ML11262A324

E-mail with Attachment from D. Logan, NRR, to S. Duda, Aecom, on Salem Hope Creek Comments and Edits on Chapter 4 Selections

ML11262A324
Person / Time
Site:	Salem, Hope Creek
Issue date:	07/30/2010
From:	Logan D Office of Nuclear Reactor Regulation
To:	Duda S, Dillard S AECOM
References
FOIA/PA-2011-0113
Download: ML11262A324 (57)

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I Logan, Dennis I

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Logan, Dennis Friday, July 30, 2010 3:13 PM Duda, Steve; 'Dillard, Steve'

'Spangler, Nicole' Salem Hope Creek: comments and edits on chapter 4 sections.

4.11.2 - Cumulative -Estuarine aquatic (2) DTL.docx; 4.5.1, 4.5.2, 4.5.3 - Aquatic Resources (3) DTL.docx; 4.5.4 Heat Shock (2) DTL.docx; 4.5.5 - Total Aquatic Impacts DTL.docx; 4.7 T&E Species DTL.docx Biologists, Here are some comments and suggested edits on Chapter 4 sections that we can talk about next week. I am still looking at the biological assessment.

Have a good weekend, Dennis

4.11.2 Cumulative Impacts on Estuarine Aquatic Resources This section addresses past, present, and future actions that have created or could result in cumulative adverse impacts on the aquatic resources of the Delaware Estuary, the geographic area of interest for this analysis. Cumulative impacts on freshwater aquatic resources other than the Delaware River are discussed with terrestrial resources in Section 4.11.3.

A wide variety of historical events have cumulatively affected the Delaware Estuary and its resources. Europeans began settling the estuary region early in the 17th century. By 1660 the English had established multiple small settlements, and major changes in the environment began. Philadelphia had 5,000 inhabitants by 1700 and became the predominant city and port in America. Agriculture grew throughout the region, and the clearing of forest led to erosion.

Dredging, diking, and filling gradually altered extensive areas of shoreline and tidal marsh. By the late 1800s, industrialization had altered much of the watershed of the upper estuary, and fisheries were declining due to overfishing as well as pollution from ships, sewers, and industry.

By the 1940s, anadromous fish were blocked from migrating upstream to spawn due to a barrier of low oxygen levels in the Philadelphia area. This barrier combined with small dams on tributaries nearly destroyed the herring and shad fisheries. A large increase in industrial pollution during and after World War II resulted in the Delaware River near Philadelphia becoming one of the most polluted river reaches in the world. Major improvements in water quality began in the 1960s through the 1980s as a result of State, multi-State, and Federal action, including the Clean Water Act and the activities of the Delaware River Basin Commission [(De#vware Estuary P 1ograrnm i_995):

In addition to past events, a variety of current and likely future activities and processes also have cumulative impacts on the aquatic resources of the Delaware Estuary to which the proposed action may contribute. Stressors associated with the proposed action and other activities or processes that may contribute to cumulative impacts on the aquatic resources of the estuary include the following:

continued operation of the once-through cooling system for Salem Units 1 and 2 continued operation of the closed-cycle cooling system for HCGS construction and operation of proposed additional unit at Salem/HCGS site continued withdrawal of water to support power generation, industry, and municipal water suppliers

• fishing pressure habitat loss and restoration

• changes in water quality

• climate change.

Each of these stressors may influence the structure and function of estuarine food webs and result in observable changes to the aquatic resources in the Delaware Estuary. In most cases, it is not possible to determine quantitatively the impact of individual stressors or groups of stressors on aquatic resources. The stressors affect the estuary simultaneously, and their effects are cumulative. A discussion follows of how the stressors listed above may contribute to cumulative impacts on aquatic resources of the Delaware Estuary.

Comment [DTL11]: Is all information in this paragraph from this source? If so, cite correctly.

Continued Operation of the Salem Once-Throulh Cooling System I Based on the assessment presented in Section 4.5 of this draft SEIS, the NRC staff concludesd that entrainment, impingement, and thermal discharge impacts on aquatic resources from the operation of Salem Units 1 and 2 collectively have not had a noticeable adverse effect on the balanced indigenous community of the Delaware Estuary in the vicinity of Salem. The continued operation of Salem during the renewal term would continue to contribute to cumulative impacts on the estuarine community of fish and shellfish. As discussed in Sections 4.5.2 through 4.5.5, there has been extensive, long-term monitoring of fish and invertebrate populations of the Delaware Estuary. The data collected by these studies reflect the cumulative effects of multiple stressors acting on the estuarine community. For example, data from 1970 through 2004 were analyzed using commonly accepted techniques for assessing species richness (the average number of species in the community) and species density (the average number of species per unit volume or area). This analysis found that in the vicinity of Salem and HCGS since 1978, when Salem began operation, finfish species richness has not changed, and species density has increased (PSEG, 2006a). Operation of Salem during the relicensing period likely would continue to contribute substantially to cumulative impacts on aquatic resources in conjunction with HCGS and other facilities that withdraw water from or discharge to the Delaware Estuary. However, given the long-term improvements in the estuarine community during recent decades while these facilities were operating, their cumulative impacts are expected to be limited, with effects on individual species populations potentially ranging from negligible to noticeable.

Continued Operation of the HCGS Closed-Cycle Cooling System As discussed in Section 4.5.1, the closed-cycle cooling system used by HCGS substantially reduces the volume of water withdrawn by the facility and similarly reduces entrainment, impingement, and thermal discharge effects. Accordingly, the impacts of these effects from operation of the HCGS cooling system during the relicensing period would be limited, and the incremental contribution of HCGS to cumulative impacts on the estuarine community would be minima1.

T-'lh-e analysis of cumulative4e-ffe-ct*, 6n the aquatic community-dis cussed aboove in-orpýoates the'effects of both HCGS and SalemiOperation of HCGS durincg the relicensin~q__

period would continue to contribute to cumulative impacts in conjunction with Salem and other facilities that withdraw water from or discharge to the Delaware Estuary. As described above for Salem, these cumulative impacts are expected to be limited, with effects on individual species populations potentially ranging from negligible to noticeable.

Construction and Operation of Proposed Additional Unit at Salem/HCGS Site Comment [DTL12]: Awkward. Even so, The chapter on impingement, entrainment, and thermal effects do not explicitly talk much about Hope Creek. We need to talk about how we are going to weave all this together.

If PSEG decides to proceed and construct a new nuclear power unit at the Salem/HCGS site, it would contribute to cumulative impacts on aquatic resources during construction and operation.

Thie ict' fof thaction on aquatic resources during the construction period may be u`*sbsta*ti i the imrmnedia*te vicinity of the Construction activities but would be limited in extent nd**iikbly tb"siginificantly contribute to cumulative impacts on the estuarine community. The Iontri'utiorlfrýom the long-term operation of the new facility to cumulative impacts on the Iu'arine community likely would be minor given the expected use of a closed-cycle coo in-g s ystem. :'

pcific impacts of this action ultimately Wou*d-- deend-onthq actual dsn---

operating charact-eristi-cs,and-construction pra-ctices proposed by the applicant. Such details are not available at this time, but if a combined license application is submitted to NRC, the detailed impacts of this action at the [S

~/HcGs site then would be analyzed and addressed in a separate NEPA document prepared by NRC.

- '" Comment [DTL13]: This is true of direct and Indirect effects. We need to expand this discussion to cumulative, though.

Also we must link our discussion to NRC's definitions of small, moderate and large levels of impact and say why what we expect fits into one of those definitions.

' Comment [DTL14]: Just curious: Are we using this symbol to represent the three units?

Continued Water Withdrawals and Discharges No lar-ge industrial facilities lie d~ownstream of Artificial Island, tharo aro no, rgo indu-trial faGilitie6-on either side of the estuary south to the mouth of Delaware Bay. An oil refinery lies uJpstream of Artificial Island, thero c6 an oil rofincr, in Delaware approximately 8 mi (13 km) to the north, and theFe-are-many industrial facilities are upstream from there (PSEG, 2009a).

Many of these facilities are permitted to withdraw water from the river and to discharge effluents to the river. In addition, water is withdrawn from the nontidal, freshwater reaches of the river to supply municipal water throughout New Jersey, Pennsylvania, and New York (DRBC 2010). In the tidal portion of the river, water is used for power plant cooling systems as well as industrial operations. DRBC-approved water users in this reach include 22 industrial facilities and 14 power plants in Delaware, New Jersey, and Pennsylvania (DRBC, 2005). Of these facilities, Salem uses by far the largest volume of water, with a reported water withdrawal volume in 2005 of 1,067,892 million gallons (4,025,953 million liters) (DRBC, 2005). This volume exceeds the combined total withdrawal for all other industrial, power, and public water supply purposes in the tidal portion of the river. The volume of water withdrawn by HCGS in 2005 was much lower, at 19,561 million gallons (73,745 million liters).

These activities are expected to continue in the future, and water supply withdrawals likely will increase in the future in conjunction with population growth. Because water withdrawals from the Delaware River will continue, and are likely to increase, during the relicensing term, this activity will continue to contribute to cumulative effects in the estuary. Similarly, ongoing discharges of effluents to the river and estuary will continue to have cumulative effects.

Withdrawals and discharges are regulated by Federal and State agencies as well as by the DRBC, limiting the magnitude of their effects. Permit requirements are expected to limit adverse effects from withdrawals and discharges, and cumulative impacts from these activities on the aquatic resources of the Delaware Estuary are expected to be minimal.

Fishing Pressure The majority of the RS and EFH species at Salem are commercially or recreationally important and, thus, are subject to effects from the harvesting of fish stocks. Losses from fish populations due to fishing pressure are cumulative in conjunction with losses due to entrainment and impingement at Salem and Hope Creek as well as other water intakes. In most cases, the commercial or recreational catches of RS are regulated by Federal or State agencies, but losses of some RS continue to occur as bycatch caught unintentionally when fishing for other species. The extent and magnitude of fishing pressure and its relationship to cumulative impacts on fish populations and the overall aquatic community of the Delaware Estuary are difficult to determine because of the large geographic scale of the fisheries and the natural variability that occurs in fish populations and the ecosystem. Fishing pressure (and protection of fisheries through catch restrictions) has the potential to influence the food web of the Delaware Estuary by affecting fish and invertebrate populations in areas extending from the Atlantic Ocean and Delaware Bay through the estuary and upriver.

Habitat Loss and Restoration As described above, alterations to terrestrial, wetland, shoreline, and aquatic habitats have occurred in the Delaware Estuary since colonial times. Development, agriculture, and other upland habitat alterations in the watershed have affected water quality. The creation of dams and the filling or isolation of wetlands to support industrial and agricultural activities have dramatically changed patterns of nutrient and sediment loading to the estuary. Such activities also have reduced productive marsh habitats and limited access of anadromous fish to upstream spawning habitats. In addition, historic dredging and deposition activities have altered estuarine environments and affected flow patterns, and future activities, such as dredging to

deepen the shipping channel through the estuary, may continue to influence estuarine habitats.

Development along the shores of the estuary in some places also has resulted in the loss of shoreline habitat.

Although habitat loss in the vicinity of the Delaware Estuary remains k-*concern[, habitat ------

Comment [DTL15]: To whom?

restoration activities have had a beneficial effect on the estuary and are expected to continue during the license renewal term as a requirement of the Salem NJPDES permit (see Section 4.5.5).

In addition, NRC expects ??? wetland permitting regulations afe-evpected-to limit future losses of wetland habitat to development in the watershed. Thus, the net cumulative impacts on aquatic habitats associated with the estuary are likely to be minimal in the future, and

-traon 'activities

_re expected to provide ongoing habitat iropovements.

[comment [D"L1-]:

Water Quality 11hneral, there is evidence to conclude that water quality in the Delaware River Basin,!.

ir'l*l;hr* g, "e"S tuary, is improving. Upgrades to wastewater treatment facilities and improved

,agricuuitural:practices during the past 25 years have reduced the amount of untreated sewage, manure,'and fertilizer entering the river and contributed to reductions in nutrients and an I plrent increase in dissolved oxygpe.- Chremical contaminants-persist-in sediments-and the tissues of fish and invertebrates, and nonpoint discharges of chemicals still occur (Kauffmann, Belden, and Homsey, 2008). Water quality in the Delaware Estuary likely will continue to be a concern; however, improvement may continue in many Icomponentsand the incremental ritribution Of Salem and HCGS to adverse effects on Water quality is p

nimal. __

• limate Chanq.d The potential cumulative effects of climate change on the Delaware Estuary, whether from natural cycles or related to anthropogenic activities, could result in a variety of changes that would affect aquatic resources. The environmental changes that could affect estuarine systems include sea level rise, temperature increase, salinity changes, and wind and water circulation changes. Changes in sea level could result in dramatic effects on tidal wetlands and other shoreline communities. Water temperature increases could affect spawning patterns or success, or influence species distributions when cold-water species move northward while warm-water species become established in new habitats. Changes in estuarine salinity patterns could influence the spawning and distribution of RS and the ranges of exotic or nuisance species. Changes in precipitation patterns could have a major effect on water circulation and change the nature of sediment and nutrient inputs to the system. This could result in changes to primary production and influence the estuarine food web on many levels. Thus, the extent and magnitude of climate change impacts may make this process an important contributor to cumulative impacts on the aquatic resources of the Delaware Estuary, and these impacts could be substantial over the long term.

Final Assessment of Cumulative Imoacts on Aquatic Resources Aquatic resources of the Delaware Estuary are cumulatively affected to varying degrees by multiple activities and processes that have occurred in the past, are occurring currently, and are likely to occur in the future. The food web and the abundance of RS and other species have been substantially affected by these stressors historically. The impacts of some of these stressors associated with human activities have been and can be addressed by management actions (e.g., cooling system operation, fishing pressure, water quality, and habitat restoration).

Other stressors, such as climate change and increased human population and associated development in the Delaware River Basin, cannot be directly managed and their effects are more difficult to quantify and predict. It is likely, however, that future anthropogenic and natural environmental stressors would cumulatively affect the aquatic community of the Delaware

• Comment [8]:

Comment [DTL19]:

Comment [DTL110]: i

Estuary sufficiently that they would noticeably alter important attributes, such as species ranges, populations, diversity, habitats, and ecosystem processes. Based on this assessment, the NRC staff concludes that cumulative impacts during the relicensing period from past, present, and future stressors affecting aquatic resources in the Delaware Estuary would range from SMALL to MODERATE. The incremental contribution from the continued operation of Salem and HCGS to impacts on aquatic resources of the estuary would be SMALL for most impacts.

References Delaware Estuary Program. 1995. Comprehensive Conservation and Management Plan for the Delaware Estuary. WHO PUBLISHED THIS AND WHERE. January.

Kauffmann, G., A. Belden, and A. Homsey. 2008. Technical Summary: State of the Delaware River Basin Report. July 4. Accessed 9 July 2010 at www.wra. udel.edu/files/DRBCStateoftheBasinReport_07042008.

4.5 Aquatic Resources 4.5.1 Categorization of Aquatic Resources Issues The Category 1 and Category 2 issues related to aquatic resources and applicable to HCGS and Salem are listed in Table 4-1 and discussed below. Section 2.1.6 of this report describes the HCGS and Salem cooling water systems, and Section 2.2.5 describes the potentially affected aquatic resources.

Table 4-1. Aquatic Resources Issues.

Issues GElS Section Category For All Plants Accumulation of contaminants in sediments or biota 4.2.1.2.4 1

Entrainment of phytoplankton and zooplankton 4.2.2.1.1 1

Cold shock 4.2.2.1.5 1

Thermal plume barrier to migrating fish 4.2.2.1.6 1

Distribution of aquatic organisms 4.2.2.1.6 1

Premature emergence of aquatic insects 4.2.2.1.7 1

Gas supersaturation (gas bubble disease) 4.2.2.1.8 1

Low dissolved oxygen in the discharge 4.2.2.1.9 1

Losses from parasitism, predation, and disease among 4.2.2.1.10 1

organisms exposed to sublethal stresses Stimulation of nuisance organisms 4.2.2.1.11 1

For Plants with Cooling-Tower-Based Heat Dissipation Systems'a)

Entrainment of fish and shellfish in early life stages 4.3.3 1

Impingement of fish and shellfish 4.3.3 1

Heat shock 4.3.3 1

For Plants with Once-Through Heat Dissipation Systems")

Entrainment of fish and shellfish in early life stages 4.2.2.1.2 2

Impingement of fish and shellfish 4.2.2.1.3 2

Heat shock 4.2.2.1.4 2

(a Applicable to HCGS

• ")Applicable to Salem The NRC staff did not identify any new and significant information related to Category 1 aquatic resources issues during the review of the applicant's ERs for Salem (PSEG, 2009a) and HCGS (PSEG, 2009b), the site audit, or the scoping process. Consequently, there are no impacts related to the generic, Category 1 issues beyond those discussed in the GELS. For these Category 1 issues, the GElS concluded that the impacts are SMALL, and additional site-specific mitigation measures are not likely to be warranted.

