ML102990043

Revised Biological Assessment for License Renewal of the Indian Point Nuclear Generating Plant, Units 2 and 3

ML102990043
Person / Time
Site:	Indian Point
Issue date:	12/10/2010
From:	David Wrona License Renewal Projects Branch 2
To:	Colligan M US Dept of Commerce, National Oceanographic and Atmospheric Administration
Stuyvenberg, A L, NRR/DLR, 415-4006
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ML102990042	List: ML102990043 ML102990046
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Download: ML102990043 (27)

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 10,2010 Ms. Mary A. Colligan Assistant Regional Administrator for Protected Resources U.S. Department of Commerce National Oceanic and Atmospheric Administration National Marine Fisheries Service Northeast Region One Blackburn Drive Gloucester, MA 01930-2298

SUBJECT:

REVISED BIOLOGICAL ASSESSMENT FOR LICENSE RENEWAL OF THE INDIAN POINT NUCLEAR GENERATING PLANT, UNIT NOS. 2 AND 3

Dear Ms. Colligan:

The U.S. Nuclear Regulatory Commission (NRC) staff has prepared a revised biological assessment (BA) for the proposed license renewal of Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3). The BA is included as the enclosure to this letter. The NRC staff is conveying this revised BA in response to your letter dated February 24, 2009, which indicated that formal consultation under Section 7 of the Endangered Species Act could not begin until NRC submitted additional information or explained why certain information is not available. The enclosed BA contains, wherever possible, the requested information. As noted in our initial consultation letter dated December 22, 2008, the proposed action (license renewal) involves continued operation of IP2 and IP3 for 20 years beyond their current license expiration dates of 2013 and 2015, respectively. The proposed action (license renewal) is not a major construction activity.

On August 16, 2007, the NRC requested that the National Marine Fisheries Service (NMFS) provide lists of Federally listed endangered or threatened species and information on protected, proposed, and candidate species, as well as any designated critical habitat, that may be in the vicinity of IP2 and IP3 and their associated transmission line right-of-ways. The NMFS responded to the NRC request on October 4, 2007, and indicated that the Federally listed endangered shortnose sturgeon (Acipenser brevirostrum) and the candidate species Atlantic sturgeon (Acipenser oxyrinchus) should be considered for potential impacts of license renewal and operation.

In its letter of December 22, 2008, the NRC staff found that renewal of the operating licenses of IP2 and IP3 to include another 20 years of operation could adversely affect the population of shortnose sturgeon in the Hudson River through impingement and thermal impacts. NRC staff indicated, in the 2008 BA, that it was unable to determine the specific impacts to shortnose sturgeon of continued IP2 and IP3 operation.

On February 24, 2009, NMFS responded to NRC and indicated that additional information would be necessary before NMFS could begin its consultation regarding the shortnose sturgeon. NMFS requested four types of information from NRC:

M.Colligan -2

1. Corrections to the life history section of the SA;

2. Additional information on impingement and impingement mortality;

3. Estimates of thermal impacts; and

4. Closed-cycle cooling and the National Pollutant Discharge Elimination System (NPDES) perm it process.

Item 1: Corrections to life history The NRC staff has updated the life history of the shortnose sturgeon as suggested in the February 24, 2009, NMFS letter.

Item 2: Additional information on impingement and impingement mortality The NRC staff requested additional data from Entergy Nuclear Operations, Inc. (Entergy)

(owner and operator of IP2 and IP3), and has included the additional data provided by Entergy in the attached SA. These data include the level of monitoring effort, dates of impingements, and size and condition of impinged fish. As reported in the NRC staff's 2008 SA and reiterated by NMFS, no impingement monitoring has occurred since traveling Ristroph-type screens were installed at the facility in 1991.

The NRC staff has not identified any relevant data regarding impingement rates for shortnose sturgeon at similar facilities with Ristroph screens. The NRC staff assumes, however, that impingement has increased proportionately with the Hudson River shortnose sturgeon population. Additionally, the NRC staff did not identify any information resources that could assist the staff in developing mortality rates for shortnose sturgeon after impingement at a facility similar to IP2 and IP3. As noted by the NRC staff and NMFS, however, Ristroph screens may have reduced impingement mortality. In view of the lack of any more recent data, the NRC staff suggests that pre-1991 impingement numbers with a 100 percent mortality rate could be used to estimate current impingement mortality.

Item 3: Estimates of thermal impacts As NMFS is likely aware, the New York State Department of Environmental Conservation (NYSDEC) has requested that Entergy perform a three-dimensional thermal study of the Hudson River near Indian Point to determine plume extent and characteristics. The NRC staff understands that Entergy will be providing model and verification data to NYSDEC in the coming year. At this point, the NRC staff has no basis for estimating the temporal and spatial extent of thermal plume that exceeds 28 degrees Celsius.

