ML11348A347

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New York State (NYS) Pre-Filed Hearing Exhibit NYS00133B, NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Regarding Indian Point Nuclear Generating, Units 2 & 3, Supplement 38, Volumes 1, 2, & 3.
ML11348A347
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 12/14/2011
From:
Office of Nuclear Reactor Regulation
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 21542, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01, NYS00133B
Download: ML11348A347 (153)


Text

NYS00133B Submitted: December 14, 2011 Plant and the Environment 1 Table 2-8. Housing in Dutchess, Orange, Putnam and Westchester Counties, New York Dutchess Orange Putnam Westchester ROI 2000 Total 106,103 122,754 35,030 349,445 613,332 Occupied housing units 99,536 114,788 32,703 337,142 584,169 Vacant units 6,567 7,966 2,327 12,303 29,163 Vacancy rate (percent) 6.2 6.5 6.6 3.5 4.8 Median value (dollars) 150,800 141,500 205,500 285,800 195,900 2006*

Total 111,507 132,983 36,471 355,581 636,542 Occupied housing units 104,289 121,887 33,544 333,114 592,834 Vacant units 7,218 11,096 2,927 22,467 43,708 Vacancy rate (percent) 6.5 8.3 8.0 6.3 6.9 Median value (dollars) 334,200 319,300 407,800 581,600 410,725

  • Estimated Source: USCB 2008a; 2006 American Community Survey 2 2.2.8.2 Public Services 3 This section presents a discussion of public services including water supply, education, and 4 transportation.

5 Water Supply 6 IP2 and IP3 do not utilize a public water system for plant circulating and service water purposes, 7 but instead rely on surface water from the Hudson River. Potable water and process water are 8 supplied to the site by the Village of Buchanan water supply system. Based on water bills, IP2 9 and IP3 utilize approximately 2.3 million cubic feet (fe) or 17.4 million gal per month (65,000 m3 10 or 8.7 million L per month) of potable water (VBNY 2006). There are no restrictions on the 11 supply of potable water from the Village of Buchanan. The Village of Buchanan obtains its 12 water from two sources, the City of Peekskill Public Water System and the Montrose 13 Improvement District. While the demand on the City of Peekskill Public Water System currently 14 appears to be near the system design capacity, the contract with the Montrose Improvement 15 District (now consolidated with the Northern Westchester Joint Water Works) appears to NRC 16 staff to be capable of providing an adequate supply of potable water based on treatment 17 capacity upgrades.

18 Public water supply systems in the vicinity of IP2 and IP3 include community and noncommunity 19 (including nontransient noncommunity and transient noncommunity) systems. Community 20 water systems within a 10 mi (16 km) radius of IP2 and IP3 include Westchester, Putnam, 21 Orange, and Rockland County systems. Each of these county systems uses both groundwater 22 and surface water sources (EPA 2006b). Although outside the 10 mi (16 km) radius, public 23 water supply systems in Dutchess County were included because Dutchess County provides 24 residence to the largest percentage of the site's permanent full-time employees (42 percent).

25 Approximately 57 percent of the Dutchess County community water systems, including the I NUREG-1437, Supplement 38 2-116 December 2010 OAGI0001367A_00154

Plant and the Environment 1 Poughkeepsie water supply system, obtain water from surface water sources that include the 2 Hudson River (EPA 2006b).

3 The Village of Buchanan purchases water from the City of Peekskill Public Water System and 4 the Montrose Improvement District. The City of Peekskill has two sources of water, both of 5 which are surface waters. The City of Peekskill's year-round major water source originates in 6 the Town of Putnam Valley (Putnam County). The City of Peekskill's second source of water is 7 an emergency source from a neighboring community, via the Catskill Aqueduct. Water is 8 pumped to the Camp Field Reservoir in the City of Peekskill, where it is then filtered and treated 9 (PWD 2005).

10 The Town of Cortlandt purchases 80 percent of its water supply from the Montrose 11 Improvement District, which treats raw water purchased from the New York City Catskill 12 Aqueduct. The town purchases 10 percent from the City of Peekskill, which filters and treats 13 raw water pumped from the Peekskill Hollow Brook to the city's Camp Field Reservoir, and 14 10 percent from the Town of Yorktown, which purchases water filtered and treated by the 15 Westchester County-owned Amawalk treatment plant (CCWD no date).

16 The Cortlandt Consolidated Water District (CCWD) has joined with the Yorktown and Montrose 17 Improvement District in a new corporation known as the Northern Westchester Joint Water 18 Works (NWJWW). The NWJWW has assumed ownership of the Amawalk treatment plant, 19 which has been upgraded to 7 mgd (26,000 m3/day) capacity. A new NWJWW 7 mgd (26,000 20 m3/day) plant (Catskill water treatment plant) has been in operation since 2000 (CCWD no 21 date).

22 Westchester Joint Water Works (WJWW) serves the municipalities of the Village/Town of 23 Mamaroneck, TownNiliage of Harrison, portions of the City of New Rochelle, and the City of 24 Rye. WJWW, which has a capacity of 14.2 mgd (53,800 m3/day) and an average daily demand 25 of 13.1 mgd (49,600 m3/d), obtains its water from the Catskill and Delaware watersheds of the 26 New York City water system, which includes the Delaware Aqueduct, Rye Lake (Delaware 27 watershed), and the Kensico reservoir (WJWW 2006).

28 A majority of Rockland County uses groundwater to supply numerous small public water 29 systems, most of which are supplied by a single well (RWS 2006). The large public water 30 systems of Rockland County include United Water New York (UWNY), Nyack Village Public 31 Water System, and Suffern Village Public Water System (RWS 2006). UWNY provides water to 32 approximately 267,000 residents from 53 groundwater wells drilled throughout the county, Lake 33 DeForest, and the Letchworth reservoirs (UWNY 2006). The UWNY peak demand in 2006 was 34 estimated at 47.5 mgd (180,000 m3/day) and its peak supply at approximately 48.5 mgd 35 (184,000 m3/day) (RCDH 2006).

36 The Poughkeepsie Water Treatment Facility, which is owned and operated by the City and 37 Town of Poughkeepsie, provides drinking water in Dutchess County to the City of 38 Poughkeepsie, Town of Poughkeepsie, and Village of Wappingers Falls. The plant is located 39 along and draws water from the Hudson River. The plant was built in 1962 and is currently 40 rated at a maximum capacity of 16 mgd (61,000 m3 /day). Average demand is reported to be 41 approximately 8 mgd (31,000 m3/day) (PTWD 2005).

42 The Village of Ossining Water System in Westchester County is supplied from two surface 43 water sources, the Indian Brook Reservoir, located near Fowler Avenue and Reservoir Road, 44 and the Croton Reservoir, which is part of the New York City Water System. The average blend December 2010 2-117 NUREG-1437, Supplement 38 OAGI0001367A_00155

Plant and the Environment 1 of water is approximately 63 percent from the Croton Reservoir and 37 percent from the Indian 2 Brook Reservoir. The system obtains its water from the Croton watershed in Putnam and 3 Westchester counties and serves approximately 30,000 people. The Village of Ossining Water 4 System services an average daily demand of approximately 3.7 mgd (14,000 m3/day) (VOWS 5 2005).

6 Many public water supply systems supply only small segments of the population. For example, 7 Orange County has approximately 150 public water systems, but no major public water systems 8 in the county were identified within 10 mi of IP2 and IP3. Groundwater is the primary source of 9 both community and noncommunity water supply systems and serves 60 to 85 percent of the 10 population in the area (NWWW2006; OCWA 2006; PCWD 2006; RCDH 2006). Large areas of 11 Westchester, Putnam, Orange, Rockland, and Dutchess Counties are not served by community 12 water supplies. Private water supplies in these areas draw primarily from groundwater sources.

13 The groundwater quality in New York is generally good, but contamination can and does occur 14 locally.

15 The Village of Croton-on-Hudson public water system is supplied by a groundwater well system 16 located downstream from the New Croton Dam and spillway. Groundwater is pumped from the 17 well system directly into the distribution system. The system has a total storage capacity of 18 2.3 mgd (8700 m3 /day) and supplies approximately 7600 people an average of 1.1 mgd 19 (4200 m3/day) (VCOH 2005).

20 Table 2-9 lists the major public water supply systems within the vicinity of IP2 and IP3.

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Plant and the Environment 1 Table 2-9. Major Public Water Supply Systems in 2005 (mgd)

Water Average Daily Design Population Water Supplier a Source a Production I:i Capacity b Served a Northern Westchester Joint Water Works C SW 6.9 14.0 0 Peekskill, NY SW 3.9 4.0 22,400 Croton-on-Hudson, NY GW 1.1 2.3 7,100 Westchester Joint Water Works SW 13.1 14.2 55,200 Ossining, NY SW 3.7 6.0 30,000 Poughkeepsie, NY SW 8.9 16.0 28,000 United Water New York GW&SW 47.5 48.5 270,000 Village of Suffern GW 2.0 4.0 12,000 Village of Nyack SW 1.8 3.0 14,700 GW = Groundwater; SW = surface water; N/A = Not Applicable or No Information Available a EPA 2008b Average daily production and design capacity. Information from 2005 Annual Drinking Water Quality Report for each public water system.

C Includes the CCWD, Yorktown Improvement District, and the Montrose Improvement District (CCWD 2006).

2 An estimated 85,000 residents north of Kensico Dam in Westchester County use groundwater 3 as their primary water source. Exceptions are residents using surface water or aqueduct 4 sources in Mt. Kisco, parts of the Town of Yorktown, much of the Town of Cortlandt, and most 5 municipalities directly adjoining the Hudson River (WCDP 2003). Approximately 15 percent of 6 the residents of the Town of Cortlandt are estimated to use groundwater supplies (WCDP 2003, 7 Table 2).

8 Education 9 IP2 and IP3 are located in the Hendrick Hudson Central School District, Westchester County, 10 which had an enrollment of approximately 2800 students in 2003. Including the Hendrick 11 Hudson Central School District, Westchester County has 40 school districts with a total 12 enrollment of approximately 147,000 students. In contrast, Dutchess, Orange, and Putnam 13 Counties have 16, 17, and 6 school districts with a total enrollment of approximately 46,000, 14 66,000, and 17,000 students, respectively (WCDP 2005).

15 Transportation 16 Several major highway routes serve as transportation corridors along either side of the Hudson 17 River Valley. Westchester County and Putnam County are located on the eastern side of the 18 Hudson River. The primary highways in Westchester County include Interstate 684, US 9, 19 US 6, and US 202, as well as the Taconic State and Saw Mill River Parkways (see Figures 2-1 20 and 2-2). US 9 runs north and south along the Hudson River Valley through both Westchester 21 and Putnam Counties. Further east, the Taconic State Parkway also runs north and south December 2010 2-119 NUREG-1437, Supplement 38 OAGI0001367A_00157

Plant and the Environment 1 through both counties. The Taconic State Parkway and the Saw Mill River Parkway connect 2 near Hawthorne, New York, southeast of the site. Interstate 684 runs north and south along the 3 eastern side of Westchester County and connects to Interstate 84 in Putnam County. US 6 runs 4 east and west through the southern end of Putnam County and the northern portion of 5 Westchester County. US 202 runs east and west across northern Westchester County. The 6 Saw Mill River Parkway extends northeast and southwest between US 9 at Riverdale, New 7 York, and Interstate 684. Additional highways within the two counties include State Routes 117, 8 120, 129, 100, 139, and 301.

9 The nearest highway serving the site area is US 9. Using local roads from US 9, the site can be 10 accessed from Broadway. A summary of data from 2005 of the New York State Department of 11 Transportation estimates for average annual daily traffic counts on US 9 north and south of the 12 site is presented in Table 2-10.

13 The Palisades Interstate Parkway is the largest highway system in Rockland County, running 14 north and south through the county, and connecting with US 6 and US 9W in southeastern 15 Orange County (see Figure 2-2). US 9W runs north and south along the Hudson River and 16 connects with Interstate 87 to the south at the Village of Nyack, New York. Interstate 87 allows 17 travel north and south through Orange County but then loops toward the east across Rockland 18 County, crosses the Hudson, and intersects US 9, the Saw Mill River Parkway, and the Taconic 19 State Parkway in Westchester County. US 202 runs northeast and southwest through Rockland 20 County till it meets US 9W and then crosses the Hudson River and runs easterly and intersects 21 the Taconic State Parkway. Route 17 (future Interstate 86) runs northwest and southeast 22 across Orange County to where it intersects Interstate 87, and turns south until it intersects 23 Route 3 near New York City. Interstate 84 runs east and west through Orange County, crosses 24 the Hudson River, and travels down Dutchess County and into Putnam County were it meets 25 Interstate 684.

26 Dutchess County is located approximately 13 mi (21 km) north of the site, on the east side of 27 the Hudson River. The major roads in this county are Interstate 84, US 44, US 9, Route 199 28 (Taconic State Parkway), and Route 22. Interstate 84 and US 44 run east and west in the 29 southern and central portions of the county, respectively. Route 199 (Taconic State Parkway),

30 Route 22, and US 9 run north and south in the central, eastern, and western portions of the 31 county, respectively.

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Plant and the Environment 1

2 Table 2-10. Average Annual Daily Traffic Counts on US 9 Near IP2 and IP3, 2004a Annual Average Daily Roadway and Location Traffic US 9-from Montrose crossing to Route 9A overlap b 50,500 US 9-from Peekskill city line to Montrose crossing 11,aooc US 9-from Montrose crossing to Old Post Road crossing Source: NYSDOT 2005 a Traffic volume during the average 24-hour day during 2004.

b Readings taken at a continuous count station (accounts for seasonal and daily variation).

C NYSDOT projection from the latest year for which data were available.

3 2.2.8.3 Offsite Land Use 4 This section describes land use conditions in Dutchess, Orange, Putnam, and Westchester 5 Counties in New York, because the majority of the IP2 and IP3 workforce lives in these 6 counties. In addition to payment-in-lieu-of-taxes (PILOT) and property tax payments to 7 Westchester County, the surrounding counties receive property tax payments from the 1255 8 people employed by the site.

9 Dutchess County 10 Dutchess County is distinctly different from its neighboring counties in that it contains a 11 combination of urban and rural settings rather than metropolitan areas. Currently, Dutchess 12 County is conserving open spaces such as farms while increasing the number of housing units 13 available in order to create a mix of urban areas and farmland (Dutchess County Department of 14 Planning and Development 2006).

15 Dutchess County occupies roughly 802 sq mi (2080 sq km) or approximately 513,000 acres 16 (208,000 ha) (USCB 2008b). The largest category of land use in Dutchess County is 17 agriculture. Evenly distributed throughout the county, land used for agriculture makes up 18 21.3 percent (112,339 acres (45,462 ha)) of the county's area (USDA 2002a). Major agricultural 19 land uses consist of cropland (52.75 percent), woodland (23.32 percent), pasture 20 (11.12 percent), and other uses (12.81 percent) (USDA 2002a). Residential land areas cover 21 approximately 7.1 percent of Dutchess County, with approximately 1.4 percent being devoted to 22 commercial, industrial, and transportation uses (Entergy 2007a).

23 Dutchess County is planning to create developments in central locations by developing mass 24 transit systems and waterways. Retail areas are planned to be centralized and within 25 convenient walking distance from these transient terminals. Developments outside the primary 26 growth areas are designed to blend into the natural landscape. In this way, Dutchess County 27 hopes to maintain its open spaces and farming culture (PDCTC 2006; Dutchess County 28 Department of Planning and Development 2006).

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Plant and the Environment 1 Orange County 2 Three interstates intersect within Orange County. A byproduct of the county's interstate road 3 access is a clustering of industry and commercial development along these highway corridors.

4 Recently, most new development has occurred in the southeastern corner of the county as a 5 result of the access to major transportation corridors. The largest land development in the 6 southeastern part of the county is the U.S. Military Academy at West Point (see Figure 2-2) 7 (Orange County Department of Planning 2003).

8 Orange County occupies roughly 816 sq mi (2110 sq km) or approximately 522,000 acres 9 (211,000 ha) (USCB 2008b). Approximately 107,977 acres (43,697 ha) are used for agricultural 10 purposes, with major agricultural land uses consisting of cropland (65.53 percent), woodland 11 (16.50 percent), pasture (8.99 percent), and other uses (8.98 percent) (USDA 2002b).

12 Residential land areas cover approximately 7.5 percent of Orange County, with approximately 13 1.7 percent devoted to commercial, industrial, and transportation uses (Entergy 2007a).

14 Orange County's Comprehensive Development Plan continues to reflect the importance of 15 transportation interchanges, crossroads, and corridors (Orange County Department of Planning 16 2003). The dynamic real estate market and the loss of open spaces has been a challenge for 17 Orange County. The county, along with civic organizations, has been inventorying current open 18 spaces as part of defining and recommending future open space needs. Orange County also 19 plans to initiate a redevelopment program to assist with historical improvements to the cities and 20 villages within Orange County. With the increasing growth of Orange County, nontraditional 21 zoning strategies are expected to help maintain historical and open spaces throughout the 22 county (Orange County Department of Planning 2003).

23 Putnam County 24 Putnam County occupies roughly 231 sq mi (598 sq km) or approximately 148,000 acres 25 (59,900 ha) (USCB 2008b) and is one of the fastest growing counties in New York (Putnam 26 County Division of Planning and Development 2003). Approximately 6720 acres (2720 ha) 27 (4.3 percent) are in agricultural use, with major agricultural land uses consisting of woodland 28 (59.87 percent), cropland (26.49 percent), and other uses (13.65 percent) (USDA 2002c). Hilly 29 topography has prevented or slowed development in the more rugged parts of the county.

30 Additionally, there are many wetlands throughout the county. The most significant wetland in 31 the county is the Great Swamp, which is a 4200-acre (1700-ha) wetland. Agricultural land use, 32 undeveloped land, and forest land within the county have been decreasing. Residential land 33 use occurs on large lot subdivisions or in rural areas. Industrial and commercial development 34 can be found around the villages and along the major transportation corridors (Putnam County 35 Division of Planning and Development 2003). Residential land use accounts for approximately 36 6.9 percent of the county's land, while only 1.1 percent is used for commercial, industrial, or 37 transportation purposes (Entergy 2007a).

38 Putnam County attempts to integrate development into the natural environment, which includes 39 enhancing, when possible, views of the Hudson River (Putnam County Division of Planning and 40 Development 2003). The county and municipalities are working together by changing the 41 zoning ordinances and subdivision regulations to preserve strategic historic structures and 42 protect open spaces, while providing affordable housing and development throughout the 43 county (Putnam County Division of Planning and Development 2003).

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Plant and the Environment 1 Westchester County 2 Westchester County occupies roughly 433 sq mi (1121 sq km) or approximately 277,000 acres 3 (112,000 ha) (USCB 2008b). According to the 2002 U.S. Department of Agriculture (USDA) 4 Census of Agriculture, 129 farms were located in Westchester County, which is a 10 percent 5 increase since 1997 (USDA 2002e). Land acreage associated with farms increased 14 percent 6 during this period with total acreage increasing from 8681 acres (3513 ha) to over 9917 acres 7 (4013 ha). The average size of farms also increased 4 percent, from 74 to 77 acres (30 to 8 31 ha) from 1997 to 2002. Of the approximately 9917 acres (4013 ha) in agricultural land use in 9 2002, the major agricultural land uses consisted of woodland (48.84 percent), cropland 10 (24.83 percent), pasture (12.81 percent), and other uses (13.53 percent) (USDA 2002d).

11 Residential land areas cover approximately 30.1 percent of Westchester County, with 12 approximately 3.1 percent devoted to commercial, industrial, and transportation uses (Entergy 13 2007a). The long-range plan for the physical development of Westchester County concentrates 14 on three distinct physical characteristics-centers, corridors, and open space (Westchester 15 County Department of Planning 2000).

16 IP2 and IP3 are located in Westchester County in the Village of Buchanan, within the Town of 17 Cortlandt. IP2 and IP3 provide tax revenues and other payments to both the Town of Cortlandt 18 and the Village of Buchanan. The Town of Cortlandt encompasses 34.5 sq mi (89.4 sq km) or 19 22,080 acres (8935 ha) (TOCNY 2006). Land use is predominately residential zoning with 20 %-acre to 2-acre plots further protecting environmentally sensitive areas and open spaces 21 (TOCNY 2004). The town's growth was intentionally slowed over the past several decades, 22 allowing the town's leaders to plan its development. Significant commercial development has 23 taken place along major transportation corridors, as well as at new community facilities within 24 the area. From 1992 to 2004, the Town of Cortlandt has increased open space by 65 percent 25 from 2729 acres (1104 ha) to 4502 acres (1822 ha) (TOCNY 2004). The town also has made 26 an effort to increase public access to the Hudson River waterfront and encourage historic 27 preservation (TOCNY 2004).

28 The Village of Buchanan, located within the Town of Cortlandt, encompasses 1.4 sq mi (3.6 sq 29 km) or 896 acres (363 ha) (VBNY 1998). Land use in the village has changed very little over 30 the last 20 to 30 years. The Village of Buchanan recently began restoring older buildings to 31 beautify the village square. The Village of Buchanan has zoning ordinances, subdivision 32 ordinances, and a development review board (Miller 2006).

33 2.2.8.4 Visual Aesthetics and Noise 34 IP2 and IP3 can be seen from the Hudson River but are shielded from the land side by 35 surrounding high ground and vegetation. With the exception of Broadway, the site is also 36 shielded from view from the Village of Buchanan. The superheater stack for IP1 (334 ft (102 m) 37 tall), the IP2 and IP3 turbine buildings (each 134 ft (41.8 m) tall), and reactor containment 38 structures (each 250 ft (76 m) tall) dominate the local landscape and can be seen from the 39 Hudson River.

40 Noise from IP2 and IP3 is detectable offsite, and the Village of Buchanan has a sound 41 ordinance (Chapter 211-23 of the Village Zoning Code) that limits allowable sound levels at the 42 property line of the sound generating facility. The combined frequencies of the sound standard 43 equate to an overall level of 48 decibels (dB(A)). An ambient noise level monitoring program 44 was conducted in the vicinity of IP2 and IP3 between September 2001 and January 2002, which December 2010 2-123 NUREG-1437, Supplement 38 OAG10001367A_00161

Plant and the Environment 1 showed that IP2 and IP3 meet the Village of Buchanan's sound ordinance (Enercon Services 2 2003).

3 2.2.8.5 Demography 4 According to the 2000 census, approximately 1,113,089 people lived within 20 mi (32 km) of IP2 5 and IP3, which equates to a population density of 886 persons per sq mi (332 persons per 6 sq km) (Entergy 2007a). This density translates to the least sparse Category 4 (greater than or 7 equal to 120 persons per square mile within 20 mi). Approximately 16,791,654 people live 8 within 50 mi (80 km) of IP2 and IP3 (Entergy 2007a). This equates to a population density of 9 2138 persons per sq mi (825 persons per sq km). Applying the proximity measures from 10 NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear 11 Power Plants" (GElS), IP2 and IP3 are classified as proximity Category 4 (greater than or equal 12 to 190 persons per square mile within 50 mi (80 km)). Therefore, according to the sparseness 13 and proximity matrix presented in the GElS, the IP2 and IP3 ranks of sparseness Category 4 14 and proximity Category 4 indicate that IP2 and IP3 are located in a high-population area.

15 Table 2-11 shows population projections and growth rates from 1970 to 2050 in Dutchess, 16 Orange, Putnam, and Westchester Counties. The population growth rate in Westchester 17 County for the period of 1990 to 2000 was the lowest of the four counties at 5.6 percent.

18 County populations are expected to continue to grow in all four counties in the next decades 19 although Westchester County's population is expected to increase at a lower rate. Dutchess, 20 Orange, and Putnam County populations are projected to continue to grow at a rapid rate 21 through 2050.

22 The 2000 and 2006 (estimate) demographic profiles of the four-county ROI population are 23 presented in Table 2-12 and Table 2-13. Minority individuals (both race and ethnicity) constitute 24 28.8 percent of the total four-county population. The minority population was composed largely 25 of Hispanic or Latino and Black or African-American residents.

26 According to the U.S. Census Bureau's 2006 American Community Survey, minority populations 27 in the four-county region were estimated to have increased by nearly 90,000 persons and made 28 up 32.7 percent of the total four-county population in 2006 (see Table 2-13). The largest 29 increases in minority populations were estimated to occur in Hispanic or Latino and Asian 30 populations. The Black or African-American population increased by approximately 5 percent 31 from 2000 to 2006 but remained unchanged as a percentage of the total four-county population.

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Plant and the Environment 1 Table 2-11. Population and Percent Growth in Dutchess, Orange, Putnam, and 2 Westchester Counties, New York, from 1970 to 2000 and Projected for 2010 and 2050 Dutchess Orange Putnam Westchester Percent Percent Percent Percent Year Population Growth(a) Population Growth(a) Population Growth(a) Population Growth(a) 1970 222,295 221,657 56,696 894,104 1980 245,055 10.2 259,603 17.1 77,193 36.2 866,599 -3.1 1990 259,462 5.9 307,647 18.5 83,941 8.7 874,866 1.0 2000 280,150 8.0 341,367 11.0 95,745 14.1 923,459 5.6 2006 295,146 5.4 376,392 10.3 100,603 5.1 949,355 2.8 2010 328,000 17.1 408,900 19.8 110,000 14.9 974,200 5.5 2020 362,900 10.6 467,000 14.2 120,300 9.4 985,800 1.2 2030 431,500 18.9 532,400 14.0 134,300 11.6 1,011,900 2.6 2040 460,450 6.7 584,005 9.7 146,439 9.0 1,054,968 4.3 2050 503,133 9.3 641,518 9.8 158,966 8.6 1,088,609 3.2

- = No data available.

(a) Percent growth rate is calculated over the previous decade.

Sources: Population data for 1970 through 2000 (USCB 2008c); population data for 2006 (estimated) 2006 American Community Survey; population projections for 2010-2030 by New York Metropolitan Transportation Council, September 2004; population projections for 2040 and 2050 (calculated) 3 December 2010 2-125 NUREG-1437, Supplement 38 I OAG10001367A_00163

Plant and the Environment 1 Table 2-12. Demographic Profile of the Population in the IP2 and IP3 2 Four-Count~ ROI in 2000 Region of Dutchess Orange Putnam Westchester Influence Total Population 280,150 341,367 95,745 923,459 1,640,721 Race (percent of total population, not Hispanic or Latino)

White 80.3 77.6 89.8 64.1 71.2 Black or African-American 8.9 7.5 1.5 13.6 10.8 American Indian and Alaska Native 0.2 0.2 0.1 0.1 0.1 Asian 2.5 1.5 1.2 4.4 3.3 Native Hawaiian and Other Pacific Islander 0.0 0.0 0.0 0.0 0.0 Some other race 0.2 0.1 0.1 0.3 0.3 Two or more races 1.5 1.4 1.0 1.8 1.6 Ethnicity Hispanic or Latino 18,060 39,738 5,976 144,124 207,898 Percent of total population 6.4 11.6 6.2 15.6 12.7 Minority Population (including Hispanic or Latino ethnicity)

Total minority population 55,237 76,607 9,772 331,683 473,299 Percent minority 19.7 22.4 10.2 35.9 28.8 3 Source: useB 2008c 4

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Plant and the Environment 1 Table 2-13. Demographic Profile of the Population in the IP2 and IP3 2 Four-County ROI in 2006 (Estimate)

Region of Dutchess Orange Putnam Westchester Influence Total Population 295,146 376,392 100,603 949,355 1,721,496 Race (percent of total population, not Hispanic or Latino)

White 77.2 71.1 85.0 60.8 67.3 Black or African-American 7.8 8.7 2.0 13.5 10.8 American Indian and Alaska Native 0.1 0.3 0.0 0.1 0.1 Asian 3.4 2.5 2.2 5.5 4.3 Native Hawaiian and Other Pacific Islander 0.1 0.0 0.0 0.0 0.0 Some other race 0.2 0.3 0.1 0.5 0.4 Two or more races 2.6 1.7 1.0 1.0 1.5 Ethnicity Hispanic or Latino 24,879 57,980 9,692 175,990 268,541 Percent of total population 8.4 15.4 9.6 18.5 15.6 Minority Population (including Hispanic or Latino ethnicity)

Total minority population 67,160 108,604 15,068 372,414 563,246 Percent minority 22.8 28.9 15.0 39.2 32.7 Source: useB 2008c 3 Transient PO[2ulation 4 Within 50 mi (SO km) of IP2 and IP3, colleges and recreational opportunities attract daily and 5 seasonal visitors who create demand for temporary housing and services. In 2007, there were 6 approximately 655,000 students attending colleges and universities within 50 mi (SO km) of IP2 7 and IP3 (lES 200S).

S In 2000 in Westchester County, O.S percent of all housing units were considered temporary 9 housing for seasonal, recreational, or occasional use. By comparison, seasonal housing 10 accounted for 2.3 percent, 1.S percent, 4.0 percent, and 3.1 percent of total housing units in 11 Dutchess, Orange, and Putnam Counties, and New York as a whole, respectively (USCB 12 200Sc). Table 2-14 provides information on seasonal housing located within 50 mi (SO km) of 13 IP2 and IP3.

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Plant and the Environment 1 Table 2-14. Seasonal Housing within 50 mi (80 km) of the IP2 and IP3 I Vacant housing units: For seasonal, County a Housing units recreational, or occasional use Percent New York 7,679,307 235,043 3.1 Bronx 490,659 962 0.2 Dutchess 106,103 2,410 2.3 Kings 930,866 2,616 0.3 Nassau 458,151 3,086 0.7 New York 798,144 19,481 2.4 Orange 122,754 2,215 1.8 Putnam 35,030 1,417 4.0 Queens 817,250 4,574 0.6 Richmond 163,993 524 0.3 Rockland 94,973 380 0.4 Suffolk 522,323 38,350 7.3 Sullivan 44,730 13,309 29.8 Ulster 77,656 5,238 6.7 Westchester 349,445 2,711 0.8 County Subtotal 5,012,077 97,273 4.1 (avg)

Connecticut 1,385,975 23,379 1.7 Fairfield 339,466 3795 1.1 Litchfield 79,267 4579 5.8 New Haven 340,732 3,245 1.0 County Subtotal 759,465 11619 2.6 (avg)

New Jersey 3,310,275 109,075 3.3 Bergen 339,820 1266 0.4 Essex 301,011 660 0.2 Hudson 240,618 674 0.3 Middlesex 273,637 905 0.3 Morris 174,379 1237 0.7 Passaic 170,048 849 0.5 Somerset 112,023 456 0.4 Sussex 56,528 3575 6.3 Union 192,945 475 0.2 Warren 41,157 361 0.9 County Subtotal 1,902,166 10,458 1.0 (avg)

Pennsylvania 5,249,750 148,230 2.8 Pike 34,681 15350 44.3 County Subtotal 34,681 15,350 44.3 (avg)

County Total 7,708,389 134,700 4.3 (avg)

Source: USCB 2008c a Counties within 50 mi of IP2 and IP3 with at least one block group located within the 50-mi radius avg = percent average for counties within the IP2 and IP3 50-mi radius and excludes state percentage I NUREG-1437, Supplement 38 2-128 December 2010 OAG10001367A_00166

Plant and the Environment 1 Migrant Farm Workers 2 Migrant farm workers are individuals whose employment requires travel to harvest agricultural 3 crops. These workers mayor may not have a permanent residence. Some migrant workers 4 may follow the harvesting of crops, particularly fruit, throughout the northeastern U.S. rural 5 areas. Others may be permanent residents near IP2 and IP3 who travel from farm to farm 6 harvesting crops.

7 Migrant workers may be members of minority or low-income populations. Because they travel 8 and can spend significant time in an area without being actual residents, migrant workers may 9 be unavailable for counting by census takers. If uncounted, these workers would be 10 underrepresented in U.S. Census Bureau (USCB) minority and low-income population counts.

11 Information on migrant farm and temporary labor was collected in the 2002 Census of 12 Agriculture. Table 2-15 provides information on migrant farm workers and temporary farm labor 13 (fewer than 150 days) within 50 mi (80 km) of IP2 and IP3. According to the 2002 Census of 14 Agriculture, approximately 9100 farm workers were hired to work for fewer than 150 days and 15 were employed on 1800 farms within 50 mi (80 km) of the IP2 and IP3. The county with the 16 largest number of temporary farm workers (1951 workers on 193 farms) was Suffolk County in 17 New York.

18 In the 2002 Census of Agriculture, farm operators were asked for the first time whether any 19 hired migrant workers, defined as a farm worker whose employment required travel that 20 prevented the migrant worker from returning to his or her permanent place of residence the 21 same day. A total of 360 farms in the 50-mi (80-km) radius of IP2 and IP3 reported hiring 22 migrant workers. Suffolk County in New York reported the most farms (110) with hired migrant 23 workers, followed by Orange and Ulster Counties in New York with 69 and 55 farms, 24 respectively. Dutchess, Putnam, and Westchester Counties host relatively small numbers of 25 migrant workers compared to those counties.

26 According to 2002 Census of Agriculture estimates, 275 temporary farm laborers (those working 27 fewer than 150 days per year) were employed on 34 farms in Westchester County, and 435, 28 1583, and 127 temporary farm workers were employed on 132,244, and 22 farms, respectively, 29 in Dutchess, Orange, and Putnam Counties (USDA 2002e).

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Plant and the Environment 1 Table 2-15. Migrant Farm Worker and Temporary Farm Labor within 50 mi (80 km) 2 of IP2 and IP3 Number of farm Number of farms Number of farms workers working hiring workers reporting Number of farms fewer than for fewer than migrant farm with hired farm County a 150 days 150 days labor labor New York Bronx 0 0 0 0 Dutchess 435 132 18 194 Kings 0 0 0 0 Nassau 91 24 4 31 New York 0 0 0 4 Orange 1583 244 69 349 Putnam 127 22 0 27 Queens 1 0 1 Richmond 1 0 3 Rockland 69 19 0 21 Suffolk 1951 193 110 313 Sullivan 595 100 1 124 Ulster 550 102 55 163 Westchester 275 34 3 68 Subtotal 5676 872 260 1298 Connecticut Fairfield 377 108 1 114 Litchfield 459 174 9 198 New Haven 713 88 25 102 Subtotal 1549 370 35 414 New Jersey Bergen 103 32 3 40 Essex 3 1 4 Hudson 0 0 0 0 Middlesex 334 71 15 92 Morris 432 69 12 83 Passaic 66 15 4 17 Somerset 160 100 8 114 Sussex 200 158 4 217 Union 7 1 8 Warren 549 131 17 178 Subtotal 1844 586 65 753 3

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Plant and the Environment 1 Table 2-15 (continued)

Number of farm Number of farms Number of farms workers working hiring workers reporting Number of farms fewer than for fewer than migrant farm with hired farm County a 150 days 150 days labor labor Pennsylvania Pike 8 0 10 Subtotal 8 0 10 Total 9069 1836 360 2475 Source: USDA 2002e, "Census of Agriculture," County Data, Table 7. Hired Farm Labor-Workers and Payroll:

2002 a Counties within 50 mi of IP2 and IP3 with at least one block group located within the 50-mi radius 2 2.2.8.6 Economy 3 This section contains a discussion of the economy, including employment and income, 4 unemployment, and taxes.

5 Employment and Income 6 Between 2000 and 2006, the civilian labor force in Westchester County increased 3.8 percent 7 from 452,417 to 469,558. The civilian labor force in Dutchess, Orange, and Putnam Counties 8 also grew by 11.9, 16.4, and 9.4 percent, respectively (USCB 2008c).

9 In 2002, health care and social assistance represented the largest sector of employment in the 10 four-county region followed closely by retail, manufacturing, and the accommodation and food 11 service industry. The health care and social assistance sector employed the most people in 12 Westchester County followed by retail trade and professional, scientific, and technical services 13 sectors. A list of some of the major employers in Westchester County in 2006 is provided in 14 Table 2-16. As shown in the table, the largest employer in Westchester County in 2006 was 15 IBM Corporation with 7475 employees.

16 Income information for the IP2 and IP3 ROI is presented in Table 2-17. In 1999, the date of the 17 last economic census, the four counties each had median household incomes far above the 18 New York State average. Per capita income, with the exception of Orange County, was also 19 above the New York State average. In 1999, only 8.8 percent of the population in Westchester 20 County was living below the official poverty level, while in Dutchess, Orange, and Putnam 21 Counties, 7.5, 10.5, and 4.4 percent of the respective populations were living below the poverty 22 level. The percentage of families living below the poverty level was about the same for 23 Dutchess, Orange, and Westchester Counties. Putnam County had the smallest percentage of 24 families living below the poverty level (USCB 2008c).

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Plant and the Environment 1 Table 2-16. Major Employers in Westchester County in 2006 Firm Number of Employees IBM Corporation 7475 County of Westchester 5881 Yonkers Public Schools 4049 Westchester Medical Center 3367 United States Postal Service District Office 3007 Verizon Communications 2733 Sound Shore Health System of Westchester 2515 City of Yonkers 2418 Riverside Health Care (S1. John's Riverside Hospital) 2418 PepsiCo Incorporated 2372 White Plains Hospital Center 1923 New York State Department of Correctional Services 1735 Pace University 1620 MTA Metro-North Railroad 1617 Entergy Nuclear Northeast 1500 Morgan Stanley 1475 The Bank of New York Company 1450 Mount Vernon City School District 1450 Con Edison 1400 City School District of New Rochelle 1352 Phelps Memorial Hospital Center 1347 White Plains Public Schools 1285 Source: The Journal News 2006 2 Table 2-17. Income Information for the IP2 and IP3 ROI Dutchess Orange Putnam Westchester New York Median household income 1999 (dollars) 53,086 52,058 72,279 63,582 43,393 Per capita income 1999 (dollars) 23,940 21,597 30,127 36,726 23,389 Percent of families living below the poverty level (2000) 5.0 7.6 2.7 6.4 11.5 Percent of individuals living below the poverty level (2000) 7.5 10.5 4.4 8.8 14.6 Source: useB 2008c I NUREG-1437, Supplement 38 2-132 December 2010 OAGI0001367 A_00170

Plant and the Environment 1 Unemployment 2 In 2006, the annual unemployment averages in Westchester and Dutchess, Orange, and 3 Putnam Counties were 5.3, 5.5, 6.2, and 4.8 percent, respectively, which were lower than the 4 annual unemployment average of 6.5 percent for the State of New York (USCB 2008c).

5 Taxes 6 IP2 and IP3 are assessed annual property taxes by the Town of Cortlandt, the Village of 7 Buchanan, and the Hendrick Hudson Central School District. PILOT payments, property taxes, 8 and other taxes from the site are paid directly to the Town of Cortlandt, the Village of Buchanan, 9 and the Hendrick Hudson Central School District (see Table 2-18). The payments to the Town 10 of Cortlandt are distributed to the Town of Cortlandt, Westchester County, the Verplanck Fire 11 District, the Hendrick Hudson Central School District, and Lakeland Central Schools.

12 PILOT payments, property taxes, and other taxes paid by Entergy account for a significant 13 portion of revenues for these government agencies. The remainder is divided between the 14 Village of Buchanan, Westchester County, the Town of Cortlandt, and the Verplanck Fire 15 District.

16 The Village of Buchanan is the principal local jurisdiction that receives direct revenue from the 17 site. In fiscal year 2006, PILOT payments, property taxes, and other taxes from the site 18 contributed about 39 percent of the Village of Buchanan's total revenue of $5.07 million, which 19 is used for police, fire, health, transportation, recreation, and other community services for over 20 2100 residents (NYSOSC 2007). Additionally in fiscal year 2006, PILOT payments, property 21 taxes, and other taxes from the site contributed over 27 percent of the total revenue collected 22 for the Hendrick Hudson Central School District.

23 Entergy also pays approximately $1 million dollars per year to New York State Energy Research 24 and Development Authority (NYSERDA) for lease of the discharge canal structure and 25 underlying land (NYSERDA 2007).

26 From 2003 through 2006, the Town of Cortlandt had between $31.6 and $34.5 million annually 27 in total revenues (NYSOSC 2008). Between 2003 and 2006, IP2 and IP3 PILOT and property 28 tax payments represented 11 to 16 percent of the Town's total revenues (see Table 2-18).

29 From 2003 through 2006, the Hendrick Hudson Central School District had between $51 and 30 $57 million annually in total revenues (NYSOSC 2008). Between 2003 and 2006, IP2 and IP3 31 PILOT payments represented 27 to 38 percent of the school district's total revenues (see 32 Table 2-18).

33 From 2003 to 2006, the Village of Buchanan had between $5 and $5.7 million annually in total 34 revenues (NYSOSC 2008). Between 2003 and 2006, IP2 and IP3 PILOT and property tax 35 payments represented between 39 and 44 percent of the Village's total revenues (see 36 Table 2-18).

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Plant and the Environment 1 Table 2-18. IP2 and IP3 PILOT and Property Tax Paid and Percentage of the Total 2 Revenue of the Town of Cortlandt, Hendrick Hudson Central School District, and Village 3 of Buchanan, 2003 to 2006 PILOT and Property Tax Total Revenue Paid Percent of Entity Year (millions of dollars) (millions of dollars) Total Revenue Town of Cortlandt 2003 31.6 5.0 16 2004 31.9 4.7 15 2005 34.5 3.8 11 2006 33.8 3.7 11 Hendrick Hudson 2003 51.1 19.6 38 Central School 2004 52.8 18.9 36 District 2005 56.9 16.9 30 2006 55.9 15.3 27 Village of 2003 5.7 2.3 40 Buchanan 2004 5.0 2.2 44 2005 5.1 2.0 39 2006 5.1 2.0 39 Source: NYSOSC 2008; ENN 2007c 4 2.2.9 Historic and Archeological Resources 5 This section presents a brief summary of the region's cultural background and a description of 6 known historic and archaeological resources at the IP2 and IP3 site and its immediate vicinity.

7 The information presented was collected from the New York State Historic Preservation Office 8 (NYSHPO), and the applicant's environmental report (Entergy 2007a).

9 2.2.9.1 Cultural Background 10 Prehistory 11 The basic prehistoric cultural sequence and chronology for New York State is presented in 12 Table 2-19 below and the text that follows. This cultural sequence was generated primarily for 13 western and southern New York, and its applicability to the unusual estuarine environments of 14 the lower Hudson and southeastern New York is uncertain. Given the lack of excavated data 15 specific to the lower Hudson River Valley, the NRC staff used this generalized sequence 16 (Ritchie 1980).

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Plant and the Environment 1 Table 2-19. Cultural Sequence and Chronology Cultural Period Time Period Paleo-Indian Period 10000-7000 B.C.

Archaic Period 7000-1000 B.C.

Woodland Period 1000 B.C.-A.D. 1524 European Contact A.D. 1524-1608 2 Paleo-Indian Period 3 Archeological evidence suggests that Paleo-Indian people were hunter-gatherers who primarily 4 hunted large mammals using projectiles tipped with distinctively flaked "fluted" stone points.

5 These small, widely dispersed bands ranged over large geographic areas supplementing food 6 taken from large mammal hunts by collecting edible wild plant foods, fishing, and hunting 7 smaller game (Ritchie 1980).

8 Humans entered upstate New York and the Hudson River Valley for the first time around 9 10,000-9,000 B.C. Ritchie (1980) reports isolated finds of fluted points characteristic of the 10 Clovis tradition in the Albany area. Data on Paleo-Indian fluted points indicate only one 11 example each in Westchester, Rockland, and Orange Counties. Levine's more extensive 12 publication (1989) regarding Paleo-Indian fluted points from surface collections in the Upper 13 Hudson River Valley is similarly vague regarding the nature of findspots and their environmental 14 settings. Most appear to have been collected from agricultural plow zones and indicate a 15 temporary occupation, such as a hunting camp.

16 Excavated sites are consistently small and indicative of extremely short-term utilization. Of 17 particular interest to the lower Hudson is the Port Mobil site, located above the Arthur Kill on 18 Staten Island. Though badly disturbed, the location of the site indicates a strong estuarine 19 orientation, and the lithic materials recovered at the site derive from both eastern New York and 20 eastern Pennsylvanian sources (Ritchie 1994).

21 Archaic Period 22 Generalized hunter-gatherers exploiting large game and a wide variety of fauna, including small 23 mammals and birds, and fish, characterize the Archaic period. The Early and Middle Archaic 24 Periods had long been interpreted as representing a low point in human occupation in the 25 Northeast, but as with the Paleo-Indian period, surface collections have begun to fill in the gap 26 (Levine 1989). Part of the explanation for the increasing density of human occupation of upper 27 New York State may involve the gradual transition from relatively resource-poor coniferous 28 forests to hardwood forests during the course of the period (Salwen 1975). Gradually rising sea 29 levels would have shortened the descent to the Hudson River banks and flooded any number of 30 Early Archaic sites.

31 A study by Brennan noted that Archaic hunting and foraging was centered on two pools or bays, 32 the Tappan Zee, stretching from just north of Yonkers to the Croton River, and Haverstraw Bay, 33 from the Croton River to Bear Mountain. He disagreed, however, with the notion that any of the 34 sites represented long-term, much less permanent, settlements and specialized subsistence.

35 Instead, he suggested that Archaic exploitation of the lower Hudson was only seasonal, as part 36 of a generalized subsistence strategy (Brennan 1977).

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Plant and the Environment 1 Woodland Period 2 The Woodland Period in New York State saw the establishment of horticulture and the 3 development of larger social units, including matriarchal and matrilocal clans, sedentary 4 villages, and tribes. Pottery is gradually introduced, and a much wider variety of material culture 5 comes into use. While minor climate fluctuations took place during this period, the overall 6 environment was very similar to that of today.

7 Early Woodland sites are similar to those of the Late Archaic Period. They are typically small 8 sites, with projectile points, scrapers, and bone tools providing evidence of hunting, fishing, and 9 limited cultivation (Funk 1976). Pottery is found on an increasing number of sites, typically 10 stamped and impressed cooking pots tempered with crushed shell. The wide variety of pottery 11 types found at individual sites, however, points to low levels of interaction between groups.

12 Other new features of the early Woodland Period are burials with elaborate grave goods, 13 including flints and bone tools, shell and copper beads, and stone pendants (Ritchie 1980).

14 By the Middle and Late Woodland Periods, the size and complexity of sites increased 15 tremendously. The key to later developments was the introduction of horticulture and the 16 cultivation of maize (Zea mays), beans (Phaseolus vulgaris), and squash (Cucurbita pepo).

17 Processing of these crops was facilitated by the use of cooking pots and storage pits. Villages 18 were occupied year-round by the end of the period and often comprised multiple long houses 19 positioned on defensible hills and fortified with walls or palisades.

20 European Contact, 1524-1608 21 The Contact Period in the lower Hudson Valley began in 1524, when the Spanish explorer 22 Giovanni de Verrazzano reached New York Harbor in his ship, the Oauphin. After anchoring 23 near Staten Island, he attempted to go ashore in a small boat but was forced to return to his 24 ship because of a sudden storm. Verrazzano then departed quickly and continued up the East 25 Coast. The Spanish continued to exploit the area between the Chesapeake and the Gulf of 26 Maine, primarily as slavers, while French fishermen appear to have frequented the Grand Banks 27 in the 16th century.

28 Historic Period 29 The Colonial Period, 1608-1776 30 The English explorer Henry Hudson undertook two unsuccessful Arctic explorations in search of 31 the Northwest Passage to the Orient in 1608. With the support of the Dutch East Indies 32 Company, Hudson's famous voyage in the Half Moon took place in 1609, whereupon he 33 discovered instead the river that now bears his name. Almost immediately thereafter, Dutch 34 traders in great numbers began flooding into the area, primarily in search of furs. In 1614, the 35 New Netherlands Company was formed and given a charter by the Dutch to exploit the areas 36 between the Connecticut, Mohawk, and Hudson Rivers. In 1614, the Dutch established Fort 37 Nassau on the west bank of the Hudson River at what is now Albany.

38 The island known as Manhattan was, famously, purchased from the Manhattes in 1626, and 39 other areas such as Staten Island, Hoboken, and Nyack were purchased in the succeeding 40 decades (Francis 1997; Kraft 1991). Dutch, Walloon, Huguenot, and even small numbers of 41 Jews began to arrive as refugees and settlers in New Amsterdam, but by 1630, the population 42 was still only around 300. In 1664 an English fleet sailed into the harbor at New Amsterdam, NUREG-1437, Supplement 38 2-136 December 2010 OAG10001367A_00174

Plant and the Environment 1 and after some negotiation, the Dutch capitulated. The English seized the entire colony of New 2 Amsterdam and renamed the area New York and New Jersey.

3 The Revolutionary War, 1776-1783 4 New York and, more specifically, Westchester County were the site of many significant events 5 during the American Revolution. The social and economic structure of the State was still 6 dominated by large landowners, and discontent had already emerged among tenant farmers 7 during the 1750s and 1760s. British troops landed on Staten Island in July 1776 and advanced 8 northward, pressing colonial forces under the command of George Washington to make a 9 strategic retreat north into Westchester County (Griffin 1946). With a large British force 10 advancing, the bulk of American forces in Westchester retreated across the Hudson to New 11 Jersey (Griffin 1946; Countryman 2001). Westchester remained on the front lines until the end 12 of the war. The American defense line stretched from Mamaroneck to Peekskill, with British 13 forces arrayed across southern Westchester County, creating a "neutral ground" in between, 14 across which violence raged. The British gradually captured the bulk of Westchester County by 15 1779 but were unable to press their advantage further (Griffin 1946; Countryman 2001).

16 The Americans slowly pushed the British back from the Hudson Highlands and then 17 Westchester County. In July 1779, General Anthony Wayne and his Corps of Light Infantry 18 conducted a successful assault against a British encampment at Stony Point (now a National 19 Historic Landmark). The modern Stony Point Battlefield in Rockland County is across the 20 Hudson River and south of the IP2 and IP3 site.

21 19th Century Development 22 The economy of Westchester County remained overwhelmingly agricultural during the first half 23 of the 19th century, driving a number of infrastructure improvements. The Croton Turnpike, for 24 example, was organized in 1807 to carry the enormous cattle traffic en route to New York City 25 from Westchester County. Though shipbuilding was a major industry on both the Hudson and 26 Long Island Sound sides of Westchester, regular sloop traffic to Manhattan did not begin until 27 the later 18th century. After 1807, the steamboat revolution, engineered by Robert Livingston 28 and Robert Fulton, opened a new era on the Hudson River.

29 The landscape of New York State and Westchester County was profoundly transformed by land 30 speculation, which opened virtually the entirety of the State for farming, and more gradually by 31 the spread of industry. Copper was mined near Sing-Sing and iron near Port Chester and 32 Irvington, and iron working was established in Peekskill. During the latter part of the 33 19th century, the area just north of the IP2 and IP3 site was surface-mined, and a small lime kiln 34 and blast furnace were operated within or adjacent to the footprint of the current facility 35 (Enercon, 2006). By the end of the 19th century, industrialization was widespread in 36 Westchester County.

37 20th Century Development 38 Land remained the dominant theme for the 20th century in Westchester County, but in a far 39 different sense than during the 19th . The preceding century had seen the landscape 40 transformed through the end of the manorial system and the spread of freehold farming, then by 41 industrialization and transportation networks, and finally by deliberate preservation as New York 42 City's water source. Though the surrounding counties had always been secondary to New York December 2010 2-137 NUREG-1437, Supplement 38 I OAGI0001367A_00175

Plant and the Environment 1 City in terms of population, productivity, and wealth, the 20th century gradually saw decisive 2 political and economic subordination.

