ML12334A642

Official Exhibit - NYS00133C-00-BD01 - NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Regarding Indian Point Nuclear Generating Units 2 and 3, Supplement 38, Volume 1 (December 2010) (FSEIS)

ML12334A642
Person / Time
Site:	Indian Point
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
Download: ML12334A642 (153)

Text

United States Nuclear Regulatory Commission Official Hearing Exhibit Entergy Nuclear Operations, Inc.

In the Matter of:

(Indian Point Nuclear Generating Units 2 and 3)

ASLBP #: 07-858-03-LR-BD01 NYS00133C

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Docket #: 05000247 l 05000286 Submitted: December 14, 2011

¢I:! "0 Exhibit #: NYS00133C-00-BD01 Identified: 10/15/2012

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'? i Admitted:

10/15/2012 Withdrawn:

'1"'/1; & Rejected: Stricken:

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Environmental Impacts of Postulated Accidents

• SMA 62 - Provide a hard-wired connection to a safety injection (SI) pump from the alternate safe shutdown system (ASSS) power supply. This modification would reduce the CDF from events that involve loss of power from the 4S0V vital buses.

• SAMA 65 - Upgrade the alternate safe shutdown system to allow timely restoration of reactor coolant pump seal injection and cooling from events that cause loss of power from the 4S0-V ac vital buses.

The potentially cost-beneficial SAMAs for IP3 include the following:

• SAMA 7 - Create a reactor cavity flooding system. This modification would enhance core debris cooling and reduce the frequency of containment failure due to core-concrete interaction.

• SAMA 1S - Route the discharge from the main steam safety valves through a structure where a water spray would condense the steam and remove fission products.

• SAMA 19 - Install additional pressure or leak monitoring instrumentation to reduce the frequency of interfacing system loss of coolant accidents.

• SAMA 30 - Provide a portable diesel-driven battery charger to improve dc power reliability. A safety-related disconnect would be used to change a selected battery. This modification would enhance the long-term operation of the turbine-driven AFW pump on battery depletion.

• SAMA 52 - Proceduralize opening the city water supply valve for alternative AFW system pump suction to enhance the availability of the AFW system.

• SAMA 53 - Install an excess flow valve to reduce the risk associated with hydrogen explosions inside the turbine building or primary auxiliary building.

• SAMA 55-Provide the capability of powering one safety injection pump or RHR pump using the Appendix R diesel (MCC 312A) to enhance reactor cooling system injection capability during events that cause loss of power from the 4S0-V ac vital buses.

• SAMA 61 - Upgrade the alternate safe-shutdown system to allow timely restoration of reactor coolant pump seal injection and cooling from events that cause loss of power from the 4S0-V ac vital buses.

• SAMA 62 - Install a flood alarm in the 4S0-V ac switchgear room to mitigate the occurrence of internal floods inside the 4S0-V ac switchgear room.

In response to an NRC staff inquiry regarding estimated benefits for certain SAMAs and lower cost alternatives, Entergy identified one additional potentially cost-beneficial SAMA (regarding a dedicated main steam safety valve gagging device for SGTR events in both units; this was unnumbered for each unit because the applicant did not initially identify them) (Entergy 200Sb);

and Entergy determined that one SAMA that was previously identified as potentially cost beneficial was no longer cost beneficial based on correction of an error in the ER (I P3 SAMA

30) (Entergy 200Sa, Entergy 2009).

Based on its review of Entergy's SAMA analysis, as revised, the staff concludes that, with the exception of the potentially cost-beneficial SAMAs discussed above, the costs of the SAMAs evaluated would be higher than their associated benefits.

I NUREG-1437, Supplement 38 5-10 December 201 0 OAGI0001367A_00307

Environmental Impacts of Postulated Accidents 5.2.6 Conclusions The NRC staff reviewed Entergy's analysis, as revised, and concludes that the methods used, and the implementation of those methods, were sound. The treatment of SAMA benefits and costs support the general conclusion that the SAMA evaluations performed by Entergy are reasonable and sufficient for the license renewal submittal. Although the treatment of SAMAs for external events was somewhat limited, the likelihood of there being cost-beneficial enhancements in this area was minimized by improvements that have been realized as a result of the IPEEE process and inclusion of a multiplier to account for external events.

Based on its review of the SAMA analysis, as revised, the staff concurs with Entergy's identification of areas in which risk can be further reduced in a cost-beneficial manner through the implementation of all or a subset of potentially cost-beneficial SAMAs. Given the potential for cost-beneficial risk reduction, the staff considers that further evaluation of these SAMAs by Entergy is appropriate. However, none of the potentially cost-beneficial SAMAs relate to adequately managing the effects of aging during the period of extended operation. Therefore, they need not be implemented as part of IP2 and IP3 license renewal pursuant to 10 CFR Part 54.

In a decision issued on June 30, 2010, the Atomic Safety and Licensing Board ("Board")

admitted two contentions for litigation, which had been filed by the State of New York in the Indian Point Units 2 and 3 license renewal adjudicatory proceeding. Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3), lBP-10-13, 71 NRC_

(2010). These contentions generally assert that the NRC staff must reach a final determination of the cost-beneficial SAMAs, from the slate of SAMAs that have been found to be potentially cost-beneficial, and that (a) the cost-beneficial SAMAs must be imposed as a "backfit" on the plants' current licensing basis ("ClB"), as a condition for license renewal, or (b) the staff must provide a sufficient explanation for not imposing such a license renewal condition. In this regard, the NRC staff has provided a detailed discussion of SAMA costs and benefits in this SEIS, which satisfies the NRC's obligation, under NEPA and related case law, to consider SAMAs in a license renewal proceeding such as the IP2 and IP3 proceeding. Indeed, as the Board found, while NEPA requires consideration of environmental impacts and alternatives, it does not require that SAMAs be imposed to redress environmental impacts. lBP-10-13, slip op. at 29.

Moreover, the NRC staff has determined that none of the potentially cost-beneficial SAMAs are related to the license renewal requirements in 10 CFR Part 54 (i.e., managing the effects of aging) (SEIS § 5.2.6). Under the NRC's regulatory system, any potentially cost-beneficial SAMAs that do not relate to 10 CFR Part 54 requirements would be considered, to the extent necessary or appropriate, under the agency's oversight of a facility's current operating license in accordance with 10 CFR Part 50 requirements, inasmuch as such matters would pertain not just to the period of extended operation but to operations under the current operating license term as well. Thus, there is no regulatory basis to suggest that potentially cost-beneficial SAMAs that are unrelated to Part 54 requirements must be imposed as a backfit to the ClB, as a condition for license renewal.

Finally, the NRC staff notes that SAMAs, by definition, pertain to severe accidents - i.e., those accidents whose consequences could be severe, but whose probability of occurrence is so low that they may be excluded from the spectrum of design basis accidents ("OBAs) that have been postulated for a plant (see GElS §§ 5.3.2, 5.3.3, 5.4); this is consistent with the conclusions reached in § 5.2.2 of this SEIS concerning severe accidents at IP2 and IP3. The Commission has previously concluded, as a generic matter, that the probability-weighted radiological consequences of severe accidents are SMAll. GElS § 5.5.2; 10 CFR Part 51, App. B, Table B December 2010 5-11 Draft NUREG-1437, Supplement 38 OAGI0001367A_00308

Environmental Impacts of Postulated Accidents

1. As stated in §§ 5.1.1 and 5.1.2 above, no significant new information has been identified that would remove IP2 and IP3 from these generic determinations. Thus, there is no regulatory basis to impose any of the potentially cost-beneficial SAMAs as a condition for license renewal of IP2 and IP3 - even if those potentially cost-beneficial SAMAs are "finally" found to be cost-beneficial.

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

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

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

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

Atomic Safety and Licensing Board Panel (ASLBP). Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3), LBP-10-13, 71 NRC _ (2010).

Consolidated Edison (Con Ed). 1992. Letter from Stephen B. Bram to U.S. Nuclear Regulatory Commission,

Subject:

Generic Letter 88-20, Supplement 1: Individual Plant Examination (lPE) for Severe Accident Vulnerabilities-10 CFR 50.54, Indian Point Unit No.2, August 12, 1992.

Consolidated Edison (Con Ed). 1995. Letter from Stephen E. Quinn to U.S. Nuclear Regulatory Commission,

Subject:

Final Response to Generic Letter 88-20, Supplement 4: Submittal of Individual Plant Examination of External Events (lPEEE) for Severe Accident Vulnerabilities, Indian Point Unit No.2, December 6, 1995.

Entergy Nuclear Operations, Inc. (Entergy). 2007a. "Applicant's Environment Report, Operating License Renewal Stage." (Appendix E to Indian Point, Units 2 and 3, License Renewal Application; Attachment E: Severe Accident Mitigation Alternatives). April 23,2007.

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

ML071210562.

Entergy Nuclear Operations, Inc. (Entergy). 2007b. Letter from Fred Dacimo to U.S. Nuclear Regulatory Commission,

Subject:

Indian Point Energy Center License Renewal Application, NL-07-039, April 23, 2007. ADAMS Accession No. ML071210512.

Entergy Nuclear Operations, Inc. (Entergy). 2008a. Letter from Fred Dacimo to U.S. Nuclear Regulatory Commission,

Subject:

Reply to Request for Additional Information Regarding License Renewal Application-Severe Accident Mitigation Alternatives Analysis, NL-08-028, May 22,2008. ADAMS Accession No. ML080420264.

Entergy Nuclear Operations, Inc. (Entergy). 2008b. Letter from Fred Dacimo to U.S. Nuclear Regulatory Commission,

Subject:

Supplemental Reply to Request for Additional Information Regarding License Renewal Application-Severe Accident Mitigation Alternatives Analysis, NL-08-086, May 22,2008. ADAMS Accession No. ML081490336.

Entergy Nuclear Operations, Inc. (Entergy). 2009. Letter from Fred Dacimo to U.S. Nuclear Regulatory Commission,

Subject:

License Renewal Application - SAMA Reanalysis Using Alternate Meteorological Tower Data, NL-09-165, December 11,2009. ADAMS Accession No.

NUREG-1437, Supplement 38 5-12 December 201 0 OAGI0001367A_00309

Environmental Impacts of Postulated Accidents M L093580089.

New York Power Authority (NYPA). 1994. Letter from William A. Josiger to U.S. Nuclear Regulatory Commission,

Subject:

Indian Point 3 Nuclear Power Plant Individual Plant Examination for Internal Events, June 30, 1994.

New York Power Authority (NYPA). 1997. Letter from James Knubel to U.S. Nuclear Regulatory Commission,

Subject:

Indian Point 3 Nuclear Power Plant Individual Plant Examination of External Events (lPEEE), September 26, 1997.

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

Nuclear Regulatory Commission (NRC). 1997. "Regulatory Analysis Technical Evaluation Handbook." NUREG/BR-0184, Washington, DC.

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

Nuclear Regulatory Commission (NRC). 2004. "Regulatory Analysis Guidelines of the U.S.

Nuclear Regulatory Commission." NUREG/BR-0058, Rev. 4, Washington, DC. ADAMS Accession No. ML042820192.

December 2010 5-13 Draft NUREG-1437, Supplement 38 I OAGI0001367A_0031 0

1 6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL 2 CYCLE, SOLID WASTE MANAGEMENT, AND GREENHOUSE 3 GAS EMISSIONS 4 Environmental issues associated with the uranium fuel cycle and solid waste management are 5 discussed in NUREG-1437, Volumes 1 and 2, "Generic Environmental Impact Statement for 6 License Renewal of Nuclear Plants" (hereafter referred to as the GElS) (NRC 1996, 1999.)(1) 7 The GElS includes a determination of whether the analysis of the environmental issue could be 8 applied to all plants and whether additional mitigation measures would be warranted. Issues 9 are then assigned a Category 1 or a Category 2 designation. As set forth in the GElS, 10 Category 1 issues are those that meet all of the following criteria:

11 (1) The environmental impacts associated with the issue have been determined to apply 12 either to all plants or, for some issues, to plants having a specific type of cooling system 13 or other specified plant or site characteristics.

14 (2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 15 the impacts (except for collective offsite radiological impacts from the fuel cycle and from 16 high-level waste and spent fuel disposal).

17 (3) Mitigation of adverse impacts associated with the issue has been considered in the 18 analysis, and it has been determined that additional plant-specific mitigation measures 19 are likely not to be sufficiently beneficial to warrant implementation.

20 For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 21 required unless new and significant information is identified.

22 Category 2 issues are those that do not meet one or more of the criteria for Category 1; 23 therefore, additional plant-specific review of these issues is required.

24 This chapter addresses the issues that are related to the uranium fuel cycle and solid waste 25 management that are listed in Table 8-1 of Appendix 8 to Subpart A, "Environmental Effect of 26 Renewing the Operating License of a Nuclear Power Plant," of Title 10, Part 51, "Environmental 27 Protection Regulations for Domestic Licensing and Related Regulatory Functions," of the Code 28 of Federal Regulations (10 CFR Part 51) and are applicable to the Indian Point Nuclear 29 Generating Unit Nos. 2 and 3 (lP2 and IP3). The generic potential radiological and 30 nonradiological environmental impacts of the uranium fuel cycle and transportation of nuclear 31 fuel and wastes are described in detail in the GElS based, in part, on the generic impacts 32 provided in 10 CFR 51.51(b), Table S-3, "Table of Uranium Fuel Cycle Environmental Data,"

33 and 10 CFR 51.52(c), Table S-4, "Environmental Impact of Transportation of Fuel and Waste to 34 and from One Light-Water-Cooled Nuclear Power Reactor." The U.S. Nuclear Regulatory 35 Commission (NRC) staff also addresses the impacts from radon-222 and technetium-99 in the 36 GElS.

37 6.1 The Uranium Fuel Cycle (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 6-1 NUREG-1437, Supplement 38 OAG10001367A_00311

Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, that are applicable to 2 IP2 and IP3 from the uranium fuel cycle and solid waste management are listed in Table 6-1.

3 Table 6-1. Category 1 Issues Applicable to the Uranium Fuel Cycle and Solid Waste 4 Management during the Renewal Term ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Section URANIUM FUEL CYCLE AND WASTE MANAGEMENT Offsite radiological impacts (individual effects from other than the 6.1; 6.2.1; 6.2.2.1; 6.2.2.3; disposal of spent fuel and high-level waste) 6.2.3; 6.2.4; 6.6 Offsite radiological impacts (collective effects) 6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6 Offsite radiological impacts (spent fuel and high-level waste disposal) 6.1; 6.2.2.1; 6.2.2.2; 6.2.3; 6.2.4; 6.6 Nonradiological impacts of the uranium fuel cycle 6.1; 6.2.2.6; 6.2.2.7; 6.2.2.8; 6.2.2.9; 6.2.3; 6.2.4; 6.6 Low-level waste storage and disposal 6.1; 6.2.2.2; 6.4.2; 6.4.3; 6.4.4 Mixed waste storage and disposal 6.1; 6.4.5; 6.6 Onsite spent fuel 6.1; 6.4.6; 6.6 Nonradiological waste 6.1; 6.5; 6.6 Transportation 6.1; 6.3, Addendum 1; 6.6 5 Entergy Nuclear Operations, Inc. (Entergy), stated in the IP2 and IP3 environmental report (ER) 6 (Entergy 2007) that it is not aware of any new and significant information associated with the 7 renewal of the IP2 and IP3 operating licenses, though it did identify leaks to ground water as a 8 potential new issue. The NRC staff addressed this issue in Sections 2.2.7,4.3, and 4.5 of this 9 supplemental environmental impact statement (SEIS). In Section 4.5, the NRC staff concludes 10 that the abnormal liquid releases (leaks) discussed by Entergy in its ER, while new information, 11 are within the NRC's radiation safety standards contained in 10 CFR Part 20 and are not 12 considered to have a significant impact on plant workers, the public, or the environment (i.e.,

13 while the information related to spent fuel pool leakage is new, it is not significant). The NRC 14 staff has not identified any new and significant information during its independent review of the 15 IP2 and IP3 ER (Entergy 2007), the site audit, the scoping process, or evaluation of other 16 available information. Therefore, the NRC staff concludes that there are no impacts related to 17 these issues beyond those discussed in the GElS. For these issues, the NRC staff concluded 18 in the GElS that the impacts are SMALL (except for the collective offsite radiological impacts 19 from the fuel cycle and from high-level waste and spent fuel disposal, as discussed below) and 20 that additional plant-specific mitigation measures are not likely to be sufficiently beneficial to be 21 warranted.

22 A brief description of the NRC staff's review and the GElS conclusions, as codified in Table B-1 23 of 10 CFR Part 51, for each of these issues follows:

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Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1

• Off-site radiological impacts (individual effects from other than the disposal of spent fuel 2 and high-level waste). Based on information in the GElS, the Commission found the 3 following:

4 Off-site impacts of the uranium fuel cycle have been considered by the 5 Commission in Table S-3 of this part (10 CFR 51.51 (b)). Based on information in 6 the GElS, impacts on individuals from radioactive gaseous and liquid releases 7 including radon-222 and technetium-99 are small.

8 The NRC staff has not identified any new and significant information during its independent 9 review of the IP2 and IP3 ER, the site audit, the scoping process, or evaluation of other 10 available information. Therefore, the NRC staff concludes that there are no offsite radiological 11 impacts (individual effects) of the uranium fuel cycle during the renewal term beyond those 12 discussed in the GElS.

13

• Off-site radiological impacts (collective effects). Based on information in the GElS, the 14 Commission found the following:

15 The 100 year environmental dose commitment to the United States (U.S.)

16 population from the fuel cycle, high level waste and spent fuel disposal excepted, 17 is calculated to be about 14,800 person rem, or 12 cancer fatalities, for each 18 additional 20-year power reactor operating term. Much of this, especially the 19 contribution of radon releases from mines and tailing piles, consists of tiny doses 20 summed over large populations. This same dose calculation can theoretically be 21 extended to include many tiny doses over additional thousands of years as well 22 as doses outside the U.S. The result of such a calculation would be thousands 23 of cancer fatalities from the fuel cycle, but this result assumes that even tiny 24 doses have some statistical adverse health effect which will not ever be mitigated 25 (for example no cancer cure in the next one thousand years), and that these 26 doses projected over thousands of years are meaningful. However, these 27 assumptions are questionable. In particular, science cannot rule out the 28 possibility that there will be no cancer fatalities from these tiny doses. For 29 perspective, the doses are very small fractions of regulatory limits and even 30 smaller fractions of natural background exposure to the same populations.

31 Nevertheless, despite all of the uncertainty, some judgement as to the National 32 Environmental Policy Act of 1969, as amended (NEPA) implications of these 33 matters should be made and it makes no sense to repeat the same judgement in 34 every case. Even taking the uncertainties into account, the Commission 35 concludes that these impacts are acceptable in that these impacts would not be 36 sufficiently large to require the NEPA conclusion, for any plant, that the option of 37 extended operation under 10 CFR Part 54 should be eliminated. Accordingly, 38 while the Commission has not assigned a single level of significance for the 39 collective effects of the fuel cycle, this issue is considered Category 1.

40 December 2010 6-3 NUREG-1437, Supplement 38 I OAGI0001367A_00313

Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 The NRC staff has not identified any new and significant information during its independent 2 review of the IP2 and IP3 ER, the NRC staff's site visit, the scoping process, or its evaluation of 3 other available information. Therefore, the NRC staff concludes that there are no offsite 4 radiological impacts (collective effects) from the uranium fuel cycle during the renewal term 5 beyond those discussed in the GElS.

6

• Offsite radiological impacts (spent fuel and high-level waste disposal). Based on 7 information in the GElS, the Commission found the following:

8 For the high-level waste (HLW) and spent fuel disposal component of the fuel 9 cycle, there are no current regulatory limits for off-site releases of radionuclides 10 for the current candidate repository site. However, if we assume that limits are 11 developed along the lines of the 1995 National Academy of Sciences (NAS) 12 report, "Technical Bases for Yucca Mountain Standards" (NAS 1995), and that in 13 accordance with the Commission's Waste Confidence Decision, 10 CFR 51.23, a 14 repository can and likely will be developed at some site which will comply with 15 such limits, peak doses to virtually all individuals will be 100 millirem (mrem) 16 (1 millisevert [mSv]) per year or less. However, while the Commission has 17 reasonable confidence that these assumptions will prove correct, there is 18 considerable uncertainty since the limits are yet to be developed, no repository 19 application has been completed or reviewed, and uncertainty is inherent in the 20 models used to evaluate possible pathways to the human environment. The 21 NAS report indicated that 100 mrem per year should be considered as a starting 22 point for limits for individual doses, but notes that some measure of consensus 23 exists among national and international bodies that the limits should be a fraction 24 of the 100 mrem (1 mSv) per year. The lifetime individual risk from 100 mrem 25 annual dose limit is about 3x 10-3 .

26 Estimating cumulative doses to populations over thousands of years is more 27 problematic. The likelihood and consequences of events that could seriously 28 compromise the integrity of a deep geologic repository were evaluated by the 29 U.S. Department of Energy (DOE) in the "Final Environmental Impact Statement:

30 Management of Commercially Generated Radioactive Waste," October 1980 31 (DOE 1980). The evaluation estimated the 70-year whole-body dose 32 commitment to the maximum individual and to the regional population resulting 33 from several modes of breaching a reference repository in the year of closure, 34 after 1,000 years, after 100,000 years, and after 100,000,000 years.

35 Subsequently, the NRC and other federal agencies have expended considerable 36 effort to develop models for the design and for the licensing of a high level waste 37 repository, especially for the candidate repository at Yucca Mountain. More 38 meaningful estimates of doses to population may be possible in the future as 39 more is understood about the performance of the proposed Yucca Mountain 40 repository. Such estimates would involve very great uncertainty, especially with 41 respect to cumulative population doses over thousands of years. The standard 42 proposed by the NAS is a limit on maximum individual dose. The relationship of NUREG-1437, Supplement 38 6-4 December 2010 OAG10001367A_00314

Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 potential new regulatory requirements, based on the NAS report, and cumulative 2 population impacts has not been determined, although the report articulates the 3 view that protection of individuals will adequately protect the population for a 4 repository at Yucca Mountain. However, EPA's generic repository standards in 5 40 CFR Part 191 generally provide an indication of the order of magnitude of 6 cumulative risk to population that could result from the licensing of a Yucca 7 Mountain repository, assuming the ultimate standards will be within the range of 8 standards now under consideration. The standards in 40 CFR Part 191 protect 9 the population by imposing "containment requirements" that limit the cumulative 10 amount of radioactive material released over 10,000 years. Reporting 11 performance standards that will be required by EPA are expected to result in 12 releases and associated health consequences in the range between 10 and 100 13 premature cancer deaths with an upper limit of 1,000 premature cancer deaths 14 world-wide for a 100,000 metric ton (MT) repository.

15 Nevertheless, despite all of the uncertainty, some judgement as to the regulatory 16 NEPA implications of these matters should be made and it makes no sense to 17 repeat the same judgement in every case. Even taking the uncertainties into 18 account, the Commission concludes that these impacts are acceptable in that 19 these impacts would not be sufficiently large to require the NEPA conclusion, for 20 any plant, that the option of extended operation under 10 CFR Part 54 should be 21 eliminated. Accordingly, while the Commission has not assigned a single level of 22 significance for the impacts of spent fuel and high level waste disposal, this issue 23 is considered Category 1.

24 On February 15, 2002, based on a recommendation by the Secretary of the DOE, the President 25 recommended the Yucca Mountain site for the development of a repository for the geologic 26 disposal of spent nuclear fuel and HLW. The U.S. Congress approved this recommendation on 27 July 9, 2002, in Joint Resolution 87, which designated Yucca Mountain as the repository for 28 spent nuclear waste. On July 23, 2002, the President signed Joint Resolution 87 into law; 29 Public Law 107-200, 116 Stat. 735 designates Yucca Mountain as the repository for spent 30 nuclear waste. The staff notes that, on March 3, 2010, the U.S. Department of Energy (DOE) 31 submitted a motion to the Atomic Safety and Licensing Board to withdraw with prejudice its 32 application for a permanent geologic repository at Yucca Mountain, NV. The NRC is currently 33 considering DOE's request. Nevertheless, the NRC has evaluated the safety and 34 environmental effects of spent fuel storage and, as set forth in 10 CFR 51.23, "Temporary 35 Storage of Spent Fuel after Cessation of Reactor Operation-Generic Determination of No 36 Significant Impact" (known as the Waste Confidence Rule).

37 The Commission has made a generic determination that, if necessary, spent fuel 38 generated in any reactor can be stored safely and without significant 39 environmental impacts for at least 30 years beyond the licensed life for operation 40 (which may include the term of a revised or renewed license) of that reactor at its 41 spent fuel storage basin or at either onsite or offsite independent spent fuel 42 storage installations. Further, the Commission believes there is reasonable 43 assurance that at least one mined geologic repository will be available within the December 2010 6-5 NUREG-1437, Supplement 38 OAGI0001367A_00315

Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 first quarter of the twenty-first century, and sufficient repository capacity will be 2 available within 30 years beyond the licensed life for operation of any reactor to 3 dispose of the commercial high-level waste and spent fuel originating in such 4 reactor and generated up to that time.

5 That rule is the subject of an ongoing rulemaking proceeding, as discussed in "Waste 6 Confidence Decision Update," 73 F.R. 59551 (Oct. 9, 2008).

7 In 10 CFR Part 51, "Environmental Protection Regulations for Domestic Licensing and Related 8 Regulatory Functions," onsite spent fuel storage is classified as a Category 1 issue that applies 9 to all nuclear power reactors. While the Commission did not assign a single level of significance 10 (i.e., SMALL, MODERATE, or LARGE) in Table B-1 of Appendix B to Subpart A, "Environmental 11 Effect of Renewing the Operating License of a Nuclear Power Plant," of 10 CFR Part 51 for the 12 impacts associated with spent fuel and HLW disposal, it did conclude that the impacts are 13 acceptable in that these impacts would not be sufficiently large to require the NEPA conclusion 14 that for any plant, the option of extended operation under 10 CFR Part 54, "Requirements for 15 Renewal of Operating Licenses for Nuclear Power Plants," should be eliminated.

16 The GElS for license renewal (NUREG-1437) evaluated a variety of spent fuel and waste 17 storage scenarios, including onsite storage of these materials for up to 30 years following 18 expiration of the operating license, transfer of these materials to a different plant, and transfer of 19 these materials to an ISFSI. During dry cask storage and transportation, spent nuclear fuel 20 must be "encased" in NRC-approved casks. An NRC-approved cask is one that has undergone 21 a technical review of its safety aspects and been found to meet all of the NRC's requirements, 22 as specified in 10 CFR Part 72, "Licensing Requirements for the Independent Storage of Spent 23 Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than Class C 24 Waste" (for storage casks), and 10 CFR Part 71, "Packaging and Transportation of Radioactive 25 Material" (for transportation casks). For each potential scenario involving spent fuel, the GElS 26 determined that existing regulatory requirements, operating practices, and radiological 27 monitoring programs were sufficient to ensure that impacts resulting from spent fuel and waste 28 storage practices during the term of a renewed operating license would be small.

29 The NRC staff has not identified any new and significant information during its independent 30 review of the IP2 and IP3 ER, the site audit, the scoping process, or evaluation of other 31 available information. Therefore, the NRC staff concludes that there are no offsite radiological 32 impacts related to spent fuel and high-level waste disposal during the renewal term beyond 33 those discussed in the GElS.

34

• Nonradiological impacts of the uranium fuel cycle. Based on information in the GElS, 35 the Commission found the following:

36 The nonradiological impacts of the uranium fuel cycle resulting from the renewal 37 of an operating license for any plant are found to be small.

38 The NRC staff has not identified any new and significant information during its independent 39 review of the IP2 and IP3 ER, the NRC staff's site visit, the scoping process, or its evaluation of 40 other available information pertaining to the IP2 and IP3 license renewal application. Therefore, 41 the NRC staff concludes that there are no nonradiological impacts of the uranium fuel cycle 42 during the renewal term beyond those discussed in the GElS.

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Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1

• Low-level waste storage and disposal. Based on information in the GElS, the 2 Commission found the following:

3 The comprehensive regulatory controls that are in place and the low public doses 4 being achieved at reactors ensure that the radiological impacts to the 5 environment will remain small during the term of a renewed license. The 6 maximum additional on-site land that may be required for low-level waste storage 7 during the term of a renewed license and associated impacts will be small.

8 Nonradiological impacts on air and water will be negligible. The radiological and 9 nonradiological environmental impacts of long-term disposal of low-level waste 10 from any individual plant at licensed sites are small. In addition, the Commission 11 concludes that there is reasonable assurance that sufficient low-level waste 12 disposal capacity will be made available when needed for facilities to be 13 decommissioned consistent with NRC decommissioning requirements.

14 The NRC staff has not identified any new and significant information during its independent 15 review of the IP2 and IP3 ER, the site audit, the scoping process, or evaluation of other 16 available information. Therefore, the NRC staff concludes that there are no impacts of low-level 17 waste storage and disposal associated with the renewal term beyond those discussed in the 18 GElS.

19

• Mixed waste storage and disposal. Based on information in the GElS, the Commission 20 found the following:

21 The comprehensive regulatory controls and the facilities and procedures that are 22 in place ensure proper handling and storage, as well as negligible doses and 23 exposure to toxic materials for the public and the environment at all plants.

24 License renewal will not increase the small, continuing risk to human health and 25 the environment posed by mixed waste at all plants. The radiological and 26 nonradiological environmental impacts of long-term disposal of mixed waste from 27 any individual plant at licensed sites are small. In addition, the Commission 28 concludes that there is reasonable assurance that sufficient mixed waste 29 disposal capacity will be made available when needed for facilities to be 30 decommissioned consistent with NRC decommissioning requirements.

31 The NRC staff has not identified any new and significant information during its independent 32 review of the IP2 and IP3 ER, the site audit, the scoping process, or evaluation of other 33 available information. Therefore, the NRC staff concludes that there are no impacts of mixed 34 waste storage and disposal associated with the renewal term beyond those discussed in the 35 GElS.

36

• Onsite spent fuel. Based on information in the GElS, the Commission found the 37 following:

38 The expected increase in the volume of spent fuel from an additional 20 years of 39 operation can be safely accommodated on site with small environmental effects 40 through dry or pool storage at all plants if a permanent repository or monitored December 2010 6-7 NUREG-1437, Supplement 38 OAGI0001367A_00317

Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 retrievable storage is not available.

2 The NRC staff has not identified any new and significant information during its independent 3 review of the IP2 and IP3 ER, the site audit, the scoping process, or evaluation of other 4 available information. Therefore, the NRC staff concludes that there are no impacts of onsite 5 spent fuel associated with license renewal beyond those discussed in the GElS.

6

• Nonradiological waste. Based on information in the GElS, the Commission found the 7 following:

8 No changes to generating systems are anticipated for license renewal. Facilities 9 and procedures are in place to ensure continued proper handling and disposal at 10 all plants.

11 The NRC staff has not identified any new and significant information during its independent 12 review of the IP2 and IP3 ER, the site, the scoping process, or evaluation of other available 13 information. Therefore, the NRC staff concludes that there are no nonradiological waste 14 impacts during the renewal term beyond those discussed in the GElS.

15

• Transportation. Based on information contained in the GElS, the Commission found the 16 following:

17 The impacts of transporting spent fuel enriched up to 5 percent uranium-235 with 18 average burnup for the peak rod to current levels approved by NRC up to 62,000 19 megawatt-days per metric ton of uranium (MWd/MTU) and the cumulative 20 impacts of transporting high-level waste to a single repository, such as Yucca 21 Mountain, Nevada are found to be consistent with the impact values contained in 22 10 CFR 51.52(c), Summary Table S-4-Environmentallmpact of Transportation 23 of Fuel and Waste to and from One Light-Water-Cooled Nuclear Power Reactor.

24 If fuel enrichment or burnup conditions are not met, the applicant must submit an 25 assessment of the implications for the environmental impact values reported in 26 10 CFR 51.52.

27 IP2 and IP3 meet the fuel-enrichment and burnup conditions set forth in Addendum 1 to the 28 GElS. The NRC staff has not identified any new and significant information during its 29 independent review of the IP2 and IP3 ER, the site audit, the scoping process, or evaluation of 30 other available information. Therefore, the NRC staff concludes that there are no impacts of 31 transportation associated with license renewal beyond those discussed in the GElS.

32 There are no Category 2 issues for the uranium fuel cycle and solid waste management.

33 6.2 Greenhouse Gas Emissions 34 6.2.1 Introduction 35 The NRC staff received many comments during the scoping period from individuals and groups 36 regarding the impact of the proposed relicensing of IP2 and IP3 on the release of carbon dioxide 37 (C0 2) and other greenhouse gas (GHG) emissions relative to potential alternative energy 38 sources, including fossil fuels, renewable energy sources, and conservation programs.

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Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 6.2.2 IP2 and IP3 2 The NRC staff has not identified any studies specifically addressing GHGs produced by IP2 and 3 IP3 or their fuel cycles. Although Entergy developed a study identifying gas emissions that 4 would result if IP2 and IP3 were to be decommissioned and their generating capacity replaced 5 with fossil-fuel based sources (Entergy Nuclear Northeast 2002), Entergy did not evaluate GHG 6 emissions related to the existing facility. This study evaluated emissions of CO 2, sulfur dioxide 7 (S02), nitrogen oxides (NOx), particulates (i.e., particulate matter, 10 microns or less in diameter 8 [PM1O]), carbon monoxide (CO), and volatile organic compounds (VOCs). The study was 9 intended as an evaluation of the impact of IP2 and IP3 shutdown on air quality in the local New 10 York City area, rather than an evaluation of the impact of IP2 and IP3 shutdown on global GHG 11 emissions.

12 6.2.3 GElS 13 The GElS provided only qualitative discussions regarding the GHG impacts of the nuclear fuel 14 cycle. In the analysis of potential alternatives to nuclear power plant relicensing, the GElS 15 referenced CO2 emissions as one of the substantial operating impacts associated with new 16 coal-fired and oil-fired power plants, although no direct quantitative assessment of GHG 17 emissions was presented. The GElS also did not address GHG impacts of the nuclear fuel 18 cycle relative to other potential alternatives, such as natural gas, renewable energy sources, or 19 conservation programs.

20 6.2.4 Other Studies 21 Since the development of the GElS, extensive further research into the relative volumes of 22 GHGs emitted by nuclear and other electricity generating methods has been performed. In 23 support of the analysis for this SEIS, the NRC staff performed a survey of the recent literature 24 on the subject. Based on this survey, the NRC staff found that estimates and projections of the 25 carbon footprint of the nuclear power lifecycle vary widely, and considerable debate exists 26 regarding the relative impacts of nuclear and other electricity generation methods on GHG 27 emissions. These recent studies take two different forms:

28 (1) qualitative discussions of the potential use of nuclear power to address GHG emissions 29 and global warming 30 (2) technical analyses and quantitative estimates of the actual amount of GHGs generated 31 by the nuclear fuel cycle 32 6.2.4.1 Qualitative Studies 33 The qualitative studies primarily consist of broad, large-scale public policy or investment 34 evaluations of whether an expansion of nuclear power is likely to be a technically, economically, 35 and/or politically feasible means of achieving global GHG reductions. Examples of the studies 36 that commenters referenced during the scoping period or that the NRC staff identified during the 37 subsequent literature search include the following:

38

• Studies conducted to evaluate whether investments in nuclear power in developing 39 countries should be accepted as a flexibility mechanism to assist industrialized nations in December 2010 6-9 NUREG-1437, Supplement 38 OAGI0001367A_00319

Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 achieving their GHG reduction goals under the Kyoto Protocols (Schneider 2000; 2 International Atomic Energy Agency [IAEA] 2000; NEA 2002; and Nuclear Information 3 and Resource Service and World Information Service on Energy [NIRSIWISE] 2005).

4 Ultimately, the parties did not approve nuclear power as a component under the Clean 5 Development Mechanism (COM), but not because of concerns about GHGs from the 6 nuclear fuel cycle (NEA 2002). Instead, it was eliminated from consideration for the 7 COM because it was not considered to meet the criterion of helping developing nations 8 achieve sustainable development because of safety and waste disposal concerns (NEA 9 2002).

10

• Analyses developed to assist governments (including the U.S. Government) in making 11 long-term investment and public policy decisions in nuclear power (Keepin 1988; Hagen 12 et al. 2001; Massachusettes Institute of Technology [MIT] 2003).

13 Although the qualitative studies sometimes reference and critique the rationale contained in the 14 existing quantitative estimates of GHGs produced by the nuclear fuel cycle, their conclusions 15 generally rely heavily on discussions of other aspects of nuclear policy decisions and 16 investment such as safety, cost, waste generation, and political acceptability. Therefore, these 17 studies are not directly applicable to the evaluation of GHG emissions that will be associated 18 with the proposed relicensing of IP2 and IP3.

19 6.2.4.2 Quantitative Studies 20 A large number of technical studies, including calculations and estimates of the amount of 21 GHGs emitted by nuclear and other power generation options, are available in the literature.

22 Examples of these studies include Mortimer (1990), Andseta et al. (1998), Spadaro (2000),

23 Storm van Leeuwen and Smith (2005), Fritsche (2006), Paliamentery Office of Science and 24 Technology (POST; 2006), AEA (2006), Weisser (2006), Fthenakis and Kim (2007), and Dones 25 (2007).

26 Comparison of the different studies is difficult because the assumptions and components of the 27 lifecycles included within each study vary widely. Examples of differing assumptions that make 28 comparability between the studies difficult include the following:

29

• the type of energy source that may be used to mine uranium deposits in the future 30

• the amount of reprocessing of nuclear fuel that will be performed in the future 31

• the type of energy source and process that might be used to enrich uranium in the future 32

• different calculations regarding the grade and volume of recoverable uranium deposits in 33 the world 34

• different estimates regarding the GHG emissions associated with declining grades of 35 recoverable coal, natural gas, and oil deposits 36

• the release of GHG gases other than CO2 , including the conversion of the masses of 37 these gases into grams of CO2 equivalents per kilowatt-hour (g Ceq IkWh)

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Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1

• the technology to be used for future fossil fuel power systems, including cogeneration 2 systems 3

• the projected capacity factors assumed for the different generation alternatives 4

• the different types of nuclear reactors used currently and in the projected future (light 5 water reactor, pressurized-water reactor, Canadian deuterium-natural uranium reactor, 6 breeder) 7 In addition, studies are inconsistent in their application of fulilifecycle analyses, including plant 8 construction, decommissioning, and resource extraction (uranium ore, fossil fuel). For instance, 9 Storm van Leeuwen and Smith (2005) present comparisons of GHG emissions from nuclear 10 versus natural gas that incorporate GHG emissions associated with nuclear plant construction 11 and decommissioning in the values used for comparison.

12 In the case of the proposed IP2 and IP3 relicensing, the relicensing action will not involve 13 additional GHG emissions associated with construction because the facility already exists. In 14 addition, the proposed relicensing action will not involve additional GHG emissions associated 15 with facility decommissioning, because that decommissioning must occur whether the facility is 16 relicensed or not. In many of these studies, the contribution of GHG emissions from facility 17 construction and decommissioning cannot be separated from the other lifecycle GHG emissions 18 that would be associated with IP2 and IP3 relicensing. Therefore, these studies overestimate 19 the GHG emissions attributed to the proposed IP2 and IP3 relicensing action.

20 In an early study on the subject, Dr. Nigel Mortimer conducted an analysis of the GHG 21 emissions resulting from the nuclear fuel cycle in 1990 (Mortimer 1990). In this study, Mortimer 22 stressed that the GHG implications of the nuclear fuel cycle were substantially related to the ore 23 grade of uranium that must be mined to support nuclear power generation. Using ore grades 24 that were current as of 1990, this study concluded that nuclear power offered a dramatic 25 reduction in GHG emissions over conventional coal-fired power plants over an estimated 26 35-year lifecycle. The analysis estimated that a nuclear power plant would generate 230,000 27 tons (209,000 metric tons (MT)) of CO2 over a 35-year life span, or about 3.9 percent of the 28 5,912,000 tons (5,363,000 MT) that an equivalent coal-fired plant would generate (Mortimer 29 1990). The study also projected that most of this 230,000 tons (209,000 MT) of CO 2 resulted 30 from the use of a coal-fired plant to perform uranium enrichment by gaseous diffusion, and that 31 using nuclear power and alternative enrichment methods in the future could reduce the amount 32 to 21,000 tons (19,000 MT) (Mortimer 1990).

33 Mortimer's study went on to demonstrate that the GHG impact of the nuclear fuel cycle would 34 increase as the grade of uranium ore mined dropped, and that the net emissions of CO 2 from 35 the nuclear and coal-fired alternatives would become equal once uranium ore grades reached 36 0.01-percent uranium oxide. However, Mortimer does not address differences in energy 37 consumption from future extraction and enrichment methods, the potential for higher grade 38 resource discovery, and technology improvements. Based on his cutoff ore grade and 39 projections of ore reserves, Mortimer estimated GHG emissions of nuclear and natural gas 40 generation would be similar after a period of 23 years (Mortimer 1990). The analysis also 41 compared GHG emissions associated with the nuclear fuel cycle with other electricity 42 generation and efficiency options, including hydroelectric, wind, tidal power, and new types of 43 insulation and lighting (but not including natural gas). The conclusion was that nuclear power December 2010 6-11 NUREG-1437, Supplement 38 OAGI0001367A_00321

Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 had lower GHG emissions compared to coal, but that GHG emissions associated with the 2 nuclear fuel cycle still exceeded those for renewable generation and conservation options 3 (Mortimer 1990).

4 The Mortimer (1990) study is not presented here to support a definitive conclusion regarding 5 whether nuclear energy produces fewer GHG emissions than other alternatives and similar 6 discussions will not be presented in this SEIS for each of the available studies. Instead, the 7 NRC staff presents the Mortimer (1990) study to provide an example of the types of 8 considerations underlying the calculations and arguments presented by the various authors.

9 Almost every existing study has been critiqued, and its assumptions challenged, by later 10 authors. Therefore, no single study has been selected to represent definitive results in this 11 SEIS. Instead, the results from a variety of the studies are presented in Tables 6-2, 6-3, and 12 6-4 to provide a weight-of-evidence argument comparing the relative GHG emissions resulting 13 from the proposed IP2 and IP3 relicensing compared to the potential alternative use of coal-fired 14 plants, natural gas-fired plants, and renewable energy sources.

15 6.2.5 Summary of Nuclear Greenhouse Gas Emissions Compared to Coal 16 Because coal is the fuel most commonly used to generate electricity in the United States, and 17 the burning of coal results in the largest emissions of GHGs for any of the likely alternatives to 18 nuclear power, most of the available quantitative studies have focused on comparisons of the 19 relative GHG emissions of nuclear to coal-fired generation. The quantitative estimates of the 20 GHG emissions associated with the nuclear fuel cycle, as compared to an equivalent coal-fired 21 plant, are presented in Table 6-2.

22 Table 6-2. Nuclear GHG Emissions Compared to Coal Source GHG Emission Results Mortimer 1990 Nuclear-230,000 tons CO 2 Coal-S,912,000 tons CO 2 Note: Future GHG emissions from nuclear to increase because of declining ore grade Andseta et al. Nuclear energy produces 1.4 percent of the GHG emissions compared to 1998 coal.

Note: Future reprocessing and use of nuclear-generated electrical power in the mining and enrichment steps are likely to change the projections of earlier authors, such as Mortimer (1990).

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Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1

Spadaro 2000 Nuclear-2.5 to 5.7 g Ceq/kWh Coal-264 to 357 g Ceq/kWh Storm van Authors did not evaluate nuclear versus coal.

Leeuwen and Smith 2005 Fritsche 2006 Nuclear-33 g Ceq/kWh (values estimated Coal-950 g Ceq/kWh from graph in Figure 4)

POST 2006 Nuclear-5 g Ceq/kWh (Nuclear Coal->1000 g Ceq/kWh calculations from AEA 2006) Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 6.8 g Ceq /kWh. Future improved technology and carbon capture and storage could reduce coal-fired GHG emissions by 90 percent.

Weisser 2006 Nuclear-2.8 to 24 g Ceq/kWh (compilation of results from other Coal-950 to 1250 g Ceq/kWh studies)

Fthenakis and Kim Authors did not evaluate nuclear versus coal.

(2007)

Dones 2007 Author did not evaluate nuclear versus coal.

2 6.2.6 Summary of Nuclear Greenhouse Gas Emissions Compared to Natural Gas 3 The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle, as 4 compared to an equivalent natural gas-fired plant, are presented in Table 6-3.

5 Table 6-3. Nuclear GHG Emissions Compared to Natural Gas Source GHG Emission Results Mortimer 1990 Author did not evaluate nuclear versus natural gas.

Andseta 1998 Author did not evaluate nuclear versus natural gas.

Spadaro 2000 Nuclear-2.5 to 5.7 g Ceq/kWh Natural Gas-120 to 188 g Ceq/kWh Storm van Nuclear fuel cycle produces 20 to 33% of the GHG emissions compared to Leeuwen and natural gas (at high ore grades).

Smith 2005 Note: Future nuclear GHG emissions to increase because of declining ore grade.

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Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1

Fritsche 2006 Nuclear-33 g Ceq/kWh (values estimated Cogeneration Combined Cycle Natural Gas-1S0 g Ceq/kWh from graph in Figure 4)

POST 2006 Nuclear-S g Ceq/kWh (Nuclear calculations from Natural Gas-SOO g Ceq/kWh AEA 2006) Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 6.8 g Ceq/kWh. Future improved technology and carbon capture and storage could reduce natural gas GHG emissions by 90%.

Weisser 2006 Nuclear-2.8 to 24 g Ceq/kWh (compilation of Natural Gas-440 to 780 g Ceq/kWh results from other studies)

Fthenakis and Kim Authors did not evaluate nuclear versus natural gas.

(2007)

Dones 2007 Author critiqued methods and assumptions of Storm van Leeuwen and Smith (200S), and concluded that the nuclear fuel cycle produces 1S to 27%

of the GHG emissions of natural gas.

2 6.2.7 Summary of Nuclear Greenhouse Gas Emissions Compared to Renewable 3 Energy Sources 4 The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle, as 5 compared to equivalent renewable energy sources, are presented in Table 6-4. Calculation of 6 GHG emissions associated with these sources is more difficult than the calculations for nuclear 7 energy and fossil fuels because the efficiencies of the different energy sources vary so much by 8 location. For instance, the efficiency of solar and wind energy is highly dependent on the 9 location in which the power generation facility is installed. Similarly, the range of GHG 10 emissions estimates for hydropower varies greatly depending on the type of dam or reservoir 11 involved. Therefore, the GHG emissions estimates for these energy sources have a greater 12 range of variability than the estimates for nuclear and fossil fuel sources.

13 Table 6-4. Nuclear GHG Emissions Compared to Renewable Energy Sources Source GHG Emission Results Mortimer 1990 Nuclear-230,000 tons CO 2 Hydropower-78,000 tons CO 2 Wind power-S4,000 tons CO 2 Tidal power-S2,SOO tons CO 2 Note: Future GHG emissions from nuclear to increase because of declining ore grade.

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Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management Andseta 1998 Author did not evaluate nuclear versus renewable energy sources.

Spadaro 2000 Nuclear-2.5 to 5.7 9 Ceq/kWh Solar PV-27.3 to 76.4 9 Ceq/kWh Hydroelectric-1.1 to 64.6 9 Ceq/kWh Biomass-8.4 to 16.6 9 Ceq/kWh Wind-2.5 to 13.1 9 Ceq/kWh Storm van Author did not evaluate nuclear versus renewable energy sources.

Leeuwen and Smith 2005 Fritsche 2006 Nuclear-33 9 Ceq/kWh (values estimated Solar PV-125 9 Ceq/kWh from graph in Figure 4) Hydroelectric-50 9 Ceq/kWh Wind-20 9 Ceq/kWh POST 2006 Nuclear-5 9 Ceq/kWh (Nuclear Biomass-25 to 93 9 Ceq/kWh calculations from AEA 2006) Solar PV-35 to 58 9 Ceq/kWh WavelTidal-25 to 50 9 Ceq/kWh Hydroelectric-5 to 30 9 Ceq/kWh Wind-4.64 to 5.25 9 Ceq/kWh Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 6.8 9 Ceq/kWh.

