ML14008A285

NRR E-mail Capture - Revised IPEC Sturgeon Impingement Monitoring Plan 3Dec13

ML14008A285
Person / Time
Site:	Indian Point, Hope Creek
Issue date:	01/08/2014
From:	Mattson M - No Known Affiliation
To:	Logan D NRC/NRR/DLR/RERGUB
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Download: ML14008A285 (58)

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1 NRR-PMDAPEm Resource From:

Mark Mattson [mmattson@normandeau.com]

Sent:

Wednesday, January 08, 2014 12:22 PM To:

Logan, Dennis Cc:

Gray, Dara F (DGray@entergy.com)

Subject:

Revised IPEC Sturgeon Impingement Monitoring Plan 3Dec13 Attachments:

IPEC_sturgeon_monitoring_plan_revision_1a.pdf; IPEC_Sturgeon_BIOP_Monitoring_Plan_Cover_Letter_3Dec2013a.pdf Hi Dennis - Dara called this morning to say you were having difficulty with the password protection of the revised IPEC Sturgeon Impingement Study Plan that I completed and distributed to NMFS and others (including you) on 3 December 2013 because the password would not let the document be uploaded to your ADAMS system. Try uploading the attached PDF versions of the cover letter and Study Plan, neither are password protected. If they dont work, the MS Word document is 15.8 mb (due to photos), but I am not sure if you can receive email attachments that large, and I know Dara cannot. So let me know if you were successful with these attachments, or if we need to try Plan B.

Happy New Year. Mark

><((((:>><((((:>>((((:>><((((:>

Mark T. Mattson, Ph.D., Vice President Normandeau Associates, Inc.

30 International Drive, Suite 6 Portsmouth, NH 03801 Phone: 603.319.5307 Cell: 603.345.0071 Please consider the environment before printing this e-mail.

Hearing Identifier:

NRR_PMDA Email Number:

999 Mail Envelope Properties (4B777AA8CA45D94EB7008BF6B0860DF42BDF42C9)

Subject:

Revised IPEC Sturgeon Impingement Monitoring Plan 3Dec13 Sent Date:

1/8/2014 12:22:16 PM Received Date:

1/8/2014 12:27:20 PM From:

Mark Mattson Created By:

mmattson@normandeau.com Recipients:

"Gray, Dara F (DGray@entergy.com)" <DGray@entergy.com>

Tracking Status: None "Logan, Dennis" <Dennis.Logan@nrc.gov>

Tracking Status: None Post Office:

Mail01.normandeau.com Files Size Date & Time MESSAGE 1022 1/8/2014 12:27:20 PM IPEC_sturgeon_monitoring_plan_revision_1a.pdf 3996090 IPEC_Sturgeon_BIOP_Monitoring_Plan_Cover_Letter_3Dec2013a.pdf 413869 Options Priority:

Standard Return Notification:

No Reply Requested:

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Recipients Received:

Proposed Monitoring Plan for Indian Point Energy Center Take of Atlantic and Shortnose Sturgeons by Impingement at Cooling Water Intakes Revision 1 Presented to:

Indian Point Energy Center 450 Broadway, Suite 1 Buchanan, NY 10511 Submitted:

3 December 2013 Submitted by:

Normandeau Associates, Inc.

25 Nashua Road Bedford, NH 03110 and ASA Analysis and Communication, Inc.

921 Pike Street, P.O. Box 303 Lemont, PA 16851 www.normandeau.com

MONITORING PLAN FOR IPEC STURGEON IMPINGEMENT REVISION 1 IPEC_sturgeon_monitoring_plan_revision_1.docx 1/8/14 ii Normandeau Associates, Inc.

Table of Contents Page

1.0 INTRODUCTION

................................................................................ 1 1.1 REGULATORY CONTEXT..................................................................... 1