Entrainment of fish and shellfish in early life stages, impingement of fish and shellfish, and heat shock are Category 1 issues at power plants with closed-cycle cooling systems and are

Category 2 issues at plants with once-through cooling systems. Hope Creek uses a closed-cycle cooling system with a cooling tower. This type of cooling system substantially reduces the volume of water withdrawn by the plant and, consequently, also substantially reduces entrainment, impingement, and thermal discharge effects (heat shock potential). Entrainment, impingement, and heat shock are Category 1 issues for Hope Creek and do not require further analysis to determine that their impacts during the relicensing period would be SMALL. In contrast, the cooling water system at Salem is a once-through system, and for such systems entrainment, impingement, and heat shock are Category 2 issues that require site-specific analysis. The remainder of Section 4.5 discusses these Category 2 issues for Salem.

4.5.2 Entrainment of Fish and Shellfish in Early Life Stages Entrainment occurs when early life stages of fish and shellfish are drawn into cooling water intake systems along with the cooling water. Cooling water intake systems are designed to screen out larger organisms, but small life stages, such as eggs and larvae, can pass through the screens and be drawn into the plant condensers. Once inside, organisms may be killed or injured by heat, physical stress, or chemicals.

Reaulatory Background Section 316(b) of the Clean Water Act of 1977 (CWA) requires that the location, design, construction, and capacity of cooling water intake structures reflect the best technology available (BTA) for minimizing adverse environmental impacts (33 USC 1326). In July 2004, the U.S. Environmental Protection Agency (EPA) published the Phase II Rule implementing Section 316(b) of the CWA for Existing Facilities (69 FR 41576). The rule became effective on September 7, 2004 and included numeric performance standards for reductions in impingement mortality and entrainment that would demonstrate that the cooling water intake system constitutes BTA for minimizing impingement and entrainment impacts. Existing facilities subject to the rule were required to demonstrate compliance with the rule's performance standards during the renewal process for their National Pollutant Discharge Elimination System (NPDES) permit through development of a Comprehensive Demonstration Study (CDS). EPA officially suspended the Phase II rule on July 9, 2007, Ileaving permit Writers to utilize Best Professional.....

] Comment [DLI]: Actually, it didn't leave Judgment (BPJ) for determining BTA in compliance with Section 316(b).

permit writers In this conditions. EPA instructed permit writers to use 8 PJ.

EPA delegated authority for NPDES permitting to the New Jersey Department of Environmental Protection (NJDEP) in 1984. In 1990, NJDEP issued a draft permit that proposed closed-cycle cooling as BTA for Salem under the New Jersey Pollutant Discharge Elimination System (NJPDES). In 1993 NJDEP concluded that the cost of retrofitting Salem to closed-cycle cooling would be wholly disproportionate to the environmental benefits realized, and a new draft permit was issued in 1994 (PSEG, 1999a). The 1994 final NJPDES permit stated that the existing cooling water intake system was BTA for Salem, with certain conditions (NJDEP, 1994).

Conditions of the 1994 permit included improvements to the screens and Ristroph buckets, a monthly average limitation on cooling water flow of 3,024 million gallons per day (MGD), and a pilot study for the use of a sound deterrent system. In addition to technology and operational measures, the 1994 permit required restoration measures that included a wetlands restoration and enhancement program designed to increase primary production in the Delaware Estuary and fish ladders at dams along the Delaware River to restore access to traditional spawning runs for anadromous species such as blueback herring and alewife. A Biological Monitoring Work Plan (BMWP) also was required to monitor the efficacy of the technology and operational measures employed at the site and the restoration programs funded by PSEG (PSEG, 1999a).

The BMWP included monitoring plans for fish utilization of restored wetlands, elimination of impediments to fish migration, bay-wide trawl survey, and beach seine survey, in addition to the entrainment and impingement abundance monitoring (NJDEP, 1994). The main purpose of these studies was to monitor the success of the wetland restoration activities and screen modifications undertaken by PSEG.

The 2001 NJPDES permit required continuation of the restoration programs implemented in response to the 1994 permit, an Improved Biological Monitoring Plan (IBMP), and a more detailed analysis of impingement mortality and entrainment losses at the facility (NJDEP, 2001b). The 2006 NJPDES permit renewal application responded to the requirement for a detailed analysis by including a CDS as required by the Phase II rule and an assessment of alternative intake technologies (AIT). The AIT assessment includes a detailed analysis of the costs and benefits associated with the existing intake configuration and alternatives along with an analysis of the costs and benefits of the wetlands restoration program that PSEG implemented in response to the requirements of the 1994 NJPDES permit (PSEG, 2006a).

The IBMWP was submitted to NJDEP in April 2002 and approved in July 2003. A reduction in the frequency of monitoring at fish ladder sites that successfully pass river herring was submitted in December 2003 and approved in May 2004. In 2006 PSEG submitted a revised IBMWP that proposed a reduction in sampling at the restored wetland sites. Sampling would be conducted at representative locations instead of at every restoration site (PSEG, 2006a).

Salem's 2006 NJPDES permit renewal application included a CDS because the Phase II rule was still in effect at that time. The CDS for Salem was completed in 2006 and included an analysis of impingement mortality and entrainment at the facility's cooling water intake system.

This analysis shows that the changes in technology and operation of the Salem cooling water intake system satisfied the performance standards of the Phase II rule and that the current configuration constitutes BTA (PSEG, 2006a). In 2006 NJDEP administratively continued Salem's NJPDES permit (NJ0005622). No timeframe has been determined for issuance of the new NJPDES permit.

Entrainment Studies Prior to construction of the Salem facility, baseline biological studies were begun in 1968 to characterize the biological community in the Delaware Estuary. The study area consisted of the estuary 10 mi to the north and south of Salem. In 1969 with the passing of the National Environmental Policy Act (NEPA), the study program was expanded to include ichthyoplankton and benthos studies and to gather information on the feeding habits and life histories of the common species. In 1973 the Atomic Energy Commission (AEC) published its Final Environmental Statement (FES) for Salem, which concluded that the effects of impingement and entrainment on the biological community of the Delaware Estuary would not be significant (PSEG, 1999a).

The Salem facility began operation in 1977, and monitoring has been performed on an annual basis since then to evaluate the impacts on the aquatic environment of the Delaware Estuary from entrainment of organisms through the cooling water system. Methods and results of these studies are summarized in several reports, including the 1984 316(b) Demonstration (PSEG, 1984), the 1999 316(b) Demonstration (PSEG, 1999a), and the 2006 316(b) Demonstration (PSEG, 2006a). In addition, biological monitoring reports were submitted to NJDEP on an annual basis from 1995 through the present (PSEG, 1996; PSEG, 1997; PSEG, 1998; PSEG,

1999b; PSEG, 2000; PSEG, 2001; PSEG, 2002; PSEG, 2003; PSEG, 2004a; PSEG, 2005; PSEG, 2006b; PSEG, 2007b; PSEG, 2008; PSEG, 2009c).

The 1977 316(b) rule included a provision to select Representative Important Species (RIS) to focus the investigations, and previous demonstrations evaluated RIS as well as additional target species (PSEG, 1984; PSEG, 1999a). The 2006 CDS used the term Representative Species (RS) to comprise both RIS and target species and to be consistent with the published Phase II I Rule. RS were selected based on several criteria PeLiudif:fl-ludinasusceptibility to impingement and entrainment at the facility, importance to the ecological community, recreational or commercial value, and threatened or endangered status (PSEG, 2006a).

The 1984 316(b) Demonstration was a 5-year study from 1978 to 1983 that focused on nine RS, I including seven fish species and two macroinvertebrates. These species wete-are weakfish (Cynoscion regalis), bay anchovy (Anchoa mitchilli), white perch (Morone americana), striped bass (Morone saxatilis), blueback herring (Alosa aestivalis), alewife (Alosa pseudoharengus),

American shad (Alosa sapidissima), spot (Leiostomus xanthurus), Atlantic croaker (Micropogonias undulatus), opossum shrimp (Neomysis americana), and scud (Gammarus sp.)

(PSEG, 1984).

In 1999 PSEG submitted a 316(b) demonstration that included the same RS fish species as the previous studies and added the blue crab (Callinectes sapidus). Scud and opossum shrimp were removed from the list of RS because they have high productivity, high natural mortality, and assessments completed prior to PSEG's 1999 NJPDES application concluded that Salem does not and will not have an adverse environmental impact on these macroinvertebrates (PSEG, 1999a).

The 316(b) demonstration submitted during the 2006 NJPDES renewal process included an estimation of entrainment losses for the RS developed from data collected during annual entrainment monitoring conducted in accordance with the IBMWP.

A revised RS list was developed that included the nine finfish and the blue crab from previous studies and added the Atlantic silverside (Menidia menidia), Atlantic menhaden (Brevoortia tyrannus), and bluefish (Pomotomus saltrix) (PSEG, 2006a).

Entrainment samples typically were collected from the circulating water system intake bays 1 1A, 12B, or 22A or at discharge standpipes 12 or 22. From August 1977 through May 1980, intake samples were collected from the circulating water after it passed through the travelling screens and the circulating water pumps. In June 1980 the sample location was changed to the discharge pipes (PSEG, 1984). Beginning in 1994, samples were collected from either intake bay 12 B or22A (PSEG, 1996; PSEG, 1997; PSEG, 1998; PSEG, 1999b; PSEG, 2000; PSEG, 2001; PSEG, 2002; PSEG, 2003; PSEG, 2004a; PSEG, 2005; PSEG, 2006b; PSEG, 2007b; PSEG, 2008; PSEG, 2009c).

Samples were collected by pumping water through a Nielsen fish pump through a 1.0 meter diameter, 0.5 mm mesh, conical plankton net in an abundance chamber. A total sample volume of 50 to 100 m3 was filtered at a rate not to exceed 2.0 m3/minute. Sample contents were rinsed into a jar and preserved for laboratory analysis. Ichthyoplankton collected was identified to the lowest practical taxon and life stage, counted, and a subset was measured (PSEG, 1984).

From August 1977 to April 1978 entrainment samples were collected monthly from September through May and twice monthly from June through August. In 1979 samples were collected once monthly in March, April, October, and November, twice monthly in May, August, and

September and four times monthly in June and July. In 1980 through 1982 additional samples were collected every fourth day from May through October. Samples were collected every 4 hrs during a 24-hr period (PSEG, 1984). In 1994 and 1995 samples were collected three times a day, once a week from January through December (PSEG, 1994, PSEG, 1996). Beginning in April 1996 samples were typically collected three times a week in the summer months (April through September) and once a week throughout the remainder of the year (PSEG, 1997; PSEG, 1998; PSEG, 1999b; PSEG, 2000; PSEG, 2001; PSEG, 2002; PSEG, 2003; PSEG, 2004a; PSEG, 2005; PSEG, 2006b; PSEG, 2007b; PSEG, 2008; PSEG, 2009c). Six samples were collected during each 24-hr sampling period.

Ichthyoplankton samples also were collected from June through August in 1981 and 1982 adjacent to the intake structure in five horizontal offshore strata to develop model inputs for bay anchovy and weakfish. These samples were collected with a conical plankton net 0.5 m wide with a mesh size of 0.5 mm (PSEG, 1984).

Entrainment survival studies were conducted from 1977 through 1982. Survival studies were conducted twice in 1977 and three times in 1978. In 1979 no samples were collected for survival studies. In 1980 sampling was conducted from April through October with 10 events.

In 1981 and 1982 the sampling schedule was expanded to include four times monthly in June and July, twice monthly in May and August, and once each in September and October with 11 events occurring in May through October of 1981 and 12 events in June through September of 1982. Sampling locations for the survival studies were the same as for the abundance studies.

Intake and discharge locations were sampled with a lag to account for plant transit time with duplicate sampling gear to account for sampling induced mortality (PSEG, 1984).

Samples were collected using a centrifugal fish transfer pump and a one-screen larval table until 1980. After 1980 a low velocity flume was used to allow for a larger sample volume. Specimens were taken to an onsite laboratory where their condition was recorded. Individuals were classified as live, stunned, or dead according to pre-established criteria. Live and stunned specimens were held for 12 hr to determine latent mortality (PSEG, 1984).

In addition, tests were conducted from 1979 through 1981 to quantify mortality caused by the collection equipment. Tests were conducted with alewife, blueback herring, white perch, weakfish, spot, N. americana, and Gammarus spp. Mortality rates due to the larval table, the low velocity flume, and the fish pump combined with the larval table were estimated separately.

Entrainment simulation tests also were conducted from 1974 through 1982 to quantify the effects of pressure and temperature changes on entrained organisms (PSEG, 1984).

For the 1984 316(b) Demonstration, weekly entrainment densities (numbers of organisms per volume of water) were estimated based on densities in both the intake and the estuary. These projected densities then were used along with estimated weekly mortality rates to project annual entrainment losses due to the facility. Weekly mortality rates were estimated from the results of the onsite studies, simulation studies conducted in the laboratory, and literature values.

Mortality rates were calculated for the effects of mechanical and chemical stresses separately from thermal stresses. Total entrainment mortality was estimated based on the following equation (PSEG, 1984).

=1r-(1I M a) x (l 1it) where Mt total entrainment mortality rate nonthermal mortality rate thermal mortality rate Projected entrainment losses for each species were calculated on a daily basis using the following equation. Daily entrainment losses were then summed on a weekly basis and projected based on plant operating schedules (PSEG, 1984).

DaiLy Yntrainment loss M

CWSI. + SWS1.

+ CWS2. + SWS2.

CWSli - xi x Dnai*ty. 3 (r. " R x 7,)i(l - R + R x ri)

OWSLi - K2 x Denait7i x (0 - R) where C(SL.

= entrainmont IneR' at Unit No.

I CWS on the ith day EWS1. -

entrainmenc losa at Unit no.

I SVS on the ith day

.SZ.

entrainment loss at Uni: No. 2 CVS on the ith day SWS2i entrainment loss at Uni: go. 2 SWS on the its day KI p tltit withdrawal at Uni-. No.

1 CWS on tho ita day 11.672 m 3sec x 86400 seconds x the number of uWS pumps operating ia Uni: Ito. I K2 - plant withdrawal at Uni: No. I SWS on the it.% day

- 0.686 m /see x 86400 seconds x the number of SWS pumps operatint in Unit No.. 1 Denoity c

- *otit*ted outrai.ment density on the ith day F

- estimated total entrainmeut mortaliLy ut Unit No.

I OWO oa the i:h day R

• rezirculation factor The 1999 316(b) Demonstration used data from entrainment monitoring that was conducted annually from 1995 through 1998 in accordance with the BMWP. PSEG calculated fo0tal e-ntrainrentiossby species and life stage by summing the individual occurrences in sa*m*ples taken at the intakes for both the circulating water system (CWS) and the service water system (SWS) for Units I and 2; using correction factors for collection efficiency, recirculation (re-entrainment), and mortality; and then scaling for plant flow using the following equation (PSEG, 1999a).

" Comment [DL2]: Is the E in the equations that lfollows?I

K 36$

IQ, lR +RfY) where i

-i-water system, i.e., Unit I CWS, Unit I SWS, Unit 2 CWS, and Unit 2 SWS j

= f'day ofthe year Dy average concentration (number per m3 of intake water)

C

= collection efficiency jj daily through-plant mortality R

recirculation factor Qj, average daily plant flow forfh water system (m3)

This calculation provided estimated entrainment for each species and life stage during the sampling period. These data were used to compute densities for each week of the year, which then were scaled up based on weekly flow through the facility to estimate total entrainment losses for each year by species (Table 4-2). The years 1978 through 1981 were a transitional period between the beginning of commercial operation of Salem Unit 1 in 1978 and Unit 2 in 1982 (PSEG, 1999a).

In the 2006 316(b) Demonstration, PSEG estimated annual entrainment losses for the years 2002 through 2004 by using entrainment density data from sampling conducted at the intakes and scaling for total water withdrawal volume using the same methodology as described above for the 1999 316(b) study (Table 4-3). Entrainment losses were calculated by assuming an entrainment mortality rate of 100 percent (PSEG, 2006a). From 1978 through 1998 (Table 4-2) and 2002 through 2004 (Table 4-3), bay anchovy was the species with the greatest entrainment losses for all life stages (PSEG, 1999a; PSEG, 2006a).

Results of the annual entrainment monitoring for the RS at Salem from 1995 through 2008 were reported in annual biological monitoring reports for 1995 through 2008 (PSEG, 1996; PSEG, 1997; PSEG, 1998; PSEG, 1999b; PSEG, 2000; PSEG, 2001; PSEG, 2002; PSEG, 2003; PSEG, 2004a; PSEG, 2005; PSEG, 2006b; PSEG, 2007b; PSEG, 2008; PSEG, 2009c). Total annual entrainment was reported by species and life stage based on mean density expressed as number of organisms per 100 cubic meters (n/l 00 M3) of water withdrawn through the intake screens (Table 4-4).

