ML103350438
| ML103350438 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/31/2010 |
| From: | Stuyvenberg A Office of Nuclear Reactor Regulation |
| To: | |
| Beltz G | |
| References | |
| NUREG-1437 S38 V2 DFC | |
| Download: ML103350438 (311) | |
Text
NUREG-1437, Supplement 38, Vol. 2 Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 38 Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3 Final Report Public Comments Office of Nuclear Reactor Regulation
AVAILABILITY OF REFERENCE MATERIALS IN NRC PUBLICATIONS NRC Reference Material Non-NRC Reference Material As of November 1999, you may electronically access Documents available from public and special technical NUREG-series publications and other NRC records at libraries include all open literature items, such as NRC=s Public Electronic Reading Room at books, journal articles, and transactions, Federal http://www.nrc.gov/reading-rm.html. Register notices, Federal and State legislation, and Publicly released records include, to name a few, congressional reports. Such documents as theses, NUREG-series publications; Federal Register notices; dissertations, foreign reports and translations, and applicant, licensee, and vendor documents and non-NRC conference proceedings may be purchased correspondence; NRC correspondence and internal from their sponsoring organization.
memoranda; bulletins and information notices; inspection and investigative reports; licensee event reports; and Commission papers and their Copies of industry codes and standards used in a attachments. substantive manner in the NRC regulatory process are maintained atC NRC publications in the NUREG series, NRC The NRC Technical Library regulations, and Title 10, Energy, in the Code of Two White Flint North Federal Regulations may also be purchased from one 11545 Rockville Pike of these two sources. Rockville, MD 20852B2738
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- 2. The National Technical Information Service American National Standards Institute nd Springfield, VA 22161B0002 11 West 42 Street www.ntis.gov New York, NY 10036B8002 1B800B553B6847 or, locally, 703B605B6000 www.ansi.org 212B642B4900 A single copy of each NRC draft report for comment is available free, to the extent of supply, upon written request as follows: Legally binding regulatory requirements are stated only Address: U.S. Nuclear Regulatory Commission in laws; NRC regulations; licenses, including technical Office of Administration specifications; or orders, not in Mail, Distribution and Messenger Team NUREG-series publications. The views expressed in Washington, DC 20555-0001 contractor-prepared publications in this series are not E-mail: DISTRIBUTION@nrc.gov necessarily those of the NRC.
Facsimile: 301B415B2289 The NUREG series comprises (1) technical and Some publications in the NUREG series that are administrative reports and books prepared by the staff posted at NRC=s Web site address (NUREGBXXXX) or agency contractors http://www.nrc.gov/reading-rm/doc-collections/nuregs (NUREG/CRBXXXX), (2) proceedings of conferences are updated periodically and may differ from the last (NUREG/CPBXXXX), (3) reports resulting from printed version. Although references to material found international agreements (NUREG/IABXXXX), (4) on a Web site bear the date the material was brochures (NUREG/BRBXXXX), and (5) compilations accessed, the material available on the date cited may of legal decisions and orders of the Commission and subsequently be removed from the site. Atomic and Safety Licensing Boards and of Directors=
decisions under Section 2.206 of NRC=s regulations (NUREGB0750).
NUREG-1437, Supplement 38, Vol. 2 Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 38 Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3 Final Report Public Comments Manuscript Completed: November 2010 Date Published: December 2010 Office of Nuclear Reactor Regulation
1 ABSTRACT 2 The U.S. Nuclear Regulatory Commission (NRC) considered the environmental impacts of 3 renewing nuclear power plant operating licenses for a 20-year period in NUREG-1437, 4 Volumes 1 and 2, Generic Environmental Impact Statement for License Renewal of Nuclear 5 Plants (hereafter referred to as the GEIS),(1) and codified the results in Title 10, Part 51, 6 Environmental Protection Regulations for Domestic Licensing and Related Regulatory 7 Functions, of the Code of Federal Regulations (10 CFR Part 51). In the GEIS (and its 8 Addendum 1), the NRC staff identified 92 environmental issues and reached generic 9 conclusions related to environmental impacts for 69 of these issues that apply to all plants or to 10 plants with specific design or site characteristics. Additional plant-specific review is required for 11 the remaining 23 issues. These plant-specific reviews are to be included in a supplement to the 12 GEIS.
13 This supplemental environmental impact statement (SEIS) has been prepared in response to an 14 application submitted to the NRC by Entergy Nuclear Operations, Inc. (Entergy), Entergy 15 Nuclear Indian Point 2, LLC, and Entergy Nuclear Indian Point 3, LLC (all applicants will be 16 jointly referred to as Entergy) to renew the operating licenses for Indian Point Nuclear 17 Generating Unit Nos. 2 and 3 (IP2 and IP3) for an additional 20 years under 10 CFR Part 54, 18 Requirements for Renewal of Operating Licenses for Nuclear Power Plants. This SEIS 19 includes the NRC staffs analysis which considers and weighs the environmental impacts of the 20 proposed action, the environmental impacts of alternatives to the proposed action, and 21 mitigation measures available for reducing or avoiding adverse impacts. It also includes the 22 NRC staffs recommendation regarding the proposed action.
23 Regarding the 69 issues for which the GEIS reached generic conclusions, neither Entergy nor 24 the NRC staff has identified information that is both new and significant for any issues that apply 25 to IP2 and/or IP3. In addition, the NRC staff determined that information provided during the 26 scoping process was not new and significant with respect to the conclusions in the GEIS.
27 Therefore, the NRC staff concludes that the impacts of renewing the operating licenses for IP2 28 and IP3 will not be greater than the impacts identified for these issues in the GEIS. For each of 29 these issues, the NRC staffs conclusion in the GEIS is that the impact is of SMALL(2) 30 significance (except for the collective offsite radiological impacts from the fuel cycle and high-31 level waste and spent fuel, which were not assigned a single significance level).
32 Regarding the remaining 23 issues, those that apply to IP2 and IP3 are addressed in this SEIS.
33 The NRC staff determined that several of these issues were not applicable because of the type 34 of facility cooling system or other reasons detailed within this SEIS. For the remaining 35 applicable issues, the NRC staff concludes that the significance of potential environmental 36 impacts related to operating license renewal is SMALL, with three exceptionsentrainment, 37 impingement, and heat shock from the facilitys heated discharge. Overall effects from 38 entrainment and impingement are likely to be MODERATE. Impacts from heat shock potentially (1)
The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the GEIS include the GEIS and its Addendum 1.
(2)
Environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource.
December 2010 iii NUREG-1437, Supplement 38
Abstract 1 range from SMALL to LARGE depending on the conclusions of thermal studies proposed by the 2 New York State Department of Environmental Conservation (NYSDEC). Based on corrected 3 data received since completing the draft SEIS, NRC staff concludes that impacts to the 4 endangered shortnose sturgeon - which ranged from SMALL to LARGE in the draft SEIS - are 5 likely to be SMALL.
6 The NRC staffs recommendation is that the Commission determine that the adverse 7 environmental impacts of license renewals for IP2 and IP3 are not so great that preserving the 8 option of license renewal for energy planning decision makers would be unreasonable. This 9 recommendation is based on (1) the analysis and findings in the GEIS, (2) the environmental 10 report and other information submitted by Entergy, (3) consultation with other Federal, State, 11 Tribal, and local agencies, (4) the NRC staffs own independent review, and (5) the NRC staffs 12 consideration of public comments received during the scoping process and in response to the 13 draft SEIS.
14 Paperwork Reduction Act Statement 15 This NUREG does not contain information collection requirements and, therefore, is not subject 16 to the requirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). These 17 information collections were approved by the Office of Management and Budget (OMB),
18 approval numbers 3150-0004, 3150-0155, 3150-0014, 3150-0011, 3150-0021, 3150-0132, and 19 3150-0151.
20 Public Protection Notification 21 The NRC may not conduct or sponsor, and a person is not required to respond to, a request for 22 information or an information collection requirement unless the requesting document displays a 23 currently valid OMB control number.
NUREG-1437, Supplement 38 iv December 2010
Table of Contents ABSTRACT ...................................................................................................................................iii EXECUTIVE
SUMMARY
............................................................................................................ xv ABBREVIATIONS/ACRONYMS .................................................................................................xxi 1.0 Introduction .................................................................................................................... 1-1 1.1 Report Contents ................................................................................................. 1-2 1.2 Background ........................................................................................................ 1-3 1.2.1 Generic Environmental Impact Statement .............................................. 1-3 1.2.2 License Renewal Evaluation Process..................................................... 1-4 1.3 The Proposed Federal Action ............................................................................. 1-6 1.4 The Purpose and Need for the Proposed Action ................................................ 1-7 1.5 Compliance and Consultations ........................................................................... 1-7 1.6 References ......................................................................................................... 1-8 2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment ...................................................................................................................2-1 2.1 Plant and Site Description and Proposed Plant Operation During the Renewal Term .................................................................................................... 2-1 2.1.1 External Appearance and Setting ........................................................... 2-2 2.1.2 Reactor Systems .................................................................................... 2-5 2.1.3 Cooling and Auxiliary Water Systems..................................................... 2-8 2.1.4 Radioactive Waste Management Systems and Effluent Control Systems ................................................................................................ 2-14 2.1.4.1 Liquid Waste Processing Systems and Effluent Controls .......2-15 2.1.4.2 Gaseous Waste Processing Systems and Effluent Controls ..2-17 2.1.4.3 Solid Waste Processing..........................................................2-20 2.1.5 Nonradioactive Waste Systems ............................................................ 2-21 2.1.5.1 Nonradioactive Waste Streams ..............................................2-22 2.1.5.2 Pollution Prevention and Waste Minimization ........................2-23 2.1.6 Facility Operation and Maintenance ..................................................... 2-23 2.1.7 Power Transmission System ................................................................ 2-23 2.2 Plant Interaction with the Environment ............................................................. 2-24 2.2.1 Land Use .............................................................................................. 2-24 2.2.2 Water Use ............................................................................................. 2-24 2.2.3 Water Quality ........................................................................................ 2-24 2.2.4 Meteorology and Air Quality ................................................................. 2-27 2.2.4.1 Climate ...................................................................................2-27 2.2.4.2 Meteorological System ...........................................................2-28 2.2.4.3 Air Quality ...............................................................................2-29 2.2.5 Aquatic Resources................................................................................ 2-31 2.2.5.1 The Hudson River Estuary .....................................................2-31 December 2010 v NUREG-1437, Supplement 38
Table of Contents 2.2.5.2 Significant Environmental Issues Associated with the Hudson River Estuary .............................................................2-39 2.2.5.3 Regulatory Framework and Monitoring Programs ..................2-48 2.2.5.4 Potentially Affected Fish and Shellfish Resources .................2-52 2.2.5.5 Special Status Species and Habitats......................................2-77 2.2.5.6 Other Potentially Affected Aquatic Resources ........................2-80 2.2.5.7 Nuisance Species ...................................................................2-82 2.2.6 Terrestrial Resources ........................................................................... 2-84 2.2.6.1 Description of Site Terrestrial Environment ............................2-85 2.2.6.2 Threatened and Endangered Terrestrial Species ...................2-86 2.2.7 Radiological Impacts........................................................................... 2-104 2.2.8 Socioeconomic Factors ...................................................................... 2-114 2.2.8.1 Housing ................................................................................2-115 2.2.8.2 Public Services .....................................................................2-116 2.2.8.3 Offsite Land Use ...................................................................2-121 2.2.8.4 Visual Aesthetics and Noise .................................................2-123 2.2.8.5 Demography .........................................................................2-124 2.2.8.6 Economy...............................................................................2-131 2.2.9 Historic and Archeological Resources ................................................ 2-134 2.2.9.1 Cultural Background .............................................................2-134 2.2.9.2 Historic and Archeological Resources at the IP2 & IP3 Site .......................................................................................2-138 2.2.10 Related Federal Project Activities and Consultations ......................... 2-139 2.3 References ..................................................................................................... 2-142 3.0 Environmental Impacts of Refurbishment ...................................................................... 3-1 3.1 Potential Refurbishment Activities ...................................................................... 3-1 3.2 Refurbishment Impacts ...................................................................................... 3-4 3.2.1 Terrestrial EcologyRefurbishment Impacts ......................................... 3-7 3.2.2 Threatened or Endangered SpeciesRefurbishment Impacts .............. 3-8 3.2.3 Air Quality During Refurbishment (Nonattainment and Maintenance Areas) ..................................................................................................... 3-9 3.2.4 Housing ImpactsRefurbishment ........................................................ 3-10 3.2.5 Public Services: Public UtilitiesRefurbishment ................................. 3-10 3.2.6 Public Services: EducationRefurbishment ....................................... 3-11 3.2.7 Offsite Land UseRefurbishment ........................................................ 3-11 3.2.8 Public Services: TransportationRefurbishment ................................ 3-11 3.2.9 Historic and Archeological ResourcesRefurbishment ....................... 3-12 3.2.10 Environmental JusticeRefurbishment................................................ 3-13 3.3 Evaluation of New and Potentially Significant Information on Impacts of Refurbishment .................................................................................................. 3-13 3.4 Summary of Refurbishment Impacts ................................................................ 3-13 3.5 References ....................................................................................................... 3-13 4.0 Environmental Impacts of Operation .............................................................................. 4-1 4.1 Cooling System .................................................................................................. 4-2 4.1.1 Impingement of Fish and Shellfish........................................................ 4-10 NUREG-1437, Supplement 38 vi December 2010
Table of Contents 4.1.2 Entrainment of Fish and Shellfish in Early Lifestages........................... 4-14 4.1.3 Combined Effects of Impingement and Entrainment ............................ 4-15 4.1.3.1 Assessment of Population TrendsThe First Line of Evidence .................................................................................4-19 4.1.3.2 Assessment of Strength of ConnectionThe Second Line of Evidence .............................................................................4-20 4.1.3.3 Impingement and Entrainment Impact Summary ...................4-20 4.1.3.4 Discussion of Uncertainty .......................................................4-24 4.1.3.5 Overall Impingement and Entrainment Impact .......................4-25 4.1.4 Heat Shock ........................................................................................... 4-26 4.1.4.1 Potential Effects of Heated Water Discharges on Aquatic Biota .......................................................................................4-27 4.1.4.2 Historical Context ...................................................................4-27 4.1.4.3 Thermal Studies and Conclusions ..........................................4-28 4.1.4.4 Assessments of Thermal Impacts ..........................................4-30 4.1.4.5 NRC Staff Assessment of Thermal Impacts ...........................4-32 4.1.5 Potential Mitigation Options .................................................................. 4-32 4.2 Transmission Lines .......................................................................................... 4-36 4.2.1 Electromagnetic FieldsAcute Effects................................................. 4-38 4.2.2 Electromagnetic FieldsChronic Effects ............................................. 4-40 4.3 Radiological Impacts of Normal Operations ..................................................... 4-40 4.4 Socioeconomic Impacts of Plant Operations during the License Renewal Term ................................................................................................................. 4-42 4.4.1 Housing Impacts ................................................................................... 4-43 4.4.2 Public ServicesPublic Utility Impacts ................................................ 4-44 4.4.3 Offsite Land UseLicense Renewal Period......................................... 4-45 4.4.3.1 Population-Related Impacts ...................................................4-46 4.4.3.2 Tax-Revenue-Related Impacts ...............................................4-46 4.4.4 Public Services: Transportation Impacts during Operations ................ 4-47 4.4.5 Historic and Archeological Resources .................................................. 4-47 4.4.5.1 Site-Specific Cultural Resources Information .........................4-48 4.4.5.2 Conclusions ............................................................................4-48 4.4.6 Environmental Justice........................................................................... 4-49 4.5 Ground Water Use and Quality ........................................................................ 4-56 4.6 Threatened or Endangered Species ................................................................ 4-56 4.6.1 Aquatic Special Status Species ............................................................ 4-57 4.6.2 Terrestrial Threatened or Endangered Species.................................... 4-60 4.7 Evaluation of New and Potentially Significant Information on Impacts of Operations during the Renewal Term .............................................................. 4-61 4.8 Cumulative Impacts .......................................................................................... 4-61 4.8.1 Cumulative Impacts on Aquatic Resources .......................................... 4-62 4.8.2 Cumulative Impacts on Terrestrial Resources ...................................... 4-66 4.8.3 Cumulative Radiological Impacts.......................................................... 4-67 4.8.4 Cumulative Socioeconomic Impacts ..................................................... 4-68 4.8.5 Cumulative Impacts on Ground Water Use and Quality ....................... 4-69 4.8.6 Conclusions Regarding Cumulative Impacts ........................................ 4-69 4.9 Summary of Impacts of Operations during the Renewal Term......................... 4-69 December 2010 vii NUREG-1437, Supplement 38