3 2.2.9.2 Historic and Archeological Resources at the IP2 & IP3 Site 4 Previously Recorded Resources 5 A Phase 1A Survey (literature review and sensitivity assessment) was conducted in 2006 by 6 Entergy (Enercon, 2006). This survey was primarily a literature review and included only an 7 informal walkover of a portion of the plant site. Areas of potential aboriginal and historical 8 interest were noted; however, no sites were recorded as part of this effort.

9 More recently, Entergy conducted a Phase 1b investigation of potential cooling tower locations 10 onsite as part of ongoing proceedings before the State of New York related to the facility's 11 SPDES permit. This investigation was intended to indicate how potential installation of cooling 12 towers may affect onsite archaeological resources. The potential impacts of cooling tower 13 installation are discussed in Chapter 8 of this SEIS.

14 NYSHPO houses the State's archeological site files and information on historic resources such 15 as buildings and houses, including available information concerning the National or State 16 Register eligibility status of these resources. The NRC cultural resources team visited NYSHPO 17 and conducted a records search for archeological sites located within or near the IP2 and IP3 18 property. The results of this search are detailed below.

19 There are no previously recorded archeological sites within the IP2 and IP3 property. A search 20 for sites within a 1 mi (1.6 km) radius of the plant also revealed no previously recorded sites.

21 The nearest recorded site (A-119-02-0003) is located southwest of the plant, at Verplanck's 22 Point. Site A-119-02-003 is the site of the Revolutionary War era Fort Lafayette. The New York 23 State Historic Trust site inventory form indicates that there is no longer any visible, above 24 ground evidence of the fort; however, the inventory form documents artifacts from the fort site 25 (including cannonballs and uniform buttons) found in the collections of local residents in the mid-26 1970s. The nearest previously recorded prehistoric archaeological site is the "Peekskill Shell 27 Heap" (NYSM 6910). This site is a shell and artifact midden deposit located northeast of the 28 IP2 and IP3 site in the City of Peekskill.

29 A review of the NYSH PO files was conducted to identify aboveground historic resources within 30 5 mi (8 km) of the plant. In Westchester County, 29 resources are listed on the National 31 Register of Historic Places (NRHP) within the 5 mi (8 km) radius. Additionally, there are 32 16 NRHP-listed resources in Rockland County, 19 in Orange County, and 22 in Putnam County 33 within 5 mi (8 km) of the site. The nearest NRHP-listed historic resource to the IP2 and IP3 34 facilities is the Standard House in the City of Peekskill, approximately 2 mi (3.2 km) to the 35 northeast. The Standard House is a three-story Italianate structure built in 1855 and originally 36 used as a boarding house and tavern. As mentioned in Section 2.2.9.1, the Stony Point 37 Battlefield, a National Historic Landmark, is located across the Hudson River and south of IP2 38 and IP3.

39 IP1 began operation in August 1962 and was shut down in October 1974 and placed in 40 SAFSTOR with intent for decommissioning at a later date. The plant was one of three 41 "demonstration plants" that began operation in the early 1960s and is representative of the 42 earliest era of commercial reactors to operate in the United States. To date, no formal 43 significance or eligibility evaluation has been conducted for IP1.

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Plant and the Environment 1 Results of Walkover Survey 2 The NRC staff performed an informal walkover survey of the IP2 and IP3 property during the 3 environmental site audit, including portions of the power block area and portions of the former 4 Lent's Cove Park (wooded area north of the power block area). During this walkover, it was 5 observed that the power block area has been extensively disturbed and graded. The NRC staff 6 walked a meandering path through the wooded area north of the plant and along a portion of the 7 shoreline of Lent's Cove.

8 The NRC cultural resources team observed evidence of prehistoric use of this area in two 9 locations along the walkover route. The NRC staff observed two pieces of chert debitage near a 10 stream in the western portion of the wooded area, and a Woodland Period, Meadowood Phase, 11 projectile point was observed near the shoreline along Lent's Cove. Historic Period use of this 12 area was also observed in the form of an apparent stone house foundation and scattered 13 historic era trash piles.

14 Evidence of mining (Enercon 2006) was confirmed in the western portion of the wooded area.

15 Manmade holes of varying size and piles of spoil material were observed by the NRC staff along 16 the route of the walkover in this portion of the property.

17 The NRC staff observed a concrete stairway and retaining wall (remnants of an early 18 20th century park) south of the main power block area. These appear to be the only remaining 19 features of the former Indian Point Park, a popular recreation area from 1923 to 1956 (Enercon 20 2006).

21 Potential Archeological Resources 22 As the result of disturbances associated with site preparation and construction, the main 23 generating station areas at IP2 and IP3 have little or no potential for archeological resources.

24 There is potential for archeological resources to be present in the wooded area north of the 25 main generating station areas, and the historic period mining features in this area represent a 26 potentially significant resource. The portion of the property south and east of the power block 27 area, which contains a variety of ancillary plant facilities, has been disturbed by construction 28 activities over the course of the plant's history. It is possible, however, that portions of that area 29 not disturbed by construction activities may contain intact subsurface archeological deposits.

30 The 2009 Phase 1b investigation for potential cooling tower installation identified numerous 31 historic resources south of IP3, in and around the potential location of the southernmost of two 32 proposed cooling towers. The survey also identified some prehistoric resources at two south 33 tower survey locations. Prehistoric artifacts included stone flakes and shatter, as well as quartz 34 shatter. Historic resources include indications of a smelter that once operated onsite as well as 35 concrete pads or caps, a fence, and other expected indications of historic site usage. Some 36 resources, including the concrete stairway and retaining wall from the former Indian Point Park 37 would require evaluation, should any construction activity be planned for that area of the facility.

38 2.2.10 Related Federal Project Activities and Consultations 39 During the preparation of the IP2 and IP3 ER, Entergy did not identify any known or reasonably 40 foreseeable Federal projects or other activities that could contribute to the cumulative 41 environmental impacts of license renewal at the site (Entergy 2006a).

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Plant and the Environment 1 The NRC staff reviewed the possibility that activities of other Federal agencies might affect the 2 renewal of the operating licenses for IP2 and IP3. The presence of any such activity could 3 result in cumulative environmental impacts and the possible need for a Federal agency to 4 become a cooperating agency in the preparation of the SEIS.

5 The NRC staff identified several current Federal projects occurring near IP2 and IP3. The NRC 6 staff has determined that none of these Federal projects would result in impacts to the IP2 and 7 IP3 license renewal review that would make it desirable for another Federal agency to become 8 a cooperating agency in the preparation of this SEIS.

9 The NRC is required under Section 102(c) of NEPA to consult with and obtain the comments of 10 any Federal agency that has jurisdiction by law or special expertise with respect to any 11 environmental impact involved. Federal agency comment correspondence is included in 12 Appendix E.

13 New York/New Jersey/Philadelphia Airspace Redesign 14 The Federal Aviation Administration (FAA) is proposing to redesign the airspace in the New 15 York/New Jersey/Philadelphia (NY/NJ/PHL) Metropolitan Area. This redesign was conceived as 16 a system for more efficiently directing Instrument Flight Rule aircraft to and from five major 17 airports in the NY/NJ/PHL Metropolitan Area, including John F. Kennedy International Airport 18 and LaGuardia Airport in New York, Newark Liberty International Airport and Teterboro Airport 19 in New Jersey, and Philadelphia International Airport in Pennsylvania. All of these airports are 20 south of the IP2 and IP3 facility with the closest being the Teterboro Airport which is about 30 mi 21 away. The redesign project also included 16 satellite airports in the study area. Of these 22 satellite airports, the White Plains/Westchester County Airport, located about 24 mi south-23 southeast of the IP2 and IP3 facility, and Stewart International Airport, located about 25 mi 24 north, are the closest to the facility.

25 FAA, in cooperation with DOT, prepared an EIS to evaluate the environmental effects of the 26 NY/NJ/PHL Metropolitan Area Airspace Redesign in accordance with NEPA (DOT/FAA 2007).

27 The proposed action for this EIS is to redesign the airspace in the NY/NJ/PHL metropolitan 28 area. This involves developing new routes and procedures to take advantage of improved 29 aircraft performance and emerging air traffic control technologies. The final EIS identified that 30 potential significant impacts exist in the categories Noise/Compatible Land Use and 31 Socioeconomic Impacts/Environmental Justice (DOT/FAA 2007). The greatest potential impact 32 of the proposed action and preferred alternative is changes in the noise levels in the airspace 33 redesign area.

34 The EIS provides detailed descriptions of the proposed noise mitigation procedures identified for 35 the preferred alternative mitigation package. The EIS studied regions of the Appalachian Trail 36 which lie north of the IP2 and IP3 facility. The trail crosses the Hudson River about 4 mi north of 37 the facility near Bear Mountain. In this area, the EIS mitigated preferred alternative for 2011 38 would result in an average of 512.4 daily air jet operations in the region (DOT/FAA 2007). The 39 no action alternative for 2011 air traffic would result in an average of 268.1 daily air jet 40 operations (DOT/FAA 2007). The mitigated preferred alternative would, therefore, result in a 41 more than 90-percent increase in air traffic in the region immediately north and northwest of the 42 facility. The formal Record of Decision (ROD) for the airspace redesign study which supports 43 the FAA's mitigated preferred alternative was issued in September 2007 (FAA 2007).

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Plant and the Environment 1 Hudson River PCBs Site 2 The EPA Hudson River Polychlorinated Biphenyls (PCBs) Site encompasses a nearly 200 mi 3 stretch of the Hudson River in eastern New York State from Hudson Falls, New York, to the 4 Battery in New York City and includes communities in 14 New York counties and 2 counties in 5 New Jersey (EPA 2008c). The EPA ROD for the Hudson River PCBs Superfund Site 6 addresses the risks to people and ecological receptors associated with PCBs in the in-place 7 sediments of the Upper Hudson River. The February 2002 ROD calls for targeted 8 environmental dredging and removal of approximately 2.65 million cubic yards of PCB-9 contaminated sediment from a 40-mi stretch of the Upper Hudson. In the ROD, EPA selected a 10 plan that addresses the risks to people and the environment associated with PCBs in the 11 sediments of the Upper Hudson River. The actions in the Upper Hudson will lower the risks to 12 people, fish, and wildlife in the Lower Hudson (EPA 2008c).

13 On January 25,2008, EPA completed the final step in the approval process for the design of 14 Phase 1 of the Hudson River PCBs Site dredging program (EPA 2008c). Phase 1 15 encompasses the construction of facilities necessary to process and transport sediments to be 16 dredged from the river, as well as the first year of the dredging program and the habitat 17 replacement and reconstruction program for those areas dredged during Phase 1. Phase 2 will 18 consist of dredging the first three sections of the Upper Hudson River (north of the Federal Dam 19 at Troy, New York) (EPA 2008d).

20 Phase 1 of the project was completed in October 2009, and resulted in the removal of 293,000 21 cubic yards of PCB-contaminated sediment from the river. While this volume exceeded 22 established goals for Phase 1, removal was completed for only 10 of 18 targeted areas due to 23 the presence of contamination in some areas that was deeper than expected, and the presence 24 of woody debris and PCB oil in the sediment that complicated the removal effort. Phase 2 of the 25 project will begin with removal actions at areas that were not completed under Phase 1 (EPA 26 2009).

27 U.S. Army Corps of Engineers Hudson River Federal Navigation Project 28 The U.S. Army Corps of Engineers (USACE), New York District, prepared an EIS addressing 29 the effects of the Hudson River Federal Navigation Project in 1983. Environmental 30 assessments updating the EIS were prepared by the USACE New York District for various 31 maintenance dredging projects since the mid-1980s. USACE determined that the maintenance 32 dredging for the Hudson River Federal Navigation Project, with placement of dredged material 33 on the federally owned upland placement site on Houghtaling Island, has no significant adverse 34 environmental impacts on water quality, marine resources, fish, wildlife, recreation, aesthetics, 35 and flood protection (USACE 2006).

36 Coastal Zone Management Act 37 In the United States, coastal areas are managed through the Coastal Zone Management Act of 38 1972 (CZMA). The Act, administered by the NOAA Office of Ocean and Coastal Resource 39 Management, provides for management of the nation's coastal resources, including the Great 40 Lakes, and balances economic development with environmental conservation. The Federal 41 Consistency Regulations implemented by NOAA are contained in 15 CFR Part 930.

42 This law authorizes individual states to develop plans that incorporate the strategies and 43 policies they will employ to manage development and use of coastal land and water areas. Each December 2010 2-141 NUREG-1437, Supplement 38 OAGI0001367A_00179

Plant and the Environment 1 plan must be approved by NOAA. One of the components of an approved plan is "enforceable 2 polices," by which a state exerts control over coastal uses and resources.

3 The New York Coastal Management Program was approved by NOAA in 1982. The lead 4 agency is the Division of Coastal Resources within the Department of State. The lead agency 5 implements and supervises all the various Coastal Zone Management programs in the state.

6 New York's coastal zone includes coastal counties on Long Island as well as Westchester 7 County, the boroughs of New York City, counties along the Hudson River up the Federal Dam at 8 Troy, and counties along the Great Lakes (NOAA 2007). Federal Consistency requires "federal 9 actions, occurring inside a state's coastal zone, that have a reasonable potential to affect the 10 coastal resources or uses of that state's coastal zone, to be consistent with that state's 11 enforceable coastal policies, to the maximum extent practicable."

12 IP2 and IP3 are located in Westchester County, within the State's Coastal Zone, specifically in 13 the Peekskill South region of the Hudson River (NYSDOS undated). The IP2 and IP3 site is 14 adjacent to a Significant Coastal Fish and Wildlife Habitat (Haverstraw Bay), and south of the 15 Hudson Highlands Scenic Area of Statewide Significance (NYSDOS undated). Based on IP2 16 and IP3's location within the State's Coastal Zone, license renewal of IP2 and IP3 will require a 17 State coastal consistency certification.

18 2.3 References 19 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for 20 Protection Against Radiation."

21 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of 22 Production and Utilization Facilities."

23 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 24 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

25 10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, "Reactor Site 26 Criteria."

27 40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 28 "Environmental Radiation Protection Requirements for Normal Operations of Activities in the 29 Uranium Fuel Cycle."

30 40 CFR Part 261. Code of Federal Regulations, Title 40, Protection of Environment, Part 261, 31 "Identification and Listing of Hazardous Waste."

32 40 CFR Part 264. Code of Federal Regulations, Title 40, Protection of Environment, Part 264, 33 "Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal 34 Facilities."

35 40 CFR Part 273. Code of Federal Regulations, Title 40, Protection of Environment, Part 273, 36 "Standards for Universal Waste Management."

37 32 FR 4001. U.S. Department of the Interior. "Native Fish and Wildlife: Endangered Species."

38 March 11, 1967.

I NUREG-1437, Supplement 38 2-142 December 2010 OAGI0001367A_00180

Plant and the Environment 1 41 FR 41914. U.S. Fish and Wildlife Service. "Endangered and Threatened Wildlife and Plants:

2 Determination of Critical Habitat for American Crocodile, California Condor, Indiana Bat, and 3 Florida Manatee." September 24, 1976.

4 69 FR 39395. U.S. Fish and Wildlife Service. "Endangered and Threatened Wildlife and Plants; 5 90-Day Finding on a Petition to List the New England Cottontail as Threatened or Endangered."

6 June 30, 2004.

7 71 FR 61022. National Marine Fisheries Services. "Endangered and Threatened Species; 8 Revision of Species of Concern List, Candidate Species Definition, and Candidate Species List."

9 October 17, 2006.

10 72 FR 37346. U.S. Fish and Wildlife Service. "Endangered and Threatened Wildlife and Plants:

11 Removing the Bald Eagle in the Lower 48 States from the List of Endangered and Threatened 12 Wildlife." Final rule. July 9,2007.

13 72 FR 69033. U.S. Fish and Wildlife Service. "Review of Native Species That Are Candidates 14 or Proposed for Listing as Endangered or Threatened; Annual Notice of Findings on 15 Resubmitted Petitions; Annual Description of Progress on Listing Actions." Proposed Rule.

16 December 12,2007.

17 6 New York Codes, Rules, and Regulations (NYCRR) Subpart B. Title 6 of the Official 18 Compilation of New York Codes, Rules and Regulations, Subpart B, "Solid Waste."

19 16 U.S.C. Section 668aa(c). "Endangered Species Preservation Act." October 15.

20 16 U.S.C. Section 1531 to 1544. "Endangered Species Act of 1973" (16 U.S.C. 1531-1544,87 21 Stat. 884), as amended. Public Law 93-205, approved December 28, 1973.

22 16 U.S.C. Section 5151 to 5158. "Atlantic Striped Bass Conservation Act" (16 U.S.C. 5151-23 1544,98 Stat. 3187). Public Law 98-613, approved 1984.

24 Abood, K.A., T.L. Englert, S.G. Metzger, C.V. Beckers, Jr., T.J. Groninger, and S. Mallavaram.

25 2006. "Current and Evolving Physical and Chemical Conditions in the Hudson River Estuary."

26 American Fisheries Society Symposium 51, pp. 39--61.

27 Achman, D.R., B.J. Brownawell, and L. Zhang. 1996. "Exchange of Polychlorinated Biphenyls 28 Between Sediment and Water in the Hudson River Estuary." Estuaries 19:4, pp. 950-965.

29 ASA (ASA Analysis and Communication). 2007. 2005 Year Class Report for the Hudson River 30 Estuary Monitoring Program. Prepared on behalf of Dynergy Roseton LLC, Entergy Nuclear 31 Indian Point 2 LLC, Entergy Nuclear Indian Point 3 LLC, and Mirant Bowline LLC. January 32 2007. ADAMS No. ML073331067.

33 Ashizawa, D., and J.J. Cole. 1994. "Long-Term Temperature Trends of the Hudson River: A 34 Study of the Historical Data." Estuaries 17:18, pp. 166-171.

35 ASSRT (Atlantic Sturgeon Status Review Team). 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. Accessed at 38 http://www.nmfs.noaa.gov/pr/pdfs/statusreviews/atlanticsturgeon2007.pdf on December 7, 39 2007.

December 2010 2-143 NUREG-1437, Supplement 38 I OAGI0001367A_00181

Plant and the Environment 1 Atlantic States Marine Fisheries Commission (ASMFC). 1998. "American Shad Stock 2 Assessment: Peer Review Report." March 1998. Washington, DC. Accessed at 3 http://www.asmfc.org/speciesDocuments/shad/stockassmtreports/shadstockassmtreport.PDF 4 on January 21,2008.

5 Atlantic States Marine Fisheries Commission (ASMFC). 2004. "Status of the Blue Crab 6 (Callinectes sapid us) on the Atlantic Coast." Special Report No. 80.

7 Atlantic States Marine Fisheries Commission (ASMFC). 2006a. "2006 Stock Assessment 8 Report for Atlantic Menhaden." Atlantic Menhaden Technical Committee. September 26, 2006.

9 Accessed at 10 http://www .asmfc. org/species Documents/menhaden/reports/stockAssessm ents/2006StockAsse 11 ssmentReport. pdf?bcsi_scan_ 513F405096A035F7=0&bcsi_ scan_filename=2006StockAssessm 12 entReport.pdf on February 5, 2008.

13 Atlantic States Marine Fisheries Commission (ASMFC). 2006b. "Species profile: Atlantic 14 striped bass, the challenges of managing a restored stock." Accessed at 15 http://www.asmfc.org/speciesDocuments/stripedBass/speciesprofile.pdf on December 10, 2007.

16 ADAMS No. ML083360698.

17 Atlantic States Marine Fisheries Commission (ASMFC). "2006c Weakfish Stock Assessment 18 Report." December 2006. Accessed at 19 http://www.asmfc.org/speciesDocuments/weakfish/stockassessmentreports/2006WeakfishStock 20 Assessment. pdf?bcsi_scan_B666A 1DE717DB577=0&bcsi_scan_filename=2006WeakfishStock 21 Assessment.pdf on February 13, 2008.

22 Atlantic States Marine Fisheries Commission (ASMFC). 2007a. "American Shad Stock 23 Assessment Report for Peer Review." Stock Assessment Report No. 07-01 (Supplement) of the 24 Atlantic States Marine Fisheries Commission. August 16, 2007. Accessed at 25 http://www.asmfc.org/speciesDocuments/shad/stockassmtreports/2007ShadStockAssmtReport 26 Volumel.pdf on January 21,2008.

27 Atlantic States Marine Fisheries Commission (ASMFC). 2007b. "Species Profile: Weakfish-28 The Challenge of Managing a Stock Decline When Fishing is Not the Cause." ASMFC 29 Fisheries Focus, Vol. 16, Issue 4: May/June 2007. Accessed at 30 http://www.asmfc.org/speciesDocuments/weakfish/weakfishProfile.pdf on February 17, 2008.

31 Atlantic States Marine Fisheries Commission (ASMFC). 2007c. "Species Profile: Atlantic 32 Sturgeon, Ancient Species' Slow Road to Recovery." Accessed at 33 http://www.asmfc.org/speciesDocuments/sturgeon/sturgeonProfile.pdf on December 6,2007.

34 Bain, M.B., N. Haley, D.L. Peterson, K.K. Arend, K.E. Mills, and P.J. Sullivan. 2007. "Recovery 35 of a U.S. Endangered Fish." PLoS ONE 2(1): e168. Department of Natural Resources, Cornell 36 University, Ithaca, New York. Accessed at 37 http://www.plosone.org/article/info%3Adoi%2F1 0.1371 %2Fjournal.pone.0000168#s3 on 38 December 11, 2007.

39 Barnthouse, L.W., and W. Van Winkle. 1988. "Analysis of Impingement Impacts on Hudson 40 River Fish Populations." American Fisheries Society Monograph 4, pp. 182-190.

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Plant and the Environment 1 Berggren, T.J., and J.T. Lieberman. 1978. "Relative Contribution of Hudson, Chesapeake, and 2 Roanoke Striped Bass, Morone saxatilis, Stocks to the Atlantic Coast Fishery." U.S. National 3 Marine Fisheries Service Fishery Bulletin 76, pp. 335-345.

4 Bigelow, H.B., and W.C. Schroeder. 1953. Fishes of the Gulf of Maine. Fishery Bulletin 74, 5 Fishery Bulletin of the Fish and Wildlife Service, Volume 53, Contribution No. 592, Woods Hole 6 Oceanographic Institution. U.S. Government Printing Office. Accessed at 7 http://www.gma.org/fogm on January 21, 2008.

8 Blumberg, AF., and F.L. Hellweger. 2006. "Hydrodynamics of the Hudson River Estuary."

9 American Fisheries Society Symposium 51, pp. 9-28.

10 Boreman, J., and C.P. Goodyear. 1988. "Estimates of Entrainment Mortality for Striped Bass 11 and Other Fish Species Inhabiting the Hudson River Estuary." American Fisheries Society 12 Monograph 4, pp. 152-160.

13 Brennan, L.A 1977. "The Lower Hudson: The Archaic." In Amerinds and their 14 Paleoenvironments in Northeastern North America. pp. 411-430. Edited by Walter S. Newman 15 and Bert Salwen. New York Academy of Sciences, NY.

16 Britton, N.L., and A Brown. 1913. An Illustrated Flora of the Northern United States, Canada 17 and the British Possessions. Volume II. Second edition, revised and enlarged. Charles 18 Scribner's Sons, New York.

19 Brosnan, T.M., and M.L. O'Shea. 1996. "Long-term Improvements in Water Quality Due to 20 Sewage Abatement in the Lower Hudson River." Estuaries 19:4, pp. 890-900.

21 Buckley, J.L. 1989. "Species Profiles: Life Histories and Environment; Requirements of Coastal 22 Fishes and Invertebrates (North Atlantic)-Rainbow Smelt." U.S. Fish and Wildlife Service 23 Biological Report 82(11.106), U.S. Army Corps of Engineers, TR EL-82-4. 11 pp. Accessed at 24 http://www.nwrc.usgs.gov/wdb/pub/species_profiles/82_11-106.pdf on March 13,2008.

25 Caraco, N.F., J.J. Cole, P.A Raymond, D.L. Strayer, M.L. Pace, S.E.G. Findlay, and D.T.

26 Fisher. 1997. "Zebra Mussel Invasion in a Large, Turbid River: Phytoplankton Response to 27 Increased Grazing." Ecology 78, pp. 588-602.

28 Caraco, N.F., J.J. Cole. S.E.G. Findlay, D.T. Fischer, G.G. Lampman, M.L. Pace, and D.L.

29 Strayer. 2000. "Dissolved Oxygen Declines in the Hudson River Associated with the Invasion 30 of the Zebra Mussel (Dreissena polymorpha)." Environmental Science and Technology 34, pp.

31 1204-1210.

32 Caraco, N.F., and J.J. Cole. 2006. "Hydrologic Control of External Carbon Loads and Primary 33 Production in the Tidal Freshwater Hudson." American Fisheries Society Symposium 51, pp.

34 63-74.

35 Center for Plant Conservation (CPC). 2008. "National Collection of Endangered Plants-Plant 36 Profiles." Accessed at http://www.centerforplantconservation.org/ASP/CPC_NCList_Alpha.asp 37 on March 12,2008. ADAMS No. ML083390228.

38 Chesapeake Bay Program. 2006. "White Perch." Accessed at 39 http://www.chesapeakebay.net/white_perch.htm on January 11,2008. ADAMS No.

40 ML083390252.

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Plant and the Environment 1 CHGEC (Central Hudson Gas and Electric Corporation). 1999. "Draft Environmental Impact 2 Statement for State Pollutant Discharge Elimination System Permits for Bowline Point, Indian 3 Point 2 and 3, and Roseton Steam Electric Generating Stations." Consolidated Edison 4 Company New York, Inc. New York Power Authority and Southern Energy New York.

5 December 1999. ADAMS Accession No. ML083400128.

6 Christensen, S.W., and T.L. Englert. 1988. "Historical Development of Entrainment Models for 7 Hudson River Striped Bass." American Fisheries Society Monograph 4, 133-142.

8 Collette, B.B., and G. Klein-MacPhee (eds.). 2002. Bigelow and Schroeder's Fishes of the Gulf 9 of Maine (3rd Ed.). 748 pp. Smithsonian Institute Press, Herndon, VA.

10 Conant, R., and J.T. Collins. 1998. A Field Guide to Reptiles and Amphibians, Eastern and 11 Central North America. Third edition, expanded. Houghton Mifflin Co., Boston.

12 Cortlandt Consolidated Water District (CCWD). 2006. "Annual Water Supply Statement," p. 1.

13 Accessed at www.townofcortlandt.com on July 15, 2006. ADAMS No. ML083390256.

14 Countryman, E. 2001. "From Revolution to Statehood (1776-1825)." In The Empire State: A 15 History of New York, p. 237. Edited by Milton M. Klein. Cornell University Press, Ithaca, NY.

16 Dadswell, M.J., B.D. Taubert, T.S. Squiers, D. Marchette, and J. Buckley. 1984. "Synopsis of 17 Biological Data on Shortnose Sturgeon, Acipenser brevi rostrum LeSueur 1818". NOAA 18 Technical Report NMFS-14, FAO Fisheries Synopsis No. 140,45 pp. Accessed at 19 http://www. nmfs. noaa. gov/pr/pdfs/species/shortnosesturgeon_biological_data. pdf on December 20 11,2007.

21 Daniels, R.A., K.E. Limburg, R.E. Schmidt, D.L. Strayer, and R.C. Chambers. 2005. "Changes 22 in Fish Assemblages in the Tidal Hudson River, New York." American Fisheries Society 23 Symposium 45: pp.471-503. Accessed at 24 http://www.ecostudies.org/reprints/daniels_et_al_2005.pdf on March 13, 2008.

25 Deason, E.E. 1982. "Mnemiopsis leidyi (Ctenophora) in Narragansett Bay, 1975-1979:

26 Abundance, Size, Composition, and Estimation of Grazing." Estuarine, Coastal and Shelf 27 Science 15(2), pp. 121-134.

28 Department of Transportation (DOT)/Federal Aviation Administration (FAA). 2007. Final 29 Environmental Impact Statement, New York/New Jersey/Philadelphia Metropolitan Area 30 Airspace Redesign. July 2007.

31 Derrick, P.A., and V.S. Kennedy. 1997. "Prey Selection by the Hogchoker, Trinectes maculates 32 (Pisces: Soleidae), Along Summer Salinity Gradients in Chesapeake Bay, USA." Marine 33 Biology 129(4), pp. 699-711.

34 Dew, C.B., and J.H. Hecht. 1994. "Hatching, Estuarine Transport, and Distribution of Larval 35 and Early Juvenile Atlantic Tomcod, Microgadus tomcod, in the Hudson River." Estuaries, Vol.

36 17, No.2, pp. 472-488. Accessed at 37 http://estuariesandcoasts.org/cdrom/ESTU1994_17_2_472_488. pdf on December 11, 2007.

38 (Agencywide Documents Access and Management System (ADAMS) Accession No.

39 ML073460164) 40 Dovel, W.L., J.A. Mihursky, and A.J. McErlean. 1969. "Life History Aspects of the Hogchoker, 41 Trinectes maculatus, in the Patuxent River Estuary, Maryland." Chesapeake Science 10(2), pp.

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Plant and the Environment 1 104-119. Accessed at http://estuariesandcoasts.org/cdrom/CPSC1969_10_2_104_119.pdf on 2 February 18, 2008.

3 Dunn, J.L., and J. Alderfer (eds.). 2006. National Geographic Field Guide to the Birds of North 4 America. Fifth Edition. National Geographic, Washington, DC.

5 Dunning, D.J., Q.E. Ross, M.T. Mattson, and D.G. Heimbuch. 2006a. "Distribution and 6 Abundance of Bay Anchovy Eggs and Larvae in the Hudson River and Nearby Waterways."

7 American Fisheries Society Symposium 51, pp. 215-226.

8 Dunning, D.J., J.R. Waldman, Q.E. Ross, and M.T. Mattson. 2006b. "Dispersal of Age-2+

9 Striped Bass Out of the Hudson River." American Fisheries Society Symposium 51, pp. 287-10 294.

11 Dutchess County Department of Planning and Development-Greenway Connections Report.

12 2006. Dutchess County New York. Accessed at 13 http://www.co.dutchess.ny.us/EnvironmentLandPres/ELPgreenwayguide.htm on June 30,2006.

14 Enercon Services, Inc. (Enercon). 2003. "Economic and Environmental Impacts Associated 15 with Conversion of Indian Point Units 2 and 3 to a Closed-Loop Condenser Cooling Water 16 Configuration."

17 Enercon Services, Inc. (Enercon). 2006. "Phase 1A Literature Review and Archaeological 18 Sensitivity Assessment of the Indian Point Site, Westchester County, New York." Tulsa, OK.

19 Entergy Nuclear Northeast (ENN). 2007a. "Indian Point 2, Offsite Dose Calculation Manual 20 (ODCM), Part II-Calculation Methodology." Revision 11, Table 2-9.

21 Entergy Nuclear Northeast (ENN). 2007b. "Indian Point Site Audit Information Needs" (Letter 22 from Fred R. Dacimo, Indian Point Energy Center to the U.S. Nuclear Regulatory Commission).

23 Buchanan, NY. November 14, 2007. (ADAMS Accession No. ML073330590) 24 Entergy Nuclear Northeast (ENN). 2007c. "Supplement to License Renewal Application (LRA) 25 Environmental Report References." November 14,2007. (ADAMS Accession No.

26 M L073330590) 27 Entergy Nuclear Operations Inc. (Entergy). 2003a. "Indian Point Units 1 and 2-Annual 28 Effluent and Waste Disposal Report." Docket Numbers 50-3 and 50-247, Buchanan, NY.

29 (ADAMS Accession No. ML031220099) 30 Entergy Nuclear Operations Inc. (Entergy). 2003b. "Indian Point Unit 3-Annual Radioactive 31 Effluent Release Report." Docket Number 50-286, Buchanan, NY. (ADAMS Accession No.

32 ML031220024) 33 Entergy Nuclear Operations Inc. (Entergy). 2004. "Indian Point Units 1,2, and 3-2003 Annual 34 Effluent and Waste Disposal Report." Docket Numbers 50-3, 50-247, and 50-286, Buchanan, 35 NY. (ADAMS Accession No. ML041250522) 36 Entergy Nuclear Operations Inc. (Entergy). 2005a. "Indian Point Units 1,2, and 3-2004 37 Radioactive Effluent Release Report." Docket Numbers 50-3, 50-247, and 50-286, Buchanan, 38 NY. (ADAMS Accession No. ML051180211) 39 Entergy Nuclear Operations, Inc. (Entergy). 2005b. "Indian Point Energy Center, Indian Point 40 3, Updated Final Safety Analysis Report," Revision 01.

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Plant and the Environment 1 Entergy Nuclear Operations, Inc. (Entergy). 2006a. "Indian Point 2 UFSAR," Revision 20.

2 Entergy Nuclear Operations Inc. (Entergy). 2006b. "Indian Point Units 1,2, and 3-2005 3 Annual Radioactive Effluent Release Report." Docket Numbers 50-3,50-247, and 50-286, 4 Buchanan, NY. (ADAMS Accession No. ML061240373) 5 Entergy Nuclear Operations, Inc. (Entergy). 2006c. "Abundance and Stock Characteristics of 6 the Atlantic Tomcod Spawning Population in the Hudson River, Winter 2003-2004." Prepared 7 by Normandeau Associates, Inc., Document R-19900.000. December 2006. ADAMS No.

8 ML073511572.

9 Entergy Nuclear Operations Inc. (Entergy). 2006d. "Indian Point, Units 1,2 and 3-Annual 10 Radiological Environmental Operating Report for 2005." Docket Numbers 50-3,50-247, and 50 11 286, Buchanan, NY. (ADAMS Accession No. ML061290085) 12 Entergy Nuclear Operations, Inc. (Entergy). 2007a. "Applicant's Environmental Report, 13 Operating License Renewal Stage." (Appendix E of "Indian Point, Units 2 & 3, License Renewal 14 Application.") April 23, 2007. (ADAMS Accession No. ML071210530) 15 Entergy Nuclear Operations, Inc. (Entergy). 2007b. "Indian Point, Units 2 & 3, License 16 Renewal Application." April 23, 2007. (ADAMS Accession No. ML071210512) 17 Entergy Nuclear Operations Inc. (Entergy). 2007c. "Indian Point Units 1, 2, and 3-2006 18 Annual Radioactive Effluent Release Report." Docket Numbers 50-3,50-247, and 50-286, 19 Buchanan, NY. (ADAMS Accession No. ML071230305) 20 Entergy Nuclear Operations Inc. (Entergy). 2007d. "Indian Point, Units 1,2, and 3-Annual 21 Radiological Environmental Operating Report for 2006." Docket Numbers 50-3,50-247, and 50 22 286, Buchanan, NY. (ADAMS Accession No. ML071420088) 23 Entergy Nuclear Operations Inc. (Entergy). 2008. "Dry Cask Storage Information Sheet" 24 (http://www.entergy-nuclear.com/contentiResource_Library/dry_cask! Dry_Cask_Storage_info_

25 sheet. pdf). Accessed at http://www.entergy-nuclear.com/resource_library/IPEC.aspx on June 26 26,2008. ADAMS No. ML083390262.

27 Entergy Nuclear Operations Inc. (Entergy). 2010a. "2009 Annual Radioactive Effluent Release 28 Report." Indian Point Units 1,2 & 3; Docket Nos.50-003, 50-247, and 50-286; License Nos.

29 DPR-5, DPR-26, DPR-64. Buchanan, NY. (ADAMS Accession No. ML101240989) 30 Entergy Nuclear Operations Inc. (Entergy). 2010b. "Indian Point Nuclear Power Plants Units 1, 31 2, and 3-Annual Radiological Environmental Operating Report for 2009." Indian Point Units 1, 32 2 and 3; Docket Nos.50-003, 50-247, and 50-286; License Nos. DPR-5, DPR-26, DPR-64; 33 Buchanan, NY. (ADAMS Accession No. ML101390564) 34 Environmental Protection Agency (EPA). 2004. "Total Maximum Daily Loads, Listed Water 35 Information, Cycle: 2004. Hudson River, Lower Hudson River." Accessed at 36 http://oaspub.epa.gov/tmdl/enviro.control?pJisUd=NY-1301-0002&p_cycle=2004 on February 37 23,2008.

38 Environmental Protection Agency (EPA). 2006a. "Green Book." Accessed at 39 http://www.epa.gov/air/oaqps/greenbk!ancl.htmlon August 10, 2007. ADAMS No.ML083390099 I NUREG-1437, Supplement 38 2-148 December 2010 OAGI0001367A_00186

Plant and the Environment 1 Environmental Protection Agency (EPA). 2006b. "Safe Drinking Water Information System 2 (SDWIS) Database." Accessed at http://oaspub.epa.gov on January 24, 2006. ADAMS No.

3 ML083390264.

4 Environmental Protection Agency (EPA). 2007a. "Level III Ecoregions of the Conterminous 5 United States." Western Ecology Division. Accessed at 6 http://www.epa.gov/wed/pages/ecoregions/leveUii.htm on March 11,2008. ADAMS No.

7 M L083390482 8 Environmental Protection Agency (EPA). 2007b. "Nanotechnology White Paper." EPA 100/B-9 07/001, February 2007. Science Policy Council, Washington, D.C. Accessed at 10 http://www .epa. govlosa/pdfs/nanotech/epa- nanotechnology-whitepaper-11 0207. pdf?bcsi_ scan_A3171404B2C9D30E=0&bcsi_ scan_filename=epa-nanotechnology-12 whitepaper-0207.pdf on December 2,2008.

13 Environmental Protection Agency (EPA). 2008a. "Hudson River PCB Superfund Site, Dredge 14 Area 2 Delineation Fact Sheet, 2008." Accessed at 15 http://www.epa.gov/hudson/factsheet_2nd_phaselow.pdf on February 4,2008. ADAMS No.

16 ML083360712.

17 Environmental Protection Agency (EPA). 2008b. "Local Drinking Water Information, 18 Pennsylvania Drinking Water, Envirofacts Data on Pennsylvania, County Search-Allegheny 19 and Beaver Counties-January 18, 2008." Accessed at 20 http://oaspub.epa.gov/envirolsdw_form_v2.create_page?state_abbr=PA in April 2008. ADAMS 21 No. ML083390266.

22 Environmental Protection Agency (EPA). 2008c. "Hudson River PCBs" Web page. Accessed 23 at http://www.epa.gov/hudson on March 5, 2008. ADAMS No. ML083390040.

24 Environmental Protection Agency (EPA). 2009. "First Phase of Hudson River Dredging Project 25 Complete." Accessed at http:ww.epa.gov/Hudson/ on December 14, 2009.

26 Euston, E.T., S.A Haney, K.A Hattala, and AW. Kahnle. 2006. "Overview of the Hudson 27 River Recreational Fisheries, with an Emphasis on Striped Bass." American Fisheries Society 28 Symposium 51, pp. 295-315.

29 Everly, AW., and J. Boreman. 1999. "Habitat Use and Requirements of Important Fish 30 Species Inhabiting the Hudson River Estuary." National Oceanic and Atmospheric 31 Administration, Technical Memorandum NMFS-NE-121. Accessed at 32 http://www.nefsc.noaa.gov/nefsc/publications/tm/tm121/ on November 29,2007. (ADAMS 33 Accession No. ML073460167) 34 Fabrizio, M.C. 1987. "Contribution of Chesapeake Bay and Hudson River Stocks of Striped 35 Bass to Rhode Island Coastal Waters as Estimated by Isoelectric Focusing of Eye Lens 36 Proteins." Transactions of the American Fisheries Society 116, pp. 588-593.

37 Facey, D.E., and M.J. Van Den Avyle. 1986. "Species Profile: Life Histories and 38 Environmental Requirements of Coastal Fishes and Invertebrates (South Atlantic)-American 39 Shad." U.S. Fish and Wildlife Service BioI. Rep. 82 (11.76). U.S. Army Corps of Engineers, TR 40 EL-82-4. Accessed at 41 http://conserveonline.org/workspaces/atlantic.diadromous.migratory.fish/alosa.sapidissima/Shad 42 %20profile.pdf on December 18,2007.

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Plant and the Environment 1 Fay, C.W., R.J. Neves, and G.B. Pardue. 1983. "Species Profile: Life Histories and 2 Environmental Requirements of Coastal Fishes and Invertebrates (Mid-Atlantic)-

3 Alewife/Blueback Herring." U.S. Fish and Wildlife Service BioI. Rep. 82 (11.45). U.S. Army 4 Corps of Engineers, TR EL-82-4. Accessed at 5 http://www.nwrc.usgs.gov/wdb/pub/species_profiles/82_11-009.pdf on November 29,2007.

6 (ADAMS Accession No. ML073460154) 7 Federal Aviation Administration (FAA). 2007. Press Release: "FAA Issues Final Decision on 8 Airspace Redesign." September 5, 2007. Accessed at 9 http://news.thomasnet.com/companystory/535311 on March 5,2008. ADAMS No.

10 ML083390269.

11 Findlay, S., D. Strayer, M. Bain, and W.C. Nieder. 2006. "Ecology of Hudson River Submerged 12 Aquatic Vegetation." Final Report to the New York State Department of Environmental 13 Conservation. Accessed at http://www.nysl.nysed.gov/scandoclinks/ocm82162378.htm on 14 February 21, 2008.

15 Fish and Wildlife Service (FWS). 2001. "Bog Turtle (Clemmys muhlenbergii), Northern 16 Population, Recovery Plan." Hadley, Massachusetts. 103 pp. Accessed at 17 http://ecos.fws.gov/docs/recovery_plan/010515.pdf on March 4,2008.

18 Fish and Wildlife Service (FWS). 2002. "Threatened and Endangered Species: Indiana Bat 19 (Myotis sodalis)." Accessed at http://www.fws.gov/midwestiEndangered/ on March 4,2008.

20 ADAMS No. ML083390273.

21 Fish and Wildlife Service (FWS). 2004. "Plant Invaders of Mid-Atlantic Natural Areas: Aquatic 22 Plants." U.S. Fish and Wildlife Service Bayscapes Conservation Landscaping Program.

23 October 7,2004. Accessed at http://www.nps.gov/plants/alien/pubs/midatlantic/trna.htm on 24 February 23,2008. ADAMS No. ML083390277.

25 Fish and Wildlife Service (FWS). 2007a. "Indiana Bat (Myotis sodalis) Draft Recovery Plan:

26 First Revision." Fort Snelling, Minnesota. 258 pp. Accessed at 27 http://www.fws.gov/midwestiEndangered/mammals/documents/inba_fnldrftrecpln_apr07.pdf on 28 March 4, 2008.

29 Fish and Wildlife Service (FWS). 2007b. "Species Assessment and Listing Priority Assignment 30 Form, Scientific Name: Sylvilagus transitional is, Common Name: New England Cottontail."

31 April 16, 2007. Accessed at http://ecos.fws.gov/docs/candforms_pdf/r5/A09B_V01.pdf on 32 March 10, 2008.

33 Fish and Wildlife Service (FWS). 2008a. Significant Habitats and Habitat Complexes of the 34 New York Bight Watershed. Lower Hudson River Complex #21. Accessed at 35 http://training.fws.gov/library/pubs5/webJinkitextilow_hud.htm on February 23,2008. ADAMS 36 No. ML083390034.

37 Fish and Wildlife Service (FWS). 2008b. "Westchester County Federally Listed Endangered 38 and Threatened Species and Candidate Species." Accessed at 39 http://www. fws.gov/northeastinyfo/es/CountyLists/WestchesterDec2006. htm on February 26, 40 2008. ADAMS No. ML083390032.

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Plant and the Environment 1 Flora of North America (FNA) Editorial Committee (eds.). 1993+. Flora of North America North 2 of Mexico. 12+ vols. New York and Oxford. Accessed at 3 http://www.efloras.org/flora_page.aspx?florajd=1 on March 11, 2008.

4 Francis, P., Jr. 1997. "The Beads that Did Not Buy Manhattan Island." New York History 78:

5 411-428.

6 Froese, R., and D. Pauly (eds.). 2007a. "Microgadus Tomcod Atlantic Tomcod" on FishBase:

7 World Wide Web Electronic Database. Version (10/2007). Accessed at 8 http://www.fishbase.org/summary/Speciessummary.php?id=316 on November 30,2007.

9 (ADAMS Accession No. ML073460169) 10 Froese, R., and D. Pauly (eds.) 2007b. "Dorosoma cepedianum American Gizzard Shad" on 11 FishBase: World Wide Web Electronic Database. Version (10/2007). Accessed at 12 http://www.fishbase.org/Summary/SpeciesSummary.php?id=1604 on February 6,2008.

13 ADAMS No. ML083390031.

14 Froese, R., and D. Pauly (eds.) 2007c. "Cynoscion regalis Gray Weakfish" on FishBase:

15 World Wide Web Electronic Database. Version (10/2007). Accessed at 16 http://www.fishbase.org/Summary/SpeciesSummary.php?id=406 on February 14, 2008.

17 ADAMS No. ML083390030.

18 Funk, R.E. 1976. Recent Contributions to Hudson Valley Prehistory. ed. Vol. pp.272-275.

19 State University of New York, State Education Department, Albany, NY.

20 Gilbert, C.R. 1989. "Species Profiles: Life Histories and Environmental Requirements of 21 Coastal Fishes and Invertebrates (Mid-Atlantic Bight)-Atlantic and Shortnose Sturgeons." U.S.

22 Fish and Wildlife Service Biological Report 82 (11.122). U.S. Army Corps of Engineers TR 82 4.

23 28 pp.

24 Griffin, E.F. 1946. Westchester County and Its People, A Record. pp.281-294. Lewis 25 Historical Publishing Company, New York.

26 Haas-Castro, R. 2006a. "Status of Fishery Resources off the Northeastern U.S.: River 27 Herring." Northeast Fisheries Science Center Resource Evaluation and Assessment Division, 28 National Oceanic and Atmospheric Administration. Accessed at 29 http://www. nefsc. noaa. gov/sos/spsyn/af/herring/archives/38_RiverHerring_2006. pdf on 30 December 17,2007. ADAMS No. ML083390029.

31 Haas-Castro, R. 2006b. "Status of Fishery Resources off the Northeastern U.S.: American 32 Shad." Northeast Fisheries Science Center Resource Evaluation and Assessment Division, 33 National Oceanic and Atmospheric Administration. Accessed at 34 http://www.nefsc.noaa.gov/sos/spsyn/af/shad/archives/39_AmericanShad_2006.pdf on 35 December 18,2007. ADAMS Accession No. ML083390028.

36 Haddock, S.HD. 2007. "Comparative Feeding Behavior of Planktonic Ctenophores."

37 Integrative and Comparative Biology 47(6), pp. 847-853.

38 Hall, C.A.S. 1977. "Model and the Decision Making Process: The Hudson River Power Plant 39 Case." Ecosystem Modeling in Theory and Practice, pp. 345-364. C.A.S Hall and J.W. Day, 40 Editors. Wiley, New York.

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Plant and the Environment 1 Hartman, K.J., J. Howell, and J.A. Sweka. 2004. "Diet and Daily Ration of Bay Anchovy in the 2 Hudson River, New York." Transactions of the American Fisheries Society 133, pp. 762-771.

3 Hirschberg, D.J., P. Chen, H. Feng, and J.K. Cochran. 1996. "Dynamics of Sediment and 4 Contaminant Transport in the Hudson River Estuary: Evidence from Sediment Distributions of 5 Naturally Occurring Radionnuclides." Estuaries 19:4, pp. 931-949.

6 Howard, R.W. 2001. "The English Province (1664-1776)." In The Empire State: A History of 7 New York, pp. 112-228. Edited by Milton M. Klein. Cornell University Press, Ithaca.

8 Idaho Department of Fish and Game, Bureau of Fisheries (lDFG). 1985. "Proposal for the 9 Introduction of Spottail Shiner (Notropis hudsonius) into Ondeida Narrows Reservoir."

10 November 1985. Accessed at 11 https://research.idfg.idaho.gov/Fisheries%20Research%20Reports/Volume%20087_Article%20 12 07.pdf on March 12, 2008.

13 Indian Point Energy Center. 2004. Meteorological Tower Data, 2000-2004. ADAMS No.

14 M L083390408 15 Indian Point Energy Center. 2005. "Indian Point 3, Updated Final Safety Analysis Report,"

16 Revision 1, Section 2.6.5.

17 Institute of Educational Science (I ES). 2008. U.S. Department of Education. National Center 18 for Educational Statistics. "College Opportunities Online Locator." Accessed at 19 http://nces.ed.gov/ipeds/cool/RefineSearch.aspx in April 2008.

20 Invasive Plant Council of New York State (lPCNYS). 2008. "Water Chestnut-Overview."

21 Accessed at http://www.ipcnys.org/sections/target/water_chestnut_overview.htm on February 22 23,2008.

23 Iverson, L.R., D. Ketzner, and J. Karnes. 1999. Illinois Plant Information Network. Illinois 24 Natural History Survey and USDA Forest Service. Accessed at 25 http://www.fs.fed.us/ne/delaware/ilpin/ilpin.htmlon March 11,2008. ADAMS Accession No.

26 M L083390027.

27 Juanes, F., R.E. Marks, K.A. McKown, and D.O. Conover. 1993. "Predation by Age-O Bluefish 28 on Age-O Anadromous Fishes in the Hudson River Estuary." Transactions of the American 29 Fisheries Society 122, pp. 348-356.

30 Kenney, G. 2002. "Annual Report on the Commercial Monitoring of the Hudson River Blue 31 Crab Fishery." New England Interstate Water Pollution Control Commission and New York 32 State Department of Environmental Conservation. New Paltz, NY.

33 Kentucky State Nature Preserves Commission (KSNPC). 2008. Kentucky Rare Plant 34 Database. Accessed at http://eppcapps.ky.gov/nprareplants/ on March 14,2008. ADAMS 35 Accession No. ML083390026.

36 Klauda, R.J., J.B. McLaren, R.E. Schmidt, and W.P. Dey. 1988. "Life History of White Perch in 37 the Hudson River Estuary." American Fisheries Society Monograph 4,69-88.

38 Koski, R.T. 1978. "Age, Growth, and Maturity of the Hogchoker, Trinectes maculates, in the 39 Hudson River, New York." Transactions of the American Fisheries Society 107(3), pp. 449-40 453.

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Plant and the Environment 1 Kraft, H.C. 1991. "The Indians of the Lower Hudson Valley at the Time of European Contact."

2 In The Archaeology and Ethnohistory of the Lower Hudson Valley and Neighboring Regions:

3 Essays in Honor of Louis A. Brennan. Edited by Herbert C. Kraft. Archaeological Services, 4 Bethlehem, CT.

5 Kynard, B. 1997. "Life History, Latitudinal Patterns, and Status of the Shortnose Sturgeon 6 Acipenser brevi rostrum." Environmental Biology of Fishes 48, pp. 319-334.

7 Lady Bird Johnson Wildflower Center Native Plant Information Network (NPIN). 2008. Native 8 Plant Database. Accessed at http://www.wildflower.org/plants/ on March 14, 2008. ADAMS 9 Accession No. ML083390025.

10 Larson, R.J. 1988. "Feeding and Functional Morphology of the Lobate Ctenophore Mnemiopsis 11 mccradyi." Estuarine, Coastal and Shelf Science 27(5), pp. 495-502.