Table 4-5 provides a list of species collected during the annual entrainment monitoring conducted at Salem from 1995 through 2008 and their average densities in cooling water during that period. On average, the RS constituted approximately 75 percent of total entrainment abundance based on average densities for these species from 1995 through 2008, and bay anchovy alone made up about 50 percent of total entrainment during this period.

Table 4-2. Estimated Annual Entrainment Losses for Representative Species (RS) at aiemf**78 to*

.99.

Comment [DL3]: Generally tables should be able to stand alone.

I Year Estimated Annual Entrainment Losses (in Millions)

American Atlantic Bay Blueback White Atlantic Alewife shad croaker anchovy herring Striped bass Spot Weakfish perch menhaden Silversiwe-1978 0.008 0.004 0.784 7,962.1 0.775 0.026 5.096 399.818 0.000 0.000 79.935 1979 0.050 0

14.515 3,535.1 0.019 0.020 1.095 23.193 0.625 0.072 18.083 1980 0.860 0.015 0.756 15,155.9 2.813 0

10.296 256.708 27.514 4.277 145.109 1981 2.002 0

8.157 11,714.1 11.853 0

5.418 45.765 0.969 9.207 113.240 1982 0

0 0

3,712.9 0.017 0

29.963 74.457 18.857 4.157 22.201 1985 0.163 0.126 0.933 29,463.7 1.151 0

0.184 63.616 0.447 0

0 1986 0.348 0.059 0.492 45,248.6 1.594 0

0.858 110.397 0.654 0

0 1987 0

0.062 0.000 40,172.4 0.082 0

0.055 61.267 0.628 0

0 1988 0.749 0

1.710 22,331.5 2.988 0

73.502 57.063 8.968 0

0 1989 0.541 0

56.341 10,163.5 2.395 47.946 1.027 3.026 192.131 0

0 1990 0.101 0

123.375 7,678.4 0.260 1.313 4.395 6.685 2.626 0

0 1991 0

0 131.798 19,506.6 0

0.778 1.096 72.478 1.108 0

0 1992 0.319 0

71.352 1,570.5 0.864 1.728 0.000 10.375 3.393 0

0 1993 0.676 0

75.030 11,774.2 2.340 108.065 0.585 122.672 37.635 0

0 1994 0.697 0

24.783 1,120.3 2.623 7.490 46.859 88.781 66.927 0

0 1995 0.477 0.014 31.454 1,404.5 0.082 0.579 0.071 335.083 2.039 177.221 31.019 1996 0.083 0.028 4.385 70.6 0.425 7.289 0.025 14.258 16.800 3.039 1.227 1997 0.053 0.747 71.819 1,811.8 0.318 6.505 0.007 12.601 7.865 16.668 6.919 1998 14.480 0

132.130 2,003.7 59.282 448.563 0.020 76.343 412.839 480.557 51.528 Source: NJPDES Application (PSEG, 1999a)

- Comment [DL4]: Atlantic silverside I think you should say so.

Table 4-3. Estimated Annual Entrainment and Annual Entrainment Losses for RS at Salem, 2002-2004 Total Entrained (in millions)

Taxon 2002 2003 2004 Alewife 9.8 5.2 2.5 American shad 0

0 0

Atlantic croaker 448.0 211.5 213.2 Bay anchovy 946.4 366.4 2,343.2 Blueback herring 1.1 1.7 1.1 Spot 2.3 0.047 0

Striped bass 403.6 120.3 35.7 Weakfish 29.2 11.9 46.8 White perch 18.7 19.5 25.8 Atlantic silverside 44.8 3.6 10.1 Atlantic menhaden 190.3 4.9

6.8 Source

Comprehensive Demonstration Study (PSEG, 2006a)

Entrainment Losses (in millions) 2002 2003 2004 9.4 4.5 2.4 0

0 0

182.5 86.4 87.9 946.4 366.4 2,343.2 1.0 1.6 0.934 0.454 0.009 0

159.5 37.6 14.3 19.2 8.5 32.8 18.0 13.9 23.9 44.8 3.6 10.1 190.3 4.9 6.8

Table 4-4. Entrainment Densities for Representative Species (RS. at Salem, 1995-2008 Density (n/100 M 3)

Taxon 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 Alewife 0.01 0.05

<0.01 0.11 0.02

<0.01 0.02 0.05 <0.01 American shad 0.01 0.01 0.00 Atlantic croaker 3.03 1.60 8.19 9.48 15.45 6.70 4.17 12.52 2.62 5.05 5.56 10.51 5.88 7.74 Atlantic menhaden 2.91 0.38 0.46 1.68 2.23 1.34 1.04 4.92 0.20 0.47 1.06 5.01 1.47 16.21 Atlantic silverside 0.13 0.29 0.69 0.22 2.20 0.36 0.09 0.95 0.15 0.47 0.55 0.29 0.12 0.10 Bay anchovy 66.55 17.43 42.95 61.88 292.14 12.72 8.86 24.18 13.15 100.52 54.57 101.45 174.66 41.87 Blueback herring 0.02 0.00 0.01 0.09 0.03 0.01

<0.01 0.02

<0.01

<0.01 0.01 <0.01 Blueback herring/alewife 0.01 0.12 2.06 0.02 0.05 0.01 0.11 0.07 0.07 0.05 0.03 0.72 Bluefish 0.01 0.00

<0.01 Spot 0.01 0.00 0.09 0.09 0.01 0.10

<0.01 0.25

<0.01 0.03 0.14 Striped bass 0.03 1.55 0.02 11.50 0.03 13.97 9.07 7.20 5.07 1.84 4.03 0.55 42.34 1.72 Weakfish 11.86 3.69 0.76 1.99 6.61 2.48 2.25 0.64 0.43 1.10 2.09 0.70 1.44 0.52 White perch 0.02 0.88 4.49 0.11 6.15 0.06 0.10 0.44 0.64 0.24 0.55 1.19 0.01 White perch/striped bass 0.06 1.10 3.63 0.00

<0.01 0.87 0.44 0.40 0.11 10.69 0.02 Eggs 47.54 0.51 21.41 41.84 278.18 0.35 2.97 8.42 2.06 74.22 28.56 78.20 149.59 23.82 Larvae 48.46 26.52 31.66 78.64 97.93 47.13 29.13 67.53 46.10 51.12 62.67 82.92 103.57 39.65 Juveniles 11.84 7.87 19.15 13.11 21.17 11.10 7.27 16.74 5.67 7.84 9.46 15.99 10.79 21.86 Adults 0.14 0.07 0.20 0.23 0.29 0.18 0.13 0.15 0.15 0.20 0.27 0.26 0.25 0.19 Source: Biological Monitoring Program Annual Reports (PSEG, 1996; PSEG, 1997; PSEG, 1998; PSEG, 1999b; PSEG, 2000; PSEG, 2001; PSEG, 2002; PSEG, 2003; PSEG, 2004a; PSEG, 2005; PSEG, 2006b; PSEG, 2007b; PSEG, 2008; PSEG, 2009c)

NOTE WHAT BLANKS MEAN.

Table 4-5. Species Entrained at Salem During Annual Entrainment Monitoring, 1995-2008 Common Name Bay anchovy Naked goby Striped bass Atlantic croaker Atlantic menhaden Weakfish Goby White perch/striped bass White perch Atlantic silverside Unidentifiable silverside Blueback herring/alewife Silversides Northern pipefish American eel Unidentifiable fish Summer flounder Hogchoker Spot Inland silverside Herrings Black drum Carps and minnows Gizzard shad Unidentifiable larvae Atlantic herring Alewife Smallmouth flounder Rough silverside Blueback herring Yellow perch Spotted hake Killifishes Mummichog Northern searobin Quillback Unidentifiable eggs Silver perch Winter flounder Threespine stickleback Atlantic needlefish Unidentifiable Blackcheek tonguefish Oyster toadfish Scientific Name Anchoa mitchilli Gobiosoma bosc Morone saxatilis Micropogonias undulatus Brevoortia tyrannus Cynoscion regalis Gobiidae Morone spp.

Morone americana Menidia menidia Antherinidae Alosa spp.

Menidia spp.

Syngnathusfuscus Anguilla rostrata Paralichthys dentatus Trinectes maculatus Leiostomus xanthurus Menidia beryllina Clupeidae Pogonios cromis Cyprinidae Dorosomo cepedianum Clupea harengus Alosa pseudoharengus Etropus microstomus Membras martinico Alosa aestivalis Perca flovescens Urophycis regia Fundulus spp.

Fundulus heteroclitus Prionotus carolinus Carpiodes cyprinus Bairdiella chrysoura Pleuronectes omericonus Gasterosteus aculeatus Strongylura marina Average Density (n/100 M3) 72.35 27.58 7.07 7.04 6.91 2.81 2.61 1.57 1.15 0.66 0.47 0.37 0.22 0.18 0.13 0.13 0.12 0.10 0.09 0.08 0.08 0.07 0.06 0.06 0.06 0.06 0.05 0.04 0.03 0.03 0.03 0.02 0.02.

0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 Symphurus plagiusa Opsanus tau

Common Name Scientific Name Common carp American shad Striped cusk-eel Windowpane Green goby Northern puffer Feather blenny American sand lance Bluefish Unidentifiable juvenile Striped searobin Conger eel Inshore lizardfish Unidentifiable drum Eastern silvery minnow Perches Northern kingfish Bluegill Banded killifish Unidentifiable sucker Striped anchovy Northern stargazer White crappie Tautog Unidentifiable porgy Spanish mackerel Black sea bass Sheepshead minnow Striped killifish Unidentifiable sunfish White sucker Channel catfish Cyprinus carpio Alosa sapidissima Ophidion morginatum Scoph thalmus aquosus Microgobius thalassinus Sphoeroides maculatus Hypsoblennius hentz Ammodytes americanus Pomatomus salatrix Prionotus evolans Conger oceanicus Synodus foetens Sciaenidae Hybognathus regius Percidae Men ticirrhus saxa tilis Lepomis macrochirus Fundulus diaphanus Catostomidae Anchoa hepsetus Astroscopus guttatus Pomoxis annularis Tautoga onitis Sparidae Scomberomorus maculatus Centropristis striata Cyprinodon variegauts Fundulus majolis Centrarchidae Catostomus commersoni Ictalurus punctatus Average Density (n/100 M3) 0.01 0.01 0.01 0.004 0.004 0.004 0.004 0.004 0.003 0.003 0.003 0.003 0.003 0.003 0.003 0.003 0.003 0.002 0.002 0.002 0.002 0.002 0.002 0.002 0.001 0.001 0.001 0.001 0.001 0.001 0.001 0.001

1) Species in bold are RS at Salem.

(2) Average density expressed as number of organisms entrained (n) per 100 cubic meters (m3) of water withdrawn through the intake screens.

Source: Biological Monitoring Program Annual Reports (PSEG, 1996; PSEG, 1997; PSEG, 1998; PSEG, 1999b; PSEG, 2000; PSEG, 2001; PSEG, 2002; PSEG, 2003; PSEG, 2004a; PSEG, 2005; PSEG, 2006b; PSEG, 2007b; PSEG, 2008; PSEG, 2009c)

Due to the differences in calculation methods and mortality rate estimates used during the more than 30 years since Salem Unit 1 began commercial operation in 1978, it is difficult to compare entrainment across the studies. The NRC staff used entrainment density as a metric to evaluate trends in entrainment and abundance of RS in water of the Delaware Estuary at the Salem intake over the operational period 1978 through 2008 (Table 4-6). Throughout this period, the species most entrained was the bay anchovy.

Table 4-6. Entrainment Densities for RS at Salem, 1978-2008 Density (n/1O0 mn 3)

Taxon 1978 1979 1980 1981 1982 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 Alewife 0.03 0.01 0.01 Alosa sp.

0.14 0.01 0.02 0.15 0.11 American shad Atlantic croaker 0.10 0.02 0.02 1.24 0.02 0.07 0.07 2.76 0.72 3.47 2.51 2.71 1.19 Atlantic menhaden 0.02 0.25 1.13 0.27 Atlantic silverside Bay anchovy 349.64 1848.55 845.68 706.22 148.12 1799.26 2527.17 2094.53 618.68 314.27 243.26 416.78 111.59 416.25 27.22 Blueback hemng 0.06 0.07 0.12 0.03 0.04 Blueback hemng/alewife Morone sp.

0.21 0.01 0.03 0.90 0.01 Bluefish Silversides 6.32 15.33 4.77 4.04 0.86 Spot 0.07 0.10 1.53 0.86 3.69 0.04 0.01 1.64 0.02 0.16 0.09 0.01 1.17 Striped bass 0.05 1.87 0.01 0.03 0.06 3.63 0.29 Weakfish 16.31 3.35 5.15 1.20 2.63 1.77 4.50 3.09 1.11 0.08 0.28 1.43 0.25 1.91 2.46 White perch 0.09 0.26 0.01 0.01 0.10 4.16 0.03 0.01 0.07 0.46 0.81 White perch/striped bass Density (n/100 mi)

Taxon 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 Alewife 0.01 0.05

< 0.01 0.11 0.02

< 0.01 0.02 0.05

< 0.01 Alosa sp.

0.01 0.13 1.58 American shad 0.01 0.00 Atlantic croaker 3.07 1.64 12.48 8.52 15.45 6.70 4.17 12.52 2.62 5.05 5.56 10.51 5.88 7.74 Atlantic menhaden 2.90 0.37 0.86 3.19 2.23 1.34 1.04 4.92 0.20 0.47 1.06 5.01 1.47 16.21 Atlantic silverside 2.20 0.36 0.09 0.95 0.15 0.47 0.55 0.29 0.12 0.10 Bay anchovy 64.18 17.63 52.89 53.31 292.14 12.72 8.86 24.18 13.15 100.52 54.57 101.45 174.66 41.87 Blueback herring 0.02 0.10 0.01 0.09 0.03 0.01

< 0.01 0.02

< 0.01

< 0.01 0.01

< 0.01 Blueback herring/alewife 0.02 0.05 0.01 0.11 0.07 0.07 0.05 0.03 0.72 Morone sp.

0.06 1.11 2.92 0.02 Bluefish 0.00

< 0.01 Silversides 0.99 0.30 0.96 0.87 Spot 0.01 0.03 0.00 0.09 0.09 0.01 0.10

< 0.01 0.25

< 0.01 0.03 0.14 Striped bass 0.03 1.58 0.03 9.92 0.03 13.97 9.07 7.20 5.07 1.84 4.03 0.55 42.34 1.72 Weakfish 11.78 3.75 0.77 1.80 6.61 2.48 2.25 0.64 0.43 1.10 2.09 0.70 1.44 0.52 White perch 0.02 0.90 3.73 0.11 6.15 0.06 0.10 0.44 0.64 0.24 0.55 1.19 0.01 White perch/striped bass 0.00

< 0.01 0.87 0.44 0.40 0.11 10.69 Source: Biological Monitoring Program Annual Reports ( PSEG, 2000; PSEG, 2001; PSEG, 2002; PSEG, 2003; PSEG, 2004a; PSEG, 2005; PSEG, 2006b; PSEG, 2007b; PSEG, 2008; PSEG, 2009c)

w 0z

Entrainment Reductions Due to the potential for entrainment to have adverse effects on the aquatic environment in the vicinity of Salem, and in response to the requirements of the 1994 NJPDES permit, PSEG has employed technological and operational changes to reduce entrainment and impingement and mitigate their effects on the Delaware Estuary. While improvements to the cooling water intake system were targeted mainly toward reducing impingement mortality, improvement in entrainment rates also has resulted. In response to the requirements of the 1994 NJPDES permit, PSEG made modifications to the trash racks, intake screens, and fish return system (PSEG, 1999a).

Improved intake screen panels were installed that use a thinner wire in the mesh (14 gage instead of 12 gage), which in combination with smaller screen openings allowed for a 20 percent decrease in through-screen velocity. Lower velocities through the screens allow more small fish to be able to swim away from the screens and escape entrainment. Screen openings also were reduced in size from 3/8 in. (10 mm) square mesh to 1/4 in. (6 mm) wide by 1/2 in. (13 mm) high rectangular mesh. The smaller screen openings reduce the size of organisms that can be drawn through the screens, thus reducing entrainment. The smaller screen mesh excludes more organisms, which then may be impinged and could be returned to the estuary alive (PSEG, 1999a). While impingement mortality rates for these smaller organisms generally are higher than for larger organisms, they are lower than estimated entrainment mortality rates (PSEG, 1999a).

4.5.3 Impingement of Fish and Shellfish Impingement occurs when fish and shellfish are held against the intake screens by the force of the water being drawn into the cooling system. Impingement mortality can occur directly as a result of the force of the water, or indirectly due to stresses from the time spent on the screens or as a result of being washed off the screens.

Regulatory Background Impingement and entrainment are both regulated by Section 316(b) of the CWA through the NPDES permit renewal process. A history of NPDES permitting at Salem can be found in Section 4.5.2 under the heading Regulatory Background.

