ML11348A341
| ML11348A341 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/14/2011 |
| From: | State of NY |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 21541, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 NUREG-1437, S38 | |
| Download: ML11348A341 (180) | |
Text
NYS00132B Submitted: December 14, 2011 Plant and the Environment 1 April 16, 2007. Accessed at http://ecos.fws.gov/docs/candforms_pdf/r5/A09B_V01.pdf on 2 March 10, 2008.
3 Fish and Wildlife Service (FWS). 2008a. Significant Habitats and Habitat Complexes of the 4 New York Bight Watershed. Lower Hudson River Complex #21. Accessed at 5 http://training.fws.gov/library/pubs5/webJinkitextllow_hud.htm on February 23,2008. ADAMS 6 No. ML083390034.
7 Fish and Wildlife Service (FWS). 2008b. "Westchester County Federally Listed Endangered 8 and Threatened Species and Candidate Species." Accessed at 9 http://www.fws.gov/northeastinyfo/es/CountyLists/WestchesterDec2006.htm on February 26, 10 2008. ADAMS No. ML083390032.
11 Flora of North America (FNA) Editorial Committee (eds.). 1993+. Flora of North America North 12 of Mexico. 12+ vols. New York and Oxford. Accessed at 13 http://www.efloras.org/flora_page.aspx?florajd=1 on March 11,2008.
14 Francis, P., Jr. 1997. "The Beads that Did Not Buy Manhattan Island." New York History 78:
15 411-428.
16 Froese, R., and D. Pauly (eds.). 2007a. "Microgadus Tomcod Atlantic Tomcod" on FishBase:
17 World Wide Web Electronic Database. Version (10/2007). Accessed at 18 http://www.fishbase.org/summary/Speciessummary.php?id=316 on November 30,2007.
19 (ADAMS Accession No. ML073460169) 20 Froese, R., and D. Pauly (eds.) 2007b. "Dorosoma cepedianum American Gizzard Shad" on 21 FishBase: World Wide Web Electronic Database. Version (10/2007). Accessed at 22 http://www.fishbase.org/Summary/SpeciesSummary.php?id=1604 on February 6,2008.
23 ADAMS No. ML083390031.
24 Froese, R., and D. Pauly (eds.) 2007c. "Cynoscion regalis Gray Weakfish" on FishBase:
25 World Wide Web Electronic Database. Version (10/2007). Accessed at 26 http://www.fishbase.org/Summary/SpeciesSummary.php?id=406 on February 14, 2008.
27 ADAMS No. ML083390030.
28 Funk, R.E. 1976. Recent Contributions to Hudson Valley Prehistory. ed. Vol. pp.272-275.
29 State University of New York, State Education Department, Albany, NY.
30 Gilbert, C.R. 1989. "Species Profiles: Life Histories and Environmental Requirements of 31 Coastal Fishes and Invertebrates (Mid-Atlantic Bight)-Atlantic and Shortnose Sturgeons." U.S.
32 Fish and Wildlife Service Biological Report 82 (11.122). U.S. Army Corps of Engineers TR 82 4.
33 28 pp.
34 Griffin, E.F. 1946. Westchester County and Its People, A Record. pp.281-294. Lewis 35 Historical Publishing Company, New York.
36 Haas-Castro, R. 2006a. "Status of Fishery Resources off the Northeastern U.S.: River 37 Herring." Northeast Fisheries Science Center Resource Evaluation and Assessment Division, 38 National Oceanic and Atmospheric Administration. Accessed at 39 http://www. nefsc. noaa. gov/sos/spsyn/af/herring/archives/38_RiverHerring_2006. pdf on 40 December 17,2007. ADAMS No. ML083390029.
Draft NUREG-1437, Supplement 38 2-146 December 2008 OAG10001366_00181
Plant and the Environment 1 Haas-Castro, R. 2006b. "Status of Fishery Resources off the Northeastern U.S.: American 2 Shad." Northeast Fisheries Science Center Resource Evaluation and Assessment Division, 3 National Oceanic and Atmospheric Administration. Accessed at 4 http://www.nefsc.noaa.gov/sos/spsyn/af/shad/archives/39_AmericanShad_2006.pdf on 5 December 18,2007. ADAMS Accession No. ML083390028.
6 Haddock, S.HD. 2007. "Comparative Feeding Behavior of Planktonic Ctenophores."
7 Integrative and Comparative Biology 47(6), pp. 847-853.
8 Hall, C.A.S. 1977. "Model and the Decision Making Process: The Hudson River Power Plant 9 Case." Ecosystem Modeling in Theory and Practice, pp. 345-364. C.A.S Hall and J.W. Day, 10 Editors. Wiley, New York.
11 Hartman, K.J., J. Howell, and J.A. Sweka. 2004. "Diet and Daily Ration of Bay Anchovy in the 12 Hudson River, New York." Transactions of the American Fisheries Society 133, pp. 762-771.
13 Hirschberg, D.J., P. Chen, H. Feng, and J.K. Cochran. 1996. "Dynamics of Sediment and 14 Contaminant Transport in the Hudson River Estuary: Evidence from Sediment Distributions of 15 Naturally Occurring Radionnuclides." Estuaries 19:4, pp. 931-949.
16 Howard, R.W. 2001. "The English Province (1664-1776)." In The Empire State: A History of 17 New York, pp. 112-228. Edited by Milton M. Klein. Cornell University Press, Ithaca.
18 Idaho Department of Fish and Game, Bureau of Fisheries (lDFG). 1985. "Proposal for the 19 Introduction of Spottail Shiner (Notropis hudsonius) into Ondeida Narrows Reservoir."
20 November 1985. Accessed at 21 https://research.idfg.idaho.gov/Fisheries%20Research%20Reports/Volume%20087_Article%20 22 07.pdf on March 12, 2008.
23 Indian Point Energy Center. 2004. Meteorological Tower Data, 2000-2004. ADAMS No.
24 ML083390408 25 Indian Point Energy Center. 2005. "Indian Point 3, Updated Final Safety Analysis Report,"
26 Revision 1, Section 2.6.5.
27 Institute of Educational Science (I ES). 2008. U.S. Department of Education. National Center 28 for Educational Statistics. "College Opportunities Online Locator." Accessed at 29 http://nces.ed.gov/ipeds/cool/RefineSearch.aspx in April 2008.
30 Invasive Plant Council of New York State (lPCNYS). 2008. "Water Chestnut-Overview."
31 Accessed at http://www.ipcnys.org/sections/target/water_chestnut_overview.htm on February 32 23,2008.
33 Iverson, L.R., D. Ketzner, and J. Karnes. 1999. Illinois Plant Information Network. Illinois 34 Natural History Survey and USDA Forest Service. Accessed at 35 http://www.fs.fed.us/ne/delaware/ilpin/ilpin.htmlon March 11,2008. ADAMS Accession No.
36 M L083390027.
37 Juanes, F., R.E. Marks, K.A. McKown, and D.O. Conover. 1993. "Predation by Age-O Bluefish 38 on Age-O Anadromous Fishes in the Hudson River Estuary." Transactions of the American 39 Fisheries Society 122, pp. 348-356.
December 2008 2-147 Draft NUREG-1437, Supplement 38 OAG10001366_00182
Plant and the Environment 1 Kenney, G. 2002. "Annual Report on the Commercial Monitoring of the Hudson River Blue 2 Crab Fishery." New England Interstate Water Pollution Control Commission and New York 3 State Department of Environmental Conservation. New Paltz, NY.
4 Kentucky State Nature Preserves Commission (KSNPC). 2008. Kentucky Rare Plant 5 Database. Accessed at http://eppcapps.ky.gov/nprareplants/ on March 14,2008. ADAMS 6 Accession No. ML083390026.
7 Klauda, R.J., J.B. McLaren, R.E. Schmidt, and W.P. Dey. 1988. "Life History of White Perch in 8 the Hudson River Estuary." American Fisheries Society Monograph 4,69-88.
9 Koski, R.T. 1978. "Age, Growth, and Maturity of the Hogchoker, Trinectes maculates, in the 10 Hudson River, New York." Transactions of the American Fisheries Society 107(3), pp. 449-11 453.
12 Kraft, H.C. 1991. "The Indians of the Lower Hudson Valley at the Time of European Contact."
13 In The Archaeology and Ethnohistory of the Lower Hudson Valley and Neighboring Regions:
14 Essays in Honor of Louis A. Brennan. Edited by Herbert C. Kraft. Archaeological Services, 15 Bethlehem, CT.
16 Kynard, B. 1997. "Life History, Latitudinal Patterns, and Status of the Shortnose Sturgeon 17 Acipenser brevirostrum." Environmental Biology of Fishes 48, pp. 319-334.
18 Lady Bird Johnson Wildflower Center Native Plant Information Network (NPIN). 2008. Native 19 Plant Database. Accessed at http://www.wildflower.org/plants/ on March 14, 2008. ADAMS 20 Accession No. ML083390025.
21 Larson, R.J. 1988. "Feeding and Functional Morphology of the Lobate Ctenophore Mnemiopsis 22 mccradyi." Estuarine, Coastal and Shelf Science 27(5), pp. 495-502.
23 Levine, M.A. 1989. "New Evidence for Postglacial Occupations in the Upper Hudson Valley."
24 Bulletin, Journal of the New York State Archaeological Association 98: 5-12.
25 Levinton, J.S., and J.R. Waldman (eds.). 2006. The Hudson River Estuary. Cambridge 26 University Press, New York.
27 Limburg, K.E. 1996. "Modeling the Ecological Constraints on Growth and Movement of 28 Juvenile American Shad (Alosa sapidissima) in the Hudson River Estuary." Estuaries 19:4, pp.
29 794-813.
30 Lonsdale, D.J., E.M. Cosper, and M. Doall. 1996. "Effects of Zooplankton Grazing on 31 Phytoplankton Size-Structure and Biomass in the Lower Hudson River Estuary." Estuaries 32 19:4, pp. 874-889.
33 Marcy, B.C., D.E. Fletcher, F.D. Martin, M.H. Paller, and M.J.M. Reichert. 2005a. "Spottail 34 Shiner." In: Fishes of the Middle Savannah River Basin. Athens, GA: University of Georgia 35 Press, pp. 153-156.
36 Marcy, B.C., D.E. Fletcher, F.D. Martin, M.H. Paller, and M.J.M. Reichert. 2005b. "White 37 Catfish." In: Fishes of the Middle Savannah River Basin, pp. 212-214. University of Georgia 38 Press, Athens, GA.
39 Maryland Department of Natural Resources (MDNR). 2007a. "Maryland Fish Facts: American 40 Gizzard Shad." Accessed at Draft NUREG-1437, Supplement 38 2-148 December 2008 OAG10001366_00183
Plant and the Environment 1 http://www.dnr.state.md.us/fisheries/fishfacts/americangizzardshad.asp on February 6, 2008.
2 ADAMS Accession No. ML083390023.
3 Maryland Department of Natural Resources (MDNR). 2007b. "White Catfish-Ameiurus catus."
4 Accessed at http://www.dnr.state.md.us/fisheries/fishfacts/whitecatfish.asp on March 13,2008.
5 ADAMS Accession No. ML080730512.
6 McGovern, J.C., and J.E. Olney. 1988. "Potential Predation by Fish and Invertebrates on Early 7 Life History Stages of Striped Bass in the Pamunkey River, Virginia." Transactions of the 8 American Fisheries Society 117, pp. 152-161.
9 McLaren, J.B., T.H. Peck, W.P. Dey, and M. Gardinier. 1988. "Biology of Atlantic Tomcod in 10 the Hudson River Estuary." American Fisheries Society Monograph 4, pp. 102-112.
11 Menhaden Resource Council (MRC). 2006. "Atlantic Menhaden Biology." Accessed at 12 http://www.menhaden.org/biology.htm on February 4,2008.
13 Mercer, L.P. 1989. "Species Profile: Life Histories and Environmental Requirements of 14 Coastal Fishes and Invertebrates (Mid-Atlantic)-Weakfish." U.S. Fish and Wildlife Service 15 Biological Report 82 (11.109). U.S. Army Corps of Engineers, TR EL-82-4. Accessed at 16 http://www.nwrc.usgs.gov/wdb/pub/species_profiles/82_11-109.pdf on February 8,2008.
17 Miller, D., J. Ladd, and W. Nieder. 2006. "Channel Morphology in the Hudson River Estuary:
18 Historical Changes and Opportunities for Restoration." American Fisheries Society Symposium 19 51, pp. 29-37.
20 Mills, E.L., D.L. Strayer, M.D. Scheuerell, and J.T. Carlton. 1996. "Exotic Species in the 21 Hudson River Basin: A History of Invasions and Introductions." Estuaries 19:4, pp. 814-823.
22 Morris, C. 2001. "Dorosoma cepedianum." Animal Diversity Web. Accessed at 23 http://animaldiversity.ummz.umich.edu/site/accounts/information/Dorosoma_cepedianum. html 24 on February 6, 2008.
25 Morton, T. 1989. "Species Profiles: Life Histories and Environmental Requirements of Coastal 26 Fishes and Invertebrates (Mid-Atlantic)-Bay Anchovy." U.S. Fish and Wildlife Service 27 Biological Report 82 (11.97). U.S. Army Corps of Engineers TR EL-82-4 13 pp. Accessed at 28 http://www.nwrc.usgs.gov/wdb/pub/species_profiles/82_11-097.pdf on March 13,2008.
29 National Oceanic and Atmospheric Administration (NOAA). 2004. Local Climatological Data-30 Annual Summary with Comparative Data-Binghamton, Albany, and New York City, New York.
31 ISSN 0198-2419, Asheville, NC.
32 National Oceanic and Atmospheric Administration (NOAA). 2007. "Species of Concern:
33 Rainbow Smelt, Osmerus mordax." Updated May 17, 2007. Accessed at 34 http://nmfs.noaa.gov/pr/pdfs/species/rainbowsmelt_detailed.pdf on March 12, 2008.
35 National Oceanic and Atmospheric Administration (NOAA). 2008a. "Hudson River Reserve, 36 New York." National Estuarine Research Reserve System. Accessed at 37 http://www.nerrs.noaa.gov/HudsonRiver/ on February 23,2008.
December 2008 2-149 Draft NUREG-1437, Supplement 38 OAG10001366_00184
Plant and the Environment 1 National Oceanic and Atmospheric Administration (NOAA). 2008b. "Pharmaceuticals in the 2 Environment, Information for Assessing Risk." National Centers for Coastal Ocean Science 3 (NCCOS), National Ocean Service. Accessed at http://www.chbr.noaa.gov/peiar on December 4 2,2008.
5 National Park Service (NPS). 2006a. "Class I Mandatory Areas." Accessed at 6 http://www2.nature.nps.gov/air/Maps/Receptors/index.cfm on December 4,2008. ADAMS No.
7 M L083390507 8 National Park Service (NPS). 2006b. "Explore Air. Class I Receptors." Accessed at 9 http://www2.nature.nps.gov/air/Maps/images/ClassIAreas.jpg on December 3,2008. ADAMS 10 No. ML083390114 11 National Severe Storm Laboratory (NSSL). 2006. "Tornadoes ... Nature's Most Violent Storms."
12 Natural Resources Conservation Service (NRCS). 2008. Plants Database. U.S. Department of 13 Agriculture. Accessed at http://plants.usda.gov/java/factSheet on March 10,2008.
14 NatureServe. 2007. NatureServe Explorer: An online encyclopedia of life (Web application).
15 Version 6.2. NatureServe, Arlington, VA. Accessed at http://www.natureserve.org/explorer/ in 16 March 2008.
17 Nearctica.com, Inc. (Nearctica). 2008. "Wildflowers of the Eastern United States." Accessed at 18 http://www.nearctica.com/flowers/index.htm on March 12,2008.
19 New Jersey Department of Environmental Protection (NJDEP). 2005. "White Catfish."
20 Accessed at http://www.nj.gov/dep/fgw/fish_wht_cat.htm on March 13,2008. (ADAMS 21 Accession No. ML080730514) 22 New Jersey Department of Environmental Protection (NJDEP) and New Jersey Department of 23 Health and Senior Services (NJDHSS). 2006. "Fish Smart, Eat Smart: A Guide to Health 24 Advisories for Eating Fish and Crabs Caught in New Jersey Waters." Accessed at 25 http://www.state.nj.us/dep/dsr/2006fishadvisorybrochure.pdf on March 13,2008. (ADAMS 26 Accession No. ML080730515) 27 New York Natural Heritage Program (NYNHP). 2007. "New York Rare Plant Status Lists."
28 Albany, New York. 115pp. June 2007. Accessed at 29 http://www.dec.ny.gov/docs/wildlife_pdf/Rare_Plant_Status_Lists_2007.pdf on March 11,2008.
30 New York Natural Heritage Program (NYNHP). 2008a. "Online Conservation Guide for Myotis 31 sodalis." Accessed at http://www.acris.nynhp.org/guide.php?id=7405 on March 21,2008.
32 ADAMS Accession No. ML083390018.
33 New York Natural Heritage Program (NYNHP). 2008b. "Online Conservation Guide for 34 Glyptemys muhlenbergii." Accessed at http://www.acris.nynhp.org/guide.php?id=7507 on 35 March 21,2008. ADAMS Accession No. ML083390017.
36 New York Natural Heritage Program (NYNHP). 2008c. "Online Conservation Guide for 37 Sylvilagus transitionalis." Accessed at http://www.acris.nynhp.org/guide.php?id=7415 on March 38 21,2008. ADAMS Accession No. ML083390015.
39 New York Natural Heritage Program (NYNHP). 2008d. "Animal and Plant Guides." Accessed 40 at http://www.acris.nynhp.org/ in March 2008. ADAMS Accession No. ML083390012.
Draft NUREG-1437, Supplement 38 2-150 December 2008 OAG10001366_00185
Plant and the Environment 1 New York Metropolitan Transportation Council. 2004. Accessed at 2 http://www. nymtc. org/Project/conform ity/Appendix!Appendix%206B%20Population. pdf on Apri I 3 2008.
4 New York State Department of Environmental Conservation (NYSDEC). 2003a. "Final 5 Environmental Impact Statement Concerning the Applications to Renew New York State 6 Pollutant Discharge Elimination System (SPDES) Permits for the Roseton 1&2 Bowline 1&2 and 7 Indian Point 2&3 Steam Electric Generating Stations, Orange, Rockland and Westchester 8 Counties." Hudson River Power Plants FEIS. June 25, 2003. ADAMS Accession No.
9 ML083360752.
10 New York State Department of Environmental Conservation (NYSDEC). 2003b. "Fact Sheet.
11 New York State Pollutant Discharge Elimination System (SPDES) Draft Permit Renewal with 12 Modification, Indian Point Electric Generating Station, Buchanan, NY." November 2003.
13 Accessed at http://www.dec.ny.gov/docs/permits_eLoperations_pdf/lndianPointFS.pdf on July 14 12,2007. ADAMS Accession No. ML083360743.
15 New York State Department of Environmental Conservation (NYSDEC). 2004a. "Descriptive 16 Data of Municipal Wastewater Treatment Plants in New York State." New York Department of 17 Environmental Conservation, Division of Water, Bureau of Water Compliance. January 2004.
18 Accessed at http://www.dec.ny.gov/docs/water_pdf/descdata2004.pdf on January 15, 2008.
19 New York State Department of Environmental Conservation (NYSDEC). 2004b. "Abundance 20 and Distribution of Blue Crab (Callinectes sapidus) Overwintering in the Hudson River Estuary."
21 Prepared by Normandeu Associates Inc. for New York State Department of Environmental 22 Conservation, Hudson River Fisheries Unit. R-19934.000, March 2004. Accessed at 23 http://www.nysl.nysed.gov/scandoclinks/ocm60127660.htm on March 15,2008.
24 New York State Department of Environmental Conservation (NYSDEC). 2004c. New York 25 State Freshwater Wetlands Map, Westchester County, Map 1 of 14. Promulgated October 7, 26 1987. Revised July 28,2004.
27 New York State Department of Environmental Conservation (NYSDEC). 2005. "New York 28 State Breeding Bird Atlas, 2000-2005." Release 1.0. Albany, NY. Updated June 2007.
29 Accessed at http://www.dec.ny.gov/animals/7312.htmlon March 5, 2008. ADAMS Accession 30 No. ML083380509.
31 New York State Department of Environmental Conservation (NYSDEC). 2007a. "Hudson River 32 Estuary Program Annual Report for the Period April 1, 2006-March 30,2007." The Hudson 33 River Estuary Program, New York State Department of Environmental Conservation.
34 Accessed at http://www.dec.ny.gov/docs/remediation_hudson_pdf/annrep07.pdf on February 35 21,2008. ADAMS Accession No. ML083380517.
36 New York State Department of Environmental Conservation (NYSDEC). 2007b. "Checklist of 37 Amphibians, Reptiles, Birds and Mammals of New York State-Including Their Legal Status."
38 Division of Fish, Wildlife and Marine Resources, Wildlife Diversity Group. Eighth revision.
39 Accessed at www.dec.ny.gov/docs/wildlife_pdf/vertchecklist0907.pdf on March 3, 2008.
40 ADAMS Accession No. ML083380524.
41 New York State Department of Environmental Conservation (NYSDEC). 2007c. Letter from 42 Tara Seoane, Information Services, New York Natural Heritage Program, to Rani Franovitch, December 2008 2-151 Draft NUREG-1437, Supplement 38 OAG10001366_00186
Plant and the Environment 1 NRC. Response to November 27,2007, request from the NRC for information on State-listed, 2 proposed, and candidate species and critical habitat that may be in the vicinity of Indian Point.
3 December 2S, 2007. ADAMS Accession No. MLOS00700S5.
4 New York State Department of Environmental Conservation (NYSDEC). 200Sa. "Some 5 Catfishes of New York." Accessed at http://www.dec.ny.gov/animals/7046.htmlon March 13, 6 200S. (ADAMS Accession No. MLOS0730517) 7 New York State Department of Environmental Conservation (NYSDEC). 200Sb. "Bald Eagle S Fact Sheet." Accessed at http://www.dec.ny.gov/animals/93S3.html?showprintstyles on March 9 13,200S. ADAMS Accession No. MLOS33S0531.
10 New York State Department of Environmental Conservation (NYSDEC). 200Sc. "Bald Eagles 11 of the Hudson River." Accessed at http://www.dec.ny.gov/animals/93S2.html?showprintstyles 12 on March 13, 200S. ADAMS Accession No. MLOS33S0535.
13 New York State Department of Environmental Conservation (NYSDEC). 200Sd. "Peregrine 14 Falcon Fact Sheet." Accessed at http://www.dec.ny.gov/animals/7294.html?showprintstyles on 15 March 5, 200S. ADAMS Accession No. MLOS33S0540.
16 New York State Department of Environmental Conservation (NYSDEC). 200Se. "Peregrine 17 Falcon." Accessed at http://www.dec.ny.gov/animals/7059.html?showprintstyles on March 13, 1S 200S. ADAMS Accession No. MLOS33S0542.
19 New York State Department of Environmental Conservation (NYSDEC). 200Sf. "Bog Turtle 20 Fact Sheet." Accessed at http://www.dec.ny.gov/animals/7164.html?showprintstyles on March 21 13,200S. ADAMS Accession No. MLOS33S0545.
22 New York State Department of Environmental Conservation (NYSDEC). 200Sg. "New York 23 State Amphibian and Reptile Atlas Project." Accessed at 24 http://www.dec.ny.gov/animals/7479.html?showprintstyles on March 13, 200S. ADAMS 25 Accession No. MLOS33S0553.
26 New York State Department of Environmental Conservation (NYSDEC). 200Sh. "List of 27 Endangered, Threatened and Special Concern Fish & Wildlife Species of New York State."
2S Accessed at http://www.dec.ny.gov/animals/70S2.htmlon March 17, 200S.
29 New York State Department of Environmental Conservation (NYSDEC). 200Si. "Red-30 shouldered Hawk Fact Sheet." Accessed at http://www.dec.ny.gov/animals/70S2.htmlon March 31 17,200S. ADAMS Accession No. MLOS33S055S.
32 New York State Department of Health (NYSDOH). 1994. "Environmental Radiation in New 33 York State." 1993 Annual Report. Albany, NY. ADAMS Accession No. ML0703S0534.
34 New York State Department of Health (NYSDOH). 1995. "Environmental Radiation in New 35 York State." 1994 Annual Report. Albany, NY. ADAMS Accession No. ML0703S0532.
36 New York State Department of Health (NYSDOH). 2007. "Chemicals in Sportfish and Game:
37 2007-200S Health Advisories." Division of Environmental Health Assessment. Accessed at 3S http://www.health.state.ny.us/environmental/outdoors/fish/docs/fish.pdf on March 13, 200S.
39 ADAMS Accession No. MLOS33S0561.
40 New York State Department of State (NYSDOS). 2004. "Coastal Resources Online:
41 Significant Coastal Fish and Wildlife Habitats-Hudson River Mile 44-56 link." Division of Draft NUREG-1437, Supplement 3S 2-152 December 200S OAG10001366_001S7
Plant and the Environment 1 Coastal Resources. Accessed at 2 http://www.nyswaterfronts.com/waterfront_natural_narratives.asp on March 17,2008. ADAMS 3 Accession No. ML083380563.
4 New York State Department of Transportation (NYSDOT). 2005. "2004 Traffic Data Report for 5 New York State."
6 New York State Office of the State Comptroller (NYSOSC). 2008. "Local Government Services 7 and Economic Development." Accessed at http://www.osc.state.ny.us on May 30,2008.
8 ADAMS Accession No. ML083380565.
9 New York State Ornithological Association (NYSOA). 2007. "Historical Waterfowl Count Data, 10 1973-2007." Accessed at http://www.nybirds.org/ProjWaterfowl.htm on March 5, 2008.
11 ADAMS Accession No. ML083380567.
12 Nieder, W.C., E. Barnaba, S.E.G. Findlay, S. Hoskins, N. Holochuck, and E.A. Blair. (2004).
13 "Distribution and Abundance of Submerged Aquatic Vegetation and Trapa natans in the Hudson 14 River Estuary." Journal of Coastal Research 45: 150-161.
15 Niering, W.A. and N.C. Olmstead. 1979. The Audubon Society Field Guide to North American 16 Wildflowers, Eastern Region. 863 pp. Alfred A. Knopf, Inc., NY.
17 North Carolina State University (NCSU). 2008. "Plant Fact Sheets." Accessed at 18 http://www.ces.ncsu.edu/depts/hortlconsumer/factsheets/index.htmlon March 12, 2008.
19 ADAMS Accession No. ML083380570.
20 Northeast Regional Climate Center (NRCC). 2006. New York Climate Office. "The Climate of 21 New York." Accessed at http://nysc.eas.comell.edu/climate_oCny.htmlon December 3,2008.
22 ADAMS No. ML083380625 23 Nuclear Regulatory Commission (NRC). 1975. "Final Environmental Statement Related to the 24 Operation of Indian Point Nuclear Generating Plant Unit No.3," Volume 1. Office of Nuclear 25 Reactor Regulation. NUREG-75/002. February 1975.
26 Nuclear Regulatory Commission (NRC). 2006. "Indian Point Nuclear Generating Unit 2-NRC 27 Special Inspection Report No. 05000247/2005011." Docket Number 50-247. Washington, DC.
28 (ADAMS Accession No. ML060750842) 29 Nuclear Regulatory Commission (NRC). 2007. "Indian Point Nuclear Generating Unit 2-30 Routine Integrated Inspection Report No. 05000247/07003." Docket Number 50-247.
31 Washington, DC. (ADAMS Accession No. ML072150161) 32 Office of Protected Resources (OPR). Undated. "Shortnose Sturgeon (Acipenser 33 brevirostrum)." National Marine Fisheries Service. Accessed at 34 http://www.nmfs.noaa.gov/prlspecies/fish/shortnosesturgeon.htm on December 11, 2007.
35 ADAMS Accession No. ML083380572.
36 Opler, P.A., H. Pavulaan, R.E. Stanford, and M. Pogue, coordinators. 2006. "Butterflies and 37 Moths of North America." Bozeman, MT: NBII Mountain Prairie Information Node. Accessed at 38 http://www.butterfliesandmoths.org/ on March 18, 2008. ADAMS Accession No. ML083380575.
December 2008 2-153 Draft NUREG-1437, Supplement 38 OAG10001366_00188
Plant and the Environment 1 Orange County Department of Planning. 2003. Orange County Comprehensive Plan:
2 Strategies for Quality Communities. Accessed at 3 http://www.orangecountygov.com/documentView.asp?docl 0=138 on May 30, 2006. ADAMS 4 Accession No. ML083380576.
5 Pace, M.L., S.E.G. Findlay, and D. Fischer. 1998. "Effects of an Invasive Bivalve on the 6 Zooplankton Community of the Hudson River." Freshwater Biology 39, pp. 103-116.
7 Peekskill Water Department, City of (PWD). 2005. "Annual Drinking Water Quality Report for 8 2005, City of Peekskill-Water Department." Accessed at http://www.ci.peekskill.ny.us on June 9 30,2006. ADAMS Accession No. ML083380578.
10 Perry, H.M., and T.D. Mcilwain. 1986. "Species Profiles: Life Histories and Environmental 11 Requirements of Coastal Fishes and Invertebrates (Gulf of Mexico)-Blue Crab." U.S. Fish and 12 Wildlife Service Biological Report 82 (11.55). U.S. Army Corps of Engineers, TR EL-82-4.
13 Peteet, D.M., D.C. Pederson, D. Kurdyla, and T. Guilderson. 2006. "Hudson River 14 Paleoecology from Marshes: Environmental Change and its Implications for Fisheries."
15 American Fisheries Society Monograph 51, pp. 113-128.
16 Phillips, P.J., and D.W. Hanchar. 1996. "Water-Quality Assessment of the Hudson River Basin 17 in New York and Adjacent States-Analysis of Available Nutrient, Pesticide, Volatile Organic 18 Compound, and Suspended-Sediment Data, 1970-1990." U.S. Geological Survey, Water-19 Resources Investigations Report 96-4065.
20 Pottern, G.B., M.T. Huish, and J.H. Kerby. 1989. "Species Profile: Life Histories and 21 Environmental Requirements of Coastal Fishes and Invertebrates (Mid-Atlantic)-Bluefish."
22 U.S. Fish and Wildlife Service Biological Report 82 (11.94). U.S. Army Corps of Engineers, TR 23 EL-82-4. Accessed at http://www.nwrc.usgs.gov/wdb/pub/species_profiles/82_11-094.pdf on 24 February 7,2008. ADAMS Accession No. ML083380583.
25 Poughkeepsie Townwide Water District (PTWD). 2005. "Annual Water Quality Report for 26 Calendar Year 2005." Accessed at 27 http://www.townofpoughkeepsie.com/PoughkeepsieTWWD2005.pdf on July 10, 2006.
28 Poughkeepsie-Dutchess County Transportation Council (PDCTC) Planning and Development.
29 2006. Divisions: Poughkeepsie-Dutchess County Transportation Council. Accessed at 30 http://www.co.dutchess.ny.us/CountyGov/Departments/Planning/PLpdctclndex.htm on June 30, 31 2006. ADAMS Accession No. ML083380587.
32 Pullen Herbarium. 2008. Pullen Herbarium Specimen Database (MISS), University of 33 Mississippi Department of Biology. Accessed at http://herbarium.olemiss.edu on March 14, 34 2008. ADAMS Accession No. ML083380589.
35 Purcell, J.E., D.A. Namazie, S.E. Dorsey, E.D. Houde, and J.C. Gamble. 1994. "Predation 36 Mortality of Bay Anchovy Anchoa mitchelli Eggs and Larvae Due to Scyphomedusae and 37 Ctenophores in Chesapeake Bay." Marine Ecology Progress Series 114, pp. 47-58.
Draft NUREG-1437, Supplement 38 2-154 December 2008 OAG10001366_00189
Plant and the Environment 1 Putnam County Division of Planning and Development. 2003. "Report on the Task Force on 2 Vision 2010: Guiding Putnam into the Next Decade." Accessed at 3 http://www.putnamcountyny.com/vision2010.htmlon May 30,2006.
4 Ritchie, W.A. 1980. The Archaeology of New York State. pp. 196-200. Harbor Hill Books, 5 Harrison, NY.
6 Ritchie, W.A. 1994 (orig. 1980). The Archaeology of New York State. pp. xvii-xviii. Purple 7 Mountain Press, Fleischmanns, NY.
8 Rockland County Department of Health (RCDH). 2006. "Assessment of United Water New 9 York Supply." Accessed for New Projects, 2006. Accessed at 10 http://www.co.rockland.ny.us/health/pdf/SupplyDemandTracking_1.pdf on August 28,2006.
11 ADAMS Accession No. ML083380591.
12 Rockland's Water Supply (RWS). 2006. Clearwater. Poughkeepsie, NY. Accessed at 13 www.clearwater.org/sustainablewatershed/pdfs/miller.pdf on February 20,2007.
14 Roditi, H.A., N.F. Caraco, J.J. Cole, and D.L. Strayer. 1996. "Filtration of Hudson Water by the 15 Zebra Mussel (Dreissena polymorpha)." Estuaries 19:4, pp. 824-832.
16 Rogers, S.G., and M.J. Van Den Avyle. 1989. "Species Profile: Life Histories and 17 Environmental Requirements of Coastal Fishes and Invertebrates (Mid-Atlantic)-Atlantic 18 Menhaden." U.S. Fish and Wildlife Service Biological Report 82 (11.108). U.S. Army Corps of 19 Engineers, TR EL-82-4. Accessed at 20 http://www.nwrc.usgs.gov/wdb/pub/species_profiles/82_11-108.pdf on February 5,2008.
21 ADAMS Accession No. ML083380608.
22 Rohmann, S.O., N. Lilienthal, R.L. Miller, R.M. Szwed, and W.R. Muir. 1987. "Tracing a River's 23 Toxic Pollution: A Case Study of the Hudson. Phase 2. 209 pp. Inform, Inc., NY.
24 Roundtree, R.A. 1999. "Nov. Diets of NW Atlantic Fishes and Squid." Accessed at 25 http://www.fishecology.org/diets/diets.htm on February 20,2008. ADAMS Accession No.
26 M L08338061 O.
27 Salwen, Bert. 1975. "Post-glacial Environments and Cultural Change in the Hudson River 28 Basin." Man in the Northeast 10: 43-70.
29 Sanders, C., and J. Chenger. 2001. "Williams Lake Telemetry Study: New York Indiana Bat 30 Spring Migration Tracking." Bat Conservation and Management, Mechanicsburg, PA.
31 Accessed at http://www.batmanagement.com/Projects/kings/WiliiamsScreen.pdf on March 19, 32 2008. ADAMS Accession No. ML083380612.
33 Schmidt, R.E., and T.R. Lake. 2006. "Tributaries and Hudson River Fishes." In: The Hudson 34 River Estuary. J.S. Levinton and J.R. Waldman, eds. 209 pp Cambridge University Press, 35 Cambridge.
36 Schultz, E.T., K.M.M. Lwiza, J.R. Young, K.J. Hartman, and R.C. Tipton. 2006. "The Dynamics 37 of Bay Anchovy in the Hudson River Estuary: Process-oriented Studies and Long-term 38 Changes." American Fisheries Society Symposium 51, pp. 197-213.
December 2008 2-155 Draft NUREG-1437, Supplement 38 OAG10001366_00190
Plant and the Environment 1 Shepherd, G. 2006a. "Status of Fishery Resources off the Northeastern U.S.: Bluefish."
2 Northeast Fisheries Science Center Resource Evaluation and Assessment Division, National 3 Oceanic and Atmospheric Administration. Accessed at 4 http://www.nefsc.noaa.gov/sos/spsyn/op/bluefish/archives/25_Bluefish_2006.pdf on February 7, 5 2008. ADAMS Accession No. ML083360690.
6 Shepherd G. 2006b. "Atlantic Striped Bass." Accessed at 7 http://www.nefsc.noaa.gov/sos/spsyn/af/sbass/archives/40_ StripedBass_2006. pdf on December 8 10,2007. ADAMS Accession No. ML083360766.
9 Shepard, G. 2006c. "Status of Fishery Resources off the Northeastern US, NEFSC-Resource 10 Evaluation and Assessment Division, Atlantic and Shortnose Sturgeons." Accessed at 11 http://www.nefsc.noaa.gov/sos/spsyn/af/sturgeon/ on December 10, 2007. ADAMS Accession 12 No. ML083380619.
13 Smith, C.L. 1985a. "Spottail Shiner." In: The Inland Fishes of New York State, pp. 194-195.
14 New York State Department of Environmental Conservation, Albany, NY.
15 Smith, C.L. 1985b. "White Catfish." In: The Inland Fishes of New York State," pp. 78-79.
16 New York State Department of Environmental Conservation, Albany, NY.
17 Snow,D.R. 1995. Mohawk Valley Archaeology: the Sites. Matson Museum of Anthropology, 18 Pennsylvania State University, University Park, PA 19 Stanley, J.G., and D.S. Danie. 1983. "Species Profiles: Life Histories and Environmental 20 Requirements of Coastal Fishes and Invertebrates (North Atlantic)-White Perch." U.S. Fish 21 and Wildlife Service, Division of Biological Services, FWS/OBS-82/11.7. U.S. Army Corps of 22 Engineers, TR EL-82-4. 12pp. Accessed at 23 http://www.nwrc.usgs.gov/wdb/pub/species_profiles/82_11-007.pdf on March 14,2008.
24 ADAMS Accession No. ML083380621.
25 Steinberg, N., D.J. Suszkowski, L. Clark, and J. Way. 2004. Health of the Harbor: The First 26 Comprehensive Look at the State of the NY, NY Harbor Estuary. A Report to the New 27 York/New Jersey Harbor Estuary Program. Hudson River Foundation, New York. ADAMS 28 Accession No. ML083380622.
29 Stewart, L.L., and P.J. Auster. 1987. "Species Profile: Life Histories and Environmental 30 Requirements of Coastal Fishes and Invertebrates (Mid-Atlantic)-Atlantic Tomcod." U.S. Fish 31 and Wildlife Service Biological Report 82 (11.76). U.S. Army Corps of Engineers, TR EL-82-4.
32 Accessed at http://www.nwrc.usgs.gov/wdb/pub/species_profiles/82_11-076.pdf on November 33 29,2007. ADAMS Accession No. ML073460171.
34 Strayer, D.L., and L.C. Smith. 1996. "Relationships Between Zebra Mussels (Dreissena 35 polymorpha) and Unionid Clams During the Early Stages of the Zebra Mussel Invasion of the 36 Hudson River." Freshwater Biology 36, pp. 771-779.
37 Strayer, D.L., K.A Hattala, and AW. Kahnle. 2004. "Effects of an Invasive Bivalve (Dreissena 38 polymorpha) on Fish in the Hudson River Estuary." Canadian Journal of Fisheries and Aquatic 39 Sciences 61, pp. 924-941.
40 Strayer, D.L., and H.M. Malcom. 2006. "Long-term Demography of a Zebra Mussel (Dreissena 41 polymorpha) Population. Freshwater Biology 51, pp. 117-130.
Draft NUREG-1437, Supplement 38 2-156 December 2008 OAG10001366_00191
Plant and the Environment 1 Strayer, D.L. 2007. "Zebra Mussels and the Hudson River." Cary Institute of Ecosystem 2 Studies. Accessed at http://www.ecostudies.org/people_sci_strayer_zebra_mussels.htmlon 3 January 8,2008. ADAMS Accession No. ML083380623.
4 Steinberg, N., D.J. Suszkowski, L. Clark, and J. Way. 2004. Health of the Harbor: The First 5 Comprehensive Look at the State of NY.NY Harbor Estuary. A Report to the New York/New 6 Jersey Harbor Estuary Program. Hudson River Foundation. New York, New York. ADAMS 7 Accession No. ML083360721.
8 Swaney, D.P., K.E. Limburg, and K. Staingrook. 2006. "Some Historical Changes in the 9 Pattern of Population and Land Use in the Hudson River Watershed." American Fisheries 10 Society Symposium 51, pp.75-112.
11 Sweka, J.A., J. Mohler, M.J. Millard, T. Kehler, A. Kahnle, K. Hattala, G. Kenney, and A. Higgs.
12 2007. "Juvenile Atlantic Sturgeon Habitat Use in Newburgh and Haverstraw Bays of the 13 Hudson River: Implications for Population Monitoring." North American Journal of Fisheries 14 Management 27, pp. 1058-1067.
15 The Journal News, New York's Lower Hudson Valley. 2006 "Westchester County's major 16 employers." From Staff Reports dated March 19,2006. Accessed at 17 http://www.lohud.com/apps/pbcs.dll/article?AID=/20060319/BUSINESS/603190302/1066/BUSI 18 NESS01 in April 2008. ADAMS Accession No. ML083380624.
19 Tipton, R.C. 2003. "Distributional Ecology of Bay Anchovy (Anchoa mitchilli) in the Hudson 20 River Estuary, USA." A dissertation submitted to West Virginia University. Forest Resources 21 Sciences Wildlife and Fisheries Program. Accessed at 22 http://kitkat.wvu.edu:8080/files/2930ITipton_Ronald_Dissertation.pdf on March 13,2008.
23 ADAMS Accession No. ML083380626.
24 Town of Cortlandt, New York (TOCNY). 2004. Comprehensive Master Plan, Town of Cortlandt, 25 July 2004. Accessed at http://www.townofcortlandt.com/on May 30,2006. ADAMS Accession 26 No. ML083380627.
27 Town of Cortlandt, New York (TOCNY). 2006. Town Profile. Accessed at 28 http://www.townofcortlandt.com/Cit-e-Access/webpage.cfm?TI 0=20&TPI 0=2564 on July 15, 29 2006. ADAMS Accession No. ML083380629.
30 U.S. Army Corps of Engineers (USACE). 2006. Public Notice No. HR-AFO-06. "Hudson River, 31 New York (Coeymans and Kingstong Reaches) Federal Navigation Projects Maintenance 32 Dredging." April 7. Accessed at 33 http://www.nan.usace.army.mill. ../buslinks/navig/cntldpth/kingston.pdf on March 5, 2008.
34 U.S. Atomic Energy Commission (USAEC). 1972. "Final Environmental Statement Related to 35 the Operation of Indian Point Nuclear Generating Plant Unit No.2." Directorate of Licensing.
36 Docket No. 50-247. September 1972.
37 U.S. Census Bureau (USCB). 2000. State and County Quick Facts. Accessed at 38 http://www.census.gov on March 4,2008. ADAMS Accession No. ML083380631.
39 U.S. Census Bureau (USCB). 2006. American Fact Finder, New York City, NY. Accessed at 40 http://factfinder.census.gov/home/saff/main.html?_lang=en on March 4,2008.
December 2008 2-157 Draft NUREG-1437, Supplement 38 OAG10001366_00192
Plant and the Environment 1 U.S. Census Bureau (USCB). 2008a. American FactFinder, American Community Survey of 2 Dutchess, Orange, Putnam, and Westchester Counties, Data Profile Highlights. Housing 3 Characteristics for 2000 and 2006. Accessed at http://factfinder.census.gov in April 2008.
4 U.S. Census Bureau (USCB). 2008b. "New York Quickfacts: Dutchess, Orange, Putnam, and 5 Westchester Counties." Accessed at http://quickfacts.census.gov/ on March 11, 2008. ADAMS 6 Accession No. ML083380632.
7 U.S. Census Bureau (USCB). 2008c. Decennial Census 2000 Data and American FactFinder, 8 American Community Survey of Dutchess, Orange, Putnam, and Westchester Counties, Data 9 Profile Highlights. ACS Demographic Estimates for 2006. Accessed at 10 http://factfinder.census.gov in April 2008.
11 U.S. Department of Agriculture (USDA). 2002a. "Dutchess County: 2002 Census of 12 Agriculture County Profile." Accessed at 13 http://www.nass.usda.gov/census/census02/profiles/ny/ on May 15, 2005.
14 U.S. Department of Agriculture (USDA). 2002b. "Orange County: 2002 Census of Agriculture 15 County Profile." Accessed at http://www.nass.usda.gov/census/census02/profiles/ny/ on May 16 15,2005.
17 U.S. Department of Agriculture (USDA). 2002c. "Putnam County: 2002 Census of Agriculture 18 County Profile." Accessed at 19 http://www.nass.usda.gov/census/census02/profiles/ny/cp36079.PDF on May 15, 2005.
20 U.S. Department of Agriculture (USDA). 2002d. "Westchester County: Farm Statistics."
21 Accessed at http://www.nass.usda.gov/census/census02/profiles/ny/cp36119.PDF on May 15, 22 2006.
23 U.S. Department of Agriculture (USDA). 2002e. "Census of Agriculture." Accessed at 24 http://www.nass.usda.gov/census/census02/volume1/pa/index2.htmin April 2008. ADAMS 25 Accession No. ML083380633.
26 U.S. Department of Commerce (USDOC). 2006a. National Climatic Data Center, NOAA 27 Satellite and Information Service, Tornado Climatology. Accessed at 28 http://www.ncdc.noaa.gov/oa/climate/severeweather/tornadoes.htmlon August 28,2006.
29 ADAMS Accession No. ML083380644.
30 U.S. Department of Commerce (USDOC). 2006b. National Climatic Data Center (NCDC), 2006 31 Westchester County Tornado Query Results. Accessed at http://www4.ncdc.noaa.gov/cgi-32 win/wwcgi.dll/wwevent-storms on July 6, 2006.
33 U.S. Geological Survey (USGS). 2008. "Hudson River Salt Front Data." Accessed at 34 http://ny.water.usgs.gov/projects/dialer_plots/saltfront.htmlon January 31, 2008.
35 United Water New York (UWNY). 2006. "Annual Water Quality Report 2005." Accessed at 36 http://www.unitedwater.com/uwny/pdfs/dNY.pdf on August 28,2006. ADAMS Accession No.
37 ML083380655.
38 Village of Buchanan, New York (VBNY). 1998. "About Our Village." Accessed at 39 http://www.villageofbuchanan.com/on July 7,2006.
40 Village of Buchanan, New York (VBNY). 2006. Buchanan Water Department, Entergy Nuclear 41 Operations, March, April, and May 2006 Account Statements.
Draft NUREG-1437, Supplement 38 2-158 December 2008 OAG10001366_00193
Plant and the Environment 1 Village of Croton-on-Hudson (VCOH). 2005. "Annual Water Quality Report 2005." Accessed at 2 http://Village.croton 3 onhudson. ny. us/Public_Documents/CrotonHudsonNY_ WebDocs/Water/CCReport2005. pdf on 4 July 14, 2006.
5 Village of Ossining Water System (VOWS). 2005. "Annual Drinking Water Report for 2005."
6 Accessed at http://www.Village.ossining.ny.us/documents/wqr_2005.pdf on July 14, 2006.
7 Waldman, J.R., K.E. Limburg, and D.L. Strayer. 2006. "The Hudson River Environment and Its 8 Dynamic Fish Community." American Fisheries Society Symposium 51, pp. 1-7.
9 Walter, J.F., A.S. Overton, K.H. Ferry, and M.E. Mather. 2003. "Atlantic Coast Feeding Habits 10 of Striped Bass: A Synthesis Supporting a Coast-wide Understanding of Trophic Biology."
11 Fisheries Management and Ecology 10 (5), pp. 349-360.
12 Westchester County Department of Planning (WCDP). 2003. "Northern Westchester County, 13 Groundwater Conditions Summary, Data Gaps, and Program Recommendations Contract C PL-14 02-71." Prepared by The Chazen Companies, April 2003.
15 Westchester County Department of Planning (WCDP). 2005. "Databook Westchester County, 16 Education, School Districts 2003." November 30,2005.
17 Westchester County Department of Planning. 2000. Westchester County Databook: History, 18 Geography and Land Use. Accessed at 19 http://www.westchestergov.com/planning/research/main.htm on May 31,2006. ADAMS 20 Accession No. ML083380659.
21 Westchester Joint Water Works (WJWW). 2006. "Annual Drinking Water Quality Report for 22 2005." Accessed at http://www.wjww.com on June 30, 2006. ADAMS Accession No.
23 M L083380661.
24 Whitaker, J.O., Jr. 1980. The Audubon Society Field Guide to North American Mammals. 745 25 pp. Alfred A. Knopf, Inc., New York.
26 Whiteside, B.G., and T.H. Bonner. 2007. "Trinectes maculates fasciatus: Hogchoker."
27 Department of Biology, Texas State University, San Marcos. Accessed at 28 http://www. bio. txstate. edu/-tbonner/txfishes/trinectes%20maculatus%20fasciatus. htm on 29 February 19, 2008. ADAMS Accession No. ML083380667.
30 Wingate, R.L. and D.H. Secor. 2007. "Intercept Telemetry of the Hudson River Striped Bass 31 Resident Contingent: Migration and Homing Patterns." Transactions of the American Fisheries 32 Society 136, pp.95-104.
33 Wirgin, I., L. Maceda, J.R. Waldman, and R.N Crittenden. 1993. "Use of Mitochondrial DNA 34 Polymorphisms to Estimate the Relative Contributions of the Hudson River and Chesapeake 35 Bay Striped Bass Stocks to the Mixed Fishery on the Atlantic Coast." Transactions of the 36 American Fisheries Society 122, pp. 669--684.
37 Wirgin, I., and R.C. Chambers. 2006. "Atlantic Tomcod Microgadus tomcod: A Model Species 38 for the Responses of Hudson River Fish to Toxicants." American Fisheries Society Symposium 39 51, pp. 331-365.
December 2008 2-159 Draft NUREG-1437, Supplement 38 OAG10001366_00194
Plant and the Environment 1 Wolfe, D.A., E.R. Long, and G.B. Thursby. 1996. "Sediment Toxicity in the Hudson-Raritan 2 Estuary: Distribution and Correlations with Chemical Contamination." Estuaries 19:4, pp. 901-3 912.
4 Woodland, R.J., and D.H. Secor. 2007. "Year-Class Strength and Recovery of Endangered 5 Shortnose Sturgeon in the Hudson River, New York." Transactions of the American Fisheries 6 Society 136, pp. 72-81.
7 World Book Encyclopedia. 2006. "New York Climate." Chicag York Climate." Chicago, IL.
Draft NUREG-1437, Supplement 38 2-160 December 2008 OAG10001366_00195
1 3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT 2 Environmental issues associated with refurbishment activities are discussed in NUREG-1437, 3 Volumes 1 and 2, "Generic Environmental Impact Statement for License Renewal of Nuclear 4 Plants" (hereafter referred to as the GElS) (NRC 1996, 1999).(1) The GElS includes a 5 determination of whether the analysis of the environmental issues could be applied to all plants 6 and whether additional mitigation measures would be warranted. Issues are then assigned a 7 Category 1 or a Category 2 designation. As set forth in the GElS, Category 1 issues are those 8 that meet all of the following criteria:
9 (1) The environmental impacts associated with the issue have been determined to apply 10 either to all plants or, for some issues, to plants having a specific type of cooling system 11 or other specified plant or site characteristics.
12 (2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 13 the impacts (except for collective offsite radiological impacts from the fuel cycle and from 14 high-level waste and spent fuel disposal).
15 (3) Mitigation of adverse impacts associated with the issue has been considered in the 16 analysis, and it has been determined that additional plant-specific mitigation measures 17 are likely not to be sufficiently beneficial to warrant implementation.
18 For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 19 required in this draft supplemental environmental impact statement (draft SEIS) unless new and 20 significant information is identified.
21 Category 2 issues are those that do not meet one or more of the criteria for Category 1, and 22 therefore, additional plant-specific review of these issues is required.
23 License renewal actions may include associated refurbishment actions that provide for safe and 24 economic operation during the period of extended operation. These actions may have impacts 25 on the environment that require evaluation, depending on the type of action and the plant-26 specific design.
(1)
The GElS was originally issued in 1996. Addendum 1 to the GElS was issued in 1999. Hereafter, all references to the "GElS" include the GElS and its Addendum 1.
December 2008 3-1 Draft NUREG-1437, Supplement 38 OAG10001366_00196
Environmental Impacts of Refurbishment 1 3.1 Potential Refurbishment Activities 2 Entergy, in its environmental report, stated that its evaluation of structures and components 3 required by Title 10, Section 54.21, "Contents of Application-Technical Information," of the 4 Code of Federal Regulations (10 CFR 54.21), did not identify the need for refurbishment of 5 structures or components for purposes of license renewal and that Entergy planned no such 6 refurbishment activities (Entergy 2007). Entergy indicated that routine operational and 7 maintenance activities would be performed during the license renewal period but that they were 8 not refurbishment activities as described in the GElS.
9 During the license renewal environmental scoping process, the staff of the U.S. Nuclear 10 Regulatory Commission (NRC) received comments (Kaplowitz 2007; Shapiro 2007) indicating 11 that Entergy had taken steps toward procuring replacement reactor vessel heads and control 12 rod drive mechanisms (CRDMs) for Indian Point Nuclear Generating Unit Nos. 2 and 3 (lP2 and 13 IP3). The scoping comments indicated that an overseas firm plans to deliver replacement 14 reactor vessel heads and CRDMs for IP2 and IP3 in October 2011 and October 2012, 15 respectively. Based on this information, the staff requested, by letter to Entergy dated 16 December 5, 2007, additional information regarding these potential refurbishment activities 17 (NRC 2007).
18 Entergy's response, dated January 4,2008, indicated that "no reactor vessel head 19 replacements are required for purposes of aging management during the period of extended 20 operation. Accordingly, no evaluation of the environmental impacts of reactor vessel head 21 replacement as a refurbishment activity is required or presented in the Environmental Report."
22 The response also stated that "the decision to proceed with procurement of long lead items 23 [replacement vessel heads] is strictly economic" and therefore need not be addressed in 24 Entergy's environmental report (Entergy 2008a).
25 During a telephone conference call on March 18,2008 (NRC 2008a), the staff acknowledged 26 that while there may be no requirement to replace the reactor vessel heads at IP2 and IP3 for 27 license renewal, Section 2.6.1 of the GElS discusses initiating actions for environmental impacts 28 associated with license renewal. These actions include (1) refurbishment, repair, or 29 replacement activities that "may be performed to ensure that this objective [aging management 30 and maintaining functionality of certain SSCs] is achieved" and (2) activities that licensees may 31 choose to undertake, including "various refurbishment and upgrade activities at their nuclear 32 facilities to better maintain or improve reliability, performance, and economics of power plant 33 operation during the extended period of operation." Since the GElS considers refurbishment 34 activities beyond those that are related to aging management during the period of extended 35 operation, the NRC staff indicated that Entergy's response to the staff's request for additional 36 information (RAI) did not effectively address the staff's need for information about the potential 37 refurbishment activities.
38 During the conference call, Entergy staff indicated that, if license renewal were not being 39 pursued for IP2 and IP3, Entergy would not have ordered the vessel head forgings. Entergy 40 also indicated that the vessel head forgings that were procured for IP2 and IP3 may never be 41 needed at IP2 and IP3.
42 Given that Entergy has taken steps toward obtaining the replacement reactor vessel heads and Draft NUREG-1437, Supplement 38 3-2 December 2008 OAG10001366_00197
Environmental Impacts of Refurbishment 1 CRDMs, and given that these replacement activities, should they occur, would be associated 2 with license renewal (i.e., they would not be undertaken in the absence of license renewal), the 3 NRC staff issued an additional RAI on April 14, 2008 (NRC 2008b), in which the staff requested 4 information from Entergy regarding the process Entergy would use in deciding whether to 5 replace the vessel heads and CRDMs, as well as indicating the potential environmental impacts 6 of these replacement activities. Entergy submitted its response to NRC on May 14, 2008 7 (Entergy 2008b).
8 In its RAI response, Entergy reasserted that it did not believe vessel head and CRDM 9 replacement constituted a refurbishment activity (Entergy 2008b). In addition, the response 10 indicated that the current vessel heads are in good condition, though Entergy may eventually 11 decide to replace them pending the results of future inspections.
12 Entergy's response also provided a likely hypothetical scenario for the replacement activities, 13 should they occur. The scenario includes the following characteristics (Entergy 2008b):
14
- Approximately 250 additional workers would be required for the replacement of each 15 reactor vessel head and CRDM. The replacement would take place during a 60-day 16 refueling outage for each unit, when approximately 950 refueling outage workers are at 17 the Indian Point site. An additional 50 workers would be required to construct the vessel 18 head storage structure, though their work would be largely completed before the 19 beginning of the refueling outage.
20
- The reactor vessel heads would be manufactured overseas, transported to a U.S. port, 21 and shipped up the Hudson River via barge, with the CRDMs installed, to the existing IP 22 barge slip.
23
- Once delivered to the IP2 and IP3 site, storage and preinstallation preparation would 24 take place at onsite temporary structures. If possible, existing warehouses would also 25 be used. The only permanent building constructed would be used to store the old 26 reactor vessel heads and CRDMs; this building would likely be constructed near the 27 onsite structure storing the old IP2 and IP3 steam generators and occupy less than 446 28 square meters (4800 square feet). All structures would be constructed on previously 29 disturbed areas.
30
- Staff or contractors would cut a temporary opening in containment approximately 7.6 by 31 7.9 meters (26 feet by 25 feet) to allow for removal of the old heads and CRDMs and 32 installation of the new ones. Containment concrete would be removed by hydro-33 demolition, while rebar and a portion of steel liner would be removed by other means.
34
- Before removing the old reactor vessel head from containment, Entergy would remove 35 any loose contamination or affix it with a coating. The old head would then be 36 transported to the onsite storage facility (for possible offsite permanent disposition).
37 Meanwhile, the new head (with CRDMs) would be installed.
38
- Upon project completion, each unit's containment would be returned to its original 39 configuration.
40 The NRC staff considered the GElS guidance on refurbishment activities, the need to disclose December 2008 3-3 Draft NUREG-1437, Supplement 38 OAG10001366_00198
Environmental Impacts of Refurbishment 1 potential impacts of the proposed action, and Entergy's analysis of possible impacts of vessel 2 head and CRDM replacements. The NRC staff also acknowledged that vessel head and CRDM 3 replacements may not occur. Nevertheless, to ensure that, should these refurbishment 4 activities occur, their environmental impacts will have been characterized and disclosed in 5 accordance with the National Environmental Policy Act and NRC implementing regulations, the 6 NRC staff determined that it would be appropriate to evaluate the potential impacts of these 7 possible replacement activities using the GElS framework for refurbishment.
8 3.1 Refurbishment Impacts 9 The IP2 and IP3 site was one of seven case study reactor locations the NRC staff used in 10 determining potential environmental impacts from refurbishment activities while developing the 11 GElS. After reviewing construction-stage impacts at these seven plant sites and then scaling 12 them down to better approximate the duration and intensity of impacts expected during plant 13 refurbishment activities, the NRC staff determined that nine refurbishment-related issues would 14 be Category 1 issues. The GElS approach to refurbishment assumed longer duration outages, 15 more workers, and a wider array of activities on site than would occur during the reactor vessel 16 head and CRDM replacement project discussed here. The GElS also noted, in Appendix 8, 17 that outages would grow shorter as licensees gained experience with major replacement 18 activities. Additionally, the GElS noted that some licensees may choose to perform only a few 19 activities.
20 Even given larger workforces, more activities, and longer outages, the NRC staff determined in 21 the GElS that the impacts for these nine issues are SMALL.
22 Table 3-1 contains a list of Category 1 issues associated with refurbishment.
Draft NUREG-1437, Supplement 38 3-4 December 2008 OAG10001366_00199
Environmental Impacts of Refurbishment 1 Table 3-1. Category 1 Issues for Refurbishment Evaluation ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Sections Surface Water Quality, Hydrology, and Use (for all plants)
Impacts of refurbishment on surface water quality 3.4.1 Impacts of refurbishment on surface water use 3.4.1 Aquatic Ecology (for all plants)
Refurbishment 3.5 Ground Water Use and Quality Impacts of refurbishment on ground water use and quality 3.4.2 Land Use Onsite land use 3.2 Human Health Radiation exposures to the public during refurbishment 3.8.1 Occupational radiation exposures during refurbishment 3.8.2 Socioeconomics Public services: public safety, social services, and tourism and 3.7.4,3.7.4.3, recreation 3.7.4.4, 3.7.4.6 Aesthetic impacts (refurbishment) 3.7.8 2 Provided below are the results of the NRC staff reviews and a brief statement of GElS 3 conclusions, as codified in Table B-1 of 10 CFR Part 51, "Environmental Protection Regulations 4 for Domestic Licensing and Related Regulatory Functions," Subpart A, "National Environmental 5 Policy Act-Regulations Implementing Section 102(2)," Appendix B, "Environmental Effect of 6 Renewing the Operating License of a Nuclear Power Plant," for each of the Category 1 7 refurbishment issues listed in Table 3-1. For each Category 1 issue, the NRC staff has not 8 identified any new and significant information during its review of the Entergy environmental 9 report (Entergy 2007), its site audit, the SEIS scoping process, and its evaluation of other 10 available information, including Entergy's May 14, 2008, RAI response (Entergy 2008b).
11
- Impacts of refurbishment on surface water quality. Based on information in the GElS, 12 the Commission found the following:
13 Impacts are expected to be negligible during refurbishment because best 14 management practices are expected to be employed to control soil erosion and 15 spills.
16
- Impacts of refurbishment on surface water use. Based on information in the GElS, the 17 Commission found the following:
18 Water use during refurbishment will not increase appreciably or will be reduced 19 during plant outage.
December 2008 3-5 Draft NUREG-1437, Supplement 38 OAG10001366_00200
Environmental Impacts of Refurbishment 1
- Impacts of refurbishment on aquatic biota. Based on information in the GElS, the 2 Commission found the following:
3 During plant shutdown and refurbishment there will be negligible effects on 4 aquatic biota because of a reduction of entrainment and impingement of 5 organisms or a reduced release of chemicals.
6
- Impacts of refurbishment on ground water use and quality. Based on information in the 7 GElS, the Commission found the following:
8 Extensive dewatering during the original construction on some sites will not be 9 repeated during refurbishment on any sites. Any plant wastes produced during 10 refurbishment will be handled in the same manner as in current operating 11 practices and are not expected to be a problem during the license renewal term.
12
- Impacts of refurbishment on onsite land use. Based on information in the GElS, the 13 Commission found the following:
14 Projected onsite land use changes required during refurbishment and the 15 renewal period would be a small fraction of any nuclear power plant site and 16 would involve land that is controlled by the applicant.
17
- Radiation exposures to the public during refurbishment. Based on information in the 18 GElS, the Commission found the following:
19 During refurbishment, the gaseous effluents would result in doses that are similar 20 to those from current operation. Applicable regulatory dose limits to the public 21 are not expected to be exceeded.
22
- Occupational radiation exposures during refurbishment. Based on information in the 23 GElS, the Commission found the following:
24 Occupational doses from refurbishment are expected to be within the range of 25 annual average collective doses experienced for pressurized-water reactors and 26 boiling-water reactors. Occupational mortality risks from all causes including 27 radiation is in the mid-range for industrial settings.
28
- Public services: public safety, social services, and tourism and recreation. Based on 29 information in the GElS, the Commission found the following:
30 Impacts to public safety, social services, and tourism and recreation are 31 expected to be of small significance at all sites.
32
- Aesthetic impacts (refurbishment). Based on information in the GElS, the Commission 33 found the following:
34 No significant impacts are expected during refurbishment.
35 The NRC staff identified no new and significant information related to these issues during its 36 review of the Entergy ER, during the SEIS scoping process, in correspondence identified in 37 Section 3.1 of this chapter, or in Entergy's May 14, 2008, RAI response (Entergy 2008b).
38 Therefore, the NRC staff expects that there would be no impacts during the renewal term Draft NUREG-1437, Supplement 38 3-6 December 2008 OAG10001366_00201
Environmental Impacts of Refurbishment 1 beyond those discussed in the GElS.
2 Environmental issues related to refurbishment considered in the GElS for which these 3 conclusions could not be reached for all plants, or for specific classes of plants, are Category 2 4 issues. These are listed in Table 3-2.