Weisser 2006 Nuclear-2.8 to 24 9 Ceq/kWh (compilation of Solar PV--43 to 73 9 Ceq/kWh results from other studies) Hydroelectric-1 to 34 9 Ceq/kWh Biomass-35 to 99 9 Ceq/kWh Wind-8 to 30 9 Ceq/kWh Fthenakis and Kim Nuclear-16 to 55 9 Ceq/kWh (2007)

Solar PV-17 to 49 9 Ceq/kWh Dones 2007 Author did not evaluate nuclear versus renewable energy sources.

1 6.2.8 Conclusions 2 Estimating the GHG emissions associated with current nuclear energy sources is challenging 3 because of differing assumptions and noncomparable analyses performed by the various 4 authors. The differences and complexities in these assumptions and analyses increase when December 2010 6-15 NUREG-1437, Supplement 38 OAGI0001367A_00325

Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 using them to project future GHG emissions. However, even with these differences, the NRC 2 staff can draw several conclusions.

3 First, the studies indicate a consensus that nuclear power currently produces fewer GHG 4 emissions than fossil-fuel-based electrical generation. Based on the literature review, the 5 lifecycle GHG emissions from the complete nuclear fuel cycle currently range from 2.5 to 6 33 g Ceq/kWh. The comparable lifecycle GHG emissions from the current use of coal range 7 from 264 to 1250 g Ceq/kWh, and GHG emissions from the current use of natural gas range 8 from 120 to 780 g Ceq/kWh. The existing studies also provided estimates of GHG emissions 9 from five renewable energy sources, based on current technology. These estimates included 10 solar-photovoltaic (17 to 125 g Ceq/kWh), hydroelectric (1 to 64.6 g Ceq/kWh), biomass (8.4 to 11 99 g Ceq/kWh), wind (2.5 to 30 g Ceq/kWh), and tidal (25 to 50 g Ceq/kWh). The range of these 12 estimates is very wide, but the general conclusion is that the current GHG emissions from the 13 nuclear fuel cycle are of the same order of magnitude as those for these renewable energy 14 sources.

15 Second, the studies indicate no consensus on future relative GHG emissions from nuclear 16 power and other sources of electricity. There is substantial disagreement among the various 17 authors regarding the GHG emissions associated with declining uranium ore concentrations, 18 future uranium enrichment methods, and other factors, including changes in technology. Similar 19 disagreement exists regarding future GHG emissions associated with coal and natural gas 20 electricity generation. Even the most conservative studies conclude that the nuclear fuel cycle 21 currently produces fewer GHG emissions than fossil-fuel-based sources, and are expected to 22 continue to do so in the near future. The primary difference between the authors is the 23 projected cross-over date (the time at which GHG emissions from the nuclear fuel cycle exceed 24 those of fossil-fuel-based sources) or whether cross-over will actually occur at all.

25 Considering the current estimates and future uncertainties, it appears that GHG emissions 26 associated with the proposed I P2 and I P3 relicensing action are likely to be lower than those 27 associated with fossil-fuel-based energy sources. The NRC staff bases this conclusion on the 28 following rationale:

29 (1) The current estimates of GHG emissions from the nuclear fuel cycle are far below those 30 for fossil-fuel-based energy sources.

31 (2) IP2 and IP3 license renewal will involve continued uranium mining, processing, and 32 enrichment, but will not result in increased GHG emissions associated with plant 33 construction or decommissioning (as the plant will have to be decommissioned at some 34 point whether the license is renewed or not).

35 (3) Few studies predict that nuclear fuel cycle emissions will exceed those of fossil fuels 36 within a timeframe that includes the IP2 and IP3 periods of extended operation. Several 37 studies suggest that future extraction and enrichment methods, the potential for higher 38 grade resource discovery, and technology improvements could extend this timeframe.

39 With respect to comparison of GHG emissions between the proposed IP2 and IP3 license 40 renewal action and renewable energy sources, it appears likely that there will be future 41 technology improvements and changes in the type of energy used for mining, processing, and 42 constructing facilities in both areas. Currently, the GHG emissions associated with the nuclear 43 fuel cycle and renewable energy sources are within the same range. Because nuclear fuel 44 production is the most significant contributor to possible future increases in GHG emissions NUREG-1437, Supplement 38 6-16 December 2010 OAGI0001367A_00326

Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 from nuclear power, and because most renewable energy sources lack a fuel component, it is 2 likely that GHG emissions from renewable energy sources would be lower than those 3 associated with IP2 and IP3 at some point during the period of extended operation.

4 6.3 References 5 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for 6 Protection Against Radiation."

7 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 8 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

9 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for 10 Renewal of Operating Licenses for Nuclear Power Plants."

11 10 CFR Part 63. Code of Federal Regulations, Title 10, Energy, Part 63, "Disposal of High-12 Level Radioactive Wastes in a Geologic Repository at Yucca Mountain, Nevada."

13 40 CFR Part 191. Code of Federal Regulations, Title 40, Protection of Environment, Part 191, 14 "Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear 15 Fuel, High-Level and Transuranic Radioactive Waste."

16 73 FR 59551. "Nuclear Regulatory Commission, 10 CFR Part 51, Waste Confidence Decision 17 Update." (October 9,2008).

18 AEA Technology (AEA). 2006. "Carbon Footprint of the Nuclear Fuel Cycle, Briefing Note."

19 Prepared for British Energy. March 2006.

20 Andseta, S., M.J. Thompson, J.P. Jarrell, and D.R. Pendergast. 1998. "CANDU Reactors and 21 Greenhouse Gas Emissions." Canadian Nuclear Association, 11th Pacific Basin Nuclear 22 Conference, Banff, Alberta, Canada. May 1998.

23 Department of Energy (DOE). 1980. "Final Environmental Impact Statement: Management of 24 Commercially Generated Radioactive Waste." DOE/EIS-0046F, Washington, DC.

25 Dones, R. 2007. "Critical Note on the Estimation by Storm Van Leeuwen J.W. and Smith P. of 26 the Energy Uses and Corresponding CO 2 Emissions for the Complete Nuclear Energy Chain."

27 Paul Sherer Institute. April 2007.

28 Entergy Nuclear Northeast. 2002. "Entergy Nuclear Indian Point 2, LLC and Entergy Nuclear 29 Indian Point 3, LLC, Village of Buchanan, New York, Emissions Avoidance Study." Prepared by 30 TRC Environmental Corporation, Lyndhurst, New Jersey. August 2002.

31 Entergy Nuclear Operations, Inc. (Entergy). 2007. "Applicant's Environment Report, Operating 32 License Renewal Stage." (Appendix E to Indian Point, Units 2 and 3, License Renewal 33 Application). April 23, 2007. Agencywide Documents Access and Management System 34 (ADAMS) Accession No. ML071210530.

35 Fritsche, U.R. 2006. "Comparison of Greenhouse-Gas Emissions and Abatement Cost of 36 Nuclear and Alternative Energy Options from a Life-Cycle Perspective." Oko-Institut, Darmstadt 37 Office. January 2006.

38 Fthenakis, V.M., and H.C. Kim. 2007. Greenhouse-gas emissions from solar electric- and December 2010 6-17 NUREG-1437, Supplement 38 OAGI0001367A_00327

Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 nuclear power: A life cycle study. Energy Policy, Volume 35, Number 4.

2 Hagen, R.E., J.R. Moens, and Z.D. Nikodem. 2001. "Impact of U.S. Nuclear Generation on 3 Greenhouse Gas Emissions." International Atomic Energy Agency, Vienna, Austria. November 4 2001.

5 International Atomic Energy Agency (lAEA). 2000. "Nuclear Power for Greenhouse Gas 6 Mitigation under the Kyoto Protocol: The Clean Development Mechanism (COM)." November 7 2000.

8 Joint Resolution 87, 2002. Public Law 107-200, 116 Stat 735.

9 Keepin, B. 1988. "Greenhouse Warming: Efficient Solution of Nuclear Nemesis?" Rocky 10 Mountain Institute. Joint Hearing on Technologies for Remediating Global Warming, 11 Subcommittee on Natural Resources, Agriculture Research and Environment and 12 Subcommittee on Science, Research and Technology, United States House of Representatives.

13 June 1988.

14 Massachusetts Institute of Technology (MIT). 2003. "The Future of Nuclear Power: An 15 Interdisciplinary MIT Study."

16 Mortimer, N. 1990. World warms to nuclear power. SCRAM Safe Energy Journal. December 17 1989 and January 1990. Available at URL:

18 http://www.n02nuclearpower.org.uk/articles/mortimer se74.php. Accessed February 29,2007.

19 National Academy of Sciences (NAS). 1995. "Technical Bases for Yucca Mountain Standards."

20 Washington, DC.

21 National Environmental Policy Act of 1969 (NEPA). 42 USC 4321, et. seq.

22 Nuclear Information and Resource Service and World Information Service on Energy 23 (NIRSIWISE). 2005. Nuclear power: No solution to climate change. Nuclear Monitor, 24 Numbers 621 and 622. February 2005.

25 Nuclear Regulatory Commission (NRC). 1996. "Generic Environmental Impact Statement for 26 License Renewal of Nuclear Power Plants." NUREG-1437, Volumes 1 and 2, Washington, DC.

27 Nuclear Regulatory Commission (NRC). 1999. "Generic Environmental Impact Statement for 28 License Renewal of Nuclear Plants Main Report," Section 6.3, "Transportation," Table 9.1, 29 "Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants."

30 NUREG-1437, Volume 1, Addendum 1, Washington, DC.

31 Nuclear Energy Agency (NEA). 2002. Organization for Economic Co-Operation and 32 Development, Nuclear Energy and the Kyoto Protocol.

33 Parliamentary Office of Science and Technology (POST). 2006. "Carbon Footprint of Electricity 34 Generation." Postnote, Number 268. October 2006.

35 Schneider, M. 2000. Climate Change and Nuclear Power. World Wildlife Fund for Nature.

36 April 2000.

37 Spadaro, J.v., L. Langlois, and B. Hamilton. 2000. "Greenhouse Gas Emissions of Electricity 38 Generation Chains: Assessing the Difference." IAEA Bulletin 42/2/2000, Vienna, Austria.

39 Storm van Leeuwen, J.W., and P. Smith. 2005. Nuclear Power-The Energy Balance. August NUREG-1437, Supplement 38 6-18 December 2010 OAGI0001367A_00328

Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management 1 2005.

2 Weisser, D. 2006. "A Guide to Life-Cycle Greenhouse Gas (GHG) Emissions from Electric 3 Supply Technologies." Available at URL:

4 http://www.aseanenvironmentinfo/abstract41 015146. pdf. Accessed March 3, 2008.

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1 7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING 2 Environmental impacts from the activities associated with the decommissioning of any reactor 3 before or at the end of an initial or renewed license are evaluated in NUREG-0586, 4 Supplement 1, "Generic Environmental Impact Statement on Decommissioning of Nuclear 5 Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors" (NRC 6 2002). The U.S. Nuclear Regulatory Commission (NRC) staff's evaluation of the environmental 7 impacts of decommissioning presented in NUREG-0586, Supplement 1, identifies a range of 8 impacts for each environmental issue.

9 The incremental environmental impacts associated with decommissioning activities resulting 10 from continued plant operation during the renewal term are discussed in NUREG-1437, 11 Volumes 1 and 2, "Generic Environmental Impact Statement for License Renewal of Nuclear 12 Plants" (hereafter referred to as the GElS) (NRC 1996, 1999).(1) The GElS includes a 13 determination of whether the analysis of the environmental issue could be applied to all plants 14 and whether additional mitigation measures would be warranted. Issues were then assigned a 15 Category 1 or a Category 2 designation. As set forth in the GElS, Category 1 issues are those 16 that meet all of the following criteria:

17 (1) The environmental impacts associated with the issue have been determined to apply 18 either to all plants or, for some issues, to plants having a specific type of cooling system 19 or other specified plant or site characteristics.

20 (2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 21 the impacts (except for collective offsite radiological impacts from the fuel cycle and from 22 high-level waste and spent fuel disposal).

23 (3) Mitigation of adverse impacts associated with the issue has been considered in the 24 analysis, and it has been determined that additional plant-specific mitigation measures 25 are likely not to be sufficiently beneficial to warrant implementation.

26 For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 27 required unless new and significant information is identified.

28 Category 2 issues are those that do not meet one or more of the criteria for Category 1; 29 therefore, additional plant-specific review of these issues is required. There are no Category 2 30 issues related to decommissioning.

31 7.1 Decommissioning 32 Category 1 issues in Table 8-1 of Appendix 8 to Subpart A, "Environmental Effect of Renewing 33 the Operating License of a Nuclear Power Plant," of Title 10, Part 51, "Environmental Protection 34 Regulations for Domestic Licensing and Related Regulatory Functions," of the Code of Federal 35 Regulations (10 CFR Part 51) that are applicable to IP2 and IP3 decommissioning following the 36 renewal term are listed in Table 7-1. Entergy Nuclear Operations, Inc. (Entergy), stated in the 37 IP2 and IP3 environmental report (ER) (Entergy 2007) that it is not aware of any new and 38 significant information regarding the environmental impacts of IP2 and IP3 license renewal, 39 though it did identify leaks from spent fuel pools as a potential new issue. The NRC staff (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 7-1 NUREG-1437, Supplement 38 OAGI0001367A_00330

Environmental Impacts of Decommissioning 1 addressed this issue in Sections 2.2.7,4.3, and 4.5 of this supplemental environmental impact 2 statement (SEIS). In Section 4.5, the NRC staff concludes that the abnormal liquid releases 3 (leaks) discussed by Entergy in its ER, while new information, are within the NRC's radiation 4 safety standards contained in 10 CFR Part 20 and are not considered to have a significant 5 impact on plant workers, the public, or the environment (i.e., while the information related to 6 spent fuel pool leakage is new, it is not significant).

7 The NRC staff has not identified any information during its independent review of the IP2 and 8 IP3 ER (Entergy 2007), the site visit, the scoping process, or its evaluation of other available 9 information that is both new and significant. Therefore, the NRC staff concludes that there are 10 no impacts related to the Category 1 issues applicable to the decommissioning of IP2 and IP3 11 beyond those discussed in the GElS. For all of these issues, the NRC staff concluded in the 12 GElS that the impacts are SMALL, and additional plant-specific mitigation measures are not 13 likely to be sufficiently beneficial to be warranted.

14 Table 7-1. Category 1 Issues Applicable to the Decommissioning of 15 IP2 and IP3 Following the Renewal Term ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Section DECOMMISSIONING Radiation doses 7.3.1 Waste management 7.3.2 Air quality 7.3.3 Water quality 7.3.4 Ecological resources 7.3.5 Socioeconomic impacts 7.3.7 16 A brief description of the NRC staff's review and the GElS conclusions, as codified in Table B-1, 17 10 CFR Part 51, for each of the issues follows:

18

• Radiation doses. Based on information in the GElS, the Commission found the 19 following:

20 Doses to the public will be well below applicable regulatory standards regardless 21 of which decommissioning method is used. Occupational doses would increase 22 no more than 1 man-rem caused by buildup of long-lived radionuclides during the 23 license renewal term.

24 The NRC staff has not identified any new and significant information during its independent 25 review of the IP2 and IP3 ER, the site visit, the scoping process, or its evaluation of other 26 available information. Therefore, the NRC staff concludes that there are no radiation dose 27 impacts associated with decommissioning following the license renewal term beyond those 28 discussed in the GElS.

I NUREG-1437, Supplement 38 7-2 December 2010 OAGI0001367A_00331

Environmental Impacts of Decommissioning 1

• Waste management. Based on information in the GElS, the Commission found the 2 following:

3 Decommissioning at the end of a 20-year license renewal period would generate 4 no more solid wastes than at the end of the current license term. No increase in 5 the quantities of Class C or greater than Class C wastes would be expected.

6 The NRC staff has not identified any new and significant information during its independent 7 review of the IP2 and IP3 ER, the site visit, the scoping process, or its evaluation of other 8 available information. Therefore, the NRC staff concludes that there are no impacts from solid 9 waste associated with decommissioning following the license renewal term beyond those 10 discussed in the GElS.

11

• Air quality. Based on information in the GElS, the Commission found the following 12 Air quality impacts of decommissioning are expected to be negligible either at the 13 end of the current operating term or at the end of the license renewal term.

14 The NRC staff has not identified any new and significant information during its independent 15 review of the IP2 and IP3 ER, the site visit, the scoping process, or its evaluation of other 16 available information. Therefore, the NRC staff concludes that there are no impacts on air 17 quality associated with decommissioning following the license renewal term beyond those 18 discussed in the GElS.

19

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

20 The potential for significant water quality impacts from erosion or spills is no 21 greater whether decommissioning occurs after a 20-year license renewal period 22 or after the original 40-year operation period, and measures are readily available 23 to avoid such impacts.

24 The NRC staff has not identified any new and significant information during its independent 25 review of the IP2 and IP3 ER, the site visit, the scoping process, or its evaluation of other 26 available information. Therefore, the NRC staff concludes that there are no impacts on water 27 quality associated with decommissioning following the license renewal term beyond those 28 discussed in the GElS.

29

• Ecological resources. Based on information in the GElS, the Commission found the 30 following:

31 Decommissioning after either the initial operating period or after a 20-year 32 license renewal period is not expected to have any direct ecological impacts.

33 The NRC staff has not identified any new and significant information during its independent 34 review of the IP2 and IP3 ER, the site visit, the scoping process, or its evaluation of other 35 available information. Therefore, the NRC staff concludes that there are no impacts on 36 ecological resources associated with decommissioning following the license renewal term 37 beyond those discussed in the GElS.

38

• Socioeconomic Impacts. Based on information in the GElS, the Commission found the 39 following:

December 2010 7-3 NUREG-1437, Supplement 38 I OAGI0001367A_00332

Environmental Impacts of Decommissioning 1 Decommissioning would have some short-term socioeconomic impacts. The 2 impacts would not be increased by delaying decommissioning until the end of a 3 20-year relicense period, but they might be decreased by population and 4 economic growth.

5 The NRC staff has not identified any new and significant information during its independent 6 review of the IP2 and IP3 ER, the site visit, the scoping process, or its evaluation of other 7 available information. Therefore, the NRC staff concludes that there are no socioeconomic 8 impacts associated with decommissioning following the license renewal term beyond those 9 discussed in the GElS.

10 7.2 References 11 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for 12 Protection Against Radiation."

13 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 14 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

15 Entergy Nuclear Operations, Inc. (Entergy). 2007. "Applicant's Environment Report, Operating 16 License Renewal Stage." (Appendix E to Indian Point, Units 2 and 3, License Renewal 17 Application). April 23, 2007. Agencywide Documents Access and Management System 18 (ADAMS) Accession No. ML071210530.

19 Nuclear Regulatory Commission (NRC). 1996. "Generic Environmental Impact Statement for 20 License Renewal of Nuclear Power Plants." NUREG-1437, Volumes 1 and 2, Washington, DC.

21 Nuclear Regulatory Commission (NRC). 1999. "Generic Environmental Impact Statement for 22 License Renewal of Nuclear Plants Main Report," Section 6.3, "Transportation," Table 9.1, 23 "Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants."

24 NUREG-1437, Volume 1, Addendum 1, Washington, DC.

25 Nuclear Regulatory Commission (NRC). 2002. "Generic Environmental Impact Statement on 26 Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of 27 Nuclear Power Reactors." NUREG-0586, Volumes 1 and 2, Supplement 1, Washington, DC.

I NUREG-1437, Supplement 38 7-4 December 2010 OAGI0001367A_00333

1 8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES 2 TO LICENSE RENEWAL 3 This chapter examines the potential environmental impacts associated with (1) a closed-cycle 4 cooling system alternative to replace the Indian Point Nuclear Generating Unit No.2 (lP2) and 5 Unit No.3 (lP3) existing once-through cooling-water systems, (2) denying the renewal of both 6 operating licenses for IP2 and IP3 (i.e., the no-action alternative), (3) replacing the electric 7 generation capacity of both units with alternative electric-generation sources or energy 8 conservation, (4) importing electric power from other sources to replace power generated by IP2 9 and IP3, and (5) combinations of generation and conservation measures to replace power 10 generated by IP2 and/or IP3. In addition, this chapter briefly discusses other alternatives that 11 were deemed unsuitable to replace power generated collectively by IP2 and IP3.

12 As NRC staff indicated in its 1996 statements of consideration in promulgating the final license 13 renewal environmental rules (61 FR 28467; June 5, 1996), NRC staff evaluates alternative 14 energy sources as direct alternatives to license renewal, and not simply as consequences of the 15 no-action alternative. Many comments received by the staff after the publication of the draft 16 SEIS appear to conflate energy alternatives with the no-action alternative. Whether NRC 17 renews a license or not, all alternatives to license renewal are available to energy planning 18 decision makers. Continued operation, however, is only an available option if NRC grants 19 renewed licenses. NRC evaluates, in this chapter, likely environmental impacts from 20 alternatives in order to provide a comparison that allows NRC to determine whether or not the 21 adverse environmental impacts of license renewal are so great that preserving the option of 22 license renewal for energy planning decisionmakers would be unreasonable (N RC's "decision 23 standard" from 10 CFR 51.95(c)(4)).

24 This chapter contains a number of updated or revised discussions in response to comments on 25 the draft SEIS. First, NRC staff no longer considers a restoration-based alternative for 26 complying with New York State Department of Environmental Conservation (NYSDEC) 27 determinations on aquatic impacts from IP2 and IP3. As indicated in several comments NRC 28 staff received on the draft SEIS, the U.S. Second Circuit Court of Appeals has held that habitat 29 restoration is an impermissible means of complying with 316(b) (in Riverkeeper / and 30 Riverkeeper /1). Because the restoration alternative relied on habitat restoration to meet 316(b) 31 goals, and would not be capable of meeting 316(b) goals in the absence of the restoration 32 portion, the NRC staff has removed the restoration alternative from this SEIS.

33 The NRC staff has also removed the coal-fired alternative from the range of alternatives 34 considered in depth (though staff has retained the discussion from the draft SEIS in Section 35 8.3.4, Alternatives Dismissed from Individual Consideration, based partly on comments 36 regarding greenhouse gas and permitting restrictions in New York State, as well as on 37 indications from the U.S. Department of Energy that coal use in New York State power 38 generation is markedly declining. The Staff has also updated its combination alternatives, 39 recognized that a gas-fired facility could also be a repowering project at an existing power plant, 40 and upgraded its consideration of energy conservation to a full alternative given projections from 41 New York State's energy efficiency (here used interchangeably with energy conservation) 42 programs.

43 As in the draft SEIS, the NRC staff considered an alternative to the existing IP2 and IP3 cooling-44 water systems because the New York State Department of Environmental Conservation December 2010 8-1 NUREG-1437, Supplement 38 OAGI0001367A_00334

Environmental Impacts of Alternatives to License Renewal 1 (NYSDEC) identified closed-cycle cooling (e.g., cooling towers) as the best technology available 2 (BTA) to reduce fish mortality in the draft New York State Pollutant Discharge Elimination 3 System (SPDES) discharge permit (NYSDEC 2003a). This alternative is described in Section 4 8.1 of this SEIS. IP2 and IP3 have been operating under timely renewal provisions of the New 5 York SPDES permit process since 1992. In 2004, NYSDEC issued a revised draft SPDES 6 permit, including the BTA determination. The requirements, limits, and conditions of the draft 7 SPDES permit had not been finalized at the time the NRC staff performed the assessment 8 presented in this SEIS, and are subject to ongoing adjudication.

9 The environmental impacts of alternatives are evaluated using the NRC's three-level standard 10 of significance-SMALL, MODERATE, or LARGE-developed based on the Council on 11 Environmental Quality (CEQ) guidelines and set forth in the footnotes to Table B-1 of 12 Appendix B to Subpart A, "Environmental Effect of Renewing the Operating License of a 13 Nuclear Power Plant," of Title 10, Part 51, "Environmental Protection Regulations for Domestic 14 Licensing and Related Regulatory Functions," of the Code of Federal Regulations 15 (10 CFR Part 51). The following definitions are used for each category:

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 important attributes of the resource.

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

22 The impact categories evaluated in this chapter are the same as those used in NUREG-1437, 23 Volumes 1 and 2, "Generic Environmental Impact Statement for License Renewal of Nuclear 24 Plants" (hereafter referred to as the GElS) (NRC 1996, 1999)(1) with the additional impact 25 categories of environmental justice and transportation.

26 8.1 Alternatives to the Existing IP2 and IP3 Cooling-Water 27 System 28 IP2 and IP3 currently use once-through cooling-water systems that withdraw water from and 29 discharge water to the Hudson River as described in Section 2.1.3 of this SEIS. The circulating 30 water systems for IP2 and IP3 include two intake structures, each containing seven pumps.

31 The maximum flow rate for the facility is 6,553,000 Ipm (1,731,000 gpm) IP2 uses dual-speed 32 pumps and IP3 uses variable-speed pumps.

33 Warm discharge water from IP2 and IP3 flows from the condensers through six pipes that are 34 2.4 meters (m) (94 inches (in.)) in diameter and exits beneath the water surface into a discharge 35 canal 12 m (39 feet (ft)) wide. Water flows from the discharge canal to the Hudson River 36 through an outfall structure located south of IP3 at a discharge velocity of about 3.7 meters per 37 second (mps) (12 feet per second (fps)). The design of the outfall is intended to reduce the 38 thermal impact the warm water may potentially have on the river. An assessment of the impacts (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.

NUREG-1437, Supplement 38 8-2 December 2010 OAGI0001367A_00335

Environmental Impacts of Alternatives to License Renewal 1 of the current cooling-water system on the environment is presented in Section 4.1 of this SEIS.

2 Surface water withdrawals and discharges at IP2 and IP3 are regulated under the New York 3 SPDES permit program. In 1975, the U.S. Environmental Protection Agency (EPA) issued 4 National Pollutant Discharge Elimination System (NPDES) permits for the facility.

5 Subsequently, the NYSDEC issued an SPDES permit for the facility in 1987. In 1992, a timely 6 renewal application was filed with the NYSDEC, and terms of the 1992 SPDES have been 7 continued under provisions of the NY State Administrative Procedure Act. Petitioners 8 commenced proceedings in 2002 to mandate that the NYSDEC act on the SPDES permit 9 renewal application. On April 8, 2003, the NYSDEC proposed to modify the SPDES permit to 10 require that IP2 and IP3 reduce the impacts to aquatic organisms caused by the once-through 11 cooling systems and that Entergy Nuclear Operations, Inc. (Entergy), complete a water quality 12 review. NYSDEC published a draft SPDES permit in 2003 (NYSDEC 2003), and then issued a 13 revised draft SPDES permit on March 2,2004 (NYSDEC 2010a). The 2003 draft and 2004 14 revised draft identified closed-cycle cooling as the BTA. NYSDEC affirmed this perspective in 15 its April 2, 2010, Notice of Denial of Entergy's Clean Water Act Section 401 Water Quality 16 Certification (NYSDEC 2010b), indicating that closed cycle cooling would minimize aquatic 17 impacts (the denial itself is currently subject to further state-level adjudication). Also, NYSDEC 18 has published a draft policy on BTA (NYSDEC 2010c) indicating that "Wet closed-cycle cooling 19 or its equivalent" is the "minimum performance goal for existing industrial facilities that operate a 20 CWIS [cooling water intake system] in connection with a point source thermal discharge ... "

21 The policy is in draft form and NYSDEC received public comments through July 9, 2010.

22 The revised draft SPDES permit requires that immediate and long-term steps be taken to 23 reduce the adverse impacts on the Hudson River estuary once the permit is issued (NYSDEC 24 2004). The short-term steps include mandatory outage periods, reduced intake during certain 25 times, continued operation of fish-impingement mitigation measures, the payment of $24 million 26 to a Hudson River Estuary Restoration Fund, and various studies. In the long term, IP2 and IP3 27 will have to implement the BTA to minimize environmental impacts to the aquatic ecology.

28 Should the BTA determination in the revised draft SPDES permit go into effect, final 29 implementation of the BTA is subject to NRC's approval only insofar as the NRC oversees the 30 plant's safety performance and ability to cool itself. ).

31 Specifically, the revised draft SPDES permit states the following:

32 Within six months of the effective date of this permit, the permitee must submit to 33 the NYSDEC ... its schedule for seeking and obtaining, during its permit term, all 34 necessary approvals from the NRC, Federal Energy Regulatory Commission 35 (FERC), and other government agencies to enable construction and operation of 36 closed-cycle cooling at Indian Point.

37 NYSDEC (2004) has also indicated that any alternative technology or technologies may be 38 proposed for IP2 and IP3 within 1 year of the permit's effective date. These technologies must 39 be able to minimize the adverse environmental impacts to a level equivalent to that achieved by 40 a closed-cycle cooling system at IP2 and IP3 (NYSDEC 2004).

41 The NYSDEC identified construction and operation of a closed-cycle cooling system at IP2 and 42 IP3 as its preferred alternative to meet current national performance standards for impingement 43 and entrainment losses. Entergy indicates that Entergy or its predecessors have proposed and December 2010 8-3 NUREG-1437, Supplement 38 OAGI0001367A_00336

Environmental Impacts of Alternatives to License Renewal 1 NYSDEC has rejected the following alternative cooling technologies as described in the IP2 and 2 IP3 ER (Entergy 2007). As a result, these options are not discussed further in this SEIS.

3

• Evaporative ponds, spray ponds, or cooling canals all require significantly more land 4 area than exists at the site.

5

• Dry cooling towers, which rely totally on sensible heat transfer, lack the efficiency of wet 6 or hybrid towers using evaporative cooling, and thus require a far greater surface area 7 than is available at the site. Additionally, because of their lower efficiency, dry towers 8 are not capable of supporting condenser temperatures necessary to be compatible with 9 IP2 or IP3 turbine design and, therefore, are not a feasible technology.

10

• Natural draft cooling towers, while potentially feasible, would be 137 to 152 m (450 to 11 500 ft) above ground level with significant adverse aesthetic impacts in an important 12 viewshed corridor. This option also would raise water vapor plume-related and sound 13 effects concerns. In the original EPA permitting proceeding, New York State opposed 14 natural draft cooling towers on aesthetic grounds.

15

• Single-stage mechanical-draft wet cooling towers were eliminated for a number of 16 reasons including, but not limited to, the dense water vapor plumes that may 17 compromise station operations (including visual signaling) and equipment over time, and 18 result in increased noise (Enercon 2003).

19 The EPA has concluded that, in some circumstances, retrofitting a plant to a closed-cycle 20 cooling system lacks demonstrated feasibility or economic practicality (EPA 2004). In addition, 21 Entergy asserts that retrofitting facilities the size and configuration of IP2 and IP3 with a closed-22 cycle cooling system is neither tried nor proven (Entergy 2007). Entergy also considers 23 mitigation measures currently implemented to protect aquatic wildlife as part of the once-24 through cooling system to be adequate in terms of minimizing impacts from current operations 25 and operations during the license renewal period (Entergy 2007).

26 Entergy expressed a number of concerns regarding financial or technical issues related to a 27 closed-cycle cooling retrofit (Entergy 2007), including high cost, a lengthy forced outage, and 28 lost power output due to parasitic losses from new cooling system components 29 Entergy notes that replacement power during the outage may carry negative air quality impacts, 30 and that the outage may have negative impacts on electric-system reliability and market pricing.

31 Finally, Entergy indicates that closed-cycle cooling would result in a loss of generating capacity 32 due to lowered thermal efficiency and parasitic loads related to cooling system pumps and 33 auxiliary systems (an average annual loss of 88 megawatts electric [MW(e)], per unit) because 34 of power demands of the closed-cycle system (Entergy 2010).

35 In the following chapter, the NRC staff will evaluate the environmental impacts associated with 36 installing a closed-cycle cooling system at Indian Point, as well as the environmental impacts 37 associated with a potentially-equivalent combination of plant modifications and restoration 38 activities. Regardless of the NRC staff's findings, the NRC does not have the regulatory 39 authority to implement the requirements of the Clean Water Act (CWA), and it is not up to the 40 NRC staff to judge the validity of Entergy's or others' claims in the ongoing NYSDEC SPDES 41 permit process.

NUREG-1437, Supplement 38 8-4 December 2010 OAGI0001367A_00337

Environmental Impacts of Alternatives to License Renewal 1 In 2004, EPA issued regulations for reducing impingement and entrainment losses at existing 2 electricity-generating facilities (EPA 2004). These regulations, known as the Phase II rule, 3 established standards for compliance with the requirements of Section 316(b) of the CWA, 4 which calls for intake structures to reflect the BTA for minimizing adverse environmental impact.

5 The EPA's Phase II rule established two compliance alternatives that reduce impingement 6 mortality by 80 to 95 percent of baseline and reduce organism entrainment by 60 to 90 percent 7 of baseline (EPA 2004). These regulations supported the requirements of the draft New York 8 SPDES permit's requirement that immediate and long-term steps be taken to minimize adverse 9 impacts on the Hudson River estuary.

10 The EPA's rules concerning Phase II of Section 316(b) of the CWA were struck down by the 11 U.S. Court of Appeals in the Second Circuit in January 2007. The Court also mandated the 12 conduct of a cost-benefit analysis under Section 316(b) of the CWA. Specifically, the EPA 13 suspended 40 CFR 122.2(r)(1)(ii) and (5) and Subpart J, "Requirements Applicable to Cooling 14 Water Intake Structures for Phase II Existing Facilities Under Section 316(b) of the Act," of 15 40 CFR Part 125, "Criteria and Standards for the National Pollutant Discharge Elimination 16 System," with the exception of 40 CFR 125.90(b) (EPA 2007). On April 1,2009, the Supreme 17 Court ruled that EPA may permissibly use cost-benefit analyses in its Phase II rule, though EPA 18 has yet to reinstate or reissue the rule. Nonetheless, the 1987 SPDES permit remains in effect, 19 pending the conclusion of State-level administrative and legal proceedings.

20 8.1.1 Closed-Cycle Cooling Alternative 21 Entergy's preferred close-cycle alternative consists of two hybrid mechanical-draft cooling 22 towers (Enercon 2003, Entergy 2007). IP2 and IP3 would utilize one cooling tower, each, for a 23 total of two towers onsite. Entergy rejected single-stage mechanical draft cooling towers, 24 indicating that the dense water vapor plumes from the towers may compromise station 25 operations (including visual signaling) and equipment over time, and single-stage towers may 26 result in increased noise (Enercon 2003).

27 Entergy asserts that a hybrid mechanical-draft cooling tower system, also referred to as a 28 "wet/dry" or "plume-abated" mechanical-draft cooling tower, addresses some of the 29 shortcomings of the cooling system types described in Section 8.1 (Entergy 2007). In the ER, 30 Entergy indicates that hybrid towers are "appreciably more expensive" than single-stage towers 31 (Entergy 2007).

32 A hybrid tower consists of a standard efficiency wet tower segment combined with a dry heat 33 exchanger section above it. The dry section eliminates visible plumes in the majority of 34 atmospheric conditions. After the plume leaves the lower "wet" section of the tower, it travels 35 upward through a "dry" section where heated, relatively dry air is mixed with the plume in the 36 proportions required to achieve a nonvisible plume. Because of the "dry" section, which is on 37 top of the "wet" section, hybrid towers are slightly taller than comparable wet towers and require 38 a larger footprint (Entergy 2007). A potential exists for increased noise from additional fans in 39 the dry section, although Entergy indicates that sound effects can be attenuated (Entergy 2007).

40 Portions of the site where Entergy could construct cooling towers are heavily forested, with 41 rocky terrain and some steep slopes. Entergy indicates that these areas can be more 42 environmentally sensitive and costly to build on.

December 2010 8-5 NUREG-1437, Supplement 38 I OAGI0001367A_00338

Environmental Impacts of Alternatives to License Renewal 1 The NRC staff has previously assessed closed cycle cooling with a hybrid cooling tower in the 2 license renewal SEIS for Oyster Creek Nuclear Generating Station (OCNGS) (NRC 2006). The 3 NRC staff finds that a hybrid cooling tower system is a reasonable design for the purpose of 4 evaluating potential environmental impacts in a NEPA document. However, the NRC staff does 5 not intend for this analysis to prejudice potential requirements imposed by NYSDEC or other 6 authorities.

7 8.1.1.1 Description of the Closed-Cycle Cooling Alternative 8 As described in the Entergy's "Engineering Feasibility and Costs of Conversion of Indian Point 9 Units 2 and 3 to a Closed-Loop Condenser Cooling Water Configuration" (Enercon 2010, 10 prepared for Entergy), new hybrid cooling towers would be large, approximately 160 m (525 ft) 11 in diameter and 50 m (165 ft) high. To provide construction access for tower erection and 12 clearance for air intake, the excavation diameter for each tower would be approximately 215 m 13 (700 ft) (Enercon 2010). The locations for the IP2 and IP3 towers are expected to be 14 approximately 305 m (1000 ft) north of the IP2 reactor and approximately 305 m (1000 ft) south 15 of the IP3 reactor, respectively (Entergy 2007). A detailed description of a round hybrid cooling 16 tower conceptual design is presented in the 2010 engineering feasibility and cost evaluation 17 (Enercon 2010). Crews excavating areas for the cooling tower basins and associated piping will 18 need to blast substantial amounts of rock during the construction process.

19 As noted in Section 8.1, the closed-cycle cooling alternative would introduce parasitic losses 20 from additional pumps and other equipment. The new circulating pumps would likely be housed 21 in a new pumphouse located along the discharge canal (Enercon 2010). The new, enclosed 22 pumphouse would supply circulating water to the new towers via two concrete-lined steel pipes 233m (10ft) in diameter. Flow from the cooling tower basin to the condenser is expected via two 24 pipes 3.7 m (12 ft) in diameter (Enercon 2010).

25 Enercon also reported that two dedicated substations would likely supply electricity to the 26 closed-cycle cooling system from the 138-kilovolt (kV) offsite switchyard. The substation 27 transformers, switch gear, and system controls for each tower and pumphouse would be 28 housed in prefabricated metal buildings (Enercon 2003).

29 8.1.1.2 Environmental Impacts of the Closed-Cycle Cooling Alternative 30 In this section, the NRC staff addresses the impacts that would occur if Entergy constructs and 31 operates the closed-cycle cooling system described in Section 8.1.1.1. The NRC staff 32 summarizes anticipated impacts of the closed-cycle cooling alternative in Table 8-1. In the 33 areas of land use, terrestrial ecology, terrestrial threatened and endangered species, waste, 34 transportation and aesthetics, the environmental impacts of constructing and operating this 35 closed-cycle cooling system would be greater than the impacts associated with the existing 36 once-through cooling system, primarily due to construction-stage impacts. The closed-cycle 37 cooling alternative significantly reduces impacts to aquatic ecology, including impacts from 38 entrainment, impingement, and heat shock. Impacts to aquatic threatened and endangered 39 species - already SMALL - are also likely to further decline. In the following sections, the NRC 40 staff presents the potential environmental impacts of installing and operating a closed-cycle 41 cooling alternative at Indian Point. The NRC staff addresses impacts for each resource area.

42

• Land Use 43 Construction of two hybrid mechanical-draft cooling towers would entail significant clearing and NUREG-1437, Supplement 38 8-6 December 2010 OAGI0001367A_00339

Environmental Impacts of Alternatives to License Renewal 1 excavation of the currently timbered areas within the IP2 and IP3 exclusion area. Each cooling 2 tower requires an excavated area of approximately 3.6 hectares (ha) (9 acres (ac)). Ultimately, 3 approximately 16 ha (40 ac), most of which is presently wooded (though previously disturbed; 4 ENN 2007), would need to be cleared for the two cooling towers, access roads, and support 5 facilities (Enercon 2003). The towers would be located within the property exclusion area 6 boundary adjacent to existing facilities as described in Section 8.1.1.1.

7 Unlike the IP2 tower, the proposed IP3 cooling tower would be located in the permanent right-8 of-way (ROW) easement granted to the Algonquin Gas Transmission Company (AGTC) for 9 constructing, maintaining, and operating the two natural gas pipelines that traverse the IP2 and 10 IP3 site (Entergy 2007, ENN 2010, Enercon 2010). These pipelines transport natural gas under 11 the Hudson River, across the IP2 and IP3 site, and exit the site between Bleakley Avenue and 12 the Buchanan substation (see Figure 2-3 in Chapter 2 of this SEIS for a graphical 13 representation).

14 Entergy indicates that roughly 305 m (1000 ft) of river bank would be clear-cut and excavated to 15 allow for the installation of the four large-diameter water pipes (two 3-m-diameter supply pipes 16 and two 3.7-m-diameter pipes to each condenser) required for each tower (Entergy 2007). In 17 addition, Enercon reports that the base of each tower would be constructed on bedrock at an 18 elevation of about 9.1 m (30 ft) above mean sea level. This would entail the removal of 19 approximately 2 million cubic yards (cy) (1.5 million cubic meters (m 3)) of material, primarily rock 20 and dirt, using traditional excavation methods as well as a significant amount of blasting 21 (Enercon 2010). This volume of material includes material excavated to allow rerouting of the 22 Algonquin pipeline. Disposal of 2 million cy (1.5 million m3 ) of material from the excavations for 23 the cooling towers would create some offsite land use impacts. Excavated material also may be 24 recycled or reused, which would reduce these impacts.

25 Entergy indicates that ROW easement agreement calls for AGTC to relocate the pipelines at 26 Entergy's request. The FERC would first have to review and approve any such action. Entergy 27 must also provide a suitable location for the pipeline on its land or land that it has acquired 28 (Entergy 2007). Entergy indicates that pipeline relocation may require blasting and could also 29 require Entergy to purchase additional land adjacent to the IP2 and IP3 site if onsite areas aren't 30 suitable for the pipeline (Entergy 2007). Entergy's 2010 feasibility and cost evaluation indicates 31 that relocation would be feasible, through additional regulatory approvals (Enercon 2010).

32 The IP2 and IP3 site is within New York's Coastal Zone. As indicated in Chapter 2, the IP2 and 33 IP3 site is located adjacent to a Significant Coastal Fish and Wildlife Habitat, as well as a Scenic 34 Area of Statewide Significance. Construction activities, such as grading, excavating, and filling, 35 would require a coastal erosion management permit. Permitting restrictions would influence the 36 construction of the cooling towers but they would not likely prevent Entergy from building the 37 towers.

38 Excavation for the cooling towers would cut into the side of the hills east of IP2 and IP3, 39 resulting in the removal of approximately 2 million cy (1.5 million m3 ) of material, including 40 mostly rock as well as dirt (Enercon 2010). In areas where the excavation intersects onsite 41 plumes of groundwater contaminated with tritium, strontium-90, and other radionuclides, 42 Entergy expects that excavated material will also be contaminated. The 2010 feasibility and 43 cost evaluation indicates that at least 6350 cy may be contaminated (Enercon 2010). Any 44 contaminated material would require appropriate disposal as radioactive waste. Currently, the December 2010 8-7 NUREG-1437, Supplement 38 OAGI0001367A_00340

Environmental Impacts of Alternatives to License Renewal 1 only available disposal site for low-level radioactive wastes is in Clive, Utah.

2 Entergy's 2010 feasibility and cost study indicated that clean spoils from blasting could be 3 marketed as commodity crushed stone for construction projects, used as mine fill. Entergy 4 could also dispose of spoils in artificial reef projects off the New Jersey and New York coasts, 5 though their analysis indicates that additional permitting requirements may result (Enercon 6 2010). The NRC staff concludes that construction activities associated with cooling tower 7 installation at IP2 and IP3 would likely result in SMALL to LARGE land use impacts, depending 8 largely on how much material Entergy is able to reuse or recycle, and where Entergy disposes 9 of excavated material that cannot be reused or recycled.

10

• Ecology 11 Aquatic ecoloav. Land-clearing and construction activities can cause short-term, localized 12 impacts on streams and rivers from increased site runoff. These impacts are generally 13 mitigated through the use of erosion and sediment controls. Because of the size of the 14 construction area needed for the cooling towers at the IP2 and IP3 site, such measures would 15 be necessary to limit erosion and sediment deposition in the Hudson River. Construction 16 impacts, however, would be relatively short-lived, and would be offset to some degree by 17 reduced water consumption during prolonged outages at IP2 and IP3 when Entergy or its 18 contractors would connect the closed-cycle cooling system to the units.

19 Following construction, the closed-cycle cooling alternative will significantly reduce operational 20 impacts on streams and rivers compared to the current once-through cooling system. During 21 the summer months, when water use is at its highest, service and cooling tower makeup water 22 would be withdrawn at a rate of approximately 314,000 Ipm (83,000 gpm) for the combined 23 needs of IP2 and IP3. This would be a 95.2-percent reduction in water use compared to the 24 existing IP2 and IP3 once-through systems, which have a maximum flow rate of 6,553,000 Ipm 25 (1,731,000 gpm). Without modifications to the intake screening technologies, the NRC staff 26 assumes that the reduction in water intake results in an equivalent reduction in entrainment and 27 impingement. Entergy's feasibility and cost evaluation indicates that 4 of the existing 6 28 circulating water intake bays would be used at each unit, and the existing service water intake 29 bays would also remain in service (Enercon 2010). The staff concludes that this significant 30 reduction in water demand would likely result in a similarly significant reduction in entrainment-31 and impingement-related losses compared to the losses created by the current once-through 32 cooling system.

33 New circulating-water intake pumps would likely continue to utilize the Ristroph traveling 34 screens and fish-return system currently in operation (Entergy 2007). The greatest impact of 35 the closed-cycle system would be a reduction in entrainment and impingement of aquatic 36 species. As described in Section 4.1.3.3 of this SEIS, the NRC staff has concluded that the 37 once-through cooling system has a MODERATE impact from impingement and entrainment.

38 The reduction in flow may also reduce impingement or entrainment of the endangered 39 shortnose sturgeon (Acipenser brevirostrum) and macroinvertebrates, such as small clams and 40 mussels (bivalves), snails, worms, crustaceans, and aquatic insects. In Section 4.6.1, the NRC 41 staff had indicated that the impacts to the shortnose sturgeon are already SMALL, though 42 additional reductions in effects may occur as a result of reduced flow.

43 Under a closed-cycle cooling system, most discharged blowdown water is unheated. Because 44 the closed-cycle cooling system discharges a smaller volume of water, and because the water is NUREG-1437, Supplement 38 8-8 December 2010 OAGI0001367A_00341

Environmental Impacts of Alternatives to License Renewal 1 cooler than in a once-through system, the extent of thermal impacts - which could range from 2 SMALL to LARGE for the current once-through system, given uncertainty in the facility's thermal 3 impacts - would be reduced. Thus, the effects of thermal shock also decline. However, the 4 discharge water may be higher in salinity and may contain higher concentrations of biocides, 5 minerals, trace metals, or other chemicals or constituents. To maintain compliance with 6 discharge permits, the water may need to be treated.

7 Overall, operation of the closed-cycle cooling alternative would produce substantially fewer 8 impacts to the aquatic environment relative to those caused by the existing once-through 9 system. The NRC staff concludes that the aquatic ecological impacts (including those to 10 threatened and endangered species) from the construction and operation of the hybrid 11 mechanical-draft closed-cycle cooling alternative for IP2 and IP3 would be SMALL.

12 Terrestrial ecology. Construction of the closed-cycle cooling alternative would entail clear-13 cutting of onsite trees and excavation of areas for the two cooling towers as described in the 14 Land Use section. These activities would destroy fragments of onsite eastern hardwood forest 15 habitat (NYSDEC 2007; NYSDEC 2008a; Enercon 2010). Effects of removing these habitats 16 could include localized reductions in productivity or relocations of some species.

17 Operation of the cooling towers also could have adverse localized impacts on terrestrial 18 ecology. The cooling towers would be 50 m (165 ft) tall and may produce a visible plume as 19 well as minimal ground fog under certain conditions, though hybrid towers of a round 20 configuration minimize these conditions to the maximum extent possible (Enercon 2010). The 21 potential physical impacts from a cooling tower plume include icing and fogging of surrounding 22 vegetation during winter conditions. Icing can damage trees and other vegetation near the 23 cooling towers. The salt content of the entrained moisture (drift) also has the potential to 24 damage vegetation, depending on concentrations (Enercon 2010), though this is reduced by the 25 higher release height and minimized entrainment inherent in the round, hybrid design.