Impinpement Studies PSEG has performed annual impingement monitoring at the Salem plant since 1977 in order to determine the impacts that impingement at Salem might have on the aquatic environment of the Delaware Estuary. The monitoring program described in the early 316(b) demonstration focused on seven target fish species. The two macroinvertebrates included in the entrainment study program are too small to be impinged and, therefore, were not included in the impingement study program. The fish species arei-are weakfish (Cynoscion regalis), bay anchovy (Anchoa mitchill), white perch (Morone americana), striped bass (Morone saxatilis),

blueback herring (Alosa aestivalis), alewife (Alosa pseudoharengus), American shad (Alosa sapidissima), spot (Leiostomus xanthurus), and Atlantic croaker WMicropogonias undulatu*

s)_(PSEG 1984). ----------------------------------------

Impingement abundance samples were collected at the cooling water system (CWS) and service water system (SWS) intakes from May 1977 through December 1982. CWS samples

_ - - j Comment EDL5]: check throughout

were collected at least 4 times per day at 6 hr intervals three days a week from May 1977 through September 1978. In September 1978 sampling frequency was increased to a minimum of ten samples per day six days a week. In spring of 1980, sampling frequency was reduced to four times a day, but remained at six days a week (PSEG, 1984).

Impinged organisms are washed off the CWS intake screens and returned to the Delaware Estuary through a fish return system. Impingement samples were collected in fish counting pools constructed for this purpose that are located adjacent to the fish return system discharge troughs at both the northern and southern ends of the CWS intake structure. Screen-wash water was diverted into the counting pools for an average sample duration of 3 min (depending on debris load, sampling time varied from 1 to 15 min). Water then was drained from the pools, and organisms were sorted by species, counted, measured, and weighed (PSEG, 1984).

Impingement abundance samples were collected from the SWS intake screens by a high-pressure spray wash into collection baskets through a trough. Screen washes were conducted at either 12 hr or 24 hr intervals depending on debris loads. Samples were collected from the SWS three times a week from April 1977 through September 1979. Organisms were sorted, counted, and weighed (PSEG, 1984).

Special impingement-related studies in addition to impingement monitoring studies also were performed. Studies were conducted from 1979 through February 1982 to quantify impingement collection efficiency. Studies of blueback herring, bay anchovy, white perch, weakfish, spot, and Atlantic croaker were conducted to determine the percentage of different size classes of fish that would not be collected by the screen washing and fish collection procedures (PSEG, 1984).

Because individual organisms that are impinged on the intake screens are washed off and returned to the estuary, studies of impingement mortality rates also were conducted from May 1977 through December 1982. Studies were conducted to estimate the percentage of impinged individuals that do not survive being impinged and washed from the intake screens (initial mortality) and the percentage that exhibit delayed mortality and do not survive for a longer period of at least 2 days (extended or latent mortality). Studies of initial mortality were conducted at a rate of three times per week until October 1978, after which samples were collected six times per week if impingement levels for target species exceeded predetermined levels. Initial mortality studies were conducted using the same counting pools as the abundance samples. Screen-wash water was diverted into the counting pool, samples were held for 5 min, the water was drained from the pool, and organisms were sorted. as live, damaged, or dead. Each subset was identified to species and the total number and weight, maximum and minimum lengths, and length frequency distribution were recorded. Studies of latent mortality were conducted using the organisms classified as live or damaged in the studies of initial mortality. At the beginning of the latent mortality studies, only organisms classified as live were used, but damaged fish also were evaluated after November 1978. Latent mortality studies were conducted at least weekly and entailed holding impinged organisms in aerated tanks for 48 hrs. Organisms were monitored continuously for the first 30 min, at hour intervals for the next 4 hrs, and then at approximately 24-hr intervals. Control specimens also were collected with a seine and subjected to the same survival study (PSEG, 1984).

Impingement mortality was found to be seasonally variable and dependent on several environmental factors, including temperature and salinity. Initial and latent mortality rates were estimated on a monthly basis and summed to provide a total mortality rate (PSEG, 1984).

Estimated impingement mortality rates by species evaluated are summarized in Table 4-7.

Table 4-7. Estimated Impingement Mortality Rates by Species at Salem, 1977-1982 Estimated Impingement Mortality Taxon (percent)

Spot 30.2 -67.7 Blueback herring 71.9 - 100 Alewife 72.6-100 American Shadshad 20.8-100 Atlantic croaker 38.8 - 87.9 Striped bass 10.0-84.8 White perch 29.4 - 52.9 Bay anchovy 77.0 -95.1 Weakfish 71.2 -78.3 Source: PSEG, 1984 PSEG submitted a 316(b) demonstration in 1999 as part of the application for NJPDES permit renewal (PSEG, 1999a). This demonstration assessed the effects of Salem's cooling water intake structure on the biological community of the Delaware Estuary (PSEG, 1999a). It focused on the same RS fish species as the earlier studies and added the blue crab (Callinectes sapidus). Impingement losses at Salem were estimated using impingement density (the number of impinged individuals collected divided by the total volume sampled, expressed as number/m 3) and adjusting for impingement survival, collection efficiency, and recirculation factor. This result was then scaled by month using the water withdrawal rates and summed for the year to provide annual impingement losses for the facility. Estimated annual impingement losses for the RS at Salem from 1978 through 1998 are summarized in Table 4-8. Bay anchovy was the dominant species lost to impingement from 1978 to 1998, constituting 46 percent of the RS impingement loss. Weakfish was the next dominant species lost, making up 20 percent of the RS impingement losses (PSEG, 1999a).

Impingement monitoring was conducted annually in accordance with the BMWP from 1995 through 2002. In 2002, the IBMWP was developed to include improvements to the BMWP.

These monitoring plans include provisions to quantify impingement and entrainment losses at Salem, as well as fish populations in the Delaware Estuary and the positive effects of the restoration program (PSEG, 2006a).

Table 4-8. Estimated Annual Impingement Losses for RS at Salem, 1978 to 1998 Year Alewife 1978 17,057 1979 11,513 1980 11,301 1981 647,832 1982 46,951 1983 19,584 1984 128,002 1985 4,676 1986 20,788 1987 74,461 1988 31,082 1989 137,998 1990 50,074 1991 21,275 1992 23,847 1993 23,267 1994 22,946 1995 14,745 1996 1,321 1997 5,899 1998 8,037 Source:

PSEG, 1999a Estimated Annual Impingement Losses American Atlantic Bay Blueback Shad croaker anchovy herring Blue crab 4,549 125,822 2,623,694 438,248 111,627 8*

2,144 8,494 1,321,105 651,005 97,434 29 6,382 93,232 11,046,658 460,638 501,000 14 8,820 14,996 11,264,933 364,803 347,436 85 9,406 2,975 3,846,612 418,130 122,032 97 5,359 2,326 3,784,994 224,303 100,953 68 3,266 853 2,444,847 1,335,665 87,890 31 11,033 275,670 3,771,190 162,478 1,011,790 18 11,007 233,915 2,011,567 467,361 1,228,076 5

24,120 1,245,098 3,346,956 157,496 834,857 2

35,182 4,046 4,657,784 357,896 1,247,649 1,9 65,138 24,168 781,653 891,085 344,310 11 15,393 5,787 1,373,446 168,555 178,511 12 22,874 45,535 1,719,784 137,107 307,591 13 64,807 55,267 1,286,667 120,649 370,591 2

22,087 176,279 596,243 100,999 387,190 1E 6,315 31,538 178,764 31,835 491,199 24 7,940 610,261 363,601 143,846 1,012,348 2

829 21,010 18,802 5,548 83,457 7

819 266,558 309,018 50,879 475,443 3(

2,214 2,370,135 1,104,126 57,267 280,741 2

Striped White Spot bass Weakfish perch 4,519 3,213 6,391,256 254,688 2,471 9,625 580,628 541,715 6,794 4,350 1,821,462 403,453 7,167 1,895 1,818,578 344,726 9,961 542 967,867 261,912 1,704 924 1,038,356 143,904 6,579 430 357,125 300,333 3,679 193 1,263,119 582,528 2,445 2,875 756,956 1,033,048

,204 6,673 1,095,105 715,912 17,236 10,450 427,218 646,825 9,381 26,006 184,538 760,842 0,833 28,003 170,778 768,431 4,807 10,089 575,349 688,724

,999 20,966 841,319 1,158,199 6,869 74,100 723,366 1,043,913 7,677 23,612 2,130,349 1,266,489 7,435 10,812 890,341 321,359

,281 9,191 130,459 75,006

),245 12,779 1,582,441 228,996

,654 10,660 1,572,811 124,351

The 316(b) demonstration submitted during the 2006 NJPDES renewal process (PSEG, 2006a) included the CDS as required by the Phase II rule and a demonstration that the plant satisfies the impingement mortality and entrainment reductions required by the rule. The CDS included an estimation of impingement losses for the RS developed from data collected during annual impingement monitoring conducted in accordance with the IBMWP. A revised RS list was developed for the IBMWP and subsequently used in the 2006 CDS that included the nine finfish and the blue crab from previous studies and added the Atlantic silverside (Menidia menidia),

Atlantic menhaden (Brevoortia tyrannus), and bluefish (Pomotomus saltrix) (PSEG, 2006a).

Estimated annual impingement and impingement losses for the study period 2002 to 2004 are summarized in Table 4-9. Atlantic croaker was the species most impinged in 2002 and the RS most often lost to impingement that year. White perch was the RS most impinged in 2003 and 2004, while weakfish was the species most often lost to impingement in those years.

Table 4-9. Estimated Annual Impingement and Annual Impingement Losses for RS at Salem, 2002-2004 Total Impingement Impingement Losses Taxon 2002 2003 2004 2002 2003 2004 Alewife 87,001 31,275 134,149 10,996 16,360 63,492 American shad 5,879 31,584 227,103 1,672 15,354 72,486 Atlantic croaker 21,313,809 620,754 3,260,494 6,332,522 143,298 332,644 Bay anchovy 424,168 475,799 544,177 197,496 326,839 341,135 Blueback herring 184,095 133,328 1,110,952 28,113 50,790 265,866 Spot 1,131 2,714 366 253 721 133 Striped bass 101,208 776,934 505,340 5,351 167,332 66,007 Weakfish 722,090 3,129,152 3,531,713 428,300 1,953,299 2,118,736 White perch 2,044,207 9,424,768 11,181,299 163,505 773,818 970,462 Atlantic silverside 509,142 220,114 156,495 138,270 44,951 48,609 Atlantic menhaden 534,646 31,211 20,420 360,931 21,769 15,724 Blue crab 2,739,118 356,983 831,320 172,725 27,483 57,931 Bluefish 45,292 31,311 44,533 3,884 7,592 17,433 Source: PSEG, 2006a Table 4-10 provides a summary of annual impingement densities based on monitoring results for RS at Salem from the annual monitoring reports for the period 1995 through 2007.

Impingement densities were calculated by relating impingement abundance to the circulating water flow and extrapolating to the number of organisms impinged per million m3 for every week of each year (PSEG, 1999a). The four most commonly impinged species were Atlantic croaker (23 percent), blue crab (21 percent), white perch (19 percent), and weakfish (14 percent). Table 4-11 provides a list of species collected and average densities impinged during this period.

Table 4-10. Impingement Densities for RS at Salem, 1995-2008 Density (n/106 Mi)

Taxon 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 Blue crab 1901.05 620.48 2033.08 824.27 636.84 393.89 606.88 502.13 76.41 171.28 1895.82 694.73 797.66 640.45 Alewife 3.09 5.47 10.8 12.09 15.78 27.41 20.55 13.91 4.84 25.99 8.19 2.41 7.66 0.66 American shad 3.1 2.63 1.00 3.39 14.5 3.82 0.57 0.79 6.43 43.24 10.11 4.01 16.98 1.7 Atlantic croaker 887.71 112.71 623.81 1489.08 625.94 403.53 412.56 3820.65 101.22 626.74 845.57 1405.31 951.09 545.25 Atlantic menhaden 14.72 9.9 38.36 78.79 15.78 20.5 25.55 88.9 6.26 4.82 22.22 44 27.49 57.85 Atlantic silverside 44.15 12.61 40.7 43.54 111.15 49.67 42.28 78.46 35.67 25.71 24.08 46.89 44.52 56.28 Bay anchovy 136.82 66.52 229.13 367 127.83 122.62 84.1 74.09 89.5 93.89 49.33 202.44 132.62 72.27 Blueback herring 30.78 8.64 126.62 107.8 110.7 73.14 81.06 31.05 23.27 156.55 19.75 25.37 17.76 7.34 Bluefish 2.69 8.88 6.41 4.79 2.55 6.00 1.14 7.89 8.14 11.67 2.06 7.44 2.95 5.7 Spot 10.28 3.38 88.74 3.94 0.53 7.28 0.05 0.34 0.8 0.14 55.11 10.38 3.73 23.65 Striped bass 64.89 82.05 62.91 28.61 52.83 102.49 54.62 20.04 159.93 110.86 29.72 10.22 47.88 32.56 White perch 641.12 543.08 1625.16 425.98 384.33 273.32 263.56 427.71 1771.18 2113.19 1042.62 360.51 429.81 662.14 Weakfish 1071.27 441.89 1370.74 528.95 228.01 369.57 524.64 172.98 530.71 725.72 930.88 343.81 379.65 304.8 Source: Biological Monitoring Program Annual Reports (PSEG, 1996; PSEG, 1997; PSEG, 1998; PSEG, 1999b; PSEG, 2000; PSEG, 2001; PSEG, 2002; PSEG, 2003; PSEG, 2004a; PSEG, 2005; PSEG, 2006b; PSEG, 2007b; PSEG, 2008; PSEG, 2009c)

Table 4-11. Species Impinged at Salem and Average Impingement Densities, Based on Annual Impingement Monitoring for 1995-2007 Common Name(

1 )

Atlantic croaker Blue crab White perch Weakfish Hogchoker Spotted hake Bay anchovy Striped bass Blueback herring Atlantic silverside Gizzard shad Atlantic menhaden Threespine stickleback Striped cusk-eel Spot Alewife Northern searobin American shad Yellow perch Black drum Atlantic herring Eastern silvery minnow Bluefish American eel Channel catfish Silver perch Summer flounder Northern kingfish Oyster toadfish Northern pipefish Red hake Naked goby Winter flounder Windowpane Mummichog Smallmouth flounder Bluegill Striped searobin Scup Harvestfish Striped killifish Butterfish Black sea bass Scientific Name(

1 )

Micropogonias undulatus Callinectes sapidus Morone americana Cynoscion regalis Trinectes maculatus Urophycis regia Anchoa mitchilli Morone saxatilis Alosa aestivalis Menidia menidia Dorosoma cepedianum Brevoortia tyrannus Gasterosteus aculeatus Ophidion marginotum Leiostomus xanthurus Alosa pseudoharengus Prionotus carolinus Alosa sapidissima Perca flavescens Pogonios cromis Clupea harengus Hybognothus regius Pomatomus saltatrix Anguilla rostrato Ictalurus punctatus Boirdiello chrysouro Paralichthys dentatus Men ticirrhus saxa tills Opsanus tau Syngnathusfuscus Urophycis chuss Gobiosomo bosc Pleuronectes omericonus Scophtholmus aquosus Fundulus heteroclitus Etropus microstomus Lepomis macrochirus Prionotus evolons Stenotomus chrysops Peprilus alepidotus Fundulus moj/lis Peprilus triacanthus Centropristis striato Average Density (n/106 m3) (2) 917.94 842.50 783.12 565.97 231.95 135.03 132.01 61.40 58.56 46.84 42.11 32.51 27.64 20.78 14.88 11.35 10.53 8.02 7.71 6.29 6.05 5.60 5.59 5.32 4.90 4.62 4.48 4.29 3.68 3.59 3.26 3.25 2.59 2.41 2.13 2.00 1.89 1.81 1.38 1.01 1.00 0.87 0.83

Common Name(1 )

Brown bullhead River herring Unknown spp.

Sea lamprey Skilletfish Rainbow smelt Northern stargazer Fourspine stickleback Conger eel Striped mullet Temperate bass Rough silverside Striped anchovy Inland silverside White mullet Spotfin butterflyfish Atlantic needlefish Yellow bullhead Crevalle jack Black crappie Banded killifish Silver hake Lookdown Blackcheek tonguefish Permit Common carp Sheepshead minnow Pumpkinseed Northern puffer Sheepshead Florida pompano Fourspot flounder Smooth dogfish Tessellated darter Lined seahorse Inshore lizardfish Pinfish Golden shiner Atlantic spadefish White crappie Unidentifiable Fish White catfish White sucker Spotfin killifish Pigfish Feather blenny Spanish mackerel Scientific Name(

1 )

Ameiurus nebulosus Alosa spp.

Unknown spp.

Petromyzon marinus Gobiesox strumosus Osmerus punctatus Astroscopus guttatus Apeltes quadracus Conger oceanicus Mugil cephalus Morone sp.