5 Table 3-2. Category 2 Issues for Refurbishment Evaluation 10 CFR 51.53 GElS (c)(3)(ii)
ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 Sections Subparagraph Terrestrial Resources Refurbishment impacts 3.6 E Threatened or Endangered Species (for all plants)
Threatened or endangered species 3.9 E Air Quality Air quality during refurbishment (nonattainment and 3.3 F maintenance areas)
Socioeconomics Housing impacts 3.7.2 Public services: public utilities 3.7.4.5 Public services: education (refurbishment) 3.7.4.1 Offsite land use (refurbishment) 3.7.5 Public services, transportation 3.7.4.2 J Historic and archeological resources 3.7.7 K 6 ENVIRONMENTAL JUSTICE Environmental justice Not addressed(a) Not addressed(a)
(a) Environmental justice is not addressed in the GElS because Executive Order 12898 issued on February 11, 1994, and implementation guidance were not available prior to completion of the GElS. Table B-1 of Appendix B, Part A of 10 CFR Part 51 indicates that this issue will be addressed in site specific reviews. The NRC staff groups Environmental Justice with Category 2 issues because the NRC staff addresses it in site specific reviews along with Category 2 issues.
7 The results of the review for each Category 2 refurbishment issue are provided in the following 8 sections.
9 3.1.1 Terrestrial Ecology-Refurbishment Impacts 10 Refurbishment impacts on terrestrial ecology are a Category 2 issue (10 CFR Part 51, 11 Subpart A, Appendix B, Table B-1). Table B-1 notes that "Refurbishment impacts are 12 insignificant if no loss of important plant and animal habitat occurs. However, it cannot be 13 known whether important plant and animal communities may be affected until the specific December 2008 3-7 Draft NUREG-1437, Supplement 38 OAG10001366_00202
Environmental Impacts of Refurbishment 1 proposal is presented with the license renewal application."
2 As stated in Section 4.4.5.2, Entergy has not proposed any new facilities, service roads, or 3 transmission lines for IP2 and IP3 associated with continued operations or refurbishment.
4 Entergy indicated, however, that it may replace the reactor vessel heads and CRDMs for IP2 5 and IP3 during the license renewal term. Ground-disturbing activities associated with this 6 project would involve the construction of a storage building to house the retired components 7 (Entergy 2008b). This area was previously disturbed by the construction of IP2 and IP3.
8 Activities associated with the transport of the new reactor vessel heads and CRDMs would 9 result in no additional land disturbance. The replacement components would arrive by barge 10 and be transported over an existing service road by an all-terrain vehicle (Entergy 2008b). The 11 route through which the service road passes was previously disturbed by the construction of all 12 three IP units. Because Entergy plans to conduct all of these activities on previously disturbed 13 land within a relatively short period of finite duration, the level of impact on terrestrial natural 14 resources is expected to be SMALL.
15 Mitigation measures would include routine land and vegetation management practices, as well 16 as using the most disturbed areas possible for new buildings and staging areas. The NRC staff 17 did not identify any cost-benefit studies associated with these measures.
18 3.1.2 Threatened or Endangered Species-Refurbishment Impacts 19 Refurbishment impacts on threatened or endangered species are a Category 2 issue.
20 Table B-1 of Appendix B to 10 CFR Part 51, Subpart A, notes the following:
21 Generally, plant refurbishment and continued operation are not expected to 22 adversely affect threatened and endangered species. However, consultation 23 with appropriate agencies would be needed at the time of license renewal to 24 determine whether threatened or endangered species are present and whether 25 they would be adversely affected.
26 The NRC staff identified three federally listed terrestrial species-bog turtle, C/emmys 27 muhlenbergii; New England cottontail, Sylvi/agus transitionaJis; and Indiana bat, Myotis 28 sodaJist-and one aquatic species-shortnose sturgeon, Acipenser brevirostrum-potentially 29 affected by the relicensing of Indian Point. As explained above under Section 3.1.1, Entergy 30 plans to conduct all terrestrial refurbishment activities on previously disturbed land within a 31 relatively short period of finite duration. Entergy does not plan to conduct these activities on 32 undisturbed land, and no designated critical habitat occurs on the site (Entergy 2008b). As a 33 result, the NRC staff finds that refurbishment activities are not likely to adversely affect the 34 continued existence of listed terrestrial species or adversely modify designated critical habitats.
35 Based on analyses presented in Section 4.6.1, shortnose sturgeon eggs and larvae probably do 36 not occur, or occur only rarely, in the vicinity of Indian Point. Juvenile and adult shortnose 37 sturgeon do occur in the vicinity of Indian Point. For refurbishment, the replacement 38 components would arrive by barge and be transported over an existing service road by an all-39 terrain vehicle (Entergy 2008b). Entergy does not have plans to dredge to accommodate the 40 barge at its dock and is not planning any other activities that would adversely affect aquatic 41 species or habitats. Also, any onsite activities will have to follow existing regulations to control 42 runoff from construction or industrial sites. Because no activities are planned that would Draft NUREG-1437, Supplement 38 3-8 December 2008 OAG10001366_00203
Environmental Impacts of Refurbishment 1 adversely affect the aquatic environment, refurbishment activities are not likely to adversely 2 affect the continued existence of endangered shortnose sturgeon.
3 Essential fish habitat, as defined under the 1996 amendments to the Magnuson-Stevens 4 Fishery Conservation and Management Act, occurs in the vicinity of IP2 and IP3 for red hake 5 (Urophycis chuss) larvae, winter flounder (Pleuronectes american us) larvae, windowpane 6 (Scophtha/mus aquosus) juveniles and adults, and Atlantic butterfish (Peprilus triacanthus) 7 juveniles and adults. Because Entergy plans no refurbishment activities that would adversely 8 affect the aquatic environment, there should be no adverse individual or cumulative effects on 9 essential fish habitat in the project area.
10 3.1.3 Air Quality During Refurbishment (Nonattainment and Maintenance Areas) 11 Air quality during refurbishment (nonattainment and maintenance areas) is a Category 2 issue.
12 Table B-1 of Appendix B to 10 CFR Part 51, Subpart A, notes the following:
13 Air quality impacts from plant refurbishment associated with license renewal are 14 expected to be small. However, vehicle exhaust emissions could be cause for 15 concern at locations in or near nonattainment or maintenance areas. The 16 significance of the potential impact cannot be determined without considering the 17 compliance status of each site and the numbers of workers expected to be 18 employed during the outage.
19 The May 14, 2008, RAI response from Entergy indicates that the replacement of reactor vessel 20 heads and CRDMs for IP2 and IP3 will result in minor impacts to air quality. Citing the GElS, 21 Entergy states that the only potential sources of impacts to air quality would be (1) fugitive dust 22 from site excavation and grading for construction of any new waste storage facilities and (2) 23 emissions from motorized equipment and workers' vehicles.
24 Entergy indicates that the bulk of air quality impacts during the postulated refurbishment activity 25 would result from exhaust emissions released by onsite motorized equipment and workers' 26 vehicles (Entergy 2008b). These effects include temporary increases in atmospheric 27 concentrations of nitrogen oxides (NOx), carbon monoxide (CO), sulfur dioxide (S02), volatile 28 organic compounds (VOC), ammonia, and particulate matter (PM).
29 A table summarizing the attainment status of the counties within the immediate area of IP2 and 30 IP3 shows nonattainment of the National Ambient Air Quality Standards (NAAQS) for 8-hour 31 ozone in Dutchess, Orange, Putnam, Rockland, and Westchester Counties. There is 32 nonattainment of the NAAQS for PM 2.5 in Orange, Rockland, and Westchester Counties.
33 Westchester County is designated as a maintenance county for CO.
34 Based on a conservative assumption that 400 additional vehicles would travel to and from the 35 site each day during a 65-day outage period (conservative because Entergy projects that only 36 300 additional workers over 60 days could accomplish the replacement activities), Entergy 37 estimated that air emissions of VOCs, CO, and NOx would increase by 0.95 tons (0.86 metric 38 tons (MT)), 16.1 tons (14.6 MT), and 1.02 tons (0.925 MT), respectively (Entergy 2008b). The 39 regulatory conformity thresholds for VOCs, CO, and NOx are 50 tons (45 MT), 100 tons 40 (90.7 MT), and 50 tons (45 MT), respectively, as indicated in 40 CFR Part 51.853(b). A 41 comparison of Entergy's conservative estimates for vehicle emissions versus the associated 42 regulatory conformity levels indicates that none of the thresholds would be exceeded. Based on December 2008 3-9 Draft NUREG-1437, Supplement 38 OAG10001366_00204
Environmental Impacts of Refurbishment 1 this analysis, the NRC staff finds that air quality impacts during the postulated reactor vessel 2 head and CRDM replacement would be SMALL.
3 The NRC staff identified a variety of measures that could mitigate potential air quality impacts 4 resulting from the vessel head and CRDM replacements at IP2 and IP3. These include the use 5 of multiperson vans and carpooling policies to reduce the number of vehicles used to transport 6 workers to the site. The NRC staff did not identify any cost-benefit studies applicable to these 7 mitigation measures.
8 3.1.4 Housing Impacts-Refurbishment 9 Housing impacts during refurbishment are a Category 2 issue. Table B-1 of Appendix B to 10 10 CFR Part 51, Subpart A, notes the following:
11 Housing impacts are expected to be of small significance at plants located in a 12 medium or high population area and not in an area where growth control 13 measures that limit housing development are in effect. Moderate or large 14 housing impacts of the workforce associated with refurbishment may be 15 associated with plants located in sparsely populated areas or in areas with 16 growth control measures that limit housing development.
17 Entergy estimates that reactor vessel head and CRDM replacement would increase the number 18 of refueling outage workers at the Indian Point site for up to 60 days during two separate 19 refueling outages, one for each unit, 12 months apart. Approximately 250 workers would be 20 needed for each replacement in addition to the normal number of refueling outage workers. An 21 additional 50 workers would construct a storage structure for the old reactor vessel heads and 22 CRDMs. This work would be completed before the beginning of the refueling outage (Entergy 23 2008b).
24 The number of additional workers would cause a short-term increase in the demand for 25 temporary (rental) housing units in the region beyond what is normally experienced during a 26 refueling outage at the Indian Point site. Since IP2 and IP3 are located in a high-population 27 area (see Section 2.2.8.5) and the number of available housing units has either kept pace with 28 or exceeded changes in county populations (see Section 2.2.8.1), any changes in employment 29 would have no noticeable effect on the availability of housing in the socioeconomic region of 30 influence. Because of the short duration of the replacement activity for each unit's reactor 31 vessel head and CRDMs and the availability of housing in the region, employment-related 32 housing impacts would have no noticeable impact.
33 3.1.5 Public Services: Public Utilities-Refurbishment 34 Public utilities is a Category 2 refurbishment issue. Table B-1 of Appendix B to 10 CFR Part 51, 35 Subpart A, notes that "[a]n increased problem with water shortages at some sites may lead to 36 impacts of moderate significance on public water supply availability."
37 Since there is no water shortage in the region and public water systems located in Dutchess, 38 Orange, and Putnam Counties have excess capacity (indicated in Table 2-9 in Chapter 2), any 39 changes in the Indian Point site and employee public water usage would have little noticeable 40 effect on public water supply availability in these counties. As discussed in Section 2.2.8.2, the Draft NUREG-1437, Supplement 38 3-10 December 2008 OAG10001366_00205
Environmental Impacts of Refurbishment 1 Indian Point site acquires potable water from the Village of Buchanan water supply system, and 2 there are no restrictions on the supply of potable water from the village.
3 As discussed in Section 3.1.4, Entergy estimates that reactor vessel head and CRDM 4 replacement would increase the number of refueling outage workers at the Indian Point site for 5 up to 60 days during two separate refueling outages, one for each unit, 12 months apart 6 (Entergy 2008b). The additional number of refueling outage workers needed to replace the 7 reactor vessel heads and CRDMs would cause short-term increases in the amount of public 8 water and sewer services used in the immediate vicinity of the Indian Point site. Since the 9 region has excess water supply capacity with no restrictions, these activities would create no 10 impacts.
11 3.1.6 Public Services: Education-Refurbishment 12 Education is a Category 2 refurbishment issue. Table B-1 of Appendix B to 10 CFR Part 51, 13 Subpart A, notes that "[m]ost sites would experience impacts of small significance but larger 14 impacts are possible depending on site- and project-specific factors."
15 As discussed in Section 3.1.4, Entergy estimates that reactor vessel head and CRDM 16 replacement would increase the number of refueling outage workers for up to 60 days at the 17 Indian Point site (Entergy 2008b). Because of the short duration of the replacement activity for 18 each unit's reactor vessel head and CRDMs, workers would not be expected to bring families 19 and school-age children with them; therefore, there would be no impact on educational services 20 during this extended refueling outage.
21 3.1.7 Offsite Land Use-Refurbishment 22 Offsite land use is a Category 2 refurbishment issue. Table B-1 of Appendix B to 23 10 CFR Part 51, Subpart A, notes that "Impacts may be of moderate significance at plants in 24 low population areas."
25 Since IP2 and IP3 are located in a high-population area, any changes in employment would 26 have little noticeable effect on land use in the region. Because of the short duration of the 27 replacement activity for each unit's reactor vessel head and CRDMs, the additional number of 28 refueling outage workers would not cause any permanent changes in population and tax-29 revenue-related land use in the immediate vicinity of IP2 and IP3.
30 3.1.8 Public Services: Transportation-Refurbishment 31 Transportation is a Category 2 refurbishment issue. Table B-1 of Appendix B to 32 10 CFR Part 51, Subpart A, notes the following:
33 Transportation impacts (level of service) of highway traffic generated during plant 34 refurbishment and during the term of the renewed license are generally expected 35 to be of small significance. However, the increase in traffic associated with 36 additional workers and the local road and traffic control conditions may lead to 37 impacts of moderate or large significance at some sites.
38 The additional number of refueling outage workers and truck material deliveries needed to December 2008 3-11 Draft NUREG-1437, Supplement 38 OAG10001366_00206
Environmental Impacts of Refurbishment 1 support the replacement of each reactor vessel head and CRDM would cause short-term level-2 of-service impacts on access roads in the immediate vicinity of the Indian Point site. According 3 to Entergy, increased traffic volumes entering and leaving the Indian Point site during refueling 4 outages, which occur at intervals of approximately 12 months for one unit or the other, have not 5 degraded the level-of-service capacity on local roads, and the higher number of refueling outage 6 workers during IP2 and IP3 steam generator replacement outages did not require any road 7 improvements (Entergy 2008b). During routine periods of high traffic volume (i.e., morning and 8 afternoon shift changes), Entergy has previously employed staggered shifts (starting and 9 quitting times) during refueling outages to minimize level-of-service impacts on State Routes 9 10 and 9A (Entergy 2008b). Based on this information and because of the short duration of the 11 replacement activity for each unit's reactor vessel head and CRDMs (up to 60 days), and given 12 that the activity occurs at the same time as a normal refueling outage, the NRC staff finds that 13 no transportation (level-of-service) impacts, beyond impacts from normal outages, would occur.
14 3.1.9 Historic and Archeological Resources-Refurbishment 15 Historic and archeological resources is a Category 2 refurbishment issue. Table B-1 of 16 Appendix B to 10 CFR Part 51, Subpart A, notes the following:
17 Generally, plant refurbishment and continued operation are expected to have no 18 more than small adverse impacts on historic and archaeological resources.
19 However, the National Historic Preservation Act requires the Federal agency to 20 consult with the State Historic Preservation Officer to determine whether there 21 are properties present that require protection.
22 As stated in Section 4.4.5.2, Entergy has not proposed any new facilities, service roads, or 23 transmission lines for IP2 and IP3 associated with continued operations or refurbishment.
24 However, Entergy indicated that it may replace the reactor vessel heads and CRDMs for IP2 25 and IP3 during the license renewal term. Ground-disturbing activities associated with this 26 project would involve the construction of a storage building to house the retired components 27 (Entergy 2008b). Should Entergy replace the vessel heads and CRDMs, ground-disturbing 28 activities would be reviewed in accordance with Entergy Nuclear fleet procedures, which are 29 designed to ensure that investigations and consultations are conducted as needed and that 30 existing or potentially existing cultural resources are adequately protected (Enercon 2006). The 31 procedures have been reviewed by the New York State Historic Preservation Office (NY 32 SHPO). According to Entergy, the area of construction would be in an area that requires no 33 prior consultation for historic, cultural, or archeological resources (Entergy 2008b). This area 34 was previously disturbed by the construction of IP2 and IP3.
35 Activities associated with the transport of the new reactor vessel heads and CRDMs would 36 result in no additional land disturbance. The replacement components would arrive by barge 37 and be transported over an existing service road by an all-terrain vehicle (Entergy 2008b). The 38 route through which the service road passes was previously disturbed by the construction of all 39 three IP units.
40 The impacts associated with this activity are not expected to adversely impact historic or 41 archeological sites in the area of IP2 and IP3. Therefore, the potential impacts from this activity 42 on National Register-eligible historic or archeological resources would be SMALL. However, 43 should archeological resources be encountered during construction, work would cease until Draft NUREG-1437, Supplement 38 3-12 December 2008 OAG10001366_00207
Environmental Impacts of Refurbishment 1 Entergy environmental personnel would perform an evaluation and consider possible mitigation 2 measures through consultation with the NY SHPO.
3 3.1.10 Environmental Justice-Refurbishment 4 Environmental justice is a plant-specific refurbishment issue. Table B-1 of Appendix B to 5 10 CFR Part 51, Subpart A, notes that "[t]he need for and the content of an analysis of 6 environmental justice will be addressed in plant specific reviews."
7 Since IP2 and IP3 are located in a high-population area, the small, short duration change in 8 employment associated with the potential replacement activities would likely have no noticeable 9 effect on minority and/or low-income populations in the region. Because of the short duration of 10 the replacement activity for each unit's reactor vessel head and CRDMs, and based on the 11 analysis of impacts for the other resource areas discussed in Section 3.1, there would be no 12 disproportionately high and adverse impacts to minority and low-income populations in the 13 immediate vicinity of IP2 and IP3.
14 3.2 Evaluation of New and Potentially Significant Information on 15 Impacts of Refurbishment 16 Entergy, in its May 14, 2008, RAI response (Entergy 2008b), indicated that it had reviewed the 17 findings included in Chapter 3 of the GElS and identified no new and significant information that 18 would invalidate the findings made in the GElS. Further, the NRC staff has reviewed Entergy's 19 response, has evaluated the likely impacts of the vessel head and CRDM replacement, and has 20 not identified any new and significant information associated with these activities.
21 3.3 Summary of Refurbishment Impacts 22 The NRC staff did not identify any information that is either new or significant related to any of 23 the applicable Category 1 issues associated with replacement activities at IP2 and IP3 during 24 the renewal term. The NRC staff concludes that the environmental impacts associated with 25 those issues are bounded by the impacts described in the GElS (NRC 1996). For each of the 26 Category 1 issues addressed in this section, the GElS concludes that impacts would be SMALL 27 and that additional plant-specific mitigation measures are not likely to be sufficiently beneficial to 28 warrant implementation.
29 For all Category 2 issues related to replacement activities at IP2 and IP3, the NRC staff 30 concluded-after reviewing guidance in the GElS and Entergy's description of potential 31 activities-that replacement activities would have SMALL or no impacts. The NRC staff's 32 conclusions for Category 2 impact levels considered the activities' limited scope and duration 33 compared to the refurbishment programs identified in the GElS.
34 3.4 References 35 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 36 Protection Regulations for Domestic Licensing and Related Regulatory Functions."
December 2008 3-13 Draft NUREG-1437, Supplement 38 OAG10001366_00208
Environmental Impacts of Refurbishment 1 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for 2 Renewal of Operating Licenses for Nuclear Power Plants."
3 Entergy Nuclear Operations, Inc. (Entergy). 2007. "Applicant's Environment Report, Operating 4 21 License Renewal Stage." (Appendix E of "IP2 and IP3, Units 2 and 3, License Renewal 22 5 Application"). April 23,2007. Agencywide Documents Access and Management System 6 (ADAMS) Accession No. ML071210530.
7 Entergy Nuclear Operations, Inc. (Entergy). 2008a. "Indian Point, Units 2 and 3-Reply to 8 Request for Additional Information Regarding Environmental Review for License Renewal 9 Application." January 4,2008. ADAMS Accession No. ML080110372.
10 Entergy Nuclear Operations, Inc. (Entergy). 2008b. "Indian Point Units 2 & 3, Reply to Request 11 for Additional Information Regarding License Renewal Application-Refurbishment." May 14, 12 2008. ADAMS Accession No. ML081440052.
13 Kaplowitz, Michael. 2007. Letter to Pao-Tsin Kuo, "Incompleteness and Inaccurate License 14 Renewal Application for Indian Point Energy Center, Units 2 and 3." June 27,2007. ADAMS 15 Accession No. ML071990093.
16 Shapiro, Milton B. and Susan H. Shapiro. 2007. Letter to Pao-Tsin Kuo, "Comments on Scope 17 of Environmental Impact Statement and Scoping Process Indian Point Energy Center Unit 2 and 18 Unit 3." October 24,2007. ADAMS Accession No. ML073100985.
19 U.S. Nuclear Regulatory Commission. 1996. "Generic Environmental Impact Statement for 20 License Renewal of Nuclear Plants." NUREG-1437, Volumes 1 and 2. Office of Nuclear 21 Regulatory Research, Washington, DC.
22 U.S. Nuclear Regulatory Commission. 1999. "Generic Environmental Impact Statement for 23 License Renewal of Nuclear Plant." NUREG-1437, Volume 1, Addendum 1. Office of Nuclear 24 Reactor Regulation, Washington, DC.
25 U.S. Nuclear Regulatory Commission. 2007. "Request for Additional Information Regarding 26 Environmental Review for Indian Point Nuclear Generating Unit Nos. 2 and 3 License Renewal 27 (TAC Nos. MD5411 and MD5412)." December 5, 2007. ADAMS Accession No. ML073330931.
28 U.S. Nuclear Regulatory Commission. 2008a. Summary of Telephone Conference Call 29 between NRC and Entergy Nuclear Operations, Inc., Pertaining to the Indian Point Units 2 & 3, 30 License Renewal Application-Environmental Request for Additional Information. April 9, 2008.
31 ADAMS Accession No. ML080920983.
32 U.S. Nuclear Regulatory Commission. 2008b. "Request for Additional Information Regarding 33 the Review of the License Renewal Application for Indian Point Nuclear Generating Unit Nos. 2 34 & 3 (TAC Nos. MD5411 and MD5412)." April 14, 2008. ADAMS Accession No. ML080940408.
Draft NUREG-1437, Supplement 38 3-14 December 2008 OAG10001366_00209
1 4.0 ENVIRONMENTAL IMPACTS OF OPERATION 2 Environmental issues associated with operation of a nuclear power plant during the renewal 3 term are discussed in NUREG-1437, Volumes 1 and 2, "Generic Environmental Impact 4 Statement for License Renewal of Nuclear Plants" (hereafter referred to as the GElS) (NRC 5 1996, 1999).(1) The GElS includes a determination of whether the analysis of the environmental 6 issues could be applied to all plants and whether additional mitigation measures would be 7 warranted. Issues are then assigned a Category 1 or a Category 2 designation. As set forth in 8 the GElS, Category 1 issues are those that meet all of the following criteria:
9 (1) The environmental impacts associated with the issue have been determined to apply 10 either to all plants or, for some issues, to plants having a specific type of cooling system 11 or other specified plant or site characteristics.
12 (2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 13 the impacts (except for collective offsite radiological impacts from the fuel cycle and from 14 high-level waste and spent fuel disposal).
15 (3) Mitigation of adverse impacts associated with the issue has been considered in the 16 analysis, and it has been determined that additional plant-specific mitigation measures 17 are likely not to be sufficiently beneficial to warrant implementation.
18 For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 19 required unless new and significant information is identified.
20 Category 2 issues are those that do not meet one or more of the criteria for Category 1 and, 21 therefore, additional plant-specific review of these issues is required.
22 This chapter addresses the issues related to operation during the renewal term that are listed in 23 Table 8-1 of Appendix 8 to Subpart A, "Environmental Effect of Renewing the Operating 24 License of a Nuclear Power Plant," of Title 10, Part 51, "Environmental Protection Regulations 25 for Domestic Licensing and Related Regulatory Functions," of the Code of Federal Regulations 26 (10 CFR Part 51) and are applicable to Indian Point Nuclear Generating Units 2 and 3 (lP2 and 27 IP3). In Section 4.1 of this draft supplemental environmental impact statement (SEIS), the U.S.
28 Nuclear Regulatory Commission (NRC) staff addresses issues applicable to the IP2 and IP3 29 cooling systems. In Section 4.2, the NRC staff addresses issues related to transmission lines 30 and onsite land use. In Section 4.3, the NRC staff addresses the radiological impacts of normal 31 operations, and in Section 4.4, the NRC staff addresses issues related to the socioeconomic 32 impacts of normal operations during the renewal term. In Section 4.5, the NRC staff addresses 33 issues related to ground water use and quality, while the NRC staff addresses the impacts of 34 renewal term operations on threatened and endangered species in Section 4.6. The NRC staff 35 addresses potential new information in Section 4.7 and addresses cumulative impacts in 36 Section 4.8. The results of the evaluation of environmental issues related to operation during 37 the renewal term are summarized in Section 4.9. Finally, Section 4.10 lists the references for 38 Chapter 4. Category 1 and Category 2 issues that are not applicable to IP2 and IP3 because 39 they are related to plant design features or site characteristics not found at IP2 and IP3 are (1)
The GElS was originally issued in 1996. Addendum 1 to the GElS was issued in 1999. Hereafter, all references to the GElS include the GElS and its Addendum 1.
December 2008 4-1 Draft NUREG-1437, Supplement 38 OAG10001366_00210
Environmental Impacts of Operation 1 listed in Appendix F to this draft SEIS.
2 4.1 Cooling System 3 Generic (Category 1) issues in Table 8-1 of Appendix 8 to Subpart A of 10 CFR Part 51 that are 4 applicable to IP2 and IP3 cooling system operation during the renewal term are listed in 5 Table 4-1. Entergy Nuclear Indian Point 2 and Entergy Nuclear Indian Point 3, LLC (Entergy) 6 stated in its environmental report (ER) (Entergy 2007a) that it is not aware of any new and 7 significant information associated with the renewal of the IP2 and IP3 operating licenses related 8 to cooling system operation. The NRC staff has not identified any new and significant 9 information related to cooling system operation during its independent review of the Entergy ER, 10 the site visit, the scoping process, or the evaluation of other available information. Therefore, 11 the NRC staff concludes that there are no impacts related to these issues beyond those 12 discussed in the GElS. For all of the Category 1 issues, the NRC staff concluded in the GElS 13 that the impacts would be SMALL, and additional plant-specific mitigation measures are not 14 likely to be sufficiently beneficial to warrant implementation.
15 A brief description of the NRC staff's review and the GElS conclusions, as codified in 16 10 CFR Part 51, Table 8-1, for each of these issues follows.
17 Table 4-1. Generic (Category 1) Issues Applicable to the Operation of the IP2 and IP3 18 Cooling System during the Renewal Term ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Section SURFACE WATER QUALITY, HYDROLOGY, AND USE Altered current patterns at intake and discharge structures 4.2.1.2.1 Temperature effects on sediment transport capacity 4.2.1.2.3 Scouring caused by discharged cooling water 4.2.1.2.3 Eutrophication 4.2.1.2.3 Discharge of chlorine or other biocides 4.2.1.2.4 Discharge of sanitary wastes and minor chemical spills 4.2.1.2.4 Discharge of other metals in wastewater 4.2.1.2.4 Water-use conflicts (plants with once-through cooling systems) 4.2.1.3 AQUATIC ECOLOGY (ALL PLANTS)
Accumulation of contaminants in sediments or biota 4.2.1.2.4 Entrainment of phytoplankton and zooplankton 4.2.2.1.1 Cold shock 4.2.2.1.5 Thermal plume barrier to migrating fish 4.2.2.1.6 Distribution of aquatic organisms 4.2.2.1.6 Premature emergence of aquatic insects 4.2.2.1.7 Gas supersaturation (gas bubble disease) 4.2.2.1.8 Draft NUREG-1437, Supplement 38 4-2 December 2008 OAG10001366_00211
Environmental Impacts of Operation Low dissolved oxygen in the discharge 4.2.2.1.9 Losses from predation, parasitism, and disease among organisms exposed 4.2.2.1.10 to sublethal stresses Stimulation of nuisance organisms 4.2.2.1.11 HUMAN HEALTH Noise 4.3.7 1 The NRC staff reviewed information provided from the Entergy ER, the NRC staff's site visit, the 2 scoping process, the New York State Pollutant Discharge Elimination System (SPDES) permits 3 for IP2 and IP3 that expired in 1992 and the subsequent draft permit, ongoing Hudson River 4 monitoring programs and their results, and other available information. The NRC staff has not 5 identified any new and significant information for Category 1 issues applicable to the operation 6 of the IP2 and IP3 cooling system during the period of extended operation.
7 Therefore, the NRC staff concludes that there would be no impacts for these issues during the 8 renewal term beyond those discussed in the GElS. The following bullets identify the Category 1 9 issues applicable to the operation of the IP2 and IP3 cooling system during the period of 10 extended operation and the Commission's findings as indicated in the GElS:
11
- Altered current patterns at intake and discharge structures. Based on information in the 12 GElS, the Commission found the following:
13 Altered current patterns have not been found to be a problem at operating 14 nuclear power plants and are not expected to be a problem during the license 15 renewal term.
16
- Temperature effects on sediment transport capacity. Based on information in the GElS, 17 the Commission found the following:
18 These effects have not been found to be a problem at operating nuclear power 19 plants and are not expected to be a problem during the license renewal term.
20
- Scouring caused by discharged cooling water. Based on information in the GElS, the 21 Commission found the following:
22 Scouring has not been found to be a problem at most operating nuclear power 23 plants and has caused only localized effects at a few plants. It is not expected to 24 be a problem during the license renewal term.
25
- Eutrophication. Based on information in the GElS, the Commission found the following:
26 Eutrophication has not been found to be a problem at operating nuclear power 27 plants and is not expected to be a problem during the license renewal term.
28
- Discharge of chlorine or other biocides. Based on information in the GElS, the 29 Commission found the following:
30 Effects are not a concern among regulatory and resource agencies, and are not December 2008 4-3 Draft NUREG-1437, Supplement 38 OAG10001366_00212
Environmental Impacts of Operation 1 expected to be a problem during the license renewal term.
2
- Discharge of sanitary wastes and minor chemical spills. Based on information in the 3 GElS, the Commission found the following:
4 Effects are readily controlled through the NPDES permit2 and periodic 5 modifications, if needed, and are not expected to be a problem during the license 6 renewal term.
7
- Discharge of other metals in wastewater. Based on information in the GElS, the 8 Commission found the following:
9 These discharges have not been found to be a problem at operating nuclear 10 power plants with cooling-tower-based heat dissipation systems and have been 11 satisfactorily mitigated at other plants. They are not expected to be a problem 12 during the license renewal term.
13
- Water-use conflicts (plants with once-through cooling systems). Based on information in 14 the GElS, the Commission found the following:
15 These conflicts have not been found to be a problem at operating nuclear power 16 plants with once-through heat dissipation systems.
17
- Accumulation of contaminants in sediments or biota. Based on information in the GElS, 18 the Commission found the following:
19 Accumulation of contaminants has been a concern at a few nuclear power plants 20 but has been satisfactorily mitigated by replacing copper alloy condenser tubes 21 with those of another metal. It is not expected to be a problem during the license 22 renewal term.
23
- Entrainment of phytoplankton and zooplankton. Based on information in the GElS, the 24 Commission found the following:
25 Entrainment of phytoplankton and zooplankton has not been found to be a 26 problem at operating nuclear power plants and is not expected to be a problem 27 during the license renewal term.
28
- Cold shock. Based on information in the GElS, the Commission found the following:
29 Cold shock has been satisfactorily mitigated at operating nuclear plants with 30 once-through cooling systems, has not endangered fish populations or been 31 found to be a problem at operating nuclear power plants with cooling towers or 32 cooling ponds, and is not expected to be a problem during the license renewal 33 term.
2 NPDES stands for National Pollutant Discharge Elimination System; in the case of IP2 and IP3, it is issued by the New York State Department of Environmental Conservation (NYSDEC) and the NRC staff refers to it as an SPDES throughout this draft SEIS.
Draft NUREG-1437, Supplement 38 4-4 December 2008 OAG10001366_00213
Environmental Impacts of Operation 1
- Thermal plume barrier to migrating fish. Based on information in the GElS, the 2 Commission found the following:
3 Thermal plumes have not been found to be a problem at operating nuclear power 4 plants and are not expected to be a problem during the license renewal term.
5
- Distribution of aquatic organisms. Based on information in the GElS, the Commission 6 found the following:
7 Thermal discharge may have localized effects but is not expected to affect the 8 larger geographical distribution of aquatic organisms.
9
- Premature emergence of aquatic insects. Based on information in the GElS, the 10 Commission found the following:
11 Premature emergence has been found to be a localized effect at some operating 12 nuclear power plants but has not been a problem and is not expected to be a 13 problem during the license renewal term.
14
- Gas supersaturation (gas bubble disease). Based on information in the GElS, the 15 Commission found the following:
16 Gas supersaturation was a concern at a small number of operating nuclear 17 power plants with once-through cooling systems but has been satisfactorily 18 mitigated. It has not been found to be a problem at operating nuclear power 19 plants with cooling towers or cooling ponds and is not expected to be a problem 20 during the license renewal term.
21
- Low dissolved oxygen in the discharge. Based on information in the GElS, the 22 Commission found the following:
23 Low dissolved oxygen has been a concern at one nuclear power plant with a 24 once-through cooling system but has been effectively mitigated. It has not been 25 found to be a problem at operating nuclear power plants with cooling towers or 26 cooling ponds and is not expected to be a problem during the license renewal 27 term.
28
- Losses from predation, parasitism, and disease among organisms exposed to sublethal 29 stresses. Based on information in the GElS, the Commission found the following:
30 These types of losses have not been found to be a problem at operating nuclear 31 power plants and are not expected to be a problem during the license renewal 32 term.
33
- Stimulation of nuisance organisms. Based on information in the GElS, the Commission 34 found the following:
35 Stimulation of nuisance organisms has been satisfactorily mitigated at the single 36 nuclear power plant with a once-through cooling system where previously it was 37 a problem. It has not been found to be a problem at operating nuclear power December 2008 4-5 Draft NUREG-1437, Supplement 38 OAG10001366_00214
Environmental Impacts of Operation 1 plants with cooling towers or cooling ponds and is not expected to be a problem 2 during the license renewal term.
3
- Noise. Based on information in the GElS, the Commission found the following:
4 Noise has not been found to be a problem at operating plants and is not 5 expected to be a problem at any plant during the license renewal term.
6 The NRC staff identified no new and significant information related to these issues during its 7 independent review (including information provided from the Entergy ER, the NRC staff's site 8 audit, the scoping process, the SPDES permits for IP2 and IP3 that expired in 1992 and the 9 subsequent draft permit, ongoing Hudson River monitoring programs and their results, and 10 other available information). Therefore, the NRC staff expects that there would be no impacts 11 during the renewal term beyond those discussed in the GElS.
12 The Category 2 issues (issues that the NRC staff must address in a site-specific review based 13 on the framework established in the GElS) related to cooling system operation during the 14 renewal term that are applicable to IP2 and IP3 are discussed in the sections that follow and are 15 listed in Table 4-2.
16 Table 4-2. Site-Specific (Category 2) Issues Applicable to the Operation of the IP2 and IP3 17 Cooling System during the Renewal Term 10 CFR ISSUE-10 CFR Part 51, GElS 51.53(a)(3)(ii) SEIS Subpart A, Appendix B, Table B-1 Section Subparagraph Section AQUATIC ECOLOGY Entrainment of fish and shellfish in early lifestages 4.2.2.1.2 B 4.1.2 Impingement of fish and shellfish 4.2.2.1.3 B 4.1.3 Heat shock 4.2.2.1.4 B 4.1.4 18 For power plants with once-through cooling systems, the NRC considers the impingement and 19 entrainment of fish and shellfish and thermal impacts from nuclear power plant cooling systems 20 to be site-specific (Category 2) issues for license renewal. The NRC staff reviewed the 21 applicant's ER (Entergy 2007a), visited the plant site, and reviewed the applicant's draft SPDES 22 permit, fact sheets describing it, and the NYSDEC permit renewal process (NYSDEC 2003b).
23 The NRC staff also reviewed relevant scientific publications, technical articles, and compilations 24 associated with the study area, as well as documents and technical reports from NYSDEC, the 25 National Marine Fisheries Service (NMFS), and other sources.
26 The SPDES permit for the Indian Point site, which addressed discharge from the currently 27 operating IP2 and IP3, as well as the shutdown IP1 unit, expired in 1992 but has been 28 administratively extended by NYSDEC. The NYSDEC proposed new SPDES permit for the 29 site, currently in draft form, is in adjudication.
30 Section 316(b) of the Clean Water Act of 1997 (CWA) (Title 33, Section 1326, of the United 31 States Code (33 USC 1326)) requires that the location, design, construction, and capacity of Draft NUREG-1437, Supplement 38 4-6 December 2008 OAG10001366_00215
Environmental Impacts of Operation 1 cooling water intake structures reflect the best technology available for minimizing adverse 2 environmental impacts. In the fact sheet for the site's draft SPDES permit, NYSDEC states that 3 it has determined that the site-specific best technology available to minimize the adverse 4 environmental impacts of the IP Units 1,2, and 3 cooling water intake structures is closed-cycle 5 cooling (NYSDEC 2003b). Under the terms of the proposed SPDES permit, NYSDEC (2003b) 6 states that it will evaluate proposals from Entergy to institute alternative methods to avoid 7 adverse environmental impacts. Given NYSDEC's statements in the proposed SPDES permit, 8 the NRC staff decided to consider the environmental impacts that may occur if Entergy institutes 9 closed-cycle cooling at IP2 and IP3-as well as the environmental impacts of a possible 10 alternative method of reducing impacts to aquatic life-in Chapter 8 of this SEIS. In the 11 following sections, the NRC staff addresses impacts from the current cooling system.
12 Applicant Assessment 13 In the draft environmental impact statement (DEIS) for the SPDES permits for IP2 and IP3, 14 Roseton, and the Bowline Point generating stations (CHGEC et al. 1999), as well as in the IP2 15 and IP3 ER (Entergy 2007a), the plant owner or owners (lP2 and IP3 had separate owners in 16 1999) acknowledged that some impinged fish survive and others die. Mortality can occur 17 immediately or at a later time. The DEIS examined impingement effects by evaluating 18 conditional mortality rates (CMR) and trends (through 1997) associated with population 19 abundance for eight selected taxa representing 90 percent of those fish species collected from 20 screens at IP2 and IP3. These included striped bass, white perch, Atlantic tomcod, American 21 shad, bay anchovy, alewife, blueback herring, and spottail shiner. Estimates of CMR, defined 22 as the fractional reduction in the river population abundance of the vulnerable age group caused 23 by a single source of mortality (in this case impingement) were assumed to be the same as or 24 lower than that which occurred in the years before installation of modified Ristroph screens and 25 fish return systems at IP2 and IP3 in 1991. For species exhibiting low impingement mortality 26 (e.g., striped bass, white perch, and Atlantic tomcod), future impingement effects were expected 27 to be substantially lower than they were before installation and use of modified Ristroph screens 28 and fish return systems.
29 The Hudson River electric-generating utilities (CHGEC et al. 1999) estimated the maximum 30 expected total impingement CMR for white perch and other taxa to quantify impact to the 31 species. In the ER, Entergy (2007a) stated that the results of in-river population studies 32 performed from 1974 to 1997 did not show any negative trend in overall aquatic river species 33 populations attributable to plant operations. The ER also stated that ongoing population studies 34 continued to support these conclusions. Thus, the applicant asserted that impingement impacts 35 were SMALL and did not warrant further mitigation measures. In support of this assessment, 36 the applicant provided two reviews (Barnthouse et al. 2002, 2008) in addition to the DEIS 37 (CHGEC et al. 1999).
38 Regarding entrainment, the applicant concluded that population studies performed from 1974 39 though 1997 have not shown any negative trend in overall aquatic populations attributable to 40 plant operations and that current mitigation measures will ensure that entrainment impacts 41 remain SMALL during the license renewal term. Therefore, the applicant asserted (Entergy 42 2007a) that continued operation of once-through cooling at the site "does not have any 43 demonstrable negative effect on representative Hudson River fish populations nor does it 44 warrant further mitigation measures." Barnthouse et al. (2008) used an ecological risk 45 assessment approach to evaluate the potential for adverse impacts to the representative December 2008 4-7 Draft NUREG-1437, Supplement 38 OAG10001366_00216
Environmental Impacts of Operation 1 important species (RIS) of the Hudson River from a variety of natural and anthropogenic 2 stressors, including the operation of the IP2 and IP3 cooling water intake system, fishing 3 pressure, the presence of zebra mussels, predation by striped bass, and water temperature.
4 The authors concluded that operation of the IP2 and IP3 cooling met the NRC criteria for a 5 SMALL impact level.
6 NYSDEC Assessment 7 Under the CWA, the U.S. Environmental Protection Agency (EPA) has delegated authority for 8 the NPDES permit and Water Quality Certification programs in the State of New York to 9 NYSDEC. The regulatory role of NYSDEC in the operation of the IP2 and IP3 cooling system 10 includes protecting aquatic resources from impacts associated with impingement, entrainment, 11 and thermal and chemical discharges through issuance of State (SPDES) permits and other 12 means. The last SPDES permit for IP2 and IP3 expired in 1992, but its terms have been 13 continued under provisions of the New York State Administrative Procedure Act. Regarding 14 Section 316(b) of the CWA and New York Code, Rules and Regulations, Section 704.5 15 (6 NYCRR Section 704.5), NYSDEC (2003b) has determined that the site-specific best 16 technology available to minimize the adverse environmental impact of the IP1, IP2, and IP3 17 cooling water intake structures is closed-cycle cooling.
18 In 2003, NYSDEC developed a final environmental impact statement (FEIS) (NYSDEC 2003a) 19 in response to the DEIS submitted by the operators of IP2 and IP3, Roseton, and Bowline Point 20 (CHGEC et al. 1999). In the FEIS, NYSDEC noted that "while the DEIS was acceptable as an 21 initial evaluation and assessment, it was not sufficient to stand as the final document, and 22 additional information as to alternatives and evaluation of impacts must be considered." In 23 responding to public comments on the DEIS (CHGEC et al. 1999), NYSDEC noted that, in 24 contrast to the utilities' assertions that the Hudson River fish community is healthy and robust, 25 changes in "total species richness and diversity suggest that the Hudson estuary ecosystem is 26 far from equilibrium." NYSDEC points out that the approach used by the utilities assumes 27 "selected cropping" of individual fish species while "the impacts associated with power plants 28 are more comparable to habitat degradation; the entire natural community is impacted" because 29 entrainment, impingement, and warming of the water simultaneously affect the entire aquatic 30 community of organisms. Emphasizing a more ecological approach, NYSDEC detailed the 31 importance of food webs, trophic and other interspecies relationships, and ecosystem 32 functioning.
33 NYSDEC (2003a) also stated that, while the changes to the IP2 and IP3 cooling system, 34 including the use of dual-speed and variable-flow pumps and the installation of modified 35 Ristroph traveling screens, "represent some level of improvement compared to operations with 36 no mitigation or protection, there are still significant unmitigated mortalities from entrainment 37 and impingement at all three of the Hudson River Settlement Agreement (HRSA) facilities."
38 NYSDEC (2003a) concluded that the millions of fish killed by impingement, entrainment, and 39 thermal effects at the HRSA power plants represent a significant source of mortality and stress 40 on the Hudson River's fish community and must be taken into account when assessing the 41 observed fish population declines. To help mitigate such losses, the NYSDEC (2003b) fact 42 sheet for the SPDES permit states that "This permit does not require the construction of cooling 43 towers unless: (1) the applicant seeks to renew its NRC operating licenses, (2) the NRC 44 approves extension of the licenses, and determines that the installation and operation of closed-45 cycle cooling is feasible and safe, and (3) all other necessary Federal approvals are obtained."
Draft NUREG-1437, Supplement 38 4-8 December 2008 OAG10001366_00217
Environmental Impacts of Operation 1 Furthermore, NYSDEC states that if the NRC grants extensions of the operating licenses, Indian 2 Point would have to submit for NYSDEC approval a revised construction schedule for closed-3 cycle cooling.
4 NYSDEC, in Section 1, "Biological Effects," of Attachment B to the 2003 SPDES fact sheet 5 (NYSDEC 2003b), states that operation of IP2 and IP3 results in the mortality of more than a 6 billion fish of various lifestages per year and that losses are distributed primarily among seven 7 species, including bay anchovy, striped bass, white perch, blueback herring, Atlantic tomcod, 8 alewife, and American shad. Of these, NYSDEC indicates that the populations of Atlantic 9 tomcod, American shad, and white perch are known to be declining in the Hudson River and 10 considers current losses to be substantial.
11 Studies have also been conducted to detect trends of fish populations in the Hudson River.
12 Both the applicant and NYSDEC have used the results of these studies to assess the potential 13 for adverse effects associated with the operation of the IP2 and IP3 cooling system. The results 14 of these assessments are described below. Some nongovernmental organizations (NGOs) and 15 citizens have also evaluated publicly available information and data associated with the Hudson 16 River and have expressed the opinion that many species of fish in the Hudson River are in 17 decline and that the entrainment and impingement of alilifestages of fish and shellfish at IP2 18 and IP3 is contributing to the decline of these important aquatic resources.
19 NRC Assessment 20 Because the proposed SPDES permit (which includes NYSDEC's 316(b) determination 21 regarding the cooling water intake structure) is still in draft stage and subject to ongoing 22 adjudication, the NRC staff conducted an independent impact analysis for the purpose of 23 addressing the Category 2 issues identified in Table 4-2 of this draft SEIS. The operation of the 24 IP2 and IP3 cooling system can directly affect the aquatic communities of the Hudson River 25 through impingement, entrainment, and thermal releases. Evaluating the potential for adverse 26 impacts of the cooling system to the aquatic resources of the Hudson River estuary presents a 27 significant challenge for three primary reasons:
28 (1) The potential stressor of interest (the IP2 and IP3 cooling system) occupies a fixed 29 position on the Hudson River, while many of the RIS that the NRC staff have chosen for 30 evaluation have the freedom to move up- and down-river during different stages in their 31 growth and development, during different seasons of the year, and, in some cases, at 32 different times of day.
33 (2) The Hudson River estuary is a dynamic, open-ended system containing a complex food 34 web that extends from the freshwater portion of the river downstream of the Troy Dam to 35 the Atlantic Ocean. Detectable changes in RIS populations may be influenced by 36 natural stressors or may be the result of stressors associated with human activities, 37 which include the operation of IP2 and IP3.
38 (3) Because the Hudson River estuary represents a complex system with hundreds of 39 aquatic species, the NRC staff chose to focus its analysis of impact on a subset of RIS 40 historically used to monitor the lower Hudson River (as indicated in Section 2.2.5.4 of 41 this SEIS). By focusing on a subset of species that are representative of many of the 42 species that exist in the lower Hudson River fish community, the NRC staff can more-43 easily analyze impacts to the Hudson River community, and the NRC staff can make use 44 of a large body of sampling data compiled over many years. The NRC staff December 2008 4-9 Draft NUREG-1437, Supplement 38 OAG10001366_00218
Environmental Impacts of Operation 1 acknowledges that the simplification inherent in relying on RIS may introduce some 2 additional uncertainty, but the NRC staff finds that the utility of the RIS approach (due to 3 the availability of large, long-term data sets; applicability to species with similar 4 characteristics; and comparability to other Hudson River studies) in evaluating 5 communitywide effects outweighs the uncertainties associated with using it.
6 Because impingement and entrainment are fundamentally linked, the NRC staff determined that 7 the effects of each should be assessed using an integrated approach, described in 8 Section 4.1.3 of this draft SEIS. The NRC staff assessed thermal impacts separately in 9 Section 4.1.4. Because the analysis of the environmental impacts associated with the IP2 and 10 IP3 cooling system is complex, the NRC staff provides summary results, analyses, and 11 conclusions in this chapter, and provides a complete discussion of the environmental impact 12 assessment in Appendix H, with supporting statistical analyses in Appendix I to this draft SEIS.
13 4.1.1 Impingement of Fish and Shellfish 14 Impingement occurs when organisms are trapped against cooling water intake screens or racks 15 by the force of moving water. Impingement can kill organisms immediately or contribute to a 16 slower death resulting from exhaustion, suffocation, injury, or exposure to air when screens are 17 rotated for cleaning. The potential for injury or death is generally related to the amount of time 18 an organism is impinged, its susceptibility to injury, and the physical characteristics of the 19 screenwashing and fish return system that the plant operator uses. In this section, the NRC 20 staff provides a summary assessment of impingement impacts based on NRC staff analyses of 21 available data. More detail appears in Appendix H.
22 Impingement monitoring at IP2 and IP3 was conducted by former plant owners and their 23 contractors between 1975 and 1990 using a variety of techniques. (A complete description of 24 the impingement monitoring studies conducted at IP2 and IP3 appears in Appendix H to this 25 draft SEIS.) The NRC staff assessment for the effects of cooling water system operation 26 concentrated on 18 RIS identified in Section 2.2.5.4, which include the 17 species identified in 27 the Hudson River utilities' DEIS (CHGEC et al. 1999) for assessing power plant effects plus the 28 Atlantic menhaden (Brevoortia tyranus), a member of the herring family whose young are 29 common inhabitants of the lower Hudson River. All but one RIS are fish; the exception is the 30 blue crab (Callinectes sapidus). The estimated number of impinged RIS made up greater than 31 90 percent of all impinged taxa for all but 1 year at IP2 (Figure 4-1); at IP3, the estimated 32 number of RIS impinged was greater than 85 percent for all but 1 year (Figure 4-2). To assess 33 impingement impacts, the NRC staff analyzed weekly estimated impingement numbers at IP2 34 and IP3 from January 1975 to November 1980 and seasonally estimated impingement numbers 35 from January 1981 to December 1990. (The former plant owners and their contractors based 36 estimated numbers on sampling data.) The combined numbers of young of the year (YOY),
37 yearling, and older fish were used for analysis since these data were available for all years of 38 sampling.
Draft NUREG-1437, Supplement 38 4-10 December 2008 OAG10001366_00219
Environmental Impacts of Operation 100% ................................................................................................................................................................ 5.0
.
95% ~--------'-'-',,- - - - - - v " ' - - - - - - - - - '........~~-_____-'-----'~------[]I----T 4.5 I , ::c C
CIl 90% ~---~*~----~~----~~---~~~+--___I 4.0 ~
E I I " N(.)
CIl Cl 85%
" \
~----~~',--,~,-~/~,----------4--+----1
" " 3.5 ~ ~
=ffi c:
'is.. , , \ , I 30
',,' \ , . "' "'C
.E 80% ~---~-~~-~~-~'----------~+---___I ~c:
iii * \: 2.5 ~~
c: en
-
'0 75% I I- I I " 20 'c..ii:
0
. ' I'. . E-70% .. : " " \ - 0 C * , I 15 iii en CIl "0 § g
" " I I \ .
...C.J CIl 65%
'\ I
~-~~-----------'~~-----'-,,-,----/~/--~~------I
" ' \
1.0 I-- .-
c..
60% ~---------------,,~_~----------~0.5 55% +---~--~--~--~-~--~--~--~---+O.O 1974 1976 1978 1980 1982 1984 1986 1988 1990 1992
- RIS Fish - - RIS Fish + Blue Crab - - - - - - - Total Impinged Unit 21 1 Figure 4-1. Percentage of impingement comprised of RIS fish and RIS fish plus blue crab 2 in relation to the total estimated impingement at IP2 (data from Entergy 2007b) 100% 5.0 95% ~_ _ _ _ _ _ _ _ _ _~_ _~~~~~~~_ _ _ _ _ _ _+4.5 C :c CIl 90% ~---------------------\-'-ir-------I 4.0 MU ~
E CIl Cl c:
'is..
85% ~--------------------.~-~---I 3.5 ~ ~
=m 3.0 ra ~
.E 80% ~---------------------~~~~--I ~ ~
iii 2.5 Cl..c:
-
'0 I-C 0
CIl 75%
70%
.'
,
"
2.0 E-
'5.~
-0 1 5 iii en
. '0 §
...
C.J 65% ~---~/--~--~~-------------4-~-----1 1-=
CIl c.. ,
.' --
... , 1.0 I-60% ~---~/--------~,~-~_-=-----~~----~0.5
,, , -
55% ~----r-----r-----r-----r-~'~'~----~----~----~-----+O.O 1974 1976 1978 1980 1982 1984 1986 1988 1990 1992
- RIS Fish --o--RIS Fish + Blue Crab - - - - - - - Total Impinged Unit 31 3 Figure 4-2. Percentage of impingement comprised of RIS fish and RIS fish plus blue crab 4 in relation to the total estimated impingement at IP3 (data from Entergy 2007b)
December 2008 4-11 Draft NUREG-1437, Supplement 38 OAG10001366_00220
Environmental Impacts of Operation 1 Total impingement trends at IP2 and IP3 suggest that the total number of fish and blue crab 2 impinged tended to decrease between 1977 and 1982, then generally leveled off between 1982 3 and 1990 (as show in Figures 4-1 and 4-2). If the IP2 and IP3 cooling systems are considered a 4 relatively constant sampler of Hudson River aquatic biota (recognizing the slight increase in 5 days of operation and volume of water circulated at IP2 and IP3 from 1975 to 1990), then the 6 decrease in the percent of RIS impinged and total impingement would suggest that RIS and all 7 other taxa within the vicinity of IP2 and IP3 have decreased from a high in 1977 to a relatively 8 constant lower level between 1984 and 1990. This decline will be explored further in Section 9 4.1.3 of this draft SEIS.
10 In addition to evaluating trends in impingement losses, the NRC staff also reviewed the results 11 of studies designed to evaluate impingement mortality. Before installation of modified Ristroph 12 screen systems in 1991, impingement mortality was assumed to be 100 percent. Beginning in 13 1985, pilot studies were conducted to evaluate whether the addition of Ristroph screens would 14 decrease impingement mortality for representative species (see Appendix H for additional 15 detail). The final design of the screens (Version 2), as reported in Fletcher (1990), appeared to 16 reduce impingement mortality for some species based on a pilot study compared to the existing 17 (original) system in place at IP2 and IP3. Based on the information reported by Fletcher (1990),
18 impingement mortality and injury are lowest for striped bass, weakfish, and hogchoker, and 19 highest for alewife, white catfish, and American shad (Table 4-3). The plant owners did not 20 monitor impingement rates or validate impingement mortality estimates after the new Ristroph 21 screens were installed at IP2 and IP3 in 1991.
22 Table 4-3. Assumed Cumulative Mortality and Injury of Selected Fish Species after 23 Impingement on Ristroph Screens Percent Species Dead and Injured Alewife 62 American Shad 35 Atlantic Tomcod 17 Bay Anchovy 23 Blueback Herring 26 Hogchoker 13 Striped Bass 9 Weakfish 12 White Catfish 40 White Perch 14 Source: Fletcher 1990 24 Based on Fletcher's assessment, the NRC staff concludes that the IP2 and IP3 cooling system 25 continues to impinge RIS of the lower Hudson River and that impingement mortality for several 26 species exceeds 25 percent. Monitoring data (Entergy 2007b, reviewed by NRC staff) also 27 suggest that impingement is greater at IP2 than at IP3 and that impingement has generally 28 declined since 1976. Although IP2 and IP3 currently employ modified Ristroph screens and fish Draft NUREG-1437, Supplement 38 4-12 December 2008 OAG10001366_00221
Environmental Impacts of Operation 1 return systems to increase the survival rates of impinged organisms, the actual improvements in 2 fish survival after installation of these systems at IP2 and IP3 have not been established 3 (impingement monitoring last occurred in 1990). In Section 4.1.3 of this draft SEIS, the NRC 4 staff includes impingement results in a weight-of-evidence (WOE) analysis to evaluate the 5 overall impacts of the IP2 and IP3 cooling system on lower Hudson River RIS.
6 4.1.2 Entrainment of Fish and Shellfish in Early Lifestages 7 Entrainment occurs when small aquatic life forms are carried into and through the cooling 8 system during water withdrawals and primarily affects organisms with limited swimming ability 9 that can pass through the screen mesh, which is typically 0.25 to 0.5 inch (in.) (6.35 to 10 12.7 millimeters (mm)), used on the intake systems. Organisms typically entrained include 11 phytoplankton, zooplankton, and the eggs, larvae, and juvenile forms of many of the fish and 12 invertebrates.
13 Once entrained, organisms pass through the circulating pumps and are carried with the water 14 flow through the intake conduits toward the condenser units. They are then drawn through one 15 of the many condenser tubes used to cool the turbine exhaust steam (where cooling water 16 absorbs heat) and then enter the discharge canal for return to the Hudson River. As entrained 17 organisms pass through the intake they may be injured from abrasion or compression. Within 18 the cooling system, they encounter physical impacts in the pumps and condenser tubing; 19 pressure changes and shear stress throughout the system; thermal shock within the condenser; 20 and exposure to chemicals, including chlorine and residual industrial chemicals discharged at 21 the diffuser ports (Mayhew et al. 2000). Death can occur immediately or at a later time from the 22 physiological effects of heat, or it can occur after organisms are discharged if stresses or 23 injuries result in an inability to escape predators, a reduced ability to forage, or other 24 impairments.
25 Studies to evaluate the effects of entrainment at IP2 and IP3 conducted since the early 1970s 26 employed a variety of methods to assess actual entrainment losses and to evaluate the survival 27 of entrained organisms after they are released back into the environment by the once-through 28 cooling system (see Appendix H for a more-detailed discussion). Despite increasingly refined 29 study techniques, entrainment survival estimates were compromised by poor ichthyoplankton 30 survival in control samples, and entrainment survival for many species is still unresolved. The 31 variability of entrainment data informed the NRC staff's decision to employ a WOE approach.
32 To assess the effects of entrainment on the aquatic resources of the lower Hudson River, the 33 NRC staff evaluated weekly average densities of entrained taxa for a given lifestage for IP2 and 34 IP3 that were provided by the applicant. The NRC staff then multiplied the sum of the mean 35 densities of all lifestages by the volume of circulated water to estimate the mean number 36 entrained per taxa and season.
37 The NRC staff found that a total of 66 taxa were identified during entrainment monitoring in data 38 supplied by Entergy (2007b). There were no blue crabs, shortnose or Atlantic sturgeon, or 39 gizzard shad identified in the 1981-1987 entrainment data. Because of the difficulty in 40 identification of early lifestages, RIS included those taxa that were identified only to family or 41 genus (e.g., herring family, anchovy family, Alosa spp., and Morone spp.). The percent RIS fish 42 entrained and the total entrainment are presented in Figure 4-3. Except for 2 weeks in 1984 43 and 1985 (1 week in May and 1 in June) for which amphipods (Gammarus spp.) were recorded, December 2008 4-13 Draft NUREG-1437, Supplement 38 OAG10001366_00222
Environmental Impacts of Operation 1 RIS represented at least 90 percent of all entrainment. The total number of identified fish 2 entrained has decreased at a rate of 1.6 billion fish per year since 1984. This result is 3 consistent with the decrease observed in the number of fish impinged (Figures 4-1 and 4-2).
100% .¥==~~~~
- n**** .....................................................~.... 50 01
><
90% 1----------1\t----,-, ---/----r-------+ 45 01 l-80% +------------------r--~,~,~-----.r-------------+40~
S0 I-70% 1-----\--\-\--;-,/------':----1-7-/-------+ 35 ;.
'0 60% +-------------------~--~~~----------------+30 "OCD
'S 0
"0 50% +-------------------~/\--\----'r~~-------------------+25 ._~
CD 40% +-----------------~--~b(~L-~\------------------+20 ~
\ /\ f::
f::
.~
1: 30% +-----~--------------_¥~--~----------------+15
-
I-w "iii f ::
CD 20% +----------------*-*----------~~--------------+10 0 I-
~
CD
- n. 10% +-------------------------------------~~----+5 0% +-----,----,-----,-----,-----,----~----,-----+O 1980 1981 1982 1983 1984 1985 1986 1987 1988 I----+--- % RIS Fish --D-- % Total Fish ....... Total Taxa Entrained I 4
5 Figure 4-3. Percentage of entrainment comprised of RIS fish and total fish in relation to 6 the total estimated entrainment at IP2 and IP3 combined (data from Entergy 2007b) 7 4.1.3 Combined Effects of Impingement and Entrainment 8 The NRC staff employed a modified WOE approach to evaluate whether the impingement and 9 entrainment that occurs during the operation of the IP2 and IP3 cooling system has the potential 10 to adversely affect RIS in the lower Hudson River. The term "weight of evidence" has many 11 meanings, but it is defined by the NRC staff in this draft SEIS as an organized process for 12 evaluating information or data from multiple sources to determine whether there is evidence to 13 suggest that an existing or future environmental action has the potential to result in an adverse 14 impact. The NRC staff employs a WOE approach adapted from the process described in 15 Menzie et al. (1996). The overall approach is represented in Figure 4-4 and presented in detail 16 in Appendix H to this draft SEIS; specific steps in the process are defined below.
Draft NUREG-1437, Supplement 38 4-14 December 2008 OAG10001366_00223
Environmental Impacts of Operation 18 Representative Important Species River Data for Each Species In-Plant Data for Each Species
- 1) Monitoring Surveys (LRS, FJS, BSS) 1) ImpingementofRIS
-River Segment Measurements 2) I mpingement of Prey
-River-wide Measurements 3) Entrainment of RIS
- 2) Coastal Assessment (Literature) 4) Entrainment of Prey Line of Evidence: Line of Evidence:
Population Trend Strength of Connection of for Each Species Indian Point to Each Species Evaluate Data Evaluate Data To Determine WOE Score To Determine WOE Score 1 Figure 4-4. General weight-ot-evidence approach employed to assess the level ot impact 2 to population trends attributable to IP cooling system operation 3 Step 1: Identify the Environmental Component or Value To Be Protected 4 For this assessment, the environmental component to be protected is the Hudson River aquatic 5 resources as represented by the 18 RIS identified in Table 2-4. These species represent a 6 variety of feeding strategies and food web classifications and are ecologically, commercially, or 7 recreationally important. The WOE approach focuses primarily on the potential impacts to 8 young-of-the-year and yearling fish and their food sources. The long-term sampling programs 9 of the Hudson River, on which this analysis is based, focused on these early lifestages.
10 Although eggs and larval forms are important components to the food web, the natural mortality 11 to these lifestages is high. In contrast, fish surviving to the YOY stage and older are more likely 12 to add to the adult breeding population and are at greater risk from the cooling system 13 operation. Any factor that decreases (or increases) the survival of those fish during juvenile and 14 yearling stages can affect the sustainability of the population.
15 Step 2: Identify Lines of Evidence and Quantifiable Measurements 16 The goal of this step is to identify data sets and information that can be used to assess the 17 potential for adverse environmental effects and evaluate whether the IP2 and IP3 cooling 18 system is contributing to the effect. The NRC staff developed two primary lines of evidence 19 (LOE) to evaluate impacts. The first LOE included measurements of RIS population trends in 20 the lower Hudson River and coastal areas to assess whether populations were increasing, 21 decreasing, or stable; the second LOE addressed how much influence the operation of the IP2 December 2008 4-15 Draft NUREG-1437, Supplement 38 OAG10001366_00224
Environmental Impacts of Operation 1 and IP3 cooling systems had on the RIS populations in the lower Hudson River (i.e., the 2 strength of connection between IP2 and IP3 and the aquatic environment). The NRC staff used 3 impingement and entrainment monitoring data obtained from the IP2 and IP3 facility; data from 4 the lower Hudson River collected during the Long River Survey (LRS), Fall Juvenile/Fall Shoals 5 Survey (FJS/FSS), and Beach Seine Survey (BSS), as described in Table 2-3 in the main text; 6 and coastal fishery trend data, when available. A summary of measurements associated with 7 each LOE is presented in Appendix H to this draft SEIS.