12 Levine, M.A. 1989. "New Evidence for Postglacial Occupations in the Upper Hudson Valley."

13 Bulletin, Journal of the New York State Archaeological Association 98: 5-12.

14 Levinton, J.S., and J.R. Waldman (eds.). 2006. The Hudson River Estuary. Cambridge 15 University Press, New York.

16 Limburg, K.E. 1996. "Modeling the Ecological Constraints on Growth and Movement of 17 Juvenile American Shad (Alosa sapidissima) in the Hudson River Estuary." Estuaries 19:4, pp.

18 794-813.

19 Lonsdale, D.J., E.M. Cosper, and M. Doall. 1996. "Effects of Zooplankton Grazing on 20 Phytoplankton Size-Structure and Biomass in the Lower Hudson River Estuary." Estuaries 21 19:4, pp. 874-889.

22 Marcy, B.C., D.E. Fletcher, F.D. Martin, M.H. Paller, and M.J.M. Reichert. 2005a. "Spottail 23 Shiner." In: Fishes of the Middle Savannah River Basin. Athens, GA: University of Georgia 24 Press, pp. 153-156.

25 Marcy, B.C., D.E. Fletcher, F.D. Martin, M.H. Paller, and M.J.M. Reichert. 2005b. "White 26 Catfish." In: Fishes of the Middle Savannah River Basin, pp. 212-214. University of Georgia 27 Press, Athens, GA.

28 Maryland Department of Natural Resources (MDNR). 2007a. "Maryland Fish Facts: American 29 Gizzard Shad." Accessed at 30 http://www.dnr.state.md.us/fisheries/fishfacts/americangizzardshad.asp on February 6, 2008.

31 ADAMS Accession No. ML083390023.

32 Maryland Department of Natural Resources (MDNR). 2007b. "White Catfish-Ameiurus catus."

33 Accessed at http://www.dnr.state.md.us/fisheries/fishfacts/whitecatfish.asp on March 13,2008.

34 ADAMS Accession No. ML080730512.

35 McGovern, J.C., and J.E. Olney. 1988. "Potential Predation by Fish and Invertebrates on Early 36 Life History Stages of Striped Bass in the Pamunkey River, Virginia." Transactions of the 37 American Fisheries Society 117, pp. 152-161.

38 McLaren, J.B., T.H. Peck, W.P. Dey, and M. Gardinier. 1988. "Biology of Atlantic Tomcod in 39 the Hudson River Estuary." American Fisheries Society Monograph 4, pp. 102-112.

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Plant and the Environment 1 Menhaden Resource Council (MRC). 2006. "Atlantic Menhaden Biology." Accessed at 2 http://www.menhaden.org/biology.htm on February 4,2008.

3 Mercer, L.P. 1989. "Species Profile: Life Histories and Environmental Requirements of 4 Coastal Fishes and Invertebrates (Mid-Atlantic)-Weakfish." U.S. Fish and Wildlife Service 5 Biological Report 82 (11.109). U.S. Army Corps of Engineers, TR EL-82-4. Accessed at 6 http://www.nwrc.usgs.gov/wdb/pub/species_profiles/82_11-1 09.pdf on February 8, 2008.

7 Miller, B. (Building Inspector). Village of Buchanan. 2006. Phone conversation concerning 8 land development in the Village of Buchanan on January 24, 2006.

9 Miller, D., J. Ladd, and W. Nieder. 2006. "Channel Morphology in the Hudson River Estuary:

10 Historical Changes and Opportunities for Restoration." American Fisheries Society Symposium 11 51, pp. 29-37.

12 Mills, E.L., D.L. Strayer, M.D. Scheuerell, and J.T. Carlton. 1996. "Exotic Species in the 13 Hudson River Basin: A History of Invasions and Introductions." Estuaries 19:4, pp. 814-823.

14 Morris, C. 2001. "Dorosoma cepedianum." Animal Diversity Web. Accessed at 15 http://animaldiversity.ummz.umich.edu/site/accounts/information/Dorosoma_cepedianum.html 16 on February 6,2008.

17 Morton, T. 1989. "Species Profiles: Life Histories and Environmental Requirements of Coastal 18 Fishes and Invertebrates (Mid-Atlantic)-Bay Anchovy." U.S. Fish and Wildlife Service 19 Biological Report 82 (11.97). U.S. Army Corps of Engineers TR EL-82-4 13 pp. Accessed at 20 http://www.nwrc.usgs.gov/wdb/pub/species_profiles/82_11-097.pdf on March 13,2008.

21 National Marine Fisheries Service (NMFS). 2009. Letter from Mary A. Colligan to David J.

22 Wrona on February 24,2009.

23 National Marine Fisheries Service (NMFS). 1998. Recovery Plan for the Shortnose Sturgeon 24 (Acipenser brevirostrum). Prepared by the Shortnose Sturgeon Recovery Team for the National 25 Marine Fisheries Service, Silver Spring, Maryland. 104 pages. Accessed at 26 httg://www.nmfs. noaa.gov/gr/gdfs/recovery/sturgeon shortnose.gdf on November 17, 2010.

27 National Oceanic and Atmospheric Administration (NOAA). 2004. Local Climatological Data-28 Annual Summary with Comparative Data-Binghamton, Albany, and New York City, New York.

29 ISSN 0198-2419, Asheville, NC.

30 National Oceanic and Atmospheric Administration (NOAA). 2007. "Species of Concern:

31 Rainbow Smelt, Osmerus mordax." Updated May 17, 2007. Accessed at 32 http://nmfs.noaa.gov/pr/pdfs/species/rainbowsmelt_detailed.pdf on March 12, 2008.

33 National Oceanic and Atmospheric Administration (NOAA). 2008a. "Hudson River Reserve, 34 New York." National Estuarine Research Reserve System. Accessed at 35 http://www.nerrs.noaa.gov/HudsonRiver/ on February 23,2008.

36 National Oceanic and Atmospheric Administration (NOAA). 2008b. "Pharmaceuticals in the 37 Environment, Information for Assessing Risk." National Centers for Coastal Ocean Science 38 (NCCOS), National Ocean Service. Accessed at http://www.chbr.noaa.gov/peiar on December 39 2,2008.

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Plant and the Environment 1 National Park Service (NPS). 2006a. "Class I Mandatory Areas." Accessed at 2 http://www2.nature.nps.gov/air/Maps/Receptors/index.cfm on December 4,2008. ADAMS No.

3 M L083390507 4 National Park Service (NPS). 2006b. "Explore Air. Class I Receptors." Accessed at 5 http://www2.nature.nps.gov/air/Maps/images/ClassIAreas.jpg on December 3,2008. ADAMS 6 No. ML083390114 7 National Severe Storm Laboratory (NSSL). 2006. "Tornadoes ... Nature's Most Violent Storms."

8 Natural Resources Conservation Service (NRCS). 2008. Plants Database. U.S. Department of 9 Agriculture. Accessed at http://plants.usda.gov/java/factSheet on March 10,2008.

10 NatureServe. 2007. NatureServe Explorer: An online encyclopedia of life (Web application).

11 Version 6.2. NatureServe, Arlington, VA. Accessed at http://www.natureserve.org/explorer/ in 12 March 2008.

13 Nearctica.com, Inc. (Nearctica). 2008. "Wildflowers of the Eastern United States." Accessed at 14 http://www.nearctica.com/flowers/index.htm on March 12,2008.

15 New Jersey Department of Environmental Protection (NJDEP). 2005. "White Catfish."

16 Accessed at http://www.nj.gov/dep/fgw/fish_wht_cat.htm on March 13,2008. (ADAMS 17 Accession No. ML080730514) 18 New Jersey Department of Environmental Protection (NJDEP) and New Jersey Department of 19 Health and Senior Services (NJDHSS). 2006. "Fish Smart, Eat Smart: A Guide to Health 20 Advisories for Eating Fish and Crabs Caught in New Jersey Waters." Accessed at 21 http://www.state.nj.us/dep/dsr/2006fishadvisorybrochure.pdf on March 13,2008. (ADAMS 22 Accession No. ML080730515) 23 New York Natural Heritage Program (NYNHP). 2007. "New York Rare Plant Status Lists."

24 Albany, New York. 115pp. June 2007. Accessed at 25 http://www.dec.ny.gov/docs/wildlife_pdf/Rare_Plant_Status_Lists_2007.pdf on March 11,2008.

26 New York Natural Heritage Program (NYNHP). 2008a. "Online Conservation Guide for Myotis 27 sodalis." Accessed at http://www.acris.nynhp.org/guide.php?id=7405 on March 21,2008.

28 ADAMS Accession No. ML083390018.

29 New York Natural Heritage Program (NYNHP). 2008b. "Online Conservation Guide for 30 Glyptemys muhlenbergii." Accessed at http://www.acris.nynhp.org/guide.php?id=7507 on 31 March 21,2008. ADAMS Accession No. ML083390017.

32 New York Natural Heritage Program (NYNHP). 2008c. "Online Conservation Guide for 33 Sylvilagus transitionalis." Accessed at http://www.acris.nynhp.org/guide.php?id=7415 on March 34 21,2008. ADAMS Accession No. ML083390015.

35 New York Natural Heritage Program (NYNHP). 2008d. "Animal and Plant Guides." Accessed 36 at http://www.acris.nynhp.org/ in March 2008. ADAMS Accession No. ML083390012.

37 New York Metropolitan Transportation Council. 2004. Accessed at 38 http://www. nymtc. org/Project/conform ity/Appendix!Appendix%206B%20Population. pdf on Apri I 39 2008.

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Plant and the Environment 1 New York State Department of Environmental Conservation (NYSDEC). 2003a. "Final 2 Environmental Impact Statement Concerning the Applications to Renew New York State 3 Pollutant Discharge Elimination System (SPDES) Permits for the Roseton 1&2 Bowline 1&2 and 4 Indian Point 2&3 Steam Electric Generating Stations, Orange, Rockland and Westchester 5 Counties." Hudson River Power Plants FEIS. June 25, 2003. ADAMS Accession No.

6 ML083360752.

7 New York State Department of Environmental Conservation (NYSDEC). 2003b. "Fact Sheet.

8 New York State Pollutant Discharge Elimination System (SPDES) Draft Permit Renewal with 9 Modification, Indian Point Electric Generating Station, Buchanan, NY." November 2003.

10 Accessed at http://www.dec.ny.gov/docs/permits_eLoperations_pdf/lndianPointFS.pdf on July 11 12,2007. ADAMS Accession No. ML083360743.

12 New York State Department of Environmental Conservation (NYSDEC). 2004a. "Descriptive 13 Data of Municipal Wastewater Treatment Plants in New York State." New York Department of 14 Environmental Conservation, Division of Water, Bureau of Water Compliance. January 2004.

15 Accessed at http://www.dec.ny.gov/docs/water_pdf/descdata2004.pdf on January 15, 2008.

16 New York State Department of Environmental Conservation (NYSDEC). 2004b. "Abundance 17 and Distribution of Blue Crab (Callinectes sapidus) Overwintering in the Hudson River Estuary."

18 Prepared by Normandeu Associates Inc. for New York State Department of Environmental 19 Conservation, Hudson River Fisheries Unit. R-19934.000, March 2004. Accessed at 20 http://www.nysl.nysed.gov/scandoclinks/ocm60127660.htm on March 15,2008.

21 New York State Department of Environmental Conservation (NYSDEC). 2004c. New York 22 State Freshwater Wetlands Map, Westchester County, Map 1 of 14. Promulgated October 7, 23 1987. Revised July 28,2004.

24 New York State Department of Environmental Conservation (NYSDEC). 2005. "New York 25 State Breeding Bird Atlas, 2000-2005." Release 1.0. Albany, NY. Updated June 2007.

26 Accessed at http://www.dec.ny.gov/animals/7312.htmlon March 5, 2008. ADAMS Accession 27 No. ML083380509.

28 New York State Department of Environmental Conservation (NYSDEC). 2007a. "Hudson River 29 Estuary Program Annual Report for the Period April 1, 2006-March 30,2007." The Hudson 30 River Estuary Program, New York State Department of Environmental Conservation.

31 Accessed at http://www.dec.ny.gov/docs/remediation_hudson_pdf/annrep07.pdf on February 32 21,2008. ADAMS Accession No. ML083380517.

33 New York State Department of Environmental Conservation (NYSDEC). 2007b. "Checklist of 34 Amphibians, Reptiles, Birds and Mammals of New York State-Including Their Legal Status."

35 Division of Fish, Wildlife and Marine Resources, Wildlife Diversity Group. Eighth revision.

36 Accessed at www.dec.ny.gov/docs/wildlife_pdf/vertchecklist0907.pdf on March 3, 2008.

37 ADAMS Accession No. ML083380524.

38 New York State Department of Environmental Conservation (NYSDEC). 2007c. Letter from 39 Tara Seoane, Information Services, New York Natural Heritage Program, to Rani Franovitch, 40 NRC. Response to November 27,2007, request from the NRC for information on State-listed, 41 proposed, and candidate species and critical habitat that may be in the vicinity of Indian Point.

42 December 28,2007. ADAMS Accession No. ML080070085.

NUREG-1437, Supplement 38 2-156 December 2010 OAGI0001367A_00194

Plant and the Environment 1 New York State Department of Environmental Conservation (NYSDEC). 200Sa. "Some 2 Catfishes of New York." Accessed at http://www.dec.ny.gov/animals/7046.htmlon March 13, 3 200S. (ADAMS Accession No. MLOS0730517) 4 New York State Department of Environmental Conservation (NYSDEC). 200Sb. "Bald Eagle 5 Fact Sheet." Accessed at http://www.dec.ny.gov/animals/93S3.html?showprintstyles on March 6 13,200S. ADAMS Accession No. MLOS33S0531.

7 New York State Department of Environmental Conservation (NYSDEC). 200Sc. "Bald Eagles S of the Hudson River." Accessed at http://www.dec.ny.gov/animals/93S2.html?showprintstyles 9 on March 13, 200S. ADAMS Accession No. MLOS33S0535.

10 New York State Department of Environmental Conservation (NYSDEC). 200Sd. "Peregrine 11 Falcon Fact Sheet." Accessed at http://www.dec.ny.gov/animals/7294.html?showprintstyles on 12 March 5, 200S. ADAMS Accession No. MLOS33S0540.

13 New York State Department of Environmental Conservation (NYSDEC). 200Se. "Peregrine 14 Falcon." Accessed at http://www.dec.ny.gov/animals/7059.html?showprintstyles on March 13, 15 200S. ADAMS Accession No. MLOS33S0542.

16 New York State Department of Environmental Conservation (NYSDEC). 200Sf. "Bog Turtle 17 Fact Sheet." Accessed at http://www.dec.ny.gov/animals/7164.html?showprintstyles on March 1S 13,200S. ADAMS Accession No. MLOS33S0545.

19 New York State Department of Environmental Conservation (NYSDEC). 200Sg. "New York 20 State Amphibian and Reptile Atlas Project." Accessed at 21 http://www.dec.ny.gov/animals/7479.html?showprintstyles on March 13, 200S. ADAMS 22 Accession No. MLOS33S0553.

23 New York State Department of Environmental Conservation (NYSDEC). 200Sh. "List of 24 Endangered, Threatened and Special Concern Fish & Wildlife Species of New York State."

25 Accessed at http://www.dec.ny.gov/animals/70S2.htmlon March 17, 200S.

26 New York State Department of Environmental Conservation (NYSDEC). 200Si. "Red-27 shouldered Hawk Fact Sheet." Accessed at http://www.dec.ny.gov/animals/70S2.htmlon March 2S 17,200S. ADAMS Accession No. MLOS33S055S.

29 New York State Department of Health (NYSDOH). 1994. "Environmental Radiation in New 30 York State." 1993 Annual Report. Albany, NY. ADAMS Accession No. ML0703S0534.

31 New York State Department of Health (NYSDOH). 1995. "Environmental Radiation in New 32 York State." 1994 Annual Report. Albany, NY. ADAMS Accession No. ML0703S0532.

33 New York State Department of Health (NYSDOH). 2007. "Chemicals in Sportfish and Game:

34 2007-200S Health Advisories." Division of Environmental Health Assessment. Accessed at 35 http://www.health.state.ny.us/environmental/outdoors/fish/docs/fish.pdf on March 13, 200S.

36 ADAMS Accession No. MLOS33S0561.

37 New York State Department of State (NYSDOS). 2004. "Coastal Resources Online:

3S Significant Coastal Fish and Wildlife Habitats-Hudson River Mile 44-56 link." Division of 39 Coastal Resources. Accessed at 40 http://www.nyswaterfronts.com/waterfront_natural_narratives.asp on March 17, 200S. ADAMS 41 Accession No. MLOS33S0563.

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Plant and the Environment 1 New York State Department of Transportation (NYSDOT). 2005. "2004 Traffic Data Report for 2 New York State."

3 New York State Office of the State Comptroller (NYSOSC). 2008. "Local Government Services 4 and Economic Development." Accessed at http://www.osc.state.ny.us on May 30,2008.

5 ADAMS Accession No. ML083380565.

6 New York State Ornithological Association (NYSOA). 2007. "Historical Waterfowl Count Data, 7 1973-2007." Accessed at http://www.nybirds.org/ProjWaterfowl.htm on March 5, 2008.

8 ADAMS Accession No. ML083380567.

9 Nieder, W.C., E. Barnaba, S.E.G. Findlay, S. Hoskins, N. Holochuck, and E.A. Blair. (2004).

10 "Distribution and Abundance of Submerged Aquatic Vegetation and Trapa natans in the Hudson 11 River Estuary." Journal of Coastal Research 45: 150-161.

12 Niering, W.A. and N.C. Olmstead. 1979. The Audubon Society Field Guide to North American 13 Wildflowers, Eastern Region. 863 pp. Alfred A. Knopf, Inc., NY.

14 North Carolina State University (NCSU). 2008. "Plant Fact Sheets." Accessed at 15 http://www.ces.ncsu.edu/depts/hortlconsumer/factsheets/index.htmlon March 12, 2008.

16 ADAMS Accession No. ML083380570.

17 Northeast Regional Climate Center (NRCC). 2006. New York Climate Office. "The Climate of 18 New York." Accessed at http://nysc.eas.comell.edu/climate_oCny.htmlon December 3,2008.

19 ADAMS No. ML083380625 20 Northern Westchester Water Works (NWWW). 2006. Telephone correspondence from R.

21 Schoenewe (Enercon) to B. Leibowitz (Northern Westchester Water Works) regarding the 22 Westchester County, NY, Public Water Supply. January 27, 2006.

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 Nuclear Regulatory Commission (NRC). 2008. "Indian Point Nuclear Generating Unit Nos. 1 &

33 2 - NRC Inspection Report Nos. 05000003/2007010 and 05000247/2007010." Washington, 34 DC. (ADAMS Accession No. ML081340425).

35 Nuclear Regulatory Commission (NRC). 2009. "NRC Inspection Report No.

36 05000003/2009006, Entergy Nuclear Operations, Inc., Indian Point Nuclear Generating Unit 1, 37 Buchanan, NY." Docket Number 50-003. Washington, DC. (ADAMS Accession No.

38 ML091470168).

39 Office of Protected Resources (OPR). Undated. "Shortnose Sturgeon (Acipenser 40 brevirostrum)." National Marine Fisheries Service. Accessed at NUREG-1437, Supplement 38 2-158 December 2010 OAGI0001367A_00196

Plant and the Environment 1 http://www.nmfs.noaa.gov/prlspecies/fish/shortnosesturgeon.htm on December 11, 2007.

2 ADAMS Accession No. ML083380572.

3 Opler, P.A., H. Pavulaan, R.E. Stanford, and M. Pogue, coordinators. 2006. "Butterflies and 4 Moths of North America." Bozeman, MT: NBII Mountain Prairie Information Node. Accessed at 5 http://www.butterfliesandmoths.org/ on March 18, 2008. ADAMS Accession No. ML083380575.

6 Orange County Department of Planning. 2003. Orange County Comprehensive Plan:

7 Strategies for Quality Communities. Accessed at 8 http://www.orangecountygov.com/documentView.asp?docl 0=138 on May 30, 2006. ADAMS 9 Accession No. ML083380576.

10 Orange County Water Authority (OCWA). 2006. Telephone correspondence from R.

11 Schoenewe (Enercon) to J. Beaumont (Orange County Water Works) regarding the Orange 12 County, NY, Public Water Supply. January 27,2006.

13 Pace, M.L., S.E.G. Findlay, and D. Fischer. 1998. "Effects of an Invasive Bivalve on the 14 Zooplankton Community of the Hudson River." Freshwater Biology 39, pp. 103-116.

15 Peekskill Water Department, City of (PWD). 2005. "Annual Drinking Water Quality Report for 16 2005, City of Peekskill-Water Department." Accessed at http://www.ci.peekskill.ny.us on June 17 30,2006. ADAMS Accession No. ML083380578.

18 Perry, H.M., and T.D. Mcilwain. 1986. "Species Profiles: Life Histories and Environmental 19 Requirements of Coastal Fishes and Invertebrates (Gulf of Mexico)-Blue Crab." U.S. Fish and 20 Wildlife Service Biological Report 82 (11.55). U.S. Army Corps of Engineers, TR EL-82-4.

21 Peteet, D.M., D.C. Pederson, D. Kurdyla, and T. Guilderson. 2006. "Hudson River 22 Paleoecology from Marshes: Environmental Change and its Implications for Fisheries."

23 American Fisheries Society Monograph 51, pp. 113-128.

24 Phillips, P.J., and D.W. Hanchar. 1996. "Water-Quality Assessment of the Hudson River Basin 25 in New York and Adjacent States-Analysis of Available Nutrient, Pesticide, Volatile Organic 26 Compound, and Suspended-Sediment Data, 1970-1990." U.S. Geological Survey, Water-27 Resources Investigations Report 96-4065.

28 Pottern, G.B., M.T. Huish, and J.H. Kerby. 1989. "Species Profile: Life Histories and 29 Environmental Requirements of Coastal Fishes and Invertebrates (Mid-Atlantic)-Bluefish."

30 U.S. Fish and Wildlife Service Biological Report 82 (11.94). U.S. Army Corps of Engineers, TR 31 EL-82-4. Accessed at http://www.nwrc.usgs.gov/wdb/pub/species_profiles/82_11-094.pdf on 32 February 7,2008. ADAMS Accession No. ML083380583.

33 Poughkeepsie Townwide Water District (PTWD). 2005. "Annual Water Quality Report for 34 Calendar Year 2005." Accessed at 35 http://www.townofpoughkeepsie.com/PoughkeepsieTWWD2005.pdf on July 10, 2006.

36 Poughkeepsie-Dutchess County Transportation Council (PDCTC) Planning and Development.

37 2006. Divisions: Poughkeepsie-Dutchess County Transportation Council. Accessed at 38 http://www.co.dutchess.ny.us/CountyGov/Departments/Planning/PLpdctclndex.htm on June 30, 39 2006. ADAMS Accession No. ML083380587.

December 2010 2-159 NUREG-1437, Supplement 38 I OAGI0001367A_00197

Plant and the Environment 1 Pullen Herbarium. 2008. Pullen Herbarium Specimen Database (MISS), University of 2 Mississippi Department of Biology. Accessed at http://herbarium.olemiss.edu on March 14, 3 2008. ADAMS Accession No. ML083380589.

4 Purcell, J.E., D.A. Namazie, S.E. Dorsey, E.D. Houde, and J.C. Gamble. 1994. "Predation 5 Mortality of Bay Anchovy Anchoa mitchelli Eggs and Larvae Due to Scyphomedusae and 6 Ctenophores in Chesapeake Bay." Marine Ecology Progress Series 114, pp. 47-58.

7 Putnam County Division of Planning and Development. 2003. "Report on the Task Force on 8 Vision 2010: Guiding Putnam into the Next Decade." Accessed at 9 http://www.putnamcountyny.com/vision2010.htmlon May 30,2006.

10 Putnam County Water Department (PCWD). 2006. Telephone correspondence from R.

11 Schoenewe (Enercon) to E. Bartus (Putnam County Water Works) regarding the Putnam 12 County, NY, Public Water Supply System. January 27,2006.

13 Ritchie, W.A. 1980. The Archaeology of New York State. pp. 196-200. Harbor Hill Books, 14 Harrison, NY.

15 Ritchie, W.A. 1994 (orig. 1980). The Archaeology of New York State. pp. xvii-xviii. Purple 16 Mountain Press, Fleischmanns, NY.

17 Rockland County Department of Health (RCDH). 2006. "Assessment of United Water New 18 York Supply." Accessed for New Projects, 2006. Accessed at 19 http://www.co.rockland.ny.us/health/pdf/SupplyDemandTracking_1.pdf on August 28,2006.

20 ADAMS Accession No. ML083380591.

21 Rockland's Water Supply (RWS). 2006. Clearwater. Poughkeepsie, NY. Accessed at 22 www.clearwater.org/sustainablewatershed/pdfs/miller.pdf on February 20,2007.

23 Roditi, H.A., N.F. Caraco, J.J. Cole, and D.L. Strayer. 1996. "Filtration of Hudson Water by the 24 Zebra Mussel (Dreissena polymorpha)." Estuaries 19:4, pp. 824-832.

25 Rogers, S.G., and M.J. Van Den Avyle. 1989. "Species Profile: Life Histories and 26 Environmental Requirements of Coastal Fishes and Invertebrates (Mid-Atlantic)-Atlantic 27 Menhaden." U.S. Fish and Wildlife Service Biological Report 82 (11.108). U.S. Army Corps of 28 Engineers, TR EL-82-4. Accessed at 29 http://www.nwrc.usgs.gov/wdb/pub/species_profiles/82_11-108.pdf on February 5,2008.

30 ADAMS Accession No. ML083380608.

31 Rohmann, S.O., N. Lilienthal, R.L. Miller, R.M. Szwed, and W.R. Muir. 1987. "Tracing a River's 32 Toxic Pollution: A Case Study of the Hudson. Phase 2. 209 pp. Inform, Inc., NY.

33 Roundtree, R.A. 1999. "Nov. Diets of NW Atlantic Fishes and Squid." Accessed at 34 http://www.fishecology.org/diets/diets.htm on February 20,2008. ADAMS Accession No.

35 M L08338061 O.

36 Salwen, Bert. 1975. "Post-glacial Environments and Cultural Change in the Hudson River 37 Basin." Man in the Northeast 10: 43-70.

38 Sanders, C., and J. Chenger. 2001. "Williams Lake Telemetry Study: New York Indiana Bat 39 Spring Migration Tracking." Bat Conservation and Management, Mechanicsburg, PA.

40 Accessed at http://www.batmanagement.com/Projects/kings/WiliiamsScreen.pdf on March 19, 41 2008. ADAMS Accession No. ML083380612.

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Plant and the Environment 1 Schmidt, R.E., and T.R. Lake. 2006. "Tributaries and Hudson River Fishes." In: The Hudson 2 River Estuary. J.S. Levinton and J.R. Waldman, eds. 209 pp Cambridge University Press, 3 Cambridge.

4 Schultz, E.T., K.M.M. Lwiza, J.R. Young, K.J. Hartman, and R.C. Tipton. 2006. "The Dynamics 5 of Bay Anchovy in the Hudson River Estuary: Process-oriented Studies and Long-term 6 Changes." American Fisheries Society Symposium 51, pp. 197-213.

7 Shepherd, G. 2006a. "Status of Fishery Resources off the Northeastern U.S.: Bluefish."

8 Northeast Fisheries Science Center Resource Evaluation and Assessment Division, National 9 Oceanic and Atmospheric Administration. Accessed at 10 http://www. nefsc. noaa.gov/sos/spsyn/op/bluefish/archives/25_Bluefish_2006. pdf on February 7, 11 2008. ADAMS Accession No. ML083360690.

12 Shepherd G. 2006b. "Atlantic Striped Bass." Accessed at 13 http://www.nefsc. noaa.gov/sos/spsyn/af/sbass/archives/40_StripedBass_2006. pdf on December 14 10,2007. ADAMS Accession No. ML083360766.

15 Shepard, G. 2006c. "Status of Fishery Resources off the Northeastern US, NEFSC-Resource 16 Evaluation and Assessment Division, Atlantic and Shortnose Sturgeons." Accessed at 17 http://www.nefsc.noaa.gov/sos/spsyn/af/sturgeon/ on December 10, 2007. ADAMS Accession 18 No. ML083380619.

19 Smith, C.L. 1985a. "Spottail Shiner." In: The Inland Fishes of New York State, pp. 194-195.

20 New York State Department of Environmental Conservation, Albany, NY.

21 Smith, C.L. 1985b. "White Catfish." In: The Inland Fishes of New York State," pp. 78-79.

22 New York State Department of Environmental Conservation, Albany, NY.

23 Snow,D.R. 1995. Mohawk Valley Archaeology: the Sites. Matson Museum of Anthropology, 24 Pennsylvania State University, University Park, PA.

25 Stanley, J.G., and D.S. Danie. 1983. "Species Profiles: Life Histories and Environmental 26 Requirements of Coastal Fishes and Invertebrates (North Atlantic)-White Perch." U.S. Fish 27 and Wildlife Service, Division of Biological Services, FWS/OBS-82/11.7. U.S. Army Corps of 28 Engineers, TR EL-82-4. 12pp. Accessed at 29 http://www.nwrc.usgs.gov/wdb/pub/species_profiles/82_11-007.pdf on March 14,2008.

30 ADAMS Accession No. ML083380621.

31 Steinberg, N., D.J. Suszkowski, L. Clark, and J. Way. 2004. Health of the Harbor: The First 32 Comprehensive Look at the State of the NY, NY Harbor Estuary. A Report to the New 33 York/New Jersey Harbor Estuary Program. Hudson River Foundation, New York. ADAMS 34 Accession No. ML083380622.

35 Stewart, L.L., and P.J. Auster. 1987. "Species Profile: Life Histories and Environmental 36 Requirements of Coastal Fishes and Invertebrates (Mid-Atlantic)-Atlantic Tomcod." U.S. Fish 37 and Wildlife Service Biological Report 82 (11.76). U.S. Army Corps of Engineers, TR EL-82-4.

38 Accessed at http://www.nwrc.usgs.gov/wdb/pub/species_profiles/82_11-076.pdf on November 39 29,2007. ADAMS Accession No. ML073460171.

40 Strayer, D.L., and L.C. Smith. 1996. "Relationships Between Zebra Mussels (Dreissena 41 polymorpha) and Unionid Clams During the Early Stages of the Zebra Mussel Invasion of the 42 Hudson River." Freshwater Biology 36, pp. 771-779.

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Plant and the Environment 1 Strayer, D.L., K.A Hattala, and AW. Kahnle. 2004. "Effects of an Invasive Bivalve (Dreissena 2 polymorpha) on Fish in the Hudson River Estuary." Canadian Journal of Fisheries and Aquatic 3 Sciences 61, pp. 924-941.

4 Strayer, D.L., and H.M. Malcom. 2006. "Long-term Demography of a Zebra Mussel (Dreissena 5 polymorpha) Population. Freshwater Biology 51, pp. 117-130.

6 Strayer, D.L. 2007. "Zebra Mussels and the Hudson River." Cary Institute of Ecosystem 7 Studies. Accessed at http://www.ecostudies.org/people_sci_strayer_zebra_mussels.htmlon 8 January 8,2008. ADAMS Accession No. ML083380623.

9 Steinberg, N., D.J. Suszkowski, L. Clark, and J. Way. 2004. Health of the Harbor: The First 10 Comprehensive Look at the State of NY.NY Harbor Estuary. A Report to the New York/New 11 Jersey Harbor Estuary Program. Hudson River Foundation. New York, New York. ADAMS 12 Accession No. ML083360721.

13 Swaney, D.P., K.E. Limburg, and K. Staingrook. 2006. "Some Historical Changes in the 14 Pattern of Population and Land Use in the Hudson River Watershed." American Fisheries 15 Society Symposium 51, pp.75-112.

16 Sweka, J.A, J. Mohler, M.J. Millard, T. Kehler, A Kahnle, K. Hattala, G. Kenney, and A Higgs.

17 2007. "Juvenile Atlantic Sturgeon Habitat Use in Newburgh and Haverstraw Bays of the 18 Hudson River: Implications for Population Monitoring." North American Journal of Fisheries 19 Management 27, pp. 1058-1067.

20 The Journal News, New York's Lower Hudson Valley. 2006 "Westchester County's major 21 employers." From Staff Reports dated March 19,2006. Accessed at 22 http://www.lohud.com/apps/pbcs.dll/article?AID=/20060319/BUSINESS/603190302/1066/BUSI 23 NESS01 in April 2008. ADAMS Accession No. ML083380624.

24 Tipton, R.C. 2003. "Distributional Ecology of Bay Anchovy (Anchoa mitchilli) in the Hudson 25 River Estuary, USA" A dissertation submitted to West Virginia University. Forest Resources 26 Sciences Wildlife and Fisheries Program. Accessed at 27 http://kitkat.wvu.edu:8080/files/2930ITipton_Ronald_Dissertation.pdf on March 13,2008.

28 ADAMS Accession No. ML083380626.

29 Town of Cortlandt, New York (TOCNY). 2004. Comprehensive Master Plan, Town of Cortlandt, 30 July 2004. Accessed at http://www.townofcortlandt.com/on May 30,2006. ADAMS Accession 31 No. ML083380627.

32 Town of Cortlandt, New York (TOCNY). 2006. Town Profile. Accessed at 33 http://www.townofcortlandt.com/Cit-e-Access/webpage.cfm?TI 0=20&TPI 0=2564 on July 15, 34 2006. ADAMS Accession No. ML083380629.

35 U.S. Army Corps of Engineers (USACE). 2006. Public Notice No. HR-AFO-06. "Hudson River, 36 New York (Coeymans and Kingstong Reaches) Federal Navigation Projects Maintenance 37 Dredging." April 7. Accessed at 38 http://www.nan.usace.army.mill. ../buslinks/navig/cntldpth/kingston.pdf on March 5, 2008.

39 U.S. Atomic Energy Commission (USAEC). 1972. "Final Environmental Statement Related to 40 the Operation of Indian Point Nuclear Generating Plant Unit No.2." Directorate of Licensing.

41 Docket No. 50-247. September 1972.

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Plant and the Environment 1 U.S. Census Bureau (USCB). 2000. State and County Quick Facts. Accessed at 2 http://www.census.gov on March 4,2008. ADAMS Accession No. ML083380631.

3 U.S. Census Bureau (USCB). 2006. American Fact Finder, New York City, NY. Accessed at 4 http://factfinder.census.gov/home/saff/main.html?_lang=en on March 4,2008.

5 U.S. Census Bureau (USCB). 2008a. American FactFinder, American Community Survey of 6 Dutchess, Orange, Putnam, and Westchester Counties, Data Profile Highlights. Housing 7 Characteristics for 2000 and 2006. Accessed at http://factfinder.census.gov in April 2008.

8 U.S. Census Bureau (USCB). 2008b. "New York Quickfacts: Dutchess, Orange, Putnam, and 9 Westchester Counties." Accessed at http://quickfacts.census.gov/ on March 11, 2008. ADAMS 10 Accession No. ML083380632.

11 U.S. Census Bureau (USCB). 2008c. Decennial Census 2000 Data and American FactFinder, 12 American Community Survey of Dutchess, Orange, Putnam, and Westchester Counties, Data 13 Profile Highlights. ACS Demographic Estimates for 2006. Accessed at 14 http://factfinder.census.gov in April 2008.

15 U.S. Department of Agriculture (USDA). 2002a. "Dutchess County: 2002 Census of 16 Agriculture County Profile." Accessed at 17 http://www.nass.usda.gov/census/census02/profiles/ny/ on May 15, 2005.

18 U.S. Department of Agriculture (USDA). 2002b. "Orange County: 2002 Census of Agriculture 19 County Profile." Accessed at http://www.nass.usda.gov/census/census02/profiles/ny/ on May 20 15,2005.

21 U.S. Department of Agriculture (USDA). 2002c. "Putnam County: 2002 Census of Agriculture 22 County Profile." Accessed at 23 http://www.nass.usda.gov/census/census02/profiles/ny/cp36079.PDF on May 15, 2005.

24 U.S. Department of Agriculture (USDA). 2002d. "Westchester County: Farm Statistics."

25 Accessed at http://www.nass.usda.gov/census/census02/profiles/ny/cp36119.PDF on May 15, 26 2006.

27 U.S. Department of Agriculture (USDA). 2002e. "Census of Agriculture." Accessed at 28 http://www.nass.usda.gov/census/census02/volume1/pa/index2.htmin April 2008. ADAMS 29 Accession No. ML083380633.

30 U.S. Department of Commerce (USDOC). 2006a. National Climatic Data Center, NOAA 31 Satellite and Information Service, Tornado Climatology. Accessed at 32 http://www.ncdc.noaa.gov/oa/climate/severeweather/tornadoes.htmlon August 28,2006.

33 ADAMS Accession No. ML083380644.

34 U.S. Department of Commerce (USDOC). 2006b. National Climatic Data Center (NCDC), 2006 35 Westchester County Tornado Query Results. Accessed at http://www4.ncdc.noaa.gov/cgi-36 win/wwcgi.dll/wwevent-storms on July 6, 2006.

37 U.S. Geological Survey (USGS). 2008. "Hudson River Salt Front Data." Accessed at 38 http://ny.water.usgs.gov/projects/dialer_plots/saltfront.htmlon January 31, 2008.

39 United Water New York (UWNY). 2006. "Annual Water Quality Report 2005." Accessed at 40 http://www.unitedwater.com/uwny/pdfs/dNY.pdf on August 28,2006. ADAMS Accession No.

41 ML083380655.

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Plant and the Environment 1 Village of Buchanan, New York (VBNY). 1998. "About Our Village." Accessed at 2 http://www.villageofbuchanan.com/on July 7,2006.

3 Village of Buchanan, New York (VBNY). 2006. Buchanan Water Department, Entergy Nuclear 4 Operations, March, April, and May 2006 Account Statements.

5 Village of Croton-on-Hudson (VCOH). 2005. "Annual Water Quality Report 2005." Accessed at 6 http://Village.croton 7 onhudson. ny. us/Public_Documents/CrotonHudsonNY_ WebDocs/Water/CCReport2005. pdf on 8 July 14, 2006.

9 Village of Ossining Water System (VOWS). 2005. "Annual Drinking Water Report for 2005."

10 Accessed at http://www.Village.ossining.ny.us/documents/wqr_2005.pdf on July 14, 2006.

11 Waldman, J.R., K.E. Limburg, and D.L. Strayer. 2006. "The Hudson River Environment and Its 12 Dynamic Fish Community." American Fisheries Society Symposium 51, pp. 1-7.

13 Walter, J.F., A.S. Overton, K.H. Ferry, and M.E. Mather. 2003. "Atlantic Coast Feeding Habits 14 of Striped Bass: A Synthesis Supporting a Coast-wide Understanding of Trophic Biology."

15 Fisheries Management and Ecology 10 (5), pp. 349-360.

16 Westchester County Department of Planning (WCDP). 2003. "Northern Westchester County, 17 Groundwater Conditions Summary, Data Gaps, and Program Recommendations Contract C PL-18 02-71." Prepared by The Chazen Companies, April 2003.

19 Westchester County Department of Planning (WCDP). 2005. "Databook Westchester County, 20 Education, School Districts 2003." November 30, 2005.

21 Westchester County Department of Planning. 2000. Westchester County Databook: History, 22 Geography and Land Use. Accessed at 23 http://www.westchestergov.com/planning/research/main.htm on May 31,2006. ADAMS 24 Accession No. ML083380659.

25 Westchester Joint Water Works (WJWW). 2006. "Annual Drinking Water Quality Report for 26 2005." Accessed at http://www.wjww.com on June 30, 2006. ADAMS Accession No.

27 M L083380661.

28 Whitaker, J.O., Jr. 1980. The Audubon Society Field Guide to North American Mammals. 745 29 pp. Alfred A. Knopf, Inc., New York.

30 Whiteside, B.G., and T.H. Bonner. 2007. "Trinectes maculates fasciatus: Hogchoker."

31 Department of Biology, Texas State University, San Marcos. Accessed at 32 http://www. bio. txstate. edu/-tbonner/txfishes/trinectes%20maculatus%20fasciatus. htm on 33 February 19, 2008. ADAMS Accession No. ML083380667.

34 Wingate, R.L. and D.H. Secor. 2007. "Intercept Telemetry of the Hudson River Striped Bass 35 Resident Contingent: Migration and Homing Patterns." Transactions of the American Fisheries 36 Society 136, pp.95-104.

37 Wirgin, I., L. Maceda, J.R. Waldman, and R.N Crittenden. 1993. "Use of Mitochondrial DNA 38 Polymorphisms to Estimate the Relative Contributions of the Hudson River and Chesapeake 39 Bay Striped Bass Stocks to the Mixed Fishery on the Atlantic Coast." Transactions of the 40 American Fisheries Society 122, pp. 669--684.

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Plant and the Environment 1 Wirgin, I., and R.C. Chambers. 2006. "Atlantic Tomcod Microgadus tomcod: A Model Species 2 for the Responses of Hudson River Fish to Toxicants." American Fisheries Society Symposium 3 51, pp. 331-365.

4 Wolfe, D.A., E.R. Long, and G.B. Thursby. 1996. "Sediment Toxicity in the Hudson-Raritan 5 Estuary: Distribution and Correlations with Chemical Contamination." Estuaries 19:4, pp. 901-6 912.

7 Woodland, R.J., and D.H. Secor. 2007. "Year-Class Strength and Recovery of Endangered 8 Shortnose Sturgeon in the Hudson River, New York." Transactions of the American Fisheries 9 Society 136, pp. 72-81.

10 World Book Encyclopedia. 2006. "New York Climate." Chicago York Climate." Chicago,IL.

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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 supplemental environmental impact statement (SEIS) unless new and significant 20 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.

27 3.1 Potential Refurbishment Activities 28 Entergy, in its environmental report (ER), stated that its evaluation of structures and 29 components required by Title 10, Section 54.21, "Contents of Application-Technical 30 Information," of the Code of Federal Regulations (10 CFR 54.21), did not identify the need for 31 refurbishment of structures or components for purposes of license renewal and that Entergy 32 planned no such refurbishment activities (Entergy 2007). Entergy indicated that routine 33 operational and maintenance activities would be performed during the license renewal period 34 but refurbishment activities as described in the GElS were not planned.

35 During the license renewal environmental scoping process, the staff of the U.S. Nuclear 36 Regulatory Commission (NRC) received comments (Kaplowitz 2007; Shapiro 2007) indicating 37 that Entergy had taken steps toward procuring replacement reactor vessel heads and control 38 rod drive mechanisms (CRDMs) for Indian Point Nuclear Generating Unit Nos. 2 and 3 (lP2 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 2010 3-1 NUREG-1437, Supplement 38 OAGI0001367A_00204

Environmental Impacts of Refurbishment 1 IP3). The scoping comments indicated that an overseas firm plans to deliver replacement 2 reactor vessel heads and CRDMs for IP2 and IP3 in October 2011 and October 2012, 3 respectively. Based on this information, the staff requested, by letter to Entergy dated 4 December 5, 2007, additional information regarding these potential refurbishment activities 5 (NRC 2007).

6 Entergy's response, dated January 4, 2008, indicated that "no reactor vessel head 7 replacements are required for purposes of aging management during the period of extended 8 operation. Accordingly, no evaluation of the environmental impacts of reactor vessel head 9 replacement as a refurbishment activity is required or presented in the Environmental Report."

10 The response also stated that "the decision to proceed with procurement of long lead items 11 [replacement vessel heads] is strictly economic" and therefore need not be addressed in 12 Entergy's environmental report (Entergy 2008a).

13 During a telephone conference call on March 18,2008 (NRC 2008a), the staff acknowledged 14 that while there may be no requirement to replace the reactor vessel heads at IP2 and IP3 for 15 license renewal, Section 2.6.1 of the GElS discusses initiating actions for environmental impacts 16 associated with license renewal. These actions include (1) refurbishment, repair, or 17 replacement activities that "may be performed to ensure that this objective [aging management 18 and maintaining functionality of certain SSCs] is achieved" and (2) activities that licensees may 19 choose to undertake, including "various refurbishment and upgrade activities at their nuclear 20 facilities to better maintain or improve reliability, performance, and economics of power plant 21 operation during the extended period of operation." Since the GElS considers refurbishment 22 activities beyond those that are related to aging management during the period of extended 23 operation, the NRC staff indicated that Entergy's response to the staff's request for additional 24 information (RAI) did not effectively address the staff's need for information about the potential 25 refurbishment activities.

26 During the conference call, Entergy staff indicated that if license renewal were not being 27 pursued for IP2 and IP3, Entergy would not have ordered the vessel head forgings. Entergy 28 also indicated that the vessel head forgings that were procured for IP2 and IP3 may never be 29 needed at IP2 and IP3.

30 Given that Entergy has taken steps toward obtaining the replacement reactor vessel heads and 31 CRDMs, and given that these replacement activities, should they occur, would be associated 32 with license renewal (i.e., they would not be undertaken in the absence of license renewal), the 33 NRC staff issued an additional RAI on April 14, 2008 (NRC 2008b), in which the staff requested 34 information from Entergy regarding the process Entergy would use in deciding whether to 35 replace the vessel heads and CRDMs, as well as indicating the potential environmental impacts 36 of these replacement activities. Entergy submitted its response to NRC on May 14, 2008 37 (Entergy 2008b).

38 In its RAI response, Entergy reasserted that it did not believe vessel head and CRDM 39 replacement constituted a refurbishment activity (Entergy 2008b). In addition, the response 40 indicated that the current vessel heads are in good condition, though Entergy may eventually 41 decide to replace them pending the results of future inspections.

42 Entergy's response also provided a likely hypothetical scenario for the replacement activities, 43 should they occur. The scenario includes the following characteristics (Entergy 2008b):

I NUREG-1437, Supplement 38 3-2 December 2010 OAGI0001367A_00205

Environmental Impacts of Refurbishment 1

  • Approximately 250 additional workers would be required for the replacement of each 2 reactor vessel head and CRDM. The replacement would take place during a 60-day 3 refueling outage for each unit, when approximately 950 refueling outage workers are at 4 the Indian Point site. An additional 50 workers would be required to construct the vessel 5 head storage structure, though their work would be largely completed before the 6 beginning of the refueling outage.

7

  • The reactor vessel heads would be manufactured overseas, transported to a U.S. port, 8 and shipped up the Hudson River via barge, with the CRDMs installed, to the existing 9 Indian Point barge slip.

10

  • Once delivered to the IP2 and IP3 site, storage and preinstallation preparation would 11 take place at onsite temporary structures. If possible, existing warehouses would also 12 be used. The only permanent building constructed would be used to store the old 13 reactor vessel heads and CRDMs; this building would likely be constructed near the 14 onsite structure storing the old IP2 and IP3 steam generators and occupy less than 446 15 square meters (4800 square feet). All structures would be constructed on previously 16 disturbed areas.

17

  • Staff or contractors would cut a temporary opening in containment approximately 7.6 18 meters by 7.9 meters (25 feet by 26 feet) to allow for removal of the old heads and 19 CRDMs and installation of the new ones. Containment concrete would be removed by 20 hydro-demolition, while rebar and a portion of steel liner would be removed by other 21 means.

22

  • Before removing the old reactor vessel head from containment, Entergy would remove 23 any loose contamination or affix it with a coating. The old head would then be 24 transported to the onsite storage facility (for possible offsite permanent disposition).

25 Meanwhile, the new head (with CRDMs) would be installed.

26

  • Upon project completion, each unit's containment would be returned to its original 27 configuration.

28 The NRC staff considered the GElS guidance on refurbishment activities, the need to disclose 29 potential impacts of the proposed action, and Entergy's analysis of possible impacts of vessel 30 head and CRDM replacements. The NRC staff also acknowledged that vessel head and CRDM 31 replacements may not occur. Nevertheless, to ensure that, should these refurbishment 32 activities occur, their environmental impacts will have been characterized and disclosed in 33 accordance with the National Environmental Policy Act and NRC implementing regulations, the 34 NRC staff determined that it would be appropriate to evaluate the potential impacts of these 35 possible replacement activities using the GElS framework for refurbishment.

36 Since the NRC staff published the draft SEIS, Entergy indicated (at the 2009 Annual 37 Assessment meeting in Tarrytown, NY), that it planned to replace the Unit 2 vessel head in 38 2014, and the Unit 3 vessel head in 2016. Entergy did not directly address timing for CRDM 39 replacement at this meeting, but NRC staff finds it likely that Entergy would replace vessel 40 heads and CRDMs at the same time. NRC staff addresses the potential environmental impacts December 2010 3-3 NUREG-1437, Supplement 38 OAGI0001367A_00206

Environmental Impacts of Refurbishment 1 of vessel head and CRDM replacements below.

2 3.2 Refurbishment Impacts 3 The IP2 and IP3 site was one of seven case study reactor locations the NRC staff used in 4 determining potential environmental impacts from refurbishment activities while developing the 5 GElS. After reviewing construction-stage impacts at these seven plant sites and then scaling 6 them down to better approximate the duration and intensity of impacts expected during plant 7 refurbishment activities, the NRC staff determined that nine refurbishment-related issues would 8 be Category 1 issues. The GElS approach to refurbishment assumed longer duration outages, 9 more workers, and a wider array of activities on site than would occur during the reactor vessel 10 head and CRDM replacement project discussed here. The GElS also noted, in Appendix B, 11 that outages would grow shorter as licensees gained experience with major replacement 12 activities. Additionally, the GElS noted that some licensees may choose to perform only a few 13 activities.

14 Even given larger workforces, more activities, and longer outages, the NRC staff determined in 15 the GElS that the impacts for these nine issues are SMALL.

16 Table 3-1 contains a list of Category 1 issues associated with refurbishment.

17 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 18 Provided below are the results of the NRC staff reviews and a brief statement of GElS 19 conclusions, as codified in Table B-1 of 10 CFR Part 51, "Environmental Protection Regulations NUREG-1437, Supplement 38 3-4 December 2010 OAGI0001367A_00207

Environmental Impacts of Refurbishment 1 for Domestic Licensing and Related Regulatory Functions," Subpart A, "National Environmental 2 Policy Act-Regulations Implementing Section 102(2)," Appendix B, "Environmental Effect of 3 Renewing the Operating License of a Nuclear Power Plant," for each of the Category 1 4 refurbishment issues listed in Table 3-1. For each Category 1 issue, the NRC staff has not 5 identified any new and significant information during its review of the Entergy ER (Entergy 6 2007), its site audit, the SEIS scoping process, public comments on the draft SEIS, and its 7 evaluation of other available information, including Entergy's May 14, 2008, RAI response 8 (Entergy 2008b).

9

  • Impacts of refurbishment on surface water quality. Based on information in the GElS, 10 the Commission found the following:

11 Impacts are expected to be negligible during refurbishment because best 12 management practices are expected to be employed to control soil erosion and 13 spills.

14

  • Impacts of refurbishment on surface water use. Based on information in the GElS, the 15 Commission found the following:

16 Water use during refurbishment will not increase appreciably or will be reduced 17 during plant outage.

18

  • Impacts of refurbishment on aquatic ecology. Based on information in the GElS, the 19 Commission found the following:

20 During plant shutdown and refurbishment there will be negligible effects on 21 aquatic biota because of a reduction of entrainment and impingement of 22 organisms or a reduced release of chemicals.