Membras martinica Anchoa hepsetus Menidia beryllina Mugil curema Choetodon ocellatus Strongylura marina Ameiurus natalis Caranx hippos Pomoxis nigromaculatus Fundulus diaphanus Merluccius bilinearis Selene vomer Symphurus plagiusa Trachinotus falcatus Cyprinus carpio Cyprinodon variegatus Lepomis gibbosus Sphoeroides maculatus Archosargus probatocephalus Trachinotus carolinus Paralichthys oblongus Mustelus canis Etheostoma olmstedi Hippocampus erectus Synodus foetens Lagodon rhomboides Notemigonus crysoleucas Chaetodipterusfaber Pomoxis annularis Unidentifiable fish Ameiurus catus Catostomus commersani Fundulus luciae Orthopristis chrysoptera Hypsoblennius hentz Scomberomorus maculatus Average Density (n/lO6 M3) (2) 0.76 0.75 0.52 0.52 0.51 0.48 0.45 0.44 0.43 0.43 0.38 0.36 0.36 0.33 0.32 0.28 0.27 0.26 0.25 0.24 0.24 0.23 0.20 0.20 0.16 0.14 0.14 0.14 0.14 0.13 0.13 0.12 0.12 0.12 0.11 0.11 0.11 0.11 0.10 0.10 0.10 0.10 0.09 0.09 0.09 0.09 0.09

Common Name(

tl Bluespotted cornetfish Spottail shiner Goosefish Atlantic thread herring Green sunfish Redfin pickerel Spotfin mojarra Redeared sunfish Tautog Fat sleeper Largemouth bass Cownose Satinfin shiner Rainbow trout Redbreast sunfish Green goby Eastern mudminnow Mud sunfish Atlantc sturgeon Atlantic cutlassfish Southern kingfish Scientific Name(')

Fistularia tabacaria Notropis hudsonius Lophius americanus Opisthonema oglinum Lepomis cyanellus Esox americanus Eucinostomus argenteus Lepomis microlophus Tautoga onitis Dormitator maculatus Micropterus salmoides Rhinoptera bonasus Cyprinella analostana Oncorhynchus mykiss Lepomis auritus Microgobius thalassinus Umbra pygmaea Acantharchus pomotis Acipenser oxyrhynchus Trichiurus lepturus Menticirrhus americanus Average Density (n/10 6 M

3) (2) 0.09 0.08 0.08 0.07 0.07 0.07 0.07 0.07 0.06 0.06 0.06 0.06 0.06 0.06 0.06 0.06 0.06 0.05 0.05 0.05 0.05

11) Species in bold are RS at Salem.

(2) Average density expressed as number of fish impinged (n) per million (106) cubic meters (M3) of water withdrawn through the intake screens.

Source: Biological Monitoring Program Annual Reports (PSEG, 1996; PSEG, 1997; PSEG, 1998; PSEG, 1999b; PSEG, 2000; PSEG, 2001; PSEG, 2002; PSEG, 2003; PSEG, 2004a; PSEG, 2005; PSEG, 2006b; PSEG, 2007b; PSEG, 2008; PSEG, 2009c)

Due to the differences in methods used during the more than 30 years since Salem Unit 1 began commercial operation in 1978, it is difficult to compare impingement estimates across studies. The NRC staff used impingement density as a metric to evaluate trends in impingement and abundance of RS in water withdrawn at the Salem intake over the operational period 1978 through 2008 (Table 4-12).

Table 4-12. Impingement Densities for IRS at Salem, 1978-2008 Taxon Alewife American shad Atlantic croaker Atlantic menhaden Atlantic silverside gwp.

4nho Blue crab Blueback herring Bluefish Spot Striped bass Weakfish White perch Density (n/10' m')

1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 0.26 0.95 0.89 26.35 2.02 0.75 3.81 0.13 0.75 2.04 0.94 3.70 0.12 0.39 0.41 0.38 0.69 0.38 0.20 0.48 0.64 1.04 1.57 2.78 7.04 0.42 5.89 0.70 0.15 0.30 0.09 9.36 7.23 43.97 0.42 1.66 1990 1991 199Z 1993 1.33 0.75 0.89 0.91 0.70 1.14 4.04 0.95 0.25 3.21 7.55 11.22 228.56_

204.95 459.35 _ 406.60 97.15__ 142.69

_1M06.9

_ 8199 55.35 56.97 44.45 151.83 66.59 16.33 16.24 19.73 141.62 181.63 28.28 27.13 17.98 14.93 17.79 10.80 54.15 4.54 10.04 15.42 52.60 17-58 45.34 60.92 47.50 32.48 4.37 3.85 0.83 2.58 0.64 0.18 0.09 0.04 0.08 0.13 0.39 910.81 149.03 105.78 78.91 43.69 49.78 30.34 55.38 36.60 32.27 69.78 33.33 33.24 25.47 20.91 23.30 25.69 75.29 78.23 109.58 4.40 0.09 1.95 52.25 49.20 94.96 160.39 7.90 96.29 1.62 18.39

'38.93 19.52 47.22 27.43 7.08 3.84 7.27 S2.33 36.61

_ _40.94 _ 17.09 _ _16.44_

38.04 45.42 75.99 65.48 4.70 6.19 5.27 2.77 5.43 5.38 0.12 0.98 3.84 2.08 3.59 15.85 10.70 25.20 48.07 40.86 57.08 52.80 55.23 123.43 Comment [DL6]: Anything we can say about trends? Particularly in relation to Salem-Hope Creek?

r Density (n/106 n')

Taxon 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 Alewife 0.65 3.09 5.47 10.8 12.09 15.78 27.41 20.55 13.91 4.84 25.99 8.19 2.41 7.66 0.66 American shad 0.32 3.1 2.63 1

3.39 14.S 3.82 0.57 0.79 6.43 43.24 10.11 4.01 16.98 1.7 Atlantic croaker 3.59 887.71 112.71 623.81 1489.08 625.94 403.53 412.56 3820.65 101.22 626.74 845.57 1405.31 901.09 545.25 Atlantic menhaden 14.72 9.9 38.36 78.79 15.78 20.5 25.55 88.9 6.26 4.82 22.22 44 27.49 57.85 Atlantic silverside 44.15 12.61 40.7 43.54 111.15 49.67 42.28 78.46 35.67 25.71 24.08 46.89 44.52 56.28 Bay anchovy 5.11 136.82 66.52 229.13 367 127.83 122.62 84.1 74.09 89.5 93.89 49.33 202.44 132.62 72.27 Blue crab 88.60 1901.05 620.48 2033.08 824.27 636.84 393.89 606.88 002.13 76.41 171.28 1895.82 694.73 797.66 640.45 Blueback herring 1.30 30.78 8.64 126.62 107.8 110.7 73.14 81.06 31.05 23.27 156.55 19.75 25.37 17.76 7.34 Bluefish 2.69 8.88 6.41 4.79 2.55 6

1.14 7.89 8.14 11.67 2.06 7.44 2.95 5.7 Spot 26.78 10.28 3.38 88.74 3.94 0.53 7.28 0.05 0.34 0.8 0.14 55.11 10.38 3.73 23.65 Striped bass 0.73 64.89 82.05 62.91 28.61 02.83 102.49 54.62 20.04 159.93 110.86 29.72 10.22 47.88 32.56 Weakfish 132.51 1071.27 441.89 1370.74 528.95 228.01 369.57 524.64 172.98 530.71 725.72 930.88 343.81 379.65 304.8 White perch 96.26 641.12 543.08 1625.16 425.98 384.33 273.32 263.56 427.71 1771.18 2113.19 1042.62 360.51 429.81 662.14 Source: Biological Monitoring Program Annual Reports (PSEGI 1996; PSEG, 1997; PSEG, 1998; PSEG, 1999b; PSEG, 2000; PSEG, 2001; PSEG, 2002; PSEG, 2003; PSEG, 2004a; PSEG, 2005; PSEG, 2006b; PSEG, 2007b; PSEG, 2008; PSEG, 2009c)

Impingement Reductions Due to the potential for impingement to have adverse effects on the aquatic environment in the vicinity of Salem, and in response to the requirements of the 1994 NJPDES permit, PSEG has taken steps to reduce impingement mortality and its effects in the Delaware Estuary. PSEG has made many improvements to the cooling water intake system at Salem over the years, including modifications to the intake screens and fish return system (PSEG, 1999a).

Improved intake screen panels that have a smooth mesh surface were installed to allow impinged fish to more easily slide across the panels. The Ristroph buckets and screen-wash system were modified to increase survival of impinged organisms. The new buckets are constructed from smooth, non-metallic materials and have several design elements that minimize turbulence inside the bucket, including a reshaped lower lip, mounting hardware located behind the screen mesh, a flow spoiler inside the bucket, and flap seals to prevent fish and debris from bypassing their respective troughs (PSEG 1999a). The screen wash system was redesigned to provide an optimal spray pattern using low-pressure nozzles to more gently remove organisms from the screens prior to use of high pressure nozzles that remove debris.

In addition, the maximum screen rotation speed was increased from 17.5 feet per minute (fpm) to 35 fpm to reduce the differential pressure across the screens during times of high debris loading. The screens are continuously rotated, and the rotation speed automatically adjusts as the pressure differential increases. The fish return trough was redesigned from the original rectangular trough to incorporate a custom formed fiberglass trough with radius rounded corners. The fish return system has a bi-directional flow that is coordinated with the tidal cycle to minimize re-impingement. The flow from the trough discharges to the downstream side of the cooling water intake system on the ebb tide and to the upstream side on the flood tide (PSEG, 1999a).

Estimates of impingement mortality with the modified screens were compared to estimated mortality with the original screens to assess the reduction in impingement mortality due to the screen modifications. Data from impingement studies conducted in 1995, 1997, and 1998 were used for this assessment of the modified screens. These data were compared to data collected in 1978 through 1982 when impingement survival studies were conducted for the original screen configuration. A side-by-side comparison also was conducted in 1995 when only one of the units had the modified intake system. Table 4-13 provides a comparison of estimated impingement mortality rates for the original screens versus the modified screens (PSEG, 1999a).

Results from the comparison of 1997 and 1998 data for the modified screens to data from 1978 to 1982 for the original screens indicate that the modified intake system provides reductions in impingement mortality. White perch, bay anchovy, Atlantic croaker, spot, and Alosa species (blueback herring, alewife, and American shad combined) had lower mortality rates for all months studied during the 1997 and 1998 studies compared to those estimated for the 1978 to 1982 study of the original screens. In contrast, weakfish had higher mortality rates for the modified screens in June and July, but lower in August and September. This difference may result from the much smaller size of the weakfish impinged in June and July - impingement mortality rates for smaller fish generally are higher than for larger fish (however, they are lower than estimated entrainment mortality rates, and the modifications to improve impingement survival increase this difference). "The 1995 side-by-side study showed higher survival rate estimates for weakfish with the modified screens (PSEG, 1999a).

Table 4-13. Comparison of Impingement Mortality Rates (percent) for Original Screens (1978-1982 and 1995 Studies) and Modified Screens (1995 and 1997-1998 Studies)

Original Screens Modified Screens Taxon Month 1978-1982 1995 1995 1997-1998 Weakfish June 39 33 17 79 July 51 31 18 82 August 52 51 25 38 September 40 12 October 53 White perch January 13 February 16 March 12 April 15 7

October 21 November 16 7

December 8

2 Bay anchovy April 54 May 81 55 June 89 78 July 90 80 August 85 September 72 October 65 35 November 32 28 Atlantic croaker April 42 May 34 June 28 July 35 October 5

November 2

Dec-Jan 49 15 Spot June 31 July 48 August 47 October 38 November 19 7

December 29 Alosa species Mar-Apr 89 18 Oct - Dec 31 22 Note: Mortality rate estimates for Alosa species for original screens are based on blueback herring only while estimates for modified screens are based on Alosa species (blueback herring, alewife, and American shad combined).

Estimates include initial and 48-hr latent mortalities.

]Source: PSEG, 1999a

INDICATE MEANING OF DASH.

4.5.4 Heat Shock (submitted previously)

References for Sections 4.5.2, 4.5.3, and 4.5.5 New Jersey Department of Environmental Protection. (NJDEP) 1994. Final NJPDES Permit Including Section 316(a) Variance Determination and Section 316(b) Decision, Salem Generating Station, NJ0005622. Trenton, NJ.

NJDEP 2001b. Final NJPDES Permit Including Section 316(a) Variance Determination and Section 316(b) Decision, Salem Generating Station, NJ0005622. Trenton, NJ. Issue Date: June 29, 2001.

PSEG Nuclear, LLC (PSGE). 1984. Salem Generating Station 316(b) Demonstration Project.

Newark, New Jersey, Public Service Enterprise Group. Publication date: February 1984.

PSEG 1994. Work Plan for the Biological Monitoring of the Delaware Estuary Under Salem's New Jersey Pollutant Discharge Elimination System Permit. Prepared for Public Service Electric and Gas Company Estuary Enhancement Program. Prepared by EA Engineering, Science, and Technology. October 1994.

PSEG 1996. 1995 Annual Report, Biological Monitoring Program, Public Service Electric and Gas Company, Estuary Enhancement Program. June 1996.

PSEG 1997. 1996 Annual Report. Biological Monitoring Program, Public Service Electric and Gas Company, Estuary Enhancement Program.

PSEG 1998. 1997 Annual Report. Biological Monitoring Program, Public Service Electric and Gas Company, Estuary Enhancement Program.

PSEG 1999a. Application for Renewal of the Salem Generating Station NJPDES Permit. Public Service Enterprise Group Publication date: March 4, 1999.

PSEG 1999b. 1998 Annual Report. Biological Monitoring Program, Public Service Electric and Gas Company, Estuary Enhancement Program.

PSEG 2000. 1999 Annual Report. Biological Monitoring Program, Public Service Electric and Gas Company, Estuary Enhancement Program.

PSEG 2001. 2000 Annual Report. Biological Monitoring Program, Public Service Enterprise Group, Estuary Enhancement Program.

PSEG 2002. 2001 Annual Report. Biological Monitoring Program, Public Service Enterprise Group, Estuary Enhancement Program.

PSEG 2003. 2002 Annual Report. Biological Monitoring Program, Public Service Enterprise Group, Estuary Enhancement Program.

PSEG 2004a. 2003 Annual Report. Newark, Biological Monitoring Program, Public Service Enterprise Group, Estuary Enhancement Program.

PSEG 2005. 2004 Annual Report. Biological Monitoring Program, Public Service Enterprise Group, Estuary Enhancement Program.

PSEG 2006a. Salem NJPDES Permit Renewal Application. NJPDES Permit No. NJ0005622.

Newark, New Jersey, Public Service Enterprise Group. Issue date: February 1, 2006.

PSEG 2006b. 2005 Annual Report. Biological Monitoring Program, Public Service Enterprise Group, Estuary Enhancement Program.

PSEG 2007b. 2006 Annual Report. Biological Monitoring Program, Public Service Enterprise Group, Estuary Enhancement Program.

PSEG 2008. 2007 Annual Report. Biological Monitoring Program, Public Service Enterprise Group, Estuary Enhancement Program.

PSEG 2009a. Salem Nuclear Generating Station Units 1 and 2, License Renewal Application, Appendix E: Applicant's Environmental Report - Operating License Renewal Stage. Lower Alloways Creek Township, New Jersey. August 2009.

PSEG) 2009b. Hope Creek Generating Station, License Renewal Application, Appendix E -

Applicant's Environmental Report - Operating License Renewal Stage. Lower Alloways Creek Township, New Jersey. August, 2009.

PSEG 2009c. 2008 Annual Report. Biological Monitoring Program, Public Service Enterprise Group, Estuary Enhancement Program.

4.5.4 Heat Shock Heat shock is defined as "acute thermal stress caused by exposure to a sudden elevation of water temperature that adversely affects the metabolism and behavior of fish and can lead to death" (NRC 2009). Heat shock can occur at power plants when the cooling water discharge elevates the temperature of the surrounding water.

The NRC considers heat shock to be a Category 1 issue at power plants with closed-cycle cooling systems. HCGS uses closed-cycle cooling; therefore, if NRC finds no new and significant information, site-specific evaluation is not required to determine that impacts to fish and shellfish from heat shock associated with the continued operation of HCGS during the renewal term would be SMALL.

In contrast, heat shock is a Category 2 issue at power plants with once-through cooling systems. Salem has a once-through cooling system; therefore, heat shock is considered a Category 2 issue for Salem, and a site-specific analysis is required to determine the level of impact that heat shock may have on the aquatic environment. The potential for heat shock at Salem is discussed below.