8 Step 3: Quantify the Use and Utility of Each Measurement 9 The following attributes of each measurement within each LOE were assigned an ordinal score 10 corresponding to a ranking of its use and utility of low, medium, or high:
11
- Strength of Association: The extent to which the measurement is representative of, 12 correlated with, or applicable to the RIS.
13
- Stressor-specificity: The extent to which the measurement is associated with a specific 14 stressor or the extent to which the data used in the assessment relate to the stressor of 15 interest.
16
- Site-specificity: The extent to which data used in the assessment relate to the site of 17 interest.
18
- Sensitivity of the Measurement: The ability of the measurement to detect a response.
19
- Spatial Representativeness: The degree of compatibility between the study area and 20 the location of measurements, known stressors, and biological receptors.
21
- Temporal Representativeness: The degree of compatibility between the measurement 22 and the time period during which effects are expected to occur.
23
- Correlation of Stressor to Response: The degree of correlation between the levels of 24 exposure to a stressor and levels of response observed in the measurement.
25 The NRC staff then calculated overall use and utility scores for each measurement within each 26 LOE as the average of the individual attribute numbers. Scores for each LOE are available in 27 Appendix H, Section H.3.
28 Step 4: Develop Quantifiable Decision Rules for Interpreting the Results of Each Measurement 29 Decision rules are used to assign a level of potential impact based on an analysis of the data.
30 In support of the first LOE, the NRC staff developed decision rules that described a small, 31 moderate, and large potential for adverse impact. Because the development and use of these 32 rules is complex, a general definition of a small, moderate, and large potential for adverse 33 impact is presented below. A detailed discussion of how the decision rules were developed and 34 used in the environmental assessment is presented in Appendices H and I to this draft SEIS.
35
- A small potential for an adverse impact to a RIS population was determined if an 36 analysis of available data suggested that a RIS population had remained stable over 37 time and that the observed population levels were generally within the range of expected 38 natural variability.
Draft NUREG-1437, Supplement 38 4-16 December 2008 OAG10001366_00225
Environmental Impacts of Operation 1
- A moderate potential for an adverse impact to a RIS population was determined if an 2 analysis of available data suggested that a RIS population was declining over time, OR 3 that many of the observed population levels were outside the range of expected natural 4 variability.
5
- A large potential for an adverse impact to a RIS population was determined if an 6 analysis of available data suggested that the population was declining over time, AND 7 that many of the observed population levels were outside the range of expected natural 8 variability.
9 These decision rules were applied to each RIS species if sufficient data were available to 10 support a determination. If sufficient data were not available, the NRC staff called the level of 11 impact "unknown."
12 In support of the second LOE, which evaluated the strength of connection between the 13 operation of the IP2 and IP3 cooling system and the RIS in the lower Hudson River, the NRC 14 staff developed decision rules to assess whether the proportion of RIS present in impingement 15 and entrainment samples obtained from IP2 and IP3 were similar to the proportions observed 16 from the environmental sampling conducted in the lower Hudson River (e.g., the LRS, FJS/FSS, 17 and BSS studies). The general definitions for each rule are presented below; a detailed 18 discussion of decision rule development and use to assess strength of connection is presented 19 in Appendices H and I to this draft SEIS.
20
- A low strength of connection was present if the proportional representation of a given 21 RIS in the cooling system (entrainment and impingement samples) was less than the 22 proportional representation obtained from the fishery studies, suggesting the RIS is 23 underrepresented in the cooling system samples compared to the fishery studies.
24
- A medium strength of connection was present if the proportional representation of a 25 given RIS in the cooling system samples was equal to the proportional representation 26 observed in the fishery studies, suggesting the cooling system sample is equally 27 representing the Hudson River population near IP2 and IP3.
28
- A high strength of connection was present if the proportional representation of a given 29 RIS in the cooling system entrainment samples was greater than the proportional 30 representation observed in the fishery studies, suggesting the cooling system sample is 31 overrepresenting the Hudson River population near IP2 and IP3.
32 These decision rules were applied to each RIS species if sufficient data were available to 33 support the determination. As described above, numerical scores were assigned to each 34 impact level to facilitate integration.
35 Step 5: Integrate the Results and Assess Impact 36 The process used to integrate the two LOE and associated measurements brought together the 37 assessment of population impacts and strength of connection derived from the use of the 38 decision rules and the overall use and utility of each measurement with regards to 39 decisionmaking. A detailed description of the process and statistical analysis employed is 40 presented in Appendices H and I to this draft SEIS. The final determination of impact is December 2008 4-17 Draft NUREG-1437, Supplement 38 OAG10001366_00226
Environmental Impacts of Operation 1 consistent with the NRC guidelines for SMALL, MODERATE, and LARGE potential for adverse 2 impacts as defined below:
3 SMALL: Environmental effects are not detectable or are so minor that they will 4 neither destabilize nor noticeably alter any important attribute of the resource.
5 MODERA TE: Environmental effects are sufficient to alter noticeably-but not to 6 destabilize-any important attributes of the resource.
7 LARGE: Environmental effects are clearly noticeable and are sufficient to 8 destabilize any important attributes of the resource.
9 What follows is the NRC staff assessment of the two LOE (population trends and strength of 10 connection) and a determination of impact associated with impingement and entrainment at IP2 11 and IP3 using the above definitions.
12 4.1.3.1 Assessment of Population Trends-The First Line of Evidence 13 As described above, data from the LRS, FSS, and BSS studies of the lower Hudson River were 14 used to assess population trends. Data from 1974 to 2005 were obtained from the applicant in 15 electronic format. The NRC staff used an abundance index calculated by the applicant and 16 calculated catch-per-unit-effort values where available. The NRC staff also evaluated coastal 17 population trends for striped bass, American shad, Atlantic sturgeon, river herring, bluefish, 18 Atlantic menhaden, and weakfish using commercial and recreational harvest statistics provided 19 by the Atlantic States Marine Fisheries Commission (ASMFC).
20 To evaluate the population trend LOE, the NRC staff assessed population trends in river 21 segment 4 (the region of the lower Hudson River encompassing IP2 and IP3), population trends 22 in the lower Hudson River from the Troy Dam to the Battery, and the coastal trends reported by 23 ASMFC. For each measurement, a WOE score was calculated, and a final WOE score was 24 obtained. The results from this analysis appear in Appendix H to this draft SEIS and predict a 25 moderate to large potential for adverse impacts for 13 of the 18 RIS. For two of these (Atlantic 26 menhaden and Atlantic sturgeon) the moderate to large potential impact determination was 27 based on only one LOE (coastal trends). The NRC staff predicts a small potential for adverse 28 population-level impacts for blue crab based on only one LOE (coastal trends). The NRC staff 29 could not reach an impact conclusion for gizzard shad because it was not a target species for 30 the LRS, FSS, or BSS surveys. Likewise, NRC staff was unable to reach a determination of 31 impact for the shortnose sturgeon because of a lack of available data for the YOY lifestage, the 32 primary focus of the WOE assessment. Based on a lack of information for these species, the 33 population trend LOE impact level could range from small to large. Population trends for year 1 34 and older Atlantic and shortnose sturgeon are presented in Section 4.6.1 of this draft SEIS 35 based on electronic data provided by the applicant.
36 4.1.3.2 Assessment of Strength of Connection-The Second Line of Evidence 37 To determine whether the operation of the IP2 and IP3 cooling system had the potential to 38 influence RIS populations near the facility or within the lower Hudson River, the NRC staff 39 conducted strength of connection analyses. A summary of this analysis can be found in 40 Appendix H, and detailed information on the analysis is presented in Appendix I to this draft 41 SEIS.
Draft NUREG-1437, Supplement 38 4-18 December 2008 OAG10001366_00227
Environmental Impacts of Operation 1 The strength of connection analysis assumes the IP2 and IP3 cooling system can affect aquatic 2 resources directly through impingement or entrainment, or indirectly by impinging and entraining 3 potential food (prey). By comparing the rank order of RIS caught in the river to the order 4 observed in impingement and entrainment samples, it is possible to evaluate how efficient the 5 IP2 and IP3 cooling system is at removing RIS from the river (e.g., how strongly it is connected 6 to the RIS of interest). The results of this analysis are presented in Table 4-4 and show that a 7 HIGH strength of connection was observed for only two species (bluefish and striped bass). For 8 those species, the IP2 and IP3 cooling system was removing either the species or its prey at 9 levels that were proportionally higher than what was observed in the river studies. This 10 suggests that there is strong evidence that the operation of the cooling system is affecting these 11 species. For the remaining RIS, the strength of connection ranged from low (minimal evidence 12 of connection) to medium (some evidence of connection). The strength of connection was 13 unknown for five species (Atlantic menhaden, Atlantic and shortnose sturgeon, gizzard shad, 14 and blue crab) because of a lack of available data. For these species, actual strength of 15 connection could be low, medium, or high, but the lack of data makes a specific determination 16 impossible.
17 4.1.3.3 Impingement and Entrainment Impact Summary 18 The NRC staff presents the final integration of population-level and strength-of-connection LOE 19 in Table 4-4. This table shows the final conclusions for both LOE (i.e., population trends and 20 strength of connection). An adverse impact from IP2 and IP3 means that the data show both a 21 measurable response in the RIS population and clear evidence that the RIS is influenced by the 22 operation of the IP2 and IP3 cooling system. Thus, when the strength of connection is low, it is 23 not possible to arrive at an impact level greater than SMALL because there is little evidence that 24 a relationship between the cooling system and RIS exists. This logic also requires that for an 25 RIS with a HIGH strength of connection to the IP2 and IP3 cooling system operation but little 26 evidence of population decline, the final determination must also be SMALL.
27 Based on the final WOE assessment (available in Appendix H, Section H.3.3), a SMALL 28 potential for adverse impact was predicted for two species (striped bass and weakfish) because 29 there was no evidence of a population decline even though the strength of connection was 30 MEDIUM or HIGH. A SMALL to MODERATE impact was predicted for seven species (alewife, 31 bay anchovy, American shad, blueback herring, spottail shiner, Atlantic tomcod, and white 32 catfish). A MODERATE impact was predicted for rainbow smelt, and a MODERATE to LARGE 33 impact level was predicted for the hogchoker and white perch. A LARGE potential for adverse 34 impact was predicted for only one species, the bluefish, based on observed population declines 35 and an apparent HIGH strength of connection to the IP2 and IP3 cooling system. An impact 36 determination could not be made for Atlantic menhaden, Atlantic and shortnose sturgeon, 37 gizzard shad, and blue crab because of a lack of data for YOY lifestages, and therefore specific 38 impacts are unknown and could range from SMALL to LARGE. The NRC staff addresses 39 mitigation measures for these impacts in Section 4.1.5 of this draft SEIS.
40 The NRC staff assigns an overall impact level of SMALL to LARGE for impingement and 41 entrainment to encompass the range of impacts for individual species. The RIS identified in this 42 section are meant to represent the overall aquatic resource, express uncertainty from 43 unquantifiable impact levels for some individual RIS, and reflect the complexity of the Hudson 44 River ecosystem by encompassing a broad range of attributes, such as biological importance, 45 commercial or recreation value, trophic position, commonness or rarity, interaction with other December 2008 4-19 Draft NUREG-1437, Supplement 38 OAG10001366_00228
Environmental Impacts of Operation 1 species, vulnerability to cooling system operation, and fidelity or transience in the local 2 community. This range of impacts, then, expresses the impact to the overall aquatic 3 community.
4 Table 4-4. Impingement and Entrainment Impact Summary for Hudson River RIS Impacts of IP2 and IP3 Population Strength of Connection Species Cooling System on Line of Evidence Line of Evidence Aquatic Resources Alewife Large Low to Medium Small to Moderate Bay Anchovy Moderate Low to Medium Small to Moderate American Shad Large Low to Medium Small to Moderate Bluefish Large High Large Hogchoker Large Medium to High Moderate to Large Atlantic Menhaden Moderate to Large Unknown(a) Unknown(b)
Blueback Herring Large Low to Medium Small to Moderate Rainbow Smelt Large Medium Moderate Shortnose Sturgeon Unknown Unknown(a) Unknown(b)
Spottail Shiner Large Low to Medium Small to Moderate Atlantic Sturgeon Large Unknown(a) Unknown(b)
Striped Bass Small High Small Atlantic Tomcod Large Low to Medium Small to Moderate White Catfish Large Low to Medium Small to Moderate White Perch Large Medium to High Moderate to Large Weakfish Small Medium to High Small Gizzard Shad Unknown Unknown(a) Unknown(b)
Blue Crab Small Unknown(a) Unknown(b)
(a) Strength of connection could not be established using WOE, therefore strength of connection could range from LOW to HIGH.
(b)Conclusion of impact could not be established using WOE, therefore impacts could range from SMALL to LARGE.
5 4.1.3.4 Discussion of Uncertainty 6 As part of reporting ecological risks, the EPA (1998) has recommended that practitioners review 7 and summarize the major areas of uncertainty in their analyses. In this section, the NRC staff 8 discusses the known uncertainties inherent with using the WOE approach.
9 As with any quantitative evaluation, the rigor of the analysis is dependent on the quality and 10 source of data. The NRC staff acknowledges that the lack of studies and data on impingement 11 and entrainment at IP2 and IP3 since 1990 and 1987, respectively, yields potential uncertainties 12 for the staff's disposition of impingement and entrainment impacts using the WOE approach.
13 The range and age of the data used is expected to introduce some inherent uncertainties (i.e.,
14 the current impacts, as described in Table 4-4, are inferred from impingement and entrainment 15 data collected between 1975 and 1990). The NRC staff also notes that data collection for 16 impingement and entrainment at Indian Point ended around the same time that the plant 17 installed the modified Ristroph screens and fish return systems. Although it is expected that this Draft NUREG-1437, Supplement 38 4-20 December 2008 OAG10001366_00229
Environmental Impacts of Operation 1 system would likely have a positive effect on impingement mortality, there have been no 2 additional data since 1990 to validate any impingement mortality estimates. More recent 3 impingement and entrainment data, that reflect the effects of these plant modifications, could 4 potentially affect the results of the Staff's WOE analysis; without such data, however, the NRC 5 staff did not quantitatively incorporate this effect into the WOE approach. Nevertheless, as 6 previously noted, the final design of the screens appeared to reduce impingement mortality for 7 some species based on a pilot study compared to the original system in place at Indian Point 8 (Fletcher 1990). The NRC staff did not include the results of this pilot study during or following 9 the application of the WOE approach. As such, the NRC staff recognizes, in Appendix H, that 10 the WOE results may potentially yield overestimates.
11 As previously noted, using the same data available to the staff with a different analytical 12 approach, and affording consideration to the plant modifications which have been made, the 13 applicant assessed impacts from impingement and entrainment as SMALL in its ER. The 14 NYSDEC, however, while acknowledging that the Ristroph screens provide some 15 improvements, expressed a continuing concern with respect to mortalities from impingement 16 and entrainment. For these impacts, the NRC staff has independently chosen the use of the 17 WOE approach to make its determination as quantitatively as possible, using available data.
18 The Massachusetts Weight-of-Evidence Workgroup (Menzie et al. 1996) discussed the value 19 and use of both quantitative and qualitative approaches in development of the weight-of-20 evidence methodology. As recommended by the Workgroup (Menzie et al. 1996), NRC staff 21 has used professional judgment to select and refine methods before analyzing data and 22 documented all steps (see Appendices H and I) to allow interested readers to gain an 23 understanding of the assumptions and limitations associated with this assessment. The NRC 24 staff has also employed a similar methodology (Menzie et al. 1996), using other data, for 25 assessing the effects of power plant operation on fish populations in its GElS Supplement 22, 26 regarding Millstone Power Station, Units 2 and 3 (NRC 2005).
27 In summary, the NRC staff's findings for impact from impingement and entrainment, as 28 described in Table 4-4, are subject to the potential uncertainties described above to varying 29 degrees. They also represent the NRC staff's best estimates based on the WOE derived from 30 the available data.
31 4.1.3.5 Overall Impingement and Entrainment Impact 32 Based on the results of the NRC staff WOE analysis for RIS and the uncertainties discussed in 33 the previous section, the NRC staff concludes that the overall impact to aquatic resources from 34 impingement and entrainment ranges from SMALL to LARGE, depending on species affected.
35 4.1.4 Heat Shock 36 As discussed in Chapter 2, thermal discharges associated with the operation of the once-37 through cooling water system for IP2 and IP3 are regulated by NYSDEC. Temperature 38 limitations are established and imposed on a case-by-case basis for each facility subject to 39 6 NYCRR 704.
40 Specific conditions associated with the extent and magnitude of thermal plumes are addressed 41 in 6 NYCRR 704 as follows:
42 (5) Estuaries or portions of estuaries.
December 2008 4-21 Draft NUREG-1437, Supplement 38 OAG10001366_00230
Environmental Impacts of Operation 1 (i) The water temperature at the surface of an estuary shall not be raised to more 2 than 90 degrees Fahrenheit at any point.
3 (ii) At least 50 percent of the cross sectional area and/or volume of the flow of the 4 estuary including a minimum of one-third of the surface as measured from water 5 edge to water edge at any stage of tide, shall not be raised to more than four 6 Fahrenheit degrees over the temperature that existed before the addition of heat 7 of artificial origin or a maximum of 83 degrees Fahrenheit, whichever is less.
8 (iii) From July through September, if the water temperature at the surface of an 9 estuary before the addition of heat of artificial origin is more than 83 degrees 10 Fahrenheit an increase in temperature not to exceed 1.5 Fahrenheit degrees at 11 any point of the estuarine passageway as delineated above, may be permitted.
12 (iv) At least 50 percent of the cross sectional area and/or volume of the flow of 13 the estuary including a minimum of one-third of the surface as measured from 14 water edge to water edge at any stage of tide, shall not be lowered more than 15 four Fahrenheit degrees from the temperature that existed immediately prior to 16 such lowering.
17 Thermal discharges associated with the operation of IP2 and IP3 are regulated under SPDES 18 permit NY-0004472. This permit imposes effluent limitations, monitoring requirements, and 19 other conditions to ensure that all discharges are in compliance with Title 8 of Article 17 of the 20 Environmental Conservation law (ECl) of New York State, 6 NYCRR 704, and the CWA.
21 Specific conditions of permit NY-0004472 related to thermal discharges from IP2 and IP3 are 22 specified in NYSDEC (2003b) and include the following:
23
- The maximum discharge temperature is not to exceed 110 degrees F (43 degrees C).
24
- The daily average discharge temperature between April 15 and June 30 is not to exceed 25 93.2 degrees F (34 degrees C) for an average of more than 10 days per year during the 26 term of the permit, beginning in 1981, provided that it not exceed 93.2 degrees F (34 27 degrees C) on more than 15 days during that period in any year.
28 4.1.4.1 Potential Effects of Heated Water Discharges on Aquatic Biota 29 The discharge of heated water into the Hudson River can cause lethal or sublethal effects on 30 resident fish, influence food web characteristics and structure, and create barriers to migratory 31 fish moving from marine to freshwater environments. The potential for harm associated with the 32 discharge of heated water into streams, rivers, bays, and estuaries became known during the 33 early 1960s as new power facilities were being considered or constructed, and resulted in the 34 definition of waste heat as a pollutant in the Federal Water Pollution Control Act of 1965. Waste 35 heat discharges can directly kill sensitive aquatic organisms if the duration and extent of the 36 organism's exposure exceeds its upper thermal tolerance limit. Indirect effects associated with 37 exposure to nonlethal temperatures can result in disruptions or changes to spawning behavior, 38 accelerated or diminished growth rates of early lifestages (both positive and negative), or 39 changes in growth or survival in response to changes to food web dynamics or predator/prey 40 interactions (CHGEC et al. 1999). Indirect effects can also occur if the presence of a thermal 41 plume restricts or blocks a species' migratory pattern during a critical lifestage, or results in Draft NUREG-1437, Supplement 38 4-22 December 2008 OAG10001366_00231
Environmental Impacts of Operation 1 avoidance behavior that affects species' viability or increases the likelihood of predation.
2 Adverse thermal effects can also occur when thermal discharges are interrupted, resulting in 3 cold shock. To evaluate the nature and extent of thermal discharges, it is necessary to have an 4 understanding of the characteristics of the thermal plume when it enters the receiving water, the 5 lethal and sublethal tolerance limits for key aquatic species and lifestages of interest, and the 6 possible exposure scenarios (nature and extent). Thus, regulatory agencies tasked with 7 developing thermal discharge criteria that are protective of aquatic resources (in this case, 8 NYSDEC) generally set limits on the extent, magnitude, and duration of the thermal plume to 9 ensure it addresses potential lethal and sublethal effects associated with the temperature of 10 heated water discharged into the environment, and its characteristics when it enters receiving 11 waters.
12 4.1.4.2 Historical Context 13 Thermal impacts associated with the operation of IP2 and IP3, Roseton, and the Bowline Point 14 electrical generating stations have been a concern of NYSDEC, the NRC's predecessor 15 organization (the U.S. Atomic Energy Commission (USAEC)), and the NRC. In the 1972 final 16 environmental statement (FES) for the IP2 operating license (USAEC 1972), the USAEC 17 concluded that, although operation of IP2 would meet New York thermal standards for river 18 surface water temperature, there was evidence to suggest that the IP2 discharge could exceed 19 New York State standards for surface area and cross-sectional area enclosed within the 20 4 degrees Fahrenheit (F) isotherm. USAEC, in response, issued an operating license for IP2 21 with the following conditions related to potential thermal impacts:
22
- operation of the once-through system would be permitted until January 1, 1978, and 23 thereafter a closed-cycle system would be required; 24
- the applicant would perform an economic and environmental impact analysis of an 25 alternative closed-cycle system, and provide the evaluation to the USAEC by July 1, 26 1973; and 27
- after approval by the USAEC, the required closed-cycle cooling system would be 28 designed, built, and placed in operation no later than January 1, 1978.
29 The operating license also required the applicant to monitor dissolved oxygen in the discharge 30 water and thermal plume, and monitor the size, shape, and locations of isotherms in the thermal 31 plume (USAEC 1972). In the FES developed for the IP3 operating license, the NRC staff 32 assessed the impact of thermal discharges from once-through cooling for all units (lP1, IP2, and 33 IP3) and again concluded that, under certain conditions, the thermal discharges from the three 34 units would exceed New York State thermal criteria (NRC 1975). The NRC issued an operating 35 license to IP3 with conditions similar to those of IP2, but reflecting the decisions of the Atomic 36 Safety and Licensing Board in 1974 that required closed-cycle cooling by May 1, 1979.
37 In 1976, the former owners of IP2 and IP3 submitted an environmental report to the NRC that 38 evaluated various alternative closed-cycle cooling systems from an economic and 39 environmental standpoint. In 1978, the former owners submitted a 316(a) determination to 40 NYSDEC asserting that the facility complied with thermal standards established by New York 41 State (6 NYCRR 704). In 1980, litigation associated with the operation of electric generation 42 stations along the Hudson River resulted in the HRSA. In place of the cooling tower December 2008 4-23 Draft NUREG-1437, Supplement 38 OAG10001366_00232
Environmental Impacts of Operation 1 requirement, HRSA required a variety of mitigation measures including seasonal outages and 2 the installation of dual-speed or variable-speed pumps at IP2 and IP3. The existence of HRSA 3 also superseded the 1978 316(a) study. In support of the Fourth Amended Consent Order to 4 HRSA (NYSDEC 1997), the owners of IP2 and IP3 developed flow efficiency curves for each 5 unit that related flow to inlet temperature. For both units, flows of 500,000 gallons per minute 6 (gpm) (1900 cubic meters per minute (m 3/min)) were generally attainable during the winter 7 months (December-March when water inlet temperatures were less than 50 degrees F 8 (10 degrees Celsius (C)), with flow rates of 700,000 gpm (2650 m3/min) required during the 9 summer months when inlet temperatures exceeded 70 degrees F (21 degrees C) (NYSDEC 10 1997, Figures B-1 and B-2). The Fourth HRSA Consent Order also developed a system of "flow 11 variation points" as a means of evaluating changes in plant operations at IP2 and IP3, Bowline 12 Point, and Roseton that offset exceedences of recommended flows with reductions at other 13 times.
14 4.1.4.3 Thermal Studies and Conclusions 15 A detailed discussion of the thermal studies conducted at IP2 and IP3 to supplement the initial 16 316(a) work performed in the late 1970s is presented in CHGEC et al. (1999). The studies 17 included thermal modeling of near-field effects using the Cornell University Mixing Zone Model 18 (CORMIX), and modeling of far-field effects using the Massachusetts Institute of Technology 19 (MIT) dynamic network model (also called the far-field thermal model). For the purpose of 20 modeling, near field was defined as the region in the immediate vicinity of each station 21 discharge where cooling water occupies a clearly distinguishable, three-dimensional 22 temperature regime in the river that is not yet fully mixed; far field was defined as the region 23 farthest from the discharges where the plumes are no longer distinguishable from the river, but 24 the influence of the discharge is still present (CHGEC et al. 1999). The MIT model was used to 25 simulate the hydraulic and thermal processes present in the Hudson River at a scale deemed 26 sufficient by the utilities and their contractor and was designed and configured to account for 27 time-variable hydraulic and meteorological conditions and heat sources of artificial origins.
28 Model output included a prediction of temperature distribution for the Hudson River from the 29 Troy Dam to the island of Manhattan. Using an assumption of steady-state flow conditions, the 30 permit applicants applied CORM IX modeling to develop a three-dimensional plume 31 configuration of near-field thermal conditions that could be compared to applicable water quality 32 criteria (CHGEC et al. 1999).
33 Former owners of IP2 and IP3 conducted thermal plume studies employing both models for time 34 scenarios that encompassed the period of June-September (CHGEC et al. 1999). These 35 months were chosen because river temperatures were expected to be at their maximum levels.
36 The former owners used environmental data from 1981 to calibrate and verify the far-field MIT 37 model and to evaluate temperature distributions in the Hudson River under a variety of power 38 plant operating conditions. They chose the summer months of 1981 because data for all 39 thermal discharges were available, and because statistical analysis of the 1981 summer 40 conditions indicated that this year represented a relatively low-flow, high-temperature summer 41 that would represent a conservative (worst-case) scenario for examining thermal effects 42 associated with power plant thermal discharges. Modeling was performed under the following 43 two power plant operating scenarios to determine if New York State thermal criteria would be 44 exceeded:
Draft NUREG-1437, Supplement 38 4-24 December 2008 OAG10001366_00233
Environmental Impacts of Operation 1 (1) Individual station effects-full capacity operation of Roseton Units 1 and 2, IP2 and IP3, 2 or Bowline Point Units 1 and 2, with no other sources of artificial heat.
3 (2) Extreme operating conditions-Roseton Units 1 and 2, IP2 and IP3, and Bowline Point 4 Units 1 and 2, and all other sources of artificial heat operating at full capacity.
5 Modeling was initially conducted using MIT and CORMIX Version 2.0 under the conditions of 6 maximum ebb and flood currents (CHGEC et al. 1999). These results were supplemented by 7 later work using MIT and CORMIX Version 3.2 and were based on the hypothetical conditions 8 represented by the 10th -percentile flood currents, mean low water depths in the vicinity of each 9 station, and concurrent operation of all three generating stations at maximum permitted capacity 10 (CHGEC et al. 1999). The 10th percentile of flood currents was selected because it represents 11 the lowest velocities that can be evaluated by CORM IX, and because modeling suggests that 12 flood currents produce larger plumes than ebb currents. The results obtained from the CORMIX 13 model runs were integrated with the riverwide temperature profiles developed by the MIT 14 dynamic network model to evaluate far-field thermal impacts (e.g., river water temperature rises 15 above ambient) for various operating scenarios, the surface width of the plume, the depth of the 16 plume, the percentage of surface width relative to the river width at a given location, and the 17 percentage of cross-sectional area bounded by the 4 degrees F (2 degrees C) isotherm. In 18 addition, the decay in excess temperature was estimated from model runs under near slack 19 water conditions (CHGEC et al. 1999).
20 For IP2 and IP3, two-unit operation at full capacity resulted in a monthly average cross-sectional 21 temperature increase of 2.13 to 2.86 degrees F (1.18 to 1.59 degrees C) for ebb tide events in 22 June and August, respectively. The average percentage of river surface width bounded by the 23 4 degrees F (2 degrees C) temperature rise isotherm ranged from 54 percent (August ebb tide) 24 to 100 percent (July and August flood tide). Average cross-sectional percentages bounded by 25 the plume ranged from 14 percent (June and September) to approximately 20 percent (July and 26 August). When the temperature rise contributions of IP2 and IP3, Bowline Point, and Roseton 27 were considered collectively (with all three facilities operating a maximum permitted capacity 28 and discharging the maximum possible heat load), the monthly cross-sectional temperature rise 29 in the vicinity of IP2 and IP3 ranged from 3.24 degrees F (1.80 degrees C) during June ebb 30 tides to 4.63 degrees F (2.57 degrees C) during flood tides in August. Temperature increases 31 exceeded 4 degrees F (2 degrees C) on both tide stages in July and August. After model 32 modifications were made to account for the variable river geometry near IP2 and IP3, 33 predictions of surface width bounded by the plume ranged from 36 percent during September 34 ebb tides to 100 percent during flood tides in all study months. On near-slack tide, the 35 percentage of the surface width bounded by the 4 degrees F (2 degrees C) isotherm was 99 to 36 100 percent in all study months. The average percentage of the cross-sectional area bounded 37 by the plume ranged from 27 percent (June ebb tide) to 83 percent (August flood tide) and was 38 24 percent in all study months during slack water events. These results suggest that the 39 4 degrees F (2 degrees C) lateral extent and cross-sectional criteria may sometimes be 40 exceeded at IP2 and IP3. Exceedences generally occurred under scenarios that the applicants 41 indicated may be considered quite conservative (maximum operation of three electrical 42 generation facilities simultaneously for long periods of time, tidal conditions promoting maximum 43 thermal impacts, atypical river flows). The steady-state assumptions of CORMIX are also 44 important because, although the modeled flow conditions in the Hudson River would actually 45 occur for only a short period of time when slack water conditions are replaced by tidal flooding, December 2008 4-25 Draft NUREG-1437, Supplement 38 OAG10001366_00234
Environmental Impacts of Operation 1 CORMIX assumes this condition has been continuous over a long period of time. CHGEC et al.
2 (1999) found that this assumption can result in an overestimate of the cross-river extent of the 3 plume centerline.
4 4.1.4.4 Assessments of Thermal Impacts 5 In this section, the NRC staff provides a summary of the various assessments of impacts 6 associated with thermal discharges from the IP2 and IP3 cooling system. The applicant's 7 assessment is based primarily on statements made in the ER (Entergy 2007a). The 8 conclusions of NYSDEC concerning the thermal impacts of the IP2 and IP3 cooling system are 9 presented in the final impact statement associated with the SPDES permits for Roseton Units 2 10 and 3, Bowline Units 1 and 2, and IP2 and IP3 (NYSDEC 2003a). The NRC staff also notes 11 that NGOs and members of the public have expressed concern that the applicant's assessment 12 of the effect of thermal discharges is incomplete, and that there is evidence to suggest that the 13 existing thermal discharges do not consistently meet applicable criteria as defined in 6 NYCRR 14 704.2(b)(5).
15 Applicant's Assessment 16 The IP2 and IP3 ER (Entergy 2007a) discusses the potential environmental impacts of thermal 17 discharges from IP2 and IP3. The conclusions provided in the ER acknowledge that the current 18 owners of IP2 and IP3 hold a NYSDEC SPDES permit (NY-0004472) and that the station is 19 complying with the terms of this permit. The conclusions of the ER also describe the current 20 mitigation required under the terms of the Fourth HRSA Consent Order that include flow 21 reductions to limit aquatic impacts and extensive studies in the Hudson River to evaluate 22 temporal and spatial trends. The applicant concludes that "continued operation in the manner 23 required by the current SPDES permit and the associated agreement to continue 24 implementation of the fourth Consent Degree ensures that thermal impacts will satisfy the 25 requirements of CWA 316(a) and will thus remain SMALL during the license renewal term.
26 Therefore, no further mitigation measures are warranted" (Entergy 2007a).
27 NYSDEC Assessment 28 In the FEIS associated with the SPDES permits for Roseton Units 1 and 2, Bowline Point Units 29 1 and 2, and IP2 and IP3 (NYSDEC 2003a), NYSDEC concludes that "Thermal modeling 30 indicates that the thermal discharge from IP2 and IP3 causes water temperatures to rise more 31 than allowed, which is four degrees (F.) over the temperature that existed before the addition of 32 heat, or a maximum of 83 of, whichever is less, in the estuary cross sections specified in 33 6 NYCRR § 704.2(b)(5)."
34 According to NYSDEC (2003b), the last SPDES permit for the Indian Point facility expired in 35 1992, but its terms have been continued under provisions of the NY State Administrative 36 Procedure Act. The fact sheet published by NYSDEC (2003b) in November 2003 describes the 37 environmental and facility operational issues and permit conditions of the draft SPDES permit 38 that NYSDEC has proposed to issue for IP2 and IP3. In Section IV, "Overview of the Permit" 39 (Section B, "Thermal Discharges"), NYSDEC indicates that the permittee must satisfy the 40 provisions of Section 316(a) of the CWA and related requirements in 6 NYCRR Section 704.2 41 "which provide that the thermal discharges from IP2 and IP3 to the Hudson River should meet 42 regulatory temperature criteria for estuaries, and must meet the NYS standard of ensuring the 43 propagation and survival of a balanced, indigenous population of shellfish, fish, and other Draft NUREG-1437, Supplement 38 4-26 December 2008 OAG10001366_00235
Environmental Impacts of Operation 1 aquatic species."
2 To meet this goal, NYSDEC requires, within the first 2 years of the SPDES permit term, that 3 Entergy conduct a triaxial (three-dimensional) thermal study to document whether the thermal 4 discharges associated with the operation of IP2 and IP3 comply with New York State water 5 quality criteria. In the event the discharges do not comply, the permittee is allowed to apply for 6 a modification of one or more criteria as provided by 6 NYCRR Section 704.4, but must 7 demonstrate to the satisfaction of NYSDEC "that one or more of the criteria are unnecessarily 8 restrictive and that the modification would not inhibit the existence and propagation of a 9 balanced indigenous population of shellfish, fish, and wildlife in the Hudson River" (NYSDEC 10 2003a). In the ongoing proceeding before NYSDEC, Entergy has indicated that it would 11 propose an alternative study. This matter is still under review before NYSDEC, and may not be 12 resolved before NRC issues a final SEIS (Entergy 2006).
13 4.1.4.5 NRC Staff Assessment of Thermal Impacts 14 In the absence of the thermal study proposed by NYSDEC (or an alternative proposed by 15 Entergy and accepted by NYSDEC), existing information must be used to determine the 16 appropriate thermal impact level to sensitive lifestages of important aquatic species. Since 17 NYSDEC modeling in the FEIS (NYSDEC 2003a) indicates that discharges from IP2 and IP3 18 could raise water temperatures to a level greater than that permitted by water quality criteria that 19 are a component of existing NYSDEC permits, the staff must conclude that adverse impacts are 20 possible. The NRC staff, after a review of available information on aquatic life in the Hudson 21 River Estuary, did not find evidence of adverse effects on aquatic life that are clearly noticeable 22 and sufficient to destabilize important attributes of an aquatic resource (the criteria for a LARGE 23 finding). In the absence of specific studies, and in the absence of effects sufficient to make a 24 determination of a LARGE impacts, the NRC staff concludes that thermal impacts from IP2 and 25 IP# could thus range from SMALL to MODERATE depending on the extent and magnitude of 26 the thermal plume, the sensitivity of various aquatic species and lifestages likely to encounter 27 the thermal plume, and the probability of an encounter occurring that could result in lethal or 28 sublethal effects. Additional thermal studies-as proposed by NYSDEC and Entergy-will 29 generate data that could further refine or modify this impact level. For the purposes of this draft 30 SEIS, the NRC staff concludes that impacts could range from SMALL to MODERATE.
31 4.1.5 Potential Mitigation Options 32 Potential mitigation options related to the operation of the IP2 and IP3 once-through cooling 33 system are discussed in Chapter VII of the DEIS (CHGEC et al. 1999). Impacts associated with 34 impingement were assumed by the Hudson River utilities to be adequately mitigated because 35 previous IP2 and IP3 owners installed dual- and variable-speed pumps at IP2 and IP3, 36 respectively, in 1994, and also installed modified Ristroph screens at both units in the early 37 1990s (CHGEC et al. 1999). The summary conclusion of the DEIS in 1999 was that the Hudson 38 River utilities considered the system to be the best technology available to mitigate impingement 39 losses (CHGEC et al. 1999). NYSDEC, however, has determined that closed-cycle cooling is 40 the best technology available to protect aquatic resources (NYSDEC 2003b).
41 CHGEC et al. (1999) also discusses the mitigation of entrainment losses at IP2 and IP3 by 42 ensuring that minimum flows are used for reactor cooling through the use of dual- or variable-43 speed pumps. In the ER (Entergy 2007a), the applicant concludes that, because impingement December 2008 4-27 Draft NUREG-1437, Supplement 38 OAG10001366_00236
Environmental Impacts of Operation 1 and entrainment are not having any demonstrable negative effects on Hudson River RIS, further 2 mitigation measures are not warranted. NYSDEC's FEIS (2003a) indicated that "a range of 3 available technologies exist to minimize aquatic resource mortality from the cooling water intake 4 structures" at the Hudson River power plants, including IP2 and IP3. While NYSDEC indicated 5 that IP2 and IP3 pump systems and modified Ristroph screens help mitigation impingement 6 mortality, it also indicated that "significant unmitigated mortalities from entrainment and 7 impingement" remain at all of the Hudson River power plants (NYSDEC 2003a).
8 The NRC staff, in the results of its analysis provided in Sections 4.1.3 and 4.1.4 of this draft 9 SEIS, has found that impingement and entrainment from the operation of IP2 and IP3 are likely 10 to have an adverse effect on aquatic ecosystems in the lower Hudson River during the period of 11 extended operation. The available evidence suggests that the operation of the cooling systems 12 directly affects RIS by impingement and entrainment, and indirectly affects these resources 13 through the impingement and entrainment of their prey. The thermal discharges may also be 14 influencing RIS, but the extent of this influence cannot be determined without further studies, 15 such as those proposed in the draft SPDES permit for IP2 and IP3.
16 To assess potential mitigation options, the NRC staff reviewed the comments and responses 17 provided in NYSDEC (2003a) and information provided by EPA in support of its Phase II 316(b) 18 program (EPA 2008a). Based on this review, additional mitigation options that may be available 19 for the existing cooling system include the following:
20
- additional flow reductions or planned outages 21
- use of wedgewire or fine-mesh screens 22
- use of barrier systems at the intake locations 23
- use of behavioral deterrent systems 24
- closed-cycle cooling using cooling towers (e.g., hybrid wet/dry mechanical draft towers) 25
- restoration 26 What follows is an overview of the effects of employing the above mitigation options to the 27 existing system currently in operation at IP2 and IP3. Because NYSDEC indicated closed-cycle 28 cooling is the best technology available for IP2 and IP3 (NYSDEC 2003b), the NRC staff will 29 review a cooling tower alternative in Chapter 8, as well as an alternative that includes 30 restoration with other mitigation measures intended to offset the effects of the existing once-31 through cooling system. Because the NRC staff will address them in greater depth in Chapter 32 8, closed-cycle cooling and restoration will not be addressed further in this chapter.
33 Costs and benefits of these measures have been addressed in the 1999 DEIS and evaluated by 34 NYSDEC in the FEIS. Of these alternative options, NYSDEC received comments indicating that 35 the cost figures for closed-cycle cooling in the DEIS were inflated by the Hudson River utilities.
36 After reviewing cost data with consultants, however, NYSDEC indicated that costs were 37 generally reasonable (noting that site-specific factors and changes in the cost of replacement 38 power may affect cost estimates) (NYSDEC 2003a).
39 The measures the NRC staff addresses below and in Chapter 8, as well as any other measures 40 to reduce entrainment and impingement at Indian Point, fall under the regulatory authority of 41 NYSDEC and the powers delegated to it by the EPA under the CWA. While the NRC has no Draft NUREG-1437, Supplement 38 4-28 December 2008 OAG10001366_00237
Environmental Impacts of Operation 1 role in regulating or enforcing water quality standards, the NRC staff has included these 2 mitigation measures in the interest of fulfilling the NRC's obligations under the National 3 Environmental Policy Act (NEPA) (42 USC 4321, et. seq) and 10 CFR Part 51.
4 Additional Flow Reductions or Shutdowns 5 As discussed in Section 4.1.1.1 of this draft SEIS, under the conditions of HRSA and the 6 subsequent consent orders, the operators of IP2 and IP3 developed programs to employ flow-7 reduction measures and scheduled outages to reduce impingement and entrainment impacts.
8 Because flow rates were dependent on water temperature, greater flows were required during 9 the months of May through October when river water temperatures were above 15 degrees C.
10 It may be possible to further reduce flows or increase the length or frequency of scheduled 11 outages, though these options will cause the plant operator to lose revenue from operating IP2 12 and IP3. In the 1999 DEIS, CHGEC et al. estimated that outages could cost between 13 $14 million and $73 million per year.
14 Wedgewire or Fine-Mesh Screens 15 In some cases, the use of wedgewire or fine-mesh screens has shown potential for decreasing 16 entrainment at once-through powerplants. Wedgewire screens typically have a screen size of 17 0.5 to 10 mm and are designed to reduce entrainment by physical exclusion and exploiting 18 hydrodynamic patterns (EPA 2008). Fine-mesh screens generally employ a mesh size of 19 0.5 mm or less, and reduce entrainment by gently trapping organisms and reintroducing them 20 back into the environment via plant-specific collection and transfer systems. Factors influencing 21 the use of this technology include the screen size, the location and configuration of the system 22 relative to the intake, the intake flow rates, the presence and magnitude of a "sweeping" current 23 that can limit impingement or move organisms past the screen into safe water, and the size of 24 the organism present near the intake. In its evaluation of wedgewire and fine-mesh screens, 25 EPA (2008a) indicated that these technologies showed promise for reducing entrainment, but 26 expressed concerns about the maintenance required to prevent clogging and the potential for 27 this technology to reduce entrainment but increase impingement. EPA (2008a) considered the 28 use of wedgewire screen technology to be more suitable for use in closed-cycle makeup water 29 systems where lower flow rates exist and fewer screens are required.
30 Because the portion of the Hudson River near IP2 and IP3 is subject to tidal influence, there are 31 periods of time when a sweeping current is not present. During this time, impingement against 32 wedgewire or fine-mesh screen systems would be exacerbated. Although the use of these 33 technologies at IP2 and IP3 is possible, numerous technical challenges would exist, including 34 how to configure and clean the screens, how to evaluate capture and removal success, and 35 how to assess the environmental effects and tradeoffs that would occur when one type of 36 impact (entrainment) is reduced while another impact (impingement) may increase. CHGEC 37 estimated that wedgewire screens could cost $44 million to $55 million per year in lost electricity 38 production, and indicated that fine-mesh screens would not be feasible.
39 Barrier Systems 40 Gunderboom and Marine Life Exclusion System' (MLESTM) technologies provide additional 41 exclusion of entrainable-sized organism from cooling systems. Nets or screens are deployed 42 during peak periods of entrainment to reduce overall entrainment. Gunderboom technology has 43 been evaluated at the Lovett fossil fuel generating station since 1994. The system deployed in 44 2000 consisted of a two-ply fabric 500 feet (ft) (150 meters (m)) long, with a surface area of December 2008 4-29 Draft NUREG-1437, Supplement 38 OAG10001366_00238
Environmental Impacts of Operation 1 8000 square feet (ft2) (743 square meters (m2)), and equipped with 500-micrometer (0.020 in.)
2 perforations. The system extended to a depth of 20-30 ft (6.1-9.1 m) and was held in place 3 with anchors. An automated airburst system with strain gages and head differential monitors 4 was used to release compressed air at depth to clean the screens. The preliminary results from 5 the 2000 deployment documented by Raffenberg et al. (2008) suggested that the system 6 resulted in an 80-percent reduction in ichthyoplankton entering the facility, and that periodic 7 elevated densities of ichthyoplankton inside the barrier were linked to breaches of the system.
8 Impingement investigations suggested that eggs did not adhere to fabric, and mortality was 9 below 2 percent in laboratory studies. Based on observational data, larvae did not orient toward 10 the flow, and did not impinge on the fabric with a through-fabric velocity of 5 gallons per minute 11 per square foot or 0.20 meters per minute (Raffenberg et al. 2008).
12 The use of barrier systems may be feasible at IP2 and IP3 as a mitigation action, but further 13 study may be needed to determine the long-term impacts of these systems. CHGEC et al.
14 (1999) indicated that barrier nets or fine-mesh barrier nets would not be feasible at Indian Point, 15 and did not assign a cost. EPA (2008), however, has indicated that barrier systems like 16 Gunderboom show significant promise for minimizing entrainment, but still considers the 17 technology "experimental in nature." Some advantages of the systems are that they can be 18 deployed, retrieved, and replaced seasonally as needed. They are suitable for use in all types 19 of water bodies and appear to reduce entrainment and impingement losses. The disadvantages 20 are related to the limited number of long-term studies available to assess the performance of the 21 technology, the durability of the systems in high-energy areas, the level of maintenance and 22 monitoring required, the effects of biofouling on system performance, and the large volume of 23 water that IP2 and IP3 withdraw. Additionally, it may be necessary to determine whether 24 potential safety issues associated with the deployment of the systems at a nuclear generating 25 station can be addressed.
26 Behavioral Deterrent Systems 27 Behavioral deterrent systems such as noncontact sound barriers or the use of light sources to 28 reduce impingement have been evaluated at a variety of power generating stations in marine, 29 estuarine, and freshwater environments (EPA 2008a). At present, a sonic deterrent system is 30 being used at the Danskammer Point fossil energy plant on the Hudson River, and a similar 31 system has been evaluated at Roseton. The advantage to these systems is that they can be 32 configured and deployed at a variety of locations at costs that are not prohibitively high for 33 simple system configurations. The disadvantages of the systems are that pneumatic air guns, 34 hammers, and fishpulser systems are not considered reliable, the cost of sophisticated acoustic 35 sound-generating systems can be high, and the use of high-technology equipment requires 36 maintenance at the site (EPA 2008a). EPA (2008a) further states that, although many studies 37 have been conducted to evaluate the feasibility of sound and light to reduce impingement and 38 entrainment, the results "have either been inconclusive or shown no tangible reduction in 39 impingement or entrainment" (EPA 2008a). There is, however, evidence that the use of 40 acoustic sound barriers at a site in Pickering, Ontario, did appear to reduce the impingement 41 and entrainment of alewife, but no benefits were realized for rainbow smelt or gizzard shad. At 42 the Roseton facility, the use of sound barriers provided little or no deterrence for any species 43 (EPA 2008a). In its review, the EPA concluded that it may be possible to employ acoustic or 44 light barrier systems in conjunction with other technologies to reduce impingement or 45 entrainment, but further studies are likely necessary to evaluate the feasibility of various Draft NUREG-1437, Supplement 38 4-30 December 2008 OAG10001366_00239
Environmental Impacts of Operation 1 technology combinations. The 1999 DEIS from CHGEC et al. indicated an unknown cost 2 associated with implementing behavioral deterrence systems.
3 4.2 Transmission Lines 4 The two transmission lines and right-of-ways (ROWs) built to connect IP2 and IP3 with the 5 transmission system that existed before their construction are described in Section 2.1.7 and 6 mapped on Figure 2-3 of this draft SEIS. The lines are each about 2000 ft (610 m) in length, 7 and have ROW widths of approximately 150 ft (46 m). The transmission lines are located within 8 the site except for a terminal, 100-ft (30.5-m) segment of each that crosses the facility boundary 9 and Broadway (a public road) to connect to the Buchanan substation (Entergy 2007a).
10 Of the total of 4000 ft (1220 m) of transmission line, about 3500 ft (1070 m) traverses buildings, 11 roads, parking lots, and other developed areas. The remaining 500 ft (150 m) of ROW is 12 vegetated. In these segments, the growth of trees is prevented and a cover of mainly grasses 13 and forbs is maintained.
14 Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, that are applicable to 15 the IP2 and IP3 transmission lines are listed in Table 4-5 of this draft SEIS. The applicant 16 stated in its ER that it is not aware of any new and significant information associated with the 17 renewal of the IP2 and IP3 operating licenses (Entergy 2007a). The NRC staff has not 18 identified any new and significant information during its independent review of the Entergy ER, 19 the NRC staff's site audit, the scoping process, or evaluation of other available information.
20 Therefore, the NRC staff concludes that there would be no impacts related to these issues 21 beyond those discussed in the GElS. For all of those issues, the NRC staff concluded in the 22 GElS that the impacts would be SMALL, and additional plant-specific mitigation measures are 23 not likely to be sufficiently beneficial to warrant implementation.
24 Table 4-5. Category 1 Issues Applicable to the IP2 and IP3 Transmission Lines 25 during the Renewal Term ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Sections TERRESTRIAL RESOURCES Power line right-of-way management (cutting and herbicide application) 4.5.6.1 Bird collisions with power lines 4.5.6.2 Impacts of electromagnetic fields on flora and fauna (plants, agricultural crops, 4.5.6.3 honeybees, wildlife, livestock)
Floodplains and wetland on power line right-of-way 4.5.7 AIR QUALITY Air quality effects of transmission lines 4.5.2 LAND USE Onsite land use 4.5.3 Power line right-of-way 4.5.3 December 2008 4-31 Draft NUREG-1437, Supplement 38 OAG10001366_00240
Environmental Impacts of Operation ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Sections 1 A brief description of the GElS conclusions, as codified in Table B-1, for each of these issues 2 follows:
3
- Power line right-of-way management (cutting and herbicide application). Based on 4 information in the GElS, the Commission found the following:
5 The impacts of right-of-way maintenance on wildlife are expected to be of small 6 significance at all sites.
7
- Bird collisions with power lines. Based on information in the GElS, the Commission 8 found the following:
9 Impacts are expected to be of small significance at all sites.
10
- Impacts of electromagnetic fields (EMFs) on flora and fauna (plants, agricultural crops, 11 honeybees, wildlife, livestock). Based on information in the GElS, the Commission 12 found the following:
13 No significant impacts of electromagnetic fields on terrestrial flora and fauna 14 have been identified. Such effects are not expected to be a problem during the 15 license renewal term.
16
- Floodplains and wetlands on power line right-of-way. Based on information in the GElS, 17 the Commission found the following:
18 Periodic vegetation control is necessary in forested wetlands underneath power 19 lines and can be achieved with minimal damage to the wetland. No significant 20 impact is expected at any nuclear power plant during the license renewal term.
21
- Air quality effects of transmission lines. Based on the information in the GElS, the 22 Commission found the following:
23 Production of ozone and oxides of nitrogen is insignificant and does not 24 contribute measurably to ambient levels of these gases.
25
- Onsite land use. Based on the information in the GElS, the Commission found the 26 following:
27 Projected on-site land use changes required during ... the renewal period would 28 be a small fraction of any nuclear power plant site and would involve land that is 29 controlled by the applicant.
30
- Power line right-of-way. Based on information in the GElS, the Commission found the 31 following:
32 Ongoing use of power line rights-of-way would continue with no change in 33 restrictions. The effects of these restrictions are of small significance.
Draft NUREG-1437, Supplement 38 4-32 December 2008 OAG10001366_00241
Environmental Impacts of Operation 1 The NRC staff identified no new and significant information associated with these issues during 2 the review. Therefore, the NRC staff expects that there would be no impacts during the renewal 3 term beyond those discussed in the GElS.
4 The NRC staff has identified one Category 2 issue and one un categorized issue related to 5 transmission lines. These issues are listed in Table 4-6 and are discussed in Sections 4.2.1 6 and 4.2.2 of this draft SEIS.
7 Table 4-6. Category 2 and Uncategorized Issues Applicable to the IP2 and IP3 8 Transmission Lines during the Renewal Term 10 CFR ISSUE-10 CFR Part 51, Subpart A, GElS 51.53(c)(3)(ii) SEIS Appendix B, Table B-1 Sections Subparagraph Section HUMAN HEALTH Electromagnetic fields, acute effects 4.5.4.1 H 4.2.1 (electric shock)
Electromagnetic fields, chronic effects 4.5.4.2 NA 4.2.2 9 4.2.1 Electromagnetic Fields-Acute Effects 10 Based on the GElS, the Commission determined that electric shock resulting from direct access 11 to energized conductors or from induced charges in metallic structures has not been found to be 12 a problem at most operating plants and generally is not expected to be a problem during the 13 license renewal term. However, site-specific review is required to determine the significance of 14 the electric shock potential along the portions of the transmission lines that are within the scope 15 of this draft SEIS.
16 In the GElS, the NRC staff found that, without a review of the conformance of each nuclear 17 plant transmission line to National Electrical Safety Code (N ESC) (I EEE 1997) criteria, it was 18 not possible to determine the significance of the electric shock potential. Evaluation of 19 individual plant transmission lines is necessary because the issue of electric shock safety was 20 not addressed in the licensing process for some plants. For other plants, land use in the vicinity 21 of transmission lines may have changed, or power distribution companies may have chosen to 22 upgrade line voltage. To comply with 10 CFR 51.53(c)(3)(ii)(H), the applicant must provide an 23 assessment of the potential shock hazard if the transmission lines that were constructed for the 24 specific purpose of connecting the plant to the transmission system do not meet the 25 recommendations of the NESC for preventing electric shock from induced currents.
26 As described in Section 2.1.7 of this draft SEIS, two 345-kilovolt (kV) transmission lines were 27 built to distribute power from IP2 and IP3 to the electric grid. Also, two 138-kV lines that use the 28 same transmission towers supply offsite (standby) power to IP2 and IP3. These lines are 29 contained within the IP2 and IP3 site, except for where they cross Broadway (a public road) to 30 connect to the Buchanan substation. Electric lines having voltages exceeding 98 kV of 31 alternating current to ground must comply with the NESC provision on minimum vertical 32 clearance, adopted in 1977, that limits the steady-state current from electrostatic effects to 5 33 milliamperes (mA) if the largest anticipated truck, vehicle, or equipment under the line were December 2008 4-33 Draft NUREG-1437, Supplement 38 OAG10001366_00242
Environmental Impacts of Operation 1 short circuited to ground. The New York Public Service Commission (NYPSC) requires a more 2 restrictive induced current limit of 4.5 mA (Entergy 2007a).
3 Entergy indicates that at the time it acquired IP2 from the Consolidated Edison Company of 4 New York, the transmission lines connecting IP2 and IP3 to the Buchanan substation were in 5 compliance with the applicable NESC provisions for preventing electric shock from induced 6 current. The lines were also in compliance with the NYPSC 4.5-mA criterion, as calculated 7 using the methods described in the Electric Power Research Institute (EPRI) document 8 "Transmission Line Reference Book" (Con Edison 2007). There have been no configuration or 9 operation changes made to these lines since transfer of their ownership to Entergy (Entergy 10 2007a). Entergy indicates that it has maintenance procedures to ensure that the transmission 11 lines continue to conform to ground clearance standards (Entergy 2008).
12 Entergy commissioned a study of the two 345-kV lines that connect IP2 and IP3 to the electric 13 transmission system to demonstrate to the NRC staff that they meet the NESC and NYPSC 14 requirements (Enercon 2008). The two 138-kV lines, which are at similar ground-crossing 15 heights to the 345-kV lines, are also addressed by the study. The analysis was performed using 16 the EPRI TL Workstation calculation software to determine the highest ground-level electric field 17 strengths at the ROWs where they cross Broadway. Enercon employed procedures and 18 calculations from the EPRI "Transmission Line Reference Book, 200kV and Above (Third 19 Edition)", which Enercon indicates is the industry-accepted reference for transmission line 20 design and field effects. Enercon notes that The EPRI parameters for a 55-ft- (17-m)-long 21 tractor trailer were used, with the length increased to 65 ft (20 m) to represent the maximum 22 allowed under New York size restrictions. The analysis revealed a maximum calculated 23 induced current for the 345-kV lines of 1.3 mA, below the NYPSC 4.5-mA limit (Enercon 2008).
24 In the GElS, the NRC staff found that electrical shock is of SMALL significance for transmission 25 lines that are operated in adherence with the NESC criteria for limiting hazards. Based on a 26 review of the available information, including that provided in the ER (Entergy 2007a), the NRC 27 staff's environmental site audit, the scoping process, the NRC staff's evaluation of Entergy's 28 2008 study (Enercon 2008), and existing NESC requirements, the NRC staff concludes that the 29 transmission lines associated with IP2 and IP3 meet NESC criteria for limiting hazards, and thus 30 the potential impact from electric shock during the renewal term is SMALL.
31 The NRC staff identified measures that could further mitigate potential acute EMF impacts 32 resulting from continued operation of the IP2 and IP3 transmission lines, including installing 33 road signs at road crossings and increasing transmission line clearances. These mitigation 34 measures could reduce human health impacts by minimizing public exposures to electric shock 35 hazards. The staff did not identify any cost benefit studies applicable to the mitigation measures 36 mentioned above.
37 4.2.2 Electromagnetic Fields-Chronic Effects 38 In the GElS, the chronic effects of 60-hertz EMFs from power lines were not designated as 39 Category 1 or 2, and a designation will not be made until scientific consensus is reached on the 40 health implications of these fields.
41 The potential for chronic effects from these fields continues to be studied and is not known at 42 this time. The National Institute of Environmental Health Sciences (NIEHS) directs related Draft NUREG-1437, Supplement 38 4-34 December 2008 OAG10001366_00243
Environmental Impacts of Operation 1 research through the U.S. Department of Energy (DOE). The 1999 report of the NIEHS and 2 DOE Working Group (NIEHS 1999) contains the following conclusion:
3 The NIEHS concludes that ELF-EMF [extremely low frequency-electromagnetic 4 field] exposure cannot be recognized as entirely safe because of weak scientific 5 evidence that exposure may pose a leukemia hazard. In our opinion, this finding 6 is insufficient to warrant aggressive regulatory concern. However, because 7 virtually everyone in the United States uses electricity and therefore is routinely 8 exposed to ELF-EMF, passive regulatory action is warranted, such as a 9 continued emphasis on educating both the public and the regulated community 10 on means aimed at reducing exposures. The NIEHS does not believe that other 11 cancers or non-cancer health outcomes provide sufficient evidence of a risk to 12 currently warrant concern.
13 This statement is not sufficient to cause the NRC to reach a conclusion with respect to the 14 chronic effects of EMFs as detailed below (from 10 CFR Part 51, Subpart A, Appendix B, Table 15 B-1):
16 If, in the future, the Commission finds that, contrary to current indications, a 17 consensus has been reached by appropriate Federal health agencies that there 18 are adverse health effects from electromagnetic fields, the Commission will 19 require applicants to submit plant-specific reviews of these health effects as part 20 of their license renewal applications. Until such time, applicants for license 21 renewal are not required to submit information on this issue.
22 The NRC staff considers the GElS finding of "uncertain" still appropriate and continues to follow 23 developments on this issue.
24 4.3 Radiological Impacts of Normal Operations 25 Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, applicable to IP2 and 26 IP3 in regard to radiological impacts are listed in Table 4-7. Entergy stated in its ER that it was 27 aware of one new issue associated with the renewal of the IP2 and IP3 operating licenses-28 potential ground water contamination and a new radioactive liquid effluent release pathway as a 29 result of leakage from the plant. The NRC staff has discussed this issue and the various studies 30 relating to it in Section 2.2.7 of this draft SEIS, and addresses the significance of this issue in 31 Section 4.5. The NRC staff has not identified any new and significant information, beyond the 32 new issue identified by the applicant in its ER, during its independent review of Entergy's ER, 33 the site audit, the scoping process, NRC inspection reports, or its evaluation of other available 34 information.
35 As discussed in Sections 2.2.7 and 4.5 of this SEIS, the NRC staff concludes that the new issue 36 is not significant, and thus does not challenge the finding in the GElS. According to the GElS, 37 the impacts to human health are SMALL, and additional plant-specific mitigation measures are 38 not likely to be sufficiently beneficial to be warranted.
December 2008 4-35 Draft NUREG-1437, Supplement 38 OAG10001366_00244
Environmental Impacts of Operation 1 Table 4-7. Category 1 Issues Applicable to Radiological Impacts of Normal Operations 2 during the Renewal Term ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Sections HUMAN HEALTH Radiation exposures to public (license renewal term) 4.6.2 Occupational radiation exposures (license renewal term) 4.6.3 3 The NRC staff has not identified any new and significant information, beyond the new issue 4 identified by the applicant in its ER concerning potential ground water contamination and a new 5 radioactive effluent release pathway for leakage from the plant, during its independent review of 6 Entergy's ER, the site audit, the scoping process, NRC inspection reports, or its evaluation of 7 other available information. The NRC evaluated the detailed information provided by the 8 applicant, State agencies, and NRC inspections on the new issue and concluded that the new 9 issue is not significant and that the impacts are SMALL. Therefore, the NRC staff concludes 10 that there would be no impact from radiation exposures to the public or to workers during the 11 renewal term beyond those discussed in the GElS.
12 The NRC staff concludes that the abnormal liquid releases discussed by Entergy in its ER, while 13 new information, are within the NRC's radiation safety standards contained in 10 CFR Part 20, 14 "Standards for Protection against Radiation," and are not considered to have a significant 15 impact on plant workers, the public, or the environment. Furthermore, the NRC staff 16 acknowledges that the commitments made by Entergy-and identified in Section 2.2.7 of this 17 SEIS-for long-term monitoring and remediation will help to minimize the potential impacts from 18 contaminated ground water and help maintain radiological impacts within NRC radiation safety 19 standards.
20
- Radiation exposures to public (license renewal term). Based on information in the GElS, 21 the Commission found the following:
22 Radiation doses to the public will continue at current levels associated with 23 normal operations.
24
- Occupational exposures to public (license renewal term). Based on information in the 25 GElS, the Commission found the following:
26 Projected maximum occupational doses during the license renewal term are 27 within the range of doses experienced during normal operations and normal 28 maintenance outages, and would be well below regulatory limits.
29 The NRC staff identified no information that was both new and significant on these issues during 30 the review. Therefore, the NRC staff expects that there would be no impacts during the renewal 31 term beyond those discussed in the GElS.
32 There are no Category 2 issues related to radiological impacts of routine operations.
Draft NUREG-1437, Supplement 38 4-36 December 2008 OAG10001366_00245
Environmental Impacts of Operation 1 4.4 Socioeconomic Impacts of Plant Operations during the License 2 Renewal Term 3 Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, applicable to 4 socioeconomic impacts during the renewal term are listed in Table 4-8 of this draft SEIS. As 5 stated in the GElS, the impacts associated with these Category 1 issues were determined to be 6 SMALL, and plant-specific mitigation measures would not be sufficiently beneficial to be 7 warranted.
8 Table 4-8. Category 1 Issues Applicable to Socioeconomics during the Renewal Term ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Section SOCIOECONOMICS Public services: public safety, social services, and tourism and 4.7.3; 4.7.3.3; recreation 4.7.3.4; 4.7.3.6 Public services: education (license renewal term) 4.7.3.1 Aesthetic impacts (license renewal term) 4.7.6 Aesthetic impacts of transmission lines (license renewal term) 4.5.8 9 The NRC staff reviewed and evaluated the IP2 and IP3 ER, scoping comments, and other 10 available information. The NRC staff also visited IP2 and IP3 in search of new and significant 11 information that would change the conclusions presented in the GElS. No new and significant 12 information was identified during this review and evaluation. Therefore, the NRC staff 13 concludes that there would be no impacts related to these Category 1 issues during the renewal 14 term beyond those discussed in the GElS.
15 The results of the review and brief statement of GElS conclusions, as codified in Table B-1 of 16 10 CFR Part 51, Subpart A, Appendix B, for each of the socioeconomic Category 1 issues are 17 provided below:
18
- Public services: public safety, social services, and tourism and recreation. Based on 19 information in the GElS, the Commission found the following:
20 Impacts to public safety, social services, and tourism and recreation are 21 expected to be of small significance at all sites.