23

  • Impacts of refurbishment on ground water use and quality. Based on information in the 24 GElS, the Commission found the following:

25 Extensive dewatering during the original construction on some sites will not be 26 repeated during refurbishment on any sites. Any plant wastes produced during 27 refurbishment will be handled in the same manner as in current operating 28 practices and are not expected to be a problem during the license renewal term.

29

  • Impacts of refurbishment on onsite land use. Based on information in the GElS, the 30 Commission found the following:

31 Projected onsite land use changes required during refurbishment and the 32 renewal period would be a small fraction of any nuclear power plant site and 33 would involve land that is controlled by the applicant.

34

  • Radiation exposures to the public during refurbishment. Based on information in the 35 GElS, the Commission found the following:

36 During refurbishment, the gaseous effluents would result in doses that are similar 37 to those from current operation. Applicable regulatory dose limits to the public 38 are not expected to be exceeded.

December 2010 3-5 NUREG-1437, Supplement 38 I OAGI0001367A_00208

Environmental Impacts of Refurbishment 1

  • Occupational radiation exposures during refurbishment. Based on information in the 2 GElS, the Commission found the following:

3 Occupational radiation doses from refurbishment are expected to be within the 4 range of annual average collective doses experienced for pressurized-water 5 reactors and boiling-water reactors. Occupational mortality risks from all causes 6 including radiation is in the mid-range for industrial settings.

7

  • Public services: public safety, social services, and tourism and recreation. Based on 8 information in the GElS, the Commission found the following:

9 Impacts to public safety, social services, and tourism and recreation are 10 expected to be of small significance at all sites.

11

  • Aesthetic impacts (refurbishment). Based on information in the GElS, the Commission 12 found the following:

13 No significant impacts are expected during refurbishment.

14 The NRC staff identified no new and significant information related to these issues during its 15 review of the Entergy ER, during the SEIS scoping process, in correspondence identified in 16 Section 3.1 of this chapter, in Entergy's May 14, 2008, RAI response (Entergy 2008b) or from 17 public comments on the draft SEIS. Therefore, the NRC staff expects that there would be no 18 impacts related to these issues during the renewal term beyond those discussed in the GElS.

19 Environmental issues related to refurbishment considered in the GElS for which these 20 conclusions could not be reached for all plants, or for specific classes of plants, are Category 2 21 issues. These are listed in Table 3-2.

22 I NUREG-1437, Supplement 38 3-6 December 2010 OAGI0001367A_00209

Environmental Impacts of Refurbishment 1

2 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 3 ENVIRONMENTAL JUSTICE Environmental justice Not addressed Ca ) Not addressed Ca )

(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.

4 The results of the review for each Category 2 refurbishment issue are provided in the following 5 sections.

6 3.2.1 Terrestrial Ecology-Refurbishment Impacts 7 Refurbishment impacts on terrestrial ecology are a Category 2 issue (10 CFR Part 51, 8 Subpart A, Appendix B, Table B-1). Table B-1 notes that "Refurbishment impacts are 9 insignificant if no loss of important plant and animal habitat occurs. However, it cannot be 10 known whether important plant and animal communities may be affected until the specific 11 proposal is presented with the license renewal application.

12 As stated in Section 4.4.5.2, Entergy has not proposed any new facilities, service roads, or 13 transmission lines for IP2 and IP3 associated with continued operations or refurbishment.

December 2010 3-7 NUREG-1437, Supplement 38 OAGI0001367A_0021 0

Environmental Impacts of Refurbishment 1 Entergy indicated, however, that it may replace the reactor vessel heads and CRDMs for IP2 2 and IP3 during the license renewal term. Ground-disturbing activities associated with this 3 project would involve the construction of a storage building to house the retired components 4 (Entergy 2008b). This area was previously disturbed by the construction of IP2 and IP3.

5 Activities associated with the transport of the new reactor vessel heads and CRDMs would 6 result in no additional land disturbance. The replacement components would arrive by barge 7 and be transported over an existing service road by an all-terrain vehicle (Entergy 2008b). The 8 route through which the service road passes was previously disturbed by the construction of all 9 three IP units. Because Entergy plans to conduct all of these activities on previously disturbed 10 land within a relatively short period of finite duration, the level of impact on terrestrial natural 11 resources is expected to be SMALL.

12 Mitigation measures would include routine land and vegetation management practices, as well 13 as using the most disturbed areas possible for new buildings and staging areas. The NRC staff 14 did not identify any cost-benefit studies associated with these measures.

15 3.2.2 Threatened or Endangered Species-Refurbishment Impacts 16 Refurbishment impacts on threatened or endangered species are a Category 2 issue.

17 Table B-1 of Appendix B to 10 CFR Part 51, Subpart A, notes the following:

18 Generally, plant refurbishment and continued operation are not expected to 19 adversely affect threatened and endangered species. However, consultation 20 with appropriate agencies would be needed at the time of license renewal to 21 determine whether threatened or endangered species are present and whether 22 they would be adversely affected.

23 The NRC staff identified three federally listed terrestrial species-bog turtle, C/emmys 24 muhlenbergii; New England cottontail, Sylvi/agus transitionaJis; and Indiana bat, Myotis 25 sodaJist-and one aquatic species-shortnose sturgeon, Acipenser brevirostrum-as potentially 26 affected by the relicensing of Indian Point. As explained above under Section 3.2.1, Entergy 27 plans to conduct all terrestrial refurbishment activities on previously disturbed land within a 28 relatively short period of finite duration. Entergy does not plan to conduct these activities on 29 undisturbed land, and no designated critical habitat occurs on the site (Entergy 2008b). As a 30 result, the NRC staff finds that refurbishment activities are not likely to adversely affect the 31 continued existence of listed terrestrial species or adversely modify designated critical habitats.

32 Based on analyses presented in Section 4.6.1, shortnose sturgeon eggs and larvae probably do 33 not occur, or occur only rarely, in the vicinity of Indian Point. Juvenile and adult shortnose 34 sturgeon do occur in the vicinity of Indian Point. For refurbishment, the replacement 35 components would arrive by barge and be transported over an existing service road by an all-36 terrain vehicle (Entergy 2008b). Entergy does not have plans to dredge to accommodate the 37 barge at its dock and is not planning any other activities that would adversely affect aquatic 38 species or habitats. Also, any onsite activities will have to follow existing regulations to control 39 runoff from construction or industrial sites. Because no activities are planned that would 40 adversely affect the aquatic environment, refurbishment activities are not likely to adversely 41 affect the continued existence of endangered shortnose sturgeon.

42 Essential fish habitat, as defined under the 1996 amendments to the Magnuson-Stevens NUREG-1437, Supplement 38 3-8 December 2010 OAG10001367A_00211

Environmental Impacts of Refurbishment 1 Fishery Conservation and Management Act, occurs in the vicinity of IP2 and IP3 for red hake 2 (Urophycis chuss) larvae, winter flounder (Pleuronectes american us) larvae, windowpane 3 (Scophtha/mus aquosus) juveniles and adults, and Atlantic butterfish (Peprilus triacanthus) 4 juveniles and adults. Because Entergy plans no refurbishment activities that would adversely 5 affect the aquatic environment, there should be no adverse individual or cumulative effects on 6 essential fish habitat in the project area.

7 3.2.3 Air Quality During Refurbishment (Nonattainment and Maintenance Areas) 8 Air quality during refurbishment (nonattainment and maintenance areas) is a Category 2 issue.

9 Table B-1 of Appendix B to 10 CFR Part 51, Subpart A, notes the following:

10 Air quality impacts from plant refurbishment associated with license renewal are 11 expected to be small. However, vehicle exhaust emissions could be cause for 12 concern at locations in or near nonattainment or maintenance areas. The 13 significance of the potential impact cannot be determined without considering the 14 compliance status of each site and the numbers of workers expected to be 15 employed during the outage.

16 The May 14, 2008, RAI response from Entergy (Entergy 2008b) indicates that the replacement 17 of reactor vessel heads and CRDMs for IP2 and IP3 will result in minor impacts to air quality.

18 Citing the GElS, Entergy states that the only potential sources of impacts to air quality would be 19 (1) fugitive dust from site excavation and grading for construction of any new waste storage 20 facilities and (2) emissions from motorized equipment and workers' vehicles.

21 Entergy indicates that the bulk of air quality impacts during the postulated refurbishment activity 22 would result from exhaust emissions released by onsite motorized equipment and workers' 23 vehicles (Entergy 2008b). These effects include temporary increases in atmospheric 24 concentrations of nitrogen oxides (NOx), carbon monoxide (CO), sulfur dioxide (S02), volatile 25 organic compounds (VOCs), ammonia, and particulate matter (PM).

26 A table summarizing the attainment status of the counties within the immediate area of IP2 and 27 IP3 shows nonattainment of the National Ambient Air Quality Standards (NAAQS) for 8-hour 28 ozone in Dutchess, Orange, Putnam, Rockland, and Westchester Counties. There is 29 nonattainment of the NAAQS for particulate matter, 2.5 microns or less in diameter (PM 2.5) in 30 Orange, Rockland, and Westchester Counties. Westchester County is designated as a 31 maintenance county for CO.

32 Based on a conservative assumption that 400 additional vehicles would travel to and from the 33 site each day during a 65-day outage period (conservative because Entergy projects that only 34 300 additional workers over 60 days could accomplish the replacement activities), Entergy 35 estimated that air emissions of VOCs, CO, and NOx would increase by 0.95 tons (0.86 metric 36 tons (MT)), 16.1 tons (14.6 MT), and 1.02 tons (0.926 MT), respectively (Entergy 2008b). The 37 regulatory conformity thresholds for VOCs, CO, and NOx are 50 tons (45 MT), 100 tons 38 (90.7 MT), and 50 tons (45 MT), respectively, as indicated in 40 CFR 51.853(b). A comparison 39 of Entergy's conservative estimates for vehicle emissions versus the associated regulatory 40 conformity levels indicates that none of the thresholds would be exceeded. Based on this 41 analysis, the NRC staff finds that air quality impacts during the postulated reactor vessel head 42 and CRDM replacement would be SMALL.

December 2010 3-9 NUREG-1437, Supplement 38 I OAG10001367A_00212

Environmental Impacts of Refurbishment 1 The NRC staff identified a variety of measures that could mitigate potential air quality impacts 2 resulting from the vessel head and CRDM replacements at IP2 and IP3. These include the use 3 of multiperson vans and carpooling policies to reduce the number of vehicles used to transport 4 workers to the site. The NRC staff did not identify any cost-benefit studies applicable to these 5 mitigation measures.

6 3.2.4 Housing Impacts-Refurbishment 7 Housing impacts during refurbishment are a Category 2 issue. Table B-1 of Appendix B to 8 10 CFR Part 51, Subpart A, notes the following:

9 Housing impacts are expected to be of small significance at plants located in a 10 medium or high population area and not in an area where growth control 11 measures that limit housing development are in effect. Moderate or large 12 housing impacts of the workforce associated with refurbishment may be 13 associated with plants located in sparsely populated areas or in areas with 14 growth control measures that limit housing development.

15 Entergy estimates that reactor vessel head and CRDM replacement would increase the number 16 of refueling outage workers at the Indian Point site for up to 60 days during two separate 17 refueling outages, one for each unit, 12 months apart. Approximately 250 workers would be 18 needed for each replacement in addition to the normal number of refueling outage workers. An 19 additional 50 workers would construct a storage structure for the old reactor vessel heads and 20 CRDMs. This work would be completed before the beginning of the refueling outage (Entergy 21 2008b).

22 The number of additional workers would cause a short-term increase in the demand for 23 temporary (rental) housing units in the region beyond what is normally experienced during a 24 refueling outage at the Indian Point site. Since IP2 and IP3 are located in a high-population 25 area (see Section 2.2.8.5) and the number of available housing units has either kept pace with 26 or exceeded changes in county populations (see Section 2.2.8.1), any changes in employment 27 would have no noticeable effect on the availability of housing in the socioeconomic region of 28 influence. Because of the short duration of the replacement activity for each unit's reactor 29 vessel head and CRDMs and the availability of housing in the region, employment-related 30 housing impacts would have no noticeable impact.

31 3.2.5 Public Services: Public Utilities-Refurbishment 32 Public utilities is a Category 2 refurbishment issue. Table B-1 of Appendix B to 10 CFR Part 51, 33 Subpart A, notes that "[a]n increased problem with water shortages at some sites may lead to 34 impacts of moderate significance on public water supply availability."

35 Since there is no water shortage in the region and public water systems located in Dutchess, 36 Orange, and Putnam Counties have excess capacity (indicated in Table 2-9 in Chapter 2), any 37 changes in the Indian Point site and employee public water usage would have little noticeable 38 effect on public water supply availability in these counties. As discussed in Section 2.2.8.2, the 39 Indian Point site acquires potable water from the Village of Buchanan water supply system, and 40 there are no restrictions on the supply of potable water from the village.

I NUREG-1437, Supplement 38 3-10 December 2010 OAGI0001367A_00213

Environmental Impacts of Refurbishment 1 As discussed in Section 3.2.4, Entergy estimates that reactor vessel head and CRDM 2 replacement would increase the number of refueling outage workers at the Indian Point site for 3 up to 60 days during two separate refueling outages, one for each unit, 12 months apart 4 (Entergy 2008b). The additional number of refueling outage workers needed to replace the 5 reactor vessel heads and CRDMs would cause short-term increases in the amount of public 6 water and sewer services used in the immediate vicinity of the Indian Point site. Since the 7 region has excess water supply capacity with no restrictions, these activities would create no 8 impacts.

9 3.2.6 Public Services: Education-Refurbishment 10 Education is a Category 2 refurbishment issue. Table B-1 of Appendix B to 10 CFR Part 51, 11 Subpart A, notes that "[m]ost sites would experience impacts of small significance but larger 12 impacts are possible depending on site- and project-specific factors."

13 As discussed in Section 3.2.4, Entergy estimates that reactor vessel head and CRDM 14 replacement would increase the number of refueling outage workers for up to 60 days at the 15 Indian Point site (Entergy 2008b). Because of the short duration of the replacement activity for 16 each unit's reactor vessel head and CRDMs, workers would not be expected to bring families 17 and school-age children with them; therefore, there would be no impact on educational services 18 during this extended refueling outage.

19 3.2.7 Offsite Land Use-Refurbishment 20 Offsite land use is a Category 2 refurbishment issue. Table B-1 of Appendix B to 21 10 CFR Part 51, Subpart A, notes that "Impacts may be of moderate significance at plants in 22 low population areas."

23 Since IP2 and IP3 are located in a high-population area, any changes in employment would 24 have little noticeable effect on land use in the region. Because of the short duration of the 25 replacement activity for each unit's reactor vessel head and CRDMs, the additional number of 26 refueling outage workers would not cause any permanent changes in population and tax-27 revenue-related land use in the immediate vicinity of IP2 and IP3.

28 3.2.8 Public Services: Transportation-Refurbishment 29 Transportation is a Category 2 refurbishment issue. Table B-1 of Appendix B to 30 10 CFR Part 51, Subpart A, notes the following:

31 Transportation impacts (level of service) of highway traffic generated during plant 32 refurbishment and during the term of the renewed license are generally expected 33 to be of small significance. However, the increase in traffic associated with 34 additional workers and the local road and traffic control conditions may lead to 35 impacts of moderate or large significance at some sites.

36 The additional number of refueling outage workers and truck material deliveries needed to 37 support the replacement of each reactor vessel head and CRDM would cause short-term level-38 of-service impacts on access roads in the immediate vicinity of the Indian Point site. According 39 to Entergy, increased traffic volumes entering and leaving the Indian Point site during refueling December 2010 3-11 NUREG-1437, Supplement 38 OAG10001367A_00214

Environmental Impacts of Refurbishment 1 outages, which occur at intervals of approximately 12 months for one unit or the other, have not 2 degraded the level-of-service capacity on local roads, and the higher number of refueling outage 3 workers during IP2 and IP3 steam generator replacement outages did not require any road 4 improvements (Entergy 2008b). During routine periods of high traffic volume (i.e., morning and 5 afternoon shift changes), Entergy has previously employed staggered shifts (starting and 6 quitting times) during refueling outages to minimize level-of-service impacts on State Routes 9 7 and 9A (Entergy 2008b). Based on this information and because of the short duration of the 8 replacement activity for each unit's reactor vessel head and CRDMs (up to 60 days), and given 9 that the activity occurs at the same time as a normal refueling outage, the NRC staff finds that 10 no transportation (level-of-service) impacts, beyond impacts from normal outages, would occur.

11 3.2.9 Historic and Archeological Resources-Refurbishment 12 Historic and archeological resources is a Category 2 refurbishment issue. Table B-1 of 13 Appendix B to 10 CFR Part 51, Subpart A, notes the following:

14 Generally, plant refurbishment and continued operation are expected to have no 15 more than small adverse impacts on historic and archaeological resources.

16 However, the National Historic Preservation Act requires the Federal agency to 17 consult with the State Historic Preservation Officer to determine whether there 18 are properties present that require protection.

19 As stated in Section 4.4.5.2, Entergy has not proposed any new facilities, service roads, or 20 transmission lines for IP2 and IP3 associated with continued operations or refurbishment.

21 However, Entergy indicated that it may replace the reactor vessel heads and CRDMs for IP2 22 and IP3 during the license renewal term. Ground-disturbing activities associated with this 23 project would involve the construction of a storage building to house the retired components 24 (Entergy 2008b). Should Entergy replace the vessel heads and CRDMs, ground-disturbing 25 activities would be reviewed in accordance with Entergy Nuclear fleet procedures, which are 26 designed to ensure that investigations and consultations are conducted as needed and that 27 existing or potentially existing cultural resources are adequately protected (Enercon 2006). The 28 procedures have been reviewed by the New York State Historic Preservation Office (NY 29 SHPO). According to Entergy, the area of construction would be in an area that requires no 30 prior consultation for historic, cultural, or archeological resources (Entergy 2008b). This area 31 was previously disturbed by the construction of IP2 and IP3.

32 Activities associated with the transport of the new reactor vessel heads and CRDMs would 33 result in no additional land disturbance. The replacement components would arrive by barge 34 and be transported over an existing service road by an all-terrain vehicle (Entergy 2008b). The 35 route through which the service road passes was previously disturbed by the construction of all 36 three IP units.

37 The impacts associated with this activity are not expected to adversely impact historic or 38 archeological sites in the area of IP2 and IP3. Therefore, the potential impacts from this activity 39 on National Register-eligible historic or archeological resources would be SMALL. However, 40 should historic archeological resources be encountered during construction, work would cease 41 until Entergy environmental personnel would perform an evaluation and consider possible 42 mitigation measures through consultation with the NY SHPO.

I NUREG-1437, Supplement 38 3-12 December 2010 OAGI0001367A_00215

Environmental Impacts of Refurbishment 1 3.2.10 Environmental Justice-Refurbishment 2 Environmental justice is a plant-specific refurbishment issue. Table B-1 of Appendix B to 3 10 CFR Part 51, Subpart A, notes that "[t]he need for and the content of an analysis of 4 environmental justice will be addressed in plant specific reviews."

5 Since IP2 and IP3 are located in a high-population area, the small, short duration change in 6 employment associated with the potential replacement activities would likely have no noticeable 7 effect on minority and/or low-income populations in the region. Because of the short duration of 8 the replacement activity for each unit's reactor vessel head and CRDMs, and based on the 9 analysis of impacts for the other resource areas discussed in Section 3.2, the NRC staff 10 concludes there would be no disproportionately high and adverse impacts to minority and low-11 income populations in the immediate vicinity of IP2 and IP3.

12 3.3 Evaluation of New and Potentially Significant 13 Information on Impacts of Refurbishment 14 Entergy, in its May 14, 2008, RAI response (Entergy 2008b), indicated that it had reviewed the 15 findings included in Chapter 3 of the GElS and identified no new and significant information that 16 would invalidate the findings made in the GElS. Further, the NRC staff has reviewed Entergy's 17 response, has evaluated the likely impacts of the vessel head and CRDM replacement, and has 18 not identified any new and significant information associated with these activities.

19 3.4 Summary of Refurbishment Impacts 20 The NRC staff did not identify any information that is either new or significant related to any of 21 the applicable Category 1 issues associated with refurbishment activities at IP2 and IP3 during 22 the renewal term. The NRC staff concludes that the environmental impacts associated with 23 those issues are bounded by the impacts described in the GElS (NRC 1996). For each of the 24 Category 1 issues addressed in this section, the GElS concludes that impacts would be SMALL 25 and that additional plant-specific mitigation measures are not likely to be sufficiently beneficial to 26 warrant implementation.

27 For all Category 2 issues related to refurbishment activities at IP2 and IP3, the NRC staff 28 concluded-after reviewing guidance in the GElS and Entergy's description of potential 29 activities-that refurbishment activities would have SMALL or no impacts. The NRC staff's 30 conclusions for Category 2 impact levels considered the activities' limited scope and duration 31 compared to the refurbishment programs identified in the GElS.

32 3.5 References 33 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 34 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

35 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for 36 Renewal of Operating Licenses for Nuclear Power Plants."

December 2010 3-13 NUREG-1437, Supplement 38 I OAG10001367A_00216

Environmental Impacts of Refurbishment 1 Enercon Services, Inc. (Enercon). 2006. "Phase 1A Literature Review and Archaeological 2 Sensitivity Assessment of the Indian Point Site, Westchester County, New York." Tulsa, OK.

3 Entergy Nuclear Operations, Inc. (Entergy). 2007. "Applicant's Environment Report, Operating 4 License Renewal Stage." (Appendix E of "IP2 and IP3, Units 2 and 3, License Renewal 5 Application"). April 23, 2007. Agency wide 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. (NRC) 1996. "Generic Environmental Impact Statement 20 for 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. (NRC) 1999. "Generic Environmental Impact Statement 23 for License Renewal of Nuclear Plant." NUREG-1437, Volume 1, Addendum 1. Office of 24 Nuclear Reactor Regulation, Washington, DC.

25 U.S. Nuclear Regulatory Commission. (NRC) 2007. "Request for Additional Information 26 Regarding Environmental Review for Indian Point Nuclear Generating Unit Nos. 2 and 3 License 27 Renewal (TAC Nos. MD5411 and MD5412)." December 5, 2007. ADAMSAccession 28 No. ML073330931.

29 U.S. Nuclear Regulatory Commission. (NRC) 2008a. Summary of Telephone Conference Call 30 between NRC and Entergy Nuclear Operations, Inc., Pertaining to the Indian Point Units 2 & 3, 31 License Renewal Application-Environmental Request for Additional Information. March 18, 32 2008. ADAMS Accession No. ML080920983.

33 U.S. Nuclear Regulatory Commission. (NRC) 2008b. "Request for Additional Information 34 Regarding the Review of the License Renewal Application for Indian Point Nuclear Generating 35 Unit Nos. 2 & 3 (TAC Nos. MD5411 and MD5412)." April 14, 2008. ADAMS Accession 36 No. ML080940408.

I NUREG-1437, Supplement 38 3-14 December 2010 OAGI0001367A_00217

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 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 40 listed in Appendix F to this SEIS.

(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 2010 4-1 NUREG-1437, Supplement 38 OAGI0001367A_00218

Environmental Impacts of Operation 1 4.1 Cooling System 2 Generic (Category 1) issues in Table 8-1 of Appendix 8 to Subpart A of 10 CFR Part 51 that are 3 applicable to IP2 and IP3 cooling system operations during the renewal term are listed in 4 Table 4-1. Entergy Nuclear Indian Point 2 and Entergy Nuclear Indian Point 3, LLC (Entergy) 5 stated in its environmental report (ER) (Entergy 2007a) that it is not aware of any new and 6 significant information associated with the renewal of the IP2 and IP3 operating licenses related 7 to cooling system operation. The NRC staff has not identified any new and significant 8 information related to cooling system operation during its independent review of the Entergy ER, 9 the site visit, the scoping process, comments on the draft SEIS, or the evaluation of other 10 available information. Therefore, the NRC staff concludes that there are no impacts related to 11 these issues beyond those discussed in the GElS. For all of the Category 1 issues, the NRC 12 staff concluded in the GElS that the impacts would be SMALL, and additional plant-specific 13 mitigation measures are not likely to be sufficiently beneficial to warrant implementation.

14 A brief description of the NRC staff's review and the GElS conclusions, as codified in 15 10 CFR Part 51, Table 8-1, for each of these issues follows.

16 Table 4-1. Generic (Category 1) Issues Applicable to the Operation of the IP2 and IP3 17 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 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 Low dissolved oxygen in the discharge 4.2.2.1.9 I NUREG-1437, Supplement 38 4-2 December 2010 OAGI0001367A_00219

Environmental Impacts of Operation Losses from predation, parasitism, and disease among organisms exposed 4.2.2.1.10 to sublethal stresses Stimulation of nuisance organisms (e.g., shipworms) 4.2.2.1.11 HUMAN HEALTH Noise 4.3.7 1 The NRC staff reviewed information provided from Entergy's ER, the NRC staff's site visit, the 2 scoping process, the New York State Pollutant Discharge Elimination System (SPDES) 3 permits for IP2 and IP3 that expired in 1992 and have since been administratively continued, the 4 subsequent draft permit, ongoing Hudson River monitoring programs and their results, and 5 other available information. The NRC staff has not identified any new and significant 6 information for Category 1 issues applicable to the operation of the IP2 and IP3 cooling system 7 during the period of extended operation.

8 Therefore, the NRC staff concludes that there would be no impacts for these issues during the 9 renewal term beyond those discussed in the GElS. The following bullets identify the Category 1 10 issues applicable to the operation of the IP2 and IP3 cooling system during the period of 11 extended operation and the Commission's findings as indicated in the GElS:

12

  • Altered current patterns at intake and discharge structures. Based on information in the 13 GElS, the Commission found the following:

14 Altered current patterns have not been found to be a problem at operating 15 nuclear power plants and are not expected to be a problem during the license 16 renewal term.

17

  • Temperature effects on sediment transport capacity. Based on information in the GElS, 18 the Commission found the following:

19 These effects have not been found to be a problem at operating nuclear power 20 plants and are not expected to be a problem during the license renewal term.

21

  • Scouring caused by discharged cooling water. Based on information in the GElS, the 22 Commission found the following:

23 Scouring has not been found to be a problem at most operating nuclear power 24 plants and has caused only localized effects at a few plants. It is not expected to 25 be a problem during the license renewal term.

26

  • Eutrophication. Based on information in the GElS, the Commission found the following:

27 Eutrophication has not been found to be a problem at operating nuclear power 28 plants and is not expected to be a problem during the license renewal term.

29

  • Discharge of chlorine or other biocides. Based on information in the GElS, the 30 Commission found the following:

31 December 2010 4-3 NUREG-1437, Supplement 38 I OAGI0001367A_00220

Environmental Impacts of Operation 1 Effects are not a concern among regulatory and resource agencies, and are not 2 expected to be a problem during the license renewal term.

3

  • Discharge of sanitary wastes and minor chemical spills. Based on information in the 4 GElS, the Commission found the following:

5 Effects are readily controlled through the NPDES permit2 and periodic 6 modifications, if needed, and are not expected to be a problem during the license 7 renewal term.

8

  • Discharge of other metals in wastewater. Based on information in the GElS, the 9 Commission found the following:

10 These discharges have not been found to be a problem at operating nuclear 11 power plants with cooling-tower-based heat dissipation systems and have been 12 satisfactorily mitigated at other plants. They are not expected to be a problem 13 during the license renewal term.

14

  • Water-use conflicts (plants with once-through cooling systems). Based on information in 15 the GElS, the Commission found the following:

16 These conflicts have not been found to be a problem at operating nuclear power 17 plants with once-through heat dissipation systems.

18

  • Accumulation of contaminants in sediments or biota. Based on information in the GElS, 19 the Commission found the following:

20 Accumulation of contaminants has been a concern at a few nuclear power plants 21 but has been satisfactorily mitigated by replacing copper alloy condenser tubes 22 with those of another metal. It is not expected to be a problem during the license 23 renewal term.

24

  • Entrainment of phytoplankton and zooplankton. Based on information in the GElS, the 25 Commission found the following:

26 Entrainment of phytoplankton and zooplankton has not been found to be a 27 problem at operating nuclear power plants and is not expected to be a problem 28 during the license renewal term.

29

  • Cold shock. Based on information in the GElS, the Commission found the following:

30 Cold shock has been satisfactorily mitigated at operating nuclear plants with 31 once-through cooling systems, has not endangered fish populations or been 32 found to be a problem at operating nuclear power plants with cooling towers or 33 cooling ponds, and is not expected to be a problem during the license renewal 2

NPDES stands for National Pollutant Discharge Elimination System; in the case of IP2 and IP3, the NPDES required permit is issued by the New York State Department of Environmental Conservation (NYSDEC) and the NRC staff refers to it as the State's Pollutant Discharge Elimination System (SPDES) throughout this SEIS.

NUREG-1437, Supplement 38 4-4 December 2010 OAGI0001367A_00221

Environmental Impacts of Operation 1 term.

2

  • Thermal plume barrier to migrating fish. Based on information in the GElS, the 3 Commission found the following:

4 Thermal plumes have not been found to be a problem at operating nuclear power 5 plants and are not expected to be a problem during the license renewal term.

6

  • Distribution of aquatic organisms. Based on information in the GElS, the Commission 7 found the following:

8 Thermal discharge may have localized effects but is not expected to affect the 9 larger geographical distribution of aquatic organisms.

10

  • Premature emergence of aquatic insects. Based on information in the GElS, the 11 Commission found the following:

12 Premature emergence has been found to be a localized effect at some operating 13 nuclear power plants but has not been a problem and is not expected to be a 14 problem during the license renewal term.

15

  • Gas supersaturation (gas bubble disease). Based on information in the GElS, the 16 Commission found the following:

17 Gas supersaturation was a concern at a small number of operating nuclear 18 power plants with once-through cooling systems but has been satisfactorily 19 mitigated. It has not been found to be a problem at operating nuclear power 20 plants with cooling towers or cooling ponds and is not expected to be a problem 21 during the license renewal term.

22

  • Low dissolved oxygen in the discharge. Based on information in the GElS, the 23 Commission found the following:

24 Low dissolved oxygen has been a concern at one nuclear power plant with a 25 once-through cooling system but has been effectively mitigated. It has not been 26 found to be a problem at operating nuclear power plants with cooling towers or 27 cooling ponds and is not expected to be a problem during the license renewal 28 term.

29

  • Losses from predation, parasitism, and disease among organisms exposed to sublethal 30 stresses. Based on information in the GElS, the Commission found the following:

31 These types of losses have not been found to be a problem at operating nuclear 32 power plants and are not expected to be a problem during the license renewal 33 term.

34

  • Stimulation of nuisance organisms (e.g., shipworms). Based on information in the GElS, 35 the Commission found the following:

36 Stimulation of nuisance organisms has been satisfactorily mitigated at the single December 2010 4-5 NUREG-1437, Supplement 38 OAGI0001367A_00222

Environmental Impacts of Operation 1 nuclear power plant with a once-through cooling system where previously it was 2 a problem. It has not been found to be a problem at operating nuclear power 3 plants with cooling towers or cooling ponds and is not expected to be a problem 4 during the license renewal term.

5

  • Noise. Based on information in the GElS, the Commission found the following:

6 Noise has not been found to be a problem at operating plants and is not 7 expected to be a problem at any plant during the license renewal term.

8 The NRC staff identified no new and significant information related to these issues during its 9 independent review (including information provided from Entergy's ER, the NRC staff's site 10 audit, the scoping process, the SPDES permits for IP2 and IP3 that expired in 1992 and have 11 since been administratively continued, the subsequent draft permit, ongoing Hudson River 12 monitoring programs and their results, comments on the Draft SEIS, and other available 13 information). Therefore, the NRC staff expects that there would be no impacts during the 14 renewal term beyond those discussed in the GElS.

15 The Category 2 issues (issues that the NRC staff must address in a site-specific review based 16 on the framework established in the GElS) related to cooling system operation during the 17 renewal term that are applicable to IP2 and IP3 are discussed in the sections that follow and are 18 listed in Table 4-2.

19 Table 4-2. Site-Specific (Category 2) Issues Applicable to the Operation of the IP2 and IP3 20 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 21 For power plants with once-through cooling systems, the NRC considers the impingement and 22 entrainment of fish and shellfish and thermal impacts from nuclear power plant cooling systems 23 to be site-specific (Category 2) issues for license renewal. The NRC staff reviewed the 24 applicant's ER (Entergy 2007a), visited the plant site, and reviewed the applicant's existing and 25 draft SPDES permits, fact sheets describing it, and the NYSDEC permit renewal process 26 (NYSDEC 2003b). The NRC staff also reviewed relevant scientific publications, technical 27 articles, and compilations associated with the study area, as well as documents and technical 28 reports from NYSDEC, the National Marine Fisheries Service (NMFS), and other sources.

29 The SPDES permit for the Indian Point site, which addresses discharge from the currently 30 operating IP2 and IP3, as well as the shutdown IP1 unit, was administratively continued by 31 NYSDEC since a timely SPDES permit renewal application was filed 180 days prior to the 32 current permit's stated expiration date of April 3, 1992. That permit remains in effect while NUREG-1437, Supplement 38 4-6 December 2010 OAGI0001367A_00223

Environmental Impacts of Operation 1 NYSDEC administrative proceedings continue.

2 Section 316(b) of the Clean Water Act of 1997 (CWA) (Title 33, Section 1326, of the United 3 States Code (33 USC 1326)) requires that the location, design, construction, and capacity of 4 cooling water intake structures reflect the best technology available for minimizing adverse 5 environmental impacts. In the fact sheet for the site's draft SPDES permit, NYSDEC states that 6 it has determined that the site-specific best technology available to minimize the adverse 7 environmental impacts of the IP Units 1,2, and 3 cooling water intake structures is closed-cycle 8 cooling (NYSDEC 2003b). Under the terms of the draft SPDES permit, NYSDEC (2003b) states 9 that it will evaluate proposals from Entergy to institute alternative methods to avoid adverse 10 environmental impacts. Given NYSDEC's statements in the proposed SPDES permit, the NRC 11 staff decided to consider the environmental impacts that may occur if Entergy institutes closed-12 cycle cooling at IP2 and IP3-as well as the environmental impacts of a possible alternative 13 method of reducing impacts to aquatic life-in Chapter 8 of this SEIS. In the following sections, 14 the NRC staff addresses impacts from the current cooling system.

15 Applicant Assessment 16 In the draft environmental impact statement (DEIS) for the SPDES permits for IP2 and IP3, 17 Roseton, and the Bowline Point generating stations (CHGEC et al. 1999), as well as in the IP2 18 and IP3 ER (Entergy 2007a), the plant owner or owners (lP2 and IP3 had separate owners in 19 1999) acknowledged that some impinged fish survive and others die. Mortality can occur 20 immediately or at a later time. The DEIS examined impingement effects by evaluating 21 conditional mortality rates (CMR) and trends (through 1997) associated with population 22 abundance for eight selected taxa representing 90 percent of those fish species collected from 23 screens at IP2 and IP3. These included striped bass, white perch, Atlantic tomcod, American 24 shad, bay anchovy, alewife, blueback herring, and spottail shiner. Estimates of CMR, defined 25 as the fractional reduction in the river population abundance of the vulnerable age group caused 26 by a single source of mortality (in this case impingement) were assumed to be the same as or 27 lower than that which occurred in the years before installation of modified Ristroph screens and 28 fish return systems at IP2 and IP3 in 1991. For species exhibiting low impingement mortality 29 (e.g., striped bass, white perch, and Atlantic tomcod), future impingement effects were expected 30 to be substantially lower than they were before installation and use of modified Ristroph screens 31 and fish return systems.

32 The Hudson River electric-generating utilities (CHGEC et al. 1999) estimated the maximum 33 expected total impingement CMR for white perch and other taxa to quantify impact to the 34 species. In the ER, Entergy (2007a) stated that the results of in-river population studies 35 performed from 1974 to 1997 did not show any negative trend in overall aquatic river species 36 populations attributable to plant operations. The ER also stated that ongoing population studies 37 continued to support these conclusions. Thus, the applicant asserted that impingement impacts 38 were SMALL and did not warrant further mitigation measures. In support of this assessment, 39 the applicant provided two reviews (Barnthouse et al. 2002, 2008) in addition to the DEIS 40 (CHGEC et al. 1999).

41 Regarding entrainment, the applicant concluded that population studies performed from 1974 42 through 1997 have not shown any negative trend in overall aquatic populations attributable to 43 plant operations and that current mitigation measures will ensure that entrainment impacts 44 remain SMALL during the license renewal term. Therefore, the applicant asserted (Entergy December 2010 4-7 NUREG-1437, Supplement 38 OAGI0001367A_00224

Environmental Impacts of Operation 1 2007a) that continued operation of once-through cooling at the site "does not have any 2 demonstrable negative effect on representative Hudson River fish populations nor does it 3 warrant further mitigation measures." Barnthouse et al. (2008) used an ecological risk 4 assessment approach to evaluate the potential for adverse impacts to the representative 5 important species (RIS) of the Hudson River from a variety of natural and anthropogenic 6 stressors, including the operation of the IP2 and IP3 cooling water intake system, fishing 7 pressure, the presence of zebra mussels, predation by striped bass, and water temperature.

8 The authors concluded that operation of the IP2 and IP3 cooling met the NRC criteria for a 9 SMALL impact level.

10 NYSDEC Assessment 11 Under the CWA, the U.S. Environmental Protection Agency (EPA) has delegated authority for 12 the NPDES permit and Water Quality Certification programs in the State of New York to 13 NYSDEC. The regulatory role of NYSDEC in the operation of the IP2 and IP3 cooling system 14 includes protecting aquatic resources from impacts associated with impingement, entrainment, 15 and thermal and chemical discharges through issuance of State (SPDES) permits and other 16 means. As indicated above, the SPDES permit for IP2 and IP3 has been administratively 17 continued under provisions of the New York State Administrative Procedure Act. Regarding 18 Section 316(b) of the CWA and New York Code, Rules and Regulations, Section 704.5 19 (6 NYCRR Section 704.5), NYSDEC (2003b) has determined that the site-specific best 20 technology available to minimize the adverse environmental impact of the IP1, IP2, and IP3 21 cooling water intake structures is closed-cycle cooling.

22 In 2003, NYSDEC developed a final environmental impact statement (FEIS) (NYSDEC 2003a) 23 in response to the DEIS submitted by the operators of IP2 and IP3, Roseton, and Bowline Point 24 (CHGEC et al. 1999). In the FEIS, NYSDEC noted that "while the DEIS was acceptable as an 25 initial evaluation and assessment, it was not sufficient to stand as the final document, and 26 additional information as to alternatives and evaluation of impacts must be considered." In 27 responding to public comments on the DEIS (CHGEC et al. 1999), NYSDEC noted that, in 28 contrast to the utilities' assertions that the Hudson River fish community is healthy and robust, 29 changes in "total species richness and diversity suggest that the Hudson estuary ecosystem is 30 far from equilibrium." NYSDEC points out that the approach used by the utilities assumes 31 "selected cropping" of individual fish species while "the impacts associated with power plants 32 are more comparable to habitat degradation; the entire natural community is impacted" because 33 entrainment, impingement, and warming of the water simultaneously affect the entire aquatic 34 community of organisms. Emphasizing a more ecological approach, NYSDEC detailed the 35 importance of food webs, trophic and other interspecies relationships, and ecosystem 36 functioning.

37 NYSDEC (2003a) also stated that, while the changes to the IP2 and IP3 cooling system, 38 including the use of dual-speed and variable-flow pumps and the installation of modified 39 Ristroph traveling screens, "represent some level of improvement compared to operations with 40 no mitigation or protection, there are still significant unmitigated mortalities from entrainment 41 and impingement at all three of the Hudson River Settlement Agreement (HRSA) facilities."

42 NYSDEC (2003a) concluded that the millions of fish killed by impingement, entrainment, and 43 thermal effects at the HRSA power plants represent a significant source of mortality and stress 44 on the Hudson River's fish community and must be taken into account when assessing the 45 observed fish population declines. To help mitigate such losses, the NYSDEC (2003b) fact NUREG-1437, Supplement 38 4-8 December 2010 OAGI0001367A_00225

Environmental Impacts of Operation 1 sheet for the draft SPDES permit states that "This permit does not require the construction of 2 cooling towers unless: (1) the applicant seeks to renew its NRC operating licenses, (2) the NRC 3 approves extension of the licenses, and determines that the installation and operation of closed-4 cycle cooling is feasible and safe, and (3) all other necessary Federal approvals are obtained."

5 Furthermore, NYSDEC states that if the NRC grants extensions of the operating licenses, Indian 6 Point would have to submit for NYSDEC approval a revised construction schedule for closed-7 cycle cooling.

8 NYSDEC, in Section 1, "Biological Effects," of Attachment B to the 2003 SPDES fact sheet 9 (NYSDEC 2003b), states that operation of IP2 and IP3 results in the mortality of more than a 10 billion fish of various lifestages per year and that losses are distributed primarily among seven 11 species, including bay anchovy, striped bass, white perch, blueback herring, Atlantic tomcod, 12 alewife, and American shad. Of these, NYSDEC indicates that the populations of Atlantic 13 tomcod, American shad, and white perch are known to be declining in the Hudson River and 14 considers current losses to be substantial.

15 Studies have also been conducted to detect trends of fish populations in the Hudson River.

16 Both the applicant and NYSDEC have used the results of these studies to assess the potential 17 for adverse effects associated with the operation of the IP2 and IP3 cooling system. The results 18 of these assessments are described below. Some nongovernmental organizations (NGOs) and 19 citizens have also evaluated publicly available information and data associated with the Hudson 20 River and have expressed the opinion that many species of fish in the Hudson River are in 21 decline and that the entrainment and impingement of alilifestages of fish and shellfish at IP2 22 and IP3 is contributing to the decline of these important aquatic resources.

23 On April 2, 2010, NYSDEC issued a Notice of Denial regarding the Clean Water Act Section 24 401 Water Quality Certification for IP2 and IP3. Entergy has since requested a hearing on the 25 issue, and the matter will be decided through NYSDEC's hearing process.

26 NRC Assessment 27 Because the draft SPDES permit (which includes NYSDEC's 316(b) determination regarding the 28 cooling water intake structure) is subject to ongoing adjudication, the NRC staff conducted an 29 independent impact analysis for the purpose of addressing the Category 2 issues identified in 30 Table 4-2 of this SEIS. The operation of the IP2 and IP3 cooling system can directly affect the 31 aquatic communities of the Hudson River through impingement, entrainment, and thermal 32 releases. Evaluating the potential for adverse impacts of the cooling system to the aquatic 33 resources of the Hudson River estuary presents a significant challenge for three primary 34 reasons:

35 (1) The potential stressor of interest (the IP2 and IP3 cooling system) occupies a fixed 36 position on the Hudson River, while many of the RIS that the NRC staff have chosen for 37 evaluation have the freedom to move up- and down-river during different stages in their 38 growth and development, during different seasons of the year, and, in some cases, at 39 different times of day.

40 (2) The Hudson River estuary is a dynamic, open-ended system containing a complex food 41 web that extends from the freshwater portion of the river downstream of the Troy Dam to 42 the Atlantic Ocean. Detectable changes in RIS populations may be influenced by 43 natural stressors or may be the result of stressors associated with human activities, 44 which include the operation of IP2 and IP3.

December 2010 4-9 NUREG-1437, Supplement 38 OAGI0001367A_00226

Environmental Impacts of Operation 1 (3) Because the Hudson River estuary represents a complex system with hundreds of 2 aquatic species, the NRC staff chose to focus its analysis of impact on a subset of RIS 3 historically used to monitor the lower Hudson River (as indicated in Section 2.2.5.4 of 4 this SEIS). By focusing on a subset of species that are representative of many of the 5 species that exist in the lower Hudson River fish community, the NRC staff can more 6 easily analyze impacts to the Hudson River community, and the NRC staff can make use 7 of a large body of sampling data compiled over many years. The NRC staff 8 acknowledges that the simplification inherent in relying on RIS may introduce some 9 additional uncertainty, but the NRC staff finds that the utility of the RIS approach (due to 10 the availability of large, long-term data sets; applicability to species with similar 11 characteristics; and comparability to other Hudson River studies) in evaluating 12 communitywide effects outweighs the uncertainties associated with using it.

13 Because impingement and entrainment are fundamentally linked, the NRC staff determined that 14 the effects of each should be assessed using an integrated approach, described in 15 Section 4.1.3 of this SEIS. The NRC staff assessed thermal impacts separately in 16 Section 4.1.4. Because the analysis of the environmental impacts associated with the IP2 and 17 IP3 cooling system is complex, the NRC staff provides summary results, analyses, and 18 conclusions in this chapter, and provides a complete discussion of the environmental impact 19 assessment in Appendix H, with supporting statistical analyses in Appendix I to this SEIS.

20 4.1.1 Impingement of Fish and Shellfish 21 Impingement occurs when organisms are trapped against cooling water intake screens or racks 22 by the force of moving water. Impingent can kill organisms immediately or contribute to a 23 slower death resulting from exhaustion, suffocation, injury, or exposure to air when screens are 24 rotated for cleaning. The potential for injury or death is generally related to the amount of time 25 an organism is impinged, its susceptibility to injury, and the physical characteristics of the 26 screenwashing and fish return system that the plant operator uses. In this section, the NRC staff 27 provides a summary assessment of impingement impacts based on the NRC staff analyses of 28 available data. More details appear in Appendix H.

29 The NRC staff employed a weight-of-evidence (WOE) approach during the development of the 30 draft SEIS to evaluate the effects of the IP2 and IP3 cooling system on the aquatic resources of 31 the Hudson River estuary. The WOE consisted of two lines of evidence: (1) long-term 32 population trends of RIS that live in the Hudson River and (2) strength of connection, defined by 33 the staff as the potential for the operation of the IP2 and IP3 cooling system to directly affect 34 aquatic resources of interest. In this SEIS, the NRC staff modified and refined some aspects of 35 the WOE to provide a better assessment of the potential for adverse effects to aquatic 36 resources in response to public comments received on the draft SEIS. The major changes from 37 the draft SEIS to this SEIS included a more straightforward, simplified approach to assessing 38 RIS population trends and the use of Monte Carlo population simulations to assess the strength 39 of connection. The NRC staff also removed the coastal population trend information from the 40 WOE but used it as ancillary information for RIS population trend discussions. Section 4.1.3 41 describes an overview of the modified WOE approach; Appendixes H and I contain specific 42 details of the final analyses. Other changes in the final analysis were the use of updated 43 environmental data from the operation of IP2 and IP3, which the applicant provided after the 44 publication of the draft SEIS to replace previously submitted information that contained errors.

NUREG-1437, Supplement 38 4-10 December 2010 OAGI0001367A_00227

Environmental Impacts of Operation 1 Thus, the data, analysis, and conclusions presented in this SEIS reflect modifications to the 2 WOE analysis and the corrected information provided by the applicant.

3 Impingement monitoring at IP2 and IP3 was conducted by former plant owners and their 4 contractors between 1975 and 1990 using a variety of techniques, as summarized in Appendix 5 H of this SEIS. The NRC staff assessment for the effects of cooling water system operation 6 concentrated on 18 RIS identified in Section 2.2.5.4, which include the 17 species identified in 7 the Hudson River utilities' DEIS (CHGEC et al. 1999) for assessing power plant effects plus the 8 Atlantic menhaden (Brevoortia tyranus), a member of the herring family whose young are 9 common inhabitants of the lower Hudson River. All but one RIS are fish; the exception is the 10 blue crab (Callinectes sapidus). The estimated number of impinged RIS made up greater than 11 90 percent of all impinged taxa for all but one year at IP2 (Figure 4-1); at IP3, the estimated 12 number of RIS impinged was greater than 85 percent for all but one year (Figure 4-2). To 13 assess impingement impacts, the NRC staff analyzed weekly estimated impingement numbers 14 at IP2 and IP3 from January 1975 to November 1980 and seasonally estimated impingement 15 numbers from January 1981 to December 1990. (The former plant owners and their contractors 16 based estimated numbers on sampling data.) The combined numbers of young of the year 17 (YOY), yearling, and older fish were used for analysis since these data were available for all 18 years of sampling.

December 2010 4-11 NUREG-1437, Supplement 38 I OAGI0001367A_00228

Environmental Impacts of Operation 100% ......................................... . 5.0 "C

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- t - RIS Fish ---0-- RIS Fish+Blue Crab --------- Total Impinged Unit 2 1 Figure 4-5, Percentage of impingement of RIS fish and RIS fish plus blue crab relative to 2 the estimated total impingement at IP2 (data from Entergy 2007b and 2009) 3 4

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- t - - RIS Fish RIS Fish+Blue Crab --------, Total Impinged Unit 3 15 16 Figure 4-2, Percentage of impingement composed of RIS fish and RIS fish plus blue crab 17 relative to the estimated total impingement at IP3 (data from Entergy 2007b and 2009) 18 I NUREG-1437, Supplement 38 4-12 December 2010 OAGI0001367A_00229

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 shown in Figures 4-1 and 4-2). If the IP2 and IP3 cooling systems are considered 4 a 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 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). As it was not required by 20 NYSDEC, no further monitoring of impingement rates or impingement mortality estimates was 21 conducted after the new Ristroph screens were installed at IP2 and IP3 in 1991.

22 Table 4-3. Cumulative Mortality and Injury of Selected Fish Species after Impingement on 23 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 4 of the 26 10 species exceeds 25 percent. Monitoring data (Entergy 2007b and 2009), reviewed by NRC 27 staff) also showed that impingement was greater at IP2 than at IP3 and that impingement has 28 generally declined since 1976. Although IP2 and IP3 currently employ modified Ristroph December 2010 4-13 NUREG-1437, Supplement 38 OAGI0001367A_00230

Environmental Impacts of Operation 1 screens and fish return systems to increase the survival rates of impinged organisms, since 2 impingement monitoring was required by NYSDEC after 1990, the actual improvements in fish 3 survival after installation of these systems at IP2 and IP3 have not been established 4 (impingement monitoring last occurred in 1990). In Section 4.1.3 of this SEIS, the NRC staff 5 includes impingement results in a weight-of-evidence (WOE) analysis to evaluate the overall 6 impacts of the IP2 and IP3 cooling system on lower Hudson River RIS.

7 4.1.2 Entrainment of Fish and Shellfish in Early Lifestages 8 Entrainment occurs when small aquatic life forms are carried into and through the cooling 9 system during water withdrawals. Entrainment primarily affects organisms with limited 10 swimming ability that can pass through the screen mesh, which is typically 0.25 to 0.5 inch (in.)

11 (6.35 to 12.7 millimeters (mm)), used on the intake systems. Organisms typically entrained 12 include phytoplankton, zooplankton, and the eggs, larvae, and juvenile forms of many of the fish 13 and invertebrates.

14 Once entrained, organisms pass through the circulating pumps and are carried with the water 15 flow through the intake conduits toward the condenser units. They are then drawn through one 16 of the many condenser tubes used to cool the turbine exhaust steam (where cooling water 17 absorbs heat) and then enter the discharge canal for return to the Hudson River. As entrained 18 organisms pass through the intake they may be injured from abrasion or compression. Within 19 the cooling system, they encounter physical impacts in the pumps and condenser tubing; 20 pressure changes and shear stress throughout the system; thermal shock within the condenser; 21 and exposure to chemicals, including chlorine and residual industrial chemicals discharged at 22 the diffuser ports (Mayhew et al. 2000). Death can occur immediately or at a later time from the 23 physiological effects of heat, or it can occur after organisms are discharged if stresses or 24 injuries result in an inability to escape predators, a reduced ability to forage, or other 25 impairments.