Item 4: Closed-cycle cooling and the NPDES permit process As NMFS is aware, SPDES proceedings involving Entergy and NYSDEC are in progress at this time. For water quality matters, the NRC staff defers to NYSDEC, to which the U.S. Environmental Protection Agency has delegated Clean Water Act authority. If NYSDEC determines that cooling towers must be installed at IP2 and IP3, the NRC would review the proposed implementation to the extent that installation could affect safe operations at IP2 and IP3. If the proposed installation of that requirement has no effect on safety-related plant systems, structures, or components, then the NRC would have no role in

M. Colligan - 3 approving a proposed cooling tower retrofit. The current SPDES permit does not require closed-cycle cooling or cooling towers and has been administratively extended since 1992.

NMFS requested information about the potential outcome of the ongoing NYSDEC adjudicatory process. On this matter, the NRC staff will continue to defer to NYSDEC, its internal schedules, and its delegated authority under the Clean Water Act. Given the permit's long history of administrative extension and contentious adjudication, the NRC staff cannot predict when a final permit will be issued and what requirements will exist in the final permit. The NRC staff notes that Entergy and NYSDEC are parties to an additional adjudicatory proceeding relating to the SPDES permit in the New York State civil court system. That proceeding also is in progress at this time.

The NRC staff concludes, in the Final Supplemental Environmental Impact Statement Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3, (NUREG-1437, Supplement 38) that the impacts of another 20 years of IP2 and IP3 operation to the endangered shortnose sturgeon, due to entrainment and impingement, would be small (FSEIS, 4-20). Regarding the impact of heated plant discharges, the NRC staff analysis of young-of-year shortnose sturgeon in the Hudson River could not resolve a population trend, although other investigators using other methods found a trend of increasing abundance in the overall, mixed-age population.

These observations are consistent with NRC's definition of a small level of impact in that any possible adverse effect is not detectable and is not destabilizing the population. This conclusion is based on NRC's specific definitions of small, moderate, and large impact levels as published in the NRC's Generic Environmental Impact Statement for License Renewal of Nuclear Plants and codified in NRC's 10 CFR Part 51 regulations that implement the National Environmental Policy Act.

For the purpose of the enclosed revised SA - prepared pursuant to the Endangered Species Act - the staff determines that renewal of the operating licenses for an additional 20 years could possibly have an adverse effect on the shortnose sturgeon population in the Hudson River, depending on the effects of thermal discharges. Further, NYSDEC has indicated that thermal discharges from the power plant may have an adverse affect on aquatic life. Sufficient information is not available at this time for the NRC staff to quantify the extent to which the population could be affected by thermal discharges, though proceedings between the NYSDEC and Entergy are currently underway that may provide additional information.

We are requesting your concurrence with our determination. In reaching its conclusion, the NRC staff relied on information provided by the applicant, on research performed by NRC staff and on information from NMFS (including a current listing of species provided by the NMFS). If

M. Colligan -4 you have any questions regarding this BA or the NRC staff's request, please contact Mr. Andrew Stuyvenberg, Environmental Project Manager, at 301-415-4006 or bye-mail at Andrew.Stuyvenberg@nrc.gov.

Sincerely, OJ9 David J. Wrona, Chief Projects Branch 2 V

Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-247 and 50-286 cc wI encl: Distribution via Listserv

Biological Assessment Indian Point Nuclear Generating Plant, Unit Nos. 2 and 3 License Renewal December 2010 Docket Nos. 50-247 and 50-286 U.S. Nuclear Regulatory Commission Rockville, Maryland

Revised Biological Assessment of the Potential Effects on Federally Listed Endangered or Threatened Species from the Proposed Renewal of Indian Point Nuclear Generating Plant, Unit Nos. 2 and 3 Introduction and Purpose The U.S. Nuclear Regulatory Commission (NRC) staff prepared this biological assessment (BA) to support the supplemental environmental impact statement (SEIS) for the renewal of the operating licenses for Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3), located on the shore of the Hudson River in the village of Buchanan, in upper Westchester County, New York. The current 40-year licenses expire in 2013 (IP2) and 2015 (IP3). The proposed license renewal for which this BA has been prepared would extend the operating licenses to 2033 and 2035 for IP2 and IP3, respectively.

The NRC is required to prepare the SEIS as part of its review of a license renewal application.

The SEIS supplements NUREG-1437, Volumes 1 and 2, "Generic Environmental Impact 1

Statement for License Renewal of Nuclear Plants (GElS)," (NRC 1996, 1999) for the license renewal of commercial nuclear power plants. The SEIS covers specific issues, such as the potential impact on endangered and threatened species, that are of concern at IP2 and IP3 and that could not be addressed on a generic basis in the GElS. The NRC staff published the draft SEIS in December 2008 (NRC 2008) and published the final SEIS on December 3, 2010 (NRC 2010).

Pursuant to Section 7 of the Endangered Species Act of 1973 (ESA), as amended, the NRC staff requested, in a letter dated August 16, 2007 (NRC 2007), that the National Marine Fisheries Service (NMFS) provide information on Federally listed endangered or threatened species, as well as on proposed or candidate species, and on any designated critical habitats that may occur in the vicinity of IP2 and IP3. In its response, dated October 4,2007 (NMFS 2007), NMFS expressed concern that the continued operation of IP2 and IP3 could have an impact on the shortnose sturgeon (Acipenser brev;rosfrum) , an endangered species that occurs in the Hudson River. NMFS also noted that a related species that also occurs in the Hudson River, the Atlantic sturgeon (Acipenser oxyrinchus), is a candidate species for which NMFS has proposed listing as endangered. The NRC staff has corresponded with NMFS regarding the Atlantic sturgeon, and requests that NMFS address Atlantic sturgeon to the extent appropriate (NMFS 2010).