Table of Contents 4.10 References ....................................................................................................... 4-70 5.0 Environmental Impacts of Postulated Accidents ............................................................ 5-1 5.1 Postulated Plant Accidents ................................................................................. 5-1 5.1.1 Design-Basis Accidents .......................................................................... 5-1 5.1.2 Severe Accidents .................................................................................... 5-3 5.2 Severe Accident Mitigation Alternatives ............................................................. 5-4 5.2.1 Introduction ............................................................................................. 5-4 5.2.2 Estimate of Risk ...................................................................................... 5-5 5.2.3 Potential Plant Improvements ................................................................. 5-7 5.2.4 Evaluation of Risk Reduction and Costs of Improvements ..................... 5-8 5.2.5 Cost-Benefit Comparison........................................................................ 5-8 5.2.6 Conclusions .......................................................................................... 5-11 5.3 References ....................................................................................................... 5-12 6.0 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions .......................................................................................... 6-1 6.1 The Uranium Fuel Cycle ..................................................................................... 6-1 6.2 Greenhouse Gas Emissions ............................................................................... 6-8 6.2.1 Introduction ............................................................................................. 6-8 6.2.2 IP2 and IP3 ............................................................................................. 6-9 6.2.3 GEIS ....................................................................................................... 6-9 6.2.4 Other Studies .......................................................................................... 6-9 6.2.4.1 Qualitative Studies....................................................................6-9 6.2.4.2 Quantitative Studies ...............................................................6-10 6.2.5 Summary of Nuclear Greenhouse Gas Emissions Compared to Coal ...................................................................................................... 6-12 6.2.6 Summary of Nuclear Greenhouse Gas Emissions Compared to Natural Gas........................................................................................... 6-13 6.2.7 Summary of Nuclear Greenhouse Gas Emissions Compared to Renewable Energy Sources ................................................................. 6-14 6.2.8 Conclusions .......................................................................................... 6-15 6.3 References ....................................................................................................... 6-17 7.0 Environmental Impacts of Decommissioning ................................................................. 7-1 7.1 Decommissioning ............................................................................................... 7-1 7.2 References ......................................................................................................... 7-4 8.0 Environmental Impacts of Alternatives to License Renewal .......................................... 8-1 8.1 Alternatives to the Existing IP2 and IP3 Cooling-Water System ........................ 8-2 8.1.1 Closed-Cycle Cooling Alternative ........................................................... 8-5 8.1.1.1 Description of the Closed-Cycle Cooling Alternative ................8-6 8.1.1.2 Environmental Impacts of the Closed-Cycle Cooling Alternative.................................................................................8-6 8.2 No-Action Alternative ........................................................................................ 8-20 8.3 Alternative Energy Sources .............................................................................. 8-26 8.3.1 Natural Gas-Fired Combined-Cycle (NGCC) Generation ..................... 8-28 NUREG-1437, Supplement 38 viii December 2010
Table of Contents 8.3.2 Purchased Electric Power..................................................................... 8-39 8.3.3 Conservation......................................................................................... 8-41 8.3.4 Alternatives Dismissed From Individual Consideration......................... 8-43 8.3.4.1 Wind Power ............................................................................8-43 8.3.4.2 Wood and Wood Waste..........................................................8-44 8.3.4.3 Hydropower ............................................................................8-45 8.3.4.4 Oil-Fired Generation ...............................................................8-45 8.3.4.5 Solar Power ............................................................................8-45 8.3.4.6 New Nuclear Generation ........................................................8-46 8.3.4.7 Geothermal Energy ................................................................8-46 8.3.4.8 Municipal Solid Waste ............................................................8-47 8.3.4.9 Other Biomass Derived Fuels .................................................8-47 8.3.4.10 Fuel Cells................................................................................8-48 8.3.4.11 Delayed Retirement ................................................................8-48 8.3.4.12 Combined Heat and Power ....................................................8-48 8.3.4.13 Supercritical Coal-Fired Generation .......................................8-49 8.3.5 Combination of Alternatives .................................................................. 8-59 8.3.5.1 Impacts of Combination Alternative 1 .....................................8-61 8.3.5.2 Impacts of Combined Alternative 2.........................................8-67 8.4 Summary of Alternatives Considered ............................................................... 8-72 8.5 References ....................................................................................................... 8-73 9.0 Summary and Conclusions ............................................................................................ 9-1 9.1 Environmental Impacts of the Proposed ActionLicense Renewal................... 9-4 9.1.1 Unavoidable Adverse Impacts ................................................................ 9-6 9.1.2 Irreversible or Irretrievable Resource Commitments .............................. 9-6 9.1.3 Short-Term Use Versus Long-Term Productivity .................................... 9-7 9.2 Relative Significance of the Environmental Impacts of License Renewal and Alternatives ......................................................................................................... 9-7 9.3 Conclusions and Recommendations .................................................................. 9-8 9.4 References ....................................................................................................... 9-11 Appendices Appendix A: Comments Received on the Environmental Review ............................................ A-1 Appendix B: Contributers to the Supplement ............................................................................ B-1 Appendix C: Chronology of NRC Staff Environmental Review Correspondence Related to the Entergy Nuclear Operations, Inc. Application for License Renewal of Indian Point Nuclear Generating Unit Nos. 2 and 3 .......................................................................... C-1 Appendix D: Organizations Contacted ...................................................................................... D-1 Appendix E: Indian Point Nuclear Generating Unit Numbers 2 and 3 Compliance Status and Consultation Correspondence....................................................................................... E-1 Appendix F: GEIS Environmental Issues Not Applicable to Indian Point Nuclear Generating Station Unit Nos. 2 and 3 ...............................................................................................F-1 December 2010 ix NUREG-1437, Supplement 38
Table of Contents Appendix G: U.S. Nuclear Regulatory Commission Staff Evaluation of Severe Accident Mitigation Alternatives for Indian Point Nuclear Generating Unit Nos. 2 and 3 in Support of License Renewal Application Review ....................................................................... G-1 Appendix H: U.S. Nuclear Regulatory Commission Staff Evaluation of Environmental Impacts of Cooling System ............................................................................................................. H-1 Appendix I: Statistical Analyses Conducted for Chapter 4 Aquatic Resources and Appendix H
........................................................................................................................................ I-1 NUREG-1437, Supplement 38 x December 2010
Figures Figure 2-1. Location of IP2 and IP3, 50-mi (80-km) radius ........................................................2-3 Figure 2-2. Location of IP2 and IP3, 6-mi (10-km) radius ..........................................................2-4 Figure 2-3. IP2 and IP3 property boundaries and environs .......................................................2-6 Figure 2-4. IP2 and IP3 site layout .............................................................................................2-7 Figure 2-5. IP2 intake structure ................................................................................................2-10 Figure 2-6. IP3 intake structure ................................................................................................2-11 Figure 2-7. IP2 intake system ..................................................................................................2-12 Figure 2-8. IP3 intake system ..................................................................................................2-12 Figure 2-9. Topographic features surrounding IP2 and IP3 .....................................................2-26 Figure 2-10. Hudson study area and river segments ...............................................................2-32 Figure 2-11. Hudson River area and national estuarine research sites ...................................2-33 Figure 4-1. Percentage of impingement composed of RIS fish and RIS fish plus blue crab relative to the estimated total impingement at IP2 .......................................................4-12 Figure 4-2. Percentage of impingement composed of RIS fish and RIS fish plus blue crab relative to the estimated total impingement at IP3 .......................................................4-12 Figure 4-3. Percentage of entrainment composed of RIS fish and total identified fish relative to the estimated total entrainment at IP2 and IP3 combined............................................4-15 Figure 4-4. General weight-of-evidence approach employed to assess the level of impact to population trends attributable to IP cooling system operation ......................................4-16 Figure 4-5. Minority block groups in 2000 within a 50-mi radius of IP2 and IP3 ......................4-52 Figure 4-6. Low-income block groups in 2000 within a 50-mi radius of IP2 and IP3 ...............4-55 December 2010 xi NUREG-1437, Supplement 38
Tables Table 2-1. Historical Impacts on the Hudson River Watershed ............................................... 2-42 Table 2-2. Facilities Discharging at Least 50 mgd (190,000 m3/day) into the Lower Hudson River ............................................................................................................................. 2-44 Table 2-3. Hudson River Environmental Studies Table ........................................................... 2-52 Table 2-4. Representative Important Aquatic Species............................................................. 2-53 Table 2-5. Locations in the Hudson River Estuary (see Figure 2-10) Where the Presence of RIS Life Stages Represented at Least 10 Percent of the Total Number Collected in Referenced Surveys or Studies ................................................................ 2-55 Table 2-6. Federally and State-Listed Terrestrial Species Potentially Occurring in Westchester County ..................................................................................................... 2-90 Table 2-7. IP2 and IP3 Employee Residence by County in 2006 .......................................... 2-115 Table 2-8. Housing in Dutchess, Orange, Putnam and Westchester Counties, New York .... 2-116 Table 2-9. Major Public Water Supply Systems in 2005 (mgd) ............................................. 2-119 Table 2-10. Average Annual Daily Traffic Counts on US 9 Near IP2 and IP3, 2004 ............. 2-121 Table 2-11. Population and Percent Growth in Dutchess, Orange, Putnam, and Westchester Counties, New York, from 1970 to 2000 and Projected for 2010 and 2050 .................................................................................................................... 2-125 Table 2-12. Demographic Profile of the Population in the IP2 and IP3 Four-County ROI in 2000 ....................................................................................................................... 2-126 Table 2-13. Demographic Profile of the Population in the IP2 and IP3 Four-County ROI in 2006 (Estimate) ...................................................................................................... 2-127 Table 2-14. Seasonal Housing within 50 mi (80 km) of the IP2 and IP3 ................................ 2-128 Table 2-15. Migrant Farm Worker and Temporary Farm Labor within 50 mi (80 km) of IP2 and IP3 ................................................................................................................ 2-130 Table 2-16. Major Employers in Westchester County in 2006 ............................................... 2-132 Table 2-17. Income Information for the IP2 and IP3 ROI....................................................... 2-132 Table 2-18. IP2 and IP3 PILOT and Property Tax Paid and Percentage of the Total Revenue of the Town of Cortlandt, Hendrick Hudson Central School District, and Village of Buchanan, 2003 to 2006 ..................................................................... 2-134 Table 2-19. Cultural Sequence and Chronology .................................................................... 2-135 Table 3-1. Category 1 Issues for Refurbishment Evaluation ..................................................... 3-4 Table 3-2. Category 2 Issues for Refurbishment Evaluation ..................................................... 3-7 Table 4-1. Generic (Category 1) Issues Applicable to the Operation of the IP2 and IP3 Cooling System during the Renewal Term..................................................................... 4-2 December 2010 xii NUREG-1437, Supplement 38
Tables Table 4-2. Site-Specific (Category 2) Issues Applicable to the Operation of the IP2 and IP3 Cooling System during the Renewal Term..................................................................... 4-6 Table 4-3. Cumulative Mortality and Injury of Selected Fish Species after Impingement on Ristroph Screens.......................................................................................................... 4-13 Table 4-4. Impingement and Entrainment Impact Summary for Hudson River RIS ................ 4-23 Table 4-5. Category 1 Issues Applicable to the IP2 and IP3 Transmission Lines during the Renewal Term .............................................................................................................. 4-37 Table 4-6. Category 2 and Uncategorized Issues Applicable to the IP2 and IP3 Transmission Lines during the Renewal Term ............................................................. 4-38 Table 4-7. Category 1 Issues Applicable to Radiological Impacts of Normal Operations during the Renewal Term ............................................................................................. 4-41 Table 4-8. Category 1 Issues Applicable to Socioeconomics during the Renewal Term ......... 4-42 Table 4-9. Category 2 Issues Applicable to Socioeconomics and Environmental Justice during the Renewal Term ............................................................................................. 4-43 Table 4-10. Category 2 Issues Applicable to Threatened or Endangered Species during the Renewal Term .............................................................................................................. 4-57 Table 4-11. Impingement Data for Shortnose and Atlantic Sturgeon at IP2 and IP3, 1975-1990 ................................................................................................................... 4-59 Table 5-1. Category 1 Issues Applicable to Postulated Accidents during the Renewal Term ... 5-2 Table 5-2. Category 2 Issues Applicable to Postulated Accidents during the Renewal Term .. 5-3 Table 5-3. IP2 and IP3 Core Damage Frequency...................................................................... 5-6 Table 5-4. Breakdown of Population Dose by Containment Failure Mode ................................ 5-7 Table 6-1. Category 1 Issues Applicable to the Uranium Fuel Cycle and Solid Waste Management during the Renewal Term ......................................................................... 6-2 Table 6-2. Nuclear GHG Emissions Compared to Coal........................................................... 6-12 Table 6-3. Nuclear GHG Emissions Compared to Natural Gas ............................................... 6-13 Table 6-4. Nuclear GHG Emissions Compared to Renewable Energy Sources ..................... 6-14 Table 7-1. Category 1 Issues Applicable to the Decommissioning of IP2 and IP3 Following the Renewal Term .......................................................................................................... 7-2 Table 8-1. Summary of Environmental Impacts of a Closed-Cycle Cooling Alternative at IP2 and IP3 ................................................................................................................................ 8-19 Table 8-2. Summary of Environmental Impacts of the No-Action Alternative .......................... 8-21 Table 8-3. Summary of Environmental Impacts of the NGCC Alternative Located at IP2 and IP3 and an Alternate Site ................................................................................................... 8-37 Table 8-4. Summary of Environmental Impacts of Combination Alternatives .......................... 8-71 December 2010 xiii NUREG-1437, Supplement 38
Tables Table 9-1. Summary of Environmental Significance of License Renewal, the No-Action Alternative, and Alternative Methods of Generation ....................................................... 9-9 NUREG-1437, Supplement 38 xiv December 2010
1 EXECUTIVE
SUMMARY
2 By letter dated April 30, 2007, Entergy Nuclear Operations, Inc. (Entergy) submitted an 3 application to the U.S. Nuclear Regulatory Commission (NRC) to renew the operating licenses 4 for Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3) for an additional 20-year 5 period. If the operating licenses are renewed, State regulatory agencies and Entergy will 6 ultimately decide whether the plant will continue to operate based on factors such as the need 7 for power, issues falling under the purview of the owners, or other matters within the States 8 jurisdiction, including acceptability of water withdrawal. Two state-level issues (consistency with 9 State water quality standards, and consistency with State coastal zone management plans) 10 need to be resolved. On April 2, 2010, the New York State Department of Environmental 11 Conservation (NYSDEC) issued a Notice of Denial regarding the Clean Water Act Section 401 12 Water Quality Certification. Entergy has since requested a hearing on the issue, and the matter 13 will be decided through NYSDECs hearing process. If the operating licenses are not renewed, 14 then IP2 and IP3 must be shut down at or before the expiration date of their current operating 15 licenses which expire September 28, 2013, and December 12, 2015, respectively.
16 The NRC has implemented Section 102 of the National Environmental Policy Act of 1969, as 17 amended (42 U.S.C. 4321), in Title 10, Part 51, Environmental Protection Regulations for 18 Domestic Licensing and Related Regulatory Functions, of the Code of Federal Regulations 19 (10 CFR Part 51). In 10 CFR 51.20(b)(2), the Commission requires preparation of an 20 environmental impact statement (EIS) or a supplement to an EIS for renewal of a reactor 21 operating license. In addition, 10 CFR 51.95(c) states that the EIS prepared at the operating 22 license renewal stage will be a supplement to NUREG-1437, Volumes 1 and 2, Generic 23 Environmental Impact Statement for License Renewal of Nuclear Plants (hereafter referred to 24 as the GEIS).(1) 25 Upon acceptance of the IP2 and IP3 application, the NRC began the environmental review 26 process described in 10 CFR Part 51 by publishing a notice of intent to prepare an EIS and 27 conduct scoping. The NRC staff visited the IP2 and IP3 site in September 2007, held two public 28 scoping meetings on September 19, 2007, and conducted two site audits on September 10-14, 29 2007, and September 24-27, 2007. In the preparation of this supplemental environmental 30 impact statement (SEIS) for IP2 and IP3, the NRC staff reviewed the IP2 and IP3 environmental 31 report (ER) and compared it to the GEIS; consulted with other agencies; conducted an 32 independent review of the issues following the guidance in NUREG-1555, Standard Review 33 Plans for Environmental Reviews for Nuclear Power Plants, Supplement 1: Operating License 34 Renewal, issued October 1999; and considered the public comments received during the 35 scoping process and in response to the draft SEIS. The public comments received during the 36 scoping process that were considered to be within the scope of the environmental review are 37 contained in the Scoping Summary Report for Indian Point Nuclear Generating Unit Nos. 2 and 38 3, issued by NRC staff in December 2008. In Appendix A of this SEIS, the NRC staff adopts, by 39 reference, the comments and responses in the Scoping Summary Report and provides 40 information on how to electronically access the scoping summary or view a hard copy.