26 Studies to evaluate the effects of entrainment at IP2 and IP3 conducted since the early 1970s 27 employed a variety of methods to assess actual entrainment losses and to evaluate the survival 28 of entrained organisms after they are released back into the environment by the once-through 29 cooling system (see Appendix H for a more-detailed discussion). Despite increasingly refined 30 study techniques, entrainment survival estimates were compromised by poor ichthyoplankton 31 survival in control samples, and entrainment survival for many species is still unresolved. The 32 variability of entrainment data informed the NRC staff's decision to employ a WOE approach.

33 To assess the effects of entrainment on the aquatic resources of the lower Hudson River, the 34 NRC staff evaluated weekly average densities of entrained taxa for a given life stage for IP2 and 35 IP3 from data provided by the applicant. The NRC staff then multiplied the mean weekly 36 densities by the volume of circulated water to estimate the weekly number of organisms 37 entrained for a given life stage, and then calculated the sum over weeks and life stage of the 38 numbers entrained per taxa and season.

39 The entrainment monitoring data provided Entergy (2007b) contained 66 taxa. Blue crabs, 40 shortnose and Atlantic sturgeon, and gizzard shad were not present in the 1981-1987 41 entrainment data. Some RIS data included taxa identified only to family or genus (e.g., anchovy 42 family, Alosa spp., and Morone spp.) because the identification of early life stages for these 43 groups is difficult. As shown in Figure 4-3, RIS fish represented greater than 70 percent of all NUREG-1437, Supplement 38 4-14 December 2010 OAGI0001367A_00231

Environmental Impacts of Operation 1 entrainment, except for 2 weeks in 1984 and 1985 (1 week in May and 1 in June) for which 2 amphipods (Gammarus spp.) were present. The total number of identified fish entrained has 3 decreased at a rate of 187 billion fish per year since 1984. This result is consistent with the 4 decrease observed in the number of fish impinged (Figures 4-1 and 4-2).

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-+- % RIS Fish - % Total Identified Fish --------. Total Number Entrained 19 Figure 4-3. Percentage of entrainment of RIS fish and total identified fish relative to the 20 estimated total entrainment at IP2 and IP3 combined (data from Entergy 2007b) 21 4.1.3 Combined Effects of Impingement and Entrainment 22 The NRC staff used a modified WOE approach to evaluate whether the impingement and 23 entrainment that occur during the operation of the IP2 and IP3 cooling system has the potential 24 to adversely affect RIS in the lower Hudson River. The NRC staff followed a WOE approach 25 (Figure 4-4) adapted from the process described in Menzie et al. (1996), which defines WOE as 26 " ... the process by which multiple measurement endpoints are related to an assessment endpoint 27 to evaluate whether significant risk of harm is posed to the environment." The NRC staff 28 describes the specific steps used in its WOE approach in the sections that follow, and provides 29 a detailed discussion of its WOE process in Appendix H.

December 2010 4-15 NUREG-1437, Supplement 38 I OAGI0001367A_00232

Environmental Impacts of Operation 1

2 3 General weight-ot-evidence approach employed to assess the level ot impact to 4 population trends attributable to IP cooling system operation 5 Step 1: Identify the Environmental Component or Value to Be Protected 6 For this assessment, the environmental component to be protected is the Hudson River aquatic 7 resources as represented by the 18 RIS identified in Table 2-4. These species represent a 8 variety of feeding strategies and food web classifications and are ecologically, commercially, or 9 recreationally important. The WOE approach focuses primarily on the potential impacts to 10 young-of-the-year (YOY) and yearling fish and their food sources. The long-term sampling 11 programs of the Hudson River, on which this analysis is based, focused on these early 12 lifestages. Although eggs and larval forms are important components to the food web, the 13 natural mortality to these lifestages is high. In contrast, fish surviving to the YOY stage and 14 older are more likely to add to the adult breeding population and are at greater risk from the 15 cooling system operation. Any factor that decreases (or increases) the survival of those fish 16 during juvenile and yearling stages can affect the sustainability of the population.

17 Step 2: Identify Lines of Evidence and Quantifiable Measurements 18 The goal of this step is to identify data sets and information that can be used to assess the 19 potential for adverse environmental effects and determine whether the IP2 and IP3 cooling NUREG-1437, Supplement 38 4-16 December 2010 OAGI0001367A_00233

Environmental Impacts of Operation 1 system is contributing to the effect. The NRC staff developed two lines of evidence (LOE) to 2 evaluate impacts. The first LOE was the long-term population trends of RIS species in the 3 lower Hudson River which staff used to determine whether any populations were declining.

4 The second LOE was a measure of the potential for the operation of the IP2 and IP3 cooling 5 system to directly affect aquatic resources of interest (strength of connection). The NRC staff 6 required the occurrence of a detectable population decline and the presence of a high strength 7 of connection to declare an adverse impact to an RIS. To support these analyses, the NRC 8 staff used data provided by the applicant including impingement and entrainment monitoring 9 data obtained from the IP2 and IP3 facility and data from the lower Hudson River collected 10 during the Long River Survey (LRS), Fall Juvenile/Fall Shoals Survey (FJS/FSS), and Beach 11 Seine Survey (BSS)(Table 2-3). Appendix H contains a summary of measurements for each 12 LOE 13 Step 3: Quantify the Use and Utility of Each Measurement.

14 The following attributes of each measurement within each LOE were assigned an ordinal score 15 corresponding to a ranking of its use and utility of low, medium, or high:

16

  • Strength of Association: The extent to which the measurement is representative of, 17 correlated with, or applicable to the RIS.

18

  • Stressor-specificity: The extent to which the measurement is associated with a specific 19 stressor or the extent to which the data used in the assessment relate to the stressor of 20 interest.

21

  • Site-specificity: The extent to which data used in the assessment relate to the site of 22 interest.

23

  • Sensitivity of the Measurement: The ability of the measurement to detect a response.

24

  • Spatial Representativeness: The degree of compatibility between the study area and 25 the location of measurements, known stressors, and biological receptors.

26

  • Temporal Representativeness: The degree of compatibility between the measurement 27 and the time period during which effects are expected to occur.

28

  • Correlation of Stressor to Response: The degree of correlation between the levels of 29 exposure to a stressor and levels of response observed in the measurement.

30 The NRC staff then calculated overall use and utility scores for each measurement for the 31 population LOE as the average of the individual attribute rankings. The NRC staff did not apply 32 use and utility to the strength of connection LOE because it is semi-quantitative. The scores for 33 each LOE are available in Appendix H.

34 Step 4: Develop Quantifiable Decision Rules for Interpreting the Results of Each Measurement 35 The NRC staff developed decision rules for the first LOE to determine the historical trends in 36 lower Hudson River RIS populations. The NRC staff used a mathematical approach to integrate 37 the regression results (e.g., detected population decline) from each field survey to produce a 38 single conclusion for a given RIS population trend. Appendices H and I provide detailed December 2010 4-17 NUREG-1437, Supplement 38 I OAGI0001367A_00234

Environmental Impacts of Operation 1 discussions of how the decision rules were developed and used in the environmental 2 assessment. The possible outcomes of this analysis are as follows:

3

  • RIS populations were not declining if their population trends had slopes that were not 4 significantly less than zero (i.e., undetected population declines or detectable population 5 increases). This indicated that the RIS populations had not changed appreciably over 6 time, or were increasing.

7

  • RIS populations were declining if their population trends had slopes that were 8 significantly less than zero (i.e., detectable population decline).

9

  • RIS populations were variable if historical trend data were ambiguous (i.e., some data 10 showed detectable declines, whereas others did not).

11 The NRC staff applied these decision rules for each RIS species if sufficient data were available 12 to support a determination, but defined the level of impact "unresolved" if sufficient data were 13 not available.

14 The NRC staff developed decision rules for the second LOE to determine the strength of 15 connection between the operation of the IP2 and IP3 cooling system and the RIS in the lower 16 Hudson River. The NRC staff's measure of the strength of connection was based on the 17 magnitude of influence that impingement and entrainment by the IP2 and IP3 cooling system 18 had on the RIS population abundance with respect to its temporal viability. Specifically, the staff 19 used numerical model simulations to determine whether the difference in population 20 abundances with and without losses from impingement and entrainment was detectable relative 21 to annual population variability. The decision rules for this LOE were:

22

  • A low strength of connection occurred when model simulations showed that it was not 23 possible to detect differences in population abundance with and without impingement 24 and entrainment losses. In this case, the RIS population variability was too large to 25 enable detection of impingement and entrainment losses.

26

  • The NRC staff also defined the strength of connection as low if an RIS could not be 27 modeled with the Monte Carlo simulation because it occurred rarely in entrainment and 28 impingement samples. Appendixes H and I provide a complete description of this 29 process.

30

  • A high strength of connection occurred when model simulations showed that the 31 difference in population abundance with and without losses from impingement and 32 entrainment was detectable with respect to annual population variability. In this case, 33 the effects of impingement and entrainment were greater than the variability in the RIS 34 population trends.

35 Step 5: Integrate the Results and Assess Impact 36 The NRC staff used a mathematical approach to integrate the regression results (e.g., detected 37 population decline) from each of the field surveys to produce a single conclusion for a given RIS 38 population trend. The staff used a logic-based approach to integrate the conclusions from the 39 population trend LOE and the strength of connection LOE. NRC staff defined the IP2 and IP3 NUREG-1437, Supplement 38 4-18 December 2010 OAGI0001367A_00235

Environmental Impacts of Operation 1 cooling system impact as SMALL for a given RIS if the second LOE concluded that there was a 2 low strength of connection (i.e., no evidence that system operation was adversely influencing 3 long-term population trends). Staff also defined the cooling system impact as SMALL for a 4 given RIS if the first LOE concluded that there was not a detectable population decline even if 5 the second LOE concluded that there was a high strength of connection. In that case, the 6 losses of eggs, larvae, and YOY to the IP2 and IP3 cooling system were not sufficient to 7 noticeably reduce the RIS population over time. The staff defined the IP2 and IP3 cooling 8 system impact as MODERATE for a given RIS if the first LOE concluded that the RIS population 9 trend was variable and the second LOE concluded a high strength of connection. The staff 10 defined the cooling system impact as LARGE for a given RIS if the first LOE concluded that 11 there was a detectable population decline and the second LOE concluded that there was a high 12 strength of connection. Appendices H and I provide detailed descriptions of the process and 13 statistical analysis that the NRC staff used to reach these determinations. The final cooling 14 system impact assessments are consistent with the NRC guidelines for SMALL, MODERATE, 15 and LARGE potential for adverse impacts as defined below:

16 SMALL: Environmental effects are not detectable or are so minor that they will 17 neither destabilize nor noticeably alter any important attribute of the resource.

18 MODERATE: Environmental effects are sufficient to alter noticeably-but not to 19 destabilize-any important attributes of the resource.

20 LARGE: Environmental effects are clearly noticeable and are sufficient to 21 destabilize any important attributes of the resource.

22 What follows is the NRC staff assessment of the two LOE (population trends and strength of 23 connection) and a determination of impact associated with impingement and entrainment at IP2 24 and IP3 using the above definitions.

25 4.1.3.1 Assessment of Population Trends-The First Line of Evidence 26 The NRC staff used data from the LRS, FSS, and BSS studies of the lower Hudson River from 27 1974 to 2005, as described above, to assess population trends. Staff obtained data from the 28 applicant in electronic format including weekly catch density, an abundance index, total catch, 29 and sample volumes. The staff also calculated catch-per-unit-effort values as a ratio of the total 30 catch and sample volume. The NRC staff also used commercial and recreational harvest 31 statistics from the Atlantic States Marine Fisheries Commission (ASMFC) as ancillary 32 information to evaluate coastal population trends for striped bass, American shad, Atlantic 33 sturgeon, river herring, bluefish, Atlantic menhaden, and weakfish.

34 The NRC staff assessed YOY population trends in river segment 4 (the region of the lower 35 Hudson River where IP2 and IP3 are located) and the lower Hudson River from the Troy Dam to 36 the Battery (river-wide). The final WOE score reflects an integrated result for both 37 measurements (Table 4-4). The analysis showed that YOY American shad, Atlantic tomcod, 38 blueback herring, bluefish, hogchoker, spottail shiner, and white perch populations were 39 declining, and that bay anchovy and striped bass populations were not declining. Alewife, 40 rainbow smelt, weakfish, and white catfish exhibited variable population trends, meaning some 41 data showed detectable declines, whereas other data did not. Atlantic menhaden, Atlantic 42 sturgeon, gizzard shad, shortnose sturgeon, and blue crab showed unresolved population 43 trends because Hudson River monitoring programs did not collect enough of these species to December 2010 4-19 NUREG-1437, Supplement 38 OAGI0001367A_00236

Environmental Impacts of Operation 1 support statistically significant trend analyses. The impact on these species resulting from IP2 2 and IP3 operation under a renewed license is discussed in section 4.1.3.3 of the SEIS.

3 4.1.3.2 Assessment of Strength of Connection-The Second Line of Evidence 4 The NRC staff conducted strength of connection analyses to determine whether the operation of 5 the IP2 and IP3 cooling system had the potential to influence RIS populations near the facility or 6 within the lower Hudson River. Appendix H contains a summary of this analysis, and Appendix I 7 has detailed information on the analysis procedures.

8 The strength of connection analysis assumes that the IP2 and IP3 cooling system can affect 9 aquatic resources directly through impingement or entrainment or indirectly by impinging and 10 entraining potential food (prey). The NRC staff used model simulations to evaluate the 11 detectability of the influence of impingement and entrainment by the IP2 and IP3 cooling system 12 on the RIS population abundance relative to the population variability. YOY population densities 13 near Indian Point are inherently variable, and thus the effects of the cooling system operation on 14 a given population must be greater than the variability in the abundance of the population over 15 time for them to be detectable. The NRC staff compared population models that included 16 impingement and entrainment losses with modeled trends without such losses by running 17 multiple simulations of a given population trend with its associated variability.

18 The applicant acknowledged after the publication of the draft SEIS that the applicant and its 19 contractors had provided NRC staff electronic impingement data that contained errors. The 20 staff received updated information (verified as correct by the applicant) and used this 21 information to develop the Final SEIS. Thus, the impingement losses reported and conclusions 22 in the draft SEIS are revised in the FSEIS.

23 The population simulation analysis showed that alewife, bay anchovy, blueback herring, 24 hogchoker, rainbow smelt, spottail shiner, striped bass, weakfish, and white perch exhibited a 25 High strength of connection with operation of the IP2 and IP3 cooling system (Table 4-4). The 26 Monte Carlo model simulations predicted that the population abundances for those species 27 were detectibly smaller when impingement and entrainment losses were included than when 28 they were not. American shad, Atlantic menhaden, Atlantic sturgeon, Atlantic tomcod, bluefish, 29 gizzard shad, shortnose sturgeon, white catfish, and blue crab populations exhibited a Low 30 strength of connection. The Monte Carlo model simulations for those species could not detect a 31 difference in population size for scenarios with and without impingement and entrainment 32 losses, or those species rarely occurred in entrainment and impingement samples.

33 4.1.3.3 Impingement and Entrainment Impact Summary 34 The NRC staff used two lines of evidence (LOE to determine whether the operation of the IP2 35 and IP3 cooling system had the potential to cause adverse impacts to the RIS populations of the 36 lower Hudson River. The first LOE considered RIS population trends from long-term data sets; 37 the second considered the potential for the operation of the IP2 and IP3 cooling system to 38 influence RIS population abundance. The NRC staff integrated the results from these LOE to 39 determine the impacts of cooling system operation on RIS populations that are indicative of the 40 aquatic resources of the lower Hudson River.

41 Based on the WOE assessment (Table 4-4), the NRC staff concludes that impacts to American 42 shad, Atlantic menhaden, Atlantic sturgeon, Atlantic tomcod, bay anchovy, bluefish, gizzard 43 shad, shortnose sturgeon, striped bass, white catfish, and blue crab are SMALL. The NRC staff NUREG-1437, Supplement 38 4-20 December 2010 OAGI0001367A_00237

Environmental Impacts of Operation 1 concludes impacts to alewife, rainbow smelt and weakfish are MODERATE. The staff 2 concludes that impacts to blueback herring, hogchoker, spottail shiner, and white perch are 3 LARGE. The NRC staff used the river-wide abundance and CPUE data, and river segment 4 4 (Indian Point) density and CPUE information from FSS, BSS, and LRC studies for each RIS to 5 support population trend analysis. Section 4.1.3.4 provides a discussion of the uncertainty 6 associated with the impact analysis, and Section 4.1.3.5 presents the final integrated 7 assessment of the impact of the IP2 and IP3 cooling system for all RIS combined.

8 Large Impacts 9 Blueback Herring 10 The NRC staff concludes that a LARGE impact is present for YOY blueback herring because a 11 detectable population decline occurred in most of the river-wide (3 of 3) and river segment (2 of 12 3) data sets used in the analysis, and the strength of connection with the IP2 and IP3 cooling 13 system is high. Blueback herring, which along with alewife are known as river herring, share 14 many life history and distribution characteristics with alewife. An anadromous species, blueback 15 herring migrate upriver to spawn during the spring, and live about 7-8 years. This species feeds 16 primarily on insect larvae and copepods, and is prey for bluefish, weakfish, and striped bass 17 (Hass-Castro 2006). Hass-Castro (2006) also reports that river herring populations are well 18 below historic levels of the mid 20th century, possibly because of overfishing, habitat destruction, 19 and states that a population assessment has been listed as a high priority by the Atlantic States 20 Marines Fisheries Council (ASMFC), given that the blueback herring is listed as a species of 21 concern by the NMFS.

22 Hogchoker 23 The NRC staff concludes that a Large impact is present for YOY hogchoker because a 24 detectable population decline occurred in most of the river-wide (2 of 3) and river segment (3 of 25 3) data sets, and the strength of connection with the IP2 and IP3 cooling system is high. This 26 species is a right-eyed flatfish that occurs in the Hudson River estuary and surrounding bays 27 and coastal waters. Adults are generalists, and eat annelids, arthropods, and siphons of clams; 28 adults and juveniles are prey of striped bass. Coastal population trend data were not available 29 for this species.

30 Spottai/ Shiner 31 The NRC staff concludes that a Large impact is present for YOY spottail shiner because a 32 detectable population decline occurred in the river-wide (1 of 3) and river segment (1 of 1) data 33 sets, and the strength of connection with the IP2 and IP3 cooling system is high. The habitat for 34 the spottail shiner includes small streams, lakes, and large rivers, including the Hudson. This 35 species feeds primarily on aquatic insect larvae, zooplankton, benthic invertebrates, and fish 36 eggs and larvae, and is the prey of striped bass. Spottail shiners spawn from May to June or 37 July (typically later for the northern populations) over sandy bottoms and stream mouths (Smith 38 1985; Marcy et al. 2005); water chestnut (Trapa natans) beds provide important spawning 39 habitat (CHGEC 1999). Individuals older than 3 years are rare, although some individuals may 40 live 4 or 5 years (Marcy et al. 2005). Spottail shiner is not a marine or anadromous species, so 41 coastal population trend data are not available.

42 White Perch December 2010 4-21 NUREG-1437, Supplement 38 I OAGI0001367A_00238

Environmental Impacts of Operation 1 The NRC staff concludes that a large impact is present for YOY white perch because a 2 detectable population decline occurred in the majority of the river-wide (3 of 3) and river 3 segment (2 of 3) data sets, and the strength of connection with the IP2 and IP3 cooling system 4 is high. White perch is an estuarine species that is a year-round resident in the Hudson River 5 and is commonly entrained by IP2 and IP3. An opportunistic feeder, this species is prey to large 6 piscivorous fish and terrestrial vertebrates. Reported recreational and commercial landings in 7 the Hudson River have never been great, and commercial fishing was closed in 1976 because 8 of PCB contamination. In contrast to the Hudson River, white perch populations appear to be 9 relatively stable in the Maryland portion of Chesapeake Bay, and the commercial harvest has 10 generally increased since 1980 in that area (Maryland DNR 2005).

11 I NUREG-1437, Supplement 38 4-22 December 2010 OAGI0001367A_00239

Environmental Impacts of Operation 1 Table 4-4. Impingement and Entrainment Impact Summary for Hudson River YOY RIS Impacts of IP2 and IP3 Population Trend Strength of Connection Species Cooling Systems on Line of Evidence Line of Evidence YOYRIS Alewife Variable High Moderate American Shad Detected Decline Low Small Atlantic Menhaden Unresolved(a) Low(b) Small Atlantic Sturgeon Unresolved(a) Low(b) Small Atlantic Tomcod Detected Decline Low Small Bay Anchovy Undetected Decline High Small Blueback Herring Detected Decline High Large Bluefish Detected Decline Low Small Gizzard Shad Unresolved(a) Low(b) Small Hogchoker Detected Decline High Large Rainbow Smelt Variable High Moderate-Large(C)

Shortnose Sturgeon Unresolved(a) Low(b) Small Spottail Shiner Detected Decline High Large Striped Bass Undetected Decline High Small Weakfish Variable High Moderate White Catfish Variable Low Small White Perch Detected Decline High Large Blue Crab Unresolved(a) Low(b) Small (a) Population trend could not be established because of a lack of river survey data.

(b) Monte Carlo simulation could not be conducted because of the low rate of entrainment and impingement; a Low Strength of connection was concluded.

(c) Section 4.1.3.3 provides supplemental information.

2 Moderate Impacts 3 Alewife 4

5 The NRC staff concludes that a Moderate impact is present for YOY alewife because a 6 detectable population decline occurred in river segment 4 (3 out of 3 data sets) and the strength 7 of connection with the IP2 and IP3 cooling system is high. The NRC staff found that the 8 population trend results were variable because the declines observed in river segment 4 were 9 not confirmed by river- wide population trends. YOY alewife (river herring) are present in the 10 lower and upper reaches of the Hudson River and feed as juveniles primarily on amphipods, 11 zooplankton, and fish eggs and larvae, and, as adults on small fish. This species is also prey 12 for bluefish, weakfish, and striped bass. The ASMFC implemented a combined fisheries 13 management plan for American shad and river herring in 1985. Although the herring fishery is 14 one of the oldest fisheries in the United States, no commercial fishery for river herring currently 15 exists in the Hudson River. River herring population declines have been reported in 16 Connecticut, Rhode Island, and Massachusetts, and NMFS has listed river herring as a species 17 of concern throughout its range (Hass-Castro 2006).

18 December 2010 4-23 NUREG-1437, Supplement 38 I OAGI0001367A_00240

Environmental Impacts of Operation 1 Rainbow Smelt 2

3 The NRC staff concludes that the level of impact for rainbow smelt is MODERATE to LARGE 4 because detectable population declines occurred in river-wide (1 of 2) and river segment (1 of 2) 5 data sets and strength of connection with the IP2 and IP3 cooling system is high. Although 6 detectable population declines occurred in two of four river data sets, indicating population trend 7 results were variable, the staff concluded that a MODERATE to LARGE, rather than just 8 MODERATE, impact was present based on the dramatic population declines observed for this 9 species over the past three decades. Rainbow smelt is an anadromous species once 10 commonly found along the Atlantic Coast. Larval and juvenile smelt feed primarily on planktonic 11 crustaceans; adults eat crustaceans, polychaetes, and small fish. Bluefish and striped bass are 12 primary predators of rainbow smelt. Once a prevalent fish in the Hudson River, the rainbow 13 smelt has undergone an abrupt population decline in the Hudson River since 1994, and the 14 species may no longer have a viable population within the Hudson River. The last tributary run 15 of rainbow smelt was recorded in 1988, and the Hudson River Utilities' Long River 16 Ichthyoplankton Survey showed that PYSL essentially disappeared from the river after 1995 17 (Daniels et al. 2005). The NRC staff's regression analysis of rainbow smelt population trends 18 was affected by the lack of rainbow smelt caught by the Hudson River field surveys after 1995.

19 Detectable population declines were present for CPUE data set but not for density or 20 abundance index data, given the disappearance of this species from the Hudson river. Thus, 21 the WOE conclusion of moderate impact may, in fact, be an underestimate of the true impact.

22 Therefore, the staff concluded that a MODERATE to LARGE impact assessment was more 23 appropriate.

24 25 Weakfish 26 27 The NRC staff concludes that a MODERATE impact is present for weakfish because detectable 28 population declines occurred in river-wide (1 of 2) and river segment (1 of 2) data sets, and the 29 strength of connection with the IP2 and IP3 cooling system is high. Because detectable 30 declines occurred in two of four river data sets, staff determined that the population trend results 31 were variable. The weakfish is historically one of the most abundant fish species along the 32 Atlantic coast and is fished recreationally and commercially. Small weakfish prey primarily on 33 crustaceans, whereas larger individuals eat small fish. Bluefish, striped bass, and larger 34 weakfish are the primary predators of smaller weakfish. Weakfish are thought to be in decline 35 based on decreased commercial landings in recent years. The weakfish stock declined 36 suddenly in 1999 and approached even lower levels by 2003, which the ASMFC determined to 37 be because of higher natural mortality rates rather than fishing mortality (ASMFC 2007). A 38 leading hypothesis suggests that reduced prey availability and increased predation by striped 39 bass may contribute significantly to rising natural mortality rates in the weakfish population 40 (ASMFC 2007a).

41 4.1.3.4 Discussion of Uncertainty 42 This analysis generally follows the EPA (1998) guidelines for ecological risk assessment. In 43 reporting risks of adverse effects, EPA (1998) recommends that practitioners acknowledge and 44 summarize the major areas of uncertainty in their analyses. Uncertainty, as described by EPA, 45 has many sources. The two lines of evidence in NRC's WOE approach have different sources 46 of uncertainty.

NUREG-1437, Supplement 38 4-24 December 2010 OAGI0001367A_00241

Environmental Impacts of Operation 1 NRC's population trends line of evidence (LOE-1) applies statistical tests to determine if YOY 2 RIS populations have remained stable over time or have declined. The Hudson River utilities 3 had collected the data used to assess aquatic RIR population trends continuously over three 4 decades from a variety of locations along the Hudson River using standard protocols. They had 5 applied accepted principles of experimental design and accepted sampling protocols. Over the 6 years, they conducted special studies to resolve uncertainties identified in review of the studies 7 by NYSDEC and others. They reported methods and results including both means and 8 variances or other measures of central tendency and uncertainty. The NRC staff considers the 9 data to be of high quality with minimal or known uncertainties and both useful and relevant for 10 NRC's WOE analysis. A gear change in the FSS introduced an unquantifiable source of 11 uncertainty in the RIS population trend results. The NRC applied analytic methods to minimize 12 possible bias, but gear changes in monitoring programs almost always introduce uncertainties.

13 The NRC's strength of connection line of evidence (LOE-2) incorporates estimates of 14 conditional mortality rate in Monte Carlo analyses to simulate changes in population trends with 15 and without entrainment and impingement. The NRC calculated the conditional entrainment 16 mortality rate and used estimates of conditional impingement mortality rate calculated by 17 Entergy consultants. Both have quantifiable estimates of uncertainty. NRC provides the 18 statistical basis for determining if simulated changes in population trends with and without 19 entrainment and impingement differ. An unquantifiable source of uncertainty arises from the 20 lack of studies at IP2 and IP3 since 1990 and 1987, respectively, confirming reductions of 21 impingement mortality rates from improvements made to the IP2 and IP3 Ristroph screens and 22 fish return system that appeared to reduce impingement mortality for some species in a pilot 23 study (Fletcher 1990). The conditional impingement mortality rates used in NRC's analysis 24 include adjustment for partial survival associated with the installation of Ristroph screens at IP2 25 and IP3.

26 NRC followed recommendations of the Massachusetts Weight-of-Evidence Workgroup (Menzie 27 et al. 1996) in describing the overall value, use and utility, and uncertainties associated with the 28 overall WOE approach. Consistent with Menzie et al. (1996), NRC staff used professional 29 judgment to select and refine WOE methods before analyzing data and documented all steps 30 (see Appendices H and I) to allow interested readers to gain an understanding of the 31 assumptions, limitations, and uncertainties associated with this assessment. The NRC staff 32 has also employed a similar methodology to assess effects of power plant operation on fish 33 populations in its GElS Supplement 22, regarding Millstone Power Station, Units 2 and 3 (NRC 34 2005). The NRC's staff's findings for impact from impingement and entrainment at IP2 and IP3, 35 as described in Table 4-4, represent the NRC staff's best estimates based on the WOE derived 36 from the available data and they contain both quantifiable and unquantifiable uncertainties.

37 4.1.3.5 Overall Impingement and Entrainment Impact 38 Because the WOE assessment results can be expressed numerically with respect to IP2 and 39 IP3 adverse impacts (e.g. small adverse impacts = 1, moderate impacts =2, large impacts =4),

40 it is possible to determine the overall impacts of the IP2 and IP3 cooling system using the WOE 41 impact summary conclusions presented in Table 4-4. This type of scoring is reflective of an 42 equally spaced interval on a logarithmic scale for which the magnitude of harm is doubled at 43 each step. The NRC staff used these scoring criteria to calculate an average for the 18 RIS 44 impact assessment results. Based on the assumption that the chosen RIS are representative 45 surrogates for the aquatic community important to the lower Hudson River, the NRC staff December 2010 4-25 NUREG-1437, Supplement 38 OAGI0001367A_00242

Environmental Impacts of Operation 1 concludes that the overall impact of the operation of IP2 and IP3 cooling systems to the aquatic 2 resources of the lower Hudson River is MODERATE during the relicensing period.

3 4.1.4 Heat Shock 4 As discussed in Chapter 2, thermal discharges associated with the operation of the once-5 through cooling water system for IP2 and IP3 are regulated by NYSDEC. Temperature 6 limitations are established and imposed on a case-by-case basis for each facility subject to 7 6 NYCRR Part 704.

8 Specific conditions associated with the extent and magnitude of thermal plumes are addressed 9 in 6 NYCRR Part 704 as follows:

10 (5) Estuaries or portions of estuaries.

11 (i) The water temperature at the surface of an estuary shall not be raised to more 12 than 90°F at any point.

13 (ii) At least 50 percent of the cross sectional area and/or volume of the flow of the 14 estuary including a minimum of one-third of the surface as measured from water 15 edge to water edge at any stage of tide, shall not be raised to more than 4 ° F over 16 the temperature that existed before the addition of heat of artificial origin or a 17 maximum of 83°F, whichever is less.

18 (iii) From July through September, if the water temperature at the surface of an 19 estuary before the addition of heat of artificial origin is more than an 83 ° F 20 increase in temperature not to exceed 1.5°F at any point of the estuarine 21 passageway as delineated above, may be permitted.

22 (iv) At least 50 percent of the cross sectional area and/or volume of the flow of 23 the estuary including a minimum of one-third of the surface as measured from 24 water edge to water edge at any stage of tide, shall not be lowered more than 2 5 4 ° F from the temperature that existed immediately prior to such lowering.

26 Thermal discharges associated with the operation of IP2 and IP3 are regulated under existing 27 SPDES permit NY-0004472. This permit imposes effluent limitations, monitoring requirements, 28 and other conditions to ensure that all discharges are in compliance with Title 8 of Article 17 of 29 the Environmental Conservation law (ECl) of New York State, 6 NYCRR Part 704, and the 30 CWA. Specific conditions of permit NY-0004472 related to thermal discharges from IP2 and IP3 31 are specified by NYSDEC (2003b) and include the following:

32

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

33

  • The daily average discharge temperature between April 15 and June 30 is not to exceed 34 93.2°F (34°C) for an average of more than 10 days per year during the term of the 35 permit, beginning in 1981, provided that it not exceed 93.2 ° F (34°C) on more than 15 36 days during that period in any year.

I NUREG-1437, Supplement 38 4-26 December 2010 OAGI0001367A_00243

Environmental Impacts of Operation 1 4.1.4.1 Potential Effects of Heated Water Discharges on Aquatic Biota 2 The discharge of heated water into the Hudson River can cause lethal or sublethal effects on 3 resident fish, influence food web characteristics and structure, and create barriers to migratory 4 fish moving from marine to freshwater environments. The potential for harm associated with the 5 discharge of heated water into streams, rivers, bays, and estuaries became known during the 6 early 1960s as new power facilities were being considered or constructed, and resulted in the 7 definition of waste heat as a pollutant in the Federal Water Pollution Control Act of 1965. Waste 8 heat discharges can directly kill sensitive aquatic organisms if the duration and extent of the 9 organism's exposure exceeds its upper thermal tolerance limit. Indirect effects associated with 10 exposure to nonlethal temperatures can result in disruptions or changes to spawning behavior, 11 accelerated or diminished growth rates of early lifestages (both positive and negative), or 12 changes in growth or survival in response to changes to food web dynamics or predator/prey 13 interactions (CHGEC et al. 1999). Indirect effects can also occur if the presence of a thermal 14 plume restricts or blocks a species' migratory pattern during a criticallifestage, or results in 15 avoidance behavior that affects species' viability or increases the likelihood of predation.

16 Adverse thermal effects can also occur when thermal discharges are interrupted, resulting in 17 cold shock. To evaluate the nature and extent of thermal discharges, it is necessary to have an 18 understanding of the characteristics of the thermal plume when it enters the receiving water, the 19 lethal and sublethal tolerance limits for key aquatic species and lifestages of interest, and the 20 possible exposure scenarios (nature and extent). Thus, regulatory agencies tasked with 21 developing thermal discharge criteria that are protective of aquatic resources (in this case, 22 NYSDEC) generally set limits on the extent, magnitude, and duration of the thermal plume to 23 ensure it addresses potential lethal and sublethal effects associated with the temperature of 24 heated water discharged into the environment, and its characteristics when it enters receiving 25 waters.

26 4.1.4.2 Historical Context 27 Thermal impacts associated with the operation of IP2 and IP3, Roseton, and the Bowline Point 28 electrical generating stations have been a concern of NYSDEC, the NRC's predecessor 29 organization (the U.S. Atomic Energy Commission (USAEC)), and the NRC. In the 1972 final 30 environmental statement (FES) for the IP2 operating license (USAEC 1972), the USAEC 31 concluded that, although operation of IP2 would meet New York thermal standards for river 32 surface water temperature, there was evidence to suggest that the IP2 discharge could exceed 33 New York State standards for surface area and cross-sectional area enclosed within the 4 of 34 isotherm. The USAEC, accordingly, issued an operating license for IP2 with the following 35 conditions related to potential thermal impacts:

36

  • operation of the once-through system would be permitted until January 1, 1978, and 37 thereafter a closed-cycle system would be required; 38
  • the applicant would perform an economic and environmental impact analysis of an 39 alternative closed-cycle system, and provide the evaluation to the USAEC by July 1, 40 1973; and 41
  • after approval by the USAEC, the required closed-cycle cooling system would be 42 designed, built, and placed in operation no later than January 1, 1978.

December 2010 4-27 NUREG-1437, Supplement 38 OAGI0001367A_00244

Environmental Impacts of Operation 1 The operating license also required the applicant to monitor dissolved oxygen in the discharge 2 water and thermal plume, and monitor the size, shape, and locations of isotherms in the thermal 3 plume (USAEC 1972). In the FES developed for the IP3 operating license, the NRC staff 4 assessed the impact of thermal discharges from once-through cooling for all units (lP1, IP2, and 5 IP3) and again concluded that, under certain conditions, the thermal discharges from the three 6 units would exceed New York State thermal criteria (NRC 1975). The NRC issued an operating 7 license to IP3 with conditions similar to those of IP2, but reflecting the decisions of the Atomic 8 Safety and Licensing Board in 1974 that required closed-cycle cooling by May 1, 1979.

9 In 1976, the former owners of IP2 and IP3 submitted an environmental report to the NRC that 10 evaluated various alternative closed-cycle cooling systems from an economic and 11 environmental standpoint. In 1978, the former owners submitted a 316(a) determination to 12 NYSDEC asserting that the facility complied with thermal standards established by New York 13 State (6 NYCRR 704). In 1980, litigation between New York State and electric generating 14 station owners, associated with the operation of electric generation stations along the Hudson 15 River, resulted in the HRSA. In place of the cooling tower requirement, HRSA required a variety 16 of mitigation measures including seasonal outages and the installation of dual-speed or 17 variable-speed pumps at IP2 and IP3. The existence of HRSA also superseded the 1978 18 section 316(a) study. In support of the Fourth Amended Consent Order to HRSA (NYSDEC 19 1997), the owners of IP2 and IP3 developed flow efficiency curves for each unit that related flow 20 to inlet temperature. For both units, flows of 500,000 gallons per minute (gpm) (1900 cubic 21 meters per minute (m 3 /min)) were generally attainable during the winter months (December-22 March when water inlet temperatures were less than 50°F (10°C), while flow rates of 700,000 23 gpm (2650 m3/min) were required during the summer months when inlet temperatures 24 exceeded 70°F (21°C) (NYSDEC 1997, Figures B-1 and B-2). The Fourth HRSA Consent 25 Order also developed a system of "flow variation points" as a means of evaluating changes in 26 plant operations at IP2 and IP3, Bowline Point, and Roseton that offset exceedences of 27 recommended flows with reductions at other times.

28 4.1.4.3 Thermal Studies and Conclusions 29 A detailed discussion of the thermal studies conducted at IP2 and IP3 to supplement the initial 30 316(a) work performed in the late 1970s is presented in CHGEC et al. (1999). The studies 31 included thermal modeling of near-field effects using the Cornell University Mixing Zone Model 32 (CORM IX), and modeling of far-field effects using the Massachusetts Institute of Technology 33 (MIT) dynamic network model (also called the far-field thermal model). For the purpose of 34 modeling, near field was defined as the region in the immediate vicinity of each station 35 discharge where cooling water occupies a clearly distinguishable, three-dimensional 36 temperature regime in the river that is not yet fully mixed; far field was defined as the region 37 farthest from the discharges where the plumes are no longer distinguishable from the river, but 38 the influence of the discharge is still present (CHGEC et al. 1999). The MIT model was used to 39 simulate the hydraulic and thermal processes present in the Hudson River at a scale deemed 40 sufficient by the utilities and their contractor and was designed and configured to account for 41 time-variable hydraulic and meteorological conditions and heat sources of artificial origins.

42 Model output included a prediction of temperature distribution for the Hudson River from the 43 Troy Dam to the island of Manhattan. Using an assumption of steady-state flow conditions, the 44 permit applicants applied CORM IX modeling to develop a three-dimensional plume 45 configuration of near-field thermal conditions that could be compared to applicable water quality NUREG-1437, Supplement 38 4-28 December 2010 OAGI0001367A_00245

Environmental Impacts of Operation 1 criteria (CHGEC et al. 1999).

2 The former owners of IP2 and IP3 conducted thermal plume studies employing both models for 3 time scenarios that encompassed the period of June-September (CHGEC et al. 1999). These 4 months were chosen because river temperatures were expected to be at their maximum levels.

5 The former owners used environmental data from 1981 to calibrate and verify the far-field MIT 6 model and to evaluate temperature distributions in the Hudson River under a variety of power 7 plant operating conditions. They chose the summer months of 1981 because data for all 8 thermal discharges were available, and because statistical analysis of the 1981 summer 9 conditions indicated that this year represented a relatively low-flow, high-temperature summer 10 that would represent a conservative (worst-case) scenario for examining thermal effects 11 associated with power plant thermal discharges. Modeling was performed under the following 12 two power plant operating scenarios to determine if New York State thermal criteria would be 13 exceeded:

14 (1) Individual station effects-full capacity operation of Roseton Units 1 and 2, IP2 and IP3, 15 or Bowline Point Units 1 and 2, with no other sources of artificial heat.

16 (2) Extreme operating conditions-Roseton Units 1 and 2, IP2 and IP3, and Bowline Point 17 Units 1 and 2, and all other sources of artificial heat operating at full capacity.

18 Modeling was initially conducted using MIT and CORMIX Version 2.0 under the conditions of 19 maximum ebb and flood currents (CHGEC et al. 1999). These results were supplemented by 20 later work using MIT and CORMIX Version 3.2 and were based on the hypothetical conditions 21 represented by the 10th -percentile flood currents, mean low water depths in the vicinity of each 22 station, and concurrent operation of all three generating stations at maximum permitted capacity 23 (CHGEC et al. 1999). The 10th percentile of flood currents was selected because it represents 24 the lowest velocities that can be evaluated by CORM IX, and because modeling suggests that 25 flood currents produce larger plumes than ebb currents. The results obtained from the CORMIX 26 model runs were integrated with the riverwide temperature profiles developed by the MIT 27 dynamic network model to evaluate far-field thermal impacts (e.g., river water temperature rises 28 above ambient) for various operating scenarios, the surface width of the plume, the depth of the 29 plume, the percentage of surface width relative to the river width at a given location, and the 30 percentage of cross-sectional area bounded by the 4°F (2°C) isotherm. In addition, the decay 31 in excess temperature was estimated from model runs under near slack water conditions 32 (CHGEC et al. 1999).

33 For IP2 and IP3, two-unit operation at full capacity resulted in a monthly average cross-sectional 34 temperature increase of 2.13 to 2.86°F (1.18 to 1.59°C) for ebb tide events in June and August, 35 respectively. The average percentage of river surface width bounded by the 4 ° F (2 ° C) 36 temperature rise isotherm ranged from 54 percent (August ebb tide) to 100 percent (July and 37 August flood tide). Average cross-sectional percentages bounded by the plume ranged from 14 38 percent (June and September) to approximately 20 percent (July and August). When the 39 temperature rise contributions of IP2 and IP3, Bowline Point, and Roseton were considered 40 collectively (with all three facilities operating a maximum permitted capacity and discharging the 41 maximum possible heat load), the monthly cross-sectional temperature rise in the vicinity of IP2 42 and IP3 ranged from 3.24°F (1.80°C) during June ebb tides to 4.63°F (2.5rC) during flood 43 tides in August. Temperature increases exceeded 4°F (2°C) on both tide stages in July and 44 August. After model modifications were made to account for the variable river geometry near December 2010 4-29 NUREG-1437, Supplement 38 OAGI0001367A_00246

Environmental Impacts of Operation 1 IP2 and IP3, predictions of surface width bounded by the plume ranged from 36 percent during 2 September ebb tides to 100 percent during flood tides in all study months. On near-slack tide, 3 the percentage of the surface width bounded by the 4°F (2°C) isotherm was 99 to 100 percent 4 in all study months. The average percentage of the cross-sectional area bounded by the plume 5 ranged from 27 percent (June ebb tide) to 83 percent (August flood tide) and was 24 percent in 6 all study months during slack water events. These results suggest that the 4°F (2°C) lateral 7 extent and cross-sectional criteria may sometimes be exceeded at IP2 and IP3. Exceedences 8 generally occurred under scenarios that the applicants indicated may be considered quite 9 conservative (maximum operation of three electrical generation facilities simultaneously for long 10 periods oftime, tidal conditions promoting maximum thermal impacts, atypical river flows). The 11 steady-state assumptions of CORMIX are also important because, although the modeled flow 12 conditions in the Hudson River would actually occur for only a short period of time when slack 13 water conditions are replaced by tidal flooding, CORMIX assumes this condition has been 14 continuous over a long period of time. CHGEC et al. (1999) found that this assumption can 15 result in an overestimate of the cross-river extent of the plume centerline.

16 Entergy has been engaged in discussions with the NYSDEC concerning the thermal impacts of 17 IP2 and IP3 cooling water system operation. As a result of those discussions, the NRC staff 18 notes that Entergy recently performed a triaxial thermal study of the Hudson River from 19 September 9 to November 1 of 2009 (Entergy 2010). Given the months involved in this study, 20 the study period did not include days with the highest average annual water temperature.

21 Entergy has indicated that it will perform modeling of the river based on its field data in order to 22 determine whether the power plant is in compliance with conditions of its permit; it also indicated 23 that it may conduct additional monitoring in 2010. The NYSDEC, in its recent Notice of Denial 24 of Water Quality Certification, indicated that additional verification of any modeled results would 25 be necessary (NYSDEC 2010). Entergy did conduct additional studies in 2010. This issue 26 continues to be subject to NYSDEC authority and review.

27 4.1.4.4 Assessments of Thermal Impacts 28 In this section, the NRC staff provides a summary of the various assessments of impacts 29 associated with thermal discharges from the IP2 and IP3 cooling system. The applicant's 30 assessment is based primarily on statements made in the ER (Entergy 2007a). The 31 conclusions of NYSDEC concerning the thermal impacts of the IP2 and IP3 cooling system are 32 presented in the final impact statement associated with the SPDES permits for Roseton Units 2 33 and 3, Bowline Units 1 and 2, and IP2 and IP3 (NYSDEC 2003a). The NRC staff also notes 34 that NGOs and members of the public have expressed concern that the applicant's assessment 35 of the effect of thermal discharges is incomplete, and that there is evidence to suggest that the 36 existing thermal discharges do not consistently meet applicable criteria as defined in 6 NYCRR 37 704.2(b)(5).

38 Applicant's Assessment 39 The IP2 and IP3 ER (Entergy 2007a) discusses the potential environmental impacts of thermal 40 discharges from IP2 and IP3. The conclusions provided in the ER indicate that the current 41 owners of IP2 and IP3 hold a NYSDEC SPDES permit (NY-0004472) and that the station is 42 complying with the terms of this permit. The conclusions of the ER also describe the current 43 mitigation required under the terms of the Fourth HRSA Consent Order that include flow 44 reductions to limit aquatic impacts and extensive studies in the Hudson River to evaluate NUREG-1437, Supplement 38 4-30 December 2010 OAGI0001367A_00247

Environmental Impacts of Operation 1 temporal and spatial trends. The applicant concludes that "continued operation in the manner 2 required by the current SPDES permit and the associated agreement to continue 3 implementation of the fourth Consent Degree ensures that thermal impacts will satisfy the 4 requirements of CWA 316(a) and will thus remain SMALL during the license renewal term.

5 Therefore, no further mitigation measures are warranted" (Entergy 2007a).

6 As noted in 4.1.4.3, Entergy conducted additional studies in 2009. While Entergy indicated it 7 would likely undertake additional modeling and verification of modeled results (if necessary),

8 Entergy (2010) concluded that IP2 and IP3 are in compliance with NYSDEC's thermal 9 requirements.

10 NYSDEC Assessment 11 In the FEIS associated with the SPDES permits for Roseton Units 1 and 2, Bowline Point Units 12 1 and 2, and IP2 and IP3 (NYSDEC 2003a), NYSDEC concludes that "Thermal modeling 13 indicates that the thermal discharge from IP2 and IP3 causes water temperatures to rise more 14 than allowed, which is 4 ° F over the temperature that existed before the addition of heat, or a 15 maximum of 83°F, whichever is less, in the estuary cross sections specified in 6 NYCRR § 16 704.2(b)(5)."

17 According to NYSDEC (2003b), the last SPDES permit for the Indian Point facility has been 18 administratively continued under provisions of the NY State Administrative Procedure Act since 19 1992. The fact sheet published by NYSDEC (2003b) in November 2003 describes the 20 environmental and facility operational issues and permit conditions of the draft SPDES permit 21 that NYSDEC has proposed to issue for IP2 and IP3. In Section IV, "Overview of the Permit" 22 (Section B, "Thermal Discharges"), NYSDEC indicates that the permittee must satisfy the 23 provisions of Section 316(a) of the CWA and related requirements in 6 NYCRR Section 704.2 24 "which provide that the thermal discharges from IP2 and IP3 to the Hudson River should meet 25 regulatory temperature criteria for estuaries, and must meet the NYS standard of ensuring the 26 propagation and survival of a balanced, indigenous population of shellfish, fish, and other 27 aquatic species."

28 To meet this goal, NYSDEC requires, within the first 2 years of the SPDES permit term, that 29 Entergy conduct a triaxial (three-dimensional) thermal study to document whether the thermal 30 discharges associated with the operation of IP2 and IP3 comply with New York State water 31 quality criteria. In the event the discharges do not comply, the permittee is allowed to apply for 32 a modification of one or more criteria as provided by 6 NYCRR Section 704.4, but must 33 demonstrate to the satisfaction of NYSDEC "that one or more of the criteria are unnecessarily 34 restrictive and that the modification would not inhibit the existence and propagation of a 35 balanced indigenous population of shellfish, fish, and wildlife in the Hudson River" (NYSDEC 36 2003a). In the ongoing proceeding before NYSDEC, Entergy has indicated that it would 37 propose an alternative study. This matter is still under review before NYSDEC, and may not be 38 resolved before NRC issues a final SEIS (Entergy 2007c).

39 Entergy conducted a thermal study in 2009. In its 2010 Notice of Denial related to Entergy's 40 application for Water Quality Consistency Review, the NYSDEC noted that Entergy's 2009 41 thermal study did not directly address the period of highest river temperatures, and as such, 42 would require additional confirmatory monitoring to determine whether any modeled results 43 accurately show compliance with thermal standards (NYSDEC 2010).

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Environmental Impacts of Operation 1 4.1.4.5 NRC Staff Assessment of Thermal Impacts 2 In the absence of a completed thermal study proposed by NYSDEC (or an alternative proposed 3 by Entergy and accepted by NYSDEC), existing information must be used to determine the 4 appropriate thermal impact level to sensitive life stages of important aquatic species. Since 5 NYSDEC modeling in the FEIS (NYSDEC 2003a) indicates that discharges from IP2 and IP3 6 could raise water temperatures to a level greater than that permitted by water quality criteria that 7 are a component of existing NYSDEC permits, the staff must conclude that adverse impacts are 8 possible. Cold water fish species such as Atlantic tomcod and rainbow smelt may be 9 particularly vulnerable to temperature changes caused by thermal discharges. The population 10 of both species has declined, and rainbow smelt may have been extirpated from the Hudson 11 River. The NYSDEC's issuance of a SPDES permit provides a basis to conclude that the 12 thermal impacts of IP2 and IP3 discharges could meet applicable regulatory temperature 13 criteria. The NYSDEC's recent pronouncements and its ongoing re-examination of this issue 14 create uncertainty, and this issue is currently being addressed in NYSDEC administrative 15 proceedings. Accordingly, in the absence of specific studies, and in the absence of results 16 sufficient to make a determination of a specific level of impact, the NRC staff concludes that 17 thermal impacts from IP2 and IP3 potentially could range from SMALL to LARGE depending on 18 the extent and magnitude of the thermal plume, the sensitivity of various aquatic species and 19 life stages likely to encounter the thermal plume, and the probability of an encounter occurring 20 that could result in lethal or sublethal effects. This range of impact levels expresses the 21 uncertainty accruing from the current lack of studies and data. Either additional thermal studies 22 or modeling and verification of Entergy's 2009 thermal study might generate data to further 23 refine or modify this impact level. For the purposes of this Final SEIS, the NRC staff concludes 24 that the impact level could range from SMALL to LARGE. This conclusion is meant to satisfy 25 NRC's NEPA obligations and is not intended to prejudice any determination the NYSDEC may 26 reach in response to new studies and information submitted to it by Entergy.