Under Section 7, the NRC is responsible for providing information on the potential impact that the continued operation of IP2 and IP3 could have on the Federally listed species, the shortnose sturgeon. In addition, the NRC has prepared information regarding the potential impact on important species, including the Atlantic sturgeon; this information can be found in Chapters 2 and 4 of the SEIS (NRC 2010).

The NRC staff relied on data originally supplied by the applicant, Entergy Nuclear Operations, Inc. (Entergy) in preparing the BA for IP2 and IP3 in the draft SEIS (Entergy 2007b) but a The GElS was originally issued in 1996. Addendum 1 to the GElS was issued in 1999. Hereafter, all references to the "GElS" include the GElS and its Addendum 1.

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subsequently questioned the impingement data supplied by Entergy. The NRC staff sought, and Entergy later submitted revised impingement data (Entergy 2009). Mathematical errors in the original data submitted to the NRC (Entergy 2007b) apparently resulted in overestimates of the take of shortnose sturgeon that the NRC staff presented in the previous BA. The NRC staff found that the differences in the original (Entergy 2007b) and revised (Entergy 2009) data were of sufficient magnitude to possibly affect the staffs conclusions and has issued this revised biological assessment based on the revised data.

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

Site Description IP2 and IP3 are located on a 239-acre (97-hectare) site on the eastern bank of the Hudson River in the village of Buchanan, Westchester County, New York, about 24 miles (mi)

(39 kilometers [kmJ) north of New York City, New York (Figures 1 and 2). Privately owned land bounds the north, south, and east sides of the property (Figure 3). The area is generally described as an eastern deciduous forest, dominated by oak (Quercus), maple (Acer) , and beech (Fagus) species. The lower Hudson River is a tidal estuary, flowing 152 miles (244 km) from the Federal Dam at Troy, New York, to the Battery in New York City. IP2 and IP3 are located at River Mile (RM) 43 (RKM 69), where the average water depth is 40 feet (ft) (12 meters [m]), and the average width of the river is 4500 ft (1370 m). The Hudson River is tidal all the way to the Federal Dam, and the salinity zone in the vicinity of the facility is oligohaline (low salinity, ranging from 0.5 to 5 parts per thousand (ppt>>, with the salinity changing with the level of freshwater flow. Water temperature ranges from a winter minimum of 34 degrees Fahrenheit (F) {1 degree Celsius (C>> to a summer maximum of 77 degrees F (25 degrees C)

(Entergy 2007a).

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

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- HIgI'MWJ o 71** 1,c.'09.SDO NIIorFlDIIIII 1.00a.51 0 - e,:!DI,35S am>> a.-,SISoII- 17,3140,042 o :iii G 12 1&

Source: Entergy 2007a Figure 1: Location of IP2 and IP3, 50-mile (80-km) radius

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Source: Entergy 2007a Figure 2: Location of IP2 and IP3, 6-mile (10-km) radius

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PlANT TRUE NORTH NORTH BROADWAY PROPERTY LINE 1SF'Sl_-.._ --.JJ UNIT 2 INTAKE ElECTRICAl

~~I

~Qd SWlTCHYARD UNIT 1--

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UNIT 3-~

EXCLUSION AREA BOUNDARY a

eNERCON SERVICES, INC.

INDIAN POINT 2 AND 3 SITE EXCl.USION AREA AND FFATURFS MTAAI.IIGTON, HJ Source: Entergy 2007a Figure 3: IP2 and IP3 property boundaries and environs

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

Each unit has seven intake bays (Figure 4), into which the river water flows, passing under the floating debris skimmer wall and through Ristroph traveling screens (Figure 5). IP2 has six dual-speed circulating water pumps that can each pump 140,000 gallons per minute (gpm)

(8.83 cubic meters per second [m 3/s]) at full speed and 84,000 gpm (5.30 m3/s) at reduced speed; at full speed, the approach velocity is approximately 1 foot per second (fps) (0.30 meters per second [m/s]) and at reduced speed, the approach velocity is 0.6 fps (0.2 m/s). IP3 also has six dual-speed circulating water pumps. The full speed flow rate of each of these pumps is 140,000 gpm (8.83 m3/s), with a 1 fps (0.30 m/s) approach velocity; the reduced speed is 64,000 gpm (4.04 m3/s), with a 0.6 fps (0.2 m/s) approach velocity (Entergy 2007a).