(1)
The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the GEIS include the GEIS and its Addendum 1.
December 2010 xv NUREG-1437, Supplement 38
Executive Summary 1 The NRC staff held public meetings in Cortlandt Manor, New York, on February 12, 2009 and 2 described the preliminary results of the NRC environmental review, answered questions, and 3 provided members of the public with information to assist them in formulating comments on the 4 draft SEIS. The NRC staff considered and addressed all of the comments received. These 5 comments are reflected in the SEIS or addressed in Appendix A, Part 2, to this SEIS.
6 This SEIS includes the NRC staffs analysis that considers and weighs the environmental 7 effects of the proposed action, the environmental impacts of alternatives to the proposed action, 8 and mitigation measures for reducing or avoiding adverse effects. It also includes the NRC 9 staffs recommendation regarding the proposed action.
10 The Commission has adopted the following statement of purpose and need for license renewal 11 from the GEIS:
12 The purpose and need for the proposed action (renewal of an operating license) 13 is to provide an option that allows for power generation capability beyond the 14 term of a current nuclear power plant operating license to meet future system 15 generating needs, as such needs may be determined by State, utility, and, where 16 authorized, Federal (other than NRC) decision makers.
17 The purpose of the NRC staffs environmental review, as defined in 10 CFR 51.95(c)(4) and the 18 GEIS, is to determine the following:
19 whether or not the adverse environmental impacts of license renewal are so 20 great that preserving the option of license renewal for energy planning decision 21 makers would be unreasonable.
22 Both the statement of purpose and need and the evaluation criterion implicitly acknowledge that 23 there are factors, in addition to license renewal, that will ultimately determine whether an 24 existing nuclear power plant continues to operate beyond the period of the current operating 25 license (or licenses).
26 NRC regulations (10 CFR 51.95(c)(2)) contain the following statement regarding the content of 27 SEISs prepared at the license renewal stage:
28 The supplemental environmental impact statement for license renewal is not 29 required to include discussion of need for power or the economic costs and 30 economic benefits of the proposed action or of alternatives to the proposed 31 action except insofar as such benefits and costs are either essential for a 32 determination regarding the inclusion of an alternative in the range of alternatives 33 considered or relevant to mitigation. In addition, the supplemental environmental 34 impact statement prepared at the license renewal stage need not discuss other 35 issues not related to the environmental effects of the proposed action and the 36 alternatives, or any aspect of the storage of spent fuel for the facility within the 37 scope of the generic determination in 10 CFR 51.23(a) [Temporary storage of 38 spent fuel after cessation of reactor operation-generic determination of no 39 significant environmental impact] and in accordance with 10 CFR 51.23(b).
40 The GEIS contains the results of a systematic evaluation of the consequences of renewing an 41 operating license and operating a nuclear power plant for an additional 20 years. It evaluates 42 92 environmental issues using the NRCs three-level standard of significanceSMALL, 43 MODERATE, or LARGEdeveloped using the Council on Environmental Quality (CEQ)
NUREG-1437, Supplement 38 xvi December 2010
Executive Summary 1 guidelines.
2 The following definitions of the three significance levels are set forth in footnotes to Table B-1 of 3 Appendix B, Environmental Effect of Renewing the Operating License of a Nuclear Power 4 Plant, to 10 CFR Part 51, Subpart A, National Environmental Policy ActRegulations 5 Implementing Section 102(2):
6 SMALLEnvironmental effects are not detectable or are so minor that they will 7 neither destabilize nor noticeably alter any important attribute of the resource.
8 MODERATEEnvironmental effects are sufficient to alter noticeably, but not to 9 destabilize, important attributes of the resource.
10 LARGEEnvironmental effects are clearly noticeable and are sufficient to 11 destabilize important attributes of the resource.
12 For 69 of the 92 issues considered in the GEIS, the analysis in the GEIS reached the following 13 conclusions:
14 (1) The environmental impacts associated with the issue have been determined to apply 15 either to all plants or, for some issues, to plants having a specific type of cooling system 16 or other specified plant or site characteristics.
17 (2) A single significance level (that is, SMALL, MODERATE, or LARGE) has been assigned 18 to the impacts (except for collective offsite radiological impacts from the fuel cycle and 19 from high-level waste and spent fuel disposal).
20 (3) Mitigation of adverse impacts associated with the issue has been considered in the 21 analysis, and it has been determined that additional plant-specific mitigation measures 22 are not likely to be sufficiently beneficial to warrant implementation.
23 These 69 issues were identified in the GEIS as Category 1 issues. In the absence of new and 24 significant information, the staff relied on conclusions in the GEIS for issues designated as 25 Category 1 in Table B-1 of Appendix B to 10 CFR Part 51, Subpart A.
26 Of the 23 issues that do not meet the criteria set forth above, 21 are classified as Category 2 27 issues requiring analysis in a plant-specific supplement to the GEIS. The remaining two issues, 28 environmental justice and chronic effects of electromagnetic fields, were not categorized.
29 Environmental justice was not evaluated on a generic basis and must be addressed in a plant-30 specific supplement to the GEIS. Information on the chronic effects of electromagnetic fields 31 was not conclusive at the time the GEIS was prepared.
32 This SEIS documents the NRC staffs consideration of all 92 environmental issues identified in 33 the GEIS. The NRC staff considered the environmental impacts associated with alternatives to 34 license renewal and compared the environmental impacts of license renewal and the 35 alternatives. The alternatives to license renewal that were considered include the no-action 36 alternative (not renewing the operating licenses for IP2 and IP3), alternative methods of power 37 generation, and conservation. The NRC staff also considered an alternative that included 38 continued operation of IP2 and IP3 with a closed-cycle cooling system. This alternative is 39 considered for several reasons. First, the New York State Department of Environmental 40 Conservation (NYSDEC) issued a preliminary determination in its 2003 draft and 2004 revised 41 draft State Pollutant Discharge Elimination System (SPDES) permits that closed cycle cooling is 42 the site-specific best technology available (BTA) to reduce impacts on fish and shellfish; December 2010 xvii NUREG-1437, Supplement 38
Executive Summary 1 currently the revised draft SPDES permit is the subject of NYSDEC proceedings, and the 2 existing SPDES permit continues in effect at this time. Second, NYSDEC affirmed this view in 3 its April 2, 2010, Notice of Denial of Entergys Clean Water Act Section 401 Water Quality 4 Certification, indicating that closed cycle cooling would minimize aquatic impacts; that 5 determination is currently subject to further State-level adjudication. Third, NYSDEC has 6 published a draft policy on BTA indicating that Wet closed-cycle cooling or its equivalent is the 7 minimum performance goal for existing industrial facilities that operate a CWIS [cooling water 8 intake system] in connection with a point source thermal discharge. Public comments on that 9 draft policy were submitted through July 9, 2010.
10 Entergy and the NRC staff have established independent processes for identifying and 11 evaluating the significance of any new information on the environmental impacts of license 12 renewal. Neither Entergy nor the staff has identified information that is both new and significant 13 related to Category 1 issues that would call into question the conclusions in the GEIS. Similarly, 14 neither the scoping process nor the NRC staff has identified any new issue applicable to IP2 15 and IP3 that has a significant environmental impact. Therefore, the NRC staff relies on the 16 conclusions of the GEIS for all of the Category 1 issues that are applicable to IP2 and IP3.
17 Entergys license renewal application presents an analysis of the 21 Category 2 issues that are 18 applicable to IP2 and IP3, plus environmental justice and chronic effects from electromagnetic 19 fields, for a total of 23 issues. The NRC staff has reviewed the Entergy analysis and has 20 conducted an independent assessment of each issue. Six of the Category 2 issues are not 21 applicable because they are related to a type of existing cooling system, water use conflicts, 22 and ground water use not found at IP2 and IP3. Entergy has stated that its evaluation of 23 structures and components, as required by 10 CFR 54.21, Contents of ApplicationTechnical 24 Information, did not identify any major plant refurbishment activities or modifications as 25 necessary to support the continued operation of IP2 and IP3 for the license renewal period.
26 Entergy did, however, indicate that it plans to replace reactor vessel heads and control rod drive 27 mechanisms at IP2 and IP3. The NRC staff has evaluated the potential impacts of these 28 activities using the framework provided by the GEIS for addressing refurbishment issues.
29 Seventeen environmental issues related to operational impacts and postulated accidents during 30 the renewal term are discussed in detail in this SEIS. These include 15 Category 2 issues and 31 2 uncategorized issues, environmental justice and chronic effects of electromagnetic fields. The 32 NRC staff also discusses in detail the potential impacts related to the 10 Category 2 issues that 33 apply to refurbishment activities. The NRC staff concludes that the potential environmental 34 effects for most of these issues are of SMALL significance in the context of the standards set 35 forth in the GEIS with three exceptionsentrainment, impingement, and heat shock from the 36 facilitys heated discharge. The NRC staff jointly assessed the impacts of entrainment and 37 impingement to be MODERATE based on NRCs analysis of representative important species.
38 Impacts from heat shock potentially range from SMALL to LARGE depending on the 39 conclusions of thermal studies proposed by the NYSDEC. Based on corrected data received 40 since completing the draft SEIS, the NRC staff concludes that impacts to the endangered 41 shortnose sturgeon - which ranged from SMALL to LARGE in the draft SEIS - are likely to be 42 SMALL.
43 The NRC staff also determined that appropriate Federal health agencies have not reached a 44 consensus on the existence of chronic adverse effects from electromagnetic fields. Therefore, 45 no further evaluation of this issue is required.
NUREG-1437, Supplement 38 xviii December 2010
Executive Summary 1 For severe accident mitigation alternatives (SAMAs), the staff concludes that a reasonable, 2 comprehensive effort was made to identify and evaluate SAMAs. Based on its review of the 3 SAMAs for IP2 and IP3 and the plant improvements already made, the NRC staff concludes that 4 several SAMAs may be cost-beneficial. However, these SAMAs do not relate to adequate 5 management of the effects of aging during the period of extended operation. Therefore, they do 6 not need to be implemented as part of license renewal pursuant to 10 CFR Part 54, 7 Requirements for Renewal of Operating Licenses for Nuclear Power Plants.
8 Cumulative impacts of past, present, and reasonably foreseeable future actions were 9 considered, regardless of what agency (Federal or non-Federal) or person undertakes such 10 other actions. For purposes of this analysis, the NRC staff determined that the cumulative 11 impacts to terrestrial and aquatic resources in the IP2 and IP3 environs would be LARGE, due 12 primarily to past development and pollution, much of which preceded IP2 and IP3 or occurred 13 as a result of other actions (for example, suburban development and hardening of the Hudson 14 River shoreline).
15 The NRC staffs analysis indicates that the adverse impacts of potential alternatives will differ 16 from those of the proposed action. Most alternatives result in smaller impacts to aquatic life, 17 while creating greater impacts in other resource areas. Often, the most significant 18 environmental impacts of alternatives result from constructing new facilities or infrastructure.
19 The recommendation of the NRC staff is that the Commission determine that the adverse 20 environmental impacts of license renewals for IP2 and IP3 are not so great that not preserving 21 the option of license renewal for energy planning decision makers would be unreasonable. This 22 recommendation is based on (1) the analysis and findings in the GEIS, (2) the ER and other 23 information submitted by Entergy, (3) consultation with other Federal, State, Tribal, and local 24 agencies, (4) the staffs own independent review, and (5) the staffs consideration of public 25 comments received during the scoping process and in response to the draft SEIS.
December 2010 xix NUREG-1437, Supplement 38
1 December 2010 xx NUREG-1437, Supplement 38
Abbreviations/Acronyms 1 Abbreviations/Acronyms 2 E degree(s) 3 m micron(s) 4 3D three dimensional 5 ACAA American Coal Ash Association 6 ac acre(s) 7 AC alternating current 8 ACC averted cleanup and decontamination 9 ADAMS Agencywide Documents Access and Management System 10 ADAPT Atmospheric Data Assimilation and Parameterization Technique 11 ACEEE American Council for an Energy Efficient Economy 12 AEC Atomic Energy Commission 13 AFW auxiliary feed water 14 AGTC Algonquin Gas Transmission Company 15 ALARA as low as reasonably achievable 16 ANOVA analysis of variance 17 AOC averted off-site property damage costs 18 AOE averted occupational exposure costs 19 AOSC averted on-site costs 20 APE averted public exposure 21 ASA Applied Science Associates 22 ASME American Society of Mechanical Engineers 23 ASMFC Atlantic States Marine Fisheries Commission 24 ASSS alternate safe shutdown system 25 ATWS anticipated transient without scram 26 AUTOSAM Automated Abundance Sampler 27 BA biological assessment 28 BO Biological Opinion 29 Board Atomic Safety and Licensing Board 30 Bq/L becquerel per liter 31 Bq/kg becquerel per kilogram 32 BSS Beach Seine Survey 33 BTA best technology available 34 BTU British thermal unit(s) 35 C Celsius 36 CAA Clean Air Act 37 CAFTA computer aided fault-tree analysis code 38 CAIR Clean Air Interstate Rule 39 CAMR Clean Air Mercury Rule 40 CCF common cause failure 41 CCMP Comprehensive Conservation and Management Plan 42 CCW component cooling water December 2010 xxi NUREG-1437, Supplement 38
Abbreviations and Acronyms 1 CCWD Cortlandt Consolidated Water District 2 CDF core damage frequency 3 CDM Clean Development Mechanism 4 CET Containment Event Tree 5 CEQ Council on Environmental Quality 6 CFR Code of Federal Regulations 7 cfs cubic foot (feet) per second 8 CHGEC Central Hudson Gas & Electric Corporation 9 Ci curie(s) 10 CI confidence interval 11 cm centimeter(s) 12 CMP Coastal Management Plan 13 CMR conditional mortality rate 14 CNP Cook Nuclear Plant 15 CO carbon monoxide 16 CO2 carbon dioxide 17 COE cost of enhancement 18 COL Combined License 19 Con Edison Consolidated Edison Company of New York 20 CORMIX Cornell University Mixing Zone Model 21 CPUE catch-per-unit-effort 22 CRDM control rod drive mechanism 23 CST condensate storage tank 24 CV coefficient of variation 25 CWA Clean Water Act 26 CWIS Circulating Water Intake System 27 CZMA Coastal Zone Management Act 28 dB(A) decibel(s) 29 DBA Design-basis accident 30 DC direct current 31 DDT dichloro-diphenyl-trichloroethane 32 DEIS Draft Environmental Impact Statement 33 DF Decontamination Factor 34 DNA deoxyribonucleic acid 35 DNR Department of Natural Resources 36 DO dissolved oxygen 37 DOC dissolved organic carbon 38 DOE U.S. Department of Energy 39 DOS Department of State 40 DOT U.S. Department of Transportation 41 DPS Distinct Population Segment 42 DSEIS Draft Supplemental Environmental Impact Statement 43 EA Environmental Assessment 44 ECL Environmental Conservation Law 45 EDG emergency diesel generator NUREG-1437, Supplement 38 xxii December 2010
Abbreviations/Acronyms 1 EIA Energy Information Administration 2 EIS environmental impact statement 3 EFH Essential Fish Habitat 4 ELF-EMF extremely low frequency-electromagnetic field 5 EMR entrainment mortality rate 6 Entergy Entergy Nuclear Operations, Inc.