27 4.1.5 Potential Mitigation Options 28 Potential mitigation options related to the operation of the IP2 and IP3 once-through cooling 29 system are discussed in Chapter VII of the DEIS (CHGEC et al. 1999). Impacts associated with 30 impingement were assumed by the Hudson River utilities to be adequately mitigated because 31 previous IP2 and IP3 owners installed dual- and variable-speed pumps at IP2 and IP3, 32 respectively, in 1994, and also installed modified Ristroph screens at both units in the early 33 1990s (CHGEC et al. 1999). The summary conclusion of the DEIS in 1999 was that the Hudson 34 River utilities considered the system to be the best technology available to mitigate impingement 35 losses (CHGEC et al. 1999). The NYSDEC, however, has determined that closed-cycle cooling 36 is the best technology available to protect aquatic resources (NYSDEC 2003b).

37 CHGEC et al. (1999) also discusses the mitigation of entrainment losses at IP2 and IP3 by 38 ensuring that minimum flows are used for reactor cooling through the use of dual- or variable-39 speed pumps. In the ER (Entergy 2007a), the applicant concludes that, because impingement 40 and entrainment are not having any demonstrable negative effects on Hudson River RIS, further 41 mitigation measures are not warranted. NYSDEC's FEIS (2003a) indicated that "a range of 42 available technologies exist to minimize aquatic resource mortality from the cooling water intake 43 structures" at the Hudson River power plants, including IP2 and IP3. While NYSDEC indicated 44 that IP2 and IP3 pump systems and modified Ristroph screens help mitigate impingement NUREG-1437, Supplement 38 4-32 December 2010 OAGI0001367A_00249

Environmental Impacts of Operation 1 mortality, it also indicated that "significant unmitigated mortalities from entrainment and 2 impingement" remain at all of the Hudson River power plants (NYSDEC 2003a).

3 The NRC staff, in the results of its analysis provided in Sections 4.1.3 and 4.1.4 of this SEIS, 4 has found that impingement and entrainment from the operation of IP2 and IP3 are likely to 5 have an adverse effect on aquatic ecosystems in the lower Hudson River during the period of 6 extended operation. The available evidence suggests that the operation of the cooling systems 7 directly affects RIS by impingement and entrainment, and indirectly affects these resources 8 through the impingement and entrainment of their prey. The thermal discharges may also be 9 influencing RIS, but the extent of this influence cannot be determined without further studies, 10 such as those proposed in the draft SPDES permit for IP2 and IP3 and ongoing proceedings 11 before the NYSDEC.

12 To assess potential mitigation options, the NRC staff reviewed the comments and responses 13 provided in NYSDEC (2003a) and information provided by EPA in support of its Phase II 316(b) 14 program (EPA 2008a). Based on this review, additional mitigation options that may be available 15 for the existing cooling system include the following:

16

  • additional flow reductions or planned outages 17
  • use of wedgewire or fine-mesh screens 18
  • use of barrier systems at the intake locations 19
  • use of behavioral deterrent systems 20
  • closed-cycle cooling using cooling towers (e.g., hybrid wet/dry mechanical draft towers) 21 What follows is an overview of the effects of employing the above mitigation options to the 22 existing system currently in operation at IP2 and IP3. Because NYSDEC indicated closed-cycle 23 cooling is the best technology available for IP2 and IP3 (NYSDEC 2003b), the NRC staff will 24 review a cooling tower alternative in Chapter 8. Because the NRC staff will address a cooling 25 tower alternative in greater depth in Chapter 8, closed-cycle cooling will not be addressed 26 further in this chapter.

27 Costs and benefits of these measures have been addressed in the 1999 DEIS and evaluated by 28 NYSDEC in the FEIS. Of these alternative options, NYSDEC received comments indicating that 29 the cost figures for closed-cycle cooling in the DEIS were inflated by the Hudson River utilities.

30 After reviewing cost data with consultants, however, NYSDEC indicated that costs were 31 generally reasonable (noting that site-specific factors and changes in the cost of replacement 32 power may affect cost estimates) (NYSDEC 2003a).

33 The measures the NRC staff addresses below and in Chapter 8, as well as any other measures 34 to reduce entrainment and impingement at Indian Point, fall under the regulatory authority of 35 NYSDEC and the powers delegated to it by the EPA under the CWA. While the NRC has no 36 role in regulating or enforcing water quality standards, the NRC staff has included a discussion 37 of these mitigation measures in the interest of fulfilling the NRC's obligations under the National 38 Environmental Policy Act (NEPA) (42 USC 4321, et. seq) and 10 CFR Part 51.

39 Additional Flow Reductions or Shutdowns 40 As discussed in Section 4.1.1.1 of this SEIS, under the conditions of HRSA and the subsequent December 2010 4-33 NUREG-1437, Supplement 38 OAGI0001367A_00250

Environmental Impacts of Operation 1 consent orders, the operators of IP2 and IP3 developed programs to employ flow-reduction 2 measures and scheduled outages to reduce impingement and entrainment impacts. Because 3 flow rates were dependent on water temperature, greater flows were required during the months 4 of May through October when river water temperatures were above 15°C. It may be possible to 5 further reduce flows or increase the length or frequency of scheduled outages, though these 6 options will cause the plant operator to lose revenue from operating IP2 and IP3. In the 1999 7 DEIS, CHGEC et al. estimated that outages could cost between $14 million and $73 million per 8 year.

9 Wedgewire or Fine-Mesh Screens 10 In some cases, the use of wedgewire or fine-mesh screens has shown potential for decreasing 11 entrainment at once-through powerplants. Wedgewire screens typically have a screen size of 12 0.5 to 10 mm and are designed to reduce entrainment by physical exclusion and exploiting 13 hydrodynamic patterns (EPA 2008a). Fine-mesh screens generally employ a mesh size of 14 0.5 mm or less, and reduce entrainment by gently trapping organisms and reintroducing them 15 back into the environment via plant-specific collection and transfer systems. Factors influencing 16 the use of this technology include the screen size, the location, and configuration of the system 17 relative to the intake, the intake flow rates, the presence and magnitude of a "sweeping" current 18 that can limit impingement or move organisms past the screen into safe water, and the size of 19 the organism present near the intake. In its evaluation of wedgewire and fine-mesh screens, 20 EPA (2008a) indicated that these technologies showed promise for reducing entrainment, but 21 expressed concerns about the maintenance required to prevent clogging and the potential for 22 this technology to reduce entrainment but increase impingement. EPA (2008a) considered the 23 use of wedgewire screen technology to be more suitable for use in closed-cycle makeup water 24 systems where lower flow rates exist and fewer screens are required.

25 Because the portion of the Hudson River near IP2 and IP3 is subject to tidal influence, there are 26 periods of time when a sweeping current is not present. During this time, impingement against 27 wedgewire or fine-mesh screen systems would be exacerbated. Although the use of these 28 technologies at IP2 and IP3 is possible, numerous technical challenges would exist, including 29 how to configure and clean the screens, how to evaluate capture and removal success, and 30 how to assess the environmental effects and tradeoffs that would occur when one type of 31 impact (entrainment) is reduced while another impact (impingement) may increase. CHGEC 32 estimated that wedgewire screens could cost $44 million to $55 million per year in lost electricity 33 production, and indicated that fine-mesh screens would not be feasible.

34 The NRC staff notes that NYSDEC has indicated that Wedgewire screens would not be 35 adequate for meeting NYSDEC's BTA requirements under 316(b)(NYSDEC 2010). The NRC 36 staff includes wedgewire screens here as an option that could reduce impacts from operation of 37 the once-through cooling system and reiterates that only NYSDEC has the authority to establish 38 requirements for mitigation measures to address aquatic impacts of the cooling system.

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 NUREG-1437, Supplement 38 4-34 December 2010 OAGI0001367A_00251

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 considers the technology 17 "experimental in nature." Some advantages of the systems are that they can be deployed, 18 retrieved, and replaced seasonally as needed. They are suitable for use in all types of water 19 bodies and appear to reduce entrainment and impingement losses. The disadvantages are 20 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 December 2010 4-35 NUREG-1437, Supplement 38 OAGI0001367A_00252

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 SEIS. The lines are each about 2000 ft (610 m) in length, and 7 have ROW widths of approximately 150 ft (46 m). The transmission lines are located within the 8 site except for a terminal, 100-ft (30.5-m) segment of each that crosses the facility boundary and 9 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 SEIS. The applicant stated in 16 its ER that it is not aware of any new and significant information associated with the renewal of 17 the IP2 and IP3 operating licenses (Entergy 2007a). The NRC staff has not identified any new 18 and significant information during its independent review of the Entergy ER, the NRC staff's site 19 audit, the scoping process, or evaluation of other available information. Therefore, the NRC 20 staff concludes that there would be no impacts related to these issues beyond those discussed 21 in the GElS. For all of those issues, the NRC staff concluded in the GElS that the impacts 22 would be SMALL, and additional plant-specific mitigation measures are not likely to be 23 sufficiently beneficial to warrant implementation.

24 I NUREG-1437, Supplement 38 4-36 December 2010 OAGI0001367A_00253

Environmental Impacts of Operation 1 Table 4-5. Category 1 Issues Applicable to the IP2 and IP3 Transmission Lines 2 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 3 A brief description of the GElS conclusions, as codified in Table B-1, for each of these issues 4 follows:

5

  • Power line right-of-way management (cutting and herbicide application). Based on 6 information in the GElS, the Commission found the following:

7 The impacts of right-of-way maintenance on wildlife are expected to be of small 8 significance at all sites.

9

  • Bird collisions with power lines. Based on information in the GElS, the Commission 10 found the following:

11 Impacts are expected to be of small significance at all sites.

12

  • Impacts of electromagnetic fields (EMFs) on flora and fauna (plants, agricultural crops, 13 honeybees, wildlife, livestock). Based on information in the GElS, the Commission 14 found the following:

15 No significant impacts of electromagnetic fields on terrestrial flora and fauna 16 have been identified. Such effects are not expected to be a problem during the 17 license renewal term.

18

  • Floodplains and wetlands on power line right-of-way. Based on information in the GElS, 19 the Commission found the following:

20 Periodic vegetation control is necessary in forested wetlands underneath power 21 lines and can be achieved with minimal damage to the wetland. No significant 22 impact is expected at any nuclear power plant during the license renewal term.

December 2010 4-37 NUREG-1437, Supplement 38 OAGI0001367A_00254

Environmental Impacts of Operation 1

  • Air quality effects of transmission lines. Based on the information in the GElS, the 2 Commission found the following:

3 Production of ozone and oxides of nitrogen is insignificant and does not 4 contribute measurably to ambient levels of these gases.

5

  • Onsite land use. Based on the information in the GElS, the Commission found the 6 following:

7 Projected on-site land use changes required during ... the renewal period would 8 be a small fraction of any nuclear power plant site and would involve land that is 9 controlled by the applicant.

10

  • Power line right-of-way. Based on information in the GElS, the Commission found the 11 following:

12 Ongoing use of power line rights-of-way would continue with no change in 13 restrictions. The effects of these restrictions are of small significance.

14 The NRC staff identified no new and significant information associated with these issues during 15 the review. Therefore, the NRC staff expects that there would be no impacts during the renewal 16 term beyond those discussed in the GElS.

17 The NRC staff has identified one Category 2 issue and one un categorized issue related to 18 transmission lines. These issues are listed in Table 4-6 and are discussed in Sections 4.2.1 19 and 4.2.2 of this SEIS.

20 Table 4-6. Category 2 and Uncategorized Issues Applicable to the IP2 and IP3 21 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 22 4.2.1 Electromagnetic Fields-Acute Effects 23 Based on the GElS, the Commission determined that electric shock resulting from direct access 24 to energized conductors or from induced charges in metallic structures has not been found to be 25 a problem at most operating plants and generally is not expected to be a problem during the 26 license renewal term. However, site-specific review is required to determine the significance of 27 the electric shock potential along the portions of the transmission lines that are within the scope 28 of this SEIS.

29 I NUREG-1437, Supplement 38 4-38 December 2010 OAGI0001367A_00255

Environmental Impacts of Operation 1 In the GElS, the NRC staff found that, without a review of the conformance of each nuclear 2 plant transmission line to National Electrical Safety Code (N ESC) (I EEE 1997) criteria, it was 3 not possible to determine the significance of the electric shock potential. Evaluation of 4 individual plant transmission lines is necessary because the issue of electric shock safety was 5 not addressed in the licensing process for some plants. For other plants, land use in the vicinity 6 of transmission lines may have changed, or power distribution companies may have chosen to 7 upgrade line voltage. To comply with 10 CFR 51.53(c)(3)(ii)(H), the applicant must provide an 8 assessment of the potential shock hazard if the transmission lines that were constructed for the 9 specific purpose of connecting the plant to the transmission system do not meet the 10 recommendations of the NESC for preventing electric shock from induced currents.

11 As described in Section 2.1.7 of this SEIS, two 345-kilovolt (kV) transmission lines were built to 12 distribute power from IP2 and IP3 to the electric grid. Also, two 138-kV lines that use the same 13 transmission towers supply offsite (standby) power to IP2 and IP3. These lines are contained 14 within the IP2 and IP3 site, except for where they cross Broadway (a public road) to connect to 15 the Buchanan substation. Electric lines having voltages exceeding 98 kV of alternating current 16 to ground must comply with the NESC provision on minimum vertical clearance, adopted in 17 1977, that limits the steady-state current from electrostatic effects to 5 milliamperes (mA) if the 18 largest anticipated truck, vehicle, or equipment under the line were short circuited to ground.

19 The New York Public Service Commission (NYPSC) requires a more restrictive induced current 20 limit of 4.5 mA (Entergy 2007a).

21 Entergy indicates that at the time it acquired IP2 from the Consolidated Edison Company of 22 New York, the transmission lines connecting IP2 and IP3 to the Buchanan substation were in 23 compliance with the applicable NESC provisions for preventing electric shock from induced 24 current. The lines were also in compliance with the NYPSC 4.5-mA criterion, as calculated 25 using the methods described in the Electric Power Research Institute (EPRI) document 26 "Transmission Line Reference Book" (Con Edison 2007). There have been no configuration or 27 operation changes made to these lines since transfer of their ownership to Entergy (Entergy 28 2007a). Entergy indicates that it has maintenance procedures to ensure that the transmission 29 lines continue to conform to ground clearance standards (Entergy 2008a).

30 Entergy commissioned a study of the two 345-kV lines that connect IP2 and IP3 to the electric 31 transmission system to demonstrate to the NRC staff that they meet the NESC and NYPSC 32 requirements (Enercon 2008). The two 138-kV lines, which are at similar ground-crossing 33 heights to the 345-kV lines, are also addressed by the study. The analysis was performed using 34 the EPRI TL Workstation calculation software to determine the highest ground-level electric field 35 strengths at the ROWs where they cross Broadway. Enercon employed procedures and 36 calculations from the EPRI "Transmission Line Reference Book, 200kV and Above (Third 37 Edition)", which Enercon indicates is the industry-accepted reference for transmission line 38 design and field effects. Enercon notes that The EPRI parameters for a 55-ft- (17-m)-long 39 tractor trailer were used, with the length increased to 65 ft (20 m) to represent the maximum 40 allowed under New York size restrictions. The analysis revealed a maximum calculated 41 induced current for the 345-kV lines of 1.3 mA, below the NYPSC 4.5-mA limit (Enercon 2008).

42 In the GElS, the NRC staff found that electrical shock is of SMALL significance for transmission 43 lines that are operated in adherence with the NESC criteria for limiting hazards. Based on a 44 review of the available information, including that provided in the ER (Entergy 2007a), the NRC 45 staff's environmental site audit, the scoping process, the NRC staff's evaluation of Entergy's December 2010 4-39 NUREG-1437, Supplement 38 OAGI0001367A_00256

Environmental Impacts of Operation 1 2008 study (Enercon 2008), and existing NESC requirements, the NRC staff concludes that the 2 transmission lines associated with IP2 and IP3 meet NESC criteria for limiting hazards, and thus 3 the potential impact from electric shock during the renewal term is SMALL.

4 The NRC staff identified measures that could further mitigate potential acute EMF impacts 5 resulting from continued operation of the IP2 and IP3 transmission lines, including installing 6 road signs at road crossings and increasing transmission line clearances. These mitigation 7 measures could reduce human health impacts by minimizing public exposures to electric shock 8 hazards. The staff did not identify any cost benefit studies applicable to the mitigation measures 9 mentioned above.

10 4.2.2 Electromagnetic Fields-Chronic Effects 11 In the GElS, the chronic effects of 60-hertz EMFs from power lines were not designated as 12 Category 1 or 2, and a designation will not be made until scientific consensus is reached on the 13 health implications of these fields.

14 The potential for chronic effects from these fields continues to be studied and is not known at 15 this time. The National Institute of Environmental Health Sciences (NIEHS) directs related 16 research through the U.S. Department of Energy (DOE). The 1999 report of the NIEHS and 17 DOE Working Group (NIEHS 1999) contains the following conclusion:

18 The NIEHS concludes that ELF-EMF [extremely low frequency-electromagnetic 19 field] exposure cannot be recognized as entirely safe because of weak scientific 20 evidence that exposure may pose a leukemia hazard. In our opinion, this finding 21 is insufficient to warrant aggressive regulatory concern. However, because 22 virtually everyone in the United States uses electricity and therefore is routinely 23 exposed to ELF-EMF, passive regulatory action is warranted, such as a 24 continued emphasis on educating both the public and the regulated community 25 on means aimed at reducing exposures. The NIEHS does not believe that other 26 cancers or non-cancer health outcomes provide sufficient evidence of a risk to 27 currently warrant concern.

28 This statement is not sufficient to cause the NRC to reach a conclusion with respect to the 29 chronic effects of EMFs as detailed below (from 10 CFR Part 51, Subpart A, Appendix B, Table 30 B-1):

31 If, in the future, the Commission finds that, contrary to current indications, a 32 consensus has been reached by appropriate Federal health agencies that there 33 are adverse health effects from electromagnetic fields, the Commission will 34 require applicants to submit plant-specific reviews of these health effects as part 35 of their license renewal applications. Until such time, applicants for license 36 renewal are not required to submit information on this issue.

37 The NRC staff considers the GElS finding of "uncertain" still appropriate and continues to follow 38 developments on this issue.

39 4.3 Radiological Impacts of Normal Operations I NUREG-1437, Supplement 38 4-40 December 2010 OAGI0001367A_00257

Environmental Impacts of Operation 1 Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, applicable to IP2 and 2 IP3 in regard to radiological impacts of normal operations are listed in Table 4-7. Entergy stated 3 in its ER that it was aware of one new issue associated with the renewal of the IP2 and IP3 4 operating licenses-potential ground water contamination and a new radioactive liquid effluent 5 release pathway as a result of leakage from the plant. The NRC staff has discussed this issue 6 and the various studies relating to it in Section 2.2.7 of this SEIS, and addresses the 7 significance of this issue in Section 4.5. The NRC staff has not identified any new and 8 significant information, beyond the new issue identified by the applicant in its ER, during its 9 independent review of Entergy's ER, the site audit, the scoping process, NRC inspection 10 reports, or its evaluation of other available information.

11 As discussed in Sections 2.2.7 and 4.5 of this SEIS, the NRC staff concludes that the new issue 12 is not significant, and thus does not challenge the finding in the GElS. According to the GElS, 13 the impacts to human health during license renewal term are SMALL, and additional plant-14 specific mitigation measures are not likely to be sufficiently beneficial to be warranted.

15 Table 4-7. Category 1 Issues Applicable to Radiological Impacts of Normal Operations 16 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 17 The NRC staff has not identified any new and significant information, beyond the new issue 18 identified by the applicant in its ER concerning potential ground water contamination and a new 19 radioactive effluent release pathway for leakage from the plant, during its independent review of 20 Entergy's ER, the site audit, the scoping process, NRC inspection reports, or its evaluation of 21 other available information. The NRC evaluated the detailed information provided by the 22 applicant, State agencies, and NRC inspections on the new issue and concluded that the new 23 issue is not significant and that the impacts to human health during the license renewal term are 24 SMALL. Therefore, the NRC staff concludes that there would be no impact from radiation 25 exposures to the public or to workers during the renewal term beyond those discussed in the 26 GElS.

27 The NRC staff concludes that the abnormal liquid releases discussed by Entergy in its ER, while 28 new information, are within the NRC's radiation safety standards contained in 10 CFR Part 20, 29 "Standards for Protection against Radiation," and are not considered to have a significant 30 impact on plant workers, the public, or the environment. Furthermore, the NRC staff 31 acknowledges that the commitments made by Entergy-and identified in Section 2.2.7 of this 32 SEIS-for long-term monitoring and remediation will help to minimize the potential impacts from 33 contaminated ground water and help maintain radiological impacts within NRC radiation safety 34 standards.

35

  • Radiation exposures to public (license renewal term). Based on information in the GElS, 36 the Commission found the following:

37 Radiation doses to the public will continue at current levels associated with December 2010 4-41 NUREG-1437, Supplement 38 OAGI0001367A_00258

Environmental Impacts of Operation 1 normal operations.

2

  • Occupational radiation exposures (license renewal term). Based on information in the 3 GElS, the Commission found the following:

4 Projected maximum occupational doses during the license renewal term are 5 within the range of doses experienced during normal operations and normal 6 maintenance outages, and would be well below regulatory limits.

7 The NRC staff identified no information that was both new and significant on these issues during 8 the review of the IP2 and IP3 LRA. Therefore, the NRC staff expects that there would be no 9 impacts during the renewal term beyond those discussed in the GElS.

10 There are no Category 2 issues related to radiological impacts of routine operations.

11 4.4 Socioeconomic Impacts of Plant Operations during the 12 License Renewal Term 13 Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, applicable to 14 socioeconomic impacts during the renewal term are listed in Table 4-8 of this SEIS. As stated 15 in the GElS, the impacts associated with these Category 1 issues were determined to be 16 SMALL, and plant-specific mitigation measures would not be sufficiently beneficial to be 17 warranted.

18 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 19 The NRC staff reviewed and evaluated the IP2 and IP3 ER, scoping comments, and other 20 available information. The NRC staff also visited IP2 and IP3 in search of new and significant 21 information that would change the conclusions presented in the GElS. No new and significant 22 information was identified during this review and evaluation. Therefore, the NRC staff 23 concludes that there would be no impacts related to these Category 1 issues during the renewal 24 term beyond those discussed in the GElS.

25 The results of the review and brief statement of GElS conclusions, as codified in Table B-1 of 26 10 CFR Part 51, Subpart A, Appendix B, for each of the socioeconomic Category 1 issues are 27 provided below:

I NUREG-1437, Supplement 38 4-42 December 2010 OAGI0001367A_00259

Environmental Impacts of Operation 1

  • Public services: public safety, social services, and tourism and recreation. Based on 2 information in the GElS, the Commission found the following:

3 Impacts to public safety, social services, and tourism and recreation are 4 expected to be of small significance at all sites.

5

  • Public services, education (license renewal term). Based on information in the GElS, 6 the Commission found the following:

7 Only impacts of small significance are expected.

8

  • Aesthetic impacts (license renewal term). Based on information in the GElS, the 9 Commission found the following:

10 No significant impacts are expected during the license renewal term.

11

  • Aesthetic impacts of transmission lines (license renewal term). Based on information in 12 the GElS, the Commission found the following:

13 No significant impacts are expected during the license renewal term.

14 The NRC staff identified no new and significant information regarding these issues during the 15 review. Therefore, the NRC staff expects that there would be no impacts during the renewal 16 term beyond those discussed in the GElS.

17 Table 4-9 lists the Category 2 socioeconomic issues, which require plant-specific analysis, and 18 an environmental justice impact analysis, which was not addressed in the GElS.

19 Table 4-9. Category 2 Issues Applicable to Socioeconomics 20 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.

21 4.4.1 Housing Impacts 22 Appendix C to the GElS presents a population characterization method based on two factors, 23 sparseness and proximity (see Section C.1.4). Sparseness measures population density within 24 20 miles (mi) (32 kilometers (km)) of the site, and proximity measures population density and December 2010 4-43 NUREG-1437, Supplement 38 OAGI0001367A_00260

Environmental Impacts of Operation 1 city size within 50 mi (80 km). Each factor has categories of density and size (see Table C.1 of 2 the GElS). A matrix is used to rank the population category as low, medium, or high (see Figure 3 C.1 of the GElS).

4 In Chapter 2 of this SEIS, the NRC staff describes the local population around IP2 and IP3. As 5 NRC staff indicated in Section 2.2.8.5, the 2000 U.S. Census noted that approximately 6 1,113,089 people lived within 20 mi (32 km) of IP2 and IP3, which equates to a population 7 density of 886 persons per square mi (332 persons per square km). This density translates to 8 the least sparse Category 4 (greater than or equal to 120 persons per square mi within 20 mi).

9 Approximately 16,791,654 people live within 50 mi (80 km) of IP2 and IP3 (Entergy 2007a).

10 This equates to a population density of 2138 persons per square mi (825 persons per square 11 km). Applying the GElS proximity measures, the IP2 and IP3 site is classified as proximity 12 Category 4 (greater than or equal to 190 persons per square mi within 50 mi). Therefore, 13 according to the sparseness and proximity matrix presented in the GElS, IP2 and IP3 ranks of 14 sparseness Category 4 and proximity Category 4 result in the conclusion that Indian Point is 15 located in a high population area.

16 Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, states that impacts on housing availability 17 are expected to be of small significance in high-density population areas where growth-control 18 measures are not in effect. Since Indian Point is located in a high population area and 19 Dutchess, Orange, Putnam, and Westchester Counties are not subject to growth-control 20 measures that would limit housing development, any changes in IP2 and IP3 employment would 21 have little noticeable effect on housing availability in these counties. Because Entergy has 22 indicated in its ER that there would be no hiring of additional workers to support license renewal, 23 nonoutage employment levels at IP2 and IP3 would remain relatively constant with no additional 24 demand for permanent housing during the license renewal term (Entergy 2007a). In addition, 25 the number of available housing units has kept pace with or exceeded the low growth in the 26 area population. Based on this information, the NRC staff concludes that there would be no 27 impact on permanent housing during the license renewal term beyond what is currently being 28 experienced.

29 However, as stated in section 3.1 of this SEIS, Entergy has indicated that it may replace IP2 30 and IP3 reactor vessel heads and control rod drive mechanisms (CRDMs) during the license 31 renewal term,. Entergy estimates that this replacement activity at IP2 and IP3 would require an 32 increase in the number of refueling outage workers for up to 60 days during two separate 33 refueling outages, one for each unit, 12 months apart (Entergy 2008b). These additional 34 workers would increase the demand for temporary (rental) housing in the immediate vicinity of 35 IP2 and IP3. The NRC staff has reviewed the potential environmental impacts of this 36 replacement activity, as discussed in Chapter 3 of this SEIS.

37 4.4.2 Public Services-Public Utility Impacts 38 The GElS indicates that impacts on public utilities are SMALL if the existing infrastructure could 39 accommodate plant-related demand without a noticeable effect on the level of service. The 40 GElS indicates that MODERATE impacts arise when the demand for service or use of the 41 infrastructure is sizeable and would noticeably decrease the level of service or require additional 42 resources to maintain the level of service. The GElS indicates that LARGE impacts would result 43 when new programs, upgraded or new facilities, or substantial additional staff are required 44 because of plant-related demand.

NUREG-1437, Supplement 38 4-44 December 2010 OAGI0001367A_00261

Environmental Impacts of Operation 1 In the absence of new and significant information to the contrary, the only impacts on public 2 utilities that the NRC staff found in the GElS could be significant during license renewal are 3 impacts on public water supplies. The NRC staff's analysis of impacts on the public water and 4 sewer systems considered both plant demand and plant-related population growth. In the 5 GElS, the NRC staff found that impacts from license renewal on public water supplies could 6 range from SMALL to MODERATE, with the site-specific impact depending on factors that exist 7 at each plant site.

8 As previously discussed (in Section 2.2.8.2) of this SEIS, potable water and process water is 9 supplied to IP2 and IP3 by the Village of Buchanan water supply system (VB NY 2006). IP2 and 10 IP3 use approximately 2.3 million fe (65,000 m3]) or 17.4 million gallons of potable water per 11 month, and there is no indicated restriction on the amount of potable water that IP2 and IP3 can 12 use. Further, Entergy (Entergy 2007a) does not project an increase in plant demand.

13 Because Entergy has indicated that there would be no hiring of additional workers during the 14 license renewal period (Entergy 2007a), overall employment levels at IP2 and IP3 would remain 15 relatively unchanged with no additional demand for public water and sewer services. Public 16 water systems in the region would remain adequate to meet the demands of residential and 17 industrial customers in the area. Therefore, there would be no impact to public water and sewer 18 services during the license renewal term beyond what is currently being experienced.

19 As discussed in Section 4.4.1 of this SEIS, Entergy may replace the IP2 and IP3 reactor vessel 20 heads and CRDMs during the license renewal term (Entergy 2008b). The additional number of 21 refueling outage workers needed for this replacement activity would cause short-term increases 22 in the amount of public water and sewer services used in the immediate vicinity of IP2 and IP3.

23 These impacts are discussed in Chapter 3 of this SEIS.

24 4.4.3 Offsite Land Use-License Renewal Period 25 Offsite land use during the license renewal term is a Category 2 issue (10 CFR Part 51, Subpart 26 A, Appendix B, Table B-1). Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, notes that 27 "significant changes in land use may be associated with population and tax revenue changes 28 resulting from license renewal," And effects can be small, moderate, or large.

29 Section 4.7.4 of the GElS defines the magnitude of land use changes as a result of plant 30 operation during the license renewal term as follows:

31 SMALL-Little new development and minimal changes to an area's land use 32 pattern.

33 MODERATE-Considerable new development and some changes to the land 34 use pattern.

35 LARGE-Large-scale new development and major changes in the land use 36 pattern.

37 Tax revenue can affect land use because it enables local jurisdictions to provide the public 38 services (e.g., transportation and utilities) necessary to support development. Section 4.7.4.1 of 39 the GElS states that the assessment of tax-driven land use impacts during the license renewal 40 term should consider (1) the size of the plant's payments relative to the community's total 41 revenues, (2) the nature of the community's existing land use pattern, and (3) the extent to December 2010 4-45 NUREG-1437, Supplement 38 OAGI0001367A_00262

Environmental Impacts of Operation 1 which the community already has public services in place to support and guide development. If 2 the plant's tax payments are projected to be small relative to the community's total revenue, tax-3 driven land use changes during the plant's license renewal term would be SMALL, especially 4 where the community has preestablished patterns of development and has provided adequate 5 public services to support and guide development. Section 4.7.2.1 of the GElS states that if tax 6 payments by the plant owner are less than 10 percent of the taxing jurisdiction's revenue, the 7 significance level would be SMALL. If the plant's tax payments are projected to be medium to 8 large relative to the community's total revenue, new tax-driven land use changes would be 9 MODERATE. If the plant's tax payments are projected to be a dominant source of the 10 community's total revenue, new tax-driven land use changes would be LARGE. This would be 11 especially true where the community has no preestablished pattern of development or has not 12 provided adequate public services to support and guide development.

13 4.4.3.1 Population-Related Impacts 14 Since Entergy has indicated that it has no plans to add nonoutage employees during the license 15 renewal period, there would be no noticeable population change to drive changes in land use 16 conditions in the vicinity of IP2 and IP3 that is attributable to the plant. Therefore, there would 17 be no population-related land use impacts during the license renewal term beyond those 18 already being experienced.

19 As discussed in Section 4.4.1 of this SEIS, Entergy may replace the IP2 and IP3 reactor vessel 20 heads and CRDMs during the license renewal term (Entergy 2008b). Because of the short 21 amount of time needed for this replacement activity, the NRC staff finds that additional number 22 of refueling outage workers would not cause any permanent population-related land use 23 changes in the immediate vicinity of IP2 and IP3. These impacts are discussed in Chapter 3 of 24 this SEIS.

25 4.4.3.2 Tax-Revenue-Related Impacts 26 As discussed in Chapter 2 of this SEIS, Entergy pays annual real estate taxes to the Town of 27 Cortlandt, Hendrick Hudson Central School District, and the Village of Buchanan (see Table 2-28 18 in Chapter 2 for more detail). As reported in Chapter 2, tax payments to the Town of 29 Cortlandt represented between 11 and 16 percent of the town's total annual tax revenues for the 30 3-year period from 2003 through 2005, and payments to the Hendrick Hudson Central School 31 District represented approximately 30 to 38 percent of the school district's total revenues over 32 the same time period. Entergy's tax payments to the Village of Buchanan make up a high 33 percentage of the village's tax collection. For the period 2003 through 2005, tax payments to 34 the Village of Buchanan represented 39 to 44 percent of the village's total revenues.

35 The NRC staff notes that since Entergy started making payments to local jurisdictions, 36 population levels and land use conditions in the Town of Cortlandt, Village of Buchanan, and 37 Westchester County have not changed significantly, which might indicate that these tax 38 revenues have had little or no effect on land use activities within the county.

39 Entergy has indicated that it plans no license-renewal-related construction activities to support 40 the continued operation of IP2 and IP3 during the license renewal period. Accordingly, the NRC 41 staff expects that there would be no increase in the assessed value of IP2 and IP3 and that the 42 annual payment-in-lieu-of-taxes and property taxes paid to the Town of Cortlandt, the Hendrick 43 Hudson Central School District, and the Village of Buchanan would remain relatively unchanged 44 throughout the license renewal period. Based on this information, there would be no tax-NUREG-1437, Supplement 38 4-46 December 2010 OAGI0001367A_00263

Environmental Impacts of Operation 1 revenue-related land use impacts during the license renewal term beyond those currently being 2 experienced.

3 As discussed in Section 4.4.1 of this SEIS, Entergy may replace the IP2 and IP3 reactor vessel 4 heads and CRDMs during the license renewal term (Entergy 2008b). This replacement activity 5 would not likely increase the assessed value of IP2 and IP3, and property tax payments would 6 remain unchanged. These impacts are discussed in Chapter 3 of this SEIS.

7 4.4.4 Public Services: Transportation Impacts during Operations 8 Table 8-1 of Appendix 8 to Subpart A of 10 CFR Part 51 states the following:

9 Transportation impacts (level of service) of highway traffic generated ... during the 10 term of the renewed license are generally expected to be of small significance.

11 However, the increase in traffic associated with additional workers and the local 12 road and traffic control conditions may lead to impacts of moderate or large 13 significance at some sites.

14 All applicants are required by 10 CFR 51.53(c)(3)(ii)(J) to assess the impacts of highway traffic 15 generated by the proposed project on the level of service of local highways during the term of 16 the renewed license.

17 Since Entergy has no plans to add non-outage employees during the license renewal period, 18 there would be no noticeable change in traffic volume and levels of service on roadways in the 19 vicinity of IP2 and IP3. Therefore, there would be no transportation impacts during the license 20 renewal term beyond those already being experienced.

21 As discussed in Section 4.4.1 of this SEIS, Entergy may replace the IP2 and IP3 reactor vessel 22 heads and CRDMs during the license renewal term (Entergy 2008b). The additional number of 23 outage workers and truck material deliveries needed to support this replacement activity could 24 cause short-term transportation impacts on access roads in the immediate vicinity of IP2 and 25 IP3. These impacts are discussed in Chapter 3 of this SEIS.

26 4.4.5 Historic and Archeological Resources 27 The National Historic Preservation Act (NHPA), as amended, requires Federal agencies to 28 consider the effects of their undertakings on historic properties. Historic properties are defined 29 as resources that are eligible for listing on the National Register of Historic Places. The criteria 30 for eligibility are listed in 36 CFR 60.4, "Criteria for Evaluation," and include (1) association with 31 significant events in history, (2) association with the lives of persons significant in the past, 32 (3) embodies distinctive characteristics of type, period, or construction, and (4) yielded or is 33 likely to yield important information (ACHP 2008). The historic preservation review process 34 mandated by Section 106 of the NHPA is outlined in regulations issued by the Advisory Council 35 on Historic Preservation in 36 CFR Part 800, "Protection of Historic Properties." The issuance 36 of a renewed operating license for a nuclear power plant is a Federal action that could possibly 37 affect either known or currently undiscovered historic properties located on or near the plant site 38 and its associated transmission lines. In accordance with the provisions of the NHPA, the NRC 39 is required to make a reasonable effort to identify historic properties in the areas of potential 40 effect. If no historic properties are present or affected, the NRC is required to notify the State 41 Historic Preservation Office before proceeding. If it is determined that historic properties are December 2010 4-47 NUREG-1437, Supplement 38 OAGI0001367A_00264

Environmental Impacts of Operation 1 present, the NRC is required to assess and resolve possible adverse effects of the undertaking.

2 4.4.5.1 Site-Specific Cultural Resources Information 3 A review of the New York State Historic Preservation Office (NYSHPO) files shows that there 4 are no previously recorded archeological or above-ground historic architectural resources 5 identified on the IP2 and IP3 property. As noted in Section 2.2.9.1 of this SEIS, a Phase 1A 6 survey (literature review and background research) of the plant property was conducted in 2006; 7 however, no systematic pedestrian or subsurface archeological surveys have been conducted 8 at the IP2 and IP3 site. In 2009, however, Entergy conducted a Phase 1b survey of possible 9 locations for cooling towers, should proceedings before the NYSDEC require that they be 10 installed at the site (Entergy 2009b). The survey addressed only those portions of the site likely 11 to be affected by cooling tower installation. Subsurface investigation - shovel testing - revealed 12 no artifacts or other resources in the areas considered for the northernmost of two cooling 13 towers. Investigations for the southern tower, however, identified historical artifacts at multiple 14 locations within the potential tower footprint, as well as prehistoric artifacts (primarily lithic 15 shatter) in a portion of the potential tower footprint.

16 Background research revealed a total of 76 resources listed on the National Register of Historic 17 Places within a 5-mile radius of IP2 and IP3 Also, as noted in Chapter 2, Stony Point Battlefield 18 State Historic Site - a National Historic Landmark - is located across the Hudson River and 19 south of IP2 and IP3. None of these historic resources, however, are located within the 20 boundaries of the property.

21 The NRC staff noted in the draft SEIS that there is potential for archeological resources to be 22 present on some portions of the IP2 and IP3 property. As noted in Section 2.2.9.2 of this SEIS, 23 because of disturbances associated with site preparation and construction, the power block 24 area at IP2 and IP3 has little or no potential for archeological resources. There is potential for 25 archeological resources to be present in the wooded area northeast of the power block area 26 outside the area surveyed for possible cooling tower installation. A portion of the property south 27 and east of the power block area, which contains a variety of ancillary plant facilities, has been 28 disturbed by construction activities over the course of the plant's history. It is possible, however, 29 that portions of that area not disturbed by construction activities - including those investigated in 30 the recent Phase 1b survey - may contain intact subsurface archeological deposits. In addition, 31 the IP1 reactor was one of three "demonstration plants" that began operation in the early 1960s.

32 It is representative of the earliest era of commercial reactors to operate in the United States. To 33 date, no formal significance or eligibility evaluation has been conducted for IP1; however, the 34 plant could become eligible for inclusion on the National Register of Historic Places. As 35 mandated by Section 106 of the NHPA, an evaluation would be conducted if it was determined 36 that a project could affect IP1.

37 4.4.5.2 Conclusions 38 Entergy has proposed no specific new facilities, service roads, or transmission lines for the IP2 39 and IP3 site associated with continued operation and refurbishment (which does not include the 40 installation of cooling towers). However, Entergy indicated that it plans to replace the IP2 and 41 IP3 reactor vessel heads and CRDMs during the license renewal period. This activity could 42 involve ground-disturbing activities associated with the construction of a storage building for the 43 existing reactor vessel heads and CRDMs. Ground-disturbing activities would be reviewed in 44 accordance with Entergy nuclear fleet procedures, which are designed to ensure that NUREG-1437, Supplement 38 4-48 December 2010 OAGI0001367A_00265

Environmental Impacts of Operation 1 investigations and consultations are conducted as needed, and that existing or potentially 2 existing cultural resources are adequately protected by Entergy such that the applicant can 3 meet State and Federal expectations (Enercon 2007). The NRC staff considers the potential 4 impacts to historic and archaeological resources on the IP2 and IP3 site that may result from 5 installation of cooling towers, should such towers be required by the NYSDEC, in the discussion 6 of alternatives in Chapter 8 of this SEIS.

7 The potential for impacts from continued operation of IP2 and IP3 on historic or archeological 8 resources eligible for the National Register is SMALL. However, as noted in the NRC staff 9 walkover survey discussed in Chapter 2 of this SEIS, there is a potential for prehistoric and 10 historic archeological resources to be present on the northeastern portion of the site, although 11 this area was previously disturbed by surface mining in the 19th century, the potential for intact 12 prehistoric/historic and archeological resources remains. Further, recent investigations have 13 identified existing historic and prehistoric resources on less-disturbed portions of the site south 14 of the power block (Entergy 2009b) .. Section 106 of the NHPA requires that lands not 15 previously surveyed in the vicinity of IP2 and IP3 would require investigation by a professional 16 archeologist in consultation with the NYSHPO before any ground-disturbing activities. To 17 mitigate any potential adverse impacts to historic and archeological resources from continued 18 plant operations in these areas, field surveys (archeological investigations) and consultation 19 under the NHPA should be conducted before any ground-disturbing activities take place.

20 Entergy's procedures should be followed to mitigate any potential adverse impacts to historic 21 and archeological resources.

22 4.4.6 Environmental Justice 23 Under Executive Order 12898, "Federal Actions To Address Environmental Justice in Minority 24 Populations and Low-Income Populations" (Volume 59, page 7629 of the Federal Register 25 (59 FR 7629)), Federal agencies are responsible for identifying and addressing potential 26 disproportionately high and adverse human health and environmental impacts on minority and 27 low-income populations. In 2004, the Commission issued its "Policy Statement on the 28 Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions" 29 (69 FR 52040), which states, "The Commission is committed to the general goals set forth in 30 E.O. 12898, and strives to meet those goals as part of its NEPA review process."

31 The Council of Environmental Quality (CEQ) provides the following information in its publication 32 entitled, "Environmental Justice: Guidance under the National Environmental Policy Act" 33 (1997):

34

  • Disproportionately High and Adverse Human Health Effects. Adverse health effects 35 are measured in risks and rates that could result in latent cancer fatalities, as well as 36 other fatal or nonfatal adverse impacts on human health. Adverse health effects may 37 include bodily impairment, infirmity, illness, or death. Disproportionately high and 38 adverse human health effects occur when the risk or rate of exposure to an 39 environmental hazard for a minority or low-income population is significant (as defined 40 by NEPA) and appreciably exceeds the risk or exposure rate for the general population 41 or for another appropriate comparison group (CEQ 1997).

December 2010 4-49 NUREG-1437, Supplement 38 I OAGI0001367A_00266

Environmental Impacts of Operation 1

  • Disproportionately High and Adverse Environmental Effects. A disproportionately 2 high environmental impact that is significant (as defined by NEPA) refers to an impact or 3 risk of an impact on the natural or physical environment in a low-income or minority 4 community that appreciably exceeds the environmental impact on the larger community.

5 Such effects may include ecological, cultural, human health, economic, or social 6 impacts. An adverse environmental impact is an impact that is determined to be both 7 harmful and significant (as defined by NEPA). In assessing cultural and aesthetic 8 environmental impacts, impacts that uniquely affect geographically dislocated or 9 dispersed minority or low-income populations or American Indian tribes are considered 10 (CEQ 1997).

11 The environmental justice analysis assesses the potential for disproportionately high and 12 adverse human health or environmental effects on minority and low-income populations that 13 could result from the operation of IP2 and IP3 during the renewal term. In assessing the 14 impacts, the following CEQ (1997) definitions of minority individuals and populations and low-15 income population were used:

16 (1) Minority individuals. Individuals who identify themselves as members of the following 17 population groups: Hispanic or Latino, American Indian or Alaska Native, Asian, Black 18 or African American, Native Hawaiian or Other Pacific Islander, or two or more races 19 meaning individuals who identified themselves on a Census form as being a member of 20 two or more races, for example, Hispanic and Asian.

21 (2) Minority populations. Minority populations are identified when (1) the minority 22 population of an affected area exceeds 50 percent or (2) the minority population 23 percentage of the affected area is meaningfully greater than the minority population 24 percentage in the general population or other appropriate unit of geographic analysis.

25 (3) Low-income populations. Low-income populations in an affected area are identified 26 with the annual statistical poverty thresholds from the Census Bureau's Current 27 Population Reports, Series PB60, on Income and Poverty.

28 Minority Population in 2000 29 According to 2000 census data, 48.7 percent of the population (approximately 16,805,000 30 individuals) residing with a 50-mi (80-km) radius of IP2 and IP3 identified themselves as minority 31 individuals. The largest minority group was Black or African American (3,480,000 persons or 32 20.7 percent), followed by Hispanic or Latino of any race (3,439,000 or about 20.5 percent) 33 (USCB 2003-LandView 6). About 36 percent of the Westchester County population were 34 minorities, with Hispanic or Latino the largest minority group (15.6 percent) followed by Black or 35 African American (13.6 percent) (USCB 2008).

36 Census block groups with minority populations exceeding 50 percent were considered minority 37 block groups. Based on 2000 census data, Figure 4-5 of this SEIS shows minority block groups 38 within a 50-mi (80-km) radius of IP2 and IP3 in which more than 50 percent of the block group 39 population is minority.

40 Low-Income Population in 2000 41 According to 2000 census data, approximately 484,000 families (approximately 11.7 percent) 42 residing within a 50-mi (80-km) radius of the IP2 and IP3 were identified as living below the NUREG-1437, Supplement 38 4-50 December 2010 OAGI0001367A_00267

Environmental Impacts of Operation 1 Federal poverty threshold in 1999 (USCB 2003-LandView 6). The 1999 Federal poverty 2 threshold was $17,029 for a family of four.

3 According to census data, the median household income for New York in 2004 was $45,343, 4 while 14.5 percent of the State's population was determined to be living below the Federal 5 poverty threshold. Westchester County had a much higher median household income 6 ($63,924) and a lower percentage (8.9 percent) of individuals living below the poverty level 7 when compared to the State. Dutchess, Orange, and Putnam Counties also had much higher 8 median household incomes in 2004 ($56,971, $54,771, and $75,514, respectively) and lower 9 percentages (7.7 percent, 10.2 percent, and 4.5 percent, respectively) of individuals living below 10 the poverty level when compared to the State (USCB 2008).

11 December 2010 4-51 NUREG-1437, Supplement 38 I OAGI0001367A_00268

Environmental Impacts of Operation 1

.... Connecticut

... ; :.:*;::c; Legend

_

Indicates censu.s block groups that meet the definition of a minority population County Boundaries o

D State Boundaries e-.-.-.-

7.5 15 30 iMiles PointWcView\Poverty.mxd 40 41 Figure 4-5. Minority block groups in 2000 within a 50-mi radius 42 of IP2 and IP3 (USCB 2008) 43 44 I NUREG-1437, Supplement 38 4-52 December 2010 OAGI0001367A_00269

Environmental Impacts of Operation 1 Census block groups were considered low-income block groups if the percentage of the 2 population living below the Federal poverty threshold exceeded the State percentage of 3 14.5 percent. Based on 2000 census data, Figure 4-6 of this SEIS shows low-income block 4 groups within a 50-mi (80-km) radius of IP2 and IP3.

5 Analysis of Impacts 6 The NRC addresses environmental justice matters for license renewal through (1) identification 7 of minority and low-income populations that may be affected by the proposed license renewal, 8 and (2) examining any potential human health or environmental effects on these populations to 9 determine if these effects may be disproportionately high and adverse.

10 11 The discussion and figures above indentify the location of minority and low-income populations 12 residing within a 50-mile (80-kilometer) radius of IP2 and IP3. This area of impact is consistent 13 with the impact analysis for public and occupational health and safety, which also considers the 14 radiological effects on populations located within a 50-mile (80-kilometer) radius of IP2 and IP3.

15 As previously discussed for the other resource areas in Chapter 4, the analyses of impacts for 16 all environmental resource areas indicated that the impact from license renewal would be 17 SMALL.

18 19 Socioeconomic conditions in minority and low-income communities would not change as a 20 result of renewing the IP2 and IP3 operating licenses. Employment levels and tax revenue 21 would remain relatively unchanged, so direct and indirect employment opportunities caused by 22 IP2 and IP3 would remain unchanged. Therefore, there would be no additional socioeconomic 23 impact to minority and low-income populations during the license renewal term beyond what is 24 currently being experienced.

25 26 Potential impacts to minority and low-income populations would mostly consist of radiological 27 effects; however radiation doses from continued operations associated with license renewal are 28 expected to continue at current levels, and would remain within regulatory limits. Chapter 5 29 discusses the environmental impacts from postulated accidents that might occur during the 30 license renewal term, which include both design basis and severe accidents. In both cases, the 31 Commission has generically determined that impacts associated with such accidents are 32 SMALL because nuclear plants are designed and operated to successfully withstand design 33 basis accidents, and the probability weighted impacts risks associated with severe accidents 34 were also SMALL.

35 36 Therefore, based on this information and the analysis of human health and environmental 37 impacts presented in Chapters 4 and 5 of this SEIS, there would be no disproportionately high 38 and adverse impacts to minority and low-income populations from the continued operation of 39 IP2 and IP3 during the license renewal period.

40 41 As discussed in Section 4.4.1, Entergy may replace the IP2 and IP3 reactor vessel heads and 42 CRDMs during the license renewal term (Entergy 2008b). Entergy estimates that this would 43 require an increase in the number of refueling outage workers for up to 60 days during two 44 separate refueling outages, one for each unit, 12 months apart (Entergy 2008b). This 45 replacement activity would have little noticeable affect on minority and/or low-income 46 populations in the region. These impacts are discussed in Chapter 3 of this SEIS.

December 2010 4-53 NUREG-1437, Supplement 38 OAGI0001367A_00270

Environmental Impacts of Operation 1 As part of addressing environmental justice associated with license renewal, the NRC also 2 analyzed the risk of radiological exposure through the consumption patterns of special pathway 3 receptors, including subsistence consumption of fish, native vegetation, surface waters, 4 sediments, and local produce; absorption of contaminants in sediments through the skin; and 5 inhalation of plant materials. The special pathway receptors analysis is important to the 6 environmental justice analysis because consumption patterns may reflect the traditional or 7 cultural practices of minority and low-income populations in the area.

8 Subsistence Consumption of Fish and Wildlife 9 Section 4-4 of Executive Order 12898 (1994) directs Federal agencies, whenever practical and 10 appropriate, to collect and analyze information on the consumption patterns of populations who 11 rely principally on fish and/or wildlife for subsistence and to communicate the risks of these 12 consumption patterns to the public. In this SEIS, the NRC staff considered whether there were 13 any means for minority or low-income populations to be disproportionately affected by 14 examining impacts to American Indian, Hispanic, and other traditional lifestyle special pathway 15 receptors. Special pathways that took into account the levels of contaminants in native 16 vegetation, crops, soils and sediments, surface water, fish, and game animals on or near the 17 IP2 and IP3 site were considered.

18 Entergy has a comprehensive Radiological Environmental Monitoring Program (REMP) at IP2 19 and IP3 to assess the impact of site operations on the environment. Samples are collected from 20 the aquatic and terrestrial pathways in the vicinity of IP2 and IP3. The aquatic pathways include 21 fish, Hudson River water, ground water, aquatic vegetation, sediment, and shoreline soil. The 22 terrestrial pathways include airborne particulates, broad leaf vegetation, and direct radiation.