--

T Source: Entergy 2007a Figure 4: IP2 intake structure (left) and IP3 intake structure (right)

The traveling screens employed by IP2 and IP3 are modified vertical Ristroph-type traveling screens installed in 1990 and 1991 at IP3 and IP2, respectively. The screens were designed in concert with the Hudson River Fishermen's Association, with screen basket lip troughs to retain water and minimize vortex stress (CHGEC 1999). Studies indicated that, assuming the screens continued to operate as they had during laboratory and field testing, the screens were "the screening device most likely to impose the least mortalities in the rescue of entrapped fish by mechanical means" (Fletcher 1990). The same study concluded that refinements to the screens would be unlikely to greatly reduce fish kills.

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Source: Entergy 2007a Figure 5: IP2 intake system (left) and IP3 intake system (right)

There are two spray-wash systems-the high-pressure spray wash removes debris from the front of the traveling screen mechanism; the low-pressure spray washes fish from the rear of the mechanism into a fish sluice system to return them to the river. A 0.25 x 0.5-inch (in.)

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

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

Shortnose sturgeon can grow up to 143 cm (56 in.) in total length and can weigh up to 23 kilograms (kg) (51 pounds [Ib]). Females are known to live up to 67 years, while males typically do not live beyond 30 years. As young adults, the sex ratio is 1:1; however, among fish larger than 90 cm (35 in.), measured from nose to the fork of the tail, the ratio of females to males increases to 4: 1. Throughout the range of the shortnose sturgeon, males and females mature at 45 to 55 cm (18 to 22 in.) fork length, but the age at which this length is achieved varies by geography. At the southern extent of the sturgeon's range, in Florida, males reach maturity at age two, and females reach maturity at six years or younger; in Canada, males can reach maturity as late as 11 years, and females, 13 years. In one to two years after reaching

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maturity, males begin to spawn at two-year intervals, while females may not spawn for the first time until five years after maturing and, thereafter, spawn at three- to five-year intervals (Dadswell et al. 1984).

In the Hudson River. shortnose sturgeon migrate into freshwater to spawn during late winter or early summer when water temperatures are between 8 and 15 degrees C (NMFS 2009). Eggs sink and adhere to the hard surfaces on the river bottom, hatching after 4 to 6 days. Larvae consume their yolk sac and begin feeding in 8 to 12 days. as they migrate downstream away from the spawning site. remaining close to the river bottom (Kynard 1997; Collette and Klein MacPhee 2002). The juveniles, which feed on benthic insects and crustaceans. do not migrate to the estuaries until the following winter. where they remain for three to five years. As adults, they migrate to the near-shore marine environment, where their diet consists of mollusks and large crustaceans (Dadswell 1984).

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

The Hudson River population of the shortnose sturgeon was estimated to be approximately 13.000 adults in 1979-1980. Based on population studies done in the mid-1990s, the population has apparently increased as much as 400 percent since then, up to almost 57,000 adult fish. Bain et al. (2007) suggested that the total population of the shortnose sturgeon in the Hudson River is approximately 61,000. including juveniles and nonspawning adults, although NMFS (2009) indicates that the adult population may be less than half that size (approximately 30.000 individuals). Woodland and Secor (2007) ascribed the population growth to several strong year-classes and two decades of sustained annual recruitment. Bain et al.

(2007) maintained that the annual trawl surveys conducted by the electric utilities (CHGEC 1999) show an increase in abundance between the mid-1980s and mid-1990s.

supporting the finding that the Hudson River population has increased. The NRC staff assessed the population trend for yearling and older shortnose sturgeon in the fall juvenile survey data provided by the applicant and found a small but statistically significant increase in the catch-per-unit-effort from 1975 to 2005.

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

Shortnose sturgeon larvae grow rapidly. and. after a few weeks. they are too large to be

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entrained by the cooling intake (DadsweIl1979). Because the egg and larval life stages of the shortnose sturgeon (the life stages susceptible to entrainment) are not found near the intake for IP2 and IP3, the probability of their entrainment at IP2 and IP3 is low.

IP2 and IP3 monitored entrainment from 1972 through 1987. Entrainment monitoring became more intensive at Indian Point from 1981 through 1987, and sampling was conducted for nearly 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, four to seven days per week, during the spawning season in the spring (NMFS 2000). Entrainment monitoring reports list no shortnose sturgeon eggs or larvae at IP2 and IP3. NMFS (2000) lists only eight sturgeon larvae collected at any of the mid-Hudson River power plants (all eight were collected at Danskammer, and four of the eight may have been Atlantic sturgeon). Entrainment sampling data supplied by the applicant (Entergy 2007b) include large numbers of larvae for which the species could not be determined, although sturgeon larvae are distinctive and most likely were identified when they occurred. Entergy currently conducts no monitoring program to record entrainment at IP2 and IP3, and any entrainable life stages of the shortnose sturgeon taken in recent years would go unrecorded.

Based on the life history of the shortnose sturgeon, the location of spawning grounds within the Hudson River, and the patterns of movement for eggs and larvae, the number of shortnose sturgeon in early life stages entrained at IP2 and IP3 is probably low or zero. The available data from past entrainment monitoring do not indicate that entrainment was occurring. Therefore, the NRC staff concludes that the continued operation of Indian Point for an additional 20 years is not likely to adversely affect the population of shortnose sturgeon in the Hudson River through entrainment.

