damage and permit costs used in the analyses are presented in F- 10 Table 1.6 A REFERENCES -Bruce, James, Hoesung Lee and Erik Haites. 1996. Climate Change 1995. Economic and Social Dimensions of Climate Change. Cambridge University Press: Cambridge, U.K.Cantor Fitzgerald, Inc. 1998a. "Allowance Price Indications" (data from 1994 to 1998).New York, NY: Cantor Fitzgerald (available at http://www.cantor.com/ebs).Cantor Fitzgerald, Inc. 1998b. "Continuous Clean Air Auction, NOx Budget Market Bulletin and Market Price Indices," (October to November). New York, NY: Cantor Fitzgerald (available at http://www.cantor.com/ebs). Ellerman, A. Denny, et. al. 1997. Emissions Trading Under the U.S. Acid Rain Program: Evaluation of Compliance Costs and Allowance Market Performance. MIT Center for Energy and Environmental Policy Research: Cambridge, MA.Energy Information Agency. 1998. Impacts of the Kyoto Protocol on U.S. Energy Markets and Economic Activity. SR/OF/98-03. Washington, DC: Energy Information Agency, U.S. Department on Energy.Fieldston Publications. 1994-1998. "EATX," Clean Air Compliance Review. Washington, DC: Fieldston Publications. Natsource (1998). "Natsource NOx Price Index", Airtrends 2(3-11). New York, NY: Natsource. (available at http://www.natsource.com). NESCAUM/MARAMA. 1996. "NESCAUM/MARAMA NOx Budget Model Rule", prepared by Laurel Carlson, Environmental Sciences Services for the NESCAUM/MARAMA NOx Budget Task Force, NESCAIJM/MARAMA NOx Budget Ad hoc Committee, and the Ozone Transport Commission's Stationary and Area Source Committee. May 1, 1996.*7 ENDNOTES i This analysis ignores several complications that could result in additional environmental costs under a cap-and-trade program. For one thing, if power increased at facilities outside the cap-and-trade program in response to the reduction at Salem, the increased emissions might not be compensated for by reductions at other facilities. The cap-and-trade programs for SO, and NOx apply to broad geographic areas, however, and the possibility of increased emissions outside the cap-and-trade program can be ignored. Secondly, the redistribution of emissions that occurs might lead to different local environmental impacts around the facilities whose emissions decrease and increase. Without a detailed model that predicts environmental impacts around the facilities, it is not possible to quantify these localized effects.In contrast, current allowances may be used in the current year or banked for future use. Ellerman et al. (1997) discuss reasons for differences between current and vintage prices..iii For years beyond 2005, the last year of Cantor Fitzgerald adjustment factors, an adjustment rate equal to the rate in the last year of the Cantor Fitzgerald data is used.The values for studies by Cline were not included in the averages, since some of these studies assume zero discount rates. For each study, the mid-point of the range of values is used.I These are converted from values of S129 per ton of carbon in 2010 and S123 per ton of carbon in 2020, using a conversion factor of 3.67 to convert CO, to carbon.8 PSE&G Permit Application 4 March 1999 Appendi.x F Artach.ment 10 Tables F-10 Table I Air Emission Costs from Lost Power (51998/ton emissions) Year SO, NOx CO.2001 S199 S3,333 S 5 2002 S198 S3,333 S 5 2003 S196 S3,333 S 5 2004 S195 S3,333 S 5 2005 5191 53,333 S 6 2006 5187 S3,333 S 6 2007 5183 S3,333 S 6 2008 5179 S3,333 536 2009 S175 S3,333 S36 2010 S171 S3,333 S36 2011 S167 S3,333 S36 2012 S163 S3,333 S36 2013 S159 S3,333 S35 2014 $155 S3,333 $35 2015 S151 $3,333 $35 2016 $147 S3,333 S35 2017 S143 S3,333 S35 2018 $139 S3,333 $35 2019 S135 $3,333 S34 2020 S131 S3,333 534 2021 S127 53,333 S34 Sourceý NERA calculations as explained in text.84 APPENDIX F ATTACHMENT 11 DETAILED COST TABLES SPONSOR: DAVID HARRISON, Jr.NATIONAL ECONOMIC RESEARCH ASSOCIATES PSE&G RENEWAL APPLICATION SALEM GENERATING STATION PERMIT NO. NJ0005622 4 MARCH 1999 PSE&G Per-nit Appiicaion MI\arch 1919 Appendix F TABLE OF CONTENTS REFERENCES ........................................................................................................... 3 ENDNOTES ........................................................................................................ 4 S S PSE&G Permit Application 4 March 1999 Appendix F ATTACHMENT F-l1 DETAILED COST TABLES Section IX of Appendix F evaluates the costs and benefits of fish protection alternatives for Salem. This attachment provides the details of the calculation of total costs for each fish protection alternative evaluated in Section IX. F- II Table 1 provides the present value of costs by component for all alternatives. F-I 1 Tables 2 to 13 provide annual cost estimates, by component, for each alternative. Cost components include: " construction costs;" operating and maintenance costs;" The value of lost power resulting from construction outages, including the value of capacity, energy, and air emissions costs; and" The value of lost power resulting from changes in continuing operations, including the value of capacity, energy, and air emissions costs.The methodologies for calculating each cost component are explained in Section IX.C.Attachment F-9 describes the methodology for estimating the value of energy and capacity. Attachment F-l 0 describes the methodology for estimating the value of air emissions. All costs are based on the data developed in Section VIII and its attachments,' Attachment F-9 (PSE&G's forecasts of future generation and energy and capacity prices), and Attachment F-10 (cost of air emissions changes). F-I1 Tables 2 to 13 also provide the total annual cost for each alternative. Total present values for each cost component are calculated as of January 1, 2001 using PSE&G's real cost of capital." The table for each alternative includes a list of notes providing data and assumptions used to calculate the cost estimates. These notes include capacity loss resulting from the installation of each alternative,iii and the annual energy loss of each alternative."v The table for each alternative also provides the duration of construction (which determines when alternatives actually become effective), and the duration of construction outages.The timing assumptions for construction, refueling outages, and flow reductions are discussed in greater detail in Attachment F-8.Note that NERA's calculation of present value takes into account the monthly pattern of expenditures where these data are available (e.g., construction costs). Where monthly expenditure data are not available, NERA assumes that expenditures are evenly distributed over the year. Note that the standard calculation of present value assumes that payments are made at the end of each period. Where the "payments," or expenditures, occur throughout the year, this approach leads to improper discounting. To correct for this effect, NERA's present value calculations include a six-month adjustment. This adjustment results in present value calculations which assume payments are made in the middle of the period, the correct approach for payments evenly distributed over the period. *2 PSE&G ?errnIt Appi::a n 4 March 1999 p Append%- F p REFERENCES Congressional Budget Office. 1998. Current Economic Projections. http://ww-v.cbo.gov, November 24.*3 PSE&G Pe, -mit A~pphc:3:i-n Append.ix F ENDNOTES The estimates for construction and operating & maintenance costs developed in Section VIII are expressed in July 1998 dollars. Because July 1998 is mid-year, it is not necessary to adjust these dollars any fiu-ther.The nominal cost of capital provided by PSE&G (8.42 percent) was adjusted using projections of the future Implicit GDP Deflator (2.1 percent). (Congressional Budget Office, Current Economic Projections, htnp:i/www.cbo.gov, March 23.) The nominal interest rate is adjusted for inflation using the following formula: [(1 PSE&G Cost of Capital)/(l -Projected GDP Deflator) -1). With the specific values, the real discount rate is (1.0842)/(1.021) -1 = .0619, or 6.19 percent.Capacity losses are the result of auxiliary power demands and reductions in plant efficiency.Annual energy loss includes losses due to auxiliary power demands, reductions in plant efficiency, and rescheduling of outages.4 Appendix F, Attachmet F I I F -11 Table 1. Present Value of Costs by Component for Fish Protection Alternatives COST COMPONENT (Smillions) Construction Construction Outage Power Continuing Operation Power O&M Total Alternative Capacity Energy Air Capacity Energy Air Intake Modifications Strobe Light and Air Bubble Curtain $4.7 $0.0 $0.0 $0.0 $0.1 $0.3 $0.2 $4.8 $10.0 Dual-Flow Fine Mesh Screens $29.9 $0.0 $0.0 $0.0 $0.1 $0.9 $0.5 $3.5 $34.8 Modular Inclined Screens $18.4 $0.0 $0.0 $0.0 $0.1 $0.7 $0.4 $5.3 $25.0 Flow Reduction (F.R.) Alternatives Revised Refueling Outage Schedule $0.0 $0.0 $0.0 $0.0 $12.7 $74.2 $47.9 $0.0 $134.7Seasonal F.R. 10% Delta T Vary $21.1 $0.0 $0.0 $0.0 $1.5 $6.3 $4.7 $0.0 $33.7Seasonal F.R. 20% Delta T Vary $21.1 $0.0 $0.0 $0.0 $3.5 $14.7 $10.9 $0.0 $50.2 Seasonal F.R. 45% Delta T Vary $21.1 $0.0 $0.0 $0.0 $54.9 $257.4 $191.0 $0.0 $524.5 Seasonal F.R. 10/o Delta T Constant $21.1 $0.0 $0.0 $0.0 $10.7 $43.7 $32.4 $0.0 $107.8 Seasonal F.R. 201% Delta T Constant $21.1 $0.0 $0.0 $0.0 $34.4 $156.1 $115.8 $0.0 $327.4 Seasonal F.R. 45% Delta T Constant $21.1 $0.0 $0.0 $0.0 $94.8 $448.1 $300.7 $0.0 $864.8 Natural Draft Towers $460.4 $12.7 $104.3 $14.1 $13.5 $44.4 $26.7 $35.9 $712.0Mechanical Draft Towers $576.0 $12.7 $104.3 $14.1 $9.3 $37.0 $22.3 $73.6 $849.2 Note: Present values in millions of 1998 dollars as of January 1, 2001.Source: NERA calculations as described in text.*¢4 F- I I Table 2. Strobe Lighl and Air Bubble Curtain Annualized Costs by Component ($000)Construction Constructiont Outage Power Continuing Operation Power O&M Total Year calpcity Eierg Air Capacity Energ Air 2001 $4,793 $0 $0 $0 $2 $10 $2 $184 $4,991 2002 $0 $0 $0 $0 $5 $26 $5 $451 $487 20X3 $0 $0 $0 $0 $5 $29 $5 $451 $.90 2004 $0 $0 $0 $0 $5 $27 $5 $451 $487 2005 $0 $0 $0 $0 $5 $28 $4 $451 $488 2006 $0 $0 $0 $0 $5 $28 $5 $451 $489 2007 $0 $0 $0 $0 $5 $29 $5 $451 $491 2008 $0 $0 $0 $0 S5 $31 $21 $451 $507 2009 $0 $0 $0 $0 $5 $32 $23 $451 $511 2010 $0 $0 '$0 $0 $5 $33 $23 $451 $511 2011 $0 $0 $0 $0 $5 $34 $22 $451 $512 2012 $0 $0 $0 $0 $5 $34 $22 $451 $512 2013 $0 $0 $0 $0 $5 $34 $23 $451 $512 2014 $0 $0 $0 $0 $5 $34 $23 $451 $513 2015 $0 $0 $0 $0 $5 $33 $24 $451 $513 2016 $0 $0 $0 $0 $5 $33 $24 $451 $513 2017 $0 $0 $0 so $4 $25 $18 $338 $385 2018 $0 $0 $0 $0 $2 $16 $13 $226 $257 2019 $0 $0 $0 $0 $2 $16 $13 $226 $257 2020 $0 $0 $0 $0 $2 $16 $13 $226 $257 2021 $0 $0 $0 $0 $2 $12 $10 $169 $193 Present Value $4,652 $0 $0 $0 $53 $321 $150 $4,775 $9,950 Note: Values 1998 $lhiousands. hrescnt values as ol January 1, 2U01. I'aentithcses iitdicale negative values Capacity ILoso (kW) 160 A nnual lEuergy Loss (kWh) 1,401,000 Contstructlon Duration 7 inunths Consltruction Start Date January 1, 2001 Construetion Outage 131111 I Outage Duration Outage Start Date NA Unit 2 Outage Duration Outage Start Date NA

• 8 00 Year 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 F- I I Table 3. Dual-Fluw Fine Mesh Scicens Annualized Costs by Component

($000)Construtioun Construction Outage Power Capacity Energy Air Ca$10,897 $0 $0 $0$10,897 $0 $0 $0$10,897 $0 $0 $0$0 $0 $0 $0$0 $0 $0 $0 so $0 $0 $0$0 $0 $0 so$0 $0 so $0$0 $0 $0 $0$0 $0 $0 $0$0 $0 so $0$0 $0 $0 $0$0 $0 $0 $0 SO $0 $0 $0$0 $0 $0 $0$0 $0 $0 $0$0 $0 $0 $0$o $0 $0 $0$0 $0 $o so$0 $0 $0 $0 so $0 $0 $0.onlinulng Operation Power pacity Energy Air So $0 $0$0 $0 $0$0 $0 $0$6 $90 $15$6 $94 $15$6 $94 $17$6 $99 $17$6 $104 $69$6 $109 $78$6 $109 $77$6 $115 $74$6 $114 $75$6 $113 $77$6 $113 $78$6 $112 $80$6 $111 $81$4 $83 $62$3 $55 $42$3 $55 $43$3 $54 $44$2 $41 $34 O&M TWotA S0$41$0$419$419$419$419$419$419$419$419$419$419$419$419$419$314$210 $210$210$157$111,897$10,897$0.897$530$534$536$541$598$611$612$614$614$615$616$617$618$464$310$310$311$233$34.839 Present Value $29,910 $0 $0 $0 Note: Values 1998 $thousands. Present values as ol'January 1,2001. Pareiheses indicate negative values$52 $881$470 $3.527$52 $881 Capacity Loss (kW)Annual Energy Loss (kWh)Construclion Duration Conslructlon Start Date Construction Outage Unit I Outage Duration Outage Start Date UnIt 2 Outage Duration Outage Start Date 200 4,705.(100 36 months January 1, 2001 NA NA 6 1'Year 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 201')2020 2021 F -I I Table 4. Modular Inclined Screens Annualized Costs by Component ($000)Construction Construction Outage Power Capacity Energy Air$6,696 $0 $0 $0$6.696 $0 $0 so$6,696 $0 SO $0$0 $0 $0 $0$0 $0 So $0$0 $0 $0 $o so $0 $0 $0$0 $0 $0 $0$0 $0 $0 so so $0 $0 $0$0 $0 $0 $0$0 $o $0 $o$0 $0 $0 $0$0 $0. $0 so$0 SO so $0$0 $o $0 $0$0 $0 $0 $0 so $0 $0 $o$0 $0 $0 $0 so $0 $0 $0 so so $0 $o Operation Power Capacily Energy Air$0 $0 $0$0 $0 SO$0 $0 SO$18 $76 $13$18 $79 $13$18 $79 $14$18 $83 $14$18 $87 $58 S18 $92 $66$18 $92 $65$17 $97 $62$17 $96 $63$17 $96 $65$17 $95 $66$17 $95 $67$17 $94 $69$13 $70 $52$8 $46 $36$8 $46 $36$8 $46 $37$6 $34 $28 O&M"T'otal$0 $0$0$632$032$632$632$632$632 $632$632$632$632$632$632$632$474$316$316$316$237$6,696$6.(690$6,696$738$7-11$7.13$747$795$806$806$808$809$83)9$8xo$810 $811$609$4016$,107$407$306 Present Value $18,379 $3) $0 $0 Note: Values 1998 $thousands. Present values as of January I, 2001. Parentheses indicate negalive values$147$744 $397 $5,315 $24,982 Capacity Loss (kW)A unual Energy Loss (kWh)Construction Duration Construction Start Date Construction Outage Unit. I Outage Duration Outage Start Date Unit 2 Outage Duration Outage Start Date 570 3.971,000 36 months January 1. 2001 NA NA Ar, ri F- 1 Table Q. Rvse R r~d~ tfa~ ScehkAnai-dC~~1 ooeUSK1 Year 2001 $0 2002 $0.$O 70(157 $0.2004 $0 2007 I .. $0I I$0 2019 $0.2011 -$0 2014 $0 2011) $2020 $0 2T2M .0 kCaps3~ Ir Fiwrgy Nil$0 so 54 SO$$0$0 so$0 0 .. $so so so SO 0so-$0 so Co(afaillum?~rg 52.102.; 6.1$983 .$1, 0*~ ~ I65* 53.73 5399-44Air b 821 H 767~4 189~9,210 3518~6 109~lA30 10,149 S273 L0A99~8.6l2 52 3$5,761$0 so$o so$0$0$0$0$0 SO s0$0 $0$0 522.500 g7.245$51[52"$11,149.$20.220,.-.. * -.$ t3,7)35,1.. .5.3.0* 5 7901$43784 Pr~~e ~ ~ t too .$0 .. $*N~~ ~i~ 998 Shot~j~. .rt~rt h ja h f untv 1,2t0"I'5.0 S I2,41AM*110, ý $7415 547,&fý$0 $134,706 Outqft e Duratiotn O0(aio Stan Date NA NA NA NA* Year 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 F- I I Table 6. Seasonal F.R. 10% Ddlta T Vat Annualized Costs by Compon Cunslructiont Construction Outage Power Capacity EInergy Air$21.727 $0 $0 $0$0 $0 $0 $0$0 $0 $0 $0$0 $0 $0 $0$o $o $0 $0$0 so $0 $0$0 $0 $0 $0$0 $0 $0 $0$0 $0 $0 $0$0 so $o $0$0 $0 $0 $0$0 $0 $0 $o$0 $0 $o $0$0 $0 $o $0$0 so $0 $o$0 so $0 $o$0 $0 $0 $o$0 $o $0 $0$o $o $0 $0$0 $o $o $0$0 so $0 $0 Continuing Operation Power O&M lutal Capnacity Energy Air$143 $484 $151 $St $22,504$142 $521 $225 $0 $888$141 $530 $236 $0 $907$140 $508 $196 $0 $,ix5$139 $519 $186 $0 $845$139 $534 $217 $o $889$138 $547 $208 $0 $893$137 $576 $600 $0 $1,314$136 $602 $619 $0 $1,357$135 $623 $661 $0 $1.419$135 $647 $624 $0 $1,405$134 $643 $635 $0 $1.412$133 $639 $647 $0 $1,420$132 $636 $659 $0 $1.427$132 $632 $672 $0 $1.435$131 $628 $684 $0 $1,443$79 $381 $425 $0 $885$65 $310 $355 $0 $730$64 $309 $362 $0 $734$64 $307 $368 $0 $739$63 $305 $375 $0 $744 Present Value $21,084 $0 $0 $0 $1,527 Note: Values 1998 $thousands. Piesent values as of January 1, 2001. Parentheses indicate negative values$6342 $4706$0 $33660 Capacity Loss (kW)Annual Energy Loss (kWh)(-oinstruction Duration Construction Start Dale Construction Outage 111111 1 Outage Duration Outage Start Date Unit 2 Outage Duration Outage Start Dale 19.000 29,400,000 3 inonths January 1, 2001 NA NA 9 00 Year 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 F -I I Table 7. Seasonal F.R. 20% Dela T Vary Annualizcd Costs by Component ($000) Construrtlctu Conslructiun Outage Power Co Capacity Ellergy Air Capa$21.727 $0 $0 so $$0 $0 S0 so $s0 $0 $0 S0 $so $0 $0 $0 $$0 So $0 so $$o $0 $o $0 $$o So $o $o $$0 $0 so $0 $$0 So $0 So $$0 SO $0 $0 $$0 $0 $0 $0 $so so $0 $0 $$o so so SO $$0 $o So $o $$0 $0 SO so $$0 $0 $0 so $$0 so so $0 S$0 $0 $0 $o $so so $0 $0 $$0 $0 $0 $0 $$o SO $0 $0 $$0 $0 $0 $0$ntlnulng Operatlon Power acitz Energy Air 323 $1,124 $351 321 $1,210 $524 319 $1,231 $549 318 $1,180 $456 316 $1,205 $433314 $1,240 $503 312 $1,272 $483 310 $1,339 $1,395 308 $1.398 $1,438 307 $1,447 $1,536 305 $1,503 $1,449 303 $1,494 $1,476 301 $1,485 $1,503 29) $1,477 $I.531 298 $1.468 $1.560 296 $1.459 $1,589 179 $885 $988146 $721 $825 145 $717 $840 144 $713 $856 144 $708 $872 O&M l'utIlaI$0 $23,525$0 $2,055$0 $2,099$0 $1,953$0 $1,95,1$0 $2,057$0 $2.067$0 $3.044$0 $3,145$0 $3.289$0 $3.256$0 $3,273$0 $3,290$0 $3,307$0 $3,326$0 $3,344$0 $2,052$0 $1,692$0 $1.702$0 $1,713$0 $1,724 Present Value $21,084 $0 $0 $0 $Note: Values 1998 Sthousands. Present values as ofJanuary 1, 2001. Parentheses indicate negative values 3.456 $14,734 $10,933$0 $50,207 Capacity Loss (kW)Annual Energy Loss (kWh)Construction Duration Construction Start DateConstruction Outage Unit I Outage Duration Outage Start Date Unit 2 Outage Duration Outage Start Date 43,000 723,500.000 3 months January 1, 2001 NA NA W0 F -I I Table 8. Seasonial F.R. 45% Delta T VartyAnniualizcd Costs by Comp)onet ($000)Construction Construction Outage P'ower Continuing Operatiun Power ()&Al "'Ilal Year Capacity Energy Air Capacity Energy Air 2001 S21,727 $0 $0 $0 $5.134 $19.636 $6,130 $0 $52.627 2002 $0 $0 so $0 $5.104 $21,148 $9,152 $0 $35,10.1 2003 $0 $0 $0 $0 $5,075 $21,510 $9,588 $0 $36,173 2004 $0 $0 $0 $0 $5,044 $20,611 $7,973 $0 $33,628 2005 $0 $0 $0 $0 $5,014 $21,053 $7,568 $0 $33,636 2006 $0 $0 $0 $0 $4,985 $21,661 $8.794 $0 $35,441 2007 $0 $0 $0 $0 $4,956 $22,219 $8,444 $0 $35,619 2008 $0 $0 $0 $0 $4,926 $23,401 $24,372 $0 $52,699 2009 $0 $0 $0 $0 $4,898 $24,435 $25,127 $0 $54,460 2010 $0 $0 $0 $0 $4,869 $25,280 $26,839 $0 $56,988 2011 $0 $0 $0 $0 $4,840 $26,261 $25,314 $0 $56,415 2012 $0 $0 $0 $0 $4.812 $26,107 $25,787 $0 $56,705 2013 $0 $0 $0 $0 $4,783 $25,954 $26,268 $0 $57,005 2014 $0 $0 $0 $0 $4,755 $25,801 $26.758 $0 $57,315 2015 $0 $0 $0 $0 $4,727 $25,650 $27,258 $0 $57,635 2016 $0 $0 $0 $0 $4,700 $25,499 $27,768 $0 $57,966 2017 $0 $0 $0 $0 $2,850 $15,463 $17,256 $0 $35,568 2018 $0 $0 $0 $0 $2,322 $12,600 $14,409 SU $29.331 2019 $0 $0 $0 $0 $2,309 $12,526 $14,679 s0 $29,513 2020 $0 $0 $0 $0 $2,295 $12,452 $14,954 $0 $29,701 2021 $0 $0 $0 $0 $2,282 $12,379 $15,234 $0 $29.895 Presenlt Value $21.084 $0 $0 $0 $54,894 $257,449 $191,025 $0 $524,452Note: Values 1998 $thousands. Present values as ofJanuatry

1. 2001. Partetheses indicate negative values Capacity L.oss (kW) 683.000 Aunual Energy Luss (kWh) 1.193.400.000 Construction Duration 3 months Construcilun Start Date January 1, 2001 Construction Outage thilt I Outage Duration Outage Start Date NA Unit 2 Outage Duration Outage Start Date NA@1' F -I I Table 9. Scasonal F.R. 10% Dlta 'I' ConsLtai Annualized Custs by Component

($000)Cumslnstction Cuiostructlon Outage Power Continuing Operation Power O&M T'otl2l Year Capacity Energy Air Capacity E'l'ergy Air 2001 $21,727 so $0 $0 $1,000 $3.330 $1.040 $0 $27.096 2002 $0 $0 $0 $0 $994 $3,587 $1,552 $0 $6,133 2003 $0 $0 $0) $0 $988 $3,648 $1.626 $0 $6,262 2004 $0 $0 $0 $0 $982 $3.496 $1,352 $0 $5,830)2005 $0 $0 $0 $0 $976 $3.571 $1,284 $0 $5.831 2006 $0 $0 $0 $0 $971 $3.674 $1,492 $0 $6,136 2007 $0 $0 $0 $0 $965 $3,768 $1,432 $0 $6,165 2008 $0 $0 $0 $0 $959 $3,969 $4,133 $0 $9,062 2009 $0 $0 $0 $0 $954 $4,144 $4,262 $0 $9,360 2010 $0 $0 $0 $0 $948 $4.287 $4,552 $0 $9.787 2011 $0 $0 $0 $0 $943 $4,454 $4,293 $0 $9,690 2012 $0 $0 $0 $0 $937 $4,428 $4,373 $0 $9,738 2013 $0 $0 $0 $0 $931 $4,402 $4,455 $11 $9,788 2014 $0 $0 $0 $0 $926 $4,376 $4,538 $0 $9,840 2015 $0 $0 $0 $0 $921 $4,350 $4,623 $0 $9.894 2016 $0 $0 $0 $0 $915 $4.325 $4,709 $0 $9,949 2017 $0 $0 $0 $0 $555 $2,622 $2,927 $0 $6,104 2018 $0 $0 $0 $0 $452 $2,137 $2,444 $0 $5.033 2019 $0 $0 $0 $0 $450 $2,124 $2.489 $0 $5.063 2020 $0 $0 $0 $0 $447 $2,112 $2,536 $0 $5,1095 2021 $0 $0 $0 $0 $444 $2,099 $2.584 $0 $5,127 Present Value $21,084 $0 $0 $0 $10,689 $43,663 $32,399 $0 $107,835 Note: Values 1998 $thousands. Present values as of January 1, 2001. Parentheses indicate negative values Capacity Loss (kW) 133,000 Amnual Energy Loss (kWh) 202.400.000 ConstructIon Duration 3 months Constructin Start Dale January 1, 2001 Cunstructiun Outage (utll I Outage Duration Outage Start Date NA Uith! 2 Outage Duration Outage Slart Date NA 12 F -I I Table 10. Seasonal :.R. 20% Delta TConstan Annualized Cobsts by Cmlnponent ($000)Construction Construction Outage Power Contlnuing Operation Power O&Ml Total Year Capacity E'nergy Air Capacity Energy Air 2001 $21,727 $0 $0 $0 $3,217 $11,904 $3,717 $U $40.565 2002 $0 $0 $0 $0 $3,198 $12,821 $5,548 $0 $21,568 2003 $0 $0 $0 $0 $3,180 $13,041 $5.813 $0 $22.033 2004 $0 $0 $0 $0 $3,161 $12,495 $4,834 $0 $20.490 2005 $0 $0 $0 $0 $3,142 $12,764 $4,588 $0 $2049.1 2006 $0 $0 $0 $0 $3,124 $13,132 $5,332 $0 $21.588 2007 so $0 $0 $0 $3.106 $13.470 $5.119 V) $21,695 2008 $0 $0 $0 $0 $3.087 $14,187 $14.776 $0 $320.19 2009 $0 $0 $0 $0 $3.069 $14.814 $15,233 $0 $33.117 2010 $0 $0 $0 $0 $3.051 $15.326 $16,271 $0 $34,648 2011 $0 $0 $0 $0 $3,033 $15.921 $15,347 $0 $34,301 2012 $0 $0 $0 $0) $3,015 $15,827 $15,633 $0 $34,476 2013 $0 $0 $0 $0 $2,998 $15.734 $15,925 $0 $34,657 2014 $0 $0 $0 $0 $2,980 $15,642 $16,222 $0 $.34.844 2015 $0 $0 $0 $0 $2.962 $15,550 $16.525 $0 $35,038 2016 $0 $0 $0 $0 $2,945 $15.459 $16,834 $0 $35,238 2017 $0 $0 $0 $0 $1,786 $9,374 $10,461 $0 $21.621 2018 $0 $0 $0 $0 $1,455 $7,639 $8.735 $0 $17,829 2019 $0 $0 $0 $0 $1,447 $7,594 $8.899 $0 $17,939 2020 $0 $0 $0 $0 $1,438 $7.549 $9,066 $0 $18.053 2021 $U $0 $0 $0 $1,430 $7,505 $9,236 $0 $18,170 Present Value $21,084 $0 $0 $0 $34,399 $156,079 $115.80)9 $0 $327,371 Note: Values 1998 $thousands. Present values as of January 1, 2001. Parentheses indicate negative values Capactlly Loss (kW) 428.000 Annual Energy Loss (kWh) 723,500,000 Construction Duration 3 months Construcllon Start Date January 1. 2001 Construetlun Outage Unit I Outage Duration Outage Start Date NA Unit 2 Outage Duration Outage Start Dale NA 1' F -I I Table 1I. Seasonal F.R, 45% Delia r Consi~IaI Annualized Costs by Component ($0so0)Coinstruction CountlructJois Outage Iower Continuing Operation Power O&M 'l'i.Year Capacity Energy Air Capacity Energy Air 200)1 $21.727 so $0 $0 $8.869 $34.179 $9,650 $0 $71,425 2002 $0 $0 $0 $0 $8,818 $36,811 $14,406 $0 $60,035 2003 $0 $0 $0 $0 $8,767 $37,442 $15.092 $0 $61,301 2004 $0 $0 $0 $0 $8,715 $35.877 $12.550 $0 $57.1.12 2005 $0 $0 $0 $0 $8.663 $36,647 $11,913 $0 $57.224 2006 $0 $0 $0 $0 $8,613 $37,705 $13,843 $0 $00.161 2007 $0 $0 $0 $0 $8,563 $38,675 $13.291 $0 $60.529 2008 $0 $0 $0 $0 $8,51 I $40,733 $38,365 $0 $87,608 2009 $0 $0 $0 $0 $8,462 $42,533 $39,554 $0 $90,5-19 2010 $0 $0 $0 $0 $8,412 $44,004 $412.249 $0 $9-1.664 2011 $0 $0 $0 $0 $8,362 $45.711 $39,849 $0 $93,922 2012 $0 $0 $0 $0 $8,313 $45,443 $40.592 $0 $94,349 2013 $0 $0 $0 $0 $8,264 545.176 $41.350 $0 $94,790 2014 $0 $0 $0 $0 $8,216 $44.911 $42.122 $0 $95.2.18 2015 $0 $0 $0 $0 $8,167 $44,647 $42.909 $0 $95,723 2016 $0 $0 $0 $0 $8,119 $44.385 $43.711 $0 $96,215 2017 $0 $0 $0 $0 $4,924 $26,916 $27.163 $0 $59,002 2018 $0 $0 $0 $0 $4,012 $21,932 $22,682 $0 $,18,626 2009 $0 $0 $0 $0 $3,988 $21,803 $23,106 $0 $48,898 2020 $0 $0 $0 $0 $3,965 $21,675 $23,540 $0 $49,180 2021 $0 $0 $0 $0 $3,942 521,548 $23,981 $0 $49,471 Present Value $21,084 $0 $0 $0 $94,839 $448.130 $300,700 $0 $864,754 Note: Values 1998 Sihousands. Present values as of January 1. 2001. Parentheses indicate negative values Capacity Ioss (kW) I,180,0.00 Annual Energy Loss (kWh) 2,077,300,000 Comistrucliun Duration 3 nmonths Construction Start Date January 1. 2001 Construction Outage Unit I Outage Duration Outage Start Date NA Unit 2 Outage Duration Outage Start Date NA I1I Yeatr 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 F -I I Table 12. Natural Dralt Towers Antualized Costs by Comiiponecnt ($00))Contstructlion Constructioni Outage Power Capacity Energy Air$12,192 $0 $0 $0$69,846 $0 $0 $0$139.589 $0 $0 $0$190,772 so $0 $0$123.978 $10,970 $76,400 $13,225$21.408 $5,991 $63,960 $5,643$0 $0 $0 $0$0 $0 $0 $0 s0 $0 $0 $0$0 $0 $0 $0$0 $0 $0 $0$0 $0 $0 $0$0 $0 $0 $0$0 $0 $0 $0$0 $0 $0 $0$0 $0 $0 $0 So $0 $0 $0$0 $5o $0 $(S$o $0 $o $0$0 $0 $0 $0$0 $0 $0 $o Continuing Operatin I'ower Capacity Energy Air$0 $0 $0$0 $0 $0$0 $0 $0$0 $0 $0$413 $1,141 $182$1,751 $4,890 $864$2.002 $5,902 $1,026$1,990 $6,192 $4,122$1,979 $6,493 $4,641$1,967 $6,539 $4,611$1,955 $6,862 $4.406$1,944 $6,822 $4,493$1,932 $6,782 $4,581$1,921 $6,742 $4,671$1,910 $6,702 $4.763$1,899 $6,663 $4,857$1,416 $4,968 $3,714$938 $3,292 $2.525$933 $3.273 $2,575$927 $3,254 $2.625$691 $2,426 $2,008 ()& M$0 $12.192 $0 $69,846$0 $1391589$0 $190.772$1.059 $227,368$4,516 $109,023$5,195 $14,126$5,195 $17,499$5,195 $18.3(08$5.195 $18,312$5.195 $18,419$5,195 $18,454$5,195 $18,491$5,195 $18,529$5,195 $18,571)$5,195 $18,613$3,896 $13.994$2,598 $9,353$2.598 $9.378$2,598 $9,404$1,9418 $7,073 IPresent Value $460,394 $12,677 $104,273 $14,149 $13,475 Note: Values 1998 $ltousalids. Present values as ol January I, 21831. Parendieses indicate negative values$44.409 $26,728 $35.871 $711,977Caplacily Loss (kW)Annual Energy Loss (kWh)Construcllon Durallon.Construction Start Dale Construction Oulage Uni._I I Outage Duration Outage Start Date Unli 2 Outage Duration Outage Start Date 64.000 281,295.133 51 monthls January 1, 2001 7 October I. 2005 7 January 1, 2005.5 0 pj 40 Year 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 21016 2017 2018 21019 2020 2021 F -II Table 13. Mechanical Dralt Towers Annualized Costs by Comipotnent ($03001 ctIIInrlctii ll cimIIlsrucIiuII Outlage Illver Capaclly Energy Air$15,253 $0 $0 $0$87,383 $0 $0 $0$174.637 $0 $0 $0$238,671 $0 $0 $o$155,106 $10,970 $76,400 $13.225$26,784 $5,991 $63,960 $5.643$0 $0 $0 $o$0 $0 so $o$0 $0 $0 $0$0 $0 $0 $0$0 $0 $0 $0$0 $0 $0 $0$0 $0 $0 $0 $0 $0 $0 $0$o $0 $o $0$0 $0 $0 $0 $0 $o $0 $0$0 $0 $0 $0$0 $0 $0 $0 $o $o $0 $0$o $0 $) $0 Cuntiluiig Operatini Power Capacliy EntrUy Air$0 $0 $0$1) SCI $0$0 $o $0$0 $0 $0$284 $950 $152$1.20.4 $4,075 $720$1,377 $4,918 $855$1.368 $5.160 $3.435$1,360 $5.411 $3,867$1,352 $5,449 $3.843$1,344 $5,718 $3.672 $1,336 $5,685 $3,744 $1,329 $5,651 $3,818$1.321 $5.618 $3,893 $1.313 $5.585 $3,969 $1.305 $5,552 $4.048$973 $4,140 $3,095 $645 $2.7441 $2.1041$6.11 $2.728 $2.146$637 $2,712 $2,188$475 $2,022 $1,6730 )& M $0 $15.25.3$11 $87.38.)$0 $17-1.637$0 $2.,071 I$2,171 $259.261$9,266 $117.6-12$10,660 $17.810$10,660 $20,623$10.660 $21.299$10.660 $ 21,301$10.660 $21.395$10,660 $21,125 $10,660 $21.158$111,660 $21,'192$10,6601 $21.528$10,660 $21,565$7,995 116.203$5.330 $111,823$5.330) $ 101814$5,330 $10,86"$3.998 $8,168 Prescill Value $575.991 $12,677 $11.1,273 $141,149 Note: Values 1998 $11tlousands. hie:eutl values as of January 1, 2001. Parcnithsees indicate negative values$9.2641 $37.007 $22,271 $73.607 $8.19.2.12 Capaclly Louss (kW)Aiunuul E:nergy ILnss (kWh)Coustrucllon Duration Coinstrucion Start Dale Custructilon Outage Unit IOutage DurationOutage Star( Date hUll 2Outage Duratiun Outage Date 44.000 234,412,611 51 111011n1hs J;iuaiy I, 2001 7 October I. 2005 7 Jallaay I. 21005 16 APPENDIX F ATTACHMENT 12 COMMERCIAL AND RECREATIONAL SPLITS SPONSORED BY: DAVID HARRISON, Jr.NATIONAL ECONOMIC RESEARCH ASSOCIATES PSE&G RENEWAL APPLICATION SALEM GENERATING STATION PERMIT NO. NJ0005622 4 MARCH 1999 PSE&G Pe,-m.;t Appiicanion ApndlaMrch 1,-l99 Appen ix F TABLE OF CONTENTS REFERENCES .................................................................................................................. 3 ENDNOTES ...................................................................................................................... 4 S 8 PSE&G Applica::on 4 Varch i 99 Appendix F ATTACHMENT F-12: COMMERCIAL AND RECREATIONAL SPLITS The implementation of fish protection alternatives would lead to changes in the quantity of fish caught in the recreational and commercial fisheries. In Section LX of Appendix F, the economic benefits of these potential changes in fishery catch are evaluated. This attachment describes the methodology for determining the proportion of the total change in catch (for each species) that would be caught in the recreational and commercial fisheries. This proportion is necessary to allocate the estimated gains (in pounds) to each fishery, since the fishery cropping models do not distinguish between these two types of fishermen. Estimates are derived for all RIS species with recreational and commercial value, and for Blue Crab and Atlantic menhaden.The recreational and commercial split is based upon the historical proportion of recreational and commercial catch for each species considered. (These species are listed in F-12 Table 1.) To calculate each proportion, the weight of the recreational and commercial catch is separately estimated. These estimates are produced by calculating the quantity of fish caught (by weight) over the period from 1990 to 1996 for each state and marine region (coastal or inland) within the species range. For the purposes of this analysis, the range is defined as the area in which a pre-adult fish utilizing the Delaware Estuary is likely to be caught at some point during its lifetime. These ranges are presented in F-12 Table 1. Data from several National Marine Fisheries Service surveys are used to arrive at the weight of recreational and commercial catch (NMFS, 1998).Recreational catch includes both harvest and "catch-and-release", which are fish caught but thrown back into the water. Catch-and-release fish are an important component of the benefits of recreational fishing, and consequently are included when estimating the size of the recreational catch.' F-12 Table 2 contains the proportion of total catch by commercial and recreational fishermen. 02 ?SE&G ?errn;: Apph~ca::on -+/- larch ADpendi:x F REFERENCES French, Deborah P. et al. 1996. The CERCLA Type A Natural Resource DamageAssessment Model for Coastal and Marine Environments .NR_DA/CiCME), Technical Documentation Volume I- Part I. Model Description. Prepared for the U.S. Department of the 1n[erior, Contract No. 14-01-0001-91-C-I l. Washington, DC: Office of Environmental Policy and Compliance, April.Miller, Joe and Art Lupine. 1996. "Creel Survey of the Delaware River American Shad Recreational Fishery." Hehlertown, PA: Delaware River Shad Fishermens Association, February.National Marine Fisheries Service. 1998. Personal communication with the Fisheries Statistics and Economics Division, July-November (available at: http://www.st.nmfs.gov/stl/ index.html).Whitmore, William H. 1998. "Recreational Gill Netting in Delaware 1997." Dover, DE: Department of Natural Resources and Environmental Control, May.8 PSE&G Per-nit ApplicationMarch ;999 Appendix F ENDNOTES NM,%IFS data does not provide information on the weight of catch-and-release fish caught.Consequently, the average weight of a harvested species is multiplied by the total number of fish caught-and-released (from \N'MFS) to arrive at a total catch-and-release weight.4 PSE-&G Permit Application 4 March 1999 Appendix F Attachment 12 Tables F-12 Table 1. Geographic Ranges of Species Considered' Species Inland Range American Shad Delaware and New Jersey Atlantic Croaker Delaware and New Jersey Atlantic Menhaden Delaware and New Jersey Blue Crab Delaware and New Jersey River Herringb Delaware and New Jersey Spot Delaware and New Jersey Striped Bass Delaware and New Jersey Weakfish Delaware and New Jersey White Perch Delaware and New Jersey Ocean RangeDelaware and New Jersey North Carolina to New Jersey Florida tO Maine None Delaware to New York North Carolina to New Jersey Delaware to New York North Carolina to New YorkDelaware and New Jersey' Inland and ocean waters refers to definition made by NMFS to distinguish different saltwater fishing zones. Inland refers to "other bodies of saltwater besides oceans" including" sounds, inlets, tidal portions of rivers, bay, estuaries and other areas of salt or brackish water." b The river herring category combines alewife and blueback herring.F-12 Table 2. Proportion of Total Catch that is Recreational and Commercial for Species Considered Species Commercial Proportion Recreational Proportion American Shad 44% 56%Atlantic Croaker 90% 10%Atlantic Menhaden 100% 0%River Herring' 27% 73%Spot 82% 18%Striped Bass 3% 97%Weakfish 69% 31%White Perch 58% 42%Blue Crab 96% 4%' The river herring category combines alewife and blueback herring.Source: French et al. (1996); Miller & Lupine (1996); NMFS (1998a); Whitmore (1998).*0*5 APPENDIX F ATTACHMIENT 13 VALUATION OF COMMERCIAL CATCH 0 SPONSOR: DAVID HARRISON, Jr.NATIONAL ECONOMIC RESEARCH ASSOCIATESPSE&G RENEWAL APPLICATION SALEM GENERATING STATION PERMIT NO. NJ0005622 4 MARCH 1999 PSE&G Pemi: .-kopca::on M alarch ,00.-oep.d:x F TABLE OF CONTENTS I. CONCEPTUAL APPRO ACH ................................................................................ 2 II. DATA ............................................................................................................................ 2 REFERENCES ............................................................................................................ 4 S 6 PSE&G Permt .-\ppi;ca::on -'March ! ,?99 Appendix F Attachment F-13 VALUATION OF COMMERCIAL CATCH Section IX of Appendix F evaluates the costs and benefits of changes in fisheries catch that would occur due to the implementation of fish protection alternatives. This attachment describes the procedures and data used to estimate the value of fish caught commercially. These commercial values are used to estimate additional commercialharvest benefits that would result from the implementation of fish protection alternatives. The term fish is used in this attachment to refer to both fin fish and macroinvertebrates. I. CONCEPTUAL APPROACH Producers and consumers both could in theory gain from increases in commercial catch.To estimate the gains to producers, the analysis assumes that the additional fish are caught by fishermen and marketed by wholesalers without any additional effort and that there is no decrease in prices due to the increase in harvest. Thus, producers' revenues are assumed to increase by the product of the current wholesale price and the additional harvest, while their costs remain the same.This approach makes the conservative assumption that there are no additional costs associated with increased efforts to catch and market additional fish. In fact, cost increases are likely to occur. Since the fisheries on the East Coast are currently open-access, it is possible that most of the economic gains from additional catch might be eroded by increases in either each boat's effort or the number of boats harvesting. Economic theory predicts such entry or increased effort, and most empirical experiencewith open-access fisheries confirms the erosion of economic profits (see Anderson 1986 and OECD 1997). If such entry or additional effort occurred, the producer benefits due to increased catch would be smaller than estimated here, perhaps zero.The potential gains to consumers in the form of lower prices are not estimated here.While there may be some effect on price from increased catch, the gains are likely to be relatively small since price changes as a result of the additional fish associated with fish protection alternatives are not likely to be large.The revenues to fishermen and wholesalers (as described above) are used to value the entire benefits resulting from additional commercial catch. These estimates are reasonable, since, as noted above, benefits to producers are overstated and consumer benefits are likely to be small.II. DATA Wholesale prices are presented below in F-13 Table I for each of the species considered. Prices are derived from monthly averages of daily prices at Fulton Fish Market in New York for different species by grade and state of origin. Fulton Fish Market is the largest fish market on the East Coast, and is considered representative of market prices for the entire Coast (see, e.g. Norton, Smith and Strand 1983). Annual prices are estimated by averaging across size grades and months for fish originating from the state of New Jersey, or the closest state if no New Jersey data are available. For striped bass, which had 2 PSE&G PtrrT,l:AD~hcza:ro Nal.rc. 1999 NCAppendtx F relatively few price obsenrations, data.from all states are used. Final values are estimated by averaging across annual estimates.