26 Entergy's feasibility and cost evaluation indicate deposition rates for both towers in the area of 27 highest exposure (between the two towers - an area that includes parking lots, Unit 1, and site 28 infrastructure) is 70 percent of the natural ambient salt deposition rate (Enercon 2010). The 29 hybrid cooling towers evaluated in this section have a drift rate of 0.001 percent (Enercon 2010).

30 This amounts to 26 Ipm (7 gpm (0.00001 x 70,000 gpm of water)) drift for both towers. The 31 amount and effects of drift would vary depending on a number of factors, including the 32 concentration of salt in the droplets, the size of the droplets, the number of droplets per unit of 33 surface area, the species of plant affected, and the frequency of local precipitation.

34 Actual measurements of drift deposition have been collected at only a few nuclear plants.

35 These measurements indicate that, beyond about 1.5 kilometer (km) (about 1 mile (mi)) from 36 nuclear plant cooling towers, salt deposition is generally near natural levels (NRC 1996). The 37 NRC staff reported in the GElS that the salt-drift rate estimated to cause acute injury to the 38 eastern/Canadian hemlock (a particularly sensitive species) is in excess of 940 kilograms (kg) 39 per square kilometer (km 2) (8.4 pounds per acre) per week (NRC 1996), well above the 40 anticipated deposition rates from the IP2 and IP3 cooling towers. Natural deposition is 160 kg 41 per km 2 , while the maximum deposition from both towers is 112 kg per km 2 (Enercon 2010).

42 The NRC staff does not expect bird collisions with cooling towers to be a significant issue. The 43 NRC staff found in the GElS that impacts from collisions would be SMALL at all plants with 44 existing cooling towers (NRC 1996).

December 2010 8-9 NUREG-1437, Supplement 38 I OAGI0001367A_00342

Environmental Impacts of Alternatives to License Renewal 1 Section 4.6.2 of this SEIS discusses the effects of license renewal on threatened or endangered 2 terrestrial species. The section identifies the endangered Indiana bat (Myotis soda/is), the 3 threatened bog turtle (C/emmys muhlenbergil), and the New England cottontail (Sylvi/agus 4 transitiona/is), a candidate species, as being potentially affected. However, because of both the 5 site-specific environment and the lack of evidence of the species existing at the facility, potential 6 impacts to these threatened or endangered species are considered SMALL. Nonetheless, 7 should NYSDEC decide that cooling towers must be installed at the site, then appropriate 8 consultation with Fish and Wildlife Service would need to take place regarding the potential for 9 impacts to these species. Entergy noted in its comments (included in Appendix A of this SEIS) 10 that constructing cooling towers may have an effect on the Indiana Bat or its habitat.

11 While the effects of this alternative-including onsite land clearing and introduction of cooling 12 tower drift-are greater than the effects of the continued operation of the once-through cooling 13 system and are likely to be noticeable, they are not so great that they will have a destabilizing 14 effect on terrestrial resources in the vicinity of IP2 and IP3. The NRC staff concludes that the 15 overall effect on terrestrial ecology would be SMALL to MODERATE.

16

• Water Use and Quality 17 During construction of the alternative closed-cycle cooling systems at IP2 and IP3, changes in 18 water usage would likely be negligible. Increases may be seen in potable water demand for 19 construction workers and, if concrete is mixed on site, there would be additional demands.

20 However, these water needs would be short lived and would be at least partially offset by a 21 reduction in water use while IP2 and IP3 are in outages to install the closed-cycle cooling 22 system. For the term of construction, the additional water demands would need to be met by 23 the Village of Buchanan, which supplies water to the site. The Village of Buchanan purchases 24 public drinking water from surface water supplies.

25 The NYSDEC requires a construction general permit for storm water discharges from a project 26 such as construction of the hybrid cooling towers. In addition, the NYSDEC will require a 27 stormwater pollution prevention plan describing the use of silt fencing and other erosion-control 28 management practices that will be used to minimize impacts on surface water quality. The 29 construction project could also affect ground water as a result of dewatering excavations.

30 Circulating water makeup (30,000 to 61,000 Ipm (7800 to 16,000 gpm) for the cooling towers 31 (Enercon 2010) will have a negligible impact on water flow past the site. The estimated flow 32 150 m (500 ft) off the shoreline is about 34 million Ipm (9 million gpm) in a 150-to-180-m (500-33 to-600-ft)-wide section (Entergy 2007). Therefore, the evaporation loss would be approximately 34 0.1 percent of the river flow. Further, the estuarine Hudson River is at sea level, and thus the 35 river's water level would not be affected by the cooling towers' consumptive water use.

36 To compensate for evaporative and discharge losses, makeup water from the Hudson River 37 would be treated to remove silt, suspended solids, biological material, and debris. Makeup 38 water may also need lime softening, a water treatment process that produces a waste sludge 39 that requires disposal. Biocides, such as hypochlorite, are often added to cooling water to 40 diminish the affects of the biofouling organisms (Entergy 2007). Other chemicals, such as 41 acids, dispersants, scale inhibitors, foam suppressants, and dechlorinators may also be needed 42 for water treatment (NRC 1979).

43 To manage the chemicals and elevated concentrations of dissolved solids in the discharge NUREG-1437, Supplement 38 8-10 December 2010 OAGI0001367A_00343

Environmental Impacts of Alternatives to License Renewal 1 water, treatment would likely be necessary in accordance with the IP2 and IP3 site SPDES 2 permit. The use of biocides or any other chemicals would likely require discharge treatment and 3 additional monitoring.

4 The IP2 and IP3 site does not utilize ground water for cooling operations, service water, or 5 potable water. As such, the continued operation of the site is not expected to affect local 6 ground water supplies (EPA 2008a). Localized dewatering of ground water from excavations 7 will likely be necessary during construction operations, but because this ground water is not 8 used by Entergy or entities off site, and because the ground water discharges to the Hudson 9 River after exiting the IP2 and IP3 site, construction is not likely to affect either ground water 10 quality or ground water use. Any radiologically contaminated groundwater that construction 11 crews encounter on site would need to be treated to meet release criteria before being 12 discharged. As a result of onsite contamination, crews will need to monitor for radionuclides in 13 liquid discharges and in excavations.

14 Proper controls of runoff and treatment of other site discharges, as well as appropriate 15 treatment of any contaminated groundwater, will not result in significant impacts on the surface 16 water (Hudson River) and evaporation losses are very small. Also, ground water impacts from 17 construction and operation of the cooling towers are expected to be minor. Therefore, the NRC 18 staff concludes that overall impacts to water resources and water quality from the closed-cycle 19 cooling alternative would be SMALL.

20

• Air Quality 21 The IP2 and IP3 site is located within the New Jersey-New York-Connecticut Interstate Air 22 Quality Control Region (40 CFR 81.13, "New Jersey-New York-Connecticut Interstate Air 23 Quality Control Region"). The air quality nonattainment issues associated with the portions of 24 these States located within a 50-mi radius are related to ozone (8-hour standard) and particulate 25 matter less than 2.5 microns (IJm) in diameter (PM 2 .5 ). The entire States of New Jersey and 26 Connecticut are designated nonattainment areas for ozone (8-hour standard). Several counties 27 in Central and Southeastern New York within a 50-mi radius are also in nonattainment status for 28 the 8-hour ozone standard (EPA 2008b). Air quality would be affected by three different factors:

29 replacement power during construction-related outages, construction activities and vehicles 30 (including worker transportation), and cooling tower operations.

31 Entergy contractors indicate that prolonged outages of IP2 and IP3, such as would be required 32 to install cooling towers (TRC Environmental Corp [TRC] 2002) would require replacement 33 power from existing generating facilities within the New York City metropolitan area. They 34 assert that replacement of IP2 and IP3 energy output during cooling tower installation would 35 result in substantial increases in regulated air pollutants. To the extent that coal- and natural-36 gas-fired facilities replace IP2 and IP3 output, the NRC staff finds that some air quality effects 37 would occur. The NRC staff finds that these effects would largely cease when IP2 and IP3 38 return to service, with the exception of any output lost to lower efficiency and new parasitic 39 loads from the closed-cycle cooling system (an average of approximately 88 MW, with peak 40 losses of 157.6 MW). Additional air quality impacts could result from power that replaces these 41 parasitic and efficiency losses.

42 Air quality at or near IP2 and IP3 during the construction of the IP2 and IP3 cooling towers 43 would be affected mostly by exhaust emissions from internal combustion engines. These 44 emissions would include carbon monoxide (CO), nitrogen oxides (NOx), volatile organic December 2010 8-11 NUREG-1437, Supplement 38 OAGI0001367A_00344

Environmental Impacts of Alternatives to License Renewal 1 compounds (VOCs), sulfur oxides (SOx), carbon dioxide (C0 2), and particulate matter 10 IJm or 2 less in diameter (PM 1O) from operation of gasoline- and diesel-powered heavy-duty construction 3 equipment, delivery vehicles, and workers' personal vehicles (these vehicles would also 4 produce or contribute to production of PM 2 .5 ). The amount of pollutants emitted from 5 construction vehicles and equipment and construction worker traffic would likely be small 6 compared with total vehicular emissions in the region.

7 As noted in Section 3.3 of the GElS, a conformity analysis is required for each pollutant when 8 the total direct and indirect emissions caused by a proposed Federal action would exceed 9 established threshold emission levels in a nonattainment area. In the GElS, the NRC 10 determined that a major refurbishment activity may increase the facility workforce by up to 2300 11 construction, refurbishment, and refueling personnel during a significant refurbishment outage 12 period. The construction of two new cooling towers at IP2 and IP3 could approximate such 13 conditions; however, Entergy estimates that the construction activities would require an average 14 workforce of 300 additional workers with a maximum of about 600 workers (Enercon 2003).

15 Because IP2 and IP3 are in a nonattainment area for ozone, and emissions from vehicles of the 16 additional workforce may exceed the ozone air quality thresholds, a conformity analysis would 17 be required before construction.

18 Fugitive dust, a contributor to PM 1O , would be generated from site clearing and construction 19 traffic, blasting, and excavation. Given the size of the disturbed area that would be involved 20 (about 16 ha (40 ac)), and assuming that dust management practices would be applied (e.g.,

21 watering, silt fences, covering soil piles, revegetation), the fugitive dust impacts generated 22 during construction should be minor. Furthermore, the amount of road dust generated by the 23 vehicles traveling to and from the site transporting workers or hauling rock and dirt would 24 contribute to PM 10 concentrations. Construction stage impacts, though significant, would be 25 relatively short lived.

26 Operation stage impacts could be more significant. As previously discussed, the cooling towers 27 would emit tower drift consisting of water, salt, and suspended solids. These emissions would 28 be considered PM 1O , and some portion may include PM 2 .5 . Because IP2 and IP3 are located in 29 a nonattainment area for PM 2 .5 , a conformity analysis for the cooling towers would be necessary 30 and may result in additional restrictions on emissions, additional compensatory measures, or 31 further control of drift from the towers. Entergy's feasibility and cost study indicates that 32 particulate emissions would be so great that it may not be possible to obtain construction and air 33 permits (Enercon 2010).

34 Should operational air quality impacts cause air quality to worsen and thus further exceed limits, 35 the effect would be MODERATE or greater, though some level of emissions trading would limit 36 this impact. During construction, air quality effects would be controlled by site practices and 37 compensatory measures required to maintain compliance with the Clean Air Act (CAA) (should 38 a conformity analysis show the need to take other action). Also, replacement power would be 39 required to comply with CAA requirements (and it would be short lived). Overall, the air quality 40 effects would be driven by operational impacts, and could be SMALL to LARGE, depending on 41 the towers' compliance with CAA requirements and the availability of PM2.5 allowances.

42

• Waste 43 Construction of the closed-cycle cooling alternative at IP2 and IP3 would generate some 44 construction debris and an estimated 2 million cy (1.5 million m3 ) of rock and soil (Entergy NUREG-1437, Supplement 38 8-12 December 2010 OAGI0001367A_00345

Environmental Impacts of Alternatives to License Renewal 1 2007). This material may be affected by onsite radiological contamination or by other previous 2 site activities. Depending on the characteristics of the material, it may be possible to reuse or 3 recycle much of it, as discussed in the Land Use portion of this section. If the material cannot 4 be reused or recycled, it will have to be properly managed as a waste. Whether reused, 5 recycled, or disposed of, the material will have to be transported off site. Given the likely size of 6 blasting spoil particles, an onsite crushing operation may be necessary (Enercon 2010).

7 If disposed of, rather than reused or recycled, the waste may require additional offsite land use.

8 Entergy's feasibility and cost evaluation indicates that at least 6350 cy (4850 m3 ; approximately 9 0.3 percent) is likely to be contaminated, and that contaminated spoils would need to be 10 disposed of as Class A Waste (Enercon 2010). The only current outlet for Class A Waste is in 11 Clive, Utah. Contaminated wastes would need to be appropriately packaged and transported.

12 However, Entergy's feasibility and cost evaluation also indicates that all material, even if it 13 contains low levels of contamination, could possibly be disposed of in the ocean.

14 Some solid wastes may be generated by water treatment processes. Any such waste would be 15 treated and/or disposed of in accordance with State solid waste regulations. During operation, 16 Entergy will have to maintain release of solids and chemicals to the blowdown water and, 17 subsequently, to the discharge canal and the Hudson River in accordance with IP2 and IP3 18 SPDES permits. Other solid wastes from tower operation and maintenance (including sludge 19 from the tower basins) would be managed and disposed of in accordance with applicable State 20 regulations at approved offsite facilities. As noted in the Water Quality portion of this section, 21 any contaminated ground water produced by dewatering operations will need to be properly 22 treated before discharge.

23 Though a large volume of rock and soil would require offsite transportation, at least one disposal 24 option - ocean dumping - would require no additional land .. The NRC staff concludes that 25 waste-related impacts associated with the closed-cycle cooling alternative at IP2 and IP3 could 26 range from SMALL to LARGE, depending on where Entergy disposes of the material, whether 27 the material can be reused or recycled, and the extent to which contaminated spoils require 28 special disposal.

29

• Human Health 30 Human health impacts for an operating nuclear power plant are identified in 10 CFR Part 51, 31 Subpart A, Appendix B, Table B-1. Potential impacts on human health from the operation of 32 closed-cycle cooling towers at nuclear power plants are evaluated in Section 4.3.6 of the GElS.

33 During construction activities there would be risk to workers from typical industrial incidents and 34 accidents. Accidental injuries are not uncommon in the construction industry and accidents 35 resulting in fatalities do occur. However, the occurrence of such events is mitigated by the use 36 of proper industrial hygiene practices, complying with worker safety requirements, and training.

37 Occupational and public health impacts during construction are expected to be controlled by 38 continued application of accepted industrial hygiene protocols, occupational health and safety 39 controls, and radiation protection practices.

40 Depending on the level of contaminated spoils and groundwater removed during the 41 construction process, it is possible that additional occupational exposures to radiation may 42 occur. Crews would need to comply with existing radiation exposure standards. Given the low 43 level of contamination in soil and groundwater, as well as the limited extent of the December 2010 8-13 NUREG-1437, Supplement 38 OAGI0001367A_00346

Environmental Impacts of Alternatives to License Renewal 1 contamination, this is likely not to be a significant issue at the construction site.

2 Hybrid cooling towers at IP2 and IP3 would be equipped with sound attenuators (Enercon 3 2010). The topography of the area would provide additional attenuation of the noise levels. An 4 analysis of potential offsite noise levels resulting from both cooling towers operating 5 continuously indicated that the increase in noise levels at sensitive receptor sites would be 6 1 decibel or less, a level most likely not noticeable by the residents of the Village of Buchanan 7 (Enercon 2010). These sound levels would comply with Village of Buchanan requirements.

8 The GElS evaluation of health effects from plants with cooling towers focuses on the threat to 9 workers from microbiological organisms whose presence might be enhanced by the thermal 10 conditions found in cooling towers. The microbiological organisms of concern are freshwater 11 organisms that are present at nuclear plants that use cooling ponds, lakes, or canals and that 12 discharge to small rivers (NRC 1996). Because the closed-cycle system at IP2 and IP3 would 13 operate using brackish water, and because the Hudson River at Indian Point does not meet the 14 NRC's definition of a small river, thermal enhancement of microbiological organisms is not 15 expected to be a concern.

16 Furthermore, as described in Section 4.3 of this SEIS, the NRC concludes that continued 17 operation of the facility would not increase the impacts of occupational radiation exposures 18 during the relicensing period. Overall, the NRC staff concludes that human health impacts from 19 the closed-cycle cooling alternative would also be SMALL.

20

• Socioeconomics 21 Socioeconomic impacts are defined in terms of changes to the demographic and economic 22 characteristics and social conditions of a region. For example, the number of jobs created by 23 the construction and operation of a closed-cycle cooling could affect regional employment, 24 income, and expenditures. Two types of job creation result from this alternative: (1) 25 construction-related jobs, and (2) operation-related jobs, which have the greater potential for 26 permanent, long-term socioeconomic impacts.

27 Entergy estimates that construction of the cooling towers would require an average workforce of 28 300 mostly temporary employees or contractors and could take an estimated 62 months.

29 During the outage phase of the effort, the temporary workforce could peak at 600 (Entergy 30 2007). For comparison purposes, a workforce of approximately 950 additional workers is on 31 site during a routine refueling outage (Entergy 2007).

32 As previously described, the impacts of relicensing and refurbishing IP2 and IP3 are addressed 33 in a site-specific case study presented in Appendix C (Section CA.4) to the GElS. The case 34 study postulated that major refurbishment activities could result in as many as 2300 workers on 35 site. In the case study, the workers were engaged in a variety of component replacement and 36 inspection activities. The case study employment estimate is significantly larger than Entergy's 37 estimate in the previous paragraph and is considered by the NRC staff to be the maximum 38 potential size of the temporary workforce because the GElS estimate includes a variety of 39 activities that will not be occurring at Indian Point during an outage to install a closed-cycle 40 cooling system. As of June 2006 the site had approximately 1255 full-time workers (Entergy 41 employees and baseline contractors) during normal plant operations (Entergy 2007).

42 The GElS case study concluded that, because the surrounding counties are high population 43 density areas as described in Section 4.4.1 of this SEIS, there will be available housing to NUREG-1437, Supplement 38 8-14 December 2010 OAGI0001367A_00347

Environmental Impacts of Alternatives to License Renewal 1 support the influx of workers. Therefore, the GElS concluded that any construction-related 2 impact on housing availability would likely be small. With even fewer workers on site than 3 anticipated in the GElS, impacts would be even less noticeable.

4 As reported by Levitan and Associates, Inc. (2005), payments-in-lieu-of-taxes (PILOT) are made 5 by Entergy to surrounding taxing jurisdictions. The PI LOT amounts would not likely be affected 6 by the construction of new closed-cycle cooling systems or other capital expenditures. In 7 accordance with the PI LOT agreements, this payment schedule will remain fixed through the 8 term of the current site licenses (Levitan and Associates, Inc. 2005). Because plant valuation is 9 not likely to change drastically with the installation of closed-cycle cooling (though it may 10 increase), PILOT payments are likely to stay at similar relative levels throughout the renewal 11 term.

12 Electricity costs and grid reliability are outside of the scope of NRC's review, though many 13 commenters have expressed concern about these two issues. The NRC staff notes that the 14 New York Independent System Operator (NYISO) would continue to monitor grid function and 15 reliability, and prices would be established on New York State's restructured electricity market.

16 Approximately 42 weeks of outage would be necessary to complete construction and implement 17 closed-cycle cooling (Enercon 2010).

18 The NRC staff concludes that most socioeconomic impacts related to construction and 19 operation of cooling towers at the site would be SMALL.

20

• Transportation 21 Adverse transportation impacts would be likely during construction of cooling towers. The 22 greatest impacts would occur during site excavation and would decline later in construction.

23 These impacts would return to current levels following construction.

24 Offsite disposal of approximately 2 million cy (1.5 million m3 ) of rock and soil from the 25 excavation of the two cooling tower sites would be expected to have a significant impact on 26 local transportation infrastructure. As indicated by Entergy's feasibility and cost evaluation, the 27 blasting and excavation phase of construction would take approximately four years to complete 28 (Enercon 2010). Given 20 cy dump trucks, approximately 100,000 round trips would be needed 29 to remove the excavated materials. During peak excavation periods, 364 to 518 truck loads 30 would leave the site each day. Much of this material could leave the site on barges in the 31 Hudson River (Enercon 2010). Entergy's feasibility and cost evaluation indicates that barge 32 transportation is the most likely option for reused and recycled blasting spoils (Enercon 2010).

33 Earlier estimates by Entergy indicated that each barge may hold 1000 tons of spoils.

34 Road traffic in the area is heavy and the additional traffic from construction and site workers 35 would cause increased traffic delays, particularly along US Highway 9 and State Highway 9A 36 (Entergy 2007). Barged material may be transferred to trucks at transshipment points along the 37 Hudson, though this is likely to have markedly lower impacts on transportation than if all spoils 38 were trucked offsite along surface roads near Indian Point. In some cases, though, impacts 39 could still be significant. If barged material were transported out to sea and disposed of there, 40 then NRC staff expects that impacts on transportation would be minor.

41 42 During operations, NRC staff anticipates that the closed-cycle cooling system would have little 43 to no effect on transportation, and would likely be limited to occasional shipments of waste December 2010 8-15 NUREG-1437, Supplement 38 OAGI0001367A_00348

Environmental Impacts of Alternatives to License Renewal 1 cleaned out from cooling tower basins, occasional deliveries of chemicals used to prevent 2 fouling of the towers, and any replacement components necessary throughout the life of the 3 towers. As noted previously, fogging and icing is not expected to be significant.

4 Based on independent calculations of expected waste volumes from site excavations that were 5 on the same order of magnitude as the Entergy estimates, the NRC staff concludes that impacts 6 from transportation activities, primarily during excavation of the construction site, could be 7 significant and destabilizing, though temporary, during construction and will not be noticeable 8 during operations. Impacts, then, will be SMALL during operations, but SMALL to LARGE 9 during construction.

10

• Aesthetics 11 IP2 and IP3 are already visible from the Hudson River, scenic overlooks on area highways, and 12 the Palisades Interstate State Park. The property is adjacent to the Scenic Area of Statewide 13 Significance. The addition of the two cooling towers, standing 50 m (165 ft) in height, would 14 make the entire facility more visible as the developed footprint of the facility would be expanded 15 (Entergy's feasibility and cost evaluation includes site renderings to illustrate visual impacts; 16 Enercon 2010. The towers are more aesthetically similar to austere, international-style 17 performance or convention centers than to the hyperbolic natural draft towers many associate 18 with nuclear power plant sites). The clear-cutting of wooded areas for construction of the towers 19 would remove a visual buffer for some site structures. The towers themselves would be clearly 20 visible from offsite vantage points. Entergy has indicated that it would preserve as many trees 21 as possible and that it would plant new trees to reestablish some visual buffers and help 22 attenuate noise (Entergy 2007). Remaining and new trees could act as a partial visual buffer 23 between the construction sites and the river and a visual and noise buffer on land (Entergy 24 2007).

25 While the hybrid mechanical-draft cooling towers under consideration are designed to reduce 26 fog and ice production in the local area and minimize presence at ground level, fog and ice 27 produced during operation could still occur. In particular, a visible plume, though attenuated by 28 the hybrid design, may occur under certain meteorological conditions during the year (Enercon 29 2010). In most cases, these plumes would occur immediately over the towers and Indian Point 30 property, though under worst case conditions, plumes may extend several hundred to 31 thousands of meters (Enercon 2010). Given tower design, it is likely to remain aloft and not 32 occur at ground level thereby reducing the likelihood and severity of fog and ice. Less 33 noticeable moisture and salt deposition from the plume may increase dampness and corrosion 34 on surrounding property, which could affect the visual environment. The circular hybrid design 35 proposed by Entergy disperses remaining drift over a greater area at a lower intensity than a 36 single-stage wet mechanical-draft cooling tower (Enercon 2003).

37 Given proximity to a Scenic Area of Statewide Significance, Entergy's feasibility and cost 38 evaluation indicates that cooling towers may be incompatible with NYSDEC Visual Policy. From 39 NRC's perspective, this is an issue for Entergy and the State to reconcile, should NYSDEC 40 require cooling towers.

41 The NRC staff concludes that the impact of construction and operation of a closed-cycle cooling 42 system at IP2 and IP3 on aesthetics would likely be MODERATE to LARGE, given the proximity 43 to important visual resources. Impacts will be greater when atmospheric conditions result in 44 large, visible plumes, and the towers will always be clearly visible.

NUREG-1437, Supplement 38 8-16 December 2010 OAGI0001367A_00349

Environmental Impacts of Alternatives to License Renewal 1

• Historic and Archeological Resources 2 Should NYSDEC decide that Indian Point must install cooling towers, extensive consultation 3 and further study of onsite historical resources will be necessary. As noted in Section 4.4.5.1 of 4 this SEIS, Entergy's Phase 1b study identified historic and prehistoric resources in the area 5 identified for the south tower (ENN 2009). Based on Entergy's consultation with the New York 6 State Historic Preservation Office, significant additional site study and consultation with other 7 interested groups, particularly Tribal representatives, will be necessary should NYSDEC require 8 cooling tower installation (ENN 2009, NYSHPO 2009). Prior to Entergy's Phase 1b study, a 9 Phase 1A survey was conducted on the property in 2006. The NRC staff identified 76 10 resources listed on the National Register of Historic Places (NRHP) within 5 miles of IP2 and 11 IP3.

12 There are registered historically significant buildings and sites within several kilometers of IP2 13 and IP3 and other nonregistered sites or buildings that may be eligible for registration (NRC 14 1996). However, the NRC case study presented in the GElS indicated that some unregistered 15 sites may go unprotected because the sites' significance may be discounted because of their 16 proximity to the IP2 and IP3 facility.

17 Further studies and consultation with the State Historic Preservation Office and appropriate 18 Native American Tribes, would occur under Section 106 of the National Historic Preservation 19 Act (NHPA) should NYSDEC require that cooling towers be constructed onsite. Any historic or 20 archeological resources are present in previously disturbed areas or in undisturbed areas, they 21 would have to be evaluated for eligibility for listing on the NRHP.

22 Entergy has procedures for addressing historic and archeological resources (as noted in 23 Section 4.4.5.2), and it has acknowledged the need to survey for unknown resources before 24 construction. As noted in this section, further evaluation and consultation would be necessary 25 prior to cooling tower installation. Historic and archeological resources could be adversely 26 impacted given the potential for historic and prehistoric resources to be discovered on the 27 cooling tower sites. Entergy's early coordination, consultation, and planning could help to 28 reduce or minimize most impacts .. Nonetheless, the NRC staff concludes that the impact from 29 the closed-cycle cooling alternative would likely range from SMALL to MODERATE if historic 30 and archeological resources cannot be avoided.

31 December 2010 8-17 NUREG-1437, Supplement 38 I OAGI0001367A_00350

Environmental Impacts of Alternatives to License Renewal 1

• Environmental Justice 2 The NRC staff addresses environmental justice impacts of continued operations in Section 4.4.6 3 of this SEIS. Construction and operation of cooling towers at IP2 and IP3 could have an impact 4 on minority and low-income populations.

5 The environmental justice impact analysis evaluates the potential for disproportionately high and 6 adverse human health and environmental effects on minority and low-income populations that 7 could result from the construction and operation of a closed-cycle cooling system at Indian 8 Point. Adverse health effects are measured in terms of the risk and rate of fatal or nonfatal 9 adverse impacts on human health. Disproportionately high and adverse human health effects 10 occur when the risk or rate of exposure to an environmental hazard for a minority or low-income 11 population is significant and exceeds the risk or exposure rate for the general population or for 12 another appropriate comparison group. Disproportionately high environmental effects refer to 13 impacts or risk of impact on the natural or physical environment in a minority or low-income 14 community that are significant and appreciably exceeds the environmental impact on the larger 15 community. Such effects may include biological, cultural, economic, or social impacts. Some of 16 these potential effects have been identified in resource areas previously discussed in this 17 section. For example, increased demand for rental housing during construction could 18 disproportionately affect low-income populations. Minority and low-income populations are 19 subsets of the general public residing around IP2 and IP3, and all are exposed to the same 20 hazards generated from constructing and operating a closed-cycle cooling system.

21 Potential impacts to minority and low-income populations from the construction and operation of 22 a closed-cycle cooling system at Indian Point would mostly consist of environmental and 23 socioeconomic effects (e.g., noise, dust, traffic, employment, and housing impacts). Noise and 24 dust impacts from construction would be short-term and primarily limited to onsite activities.

25 However, minority and low-income populations residing along site access roads could be 26 affected by increased commuter vehicle traffic during shift changes. Increased demand for 27 rental housing during construction of the closed-cycle cooling system could affect low-income 28 populations in the vicinity of IP2 and IP3. However, these effects would be temporary during 29 certain hours of the day and not likely to be high and adverse. Since IP2 and IP3 are located in 30 a high population area and the number of available housing units exceeds demand, any 31 increase in employment would have little or no noticeable effect on the availability of housing in 32 the region. Given the close proximity to the New York metropolitan area, most construction 33 workers would commute to the site thereby reducing the potential demand for rental housing.

34 As noted earlier in this section, replacement power required during a 42-week outage could 35 increase air quality effects in minority and low-income communities, depending on the location 36 and characteristics of generator units used to replace IP2 and IP3 output. These effects are 37 likely to be short-lived (most will be no longer than the outage period), and may vary with time of 38 year, scheduled outages at other facilities, and generator pricing on the New York Independent 39 System Operator (NYISO) grid. Additionally, impacts would occur near existing facilities and 40 would result from incremental increases rather than new effects. As a result, impacts are likely 41 to be small. Nonetheless, some additional power generation may have to come from other 42 sources to make up for parasitic and efficiency losses. These could contribute to additional air 43 quality and human health impacts. However, it is assumed that emissions from these generator 44 facilities would meet air quality standards.

I NUREG-1437, Supplement 38 8-18 December 2010 OAGI0001367A_00351

Environmental Impacts of Alternatives to License Renewal 1 Based on this information and the analysis of human health and environmental impacts 2 presented in this section, the construction and operation of the closed-cycle cooling system 3 would not have disproportionately high and adverse human health and environmental effects on 4 minority and low-income populations residing in the vicinity of IP2 and IP3.

5 6 Table 8-1. Summary of Environmental Impacts of a Closed-Cycle Cooling Alternative 7 at IP2 and IP3 Closed-Cycle Impact Cooling Alternative Category Impact Comments Land Use SMALL to Construction of towers requires about 16 ha (40 ac). Waste LARGE disposal may require much offsite land.

Ecology: SMALL Entrainment and impingement of aquatic organisms, as well Aquatic as heat shock, would be reduced.

Ecology: SMALL to Onsite forest habitats disturbed with possible effects to Terrestrial MODERATE endangered species.

Water Use and SMALL Releases to surface water would be treated as necessary to Quality meet permit requirements. Runoff from construction activities is likely to be controlled.

Air Quality SMALL to Primary impacts from operational emissions, as well as LARGE replacement power. Existing regulations may limit effects.

Waste SMALL to Construction would generate soil, rock, and debris requiring LARGE disposal; impacts vary greatly with disposal options.

Human Health SMALL Workers experience minor accident risk and may encounter contaminated blasting spoils during construction, though monitoring will limit potential for impacts.

Socioeconomics SMALL No impact to offsite housing or public services occurs.

Transportation SMALL to Increased traffic associated with construction (workers and LARGE waste disposal) may be significant, though little effect during operations.

Aesthetics MODERATE Construction of two towers, 165 ft tall, would have a to LARGE noticeable impact on the aesthetics of the site. Plume may be highly visible on some days.

Historical and SMALL to Recent study indicates potential for resources, though Archeological MODERATE existing procedures should help protect resources on the Resources largely-disturbed site.

Environmental SMALL Impacts are not anticipated to be disproportionately high and Justice adverse for minority and low-income communities.

8 9

December 2010 8-19 NUREG-1437, Supplement 38 I OAGI0001367A_00352

Environmental Impacts of Alternatives to License Renewal 1

3 8.2 No-Action Alternative 4 The NRC regulations implementing the National Environmental Policy Act of 1969, as amended 5 (NEPA) (see 10 CFR Part 51, Subpart A, Appendix A, paragraph 4), specify that the no-action 6 alternative will be discussed in an NRC environmental impact statement.

7 For license renewal, the no-action alternative refers to a scenario in which the NRC would not 8 renew the IP2 and IP3 operating licenses and Entergy would then cease operating both units on 9 or before the expiration of their current operating licenses. Following the shutdown of each unit, 10 Entergy would initiate decommissioning of the facility in accordance with the NRC 11 decommissioning requirements in 10 CFR 50.82, "Termination of License." Full dismantling of 12 structures and decontamination of the site may not occur for up to 60 years after plant 13 shutdown.

14 Regardless of whether or not the IP2 and IP3 operating licenses are renewed, the facility's 15 owner will eventually be required to shut down the reactors and decommission the IP2 and IP3 16 facility. If the operating licenses are renewed, shutdown and decommissioning activities would 17 not be avoided but would be postponed for up to an additional 20 years.

18 The environmental impacts associated with decommissioning, following a license renewal 19 period of up to 20 years or following the no-action alternative, would be bounded by the 20 discussion of impacts in Chapter 7 of the GElS, Chapter 7 of this SEIS, and NUREG-0586, 21 "Final Environmental Impact Statement on Decommissioning of Nuclear Facilities" (NRC 2002).

22 The impacts of decommissioning after 60 years of operation are not expected to be significantly 23 different from those occurring after 40 years of operation.

24 I NUREG-1437, Supplement 38 8-20 December 2010 OAGI0001367A_00353

Environmental Impacts of Alternatives to License Renewal 1 Table 8-2. Summary of Environmental Impacts of the No-Action Alternative Impact Category Impact Comment Land Use SMALL Impacts are expected to be SMALL because plant shutdown is expected to result in few changes to offsite and onsite land use, and transition to alternate uses is expected over an extended timeframe.

Ecology SMALL Negative impacts to aquatic ecology of the Hudson River will cease. The overall impact is SMALL.

Water Use and SMALL Impacts are expected to be SMALL as no new impacts occur Quality with plant shutdown.

Air Quality SMALL Impacts are expected to be SMALL because emissions related to plant operation and worker transportation will decrease.

Waste SMALL Impacts are expected to be SMALL because generation of high-level waste will stop and generation of low-level and mixed waste will decrease.

Human Health SMALL Impacts are expected to be SMALL because radiological doses to workers and members of the public, which are within regulatory limits, will be reduced.

Socioeconomics SMALL to Impacts vary by jurisdiction, with some areas experiencing MODERATE MODERATE effects.

Socioeconomics SMALL Impacts are expected to be SMALL because the decrease in (Transportation) employment would reduce traffic.

Aesthetics SMALL Impacts are expected to be SMALL because plant structures will remain after plant shutdown.

Historic and SMALL Impacts are expected to be SMALL because shutdown of the Archeological plant will not immediately change land use.

Resources Environmental Justice SMALL Impacts are not anticipated to be disproportionately high and adverse for minority and low-income populations.

2 3

December 2010 8-21 NUREG-1437, Supplement 38 I OAGI0001367A_00354

Environmental Impacts of Alternatives to License Renewal 1 Impacts from the decision to permanently cease operations are not considered in NUREG-0586, 2 or its Supplement 1. (2) Therefore, immediate impacts that occur between plant shutdown and 3 the beginning of decommissioning are considered here. These impacts will occur when the 4 units shut down regardless of whether the license is renewed (see Table 8-2).

5 Plant shutdown will result in a net loss of power generating capacity. The power not generated 6 by IP2 and IP3 during the license renewal term would likely be replaced by (1) power supplied 7 by other producers (either existing or new units) using generating technologies that may differ 8 from that employed at IP2 and IP3, (2) demand-side management and energy conservation, or 9 (3) some combination of these options. The environmental impacts of these options are 10 discussed in Section 8.3 of this SEIS. While these options can be alternatives to license 11 renewal (given sufficient resource availability), they also constitute potential consequences of 12 the no-action alternative. Impacts from these options will addressed in their respective portions 13 of this Section.

14 This SEIS does not assess the specifics of the need for corrections to reactive power that would 15 be required if IP2 and IP3 were shut down. Reactive power (i.e., power stored in magnetic 16 fields throughout the power grid) is essential for the smooth operation of the transmission grid 17 because it helps hold the voltage to desired levels. It may be possible to use the existing 18 generators at IP2 and IP3 as a source of reactive power even if IP2 and IP3 are shut down. As 19 "synchronous condensers," the generators could add reactive power (but not real power) to the 20 transmission system (National Research Council 2006). Because it is assumed that the 21 generators would be operated as synchronous condensers only until the reactive power could 22 be supported by new, real replacement power generation, their operation is not considered as a 23 significant contributor to the impacts described below. Further, as a shut-down nuclear power 24 plant may not be decommissioned for many years after shutdown, the continued operation of 25 IP2 and IP3 generators would not necessarily slow or impede decommissioning activities.

26

• Land Use 27 In Chapter 4 of this SEIS, the NRC staff concluded that the impacts of continued plant operation 28 on land use would be SMALL. Onsite land use will not be affected immediately by plant 29 shutdowns. Plant structures and other facilities are likely to remain in place until 30 decommissioning. In the near term, the transmission lines associated with IP2 and IP3 will 31 likely remain in place. In the long term, it is possible that the transmission lines that extend from 32 the onsite switchyard to major transmission corridors will be removed. As a result, the 33 transmission line ROWs will no longer be maintained and the ROW will be available for other 34 uses. Also, as a result of plant shutdowns, there would be a reduction in uranium mining activity 35 on approximately 870 ha (2150 ac), or 405 ha (1000 ac) per 1000 MW(e) (NRC 1996).

36 Therefore, the staff concludes that the impacts on land use from plant shutdown would be 37 SMALL.

38 (2)

Appendix J, "Socioeconomic and Environmental Justice Impacts Related to the Decision to Permanently Cease Operations," to NUREG-0586, Supplement 1, discusses the socioeconomic impacts of plant closure, but the results of the analysis in Appendix J are not incorporated in the analysis presented in the main body of the NUREG.

NUREG-1437, Supplement 38 8-22 December 2010 OAGI0001367A_00355

Environmental Impacts of Alternatives to License Renewal 1

• Ecology 2 In Chapter 4 of this SEIS, the NRC staff concluded that entrainment and impingement of aquatic 3 species would have MODERATE impacts. The NRC staff also concluded that thermal shock 4 could have a SMALL to LARGE impact. Terrestrial ecological impacts were SMALL. Cessation 5 of operations will eliminate cooling water intakes from and discharges to the Hudson River. The 6 environmental impacts to aquatic species, including threatened and endangered species, 7 associated with these changes are generally positive because entrainment and impingement 8 issues will be eliminated, as would impacts from the plant's thermal plume. The NRC staff 9 expects that impacts to aquatic ecology would decline to SMALL if the plant shuts down.

10 The impacts of plant closure on the terrestrial ecosystem could be both negative and positive, 11 depending on final disposition of the IP2 and IP3 site. Currently, there is a fragment of eastern 12 deciduous hardwood habitat in the exclusion area of the facility that Entergy indicates has not 13 been previously developed. This fragment could be destroyed by new development once 14 access is no longer restricted. Plant closure will not directly affect this fragment, however, and a 15 prolonged period prior to site decontamination may also provide protection for this fragment.

16 Overall, the NRC staff concludes that ecological impacts from shutdown of the plant would be 17 SMALL.

18

• Water Use and Quality 19 When the plant stops operating and cooling water is no longer needed, there will be an 20 immediate reduction in water withdrawals from and discharge to the Hudson River. This will 21 reduce evaporation from the river in the vicinity of the plant and will result in decreased 22 discharges of biocides and other chemicals. Therefore, the staff concludes that the impacts on 23 surface water use and quality from plant shutdown would be less noticeable than current 24 operations and would remain SMALL.

25 Ground water at the IP2 and IP3 site contains elevated concentrations of tritium (EPA 2004). In 26 Sections 2.2.7 and 4.5 of this SEIS, the NRC staff examined available information on leakage to 27 ground water and determined that the issue, while new, is not significant. The source of the 28 contamination is believed to be historical leakage from the IP1 and IP2 spent fuel pools. Since 29 discovering the leaks, Entergy has removed fuel from the IP1 spent fuel pool and drained it.

30 The no-action alternative would not, on its own, affect ground water contamination.

31 Consequently, the NRC staff concludes that ground water quality impacts from shutdown of the 32 plant would be SMALL.

33

• Air Quality 34 In Chapter 4 of this SEIS, the NRC staff adopted the findings in the GElS that the impacts of 35 continued plant operation on air quality would be SMALL. When the plant stops operating, there 36 will be a reduction in emissions from activities related to plant operation (e.g., use of diesel 37 generators and vehicles to transport workers to the site). As such, the NRC staff concludes that 38 the impact on air quality from shutdown of the plant would be SMALL.

39 December 2010 8-23 NUREG-1437, Supplement 38 I OAGI0001367A_00356

Environmental Impacts of Alternatives to License Renewal 1

• Waste 2 The impacts of waste generated by continued plant operation are discussed in Chapter 6 of this 3 SEIS. The impacts of low-level and mixed waste from plant operation are characterized as 4 SMALL. When IP2 and IP3 stop operating, the plant will stop generating high-level waste and 5 generation of low-level and mixed waste associated with plant operation will briefly increase, 6 and then will decline. Therefore, the staff concludes that the impacts of waste generated after 7 shutdown of the plant would be SMALL.

8 Wastes associated with plant decommissioning are unavoidable and will be significant whether 9 the plant is decommissioned at the end of the initial license term or at the end of the period of 10 extended operation. The no-action alternative will not have an appreciable effect on waste 11 volumes associated with decommissioning.

12

• Human Health 13 In Chapter 4 of this SEIS, the NRC staff concluded that the impacts of continued plant operation 14 on human health are SMALL. After cessation of plant operations, the amount of radioactive 15 material released to the environment in gaseous and liquid forms, which are currently within 16 regulatory limits, will be reduced. Therefore, the NRC staff concludes that the impact of plant 17 shutdown on human health also would be SMALL. In addition, the variety of potential accidents 18 at the plant will be reduced to a limited set associated with shutdown events and fuel handling.

19 In Chapter 5 of this SEIS, the staff concluded that impacts of accidents during operation are 20 SMALL. Therefore, the NRC staff concludes that the impacts of potential accidents following 21 shutdown of IP2 and IP3 also would be SMALL.

22

• Socioeconomics 23 In Chapter 4 of this SEIS, the NRC staff concluded that the socioeconomic impacts of continued 24 plant operation would be SMALL. Should the plant shut down, there would be immediate 25 socioeconomic impacts from loss of jobs (some, though not all, of the approximately 1255 full-26 time employees and baseline contractors would begin to leave the site); property tax payments 27 to Westchester County may be reduced. These impacts, however, would not be considered 28 significant on a countywide basis because of the large population in the area and because plant 29 workers' residences are not concentrated in a single municipality or county.

30 PILOT payments and other taxes from IP2 and IP3 are paid directly to the Town of Cortlandt, 31 the Village of Buchanan, and the Hendrick Hudson Central School District. Entergy paid a 32 combined $21.2 million in PILOT payments, property taxes, and other taxes to Westchester 33 County, the Town of Cortlandt, the Village of Buchanan, the Verplanck Fire District, and the 34 Hendrick Hudson Central School District in 2005 (Entergy 2007). PILOT payments, property 35 taxes, and other taxes paid by the site account for a significant portion of revenues for these 36 Government agencies.

37 The Village of Buchanan, which has over 2100 residents, is the principal local jurisdiction that 38 receives direct revenue from IP2 and IP3. In fiscal year 2005, PILOT payments, property taxes, 39 and other taxes from Entergy contributed about 39 percent of the Village of Buchanan's total 40 revenue of $5.08 million (Entergy 2007). The revenues generated from IP2 and IP3 are used to 41 fund police, fire, health, transportation, recreation, and other community services. Additionally 42 in fiscal year 2005, PI LOT payments, property taxes, and other taxes from Entergy contributed I NUREG-1437, Supplement 38 8-24 December 2010 OAGI0001367A_00357

Environmental Impacts of Alternatives to License Renewal 1 over 35 percent of the total revenue collected for the Hendrick Hudson Central School District, 2 which serves approximately 3000 students (Entergy 2007).

3 The shutdown of IP2 and IP3 may result in increased property values of the homes in the 4 communities surrounding the site (Levitan and Associates, Inc. 2005). This would result in 5 some increases in tax revenues. However, to fully offset the revenues lost from the shutdown of 6 IP2 and IP3, taxing jurisdictions most likely would have to compensate with higher property 7 taxes (Levitan and Associates, Inc. 2005). The combined increase in property values and 8 increased taxes could have a noticeable effect on some area homeowners and business, 9 though Levitan and Associates did not indicate the magnitude of this effect and whether the net 10 effect would be positive or negative.

11 Revenue losses from Indian Point operation would affect the communities closest to and most 12 reliant on the plant's tax revenue and PILOT. If property values and property tax revenues 13 increase, some of these effects would be smaller. The NRC staff concludes that the 14 socioeconomic impacts of plant shutdown would likely be SMALL to MODERATE (MODERATE 15 effects for the Hendrick Hudson Central School District, Village of Buchanan, Town of Cortlandt, 16 and the Verplanck Fire District). See Appendix J to NUREG-0586, Supplement 1 (NRC 2002),

17 for additional discussion of the potential impacts of plant shutdown.

18

• Transportation 19 In Chapter 4 of this SEIS, the NRC staff concluded that the impacts of continued plant operation 20 on transportation would be SMALL. Cessation of operations will be accompanied by reduced 21 traffic in the vicinity of the plant. Most of the reduction will be associated with a reduction in 22 plant workforce, but there will also be a reduction in shipment of maintenance materials to and 23 from the plant. Therefore, the staff concludes that the impacts of plant closure on transportation 24 would be SMALL 25

• Aesthetics 26 In Chapter 4 of this SEIS, the NRC staff concluded that the aesthetic impacts of continued plant 27 operation would be SMALL. Major plant structures and other facilities, such as the containment 28 buildings and turbine buildings, are likely to remain in place until decommissioning begins. The 29 NRC staff also anticipates that the overall appearance of the facility and its grounds would be 30 maintained through the decommissioning. Since no significant changes would occur between 31 shut down and decommissioning, the staff concludes that the aesthetic impacts of plant closure 32 would be SMALL.

33

• Historic and Archeological Resources 34 In Chapter 4 of this SEIS, the staff concluded that the impacts of continued plant operation on 35 historic and archeological resources would be SMALL. Onsite land use will not be affected 36 immediately by the cessation of operations since plant structures and other facilities are likely to 37 remain in place until decommissioning. Following plant shutdown, there would be no 38 foreseeable need for archeological surveys of the area. Therefore, the NRC staff concludes 39 that the impacts on historic and archeological resources from plant shutdown would be SMALL.

40 December 2010 8-25 NUREG-1437, Supplement 38 I OAGI0001367A_00358

Environmental Impacts of Alternatives to License Renewal 1

• Environmental Justice 2 In Chapter 4 of this SEIS, the NRC staff concluded that the environmental justice impacts of 3 continued operation of the plant would be SMALL because continued operation of the plant 4 would not have a disproportionately high and adverse impact on minority and low-income 5 populations. Although the NRC staff concluded that the socioeconomic impacts of the plant 6 shutdown would be MODERATE for some jurisdictions, the impacts of the plant shutdown are 7 likely to be felt across the entire community and could disproportionately affect some minority 8 and low-income populations. Some minority and low-income populations located in urban areas 9 could be affected by reduced air quality and increased health risks due to the burning of fossil 10 fuel in existing power plants used to replace the lost power generated by Indian Point.