Re-gulatory Back-ground The Delaware River Basin Commission (DRBC) is a federal interstate compact agency charged with managing the water resources of the Delaware River Basin without regard to political boundaries. It regulates water quality in the Delaware River and Delaware Estuary through DRBC Water Quality Regulations, including temperature standards. The temperature standards for Water Quality Zone 5 of the Delaware Estuary, where the Salem discharge is located, state that the temperature in the river outside of designated heat dissipation areas (HDAs) may not be raised above ambient by more than 4°F (2.20C) during non-summer months (September through May) or 1.5°F (0.80C) during the summer (June through August), and a maximum temperature of 86°F (30.0*C) in the river cannot be exceeded year-round (DRBC 2001 and 2008). HDAs are zones outside of which the DRBC temperature-increase standards shall not be exceeded. HDAs are established on a case-by-case basis. The thermal mixing zone requirements and HDAs that had been in effect for Salem since it initiated operations in 1977 were modified by the DRBC in 1995 and again in 2001 (DRBC 2001), and the 2001 requirements were included in the 2001 NJPDES permit. The HDAs at Salem are seasonal. In the summer period (June through August), the Salem HDA extends 25,300 ft upstream and 21,100 ft downstream of the discharge and does not extend closer than 1320 ft from the eastern edge of the shipping channel. In the non-summer period (September through May), the HDA extends 3300 ft upstream and 6000 ft downstream of the discharge and does not extend closer than 3200 ft from the eastern edge of the shipping channel (DRBC 2001).

Section 316(a) of the Clean Water Act (CWA) regulates thermal discharges from power plants.

This regulation includes a process by which a discharger can obtain a variance from thermal discharge limits when it can be demonstrated that the limits are more stringent than necessary to protect aquatic life (33 USC 1326). PSEG submitted a comprehensive Section 316(a) study for Salem in 1974, filed three supplements through 1979, and provided further review and analysis in 1991 and 1993. In 1994, NJDEP granted PSEG's request for a thermal variance and concluded that the continued operation of Salem in accordance with the terms of the NJPDES permit "would ensure the continued protection and propagation of the balanced indigenous population of aquatic life" in the Delaware Estuary (NJDEP 1994). The 1994 permit continued the same thermal limitations that had been imposed by the prior NJPDES permits for Salem. This variance has been continued through the current NJPDES permit. PSEG

subsequently provided comprehensive Section 316(a) Demonstrations in the 1999 and 2006 NJPDES permit renewal applications for Salem. NJDEP reissued the Section 316(a) variance in the 2001 NJPDES Permit (NJDEP 2001b).

The Section 316(a) variance for Salem limits the temperature of the discharge, the difference in temperature (AT) between the thermal plume and the ambient water, and the rate of water withdrawal from the Delaware Estuary (NJDEP 2001b). During the summer period the I maximum permissible discharge temperature is 115°F. In non-summer months-months the maximum permissible discharge temperature is 110°F. The maximum permissible temperature differential year round is 27.50F. The permit also limits the amount of water that Salem withdraws to a monthly average of 3,024 MGD (NJDEP 2001b).

In 2006 PSEG submitted an NJPDES permit renewal application with a request for renewal of the Section 316(a) variance. The variance renewal request summarizes studies that have been conducted at the Salem plant, including the 1999 Section 316(a) Demonstration, and evaluates the changes in the thermal discharge characteristics, facility operations, and aquatic environment since the time of the 1999 Section 316(a) Demonstration. PSEG determined that Salem's thermal discharge had not changed significantly since the 1999 application and that the thermal variance should be continued. In 2006 NJDEP administratively continued Salem's NJPDES permit (NJ0005622), including the Section 316(a) variance. No timeframe has been determined for issuance of the new NJPDES permit.

Characteristics of the Thermal Plume Cooling water from Salem is discharged through six adjacent 10-ft-diameter pipes spaced 15 ft apart on center that extend approximately 500 ft from the shore (PSEG 1999). The discharge pipes are buried for most of their length until they discharge horizontally into the water of the esturary at a depth at mean tidal level of about 31 ft. The discharge is approximately perpendicular to the prevailing currents. Figure 4.5.4-1 provides a plan view of the Salem discharge, and Figure 4.5.4-2 is a section view. At full power, Salem is designed to discharge approximately 3200 million gallons per day (MGD) at a velocity of about 10 ft/s. The location of the discharge and its general design characteristics have remained essentially the same over the period of operation of the Salem facility.

The thermal plume at Salem can be defined by the regulatory thresholds contained in the DRBC water quality regulations consisting of the 1.5°F isopleth of 4T[ during the summern period and

-(... Comment [DL1]: Have we defined this?

the 4°F isopleth of AT during non-summer months. Thermal modeling to characterize the thermal plume has been conducted numerous times over the period of operation of Salem.

Since Unit 2 began operation in 1981, operations at Salem have been essentially the same and studies have indicated that the characteristics of the thermal plume have remained relatively constant.

The most recent thermal modeling was conducted during the 1999 Section 316(a)

Demonstration. Three linked models were used to characterize the size and shape of the thermal plume: an ambient temperature model, a far-field model (RMA-10), and a near-field model (CORMIX). The plume is narrow and approximately follows the contour of the shoreline at the discharge. The width of the plume varies from about 4000 feet on the flood tide to about 10,000 feet on the ebb tide. The maximum plume length extends to approximately 43,000 feet upstream and 36,000 feet downstream (PSEG 1999). Figures 4.5.4-3 through 4.5.4-6 depict the expansion and contraction of the surface and bottom plumes through the tidal cycle. Table

4.5.4-1 includes the surface area occupied by the plume within each AT isopleth through the tidal cycle.

The thermal plume consists of a near-field region, a transition region, and a far-field region. The near-field region, also referred to as the zone of initial mixing, is the region closest to the outlet of the discharge pipes where the mixing of the discharge with the waters of the Delaware Estuary is induced by the velocity of the discharge itself. The length of the near-field region is approximately 300 ft during ebb and flood tides and 1000 ft during slack tide. The transition region is the area where the plume spreads horizontally and stratifies vertically due to the buoyancy of the warmer waters. The length of the transition region is approximately 700 ft. In the far-field region, mixing is controlled by the ambient currents induced mainly by the tidal nature of the receiving water. The ebb tide draws the discharge downstream, and the flood tide draws it upstream. The boundary of the far-field region is delineated by a line of constant AT.

Table 4.5.4-1 Surface Area within Each AT Contour through the Tidal Cycle Ebb: 6/2/1998 at End 0830 hrs 6/2/1991 Percent Surface of Surface AT Area Estuary Area

(°F)

(Acres)

Area (Acres)

>13 0.08 0.00002 0.00

>12 0.46 0.00010 0.47

>11 0.98 0.00020 2.15

>10 1.66 0.00034 2.15 of Ebb:

at 0000 hrs Percent of Estuary Area 0.00000 0.00010 0.00045 0.00045 Flood: 6/4/1998 at 1630 hrs End of Flood:

5/31/1998 at 1600 hrs Percent of Surface Percent Surface Area of Estuary Area (Acres)

Area (Acres) 0.00 0.00000 0.00 0.21 0.00004 0.00 0.61 0.00013 0.00 1.15 0.00024 0.85 Estuary Area

>9 2.22 0.00046 2.15 0.00045 1.82 0.00038 1.93

>8 3.19 0.00066 2.15 0.00045 2.64 0.00055 1.93

>7 4.32 0.00090 5.10 0.00106 3.59 0.00075 1.93

>6 5.61 0.00116 11.32 0.00235 4.68 0.00097 1.93

>5 36.60 0.00760 21.43 0.00445 56.58 0.01174 2.14

>4 150.08 0.03115 45.11 0.00936 245.94 0.05105 205.37

>3 631.42 0.13106 739.88 0.15357 585.78 0.12158 920.75

>2 1947.91 0.40430 2519.94 0.52303 2212.75 0.45927 2093.04

>1.5 3156.56 0.65517 3725.19 0.77319 3703.61 0.76871 3596.95 0.00000 0.00000 0.00000 0.00018 0.00040 0.00040 0.00040 0.00040 0.00044 0.04263 0.19111 0.43442 0.74657 Notes:

Plant Conditions: Low flow (140,000 gpm/pump), high AT (18.6°F)

Total surface area of the estuary is 481,796 acres Reasonable worst-case tide phases were selected based on analysis of time-temperature curves.

Running tides (e.g., ebb and flood) include area approximation of the intermediate field.

Source: PSEG 1999 NEED A NOTE ON CONVERSION FACTOR FROM AC TO HA.

s.

AO Rik

-16.4

,21.4

,,i

-26.4.31.4 F-10 0.0.t wei p.ewd MtW Figure 4.5.4-1 Plan View of Salem discharge pipes (From PSEG 1999)

I I Z I I [

I I

I I

It~

Iia

-ii

• 1 a

jj I

b*

Figure 4.5.4-2 Section View of Salem discharge pipes (From PSEG 1999)

0z 400000U.

380000 38000'0 L 340000 320000 NJ o00000

/

200000 S

~F 260000 240000 ARTIFICIA SLAND 220000 O0000 180000 160000 12000CN fl"

10000D, 80000 60000 *--

60000 20000 0

1700000 18OouUc SC9 0 2IN WILES I 1900000 2000000 Eass1ng, feel (NJSPCS]

Figure 4.5.4-3 Surface AT isotherms for Salem's longest plume at end of flood on May 31, 1998 (From PSEG 1999)

z 40000 350000 360000 340000 320000 300000 28O0O0 280000 240000 220000 200000 180000 160000 DE 140000 120000 I00000 80000 60000 40000 20000 170D000 AR*

I

!rNJ I,

ARTIF ICIAL

. SLAND rail j.;

0 1600000 1900000 Easting, feet (NJSPCS)

Figure 4.5.4-4 Surface AT isotherms for Salem at end of ebb on June 2, 1998 (From PSEG 1999)

0 400000 D-O 380000 D 350000 340000 320000 300000 L--

280000 260000 240000 220000 200000 180000

• 140000 F 120000 100000 80000 W000o 40000 20000 1700000 0

lf K~ALE IN MILES 2000000 1800000 1900000 Easting, feel 4NJSPCS)

Figure 4.5.4-5 Bottom AT isotherms for Salem's longest plume at end of flood on May 31, 1998 (From PSEG 1999)

9cm 400000 380000..

3810000 340000 320000 300000 D 200000 240000 220000 200000 L 180000 160000 140000 120000 100000 80000 80000 40DCO 200C00 0'7000D0 ARFA J/

/

/

AR~nrIOLAL ISLAND MUM OF W

DE 0

0 m.

SCALE! IN MEE S

)D V900000 Eas~ing, feet (NJ SPCSý 2000000 Figure 4.5.4-6 Bottom AT isotherms for Salem at end of ebb on June 2, 1998 (From PSEG 1999)

Thermal Discharge Studies Extensive studies were conducted at Salem between 1968 and 1999 to determine the effects of the thermal plume on the biological community of the Delaware Estuary. Initial studies were conducted in 1968 to determine the location and design for the outfall that would best minimize the potential for adverse environmental effects. Several hydrothermal and biothermal studies subsequently have been conducted in support of requests for variance from thermal discharge limitations pursuant to Section 316(a). The Section 316(a) Demonstrations from 1974 through 1979 evaluated information on the life history, geographical distribution, and thermal tolerances of the representative important species (RIS) compared to the characteristics of the projected thermal plume. Supplements included information on the potential for Salem's thermal plume to promote the presence of undesirable organisms; use of the area in the vicinity of the Salem facility as spawning and nursery habitat; attraction of fish to the thermal plume and the potential for cold shock; effects of thermal plume entrainment on ichthyoplankton and zooplankton; effects of the plume on migration of anadromous fishes; and effects of the thermal plume on macroinvertebrates, such as blue crabs, oysters (Crassostrea virginica), and shipworms (Teredinidae), and other benthos (PSEG 1975).

In 1995, PSEG applied to the DRBC for revision of the Salem Docket to provide seasonal HDAs to assure compliance with DRBC's water quality regulations. PSEG used mathematical modeling and statistical analyses to characterize the maximum size of the summer thermal plume (June through August) and non-summer thermal plume (September through May) in terms of the 24-hr average AT between the thermal plume and ambient water temperatures.

PSEG also updated the information collected on the thermal tolerances, preferences, and avoidances of the RIS and conducted an evaluation of the potential for the thermal plume to have adverse effects on these species. The assessment indicated that Salem's thermal plume and the proposed HDAs would not have the potential to adversely affect aquatic life or recreational uses in the Delaware Estuary, and the DRBC granted the requested HDAs.

In 1999 PSEG submitted an application to renew the NJPDES permit for Salem, and the Section 316(a) Demonstration included provided another thermal plume characterization, biothermal assessment, and detailed analysis of the potential effects of Salem's thermal plume on the aquatic community. NJDEP reviewed this Section 316(a) Demonstration, determined that a "thermal discharge at the Station, which does not exceed a maximum of 115 °F, is expected to assure the protection and propagation of the balanced indigenous population," and included a Section 316(a) variance in Salem's 2001 NJPDES permit (NJDEP 2001b).

The 1999 Section 316(a) Demonstration includes the most detailed and most recent evaluation of the potential effects of the thermal discharge on the aquatic environment near Salem. This evaluation includes a four-part assessment of the potential for the discharge to negatively affect the balanced indigenous community of the Delaware Estuary, including consideration of the following factors: (1) the vulnerability of the aquatic community to thermal effects; (2) the potential for the survival, growth, and reproduction of the RIS to be affected; (3) the potential for effects of other pollutants to be increased by heat; and (4) evidence of prior appreciable harm from the thermal discharge (PSEG 1999).

Conclusions of the vulnerablity analysis indicate that the location and design of Salem's discharge minimize the potential for adverse environmental effects. The high exit velocity produces rapid dilution, which limits high temperatures to relatively small areas in the zone of initial mixing in the immediate vicinity of the discharge. Fish and other nektonic organisms are

essentially excluded from these areas due to high velocities and turbulence. The offshore location and rapid dilution of the thermal discharge also places the highest temperature plumes in an area of the Estuary where productivity is lowest (PSEG 1999).

The RIS evaluation in the 1999 Section 316(a) Demonstration included an assessment of the potential for the thermal plume to adversely affect survival, growth, and reproduction of the selected RIS. The RIS included alewife (Alosa pseudoharengus), American shad (Alosa sapidissima), Atlantic croaker (Micropogonias undulatus), bay anchovy (Anchoa mitchillh),

blueback herring (Alosa aestivalis), spot (Leiostomus xanthurus), striped bass (Morone saxatilis), weakfish (Cynoscion regalis), white perch (Morone americana), blue crab (Callinectes sapidus), opossum shrimp (Neomysis americana), and scud (Gammarus daiberi, G. fasciatus, G. tigrinus). For each of the RIS, temperature requirements and preferences as well as thermal limits were identified and compared to temperatures in the thermal plume to which these species may be exposed (PSEG 1999).

This biothermal assessment concluded that Salem's thermal plume would not have substantial effects on the survival, growth, or reproduction of the selected species from heat-induced mortality. Scud, blue crab, and juvenile and adult American shad, alewife, blueback herring, white perch, striped bass, Atlantic croaker, and spot have higher thermal tolerances than the temperature of the plume in areas where their swimming ability would allow them to be exposed. Juvenile and adult weakfish and bay anchovy could come into contact with plume waters that exceed their tolerances during the warmer months, but the mobility of these organisms is expected to allow them to avoid contact with these temperatures (PSEG 1999).

The biothermal assessment also concluded that less-mobile organisms, such as scud, juvenile blue crab, and fish eggs, would not be likely to experience mortality from being transported through the plume. American shad, alewife, blueback herring, white perch, striped bass, Atlantic croaker, spot, and weakfish are not likely to spawn in the vicinity of the discharge.

Scud, juvenile blue crab, and eggs and larvae that do occur in the vicinity of the discharge have higher temperature tolerances than the maximum temperature of the centerline of the plume in average years. Opossum shrimp, weakfish, and bay anchovy may experience some mortality during peak summer water temperatures in warm years (approximately 1 to 3 percent of the time) (PSEG 1999).

Interactions of heat with other pollutants were also evaluated in the 1999 Section 316(a)

Demonstration. The assessment concluded that the thermal plume has no observable effects on the dissolved oxygen level near the Salem discharge. In addition, the assessment indicates that there is no potential for plume interaction with other contaminants in the E-stuaFy-estuarv from other industrial, municipal, or agricultural sources such as PCB's, DDT, dieldrin, PAHs, PCE, DCE, and copper due to the low concentrations of such contaminants in the vicinity of Salem (PSEG 1999).

As part of the 1999 Section 316(a) Demonstration, an analysis of the biological community in the Delaware Estuary was conducted to determine whether there has been evidence of changes within the community that could be attributable to the thermal discharge at Salem.

PSEG concluded that observed changes in the species composition or overall abundance in organisms in the Estuary since Salem began operation are within the range expected to occur as a result of natural variation or changes in water quality. There were no indications of increases in populations of nuisance species or stress-tolerant species and there were statistically significant increases in the abundance of juveniles for almost all species of RIS

evaluated. A declining trend for blueback herring was determined to be a coast-wide trend and not related to Salem's operation (PSEG 1999).

Conclusions PSEG has conducted extensive studies of the thermal plume at Salem that have consistently demonstrated that the thermal discharge from operation of the Salem facility has not had a noticeable adverse effect on the balanced indigenous community of the Delaware Estuary in the vicinity of the outfall. The NRC staff considered the results of these studies, the fact that PSEG was granted a thermal variance in accordance with Section 316(a) of the CWA in 1994, and the fact that this variance remains a part of the current NJPDES permit, issued to PSEG in 2001 and administratively continued in 2006. The NRC staff concludes that impacts to fish and shellfish from heat shock at Salem during the renewal term would be SMALL and would warrant no additional mitigation.