• 3 PSE&G Permut .-\ppiiicauo

-\arc.r !991)A~ppendiv F REFERENCES Aknderson, Lee G. 1986. The Economics of Fisheries Management. Revised and enlargededition. Baltimore: The Johns Hopkins University Press.National Marine Fisheries Service. 1998. "Fulton Fish Market Average Prices," (data from 1987 to 1997). New York, .NY::National Marine Fisheries Service. Norton, Virgil, V. Kerry Smith, and Ivar Strand (Eds.). 1983. Stripers: The Economic Value of the Atlantic Coast Commercial and Recreational Striped Bass Fisheries.College Park, Maryland: University of Maryland Sea Grant, Publication Number UM-SG-TS-83-12. Organization for Economic Co-operation and Development (OECD). 1997. TowardsSustainable Fisheries: Economic Aspects of the Management of Living Marine Resources. OECD, Paris, France.4 FSE.0 crrt piintG 4 March 1999 Appendix F Attachment 13 Tables F-13 Table 1. Commercial (Wholesale) Fishing Prices Commercial Values per Pound by Year (S1998) 1990-1997 Species 1990 1991 1992 1993 1994 1995 1996 1997 Average Finfish Ainerican Shad SO.71 SO.96 S0.56 50.74 SO.55 $0.60 SO.69 Atlantic Croaker 50.56 $0.92 $0.74 $0.58 $0.71 S0.60 $0.61 $0.67 Atlantic Menhaden "..07'River Herring' " .* $0.191 Spot $0.94 $0.96 $0.67 S0.86 $0.69 $0.81 $0.74 50.81 SO.81 Striped Bass $3.91 $2.85 $3.57 $3.40 $2.32 S2.87 $2.41 S3.05 Weakfish $1.32 S1.31- $1.38 $1.28 SI.28 $0.87 SI.21 SO.84 $1.19 White Perch $1.02 SO.69 SO.96 $1.37 SI.62 SI.44 $1.44 SO.70 $1.15 Macroinvertebrates Blue Crab * .98'* Denotes data not available. a The river herring category combines alewife and blueback herring.b Atlantic menhaden, river herring, and blue crab prices are calculated by multiplying ex-vessel prices by the average ratio of wholesale to ex-vessel prices for other species. Source: NMFS (1990-1997). 6 S APPENDIX F ATTACHMENT 14 VALUATION OF RECREATIONAL CATCH SPONSOR: DAVID HARRISON, Jr.NATIONAL ECONOMIC RESEARCH ASSOCIATES PSE&G RENEWAL APPLICATION SALEM GENERATING STATION PERMIT NO. NJ0005622 4 MARCH 1999 PSE&G Permit Appiication -1 March 1999 Appendix F TABLE OF CONTENTS I. CONCEPTUAL BACKGROUND ............................................................................... II. BASIC TRAVEL COST ESTIMATION METHOD ....................................... 3 III. BENEFITS OF IMPROVED CATCH RATES ................................................ 4 IV. EMPIRICAL ESTIMATES ..................................... 4 IV.A. Overview of M ethodology ................................................................................. 5 IV.B. Recreational Fish Valuation Studies Used in the Analyses ............................ 5 IV.C. Statistical Analyses .................................................................................... 6 IV.D. Results: Value per Pound of Recreational Catch .................. 6 REFERENCES ......................................................................................................... 8 ENDNOTES ............................................................................................................. 9 1 PSE&G Permit Application 4March t999 ATTACHMENT F-14 Appendix F VALUATION OF RECREATIONAL CATCH This attachment describes the method and data used to develop estimates of the value thatrecreational fishermen place on additional pounds of fish caught. This recreational value is used to put a dollar value on the changes in fish caught by recreational fishermen if the fish protection alternatives evaluated in Section IX were implemented. The attachment includes background on the methods economists have developed to put dollar values on recreational fishing as well as the steps used in this study to develop a specific dollar estimate.I. CONCEPTUAL BACKGROUND Access to recreational fishing is a classic non-market commodity. Recreational fishing services are not packaged and sold by private producers to private customers. Thus, it is not possible to use market prices to infer the value that households place on additional catch.The fact that recreational fishing is not a market good does not mean that recreational fishing benefits cannot be put in an economic framework or that the benefits cannot be estimated empirically. It is possible to evaluate the demand for fishing trips to a givenrecreational fishing area in the same way as the demand for any other good or service is considered. Consider the value that recreational fisher-men would place on access to a given fishery.An individual contemplating a fishing trip would incur several types of costs. The monetary costs would include additional fishing equipment (e.g., bait), gasoline, and anyboat or shore access fees that would apply. A less obvious type of cost is the opportunity cost of time. Time spent fishing and traveling to and from the fishing site could be spent in other ways. It could be spent on other leisure activities, such as hiking or reading; it could be spent studying; or it could be spent working. The value of the time used for thetrip in its next best use-that is, the opportunity cost of time-is part of the cost of the fishing trip. Indeed, in many situations it is likely to be the largest component. Both the direct monetary costs of a fishing trip and the opportunity cost of time depend upon distance from the fishery. Gasoline costs and wear and tear on a car would be much greater for someone living 100 miles from the fishery than for someone only 10 miles away. Similarly, the travel time would be far greater for the person farther away.F-14 Figure I shows a hypothetical demand curve for a typical recreational angler living 50 miles from the fishery. This individual would go fishing ten times a year if the cost were S 100 per trip, six times if the cost were S 125, twice if the cost were $ 150, and not at all if the cost were S 162.50 or greater. These values fall along his hypothetical demand curve. Th is demand curve can be used to derive an estimate of the value of the fishery to the angler. If the actual cost of a fishing trip were $100, the individual would go fishing ten times per year and derive a value from using the fishery equal to the area below the demand curve D and above the horizontal line at SI 100. With the linear demand curve 2 PSE&G Applicavon 4 March !999 Appendix F shown in F-14 Figure 1, the individual recreational angler's valuewould be equal to S312.50.'II. BASIC TRAVEL COST ESTIMATION METHOD The travel cost estimation method has been used to develop empirical estimates of the demand for a recreational site-such as a fishery-using travel costs to measure how much people would be willing to pay to use the resource. A simple version of the method consists of the following steps:.1. For a recreation site, the surrounding area is divided into concentric circular zones for the purpose of measuring the travel cost from each zone to the site and return.2. Visitors at the site are sampled to determine their zones of origin.3. Visitation rates defined as visitor days per capita are calculated for each zone of origin.4. A travel cost measure is constructed to indicate the cost of travel from the origin zone to the recreation site and return.5. Using regression analysis, visitation rates are related to travel costs and socioeconomic variables such as average income, median educational attainment, and the like.6. The observed total visitation for the site from all travel cost zones represents one point on the demand curve for that site-the total number of fishermen that would fish at the site at the given access price (typically zero).7. Other points on the demand curve are found by assuming that visitors will.respond to a $I increase in admission price in the same way that they would respond to a S1 increase in computed travel cost. To find the point on the demand curve for the site where the admission price rises by $1, we use the estimated visitation rate equation to compute visitation rates and total visits for all travel cost zones with the existing travel cost plus S1. Visits are summed across travel cost zones to determine the predicted total visitation at the higher price. These calculations are repeated for higher and higher hypothetical admission prices, and, the full demand curve is traced out.Several conceptual and empirical issues arise in developing accurate estimates based upon the travel cost methodology (see, e.g., Freeman 1993 and Lesser, Dodds and Zerbe 1997). For example, because the basic data on fishing trips for households at different locations are obtained from surveys, it is important to design and administer the survey to avoid sampling bias and nonresponse bias. As with all statistical analyses, it is important to avoid bias from omitting important variables. Moreover, it may be particularly difficult to develop accurate estimates of the value that households place on their time, which is important to the empirical estimation. The travel cost method can be extended to provide estimates of the benefits recreational fishermen place on increased catch rates at recreational fisheries. Because fish abundance and other attributes of the fishery do not differ for different individuals fishing at a single location, information on a single fishery cannot be used to estimate the value of increased catch rate (i.e., greater expected pounds of fish caught per trip). Researchers have 8 PSE&G Permiit Applicatnon 4 N1arch 1999.Appendix F developed methods to use inform-ation from multiple sites to infer the value of greater catch rate and other measures of the quality of the fishing experience. The most widely used methods are the random utility model (RUIM) and the travel cost model with multiple sites. The RUM methodology emphasizes the choice of a particular site as a function of the characteristics of all of the sites available to the angler, rather than explaining the number of visits and overall valuation of a given site. iv The existing economic literature can be used to provide information on the value that households place on fishing. As discussed below, we use the results of empirical studies using the travel cost method to develop estimates of the value that recreational fishermen would place on additional recreational catch due to fish protection at the Station. The use of value estimates from existing studies, called the benefits transfer methodology, is a sound and reliable approach to measuring non-market values when site- or region-specific data are not available (see, e.g., Brookshire and Neill 1992).III. BENEFITS OF UIMPROVED CATCH RATESStudies that include catch rate can be used to develop estimates of the increased value that fishermen place on trips with a higher expected catch. F- 14 Figure 2 illustrates the relationship between the benefit per angler trip and the catch rate (i.e., pounds per trip)indicated by the empirical evidence. As the catch rate increases, the value of the trip increases. However, the added value from each additional pound of catch decreases as the catch rate increases. The value of the additional catch can be measured by the, marginal value, i.e. the value that recreational fishermen place on an additional pound of fish caught per angler trip.'- The slope of the curve in F- 14 Figure 2 illustrates the marginal value. The decreasing slope of the benefit curve as catch increases shows the decreasingmarginal benefit of additional pounds of catch. This result is consistent with the basiceconomic concept of diminishing marginal returns and is confirmed by the existingrecreational valuation literature (for example, see Smith, Palmquist, and Jakus (1991)).This relationship between the marginal value and the catch rate (i.e., pounds per trip) is also illustrated in F- 14 Figure 3. The curve shows that the value placed on a given change in the expected catch rate is relatively high when the catch rate is low. As the catch rate increases, the value that recreational fishermnen place on additional fish caught per trip decreases. If this figure were based upon empirical data, the results could be used to calculate, for any given baseline catch rate, the per pound value to recreational fishermen of a small change in the catch rate.IV. EMPIRICAL ESTIMATES Changes in fisheries catch due to the implementation of fish protection alternatives at Salem would be dispersed over a wide geographic region. These additional fish would represent r~elatively small increases in the total catch. These additional fish will produce a small increase in the catch for each angler above the present level of catch they expect on each trip. To measure the value that fishermen place on these small changes, we estimate the marginal value curve, the relationship illustrated in F-14 Figure 3.4 PSE&G Permit Application 4 March 1999 Appendix F is This subsection describes the empirical strategy used to estimate the marginal value curve.As noted in Section IX, the additional fish consist of a variety of species of finfish and macroinvertebrates, some of which are caught by recreational fishermen. (For ease ofexposition, we refer to both categories as fish.) The migration patterns of the fish indicatethat the additional fish would be caught in the Delaware Estuary as well as otherrecreational fisheries on the East Coast. The next section outlines the overall methodology. We then provide the empirical results. IV.A. Overview of Methodology F-14 Figure 4 summarizes the steps involved in using the results of the existing literature to develop an estimate of the value that recreational fishermen place on additional fish.Step 1: Obtain recreational fishing value studies. The first step is to obtain studies that estimate the additional value that recreational fishermen place on additional catch.These studies include both journal articles and published reports.Step 2: Determine relevant studies. The next step is to select studies that are relevant to fishing affected by the Station. Studies were selected based upon fishery location and mode of fishing.Step 3: Conduct a statistical meta-analysis of the marginal value of increased catch.This step uses the relevant studies and statistical estimation procedures to determine the relationship illustrated in F-14 Figure 3. (This study is referred to as a meta-analysis because it uses results from many studies.)Step 4: Determine the marginal value per pound offish. The final step is to use the results of the meta-analysis to calculate the appropriate marginal value for fish relevant to this study.IV.B. Recreational Fish Valuation Studies Used in the Analyses We reviewed hundreds of studies that have been conducted to estimate the dollar value of recreational fishing. These studies related to different geographic locations (East Coast, West Coast, different states), different fishing environments (marine, lake, river, ocean, etc.), different types of fishing (shore, private boat, charter boat, etc.), different target species, and different estimation methodologies (travel cost, contingent valuation, random utility). Many of these studies are not relevant to characteristics of fishing in the Delaware Estuary and other areas that might be affected by changes in fish cropping at the Salem facilities. Thus, in our meta-analysis we restrict the studies to those that estimate the value of recreational fishing for the following circumstances:Vi" East Coast;'ii* Marine environment;* Bank and private boat fishing (excluding charter boat).F-14 Table 1 summarizes the studies that are used in our meta-analysis. The table has multiple entries for studies that estimate incremental benefits using different geographic areas or methodologies. 1 5* PSE&G Permit Application4 March 1999 Appendix F IV.C. Statistical AnalysesThe value that an angler derives from a fishing trip can be expressed as a function of the pounds of fish caught per trip: (1) V=r+(a+4)catch+,8* vc 7 h+ .where V is the dollar value per angler trip, catch is the pounds of fish caught per trip, V, a and/f are unknown parameters, and e and p are error terms. This functional form is chosen because the marginal value is decreasing as the catch rate increases, consistent with the economic theory of declining marginal returns. If the number of fish caught per trip changes, the change in value is: (2) AV = (a + -)Acatch +/8

• A-fc-4 .where A represents the change in a variable.viii Dividing by the change in catch (Acatch)leads to the following equation:) AV A-catch e Acatch Acatch This equation is estimated in the meta-analysis.

F- 14 Table 2 shows the specific data used in the estimation. These data include the change in value per angler trip as reported in each study (in nominal and real dollars), the size of the increase in catch, and the estimate of the catch rate (i.e., average pounds of fish per trip) for the relevant location.lx Equation (3) is estimated using standard statistical techniques yielding the following results.'AV A f-a t (4) IsV = -7.84 + 65.55 A catch Acatch A catchFrom this relationship, the marginal value can be estimated by taking the derivative of(1)and substituting the estimated values of a and/f:xi (5) MV = -7.84 + 32.78/,ctc F-14 Figure 5 shows equation (5) graphically. The results show decreasing marginal value, which, as noted, is consistent with the existing literature. IV.D. Results: Value per Pound of Recreational Catch The statistical relationship in equation (5) can be used to estimate the dollar value for additional pounds of fish at the baseline catch rate relevant to this study, which we assume is the average catch rate for recreational fishermen from New York to North Carolina."ii The average fish per trip for recreational fishermen in this area is 4.67 fish per 6* PSE&C Pý,"Mlt Apiication S..fMarch

,99Q Appendix F angler trip.x" An average weight of 1.78 pounds per fish translates into a baseline catch rate of 8.32 pounds per angler trip.iv Using the statistical relationship in Equation 5 (and F-14 Figure 5) and this baseline catch rate, the dollar value of additional fish is calculated as 53.52 (1998 dollars) per pound.This value is used to determine the recreational catch benefits of reduced cropping of fish at the Station.7 PSE&G Perrh Appiicauon

-\IMarch 1999F REFERENCESAgnello, Richard J. 1988. "The Economic Value of Fishing Success: An Application of Socioeconomic Survey Data." Fishery Bulletin 87(1):224-232. Agnello, Richard J. and Yunqi Han. 1993. "Substitute Site Measures in a Varying Parameter Model with Application to Recreational Fishing." Marine Resource Economics 8:65-77.Arrow, Kenneth et al. 1993. "Report of the NOAA Panel on Contingent Valuation." Silver Spring, MD: NOAA, January 11.Bockstael, Nancy E., Alan Graefe, Ivar E. Strand and Linda Caldwell. 1986. "Economic Analysis of Artificial Reefs: A Pilot Study of Selected Valuation Methodologies." Washington, DC: The Sport Fishing Institute, May.Brookshire, David S. and Helen R. Neill. 1992. "Benefit Transfers: Conceptual and Empirical Issues," Water Resources Research 28(3):651-656. Congressional Budget Office. 1998. Current Economic Projections. http://www.cbo.gov, November 24.Freeman ITf, A. Myrick. 1993. The Measurement of Environmental and Resource Values: Theory and Methods. Washington, DC: Resources for the Future.Gautam, A. and S. Steinbeck. 1998. "Valuation of recreational fisheries in the north-east US. Striped bass: a case study'.Lesser, Jonathan A., Daniel E. Dodds, and Richard 0. Zerbe, Jr. 1997. Environmental Economics and Policy. New York, NY: Addison-Wesley Educational Publishers, Inc.McConnell, Kenneth E. and Ivar Strand. 1994. The Economic Value of Mid and South Atlantic Sportfishing, Volume 2. Report on Cooperative Agreement

1. CR-8 11043-01-0 Between the University of Maryland, the Environmental Protection Agency, the National Marine Fisheries Service and the National Oceanic and Atmospheric Administration.

Washington, DC: U.S. EPA, September. National Marine Fisheries Service. 1998a. Personal communication with the Fisheries Statistics and Economics Division, July-November (available at: http://www.st.nmfs.gov/stl/ index.html). Norton, Virgil, V. Kerry Smith, and Ivar Strand (Eds.). 1983. Stripers: The Economic Value of the Atlantic Coast Commercial and Recreational Striped Bass Fisheries. College Park, Maryland: University of Maryland Sea Grant, Publication Number UM-SG-TS-83-12. Smith, V. Kerry, Raymond Palmquist, and Paul Jakus (1991). "Combining Farrell Frontier and Hedonic Travel Cost Models for Valuing Estuarine Quality", The Review of Economics and Statistics LXXIHf:649-699. Tietenberg, Thomas H. 1992. Environmental and Natural Resource Economics. New York, NY: HarperCollins Publishers. 08 PSE&G Permit 4 %larch 1999 Appendix F ENDNOTES This section draws on the treatment of recreational demand in Lesser, Dodds and Zerbe (1997, pp.296-314).The value is equal to (10

• 362.50)/2, which is the area of the shaded triangle.See Tietenberg (1992). See also Lesser, Dodds and Zerbe (1997, p. 313-314) for a mathematical explanation of the derivation of consumer surplus benefits using the travel cost method.iv See Freeman (1993) for a discussion of the RUM methodology.

Another methodology commonly used is the contingent valuation method (CVM), though none of the studies used in this analysis utilizes this method.The marginal value measures the change in value from a small change in the catch rate. Formally, the marginal benefit is the derivative of the function relating the total value per trip to the catch rate.Some studies meeting these criteria were not included because they did not provide information on incremental values. In addition, some studies providing incremental values were not used because they did not provide results in a form that was compatible with our analyses.We excluded studies based upon Florida fisheries because none of the species ranges extended to Florida. See Table F. 13.1.Therefore, Ac = Ncatch + increment -c , where increment is the increase in catch for which the change in willingness to pay is measured.Sx When studies report marginal benefits, rather than the benefit of an incremental change in catch, the independent variable, , is measured by taking the limit as Acatch -* 0 .As a result, the Acatch independent variable is for these observations. The regression is estimated in Stata using ordinary least squares regression techniques. The t-statistic on the coefficient is 3.15, which is significant at the 99 percent confidence level. The regression has an adjusted-R" of 0.34.The marginal value is MV = a + --,since E[]-=O.This geographic area reflects the range for the fish cropped at Salem. See Table F.12.1.xiii This figure is the weighted average over the period from 1990 to 1996, as reported by the National Marine Fisfieries Service in their Marine Recreational Fisheries Statistical Survey database (National Marine Fisheries Service 1998). The area includes the inland waters of Delaware and New Jersey and ocean waters of all states from New York to North Carolina.89 PSE&G Permit Application M March 1999 Appendix F Pounds per fish is calculated by taking the total weight of harvested fish and dividing by the total number of fish harvested over the same geographic range and years described in the previous footnote.10 PSE&G Permit Application 4 March 1999 Appendix F Attachment 14 Tables F-14 Table 1. Studies Used in Meta-Analvsis Publication Type of Author Year Methodology Geographic Area Species Fishing Agnello & Han 1993 Travel Cost Long Island General Boat & shore Agnello 1988 Travel Cost New York-toFlorida Blue Fish Boat & shore 1988 Travel Cost New York to Florida Summer Flounder Boat & shore 1988 Travel Cost New York to Florida Weakfish Boat & shoreBockstael, Graefe et. al.' 1986 Travel Cost South Carolina (inlet) General Boat 1986 Travel Cost South Carolina General Boat Gautam & Steinbeck 1998 Random Utility Maine to Virginia Striped Bass Boat & shore 1998 Travel Cost Maine to Virginia Striped Bass Boat & shore Norton, Strand & Smith 1980 Travel Cost New England Striped Bass Boat & shore 1980 Travel Cost Mid Atlantic Striped Bass Boat & shore 1980 Travel Cost Chesapeake Striped Bass Boat & shore 1980 Travel Cost South Atlantic Striped Bass Boat & shore McConnell & Strandb 1994 Random Utility New York to Georgia General Boat & shore 1994 Random Utility New York to Georgia General Boat & shore 1994 Random Utility New York to Georgia General Boat & shore 1994 Travel Cost New York to Georgia General Boat & shore 1994 Travel Cost New York to Georgia General Boat & shore 1994 Travel Cost New York to Georgia General Boat & shore a Study evaluates an on-site intercept survey from Murrel's Inlet, South Carolina and a general mail survey of South Carolina fishermen. b Marginal recreational values are estimated by the authors using three different approaches for both therandom utility and travel cost methods. The results from all three are included as separate data points since the authors do not state a preferred model and results vary dramatically. S 7 PSE&G Permit Application 4 March 1999 Appendix F F-14 Table 2. Data Used in Meta-Analysis Author Study Incremental Incremental Increment IncrementalValue Catch Rate Year. Value (Nomr.) Value Size (lbs.)d per pound (Pounds/Trip)'(S1998)c ($1998)Agnello& Han 1981 S 1.86 S 3.18 0.99 $ 3.21 4.95 Agnello 1980 S 1.36 S 2.53 (2.50) S 1.01 I0.52 1980 S 9.24 S17.22 (1.12) SI5.40 2.17 1980 $ 1.79 S 3.34 (3.47) S 0.96 11.64 Bockstael, Graefe 1985 S12.00 S17.23 2.34 S 7.36 11.70 et. al. 1985 $ 5.00 $ 7.18 1.85 S 3.88 9.25 Gautarn & 1994 $ 3.37 S 3.62 12.06 S 0.30 6.60 Steinbeck 1994 $16.36 S17.59 (12.06) S 1.46 6.60 Norton, Strand & 1980 $12.63 S23.54 14.30 $ 1.65 5.15 Smith 1980 S 7.44 $13.87 14.30 $ 0.97 6.86 1980 $ 5.30 S 9.88 14.30 S 0.69 10.01 1980 $ 1.34 S 2.50 14.30 S 0.17 5.01 McConnell & 1988 S 7.88 $10.30 0.53 $19.36 5.17 Strand 1988 $ 3.97 $ 5.19 0.53 $ 9.76 5.17 1988 $ 0.27 S 0.36 0.53 $ 0.67 5.17 1988 $ 0.95 S 1.30 0.53 $ 2.44 5.17 1988 $ 0.96 $ 1.31 0,53 S 2.47 5.17 1988 S 2.32 $ 3.17 0.53 $ 5.97 5.17'Study year indicates the year for which the data were collected. b Incremental value is the increase in individual consumer surplus for the incremental increase in catch per trip, reported in nominal dollars of the study year. The increment size, which varies across the studies, is reported in the increment size column. For Agnello and the travel cost results from Gautam & Steinback, the marginal value of increased catch (measured in number of fish) is reported.Incremental value in 1998 dollars, where the 1998 GDP Deflater (CPI) is used to convert dollars in thestudy year to 1998 dollars (Congressional Budget Office, 1998)." Increment size is the increase in catch for which the change in individual value is estimated (i.e. the incremental value). The studies measure the change in the value of a trip for an increase in either the number of fish caught or a percentage increase in the total catch. Average fish size and total catch estimates are used to convert these increments into pounds. For studies reporting marginal values of increased catch, the average pounds per fish is used to convert numbers of fish to pounds of fish. For these studies, average fish weight is reported in parentheses. Change in value per pound is estimated by dividing the incremental value (in $1998) by the increment size. For Agnello and the travel cost results from Gautarn & Steinback, the marginal value for increased catch (measured by weight) is reported.f The pounds per trip are calculated from the following sources: Agnello & Han, and Agnello -Calculated from fish per trip reported by study and MRFSS fish weight data; Bockstael et. al., and Norton, Strand &Smith -Calculated from study data; Gautarn & Steinbeck, and McConnell and Strand -Calculated fromMarine Recreational Fisheries Statistical Survey Database for the study year or the closest year for which data are available in the study state.8 0 PSE&G Per-n! Ai ph,:.cn.-ppec:,,;; F Attachment 14 Figures 33501 S300 S250 S200 1$50 3100 S50 D 0 2 4 6 8 10 12 Number of Annual Visits F-14 Figure 1. Hypothetical Value of Recreational Fishing 9 PSE&G Permit Application 4 March 1999 Appendix F alue per Fisherman Trip Slope -Marginal Value (S/pound) at a given Baseline Pound" per Fisherman Trip Value per Fisherman Trip Baseline Pounds per Fisherman Trip Catch Rate (Pounds per Trip)F-14 Figure 2. Hypothetical Value per Fisherman Trip at Different Catch Rates 10 PSE&G Permit Application 4 March 1999 Appendix F Marginal Value (S/pound)Marginal Value of Increased Catch.ý3 Baseline Pounds per Fisherman Trip Catch Rate (Pounds per Trip)F-14 Figure 3. Hypothetical Marginal Value per Fisherman Trip at Different Catch Rates 81 11 PSE&G Pernit Apphcaion 4 March !999 Appendix F Recreational Fishing Value Studies Relevant Studies-Marine Fishing -East Coast-Shore / Boat Meta Study of Marginal Value= Catch Rate (Pounds per Thp)Marginal Value F-14 Figure 4. Methodology for Estimating Recreational Fish Value 12 PSE&.G Pvrmit AppiibafiLon ~Nfaj-rz 1999 Appcndix F 0Oc V\M 516.00 S14.00 512.00 S10.00 S8.00$6.00 S4.00 S2.00 SO.0O fisherm 3.0 4.0 5.0 6.0 7.0 8.0 9.0 10.0 11.0 12.0 13.0 14.0 15.0 Average Catch for RIS Species Range (lbs/trip) F-14 Figure 5. Estimated Marginal Value of Additional Recreational Catch 13 APPENDIX F ATTACHMENT 15 DETAILED BENEFITS TABLES SPONSOR: DAVID HARRISON, Jr.NATIONAL ECONOMIC RESEARCH ASSOCIATES PSE&G RENEWAL APPLICATION SALEM GENERATING STATION PERMIT NO. NJ0005622 4 MARCH 1999 PSE&G Permit Application 4 March 1999 Appendix F ATTACHMENT 15 DETAILED BENEFIT TABLES Section IX of Appendix F evaluates the costs and benefits of fish protection alternativesfor Salem. This attachment provides the details of the calculation of total benefits for each fish protection alternative evaluated in Section IX. F- 15 Table 1 provides the present value of benefits for all alternatives for commercial/recreational species and non-RIS.The term commercial/recreational species refers to RIS with commercial or recreational value as well as blue crab, a species with recreational and commercial value. F-15 Tables 2 through 13 provide the base year increases in RIS, in pounds of adult equivalents, due to each alternative. Forage fish increases are included in changes of RIS commercial/recreational fish adult equivalent weight. The commercial and recreational quantities reflect the percentages of each species caught by recreational and commercial fishermen over the relevant species range (NMFS 1998; Miller and Lupine 1996; Frenchet al. 1996; and Whitmore 1998). The quantity of non-RIS (Atlantic Menhaden and other non-RIS) are also reported in F-15 Tables 2 through 13. Attachment F-4 provides details on the estimation of the pounds of equivalent adults of commercial/recreational species and non-RIS.The value per pound for other non-RIS is based upon the per pound values for RIS commercial/recreational fish. F- 15 Table 14 shows this calculation. The first step is to determine average values for each RIS by averaging the recreational and commercial values, using the recreational and commercial proportions as weights. The second step is to determine an average value across all RIS by averaging the individual RIS values, , using each species' proportion of base case plant losses as weights. These weights are reported in the final column of F-15 Table 14. The resulting average value for RIS is$1.89 per pound.F-15 Tables 15 through 26 provide the benefits estimates, in dollars, for each species inthe base year. The benefits from each species are provided in the top portion of the tableand are calculated by multiplying the biomass increases resulting from the alternative for that species by the appropriate value per pound. The commercial values per pound for each species are provided in Attachment F-13 and the recreational value per pound is provided in Attachment F-14. The benefits from non-RIS are calculated by multiplying the biomass increases (in pounds) by the appropriate values.F-15 Tables 27 through 38 provide the annual benefits due to each alternative. Thesebenefit estimates reflect the total value of the increases in populations of all species due to each alternative. These tables also provide the resulting present value of benefits as of January 1, 2001, discounted at an annual rate of 6.19 percent.' Note that the calculations of present values take into account the months in which an alternative would operate during the first year of operation. In later years, we assume that benefits are evenly distributed over the year. Note that the standard calculation of present value assumes that payments are made at the end of each period. Where the "payments," or benefits, occur throughout the year, this approach leads to improper discounting. To correct for this effect, present value calculations include a six-month adjustment. This adjustment results 3* PSE&G Pernai Apphca::on M ,arch i 999 Appendix F in present value calculations which assume payments are made in the middle of the period, the correct approach for payments evenly distributed over the period.2 PSE&G Pe mýi AppDicauorn N )999 Appendix F ENDNOTES I Nominal cost of capital provided by PSE&G (8,42 percent) adjusted by Congressional Budget Office Current Economic Predictions of the future Implicit GDP Deflator (2.1 percent). The nominal interest rate is adjusted for inflation using the following formula: [(I+PSE&G Cost of Capital)/(l+Projected GDP Deflator) -1]. Using this formula and the data above, the real discount rate based on PSE&G's cost of capital is (1.0842)/(1.02

1) -1 = .0619, or 6.19 percent.3 F -15 Table 1. Present Value of Benefits by Component for Fish Protention Alternatives Benefit Component (millions)