11 As described in Section 2.2.8.6, the site contributed over 35 percent of the total revenue 12 collected for the Hendrick Hudson Central School District in 2005. The Hendrick Hudson 13 Central School District has only an 18-percent minority population (compared to a 47-percent 14 Statewide average) and only 5 percent of the students are eligible for a free or reduced-price 15 lunch program (compared to a Statewide average of 44 percent). Therefore, the loss of funding 16 to the Hendrick Hudson Central School District would not disproportionately affect minority and 17 low-income populations (GreatSchools 2008).

18 The site contributed about 39 percent of the Village of Buchanan's total revenue in 2005 19 (Entergy 2007). In 2000, less than 4 percent of the population were minorities and less than 20 4 percent of the individuals were below the poverty level (US Census Bureau 2000). Therefore, 21 the loss of funding to the Village of Buchanan would not disproportionately affect minority and 22 low-income populations.

23 The NRC staff concludes that the environmental justice impacts of plant shutdown would be 24 SMALL. See Appendix J to NUREG-0586, Supplement 1 (NRC 2002), for additional discussion 25 of these impacts.

26 8.3 Alternative Energy Sources 27 This section discusses the environmental impacts associated with developing alternative 28 sources of electric power to replace power generated by IP2 and IP3. The order of alternative 29 energy sources presented in this section does not imply which alternative would be most likely 30 to occur or which is expected to have the least environmental impacts. The NRC staff notes 31 that discussion of supercritical coal-fired generation has been relocated to Section 8.3.

32 The following central generating station alternatives are considered in detail in the identified 33 sections of this SEIS:

34

• natural gas combined-cycle (NGCC) generation at either the IP2 and IP3 site or an 35 alternate site (Section 8.3.1) 36 The NRC staff considers the following nongeneration alternatives to license renewal in detail in 37 the identified sections of this SEIS:

38

• purchased electrical power (Section 8.3.2) 39

• energy conservation and efficiency (Section 8.3.3) 40 NUREG-1437, Supplement 38 8-26 December 2010 OAGI0001367A_00359

Environmental Impacts of Alternatives to License Renewal 1 The NRC staff also considers two combinations of alternatives that include new or existing 2 generation along with conservation or purchased power in the identified sections of this SEIS:

3

• continued operation of either IP2 or IP3, renewable generation, and conservation 4 programs (Section 8.3.5.1) 5

• repowering a retired facility with a new NGCC power plant, renewable generation, and 6 conservation (Section 8.3.5.2) 7 Alternatives considered by the NRC staff but dismissed from further evaluation as stand-alone 8 alternatives are addressed in Section 8.3.4 of this SEIS. Several of the alternatives discussed 9 in Section 8.3.4 are included in the combinations addressed in Section 8.3.5.

10 Alternatives Process 11 Since IP2 and IP3 have a net electric output of 2158 MW(e), the NRC staff evaluated the 12 impacts of alternatives with comparable capabilities.

13 Of the alternatives mentioned in this section, the NRC staff expects that only a NGCC 14 generation alternative could be wholly developed at the IP2 and IP3 facility because the site is 15 too small to host other alternatives. As noted elsewhere in this Chapter, the NGCC alternative 16 could also be constructed as part of a repowering operation of another existing but retired power 17 plant.

18 While the alternate site considered need not be situated in New York State, the availability of 19 transmission line capacity to deliver power from a location outside the New York metropolitan 20 region to current IP2 and IP3 customers could constrain siting choices. The DOE has identified 21 critical congestion areas where it is critically important to remedy existing or growing electrical 22 transmission congestion problems because the impacts of the congestion could be severe. It is 23 conceivable that these transmission congestion patterns would influence selection of an 24 alternate site for generating power that is needed in the New York metropolitan region. For 25 purposes of this analysis, however, the NRC staff assumes that adequate transmission will exist 26 - either through planned, new projects (e.g., the proposed New York Regional Interconnect -

27 NYRI , or the Champlain-Hudson Power Express, Inc. - CHPEI - Project, among others) - or by 28 locating the alternatives near to downstate loads.

29 All of New York's constrained transmission paths move power from areas to the west, south, 30 and north of the State to the loads in and around New York City and Long Island. The New 31 York City metropolitan area consumes major quantities of electricity with less generation 32 capacity than load. Therefore, the region is dependent on imports. Because of the area's 33 current dependence on local power generation from natural gas and oil fuels, the area has high 34 electricity rates (DOE 2006). The replacement of limited local generation sources with 35 additional imported power would place even more demands on the constrained transmission 36 system moving power into the New York City area, though direct current transmission, like 37 CHPEI, could allow greater flexibility. As noted in Section 8.2, it may be necessary to continue 38 operating the IP2 and IP3 generators as synchronous condensers to supply virtual power to the 39 local transmission system after the IP2 and IP3 reactors shut down.

40 Finally, the NRC staff notes that an infinite number of potential combination alternatives exists, 41 based on varying the amounts or types of power generation means employed or varying the 42 extent to which alternatives rely on energy conservation. The following alternatives are based December 2010 8-27 NUREG-1437, Supplement 38 OAGI0001367A_00360

Environmental Impacts of Alternatives to License Renewal 1 on available research and input from the draft SEIS comment process, and represent, in the 2 staff's professional judgment, reasonable examples of combinations that address comments 3 received, ongoing State-level programs, and resource availability in New York State. The staff 4 also notes that none of these combinations are intended to place a limit on available capacities, 5 nor are they intended to supplant State or utility level policy decisions about how to generate 6 electricity, reduce or add to load, set prices, or promote different approaches to generating 7 electricity or managing loads.

8 EIA Projections 9 Each year the Energy Information Administration (EIA), a component of DOE, issues an annual 10 energy outlook. In its "Annual Energy Outlook 2010 with Projections to 2035," EIA projects that 11 natural gas-fired plants will account for approximately 46 percent of electric generating capacity 12 additions through 2035 (DOE/EIA 2010), while coal-fired plants will account for approximately 13 12 percent of generating capacity additions through 2035 (DOE/EIA 2010). EIA projects that 14 renewable energy sources will account for 36 percent of capacity additions through 2035 15 (DOE/EIA 2010). New nuclear units are expected to account for only 3 percent of additions 16 over the same time period (DOE/EIA 2010).

17 EIA bases its projections on the assumption that providers of new generating capacity will seek 18 to add generating sources that are cost effective and meet applicable environmental 19 requirements, like air emissions standards. Particularly, uncertainty about future limits on 20 greenhouse gases (GHGs), along with Federal incentives, State energy programs, and rising 21 fossil fuel prices increase competitiveness for renewable and nuclear power (DOE/EIA 2010).

22 Aspects of the American Recovery and Reinvestment Act (ARRA) have also supported 23 renewable capacity growth and will likely continue to do so. EIA notes that regulatory 24 uncertainty also drives capacity decisions. For example, EIA notes that potential future 25 requirements for carbon capture and sequestration (CCS) could result in higher costs for coal 26 generation. Given a smaller future role for coal-fired power, in line with New York State's 27 declining reliance on coal (DOE/EIA 2009) and GHG restrictions imposed by the Regional 28 Greenhouse Gas Initiative (RGGI), the NRC staff has relocated the supercritical coal-fired 29 alternative to Section 8.3.4., Alternatives Dismissed from Individual Consideration. NRC staff 30 addresses the impacts of a new NGCC plant located at either the IP2 and IP3 site or an 31 alternate site in Section 8.3.1 of this SEIS, and considers combinations of alternatives that 32 include substantial amounts of renewable energy sources in Section 8.3.5.

33 In contrast to many recent AEO editions, EIA no longer indicates, in its overview of future 34 electrical generation capacity, that any new capacity will be fired with oil. NRC staff notes that 35 some gas-fired facilities may fire with oil during periods of high gas demand, but does not 36 consider new oil-fired capacity in this SEIS ..

37 The NRC staff uses EIA's projections to help select reasonable alternatives to license renewal.

38 In the following sections of this chapter, the NRC staff will examine several alternatives in depth, 39 and identify a range of others that staff considered but rejected.

40 8.3.1 Natural Gas-Fired Combined-Cycle (NGCC) Generation 41 In this section, the NRC staff examines the environmental impacts of the NGCC alternative at 42 both IP2 and IP3 and at an alternate site. The NRC staff assumed that a natural gas-fired plant 43 would use a closed-cycle cooling system.

NUREG-1437, Supplement 38 8-28 December 2010 OAGI0001367A_00361

Environmental Impacts of Alternatives to License Renewal 1 This replacement NGCC plant would likely use combined-cycle technology. Compared to 2 simple-cycle combustion turbines, combined-cycle plants are significantly more efficient, and 3 thus provide electricity at lower costs. NGCC power plants also tend to operate at markedly 4 higher thermal efficiencies than other fossil-fuel or nuclear power plants, and require less water 5 for condenser cooling than other thermoelectric alternatives. As such, the NGCC alternative 6 would require smaller cooling towers and substantially less makeup water than the cooling 7 system proposed in Section 8.1.1 of this SEIS. Typically, these plants support intermediate 8 loads but they are capable of supporting a baseload duty cycle; thus they provide an alternative 9 to renewing the IP2 and IP3 operating licenses. Levitan and Associates indicated that gas-fired 10 generation was the most likely alternative to take the place of IP2 and IP3 (Levitan and 11 Associates 2005). Further, New York State is increasingly reliant on natural gas for electrical 12 power.

13 The NRC evaluated environmental impacts from gas-fired generation alternatives in the GElS, 14 focusing on combined-cycle plants (NRC 1996). In a combined-cycle unit, hot combustion 15 gases in a combustion turbine rotate the turbine to generate electricity. Waste combustion heat 16 from the combustion turbine is routed through a heat-recovery steam generator, which then 17 powers a steam turbine electrical generator. The combination of two cycles can be as much as 18 60 percent efficient.

19 EIA projects that advanced combined-cycle gas turbines can operate at a heat rate as low as 20 6333 BTU/kWh for units with net output of 400 MW(e) (DOE/EIA 2010b). These units are more 21 efficient than the 408-MW(e) units Entergy considered in its ER, and would consume less fuel, 22 while producing fewer emissions per unit of electrical output. Using five, 400-MW(e) units would 23 slightly underestimate the total impact to some resources, but it provides a useful approximation 24 using more-current technology ..

25 The NRC staff discusses the overall impacts of the NGCC generating system in the following 26 sections and summarizes them in Table 8-4 of this SEIS. The extent of impacts at an alternate 27 site would depend on the location of the site selected. A third option is that this NGCC 28 alternative could be constructed at an existing, retired or underutilized fossil facility as part of a 29 facility repowering. Impacts would be essentially the same for a repowered facility as for a 30 facility constructed at Indian Point, though available site infrastructure could result in slightly 31 lower or higher impacts at the repowering project. Regardless, a repowered site would already 32 have transmission access, likely access to cooling water, and possible access to gas 33 transmission infrastructure.

34

• Land Use 35 Existing facilities and infrastructure would be used to the extent practicable if a NGCC complex 36 were to be developed at IP2 and IP3. Specifically, the NRC staff assumed that this alternative 37 would use the existing switchyard, offices, and transmission line ROWs. However, a new 38 mechanical-draft cooling tower would need to be constructed to support the new closed-cycle 39 cooling system.

40 The GElS estimated that 45 ha (110 ac) are needed for a 1000-MW(e) natural gas-fired facility.

41 Scaling up for the 2000-MW(e) facility would indicate a land requirement of approximately 90 ha 42 (220 ac). The NRC staff notes that some existing NGCC facilities require less space than the 43 GElS indicates, and may be more on the order of 16 ha (40 ac) per 1000 MW(e), inclusive of 44 cooling towers. (Entergy's withdrawn proposal for combined-cycle capacity on the IP2 and IP3, December 2010 8-29 NUREG-1437, Supplement 38 OAGI0001367A_00362

Environmental Impacts of Alternatives to License Renewal 1 for example, required only 2 ha (5 ac) for 330 MW(e) of capacity (as noted in Levitan and 2 Associates 2005)). The IP2 and IP3 site is only 98 ha (242 ac) with some land unsuitable for 3 construction. Also, much of the site is covered by the IP2 and IP3 containment structures, 4 turbine buildings, other IP2 and IP3 support facilities, and AGTC gas pipeline. Land covered by 5 some IP2 and IP3 facilities would not be available until decommissioning, though land covered 6 by some support facilities may be available prior to the end of the current license. The AGTC 7 pipeline ROW would remain unavailable. Based on previous Entergy proposals and experience 8 at other combined-cycle plants, however, the NRC staff finds it possible that a NGCC alternative 9 could be constructed and operated on the IP2 and IP3 site.

10 As reported by Levitan and Associates, Inc. (2005), the existing Algonquin pipeline that passes 11 through the IP2 and IP3 site may be adequate for a 330-MW(e) simple-cycle plant that would 12 operate in peaking mode during the summer season, when gas supplies are less constrained by 13 winter-season heating demands. Levitan and Associates (2005) concluded that substantial and 14 expensive pipeline upgrades would probably be necessary to supply natural gas to a combined-15 cycle alternative throughout the winter heating season and for the additional baseload capacity 16 throughout the year. Given firm demand for natural gas during the winter heating season, it is 17 possible that the NGCC alternative may need to burn fuel oil during several weeks of the year, 18 should conditions of limited supply emerge. This practice is common at gas-fired power plants 19 in the northeastern United States. Another option is that future, proposed liquefied natural gas 20 (LNG) facilities in the northeastern United States or Canadian maritime provinces could reduce 21 demands on the Algonquin pipeline system.

22 The environmental impacts of locating the NGCC facility at an alternate location would depend 23 on the past use of the location. If the site is a previously undisturbed site the impacts would be 24 more significant than if the site was a previously developed site, or if the site is a repowered, 25 existing facility. Construction and operation of the NGCC facility at an undeveloped site would 26 require construction of a new cooling system, switchyard, offices, gas transmission pipelines, 27 and transmission line ROWs. A previously industrial site may have closer access to existing 28 infrastructure, which would help to minimize environmental impacts. A NGCC alternative 29 constructed at the IP2 and IP3 site would have direct access to a transmission system, an 30 existing pipeline ROW, and an existing dock to receive major components. A repowered facility 31 is likely to have similar access to supporting infrastructure as a facility sited at the Indian Point 32 site, and may have other benefits, like existing connections to natural gas pipelines. In some 33 cases, other onsite support structures may also be repurposed to support the repowering 34 operation.

35 Regardless of where a NGCC alternative is built, the GElS indicates that additional land would 36 be required for natural gas wells and collection stations. According to the GElS, a 1000-MW(e) 37 gas-fired plant requires approximately 1500 ha (3700 ac) for wells, collection stations, and 38 pipelines, or about 3000 ha (7400 ac) for a 2000-MW(e) facility (NRC 1996).

39 Overall, land use impacts of the NGCC alternative are considered SMALL to MODERATE at the 40 IP2 and IP3 site. NGCC land use impacts at a new previously industrial site or a repowered 41 facility are considered to be SMALL to MODERATE; while NGCC generation at a new 42 undeveloped site would have MODERATE to LARGE impacts.

43

• Ecology 44 At the IP2 and IP3 site, there would be terrestrial ecological impacts associated with siting a NUREG-1437, Supplement 38 8-30 December 2010 OAGI0001367A_00363

Environmental Impacts of Alternatives to License Renewal 1 NGCC facility. These impacts would likely be less than those described in Section 8.1.1.2 of 2 this SEIS, which discusses the ecological impacts of the construction of a closed-cycle cooling 3 system to support IP2 and IP3, as existing portion of the site currently used for support 4 structures like parking lots or outbuildings could be redeveloped for a gas fired alternative. Also, 5 substantially less soil and rock removal would be necessary. The duration of impacts from 6 construction would be less.

7 Improvements to the existing pipeline network would also be necessary, with some impacts 8 along the already-disturbed ROW. Levitan and Associates (2005) indicated that no 9 transmission system improvements would be necessary to accommodate the NGCC alternative 10 at the IP2 and IP3 site. Overall, construction effects are limited in both scope and duration.

11 Impacts to terrestrial ecology of constructing the NGCC alternative on site are likely to be 12 SMALL. In most cases, impacts at a repowering project would be similarly SMALL, depending 13 on the extent to which existing site structures can be reused. Some transmission improvements 14 may be necessary if the repowered site was previously of smaller capacity.

15 Ecological impacts at an alternate site would depend on the nature of the land used for the plant 16 and the possible needs for a new gas pipeline and/or transmission lines. Construction of the 17 transmission line and construction and/or upgrade of the gas pipeline to serve a new plant at an 18 alternate site, if necessary, would have substantial ecological impacts, though these would be 19 temporary. Ecological impacts to the plant site and in utility ROWs could include impacts on 20 threatened or endangered species, habitat loss or fragmentation, reduced productivity, and a 21 local reduction in biological diversity. Impacts to terrestrial ecology would likely be SMALL to 22 MODERATE, depending on site characteristics.

23 Operation of the NGCC alternative at the IP2 and IP3 site or another site would likely not 24 introduce noticeable new terrestrial ecological effects after construction.

25 The NGCC alternative is unlikely to create significant impacts for aquatic ecology during 26 construction, regardless of location. Because the plant has a relatively small footprint, and 27 because crews would likely implement some measures to control site runoff, it is unlikely that 28 impacts to aquatic ecology would be noticeable. Noticeable effects could occur during 29 construction if new transmission line ROWs or gas pipelines would need to cross streams or 30 rivers.

31 During operations, aquatic ecological resources would experience significantly smaller effects 32 than they would from a comparable nuclear or coal-fired power plant. The combined-cycle gas 33 plant using closed-cycle cooling would require less than half the cooling water of IP2 and IP3 34 using closed-cycle cooling. Construction of intake and discharge structures at an alternate site 35 could trigger some impacts to aquatic ecology, but because these impacts are very limited in 36 scope and time, they will likely not affect any important resource characteristics. Thus, aquatic 37 ecological impacts of the NGCC alternative are likely to be SMALL.

38 At an alternate site, impacts to ecology may range from SMALL to MODERATE, while they are 39 likely to be SMALL if constructed at the existing IP2 and IP3 site or a repowered site.

40

• Water Use and Quality 41 Surface Water: NGCC plants are highly efficient and require less cooling water than other 42 generation alternatives. Plant discharges would consist mostly of cooling tower blowdown, with 43 the discharge having a slightly higher temperature and increased concentration of dissolved December 2010 8-31 NUREG-1437, Supplement 38 OAGI0001367A_00364

Environmental Impacts of Alternatives to License Renewal 1 solids relative to the receiving water body, as well as intermittent, low concentrations of biocides 2 (e.g., chlorine). All discharges from a new plant at the IP2 and IP3 site would be regulated 3 through a New York SPDES permit, which would be issued by NYSDEC. Finally, some erosion 4 would probably occur during construction (NRC 1996), though the GElS indicates this effect 5 would be SMALL. Plant construction crews would employ at least basic runoff control 6 measures. Because crews would likely not have to construct entirely new intake structures, 7 transmission lines, or a gas pipeline, most activities that could affect water use and quality will 8 not occur for an alternative constructed at the IP2 and IP3 site, or at a repowered site. Like the 9 existing IP2 and IP3, a NGCC alternative located on the site would likely not rely on ground 10 water. Overall, impacts to water use and quality at the IP2 and IP3 site from a NGCC 11 alternative would likely be SMALL for both construction and operation.

12 At an alternate site, a NGCC alternative would likely rely on surface water for cooling makeup 13 water and blowdown discharge. Intake and discharge would involve relatively small quantities 14 of water compared to once-through cooling and less than a nuclear or coal-fired power plant.

15 The impact on the surface water would depend on the volume of water needed for makeup 16 water, the discharge volume, and the characteristics of the receiving body of water. If a NGCC 17 plant discharges to surface water, the plant would have to meet the requirement of a SPDES 18 permit. The NRC staff expects that any new facility would comply with requirements of the 19 discharge permits issued for its operation. Thus discharges from the plant would be legally 20 obligated to conform to applicable water quality standards. Water withdrawals from a small river 21 or cooling pond, however, could lead to potential water use conflicts. The impacts would be 22 SMALL to MODERATE during operations depending on receiving water characteristics, though 23 they would likely be SMALL at a repowered site. During construction, some erosion would 24 probably occur though the GElS indicates this would have a SMALL effect (NRC 1996).

25 Ground Water: IP2 and IP3 currently use no ground water. It is likely that a NGCC alternative 26 at the IP2 and IP3 site would also use no ground water. Impacts at the IP2 and IP3 site would 27 thus be SMALL. Ground water impacts from operations at an alternate site or a repowered site 28 may vary widely depending on whether the plant uses ground water for any of its water needs, 29 though it would be unlikely that a plant on an alternate site would use ground water for cooling 30 system makeup water given the quantity of water required. Ground water impacts at an 31 alternate site could range from SMALL to MODERATE, depending on the quantity of ground 32 water used and characteristics of aquifers used. Construction-stage impacts at both the existing 33 site and a new site are likely to be SMALL.

34

• Air Quality 35 Natural gas is a relatively clean-burning fuel relative to relative to other fossil fuels. The NGCC 36 alternative would release a variety of emissions, however.

37 The NRC staff calculates that approximate emissions from the five-unit, 2000-MW NGCC 38 alternative with a heat rate of 6333 BTU/kWh would be:

39

• SOx-150 MT/yr (164 tons/yr) 40

• NOx-493 MT/yr (543 tons/yr) 41

• CO-103 MT/yr (113 tons/yr)

I NUREG-1437, Supplement 38 8-32 December 2010 OAGI0001367A_00365

Environmental Impacts of Alternatives to License Renewal 1

• Filterable particulates (PM1Q)-83 MT/yr (92 tons/yr)(3) 2 NGCC power plants primarily emit pollutants as a result of combustion conditions. These 3 pollutants include NOx , CO, and particulates. Regulations in place to reduce potential health 4 effects from air emissions, especially those promulgated in response to the CAA, drive the types 5 of emissions controls this NGCC alternative would use to limit its effects on air quality. CAA 6 mechanisms like new source performance standards, nonattainment areas, State 7 implementation plans, and specialized programs, including one that limited overall NOx 8 emissions throughout the Eastern United States, all drive emissions control technologies used 9 in this NGCC alternative.

10 NOx is typically the pollutant of greatest concern for a NGCC power plant. Given the proper 11 atmospheric conditions, NOx helps to form ozone, as well as smog. The NGCC alternative in 12 this case relies on selective catalytic reduction (SCR) to reduce NOx emissions. As previously 13 discussed, IP2 and IP3 are located within the New Jersey-New York-Connecticut Interstate Air 14 Quality Control Region (40 CFR 81.13). All of the States of New Jersey and Connecticut, as 15 well as several counties in Central and Southeastern New York within a 80-km (50-mi) radius of 16 IP2 and IP3, are designated as nonattainment areas for ozone (8-hour standard) (EPA 2008b).

17 Operators or owners of a NGCC power plant constructed in a nonattainment area would need to 18 purchase offsets for ozone precursor emissions. In this case, NOx is the major ozone precursor 19 emitted by the NGCC power plant. In accordance with NYSDEC regulations, "Emission offsets 20 must exceed the net increase in annual actual emissions from the air contamination source 21 project" (NYSDEC, Chapter 3, Parts 231-15). By design, this regulatory requirement should 22 result in a net reduction in ozone emissions in the region.

23 A new NGCC generating plant located in a nonattainment area (like that at the IP2 and IP3 site) 24 would need a nonattainment area permit and a Title IV operating permit under the CAA. The 25 plant would need to comply with the new source performance standards for such plants set forth 26 in 40 CFR Part 60, Subpart Da. The standards establish limits for particulate matter and opacity 27 (40 CFR 60.42(a)), S02 (40 CFR 60.43(a)), and NOx (40 CFR 60.44(a)).

28 In December 2000, EPA issued regulatory findings on emissions of HAPs from electric utility 29 steam-generating units (EPA 2000a). NGCC power plants were found by EPA to emit arsenic, 30 formaldehyde, and nickel (EPA 2000a). Unlike coal- and oil-fired plants, EPA did not determine 31 that emissions of HAPs from NGCC power plants should be regulated under Section 112 of the 32 CAA.

33 A NGCC plant would have unregulated CO2 emissions of about 117 pounds per MMBtu 34 (DOE/EIA 2008a). The NRC staff calculates that a five-unit NGCC alternative with 35 technologically advanced turbines rated at 6333 BTU/kWh would emit approximately 5,516,000 36 MT (6,076,000 tons) of CO 2 per year. Section 6.2 of this SEIS contains a discussion of current 37 and future relative GHG emissions from several energy alternatives including coal, natural gas, 38 nuclear, and renewables. Other emissions and losses during natural gas production or 39 transportation could also increase the relative GHG impact.

40 Construction activities also would result in some air effects, including those from temporary 41 fugitive dust, though construction crews likely would employ dust control practices to limit this 42 impact. Exhaust emissions also would come from vehicles and motorized equipment used (3)

Additional particulate emissions associated with the cooling towers were not quantified.

December 2010 8-33 NUREG-1437, Supplement 38 OAGI0001367A_00366

Environmental Impacts of Alternatives to License Renewal 1 during the construction process, though these emissions are likely to be intermittent in nature 2 and will occur over a limited period of time. As such, construction stage impacts would be 3 SMALL.

4 The overall air quality impact for operation of a new NGCC plant at the IP2 and IP3, at an 5 alternate site, or at a repowered site would be SMALL to MODERATE, depending on air quality 6 in the surrounding airshed. Air quality impacts during construction would be SMALL.

7

• Waste 8 Burning natural gas fuel generates small amounts of waste. However, a plant using SCR to 9 control NOx will generate spent SCR catalyst and small amounts of solid waste products (i.e.,

10 ash). In the GElS, the NRC staff concluded that waste generation from gas-fired technology 11 would be minimal (NRC 1996). Waste generation impacts would be minor and would not 12 noticeably alter any important resource attribute.

13 Constructing a NGCC alternative would generate small amounts of waste, though many 14 construction wastes can be recycled. Construction either at the Indian Point site or at a 15 repowered site would likely require little land-clearing, though some existing on-site structures at 16 either Indian Point or a repowered site may need to be dismantled or demolished. Most of this 17 type of debris would be recycled, transported offsite, or, in the case of demolished concrete, 18 parking lots, and roads, could be reused at road bed material, laydown areas, or for clean fill 19 onsite. Land-clearing debris from construction at an alternate location could be land filled on 20 site. Overall, the waste impacts would be SMALL for a NGCC plant sited at an alternate site or 21 a repowered site.

22 Cooling towers for a new NGCC alternative would be much smaller than those proposed in 23 8.1.1, and would not need to be constructed on slopes near the Hudson. Waste generation 24 from plant construction, then, is much less than in 8.1.1.2. The waste-related impacts 25 associated with construction of a five-unit NGCC plant with closed-cycle cooling systems at the 26 IP2 and IP3 site would be SMALL.

27

• Human Health 28 Human health effects from the operation of a NGCC alternative with SCR emissions controls 29 would likely not be detected or would be sufficiently minor that they would neither destabilize nor 30 noticeably alter any important attribute of the resource.

31 During construction activities there would be a risk to workers from typical industrial incidents 32 and accidents. Accidental injuries are not uncommon in the construction industry, and 33 accidents resulting in fatalities do occur. However, the occurrence of such events is mitigated 34 by the use of proper industrial hygiene practices, complying with worker safety requirements, 35 and training. Occupational and public health impacts during construction are expected to be 36 controlled by continued application of accepted industrial hygiene protocols, occupational health 37 and safety controls, and radiation protection practices. Fewer workers would be on site for a 38 shorter period of time to construct a NGCC plant than other new generation alternatives, and so 39 exposure to occupational risks tends to be lower than other alternatives.

40 Overall, the impacts on human health of a NGCC alternative sited at IP2 and IP3, a repowered 41 site, or at an alternate site would be considered SMALL.

42

• Socioeconomics NUREG-1437, Supplement 38 8-34 December 2010 OAGI0001367A_00367

Environmental Impacts of Alternatives to License Renewal 1 Construction of a NGCC plant would take approximately 3 years (DOE/EIA 2007b). Peak labor 2 force would be approximately 1090 workers (NRC 1996). The NRC staff assumed that 3 construction of an offsite alternative would take place while IP2 and IP3 continue operation and 4 would be completed by the time the plants permanently cease operations. Entergy indicates 5 that a gas-fired facility could be producing power before IP2 and IP3 shut down (Entergy 2007).

6 Construction time periods and employment figures may vary somewhat a repowering project 7 depending on the extent to which existing structures can be reused.

8 At the end of construction, the local population would be affected by the loss of as many as 9 1090 construction jobs. However, this loss would be partially offset by a postconstruction 10 permanent employment. An additional construction workforce would be needed for the 11 decommissioning of IP2 and IP3 which could temporarily offset the impacts of the lost 12 construction and IP2 and IP3 jobs at the IP2 and IP3 site. A new NGCC plant at the IP2 and 13 IP3 site would offset a small portion of lost employment, though, according to Levitan and 14 Associates, it may provide more revenues to the surrounding jurisdictions than IP2 and IP3 do 15 (2005). The large and diverse economic base of the region would help to offset or minimize the 16 significance of job losses.

17 The NRC staff concludes that the overall socioeconomic impacts from the NGCC alternative 18 could be SMALL to MODERATE during construction and could be SMALL to MODERATE 19 during operation at most sites, depending largely on tax impacts.

20

• Transportation 21 Impacts associated with transportation of the construction and operating personnel to the plant 22 site would depend on the population density and transportation infrastructure in the vicinity of 23 the site. During the 3-year construction period of the NGCC facility, approximately 1090 24 construction workers may be working at the site. The addition of these workers would increase 25 traffic on highways and local roads that lead to the construction site. The impact of this 26 additional traffic would have a SMALL to MODERATE impact on nearby roadways, depending 27 on road infrastructure and existing traffic demands. Rural areas would typically experience a 28 greater impact than urban or suburban areas. Impacts associated with plant operating 29 personnel commuting to and from work are considered SMALL at all sites. Because the NGCC 30 alternative relies on pipelined fuel, transportation impacts from natural gas supply are not likely 31 to be noticeable, though plant operators will have to ensure that sufficient gas transportation 32 capacity exists.

33

• Aesthetics 34 The combustion turbines and the heat-recovery boilers of the NGCC plant would be relatively 35 low structures compared to existing plant facilities, but could be visible from the Hudson River if 36 located at the current IP2 and IP3 site. Some facility structures could be visible from offsite 37 locations as well. The impact on aesthetic resources of a NGCC plant is likely less than the 38 impact of the current nuclear plant, excepting when cooling towers produce noticeable plumes.

39 Overall, aesthetic impacts from a NGCC plant constructed at the IP2 and IP3 site would likely 40 be SMALL. Impacts on a repowered site would be similar to those at the Indian Point site. In 41 some cases, substantial portions of onsite infrastructure may be reused such that the aesthetic 42 impacts of a repowered facility differ little from those of the facility prior to repowering.

43 At an alternate site, new buildings, cooling towers, cooling tower plumes, and electric December 2010 8-35 NUREG-1437, Supplement 38 OAGI0001367A_00368

Environmental Impacts of Alternatives to License Renewal 1 transmission lines would be visible off site. Visual impacts from new transmission lines or a 2 pipeline ROW would also be significant, though these may be minimized by building near 3 existing transmission lines or on previously developed land. Additionally, aesthetic impacts 4 would be minimized if the plant were located in an industrial area adjacent to other power 5 plants. Overall, the aesthetic impacts associated with the NGCC alternative at alternate site 6 could be SMALL to LARGE, though LARGE impacts would be expected only in cases where 7 substantial new transmission is necessary, and the lines have a significant effect on important 8 aesthetic values.

9

• Historic and Archeological Resources 10 As noted in Section 8.1.1.2, Entergy's recent Phase 1b survey revealed additional onsite historic 11 and prehistoric resources.A cultural resource inventory would be needed for any property at a 12 new site or adjacent to the IP2 and IP3 site that has not been previously surveyed. The survey 13 would include an inventory of field cultural resources, identification and recording of existing 14 historic and archeological resources, and possible mitigation of adverse effects from 15 subsequent ground-disturbing actions related to physical expansion of the plant site. The 16 studies would likely be needed for all areas of potential disturbance at the proposed plant site 17 and along associated corridors where new construction would occur (e.g., roads, transmission 18 corridors, rail lines, or other ROWs).

19 The impacts to historic and archeological resources for the NGCC alternative at the IP2 and IP3 20 site would be similar to, or less than those described in Section 8.1.1.2 of this SEIS for the 21 closed-cycle cooling alternative (given that the NGCC alternative would require less than half 22 the cooling tower capacity needed by IP2 and IP3. These impacts can likely be effectively 23 managed, and could range from SMALL to MODERATE if surveys reveal unavoidable conflicts 24 between the new facility and onsite resources. Impacts at a repowered site would likely entail 25 similar impacts of disturbance. At a repowered site, it may be possible to begin construction in 26 power block areas at a repowering site, while such reuse or repurposing would not be possible 27 until after Indian Point structures are no longer needed (and, perhaps, until decommissioning 28 occurs).

29 Historic and archeological resource impacts can generally be effectively managed on alternate 30 sites and, as such, would be considered SMALL to MODERATE at a new, undeveloped site.

31 For a previously developed site, impact on cultural and historic resources would also be SMALL 32 to MODERATE. Previous development would likely have either removed items of archeological 33 interest or may have included a survey for sensitive resources. Any significant resources 34 identified would have to be handled in accordance with the NHPA.

35

• Environmental Justice 36 As described in Section 8.1.1.2 of this SEIS, impacts to the environment or community from 37 actions at the IP2 and IP3 site, including the construction of a NGCC plant, are not likely to 38 disproportionately affect minority or low-income populations because these populations in the 39 area around the site are proportionately small compared to the geographical region's 40 population. Therefore, the NGCC alternative constructed at the IP2 and IP3 site would have 41 SMALL impacts on environmental justice. At a repowered site or at an alternate site, impacts 42 would depend upon the site chosen, nearby population characteristics, and economic 43 conditions. These impacts would range from SMALL to LARGE, depending on impacts and the 44 distribution of low-income and minority populations. At a repowered site, impact levels would NUREG-1437, Supplement 38 8-36 December 2010 OAGI0001367A_00369

Environmental Impacts of Alternatives to License Renewal 1 also depend on the current status of the existing power plant. If the plant is currently operating, 2 then repowering may reduce effects; if the plant is no longer operating, then repowering with a 3 baseload NGCC facility will create more significant impacts.

4 Table 8-3. Summary of Environmental Impacts of the NGCC Alternative Located at IP2 5 and IP3 and an Alternate Site Impact At IP Site or a Repowered Site New Site Category Impact Comments Impact Comments Land Use SMALL to Onsite land used; MODERATE About 90 ha (220 ac)

MODERATE most has been to LARGE needed for plant previously disturbed. construction; additional land may be needed for pipeline and transmission line ROWs.

Ecology SMALL Both terrestrial and SMALL to Impacts would depend aquatic impacts MODERATE on the nature of the land would be SMALL used for the plant and because the plant whether a new gas uses mostly d istu rbed pipeline and/or land and uses transmission lines are relatively little water. needed; cooling water would have SMALL aquatic resource impacts.

Water Use and SMALL Minor erosion and SMALL to With closed-cycle Quality sedimentation may MODERATE cooling, the impact occur during would likely be SMALL.

construction. The Impact depends on the plant would use no volume of used and groundwater. characteristics of the water body; impacts from water use conflicts could be MODERATE.

Air Quality SMALL to

• SOx: 150 MT/yr SMALL to Operational impacts MODERATE (164 tons/yr) MODERATE are the same as onsite

• NOx: 493 MT/yr plant but more (543 tons/yr) emissions from

• PM 10 : 83 MT/yr additional construction (92 tons/yr) activities.

• CO: 103 MT/yr (113 tons/yr)

• CO 2 : 5.5 million MT/yr (6.1 million tons/yr) 6 December 2010 8-37 NUREG-1437, Supplement 38 I

OAGI0001367 A_00370

I NUREG-1437, Supplement 38 8-38 December 2010 OAGI0001367A_00371

Environmental Impacts of Alternatives to License Renewal 1 Table 8-3 (continued)

At IP At a New Site Impact Site or a Repowered Site Category Impact Comments Impact Comments Aesthetics SMALL The impact is likely SMALL to The greatest impacts less than the impacts LARGE would be from new of the current plant; transmission lines, gas more land would be line ROW, and plant cleared and new structures. Impacts structures built; depend on the nature repowered site impacts of the site.

likely to be similar to those of existing structures.

Historical and SMALL to Impacts may reach SMALL to An alternate location Archeological MODERATE MODERATE on IP MODERATE would necessitate Resource site; most repowerings cultural resource likely to be SMALL. studies; construction would likely avoid highly sensitive areas.

Impacts likely would be managed or mitigated.

Environmental SMALL to SMALL at IP site; SMALL to Impacts would vary Justice LARGE SMALL to LARGE at LARGE depending on repowered site. population distribution and location of the new plant site.

2 8.3.2 Purchased Electrical Power 3 Based on currently scheduled unit retirements and demand growth projections, the NYISO 4 predicted in 2006 that up to 1600 MW(e) from new projects not yet under construction would be 5 needed by 2010 and a total of up to 3300 MW(e) by 2015 (National Research Council 2006).

6 Within the New York Control Area (NYCA), State power regulators require that load-serving 7 entities (LSE), or power buyers, purchase enough generating capacity to meet their projected 8 needs plus a reserve margin (National Research Council 2006). Entergy is not an LSE. In New 9 York, Entergy owns and operates power plants, but not transmission or distribution systems; 10 therefore, Entergy does not purchase power from other power generators. To replace the 11 output from IP2 and IP3, LSEs, like Consolidated Edison, would need to purchase additional 12 electric power from other sources, which could include new fossil-fueled power plants or 13 renewable alternatives, or it could purchase power from existing facilities at other sites outside 14 the NYCA (National Research Council 2006). Given New York State's power market, all 15 alternatives considered here could supply purchased power. The only constraint on the 16 purchase of electrical power then becomes electric transmission capacity.

December 2010 8-39 NUREG-1437, Supplement 38 I OAGI0001367A_00372

Environmental Impacts of Alternatives to License Renewal 1 Power sources within NYCA have an installed capacity of about 38,000 MW(e) and more than 2 6300 km (3900 mi) of high-voltage transmission lines (National Research Council 2006). The 3 current power transmission infrastructure makes it difficult to purchase power from outside the 4 southern regions of the NYCA (namely the New York City and Long Island load zones) because 5 there are power transmission constraints or "bottlenecks" between the southern load zones and 6 other power generating areas to the east and north, including Canada. These neighboring 7 areas would be needed to supply additional purchased power to replace power generated by 8 IP2 and IP3. Because of the bottlenecks in the transmission lines, new transmission capacity 9 would likely be necessary to efficiently move purchased power into the southern load zones and 10 provide a partial solution to the retirement of IP2 and IP3 (National Research Council 2006).

11 Such new transmission capacity would likely come in the form of either an expansion of the 12 existing high-voltage alternating current transmission system or the addition of new high-voltage 13 direct current transmission facilities (National Research Council 2006).

14 The National Research Council found that improvements in transmission capability could 15 significantly relieve congestion in the NYCA and increase delivery capacity from existing and 16 potential electric generation resources to the southern load zones. The Council has proposed a 17 550-MW(e) west-to-east line across the Hudson River and a new north-to-south transmission 18 line (up to 1000 MW(e)) for better access to upstate New York and Canadian electric resources 19 to provide useful capacity in the 2010 and 2015 time period (National Research Council 2006).

20 However, a variety of institutional and financial obstacles often stand in the way of such plans.

21 In 2006, the Council determined that a "concerted, well-managed, and coordinated effort would 22 be required to replace IP2 and IP3 by 2015 (National Research Council 2006).

23 Several new transmission projects are currently in planning stages. NRC staff will address two 24 of the proposed projects here as illustrative of the potential for new transmission in congested 25 areas of New York State.

26 As of November 2010, New York Regional Interconnection (NYRI is seeking the approval of the 27 New York Public Service Commission (NYPSC) to build a 306-km (190-mi) transmission line 28 with a rated power flow of 1200 MW(e) from the Town of Marcy in Oneida County to the towns 29 of Hamptonburgh and New Windsor in Orange County, New York (NYRI 2010). In accordance 30 with the NYRI application to the NYPSC, overhead transmission lines will make up 31 approximately 89 percent of the proposed route, and underground cable will constitute the 32 remainder of the route (NYRI 2008). NYRI has placed the proposed route within or parallel to 33 existing or inactive railroads and energy ROWs for approximately 78 percent of its distance. For 34 the remaining 22 percent of its distance, NYRI will construct the transmission lines in 35 undeveloped areas or areas where there are no existing ROWs. The proposed transmission 36 corridor includes 1155 ha (2854 ac). If approved, NYRI will clear 768 ha (1898 ac) of forested 37 habitat during construction. While the proposed route minimizes the amount of land clearing 38 and habitat destruction necessary, the proposed route also crosses sensitive habitats such as 39 streams and wetlands (NYRI 2008).

40 NYRI has proposed to construct additional transmission capacity that could be used to import 41 power into the southern load zones for the NYCA, with the potential for it to expand its proposed 42 1200-MW(e) capacity to 2400 MW(e). In addition, other proposed projects, like CHPEI, have the 43 potential to import additional power from Canada. In the case of CHPEI, the total project would 44 include 2000 MW(e) of transmission, though only 1000 MW(e) would be targeted to the New 45 York metropolitan area (CHPEI 2010). CHPEI is currently in the permitting process, and NUREG-1437, Supplement 38 8-40 December 2010 OAGI0001367A_00373

Environmental Impacts of Alternatives to License Renewal 1 expects to be operational by 2015. The NRC staff recognizes that purchased power could be 2 an alternative to IP2 and IP3. To the extent that new transmission projects allow other existing 3 facilities to provide additional power to downstate New York, the environmental impacts are 4 likely to be only the incremental impacts of additional operation. Upstate hydropower, wind 5 power, biomass, nuclear and fossil-fueled plants would likely contribute to additional power 6 supply. On CHPEI, project developers indicate that they expect Canadian hydro and wind 7 power to dominate their power supply (Canada relies extensively on hydropower for its current 8 generation).

9 To the extent that new generation capacity supplies power to these new projects, construction 10 impacts may be similar to those of other alternatives in this SEIS. New hydropower in Canada, 11 for example, may have substantial environmental impacts during construction and operation.

12 The actual environmental impacts of purchased power are difficult to determine, Each type of 13 power generation alternative has its own set of potential environmental costs and benefits, and 14 each must be evaluated with respect to the specific location and features of the generator. As a 15 result, the specific environmental impacts of purchased power cannot be reasonably evaluated 16 in the absence of more information. Nonetheless, it is highly likely that any generating source of 17 purchased power will have environmental impacts, the type and magnitude of which cannot be 18 assessed for comparative purposes as an alternative to license renewal of IP2 and IP3. It is 19 also highly likely that projects like NYRI and CHPEI will have separate State, and in the case of 20 CHPEI, Federal, processes for determining environmental impacts. In general, any 21 transmission project will serve to make environmental impacts of power generation more 22 distant from load centers in downstate New York. Impacts from the projects themselves are 23 highly variable and mayor may not be substantial. For example, visual impacts from 24 aboveground projects like NYRI could be substantial. CHPEI, in contrast, is likely to be partially 25 constructed underwater or underground along existing waterways and transportation right-of-26 ways, which should help to reduce effects, but its construction may have short-term impacts on 27 aquatic ecology or affect traffic in the transportation corridors along which it will be installed.

28 Both of these projects are independent of any decision to grant or deny renewal of the IP2 and 29 IP3 operating licenses, and are subject to other environmental review and regulatory processes 30 over which NRC has no control. Transmission system construction and operation have their 31 own environmental impacts, the specific nature and magnitude of which will vary depending on 32 the length and location of the proposed route. For example, construction through wetland areas 33 could entail significant ecological impacts, while construction through residential areas could 34 entail significant aesthetic impacts. In the absence of any specific route information, NRC staff 35 will not independently evaluate impacts of the transmission projects in this SEIS. They do, 36 however, serve as meaningful illustrations of projects that may improve the availability of power 37 from other regions of the State or Canada to reach the same end-use markets currently served 38 by IP2 and IP3.

39 8.3.3 Conservation 40 In this section, the NRC staff evaluates conservation(4)as an alternative to license renewal.

(4)

The NRC staff notes that conservation typically refers to all programs that reduce energy consumption, while energy efficiency refers to programs that reduce consumption without reducing services. For this section, some conservation measures considered by the NRC staff are also energy efficiency measures.

December 2010 8-41 NUREG-1437, Supplement 38 OAG10001367A_00374

Environmental Impacts of Alternatives to License Renewal 1 According to the American Council for an Energy-Efficient Economy (ACEEE) State Energy 2 Efficiency Scorecard for 2006, New York ranks seventh in the country in terms of 3 implementation of energy efficiency programs, suggesting that the State's conservation efforts 4 are significant when compared to other States (ACEEE 2006). New York scored well (2 out of 5 3) on tax incentives and appliance standards. The State scored low on energy efficiency 6 resource standards (0 out of 5) and utilities' per-capita spending on energy efficiency (5 out of 7 15), suggesting there is room for improvement in these areas.

8 The IP2 and IP3 ER (Energy 2007) dismissed conservation as a replacement alternative for IP2 9 and IP3 because conservation does not meet the criterion of a "single, discrete source." Also, 10 because Entergy is a generator of electricity and not a distributor, it indicated that it does not 11 have the ability to implement regionwide conservation programs (Entergy 2007). However, 12 because of efforts made by the State of New York and comments received during preparation of 13 this SEIS, the NRC staff examines conservation in this SEIS as an alternative to replace at least 14 part of the output of IP2 and IP3.

15 The New York State Energy Research and Development Authority (NYSERDA) is pursuing 16 initiatives in conservation. Within NYSERDA, the Energy Efficiency Services Program and 17 Residential Efficiency and Affordability Program deploy programs and services to promote 18 energy efficiency and smart energy choices (NYSERDA 2007). According to the NYSERDA, 19 implementation of conservation in the following program areas has resulted in significant energy 20 savings:

21

• existing buildings and structures 22

• new buildings and structures 23

• market/workforce development 24

• distributed generation and renewables 25

• industrial process 26

• transportation 27 In 2006, the National Research Council's Committee on Alternatives to Indian Point for Meeting 28 Energy Needs developed a report that specifically addressed alternatives to IP2 and IP3 for 29 meeting Statewide power needs (National Research Council 2006). The document reports that 30 in 2005, NYSERDA estimated that its energy efficiency programs had reduced peak energy 31 demands in New York by 860 MW(e). NYSERDA further forecasted that the technical potential 32 of its efficiency programs in New York would result in a cumulative 3800 MW(e)-reduction of 33 peak load by 2012 and 7400 MW(e) by 2022 (National Research Council 2006). "Technical 34 potential" refers to the complete deployment of all applications that are technically feasible.

35 In addition to the currently anticipated peak load reductions resulting from the NYSERDA 36 energy efficiency initiatives, additional conservation measures and demand-side investments in 37 energy efficiency, demand response, and combined heat and power facilities could significantly 38 offset peak demand Statewide. The National Resource Council estimated that peak demand 39 could be reduced by 1000 MW(e) or more by 2010 and 1500 MW(e) by 2015 (National 40 Research Council 2006).

41 The National Research Council estimates that economic potential peak demand in the IP2 and NUREG-1437, Supplement 38 8-42 December 2010 OAGI0001367A_00375

Environmental Impacts of Alternatives to License Renewal 1 IP3 service area could be expanded by approximately 200 MW(e) by 2010 and 300 MW(e) by 2 2015 assuming a doubling of the program budgets (National Research Council 2006).

3 "Economic potential" is defined as that portion of the technical potential that the National 4 Research Council judged to be cost effective. This estimate is based partly on the experience 5 with three NYSERDA programs that avoided the need for 715 MW(e) of Statewide peak 6 demand in 2004. Cost-effectiveness is based on a conservation option's ability to lower energy 7 costs (consumers' bills) while energy prices continue to increase using EIA price forecasts. The 8 National Research Council concludes that energy efficiency and demand-side management 9 have great economic potential and could replace at least 800 MW(e) of the energy produced by 10 IP2 and IP3 and possibly much more (National Research Council 2006).