7 EOP emergency operating procedure 8 EPA U.S. Environmental Protection Agency 9 EPRI Electric Power Research Institute 10 ER Environmental Report 11 ER-M effects-range-median 12 ESA Endangered Species Act 13 F Fahrenheit 14 F&O Facts and Observations 15 FAA Federal Aviation Administration 16 FDA Food and Drug Administration 17 FEIS Final Environmental Impact Statement 18 FERC Federal Energy Regulatory Commission 19 FES Final Environmental Statement 20 FJS Fall Juvenile Survey 21 FPC Federal Power Commission 22 fps feet per second 23 FPS fire protection system 24 FR Federal Register 25 FSAR Final Safety Analysis Report 26 FSS Fall Shoals Survey 27 ft foot (feet) 28 ft2 square feet 29 ft3 cubic feet 30 FWS U.S. Fish and Wildlife Service 31 g gram(s) 32 gal gallon(s) 33 gCeq/kWh gram(s) of carbon dioxide equivalents per kilowatt-hour 34 GEIS Generic Environmental Impact Statement for License Renewal of Nuclear 35 Plants, NUREG-1437 36 GHG greenhouse gas 37 GL Generic Letter 38 gpm gallon(s) per minute 39 GW gigawatt 40 ha hectare(s) 41 HAP hazardous air pollutant 42 HLW high-level waste 43 hr hour(s) 44 HRA Human Reliability Analysis December 2010 xxiii NUREG-1437, Supplement 38
Abbreviations and Acronyms 1 HRERF Hudson River Estuary Restoration Fund 2 HRFI Hudson River Fisheries Investigation 3 HRPC Hudson River Policy Committee 4 HRSA Hudson River Settlement Agreement 5 IAEA International Atomic Energy Agency 6 IMR impingement mortality rate 7 in. inch(es) 8 INEEL Idaho National Energy and Environmental Laboratory 9 IP1 Indian Point Nuclear Generating Unit No. 1 10 IP2 Indian Point Nuclear Generating Unit No. 2 11 IP3 Indian Point Nuclear Generating Unit No. 3 12 IPE individual plant examination 13 IPEEE individual plant examination of external events 14 ISFSI Independent Fuel Storage Installation 15 ISLOCA Interfacing Systems Loss of Coolant Accidents 16 IWSA Integrated Waste Services Association 17 kg kilogram(s) 18 km kilometer(s) 19 km2 square kilometer(s) 20 kV kilovolt(s) 21 kWh kilowatt hour(s) 22 lb pound(s) 23 L liter(s) 24 LERF Large Early Release Frequency 25 LLMW low-level mixed waste 26 LLNL Lawrence Livermore National Library 27 LOCA loss of coolant accident 28 LODI Lagrangian Operational Dispersion Integrator 29 LOE Line(s) of Evidence 30 lpm liters per minute 31 LRA license renewal application 32 LR linear regression 33 LRS Long River Survey 34 LSE load serving entities 35 m meter(s) 36 mm millimeter(s) 37 m2 square meter(s) 38 m3 cubic meter(s) 39 m3/sec cubic meter(s) per second 40 MAAP Modular Accident Analysis Program 41 MACCS2 MELCOR Accident Consequence Code System 2 42 MBq megabecquerel 43 mg milligram(s)
NUREG-1437, Supplement 38 xxiv December 2010
Abbreviations/Acronyms 1 mgd million gallons per day 2 mg/L milligram(s) per liter 3 mGy milligray 4 mi mile(s) 5 min minute(s) 6 MIT Massachusetts Institute of Technology 7 mL milliliter(s) 8 MLES Marine Life Exclusion System 9 MMBtu million British thermal unit(s) 10 mps meter(s) per second 11 mrad millirad(s) 12 mrem millirem(s) 13 mRNA messenger ribonucleic acid 14 MSE mean squared error 15 MSL mean sea level 16 MSPI Mitigating Systems Performance Indicator 17 mSv millisievert 18 MT metric ton(s) 19 MTU metric ton of uranium 20 MW megawatt 21 MWd megawatt-days 22 MW(e) megawatt(s) electric 23 MW(h) megawatt hour(s) 24 MW(t) megawatt(s) thermal 25 MWSF Mixed Waste Storage Facility 26 NAAQS National Ambient Air Quality Standards 27 NARAC National Atmospheric Release Advisory Center 28 NAS National Academy of Sciences 29 NEA Nuclear Energy Agency 30 NEPA National Environmental Policy Act of 1969, as amended 31 NESC National Electric Safety Code 32 NGO Nongovernmental Organization 33 NHPA National Historic Preservation Act 34 NIEHS National Institute of Environmental Health Sciences 35 NIRS Nuclear Information and Resource Service 36 NMFS National Marine Fisheries Service 37 NJDEP New Jersey Department of Environmental Protection 38 NO2 nitrogen dioxide 39 NOx nitrogen oxide(s) 40 NOAA National Oceanic and Atmospheric Administration 41 NPDES National Pollutant Discharge Elimination System 42 NRC U.S. Nuclear Regulatory Commission 43 NRHP National Register of Historic Places 44 NSSS nuclear steam supply system 45 NWJWW Northern Westchester Joint Water Works 46 NY/NJ/PHL New York/New Jersey/Philadelphia December 2010 xxv NUREG-1437, Supplement 38
Abbreviations and Acronyms 1 NYCA New York Control Area 2 NYCDEP New York City Department of Environmental Protection 3 NYCRR New York Code of Rules and Regulations 4 NYISO New York Independent System Operator 5 NYPA New York Power Authority 6 NYPSC New York Public Service Commission 7 NYRI New York Regional Interconnect, Inc.
8 NYSDEC New York State Department of Environmental Conservation 9 NYSDOH New York State Department of Health 10 NYSERDA New York State Energy Research and Development Authority 11 NYSHPO New York State Historic Preservation Office 12 O3 ozone 8-hour standard 13 OCNGS Oyster Creek Nuclear Generating Station 14 ODCM Offsite Dose Calculation Manual 15 OMB Office of Management and Budget 16 OPR Office of Protected Resources 17 PAB primary auxiliary building 18 PAH polycyclic aromatic hydrocarbon 19 PCB polychlorinated biphenyls 20 pCi/L picoCuries per liter 21 pCi/kg picoCuries per kilogram 22 PDS plant damage state 23 PILOT payment-in-lieu-of-taxes 24 PM particulate matter 25 PM2.5 particulate matter, 2.5 microns or less in diameter 26 PM10 particulate matter, 10 microns or less in diameter 27 POC particulate organic carbon 28 PORV power operated relief valve 29 POST Parliamentary Office of Science and Technology 30 ppm parts per million 31 ppt parts per thousand 32 PRA probabilistic risk assessment 33 PSA probabilistic safety assessment 34 PV photovoltaic 35 PWR pressurized water reactor 36 PWW Poughkeepsie Water Works 37 PYSL post yolk-sac larvae 38 REMP Radiological Environmental Monitoring Program 39 R-EMAP regional environmental monitoring and assessment program 40 RAI request for additional information 41 RCP reactor coolant pump 42 RCRA Resource Conservation and Recovery Act 43 RCS reactor cooling system 44 REMP radiological environmental monitoring program NUREG-1437, Supplement 38 xxvi December 2010
Abbreviations/Acronyms 1 RHR residual heat removal 2 Riverkeeper Hudson River Fishermens Association 3 RIS Representative Important Species 4 RKM river kilometer(s) 5 RM river mile(s) 6 RMP Risk Management Plan 7 ROD Record of Decision 8 ROI region of influence 9 ROW right-of-way 10 RPC long-term replacement power costs 11 rpm revolutions per minute 12 RRW risk reduction worth 13 RWST refueling water storage tank 14 s second(s) 15 SAFSTOR safe storage condition 16 SAMA severe accident mitigation alternative 17 SAR Safety Analysis Report 18 SAV submerged aquatic vegetation 19 SBO station blackout 20 Scenic Hudson Scenic Hudson Preservation Conference 21 SCR selective catalytic reduction 22 SECPOP sector population, land fraction and economic estimation program 23 SEIS Supplemental Environmental Impact Statement 24 SFP Spent Fuel Pool 25 SGTR Steam Generator Tube Ruptures 26 SI Safety Injection 27 SO2 sulfur dioxide 28 SOx sulfur oxide(s) 29 SPDES State Pollutant Discharge Elimination System 30 SPU stretch power update 31 sq mi square mile(s) 32 SR segmented regression 33 SRP Standard Review Plan 34 SRT Status Review Team 35 SSBR spawning stock biomass per-recruit 36 SSE safe shutdown earthquake 37 Sv person-sievert 38 SWS service water system 39 t ton(s) 40 TDEC Tennessee Department of Environment and Conservation 41 TI-SGTR thermally-induced Steam Generator Tube Ruptures 42 TLD Thermoluminescent dosimeter 43 TOC total organic carbon 44 TRC TRC Environmental Corporation December 2010 xxvii NUREG-1437, Supplement 38
Abbreviations and Acronyms 1 U.S. United States 2 U.S.C. United States Code 3 USACE U.S. Army Corps of Engineers 4 USAEC U.S. Atomic Energy Commission 5 USCB U.S. Census Bureau 6 USDA U.S. Department of Agriculture 7 USGS U.S. Geological Survey 8 UWNY United Water New York 9 V volt(s) 10 VALWNF value of non-farm wealth 11 VOC volatile organic compound 12 WCDOH Westchester County Department of Health 13 WISE World Information Service on Energy 14 WJWW Westchester Joint Water Works 15 WOE weight of evidence 16 WOG Westinghouse Owners Group 17 YSL yolk-sac larvae 18 YOY young of year 19 yr year(s)
NUREG-1437, Supplement 38 xxviii December 2010
1 Appendix A 2
3 4 Comments Received on the Environmental Review
Appendix A 1
2 3
4 5
6 7
8 9
10 11 12 The following pages contain the original comment letters, e-mail messages, 13 and public meeting transcripts pertaining to the IP scoping summary report.
14 Each commented is labeled and identified by a unique comment 15 identification code.
16 17 December 2010 A-175 NUREG-1437, Supplement 38
Appendix A 1 MR. ADAMS: Good evening. I'm Kenneth Adams. I'm the 2 president and CEO of the Business Council of New York State, 3 which is the leading statewide business association. We 4 represent more than 3000 private-sector employers, over a 5 million of their employees and about 90 local Chambers of 6 Commerce throughout the state of New York. The largest 7 component of our membership at the Business Council is 8 manufacturing with more than 1100 employers. It's the sector 9 for which the reliability and cost of electric power is a 10 significant concern. We also represent many businesses in the 11 energy field, including Entergy, which has been a Business 1-a-EC/SO/
12 Council member since 2000. Because the importance of energy SR 13 issues to our broad membership, we welcome the opportunity to 14 testify in support of the Indian Point Energy Center and the 15 important role the site plays in maintaining the economic health 16 of the whole state of New York.
17 The most recent data from the U.S. Energy Information 18 Administration show electric rates in New York of residential 19 and commercial customers at about 64% above the national 20 average. And for industrial customers, many of our Business 1-b-EC/
SE 21 Council members, something like 47% above the national average.
22 Several years ago, we estimated that this electric energy 23 premium share in New York State costs our economy more than $6 24 billion a year. Given these price pressures and continuing NUREG-1437, Supplement 38 A-176 December 2010
Appendix A 1 increases in energy consumption and peak demand, theres an 2 obvious need to maintain or add to our existing generating 3 capacity. Energy supply and price remains a key factor for the 4 competitiveness of our states economy. If were going to get 5 our economy to turnaround, energy pricing and availability and 6 reliability are just going to be fundamental. One company that 7 is already paying an extraordinary cost for conducting business 8 in New York State is in fact Entergy. We need to remember that 9 Entergy was invited to become the state's business partner in 10 running two of the three nuclear plants the company purchased in 11 New York back in 2000.
12 At that time, the company's background and expertise 1-b-EC/
SE 13 was thoroughly scrutinized by the state. After an extensive contd.
14 vetting and licensing process, the company, you can say, won the 15 right to run Indian Point 3 and James A. FitzPatrick nuclear 16 facility in upstate New York. In addition to their initial one 17 billion-dollar investment in buying these plants, Entergy has 18 invested hundreds of millions of dollars to run these assets, 19 making marked improvements in their performance. Entergy's 20 operations also directly benefit the state through a substantial 21 revenue-sharing agreement. They support many other in-state 22 businesses through the goods and services they buy. They pay 23 significant taxes to the local communities and schools, invest 24 millions in emergency planning upgrades, invest millions more December 2010 A-177 NUREG-1437, Supplement 38
Appendix A 1 into regional non-profit organizations and most importantly, 2 employ thousands in the state at a time when many other 1-b-EC/
SE 3 companies are making significant cutbacks in their New York contd.
4 State employment.
5 In upstate New York where Entergy is a welcome member 6 of the Oswego County community, there is interest in expanding 7 nuclear power there and rightly so. The FitzPatrick plant is 8 just as well run as the one here, just as critical and provides 9 the stabilizing economic force in an area of New York State 10 suffering in this recession. Downstate here in this region, 11 some try to portray Indian Points potential closure as being 12 somehow far less consequential to the area than a closure in 1-c-EC/
SO 13 upstate New York. But this assumption is widely incorrect.
14 Indian Point provides 2000 Mw of affordable, reliable, 15 green, clean power something to 40% of this region's energy 16 supply during peak times. Overall, nuclear power is essential 17 to the state's energy grid. Last year through the end of 18 October, nuclear plants provided 30.3% of all kilowatt hours of 19 electric power produced in New York. Nearly the same level as 20 natural gas generation, which is about 31.9%. Importantly, in 21 the carbon restricted regulatory environment imposed by the 22 Regional Greenhouse Gas Initiative, these 35 million Mw hours 1-d-AQ/
EC 23 were produced at nuclear facilities without significant 24 greenhouse gas emissions from power generation. Both public and NUREG-1437, Supplement 38 A-178 December 2010
Appendix A 1 private studies, including extensive analysis done by 2 Westchester County and the federal government, have shown the 3 critical importance of Indian Point, the lack of viable 4 replacement power and the consequences of shutting the facility 5 down. According to the New York Independent System Operator, 6 the closing of Indian Point Energy Center quote would cause an 7 immediate violation of reliability standards close quote.
8 Closing Indian Point would significantly weaken the state's 9 energy grid. Every day the demand grows for affordable, 10 reliable, low- carbon electric power generation, no question. 1-d-AQ/
EC 11 Indian Point meets all three of these needs in the lower Hudson contd.
12 Valley making the plant an invaluable facility in this region.
13 Nuclear power is an environmentally sound and carbon-clean 14 source of power. If Indian Point is not re-licensed, 15 replacement power would have to come from sources already deemed 16 inadequate to replace Indian Point. Furthermore, studies show 17 that replacing Indian Points power with fossil fuel based 18 plants will likely create a rise in carbon dioxide emissions, a 19 19% jump in nitrous oxide emissions and an 11% hike in sulfur 20 dioxide emissions.
21 MR. RAKOVAN: Sir, if you could conclude, please.
22 MR. ADAMS: For all of these reasons, I'm going to 23 conclude right now.
24 MR. RAKOVAN: Thank you.
December 2010 A-179 NUREG-1437, Supplement 38
Appendix A 1 MR. ADAMS: As well as the million dollars in annual 2 economic stimulus Indian Point provides the state, the Business 3 Council of New York State, my organization, strongly supports 1-e-SR 4 the re-licensing of the Indian Point Energy Center. Thank you 5 all for being here. Thank you very much for your attention.
6 7
8 9
NUREG-1437, Supplement 38 A-180 December 2010
Appendix A 1 MS. ALLEN: Hi, I'm Judy Allen. I live in Putnam 2 Valley. I do not get any electricity from Indian Point because 3 Putnam County does not. However, I live 14 miles away from the 4 plant. So, I am actually going to address the environmental 5 impact and I would like to see who are the people here from the 6 NRC, so I know who I'm talking to? Okay, thank you very much.
7 The slide that I'm addressing is the Example Common Issue:
8 Radiological Impacts and it says, Preliminary findings: no new 9 and significant information. GEIS conducted impacts are SMALL. 2-a-AL/RI 10 So, you're not going to want to know about the Wall Street 11 article in November 21st that says, surprise drop in power 12 worries utilities. You're not going to want to know about cover 13 story in Time of December 31st that says, America's untapped 14 energy resource boosting efficiency. This is not about 15 conservation. This is not about putting on a sweater or turning 16 the lights off. This is just about increased efficiency.
17 You're not going to know about, you're not going to 18 want to know about the study on rising child leukemia rates near 19 U.S. nuclear plants because Joe Mangano, I believe is going to 20 be submitting written information about that. So, what I'm 2-b-HH/
RI 21 going to talk about is the study that faults regulators for 22 relying on reference-man radiation dose standard. A study from 23 the Institute for Energy and Environment Research indicates that 24 U.S. radiation exposure regulations and compliance assessment December 2010 A-181 NUREG-1437, Supplement 38
Appendix A 1 guidelines often underestimate the risk of radiation for women 2 and children because they are based on standards of the 3 reference-man. A hypothetical 20 to 30 year old white male.
4 Could I have a show of hands please, how many people fall into 5 that category of 20 to 30 year old white male. That's one.