1.2 DESCRIPTION

OF IPEC AND OPERATIONS RELEVANT TO THE PROPOSED MONITORING PLAN.. 1 1.2.1 Cooling Water Intake Structures............................................. 2 1.2.2 Cooling Water Flow Management............................................ 3 1.2.3 Optimized Ristroph-Type Traveling Water Screens........................ 4 2.0 MONITORING PROGRAM...................................................................... 5 2.1 MONITORING AT TRASH RACKS............................................................. 5 2.1.1 IP2 and IP3...................................................................... 5 2.1.2 Pilot Study at IP2 and IP3..................................................... 6 2.1.3 Routine Trash Rack Monitoring at IP2 and IP3.............................. 7 2.1.4 Pilot Study and Routine Trash Rack Monitoring at IP1.................... 8 2.1.5 Trash Rack Monitoring Implementation Schedule, Modifications, and Permits..................................................................... 8 2.2 MONITORING IN FOREBAYS.................................................................. 8 2.2.1 Forebay Monitoring at IP2 and IP3........................................... 9 2.2.2 Forebay Residence Study Implementation Schedule, Modifications, and Permits.................................................. 10 2.3 MONITORING AT TRAVELING SCREENS...................................................... 10 2.3.1 Traveling Screen Sluice Sampling........................................... 10 2.3.2 Traveling Screen Monitoring Implementation Schedule, Modifications, and Permitting............................................... 12 2.4 FISH HANDLING PROCEDURES.............................................................. 13 2.4.1 Live Fish........................................................................ 13 2.4.2 Dead Fish....................................................................... 14 2.4.3 Genetic Samples............................................................... 14 2.5 ANCILLARY DATA.......................................................................... 14 2.5.1 Temperature................................................................... 14 2.5.2 Water Velocity................................................................. 15 2.5.3 Plant Operating Data......................................................... 18 2.5.4 Ancillary Data Collection Implementation Schedule, Monitoring, and Permits.................................................................... 18 2.6 REPORTING................................................................................ 19 2.6.1 Take Notification.............................................................. 19 2.6.2 Annual Report.................................................................. 19 2.6.3 Genetic Samples............................................................... 19 2.6.4 Dead Sturgeon or Sturgeon Parts............................................ 19 2.7 TRAINING OF FIELD BIOLOGISTS........................................................... 20 2.8 QA/QC PROCEDURES..................................................................... 20 3.0 LITERATURE CITED.......................................................................... 21

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List of Figures Page Figure 1-1.

Indian Point Unit 2 (IP2) cooling water intake structure - plan view.......... 24 Figure 1-2.

Indian Point Unit 2 (IP2) cooling water intake structure - sectional view...................................................................................... 25 Figure 1-3.

Indian Point Unit 3 (IP3) cooling water intake structure - plan view.......... 26 Figure 1-4.

Indian Point Unit 3 (IP3) cooling water intake structure - sectional view...................................................................................... 27 Figure 2-1.

Trash rack slots at the outer (western) side of the IP2 cooling water intake structure........................................................................ 28 Figure 2-2.

Telescoping pole with locking noose proposed to retrieve sturgeon observed on the outer side of the trash racks at IP2 and IP3................... 28 Figure 2-3.

Low-light underwater camera system proposed for observations of trash rack impingement of Atlantic and Shortnose Sturgeon at IP2 and IP3........................................................................................ 29 Figure 2-4.

Specifications of a Splash Cam Deep Blue Pro Video system for detecting Atlantic and Shortnose Sturgeon impinged at the IP2 and IP3 trash racks. Camera is shown mounted on auxiliary light source.............. 30 Figure 2-5.

Example screen capture from a Splash Cam Deep Blue Pro video of a free-swimming white sturgeon at a depth of 6.7 m and turbidity of 1.75 NTU in the Yuba River, California, USA (Bergman, et al. 2011).......... 31 Figure 2-6.

Low-light 360°panning underwater camera system (Splash Cam SideWinder 360) deployed with stabilizer fins for forebay observations of Atlantic and Shortnose Sturgeon at IP2 and IP3................................ 32 Figure 2-7.

Specifications of a Splash Cam SideWinder 360 dual underwater camera unit for detecting Atlantic and Shortnose Sturgeon in the intake forebays of the IP2 and IP3.................................................. 33 Figure 2-8.

Example of a sluice sampling net and frame (without delta mesh liner)..................................................................................... 35 Figure 2-9.

Example of two 150-gallon sturgeon holding tanks............................... 35 Figure 2-10.

IP2 Ristroph screen fish sluice (right) and debris sluice (left) return system shown under yellow deck grating looking north from the north end of the IP2 intake bulkhead...................................................... 36 Figure 2-11.

IP3 Ristroph screen fish sluice (top) and debris sluice (bottom) return system shown looking north from the south end of the IP3 intake bulkhead................................................................................ 37 Figure 2-12.

IP1 sluice system located under deck plates at the southwestern corner of the screen house where sluice sampling would occur when the plates are removed............................................................... 38

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Figure 2-13.