11 More recently, New York State launched its Energy Efficiency Portfolio Standard program, 12 calling for a 15 percent reduction in energy usage by 2015 compared to forecast levels 13 (sometimes referred to as "15 by 15", and later combined with an augmented renewable 14 portfolio standard in the 45 by 15 plan). Between June 2009 and January 2010, the Public 15 Service Commission approved 45 electric energy efficiency programs and 44 gas efficiency 16 programs (NYSPSC 2010) 17 Given New York State's aggressive efforts in energy efficiency, as amplified by comments 18 received on the draft SEIS, the NRC staff here considers an energy conservation/energy 19 efficiency alternative, and will also include energy conservation in the combination alternatives.

20 Analyses in recent NRC license renewal SEISs (See NUREG-1437, Supplements 33 and 37, 21 regarding Shearon Harris and Three Mile Island, Unit 1, respectively), indicate that all impacts 22 from conservation are SMALL. The NRC staff adopts the analyses from those SEISs here, 23 insofar as they identified all SMALL impacts from conservation as an alternative. The NRC staff 24 also notes that loss of tax and PILOT revenue paid to municipalities near IP2 and IP3, as well 25 as lost jobs, may result in SMALL to MODERATE socioeconomic impacts, which will not be 26 offset by conservation.

27 28 8.3.4 Alternatives Dismissed from Individual Consideration 29 Other generation technologies the NRC staff considered but determined to be individually 30 inadequate to serve as alternatives to IP2 and IP3 are discussed in the following paragraphs.

31 The NRC staff has moved the supercritical coal-fired alternative to this section based on 32 comments, a staff review of likely generating alternatives in New York State, and policies like 33 the Regional Greenhouse Gas Initiative that make coal-fired generation unlikely in New York 34 State. The discussion of the supercritical coal-fired alternative in this section has not been 35 updated from the draft SEIS.

36 8.3.4.1 Wind Power 37 Studies conducted for the New York State Department of Public Service indicates that the total 38 wind resource potential by 2015 is 8527 MW (NYSDPS 2009). This includes both onshore and 39 offshore resources. offshore wind resources. Wind currently accounts for approximately 1275 40 MW(e), statewide (NYISO 2010). The NYSIO is managing wind generation projects that are 41 proceeding through the grid interconnection process. These projects have a potential of 42 December 2010 8-43 NUREG-1437, Supplement 38 I OAGI0001367A_00376

Environmental Impacts of Alternatives to License Renewal 1 generating almost 7000 MW(e) if all are completed (NYISO 2010). NYISO indicates 2 approximately 10% capacity credit, or 124 MW(e) for the 1275 MW(e) of existing wind power 3 based on availability of the resource. Thus, 7000 additional MW(e) of wind capacity would be 4 credited for less than 700 MW(e) of firm capacity(NRC staff further discusses this issue in the 5 combination alternatives later in this chapter).

6 Generally, wind power, by itself, is not suitable for large baseload capacity. As discussed in 7 Section 8.2.1 of the GElS, wind has a high degree of intermittency, and average annual 8 capacity factors for wind facilities are relatively low (on the order of 30 to 40 percent). Wind 9 power, in conjunction with energy storage mechanisms or other readily dispatchable power 10 sources like hydropower, might serve as a means of providing baseload power. However, 11 current energy storage technologies are too expensive to allow wind power to serve as a large 12 baseload generator.

13 Areas of class 3 or higher wind energy potential occur throughout much of the northeastern 14 United States (DOE 1986, 2008). The primary areas of good wind energy resources are the 15 Atlantic coast, the Great Lakes, and exposed hilltops, ridge crests, and mountain summits.

16 Winter is the season of maximum wind power throughout the Northeast when all except the 17 most sheltered areas have class 3 or better wind resource; exposed coastal areas and 18 mountain summits can expect class 6 or 7 wind resource. In summer, the season of minimum 19 wind power, class 3 wind resource can be found only on the outer coastal areas and highest 20 mountain summits (DOE 1986).

21 Wind power of class 3 and higher is estimated for the high elevations of the Adirondack 22 Mountains of northeastern New York (DOE 1986, 2008). Annual average wind power of class 3 23 or 4 is found along the coastal areas of both Lake Erie and Lake Ontario, while class 5 winds 24 are estimated to exist in the central part of both lakes (DOE 1986, 2008).

25 The National Research Council estimated that offshore wind could meet most of the IP2 and IP3 26 load by 2014 (National Research Council 2006).

27 Given the difficulties inherent in relying on wind power as a baseload alternative, the NRC staff 28 does not consider wind power to be a suitable stand-alone alternative, though the staff 29 recognizes New York's utility-scale wind resources and active wind resource development.

30 Therefore, the NRC staff includes wind power in the combination alternatives addressed in 31 Section 8.3.5 of this SEIS.

32 8.3.4.2 Wood and Wood Waste 33 Wood-burning electric generating facilities can provide baseload power. However, the 34 economic feasibility of a wood-burning facility is highly dependent on the availability of fuel 35 sources and the location of the generating facility. Most wood-fired and other biomass plants 36 are independent power producers and cogenerating stations with capacities on the order of 10 37 to 25 MW(e), with some plants operating in the 40 to 50 MW(e) range. In the 2007 New York 38 Renewable Electricity Profile (DOE/EIA 2009), New York's power industry reported only 37 39 MW(e) of generating capacity for wood or wood waste derived power. Power generated by 40 burning wood waste qualifies as renewable under New York's Renewable Portfolio Standard.

41 Wood-burning energy generation continues to be developed in the northeastern U.S. In 2005, 42 about 16 percent of the nation's energy derived from wood and wood wastes was generated in 43 the New England and Middle Atlantic census divisions (DOE/EIA 2007). Within the region, NUREG-1437, Supplement 38 8-44 December 2010 OAGI0001367A_00377

Environmental Impacts of Alternatives to License Renewal 1 about 12 percent of this generating capacity is from wood and wood wastes.

2 Walsh et al estimated New York's wood resources in a study published in 1999 (Walsh et al 3 1999). The study presents the amount of resources available in tons per year given a specified 4 price per dry ton delivered. Wood feedstock categories included forest residues, defined as 5 "logging residues; rough, rotten, and salvable dead wood; excess saplings; and small pole 6 trees," and primary mill residues (Walsh 1999). The annual resources available for each of 7 these categories at a delivery cost of less than $50 per dry ton are 1,746,400 and 1,274,000 8 tons, respectively (Walsh 1999). These volumes, respectively, account for about 4 percent and 9 1.5 percent of the total resource available in the 48 contiguous States. The neighboring States 10 of New Jersey, Connecticut, Massachusetts, and Vermont have significantly less wood 11 resource. Pennsylvania, however, has comparable resources to New York available.

12 Assumptions in the analysis include transportation distances of less than 50 mi and accessibility 13 of 50 percent of the forest residues from existing roads.

14 The NRC staff finds that New York has utility-scale wood waste resources, but given 15 uncertainties in supply estimates, as well as the small size and high number of installed facilities 16 necessary to replace IP2 and IP3, the NRC staff does not find wood biomass to be a suitable 17 alternative to IP2 and IP3 operating license renewals. The NRC staff will include wood waste 18 facilities as a contributor to biomass generating capacity in combinations of alternatives 19 addressed in Section 8.3.5 of this SEIS.

20 8.3.4.3 Hydropower 21 New York State receives an abundant supply of hydroelectric power from Niagara Falls and 22 other sites. Hydropower accounts for 5990 MW(e)-or about 15 percent-of the State's 23 generating capacity (NYISO 2008).

24 Studies conducted for the New York State Department of Public Service indicate a potential for 25 2527 MWof hydroelectric power by 2022 (NYSDPS 2009). NYSDPS estimates that 289 MW of 26 hydropower will come online by 2015, based on Renewable Portfolio Standard supply curves.

27 Though the likely potential by 2015 is too little to replace IP2 or IP3, it is sufficient for inclusion in 28 combination alternatives.

29 8.3.4.4 Oil-Fired Generation 30 Oil accounts for about 8 percent of the generating capacity-or 3515 MW( e)-Statewide 31 (NYISO 2008). EIA projects that oil-fired plants will account for very little new generation 32 capacity in the United States during the next 20 years, and higher fuel prices will lead to a 33 decrease in overall oil consumption for electricity generation (DOE/EIA 2007a).

34 EIA no longer addresses oil as a significant contributor to capacity additions (DOE/EIA 2010),

35 as discussed in Section 8.3. The relatively high cost of oil-even prior to 2008's record high 36 prices-had prompted a steady decline for use in electricity generation. The NRC staff has not 37 evaluated oil-fired generation as an alternative to the renewal of the IP2 and IP3 operating 38 licenses, though the NRC staff notes that oil may temporarily be burned in a gas-fired 39 alternative should gas capacity become constrained during winter heating season.

40 8.3.4.5 Solar Power 41 New York has enacted demand-side policies aimed at encouraging the adoption of photovoltaic 42 (PV) technology for residents and businesses. These policies had resulted in the installation of December 2010 8-45 NUREG-1437, Supplement 38 OAGI0001367A_00378

Environmental Impacts of Alternatives to License Renewal 1 more than 1.5 MW(e) of demand-side PV energy as of summer 2005 (National Research 2 Council 2006). Through its Clean Energy Initiative, the Long Island Power Authority had issued 3 rebates for PV systems totaling more than 2.63 MW(e) (National Research Council 2006). The 4 National Research Council indicates that PV systems may be in the economic interests of New 5 York customers because of high retail electricity rates and the falling prices of PV-generated 6 electricity (National Research Council 2006).

7 The National Research Council reported that PV-generated electricity can provide high-value 8 peak-time distributed generation power with minimal environmental emissions, and PV can 9 contribute significantly to grid stability, reliability, and security (National Research Council 2006).

10 Distributed generation refers to the production of electricity at or close to the point of use.

11 Under an aggressive development scenario, the National Research Council estimates that 12 70 MW(e) of distributed PV could be installed in the NYCA by 2010 and 335 MW(e) by 2015.

13 However, the National Research Council states that there would have to be "reductions in PV 14 costs and a long-term commitment to expand New York's PV programs" in order to reach these 15 goals (National Research Council 2006). Finally, the National Research Council considers most 16 of the projected PV distributed generation as demand-side reductions in peak energy demands.

17 Therefore, the energy-saving impacts of solar power are included in the conservation estimates 18 described in Section 8.3.4 of this SEIS.

19 More recently, the NRC staff notes that new solar projects are moving forward in the State, 20 including, for example, a proposed 32 MW(e) facility at Brookhaven National Laboratory and a 21 15 MW(e) facility (with potential to expand to 20 MW(e)) in Coxsackie. Additionally, the New 22 York Power Authority has its own solicitation for 100 MW(e) of photovoltaic power. The New 23 York State Department of Public Service projects that solar photovoltaics will contribute 52.57 24 MW(e) of capacity for the customer-sited tier of the State's Renewable Portfolio Standard by 25 2015 (NYSDPS 2009).

26 The NRC staff does not consider solar power to be a suitable stand-alone alternative to the 27 renewal of the IP2 and IP3 operating licenses, and the capacities being added in New York 28 State are relatively small. The NRC staff does, however, recognize that solar energy is an 29 important component of the NYSERDA demand-side reductions in peak load demands from 30 generating facilities, including IP2 and IP3, as well as a contributor to the Renewable Portfolio 31 Standard. Solar power may contribute to the combination alternatives addressed in Section 32 8.3.5 of this SEIS as a part of the conservation-derived demand reductions (as described in 33 Section 8.3.4), and may support other generation at peak times.

34 8.3.4.6 New Nuclear Generation 35 Given the expressed industry interest in new nuclear construction, the NRC staff has previously 36 evaluated the construction of a new regional nuclear power plant as an alternative to license 37 renewal in SEISs for other nuclear power plant license renewal requests.

38 Given the current combined license (COL) application schedule, the time needed to review an 39 application, and the anticipated length of construction, the NRC staff does not consider the 40 construction and operation of a new nuclear power plant specifically for the purpose of replacing 41 IP2 and IP3 to be a feasible alternative to license renewal at this time.

42 8.3.4.7 Geothermal Energy 43 Geothermal plants are most likely to be sited where hydrothermal reservoirs are prevalent, such NUREG-1437, Supplement 38 8-46 December 2010 OAGI0001367A_00379

Environmental Impacts of Alternatives to License Renewal 1 as in the western continental United States, Alaska, and Hawaii. There are no feasible eastern 2 locations for geothermal capacity to serve as an alternative to IP2 and IP3 (NRC 1996), and the 3 New York Renewable Electricity Profile did not indicate any geothermal energy production in 4 New York in 2007 (DOE/EIA 2009). As such, the NRC staff concludes that geothermal energy 5 would not be a feasible alternative to renewal of the IP2 and IP3 operating licenses.

6 8.3.4.8 Municipal Solid Waste 7 According to the Integrated Waste Services Association (lWSA), fewer than 90 waste-to-energy 8 plants are operating in the United States, generating approximately 2700 MW(e) of electricity or 9 an average of approximately 30 MW(e) per plant (lWSA 2007). The existing net capacity in the 10 region of IP2 and IP3 is 156 MW(e) generated by six plants, while the technical potential within 11 the region is 1096 MW(e) by 2014 (National Research Council 2006). The 2014 estimate 12 includes production from fuels containing municipal solid waste and construction and demolition 13 wood (a portion likely to be at least partially captured in Walsh et al and referenced in the Wood 14 Waste section of 8.3.4).

15 Estimates in the GElS suggest that the overall level of construction impact from a waste-fired 16 plant would be approximately the same as that for a coal-fired plant. Additionally, waste-fired 17 plants have the same or greater operational impacts than coal-fired technologies (including 18 impacts on the aquatic environment, air, and waste disposal). The initial capital costs for 19 municipal solid waste plants are greater than for comparable steam turbine technology at coal 20 facilities or at wood waste facilities because of the need for specialized waste separation and 21 handling equipment.

22 The decision to burn municipal waste to generate energy (waste-to-energy) is usually driven by 23 the need for an alternative to landfills rather than by energy considerations. The use of landfills 24 as a waste disposal option is likely to increase in the near term; with energy prices increasing, 25 however, it is possible that municipal waste combustion facilities may become attractive.

26 Congress has included waste-to-energy in the Production Tax Credit legislation to encourage 27 development of waste-to-energy and other renewable technologies (lWSA 2008).

28 Given the small average installed size of municipal solid waste plants, it would take about 70 29 plants to replace IP2 and IP3. Furthermore, NYSERDA estimates that the Statewide 30 economically achievable potential for summer peak load from municipal solid-waste-derived 31 energy by 2022, well into the relicensing period for IP2 and IP3, is only 190 MW(e) (NYSERDA 32 2003). Therefore, the NRC staff does not consider municipal solid waste combustion to be a 33 feasible alternative to license renewal. Certain types of refuse-derived fuel, however, may 34 qualify for inclusion in New York's Renewable Portfolio Standard (RPS) as biomass to the 35 extent that they make use of renewable waste streams. Staff addresses biomass contributions 36 as part of the combination alternatives.

37 8.3.4.9 Other Biomass Derived Fuels 38 In addition to wood and wood waste fuels, there are several other biomass fuels used for 39 generating electricity. These include burning crops, converting crops to a liquid fuel such as 40 ethanol, gasifying crops, and biogas. Additionally, the National Research Council identifies 41 animal and avian "manure" and wastewater methane as biomass derived fuel sources. The 42 National Research Council estimates that the NYCA has a potential capacity of 41 MW(e) from 43 biogas by 2014 (National Research Council 2006). NYSERDA estimates that the Statewide 44 economically achievable annual load from biomass-derived energy by 2022, well into the December 2010 8-47 NUREG-1437, Supplement 38 OAGI0001367A_00380

Environmental Impacts of Alternatives to License Renewal 1 relicensing period for IP2 and IP3, is 1.7 million MW(h) (NYSERDA 2003) or about 190 MW(e).

2 In the period between 2005 and 2007, IP2 and IP3 produced more than 16 million MW(h) 3 annually (Blake 2008). Furthermore, the New York Renewable Electricity Profile did not 4 indicate any energy production in New York from biomass fuels other than wood and wood 5 waste in 2007 (DOE/EIA 2009), which is considered above. For these reasons, the NRC staff 6 concludes that power generation from biomass fuels alone does not offer a feasible alternative 7 to the renewal of the IP2 and IP3 operating licenses. It will, however, be considered as a 8 portion of a combination alternative grouped with wood waste. NRC staff notes that, under New 9 York's RPS, certain other waste streams, which may include source-separated portions of 10 municipal solid waste, may qualify as biomass. This is distinguished from municipal solid waste 11 in that certain portions of a municipal solid waste stream that may qualify as biomass are 12 segregated from other portions of the municipal solid waste stream prior to further treatment 13 (e.g., gasification) or direct combustion.

14 8.3.4.10 Fuel Cells 15 Fuel cells work by oxidizing fuels without combustion and the accompanying environmental side 16 effects. The only byproducts are heat, water, and, if the fuel is not pure hydrogen, CO 2 .

17 Hydrogen fuel can come from a variety of hydrocarbon resources by subjecting them to steam 18 under pressure. Natural gas is typically used as the source of hydrogen.

19 The only current program that was identified as being initiated by one of the three major power 20 providers in downstate New York is a program being conducted by the New York Power 21 Authority that involves nine fuel cell installations totaling 2.4 MW(e) using waste gas produced 22 from sewage plants (National Research Council 2006).

23 At the present time, fuel cells are not economically or technologically competitive with other 24 alternatives for baseload electricity generation. NYSERDA estimates that the Statewide 25 technical potential for annual supply from fuel cells by 2022 is more than 37 million MW(h);

26 however, NYSERDA indicated that the economical potential for 2022 is zero (NYSERDA 2003).

27 NYSERDA defines economic potential as "that amount of technical potential available at 28 technology costs below the current projected costs of conventional electric generation that these 29 resources would avoid." Therefore, while it may be possible to use a distributed array of fuel 30 cells to provide an alternative to IP2 and IP3, it currently would be prohibitively costly to do so.

31 Since fuel cells are not currently economically feasible on such a large scale, the NRC staff 32 concludes that fuel cell-derived power is not a feasible alternative to the IP2 and IP3 license 33 renewals.

34 8.3.4.11 Delayed Retirement 35 Plants scheduled for retirement are aging and have higher emissions than newer plants.

36 Keeping older plants online may not be technically or economically achievable when emissions 37 controls or necessary environmental mitigation measures are taken into account. Furthermore, 38 given that the demand for electricity is increasing and, in the near term, planned new sources 39 within the NYCA are just keeping pace with retirements, the NRC staff does not consider 40 additional delays in the retirements of existing plants to be a feasible alternative to compensate 41 for the loss of power from IP2 and IP3. In section 8.3.1, however, NRC staff contemplates the 42 repowering of a shutdown or underutilized facility with a natural gas combined-cycle power 43 plant.

44 8.3.4.12 Combined Heat and Power NUREG-1437, Supplement 38 8-48 December 2010 OAGI0001367A_00381

Environmental Impacts of Alternatives to License Renewal 1 In course of preparing this SEIS, the NRC staff has received comments indicating that it should 2 consider combined heat and power (CHP) as an alternative to license renewal. In some cases, 3 these suggestions have also included an indication of the potential that CHP could have, as well 4 as the environmental advantages of CHP applications.

5 CHP facilities provide electrical power as well as heat (often in the form of steam) for use by 6 nearby industries or buildings. CHP installations are commonly found on large industrial 7 facilities or in urban centers where many buildings are near to one another. Modern CHP tends 8 to be efficient, in that CHP systems make effective use of some heat that would be wasted by 9 conventional electrical generation. CHP systems can be designed to produce relatively larger 10 proportions of electrical power or heat depending on existing demands.

11 The NRC staff notes that the current IP2 and IP3 are only used to produce electrical power, and 12 do not supply heat to any offsite users. Combined heat and power, then, fulfills a need not 13 currently met by IP2 and IP3 and is not a direct alternative to IP2 and IP3 license renewal.

14 8.3.4.13 Supercritical Coal-Fired Generation 15 The NRC staff has moved the supercritical coal-fired alternative to this section based on public 16 draft SEIS comments, a staff review of likely generating alternatives in New York State, and 17 policies like the Regional Greenhouse Gas Initiative that all suggest that new coal-fired 18 generation is unlikely in New York State. The discussion of the supercritical coal-fired 19 alternative in this section has not been updated from the draft SEIS.

20 Supercritical coal-fired plants are similar to other coal burners except that they operate at higher 21 temperatures and pressures, which allows for greater thermal efficiency. Supercritical coal-fired 22 boilers are commercially proven and represent an increasing proportion of new coal-fired power 23 plants. In evaluating the supercritical coal-fired alternative, the NRC staff assumed that a new 24 plant located at an alternate site would use a closed-cycle cooling system.

25 Construction of a coal-fired plant at an alternate site may necessitate the acquisition of 26 additional ROWs for new transmission lines and construction of new lines to transmit power.

27 Transmission line and ROW length would vary with distance to suitable existing lines. In 28 addition, construction at an alternate site may necessitate the construction of an appropriate 29 railroad spur (or other transportation infrastructure) for coal and limestone (used in scrubbers to 30 remove sulfur oxides) deliveries.

31 For purposes of this analysis, the NRC staff will rely on data published by EIA indicating that a 32 new, scrubbed coal plant constructed in 2015 will operate at a heat rate of 8661 BTU per 33 kilowatt hour (BTU/kWh) (DOE/EIA 2007b). (This reduces the level of emissions for this 34 alternative when compared to the coal-fired alternative Entergy analyzed in the ER for IP2 and 35 IP3 ER by approximately 15 percent for some impact areas).

36 Impacts of a coal-fired alternative evaluated by the NRC staff assume that the new plant would 37 have a gross electrical capacity of 2200 MW(e). The NRC staff's analysis of the 2200-MW(e) 38 coal-fired plant is based on the factors used to calculate the impacts of the plant that would 39 replace the 2158 MW(e) of power produced by the IP2 and IP3 plants (Entergy 2007). Because 40 up to 10 percent of gross generation may be consumed on site by the coal-fired plant (or its 41 pollution control equipment), the NRC staff's evaluation of a 2200-MW(e) plant may actually 42 slightly understate impacts from this alternative. This ensures, however, that impact levels for 43 alternatives are not overstated when compared to the proposed action.

December 2010 8-49 NUREG-1437, Supplement 38 OAGI0001367A_00382

Environmental Impacts of Alternatives to License Renewal 1 The NRC staff will present most impacts on an annualized basis. While the renewal period for 2 the IP2 and IP3 operating licenses is only 20 years, the operating lifespan for a new coal-fired 3 plant is likely closer to 40 years, and may even be longer given the lifespans of some existing 4 coal-fired plants. Most impacts will be independent of plant lifespan, though total land area 5 used for waste disposal, for example, will be larger after 40 years than after 20 years. Where 6 these differences exist, the NRC staff will identify them.

7 For replacing IP2 and IP3, the NRC evaluated an alternative that would use four 550-MW(e)-net 8 coal-fired units to replace the power output of IP2 and IP3. Advanced coal and conventional 9 combined-cycle coal plants could operate at even greater efficiencies (about 7477 and 6866 10 BTU/kWh, respectively, or greater) by 2015 (DOE/EIA 2007b).

11 The supercritical coal-fired plant, with a gross output of about 2200 MW(e), would consume 12 approximately 4.9 million metric tons (MT) (5.4 million tons) per year of pulverized bituminous 13 coal with an ash content of approximately 7.11 percent and sulfur content of 1.12 percent 14 (based on New York coal consumption) (DOE/EIA 2001). The NRC staff assumed a capacity 15 factor of 0.85 for the supercritical coal-fired alternative.

16 Based on Table 8-1 of the GElS, a pulverized coal-fired facility requires approximately 0.7 ha 17 (1.7 ac) of land per MW of generating capacity. Based on this relationship, a 1540-ha (3805-ac) 18 site would be needed to replace the nuclear power output of IP2 and IP3 with an equivalent 19 capacity coal-fired facility. In more recent SEIS documents, however, the NRC staff indicated 20 that smaller quantities of land may be sufficient to construct coal-fired facilities based on land 21 use at existing coal-fired power plants. Because the existing IP2 and IP3 site includes only 239 22 ac (97 ha), and much of the area is occupied by plant structures, the NRC staff concludes that 23 there is not sufficient land area at the IP2 and IP3 site to support operations of the alternative.

24 Thus, the coal-fired alternative is analyzed only for an unspecified alternate site. It should be 25 noted that several of the newer coal utilization technologies (e.g., coal-fired integrated 26 gasification combined-cycle systems) could be accommodated on smaller sites than would the 27 conventional pulverized coal concept evaluated here, but likely not a site as small as the IP2 28 and IP3 site.

29 The overall impacts of the coal-fired generating facility are discussed in the following sections 30 and summarized in Table 8-3, at the end of Section 8.3.1 of this SEIS. The implications of 31 constructing a new coal-fired plant at an alternate site will depend on the actual location and 32 characteristics of that site. For purposes of this section, the NRC staff assumes that a coal-fired 33 plant located at an alternate site would require the construction of a new transmission line to 34 connect that plant to the regional transmission grid.

35 Land Use 36 In the GElS, the NRC staff estimated that about 0.7 ha (1.7 ac) of land are needed per MW(e) 37 for the construction and operation of a coal-fired power plant. Constructing a 2200-MW(e) coal-38 fired facility would take approximately 1540 ha (3805 ac). In more recent SEIS documents, the 39 NRC staff indicated that smaller quantities of land may be sufficient to construct coal-fired 40 facilities based on land use at existing coal-fired power plants. A 2200-MW(e) facility may be 41 able to fit on a site with several hundred acres of land rather than the 1540 ha (3805ac) 42 indicated in the GElS.

43 Committing land resources to a new coal-fired plant could result in the loss of wildlife habitat or NUREG-1437, Supplement 38 8-50 December 2010 OAGI0001367A_00383

Environmental Impacts of Alternatives to License Renewal 1 agricultural land. The potential need for new transmission line corridors and ROWs also drive 2 land use effects for the coal-fired facility. As a result of the substantial site area that would be 3 dedicated to and disrupted by coal-fired operations, the NRC staff views this alternative as 4 having potentially MODERATE land use impacts from construction.

5 Additionally, for the coal-fired alternative, land use changes would occur at an undetermined 6 coal mining area where approximately 75 square miles (sq mi) (19,400 ha) would be affected for 7 mining coal and disposing of mining wastes to support a 2200-MW(e) coal-fired power plant (the 8 GElS estimates that approximately 34 sq mi (8800 ha) would be disturbed for a 1000-MW(e) 9 coal-fired plant (NRC 1996). Offsite land use for coal mining would partially be offset by the 10 elimination of the need for offsite uranium mining. In the GElS, the NRC staff estimated that 11 approximately 405 ha (1000 ac) would be affected for mining the uranium and processing it 12 during the operating life of a 1000-MW(e) nuclear power plant (NRC 1996). Therefore the 13 uranium mining offset for a 2200-MW(e) facility would be approximately 890 ha (2,200 ac) of 14 the 19,400 ha required for the coal-fired alternative, resulting in a net requirement of 15 approximately 18,500 ha (45,700 ac). Impacts from the coal fuel cycle would add to the already 16 MODERATE impacts from plant construction.

17 A coal-fired alternative would likely receive coal and limestone by rail. The coal-fired option 18 would require approximately 10.4 coal unit trains per week (assuming each train has 100 cars 19 with 100 tons of coal per car). For an undeveloped site, a new rail spur would be necessary.

20 For an existing industrial site, a rail spur may exist but could require improvements to handle 21 these deliveries. Impacts from improving an existing rail spur would be small, as the area is 22 already disturbed and used for industrial purposes. Installing a new rail spur could result in 23 relatively minor impacts depending on the length of the rail spur.

24 Overall, impacts to land use from construction of the coal-fired alternative and its fuel cycle 25 would be MODERATE to LARGE.

26 Ecology 27 Siting a coal-fired plant at an alternate site would introduce construction and operating impacts.

28 Converting as much as 1500 ha (3700 ac) of land to industrial use (generating facilities, coal 29 storage, ash and scrubber sludge disposal) could significantly alter terrestrial ecological 30 resources and could affect aquatic ecological resources. Construction and maintenance of a 31 transmission line and rail spur would incrementally add to the terrestrial ecological impacts.

32 Impacts to terrestrial ecology from coal mining also could be substantial, though terrestrial 33 ecology at many coal mining sites has already been disturbed. Therefore, the NRC staff 34 concludes that the impact to terrestrial ecology would be MODERATE to LARGE, depending 35 largely on the ecological sensitivity of the plant and mine sites.

36 Use of surface water resources to provide makeup water for a closed-cycle cooling system 37 would have some impact on local aquatic resources. Aquatic impacts of a supercritical coal-38 fired alternative would likely be similar to the impacts of the proposed closed-cycle cooling 39 system proposed for the existing nuclear reactors described in Section 8.1.1 of this SEIS. The 40 supercritical coal-fired power plant's greater thermal efficiency-when compared to the existing 41 IP2 and IP3-would result in smaller impacts, while the coal-fired alternative has greater 42 potential for deposition of pollutants or runoff from coal, ash, or scrubber waste areas. On the 43 whole, the level of impact would be similar. Therefore, the NRC staff concludes that the impact 44 to aquatic ecology would be SMALL.

December 2010 8-51 NUREG-1437, Supplement 38 OAGI0001367A_00384

Environmental Impacts of Alternatives to License Renewal 1 Due primarily to the potential effects on terrestrial ecology, the NRC staff concludes that the 2 overall impacts of this alternative would be MODERATE to LARGE.

3 Water Use and Quality 4 For coal-fired operations at an alternate site, impacts to surface waters would result from 5 withdrawal of water for various operating needs of the facility. These operating needs would 6 include cooling tower makeup and possibly auxiliary cooling for equipment and potable water 7 requirements. Discharges to surface water could result from cooling tower blowdown, coal pile 8 runoff, and runoff from coal ash and scrubber byproduct disposal areas. Both the use of surface 9 waters and discharges to surface waters would be regulated by the State within which the coal-10 fired facility is located.

11 The NRC staff expects that any new coal-fired facility would comply with requirements of the 12 discharge permits issued for its operation. Thus, the utility would be obligated to ensure that 13 discharges from the plant conform to applicable water quality standards. Water withdrawals 14 from a small river or cooling pond, however, could lead to potential water use conflicts. Overall, 15 the NRC staff concludes that the potential impacts to surface water resources and water quality 16 would be SMALL to MODERATE for a new coal-fired facility located at an alternate site.

17 Potential impacts to ground water quality at an alternate site may occur as a result of seepage 18 to ground water from coal storage areas and onsite ash and scrubber sludge disposal areas.

19 However, a coal-fired plant of this size is unlikely to use ground water for cooling tower makeup.

20 In all cases, the NRC staff expects that a coal-fired facility would comply with a ground water 21 use and discharge permit issued by the State having jurisdiction over the plant. Complying with 22 permit requirements should ensure a small impact. Therefore, the NRC staff concludes that the 23 potential impacts to water resources would be SMALL to MODERATE.

24 Air Quality 25 A coal-fired power plant emits a variety of airborne emissions, including SOx, NOx, particulate 26 matter, carbon monoxide (CO), hazardous air pollutants (HAPs) (e.g., mercury), and naturally 27 occurring radioactive materials.

28 A coal-fired alternative built in a nonattainment area (such as exists at the current IP2 and IP3 29 site) would require a nonattainment area permit and a Title V operating permit under the CAA.

30 A new power plant would also be subject to the new source performance standards for such 31 units in Subpart DA, "Standards of Performance for Electric Utility Steam Generating Units for 32 Which Construction Is Commenced after September 18, 1978," of 40 CFR Part 60, "Standards 33 of Performance for New Stationary Sources." These regulations establish emission limits for 34 particulates, opacity, sulfur dioxide (S02), and NOx. EPA has various regulatory requirements 35 for visibility protection in Subpart P, "Protection of Visibility," of 40 CFR Part 51, "Requirements 36 for Preparation, Adoption, and Submittal of Implementation Plans," including a specific 37 requirement for review of any new major stationary source in an area designated attainment or 38 unclassified under the CAA.

39 NRC discussions of SOx and NOx emissions include the most recent relevant regulations, 40 because the Clean Air Interstate Rule (CAIR) was vacated by the D.C. Circuit Court in July of 41 2008. On September 24,2008, EPA filed for a rehearing of the D.C. Circuit Court decision.

42 Until EPA, Congress, or the courts act, elements of future SOx and NOx regulatory approaches NUREG-1437, Supplement 38 8-52 December 2010 OAGI0001367A_00385

Environmental Impacts of Alternatives to License Renewal 1 remain uncertain.

2 Emissions of specific pollutants from coal-fired alternatives are as follows:

3 Sulfur oxides emissions. The NRC staff calculates that a new coal-fired power plant would emit 4 5236 MT/yr (5767 tons/yr) of SOx after limestone-based scrubbers remove approximately 99 5 percent of sulfur compounds from plant exhaust. This plant would be subject to the 6 requirements in Title IV of the CAA. Title IV was enacted to reduce emissions of SOx and NOx, 7 the two principal precursors of acid rain, by restricting emissions of these pollutants from power 8 plants. Title IV caps aggregate annual power plant SOx emissions and imposes controls on SOx 9 emissions through a system of marketable allowances. EPA issues one allowance for each ton 10 of SOx that a unit is allowed to emit.

11 New units do not receive allowances but are required to have allowances to cover their SOx 12 emissions. Owners of new units must, therefore, acquire allowances from owners of other 13 power plants or reduce SOx emissions at other power plants they own. Allowances can be 14 banked for use in future years. Thus, a new coal-fired power plant would not add to net regional 15 SOx emissions, although it might contribute to the local SOx burden.

16 Nitrogen oxides emissions. Title IV of the CAA directed EPA to establish technology-based 17 emission limitations for NOx emissions (see Section 407), rather than a market-based allowance 18 system as is used for SOx emissions. A new coal-fired power plant would be subject to the new 19 source performance standards for such plants in 40 CFR 60.44a(d)(1). That regulation, issued 20 September 16, 1998 (Volume 63, page 49453 of the Federal Register (63 FR 49453)), limits the 21 discharge of any gases that contain nitrogen oxides (expressed as nitrogen dioxide (N02 )) to 22 200 nanograms per joule of gross energy output (1.6 pound/megawatt-hour (MW(h)), based on 23 a 30-day rolling average.

24 As previously discussed, IP2 and IP3 are located within the New Jersey-New York-Connecticut 25 Interstate Air Quality Control Region (40 CFR 81.13). All of the States of New Jersey and 26 Connecticut, as well as several counties in Central and Southeastern New York within a 80-km 27 (50-mi) radius of IP2 and IP3, are designated as nonattainment areas for ozone (8-hour 28 standard) (EPA 2008b). Operators or owners of a coal-fired power plant constructed in a 29 nonattainment area would need to purchase offsets for ozone precursor emissions. In this 30 case, NOx is the major ozone precursor emitted by a coal-fired power plant. In accordance with 31 NYSDEC regulations, "Emission offsets must exceed the net increase in annual actual 32 emissions from the air contamination source project" (NYSDEC, Chapter 3, Parts 231-15). By 33 design, this regulatory requirement should result in a net reduction in ozone emissions in the 34 region.

35 This new coal-fired plant would likely use a variety of NOx control technologies, including low-36 NOx burners, overfire air, and selective catalytic reduction. EPA notes that when these 37 emissions controls are used in concert, they can reduce NOx emissions by up to 95 percent 38 (EPA 1998), for total annual emissions of approximately 1230 MT/yr (1355 tons/yr) or 39 0.14 pounds/MW(h). This is significantly less than the amount allowed by Title IV of the CAA.

40 Particulate emissions. The NRC staff estimates that the total annual stack emissions would 41 include 175 MT (192 tons) of total suspended particulates and 40 MT (44 tons) of particulate 42 matter having an aerodynamic diameter less than or equal to 10 IJm (PM 1O) (40 CFR 50.6, 43 "National Primary and Secondary Ambient Air Quality Standards for PM 1O "). Some of this PM 10 44 would also be classified as primary PM 2 .5 .

December 2010 8-53 NUREG-1437, Supplement 38 OAGI0001367A_00386

Environmental Impacts of Alternatives to License Renewal 1 As indicated in the IP2 and IP3 ER, fabric filters or electrostatic precipitators would be used for 2 particulate control. EPA notes that filters or precipitators are each capable of removing more 3 than 99 percent of particulate matter, and that S02 scrubbers further reduce particulate matter 4 emissions (EPA 1998). In addition to flue emissions, coal-handling equipment would introduce 5 fugitive particulate emissions from coal piles, reclamation equipment, conveyors, and other 6 sources.

7 Fugitive dust also would be generated during the construction of a coal-fired plant, and 8 construction vehicles and motorized equipment would further contribute to construction-phase 9 air emissions. These emissions would be short lived and intermittent, and construction crews 10 would likely mitigate some impacts through dust control measures.

11 Carbon monoxide emissions. The NRC staff estimates that the total CO emissions from coal 12 combustion would be approximately 1230 MT/yr (1354 tons/yr) based on EPA-calculated 13 emissions factors for coal-fired power plants.

14 Hazardous air pollutants including mercury. Following the D.C. Circuit Court's February 8, 15 2008, ruling that vacated its Clean Air Mercury Rule (CAMR), EPA is working to evaluate how 16 the court's ruling will affect mercury regulation (EPA 2008d). Before CAMR, EPA determined 17 that coal- and oil-fired electric utility steam-generating units are significant emitters of HAPs 18 (EPA 2000a). EPA determined that coal plants emit arsenic, beryllium, cadmium, chromium, 19 dioxins, hydrogen chloride, hydrogen fluoride, lead, manganese, and mercury (EPA 2000a).

20 EPA concluded that mercury is the HAP of greatest concern and that (1) a link exists between 21 coal combustion and mercury emissions, (2) electric utility steam-generating units are the 22 largest domestic source of mercury emissions, and (3) certain segments of the U.S population 23 (e.g., the developing fetus and subsistence fish-eating populations) are believed to be at 24 potential risk of adverse health effects resulting from mercury exposures caused by the 25 consumption of contaminated fish (EPA 2000a). In light of the recent court decision, EPA will 26 revisit mercury regulation, although it is possible that the agency will continue to regulate 27 mercury as a HAP, thus requiring the use of best available control technology to prevent its 28 release to the environment.

29 Uranium and thorium. Coal contains uranium and thorium, among other naturally occurring 30 elements. According to Alex Gabbard of Oak Ridge National Laboratory, uranium 31 concentrations are generally in the range of 1 to 10 parts per million (ppm), and thorium 32 concentrations are generally about 2.5 times this level (Gabbard 1993). The U.S. Geological 33 Survey (USGS) indicates that Western and Illinois Basin coals contain uranium and thorium at 34 roughly equal concentrations, mostly between 1 and 4 ppm, but also indicates that some coals 35 may contain concentrations of both elements as high as 20 ppm (USGS 1997). Gabbard 36 indicates that a 1000-MW(e) coal-fired plant could release roughly 4.7 MT (5.2 tons) of uranium 37 and 11.6 MT (12.8 tons) of thorium to the atmosphere each year (Gabbard 1993).

38 Both USGS and Gabbard, however, indicate that almost all of the uranium, thorium, and most 39 decay products remain in solid coal wastes, especially in the fine glass spheres that constitute 40 much of coal's fly ash. Modern emissions controls, such as those included for this coal-fired 41 alternative, allow for recovery of greater than 99 percent of these solid wastes (EPA 1998), thus 42 retaining most of coal's radioactive elements in solid form rather than releasing it to the 43 atmosphere. Even after concentration in coal waste, the level of radioactive elements remains 44 relatively low-typically 10 to 100 ppm-and consistent with levels found in naturally occurring NUREG-1437, Supplement 38 8-54 December 2010 OAGI0001367A_00387

Environmental Impacts of Alternatives to License Renewal 1 granite rocks, shales, and phosphate rocks (USGS 1997). The levels of uranium and thorium 2 contained in coal wastes and discharged to the environment exceed the levels of uranium and 3 thorium released to the environment by IP2 and IP3.

4 Carbon dioxide: A coal-fired plant would have unregulated CO2 emissions that could contribute 5 to global warming. Under the current regulatory framework, a coal-fired plant would have 6 unregulated CO2 emissions during operations as well as during coal mining and processing, and 7 coal and lime transportation. Burning bituminous coal in the United States emits roughly 93.3 8 kg (205.3 pounds) of CO 2 per million BTU (DOE/EIA 2008a). The four-unit 2200-MW(e) 9 supercritical coal-fired plant would emit approximately 13.1 million MT (14.4 million tons) of CO 2 10 per year assuming a heat rate of 8661 BTU/kWh (DOE/EIA 2007b). Section 6.2 of this SEIS 11 contains a discussion of current and likely future relative greenhouse gas (GHG) emissions from 12 several energy alternatives, including coal, natural gas, nuclear, and renewables. In Section 13 6.2, the NRC staff found that GHG emissions from coal would likely exceed those from other 14 energy alternatives throughout the period of extended operation.

15 Visibility Regulations: Section 169A of the CAA (42 USC 7491) establishes a national goal of 16 preventing future and remedying existing impairment of visibility in mandatory Class I Federal 17 areas when impairment results from manmade air pollution. EPA issued a new regional haze 18 rule in 1999 (64 FR 35714). The rule specifies that for each mandatory Class I Federal area 19 located within a State, the State must establish goals that provide for reasonable progress 20 towards achieving natural visibility conditions. The reasonable progress goals must provide for 21 an improvement in visibility for the most-impaired days over the period of the implementation 22 plan and ensure no degradation in visibility for the least-impaired days over the same period 23 (40 CFR 51.308(d)(1)). If a coal-fired alternative were located close to a mandatory Class I 24 area, additional air pollution control requirements would be imposed. New York has no Class I 25 areas; of the neighboring States, New Jersey and Vermont each have one-the Brigantine 26 Wilderness Area and the Lye Brook Wilderness, respectively. Brigantine is located about 225 27 km (140 mi) south of IP2 and IP3, while Lye Brook is roughly 215 km (134 mi) north-northeast.

28 A coal-fired alternative located near these areas or any other Class I area may need additional 29 pollution controls to keep from impairing visibility.

30 Summary. The GElS analysis did not quantify emissions from coal-fired power plants, but 31 implied that air impacts would be substantial. The GElS also mentioned global warming from 32 unregulated CO2 emissions and acid rain from SOx and NOx emissions as potential impacts 33 (NRC 1996). The NRC staff's analysis shows that emissions of air pollutants, including SOx, 34 NOx, and CO, would be significant and would be greater than all other alternatives. Operational 35 emissions of CO 2 are also greater under the coal-fired alternative than under any other 36 alternative.

37 The NRC analysis for a coal-fired alternative at an alternative site indicates that impacts from 38 the coal-fired alternative would have clearly noticeable effects, but given existing regulatory 39 regimes, permit requirements, and emissions controls, the coal-fired alternative would not 40 destabilize air quality. Thus, the appropriate characterization of air impacts from coal-fired 41 generation would be MODERATE.

42 Waste 43 A four-unit, 2220-MW(e) coal-fired plant with a heat rate of 8661 BTU/kWh (DOE/EIA 2007b) 44 would annually consume approximately 5.4 million tons of coal having an ash content of December 2010 8-55 NUREG-1437, Supplement 38 OAGI0001367A_00388

Environmental Impacts of Alternatives to License Renewal 1 7.11 percent (Entergy 2007). After combustion, 99.9 percent of this ash, approximately 348,600 2 MT (384,000 tons) per year, would be collected and disposed of at either an onsite or offsite 3 landfill, or recycled. Based on industry-average recycling rates, approximately 155,610 MT 4 (171,000 tons), or 45 percent, of the ash content would be recycled, leaving a total of 5 approximately 192,290 MT (209,000 tons) for disposal (ACAA 2007). In addition, approximately 6 300,300 MT (330,000 tons) of scrubber waste would be disposed of or recycled each year.

7 Based on industry-average recycling rates, approximately 237,000 MT (261,000), or 79 percent, 8 of gypsum scrubber waste would be recycled (ACAA 2007). As mentioned in the Air Quality 9 section, this waste also would contain levels of uranium and thorium in concentrations similar to 10 those found in naturally occurring granites, shales, and phosphate rocks (USGS 1997). In 11 addition to coal combustion wastes, a supercritical coal-fired alternative also would produce 12 small amounts of domestic and hazardous wastes.

13 Disposal of the waste could noticeably affect land use and ground water quality, but with 14 appropriate management and monitoring, it would not destabilize any resources. After closure 15 of the waste site and revegetation, the land could be available for other uses.

16 In May 2000, EPA issued a "Notice of Regulatory Determination on Wastes from the 17 Combustion of Fossil Fuels" (EPA 2000b). EPA concluded that some form of national 18 regulation is warranted to address coal combustion waste products because (1) the composition 19 of these wastes could present danger to human health and the environment under certain 20 conditions, (2) EPA has identified 11 documented cases of proven damages to human health 21 and the environment by improper management of these wastes in landfills and surface 22 impoundments, (3) disposal practices are such that, in 1995, these wastes were being managed 23 in 40 to 70 percent of landfills and surface impoundments without reasonable controls in place, 24 particularly in the area of ground water monitoring, and (4) EPA identified gaps in State 25 oversight of coal combustion wastes. Accordingly, EPA announced its intention to issue 26 regulations for disposal of coal combustion waste under Subtitle D of the Resource 27 Conservation and Recovery Act (RCRA). EPA has not yet issued these regulations.

28 In addition to the waste streams generated during plant operations, considerable debris would 29 be generated during construction of a coal-fired facility. Crews would likely dispose of land-30 clearing debris on site.

31 For all of the preceding reasons, the NRC staff considers the impacts of managing waste 32 generated by a coal facility (construction and operating phases) to be MODERATE-the 33 impacts would be clearly noticeable, but would likely not destabilize any important resource.

34 Human Health 35 Coal-fired power generation introduces risks to workers at many points in the fuel cycle. These 36 risks include risks from mining coal and limestone, transportation of raw materials, plant 37 construction and operation, and waste management. There also may be public health risks 38 from a coal-fired plant's operation (routine emissions and coal-pile fires) and fuel cycle (mining 39 and transportation).

40 During construction activities there would be risk to workers from typical industrial incidents and 41 accidents. Accidental injuries are not uncommon in the construction industry and accidents 42 resulting in fatalities do occur. However, the occurrence of such events is mitigated by the use 43 of proper industrial hygiene practices, complying with worker safety requirements, and training.

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Environmental Impacts of Alternatives to License Renewal 1 Occupational and public health impacts during construction are expected to be controlled by 2 continued application of accepted industrial hygiene protocols, occupational health and safety 3 controls, and radiation protection practices.

4 In the GElS, the NRC staff stated that human health impacts (cancer and emphysema) could 5 arise from chronic exposures to coal-fired plant emissions. Emissions contain pollutants such 6 as toxins, particulates, and low levels of naturally occurring radioactive elements. However, 7 Federal and/or State agencies regulate these emissions and enforce emissions standards that 8 are designed to be protective of human health. As a result, power plants install appropriate 9 emission controls to meet regulatory standards.

10 Coal-fired generation would introduce mechanical sources of noise that would be audible off 11 site. Sources contributing to total noise produced by plant operations are both continuous and 12 intermittent. Continuous sources include the mechanical equipment associated with normal 13 plant operations. Intermittent sources include the coal-handling equipment, solid-waste disposal 14 systems, outside loudspeakers, and commuting activities of plant employees. Noise impacts 15 associated with rail delivery of coal and lime to the generating station site would be most 16 significant for residents living along the new rail spur leading to the plant. Although passing 17 trains significantly raise noise levels near rail corridors, the short duration of the noise tends to 18 minimize impacts.

19 Based on the cumulative potential impacts of construction activities, emissions, and noise on 20 human health, the NRC staff considers the impact of constructing and operating a new coal-21 fired facility to be MODERATE.