6 Anyone else?
7 Okay, so at least three federal agencies: the 8 Environmental Protection Agency, Nuclear Regulatory Commission 9 and Department of Energy, still use reference-man criteria to 10 guide radiation dose regulations and compliance assessment. A 11 woman is 52% more likely than a man to develop cancer from the 12 same radiation doses according to the study. Children are at 2-b-HH/
RI 13 greater risk than adults. A female infant has about an 11 times contd.
14 greater chance of eventually developing cancer than a 30-year-15 old male in the same radiation dose. Pregnant women and the 16 developing fetus are particularly vulnerable, but non-cancer 17 reproductive effects are generally not part of U.S. regulatory 18 framework for radiation production.
19 Okay, so, the last thing about this in the report 20 recommends that compliance with radiation protection always the 21 estimated by calculating doses for those at greatest risk. It 22 calls for a significant reduction in the maximum allowable dose 23 to the general public from 100 mrem per year to 25 mrem per 24 year. So, I believe that would be considered new information NUREG-1437, Supplement 38 A-182 December 2010
Appendix A 1 and I will hope that the NRC will consider that new information 2-b-HH/
RI 2 in determining whether Indian Point should be re-licensed and contd.
3 after 20 years. Thank you very much.
4 5
December 2010 A-183 NUREG-1437, Supplement 38
Appendix A 1
2 2-c-HH NUREG-1437, Supplement 38 A-184 December 2010
Appendix A 1
2 2-c-HH contd.
December 2010 A-185 NUREG-1437, Supplement 38
Appendix A 1
2 3-a-AE/LE/LR NUREG-1437, Supplement 38 A-186 December 2010
Appendix A 1
2 4-a- AE/LR December 2010 A-187 NUREG-1437, Supplement 38
Appendix A 4-a-LR contd.
4-b-AL/LR 1
NUREG-1437, Supplement 38 A-188 December 2010
Appendix A 4-b-AL/LR contd.
4-c-LR/SF 4-d-CI/LR/SO 1
December 2010 A-189 NUREG-1437, Supplement 38
Appendix A 4-d-CI/LR/SO contd.
4-e-LR 1
2 NUREG-1437, Supplement 38 A-190 December 2010
Appendix A 1 REV. DR. ANTHONY: Good afternoon, my name is Reverend 2 Dr. Cheryl Anthony and I am the pastor and CEO of Jude 3 International Christian Center. Jude International Christian 4 Center is a multi-faceted inner-city ministry that serves as an 5 intermediary to government agencies, the private sector, 6 churches, mosques, temples and synagogues. I have served as a 7 faith-based liaison and advisor to Presidents Bush and Clinton 8 helping them to implement programs within our local community.
9 I'm here today representing my congregation as well as the 10 African-American clergy and elected officials, the Brooklyn 11 Council of Churches and Woman of Faith advocating change. We 12 are here in support of the Indian Point Energy Center.
13 Over the past years, we have seen the air quality in 14 Brooklyn get worse and worse as more people move into our 15 neighborhood and fill our streets with cars and diesel trucks 5-a-AQ/SR 16 that pollute the air that we breathe. In fact, the air-quality 17 throughout New York City is dangerously below federal standards.
18 I support the re-licensing of Indian point because I know that 19 nuclear power is a safe way to reduce greenhouse gas emissions 20 and pollution in our community and keep Brooklyn safe for future 21 generations. The dangers of rising greenhouse gases and 22 pollution are visible even today, particularly in Brooklyn's low 23 income families.
24 December 2010 A-191 NUREG-1437, Supplement 38
Appendix A 1 Our children, exposed to dangerously poor air quality 2 are developing, and it's been said previously, but I need to 3 reiterate, are developing asthma at a rate that is four times a 4 national average. Many of Brooklyn's families cannot afford to 5 pay for the metal care and medicines that children need, leading 6 to hospitalization and missed school days for low income 5-b -AQ/SR 7 children. Yet, because of this disease, poor air quality can be 8 prevented through smart policy decisions and a dedication clean 9 air technology. Re-licensing the Indian Point Energy Center is 10 a critical step in improving air quality in our communities and 11 lowering the number of those that suffer from asthma. Religious 12 leaders throughout Brooklyn see Indian Point as a clean, safe 13 and affordable option for New York City's energy supply.
14 By re-licensing Indian Point, New York has the 15 opportunity to invest in a future that reduces greenhouse gases 16 and is safer for our children. Thank you for giving me this 5-c-AQ/SR 17 opportunity to speak today. I hope that through my testimony 18 and that of other supporters, you will see how keeping Indian 19 Point open is the right move for New York. Thank you.
20 21 22 NUREG-1437, Supplement 38 A-192 December 2010
Appendix A 1
2 3
6-a-EP/OR December 2010 A-193 NUREG-1437, Supplement 38
Appendix A 1
2 3
7-a-SE/SL 7-b-AL 7-c-SO 7-d-AQ/EC/SR 7-e-SR NUREG-1437, Supplement 38 A-194 December 2010
Appendix A 1
2 December 2010 A-195 NUREG-1437, Supplement 38
Appendix A 1
2 3
8-a-SR 8-b-SO 8-c-AQ/HH/SO 8-d-SE/SR NUREG-1437, Supplement 38 A-196 December 2010
Appendix A 1
2 9-a-GI December 2010 A-197 NUREG-1437, Supplement 38
Appendix A 1
2 9-b-OR/SA 9-c-LE/PA/RW 9-d-EP 9-e-AE/AL 9-f-AL NUREG-1437, Supplement 38 A-198 December 2010
Appendix A 1
2 9-f-AL contd.
9-g-AL/SO 9-h-AE/AL/AQ December 2010 A-199 NUREG-1437, Supplement 38
Appendix A 1
2 9-h-AE/AL/AQ contd.
9-i-AL/ED NUREG-1437, Supplement 38 A-200 December 2010
Appendix A 1
2 9-i-AL/ED contd.
December 2010 A-201 NUREG-1437, Supplement 38
Appendix A 1
2 9-i-AL/ED contd.
9-j-AL/ED NUREG-1437, Supplement 38 A-202 December 2010
Appendix A 1
2 3
December 2010 A-203 NUREG-1437, Supplement 38
Appendix A 1 MS. BARTHELME: Hi, I'm Margaret Barthelme. I am the 2 last student from Ramapo Colleges Environmental Assessment 3 class. I just want to go over three points in regard to the 4 DSEIS. I believe that certain things are lacking from it. I 10-a-PA 5 believe that the spent nuclear storage is not adequately 6 examined, specifically in a site-specific examination of the 7 imminent danger of the proximity of the Ramapo faults.
8 Including the unmentioned use of the resources of Unit 1, which 9 never had an impact statement.
10 Secondly, to be in compliance, Indian Point must 11 install a cooling tower. This is an unlikely future action and 12 the impacts of the impending tower need to be addressed in a 10-b-AL 13 more in-depth analysis including visual impacts and others, 14 instead of just a cursory evaluation. So these are two issues I 15 believe are not addressed in the DSEIS. Without them, it's not 16 an accurate environmental assessment.
17 A third side note, we've been talking a lot of the 18 greenhouse gas emissions. But theyre based on a 19-year-old 19 study by Mortimer who found savings in greenhouse gas emissions, 20 but it was based on a more pure ore. So, if we could have an 10-c-GL 21 updated look at that we might have a more accurate point of the 22 amount of greenhouse gases were having. So, to be short, thank 23 you for your time. Thank you to the NRC for allowing me to 24 speak.
NUREG-1437, Supplement 38 A-204 December 2010
Appendix A 1
2 10-d-PA December 2010 A-205 NUREG-1437, Supplement 38
Appendix A 1
2 3
NUREG-1437, Supplement 38 A-206 December 2010
Appendix A 1
2 11-a-OR 11-b-AE 11-c-AE 11-d-LE 11-e-RW/ST 11-f-AL/OR December 2010 A-207 NUREG-1437, Supplement 38
Appendix A 1
2 3
12-a-OR 12-b-AE 12-c-AE 12-d-LE 12-e-RW/ST 12-f-AL NUREG-1437, Supplement 38 A-208 December 2010
Appendix A 1
2 13-a-OR 13-b-AE 13-c-AE 13-d-PA/RW/ST 13-e-PA/SF 13-f-AM/GE/OM 13-g-DE/EP December 2010 A-209 NUREG-1437, Supplement 38
Appendix A 1
2 13-g-DE/EP contd.
13-h-OR 3
NUREG-1437, Supplement 38 A-210 December 2010
Appendix A 1
2 3
4 December 2010 A-211 NUREG-1437, Supplement 38
Appendix A 1
2 3
14-a-AQ/EJ/SR NUREG-1437, Supplement 38 A-212 December 2010
Appendix A 1
2 14-a-AQ/EJ/SR contd.
14-b-AQ/EJ/SR December 2010 A-213 NUREG-1437, Supplement 38
Appendix A 1
14-b- AQ/EJ/SR contd.
14-c-AL/AQ 14-d-AL/EJ/GL NUREG-1437, Supplement 38 A-214 December 2010
Appendix A 1
2 3
4 5
6 14-d-AL/EJ/GL contd.
December 2010 A-215 NUREG-1437, Supplement 38
Appendix A 1
2 14-d-AL/EJ/GL contd.
14-e-SR NUREG-1437, Supplement 38 A-216 December 2010
Appendix A 1
2 3
15-a-OR December 2010 A-217 NUREG-1437, Supplement 38
Appendix A 1
2 16-a-DE/PA 16-b-PS/ST 16-c-EP/PA/PS NUREG-1437, Supplement 38 A-218 December 2010
Appendix A 1
2 16-c-EP/PA/PS contd.
16-d-LR 3
December 2010 A-219 NUREG-1437, Supplement 38
Appendix A 1
2 NUREG-1437, Supplement 38 A-220 December 2010
Appendix A 1
2 17-a-NE/SF 17-b-EP/LI/ST December 2010 A-221 NUREG-1437, Supplement 38
Appendix A 1
2 17-b-EP/LI/ST contd.
17-c-NE NUREG-1437, Supplement 38 A-222 December 2010
Appendix A 1
2 17-c-NE contd.
December 2010 A-223 NUREG-1437, Supplement 38
Appendix A 1
2 17-c-NE contd.
17-d-DE NUREG-1437, Supplement 38 A-224 December 2010
Appendix A 1
2 17-e-NE/PA 17-f- PA December 2010 A-225 NUREG-1437, Supplement 38
Appendix A 1
2 17-f- PA contd.
17-g-ST NUREG-1437, Supplement 38 A-226 December 2010
Appendix A 1
2 17-h-SF 17-i-SF/ ST 17-j-SF December 2010 A-227 NUREG-1437, Supplement 38
Appendix A 1
2 17-j-SF contd.
17-k-SF/ST NUREG-1437, Supplement 38 A-228 December 2010
Appendix A 1
2 17-k-SF/ST contd.
17-l-SF/ST December 2010 A-229 NUREG-1437, Supplement 38
Appendix A 1
2 17-l- SF/ST contd.
17-m-EP 17-n-EP/PA/
ST NUREG-1437, Supplement 38 A-230 December 2010
Appendix A 1
2 17-n-EP/PA/
ST contd.
17-o-AE/LI/NE December 2010 A-231 NUREG-1437, Supplement 38
Appendix A 1
2 17-o-AL/LI/NE contd.
17-p-EP/PA/RI 17-q-AE/NE/
OE NUREG-1437, Supplement 38 A-232 December 2010
Appendix A 1
2 17-q-AE/NE/
contd.
December 2010 A-233 NUREG-1437, Supplement 38
Appendix A 1
2 3
17-q-AE/NE/
contd.
17-r-EP/GI/RI NUREG-1437, Supplement 38 A-234 December 2010
Appendix A 1
2 3
18-a-LE/OR 18-b-DE/ST 18-c-AE 18-d-OR December 2010 A-235 NUREG-1437, Supplement 38
Appendix A 1 MR. BOWMAN: Good afternoon everyone. Good afternoon.
2 How are you? I know that were all here on different sides, but 3 we are all in this together. My name is Reginald Bowman and Im 4 the Chairperson of the New York City Housing Authority's 5 Resident Council, which actually represents more than 400,000 6 New Yorkers that live in public housing in the five boroughs of 7 the city of New York. And all the speakers that have come 8 before me have sort of outlined what I had to say and I just 9 wanted to make sure that when I came up here today looked around 10 this room I encouraged all of us who are here, regardless of 11 which side we are on, to understand that were all in this 12 together and there's a domino effect that takes place when 19-a-EC/
SR 13 policy decisions are made about major facilities like this that 14 provide a life source of energy for all of us that live in the 15 State of New York. Last summer, gas and electricity bills 16 skyrocketed for the renters, homeowners, businesses across the 17 country.
18 In New York City in public housing, people say well, 19 people in public housing don't pay electric bills. That's no 20 longer true. We that live in public housing were hit with rent 21 increases that were directly related to the fact that the energy 22 cost for the New York City Housing Authority have escalated 23 along with the cost for everything else that is provided for 24 people in public housing through those budgets. Those of us NUREG-1437, Supplement 38 A-236 December 2010
Appendix A 1 that live in those developments were directly impacted by those 2 things. It is vitally important to keep Indian Point open as 19-a-EC/
3 one of the few sources of energy with reliable output and stable SR contd.
4 prices. You've heard that over and over again this afternoon 5 and when someone repeats something over and over again, some 6 part of that has to be true.
7 During this period of economic insecurity, we cannot 8 afford to make already struggling families and businesses pay 9 more just to keep our houses warm and you know what happened 10 this winter, it was a brutal winter here up-state. It was a 11 brutal winter down-state. Were paying more and more to keep a 12 houses warm. And if we're going to think about the next 10, 15, 13 20 years of energy provision for this region, we have to really 14 realistically look at the fact that we're going to have to keep 19-b-EC/
SO/SR 15 Indian Point online if we're going to provide this energy and 16 then do the intelligent type of thinking together to create 17 policy for the future and to keep the energy and businesses in 18 our community alive. The re-licensing of Indian Point will not 19 only protect families from overly expensive energy costs. It 20 will also help the economy stabilize in this difficult economic 21 time. High prices for gas and oil effect costs across the 22 economy from making and shipping products to subway and bus 23 fares.
24 December 2010 A-237 NUREG-1437, Supplement 38
Appendix A 1 Indian Point, however, represents stability in this 2 unpredictable atmosphere. The reliability and stable course of 3 nuclear energy are one of the keys to keeping the economic 4 crisis from spiraling out of control for the people that I 5 represent in public housing in the city of New York. So, as the 6 president of the Council of residents of the New York City 19-c-EC/
7 Housing Authority, I cannot stand by as opponents of Indian SO/SR 8 Point threaten to force New York City families to pay higher 9 rents, outrageous energy bills and more for the products and 10 services that we need. New York must move together towards 11 making sure that all families in this state and in the city have 12 access to affordable energy. Re-licensing Indian point is the 13 first step in making that goal a reality. Thank you.
14 15 16 NUREG-1437, Supplement 38 A-238 December 2010
Appendix A 1 MS. BRANCATO: Hello everyone. My name is Deborah 2 Brancato. I'm a staff attorney for Riverkeeper. We will be 3 submitting detailed written comment on the Draft Environmental 4 Impact Statement, but for today I just want to highlight some of 5 the major concerns Riverkeeper sees with the NRC staffs analysis 6 of the environmental impacts of relicensing.
7 To begin with, the NRC has completely failed to assess 8 the impacts of nuclear waste storage at Indian Point.
9 Currently, Indian Point houses 1500 tons of nuclear waste on 10 site in pools and in dry-cask storage. If the plant is 11 relicensed for an additional 20 years, at least an additional 12 1000 tons will accumulate. The Draft Environmental Impact 13 Statement has no analysis whatsoever of a long-term impacts of 14 storing all of this waste on site. Security issues continue to 20-a-PA/
15 evade any kind of site-specific review. Including the SF/ST 16 vulnerability of the pools and the dry-casks to terrorist 17 attacks or natural disasters. Given that only last week there 18 was an earthquake that registered a magnitude of 3 in New Jersey 19 right near the Ramapo seismic zone and the Ramapo fault-line 20 does run directly underneath Indian Point, it is truly incumbent 21 upon the NRC to provide an analysis of whether the dry-casks and 22 the pools are designed so that they would be able to withstand 23 such natural occurrences or intentional attacks.
24 In addition, we take issue with the NRC staffs 20-b-HH December 2010 A-239 NUREG-1437, Supplement 38
Appendix A 1 analysis of the ongoing leaking that is going on from the spent 2 fuel pools. The Unit 1 pools and the Unit 2 pools have been 3 leaking radioactive materials into the groundwater which leaches 4 into the Hudson River for years now. The NRC has concluded in 5 the Environmental Impact Statement that these impacts are not 20-b-HH contd.