Alternative Recreational Commercial Non-RIS Total Intake Modifications Strobe Light and Air Bubble Curtain S0.8 SO.5 50.1 51.4 Dual-Flow Fine Mesh Screens (50.4) S1.9 32.0 S3.5 Modular Inclined Screens S0.3 (31.1) 30.0 (SO.8)Flow Reduction (F.R.) Alternatives Revised Refueling Outage Schedule S10.6 $3.6 31.0 515.3 Seasonal F.R. 10% Delta T Vary 52.1 (30.2) $0.0 52.0 Seasonal F.R. 20% Delta T Vary 53.9 (50.5) $0.1 53.5 Seasonal F.R. 45% Delta T Vary S12.7 S2.9 30.2 $15.8 Seasonal F.R. 10% Delta T Constant S3.1 $0.6 $0.0 53.8 Seasonal F.R. 20% Delta T Constant 57.6 $2.2 $0.1 39.9 Seasonal F.R. 45% Delta T Constant S18.8 56.4 30.2 525.4 Natural Draft Towers S32.2 S14.9 S10.8 558.0 Mechanical Draft Towers 532.2 314.9 310.8 558.0 Note: Present values in 1998 millions of dollars as of January 1, 2001. Parentheses indicate negative values.4 F -15 Table ,2. Annual Biomass Benefits (lbs.): Strobe Light and Air Bubble Curtain RIS Species Total Recreational Commercial Fin Fish American Shad 209 116 93Atlantic Croaker 6,069 603 5,466 River Herring 135 99 36 Spot 4,095 718 3,376 Striped Bass 8,831 8,589 242 Weakfish 36,357 11,353 25,004 White Perch 85 35 49 Invertebrates Blue Crab 13,561 542 13,018 Non-RIS Species Atlantic Menhaden 6,963 Other 3,917 Notes: All weights expressed in pounds of adult equivalents. Parentheses indicate negative values."0" entries indicate a positive value of less than 0.5.Source: Attachment F-4; Table F.12.2. 8 5 F -15 Tab e 3. Annual Biomass Benefits (lbs.): Dual-Flow Fine Mesh Screens Total Recreational Commercial RIS Species Fin Fish American Shad Atlantic Croaker River Herring SpotStriped Bass Weakfish White Perch InvertebratesBlue Crab Non-RIS Species Atlantic Menhaden Other 19 (225,684)307 315,435 (93,524)142.8 15 4,934 11 (22,418)225 55.336 (90,963)44,597 2,051 8 (203,266)82 260,099 (2,562)98,218 2,883 174,43 8 98.,122 Notes: All weights expressed in pounds of adult equivalents. Parentheses indicate negative values."0" entries indicate a positive value of less than 0.5.Source: Attachment F-4; Table F.12.2.6 F -15 Tabl e 4. Annual Biomass Benefits (lbs.): Modular Inclined Screens Total Recreational RIS Species Fin FishAmerican Shad Atlantic CroakerRiver Herring Spot Striped Bass Weakfish White Perch Invertebrates Blue Crab Non-RIS Species Commercial (467)5,474 (307)(5,068)3,989 4,4,300 (100)(177,401)(259)544 (225)(889)3,879 13,834 (42)(7,096)(208)4,930 (82)(4,179)109 30,466 (59)(170,305)Atlantic Menhaden 4,183 Other 2,353 Notes: All weights expressed in pounds of adult equivalents. Parentheses indicate negative values."0" entries indicate a positive value of less than 0.5.Source: Attachment F-4; Table F.12.2.S 7 F -15 Table 5. Annual Biomass Benefits (lbs.): Revised Refueling Outage Schedule RIS Species Total Recreational Commercial Fin Fish American Shad (97) (54) (43)Atlantic Croaker 55,693 5.532 50,160 River Herring (122) (90) (32)Spot 69,653 12,219 57,.434 Striped Bass 168,902 164.276 4,626 Weakfish 280.944 87,732 193.213 White Perch 1.965 817 1,143 InvertebratesBlue Crab 412 16 396 Non-RIS SpeciesAtlantic Menhaden 81,526 Other 45.858 Notes: All weights expressed in pounds of adult equivalents. Parentheses indicate negative values."0" entries indicate a positive value of less than 0.5.Source: Attachment F-4; Table F.12.2.8 F -15 Tabl e 6. Annual Biomass Benefits (lbs.): Seasonal F.R. 10% Delta T Vary Total Recreational RIS Species Fin Fish American Shad Atlantic Croaker River Herring Spot Striped Bass Weakfish White Perch Invertebrates Blue Crab Non-RIS Species Atlantic Menhaden Other Commercial (961)3 (93,561)58,241 45,686 307 397 (95)2 (16,413)56,645 14,266 127 16 (865)1 (77,148)1.595 31,419 179 381 3,803 2.139 Notes: All weights expressed in pounds of adult equivalents. Parentheses indicate negative values."0" entries indicate a positive value of less than 0.5.Source: Attachment F-4; Table F.12.2.81 9 F- 15T: able 7. Annual Biomass Benefits (lbs.): Seasonal F.R. 20% Delta T Vary Total Recreational Commercial RIS Species Fin Fish American Shad Atlantic Croaker River Herring Spot Striped Bass Weakfish White Perch Invertebrates Blue Crab Commercial 2 (4,075)5 (158.945)111,835 59,028 556 1 (405)4 (27.883)108,772 18,433 231 73 1 (3.67 1)1 (131,062)31063 40,595 325 1.759 1,832 7,767 Non-RIS Species Atlantic Menhaden Other 4,369 Notes: All weights expressed in pounds of adult equivalents. Parentheses indicate negative values."0" entries indicate a positive value of less than 0.5.Source: Attachment F-4; Table F.12.2.0 10 F -15 Tabe 8. Annual Biomass Benefits (lbs.): Seasonal F.R. 45% Delta T Vary Total Recreational RIS Species Fin Fish American ShadAtlantic CroakerRiver Herring Spot Striped Bass Weakfish White Perch Invertebrates Blue Crab Non-RIS Species Atlantic Menhaden Other Commercial 2 (2.975)11 (42,705)234,156 324,394 3,602 4,059 1 (296)8 (7,492)227,742 101.300 1.497 1 (2,680)3 (35,213)6,413 223,094 2,104 162 3,897 17,677 9,943 Notes: All weights expressed in pounds of adult equivalents. Parentheses indicate negative values."0" entries indicate a positive value of less than 0.5.Source: Attachment F-4: Table F.12.2. 8 II F- 15 Tab le 9. Annual Biomass Benefits (lbs.): Seasonal F.R. 10% Delta T Constant Total Recreational RIS SpeciesFin Fish American ShadAtlantic Croaker River Herring Spot Striped Bass Weakfish White Perch Invertebrates Blue Crab Non-RIS Species Commercial 185 3 (39,124)60,179 87.959 766 941 IS (6,863)58,530 27,467 318 167 1 (32,261)1,648 60,492 448 38 904 Atlantic Menhaden 3,803 Other 2.139 Notes: All weights expressed in pounds of adult equivalents. Parentheses indicate negative values."0" entries indicate a positive value of less than 0.5.Source: Attachment F-4; Table F.12.2.12 F -15 Table 10. Annual Biomass Benefits Olbs.): Seasonal F.R. 20% Delta T ConstantRIS Species Total Recreational Commercial Fin Fish American Shad 2 1 1 Atlantic Croaker 1,397 139 1,259River Herring 5 4 1 Spot (326) (57) (269)Striped Bass 124,359 120.952 3,406 Weakfish 22S,469 71,345 157.124White Perch 2.159 897 1.261 Invertebrates Blue Crab 1,832 73 1.759 Non-RIS Species Atlantic Menhaden 7,767 Other 4,369 Notes: All weights expressed in pounds of adult equivalents. Parentheses indicate negative values."0" entries indicate a positive value of less than 0.5.Source: Attachment F-4; Table F.12.2.513 F -15 Tab le IL. Annual Biomass Benefits (lbs.): Seasonal F.R. 45% Delta T Constant Total Recreational Commercial RIS Species Fin Fish American ShadAtlantic Croaker River Herring Spot Striped Bass Weakfish White Perch InvertebratesBlue Crab Non-RIS Species Atlantic Menhaden 2 4,491 I1 96.669 283,306 583,336 5,699 4,059 17,677 1 4,46 8 16,958 275,546 182.160 2,369 1 4.045 3 79,711 7,760 401,175 3.330 162 3,897 Other 9,943 Notes: All weights expressed in pounds of adult equivalents. Parentheses indicate negative values."0" entries indicate a positive value of less than 0.5.Source: Attachment F-4; Table F.12.2.14 F -15 Table 12. Annual Biomass Benefits (lbs.): Natural Draft Towers RIS Species Total Recreational Commercial Fin Fish American Shad 613 340 273Atlantic Croaker 751,119 74,612 676.507 River Herring 1,047 768 279 Spot 384.222 67,403 316.819 Striped Bass 640,675 623,127 17.548 Weakfish 1.517,959 474,019 1,043.940White Perch 21.203 8.814 12.389 Invertebrates Blue Crab 23,381 935 22.446 Non-RIS Species Atlantic Menhaden 1,298,844 Other 730.600 Notes: All weights expressed in pounds of adult equivalents. Parentheses indicate negative values."0" entries indicate a positive value of less than 0.5.Source: Attachment F-4; Table F.12.2.S!15 F -15 Tabl e 13. Annual Biomass Benefits (lbs,): Mechanical Draft Towers Total Recreational PIS Species Fin FishAmerican ShadAtlantic Croaker River Herring Spot Striped Bass Weakfish White Perch InvertebratesBlue Crab Non-RIS Species Commercial 613 751.119 1,047 384.222 640,675 1,517,959 21,203 23,381 340 74,612 768 67.403 623,127 474.019 8,814 273 676,507 279 316,819 17.548 1,043,940 12,389 935 22.446 Atlantic Menhaden 1,298,844 Other 730.600Notes: All weights expressed in pounds of adult equivalents. Parentheses indicate negative values. "0" entries indicate a positive value of less than 0.5.Source: Attachment F-4; Table F.12.2.16 F- 15 Table 14. Weighted Average RIS Price per Pound Recreational Commercial Average RIS Percentage of RIS Species Value Percentage Value Percentage Species Value Total RIS Pounds Fin Fish American Shad S3.52 56% 50.69 44% S2.26 0.02%Atlantic Croaker 33.52 10% 30.67 90% S0.96 25.16%River Herring 33.52 73% $0.19 27% 52.64 0.03%Spot S3.52 18% 30.81 82% 51.29 11.89%Striped Bass 33.52 97% 33.05 3% 53.51 18.45%Weakfish S3.52 31% $1.19 69% S1.92 .43.23%White Perch $3.52 42% 31.15 58% 32.14 0.64%Invertebrates Blue Crab $3.52 4% SO.98 96% S1.08 0.59%Weighted Average RIS Price per Pounda $1.89 Note: aWeights are percentage of total RIS pounds based on current intake structure. S 17 F -15 Table. 15. Annual Benefits: Strobe Light and Air Bubble Curtain RIS Species Recreational RIS Commercial RIS Fin Fish American Shad SO.41 $0.06 Atlantic Croaker S2.12 53.68 River Herring 30.35 S0.01 Spot 32.53 52.74Striped Bass S30.27 30.74 Weakfish $40.02 $29.67 White Perch 30.12 $0.06 Invertebrates Blue Crab S1.9 !12.79 Total RIS Benefits 377.74 S49.74Non-RIS Species Non-RIS BenefitsAtlantic Menhaden $0.50 Other $7.41 Total Non-RIS Benefits $7.90 Notes: RIS forage fish included in game fish gains.All values in thousands of 1998 dollars. Parentheses indicate negative values.Source: NERA calculations as described in text.18 F -15 Table. 16. Annual Benefits: Dual-Flow.Fine Mesh Screens RIS Species Recreational RIS Commercial RIS Fin Fish American Shad $0.04 $0.01 Atlantic Croaker (S79.02) ,(3136.90) River Herring $0.79 0.02 Spot S195.04 $210.79 Striped Bass ($320.61) ($7.81)Weakfish $157.19 $116.53 White Perch 57.23 $3.33 Invertebrates Blue Crab SO.00 $0.00 Total RIS Benefits ($39.34) $185.96 Non-RIS Species -Non-RIS Benefits Atlantic Menhaden $12.47 Other $185.57 Total Non-RIS Benefits $198.05 Notes: RIS forage fish included in game fish gains.All values in thousands of 1998 dollars. Parentheses indicate negative values.Source: NERA calculations as described in text.S 8 19 F -15 Table. 17. Annual Benefits: Modular Inclined Screens RIS Species Recreational RIS Commercial RIS Fin Fish American Shad (50.91) (30.14)Atlantic Croaker S1.92 33.32 River Herring (30.79) (30.02)Spot (S3.13) (S3.39)Striped Bass S13.67 30.33 Weakfish 348.76 536.15 White Perch (30.15) (30.07)Invertebrates Blue Crab (S25.01) (S167.33)Total RIS Benefits 534.35 ($131.14)Non-RIS Species Non-RIS Benefits Atlantic Menhaden $0.30 Other 34.45Total Non-RIS Benefits $4.75 Notes: RIS forage fish included in game fish gains.All values in thousands of 1998 dollars. Parentheses indicate negative values.Source: NERA calculations as described in text.ý 20 F -15 Table. 18. Annual Benefits: Revised Refueling Outage Schedule RIS Species Recreational RIS Commercial RIS Fin Fish American Shad (S0.19) (S0.03)Atlantic Croaker S19.50 S33.78 River Herring (SO.32) (S0.01)Spot 343.07 S46.55Striped Bass S579.02 S14.10 Weakfish 5309.22 $229.24White Perch S2.88 $1.32 Invertebrates Blue Crab $0.06. $0.39 Total RIS Benefits 5953.24 3325.34 Non-RIS Species Non-RIS BenefitsAtlantic Menhaden $5.83 Other 386.73 Total Non-RIS Benefits $92.56 Notes: RIS forage fish included in game fish gains.All values in thousands of 1998 dollars. Parentheses indicate negative values.Source: NERA calculations as described in text.U 21 F -15 Table. 19. Annual Benefits: Seasonal F.R. 10% Delta T VaryRIS Species Recreational RIS Commercial RIS Fin Fish American Shad $0.00 $0.00 Atlantic Croaker (S0.34) ($0.58)River Herring $0.01 SO.00 Spot (557.85) (S62.52)Striped Bass $199.66 $4.86 Weakfish $50.28 537.28 White Perch $0.45 $0.21 InvertebratesBlue Crab $0.06 $0.37 Total RIS Benefits 5192.27 (320.39)Non-RIS Species Non-RIS BenefitsAtlantic Menhaden $0.27 Other $4.05 Total Non-RIS Benefits $4.32 Notes: RIS forage fish included in game fish gains.All values in thousands of 1998 dollars. Parentheses indicate negative values. Source: NERA calculations as described in text. F -15 Table. 20. Annual Benefits: Seasonal F.R. 20% Delta T Vary RIS Species Recreational RIS Commercial RIS Fin Fish American Shad S0.00 S0.00Atlantic Croaker (51.43) ($2.47)River Herring $0.01 $0.00 Spot (598.28) ($106.22)Striped Bass S383.38 59.33 Weakfish $64.97 $48.16 White Perch $0.81 $0.38 Invertebrates Blue Crab SO.26 $1.73 Total RIS Benefits 3349.74 ($49.09)Non-RIS Species Non-RIS BenefitsAtlantic Menhaden $0.56 Other $8.26Total Non-RIS Benefits $8.82 Notes: RIS forage fish included in game fish gains.All values in thousands of 1998 dollars. Parentheses indicate negative values.Source: NERA calculations as described in text.I 23 F -15 Table. 21. Annual Benefits: Seasonal F.R. 45% Delta T Vary RIS Species Recreational RIS Commercial RIS Fin Fish American Shad 50.00 50.00 Atlantic Croaker (S1.04) (51.80)River Herring 50.03 SO.00 Spot (S26.41) (328.54)Striped Bass 5802.71 S 19.54 Weakfish S357.05 5264.69 White Perch S5.28 S2.43 Invertebrates Blue Crab SO.57 S3.83 Total RIS Benefits $1.138.19 S260.15 Non-RIS Species Non-RIS Benefits Atlantic Menhaden $1.26 Other $18.81 Total Non-RIS Benefits $20.07 Notes: RIS forage fish included in game fish gains.All values in thousands of 1998 dollars. Parentheses indicate negative values.Source: NERA calculations as described in text.24 F -15 Table. 22. Annual Benefits: Seasonal F.R. 10% Delta T Constant RIS Species Recreational RIS Commercial RIS Fin Fish American Shad 30.00 30.00Atlantic Croaker 30.06 "0.11River Herring $0.01 S0.00 Spot (524.19) (326.14)Striped Bass $206.30 35.02 Weakfish 596.81 371.77 White Perch S1.12 S0.52 Invertebrates Blue Crab $0.13 $0.89 Total RIS Benefits $280.25 $52.16 Non-RIS Species Non-RIS Benefits Atlantic Menhaden $0.27 Other $4.05 Total Non-RIS Benefits $4.32 Notes: RIS forage fish included in game fish gains.All values in thousands of 1998 dollars. Parentheses indicate negative values.Source: NERA calculations as described in text.0 S 25 F -15 Table. 23. Annual Benefits: Seasonal F.R. 20% Delta T Constant RIS Species Recreational RIS Commercial RIS Fin Fish American Shad 30.00 $0.00 Atlantic Croaker S0.49 30.85 River Herrin2 $0.01 30.00 Spot (30.20) ($0.22)Striped Bass S426.32 $10.38 Weakfish S251.47 S186.42 White Perch 53.16 31.46 Invertebrates Blue Crab SS.26 31.73 Total RIS Benefits 3681.51 3200.61 Non-RIS Species Non-RIS Benefits Atlantic Menhaden 30.56 Other 58.26 Total Non-RIS Benefits $8.82 Notes: RIS forage fish included in game fish gains.All values in thousands of 1998 dollars. Parentheses indicate negative values.Source: NERA calculations as described in text.26 F -15 Table. 24. Annual Benefits: Seasonal F.R. 45% Delta T Constant RIS Species Recreational RIS Commercial RIS Fin Fish American Shad 30.00 S0.00 Atlantic Croaker S1.57 S2.72 River Herring 50.03 S0.00 Spot S59.77 S64.60 Striped Bass 3971.21 323.65 Weakfish S642.05 S475.97 White Perch S8.35 $3.84 Invertebrates Blue Crab $0.57 S3.83 Total RIS Benefits $1.683.56 $574.61 Non-RIS Species Non-RIS Benefits Atlantic Menhaden 31.26 Other $18.81 Total Non-RIS Benefits S20.07 Notes: RIS forage fish included in game fish gains.All values in thousands of 1998 dollars. Parentheses indicate negative values.Source: NERA calculations as described in text.S 27 F -15 Table. 25. Annual Benefits: Natural Draft Towers RIS Species Recreational RIS Commercial RIS Fin Fish American Shad S1.20 50,19 Atlantic Croaker S262.98 S455.64 River Herring 52.71 SO.05 Spot 5237.57 S256.76 Striped Bass 52,196.31 $53.48 Weakfish 51,670.75 $1,238.57 White Perch 531.07 S14.30 Invertebrates Blue Crab 53.30 522.05 Total RIS Benefits 54,405.88 $2,041.03 Non-RIS Species Non-RIS Benefits Atlantic Menhaden S92.88 Other S1,381.73 Total Non-RIS Benefits 51,474.62 Notes: RIS forage fish included in game fish gains.All values in thousands of 1998 dollars, Parentheses indicate negative values.Source: NERA calculations as described in text.28 F -15 Table. 26. Annual Benefits: Mechanical Draft Towers RIS Species Recreational RIS Commercial RIS Fin Fish American Shad 51.20 50.19 Atlantic Croaker S262.98 S455.64River Herrin-S2.71 50.05 Spot S237.57 S256.76 Striped Bass 52,196.31 S53.48 Weakfish 31,670.75 $1,238.57 White Perch $31.07 S14.30 Invertebrates Blue Crab $3.30 S22.05 Total RIS Benefits 34.405.88 $2,041.03 Non-RIS Species Non-RIS Benefits Atlantic Menhaden $92.88 Other $1.381.73 Total Non-RIS Benefits 31,474.62 Notes: RIS forage fish included in game fish gains.All values in thousands of 1998 dollars. Parentheses indicate negative values.Source: NERA calculations as described in text.S 8 29 F -15 Table 27. Total Benefits: Strobe Light and Air Bubble Curtain Year Recreational RIS Commercial RIS Non-RIS Total 2001 532 $20 so $52 2002 578 550 $8 5135 2003 S78 $50 S8 S135 2004 $78 $50 $8 S135 2005 $78 $50 $8 S135 2006 $78 $50 $8 5135 2007 578 $50 $8 $135 2008 $78 S50 $8 $135 2009 $78 $50 $8 $135 2010 $78 $50 $8 $135 2011 $78 $50 $8 $135 2012 $78 $50 $8 5135 2013 $78 $50 $8 $135 2014 $78 $50 $8 $135 2015 $78 $50 $8 $135 2016 $78 $50 $8 $135 2017 S58 $37 $6 $102 2018 $39 $25 $4 $68 2019 $39 $25 $4 $68 2020 $39 $25 $4 $68 2021 $29 $19 $3 $51 Present Value $823 $527 $81 $1,430 Notes: Present values as of January 1, 2001.All values in thousands of 1998 dollars. Parentheses indicate negative values.Source: NERA calculations as explained in text.30 F- 15 Table 28. Total Benefits: Dual-Flow Fine Mesh Screens Year Recreational RIS Commercial RIS Non-RIS Total 2001 s0 So so so 2002 (S39) S186, S198 3345 2003 ($39) 3186 3198 S345 2004 (339) 3186 3198 3345 2005 (339) 5186 3198 3345 2006 (S39) 3186 3198 S345 2007 (339) $186 3198- S345 2008 (S39) 5186 $198 3345 2009 (339) 3186 3198 3345 2010 ($39) S186 S198 3345 2011 (339) 3186 $198 5345 2012 (339) 3186 3198 $345 2013 (339) 3186 3198 3345 2014 (339) 5186 $198 S345 2015 (339) 5186 $198 S345 2016 ($39) 5186 3198 S345 2017 (330) $139 $149 $259 2018 (320) 393 $99 3172 2019 ($20) $93 $99 $172 2020 (320) $93 $99 3172 2021 (S15) $70 S74 3129-Present Value (3401) 51,895 $2,018 $3,513 Notes: Present values as of January 1, 2001.All values in thousands of 1998 dollars. Parentheses indicate negative values.Source: NERA calculations as explained in text.8 F -15 Table 29. Total Benefits: Modular Inclined Screens Year Recreational RIS Commercial RIS Non-RIS Total 2001 so $0 so s0 2002 so s0 s0 s0 2003 30 30 s0 SO 2004 S34 (S131) 35 (S92)2005 S34 ($131) $5 (S92)2006 S34 (S131) 35 (S92)2007 S34 ($13.1) S5 (392)2008 $34 (S131) $5 (S92)2009 $34 (S131) $5 (S92)2010 $34 ($131) S5 (S92)2011 S34 ($131) $5 (S92)2012 S34 (S131) $5 (S92)2013 $34 ($131) $5 ($92)2014 S34 ($131) $5 (S92)2015 S34 ($131) $5 (392)2016 $34 (S131) $5 (392)2017 $26 ($98) $4 ($69)2018 $17 ($66) $2 ($46)2019 $17 ($66) $2 ($46)2020 S17 (S66) $2 ($46)2021 $13 (349) $2 (S35)Present Value $289 (51,104) S40 (S775)Notes: Present values as of January 1, 2001.All values in thousands of 1998 dollars. Parentheses indicate negative values.Source: NERA calculations as explained in text. F- 15 Table 30.Year 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 Total Benefits: Revised Refueline Outage Schedule Recreational RIS Commercial RIS 3953 5325 3953 5325 5953 $325$953 3325 3953 5325$953 3325 5953 5325$953 S325$953 5325 5953 $325 5953 5325$953 $325 5953 3325$953 3325$953 $325$953 $325 S715 $244$477 $163 5477 S163$477 $163$357 S122 Non-RIS 393$93$93$93$93$93 593 393$93 393$93$93$93$93$93$93$69$46$46$46$35 Total 31,371 S1.371 51,371 S1,371 Si.371 S1,371 S 1,371 51,371 S1,371 31,371 51,371 31,371 S1,371 S1,371 31,371 S1,371 S1,028$686$686$686$514 Present Value S10,640 $3,631 $1,033 $15,304 Notes: Present values as of January 1. 2001.All values in thousands~of 1998 dollars. Parentheses indicate negative values.Source: NERA calculations as explained in text.IS 33 F- 15 Table 31.Year 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 Total Benefits: Seasonal F.R. 10% Delta T Var'Recreational RIS Commercial RIS S192 ($20)S192 (S20)5192 (S20)$192 (S20)5192 (S20)5192 (520)$192 (S20)$192 (S20)5192 (520)$192 ($20)5192 (S20)$192 (520)3192 ($20)$192 ($20)S192 (S20)S192 (520)$144 (515)$96 ($10)$96 ($10)$96 ($I0)S72 ($8)Non-RIS S4 S4 54 S4 54 S4 S4 S4 S4 S4 $4$4$4$4$4$4$3$2$2$2$2 Total 5176 5176 5176 5176$176 5176 5176$176 5176 5176 S176$176$176 5176 5176$176$132 588$88$88 S66 Present Value S2.146 ($228) $48 $1,967 Notes: Present values as of January 1, 2001.All values in thousands of 1998 dollars. Parentheses indicate negative values.Source: NERA calculations as explained in text.34 F -15 Table 32. Total Benefits: Seasonal F.R. 20% Delta T Vary Year Recreational RIS Commercial RIS 2001 5350 (S49)2002 3350 (S49)2003 S350 (349)2004 5350 (S49)2005 5350 (S49)2006 3350 (349)2007 $350 (349)2008 3350 ($49)2009 5350 (S49)2010 S350 (S49)2011 $350 (349)2012 3350 (349)2013 $350 (S49)2014 $350 ($49)2015 3350 (549)2016 3350 (S49)2017 $262 ($37)2018 $175 (525)2019 3175 (S25)2020 $175 (S25)2021 $131 (S18)Non-RIS S9 S9 39 39$9 39$9 39$9 39$9 39$9$9 39 39 37 S4 34 34$3 Total 3309 3309-$309$309 3309$309 3309$309 3309 S309 3309 3309 S309 S309 3309 3309 3232 3155 3155 3155$116 Present Value 53,904 (S548) $98 $3,454 Notes: Present values as of January 1, 2001.All values in thousands of 1998 dollars. Parentheses indicate negative values.Source: NERA calculations as explained in text.S 35 F -15 Table 33. Total Benefits: Seasonal F.R. 45% Delta T Vary Year Recreational RIS Commercial RIS Non-RIS Total 2001 51,138 $260 S20 S1,418 2002 S1,138 $260 S20 51.,418 2003 S1,138 $260 $20 SI.418 2004 $1,138 $260 $20 S1,418 2005 $1,138 5260 $20 51,418 2006 $1,138 S260 $20 51,418 2007 $1,138 $260 $20 SI.418 2008 $1,138 $260 S20 S1,418 2009 $1,138 S260 $20 S1.418 2010 $1,138 $260 $20 $1,418 2011 $1,138 $260 $20 $1,418 2012 $1,138 $260 $20 31,418 2013 $1,138 $260 $20 $1,418 2014 $1,138 $260 $20 $1,418 2015 $1,138 $260 $20 $1,418 2016 $1,138 S260 $20 $1,418 2017 S854 $195 $15 $1,064 2018 $569 $130 310 $709 2019 $569 $130 310 $709 2020 $569 $130 $10 5709 2021 $427 $98 $8 S532 Present Value $12,704 S2,904 $224 $15,832 Notes: Present values as of January 1, 2001.All values in thousands of 1998 dollars. Parentheses indicate negative values.Source: NERA calculations as explained in text.0 36

• F-15 Table 34.Year 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 Total Benefits: Seasonal F.R. 10% Delta T Constant Recreational RIS Commercial RIS 3280 352 5280 S52 5280 $52 S280 $52 3280 $52 3280 352$280 552 S280 S 352 3280 $52$280 352 3280 $52 3280 $52 3280 $52$280 $52 3280 352 5280 .$52$210 339 3140 $26$140 $26$140 $26 S105 S20 Non-RIS S4 34 34 54$4 34 54$4$4$4 34$4$4$4$4$4$3 32 S2

$2 32 Total 3337 5337 3337 3337 3337 5337 3337 3337 3337.3337 3337 3337 3337 3337 S337 3253 3168 3168 3168 3126 Present Value S3;128 $582 348 $3,758 Notes: Present values as of January 1, 2001.All values in thousands of 1998 dollars. Parentheses indicate negative values.Source: NERA calculations as explained in text.37 F -15 Table 35. Total Benefits: Seasonal F.R. 20% Delta T Constant Year Recreational RIS Commercial RIS Non-RIS Total 2001 S682 S201 59 S891 2002 5682 S201 59 5891 2003 5682 S201 S9 S891 2004 5682 5201 59 3891 2005 5682 3201 59 $891 2006 5682 5201 $9 5891 2007 5682 S201 59 5891 2008 5682 5201 S9 5891 2009 5682 S201 S9 5891 2010 S682 5201 59 5891 2011 $682 5201 $9 $891 2012 S682 3201 59 5891 2013 S682 S201 $9 S891 2014 5682 5201 59 5891 2015 S682 $201 $9 $891 2016 5682 $201 $9 5891 2017 S511 5150 S7 5668 2018 $341 $100 S4 S445 2019 5341 S1OO $4 $445 2020 $341 5100 $4 5445 2021 5256 S75 $3 5334 Present Value $7,607 S2,239 $98 $9,944 Notes: Present values as of January 1, 2001.All values in thousands of 1998 dollars. Parentheses indicate negative values.Source: NERA calculations as explained in text.38 F -15 Table 36. Total Benefits: Seasonal F.R. 45% Delta T Constant Year Recreational RIS Commercial RIS Non-RIS Total 2001 S1,684 $575 $20 S2.278 2002 51,684 S575 $20 $2,278 2003 31,684 S575 S20 S2,278 2004 31,684 S575 320 S2.278 2005 $1,684 5575 $20 52.278 2006 $1,684 S575 $20 S2.278 2007 $1,684 5575 $20 S2,278 2008 $1,684 $575 $20 $2,278 2009 $1,684 $575 S20 S2,278 2010 $1,684 S575 $20 $2,278 2011 $1,684 $575 $20 $2,278 2012 $1,684 $575 $20 $2,278 2013 $1,684 $575 $20 S2.278 2014 $1,684 $575 $20 $2,278 2015 $1,684 $575 $20 $2,278 2016 $1,684 $575 $20 $2,278 2017 $1,263 $431 $15 $1,709 2018 $842 $287 $10 51,139 2019 $842 $287 $10 $1,139 2020 $842 $287 $10 $1,139 2021 $631 $215 $8 $854 Present Value $18,791 $6,414 $224 $25,429 Notes: Present values as of January 1, 2001.All values in thousands of 1998 dollars. Parentheses indicate negative values.Source: NERA calculations as explained in text. F -15 Table 37.Year 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 Total Benefits: Natural Draft Towers Recreational RIS Commercial RIS 30 SO so s0 so so so so S2,732 S1,266$4.406 52,041 S4,406 $2.041$4,406 $2,041 S4,406 $2,041$4,406 $2,041 S4,406 52,041 34,406 S2,041$4.406 $2,041 34,406 $2,041 S4.406 32,041 S4.406 S2,041 S3,304 31,531 S2,203 31,021$2,203 51,021 S2,203 S1,021 S1,652 $765 Non-RIS So so so so 3914 S1,475 S1,475 S1,475$1,475 31,475$1,475$1,475 S1,475 31,475$1,475 31,475$1,106$737 S737 3737 S553 Total so SO so so S4.912 57,922 37 922 37,922 37,922$7.922$7,922$7,922 37,922$7,922 S7,922 S7.922 S5,941 S3,961 33,961 33,961 32,971 Present Value 332,236 314,933 $10,789 $57,958 Notes: Present values as of January 1, 2001.All values in thousands of 1998 dollars. Parentheses indicate negative values.Source: NERA calculations as explained in text.4) F -15 Table 38. Total Benefits: Mechanical Draft Towers Year Recreational RIS Commercial RIS Non-RIS Total 2001 s0 so so so 2002 50 s0 s0 s0 2003 s0 so s0 s0 2004 SO SO so so 2005 r2.732 S1,266 5914 S4.912 2006 S4,406 S2,041 S1,475 57,922 2007 S4,406 S2,041 S1,475 37,922 2008 34,406 52,041 31,475 37,922 2009 34,406 32,041 S1,475 S7,922 2010 S4.406 32,041 S1,475 $7,922 2011 34,406 S2,041 S1,475 S7,922 2012 $4,406 32,041 31,475 37,922 2013 34,406 S2,041 31,475 37,922 2014 $4,406 52,041 S1,475 37,922 2015 $4,406 S2,041 31,475 37,922 2016 $4,406 32,041 $1,475 37,922 2017 33,304 S1,531 S,106 S5,941 2018 $2,203 $1,021 3737 S3,961 2019 52.203 $1,021 $737 $3,961 2020 $2,203 31,021 3737 33,961 2021 $1.652 $765 $553 $2,971 Present Value 332,236 5 14,933 $10,789 $57,958 Notes: Present values as of January 1, 2001.All values in thousands of 1998 dollars. Parentheses indicate negative values.Source: NERA calculations as explained in text.41 APPENDIX F ATTACHMENT 16 OTHER ENVIRONMENTAL COSTS A.ND BENEFITS SPONSORED BY: DAVID HARRISON, Jr.NATIONAL ECONOMIC RESEARCH ASSOCIATES PSE&G RENEWAL APPLICATION SALEM GENERATING STATION PERMIT NO. NJ0005622 4 MARCH 1999 ...s&: .-,, TABLE OF CONTENTS I. ENVIRONVMENTAL COSTS OF MR EMISSIONS NOT INCLUDED ....... 2 II. OTHER ENVIRONMENTAL COSTS SPECIFIC TO MODULARIN C LINE D SC R EEN S ................................................................................................. 2 II. OTHER ENVIRONMENTAL COSTS SPECIFIC TO SEASONAL FLO W RED UCTIO NS ................................................................................................. 2 IV. OTHER ENVIRONMENTAL COSTS SPECIFIC TO CLOSED CYCLE CO O LING TO W ER ..................................................................................................... 2 ENDNOTES ........................................................................................................... 4 S PSE&ýG P?..: Aamro ATTACHMENT F-16 OTHER ENVIRONMENTAL COSTS AND BENEFITS Section LX evaluates the costs and benefits that would be produced by the implementation of fish protection alternatives at Salem. These costs and benefits include the value of environmental changes, such as changes to the fisheries catch and changes in air emissions. However, there are other environmental changes that are not quantified. This attachment describes the environmental costs and benefits of alternatives that are not quantified in Section IX. F-16 Table I lists other environmental costs and benefits as well as a qualitative evaluation of the net effect of these costs and benefits for fish protection altematives.Additional details on environmental costs are provided in Section VyiI.I. ENVIRONMENTAL COSTS OF AIR EMISSIONS NOT INCLUDED The benefit estimates in Section IX include consideration of the value of increases in three air emissions (C0 2 , SO 2 , and NOx) that would result from reduced power at Salem.Pollutants other than these three also would be emitted if other facilities were to increase generation. For example, power generated at facilities other than Salem could cause an increase in particulate or mercury emissions.Because the costs of these other emissions are not considered, the cost estimates in this study are understated. II. OTHER ENVIRONMENTAL COSTS SPECIFIC TO MODULAR INCLINED SCREENS Installation of the modular inclined screens and the dual-flow fine mesh screens would require dredging the area in front of the intake system and disposal of the dredged material. Dredging disrupts the immediate ecosystem, producing potential damages to aquatic life. Dredged material may contain contaminants, such as heavy metals, thatwould produce potential groundwater impacts and require costly disposal.III. OTHER ENVIRONMENTAL COSTS SPECIFIC TO SEASONAL FLOW REDUCTIONS Seasonal flow reductions would lead to additional power at other facilities to offset the power losses at Salem. Since the generating facilities producing replacement power may also utilize water intake systems, fish losses may increase at these other facilities.' Seasonal flow reductions would therefore shift some of the fish losses from Salem to another facility. These effects are not included in the analysis.IV. OTHER ENVIRONMENTAL COSTS SPECIFIC TO CLOSED CYCLE COOLING TOWER Both closed cycle cooling tower alternatives-the natural draft and mechanical draft cooling towers-would produce several additional environmental costs. First, the tower alternatives would lead to additional power to offset the energy losses from construction and changes in continuing operations. Since the generating facilities producing additional power may also utilize water intake systems, fish losses may increase at these other facilities. Closed cycle cooling would therefore shift some of the fish losses from the Salem facility to another facility. Second, once constructed, the towers would reduce 2 0 ?SES&r ?c=,'m:: .~oe~.i\ F local wildlife habitat. Third, the towers would produce noise and other aesthetic impacts.These effects are not included in the analysis.3 I .A ENDNOTES Other altematives also require replacement power and Lhus may lead to potential increase in impingement and entrainment losses at other sites. The quantity of repiacement power from othera!ternatives, however, is small enough that the magnitude of these impacts is not significant. 4 FORE\VORD This Appendix is one part of a larger submission by Public Service Electric and Gas Company (PSE&G) to the New Jersey Department of Environmental Protection (NJDEP). The submittal is in support of the renewal of the New Jersey Pollutant Discharge Elimination System (NJPDES) Permit for the Salem Generating Station (Station). The relationships amongst the several parts of the submittal are shown in the attached figure. The present Appendix is highlighted. The submittal is built on seven Appendices (A, B, C, D, 1, J, L) that provide the legal, regulatory, and factual basis for the Demonstrations. Three Demonstrations make up the bulk of the filing: the 316(a) Demonstration assessing the thermal discharge. the 316(b) Demonstration assessing the effects of Salem's cooling water intake, and the Demonstration of Compliance with the 1994 Permit. The Cumulative Effects Analysis assesses the potential for impacts on the indigenous community of the Delaware Estuary related to all stresses from the Station.S Memoranduminn" -Supp if PSE& G s Request for RenewoaI!,:M em orandum :!n S u:.pport , ....~~~~~~. :. ..:. *..... .:, .. APlCTO DEMONSTRATIONS

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App~ix Ei~ jij ~ Appen dix F-----------------" --Compliance AppenidixG(Cumnultive .fflcts SUPPORT APPFtND]ICES I -.. .. ....... --,- --1 .......... ....................... ....- .... ...

d N, A satylsV Opernti4o~us A pLmdi -, U oCirefrthe i Ajppumdix re1nd# ,7{{ ...,"k<>>KPk-e& ~kn(U cp~n~nd~Apji~idL I-----------------

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0 APPENDIX G PSE&G'S COMPLIANCE WITH THE SPECIAL CONDITIONS OF THE 1994 PERMIT IS PROVIDING AND WILL PROVIDE SUBSTANTIAL BENEFITS PSE&G PSE&G RENEWAL APPLICATION SALEM GENERATING STATION PERMIT NO. NJ0005622 4 MARCH 1999 s APPENDIX G PSE&G'S COMPLIANCE WITH THE SPECIAL CONDITIONS OF THE 1994 PERMIT IS PROVIDING AND WILL PROVIDE SUBSTANTIAL BENEFITS 0 PSE&G Reneal Appiwcarn~ -1 Nlarch NPQ Appendix G TABLE OF CONTENTS I. IN T R O D U C T IO N ................................................................................................ ..7 II. PSE&G HAS COMPLIED WITH THE SPECIAL CONDITIONS OF THE PERMIT RELATED TO SECTION 316 OF THE CLEAN WATER ACT ............................... 8 II.A .W etlands Restoration and Enhancem ent. .............................................................. 8 II.B. Elimination of Impediments to Fish Migration ................................................ 9II.C .M odification of the Intake Screens ..................................................................... 11II.D .Sound Deterrent Feasibility Study ................................................................. 12 II.E .B iological M onitoring .................................................................................. 13 III. PSE&G'S FULFILLMENT OF THE SPECIAL CONDITIONS IN THE PERMIT HAS SUBSTANTIALLY BENEFITED THE FISH, SHELLFISH, AND WILDLIFE OF THE DELAWARE ESTUARY, AS WELL AS THE PEOPLE OF THE REGION ........ 14 III.A. The Restored Marshes Are On a Trajectory to Ultimate Success, Already Producing Substantial Quantities of Aquatic Biota and Providing Food and Habitat to Birds and O ther W ildlife ...................................................................................... 15 III.A. I. W etland Restoration Program ............................................................. 15 III.A .2. Status of Restoration ................................................................................. 20 III.A .3. M arsh Productivity ............................................................................. 23 III.A.4. Phragmites-Dominated Marshes ........................................................... 32 III.A.5. Benefits of Marsh Restoration to Other Wildlife .................................. 34 III.A.6. Human Benefits From Marsh Restoration. ........................................... 36 III.B. Fish Ladders Will Promote Spawning Runs of River Herring, Providing Both Forage Fish in the Fall and Adult Herring Fishing Thereafter ................................ 36 III.C. The Modification of the Traveling Screens Has Reduced Fish Mortality from Im pingem ent at Salem .......................................................................................... 39 III.D. The Sound Deterrent Study Has Advanced Knowledge, Producing Unexpected Results Which Would Require Replication Before Application ............................. 40 III.E. The Biological Monitoring Program Has Resulted in Advances in Scientific Knowledge and In Practical Knowledge Valuable for Natural Resource Management4l III.F. Benefits of Delaware's Construction of Artificial Reefs and Restoration of the Augustine Creek Impoundment ........................................................................... 43 IV. CONCLUSION: PSE&G HAS COMPLIED WITH THE SPECIAL CONDITIONS OF THE PERMIT WHICH HAVE BROUGHT SIGNIFICANT BENEFITS TO THE DELAW ARE ESTUARY ......................................................................................... 45 E N D N O T E S .................................................................................................................. 47 S PSE&.G Renc.,al *\~pih:,:wn Nlar~h )Q Appendix G LIST OF FIGURES Number G Figure 1 G Figure 2 G Figure 3 G Figure 4 G Figure 5 G Figure 6 G Figure 7 G Figure 8 G Figure 9 G Figure 10 G Figure 11 G Figure 12 G Figure 13 Description General Site Location Map.1951 Phragmites Coverage at Alloway Creek Wetland Restoration Site.1962 Phragmites Coverage at Alloway Creek Wetland Restoration Site.1972 Phragmites Coverage at Alloway Creek Wetland Restoration Site.1996 Phragmites Coverage at Alloway Creek Wetland Restoration Site.1996 Hydrologic Features at Maurice River Township Salt Hay Farm Wetland Restoration Site.1998 Hydrologic Features at Maurice River Township Salt Hay Farm Wetland Restoration Site.Restoration Success at the Dennis Township Site. Benthic Algae and Sparrina Seedlings. Restoration Success at the Dennis Township Site. Vigorous Spartina Growth.Dennis Township Vegetation Cover 1995-1998. 1996 Hydrologic Features at Mill Creek Area of the Alloway Creek Watershed Wetland Restoration Site.1998 Hydrologic Features at Mill Creek Area of the Alloway Creek Watershed Wetland Restoration Site.1998 Vegetation Features at Alloway Creek Watershed Wetland Restoration Site -Mill Creek Area.2 PSE&G RenceAd Applicaufl 4 \1~rch '4N A.Ppendix G LIST OF ATTACHMENTS AND EXHIBITS S Attachment G-1 Exhibit G- 1 -I Exhibit G- 1-2 Attachment G-2 Exhibit G-2-1 Exhibit G-2-2 Exhibit G-2-3 Exhibit G-2-4 Exhibit G-2-5 Exhibit G-2-6 Exhibit G-2-7 Exhibit G-2-8 Exhibit G-2-9 Exhibit G-2-10 Part I Exhibit G-2-10 Part II Exhibit G-2-10 Part III Exhibit G-2-11-Exhibit G-2-12 Exhibit G-2-13 Traveling Water Intake Screen Modifications Improvements to Salem Generating Station's Traveling Water Screens Biological Efficacy of Intake Strucure Modifications Wetlands Restoration Success Land Selection, Acquisition, and Preservation Program Reference Marsh: Background for Selection and Use Restoration of Normal Daily Tidal Inundation at PSE&G's Wetlands Restoration Sites Vascular Plants and Algal Production Monitoring and Geomorphological Monitoring Preservation and Management of the Bayside Tract and Upland Buffers Benefits the Delaware Estuary Common Reed (Phragmites australis): The Plant and Its Relationships Residual Pesticide Monitoring at PSE&G's Salt Hay Farm Restoration Sites Assessment of Offsite Flooding Effects Associated with Wetland Restoration Activities Groundwater Response to Wetland Restoration Activities PSE&G's Spray and Burn Program for the Control of Phragmites Toxicological Hazard and Risk Assessment of Glyphosate in Association with Marsh Restoration in the Delaware River Estuary Ecological Risk Assessment of the Use of Glyphosate for the PSE&G Wetland Restoration Program Assessment of Potential Effects of PSE&G's Wetland Restoration and Upland Buffer Preservation Activities on Threatened and Endangered Species Potential Effects of Diked Salt Hay Farm Restoration on Horseshoe Crabs Enhancement Benefits to Waterfowl, Shorebirds, and Other Wildlife of the Delaware Bayshore Region 3 .Appendix G Exhibit G-2-14 Exhibit G 15 Exhibit G-2-16 Exhibit G-2-17 Exhibit G-2-18 Attachment G-3 Exhibit G-3-1 Exhibit G-3-2 Exhibit G-3-3 Exhibit G-3-4 Exhibit G-3-5 Exhibit G-3-6 Exhibit G-3-7Exhibit G-3-8 Exhibit G-3-9 Exhibit G-3-10 Exhibit G-3-11 Exhibit G-3-12 Human Access-Related Benefits Associated with theWetlands Restoration Reserved Reserved Phragmites Migration Delaware Estuary Marsh Communities and an Overview of Wetlands Restoration Evaluation of Faunal Response to Marsh Restoration: A Synthesis Evaluating Salt Marsh Restoration in Delaware Bay: Summary of Three Years of Fish Utilization Monitoring Evaluating Salt Marsh Restoration in Delaware Bay: Summary of Two Years of Food Habits Monitoring Distribution, Abundance, and Food Habits of Large Predatory Fishes: Comparisons between Restored and Reference Marshes Utilization of Reference and Restored Tidal Creeks by Young-of-the-Year Atlantic Croaker, Micropogonias Undulatus, as Demonstrated by Mark-and-Recapture Techniques Utilization of Tidal Creeks by a Large Predatory Fish as Demonstrated by Ultrasonic Tracking: Comparison of a Restored and a Reference Marsh Response of Killifishes. to Marsh Restoration in Delaware Bay Comparison of Distribution and Feeding Ecology of Young-of-the-Year Fundulus heteroclitus Between a Restored Salt Hay Farm and a Reference Salt Marsh Relative Importance of Benthic Microalgae, Phytoplankton, and the Detritus of Smooth Cordgrass (Spartina) and the Common Reed (Phragmites) to Brackish Marsh Food Webs Occurrence of Small Pelagic Fishes in Tidal Creeks at the Dennis Township Salt Hay Farm Restoration Site The Response of Blue Crabs, Callinecties sapidus, to Salt-Marsh Restoration in Delaware Bay Spatial Variation in Delaware Bay (U.S.A.) Marsh Creek Fish Assemblages Fish Studies in the Delaware Bay and Adjacent Marshes: Literature 4 PSE&G R~ne,"ýl A\nplic2:lin .4 Mlarch I~QQ-Appendix G Exhibit G-3-13 Exhibit G-3-14 Exhibit G-3-15 Exhibit G-3-16 Exhibit G-3-17 Preliminary Analysis of Effects of Reed Grass (Phragmites australis) Invasion on Marsh Surface Macrofauna: Response of Fishes Stable Isotope and RNA-DNA Analysis of JuvenileFishes from Open Water and Tidal Marsh Habitats of Delaware Bay Reserved Reserved Aspects of the Distribution and Life History for Selected Species in Delaware Bay Occurrence of Neomysis Americana in Tidal Creeks at Dennis Township Salt Hay Farm Wetland Restoration Site Bioenergetics Modeling of Restored and Reference Wetland SitesExhibit G-3-18 Attachment G-4 Attachment G-5 Exhibit G-5-1 Exhibit G-5-2 Exhibit G-5-3 Exhibit G-5-4 Exhibit G-5-5 Exhibit G-5-6 Exhibit G-5-7 Attachment G-6 Attachment G-7 Exhibit G-7-1 Exhibit G-7-2 Exhibit G-7-3 Exhibit G-7-4 Fish Ladders Provide Increased Production in the Delaware Estuary Fisheries Site Characterizations and Selection Process Fish Ladder Design/As-Built Drawings Ladder Operation and MaintenanceFish Ladder Monitoring 1998 Fish Ladder Stocking Juvenile Herring Emigration at PSE&G Fish Ladder Sites Fish Ladder Site Photograph Bioenergetics Modeling Of Sites Where Fish Ladders Have Been Installed Feasibility Study on the Use of Sound to Deter Fishfrom the Vicinity of the Salem Generating Station Circulating Water Intake Structure Study Chronology Report on 1994 Cage Tests Report on 1998 Supplemental Cage Tests Report on Sound Field Mapping 5 S PSE&G Rene~jl kApritcution 4 Mairch 1)L)L)A\ppendix G 0 Exhibit G-7-5 Attachment G-8 Exhibit G-8-1 Attachment u-9 Exhibit G-9-1 Exhibit G-9-2 Report on 1998 In Situ Tests Benefits of PSE&G's Monitoring Programs Biological Monitoring Program Work Plan Other Estuarine Improvements: Artificial Reefs and Restoration of Augustine Creek Impoundment Artificial Reefs Increase Fisheries Production in the Delaware Estuary Restoration of Augustine Creek 6 PSE&G R.nc,.j.l Apphicitio'rt MaI~rch I'1Q9.Appendix G I. INTRODUCTION This Appendix addresses two broad issues. First. we will show that Public Service Electric &Gas Company (PSE&G) has complied with the Special Conditions of the 1994 New Jersey Pollution Discharge Elimination System (NJPDES) Permit that addressed: a)conservation measures in the Delaware Estuary; in particular. the restoration and preservation of tidal marshes and the construction of fish ladders on tributaries to the estuary; b) the Salem Generating Station's (Salem of the Station) cooling water intake structure; and c) biological monitoring. Second. we will show the benefits to the environment and people of the Delaware Estuary that have flowed, and will continue to flow, from the actions PSE&G has taken. At the center of these benefits is the enhanced production of fish on the Delaware, but the benefits are greater than enhancing the production of aquatic biota. They include benefits to birds that use salt marshes and upland buffers for refuge and to obtain food; to terrestrial mammals who make use of the marsh; and to people who can use the protected resources and enjoy new opportunities provided by the marshes and the reinvigorated ponds and lakes that are now open to migrating fish. The local economy has expanded through new opportunities for tourism and recreation. Finally, and importantly, PSE&G's program has brought advances and contributions to the knowledge and science of aquatic biology and the management of natural resources in an estuary. These benefits will remain long after Salem has ceased to operate. They surpass any detrimental effects on aquatic biota in the estuary that may be claimed to occur from Salem by those who oppose the renewal of the Salem Permit.The Special Conditions of the 1994 Permit that are related to the central requirement of Section 316 of the Clean Water Act -the maintenance of a balanced, indigenous population of aquatic biota in the Delaware' -may be grouped under three heads: (1) actions to be taken in the estuary that are likely in the long term to enhance the populations of aquatic species in the estuary; (2) actions at and analyses of the physical conditions at the intake to Salem that could reduce the cropping of aquatic biota through entrainment or impingement at the plant; and (3) the collection and analysis of data with a number of objectives -relating plant operations to changes in the aquatic populations of the Delaware and, where relevant, to the species of the Atlantic Coast; evaluating the performance of the restored tidal marshes and the reopened impoundments on the tributaries; generally tracing the relationships of the aquatic biota of the Delaware to their habitat and food supplies, to the large scale changes in pollution discharges in the estuary, to fishery management on the coast, and to large scale human intrusions into the physical conditions of the estuary; and ultimately developing knowledge and understanding that can support and promote more effective management of the resources of the Delaware Estuary.2 The Special Conditions to the Permit are reproduced as a supplement to this Appendix for the convenience of the reader.Following issuance of the Permit in 1994, the Delaware Department of Natural Resources and Environmental Control (DNREC) challenged the terms of the Permit. PSE&G entered into a settlement agreement that resolved that challenge. PSE&G's obligations

• 7 PSE&G Rcner, A -.n\ YLrcn I4qM A ppendix G under the settlement agreement are in addition to and distinct from its obhigations under the NJDEP Permit. Nevertheless the tern-Ls of the settlement agreement were primarily addressed to protection or enhancement of aquatic biota and are thus closely related to the topics addressed in this Appendix.