22 Socioeconomics 23 Construction of a coal-fired facility at an alternate site would take approximately 4 years 24 (DOE/EIA 2007b). Based on estimates given in Table 8.1 of the GElS, the peak workforce is 25 estimated to range from 1.2 to 2.5 additional workers per MW( e) during the construction period.

26 For the 2200-MW(e) plant utilized in this analysis, the peak workforce would range from 27 approximately 2640 to as many as 5500 workers during the 4-year construction period (NRC 28 1996). During construction, the surrounding communities would experience demands on 29 housing and public services unless some of the workforce is composed of local residents. In 30 the GElS, the NRC staff stated that socioeconomic impacts would depend on the location of the 31 new plant. For example, at a rural site more of the peak construction workforce would need to 32 relocate (temporarily or permanently) to the area to work. Therefore, socioeconomic impacts 33 could range from SMALL to LARGE depending on whether workers would relocate to be near 34 the site, as well as depending on the size and makeup of the existing community.

35 At the end of construction, the local population would be affected by the loss of as many as 36 5000 construction jobs. However, this loss would be partially offset by a postconstruction 37 permanent employment rate of 0.25 workers per MW(e) based on Table 8.2 of the GElS, or a 38 total of 550 total workers. An additional construction workforce would be needed for the 39 decommissioning of IP2 and IP3 which could temporarily offset the impacts of the lost 40 construction and IP2 and IP3 jobs at the site.

41 The coal-fired plant would provide new tax revenue to its community. Because this plant would 42 be located in another community, it would have a positive impact on its community while the 43 shutdown of IP2 and IP3 will have a negative impact on the tax base of the IP2 and IP3 December 2010 8-57 NUREG-1437, Supplement 38 OAGI0001367A_00390

Environmental Impacts of Alternatives to License Renewal 1 community.

2 The NRC staff concludes that the overall socioeconomic impacts of changes in the local 3 population from the influx of the construction workforce and changes to community tax revenues 4 could be SMALL to LARGE during construction and SMALL to MODERATE during operation, 5 depending on the size and economic structure of the affected communities.

6 Transportation 7 During the 4-year construction period of the coal-fired unit, as many as 2640 to 5500 8 construction workers may be working at the site. During this same time period, trucks and trains 9 would likely be delivering construction materials to the site. The addition of these workers would 10 increase traffic on highways and local roads that lead to the construction site. The impact of this 11 additional traffic could have a MODERATE to LARGE impact on nearby roadways, particularly if 12 the alternate site is in a rural area. Impacts associated with plant operating personnel 13 commuting to work are likely to be SMALL.

14 For rail transportation of coal and limestone to the alternate site, impacts are likely to range from 15 SMALL to LARGE, depending on local rail characteristics. On average, more than ten 100-car 16 trains per week would deliver coal to the new generating station, and two 10-car trains per week 17 would deliver limestone to the facility. Transportation impacts associated with coal and 18 limestone delivery could range from SMALL to LARGE 19 Overall, transportation impacts could range from MODERATE to LARGE during construction, 20 and SMALL to LARGE during operation.

21 Aesthetics 22 At an alternate site, plant buildings, exhaust stacks, cooling towers, and cooling tower plumes 23 would create aesthetic impacts. The coal-fired alternative's four power plant units would be up 24 to 200 ft (61 m) tall and may be visible off site in daylight hours. The three exhaust stacks could 25 be up to 600 ft (183 m) high (at least 500 ft (152 m) for good engineering practice). If the coal-26 fired alternative makes use of natural-draft cooling towers, then additional visual impacts will 27 occur from the towers, which may be several hundred feet tall and topped with condensate 28 plumes. Mechanical-draft towers would also generate condensate plumes, but would be 29 markedly shorter than natural-draft towers (or they may use hybrid towers like the alternative 30 described in Section 8.1 of this SEIS). Other buildings on site may also affect aesthetics, as 31 could construction of new transmission lines. Noise and light from plant operations, as well as 32 lighting on plant structures, may be detectable off site.

33 Aesthetic impacts at the plant site would be minimized if the plant were located in an industrial 34 area adjacent to other power plants or industrial facilities. Development of a new coal-fired 35 facility at an undeveloped alternate site, however, would entail construction of a new 36 transmission line and a new rail spur to bring coal and lime to the plant. The rail spur and 37 transmission line could extend many miles from the site to tie-in points with existing rail and 38 transmission systems. The visual intrusion of these two linear elements, particularly the 39 transmission line, could be significant.

40 Overall the aesthetic impacts associated with locating at an alternate site would be categorized 41 as MODERATE to LARGE for an undeveloped site, and may be SMALL to MODERATE at a 42 site previously developed for industrial uses.

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Environmental Impacts of Alternatives to License Renewal 1 Historic and Archeological Resources 2 A cultural resource inventory would be needed for any property that has not been previously 3 surveyed. The survey would include an inventory of field cultural resources, identification and 4 recording of existing historic and archeological resources, and possible mitigation of adverse 5 effects from subsequent ground-disturbing actions related to physical expansion of the plant 6 site. The studies would likely be needed for all areas of potential disturbance at the proposed 7 plant site and along associated corridors where new construction would occur (e.g., roads, 8 transmission corridors, rail lines, or other ROWs).

9 Historic and archeological resource impacts can generally be effectively managed and, as such, 10 would be considered SMALL to MODERATE at a new undeveloped site, depending on the 11 sensitivity of the site. For a previously developed site, most of which have already been 12 intensively developed, impact on cultural and historic resources would also be SMALL.

13 Previous development would likely have either removed items of archeological interest or may 14 have included a survey for sensitive resources. Any significant resources identified would have 15 to be handled in accordance with the NHPA.

16 Environmental Justice 17 As described in Section 8.2 of this SEIS, no environmental impacts were identified that would 18 result in disproportionately high and adverse environmental impacts on minority and low-income 19 populations if IP2 and IP3 were shut down.

20 Impacts at the location of the new four-unit coal-fired plant would depend upon the site chosen 21 and the nearby population distribution, but would likely be SMALL to MODERATE for most 22 alternate sites, but could reach LARGE. For previously developed industrial sites, impacts 23 could be larger or smaller, depending on the relative proximity of low-income populations.

24 25 8.3.5 Combinations of Alternatives 26 Even though many individual alternatives to license renewal might not be sufficient on their own 27 to replace the 2158-MW(e) total capacity of the IP2 and IP3 units because of the lack of 28 resource availability, technical maturity, or regulatory barriers, it is conceivable that a 29 combination of alternatives might be sufficient. Such alternatives may also include the 30 continued operation of either IP2 or IP3 combined with other alternatives.

31 There are many possible combinations of alternatives that could be considered to replace the 32 power generated by IP2 and IP3. In the GElS, NRC staff indicated that consideration of 33 alternatives would be limited to single, discrete generating options, given the virtually unlimited 34 number of combinations available. In this section, the NRC staff examines two possible 35 combinations of alternatives, considering, among others, the work of Levitan and Associates 36 (2005) and the National Research Council (2006) have all addressed combinations of 37 alternatives. The National Research Council (2006) noted, for example, that "... the additional 38 2 gigawatts (GWs) required if IP2 and IP3 were to be closed could be met by some suitable 39 combination of new generation in the New York City area, efficiency improvements and 40 demand-side management, and new transmission capability from upstate." Information 41 available since the publication of the draft SEIS provides additional insight into renewal energy 42 capability and potential transmission options.

December 2010 8-59 NUREG-1437, Supplement 38 I OAGI0001367A_00392

Environmental Impacts of Alternatives to License Renewal 1 The NRC staff presents two possible combinations based partly on analysis by the National 2 Research Council and in part on comments received on the draft SEIS. In one of these 3 combinations, the NRC has included the continued operation of either IP2 or IP3. The second 4 combination considers several alternatives as a complete replacement of IP2 and IP3. The 5 second combination is based entirely on new generation, efficiency improvements or demand-6 side management Uointly addressed as conservation), and assumes the availability of 7 transmission capacity to carry power from upstate. These combinations include several 8 alternatives that the NRC staff found to be unsuitable for replacing the entirety of IP2 and IP3 9 electrical capacity. The NRC staff notes that an infinite number of potential combination 10 alternatives exists, based on varying the amounts or types of power generation employed or 11 varying the extent to which alternatives rely on energy conservation. It is not possible to 12 consider all such combinations. Rather, the NRC staff selected the following alternatives based 13 on available research and input from the draft SEIS comment process. They represent, in the 14 staff's judgment, reasonable examples of combinations based upon comments received, 15 ongoing State-level programs, and resource availability in New York State. The staff notes that 16 none of these combinations are intended to place a limit on available resource capacities, nor 17 are they intended to supplant State or utility level policy decisions about how to generate 18 electricity, reduce or add to loads, set prices, or promote different approaches to generating 19 electricity or managing loads.

20 Combination Alternative 1 21

• continued operation of either IP2 or IP3 22

• obtaining 600 MW(e) from renewable energy sources (primarily wind with smaller 23 amounts of hydropower, biomass, and possibly landfill gas; assumes that sufficient 24 hydropower, biomass, and landfill gas capacity exists to compensate for wind power 25 intermittency) 26

• implementing 600 MW(e) of conservation programs based on the State's "15x15" energy 27 conservation program and other efforts to improve energy efficiency or increase 28 conservation 29 Combination Alternative 2 30

• repowering an existing fossil-powered plant in downstate New York with a new 400-31 MW(e) to 600 MW(e) combined-cycle power plant (the plant could also be located at the 32 Indian Point site) 33

• obtaining 600 MW(e) from renewable energy sources (primarily wind, biomass, new 34 hydropower, and landfill gas) 35

• implementing 1000 to 1200 MW(e) of conservation programs 36 37 The following sections analyze the impacts of the two combination alternatives outlined above.

38 In some cases, detailed impact analyses for similar actions are described in previous sections of 39 this Chapter. When this occurs, the impacts of the combined alternatives are discussed in a 40 general manner with reference to other sections of this SEIS. A summary of the impacts from NUREG-1437, Supplement 38 8-60 December 2010 OAGI0001367A_00393

Environmental Impacts of Alternatives to License Renewal 1 the two combined alternative options is presented in Table 8-5.

2 8.3.5.1 Impacts of Combination Alternative 1 3 Each component of the first combination alternative produces different environmental impacts, 4 though several of the options would have impacts similar to-but smaller than-alternatives 5 already addressed in this SEIS. If NYSDEC requires cooling towers, then constructing closed-6 cycle cooling for one of the existing Indian Point generating units (either IP2 or IP3) would 7 create impacts roughly equal to half of the impacts addressed in 8.1.1 (slightly larger impacts in 8 land use and historical and archaeological resources if IP3 continues to operate as the 9 Algonquin pipeline only needs to be rerouted for the IP3 proposed tower, and Entergy's Phase 10 1b study identified historic and archaeological resources near the IP3 tower site; potentially 11 larger waste disposal or human health impacts for the IP2 tower as the potential for 12 contaminated blasting spoils and groundwater is greater in that area). Continued operations of 13 either IP2 or IP3 would incur roughly half the impacts of continued operations described in 14 Chapters 3,4, and 6. (Decommissioning impacts, as described in Chapter 7 of this SEIS, as 15 well as NUREG-0586, would still occur but may occur later than they would if both units retired 16 at the end of their current Operating Licenses.)

17 The NRC staff has not yet addressed in any depth in this SEIS the impacts of wind power or 18 biomass generation. The New York State Department of Public Service, in late 2009, indicated 19 that renewable generation resources developed under its Renewable Portfolio Standard by 20 2015 would likely be wind powered (NYSDPS 2009). In the years 2011 through 2015, NYSDPS 21 expects 1076 MW of wind power to come online. Over the same period, it expects 303 MWof 22 biomass (NYSDPS 2009) (including, among other fuel resources, source-separated waste and 23 wood fuel; NYSPSC 2004),289 MWof hydropower (from upstate New York and Canada), and 24 95 MWof landfill gas capacity (NYSDPS 2009). These potentials do not indicate an upper 25 bound of the possible resources in the state, but are indicative of the resources most likely to be 26 added based on NYSDPS supply curve projections. By 2015, then, new renewable resource 27 additions could readily supply the 600 MW of renewable capacity considered here with sufficient 28 biomass, hydropower, and landfill gas additions to back up wind power generation.

29 The wind power portion of this alternative could include onshore or offshore installations, and 30 may include more than one location. Installations have been proposed for many locations 31 around the state, both on- and offshore, and could include wind turbines off Long Island on the 32 Atlantic coast (with easy access to downstate electricity demand), in upstate New York, or on 33 Lake Erie or Lake Ontario. Multiple locations would also allow operators to hedge for poor wind 34 conditions in anyone location. A study conducted for NYSERDA (NYSERDA 2005) indicates 35 that unforced capacity - the percentage of installed capacity available at any given time - at 36 New York State wind installations is approximately 10% for onshore installations and 36% at 37 offshore installations (the offshore estimate is based on one location near Long Island).

38 Because wind power installations do not provide full power all the time, the total installed 39 capacity would either need to exceed the capacity stated here or have sufficient backup 40 generation. In this case, NRC staff assumes that other renewables (hydropower, biomass, and 41 landfill gas) could function as a backup.

42 As noted in Section 8.3.4, under Wood Waste, the biomass alternative would have impacts 43 similar to a coal-fired plant of similar capacity. Unlike a coal-fired plant, however, the biomass 44 plant does not release heavy metals (including mercury, uranium, and thorium) in fly ash.

December 2010 8-61 NUREG-1437, Supplement 38 OAGI0001367A_00394

Environmental Impacts of Alternatives to License Renewal 1 Biomass plants also tend to be slightly less efficient with slightly lower capacity factors than 2 coal-fired facilities. The types of pollutants would be similar to that shown for the NGCC 3 alternative, but in larger quantities for a given output. New York's RPS does not contemplate 4 direct combustion of municipal solid waste as a qualifying resource (NYSPSC 2004), and thus 5 the more-severe air effects of MSW combustion are not addressed here.

6 Impacts from conservation measures are likely to be negligible, as the NRC staff indicated in the 7 GElS (1996) and earlier in this chapter. The primary concerns NRC staff identified in the GElS 8 related to indoor air quality and waste disposal. In the GElS, NRC staff indicated that air quality 9 appeared to become an issue when weatherization initiatives exacerbated existing problems, 10 and were expected not to present significant effects. The NRC staff also indicated that waste 11 disposal concerns related to energy-saving measures like fluorescent lighting could be 12 addressed by recycling programs. The NRC staff considers the overall impact from 13 conservation to be SMALL in all resource areas, though measures that provide weatherization 14 assistance to low-income populations may have positive effects on environmental justice.

15

• Land Use 16 Impacts from this alternative would include the types of impacts discussed for land use in 17 Section 8.1.1.2 and Section 8.3.2.1 of this SEIS. Construction of two hybrid cooling towers 18 would have a SMALL to LARGE impact on land use, depending on where Entergy disposes of 19 excavated material, and construction of one tower would be expected to have approximately 20 half of the impact. If the plant operator constructed only one new cooling tower for the 21 remaining IP unit the land use impacts will also be SMALL to MODERATE, depending on where 22 Entergy disposes of excavated material from the one cooling tower. If no cooling tower was 23 constructed for the remaining unit, the land use impact would be SMALL.

24 The GElS notes that gathering fuel for wood-fired plants (a type of biomass plant) can have 25 significant environmental impacts. However, the NRC staff believes that the operation of the 26 303 MW(e) of biomass-fired generation projected by NYSDPS (NYSDPS 2009) would have 27 minor impacts, especially if the plants were widely distributed and feedstocks were primarily 28 preexisting waste streams. Construction impacts of the biomass plants on land use would be 29 SMALL to MODERATE depending on plant cooling configurations and plant locations. These 30 impacts would be minimized by locating plants on previously disturbed land near other industrial 31 applications, including paper/pulp mills or other forest-product operations where fuels may be 32 readily available. Landfill gas facilities would likely have few new land use impacts as they are 33 typically constructed within or adjacent to existing landfills. New transmission capacity, as 34 discussed in Section 8.3.2 of this SEIS, may be necessary to convey renewables to downstate 35 loads, and could result in additional land use impacts, but staff assumes that adequate 36 transmission will be available.

37 Impacts from the wind power portion of this alternative would depend largely on whether the 38 wind facility is located onshore or offshore. Onshore wind facilities will incur greater land use 39 impacts than offshore, simply because all towers and supporting infrastructure will be located on 40 land. NRC observations indicate that onshore installations could require several thousand 41 acres, though turbines and infrastructure would actually occupy only a small percentage of that 42 land area. Total land disturbance (temporary and permanent) would be approximately 1 ha (2.5 43 ac) per MW (NREL 2009). Most of this area (70 percent) is disturbed temporarily during 44 construction. The majority of both temporary and permanent disturbance is a result of roads to NUREG-1437, Supplement 38 8-62 December 2010 OAGI0001367A_00395

Environmental Impacts of Alternatives to License Renewal 1 support the project (NREL 2009). Land around wind installations could remain in use for 2 activities like agriculture (a practice consistent with wind farm siting throughout the U.S.). For 3 600 MW of wind capacity, NRC staff estimates a total land disturbance of 600 ha (1482 ac), of 4 which 180 ha (445 ac) would be disturbed for the duration of the project if the entire project were 5 constructed on land. Offshore turbines would have much smaller land use impacts.

6 Impacts from hydropower contributions to this combination alternative would depend on the 7 location and type of hydropower installation. Hydropower installations that rely on new 8 impoundments may have substantial land use impacts. Hydropower projects that rely on run-of-9 river or in-stream generator approaches will have markedly lower impacts.

10 Overall, the NRC staff considers that the land use impacts from the first combination alternative 11 would be SMALL to MODERATE.

12

• Ecology 13 As described in Section 8.1.1.2 of the SEIS, the construction of two hybrid cooling towers would 14 have a SMALL impact on aquatic ecology and a SMALL impact on terrestrial ecology (Entergy 15 noted in its comments - included in Appendix A of this SEIS - that constructing cooling towers 16 may have an effect on the Indiana Bat; consultation with the U.S. Fish and Wildlife Service may 17 be necessary in the event that one unit continued to operate and NYSDEC required closed-18 cycle cooling). Because the combined alternative would involve construction and operation of 19 only one cooling tower, the NRC staff considered the resulting impacts from the construction 20 and operation of a single cooling to be SMALL on both the aquatic and terrestrial ecology. (If 21 the remaining IP unit were to continue operating with once-through cooling, the volume of water 22 used would be cut in half, resulting in lower impingement and entrainment impacts, as well as 23 smaller thermal effects. Such effects would not be eliminated, however, and it is reasonable to 24 expect that they would likely be at least MODERATE for some species, though the NRC staff 25 have not analyzed the specific level of impact for this option. Not constructing a cooling tower 26 would mean a smaller terrestrial impact.)

27 Offsite construction and operation of biomass plants may have a SMALL to MODERATE impact 28 on both aquatic and terrestrial ecology, depending heavily on the location of the plants.

29 The principal ecological impacts of an offshore wind farm would be to aquatic ecological 30 resources. An onshore wind farm located in upstate New York would primarily affect terrestrial 31 ecology, with up to 180 ha (445 ac) disturbed for the life of the project, though in many cases 32 this land is already in use for agricultural purposes. Neither type of wind farm would be likely to 33 destabilize ecological resources. Accordingly, a wind farm would have SMALL ecological 34 impacts.

35 NRC staff expects little or no impact to ecology from landfill gas combustion apart from impacts 36 that may be caused by construction on areas outside the landfill confines. Hydropower, 37 however, may trigger additional ecological effects if substantial construction or the creation of 38 new reservoirs are necessary. Some riparian habitats may be inundated along with some 39 upland areas, depending on depth and area of a reservoir. Impoundments could also disrupt 40 migration of fish species, reduce oxygen content, and disrupt water level patters. Run-of-river 41 and in-stream hydropower generation would have relatively minor impacts.

42 The NRC staff concludes that substantial ecological impacts could occur during the construction 43 phase but could be managed by choice of construction methods (e.g., avoiding particularly December 2010 8-63 NUREG-1437, Supplement 38 OAGI0001367A_00396

Environmental Impacts of Alternatives to License Renewal 1 sensitive habitats) and by avoiding hydropower options that require reservoirs.

2 Overall, the NRC staff considers that the ecological impacts, both aquatic and terrestrial, from 3 this combination alternative could range from SMALL to LARGE. Selecting low-impact 4 hydropower approaches and less-sensitive windpower locations would minimize impacts.

5

• Water Use and Quality 6 The primary water use and quality issues from this alternative would occur from the hydropower 7 portion of this alternative. Impacts, however, depend on the location and type of hydropower 8 facility, with in-stream or run-of-river facilities having lower impacts than facilities that block 9 watercourses. For some installations, impacts would be SMALL, while for others, impacts may 10 be greater.

11 While construction impacts could occur from a wind farm, particularly if located offshore, these 12 impacts are likely to short lived. An offshore windfarm is unlikely to located immediately 13 adjacent to any water users, though construction may increase turbidity. An onshore wind farm 14 could create additional erosion during construction, as would biomass plants. Landfill gas 15 facilities are likely to trigger little to no additional impacts as they are located on sites that are 16 already developed and typically have controls on water runoff and groundwater infiltration (even 17 if such measures were not working properly at a given landfill, the incremental effect of a landfill 18 gas facility would likely be undetectable compared to the effects of a landfill In general, site 19 management practices keep effects from these components to a small level.

20 During operations, only the biomass and landfill gas plants would require water for cooling. All 21 of these installations would likely use closed-cycle cooling, however, and this would limit the 22 effects on water resources. As the NRC staff indicated for the NGCC alternative, the landfill gas 23 and wood-fired portions of this alternative are likely to rely on surface water for cooling (or, as is 24 the case in some locations, treated sewage effluent).

25 Effects from the continued operation of one IP unit with closed-cycle cooling would be SMALL, 26 as would continued operation of one unit with the existing cooling system.

27 The NRC staff considers impacts on water use and quality to be SMALL to LARGE for this 28 combination alternative. Impacts would be SMALL if low-impact hydropower facilities are 29 selected, and IP2 or IP3 operate with closed-cycle cooling.

30

• Air Quality 31 The first combined alternative will have some impact on air quality as a result of emissions from 32 the biomass plants and the landfill gas facilities. The impacts are likely to be similar to the 33 NGCC alternative considered in this chapter in terms of the type of emissions, though relatively 34 higher on a per-unit-output basis. Based on DPS projections for renewable generation through 35 2015, NRC staff projects that roughly 60 percent of backup for the windpower portion of this 36 alternative would come from biomass and landfill gas, and these portions would not operate at 37 all times (combustion units provide support to the windpower power portion of this alternative).

38 Hydropower would supply the remainder of the backup to the wind portion. Hydropower itself 39 produces no direct emissions.

40 Given the relatively small size of backup combustion generation -less than 400 MW from 41 biomass and landfill gas - the emissions levels are likely to be a fraction of those from the 42 NGCC alternative considered in this chapter. Landfill gas units may require pre-treatment of NUREG-1437, Supplement 38 8-64 December 2010 OAGI0001367A_00397

Environmental Impacts of Alternatives to License Renewal 1 gas streams in order to avoid emitting toxic gases, though these units also convert methane - a 2 potent greenhouse gas and frequent byproduct of anaerobic decomposition - into carbon 3 dioxide, a less-potent greenhouse gas. Also, these combustion installations are likely to be 4 spread out over several locations in multiple areas. These new facilities would require air 5 permits similar to those discussed for the NGCC alternative, though it is possible that the 6 combustion portions of this alternative may be located outside of non-attainment areas, and 7 thus be subject to less-stringent regulations. Given that a number of areas of New York State 8 are non-attainment areas for ozone, however, it is likely that combustion portions of this 9 alternative would have to offset emissions of NOx. Overall impacts of these portions of the 10 combination alternative would be SMALL, given the reduced size of this generating source as 11 compared to the NGCC alternative.

12 Section 8.1.1.2 of this SEIS describes the impacts on air quality from the construction and 13 operation of two hybrid cooling towers to be SMALL to LARGE, depending on CAA compliance.

14 For the construction and operation of a single tower, the impacts would likely be SMALL to 15 MODERATE. The continued operation of one of the nuclear power units without a cooling tower 16 would have SMALL impacts.

17 Overall, the NRC staff considers that the air quality impacts from the first combination 18 alternative would be SMALL to MODERATE, depending on whether a cooling tower is required 19 at the IP site.

20

• Waste 21 Constructing a wind farm, biomass generation, and landfill gas generation has the potential to 22 create substantial amounts of waste, as could constructing one cooling tower on the IP site.).

23 Construction impacts could range from SMALL to LARGE during construction depending on site 24 characteristics and the extent to which wastes can be reused, recycled, or readily disposed of.

25 Operational wastes would come primarily from the biomass power plant. Most of the ash from 26 burned wood waste could be recycled or reused. The waste contribution from the remaining IP2 27 or IP3 unit would be roughly half of the waste generated by the current plant. Operation of the 28 landfill gas and biomass plants, in addition to generating relatively little waste, would likely 29 reduce or reuse waste streams.

30 During operations, waste volumes would have only SMALL impacts, while construction stage 31 impacts could range from SMALL to LARGE.

32

• Human Health 33 The primary health concerns under this option would be occupational health and safety risks 34 during the construction of the new facilities, and excavation for the cooling tower, if necessary.

35 As described in previous sections (NGCC alternative), if the risks are appropriately managed, 36 the human health impacts from these or similar alternatives are SMALL. Impacts from 37 emissions are uncertain, but considered SMALL as the plants would comply with the CAA 38 health-informed standards and other relevant emissions regulations. Continued operation of 39 one IP unit with the existing once-through cooling system would not change this assessment.

40 Therefore, the NRC staff concludes that the overall human health impact from the first 41 combination alternative would be SMALL.

42

• Socioeconomics December 2010 8-65 NUREG-1437, Supplement 38 I OAGI0001367A_00398

Environmental Impacts of Alternatives to License Renewal 1 This combination alternative involves the shutdown of either IP2 or IP3. As detailed in Section 2 8.2 of this SEIS, the socioeconomic impacts of shutting down the plants would be SMALL to 3 MODERATE because of the loss of PI LOT payments to local municipalities. Under this option, 4 those payments would be expected to decrease but would not be completely eliminated. Some 5 IP2 or IP3 jobs would be lost with closure of one unit. At the same time, this alternative would 6 create jobs in other locations and also generate new revenues for other municipalities. Overall, 7 the NRC staff concludes that the socioeconomic impacts from the first combined alternative 8 would be SMALL.

9

• Socioeconomics (Transportation) 10 As described in Section 8.1.1.2 of this SEIS, the construction of two hybrid cooling towers could 11 have up to a LARGE impact on transportation in the area around IP2 and IP3 during 12 construction because of the large volume of rock and debris that would need to be transported 13 off site. Approximately half as much excavated material will need to leave the IP2 and IP3 site 14 under this combination alternative (if the IP unit continued to operate with once-through cooling, 15 no excavated material would need to leave the site and transportation impacts would be 16 eliminated). The other aspects of this alternative will create modest, but noticeable, 17 transportation effects during construction. Given that the biomass facility, hydropower facility, 18 landfill gas installations, and wind farm are likely not be located in the same place, construction-19 stage impacts are less intense than if they were part of one collocated facility. Construction for 20 the wind-power portion of this alternative may have noticeable impacts while trucks, trains, or 21 ships carry large components to the project sites, but the impacts are limited in duration. The 22 hydropower portion of this alternative is not likely to create transportation impacts unless an 23 impoundment blocked a waterway used for shipping. NRC staff considers this unlikely.

24 During operation, only the biomass facility is likely to create noticeable impacts on transportation 25 (in gathering materials), and these may not affect any important aspects of local transportation.

26 No other transportation impacts for this alternative are considered to be as severe. Overall, the 27 impact from this combined alternative would likely be MODERATE.

28

• Aesthetics 29 As described in Section 8.1.1.2 of this SEIS, the construction of two hybrid cooling towers would 30 have a MODERATE impact on aesthetics. Aesthetic impacts from one cooling tower may be 31 slightly smaller, though it would likely still affect the scenic value of the Hudson Valley.

32 Aesthetic impacts would occur during construction and operation of an offshore wind installation 33 and would depend on its distance from the shore and on its orientation in regard to shoreline 34 communities. The NRC staff estimates that the construction and operational impacts of the 35 facility could be managed, though some may consider the impact to be LARGE, depending on 36 the location of the turbines. An onshore wind facility would also have the potential to create 37 LARGE effects. The aesthetic impacts from new biomass generating plants would likely not 38 have a major effect on visual resources, because the plants are small. Impacts would depend 39 on the plants' locations. Landfill gas facilities would also be unlikely to negative affect 40 aesthetics. Hydropower power facilities would only be likely to have significant effects if they 41 require a large impoundment.

42 The NRC staff concludes that the overall aesthetic impacts from the first combination alternative 43 could range from SMALL to LARGE, depending primarily on the aesthetic effects of the wind NUREG-1437, Supplement 38 8-66 December 2010 OAGI0001367A_00399

Environmental Impacts of Alternatives to License Renewal 1 power portion and whether a cooling tower is required for remaining IP unit.

2

• Historic and Archeological Resources 3 Onsite impacts to historical and cultural resources from the construction of a hybrid cooling 4 tower may range from SMALL to MODERATE. The offsite impacts from the construction of 5 biomass units, wind installations, landfill gas facilities, and hydropower are also expected to be 6 small given the opportunity to evaluate and select the sites in accordance with applicable 7 regulations and the ability to minimize impacts before construction. The impacts from 8 construction of an onshore wind installation or hydropower facility could range from SMALL to 9 MODERATE, depending on whether historical and archaeological resources are present. In 10 that event, proper management of the resources, in conjunction with State historical 11 preservation authorities, would assure that the impacts are not LARGE. Therefore, the NRC 12 staff concludes that the overall impacts on historic and archeological resources from the first 13 combination alternative would be SMALL to MODERATE.

14

• Environmental Justice 15 No impacts are anticipated in the IP2 and IP3 area that could disproportionately affect minority 16 or low-income communities. Impacts from offsite activities would depend on the location of the 17 activity. Many conservation measures, especially those involving weatherization or efficiency 18 improvements to low-income households, can have disproportionately positive effects for low-19 income families. Overall, though, impacts to minority and low-income populations from the first 20 combination alternative would depend substantially on the location of the installations and the 21 characteristics of the surrounding communities. Impacts could range from SMALL to LARGE, 22 depending on the location of the facilities relative to minority and low-income communities.

23 24 8.3.5.2 Impacts of Combination Alternative 2 25 The second combination alternative differs from the first in that it completely replaces IP2 and 26 IP3 capacity. In contrast to the first combination alternative, a 400-MW(e) to 600 MW(e) NGCC 27 plant is included as a repowering of an existing facility. NRC staff notes that it could also be 28 located on the IP site. Either modifications to the existing onsite pipeline would be necessary to 29 provide firm year-round service to the site without removing the service rights of other 30 customers in New York and Connecticut served by the pipeline (Levitan and Associates, Inc.

31 2005) or new gas supplies would have be available from proposed LNG projects or other 32 sources. A repowered NGCC plant at another site may have similar supply restrictions.

33 Like the first combination alternative, the second combination alternative employs 600 MW(e) 34 from renewable energy sources (wind backed by other renewables). The impacts of these 35 sources are described in the discussion of Combination Alternative 1 in Section 8.3.5.1 of this 36 SEIS, and are not repeated in this section of the SEIS.

37 Finally, this option requires more aggressive energy conservation programs that would result in 38 an energy savings of 1000 to 1200 MW(e). As described in Section 8.3.4 of this SEIS, these 39 conservation efforts would have overall SMALL impacts, and are not repeated in this section of 40 the SEIS.

41

• Land Use December 2010 8-67 NUREG-1437, Supplement 38 I OAGI0001367A_00400

Environmental Impacts of Alternatives to License Renewal 1 Siting 400 to 600 MW(e) of NGCC capacity with a closed-cycle cooling system at a repowered 2 facility would require about 18 ha (45 ac) and would likely have SMALL impacts on land use as 3 the existing site as the unit or units could likely be constructed on previously-disturbed land and 4 may be able to reuse substantial portions of onsite infrastructure. These effects would be 5 similar if the NGCC capacity were located at the IP site 6 Land use impacts from the renewable portion of this alternative are identical to those in 7 Combination Alternative 1.

8 Overall, the NRC staff considers that the land use impacts from this combination alternative 9 would be SMALL to MODERATE.

10

• Ecology 11 As described in Section 8.3.1 of this SEIS, the impacts from the construction of five NGCC 12 units at a repowered site or at IP2 and IP3 would have a SMALL impact on aquatic and 13 terrestrial ecology.

14 Impacts from the renewable portion are SMALL to LARGE, as was the case in Combination 15 Alternative 1.

16 Overall, the NRC staff considers that the ecological impacts from the second combination 17 alternative would be SMALL to LARGE, depending on locations selected for each alternative.

18

• Water Use and Quality 19 Impacts from the renewable portions of this alternative are SMALL to LARGE, as were those 20 considered in Combination Alternative 1.

21 The NGCC repowering portion of this alternative would create water demands, but would 22 minimize them by relying on closed-cycle cooling. Impacts would be significantly smaller than 23 those considered for the stand-alone NGCC alternative, which were SMALL at the IP site or a 24 repowered site.

25 The overall effects on water use and quality of the second combination alternative would range 26 from SMALL to LARGE, depending on locations of the alternatives and the type of hydroelectric 27 facility constructed.

28

• Air Quality 29 The second combination alternative will have some impact on air quality as a result of emissions 30 from the combustion alternatives. The impact from renewable portions would be the same as 31 those described in Combination Alternative 1, which was SMALL to MODERATE. The NGCC, 32 repowered facility would have emissions that range from 20 to 30 percent of those of the stand-33 alone NGCC alternative (which also had SMALL to MODERATE impacts). Nonetheless, the 34 NRC staff concludes that the overall impacts from all of the new plants would range from 35 SMALL to MODERATE.

36

• Waste 37 Impacts from renewable portions of this alternative would be the same as those in Combination 38 Alternative 1, which were SMALL to LARGE. Wastes from the NGCC portion of this alternative 39 would be similar in type to those in the stand-alone NGCC alternative, which had SMALL 40 impacts. Overall, the NRC staff concludes that the impacts will be SMALL to LARGE.

NUREG-1437, Supplement 38 8-68 December 2010 OAGI0001367A_00401

Environmental Impacts of Alternatives to License Renewal 1

• Human Health 2 The primary health concerns under this option would be occupational health and safety risks 3 during construction As described in previous sections (for combination alternative 1 and the 4 NGCC alternatives), if the risks are appropriately managed, the human health impacts from 5 these or similar alternatives are SMALL.

6 The NRC staff concludes that the overall human health impact from the second combination 7 alternative would be SMALL.

8

• Socioeconomics 9 The second combination alternative involves the complete shutdown of IP2 and IP3. As 10 detailed in Section 8.2 of this SEIS, the socioeconomic impacts of shutting down the plant 11 would be SMALL to MODERATE because of the loss of PI LOT payments. (Constructing the 12 NGCC portion of this alternative at the IP site could replace some of the PILOT payments.

13 Levitan and Associates (2005) indicated that a smaller gas-fired plant may replace a significant 14 portion of the PILOT payments currently provided by IP2 and IP3.) Some IP2 and IP3 jobs 15 would be lost but replaced with decommissioning jobs and jobs associated with the construction 16 and operation of the gas turbine plant. Other jobs would be generated by the construction of the 17 offsite alternatives. While many of these jobs would cease at the end of construction, a fraction 18 would remain during operation. Overall, the NRC staff concludes that the socioeconomic 19 impacts from the second combination alternative would likely be SMALL to MODERATE, 20 primarily because of the significant loss in revenues from the PI LOT payments and the loss of 21 IP2 and IP3 jobs.

22

• Socioeconomics (Transportation) 23 The aspects of this alternative will create modest transportation effects during construction. The 24 renewable portions of this alternative will have the same impacts as in combination alternative 25 1, which were MODERATE. Also, construction of this NGCC facility will require fewer workers 26 than the NGCC alternative considered in Section 8.3.1 of this SEIS because it is much smaller.

27 The NGCC unit may create noticeable impacts on gas transmission, but improvements to gas 28 transmission or new LNG capacity may offset these impacts. Because winter heating 29 customers take priority over utility generation customer, the plant is unlikely to have noticeable 30 effects for other gas users, though it may need to burn fuel oil during peak demand periods.

31 Transportation impacts for this alternative would be moderated because the construction and 32 operation workforce would be spread over multiple locations. No single project would have a 33 significant long-term impact. Overall, the NRC staff concludes that the impact would likely be 34 MODERATE.

35

• Aesthetics 36 Aesthetic impacts would occur primarily as a result of the wind power portion of this alternative, 37 and may range from SMALL to LARGE from wind power alone. Other aspects of this alternative 38 are unlikely to have noticeable effects. Particularly, NGCC repowering will have little, if any 39 effect on the repowered site.

40 As a result, the NRC staff concludes that the overall aesthetic impacts from the second 41 combination alternative would be SMALL to LARGE, depending on the degree to which wind December 2010 8-69 NUREG-1437, Supplement 38 OAGI0001367A_00402

Environmental Impacts of Alternatives to License Renewal 1 power installations affect areas where aesthetics are an important value.

2

• Historic and Archeological Resources 3 Onsite impacts to historical and cultural resources from the construction of a single gas turbine 4 plant are expected to be SMALL. The offsite impacts from the construction of renewable 5 installations are expected to be SMALL to MODERATE, as in Combination Alternative 1, given 6 the opportunity to evaluate and select the sites in accordance with applicable regulations and 7 the ability to minimize impacts before construction. The NGCC portion of this alternative will be 8 constructed on an existing site, using existing infrastructure to the extent possible. Even if 9 constructed on the IP2 and IP3 site, it is likely that the NGCC portion of this alternative could 10 avoid sensitive areas. Therefore, the NRC staff concludes that the overall impacts on historic 11 and archeological resources from the second combination alternative would be SMALL to 12 MODERATE.

13

• Environmental Justice 14 Impacts from construction and operations would depend on the locations of the activities. Many 15 conservation measures, especially those involving weatherization or efficiency improvements to 16 low-income households, can have disproportionately positive effects for low-income families.

17 Overall, though, impacts to minority and low-income populations from the second combination 18 alternative would depend substantially on the location of the installations and the characteristics 19 of the surrounding communities. Impacts could range from SMALL to LARGE, depending on 20 the location of the facilities relative to minority and low-income communities.

21 I NUREG-1437, Supplement 38 8-70 December 2010 OAGI0001367A_00403

Environmental Impacts of Alternatives to License Renewal 1

2 Table 8-4. Summary of Environmental Impacts of Combination Alternatives Impact Combination 1 Combination 2 Category Impact Comments Impact Comments Land Use SMALL to Impacts would depend SMALL to Impacts would depend on MODERATE on location of wind MODERATE location of wind farm, type farm, type of hydro of hydro facilities, the site facilities, the site selection for the biomass selection for the plants.

biomass plants, as well as land-disposal of wastes Ecology SMALL to Impacts substantially SMALL to Impacts substantially LARGE depend on the type and LARGE depend on the type and location of facilities. location of facilities.

Water Use and SMALL to Impacts depend largely SMALL to Impacts depend largely on Quality LARGE on type and location of LARGE the type and location of hydropower facilities. hydropower facilities.

Air Quality SMALL to Air emissions from SMALL to Air emissions of the small MODERATE biomass and landfill gas MODERATE biomass and landfill gas facilities would be minor facilities would be minor given their size and considering their size and possible multiple possible multiple locations. One cooling locations; NGCC facility tower could have an 20-30 percent of output of effect on air quality. alternative in 8.3.1.

Waste SMALL to Construction waste SMALL to Construction waste LARGE impacts could range LARGE impacts could range from from SMALL to LARGE. SMALL to LARGE.

Operational wastes are Operational wastes are SMALL. SMALL.

3 December 2010 8-71 NUREG-1437, Supplement 38 I OAGI0001367 A_00404

Environmental Impacts of Alternatives to License Renewal 1 Table 8-4 (continued)

I Impact Combination 1 Combination 2 Category Impact Comments Impact Comments Human Health SMALL Emissions and SMALL Emissions and occupational risks occupational risks would would be managed in be managed in accordance with accordance with applicable regulations. applicable regulations.

Socioeconomics SMALL Some PILOT payments SMALL to IP2 and IP3 jobs and and jobs may be lost. MODERATE PILOT payments lost; some new jobs and taxes; minimum impacts from other power alternatives.

Socioeconomics MODERATE Construction impacts MODERATE Transportation effects may (Transportation) may be significant but be noticeable during short-lived. construction ..

Aesthetics SMALL to Visual impacts from SMALL to Visual impacts from new LARGE new wind turbines, LARGE wind turbines depend on depend on locations the location chosen.

selected. Impacts also Limited impact from from cooling tower, if combustion facilities.

constructed.

Historic and SMALL to Cultural resources SMALL to Cultural resources Archeological MODERATE inventories would be MODERATE inventories would be Resources needed to identify, needed to identify, evaluate, and mitigate evaluate, and mitigate potential impacts from potential impacts from construction. construction.

Environmental SMALL to Impacts would depend SMALL to Impacts would depend on Justice LARGE on plant locations. LARGE plant locations.

2 3

4 5 8.4 Summary of Alternatives Considered 6 In this SEIS, the NRC staff has considered alternative actions to license renewal of IP2 and IP3 7 including the no-action alternative (discussed in Section 8.2), new generation or energy 8 conservation alternatives (natural gas and conservation alternatives discussed in Sections 8.3.1 9 through 8.3.2), purchased electrical power (discussed in Section 8.3.3), alternative power-10 generating technologies that staff dismissed from detailed consideration (including supercritical 11 coal-fired power; discussed in Section 8.3.4), and two combinations of alternatives (discussed 12 in Section 8.3.5).

13 As established in the GElS, the need for power from IP2 and IP3 is assumed by the NRC in the NUREG-1437, Supplement 38 8-72 December 2010 OAGI0001367 A_00405

Environmental Impacts of Alternatives to License Renewal 1 license renewal process. Should the NRC not renew the IP2 and/or IP3 operating licenses, 2 their generating capacity or load reduction (e.g., by conservation) would have to come from an 3 alternative to license renewal (which may include some of the alternatives considered here).

4 Furthermore, even if the NRC renews the operating licenses, Entergy could elect not to operate 5 either IP2 or IP3 for the full terms of the renewed licenses. Decisions about which alternative to 6 implement, regardless of whether or not the NRC renews the IP2 and IP3 operating licenses, 7 are outside the NRC's authority and are subject to consideration by Entergy, other power 8 producers, and State-level decision makers (or non-NRC Federal-level decision makers where 9 applicable).

10 Impacts from the conservation alternative are generally lower than those from other alternatives, 11 including the proposed action. Impacts from the NGCC alternative at a repowered site or the IP 12 site has the potential for larger air quality impacts, but smaller aquatic ecology impacts. Impacts 13 from combination alternatives (with or without continued operation of one IP unit) that do not rely 14 on conventional hydropower are likely to have smaller aquatic impacts than continued operation 15 of IP2 and IP3, while they have potentially larger impacts in other areas, including air quality, 16 aesthetics, and land use. Continued operation of one IP unit with closed-cycle cooling as part of 17 a combination alternative would increase impacts to aesthetics, land use, waste, and air quality 18 while reducing aquatic impacts. A NGCC alternative at a new site is likely to have a variety of 19 more-significant impacts than continued operations of IP2 and IP3.

20 For most impact areas - land use, air quality, waste, transportation, aesthetics, historic and 21 archaeological resources, for example - the closed-cycle cooling alternative has larger impacts 22 that continued operation of IP2 and IP3 with its current cooling system. Its impact to aquatic 23 ecology, however, is smaller than continued operation with the existing once-through cooling 24 system. The NRC staff notes that this evaluation is not intended to preempt or prejudice 25 NYSDEC SPDES proceedings in any way, and resolution of cooling system requirements for 26 IP2 and IP3 remains and issue for resolution in these proceedings.

27 8.5 References 28 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of 29 Production and Utilization Facilities."

30 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 31 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

32 40 CFR Part 50. Code of Federal Regulations, Title 40, Protection of Environment, Part 50, 33 "National Primary and Secondary Ambient Air Quality Standards."

34 40 CFR Part 51. Code of Federal Regulations, Title 40, Protection of Environment, Part 51, 35 "Requirements for Preparation, Adoption, and Submittal of Implementation Plans."

36 40 CFR Part 60. Code of Federal Regulations, Title 40, Protection of Environment, Part 60, 37 "Standards of Performance for New Stationary Sources."

38 40 CFR Part 81. Code of Federal Regulations, Title 40, Protection of Environment, Part 81, 39 "Designation of Areas for Air Quality Planning Purposes."

40 40 CFR Part 122. Code of Federal Regulations, Title 40, Protection of Environment, Part 122, 41 "EPA Administered Permit Programs: National Pollutant Discharge Elimination System."

December 2010 8-73 NUREG-1437, Supplement 38 OAGI0001367A_00406

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41 December 2010 8-75 NUREG-1437, Supplement 38 I OAGI0001367A_00408

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38 I NUREG-1437, Supplement 38 8-80 December 2010 OAGI0001367A_00413

Environmental Impacts of Alternatives to License Renewal 1 U.S. Census Bureau. 2000. Available at URL:

2 http://factfinder.census.gov/servlet/SAFFFacts?_event=&geo_id=16000US361 0341 &_geoConte 3 xt=01000US%7C04000US36%7C16000US361 0341 &_street=&_coun ty=Buchanan&_cityTown=

4 Buchanan&_state=04000US36&_zip=&_lang=en&_sse=on&ActiveGeoDiv=geoSelect&_useEV 5 =&pctxt=fph&pgsl=160&_submenuld=factsheet_1&ds_name=nulI&_ci_nbr=null&qr_name=null&

6 reg=null%3Anull&_keyword=&_industry=&show_2003_tab=&redirect=Y. Accessed 7 February 13, 2008.

8 U.S. Geological Survey (USGS). 1997. "Radioactive Elements in Coal and Fly Ash:

9 Abundance, Forms, and Environmental Significance; USGS Fact Sheet FS-163-97." Available 10 at URL: http://greenwood.cr. usgs.gov/enerfy/factshts/163-97IFS-163-97. pdf.

11 U.S. Second Circuit Court of Appeals. 2004. Riverkeeper, Inc. v. U.S. E.P.A. (Riverkeeper I).

12 358 F.3d 174. (February 2,2004).

13 U.S. Second Circuit Court of Appeals. 2007. Riverkeeper, Inc. v. U.S. E.P.A. (Riverkeeper II).

14 475 F.3d 83. (January 25,2007) 15 University of Liege. 2007. "Deep Sounds Scare Fish Away From Turbines That Could Kill 16 Them." ScienceOaily, 16 May 2007. Available at URL:

17 http://www.sciencedaily.com/releases/2007/05/070514154055.htm. Accessed February 28, 18 2008.

19 Walsh et al. 1999. "Biomass Feedstock Availability in the United States: 1999 State Level 20 Analysis." April 30, 1999.

21 WINS. 2008. "Plans for Wind Farm Off Long Island Triples in Size." April 17, 2008. Available 22 at URL: http://www.1010wins.com/pages/2021612.php?. Accessed June 9,2008.

December 2010 8-81 NUREG-1437, Supplement 38 I OAG10001367A_00414

1 9.0

SUMMARY

AND CONCLUSIONS 2 Entergy Nuclear Operations, Inc. (Entergy), Entergy Nuclear Indian Point 2 (lP2), LLC, and 3 Entergy Nuclear Indian Point 3 (lP3), LLC, are joint applicants for the renewal of the IP2 and IP3 4 operating licenses Uoint applicants will be referred to as Entergy). On April 23, 2007, Entergy 5 submitted an application to the U.S. Nuclear Regulatory Commission (NRC) to renew the IP2 6 and IP3 operating licenses for an additional 20 years each under Title 10, Part 54, 7 "Requirements for Renewal of Operating Licenses for Nuclear Power Plants," of the Code of 8 Federal Regulations (10 CFR Part 54) (Entergy 2007a). If the operating licenses are renewed, 9 State and Federal (other than NRC) regulatory agencies and Entergy would ultimately decide 10 whether the plant will continue to operate based on factors such as the need for power, power 11 availability from other sources, regulatory mandates, or other matters within the agencies' 12 jurisdictions or the purview of the owners. If the NRC decides not to renew the operating 13 licenses, then the units must be shut down upon the expiration of the current operating licenses, 14 subject to the conclusion of the license renewal process. If the license renewal review is 15 ongoing at the time of license expiration, the units will be allowed to continue operating until the 16 NRC makes a determination. The IP2 operating license will expire on September 28,2013; the 17 IP3 operating license will expire on December 12, 2015.