6 significant. We do not believe they have done a complete 7 analysis. They have merely looked at imminent public health 8 impacts and really have not done any analysis whatsoever of the 9 long-term impacts to the groundwater into the Hudson River 10 ecosystem.
11 In addition to their complete failure to adequately 12 look at nuclear waste storage issues, we also take issue with 13 the NRC's analysis of aquatic impacts due to the once-through 14 cooling system. This cooling system slaughters billions of fish 15 eggs and larvae every year contributing to the overall decline 16 in fish species populations in the Hudson River. And yet the 17 NRC is only able to come to the conclusion of large impact as to 20-c-AE/
OR 18 one species in the river and thats bluefish. We believe based 19 on current data and analyses that a finding of large impacts is 20 warranted across the board for species in the Hudson River. Of 21 particular concern is the NRC's lack of definitive conclusion as 22 to the impacts to the endangered species of short-nosed 23 sturgeon, which there's no data showing that they aren't 24 impinged against the cooling water intake screens and yet the NUREG-1437, Supplement 38 A-240 December 2010
Appendix A 1 NRC has failed to come to any definitive conclusion as to the 2 impacts to that species. So, those are all the remarks I'll 3 provide today. Again, Riverkeeper will be providing detailed 20-c-AE/
4 written comments by the March 18th deadline and in conclusion we OR contd.
5 do not agree with the NRC with the overall conclusion that the 6 impacts of relicensing will be not so significant in the future.
7 Thank you.
8 9
10 December 2010 A-241 NUREG-1437, Supplement 38
Appendix A 1
2 3
21-a-AE/
OR/SF 21-b-GI/OR NUREG-1437, Supplement 38 A-242 December 2010
Appendix A 1
2 3
22-a-HH/OR/
PA December 2010 A-243 NUREG-1437, Supplement 38
Appendix A 1 MR. BURRUSS: Good evening. My name is Melvin Burruss.
2 I'm president of the African-American Men of Westchester. I want 3 to thank the NRC and you folks for coming here today because you 4 could've been somewhere else. The issues here before us are 5 very complex. We can talk about the health issues. We can 6 talk about the energy issues. The environmental issues. 23-a-SE/
SR 7 Employment issues also. But more importantly, I want to talk 8 about and just briefly say that I support, or my organizations 9 support, Indian Point and Entergy because they are great 10 corporate partners. They are interested in our kids education 11 and they have helped support educating our young people and 12 getting our young people scholarships to go on to college.
13 But the other side of it is Indian Point, as you know, 14 in this recession that we have and people are losing their jobs, 23-b-SO 15 do we need or can we afford to lose or close down Indian Point 16 and lose the amount of jobs and the income that folks have there 17 now? Also, Indian Point currently helps New York progress on 18 improving the quality of the air we breathe. You heard before 19 me, people were saying 30% to 70% of the African-Americans and 20 Hispanics have asthma. Which is true. Here in Westchester 23-c-AL/
AQ 21 County, there's 5000 asthmatic young people every year here.
22 Any replacement options would truly increase the pollutants and 23 toxins that this congested region already feels throughout the 24 year. Indian Point also helps the region maintain independence 23-d-EC NUREG-1437, Supplement 38 A-244 December 2010
Appendix A 1 from the radically fluctuating oil and gas prices. New York 2 State, in efforts to maintain a clean environment, rely very 23-d-EC 3 heavily on natural gas for electricity production. This contd.
4 reliance is beneficial and it produces fewer pollutants than 5 coal.
6 As you can see, you can look over to the west side of 7 the Hudson and you can see that coal fed plant over there 23-e-AQ 8 polluting the air sending many toxins back over here to 9 Westchester County. Do we need any more of that? The economic 10 impacts of closing Indian Point are very real. At this time, 11 there's no feasible alternative of the 2000 Mw that's produced 12 continuously by the plant. This shut down of the facility would 13 truly result in real prices to pay in terms of job losses and 14 increased cost to Westchester residents. Not only the taxes 15 thats being paid here to municipalities which also helps in our 16 cleanup, trash removal, municipality of services that we would 23-f-EC/
17 lose and as we know, every dollar counts. Besides the large job SO 18 losses and increase electrical costs, Indian Point has its own 19 economic engine. The taxes paid by Entergy surely are a great 20 benefit to the county as well as to local municipalities. Also, 21 their contributions to emergency response services, now in a 22 time after 9/11. So, I just want to close and say that many 23 Westchester County residents in the Peekskill area are also 24 struggling to keep their houses and pay their electric bills.
December 2010 A-245 NUREG-1437, Supplement 38
Appendix A 1 The close of Indian Point would only compound that area and have 2 an immediate negative impact on all of us. Thank you very much. 23-g-SR 3 We support continuing the re-license of Indian Point. Thank 4 you.
5 6
7 NUREG-1437, Supplement 38 A-246 December 2010
Appendix A 1
2 3
23-h-AL/AQ 23-i-EC/SO/
SR December 2010 A-247 NUREG-1437, Supplement 38
Appendix A 1 MS. BURTON: Thank You. Good afternoon. I'm Nancy 2 Burton and I've come here all the way from Redding, Connecticut 3 with three pales of mine: Cindy-Lou and Luna and The Dude.
4 They are outside in the car for anybody would like to make their 5 acquaintance. I'm here on behalf of the Mothers Milk Project, 6 which was launched this past June involving New York and 7 Connecticut directors.
8 Our purpose is to collect and sample, at a certified 9 laboratory, milk that is collected from mothers, including human 10 mothers. This has never been done before on a formal basis by 11 citizens near a nuclear power plant. We're also collecting milk 12 from mammals, including goats and cows and sheep and any other 13 mammals, who are willing to share their milk with us. The 14 reason we are doing this is that Entergy is not. Entergy does 15 not engage in any sampling of milk as part of its radiological 24-a-HH/
16 effluent sampling program at Indian Point. They do in Vermont OR/RI 17 sample milk from dairy cows near Brattleboro.
18 In addition, the NRC does not independently sample 19 milk for purposes of evaluating environmental contamination by 20 Indian Point, nor does New York state's Department of Health or 21 its environmental agency and neither does Connecticuts 22 Department of Health and environmental agencies. I'm here today 23 specifically to tell you that we have so far collected some 60 24 samples of milk from the all kinds of mothers and we have NUREG-1437, Supplement 38 A-248 December 2010
Appendix A 1 received to date 30 results from our independent laboratory, 2 which is charging us a commercial, competitive rate.
3 I have with me a statement, which I have left at the 4 front desk to be inserted in the record, but I'd like to share a 5 couple of highlights from our first results with you today.
6 I'll begin with Cindy-Lou. We have guaranteed absolute 7 confidentiality to all of the participants in the project who 8 share their milk unless they choose to go public and they 9 possibly may in the future when we have a large event and invite 10 them all to come and speak. These are preliminary results that 11 we have received and so the only donor so far who has waived 12 confidentiality is my friend Cindy-Lou the goat. She has given 24-a-HH/
OR/RI 13 seven samples that we have received results for so far and one contd.
14 of those results, in particular, has potentially grave 15 significance for all of us and that is her milk has tested for 16 levels of Strontium-90, 3.4, and Strontium-89, 3.7. Strontium-17 90 is a potent carcinogen. It's routinely released by Indian 18 Point. It doesn't disappear and go away. Even though you cant 19 see it or smell it or hear it or taste it. Also, the same for 20 Strontium-89. Both are routinely released. Strontium-90 has a 21 half-life of 28 years. It's around for a long time. Strontium-22 89 decays within 50 days. The significance of that is that if 23 you have a sample that has both radioisotopes, as Cindy-Lous 24 milk did, then it means that there's a very good probability December 2010 A-249 NUREG-1437, Supplement 38
Appendix A 1 that the source of the radiation was a recent fission event 24-a-HH/
2 because otherwise the Strontium-89 would have decayed to a point OR/RI contd.
3 beyond detectability.
4 MR. RAKOVAN: Ms. Burton --
5 MS. BURTON: Yes.
6 MR. RAKOVAN: If you could summarize. We asked 7 everyone to stick to about three minutes.
8 MS. BURTON: I'm very sorry. To move to the mothers, 9 we have one mother of 11 who gave us samples who tested 10 positively for both Strontium-90 and Strontium-89. She lives 11 about 10 miles from Indian Point and that is extremely 12 troubling. All our goat and dairy cow samples tested positively 13 for Strontium-90. Of the 11 mothers, human mothers, who gave us 14 samples, only two tested clear for Strontium-90. There was no 15 detectable level. The others, nine mothers living within 50 24-a-HH/
16 miles and most very close to Indian Point are in the process or OR/RI contd.
17 recently were feeding their babies breast milk that is 18 radioactive. With these comments, I am asking the NRC to 19 suspend its re-licensing proceedings. To do a thorough 20 investigation of this very, very fundamentally serious issue and 21 new information. To the extent that you are able to verify the 22 preliminary numbers I'm giving you today, I believe it calls for 23 cessation of the operations of this facility. Thank you very 24 much.
NUREG-1437, Supplement 38 A-250 December 2010
Appendix A 1
24-b-HH/OR/
RI December 2010 A-251 NUREG-1437, Supplement 38
Appendix A 1
24-b-HH/OR/
RI contd.
NUREG-1437, Supplement 38 A-252 December 2010
Appendix A 1
24-b-HH/OR/
RI contd.
December 2010 A-253 NUREG-1437, Supplement 38
Appendix A 1
2 3
24-b-HH/OR/
RI contd.
NUREG-1437, Supplement 38 A-254 December 2010
Appendix A 1
2 3
25-a-OR December 2010 A-255 NUREG-1437, Supplement 38
Appendix A 1
2 MR. BYRD: Good afternoon. My name is Ricardo Byrd. I 3 am the executive director of the National Association of 4 Neighborhoods. NAN is one of America's oldest and largest 5 grassroots multi-issue membership organizations. Our mission is 6 to improve the quality of life in America's neighborhoods.
7 Working together with our member organizations, we strive to 8 improve the economic, social, environment, health and safety 9 conditions in neighborhoods.
10 The National Association of Neighborhoods is here 11 today supporting the of Indian Point Energy Center because the 12 center generates reliable, affordable and clean electric power.
13 We are not experts in the generation, transmission and 14 distribution of electricity. However, our members are expert 15 electric rate payers. Business and residential consumers of 16 electric power. People in homes and small businesses across the 17 state are plugging more and more electric devices into outlets 26-a-EC/
LR 18 to the point where it is hard to find a home or small business 19 that is not running out of outlets. And if the United States 20 Congress has its way, sooner then later, we will all be plugging 21 in every new car and truck into the outlets outside our homes.
22 The decision that will be made regarding the Indian Point Energy 23 Center has huge economic and social consequences for all of New 24 York's neighborhoods and businesses. Because of our interest in NUREG-1437, Supplement 38 A-256 December 2010
Appendix A 1 climate change and energy issues, it was important that our 26-a-EC/
2 Association see a nuclear plant up close and we chose Indian LR contd.
3 Point.
4 We also brought together six national Black 5 associations of grassroot advocates, print media and elected 6 officials to tour Indian Point Center. The purpose of the tour 7 was to see a plant in operation and talk with the operators.
8 What we saw was a well-maintained facility and an operational 26-b-OP 9 team that was focused on their duties and responsibilities in 10 generating power with strict security and safety protocols. In 11 our candid discussions with plant managers, they admitted to 12 having some issues and they were working to improve them. Never 13 being satisfied that they had done enough.
14 I am certain that there are people here today that are 15 advocates for shutting down all nuclear power plants, but the 16 question we must ask in making that decision is, if IPEC was 17 shut down, what would be the consequences? None of us can be 18 certain, however, of what will happen. According to a study 26-c-EC/
19 published by the Westchester Business Council, within five years SO/SR 20 electrical cost would raise annually by $1500 for the average 21 Westchester resident and $10,000 for the average Westchester 22 small business. These price spikes would be even more dramatic 23 in New York City where electric prices are higher. In closing, 24 Barak Obama has stated in working with the United States December 2010 A-257 NUREG-1437, Supplement 38
Appendix A 1 Congress words that apply to this important decision. Do not 2 let the perfect become the enemy of the good. Closing IPEC has 3 the potential to disproportionately affect the economic and 26-c-EC/
4 social health of New York. On behalf of our membership and the SO/SR contd.
5 residents of neighborhoods in New York and across the country, 6 the National Association of Neighborhoods urges the Nuclear 7 Regulatory Commission to renew the IPEC license.
8 9
NUREG-1437, Supplement 38 A-258 December 2010
Appendix A 1
2 3
27-a-OR 27-b-AE 27-c-AE 27-d-LE 27-e-SF/ST 27-f-OR December 2010 A-259 NUREG-1437, Supplement 38
Appendix A 1 MS. CAMPBELL: Good afternoon. My name is Joanne 2 Campbell and I am vice-president of Albany Houses Tenants 3 Association in Brooklyn. On behalf of Tenants Association and 4 residents of public housing throughout the borough, I would like 5 to testify today in support of the Indian Point Energy Center. 28-a-EC/SR 6 Re-licensing the Indian Point Energy Center is the right move 7 for Brooklyns public housing families. New York currently has 8 the second-highest energy prices in the nation and in order to 9 secure a future where energy prices are stable and affordable, 10 Indian Point must remain open and operational.
11 Independent studies show that closing Indian Point 12 could increase energy bills for families by thousands of dollars 13 a year. At this time of economic uncertainty or, now is not the 14 time to force already struggling families to pay more just to 15 turn the lights on. Although I electricity bills are often 16 included with the rent we pay, make no mistake about it, the 17 families I represent at Albany Houses feel the painful sting of 28-b-EC/
SO 18 increased energy prices throughout our community.
19 The prices families in my neighborhood pay for the 20 milk, corn and other groceries are a direct result of higher 21 energy costs. High energy prices are also felt by those families 22 who rely on New York City's mass transit system because subways 23 and bus fares are similarly increased to keep the pace New York 24 City public housing set last year that if prices continue to NUREG-1437, Supplement 38 A-260 December 2010
Appendix A 1 rise that they will be forced to raise rents and eliminate 2 hundreds of community and senior centers in my neighborhood 3 needed to survive. Excuse me y'all. There are too many 4 families in my neighborhood that live below the federal poverty 5 line, and it is those families and countless others who are just 6 getting by who cannot withstand even the slightest increase in 7 our electric bills.
8 As the economy threatens to plunge my community into 9 further peril, the voice and concerns of low income Brooklyn 28-b-EC/
10 must be heard in this debate. Tenants Associations and public SO contd.
11 housing families in Brooklyn stand together in the belief that 12 New York's clean energy future must be affordable for all. The 13 crucial first step for towards securing a affordable energy 14 future is to re-license Indian Point so it can remain open an 15 additional 20 years. Thank you for allowing me to add the 16 concerns of the Brooklyn Tenant Association to this debate. I 17 hope we will be able to reach a decision that keeps Indian Point 18 open.
19 20 21 December 2010 A-261 NUREG-1437, Supplement 38
Appendix A 1 MR. CAPURSO: Hello, my name is Tom Capurso. I'm a 2 business representative with Local 3 here in New York. I'd like 3 to thank the NRC for having this opportunity to come here and 4 stand in favor of the re-licensing of Indian Point. Indian 29-a-SO/
5 Point provides a lot of good paying construction jobs as well as SR 6 good paying jobs for the people who work in plant and daily day-7 to-day. To close the plant would decimate the economy of the 8 local area. On a personal note, I'm a Peekskill resident, I 9 moved to Peekskill over five years ago with my wife and two 10 children. The fact of having a nuclear power plant in a close 29-b-OP 11 proximity to where we live did not stop us from making a 12 decision of coming to the area. We feel it's safe. We don't 13 lie in bed at night with our eyes open.
14 If youve taken a look at your heating bill this 15 winter, to close down Indian Point, the electric portion of that 16 bill would probably do the same thing and double. I'm just 17 speaking personally for my heating bill. And your gas in your 18 car. If you remember this past summer when the price of 19 gasoline doubled, you close the Indian Point your price of 29-c-EC/
SA 20 electricity in this area is going to double. In those are all 21 things we need to consider. It's a safe environment there. A 22 lot of people have never been there. I've been inside the 23 plant. I've been inside the containment building. There are a 24 lot of steps you have to go through to get in there. It's not NUREG-1437, Supplement 38 A-262 December 2010
Appendix A 1 like someone is going to walk in off the street and fool around.