Consequently we summarize the terms of the settlement in the Supplement to the Appendix and, where appropriate, will touch on them further in the course of this Appendix.II. PSE&G HAS COMPLIED WITH THE SPECIAL CONDITIONS OF THE PERMIT RELATED TO SECTION 316 OF THE CLEAN WATER ACT II.A. Wetlands Restoration and Enhancement Clearly, the most complex, demanding and large-scale action required by the Special Conditions to the Permit was the restoration, enhancement, and/or preservation of at least 10,000 acres of degraded wetlands and upland buffers along the Delaware Estuary.Under the terms of the Permit, PSE&G was to obtain ownership and control of 10,000 acres of these lands; assure the continued protection of the lands from development; and through Management Plans, developed with input from the Management Plan Advisory Committee (MPAC) and the public and approved by NJDEP, restore normal daily tidal inundation to the diked wetlands to recolonize the marsh with desirable, naturally occurring marsh grasses and control the Phragmites from the marshes they dominate to allow re-vegetation by desirable, naturally occurring marsh grasses.Eighty percent of the marsh lands were to be in New Jersey; at least 4,000 acres of them were to be diked salt hay farms; and, recognizing the essential and mutually enhancing relationship of the marshes to adjacent uplands, up to 6,000 acres of upland buffers could be preserved and counted toward the 10,000 acres on a 3 to 1 basis. Finally, the Bayside Tract was to be preserved as open land, preserving 2,585 acres of tidal marsh, with 1,822 acres upland acres counting as upland buffers, contributing to the 10,000 acres on the same 3 to I basis.PSE&G has complied fully with the wetland restoration requirements. In particular, PSE&G has acquired approximately 20,500 acres of land, restored and preserved 12,459 acres of degraded wetlands, and preserved an additional 2,649 acres of upland buffer in New Jersey (of which 1,822 acres are contributed by the Bayside Tract). The wetlands restored include 4,398 acres of restorable diked wetlands, 3,723 acres of restorable Phragmites-dorninated wetlands in New Jersey, 4,338 acres of restorable Phragmites-dominated wetlands in Delaware (of which 2,000 acres will be applied to the Permit requirements). The total acres of wetlands and upland buffers (converted at 3:1 ratio pursuant to the terms of the Permit) are 11,004. (G Figure 1) Restoration, enhancement, and preservation, as appropriate, have been implemented in accordance with the site-specific Management Plans approved by NJDEP. Further, an additional 1,452 acres of impounded marsh, undisturbed wetlands, and upland buffer have been acquired in Delaware in satisfaction of the terms of the settlement agreement with DNREC.*8 PSE&,G A.phý-"Ewn Nia .rcn 11N'Appendix G PSE&G first acquired available diked salt hay farms in New Jersey. Then. PSE&Gdeveloped a systematic approach to identify, evaluate. select. secure, and preserve additional suitable wetland restoration sites (Exhibit G-2-1). This land selection process was conducted within a rigorous scientific and engineering framework that focused on the ability to restore the sites. To ensure that conditions favorable for restoration were present. appropriate experts. including aquatic ecologists, wetland scientists, biologists, hydrologists, and coastal process experts, worked closely with PSE&G staff to evaluate the candidate sites. PSE&G selected five sites for restoration in New Jersey and, in consultation with DNREC, five sites in Delaware (G Figure 1). These sites were identified, evaluated, acquired, and preserved while satisfying the ambitious schedule set forth in the Permit.The New Jersey sites include three previously diked salt hay farms, located in Commercial, Dennis and Maurice River Townships, and two areas, the Alloway Creek Watershed and the Cohansey River Watershed, that, prior to restoration, were dominated by Phragmites. The Delaware sites are five Phragmites-dorminated sites: Cedar Swamp, Lang Tract, The Rocks, Silver Run, and Woodland Beach. All five sites had been previously identified and evaluated by PSE&G as suitable candidates for restoration. Once these restoration sites were acquired, or control otherwise secured, it was necessary, in compliance with the Permit, to guarantee that the sites would be preserved in an undeveloped state. For the New Jersey sites, Deeds of Conservation Restriction (DCR) in favor of New Jersey were established for each site acquired by PSE&G, as well as for the privately owned lots that were not acquired but were included within restoration or uplandbuffer areas. For restoration lands owned by New Jersey, DCRs were not necessary since state statutory restrictions for long-term preservation already exist. For sites in Delaware, Declaration of Restrictions and Covenants in favor of New Jersey have been recorded.For each of the restoration sites, a conceptual design was developed and incorporated into a Management Plan. The plans were developed with the advice and review of the MPAC.The details of the marsh restoration program are set out in Attachment G-2.In sum, PSE&G has complied with the wetland restoration requirements in the Permid II.B. Elimination of Impediments to Fish MigrationThe Permit required PSE&G to build five fish ladders to restore river herring runs that had been impeded by the construction of dams and other barriers over the last 100 years.River herring are important prey for weakfish, striped bass and other predators as they migrate through the estuary in the fall and in the spring. There are two species of river herring, ailewife-and blueback herring, which spawn in small tributaries of the Delaware in the spring. Juvenile herring migrate down the tributaries in the late fall and early winter.After spending three to five years in coastal waters, the adult herring return to the fresh water tributaries to spawn. For many years dams on many of the tributaries have blocked 9 PSE&G Rcnc jil .Pphtic on 4 March I1999 AppcndN G the herring from reaching their natal spawning grounds. Fish ladders are a well-established technology that allows the herring spawning runs to resume and should increase the production of river herring.In carrying out the Permit terms to construct five fish ladders, PSE&G followed a careful and thorough process of site selection, evaluation of engineering feasibility; obtaining legal rights necessary to install and maintain the ladders- and construction of the ladders. This program was carried out in concert with NJDEP and the U.S. Fish and Wildlife Service (USFWS), This process is fully described in Attachment G-5.The careful and thorough site selection and evaluation process led to the selection of eight locations for the installation of ladders (substitutions were made from the original list as problems such as dam safety became apparent later in the process). The selected sites were approved by NJDEP. PSE&G has installed fish ladders at the following sites:* Sunset Lake: on the Cohansey River in Bridgeton, NJ; the lake has an impounded area of 94 acres;* Cooper River-Kaighn Avenue Dam: at west end of Cooper River Park between Camden and Pennsauken, NJ; there is an impounded area of 190 acres behind the dam;" Silver Lake: approximately 13 miles from where the St. Jones River enters Delaware Bay; the surface area of the lake is 171 acres;" McGinnis Pond: located on the headwaters of the Murderkill River near Frederica, DE;the pond is approximately 31.3 acres;* McColley Pond: approximately 49 acres and located on the headwaters of the Murderkill River; and" Coursey's Pond: The surface area of the pond is 58 acres and is located on the Murderkill River in Kent County, DE.Fish ladders will also be installed at two additional sites in Delaware before the 1999 spawning run: " Garrisons Lake: located on the Leipsic River; the lake is 85.9 acres; and" Moores Lake: located on the Isaac Branch of the St. Jones River; the lake is approximately 27 acres.In addition, the USFWS will install two additional fish ladders in New Jersey with assistance from PSE&G at Wallworth Lake and Evans Pond. Both impoundments are located on the Cooper River between Cherry Hill and Haddonfield, NJ. The surface area 10 PSE&G Renc',,l Application 4 March 1990 Apprndix G of Walworth Lake is two acres; the Evans Pond dam is approximately 500 ft upstream of the Wallworth Lake dam, and the surface area of the pond is 25 acres.Once construction is complete. the Permit requires PSE&G to conduct operation and maintenance activities at the fish ladders for the term of the Permit and any period for which it is extended. PSE&G has performed these obligations at each of the ladders since the first became operational in 1996.Thus PSE&G has complied with each of the Permit conditions related to elminating impediments to fish migration' I.C. Modification of the Intake Screens Special Condition H.2 of the Permit required installation of a number of advances in traveling screen and fish return design: equipping the fish buckets with an extended, inward bending lip to prevent fish escape and control turbulence in the bucket; installing a smooth woven mesh that should reduce abrasion and de-scaling of the fish; reconfiguring the fish and debris spray nozzles; and providing a fish return system of a width (30 inches)and water depth (approximately 3 inches) that would increase the likelihood of fish survival. Finally, the installation of the improvements was to be done in stages, one unit at a time, with an operability test following installation at the first unit, so that the system could be adjusted and fine-tuned. Following this, the final modifications designed into the upgrade of the screens would be installed at the second unit and retrofitted to the first unit that had been modified.PSE&G installed the required screen modifications in a timely fashion. As explained in Attachment G-1 and Exhibit G-1-1, PSE&G installed Envirex Non-Metallic Fish Assemblies containing the following features: " panel frames constructed from engineered composite materials that provide corrosion resistance, weight reduction, and an enhanced frame shape;" a bucket with a reshaped lower lip profile that includes a flow spoiler at its top to provide a protected environment for fish during the ascending mode of the traveling screen operation;" Smooth-Tex" wire mesh that provides a smooth surface for fish to slide gently to the fish return trough;" mounting of the mesh hardware is configured behind the smooth mesh surface, reducing the debris carryover and increasing the ease of debris and organism removal by the sprays; PSE&G Rene:,za Apphlation M atdrch 19Q4 Appendix G" a new weave pattern in the screen mesh that allows the use of thinner wire that reducesthrough-screen velocity: " improved location of fish spray nozzles to keep the surfaces of the screen mesh wet for enhanced fish removal and transfer to the fish return trough; and* improved spray nozzle location for more effective removal of fish and debris from the baskets.In addition, in light of experience at the Indian Point plant on the Hudson, a concern wasraised regarding fish entanglement, which occurs when fish being returned to the water body become entangled with the detritus and debris from the screen wash. PSE&G performed a special study early in 1995 to see if fish in the return trough were entangled in detritus. PSE&G also videotaped the actual transfer of fish from the traveling screen panels to the return trough during the spring of 1996. No fish were observed to experience entanglement with the type of detritus found in the Delaware River. No modifications were necessary to the dimensions of the fish troughs, which already met the requirements of the Permit.PSE&G first installed the screen modifications on Unit 2. Upon completion of the modifications, the prescribed operability tests were conducted. The only resulting change to the original modification at Unit 2 was the replacement of the screen drive motors to enhance the reliability of the system. PSE&G completed the modification of the intakescreens within the time allowed by the Permit 6 H.D. Sound Deterrent Feasibility Study The Permit required PSE&G to undertake a study of the feasibility of using sound at Salem as a deterrent and to assess its possible adverse effects. This work was to follow a Plan of Study approved by NJDEP (Exhibit G-7-1) and was to be completed and submitted to the agency four and a half years after the effective date of the Permit.PSE&G has satisfied the Permit conditions related to the sound deterrence studies. The details of PSE&G's studies are set out in Attachment G-7 and its related Exhibits. As explained in Attachment G-7, PSE&G submitted to NJDEP its original Plan of Study in 1994. A modified plan was submitted to NJDEP on October 6, 1995 and was approved by NJDEP on April 6, 1996.PSE&G's 1994 sound deterrent feasibility studies were conducted using the nine Salem Representative Important Species (RIS) (Exhibit G-7-2). Two series of cage tests were performed to identify sounds that would potentially be effective in repelling fish from the intake during subsequent in situ tests. Salem was not operating at full power in 1996 and 1997, with the consequence that in situ sound deterrent tests did not take place until 1998 and could only be conducted through one season.12 PSE&G R-nca, Apphicacon -1 Marchi 1l)QG On the recommendation of Arthur N. Popper. Ph.D.. an expert in fish hearing. PSE&G determined that supplemental cage testing would be appropriate before performing the in situ tests so that acoustic signals could be refined to optimize fish deterrence. A revised Plan of Study incorporating the supplemental studies was submitted to NJDEP on June 8.1998 and approved on June 24. 1998. Following conclusion of the 1998 cage tests (Exhibit G-7-3). PSE&G conducted the in situ tests, in which two sounds were used, one for American shad and the river herring and the other for the remaining RIS at Salem (Exhibit G-7-5). Testing was conducted in the summer and fall. The summer tests showed some reductions in impingement for a few species. The fall tests showed several statistically significant changes in impingement. Bay anchovy had a reduction that was significant in all three statistical analyses performed. Atlantic silversides showed a statistically significant reduction in impingement in two of the three statistical tests performed. There was also a statistically significant reduction in impingement of blueback herring. The only other statistically significant change in the fall was for blue crab, where the impingement increased with the sound on.Several studies were conducted to assess whether the sounds used at the Salem intake could have an adverse impact on fish. These included sound field mapping to determine whether sound could potentially have an adverse effect on migratory patterns of fish in the estuary and a study of possible damage to eggs and larvae by sound. The results from the two studies, combined with data in the literature on the effects of sound on fish, strongly suggest that the sound levels used in the intake tests are not likely to cause any temporary or permanent damage to any vertebrate biota around Salem (Exhibits G-7-2, G-7-4).Attachment G-7 and its associated Exhibits constitute the report on the results of PSE&G's sound deterrent studies required by the Permit.II.E. Biological Monitoring The biological monitoring required under the Permit is related to different elements of the company's programs, many of which are discussed in other Appendices to this Permit renewal application in relation to the subject matter to which they are addressed. PSE&G submitted the required Biological Monitoring Work Plan (BMWP) to NJDEP in a timely manner.7 The BMWP involves several different aspects of estuary monitoring, including detritus production, residual pesticide releases, fish habitat utilization and food habits of fish utilizing restored wetlands, and thermal effects, including analysis of the plume and biological effects. In addition, PSE&G conducted an annual survey of the geomorphology and algal productivity at all marsh restoration sites.PSE&G has submitted to the MAC and NJDEP Annual Reports summarizing the monitoring results conducted pursuant to the BMWP. These reports have been submitted for 1996 and 1997, and the 1998 Annual Report is in preparation. 1 13 PSE&G Aph-t\ ý:ler 4 \March lqq.Appendi\ G PSE&G has complied with its biological monitoring obligations under the Permit to date (Attachment G-8).III. PSE&G'S FULFILLMENT OF THE SPECIAL CONDITIONS IN THE PERMIT HAS SUBSTANTIALLY BENEFITED THE FISH, SHELLFISH, ANDWILDLIFE OF THE DELAWARE ESTUARY, AS WELL AS THE PEOPLE OF THE REGION The wide array of benefits that have already been achieved and will continue to flow in the future from PSE&G's fulfillment of the Special Conditions of the 1994 Permit are manifest and justify the renewal of the Permit.These benefits must be considered under at least five separate heads. The first is the most obvious: are PSE&G's actions likely to meet the expectations at the time of Permit issuance? For example, will the restoration of tidal marshes enhance the aquatic populations of the Delaware Estuary or are the fish ladders likely to promote an increase in the abundance of fiver herring for forage and fishery purposes? We will show that the answers to these questions are clearly in the affirmative. Second, weight should be given to the time scale on which many of these benefits will be available. For instance, ecological benefits that flow from marsh restoration are likely to long outlast the period of plant operation. At least at the scale of a human lifetime, these benefits are permanent, while any arguable impact from plant operation is transient.Third, there are numerous ecological benefits which flow from the fulfillment of the Special Conditions that are not captured by focusing on the expectations at the time of Permit issuance. The enhancement of bird life through marsh restoration contributes substantial ecological value not directly related to fish production. For instance, about 30 species of shorebirds represent a resource of global significance for the Delaware Estuary.The estuary is critical to shorebirds in their spring and fall migrations and many species -short-billed dowitcher, greater and lesser yellowlegs, least and semipalmated sandpiper, black-billed plover, and dunlin -feed on invertebrates in the marshes. Similar benefits flow to the biota, from turtles to butterflies, that use the upland edge of the wetlands that PSE&G's holistic approach to the marsh restoration has secured and preserved as part of the marsh ecosystem. Fourth, one should not forget that the benefits of these programs are often more thanecological. Pointing out the economic benefits to southern New Jersey resulting from the marsh restoration may seem mundane next to the almost lyrical excitement one carriesaway from understanding the magnitude, biological intricacies, and robust vitality of the restored marshes, but the local economic gain is likely to occur. Knowledge and educationi have- also benefited from these programs. Our understanding of marsh functioning, based on hard data has materially advanced through the monitoring and special studies PSE&G has carried out. The programs have produced chance discoveries and have posed scientific riddles that will lure researchers to further work, such as the 14 PSE&G R.nejal Applic.aion-t A'ppcndiý G apparent reciprocity between the spot and Atlantic croaker populations in the estuary, with the years of high abundance of one species coinciding with low abundance of the other. At the local and immediate level, the marshes are feeding our future: at Cohansey River, the Fairfield School has been involved with the development of a nature trail with outdoor classrooms; a Greenwich teacher has developed a children's guide book to the resources of the Bayside Tract. The Nature Conservancy has hosted school visits at Maurice River. The marshes will bring the teaching of science alive; they should also be a seed bed for the child's imagination. Finally, the whole spectrum of benefits that have resulted and will continue to result from PSE&G's programs needs to be placed in the balance in reaching a judgment on the ultimate question posed by the NJDEP at Permit renewal: given the terms of the Permit, both plant operation and Special Conditions, will PSE&G have done its part to maintain the balanced, indigenous population of aquatic species in the Delaware Estuary?Answering this question, of course, requires a review of plant operation and its effect, if any, on the populations of aquatic biota in the estuary. That lies beyond the scope of this Appendix, but the benefits discussed in the remainder of this Appendix are significant weights in striking the final balance, often providing benefits whether to the varied array of fish that live in the estuary or to the school child learning the life of the marsh that will liveon long after Salem has ceased to operate. In addressing the benefits generated by the Special Conditions, we will take the conditions in turn for ease of understanding. III.A. The Restored Marshes Are On a Trajectory to Ultimate Success, Already Producing Substantial Quantities of Aquatic Biota and Providing Food and Habitat to Birds and Other Wildlife III.A.1. Wetland Restoration Program III.A.l.a. Context of Wetlands Restoration Program PSE&G has complied with the wetland restoration Permit terms by designing and articulating a program that recognizes the complexity of the life forces and natural phenomena that converge in a fully functioning and productive tidal marsh. The restoration program also sought to achieve a wide range of valuable benefits, both in the marsh and in the surrounding ecosystem. The wetland restoration was designed around the core understanding of the biological habitat and energy flows within the marsh ecosystem. Estuarine wetlands provide habitat for many kinds of fish and shellfish, and make important contributions to the food webs of the coastal ecosystem. A "food web" is the pattern of. relationships among organisms that eat and are eaten in the ecosystem. Green plants- such as marsh algae and grasses, trap energy from sunlight and produce plant tissues (biomass). This biomass in turn supports the fish, shellfish, and other organisms of the coastal ecosystem.

• 15 PSE&G Rene.'., Apphc:ton Appendix G The loss of wetlands through conversion for human use has had a substantial impact on these relationships.

The Dutch were among the first European settlers in southern New Jersey. and, from colonial times, tidal marshes on Delaware Bay were diked to allow the growing and harvesting of salt hay. Human alteration of the wetlands has continued from that time in many forms: diking to keep water out to prevent flooding and to keep water in, to attract waterfowl, or for agricultural purposes; ditching for mosquito control; and filling, both for development of the resulting fastland and for disposal of material dredged for navigational and other purposes. From 1953 to 1975, New Jersey lost 25 percent of its tidal wetlands, the vast majority in counties bordering the Delaware Estuary. This was in addition to earlier losses when much of the agricultural and industrial development and urbanization of the coastline had occurred. Dikes isolate the wetland from tidal exchange, drastically changing the wetland ecosystem in the diked area and reducing or eliminating the contribution of the wetland to estuarine and coastal food webs.Invasion by Phragmites australis (Phragmires) (examples shown in G Figures 2 through 5) also disrupts the linked and integrated nature of the coastal ecosystem. Standing sterns (live and dead) and a thick mat of rhizomes (tough, horizontal, rootlike structures) and litter (fallen stems and leaves) trap sediments and raise the surface of the marsh plain.Sediments are shaded by the dense growth, and the raised marsh surface dries. Growth ofrhizomes beneath the marsh plain, accompanied by sediment deposition, fills in small creeks and rivulets. The rhizome mat resists erosion at the banks of tidal channels, and these banks become nearly vertical as sediment erodes from the creek walls.The steep channel banks, lack of rivulets and small creeks, and raised marsh surface reduce fish and invertebrate access to the marsh plain. Shelter and breeding habitat are reduced. Algal production on the dry marsh surface is low, and what little there is, is not accessible. The estuarine aquatic ecosystem is impoverished by extensive Phragmites stands because the critical linkage between marsh and estuary is disrupted. In restoring diked salt hay farms and Phragmites-dominated sites, PSE&G was guided by an understanding of marsh biology, recognizing that the ecosystem is in constant communication and exchange with the estuary and linked to the shoreline buffers.Together, these support a food chain in which the energy moves from the dense Spartina to the small decomposing organisms and to marsh fish and crustaceans, to forage fish and top predators, to birds and to mammals. All of this rests physically on the daily ebb and flood of the tide across the broad flat expanse of the marsh, moving through a network of tiny rivulets to small and larger creeks.When the marsh is seen in this integrated ecological setting, the framework for restoration becomes apparent. PSE&G selected and acquired lands with conditions that allow for the prompt conversion to functional marsh, implemented a design grounded in ecological concepts,- and is assuring the restoration success through a program of continued evaluation and response. PSE&G's wetland restoration sites had appropriate marsh plain elevations and groundwater and tidal relations, propagules (seeds, rhizomes, larvae, etc.)present in the marshes or neighboring marshes, animals that would populate the marshes 16 PSE-G R~nc,'a ,kphbnin 4 Nlurcn I'm Appendl\ G Spresent nearby, and sediments of appropriate organic and nutrient content for marsh* restoration. Proper application of engineering and ecological principles together contributes to long-term sustainability in restored systems. PSE&G's restoration is based on ecological engineering. an approach in which human engineering is used to initiate and encourage natural processes. Nature is then allowed to complete the restoration more efficiently and in a more ecologically beneficial manner than would human intervention. This is not to suggest that ongoing intervention, oversight, or adjustment may not be necessary, particularly for control of invasive Phragmites. But taking maximal advantage of natural engineering minimizes the need for human engineering and allows natural ecosystem development. This is enhanced by applying Adaptive Management principles to long-term maintenance and management decisions. The Adaptive Management program provides a framework to identify and implement actions necessary to keep the restoration on track.These principles are the foundation of the Permit-required Management Plans. For each of the selected restoration sites, a conceptual design was developed and incorporated into a Management Plan. These Plans were prepared for each site to provide an integrated framework for land management and restoration. The Plans provide an overview of existing conditions, identify design provisions for implementation, assess potential environmental and off-site impacts, provide a schedule for implementation, identify success criteria, and establish an Adaptive Management program to ensure the long-term success of the restoration process.These Plans were developed and implemented in consultation with an expert team of ecologists, wetland scientists, engineers, biologists and coastal process experts and with the Management Plan Advisory Committee (MPAC).9 At significant junctures, program elements, including the Management Plans, required the approval of the NJDEP.III.A. 1.b. Salt Hay Farm Wetland Restoration The designs for the salt hay farm wetland restoration sites maximized the area of each diked salt hay farm that would be subject to the full tidal cycle and were developed to assure inundation of the marsh plain during rising tide and drainage during falling tide to promote the growth of Spartina and other desirable, naturally occurring marsh species.Tidal exchange was restored through excavation and construction of tidal channels and removal of perimeter dikes. Computer hydraulic models were used to develop the restoration designs to ensure adequate tidal inundation and drainage at each site.Excavated channel depths were designed to be below mean low water so that subtidal habitat would be available for use by fish during low tide. The channels were designed to be trapezoidal in cross-section to promote the formation of gently sloping banks to provide access to the marsh plain and intertidal habitat. Drainage patterns incorporated historic tidal channels and inlets. The designs also addressed potential off-site impacts and effects on wildlife, including threatened and endangered species.*17 PSE&:G Renewal .-ppF'hition 4 .\i.rch Append", G The wetland restoration projects were designed to ensure that the frequency and depth of flooding of adjacent properties would not increase after restoration. This protection was accomplished through the construction of dikes at the upland edge of the restoration areas and through the purchase and control of properties that exceed the relative design flood elevation. Further. to allow for drainage of the uplands along the dike, cross-drains have been installed in the upland dikes. (Exhibit G-2-8).Because pesticides historically were used in the diked salt hay farms, concerns were raised regarding the potential for release of pesticide residuals during the construction activity.Pre-restoration soil samples indicated that only DDT and its metabolites were consistently detected in soils at the diked salt hay farms, although at levels below NJDEP direct-contact soil cleanup criteria. A total of 48 composite surface water samples were collected immediately following breaching of the perimeter dikes at each of the diked salt hay farm sites. Only two samples, both from the Dennis Township Site, contained low, detectable levels of DDT. These low concentrations of DDT found at the Denrns Township site did not result in any adverse impacts to human health or the environment, as more fully explained in Exhibit G-2-7.PSE&G also developed a comprehensive monitoring program at each diked salt hay farm to detect any change in groundwater quality or groundwater elevations resulting from restoration activities that might impact wells or septic systems. The program sampled homeowners' wells and installed monitoring wells and peizometers to establish pre-breach baseline conditions. Following restoration of the sites, PSE&G sampled to identify impacts to well and septic systems. To date, monitoring data have not reflected any adverse impacts associated with the restoration sites (Exhibit G-2-9).Buffer zones were established and construction activities were timed to minimize potential impacts to threatened and endangered species. In addition, areas for colonization by highmarsh species were created by selective placement of material excavated from channels, thus creating habitat for a number of threatened and endangered species. Other design elements included predator breaks in internal berms and construction of osprey nesting platforms and peregrine falcon hacking towers (Exhibit G-2-1 1).III.A. I.c. Phragmites-Dominated Wetland RestorationThe Management Plans for the Phragmites-dominated marshes were developed on a template similar to that for the salt hay farms, but the Phragmites marshes presented a different geophysical setting. Phragmites became established in artificially elevated areas created during ditch excavation and spoil disposal, adjacent to filled areas such as dikes and levees, and on natural upland marsh edges. Once established on the remnants of dikes or other disturbed areas, Phragmites spread into adjacent areas and out-competeddesirable marsh vegetation over much of the marsh plain surface (Exhibit G-2-17).Since Phragmites grows in dense stands with a high rate of fitter production, it also alters marsh plain hydrology by "filling in" the microtopographic relief of the marsh surface.18 PSE&G Renewal A.r-phcjjtion M Nircn l01 Appendix G Small streams or rivulets are filled, thereby flattening and raising the marsh plain. This allows Phragmites to spread rapidly through rhizomes into lower elevations on the marsh surface (Exhibit G-2-6).In response to these conditions, the restoration program seeks to reverse the undesirable ecological conditions associated with a Phragmires monoculture by controlling the Phragrnites. thus promoting the growth of Spartina and other desirable, naturally occurring marsh vegetation. The wetland restoration program for the Phragmites-dominated sites includes initial Phragmites control through application of Rodeo with surfactant and prescribed burning; additional field data collection; continued Phragmitescontrol through the spray and burn program; and supplementalPhragmites control.Biological, geomorphic, hydrologic, and chemical data were collected prior to removal of the Phragmites to establish baseline characteristics and support restoration design.PSE&G then developed a conceptual design consisting of spraying, burning, and modification of existing channels and excavation of additional channels to re-establish a natural hydroperiod. Following the removal of dead standing Phragmites stalks, intermediate channels were identified. Tidal data collected on the marsh plain in areaspreviously dominated by standing Phragmites indicated that no appreciable tidal restrictions existed at the Phragmites-dominated sites and that they experience a naturalhydroperiod. Therefore, it was determined no additional channel excavation was necessary. However, evaluation of the marsh plain indicated the absence of rivulets and microtopography typically present in Spartina-dominated marshes. Following Phragmites spraying and burning, the changing morphology of the marsh plain makes it available for the re-establishment of Spartina and other desirable marsh vegetation. Exhibit G-2-10 describes PSE&G's spray and burn program.Spraying of the Phragmites was considered by some as likely to cause adverse effects.Phragmites was treated with Rodeo", a non-selective herbicide with the active ingredient glyphosate. To enhance the absorption of glyphosate by plants, a surfactant that acts as a wetting agent was added. The surfactant used in the glyphosate mixture was specified in permits issued by the NJDEP and has been classified as non-toxic when applied at field usage rates. Glyphosate was selected because of its demonstrated effectiveness for Phragmites control, its minimal toxicity to humans and other species, and its biodegradability. The safety of glyphosate has been reviewed by the United States Environmental Protection Agency (USEPA) and other national and international bodies, including the World Health Organization. These reviews show that glyphosate presents negligible risks to humans and the environment. Indeed, the USEPA has classified glyphosate as a Group E oncogen -a chemical that shows evidence of non-carcinogenicity for humans.After initial control through the spray and burn program, future Phragmites control may use other techniques to control the expansion of Phragmites. These measures, among other things, will encourage the re-establishment of the rivulets and microtopography that provide favorable fish habitat and provide a competitive advantage to Spartina and other 19 PSE&G Ren al ..\ ppihcja,,,"NMarch lQQQ Afpendix G desirable, naturally occurring marsh vegetation. In particular. these measures may include marsh plain modifications (microtopography), marsh plain and upland mowing, remnant dike removal, and seeding.lilA, ].d. Bavside Tract: Marsh and Upland Preservation The final Permit requirement relating to marshes is the preservation of tidal marshes and uplands at the Bayside Tract. The Bayside Tract covers approximately 4,407 acres in Greenwich Township, Cumberland County, NJ. The focus of the Management Plan was to protect aquatic habitat, particularly the 2,585 acres of salt marsh, by preserving 1,822 acres of upland area from development. The controls placed on this extensive riparian property preserve its open space and marsh-protective values for the benefit of the estuarine ecosystem. Salt and brackish marshes, which are located primarily along the western perimeter of the Bayside Tract, are the dominant type of land cover and vegetative communities. Agricultural cropland is the dominant land use in areas landward of the salt and brackish marshes. Most upland and wetland forests are within the northeastern part of the Bayside Tract.The Plan for this site was developed to provide long-term preservation and conservation, while maintaining existing uses. In addition, the plan maintains and protects the agricultural economy; protects natural and historic communities and cultural resources; and provides public access in a manner consistent with these goals.III.A.2. Status of Restoration As explained in more detail in Attachment G-2, PSE&G selected and acquired wetlands suitable for restoration with adjacent upland buffer, preserved those lands and the lands on the Bayside Tract, and appropriately designed and restored the degraded wetlands using the principles of ecological engineering. This section demonstrates that, as result of these efforts, PSE&G's wetland restoration program is on a trajectory for success. This is demonstrated through an analysis of monitoring data generated through PSE&G's Biological Monitoring Program (Exhibits G-2-2, G-2-3, and G-2-4) compared, as appropriate, to (1) the interim and final success criteria established in the Management Plans or (2) data from the annual monitoring of reference marshes.IIl.A.2.a. Reference Marshes We turn first to the issue of benchmarks for success. Tidal marshes are living systems that vary markedly from one another over time and space. Consequently, one cannot establish immutable and detailed specifications for judging when a marsh is fully restored and functioning in terms of its geomorphology, hydroperiod, or vegetation. As is common scientific practice in the assessment of variable field conditions, PSE&G used reference marshes; that is, marshes that were perceived to be functioning appropriately, that were close to the restored marshes in terms of important environmental 20 PSE&G Rene.al .Appication -, March 1994 Appendix G variables such as salinity, water temperature. and so on. and that could be compared to the restoration marshes to judge the progress or eventual success of the restored marshes.This use of reference marshes minimizes the variability between the standard and themarsh being restored and allows a fair analysis of restoration progress and success.Reference marshes were selected for two purposes. First, "time course" marshes allow one to understand how a natural, or naturally restored, marsh functions on a multi-year basis to determine the time course for the success of the restoration efforts and to establish the bounds of expectation for the restoration sites. Second, "'annual monitoring reference" marshes provide data and allow annual comparisons of both flora and fauna and thus provide a reference point for determining annual variations in marsh characteristics. III.A.2.b. Success Criteria Interim and final criteria were established to define restoration success based on conditions observed over time at the time course reference marshes, and included in the Management Plan for each of the sites. PSE&G used the time course reference marshes to provide data on the pace and end point of restoration (Exhibit G-2-2). The criteria for success are that within 12 years of completion of restoration activities:

• no less than 95 percent of the marsh plain (66 percent of the total marsh at the Maurice River Township Wetland Restoration Site and 76 percent at the other restoration sites)will be colonized by desirable vegetation;
• Phragmites coverage will be reduced to less than five percent of the total vegetated area of the marsh plain (less than four percent of the total marsh); and a open water and associated intertidal mudflat constituents of the restored sites will be targeted to be less than 20 percent of the total marsh area, and with a potential range of up to 30 percent of the total marsh at the Maurice River Township Site, to allow for the potential continuation of valuable shorebird habitat.Interim evaluation criteria were developed to monitor and document progress toward the final success criteria to assure that conditions during and immediately following restoration activities were moving the wetlands toward successful restoration.