Acoustic Doppler current profiler (ADCP) monitoring station locations near IP2 and IP3 from continuous monitoring studies performed during 2010 (Stations 2A, 2B, 3A, 3B) and 2011 (Stations 1S and 2N). The base image is from Google Earth.................................................... 39 Figure 2-14.

Incident report form for incidental take of Atlantic Sturgeon or Shortnose Sturgeon by impingement at the IPEC cooling water intakes...... 40 Figure 2-15.

Summary form for environmental data associated with incidental take of Atlantic Sturgeon or Shortnose Sturgeon........................................ 42 Figure 2-16.

Instructions for collecting, certifying, identifying, and shipping sturgeon tissue samples............................................................... 43 Figure 2-17.

Certification of species, sample identification, and chain of custody form...................................................................................... 44 Figure 2-18.

Summary form for sturgeon genetic tissue samples.............................. 45 Figure 2-19.

Guidelines and form for air shipment of excepted quantities of ethanol solutions....................................................................... 46 Figure 2-20.

Sturgeon salvage form................................................................ 48

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1.0 Introduction 1.1 Regulatory Context On 30 January, 2013, the National Marine Fisheries Service (NMFS) issued a final Biological Opinion (Opinion) and Incidental Take Statement (ITS) authorizing takes of Atlantic and Shortnose Sturgeon during the continued operation of the Indian Point Energy Center (IPEC) pursuant to existing operating licenses and proposed renewed operating licenses to be issued by the U.S. Nuclear Regulatory Commission (NRC). In the Opinion, NMFS addressed Shortnose Sturgeon and the Gulf of Maine Distinct Population Segment (DPS),

the New York Bight DPS, and the Chesapeake Bay DPS of Atlantic Sturgeon.

Among other things, the Opinion requires that "Entergy must develop a proposed, draft monitoring plan designed to document all Atlantic and Shortnose Sturgeon impinged at IP1, IP2 and IP3 (trash racks and intake screens) while these facilities are operating under their existing operating licenses and the proposed renewed operating licenses. The draft monitoring plan must be provided to NMFS and NRC within 60 days of the issuance of this Opinion for NMFS review and approval. The Opinion also contains Reasonable and Prudent Measures (RPMs) and Terms and Conditions (T&C) that are to be "developed in coordination with the action agency and applicant, if any, to ensure that the measures are reasonable" (USFWS & NMFS, 1998).

Entergy provided a draft monitoring plan as specified in the Opinion for NMFS review on 29 March 2013. NMFS and NRC participated in a site visit, intake tour, and meeting at IPEC on 11 June 2013 to discuss the draft monitoring plan. NMFS provided comments, dated 23 October 2013, on this draft monitoring plan in a letter to Ms. Dara Gray of Entergy. We understand that these comments also reflect NMFS coordination with NYSDEC. This Revision 1 of the draft monitoring plan responds to these comments.

1.2 Description of IPEC and Operations Relevant to the Proposed Monitoring Plan Entergy Nuclear Operations, Inc. (Entergy) currently operates two NRC-licensed pressurized water reactors and associated generating units at Unit 2 and Unit 3 (IP2 and IP3; collectively, IPEC). These units condense the steam exiting the turbines by transferring heat to water withdrawn from the Hudson River, which is then discharged back to the river.

Maximum cooling water flow is 840,000 gallons per minute (gpm) at each unit (Enercon 2010).

Both IP2 and IP3 also use once-through systems to manage auxiliary heating loads, referred to as service water systems. These service water systems at IP2 and IP3 are significantly smaller than the cooling water systems, with maximum (design) service water flow of 30,000 gpm at IP2 and 36,000 gpm at IP3 (Enercon 2010), although service water flows are typically 15,000 gpm or less for each unit. The cooling water system for Unit 1 IP1 was originally designed to provide 280,000 gpm before the generating unit was retired in November 1974. The cooling water pumps at the IP1 intake were removed in the 1990s, but

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the IP1 service water system is still operational and provides up to 16,000 gpm of supplemental service water for IP2 when needed.

1.2.1 Cooling Water Intake Structures Cooling water for IP2 and IP3 is obtained through their respective cooling water intake structures (CWISs), located approximately 700 feet apart along the eastern shoreline of the Hudson River at approximately Hudson River mile 41.8 (41.8 miles upstream from the southern end of Battery Park in lower Manhattan, New York City). The CWISs are located within IPECs federally mandated Safety and Security Zone (S&SZ).