References Delaware River Basin Commission (DRBC). 1970. Docket No. D-68-20 CP, Delaware River Basin Commission, Public Service Electric and Gas Company, Salem Nuclear Generating Station, Lower Alloways Creek Township, Salem County, NJ. October 27.

Delaware River Basin Commission (DRBC). 2001. Docket No. D-68-20 CP (Revision 2),

Delaware River Basin Commission, PSEG, Salem Nuclear Generating Station, Lower Alloways Creek Township, Salem County, NJ. September 18.

Delaware River Basin Commission (DRBC).

2008. Administrative Manual - Part Ill: Water Quality Regulations, with Amendments through July 16, 2008, 18 CFR Part 410. West Trenton, NJ. Printed September 12.

New Jersey Department of Environmental Protection (NJDEP). 1994. Final NJPDES Permit Including Section 316(a) Variance Determination and Section 316(b) Decision, Salem Generating Station, NJ0005622. Trenton, NJ.

New Jersey Department of Environmental Protection (NJDEP). 2001b. FinaINJPDES Permit Including Section 316(a) Variance Determination and Section 316(b) Decision, Salem Generating Station, NJ0005622. Trenton, NJ.

Issue date June 29.

Nuclear Regulatory Commission (NRC). 2009. Draft Generic Environmental Impact Statement for License Renewal of Nuclear Plants (NUREG-1437), Volumes 1 and 2, Revision 1.

Office of Nuclear Reactor Regulation. June 2009.

PSEG Nuclear, LLC (PSEG). 1975. A Report on the Salem Nuclear Generating Station, Artificial Island, Salem County, New Jersey. Supplement to Section 316(a),

Demonstration Type 3 (dated 18 September 1974). Newark, NJ. December 5.

PSEG Nuclear, LLC (PSEG). 1999. Application for Renewal of the Salem Generating Station NJPDES Permit. Publication date March 4.

4.5.5 p*o*mpa c

_qu atic* Resourcei The principal means by which the {Salem-facility ýnay_affect aquatic resources of the Delaware Estuary are the processes of entrainment and impingement of organisms at the cooling water intake and the discharge of thermal effluent. These processes simultaneously and cumulatively affect the aquatic community of the estuary, so assessment of their collective impacts is warranted. Because the Salem facility has been operating for more than 30 years, the total impacts of its operation are integrated and reflected in the condition of the ecosystem of the estuary. By evaluating total impacts from the historical, long-term operation of the facility and the beneficial effects of ongoing restoration activities, total impacts on the estuary from future operation during the relicensing period can be assessed.

Impact Assessment As part of the 2006 NJPDES application, PSEG prepared an assessment of Adverse Environmental Impact for the Salem facility that analyzed the composition of the fish community in the vicinity, trends in the relative abundance of the RS, and the long-term sustainability of fish stocks in the estuary. The assessment demonstrated that the Salem cooling water intake system has not caused and is unlikely to cause in the future substantial harm to the sustainability of populations of important aquatic species, including threatened or endangered species, or to the structure and function of the ecosystem in the Delaware Estuary (PSEG, 2006a).

Estimates of production lost due to impingement and entrainment at Salem were calculated for the 13 RS, or target species, of PSEG's monitoring program (i.e., American shad, alewife, Atlantic croaker, bay anchovy, blueback herring, spot, striped bass, weakfish, white perch and blue crab, plus Atlantic menhaden, Atlantic silverside, and bluefish). These species make up more than 98 percent of the age-0 biomass lost to impingement and entrainment. Production lost was calculated using data on biomass lost to impingement and entrainment from 2002 through 2004 and adding a projected production foregone for those organisms through the first year of life. Production foregone was projected using literature estimates of growth rates.

Biomass lost to impingement and entrainment was estimated to be 138,057 lbs wet weight/yr.

Production forgone was estimated to be 4,664,837 lbs wet weight/yr. Production lost was therefore estimated to be 4,802,894 lbs wet weight/yr. Production lost was also calculated separately for river herring to facilitate direct comparisons of loss to production gained from restoration activities (fish ladders). The production of river herring lost to impingement and entrainment was estimated to be 6,093 lbs wet weight/yr (PSEG, 2006a).

Data on the composition of the fish community in the Delaware Estuary over the period from 1970 through 2004 were analyzed for species richness and species density. Species richness is defined as the number of different species present in a community regardless of area analyzed, and species density is the number of species per unit of area or volume. Nearfield sampling using a 16 ft bottom trawl was conducted in most years since 1970. Data from 1970 to 1977, the pre-operational period, was compared to data from 1986 to 2004, the operational period. Both species richness and species density are generally higher in the 1986 to 2004 data than the 1970 to 1977 data, but there is no evident long-term trend in species richness or species density in the vicinity of Salem (PSEG, 2006a).

Abundance data for the RS at Salem kwere evalua-ted to determine whether long-term population trends exist. Several monitoring programs Ihave been-cnducted1in the Delaware Estuary for

-- comment [DLI]: Much of this section is about field studies, which implicitly include the effects of both Salem and Hope Creek.

We need to discuss this.

I Also this section has a lot of passive voice, unknown actors, etc., and needs serious editing.

Comment [DL2]: We have to say something about Hope Creek as well.

i Comment [DL3]: By whom? ACTIVE I VOICE I

Comment [DL4]: By whom? Active voice

many years. Data from four monitoring 5rog6rams were used for the lanalysis of trends: the Comment [DL5]: By whom? Active Voice.

DNREC Juvenile Trawl Survey, the NJDEP Beach Seine Survey, the PSEG Bay-wide Bottom Trawl Survey, and the PSEG Beach Seine Survey.

Results naýlysisndicate that seven s pecies (alewife, American shad_ Atlantic croaker, blue crab, striped bass, weakfish, and white perch) have increased in abundance, one species has shown declines (spot), and the remaining four species (Atlantic menhaden, Atlantic silversides, bay anchovy, and blueback herring) show no clear long-term trends (PSEG, 2006a).

Spot is the only species lhat-wa-s-sho-wn o have appareent long-term declines in abundance in the Delaware Estuary over the period of operation of Salem. However, this speciesi.!so-* has e inin the ChesapeakeBqay since the 1970sindicatn that its decline-is widespread and not due to the operation of Salem.

PSE&G (2006a) performed a stock jeopardy analysis to determine whether Salem has an impact on the long-term sustainability of fish stocks. The models used in this analysis ýv-aluate_

the effect of impingement and entrainment losses on spawning stock biomass (SSB) and spawning stock biomass per recruit (SSBPR). These metrics are commonly used by fisheries managers to establish maximum fishing rates for managed fish populations. The ýtock jeopardy

!Sc_ _mpared estimated impacts of Salem on these metrics with the impacts 0ffishingon the same metrics. PSE&G (2006a) concludedThe analyri6s cncu!-- dod that for those species analyzed the effects of impingement and entrainment are negligible compared to the effects of fiehi*g, and-fishinf and that reducing or eliminating impingement and entrainment at Salem would not measurably increase the reproductive potential or spawning stock biomass of any of these specie. (PS-EG 2006a)-

Restoration In addition to the changes in technology and operations of the Salem facility, PSEG has implemented restoration activities that enhance the fish and shellfish populations in the Delaware Estuary. In compliance with Salem's 1994 and 2001 NJPDES permits PSEG implemented the Estuary Enhancement Program (EEP), which has preserved and/or restored more than 20,000 ac of wetland and adjoining upland buffers (PSEG, 2009a).

--Comment

[DL6]: Whose analyses?

Comment [DL7]: By whom. Also bad grammar.

-- -Comment

[DL8]: According to whom?

- -[ Comment [DL9]: assess?

Comment [DLI0]: Where did this come from. I don't think this is a common tool. I In particular, 4,400 acres of formerly diked salt hay farms were restored to reestablish conditions suitable for the growth of low marsh vegetation such as saltmarsh cord grass (Spartina alterniflora) and provide for tidal exchange with the estuary. These restored wetlands increase the production of fish and shellfish by increasing primary production in the detrital based food web in the Delaware Estuary. Both primary and secondary consumers benefit from this increase in production, including many of the RS at Salem. PSEG (2006a) estimated the increase in production of secondary consumers due to this restoration to be at least 18.6 million lbs y*-*Eý_--.QQa.

These secondary consumers include species of fish and shellfish Comment [DLI 1]: When you do edits, affected by impingement and entrainment at Salem, as well as other species, add International Units.

The EEP also included the installation of 13 fish ladders at impoundments in New Jersey and Delaware (PSEG, 2009a). The fish ladders eliminate blockages to spawning areas for anadromous fish species such as alewife and blueback herring (both RS at Salem). Fish ladders were constructed in New Jersey at Sunset Lake, Stewart Lake (two ladders), Newton Lake and Cooper River Lake, and in Delaware at Noxontown Pond, Silver Lake (Dover), Silver Lake (Milford), McGinnis Pond, Coursey Pond, McColley Pond, Garrisons Lake, and Moore's Lake (PSEG, 2009a). Most anadromous fish exhibit spawning site fidelity, returning to the same areas where they hatched to spawn. Therefore, PSEG undertook a stocking program that

transplanted gravid adults into the newly accessible impoundments to induce future spawning runs (PSEG, 2009a).

Along with the active restoration programs described above, ý6lh-E-EEP-hasp-rovilded[funding_for many other programs in the area, including some managed by NJDEP and the Delaware Department of Natural Resources and Environmental Control (DNREC). Examples of these funded programs are restoration of three areas in Delaware dominated by common reed (Phragmites australis), State-managed artificial reef programs, revitalization of 150 ac of State-managed oyster habitat, and restoration of 964 ac of degraded wetlands at the Augustine Creek impoundment (PSEG, 2009a).

Comment [DL12]: pse&g provided the

/ funding thgough the eep, no. Make sure

/ you accurately express the actors in the sentences.

A requirement of the 2001 NJPDES permit for Salem was to evaluate and quantify the increased production associated with PSEG's restoration activities and compare it to the production lost due to entrainment and impingement at the facility. Section 7 of the 2006 permit renewal application (PSEG, 2006a) includes this assessment. Estimates of increased production associated with the restoration of the three salt hay farms and 12 fish ladder sites were included in this evaluation. The restoration of marshes dominated by common reed, upland buffer areas, and artificial reefs *ere not lincludedin this evaluation..................

I Comment [DL1 3]: active voice please PSEG (2006a) used an Aggregated Food Chain Model (AFCM) to estimate the annual production (lbs wet weightlyr) of secondary consumers attributable to the restoration of the salt hay farm sites-(PSEaG,2006a). This method used data for the biomass of above-ground vegetation collected during the annual monitoring from 2002 through 2004 to estimate primary production (production of above-ground marsh vegetation). This primary production was then converted to production of secondary consumers through three trophic transfers: vegetation to detrital complex (dissolved and particulate organic matter, bacteria, fungi, protozoa, nematodes, rotifers, copepods, and other microscopic organisms) to primary consumers (zooplankton and macroinvertebrates) to secondary consumers (age-0 fish).

This method ýinderestimatefs the

_totalproduction that could be attributed to the salt hay marsh_....

Comment [DL14]: Our observation or restoration in that it does not include below-ground production or recycled production someone elses? ACTIVE VOICE (production attributable to consumption of a secondary consumer by a primary consumer). *--he_

- - Comment [DLI5]: Should this be "PSEG roduction of secondary consumers attributable to the restoration of the salt hay marsh sites (2008) estimates..." Did PSEG do the weo be 1122_8,415 bs wet weiIht/vr CPSEG, 2006a work or their consultants, If the latter, 2841.lb. we.we.htyr..SE....a.--

shouldn't we be citing them?

Annual production of river herring (blueback herring and alewife) attributable to the installation Comment [DL16]: by whom of fish ladders Iwaýesimatý-ecdl-sing results from surveys_ ofjuvenile fish in the impoundmments_......

Comment [DL17]: by whom? These are which were then converted to weight using an age-1 average weight. The production of river only summarized in PSEG 2006, no? who herring due to the fish ladders east(i2mnated fto be_944lbs wet weig9ht/yr CPSEG 2006a.

did the studies?

Comment [DL18]: by whom?

The increase in production attributable to the salt hay farms isestimated lo be 2.3 times the......

Comment [DL19]: by whom. not by us.

annual production lost from impingement and entrainment at Salem. The installation of fish ladders at 12 impoundments in New Jersey and Delaware is estimated fro be 1/6 of the.

Comment [DL20]: by whom? ACTIVE production of river herring lost to impingement and entrainment at the facility.

VOICE Conclusions Entrainment, impingement, and heat shock all affect the aquatic resources of the Delaware Estuary. PSEG has conducted extensive studies of the effects of entrainment (Section 4.5.2) and impingement (Section 4.5.3) at Salem over the more than 30-yr period during which it has been operating, and the effects of the thermal discharge similarly have been extensively studied

(Section 4.5.4). Multiple long-term, large-scale studies of the estuary by PSEG and State and Federal agencies have documented the ecological condition of the estuary through time and allowed the analysis of long-term trends in populations of RS. The studies have deonstrateci L C

Comment [DL21]: concluded, no?

that these processes of entrainment, impingement, and thermal discharge collectively have not had a noticeable adverse effect on the balanced indigenous community of the Delaware Estuary in the vicinity of Salem according those authors' definitions of adverse effect. -

The NRC staff considered the results of these studies, the fact that PSEG was granted a thermal variance in accordance with Section 316(a) of the CWA in 1994, and the fact that this variance remains a part of the current NJPDES permit, issued to PSEG in 2001 and administratively continued in 2006. The NJDEP, not the NRC, is responsible for issuing and enforcing NPDES permits. NRC assumes that NJDEP will continue to apply the best information available to the evaluation and approval of future NPDES permits. The NRC staff concludes that impacts to fish and shellfish from entrainment, impingement, and heat shock at Salem during the renewal term would be SMALL and would not warrant additional mitigation beyond the EEP.

4.7 Threatened or Endangered Species Potential impacts to threatened or endangered species are listed as a Category 2 issue in 10 CFR Part 51, Subpart A, Appendix B, Table B-I. The GElS section and category for this issue are listed in Table 4.7-1.

Table 4.7-1. Category 2 Issues Applicable to Threatened or Endangered Species During the Renewal Term Issue GElS Section Category Threatened or endangered species 4.1 2

This site-specific issue requires consultation with appropriate agencies to determine whether threatened or endangered species are present and whether they would be adversely affected by continued operation of the nuclear facility during the license renewal term. The presence of threatened or endangered species in the vicinity of the site of the Salem and HCGS facilities is discussed in Sections 2.2.7.1 and 2.2.7.2. In 2009, the NRC staff contacted the National Marine Fisheries Service (NMFS) and U.S. Fish and Wildlife Service (FWS) to request information on the occurrence of threatened or endangered species in the vicinity of the site and the potential for impacts on those species from license renewal. NMFS identified in its response a species federally listed as endangered, the shortnose sturgeon (Acipenserbrevirostrum), and a candidate species, the Atlantic sturgeon (Acipenser oxyrinchus oxyrinchus), as having the potential to be affected by the proposed action (NMFS 2010a). Additionally, NMFS identified four Federally listed sea turtle species, the threatened loggerhead (Caretta caretta), and the endangered Kemp's ridley (Lepidochelys kempi), green (Chelonia mydas), and leatherback (Dermochelys coriacea), as having the potential to be adversely affected by the proposed action. These six species, their habitats, and their life histories are described in Section 2.2.7.1.

In correspondence between FWS and PSEG prior to the NRCs request for information on Federally listed species potentially affected by the proposed action, FWS indicated that there were no Federally listed species under its jurisdiction present on the Salem and HCGS site.

FWS did identify two species Federally listed as threatened that potentially could occur along the transmission lines: the bog turtle (Clemmys muhlenbergih) and swamp pink (Helonias bullata) (FWS 2009a).

The NRC staff has prepared a Biological Assessment (BA) for NMFS that documents its review of the potential for the proposed action to affect the Federally listed species under the jurisdiction of NMFS. The BA is provided in Appendix D of this draft SEIS. During informal consultation with FWS regarding the potential for effects on terrestrial threatened or endangered species, the staff determined that a BA for FWS was not needed because there was no likelihood of adverse effects on potentially occurring Federally listed species under the jurisdiction of FWS.

4.7.1 Aquatic ThrcFatcnd or Endk.ngcrcd Species of Special Concern in the Delaware Com ment [DTL1t

.]: Atlantic sturgeon Is neither threatened nor endangered, but we must and do Pcdiscuss It because It Is a candidate for listing.