The data relating to vegetation, geomorphology, macrophyte productivity, and algal productivity from the restoration sites are collected and compared with that from the reference marshes being monitored. The information provides additional data on which to evaluate the progress of the restoration sites.III.A.2.c. Status of Restoration at Salt Hay Farms A review of the geomorphology, hydrology, vegetation coverage, macrophyte productivity, and algal productivity at each of the salt hay farm sites confirms that they are on a trajectory for successful restoration. 21 PSE&G Renewal ,-pphhctwn .1ukrcn IQ9 Appendix G There has been a rapid increase in the number of channels at the salt hay farm sites (examples shown in G Fieures 6 and 7). The first year of post-restoration data also indicate the presence of a large number of channel classes at the Maurice River Township Site. While all of these sites are dominated by larger, or lower class, channels, large numbers of smaller. or higher class, channels have developed at all sites. The distribution of channel frequency and sinuosity of tidal channels at all sites are approaching the levels seen at the reference sites. Channels at all sites are rapidly developing morphology similar to the reference sites.Natural tidal inundation has been restored at the Dennis and Maurice River sites, and the rapid increase in number of channel classes and the corresponding increase in channel frequency indicates that hydraulic efficiency has improved there. Tidal inundation has been restored at the Commercial site. The period of tidal flooding within the interior portion of the site is, however, generally longer. Corrective measures have been and will be implemented there. Field observations in 1998 indicate that inundation time is declining. The rapid increase in the number of channels and the corresponding increase in channel frequency indicate hydraulic efficiency is improving there. Field observations along the bayfront show hydroperiods exist which support revegetation by Spartina and other desirable, naturally occurring marsh vegetation. Re-vegetation of portions of all sites with Spartina and other desirable, naturally occurring marsh species has occurred. The Dennis Township site was the first site completed. The restoration of normal tidal inundation and the resultant favorable hydroperiod has resulted in the rapid re-vegetation of the entire site with Spartina and other desirable, naturally occurring marsh species. G Figure 8 shows the Dennis Township Restoration Site shortly after construction was completed, while G Figure 9 shows the revegetated marsh plain inthe summer of 1998. G Figure 10 shows the dramatic increase in Spartina from 1995 to 1998. Since the hydraulic efficiency at Maurice River is on a trajectory similar to Dennis after the first year of restoration, it is anticipated that Maurice River will rapidly revegetate with Spartina and other desirable naturally occurring marsh species in 1999.As indicated above, it is anticipated that the length of tidal inundation across the Commercial Township site will decrease near term (i.e., over the next few years) and, correspondingly, re-vegetation will occur.Macrophyte production at all sites either approximates or exceeds the values at reference sites and is not statistically different. Algal production at all sites is not statistically different from the reference sites. The increase in the number of higher class channels and the development of the morphology of these channels improves the mechanisms for fish access to and from the marsh and transport of detritus to the estuary.Immediately after the dikes were breached at all three salt hay farm sites, the Adaptive Management Team observed large numbers of fishes using the recently dredged channels and large numbers of small fish on the marsh plain. During one visit to a Commercial Township tidal creek, the Adaptive Management Team observed so many striped bass 22 PSE&G RenewJl .-\pplica[ion aNfach IQ90 Appendix G feeding on the small fish cascading off the marsh plain during an ebb tide that the bass were forcing each other out of the water.lII.A.2.d. Restoration Status at Phragmites-Domninated Sites A review of the geomorphology, hydrology, vegetation coverage, macrophyte production and algal productivity at each of the Phragmnites-dominated restoration sites confirms that they are on a trajectory for successful restoration. The removal of Phragmites standing crop has initiated development of geomorphologic and morphologic changes and is expected to result in a lowering of the marsh plain due to rhizome decomposition and litter removal. Geomorphic changes include increases in the number of smaller or higher class channels. Morphologic changes include the development of shallower sloped channel banks with abundant intertidal mud flats.Normal tidal inundation exists at all sites and there are no channel restrictions. There has been a rapid increase in the number of channels and channel classes at all Phragmites-dominated sites, particularly at the smaller or higher class channels (examples shown in G Figures 11 and 12). The distribution of channel frequency and sinuosity of tidal channels at all sites is similar to the reference sites. In addition, the channels are developing.similar morphology to the reference sites (i.e., shallower sloped channels with abundant intertidal mud flats). The development of marsh plain rivulets has been observed at all sites. The increase in the number and class of channels, particularly smaller or higher class channels, and the development of the morphology of these channels improves mechanisms for fish access to and from the marsh, and transport of detritus and nutrients to the estuary.The vegetation analyses for the Phragmites-dominated restoration sites provide evidence of a significant reduction in monotypic stands of Phragmites and a corresponding increase in Spartina and other desirable naturally occurring marsh vegetation following spray and bum treatments (G Figure 13).Macrophyte production at the Alloway Creek and Cohansey River Sites either approximates or exceeds the values at reference sites, and algal production at these sites is higher than at the reference sites. It is anticipated that these values are representative of values for these parameters at the Delaware sites.IIIA.3. Marsh Productivity The underlying expectation of PSE&G's substantial marsh restoration program was that marshes that were fully functioning in terms of tidal exchange, geomorphology, and vegetation cover would produce fish that would minimize any perceived effect of Salem's operation:, In other words, the food web described earlier, with energy carried from the marsh grasses to the decomposers and primary producers and so up higher levels of the food web to forage fish, predators and birds, would establish itself if the appropriate basic conditions were provided. PSE&G undertook an unprecedented series of studies designed to determine whether these core expectations would be borne out in fact.23 PSE&G Rei.e.ji AnphI:. ?n" I r,,: 'I I L4)1 Appendix G These studies addressed two basic questions. First. do or will the restored marshes function in the same manner and support essentially the same hierarchy of aquatic life in the same abundance as fully functioning marshes in the Delaware Estuary. Second. how can we characterize the flow of energy through the marsh related food chain'? Both these questions are addressed from the perspective of the marsh habitat (e.g., is the assemblage of fishes in both small and large marsh creeks the same in reference and restored marshes,and what is that assemblage?) and from the perspective of particular biota (e.g., do striped bass move in and out of the creeks in the same manner in reference and restored marshes.and what does this movement indicate about predator-prey relationships?). The marshes provide habitat to a large number of species, both resident and transients, forming a highly complex marsh food web that is not completely understood by scientists. PSE&G's studies examine representative aspects of marsh life, to give a fair and balanced account of the marsh food web. To provide fair and balanced comparisons to the reference marshes, the studies were focused on a broad array of species, life stages and biological functions. The studies addressed the following areas. From the perspective of the food web, the studies included sediment chemistry and its relation to the bottom of the food web; blue crab and invertebrates in the marshes; young-of-the-year fish, particularly marsh residents and seasonally resident species; and the abundance and diversity of predators and the food habits of fish at different trophic levels. From the point of view of the broader biotic community, the communities of organisms were studied. Looking at the aspect ofbiological functions served by the marshes, the studies consider the use of the marshes as habitat and examine their contribution to the feeding, growth, reproduction, and survival of various species of fish. Finally, the energetic or trophic linkage from marsh to the Delaware Estuary was addressed. Out of these studies, two sorts of conclusions about marsh productivity may be drawn.First, conclusions are possible on the comparison of the restored marshes to the reference marshes. The parameters of the fish communities occurring in restored marshes that were former salt hay farms indicate that the restored marshes have similar, or in some instances enhanced, characteristics relative to reference marshes. Second, the analyses of the marsh food web allow one to make rough and limited estimates of the marshes' production of aquatic biota which show even with limited measurements and at an early stage, that the marshes are robustly productive. We turn now to a more detailed review of the studies of the marshes and their aquatic life that are fully set out in Attachments G-2, G-3, and G-4 and their associated Exhibits. Our analysis is limited to the restored salt hay farms because the Phragmites sites are not sufficiently close- to full restoration to permit the sort of comprehensive comparison and measurements that would provide a fair picture of the results of restoration at those sites.Data were collected from the Dennis and Commercial Townships restoration sites, as well as the Moores Beach reference site.24 PSE&G Renrcj I ..piwc.non 4.,rch 1990 Appendix G III.A.3.a. Development of the Food Web The Base of the Food Web: the Sediments and Benthic Invertebrates. Once the tidal exchange, geomorphology, and vegetation cover of the restored marsh are established.one can look for the development of the food web. starting at the bottom with the sediments and benthic invertebrates. In Delaware Bay, the lower trophic organismsinclude the benthic microalgae and macrophytes upon which higher trophic-level fish ultimately depend. These organisms require a sediment chemistry different from that of a salt hay farm in order to thrive. Decomposition of marsh plant biomass into detritus must occur for this successful sediment chemistry change to support benthic consumer communities and small fish (Exhibit G-3-7).Sediment chemical and physical properties changed rapidly in response to the marsh restoration at the Dennis Township Site (Exhibit G-3-7). Approximately one year after the dikes were breached in 1996, surface sediments consisted almost entirely of small size particles similar to the reference marsh. Over this same period, total carbon and total organic matter concentration, and carbon to nitrogen ratios at Dennis Township declined dramatically, and by the end of 1997 the values at the restored and reference marshes were comparable. Most importantly, this change in soil chemistries and soil physical characteristics has provided a habitat conducive to the establishment of benthic microalgae and microorganisms, which are key elements in establishing a vigorous food web. As occurs in other newly deposited sediments, the first benthic colonists were opportunistic species such as oligochaetaes and selected polychaetaes. These small surface dwelling species are well adapted to exploit new habitats because of their larval dispersal and rapid growth rates. Although the benthic invertebrates were not identical to those at thereference marsh, by the end of 1997, similar faunal groups were represented in each site. It appears that the benthic fauna are on a trajectory to a natural marsh assemblage. The Food Web: Blue Crab, An Invertebrate. Blue crab has an ecological role as both predator and prey, depending on its size. To examine blue crabs, abundances and other characteristics at the restored sites and the reference site were determined from 1996 through 1998 (Exhibit G-3-10). In general, by 1998 at both the restored sites, the patterns of seasonal occurrence and abundance of blue crabs were similar to that of the reference marsh for both large and small creeks. Abundance of blue crabs at Dennis Township was greater in 1997 and 1998 than at the reference marsh. Abundance of blue crabs at Commercial Township was higher than at the reference marsh in 1998, the first year after restoration was completed. Several other observed characteristics suggest that the restored marsh is providing high quality habitat for blue crabs. For example, at the restored sites, there were more larger crabs (i.e., presumably because these sites are providing better growth and survival) and more premolt females (i.e., perhaps because they are providing a better molting habitat).The Food Web: Fishes. The studies indicate that fish have responded positively to marsh restorations at both Dennis and Commercial Townships. Tidal flow was restored to these sites in different years (fall of 1996 for Dennis Township and 1997 for Commercial 25 PSE&G -\phcauitn I Narch It qQ Appendix G Township), and thus the responses to these marsh restoration efforts are different. The dominant fishes in large creeks in both of these restored marshes included Atlantic croaker, bay anchovy, hogchoker, menhaden, spot, spotted hake. striped bass. weakfish. and white perch. In addition, during 1997 and 1998, the abundance of bay anchovy, weakfish. spot, and all species combined in large marsh creeks was significantly greater at Dennis Township than at the reference site (Exhibit G-3-1).At Commercial Township, for which 1998 is the first complete year post-restoration, the response varied with the species. Bay anchovy, spot, and white perch abundances in large marsh creeks were not significantly different at the restored site from the reference site;however, weakfish were significantly more abundant at Commercial Township (Exhibit G-3-l).The abundant fishes in small marsh creeks in all study sites were Atlantic croaker, menhaden, Atlantic silverside, mummichog, sheepshead minnow, and occasionally bay anchovy (Exhibit G-3-1). Although the species composition in small marsh creeks was generally similar between the restored and reference marshes, non-quantitative nature of weir sampling made direct comparisons of abundance difficult. At Commercial Township, which had only recently been restored in 1997, a qualitative assessment of the abundance of target species (except spot) and all species combined indicated that their abundances were greater than the reference site. Thus, the response of fishes in the restored marshes was positive and comparable to the reference marsh.The small pelagic fish in large marsh creeks were studied in 1998 (Exhibit G-3-9). The fishes collected at the restoration sites were similar to those collected at the reference sites. In surface samples, Atlantic silverside dominated the catches in both the restored and reference marsh, followed by bay anchovy. Other species of importance included Atlantic menhaden and weakfish, and these were also similar in abundance at the restored and reference marshes.Thus, based on both qualitative and quantitative assessments, the higher abundances of young-of-the-year fish species in the restored marshes, relative to the reference marsh, shows that there is a positive response to the restoration by all species.Top of the Food Web: the Large Predators. Larger fishes, typically predators, that were using creeks in restored and reference marshes during the summer and fall of 1998 were assessed to examine how they use the restored and reference marshes (Exhibit G-3-3).Four species of predatory fish were collected at each site: striped bass, white perch, and, relatively rarely, weakfish and bluefish, most of which are RIS. Both species richness and abundance tended to be greater in the restored marsh. During the sampling period, catches in both reference and restored marshes were consistently greatest around low tide, when prey wer e-presumably concentrated at the creek mouths. Predators were seldom collected at the upper reaches of the creeks in either reference or restored marshes. In summary, the suite of large predators at each site appears to be similar, in both instances being dominated by striped bass and white perch which appear at the time their prey are 26 PSE&U Rencvj1 ,rppht jtn 4 NIarch1 I194)Appendix G being carried with ebb tide out of the marsh. The restoration appears to support a species richness and abundance of predators comparable to the reference marsh.Conclusions. In sum. the studies looked at numerous levels in the food web from benthic sediment dwellers up to predator fish. such as weakfish and striped bass. There was a consistent positive response in the restored marshes. The various levels of the food web were occupied not only by essentially the same species found in the reference marshes but usually at the same or greater density or abundance as found in the reference marsh. Thus, it appears that the hierarchical structure of the trophic levels of the marsh are not only in place but indeed are thriving in the restored marshes.III.A.3.b. Food Habits Another way to assess the flow of energy through the linkages of the food web is to examine what fish are eating. The food habits of a variety of fish species at several different trophic levels were examined at the restored salt hay farms to determine whether they were similar to that of the reference marsh (Exhibit G-3-7). The mummichog is one of the dominant species in salt marsh systems all along the East Coast of North America;thus, the nature of its response to the restoration is critical to evaluating the success of this restoration. The food habits of young-of-the-year mummichog at both the restored and reference marshes were similar. First, the changes in diet were similar at both sites, with a pronounced change from a relatively carnivorous diet at sizes less than 15 mm total length to one that was more omnivorous and contained larger quantities of detritus at sizes greater than 15 mm. Second, the diets contained many of the same kinds of organisms, including benthic organisms such as annelid worms, crustaceans, insects, and microfauna. However, the relative contribution of each varied between restored and reference marshes and reflected the availability of prey, as observed in the benthic invertebrate sampling at the same sites.The foraging ecology of the young-of-the-year of four other species (bay anchovy, spot, weakfish, and white perch) indicate that the restored marsh is providing suitable foraging habitat relative to the reference marsh (Exhibit G-3-2). These species generally consumed similar prey types and equivalent per capita quantities of prey at the restored and reference sites. This was true for all young-of-the-year target species in 1997 and for young-of-the-year bay anchovy and weakfish in 1998 (white perch were not adequately sampled in 1998). All four of these species had higher aggregate consumption rates at the restored marsh in 1997, in part because of the greater abundance of these species relative to the reference marsh. This pattern was consistent for bay anchovy in 1998 but not for other species. In summary, in the restored marsh these species are eating, in quantities and type, diets that are equivalent to those of fish in the reference marshes. This indicates that fish are able to obtain and consume comparable food in reference and restored marshes, and that these-food items are in fact available. The food habits of the dominant predators in the restored and reference marshes, i.e., striped bass and white perch, were also examined (Exhibit G-3-3). Their stomach 1 27 PSE&G Renewal -\ppl ion-. March I1)-14 Appendix G contents were dominated by benthic species which likely originated in the marshes. These included juvenile blue crabs, grass shrimp, seven-spine bay shrimp, and mumrnichog. Overall. the diet of these predators was similar at the reference and restored sites. with most of the inter-site variation occurring between the upper and lower portions of the reference site.Thus, the food habitats of the fish confirm the equivalence of the food web in the reference and restored marshes. Taken together, this suite of studies also confirms that the fish assemblages, the structure of the aquatic biotic community, are closely parallel in the restored and reference marshes.III.A.3.c. Marsh Use We turn now from the examination of the biotic community and trophic structure to the analyses of the use of the marshes by the fish and the contribution of the marsh to different aspects of the life cycle of fish. In particular, the studies look at the marsh as habitat and at their value and contribution to the reproduction, growth, and survival of fish and asks whether fish are using restored marshes in similar ways as reference marshes.Marsh Use: Habitat. To examine habitat use and determine whether the restored'habitat was being used in the manner that would be expected, the movements of four species of fish, mummichog, sheepshead minnow, Atlantic croaker, and striped bass, were followed in 1998 using tag-recapture techniques (Exhibits G-3-4, G-3-5, and G-3-6).At Dennis Township, the movements of two resident fishes, the mummichog and the sheepshead minnow, were followed (Exhibit G-3-6). The reported mummichog movements occurred over the marsh surface, especially on flooding tides. During the following ebbing tides, mummichog retreated to small marsh creeks and the large created creeks. Mummichog have a home range of approximately 400 meters. Sheepshead minnow, on the other hand, rarely moved beyond 50m from where they were tagged and released. These observations indicate that the mummichog and sheepshead minnow that occurred in the restored marsh were largely residents in the marsh system during the summer and likely the result of local reproduction. Furthermore, these findings indicate that this marsh system was acting as a habitat for feeding (Exhibit G-3-7) and growth (Exhibit G-3-5) and thus is functioning as a natural marsh system for these ecologically important species.Another species that commonly occurs in marshes, the Atlantic croaker, was the basis for intensive tag/recapture studies (Exhibit G-3-4). This is a representative and abundant species that typically uses the marshes as young-of-the-year and retreats to the deeper waters of the bay and ocean during colder portions of the year (Exhibit G-3-17). During the sumnler and early fall, the young-of-the-year were largely resident in the created creeks at Dennis Township, with up to 96 percent of the recaptures made in the same creeks in which they were tagged. This species was much less abundant at the reference site. This study indicates that croaker use the entire extent of the natural and created 28 PSE&G A~phf..,:k'n 4 March I QQ9 Appendix 6 creeks during high tides: during low tides, most appear either to leave the creeks and move into adjacent larger creeks or accumulate in the mouth of the creeks. In short, the young-of-the-year of this species spend a large portion of the summer and early fall in marsh creeks, and their use of habitats in the restored marsh was similar to that for reference marshes.The movements of a large predator. the striped bass, were studied in the restored marsh at Dennis Township and the reference marsh in 1998 (Exhibit G-3-5). In the restored and reference marsh the pattern of movements of large juvenile and adult striped bass was similar. Striped bass appeared to use the tidal creeks in the restored marsh to a greater extent than those in the reference marsh. However, striped bass were captured further up in the Moores Beach site. Thus, one may assume that habitat use by striped bass is fairly similar in the two types of marshes, because they shared ebb tide movement into creeks and flood tide movement into the bay.Marsh Use: Reproduction. There are relatively few fishes that reproduce in salt marshes in the Middle Atlantic Bight. However, those species that do, tend to be the most abundant and therefore are ecologically important species. Many of these locally-reproducing species are resident or seasonally-resident species (i.e., mummichog and Atlantic silverside, respectively). The evidence of reproduction is indicated by the presence of small larvae and juveniles (Exhibits G-3-15 andj-3-7). For mumrnichog and sheepshead minnow, it is clear that reproduction occurred in both the reference marsh and at the restored sites at the Dennis and Commercial Townships because small, recently hatched individuals were collected in both locations in 1997 and 1998 (Exhibits G-3-15, G-3-6, and G-3-7). Spawning in the intertidal marsh surface is characteristic for this species and has been demonstrated for many populations. The Atlantic silverside, which overwinters in the ocean and moves into the estuary in the spring to spawn, apparently spawned in both reference and restored marshes as shown by the collection of numerous small individuals (Exhibits G-3-1 and G-3-8). These seasonal and size patterns in collections are typical for other estuarine systems in southern New Jersey and elsewhere in the Middle Atlantic Bight. In summary, reproduction by the dominant forage fishes indicate that the restored marsh is functioning in a manner similar to the reference marsh, with respect to providing habitat for reproduction. Marsh Use: Feeding and Growth. Optimal feeding and subsequent growth of young-of-the-year fishes is a presumed function of estuarine/salt marsh habitats. This function appears to have been fulfilled at the restored marshes during 1997-1998. For this analysis, growth of the target species was measured during the summer to fall growing season.A number of seasonally resident species showed evidence of growth within the created creeks at the restored marshes based on monthly modal progressions in length. Growth rates at the restored marshes were similar to those at the reference site (Exhibit G-3-15).Similar growth between restored and reference marshes was apparent for young-of-the-29 PSE&G Rene,,al Apphic.mn 4 March 11)91)Appcndx G year RIS such as bay anchovy, spot. and croaker. Detailed analysis of growth of the seasonally resident young-of-the-year croaker, as demonstrated by recapture of tagged individuals, gave very similar estimates of growth between the restored marsh at Dennis Township and the reference marsh (Exhibit G-3-4). In short, growth rates of these dominant young-of-the-year fishes were similar between restored and reference marshes.indicating that the restored marshes are fulfilling a similar function to that of the reference marsh in providing habitat where young-of-the-year can forage and grow.Marsh Use: Survival. Another presumed function of salt marshes is to provide refuge from predators. To evaluate the survival of fishes in restored habitats, length frequency and abundance data were examined to determine if the fish were: 1) surviving to the time of egress in the fall, at least for seasonally resident species, and 2) surviving to the size at maturity for resident species. For the resident mummichog, it is clear from monthly length-frequency data (Exhibit G-3-15) that they reached the size of maturity by the fall of each year. These same individuals are evident in the length-frequency histograms the following spring. In a similar manner, the sheepshead minnow reach the size of maturity by the fall and thus probably are capable of reproducing in the following spring (ExhibitG-3-6). For a seasonally resident species, such as Atlantic silverside, the progression in modal lengths through the summer in both years at Dennis Township clearly showed that they reach the approximate size of reproduction by November; thus, they have survived to the size at which reproduction can occur the following spring. These patterns are typical for reference marshes as well. In sum, these correlates of survival indicate similar function between restored and reference marshes.Conclusion. From this array of studies, the similarity between the restored marshes and thereference marshes is shown in terms of how the fish use the marsh and the contribution that the marsh makes to the life cycle of a number of fish species. The evidence is powerful that across a large number of comparative measurement points the similarity of the restored marshes to the reference marsh is established. These include, for example, species richness, composition, abundance, etc. Of the 29 characteristics compared between the restored marsh at Dennis Township and the reference marsh, only two years post-restoration 23 were similar in value to the reference marsh, having equivalent or greater value. At Commercial Township, only one year after restoration, 14 of 19 characteristics had values similar to or greater than the reference marsh. These marshes are clearly on the trajectory of having the productive values that natural marshes possess.Equally important, this comparison is made from two perspectives that tell us more about the restored marshes; namely, the food web and the detailed structure of the biotic community, and the use of the marsh by aquatic species. It becomes evident from consideration of these data, that the restored marshes display the anticipated biologic community structure of the natural marsh and that the fish use the marsh in the anticipatedmanner, clearly demonstrating that the marsh makes a major contribution to the structure and functioning of the biologic community. 30 0 PSE&G Rene',a] Applhca..b n 4 March 199'Appendix G III.A.3.d. Measuring Productivit' Through the use of bioenergetics analysis. which captures a part of the marsh productivity. these studies also provide quantitative insight into the productivity of the marsh (Exhibit G-4). The bioenergetic method has Limitations. The approach relies on fish actually captured in the marsh by the monitoring program and on growth by predators feeding on fish produced in the tidal marsh. This approach does not account for detritus export-based production, which is important in the Delaware Bay. Both small invertebrates and very early life forms of fish pass through the monitoring nets and are lost to the bioenergetics calculations. Similarly, the larger fish are able to avoid the gear. The production: biomass ratios are very conservative. Finally, the restoration of the diked salt hay farms is not complete. Despite these severe limitations, the bioenergetics model estimates substantial production from the tidal marshes.The bioenergetics analysis was done independently for 1997 and 1998 and, in each year, a high and low estimate was provided based on differing estimates of the catchibility of the fish. The low amount for the RIS occurred in 1998 when production of 50,835 kg live weight was calculated; the largest figure of 404,835 occurred in 1997. The RIS category included bay anchovy, spot, striped bass, weakfish, white perch, and Atlantic croaker Blue crab were particularly abundant in 1998 with the high estimate at 273,168 kg as against a low end figure in 1997 of 28,128 kg. The total for all species combined varied from a low of 196,477 kg in 1998 to a high of 945,996 kg in 1997.In addition, the marsh production provides some corroboration of the aggregated food chain model used to estimate wetland acreage prior to Permit issuance. This was a general model that did not attempt to provide a detailed depiction of the energy flows in tidal marshes on the Delaware. Nevertheless, the macrophyte production data collected by the company at the restored marshes shows detrital production at a rate roughly equivalent to that used by PSE&G in the aggregated food chain model to estimate acreage.If.A.3.e. Linkage of Marsh to Estuary In conclusion, we focus on the multiple linkages between the marshes and Delaware Bay and the Atlantic Ocean. The first linkage is evident from the life history of various species. For example, spot reproduce in the ocean; the larvae leave the ocean as planktonand move inshore to settle in marshes, and it is in marshes where most feeding and growth occurs (Exhibit G-3-15). This pattern is substantiated by data from marsh sampling in 1996-1998. Spot was consistently the most abundant species in marsh collections, relativeto the bay. The data indicate that they feed heavily while in the marshes, including restored ynarshes (Exhibit G-3-2). Eventually, the young-of-the-year spot leave the marshes, enter Delaware Bay (Exhibit G-3-15), and overwinter in the ocean. Similar patterns have been demonstrated by pre-operational data collected by PSE&G (Exhibit G-3-12).31 PSE&G Renesal -p~ic.non Appendt\ G The same general pattern is evident for Atlantic croaker: i.e., spawning in the ocean followed by settlement, in highest numbers. in the marshes (Figure G-3-23) where they feed heavily (Exhibit G-3-2). grow quickly (Exhibit G-3-2), and. at about one year, move into the deeper waters of the bay. Thus. both spot and Atlantic croaker are excellent examples of how energy consumed in restored marshes and assimilated through growth is transferred to the bay and ocean.To investigate the position of marshes in the food web which extends into the estuary, a stable isotope analysis was undertaken to examine the food source of three fish species associated with the marshes: weakfish, white perch, and bay anchovy (Exhibit G-3-14).The study allowed comparisons of the tissue of these species, taken in particular times and places in the Delaware Estuary, to be compared to the isotopic "signature" of identified food sources.For bay anchovy and white perch, both of which were captured primarily in or near the marshes, the dominant patterns reflected the type of marsh in which they were captured.Those caught in or near the Phragmites dominated marshes carried the Phragmites pattern; those caught in or near the Spartina marsh carried the Spartina pattern. Although these results suggest that Phragmites-doninated marshes can provide food for these fish, just as Spartina marshes do, they do not provide insight to the relative levels of fish productivity from these marshes. As explained below and in Exhibit G-3-13, other studiesshow that Spartina marshes provide more favorable conditions for fish foraging, growth and survival. Furthermore, as explained in G-2, studies have demonstrated higher fish productivity and greater tidal exchange inSpartina marshes.The analysis for weakfish compared the signature of a group of weakfish taken at the mouth of the bay at the end of October 1998 to the isotope pattern of a Phragmites marsh, an upbay Spartina marsh and the downbay reference marsh at Moores Beach. The dominant pattern in the weakfish came from the downbay Spartina marsh. This is a powerful demonstration of the export of the Spartina marsh production to the fish of the Delaware Estuary and, given the location where the weakfish were captured, to the Atlantic coastal waters. Thus at the top trophic level of the foodweb, one finds clear evidence of the important contribution of the marsh through the primary producers up to the forage fish to the indigenous predator populations of the Delaware Estuary.III.A.4. Phragmites-Dominated Marshes We turn briefly to the Phragmites-dominated marshes. Comparisons between treated Phragmites marshes and their reference marshes is difficult to interpret because of the inherent variability between sites relative to salinity, distances between restored and reference,.marshes, annual differences in the seasonally resident fish fauna, and status of the restoration. One also needs to take into account the present stage of the restoration at the Phragmites sites. As the spray and burn program in the Phragmites-dominated marshes has progressed, important aspects of the tidal exchange and geomorphology of these sites have been uncovered. The Phragmites marshes typically had, hidden beneath 32 PSE&G Rone'al .pplicaIwn 1999 Appendix G their thick cover, a number of larger creeks with steep banks, but the raised marsh plain surface did not have the pattern of sinuous smaller creeks and rivulets that provide constant tidal exchange and refuge habitat for fish that use the marsh surface, such as mummichog. These smaller watercourses. part of the microtopography of the marsh.were typically filled up and cut off by the dense system of Phragmites rhizomes. These structural conditions are important to whether young fish such as mummichogs have access to the marsh plain. The studies already reviewed underscore the importance of these fish to the marsh food web. Comparative observations of fish at Phragmites and Spartina marshes at Hog Islands indicate the importance of these geomorphological and hydrological differences. (Exhibit G-3-13). At Hog Islands, the abundance of young-of-the-year mummichogs was found to be far greater in the Spartina-dominated habitats than in Phragmites habitats. The studies at the restored salt hay farms have shown the affinity of the mumxnichogs to the conditions of the Spartina marsh plain, which provides optimal habitat for forage, growth, and survival. In short, the marshes provide the mummichogthe ingredients and conditions supporting abundant populations, and it is the Spartina rather than the Phragmites marshes that do this most successfully.The importance of the mummichog as a basic forage fish up and down the Atlantic Coast, providing the link to transfer energy from one trophic level to the next higher level, underscores the importance for fish production of achieving the full suite of hydrogeomorphological and vegetative conditions in the Phragmites marshes before attempting to reach conclusions on the fish production that can be demonstrated to flow from the Phragmites marshes.Studies also indicate the presence of significantly greater numbers of blue crabs at the reference marsh as compared to the Phragmites restoration sites prior to and one year following treatment. In fact, blue crab abundance was extremely low at one Phragmites restoration site. Blue crab are commercially important and represent a high level consumer in the food web. Abundance of this important species is expected to remain low until favorable morphology (sloping channel banks, formation of small creeks and rivulets)is restored.In short, we are presently at too early a stage of the restoration to be able to quantify the biotic conditions that will be achieved at full restoration. Moreover, to quantify the fish production from the Phragmites marshes at full restoration, it may well be necessary to refine our techniques to assure that the full increased fish production of the former Phragmites sites is captured. Nevertheless, the evidence clearly suggests that successful restoration should support abundant and diverse fish life of a sort not present in the unrestored marshes.* 33 PSE&G Renc,.A. Appilýrwn 4 March 19141).Appendl\lII.A.5. Benefits of Marsh Restoration to Other Wildlife 0[[IA.5.a. Birds One of the most widely recognized values of estuarine marshes is their support of significant migratory and resident bird populations. Birds are part of the balanced wildlife community indigenous to the Delaware Bay and Estuary. The restoration of the marshes along the Delaware will support the large and robust bird populations that use the estuary.More than 100,000 acres of wetlands in the Delaware Estuary including PSE&G's restored wetlands have been designated as wetlands of International Importance by the Ramsar Convention, and The Nature Conservancy has included the bay wetlands in its"Last Great Places Program" -a landmark effort to preserve internationally important habitats. These designations reflect the important role of the Delaware salt marshes as refueling stops for many species of shorebirds on their migrations from South America to Canada for breeding. While at the marshes, the birds feast on horseshoe crab eggs and other invertebrate organisms and often double their weight before moving north.Scientists believe that some of these species have 75 to 80 percent of their total population feeding in the Delaware Bay during the spring migration. Delaware Bay has the largest concentration of shorebirds in the spring in eastern North America.Colonial nesting wading birds such as the great blue heron, little blue heron, tri-colored heron, black-crowned night heron, yellow-crowned night heron, snowy egret, great egret and glossy ibis feed primarily on fish and crustaceans within shallow-water areas. Marsh restoration has resulted in extensive shallow water and channel areas suitable for wading bird feeding.Marshes along the Delaware Estuary are used for breeding and wintering by waterfowl, such as the mallard and black duck, and are also important wintering grounds for green-winged teal, Canada geese and snow geese. Black ducks prefer nesting sites along the wetland/upland edge or on islands that afford isolation and freedom from disturbance; mallards use many types of vegetation for nesting cover, typically pools within stands of Spartina.The Delaware Estuary also has long been recognized as a critical stopover for migrating songbirds. Several species that breed within tidal marshes are the marsh wren, coastal plain swamp sparrow, seaside sparrow, and sharp-tailed sparrow. Long-term benefits to these species will be created by the removal of the dense vegetative cover at the Phragmites-dominated sites; and the development of a more diverse low growing herbaceous cover.fIl:A.5.b. Mammals The mammals that are most associated with the Delaware Estuary include the muskrat, river otter, marsh rice rat, meadow vole, and raccoon.34 PSE&G Renew"a Apphcaion 4 Nlarch I H Q Appendix GThe most productive marsh areas for muskrats in New Jersey appear to be brackish Scirpus spp. tidal marshes: Spartina alterniflora and Typha spp. marshes are also valuable. PSE&G's wetland restoration program will favor the development of thesemarsh grass species and thus benefit muskrats. River otter colonies are usually located near good herbaceous cover that provides den and resting sites and relatively low levels of disturbance. Saline marshes used by otters typically contain species such as D. Spicata, S. alterniflora, Scirpus olneyi, all of which will be present within the salt hay farm and Phragmites-dominated wetland restoration sites.The marsh rice rats and meadow voles are the principal prey species of many predators. While these species may be adversely affected by the restoration of tidal flows at the salt hay farm restoration sites, long term benefits will be created by the removal of the dense vegetative cover at the Phragmites-dorminated sites and the development of a more diverse low growing herbaceous cover that will provide nesting and foraging sites thatwere not available prior to wetland restoration. As high marsh vegetation communities develop within the sites, recolonization by meadow voles and rice rats is expected to occur.II.A.5.c. Reptiles The diamondback terrapin is closely associated with the tidal marshes of the Delaware Estuary. Terrapins tend to prefer sinuous creeks as opposed to the open waters of thebay and will benefit from the new channel systems at the salt hay farm sites. Nesting occurs along upper slope beaches, on the landward side of salt marshes, along the margins of upland forests, and even open farmland. Terrapin nesting will likely occur along many of the upland dikes that were constructed at the salt hay farm sites.III.A.5.d. Threatened and Endangered Species PSE&G took particular care to protect threatened and endangered species during the construction of the restored wetlands. Activities were timed and located to minimize potential impacts. In many cases, the completed restoration will provide habitat and protections designed for threatened or endangered species. High marsh habitat appropriate for such species as northern harrier, black rail, and short-eared owl was an integral component of the design and was constructed at all salt hay farm sites. The upland edge and marsh borders will provide vital nesting habitat for the American bittern. A total of 20 nesting platforms for osprey were built in and are maintained at the restoration sites and the Bayside Tract.8 35 PSE&G Rene.al Applicamtn -March 19')'G III.A.6. Human Benefits From Marsh Restoration The restored marshes are of immense value to people as well as animals. PSE&G has installed numerous new public use facilities at the wetland restoration sites and the Bayside Tract.In doing so. PSE&G has provided access to thousands of acres and vast, natural areas for a broad range of diverse public uses such as environmental education, nature study, hunting, fishing, trapping, and other recreational uses. The public access facilities include:

• seven wildlife observation platforms;" six boat launches;" a floating educational platform;" several miles of nature trails and boardwalks; and" dispersed parking throughout the Delaware Bay Estuary region for over 100 cars/buses.

The public access facilities were developed in consultation with local communities and in partnership with The Nature Conservancy, an international, not-for-profit land and conservation organization whose overall mission is to preserve plants, animals, and naturalcommunities that represent the diversity of life by protecting the lands and waters they need to survive. The Nature Conservancy reports that "public access improvements at PSE&G's wetland restoration sites and the Bayside Tract represent unique efforts to provide to the public high quality amenities for the enjoyment of the natural environments of the Delaware Bayshore region.... the quality and scale of which are not found in any other publicly accessible natural area in the Bayshore region" (Exhibit G-2-14).Ill.B. Fish Ladders Will Promote Spawning Runs of River Herring, Providing Both Forage Fish in the Fall and Adult Herring Fishing Thereafter Monitoring results to date at all fish ladder sites demonstrate that PSE&G fish laddershave been properly located at sites suitable to support successful river herring spawning.The company has gone further than the Permit required to assure the success of this program. In 1996 and 1997, PSE&G initiated a program to lift river herring from spillpools over the dams. The company began an intensive stocking program at all sites during 1998 based on literature review and the advice of fishery experts who concluded that many of the successfully restored runs of river herrings had been initiated by transplanting gravid adults into newly accessible impoundments. By stocking gravid adults into the impoundments, juvenile herring will be produced that, upon their maturity, will follow instinctive olfactory cues back to their natal waters above the fish ladders for spawning. This instinct to return to natal waters, combined with the need for new habitat, given increasing population pressure below the dam, will lead these returning herring to use the fish ladders. The stocking program was intended to enhance the development of sizeable herring runs at each of the impoundments in a period of 36 PSE&G Rene.ul .Arphcatio Appcndiix G approximately three to five years. For 1998, a target stocking rate of five adult river herring per acre was established. Based on discussions with fishery managers involved in restoring herring runs at other sites on the East Coast, PSE&G has developed and implemented an appropriate monitoring system to assess the success of the fish ladder program. PSE&G's monitoring to date at all ladder sites shows that the ladders have been properly located and designed, that fish are able to pass upstream through them, that spawning is successful, and that juvenile growth is being achieved. Even small numbers of eggs, larvae, and juveniles reflect the capability of the impoundment to support the spawning and development of river herring from egg to juvenile life stages. In addition to the sampling results,numerous schools of juvenile herring gathered to out-migrate from the impoundments. Atypical weather conditions in 1998, such as low precipitation and warmer fall temperatures, caused a delay in outmigration and resultant low collection rate in the juvenile emigration monitoring program. While some collections were made demonstrating emigration, the total numbers collected were small. Visual observations, made from late October through late December, the period during which emigration normally occurs, indicated the presence of large schools of juvenile river herring in proximity to the darn, but not emigrating. In fact, when the sampling nets were pulled in late December, large schools of juveniles were still observed within the impoundment in proximity to the dam.Juvenile abundance estimates and impoundment acreage reported for watersheds in Maine, Connecticut, and Nova Scotia were used to estimate the potential production of juvenile river herring upstream of the fish ladder sites in New Jersey and Delaware. The number of juvenile herring produced per acre was calculated from the existing data and used to develop projected low and high estimates of juveniles per acre for the fish ladder sites. Existing data included juvenile emigration estimates from Love Lake, Damariscotta Lake, and Lake George in Maine, Bride Lake in Connecticut, and Giant Lake in Nova Scotia.The surface acreage of the sites ranges from 45 acres at Bride Lake to 4,463 acres at Damariscotta Lake. Bride Lake had the smallest surface area and the highest production rate (5,723 juveniles per acre) and Love Lake had the second largest surface area and the lowest production (1,005 juveniles per acre). Damariscotta Lake has the largest surface area and the third highest production rate. The juvenile production estimates for Love and Damariscotta Lakes are based on nine and eight years of data, respectively (Attachment G-5). Consequently, these estimates are considered more reliable than estimates for the other three sites, two of which are based on only one year of data.The low and high estimates of juvenile production per surface acre of impoundment from the existing studies were used to estimate the potential production upstream of each fish ladder installation. Approximately 1,000 juveniles per acre was used as the lower limit of potential production and approximately 5,700 fish per acre was used as the upper limit.For all fish ladder sites combined, the estimated range of potential juvenile production is 736,665 to 4,194,959 fish. Because the available habitat upstream of the fish ladder sites* 37 PSE&CG 4 Nlarc;n 191)W Appendix G is similar in size to the two sites from previous studies with the highest production rates (Bride Lake and Giant Lake), it is likely that actual juvenile production upstream of the fish ladder installations will be near the higher end of the estimated range. The lower estimate should be considered conservative because it is based on data from an impoundment (Love Lake) with considerably more surface area than any of the PSE&G impoundments. These fish will provide forage to predators such as weakfish and striped bass when they enter the estuary in the late fall or early winter. As developed at the time of Permit issuance, PSE&G anticipates that the river herring will re-enter the estuary from coastal waters after two to four years. At that point, one can expect that they will return to the estuary at the rate of 235 per acre of new spawning ground. These fish are likely to be the target of a directed fishery which could harvest 70-85 percent of these returning adults before they ascend the fish ladders into the ponds and lakes. This rate of adult return should be sufficient to maintain a robust river herring population in the impoundments. These estimated outputs were evaluated through bio-energetics modeling to provide a benchmark to determine the contribution that the fish ladders would make to the fish biomass of the estuary. Using densities of 1005 and 5723 juvenile herring per acre, the estimated number of juveniles expected to out-migrate from the sites where fish ladderswill be installed would be from 736,665 to 4,194,959 fish (Attachment G-5, Table 19).Two different estimates were made of the production of juvenile herring that would be available to fuel predators. First, it was assumed that all herring were eaten over a short period of time after leaving the lakes (instantaneous consumption). Thus, the biomass available for predators to consume was the product of numbers (low or high abundance) times the mean weight (5.8g). It was further assumed that 60 percent of this biomass would be eaten and the remainder would be available to return as spawners in later years.In the second method, life-history parameters for river herring were used to model the population of river herring once they left the lakes. Here it was assumed that the portion of production that was lost to the population through mortality was available for consumption by the predator populations (delayed consumption). Further modeling of the quantity of predators that could be produced examined river herring allocation to striped bass and weakfish. In the absence of any recent, quantifiable relative abundance for these two species in the vicinity of the fish ladder sites, it was assumed that prey were eaten by the predators in rations of 25:75, 50:50, and 75:25 between striped bass and weakfish populations. The delayed consumption approach results in higher production estimates than the instantaneous consumption method. The results of the modeling suggest that under 25:75 rationing of prey (striped bass: weakfish) between 74.8 and 9873.9 kg of striped bass and 222.0-29,'303 kg- of weakfish would be produced by the sites where fish ladders have been installed. Under 50:50 rationing, between 149.6 and 19,747.7 kg of striped bass and 148 -19,535 kg of weakfish would be produced. Under- 75:25 rationing of prey, between 224.4 and 29,261.6 kg of striped bass and 74 -9,767.7 kg of weakfish would be produced. Total 38 PSE&G Rcne.ajl .pph,:Ijt n 4 -March 109)9 A ppendix: G predator production (striped bass and weakfish) was about 300 kg under low abundance. instantaneous consumption: 69,165 kg for high abundance, instantaneous consumption: 5.882 kg for low abundance, delayed consumption: and 39.498 kg for high abundance. delayed consumption. The delayed consumption estimation is probably more realistic. Based upon this modeling, between 5.882 and 33,498 kg of striped bass and weakfish would be produced. This level of predator production will represent a significant contribution to the production of predators in the Delaware Bay.In addition to this increase of predator biomass, approximately 200,000 adult river herring should return to the estuary annually where they are available to fishery harvest or for spawning.' 0 III.C. The Modification of the Traveling Screens Has Reduced Fish Mortalityfrom Impingement at Salem As explained in Section II, PSE&G has implemented modifications to the Station intake screens in accordance with Permit requirements. These changes were expected to increase the survival of fish that are impinged at the intake. The changes were designed to accomplish this increase by a number of means: faster removal of fish from the screens with quicker return to the river; minimization of turbulent vortexing of water in the buckets that lift the fish as the traveling screens rotate; and a gentler transition from the fish bucket to the fish return sluice. These changes to the screens were largely recommended on the basis of analysis by the consultant to environmental groups, Dr. Ian Fletcher; experimentation by the screen vendor, Envirex; and practical experience with screens at the Indian Point plants on the Hudson River.For three months in 1995, a side-by-side study was conducted comparing the old screen design in Unit 1 to the new design that had been installed in Unit 2. Impinged fish were collected and observed at the time of collection and periodically over the next 48 hours. It was unfortunate, from the point of view of the experiment, that the only species that was impinged at this time in sufficient numbers to allow meaningful analysis was weakfish.The results of the side-by-side comparison indicate an increase in weakfish survival with the modified screen design in the range of 13-26 percent, depending on the month.Further analysis was undertaken in 1998, after completion of the screen modifications at both Units. Impinged fish were sampled twice a week from May through September and observed at the time of collection and periodically over the next 48 hours. The survival rates for these fish were compared to historic survival rates derived from similar studies undertaken from 1978 to 1982. This comparison shows that the screen modifications have been very effective in improving fish survival. For white perch, bay anchovy, Atlantic croaker, spot and the alosids, all estimates of impingement survival rates from the 1997-1998 studies (new intake screens) are higher than corresponding estimates from the 1978-1982 studies (old intake screens). For weakfish, the August and September impingement survival rate estimates, from the 1997-1998 studies are higher than the corresponding estimates from the 1978-1982 studies. However, the weakfish survival 39 PSE&G Rencwal Appliuaton 4 March Iq4 Appendix G estimates from the 1997-1998 studies for June and July are lower than the corresponding estimates from the 1978-1982 studies. The difference in results for weakfish in June and July, in comparison to August and September, may be due to the much smaller size of weakfish impinged in June and July. Results for other species are based on data that may be affected by smaller fish being impinged on the new screens. For this reason, the screen effectiveness estimates for the other species may be biased low.Because the 1995 Study provided a concurrent. side-by-side comparison, it was not biased by possible confounding factors (such as differing fish size, different experimental conditions, e.g., incorrect flap seal adjustment, different water depths in the system, or different conditions of fish used in the experiments) that could affect comparisons of results from the 1978-1982 studies and results from the 1997-1998 studies. To minimize such biases, only results from the 1995 Study should be used to assess the effectiveness of the modified intake screens for weakfish. PSE&G is undertaking additional studies to explicate the unanticipated results for weakfish and other species obtained from the 1997-1998 study.Put in terms of the percentage reduction in mortality achieved by the new screens in comparison to the old screens, the improvements obtained by the new screens range from an average of 23 percent for bay anchovy to 69 percent for Atlantic croaker for the months in which the comparison can be made. For all species other than bay anchovy, the average reduction in mortality obtained by the new screens was over 50 percent. The modified screens, therefore, have significantly reduced impingement mortality.III.D. The Sound Deterrent Study Has Advanced Knowledge, Producing Unexpected Results Which Would Require Replication Before Application PSE&G developed excellent experimental approaches for both semi-field and in situ studies to assess the feasibility of deterring fish from the area in front of the intake. Taken as a whole, the 1994 and 1998 cage tests and the 1998 in situ tests were probably the best designed, best executed, and most comprehensive set of studies on reduction of fish impingement by sound that have been conducted to date. These studies have generated promising data that suggests additional study of sound for application at Salem is warranted. The 1994 cage tests were the first study of the application of sound to provide a rigorous method of recording data and a wide range of acoustic parameters to test. The 1998 cage tests built upon the strengths of the 1994 cage tests, but also incorporated more quantitative and refined data acquisition and analysis techniques. The 1998 cage tests may be the most comprehensive quantitative analysis ever done on the response of fish to a range of sounds, in a semi-field situation. Virtually all previous studies of this type suffered from one or more problems associated with quantification of results, potential observer bias, or possible adaptation of the fish to the sounds so that the fish would stop responding to the signal.40 PSE&G Renewil -piptzca in -March 19411 Appendix G Likewise, the design of the in situ studies was rigorous. Sound presentation methods were well designed. as was the method for sampling fish. The extended period of the experiment provided statistical validity to the design. There was also little or no interference in the experiments due to weather conditions, Station outages, or other variables that could not be controlled by the investigators. The sounds themselves were selected on the basis of a well designed and executed set of experiments and were the appropriate and logical selection for the Salem RIS.PSE&G's sound feasibility study has generated promising data that indicate that there is good potential to deter at least some species, at least at certain times of the year.Specifically, the data suggest that fish such as bay anchovy, Atlantic silversides, weakfish, and Atlantic croaker, may be deterred by sonic frequencies, while the Alosa species may be deterred by ultrasound. At the same time, there were insufficient data to come to statistically valid conclusions regarding the majority of species impinged at the Station, and the conclusions reached must be replicated. Additional studies are needed to confirm and better understand and optimize the* promising results, as well as to come to conclusions regarding other species, before a final determination regarding the application of this technology at the Station can be reached. Without additional studies, a system cannot be properly designed -and the viability of the technology (i.e., its overall effect onthe fish population) cannot be evaluated. In summary, the sound feasibility study has advanced the knowledge of sound as a possible fish deterrent by providing rigorous scientific testing of a range of sound on a variety of fish species both in semi-field and field tests. PSE&G has demonstrated some potentially significant success in reducing impingement of RIS at Salem while demonstrating that there would be no detrimental effect on fish species in the estuary.III.E. The Biological Monitoring Program Has Resulted in Advances in Scientific Knowledge and In Practical Knowledge Valuable for Natural Resource Management The benefits from the scientific biological monitoring program go beyond the objectives ofPermit compliance. The monitoring required by the Permit and the supplemental monitoring programs represent a coordinated effort to provide valuable information not only for assessing the potential environmental effects of Salem, but also for managing the natural resources of the Delaware Bay ecosystem. The results of the PSE&G monitoring programs have advanced the state of scientific knowledge about the estuarine ecosystem in significant ways.PSE&G has also established and is funding a Marsh Ecology Research Program (MERP)through the Academy of Natural Sciences of Philadelphia, providing competitive grants to promote basic scientific research in marsh and marsh restoration ecology. This unique initiative is also being supported through funding from the Sea Grant Programs of New Jersey, Delaware, Maryland, and Connecticut. 41 PSE&G Rencwaj -pphcatwn M Njarch 1099 The PSE&G monitoring pro-ram provides the following environmental benefits: Appendix G* advancing the state of scientific knowledge about the structure and function of estuarine wetlands and habitat restoration techniques;

• supporting assessments of potential ecological effects of wetland restoration projects, power plants operation and other human activities; and* contributing to databases that are valuable for management of natural resources of the Delaware Bay ecosystem, including fisheries, wetlands, and watersheds.

Several major elements of the PSE&G monitoring programs address abundance, habitat utilization, and reproductive status of important fish species. These programs include monitoring of fish habitat utilization, fish food habits, ichthyoplankton, juvenile, and adult river herring, and baywide abundance. Monitoring data on ecologically and economically important species of fishes collected in these programs contribute to management of regional fisheries. For example, the river herring monitoring program contributes to a database to assess the effectiveness of fish ladders and wetland restoration activities on fisheries resources. Observations that spawning habitat has increased illustrate the value of monitoring in a fisheries management context. Habitat utilization and dietary data collected for important fish species as part of PSE&G's monitoring of marsh restoration projects and reference wetlands is a significant contribution to regional ecological information that is critical for fisheries management. Collection of baywide abundance data for fishes and blue crab is integrated with long-term monitoring programs such as the DNREC Small Trawl Survey, and the NJDEP Beach Seine Survey. The PSE&G baywide monitoring program has continued and expanded on these two surveys. Thus, important information is being collected for management of weakfish, bay anchovy, white perch, striped bass, spot, Atlantic croaker, blueback herring and alewife.The contribution of PSE&G's monitoring programs to regional databases on tidal marsh ecology is also significant. PSE&G studies of natural and restored estuarine marshes have significantly advanced scientific knowledge of these systems. Particularly, data on species distributions, food habits of fishes, and trophic linkages between marsh habitats, adjacent creeks, and the bay are valuable for understanding the ecological functions of marshes.The monitoring data demonstrate the relative importance of various primary producers in marshes (e.g., benthic algae, phytoplankton, and macrophytes), contributions to the detrital supply both within and outside the marsh, and habitat values for aquatic and terrestrial species. In a regional context, the PSE&G monitoring data provide information for management of specific restored and reference marshes, as well as general scientific information for management of other wetlands. An understanding of marsh structure and function developed from these monitoring data have substantially improved our ability to manage wetland resources. 42 PSE&G Renewal Aoppicanon 4 M\ ch 11.9q Appendtx G Managers of regional wetlands can also benefit from PSE&G monitoring data on the effectiveness of available techniques for restoring estuarine wetlands. Limited information is available on practical techniques to restore tidal marshes to functional ecosystems similar to natural marshes. The PSE&G data have substantially improved our understanding of the ecological effects of different marsh restoration techniques, theirlimitations, and possibilities for improvements. Moreover, these studies have shown that restored marshes are similar to natural marshes in trophic functions and connections to adjacent ecological systems. This information will be valuable to natural resource managers for ecological engineering of other wetlands systems. In addition, scientific efforts reflected in this Application have significant value for other purposes. The attachments to Appendix C that provide detailed and up-to-date reviews of each of the Salem RIS and a number of other fish will be of value to every student of those species. The work undertaken for the hydrothermal and biothermal assessment provides many specific advances in data collection and analytical techniques. The monitoring made possible extensive enhancement and validation of mathematical hydrothermal modelswhich allowed improved modeling of extreme environmental conditions and improved depiction of environmental variability. Additionally, analyses of potential biological effectswere improved by including new biological data in thermal responses of organisms, development of confidence intervals for biological source information, and using new quantitative analysis techniques for evaluating organism survival after transit through the thermal plume.Overall, the PSE&G monitoring programs and related studies partially funded by PSE&G have provided valuable scientific information for managing natural resources in the Delaware Estuary as well as other mid-Atlantic estuaries. PSE&G-funded research has not only evaluated the effectiveness of marsh restoration techniques, but also has demonstrated the success of an ecological engineering approach in restoring valuable habitat for estuarine fishes and invertebrates, especially at the diked salt hay farms. Moreover, the monitoring programs have improved scientific understanding of the ecological functions of marshes, including trophic connections with adjacent estuarine and coastal waters. Available monitoring data also will be used in adaptive management of existing restoration projects. New scientific knowledge gained during the monitoring will likely facilitate the design of future projects involving marsh creation or restoration and improve the chances of success for other restoration projects.HI.F, Benefits of Delaware's Construction of Artificial Reefs and Restoration ofthe Augustine Creek Impoundment With funds provided by PSE&G pursuant to the company's settlement with DNREC, Delaware.has undertaken two estuarine enhancement projects that provide benefits to Delaware Bay and provide habitat for particular indigenous species of aquatic biota.First, DNREC constructed eight artificial reefs in Delaware Bay pursuant to the National Reef Plan which has been developed under the 1984 National Fishing Enhancement Act.8 43 PSE&G Rcnc., .--i,,, Appendi\ G Two of these sites are located in the upper bay adjacent to natural oyster beds. The six other sites are located in the lower bay adjacent to the lower bay anchorage area.DNREC has collected data on on-reef epifaunal (attached) and fish community structure and abundance. These data show that the lower bay reefs have enhanced the biomass the epifaunal community and the benthic forage available to the bay fish community. in addition, data from the upper bay reefs show that the epifaunal community density on the oyster reef structure was nearly 50 times the density of the infauna on the surrounding bottom and similar to that found on the reefs in the lower bay. These structures should aid in the restoration of the Delaware's severely depleted oyster population. Studies of other artificial reefs in the Delaware Bay demonstrate their benefits to fish communities. Studies conducted by the U.S. Army Corps of Engineers at the Brown Shoal reef in the lower bay showed that the reef habitat was dominated by tautog, scup, black sea bass, smooth dogfish, and oyster toadfish. Other species collected include weakfish, gray triggerfish, Atlantic spadefish, conger eel, banded rudderfish, pigfish, and cunner. While not designed to benefit Salem RIS, these lower bay reefs provide some habitat and/or feeding opportunity for the RIS, as well as providing habitat and fostering a number of other indigenous species which are part of the biotic community of the Delaware and which receive less direct assistance and support from other projects.Second, DNREC has undertaken to restore approximately 964 acres of degraded wetlands at the Augustine Creek Impoundment, located along the Delaware River, one mile south of Port Penn in New Castle County, DE.Historically, the Augustine Creek Impoundment was a freshwater-to-oligohaline (salinity less than 5 ppt) tidal marsh which, beginning about 1868, has been periodically impounded by dikes. In 1952, the reconstruction of the earthen dike along the eastern boundary of the site, parallel to the Delaware River, formed the existing impounding structure. This dike contains two flapper like gates that provide one-way flow out of the marsh but restrict and largely prevent tidal inflow from the Delaware River. The diking of the marsh led to deteriorated conditions: an increase in upland flooding, a reduction in water quality, increased sedimentation and shoreline erosion, siltation of tidal channels, decreased vegetative species diversity, increased coverage by Phragmites, reduced diversity of fish and wildlife, and an increase in mosquito populations. The goal of the restoration project is to ameliorate these degraded conditions. The Augustine Creek Impoundment restoration plan includes six elements: " installation of an automated water control structure containing vertical lift gates and automated sensors;" implementation of a water management plan to bring management consistency while restoring wetland habitats, improving habitat and water quality for fish and wildlife, reducing upland flooding, and reducing shoreline and island erosion;44 PSE&G R env~a.Apph 4 Ma rcn I100-)Appendix G S .continuation of a Phragmnites control program begun in 1994;* shoreline erosion control and stabilization along the marshes of the impounding structure;

• excavation of existing tidal channels and ponds to increase shallow-water habitat diversity and estuarine circulation; and* restoration of a maximum of 25.8 acres of historic emergent wetland islands and shorelines.