Impingement IP2 and IP3 monitored impingement of most fish species daily until 1981, reduced collections to a randomly selected schedule of 110 days per year until 1991, and then ceased monitoring in 1991 with the installation of the modified Ristroph traveling screens. IP2 and IP3 monitored the impingement of sturgeon species daily from 1974 through 1990 (Entergy 2009). As described in Section 2.2.5.3 of the 2008 draft SEIS (NRC 2008) and the final SEIS (NRC 2010), the Ristroph screens, installed in 1990 and 1991, were designed in a collaborative effort with the Hudson River Fishermen's Association to minimize the mortality of impinged fish.

In 2000, NMFS prepared an environmental assessment (EA) for the incidental take of shortnose sturgeon at Roseton and Danskammer (NMFS 2000). The EA included the estimated total number (Table 1) of shortnose sturgeon impinged at Roseton, Danskammer, Bowline Point, lovett, and IP2 and IP3, with adjustments to include the periods when sampling was not conducted.

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

-,P=-o_w-.,.e,-r_P..",
a_n:-t_____T~o."..ta-I--lm--.l..pingedlYear Total ImpingedlYear Bowline Point 23 0.9 0 0 Lovett 0 0 0 0 IP2 37 1.4 8 0.8 IP3 26 1.0 8 0.8 Roseton 49 1.8 15 1.5 Danskammer Point 140 5.2 44 4.4 Total 275 10.2 75 7.5 Source: Adapted from NMFS 2000.

Entergy (2009) provided revised shortnose sturgeon impingement data (Table 2), which are available through the NRC's online Agencywide Documents Access and Management System (ADAMS). The average impingement rate of shortnose sturgeon at IP2 and IP3 combined from 1975 through 1990 is about four fish per year. Appendix 1 to this BA reproduces detailed information from Entergy (2009) on the impinged fish. These data are the most recent and complete available.

An increase in the population of shortnose sturgeon in the Hudson River would most likely result in an increase in impinged shortnose sturgeon at IP2 and IP3. If the population data presented by Bain et al. (2007) and Woodland and Secor (2007) are accurate, then a four-fold increase in population between the mid-1980s and mid-1990s could result in a similar increase in impingement rates. Impingement data (Table 2), however, do not increase concomitantly with population through 1990. A population increase would mean that the population-level effect of taking an individual shortnose sturgeon would decrease.

When considering the effects of impingement, it is important to consider the affected species' impingement mortality rate. For IP2 and IP3, however, there are few data regarding the survival of the shortnose sturgeon after impingement. In 1979, NMFS issued a biological opinion (BO) relating to the take of shortnose sturgeon at Indian Point (DadsweIl1979). At the time, there was only one year in which records describing the status of impinged shortnose sturgeon were kept. In that year, 60 percent of collected impinged shortnose sturgeon were dead when collected. The BO assumed both that all dead sturgeon died as a result of the impingement and that no impingement-related mortality occurred after the impinged sturgeon were released.

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Table 2: Estimated* Numbers of Impinged Shortnose Sturgeon from Impingement Monitoring at Indian Point Units 2 and 3 Year Unit 2 Unit 3 1975 3 NA 1976 2 o 1977 11 2 1978 5 5 1979 4 3 1980 o 2 1981 o o 1982 o o 1983 o o 1984 3 2 1985 o o 1986 o o 1987 o 2 1988 7 2 1989 o 2 1990 3 o Yearly Mean 2.8 1.2 Sum of Unit 4.0 Yearly Means

• Numbers are corrected for collection effiCiency and then rounded to whole numbers.

NA means data not available.

Source: Entergy 2009, ML091950345 The BO estimated that, in a worst-case scenario, 35 shortnose sturgeon would be impinged at IP2 and IP3 per year, and that 60 percent (21 individuals) would die on the intake screens. At the time, the population of adult shortnose sturgeon in the Hudson River was estimated to be 6,000, and this level of mortality would result in a 0.3 to 0.4 percent death rate caused by impingement at IP2 and IP3 (Dadswell 1979). The average yearly impingement rate from 1975 through 1990 based on revised data (Entergy 2009) is about four shortnose sturgeon, a rate almost an order of magnitude lower than Dadswell's (1979) worst-case assumption of 35 fish per year in the BO. Also, as stated above, the population of shortnose sturgeon in the Hudson River has increased and the population-level effect of IP2/1P3 impingement is thus lower than was previously estimated by NMFS in its BO.

Because all monitoring of impingement ceased after the Ristroph screens were installed in 1991, no updated mortality rate estimates for impinged shortnose sturgeon exist at IP2 and IP3.

The NRC staff does not know the current level of impingement or the level of mortality.

Although the laboratory and field tests (Fletcher 1990) performed on the modified Ristroph screens were not conducted using the shortnose sturgeon, the tests did show that injury and death were reduced for most species when compared to the first version of screens that were proposed (and rejected, based on their "unexceptional performance") (Fletcher 1990). If the NRC staff assumes that the modified Ristroph screens performed as well as the Fletcher'S 1990 results indicated, then mortality and injury from impingement would be lower than reported by the NMFS in its BO (DadsweIl1979), and the impact to the species would be less. Without current monitoring, however, the NRC staff cannot confirm this.