18 Section 102 of the National Environmental Policy Act of 1969, as amended (NEPA), requires an 19 environmental impact statement (EIS) for major Federal actions that significantly affect the 20 quality of the human environment. The NRC has implemented Section 102 of NEPA in 21 10 CFR Part 51, "Environmental Protection Regulations for Domestic Licensing and Related 22 Regulatory Functions." As identified in 10 CFR Part 51, certain licensing and regulatory actions 23 require an EIS. In 10 CFR 51.20(b)(2), the NRC requires preparation of an EIS or a supplement 24 to an EIS for renewal of a reactor operating license. Furthermore, 10 CFR 51.95(c) states that 25 the EIS prepared at the operating license renewal stage will be a supplement to NUREG-1437, 26 Volumes 1 and 2, "Generic Environmental Impact Statement for License Renewal of Nuclear 27 Plants" (hereafter referred to as the GElS) (NRC 1996, 1999).(1) 28 Upon acceptance of the license renewal application for docketing, the NRC began the 29 environmental review process described in 10 CFR Part 51 by publishing, on August 10,2007, 30 a Notice of Intent to prepare an EIS and conduct scoping (Volume 72, page 45075, of the 31 Federal Register (72 FR 45075)). The NRC staff held two public scoping meetings on 32 September 19,2007, and visited the IP2 and IP3 site to conduct site audits on September 10-33 14,2007, and September 24-27,2007. The NRC staff reviewed the Entergy environmental 34 report (ER) (Entergy 2007b) and compared it to the GElS, consulted with other agencies, and 35 conducted an independent review of the issues following the guidance set forth in 36 NUREG-1555, Supplement 1, "Standard Review Plans for Environmental Reviews for Nuclear 37 Power Plants, Supplement 1: Operating License Renewal" (NRC 2000). The NRC staff also 38 considered the public comments received during the scoping process for preparation of the draft 39 supplemental environmental impact statement (SEIS) for IP2 and IP3. Public comments and 40 NRC staff responses are available in the Scoping Summary Report prepared by the NRC staff 41 (ADAMS Accession NumberML083360115).

42 The NRC staff issued a draft SEIS in December 2008. Thereafter, the staff held public meetings (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 9-1 NUREG-1437, Supplement 38 OAGI0001367A_00415

Summary and Conclusions 1 in Cortlandt Manor, New York, on February 12, 2009 and presented the preliminary results of 2 the NRC environmental review, answered questions from the public, and received comments on 3 the draft SEIS. The NRC staff considered and addressed all of the comments received. The 4 comments are reflected in this SEIS and/or addressed in Part 2 of Appendix A to this final SEIS.

5 This SEIS includes the NRC staff's analysis that considers and weighs the environmental 6 effects of the proposed action (including cumulative impacts), the environmental impacts of 7 alternatives to the proposed action, and mitigation measures available for reducing or avoiding 8 adverse effects. This SEIS also includes the NRC staff's recommendation regarding the 9 proposed action.

10 The NRC has adopted the following statement of purpose and need for license renewal from the 11 GElS:

12 The purpose and need for the proposed action (renewal of an operating license) 13 is to provide an option that allows for power generation capability beyond the 14 term of a current nuclear power plant operating license to meet future system 15 generating needs, as such needs may be determined by State, utility, and, where 16 authorized, Federal (other than NRC) decision makers.

17 The evaluation criterion for the NRC staff's environmental review, as defined in 18 10 CFR 51.95(c)(4) and the GElS, is to determine the following:

19 ... whether or not the adverse environmental impacts of license renewal are so 20 great that preserving the option of license renewal for energy planning 21 decisionmakers would be unreasonable.

22 Both the statement of purpose and need and the evaluation criterion implicitly acknowledge that 23 there are factors, in addition to license renewal, that will ultimately determine whether an 24 existing nuclear power plant continues to operate beyond the period of the current operating 25 licenses.

26 NRC regulations (10 CFR 51.95(c) (2)) contain the following statement regarding the content of 27 SEISs prepared at the license renewal stage:

28 The supplemental environmental impact statement for license renewal is not 29 required to include discussion of need for power or the economic costs and 30 economic benefits of the proposed action or of alternatives to the proposed 31 action except insofar as such benefits and costs are either essential for a 32 determination regarding the inclusion of an alternative in the range of alternatives 33 considered or relevant to mitigation. In addition, the supplemental environmental 34 impact statement prepared at the license renewal stage need not discuss other 35 issues not related to the environmental effects of the proposed action and the 36 alternatives, or any aspect of the storage of spent fuel for the facility within 37 thescope of the generic determination in 10 CFR 51.23(a) and in accordance 38 with 10 CFR 51.23(b).(2)

(2)

The title of 10 CFR 51.23 is "Temporary storage of spent fuel after cessation of reactor operation-generic determination of no significant environmental impact."

NUREG-1437, Supplement 38 9-2 December 2010 OAG10001367A_00416

Summary and Conclusions 1 The GElS contains the results of a systematic evaluation of the consequences of renewing an 2 operating license and operating a nuclear power plant for an additional 20 years. It evaluates 3 92 environmental issues using the NRC's three-level standard of significance-SMALL, 4 MODERATE, or LARGE-developed using the Council on Environmental Quality (CEQ) 5 guidelines. The following definitions of the three significance levels are set forth in the 6 footnotes to Table B-1 of Appendix B to Subpart A, "Environmental Effect of Renewing the 7 Operating License of a Nuclear Power Plant," of 10 CFR Part 51:

8 SMALL-Environmental effects are not detectable or are so minor that they will 9 neither destabilize nor noticeably alter any important attribute of the resource.

10 MODERATE-Environmental effects are sufficient to alter noticeably, but not to 11 destabilize, important attributes of the resource.

12 LARGE-Environmental effects are clearly noticeable and are sufficient to 13 destabilize important attributes of the resource.

14 For 69 of the 92 environmental issues considered in the GElS, the analysis in the GElS reached 15 the following conclusions:

16 (1) The environmental impacts associated with the issue have been determined to apply 17 either to all plants or, for some issues, to plants having a specific type of cooling system 18 or other specified plant or site characteristics.

19 (2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 20 the impacts (except for collective offsite radiological impacts from the fuel cycle and from 21 high-level waste and spent fuel disposal).

22 (3) Mitigation of adverse impacts associated with the issue has been considered in the 23 analysis, and it has been determined that additional plant-specific mitigation measures 24 are likely not to be sufficiently beneficial to warrant implementation.

25 These 69 issues were identified in the GElS as Category 1 issues. In the absence of new and 26 significant information, the NRC staff relied on conclusions as amplified by supporting 27 information in the GElS for issues designated as Category 1 in 10 CFR Part 51, Subpart A, 28 Appendix B, Table B-1.

29 Of the 23 issues that do not meet the criteria set forth above, 21 are classified as Category 2 30 issues requiring analysis in a plant-specific SEIS. The remaining two issues, environmental 31 justice and chronic effects of electromagnetic fields, were not categorized.

32 This SEIS documents the NRC staff's consideration of all 92 environmental issues identified in 33 the GElS. The NRC staff considered the environmental impacts associated with alternatives to 34 license renewal and compared the environmental impacts of license renewal and the 35 alternatives. The alternatives to license renewal that were considered include the no-action 36 alternative (not renewing the operating licenses for IP2 and IP3), continued operation of either 37 IP2 or IP3, alternative methods of power generation, and conservation. The NRC staff also 38 considered an alternative that included continued operation of IP2 and IP3 with a closed-cycle 39 cooling system.

December 2010 9-3 NUREG-1437, Supplement 38 I OAGI0001367A_00417

Summary and Conclusions 1 9.1 Environmental Impacts of the Proposed Action-2 License Renewal 3 The NRC staff has established an independent process for identifying and evaluating the 4 significance of any new information on the environmental impacts of license renewal. The NRC 5 staff has not identified any information that is both new and significant related to Category 1 6 issues that would call into question the conclusions in the GElS. In the IP2 and IP3 ER, Entergy 7 identified leakage from onsite spent fuel pools as potentially new and significant information 8 (Entergy 2007b). The NRC staff has reviewed Entergy's analysis of the leakage and has 9 conducted an extensive onsite inspection of leakage to ground water, as identified in Section 10 2.2.7 of this SEIS. Based on the NRC staff's review of Entergy's analysis, the NRC staff's 11 adoption of the NRC inspection report findings in this SEIS, and Entergy's subsequent 12 statements (all discussed in Section 2.2.7), the NRC staff concludes that the abnormal liquid 13 releases discussed by Entergy in its ER, while new information, are within the NRC's radiation 14 safety standards contained in 10 CFR Part 20 and are not considered to have a significant 15 impact on plant workers, the public, or the environment (i.e., while the information related to 16 spent fuel pool leakage is new, it is not significant). Therefore, the NRC staff relied upon the 17 conclusions of the GElS for all Category 1 issues that are applicable to IP2 and IP3.

18 Entergy's license renewal application contains an analysis of the Category 2 issues that are 19 applicable to IP2 and IP3, plus environmental justice and chronic effects from electromagnetic 20 fields for a total of 23 issues. The NRC staff has reviewed the Entergy analysis and has 21 conducted an independent review of each issue. Six of the Category 2 issues are not 22 applicable because they are related to cooling systems, water use conflicts, and ground water 23 use not found at IP2 and IP3.

24 As discussed in Chapter 3, scoping comments revealed-and Entergy indicated-that Entergy 25 may replace reactor vessel heads and control rod drive mechanisms (CRDMs) in both units. As 26 a result, the NRC staff addressed the impacts of these replacement activities in Chapter 3. This 27 includes three Category 2 issues that apply only to refurbishment, six Category 2 issues that 28 apply to refurbishment and continued operation, and one uncategorized issue, environmental 29 justice, that applies to both refurbishment and continued operations. The NRC staff determined 30 that all effects from refurbishment activities are of SMALL significance.

31 The NRC staff addresses twelve Category 2 issues related to impacts from continued 32 operations and postulated accidents during the renewal term, as well as environmental justice 33 and chronic effects of electromagnetic fields. Research is continuing in the area of chronic 34 effects on electromagnetic fields, and a scientific consensus has not been reached. Therefore, 35 no further evaluation of this issue is required. The NRC staff concludes that the potential 36 environmental effects for 9 of the 12 categorized issues are of SMALL significance in the 37 context of the standards set forth in the GElS. The NRC staff concludes that the combined 38 impacts from impingement and entrainment (each a separate issue) are MODERATE. Impacts 39 from heat shock could range from SMALL to LARGE, based on the large uncertainties 40 discussed in Chapter 4. Based on corrected data received since the completion of the draft 41 SEIS, the NRC staff concludes that impacts to the endangered shortnose sturgeon which 42 ranged from SMALL to LARGE in the draft SEIS are likely to be SMALL.

43 For severe accident mitigation alternatives (SAMAs), the NRC staff concludes that a NUREG-1437, Supplement 38 9-4 December 2010 OAGI0001367A_00418

Summary and Conclusions 1 reasonable, comprehensive effort was made by Entergy to identify and evaluate SAMAs.

2 Based on its review of the SAMAs for IP2 and IP3, and the plant improvements already made, 3 the NRC staff concludes that several candidate SAMAs may be cost-beneficial. However, these 4 SAMAs do not relate to adequately managing the effects of aging during the period of extended 5 operation. Therefore, they need not be implemented as part of license renewal pursuant to 6 10 CFR Part 54.

7 For all issues of SMALL significance, current measures to mitigate the environmental impacts of 8 plant operation were found to be adequate. For issues of MODERATE or LARGE significance 9 (i.e., issues related to aquatic ecology), mitigation measures are addressed both in Chapter 4 10 and in Chapter 8 as alternatives based on determinations in the draft New York State 11 Department of Environmental Conservation (NYSDEC) State Pollutant Discharge Elimination 12 System (SPDES) permit proceeding, Clean Water Act Section 401 proceeding, and in draft 13 policy statements published by the State. In Chapter 8, the NRC staff considers the impacts 14 that may result if the plant converts from once-through cooling to a closed-cycle cooling system 15 (Section 8.1.1).

16 Cumulative impacts of past, present, and reasonably foreseeable future actions were 17 considered, regardless of what agency (Federal or non-Federal) or person undertakes such 18 other actions. The NRC staff concludes that the cumulative impacts to the environment around 19 IP2 and IP3 license renewal would be LARGE for some affected resources, given historical 20 environmental impacts, current actions, and likely future actions. With the exception of aquatic 21 resources, the contribution of IP2 and IP3 to cumulative impacts is SMALL.

22 The following sections discuss unavoidable adverse impacts, irreversible or irretrievable 23 commitments of resources, and the relationship between local short-term use of the 24 environment and long-term productivity.

25 December 2010 9-5 NUREG-1437, Supplement 38 I OAGI0001367A_00419

Summary and Conclusions 1 9.1.1 Unavoidable Adverse Impacts 2 An environmental review conducted at the license renewal stage differs from the review 3 conducted in support of a construction permit or operating license because the plant is in 4 existence at the license renewal stage and has operated for a number of years. As a result, 5 adverse impacts associated with the initial construction and operation have already occurred, 6 have been mitigated, or have been avoided. The environmental impacts to be evaluated for 7 license renewal are those associated with refurbishment and continued operation during the 8 renewal term.

9 Adverse impacts of continued operation from (a) heat shock and (b) the combined effects of 10 entrainment and impingement of fish and shellfish are considered to be potentially SMALL to 11 LARGE, and MODERATE, respectively. Other adverse impacts are considered to be of SMALL 12 significance.

13 Adverse impacts of likely alternatives to the operation of IP2 and IP3 vary greatly. Many have 14 smaller impacts to aquatic resources than the proposed renewal of IP2 and IP3, though all have 15 larger impacts than the proposed renewal of IP2 and IP3 in at least one other resource area.

16 9.1.2 Irreversible or Irretrievable Resource Commitments 17 The commitment of resources related to construction and operation of IP2 and IP3 during the 18 current license period was made when the plant was built. The resource commitments to be 19 considered in this SEIS are associated with continued operation of the plant for an additional 20 20 years. These resources include materials and equipment required for plant maintenance, 21 operation, and refurbishment; the nuclear fuel used by the reactors; and ultimately, permanent 22 offsite storage space for the spent fuel assemblies.

23 Entergy may be required to commit additional resources should the final NYSDEC SPDES 24 permit require closed-cycle cooling (as required in the draft revised SPDES permit) and Entergy 25 decides to (1) build and operate a closed-cycle cooling system to meet the permit's required 26 reductions in impacts to aquatic ecology, or (2) make other modifications that meet the terms of 27 the SPDES permit without retrofitting to closed-cycle cooling. However, regardless of the future 28 status of the SPDES permit, significant resource commitments will be required during the 29 renewal term for additional fuel and the permanent spent fuel storage space. IP2 and IP3 30 replace a portion of their fuel assemblies during every refueling outage, which typically occurs 31 on a 24-month cycle (Entergy 2007a). Additional resources would also be committed to 32 constructing and installing new reactor vessel heads and CRDMs.

33 The likely energy alternatives would also require a commitment of resources for construction of 34 the replacement facilities, implementation of conservation measures, and in some cases, fuel to 35 run plants. Significant resource commitments would also be required for development of 36 transmission capacity. These resource commitments, however, would not necessarily come 37 from Entergy as Entergy currently has no obligation to support power production in the New 38 York area should IP2 and IP3 permanently shut down.

39 I NUREG-1437, Supplement 38 9-6 December 2010 OAGI0001367A_00420

Summary and Conclusions 1 9.1.3 Short-Term Use Versus Long-Term Productivity 2 An initial balance between local short-term uses of the environment and maintenance and 3 enhancement of long-term productivity at IP2 and IP3 was set when the plant was approved and 4 construction began. Renewal of the operating licenses for IP2 and IP3 and continued operation 5 of the plant would not alter the existing balance, but may postpone the availability of the site for 6 other uses. Denial of the application to renew the operating licenses would lead to a shutdown 7 of the plant that will alter the balance in a manner that depends on subsequent uses of the site.

8 Furthermore, new replacement energy sources or conservation options will establish new 9 balances at their respective locations.

10 9.2 Relative Significance of the Environmental Impacts of 11 License Renewal and Alternatives 12 The proposed action is renewal of the operating licenses for IP2 and IP3. Chapter 2 describes 13 the site, power plant, and interactions of the plant with the environment. Chapters 3 through 7 14 discuss environmental issues associated with renewal of the operating licenses. Environmental 15 issues associated with the no-action alternative and alternatives such as new power generation, 16 purchased power, conservation, and cooling system modifications are discussed in Chapter 8.

17 The significance of the environmental impacts from the proposed action (approval of the 18 application for renewal of the operating licenses), the no-action alternative (denial of the 19 application), an alternative involving altering plant operations to comply with the NYSDEC draft 20 SPDES discharge permit, construction of gas-fired generating capacity at alternate sites, gas-21 fired generation of power at IP2 and IP3, and two combinations of alternatives are compared in 22 Table 9-1. All new fossil-fueled alternatives presented in Table 9-1 are assumed to use closed-23 cycle cooling systems given current New York State regulations for new power plants.

24 Table 9-1 shows the significance of the plant-specific environmental effects of the proposed 25 action (renewal of IP2 and IP3 operating licenses) as well as the environmental effects of 26 alternatives to the proposed action. Impacts from license renewal would be SMALL for all 27 impact categories except aquatic ecology, which includes the impacts of heat shock, 28 entrainment, and impingement. Chapter 4 of this SEIS describes the MODERATE impacts of 29 plant operation on aquatic ecology through impingement and entrainment (impact levels vary by 30 species), and the potentially SMALL to LARGE impacts from thermal shock. Overall, impacts to 31 aquatic ecology from continued operation of IP2 and IP3 without cooling system modifications or 32 restoration actions are SMALL to LARGE. A single significance level was not assigned for the 33 collective offsite radiological impacts from the fuel cycle and from high-level radioactive waste 34 spent fuel disposal (see Chapter 6) or for the impacts of greenhouse gases (GHG).

35 The NRC staff is analysis indicates that the no-action alternative has the smallest effect, but it 36 would necessitate additional actions to replace generation capacity (whether with newly-37 constructed power plants or purchased power) and/or to institute conservation programs.

38 Impacts of the likely consequences of the no-action alternative would be similar to those of the 39 energy alternatives that the NRC staff considered. All other alternative actions have impacts in 40 at least four resource areas that reach SMALL to MODERATE or higher significance. Often, 41 these impacts are the result of constructing new facilities or infrastructure.

December 2010 9-7 NUREG-1437, Supplement 38 I OAGI0001367A_00421

Summary and Conclusions 1 9.3 Conclusions and Recommendations 2 Based on (1) the analysis and findings in the GElS, (2) the ER and other information submitted 3 by Entergy, (3) consultation with Federal, State, Tribal, and local agencies, (4) the NRC staff's 4 consideration of public scoping comments received, and comments on the draft SEIS, and (5) 5 the NRC staff's independent review, the recommendation of the NRC staff is that the 6 Commission determine that the adverse environmental impacts of license renewal for IP2 and 7 IP3 are not so great that preserving the option of license renewal for energy planning decision 8 makers would be unreasonable.

I NUREG-1437, Supplement 38 9-8 December 2010 OAGI0001367A_00422

Summary and Conclusions 1 Table 9-1. Summary of Environmental Significance of License Renewal and Alternatives Proposed No-Action License Action Alternative(b) Renewal with NGCC I New Closed-Impact License Plant At the IP Site or a Category Renewal Shutdown Cycle Cooling Repowered Site At a New Site I Land Use SMALL to SMALL to SMALL SMALL LARGE MODERATE MODERATE to LARGE I Ecology- MODERATE I Aquatic and SMALL to LARGE(a)

SMALL SMALL SMALL SMALL I Ecology- SMALL to Terrestrial SMALL SMALL MODERATE SMALL SMALL to MODERATE I Water Use and Quality SMALL SMALL SMALL SMALL SMALL to MODERATE I Air Quality SMALL to SMALL to SMALL SMALL SMALL to MODERATE LARGE MODERATE Waste SMALL to SMALL SMALL SMALL SMALL LARGE Human Health SMALL Ie) SMALL SMALL SMALL SMALL Socioeconomics SMALL to SMALL to SMALL SMALL SMALL to MODERATE MODERATE MODERATE T ranspo rtati on SMALL to SMALL to SMALL SMALL LARGE MODERATE SMALL to MODERATE I Aesthetics MODERATE SMALL SMALL SMALL SMALL to LARGE Historical and to LARGE I SMALL to SMALL to Archeological SMALL SMALL SMALL to MODERATE Resources MODERATE MODERATE I Environmental Justice SMALL SMALL SMALL SMALL to LARGE SMALL to LARGE I 2

3 NUREG-1437, Supplement 38 9-9 December 2010 I OAGI0001367A_00423

Summary and Conclusions 1 Table 9-1 (continued)

Conservation/Energy Combination of Alternatives Efficiency Option 2:

Option 1:

Gas, offsite One IP unit, onsite gas, Impact Category renewables, additional offsite renewables, and imported power, and conservation conservation Land Use SMALL to SMALL SMALLto MODERATE MODERATE Ecology - Aquatic SMALL SMALL to LARGE SMALL to LARGE Ecology - Terrestrial SMALL to SMALL to SMALL LARGE LARGE Water Use and Quality SMALL SMALL to LARGE SMALL to LARGE Air Quality SMALL to SMALL SMALL to MODERATE MODERATE Waste SMALL SMALL to LARGE SMALL to LARGE Human Health SMALL SMALL SMALL Socioeconomics SMALL to SMALL to MODERATE SMALL MODERATE Transportation MODERATE SMALL MODERATE Aesthetics SMALL SMALL to LARGE SMALL to LARGE Historical and Archeological SMALL SMALL to MODERATE SMALL to MODERATE Resources Environmental Justice SMALL SMALL to LARGE SMALL to LARGE (a) NRC staff analysis indicates that impingement and entrainment impacts are MODERATE, but that thermal shock effects could potentially range from SMALL to LARGE.

(b) The no-action alternative does not, on its own, meet the purpose and need of the GElS. No action would necessitate other generation or conservation actions which may include-but are not limited to-the alternatives addressed in this table.

(c) For the collective offsite radiological impacts from the fuel cycle and from high-level waste and spent fuel disposal, a specific significance level was not assigned. See Chapter 6 for details.

(d) Analysis was based on use of a closed-cycle cooling system.

2 3

4 5

6 7

8 I NUREG-1437, Supplement 38 9-10 August 2010 OAGI0001367A_00424

Summary and Conclusions 1 9.4 References 2 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for 3 Protection Against Radiation."

4 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 5 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

6 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for 7 Renewal of Operating Licenses for Nuclear Power Plants."

8 72 FR 45705. "Entergy Nuclear Operations, Inc., Indian Point Nuclear Generating Unit Nos. 2 9 and 3; Notice of Intent To Prepare an Environmental Impact Statement and Conduct Scoping 10 Process." August 10, 2007 11 Entergy Nuclear Operations, Inc. (Entergy). 2007a. "Indian Point, Units 2 & 3, License 12 Renewal Application." April 23, 2007. Agencywide Documents Access and Management 13 System (ADAMS) Accession No. ML071210512.

14 Entergy Nuclear Operations, Inc. (Entergy). 2007b. "Applicant's Environment Report, 15 Operating License Renewal Stage." (Appendix E to Indian Point, Units 2 and 3, License 16 Renewal Application). April 23, 2007. ADAMS Accession No. ML071210530.

17 National Environmental Policy Act of 1969, as amended (NEPA). 42 USC 4321, et seq.

18 Nuclear Regulatory Commission (NRC). 1996. NUREG-1437, Volumes 1 and 2, "Generic 19 Environmental Impact Statement for License Renewal of Nuclear Power Plants (GElS)."

20 Washington, DC. May 1996.

21 Nuclear Regulatory Commission (NRC). 1999. NUREG-1437, Volume 1, Addendum 1, 22 "Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Main Report,"

23 Section 6.3, "Transportation," Table 9.1, "Summary of Findings on NEPA Issues for License 24 Renewal of Nuclear Power Plants, Final Report." Washington, DC.

25 Nuclear Regulatory Commission (NRC). 2000. NUREG-1555, Supplement 1, "Standard 26 Review Plans for Environmental Reviews for Nuclear Power Plants, Supplement 1: Operating 27 License Renewal." Washington, DC.

NUREG-1437, Supplement 38 9-11 December 2010 I OAGI0001367A_00425

Summary and Conclusions 1 in Cortlandt Manor, New York, on February 12, 2009 and presented the preliminary results of 2 the NRC environmental review, answered questions from the public, and received comments on 3 the draft SEIS. The NRC staff considered and addressed all of the comments received. The 4 comments are reflected in this SEIS and/or addressed in Part 2 of Appendix A to this final SEIS.

5 This SEIS includes the NRC staff's analysis that considers and weighs the environmental 6 effects of the proposed action (including cumulative impacts), the environmental impacts of 7 alternatives to the proposed action, and mitigation measures available for reducing or avoiding 8 adverse effects. This SEIS also includes the NRC staff's recommendation regarding the 9 proposed action.

10 The NRC has adopted the following statement of purpose and need for license renewal from the 11 GElS:

12 The purpose and need for the proposed action (renewal of an operating license) 13 is to provide an option that allows for power generation capability beyond the 14 term of a current nuclear power plant operating license to meet future system 15 generating needs, as such needs may be determined by State, utility, and, where 16 authorized, Federal (other than NRC) decision makers.

17 The evaluation criterion for the NRC staff's environmental review, as defined in 18 10 CFR 51.95(c)(4) and the GElS, is to determine the following:

19 ... whether or not the adverse environmental impacts of license renewal are so 20 great that preserving the option of license renewal for energy planning 21 decisionmakers would be unreasonable.

22 Both the statement of purpose and need and the evaluation criterion implicitly acknowledge that 23 there are factors, in addition to license renewal, that will ultimately determine whether an 24 existing nuclear power plant continues to operate beyond the period of the current operating 25 licenses.

26 NRC regulations (10 CFR 51.95(c) (2)) contain the following statement regarding the content of 27 SEISs prepared at the license renewal stage:

28 The supplemental environmental impact statement for license renewal is not 29 required to include discussion of need for power or the economic costs and 30 economic benefits of the proposed action or of alternatives to the proposed 31 action except insofar as such benefits and costs are either essential for a 32 determination regarding the inclusion of an alternative in the range of alternatives 33 considered or relevant to mitigation. In addition, the supplemental environmental 34 impact statement prepared at the license renewal stage need not discuss other 35 issues not related to the environmental effects of the proposed action and the 36 alternatives, or any aspect of the storage of spent fuel for the facility within 37 thescope of the generic determination in 10 CFR 51.23(a) and in accordance 38 with 10 CFR 51.23(b).(2)

(2)

The title of 10 CFR 51.23 is "Temporary storage of spent fuel after cessation of reactor operation-generic determination of no significant environmental impact."

NUREG-1437, Supplement 38 9-2 December 2010 OAGI0001367A_00426

Summary and Conclusions 1 The GElS contains the results of a systematic evaluation of the consequences of renewing an 2 operating license and operating a nuclear power plant for an additional 20 years. It evaluates 3 92 environmental issues using the NRC's three-level standard of significance-SMALL, 4 MODERATE, or LARGE-developed using the Council on Environmental Quality (CEQ) 5 guidelines. The following definitions of the three significance levels are set forth in the 6 footnotes to Table B-1 of Appendix B to Subpart A, "Environmental Effect of Renewing the 7 Operating License of a Nuclear Power Plant," of 10 CFR Part 51:

8 SMALL-Environmental effects are not detectable or are so minor that they will 9 neither destabilize nor noticeably alter any important attribute of the resource.

10 MODERATE-Environmental effects are sufficient to alter noticeably, but not to 11 destabilize, important attributes of the resource.

12 LARGE-Environmental effects are clearly noticeable and are sufficient to 13 destabilize important attributes of the resource.

14 For 69 of the 92 environmental issues considered in the GElS, the analysis in the GElS reached 15 the following conclusions:

16 (1) The environmental impacts associated with the issue have been determined to apply 17 either to all plants or, for some issues, to plants having a specific type of cooling system 18 or other specified plant or site characteristics.

19 (2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 20 the impacts (except for collective offsite radiological impacts from the fuel cycle and from 21 high-level waste and spent fuel disposal).

22 (3) Mitigation of adverse impacts associated with the issue has been considered in the 23 analysis, and it has been determined that additional plant-specific mitigation measures 24 are likely not to be sufficiently beneficial to warrant implementation.

25 These 69 issues were identified in the GElS as Category 1 issues. In the absence of new and 26 significant information, the NRC staff relied on conclusions as amplified by supporting 27 information in the GElS for issues designated as Category 1 in 10 CFR Part 51, Subpart A, 28 Appendix B, Table B-1.

29 Of the 23 issues that do not meet the criteria set forth above, 21 are classified as Category 2 30 issues requiring analysis in a plant-specific SEIS. The remaining two issues, environmental 31 justice and chronic effects of electromagnetic fields, were not categorized.

32 This SEIS documents the NRC staff's consideration of all 92 environmental issues identified in 33 the GElS. The NRC staff considered the environmental impacts associated with alternatives to 34 license renewal and compared the environmental impacts of license renewal and the 35 alternatives. The alternatives to license renewal that were considered include the no-action 36 alternative (not renewing the operating licenses for IP2 and IP3), continued operation of either 37 IP2 or IP3, alternative methods of power generation, and conservation. The NRC staff also 38 considered an alternative that included continued operation of IP2 and IP3 with a closed-cycle 39 cooling system.

December 2010 9-3 NUREG-1437, Supplement 38 I OAGI0001367A_00427

Summary and Conclusions 1 9.1 Environmental Impacts of the Proposed Action-2 License Renewal 3 The NRC staff has established an independent process for identifying and evaluating the 4 significance of any new information on the environmental impacts of license renewal. The NRC 5 staff has not identified any information that is both new and significant related to Category 1 6 issues that would call into question the conclusions in the GElS. In the IP2 and IP3 ER, Entergy 7 identified leakage from onsite spent fuel pools as potentially new and significant information 8 (Entergy 2007b). The NRC staff has reviewed Entergy's analysis of the leakage and has 9 conducted an extensive onsite inspection of leakage to ground water, as identified in Section 10 2.2.7 of this SEIS. Based on the NRC staff's review of Entergy's analysis, the NRC staff's 11 adoption of the NRC inspection report findings in this SEIS, and Entergy's subsequent 12 statements (all discussed in Section 2.2.7), the NRC staff concludes that the abnormal liquid 13 releases discussed by Entergy in its ER, while new information, are within the NRC's radiation 14 safety standards contained in 10 CFR Part 20 and are not considered to have a significant 15 impact on plant workers, the public, or the environment (i.e., while the information related to 16 spent fuel pool leakage is new, it is not significant). Therefore, the NRC staff relied upon the 17 conclusions of the GElS for all Category 1 issues that are applicable to IP2 and IP3.

18 Entergy's license renewal application contains an analysis of the Category 2 issues that are 19 applicable to IP2 and IP3, plus environmental justice and chronic effects from electromagnetic 20 fields for a total of 23 issues. The NRC staff has reviewed the Entergy analysis and has 21 conducted an independent review of each issue. Six of the Category 2 issues are not 22 applicable because they are related to cooling systems, water use conflicts, and ground water 23 use not found at IP2 and IP3.

24 As discussed in Chapter 3, scoping comments revealed-and Entergy indicated-that Entergy 25 may replace reactor vessel heads and control rod drive mechanisms (CRDMs) in both units. As 26 a result, the NRC staff addressed the impacts of these replacement activities in Chapter 3. This 27 includes three Category 2 issues that apply only to refurbishment, six Category 2 issues that 28 apply to refurbishment and continued operation, and one uncategorized issue, environmental 29 justice, that applies to both refurbishment and continued operations. The NRC staff determined 30 that all effects from refurbishment activities are of SMALL significance.

31 The NRC staff addresses twelve Category 2 issues related to impacts from continued 32 operations and postulated accidents during the renewal term, as well as environmental justice 33 and chronic effects of electromagnetic fields. Research is continuing in the area of chronic 34 effects on electromagnetic fields, and a scientific consensus has not been reached. Therefore, 35 no further evaluation of this issue is required. The NRC staff concludes that the potential 36 environmental effects for 9 of the 12 categorized issues are of SMALL significance in the 37 context of the standards set forth in the GElS. The NRC staff concludes that the combined 38 impacts from impingement and entrainment (each a separate issue) are MODERATE. Impacts 39 from heat shock could range from SMALL to LARGE, based on the large uncertainties 40 discussed in Chapter 4. Based on corrected data received since the completion of the draft 41 SEIS, the NRC staff concludes that impacts to the endangered shortnose sturgeon which 42 ranged from SMALL to LARGE in the draft SEIS are likely to be SMALL.

43 For severe accident mitigation alternatives (SAMAs), the NRC staff concludes that a NUREG-1437, Supplement 38 9-4 December 2010 OAGI0001367A_00428

Summary and Conclusions 1 reasonable, comprehensive effort was made by Entergy to identify and evaluate SAMAs.

2 Based on its review of the SAMAs for IP2 and IP3, and the plant improvements already made, 3 the NRC staff concludes that several candidate SAMAs may be cost-beneficial. However, these 4 SAMAs do not relate to adequately managing the effects of aging during the period of extended 5 operation. Therefore, they need not be implemented as part of license renewal pursuant to 6 10 CFR Part 54.

7 For all issues of SMALL significance, current measures to mitigate the environmental impacts of 8 plant operation were found to be adequate. For issues of MODERATE or LARGE significance 9 (i.e., issues related to aquatic ecology), mitigation measures are addressed both in Chapter 4 10 and in Chapter 8 as alternatives based on determinations in the draft New York State 11 Department of Environmental Conservation (NYSDEC) State Pollutant Discharge Elimination 12 System (SPDES) permit proceeding, Clean Water Act Section 401 proceeding, and in draft 13 policy statements published by the State. In Chapter 8, the NRC staff considers the impacts 14 that may result if the plant converts from once-through cooling to a closed-cycle cooling system 15 (Section 8.1.1).

16 Cumulative impacts of past, present, and reasonably foreseeable future actions were 17 considered, regardless of what agency (Federal or non-Federal) or person undertakes such 18 other actions. The NRC staff concludes that the cumulative impacts to the environment around 19 IP2 and IP3 license renewal would be LARGE for some affected resources, given historical 20 environmental impacts, current actions, and likely future actions. With the exception of aquatic 21 resources, the contribution of IP2 and IP3 to cumulative impacts is SMALL.

22 The following sections discuss unavoidable adverse impacts, irreversible or irretrievable 23 commitments of resources, and the relationship between local short-term use of the 24 environment and long-term productivity.

25 December 2010 9-5 NUREG-1437, Supplement 38 I OAGI0001367A_00429

Summary and Conclusions 1 9.1.1 Unavoidable Adverse Impacts 2 An environmental review conducted at the license renewal stage differs from the review 3 conducted in support of a construction permit or operating license because the plant is in 4 existence at the license renewal stage and has operated for a number of years. As a result, 5 adverse impacts associated with the initial construction and operation have already occurred, 6 have been mitigated, or have been avoided. The environmental impacts to be evaluated for 7 license renewal are those associated with refurbishment and continued operation during the 8 renewal term.

9 Adverse impacts of continued operation from (a) heat shock and (b) the combined effects of 10 entrainment and impingement of fish and shellfish are considered to be potentially SMALL to 11 LARGE, and MODERATE, respectively. Other adverse impacts are considered to be of SMALL 12 significance.

13 Adverse impacts of likely alternatives to the operation of IP2 and IP3 vary greatly. Many have 14 smaller impacts to aquatic resources than the proposed renewal of IP2 and IP3, though all have 15 larger impacts than the proposed renewal of IP2 and IP3 in at least one other resource area.

16 9.1.2 Irreversible or Irretrievable Resource Commitments 17 The commitment of resources related to construction and operation of IP2 and IP3 during the 18 current license period was made when the plant was built. The resource commitments to be 19 considered in this SEIS are associated with continued operation of the plant for an additional 20 20 years. These resources include materials and equipment required for plant maintenance, 21 operation, and refurbishment; the nuclear fuel used by the reactors; and ultimately, permanent 22 offsite storage space for the spent fuel assemblies.

23 Entergy may be required to commit additional resources should the final NYSDEC SPDES 24 permit require closed-cycle cooling (as required in the draft revised SPDES permit) and Entergy 25 decides to (1) build and operate a closed-cycle cooling system to meet the permit's required 26 reductions in impacts to aquatic ecology, or (2) make other modifications that meet the terms of 27 the SPDES permit without retrofitting to closed-cycle cooling. However, regardless of the future 28 status of the SPDES permit, significant resource commitments will be required during the 29 renewal term for additional fuel and the permanent spent fuel storage space. IP2 and IP3 30 replace a portion of their fuel assemblies during every refueling outage, which typically occurs 31 on a 24-month cycle (Entergy 2007a). Additional resources would also be committed to 32 constructing and installing new reactor vessel heads and CRDMs.

33 The likely energy alternatives would also require a commitment of resources for construction of 34 the replacement facilities, implementation of conservation measures, and in some cases, fuel to 35 run plants. Significant resource commitments would also be required for development of 36 transmission capacity. These resource commitments, however, would not necessarily come 37 from Entergy as Entergy currently has no obligation to support power production in the New 38 York area should IP2 and IP3 permanently shut down.

39 I NUREG-1437, Supplement 38 9-6 December 2010 OAGI0001367A_00430

Summary and Conclusions 1 9.1.3 Short-Term Use Versus Long-Term Productivity 2 An initial balance between local short-term uses of the environment and maintenance and 3 enhancement of long-term productivity at IP2 and IP3 was set when the plant was approved and 4 construction began. Renewal of the operating licenses for IP2 and IP3 and continued operation 5 of the plant would not alter the existing balance, but may postpone the availability of the site for 6 other uses. Denial of the application to renew the operating licenses would lead to a shutdown 7 of the plant that will alter the balance in a manner that depends on subsequent uses of the site.

8 Furthermore, new replacement energy sources or conservation options will establish new 9 balances at their respective locations.

10 9.2 Relative Significance of the Environmental Impacts of 11 License Renewal and Alternatives 12 The proposed action is renewal of the operating licenses for IP2 and IP3. Chapter 2 describes 13 the site, power plant, and interactions of the plant with the environment. Chapters 3 through 7 14 discuss environmental issues associated with renewal of the operating licenses. Environmental 15 issues associated with the no-action alternative and alternatives such as new power generation, 16 purchased power, conservation, and cooling system modifications are discussed in Chapter 8.

17 The significance of the environmental impacts from the proposed action (approval of the 18 application for renewal of the operating licenses), the no-action alternative (denial of the 19 application), an alternative involving altering plant operations to comply with the NYSDEC draft 20 SPDES discharge permit, construction of gas-fired generating capacity at alternate sites, gas-21 fired generation of power at IP2 and IP3, and two combinations of alternatives are compared in 22 Table 9-1. All new fossil-fueled alternatives presented in Table 9-1 are assumed to use closed-23 cycle cooling systems given current New York State regulations for new power plants.

24 Table 9-1 shows the significance of the plant-specific environmental effects of the proposed 25 action (renewal of IP2 and IP3 operating licenses) as well as the environmental effects of 26 alternatives to the proposed action. Impacts from license renewal would be SMALL for all 27 impact categories except aquatic ecology, which includes the impacts of heat shock, 28 entrainment, and impingement. Chapter 4 of this SEIS describes the MODERATE impacts of 29 plant operation on aquatic ecology through impingement and entrainment (impact levels vary by 30 species), and the potentially SMALL to LARGE impacts from thermal shock. Overall, impacts to 31 aquatic ecology from continued operation of IP2 and IP3 without cooling system modifications or 32 restoration actions are SMALL to LARGE. A single significance level was not assigned for the 33 collective offsite radiological impacts from the fuel cycle and from high-level radioactive waste 34 spent fuel disposal (see Chapter 6) or for the impacts of greenhouse gases (GHG).

35 The NRC staff is analysis indicates that the no-action alternative has the smallest effect, but it 36 would necessitate additional actions to replace generation capacity (whether with newly-37 constructed power plants or purchased power) and/or to institute conservation programs.

38 Impacts of the likely consequences of the no-action alternative would be similar to those of the 39 energy alternatives that the NRC staff considered. All other alternative actions have impacts in 40 at least four resource areas that reach SMALL to MODERATE or higher significance. Often, 41 these impacts are the result of constructing new facilities or infrastructure.

December 2010 9-7 NUREG-1437, Supplement 38 I OAGI0001367A_00431

Summary and Conclusions 1 9.3 Conclusions and Recommendations 2 Based on (1) the analysis and findings in the GElS, (2) the ER and other information submitted 3 by Entergy, (3) consultation with Federal, State, Tribal, and local agencies, (4) the NRC staff's 4 consideration of public scoping comments received, and comments on the draft SEIS, and (5) 5 the NRC staff's independent review, the recommendation of the NRC staff is that the 6 Commission determine that the adverse environmental impacts of license renewal for IP2 and 7 IP3 are not so great that preserving the option of license renewal for energy planning decision 8 makers would be unreasonable.

I NUREG-1437, Supplement 38 9-8 December 2010 OAGI0001367A_00432

Summary and Conclusions 1 Table 9-1. Summary of Environmental Significance of License Renewal and Alternatives Proposed No-Action License Action Alternative(b) Renewal with NGCC I New Closed-Impact License Plant At the IP Site or a Category Renewal Shutdown Cycle Cooling Repowered Site At a New Site I Land Use SMALL to SMALL to SMALL SMALL LARGE MODERATE MODERATE to LARGE I Ecology- MODERATE I Aquatic and SMALL to LARGE(a)

SMALL SMALL SMALL SMALL I Ecology- SMALL to Terrestrial SMALL SMALL MODERATE SMALL SMALL to MODERATE I Water Use and Quality SMALL SMALL SMALL SMALL SMALL to MODERATE I Air Quality SMALL to SMALL to SMALL SMALL SMALL to MODERATE LARGE MODERATE Waste SMALL to SMALL SMALL SMALL SMALL LARGE Human Health SMALL Ie) SMALL SMALL SMALL SMALL Socioeconomics SMALL to SMALL to SMALL SMALL SMALL to MODERATE MODERATE MODERATE T ranspo rtati on SMALL to SMALL to SMALL SMALL LARGE MODERATE SMALL to MODERATE I Aesthetics MODERATE SMALL SMALL SMALL SMALL to LARGE Historical and to LARGE I SMALL to SMALL to Archeological SMALL SMALL SMALL to MODERATE Resources MODERATE MODERATE I Environmental Justice SMALL SMALL SMALL SMALL to LARGE SMALL to LARGE I 2

3 December 2010 9-9 NUREG-1437, Supplement 38 I OAGI0001367A_00433

Summary and Conclusions 1 Table 9-1 (continued)

Conservation/Energy Combination of Alternatives Efficiency Option 2:

Option 1:

Gas, offsite One IP unit, onsite gas, Impact Category renewables, additional offsite renewables, and imported power, and conservation conservation Land Use SMALL to SMALL SMALLto MODERATE MODERATE Ecology - Aquatic SMALL SMALL to LARGE SMALL to LARGE Ecology - Terrestrial SMALL to SMALL to SMALL LARGE LARGE Water Use and Quality SMALL SMALL to LARGE SMALL to LARGE Air Quality SMALL to SMALL SMALL to MODERATE MODERATE Waste SMALL SMALL to LARGE SMALL to LARGE Human Health SMALL SMALL SMALL Socioeconomics SMALL to SMALL to MODERATE SMALL MODERATE Transportation MODERATE SMALL MODERATE Aesthetics SMALL SMALL to LARGE SMALL to LARGE Historical and Archeological SMALL SMALL to MODERATE SMALL to MODERATE Resources Environmental Justice SMALL SMALL to LARGE SMALL to LARGE (a) NRC staff analysis indicates that impingement and entrainment impacts are MODERATE, but that thermal shock effects could potentially range from SMALL to LARGE.

(b) The no-action alternative does not, on its own, meet the purpose and need of the GElS. No action would necessitate other generation or conservation actions which may include-but are not limited to-the alternatives addressed in this table.

(c) For the collective offsite radiological impacts from the fuel cycle and from high-level waste and spent fuel disposal, a specific significance level was not assigned. See Chapter 6 for details.

(d) Analysis was based on use of a closed-cycle cooling system.

2 3

4 5

6 7

8 I NUREG-1437, Supplement 38 9-10 December 2010 OAGI0001367A_00434

Summary and Conclusions 1 9.4 References 2 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for 3 Protection Against Radiation."

4 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 5 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

6 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for 7 Renewal of Operating Licenses for Nuclear Power Plants."

8 72 FR 45705. "Entergy Nuclear Operations, Inc., Indian Point Nuclear Generating Unit Nos. 2 9 and 3; Notice of Intent To Prepare an Environmental Impact Statement and Conduct Scoping 10 Process." August 10, 2007 11 Entergy Nuclear Operations, Inc. (Entergy). 2007a. "Indian Point, Units 2 & 3, License 12 Renewal Application." April 23, 2007. Agencywide Documents Access and Management 13 System (ADAMS) Accession No. ML071210512.

14 Entergy Nuclear Operations, Inc. (Entergy). 2007b. "Applicant's Environment Report, 15 Operating License Renewal Stage." (Appendix E to Indian Point, Units 2 and 3, License 16 Renewal Application). April 23, 2007. ADAMS Accession No. ML071210530.

17 National Environmental Policy Act of 1969, as amended (NEPA). 42 USC 4321, et seq.

18 Nuclear Regulatory Commission (NRC). 1996. NUREG-1437, Volumes 1 and 2, "Generic 19 Environmental Impact Statement for License Renewal of Nuclear Power Plants (GElS)."

20 Washington, DC. May 1996.

21 Nuclear Regulatory Commission (NRC). 1999. NUREG-1437, Volume 1, Addendum 1, 22 "Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Main Report,"

23 Section 6.3, "Transportation," Table 9.1, "Summary of Findings on NEPA Issues for License 24 Renewal of Nuclear Power Plants, Final Report." Washington, DC.

25 Nuclear Regulatory Commission (NRC). 2000. NUREG-1555, Supplement 1, "Standard 26 Review Plans for Environmental Reviews for Nuclear Power Plants, Supplement 1: Operating 27 License Renewal." Washington, DC.

December 2010 9-11 NUREG-1437, Supplement 38 I OAGI0001367A_00435

1 Appendix A 2

3 4 Comments Received on the Environmental Review OAGI0001367A_00436

1 Appendix A 2 Comments Received on the Environmental Review 3 Comments Received During Scoping and Scoping Summary Adoption 4 In this appendix, the NRC staff adopts the Scoping Summary Report for Indian Point Nuclear 5 Generating Unit Nos. 2 and 3 as prepared by the NRC staff in response to comments received 6 on the scope of the environmental review. The NRC staff issued the scoping summary report 7 on December 19, 2008. The Scoping Summary Report is available for public inspection in the 8 NRC Public Document Room (PDR), located at One White Flint North, 11555 Rockville Pike, 9 Rockville, Maryland, 20852, or from the NRC's Agencywide Documents Access and 10 Management System (ADAMS).

11 The ADAMS Public Electronic Reading Room is accessible at http://www.nrc.gov/reading-12 rm/adams/web-based.html. The scoping summary report is listed under Accession No.