DNREC has implemented all but the last two of these elements. DNREC expects to complete the excavation of tidal channels and ponds and restoration of historic islands and shorelines by 2002. Information from restoration projects at similar sites suggests that the Augustine Creek project will provide significant ecological and other benefits:* restoration should increase vegetative coverage and improve vegetative diversity by reducing Phragmites coverage;* restoration should benefit fish by providing enhanced habitat, improved water quality, and increased access to marsh, as well as improved tidal exchange with the river, promoting the exchange of nutrients, detritus, and organisms between the estuary and wetland complex;* restoration should also benefit wildlife by providing enhanced forage and improved habitat diversity for wading birds, waterfowl and other wildlife; and e restoration should help mosquito populations by improved predator access to mosquito larvae and pupae. In sum, the Augustine Creek Impoundment restoration project is proceeding on schedule. Once completed, it is anticipated that the project will improve water quality and habitat and will provide other, ancillary benefits.IV. CONCLUSION: PSE&G HAS COMPLIED WITH THE SPECIAL CONDITIONS OF THE PERMIT WHICH HAVE BROUGHT SIGNIFICANT BENEFITS TO THE DELAWARE ESTUARY PSE&G has fully complied with, and indeed has done more than required by, the Special Conditions of -the Permit and the settlement agreement with DNREC. PSE&G modified its intake traveling screens in accordance with the Permit and made additional changes to the intake system designed to increase the survival rate for impinged fish. PSE&G conducted the sound deterrent studies to determine the feasibility and effectiveness of S.. 45 PSE&G Rene~ al .-).p icaion 4 .iarch I199 AppendiN G using sound to reduce impingement. PSE&G also secured, preserved. restored. and is currently performing Adaptive Management at more than 11,000 acres of wetlands and associated upland buffers. PSE&G constructed and installed six fish ladders to restoreriver herring spawning runs. Finally, PSE&G engaged in a substantial biological monitoring program to assess the benefits from implementation of these Special Conditions and to assess the potential impacts of Salem. All these efforts were completed in accordance with the schedules set out in the Permit.When NJDEP issued the Permit it was anticipated that the Special Conditions wouldbenefit the Delaware Estuary, and the animals and people that use and rely upon it. It is clear that PSE&G's efforts have met and surpassed these expectations. The new screens and intake system have in fact increased the impingement survival rate. The sound feasibility testing studies were among the best designed and most comprehensive tests of the use of sound as a deterrent and have advanced the state of knowledge about thispotentially important technology. The marsh restoration program has been anoverwhelming success by any measure; the marshes are on a trajectory to complete and full restoration and are increasing the productive capacity of the estuary. The marshes do more than simply produce fish; they also benefit other wildlife and provide immeasurable benefits to humans. Fish ladders are functioning and are on a trajectory to restore riverherring spawning runs to several rivers. Finally, PSE&G's biological monitoring program has resulted in significant advances in scientific knowledge and has provided practical knowledge valuable for natural resource management in the Delaware Estuary and beyond.It is important to remember that these benefits are not temporary; they are long-lasting and permanent. PSE&G's compliance with the Special Conditions of the Permit will continue to provide benefits for many years beyond the life of the Station. The successful implementation of these conditions, with the input and advice of stakeholders and the ongoing guidance of a team of experts, is a testament to PSE&G and confirms that the Permit should be re-issued. 46 PSE&G Renewal Application 4 March 10W-t Appendix G ENDNOTES NJDEP posed this as the central test for Permit renewal when addressing the conservation measures in the Permit: "'The Permit will expire after a five year term. If. at that time.... It is determined that the balanced indigenous population of aquatic species in the Delaware Estuary is not being maintained, the Department will take all appropriate steps required under Section 316." Response to Comments Document at 44.2 There are a handful of minor Permit requirements which do not merit extended discussion and which we therefore address in this footnote: 1) Effluent Characterization Study. Part IV-B/C Section I.E required PSE&G to conduct an Effluent Characterization Study (ECS). The purpose of the ECS is to determine whether the discharge of any pollutant from the Station has a reasonable potential to cause an exceedance of the applicable NewJersey Surface Water Quality Standards (SWQS) for Zone 5 of the Delaware Estuary.In March 1995, PSE&G initiated an ECS at Salem. The ECS was suspended in August 1995 due to an extended Station outage. In March 1996, PSE&G submitted the Salem Generating Station Effluent Characterization Study Interim Report (Interim Report) to the NJDEP summarizing the results of the first rounds of data collection at Salem for the ECS. The Department reviewed the Interim Report and agreed with PSE&G's conclusions. On 17 April, 1998, Salem resumed full power, allowing the ECS to be reinitiated. In February 1999, PSE&G submitted the final ECS Report, which included the following conclusions:

• The study is complete.

All samples have been collected and all data have been analyzed and reported as required in the Permit.9 No Station discharge has a significant effect on the water quality of the Delaware Estuary.2) Whole Effluent Toxicity Study. Part IV-B/C Section I.F requires PSE&G to conduct a Chronic Toxicity Characterization Study (CTS) on the non-contact cooling water effluent. Non-contact cooling water (NCCW) is discharged at discharge serial numbers (DSN) 481-486 to the Delaware Estuary.NJDEP's purpose for requiring the acute and chronic testing was to determine if significant acute or chronic toxicity was caused by the Station through the NCCW discharge. The study tested the effects of appropriately selected effluent concentrations on the survival and growth of test species.A first set of toxicity characterization studies was conducted in the spring and summer of 1995.PSE&G concluded, in a Study Report to the NIDEP in September 1995, that these results demonstrated that there was no conclusive evidence that toxicity was added by the Station to the non-contact cooling water. The NJDEP reviewed the results of the 1995 CTS and responded to PSE&G in November of 1995. The NJDEP determined that these results did not conclusively demonstrate an absence of toxicity; nor, however, did it demonstrate a pattern of toxicity that would warrant an extensive dilution study. As a result, the NJDEP required PSE&G to conduct an additional series of tests to characterize acute and chronic toxicity fully. Due to the extended outage, the second-set of such studies was conducted in the summer and fall of 1998. No acute toxicity to sheepshead minnows was observed in any of the tests. Nor were significant adverse effects observed in either survival or growth of inland silversides. The results of the sheepshead minnow chronic testing, however, are not fully understood at this time since the results seem to indicate problems with the fish tested rather than with the effluent. Copies of all test results were submitted to the NJDEP in February 1999.3) DSN 489. Modification (Oil Water Separator). Part IV-B/C, Section G.2 requires PSE&G to install an Oil Water Separator (OWS) at DSN 489. The OWS system was installed in accordance with the requirements of the Permit.4) DSN 487B Modification Part IV-B/C, Section G. 1 requires PSE&G to reroute the discharge of the#3 skim tank (DSN 487B). This has been completed. 1 47 PSE&G Renewal .Applicaton .March 1949 Appendix G 5) Cooling Water Flow Limitation. Part IV-B/C. Section H. I requires that the intake tlow rate not exceed 3024 MGD as a monthly average, Part III-B/C. Section L.A requires that compliance with this condition be monitored daily (by calculation) and reported monthly to the NJDEP on the Discharge Monitoring Reports (DMRs). During the period from I September 1994 through 30 September 1998, the average intake flow rate reported on the DMRs was 1185 MGD. The highest monthly average intake flow rate reported on a DMR was 3024 MGD.Part IV-B/C. Section H. I also requires annual evaluations of the flow rate from each circulating waterpump. Performance testing was undertaken using a dye dilution flow measurement technique in 1994, 1995, 1997 and 1998. These dye studies were performed in accordance with Section A.I0.(b). The results of the dye evaluation confirmed that PSE&G was complying with the intake flow rate limitations, and these results have been reported to the NJDEP on DMRs.6) Financial Assurances. A. Letter of Credit. Special Condition H.7.(a) and (b) required PSE&G to establish an irrevocable letter of credit in the amount of $20,000.000 posted to a standby trust, of which NJDEP was the beneficiary, in order to guarantee the performance of Special Conditions H.3 through H.6. On 30 September 1994. the Bank of New York, National Community Bank Division established a Standby Trust Agreement between it and PSE&G naming NJDEP as beneficiary and issued a letter of credit in the amount of $20,000.000 under the terms of the Standby Trust Agreement. The letter of credit has been renewed each year that the Permit requirement has been extant.B. Escrow Fund. Special Condition H.4.(a) requires PSE&G to establish an escrow account in the amount of five hundred thousand dollars ($500,000) to be used exclusively for the fish ladders program. On 28 October 1994, PSE&G established and funded an escrow in the required amount with First Fidelity Bank, N.A. (now known as First Union Corporation) as Trustee.PSE&G has used the escrow for the fish ladders program once since Permit issuance. In March 1997, PSE&G -after approval from NJDEP -drew $300,000 from the escrow, leaving$200,000 in the escrow as of this date. The request to draw from the escrow was made after the Silver Lake, McGinnis, and McColley Pond fish ladders were completed. PSE&G has satisfied all the Permit requirements related to wetland restoration which are documented as follows:* PSE&G has restored 4,398 acres of wetlands at the New Jersey Salt Hay Farms, 3,723 acres of wetlands at the New Jersey Phragmites sites, and 4,338 acres of wetlands at the Delaware Phragmites sites (Attachment G-2).* PSE&G has preserved the Bayside Tract through deeds of conservation restriction and notified NJDEP of these restrictions on 27 February 1994 (PSE&G letter to NJDEP (27 Feb. 1994).* PSE&G selected and secured the lands related to the restoration sites in accordance with the Permit terms and schedules:-Commercial Township: 3 August 1995 Letter to NJDEP-Maurice River Township: 31 August 1995 Letter to NJDEP -Dennis Township: 31 August 1995 Letter to NJDEP-Alloway Creek: Exhibit G-2-1, Table 7-Cohansey River: Exhibit G-2-1, Table 7-Delaware Phragmites Sites: Exhibit G-2-1, Tables 10-14.* PSE&G submitted to NJDEP for approval Management Plans for the restoration sites as follows:-Commercial Township: 22 August 1995 Letter to NJDEP-Maurice River Township: 8 August 1995 Letter to NJDEP-Dennis Township: 20 July 1995 Letter to NJDEP is 48 PSE&G Renejal Appic,:jtmn March 19-'Appendix C Alloway Creek: 21 February 1996 Letter to NJDEP-Cohansey River: 21 February 1996 Letter to NJDEP-Bayside Tract: 27 February 1995 Letter to NJDEP-Delaware Phragmites Sites: 23 February 1996 Letter to NJDEP" PSE&G established the Manaagement Plan Advisory Committee (MPAC) and submitted the roster of the MPAC membership to NJDEP on 28 October 1994 -PSE&G Letter to NJDEP (28 Oct. 1994)." PSE&G (or DNREC),began implementation of the Management Plans at the restoration sites as follows:-Commercial Township: 23 September 1996: completed 24 December 1997 (Exhibit G-2-1, Table 18)-Maurice River Township: (8 November 1996: completed 22 March 22 1998 (Exhibit G-2-1. Table 20)-Dennis Township: 29 January 1996; completed 27 September 1997 (Exhibit G-2-1, Table 19)-Alloway Creek: 27 August 1996 (Exhibit G-2-1, Table 21)-Cohansey River: 10 October 1996 (Exhibit G-2-1, Table 22)-Bayside Tract: 15 September 1996; completed I 1 July 1997 (Exhibit G-2-1, Table 23)The Permit required PSE&G to submit to NJDEP a Fish Migration Project Work Plan, including a schedule for permitting and construction activities. This Plan was submitted on August 30, 1995, and was modified as alternative sites were substituted and schedules necessarily changed. Permits were obtained on a timely basis, including Army Corps of Engineers permits, Dam Safety permits, state Water Quality Certificates, and all other federal, state, and local permits required for ladder installation and operation at each site.The Permit also required that PSE&G solicit access rights to each of the sites. Appropriate easement and access agreements were obtained for Sunset Lake (City of Bridgeton, NJ), McColley Pond and McGinnis Pond(DNREC and DELDOT), and Silver Lake (City of Dover. DE) in 1995. A Deed of Easement was obtained from the Camden County Department of Parks for the Cooper River/Kaighn Avenue Bridge ladder site in 1998.PSE&G has satisfied, indeed exceeded, the Permit conditions related to the fish ladders. Compliance with the Permit terms is documented as follows: " PSE&G established an escrow account and funded it with $500,000 on 28 October 1994 -PSE&G letter to NJDEP (28 Oct. 1994)" PSE&G completed an engineering feasibility study of candidate sites by 28 February 1995 -PSE&G letter to NJDEP (12 Feb. 1995)" PSE&G solicited access rights and/or authorizations to implement the fish ladders at the candidate sites by 25 May 1995 -PSE&G letter to NJDEP (25 May 1995)." PSE&G completed the selection of fish ladder sites in conjunction with NJDEP by 23 May 1995 -PSE&G letter to NJDEP (23 May 1995)" PSE&G submitted to NJDEP a work plan to install the fish ladders on August 30, 1995, which PSE&G letter to NJDEP (30 August 1995)" PSE&G began to implement the approved work plan within 60 days of approval -PSE&G letter to NJDEP (26 Jan. .1996)As explained in Attachment G-5, PSE&G has completed construction and begun maintenance of the five required ladders.8 49 PSE&G Rene'xsl AprIlicaton -Mtarch 190).Appendix G PSE&G's compliance with the traveling screen requirements is set out in letters to NJDEP which are attached to Exhibit G-l-1: " Completion of engineering design -PSE&G letter to New Jersey Division of Fish. Game and Wildlife (NJDFGW) (25 January 1995)." Completion of installation and operation of first unit -PSE&G letter to NJDFGW (28 July 1995)." Completion of testing of first unit -PSE&G letter to NJDFGW (28 June 1996)." Completion of installation of second unit -PSE&G letter to NJDFGW (21 February 1997).7 The BMWP was submitted to NJDEP on 25 January 1995. The BMWP was discussed by the Monitoring Advisory Committee ("MAC") at meetings of I and 15 December 1994 and its written comments were received and reviewed by PSE&G prior to submission to NJDEP. Modifications of the BMWP. after MAC review, were submitted to NJDEP on 2 May 1995, 7 March 1996. 7 May 1997. 10 August 1998. and 2 November 1998. Approvals were obtained from NJDEP for these modifications on 24 June 1998, 30 September 1998, and 4 January 1999. Meetings of the MAC on I May 1996, 20 May 1997 and 29 May 1998 were devoted to the review of data collected pursuant to the BMWP.8 As a result of extended outage of both of the Station's Units, the original thermal monitoring plan (TMP) could not be carried out and a Modified TMP was designed in 1997 to collect data in the summer and fall of 1998, when both Units were in operation. The modified plan was approved by NJDEP.9 The MPAC includes technical representatives from at least three agencies having jurisdiction over wetland restoration activities, a coastal geologist and two scientists with appropriate expertise, representatives from New Jersey's Division of Fish, Game and Wildlife and the Mosquito Control Commission, a PSE&G representative, representatives of municipalities, and representatives from Cape May, Cumberland, and Salem Counties. The PSE&G representative is designated the chair of the committee, and, under the Permit the MPAC "shall conduct business when, as, and how the MPAC so decides." The MPAC has been actively involved in the development of the Management Plans, providing in-depth technical review and advice before the Management Plans are submitted to NJDEP for approval.With the ideas contributed by the MPAC members, the Management Plans were shaped into technically sound and effective blueprints for restoration. MPAC's review of the plans and guidance to PSE&G assured that stakeholders had input to these most important framework documents 10 The fish ladders also provide other values to the public. For instance, the fish ladder off the raceway at the southern end of Sunset Lake is adjacent to the Bridgeton City Park. A city-developed nature trail is located next to the fish ladder and has been integrated with the fish ladder facility. PSE&G has developed three interpretive signs that have been placed along the city park nature trail leading to the fish ladder.One of these interpretive signs describes how the fish ladder functions and the benefits it provides to the Delaware Estuary. The fish ladder itself is available for public observation from the top of the trail. 50 G Figure 1 Gencral Sitc Location Map. _ t ,< qt d Bnw:r2%4:2

." r WtG'th 212 .24. as. 222,1 t2& 23322, Creeh in 3333-3 333 2n rrn u" 3 2w i2 '332( "342 33 24 33 ,.23 3.

I LItJrND 0 0 nat sh ~t11Ut 4apM] p arigi6rnn SWO AS ran tiarali Va> <mama>. low <a'awaO>fl> >1/2>na at 8 a> 800- '$4-8~0 ITh'mgmr'arthar> >9" 1<6-> 9' '0-4 a->" 'A'6--A "'"6 a>> <" >6-A I"">' a;>A~9' 3763 '6-A ii'-- Wta>' ttr 0 -Ita> A Ja>t >t>t>>>AS6->J>XL tin>>' '>6- 6-p>*tt<t"'tantl --PSIG;-J>'l'- -1' 6; Phraemuts Leverage at I ma Ge A We~ and Reuorargon Sii~~. -'-Lo'a>-torn 2UU1 ~ O$'r tdnwtnS rod Jnwnthipo Salem C600 p~jy 3/404 Jmr'tO "- ReSo~ati-4it i .D a S lA ,* RL ~wran.n Su'*2 '*i :53s"> .- i'> 5 i" T]i: 's "-" R'js in (O it Sie ": " ad ..qer Ails'4"PR'I% !}ei> : TIN,>i, LEGEND---SITE BOUNDARY WETLAND RESTORATION AREA BOUNDARY EXISTING SURFACE WATER FEATUREPONDED AREAS C URS Greiner Woodward Clyde O PS Comopany£ S E , i, 'G Figure 6 MAURICE RIVER TOWNSHIP SAL T HA Y FARM WETLAND RESTORATION SITE 1996 HYDROLOGIC FEATURES MAURICE RIVER TOWNSHIP CUMBERLAND COUNTY, NEW JERSEY 0000 0.01 ~09 0. SB S ~ 1200 1200 ft 0 ft 1200 iN 566m Om 366rr.DELAWARE BAY@ -,- ý- .--I'll LEGEND S1, -.SITE BOUNDARY WETLAND RESTORATION AREA BOUNDARY EXISTING SURFACE WATER FEATURE S PONDEO AREAS%0 P S K c0"pnG Figure 7 MAURICE RIVER TOWNSHJP SAL T HA Y FARM WETLAND RESTORA T/ON SITE f998 HYDROLOGIC FEATURES MAURICE RIVER TOWNSHIP CUMBERLAND COUNTY, NEW JERSEY c~~~~flO~1" -Ifl Fm~gO SAJ 0 DELAWARE BAY 1200 ft 0 ft 1200 ft 366m -Om 366m URS Greiner Woodward Clyde-Pwuc sE"m -mK I ý -1195 F FiqrL8 C 1 1 Vi I II I~.0 . (C 77 LL, F CF\ IAl r G Figure II MILL CREEK AREA -ALLOWA Y CREEK WA TERSHED WETLAND RESTORA TION SITE 1/99 HYDROLOGIC FEATURES ELSINBORO TOWNSHIPSALEM COUNTY, NEW JERSEY c000 JL Coil OCR S W R i INo CO~COCICC PuO&X cLmo & o Co D oo 0 PsIdk &ýý51 ý10=111 71, 1100 -f t 0 ft 1 100 ft 335,,, C 0 ý ý3 2 5 5 G Figure 12 MILL CREEK AREA -ALLO WAY CREEK WATERSHED WETLAND RES TORA TION SITE 1898 HYDROLOGIC FEATURES ELSINPORO TOWNSHIP SALEM COUNTY, NEW JERSEY A ~o J r~e -1 ggt c 0[URS Greiner Woodward Clyde Ja Wdl* -U Li CJ IPSIEG1 ýý. -., " ; -, , , , , , , " ý H ýý ý ", 6 ý " ýZWAi'kl telk" G Fiyuite 131 ff. .? jAP_ ,-OW Y' 3 K WAVVý Lý-V) HESTJ'?Af(A Ill"IN m, U'~ 1/24j-~5 APPENDIX G -SUPPLEMENT I SPECIAL CONDITIONS OF THE 1994 PERMIT AND SETTLEMENT WITH DNREC PSE&G PSE&G RENEWAL APPLICATION SALEM GENERATING STATION PERMIT NO. NJO005622 4 MARCH 1999 PSE&G Rdnev~al -.priiaLeno-: March N1-)Appendix G Supplement I TABLE OF CONTENTS 1. PERM IT SPECIAL CONDITIONS .......-......... ....................................... [.A Terms and Requirements Related to Conser, .tion Measures in the Estuary' 2 L.B Terms and Requirements Related to Salem's Intakes ............................... 8 I.C Terms and Requirements Related to Data Collection and Analysis ........... 10 II. SETTLEMENT AGREEMENT WITH DNREC (23 MARCH 1995) ............ 11 1 PSE&G Rene"al Aprihaton.4 March 1999 Appendix G Supplement I I. PERMIT SPECIAL CONDITIONS L.A Terms and Requirements Related to Conservation Measures in the Estuary The first category of Permit conditions relates to actions elsewhere in the Estuary which are likely to enhance aquatic populations and is made up of two requirements: the restoration and enhancement of wetlands and the elimination of impediments to fish migration. With regard to wetland restoration and preservation, Part IV-B/C, paragraph (H)(3) of the Permit sets out the following requirements:

3. Wetlands Restoration and Enhancement (a) The Permittee shall undertake a wetlands restoration and enhancement program within the region of the Delaware Estuary (primarily within New Jersey; not more than 20% of the acres restored or enhanced under the program to be located within Delaware and/or Pennsylvania.

unless the Department determines that there are not sufficient available wetlands in New Jersey to meet the requirements of this Permit) as follows: (i) restore an aggregate of no less than 8,000 acres of(l) dikedwetlands (including salt hay farms, muskrat impoundmentsand/or agricultural impoundments) to normal daily tidal inundation so as to become functional salt marsh; and/or (2) wetlands dominated by common reed (Phragmites australis) to primarily Syartin species with other naturally occurring marsh grasses (e.g. Distichl spicata Juncus Spp.). No lessthan 4,000 of the 8,000 acres required to be restored above must have been diked wetlands. The Permittee shall secure access to or control of such lands such that said lands will have title ownership or deed restriction as may be necessary to assure the continued protection of said lands from development;(ii) restore an additional 2,000 acres of wetlands as set forth in paragraph H.3. (a)(]) above and/or preserve in a state that precludes development through appropriate title ownership or Conservation Restriction of no less than 6,000 acres of uplands adjacent to Delaware Estuary tidal wetlands (" Upland Buffer"). For purposes of this paragraph

3. (a) (ii), an Upland Buffer shall mean an area of land adjacent to wetlands which 2 PSE&G Renewal A plicanon 4 MUrch 9I)t'Appendix G Supplement I minimizes adverse impacts on the wetlands and serves as an integral component ofdthe wetland ecosYstem;(iii) the acreage restored, enhanced and/or preserved pursuant to 3.(a)(i) and/or (ii) above will aggregate no less than 10,000 acres; provided, however, the Permittee only will be credited one acre toward the 10,000 acre aggregate for every three acres of Upland Buffer acquired or restricted pursuant to 3.(a)(ii) above; and (iv) all lands restored, enhanced, or preserved pursuant to paragraph

3. (a) above shall be subject to Conservation Restriction.(b) Permittee shall impose a Conservation Restriction on the approximately 4,500 acres of land in Greenwich Township, Cumberland County, commonly known as the Bayside Tract. The approximate 1,900 acres of Upland Buffer on the Bayside Tract shall be applied on a 3:1 basis toward satisfying the acreage requirement in 3.(a)(iii) above. Not later than EDP + 180 days, the Permittee shall provide the Department with evidence that thisspecial condition has been satisfied.(c) The Conservation Restriction imposed pursuant to paragraphs 3.(a) and 3.(b), shall name the Department as a Grantee of the Conservation Restriction.

The Conservation Restriction shall be in the form of Attachment A to this Permit and shall be recorded by the Permittee. Attachment A provides for the submission of the schedules which will be site specific. There shall be no liens superior to the Conservation Restriction on the lands in question (except those liens or encumbrances created by virtue of the PSE&G Corporate Mortgage dated August 1, 1924, including all amendments, to Fidelity Union Trust Company, Trustee, on lands owned by the Permittee which are subject to this Conservation Restriction), proof of which shall be provided by the Permittee through a title search and/or title insurance. The Permittee shall regularly inspect the Property and take appropriate action to prevent or correct a violation of the Conservation Restriction notwithstanding that such Violation, was by a person other than Permittee.(d) For salt hay farm lands identified in paragraph 3.(a) above, the Permittee shall: 3 PSE&G Rene~al Applh"[tron -. March 199L Appendix G Supplement I (i) not later than EDP + twelve (12) months, select and secure control of said lands through acquisition, deed restriction, termination of life estate or termination of leasehold interests;(fi) not later than EDP + trwelve (12) months or not later than ninety (90) days after securing control of said lands, whichever comes first, design and file with the Department for approval a Management Plan(s), except that no Management Plan shall be required to be submitted until sixty (60) days after a Management Plan Advisory Committee (MPAC) is established pursuant to 3.(j) below.(Provided, however, that in the event that the Permittee L secures control of a parcel of said lands but intends to secure control of a contiguous parcel(s) of said lands, the Management Plan encompassing all contiguous parcels of said land must be filed no later than EDP + (12) months).The Management Plan(s) shall include, but not be limited to, techniques by which the Permittee shall breach dikes and construct and maintain upland dikes, and implement steps to protect all roadways, property and improvements thereon located on or adjacent to said lands from damage due to flooding at both normal and high tides, and an anticipated schedule for natural revegetation; and (iii) not later than sixty (60) days after receipt of the Department's approval of the Management Plan(s), implement the Management Plan(s) as approved by the Department. The Management Plan(s) is automatically incorporated as a condition of this permit upon final approval by the Department.(e) For muskrat or agricultural impoundment lands and/or wetlands dominated by common reed as specified in paragraph 3.(a) above, the Permittee shall: (i) not later than EDP + eighteen (18) months, select and secure access and/or control of said lands;(ii) not later than EDP + eighteen (18) months, design and filewith the Department for approval a Management Plan(s).The Management Plan(s) shall include, but not be limited to: for wetlands dominated by common reed, techniques for application of herbicides and/or burning to remove dead common reed, techniques by which the Permittee shall 4 PSE&G Renewai Apphc.laijon -4 Ma.rch )WI XAppendix G Supplement I breach dikes and construct and maintain upland dikes, and implement steps to protect all roadways, property" and improvements thereon located on or adjacent to said lands from damage due to flooding at both normal and high tides, and an anticipated schedule for natural revegetation; and for muskrat or agricultural impoundments, techniques for restoration of tidal flow, techniques by which the Permittee shall breach dikes and construct and maintain upland dikes, and implement steps to protect all roadways, property and improvements thereon located on or adjacent to said lands from damage due to flooding at both normal and high tides, and an anticipated schedule for natural revegetation; and (iii) not later than sixty (60) days after receipt of the Department's approval of the Management Plan(s), implement the Management Plan(s) as approved by the Department. The Management Plan(s) is automatically incorporated as a condition of this permit upon final approval by the Department.(f) For lands described in 3.(a)(ii) above, the Permittee shall: (i) not later than EDP + eighteen (18) months, select and secure access and/or control of said lands;(ii) not later than EDP + eighteen (18) months, design and file with the Department for approval a Management Plan(s)for such lands; and (iii) not later than sixty (60) days after receipt of the Department's approval of the Management Plan(s), implement the Management Plan(s) as approved by the Department. The Management Plan(s) is automatically incorporated as a condition of this permit upon final approval by the Department.(g) For the lands described in 3.(b) above, the Permittee shall: (i) not later than EDP + six (6) months, design and file with the Department for approval a Management Plan for these lands, except that no Management Plan shall be requiredto be submitted until sixty (60) days after a Management Plan Advisory Committee (MPAC) is established pursuant to 3.(j) below; and 85 PSE&G Rcne" .'.l Apphiacanon4 Nlirc~m -"Q9 Appendix G Supplement 1 (ii) not later than sixty (60) days after receipt of the Department's approval of the Management Plan. implement the Management Plan as approved by the Department. The Management Plan(s) is automatically incorporated as a condition of this permit upon final approval by the Department.(h) No later than EDP + sixty (60) months, complete implementation of the Management Plans specified in paragraphs (d), (e), (f)and/or (g). However, the Permittee must continue to implement the Management Plan(s) with respect to maintenance during any period of time the permit is extended pursuant to N.J.A.C. 7:14A-2.3.(i) The Permittee shall be deemed to have complied with the requirements of Special Condition H.3. upon completion of the Department-approved Management Plans.(j) Not later than EDP + sixty (60) days, the Permittee shall establish a Management Plan Advisory Committee (MPAC). The Permittee shall request, subject to the Department's approval, at least three agencies having jurisdiction over wetland restoration activities to provide a technical representative to serve on the MPAC. The Permittee shall request, subject to the Department's approval, a coastal geologist and two scientists with appropriate expertise, to serve on the MPAC. The Department and shall also designate a representative from its Division of Fish, Game and Wildlife and its Mosquito Control Commission to serve on the MPAC. The Permittee shall also designate a representative to serve on the MPAC. The Permittee shall also request, subject to the Department's approval, the governments of Cape May, Cumberland, and Salem Counties to appoint a representative(s) to serve on the MPA C.The MPAC will serve as a body to provide technical advice to the Permittee concerning the development and implementation of the Management Plans identified in this Section 3. Management Plans must be submitted to the MPAC for technical advice prior to submission to the Department for approval. Contemporaneouswith the submission of a Management Plan to the Department, the Permittee shall provide copies of said Plan to the County Library in the affected County. The Permittee shall cause to be published in a daily or weekly newspaper circulated in the affected County a 6 PSE&G RenevIl Applica2in 4 Mach N'99 Appendix 6 Supplement public notice advising of the time and place that the Management Plan is available for review.MPAC shall be chaired by the Permittee's representative. The MPAC shall conduct business when, as, and how the MPAC so decides.With regard to eliminating impediments to fish migration, Part IV-B/C, paragraph (H)(4) of the Permit sets out the following requirements:

4. Elimination of Impediments to Fish Migration (a) The Permittee shall construct and maintain five fish ladders. The Permittee shall fund an escrow account in an amount of $500,000 within EDP + sixty (60) days. The monies in the escrow account will be used exclusively for a program to eliminate impediments for fish migration in accordance with the provisions of this Special Condition H.4. (Fish Migration Project) (the Permittee's obligations under this Special Condition H.4.(b), (c), and (d) are subject to the amount of monies deposited in the Escrow Account;provided, however, that with respect to the $500,000, at least$425,000 must be used exclusively to fund construction and maintenance of the fish ladders and not more than $75,000 can beused to fund engineering designs).(b) In connection with the Fish Migration Project, the Permittee shall: (i) not later than EDP + six (6) months, complete an engineering feasibility study of not less than five candidate sites which will be selected based on a site selection study conducted on consultation with the Department;(ii) not later than EDP + nine (9) months, solicit access rights and/or necessary authorizations with respect to the implementation of the Fish Migration Project at the candidate sites; and (iii) not later than EDP + nine (9) months, complete site selection(s) in consultation with the Department.(c) For those sites selected for implementation in the Fish Migration Project, and in consultation with the Department the Permittee shall: 7 PSE&G Renewal Apphcation

-March 1999 Appendix Cj Supplement I (i) not later than EDP + twelve (12) months, complete an engineering design and submit a Work Plan which will include at a minimum a schedule for installation offish ladders for Department approval;(ii) not later than sixt-v (60) days after receipt of the Department's approval of the Work Plan, implement the Department-approved Work Plan in accordance with the schedule approved by the Department;(iii) not later than EDP + sixty (60) months, complete implementation of the Work Plan; and (iv) the Work Plan is automatically incorporated as a condition of this permit upon final approval by the Department.(d) From those sites at which fish ladders are installed, the Permittee shall conduct operational and maintenance activities during the term of the permit and during any period of time the permit is extended pursuant to N.J.A.C. 7.14A 2.3.I.B Terms and Requirements Related to Salem's Intakes The second category of Permit requirements directly related to aquatic biota at theSalem intakes is made up of two special conditions: upgrading the screens at theintake and conducting a study of whether sound would be a feasible and effective technology at Salem to deter aquatic biota from the plant's intake screens. As to intake screen modifications the Part IV-B/C, paragraph (H)(2) of the Permit set out the following requirements:Intake Screen Modifications (a) The Permittee shall implement modifications to the circulating water system intake traveling screens to incorporate a new fish bucket design including without limitation: an extended lip which bends inward toward the screen face at the top based on the fish bucket design to prevent fish escape; smooth woven mesh screen having rectangular pore openings; 30 inch wide fish sluice providing an approximate 3 inch depth of water (Intake Screen Modifications);(b) The Permittee shall: (i) not later than EDP + six (6) months, complete the engineering design for the Intake Screen Modifications; 8 PSE&G Renc'.,a Application 4, March Appendix G Supplement I (ii) not later than EDP + fourteen (14) months, complete installation and initiate operation of the Intake Screen Modifications to the first unit to be modified: (iii) not later than EDP -P twenty-tvo (22) months, complete operability testing of the first unit's Intake Screen Modifications including without limitation, study of best placement of inside and outside high pressure and low pressure fish sprays; and study of combining or separating fish return and debris water systems high pressure provided, however, that the operability testing shall be conducted during the months May through September;(iv) not later than EDP + thirty (30) months, incorporate any necessary changes into the design for the second unit's intake screens and complete installation and initiate operation of the Intake Screen Modifications as specified in 2.(a) and (b) (iii)above to the second unit to be modified's screens; and (v) not later than EDP + thirty-six (36) months or the conclusion of the next regularly scheduled refueling outage for the first unit which was modified, whichever is later, complete installation and initiate operation of any necessary changes in the engineering design identified as a result of the operability testing described in 2. (b) (iii) above to the first unit's intake screens.As to studying the feasibility of using sound to reduce the number of fish impinged at the Salem intakes, Part IV-B/C, paragraph (H)(5) of the Permit sets out the following requirement:

5. Sound Deterrent Feasibility Study The Permittee shall: (a) not later than EDP + twelve (12) months, submit a Plan of Study to the Department for approval to assess the feasibility of deterring fish from the area in front of the CWS intake structure through the use of underwater speakers or sound projectors (such Study shall also assess the potential detrimental effects on fish species in the Delaware Estuary);(b) not later than sixty (60) days after receipt of the Department's approval of the Plan of Study, implement the Plan of Study in accordance with the schedule approved by the Department subject to species availability; and 31 9 PSE&G Rcne,,I -\ppihcanon 4 March 1990 Appendix G Supplement (c) not later than EDP + fifty-four (54) months, complete the Plan of Study and file a report of the results to the Department in accordance with the schedule approved bY the Department.

I.C Terms and Requirements Related to Data Collection and Analysis The third category of special conditions is data collection or monitoring set out in the provision as follows: 6. Biological Monitoring The Permittee shall: (a) develop and implement a biological monitoring program for the Delaware Estuary. The biological monitoring program shall include comprehensive thermal monitoring and performance of a biothermal assessment on the RIS, bay-wide abundance monitoring, impingement and entrainment monitoring, abundance monitoring for ichthyoplankton and juvenile blueback herring and alewife in connection with fish ladder sites, detritus production monitoring, andresidual pesticide release monitoring (in salt hay impoundments) and such other special monitoring studies including effects of sound deterrents as may be required by the Department.(b) not later than EDP + sixty (60) days, the Permittee shall establish a Monitoring Advisory Committee (MAC). The Permittee shall request, subject to the Department's approval, at least three resource agencies having expertise in the aquatic resources of the Delaware Estuary to provide a representative to serve on the Committee. In addition, the Permittee shall request, subject to the Department's approval, at least three scientists having similar expertise to serve on the MAC. The Department shall designate representatives from its Division of Fish, Game and Wildlife and its Mosquito Control Commission to serve on the MAC. The Permittee shall also designate a representative to serve on the MAC.(c) the MAC will serve as a body to provide technical advice to the Permittee concerning the following: (i) design of the Biological Monitoring Program;(ii) implementation of the Biological Monitoring Program;10 PSE&G Rznexal .Arplicatu n l \Iarch 11Q1)9 Appendix G Supplement I (iii) modifications to the Biological Monitoring Program: and (iv) interpretation of the Biological Monitoring Program results.(d) the MAC shall be chaired by the Permittee's representative. The MAC shall conduct business when, as, and how the MAC decides.(e) The Biological Monitoring Program Work Plan shall be submitted to the MAC for technical advice prior to submission of the Work Plan to the Department for approval.(t) not later than EDP + one hundred fifty (150) days, the Permittee shall submit to the Department for approval a Biological Monitoring Program Work Plan (Work Plan) (which will include a reporting schedule). Contemporaneous with the submission of a Work Plan to the Department, the Permittee shall provide copies of said Work Plan to the County Library in Salem, Cape May, and Cumberland Counties.In addition, the Permittee shall cause to be published in a daily or weekly newspaper circulated in the general area a public notice advising of the, time and place that the Monitoring Program is available for review.(g) not later than sixty (60) days after receipt of the Department's approval of the Work Plan, the Permittee shall implement the Work Plan. The Biological Monitoring Program Work Plan is automatically incorporated as a condition of this permit upon final approval by the Department.(h) the Permittee shall submit to the Department the Biological Monitoring Program results in accordance with the schedule specified in the Work Plan. Contemporaneous with submission of said results to the Department, the Permittee shall forward the results to each member of the MAC for technical review. Any proposed modifications to the Work Plan (as may be necessary based on Biological Monitoring Program results) shall be submitted to the MAC for technical review prior to submission to the Department for the Department's approval. Settlement Agreement with DNREC (March 23, 1995)II. SETTLEMENT AGREEMENT WITH DNREC (23 MARCH 1995)The principal terms of the DNREC settlement agreement are that PSE&G would establish an interest bearing escrow fund and fund it with $10,575,000 in accordance with an agreed-upon schedule to allow DNREC to undertake the following activities: PSE&G Renewal Application 4 March 199W Appendix G Supplement I" Restoration and maintenance in, accordance with the Permit of at least 2.000 acres of degraded wetlands along Delaware Bay/River that were either diked wetlands or publicly-owned wetlands dominated byPhragmiies:

• Restoration, not according to Permit protocols.

of approximately 1,000 acres of diked or impounded wetlands along Delaware Bay/River;

• Restoration, under DNREC protocols for Phragmnites control, of at least 3.000 acres of publicly-owned and/or privately owned wetlands dominated by Phragmites;" Acquisition and/or preservation of approximately 2,000 acres of upland buffers along Delaware Bay/River; i Site selection, engineering and construction of three fish ladders in the State of Delaware, in accordance with the terms and conditions of the Permit;" Funding of construction of artificial reefs in Delaware Bay;" Review of the operation of the intake structure at Salem to determine whether there is a problem with fish entanglement in marsh grasses or other debris on the intake screen as argued by Dr. Ian Fletcher in a report entitled "FurtherComments on the Proposed Alterations of the Intake Screening System at the Salem Nuclear Station" dated November 20, 1994 and prepare a response to this report; and" Funding, upon renewal of the Permit, of a consultant for NJDEP if the agency chooses to assess the Technology Evaluation submitted by PSE&G pursuant to Section 316(b) of the Clean Water Act.PSE&G filled its central obligation under the DNREC settlement by establishing the escrow in June 1995 and funding it in accordance with the escrow schedule.12 PSE&G Acclicawcn March 19Q9 Appendix G Supplement I TABLE OF CONTENTS I. PERM IT SPECIAL CONDITIONS

.............................................................. 2 I.A Terms and Requirements Related to Conservation Measures in the Estuary 2 L.B Terms and Requirements Related to Salem's Intakes .................... 8 I.C Terms and Requirements Related to Data Collection and Analysis ........... 10 II. SETTLEMENT AGREEMENT WITH DNREC (23 MARCH 1995) ............ 11 13 PSE&G Renewal Applicarion -Muarch 1999 I. PERMIT SPECIAL CONDITIONS A~pendix G supplement I L.A Terms and Requirements Related to Conservation Measures in the Estuary The first category of Permit conditions relates to actions elsewhere in the Estuary which are likely to enhance aquatic populations and is made up of two requirements: the restoration and enhancement of wetlands and the elimination of impediments to fish migration. With regard to wetland restoration and preservation. Part IV-B/C, paragraph (H)(3) of the Permit sets out the following requirements:

3. Wetlands Restoration and Enhancement (a) The Permittee shall undertake a wetlands restoration and enhancement program within the region of the Delaware Estuary (primarily within New Jersey; not more than 20% of the acres restored or enhanced under the program to be located within Delaware and/or Pennsylvania.

unless the Department determines that there are not sufficient available wetlands in New Jersey to meet the requirements of this Permit) as follows: (i) restore an aggregate of no less than 8,000 acres of(1) diked wetlands (including salt hay farms, muskrat impoundments and/or agricultural impoundments) to normal daily tidal inundation so as to become functional salt marsh; and/or (2) wetlands dominated by common reed (Phragmites australis) to primarily Sparring species with other naturally occurring marsh grasses (e.g. Distichli spicata Juncus sWpp.). No less than 4,000 of the 8,000 acres required to be restored above must have been diked wetlands. The Permittee shall secure access to or control of such lands such that said lands will have title ownership or deed restriction as may be necessary to assure the continued protection of said lands from development;(H) restore an additional 2,000 acres of wetlands as set forth in paragraph H.3. (a)(1) above and/or preserve in a state that precludes development through appropriate title ownership or Conservation Restriction of no less than 6,000 acres of uplands adjacent to Delaware Estuary tidal wetlands ("Upland Buffer"). For purposes of this paragraph 3.(a) (ii), an Upland Buffer shall mean an area of land adjacent to wetlands which 14 PSE&G Reneal .-ApIicaucon ..March 199q Appendix G Supplement I minimizes adverse impacts on the wetlands and serves as an integral component of the wetland ecosystem: (i'i) the acreage restored, enhanced and/or preserv.ed pursuant to 3.(a)(i) and/or (ii) above will aggregate no less than 10,000 acres; provided, however, the Permittee only will be credited one acre toward the 10,000 acre aggregate for every three acres of Upland Buffer acquired or restricted pursuant to3.(a)(ii) above; and (iv) all lands restored. enhanced, or preserved pursuant to paragraph

3. (a) above shall be subject to Conservation Restriction.(b) Permittee shall impose a Conservation Restriction on the approximately 4,500 acres of land in Greenwich Township, Cumberland County, commonly known as the Bayside Tract. The approximate 1,900 acres of Upland Buffer on the Bayside Tract shall be applied on a 3:1 basis toward satisfying the acreage requirement in 3.(a)(iii) above. Not later than EDP + 180 days, the Permittee shall provide the Department with evidence that this special condition has been satisfied.(c) The Conservation Restriction imposedpursuant to paragraphs

3. (a) and 3. (b), shall name the Department as a Grantee of the Conservation Restriction.