22
- Public services: education (license renewal term). Based on information in the GElS, 23 the Commission found the following:
24 Only impacts of small significance are expected.
25
- Aesthetic impacts (license renewal term). Based on information in the GElS, the 26 Commission found the following:
27 No significant impacts are expected during the license renewal term.
December 2008 4-37 Draft NUREG-1437, Supplement 38 OAG10001366_00246
Environmental Impacts of Operation 1
- Aesthetic impacts of transmission lines (license renewal term). Based on information in 2 the GElS, the Commission found the following:
3 No significant impacts are expected during the license renewal term.
4 The NRC staff identified no new and significant information regarding these issues during the 5 review. Therefore, the NRC staff expects that there would be no impacts during the renewal 6 term beyond those discussed in the GElS.
7 Table 4-9 lists the Category 2 socioeconomic issues, which require plant-specific analysis, and 8 an environmental justice impact analysis, which was not addressed in the GElS.
9 Table 4-9. Category 2 Issues Applicable to Socioeconomics 10 and Environmental Justice during the Renewal Term 10 CFR ISSUE-10 CFR Part 51, Subpart A, 51.53(c)(3)(ii) SEIS Appendix B, Table B-1 GElS Section Subparagraph Section SOCIOECONOMICS Housing impacts 4.7.1 4.4.1 Public services: public utilities 4.7.3.5 4.4.2 Offsite land use (license renewal term) 4.7.4 4.4.3 Public services: transportation 4.7.3.2 J 4.4.4 Historic and archeological resources 4.7.7 K 4.4.5 Environmental justice Not addressed(a) Not addressed(a) 4.4.6 (a)Guidance related to environmental justice was not in place at the time the GElS and the associated revision to 10 CFR Part 51 were prepared. Therefore, environmental justice must be addressed in plant-specific reviews.
11 4.4.1 Housing Impacts 12 Appendix C to the GElS presents a population characterization method based on two factors, 13 sparseness and proximity (see Section C.1.4). Sparseness measures population density within 14 20 miles (mi) (32 kilometers (km)) of the site, and proximity measures population density and 15 city size within 50 mi (80 km). Each factor has categories of density and size (see Table C.1 of 16 the GElS). A matrix is used to rank the population category as low, medium, or high (see Figure 17 C.1 of the GElS).
18 In Chapter 2 of this draft SEIS, the NRC staff describes the local population around IP2 and IP3.
19 As NRC staff indicated in Section 2.2.8.5, the 2000 U.S. Census noted that approximately 20 1,113,089 people lived within 20 mi (32 km) of IP2 and IP3, which equates to a population 21 density of 886 persons per square mi (332 persons per square km). This density translates to 22 the least sparse Category 4 (greater than or equal to 120 persons per square mi within 20 mi).
23 Approximately 16,791,654 people live within 50 mi (80 km) of IP2 and IP3 (Entergy 2007a).
24 This equates to a population density of 2138 persons per square mi (825 persons per square 25 km). Applying the GElS proximity measures, the IP2 and IP3 site is classified as proximity 26 Category 4 (greater than or equal to 190 persons per square mi within 50 mi). Therefore, 27 according to the sparseness and proximity matrix presented in the GElS, IP2 and IP3 ranks of Draft NUREG-1437, Supplement 38 4-38 December 2008 OAG10001366_00247
Environmental Impacts of Operation 1 sparseness Category 4 and proximity Category 4 result in the conclusion that Indian Point is 2 located in a high population area.
3 Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, states that impacts on housing availability 4 are expected to be of small significance in high-density population areas where growth-control 5 measures are not in effect. Since Indian Point is located in a high population area and 6 Dutchess, Orange, Putnam, and Westchester Counties are not subject to growth-control 7 measures that would limit housing development, any changes in IP2 and IP3 employment would 8 have little noticeable effect on housing availability in these counties. Because Entergy has 9 indicated in its ER that there would be no hiring of additional workers to support license renewal, 10 nonoutage employment levels at IP2 and IP3 would remain relatively constant with no additional 11 demand for permanent housing during the license renewal term (Entergy 2007a). In addition, 12 the number of available housing units has kept pace with or exceeded the low growth in the 13 area population. Based on this information, the NRC staff concludes that there would be no 14 impact on permanent housing during the license renewal term beyond what is currently being 15 experienced.
16 However, Entergy has indicated that it may replace IP2 and IP3 reactor vessel heads and 17 control rod drive mechanisms (CRDMs) at some time in the future before or during the license 18 renewal term, and the decision to proceed with this replacement activity would be made based 19 on future inspection results (Entergy 2008b). Entergy estimates that this replacement activity at 20 IP2 and IP3 would require an increase in the number of refueling outage workers for up to 60 21 days during two separate refueling outages, one for each unit, 12 months apart (Entergy 22 2008b). These additional workers would increase the demand for temporary (rental) housing in 23 the immediate vicinity of IP2 and IP3. Even though it is not certain whether Entergy will replace 24 the reactor vessel heads and CRDMs, the NRC staff has reviewed the potential environmental 25 impacts of this replacement activity. These impacts are discussed in Chapter 3 of this draft 26 SEIS.
27 4.4.2 Public Services-Public Utility Impacts 28 The GElS indicates that impacts on public utilities are SMALL if the existing infrastructure could 29 accommodate plant-related demand without a noticeable effect on the level of service. The 30 GElS indicates that MODERATE impacts arise when the demand for service or use of the 31 infrastructure is sizeable and would noticeably decrease the level of service or require additional 32 resources to maintain the level of service. The GElS indicates that LARGE impacts would result 33 when new programs, upgraded or new facilities, or substantial additional staff are required 34 because of plant-related demand.
35 In the absence of new and significant information to the contrary, the only impacts on public 36 utilities that the NRC staff found in the GElS could be significant during license renewal are 37 impacts on public water supplies. The NRC staff's analysis of impacts on the public water and 38 sewer systems considered both plant demand and plant-related population growth. In the 39 GElS, the NRC staff found that impacts from license renewal on public water supplies could 40 range from SMALL to MODERATE, with the site-specific impact depending on factors that exist 41 at each plant site.
42 As previously discussed (in Section 2.2.8.2) of this draft SEIS, potable water and process water 43 is supplied to IP2 and IP3 by the Village of Buchanan water supply system (VBNY 2006). IP2 December 2008 4-39 Draft NUREG-1437, Supplement 38 OAG10001366_00248
Environmental Impacts of Operation 1 and IP3 use approximately 2.3 million fe (65,000 m3 ) or 17.4 million gallons of potable water per 2 month, and there is no indicated restriction on the amount of potable water that IP2 and IP3 can 3 use. Further, Entergy (NRC 2007a) does not project an increase in plant demand.
4 Because Entergy staff has indicated that there would be no hiring of additional workers during 5 the license renewal period (Entergy 2007a), overall employment levels at IP2 and IP3 would 6 remain relatively unchanged with no additional demand for public water and sewer services.
7 Public water systems in the region would remain adequate to meet the demands of residential 8 and industrial customers in the area. Therefore, there would be no impact to public water and 9 sewer services during the license renewal term beyond what is currently being experienced.
10 As discussed in Section 4.4.1 of this draft SEIS, Entergy might replace the IP2 and IP3 reactor 11 vessel heads and CRDMs during the license renewal term (Entergy 2008b). The additional 12 number of refueling outage workers needed for this replacement activity would cause short-term 13 increases in the amount of public water and sewer services used in the immediate vicinity of IP2 14 and IP3. These impacts are discussed in Chapter 3 of this draft SEIS.
15 4.4.3 Offsite Land Use-License Renewal Period 16 Offsite land use during the license renewal term is a Category 2 issue (10 CFR Part 51, Subpart 17 A, Appendix B, Table B-1). Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, notes that 18 "significant changes in land use may be associated with population and tax revenue changes 19 resulting from license renewal."
20 Section 4.7.4 of the GElS defines the magnitude of land use changes as a result of plant 21 operation during the license renewal term as follows:
22 SMALL-Little new development and minimal changes to an area's land use 23 pattern.
24 MODERATE-Considerable new development and some changes to the land 25 use pattern.
26 LARGE-Large-scale new development and major changes in the land use 27 pattern.
28 Tax revenue can affect land use because it enables local jurisdictions to provide the public 29 services (e.g., transportation and utilities) necessary to support development. Section 4.7.4.1 of 30 the GElS states that the assessment of tax-driven land use impacts during the license renewal 31 term should consider (1) the size of the plant's payments relative to the community's total 32 revenues, (2) the nature of the community's existing land use pattern, and (3) the extent to 33 which the community already has public services in place to support and guide development. If 34 the plant's tax payments are projected to be small relative to the community's total revenue, tax-35 driven land use changes during the plant's license renewal term would be SMALL, especially 36 where the community has preestablished patterns of development and has provided adequate 37 public services to support and guide development. Section 4.7.2.1 of the GElS states that if tax 38 payments by the plant owner are less than 10 percent of the taxing jurisdiction's revenue, the 39 significance level would be SMALL. If the plant's tax payments are projected to be medium to 40 large relative to the community's total revenue, new tax-driven land use changes would be 41 MODERATE. If the plant's tax payments are projected to be a dominant source of the Draft NUREG-1437, Supplement 38 4-40 December 2008 OAG10001366_00249
Environmental Impacts of Operation 1 community's total revenue, new tax-driven land use changes would be LARGE. This would be 2 especially true where the community has no preestablished pattern of development or has not 3 provided adequate public services to support and guide development.
4 4.4.3.1 Population-Related Impacts 5 Since Entergy has indicated that it has no plans to add nonoutage employees during the license 6 renewal period, there would be no noticeable population change to drive changes in land use 7 conditions in the vicinity of IP2 and IP3 that is attributable to the plant. Therefore, there would 8 be no population-related land use impacts during the license renewal term beyond those 9 already being experienced.
10 As discussed in Section 4.4.1 of this SEIS, Entergy might replace the IP2 and IP3 reactor vessel 11 heads and CRDMs during the license renewal term (Entergy 2008b). Because of the short 12 amount of time needed for this replacement activity, the NRC staff finds that additional number 13 of refueling outage workers would not cause any permanent population-related land use 14 changes in the immediate vicinity of IP2 and IP3. These impacts are discussed in Chapter 3 of 15 this draft SEIS.
16 4.4.3.2 Tax-Revenue-Related Impacts 17 As discussed in Chapter 2 of this draft SEIS, Entergy pays annual real estate taxes to the Town 18 of Cortlandt, Hendrick Hudson Central School District, and the Village of Buchanan (see Table 19 2-18 in Chapter 2 for more detail). As reported in Chapter 2, tax payments to the Town of 20 Cortlandt represented between 11 and 16 percent of the town's total annual tax revenues for the 21 3-year period from 2003 through 2005, and payments to the Hendrick Hudson Central School 22 District represented approximately 30 to 38 percent of the school district's total revenues over 23 the same time period. Entergy's tax payments to the Village of Buchanan make up a high 24 percentage of the village's tax collection. For the period 2003 through 2005, tax payments to 25 the Village of Buchanan represented 39 to 43 percent of the village's total revenues.
26 The NRC staff notes that since Entergy started making payments to local jurisdictions, 27 population levels and land use conditions in the Town of Cortlandt, Village of Buchanan, and 28 Westchester County have not changed significantly, which might indicate that these tax 29 revenues have had little or no effect on land use activities within the county.
30 Entergy has indicated that it plans no license-renewal-related construction activities to support 31 the continued operation of IP2 and IP3 during the license renewal period. Accordingly, the NRC 32 staff expects that there would be no increase in the assessed value of IP2 and IP3 and that the 33 annual payment-in-lieu-of-taxes and property taxes paid to the Town of Cortlandt, the Hendrick 34 Hudson Central School District, and the Village of Buchanan would remain relatively unchanged 35 throughout the license renewal period. Based on this information, there would be no tax-36 revenue-related land use impacts during the license renewal term beyond those currently being 37 experienced.
38 As discussed in Section 4.4.1 of this draft SEIS, Entergy might replace the IP2 and IP3 reactor 39 vessel heads and CRDMs during the license renewal term (Entergy 2008b). This replacement 40 activity would not likely increase the assessed value of IP2 and IP3, and property tax payments 41 would remain unchanged. These impacts are discussed in Chapter 3 of this draft SEIS.
December 2008 4-41 Draft NUREG-1437, Supplement 38 OAG10001366_00250
Environmental Impacts of Operation 1 4.4.4 Public Services: Transportation Impacts during Operations 2 Table 8-1 of Appendix 8 to Subpart A of 10 CFR Part 51 states the following:
3 Transportation impacts (level of service) of highway traffic generated ... during the 4 term of the renewed license are generally expected to be of small significance.
5 However, the increase in traffic associated with additional workers and the local 6 road and traffic control conditions may lead to impacts of moderate or large 7 significance at some sites.
8 All applicants are required by 10 CFR 51.53(c)(3)(ii)(J) to assess the impacts of highway traffic 9 generated by the proposed project on the level of service of local highways during the term of 10 the renewed license.
11 Since Entergy has no plans to add nonoutage employees during the license renewal period, 12 there would be no noticeable change in traffic volume and levels of service on roadways in the 13 vicinity of IP2 and IP3. Therefore, there would be no transportation impacts during the license 14 renewal term beyond those already being experienced.
15 As discussed in Section 4.4.1 of this draft SEIS, Entergy might replace the IP2 and IP3 reactor 16 vessel heads and CRDMs during the license renewal term (Entergy 2008b). The additional 17 number of outage workers and truck material deliveries needed to support this replacement 18 activity could cause short-term transportation impacts on access roads in the immediate vicinity 19 of IP2 and IP3. These impacts are discussed in Chapter 3 of this draft SEIS.
20 4.4.5 Historic and Archeological Resources 21 The National Historic Preservation Act (NHPA), as amended, requires Federal agencies to 22 consider the effects of their undertakings on historic properties. Historic properties are defined 23 as resources that are eligible for listing on the National Register of Historic Places. The criteria 24 for eligibility are listed in 36 CFR 60.4, "Criteria for Evaluation," and include (1) association with 25 significant events in history, (2) association with the lives of persons significant in the past, 26 (3) embodies distinctive characteristics of type, period, or construction, and (4) yielded or is 27 likely to yield important information (ACHP 2008). The historic preservation review process 28 mandated by Section 106 of the NHPA is outlined in regulations issued by the Advisory Council 29 on Historic Preservation in 36 CFR Part 800, "Protection of Historic Properties." The issuance 30 of a renewed operating license for a nuclear power plant is a Federal action that could possibly 31 affect either known or currently undiscovered historic properties located on or near the plant site 32 and its associated transmission lines. In accordance with the provisions of the NHPA, the NRC 33 is required to make a reasonable effort to identify historic properties in the areas of potential 34 effect. If no historic properties are present or affected, the NRC is required to notify the State 35 Historic Preservation Office before proceeding. If it is determined that historic properties are 36 present, the NRC is required to assess and resolve possible adverse effects of the undertaking.
37 4.4.5.1 Site-Specific Cultural Resources Information 38 A review of the New York State Historic Preservation Office (NYSHPO) files shows that there 39 are no previously recorded archeological or above-ground historic architectural resources 40 identified on the IP2 and IP3 property. As noted in Section 2.2.9.1 of this draft SEIS, a Draft NUREG-1437, Supplement 38 4-42 December 2008 OAG10001366_00251
Environmental Impacts of Operation 1 Phase 1A survey (literature review and background research) of the plant property was 2 conducted in 2006; however, no systematic pedestrian or subsurface archeological surveys 3 have been conducted at the IP2 and IP3 site. Background research revealed a total of 76 4 resources listed on the National Register of Historic Places within a 5-mile radius of IP2 and 5 IP3; however, none are located within the boundaries of the property.
6 There is potential for archeological resources to be present on some portions of the IP2 and IP3 7 property. As noted in Section 2.2.9.2 of this draft SEIS, because of disturbances associated 8 with site preparation and construction, the power block area at IP2 and IP3 has little or no 9 potential for archeological resources. There is potential for archeological resources to be 10 present in the wooded area northeast of the power block area. A portion of the property south 11 and east of the power block area, which contains a variety of ancillary plant facilities, has been 12 disturbed by construction activities over the course of the plant's history. It is possible, however, 13 that portions of that area not disturbed by construction activities may contain intact subsurface 14 archeological deposits. In addition, the IP1 reactor was one of three "demonstration plants" that 15 began operation in the early 1960s. It is representative of the earliest era of commercial 16 reactors to operate in the United States. To date, no formal significance or eligibility evaluation 17 has been conducted for IP1; however, the plant could become eligible for inclusion on the 18 National Register of Historic Places. As mandated by Section 106 of the NHPA, an evaluation 19 would be conducted if it was determined that a project could affect IP1.
20 4.4.5.2 Conclusions 21 Entergy has proposed no specific new facilities, service roads, or transmission lines for the IP2 22 and IP3 site associated with continued operation and refurbishment. However, Entergy 23 indicated that it may replace the IP2 and IP3 reactor vessel heads and CRDMs during the 24 license renewal period. This activity would involve ground-disturbing activities associated with 25 the construction of a storage building for the existing reactor vessel heads and CRDMs.
26 Ground-disturbing activities would be reviewed in accordance with Entergy nuclear fleet 27 procedures, which are designed to ensure that investigations and consultations are conducted 28 as needed, and that existing or potentially existing cultural resources are adequately protected 29 by Entergy such that the applicant can meet State and Federal expectations (Enercon 2007).
30 Therefore, the potential for impacts from continued operation of IP2 and IP3 on historic or 31 archeological resources eligible for the National Register is SMALL. However, as noted in the 32 NRC staff walkover survey discussed in Chapter 2 of this draft SEIS, there is the potential for 33 prehistoric and historic archeological resources to be present on the northeastern portion of the 34 site. Even though this area was previously disturbed by surface mining in the 19th century, the 35 potential for intact prehistoric/historic and archeological resources remains. In addition, Section 36 106 of NHPA requires that lands not previously surveyed in the vicinity of IP2 and IP3 would 37 require investigation by a professional archeologist in consultation with the NYSHPO before any 38 ground-disturbing activities. To mitigate any potential adverse impacts to historic and 39 archeological resources from continued plant operations in these areas, field surveys 40 (archeological investigations) and consultation under the NHPA should be conducted before any 41 ground-disturbing activities. Entergy procedures should be followed to mitigate any potential 42 adverse impacts to historic and archeological resources.
December 2008 4-43 Draft NUREG-1437, Supplement 38 OAG10001366_00252
Environmental Impacts of Operation 1 4.4.6 Environmental Justice 2 Under Executive Order 12898, "Federal Actions To Address Environmental Justice in Minority 3 Populations and Low-Income Populations" (Volume 59, page 7629 of the Federal Register 4 (59 FR 7629)), Federal agencies are responsible for identifying and addressing potential 5 disproportionately high and adverse human health and environmental impacts on minority and 6 low-income populations. In 2004, the Commission issued its "Policy Statement on the 7 Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions" 8 (69 FR 52040), which states, "The Commission is committed to the general goals set forth in 9 E.O. 12898, and strives to meet those goals as part of its NEPA review process."
10 The Council of Environmental Quality (CEQ) provides the following information in its publication 11 entitled, "Environmental Justice: Guidance under the National Environmental Policy Act" 12 (1997):
13
- Disproportionately High and Adverse Human Health Effects. Adverse health effects 14 are measured in risks and rates that could result in latent cancer fatalities, as well as 15 other fatal or nonfatal adverse impacts on human health. Adverse health effects may 16 include bodily impairment, infirmity, illness, or death. Disproportionately high and 17 adverse human health effects occur when the risk or rate of exposure to an 18 environmental hazard for a minority or low-income population is significant (as defined 19 by NEPA Act) and appreciably exceeds the risk or exposure rate for the general 20 population or for another appropriate comparison group (CEQ 1997).
21
- Disproportionately High and Adverse Environmental Effects. A disproportionately 22 high environmental impact that is significant (as defined by NEPA) refers to an impact or 23 risk of an impact on the natural or physical environment in a low-income or minority 24 community that appreciably exceeds the environmental impact on the larger community.
25 Such effects may include ecological, cultural, human health, economic, or social 26 impacts. An adverse environmental impact is an impact that is determined to be both 27 harmful and significant (as defined by NEPA). In assessing cultural and aesthetic 28 environmental impacts, impacts that uniquely affect geographically dislocated or 29 dispersed minority or low-income populations or American Indian tribes are considered 30 (CEQ 1997).
31 The environmental justice analysis assesses the potential for disproportionately high and 32 adverse human health or environmental effects on minority and low-income populations that 33 could result from the operation of IP2 and IP3 during the renewal term. In assessing the 34 impacts, the following CEQ (1997) definitions of minority individuals and populations and low-35 income population were used:
36 (1) Minority individuals. Individuals who identify themselves as members of the following 37 population groups: Hispanic or Latino, American Indian or Alaska Native, Asian, Black 38 or African American, Native Hawaiian or Other Pacific Islander, or two or more races 39 meaning individuals who identified themselves on a Census form as being a member of 40 two or more races, for example, Hispanic and Asian.
Draft NUREG-1437, Supplement 38 4-44 December 2008 OAG10001366_00253
Environmental Impacts of Operation 1 (2) Minority populations. Minority populations are identified when (1) the minority 2 population of an affected area exceeds 50 percent or (2) the minority population 3 percentage of the affected area is meaningfully greater than the minority population 4 percentage in the general population or other appropriate unit of geographic analysis.
5 (3) Low-income populations. Low-income populations in an affected area are identified 6 with the annual statistical poverty thresholds from the Census Bureau's Current 7 Population Reports, Series PB60, on Income and Poverty.
8 Minority Population in 2000 9 According to 2000 census data, 48.7 percent of the population (approximately 16,805,000 10 individuals) residing with a 50-mi (80-km) radius of IP2 and IP3 identified themselves as minority 11 individuals. The largest minority group was Black or African American (3,480,000 persons or 12 20.7 percent), followed by Hispanic or Latino of any race (3,439,000 or about 20.5 percent) 13 (USCB 2003-LandView 6). About 36 percent of the Westchester County population were 14 minorities, with Hispanic or Latino the largest minority group (15.6 percent) followed by Black or 15 African American (13.6 percent) (USCB 2008).
16 Census block groups with minority populations exceeding 50 percent were considered minority 17 block groups. Based on 2000 census data, Figure 4-5 of this draft SEIS shows minority block 18 groups within a 50-mi (80-km) radius of IP2 and IP3 in which more than 50 percent of the block 19 group population is minority.
20 Low-Income Population in 2000 21 According to 2000 census data, approximately 484,000 families (approximately 11.7 percent) 22 residing within a 50-mi (80-km) radius of the IP2 and IP3 were identified as living below the 23 Federal poverty threshold in 1999 (USCB 2003-LandView 6). The 1999 Federal poverty 24 threshold was $17,029 for a family of four.
25 According to census data, the median household income for New York in 2004 was $45,343, 26 while 14.5 percent of the State's population was determined to be living below the Federal 27 poverty threshold. Westchester County had a much higher median household income 28 ($63,924) and a lower percentage (8.9 percent) of individuals living below the poverty level 29 when compared to the State. Dutchess, Orange, and Putnam Counties also had much higher 30 median household incomes in 2004 ($56,971, $54,771, and $75,514, respectively) and lower 31 percentages (7.7 percent, 10.2 percent, and 4.5 percent, respectively) of individuals living below 32 the poverty level when compared to the State (USCB 2008).
33 Census block groups were considered low-income block groups if the percentage of the 34 population living below the Federal poverty threshold exceeded the State percentage of 35 14.5 percent. Based on 2000 census data, Figure 4-6 of this draft SEIS shows low-income 36 block groups within a 50-mi (80-km) radius of IP2 and IP3.
37 Analysis of Impacts 38 Consistent with the impact analysis for the public and occupational health and safety, the 39 affected populations are defined as minority and low-income populations residing within a 50-mi 40 radius of the IP2 and IP3. Based on the analysis of environmental health and safety impacts 41 presented in this draft SEIS for other resource areas (contained in Chapters 2 and 4 of this 42 SEIS), there would be no disproportionately high and adverse impacts to minority and low-December 2008 4-45 Draft NUREG-1437, Supplement 38 OAG10001366_00254
Environmental Impacts of Operation 1 income populations from continued operation of IP2 and IP3 during the license renewal period.
- ..: ...; ...*.. ;
Legend N
_
Indicates census block groups that meet the definition of a minority population Water Bodies D County Boundaries State Boundaries o 7.5
__
15 30
~r-"I~_iiiiiil-~Iiiiiiiiil~~~~~i'Mi1es j
Printing Date: ay 12, 2 8 File: M:\lnGIS Data\lndian Point\ArcView\Poverty.mxd 2
3 Figure 4-5. Minority block groups in 2000 within a 50-mi radius 4 of IP2 and IP3 (USCB 2008)
Draft NUREG-1437, Supplement 38 4-46 December 2008 OAG10001366_00255
Environmental Impacts of Operation
_Legend Indicat.es cens!Js block groups that meet tne definition of a poverty population County Boundaries o
Water Bodies D State Boundaries 7.5 15 30
__~~~~~i Miles
&"'I~5i_iiiiil-~!ii Printing Date: ay 12, 2008 File: M:\IT\GIS Data\lndian Point\ArcView\Poverty.mxd 1
2 Figure 4-6. Low-income block groups in 2000 within a 50-mi radius 3 of IP2 and IP3 (USCB 2008)
December 2008 4-47 Draft NUREG-1437, Supplement 38 OAG10001366_00256
Environmental Impacts of Operation 1 As discussed in Section 4.4.1, Entergy might replace the IP2 and IP3 reactor vessel heads and 2 CRDMs during the license renewal term (Entergy 2008b). Entergy estimates that this would 3 require an increase in the number of refueling outage workers for up to 60 days during two 4 separate refueling outages, one for each unit, 12 months apart (Entergy 2008b). This 5 replacement activity would have little noticeable affect on minority and/or low-income 6 populations in the region. These impacts are discussed in Chapter 3 of this draft SEIS.
7 The NRC also analyzed the risk of radiological exposure through the consumption patterns of 8 special pathway receptors, including subsistence consumption of fish, native vegetation, surface 9 waters, sediments, and local produce; absorption of contaminants in sediments through the 10 skin; and inhalation of plant materials. The special pathway receptors analysis is important to 11 the environmental justice analysis because consumption patterns may reflect the traditional or 12 cultural practices of minority and low-income populations in the area.
13 Subsistence Consumption of Fish and Wildlife 14 Section 4-4 of Executive Order 12898 (1994) directs Federal agencies, whenever practical and 15 appropriate, to collect and analyze information on the consumption patterns of populations who 16 rely principally on fish and/or wildlife for subsistence and to communicate the risks of these 17 consumption patterns to the public. In this draft SEIS, the NRC staff considered whether there 18 were any means for minority or low-income populations to be disproportionately affected by 19 examining impacts to American Indian, Hispanic, and other traditional lifestyle special pathway 20 receptors. Special pathways that took into account the levels of contaminants in native 21 vegetation, crops, soils and sediments, surface water, fish, and game animals on or near the 22 IP2 and IP3 site were considered.
23 Entergy has a comprehensive Radiological Environmental Monitoring Program (REMP) at IP2 24 and IP3 to assess the impact of site operations on the environment. Samples are collected from 25 the aquatic and terrestrial pathways in the vicinity of IP2 and IP3. The aquatic pathways include 26 fish, Hudson River water, ground water, aquatic vegetation, sediment, and shoreline soil. The 27 terrestrial pathways include airborne particulates, broad leaf vegetation, and direct radiation.
28 During 2006, Entergy or its contractors performed 1342 analyses on collected samples of 29 environmental media as part of the required REMP which showed no significant or measurable 30 radiological impact from IP2 and IP3 operations (ENN 2007).
31 The NRC staff presents a summary of results from the IP2 and IP3 REMP program in 32 Section 2.2.7 of this draft SEIS. The results of the 2006 REMP (the most recent available) 33 demonstrate that the routine operation at the IP2 and IP3 site has had no significant or 34 measurable radiological impact on the environment. No elevated radiation levels were detected 35 in the offsite environment as a result of plant operations and the storage of radioactive waste.
36 The results of the REMP continue to demonstrate that the operation of IP2 and IP3 did not 37 result in a significant measurable dose to a member of the general population or adversely 38 impact the environment as a result of radiological effluents. The REMP continues to 39 demonstrate that the dose to a member of the public from the operation of IP2 and IP3 remains 40 significantly below the Federally required dose limits specified in 10 CFR Part 20 and 40 CFR 41 Part 190, "Environmental Radiation Protection Standards for Nuclear Power Operations."
42 The NRC staff's review of recent REMP monitoring results shows that concentrations of 43 contaminants in native leafy vegetation, soils and sediments, surface water, and fish in areas 44 surrounding IP2 and IP3 have been quite low (at or near the threshold of detection) and seldom Draft NUREG-1437, Supplement 38 4-48 December 2008 OAG10001366_00257
Environmental Impacts of Operation 1 above background levels. Consequently, the NRC staff concludes that no disproportionately 2 high and adverse human health impacts would be expected in special pathway receptor 3 populations in the region as a result of subsistence consumption of fish and wildlife.
4 4.5 Ground Water Use and Quality 5 No Category 1 or Category 2 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, are 6 potentially applicable to IP2 and IP3 ground water use and quality during the renewal term. The 7 applicant stated in its ER that IP2 and IP3 do not use any ground water, though onsite 8 monitoring wells exist for the purpose of monitoring ground water conditions.
9 In the IP2 and IP3 ER, Entergy identified leakage from onsite spent fuel pools as potentially new 10 and significant information (Entergy 2007a). The NRC staff has reviewed Entergy's analysis of 11 the leakage and has conducted an extensive onsite inspection of leakage to ground water, as 12 identified in Section 2.2.7 of this draft SEIS. Based on the NRC staff's review of Entergy's 13 analysis, the NRC staff's adoption of the NRC inspection report findings in this SEIS, and 14 Entergy's subsequent statements (all discussed in Section 2.2.7), the NRC staff concludes that 15 the abnormal liquid releases discussed by Entergy in its ER, while new information, are within 16 the NRC's radiation safety standards contained in 10 CFR Part 20 and are not considered to 17 have a significant impact on plant workers, the public, or the environment (i.e., while the 18 information related to spent fuel pool leakage is new, it is not significant).
19 4.6 Threatened or Endangered Species 20 Potential impacts to threatened or endangered species are listed as a Category 2 issue in 21 10 CFR Part 51, Subpart A, Appendix B, Table B-1. This issue is listed in Table 4-10.
22 Table 4-10. Category 2 Issues Applicable to Threatened or Endangered Species during 23 the Renewal Term ISSUE-10 CFR Part 51, Subpart A, GElS 10 CFR 51.53(c)(3)(ii) Draft SEIS Appendix B, Table B-1 Section Subparagraph Section THREATENED OR ENDANGERED SPECIES (FOR ALL PLANTS)
Threatened or Endangered Species 4.1 E 4.6 24 This issue requires consultation under Section 7 of the Endangered Species Act of 1973 (ESA 25 1973) with appropriate agencies to determine whether threatened or endangered species are 26 present and whether they would be adversely affected by continued operation of the nuclear 27 facility during the license renewal term. The presence of threatened or endangered species in 28 the vicinity of the IP2 and IP3 site is discussed in Sections 2.2.5.5 and 2.2.6.2 of this draft SEIS.
29 In 2007, the NRC staff contacted NMFS and the U.S. Fish and Wildlife Service (FWS) to 30 request information on the occurrence of threatened or endangered species in the vicinity of the 31 site and the potential for impacts on those species from license renewal. NMFS identified in its 32 response two Federally protected sturgeon species under its jurisdiction as having the potential 33 to be affected by the proposed action (NMFS 2007a). FWS provided a link to the Web site of its 34 New York Field Office, where lists of species occurrences were available by county (FWS December 2008 4-49 Draft NUREG-1437, Supplement 38 OAG10001366_00258
Environmental Impacts of Operation 1 2007). Three terrestrial species with a Federal listing status were identified as potentially 2 occurring at or near the site-the Indiana bat (Myotis soda/is), bog turtle (C/emmys 3 muhlenbergil), and New England cottontail (Sylvi/agus transitiona/is).
4 Because the NRC recognizes that there is the potential that the continued operation of IP2 and 5 IP3 could adversely affect the Federally listed species shortnose sturgeon (Acipenser 6 brevirostrum), the NRC staff has prepared a biological assessment (BA) for NMFS that 7 documents its review. The BA is provided in Appendix E to this draft SEIS. During informal 8 consultation regarding the potential for effects on terrestrial threatened or endangered species, 9 FWS determined that a BA was not needed because there was no likelihood of adverse effects 10 on potentially occurring species under its jurisdiction (NRC 2008).
11 4.6.1 Aquatic Threatened or Endangered Species 12 Pursuant to Section 7 of the Endangered Species Act of 1973 (ESA 1973), the NRC staff 13 requested in a letter dated August 16,2007 (NRC 2007a), that NMFS provide information on 14 Federally listed endangered or threatened species, as well as proposed candidate species. In 15 its response on October 4,2007 (NMFS 2007b), NMFS expressed concern that the continued 16 operation of IP2 and IP3 could have an adverse impact on the shortnose sturgeon, an 17 endangered species that occurs in the Hudson River. NMFS also noted that the Atlantic 18 sturgeon (A. oxyrinchus) also occurs in the river and is currently a candidate for listing as 19 threatened or endangered. The NRC staff also reviewed the list of threatened and endangered 20 fish species available at the NYSDEC Web site (NYSDEC 2008a) and determined that the only 21 listed species occurring in the Hudson River near the IP2 and IP3 facility was the shortnose 22 sturgeon. Based on this information, the NRC staff determined that an analysis of impacts was 23 required only for the shortnose sturgeon. The NRC staff has, however, included an assessment 24 of impact for the Atlantic sturgeon in this section, given its current status as a candidate for 25 listing.
26 As described in Section 2.2.5.5 of this draft SEIS, the shortnose sturgeon is amphidromous, 27 with a range extending from St. Johns River, Florida, to St. John River, Canada. Unlike 28 anadromous species, shortnose sturgeons spend the majority of their lives in freshwater and 29 move to salt water periodically, independent of spawning periods (Collette and Klein-MacPhee 30 2002). The shortnose sturgeon was listed on March 11, 1967, as endangered under the 31 Endangered Species Act of 1973, as amended. In 1998, a recovery plan for the shortnose 32 sturgeon was finalized by NMFS (NMFS 1998).
33 Shortnose sturgeon are found in the lower Hudson River and are dispersed throughout the river-34 estuary from late spring to early fall, congregating to winter near Sturgeon Point (RKM 139; RM 35 86). The population of shortnose sturgeon in the Hudson River has increased 400 percent 36 since the 1970s, according to Cornell University researchers (Bain et al. 2007). Woodland and 37 Secor (2007) estimate a fourfold increase in sturgeon abundance over the past 3 decades, but 38 report that the population growth slowed in the late 1990s as evidenced by the nearly constant 39 recruitment pattern at depressed levels relative to the classes in 1986-1992. Although the 40 Hudson River appears to support the largest population of shortnose sturgeon in the region, 41 Bain et al. (2007) report that other populations along the Atlantic coast are also increasing and 42 some appear to be nearing safe levels, suggesting that the overall population could recover if 43 full protection and management continue.
Draft NUREG-1437, Supplement 38 4-50 December 2008 OAG10001366_00259
Environmental Impacts of Operation 1 As described in Section 2.2.5.5 of this draft SEIS, the Atlantic sturgeon is an anadromous 2 species with a range extending from St. Johns River, Florida, to Labrador, Canada. This 3 species is long lived, matures slowly, and can reach 60 years of age (ASMFC 2007; Gilbert 4 1989). In 1996, the State of New York placed a moratorium on harvesting Atlantic sturgeon 5 when it became apparent that the Hudson River stock was overfished. Unfortunately, the 6 American shad gill net fishery continues to take subadult sturgeon as by catch (e.g., the 7 unintentional collection of some species during the harvest or others). The Status Review Team 8 for Atlantic Sturgeon concluded in 2007 that the Hudson River subpopulation has a moderate 9 risk (less than 50 percent) of becoming endangered in the next 20 years because of the threat 10 of commercial bycatch. However, the New York Bight distinct population segment, which 11 includes the Hudson River subpopulation, was determined to have a greater than 50-percent 12 chance of becoming endangered in the foreseeable future. Despite this, the Hudson River 13 supports the largest subpopulation of spawning adults and juveniles, and the abundance 14 appears to be stable or even increasing (ASSRT 2007). Recent work by Sweka et al. (2007) 15 suggests that a substantial population of juvenile Atlantic sturgeon is present in Haverstraw Bay, 16 and that this area should be the focus of future monitoring studies to obtain the greatest 17 statistical power for assessing population trends.
18 To determine the potential adverse impacts of the IP2 and IP3 cooling system on these species, 19 the NRC staff evaluated the potential effects of entrainment, impingement, and thermal 20 discharges for all RIS, including both sturgeon species, in Sections 4.1.1, 4.1.2, and 4.1.3 of this 21 draft SEIS. Based on an evaluation of entrainment data provided by the applicant, there is no 22 evidence that the eggs or larvae of either species are commonly entrained at IP2 or IP3. The 23 potential impacts of thermal discharges on shortnose and Atlantic sturgeon cannot be 24 determined at this time because additional studies are required to quantify the extent and 25 magnitude of the thermal plume, as discussed in Section 4.1.4 of this draft SEIS.
26 Impingement data provided by the applicant (Entergy 2007b) suggest that both species of 27 sturgeon have been impinged at IP2 and IP3, with impingement of Atlantic sturgeon accounting 28 for the largest losses (Table 4-11). Impingement data for the endangered shortnose sturgeon 29 show that from 1975 to 1990, 317 fish were impinged at IP2 and 407 fish were impinged at IP3.
30 Impingement of this species was greatest in 1984 and 1988, and no impinged fish were 31 observed at either unit in 1981, 1982, 1983, 1985, and 1986 (Table 4-11). Impingement of 32 Atlantic sturgeon was much greater than that observed for shortnose sturgeon, with 2667 fish 33 impinged at IP2 and 1268 fish impinged at IP3 between 1975 and 1988. The only year when 34 impingement of Atlantic sturgeon at both units was not observed (Table 4-11) was 1988.
35 Because recent data are not available, it is not possible to determine whether the current 36 impingement losses are similar to the past observations.
December 2008 4-51 Draft NUREG-1437, Supplement 38 OAG10001366_00260
Environmental Impacts of Operation 1 Table 4-11. Impingement Data for Shortnose and Atlantic Sturgeon at IP2 and IP3, 2 1975-1990 (data from Entergy 2007b)
IP2 IP3 Study IP2 IP3 Grand Year Shortnose Atlantic Total Shortnose Atlantic Total Total Sturgeon Sturgeon Sturgeon Sturgeon a
1975 3 302 305 305 1976 2 17 19 14 14 33 1977 11 105 116 2 252 254 370 1978 5 38 43 5 31 36 79 1979 4 75 79 3 61 64 143 1980 24 24 2 17 18 42 1981 221 221 73 73 294 1982 217 217 127 127 344 1983 149 149 149 1984 176 363 539 154 179 333 872 1985 460 460 300 300 760 1986 696 696 126 126 822 1987 116 116 55 88 143 259 1988 186 186 186 1989 1990 Grand 317 2667 2984 407 1268 1674 4658 Total (a) _ = not indicated in sample 3 The NRC staff reviewed information from the site audit, Entergy's ER for the IP2 and IP3 site, 4 other reports, and information from NMFS. Because of the uncertainty of the current 5 impingement losses of both species of sturgeon and because insufficient data exist to use the 6 WOE approach used earlier in Chapter 4 to address impacts to RIS, operation of IP2 and IP3 7 has the potential to adversely affect the Atlantic and shortnose sturgeons during the license 8 renewal term. Therefore, the NRC staff concludes that the impacts of an additional 20 years 9 (beyond the current term) of operation and maintenance of the site, including associated 10 transmission line ROWs, on aquatic species that are Federally listed as threatened or 11 endangered could be SMALL to LARGE. However, if monitoring were to be reinstated at IP2 12 and IP3, the range of impact levels from continued operation could possibly be refined.
13 The NRC staff has included a biological assessment of the impacts of license renewal on the 14 shortnose sturgeon in Appendix E to this draft SEIS for NMFS to review. Should NMFS 15 determine that there is a potential that the continued operation of IP2 and IP3 will adversely 16 impact the shortnose sturgeon, NMFS will issue a biological opinion. Included in the biological 17 opinion would be any reasonable and prudent measures that the applicant could undertake, as 18 well as the terms and conditions for the applicant to comply with the formal Section 7 19 consultation. Possible mitigation measures could range from monitoring to determine the 20 number of shortnose sturgeon impinged at IP2 and IP3 to changes in the cooling water intake Draft NUREG-1437, Supplement 38 4-52 December 2008 OAG10001366_00261
Environmental Impacts of Operation 1 system, as described in Section 4.1.5 of this draft SEIS. Additionally, as described in Chapter 8, 2 the installation of cooling towers could reduce impingement, entrainment, and thermal impacts 3 for all aquatic resources, including those that are Federally listed.
4 4.6.2 Terrestrial Threatened or Endangered Species 5 There are two Federally listed terrestrial species that have the potential to occur at or near the 6 IP2 and IP3 site and its associated transmission line ROWs, the endangered Indiana bat 7 (M. soda/is) and the threatened bog turtle (C. muhlenbergil). A candidate species, the New 8 England cottontail (S. transitiona/is), also may occur in the vicinity. The characteristics, habitat 9 requirements, and likelihood of occurrence of each of these species are discussed in 10 Section 2.2.6.2 of this draft SEIS.
11 Although Westchester County is within the potential range of the Indiana bat in New York, winter 12 hibernacula and summer maternity colonies and bachelor colonies are not known to be present 13 in the county or the vicinity of the site (NYNHP 2008a). The NRC staff notes that it is possible 14 that the 70-acre (ac) (28-hectare (ha)) forest at the north end of the site could provide summer 15 habitat for the Indiana bat because of the presence of suitable foraging habitat and possible 16 roosting trees in the forest and the presence of large hibernacula within migration distance of 17 the site. The ER indicated that no expansion of existing facilities or disturbance of forest or 18 other land on the site would occur during the renewal period. Thus, even if Indiana bats 19 currently utilize habitat on the site, it is not likely that they would be adversely affected by 20 ongoing operations and maintenance activities during the renewal period.
21 In Section 2.2.6.2, the NRC staff noted that the IP2 and IP3 site area does not have suitable 22 habitat for the bog turtle, and that bog turtles have not been observed in the region of 23 Westchester County near the IP2 and IP3 site (NYSDEC 2008b). The NRC staff acknowledged 24 that wetlands nearest the site had not, however, been evaluated for the presence of the bog 25 turtle. Given the available information, the NRC staff concludes that the bog turtle is not likely to 26 occur on or in the immediate vicinity of the site. The known locations of the New England 27 cottontail in Westchester County are in the central and northeastern areas of the county 28 (NYNHP 2008b), not in the northwestern area where the site is located. The forests on the site 29 consist mainly of mature hardwoods and do not contain early successional habitats, such as 30 thickets, that are required by the New England cottontail, so the NRC staff does not expect the 31 species to occur on or in the immediate vicinity of the site.
32 The NRC staff reviewed information from the site audit, Entergy's ER for the IP2 and IP3 site, 33 other reports, and information from FWS. Operation of IP2 and IP3 is not expected to adversely 34 affect any threatened or endangered terrestrial species during the license renewal term.
35 Therefore, the NRC staff concludes that the impacts of an additional 20 years of operation and 36 maintenance of the site, including associated transmission line ROWs, on terrestrial species 37 that are Federally listed as threatened or endangered would be SMALL. Because no listed 38 species are known to be present in the area of the IP2 and IP3 site, there are no recommended 39 mitigation measures, unless the applicant becomes aware of the presence of a listed species, in 40 which case appropriate protective action should be taken, and the NRC and FWS should be 41 notified. Informal consultation with FWS indicated that formal consultation and a BA are not 42 required for terrestrial threatened or endangered species.
December 2008 4-53 Draft NUREG-1437, Supplement 38 OAG10001366_00262
Environmental Impacts of Operation 1 4.7 Evaluation of New and Potentially Significant Information on 2 Impacts of Operations during the Renewal Term 3 The NRC staff has conducted its own independent review of environmental issues through staff 4 research, consultation with State and Federal agencies, and comments delivered to the NRC by 5 the public during the environmental scoping period to identify potentially new and significant 6 information about environmental issues listed in 10 CFR Part 51, Subpart A, Appendix B, 7 Table B-1, related to operation of IP2 and IP3 during the renewal term. Processes for 8 identification and evaluation of new information are described in Section 1.2.2 of this draft SEIS.
9 As discussed in Section 2.2.7 of this draft SEIS and synopsized in Section 4.5 of this chapter, 10 Entergy identified leakage from onsite spent fuel pools as potentially new information (Entergy 11 2007a). The NRC staff has reviewed Entergy's analysis of the leakage and has conducted an 12 extensive onsite inspection of leakage to ground water, as identified in Section 2.2.7 of this draft 13 SEIS. Based on the NRC staff's review of Entergy's ground water analyses, the NRC ground 14 water inspection report, and Entergy's subsequent statements (all discussed in Section 2.2.7 of 15 this draft SEIS), the NRC staff concludes that the abnormal liquid releases discussed by 16 Entergy in its ER, while constituting new information, are within the NRC's radiation safety 17 standards contained in 10 CFR Part 20 and are not considered to have a significant impact on 18 plant workers, the public, or the environment (i.e., while the information related to spent fuel 19 pool leakage is new, it is not significant).
20 The NRC staff did not identify any other information that was both new and significant. As such, 21 the NRC staff adopts the GElS findings for Category I issues applicable to Indian Point, as 22 described in the previous sections of this chapter.
23 4.8 Cumulative Impacts 24 The NRC staff considered potential cumulative impacts on the environment resulting from past, 25 present, and reasonably foreseeable future actions. The geographical area over which past, 26 present, and future actions are assessed is dependent on the affected resource.
27 The impacts of the proposed action, license renewal, as described in previous sections of 28 Chapter 4 of this draft SEIS, are combined with other past, present, and reasonably foreseeable 29 future actions in the potentially affected area regardless of which agency (Federal or non-30 Federal) or entity is undertaking the actions. The combined impacts are defined as "cumulative" 31 in 40 CFR 1508.7, "Cumulative Impact," and include individually minor but collectively significant 32 actions taking place over a period of time (CEQ 1997). It is possible that an impact that may be 33 SMALL by itself could result in a MODERATE or LARGE impact when considered in 34 combination with the impacts of other actions on the affected resource. Likewise, if a resource 35 is regionally declining or imperiled, even a SMALL direct or indirect impact could be important if 36 it contributes to or accelerates the overall resource decline.
37 The NRC staff has identified the principal past, present, and reasonably foreseeable future 38 actions potentially impacting the environment affected by IP2 and IP3. The potential cumulative 39 impacts of these actions are discussed below.
Draft NUREG-1437, Supplement 38 4-54 December 2008 OAG10001366_00263
Environmental Impacts of Operation 1 4.8.1 Cumulative Impacts on Aquatic Resources 2 The purpose of this section is to address past, present, and future actions that have created or 3 could result in cumulative adverse impacts to the aquatic resources of the lower Hudson River.
4 In Section 2.2.5.2 of this SEIS, the NRC staff discussed a wide variety of historical events that 5 have affected the Hudson River and its resources. The NRC staff notes that these historical 6 events are contributors to the cumulative effects on the Hudson River. In addition to the past 7 events in Section 2.2.5.2, the NRC staff has identified a variety of current and likely future 8 stressors that may also contribute to cumulative impacts. These stressors, included in the 9 follow list, is consistent with those identified by the Pew Oceans Commission (2003).
10
- the continued operation of the IP2 and IP3 once-through cooling system (addressed in 11 Section 4.1 of this Chapter) 12
- continued withdrawal of water to support fossil fuel electrical generation or water for 13 human use 14
- the presence of invasive or nuisance species 15
- fishing pressure 16
- habitat loss 17
- changes to water and sediment quality 18
- climate change 19 Each of these potential stressors may influence the structure and function of freshwater, 20 estuarine, and marine food webs and result in observable changes to the aquatic resources in 21 the lower Hudson River estuary. Examples of measurable changes to aquatic resources could 22 include the following:
23
- reductions or increases in RIS populations or changes in their distribution 24
- changes in predator-prey relationships or noticeable alterations to food webs, including 25 the permanent loss of species 26
- changes in contaminant body-burdens in fish and shellfish that result in the imposition or 27 lifting of consumption advisories 28
- introduction of exotic or nuisance species and increases or decreases in populations of 29 existing invasive species 30 What follows is a brief discussion of how the stressors listed above might have cumulative 31 impacts on aquatic resources of the lower Hudson River estuary. An expanded discussion of 32 cumulative impacts is presented in Appendix H to this draft SEIS. Because in most cases it is 33 not possible to quantitatively determine the impact of each stressor, or a collection of stressors, 34 on the aquatic resources of the lower Hudson River, the following is a general discussion of 35 cumulative impacts.
December 2008 4-55 Draft NUREG-1437, Supplement 38 OAG10001366_00264
Environmental Impacts of Operation 1 Continued Operation of the IP2 and IP3 Once-Through Cooling System 2 Based on the assessment presented in Sections 4.1.3 and 4.1.4 of this draft SEIS, the NRC 3 staff concludes that the operation of IP2 and IP3 has the potential to adversely affect a variety of 4 RIS species that currently exist in the Hudson River between Troy Dam and the Battery. Based 5 on the staff's analysis of entrainment and impingement impacts, effects to RIS range from 6 SMALL to LARGE, depending on the species affected. It is also possible that the operation of 7 IP2 and IP3 could be affecting the endangered shortnose sturgeon. If the IP2 and IP3 once-8 through cooling system continues to operate as it has for the past 3 decades, the NRC staff 9 finds that it will continue to contribute to cumulative effects.
10 Continued Water Withdrawals 11 As described in Section 2.2.5 of this draft SEIS, water is withdrawn from the Hudson River to 12 support fossil fuel electrical generation and to provide a source of drinking water. Although 13 some fossil fuel electrical generating stations that use natural gas or oil operate only 14 intermittently, coal-fired electrical generation stations that employ once-through cooling systems 15 are expected to continue to operate in the future. Likewise, water withdrawals in the freshwater 16 portions of the Hudson River will continue to occur and increase in the future. Because the 17 NRC staff concludes that water withdrawals from the Hudson River to support human needs will 18 continue and will likely increase during the relicensing term, this stressor will continue to 19 contribute to the cumulative effects in the river.
20 Invasive and Nuisance Species 21 As discussed in Section 2.2.5 of this draft SEIS, the presence of invasive or nuisance species in 22 the Hudson River estuary has been documented for over 200 years. While the presence of new 23 or exotic species can benefit some existing species, introductions of new species often have a 24 negative impact on their new environment. A classic example of the latter is the appearance of 25 the zebra mussel in the freshwater portion of the Hudson River in 1991. Since 1992, zebra 26 mussels have been a dominant species in the freshwater tidal portion of the Hudson River and 27 constitute more than half of heterotrophic biomass. Strayer (2007) estimated that the current 28 population is capable of filtering a volume of water equal to all of the water in the estuary every 29 1 to 4 days during the summer.
30 Some evidence suggests that the presence of zebra mussels can affect the species 31 composition and abundance of some Hudson River RIS. Strayer et al. (2004) hypothesized that 32 the abundance or growth rates of American shad, blueback herring, alewife, gizzard shad, white 33 perch, and striped bass would decline following the zebra mussel invasion or that their 34 distributions within the river would shift downriver away from the zone of greatest zebra mussel 35 impacts. The authors found that significant decreases in early lifestages of the estimated 36 riverwide abundance of several species of fish coincided with the zebra mussel invasion, 37 including American shad and white perch. Barnthouse et al. (2008) also concluded that zebra 38 mussels may have contributed to declines in white perch, but rejected the hypothesis that zebra 39 mussels were affecting American shad. Independent analyses by the staff suggested that the 40 presence of zebra mussels resulted in a MODERATE to LARGE potential for adverse impacts 41 to the American shad, blueback herring, spottail shiner, and white perch (see Appendices Hand 42 I to this draft SEIS). The presence of invasive or nuisance species in the lower Hudson River 43 will continue to be a concern, as it is in other locations throughout the world, and the presence 44 of these species will continue to represent an important source of cumulative impacts to the Draft NUREG-1437, Supplement 38 4-56 December 2008 OAG10001366_00265
Environmental Impacts of Operation 1 river.
2 Fishing Pressure 3 Many RIS are commercially or recreationally important, and are thus subject to effects from 4 fishing pressure. In many cases, the commercial or recreational catches of RIS are regulated 5 by Federal or State agencies or entities, but losses of some RIS continue to occur as the result 6 of bycatch. The extent and magnitude of fishing pressure and its relationship to overall 7 cumulative impacts to the aquatic resources of the lower Hudson River is difficult to determine 8 because of the large geographic scale and the natural variation that exists in the system.
9 Recent work by Barnthouse et al. (2008) has suggested that fishing pressure is contributing to 10 the decline of some RIS in the lower Hudson River, but this could not be confirmed by the staff.
11 The staff does acknowledge that fishing pressure (or the lack of it due to catch restrictions) has 12 the potential to influence the freshwater, estuarine, and marine food webs present in the lower 13 Hudson River and may contribute to cumulative impacts in the future.
14 Habitat Loss 15 As described in Section 2.2.5 of this draft SEIS, alterations to terrestrial, wetland, nearshore, 16 and aquatic habitats have occurred in the Hudson River estuary since colonial times. During 17 the colonization of the region, upland habitat alterations profoundly influenced watershed 18 dynamics. The creation of dams and the filling or isolation of wetlands to support industrial 19 activities have dramatically changed patterns of nutrients and sediment loading to the estuary.
20 In addition, historic dredging activities altered aquatic environments and affected river flow 21 patterns, and future activities, as described in Section 2.2.10 of this draft SEIS, may continue to 22 influence the river. Finally, development along the shores of the Hudson has resulted in the 23 loss or isolation of nearshore habitat, and the armoring of the shoreline in the lower portions of 24 the river from Yonkers to the Battery has effectively eliminated nearshore habitat. The NRC 25 staff recognizes that Federal, State, and local agencies, as well as many NGOs, are interested 26 in restoring habitat lost during past development and notes that the identification of four 27 locations along the lower Hudson River estuary for inclusion in the National Estuarine Research 28 Reserve System in 1982 represents a important step in protecting and restoring important 29 habitats.
30 Because habitat loss remains a concern, the NRC staff concludes that this stressor will continue 31 to be an important contributor to cumulative impacts to the lower Hudson River.
32 Water and Sediment Quality 33 In general, there is evidence to conclude that the overall quality of water and sediment in the 34 lower Hudson River is improving. Cleanup of polychlorinated biphenyls in stretches of the river 35 above the Troy Dam continues, and upgrades to wastewater treatment facilities during the past 36 20 years have reduced the amount of untreated sewage discharged into the river and 37 contributed to reductions in nutrients and an apparent increase in dissolved oxygen. Chemical 38 contaminants continue to persist in the tissues of fish and invertebrates inhabiting the lower 39 Hudson River, and the presence of nonpoint discharges of chemicals and constituents 40 continues to be a concern of local, State, and Federal regulatory agencies and NGOs. The 41 NRC staff concludes that the quality of water and sediment in the lower Hudson River will 42 continue to be a concern and a potential contributor to cumulative impacts.
December 2008 4-57 Draft NUREG-1437, Supplement 38 OAG10001366_00266
Environmental Impacts of Operation 1 Climate Change 2 The potential cumulative effects of climate change on the Hudson River watershed, whether 3 from natural cycles or related to anthropogenic activities, could result in a variety of changes 4 that would affect aquatic resources. The environmental factors of significance identified by 5 Kennedy (1990) that could affect estuarine systems included sea level rise, temperature 6 increase, salinity changes, and wind and water circulation changes. Changes in sea level could 7 result in dramatic effects to nearshore communities, including the reduction or redistribution of 8 submerged aquatic vegetation, changes to marsh communities, and influences to wetland areas 9 adjacent to nearshore systems. Water temperature increases could affect spawning patterns or 10 success, or influence the distribution of key RIS when cold-water species move northward while 11 warm-water species become established in new habitats. Changes to river salinity and the 12 presence of the salt front could influence the spawning and distribution of RIS and the range of 13 exotic or nuisance species. Fundamental changes in precipitation could profoundly influence 14 water circulation and change the nature of sediment and nutrient inputs to the system. This 15 could result in changes to primary production and influence the estuarine food web on many 16 levels. Kennedy (1990) also concluded that some fisheries and aquaculture enterprises might 17 benefit from climate change, while others would suffer extensive economic losses.
18 The extent and magnitude of climate change impacts to the aquatic resources of the lower 19 Hudson River are an important component of the cumulative assessment analyses and could be 20 substantial.
21 Final Assessment of Cumulative Impacts on Aguatic Resources 22 Based on the NRC staff review, it is clear that Hudson River RIS are affected (some to a lesser 23 degree than others) by multiple stressors. The NRC staff's analysis (Appendix H) demonstrated 24 that the food web and abundance of RIS were noticeably altered, and many RIS appeared to be 25 directly influenced by the operation of the IP2 and IP3 cooling system (e.g., HIGH strength of 26 connection). The impacts of some of the stressors may be addressed by management actions 27 (e.g., IP2 and IP3 cooling system operation, fishing pressure, and water quality) and some 28 cannot (e.g., long-term impacts associated with climate change). Although the impacts 29 associated with increased human populations and associated development of the Hudson River 30 basin, climate change, redistribution of resources, and the presence of invasive species and 31 disease cannot be quantitatively calculated, the cumulative impacts on aquatic resources have 32 had destabilizing effects on Hudson River living resources, including threatened and 33 endangered species (i.e., the net effect of all stressors destabilized some populations) and are 34 considered by the NRC staff to be LARGE.
35 4.8.2 Cumulative Impacts on Terrestrial Resources 36 This section addresses past, present, and future actions that could result in cumulative adverse 37 impacts on terrestrial resources, including wildlife populations, vegetation communities of 38 uplands and riparian zones, wetlands, and land use. For purposes of this analysis, the 39 geographic area considered consists of the IP2 and IP3 site, which encompasses its associated 40 transmission line ROWs, and the surrounding region of the lower Hudson Valley.
41 The changes in land use associated with historical settlement and development of this region 42 are described in Section 2.2.5.2 of this draft SEIS. During precolonial and colonial settlement Draft NUREG-1437, Supplement 38 4-58 December 2008 OAG10001366_00267
Environmental Impacts of Operation 1 by European immigrants, large areas of the forest that had almost completely covered the 2 region were cleared for agriculture, and by 1880, 68 percent of the Hudson River watershed had 3 become farmland. Also in the 19th century, major changes in land use occurred in the region in 4 conjunction with the industrial revolution as human populations grew and houses, roads, 5 railroads, bridges, and industrial facilities were constructed. These historical trends of 6 increasing development and decreasing terrestrial habitat in the region continued through the 7 20th century to the present, resulting in large reductions in native forests and other habitats for 8 terrestrial wildlife, increases in precipitation runoff due to impervious surfaces, and pollution 9 (Swaney et al. 2006).
10 Before the historical clearing of land at the IP2 and IP3 site, the terrestrial communities of the 11 area consisted mainly of upland and riparian forests (NRC 1975). The site was originally 12 purchased in 1683 by a Dutch settler, who established a homestead there. By the latter 19th 13 century, the north end of Indian Point was being surface mined for iron, and a lime kiln and blast 14 furnace were located at the shoreline. By 1900 a brickyard existed on the site, and farming still 15 occurred there. In 1920 an amusement park was built on the site. The park closed in 1956, and 16 construction of the first commercial nuclear reactor in the United States then began at the site 17 (Enercon 2007). Thus, the site had been largely cleared of forest and developed for various 18 uses for well over a century before its development for power generation began in the second 19 half of the 20th century. Power plant development resulted in over half of the site (134 ac 20 (54.2 ha)) being covered by facilities and pavement, with forest having regenerated at the north 21 end of the site where mining occurred historically. Remaining native forest habitat in central and 22 southern portions of the site has been fragmented by roads, ROWs, parking areas, and other 23 development, a phenomenon that has commonly occurred in the region.
24 Developed areas with impervious surfaces have increased precipitation runoff and reduced 25 infiltration into the soil, thus reducing ground water recharge, altering streamflow, and increasing 26 soil erosion. Maintenance of vegetation in ROWs and other developed areas, such as by 27 mowing and spraying of herbicides, has altered the ecological communities in these areas by 28 preventing natural succession. It also likely has resulted in increases in invasive species, such 29 as Japanese knotweed (Fal/opia japonica), which typically are more aggressive than native 30 species in colonizing disturbed areas; increases in species that prefer edge habitat; and 31 decreases in species that prefer interior forest habitat. Such effects from development within 32 the IP2 and IP3 site contribute to cumulative impacts from similar effects on native ecological 33 communities from other development in the region.
34 Land use data provide an indication of the impacts on terrestrial resources that have resulted 35 from historical and ongoing development. Current land uses in the region are discussed by 36 county in Section 2.2.8.3 of this draft SEIS. In Westchester County, based on 1992 data, forest 37 was the predominant type of land cover (53 percent), followed by residential (30 percent),
38 agricultural and recreational (7 percent), and commercial/industrial/transportation uses 39 (3 percent) (Entergy 2007a). In four nearby counties in the lower Hudson Valley (Rockland, 40 Orange, Putnam, and Dutchess), forest also was the predominant type of land cover, followed 41 by residential or agricultural, and commercial/industrial/transportation land uses ranged from 42 about 1 to 4 percent (Entergy 2007a). Thus, commercial, industrial, and transportation facilities, 43 including the IP2 and IP3 site, have had a relatively small impact on the loss of native terrestrial 44 forest habitats in the region compared to residential and agricultural development. The 45 commercial, industrial, and transportation facilities that have impacted terrestrial resources in December 2008 4-59 Draft NUREG-1437, Supplement 38 OAG10001366_00268
Environmental Impacts of Operation 1 the region in addition to the IP2 and IP3 site include six power generation facilities on the 2 Hudson River between RM 37 and 67 (RKM 60 to 97), highways, railways along both sides of 3 the river, and manufacturing plants.
4 Although development of the site has contributed to cumulative impacts on terrestrial resources 5 from historical and ongoing development in the region, portions of the site have been protected 6 from development. The 70-ac (28-ha) forest community at the north end of the site has been 7 and, under the proposed action, would continue to be preserved, providing a beneficial effect by 8 reducing the potential for cumulative impacts from further loss of forests in the region. In 9 conjunction with this onsite forest tract, public lands in the region also preserve forest habitat 10 and have a beneficial cumulative impact on terrestrial resources. These lands include three 11 State parks in Westchester County and a total of 22 others in Rockland, Orange, Putnam, and 12 Dutchess Counties (Entergy 2007a), as well as forested lands of the New York State National 13 Guard's Camp Smith and the U.S. Military Academy at West Point.
14 Ultimately, development of the IP2 and IP3 site for power generation contributed incrementally 15 to a substantial, cumulative reduction in terrestrial resources resulting from other development 16 activities in the region that have occurred since precolonial times. However, as discussed in 17 Section 4.4.3 of this draft SEIS, there would be no population-related land use impacts 18 attributable to IP2 and IP3 during the license renewal term beyond those already being 19 experienced, and there would be no noticeable change in land use conditions in the vicinity of 20 IP2 and IP3.
21 The NRC staff concludes that the impact of past, present, and reasonably foreseeable future 22 actions in the region on terrestrial resources is considered LARGE relative to predevelopment 23 conditions, and that much of this impact had occurred before the construction and operation of 24 IP2 and IP3.