23 During 2006, Entergy or its contractors performed 1342 analyses on collected samples of 24 environmental media as part of the required REMP which showed no significant or measurable 25 radiological impact from IP2 and IP3 operations (ENN 2007).

26 I NUREG-1437, Supplement 38 4-54 December 2010 OAGI0001367A_00271

Environmental Impacts of Operation 1

2 3

4 5

6 7

8 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 _Legend 37 Indicates census block groups that meet the definition of a poverty population County Boundaries 38 39 Water Bodies o State Boundaries o 7.5 15 30

~jP"W'I§_~-§--~~~~~IMiles Printing Date: May 12,2008 40 File: M:\1nGJS Data\lndian Point\ArcView\Poverty.mxd 41 42 Figure 4-6. Low-income block groups in 2000 within a 50-mi radius 43 of IP2 and IP3 (USCB 2008) 44 December 2010 4-55 NUREG-1437, Supplement 38 I OAGI0001367A_00272

Environmental Impacts of Operation 1 The NRC staff presents a summary of results from the IP2 and IP3 REMP program in 2 Section 2.2.7 of this SEIS. The results of the 2006 REMP (the most recent available) 3 demonstrate that the routine operation at the IP2 and IP3 site has had no significant or 4 measurable radiological impact on the environment. No elevated radiation levels were detected 5 in the offsite environment as a result of plant operations and the storage of radioactive waste.

6 The results of the REMP continue to demonstrate that the operation of IP2 and IP3 did not 7 result in a significant measurable dose to a member of the general population or adversely 8 impact the environment as a result of radiological effluents. The REMP continues to 9 demonstrate that the dose to a member of the public from the operation of IP2 and IP3 remains 10 significantly below the Federally required dose limits specified in 10 CFR Part 20 and 40 CFR 11 Part 190, "Environmental Radiation Protection Standards for Nuclear Power Operations."

12 The NRC staff's review of recent REMP monitoring results shows that concentrations of 13 contaminants in native leafy vegetation, soils and sediments, surface water, and fish in areas 14 surrounding IP2 and IP3 have been quite low (at or near the threshold of detection) and seldom 15 above background levels. Consequently, the NRC staff concludes that no disproportionately 16 high and adverse human health impacts would be expected in special pathway receptor 17 populations in the region as a result of subsistence consumption of fish and wildlife.

18 4.5 Ground Water Use and Quality 19 No Category 1 or Category 2 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, are 20 potentially applicable to IP2 and IP3 ground water use and quality during the renewal term. The 21 applicant stated in its ER that IP2 and IP3 do not use any ground water, though onsite 22 monitoring wells exist for the purpose of monitoring ground water conditions.

23 In the IP2 and IP3 ER, Entergy identified leakage from onsite spent fuel pools as potentially new 24 and significant information (Entergy 2007a). The NRC staff has reviewed Entergy's analysis of 25 the leakage and has conducted an extensive onsite inspection of leakage to ground water, as 26 identified in Section 2.2.7 of this SEIS. Based on the NRC staff's review of Entergy's analysis, 27 the NRC staff's adoption of the NRC inspection report findings in this SEIS, and Entergy's 28 subsequent statements (all discussed in Section 2.2.7), the NRC staff concludes that the 29 abnormal liquid releases discussed by Entergy in its ER, while new information, are within the 30 NRC's radiation safety standards contained in 10 CFR Part 20 and are not considered to have a 31 significant impact on plant workers, the public, or the environment (i.e., while the information 32 related to spent fuel pool leakage is new, it is not significant).

33 4.6 Threatened or Endangered Species 34 Potential impacts to threatened or endangered species are listed as a Category 2 issue in 35 10 CFR Part 51, Subpart A, Appendix B, Table B-1. This issue is listed in Table 4-10.

36 I NUREG-1437, Supplement 38 4-56 December 2010 OAGI0001367A_00273

Environmental Impacts of Operation 1 Table 4-10. Category 2 Issues Applicable to Threatened or Endangered Species during 2 the Renewal Term ISSUE-10 CFR Part 51, Subpart A, GElS 10 CFR 51.53(c)(3)(ii) 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 3 This issue requires consultation under Section 7 of the Endangered Species Act of 1973 (ESA 4 1973) with appropriate agencies to determine whether threatened or endangered species are 5 present and whether they would be adversely affected by continued operation of the nuclear 6 facility during the license renewal term. The presence of threatened or endangered species in 7 the vicinity of the IP2 and IP3 site is discussed in Sections 2.2.5.5 and 2.2.6.2 of this SEIS. In 8 2007, the NRC staff contacted NMFS and the U.S. Fish and Wildlife Service (FWS) to request 9 information on the occurrence of threatened or endangered species in the vicinity of the site and 10 the potential for impacts on those species from license renewal. NMFS identified in its response 11 two Federally protected sturgeon species under its jurisdiction as having the potential to be 12 affected by the proposed action (NMFS 2007a). FWS provided a link to the Web site of its New 13 York Field Office, where lists of species occurrences were available by county (FWS 2007).

14 Three terrestrial species with a Federal listing status were identified as potentially occurring at 15 or near the site-the Indiana bat (Myotis soda/is), bog turtle (C/emmys muhlenbergil), and New 16 England cottontail (Sylvi/agus transitiona/is).

17 Because the NRC recognizes that there is the potential that the continued operation of IP2 and 18 IP3 could adversely affect the Federally listed species shortnose sturgeon (Acipenser 19 brevirostrum), the NRC staff has prepared a biological assessment (BA) for NMFS that 20 documents its review. The BA is provided in Appendix E to this SEIS. During informal 21 consultation regarding the potential for effects on terrestrial threatened or endangered species, 22 FWS determined that a BA was not needed because there was no likelihood of adverse effects 23 on potentially occurring species under its jurisdiction (NRC 2008).

24 4.6.1 Aquatic Special Status Species 25 Pursuant to Section 7 of the Endangered Species Act of 1973 (ESA 1973), the NRC staff 26 requested in a letter dated August 16,2007 (NRC 2007a), that NMFS provide information on 27 Federally listed endangered or threatened species, as well as proposed candidate species. In 28 its response on October 4,2007 (NMFS 2007b), NMFS expressed concern that the continued 29 operation of IP2 and IP3 could have an adverse impact on the shortnose sturgeon, an 30 endangered species that occurs in the Hudson River. NMFS also noted that the Atlantic 31 sturgeon (A. oxyrinchus) also occurs in the river and is currently a candidate for listing as 32 threatened or endangered. The NRC staff also reviewed the list of threatened and endangered 33 fish species available at the NYSDEC Web site (NYSDEC 2008a) and determined that the only 34 listed species occurring in the Hudson River near the IP2 and IP3 facility was the shortnose 35 sturgeon. Based on this information, the NRC staff determined that an analysis of impacts was 36 required only for the shortnose sturgeon. The NRC staff has also included an assessment of 37 impact for the Atlantic sturgeon in this section on special status species given its status as a 38 candidate for listing.

December 2010 4-57 NUREG-1437, Supplement 38 I OAG10001367A_00274

Environmental Impacts of Operation 1 As described in Section 2.2.5.5 of this SEIS, the shortnose sturgeon is amphidromous, with a 2 range extending from St. Johns River, Florida, to St. John River, Canada. Unlike anadromous 3 species, shortnose sturgeons spend the majority of their lives in freshwater and move to salt 4 water periodically, independent of spawning periods (Collette and Klein-MacPhee 2002). The 5 shortnose sturgeon was listed on March 11, 1967, as endangered under the Endangered 6 Species Act of 1973, as amended. In 1998, a recovery plan for the shortnose sturgeon was 7 finalized by NMFS (NMFS 1998).

8 Shortnose sturgeon are found in the lower Hudson River and are dispersed throughout the river-9 estuary from late spring to early fall, congregating to winter near Sturgeon Point (RKM 139; RM 10 86). The population of shortnose sturgeon in the Hudson River has increased 400 percent 11 since the 1970s, according to Cornell University researchers (Bain et al. 2007). Woodland and 12 Secor (2007) estimate a fourfold increase in sturgeon abundance over the past 3 decades, but 13 report that the population growth slowed in the late 1990s as evidenced by the nearly constant 14 recruitment pattern at depressed levels relative to the classes in 1986-1992. Although the 15 Hudson River appears to support the largest population of shortnose sturgeon in the region, 16 Bain et al. (2007) report that other populations along the Atlantic coast are also increasing and 17 some appear to be nearing safe levels, suggesting that the overall population could recover if 18 full protection and management continue.

19 As described in Section 2.2.5.5 of this SEIS, the Atlantic sturgeon is an anadromous species 20 with a range extending from St. Johns River, Florida, to Labrador, Canada. This species is long 21 lived, matures slowly, and can reach 60 years of age (ASMFC 2007b; Gilbert 1989). In 1996, 22 the State of New York placed a moratorium on harvesting Atlantic sturgeon when it became 23 apparent that the Hudson River stock was overfished. Unfortunately, the American shad gill net 24 fishery continues to take subadult sturgeon as bycatch (e.g., the unintentional collection of some 25 species during the harvest or others). The Status Review Team for Atlantic Sturgeon concluded 26 in 2007 that the Hudson River subpopulation has a moderate risk (less than 50 percent) of 27 becoming endangered in the next 20 years because of the threat of commercial bycatch.

28 However, the New York Bight distinct population segment, which includes the Hudson River 29 subpopulation, was determined to have a greater than 50-percent chance of becoming 30 endangered in the foreseeable future. Despite this, the Hudson River supports the largest 31 subpopulation of spawning adults and juveniles, and the abundance appears to be stable or 32 even increasing (ASSRT 2007). Recent work by Sweka et al. (2007) suggests that a substantial 33 population of juvenile Atlantic sturgeon is present in Haverstraw Bay, and that this area should 34 be the focus of future monitoring studies to obtain the greatest statistical power for assessing 35 population trends.

36 To determine the potential adverse impacts of the IP2 and IP3 cooling system on these species, 37 the NRC staff evaluated the potential effects of entrainment, impingement, and thermal 38 discharges for all RIS, including both sturgeon species, in Sections 4.1.1, 4.1.2, and 4.1.3 of this 39 SEIS. Based on an evaluation of entrainment data provided by the applicant, there is no 40 evidence that the eggs or larvae of either species are commonly entrained at IP2 or IP3. The 41 potential impacts of thermal discharges on shortnose and Atlantic sturgeon cannot be 42 determined at this time because additional studies are required to quantify the extent and 43 magnitude of the thermal plume, as discussed in Section 4.1.4 of this SEIS.

44 Corrected impingement data provided by the applicant after the publication of the draft SEIS 45 (Entergy 2007b and 2009) shows that both species of sturgeon have been impinged at IP2 and NUREG-1437, Supplement 38 4-58 December 2010 OAGI0001367A_00275

Environmental Impacts of Operation 1 IP3, with impingement of Atlantic sturgeon accounting for the largest losses (Table 4-11). The 2 corrected data, however, reflect an order of magnitude less impingement than had been 3 suggested earlier. The corrected impingement data for the endangered shortnose sturgeon 4 show that from 1975 to 1990, 20 fish were impinged at IP2 and 11 fish were impinged at IP3.

5 Impingement of Atlantic sturgeon was much greater than that observed for shortnose sturgeon, 6 with 250 fish impinged at IP2 and 265 fish impinged at IP3 between 1975 and 1988. Installation 7 of modified Ristroph screens following the 1987-1990 monitoring period is expected to have 8 reduced impingement levels. Nonetheless, because more recent data are not available, the 9 NRC staff cannot determine whether the current impingement losses are similar to the past 10 observations.

11 Table 4-11. Impingement Data for Shortnose and Atlantic Sturgeon at IP2 and IP3, 12 1975-1990 (data from Entergy 2009 and 8arnthouse et al. 2009)

IP2 IP3 Study IP2 IP3 Grand Year Shortnose Atlantic Total Shortnose Atlantic Total Total Sturgeon Sturgeon Sturgeon Sturgeon 1975 1 118 119 NS NS 119 1976 2 8 10 8 8 18 1977 6 44 50 153 154 204 1978 2 16 18 3 21 24 42 1979 2 32 34 2 38 40 74 1980 o 9 9 10 11 20 1981 o 3 3 o 5 5 8 1982 o o 2 1983 o 3 3 o o o 3 1984 3 4 5 6 10 1985 o 8 8 o 17 17 25 1986 o 2 2 o 4 4 6 1987 2 2 4 2 6 1988 3 4 o 5 1989 o o o o 1990 o o 2 2 3 Grand 20 250 270 11 265 276 546 Total (a) _ = not sampled, unit not in operation 13 The NRC staff reviewed information from the site audit, Entergy's ER for the IP2 and IP3 site, 14 other reports, and information from NMFS. Based on the WOE information presented in Table 15 4-4, The NRC staff concludes that the impacts associated with the IP2 and IP3 cooling system 16 are Small for both Atlantic and shortnose sturgeon. The population trend LOE evaluation was 17 unresolved because the Hudson River monitoring programs were not designed to catch either 18 species. The NRC staff was also unable to determine the strength of connection for either 19 species using the Monte Carlo simulation modeling. Because historical impingements of 20 sturgeon have been relatively low, especially for shortnose sturgeon, the NRC staff concluded December 2010 4-59 NUREG-1437, Supplement 38 OAGI0001367A_00276

Environmental Impacts of Operation 1 that the strength of connection was low. Based on the WOE analysis described above, a 2 determination of Moderate or Large impact is not supported, and the NRC staff concludes that 3 the impacts of an additional 20 years (beyond the current term) of operation and maintenance of 4 the site on aquatic species that are Federally listed as threatened or endangered is SMALL.

5 The NRC staff is sending a revised biological assessment (BA) of the impacts of license 6 renewal on the shortnose sturgeon to NMFS to review as this SEIS goes to press (the BA will 7 be publicly available at ML102990042). Should NMFS determine that continued operation of 8 IP2 and IP3 has the potential to adversely impact the shortnose sturgeon, NMFS will issue a 9 biological opinion. Included in the biological opinion would be any reasonable and prudent 10 measures that the applicant could undertake, as well as the terms and conditions for the 11 applicant to comply with the formal Section 7 consultation. Possible mitigation measures could 12 range from a resumption of monitoring to determine the number of shortnose sturgeon impinged 13 at IP2 and IP3 to changes in the cooling water intake system, as described in Section 4.1.5 of 14 this FEIS. Additionally, as described in Chapter 8, the installation of cooling towers could 15 reduce impingement, entrainment, and thermal impacts for all aquatic resources, including 16 those that are Federally listed.

17 4.6.2 Terrestrial Threatened or Endangered Species 18 There are two Federally listed terrestrial species that have the potential to occur at or near the 19 IP2 and IP3 site and its associated transmission line ROWs, the endangered Indiana bat 20 (M. soda/is) and the threatened bog turtle (C. muhlenbergil). A candidate species, the New 21 England cottontail (S. transitiona/is), also may occur in the vicinity. The characteristics, habitat 22 requirements, and likelihood of occurrence of each of these species are discussed in 23 Section 2.2.6.2 of this SEIS.

24 Although Westchester County is within the potential range of the Indiana bat in New York, winter 25 hibernacula and summer maternity colonies and bachelor colonies are not known to be present 26 in the county or the vicinity of the site (NYNHP 2008a). The NRC staff notes that it is possible 27 that the 70-acre (ac) (28-hectare (ha)) forest at the north end of the site could provide summer 28 habitat for the Indiana bat because of the presence of suitable foraging habitat and possible 29 roosting trees in the forest and the presence of large hibernacula within migration distance of 30 the site. The ER indicated that no expansion of existing facilities or disturbance of forest or 31 other land on the site would occur during the renewal period. Thus, even if Indiana bats 32 currently utilize habitat on the site, it is not likely that they would be adversely affected by 33 ongoing operations and maintenance activities during the renewal period.

34 In Section 2.2.6.2, the NRC staff noted that the IP2 and IP3 site area does not have suitable 35 habitat for the bog turtle, and that bog turtles have not been observed in the region of 36 Westchester County near the IP2 and IP3 site (NYSDEC 2008b). The NRC staff acknowledged 37 that wetlands nearest the site had not, however, been evaluated for the presence of the bog 38 turtle. Given the available information, the NRC staff concludes that the bog turtle is not likely to 39 occur on or in the immediate vicinity of the site.

40 The known locations of the New England cottontail in Westchester County are in the central and 41 northeastern areas of the county (NYNHP 2008b), not in the northwestern area where the site is 42 located. The forests on the site consist mainly of mature hardwoods and do not contain early 43 successional habitats, such as thickets, that are required by the New England cottontail, so the NUREG-1437, Supplement 38 4-60 December 2010 OAGI0001367A_00277

Environmental Impacts of Operation 1 NRC staff does not expect the species to occur on or in the immediate vicinity of the site.

2 The NRC staff reviewed information from the site audit, Entergy's ER for the IP2 and IP3 site, 3 other reports, and information from FWS. Operation of IP2 and IP3 is not expected to adversely 4 affect any threatened or endangered terrestrial species during the license renewal term.

5 Therefore, the NRC staff concludes that the impacts of an additional 20 years of operation and 6 maintenance of the site, on terrestrial species that are Federally listed as threatened or 7 endangered would be SMALL. Because no listed species are known to be present in the area 8 of the IP2 and IP3 site, there are no recommended mitigation measures, unless the applicant 9 becomes aware of the presence of a listed species, in which case appropriate protective action 10 should be taken, and the NRC and FWS should be notified. Informal consultation with FWS 11 indicated that formal consultation and a BA are not required for terrestrial threatened or 12 endangered species.

13 4.7 Evaluation of New and Potentially Significant Information on 14 Impacts of Operations during the Renewal Term 15 The NRC staff has conducted its own independent review of environmental issues through staff 16 research, consultation with State and Federal agencies, and comments delivered to the NRC by 17 the public during the environmental scoping period and comments on the draft SEIS to identify 18 potentially new and significant information about environmental issues listed in 10 CFR Part 51, 19 Subpart A, Appendix B, Table B-1, related to operation of IP2 and IP3 during the renewal term.

20 Processes for identification and evaluation of new information are described in Section 1.2.2 of 21 this SEIS.

22 As discussed in Section 2.2.7 of this SEIS and synopsized in Section 4.5 of this chapter, 23 Entergy identified leakage from onsite spent fuel pools as potentially new information (Entergy 24 2007a). The NRC staff has reviewed Entergy's analysis of the leakage and has conducted an 25 extensive onsite inspection of leakage to ground water, as identified in Section 2.2.7 of this 26 SEIS. Based on the NRC staff's review of Entergy's ground water analyses, the NRC ground 27 water inspection report, and Entergy's subsequent statements (all discussed in Section 2.2.7 of 28 this SEIS), the NRC staff concludes that the abnormal liquid releases discussed by Entergy in 29 its ER, while constituting new information, are within the NRC's radiation safety standards 30 contained in 10 CFR Part 20 and are not considered to have a significant impact on plant 31 workers, the public, or the environment (i.e., while the information related to spent fuel pool 32 leakage is new, it is not significant).

33 The NRC staff did not identify any other information that was both new and significant. As such, 34 the NRC staff adopts the GElS findings for Category 1 issues applicable to Indian Point, as 35 described in the previous sections of this chapter.

36 4.8 Cumulative Impacts 37 The NRC staff considered potential cumulative impacts on the environment resulting from past, 38 present, and reasonably foreseeable future actions. The geographical area over which past, 39 present, and future actions are assessed is dependent on the affected resource.

40 The impacts of the proposed action, license renewal, as described in previous sections of December 2010 4-61 NUREG-1437, Supplement 38 OAGI0001367A_00278

Environmental Impacts of Operation 1 Chapter 4 of this SEIS, are combined with other past, present, and reasonably foreseeable 2 future actions in the potentially affected area regardless of which agency (Federal or non-3 Federal) or entity is undertaking the actions. The combined impacts are defined as "cumulative" 4 in 40 CFR 1508.7, "Cumulative Impact," and include individually minor but collectively significant 5 actions taking place over a period of time (CEQ 1997). It is possible that an impact that may be 6 SMALL by itself could result in a MODERATE or LARGE impact when considered in 7 combination with the impacts of other actions on the affected resource. Likewise, if a resource 8 is regionally declining or imperiled, even a SMALL direct or indirect impact could be important if 9 it contributes to or accelerates the overall resource decline.

10 The NRC staff has identified the principal past, present, and reasonably foreseeable future 11 actions potentially impacting the environment affected by IP2 and IP3. The potential cumulative 12 impacts of these actions are discussed below.

13 4.8.1 Cumulative Impacts on Aquatic Resources 14 The purpose of this section is to address past, present, and future actions that have created or 15 could result in cumulative adverse impacts to the aquatic resources of the lower Hudson River.

16 In Section 2.2.5.2 of this SEIS, the NRC staff discussed a wide variety of historical events that 17 have affected the Hudson River and its resources. The NRC staff notes that these historical 18 events are contributors to the cumulative effects on the Hudson River. In addition to the past 19 events in Section 2.2.5.2, the NRC staff has identified a variety of current and likely future 20 stressors that may also contribute to cumulative impacts. These stressors, included in the 21 following list, are consistent with those identified by the Pew Oceans Commission (2003).

22

  • the continued operation of the IP2 and IP3 once-through cooling system (addressed in 23 Section 4.1 of this Chapter) 24
  • continued withdrawal of water to support fossil fuel electrical generation or water for 25 human use 26
  • the presence of invasive or nuisance species 27
  • fishing pressure 28
  • habitat loss 29
  • changes to water and sediment quality 30
  • climate change 31 Each of these potential stressors may influence the structure and function of freshwater, 32 estuarine, and marine food webs and result in observable changes to the aquatic resources in 33 the lower Hudson River estuary. Examples of measurable changes to aquatic resources could 34 include the following:

35

  • reductions or increases in RIS populations or changes in their distribution 36
  • changes in predator-prey relationships or noticeable alterations to food webs, including 37 the permanent loss of species I NUREG-1437, Supplement 38 4-62 December 2010 OAGI0001367A_00279

Environmental Impacts of Operation 1

  • changes in contaminant body-burdens in fish and shellfish that result in the imposition or 2 lifting of consumption advisories 3
  • introduction of exotic or nuisance species and increases or decreases in populations of 4 existing invasive species 5 What follows is a brief discussion of how the stressors listed above might have cumulative 6 impacts on aquatic resources of the lower Hudson River estuary. An expanded discussion of 7 cumulative impacts is presented in Appendix H to this SEIS. Because in most cases it is not 8 possible to quantitatively determine the impact of each stressor, or a collection of stressors, on 9 the aquatic resources of the lower Hudson River, the following is a general discussion of 10 cumulative impacts.

11 Continued Operation of the IP2 and IP3 Once-Through Cooling System 12 Based on the assessment presented in Sections 4.1.3 and 4.1.4 of this SEIS, the NRC staff 13 concludes that the operation of IP2 and IP3 has the potential to adversely affect a variety of RIS 14 species that currently exist in the Hudson River between Troy Dam and the Battery. Based on 15 the staff's analysis of entrainment and impingement impacts, effects to RIS range from SMALL 16 to LARGE, depending on the species affected. As discussed in Section 4.6.1 of this SEIS, it is 17 also possible that the operation of IP2 and IP3 could be affecting the endangered shortnose 18 sturgeon and the listed Atlantic sturgeon. If the IP2 and IP3 once-through cooling system 19 continues to operate as it has for the past 3 decades, the NRC staff finds that it will continue to 20 contribute to cumulative effects.

21 Continued Water Withdrawals 22 As described in Section 2.2.5 of this SEIS, water is withdrawn from the Hudson River to support 23 fossil fuel electrical generation and to provide a source of drinking water. Although some fossil 24 fuel electrical generating stations that use natural gas or oil operate only intermittently, coal-fired 25 electrical generation stations that employ once-through cooling systems are expected to 26 continue to operate in the future. Likewise, water withdrawals in the freshwater portions of the 27 Hudson River will continue to occur and increase in the future. Because the NRC staff 28 concludes that water withdrawals from the Hudson River to support human needs will continue 29 and will likely increase during the relicensing term, this stressor will continue to contribute to the 30 cumulative effects in the river.

31 Invasive and Nuisance Species 32 As discussed in Section 2.2.5 of this SEIS, the presence of invasive or nuisance species in the 33 Hudson River estuary has been documented for over 200 years. While the presence of new or 34 exotic species can benefit some existing species, introductions of new species often have a 35 negative impact on their new environment. A classic example of the latter is the appearance of 36 the zebra mussel in the freshwater portion of the Hudson River in 1991. Since 1992, zebra 37 mussels have been a dominant species in the freshwater tidal portion of the Hudson River and 38 constitute more than half of heterotrophic biomass. Strayer (2007) estimated that the current 39 population is capable of filtering a volume of water equal to all of the water in the estuary every 40 1 to 4 days during the summer.

41 Some evidence suggests that the presence of zebra mussels can affect the species 42 composition in the Hudson River and the abundance of some Hudson River RIS. Strayer et al.

December 2010 4-63 NUREG-1437, Supplement 38 OAGI0001367A_00280

Environmental Impacts of Operation 1 (2004) hypothesized that the abundance or growth rates of American shad, blueback herring, 2 alewife, gizzard shad, white perch, and striped bass would decline following the zebra mussel 3 invasion or that their distributions within the river would shift downriver away from the zone of 4 greatest zebra mussel impacts. The authors found that significant decreases in the estimated 5 river-wide abundance of early life stages of several species of fish, including American shad and 6 white perch, coincided with the zebra mussel invasion. Barnthouse et al. (2008) also concluded 7 that zebra mussels may have contributed to declines in white perch populations but rejected the 8 hypothesis that zebra mussels were affecting American shad. The NRC staff's independent 9 analysis concluded that the presence of zebra mussels in the river would have a Small potential 10 for adverse impacts to the alewife, American shad, blueback herring, spottail shiner, striped 11 bass, white catfish, and white perch (Appendices H and I). The presence of invasive or 12 nuisance species in the lower Hudson River will continue to be a concern, as it is in other 13 locations throughout the world, and the presence of these species will continue to represent an 14 important source of cumulative impacts to the river.

15 Fishing Pressure 16 Many RIS are commercially or recreationally important, and are thus subject to effects from 17 fishing pressure. In many cases, the commercial or recreational catches of RIS are regulated 18 by Federal or State agencies or entities, but losses of some RIS continue to occur as the result 19 of bycatch. The extent and magnitude of fishing pressure and its relationship to overall 20 cumulative impacts to the aquatic resources of the lower Hudson River is difficult to determine 21 because of the large geographic scale and the natural variation that exists in the system.

22 Recent work by Barnthouse et al. (2008) has suggested that fishing pressure is contributing to 23 the decline of some RIS in the lower Hudson River, but this could not be confirmed by the staff.

24 The staff does acknowledge that fishing pressure (or the lack of it due to catch restrictions) has 25 the potential to influence the freshwater, estuarine, and marine food webs present in the lower 26 Hudson River and may contribute to cumulative impacts in the future.

27 Habitat Loss 28 As described in Section 2.2.5 of this SEIS, alterations to terrestrial, wetland, nearshore, and 29 aquatic habitats have occurred in the Hudson River estuary since colonial times. During the 30 colonization of the region, upland habitat alterations profoundly influenced watershed dynamics.

31 The creation of dams and the filling or isolation of wetlands to support industrial activities have 32 dramatically changed patterns of nutrients and sediment loading to the estuary. In addition, 33 historic dredging activities altered aquatic environments and affected river flow patterns, and 34 future activities, as described in Section 2.2.10 of this SEIS, may continue to influence the river.

35 Finally, development along the shores of the Hudson has resulted in the loss or isolation of 36 nearshore habitat, and the armoring of the shoreline in the lower portions of the river from 37 Yonkers to the Battery has effectively eliminated nearshore habitat. The NRC staff recognizes 38 that Federal, State, and local agencies, as well as many NGOs, are interested in restoring 39 habitat lost during past development and notes that the identification of four locations along the 40 lower Hudson River estuary for inclusion in the National Estuarine Research Reserve System in 41 1982 represents an important step in protecting and restoring important habitats.

42 Because habitat loss remains a concern, the NRC staff concludes that this stressor will continue 43 to be an important contributor to cumulative impacts to the lower Hudson River.

I NUREG-1437, Supplement 38 4-64 December 2010 OAGI0001367A_00281

Environmental Impacts of Operation 1 Water and Sediment Quality 2 In general, there is evidence to conclude that the overall quality of water and sediment in the 3 lower Hudson River is improving. Cleanup of polychlorinated biphenyls in stretches of the river 4 above the Troy Dam continues, and upgrades to wastewater treatment facilities during the past 5 20 years have reduced the amount of untreated sewage discharged into the river and 6 contributed to reductions in nutrients and an apparent increase in dissolved oxygen. Chemical 7 contaminants continue to persist in the tissues of fish and invertebrates inhabiting the lower 8 Hudson River, and the presence of nonpoint discharges of chemicals and constituents 9 continues to be a concern of local, State, and Federal regulatory agencies and NGOs. The 10 NRC staff concludes that the quality of water and sediment in the lower Hudson River will 11 continue to be a concern and a potential contributor to cumulative impacts.

12 Climate Change 13 The potential cumulative effects of climate change on the Hudson River watershed, whether 14 from natural cycles or related to anthropogenic activities, could result in a variety of changes 15 that would affect aquatic resources. The environmental factors of significance identified by 16 Kennedy (1990) that could affect estuarine systems included sea level rise, temperature 17 increase, salinity changes, and wind and water circulation changes. Changes in sea level could 18 result in dramatic effects to nearshore communities, including the reduction or redistribution of 19 submerged aquatic vegetation, changes to marsh communities, and influences to wetland areas 20 adjacent to nearshore systems. Water temperature increases could affect spawning patterns or 21 success, or influence the distribution of key RIS when cold-water species move northward while 22 warm-water species become established in new habitats. Changes to river salinity and the 23 presence of the salt front could influence the spawning and distribution of RIS and the range of 24 exotic or nuisance species. Fundamental changes in precipitation could profoundly influence 25 water circulation and change the nature of sediment and nutrient inputs to the system. This 26 could result in changes to primary production and influence the estuarine food web on many 27 levels. Kennedy (1990) also concluded that some fisheries and aquaculture enterprises might 28 benefit from climate change, while others would suffer extensive economic losses.

29 The extent and magnitude of climate change impacts to the aquatic resources of the lower 30 Hudson River are an important component of the cumulative assessment analyses and could be 31 substantial.

32 Final Assessment of Cumulative Impacts on Aquatic Resources 33 Based on the NRC staff's review, it is clear that Hudson River RIS are affected (some to a 34 lesser degree than others) by multiple stressors. The NRC staff's analysis (Appendix H) 35 demonstrated that the food web and abundance of RIS were noticeably altered, and many RIS 36 appeared to be directly influenced by the operation of the IP2 and IP3 cooling system (e.g., high 37 strength of connection). The impacts of some of the stressors may be addressed by 38 management actions (e.g., IP2 and IP3 cooling system operation, fishing pressure, and water 39 quality) and some cannot (e.g., long-term impacts associated with climate change). Although 40 the impacts associated with increased human populations and associated development of the 41 Hudson River basin, climate change, redistribution of resources, and the presence of invasive 42 species and disease cannot be quantitatively calculated, the cumulative impacts on aquatic 43 resources have had destabilizing effects on Hudson River living resources, including threatened 44 and endangered species (i.e., the net effect of all stressors destabilized some populations) and December 2010 4-65 NUREG-1437, Supplement 38 OAGI0001367A_00282

Environmental Impacts of Operation 1 are considered by the NRC staff to be LARGE.

2 4.8.2 Cumulative Impacts on Terrestrial Resources 3 This section addresses past, present, and future actions that could result in cumulative adverse 4 impacts on terrestrial resources, including wildlife populations, vegetation communities of 5 uplands and riparian zones, wetlands, and land use. For purposes of this analysis, the 6 geographic area considered consists of the IP2 and IP3 site, which encompasses its associated 7 transmission line ROWs, and the surrounding region of the lower Hudson Valley.

8 The changes in land use associated with historical settlement and development of this region 9 are described in Section 2.2.5.2 of this SEIS. During precolonial and colonial settlement by 10 European immigrants, large areas of the forest that had almost completely covered the region 11 were cleared for agriculture, and by 1880, 68 percent of the Hudson River watershed had 12 become farmland. Also in the 19th century, major changes in land use occurred in the region in 13 conjunction with the industrial revolution as human populations grew and houses, roads, 14 railroads, bridges, and industrial facilities were constructed. These historical trends of 15 increasing development and decreasing terrestrial habitat in the region continued through the 16 20th century to the present, resulting in large reductions in native forests and other habitats for 17 terrestrial wildlife, increases in precipitation runoff due to impervious surfaces, and pollution 18 (Swaney et al. 2006).

19 Before the historical clearing of land at the IP2 and IP3 site, the terrestrial communities of the 20 area consisted mainly of upland and riparian forests (NRC 1975). The site was originally 21 purchased in 1683 by a Dutch settler, who established a homestead there. By the latter 19th 22 century, the north end of Indian Point was being surface mined for iron, and a lime kiln and blast 23 furnace were located at the shoreline. By 1900 a brickyard existed on the site, and farming still 24 occurred there. In 1920 an amusement park was built on the site. The park closed in 1956, and 25 construction of the first commercial nuclear reactor in the United States then began at the site 26 (Enercon 2007). Thus, the site had been largely cleared of forest and developed for various 27 uses for well over a century before its development for power generation began in the second 28 half of the 20th century. Power plant development resulted in over half of the site (134 ac 29 (54.2 ha)) being covered by facilities and pavement, with forest having regenerated at the north 30 end of the site where mining occurred historically. Remaining native forest habitat in central and 31 southern portions of the site has been fragmented by roads, ROWs, parking areas, and other 32 development, a phenomenon that has commonly occurred in the region.

33 Developed areas with impervious surfaces have increased precipitation runoff and reduced 34 infiltration into the soil, thus reducing ground water recharge, altering streamflow, and increasing 35 soil erosion. Maintenance of vegetation in ROWs and other developed areas, such as by 36 mowing and spraying of herbicides, has altered the ecological communities in these areas by 37 preventing natural succession. It also likely has resulted in increases in invasive species, such 38 as Japanese knotweed (Fal/opia japonica), which typically are more aggressive than native 39 species in colonizing disturbed areas; increases in species that prefer edge habitat; and 40 decreases in species that prefer interior forest habitat. Such effects from development within 41 the IP2 and IP3 site contribute to cumulative impacts from similar effects on native ecological 42 communities from other development in the region.

43 Land use data provide an indication of the impacts on terrestrial resources that have resulted NUREG-1437, Supplement 38 4-66 December 2010 OAGI0001367A_00283

Environmental Impacts of Operation 1 from historical and ongoing development. Current land uses in the region are discussed by 2 county in Section 2.2.8.3 of this SEIS. In Westchester County, based on 1992 data, forest was 3 the predominant type of land cover (53 percent), followed by residential (30 percent),

4 agricultural and recreational (7 percent), and commercial/industrial/transportation uses 5 (3 percent) (Entergy 2007a). In four nearby counties in the lower Hudson Valley (Rockland, 6 Orange, Putnam, and Dutchess), forest also was the predominant type of land cover, followed 7 by residential or agricultural, and commercial/industrial/transportation land uses ranged from 8 about 1 to 4 percent (Entergy 2007a). Thus, commercial, industrial, and transportation facilities, 9 including the IP2 and IP3 site, have had a relatively small impact on the loss of native terrestrial 10 forest habitats in the region compared to residential and agricultural development. The 11 commercial, industrial, and transportation facilities that have impacted terrestrial resources in 12 the region in addition to the IP2 and IP3 site include six power generation facilities on the 13 Hudson River between RM 37 and 67 (RKM 60 to 97), highways, railways along both sides of 14 the river, and manufacturing plants.

15 Although development of the site has contributed to cumulative impacts on terrestrial resources 16 from historical and ongoing development in the region, portions of the site have been protected 17 from development. The 70-ac (28-ha) forest community at the north end of the site has been 18 and, under the proposed action, would continue to be preserved, providing a beneficial effect by 19 reducing the potential for cumulative impacts from further loss of forests in the region. In 20 conjunction with this onsite forest tract, public lands in the region also preserve forest habitat 21 and have a beneficial cumulative impact on terrestrial resources. These lands include three 22 State parks in Westchester County and a total of 22 others in Rockland, Orange, Putnam, and 23 Dutchess Counties (Entergy 2007a), as well as forested lands of the New York State National 24 Guard's Camp Smith and the U.S. Military Academy at West Point.

25 Ultimately, development of the IP2 and IP3 site for power generation contributed incrementally 26 to a substantial, cumulative reduction in terrestrial resources resulting from other development 27 activities in the region that have occurred since precolonial times. However, as discussed in 28 Section 4.4.3 of this SEIS, there would be no population-related land use impacts attributable to 29 IP2 and IP3 during the license renewal term beyond those already being experienced, and there 30 would be no noticeable change in land use conditions in the vicinity of IP2 and IP3.

31 The NRC staff concludes that the impact of past, present, and reasonably foreseeable future 32 actions in the region on terrestrial resources is considered LARGE relative to predevelopment 33 conditions, and that much of this impact had occurred before the construction and operation of 34 IP2 and IP3.

35 4.8.3 Cumulative Radiological Impacts 36 The radiological dose limits for protection of the public and workers have been developed by the 37 NRC and EPA to address the cumulative impact of acute and long-term exposure to radiation 38 and radioactive material. These dose limits are codified in 10 CFR Part 20 and 39 40 CFR Part 190. For the purpose of this analysis, the area within a 50-mi (80.4-km) radius of 40 the IP2 and IP3 site was included. The radiological environmental monitoring program 41 conducted by Entergy in the vicinity of the IP2 and IP3 site measures radiation and radioactive 42 materials from all sources; therefore, the monitoring program measures cumulative radiological 43 impacts. Within the 50-mi (80-km) radius of the IP2 and IP3 site there are no other nuclear 44 power reactors or uranium fuel cycle facilities. The NRC staff reviewed the 1993 and 1994 December 2010 4-67 NUREG-1437, Supplement 38 OAGI0001367A_00284

Environmental Impacts of Operation 1 radiological environmental monitoring data from the area around IP2 and IP3 reported by 2 New York State; the data showed no adverse environmental impact. For the new issue 3 identified by Entergy concerning the tritium leak into the Hudson River, the NRC staff also 4 reviewed the information reported by Entergy, the NYSDEC and NYSDOH, and by the NRC.

5 No adverse impacts were identified (Entergy 2007b, NYSDEC and NYSDOH 2008, NRC 2006b, 6 NRC 2007b).

7 Radiation monitoring results for the 5-year period from 2002 to 2006 were reviewed as part of 8 the cumulative impacts assessment. In Sections 2.2.7 and 4.3 of this SEIS, the NRC staff 9 concluded that impacts of radiation exposure to the public and workers (occupational) from 10 operation of IP2 and IP3 during the renewal term are SMALL. The NRC and the State of New 11 York would regulate any future actions in the vicinity of the IP2 and IP3 site that could contribute 12 to cumulative radiological impacts (Entergy 2003,2004,2005,2006, 2007b).

13 Entergy constructed an independent spent fuel storage installation (lSFSI) on the IP2 and IP3 14 site in 2008 for the storage of its spent fuel. The installation and monitoring of this facility is 15 governed by NRC requirements in 10 CFR Part 72, "Licensing Requirements for the 16 Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-17 Related Greater Than Class C Waste." Radiation from this facility as well as from the operation 18 of IP2 and IP3 must not exceed the radiation dose limits in 10 CFR Part 20,40 CFR Part 190, 19 and 10 CFR Part 72 (Entergy 2007a).

20 In addition, Entergy has indicated that it may replace IP2 and IP3 reactor vessel heads and 21 CRDMs during the period of extended operation. Such an action is not expected to change the 22 applicant's ability to maintain radiological doses to members of the public well within regulatory 23 limits because the amount of radioactive liquid, gaseous, and solid waste is not expected to 24 increase significantly (see Sections 2.1.4 and 2.2.7 of this SEIS for the detailed discussion).

25 For these reasons, the NRC staff concludes that cumulative radiological impacts are SMALL, as 26 are the contribution to radiological impacts from continued operation of IP2 and IP3 and their 27 associated ISFSI. The NRC and the State of New York will continue to regulate operation of 28 IP2 and IP3 for radiological impacts.

29 4.8.4 Cumulative Socioeconomic Impacts 30 As discussed in Section 4.4 of this SEIS, continued operation of IP2 and IP3 during the license 31 renewal term would have no impact on socioeconomic conditions in the region beyond those 32 already being experienced. Since Entergy has indicated that it plans to hire no additional non-33 outage workers during the license renewal term, overall expenditures and employment levels at 34 IP2 and IP3 would be expected to remain relatively constant with no additional demand for 35 permanent housing, public utilities, and public services. In addition, since employment levels 36 and the value of IP2 and IP3 would not change, there would be no population and tax-revenue-37 related land use impacts. Also, there would be no disproportionately high and adverse health 38 and environmental impacts on minority and low-income populations in the region.

39 Entergy has indicated that it may replace the IP2 and IP3 reactor vessel heads and CRDMs, 40 Entergy estimates that this replacement activity would require an increase in the number of 41 refueling outage workers for up to 60 days during two separate refueling outages, one for each 42 unit, 12 months apart (Entergy 2008b). These additional workers would create short-term 43 increases in the demand for temporary (rental) housing, increased use of public water and NUREG-1437, Supplement 38 4-68 December 2010 OAGI0001367A_00285

Environmental Impacts of Operation 1 sewer services, and transportation impacts on access roads in the immediate vicinity of IP2 and 2 IP3. Given the short amount of time needed for this replacement activity, the cumulative effects 3 of these replacement activities on socioeconomic conditions in the vicinity of IP2 and IP3 would 4 not likely be noticeable. Also, there would be no long-term cumulative socioeconomic impacts 5 after the reactor vessel heads and CRDMs are replaced.

6 In general, the region surrounding IP2 and IP3 has experienced growing population, increasing 7 economic activity and tax revenue, and changes in demographics over time. These effects in 8 the region have been LARGE, though the contribution of IP2 and IP3 to these effects have been 9 SMALL, except, in some cases, locally. Additionally, development in the region has had a 10 significant effect on historical and archaeological resources, which could be LARGE, as the 11 region is home to significant historic and prehistoric resources (as noted in 4.4.5, however, 12 continued operation of the plant would only have SMALL effects on historic and archaeological 13 resources).

14 4.8.5 Cumulative Impacts on Ground Water Use and Quality 15 In 2005 tritium was located in ground water beneath the IP2 and IP3 site. During a subsequent 16 subsurface monitoring program at the site, radioactive forms of cesium, cobalt, nickel, and 17 strontium also were found. The radiological impact of these elements to the ground water is 18 discussed in Section 2.2.7 of this SEIS, and referenced in Sections 4.5 and 4.7.

19 The topography of the site and the foundation drains around the structures result in a flow 20 regime that transports ground water towards the Hudson River. As a result, the contaminated 21 ground water will be transported to the Hudson River and not offsite in a direction that might 22 lead it to be captured by an offsite ground water user. The results of monitoring programs 23 support this conclusion.

24 Because the water travels offsite and into the Hudson River, there are no users for onsite 25 ground water. Any effects from the plant, previous development, or future development on site 26 will likely remain confined to effects on ground water transiting the site to the Hudson River, and 27 thus, are likely to be limited.

28 On the basis of the topography of the site, the characteristics of the subsurface media, location 29 of the plant relative to the Hudson River, recent ground water monitoring observations, and the 30 fact that there are no users for the site's ground water, the NRC staff concludes that the 31 cumulative impact on the site's ground water use and quality are SMALL.

32 4.8.6 Conclusions Regarding Cumulative Impacts 33 The NRC staff considered the potential impacts resulting from the operation of IP2 and IP3 and 34 resulting from other past, present, and reasonably foreseeable future actions in the vicinity. The 35 NRC staff's determination is that the cumulative impacts to the environment surrounding IP2 36 and IP3 from past and present human activities (beyond impacts from IP2 and IP3) have 37 generally been LARGE and could continue to be LARGE in some issue areas. Future 38 development is likely to continue to affect these resources.

39 4.9 Summary of Impacts of Operations during the Renewal 40 Term December 2010 4-69 NUREG-1437, Supplement 38 I OAGI0001367A_00286

Environmental Impacts of Operation 1 The NRC staff did not identify any information that is both new and significant related to any of 2 the applicable Category 1 issues associated with the operation of IP2 and IP3 during the 3 renewal term, including information related to ground water contamination at Indian Point.

4 Consequently, the NRC staff concludes that the environmental impacts associated with these 5 issues are bounded by the impacts described in the GElS. For each of these issues, the GElS 6 concluded that the impacts would be SMALL and that additional plant-specific mitigation 7 measures are not likely to be sufficiently beneficial to warrant implementation.

8 Thirteen of the site-specific environmental issues identified in the GElS related to operational 9 impacts and postulated accidents during the renewal term are discussed in detail in this SEIS.

10 These include 11 Category 2 issues and two uncategorized issues (environmental justice and 11 the chronic effects of EMFs). The NRC staff did not evaluate the chronic effects of EMFs 12 because research is continuing in the area and no scientific consensus on human health 13 impacts exists. The NRC staff's will evaluation of severe accident mitigation alternatives is in 14 Chapter 5.

15 For 6 of the remaining 10 Category 2 issues and environmental justice, the NRC staff concluded 16 that the potential impacts of continued plant operation during the license renewal period on 17 these issues are of SMALL significance in the context of the standards set forth in the GElS.

18 For four of these issues, the NRC staff concluded that the impacts of continued operation would 19 have a significant effect. On the issue of heat shock on the aquatic ecology, the NRC staff 20 concludes that effects are of SMALL to LARGE significance, given uncertainty about actual 21 thermal effects of the plant. The NRC staff evaluated the combined effects of entrainment and 22 impingement on aquatic life and found the impacts to be MODERATE. However, these impact 23 level conclusions are based on historical data as previously discussed in this SEIS. Finally, 24 unlike in the draft SEIS, the NRC staff found that impacts to threatened and endangered aquatic 25 species are likely to be SMALL, based on corrected data submitted by Entergy.

26 4.10 References 27 Abood, K.A., T.L. Englert, S.G. Metzger, C.V. Beckers, Jr., T.J. Groninger, and S. Mallavaram.

28 2006. Current and evolving physical and chemical conditions in the Hudson River Estuary.

29 American Fisheries Society Symposium 51 :39-61.

30 Achman, D.R., B.J. Brownawell, and L. Zhang. 1996. Exchange of polychlorinated biphenyls 31 between sediment and water in the Hudson River Estuary. Estuaries 19(4):950-965.

32 Atlantic States Marine Fisheries Commission (ASMFC). 2006. "Species Profile: Atlantic 33 Striped Bass, The Challenges of Managing a Restored Stock." Available at URL:

34 http://www.asmfc.org/speciesDocuments/stripedBass/speciesprofile.pdf. Accessed December 35 10,2007.

36 Atlantic States Marine Fisheries Commission (ASMFC). 2007a. "Species Profile: Weakfish-37 The Challenge of Managing a Stock Decline When Fishing is Not the Cause." ASMFC 38 Fisheries Focus, Vol. 16, Issue 4: May/June 2007. Accessed at 39 http://www.asmfc.org/speciesDocuments/weakfish/weakfishProfile.pdf on February 17, 2008.

40 Atlantic States Marine Fisheries Commission (ASMFC). 2007b. "Species Profile: Atlantic 41 Sturgeon, Ancient Species' Slow Road to Recovery." Available at URL: http://www.asmfc.org/

42 speciesDocuments/sturgeon/sturgeonProfile.pdf. Accessed December 6,2007. ADAMS NUREG-1437, Supplement 38 4-70 December 2010 OAGI0001367A_00287

Environmental Impacts of Operation 1 Accession No. ML083360698.

2 Atlantic Sturgeon Status Review Team (ASSRT). 2007. "Status Review of Atlantic Sturgeon 3 (Acipenser oxyrinchus oxyrinchus)." Report to National Marine Fisheries Service, Northeast 4 Regional Office. February 23,2007. 174 pp. Available at URL:

5 http://www. nmfs. noaa. gov/pr/pdfs/statusreviews/atlanticsturgeon2007. pdf. Accessed December 6 7,2007.

7 Baird, D., and R.E. Ulanowicz. 1989. The seasonal dynamics of the Chesapeake Bay 8 ecosystem. Ecological Monographs 59(4):329-364.

9 Bain, M.B., N. Haley, D.L. Peterson, K.K. Arend, K.E. Mills, and P.J. Sullivan. 2007. "Recovery 10 of a US Endangered Fish." PLoS ONE 2(1): e168. Department of Natural Resources, Cornell 11 University, Ithaca, New York. Available at URL: http://www.plosone.org/article/info 12 percent3Adoi percent2F10.1371 percent2Fjournal.pone.0000168#s3. Accessed December 11, 13 2007.

14 Barnthouse, L.W., C.C. Coutant, and W. Van Winkle. 2002. "Status and Trends of Hudson 15 River Fish Populations and Communities Since the 1970's: Evaluation of Evidence Concerning 16 Impacts of Cooling Water Withdrawals." January 2002. ADAMS Accession No. ML083360704.

17 Barnthouse, L.W., D.G. Heimbuch, W. Van Winkle, and J. Young. 2008. "Entrainment and 18 Impingement at IP2 and IP3: A Biological Impact Assessment." January 2008. ADAMS 19 Accession No. ML080390059.

20 Barnthouse, L.W., D.G. Heimbuch, M. Mattson, and J.R. Young. 2009. Review of NRC's 21 Impingement and Entrainment Assessment for IP2 and IP3. (Data from Table A-1). March 16, 22 2009. Enclosure 6 in Entergy Nuclear Northeast (Entergy). 2009. Letter from F. Dacimo, Vice 23 President, Entergy Nuclear Northeast, to U.S. Nuclear Regulatory Commission, Chief, 24 Rulemaking, Directives and Editing Branch. Reference NL-09-036.

Subject:

Comments on 25 NUREG-1437, Draft Supplement 38. March 18,2009. ADAMS Accession No. ML091040133.

26 Brosnan, T.M. and M.L. O'Shea. 1996. Long-term improvements in water quality due to 27 sewage abatement in the lower Hudson River. Estuaries 19(4)890-900.

28 Central Hudson Gas and Electric Corporation; Consolidated Edison Company New York, Inc.;

29 New York Power Authority; and Southern Energy New York (CHGEC et al.). 1999. "Draft 30 Environmental Impact Statement for State Pollutant Discharge Elimination System Permits for 31 Bowline Point, Indian Point 2 and 3, and Roseton Steam Electric Generating Stations."

32 December 1999. ADAMS Accession No. ML083400128.

33 Clean Water Act of 1977 (CWA). 33 U.S.C. 1326 et seq. (common name of the Federal Water 34 Pollution Control Act of 1977).

35 Cochran, W.G. 1997. Sampling Techniques. John Wiley and Sons, New York, New York. 428 36 pp.

37 Collette, B.B., and G. Klein-MacPhee (eds.). 2002. Bigelow and Schroeder's Fishes of the Gulf 38 Of Maine. (3rd Ed.) 748 pp. Smithsonian Institute Press, Herndon, Virginia.