29-c-EC/
2 So it is safe, and it is vital. We need to have this plant here SA contd.
3 because we do need the clean electricity. Thank you.
4 5
6 December 2010 A-263 NUREG-1437, Supplement 38
Appendix A 1
2 NUREG-1437, Supplement 38 A-264 December 2010
Appendix A 1
2 3
30-a-AL/AQ/AS/
EJ/GE December 2010 A-265 NUREG-1437, Supplement 38
Appendix A 1 MS. CASTRO: Good evening. My name is Maria Castro and I'm the 2 founding member of the Hispanic Energy Coalition. On behalf of 3 the Latino business and civic organizations, excuse me, 4 including the Manhattan Hispanic Chamber of Commerce and The 5 League of United Latino American Citizens, I'm here this evening 31-a-EJ/
6 in support of the continued operation of Indian Point. Indian SR 7 Point provides the clean and affordable electricity that homes 8 and businesses, schools and hospitals in New York City rely on.
9 Keeping Indian Point open means that families in the working-10 class and the low-income neighborhoods represented by the 11 Hispanic Energy Coalition will not be held hostage to rapidly 12 increasing electricity bills. In this age of global warming, 13 and open an operational Indian Point also means were holding 14 true to our promise in fighting climate change by reducing 15 greenhouse gases. The Latino community has been especially 16 vulnerable to poor environmental decisions in the pass. We live 17 daily with the health risks associated with poor air quality and 31-b-EC/
EJ/HH 18 sky-high energy bills that impact the price of everything from 19 gas to groceries. Hispanic Energy Coalition was formed to 20 galvanize and organize the Latino community to ensure that no 21 further poor environmental decisions are made for our community, 22 but are rather made by our community.
23 Like a growing number of Americans, including our 31-c-AQ/
SR 24 newly elected President Barack Obama, the Hispanic Energy NUREG-1437, Supplement 38 A-266 December 2010
Appendix A 1 Coalition has embraced nuclear power as a vital part of our 2 overall clean energy mix and proven to reduce carbon emissions.
3 A safe and secure facility like Indian Point is key to our 4 regions environmental and economic health. As increasing 5 numbers of New Yorkers begin to fully grasp the many 6 environmental, health and economic benefits Indian Point 31-c-AQ/
SR 7 provides, the more will join our call for it to remain open and contd.
8 operational. Thank you for allowing me the opportunity to place 9 the concerns of the Hispanic Energy Coalition and the families 10 and businesses that we represent into this debate. It is our 11 hope that any decision reached ensures a continued supply of 12 reliable, clean and affordable electricity for all New Yorkers.
13 Thank you.
14 15 16 December 2010 A-267 NUREG-1437, Supplement 38
Appendix A 1
2 3
32-a-AM/OP/
PA NUREG-1437, Supplement 38 A-268 December 2010
Appendix A 1
2 3
33-a-AE/GL/
LE December 2010 A-269 NUREG-1437, Supplement 38
Appendix A 1 MR. CLEGG: To start off with, my name is Thomas Clegg.
2 I live in Windsor, New York. Grew up in God's country, 3 Brooklyn, New York. I worked at Indian Point. I've worked 4 there for 25 years. I am a nuclear mechanic. I fix things that 5 operators break. I've come here to give you a few numbers.
6 Those who think that wind power can replace Indian Point should 7 really look into their facts. Denmark is your leading producer 8 of wind. It's about the size of Massachusetts and a half. They 34-a-AL/EC 9 have a 3 million population. They have 5,500 windmills that 10 produce approximately 16% of their electric. 5,500 windmills 11 can only make up 16% of their electric. It is never going to 12 replace Indian Point. To close Indian Point with numbers, 13 you'll need to have 80,000 barrels of oil a day to replace 14 Indian point or 18,000 tons of coal. We use about 30 pounds of 15 uranium a day. So where all that tremendous waste is, is 30 16 pounds of uranium a day. Nothing. Now, I'd like to ask you one 17 more fact. There are 16 nuclear power plants on Lake Ontario.
18 As anybody who's lived in New York State knows, Lake Ontario is 19 one of the best fishing places in New York State. Out of the 16 20 nuclear power plants, only one of them has a cooling tower. So, 34-b-AL/EC 21 I would like to know how two nuclear power plants on the Hudson 22 River can effect the fish population worse than 15 nuclear power 23 plants on Lake Ontario. In closing, I like to disagree with the 24 NRC. We have a large impact on the environment at Indian Point.
NUREG-1437, Supplement 38 A-270 December 2010
Appendix A 1 Do you want to see them disappear? We saved the polar bears.
34-b-AL/EC 2 Don't let your grandchildren grow up saying what was a polar contd.
3 bear? Thank you very much everyone.
December 2010 A-271 NUREG-1437, Supplement 38
Appendix A 1
2 3
35-a-LE/OM 35-b-EP 35-c-AM/RW 35-d-OR 35-e-OR/RE NUREG-1437, Supplement 38 A-272 December 2010
Appendix A 1 MR. CONNOLLY: Good evening. My name is Jerry 2 Connolly. I am the spokesperson for the Coalition of Labor for 3 Energy and Jobs. I served as business manager of Boilermakers 4 Local-5 from July 1999 to December 2007. My first job at Indian 5 Point was during the summer of 1968. I worked on every major 6 pressure part system in both Units 2 and 3 and worked on the 7 failed attempt to rehabilitate Unit 1 in the 1970s. I have come 8 here tonight as a representative of a coalition of unions who 36-a-SR 9 support the re-licensing of these important assets. Indian Point 10 and the 2000 Mw it produces are vital to the economy of the 11 downstate region and it produces no greenhouse gases. Since 12 Entergy has possessed Indian Point, we have seen significant 13 investments made to improve safety and liability. Is there more 14 that should be done to ensure health and safety of the public?
15 Of course there is. That is the reason why we are here today.
16 As important as Indian Point is economically, it is paramount 17 that the safety of the plant is first on the list of priorities.
36-b-OP 18 We in the Coalition of Labor for Energy and Jobs urge the NRC to 19 review all the facts carefully and with due diligence for the 20 confidence of the public is at stake. Any outstanding safety or 21 operational issues must be addressed to give assurance to the 22 public that the plant is operating in a safe manner. The 23 Coalition feels that Entergy has the resources and qualified 24 personnel to address any presently unresolved issues. The local December 2010 A-273 NUREG-1437, Supplement 38
Appendix A 1 building trades have nuclear qualified tradesmen to be used as 36-b-OP 2 needed, particularly during scheduled maintenance outages. contd.
3 Contrary to what some organizations have placed on 4 their web sites, the trades have many members who, like myself, 5 have worked at these facilities since they were owned by 6 ConEdison and the Power Authority. Each trade has training 7 programs to prepare them for working in the nuclear environment. 36-c-AL/
AQ/EC 8 Many tradesmen's spend a majority of their working careers, 9 working within nuclear facilities. Not only Indian Point, many 10 of them travel upstate New York and work up around Oswego in the 11 plants. Some of them even go out of state. Some local and 12 national politicians are here today or sent representatives to 13 oppose the re-licensing of the plant. If the NRC finds safety 14 issues that cannot be resolved, I hope these officials will 15 realize their responsibility in identifying 2000 Mw of 16 immediately available base-load power. I hope they are ready to 17 listen to their constituents who when the price of electricity 36-d-OP/
18 soars will scream bloody murder. New York State presently has SO 19 no expedited method or procedure to site new base-load 20 generating facilities of the magnitude of replacing Indian 21 Point. I guess we could put up approximately (700) 3 Mw wind 22 turbines as some suggest.
23 But to meet Indian Points output, they might be 24 required to run at full capacity for as many as 600 days at a NUREG-1437, Supplement 38 A-274 December 2010
Appendix A 1 clip and thats at its 7/24 supply level. It would be 2 interesting to see them strung along the Palisades or stretching 3 over Bear Mountain and up to Storm King. Unfortunately, wind is 36-d-OP/
4 an intermittent source and could never replace the nuclear SO contd.
5 facility megawatt for megawatt, hour production for hour 6 production. The only real base-load option is more fossil fuel 7 plants, which translates into increased air pollution. In 8 closing, I would like to add that we believe the NRC has the 9 people and expertise to make a sound decision about the future 10 of Indian Point. We believe the facility can be operated in a 11 safe and secure manner. Entergy's making the right investments 12 to meet requirements for operation. As we speak, a scheduled 13 maintenance outage is beginning with the employer employing many 36-e-OP/
SO 14 local tradesmen at a time when jobs are badly needed. The work 15 they will perform will improve safety and reliability of this 16 facility. We urge that you, the NRC, be thorough and listen to 17 the concerns of all here present tonight and all the remarks 18 that you receive. I thank you very much for the opportunity to 19 address this group. I wish you good luck in coming to a 20 successful conclusion.
21 22 23 December 2010 A-275 NUREG-1437, Supplement 38
Appendix A 1
2 3
37-a-AE/OR 37-b-LE/SF/
ST NUREG-1437, Supplement 38 A-276 December 2010
Appendix A 1 MS. CYPSER: This afternoon, we represent the Raging 2 Grannies and their friends of Westchester, New York. The Raging 3 Grannies are in international protest group that works for 4 peace, the environment, social and economic justice. We work to 5 make the world a better place for all the grandchildren and 6 their grandchildren. We express our thoughts on issues through 7 new lyrics to old familiar tunes.
8 Many people in this country say that nuclear energy is 9 safe enough and green enough, but what does the rest of the 10 world say? What do they say when representatives from all of 38-a-ON 11 the countries of the world gather and discuss all the facets of 12 the issue? They refused to give nuclear energy greenhouse gas 13 credits at the U.N. Climate Change in the Hague in November 14 2000. They refused to label nuclear energy a sustainable 15 technology at the U.N. Sustainable Development Conference in 16 April 2001. We support replacing Indian Point with solar 17 generated by private residences and businesses. New York State 18 allows us to run our electric meters backwards. Europe is 19 moving ahead with sustainable energy and we can too.
20 21 December 2010 A-277 NUREG-1437, Supplement 38
Appendix A 1
2 3
4 5
6 7
8 9
10 11 12 38-b-PA/RW/
ST 38-c-RW/SF/
ST 38-d-AL 38-e-RW/SF NUREG-1437, Supplement 38 A-278 December 2010
Appendix A 1
2 38-f-RW/SF 38-g-RW 38-h-ST 38-i-RW December 2010 A-279 NUREG-1437, Supplement 38
Appendix A 1 MR. CYPSER: No problem. Hello everybody. I've been 2 in this kind of study business for all of my life. I'm 85 years 3 old. Former doctor and scientist at MIT. So, I have a real 4 interest in seeing that this is done right. I have a great 5 sympathy for the people who are concerned about their jobs. A 6 great sympathy for the people who have asthma. But I think as 39-a-RW/
7 we go down an important road like this, we need to know what SF 8 we're doing. We can't close our eyes to facts. We can't ignore 9 areas that are very, very important, very, very significant.
10 We're tending to look at today's benefits. Were tending not to 11 look at tomorrow's costs. I'd like to ask that we not go 12 forward until we look at all the costs. There are three 13 particular areas that are particularly troublesome.
14 First, we've heard quite about them already. First is 15 the spent fuel. This waste is going to last hundreds or 16 thousands of years. What is the cost of maintaining that 17 surveillance? What is the possible cost of leakage over the 18 next 150, 200, 1000 years? What are the costs involved? Or 39-b-LE 19 more specifically now, what do we have to do to expend money now 20 to reduce the probability of high-costs down the road of a 100 21 years or a 1000 years? What are the costs we have to invest to 22 make ourselves sufficiently safe over that longtime period?
23 Second subject is the leakage. We've heard again and 39-c-PA/
ST 24 again there is leakage. Mother's milk is being contaminated.
NUREG-1437, Supplement 38 A-280 December 2010
Appendix A 1 Strontium-90 is going out. Cancer is being caused. What is the 2 cost of cancer due to this leakage over the next period of time, 3 5 years, 10 years?
4 How many people will die? What number of deaths are we willing 39-c-PA/
ST 5 to tolerate? What is the long-term cost of that leakage? Then contd.
6 specifically, what do we have to expend today to reduce the 7 probability of that cost escalating in the future? What are the 8 costs? What are the total cost?
9 The third element is even more difficult. We are 10 subject to mistakes. We are subject to maliciousness. We are 11 subject to terrorism. All of these things will happen to some 12 degree. We can't close our eyes the fact that a catastrophe is 13 impossible. We can't pretend that. We've got to say, it is 14 possible. Now, we've done many things to prevent it. Have we 15 done enough? What additional costs do we have to expend in 16 order to reduce that to a tolerable level? Is it tolerable the 39-d-PA/
ST 17 way it is now or is the possibility there because the 18 catastrophe is so horrendous? Granted the probability of small 19 but if the consequences are so horrendous, weve got to invest 20 more and more to reduce the probability still smaller. So, 21 total costs is the answer. What are the total costs on these 22 three items at least? Look at the total cost today. Look at 23 the projected total cost over the time period of the 24 consequences of our decision today. Thank you.
December 2010 A-281 NUREG-1437, Supplement 38
Appendix A 1 MR. DACIMO: Good evening. My name is Fred Dacimo. I'm vice-2 president for License Renewal at Entergy. Formerly site vice-3 president. I've worked at Indian Point for over 10 years as 4 well as being a resident of the general area. I'm going to 5 submit my comments to you this evening in writing as soon as I'm 6 complete here. First place, I'd like to think the NRC for all 7 the hard work they did in preparing the DSEIS for Indian Point.
8 Entergy agrees with the staff's overall preliminary 9 recommendation in the DSEIS. I'm not going to quote the 10 conclusion, but, in other words, if you look at it, it really 11 says, there is no reason from an environmental perspective not 40-a-SR 12 to proceed with the license renewal process. In fact, we 13 believe license renewal will not result in significant 14 environmental impacts. The DSEIS recognizes plant operations 15 result in only small impacts in the areas that you indicated in 16 your slides, and I won't repeat those. But that is a very 17 significant cross-section of the DSEIS.
18 I want to focus on those areas that we disagree with.
19 We do disagree with some of the underlying analysis in the DSEIS 20 regarding some portions of impingement and entrainment. Thermal 21 shock and the analysis that was used. And the mitigation 40-b-AE 22 alternatives involving closed-cycle cooling. We will submit our 23 comments in writing to the NRC by the due date. In the area of 24 impingement and entrainment, we at Entergy, and our NUREG-1437, Supplement 38 A-282 December 2010
Appendix A 1 predecessors, which actually included the State of New York as a 2 former owner of the plant, have been collecting Hudson River 3 fish data for greater than 30 years. These studies have been 4 approved, directed and overseen by the New York State DEC. The 5 New York State DEC has testified that this data is quote unquote 40-b-AE contd.
6 probably the best data set on the planet. With two other 7 owners, we have spent more than $50 million on fish studies.
8 While we commanded the NRC for their review of what was really a 9 voluminous amount of data, we believe that some of the 10 conclusions are in error. Let me give you an example.
11 The conclusion on bluefish is one. In Chapter 4 of 12 the DSEIS, it concludes that impingement and entrainment may 13 have a very large impact on bluefish. The DSEIS does not 14 reflect the fact that the New York State DEC, which is charged 15 with overseeing bluefish, has not identified a concerned with 16 bluefish. And has not identified a concerned with bluefish vis-17 a-vie Indian Point plant operations. As a matter of fact, in 40-c-AE 18 Chapter 2, it's acknowledged and I'll quote this, bluefish have 19 not been found in entrainment from power plants along the Hudson 20 River including Roseton 1 and 2, Bowline 1 and 2, Indian Point 2 21 and 3. Juvenile bluefish may be impinged, but the numbers are 22 relatively small unquote. So the DSEIS offers no credible 23 scientific basis for a large impact finding. So we believe, 24 that the FEIS should list this area as small.
December 2010 A-283 NUREG-1437, Supplement 38
Appendix A 1 Little credit has also been given to for the greater 2 than $100 million in today's dollars for retrofits to the plant 3 including variable and dual-speed pumps, state-of-the-art fish 4 screen systems, fish return systems. Based on the success of 40-d-AE 5 those systems, the New York State DEC staff eliminated 6 impingement monitoring. We all learned that monitoring was much 7 more harmful than the benefit gained from monitoring and for 8 this and other reasons, impingement should be classified in the 9 final EIS as small. In the area of thermal impacts, the DSEIS 10 states small to moderate based on a model that has flows and 11 temperatures that simply cannot exist in nature. We'll expound 40-e-AE 12 on that in our comments to you, but we feel that that also 13 should be reclassified as small.