The IP2 intake structure is located north of the IP1 intake and contains seven bays or channels which are separated by 3-foot thick concrete walls (Figure 1-1). Each intake bay at IP2 is equipped with a debris wall at the outer (western) side that extends to a depth of -1 foot at mean sea level as measured at the CWISs (i.e., plant MSL). A vertical bar rack, or trash rack, with 3-inch open spaces between bars, is also located at the outer (western or upstream) side of the IP2 intake bay to prevent large pieces of debris from entering the structure. The trash racks extend the full height of each IP2 intake bay opening (-27 feet to -

1 foot plant MSL) (Figure 1-2). One optimized traveling screen is located at the inner (eastern or downstream) side of each IP2 intake bay. The chamber between the outer trash rack and the inner traveling screen is referred to as the forebay. Therefore, the submerged (at plant MSL) dimensions of each forebay at IP2 from the outer trash rack opening to the centerline of the traveling screen are 28 feet high by 13.3 feet wide by 11 feet long. Design velocities through the trash racks for the six cooling water intake bays range from 0.5 to 0.8 fps depending on pumping rate and tide height (Enercon 2010). Design velocity through the trash rack protecting the service water bay in the center of the intake structure at IP2 ranges from 0.06 fps to 0.17 fps (Enercon 2010). The design of the intake with the top of the trash rack submerged 1 foot below plant MSL and near the opening of each intake bay minimizes the buildup of debris on the trash racks, and there is no need for a mechanized cleaning system.

The IP3 intake structure, located south of the IP1 intake, consists of a concrete structure with nine openings which provide flow into a common plenum (Figure 1-3). The seven openings along the outer (western) side of the IP3 intake structure are each equipped with a debris wall and vertical trash rack similar to those at IP2 (Figure 1-4). Partition walls begin to isolate each of the cooling water pumps near the traveling screens, which are 18 feet inward (east) of the vertical trash racks and common plenum at the IP3 CWIS (Figure 1-4).

Therefore, the submerged (at plant MSL) dimensions of each forebay at IP3 from the outer trash rack opening to the centerline of the traveling screen are 28 feet high by 13.3 feet wide by 18 feet long. Design velocity through the trash racks is 0.5 fps to 0.9 fps depending on cooling water flow rate and water level (Enercon 2010). Actual velocities through the seven trash racks is less than the design value because there are two additional openings, one at the north end and one at the south end of the structure (Figure 1-3). These openings contain additional trash racks. As at IP2, debris accumulation on the trash racks at IP3 has not been an issue because the racks are submerged 1 foot below plant MSL and are located at the outer edge of the intake structure. The design of the IP3 intake structure makes it possible for fish that pass through the trash racks associated with any of the seven openings on the

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western side of the structure to swim within the structure parallel to the traveling screens and exit the structure through the openings at the north and south ends.

The IP1 intake structure is located between the IP2 and IP3 intakes (south of IP2 and north of IP3) behind a pile-supported dock (Enercon 2010). Since IP1 ceased power generation in 1974, the cooling water pumps have been removed, and the intake is now used seasonally to supply service water to IP2, when needed. The IP1 CWIS was originally outfitted with four trash racks at each of four intake bays, which were arranged in two sets of two bays each.

However, the trash racks at the IP1 CWIS have not been maintained since power generation ceased, and our expectation is that they have substantially degraded since 1974. The IP1 CWIS originally had four conventional traveling screens, but these were also removed after power generation ceased and were replaced with a single 0.125-inch mesh dual-flow screen located within the service water portion of each of the two intake bays at IP1. Each of the two dual flow traveling screens at IP1 has a design through-screen velocity estimated as less than 0.5 fps, and thus is considered to be the best technology available (BTA) for reducing impingement by USEPA in their proposed regulations of cooling water intake structures at existing facilities (40CFR §125.94(b)(2) (28 March 2011).

1.2.2 Cooling Water Flow Management The dual speed cooling water pumps at IP2 and variable speed cooling water pumps at IP3 were installed in the mid-1980s to minimize impingement and entrainment of fish by reducing the amount of water used for cooling (Enercon 2010). Since the amount of water needed for efficient operation varies seasonally with the river temperature, cooling water flow is reduced as much as 25% during winter months when river temperature is at its annual low. Lower flow rates not only reduce the amount of water withdrawn, but also reduce the intake velocity, facilitating escapement of fish that otherwise might be susceptible to impingement.

At IP2, each of the six of the cooling water bays provides water to an individual cooling water pump, which is located 35 feet behind the traveling screens. At the maximum pumping rate (140,000 gpm per pump), the maximum (at mean low water) average through-screen velocity for the IP2 traveling screens is calculated as 1.6 fps (Enercon 2010).