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In its 80, NMFS (Dadswell 1979) found that that operation of IP2 and IP3 is "not likely to jeopardize the continued existence of the shortnose sturgeon because, even assuming 100%

mortality of the impinged fish, its contribution to the natural annual mortality is negligible." The NRC staff finds that the best estimate of takes of shortnose sturgeon by IP2 and IP3 based on revised data (Entergy 2009) is much less than that assumed by Dadswell (1979) in the NMFS 80, that installation of Ristroph screens since the original 80 was prepared may have decreased the mortality rate of shortnose sturgeon that are impinged, and that the population of shortnose sturgeon in the Hudson River is increasing although impingement rates appear not to have increased concomitantly through 1990. The NRC staff recognizes the difficulties in drawing conclusions from two-decade old impingement data and incomplete impingement mortality data, but concludes that, based on the best available information, impingement and entrainment resulting from operation of IP2 and IP3 for an additional 20 years beyond the original license term are not likely to jeopardize the continued existence of the endangered shortnose sturgeon in the Hudson River.

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

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

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

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

The final environmental impact statement (FEIS) associated with the SPDES permit for IP2 and IP3 (NYSDEC 2003) concludes that "Thermal modeling indicates that the thermal discharge from Indian Point causes water temperatures to rise more than allowed." The thermal modeling referred to in the FEIS appears to represent a worst-case scenario; the modeling indicates the potential for the discharges from IP2 and IP3 to violate the conditions of the IP2 and IP3 SPDES permit, which could result in a negative impact on the shortnose sturgeon. IP2 and IP3 have not yet completed triaxial thermal studies, to completely assess the size and nature of the thermal plume created by the discharge from IP2 and IP3 and the possible impact on the sturgeon. The NRC staff understands, however, that Entergy has collected triaxial thermal data, and will submit a final, verified thermal model to NYSDEC in the next year.

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

Although the area closest to the discharge from IP2 and IP3 can exceed these temperatures, the summer maximum temperature of the Hudson River in the area of IP2 and IP3 is 77 degrees F (25 degrees C) (Entergy 2007a). The combined discharge from both Indian Point units is about 1.75 million gpm (110 m3/s), including the service water (Entergy 2007a).

Table 3 presents the net downstream flow (controlling for the influence of tides) of the Hudson River at Indian Point. These data suggest that discharges from IP2 and IP3 equal, at most, 15% of the river flow 20% of the time, while up to 2% of the time, IP2 and IP3 discharges equal 97% or more of the downstream river flow. This variation due to differences in seasonal precipitation, tidal influence, and other factors - suggests that discharges may mix in very different ways under different conditions.

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

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

Conclusion Renewal of the operating licenses of IP2 and IP3 to include another 20 years of operation could potentially adversely affect the population of shortnose sturgeon in the Hudson River due to the

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thermal effects of once-through cooling. An analysis of the revised impingement data recently submitted by Entergy indicates that impingement and entrainment would not adversely affect the population of shortnose sturgeon. Sufficient information is not available at this time for the NRC staff to quantify the extent to which the shortnose sturgeon population could be affected by thermal effects, though forthcoming data is likely to provide additional information.

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

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

http://www.plosone.org/article/info%3Adoi%2F1 0.1371 %2Fjournal.pone.0000168#s3 on December 11, 2007.

Central Hudson Gas and Electric Corporation (CHGEC), Consolidated Edison Company of New York, Inc., New York Power Authority, and Southern Energy New York. 1999. "Draft Environmental Impact Statement for State Pollutant Discharge Elimination System Permits for Bowline Point, Indian Point 2 and 3, and Roseton Steam Electric Generating Stations." ADAMS Accession No. ML083400128.

Collette, B.B. and Klein-MacPhee, G., eds. 2002. "Short-nosed sturgeon," Bigelow and Schroeder'S Fishes of the Gulf of Maine, Third Edition, Smithsonian Institution Press:

Washington, DC.

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

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

http://www.nmfs.noaa.gov/pr/pdfs/species/shortnosesturgeon biological data.pdf on December 11, 2007.

Entergy Nuclear Operations, Inc. (Entergy). 2007a. "Applicant's Environmental Report, Operating License Renewal Stage (Appendix E to Indian Point, Units 2 & 3, License Renewal Application)," April 23, 2007. ADAMS Accession No. ML071210530.

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

Reference NL-07-156.

Subject:

Entergy Nuclear Operations, Inc., Indian Point Nuclear Generating Unit Nos. 2 & 3, Docket Nos. 50-247 and 50-286, Supplement to License Renewal Application (LRA)-Environmental Report References. December 20,2007. ADAMS Accession Nos. ML080080205, ML080080209, ML080080213, ML080080214, ML080080216, ML080080291, ML080080298, ML080080306.

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Entergy Nuclear Northeast (Entergy). 2009. Letter from F. Dacimo, Vice President, Entergy Nuclear Northeast, to U.S. Nuclear Regulatory Commission Document Control Desk.