39 Consolidated Edison Company of New York (Con Edison). 1976a. "IP2 and IP3 Impingement 40 Study Report for the Period 1 January 1975-31 December 1975." Prepared by Texas 41 Instruments, Inc. ADAMS Accession No. ML083360750.

December 2010 4-71 NUREG-1437, Supplement 38 I OAGI0001367A_00288

Environmental Impacts of Operation 1 Consolidated Edison Company of New York (Con Edison). 1976b. "Predation by Bluefish in the 2 Lower Hudson River." Prepared by Texas Instruments, Inc. ADAMS Accession No. ML 3 Consolidated Edison Company of New York (Con Edison). 1977. "Hudson River Ecological 4 Study in the Area of IP2 and IP3 1976 Annual Report." Prepared by Texas Instruments, Inc.

5 ADAMS Accession No. ML08309161.

6 Consolidated Edison Company of New York (Con Edison). 1979. "Hudson River Ecological 7 Study in the Area of IP2 and IP3 1977 Annual Report." Prepared by Texas Instruments, Inc.

8 ADAMS Accession No. ML083091068.

9 Consolidated Edison Company of New York (Con Edison). 1980. "Hudson River Ecological 10 Study in the Area of IP2 and IP3 1979 Annual Report." Prepared by Texas Instruments, Inc.

11 ADAMS Accession No. ML083360740.

12 Consolidated Edison Company of New York (Con Edison). 1984a. "Hudson River Ecological 13 Study in the Area of IP2 and IP3 1981 Annual Report." ADAMS Accession No. ML083091069.

14 Consolidated Edison Company of New York (Con Edison). 1984b. "Precision and Accuracy of 15 Stratified Sampling to Estimate Fish Impingement at Indian Point Unit No.2 and Unit No.3."

16 Prepared by Normandeau Associates, Inc. ADAMS Accession No. ML083360792.

17 Consolidated Edison Company of New York, Inc. (Con Edison). 2007. Letter from J. McAvoy, 18 Vice President, ConEdison, to F. Dacimo, Vice President, Entergy Nuclear Operations. January 19 19,2007.

20 Consolidated Edison Company of New York (Con Edison) and New York Power Authority 21 (NYPA). 1984. "Indian Point Generating Station Entrainment Abundance and Outage 22 Evaluation 1993 Annual Report." Prepared by EA Science and Technology, Inc.

23 Consolidated Edison Company of New York (Con Edison) and New York Power Authority 24 (NYPA). 1986. "Hudson River Ecological Study in the Area of IP2 and IP3 1985 Annual 25 Report." Prepared by Normandeau Associates, Inc. ADAMS Accession No. ML083091074.

26 Consolidated Edison Company of New York (Con Edison) and New York Power Authority 27 (NYPA). 1987. "Hudson River Ecological Study in the Area of IP2 and IP3 1986 Annual 28 Report." Prepared by Normandeau Associates, Inc. ADAMS Accession No. ML083091087.

29 Consolidated Edison Company of New York (Con Edison) and New York Power Authority 30 (NYPA). 1988. "Hudson River Ecological Study in the Area of IP2 and IP3 1987 Annual 31 Report." Prepared by EA Science and Technology. ADAMS Accession No. ML083091084.

32 Consolidated Edison Company of New York (Con Edison) and New York Power Authority 33 (NYPA). 1991. "Hudson River Ecological Study in the Area of IP2 and IP3 1990 Annual 34 Report." Prepared by EA Science and Technology. ADAMS Accession No. ML083091086.

35 Council on Environmental Quality (CEQ). 1997. "Environmental Justice: Guidance under the 36 National Environmental Policy Act." Executive Office of the President, Washington, DC.

37 Daniels, R.A., K.E. Limburg, R.E. Schmidt, D.L. Strayer, and R.C. Chambers. 2005. "Changes 38 in Fish Assemblages in the Tidal Hudson River, New York." American Fisheries Society 39 Symposium 45:471-503. Available at URL: http://www.ecostudies.org/reprints/

40 daniels_et_al_2005.pdf. Accessed March 13, 2008.

NUREG-1437, Supplement 38 4-72 December 2010 OAGI0001367A_00289

Environmental Impacts of Operation 1 Ecological Analyses, Inc. (EA). 1981a. "Indian Point Generating Station Entrainment Survival 2 and Related Studies. 1979 Annual Report." Prepared for Consolidated Edison Company of 3 New York, Inc., and Power Authority of the State of New York. Ecological Analysts, Inc.

4 January 1982. ADAMS Accession No. ML073330733.

5 Ecological Analyses, Inc. (EA). 1981b. "1981 Con Edison Automated Abundance Sampling 6 (AUTOSAM) and Laboratory Processing Standard Operating Procedures." Prepared for 7 Consolidated Edison Company of New York, Inc. Ecological Analysts, Inc. May 1981.

8 ADAMS Accession No. ML083100602.

9 Ecological Analyses, Inc. (EA). 1982. "Indian Point Generating Station Entrainment Survival 10 and Related Studies. 1980 Annual Report." Prepared for Consolidated Edison Company of 11 New York, Inc., and Power Authority of the State of New York. Ecological Analysts, Inc. April 12 1981. ADAMS Accession No. ML073330737.

13 Ecological Analyses, Inc. (EA). 1984. "Indian Point Generating Station Entrainment Abundance 14 and Outage Evaluation, 1983 Annual Report." Prepared for Consolidated Edison Company of 15 New York, Inc., and Power Authority of the State of New York. EA Engineering, Science, and 16 Technology, Inc. September 1984. ADAMS Accession No. ML083101084.

17 Ecological Analyses, Inc. (EA). 1985. "Indian Point Generating Station Entrainment Abundance 18 and Outage Evaluation, 1983 Annual Report." Prepared for Consolidated Edison Company of 19 New York, Inc., and Power Authority of the State of New York. EA Science and Technology.

20 July 1985. ADAMS Accession No. ML083101091.

21 Ecological Analyses, Inc. (EA). 1989. "Indian Point Generating Station 1988 Entrainment 22 Survival Study." Prepared for Consolidated Edison Company of New York, Inc., and Power 23 Authority of the State of New York. EA Engineering, Science, and Technology, Northeast 24 Regional Operations, Report No. 10648.03. August 1989. ADAMS Accession No.

25 ML083101103.

26 Enercon Services Inc. (Enercon). 2007. "Phase 1A Literature Review and Archaeological 27 Sensitivity Assessment of the Indian Point Site, Westchester County, New York." Enercon 28 Services Inc., Tulsa, Oklahoma. March 2007.

29 Enercon. 2008. "Enercon Study ELEC-IP-08001 for IP2 and IP3 License Renewal Project 345 30 kV Transmission Line-Induced Shock Study." April 11 ,2008. Prepared for Entergy Nuclear 31 Operations, Inc.

32 Entergy Nuclear Northeast (ENN). 2007. "Indian Point Nuclear Power Plants Units 1,2, and 3, 33 Annual Radiological Environmental Operating Report for 2006." Buchanan, New York. May 34 2007.

35 Entergy Nuclear Operations Inc. (Entergy). 2003. "Indian Point Nuclear Plant Units No.1, 2, 36 and 3-Annual Radiological Environmental Operating Report for 2002." Docket Numbers 50-3, 37 50-247, and 50-286. Buchanan, New York. Agencywide Documents Access and Management 38 System (ADAMS) Accession No. ML031220085.

39 Entergy Nuclear Operations Inc. (Entergy). 2004. "Indian Point Nuclear Power Plants Units 1, 40 2, and 3-Annual Radiological Environmental Operating Report for 2003." Docket Numbers 50-41 3,50-247, and 50-286. Buchanan, New York. ADAMS Accession No. ML041340492.

42 December 2010 4-73 NUREG-1437, Supplement 38 OAGI0001367A_00290

Environmental Impacts of Operation 1 Entergy Nuclear Operations Inc. (Entergy). 2005. "Indian Point Units 1,2, and 3-2004 2 Annual Radiological Environmental Operating Report." Docket Numbers 50-3,50-247, and 50 3 286. Buchanan, New York. ADAMS Accession No. ML051220210.

4 Entergy Nuclear Operations Inc. (Entergy). 2006. "Indian Point, Units 1,2 and 3-Annual 5 Radiological Environmental Operating Report for 2005." Docket Numbers 50-3,50-247, and 50 6 286. Buchanan, New York. ADAMS Accession No. ML061290085.

7 Entergy Nuclear Operations, Inc. (Entergy). 2007a. "Applicant's Environment Report, 8 Operating License Renewal Stage." (Appendix E to Indian Point, Units 2 and 3, License 9 Renewal Application). April 23, 2007. ADAMS Accession No. ML071210530.

10 Entergy Nuclear Operations Inc. (Entergy). 2007b. "IP2 and IP3, Units 1,2, and 3-Annual 11 Radiological Environmental Operating Report for 2006." Docket Numbers 50-3,50-247, and 50 12 286. Buchanan, New York. ADAMS Accession No. ML071420088.

13 Entergy Nuclear Operations, Inc. (Entergy). 2007c. Letter from F.R. Dacimo, Vice President, 14 Entergy Nuclear Operations, Inc. to Document Control Desk, U.S. Nuclear Regulatory 15 Commission.

Subject:

Entergy Nuclear Operations, Inc., Indian Point Nuclear Generating Unit 16 Nos. 2 & 3; Docket Nos. 50-247 and 50-286; Supplement to License Renewal Application (LRA) 17 - Environmental Report References. ADAMS Nos. ML080080205, ML0800080209, 18 ML080080214, ML0800802161, ML0800080291, ML080080298, ML080080306, and 19 ML080080313.

20 Entergy Nuclear Operations, Inc. (Entergy). 2008a. Letter from F. Dacimo, Vice President, 21 Entergy Nuclear Operations, to U.S. Nuclear Regulatory Commission Document Control Desk.

22

Subject:

Reply to Document Request for Additional Information Regarding Site Audit Review of 23 License Renewal Application for Indian Point Nuclear Generating Unit Nos. 2 and 3. April 23, 24 2008. ADAMS Accession No. ML081230243.

25 Entergy Nuclear Operations, Inc. (Entergy). 2008b. Letter from F. Dacimo, Vice President, 26 License Renewal, to U.S. Nuclear Regulatory Commission Document Control Desk.

Subject:

27 Reply to Document Request for Additional Information Regarding License Renewal 28 Application-Refurbishment. May 14, 2008. ADAMS Accession No. ML081440052.

29 Entergy Nuclear Northeast (Entergy). 2009a. Letter from F. Dacimo, Vice President, Entergy 30 Nuclear Northeast, to U.S. Nuclear Regulatory Commission Document Control Desk.

31 Reference NL-09-160.

Subject:

Request for Additional Information Related to License Renewal 32 Indian Point Nuclear Application Environmental Report - Impingement Data Indian Point Nuclear 33 Generating Unit Nos. 2 & 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64.

34 November 24,2009. ADAMS Accession No. ML093420528.

35 Entergy Nuclear Northeast (Entergy). 2009b. "Documents Related to License Renewal 36 Application - Environmental Report. Indian Point Nuclear Generating Unit Nos. 2 & 3. Docket 37 Nos. 50-247 and 50-286. License Nos. DPR-26 and DPR-64." December 17, 2009. Buchanan, 38 NY. ADAMS No. ML100290495 (cover letter only; report withheld to protect sensitive 39 archaeological data).

40 Entergy Nuclear Northeast (Entergy). 2010. "Detailed Responses to the New York State 41 Department of Environmental Conservation's (the Department) Request for Information, dated 42 May 13, 2009 (the "RFI"), Exhibit K: Thermal Compliance Report." February 10, 2010.

43 A va iIa bl e URL: !J1tp..J!.w.w.w.:.g.~.~:JJy':.gQ.v.!.g.Q~§!.p..~.r.m.i.t.§~~LQp..~.r.g.tj.Q.o.lLP'9f!.~.l§~Qg.r.~.~.tJl:Kp'.g.f.

NUREG-1437, Supplement 38 4-74 December 2010 OAGI0001367A_00291

Environmental Impacts of Operation 1 Environmental Protection Agency (EPA). 1998. Guidelines for Ecological Risk Assessment.

2 EPA/630/R-95/002F. Risk Assessment Forum, Washington, D.C. Available at URL:

3 http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=12460. Accessed December 12, 2008.

4 Environmental Protection Agency (EPA). 2004. "Total Maximum Daily Loads, Listed Water 5 Information, Cycle: 2004. Hudson River, Lower Hudson River." U.S. Environmental Protection 6 Agency. Available at URL: http://oaspub.epa.gov/tmdl/enviro.control?pJisUd=NY-1301-7 0002andp_cycle=2004. Accessed February 23,2008.

8 Environmental Protection Agency (EPA). 2008a. "Phase II-Large Existing Electric Generating 9 Plant. Proposed Rule, Technical Development Document." Available at URL:

10 http://www.epa.gov/waterscience/316b/phase2/devdocl. Accessed April 10, 2008.

11 Environmental Protection Agency (EPA). 2008b. "Hudson River PCB Superfund Site, Dredge 12 Area 2 Delineation Fact Sheet, 2008." Available at URL: http://www.epa.gov/

13 hudson/factsheet_2nd_phaselow.pdf. Accessed February 4,2008. ADAMS Accession No.

14 ML083360712.

15 Endangered Species Act of 1973 (ESA). 16 U.S.C 1531, etseq.

16 Fish and Wildlife Service (FWS). 2007. Letter from R.A. Niver, Endangered Species Biologist, 17 to Rani Franovich, Branch Chief, Projects Branch 2, Division of License Renewal, Office of 18 Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington, DC.

19 Response to letter from the U.S. Nuclear Regulatory Commission requesting information on 20 Federally listed, proposed, and candidate species and critical habitat in the vicinity of Indian 21 Point Nuclear Generating Unit Nos. 2 and 3. August 29, 2007. ADAMS Accession No.

22 ML0732307840.

23 Fletcher, R.I. 1990. Flow dynamics and fish recovery experiments: Water intake systems.

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

25 Frank, K.T., B. Petrie, and N.L. Shackell. 2007. The ups and downs of trophic control in 26 continental shelf ecosystems. Trends in Ecology and Evolution 22(5):236-242.

27 Greenwood, M.FD. 2008. Trawls and cooling-water intakes as estuarine fish sampling tools:

28 Comparisons of catch composition, trends in relative abundance, and length selectivity.

29 Estuarine, Coastal and Shelf Science 76:121-130.

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 EL-33 82-4. 28 pp.

34 Haas-Castro, R. 2006. "Status of Fishery Resources off the Northeastern U.S.: River Herring."

35 Northeast Fisheries Science Center Resource Evaluation and Assessment Division, National 36 Oceanic and Atmospheric Administration. Accessed at 37 http://www. nefsc. noaa. gov/sos/spsyn/af/herring/archives/38_RiverHerring_2006. pdf on 38 December 17,2007. ADAMS Accession No. ML083390029.

39 Institute of Electrical and Electric Engineers (IEEE). 1997. "National Electric Safety Code."

40 New York.

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Environmental Impacts of Operation 1 Marcy, B.C., D.E. Fletcher, F.D. Martin, M.H. Paller, and M.J.M. Reichert. 2005. "Spottail 2 Shiner." In: Fishes of the Middle Savannah River Basin. Athens, GA: University of Georgia 3 Press, pp. 153-156.

4 Maryland Department of Natural Resources, Fisheries Service, Chesapeake Finfish Program 5 (MDNR). February 2005. 2004 Stock Assessment of Selected Resident and Migratory 6 Recreational Finfish Species within Maryland's Chesapeake Bay. Accessed at 7 http://dnr.maryland.gov/fisheries/managementltidalmng.html(under the link for White Perch) on 8 February 4,2010.

9 Mayhew, D.A., LD. Jensen, D.F. Hanson, and P.H. Muessig. 2000. A comparative review of 10 entrainment survival studies at power plants in estuarine environments. Environmental Science 11 and Policy 3:295-301.

12 Menzie, C., M.H. Henning, J. Cura, K. Finkelstein, J. Gentile, J. Maughan, D. Mitchell, S.

13 Petron, B. Potocki, S. Svirsky, and P. Tyler. 1996. Report of the Massachusetts Weight-of-14 Evidence Workgroup: A weight-of-evidence approach for evaluating ecological risks. Human 15 and Ecological Risk Assessment 2:277-304.

16 Munch, S.B., and D.O. Conover. 2000. Recruitment dynamics of bluefish (Pomatomus 17 saltatrix) from Cape Hatteras to Cape Cod, 1973-1995. ICES Journal of Marine Sciences 18 57(2):393-402.

19 National Environmental Policy Act of 1969 (NEPA). 42 U.S.C. 4321 et seq.

20 National Institute of Environmental Health Sciences (NIEHS). 1999. "NIEHS Report on Health 21 Effects from Exposure to Power-Line Frequency Electric and Magnetic Fields." NIH Publication 22 No. 99-4493, Research Triangle Park, North Carolina.

23 National Marine Fisheries Service (NMFS). 1998. "Recovery Plan for the Shortnose Sturgeon 24 (Acipenser brevirostrum)." Prepared by the Shortnose Sturgeon Recovery Team for the 25 National Marine Fisheries Service, Silver Spring, Maryland. 104 pp. Available at URL:

26 http://www.nmfs.noaa.gov/pr/pdfs/recovery/sturgeon_shortnose.pdf. Accessed December 11, 27 2007.

28 National Marine Fisheries Service (NMFS). 2007a. Letter from M. Colligan, Assistant Regional 29 Administrator for Protected Resources, to Chief, Rules and Directives Branch, Division of 30 Administrative Services, U.S. Nuclear Regulatory Commission, Washington, DC. Response to 31 letter of August 10,2007, from the U.S. Nuclear Regulatory Commission requesting information 32 on Federally listed, proposed, and candidate species, critical habitat, and designated essential 33 fish habitat in the vicinity of Indian Point Nuclear Generating Unit Nos. 2 and 3. October 4, 34 2007. ADAMS Accession No. ML073230796.

35 National Marine Fisheries Service (NMFS). 2007b. "Species of Concern: Atlantic Sturgeon, 36 Acipenser oxyrinchus." Available at URL: http://www.nmfs.noaa.gov/pr/pdfs/species/

37 atlanticsturgeon_detailed.pdf. Accessed December 6,2007.

38 New York Natural Heritage Program (NYNHP). 2008a. "Online Conservation Guide for Myotis 39 sodalis." Available at URL: http://www.acris.nynhp.org/guide.php?id=7405. Accessed March 40 21,2008. ADAMS Accession No. ML083390018.

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Environmental Impacts of Operation 1 New York Natural Heritage Program (NYNHP). 2008b. "Online Conservation Guide for 2 Sylvilagus transitional is." Available at URL: http://www.acris.nynhp.org/guide.php?id=7415.

3 Accessed March 21,2008. ADAMS Accession No. ML083390017.

4 New York Power Authority. 1986. "Size Selectivity and Relative Catch Efficiency of a 3-m 5 Beam Trawl and a 1-m2 Epibenthic Sled for Sampling Young of the Year Striped Bass and 6 Other Fishes in The Hudson River Estuary." Prepared by Normandeau Associates, Inc.

7 January 1986. (HR Library #7180). ADAMS Accession No. ML083360641.

8 New York State Department of Environmental Conservation (NYSDEC). 1997. NRDC vs.

9 NYSDEC, et al. Fourth Amended Consent Order. Letter from Keith Silliman on April 23, 1997.

10 New York State Department of Environmental Conservation, Office of General Counsel.

11 New York State Department of Environmental Conservation (NYSDEC). 2003a. "Final 12 Environmental Impact Statement Concerning the Applications to Renew New York State 13 Pollutant Discharge Elimination System (SPDES) Permits for the Roseton 1 and 2, Bowline 1 14 and 2, and Indian Point 2 and 3 Steam Electric Generating Stations, Orange, Rockland and 15 Westchester Counties. Hudson River Power Plants FEIS." June 25,2003. ADAMS Accession 16 No. ML083360752.

17 New York State Department of Environmental Conservation (NYSDEC). 2003b. Fact Sheet.

18 "New York State Pollutant Discharge Elimination System (SPDES) Draft Permit Renewal with 19 Modification, IP2 and IP3 Electric Generating Station, Buchanan, NY." November 2003.

20 Available at URL: http://www.dec.ny.gov/docs/permits_eLoperations_pdf/lndianPointFS.pdf.

21 Accessed July 12, 2007. ADAMS Accession No. ML083360743.

22 New York State Department of Environmental Conservation (NYSDEC). 2007. State of New 23 York Petition submitted to the U.S. Nuclear Regulatory Commission, November 30,2007, on 24 the Application of Entergy Nuclear Operations, Inc., for the 20-year Relicensing of Indian Point 25 Nuclear Power Plants 1 and 2, Buchanan, New York. Summary of Some of the Key 26 Contentions. Available at URL: http://www.dec.ny.gov/permits/40237.html. Accessed March 27 18,2008. ADAMS Accession No. ML083360757.

28 New York State Department of Environmental Conservation (NYSDEC). 2008a. "List of 29 Endangered, Threatened and Special Concern Fish and Wildlife Species of New York."

30 Available at URL: http://www.dec.ny.gov/animals/7494.html. Accessed May 3,2008. ADAMS 31 Accession No. ML083380558.

32 New York State Department of Environmental Conservation (NYSDEC). 2008b. "New York 33 State Amphibian and Reptile Atlas Project." Available at URL: http://www.dec.ny.gov/

34 animals/7479.html?showprintstyles. Accessed March 13,2008.

35 New York State Department of Environmental Conservation (NYSDEC). 2010. Letter from 36 William R. Adriance, Chief Permit Administrator, to Dara F. Gray, Entergy Nuclear Operations, 37 Inc. "Joint Application for CWA § 401 Water Quality Certification, NRC License Renewal-38 Entergy Nuclear Indian Point Units 2 and 3, DEC Nos.: 3-5522-00011/00030 (lP2) and 3-5522-39 00105/00031 (lP3), Notice of Oenia/." April 2, 2010. Albany, NY. Available URL:

40 http://www.dec.ny.gov/docs/permits_eLoperations_pdf/ipdeniaI4210.pdf.

41 New York State Department of Environmental Conservation (NYSDEC) and New York State 42 Department of Health (NYSDOH). 2008. "Groundwater Investigation." Albany, New York.

43 Available at URL: http://www.dec.ny.gov/permits/44014.html.

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Environmental Impacts of Operation 1 Normandeu Associates (Normandeu). 1987a. Prepared for Consolidated Edison Company of 2 New York, Inc., and New York Power Authority. Prepared by Normandeu Associates, Inc.

3 Report R-332-1062. April 1987. ADAMS Accession No. ML0803091074.

4 Normandeu Associates (Normandeu). 1987b. "Indian Point Generating Station Entrainment 5 Abundance Program, 1986 Annual Report." Prepared for Consolidated Edison Company of 6 New York, Inc., and New York Power Authority. Prepared by Normandeu Associates, Inc.

7 Report R 220. June 1987. ADAMS Accession No. ML083091087.

8 Normandeu Associates (Normandeu). 1988. "IP2 and IP3 Generating Station Entrainment 9 Abundance Program, 1987 Annual Report." Prepared for Consolidated Edison Company of 10 New York, Inc., and New York Power Authority. Prepared by Normandeu Associates, Inc.

11 Report R 1110. May 1988. ADAMS Accession No. M L083360798.

12 Northeast Fisheries Science Center (NEFSC). 2005. 41st Northeast Regional Stock 13 Assessment Workshop (41st SAW): 41st SAW Assessment Report. Northeast Fisheries 14 Science Center Reference Document 05-14.

15 Nuclear Regulatory Commission (NRC). 1975. "Final Environmental Statement Related to the 16 Operation of IP2 and IP3 Nuclear Generating Plant Unit No.3, Consolidated Edison Company 17 of New York, Inc." NUREG-75/002.

18 Nuclear Regulatory Commission (NRC). 1996. "Generic Environmental Impact Statement for 19 License Renewal of Nuclear Power Plants." NUREG-1437, Volumes 1 and 2, Washington, DC.

20 Nuclear Regulatory Commission (NRC). 1999. "Generic Environmental Impact Statement for 21 License Renewal of Nuclear Plants Main Report," Section 6.3, "Transportation," Table 9.1, 22 "Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants."

23 NUREG-1437, Volume 1, Addendum 1, Washington, DC 24 Nuclear Regulatory Commission (NRC). 2005. "Generic Environmental Impact Statement for 25 License Renewal of Nuclear Plants, Supplement 22 Regarding Millstone Power Station, Units 2 26 and 3, Final Report." NUREG-1437. Office of Nuclear Reactor Regulation. Washington, D.C.

27 Nuclear Regulatory Commission (NRC). 2006a. NUREG-1437, Supplement 20, "Generic 28 Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Donald C.

29 Cook Nuclear Plant, Units No.1 and 2," Washington, DC.

30 Nuclear Regulatory Commission (NRC). 2006b. "Indian Point Nuclear Generating Unit 2-NRC 31 Special Inspection Report No. 05000247/2005011." Docket Number 50-247. Washington, DC.

32 ADAMS Accession No. ML060750842.

33 Nuclear Regulatory Commission (NRC). 2007a. Letter from R. Franovich to Mr. Peter Colosi, 34 National Marine Fisheries Service, Gloucester, Massachusetts. Re: Request for List of 35 Protected Species and Essential Fish Habitat within the Area under Evaluation for the IP2 and 36 IP3 Nuclear Generating Unit Nos. 2 and 3 License Renewal Application Review. August 16, 37 2007. ADAMS Accession No. ML072130388.

38 Nuclear Regulatory Commission (NRC). 2007b. "Indian Point Nuclear Generating Unit 2-39 Routine Integrated Inspection Report No. 05000247/07003." Docket Number 50-247.

40 Washington, DC. ADAMS Accession No. ML072150161.

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Environmental Impacts of Operation 1 Pew Oceans Commission. 2003. America's Living Oceans: Charting a Course for Sea 2 Change. Pew Oceans Commission, Arlington, VA Available at http://www.pewoceans.org.

3 Raffenberg, M.J., J.A Matousek, W.o. Saksen, AJ. McCusker, and E.W. Radle. 2008.

4 "Development of Filter Fabric Barrier to Reduce Aquatic Impacts at Water Intake Structures."

5 Available at URL: http://www.epa.gov/waterscience/presentations/raffenberg.pdf. Accessed 6 April 9, 2008.

7 Riverkeeper. 2007. Re: Acceptance Review for Entergy Nuclear IP2 and IP3 License Renewal 8 Application. Letter to Mr. Bo Pham, Environmental Project Manager, Division of License 9 Renewal, on June 4,2007, from Phillip Musegaas, Riverkeeper Staff Attorney.

10 Secor, D.H. and E.D. Houde. 1995. Temperature effects on the timing of striped bass egg 11 production, larval viability, and recruitment potential in the Patuxent River (Chesapeake Bay).

12 Estuaries 18:527-533.

13 Shepherd G. 2006. 'Atlantic Striped Bass." December 2006. Accessed at:

14 http://www.nefsc.noaa.gov/sos/spsyn/af/sbass/archives/40_ StripedBass_2006. pdf on December 15 10,2007. ADAMS Accession No. ML083360766.

16 Shepherd, G. 2006. "Bluefish." Available at URL: http://www.nefsc.noaa.gov/

17 sos/spsyn/op/bluefish/archives/25_Bluefish_2006.pdf. Accessed October 2,2008. ADAMS 18 Accession No. ML083360690.

19 Smith, C.L. 1985. "Spottail Shiner." In: The Inland Fishes of New York State, pp. 194-195.

20 New York State Department of Environmental Conservation, Albany, NY.

21 Snedecor, G.W. and W.G. Cochran. 1980. Statistical Methods. The Iowa State University 22 Press, Ames, Iowa, 507 pp.

23 Steinberg, N., D.J. Suszkowski, L. Clark, and J. Way. 2004. "Health of the Harbor: The First 24 Comprehensive Look at the State of the NY.NY Harbor Estuary. A Report to the New York/New 25 Jersey Harbor Estuary Program." Hudson River Foundation. New York, New York. ADAMS 26 Accession No. ML083360712.

27 Strayer, D.L., K.A Hattala, and AW. Kahnle. 2004. Effects of an invasive bivalve (Dreissena 28 polymorpha) on fish in the Hudson River Estuary. Canadian Journal of Fisheries and Aquatic 29 Sciences 61 :924-941.

30 Sweka, J.A, J. Mohler, M.J. Millard, T. Kehler, A Kahnle, K. Hattala, G. Kenney, and A Higgs.

31 2007. Juvenile Atlantic sturgeon habitat use in Newburgh and Haverstraw Bays of the Hudson 32 River: Implications for population monitoring. North American Journal of Fisheries 33 Management 27:1058-1067.

34 Ulanowicz, R.E. 1995. "Trophic Flow Networks as Indicators of Ecosystem Stress." In G.A 35 Polis and K.O. Winemiller (eds). Food Webs: Integration of Patterns and Dynamics, Chapman 36 and Hall, New York. pp. 358-368.

37 U.S. Atomic Energy Commission (USAEC). 1972. "Final Environmental Statement Related to 38 the Operation of Indian Point Nuclear Generating Plant No.2." Docket No. 50-247. United 39 States Atomic Energy Commission, Directorate of Licensing. September 1972.

40 December 2010 4-79 NUREG-1437, Supplement 38 OAGI0001367A_00296

Environmental Impacts of Operation 1 U.S. Census Bureau (USCB). 2003. "LandView 6-Census 2000 Profile of General 2 Demographic Characteristics DP-1 (100 percent) and Census Profile of Selected Economic 3 Characteristics DP-3, Summary of Census Block Groups in a 50-Mile Radius around the IP2 4 and IP3 Energy Center (41.269722 Lat., -73.952083 Long.)." December 2003.

5 U.S. Census Bureau (USCB). 2008. "American FactFinder, Census 2000 Information and 6 State and County QuickFacts on Dutchess, Orange, Putnam, and Westchester Counties."

7 Available at URL: http://factfinder.census.gov and http://quickfacts.census.gov. Accessed April 8 2008.

9 Wolfe, D.A., E.R. Long, and G.B. Thursby. 1996. Sediment toxicity in the Hudson-Raritan 10 Estuary: Distribution and correlations with chemical contamination. Estuaries 19(4):901-912.

11 Woodland, R.J. and D.H Secor. 2007. Year-class strength and recovery of endangered 12 shortnose sturgeon in the Hudson River, New York. Transactions of the American Fisheries 13 Society 136:72-81.

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5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS Environmental issues associated with postulated accidents are discussed in NUREG-1437, Volumes 1 and 2, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants" (hereafter referred to as the GElS) (NRC 1996, 1999).(1) The GElS includes a determination of whether the analysis of the environmental issues could be applied to all plants and whether additional mitigation measures would be warranted. Issues are then assigned a Category 1 or a Category 2 designation. As set forth in the GElS, Category 1 issues are those that meet all of the following criteria:

(1) The environmental impacts associated with the issue have been determined to apply either to all plants or, for some issues, to plants having a specific type of cooling system or other specified plant or site characteristics.

(2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to the impacts (except for collective offsite radiological impacts from the fuel cycle and from high-level waste and spent fuel disposal).

(3) Mitigation of adverse impacts associated with the issue has been considered in the analysis, and it has been determined that additional plant-specific mitigation measures are likely not to be sufficiently beneficial to warrant implementation.

For issues that meet the three Category 1 criteria, no additional plant-specific analysis is required unless new and significant information is identified.

Category 2 issues are those that do not meet one or more of the criteria for Category 1 and, therefore, additional plant-specific review of these issues is required.

This chapter describes the environmental impacts from postulated accidents that might occur during the license renewal term.

5.1 Postulated Plant Accidents Two classes of accidents are evaluated in the GElS. These are design-basis accidents (DBAs) and severe accidents, as discussed below.

5.1.1 Design-Basis Accidents In order to receive U.S. Nuclear Regulatory Commission (NRC) approval to operate a nuclear power facility, an applicant for an initial operating license must submit a safety analysis report (SAR) as part of its application. The SAR presents the design criteria and design information for the proposed reactor and comprehensive data on the proposed site. The SAR also discusses various hypothetical accident situations and the safety features that are provided to prevent and mitigate accidents. The NRC staff reviews the application to determine whether the plant design meets the Commission's regulations and requirements and includes, in part, the nuclear plant design and its anticipated response to an accident.

DBAs are those accidents that both the licensee and the NRC staff evaluate to ensure that the (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 2010 5-1 NUREG-1437, Supplement 38 OAGI0001367A_00298

Environmental Impacts of Postulated Accidents plant can withstand normal and abnormal transients, as well as a broad spectrum of postulated accidents, without undue hazard to the health and safety of the public. A number of these postulated accidents are not expected to occur during the life of the plant, but are evaluated to establish the design basis for the preventive and mitigative safety systems of the facility. The acceptance criteria for DBAs are described in Title 10, Part 50, "Domestic Licensing of Production and Utilization Facilities," of the Code of Federal Regulations (10 CFR Part 50) and 10 CFR Part 100, "Reactor Site Criteria."

The environmental impacts of DBAs are evaluated during the initial licensing process, and the ability of the plant to withstand these accidents is demonstrated to be acceptable before issuance of the operating license. The results of these evaluations are found in licensing documentation such as the applicant's final safety analysis report, the NRC staff's safety evaluation report, the final environmental statement (FES), and Section 5.1 of this draft supplemental environmental impact statement (SEIS). A licensee is required to maintain the acceptable design and performance criteria throughout the life of the plant, including any extended-life operation. The consequences for these DBAs are evaluated for the hypothetical maximally exposed individual. Changes in the plant's surroundings, including local population, will not affect the evaluation for the maximally exposed individual. Because of the requirements that continuous acceptability of the consequences and aging management programs be in effect for license renewal, the environmental impacts as calculated for DBAs should not differ significantly from initial licensing assessments over the life of the plant, including the period of extended operation. Accordingly, the design of the plant relative to DBAs during the extended period is considered to remain acceptable, and the environmental impacts of those accidents were not examined further in the GElS.

The Commission has determined that the environmental impacts of DBAs are of SMALL significance for all plants because the plants were designed to successfully withstand these accidents. Therefore, for the purposes of license renewal, DBAs are designated as a Category 1 issue in Table B-1 of Appendix B to Subpart A, "Environmental Effect of Renewing the Operating License of a Nuclear Power Plant," of 10 CFR Part 51, "Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions." The early resolution of the DBAs makes them a part of the current licensing basis (CLB) of the plant; the CLB of the plant, which is maintained by the licensee under its current license, will continue to be maintained under a renewed license in accordance with 10 CFR 54.33, "Continuation of CLB and Conditions of Renewed License." Therefore, under the provisions of 10 CFR 54.30, "Matters Not Subject to a Renewal Review," the CLB is not subject to review under license renewal. This issue, applicable to Indian Point Nuclear Generating Unit Nos. 2 and 3 (lP2 and IP3), is listed in Table 5-1.

Table 5-1. Category 1 Issues Applicable to Postulated Accidents during the Renewal Term ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Sections POSTULATED ACCIDENTS Design-basis accidents 5.3.2; 5.5.1 Based on information in the GElS, the Commission found the following:

The NRC staff has concluded that the environmental impacts of design-basis accidents are of small significance for all plants.

Entergy Nuclear Operations, Inc. (Entergy), stated in the IP2 and IP3 environmental report (ER)

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Environmental Impacts of Postulated Accidents (Entergy 2007a) that it is not aware of any new and significant information associated with the renewal of the IP2 and IP3 operating licenses. The NRC staff has not identified any new and significant information during its independent review of the IP2 and IP3 ER, the site visit, the scoping process, or evaluation of other available information. Therefore, the NRC staff concludes that there are no impacts related to DBAs beyond those discussed in the GElS.

5.1.2 Severe Accidents Severe nuclear accidents are those that are more severe than DBAs because they could result in substantial damage to the reactor core, regardless of offsite consequences. In the GElS, the NRC staff assessed the impacts of severe accidents using the results of existing analyses and site-specific information to conservatively predict the environmental impacts of severe accidents for each plant during the renewal period.

Severe accidents initiated by external phenomena, such as tornadoes, floods, earthquakes, fires, and sabotage, traditionally have not been discussed in quantitative terms in FESs and were not specifically considered for IP2 and IP3 in the GElS. However, in the GElS, the NRC staff did evaluate existing impact assessments performed by the NRC and by the industry at 44 nuclear plants in the United States and concluded that the risk from beyond-design-basis earthquakes at existing nuclear power plants is SMALL. The GElS for license renewal documents a discretionary analysis of acts of sabotage in connection with license renewal, and concluded that the core damage and radiological release from such acts would be no worse than the damage and release expected from internally initiated events. In the GElS, the Commission concluded that the risk from sabotage and beyond-design-basis earthquakes at existing nuclear power plants is small and, additionally, that the risks from other external events are adequately addressed by a generic consideration of internally initiated severe accidents (see Volume 1 of the GElS, page 5-18).

Based on information in the GElS, the Commission found the following:

The probability weighted consequences of atmospheric releases, fallout onto open bodies of water, releases to groundwater, and societal and economic impacts from severe accidents are small for all plants. However, alternatives to mitigate severe accidents must be considered for all plants that have not considered such alternatives.

Therefore, the Commission has designated mitigation of severe accidents as a Category 2 issue in 10 CFR Part 51, Subpart A, Appendix B, Table B-1. This issue, applicable to IP2 and IP3, is listed in Table 5-2.

Table 5-2. Category 2 Issues Applicable to Postulated Accidents 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 The NRC staff has not identified any new and significant information with regard to the consequences from severe accidents during its independent review of the IP2 and IP3 ER December 2010 5-3 Draft NUREG-1437, Supplement 38 OAGI0001367A_00300

Environmental Impacts of Postulated Accidents (Entergy 2007a), the site visit, the scoping process, or evaluation of other available information.

Therefore, the NRC staff concludes that there are no impacts of severe accidents beyond those discussed in the GElS. However, in accordance with 10 CFR 51.53(c)(3)(ii)(L), the NRC staff has reviewed severe accident mitigation alternatives (SAMAs) for IP2 and IP3. The results of its review are discussed in Section 5.2 of this draft SEIS.

5.2 Severe Accident Mitigation Alternatives As required by 10 CFR 51.53(c)(3)(ii)(L), license renewal applicants must consider alternatives to mitigate severe accidents if the staff has not previously evaluated SAMAs for the applicant's plant in an environmental impact statement (EIS), or related supplement, or in an environmental assessment. The purpose of this consideration is to ensure that plant changes (i.e., hardware, procedures, and training) with the potential for improving severe accident safety performance are identified and evaluated. SAMAs have not been previously considered for IP2 and IP3; therefore, the remainder of Chapter 5 addresses those alternatives.

5.2.1 Introduction This section presents a summary of the SAMA evaluation for IP2 and IP3, conducted by Entergy, and the NRC staff's review of that evaluation. The NRC staff performed its review with contract assistance from Information Systems Laboratories, Inc. and Sandia National Laboratory. The NRC staff's review is available in greater detail in Appendix G to this draft SEIS; the SAMA evaluation is available in Entergy's ER and subsequent submittals identified herein.

The SAMA evaluation for IP2 and IP3 was conducted using a four-step approach. In the first step, Entergy quantified the level of risk associated with potential reactor accidents using the plant-specific probabilistic safety assessment (PSA) and other risk models.

In the second step, Entergy examined the major risk contributors and identified possible ways (i.e., SAMAs) of reducing that risk. Common ways of reducing risk are changes to components, systems, procedures, and training. Entergy initially identified 231 and 237 potential SAMAs for IP2 and IP3, respectively. For each unit, Entergy performed an initial screening in which it eliminated SAMAs that are not applicable to IP2 and IP3 because of design differences, have already been implemented at IP2 and IP3, or are similar in nature and could be combined with another SAMA candidate. This screening reduced the list of potential SAMAs to 68 for IP2 and 62 for IP3.

In the third step, Entergy estimated the benefits and the costs associated with each of the remaining SAMAs. Estimates were made of how much each SAMA could reduce risk. Those estimates were developed in terms of dollars in accordance with NRC guidance for performing regulatory analyses (NRC 1997). The cost of implementing the proposed SAMAs also was estimated.

Finally, in the fourth step, the costs and benefits of each of the remaining SAMAs were compared to determine whether the SAMA was cost beneficial, meaning the benefits of the SAMA were greater than the cost (a positive cost benefit). Entergy concluded in its ER that several of the SAMAs evaluated for each unit are potentially cost beneficial (Entergy 2007b).

However, in response to NRC staff inquiries regarding estimated benefits for certain SAMAs, the meteorological data used in the analysis, and lower cost alternatives, several additional potentially cost-beneficial SAMAs were identified (Entergy 2008a, Entergy 2009). The NRC staff identifies potentially cost-beneficial SAMAs in Section 5.2.5.

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Environmental Impacts of Postulated Accidents The potentially cost-beneficial SAMAs do not relate to adequately managing the effects of aging during the period of extended operation; therefore, they are not required to be implemented as part of license renewal pursuant to 10 CFR Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants." Entergy's SAMA analyses and the NRC's review are discussed in more detail below.

5.2.2 Estimate of Risk Entergy submitted an assessment of SAMAs for IP2 and IP3 as part of the ER (Entergy 2007b).

This assessment was based on the most recent IP2 and IP3 PSA available at that time, a plant-specific offsite consequence analysis performed using the MELCOR Accident Consequence Code System 2 (MACCS2) computer program, and insights from the IP2 and IP3 individual plant examination (Con Ed 1992; NYPA 1994) and individual plant examination of external events (Con Ed 1995 and NYPA 1997).

The baseline core damage frequency (CDF) for the purpose of the SAMA evaluation is approximately 1. 79x1 0-5 per year for IP2 and 1.15x10-5 per year for IP3. The CDF values are based on the risk assessment for internally initiated events. Entergy did not include the contributions from external events within the IP2 and IP3 risk estimates; however, it did perform separate assessments of the CDF from external events and did account for the potential risk reduction benefits associated with external events by multiplying the estimated benefits for internal events by a factor of approximately 3.8 for IP2 and 5.5 for IP3 (as discussed in Appendix G, Sections G.2.2, G.3.1, and G.6.2). The breakdown of CDF by initiating event for IP2 and IP3 is provided in Table 5-3.

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Environmental Impacts of Postulated Accidents IP2 and IP3 Core Damage Frequency (Entergy, 2007a)

IP2 IP3 CDF  % CDF  %

Initiating Event (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 1 1.2x10-6 8.5x10-7 Transients 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 7 7 Loss of component cooling water 5.8x10- 3 1.1x10- <1 7 7 Loss of nonessential service water 3.0x10- 2 2.8x10- 2 7 7 Interfacing systems LOCA 1.5x10- <1 1.5x10-7 Reactor vessel rupture 1.Ox10- <1 1.Ox10-7 <1 Loss of 125 volts direct current power 5.8x10-8 <1 1.Ox10-6 9 8 7 Total loss of service water system 4.4x10- <1 5.4x10- 5 Loss of essential service water 1.9x10-1O <1 1.8x10- 8

<1 5 5 Total CDF (internal events) 1.79x10- 100 1.15x10- 100

'Contributions from SBO and ATWS events are noted separately and not included in the reported values for loss of offsite power or transients.

As shown in Table 5-3, for IP2, loss of offsite power sequences, including station blackout (S80) events, and internal flooding initiators are the dominant contributors to CDF. For IP3, internal flooding initiators, loss-of-coolant accidents (LOCAs), steam generator tube rupture (SGTR) events, and anticipated transient without scram (A TWS) events are the dominant contributors to CDF. The differences in the CDF contributions are attributed, in large part, to several significant differences between the IP2 and IP3 units.

As shown in Table 5-4 below, Entergy's SAMA analysis, as revised, estimated the dose to the population within 80 kilometers (50 miles) of the IP2 and IP3 site to be approximately 0.87 person-sievert (Sv) (87 person-rem) per year for IP2, and 0.95 Sv (95 person-rem) per year for IP3 (Entergy 2009). The breakdown of the total population dose by containment failure mode is summarized in Table 5-4. SGTR events and late containment failures, caused by gradual overpressurization by steam and noncondensable gases, dominate the population dose risk for both units.

The NRC staff has reviewed Entergy's data and evaluation methods, as revised, and concludes that the quality of the risk analyses is adequate to support an assessment of the risk reduction potential for candidate SAMAs. Accordingly, the staff based its assessment of offsite risk on the CDFs and offsite doses reported by Entergy.

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Environmental Impacts of Postulated Accidents Table 5-4. Breakdown of Population Dose by Containment Failure Mode (Entergy 2009)

IP2 IP3 Population Population Containment Failure Mode Dose (Person- Dose

%  %

Rem 1 Per (Person-Contribution Contribution Year) Rem 1 Per Year)

Intact Containment <0.1 <1 <0.1 <1 Basemat Melt-through 4.1 5 2.4 3 Gradual Overpressure 28.3 32 16.8 18 Late Hydrogen Burns 3.6 4 2.1 2 Early Hydrogen Burns 8.6 10 3.2 3 In-Vessel Steam Explosion 0.6 <1 0.2 <1 Reactor Vessel Rupture 4.1 5 1.5 2 Interfacing System LOCA 6.6 8 4.2 4 SGTR 31.5 36 64.4 68 Total 87.4 100 94.8 100

'One person-rem = 0.01 person-sievert 5.2.3 Potential Plant Improvements Once the dominant contributors to plant risk were identified, Entergy searched for ways to reduce that risk. In identifying and evaluating potential SAMAs, Entergy considered insights from the plant-specific PSA and SAMA analyses performed for other operating plants that have submitted license renewal applications. In its 2007 ER, Entergy identified 231 and 237 potential risk-reducing improvements (SAMAs) to plant components, systems, procedures, and training for IP2 and IP3, respectively.

As discussed in Entergy's ER, for IP2, Entergy removed all but 68 of the SAMAs from further consideration because they are not applicable to IP2 as a result of design differences, have already been implemented at IP2, or are similar in nature and could be combined with another SAMA candidate. For IP3, all but 62 of the SAMAs were removed from further consideration based on similar criteria. A detailed cost-benefit analysis was performed for each of the remaining SAMAs.

The staff has concluded that Entergy's ER SAMA analysis used a systematic and comprehensive process for identifying potential plant improvements for IP2 and IP3, and that the set of potential plant improvements identified by Entergy is reasonably comprehensive and, therefore, acceptable.

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Environmental Impacts of Postulated Accidents 5.2.4 Evaluation of Risk Reduction and Costs of Improvements In its ER, Entergy evaluated the risk-reduction potential of the remaining candidate SAMAs that were applicable to each unit (68 for IP2 and 62 for IP3). The SAMA evaluations were performed using realistic assumptions with some conservatism.

Entergy estimated the costs of implementing the candidate SAMAs through the application of engineering judgment and the use of other licensees' estimates for similar improvements. The cost estimates reported in the ER conservatively did not include the cost of replacement power during extended outages required to implement the modifications, nor did they account for inflation.

The staff reviewed Entergy's basis for calculating the risk reduction for the various plant improvements and concluded that the rationale and assumptions for estimating risk reduction are reasonable and generally conservative (i.e., the estimated risk reduction is higher than what would actually be realized). Accordingly, the staff based its estimates of averted risk for the various SAMAs on Entergy's risk reduction estimates.

The staff reviewed the basis for the applicant's cost estimates. For certain improvements, the staff also compared the cost estimates to estimates developed elsewhere for similar improvements, including estimates developed as part of other licensees' analyses of SAMAs for operating reactors and advanced light-water reactors. The staff found the cost estimates to be reasonable and generally consistent with estimates provided in support of other plants' analyses.

The staff concluded that the risk reduction and the cost estimates provided by Entergy are sufficient and appropriate for use in the SAMA evaluation.

5.2.5 Cost-Benefit Comparison The cost-benefit analysis performed by Entergy was based primarily on NUREG/BR-0184, "Regulatory Analysis Technical Evaluation Handbook" (NRC 1997) and was executed consistent with this guidance. NUREG/BR-0058, "Regulatory Analysis Guidelines of the U.S.

Nuclear Regulatory Commission" (NRC 2004), has recently been revised to reflect the agency's revised policy on discount rates. Revision 4 of NUREG/BR-0058 states that two sets of estimates should be developed-one at 3 percent and one at 7 percent (NRC 2004). Entergy provided both sets of estimates (Entergy 2007b).

As described in Section G.6.1, Entergy identified 10 potentially cost-beneficial SAMAs (5 for IP2 and 5 for IP3) in the baseline analysis (using a 7-percent discount rate) and sensitivity analysis (using a 3-percent discount rate) contained in the ER. Based on consideration of analysis uncertainties, Entergy identified two additional potentially cost-beneficial SAMAs for IP2 in the ER (lP2 SAMAs 44 and 56).

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Environmental Impacts of Postulated Accidents In response to an NRC staff request, Entergy provided the results of a revised uncertainty analysis in which the impact of lost tourism and business was accounted for in the baseline analysis (rather than as a separate sensitivity case) (Entergy 2008a). The revised uncertainty analysis resulted in the identification of two additional potentially cost-beneficial SAMAs for I P2 (I P2 SAMAs 9 and 53) and one additional potentially cost-beneficial SAMA for I P3 (I P3 SAMA 53), as reported in the draft Supplemental Environmental Impact Statement (DSEIS).

Subsequent to issuance of the DSEIS, in response to NRC staff questions, Entergy identified an error in the Indian Point site meteorological file used to calculate offsite consequences of severe accidents, and submitted a SAMA re-analysis based on corrected meteorological data (Entergy 2009). The SAMA re-analysis resulted in identification of three additional potentially cost -

beneficial SAMAs for IP2 (lP2 SAMAs 21,22, and 62) and three additional potentially cost-beneficial SAMAS for IP3 (lP3 SAMAs 7, 18, and 19).

The potentially cost-beneficial SAMAs for IP2 include the following:

  • SAMA 9 - Create a reactor cavity flooding system to reduce the impact of core-concrete interaction from molten core debris following core damage and vessel failure.
  • SAMA 21 - Install additional pressure or leak monitoring instrumentation to reduce the frequency of interfacing system loss of coolant accidents.
  • SAMA 22 - Add redundant and diverse limit switches to each containment isolation valve. This modification would reduce the frequency of an interfacing system loss of coolant activity.
  • SAMA 28 - Provide a portable diesel-driven battery charger to improve direct current (dc) power reliability. Safety-related disconnect would be used to change a selected battery. This modification would enhance the long-term operation of the turbine-driven auxiliary feed water (AFW) pump on battery depletion.
  • SAMA 44 - Use fire water as backup for steam generator inventory to increase the availability of steam generator water supply to ensure adequate inventory for the operation of the turbine-driven AFW pump during SBO events.
  • SAMA 53 - Keep both pressurizer power-operated relief valve block valves open. This modification would reduce the CDF contribution from loss of secondary heat sink by improving the availability of feed and bleed.
  • SAMA 54 - Install a flood alarm in the 480-volt (V) alternating current (ac) switchgear room to mitigate the occurrence of internal floods inside the 480-V ac switchgear room.
  • SAMA 60 - Provide added protection against flood propagation from stairwell 4 into the 480-V ac switchgear room to reduce the CDF contribution from flood sources within stairwell 4 adjacent to the 480-V ac switchgear room.
  • SAMA 61 - Provide added protection against flood propagation from the deluge room into the 480-V ac switchgear room to reduce the CDF contribution from flood sources within the deluge room adjacent to the 480-V ac switchgear room.

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