13 ML083360115.

14 Persons who do not have access to ADAMS or who encounter problems in accessing the 15 documents located in ADAMS should contact the NRC's PDR reference staff by telephone at 1-16 800-397-4209, or 301-415-4737, or bye-mail at (2dr@nrc.gov.

17 On August 10,2007, the NRC published a Notice of Intent in the Federal Register (72 FR 18 45075) to notify the public of the Staff's intent to prepare a plant-specific supplement to the 19 GElS (SEIS) regarding the renewal application for the IP2 and IP3 operating license. As 20 outlined by NEPA, the NRC initiated the scoping process with the issuance of the Federal 21 Register Notice. The NRC invited the applicant, federal, state, local, and tribal government 22 agencies, local organizations, and individuals to participate in the scoping process by providing 23 oral comments at scheduled public meetings and/or submitting written suggestions and 24 comments no later than October 12,2007.

25 The scoping process included two public scoping meetings, which were both held on September 26 19,2007, at Colonial Terrace, 119 Oregon Road, Cortlandt Manor, New York. The NRC issued 27 press releases and distributed flyers locally. Both sessions began with NRC staff members 28 providing a brief overview of the license renewal process and the NEPA process. Following the 29 NRC's prepared statements, the meetings were open for public comments. Approximately 50 30 attendees provided oral comments that were recorded and transcribed by a certified court 31 reporter.

32 The meeting summary, which was issued on October 24, 2007, and the associated transcripts 33 can be found in the NRC PDR or in ADAMS at Accession No. ML072851079. The transcripts of 34 the meetings can be found in ADAMS at Accession Numbers ML072830682 and ML072890209.

35 The scoping summary contains all comments received on the review, as well as the NRC staff's 36 responses to those comments. Comments received on the draft SEIS will be included in this 37 Appendix of the final SEIS.

38 December 2010 A-1 NUREG-1437, Supplement 38 I OAGI0001367A_00437

Appendix A 1 A.1 Comments Received on the Draft SEIS 2 Pursuant to 10 CFR Part 51, the staff transmitted the Generic Environmental Impact Statement 3 for License Renewal of Nuclear Plants, Regarding Indian Point Nuclear Generating Units 2 and 4 3, Draft Report for Comment (NUREG-1437, Supplement 38, referred to as the draft SEIS) to 5 Federal, State, Native American Tribal, and local government agencies as well as interested 6 members of the public. As part of the process to solicit public comments on the DSEIS, the staff:

7

• placed a copy of the DSEIS in the NRC's electronic Public Document Room, its license 8 renewal website, White Plains Public Library( White Plains, NY), Hendrick Hudson Free Library 9 (Montrose, NY) and the Field Library(Peekskill, NY),

10

• sent copies of the DSEIS to the applicant, members of the public who requested copies, and 11 certain Federal, State, Native American Tribal, and local agencies, 12

• published a notice of availability of the DSEIS in the Federal Register on December 31, 2008, 13 (71 FR 75280),

14

• issued press releases and public announcements such as advertisements in local newspapers 15 and postings in public places announcing the issuance of the DSEIS, the public meetings, and 16 instructions on how to comment on the DSEIS, 17

• held public meetings in Cortlandt Manor, New York, on February 12, 2009, to describe the 18 results of the environmental review and answer related questions, 19

• established an e-mail address to receive comments on the DSEIS through the Internet.

20 During the DSEIS comment period, the staff received comments from 183 individuals or groups.

21 Eighty-eight commenters spoke during the public meetings. The staff reviewed the public 22 meeting transcripts and the comment letters that are part of the docket file for the application, all 23 of which are available in the NRC's Agencywide Documents Access Management System 24 (ADAMS). ADAMS is accessible at http://www.nrc.gov/reading-rm/adams.html. Appendix A, 25 Part II, Section A.2, contains a summary of the comments and the staff's responses. Appendix 26 A, Part II, Section A.3, contains the comment letters and commenters excerpts from the 27 transcripts. The comment period closed on March 18, 2009.

28 No individuals or groups requested an extension of the comment period. Several groups, 29 however, submitted comments months after the close of the comment period, most recently on 30 November 5,2010. The NRC staff found it impracticable to address these comments, and 31 those late-filed comments are not included in this appendix.

32 Each comment identified by the staff was assigned a specific commenter identifier (marker).

33 That identifier is typed in the letter's margin at the beginning of the comment discussion.

34 Table A-1. Individuals and/or Groups Providing Comments on the DSEIS.

35 Commenters appear in alphabetical order, and each commenter 36 has been given a unique commenter identification number.

Commenter Affiliation (if stated) Commenter 10 Number Adams, Kenneth Business Council of New York State 1 I NUREG-1437, Supplement 38 A-2 December 201 0 OAGI0001367A_00438

Appendix A Commenter Affiliation (if stated) Commenter 10 Number Allen, Judy Resident, Putnam Valley 2 American Citizen American Citizens 3 Anders, Fred NYS Office of Coastal, Local Government and 4 Community Sustainability Anthony, Rev. Dr. Cheryl Jude International Christian Center 5 Argintar, Herbert 6 Ball, Gregory New York State Assembly 7 Banfield, William Empire State Regional Council of Carpenters 8 Bard Center for Environmental Auropriya A. Reddy, Emily B. Fischer, Katherine C. 9 Policy Galbraith, Kristine E. Pierce, Shaylah C. Reagan, Michel N. Wahome, Matthew A. Guenther, Kaleena S.

Miller, Taryn L. Morris, Joshua Z. Jacobson, Jaclyn Harrison, Lindsay Chapman, Anne E. Kline, Than H.

Phoo, Daniel Smith Barthelme, Margaret Student, Ramapo College 10 Bartholomew, Alice 11 Bassi, Laura 12 Berasi, Pete 13 Bigby, Derry African American Environmentalist Association 14 Bittermann, Sister Rosemarie S1. Patrick Villa 15 Blades, Adam Student, Ramapo College 16 Blumenthal, Richard Connecticut, Attorney General 17 Boorman, Lindsay 18 Bowman, Reginald NYC Housing Authority's Resident Council 19 Brancato, Deborah Riverkeeper 20 Brennan, Chris 21 Bron, Gary 22 Burruss, Melvin African American Men of Westchester 23 Burton, Nancy Mothers Milk Project 24 Butler, Elizabeth 25 Byrd, Ricardo National Association of Neighborhoods 26 Calvani, Dorothy 27 Campbell, Joanne Albany Houses Tenants Association of Brooklyn 28 Capurso, Tom Local 3 29 Carmody, Greg Student, Ramapo College 30 Castro, Maria Hispanic Energy Coalition 31 December 2010 A-3 NUREG-1437, Supplement 38 OAGI0001367A_00439

Appendix A Commenter Affiliation (if stated) Commenter 10 Number Chernoff, Patricia 32 Clark, Pamela Hudson River Club 33 Clegg, Thomas 34 Cohen, Lisa 35 Connolly, Jerry Coalition of Labor for Energy and Jobs 36 Cooper, Loraine 37 Cypser, Betty Raging Grannies 38 Cypser, Rudy 39 Dacimo, Fred Entergy 40 Daly, Mary Ann 41 Davis, Darwin Greater Harlem Chamber of Commerce 42 Davis, Jill Hendrick Hudson Free Library 43 DeAngelo, Carol 44 Degraff, Rev. Jacques 100 Black Men 45 Digby, Derry African American Environmental Association 46 DiRocco, Steve 47 Donahue, Mayor AI Mayor, Town of Buchanan 48 Durett, Dan African American Environmentalists Association 49 Edelstein, Michael Ramapo College 50 Evans, Laurie Westchester SAFE 51 Falciano, Patrick 52 Federspiel, John Hudson Valley Hospital System 53 Feinberg, Janie 54 Filippelli, John United States Environmental Protection Agency 55 Fitzpatrick, Brian 56 Forehand, Ron Hudson Valley Gateway Chamber of Commerce 57 Form Letter 58 Foster, Mary Mayor, Peekskill 59 Fraiser, Andrew NextGen Network 60 Friedman, Carolyn Resident, Nyack 61 Frye, Glen Brooklyn Anti-Violence Coalition 62 Funck, John 63 Furgatch, Lisa 64 Garcia, Frank Bronx Hispanic Chamber of Commerce 65 I NUREG-1437, Supplement 38 A-4 December 201 0 OAGI0001367A_00440

Appendix A Commenter Affiliation (if stated) Commenter 10 Number Garisto, Mary Ann 66 Gordon, Marsha Business Council of Westchester 67 Grady, Peter 68 Raging Grannies 69 Gould, Ross Attorney (Working with HRSC) 70 Gray, Jennifer 71 Green, George 72 Greene, Manna Hudson River Sloop Clearwater 73 Hassman, Howard 74 Hawkins, Gerard Resident, Croton on Hudson 75 Helman, Lucille 76 Hirsh, Seth 77 Hohlfeld, Bill Local 46 Labor Management Cooperative Trust 78 Hudson River Sloop Clearwater, Manna Jo Greene, Ross Gould, Esq. 79 Inc.

Imoberdorf, Olivia 80 Indusi, Joan 81 Jacobs, Mark 82 Johnson, Tom Buchanan Firefighter 83 Karamaty, Valery Raging Grannies 84 Karas, Joe Carpenters Union Local 11 85 Kardos, Terry Resident, Cortlandt Manor 86 Kardos, Theresa Resident, Cortlandt Manor 87 Kearney, Gail 88 Keenan, Jennifer Student, Ramapo College 89 Kelly, John Entergy (retired Director of Licensing) 90 Ketchum, Arleen 91 Klein, Tom Boilermakers LocalS 92 Knolmayer, Liz Student, Ramapo College 93 Knubel, James New York AREA 94 Koldewyn, Kennis 95 Kopec, Eileen Student, Ramapo College 96 Kopshaw, Kaitlin Student, Ramapo College 97 Kourie, Kathleen Resident, Garrison 98 Kremer, Arthur NY AREA (Affordable Reliable Energy Alliance) 99 December 2010 A-5 NUREG-1437, Supplement 38 OAGI0001367A_00441

Appendix A Commenter Affiliation (if stated) Commenter 10 Number Lapido, Helen Resident, Cortlandt Manor 100 Ledwith, Robert Metallic Lathers Union and Reinforcing Ironworkers 101 Local 46 Lee, Michel Council on Intelligent Energy and Conservation Policy 102 Leifer, Susan Sierra Club 103 Likes, Philip 104 Ludwigson, Steve Boilermakers Local 5 105 Mallon, Sister Florence 106 Mangano, Joe Radiation and Public Health Project 107 Marzullo, Dominic Indian Point 108 Mattis, John Resident, Cortlandt 109 Maturo, Michael Orangetown Councilman 110 McCann, Dr. Daniel Superintendent, Hendrick Hudson School District 111 McCormick, John (enter for Environment Commerce and Energy) 112 McDonald, Norris (enter for Environment Commerce and Energy) 113 McGrath, John Easter Seals, New York 114 Miranda, George New York Teamsters Joint Council 16 115 Miranda, Rick Brooklyn Hispanic Chamber of Commerce 116 Mitchell, Grace Resident, Lower Hudson Valley 117 Montague, Virginia NY Coalition of 100 Black Women 118 Mooney, William Westchester County Association 119 Moore, Dr. Patrick Greenspirit Strategies, LLC 120 Murdock, Chad 121 Murphy, Regina 122 Musegaas, Phillip Riverkeeper 123 Myslinski, Melissa 124 Nemeczek, Jessica Student, Ramapo College 125 Newman, Janet West Branch Conservation Association 126 Nicklas, Donald Local 7 127 NYSDEC Joan Leary Matthews, John L. Parker 128 NYSO of the Attorney General Janice A. Dean, John Sipos, Lisa Feiner 129 Oros, George Westchester County Board of Legislators 130 Otis, Mike Professor, University 131 Parker, John NYSDEC Attorney, Region 3 132 Perry, Sharonee Former Brooklyn Community Board 133 NUREG-1437, Supplement 38 A-6 December 201 0 OAGI0001367A_00442

Appendix A Commenter Affiliation (if stated) Commenter 10 Number Perry, Donzella Resident, Brooklyn 134 Pilder, Leslie 135 Pockriss, Peter Director of Development for Historic Hudson Valley 136 Puglisi, Linda Supervisor, Town of Cortlandt 137 Race, Kira Student, Ramapo College 138 Raddant, Andrew u.S. Department of the Interior, Regional Environment 139 Officer Riverkeeper, Inc. Phillip Musegaas, Victor Tafur, Deborah Brancato 140 ROAR 141 Rogers, Sister Mary Christine 142 Rosenfeld, Alice Resident, Westchester County 143 Ryan, Thomas Boilermakers Local 5 144 Ryan, Martyn Resident, Rockland County 145 Safian, Keith Phelps Memorial Hospital 146 Sam brook, Andrea Resident, Mamaroneck 147 Samuels, AI Rockland Business Association 148 Scarola, Julianne Student, Ramapo College 149 Seeger, Bob Millwright and Machinery Erectors Local Union No. 150 740 Seeman, Laurie 151 Shapiro, Susan Sierra Club 152 Shaw, Gary 153 Shepard, Margo Westchester Citizens Awareness Network 154 Sherman, Andrea Resident, White Plains 155 Skanes, Brian Westchester Community Association 156 Slevin, James Utility Workers Local 1-2 157 Smith, Rev. George Robeson Mother AME Mount Zion Church in Harlem 158 Smith, Carol Orange County Chamber of Commerce 159 Sorbello, Dino 160 Starke, Alexis Resident, Hudson Valley 161 Sullivan, John 162 Swertfager, Diane Hendrick Hudson H.S. 163 Taormino, Michelle Student, Ramapo College 164 Tompkins, Dana Green Infrastructure LLC 165 Tracey, Michael International Association of Heat & Frost Insulators & 166 December 2010 A-7 NUREG-1437, Supplement 38 OAGI0001367A_00443

Appendix A Commenter Affiliation (if stated) Commenter 10 Number Allied Workers Local Union 91 Unknown (Sister Anne ?) 167 Various Authors 168 Vitale, Paul Business Council of Westchester 169 Walsh, Marion 170 Waltzer, Rosemary 171 Wanshel, Jeff 172 Warren, Roxanne 173 Weininger, Ellen Resident, White Plains 174 Weininger, Annette 175 Weinstein, Dava 176 Wilson, Craig SHARE 177 Withrow, Leigh 178 Wolf, Peter 179 Wood, Patti Grassroots Environmental Education 180 Yanofsky, John Paramount Center for the Arts 181 Yarme, Judith 182 Yaroscak-Lanzotti, Helen Resident, Yorktown Heights 183 1

2 I NUREG-1437, Supplement 38 A-8 December 201 0 OAGI0001367A_00444

Appendix A 1 Table A-2. Technical Issue Categories. Comments were divided into one of the 28 2 categories below, each of which has a unique abbreviation code.

3 Abbreviation Abbreviation Code Technical Issue Code Technical Issue AE Aquatic Ecology OM Operational Maintenance AL Alternatives ON Opposition to Nuclear AM Aging Management OP Operational Safety AS Aesthetics OR Opposition to Relicensing AQ Air Quality OS Out of Scope CI Cumulative Impacts PA Postulated Accidents CR Cultural Resources PS Psycho-Social Effects DC Decommissioning/Deregulation RE Remediation DE Demographics RG Regulatory EC Energy Costs/Energy Needs RI Radiological Impacts ED Editorial RF Refurbishment EJ Environmental Justice RW Radiological Waste Management EP Emergency Preparedness SA Safety GE GElS SE Support for Entergy GI General Environmental Impacts SF Spent Fuel Pool GL Global Warming SM SAMA GW Ground Water SO Socioeconomics HH Human Health Issues SR Support for Relicense LE Leaks ST Security & Terrorism LR License Renewal and its TE Terrestrial Ecology Process LU Land Use TL Transmission Lines MP Monitoring Programs TS Threatened and Endangered Species NE NEPA UF Uranium Fuel Cycle WA Water Use and Quality 4

5 December 2010 A-9 NUREG-1437, Supplement 38 OAGI0001367A_00445

Appendix A 1 Table A-3. Comments Received during Scoping Period. Comments are listed alphabetically 2 by commenter, and each comment has a unique comment identification code.

3 Comment ID Commenter Comment Comment ADAMS Source(a) Page No(s}. Accession Number 1-a-EC/SO/SR Adams, K. transcript 176 ML091410355 1-b-EC/SE Adams, K. transcript 176 ML091410355 1-c-EC/SO Adams, K. transcript 178 ML091410355 1-d-AQ/EC Adams, K. transcript 178 ML091410355 1-e-SR Adams, K. transcript 180 ML091410355 2-a-ALIRI Allen, J. transcript 181 ML091410354 2-b-HH/RI Allen, J. transcript 181 ML091410354 2-c-HH Allen, J. e-mail 184 ML090640367 3-a-AE/LE/LR American Citizen e-mail 186 ML090650458 4-a-AE/LR Anders, F. e-mail 187 ML090771329 4-b-ALlLR Anders, F. e-mail 188 ML090771329 4-c-LRISF Anders, F. e-mail 189 ML090771329 4-d-CI/LRISO Anders, F. e-mail 189 ML090771329 4-e-LR Anders, F. e-mail 190 ML090771329 5-a-AQ/SR Anthony, Rev. Dr. C. transcript 191 ML091410354 5-b-AQ/SR Anthony, Rev. Dr. C. transcript 192 ML091410354 5-c-AQ/SR Anthony, Rev. Dr. C. transcript 192 ML091410354 6-a-EP/OR Argintar, H. e-mail 193 ML090700173 7-a-SE/SL Ball, G. e-mail 194 ML090640373 7-b-AL Ball, G. e-mail 194 ML090640373 7-c-SO Ball, G. e-mail 194 ML090640373 7-d-AQ/EC/SR Ball, G. e-mail 194 ML090640373 7-e-SR Ball, G. e-mail 194 ML090640373 8-a-SR Banfield, W. e-mail 196 ML090700180 8-b-SO Banfield, W. e-mail 196 ML090700180 8-c-AQ/HH/SO Banfield, W. e-mail 196 ML090700180 8-d-SE/SR Banfield, W. e-mail 196 ML090700180 9-a-GI Bard Center for e-mail 197 ML090771343 Environmental Policy 9-b-ORISA Bard Center for e-mail 198 ML090771343 Environmental Policy 9-c-LE/PA/RW Bard Center for e-mail 198 ML090771343 Environmental Policy 9-d-EP Bard Center for e-mail 198 ML090771343 Environmental Policy 9-e-AE/AL Bard Center for e-mail 198 ML090771343 Environmental Policy 9-f-AL Bard Center for e-mail 198 ML090771343 Environmental Policy 9-g-ALISO Bard Center for e-mail 199 ML090771343 Environmental Policy 9-h-AE/ALIAQ Bard Center for e-mail 199 ML090771343 NUREG-1437, Supplement 38 A-10 December 201 0 OAGI0001367A_00446

Appendix A Comment ID Commenter Comment Comment ADAMS Source(a) Page No(s}. Accession Number Environmental Policy 9-i-ALIED Bard Center for e-mail 200 ML090771343 Environmental Policy 9-j-ALIED Bard Center for e-mail 202 ML090771343 Environmental Policy 10-a-PA Barthelme, M. transcript 204 ML091410355 10-b-AL Barthelme, M. transcript 204 ML091410355 10-c-GL Barthelme, M. transcript 204 ML091410355 10-d-PA Barthelme, M. e-mail 205 ML090720661 11-a-OR Bartholomew, A. e-mail 207 ML090650248 11-b-AE Bartholomew, A. e-mail 207 ML090650248 11-c-AE Bartholomew, A. e-mail 207 ML090650248 11-d-LE Bartholomew, A. e-mail 207 ML090650248 11-e-RW/ST Bartholomew, A. e-mail 207 ML090650248 11-f-ALIOR Bartholomew, A. e-mail 207 ML090650248 12-a-OR Bassi, L. e-mail 208 ML090700181 12-b-AE Bassi, L. e-mail 208 ML090700181 12-c-AE Bassi, L. e-mail 208 ML090700181 12-d-LE Bassi, L. e-mail 208 ML090700181 12-e-RW/ST Bassi, L. e-mail 208 ML090700181 12-f-AL Bassi, L. e-mail 208 ML090700181 13-a-OR Berasi, P. e-mail 209 ML090720667 13-b-AE Berasi, P. e-mail 209 ML090720667 13-c-PA/SF/ST Berasi, P. e-mail 209 ML090720667 13-d-PA/SF Berasi, P. e-mail 209 ML090720667 13-e-RW/UF Berasi, P. e-mail 209 ML090720667 13-f-AM/GE/OM Berasi, P. e-mail 209 ML090720667 13-g-DE/EP Berasi, P. e-mail 209 ML090720667 13-h-OR Berasi, P. e-mail 210 ML090720667 13-i-OR Berasi, P. e-mail 210 ML090720667 14-a-AQ/EJ/SR Bigby, D. hand-in 212 ML091740490 14-b-AQ/EJ/SR Bigby, D. hand-in 213 ML091740490 14-c-ALIAQ Bigby, D. hand-in 214 ML091740490 14-d-ALlEJ/GL Bigby, D. hand-in 214 ML091740490 14-e-SR Bigby, D. hand-in 216 ML091740490 15-a-OR Bittermann, Sister R. letter 217 ML090860661 16-a-DE/PA Blades, A. e-mail 218 ML090720679 16-b-PS/ST Blades, A. e-mail 218 ML090720679 16-c-EP/PA/PS Blades, A. e-mail 218 ML090720679 16-d-LR Blades, A. e-mail 219 ML090720679 17-a-NE/SF Blumenthal, R. e-mail 221 ML090720677 December 2010 A-11 NUREG-1437, Supplement 38 OAGI0001367A_00447

Appendix A Comment ID Commenter Comment Comment ADAMS Source(a) Page No(s}. Accession Number ML090820081 17-b-EP/ST Blumenthal, R. e-mail 221 ML090720677 ML090820081 17-c-NE Blumenthal, R. e-mail 222 ML090720677 ML090820081 17-d-DE Blumenthal, R. e-mail 224 ML090720677 ML090820081 17-e-NE/PA Blumenthal, R. e-mail 225 ML090720677 ML090820081 17-f-PA Blumenthal, R. e-mail 225 ML090720677 ML090820081 17-g-ST Blumenthal, R. e-mail 226 ML090720677 ML090820081 17-h-SF Blumenthal, R. e-mail 227 ML090720677 ML090820081 17-i-SF/ST Blumenthal, R. e-mail 227 ML090720677 ML090820081 17-j-SF Blumenthal, R. e-mail 227 ML090720677 ML090820081 17-k-SF/ST Blumenthal, R. e-mail 228 ML090720677 ML090820081 17-I-SF/ST Blumenthal, R. e-mail 229 ML090720677 ML090820081 17-m-EP Blumenthal, R. e-mail 230 ML090720677 ML090820081 17-n-EP/PA/ST Blumenthal, R. e-mail 230 ML090720677 ML090820081 17-o-AE/NE Blumenthal, R. e-mail 231 ML090720677 ML090820081 17-p-EP/PA/RI Blumenthal, R. e-mail 232 ML090720677 ML090820081 17-q-AE/NE Blumenthal, R. e-mail 233 ML090720677 ML090820081 17-r-EP/GI/RI Blumenthal, R. e-mail 234 ML090720677 ML090820081 18-a-LE/OR Boorman, L. e-mail 235 ML090720666 18-b-DE/ST Boorman, L. e-mail 235 ML090720666 18-c-AE Boorman, L. e-mail 235 ML090720666 18-d-OR Boorman, L. e-mail 235 ML090720666 19-a-EC/SR Bowman, R. transcript 236 ML091410354 19-b-EC/SO/SR Bowman, R. transcript 237 ML091410354 19-c-EC/SO/SR Bowman, R. transcript 238 ML091410354 I NUREG-1437, Supplement 38 A-12 December 201 0 OAGI0001367A_00448

Appendix A Comment ID Commenter Comment Comment ADAMS Source(a) Page No(s}. Accession Number 20-a-PA/SF1ST Brancato, D. transcript 239 ML091410354 20-b-HH Brancato, D. transcript 239 ML091410354 20-c-AE/OR Brancato, D. transcript 240 ML091410354 21-a-AE/ORISF Brennan, C. e-mail 242 ML090640369 21-b-GI/OR Brennan, C. e-mail 242 ML090640369 22-a-HH/OR/PA Bron, G. e-mail 243 ML090700171 23-a-SE/SR Burruss, M. transcript 244 ML091410355 23-b-SO Burruss, M. transcript 244 ML091410355 23-c-ALIAQ Burruss, M. transcript 244 ML091410355 23-d-EC Burruss, M. transcript 244 ML091410355 23-e-AQ Burruss, M. transcript 245 ML091410355 23-f-EC/SO Burruss, M. transcript 245 ML091410355 23-g-SR Burruss, M. transcript 246 ML091410355 23-h-ALIAQ Burruss, M. hand-in 247 ML091740490 23-i-EC/SO/SR Burruss, M. hand-in 247 ML091740490 24-a-HH/OR/RI Burton, N. transcript 248 ML091410354 24-b-HH/OR/RI Burton,N. hand-in 251 ML091740490 25-a-OR Butler, E. e-mail 255 ML090720676 26-a-EC/LR Byrd, R. transcript 256 ML091410354 26-b-OP Byrd, R. transcript 257 ML091410354 26-c-EC/SO/SR Byrd, R. transcript 258 ML091410354 27-a-OR Calvani, D. e-mail 259 ML090700183 27-b-AE Calvani, D. e-mail 259 ML090700183 27-c-AE Calvani, D. e-mail 259 ML090700183 27-d-LE Calvani, D. e-mail 259 ML090700183 27-e-SF/ST Calvani, D. e-mail 259 ML090700183 27-f-OR Calvani, D. e-mail 259 ML090700183 28-a-EC/SR Campbell, J. transcript 260 ML091410354 28-b-EC/SO Campbell, J. transcript 260 ML091410354 29-a-SO/SR Capurso, T. transcript 262 ML091410355 29-b-OP Capurso, T. transcript 262 ML091410355 29-c-EC/SA Capurso, T. transcript 262 ML091410355 30-a-ALlAQ/ASI Carmody, G. e-mail 265 ML090700187 EJ/GE 31-a-EJ/SR Castro, M. transcript 266 ML091410355 31-b-EC/EJ/HH Castro, M. transcript 266 ML091410355 31-c-AQ/SR Castro, M. transcript 266 ML091410355 32-a-AM/OP/PA Chernoff, P. e-mail 268 ML090640374 33-a-AE/GLILE Clark, P. e-mail 269 ML090640400 34-a-ALIEC Clegg, T. transcript 270 ML091410355 34-b-ALIEC Clegg, T. transcript 270 ML091410355 35-a-LE/OM Cohen, L. e-mail 272 ML909640370 December 2010 A-13 NUREG-1437, Supplement 38 OAGI0001367A_00449

Appendix A Comment ID Commenter Comment Comment ADAMS Source(a) Page No(s}. Accession Number 35-b-EP Cohen, L. e-mail 272 ML909640370 35-c-AM/RW Cohen, L. e-mail 272 ML909640370 35-d-OR Cohen, L. e-mail 272 ML909640370 35-e-OR/RE Cohen, L. e-mail 272 ML909640370 36-a-SR Connolly, J. transcript 273 ML091410355 36-b-OP Connolly, J. transcript 273 ML091410355 36-c-ALIAQ/EC Connolly, J. transcript 274 ML091410355 36-d-OP/SO Connolly, J. transcript 274 ML091410355 36-e-OP/SO Connolly, J. transcript 275 ML091410355 37-a-AE/OR Cooper, L. letter 276 ML091100401 37 -b-LE/SF/ST Cooper, L. letter 276 ML091100401 38-a-ON Cypser, B. transcript 277 ML091410354 38-b-PA/RW/ST Cypser, B. e-mail 278 ML090640364 38-c-RW/SF/ST Cypser, B. e-mail 278 ML090640364 38-d-AL Cypser, B. e-mail 278 ML090640364 38-e-RW/SF Cypser, B. e-mail 278 ML090640364 38-f-RW/SF Cypser, B. hand-in 279 ML091740490 38-g-RW Cypser, B. hand-in 279 ML091740490 38-h-ST Cypser, B. hand-in 279 ML091740490 38-i-RW Cypser, B. hand-in 279 ML091740490 39-a-RW/SF Cypser, R. transcript 280 ML091410355 39-b-LE Cypser, R. transcript 280 ML091410355 39-c-PA/ST Cypser, R. transcript 280 ML091410355 39-d-PA/ST Cypser, R. transcript 281 ML091410355 40-a-SR Dacimo, F. transcript 282 ML091410355 40-b-AE Dacimo, F. transcript 282 ML091410355 40-c-AE Dacimo, F. transcript 283 ML091410355 40-d-AE Dacimo, F. transcript 284 ML091410355 40-e-AE Dacimo, F. transcript 284 ML091410355 40-f-AE Dacimo, F. transcript 284 ML091410355 40-g-EC Dacimo, F. transcript 285 ML091410355 40-h-SR Dacimo, F. email 286 ML091040133 40-i-OS Dacimo, F. email 287 ML091040133 40-j-AE/AL Dacimo, F. email 287 ML091040133 40-k-AE Dacimo, F. email 292 ML091040133 40-I-ED Dacimo, F. email 292 ML091040133 40-m-ED Dacimo, F. email 292 ML091040133 40-n-AE/ED Dacimo, F. email 292 ML091040133 40-o-ED/RG Dacimo, F. email 292 ML091040133 40-p-AE Dacimo, F. email 293 ML091040133 40-q-AE Dacimo, F. email 293 ML091040133 40-r-AE Dacimo, F. email 294 ML091040133 I NUREG-1437, Supplement 38 A-14 December 201 0 OAGI0001367A_004S0

Appendix A Comment ID Commenter Comment Comment ADAMS Source(a) Page No(s}. Accession Number 40-s-AE Dacimo, F. email 294 ML091040133 40-t-AE/ED Dacimo, F. email 295 ML091040133 40-u-ED/TS Dacimo, F. email 295 ML091040133 40-v-ALITS Dacimo, F. email 295 ML091040133 40-x-ED Dacimo, F. email 296 ML091040133 40-y-AE Dacimo, F. email 296 ML091040133 40-z-AE Dacimo, F. email 296 ML091040133 40-aa-ED Dacimo, F. email 296 ML091040133 40-bb-AE/ED Dacimo, F. email 296 ML091040133 40-cc-AE/ED Dacimo, F. email 298 ML091040133 40-dd-AE/AL Dacimo, F. email 298 ML091040133 40-ee-AE Dacimo, F. email 299 ML091040133 40-ff-AE/ED Dacimo, F. email 299 ML091040133 40-gg-AE Dacimo, F. email 299 ML091040133 40-hh-AE Dacimo, F. email 300 ML091040133 40-ii-AE/ALITS Dacimo, F. email 300 ML091040133 40-jj-AE Dacimo, F. email 301 ML091040133 40-kk-AE/ED Dacimo, F. email 301 ML091040133 40-II-AE Dacimo, F. email 301 ML091040133 40-mm-AE/ED Dacimo, F. email 302 ML091040133 40-nn-AE Dacimo, F. email 302 ML091040133 40-oo-AE Dacimo, F. email 303 ML091040133 40-pp-AL Dacimo, F. email 303 ML091040133 40-qq-AE/ED Dacimo, F. email 303 ML091040133 40-rr-AE/ED/TL Dacimo, F. email 303 ML091040133 40-ss-ED Dacimo, F. email 304 ML091040133 40-tt-AE Dacimo, F. email 304 ML091040133 40-uu-AE Dacimo, F. email 305 ML091040133 40-w-ED Dacimo, F. email 305 ML091040133 40-ww-ED/SM Dacimo, F. email 305 ML091040133 40-xx-ALIAQ Dacimo, F. email 306 ML091040133 40-yy-ED Dacimo, F. email 306 ML091040133 40-zz-AL Dacimo, F. email 307 ML091040133 40-aaa-AE/AL Dacimo, F. email 309 ML091040133 40-bbb-AL Dacimo, F. email 310 ML091040133 40-ccc-ALITE Dacimo, F. email 311 ML091040133 40-ddd-ALITS Dacimo, F. email 312 ML091040133 40-eee-ALIAQ Dacimo, F. email 312 ML091040133 4O-fff-ALlAQ Dacimo, F. email 313 ML091040133 40-ggg-AL Dacimo, F. email 313 ML091040133 40-hhh-ALIED Dacimo, F. email 315 ML091040133 40-iii-ED Dacimo, F. email 316 ML091040133 40-jjj- AE Dacimo, F. email 318 ML091040133 December 2010 A-15 NUREG-1437, Supplement 38 OAGI0001367A_00451

Appendix A Comment ID Commenter Comment Comment ADAMS Source(a) Page No(s}. Accession Number 40-kkk-AL Dacimo, F. email 318 ML091040133 40-III-ED/SM Dacimo, F. email 318 ML091040133 40-mmm-AE Dacimo, F. email 320 ML091040133 40-nnn-AE Dacimo, F. email 324 ML091040133 40-ooo-AE/ED Dacimo, F. email 324 ML091040133 40-ppp-AE/CE Dacimo, F. email 325 ML091040133 40-qqq-AE Dacimo, F. email 328 ML091040133 40-rrr-AL Dacimo, F. email 341 ML091040133 40-sss-AL Dacimo, F. email 344 ML091040133 40-ttt-AE Dacimo, F. email 347 ML091040133 40-uuu-AE Dacimo, F. email 348 ML091040133 40-vw-AE Dacimo, F. email 348 ML091040133 40-www-AL Dacimo, F. email 348 ML091040133 40-xxx-AE/ED Dacimo, F. email 349 ML091040133 40-yyy-AE Dacimo, F. email 349 ML091040133 40-zzz-AE Dacimo, F. email 350 ML091040133 40-aaaa-TS Dacimo, F. email 350 ML091040133 40-bbbb-TS Dacimo, F. email 351 ML091040133 40-cccc-TS Dacimo, F. email 352 ML091040133 40-dddd-TS Dacimo, F. email 352 ML091040133 40-eeee-AE Dacimo, F. email 353 ML091040133 40-ffff-AE Dacimo, F. email 353 ML091040133 40-gggg-AL Dacimo, F. email 367 ML091040133 40-hhhh-AL Dacimo, F. email 370 ML091040133 40-iiii-AL Dacimo, F. email 374 ML091040133 40-jjjj-AL Dacimo, F. email 377 ML091040133 40-kkkk-AL Dacimo, F. email 382 ML091040133 40-IIII-AL Dacimo, F. email 384 ML091040133 40-mmmm-AL Dacimo, F. email 387 ML091040133 40-nnnn-AL Dacimo, F. email 390 ML091040133 40-oooo-AL Dacimo, F. email 428 ML091040133 40-pppp-AL Dacimo, F. email 435 ML091040133 40-qqqq-AE Dacimo, F. email 442 ML091040133 40-rrrr-AE Dacimo, F. email 457 ML091040133 40-ssss-AE Dacimo, F. email 459 ML091040133 40-tttt-AE Dacimo, F. email 461 ML091040133 40-uuuu-AE Dacimo, F. email 463 ML091040133 40-ww-AE Dacimo, F. email 471 ML091040133 40-wwww-AE Dacimo, F. email 472 ML091040133 40-xxxx-AE Dacimo, F. email 475 ML091040133 40-yyyy-AE Dacimo, F. email 476 ML091040133 40-zzzz-AE Dacimo, F. email 479 ML091040133 40-aaaaa-AE Dacimo, F. email 480 ML091040133 NUREG-1437, Supplement 38 A-16 December 201 0 OAGI0001367A_00452

Appendix A Comment ID Commenter Comment Comment ADAMS Source(a) Page No(s}. Accession Number 40-bbbbb-AE Dacimo, F. email 480 ML091040133 40-ccccc-AE Dacimo, F. email 480 ML091040133 40-ddddd-AE Dacimo, F. email 482 ML091040133 40-eeeee-AE Dacimo, F. email 482 ML091040133 40-fffff-AE Dacimo, F. email 483 ML091040133 40-ggggg-AE Dacimo, F. email 483 ML091040133 40-hhhhh-AE Dacimo, F. email 483 ML091040133 40-iiiii-AE Dacimo, F. email 485 ML091040133 40-jjjjj-AE Dacimo, F. email 487 ML091040133 40-kkkkk-AE Dacimo, F. email 489 ML091040133 40-IIIII-AE Dacimo, F. email 495 ML091040133 40-mmmmm-AE Dacimo, F. email 513 ML091040133 40-nnnnn-TS Dacimo, F. email 513 ML091040133 40-00000-TS Dacimo, F. email 515 ML091040133 40-ppppp-AE Dacimo, F. email 523 ML091040133 40-qqqqq-AE Dacimo, F. email 525 ML091040133 40-rrrrr-AE Dacimo, F. email 533 ML091040133 40-sssss-AE Dacimo, F. email 538 ML091040133 40-ttttt-AE Dacimo, F. email 553 ML091040133 40-uuuuu-AE Dacimo, F. email 574 ML091040133 40-wvw-AE Dacimo, F. email 577 ML091040133 40-wwwww- Dacimo, F. hand-in 595 ML091740490 GE/LR 40-xxxxx-SE Dacimo, F. hand-in 596 ML091740490 40-yyyyy-AE Dacimo, F. hand-in 596 ML091740490 40-zzzzz-AE Dacimo, F. hand-in 596 ML091740490 40-aaaaaa-AE Dacimo, F. hand-in 597 ML091740490 40-bbbbbb-AE Dacimo, F. hand-in 600 ML091740490 40-cccccc-ALIRG Dacimo, F. hand-in 601 ML091740490 41-a-OR Daly, Mary A. letter 604 ML090860664 41-b-AM/SF Daly, Mary A. letter 604 ML090860664 41-c-AE/LE Daly, Mary A. letter 604 ML090860664 41-d-AL Daly, Mary A. letter 604 ML090860664 42-a-EC/SR Davis, D. transcript 605 ML091410354 42-b-EC/SO Davis, D. transcript 605 ML091410354 42-c-HH Davis, D. transcript 605 ML091410354 42-d-SE/SR Davis, D. transcript 605 ML091410354 42-e-SR Davis, D. hand-in 607 ML091740490 42-f-EC/SO Davis, D. hand-in 607 ML091740490 42-g-ALIAQ Davis, D. hand-in 607 ML091740490 42-h-SE/SL Davis, D. hand-in 607 ML091740490 43-a-SE/SO Davis, J. hand-in 608 ML091740490 44-a-OR DeAngelo, C. e-mail 610 ML090771348 December 2010 A-17 NUREG-1437, Supplement 38 OAGI0001367A_00453

Appendix A Comment ID Commenter Comment Comment ADAMS Source(a) Page No(s}. Accession Number ML090860663 44-b-AM/DE/SF DeAngelo, C. e-mail 610 ML090771348 ML090860663 44-c-AE/LE DeAngelo, C. e-mail 610 ML090771348 ML090860663 44-d-OR DeAngelo, C. e-mail 610 ML090771348 ML090860663 45-a-AQ/EJ Degraff, Rev. transcript 611 ML091410354 Jacques 45-b-ALIEC/EJ Degraff, Rev. transcript 612 ML091410354 Jacques 45-c-LR Degraff, Rev. transcript 612 ML091410354 Jacques 46-a-EC/SR Digby, D. transcript 614 ML091410355 46-b-AQ/EJ Digby, D. transcript 614 ML091410355 46-c-ALlEJ/SR Digby, D. transcript 615 ML091410355 47-a-SF DiRocco, S. e-mail 616 ML090771334 47-b- LE/EP/SF DiRocco, S. e-mail 616 ML090771334 47-c-RW DiRocco, S. e-mail 616 ML090771334 48-a-OP Donahue, Mayor A. transcript 617 ML091410354 48-b-EC/SO Donahue, Mayor A. transcript 617 ML091410354 48-c-SE/SO Donahue, Mayor A. transcript 618 ML091410354 48-d-AQ/SO Donahue, Mayor A. transcript 618 ML091410354 48-e-OP/SR Donahue, Mayor A. transcript 619 5 ML091410354 9

48-f-SE Donahue, Mayor A. transcript 619 ML091410354 48-g-AQ/SO Donahue, Mayor A. transcript 620 ML091410354 49-a-SR Durett, D. transcript 621 5 ML091410354 9

49-b-AQ/EJ Durett, D. transcript 622 ML091410354 49-c-LRISR Durett, D. transcript 622 5 ML091410354 4

I 6

0 49-d-AQ/EJ/SR Durett, D. hand-in 625 5 ML091740490 9

49-e-ALlEJ Durett, D. hand-in 626 ML091740490 49-f-AQ/EJ Durett, D. hand-in 628 ML091740490 49-g-ALIAQ/EJ Durett, D. hand-in 630 ML091740490 49-h-AQ/EC Durett, D. hand-in 632 ML091740490 49-i-SR Durett, D. hand-in 633 ML091740490 50-a-LR Edelstein, M. transcript 634 ML091410355 50-b-DE/PA Edelstein, M. transcript 635 ML091410355 I NUREG-1437, Supplement 38 A-18 December 201 0 OAGI0001367A_00454

Appendix A Comment ID Commenter Comment Comment ADAMS Source(a) Page No(s}. Accession Number 50-c-PA Edelstein, M. transcript 636 ML091410355 50-d-EP/HH Edelstein, M. transcript 636 ML091410355 50-e-NE Edelstein, M. transcript 637 ML091410355 50-f-NE Edelstein, M. e-mail 639 ML090700188 50-g-GE/SF Edelstein, M. e-mail 639 ML090700188 50-h-DE/PA Edelstein, M. e-mail 639 ML090700188 50-i-EJ/LE Edelstein, M. e-mail 640 ML090700188 50-j-EJ/PA Edelstein, M. e-mail 640 ML090700188 50-k-PA Edelstein, M. e-mail 640 ML090700188 50-I-HH/PA Edelstein, M. e-mail 641 ML090700188 50-m-PA/ST Edelstein, M. e-mail 641 ML090700188 50-n-RW/SF Edelstein, M. e-mail 641 ML090700188 50-o-HH/LE/PA Edelstein, M. e-mail 641 ML090700188 50-p-DE/EP/NE Edelstein, M. e-mail 642 ML090700188 50-q-DE/EP Edelstein, M. e-mail 642 ML090700188 50-r-EP/PS Edelstein, M. e-mail 643 ML090700188 50-s-S0 Edelstein, M. e-mail 643 ML090700188 50-t-EJ Edelstein, M. e-mail 643 ML090700188 50-u-GLlUF Edelstein, M. e-mail 644 ML090700188 51-a-HH/PA/UF Evans, L. transcript 645 ML091410355 51-b-AL Evans, L. transcript 645 ML091410355 51-c-AL Evans, L. transcript 645 ML091410355 52-a-SA Falciano, P. transcript 647 ML091410355 52-b-ST Falciano, P. transcript 647 ML091410355 52-c-ALIAQ/EC Falciano, P. transcript 648 ML091410355 52-d-AL Falciano, P. transcript 648 ML091410355 52-e-SR Falciano, P. transcript 649 ML091410355 53-a-SE/SR Federspiel, J. transcript 650 ML091410354 54-a- Feinberg, J. e-mail 652 ML090720670 LE/OR/RW/SF 54-b-DE/ST Feinberg, J. e-mail 652 ML090720670 54-c-AE Feinberg, J. e-mail 652 ML090720670 54-d-OR Feinberg, J. e-mail 652 ML090720670 55-a-OS Filippelli, J. letter 653 ML090860878 55-b-AE/RG Filippelli, J. letter 654 ML090860878 55-c-RW Filippelli, J. letter 654 ML090860878 55-d-SM Filippelli, J. letter 654 ML090860878 55-e-PA Filippelli, J. letter 654 ML090860878 55-f-AE/PA/RW Filippelli, J. letter 655 ML090860878 56-a-ALIAQ/EC Fitzpatrick, B. e-mail 656 ML090700182 56-b-SO Fitzpatrick, B. e-mail 656 ML090700182 56-c-HH Fitzpatrick, B. e-mail 657 ML090700182 56-d-EP Fitzpatrick, B. e-mail 657 ML090700182 December 2010 A-19 NUREG-1437, Supplement 38 OAGI0001367A_00455

Appendix A Comment ID Commenter Comment Comment ADAMS Source(a) Page No(s). Accession Number 56-e-SE Fitzpatrick, B. e-mail 657 ML090700182 56-f-ALISA Fitzpatrick, B. e-mail 657 ML090700182 57-a-SA Forehand, R. transcript 658 ML091410355 57 -b-AQ/EC/SO Forehand, R. transcript 658 ML091410355 57 -c-SA/SE/SO Forehand, R. transcript 659 ML091410355 57-d-SL Forehand, R. letter 660 ML090700172 57 -e-EC/OP/SO Forehand, R. letter 660 ML091680295 57-f-ALIAQ Forehand, R. letter 660 ML091680295 57-g-SR Forehand, R. letter 660 ML091680295 57-h-SE/SR Forehand, R. letter 660 M L091680295 58-a-SR Form Letter letter 661 ML091100591 ML091100592 ML091100593 ML091100595 ML091100596 ML091100597 ML091100598 ML091100599 ML091100600 ML091100603 ML091100604 ML091100605 ML091100606 ML091100607 ML091100609 ML091100610 ML091100611 ML091100612 ML091100613 ML091100622 ML091100623 ML091100624 ML091100625 ML091100626 ML091100627 ML091100628 ML091100629 ML091100630 ML091100631 ML091100654 ML091100655 ML091100656 I NUREG-1437, Supplement 38 A-20 December 201 0 OAGI0001367A_00456

Appendix A Comment ID Commenter Comment Comment ADAMS Source(a) Page No(s}. Accession Number ML091100657 ML091100658 ML091100660 ML091100661 ML091100662 ML091100663 ML091100664 ML091100671 ML091100672 ML091100673 ML091100674 ML091100675 ML091100676 ML091100677 ML091100678 ML091100679 ML091100680 ML091100686 ML091100687 ML091100688 ML091100689 ML091100690 ML091100691 ML091100692 ML091100693 ML091100694 ML091100695 ML091100696 ML091100697 ML091100699 ML091100700 ML091100701 ML091100702 ML091100703 ML091100704 ML091100705 ML091100706 ML091100707 ML091100722 ML091100723 ML091100724 ML091100725 ML091100726 December 2010 A-21 NUREG-1437, Supplement 38 OAGI0001367A_00457

Appendix A Comment ID Commenter Comment Comment ADAMS Source(a) Page No(s}. Accession Number ML091100727 ML091100728 ML091100729 ML091100730 ML091100731 ML091100732 ML091100735 ML091100736 ML091100737 ML091100738 ML091100739 ML091100740 ML091100741 ML091100742 ML091100743 ML091100744 ML091100749 ML091100750 ML091100751 ML091100752 ML091100753 ML091100755 58-b-ALIAQ/EJ Form Letter letter 661 ML091100591 ML091100592 ML091100593 ML091100595 ML091100596 ML091100597 ML091100598 ML091100599 ML091100600 ML091100603 ML091100604 ML091100605 ML091100606 ML091100607 ML091100609 ML091100610 ML091100611 ML091100612 ML091100613 ML091100622 ML091100623 I NUREG-1437, Supplement 38 A-22 December 201 0 OAGI0001367A_00458

Appendix A Comment ID Commenter Comment Comment ADAMS Source(a) Page No(s}. Accession Number ML091100624 ML091100625 ML091100626 ML091100627 ML091100628 ML091100629 ML091100630 ML091100631 ML091100654 ML091100655 ML091100656 ML091100657 ML091100658 ML091100660 ML091100661 ML091100662 ML091100663 ML091100664 ML091100671 ML091100672 ML091100673 ML091100674 ML091100675 ML091100676 ML091100677 ML091100678 ML091100679 ML091100680 ML091100686 ML091100687 ML091100688 ML091100689 ML091100690 ML091100691 ML091100692 ML091100693 ML091100694 ML091100695 ML091100696 ML091100697 ML091100699 ML091100700 ML091100701 December 2010 A-23 NUREG-1437, Supplement 38 OAGI0001367A_00459