Reference NL-09-091.

Subject:

Transmission of Additional Requested Information Regarding Sturgeon Impingement Data Indian Point Nuclear Generating Unit Nos. 2 & 3 Docket Nos. 50 247 and 50-286 License Nos. DPR-26 and DPR-64. July 1, 2009. ADAMS Accession No.

ML091950345.

Fletcher, R.I. 1990. "Flow dynamics and fish recovery experiments: water intake systems,"

Transactions of the American Fisheries Society 119:393-415.

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

National Marine Fisheries Service (NMFS). No date. "Shortnose Sturgeon (Acipenser brev;rostrum}," Office of Protected Resources (OPR). Accessed at:

http://www.nmfs.noaa.gov/prlspecies/fish/shortnosesturgeon.htm on December 11,2007.

ADAMS Accession No. ML083430566.

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

http://www.nmfs.noaa.gov/pr/pdfs/recoverylsturgeon shortnose.pdf on December 11, 2007.

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

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

Subject:

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

October 4, 2007. ADAMS Accession No. ML073340068.

National Marine Fisheries Service (NMFS). 2009. Letter from M. Colligan, Assistant Regional Administrator for Protected Resources, National Marine Fisheries Service to Chief, Rules and Directives Branch, U. S. Nuclear Regulatory Commission.

Subject:

Biological Assessment for License Renewal of the Indian Point Nuclear Generating Unit Nos. 2 and 3. February 24, 2009.

ADAMS Accession No. ML090820316.

National Marine Fisheries Service (NMFS). 2010. E-mail correspondence from J. Crocker to D. Logan, NRC. November 10, 2010. ADAMS Accession No. ML103400027.

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

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

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

Nuclear Regulatory Commission (NRC). 2007. Letter from R Franovich to Mr. Peter Colosi, National Marine Fisheries Service, Gloucester, Massachusetts, "Re: Request for List of Protected Species and Essential Fish Habitat Within the Area under Evaluation for the Indian Point Nuclear Generating Unit Nos. 2 and 3 License Renewal Application Review,"

August 16, 2007. ADAMS Accession No. ML072130388.

Nuclear Regulatory Commission (NRC). 2008. "Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants: Supplement 38, Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3, Draft Report for Comment." NUREG-1437, Supplement 38, Volumes 1 & 2. December 22, 2008. Washington, DC. ADAMS Accession No. ML083540594.

Nuclear Regulatory Commission (NRC). 2010. "Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Supplement 38, Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3, Final Report." Final NUREG-1437, Supplement 38, Volumes 1, 2, and 3. December 3,2010. Washington, DC. ADAMS Accession Nos. ML103350405, ML103350438, ML103360209, ML103360212, and ML103350442.

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

Accessed at: http://www.nefsc. noaa. gov/sos/spsyn/af/sturgeon/archives/42 Atlantic ShortnoseSturgeon 2006. pdf on December 11,2007. ADAMS Accession No. ML083430573.

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

Appendix 1 to Biological Opinion This appendix presents a reproduction of Tables 2a, 2b and 4 from Entergy (2009) showing detailed information on shortnose sturgeon impinged at IP2 and IP3 for the years 1974 through 1990. The Entergy submittal is available at ADAMS Accession No. ML091950345.

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Table 2a. Individual Data File Records of 5hortnose Collected at India,n Point Unit No.2 in Each Year. 1974 1990.

Comment!

Ie C04I~..d on .. ""fHchedull!d ~pli"g ~

N1\ Hot reJ)Ol'te<i 1'\1 Not aVllIable

1. J WiJW' t_PIlr~tvre ...ttl....ted I,Dfl' .......,klyawrag.

c:::JRI./I()" ~ ; 1110 data In ttl... SItS lmpin,enten! Data Fiies Ii! Numbl!fs in plITerrtnM<!' irodiclIle nvm~r of $hQrtnos. s:urgecn tak.." on ",,"-samole 1.i,y;

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Table 2b, Individual Data File Records of Shortnose rn!'t'lIH:I'n 1990.

TUOI'I Date Commtnt$

NS Collected on II non-scheduled sampling date NR Not f~PO!1ed na Not available 1,7 Water temperature f!Stim<lted from we~1y average c=Jalank space = no data .... \he SAS Impingement Oata Files (1) NI.IIT1oorsln p<lrentheses indi(:<ltl! numbfi of ~hortnose sturgeon lilkt-n on np,,.,,amplt' day!,

- 20

t.1II<< 4. Impi",_ Data Flk L!moI S Actua' Counts IncI ....... $ CoUIIU AcljQsted lOr CoIIe<:IiotI EftIIt"'"cy for ~_ IncI Allam" 511.q_ CoIlRIAId in ......'........111: $a~, Iftdleft Point, 1m Ih,oqto 19!1(

1~2 IP!