14 In regard to mitigation alternatives, the DSEIS 15 treatment of this area is flawed. We will amplify our position 16 in writing. Simply put, the New York State DEC has determined 17 that closed-cycle cooling is either feasible or the best 18 alternative for Indian Point. We actually have until December 19 of `09 to submit a report on the technical feasibility. The DEC 40-f-AE 20 assessment of closed-cycle cooling impacts on the electric 21 system reflects incorrect assumptions. These assumptions are 22 contrary to the findings of the New York State Independent 23 System Operator. And contrary to the 2006 independent 24 evaluation conducted by the National Academy of Sciences.
NUREG-1437, Supplement 38 A-284 December 2010
Appendix A 1 Let me give you this quote before I wrap up. Indian 2 Point is a critical component of both reliability and economics 3 of power for this area, for the New York City area. So 40-g-EC 4 obviously, were going to ask you to reclassify that too. I 5 want to thank you for the opportunity to share our perspective.
6 We will be submitting our detailed comments to you by March 7 18th. Thank you.
8 9
December 2010 A-285 NUREG-1437, Supplement 38
Appendix A 1
2 3
40-h-SR NUREG-1437, Supplement 38 A-286 December 2010
Appendix A 1
40-i-OS 40-j-AE/AL December 2010 A-287 NUREG-1437, Supplement 38
Appendix A 1
40-j-AE/AL contd.
NUREG-1437, Supplement 38 A-288 December 2010
Appendix A 1
December 2010 A-289 NUREG-1437, Supplement 38
Appendix A 1
2 3
NUREG-1437, Supplement 38 A-290 December 2010
Appendix A 1
December 2010 A-291 NUREG-1437, Supplement 38
Appendix A 40-k-AE 40-l-ED 40-m-ED 40-n-AE/ED 40-o-ED/RG 1
NUREG-1437, Supplement 38 A-292 December 2010
Appendix A 1
40-o-ED/RG contd.
40-p-AE 40-q-AE/OE December 2010 A-293 NUREG-1437, Supplement 38
Appendix A 1
40-q-AE/OE contd 40-r-AE/OE 40-s-AE/OE NUREG-1437, Supplement 38 A-294 December 2010
Appendix A 1
2 3
4 40-t-AE/ED 40-u-ED/TS 40-v-AL/TS 40-x-AE/ED 40-x-ED December 2010 A-295 NUREG-1437, Supplement 38
Appendix A 1
40-x-ED contd.
40-y-AE 40-z-AE 40-aa-ED 40-bb-AE/ED NUREG-1437, Supplement 38 A-296 December 2010
Appendix A 1
2 3
4 5
6 7
8 9
10 11 40-bb-AE/ED contd.
December 2010 A-297 NUREG-1437, Supplement 38
Appendix A 1
40-cc-AE/ED 40-dd-AE/AL NUREG-1437, Supplement 38 A-298 December 2010
Appendix A 1
40-ee-AE/OE 40-ff-AE/ED 40-gg-AE December 2010 A-299 NUREG-1437, Supplement 38
Appendix A 1
40-gg-AE contd.
40-hh-AE/OE 40-ii-AE/AL/TS NUREG-1437, Supplement 38 A-300 December 2010
Appendix A 1
40-jj-AE 40-kk-AE/ED 40-ll-AE December 2010 A-301 NUREG-1437, Supplement 38
Appendix A 1
40-ll-AE contd.
40-mm-AE/ED 40-nn-AE NUREG-1437, Supplement 38 A-302 December 2010
Appendix A 1
40-oo-AE 40-pp-AL 40-qq-AE/ED 40-rr-AE/ED/TL December 2010 A-303 NUREG-1437, Supplement 38
Appendix A 1
40-rr-AE/ED/TL contd.
40-ss-ED 40-tt-AE NUREG-1437, Supplement 38 A-304 December 2010
Appendix A 1
40-uu-AE 40-vv-ED 40-ww-ED/SM December 2010 A-305 NUREG-1437, Supplement 38
Appendix A 1
40-ww-ED/SM contd.
40-xx-AL/AQ 40-yy-ED NUREG-1437, Supplement 38 A-306 December 2010
Appendix A 1
40-zz-AL December 2010 A-307 NUREG-1437, Supplement 38
Appendix A 1
2 3
40-zz-AL contd.
NUREG-1437, Supplement 38 A-308 December 2010
Appendix A 1
40-aaa-AE/AL December 2010 A-309 NUREG-1437, Supplement 38
Appendix A 1
40-bbb-AL NUREG-1437, Supplement 38 A-310 December 2010
Appendix A 1
40-bbb-AL contd.
40-ccc-AL/TE December 2010 A-311 NUREG-1437, Supplement 38
Appendix A 1
40-ddd-AL/TS 40-eee-AL/AQ NUREG-1437, Supplement 38 A-312 December 2010
Appendix A 1
40-fff-AL/AQ 40-ggg-AL December 2010 A-313 NUREG-1437, Supplement 38
Appendix A 1
40-ggg-AL contd.
NUREG-1437, Supplement 38 A-314 December 2010
Appendix A 1
40-ggg-AL contd.
40-hhh-AL/ED December 2010 A-315 NUREG-1437, Supplement 38
Appendix A 1
40-hhh-AL/ED contd.
40-iii-ED NUREG-1437, Supplement 38 A-316 December 2010
Appendix A 1
40-iii-ED contd.
December 2010 A-317 NUREG-1437, Supplement 38
Appendix A 1
40-iii-ED contd.
40-jjj-AE 40-kkk-AL 40-lll-ED/SM NUREG-1437, Supplement 38 A-318 December 2010
Appendix A 1
40-lll-ED/SM contd.
December 2010 A-319 NUREG-1437, Supplement 38
Appendix A 1
40-mmm-AE NUREG-1437, Supplement 38 A-320 December 2010
Appendix A 1
40-mmm-AE contd.
December 2010 A-321 NUREG-1437, Supplement 38
Appendix A 1
40-mmm-AE contd.
NUREG-1437, Supplement 38 A-322 December 2010
Appendix A 1
40-mmm-AE contd.
December 2010 A-323 NUREG-1437, Supplement 38
Appendix A 1
40-mmm-AE contd.
40-nnn-AE 40-ooo-AE/ED NUREG-1437, Supplement 38 A-324 December 2010
Appendix A 1
40-ooo-AE/ED contd.
40-ppp-AE/CE December 2010 A-325 NUREG-1437, Supplement 38
Appendix A 1
40-ppp-AE/CE contd.
NUREG-1437, Supplement 38 A-326 December 2010
Appendix A 1
December 2010 A-327 NUREG-1437, Supplement 38
Appendix A 1
40-qqq-ED NUREG-1437, Supplement 38 A-328 December 2010
Appendix A 1
40-qqq-ED contd.
December 2010 A-329 NUREG-1437, Supplement 38
Appendix A 1
40-qqq-ED contd.
NUREG-1437, Supplement 38 A-330 December 2010
Appendix A 1
40-qqq-ED contd.
December 2010 A-331 NUREG-1437, Supplement 38
Appendix A 1
40-qqq-ED contd.
NUREG-1437, Supplement 38 A-332 December 2010
Appendix A 1
40-qqq-ED contd.
December 2010 A-333 NUREG-1437, Supplement 38
Appendix A 1
40-qqq-ED contd.
NUREG-1437, Supplement 38 A-334 December 2010
Appendix A 1
40-qqq-ED contd.
December 2010 A-335 NUREG-1437, Supplement 38
Appendix A 1
40-qqq-ED contd.
NUREG-1437, Supplement 38 A-336 December 2010
Appendix A 1
40-qqq-ED contd.
December 2010 A-337 NUREG-1437, Supplement 38
Appendix A 1
40-qqq-ED contd.
NUREG-1437, Supplement 38 A-338 December 2010
Appendix A 1
December 2010 A-339 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-340 December 2010
Appendix A 40-rrr-AL 1
December 2010 A-341 NUREG-1437, Supplement 38
Appendix A 40-rrr-AL contd.
1 NUREG-1437, Supplement 38 A-342 December 2010
Appendix A 40-rrr-AL contd.
1 December 2010 A-343 NUREG-1437, Supplement 38
Appendix A 40-rrr-AL contd.
40-sss-AL 1
NUREG-1437, Supplement 38 A-344 December 2010
Appendix A 40-sss-AL contd.
1 December 2010 A-345 NUREG-1437, Supplement 38
Appendix A 40-sss-AL contd.
1 NUREG-1437, Supplement 38 A-346 December 2010
Appendix A 40-sss-AL contd.
40-ttt-AE 1
December 2010 A-347 NUREG-1437, Supplement 38
Appendix A 40-uuu-AE 40-vvv-AE 40-www-AL 1
NUREG-1437, Supplement 38 A-348 December 2010
Appendix A 40-www-AL contd.
40-xxx-AE/ED 40-yyy-AE 1
December 2010 A-349 NUREG-1437, Supplement 38
Appendix A 40-yyy-AE contd.
40-zzz-AE 40-aaaa-TS 1
NUREG-1437, Supplement 38 A-350 December 2010
Appendix A 40-aaaa-TS contd.
40-bbbb-TS 1
December 2010 A-351 NUREG-1437, Supplement 38
Appendix A 40-cccc-TS 40-dddd-TS 1
NUREG-1437, Supplement 38 A-352 December 2010
Appendix A 40-dddd-TS contd.
40-eeee-AE 40-ffff-AE 1
December 2010 A-353 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-354 December 2010
Appendix A 1
December 2010 A-355 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-356 December 2010
Appendix A 1
2 December 2010 A-357 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-358 December 2010
Appendix A 1
December 2010 A-359 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-360 December 2010
Appendix A 1
December 2010 A-361 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-362 December 2010
Appendix A 1
December 2010 A-363 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-364 December 2010
Appendix A 1
December 2010 A-365 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-366 December 2010
Appendix A 40-gggg-AL 1
December 2010 A-367 NUREG-1437, Supplement 38
Appendix A 40-gggg-AL contd.
1 2
NUREG-1437, Supplement 38 A-368 December 2010
Appendix A 40-gggg-AL contd.
1 December 2010 A-369 NUREG-1437, Supplement 38
Appendix A 40-hhhh-AL 1
NUREG-1437, Supplement 38 A-370 December 2010
Appendix A 40-hhhh-AL contd.
1 December 2010 A-371 NUREG-1437, Supplement 38
Appendix A 40-hhhh-AL contd.
1 NUREG-1437, Supplement 38 A-372 December 2010
Appendix A 40-hhhh-AL contd.
1 December 2010 A-373 NUREG-1437, Supplement 38
Appendix A 40-iiii-AL 1
NUREG-1437, Supplement 38 A-374 December 2010
Appendix A 40-iiii-AL contd.
1 December 2010 A-375 NUREG-1437, Supplement 38
Appendix A 40-iiii-AL contd.
1 NUREG-1437, Supplement 38 A-376 December 2010
Appendix A 40-jjjj-AL 1
December 2010 A-377 NUREG-1437, Supplement 38
Appendix A 40-jjjj-AL contd.
1 NUREG-1437, Supplement 38 A-378 December 2010
Appendix A 40-jjjj-AL contd.
1 December 2010 A-379 NUREG-1437, Supplement 38
Appendix A 40-jjjj-AL contd.
1 NUREG-1437, Supplement 38 A-380 December 2010
Appendix A 40-jjjj-AL contd.
1 December 2010 A-381 NUREG-1437, Supplement 38
Appendix A 40-kkkk-AL 1
NUREG-1437, Supplement 38 A-382 December 2010
Appendix A 40-kkkk-AL contd.
1 December 2010 A-383 NUREG-1437, Supplement 38
Appendix A 40-llll-AL 1
NUREG-1437, Supplement 38 A-384 December 2010
Appendix A 40-llll-AL contd.
1 December 2010 A-385 NUREG-1437, Supplement 38
Appendix A 40-llll-AL contd.
1 NUREG-1437, Supplement 38 A-386 December 2010
Appendix A 40-mmmm-AL 1
December 2010 A-387 NUREG-1437, Supplement 38
Appendix A 40-mmmm-AL contd.
1 NUREG-1437, Supplement 38 A-388 December 2010
Appendix A 40-mmmm-AL contd.
1 December 2010 A-389 NUREG-1437, Supplement 38
Appendix A 40-nnnn-AL 1
2 3
NUREG-1437, Supplement 38 A-390 December 2010
Appendix A 40-nnnn-AL contd.
1 December 2010 A-391 NUREG-1437, Supplement 38
Appendix A 40-nnnn-AL contd.
1 NUREG-1437, Supplement 38 A-392 December 2010
Appendix A 1
2 December 2010 A-393 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-394 December 2010
Appendix A 1
December 2010 A-395 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-396 December 2010
Appendix A 1
December 2010 A-397 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-398 December 2010
Appendix A 1
December 2010 A-399 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-400 December 2010
Appendix A 1
2 December 2010 A-401 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-402 December 2010
Appendix A 1
December 2010 A-403 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-404 December 2010
Appendix A 1
2 3
December 2010 A-405 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-406 December 2010
Appendix A 1
December 2010 A-407 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-408 December 2010
Appendix A 1
December 2010 A-409 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-410 December 2010
Appendix A 1
December 2010 A-411 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-412 December 2010
Appendix A 1
December 2010 A-413 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-414 December 2010
Appendix A 1
December 2010 A-415 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-416 December 2010
Appendix A 1
2 December 2010 A-417 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-418 December 2010
Appendix A 1
2 December 2010 A-419 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-420 December 2010
Appendix A 1
December 2010 A-421 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-422 December 2010
Appendix A 1
December 2010 A-423 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-424 December 2010
Appendix A 1
December 2010 A-425 NUREG-1437, Supplement 38
Appendix A 1
NUREG-1437, Supplement 38 A-426 December 2010
Appendix A 1
December 2010 A-427 NUREG-1437, Supplement 38
Appendix A 40-oooo-AL 1
NUREG-1437, Supplement 38 A-428 December 2010
Appendix A 40-oooo-AL contd.
1 December 2010 A-429 NUREG-1437, Supplement 38
Appendix A 40-oooo-AL contd.
1 NUREG-1437, Supplement 38 A-430 December 2010
Appendix A 40-oooo-AL contd.
1 December 2010 A-431 NUREG-1437, Supplement 38
Appendix A 40-oooo-AL contd.
1 NUREG-1437, Supplement 38 A-432 December 2010
Appendix A 40-oooo-AL contd.
1 December 2010 A-433 NUREG-1437, Supplement 38
Appendix A 40-oooo-AL contd.
1 NUREG-1437, Supplement 38 A-434 December 2010
Appendix A 40-pppp-AL 1
December 2010 A-435 NUREG-1437, Supplement 38
Appendix A 40-pppp-AL contd.
1 NUREG-1437, Supplement 38 A-436 December 2010
Appendix A 40-pppp-AL contd.
1 December 2010 A-437 NUREG-1437, Supplement 38
Appendix A 40-pppp-AL contd.
1 NUREG-1437, Supplement 38 A-438 December 2010
Appendix A 40-pppp-AL contd.
1 December 2010 A-439 NUREG-1437, Supplement 38
Appendix A 40-pppp-AL contd.
1 NUREG-1437, Supplement 38 A-440 December 2010
Appendix A 40-pppp-AL contd.
1 2
3 December 2010 A-441 NUREG-1437, Supplement 38
Appendix A 1
40-qqqq-AE 2
3 NUREG-1437, Supplement 38 A-442 December 2010
Appendix A 40-qqqq-AE contd.
1 2
3 December 2010 A-443 NUREG-1437, Supplement 38
Appendix A 40-qqqq-AE contd.
1 2
NUREG-1437, Supplement 38 A-444 December 2010
Appendix A 40-qqqq-AE contd.
1 2
December 2010 A-445 NUREG-1437, Supplement 38
Appendix A 40-qqqq-AE contd.
1 NUREG-1437, Supplement 38 A-446 December 2010
Appendix A 40-qqqq-AE contd.
1 2
December 2010 A-447 NUREG-1437, Supplement 38
Appendix A 40-qqqq-AE contd.
1 NUREG-1437, Supplement 38 A-448 December 2010
Appendix A 1
December 2010 A-449 NUREG-1437, Supplement 38
Appendix A 1
2 3
NUREG-1437, Supplement 38 A-450 December 2010
Appendix A 1
2 3
December 2010 A-451 NUREG-1437, Supplement 38
Appendix A 1
2 3
NUREG-1437, Supplement 38 A-452 December 2010
Appendix A 1
2 December 2010 A-453 NUREG-1437, Supplement 38