25 4.8.3 Cumulative Radiological Impacts 26 The radiological dose limits for protection of the public and workers have been developed by the 27 NRC and EPA to address the cumulative impact of acute and long-term exposure to radiation 28 and radioactive material. These dose limits are codified in 10 CFR Part 20 and 29 40 CFR Part 190. For the purpose of this analysis, the area within a 50-mi (80.4-km) radius of 30 the IP2 and IP3 site was included. The radiological environmental monitoring program 31 conducted by Entergy in the vicinity of the IP2 and IP3 site measures radiation and radioactive 32 materials from all sources; therefore, the monitoring program measures cumulative radiological 33 impacts. Within the 50-mi (80-km) radius of the IP2 and IP3 site there are no other nuclear 34 power reactors or uranium fuel cycle facilities. The NRC staff reviewed the 1993 and 1994 35 radiological environmental monitoring data from the area around IP2 and IP3 reported by 36 New York State; the data showed no adverse environmental impact. For the new issue 37 identified by Entergy concerning the tritium leak into the Hudson River, the NRC staff also 38 reviewed the information reported by Entergy, the NYSDEC and NYSDOH, and by the NRC.
39 No adverse impacts were identified (Entergy 2007b, NYSDEC and NYSDOH 2008, NRC 2006b, 40 NRC 2007b).
41 Radiation monitoring results for the 5-year period from 2002 to 2006 were reviewed as part of 42 the cumulative impacts assessment. In Sections 2.2.7 and 4.3 of this draft SEIS, the NRC staff 43 concluded that impacts of radiation exposure to the public and workers (occupational) from Draft NUREG-1437, Supplement 38 4-60 December 2008 OAG10001366_00269
Environmental Impacts of Operation 1 operation of IP2 and IP3 during the renewal term are SMALL. The NRC and the State of New 2 York would regulate any future actions in the vicinity of the IP2 and IP3 site that could contribute 3 to cumulative radiological impacts (Entergy 2003,2004,2005,2006, 2007b).
4 Entergy has constructed an independent spent fuel storage installation (lSFSI) on the IP2 and 5 IP3 site in 2008 for the storage of its spent fuel. The installation and monitoring of this facility is 6 governed by NRC requirements in 10 CFR Part 72, "Licensing Requirements for the 7 Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-8 Related Greater Than Class C Waste." Radiation from this facility as well as from the operation 9 of IP2 and IP3 must not exceed the radiation dose limits in 10 CFR Part 20,40 CFR Part 190, 10 and 10 CFR Part 72 (Entergy 2007a).
11 In addition, Entergy has indicated that it may replace IP2 and IP3 reactor vessel heads and 12 CRDMs during the period of extended operation. Such an action is not expected to change the 13 applicant's ability to maintain radiological doses to members of the public well within regulatory 14 limits because the amount of radioactive liquid, gaseous, and solid waste is not expected to 15 increase significantly (see Sections 2.1.4 and 2.2.7 of this draft SEIS for the detailed 16 discussion).
17 For these reasons, the NRC staff concludes that cumulative radiological impacts are SMALL, as 18 are the contribution to radiological impacts from continued operation of IP2 and IP3 and their 19 associated ISFSI. The NRC and the State of New York will continue to regulate operation of 20 IP2 and IP3 for radiological impacts.
21 4.8.4 Cumulative Socioeconomic Impacts 22 As discussed in Section 4.4 of this draft SEIS, continued operation of IP2 and IP3 during the 23 license renewal term would have no impact on socioeconomic conditions in the region beyond 24 those already being experienced. Since Entergy has indicated that it plans to hire no additional 25 nonoutage workers during the license renewal term, overall expenditures and employment 26 levels at IP2 and IP3 would be expected to remain relatively constant with no additional demand 27 for permanent housing, public utilities, and public services. In addition, since employment levels 28 and the value of IP2 and IP3 would not change, there would be no population and tax-revenue-29 related land use impacts. Also, there would be no disproportionately high and adverse health 30 and environmental impacts on minority and low-income populations in the region.
31 Entergy has indicated that it may replace the IP2 and IP3 reactor vessel heads and CRDMs, 32 and the decision to proceed with this replacement activity would be made based on future 33 component inspection results (Entergy 2008b). Nevertheless, Entergy estimates that this 34 replacement activity would require an increase in the number of refueling outage workers for up 35 to 60 days during two separate refueling outages, one for each unit, 12 months apart (Entergy 36 2008b). These additional workers would create short-term increases in the demand for 37 temporary (rental) housing, increased use of public water and sewer services, and 38 transportation impacts on access roads in the immediate vicinity of IP2 and IP3. Since it is not 39 certain if Entergy will replace the IP2 and IP3 reactor vessel heads and CRDMs, and given the 40 short amount of time needed for this replacement activity, the cumulative effects of these 41 replacement activities on socioeconomic conditions in the vicinity of IP2 and IP3 would not likely 42 be noticeable. Also, there would be no long-term cumulative socioeconomic impacts after the 43 reactor vessel heads and CRDMs are replaced.
December 2008 4-61 Draft NUREG-1437, Supplement 38 OAG10001366_00270
Environmental Impacts of Operation 1 In general, the region surrounding IP2 and IP3 has experienced growing population, increasing 2 economic activity and tax revenue, and changes in demographics over time. These effects in 3 the region have been LARGE, though the contribution of IP2 and IP3 to these effects have been 4 SMALL, except, in some cases, locally. Additionally, development in the region has had a 5 significant effect on historical and archaeological resources, which could be LARGE, as the 6 region is home to significant historic and prehistoric resources (as noted in 4.4.5, however, 7 continued operation of the plant would only have SMALL effects on historic and archaeological 8 resources).
9 4.8.5 Cumulative Impacts on Ground Water Use and Quality 10 In 2005 tritium was located beneath the IP2 and IP3 site. During a subsequent subsurface 11 monitoring program at the site, radioactive forms of cesium, cobalt, nickel, and strontium also 12 were found. The radiological impact of these abnormal leaks to the ground water is discussed 13 in Section 2.2.7 of this draft SEIS, and referenced in Sections 4.5 and 4.7.
14 The topography of the site and the foundation drains around the structures result in a flow 15 regime that transports ground water towards the Hudson River. As a result, the contaminated 16 ground water will be transported to the Hudson River and not off site in a direction that it might 17 be captured by an offsite ground water user. The results of monitoring programs support this 18 conclusion.
19 Because the water travels off site and into the Hudson River, there are no users for onsite 20 ground water. Any effects from the plant, previous development, or future development on site 21 will likely remain limited to effects on ground water transiting the site to the Hudson River, and 22 thus, are likely to be limited.
23 On the basis of the topography of the site, the characteristics of the subsurface media, location 24 of the plant relative to the Hudson River, recent ground water monitoring observations, and the 25 fact that there are no users for the site's ground water, the NRC staff concludes that the 26 cumulative impact on the site's ground water use and quality are SMALL.
27 4.8.6 Conclusions Regarding Cumulative Impacts 28 The NRC staff considered the potential impacts resulting from the operation of IP2 and IP3 and 29 resulting from other past, present, and reasonably foreseeable future actions in the vicinity. The 30 NRC staff's determination is that the cumulative impacts to the environment surrounding IP2 31 and IP3 from past and present human activities (beyond impacts from IP2 and IP3) have 32 generally been LARGE and could continue to be LARGE in some issue areas. Future 33 development is likely to continue to affect these resources.
34 4.9 Summary of Impacts of Operations during the Renewal Term 35 The NRC staff did not identify any information that is both new and significant related to any of 36 the applicable Category 1 issues associated with the operation of IP2 and IP3 during the 37 renewal term, including information related to ground water contamination at Indian Point.
38 Consequently, the NRC staff concludes that the environmental impacts associated with these 39 issues are bounded by the impacts described in the GElS. For each of these issues, the GElS Draft NUREG-1437, Supplement 38 4-62 December 2008 OAG10001366_00271
Environmental Impacts of Operation 1 concluded that the impacts would be SMALL and that additional plant-specific mitigation 2 measures are not likely to be sufficiently beneficial to warrant implementation.
3 Thirteen of the site-specific environmental issues identified in the GElS related to operational 4 impacts, and postulated accidents during the renewal term are discussed in detail in this draft 5 SEIS. These include 11 Category 2 issues and two uncategorized issues (environmental justice 6 and the chronic effects of EMFs). The NRC staff did not evaluate the chronic effects of EMFs 7 because research is continuing in the area and no scientific consensus on human health 8 impacts exists. The NRC staff will evaluate severe accident mitigation alternatives in Chapter 5.
9 For 6 of the remaining 10 Category 2 issues and environmental justice, the NRC staff concluded 10 that the potential impacts of continued plant operation during the license renewal period on 11 these issues are of SMALL significance in the context of the standards set forth in the GElS.
12 For four of these issues, the NRC staff concluded that the impacts of continued operation would 13 have a significant effect. On the issue of heat shock on the aquatic ecology, the NRC staff 14 concludes that effects are of SMALL to MODERATE significance, given uncertainty about actual 15 thermal effects of the plant. The NRC staff evaluated the combined effects of entrainment and 16 impingement on aquatic life and found the impacts to range from SMALL to LARGE, depending 17 on the species. Finally, the NRC staff found that impacts to threatened and endangered 18 species could range from SMALL to LARGE but that existing data make it difficult for staff to 19 assign a single impact level. Further sampling for threatened and endangered species at IP2 20 and IP3 could reduce this uncertainty.
21 4.10 References 22 Abood, K.A., T.L. Englert, S.G. Metzger, C.V. Beckers, Jr., T.J. Groninger, and S. Mallavaram.
23 2006. Current and evolving physical and chemical conditions in the Hudson River Estuary.
24 American Fisheries Society Symposium 51 :39-61.
25 Achman, D.R., B.J. Brownawell, and L. Zhang. 1996. Exchange of polychlorinated biphenyls 26 between sediment and water in the Hudson River Estuary. Estuaries 19(4):950-965.
27 Atlantic States Marine Fisheries Commission (ASMFC). 2006. "Species Profile: Atlantic 28 Striped Bass, The Challenges of Managing a Restored Stock." Available at URL:
29 http://www.asmfc.org/ speciesDocuments/stripedBass/speciesprofile.pdf. Accessed December 30 10,2007.
31 Atlantic States Marine Fisheries Commission (ASMFC). 2007. "Species Profile: Atlantic 32 Sturgeon, Ancient Species' Slow Road to Recovery." Available at URL: http://www.asmfc.org/
33 speciesDocuments/sturgeon/sturgeonProfile.pdf. Accessed December 6,2007. ADAMS 34 Accession No. ML083360698.
35 Atlantic Sturgeon Status Review Team (ASSRT). 2007. "Status Review of Atlantic Sturgeon 36 (Acipenser oxyrinchus oxyrinchus)." Report to National Marine Fisheries Service, Northeast 37 Regional Office. February 23,2007. 174 pp. Available at URL:
38 http://www. nmfs. noaa. gov/pr/pdfs/statusreviews/atlanticsturgeon2007. pdf. Accessed December 39 7,2007.
40 Baird, D., and R.E. Ulanowicz. 1989. The seasonal dynamics of the Chesapeake Bay 41 ecosystem. Ecological Monographs 59(4):329-364.
December 2008 4-63 Draft NUREG-1437, Supplement 38 OAG10001366_00272
Environmental Impacts of Operation 1 Bain, M.B., N. Haley, D.L. Peterson, K.K. Arend, K.E. Mills, and P.J. Sullivan. 2007. "Recovery 2 of a US Endangered Fish." PLoS ONE 2(1): e168. Department of Natural Resources, Cornell 3 University, Ithaca, New York. Available at URL: http://www.plosone.org/article/info 4 percent3Adoi percent2F10.1371 percent2Fjournal.pone.0000168#s3. Accessed December 11, 5 2007.
6 Barnthouse, L.W., C.C. Coutant, and W. Van Winkle. 2002. "Status and Trends of Hudson 7 River Fish Populations and Communities Since the 1970's: Evaluation of Evidence Concerning 8 Impacts of Cooling Water Withdrawals." January 2002. ADAMS Accession No. ML083360704.
9 Barnthouse, L.W., D.G. Heimbuch, W. Van Winkle, and J. Young. 2008. "Entrainment and 10 Impingement at IP2 and IP3: A Biological Impact Assessment." January 2008. ADAMS 11 Accession No. ML080390059.
12 Brosnan, T.M. and M.L. O'Shea. 1996. Long-term improvements in water quality due to 13 sewage abatement in the lower Hudson River. Estuaries 19(4)890-900.
14 Central Hudson Gas and Electric Corporation; Consolidated Edison Company New York, Inc.;
15 New York Power Authority; and Southern Energy New York (CHGEC et al.). 1999. "Draft 16 Environmental Impact Statement for State Pollutant Discharge Elimination System Permits for 17 Bowline Point, Indian Point 2 and 3, and Roseton Steam Electric Generating Stations."
18 December 1999. ADAMS Accession No. ML083400128.
19 Clean Water Act of 1977 (CWA). 33 USC 1326 et seq. (common name of the Federal Water 20 Pollution Control Act of 1977).
21 Cochran, W.G. 1997. Sampling Techniques. John Wiley and Sons, New York, New York. 428 22 pp.
23 Collette, B.B., and G. Klein-MacPhee (eds.). 2002. Bigelow and Schroeder's Fishes of the Gulf 24 Of Maine. (3rd Ed.) 748 pp. Smithsonian Institute Press, Herndon, Virginia.
25 Consolidated Edison Company of New York (Con Edison). 1976a. "IP2 and IP3 Impingement 26 Study Report for the Period 1 January 1975-31 December 1975." Prepared by Texas 27 Instruments, Inc. ADAMS Accession No. ML083360750.
28 Consolidated Edison Company of New York (Con Edison). 1976b. "Predation by Bluefish in the 29 Lower Hudson River." Prepared by Texas Instruments, Inc. ADAMS Accession No. ML 30 Consolidated Edison Company of New York (Con Edison). 1977. "Hudson River Ecological 31 Study in the Area of IP2 and IP3 1976 Annual Report." Prepared by Texas Instruments, Inc.
32 ADAMS Accession No. ML08309161.
33 Consolidated Edison Company of New York (Con Edison). 1979. "Hudson River Ecological 34 Study in the Area of IP2 and IP3 1977 Annual Report." Prepared by Texas Instruments, Inc.
35 ADAMS Accession No. ML083091068.
36 Consolidated Edison Company of New York (Con Edison). 1980. "Hudson River Ecological 37 Study in the Area of IP2 and IP3 1979 Annual Report." Prepared by Texas Instruments, Inc.
38 ADAMS Accession No. ML083360740.
39 Consolidated Edison Company of New York (Con Edison). 1984a. "Hudson River Ecological 40 Study in the Area of IP2 and IP3 1981 Annual Report." ADAMS Accession No. ML083091069.
Draft NUREG-1437, Supplement 38 4-64 December 2008 OAG10001366_00273
Environmental Impacts of Operation 1 Consolidated Edison Company of New York (Con Edison). 1984b. "Precision and Accuracy of 2 Stratified Sampling to Estimate Fish Impingement at Indian Point Unit No.2 and Unit No.3."
3 Prepared by Normandeau Associates, Inc. ADAMS Accession No. ML083360792.
4 Consolidated Edison Company of New York, Inc. (Con Edison). 2007. Letter from J. McAvoy, 5 Vice President, ConEdison, to F. Dacimo, Vice President, Entergy Nuclear Operations. January 6 19,2007.
7 Consolidated Edison Company of New York (Con Edison) and New York Power Authority 8 (NYPA). 1984. "Indian Point Generating Station Entrainment Abundance and Outage 9 Evaluation 1993 Annual Report." Prepared by EA Science and Technology, Inc.
10 Consolidated Edison Company of New York (Con Edison) and New York Power Authority 11 (NYPA). 1986. "Hudson River Ecological Study in the Area of IP2 and IP3 1985 Annual 12 Report." Prepared by Normandeau Associates, Inc. ADAMS Accession No. ML083091074.
13 Consolidated Edison Company of New York (Con Edison) and New York Power Authority 14 (NYPA). 1987. "Hudson River Ecological Study in the Area of IP2 and IP3 1986 Annual 15 Report." Prepared by Normandeau Associates, Inc. ADAMS Accession No. ML083091087.
16 Consolidated Edison Company of New York (Con Edison) and New York Power Authority 17 (NYPA). 1988. "Hudson River Ecological Study in the Area of IP2 and IP3 1987 Annual 18 Report." Prepared by EA Science and Technology. ADAMS Accession No. ML083091084.
19 Consolidated Edison Company of New York (Con Edison) and New York Power Authority 20 (NYPA). 1991. "Hudson River Ecological Study in the Area of IP2 and IP3 1990 Annual 21 Report." Prepared by EA Science and Technology. ADAMS Accession No. ML083091086.
22 Council on Environmental Quality (CEQ). 1997. "Environmental Justice: Guidance under the 23 National Environmental Policy Act." Executive Office of the President, Washington, DC.
24 Daniels, R.A., K.E. Limburg, R.E. Schmidt, D.L. Strayer, and R.C. Chambers. 2005. "Changes 25 in Fish Assemblages in the Tidal Hudson River, New York." American Fisheries Society 26 Symposium 45:471-503. Available at URL: http://www.ecostudies.org/reprints/
27 daniels_et_al_2005.pdf. Accessed March 13, 2008.
28 Ecological Analyses, Inc. (EA). 1981a. "Indian Point Generating Station Entrainment Survival 29 and Related Studies. 1979 Annual Report." Prepared for Consolidated Edison Company of 30 New York, Inc., and Power Authority of the State of New York. Ecological Analysts, Inc.
31 January 1982. ADAMS Accession No. ML073330733.
32 Ecological Analyses, Inc. (EA). 1981b. "1981 Con Edison Automated Abundance Sampling 33 (AUTOSAM) and Laboratory Processing Standard Operating Procedures." Prepared for 34 Consolidated Edison Company of New York, Inc. Ecological Analysts, Inc. May 1981.
35 ADAMS Accession No. ML083100602.
36 Ecological Analyses, Inc. (EA). 1982. "Indian Point Generating Station Entrainment Survival 37 and Related Studies. 1980 Annual Report." Prepared for Consolidated Edison Company of 38 New York, Inc., and Power Authority of the State of New York. Ecological Analysts, Inc. April 39 1981. ADAMS Accession No. ML073330737.
40 Ecological Analyses, Inc. (EA). 1984. "Indian Point Generating Station Entrainment Abundance 41 and Outage Evaluation, 1983 Annual Report." Prepared for Consolidated Edison Company of December 2008 4-65 Draft NUREG-1437, Supplement 38 OAG10001366_00274
Environmental Impacts of Operation 1 New York, Inc., and Power Authority of the State of New York. EA Engineering, Science, and 2 Technology, Inc. September 1984. ADAMS Accession No. ML083101084.
3 Ecological Analyses, Inc. (EA). 1985. "Indian Point Generating Station Entrainment Abundance 4 and Outage Evaluation, 1983 Annual Report." Prepared for Consolidated Edison Company of 5 New York, Inc., and Power Authority of the State of New York. EA Science and Technology.
6 July 1985. ADAMS Accession No. ML083101091.
7 Ecological Analyses, Inc. (EA). 1989. "Indian Point Generating Station 1988 Entrainment 8 Survival Study." Prepared for Consolidated Edison Company of New York, Inc., and Power 9 Authority of the State of New York. EA Engineering, Science, and Technology, Northeast 10 Regional Operations, Report No. 10648.03. August 1989. ADAMS Accession No.
11 ML083101103.
12 Enercon Services Inc. (Enercon). 2007. "Phase 1A Literature Review and Archaeological 13 Sensitivity Assessment of the Indian Point Site, Westchester County, New York." Enercon 14 Services Inc., Tulsa, Oklahoma. March 2007.
15 Enercon. 2008. "Enercon Study ELEC-IP-08001 for IP2 and IP3 License Renewal Project 345 16 kV Transmission Line-Induced Shock Study." April 11, 2008. Prepared for Entergy Nuclear 17 Operations, Inc.
18 Entergy Nuclear Northeast (ENN). 2007. "Indian Point Nuclear Power Plants Units 1,2, and 3, 19 Annual Radiological Environmental Operating Report for 2006." Buchanan, New York. May 20 2007.
21 Entergy Nuclear Operations Inc. (Entergy). 2003. "Indian Point Nuclear Plant Units No.1, 2, 22 and 3-Annual Radiological Environmental Operating Report for 2002." Docket Numbers 50-3, 23 50-247, and 50-286. Buchanan, New York. Agencywide Documents Access and Management 24 System (ADAMS) Accession No. ML031220085.
25 Entergy Nuclear Operations Inc. (Entergy). 2004. "Indian Point Nuclear Power Plants Units 1, 26 2, and 3-Annual Radiological Environmental Operating Report for 2003." Docket Numbers 50-27 3,50-247, and 50-286. Buchanan, New York. ADAMS Accession No. ML041340492.
28 Entergy Nuclear Operations Inc. (Entergy). 2005. "Indian Point Units 1,2, and 3-2004 29 Annual Radiological Environmental Operating Report." Docket Numbers 50-3,50-247, and 50 30 286. Buchanan, New York. ADAMS Accession No. ML051220210.
31 Entergy Nuclear Operations Inc. (Entergy). 2006. "Indian Point, Units 1,2 and 3-Annual 32 Radiological Environmental Operating Report for 2005." Docket Numbers 50-3,50-247, and 50 33 286. Buchanan, New York. ADAMS Accession No. ML061290085.
34 Entergy Nuclear Operations, Inc. (Entergy). 2007a. "Applicant's Environment Report, 35 Operating License Renewal Stage." (Appendix E to Indian Point, Units 2 and 3, License 36 Renewal Application). April 23, 2007. ADAMS Accession No. ML071210530.
37 Entergy Nuclear Operations Inc. (Entergy). 2007b. "I P2 and IP3, Units 1, 2, and 3-Annual 38 Radiological Environmental Operating Report for 2006." Docket Numbers 50-3,50-247, and 50 39 286. Buchanan, New York. ADAMS Accession No. ML071420088.
40 Entergy Nuclear Operations, Inc. (Entergy). 2007b. Letter from F.R. Dacimo, Vide President, 41 Entergy Nuclear Operations, Inc. to Document Control Desk, U.S. Nuclear Regulatory Draft NUREG-1437, Supplement 38 4-66 December 2008 OAG10001366_00275
Environmental Impacts of Operation 1 Commission.
Subject:
Entergy Nuclear Operations, Inc., Indian Point Nuclear Generating Unit 2 Nos. 2 & 3; Docket Nos. 50-247 and 50-2S6; Supplement to License Renewal Application (LRA) 3 - Environmental Report References. ADAMS Nos. MLOSOOS0205, MLOSOOOS0209, 4 MLOSOOS0214, MLOSOOS02161, MLOSOOOS0291, MLOSOOS029S, MLOSOOS0306, and 5 MLOSOOS0313.
6 Entergy Nuclear Operations, Inc. (Entergy). 200S. Letter from F. Dacimo, Vice President, 7 Entergy Nuclear Operations, to U.S. Nuclear Regulatory Commission Document Control Desk.
S
Subject:
Reply to Document Request for Additional Information Regarding Site Audit Review of 9 License Renewal Application for Indian Point Nuclear Generating Unit Nos. 2 and 3. April 23, 10 200S. ADAMS Accession No. MLOS1230243.
11 Entergy Nuclear Operations, Inc. (Entergy). 200Sb. Letter from F. Dacimo, Vice President, 12 License Renewal, to U.S. Nuclear Regulatory Commission Document Control Desk.
Subject:
13 Reply to Document Request for Additional Information Regarding License Renewal 14 Application-Refurbishment. May 14, 200S. ADAMS Accession No. MLOS1440052.
15 Environmental Protection Agency (EPA). 1995. Guidelines for Ecological Risk Assessment.
16 EPA/630/R-95/002F. Risk Assessment Forum, Washington, D.C. Available at URL:
17 http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=12460. Accessed December 12, 200S.
1S Environmental Protection Agency (EPA). 2004. "Total Maximum Daily Loads, Listed Water 19 Information, Cycle: 2004. Hudson River, Lower Hudson River." U.S. Environmental Protection 20 Agency. Available at URL: http://oaspub.epa.gov/tmdl/enviro.control?pJisUd=NY-1301-21 0002andp_cycle=2004. Accessed February 23, 200S.
22 Environmental Protection Agency (EPA). 200Sa. "Phase II-Large Existing Electric Generating 23 Plant. Proposed Rule, Technical Development Document." Available at URL:
24 http://www.epa.gov/waterscience/316b/phase2/devdocl. Accessed April 10, 200S.
25 Environmental Protection Agency (EPA). 200Sb. "Hudson River PCB Superfund Site, Dredge 26 Area 2 Delineation Fact Sheet, 200S." Available at URL: http://www.epa.gov/
27 hudson/factsheet_2nd_phaselow.pdf. Accessed February 4, 200S. ADAMS Accession No.
2S M LOS3360712.
29 Endangered Species Act of 1973 (ESA). 16 USC 1531, et seq.
30 Fish and Wildlife Service (FWS). 2007. Letter from R.A. Niver, Endangered Species Biologist, 31 to Rani Franovich, Branch Chief, Projects Branch 2, Division of License Renewal, Office of 32 Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington, DC.
33 Response to letter from the U.S. Nuclear Regulatory Commission requesting information on 34 Federally listed, proposed, and candidate species and critical habitat in the vicinity of Indian 35 Point Nuclear Generating Unit Nos. 2 and 3. August 29, 2007. ADAMS Accession No.
36 ML0732307S40.
37 Fletcher, R.I. 1990. Flow dynamics and fish recovery experiments: Water intake 3S systems. Transactions of the American Fisheries Society. 119:393-415.
39 Frank, K.T., B. Petrie, and N.L. Shackell. 2007. The ups and downs of trophic control in 40 continental shelf ecosystems. Trends in Ecology and Evolution 22(5):236-242.
41 Greenwood, M.FD. 200S. Trawls and cooling-water intakes as estuarine fish sampling tools:
42 Comparisons of catch composition, trends in relative abundance, and length selectivity.
December 200S 4-67 Draft NUREG-1437, Supplement 3S OAG10001366_00276
Environmental Impacts of Operation 1 Estuarine, Coastal and Shelf Science 76:121-130.
2 Gilbert, C.R. 1989. "Species Profiles: Life Histories and Environmental Requirements of 3 Coastal Fishes and Invertebrates (Mid-Atlantic Bight)-Atlantic and Shortnose Sturgeons." U.S.
4 Fish and Wildlife Service Biological Report 82 (11.122). U.S. Army Corps of Engineers TR EL-5 82-4. 28 pp.
6 Institute of Electrical and Electric Engineers (IEEE). 1997. "National Electric Safety Code."
7 New York.
8 Mayhew, D.A., LD. Jensen, D.F. Hanson, and P.H. Muessig. 2000. A comparative review of 9 entrainment survival studies at power plants in estuarine environments. Environmental Science 10 and Policy 3:295-301.
11 Menzie, C., M.H. Henning, J. Cura, K. Finkelstein, J. Gentile, J. Maughan, D. Mitchell, S.
12 Petron, B. Potocki, S. Svirsky, and P. Tyler. 1996. Report of the Massachusetts Weight-of-13 Evidence Workgroup: A weight-of-evidence approach for evaluating ecological risks. Human 14 and Ecological Risk Assessment 2:277-304.
15 Munch, S.B., and D.O. Conover. 2000. Recruitment dynamics of bluefish (Pomatomus 16 saltatrix) from Cape Hatteras to Cape Cod, 1973-1995. ICES Journal of Marine Sciences 17 57(2):393-402.
18 National Environmental Policy Act of 1969 (NEPA). 42 USC 4321, et. seq.
19 National Institute of Environmental Health Sciences (NIEHS). 1999. "NIEHS Report on Health 20 Effects from Exposure to Power-Line Frequency Electric and Magnetic Fields." NIH Publication 21 No. 99-4493, Research Triangle Park, North Carolina.
22 National Marine Fisheries Service (NMFS). 1998. "Recovery Plan for the Shortnose Sturgeon 23 (Acipenser brevirostrum)." Prepared by the Shortnose Sturgeon Recovery Team for the 24 National Marine Fisheries Service, Silver Spring, Maryland. 104 pp. Available at URL:
25 http://www.nmfs.noaa.gov/pr/pdfs/recovery/sturgeon_shortnose.pdf. Accessed December 11, 26 2007.
27 National Marine Fisheries Service (NMFS). 2007a. Letter from M. Colligan, Assistant Regional 28 Administrator for Protected Resources, to Chief, Rules and Directives Branch, Division of 29 Administrative Services, U.S. Nuclear Regulatory Commission, Washington, DC. Response to 30 letter of August 10,2007, from the U.S. Nuclear Regulatory Commission requesting information 31 on Federally listed, proposed, and candidate species, critical habitat, and designated essential 32 fish habitat in the vicinity of Indian Point Nuclear Generating Unit Nos. 2 and 3. October 4, 33 2007. ADAMS Accession No. ML073230796.
34 National Marine Fisheries Service (NMFS). 2007b. "Species of Concern: Atlantic Sturgeon, 35 Acipenser oxyrinchus." Available at URL: http://www.nmfs.noaa.gov/pr/pdfs/species/
36 atlanticsturgeon_detailed.pdf. Accessed December 6,2007.
37 New York Natural Heritage Program (NYNHP). 2008a. "Online Conservation Guide for Myotis 38 sodalis." Available at URL: http://www.acris.nynhp.org/guide.php?id=7405. Accessed March 39 21,2008. ADAMS Accession No. ML083390018.
40 New York Natural Heritage Program (NYNHP). 2008b. "Online Conservation Guide for 41 Sylvilagus transitional is." Available at URL: http://www.acris.nynhp.org/guide.php?id=7415.
Draft NUREG-1437, Supplement 38 4-68 December 2008 OAG10001366_00277
Environmental Impacts of Operation 1 Accessed March 21,2008. ADAMS Accession No. ML083390017.
2 New York Power Authority. 1986. "Size Selectivity and Relative Catch Efficiency of a 3-m 3 Beam Trawl and a 1-m2 Epibenthic Sled for Sampling Young of the Year Striped Bass and 4 Other Fishes in The Hudson River Estuary." Prepared by Normandeau Associates, Inc.
5 January 1986. (HR Library #7180). ADAMS Accession No. ML083360641.
6 New York State Department of Environmental Conservation (NYSDEC). 1997. NRDC vs.
7 NYSDEC, et al. Fourth Amended Consent Order. Letter from Keith Silliman on April 23, 1997.
8 New York State Department of Environmental Conservation, Office of General Counsel.
9 New York State Department of Environmental Conservation (NYSDEC). 2003a. "Final 10 Environmental Impact Statement Concerning the Applications to Renew New York State 11 Pollutant Discharge Elimination System (SPDES) Permits for the Roseton 1 and 2, Bowline 1 12 and 2, and Indian Point 2 and 3 Steam Electric Generating Stations, Orange, Rockland and 13 Westchester Counties. Hudson River Power Plants FEIS." June 25,2003. ADAMS Accession 14 No. ML083360752.
15 New York State Department of Environmental Conservation (NYSDEC). 2003b. Fact Sheet.
16 "New York State Pollutant Discharge Elimination System (SPDES) Draft Permit Renewal with 17 Modification, IP2 and IP3 Electric Generating Station, Buchanan, NY." November 2003.
18 Available at URL: http://www.dec.ny.gov/docs/permits_eLoperations_pdf/lndianPointFS.pdf.
19 Accessed July 12, 2007. ADAMS Accession No. ML083360743.
20 New York State Department of Environmental Conservation (NYSDEC). 2007. State of New 21 York Petition submitted to the U.S. Nuclear Regulatory Commission, November 30,2007, on 22 the Application of Entergy Nuclear Operations, Inc., for the 20-year Relicensing of Indian Point 23 Nuclear Power Plants 1 and 2, Buchanan, New York. Summary of Some of the Key 24 Contentions. Available at URL: http://www.dec.ny.gov/permits/40237.html. Accessed March 25 18,2008. ADAMS Accession No. ML083360757.
26 New York State Department of Environmental Conservation (NYSDEC). 2008a. "List of 27 Endangered, Threatened and Special Concern Fish and Wildlife Species of New York."
28 Available at URL: http://www.dec.ny.gov/animals/7494.html. Accessed May 3,2008. ADAMS 29 Accession No. ML083380558.
30 New York State Department of Environmental Conservation (NYSDEC). 2008b. "New York 31 State Amphibian and Reptile Atlas Project." Available at URL: http://www.dec.ny.gov/
32 animals/7479.html?showprintstyles. Accessed March 13,2008.
33 New York State Department of Environmental Conservation (NYSDEC) and New York State 34 Department of Health (NYSDOH). 2008. "Groundwater Investigation." Albany, New York.
35 Available at URL: http://www.dec.ny.gov/permits/44014.html.
36 Normandeu Associates (Normandeu). 1987a. Prepared for Consolidated Edison Company of 37 New York, Inc., and New York Power Authority. Prepared by Normandeu Associates, Inc.
38 Report R-332-1062. April 1987. ADAMS Accession No. ML0803091074.
39 Normandeu Associates (Normandeu). 1987b. "Indian Point Generating Station Entrainment 40 Abundance Program, 1986 Annual Report." Prepared for Consolidated Edison Company of 41 New York, Inc., and New York Power Authority. Prepared by Normandeu Associates, Inc.
42 Report R 220. June 1987. ADAMS Accession No. ML083091087.
December 2008 4-69 Draft NUREG-1437, Supplement 38 OAG10001366_00278
Environmental Impacts of Operation 1 Normandeu Associates (Normandeu). 1988. "IP2 and IP3 Generating Station Entrainment 2 Abundance Program, 1987 Annual Report." Prepared for Consolidated Edison Company of 3 New York, Inc., and New York Power Authority. Prepared by Normandeu Associates, Inc.
4 Report R 1110. May 1988. ADAMS Accession No. M L083360798.
5 Northeast Fisheries Science Center (NEFSC). 2005. 41st Northeast Regional Stock 6 Assessment Workshop (41st SAW): 41st SAW Assessment Report. Northeast Fisheries 7 Science Center Reference Document 05-14.
8 Nuclear Regulatory Commission (NRC). 1975. "Final Environmental Statement Related to the 9 Operation of IP2 and IP3 Nuclear Generating Plant Unit No.3, Consolidated Edison Company 10 of New York, Inc." NUREG-75/002.
11 Nuclear Regulatory Commission (NRC). 1996. "Generic Environmental Impact Statement for 12 License Renewal of Nuclear Power Plants." NUREG-1437, Volumes 1 and 2, Washington, DC.
13 Nuclear Regulatory Commission (NRC). 1999. "Generic Environmental Impact Statement for 14 License Renewal of Nuclear Plants Main Report," Section 6.3, "Transportation," Table 9.1, 15 "Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants."
16 NUREG-1437, Volume 1, Addendum 1, Washington, DC 17 Nuclear Regulatory Commission (NRC). 2005. "Generic Environmental Impact Statement for 18 License Renewal of Nuclear Plants, Supplement 22 Regarding Millstone Power Station, Units 2 19 and 3, Final Report." NUREG-1437. Office of Nuclear Reactor Regulation. Washington, D.C.
20 Nuclear Regulatory Commission (NRC). 2006a. NUREG-1437, Supplement 20, "Generic 21 Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Donald C.
22 Cook Nuclear Plant, Units No.1 and 2," Washington, DC.
23 Nuclear Regulatory Commission (NRC). 2006b. "Indian Point Nuclear Generating Unit 2-NRC 24 Special Inspection Report No. 05000247/2005011." Docket Number 50-247. Washington, DC.
25 ADAMS Accession No. ML060750842.
26 Nuclear Regulatory Commission (NRC). 2007a. Letter from R. Franovich to Mr. Peter Colosi, 27 National Marine Fisheries Service, Gloucester, Massachusetts. Re: Request for List of 28 Protected Species and Essential Fish Habitat within the Area under Evaluation for the IP2 and 29 IP3 Nuclear Generating Unit Nos. 2 and 3 License Renewal Application Review. August 16, 30 2007. ADAMS Accession No. ML072130388.
31 Nuclear Regulatory Commission (NRC). 2007b. "Indian Point Nuclear Generating Unit 2-32 Routine Integrated Inspection Report No. 05000247/07003." Docket Number 50-247.
33 Washington, DC. ADAMS Accession No. ML072150161.
34 Pew Oceans Commission. 2003. America's Living Oceans: Charting a Course for Sea 35 Change. Pew Oceans Commission, Arlington, VA Available at http://www.pewoceans.org.
36 Raffenberg, M.J., J.A Matousek, W.o. Saksen, AJ. McCusker, and E.W. Radle. 2008.
37 "Development of Filter Fabric Barrier to Reduce Aquatic Impacts at Water Intake Structures."
38 Available at URL: http://www.epa.gov/waterscience/presentations/raffenberg.pdf. Accessed 39 April 9, 2008.
40 Riverkeeper. 2007. Re: Acceptance Review for Entergy Nuclear IP2 and IP3 License Renewal 41 Application. Letter to Mr. Bo Pham, Environmental Project Manager, Division of License Draft NUREG-1437, Supplement 38 4-70 December 2008 OAG10001366_00279
Environmental Impacts of Operation 1 Renewal, on June 4, 2007, from Phillip Musegaas, Riverkeeper Staff Attorney.
2 Secor, D.H. and E.D. Houde. 1995. Temperature effects on the timing of striped bass egg 3 production, larval viability, and recruitment potential in the Patuxent River (Chesapeake Bay).
4 Estuaries 18:527-533.
5 Shepherd G. 2006. 'Atlantic Striped Bass." December 2006. Accessed at:
6 http://www.nefsc.noaa.gov/sos/spsyn/af/sbass/archives/40_ StripedBass_2006. pdf on December 7 10,2007. ADAMS Accession No. ML083360766.
8 Shepherd, G. 2006. "Bluefish." Available at URL: http://www.nefsc.noaa.gov/
9 sos/spsyn/op/bluefish/archives/25_Bluefish_2006.pdf. Accessed October 2,2008. ADAMS 10 Accession No. ML083360690.
11 Snedecor, G.W. and W.G. Cochran. 1980. Statistical Methods. The Iowa State University 12 Press, Ames, Iowa, 507 pp.
13 Steinberg, N., D.J. Suszkowski, L. Clark, and J. Way. 2004. "Health of the Harbor: The First 14 Comprehensive Look at the State of the NY.NY Harbor Estuary. A Report to the New York/New 15 Jersey Harbor Estuary Program." Hudson River Foundation. New York, New York. ADAMS 16 Accession No. ML083360712.
17 Strayer, D.L., K.A Hattala, and AW. Kahnle. 2004. Effects of an invasive bivalve (Dreissena 18 polymorpha) on fish in the Hudson River Estuary. Canadian Journal of Fisheries and Aquatic 19 Sciences 61 :924-941.
20 Sweka, J.A, J. Mohler, M.J. Millard, T. Kehler, A Kahnle, K. Hattala, G. Kenney, and A Higgs.
21 2007. Juvenile Atlantic sturgeon habitat use in Newburgh and Haverstraw Bays of the Hudson 22 River: Implications for population monitoring. North American Journal of Fisheries 23 Management 27:1058-1067.
24 Ulanowicz, R.E. 1995. "Trophic Flow Networks as Indicators of Ecosystem Stress." In G.A 25 Polis and K.O. Winemiller (eds). Food Webs: Integration of Patterns and Dynamics, Chapman 26 and Hall, New York. pp. 358-368.
27 U.S. Atomic Energy Commission (USAEC). 1972. "Final Environmental Statement Related to 28 the Operation of Indian Point Nuclear Generating Plant No.2." Docket No. 50-247. United 29 States Atomic Energy Commission, Directorate of Licensing. September 1972.
30 U.S. Census Bureau (USCB). 2003. "LandView 6-Census 2000 Profile of General 31 Demographic Characteristics DP-1 (100 percent) and Census Profile of Selected Economic 32 Characteristics DP-3, Summary of Census Block Groups in a 50-Mile Radius around the IP2 33 and IP3 Energy Center (41.269722 Lat., -73.952083 Long.)." December 2003.
34 U.S. Census Bureau (USCB). 2008. "American FactFinder, Census 2000 Information and 35 State and County QuickFacts on Dutchess, Orange, Putnam, and Westchester Counties."
36 Available at URL: http://factfinder.census.gov and http://quickfacts.census.gov. Accessed April 37 2008.
38 Wolfe, D.A, E.R. Long, and G.B. Thursby. 1996. Sediment toxicity in the Hudson-Raritan 39 Estuary: Distribution and correlations with chemical contamination. Estuaries 19(4):901-912.
40 Woodland, R.J. and D.H Secor. 2007. Year-class strength and recovery of endangered 41 shortnose sturgeon in the Hudson River, New York. Transactions of the American Fisheries December 2008 4-71 Draft NUREG-1437, Supplement 38 OAG10001366_00280
Environmental Impacts of Operation 1 Society 136:72-81.
Draft NUREG-1437, Supplement 38 4-72 December 2008 OAG10001366_00281
1 5.0 ENVIRONMENTAL IMPACTS OF POSTULATED 2 ACCIDENTS 3 Environmental issues associated with postulated accidents are discussed in NUREG-1437, 4 Volumes 1 and 2, "Generic Environmental Impact Statement for License Renewal of Nuclear 5 Plants" (hereafter referred to as the GElS) (NRC 1996, 1999).(1) The GElS includes a 6 determination of whether the analysis of the environmental issues could be applied to all plants 7 and whether additional mitigation measures would be warranted. Issues are then assigned a 8 Category 1 or a Category 2 designation. As set forth in the GElS, Category 1 issues are those 9 that meet all of the following criteria:
10 (1) The environmental impacts associated with the issue have been determined to apply 11 either to all plants or, for some issues, to plants having a specific type of cooling system 12 or other specified plant or site characteristics.
13 (2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 14 the impacts (except for collective offsite radiological impacts from the fuel cycle and from 15 high-level waste and spent fuel disposal).
16 (3) Mitigation of adverse impacts associated with the issue has been considered in the 17 analysis, and it has been determined that additional plant-specific mitigation measures 18 are likely not to be sufficiently beneficial to warrant implementation.
19 For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 20 required unless new and significant information is identified.
21 Category 2 issues are those that do not meet one or more of the criteria for Category 1 and, 22 therefore, additional plant-specific review of these issues is required.
23 This chapter describes the environmental impacts from postulated accidents that might occur 24 during the license renewal term.
25 5.1 Postulated Plant Accidents 26 Two classes of accidents are evaluated in the GElS. These are design-basis accidents (DBAs) 27 and severe accidents, as discussed below.
28 5.1.1 Design-Basis Accidents 29 In order to receive U.S. Nuclear Regulatory Commission (NRC) approval to operate a nuclear 30 power facility, an applicant for an initial operating license must submit a safety analysis report 31 (SAR) as part of its application. The SAR presents the design criteria and design information for 32 the proposed reactor and comprehensive data on the proposed site. The SAR also discusses 33 various hypothetical accident situations and the safety features that are provided to prevent and 34 mitigate accidents. The NRC staff reviews the application to determine whether the plant (1)
The GElS was originally issued in 1996. Addendum 1 to the GElS was issued in 1999. Hereafter, all references to the GElS include the GElS and its Addendum 1.
December 2008 5-1 Draft NUREG-1437, Supplement 38 OAG10001366_00282
Environmental Impacts of Postulated Accidents 1 design meets the Commission's regulations and requirements and includes, in part, the nuclear 2 plant design and its anticipated response to an accident.
3 DBAs are those accidents that both the licensee and the NRC staff evaluate to ensure that the 4 plant can withstand normal and abnormal transients, as well as a broad spectrum of postulated 5 accidents, without undue hazard to the health and safety of the public. A number of these 6 postulated accidents are not expected to occur during the life of the plant, but are evaluated to 7 establish the design basis for the preventive and mitigative safety systems of the facility. The 8 acceptance criteria for DBAs are described in Title 10, Part 50, "Domestic Licensing of 9 Production and Utilization Facilities," of the Code of Federal Regulations (10 CFR Part 50) and 10 10 CFR Part 100, "Reactor Site Criteria."
11 The environmental impacts of DBAs are evaluated during the initial licensing process, and the 12 ability of the plant to withstand these accidents is demonstrated to be acceptable before 13 issuance of the operating license. The results of these evaluations are found in licensing 14 documentation such as the applicant's final safety analysis report, the NRC staff's safety 15 evaluation report, the final environmental statement (FES), and Section 5.1 of this draft 16 supplemental environmental impact statement (SEIS). A licensee is required to maintain the 17 acceptable design and performance criteria throughout the life of the plant, including any 18 extended-life operation. The consequences for these DBAs are evaluated for the hypothetical 19 maximally exposed individual. Changes in the plant's surroundings, including local population, 20 will not affect the evaluation for the maximally exposed individual. Because of the requirements 21 that continuous acceptability of the consequences and aging management programs be in effect 22 for license renewal, the environmental impacts as calculated for DBAs should not differ 23 significantly from initial licensing assessments over the life of the plant, including the period of 24 extended operation. Accordingly, the design of the plant relative to DBAs during the extended 25 period is considered to remain acceptable, and the environmental impacts of those accidents 26 were not examined further in the GElS.
27 The Commission has determined that the environmental impacts of DBAs are of SMALL 28 significance for all plants because the plants were designed to successfully withstand these 29 accidents. Therefore, for the purposes of license renewal, DBAs are designated as a 30 Category 1 issue in Table B-1 of Appendix B to Subpart A, "Environmental Effect of Renewing 31 the Operating License of a Nuclear Power Plant," of 10 CFR Part 51, "Environmental Protection 32 Regulations for Domestic Licensing and Related Regulatory Functions." The early resolution of 33 the DBAs makes them a part of the current licensing basis (CLB) of the plant; the CLB of the 34 plant, which is maintained by the licensee under its current license, will continue to be 35 maintained under a renewed license in accordance with 10 CFR 54.33, "Continuation of CLB 36 and Conditions of Renewed License." Therefore, under the provisions of 10 CFR 54.30, 37 "Matters Not Subject to a Renewal Review," the CLB is not subject to review under license 38 renewal. This issue, applicable to Indian Point Nuclear Generating Unit Nos. 2 and 3 (lP2 and 39 IP3), is listed in Table 5-1.
40 Table 5-1. Category 1 Issues Applicable to Postulated Accidents 41 during the Renewal Term ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Sections POSTULATED ACCIDENTS Draft NUREG-1437, Supplement 38 5-2 December 2008 OAG10001366_00283
Environmental Impacts of Postulated Accidents ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Sections Design-basis accidents 5.3.2; 5.5.1 1 Based on information in the GElS, the Commission found the following:
2 The NRC staff has concluded that the environmental impacts of design-basis 3 accidents are of small significance for all plants.
4 Entergy Nuclear Operations, Inc. (Entergy), stated in the IP2 and IP3 environmental report (ER) 5 (Entergy 2007a) that it is not aware of any new and significant information associated with the 6 renewal of the IP2 and IP3 operating licenses. The NRC staff has not identified any new and 7 significant information during its independent review of the IP2 and IP3 ER, the site visit, the 8 scoping process, or evaluation of other available information. Therefore, the NRC staff 9 concludes that there are no impacts related to DBAs beyond those discussed in the GElS.
10 5.1.2 Severe Accidents 11 Severe nuclear accidents are those that are more severe than DBAs because they could result 12 in substantial damage to the reactor core, regardless of offsite consequences. In the GElS, the 13 NRC staff assessed the impacts of severe accidents using the results of existing analyses and 14 site-specific information to conservatively predict the environmental impacts of severe accidents 15 for each plant during the renewal period.
16 Severe accidents initiated by external phenomena, such as tornadoes, floods, earthquakes, 17 fires, and sabotage, traditionally have not been discussed in quantitative terms in FESs and 18 were not specifically considered for IP2 and IP3 in the GElS. However, in the GElS, the NRC 19 staff did evaluate existing impact assessments performed by the NRC and by the industry at 20 44 nuclear plants in the United States and concluded that the risk from beyond-design-basis 21 earthquakes at existing nuclear power plants is SMALL. The GElS for license renewal 22 documents a discretionary analysis of acts of sabotage in connection with license renewal, and 23 concluded that the core damage and radiological release from such acts would be no worse 24 than the damage and release expected from internally initiated events. In the GElS, the 25 Commission concluded that the risk from sabotage and beyond-design-basis earthquakes at 26 existing nuclear power plants is small and, additionally, that the risks from other external events 27 are adequately addressed by a generic consideration of internally initiated severe accidents 28 (see Volume 1 of the GElS, page 5-18).
29 Based on information in the GElS, the Commission found the following:
30 The probability weighted consequences of atmospheric releases, fallout onto 31 open bodies of water, releases to groundwater, and societal and economic 32 impacts from severe accidents are small for all plants. However, alternatives to 33 mitigate severe accidents must be considered for all plants that have not 34 considered such alternatives.
35 Therefore, the Commission has designated mitigation of severe accidents as a Category 2 issue 36 in 10 CFR Part 51, Subpart A, Appendix B, Table B-1. This issue, applicable to IP2 and IP3, is 37 listed in Table 5-2.
December 2008 5-3 Draft NUREG-1437, Supplement 38 OAG10001366_00284
Environmental Impacts of Postulated Accidents 1 Table 5-2. Category 2 Issues Applicable to Postulated Accidents 2 during the Renewal Term ISSUE-10 CFR Part 51, Subpart A, GElS 10 CFR 51.53(c)(3)(ii) SEIS Appendix B, Table B-1 Sections Subparagraph Section POSTULATED ACCIDENTS Severe accidents 5.3.3; 5.3.3.2; L 5.2 5.3.3.3; 5.3.3.4; 5.3.3.5; 5.4; 5.5.2 3 The NRC staff has not identified any new and significant information with regard to the 4 consequences from severe accidents during its independent review of the IP2 and IP3 ER 5 (Entergy 2007a), the site visit, the scoping process, or evaluation of other available information.
6 Therefore, the NRC staff concludes that there are no impacts of severe accidents beyond those 7 discussed in the GElS. However, in accordance with 10 CFR 51.53(c)(3)(ii)(L), the NRC staff 8 has reviewed severe accident mitigation alternatives (SAMAs) for IP2 and IP3. The results of its 9 review are discussed in Section 5.2 of this draft SEIS.
10 5.2 Severe Accident Mitigation Alternatives 11 As required by 10 CFR 51.53(c)(3)(ii)(L), license renewal applicants must consider alternatives 12 to mitigate severe accidents if the staff has not previously evaluated SAMAs for the applicant's 13 plant in an environmental impact statement (EIS), or related supplement, or in an environmental 14 assessment. The purpose of this consideration is to ensure that plant changes (i.e., hardware, 15 procedures, and training) with the potential for improving severe accident safety performance 16 are identified and evaluated. SAMAs have not been previously considered for IP2 and IP3; 17 therefore, the remainder of Chapter 5 addresses those alternatives.
18 5.2.1 Introduction 19 This section presents a summary of the SAMA evaluation for IP2 and IP3, conducted by 20 Entergy, and the NRC staff's review of that evaluation. The NRC staff performed its review with 21 contract assistance from Information Systems Laboratories, Inc. The NRC staff's review is 22 available in full in Appendix G to this draft SEIS; the SAMA evaluation is available in full in 23 Entergy's ER.
24 The SAMA evaluation for IP2 and IP3 was conducted using a four-step approach. In the first 25 step, Entergy quantified the level of risk associated with potential reactor accidents using the 26 plant-specific probabilistic safety assessment (PSA) and other risk models.
27 In the second step, Entergy examined the major risk contributors and identified possible ways 28 (i.e., SAMAs) of reducing that risk. Common ways of reducing risk are changes to components, 29 systems, procedures, and training. Entergy initially identified 231 and 237 potential SAMAs for 30 IP2 and IP3, respectively. For each unit, Entergy performed an initial screening in which it 31 eliminated SAMAs that are not applicable to IP2 and IP3 because of design differences, have 32 already been implemented at IP2 and IP3, or are similar in nature and could be combined with 33 another SAMA candidate. This screening reduced the list of potential SAMAs to 68 for IP2 and Draft NUREG-1437, Supplement 38 5-4 December 2008 OAG10001366_00285
Environmental Impacts of Postulated Accidents 1 62 for IP3.
2 In the third step, Entergy estimated the benefits and the costs associated with each of the 3 remaining SAMAs. Estimates were made of how much each SAMA could reduce risk. Those 4 estimates were developed in terms of dollars in accordance with NRC guidance for performing 5 regulatory analyses (NRC 1997). The cost of implementing the proposed SAMAs also was 6 estimated.
7 Finally, in the fourth step, the costs and benefits of each of the remaining SAMAs were 8 compared to determine whether the SAMA was cost beneficial, meaning the benefits of the 9 SAMA were greater than the cost (a positive cost benefit). Entergy concluded in its ER that 10 several of the SAMAs evaluated for each unit are potentially cost beneficial (Entergy 2007b).
11 However, in response to NRC staff inquiries regarding estimated benefits for certain SAMAs 12 and lower cost alternatives, several additional potentially cost-beneficial SAMAs were identified 13 (Entergy 2008a). The NRC staff identifies potentially cost-beneficial SAMAs in Section 5.2.5.
14 The potentially cost-beneficial SAMAs do not relate to adequately managing the effects of aging 15 during the period of extended operation; therefore, they need not be implemented as part of 16 license renewal pursuant to 10 CFR Part 54, "Requirements for Renewal of Operating Licenses 17 for Nuclear Power Plants." Entergy's SAMA analyses and the NRC's review are discussed in 18 more detail below.
19 5.2.2 Estimate of Risk 20 Entergy submitted an assessment of SAMAs for IP2 and IP3 as part of the ER (Entergy 2007b).
21 This assessment was based on the most recent IP2 and IP3 PSA available at that time, a 22 plant-specific offsite consequence analysis performed using the MELCOR Accident 23 Consequence Code System 2 (MACCS2) computer program, and insights from the IP2 and IP3 24 individual plant examination (Con Ed 1992; NYPA 1994) and individual plant examination of 25 external events (Con Ed 1995 and NYPA 1997).
26 The baseline core damage frequency (CDF) for the purpose of the SAMA evaluation is 27 approximately 1. 79x1 0-5 per year for IP2 and 1.15x10-5 per year for IP3. The CDF values are 28 based on the risk assessment for internally initiated events. Entergy did not include the 29 contributions from external events within the IP2 and IP3 risk estimates; however, it did perform 30 separate assessments of the CDF from external events and did account for the potential risk 31 reduction benefits associated with external events by multiplying the estimated benefits for 32 internal events by a factor of approximately 3.8 for IP2 and 5.5 for IP3 (as discussed in 33 Appendix G, Sections G.2.2 and G.6.2). The breakdown of CDF by initiating event for IP2 and 34 IP3 is provided in Table 5-3.
December 2008 5-5 Draft NUREG-1437, Supplement 38 OAG10001366_00286
Environmental Impacts of Postulated Accidents 1 Table 5-3. IP2 and IP3 Core Damage Frequency IP2 IP3 Initiating Event CDF % CDF %
(Per Year) Contribution (Per Year) Contribution to CDF to CDF Loss of offsite power1 6.7x10-6 38 1.2x10-7 Internal flooding 4.7x1 0-6 26 2.2x10-6 20 Loss-of-coolant accident (LOCA) 1.5x1Q-6 8 2.2x10-6 19 Transients 1 1.2x10-6 7 8.5x10- 7 7
Anticipated transient without scram 9.9x10- 7 6 1.5x10-6 13 7 7 Station blackout 8.5x10- 5 7.2x10- 6 Steam generator tube rupture 7.2x10- 7 4 1.6x10-6 14 Loss of component cooling water 5.8x10- 7 3 1.1x10-7 <1 7 7 Loss of nonessential service water 3.0x10- 2 2.8x10- 2 interfacing systems LOCA Reactor vessel rupture 1.5x10-7 <1 1.5x10-7 Loss of 125 volts direct current power 1.0x10-7 <1 1.0x10-7 <1 Total loss of service water system 5.8x10-8 <1 1.0x10-6 9 Loss of essential service water 4.4x10-8 <1 5.4x10- 7 5 1.9x10-1O <1 1.9x10-8 <1 Total CDF (internal events) 1.79x10-5 100 1.15x10-5 100 I Contributions from SBO and ATWS events are noted separately and not included in the reported values for loss of offsite ~ower or transients.
2 As shown in Table 5-3, for IP2, loss of offsite power sequences, including station blackout 3 (S80) events, and internal flooding initiators are the dominant contributors to CDF. For IP3, 4 internal flooding initiators, loss-of-coolant accidents (LOCAs), steam generator tube rupture 5 (SGTR) events, and anticipated transient without scram (A TWS) events are the dominant 6 contributors to CDF. The differences in the CDF contributions are attributed, in large part, to 7 several significant differences between the IP2 and IP3 units.
8 Entergy estimated the dose to the population within 80 kilometers (50 miles) of the IP2 and IP3 9 site to be approximately 0.22 person-sievert (Sv) (22 person-rem) per year for IP2, and 0.24 Sv 10 (24 person-rem) per year for IP3. The breakdown of the total population dose by containment 11 failure mode is summarized in Table 5-4. SGTR events and late containment failures, caused 12 by gradual overpressurization by steam and noncondensable gases, dominate the population 13 dose risk for both units.
14 The NRC staff has reviewed Entergy's data and evaluation methods and concludes that the 15 quality of the risk analyses is adequate to support an assessment of the risk reduction potential 16 for candidate SAMAs. Accordingly, the staff based its assessment of offsite risk on the CDFs Draft NUREG-1437, Supplement 38 5-6 December 2008 OAG10001366_00287
Environmental Impacts of Postulated Accidents 1 and offsite doses reported by Entergy.
2 Table 5-4. Breakdown of Population Dose by Containment Failure Mode IP2 IP3 Population Population Containment Failure Mode Dose (Person- Dose 1 % %
Rem Per (Person-Contribution 1 Contribution Year) Rem Per Year)
Intact Containment <0.1 <1 <0.1 <1 Basemat Melt-through 1.1 5 0.6 3 Gradual Overpressure 7.4 34 4.4 18 Late Hydrogen Burns 0.9 4 0.6 2 Early Hydrogen Burns 2.1 10 0.8 3 In-Vessel Steam Explosion 0.1 0.1 0 Reactor Vessel Rupture 1.0 5 0.4 2 Interfacing System LOCA 1.6 7 1.1 4 SGTR 7.7 35 16.6 68 Total 22.0 100 24.3 100 lOne person-rem = 0.01 person-sievert 3 5.2.3 Potential Plant Improvements 4 Once the dominant contributors to plant risk were identified, Entergy searched for ways to 5 reduce that risk. In identifying and evaluating potential SAMAs, Entergy considered insights 6 from the plant-specific PSA and SAMA analyses performed for other operating plants that have 7 submitted license renewal applications. Entergy identified 231 and 237 potential risk-reducing 8 improvements (SAMAs) to plant components, systems, procedures, and training for IP2 and 9 IP3, respectively.
10 For IP2, Entergy removed all but 68 of the SAMAs from further consideration because they are 11 not applicable to IP2 as a result of design differences, have already been implemented at IP2, 12 or are similar in nature and could be combined with another SAMA candidate. For IP3, all but 13 62 of the SAMAs were removed from further consideration based on similar criteria. A detailed 14 cost-benefit analysis was performed for each of the remaining SAMAs.
15 The staff concludes that Entergy used a systematic and comprehensive process for identifying 16 potential plant improvements for IP2 and IP3, and that the set of potential plant improvements 17 identified by Entergy is reasonably comprehensive and, therefore, acceptable.
December 2008 5-7 Draft NUREG-1437, Supplement 38 OAG10001366_00288
Environmental Impacts of Postulated Accidents 1 5.2.4 Evaluation of Risk Reduction and Costs of Improvements 2 Entergy evaluated the risk-reduction potential of the remaining candidate SAMAs that were 3 applicable to each unit (68 for IP2 and 62 for IP3). The SAMA evaluations were performed 4 using realistic assumptions with some conservatism.
5 Entergy estimated the costs of implementing the candidate SAMAs through the application of 6 engineering judgment and the use of other licensees' estimates for similar improvements. The 7 cost estimates conservatively did not include the cost of replacement power during extended 8 outages required to implement the modifications, nor did they account for inflation.
9 The staff reviewed Entergy's basis for calculating the risk reduction for the various plant 10 improvements and concludes that the rationale and assumptions for estimating risk reduction 11 are reasonable and generally conservative (i.e., the estimated risk reduction is higher than what 12 would actually be realized). Accordingly, the staff based its estimates of averted risk for the 13 various SAMAs on Entergy's risk reduction estimates.
14 The staff reviewed the basis for the applicant's cost estimates. For certain improvements, the 15 staff also compared the cost estimates to estimates developed elsewhere for similar 16 improvements, including estimates developed as part of other licensees' analyses of SAMAs for 17 operating reactors and advanced light-water reactors. The staff found the cost estimates to be 18 reasonable and generally consistent with estimates provided in support of other plants' 19 analyses.
20 The staff concludes that the risk reduction and the cost estimates provided by Entergy are 21 sufficient and appropriate for use in the SAMA evaluation.
22 5.2.5 Cost-Benefit Comparison 23 The cost-benefit analysis performed by Entergy was based primarily on NUREG/BR-0184, 24 "Regulatory Analysis Technical Evaluation Handbook" (NRC 1997) and was executed 25 consistent with this guidance. NUREG/BR-0058, "Regulatory Analysis Guidelines of the U.S.
26 Nuclear Regulatory Commission" (NRC 2004), has recently been revised to reflect the agency's 27 revised policy on discount rates. Revision 4 of NUREG/BR-0058 states that two sets of 28 estimates should be developed-one at 3 percent and one at 7 percent (NRC 2004). Entergy 29 provided both sets of estimates (Entergy 2007b).
30 As described in Section G.6.1, Entergy identified 10 potentially cost-beneficial SAMAs (5 for IP2 31 and 5 for IP3) in the baseline analysis (using a 7-percent discount rate) and sensitivity analysis 32 (using a 3-percent discount rate) contained in the ER. Based on consideration of analysis 33 uncertainties, Entergy identified two additional potentially cost-beneficial SAMAs for IP2 in the 34 ER (lP2 SAMAs 44 and 56).
Draft NUREG-1437, Supplement 38 5-8 December 2008 OAG10001366_00289
Environmental Impacts of Postulated Accidents 1 In response to an NRC staff request, Entergy provided the results of a revised uncertainty 2 analysis in which the impact of lost tourism and business was accounted for in the baseline 3 analysis (rather than as a separate sensitivity case) (Entergy 2008a). The revised uncertainty 4 analysis resulted in the identification of two additional potentially cost-beneficial SAMAs for IP2 5 (I P2 SAMAs 9 and 53) and one additional potentially cost-beneficial SAMA for IP3 (I P3 SAMA 6 53).
7 The potentially cost-beneficial SAMAs for IP2 include the following:
8
- SAMA 9-Create a reactor cavity flooding system to reduce the impact of core-concrete 9 interaction from molten core debris following core damage and vessel failure (cost 10 beneficial in revised analysis, with uncertainties).
11
- SAMA 28-Provide a portable diesel-driven battery charger to improve direct current 12 (dc) power reliability. Safety-related disconnect would be used to change a selected 13 battery. This modification would enhance the long-term operation of the turbine-driven 14 auxiliary feed water (AFW) pump on battery depletion.
15
- SAMA 44-Use fire water as backup for steam generator inventory to increase the 16 availability of steam generator water supply to ensure adequate inventory for the 17 operation of the turbine-driven AFW pump during SBO events (cost beneficial with 18 uncertainties).
19
- SAMA 53-Keep both pressurizer power-operated relief valve block valves open. This 20 modification would reduce the CDF contribution from loss of secondary heat sink by 21 improving the availability of feed and bleed (cost beneficial in revised analysis, with 22 uncertainties).
23
- SAMA 54-Install a flood alarm in the 480-volt (V) alternating current (ac) switchgear 24 room to mitigate the occurrence of internal floods inside the 480-V ac switchgear room.
25
- SAMA 56-Keep residual heat removal (RHR) heat exchanger discharge valves, motor-26 operated valves 746 and 747, normally open. This procedure change would reduce the 27 CDF contribution from transients and LOCAs (cost beneficial with uncertainties).