Shortnos. sturgeon AlIII1tio; StUl'll4!OO TotallP2 !ilion.,.,... Swrseon Atlantic Stvtl""" Timl1l"3 11'1& 11'3 Grarwl TOlal level S Count lfllf:l5 Covnt l_'SC""", r.-ISCovnt 1_'Stcunt 1J!Ve15 Count l<M!15 AdjustAld for Ac/jLlStil!dfor MJust.cl lor Adju.tAId for Adjllsted for Adjusted for COllection Collection tolle<:tlan CoIkctioll ,CoIle(tjan ~,c:tio" CoIIec:tio~ Gri!><lTota' Effi<;iency StudyVu. Lev!!!IS CoIlnl El'Iicie!\cy' Lli'Vels COW'll £l!Iciency Level S (cUM Efficiency Level ~ Count EffICiency l_ISC;ount EffItj""CV L_$CI;>_ UfIC.iency LeveISCouM Adj,,"'f:d Count 1975 1 ],14 118 SOUl 119 104095 NR Nit Nil NR Nil NR U9 ~1)4,9S "7i 1 2.0 8 16.6A 9 111.1;'5 0 Q,OC 11 14m 8 14,09 17 32.74 1977 S lUI! 44 104.8 49 115.91 1 1.8 153 252.2( 154 254,0 20~ 369,98 1m 2 4.53 16 38.21 18 42.8 3 ...6 11 )l.43 l4 36.05 42 7\1.86 197' 2 4,) 32 74.7S )4 19.06 2 3.14  :!3 60.91 40 64.1 74 143.17 1980 0 OJlC 9 23.72 9 23.12 1 1.6A 10 lUll 11 1lI.U 20 41.94 1981 0 O.OC 3 8.01 3 8.0 0 0.00 5 7.46 S 7.46 II .1SAI 1981 0 O.OC 1 2.3~ 1 2.l9 0 (l.CI~ 1 1.41 1 1.4 2 3.80 1981 0 o.OC 3 6.1 3 6.11 0 o.oe 0 0.00 0 0.00 3 6.11 llII4 1 2.75 \1 6.43 4 9.18 1 US S 9.75 6 11.44 10 20J,2 1985 llIIC 0

0 G.OC G.OC 9

2 19.23 5.54 9

2 19.23 S.54 0

0 0.00 0.00 11 S

2S.DC S.~

17 5

25,QC 5.79 2'7 44,23 11.33 1987 2 4.11 ~ 6.01 4 10.12 t 1.63 1 1.~ 2 3.4. 6 13.54 1.1 3 7.02 1 2.11 .. 9.13 O.oc 1 2.02 0 O.DC 1 2.0. S 1U5 I'B!! 0 O.OC 0 0 0 1 1.8 0 0.0( 1 1.B t 1.82 1990 1 3.11 (I 0 1 .U7 0 O.OC 2 3.0 2 3.0 3 6,44 GrandT_' II 4UC 251 6!.S.a 2'!! '58.u 11 1&4 2. ~ 217 447.5 S49 1,.1~,!!

NR* Not reported

> 1Int1 Sgeclfk COllection efflci..,cy coefficients calwl,ted _Onji~l to the equatlllns Pr_nt*d lllihe 1990 .!><Il." Point An"",,1 Report _rwl .. pplied tt> th" lewl S ,~w axmt.

- 21

M. Colligan -4 you have any questions regarding this BA or the NRC staff's request, please contact Mr. Andrew Stuyvenberg, Environmental Project Manager, at 301-415-4006 or bye-mail at Andrew.Stuyvenberg@nrc.gov.

Sincerely, IRA!

David J. Wrona, Chief Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-247 and 50-286 cc wI encl: Distribution via Listserv DISTRIBUTION:

See next page ADAMS Accession Nos.: ML102990042 (Package) ML102990043 (Letter) ML102990046 (Enclosurel *concurrence via e-mail OFFICE LA:RPOB:DLR GS: RERB:DLR PM:RPB2:DLR BC:RERB:DLR NAME IKing* DLogan I AStuyvenberg Almboden DATE 11/3/10 11/8/10 11/29/10 11/29110 OFFICE OGC (NLO) BC:RPB2:DLR NAME STurk DWrona DATE 12/3/10 12/10/10 OFFICIAL RECORD COpy

Letter to Mary A. Colligan from David J. Wrona dated December 10,2010

SUBJECT:

REVISED BIOLOGICAL ASSESSMENT FOR LICENSE RENEWAL OF THE INDIAN POINT NUCLEAR GENERATING PLANT, UNIT NOS. 2 AND 3 DISTRIBUTION:

HARDCOPY:

DLRRF E-MAIL:

PUBLIC [or NON-PUBLIC, if applicable]

RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRapb Resource RidsNrrDlrRerb Resource RidsNrrDlrRpob Resource RidsOgcMaifCenter Resource DWrona EDacus,OCA BPham GMeyer, RI KGreen RConte, RI AStuyvenberg MGray, RI RAuluck NMcNamara, RI JDozier DScrenci, RI OPA MKowal PCataldo, RI TMensah GMalone, RI STurk,OGC DJackson, RI BHarris, OGC BWelling, RI AJones,OGC JAyala, RI D Roth , aGC GNewman, RI ICouret,OPA CHott, RI SBurnell, OPA