The Conservation Restriction shall be in the form of Attachment A to this Permit and shall be recorded by the Permittee. Attachment A provides for the submission of the schedules which will be site specific. There shall be no liens superior to the Conservation Restriction on the lands in question (except those liens or encumbrances created by virtue of the PSE&G Corporate Mortgage dated August 1, 1924, including all amendments, to Fidelity Union Trust Company, Trustee, on lands owned by the Permittee which are subject to this Conservation Restriction), proof of which shall be provided by the Permittee through a title search and/or title insurance. The Permittee shall regularly inspect the Property and take appropriate action to prevent or correct a violation of the Conservation Restriction notwithstanding that such violation was by a person other than Permittee.(d) For salt hay farm lands identified in paragraph 3.(a) above, the Permittee shall: 15 PSE&G Renewai Apphcatjon %Ialrsh 1999 Appendix G Supplement I (i) not later than EDP + twelve (12) months, select and secure control of said lands through acquisition. deed restriction. termination of life estate or termination of leasehold interests.(ii) not later than EDP + twelve (12) months or not later than ninet (90) days after securing control of said lands, whichever comes first, design and file with the Department for approval a Management Plan(s), except that no Management Plan shall be required to be submitted until sixty (60) days after a Management Plan Advisory Committee (MPAC) is established pursuant to 3. (j) below.(Provided, however, that in the event that the Permittee secures control of a parcel of said lands but intends to secure control of a contiguous parcel(s) of said lands, the Management Plan encompassing all contiguous parcels of said land must be filed no later than EDP + (12) months).The Management Plan(s) shall include, but not be limited to, techniques by which the Permittee shall breach dikes and construct and maintain upland dikes, and implement steps to protect all roadways, property and improvements thereon located on or adjacent. to said lands from damage due to flooding at both normal and high tides, and an anticipated schedule for natural revegetation; and (iii) not later than sixty (60) days after receipt of the Department's approval of the Management Plan(s), implement the Management Plan(s) as approved by the Department. The Management Plan(s) is automatically incorporated as a condition of this permit upon final approval by the Department.(e) For muskrat or agricultural impoundment lands and/or wetlands dominated by common reed as specified in paragraph 3.(a) above, the Permittee shall: (i) not later than EDP + eighteen (18) months, select and secure access and/or control of said lands;(ii) not later than EDP + eighteen (18) months, design and file with the Department for approval a Management Plan(s).The Management Plan(s) shall include, but not be limited to: for wetlands dominated by common reed, techniques for application of herbicides and/or burning to remove dead common reed, techniques by which the Permittee shall 16 PSE&G Renewal A. pic-tcon 4 March 1999 Appendix G Supplement I breach dikes and construct and maintain upland dikes, and implement steps to protect all roadways, properry and improvements thereon located on or adjacent to said lands from damage due to flooding at both normal and high tides, and. an anticipated schedule for natural revegetation; and for muskrat or agricultural impoundments, techniques for restoration of tidalflow, techniques by which thePermittee shall breach dikes and construct and maintain upland dikes, and implement steps to protect all roadways, property and improvements thereon located on or adjacent to said lands from damage due to flooding at both normal and high tides, and an anticipated schedule for natural revegetation; and (iii) not later than sixty (60) days after receipt of the Department's approval of the Management Plan(s), implement the Management Plan(s) as approved by the Department. The Management Plan(s) is automatically incorporated as a condition of this permit upon final approval by the Department.(f) For lands described in 3.(a)(ii) above, the Permittee shall: (i) not later than EDP + eighteen (18) months, select and secure access and/or control of said lands;(ii) not later than EDP + eighteen (18) months, design and file with the Department for approval a Management Plan(s)for such lands; and (ifi) not later than sixty (60) days after receipt of the Department's approval of the Management Plan(s), implement the Management Plan(s) as approved by the Department. The Management Plan(s) is automatically incorporated as a condition of this permit upon final approval by the Department.(g) For the lands described in 3.(b) above, the Permittee shall: (i) not later than EDP + six (6) months, design and file with the Department for approval a Management Plan for these lands, except that no Management Plan shall be required to be submitted until sixty (60) days after a Management Plan Advisory Committee (MPAC) is established pursuant to 3.(j) below; and 17 PSE&G Renewal Applicauon

4. March 1999 Appendix G Supplement I (ii) not later than sixnv (60) days after receipt of the Department's approval of the Management Plan, implement the Management Plan as approved by the Department.

The Management Plan(s) is automatically incorporated as a condition of this permit upon final approval by the Department.(h) No later than EDP + sixt (60) months, complete implementation of the Management Plans specified in paragraphs (d), (e), (f)and/or (g). However, the Permittee must continue to implement the Management Plan(s) with respect to maintenance during any period of time the permit is extended pursuant to N.J.A.C. 7:14A-2.3.(i) The Permittee shall be deemed to have complied with the requirements of Special Condition H.3. upon completion of the Department-approved Management Plans.(j) Not later than EDP + sixty (60) days, the Permittee shall establish a Management Plan Advisory Committee (MPAC). The Permittee shall request, subject to the Department's approval, at least three agencies having jurisdiction over wetland restoration activities to provide a technical representative to serve on the MPAC. ThePermittee shall request, subject to the Department's approval, a coastal geologist and two scientists with appropriate expertise, to serve on the MPAC. The Department and shall also designate a representative from its Division of Fish,- Game and Wildlife and its Mosquito Control Commission to serve on the MPAC. ThePermittee shall also designate a representative to serve on the MPAC. The Permittee shall also request, subject to the Department's approval, the governments of Cape May, Cumberland, and Salem Counties to appoint a representative(s) to serve on the MPAC.The MPAC will serve as a body to provide technical advice to the Permittee concerning the development and implementation of the Management Plans identified in this Section 3. Management Plans must be submitted to the MPAC for technical advice prior to submission to the Department for approval. Contemporaneous with the submission of a Management Plan to the Department, the Permittee shall provide copies of said Plan to the County Library in the affected County. The Permittee shall cause to be published in a daily or weekly newspaper circulated in the affected County a 18 PSE&G Rene'al Application 4 NIarch 1999 Appendix G Supplement I public notice advising of the time and place that the Management Plan is available for review.MPAC shall be chaired by the Permittee's representative. The MPAC shall conduct business when, as, and how the MPAC so decides.With regard to eliminating impediments to fish migration, Part IV-B/C. paragraph (H)(4) of the Permit sets out the following requirements:

4. Elimination of Impediments to Fish Migration (a) The Permittee shall construct and maintain five fish ladders. The Permittee shall fund an escrow account in an amount of $500,000 within EDP + sixty (60) days. The monies in the escrow account will be used exclusively for a program to eliminate impediments for fish migration in accordance with the provisions of this Special Condition H.4. (Fish Migration Project) (the Permittee'sobligations under this Special Condition H.4.(b), (c), and (d) are subject to the amount of monies deposited in the Escrow Account;provided, however, that with respect to the $500,000, at least$425,000 must be used exclusively to fund construction and maintenance of the fish ladders and not more than $75,000 can be used to fund engineering designs).(b) In connection with the Fish Migration Project, the Permittee shall: (i) not later than EDP + six (6) months, complete an engineering feasibility study of not less than five candidate sites which will be selected based on a site selection study conducted on consultation with the Department;(ii) not later than EDP + nine (9) months, solicit access rights and/or necessary authorizations with respect to the implementation of the Fish Migration Project at the candidate sites; and (iii) not later than EDP + nine (9) months, complete site selection(s) in consultation with the Department.(c) For those sites selected for implementation in the Fish Migration Project, and in consultation with the Department the Permittee shall: 19 PSE&G Renewal ApN1iiazion

-'Maruch 1999 Appendix G Supplement I (i) not later than EDP + twelve (12) months, complete an engineering design and submit a Work Plan which will include at a minimum a schedule for installation offish ladders for Department approval;(ii) not later than sixty (60) days after receipt of the Department's approval of the Work Plan, implement the Department-approved Work Plan in accordance with the schedule approved by the Department;(iii) not later than EDP + sixty (60) months, complete implementation of the Work Plan; and (iv) the Work Plan is automatically incorporated as a condition of this permit upon final approval by the Department.(d) From those sites at which fish ladders are installed, the Permittee shall conduct operational and maintenance activities during the term of the permit and during any period of time the permit is extended pursuant to N.J.A.C. 7.14A 2.3.I.B Terms and Requirements Related to Salem's Intakes The second category of Permit requirements directly related to aquatic biota at the Salem intakes is made up of two special conditions: upgrading the screens at the intake and conducting a study of whether sound would be a feasible and effective technology at Salem to deter aquatic biota from the plant's intake screens. As to intake screen modifications the Part IV-B/C, paragraph (H)(2) of the Permit set out the following requirements: Intake Screen Modifications (a) The Permittee shall implement modifications to the circulating water system intake traveling screens to incorporate a new fish bucket design including without limitation: an extended lip which bends inward toward the screen face at the top based on the fish bucket design to prevent fish escape; smooth woven mesh screen having rectangular pore openings; 30 inch wide fish sluice providing an approximate 3 inch depth of water (Intake Screen Modifications);(b) The Permittee shall: (i) not later than EDP + six (6) months, complete the engineering design for the Intake Screen Modifications; 20 PSE&G Renewal Apohcatwon -March 1999 Appendix G Supplemecn I (ii) not later than EDP + fourteen (14) months, complete installation and initiate operation of the Intake Screen Modifications to the first unit to be modified;(iii) not later than EDP + twenty-two (22) months, complete operability testing of the first unit's Intake Screen Modifications including without limitation, study of best placement of inside and outside high pressure and low pressure fish sprays, and study of combining or separating fish return and debris water systems high pressure provided, however, that the operability testing shall be conducted during the months May through September;(iv) not later than EDP + thirty (30) months, incorporate any necessary changes into the design for the second'unit's intake screens and complete installation and initiate operation of the Intake Screen Modifications as specified in 2. (a) and (b) (iii)above to the second unit to be modified's screens; and (v) not later than EDP + thirty-six (36) months or the conclusion of the next regularly scheduled refueling outage for the first unit which was modified, whichever is later, complete installation and initiate operation of any necessary changes in the engineering design identified as a result of the operability testing described in 2. (b) (iii) above to the first unit's intake screens.As to studying the feasibility of using sound to reduce the number of fish impinged at the Salem intakes, Part IV-B/C, paragraph (H)(5) of the Permit sets out the following requirement:

5. Sound Deterrent Feasibility Study The Permittee shall: (a) not later than EDP + twelve (12) months, submit a Plan of Study to the Department for approval to assess the feasibility of deterring fish from the area in front of the CWS intake structure through the use of underwater speakers or sound projectors (such Study shall also assess the potential detrimental effects on fish species in the Delaware Estuary);(b) not later than sixty (60) days after receipt of the Department's approval of the Plan of Study, implement the Plan of Study in accordance with the schedule approved by the Department subject to species availability; and 21 PSE&G Renewal Applicanon 4 larch 1999 Appendix G Supplement I (c) not later than EDP + fifty-four (54) months, complete the Plan of Study and file a report of the results to the Department in accordance with the schedule approved by the Department.

I.C Terms and Requirements Related to Data Collection and Analysis The third category of special conditions is data collection or monitoring set out in the provision as follows: 6. Biological Monitoring The Permittee shall: (a) develop and implement a biological monitoring program for theDelaware Estuary. The biological monitoring program shall include comprehensive thermal monitoring and performance of a biothermal assessment on the RIS, bay-wide abundance monitoring, impingement and entrainment monitoring, abundance monitoring for ichthyoplankton and juvenile blueback herring and alewife in connection with fish ladder sites, detritus production monitoring, and residual pesticide release monitoring (in salt hay impoundments) and such other special monitoring studies including effects of sound deterrents as may be required by the Department.(b) not later than EDP + sixty (60) days, the Permittee shall establish a Monitoring Advisory Committee (MAC). The Permittee shall request, subject to the Department's approval, at least three resource agencies having expertise in the aquatic resources of the Delaware Estuary to provide a representative to serve on the Committee. In addition, the Permittee shall request, subject to the Department's approval, at least three scientists having similar expertise to serve on the MAC. The Department shall designate representatives from its Division of Fish, Game and Wildlife and its Mosquito Control Commission to serve on the MAC. The Permittee shall also designate a representative to serve on the MAC.(c) the MAC will serve as a body to provide technical advice to the Permittee concerning the following: (i) design of the Biological Monitoring Program;(ii) implementation of the Biological Monitoring Program;22 ?SE&G Renewal Application 4 March 1999 Appendix G Supplement I (iii) modifications to the Biological Monitoring Program; and (iv) interpretation of the Biological Monitoring Program results.(d) the MAC shall be chaired by the Permittee's representative. The MAC shall conduct business when, as, and how the MAC decides.(e) The Biological Monitoring Program Work Plan shall be submitted tothe MAC for technical advice prior to submission of the Work Plan to the Department for approval.(f) not later than EDP + one hundred fifty (150) days, the Permittee shall submit to the Department for approval a Biological Monitoring Program Work Plan (Work Plan) (which will include a reporting schedule). Contemporaneous with the submission of a Work Plan to the Department, the Permittee shall provide copies of said Work Plan to the County Library in Salem, Cape May, and Cumberland Counties. In addition, the Permittee shall cause to be published in a daily or weekly newspaper circulated in the general area a public notice advising of the time and place that the Monitoring Program is available for review.(g) not later than sixty (60) days after receipt of the Department's approval of the Work Plan, the Permittee shall implement the Work Plan. The Biological Monitoring Program Work Plan is automatically incorporated as a condition of this permit upon final approval by the Department.(h) the Permittee shall submit to the Department the Biological Monitoring Program results in accordance with the schedule specified in the Work Plan. Contemporaneous with submission of said results to the Department, the Permittee shallforward the results to each member of the MAC for technical review. Any proposed modifications to the Work Plan (as may be necessary based on Biological Monitoring Program results) shall be submitted to the MAC for technical review prior to submission to the Department for the Department's approval. Settlement Agreement with DNREC (March23, 1995)IU. SETTLEMENT AGREEMENT WITH DNREC (23 MARCH 1995)The 'principal terms of the DNREC settlement agreement are that PSE&G would establish an interest bearing escrow fund and fund it with $10,575,000 in accordance with an agreed-upon schedule to allow DNREC to undertake the following activities: 3 23 PSE&G Renewal Ar.plicationMaxch 1999 Appendix G Supplement I Restoration and maintenance in accordance with the Permit of at least 2.000 acres of degraded wetlands along Delaware Bay/River that were either diked wetlands or publicly-owned wetlands dominated byPhragmites;

• Restoration, not according to Permit protocols, of approximately 1,000 acres of diked or impounded wetlands along Delaware Bay/River;
• Restoration, under DNREC protocols for Phragmites control, of at least 3.000 acres of publicly-owned and/or privately owned wetlands dominated by Phragmites;
• Acquisition and/or preservation of approximately 2,000 acres of upland buffers along Delaware Bay/River;
• Site selection, engineering and construction of three fish ladders in the State of Delaware, in accordance with the terms and conditions of the Permit;" Funding of construction of artificial reefs in Delaware Bay;" Review of the operation of the intake structure at Salem to determine whether there is a problem with fish entanglement in marsh grasses or other debris on the intake screen as argued by Dr. Ian Fletcher in a report entitled "Further Comments on the Proposed Alterations of the Intake Screening System at theSalem Nuclear Station" dated November 20, 1994 and prepare a response to this report; and* Funding, upon renewal of the Permit, of a consultant for NJDEP if the agency chooses to assess the Technology Evaluation submitted by PSE&G pursuant to Section 316(b) of the Clean Water Act.PSE&G filled its central obligation under the DNREC settlement by establishing the escrow in June 1995 and funding it in accordance with the escrow schedule.

24 Salem/ Hope Creek Environmental Audit -Post-Audit Information ' Question #: ENV-102 Category: Ecology Statement of Question: Please provide the following documents that were made available during the Salem and HCGS License Renewal Environmental Audit.Copy of Ecosystem Restoration Program Presentation 3/10/10 Response: The document requested is being provided. List Attachments Provided: PSEG. "PSEG's Estuary Enhancement Program Increases Delaware Estuary Production." Handout of slides presented to NRC License Renewal Environmental Review Team. March 10, 2010.0 PSEG's Estuary Enhancement Program Increases Delaware Estuary Pro Program Scope Upgraded fish protection technology at Salem Station's cooling water intake to increase fish survival.Restoration, enhancement and/or preservation of more than 20,000 acres of degraded salt marsh &adjacent uplands in the Delaware Estuary.Construction of 14 fish ladders to enhance river herring migration. An extensive biological monitoring program forassessing fish abundance and overall program success.Studies to investigate underwater technologies with potential for diverting fish from Salem Station's intake area.Support for artificial reef programs in NJ and DE, habitat restoration, scientific research related tosalt marshes and salt marsh ecology, and environmental education programs.2 1 Fish Protection Technologies" Improvements made to Salem'sintake screens in 1995 have increased fish survival -demonstrating success in reducing impacts and returning a greater number of fish to theriver unharmed." Studies of sound deterrent technology were also conducted to assess the use of sound to deter fish from entering the intake area.3 Salem Cooling Water Intake Structure Fish Entrainment Sampling Pump Ra Circulating Watr Pump Fish enter the CWIS from the river. Large fish swim away from the intake Nwad.2 Salem Circulating Water Traveling ScreensScreen Wash Fish Bucket IL Fish SlicleScreen Travel "IWater Flow Vertical traveling screen being lifted istoplace at cooling water intake structure Traveling Screen -Fish Bucket Improvements o a 0 o ___o a 00b od 5.oo 0. 0 o 0. .0 0 ~0 0 0 0 o .=0 0 0 °°l o 0 ' o IMPINGEMENT ENTRAINMENT S 3 Traveling Screen -Fish Bucket Improvements c~ 3STALLED FLUID£CACN MCX c~ Q(C-'L.U.C FLUID Figure 4 -Illustration of Flow Streams with Old Basket and New Basket 7 Wetland Restoration

• NJDEP, DNREC, & PSEGhave been working in conjunction to preserve &restore coastal wetlands along Bayshore* Partnership has protected and/or preserved

>21,500 acres of coastal marsh &adjacent uplands since 1994* >10,500 acres newly preserved* >11,000 acres of coastal marsh preserved & restored 8 4 Area Protected or Restored by PSEG's EEP TABLE i. Area PNotoded w Rostarod by PSEGs Esluary ErBoi~earontoo Progrvml (.9105) typo A *oRM04 0..10 A- Upoldlv 8A0. 0100% L-d. 7014 Amt 0M80 Salt 147 Ftfl.- 1MRliof C -O1001 700040, 00,00.000 000 2.0 220 on .,171-flori T.o-o,0p 0.006 51. 5015 ;94 '576 M1uf. R- 1 tipRto44l0ldlo50rSd 1,135 ¶08 ¶53 wm00,0 Mn.2 Y Pfa9% lo -8406.0001170%44 M pC~ook 004101480 040 1801 15351 144 508 CoMhoo0MIR.41s410.iixSol, 410 146 0 IASS 0.4.0. Phr.9"wll... .ot~oold Cd.0ospOMrO St. 18663 0 7 1,470 no0 R0om 00,1084164

2. 139 0 0 720 4W4004 how Brlnoy lId. 02*.2 0 1.822 2,002 '1AG H"0110 if'IlA Lm0 0 M3 0 200 M4M1. VIUlA 14,40 0 021 0 521 N- .0.0.WMAIAAl0 0 300 0 300 D.-Is M7A AI-ft 0 114 0 114 D440.100w..

lUnd. iotg T~oo R0.1.80.Soo 025 0 to 20250.01 Ronm RFt.1tn Silo 300 1 2 312 wo444140 00020 01042so.l 1,177 0 7 ¶184 40*840007924 0 0 1.152 ¶A620RAN0 TOTAL 11.247 4.928 5,4892 21.6441 9Wetland Degradation in Delaware Estuary* Historical diking and impoundments -Agricultural impoundments -Salt hay farming-Waterfowl impoundments

• Colonization by invasive species -Phragmites

-Elevates the marsh plain by accumulation of un-decomposed leaf litter and sediment deposition -Elimination of small tidal drainage channels (microtopographic relief)-Reduces or eliminates access to the marsh for much of the aquatic food web, including forage fish and invertebrates that serve as trophic support* Shoreline erosion* Development on adjacent uplands and in tributary headwaters

• Historical ditching for mosquito control" Sea level rise II 0 5
• Diked Salt Hay Farm* Phragmites Invasion I I Phragmites Invasion 12 6 Wetland Restoration" Returns full ecosystem function to Delaware Bayshore" Expands habitat &food sources for fish and wildlife* Increases biodiversity" Protects natural &historic resources 13Wetland Restoration Process* Site Characterization

-Biological inventory-Vegetative and wetland mapping-Groundwater investigations -Sediment sampling-Detailed topography" Engineering Design* Environmental Impact Statements

• Permit Applications 14 7 Diked Salt Hay Farm Restoration 15 Diked Salt Hay Farm Restoration Design Issues-Wetting and drying cycles-Erosion and sedimentation

-Breach/inlet stability -Subsidence-Local flooding-Saltwater intrusion-Phragmites control-Threatened and endangered species 16 8 Diked Salt Hay Farm Restoration Design solutions-Evaluated geomorphology of nearby natural channel systems todevelop concepts or new channel layouts -Performed hydrodynamic modeling of inundation and drainage-Sized channels to have subtidal habitat at low tide and convey tidal flows at < 2 feet/second -Located high marsh creation areas for placement of materials dredged from channels-Relied on natural seed sources for reestablishment of Spartina alterniflora -Internal berms to reduce wave fetch & accelerate sediment accretion-Upland dikes to prevent flooding of developed areas 17 0 9 0 10 B !I I1I 11 Diked Salt Hay Farm Restoration Status ForerIy Diked Salt Hay Farm Restoration Sites Sp.,,rta IO r Desirable Marsh Cotwr Category Summary I1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 Year I-D-nW Toi*thIP R-Wstor- S"t OoTmrIaI TPnN R..ortWs, 9"-M ýo Rie TZ-WahItRe .00 S`te -Fh Spa S -n .iim CrIaiS IDTR9 & CTRS)-Fina S4pofn. _i~. .~treIRTRS 23Diked Salt Hay Farm Restoration Maurice Township Restoration Site Vegetative Cover 1996 1997 1998 1999 2000 2001 2004 24 12 ý I I I .-ýj Spring 1998 Diked Salt Hay Farm Restoration Maurice Township Restoration Site Drainage Density 1996 1997 1998 1999 2000 2001 26 13 Diked Salt Hay Farm Restoration Status Formersy Dikad Salt Hay Fenn Restoration Sites Marsh Csa4k DreNsug. Desaty 1200 1100 1000-900 800 I700 600 300-200--D1 -i tw3" 100 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 Year 27 Diked Salt Hay Farm Restoration Results" Restoration of three formerly-diked salt hay farms has returned approximately 4,400 ac of tidal marsh habitat to the Estuary-Including 808 miles of new tidal tributaries" Spartina/other desirable vegetative coverage at the three sites has increased from 580 acres to 2,606 acres-Two sites meet the final success criteria; third site meets interim criteria and is approaching final criteria-Detrital production supports estuarine food web" Invasive Phragmites vegetative coverage at the three sites has decreased from 1,372 acres to 108 acres-All sites meet vegetative success criteria* Marsh creek drainage density (ft/ac) at all three restored sites exceeds that of the reference marsh-Geomorphology of functioning tidal marsh has been restored-Desired increase in intertidal habitat has been achieved* Normal tidal depth and duration has been restored-Ali three sites meet hydrologic success criteria-Supports re-vegetation by desirable species and use of habitat by estuarine species" Restoration of three formerly-diked salt hay farms has been successful and results have exceeded expectations 28 14

0. -00'I-A_Phragmites-Dominated Site Restoration 29 Phragmites-Dominated Site Restoration Pre-Restoration Conditions

-Historical spread of aggressive non-native strain of Phragmitesacross marshplain -Dense monotypic stands of Phragmites" Obscured marshplain conditions" Eliminated microtopographic relief of marsh surface* Marsh rivulets eliminated" Build-up of litter & accumulation of sediment increased marsh plain elevation-Thick rhizome mat* Increased creek bank steepness" Reduction in intertidal habitat-Blockage of flow, filling of channels, and increase in bank steepness blocked fish and invertebrate access to marsh plain 30 15 Phragmites-Dominated Site Restoration Restoration Design-Eliminate conditions giving Phragmites a competitive advantage" Phragmites seed will not germinate in intertidal sediments" Control aggressive non-native strain of Phragmites" Source control through removal of manmade disturbances -Level remnant dikes & spoil piles-Multi-phased approach using ecological engineering" Baseline field data collection" Initial Phragmites control through glyphosate & surfactant application" Prescribed burning to clear marshplain (where possible)" Additional field data collection" Supplemental Phragmites control through glyphosate & surfactant application" Marshplain modifications" Follow-up glyphosate & surfactant application to control re-growth of dormant rhizomes 31 32 16 Test Area Program-Program initiated in 1999 to evaluate Phragmites control techniques-Alternatives to herbicide application & techniques to reduce required herbicide application -Agency and Advisory Committee Input* Alloway Creek Site-67 Test Areas Established in 1999-42 Test Areas Added in 2000-Included Physical, Chemical and Biological Treatments -Last Treatments Made in 2001-Field Data Collected for 2 Years Following Last Treatment(s)

• Additional Test Areas added at Cohansey River, Cedar Swamp, and The Rocks in 1999 -2000.34 17 Test Area Program" Physical Treatments

-Micro-topography Modification -Mowing-Multiple Mows* Chemical Treatment-Ground treatments using spray/wick application -Primarily fall applications, with some growing season tests-One-, Two- and Multi- year applications evaluated" Biological Treatment-Goat Herbivory* Combinations of Chemical and Physical Treatments 35 0/18 Test Area Program* Phragmites coverage significantly reduced within areas receiving glyphosate-based herbicide treatment* Mechanical/biological treatments did not result in measurable Phragmites coverage reduction* No combination of treatments resulted in better control than herbicide alone 37 Phragmites-Dominated Site Restoration Status 1I 1990 1997 1998 1999 2000 2001 2002 2003 2004 2000 200a 2007 2008 Cohanme River Re.o9tion SO. Site_CAH.W -kmp R..to,.ion Sk.-Th. Roks Restoraton SOt---FiaI Sparon Soo.. Crit.er.38 19 S Phragmites-Dominated Site Restoration Status Ph-q.lt- 4-Do.4.t~d ~-t~d R..a.t-ti-Sit.1 1 100%90%80%70%a0%50%40%30%20%10%0%.... ...97 19. 19 00 201 20 03 04 20 00 07 20 39 996 1997'ime IM 2000 2001 2002 2GO3 2004 2005 2006 2007 2008_ o.:.. R=v. R .to.8o_~w~C, -.R ..to,.tl:" S"'.= Th. Root. R.t ,lnS.FFin.P , Sot.. Cited, 39 Phragmltes-Dominated Site Restoration Alloway Creek Restoration Site Vegetative Cover~6-~,*kw Lt L 1996 2000 2001 2002 2004 2006 2008 40 20 f *I I 42 21 Phragmites-Dominated Site Restoration Status Phragnmit..-Domnlnated Wetaind Restoration Sites Marsh Creek Drainage Denslty 600 800 700 0 I400 300 200 100 1996 1997 1698 1999 2000 2001 2002 2003 2004 2005 2008 2007 2008 Year Co. y "I, .It.Sr.o Wi. Aio .- yk 6.tr8n5.1 _ C.d.r 8 .. p R-W.ftrtn SR. -Th. R-k. R.tom~iln gift.-~ N- Mdr.Cnk Rftmn.. ..mh 43 Phragmites-Dominated Site Restoration Results" Restoration of four formerly Phragmites-dominated marshes has resulted in substantial habitat improvement on approximately 5,110 acres of tidal marsh habitat in the Estuary* Spartinalother desirable vegetative coverage at the four sites has increased from 1,0 10 acres to 3,910 acres-One site meets the final vegetative success criteria; three other sites are approaching final criteria-Improved detrital production supports estuarine food web" invasive Phragmites vegetative coverage at the four sites has decreased from 3,302 acres to 317 acres-Dense monotypic stands of Phragmites have been removed-One site meets final vegetative success criteria; three other sites are approaching final criteria" Marsh creek drainage density (ft/ac) at all four restored sites is comparable to that of thereference marsh-Historical channels filled by Phragmites rhizomes and sediment are re-forming on marsh plain-Geomorphology of functioning tidal marsh has been restored-Desired increase in intertidal habitat has been achieved" Restoration of Phragmites-dominated sites is proceeding in accordance with expectations and has resulted in substantial improvements to estuarine habitat 44 22 Fish Ladders Background -Production of forage fish was primary objective-Focus on smaller tributaries suitable for alewife and blueback herring Alaska Steeppass Ladder Design-Based on survey of fishery agency personnel -Proven ability to pass river herring-56 cm. wide by 69 to 91 cm. deep Alewife (Alosa pseudoharengus) Blueback herrling (Alosa aestivalis) 45 Fish Ladders Site Selection Overview-Identified candidate impoundments -Determined access rights-Conducted field studies" HSI model" PSEG model-Conducted engineering feasibility studies-Identified candidate sites to NJDEP and DNREC 46 23 Fish Ladders Impwrndm.nt W a.%".*y e.llballn f.k Ipouded Ar. 80III- Lintl Abhoy theaS) Impoundment Illin McGinnlsIPond M04dwr0lll PN1 wr Sprng 1990 31 11.81 MoColly'sPond Murklll R9iwr Spdrng 1996 40 2115811-e, L.k. (Do-er) St. Jones Riwr S8ng 1990 171 29.25 9uniit Llk. Cohln,.y Rlr SprIng 04 3415 C9.9y. Por" MuMr.15111 R1991 Spring 1907 58 2.75Cooper Rlwor Lka Cooper 8Jver Spdng IM 190 2.36 W0.hllth L.9 Cooper RIse Spdng 1M0 2 E-ns Pond* Cooper Rir Spring 109M 25 6.58 Olenton. Lake LieP8I R0, Song 109 88 803 Moor-. Lk. St. Jon.e R01 Sping ION9 27 1.52 Stwert edL.k. Wo00d. y Crim. Spdng 2004 38 034 Newton Lk. N-.6on Cr.ee Spdng 2004 41 2,0Nox.0.-wn Pond Appoquirlmlnk Crvet SpOng 2004 162 099 Sl'99rLik. (MHI44).Upper Mts.8lllo. Risw Spling 2994 27 2.15$1sr L..ke Mispillion M-0 S0819 2004 -045* USFWS 8911 l344014 .8408 by PSEG 70.8. 8100 1304. Ewn. Poncl tfi05.rgpm, dimit into540.018,130 47 Fish Ladders PSEG FISH LADDER RIVER HERRINGTOTALS I L l160Dy Pon* _nn"Pond 120 ----Sit- ---O-N : ........ I.Sose LOke., ~ ~ ~ ~ ~ Il II llilig llll I, II I .m9 1997 1998 19 2000 2001 2002 200G 2004 2005 2000 2007 2O 28 48 24 Fish Ladders*

Conclusions:

-Sites selected are appropriate -Ladders are properly located & designed-Ladders have all passed adult river herring-Spawning has occurred in all impoundments -Juvenile growth and emigration have occurred 49 Wetland Production Secondary Consumers (18,575,270 Ibs/yr)Above Ground N.t Primary Production (928,763.500 Ibs/yr)Annual average production from three restored salt hay farms (2002-2004) using Aggregated Food Chain Model (AFCM)50 25 Wetland Production -AFCM Corroboration 30,000,000 25,000,000

---

.-.------------------------------------------------------

• 20,000,000----------------

(2 02-2004) -... ... y .. .. ...Sapa A15,000,000 -- --10.000,000 ---- --- --- --- --- --- -CR 5,00,000(2002-2004) 50000 ------Vegetation EwE Fish Abundance-Based Sampling-Based AFCM 51 Wetland Restoration Production Comp.rion of Lmt t Predaton O;a..d I o~o I eooo I ::oco I RoolowOoo' 0op0,000,0 0400.00,0 ,00..O.t.o~ 000000 0,00~o, 0~30?..,0o00 .OOt00OiU 0000 *0'0 52 26 USEPA Impingement Standards (Remanded) Salem Meets Standard for Reductions in Impingement Mortality 400POO-M50,00 j 30000O 250,000-t 200009 50.000--01*\01 88%o Reduction* Due to N Screens Proposed Operation Baseline Tar get Reduction 53 USEPA Entrainment Standards (Remanded) Salem Meets Standard for Reductions in Entrainment S I 5'Co1kuiatlon 60-.Target P1 OPO~d Basch- Reductioo OP ... ft.54 27 M USEPA Cost-Benefit Test (Remanded) Costs of All Technological & Operational Alternatives Are Significantly Greater Than Benefits Soonad...l-Flow Fin.Raoised Rft*N,40%SeaonalI Flow 054.",0. WHIt Constant0A 4S% Stnoodl Rows annos000. with ConstantAT 21b% Seasonal Flow Reduction sold, Vadlok AT 45% Seasonal Flow Rodocdlo With Vadohno AT010.01.1k~ Doraf CooOOS Tow nota51.0 20.0,"5 1073 IiTij7 1121611~1221~---p --p -I (MIAS)(11,93)(17915)$217 f1212 00729=094Ml---M1061 I -I -I -I -~ w 12 55 Wetland Restoration Costs and Benefits* PSEG recently developed estimated costs and benefits for restoration of the three formerly diked salt hay farm restoration sites as part of NJPDES Permit renewal application

• Costs-Assume maintenance through 2020 (Salem license expiration)

-Present value as of 2007: $100 million" Benefits-Expected gains to commercial & recreational fisheries-Increased pounds of striped bass (Morone saxatalis), weakfish (Cynoscion regalis) & white perch (M. americana) -Benefits continue beyond Salem operation (assumed 2040)-Present value as of 2007: $130.74 million 56 28 Wetland Restoration Benefits WE J# 4* 1$ .0 le 10 57 Environmental Benefits* Expanded habitat & food sources for fish and wildlife" Increased biodiversity" Protection of natural & historic resources* Expanding the "Greenway" of contiguous protected natural resources along the coast of the Delaware Bay and River.* Advancements in knowledge about salt marshes, their functions, values and contributions to the ecosystem. I I L -7 Commercial Twp. Site Great Egrets[ 1 Dennis Twp. Site Expanding Scientific Knowledge (Scientists on Field Tours) Alloway Creek Site Mixed Vegietation Test Area I 58 29 0 Biological Monitoring 1 10-Biological monitoring is a key component of PSEG's Estuary Enhancement Program.*]Includes restoration site, bay-wide, Station, and fish ladder monitoring that helps scientists assess abundanceof juvenile fish in the estuary, evaluate the effectiveness of variousrestoration techniques and determine the success ofrestoration efforts.

• PSEG's program is helping advance scientific knowledge about the estuary.Marsh Productivity Monitoring 15eacn withn bene niet Kecoroing Data Horseshoe Crab Monitoring 59 I 59 0 Benefits for Wildlife Fx--ý,ýOsprey at MRT Songbirds, Shorebirda, W.Al.. K&r.I AL U.b.I.60 30 Education

& Ecotourism Benefits K~77ISpecial Events and environm;ental organizations Access for fishing, hunting, crabbing, trapping and nature observation 61 62 31 0 Public AccessNJ Com" Kwttqe TODD RooMt SNOboemihon PWMS, & T~we A#""MrS Waft.hod vw~ ft" 0oEokk. &H-w.moO 0.D 8rd0..& W ..d, Y S.D. Co.,4. wJ E.* W1on TrODIOI3 .6.b)N0.oW" TroD )ý5 noB.NJ Coo"i H~l~S ToDD Raft Sb Cft~ww yRlw WDvwfmd soOD..V..gA.. Mw.S.9. A F-fAIW Nh GOD N r.T (,5.4W c-*540.wCNJy' NJAojY C~m~ No"h J Coed HwttWS TODD ROOM Sb 00. HoDSM..f& h .OESrvo, Pb~fmm(M)R-Ym moD 4.17 NW onS0.f.) Y.Prh (3)C.OT-pDELood____________NJ Coo"d H~6S TOD Rom" Sbt flnnJ. TOE-Dip ObwrD. A,.. (2)Eb. SOS 0Iokn PW- P0O-o C.U. Afty COOE5' NJ Nbow TOE (.18 nE..)PDDSW A-.. (2)mafommrwm NJ Cos"E HEWg ToDD ROL" Sib IOND Cdo~bo o P111ftOIS C..,OED.SCO~na-NJ00g.... 2 63 0 EEP Website Includes...

• Drlvlng Dfrvetluns
• She Maps and Uses*program Overviewrs mDrivinouDirections 64 0 32 Conclusions
• EEP included technological

& ecological solutions to address potential adverse environmental impacts of Station operation and results have exceeded all expectations" All restoration sites provide increased fisheries and primary food source production, expanded habitat, nursery grounds, shelter and foraging opportunities for fish and other aquatic species; and alsoprovide increased habitat availability for endangered and threatened species, and resident and migrating birds" Ecological benefits of ecosystem restoration are far greater thantechnological alternatives available & resulted in a positive cost benefit" Program success demonstrates that regulatory agencies should pursue other innovative solutions to complex environmental problems, and that strategies involving ecosystem restoration can provide greater benefits to the estuary than more typical "command and control" solutions 65 t~fMCO.4STAN~k66 66ýA 9 33 Salem/ Hope Creek Environmental Audit -Post-Audit Information Question #: ENV-94 Category: Ecology Statement of Question: A. Provide NRC with Environmental Compliance Matrix [front page for reference purposes and the single page provided at the site audit. Note: may black out any sensitive locations, if necessary.] B. Provide map identifying habitat regions along all three transmission ROWs from SHC to New Freedom switchyard. Additionally, provide text description of each habitat type.C. Page 3-13/14 of the ER. Clarify description of HC New Freedom and Salem New Freedom North descriptions (first two bullet items).Response: A The requested pages from the Environmental Compliance Matrix are being provided. The columns labeled "Federal Species" and "State Species" on the page provided during the Salem and Hope Creek License Renewal Environmental Audit are redacted. B The requested map and text descriptions are being provided.C The bullet items for which clarification is requested read as follows in both the Salem and the HCGS License Renewal Environmental Reports: HCGS-New Freedom-This 500-kV line, which is operated by PSE&G, extends northeast from Salem for 69 km (43 mi) in a 107-m (350-ft) wide corridor to the New Freedom switching station north of Williamstown, New Jersey. This line shares the corridor with the 500-kV Salem-New Freedom North line. During 2008, a new substation (Orchard) was installed along this line, dividing it into two segments." Salem-New Freedom North-This 500-kV line, which is operated by PSE&G, runs northeast from HCGS for 63 km (39 mi) in a 107-m (350-ft) wide corridor to the New Freedom Switching Station north of Williamstown, New Jersey. This line shares the corridor with the 500-kV HCGS-New Freedom line.According to PSE&G's current GIS database of transmission line information, the length of the Salem-New Freedom North line is 44.25 miles and the length of the HCGS-New Freedom line is 43.25 miles. PSEG Nuclear recommends the use of these current line lengths in the NRC's Supplemental EIS for the Salem and Hope Creek License Renewals. The one-mile length difference for the two lines, as reported in the GIS database, is likely due to differences I in turn radii when totaled over the length of the shared corridor from the plant sites to the New Freedom Switching Station.Section 3.1.6 of the Salem and the HCGS License Renewal Environmental Reports (ERs) states that the Salem-New Freedom North line has a length of39 miles, which is approximately 4 miles shorter than the length reported in PSE&G's current GIS database. The source of the information in Section 3.1.6 of the License Renewal ERs was the Salem Final Environmental-Statement_(FES)_(page 3-24, 4_th paragraph, 1973). _No historical information was found to explain why the length for the Salem-New Freedom North line was reported differently in the Salem FES (1973) than in PSE&G's current (2010) GIS database. However, it should be noted that the Salem-New Freedom North line, which was built during construction of the Salem plant and was originally connected to Salem, is now connected to the HCGS. This change is further explained below.Section 3.1.6 of the Salem and the HCGS License Renewal Environmental Reports states that the Hope Creek-New Freedom line has a length of 43 miles, which is about the same length as is reported in PSE&G's current GIS database. The source of the information in Section 3.1.6 of the License Renewal ERs was the HCGS Environmental Report -Operating License Stage (page 3.9-2, middle of the last paragraph, 1983) and the HCGS-UFSAR, Rev. 10 (page 8.2-1, middle of last paragraph, 1999). It should be noted that the HCGS-New Freedom line was built during the construction of HCGS, but connected to Salem. This is further explained below.For clarification of information in the above-quoted bullets that is not related to the lengths of the Salem-New Freedom North and Hope Creek-New Freedom lines, PSEG Nuclear refers the NRC Staff to the paragraphs that precede the bulleted lists of transmission lines in the Salem and HCGS License Renewal ERs. These paragraphs explain to which plant each transmission line was connected at the time of its construction and to which plant it is connectedtoday and why. These paragraphs clarify why the Salem-New Freedom North line is currently connected to the Hope Creek station and why the Hope Creek-New Freedom line is currently connected to the Salem station. For ease of reference, the paragraphs that precede the bulleted lists of transmission lines in each ER are reproduced below, with the paragraphs from the HCGS License Renewal ER first, followed by the paragraphs from the Salem License Renewal ER.The FES (NRC 1984) for HCGS identifies three 500-kV transmission lines needed to deliver electricity generated by HCGS to the transmission system. One 0.8-km (0.5-mi) onsite tie line was built to connect HCGS with Salem. Two lines previously connected to Salem (Salem-New Freedom North and Salem-Keeney) were re-routed to the HCGS switchyard. 2 After construction of HCGS, a new substation (known as Red Lion) was built along the Salem-Keeney transmission line. Hence, the Salem-Keeney transmission line is now comprised of two segments: one from HCGS to Red Lion and the other from Red Lion to Keeney.Because the Salem-New Freedom North line was re-routed to HCGS, it was necessary to build a new transmission line to connect Salem to the New Freedom substation. This line is referred to as the HCGS-New Freedom transmission line. Another transmission line that preexisted HCGS, called the Salem-New Freedom South line, also connects Salem to the New Freedom substation. The Salem-New Freedom North, Salem-New Freedom South, and Salem-Keeney lines were not constructed to connect HCGS to the grid. The only new transmission lines constructed as a result of the HCGS are the HCGS-New Freedom line, the tie line, and short reconnections for Salem-New Freedom North and Salem-Keeney. The HCGS-Salem tie line and the short reconnectionsdo not pass beyond the site boundary and, therefore, are not evaluated in this Environmental Report. Nevertheless, for completeness, all lines are described below.In the Salem ER, the paragraphs that precede the bulleted list on page 3-14 read as follows:The FES (AEC 1973) for Salem identifies three 500-kilovolt (kV) transmission lines that were to be built to deliver electricity generated at the Salem site to the transmission system. Two of these lines were built to connect the station with the New Freedom substation near Williamstown, New Jersey. Due to reliability considerations, these lines were constructed to transverse separate rights-of-way and are identified as "Salem-New Freedom North" and "Salem-New Freedom South". The third line was constructed to extend north, across the Delaware River, and to terminate at Keeney substation in Delaware. This line is identified as the "Salem-Keeney." When HCGS was constructed, several changes in transmission line connections with Salem were made (NRC 1984). The existing Salem-New Freedom North and Salem-Keeney lines were disconnected from Salem and reconnected to HCGS. Also, a new substation (known as Red Lion) was built along the Salem-Keeney transmission line. Hence, the Salem-Keeney transmission line is now comprised of two segments: one from HCGS to Red Lion and the other from Red Lion to Keeney.Because the Salem-New Freedom North line was re-routed to HCGS, it was necessary to build a new transmission line to connect Salem to the New Freedom substation. This line is known as the "HCGS-New Freedom" transmission line.Because the Salem-New Freedom North, Salem-New Freedom South, and Salem-Keeney lines were originally built to connect Salem to the grid, they are further considered for analysis in this Environmental Report. The HCGS-New Freedom line, having been constructed for HCGS, is not part of the analysis in this Environmental Report. The HCGS-Salem tie line does not pass beyond the 3 site boundary, and therefore, is also not evaluated in this Environmental Report.Nevertheless, for completeness, all lines are described below.List Attachments Provided: 1. PSE&G Environmental Compliance Matrix 2010 Cover page and matrix page labeled "Salem-New Freedom South (redacted)" 2. NOAA. 2008. C-CAP zone 62 2006-Era Land Cover. CSC (Coastal Services Center)/Coastal Change Analysis Program (C-CAP).http://csc.noaa.qov/crs/Ica/ ..a. Map of land cover with transmission line rights-of-way superimposed

b. Metadata for maps 4

/-PSE&G ENVIRONMENTAL COMPLIANCE MATRIX January 2010 Salem-New Freedom South____________ ____________ _______________________ p Ordered Soen INetlanflc Buffer lnOmDIned Work Pl --LfCn~n ~ dw =dra ... ie I. -REDA(T State Secies -REDACT Cr.ments/8/03-08/04Exceptional150 FeetCanton Drain M-E Plant/Animal Citicafly Dependent -15 Feet Sept 1 to Dec 14 State Owned Open Space I Wetland on half of span tcward 8/3 1 18/04-09/01 Exceptional I I e c Owned Open Space / Weland around 814 and 2008/-/1p[ Fe[s tD1ooded areas around 9/109/01-09/02Excepbonal150 Feet Sept 1 to Dec 14 State Owned Open Space I Limited access no bumowing i 12008 awamn eoik flaooed are.Notes:Bog Turtle is listed as a species under Federal and State Species. The timing restidctions we only calculated in the Federal work window. If Bog turte. swamp pink or small whoded pogonia is listed for a span, a field survey is required.If a salamander or tree frog species is noted, avoid vernal ponds'While plants communtiies of concern aoe listed, they have not been calculated into the gven work windows. -Disccss with supervisoNo maintenance in areas flagged as swamp pink habitat For Federal Listed P/ant Species -Maintenance should be conducted in the late fall and winter -after plant growing season Special Note: For spans with sensitive joint cetch -if maintenance is required -set mower at 6 inches and no herbicide use in the span ENV-94, 2a Legend* Salem and Hope Creek Generating Stations Grassland A Substation =High Intensity Developed-Transmission Line analyzed in Hope Creek ERoLow Intensity Developed Transmission Line analyzed in Salem ER g Medium Intensity Developed Landcover M. Mixed Forest Bare Land 1 Palustrine Aquatic BedCultivated Palustrine Emergent Wetland E Deciduous Forest Palustrine Forested Wetland:-,-, Developed Open Space Palustrine Scrub/Shrub Wetland;,X Estuarine Emergent Wetland Pasture/Hay m Estuarine Forested Wetland Scrub/Shrub z Estuarine Scrub/Shrub Wetland ": Unconsolidated Shore M Evergreen Forest Water Miles 0 2.5 5 10 15 PSEG License Renewal Environmental Report Transmission System Landcover ENV-94, Attachment 2 N N P E NON.PEG IdentificationInformation: Meta data for Salem/Hope Creek Site and transmission line rights of way.Citation: NOAA. 2008. C-CAP zone 62 2006-Era Land Cover. CSC (Coastal Services Center)/Coastal Change Analysis Program (C-CAP). http://csc.noaa.gov/crs/Ica/. CitationInformation: Originator: NOAA (National Oceanic and Atmospheric Administration) CSC (Coastal Services Center)/Coastal Change Analysis Program (C-CAP)PublicationDate: 20080519 Title: C-CAP zone 62 2006-Era Land Cover Metadata Geospatial_Data_PresentationForm: Map Publication_Information: PublicationPlace: Charleston SC Publisher: NOAA's Ocean Service, Coastal Services Center (CSC)Online_Linkage: http://www.csc.noaa.gov/crs/Ica LargerWorkCitation: Citation_Information: Originator: This layer is the 2006-era classification based on Landsat TM (Thematic Mapper)imagery. The C-CAP zone 62 2006-Era program list of products includes the classification of 1996-era Landsat data, 2001-era land cover, and change information. PublicationDate: 20080519 Title: C-CAP US (United States) U.S. Great Lakes zone 62 2006-Era Land Cover Project Publicationinformation: PublicationPlace: Charleston SC Publisher: NOAA's Ocean Service, Coastal Services Center (CSC)OtherCitationDetails: This classification is based on Landsat TM scenes p017r031 5/2/2006 p018r031 8/13/2006 1 ENV-94, Attachment 2 p018r032 8/1.3/2006. pO19r031 9/2/2005 pO19r032 5/13/2005