Pursuant to consultation requirements under Section 7 of the Endangered Species Act of 1973 Therefore, the present section heading Is the NRC staff requested in a letter to NMFS dated December 23, 2009 (NRC 2009) that NMFS inaccurate.

provide information on federally listed endangered or threatened species, as well as proposed or candidate species. In its response on February 11, 2010, NMFS stated that the shortnose sturgeon, the Atlantic sturgeon, and four sea turtle species are known to occur in the Delaware River and estuary in the vicinity of Salem and HCGS, and that no critical habitat is currently designated by NMFS near these facilities (NMFS 2010a).

Consultation between NMFS and NRC with regard to the cooling water intake system (CWIS) for Salem and HCGS has been ongoing since before each facility began operation. In 1980, a Biological Opinion issued by NMFS concluded that the continued operation of these facilities was not likely to jeopardize the shortnose sturgeon. After sea turtles were impinged on the intake trash bars at the Salem facility, consultation was reinitiated in 1988 to evaluate the effects of these takes on the sea turtle species involved. (Takes are considered to include mortalities as well as turtles that are impinged but removed alive and released.) In 1991, NMFS issued a Biological Opinion thatwhiGh found that continued operation of Salem and HCGS would affect threatened or endangered sea turtles but was not likely to jeopardize any populations-al and issued an incidental take statement-was-4sued for Kemp's ridley, green, and loggerhead turtles and shortnose sturgeon. The number of turtles impinged in 1991 was unexpectedly high, exceeding the incidental take allowed and resulting in additional consultation. AR opiiose lin 1992 NMFS revised the incidental take statement. The impingement of sea turtles exceeded the allowable take in 1992 as well, prompting additional consultation with NMFS (NMFS 1999 and 2010b). A 1993 Biological Opinion required the tracking of all loggerhead sea turtles taken at the CWIS. Also in 1993, PSEG implemented a policy of removing the ice barriers from the trash racks on the intake structure during the period between May 1 and October 24, which resulted in substantially lower turtle impingement rates at Salem (one in 1993 and one in 1995).

In 1999, NRC requested that these studies be eliminated due to the reduction in the number of turtles impinged after the 1993 change in procedure regarding the removal of ice barriers.

NMFS responded in 1999 with a letter and an incidental take statement stating that these studies could be discontinued because it appeared that the reason for the relatively high impingement numbers previously was the ice barriers that had been left on the intake structure during the warmer months (NMFS 1999). This letter allowed an annual incidental take of 5 shortnose sturgeon, 30 loggerhead sea turtles, 5 green sea turtles, and 5 Kemp's ridley sea turtles. In addition, the statement required ice barrier removal by May 1 and replacement after October 24, and it required that in the, warmer months the trash racks must be cleaned weekly and inspected every other hour, and in the winter they should be cleaned every other week.

The statement requires that if a turtle is killed, the racks must be inspected every hour for the rest of the warm season. Dead shortnose sturgeon are required to be inspected for tags, and live sturgeon are to be tagged and released (NMFS 1999).

No threatened or endangered species have been impinged at the Hope Creek intake structure, and NMFS does not require monitoring beyond normal cleaning operations for Hope Creek (NMFS 1993). Table 4.7-2 summarizes information on the incidental take by impingement at the Salem intakes of sturgeon and sea turtles during the monitoring period 1978 -2008.

The NRC staf e-valuated the potential effects of entrainment, impingement, and thermal ------

Comment [DTL12]: Could we use a more discharges on these and other important species in Sections 4.5.2, 4.5.3, and 4.5.4. Based on precise word here?

an evaluation of entrainment data provided by PSEG, *here is no evidence 1hkat the eggs or,

- - -- comment [DTL13]: Whose opinion is this.

larvae of either sturgeon species are commonly entrained at Salem and HCGS. Neither of the PSEG's, NRC's, or NMFS's. And also give reference.

sturgeon species is on the list of species that has been collected in annual entrainment monitoring during the 1978 -2008 period (Table 4.5-6). The life histories of these sturgeon, described in Section 2.2.7.1, suggest that entrainment of their eggs or larvae is unlikely.

Shortnose sturgeon spawn upstream in freshwater reaches of the Delaware River and are most abundant between Philadelphia and Trenton. Their eggs are demersal and adhere to the

substrate, and thek-juvenile stages tend to remain in freshwater or fresher areas of the estuary for 3 to 5 years before moving to more saline areas such as the nearshore ocean. Thus, shortnose sturgeon eggs or larvae are unlikely to be present in the water column at the Salem or HCGS intakes well downstream of the spawning areas. Similarly, the life history of the Atlantic sturgeon makes entrainment of its eggs or larvae very unlikely.

Impingement data pr.vid. d by the appic"ant uggost that _Bboth sturgeon species and three of the four turtle species have been impinged at Salem (Table 4.7-2). Atlantic sturgeon were collected in impingement studies in a single year, 2006 (PSEG biological monitoring reports 1995-2006). Impinge.mnt data foar the shortnoco turgcon showv that fFrom 1978 to 2008, 18 shortnose sturqeon4-eh were impinged at the Salem intakes, of which 16 died. Between 1978 and 2008, 24 Kemp's ridley sea turtles were impinged, of which ten died. Three green turtles (one died) and 68 loggerhead turtles (25 died) also were impinged. Impingement of the turtles was greatest in 1991 and 1992 (Table 4.7-2). After PSEG modified its use of the ice barriers in 1993, turtle impingement numbers returned to levels much lower than in 1991. From 1994 through 2008, theer wee Salem impinged six sea turtles-i

• ed (all loggerheads), and four of these died. Also during this 15-yr period, 11 shortnose sturgeon were impinged, of which eight died.

Table 4.7-2. Impingement data for shortnose sturgeon and three sea turtle species with recorded impingements at Salem intakes, 1978-2008.

Year Impingement Numbers by Species"'

Shortnose Kemp's ridley sea Green sea Loggerhead sea sturgeon turtle turtle turtle 1978 2(2) 0 0

0 1979 0

0 0

0 1980 0

1 1

2(2) 1981 1 (1) 1 (1) 0 3(2) 1982 0

0 0

1 (1) 1983 0

1 (1) 0 2(2) 1984 0

1 0

2(2) 1985 0

2(1) 0 6(5) 1986 0

1 (1) 0 0

1987 0

3(1) 0 3

1988 0

2(1) 0 8(6) 1989 0

6(2) 0 2

1990 0

0 0

0 1991 3(3) 1 1

23(1) 1992 2(2) 4(2) 1 (1) 10 1993 0

1 0

0 1994 2(2) 0 0

1 1995 0

0 0

1 (1) 1996 0

0 0

0 1997 0

0 0

0 1998 3(1) 0 0

1 (1) 1999 1

0 0

0

Year Impingement Numbers by Species"'

Shortnose Kemp's ridley sea Green sea Loggerhead sea sturgeon turtle turtle turtle 2000 1 (1) 0 0

2(1) 2001 0

0 0

1 (1) 2002 0

0 0

0 2003 1 (1) 0 0

0 2004 1 (1) 0 0

0 2005 0

0 0

0 2006 0

0 0

0 2007 1 (1) 0 0

0 2008 1 (1) 0 0

0 Total 18(16) 24(10) 3(1) 68(25)

(1) Numbers in parentheses indicate the number of individuals out of the yearly total shown that were either dead when found at the intakes or died afterward. Impingements of Atlantic sturgeon or leatherback sea turtles were not reported in the data on which this table was based.

Source: PSEG (2010).

Section 4.5.4 discusses The-potential impacts of thermal discharges on the aquatic biota of the Delaware Estuary as di'*c.*crucd in Section 4.6.4, and NRC staff expect impacts on fish and invertebrates, including those preyed upon by sturgeon and sea turtles, afe-ex-peted-to be minimal. The high exit velocity of the discharge produces rapid dilution, which limits high temperatures to relatively small areas in the zone of initial mixing in the immediate vicinity of the discharge. Fish and many other organisms are largely excluded from these areas due to high velocities and turbulence. Shortnose and Atlantic sturgeon and the four sea turtle species have rvefy-little potential to experience adverse effects from exposure to the temperatures at the discharge because of their life history characteristics and their mobility. Sturgeon spawning and nursery areas do not occur in the area of the discharge in the estuary, and adult sturgeon forage on the bottom while the buoyant thermal plume rises toward the surface. Sea turtles prefer warmer water temperatures, occur in the region only during warm months, and are unlikely to be sensitive to the localized area of elevated temperatures at the discharge. NMFS (1993) considered the possibility that the warm water near the discharge could cause sea turtles to remain in the area until surrounding waters are too cold for their safe departure in the fall, but it concluded that this scenario was not supported by any existing data (4MF.S 4Q99).

{The-NRC staff reviewed information from the site audit, the applicant's Environmental Reports for Salem and HCGS, biological monitoring reports, other reports, and coordination with NMFS, FWS, and State regulatory agencies in New Jersey and Delaware regarding listed species, The NRC staff concludes that the impacts on federally listed threatened or endangered aquatic

,pecies of the Delaware Estuary during an additional 20 years of operation of the Salem and HCGS facilities would be SMALL.I.

4.7.2 Terrestrial and Freshwater Aquatic ISpecial Statusl Threatened Or Endangered Species Two Federally-listed terrestrial or freshwater aquatic species that are Fdrderall; listed have the peteRtt ate-Might occur near the Salem and HCGS facilities and their associated transmission line ROWs are;- the bog turtle and swamp pink. Section 2.2.7.2 discusses-T-he characteristics,

-.-- Comment [DTL14]: The above does not really discuss Hope Creek and should do so.

We also need to say that the appendix contains

\\

NRC's biological assessment.

Comment [DTL15]: We discuss state species here as well as Federally-listed endangered and threatened species.

habitat requirements, and likelihood of occurrence of these species Are discussed in Soction 2.2-..2. Coordination correspondence between PSEG (dates) and FWS (2009a) ndicate Ithat no Federally listed species occur on the site of the Salem and HCGS facilities, but that the bog turtle and swamp pink potentially could occur within the transmission line ROWs (FWS 2009a).

FWS coordinated with PSEG to review all of its transmission line spans in New Jersey and transmitted to PSEG the known locations of the presence or potential presence of Federally listed species along each span. FWS (2009a) also recommended to PSEG conservation measures for each Federally listed species that potentially could occur along its transmission line spans (FWS 2009a). In October 2009, PSEG (2009) confirmed to FWS its commitment to protecting both Federally and State listed threatened or endangered species along PSEG transmission line ROWs-afid-tand adopted the conservation measures recommended by FWS for each species-(PSEG 2009). Based on PSEG's adoption of these conservation measures, FWS in November 2009 concurred that "continued vegetation maintenance activities within the transmission system are not likely to adversely affect federally listed or candidate species."

ýFWS 2009b)6 Thus, the Federally listed species potentially occurring in the transmission line_

ROWs for Salem and HCGS in New Jersey would not be adversely affected by future -

vegetation maintenance activities. The FWS New Jersey Field Office also coordinated with the FWS Chesapeake Bay Field Office regarding the transmission line ROW from HCGS that crosses the river and traverses New Castle County in Delaware. FWS (2009b) concluded that

.no proposed or federally listed endangered or threatened species are known to exist" within that ROW area-(W-,AS2009b).

The ROW maintenance procedures agreed upon for protection of the bog turtle-i eh include u-of a-cýtifiedb og turtle surveyor to examine spans containing known or potential habitat, to flag areas of potential habitat plus a 150-ft buffer, and to be on site during maintenance activities in flagged areas; performance of maintenance activities by hand in flagged areas, including selective use of specific herbicides; no use of herbicide in known nesting areas, which include all flagged areas around extant occurrence;triming restrictions to avoid disturbance during nesting season; and provision of the surveyor's reports to FWS (PSEG 2009). The ROW maintenance procedures agreed upon forprotection of the swamp pink ialud-. include use of 4a qualified botanist to survey suitable forested wetland habitat on and adjacent to the ROW for

.the plant; flagging of a 200-ft radius area around any identified populations of swamp pink; avoidance of any maintenance activities within the flagged lareas without FWS apprroval_.......

limitation of herbicide use within 500 ft of a population to manual applications to woody stumps only; and provision of the surveyor's reports to FWS (PSEG 2009).

The NRC staff reviewed information from the site audit, Environmental Reports for Salem and HCGS, other reports, and coordination with FWS and State regulatory agencies in New Jersey and Delaware regarding listed species. The NRC staff concludes that the impacts on Federally listed terrestrial and freshwater aquatic species from an additional 20 years of operation and maintenance of the Salem and HCGS facilities and associated transmission line ROWs would be SMALL.

References:

Delaware Department of Natural Resources and Environmental Control (DNREC). 2009. Letter from E. Stetzar, biologist/environmental review coordinator, Natural Heritage and Endangered Species, Division of Fish and Wildlife, to E. J. Keating, PSEG Nuclear LLC. Letter responded to request from PSEG for information on rare, threatened, and endangered species and other significant natural resources relevant to operating license renewal for Salem and HCGS, and it specifically addressed the ROW alignment extending from Artificial Island, NJ across the

- - Comment [DTL16]: No?

I

ý Comment [DTL17]: Where does this go?

- Comment [DTL18]: Make the construction of items in this list parallel.

I Comment [DTL19]: Make construction of items 1 I In this list parallel.

I

Delaware River to end in New Castle County, DE. April 21. Copy of letter provided in Appendix C of Applicant's Environmental Report for Salem (PSEG 2009a).

PSEG Nuclear, LLC (PSEG). 2009a. Salem Nuclear Generating Station, Units 1 and 2, License Renewal Application, Appendix E - Applicant's Environmental Report - Operating License Renewal Stage. Lower Alloways Creek Township, New Jersey. August, 2009.

ADAMS Nos. ML092400532, ML092400531, ML092430231.

National Marine Fisheries Service (NMFS). 1993. Biological Opinion, Endangered Species Act Section 7 consultation with the Nuclear Regulatory Commission regarding the Salem and Hope Creek Nuclear Generating Stations in Salem, NJ. NMFS Northeast Regional Office, Silver Spring, MD.

National Marine Fisheries Service (NMFS). 1999. Letter to Thomas H. Essig, Acting Chief, Generic Issues and Environmental Projects Branch, Division of Nuclear Reactor Program Management, Office of Nuclear Reactor Commission, regarding consultation and biological opinion on the operation of Salem and HCGS and endangered and threatened species.

OFFICE.

National Marine Fisheries Service (NMFS). 2010. Letter to Bo Pham, Chief, Project Branch 1.

Division of License Renewal, Office of Nuclear Reactor Regulation, regarding information on the presence of species listed as threatened or endangered by NOAA's National Marine Fisheries Service in the vicinity of Salem and Hope Creek generating stations. OFFICE.

New Jersey Department of Environmental Protection (NJDEP). 2008. Letter from H. A. Lord, data request specialist, Natural Heritage Program, to L. Bryan, Tetra Tech NUS, Inc. Letter responded to request for rare species information for the Salem and HCGS site and transmission line ROWs in Camden, Gloucester, and Salem Counties. 1OFFICI (Comment [DTL11O]: Etc....

New Jersey Department of Environmental Protection (NJDEP). 2009. Letter from C. D.

Jenkins, Chief, Endangered and Nongame Species Program, to E. J. Keating, PSEG Nuclear LLC, Hancocks Bridge, NJ. Letter responded to request from PSEG for information on listed species or critical habitat at the Salem and Hope Creek Generating Stations and along associated transmission corridors. April 2.

PSEG Nuclear, LLC. 2009. Letter from PSEG, Newark, NJ to W. Walsh, U. S. Fish and Wildlife Service, New Jersey Field Office, Pleasantville, NJ regarding PSEG freshwater wetlands permit no. 000-02-0031.2 and endangered species compliance during electric transmission right-of-way vegetation maintenance activities.

PSEG Nuclear, LLC. 2010. Tables summarizing impingement data for shortnose sturgeon, Atlantic sturgeon, and loggerhead, green, and Kemp's ridley sea turtles. Provided by PSEG on May 3 in response PSEG-4 to NRC request for additional information (RAI) dated April 16, 2010.

U.S. Fish and Wildlife Service (FWS). 2009a. Letter from New Jersey Field Office, Pleasantville, NJ to E. J. Keating, PSEG Nuclear LLC, Hancocks Bridge, NJ in response to PSEG request for information on the presence of federally listed endangered and threatened species in the vicinity of the existing Salem and Hope Creek Generating Stations located on Artificial Island in Lower Alloways Creek Township, Salem County, NJ. September 9.

U.S. Fish and Wildlife Service (FWS). 2009b. Letter from New Jersey Field Office, Pleasantville, NJ to R. A. Tripodi, Manager, Corporate Licenses and Permits, PSEG Services Corporation, Newark, NJ in response to PSEG letter of October 23, 2009 confirming commitment by PSEG to ROW vegetation maintenance procedures protective of listed species and recommended by FWS. November 4.

U.S. Nuclear Regulatory Commission (NRC). 2009. Letter to NMFS regarding: Request for List of Protected Species within the Area Under Evaluation for the Salem and Hope Creek Nuclear Generating Stations License Renewal Application Review.