28
- SAMA 60-Provide added protection against flood propagation from stairwell 4 into the 29 480-V ac switchgear room to reduce the CDF contribution from flood sources within 30 stairwell 4 adjacent to the 480-V ac switchgear room.
31
- SAMA 61-Provide added protection against flood propagation from the deluge room 32 into the 480-V ac switchgear room to reduce the CDF contribution from flood sources 33 within the deluge room adjacent to the 480-V ac switchgear room.
34
- SAMA 65-Upgrade the alternate safe shutdown system to allow timely restoration of 35 reactor coolant pump seal injection and cooling from events that cause loss of power 36 from the 480-V ac vital buses.
37 The potentially cost-beneficial SAMAs for IP3 include the following:
December 2008 5-9 Draft NUREG-1437, Supplement 38 OAG10001366_00290
Environmental Impacts of Postulated Accidents 1
- SAMA 30-Provide a portable diesel-driven battery charger to improve dc power 2 reliability. Safety-related disconnect would be used to change a selected battery. This 3 modification would enhance the long-term operation of the turbine-driven AFW pump on 4 battery depletion.
5
- SAMA 52-Proceduralize opening the city water supply valve for alternative AFW 6 system pump suction to enhance the availability of AFW system.
7
- SAMA 53-Install an excess flow valve to reduce the risk associated with hydrogen 8 explosions inside the turbine building or primary auxiliary building (cost beneficial in 9 revised analysis, with uncertainties).
10
- SAMA 55-Provide the capability of powering one safety injection pump or RHR pump 11 using the Appendix R diesel (MCC 312A) to enhance reactor cooling system injection 12 capability during events that cause loss of power from the 480-V ac vital buses.
13
- SAMA 61-Upgrade the alternate safe-shutdown system to allow timely restoration of 14 reactor coolant pump seal injection and cooling from events that cause loss of power 15 from the 480-V ac vital buses.
16
- SAMA 62-lnstall a flood alarm in the 480-V ac switchgear room to mitigate the 17 occurrence of internal floods inside the 480-V ac switchgear room.
18 In response to an NRC staff inquiry regarding estimated benefits for certain SAMAs and lower 19 cost alternatives, one additional potentially cost-beneficial SAMA was identified (applicable to 20 SGTR events in both units; unnumbered for each unit because the applicant did not initially 21 identify them), and one SAMA that was previously identified as potentially cost beneficial was 22 found to be no longer cost beneficial based on correction of an error in the ER (lP3 SAMA 30).
23 The staff concludes that, with the exception of the potentially cost-beneficial SAMAs discussed 24 above, the costs of the SAMAs evaluated would be higher than the associated benefits.
25 5.2.6 Conclusions 26 The staff reviewed Entergy's analysis and concluded that the methods used, and the 27 implementation of those methods, were sound. The treatment of SAMA benefits and costs 28 support the general conclusion that the SAMA evaluations performed by Entergy are reasonable 29 and sufficient for the license renewal submittal. Although the treatment of SAMAs for external 30 events was somewhat limited, the likelihood of there being cost-beneficial enhancements in this 31 area was minimized by improvements that have been realized as a result of the IPEEE process 32 and inclusion of a multiplier to account for external events.
33 Based on its review of the SAMA analysis, the staff concurs with Entergy's identification of 34 areas in which risk can be further reduced in a cost-beneficial manner through the 35 implementation of all or a subset of potentially cost-beneficial SAMAs. Given the potential for 36 cost-beneficial risk reduction, the staff considers that further evaluation of these SAMAs by 37 Entergy is warranted. However, none of the potentially cost-beneficial SAMAs relate to 38 adequately managing the effects of aging during the period of extended operation. Therefore, 39 they need not be implemented as part of the license renewal pursuant to 10 CFR Part 54.
Draft NUREG-1437, Supplement 38 5-10 December 2008 OAG10001366_00291
Environmental Impacts of Postulated Accidents 1 5.3 References 2 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of 3 Production and Utilization Facilities."
4 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 5 Protection Regulations for Domestic Licensing and Related Regulatory Functions."
6 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for 7 Renewal of Operating Licenses for Nuclear Power Plants."
8 10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, "Reactor Site 9 Criteria."
10 Consolidated Edison (Con Ed). 1992. Letter from Stephen B. Bram to U.S. Nuclear Regulatory 11 Commission,
Subject:
Generic Letter 88-20, Supplement 1: Individual Plant Examination (lPE) 12 for Severe Accident Vulnerabilities-10 CFR 50.54, Indian Point Unit No.2, August 12, 1992.
13 Consolidated Edison (Con Ed). 1995. Letter from Stephen E. Quinn to U.S. Nuclear Regulatory 14 Commission,
Subject:
Final Response to Generic Letter 88-20, Supplement 4: Submittal of 15 Individual Plant Examination of External Events (lPEEE) for Severe Accident Vulnerabilities, 16 Indian Point Unit No.2, December 6, 1995.
17 Entergy Nuclear Operations, Inc. (Entergy). 2007a. "Applicant's Environment Report, 18 Operating License Renewal Stage." (Appendix E to Indian Point, Units 2 and 3, License 19 Renewal Application). April 23, 2007. Agencywide Documents Access and Management 20 System (ADAMS) Accession No. ML071210530.
21 Entergy Nuclear Operations, Inc. (Entergy). 2007b. Letter from Fred Dacimo to U.S. Nuclear 22 Regulatory Commission,
Subject:
Indian Point Energy Center License Renewal Application, 23 NL-07-039, April 23, 2007. ADAMS Accession No. ML071210512.
24 Entergy Nuclear Operations, Inc. (Entergy). 2008. Letter from Fred Dacimo to U.S. Nuclear 25 Regulatory Commission,
Subject:
Reply to Request for Additional Information Regarding 26 License Renewal Application-Severe Accident Mitigation Alternatives Analysis, NL-08-028, 27 May 22,2008. ADAMS Accession No. ML080420264.
28 Entergy Nuclear Operations, Inc. (Entergy). 2008b. Letter from Fred Dacimo to U.S. Nuclear 29 Regulatory Commission,
Subject:
Supplemental Reply to Request for Additional Information 30 Regarding License Renewal Application-Severe Accident Mitigation Alternatives Analysis, NL-31 08-086, May 22,2008. ADAMS Accession No. ML081490336.
32 New York Power Authority (NYPA). 1994. Letter from William A. Josiger to U.S. Nuclear 33 Regulatory Commission,
Subject:
Indian Point 3 Nuclear Power Plant Individual Plant 34 Examination for Internal Events, June 30, 1994.
35 New York Power Authority (NYPA). 1997. Letter from James Knubel to U.S. Nuclear 36 Regulatory Commission,
Subject:
Indian Point 3 Nuclear Power Plant Individual Plant 37 Examination of External Events (lPEEE), September 26, 1997.
38 Nuclear Regulatory Commission (NRC). 1996. "Generic Environmental Impact Statement for 39 License Renewal of Nuclear Power Plants." NUREG-1437, Volumes 1 and 2, Washington, DC.
December 2008 5-11 Draft NUREG-1437, Supplement 38 OAG10001366_00292
Environmental Impacts of Postulated Accidents 1 Nuclear Regulatory Commission (NRC). 1997. "Regulatory Analysis Technical Evaluation 2 Handbook." NUREG/BR-0184, Washington, DC.
3 Nuclear Regulatory Commission (NRC). 1999. "Generic Environmental Impact Statement for 4 License Renewal of Nuclear Plants, Main Report," Section 6.3, "Transportation," Table 9.1, 5 "Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final 6 Report." NUREG-1437, Volume 1, Addendum 1, Washington, DC.
7 Nuclear Regulatory Commission (NRC). 2004. "Regulatory Analysis Guidelines of the U.S.
8 Nuclear Regulatory Commission." NUREG/BR-0058, Rev. 4, Washington, DC. ADAMS 9 Accession No. ML042820192.
Draft NUREG-1437, Supplement 38 5-12 December 2008 OAG10001366_00293
1 6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL 2 CYCLE AND SOLID WASTE MANAGEMENT 3 Environmental issues associated with the uranium fuel cycle and solid waste management are 4 discussed in NUREG-1437, Volumes 1 and 2, "Generic Environmental Impact Statement for 5 License Renewal of Nuclear Plants" (hereafter referred to as the GElS) (NRC 1996, 1999.)(1) 6 The GElS includes a determination of whether the analysis of the environmental issue could be 7 applied to all plants and whether additional mitigation measures would be warranted. Issues 8 are then assigned a Category 1 or a Category 2 designation. As set forth in the GElS, 9 Category 1 issues are those that meet all of the following criteria:
10 (1) The environmental impacts associated with the issue have been determined to apply 11 either to all plants or, for some issues, to plants having a specific type of cooling system 12 or other specified plant or site characteristics.
13 (2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 14 the impacts (except for collective offsite radiological impacts from the fuel cycle and from 15 high-level waste and spent fuel disposal).
16 (3) Mitigation of adverse impacts associated with the issue has been considered in the 17 analysis, and it has been determined that additional plant-specific mitigation measures 18 are likely not to be sufficiently beneficial to warrant implementation.
19 For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 20 required unless new and significant information is identified.
21 Category 2 issues are those that do not meet one or more of the criteria for Category 1; 22 therefore, additional plant-specific review of these issues is required.
23 This chapter addresses the issues that are related to the uranium fuel cycle and solid waste 24 management that are listed in Table 8-1 of Appendix 8 to Subpart A, "Environmental Effect of 25 Renewing the Operating License of a Nuclear Power Plant," of Title 10, Part 51, "Environmental 26 Protection Regulations for Domestic Licensing and Related Regulatory Functions," of the Code 27 of Federal Regulations (10 CFR Part 51) and are applicable to the Indian Point Nuclear 28 Generating Unit Nos. 2 and 3 (lP2 and IP3). The generic potential radiological and 29 nonradiological environmental impacts of the uranium fuel cycle and transportation of nuclear 30 fuel and wastes are described in detail in the GElS based, in part, on the generic impacts 31 provided in 10 CFR 51.51(b), Table S-3, "Table of Uranium Fuel Cycle Environmental Data,"
32 and 10 CFR 51.52(c), Table S-4, "Environmental Impact of Transportation of Fuel and Waste to 33 and from One Light-Water-Cooled Nuclear Power Reactor." The U.S. Nuclear Regulatory 34 Commission (NRC) staff also addresses the impacts from radon-222 and technetium-99 in the 35 GElS.
(1)
The GElS was originally issued in 1996. Addendum 1 to the GElS was issued in 1999. Hereafter, all references to the GElS include the GElS and its Addendum 1.
December 2008 6-1 Draft NUREG-1437, Supplement 38 OAG10001366_00294
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 6.1 The Uranium Fuel Cycle 2 Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, that are applicable to 3 IP2 and IP3 from the uranium fuel cycle and solid waste management are listed in Table 6-1.
4 Table 6-1. Category 1 Issues Applicable to the Uranium Fuel Cycle and Solid Waste 5 Management during the Renewal Term ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Section URANIUM FUEL CYCLE AND WASTE MANAGEMENT Offsite radiological impacts (individual effects from other than the 6.1; 6.2.1; 6.2.2.1; 6.2.2.3; disposal of spent fuel and high-level waste) 6.2.3; 6.2.4; 6.6 Offsite radiological impacts (collective effects) 6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6 Offsite radiological impacts (spent fuel and high-level waste disposal) 6.1; 6.2.2.1; 6.2.2.2; 6.2.3; 6.2.4; 6.6 Nonradiological impacts of the uranium fuel cycle 6.1; 6.2.2.6; 6.2.2.7; 6.2.2.8; 6.2.2.9; 6.2.3; 6.2.4; 6.6 Low-level waste storage and disposal 6.1; 6.2.2.2; 6.4.2; 6.4.3; 6.4.4 Mixed waste storage and disposal 6.1; 6.4.5; 6.6 Onsite spent fuel 6.1; 6.4.6; 6.6 Nonradiological waste 6.1; 6.5; 6.6 Transportation 6.1; 6.3, Addendum 1; 6.6 6 Entergy Nuclear Operations, Inc. (Entergy), stated in the IP2 and IP3 environmental report (ER) 7 (Entergy 2007) that it is not aware of any new and significant information associated with the 8 renewal of the IP2 and IP3 operating licenses, though it did identify leaks to ground water as a 9 potentially new issue. The NRC staff addressed this issue in Sections 2.2.7,4.3, and 4.5 of this 10 draft supplemental environmental impact statement (SEIS). In Section 4.5, the NRC staff 11 concludes that the abnormal liquid releases (leaks) discussed by Entergy in its ER, while new 12 information, are within the NRC's radiation safety standards contained in 10 CFR Part 20 and 13 are not considered to have a significant impact on plant workers, the public, or the environment 14 (i.e., while the information related to spent fuel pool leakage is new, it is not significant). The 15 NRC staff has not identified any new and significant information during its independent review of 16 the IP2 and IP3 ER (Entergy 2007), the site audit, the scoping process, or evaluation of other 17 available information. Therefore, the NRC staff concludes that there are no impacts related to 18 these issues beyond those discussed in the GElS. For these issues, the NRC staff concluded 19 in the GElS that the impacts are SMALL (except for the collective offsite radiological impacts 20 from the fuel cycle and from high-level waste and spent fuel disposal, as discussed below) and 21 that additional plant-specific mitigation measures are not likely to be sufficiently beneficial to be 22 warranted.
23 A brief description of the NRC staff's review and the GElS conclusions, as codified in Table B-1 24 of 10 CFR Part 51, for each of these issues follows:
Draft NUREG-1437, Supplement 38 6-2 December 2008 OAG10001366_00295
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1
- Off-site radiological impacts (individual effects from other than the disposal of spent fuel 2 and high-level waste). Based on information in the GElS, the Commission found the 3 following:
4 Off-site impacts of the uranium fuel cycle have been considered by the 5 Commission in Table S-3 of this part (10 CFR 51.51 (b)). Based on information in 6 the GElS, impacts on individuals from radioactive gaseous and liquid releases 7 including radon-222 and technetium-99 are small.
8 The NRC staff has not identified any new and significant information during its independent 9 review of the IP2 and IP3 ER, the site audit, the scoping process, or evaluation of other 10 available information. Therefore, the NRC staff concludes that there are no offsite radiological 11 impacts (individual effects) of the uranium fuel cycle during the renewal term beyond those 12 discussed in the GElS.
13
- Off-site radiological impacts (collective effects). Based on information in the GElS, the 14 Commission found the following:
15 The 100 year environmental dose commitment to the United States (U.S.)
16 population from the fuel cycle, high level waste and spent fuel disposal excepted, 17 is calculated to be about 14,800 person rem, or 12 cancer fatalities, for each 18 additional 20-year power reactor operating term. Much of this, especially the 19 contribution of radon releases from mines and tailing piles, consists of tiny doses 20 summed over large populations. This same dose calculation can theoretically be 21 extended to include many tiny doses over additional thousands of years as well 22 as doses outside the U.S. The result of such a calculation would be thousands 23 of cancer fatalities from the fuel cycle, but this result assumes that even tiny 24 doses have some statistical adverse health effect which will not ever be mitigated 25 (for example no cancer cure in the next one thousand years), and that these 26 doses projected over thousands of years are meaningful. However, these 27 assumptions are questionable. In particular, science cannot rule out the 28 possibility that there will be no cancer fatalities from these tiny doses. For 29 perspective, the doses are very small fractions of regulatory limits and even 30 smaller fractions of natural background exposure to the same populations.
31 Nevertheless, despite all of the uncertainty, some judgement as to the National 32 Environmental Policy Act of 1969, as amended (NEPA) implications of these 33 matters should be made and it makes no sense to repeat the same judgement in 34 every case. Even taking the uncertainties into account, the Commission 35 concludes that these impacts are acceptable in that these impacts would not be 36 sufficiently large to require the NEPA conclusion, for any plant, that the option of 37 extended operation under 10 CFR Part 54 should be eliminated. Accordingly, 38 while the Commission has not assigned a single level of significance for the 39 collective effects of the fuel cycle, this issue is considered Category 1.
40 The NRC staff has not identified any new and significant information during its independent December 2008 6-3 Draft NUREG-1437, Supplement 38 OAG10001366_00296
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 review of the IP2 and IP3 ER, the NRC staff's site visit, the scoping process, or its evaluation of 2 other available information. Therefore, the NRC staff concludes that there are no offsite 3 radiological impacts (collective effects) from the uranium fuel cycle during the renewal term 4 beyond those discussed in the GElS.
5
- Offsite radiological impacts (spent fuel and high-level waste disposal). Based on 6 information in the GElS, the Commission found the following:
7 For the high level waste and spent fuel disposal component of the fuel cycle, 8 there are no current regulatory limits for off-site releases of radionuclides for the 9 current candidate repository site. However, if we assume that limits are 10 developed along the lines of the 1995 National Academy of Sciences (NAS) 11 report, "Technical Bases for Yucca Mountain Standards" (NAS 1995), and that in 12 accordance with the Commission's Waste Confidence Decision, 10 CFR 51.23, a 13 repository can and likely will be developed at some site which will comply with 14 such limits, peak doses to virtually all individuals will be 100 millirem (mrem) 15 (1 mSv) per year or less. However, while the Commission has reasonable 16 confidence that these assumptions will prove correct, there is considerable 17 uncertainty since the limits are yet to be developed, no repository application has 18 been completed or reviewed, and uncertainty is inherent in the models used to 19 evaluate possible pathways to the human environment. The NAS report 20 indicated that 100 mrem per year should be considered as a starting point for 21 limits for individual doses, but notes that some measure of consensus exists 22 among national and international bodies that the limits should be a fraction of the 23 100 mrem (1 mSv) per year. The lifetime individual risk from 100 mrem annual 24 dose limit is about 3x10-3 .
25 Estimating cumulative doses to populations over thousands of years is more 26 problematic. The likelihood and consequences of events that could seriously 27 compromise the integrity of a deep geologic repository were evaluated by the 28 U.S. Department of Energy (DOE) in the "Final Environmental Impact Statement:
29 Management of Commercially Generated Radioactive Waste," October 1980 30 (DOE 1980). The evaluation estimated the 70-year whole-body dose 31 commitment to the maximum individual and to the regional population resulting 32 from several modes of breaching a reference repository in the year of closure, 33 after 1,000 years, after 100,000 years, and after 100,000,000 years.
34 Subsequently, the NRC and other federal agencies have expended considerable 35 effort to develop models for the design and for the licensing of a high level waste 36 repository, especially for the candidate repository at Yucca Mountain. More 37 meaningful estimates of doses to population may be possible in the future as 38 more is understood about the performance of the proposed Yucca Mountain 39 repository. Such estimates would involve very great uncertainty, especially with 40 respect to cumulative population doses over thousands of years. The standard 41 proposed by the NAS is a limit on maximum individual dose. The relationship of 42 potential new regulatory requirements, based on the NAS report, and cumulative Draft NUREG-1437, Supplement 38 6-4 December 2008 OAG10001366_00297
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 population impacts has not been determined, although the report articulates the 2 view that protection of individuals will adequately protect the population for a 3 repository at Yucca Mountain. However, EPA's generic repository standards in 4 40 CFR Part 191 generally provide an indication of the order of magnitude of 5 cumulative risk to population that could result from the licensing of a Yucca 6 Mountain repository, assuming the ultimate standards will be within the range of 7 standards now under consideration. The standards in 40 CFR Part 191 protect 8 the population by imposing "containment requirements" that limit the cumulative 9 amount of radioactive material released over 10,000 years. Reporting 10 performance standards that will be required by EPA are expected to result in 11 releases and associated health consequences in the range between 10 and 100 12 premature cancer deaths with an upper limit of 1,000 premature cancer deaths 13 world-wide for a 100,000 metric ton (MT) repository.
14 Nevertheless, despite all of the uncertainty, some judgement as to the regulatory 15 NEPA implications of these matters should be made and it makes no sense to 16 repeat the same judgement in every case. Even taking the uncertainties into 17 account, the Commission concludes that these impacts are acceptable in that 18 these impacts would not be sufficiently large to require the NEPA conclusion, for 19 any plant, that the option of extended operation under 10 CFR Part 54 should be 20 eliminated. Accordingly, while the Commission has not assigned a single level of 21 significance for the impacts of spent fuel and high level waste disposal, this issue 22 is considered Category 1.
23 On February 15, 2002, based on a recommendation by the Secretary of the DOE, the President 24 recommended the Yucca Mountain site for the development of a repository for the geologic 25 disposal of spent nuclear fuel and HLW. The U.S. Congress approved this recommendation on 26 July 9, 2002, in Joint Resolution 87, which designated Yucca Mountain as the repository for 27 spent nuclear waste. On July 23, 2002, the President signed Joint Resolution 87 into law; 28 Public Law 107-200, 116 Stat. 735 designates Yucca Mountain as the repository for spent 29 nuclear waste.
30 The NRC staff has not identified any new and significant information during its independent 31 review of the IP2 and IP3 ER, the site audit, the scoping process, or evaluation of other 32 available information. Therefore, the NRC staff concludes that there are no offsite radiological 33 impacts related to spent fuel and high-level waste disposal during the renewal term beyond 34 those discussed in the GElS.
35
- Nonradiological impacts of the uranium fuel cycle. Based on information in the GElS, 36 the Commission found the following:
37 The nonradiological impacts of the uranium fuel cycle resulting from the renewal 38 of an operating license for any plant are found to be small.
39 The NRC staff has not identified any new and significant information during its independent 40 review of the IP2 and IP3 ER, the NRC staff's site visit, the scoping process, or its evaluation of 41 other available information. Therefore, the NRC staff concludes that there are no December 2008 6-5 Draft NUREG-1437, Supplement 38 OAG10001366_00298
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 nonradiological impacts of the uranium fuel cycle during the renewal term beyond those 2 discussed in the GElS.
3
- Low-level waste storage and disposal. Based on information in the GElS, the 4 Commission found the following:
5 The comprehensive regulatory controls that are in place and the low public doses 6 being achieved at reactors ensure that the radiological impacts to the 7 environment will remain small during the term of a renewed license. The 8 maximum additional on-site land that may be required for low-level waste storage 9 during the term of a renewed license and associated impacts will be small.
10 Nonradiological impacts on air and water will be negligible. The radiological and 11 nonradiological environmental impacts of long-term disposal of low-level waste 12 from any individual plant at licensed sites are small. In addition, the Commission 13 concludes that there is reasonable assurance that sufficient low-level waste 14 disposal capacity will be made available when needed for facilities to be 15 decommissioned consistent with NRC decommissioning requirements.
16 The NRC staff has not identified any new and significant information during its independent 17 review of the IP2 and IP3 ER, the site audit, the scoping process, or evaluation of other 18 available information. Therefore, the NRC staff concludes that there are no impacts of low-level 19 waste storage and disposal associated with the renewal term beyond those discussed in the 20 GElS.
21
- Mixed waste storage and disposal. Based on information in the GElS, the Commission 22 found the following:
23 The comprehensive regulatory controls and the facilities and procedures that are 24 in place ensure proper handling and storage, as well as negligible doses and 25 exposure to toxic materials for the public and the environment at all plants.
26 License renewal will not increase the small, continuing risk to human health and 27 the environment posed by mixed waste at all plants. The radiological and 28 nonradiological environmental impacts of long-term disposal of mixed waste from 29 any individual plant at licensed sites are small. In addition, the Commission 30 concludes that there is reasonable assurance that sufficient mixed waste 31 disposal capacity will be made available when needed for facilities to be 32 decommissioned consistent with NRC decommissioning requirements.
33 The NRC staff has not identified any new and significant information during its independent 34 review of the IP2 and IP3 ER, the site audit, the scoping process, or evaluation of other 35 available information. Therefore, the NRC staff concludes that there are no impacts of mixed 36 waste storage and disposal associated with the renewal term beyond those discussed in the 37 GElS.
38
- Onsite spent fuel. Based on information in the GElS, the Commission found the 39 following:
40 The expected increase in the volume of spent fuel from an additional 20 years of Draft NUREG-1437, Supplement 38 6-6 December 2008 OAG10001366_00299
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 operation can be safely accommodated on site with small environmental effects 2 through dry or pool storage at all plants if a permanent repository or monitored 3 retrievable storage is not available.
4 The NRC staff has not identified any new and significant information during its independent 5 review of the IP2 and IP3 ER, the site audit, the scoping process, or evaluation of other 6 available information. Therefore, the NRC staff concludes that there are no impacts of onsite 7 spent fuel associated with license renewal beyond those discussed in the GElS.
8
- Nonradiological waste. Based on information in the GElS, the Commission found the 9 following:
10 No changes to generating systems are anticipated for license renewal. Facilities 11 and procedures are in place to ensure continued proper handling and disposal at 12 all plants.
13 The NRC staff has not identified any new and significant information during its independent 14 review of the IP2 and IP3 ER, the site, the scoping process, or evaluation of other available 15 information. Therefore, the NRC staff concludes that there are no nonradiological waste 16 impacts during the renewal term beyond those discussed in the GElS.
17
- Transportation. Based on information contained in the GElS, the Commission found the 18 following:
19 The impacts of transporting spent fuel enriched up to 5 percent uranium-235 with 20 average burnup for the peak rod to current levels approved by NRC up to 62,000 21 megawatt-days per metric ton of uranium (MWd/MTU) and the cumulative 22 impacts of transporting high-level waste to a single repository, such as Yucca 23 Mountain, Nevada are found to be consistent with the impact values contained in 24 10 CFR 51.52(c), Summary Table S-4-Environmentallmpact of Transportation 25 of Fuel and Waste to and from One Light-Water-Cooled Nuclear Power Reactor.
26 If fuel enrichment or burnup conditions are not met, the applicant must submit an 27 assessment of the implications for the environmental impact values reported in 28 10 CFR 51.52.
29 IP2 and IP3 meet the fuel-enrichment and burnup conditions set forth in Addendum 1 to the 30 GElS. The NRC staff has not identified any new and significant information during its 31 independent review of the IP2 and IP3 ER, the site audit, the scoping process, or evaluation of 32 other available information. Therefore, the NRC staff concludes that there are no impacts of 33 transportation associated with license renewal beyond those discussed in the GElS.
34 There are no Category 2 issues for the uranium fuel cycle and solid waste management.
35 6.2 Greenhouse Gas Emissions 36 6.2.1 Introduction 37 The NRC staff received many comments during the scoping period from individuals and groups December 2008 6-7 Draft NUREG-1437, Supplement 38 OAG10001366_00300
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 regarding the impact of the proposed relicensing of IP2 and IP3 on the release of carbon dioxide 2 (C0 2) and other greenhouse gas (GHG) emissions relative to potential alternative energy 3 sources, including fossil fuels, renewable energy sources, and conservation programs.
4 6.2.2 IP2 and IP3 5 The NRC staff has not identified any studies specifically addressing GHGs produced by IP2 and 6 IP3 or their fuel cycles. Although Entergy developed a study identifying gas emissions that 7 would result if IP2 and IP3 were to be decommissioned and their generating capacity replaced 8 with fossil-fuel based sources (Entergy Nuclear Northeast 2002), Entergy did not evaluate GHG 9 emissions related to the existing facility. This study evaluated emissions of CO 2 , sulfur dioxide, 10 nitrogen oxides, particulates (i.e., PM 1O), carbon monoxide, and volatile organic compounds 11 (VOCs). The study was intended as an evaluation of the impact of IP2 and IP3 shutdown on air 12 quality in the local New York City area, rather than an evaluation of the impact of IP2 and IP3 13 shutdown on global GHG emissions.
14 6.2.3 GElS 15 The GElS provided only qualitative discussions regarding the GHG impacts of the nuclear fuel 16 cycle. In the analysis of potential alternatives to nuclear power plant relicensing, the GElS 17 referenced CO2 emissions as one of the substantial operating impacts associated with new 18 coal-fired and oil-fired power plants, although no direct quantitative assessment of GHG 19 emissions was presented. The GElS also did not address GHG impacts of the nuclear fuel 20 cycle relative to other potential alternatives, such as natural gas, renewable energy sources, or 21 conservation programs.
22 6.2.4 Other Studies 23 Since the development of the GElS, extensive further research into the relative volumes of 24 GHGs emitted by nuclear and other electricity generating methods has been performed. In 25 support of the analysis for this draft SEIS, the NRC staff performed a survey of the recent 26 literature on the subject. Based on this survey, the NRC staff found that estimates and 27 projections of the carbon footprint of the nuclear power lifecycle vary widely, and considerable 28 debate exists regarding the relative impacts of nuclear and other electricity generation methods 29 on GHG emissions. These recent studies take two different forms:
30 (1) qualitative discussions of the potential use of nuclear power to address GHG emissions 31 and global warming 32 (2) technical analyses and quantitative estimates of the actual amount of GHGs generated 33 by the nuclear fuel cycle 34 6.2.5 Qualitative 35 The qualitative studies primarily consist of broad, large-scale public policy or investment 36 evaluations of whether an expansion of nuclear power is likely to be a technically, economically, 37 and/or politically feasible means of achieving global GHG reductions. Examples of the studies 38 that commenters referenced during the scoping period or that the NRC staff identified during the Draft NUREG-1437, Supplement 38 6-8 December 2008 OAG10001366_00301
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 subsequent literature search include the following:
2
- Studies conducted to evaluate whether investments in nuclear power in developing 3 countries should be accepted as a flexibility mechanism to assist industrialized nations in 4 achieving their GHG reduction goals under the Kyoto Protocols (Schneider 2000; IAEA 5 2000; NEA 2002; and NIRSIWISE 2005). Ultimately, the parties did not approve nuclear 6 power as a component under the Clean Development Mechanism (COM), but not 7 because of concerns about GHGs from the nuclear fuel cycle (NEA 2002). Instead, it 8 was eliminated from consideration for the COM because it was not considered to meet 9 the criterion of helping developing nations achieve sustainable development because of 10 safety and waste disposal concerns (NEA 2002).
11
- Analyses developed to assist governments (including the U.S. Government) in making 12 long-term investment and public policy decisions in nuclear power (Keepin 1988; Hagen 13 et al. 2001; MIT 2003).
14 Although the qualitative studies sometimes reference and critique the rationale contained in the 15 existing quantitative estimates of GHGs produced by the nuclear fuel cycle, their conclusions 16 generally rely heavily on discussions of other aspects of nuclear policy decisions and 17 investment such as safety, cost, waste generation, and political acceptability. Therefore, these 18 studies are not directly applicable to the evaluation of GHG emissions that will be associated 19 with the proposed relicensing of IP2 and IP3.
20 6.2.6 Quantitative 21 A large number of technical studies, including calculations and estimates of the amount of 22 GHGs emitted by nuclear and other power generation options, are available in the literature.
23 Examples of these studies include Mortimer (1990), Andseta et al. (1998), Spadaro (2000),
24 Storm van Leeuwen and Smith (2005), Fritsche (2006), POST (2006), AEA (2006), Weisser 25 (2006), Fthenakis and Kim (2007), and Dones (2007).
26 Comparison of the different studies is difficult because the assumptions and components of the 27 lifecycles included within each study vary widely. Examples of differing assumptions that make 28 comparability between the studies difficult include the following:
29
- the type of energy source that may be used to mine uranium deposits in the future 30
- the amount of reprocessing of nuclear fuel that will be performed in the future 31
- the type of energy source and process that might be used to enrich uranium in the future 32
- different calculations regarding the grade and volume of recoverable uranium deposits in 33 the world 34
- different estimates regarding the GHG emissions associated with declining grades of 35 recoverable coal, natural gas, and oil deposits 36
- the release of GHG gases other than CO2 , including the conversion of the masses of 37 these gases into grams of CO2 equivalents per kilowatt-hour (g Ceq IkWh)
December 2008 6-9 Draft NUREG-1437, Supplement 38 OAG10001366_00302
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1
- the technology to be used for future fossil fuel power systems, including cogeneration 2 systems 3
- the projected capacity factors assumed for the different generation alternatives 4
- the different types of nuclear reactors used currently and in the projected future (light 5 water reactor, pressurized-water reactor, Canadian deuterium-natural uranium reactor, 6 breeder) 7 In addition, studies are inconsistent in their application of fulilifecycle analyses, including plant 8 construction, decommissioning, and resource extraction (uranium ore, fossil fuel). For instance, 9 Storm van Leeuwen and Smith (2005) present comparisons of GHG emissions from nuclear 10 versus natural gas that incorporate GHG emissions associated with nuclear plant construction 11 and decommissioning in the values used for comparison.
12 In the case of the proposed IP2 and IP3 relicensing, the relicensing action will not involve 13 additional GHG emissions associated with construction because the facility already exists. In 14 addition, the proposed relicensing action will not involve additional GHG emissions associated 15 with facility decommissioning, because that decommissioning must occur whether the facility is 16 relicensed or not. In many of these studies, the contribution of GHG emissions from facility 17 construction and decommissioning cannot be separated from the other lifecycle GHG emissions 18 that would be associated with IP2 and IP3 relicensing. Therefore, these studies overestimate 19 the GHG emissions attributed to the proposed IP2 and IP3 relicensing action.
20 In an early study on the subject, Dr. Nigel Mortimer conducted an analysis of the GHG 21 emissions resulting from the nuclear fuel cycle in 1990 (Mortimer 1990). In this study, Mortimer 22 stressed that the GHG implications of the nuclear fuel cycle were substantially related to the ore 23 grade of uranium that must be mined to support nuclear power generation. Using ore grades 24 that were current as of 1990, this study concluded that nuclear power offered a dramatic 25 reduction in GHG emissions over conventional coal-fired power plants over an estimated 26 35-year lifecycle. The analysis estimated that a nuclear power plant would generate 230,000 27 tons (209,000 metric tonnes (MT)) of CO 2 over a 35-year life span, or about 3.9 percent of the 28 5,912,000 tons (5,363,000 MT) that an equivalent coal-fired plant would generate (Mortimer 29 1990). The study also projected that most of this 230,000 tons (209,000 MT) of CO 2 resulted 30 from the use of a coal-fired plant to perform uranium enrichment by gaseous diffusion, and that 31 using nuclear power and alternative enrichment methods in the future could reduce the amount 32 to 21,000 tons (19,000 MT) (Mortimer 1990).
33 Mortimer's study went on to demonstrate that the GHG impact of the nuclear fuel cycle would 34 increase as the grade of uranium ore mined dropped, and that the net emissions of CO 2 from 35 the nuclear and coal-fired alternatives would become equal once uranium ore grades reached 36 0.01-percent uranium oxide. However, Mortimer does not address differences in energy 37 consumption from future extraction and enrichment methods, the potential for higher grade 38 resource discovery, and technology improvements. Based on his cutoff ore grade and 39 projections of ore reserves, Mortimer estimated GHG emissions of nuclear and natural gas 40 generation would occur after a period of 23 years (Mortimer 1990). The analysis also compared 41 GHG emissions associated with the nuclear fuel cycle with other electricity generation and 42 efficiency options, including hydroelectric, wind, tidal power, and new types of insulation and 43 lighting (but not including natural gas). The conclusion was that nuclear power had lower GHG Draft NUREG-1437, Supplement 38 6-10 December 2008 OAG10001366_00303
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 emissions compared to coal, but that GHG emissions associated with the nuclear fuel cycle still 2 exceeded those for renewable generation and conservation options (Mortimer 1990).
3 The Mortimer (1990) study is not presented here to support a definitive conclusion regarding 4 whether nuclear energy produces fewer GHG emissions than other alternatives and similar 5 discussions will not be presented in this draft SEIS for each of the available studies. Instead, 6 the NRC staff presents the Mortimer (1990) study to provide an example of the types of 7 considerations underlying the calculations and arguments presented by the various authors.
8 Almost every existing study has been critiqued, and its assumptions challenged, by later 9 authors. Therefore, no single study has been selected to represent definitive results in this draft 10 SEIS. Instead, the results from a variety of the studies are presented in Tables 6-2,6-3, and 11 6-4 to provide a weight-of-evidence argument comparing the relative GHG emissions resulting 12 from the proposed IP2 and IP3 relicensing compared to the potential alternative use of coal-fired 13 plants, natural gas-fired plants, and renewable energy sources.
14 6.2.7 Summary of Nuclear Greenhouse Gas Emissions Compared to Coal 15 Because coal is the fuel most commonly used to generate electricity in the United States, and 16 the burning of coal results in the largest emissions of GHGs for any of the likely alternatives to 17 nuclear power, most of the available quantitative studies have focused on comparisons of the 18 relative GHG emissions of nuclear to coal-fired generation. The quantitative estimates of the 19 GHG emissions associated with the nuclear fuel cycle, as compared to an equivalent coal-fired 20 plant, are presented in Table 6-2.
21 Table 6-2. Nuclear GHG Emissions Compared to Coal Source GHG Emission Results Mortimer 1990 Nuclear-230,000 tons CO 2 Coal-5,912,000 tons CO 2 Note: Future GHG emissions from nuclear to increase because of declining ore grade Andseta et al. Nuclear energy produces 1.4 percent of the GHG emissions compared to 1998 coal.
Note: Future reprocessing and use of nuclear-generated electrical power in the mining and enrichment steps are likely to change the projections of earlier authors, such as Mortimer (1990).
Spadaro 2000 Nuclear-2.5 to 5.7 g Ceq/kWh Coal-264 to 357 g Ceq/kWh Storm van Authors did not evaluate nuclear versus coal.
Leeuwen and Smith 2005 Fritsche 2006 Nuclear-33 g Ceq/kWh (values estimated Coal-950 g Ceq/kWh from graph in Figure 4)
December 2008 6-11 Draft NUREG-1437, Supplement 38 OAG10001366_00304
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management POST 2006 Nuclear-S 9 Ceq/kWh (Nuclear Coal->1000 9 Ceq/kWh calculations from AEA 2006) Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 6.8 9 Ceq /kWh. Future improved technology and carbon capture and storage could reduce coal-fired GHG emissions by gO percent.
Weisser 2006 Nuclear-2.8 to 24 9 Ceq/kWh (compilation of results from other Coal-gSO to 12S0 9 Ceq/kWh studies)
Fthenakis and Kim Authors did not evaluate nuclear versus coal.
(2007)
Dones 2007 Author did not evaluate nuclear versus coal.
Draft NUREG-1437, Supplement 38 6-12 December 2008 OAG10001366_00305
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 6.2.8 Summary of Nuclear Greenhouse Gas Emissions Compared to Natural Gas 2 The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle, as 3 compared to an equivalent natural gas-fired plant, are presented in Table 6-3.
4 Table 6-3. Nuclear GHG Emissions Compared to Natural Gas Source GHG Emission Results Mortimer 1990 Author did not evaluate nuclear versus natural gas.
Andseta 1998 Author did not evaluate nuclear versus natural gas.
Spadaro 2000 Nuclear-2.5 to 5.7 g Ceq/kWh Natural Gas-120 to 188 g Ceq/kWh Storm van Nuclear fuel cycle produces 20 to 33% of the GHG emissions compared to Leeuwen and natural gas (at high ore grades).
Smith 2005 Note: Future nuclear GHG emissions to increase because of declining ore grade.
Fritsche 2006 Nuclear-33 g Ceq/kWh (values estimated Cogeneration Combined Cycle Natural Gas-150 g Ceq/kWh from graph in Figure 4)
POST 2006 Nuclear-5 g Ceq/kWh (Nuclear Natural Gas-500 g Ceq/kWh calculations from AEA 2006) Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 6.8 g Ceq/kWh. Future improved technology and carbon capture and storage could reduce natural gas GHG emissions by 90%.
Weisser 2006 Nuclear-2.8 to 24 g Ceq/kWh (compilation of Natural Gas-440 to 780 g Ceq/kWh results from other studies)
Fthenakis and Kim Authors did not evaluate nuclear versus natural gas.
(2007)
Dones 2007 Author critiqued methods and assumptions of Storm van Leeuwen and Smith (2005), and concluded that the nuclear fuel cycle produces 15 to 27%
of the GHG emissions of natural gas.
5 6.2.9 Summary of Nuclear Greenhouse Gas Emissions Compared to Renewable 6 Energy Sources 7 The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle, as 8 compared to equivalent renewable energy sources, are presented in Table 6-4. Calculation of 9 GHG emissions associated with these sources is more difficult than the calculations for nuclear December 2008 6-13 Draft NUREG-1437, Supplement 38 OAG10001366_00306
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 energy and fossil fuels because the efficiencies of the different energy sources vary so much by 2 location. For instance, the efficiency of solar and wind energy is highly dependent on the 3 location in which the power generation facility is installed. Similarly, the range of GHG 4 emissions estimates for hydropower varies greatly depending on the type of dam or reservoir 5 involved. Therefore, the GHG emissions estimates for these energy sources have a greater 6 range of variability than the estimates for nuclear and fossil fuel sources.
7 Table 6-4. Nuclear GHG Emissions Compared to Renewable Energy Sources Source GHG Emission Results Mortimer 1990 Nuclear-230,000 tons CO 2 Hydropower-78,000 tons CO 2 Wind power-54,000 tons CO 2 Tidal power-52,500 tons CO 2 Note: Future GHG emissions from nuclear to increase because of declining ore grade.
Andseta 1998 Author did not evaluate nuclear versus renewable energy sources.
Spadaro 2000 Nuclear-2.5 to 5.7 9 Ceq/kWh Solar PV-27.3 to 76.4 9 Ceq/kWh Hydroelectric-1.1 to 64.6 9 Ceq/kWh Biomass-8.4 to 16.6 9 Ceq/kWh Wind-2.5 to 13.1 9 Ceq/kWh Storm van Author did not evaluate nuclear versus renewable energy sources.
Leeuwen and Smith 2005 Fritsche 2006 Nuclear-33 9 Ceq/kWh (values estimated Solar PV-125 9 Ceq/kWh from graph in Figure 4) Hydroelectric-50 9 Ceq/kWh Wind-20 9 Ceq/kWh POST 2006 Nuclear-5 9 Ceq/kWh (Nuclear Biomass-25 to 93 9 Ceq/kWh calculations from AEA 2006) Solar PV-35 to 58 9 Ceq/kWh WavelTidal-25 to 50 9 Ceq/kWh Hydroelectric-5 to 30 9 Ceq/kWh Wind-4.64 to 5.25 9 Ceq/kWh Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 6.8 9 Ceq/kWh.
Source GHG Emission Results Draft NUREG-1437, Supplement 38 6-14 December 2008 OAG10001366_00307
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management Weisser 2006 Nuclear-2.8 to 24 9 Ceq/kWh (compilation of Solar PV--43 to 73 9 Ceq/kWh results from other studies) Hydroelectric-1 to 34 9 Ceq/kWh Biomass-35 to 99 9 Ceq/kWh Wind-8 to 30 9 Ceq/kWh Fthenakis and Kim Nuclear-16 to 55 9 Ceq/kWh (2007)
Solar PV-17 to 49 9 Ceq/kWh Dones 2007 Author did not evaluate nuclear versus renewable energy sources.
1 6.2.10 Conclusions 2 Estimating the GHG emissions associated with current nuclear energy sources is challenging 3 because of differing assumptions and noncomparable analyses performed by the various 4 authors. The differences and complexities in these assumptions and analyses increase when 5 using them to project future GHG emissions. However, even with these differences, the NRC 6 staff can draw several conclusions.
7 First, the studies indicate a consensus that nuclear power currently produces fewer GHG 8 emissions than fossil-fuel-based electrical generation. Based on the literature review, the 9 lifecycle GHG emissions from the complete nuclear fuel cycle currently range from 2.5 to 10 55 g Ceq/kWh. The comparable lifecycle GHG emissions from the current use of coal range 11 from 264 to 1250 g Ceq/kWh, and GHG emissions from the current use of natural gas range 12 from 120 to 780 g Ceq/kWh. The existing studies also provided estimates of GHG emissions 13 from five renewable energy sources, based on current technology. These estimates included 14 solar-photovoltaic (17 to 125 g Ceq/kWh), hydroelectric (1 to 64.6 g Ceq/kWh), biomass (8.4 to 15 99 g Ceq/kWh), wind (2.5 to 30 g Ceq/kWh), and tidal (25 to 50 g Ceq/kWh). The range of these 16 estimates is very wide, but the general conclusion is that the current GHG emissions from the 17 nuclear fuel cycle are of the same order of magnitude as those for these renewable energy 18 sources.
19 Second, the studies indicate no consensus on future relative GHG emissions from nuclear 20 power and other sources of electricity. There is substantial disagreement among the various 21 authors regarding the GHG emissions associated with declining uranium ore concentrations, 22 future uranium enrichment methods, and other factors, including changes in technology. Similar 23 disagreement exists regarding future GHG emissions associated with coal and natural gas 24 electricity generation. Even the most conservative studies conclude that the nuclear fuel cycle 25 currently produces fewer GHG emissions than fossil-fuel-based sources, and are expected to 26 continue to do so in the near future. The primary difference between the authors is the 27 projected cross-over date (the time at which GHG emissions from the nuclear fuel cycle exceed 28 those of fossil-fuel-based sources) or whether cross-over will actually occur at all.
29 Considering the current estimates and future uncertainties, it appears that GHG emissions 30 associated with the proposed IP2 and IP3 relicensing action are likely to be lower than those 31 associated with fossil-fuel-based energy sources. The NRC staff bases this conclusion on the December 2008 6-15 Draft NUREG-1437, Supplement 38 OAG10001366_00308
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 following rationale:
2 (1) The current estimates of GHG emissions from the nuclear fuel cycle are far below those 3 for fossil-fuel-based energy sources.
4 (2) IP2 and IP3 license renewal will involve continued uranium mining, processing, and 5 enrichment, but will not result in increased GHG emissions associated with plant 6 construction or decommissioning (as the plant will have to be decommissioned at some 7 point whether the license is renewed or not).
8 (3) Few studies predict that nuclear fuel cycle emissions will exceed those of fossil fuels 9 within a timeframe that includes the IP2 and IP3 periods of extended operation. Several 10 studies suggest that future extraction and enrichment methods, the potential for higher 11 grade resource discovery, and technology improvements could extend this timeframe.
12 With respect to comparison of GHG emissions between the proposed IP2 and IP3 license 13 renewal action and renewable energy sources, it appears likely that there will be future 14 technology improvements and changes in the type of energy used for mining, processing, and 15 constructing facilities in both areas. Currently, the GHG emissions associated with the nuclear 16 fuel cycle and renewable energy sources are within the same range. Because nuclear fuel 17 production is the most significant contributor to possible future increases in GHG emissions 18 from nuclear power, and because most renewable energy sources lack a fuel component, it is 19 likely that GHG emissions from renewable energy sources would be lower than those 20 associated with IP2 and IP3 at some point during the period of extended operation.
21 6.3 References 22 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 23 Protection Regulations for Domestic Licensing and Related Regulatory Functions."
24 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for 25 Renewal of Operating Licenses for Nuclear Power Plants."
26 10 CFR Part 63. Code of Federal Regulations, Title 10, Energy, Part 63, "Disposal of High-27 Level Radioactive Wastes in a Geologic Repository at Yucca Mountain, Nevada."
28 40 CFR Part 191. Code of Federal Regulations, Title 40, Protection of Environment, Part 191, 29 "Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear 30 Fuel, High-Level and Transuranic Radioactive Waste."
31 AEA Technology (AEA). 2006. "Carbon Footprint of the Nuclear Fuel Cycle, Briefing Note."
32 Prepared for British Energy. March 2006.
33 Andseta, S., M.J. Thompson, J.P. Jarrell, and D.R. Pendergast. 1998. "CANDU Reactors and 34 Greenhouse Gas Emissions." Canadian Nuclear Association, 11th Pacific Basin Nuclear 35 Conference, Banff, Alberta, Canada. May 1998.
36 Department of Energy (DOE). 1980. "Final Environmental Impact Statement: Management of 37 Commercially Generated Radioactive Waste." DOE/EIS-0046F, Washington, DC.
38 Dones, R. 2007. "Critical Note on the Estimation by Storm Van Leeuwen J.W. and Smith P. of 39 the Energy Uses and Corresponding CO 2 Emissions for the Complete Nuclear Energy Chain."
Draft NUREG-1437, Supplement 38 6-16 December 2008 OAG10001366_00309
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 Paul Sherer Institute. April 2007.
2 Entergy Nuclear Northeast. 2002. "Entergy Nuclear Indian Point 2, LLC and Entergy Nuclear 3 Indian Point 3, LLC, Village of Buchanan, New York, Emissions Avoidance Study." Prepared by 4 TRC Environmental Corporation, Lyndhurst, New Jersey. August 2002.
5 Entergy Nuclear Operations, Inc. (Entergy). 2007. "Applicant's Environment Report, Operating 6 License Renewal Stage." (Appendix E to Indian Point, Units 2 and 3, License Renewal 7 Application). April 23, 2007. Agencywide Documents Access and Management System 8 (ADAMS) Accession No. ML071210530.
9 Fritsche, U.R. 2006. "Comparison of Greenhouse-Gas Emissions and Abatement Cost of 10 Nuclear and Alternative Energy Options from a Life-Cycle Perspective." Oko-Institut, Darmstadt 11 Office. January 2006.
12 Fthenakis, V.M., and H.C. Kim. 2007. Greenhouse-gas emissions from solar electric- and 13 nuclear power: A life cycle study. Energy Policy, Volume 35, Number 4.
14 Hagen, R.E., J.R. Moens, and Z.D. Nikodem. 2001. "Impact of U.S. Nuclear Generation on 15 Greenhouse Gas Emissions." International Atomic Energy Agency, Vienna, Austria. November 16 2001.
17 International Atomic Energy Agency (lAEA). 2000. "Nuclear Power for Greenhouse Gas 18 Mitigation under the Kyoto Protocol: The Clean Development Mechanism (COM)." November 19 2000.
20 Joint Resolution 87, 2002. Public Law 107-200, 116 Stat 735.
21 Keepin, B. 1988. "Greenhouse Warming: Efficient Solution of Nuclear Nemesis?" Rocky 22 Mountain Institute. Joint Hearing on Technologies for Remediating Global Warming, 23 Subcommittee on Natural Resources, Agriculture Research and Environment and 24 Subcommittee on Science, Research and Technology, United States House of Representatives.
25 June 1988.
26 Massachusetts Institute of Technology (MIT). 2003. "The Future of Nuclear Power: An 27 Interdisciplinary MIT Study."
28 Mortimer, N. 1990. World warms to nuclear power. SCRAM Safe Energy Journal. December 29 1989 and January 1990. Available at URL:
30 http://www.n02nuclearpower.org.uk/articles/mortimer se74.php. Accessed February 29,2007.
31 National Academy of Sciences (NAS). 1995. "Technical Bases for Yucca Mountain Standards."
32 Washington, DC.
33 National Environmental Policy Act of 1969 (NEPA). 42 USC 4321, et. seq.
34 Nuclear Information and Resource Service and World Information Service on Energy 35 (NIRSIWISE). 2005. Nuclear power: No solution to climate change. Nuclear Monitor, 36 Numbers 621 and 622. February 2005.
37 Nuclear Regulatory Commission (NRC). 1996. "Generic Environmental Impact Statement for 38 License Renewal of Nuclear Power Plants." NUREG-1437, Volumes 1 and 2, Washington, DC.
39 Nuclear Regulatory Commission (NRC). 1999. "Generic Environmental Impact Statement for 40 License Renewal of Nuclear Plants Main Report," Section 6.3, "Transportation," Table 9.1, December 2008 6-17 Draft NUREG-1437, Supplement 38 OAG10001366_00310
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 "Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants."
2 NUREG-1437, Volume 1, Addendum 1, Washington, DC.
3 Organization for Economic Co-Operation and Development, Nuclear Energy Agency (NEA).
4 2002. Nuclear Energy and the Kyoto Protocol.
5 Parliamentary Office of Science and Technology (POST). 2006. "Carbon Footprint of Electricity 6 Generation." Postnote, Number 268. October 2006.
7 Schneider, M. 2000. Climate Change and Nuclear Power. World Wildlife Fund for Nature.
8 April 2000.
9 Spadaro, J.v., L. Langlois, and B. Hamilton. 2000. "Greenhouse Gas Emissions of Electricity 10 Generation Chains: Assessing the Difference." IAEA Bulletin 42/2/2000, Vienna, Austria.
11 Storm van Leeuwen, J.W., and P. Smith. 2005. Nuclear Power- The Energy Balance. August 12 2005.
13 Weisser, D. 2006. "A Guide to Life-Cycle Greenhouse Gas (GHG) Emissions from Electric 14 Supply Technologies." Available at URL:
15 http://www.aseanenvironmentinfo/abstract41015146.pdf. Accessed March 3, 2008.
Draft NUREG-1437, Supplement 38 6-18 December 2008 OAG10001366_00311
1 7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING 2 Environmental impacts from the activities associated with the decommissioning of any reactor 3 before or at the end of an initial or renewed license are evaluated in NUREG-0586, 4 Supplement 1, "Generic Environmental Impact Statement on Decommissioning of Nuclear 5 Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors" (NRC 6 2002). The U.S. Nuclear Regulatory Commission (NRC) staff's evaluation of the environmental 7 impacts of decommissioning presented in NUREG-0586, Supplement 1, identifies a range of 8 impacts for each environmental issue.
9 The incremental environmental impacts associated with decommissioning activities resulting 10 from continued plant operation during the renewal term are discussed in NUREG-1437, 11 Volumes 1 and 2, "Generic Environmental Impact Statement for License Renewal of Nuclear 12 Plants" (hereafter referred to as the GElS) (NRC 1996, 1999).(1) The GElS includes a 13 determination of whether the analysis of the environmental issue could be applied to all plants 14 and whether additional mitigation measures would be warranted. Issues were then assigned a 15 Category 1 or a Category 2 designation. As set forth in the GElS, Category 1 issues are those 16 that meet all of the following criteria:
17 (1) The environmental impacts associated with the issue have been determined to apply 18 either to all plants or, for some issues, to plants having a specific type of cooling system 19 or other specified plant or site characteristics.
20 (2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 21 the impacts (except for collective offsite radiological impacts from the fuel cycle and from 22 high-level waste and spent fuel disposal).
23 (3) Mitigation of adverse impacts associated with the issue has been considered in the 24 analysis, and it has been determined that additional plant-specific mitigation measures 25 are likely not to be sufficiently beneficial to warrant implementation.
26 For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 27 required unless new and significant information is identified.
28 Category 2 issues are those that do not meet one or more of the criteria for Category 1; 29 therefore, additional plant-specific review of these issues is required. There are no Category 2 30 issues related to decommissioning.
31 7.1 Decommissioning 32 Category 1 issues in Table 8-1 of Appendix 8 to Subpart A, "Environmental Effect of Renewing 33 the Operating License of a Nuclear Power Plant," of Title 10, Part 51, "Environmental Protection 34 Regulations for Domestic Licensing and Related Regulatory Functions," of the Code of Federal 35 Regulations (10 CFR Part 51) that are applicable to IP2 and IP3 decommissioning following the 36 renewal term are listed in Table 7-1. Entergy Nuclear Operations, Inc. (Entergy), stated in the 37 IP2 and IP3 environmental report (ER) (Entergy 2007) that it is not aware of any new and (1)
The GElS was originally issued in 1996. Addendum 1 to the GElS was issued in 1999. Hereafter, all references to the GElS include the GElS and its Addendum 1.
December 2008 7-1 Draft NUREG-1437, Supplement 38 OAG10001366_00312
Environmental Impacts of Decommissioning 1 significant information regarding the environmental impacts of IP2 and IP3 license renewal, 2 though it did identify leaks from spent fuel pools as a potential new issue. The NRC staff 3 addressed this issue The NRC staff addressed this issue in Sections 2.2.7,4.3, and 4.5 of this 4 draft supplemental environmental impact statement (SEIS). In Section 4.5, the NRC staff 5 concludes that the abnormal liquid releases (leaks) discussed by Entergy in its ER, while new 6 information, are within the NRC's radiation safety standards contained in 10 CFR Part 20 and 7 are not considered to have a significant impact on plant workers, the public, or the environment 8 (i.e., while the information related to spent fuel pool leakage is new, it is not significant).
9 The NRC staff has not identified any information during its independent review of the IP2 and 10 IP3 ER (Entergy 2007), the site visit, the scoping process, or its evaluation of other available 11 information that is both new and significant. Therefore, the NRC staff concludes that there are 12 no impacts related to the Category 1 issues applicable to the decommissioning of IP2 and IP3 13 beyond those discussed in the GElS. For all of these issues, the NRC staff concluded in the 14 GElS that the impacts are SMALL, and additional plant-specific mitigation measures are not 15 likely to be sufficiently beneficial to be warranted.
16 Table 7-1. Category 1 Issues Applicable to the Decommissioning of 17 IP2 and IP3 Following the Renewal Term ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Section DECOMMISSIONING Radiation doses 7.3.1 Waste management 7.3.2 Air quality 7.3.3 Water quality 7.3.4 Ecological resources 7.3.5 Socioeconomic impacts 7.3.7 18 A brief description of the NRC staff's review and the GElS conclusions, as codified in Table B-1, 19 10 CFR Part 51, for each of the issues follows:
20
- Radiation doses. Based on information in the GElS, the Commission found the 21 following:
22 Doses to the public will be well below applicable regulatory standards regardless 23 of which decommissioning method is used. Occupational doses would increase 24 no more than 1 man-rem caused by buildup of long-lived radionuclides during the 25 license renewal term.
26 The NRC staff has not identified any new and significant information during its independent 27 review of the IP2 and IP3 ER, the site visit, the scoping process, or its evaluation of other 28 available information. Therefore, the NRC staff concludes that there are no radiation dose 29 impacts associated with decommissioning following the license renewal term beyond those 30 discussed in the GElS.
Draft NUREG-1437, Supplement 38 7-2 December 2008 OAG10001366_00313
Environmental Impacts of Decommissioning 1
- Waste management. Based on information in the GElS, the Commission found the 2 following:
3 Decommissioning at the end of a 20-year license renewal period would generate 4 no more solid wastes than at the end of the current license term. No increase in 5 the quantities of Class C or greater than Class C wastes would be expected.
6 The NRC staff has not identified any new and significant information during its independent 7 review of the IP2 and IP3 ER, the site visit, the scoping process, or its evaluation of other 8 available information. Therefore, the NRC staff concludes that there are no impacts from solid 9 waste associated with decommissioning following the license renewal term beyond those 10 discussed in the GElS.
11
- Air quality. Based on information in the GElS, the Commission found the following 12 Air quality impacts of decommissioning are expected to be negligible either at the 13 end of the current operating term or at the end of the license renewal term.
14 The NRC staff has not identified any new and significant information during its independent 15 review of the IP2 and IP3 ER, the site visit, the scoping process, or its evaluation of other 16 available information. Therefore, the NRC staff concludes that there are no impacts on air 17 quality associated with decommissioning following the license renewal term beyond those 18 discussed in the GElS.
19
- Water quality. Based on information in the GElS, the Commission found the following:
20 The potential for significant water quality impacts from erosion or spills is no 21 greater whether decommissioning occurs after a 20-year license renewal period 22 or after the original 40-year operation period, and measures are readily available 23 to avoid such impacts.
24 The NRC staff has not identified any new and significant information during its independent 25 review of the IP2 and IP3 ER, the site visit, the scoping process, or its evaluation of other 26 available information. Therefore, the NRC staff concludes that there are no impacts on water 27 quality associated with decommissioning following the license renewal term beyond those 28 discussed in the GElS.
December 2008 7-3 Draft NUREG-1437, Supplement 38 OAG10001366_00314
Environmental Impacts of Decommissioning 1
- Ecological resources. Based on information in the GElS, the Commission found the 2 following:
3 Decommissioning after either the initial operating period or after a 20-year 4 license renewal period is not expected to have any direct ecological impacts.
5 The NRC staff has not identified any new and significant information during its independent 6 review of the IP2 and IP3 ER, the site visit, the scoping process, or its evaluation of other 7 available information. Therefore, the NRC staff concludes that there are no impacts on 8 ecological resources associated with decommissioning following the license renewal term 9 beyond those discussed in the GElS.
10
- Socioeconomic Impacts. Based on information in the GElS, the Commission found the 11 following:
12 Decommissioning would have some short-term socioeconomic impacts. The 13 impacts would not be increased by delaying decommissioning until the end of a 14 20-year relicense period, but they might be decreased by population and 15 economic growth.
16 The NRC staff has not identified any new and significant information during its independent 17 review of the IP2 and IP3 ER, the site visit, the scoping process, or its evaluation of other 18 available information. Therefore, the NRC staff concludes that there are no socioeconomic 19 impacts associated with decommissioning following the license renewal term beyond those 20 discussed in the GElS.
21 7.2 References 22 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 23 Protection Regulations for Domestic Licensing and Related Regulatory Functions."
24 Entergy Nuclear Operations, Inc. (Entergy). 2007. "Applicant's Environment Report, Operating 25 License Renewal Stage." (Appendix E to Indian Point, Units 2 and 3, License Renewal 26 Application). April 23, 2007. Agencywide Documents Access and Management System 27 (ADAMS) Accession No. ML071210530.
28 Nuclear Regulatory Commission (NRC). 1996. "Generic Environmental Impact Statement for 29 License Renewal of Nuclear Power Plants." NUREG-1437, Volumes 1 and 2, Washington, DC.
30 Nuclear Regulatory Commission (NRC). 1999. "Generic Environmental Impact Statement for 31 License Renewal of Nuclear Plants Main Report," Section 6.3, "Transportation," Table 9.1, 32 "Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants."
33 NUREG-1437, Volume 1, Addendum 1, Washington, DC.
34 Nuclear Regulatory Commission (NRC). 2002. "Generic Environmental Impact Statement on 35 Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of 36 Nuclear Power Reactors." NUREG-0586, Volumes 1 and 2, Supplement 1, Washington, DC.
Draft NUREG-1437, Supplement 38 7-4 December 2008 OAG10001366_00315
1 8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES 2 TO LICENSE RENEWAL 3 This chapter examines the potential environmental impacts associated with (1) the closed-cycle 4 cooling system alternatives to replace the Indian Point Nuclear Generating Unit No.2 (lP2) and 5 Unit No.3 (lP3) existing once-through cooling-water systems, (2) denying the renewal of both 6 operating licenses for IP2 and IP3 (i.e., the no-action alternative), (3) replacing the electric 7 generation capacity of both units with alternative electric-generation sources, (4) importing 8 electric power from other sources to replace power generated by IP2 and IP3, and 9 (5) combinations of generation and conservation measures to replace power generated by IP2 10 and/or IP3. In addition, this chapter discusses other alternatives that were deemed unsuitable 11 for replacement of power generated collectively by IP2 and IP3.
12 The U.S. Nuclear Regulatory Commission (NRC) staff considered alternatives to the existing 13 IP2 and IP3 cooling-water systems because the New York State Department of Environmental 14 Conservation (NYSDEC) identified closed-cycle cooling (e.g., cooling towers) as the best 15 technology available (BTA) to reduce fish mortality in the draft New York State Pollutant 16 Discharge Elimination System (SPDES) discharge permit (NYSDEC 2003a). These alternatives 17 are described in Section 8.1 of this draft supplemental environmental impact statement (SEIS).
18 IP2 and IP3 have been operating under timely renewal provisions of the New York SPDES 19 permit process since 1992. In 2003, NYSDEC issued a draft SPDES permit for public 20 comment, including the BTA determination. The requirements, limits, and conditions of the draft 21 SPDES permit had not been finalized at the time the NRC staff performed the assessment 22 presented in this draft SEIS,.
23 The environmental impacts of alternatives are evaluated using the NRC's three-level standard 24 of significance-SMALL, MODERATE, or LARGE-developed based on the Council on 25 Environmental Quality (CEQ) guidelines and set forth in the footnotes to Table B-1 of 26 Appendix B to Subpart A, "Environmental Effect of Renewing the Operating License of a 27 Nuclear Power Plant," of Title 10, Part 51, "Environmental Protection Regulations for Domestic 28 Licensing and Related Regulatory Functions," of the Code of Federal Regulations 29 (10 CFR Part 51). The following definitions are used for each category:
30 SMALL-Environmental effects are not detectable or are so minor that they will 31 neither destabilize nor noticeably alter any important attribute of the resource.
32 MODERA TE-Environmental effects are sufficient to alter noticeably, but not to 33 destabilize important attributes of the resource.
34 LARGE-Environmental effects are clearly noticeable and are sufficient to 35 destabilize important attributes of the resource.