Description:

Abstract: This is a final classification. It is ready for distribution. This data set is the 2006-era classification of U.S. Great Lakes Region, zone 62. This data set utilized 5 full or partial Landsat scenes which were analyzed according to the Coastal Change Analysis Program (C-CAP) protocol to determine land cover.Purpose: To improve the understanding of coastal uplands and wetlands, and their linkages with the distribution, abundance, and health of living marine resources. TimePeriod ofContent: TimePeriodInformation: RangeofDates/Times: BeginningDate: 20050513 EndingDate: 20060813 Currentness

Reference:

Date of the Landsat scenes Status:Progress: Complete Maintenance andUpdateFrequency: 5 years Spatial-Domain: BoundingCoordinates: West_BoundingCoordinate: -83.257580 EastBoundingCoordinate: -78.856113 North_BoundingCoordinate: 42.590893 2 ENV-94, Attachment 2 SouthBoundingCoordinate: 39.844287 Keywords: Theme: ThemeKeywordThesaurus: ISO 19115 Topic Category ThemeKeyword: lmageryBaseMapsEarthCover' Theme: ThemeKeywordThesaurus: None ThemeKeyword: Land Cover Analysis Theme Keyword: Change Detection Analysis ThemeKeyword: Remotely Sensed Imagery/Photos Place: PlaceKeywordThesaurus: None Place Keyword: Coastal Zone PlaceKeyword: U.S. Great Lakes Region Place-Keyword: Ohio Place-Keyword: Pennsylvania AccessConstraints: None, except fora possible fee.UseConstraints: Data set is not for use in litigation. While'efforts have been made to ensure that these data are accurate and reliable within the state of the art, NOAA, cannot assume liability for any damages, or misrepresentations, caused by any inaccuracies in the data, or as a result of the data to be used on a particular system. NOAA makes no warranty, expressed or implied, nor does the fact of distribution constitute such a warranty.NativeDataSetEnvironment: ERDAS Imagine 8.7 on Microsoft Windows XP Professional Version 2002 Service Pack 2 3 ENV-94, Attachment 2 DataQualityInformation: AttributeAccuracy: AttributeAccuracyReport: According to accuracy assessment performed by NOAA, the overall accuracy for the Great Lakes region is 91.4% correct, Kappa coefficient was used to determine the overall accuracy of 90.2%. The 2006 update is based on updating the change areas between 2001 and 2006 imagery, and overlaying theresults over 2001 land cover. Therefore the accuracy of the 2001 product is a sufficient indication of 2006 update accuracy as well within +/- 0.69% (percent area change from 2001). The following methodology and results are from the accuracy assessment of the 2001 dataset: 4 A team of field investigators participated in field collection of verification points in October 2001 and July 2002. Data validation teams consisted of personnel from the NOAA Coastal Services Center. Each team was equipped with a portable color laptop computer linked to a Global Positioning System (GPS).The field laptop runs software that supports the classified data as a raster background with the road network as a vector overlay with a simultaneous display of live GPS coordinates. Accuracy assessment points were generated with ERDAS Imagine software using a stratified random sample in 3x3 pixel homogeneous windows. This data collected was used to produce accuracy assessments for the Great Lakes C-CAP data. Both windshield survey methods of collection and airplane reconnaissance were implemented to collect the accuracy assessment points.NOAA implemented an accuracy assessment. The accuracy assessment plan included the collection of field points. Only areas containing at least 3 x 3 contiguous pixel clumps were assessed. Transects were created and random points were generated along those transects. The overall accuracy for the Great Lakes region is 91.4% correct. All of the states are also independently higher than the 85%accurate required by NOAA C-CAP. Kappa coefficient was used to determine the overall accuracy of 90.2%. The class accuracies were determined by the producer's accuracy, or error of omission. These were supposed to be all above 80% but three categories were below in the overall and in many states individually: Mixed Forest, Scrub/Shrub, and Palustrine Scrub/Shrub. These are the more subjective classes in that they have hard to define boundaries. No fuzzy assessments were implemented, and an error matrix was created. The overall accuracies by state are as follows: NY -85.1%, PA -94.3%, OH -91.6%, IN -92%, IL -100%, WI -96.1%, MN -91.8%.Post-Processing Steps: None 4 ENV-94, Attachment 2 Known Problems: None Spatial Filters: None LogicalConsistencyReport: Tests for logical consistency indicate that all row and column positions in the selected latitude/longitude window contain data. Conversion and integration with vector files indicates that all positions are consistent with earth coordinates covering the same area. Attribute files are logically consistent. CompletenessReport: Data does not exist for all classes. There are no pixels representing class 16 (Estuarine Forested Wetland), class 17 (Estuarine Scrub/Shrub Wetland), class 18 (Estuarine Emergent Wetland), class 23 (Estuarine Aquatic Bed). Class 1 (Unclassified) is intentionally left blank. All pixels have been classified. The NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA National Marine Fisheries Service Report 123, discusses the interagency effort to develop the land cover classification scheme and defines all categories. Positional_Accuracy: HorizontalPositional_Accuracy: HorizontalPositional_AccuracyReport: Landsat scenes were geo-referenced by Eros Data Center.Spatial accuracy assessed by MDA Federal is found to be to within 2 pixels accuracy.VerticalPositional_Accuracy: VerticalPositionalAccuracyReport: There was no terrain correction in the geo-referencing procedure. Lineage: SourceInformation: SourceCitation: CitationInformation: Originator: MDA Federal 5 ENV-94, Attachment 2 PublicationDate: 20080519 Title: C-CAP zone 62 2006-Era Land Cover Classification Geospatial_DataPresentationForm: remote-sensing image Publication_Ihformation: PublicationPlace: Charleston SC Publisher: NOAA Coastal Services Center Online_Linkage: http://www.csc.noaa.gov/ Type of SourceMedia: DVD/CD-ROM SourceTimePeriod ofContent: TimePeriodInformation: Rangeof.Dates/Times: BeginningDate: 20050513 EndingDate: 20060813 SourceCurrentness

Reference:

Date of the Landsat scenes SourceCitationAbbreviation: NOAA CSC SourceContribution: NOAA CSC ProcessStep: Process_Description: This dataset was created by MDA Federal. This classification is based on Landsat TM imagery from the MRLC 2006 database. The study area is zone 62, U.S. Great Lakes Region.Pre-processing steps: Each Landsat TM scene was geo-referenced by USGS (United States Geological Survey) EROS Data Center. Then MDA Federal staff verified the scenes for spatial accuracy to within 2 pixels. The data was geo-referenced to Albers Conical Equal Area, with a spheroid of GRS 1980, and Datum of WGS84. The 6 ENV-94, Attachment 2 data units is in meters. At-satellite reflectance was performed on each scene and the tasseled cap transformation applied. All of the image data used was Landsat TM 5 or 7. The mosaicked dataset wasused for classification. Change Detection: The next step was to determine the areas of change between 2006 and 2001. The change detection algorithm used is the Cross Correlation Analysis process (CCA) developed at MDA Federal. This copyrighted procedure produced 2 Z-score files per scene of likelihood of change. These files were thresholded and mosaicked to create a binary change layer for that scene. All of the binary files were mosaicked to create a change layer for the entire study area. A focal majority was run on the change layer to fill in some clumps to make sure all of the changerwas accounted for. The change layer is a slight over-estimation of change to make sure to include as much change as detectable. Classification: The classification of the change areas was a mixture of automated and manual approaches, The change areas were removed from the 2001 classification. The areas with no change between 2006 and 2001 were used as training for a Classification and Regression tree (CART) analysis of the changed areas.Modelling and hand-editing were used to further refine the CART output and create a final classification. The classified change areas were overlaid on the 2001 C-CAP product to create a 2006 C-CAP classification. Attributes for this product are as follows: 0 Background 1 Unclassified (Cloud, Shadow, etc)2 High Intensity Developed 3 Medium Intensity Developed 4 Low Intensity Developed 5 Open Space Developed 6 Cultivated Land 7 Pasture/Hay 8 Grassland 9 Deciduous Forest 7 ENV-94, Attachment 2 10 Evergreen Forest 11 Mixed Forest 12 Scrub/Shrub 13 Palustrine Forested Wetland 14 Palustrine Scrub/Shrub Wetland 15 Palustrine Emergent Wetland 16 Estuarine Forested Wetland 17 Estuarine Scrub/Shrub Wetland 18 Estuarine Emergent Wetland 19 Unconsolidated Shore 20 Bare Land 21 Water 22 Palustrine Aquatic Bed 23 Estuarine Aquatic Bed 24 Tundra 25 Snow/Ice ProcessDate: 20080519 ProcessContact: Contact_Information: ContactPersonPrimary: Contact-Organization: NOAA Coastal Services Center Coastal Change Analysis Program (C-CAP)ContactPerson: CRS (Coastal Remote Sensing) Program Manager ContactPosition: CRS Program Manager ContactAddress: AddressType: mailing and physical address 8 ENV-94, Attachment 2 Address: 2234 S. Hobson Ave.City: Charleston State orProvince: SC PostalCode: 29405 Country: USA ContactVoiceTelephone: 843-740-1210 ContactFacsimileTelephone: 843-740-1224 ContactElectronicMailAddress: clearinghouse@csc.noaa.gov Hours ofService: 8:00 am to 5:00 p.m. EST. M-F Process_Step: Process_Description: Classification ProcessDate: Unknown ProcessContact: ContactInformation: Contact_OrganizationPrimary: Contact-Organization: NOAA Coastal Services Center Coastal Change Analysis Program (C-CAP)ContactPosition: CRS Program Manager ContactAddress: AddressType: mailing and physical addressAddress: 2234 S. Hobson Ave.City: Charleston State orProvince: SC PostalCode: 29405 Country: USA 9 ENV-94, Attachment 2 ContactVoiceTelephone: 843-740-1210 ContactFacsimileTelephone: 843-740-1224 ContactElectronicMailAddress: csc@csc.noaa.gov Hours ofService: Monday to Friday, 8 a.m. to 5 p.m., Eastern Standard Time Spatial_Data_Organization_Information: DirectSpatial_ReferenceMethod: Raster SpatialReferenceInformation: HorizontalCoordinate_SystemDefinition: Planar: MapProjection: MapProjection_Name: Albers Conical Equal Area AlbersConicalEqualArea: StandardParallel: 29.5 StandardParallel: 45.5 LongitudeofCentralMeridian: 96 West Latitudeof ProjectionOrigin: 23 North False_Easting: 0.00000 False_Northing: 0.00000 PlanarCoordinateInformation: PlanarCoordinate_EncodingMethod: Row and column CoordinateRepresentation: AbscissaResolution: 30 meter OrdinateResolution: 30 meter 10 ENV-94, Attachment 2 PlanarDistanceUnits: Meters GeodeticModel: HorizontalDatumName: North American Datum 1983 Ellipsoid-Name: GRS80 Semi-majorAxis: 6378137.0 Denominator ofFlatteningRatio: 298.257 EntityandAttributeInformation: DetailedDescription: EntityType: EntityType_Label: U.S. Great Lakes Region (zone 62)EntityType_Definition: C-CAP zone 62 (U.S. Great Lakes Region) as delineated by NOAA using scene boundaries, hydrological units, and county boundaries EntityTypeDefinitionSource: unknown Attribute: AttributeLabel: Landcover Classification AttributeDefinition: Landcover Classification as determined by NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation AttributeDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS (National Marine Fisheries Service) 123, U.S. Department of Commerce, April 1995 AttributeDomainValues: EnumeratedDomain: EnumeratedDomainValue: 1 Unclassified EnumeratedDomainValueDefinition: This class contains no data due to cloud conditions or data voids.EnumeratedDomainValueDefinitionSource: N/A 11 ENV-94, Attachment 2 EnumeratedDomain: EnumeratedDomainValue: 2 High Intensity Developed EnumeratedDomainValueDefinition: Contains little or no vegetation. This subclass includes heavily built-up urban centers as well as large constructed surfaces in suburban and rural areas. Large buildings (such-as multiple family-housing,. hangars, and large barns), interstate-highways, and runways typically fall into this subclass. Impervious surfaces account for 80-100 percent of the total cover.EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.EnumeratedDomain: EnumeratedDomainValue: 3 Medium Intensity Developed EnumeratedDomainValueDefinition: Contains substantial amounts of constructed surface mixed with substantial amounts of vegetated surface. Small buildings (such as single family housing, farm outbuildings, and large sheds), typically fall into this subclass. Impervious surfaces account for 50-79 percent of the total cover.EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.EnumeratedDomain: EnumeratedDomainValue: 4 Low Intensity Developed EnumeratedDomainValueDefinition: Contains constructed surface mixed with vegetated surface. This class includes features seen class 3, with the addition of streets and roads with associated trees and grasses. Impervious surfaces account for 21-49 percent of the total cover.EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.EnumeratedDomain: 12 ENV-94, Attachment 2 EnumeratedDomainValue: 5 Developed Open Space EnumeratedDomainValueDefinition: Includes areas with a mixture of some constructed materials, but mostly vegetation in the form of lawn grasses. This subclass includes parks, lawns, athletic fields, golf courses, and natural grasses occurring around airports and industrial sites. Impervious surfaces account for less than 20 percent of total cover.EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.EnumeratedDomain: EnumeratedDomainValue: 6 Cultivated Land EnumeratedDomainValue Definition: Includes herbaceous (cropland) and woody (e.g., orchards, nurseries, and vineyards) cultivated lands.EnumeratedDomainValueDefinition Source: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.EnumeratedDomain: EnumeratedDomainValue: 7 Pasture/Hay EnumeratedDomainValueDefinition: Characterized by grasses, legumes or grass-legume mixtures planted for livestock grazing or the production of seed or hay crops.EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.EnumeratedDomain: EnumeratedDomainValue: 8 Grassland EnumeratedDomainValueDefinition: Dominated by naturally occurring grasses and non-grasses (forbs) that are not fertilized, cut, tilled, or planted regularly. 13 ENV-94, Attachment 2 EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.EnumeratedDomain: .Enumerated__Domain-Value: 9 Deciduous Forest ............ ..... .... .....EnumeratedDomainValueDefinition: Includes areas dominated by single stemmed, woodyvegetation unbranched 0.6 to 1 meter above the ground and having a height greater than 5 meters and cover more than 20% of land area. More than 75 percent of the tree species shed foliage simultaneous in response to seasonal change.EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.EnumeratedDomain: EnumeratedDomainValue: 10 Evergreen Forest EnumeratedDomainValueDefinition: Includes areas in which more than 67 percent of the trees remain green throughout the year. Both coniferous and broad-leaved evergreens are included in this category. Trees must be taller than 5 meters and more than 20% of the land cover.EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.EnumeratedDomain: EnumeratedDomainValue: 11 Mixed Forest EnumeratedDomainValueDefinition: Contains all forested areas in which both evergreen and deciduous trees are growing and neither predominate. Trees must be taller than 5 meters and more than 20% of the land cover.EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.14 ENV-94, Attachment 2 EnumeratedDomain: EnumeratedDomainValue: 12 Scrub/Shrub EnumeratedDomainValueDefinition: Areas dominated by woody vegetation less than 5 meters in height. This class includes true shrubs,young trees, and trees or shrubs that are small or stunted because of environmental conditions. Includes both evergreen and deciduous scrub.EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.EnumeratedDomain: EnumeratedDomainValue: 13 Palustrine Forested Wetland EnumeratedDomainValueDefinition: Includes all non-tidal wetlands dominated by woody vegetation greater than or equal to 5 meters in height, and all such wetlands that occur in tidal areas in which salinity due to ocean-derived salts is below 0.5 parts per thousand (ppt).EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.Enumerated Domain: EnumeratedDomainValue: 14 Palustrine Scrub/Shrub Wetland EnumeratedDomainValueDefinition: Includes all non-tidal wetlands dominated by woody vegetation less than or equal to 5 meters in height, and all such wetlands that occur in tidal areas in which salinity due to ocean-derived salts is below 0.5 ppt.EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.EnumeratedDomain: EnumeratedDomainValue: 15 Palustrine Emergent Wetland 15 ENV-94, Attachment 2 EnumeratedDomainValueDefinition: Includes all non-tidal wetlands dominated by persistent emergents, emergent mosses, or lichens, and all such wetlands that occur in tidal areas in which salinity due to ocean-derived salts is below 0.5 ppt.EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.EnumeratedDomain: EnumeratedDomainValue: 16 Estuarine Forest Wetland EnumeratedDomainValueDefinition: Includes all tidal wetlands dominated by woody vegetation greater than or equal to 5 meters in height, and all such wetlands that occur in tidal areas in which salinity due to ocean-derived salts is above 0.5 parts per thousand (ppt).EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.EnumeratedDomain: EnumeratedDomainValue: 17 Estuarine Scrub/Shrub Wetland Enumerated DomainValueDefinition: Includes all tidal wetlands dominated by woody vegetation less than or equal to 5 meters in height, and all such wetlands that occur in tidal areas in which salinity due to ocean-derived salts is above 0.5 ppt.EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.EnumeratedDomain: EnumeratedDomainValue: 18 Estuarine Emergent Wetland EnumeratedDomainValueDefinition: Characterized by erect, rooted, herbaceous hydrophytes (excluding mosses and lichens) that are present for most of the growing season in most years. Perennial plants usually dominate these wetlands. All water regimes are included except those that are subtidal and irregularly exposed.16 ENV-94, Attachment 2 EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.EnumeratedDomain: Enumerated Domain Value: 19 Unconsolidated Shore EnumeratedDomainValueDefinition: Characterized by substrates lacking vegetation except for pioneering plants that become established during brief periods when growing conditions are favorable. Erosion and deposition by waves and currents produce a number of landforms, such as beaches, bars, and flats, all of which are included in this class.EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.EnumeratedDomain: EnumeratedDomainValue: 20 Bare Land EnumeratedDomainValueDefinition: Composed of bare soil, rock, sand, silt, gravel, or other earthen material with little or no vegetation. EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.EnumeratedDomain: EnumeratedDomainValue: 21 Open Water EnumeratedDomainValueDefinition: Includes all areas of open water with less than 25 percent cover of vegetation or soil.EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.EnumeratedDomain: 17 ENV-94, Attachment 2 EnumeratedDomainValue: 22 Palustrine Aquatic Bed EnumeratedDomainValueDefinition: Includes wetlands and deepwater habitats dominated by plants that grow principally on or below the surface of the water for most of the growing season in most years. Salinity due to ocean-derived salts is below 0.5 ppt.EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Comrnerce, April 1995.EnumeratedDomain: EnumeratedDomainValue: 23 Estuarine Aquatic Bed EnumeratedDomainValueDefinition: Includes widespread and diverse Algal Beds in the Marineand Estuarine Systems, where they occupy substrates characterized by a wide range of sediment depths and textures. They occur in both the Subtidal and Intertidal Subsystems and may grow to depths of 30 m (98 feet). This includes kelp forests. Salinity due to ocean-derived salts is equal to or above 0.5 ppt.EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.EnumeratedDomain: EnumeratedDomainValue: 24 Tundra EnumeratedDomainValueDefinition: Includes treeless cover beyond the latitudinal limit of the boreal forest in pole-ward regions and above the elevation range of the boreal forest in high mountains. EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.EnumeratedDomain: EnumeratedDomainValue: 25 Snow/Ice EnumeratedDomainValueDefinition: Includes persistent snow and ice that persist for greater portions of the year.18 ENV-94, Attachment 2 EnumeratedDomainValueDefinitionSource: Dobson, J. et al, NOAA Coastal Change Analysis Program (C-CAP): Guidance for Regional Implementation, NOAA Technical Report NMFS 123, U.S.Department of Commerce, April 1995.Distribution Information: Distributor: ContactInformation: Contact_OrganizationPrimary: Contact_Organization: NOAA Coastal Services Center ContactPerson: Clearinghouse Manager ContactPosition: Clearinghouse Manager ContactAddress: AddressType: mailing and physical address Address: 2234 South Hobson Avenue City: Charleston State orProvince: SC PostalCode: 29405-2413 Country: USA ContactVoiceTelephone: (843)740-1210 ContactFacsimileTelephone: (843)740-1224 ContactElectronicMailAddress: clearinghouse@csc.noaa.gov Hours ofService: Monday-Friday, 8-5 EST Resource_Description: Downloadable Data DistributionLiability: Users must assume responsibility to determine the usability of these data.StandardOrderProcess: 19 ENV-94, Attachment 2 Digital-Form: Digital Transfer_Information: FormatName: ERDAS Imagine image file (.img)DigitalTransferOption: Offline_Option: OfflineMedia: CD-ROM RecordingFormat: ISO 9660 CompatibilityInformation: ISO 9660 format allows the CD-ROM to be read by most computer operating systems.Fees: none MetadataReferenceInformation: MetadataDate: 20080519 MetadataReviewDate: 20090702 MetadataContact: ContactInformation: Contact_OrganizationPrimary: Contact_Organization: NOAA Coastal Services Center ContactPerson: Metadata Specialist ContactPosition: Metadata Specialist ContactAddress: AddressType: mailing and physical addressAddress: 2234 S Hobson Ave.City: Charleston 20 ENV-94, Attachment 2 State orProvince: SC PostalCode: 29405 Country: USA ContactVoiceTelephone: 843-740-1210 ContactFacsimileTelephone: 843-740-1224 ContactElectronicMailAddress: csc@csc.noaa.gov Hours ofService: 8:00 am to 5:00 pm EST.MetadataStandardName: FGDC (Federal Geographic Data Committee) CSDGM (Content Standard for Digital Geospatial Metadata)MetadataStandardVersion: FGDC-STD-001-1998 21 Salem/ Hope Cre Question #: ENV-103.ek Environmental Audit -Post-Audit Information Category: Ecology Statement of Question: Please respond to the following question, which was raised during the Salem and HCGS License Renewal Environmental Audit.In the [License Renewal]. ERs Sec 4-13, for Salem and Hope Creek, owner/operators of the transmission lines conduct aerial and ground surveillance and maintenance to ensure design ground clearances do not change. How often are ground and/or aerial surveillance and maintenance undertaken? Response: The frequencies of ground and/or aerial surveillance and maintenance conducted by the owner/operator of transmission lines associated with Salem and HCGS are summarized in the table below.Frequency for Frequency for Activity Pepco Holdings, Inc. PSE&G Aerial Surveillance 1 per year to evaluate 2 per year (500 kV lines)equipment to evaluate equipment 2 per year to evaluate and vegetation vegetation Ground Surveillance Whenever aerial 1 per year to determine surveillance indicates vegetation maintenance need activities for the following year 1 per 5-years -Comprehensive Maintenance 4-year cycle for Annually for vegetation. vegetation (with most Otherwise, as needed recent cycle completed in based on aerial and 2009) ground surveillance 0 List Attachments Provided: NONE Salem/ Hope Creek Environmental Audit -Post-Audit Information Question #: Env-104A Category: Ecology Statement of Question: Check text regarding the lines in Section 3.1.6 of the ER (Transmission System), and Table 3.1-4 in regard to the following: -- Check text describing length of lines to ensure accuracy.Response: According to PSE&G's current GIS database of transmission line information, the length of the Salem-New-Freedom North line is 44.25 miles and the length of the Hope Creek-New Freedom line is 43.25 miles. PSEG Nuclear recommends the use of these line lengths in the NRC's Supplemental EIS for the Salem and Hope Creek License Renewals. The one-mile length difference between these two lines, which occupy a common right-of-way, is likely due to differences in turn radii when totaled over the length of the corridor.The length reported in Section 3.1.6 of the Salem and HCGS License Renewal Environmental Reports for the Salem-New Freedom North line (39 miles), which was built during the construction of Salem and is now connected to HCGS, was taken from the Salem FES (1973), page 3-24, 4 th paragraph. The length reported in Section 3.1.6 of the Salem and HCGS License Renewal Environmental Reports for the Hope Creek-New Freedom line (43 miles) which was built during the construction of HCGS but connected to Salem, was taken from the HCGS ER-Operating License Stage (1983), page 3.9-2, middle of the last paragraph. This length for the Hope Creek-New Freedom line is repeated in the HCGS-UFSAR, Rev 10 (1999), page 8.2-1, middle of last paragraph. Hence, a discrepancy exists between the current PSE&G information and the length reported in Section 3.1.6 of the Salem and HCGS License Renewal Environmental Reports for the Salem-New Freedom North line. There is no discrepancy for the Hope-Creek-New Freedom line.No historical information was found concerning the Salem-New Freedom North line that would explain why the length in PSE&G's current GIS database is different from the length reported in the Salem FES.List Attachments Provided: NONE Salem/ Hope Creek Environmental Audit -Audit Questions Question #: ENV-104B Category: Ecology Statement of Question: NJDEP "Utility Right-of-Way No-Harm Best Management Practices" (2009), as referenced in NJDEP 10/28/2009. (Note: from the binder titled,"Environmental Backup Documents" provided to the NRC at theSalem/Hope Creek environmental site audit.)Response: The document requested is being provided. List Attachments Provided: 1. "Utility Right-of-Way No-Harm Best Management Practices" (NJDEP 2009) ENV-104B, Attachment 1 NO ,PSEG NJ DEP, Div. Fish and Wildlife, Endangered and Nongame Species Program NJ DEP, Division of Land Use Regulation Developed in conjunction with PSEG, JCPL, ACE, and ORU Page 1 free(s) on or off ROW that couldcontact electric supply lines, or astructurally unsound tree that Danger/ Hazard could strike electric supply lines Tree Removal ifit fails. (ANSI A300 Part 7 2006, IVM). Tree(s) often topped and left for wildlife habitat.Control of vegetation using hand-Hand Cutting operated tools. Herbicide Stump Application of herbicides directly Treatment to cut stumps.Used only for reclamation or to create grass areas, ie; access lanesunder wire zone. Equipment used Radiarc Herbicide for this is typically a rubber-tired tractor and a radiarc spray nozzle. Includes high volume herbicide application. i'ithin5.mi c ibernacula it r'eas <1 tui%orm water: letain snags, e cauifon Use cation ,ing on .-. driving on ds to ,'X. roads to: withi 5.mi hibeinacula ii froidi wat~er: Ise caution riving i iads' toi: koid hitting hakes:..: Use cautio0ii:: roadsto :to avoid hittingsnakes : oK if no heavy A-,od Apr I 5-NovtI5 if' he" equip. usIed laiiitainý 00 ft (orsted riparian offer oneach s-ide: f stream Retain uffer area Avoid oin bdistu1rancea. Within buffer" arieal trees, & trees bark >22 cmdbh b Use cautioni: dvigon i1gd to.avoid hiitting snakes: Use caution driving oni roads to avoid hitting snakes OK if no heavy equip. use, Avoid Ap, I 5-N,,, I5 it heavy equip: se Ulse cautiioni": Use caution: airiving on 2!driving on: oads to roads tok ivoid hitting avoid hitting nke o, : I), s"nakes; Do sot broadcast not broadens serbicide herbicide herbicid NJ DEP, Div. Fish and Wildlife, Endangered and Nongame Species Program NJ DEP, Division of Land Use Regulation Developed in conjunction with PSEG, JCPL, ACE, and ORU Page 2 Golden-Bog Timber Wood Blue-spottedt G-rassland winaged Water-Utility ROW Management Activities Bald Eagie* Tluurtle indiana Batl Butterflies Rilleattlenake Snake Turtle Salamander Amphibians Bird arbler birds Mussels Wet, landsA. d -Within 5 mi of \Maintain 200 ft A voidt I hibernacula in forested riparian areas <1 mi -Avo id Aug1( Mow Avtid Ap1 buffer on each side Periodic cutting of grass on ROW , ithio 1,000 It o fRomat s..... 2 " ayl Aug 16pt M ar-A[oyl of str ... I. Retain Grass Mowing due to regulatory or public ftofnresang ,wtladls d /i ,1Aonear % eriiair & Sct h5iOct St Ao Apr ow No7%Mar concerns. & foraging Adjust tres & hrub (Cletho I' No I adus height o hI o slackýr I ,ouetruhu....." fgn :r digg Qt!ing Oc :i mower to6270%g hpAo~ closuref throughout~cnp buffers Dec hetghtof ith l&trs I diila) .. mower to 6-8 slas buffer area. Avoid l5.Au31 mnower wth> los May0 in;p'K ~ oil disturbance bark >ý22 cm ~~' ti ufrae dbh: .ithin buffer area.Undesirable vegetation foliage Avoid M I Do n use whi Jtreated using either a hose and -Istnc d Ag1 I " Us cautingon Udsevin on AvidA Selective Foliar nozzle from a rubber-tired spray wthtl 000 S 1d on dnving onMay N':l5 A vodI " AvoiF>- r1-ft of'estigith 100 ,' roads to roads* 11 in Ir I In un 1 O -A d I I bpe I Herbicide truck or a backpack sprayer. Psi atl t Jul15 Desirable vegetation is retained. biouce D1 1a, sr. e 30 and Includes noxious weed control, buffer Dee wetlands ul at -Ak snake-I s 15.AprA N I 15Aug 31 O'uh->55.'>..':ithin;mio '.1k , 'K ,Maintain 200 ft Nhibeacula in' void Apr 'forested riparian To prevent erosion from disubn Avroid My aroate I . a 30 &pr I -r buffer on each side beginning and to control erosion withip I 000fIo ter: Aug 30: MIsainrain N-la 30 v Mar i of stream. Retain Soil Erosion SepC, th,5 Retain snags ,'- -Sept 15 Oct, Set3 Avoi Ap ', Avi Apr 1 Aug Avoi Apropy Control that has started, it may be ft of nest thg n 100 necta oe ' Ior rvnR ve p 70% of canopy necessary to spread a grass seed & foraging lsbs (cl thr I Fd1 closure throughout mixture. bulters De s , a&ifoles )V buffer area. Avoid I -3i soil disturban c

5. rk >22:- c, within buffer area..K,"5' aintain 200 ft ,I a I m OK 5- i-forested riparian Minimal ROW disturbance, d May .. Iti Use ct heavy Avoid Apr 15 buffer on each side Tree Pruning/ typically involving removing ' 'ithi'I pt 15 frea sags, A drivian g on dnving on equip used AvoidM IJly Avoid Apr Aug Aug I Aoid ofstream.

Retain Mehnia Reai snagý,+ A% ol Apr: .A: fstem Rti encroaching tree branches but ft ofnesting.m . wItI n 1 s roads to roads to Avoid Apr I inornear veral 'K Remove, Apr 1 70% of canopy Pruning Along may include tree removal as & foranp f 1 4 1 shrubs LiiII avoid hitting avoid hitting 15-Nov IS pools 30 stack hip Aug 15 closure throughout needed. Teeee etlandewithak lsu buffer area. Avoid IAu3bark icf heay u- soil disturbance* -.within buffer area.NJ DEP, Div. Fish and Wildlife, Endangered and Nongame Species Program NJ DEP, Division of Land Use Regulation Page 3 Developed in conjunction with PSEG, JCPL, ACE, and ORU H 0 / I .iber wood ..te .." s Goladen -. *Bog I him er I od Il~ potted. V. r ad win itd. W Utility ROW Management Activities.

BaId Eagle* ITurtle .Indiana Bat* Butterflies Rattlesnake Pine Snake Turtle Salamander Amphibians Birds Warbler birds Mussels.<~~~~VL ., .,Uads A system of managing plant Withininin'2 50ft mi o I = o c =communities in which compatible Imboetecula in and incompatible vegetation is =. I f ',I ir= <1 mt e ... ....... Retain identified, action thresholds are No 1Sep t15 1 From water: -d,. td r .caopy .considered, control methods are AvoidApril I- IAvotdap AArii-A i I1ut bill Itegrate evaluated, and selected control(s) ithin 1tt 000 it of dead/dying Aug 3(1 1 Oc I FNv5 Avotd Mar I-July3 Aug I A ug IS Avoid a .'t -Io"ilVI t e r td a r e i m p l e m e n .t e d to a c h ie v a.n c.r.e p 3 0.f h.. .. ... ....

o w ... N o v -M a h % W ~ i 'aegtaio imleene toahiv ft of nesting wetads, trees, & trees LIiCCLeIF-Sou 3 Avt Mow Nn'- ttt, te mo' ia I ,ita tn or nenr N.era 31& ud1s Remiove, Apr 1- dirac w11 1ithin Vegetation specific objective. Choice of V foa \g Nk& adjust height oferao Management control methods is based on bu ffersa Dec i of bar se2 cm luse ): .bIcIde .I. mower to 6 tsash oF se h c! 1 effectiveness, environmental IS Aug3 me I , , dbh. Avotd Maylcricd 3V',I '"V .' thn20f impact, site characteristics, safety :1 herbicid n areasecurity and economics. (ANSI M'ayK1if necsat a vtdra A300 Part 7, 2006, Integrated IS1 .Vegetation Management) ,.'>> ,.== = =:V= -" prliun ..nPatrolling ROWs using No .=, "'.V:,* 'helicopters and/or on foot to disturbatnce Usc Use caution locate any areas of potential Pats reliability iss due to vegetatio w ithin 1000 Kdrvtng no driving onK Parlfeiblt susde tofvgt ou nst'ing O5K OK O roads to' roads to OK K ' OKOK0K K or other concerns. Aerial patrols & foraig ao hti avoi hitin typically conducted prior to foa i De' aod i ng v t h tg V== 'summer peak, foot patrols can be buffers DeAug I se conducted any time of year. IS Au3 V.55*'V Controlling undesirable saplings no ...May IS caution.Use caution.OK if no Do'.>,./ D not 1 s, 1 h1 on the ROW corridor in low to Aithi viI 1,00 heavy ].-._ driving on.diI.r"g'ei 2used; F Iriaran.I .i Basal H erbicide m ed stem density areas. M aterial I f'i t 1o o o't A void A(m i nim eI OK O A reug.Treatment used is applied in low-volume & fosgsng .te f avoidVI:s'Ia... avoid adp Jul " amounts to the bottom 12-18"bf buffers Dec wetLund snakes snakes ifheavy V .I-bark of stem(s) of vegetation. I5 Aug3; .IF V VV,.p 'Ve A IV-o Withins 5 mi of Minimally-selective means of I SI hIb Maintain 200 ft hibe acul in:: foeteaint a rian20 clearing undesirable vegetation, No wsithin 100 areas I mi Avoid April Avid Ap -tedripanutilizing different mowing units disturbance It A , f water ,I,0M n i N ;I buffe on....h side for different situations -remote within 1,000 wtld, Ra sa n -Sg O S 3 ANov of stream. Retain Brush Mowing areas, roadsides, wetlands, etc. ft of ntesing 0V.> I Ma m'dr near vf 31 &1ddtrs me OK 70% of canopy Brush Adjust K.~~~~~~K dead/dying shab (Ceithro 3 1 Avoid Mow Nov 1-Nv1 '&aduthtt0 h h f sak rci louetruhou Includes hydro-ax, ground line & foraging heigtf I tnigc....t ee. .t es.. .o i. .o e t i g u g c s I M ' c K I "m o w e r t o 6 -1 2 m V " V= l s r e t r u h u clearing, mowing as part of buffersý' Dec mowr't ILI '*"'.*' I,>s hie CF mower t s .. buffer area. Avoid Phragmites control, and structure IS ALI 3I in. Do. .".ihlose..... . ii ' > m soil disturbance site maintenance. udlin. h- within buffer area.NJ DEP, Div. Fish and Wildlife, Endangered and Nongame Species Program NJ DEP, Division of Land Use Regulation Page 4 Developed in conjunction with PSEG, JCPL, ACE, and ORU 0 0 'Bog ITi Line..snntteit Gra1ssland ýý winged Watler-i IUtility ROW Management Activities Bald Eagl" ITurtle Ilndiana Bat* lButterflies Rattlesnake IPine Snake: ITurtle l Salamander A-mphibians Birds \Warbler birds Mussels U lands No o id Nla 15 OK ifn Do not use I withn disturbd MayI1 1 Use caution Use caution heav 0fl w'ithinl 1,000 1 -Sp's 5 Au, driving on driving on, equip. used;AodMr,' 0 bfft rIpaiaHerbicide Stump Application ofherbicides directly (minimd i Avoid AprI -Aug Aod a Treatment to cut stumps. & fol Rl ` posibl I id hitin avoi hitn 1No 15 30 JIt eesr v bufr we tlad j' .,' nakes snakes fev 15 -Aug3o equip.rused Used only for reclamation or to No oid May I Use caution Use caution D, create grass areas, ic; access lanes disturb15a ay , driving on driving on Do n(Iiotu withi under wire zone. Equipment used Within ,1 000( roads to roads to 2 in rItan-In Radiarc Herbicide for this is typically a rubber-tired ftofntig D u ss"' Do ot ' avoid hitiing avoid hitting I u 1nota b r atractor and a radiarc spray nozz.. & foraging snakes; Do snakes; Do necesar av Includes high volume herbicide buffers D cJu not broadcast not broadcast Aug 1-Nov " application.. h5 erbilicide herbicide Re-establishing IVM on a ROW , that is not currently managed to Wit rin 5 mi of'. M in.ain 200...the full extent of its easement or " Id Ma hibernacula in 10fo rt ripananownership rights and intended [-etI areas <1 mi ' Avoid A I bue o c siepurpose. Conditions on a ROW n in lt from water: AvoId A. Aug ], Mw A I I of, t- I, taI need of re-claiming include tall, from wNter: Avoid Apr I Aug A g 16 7( o p dense amounts of undesirable d Retain snags, Au3 I w 1, A Jane I i s Avi M 1 1Jul 30 McswNov-Mar within...1s000 wetlandsledead/dying neta sorc ay3 & adus Reo v egeta tio n , an d elec tric su p p ly d e s, & trees 3 1 1 O K :- 1 Reclamation v et0 vi o tres in oree nea v rnal &djrhigt o f 6-12 , ht of s or chip 01'> bufr are I vt~lines that are inaccessible. o tt' tre s e (C' i ro ,e't& oain egh f with loose, I mfolDo) Do initial non-selective methods of d b .Avo IdM 'c 's'" ' b h b i ,' 'I Ii 'd '> i Do not use mowing or hand-cutting, or t Aug1 1 d herbic dbidec lirbihide witbi broadcast application of broacas May 15 h c-Aug :': ebcie':200 ft: ripl:atIa herbicides. (ANSI A300 Part 7, 1etid" 5 M A' :... buferar..2006, Integrated Vegetation ':.'7'Management) .'M aintain 200 0 hibernacula in F'orested riparia disturbance' w ihi froa.m Avoid April A buffer on each side Periodic cutting ofgrass on ROW Within I 0 fromo water: At g .30; tAv I l ' g r ' " f stream. RetainRoutine Grass Petain snags, r, rn Avid A% ',due to regulatory or public it :r Sept SA1 OK1 70%'of canopy Mowing & fonIead/dying ' ', tree ta closure throughout buffers Dee he i t esI &r awnifotia)" " e II sla s huffer area. Avoid 15 Aug3 A 1 mw t w ;o':s' llis" 7".* .4157 soil disturbancewithin buffer area.NJ DEP, Div. Fish and Wildlife, Endangered and Nongame Species ProgramNJ DEP, Division of Land Use Regulation Page 5 Developed in conjunction with PSEG, JCPL, ACE, and ORU IB.o Wood ."Bluespotted " Grassland Winged Wa STurtle Salamander .Amphibians lBrds-. Warbler "birn Utility ROW.Selective Foliar Herbicide To prevent erosion from beginning and to control erosion Control that has started, it may be necessary to spread a grass seed mixture.Tree Pruning/Mechanical Pruning Along ROW Edge Low Impact: vegetation within corridor is minimally affected by maintenance activity Medium impact: some vegetation is affected, some is not affected by activityHigh Impact: most of vegetation is affected by activity.

• The US Fish and Wildlife Service should also be consulted in areas where federally-listed species are present NJ DEP, Div. Fish and Wildlife, Endangered and Nongame Species Program NJ DEP, Division of Land Use Regulation Developed in conjunction with PSEG, JCPL, ACE, and ORU Page 6 0}}