The IP2 cooling water pumps can also be operated at 84,000 gpm, which proportionally reduces the calculated maximum average through-screen velocity to 1 fps. For the service water intake bay at IP2, the calculated maximum through-screen velocity is 0.35 fps when all six service water pumps are operated at a maximum (design) capacity of 30,000 gpm.

The six IP3 cooling water pumps, each enclosed in an intake bay and located 28 feet behind the traveling screens, have a continuously variable capacity between 70,000 gpm and 140,000 gpm. Three of the bays are also equipped with 3,200 gpm screen wash pumps. The seventh bay, located in the center of the structure, provides water to the six service water pumps, which have a maximum combined capacity of 36,000 gpm. As at IP2, the maximum average through-screen velocity for the cooling water bays is calculated as 1.6 fps (Enercon 2010), and is 0.4 fps for the service water bay.

The dual-flow screens in the IP1 intake filter the water drawn by the single 16,000-gpm service water pump and the two 1500-gpm spray wash pumps in each of the two intake bay sets. The screens are washed automatically when water level differences between the front and back of the screens exceed predetermined settings. Materials removed from the

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traveling screen mesh are sluiced to the Hudson River in the wash water flow. During normal operation only one of the two service water pumps and two of the spray wash pumps is in operation at any given time at IP1(Enercon 2010).

1.2.3 Optimized Ristroph-Type Traveling Water Screens The IP2 and IP3 intakes are outfitted with optimized Ristroph-type traveling screens and fish handling and return systems. The Ristroph-type screens and fish return systems were operational at IP3 in 1990, and at IP2 in 1991, following a collaborative research, design, and validation effort among the former owners of IP2 and IP3, the New York State Department of Environmental Conservation (NYSDEC), and the then scientific advisor to the Hudson River Fishermans Association (HRFA, now Riverkeeper).

The Ristroph-type screens are located between the trash racks and the cooling water pumps at the CWIS and have the following features to protect the aquatic organisms impinged:



Dual-speed continuous rotation - The screens are rotated continuously. Under low debris loading conditions, the screens are rotated at 2.5 fpm and under high debris loading at 10 fpm. Impingement on the screens and mortality of those organisms that are impinged is less likely to occur when low through-screen velocities are maintained by the continuous removal of debris. Continuous rotation also minimizes the time that impinged organisms are retained on the screen panels or in the fish buckets. These features significantly reduce the potential stress on impinged organisms.



Smooth screen mesh - The 0.5 inch x 0.25 inch clear opening slot mesh on the screen panels is smooth, to minimize abrasion to fish transferred into the fish return systems.



Flow deflector lip on fish buckets - The curved lip at the leading edge of the fish buckets is designed to minimize vortex stress on fish inside the buckets. The lip eliminates turbulent flow in the interior of the buckets and provides sufficient water depth to allow fish to maintain a stable, upright position (Fletcher 1985).



Dual-pressure spray wash systems - The screens encounter a series of spray washes in the operating rotation. First, high-pressure sprays are used to remove debris from the screen mesh surface. During this process, deflector plates are used to protect aquatic organisms in the fish buckets. Low-pressure sprays are then used to gently remove aquatic organisms from the fish buckets for release through the fish return system. Finally, another series of high-pressure sprays are used to wash off any remaining debris to prevent carryover into the intake bays and assist in maintaining the available open area of each screen panel to reduce the potential for impingement.

The current fish handling and return systems at IPEC also incorporate several design features specifically selected to enhance the survival of impinged fish that are returned to the river:



Separate fish return and debris return systems are provided.

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Fish return systems have smooth surfaces and gentle transition sections to minimize the potential for fish abrasion during transport.



Design water depths are maintained to allow the fish to remain in a stable, upright position during transport.



Design trough and sluice water velocities are maintained between 2 fps and 5 fps, which are sufficient to transport the organisms back to the river while minimizing stress during transport.



Return pipe discharge locations were selected following dye and fish release studies to minimize the potential for re-impingement.

Collectively, the optimized Ristroph-type screens and the fish return systems, both developed through the extensive collaborative process referenced above, reflected first-in-kind design when installed, and continue to reflect state-of-the-art design today. The effectiveness of the modified Ristroph-type screens in reducing impingement losses was demonstrated in studies showing the technology to be fully optimized as BTA for impingement (Fletcher 1990), a conclusion supported by the inclusion of the IPEC configuration as BTA for impingement on a nationwide basis (USEPA 2011).