36 The impact categories evaluated in this chapter are the same as those used in NUREG-1437, 37 Volumes 1 and 2, "Generic Environmental Impact Statement for License Renewal of Nuclear 38 Plants" (hereafter referred to as the GElS) (NRC 1996, 1999)(1) with the additional impact (1)
The GElS was originally issued in 1996. Addendum 1 to the GElS was issued in 1999. Hereafter, all references to the GElS include the GElS and its Addendum 1.
December 2008 8-1 Draft NUREG-1437, Supplement 38 OAG10001366_00316
Environmental Impacts of License Renewal 1 categories of environmental justice and transportation.
2 8.1 Alternatives to the Existing IP2 and IP3 Cooling-Water System 3 IP2 and IP3 currently use once-through cooling-water systems that withdraw water from and 4 discharge water to the Hudson River as described in Section 2.1.3 of this draft SEIS. The 5 circulating water systems for IP2 and IP3 include two intake structures, each containing seven 6 pumps. The normal design flow rate of 3,180,000 liters per minute (lpm) (840,000 gallons per 7 minute (gpm)) for each unit is achieved using dual-speed pumps for IP2 and variable-speed 8 pumps for IP3.
9 Warm discharge water from IP2 and IP3 flows from the condensers through six pipes that are 10 2.4 meters (m) (96 inches (in.)) in diameter and exits beneath the water surface into a discharge 11 canal 12 m (40 feet (ft)) wide. Water flows from the discharge canal to the Hudson River 12 through an outfall structure located south of IP3 at a discharge velocity of about 3.7 meters per 13 second (mps) (10 feet per second (fps)). The design of the outfall is intended to reduce the 14 thermal impact the warm water has on the river. An assessment of the impacts of the current 15 cooling-water system on the environment is presented in Section 4.1 of this draft SEIS.
16 Surface water withdrawals and discharges at IP2 and IP3 are regulated under the New York 17 SPDES permit program. In 1975, the U.S. Environmental Protection Agency (EPA) issued 18 National Pollutant Discharge Elimination System (NPDES) permits for the facility.
19 Subsequently, the NYSDEC issued an SPDES permit for the facility in 1987. In 1992, a timely 20 renewal application was filed with the NYSDEC, and terms of the 1992 SPDES have been 21 continued under provisions of the NY State Administrative Procedure Act. Petitioners 22 commenced proceedings in 2002 to mandate that the NYSDEC act on the SPDES permit 23 renewal application. On April 8, 2003, the NYSDEC proposed to modify the SPDES permit to 24 require that IP2 and IP3 reduce the impacts to aquatic organisms caused by the once-through 25 cooling systems and that Entergy Nuclear Operations, Inc. (Entergy), complete a water quality 26 review. A draft SPDES permit identifying closed-cycle cooling as the BTA was issued on 27 November 14,2003 (NYSDEC 2003a).
28 The draft SPDES permit requires that immediate and long-term steps be taken to reduce the 29 adverse impacts on the Hudson River estuary once the permit is issued (NYSDEC 2003a). The 30 short-term steps include mandatory outage periods, reduced intake during certain times, 31 continued operation of fish-impingement mitigation measures, the payment of $25 million to a 32 Hudson River Estuary Restoration Fund, and various studies. In the long term, IP2 and IP3 will 33 have to implement the BTA to minimize environmental impacts to the aquatic ecology. Should 34 the BTA determination in the draft SPDES permit go into effect, final implementation of the BTA 35 is subject to NRC's approval only insofar as the NRC oversees the plant's safety performance 36 and ability to cool itself. Based on NYSDEC's fact sheet addressing the draft SPDES permit, 37 NYSDEC will not require closed cycle cooling if IP2 and IP3 do not receive renewed licenses 38 from the NRC (NYSDEC 2003c).
39 Specifically, the draft SPDES permit states the following:
40 Within six months of the effective date of this permit, the permitee must submit to 41 the NYSDEC ... its schedule for seeking and obtaining, during its permit term, all 42 necessary approvals from the NRC, Federal Energy Regulatory Commission Draft NUREG-1437, Supplement 38 8-2 December 2008 OAG10001366_00317
Environmental Impacts of License Renewal 1 (FERC), and other government agencies to enable construction and operation of 2 closed-cycle cooling at Indian Point.
3 NYSDEC (2003a) has also indicated that an alternative technology or technologies may be 4 proposed for IP2 and IP3 within 1 year of the permit's effective date. These technologies must 5 be able to minimize the adverse environmental impacts to a level equivalent to that achieved by 6 a closed-cycle cooling system at IP2 and IP3 (NYSDEC 2003b).
7 The NYSDEC identified construction and operation of a closed-cycle cooling system at IP2 and 8 IP3 as its preferred alternative to meet current national performance standards for impingement 9 and entrainment losses. Entergy indicates that Entergy or its predecessors have proposed and 10 NYSDEC has rejected the following alternative cooling technologies as described in the IP2 and 11 IP3 ER (Entergy 2007). As a result, these options are not discussed further in this draft SEIS.
12
- Evaporative ponds, spray ponds, or cooling canals all require significantly more land 13 area than exists at the site.
14
- Dry cooling towers, which rely totally on sensible heat transfer, lack the efficiency of wet 15 or hybrid towers using evaporative cooling, and thus require a far greater surface area 16 than is available at the site. Additionally, because of their lower efficiency, dry towers 17 are not capable of supporting condenser temperatures necessary to be compatible with 18 IP2 or IP3 turbine design and, therefore, are not a feasible technology.
19
- Natural draft cooling towers, while potentially feasible, would be 137 to 152 m (450 to 20 500 ft) above ground level with significant adverse aesthetic impacts in an important 21 viewshed corridor. This option also would raise plume-related and sound effects 22 concerns. In the original EPA permitting proceeding, New York State opposed natural 23 draft cooling towers on aesthetic grounds.
24
- Single-stage mechanical-draft wet cooling towers for a number of reasons including, but 25 not limited to, the dense water vapor plumes that may compromise station operations 26 (including visual signaling) and equipment over time, and result in increased noise 27 (Enercon 2003).
28 The EPA has concluded that, in some circumstances, retrofitting a plant to a closed-cycle 29 cooling system lacks demonstrated feasibility or economic practicality (EPA 2004). In addition, 30 Entergy asserts that retrofitting facilities the size and configuration of IP2 and IP3 with a closed-31 cycle cooling system is neither tried nor proven (Entergy 2007). Entergy also considers 32 mitigation measures currently implemented to protect aquatic wildlife as part of the once-33 through cooling system to be adequate in terms of minimizing impacts from current operations 34 and operations during the license renewal period (Entergy 2007).
35 Entergy expressed a number of concerns regarding financial or technical issues related to a 36 closed-cycle cooling retrofit (Entergy 2007), including high cost, a lengthy forced outage, and 37 lost power output due to parasitic losses from new cooling system components. In the Hudson 38 River Utilities FEIS, NYSDEC indicated that the previous owners' closed-cycle cooling cost 39 estimates were likely generally reasonable (NYSDEC 2003d), while EPA indicated that costs 40 may have been somewhat inflated (EPA 2004). EPA also indicated some uncertainty with 41 regard to outage duration for the plant retrofit.
December 2008 8-3 Draft NUREG-1437, Supplement 38 OAG10001366_00318
Environmental Impacts of License Renewal 1 Entergy notes that replacement power during the outage may carry negative air quality impacts, 2 and that the outage may have negative impacts on electric-system reliability and market pricing.
3 Finally, Entergy indicates that closed-cycle cooling would result in a loss of generating capacity 4 due to lowered thermal efficiency and parasitic loads related to cooling system pumps and 5 auxiliary systems (an average annual loss of 26 MW(e), per unit) because of power demands of 6 the closed-cycle system (Entergy 2007).
7 In the following chapter, the NRC staff will evaluate the environmental impacts associated with 8 installing a closed-cycle cooling system at Indian Point, as well as the environmental impacts 9 associated with a potentially-equivalent combination of plant modifications and restoration 10 activities. Regardless of the NRC staff's findings, the NRC does not have the regulatory 11 authority to implement the requirements of the Clean Water Act, and it is not up to the NRC 12 staff to judge the validity of Entergy's or others' claims in the ongoing NYSDEC SPDES permit 13 process. The NRC staff, however, notes that both NYSDEC (2003b) and EPA (2004) indicated 14 that estimates for cooling conversion by the previous owners of IP2 and IP3 overestimated a 15 variety of costs and selected a more-expensive technology than was necessary. Further, EPA 16 (2004) indicated that Entergy's outage duration was likely exaggerated.
17 In 2004, EPA issued regulations for reducing impingement and entrainment losses at existing 18 electricity-generating facilities (EPA 2004). These regulations, know as the Phase II rule, 19 established standards for compliance with the requirements of Section 316(b) of the Clean 20 Water Act (CWA), which calls for intake structures to reflect the BTA for minimizing adverse 21 environmental impact. The EPA's Phase II rule established two compliance alternatives that 22 reduce impingement mortality by 80 to 95 percent of baseline and reduce organism entrainment 23 by 60 to 90 percent of baseline (EPA 2004). These regulations supported the requirements of 24 the draft New York SPDES permit's requirement that immediate and long-term steps be taken to 25 minimize adverse impacts on the Hudson River estuary.
26 The EPA's rules concerning Phase II of Section 316(b) of the CWA were struck down by the 27 U.S. Court of Appeals in the Second Circuit in January, 2007. The Court also mandated the 28 conduct of a cost-benefit analysis under Section 316(b) of the CWA. That decision is currently 29 on appeal before the U.S. Supreme Court. Specifically, the EPA suspended 30 40 CFR Part 122.2(r)(1)(ii) and (5) and Subpart J, "Requirements Applicable to Cooling Water 31 Intake Structures for Phase II Existing Facilities Under Section 316(b) of the Act," of 32 40 CFR Part 125, "Criteria and Standards for the National Pollutant Discharge Elimination 33 System," with the exception of 40 CFR 125.90(b) (EPA 2007). However, the issued SPDES 34 permit remains in effect, pending the conclusion of related administrative and legal proceedings.
35 8.1.1 Closed-Cycle Cooling Alternative 36 As indicated in Section 8.1, NYSDEC identified closed-cycle cooling as a BTA in its 2003 draft 37 SPDES permit (NYSDEC 2003a, 2003c). Entergy's preferred close-cycle alternative consists of 38 two hybrid mechanical-draft cooling towers (Enercon 2003, Entergy 2007). IP2 and IP3 would 39 each utilize one cooling tower. Entergy rejected single-stage mechanical draft cooling towers, 40 indicating that the dense water vapor plumes from the towers may compromise station 41 operations (including visual signaling) and equipment over time, and single-stage towers may 42 result in increased noise (Enercon 2003).
Draft NUREG-1437, Supplement 38 8-4 December 2008 OAG10001366_00319
Environmental Impacts of License Renewal 1 Entergy asserts that a hybrid mechanical-draft cooling tower system, also referred to as a 2 "wet/dry" or "plume-abated" mechanical-draft cooling tower, addresses some of the 3 shortcomings of the cooling system types described in Section 8.1 (Entergy 2007). In the ER, 4 Entergy indicates that hybrid towers are "appreciably more expensive" than single-stage towers 5 (2007).
6 A hybrid tower consists of a standard efficiency wet tower segment combined with a dry heat 7 exchanger section above it. The dry section eliminates visible plumes in the majority of 8 atmospheric conditions. After the plume leaves the lower "wet" section of the tower, it travels 9 upward through a "dry" section where heated, relatively dry air is mixed with the plume in the 10 proportions required to achieve a nonvisible plume. Because of the "dry" section, which is on 11 top of the "wet" section, hybrid towers are slightly taller than comparable wet towers and require 12 a larger footprint (Entergy 2007). Hybrid towers are also appreciably more expensive, both in 13 initial costs and in ongoing operating and maintenance costs (Entergy 2007). A potential exists 14 for increased noise from additional fans in the dry section, although Entergy indicates that 15 sound effects can be attenuated (Entergy 2007).
16 Portions of the site where Entergy could construct cooling towers are heavily forested, with 17 rocky terrain and some steep slopes. Entergy indicates that these areas can be more 18 environmentally sensitive and costly to build on.
19 The NRC staff has previously assessed closed cycle cooling with a hybrid cooling tower in the 20 license renewal SEIS for Oyster Creek Nuclear Generating Station (OCNGS) (NRC 2006). The 21 NRC staff finds that a hybrid cooling tower system is a reasonable design for the purpose of 22 evaluating potential environmental impacts in a NEPA document. However, the NRC staff does 23 not intend for this analysis to prejudice potential requirements imposed by NYSDEC or other 24 authorities.
25 Should hybrid towers prove prohibitively expensive (as determined by other, non-NRC 26 authorities), the NRC staff notes that single-stage mechanical draft towers will produce similar 27 decreases in impacts to aquatic life and may result in less land-clearing or blasting debris than 28 the hybrid cooling tower option. Additionally, single-stage towers will be shorter, though plumes 29 in cool or highly-saturated atmospheric conditions will impose slightly greater aesthetic impacts 30 as well as creating greater deposition of ice or dissolved solids near the towers than the circular, 31 hybrid towers proposed by Entergy would cause.
32 8.1.1.1 Description of the Closed-Cycle Cooling Alternative 33 As described in the ER (Entergy 2007), new hybrid cooling towers would be large, 34 approximately 170 m (560 ft) in diameter and 46 to 50 m (150 to 165 ft) high. To provide 35 construction access for tower erection and clearance for air intake, the excavation diameter for 36 each tower would be approximately 700 ft. The locations for the IP2 and IP3 towers are 37 expected to be approximately 305 m (1000 ft) north of the IP2 reactor and approximately 305 m 38 (1000 ft) south of the IP3 reactor, respectively. A detailed description of a round hybrid cooling 39 tower conceptual design is presented in the 2003 cooling tower evaluation (Enercon 2003).
40 Crews excavating areas for the cooling tower basins and associated piping may need to blast 41 substantial amounts of rock during the construction process.
42 As noted in Section 8.1, the closed-cycle cooling alternative would introduce parasitic losses 43 from additional pumps and other equipment. The new circulating pumps would likely be housed 44 in a new pumphouse located along the discharge canal (Enercon 2003). The new, enclosed December 2008 8-5 Draft NUREG-1437, Supplement 38 OAG10001366_00320
Environmental Impacts of License Renewal 1 pumphouse would supply circulating water to the new towers via two concrete-lined steel pipes 23m (10ft) in diameter. Flow from the cooling tower basin to the condenser is expected via two 3 pipes 3.7 m (12 ft) in diameter (Enercon 2003).
4 Enercon also reported that two dedicated substations would likely supply electricity to the 5 closed-cycle cooling system from the 138-kilovolt (kV) offsite switchyard. The substation 6 transformers, switch gear, and system controls for each tower and pumphouse would be 7 housed in prefabricated metal buildings (Enercon 2003).
8 8.1.1.2 Environmental Impacts of the Closed-Cycle Cooling Alternative 9 In this section, the NRC staff addresses the impacts that would occur if Entergy constructs and 10 operates the closed-cycle cooling system described in Section 8.1.1.1. The NRC staff 11 summarizes anticipated impacts of the closed-cycle cooling alternative summarized in Table 8-12 1. In the areas of land use, terrestrial ecology, waste, and aesthetics, the environmental 13 impacts of constructing and operating this closed-cycle cooling system would be greater than 14 the impacts associated with the existing once-through cooling system, primarily due to 15 construction-stage impacts. The closed-cycle cooling alternative significantly reduces impacts 16 to aquatic ecology, including impacts from entrainment, impingement, and heat shock. Impacts 17 to aquatic threatened and endangered species are also likely to decline. In the following 18 sections, the NRC staff presents the potential environmental impacts of installing and operating 19 a closed-cycle cooling alternative at Indian Point. The NRC staff addresses impacts for each 20 resource area.
21
- Land Use 22 Construction of hybrid mechanical-draft cooling towers would entail significant clearing and 23 excavation of the currently timbered areas within the IP2 and IP3 exclusion area. Each cooling 24 tower requires an excavated area of approximately 3.6 hectares (ha) (9 acres (ac)). Ultimately, 25 approximately 16 ha (40 ac), most of which is presently wooded (though previously disturbed; 26 ENN 2007), would need to be cleared for the two cooling towers, access roads, and support 27 facilities (Enercon 2003). The towers would be located within the property exclusion area 28 boundary adjacent to existing facilities as described in Section 8.1.1.1.
29 Entergy indicates that roughly 305 m (1000 ft) of river bank would be clear-cut and excavated to 30 allow for the installation of the four large-diameter water pipes (two 3-m-diameter supply pipes 31 and two 3.7-m-diameter pipes to each condenser) required for each tower (Entergy 2007). In 32 addition, Enercon reports that the base of each tower would be constructed on bedrock at an 33 elevation of about 9.1 m (30 ft) above mean sea level. This would entail the removal of 34 approximately 2 million cubic yards (cy) (1.5 million cubic meters (m 3)) of material, primarily rock 35 and dirt, using traditional excavation methods as well as a significant amount of blasting 36 (Entergy 2007). Disposal of 2 million cy (1.5 million m3 ) of material from the excavations for the 37 cooling towers may create offsite land use impacts. Excavated material also may be recycled or 38 reused, which would reduce these impacts.
39 Entergy's proposed IP3 cooling tower would be located in the permanent right-of-way (ROW) 40 easement granted to the Algonquin Gas Transmission Company (AGTC) for constructing, 41 maintaining, and operating the three natural gas pipelines that traverse the IP2 and IP3 site 42 (Entergy 2007). These pipelines transport natural gas under the Hudson River, across the IP2 43 and IP3 site, and exit the site between Bleakley Avenue and the Buchanan substation (see Draft NUREG-1437, Supplement 38 8-6 December 2008 OAG10001366_00321
Environmental Impacts of License Renewal 1 Figure 2-3 in Chapter 2 of this SEIS for a graphical representation).
2 Entergy indicates that ROW easement agreement calls for AGTC to relocate the pipelines at 3 Entergy's request. The Federal Energy Regulatory Commission (FERC) would first have to 4 review and approve any such action. Entergy must also provide a suitable location for the 5 pipeline on its land or land that it has acquired (Entergy 2007). Entergy indicates that pipeline 6 relocation may require blasting and could also require Entergy to purchase additional land 7 adjacent to the IP2 and IP3 site if onsite areas aren't suitable for the pipeline (Entergy 2007).
8 Feasibility studies and other regulatory approvals may also be necessary (Enercon 2003).
9 The IP2 and IP3 site is within New York's Coastal Zone. As indicated in Chapter 2, the IP2 and 10 IP3 site is located adjacent to a Significant Coastal Fish and Wildlife Habitat. Construction 11 activities, such as grading, excavating, and filling, would require a coastal erosion management 12 permit. Permitting restrictions would influence the construction of the cooling towers but they 13 would not likely prevent Entergy from building the towers.
14 Excavation for the cooling towers would cut into the side of the hills east of IP2 and IP3, 15 resulting in the removal of approximately 2 million cy of material, including significant rock as 16 well as dirt (Entergy 2007).
17 The NRC staff concludes that construction activities associated with cooling tower installation at 18 IP2 and IP3 would result in SMALL to LARGE land use impacts, depending largely on how 19 much material Entergy is unable to reuse or recycle, and where Entergy disposes of excavated 20 material that cannot be reused or recycled.
21
- Ecology 22 Aquatic ecoloav. Land-clearing and construction activities can cause short-term, localized 23 impacts on streams and rivers from increased site runoff. These impacts are generally 24 mitigated through the use of erosion and sediment controls. Because of the size of the 25 construction area needed for the cooling towers at the IP2 and IP3 site, such measures would 26 be necessary to limit erosion and sediment deposition in the Hudson River. Construction 27 impacts, however, would be relatively short-lived, and would be offset to some degree by 28 reduced water consumption during prolonged outages at IP2 and IP3 when Entergy or its 29 contractors would connect the closed-cycle cooling system to the units.
30 Following construction, the closed-cycle cooling alternative will significantly reduce operational 31 impacts compared to the current once-through cooling system. During the summer months, 32 when water use is at its highest, service and cooling tower makeup water would be withdrawn at 33 a rate of approximately 250,000 to 314,000 Ipm (66,000 to 83,000 gpm) for the combined needs 34 of IP2 and IP3. This would be a 93-to-95-percent reduction in water use compared to the 35 existing IP2 and IP3 once-through systems, which have a normal design flow rate of 3,200,000 36 Ipm (840,000 gpm) for each unit. Without modifications to the intake screening technologies, 37 the NRC staff assumes that the reduction in water intake results in an equivalent reduction in 38 entrainment and impingement. The staff concludes that this significant reduction in water 39 demand would likely result in a similarly significant reduction in entrainment- and impingement-40 related losses compared to the losses created by the current once-through cooling system.
41 New circulating-water intake pumps would likely continue to utilize the Ristroph traveling 42 screens and fish-return system currently in operation (Entergy 2007), as well as the current 43 intake bay area. The greatest impact of the closed-cycle system would be a reduction in December 2008 8-7 Draft NUREG-1437, Supplement 38 OAG10001366_00322
Environmental Impacts of License Renewal 1 entrainment and impingement of aquatic species. As described in Section 4.1.3.3 of this draft 2 SEIS, the NRC staff has concluded that the once-through cooling system has a direct impact on 3 some representative important species (RIS), which ranges from SMALL to LARGE depending 4 on the species affected. The reduction in flow may also reduce impingement or entrainment of 5 RIS to which the NRC staff could not assign a specific impact level, including blue crab 6 (Callinectes sapidus), the endangered shortnose sturgeon (Acipenser brevirostrum), and 7 macroinvertebrates, such as small clams and mussels (bivalves), snails, worms, crustaceans, 8 and aquatic insects. In Section 4.6.2, the NRC staff had indicated that the impacts to the 9 shortnose sturgeon could range from SMALL to LARGE, because of uncertainty due to the lack 10 of current sampling data.
11 Under a closed-cycle cooling system, most discharged blowdown water is unheated. Because 12 the closed-cycle cooling system discharges a smaller volume of water, and because the water is 13 cooler than in a once-through system, the extent of thermal impacts would be significantly 14 reduced. Thus, the effects of thermal shock also decline. However, the discharge water may 15 be higher in salinity and may contain higher concentrations of biocides, minerals, trace metals, 16 or other chemicals or constituents. To maintain compliance with discharge permits, the water 17 may need to be treated.
18 Overall, operation of the closed-cycle cooling alternative would produce substantially fewer 19 impacts to the aquatic environment relative to those caused by the existing once-through 20 system. The NRC staff concludes that the aquatic ecological impacts (including those to 21 threatened and endangered species) from the construction and operation of the hybrid 22 mechanical-draft closed-cycle cooling alternative for IP2 and IP3 would be SMALL.
23 Terrestrial ecology. Construction of the closed-cycle cooling alternative would entail clear-24 cutting of onsite trees and excavation of areas for the two cooling towers as described in the 25 Land Use section. These activities would destroy fragments of onsite eastern hardwood forest 26 habitat (NYSDEC 2007; NYSDEC 2008a). Effects of removing these habitats could include 27 localized reductions in productivity or relocations of some species.
28 Operation of the cooling towers also could have adverse localized impacts on terrestrial 29 ecology. The cooling towers would be about 46 to 50 m (150 to 165 ft) tall and would produce a 30 visible plume as well as minimal ground fog (Enercon 2003). The potential physical impacts 31 from a cooling tower plume include icing and fogging of surrounding vegetation during winter 32 conditions. Icing can damage trees and other vegetation near the cooling towers. The salt 33 content of the entrained moisture (drift) also has the potential to damage vegetation, depending 34 on concentrations (Enercon 2003). Enercon reported, however, that the predicted deposition 35 rates for the towers are on the order of the natural ambient salt deposition rate (Enercon 2003).
36 The hybrid cooling towers evaluated in this section have a drift rate of 0.001 percent (Enercon 37 2003). This amounts to 2.6 Ipm (0.7 gpm (0.00001 x 70,000 gpm of water)) drift for both towers.
38 The amount and effects of drift would vary depending on a number of factors, including the 39 concentration of salt in the droplets, the size of the droplets, the number of droplets per unit of 40 surface area, the species of plant affected, and the frequency of local precipitation.
41 Actual measurements of drift deposition have been collected at only a few nuclear plants.
42 These measurements indicate that, beyond about 1.5 kilometer (km) (about 1 mile (mi)) from 43 nuclear plant cooling towers, salt deposition is generally near natural levels (NRC 1996). The 44 NRC staff reported in the GElS that the salt-drift rate estimated to cause acute injury to the Draft NUREG-1437, Supplement 38 8-8 December 2008 OAG10001366_00323
Environmental Impacts of License Renewal 1 eastern/Canadian hemlock (a particularly sensitive species) is in excess of 940 kilograms (kg) 2 per square kilometer (km 2) (8.4 pounds per acre) per week (NRC 1996), well above the 3 anticipated deposition rates from the IP2 and IP3 cooling towers.
4 The NRC staff does not expect bird collisions with cooling towers to be a significant issue. The 5 NRC staff found in the GElS that impacts from collisions would be small at all plants with 6 existing cooling towers (NRC 1996).
7 Section 4.6.2 of this draft SEIS discusses the effects of license renewal on threatened or 8 endangered terrestrial species. The section identifies the endangered Indiana bat (Myotis 9 soda/is), the threatened bog turtle (C/emmys muhlenbergil), and the New England cottontail 10 (Sylvi/agus transitiona/is), a candidate species, as being potentially affected. However, because 11 of both the site-specific environment and the lack of evidence of the species existing at the 12 facility, potential impacts to these threatened or endangered species are considered SMALL.
13 While the effects of this alternative-including onsite land clearing and introduction of cooling 14 tower drift-are greater than the effects of the continued operation of the once-through cooling 15 system and are likely to be noticeable, they are not so great that they will have a destabilizing 16 effect on terrestrial resources in the vicinity of IP2 and IP3. The NRC staff concludes that the 17 overall effect on terrestrial ecology would be SMALL to MODERATE.
18
- Water Use and Quality 19 During construction of the alternative closed-cycle cooling systems at IP2 and IP3, changes in 20 water usage would likely be negligible. Increases may be seen in potable water demand for 21 construction workers and, if concrete is mixed on site, there would be additional demands.
22 However, these water needs would be short lived and would be at least partially offset by a 23 reduction in water use while IP2 and IP3 are in outages to install the closed-cycle cooling 24 system. For the term of construction, the additional water demands would need to be met by 25 the Village of Buchanan, which supplies water to the site. The Village of Buchanan purchases 26 public drinking water from surface water supplies.
27 The NYSDEC requires a construction general permit for storm water discharges from a project 28 such as construction of the hybrid cooling towers. In addition, the NYSDEC will require a 29 stormwater pollution prevention plan describing the use of silt fencing and other erosion-control 30 management practices that will be used to minimize impacts on surface water quality. The 31 construction project could also affect ground water as a result of dewatering excavations.
32 Evaporation losses (23,000 to 46,000 Ipm (6,000 to 12,000 gpm)) from the cooling towers will 33 have a negligible impact on water flow past the site. The estimated flow 150 m (500 ft) off the 34 shoreline is about 34 million Ipm (9 million gpm) in a 150-to-180-m (500-to-600-ft)-wide section 35 (Entergy 2007). Therefore, the evaporation loss would be approximately 0.1 percent of the river 36 flow. Further, the estuarine Hudson River is at sea level, and thus the river's water level would 37 not be affected by the cooling towers' consumptive water use.
38 To compensate for evaporative and discharge losses, makeup water from the Hudson River 39 would be treated to remove silt, suspended solids, biological material, and debris. Makeup 40 water may also need lime softening, a water treatment process that produces a waste sludge 41 that requires disposal. Biocides, such as hypochlorite, are often added to cooling water to 42 diminish the affects of the biofouling organisms (Entergy 2007). Other chemicals, such as 43 acids, dispersants, scale inhibitors, foam suppressants, and dechlorinators may also be needed December 2008 8-9 Draft NUREG-1437, Supplement 38 OAG10001366_00324
Environmental Impacts of License Renewal 1 for water treatment (NRC 1979).
2 To manage the chemicals and elevated concentrations of dissolved solids in the discharge 3 water, treatment would likely be necessary in accordance with the IP2 and IP3 site SPDES 4 permit. The use of biocides or any other chemicals would likely require discharge treatment and 5 additional monitoring.
6 The IP2 and IP3 site does not utilize ground water for cooling operations, service water, or 7 potable water. As such, the continued operation of the site is not expected to affect local 8 ground water supplies (EPA 2008a). Localized dewatering of ground water from excavations 9 may be necessary during construction operations, but because this ground water is not used by 10 Entergy or entities off site, and because the ground water discharges to the Hudson River after 11 exiting the IP2 and IP3 site, construction is not likely to affect either ground water quality or 12 ground water use.
13 Proper controls of runoff and treatment of other site discharges will not result in significant 14 impacts on the surface water (Hudson River) and evaporation losses are very small. Also, 15 ground water impacts from construction and operation of the cooling towers are expected to be 16 minor. Therefore, the NRC staff concludes that overall impacts to water resources and water 17 quality from the closed-cycle cooling alternative would be SMALL.
18
- Air Quality 19 The IP2 and IP3 site is located within the New Jersey-New York-Connecticut Interstate Air 20 Quality Control Region (40 CFR 81.13, "New Jersey-New York-Connecticut Interstate Air 21 Quality Control Region"). The air quality nonattainment issues associated with the portions of 22 these States located within a 50-mi radius are related to ozone (8-hour standard) and particulate 23 matter less than 2.5 microns (IJm) in diameter (PM 2 .5 ). The entire States of New Jersey and 24 Connecticut are designated nonattainment areas for ozone (8-hour standard). Several counties 25 in Central and Southeastern New York within a 50-mi radius are also in nonattainment status for 26 the 8-hour ozone standard (EPA 2008b). Air quality would be affected by three different factors:
27 replacement power during construction-related outages, construction activities and vehicles 28 (including worker transportation), and cooling tower operations.
29 Entergy contractors indicate that prolonged outages of IP2 and IP3, such as would be required 30 to install cooling towers (TRC 2002) would require replacement power from existing generating 31 facilities within the New York City metropolitan area. They assert that replacement of IP2 and 32 IP3 energy output during cooling tower installation would result in substantial increases in 33 regulated air pollutants. To the extent that coal- and natural-gas-fired facilities replace IP2 and 34 IP3 output, the NRC staff finds that some air quality effects would occur. The NRC staff finds 35 that these effects would cease when IP2 and IP3 return to service, with the exception of any 36 output lost to new parasitic loads from the closed-cycle cooling system.
37 Air quality at or near IP2 and IP3 during the construction of the IP2 and IP3 cooling towers 38 would be affected mostly by exhaust emissions from internal combustion engines. These 39 emissions would include carbon monoxide (CO), nitrogen oxides (NO x), volatile organic 40 compounds (VOCs), sulfur oxides (SOx), carbon dioxide (C0 2), and particulate matter 10 IJm or 41 less in diameter (PM1Q) from operation of gasoline- and diesel-powered heavy-duty construction 42 equipment, delivery vehicles, and workers' personal vehicles (these vehicles would also 43 produce or contribute to production of PM 2 .5 ). The amount of pollutants emitted from Draft NUREG-1437, Supplement 38 8-10 December 2008 OAG10001366_00325
Environmental Impacts of License Renewal 1 construction vehicles and equipment and construction worker traffic would likely be small 2 compared with total vehicular emissions in the region.
3 As noted in Section 3.3 of the GElS, a conformity analysis is required for each pollutant when 4 the total direct and indirect emissions caused by a proposed Federal action would exceed 5 established threshold emission levels in a nonattainment area. In the GElS, the NRC 6 determined that a major refurbishment activity may increase the facility workforce by up to 2300 7 construction, refurbishment, and refueling personnel during a significant refurbishment outage 8 period. The construction of two new cooling towers at IP2 and IP3 could approximate such 9 conditions; however, Entergy estimates that the construction activities would require an average 10 workforce of 300 additional workers with a maximum of about 600 workers (Enercon 2003).
11 Because IP2 and IP3 are in a nonattainment area for ozone, and emissions from vehicles of the 12 additional workforce may exceed the ozone air quality thresholds, a conformity analysis would 13 be required before construction.
14 Fugitive dust, a contributor to PM1Q, would be generated from site clearing and construction 15 traffic, blasting, and excavation. Given the size of the disturbed area that would be involved 16 (about 16 ha (40 ac)), and assuming that dust management practices would be applied (e.g.,
17 watering, silt fences, covering soil piles, revegetation), the fugitive dust impacts generated 18 during construction should be minor. Furthermore, the amount of road dust generated by the 19 vehicles traveling to and from the site transporting workers or hauling rock and dirt would 20 contribute to PM1Q concentrations. Construction stage impacts, though significant, would be 21 relatively short lived.
22 Operation stage impacts would, overall, be minor. As previously discussed, the cooling towers 23 would emit tower drift consisting of water, salt, and suspended solids. These emissions would 24 be considered PM10, and some portion may include PM2.5. Because IP2 and IP3 are located 25 in a nonattainment area for PM2.5, a conformity analysis for the cooling towers would be 26 necessary and may result in additional restrictions on emissions, additional compensatory 27 measures, or further control of drift from the towers. At a minimum, drift eliminators would likely 28 be required to keep these emissions to a low level.
29 Because air quality effects during construction would be controlled by site practices and 30 compensatory measures required to maintain compliance with the Clean Air Act (CAA) (should 31 a conformity analysis show the need to take other action), because replacement power would 32 be required to also comply with CAA requirements (and it would be short lived), and air quality 33 effects during operations would be minor, the NRC staff concludes that overall impact to air 34 quality is likely SMALL.
35
- Waste 36 Construction of the closed-cycle cooling alternative at IP2 and IP3 would generate some 37 construction debris and an estimated 2 million cy (1.5 million m3 ) of rock and soil (Entergy 38 2007). This material may be affected by onsite spills or other activities. Depending on the 39 characteristics of the material, it may be possible to reuse or recycle it. If the material cannot be 40 reused or recycled, it will have to be properly managed as a waste. Whether reused, recycled, 41 or disposed of, the material will have to be transported off site. If disposed of, the waste will 42 require additional offsite land use.
43 Some solid wastes may be generated by water treatment processes. Any such waste would be December 2008 8-11 Draft NUREG-1437, Supplement 38 OAG10001366_00326
Environmental Impacts of License Renewal 1 treated and/or disposed of in accordance with State solid waste regulations. During operation, 2 Entergy will have to maintain release of solids and chemicals to the blowdown water and, 3 subsequently, to the discharge canal and the Hudson River in accordance with IP2 and IP3 4 SPDES permits. Other solid wastes from tower operation and maintenance (including sludge 5 from the tower basins) would be managed and disposed of in accordance with applicable State 6 regulations at approved offsite facilities.
7 Based primarily on the large volume of rock and soil that would require offsite transportation and 8 may require disposal, the NRC staff concludes that waste-related impacts associated with the 9 closed-cycle cooling alternative at IP2 and IP3 could range from SMALL to LARGE, depending 10 on whether material can be reused or recycled.
11
- Human Health 12 Human health impacts for an operating nuclear power plant are identified in 10 CFR Part 51, 13 Subpart A, Appendix B, Table B-1. Potential impacts on human health from the operation of 14 closed-cycle cooling towers at nuclear power plants are evaluated in Section 4.3.6 of the GElS.
15 During construction activities there would be risk to workers from typical industrial incidents and 16 accidents. Accidental injuries are not uncommon in the construction industry and accidents 17 resulting in fatalities do occur. However, the occurrence of such events is mitigated by the use 18 of proper industrial hygiene practices, complying with worker safety requirements, and training.
19 Occupational and public health impacts during construction are expected to be controlled by 20 continued application of accepted industrial hygiene protocols, occupational health and safety 21 controls, and radiation protection practices.
22 Hybrid cooling towers at IP2 and IP3 would likely be equipped with sound attenuators (Entergy 23 2007). The topography of the area would provide additional attenuation of the noise levels. An 24 analysis of potential offsite noise levels resulting from both cooling towers operating 25 continuously indicated that the increase in noise levels at sensitive receptor sites would be 26 1 decibel or less, a level most likely not noticeable by the residents of the Village of Buchanan 27 (Enercon 2003).
28 The GElS evaluation of health effects from plants with cooling towers focuses on the threat to 29 workers from microbiological organisms whose presence might be enhanced by the thermal 30 conditions found in cooling towers. The microbiological organisms of concern are freshwater 31 organisms that are present at nuclear plants that use cooling ponds, lakes, or canals and that 32 discharge to small rivers (NRC 1996). Because the closed-cycle system at IP2 and IP3 would 33 operate using brackish water, and because the Hudson River does not meet the NRC's 34 definition of a small river, thermal enhancement of microbiological organisms is not expected to 35 be a concern.
36 Furthermore, as described in Section 4.3 of this draft SEIS, the NRC concludes that continued 37 operation of the facility would not increase the impacts of occupational radiation exposures 38 during the relicensing period. Overall, the NRC staff concludes that human health impacts from 39 the closed-cycle cooling alternative are considered SMALL.
40
- Socioeconomics 41 Entergy estimates that construction of the cooling towers would require an average workforce of 42 300 mostly temporary employees or contractors and could take an estimated 62 months.
Draft NUREG-1437, Supplement 38 8-12 December 2008 OAG10001366_00327
Environmental Impacts of License Renewal 1 During the outage phase of the effort, the temporary workforce could peak at 600 (Entergy 2 2007). For comparison purposes, a workforce of approximately 950 additional workers is on 3 site during a routine refueling outage (Entergy 2007).
4 As previously described, the impacts of relicensing and refurbishing IP2 and IP3 are addressed 5 in a site-specific case study presented in Appendix C (Section CA.4) to the GElS. The case 6 study postulated that major refurbishment activities could result in as many as 2300 workers on 7 site. In the case study, the workers were engaged in a variety of component replacement and 8 inspection activities. The case study employment estimate is significantly larger than Entergy's 9 estimate in the previous paragraph and is considered by the NRC staff to be the maximum 10 potential size of the temporary workforce because the GElS estimate includes a variety of 11 activities that will not be occurring at Indian Point during an outage to install a closed-cycle 12 cooling system. As of June 2006 the site had approximately 1255 full-time workers (Entergy 13 employees and baseline contractors) during normal plant operations (Entergy 2007).
14 The GElS case study concluded that, because the surrounding counties are high population 15 density areas as described in Section 4.4.1 of this draft SEIS, there will be available housing to 16 support the influx of workers. Therefore, the GElS concluded that any construction-related 17 impact on housing availability would likely be small. With even fewer workers on site than 18 anticipated in the GElS, impacts would be even less noticeable.
19 As reported by Levitan and Associates, Inc. (2005), payments-in-lieu-of-taxes (PILOT) are made 20 by Entergy to surrounding taxing jurisdictions. The PI LOT amounts would not likely be affected 21 by the construction of new closed-cycle cooling systems or other capital expenditures. In 22 accordance with the PI LOT agreements, this payment schedule will remain fixed through the 23 term of the current site licenses (Levitan and Associates, Inc. 2005). Because plant valuation is 24 not likely to change drastically with the installation of closed-cycle cooling (though it may 25 increase), PILOT payments are likely to stay at similar relative levels throughout the renewal 26 term.
27 The need for replacement power during construction may affect electricity prices, but the size of 28 this effect depends on the cost of replacement power and the duration of the outages. Plant 29 operators would likely schedule outages to avoid-to the extent possible-summer peak 30 demand periods to avoid affecting grid reliability and power transmission into New York City.
31 The NRC staff concludes that most socioeconomic impacts related to construction and 32 operation of cooling towers at the site would be SMALL.
33
- Transportation 34 Neither the NRC nor Entergy has conducted a study of the logistics for construction of cooling 35 towers. However, some adverse transportation impacts are likely. The greatest impacts would 36 likely occur during site excavation and would decline during construction. These impacts would 37 return to current levels following construction.
38 Offsite disposal of approximately 2 million cy (1.5 million m3 ) of rock and soil from the 39 excavation of the two cooling tower sites would be expected to have a significant impact on 40 local transportation infrastructure. As indicated by Entergy, the excavation phase of 41 construction would be expected to take at least 30 months to complete. In Entergy's estimates, 42 over 300,000 round trips would be needed over a period of 30 months to remove the excavated 43 materials in 6-cy dump trucks (370 truckloads per day at 7 days per week or 530 truckloads per December 2008 8-13 Draft NUREG-1437, Supplement 38 OAG10001366_00328
Environmental Impacts of License Renewal 1 day at 5 days per week given 1O-hour workdays). Traffic in the area is heavy and the additional 2 traffic from construction and site workers would cause increased traffic delays, particularly along 3 US Highway 9 and State Highway 9A (Entergy 2007).
4 An alternative to shipments of waste by truck may be to ship waste by barge on the Hudson 5 River. Entergy estimates that if 1000-ton barges were used to transport excavation debris, at 6 least five barges per day would have to be loaded and leave the site, with additional barge 7 staging required for returning barges (Entergy 2007). If shipped by barge, the waste would 8 need to be offloaded and likely would be transported by trucks to a disposal site. This would 9 shift the traffic impacts from the trucks to another location but the impacts could still be 10 significant.
11 During operations, NRC staff anticipates that the closed-cycle cooling system would have little 12 to no effect on transportation, and would likely be limited to occasional shipments of waste 13 cleaned out from cooling tower basins, occasional deliveries of chemicals used to prevent 14 fouling of the towers, and any replacement components necessary throughout the life of the 15 towers. As noted previously, fogging and icing is not expected to be significant.
16 Based on independent calculations of expected waste volumes from site excavations that were 17 on the same order of magnitude as the Entergy estimates, the NRC staff concludes that impacts 18 from transportation activities, primarily during excavation of the construction site, could be 19 significant and destabilizing, though temporary, during construction and will not be noticeable 20 during operations. Impacts, then, will be SMALL during operations, but LARGE during 21 construction.
22
- Aesthetics 23 IP2 and IP3 are already visible from the Hudson River, scenic overlooks on area highways, and 24 the Palisades Interstate State Park. The addition of the two cooling towers, standing between 25 46 and 50 m (150 to 165 ft), would make the entire facility more visible as the developed 26 footprint of the facility would be expanded. The clear-cutting of wooded areas for construction 27 of the towers would remove a visual buffer for some site structures, while the towers may 28 screen out other structures. The towers themselves would be clearly visible from offsite 29 vantage points. Entergy has indicated that it would preserve as many trees as possible and that 30 it would plant new trees to reestablish some visual buffers and help attenuate noise (Entergy 31 2007). Remaining and new trees could act as a partial visual buffer between the construction 32 sites and the river and a visual and noise buffer on land (Entergy 2007). Construction-related 33 impacts would be relatively short lived.
34 While the hybrid mechanical-draft cooling towers under consideration are designed to reduce 35 fog and ice production in the local area, fog and ice produced during operation could have an 36 impact on the aesthetics of the surrounding area. In particular, visible drift, though attenuated 37 by the hybrid design, may remain. Less noticeable moisture and salt deposition from the plume 38 may increase dampness and corrosion on surrounding property, which could affect the visual 39 environment. The circular hybrid design proposed by Entergy disperses remaining drift over a 40 greater area at a lower intensity than a single-stage wet mechanical-draft cooling tower 41 (Enercon 2003).
42 The NRC staff concludes that the impact of construction and operation of a closed-cycle cooling 43 system at IP2 and IP3 on aesthetics would likely be MODERATE, based on the physical Draft NUREG-1437, Supplement 38 8-14 December 2008 OAG10001366_00329
Environmental Impacts of License Renewal 1 dimensions of the cooling towers, the size of deforested buffer areas, and the potential for fog 2 and ice resulting from cooled water vapor.
3
- Historic and Archeological Resources 4 As noted in Section 4.4.5.1 of this draft SEIS, no previously recorded archeological or above 5 ground historic architectural resources are identified on the IP2 and IP3 property. In addition, a 6 Phase 1A survey was conducted on the property in 2006. The NRC staff identified 76 7 resources listed on the National Register of Historic Places (NRHP) within 5 miles of IP2 and 8 IP3.
9 There are registered historically significant buildings and sites within several kilometers of IP2 10 and IP3 and other nonregistered sites or buildings that may be eligible for registration (NRC 11 1996). However, the NRC case study presented in the GElS indicated that some unregistered 12 sites may go unprotected because the sites' significance may be discounted because of their 13 proximity to the IP2 and IP3 facility.
14 Entergy acknowledges that, before construction of cooling towers at the IP2 and IP3 facility can 15 begin, a survey of cultural resources may be needed to identify the potential resources in 16 previously undisturbed areas. The studies would include consultation with the State Historic 17 Preservation Office and appropriate Native American Tribes, as required under Section 106 of 18 the National Historic Preservation Act (NHPA). If historic or archeological resources are present 19 in previously disturbed areas or in undisturbed areas, they would have to be evaluated for 20 eligibility for listing on the NRHP.
21 Entergy has procedures for addressing historic and archeological resources (as noted in 22 Section 4.4.5.2), it has acknowledged the need to survey for unknown resources before 23 construction, and no significant historical or archeological resources have yet been identified in 24 areas likely to be disturbed. As a result, the NRC staff concludes that the impact from the 25 closed-cycle cooling alternative is likely to be SMALL.
26
- Environmental Justice 27 The NRC staff addresses environmental justice impacts of continued operations in Section 4.4.6 28 of this draft SEIS. Construction and operation of cooling towers at IP2 and IP3 would have an 29 impact on environmental justice if environmental impacts of cooling system construction and 30 operation affected minority and low-income populations in a disproportionately high and adverse 31 manner.
32 Within the 50-mi (80-km) radius of the IP2 and IP3 site, a number of potential environmental 33 impacts (onsite land use, aesthetics, air quality, waste management, and socioeconomic 34 impacts) could affect populations in the immediate vicinity of the site. However, the potentially 35 affected populations for the construction and operation of the closed-cycle cooling alternative, 36 including residents of the Villages of Buchanan and Verplanck, contain low percentages of 37 minority and low-income populations.
38 Overall, low-income populations within the 50-mi (80-km) radius represent a small percentage of 39 the total population. The low-income population was approximately 11.7 percent of the total 40 population in the combined four-State reference area, or 10.4 percent when the individual 41 States were used as the geographic area. According to 2004 census data, the percentages of 42 people below the low-income criteria in Dutchess and Westchester Counties were 7.7 percent December 2008 8-15 Draft NUREG-1437, Supplement 38 OAG10001366_00330
Environmental Impacts of License Renewal 1 and 8.9 percent, respectively.
2 The 2000 census indicates that 32.1 percent of the population within the 50-mi (80-km) radius 3 and 25.1 percent of the population for the four-State reference area were minority for all races 4 combined. The 2000 census also indicates that the total minority populations of the Villages of 5 Buchanan and Verplanck were 7 percent and 11 percent, respectively.
6 Therefore, the local populations that would be most directly affected by the proposed action 7 contain lower percentages of minorities and low-income populations than the entire 50-mi (80-8 km) area and the four-State reference area.
9 As noted earlier in this section, replacement power required during a 42-week outage could 10 increase air quality effects, depending on the location and characteristics of generator units 11 used to replace IP2 and IP3 output. These effects are likely to be short-lived (most will be no 12 longer than the outage period), and may vary with time of year, scheduled outages at other 13 facilities, and generator pricing on the NYISO grid. Additionally, impacts would occur near 14 existing facilities and would result from incremental increases rather than new effects. As a 15 result, impacts are likely to be small. The NRC staff concludes, then, that the overall 16 environmental justice impacts of constructing and operating a closed-cycle cooling system at 17 the IP2 and IP3 site are likely to be SMALL.
18 8.1.2 Modified Existing Once-Through Cooling System with Restoration 19 Alternative 20 The NYSDEC proposal of closed-cycle cooling as the site-specific BTA to protect aquatic life in 21 the draft SPDES permit for IP2 and IP3 (NYSDEC 2003a) is intended to dramatically reduce the 22 entrainment and impingement of aquatic life in the IP2 and IP3 cooling system, thus reducing 23 impacts to fish populations in the Hudson River estuary. Under the terms of the draft SPDES 24 permit, Entergy may propose a different approach that would reduce adverse environmental 25 impacts to an equivalent level (NYSDEC 2003b). The alternative proposed in this section 26 combines the existing once-through cooling system with alternative intake technologies and 27 additional restoration alternatives so that the net impact of the IP2 and IP3 cooling water intake 28 structures is equivalent to the impact from the operation of a new closed-cycle cooling system.
Draft NUREG-1437, Supplement 38 8-16 December 2008 OAG10001366_00331
Environmental Impacts of License Renewal 1 8.1.2.1 Description of the Modified Existing Once-Through Cooling System with 2 Restoration Alternative 3 This alternative would reduce impingement and entrainment losses by retrofitting the IP2 and 4 IP3 existing once-through cooling systems with improved intake technology, altering operations 5 of the cooling system, and implementing restoration measures within the Hudson River estuary.
6 Under the terms of the draft SPDES permit, the combined impacts of these actions would have 7 to meet the same performance measures as a closed-cycle cooling system. As described in 8 Section 8.1.1.2 (Aquatic Ecology for the closed-cycle cooling alternative), the amount of water 9 withdrawn from the Hudson River for IP2 and IP3 following implementation of the closed-cycle 10 cooling system alternative would be reduced by 93 to 95 percent. To meet the requirements of 11 the draft SPDES permit (NYSDEC 2003a), the modified once-through cooling system and 12 combined restoration alternatives would have to result in a net entrainment and impingement 13 reduction of 93 to 95 percent for species most affected by the existing system. The NRC staff 14 examined other potential mitigation options to reduce impacts to aquatic life in Section 4.1.5 of 15 this draft SEIS and concludes that one or a combination of these mitigation measures could be 16 used as part of this alternative.
17 Restoration of wetlands or other aquatic habitats in the Hudson River estuary would likely be 18 included as an aspect of any program designed to offset the residual impacts of once-through 19 cooling-water systems. The New York-New Jersey Harbor is one of the 28 National Estuary 20 Programs charged with developing and implementing a plan to protect, conserve, and restore 21 the estuary (NY-NJ HEP Undated-a). A Comprehensive Conservation and Management Plan 22 (CCMP) establishes priorities for activities, research, and funding for the estuary program. The 23 core areas of the estuary stretch north on the Hudson to Piermont Marsh (south of IP2 and IP3; 24 Piermont Marsh is near the southern end of the Tappan Zee river segment in Figure 2-10 in 25 Chapter 2) (NY-NJ HEP Undated-b), but priorities identified in the CCMP could guide possible 26 restoration activities. In addition, restoration activities would also be conducted in accordance 27 with the NYSDEC Hudson River Estuary Program, a regional partnership designed to protect, 28 conserve, restore, and enhance the estuary.
29 The estuarine wetlands and shallows of the Hudson River provide foraging habitat and shelter, 30 serve as nursery areas for early life stages and juveniles of fish and shellfish, and contribute to 31 the aquatic food web. An increase in wetlands or other aquatic habitats in the Hudson River 32 estuary could support increased populations of some species affected by the IP2 and IP3 33 cooling-system operations and thus offset entrainment and impingement losses of those 34 species.
35 Staff, consultants, or contractors would need to determine where restoration projects should 36 take place before a wetland restoration plan could be designed. The restoration plan would 37 indicate the size and location of restoration projects needed to add to aquatic populations at 38 essentially the levels that the modified once-through cooling system depletes them. Because of 39 the steep slopes on the banks of the river near the IP2 and IP3 facility, there are no significant 40 wetland areas in the immediate vicinity of the site. Therefore, wetland restoration activities 41 would likely need to take place away from the site.
42 The restoration alternative could build on features of the Hudson River Settlement Agreement 43 (HRSA; addressed in greater depth in Section 2.2.5.3 of this draft SEIS). Measures to limit 44 aquatic impacts of Hudson River Power plants discussed in the HRSA include partial outages December 2008 8-17 Draft NUREG-1437, Supplement 38 OAG10001366_00332
Environmental Impacts of License Renewal 1 for some Hudson River power plants during key spawning months, funding and operating a 2 striped bass hatchery, conducting biological monitoring, and setting up a $12-million endowment 3 for a new foundation for independent research on mitigating fish impacts by power plants.
4 As noted in Chapter 2 of this SEIS, the HRSA was replaced by four consecutive judicially 5 approved consent orders. Each of these consent orders effectively continued the HRSA terms 6 and conditions, with two exceptions. Neither consent order required outages at IP2 or IP3 or 7 the continued operation of the striped bass hatchery.
8 As described in the draft SPDES permit, financial support of organizations that can have a direct 9 impact on the health of the Hudson River estuary, such as the Hudson River Estuary 10 Restoration Fund (HRERF), is another possible piece of a restoration alternative. The draft 11 SPDES permit would require a payment of $24 million to the HRERF by Entergy (NYSDEC 12 2003a, 2003c) until it constructs closed-cycle cooling. An alternative to the construction and 13 operation of the closed-cycle cooling systems could include additional funding to the HRERF 14 and groups like it.
15 8.1.2.2 Environmental Impacts of the Modified Existing Once-Through Cooling System 16 with Restoration Alternative 17 In this section, the NRC staff discusses the impacts that would occur if the existing once-18 through cooling system intakes at IP2 and IP3 were modified, and restoration actions were 19 implemented, as described in Section 8.1.2.1 of this draft SEIS. These actions would need to 20 meet the expected requirements of the NYSDEC-issued SPDES permit. The anticipated 21 environmental impacts of this alternative are summarized in Table 8-1 with discussions on each 22 impact category provided in the following paragraphs.
23 For most issues, the impacts of operating the modified once-through cooling system and 24 restoration alternative would be the same or lower than the impacts associated with the existing 25 once-through cooling system presented in Section 4.1 of this draft SEIS. Only the impacts on 26 land use would likely be greater with the modified cooling system and restoration alternative 27 than with continued operation of the existing system.
28
- Land Use 29 Any restoration plan will have some impact on land use. Because of the steep slopes on the 30 banks of the river near the IP2 and IP3 facility, there are no significant wetland or shallows 31 areas near the site to support restoration activities. Therefore, restoration activities would likely 32 need to take place at locations further away from the site.
33 There would be noticeable short-term construction impacts on land use in any areas designated 34 for restoration by the restoration plan. Site preparation could include grading and recontouring, 35 removal of contaminated sediments, and/or replacement of sediments. Restoration often 36 requires the removal of invasive and nonnative plant species through the use of herbicides, 37 prescribed burning, biocontrol, or a combination of techniques. Following the removal of 38 invasive species, the planting of native wetland and upland species along a hydrologic gradient 39 is often required. Restoration activities would likely be conducted in accordance with the 40 NYSDEC Hudson River Estuary program.
41 Once initial restoration activities are complete, restored wetlands usually require periodic 42 maintenance such as prescribed burning, herbicide application, and planting to maintain the 43 desired mix of native plant species. Monitoring may be required for restored nearshore aquatic Draft NUREG-1437, Supplement 38 8-18 December 2008 OAG10001366_00333
Environmental Impacts of License Renewal 1 habitats. These activities could be required throughout the license renewal period. It is unlikely 2 that "operation" of a restoration site will have long-term effects on land use unless restoration 3 converts previously dry land into wetlands. Operation of the restoration site may have some 4 benefits to nearby landowners or users if the site was previously degraded.
5 Land also would be needed for construction of a new fish hatchery. The impacts to land use 6 would likely be minimal, especially if the construction site was in a previously developed area.
7 The NRC staff concludes that the activities related to restoration and maintenance of wetlands, 8 and construction and operation of a new fish hatchery, would likely result in SMALL to 9 MODERATE land use impacts.
10
- Ecology 11 Aguatic ecoloav. Implementation of a well-developed restoration plan would, as designed, have 12 an overall positive impact on aquatic ecology. There may, however, be some short-term 13 negative impacts during the initial stages of restoration and/or construction activities. A 14 restoration plan would indicate specific locations where restoration activities would take place, 15 as well as the types and duration of activities. In the absence of such a plan, only an estimate 16 of impacts is possible. To achieve performance equivalent to the 93-to-95-percent reduction in 17 impingement and entrainment likely to be achieved with closed-cycle cooling, the restoration 18 alternative would likely also need to include some intake modifications as described in 19 Section 4.1.5 of this draft SEIS, and/or modifications to pumping rates, which could reduce 20 impingement or entrainment.
21 During wetland restoration and construction of the fish hatchery, the NRC staff expects that 22 impacts to aquatic ecology would be negative. Wetland restoration could initially increase rates 23 of runoff and sedimentation, or release pollutants trapped in sediments. Construction of the fish 24 hatchery could create runoff during construction, though this would likely be minor. During 25 operations, however, any fish hatchery would have to comply with requirements of its own 26 State-issued SPDES permit to control releases of pollutants to any nearby water bodies, likely 27 including the Hudson River.
28 If this alternative achieves its intended goals-which would require rigorous monitoring-then 29 the NRC staff concludes that the overall net impacts of the cooling system modifications and 30 restoration alternative on aquatic ecology would be SMALL during operation, and MODERATE 31 during construction.
32 Terrestrial ecology. Implementation of a well-developed restoration plan, cooling system intake 33 modifications, and construction activities will produce few impacts upon the terrestrial 34 environment or threatened or endangered terrestrial species. Impacts to terrestrial ecology 35 would be most noticeable during construction, when any land conversion would take place, and 36 when site crews may need to construct roads or laydown areas for equipment used to restore 37 the wetland or construct the hatchery. Impacts from these activities would be highly site 38 specific, but they are localized and short lived.
39 Once construction and initial restoration conclude, impacts to terrestrial ecology will be minor, 40 and may be positive for the restoration portion of this alternative. Wetlands can increase the 41 ecological value of nearby land area and provide habitat for some species that are largely 42 terrestrial. Overall, the NRC staff concludes that the terrestrial ecological impacts from the 43 cooling system modification and restoration alternative at IP2 and IP3 would be SMALL to December 2008 8-19 Draft NUREG-1437, Supplement 38 OAG10001366_00334
Environmental Impacts of License Renewal 1 MODERATE, as some impacts may be noticeable during construction.
2
- Water Use and Quality 3 As noted in the Ecology section for this alternative, wetland restoration could initially increase 4 rates of runoff and sedimentation or release pollutants trapped in sediments. Wetland 5 restoration will modify the hydrologic behavior of the restoration site, and often includes 6 measures that can affect surrounding water quality once the site is operational. Hydrologic 7 modifications at a restoration site could include (1) installation of structures that control water 8 flow and affect flow patterns, (2) the removal of dikes or berms, (3) the removal of drainage 9 channels that drain water away from a site, and (4) the creation of new drainage channels or 10 basins. Once operational, wetland restoration sites help to improve surface water quality by 11 allowing natural processes to break down pollutants before being transported into open water.
12 Construction of the fish hatchery will also create some site runoff, though good construction 13 practices should limit this impact. Once operational, the fish hatchery would have to comply 14 with requirements of its own State-issued SPDES permit to control releases of pollutants to any 15 nearby water bodies, likely including the Hudson River. Fish hatcheries produce nutrient-rich 16 water that may require treatment before release.
17 While some construction-stage impacts may be noticeable, the long-term operational effects are 18 minor, and may be beneficial. Operational impacts are SMALL, while construction impacts are 19 MODERATE.
20
- Air Quality 21 Because the restoration alternative contains only relatively small-scale construction projects and 22 does not involve the installation of any major sources of air emissions, it is unlikely that this 23 alternative would trigger noticeable air quality impacts. As a result, the NRC staff concludes 24 that overall impacts to air quality from this alternative would be SMALL.
25
- Waste 26 Construction of a new fish hatchery would generate a small amount of construction debris, and 27 wetland restoration may leave some land-clearing debris that crews would likely dispose of on 28 site. Any cooling system modification activities are expected to generate modest amounts of 29 wastes for a short period of time. Ongoing operation of the fish hatchery is also expected to 30 generate small amounts of waste, most of which would probably leave the site in liquid form 31 under the restrictions of a State-issued discharge permit. Therefore, the NRC staff concludes 32 that waste-related impacts associated with the cooling system modification and restoration 33 alternative at IP2 and IP3 would be SMALL.
34
- Human Health 35 Construction of a new fish hatchery would present some general construction-related 36 occupational hazards, as would installation of cooling system modifications. Wetland 37 restoration activities also would present some occupational and environmental exposure 38 hazards. Restoration activities may have positive effects if they improve the quality of water in 39 portions of the Hudson that supply drinking water, as well as to the extent that they provide 40 unpolluted habitat for fish or shellfish that humans may consume.
41 As described in Section 4.3 of this draft SEIS, the NRC concludes that continued operation of Draft NUREG-1437, Supplement 38 8-20 December 2008 OAG10001366_00335
Environmental Impacts of License Renewal 1 the facility would not increase the impacts of occupational radiation exposures during the 2 relicensing period, nor would they likely affect radiation exposures to the public. Furthermore, 3 there would be no significant noise sources associated with construction or operation of the fish 4 hatchery or restoration activities that could not be effectively mitigated to protect site workers or 5 offsite individuals.
6 Overall, the NRC staff concludes that human health impacts from the cooling system 7 modification and restoration alternative are SMALL.
8
- Socioeconomics (including Transportation) 9 Section 4.4 of this draft SEIS describes the socioeconomic impacts of the continued operation 10 of the IP2 and IP3 facility. The cooling system modification and restoration alternative at IP2 11 and IP3 would not significantly change employment at or near IP2 and IP3. There would also 12 be no significant changes in the tax base for the region or in traffic flow or traffic patterns.
13 Therefore, the NRC staff concludes that overall socioeconomic impacts of the alternative would 14 be SMALL.
15
- Aesthetics 16 The proposed restoration alternative would have no significant impact on the aesthetic value of 17 the IP2 and IP3 facility. Cooling system modification and restoration likely would not have any 18 onsite impacts that would change the overall appearance of the site. Wetland restorations could 19 have a long-term positive impact on aesthetics, or at least minimal negative impacts.
20 Construction of a new fish hatchery would have limited visual effects because most structures 21 (tanks or ponds, storage buildings, pumphouses) are unobtrusive. Even if some negative 22 impacts occur during construction, long-term negative impacts during operation are unlikely.
23 The NRC staff concludes that the impact of the cooling system modification and restoration at 24 IP2 and IP3 on aesthetics would be SMALL.
25
- Historic and Archeological Resources 26 As noted in Section 4.4.5.1 of this draft SEIS, no previously recorded archeological or above-27 ground historic architectural resources have been identified on the IP2 and IP3 site. In addition, 28 a Phase 1A survey was conducted for the site in 2006. The NRC staff identified 76 resources 29 listed on the NRHP within 5 miles of IP2 and IP3.
30 The NHPA requires archeological surveys to identify and evaluate historic and archeological 31 resources in areas identified for restoration and construction would be required before initiation 32 of ground-disturbing activities. The studies would include consultation with the State Historic 33 Preservation Office (NYSHPO) and appropriate American Indian Tribes.
34 Many shell midden sites (ancient shell mounds) or other signs of past human activities occur 35 adjacent to wetland areas, and such sites may be encountered during surveys. Aspects of the 36 NHPA require that lands not previously surveyed be investigated by a professional archeologist 37 in consultation with the NYSHPO before any ground-disturbing activities. Through consultation, 38 whatever entity constructs the fish hatchery or wetland restoration site would identify ways to 39 reduce or avoid adverse impacts. It is possible that construction may have a noticeable effect 40 on historic and archeological resources.
41 Once operational, the restoration option would essentially have no impact on historic or December 2008 8-21 Draft NUREG-1437, Supplement 38 OAG10001366_00336
Environmental Impacts of License Renewal 1 archeological resources. The impact of restoration and construction on historic and 2 archeological resources could range from SMALL during operation to MODERATE during 3 construction, depending on the locations chosen for wetland restoration and construction of a 4 new fish hatchery, the number of sites recorded in those locations, and whether the recorded 5 sites are significant (i.e., eligible for listing on NRHP).
6
- Environmental Justice 7 Section 4.4.6 of this draft SEIS discusses the environmental justice impacts of continued plant 8 operation. Modification to the existing once-through cooling system intakes at IP2 and IP3 and 9 restoration of wetlands could have an impact on environmental justice if environmental impacts 10 of modifications affected minority and low-income populations in a disproportionately high and 11 adverse manner.
12 However, as described in Section 8.1.1.1 of this draft SEIS, under the Environmental Justice 13 section, the local populations that would be most affected by the proposed action contain lower 14 percentages of minorities and low-income populations than the entire 50-mi radius area and the 15 four-State reference area. As such, the NRC staff concludes that the environmental justice 16 impacts of the modified once-through cooling system and restoration alternative at the IP2 and 17 IP3 site would be SMALL.
Draft NUREG-1437, Supplement 38 8-22 December 2008 OAG10001366_00337
Environmental Impacts of License Renewal 1 Table 8-1. Summary of Environmental Impacts of a Closed-Cycle Cooling Alternative and 2 a Modified Existing Once-Through Cooling System with Restoration Alternative 3 at IP2 and IP3 New Closed-Cycle Once-Through Cooling Impact Cooling Alternative with Restoration Alternative Category Impact Comments Impact Comments Land Use SMALL to Construction of towers SMALL to Short-term land LARGE requires about 16 ha MODERATE disturbances may (40 ac). Waste result from habitat disposal may require restoration; land use much offsite land. changes at the fish hatchery site.
Ecology: SMALL Entrainment and SMALL to Entrainment and Aquatic impingement of aquatic MODERATE impingement of organisms, as well as aquatic organisms heat shock would be reduced, while reduced substantially. restoration of habitat benefits many species.
Noticeable impacts occur during construction.
Ecology: SMALL to Onsite forest habitats SMALL to Impacts may occur Terrestrial MODERATE disturbed while drift MODERATE from offsite from towers may affect construction and vegetation. temporary impacts in the restoration area.
Operational issues are minor.
Water Use and SMALL Releases to surface SMALL to Short-term impacts Quality water would be treated MODERATE from construction and as necessary to meet restoration can be permit requirements. controlled using Runoff from management construction activities practices, though is likely to be noticeable impacts controlled. may occur.
December 2008 8-23 Draft NUREG-1437, Supplement 38 OAG10001366_00338
Environmental Impacts of License Renewal 1 Table 8-1 (continued)
New Closed-Cycle Existing Once-Through Cooling Impact Cooling Alternative with Restoration Alternatives Category Impact Comments Impact Comments Air Quality SMALL Primary impacts from SMALL Minor impacts from vehicles and fugitive dust and equipment emissions emissions from during construction, as vehicles and well as replacement equipment occur power. Existing during construction.
regulations should limit effects.
Waste SMALL to Construction would SMALL Activities would LARGE generate about generate easily 2 million cy of soil, managed volumes of rock, and debris waste.
requiring offsite disposal.
Human Health SMALL Workers experience SMALL Workers experience minor accident risk minor accident risk during construction. during construction.
No impacts on human No negative impacts health during on human health operation. during operation.
Socioeconomics SMALL No impact to offsite SMALL This alternative housing or public creates insignificant services occurs. changes in area employment levels or tax revenues.
Transportation SMALL to Increased traffic SMALL Insignificant changes LARGE associated with in traffic volumes construction (workers result.
and waste disposal) would be significant, though little effect during operations.
Aesthetics MODERATE Construction of two SMALL Onsite aesthetics towers, 150 to 165 ft would not likely tall, would have a change significantly.
noticeable impact on Wetland restorations the aesthetics of the would have a long-site. Minor plume and term positive effect on noise issues could aesthetics.
occur.
Draft NUREG-1437, Supplement 38 8-24 December 2008 OAG10001366_00339
Environmental Impacts of License Renewal 1 Table 8-1 (continued)
New Closed-Cycle Existing Once-Through Cooling Impact Cooling Alternative with Restoration Alternatives Category Impact Comments Impact Comments Historical and SMALL Existing procedures SMALL to Impacts could reach Archeological are adequate to protect MODERATE moderate during Resources resources on the construction in largely-disturbed site. sensitive areas.
Environmental SMALL No significant impacts SMALL No significant impacts Justice are anticipated that are anticipated that could disproportion- could disproportion-ately affect minority or ately affect minority or low-income low-income communities. communities.
2 8.2 No-Action Alternative 3 The NRC regulations implementing the National Environmental Policy Act of 1969, as amended 4 (NEPA) (see 10 CFR Part 51, Subpart A, Appendix A, paragraph 4), specify that the no-action 5 alternative will be discussed in an NRC environmental impact statement.
6 For license renewal, the no-action alternative refers to a scenario in which the NRC would not 7 renew the IP2 and IP3 operating licenses and Entergy would then cease operating both units on 8 or before the expiration of their current operating licenses. Following the shutdown of each unit, 9 Entergy would initiate decommissioning of the facility in accordance with the NRC 10 decommissioning requirements in 10 CFR 50.82, "Termination of License." Full dismantling of 11 structures and decontamination of the site may not occur for up to 60 years after plant 12 shutdown.
13 Regardless of whether or not the IP2 and IP3 operating licenses are renewed, the facility's 14 owner will eventually be required to shut down the reactors and decommission the IP2 and IP3 15 facility. If the operating licenses are renewed, shutdown and decommissioning activities would 16 not be avoided but would be postponed for up to an additional 20 years.
17 The environmental impacts associated with decommissioning, following a license renewal 18 period of up to 20 years or following the no-action alternative, would be bounded by the 19 discussion of impacts in Chapter 7 of the GElS, Chapter 7 of this draft SEIS, and NUREG-0586, 20 "Final Environmental Impact Statement on Decommissioning of Nuclear Facilities" (NRC 2002).
21 The impacts of decommissioning after 60 years of operation are not expected to be significantly 22 different from those occurring after 40 years of operation.
December 2008 8-25 Draft NUREG-1437, Supplement 38 OAG10001366_00340
Environmental Impacts of License Renewal 1 Table 8-2. Summary of Environmental Impacts of the No-Action Alternative Impact Category Impact Comment Land Use SMALL Impacts are expected to be SMALL because plant shutdown is expected to result in few changes to offsite and onsite land use, and transition to alternate uses is expected over an extended timeframe.
Ecology SMALL Negative impacts to aquatic ecology of the Hudson River will cease. The overall impact is SMALL.
Water Use and SMALL Impacts are expected to be SMALL as no new impacts occur Quality with plant shutdown.
Air Quality SMALL Impacts are expected to be SMALL because emissions related to plant operation and worker transportation will decrease.
Waste SMALL Impacts are expected to be SMALL because generation of high-level waste will stop and generation of low-level and mixed waste will decrease.
Human Health SMALL Impacts are expected to be SMALL because radiological doses to workers and members of the public, which are within regulatory limits, will be reduced.
Socioeconomics SMALL to Impacts vary by jurisdiction, with some areas experiencing MODERATE MODERATE effects.
Socioeconomics SMALL Impacts are expected to be SMALL because the decrease in (Transportation) employment would reduce traffic.
Aesthetics SMALL Impacts are expected to be SMALL because plant structures will remain after plant shutdown.
Historic and SMALL Impacts are expected to be SMALL because shutdown of the Archeological plant will not immediately change land use.
Resources Environmental Justice SMALL Impacts are expected to be SMALL because there are no significant disproportionate impacts to minority or low-income populations.
Draft NUREG-1437, Supplement 38 8-26 December 2008 OAG10001366_00341
Environmental Impacts of License Renewal 1 Impacts from the decision to permanently cease operations are not considered in NUREG-0586, 2 or its Supplement 1. (2) Therefore, immediate impacts that occur between plant shutdown and 3 the beginning of decommissioning are considered here. These impacts will occur when the 4 units shut down regardless of whether the license is renewed (see Table 8-2).
5 Plant shutdown will result in a net loss of power generating capacity. The power not generated 6 by IP2 and IP3 during the license renewal term would likely be replaced by (1) power supplied 7 by other producers (either existing or new units) using generating technologies that may differ 8 from that employed at IP2 and IP3, (2) demand-side management and energy conservation, or 9 (3) some combination of these options. The environmental impacts of these options are 10 discussed in Section 8.3 of this draft SEIS. While these options can be alternatives to license 11 renewal (given sufficient resource availability), they also constitute potential consequences of 12 the no-action alternative. Impacts from these options will addressed in their respective portions 13 of this Section.
14 This draft SEIS does not assess the specifics of the need for corrections to reactive power that 15 would be required if IP2 and IP3 were shut down. Reactive power (i.e., power stored in 16 magnetic fields throughout the power grid) is essential for the smooth operation of the 17 transmission grid because it helps hold the voltage to desired levels. It may be possible to use 18 the existing generators at IP2 and IP3 as a source of reactive power even if IP2 and IP3 are 19 shut down. As "synchronous condensers," the generators could add reactive power (but not 20 real power) to the transmission system (National Research Council 2006). Because it is 21 assumed that the generators would be operated as synchronous condensers only until the 22 reactive power could be supported by new, real replacement power generation, their operation 23 is not considered as a significant contributor to the impacts described below. Further, as a shut-24 down nuclear power plant may not be decommissioned for many years after shutdown, the 25 continued operation of IP2 and IP3 generators would not necessarily slow or impede 26 decommissioning activities.
27
- Land Use 28 In Chapter 4 of this draft SEIS, the NRC staff concluded that the impacts of continued plant 29 operation on land use would be SMALL. Onsite land use will not be affected immediately by 30 plant shutdowns. Plant structures and other facilities are likely to remain in place until 31 decommissioning. In the near term, the transmission lines associated with IP2 and IP3 will 32 likely remain in place. In the long term, it is possible that the transmission lines that extend from 33 the onsite switchyard to major transmission corridors will be removed. As a result, the 34 transmission line ROWs will no longer be maintained and the ROW will be available for other 35 uses. Also, as a result of plant shutdowns, there would be a reduction in uranium mining activity 36 on approximately 870 ha (2160 ac), or 405 ha (1000 ac) per 1000 MW(e) (NRC 1996).
37 Therefore, the staff concludes that the impacts on land use from plant shutdown would be 38 SMALL.
39
- Ecology 40 In Chapter 4 of this draft SEIS, the NRC staff concluded that aquatic ecological impacts of (2)
Appendix J, "Socioeconomic and Environmental Justice Impacts Related to the Decision to Permanently Cease Operations," to NUREG-0586, Supplement 1, discusses the socioeconomic impacts of plant closure, but the results of the analysis in Appendix J are not incorporated in the analysis presented in the main body of the NUREG.
December 2008 8-27 Draft NUREG-1437, Supplement 38 OAG10001366_00342
Environmental Impacts of License Renewal 1 continued plant operation were SMALL to LARGE because of the entrainment and impingement 2 of aquatic species, depending on the species. The NRC staff also concluded that thermal shock 3 could have a SMALL to MODERATE impact. Terrestrial ecological impacts were SMALL.
4 Cessation of operations will eliminate cooling water intakes from and discharges to the Hudson 5 River. The environmental impacts to aquatic species, including threatened and endangered 6 species, associated with these changes are generally positive because entrainment and 7 impingement issues will be eliminated, as would impacts from the plant's thermal plume. The 8 NRC staff expects that impacts to aquatic ecology, including to the endangered shortnose 9 sturgeon, would decline to SMALL if the plant shuts down.
10 The impacts of plant closure on the terrestrial ecosystem could be both negative and positive, 11 depending on final disposition of the IP2 and IP3 site. Currently, there is a fragment of eastern 12 deciduous hardwood habitat in the exclusion area of the facility that Entergy indicates has not 13 been previously developed. This fragment could be destroyed by new development once 14 access is no longer restricted. Plant closure will not directly affect this fragment, however, and a 15 prolonged period prior to site decontamination may also provide protection for this fragment.
16 Overall, the NRC staff concludes that ecological impacts from shutdown of the plant would be 17 SMALL.
18
- Water Use and Quality 19 When the plant stops operating and cooling water is no longer needed, there will be an 20 immediate reduction in water withdrawals from and discharge to the Hudson River. This will 21 reduce evaporation from the river in the vicinity of the plant and will result in decreased 22 discharges of biocides and other chemicals. Therefore, the staff concludes that the impacts on 23 surface water use and quality from plant shutdown would be less noticeable than current 24 operations and would remain SMALL.
25 Ground water at the IP2 and IP3 site contains elevated concentrations of tritium (EPA 2004). In 26 Sections 2.2.7 and 4.5 of this draft SEIS, the NRC staff examined available information on 27 leakage to ground water and determined that the issue, while new, is not significant. The 28 source of the contamination is believed to be historical leakage from the IP1 and IP2 spent fuel 29 pools. Since discovering the leaks, Entergy has removed fuel from the IP1 spent fuel pool and 30 drained it. The no-action alternative would not, on its own, affect ground water contamination.
31 Consequently, the NRC staff concludes that ground water quality impacts from shutdown of the 32 plant would be SMALL.
33
- Air Quality 34 In Chapter 4 of this draft SEIS, the NRC staff adopted the findings in the GElS that the impacts 35 of continued plant operation on air quality would be SMALL. When the plant stops operating, 36 there will be a reduction in emissions from activities related to plant operation (e.g., use of diesel 37 generators and vehicles to transport workers to the site). As such, the NRC staff concludes that 38 the impact on air quality from shutdown of the plant would be SMALL.
39
- Waste 40 The impacts of waste generated by continued plant operation are discussed in Chapter 6 of this 41 draft SEIS. The impacts of low-level and mixed waste from plant operation are characterized as 42 SMALL. When IP2 and IP3 stop operating, the plant will stop generating high-level waste and 43 generation of low-level and mixed waste associated with plant operation will briefly increase, Draft NUREG-1437, Supplement 38 8-28 December 2008 OAG10001366_00343
Environmental Impacts of License Renewal 1 and then will decline. Therefore, the staff concludes that the impacts of waste generated after 2 shutdown of the plant would be SMALL.
3 Wastes associated with plant decommissioning are unavoidable and will be significant whether 4 the plant is decommissioned at the end of the initial license term or at the end of the period of 5 extended operation. The no-action alternative will not have an appreciable affect on waste 6 volumes associated with decommissioning.
7
- Human Health 8 In Chapter 4 of this draft SEIS, the NRC staff concluded that the impacts of continued plant 9 operation on human health are SMALL. After cessation of plant operations, the amount of 10 radioactive material released to the environment in gaseous and liquid forms, which are 11 currently within regulatory limits, will be reduced. Therefore, the NRC staff concludes that the 12 impact of plant shutdown on human health also would be SMALL. In addition, the variety of 13 potential accidents at the plant will be reduced to a limited set associated with shutdown events 14 and fuel handling. In Chapter 5 of this draft SEIS, the staff concluded that impacts of accidents 15 during operation are SMALL. Therefore, the NRC staff concludes that the impacts of potential 16 accidents following shutdown of IP2 and IP3 also would be SMALL.
17
- Socioeconomics 18 In Chapter 4 of this draft SEIS, the NRC staff concluded that the socioeconomic impacts of 19 continued plant operation would be SMALL. Should the plant shut down, there would be 20 immediate socioeconomic impacts from loss of jobs (some, though not all, of the approximately 21 1255 full-time employees and baseline contractors would begin to leave the site); there may 22 also be an immediate reduction in property tax revenues for Westchester County. These 23 impacts, however, would not be considered significant on a countywide basis because of the 24 large population in the area and because plant workers' residences are not concentrated in a 25 single municipality or county.
26 PILOT payments and other taxes from IP2 and IP3 are paid directly to the Town of Cortlandt, 27 the Village of Buchanan, and the Hendrick Hudson Central School District. Entergy paid a 28 combined $21.2 million in PILOT payments, property taxes, and other taxes to Westchester 29 County, the Town of Cortlandt, the Village of Buchanan, the Verplanck Fire District, and the 30 Hendrick Hudson Central School District in 2005 (Entergy 2007). PILOT payments, property 31 taxes, and other taxes paid by the site account for a significant portion of revenues for these 32 Government agencies.
33 The Village of Buchanan, which has over 2100 residents, is the principal local jurisdiction that 34 receives direct revenue from IP2 and IP3. In fiscal year 2005, PILOT payments, property taxes, 35 and other taxes from Entergy contributed about 39 percent of the Village of Buchanan's total 36 revenue of $5.08 million (Entergy 2007). The revenues generated from IP2 and IP3 are used to 37 fund police, fire, health, transportation, recreation, and other community services. Additionally 38 in fiscal year 2005, PI LOT payments, property taxes, and other taxes from Entergy contributed 39 over 35 percent of the total revenue collected for the Hendrick Hudson Central School District, 40 which serves approximately 3000 students (Entergy 2007).
41 The shutdown of IP2 and IP3 may result in increased property values of the homes in the 42 communities surrounding the site (Levitan and Associates, Inc. 2005). This would result in 43 some increases in tax revenues. However, to fully offset the revenues lost from the shutdown of December 2008 8-29 Draft NUREG-1437, Supplement 38 OAG10001366_00344
Environmental Impacts of License Renewal 1 IP2 and IP3, taxing jurisdictions most likely would have to compensate with higher property 2 taxes (Levitan and Associates, Inc. 2005). The combined increase in property values and 3 increased taxes could have a noticeable effect on some area homeowners and business, 4 though Levitan and Associates did not indicate the magnitude of this effect and whether the net 5 effect would be positive or negative.
6 Revenue losses from Indian Point operation would likely affect only the communities closest to 7 and most reliant on the plant's tax revenue and PI LOT. If property values and property tax 8 revenues increase, some of these effects would be smaller. The NRC staff concludes that the 9 socioeconomic impacts of plant shutdown would likely be SMALL to MODERATE (MODERATE 10 effects for the Hendrick Hudson Central School District, Village of Buchanan, Town of Cortlandt, 11 and the Verplanck Fire District). See Appendix J to NUREG-0586, Supplement 1 (NRC 2002),
12 for additional discussion of the potential impacts of plant shutdown.
13
- Transportation 14 In Chapter 4 of this draft SEIS, the NRC staff concluded that the impacts of continued plant 15 operation on transportation would be SMALL. Cessation of operations will be accompanied by 16 reduced traffic in the vicinity of the plant. Most of the reduction will be associated with a 17 reduction in plant workforce, but there will also be a reduction in shipment of maintenance 18 materials to and from the plant. Therefore, the staff concludes that the impacts of plant closure 19 on transportation would be SMALL 20
- Aesthetics 21 In Chapter 4 of this draft SEIS, the NRC staff concluded that the aesthetic impacts of continued 22 plant operation would be SMALL. Major plant structures and other facilities, such as the 23 containment buildings and turbine buildings, are likely to remain in place until decommissioning 24 begins. The NRC staff also anticipates that the overall appearance of the facility and its 25 grounds would be maintained through the decommissioning. Since no significant changes 26 would occur between shut down and decommissioning, the staff concludes that the aesthetic 27 impacts of plant closure would be SMALL.
28
- Historic and Archeological Resources 29 In Chapter 4 of this draft SEIS, the staff concluded that the impacts of continued plant operation 30 on historic and archeological resources would be SMALL. Onsite land use will not be affected 31 immediately by the cessation of operations since plant structures and other facilities are likely to 32 remain in place until decommissioning. Following plant shutdown, there would be no 33 foreseeable need for archeological surveys of the area. Therefore, the NRC staff concludes 34 that the impacts on historic and archeological resources from plant shutdown would be SMALL.
35
- Environmental Justice 36 In Chapter 4 of this draft SEIS, the NRC staff concluded that the environmental justice impacts 37 of continued operation of the plant would be SMALL because continued operation of the plant 38 would not have a disproportionately high and adverse impact on minority and low-income 39 populations. Although the NRC staff concluded that the socioeconomic impacts of the plant 40 shutdown would be MODERATE for some jurisdictions, the impacts of the plant shutdown are 41 likely to be felt across the entire community and are not expected to be significantly 42 disproportionate to minority and low-income populations.
Draft NUREG-1437, Supplement 38 8-30 December 2008 OAG10001366_00345
Environmental Impacts of License Renewal 1 As described in Section 2.2.8.6, the site contributed over 35 percent of the total revenue 2 collected for the Hendrick Hudson Central School District in 2005. The Hendrick Hudson 3 Central School District has only an 18-percent minority population (compared to a 47-percent 4 Statewide average) and only 5 percent of the students are eligible for a free or reduced-price 5 lunch program (compared to a Statewide average of 44 percent). Therefore, the loss of funding 6 to the Hendrick Hudson Central School District would not disproportionately affect minority and 7 low-income populations (GreatSchools 2008).
8 The site contributed about 39 percent of the Village of Buchanan's total revenue in 2005 9 (Entergy 2007). In 2000, less than 4 percent of the population were minorities and less than 10 4 percent of the individuals were below the poverty level (US Census Bureau 2000). Therefore, 11 the loss of funding to the Village of Buchanan would not disproportionately affect minority and 12 low-income populations.
13 The NRC staff concludes that the environmental justice impacts of plant shutdown would be 14 SMALL. See Appendix J to NUREG-0586, Supplement 1 (NRC 2002), for additional discussion 15 of these impacts.
16 8.3 Alternative Energy Sources 17 This section discusses the environmental impacts associated with developing alternative 18 sources of electric power to replace power generated by IP2 and IP3. The order of alternative 19 energy sources presented in this section does not imply which alternative would be most likely 20 to occur or which is expected to have the least environmental impacts.
21 The following central generating station alternatives are considered in detail in the identified 22 sections of this draft SEIS:
23
- supercritical coal-fired generation at an alternate site (Section 8.3.1) 24
- natural gas-fired generation at either the IP2 and IP3 site or an alternate site (Section 25 8.3.2) 26 The NRC staff considers the following nongeneration alternatives to license renewal in detail in 27 the identified sections of this draft SEIS:
28
- purchased power (Section 8.3.3) 29 The NRC staff also considers two combinations of alternatives that include new or existing 30 generation along with conservation or purchased power in the identified sections of this draft 31 SEIS:
32
- continued operation of either IP2 or IP3, construction and operation of a gas-fired unit, 33 renewable generation, and conservation programs (Section 8.3.5.1) 34
- construction and operation of new gas-fired plant, renewable generation, conservation, 35 and purchased power (Section 8.3.5.2) 36 Alternatives considered by the NRC staff but dismissed from further evaluation as stand-alone 37 alternatives are addressed in Section 8.3.4 of this draft SEIS. Several of the alternatives 38 discussed in Section 8.3.4 are included in the combinations addressed in 8.3.5.
December 2008 8-31 Draft NUREG-1437, Supplement 38 OAG10001366_00346
Environmental Impacts of License Renewal 1 Alternatives Process 2 Since IP2 and IP3 have a net electric output of 2158 MW(e), the NRC staff evaluated the 3 impacts of alternatives with comparable capabilities.
4 Of the alternatives mentioned in this section, the NRC staff expects that only a natural gas-fired 5 generation plant could be developed at the IP2 and IP3 facility because the site is too small to 6 host other alternatives.
7 While the alternate site considered need not be situated in New York State, the availability of 8 transmission line capacity to deliver power from a location outside the New York metropolitan 9 region to current IP2 and IP3 customers could constrain siting choices. For instance, a recent 10 analysis conducted by the U.S. Department of Energy (DOE) concluded that metropolitan New 11 York southward through northern Virginia is a "critical congestion area" (DOE 2006). The DOE 12 has identified critical congestion areas where it is critically important to remedy existing or 13 growing electrical transmission congestion problems because the impacts of the congestion 14 could be severe. It is conceivable that these transmission congestion patterns would influence 15 selection of an alternate site for generating power that is needed in the New York metropolitan 16 region.
17 All of New York's constrained transmission paths move power from areas to the west, south, 18 and north of the State to the loads in and around New York City and Long Island. The New 19 York City metropolitan area consumes major quantities of electricity with less generation 20 capacity than load. Therefore, the region is dependent on imports. Because of the area's 21 current dependence on local power generation from natural gas and oil fuels, the area has high 22 electricity rates (DOE 2006). The replacement of limited local generation sources with 23 additional imported power would place even more demands on the constrained transmission 24 system moving power into the New York City area. As noted in Section 8.2, it may be 25 necessary to continue operating the IP2 and IP3 generators as synchronous condensers to 26 supply virtual power to the local transmission system after the IP2 and IP3 reactors shut down.
27 EIA Projections 28 Each year the Energy Information Administration (EIA), a component of DOE, issues an annual 29 energy outlook. In its "Annual Energy Outlook 2007 with Projections to 2030," EIA projects that 30 natural gas-fired plants will account for approximately 26 percent of electric generating capacity 31 in 2020, an increase of about 14 percent from 2005 levels (DOE/EIA 2007a). EIA projects that 32 coal-fired plants will account for approximately 32 percent of generating capacity in 2020, 33 increasing nearly 15 percent from 2005 levels (DOE/EIA 2007a). EIA projects that renewable 34 energy sources, primarily hydropower and biomass, will account for 12 percent of capacity in 35 2020, increasing from 9 percent in 2005 (DOE/EIA 2007a). After 2020, however, new coal and 36 nuclear plants are expected to displace some of the power currently generated at natural-gas-37 fired plants (DOE/EIA 2007a).
38 EIA bases its projections on the assumption that providers of new generating capacity will seek 39 to add generating sources that are cost effective and meet applicable environmental 40 requirements. According to EIA, advanced coal-fired and advanced combined-cycle natural gas 41 generating facilities will be approximately competitive with each other in 2015, and advanced 42 coal-fired facilities will likely gain a competitive edge by 2030 (DOE/EIA 2007a). In line with the 43 EIA projections, the alternative of a new advanced coal-fired plant at an alternate location is 44 considered in this draft SEIS. The resulting impacts are presented in Section 8.3.1 of this draft Draft NUREG-1437, Supplement 38 8-32 December 2008 OAG10001366_00347
Environmental Impacts of License Renewal 1 SEIS. The impacts of a new gas-fired combined-cycle plant located at either the IP2 and IP3 2 site or an alternate site are presented in Section 8.3.2 of this draft SEIS.
3 EIA indicated that, because of environmental needs and increasing fuel costs, oil-fired plants 4 will account for little or none of the new generating capacity added in the United States through 5 2030 (DOE/EIA 2007a). This projection assumed that world oil prices would reach a low of $50 6 per barrel in 2014 and rise to $59 in 2030. After recent sharp price increases and declines, the 7 EIA now projects that oil prices will average $51 per barrel in 2009 (DOE/EIA 2008b). The NRC 8 staff notes that future oil prices will be driven by supply and demand.
9 The EIA projects that U.S. generators will increase total nuclear and renewable generation 10 capacity throughout the forecast term, due partly to tax credits and other incentives. As a 11 proportion of installed capacity, however, nuclear generation will decrease slightly through 2030, 12 while renewable generation remains relatively constant (EIA 2007). EIA indicates that changes 13 in electricity generation costs-which are highly dependent on emission control costs-will drive 14 utilities' choices in generating technologies (EIA 2007). About 70 percent of new nuclear 15 generating capacity is expected to be directly related to the availability of production tax credits 16 under the Energy Policy Act of 2005 (EPACT2005; DOE/EIA 2007a).
17 The NRC staff uses EIA's analyses to help select reasonable alternatives to license renewal. In 18 the following sections of this chapter, the NRC staff will examine several alternatives in depth, 19 and identify a range of others that staff considered but rejected.
20 8.3.1 Supercritical Coal-Fired Generation 21 In this section, the NRC staff analyzes new supercritical coal-fired boilers as an alternative to 22 nuclear power generation at the IP2 and IP3 site. Supercritical coal-fired plants are similar to 23 other coal burners except that they operate at higher temperatures and pressures, which allows 24 for greater thermal efficiency. Supercritical coal-fired boilers are commercially proven and 25 represent an increasing proportion of new coal-fired power plants. In evaluating the 26 supercritical coal-fired alternative, the NRC staff assumed that a new plant located at an 27 alternate site would use a closed-cycle cooling system.
28 The NRC staff recognizes that some coal-fired power plant proposals have recently faced 29 opposition or rejection in some jurisdictions, though other projects continue to move forward.
30 Also, coal-fired generation faces greater regulatory uncertainty and risk from potential future 31 greenhouse gas regulation than other generation alternatives. In New York, coal-fired power 32 plants would need to comply with elements of the Regional Greenhouse Gas Initiative.
33 Nonetheless, given EIA's projections and the progress of some new coal-fired proposals, the 34 NRC staff has decided to include coal-fired generation as an alternative to license renewal.
35 Construction of a coal-fired plant at an alternate site may necessitate the acquisition of 36 additional ROWs for new transmission lines and construction of new lines to transmit power.
37 Transmission line and ROW length would vary with distance to suitable existing lines. In 38 addition, construction at an alternate site may necessitate the construction of an appropriate 39 railroad spur (or other transportation infrastructure) for coal and limestone (used in scrubbers to 40 remove sulfur oxides) deliveries.
41 For purposes of this analysis, the NRC staff will rely on data published by EIA indicating that a 42 new, scrubbed coal plant constructed in 2015 will operate at a heat rate of 8661 BTU per December 2008 8-33 Draft NUREG-1437, Supplement 38 OAG10001366_00348
Environmental Impacts of License Renewal 1 kilowatt hour (BTU/kWh) (DOE/EIA 2007b). (This reduces the level of emissions for this 2 alternative when compared to the coal-fired alternative Entergy analyzed in the ER for IP2 and 3 IP3 ER by approximately 15 percent for some impact areas).
4 Impacts of a coal-fired alternative evaluated by the NRC staff assume that the new plant would 5 have a gross electrical capacity of 2200 MW(e). The NRC staff's analysis of the 2200-MW(e) 6 coal-fired plant is based on the factors used to calculate the impacts of the plant that would 7 replace the 2158 MW(e) of power produced by the IP2 and IP3 plants (Entergy 2007). Because 8 up to 10 percent of gross generation may be consumed on site by the coal-fired plant (or its 9 pollution control equipment), the NRC staff's evaluation of a 2200-MW(e) plant may actually 10 slightly understate impacts from this alternative. This ensures, however, that impact levels for 11 alternatives are not overstated when compared to the proposed action.
12 The NRC staff will present most impacts on an annualized basis. While the renewal period for 13 the IP2 and IP3 operating licenses is only 20 years, the operating lifespan for a new coal-fired 14 plant is likely closer to 40 years, and may even be longer given the lifespans of some existing 15 coal-fired plants. Most impacts will be independent of plant lifespan, though total land area 16 used for waste disposal, for example, will be larger after 40 years than after 20 years. Where 17 these differences exist, the NRC staff will identify them.
18 For replacing IP2 and IP3, the NRC evaluated an alternative that would use four 550-MW(e)-net 19 coal-fired units to replace the power output of IP2 and IP3. Advanced coal and conventional 20 combined-cycle coal plants could operate at even greater efficiencies (about 7477 and 6866 21 BTU/kWh, respectively, or greater) by 2015 (DOE/EIA 2007b).
22 The supercritical coal-fired plant, with a gross output of about 2200 MW(e) , would consume 23 approximately 4.9 million metric tonnes (MT) (5.4 million tons) per year of pulverized bituminous 24 coal with an ash content of approximately 7.11 percent and sulfur content of 1.12 percent 25 (based on New York coal consumption) (DOE/EIA 2001). The NRC staff assumed a capacity 26 factor of 0.85 for the supercritical coal-fired alternative.
27 Based on Table 8-1 of the GElS, a pulverized coal-fired facility requires approximately 0.7 ha 28 (1.7 ac) of land per MW of generating capacity. Based on this relationship, a 1540-ha (3740-ac) 29 site would be needed to replace the nuclear power output of IP2 and IP3 with an equivalent 30 capacity coal-fired facility. In more recent SEIS documents, however, the NRC staff indicated 31 that smaller quantities of land may be sufficient to construct coal-fired facilities based on land 32 use at existing coal-fired power plants. Because the existing IP2 and IP3 site includes only 239 33 ac (98 ha), and much of the area is occupied by plant structures, the NRC staff concludes that 34 there is not sufficient land area at the IP2 and IP3 site to support operations of the alternative.
35 Thus, the coal-fired alternative is analyzed only for an unspecified alternate site. It should be 36 noted that several of the newer coal utilization technologies (e.g., coal-fired integrated 37 gasification combined-cycle systems) could be accommodated on smaller sites than would the 38 conventional pulverized coal concept evaluated here, but likely not a site as small as the IP2 39 and IP3 site.
40 The overall impacts of the coal-fired generating facility are discussed in the following sections 41 and summarized in Table 8-3, at the end of Section 8.3.1 of this draft SEIS. The implications of 42 constructing a new coal-fired plant at an alternate site will depend on the actual location and 43 characteristics of that site. For purposes of this section, the NRC staff assumes that a coal-fired 44 plant located at an alternate site would require the construction of a new transmission line to Draft NUREG-1437, Supplement 38 8-34 December 2008 OAG10001366_00349
Environmental Impacts of License Renewal 1 connect that plant to the regional transmission grid.
2
- Land Use 3 In the GElS, the NRC staff estimated that about 0.7 ha (1.7 ac) of land are needed per MW(e) 4 for the construction and operation of a coal-fired power plant. Constructing a 2200-MW(e) coal-5 fired facility would take approximately 1540 ha (3740 ac). In more recent SEIS documents, the 6 NRC staff indicated that smaller quantities of land may be sufficient to construct coal-fired 7 facilities based on land use at existing coal-fired power plants. A 2200-MW(e) facility may be 8 able to fit on a site with several hundred acres of land rather than the 1540 ha (3740 ac) 9 indicated in the GElS.
10 Committing land resources to a new coal-fired plant could result in the loss of wildlife habitat or 11 agricultural land. The potential need for new transmission line corridors and ROWs also drive 12 land use effects for the coal-fired facility. As a result of the substantial site area that would be 13 dedicated to and disrupted by coal-fired operations, the NRC staff views this alternative as 14 having potentially MODERATE land use impacts from construction.
15 Additionally, for the coal-fired alternative, land use changes would occur at an undetermined 16 coal mining area where approximately 75 square miles (sq mi) (19,400 ha) would be affected for 17 mining coal and disposing of mining wastes to support a 2200-MW(e) coal-fired power plant (the 18 GElS estimates that approximately 34 sq mi (8800 ha) would be disturbed for a 1000-MW(e) 19 coal-fired plant (NRC 1996). Offsite land use for coal mining would partially be offset by the 20 elimination of the need for offsite uranium mining. In the GElS, the NRC staff estimated that 21 approximately 405 ha (1000 ac) would be affected for mining the uranium and processing it 22 during the operating life of a 1000-MW(e) nuclear power plant (NRC 1996). Therefore the 23 uranium mining offset would be about 890 ha (2,200 ac) of the 19,400 ha required for the coal-24 fired alternative. Impacts from the coal fuel cycle would add to the already MODERATE impacts 25 from plant construction.
26 A coal-fired alternative would likely receive coal and limestone by rail. The coal-fired option 27 would require approximately 10.4 coal unit trains per week (assuming each train has 100 cars 28 with 100 tons of coal per car). For an undeveloped site, a new rail spur would be necessary.
29 For an existing industrial site, a rail spur may exist but could require improvements to handle 30 these deliveries. Impacts from improving an existing rail spur would be small, as the area is 31 already disturbed and used for industrial purposes. Installing a new rail spur could result in 32 relatively minor impacts depending on the length of the rail spur.
33 Overall, impacts to land use from construction of the coal-fired alternative and its fuel cycle 34 would be MODERATE to LARGE.
35
- Ecology 36 Siting a coal-fired plant at an alternate site would introduce construction and operating impacts.
37 Converting as much as 1500 ha (3700 ac) of land to industrial use (generating facilities, coal 38 storage, ash and scrubber sludge disposal) could significantly alter terrestrial ecological 39 resources and could affect aquatic ecological resources. Construction and maintenance of a 40 transmission line and rail spur would incrementally add to the terrestrial ecological impacts.
41 Impacts to terrestrial ecology from coal mining also could be substantial, though terrestrial 42 ecology at many coal mining sites has already been disturbed. Therefore, the NRC staff 43 concludes that the impact to terrestrial ecology would be MODERATE to LARGE, depending December 2008 8-35 Draft NUREG-1437, Supplement 38 OAG10001366_00350
Environmental Impacts of License Renewal 1 largely on the ecological sensitivity of the plant and mine sites.
2 Use of surface water resources to provide makeup water for a closed-cycle cooling system 3 would have some impact on local aquatic resources. Aquatic impacts of a supercritical coal-4 fired alternative would likely be similar to the impacts of the proposed closed-cycle cooling 5 system proposed for the existing nuclear reactors described in Section 8.1.1 of this draft SEIS.
6 The supercritical coal-fired power plant's greater thermal efficiency-when compared to the 7 existing IP2 and IP3-would result in smaller impacts, while the coal-fired alternative has 8 greater potential for deposition of pollutants or runoff from coal, ash, or scrubber waste areas.
9 On the whole, the level of impact would be similar. Therefore, the NRC staff concludes that the 10 impact to aquatic ecology would be SMALL.
11 Due primarily to the potential effects on terrestrial ecology, the NRC staff concludes that the 12 overall impacts of this alternative would be MODERATE to LARGE.
13
- Water Use and Quality 14 For coal-fired operations at an alternate site, impacts to surface waters would result from 15 withdrawal of water for various operating needs of the facility. These operating needs would 16 include cooling tower makeup and possibly auxiliary cooling for equipment and potable water 17 requirements. Discharges to surface water could result from cooling tower blowdown, coal pile 18 runoff, and runoff from coal ash and scrubber byproduct disposal areas. Both the use of surface 19 waters and discharges to surface waters would be regulated by the State within which the coal-20 fired facility is located.
21 The NRC staff expects that any new coal-fired facility would comply with requirements of the 22 discharge permits issued for its operation. Thus, the utility would be obligated to ensure that 23 discharges from the plant conform to applicable water quality standards. Water withdrawals 24 from a small river or cooling pond, however, could lead to potential water use conflicts. Overall, 25 the NRC staff concludes that the potential impacts to surface water resources and water quality 26 would be SMALL to MODERATE for a new coal-fired facility located at an alternate site.
27 Potential impacts to ground water quality at an alternate site may occur as a result of seepage 28 to ground water from coal storage areas and onsite ash and scrubber sludge disposal areas. A 29 coal-fired plant of this size is unlikely to use ground water for cooling tower makeup, however.
30 In all cases, the NRC staff expects that a coal-fired facility would comply with a ground water 31 use and discharge permit issued by the State having jurisdiction over the plant. Complying with 32 permit requirements should ensure a small impact. Therefore, the NRC staff concludes that the 33 potential impacts to water resources would be SMALL to MODERATE.
34
- Air Quality 35 A coal-fired power plant emits a variety of airborne emissions, including SOx, NOx, particulate 36 matter, CO, hazardous air pollutants (HAPs) (e.g., mercury), and naturally occurring radioactive 37 materials.
38 A coal-fired alternative built in a nonattainment area (such as exists at the current IP2 and IP3 39 site) would require a nonattainment area permit and a Title V operating permit under the CAA.
40 A new power plant would also be subject to the new source performance standards for such 41 units in Subpart DA, "Standards of Performance for Electric Utility Steam Generating Units for 42 Which Construction Is Commenced after September 18, 1978," of 40 CFR Part 60, "Standards Draft NUREG-1437, Supplement 38 8-36 December 2008 OAG10001366_00351
Environmental Impacts of License Renewal 1 of Performance for New Stationary Sources." These regulations establish emission limits for 2 particulates, opacity, sulfur dioxide (S02), and NOx. EPA has various regulatory requirements 3 for visibility protection in Subpart P, "Protection of Visibility," of 40 CFR Part 51, "Requirements 4 for Preparation, Adoption, and Submittal of Implementation Plans," including a specific 5 requirement for review of any new major stationary source in an area designated attainment or 6 unclassified under the CAA.
7 NRC discussions of SOx and NOx emissions include the most recent relevant regulations, 8 because the Clean Air Interstate Rule (CAIR) was vacated by the D.C. Circuit Court in July of 9 2008. On September 24,2008, EPA filed for a rehearing of the D.C. Circuit Court decision.
10 Until EPA, Congress, or the courts act, elements of future SOx and NOx regulatory approaches 11 remain uncertain.
12 Emissions of specific pollutants from coal-fired alternatives are as follows:
13 Sulfur oxides emissions. The NRC staff calculates that a new coal-fired power plant would emit 14 5236 MT/yr (5754 tons/yr) of SOx after limestone-based scrubbers remove approximately 99 15 percent of sulfur compounds from plant exhaust. This plant would be subject to the 16 requirements in Title IV of the CAA. Title IV was enacted to reduce emissions of SOx and NOx, 17 the two principal precursors of acid rain, by restricting emissions of these pollutants from power 18 plants. Title IV caps aggregate annual power plant SOx emissions and imposes controls on SOx 19 emissions through a system of marketable allowances. EPA issues one allowance for each ton 20 of SOx that a unit is allowed to emit.
December 2008 8-37 Draft NUREG-1437, Supplement 38 OAG10001366_00352
Environmental Impacts of License Renewal 1 New units do not receive allowances but are required to have allowances to cover their SOx 2 emissions. Owners of new units must, therefore, acquire allowances from owners of other 3 power plants or reduce SOx emissions at other power plants they own. Allowances can be 4 banked for use in future years. Thus, a new coal-fired power plant would not add to net regional 5 SOx emissions, although it might contribute to the local SOx burden.
6 Nitrogen oxides emissions. Title IV of the CAA directed EPA to establish technology-based 7 emission limitations for NOx emissions (see Section 407), rather than a market-based allowance 8 system as is used for SOx emissions. A new coal-fired power plant would be subject to the new 9 source performance standards for such plants in 40 CFR 60.44a(d)(1). That regulation, issued 10 September 16, 1998 (Volume 63, page 49453 of the Federal Register (63 FR 49453)), limits the 11 discharge of any gases that contain nitrogen oxides (expressed as nitrogen dioxide (N0 2)) to 12 200 nanograms per joule of gross energy output (1.6 pound/megawatt-hour (MW(h)), based on 13 a 30-day rolling average.
14 As previously discussed, IP2 and IP3 are located within the New Jersey-New York-Connecticut 15 Interstate Air Quality Control Region (40 CFR 81.13). All of the States of New Jersey and 16 Connecticut, as well as several counties in Central and Southeastern New York within a 80-km 17 (50-mi) radius of IP2 and IP3, are designated as nonattainment areas for ozone (8-hour 18 standard) (EPA 2008b). Operators or owners of a coal-fired power plant constructed in a 19 nonattainment area would need to purchase offsets for ozone precursor emissions. In this 20 case, NOx is the major ozone precursor emitted by a coal-fired power plant. In accordance with 21 NYSDEC regulations, "Emission offsets must exceed the net increase in annual actual 22 emissions from the air contamination source project" (NYSDEC, Chapter 3, Parts 231-15). By 23 design, this regulatory requirement should result in a net reduction in ozone emissions in the 24 region.
25 This new coal-fired plant would likely use a variety of NOx control technologies, including low-26 NOx burners, overfire air, and selective catalytic reduction. EPA notes that when these 27 emissions controls are used in concert, they can reduce NOx emissions by up to 95 percent 28 (EPA 1998), for total annual emissions of approximately 1230 MT/yr (1352 tons/yr) or 29 0.14 pounds/MW(h). This is significantly less than the amount allowed by Title IV of the CAA.
30 Particulate emissions. The NRC staff estimates that the total annual stack emissions would 31 include 175 MT (192 tons) of total suspended particulates and 40 MT (44 tons) of particulate 32 matter having an aerodynamic diameter less than or equal to 10 IJm (PM 1O) (40 CFR 50.6, 33 "National Primary and Secondary Ambient Air Quality Standards for PM 1O "). Some of this PM 10 34 would also be classified as primary PM 2.5 .
35 As indicated in the IP2 and IP3 ER, fabric filters or electrostatic precipitators would be used for 36 particulate control. EPA notes that filters or precipitators are each capable of removing more 37 than 99 percent of particulate matter, and that S02 scrubbers further reduce particulate matter 38 emissions (EPA 1998). In addition to flue emissions, coal-handling equipment would introduce 39 fugitive particulate emissions from coal piles, reclamation equipment, conveyors, and other 40 sources.
41 Fugitive dust also would be generated during the construction of a coal-fired plant, and 42 construction vehicles and motorized equipment would further contribute to construction-phase 43 air emissions. These emissions would be short lived and intermittent, and construction crews 44 would likely mitigate some impacts through dust control measures.
Draft NUREG-1437, Supplement 38 8-38 December 2008 OAG10001366_00353
Environmental Impacts of License Renewal 1 Carbon monoxide emissions. The NRC staff estimates that the total CO emissions from coal 2 combustion would be approximately 1230 MT/yr (1352 tons/yr) based on EPA-calculated 3 emissions factors for coal-fired power plants.
4 Hazardous air pollutants including mercury. Following the D.C. Circuit Court's February 8, 5 2008, ruling that vacated its Clean Air Mercury Rule (CAMR), EPA is working to evaluate how 6 the court's ruling will affect mercury regulation (EPA 2008d). Before CAMR, EPA determined 7 that coal- and oil-fired electric utility steam-generating units are significant emitters of HAPs 8 (EPA 2000a). EPA determined that coal plants emit arsenic, beryllium, cadmium, chromium, 9 dioxins, hydrogen chloride, hydrogen fluoride, lead, manganese, and mercury (EPA 2000a).
10 EPA concluded that mercury is the HAP of greatest concern and that (1) a link exists between 11 coal combustion and mercury emissions, (2) electric utility steam-generating units are the 12 largest domestic source of mercury emissions, and (3) certain segments of the U.S population 13 (e.g., the developing fetus and subsistence fish-eating populations) are believed to be at 14 potential risk of adverse health effects resulting from mercury exposures caused by the 15 consumption of contaminated fish (EPA 2000a). In light of the recent court decision, EPA will 16 revisit mercury regulation, although it is possible that the agency will continue to regulate 17 mercury as a HAP, thus requiring the use of best available control technology to prevent its 18 release to the environment.
19 Uranium and thorium. Coal contains uranium and thorium, among other naturally occurring 20 elements. According to Alex Gabbard of Oak Ridge National Laboratory, uranium 21 concentrations are generally in the range of 1 to 10 parts per million (ppm), and thorium 22 concentrations are generally about 2.5 times this level (Gabbard 1993). The U.S. Geological 23 Survey (USGS) indicates that Western and Illinois Basin coals contain uranium and thorium at 24 roughly equal concentrations, mostly between 1 and 4 ppm, but also indicates that some coals 25 may contain concentrations of both elements as high as 20 ppm (USGS 1997). Gabbard 26 indicates that a 1000-MW(e) coal-fired plant could release roughly 4.7 MT (5.2 tons) of uranium 27 and 11.6 MT (12.8 tons) of thorium to the atmosphere each year (1993).
28 Both USGS and Gabbard, however, indicate that almost all of the uranium, thorium, and most 29 decay products remain in solid coal wastes, especially in the fine glass spheres that constitute 30 much of coal's fly ash. Modern emissions controls, such as those included for this coal-fired 31 alternative, allow for recovery of greater than 99 percent of these solid wastes (EPA 1998), thus 32 retaining most of coal's radioactive elements in solid form rather than releasing it to the 33 atmosphere. Even after concentration in coal waste, the level of radioactive elements remains 34 relatively low-typically 10 to 100 ppm-and consistent with levels found in naturally occurring 35 granite rocks, shales, and phosphate rocks (USGS 1997). The levels of uranium and thorium 36 contained in coal wastes and discharged to the environment exceed the levels of uranium and 37 thorium released to the environment by IP2 and IP3.
38 Carbon dioxide: A coal-fired plant would have unregulated CO2 emissions that could contribute 39 to global warming. Under the current regulatory framework, a coal-fired plant would have 40 unregulated CO2 emissions during operations as well as during coal mining and processing, and 41 coal and lime transportation. Burning bituminous coal in the United States emits roughly 93.3 42 kg (205.3 pounds) of CO 2 per million BTU (DOE/EIA 2008a). The four-unit 2200-MW(e) 43 supercritical coal-fired plant would emit approximately 13.1 million MT (14.5 million tons) of CO 2 44 per year assuming a heat rate of 8661 BTU/kWh (DOE/EIA 2007b). Section 6.2 of this draft 45 SEIS contains a discussion of current and likely future relative GHG emissions from several December 2008 8-39 Draft NUREG-1437, Supplement 38 OAG10001366_00354
Environmental Impacts of License Renewal 1 energy alternatives, including coal, natural gas, nuclear, and renewables. In Section 6.2, the 2 NRC staff found that GHG emissions from coal would likely exceed those from other energy 3 alternatives throughout the period of extended operation.
4 Visibility Regulations: Section 169A of the CAA (42 USC 7491) establishes a national goal of 5 preventing future and remedying existing impairment of visibility in mandatory Class I Federal 6 areas when impairment results from manmade air pollution. EPA issued a new regional haze 7 rule in 1999 (64 FR 35714). The rule specifies that for each mandatory Class I Federal area 8 located within a State, the State must establish goals that provide for reasonable progress 9 towards achieving natural visibility conditions. The reasonable progress goals must provide for 10 an improvement in visibility for the most-impaired days over the period of the implementation 11 plan and ensure no degradation in visibility for the least-impaired days over the same period 12 (40 CFR 51.308(d)(1)). If a coal-fired alternative were located close to a mandatory Class I 13 area, additional air pollution control requirements would be imposed. New York has no Class I 14 areas; of the neighboring States, New Jersey and Vermont each have one-the Brigantine 15 Wilderness Area and the Lye Brook Wilderness, respectively. Brigantine is located about 225 16 km (140 mi) south of IP2 and IP3, while Lye Brook is roughly 215 km (135 mi) north-northeast.
17 A coal-fired alternative located near these areas or any other Class I area may need additional 18 pollution controls to keep from impairing visibility.
19 Summary. The GElS analysis did not quantify emissions from coal-fired power plants, but 20 implied that air impacts would be substantial. The GElS also mentioned global warming from 21 unregulated CO2 emissions and acid rain from SOx and NOx emissions as potential impacts 22 (NRC 1996). The NRC staff's analysis shows that emissions of air pollutants, including SOx, 23 NOx, and CO, would be significant and would be greater than all other alternatives. Operational 24 emissions of CO 2 are also greater under the coal-fired alternative than under any other 25 alternative.
26 The NRC analysis for a coal-fired alternative at an alternative site indicates that impacts from 27 the coal-fired alternative would have clearly noticeable effects, but given existing regulatory 28 regimes, permit requirements, and emissions controls, the coal-fired alternative would not 29 destabilize air quality. Thus, the appropriate characterization of air impacts from coal-fired 30 generation would be MODERATE.
31
- Waste 32 A four-unit, 2220-MW(e) coal-fired plant with a heat rate of 8661 BTU/kWh (DOE/EIA 2007b) 33 would annually consume approximately 5.4 million tons of coal having an ash content of 34 7.11 percent (Entergy 2007). After combustion, 99.9 percent of this ash, approximately 345,800 35 MT (380,000 tons) per year, would be collected and disposed of at either an onsite or offsite 36 landfill, or recycled. Based on industry-average recycling rates, approximately 155,610 MT 37 (171,000 tons), or 45 percent, of the ash content would be recycled, leaving a total of 38 approximately 190,190 MT (209,000 tons) for disposal (ACAA 2007). In addition, approximately 39 300,300 MT (330,000 tons) of scrubber waste would be disposed of or recycled each year.
40 Based on industry-average recycling rates, approximately 237,000 MT (260,700 tons), or 41 79 percent, of gypsum scrubber waste would be recycled (ACAA 2007). As mentioned in the 42 Air Quality section, this waste also would contain levels of uranium and thorium in 43 concentrations similar to those found in naturally occurring granites, shales, and phosphate 44 rocks (USGS 1997). In addition to coal combustion wastes, a supercritical coal-fired alternative Draft NUREG-1437, Supplement 38 8-40 December 2008 OAG10001366_00355
Environmental Impacts of License Renewal 1 also would produce small amounts of domestic and hazardous wastes.
2 Disposal of the waste could noticeably affect land use and ground water quality, but with 3 appropriate management and monitoring, it would not destabilize any resources. After closure 4 of the waste site and revegetation, the land could be available for other uses.
5 In May 2000, EPA issued a "Notice of Regulatory Determination on Wastes from the 6 Combustion of Fossil Fuels" (EPA 2000b). EPA concluded that some form of national 7 regulation is warranted to address coal combustion waste products because (1) the composition 8 of these wastes could present danger to human health and the environment under certain 9 conditions, (2) EPA has identified 11 documented cases of proven damages to human health 10 and the environment by improper management of these wastes in landfills and surface 11 impoundments, (3) disposal practices are such that, in 1995, these wastes were being managed 12 in 40 to 70 percent of landfills and surface impoundments without reasonable controls in place, 13 particularly in the area of ground water monitoring, and (4) EPA identified gaps in State 14 oversight of coal combustion wastes. Accordingly, EPA announced its intention to issue 15 regulations for disposal of coal combustion waste under Subtitle D of the Resource 16 Conservation and Recovery Act (RCRA). EPA has not yet issued these regulations.
17 In addition to the waste streams generated during plant operations, considerable debris would 18 be generated during construction of a coal-fired facility. Crews would likely dispose of land-19 clearing debris on site.
20 For all of the preceding reasons, the NRC staff considers the impacts of managing waste 21 generated by a coal facility (construction and operating phases) to be MODERATE-the 22 impacts would be clearly noticeable, but would likely not destabilize any important resource.
23
- Human Health 24 Coal-fired power generation introduces risks to workers at many points in the fuel cycle. These 25 risks include risks from mining coal and limestone, transportation of raw materials, plant 26 construction and operation, and waste management. There also may be public health risks 27 from a coal-fired plant's operation (routine emissions and coal-pile fires) and fuel cycle (mining 28 and transportation).
29 During construction activities there would be risk to workers from typical industrial incidents and 30 accidents. Accidental injuries are not uncommon in the construction industry and accidents 31 resulting in fatalities do occur. However, the occurrence of such events is mitigated by the use 32 of proper industrial hygiene practices, complying with worker safety requirements, and training.
33 Occupational and public health impacts during construction are expected to be controlled by 34 continued application of accepted industrial hygiene protocols, occupational health and safety 35 controls, and radiation protection practices.
36 In the GElS, the NRC staff stated that human health impacts (cancer and emphysema) could 37 arise from chronic exposures to coal-fired plant emissions. Emissions contain pollutants such 38 as toxins, particulates, and low levels of naturally occurring radioactive elements. However, 39 Federal and/or State agencies regulate these emissions and enforce emissions standards that 40 are designed to be protective of human health. As a result, power plants install appropriate 41 emission controls to meet regulatory standards.
42 Coal-fired generation would introduce mechanical sources of noise that would be audible off 43 site. Sources contributing to total noise produced by plant operations are both continuous and December 2008 8-41 Draft NUREG-1437, Supplement 38 OAG10001366_00356
Environmental Impacts of License Renewal 1 intermittent. Continuous sources include the mechanical equipment associated with normal 2 plant operations. Intermittent sources include the coal-handling equipment, solid-waste disposal 3 systems, outside loudspeakers, and commuting activities of plant employees. Noise impacts 4 associated with rail delivery of coal and lime to the generating station site would be most 5 significant for residents living along the new rail spur leading to the plant. Although passing 6 trains significantly raise noise levels near rail corridors, the short duration of the noise tends to 7 minimize impacts.
8 Based on the cumulative potential impacts of construction activities, emissions, and noise on 9 human health, the NRC staff considers the impact of constructing and operating a new coal-10 fired facility to be MODERATE.
11
- Socioeconomics 12 Construction of a coal-fired facility at an alternate site would take approximately 4 years 13 (DOE/EIA 2007b). Based on estimates given in Table 8.1 of the GElS, the peak workforce is 14 estimated to range from 1.2 to 2.5 additional workers per MW(e) during the construction period.
15 For the 2200-MW(e) plant utilized in this analysis, the peak workforce would range from 16 approximately 2640 to as many as 5500 workers during the 4-year construction period (NRC 17 1996). During construction, the surrounding communities would experience demands on 18 housing and public services unless some of the workforce is composed of local residents. In 19 the GElS, the NRC staff stated that socioeconomic impacts would depend on the location of the 20 new plant. For example, at a rural site more of the peak construction workforce would need to 21 relocate (temporarily or permanently) to the area to work. Therefore, socioeconomic impacts 22 could range from SMALL to LARGE depending on whether workers would relocate to be near 23 the site, as well as depending on the size and makeup of the existing community.
24 At the end of construction, the local population would be affected by the loss of as many as 25 5000 construction jobs. However, this loss would be partially offset by a postconstruction 26 permanent employment rate of 0.25 workers per MW(e) based on Table 8.2 of the GElS, or a 27 total of 550 total workers. An additional construction workforce would be needed for the 28 decommissioning of IP2 and IP3 which could temporarily offset the impacts of the lost 29 construction and IP2 and IP3 jobs at the site.
30 The coal-fired plant would provide new tax revenue to its community. Because this plant would 31 be located in another community, it would have a positive impact on its community while the 32 shutdown of IP2 and IP3 will have a negative impact on the tax base of the IP2 and IP3 33 community.
34 The NRC staff concludes that the overall socioeconomic impacts of changes in the local 35 population from the influx of the construction workforce and changes to community tax revenues 36 could be SMALL to LARGE during construction and SMALL to MODERATE during operation, 37 depending on the size and economic structure of the affected communities.
38
- Transportation 39 During the 4-year construction period of the coal-fired unit, as many as 2600 to 5500 40 construction workers may be working at the site. During this same time period, trucks and trains 41 would likely be delivering construction materials to the site. The addition of these workers would 42 increase traffic on highways and local roads that lead to the construction site. The impact of this 43 additional traffic could have a MODERATE to LARGE impact on nearby roadways, particularly if Draft NUREG-1437, Supplement 38 8-42 December 2008 OAG10001366_00357
Environmental Impacts of License Renewal 1 the alternate site is in a rural area. Impacts associated with plant operating personnel 2 commuting to work are likely to be SMALL.
3 For rail transportation of coal and limestone to the alternate site, impacts are likely to range from 4 SMALL to LARGE, depending on local rail characteristics. On average, more than ten 100-car 5 trains per week would deliver coal to the new generating station, and two 1O-car trains per week 6 would deliver limestone to the facility. Transportation impacts associated with coal and 7 limestone delivery could range from SMALL to LARGE 8 Overall, transportation impacts could range from MODERATE to LARGE during construction, 9 and SMALL to LARGE during operation.
10
- Aesthetics 11 At an alternate site, plant buildings, exhaust stacks, cooling towers, and cooling tower plumes 12 would create aesthetic impacts. The coal-fired alternative's four power plant units would be up 13 to 200 ft (61 m) tall and may be visible off site in daylight hours. The three exhaust stacks could 14 be up to 600 ft (183 m) high (at least 500 ft (152 m) for good engineering practice). If the coal-15 fired alternative makes use of natural-draft cooling towers, then additional visual impacts will 16 occur from the towers, which may be several hundred feet tall and topped with condensate 17 plumes. Mechanical-draft towers would also generate condensate plumes, but would be 18 markedly shorter than natural-draft towers (or they may use hybrid towers like the alternative 19 described in Section 8.1 of this draft SEIS). Other buildings on site may also affect aesthetics, 20 as could construction of new transmission lines. Noise and light from plant operations, as well 21 as lighting on plant structures, may be detectable off site.
22 Aesthetic impacts at the plant site would be minimized if the plant were located in an industrial 23 area adjacent to other power plants or industrial facilities. Development of a new coal-fired 24 facility at an undeveloped alternate site, however, would entail construction of a new 25 transmission line and a new rail spur to bring coal and lime to the plant. The rail spur and 26 transmission line could extend many miles from the site to tie-in points with existing rail and 27 transmission systems. The visual intrusion of these two linear elements, particularly the 28 transmission line, could be significant.
29 Overall the aesthetic impacts associated with locating at an alternate site would be categorized 30 as MODERATE to LARGE for an undeveloped site, and may be SMALL to MODERATE at a 31 site previously developed for industrial uses.
32
- Historic and Archeological Resources 33 A cultural resource inventory would be needed for any property that has not been previously 34 surveyed. The survey would include an inventory of field cultural resources, identification and 35 recording of existing historic and archeological resources, and possible mitigation of adverse 36 effects from subsequent ground-disturbing actions related to physical expansion of the plant 37 site. The studies would likely be needed for all areas of potential disturbance at the proposed 38 plant site and along associated corridors where new construction would occur (e.g., roads, 39 transmission corridors, rail lines, or other ROWs).
40 Historic and archeological resource impacts can generally be effectively managed and, as such, 41 would be considered SMALL to MODERATE at a new undeveloped site, depending on the 42 sensitivity of the site. For a previously developed site, most of which have already been December 2008 8-43 Draft NUREG-1437, Supplement 38 OAG10001366_00358
Environmental Impacts of License Renewal 1 intensively developed, impact on cultural and historic resources would also be SMALL.
2 Previous development would likely have either removed items of archeological interest or may 3 have included a survey for sensitive resources. Any significant resources identified would have 4 to be handled in accordance with the NHPA.
5
- Environmental Justice 6 As described in Section 8.2 of this draft SEIS, no environmental impacts were identified that 7 would result in disproportionately high and adverse environmental impacts on minority and low-8 income populations if IP2 and IP3 were shut down.
9 Impacts at the location of the new four-unit coal-fired plant would depend upon the site chosen 10 and the nearby population distribution, but would likely be SMALL to MODERATE for most 11 alternate sites, but could reach LARGE. For previously developed industrial sites, impacts 12 could be larger or smaller, depending on the relative proximity of low-income populations.
13 Table 8-3. Summary of Environmental Impacts of the Coal-Fired Plant Alternative Located 14 at an Alternate Site Impact Category Impact Comment Land Use MODERATE to Uses up to 1500 ha (3700 ac) for plant, offices, parking, and LARGE waste disposal; additional impacts from transmission line and rail spur, as well as coal and limestone mining.
Ecology MODERATE to Impacts to terrestrial ecology would likely be MODERATE to LARGE LARGE, while impacts to aquatic ecology would likely be SMALL.
Draft NUREG-1437, Supplement 38 8-44 December 2008 OAG10001366_00359
Environmental Impacts of License Renewal 1 Table 8-3 (continued)
Impact Category Impact Comment Water Use and SMALL to With closed-cycle cooling, the impact would likely be SMALL, Quality MODERATE though it would depend on the volume of water withdrawn and discharged and the characteristics of the surface water body.
Air Quality MODERATE
- SOx: 5230 MT/yr (5748 tons/yr)
- NOx: 1129 MT/yr (1351 tons/yr)
- Total suspended particulates: 175 MT/yr (192 tons/yr)
- PM 10 : 40 MT/yr (44 tons/yr)
- CO: 1129 MT/yr (1315 tons/yr)
- Small amounts of mercury and other hazardous air pollutants Extensive emissions controls and regulations limit impacts to MODERATE.
Waste MODERATE Total waste production would be approximately 645,000 MT/yr (710,000 tons/yr) of ash (after some is recycled) and scrubber sludge requiring approximately 150 ha (370 ac) for disposal during the 40-year life of the plant. The plant would also generate relatively small amounts of conventional, hazardous, and universal wastes during operation.
Human Health MODERATE Impacts are uncertain, but considered MODERATE as the plant would comply with health-informed standards in the CAA and other relevant emissions regulations. Minor risk to workers associated with construction and industrial accidents.
Socioeconomics SMALL to Construction impacts depend on location, but would be LARGE LARGE if the plant is located in an area that is rural or is growing less quickly than areas near IP2 and IP3. IP2 and IP3 communities may lose tax revenue and employment, though economic growth would likely offset much of this loss.
Impacts from placement of a plant near to an urban area may be MODERATE. Impacts during operation would be smaller than during construction.
Transportation MODERATE to Transportation impacts could be MODERATE to LARGE, LARGE during construction, though operational impacts may be smaller during operations.
Aesthetics SMALL to The greatest impacts would be from new transmission lines, LARGE plant stacks, and rail lines to transport coal and lime. Impacts would be largest at an undeveloped site.
December 2008 8-45 Draft NUREG-1437, Supplement 38 OAG10001366_00360