Entergy proposes to continue operating IPEC using this system for the duration of its operating licenses, or until a different system is determined to be BTA for the IPEC facility as a result of a final NYSDEC determination and the alternative system can be permitted, constructed, and installed.

2.0 Monitoring Program The implementation schedules for monitoring (1) trash racks, (2) intake bays, (3) the traveling screens, as well as (4) collecting ancillary data associated with sturgeon occurrences, are set forth in the program components below (with references to the specific section of the Opinion in which the program element is specified).

2.1 Monitoring at Trash Racks Monitoring sturgeons at the trash racks is specified by RPM#1, and T&C#s 1.a, 1.b, and 1.c of the Opinion. The pilot study described in Section 2.1.2 below will be performed during the first year, coincident with weekly inspection of all trash racks scheduled for two consecutive days per week. In subsequent years, the inspection frequency for routine trash rack monitoring (Section 2.1.3) will be based on analysis of the pilot study data describing the seasonal variation in sturgeon degradation rates.

2.1.1 IP2 and IP3 The main focus of trash rack monitoring is on moribund or dead sturgeon, which would be collected on the trash racks as they are carried with the current, likely with other debris.

Specifically, since sturgeon large enough to become impinged on the trash racks are also large enough to easily avoid or overcome the intake approach velocity at the trash racks, the only sturgeon likely to be found against the trash racks are those that died before encountering the IPEC intake and drifted against the trash racks in the intake flow.

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It is expected that this collection of dead sturgeon on the trash racks will be extremely infrequent because (1) sturgeon large enough that they could not fit through the trash racks (i.e., those greater than 3 inches in limiting body width dimensions, or approximately 600 mm total length) would have few predators and low natural mortality rates, and (2) closure of the shad fishery in the Hudson River has eliminated the fisheries by-catch mortality that was the likely source of many previously observed sturgeon impingements at IPEC.

An inspection of the IP2 and IP3 CWIS was recently (5 November 2013) performed by IPECs engineering staff to determine if there are feasible access points to assess collection at the trash racks at IP2 or IP3 from the bulkheads and decks of the CWISs without significant civil or structural modifications, or the need to significantly modify the security system in these areas. The inspection revealed deck-level access through narrow slots providing clearance to the water immediately upstream and downstream of the trash racks at IP2 and IP3. At IP2, there was access to the top of the trash racks with about two feet of clearance upstream (outward), and about 5 to 7 inches of clear space downstream (inward) between the concrete bulkhead deck and each vertical trash rack (Figure 2-1). At IP3, welded metal floor plates cover these trash rack slots, but access to the top of the trash racks could be gained from the bulkhead deck level by modifying these plates to provide similar access to the upstream and downstream sides of the trash racks as was observed at IP2.

2.1.2 Pilot Study at IP2 and IP3 IPEC proposes to conduct a pilot study using low-light underwater cameras to detect and determine degradation rates and retention times of dead sturgeon on the trash racks at IP2 and IP3, and allow the field crew to refine our proposed methods for detecting and removing sturgeon from the trash racks.

Published studies on the degradation rates of dead fish suggest that complete degradation occurs from 6 to 34 days after winter kill for a mixed community of freshwater fish >150 mm total length (TL) in a Michigan lake (Schneider 1998), and averaged 10 days for post spawning dead anadromous clupeids (Alosa sp., mostly blueback herring, Alosa aestivalis) in the James River, Virginia (Garman 1992). Given the toughness of the sturgeon integument relative to that of most freshwater fishes or clupeids, we would expect the time for complete degradation of dead sturgeon impinged on the trash racks at IPEC to exceed that observed in the James River and in Michigan. Nonetheless, the proposed pilot study allows empirical determination of the degradation rate of sturgeon impinged on the trash racks at IPEC, and how degradation varies as water temperatures and scavenger densities change among four seasons.

White Sturgeon (Acipenser transmontanus) carcases between 600 mm total length (TL) and 1000 mm TL will be purchased freshly frozen from a commercial hatchery caviar operation and used as surrogate test subjects for this pilot study. Each test White Sturgeon will be thawed to ambient water temperature, placed in a mesh bag made from knotted multifilament gill net twine (1.5 inch square mesh), and tethered onto the upstream side of one randomly selected trash rack at IP2 and IP3. Each test White Sturgeon will be placed within one grid square randomly selected from nine grid squares of equal size across the western (upstream) face of one randomly selected trash rack at IP2 and IP3. Each test White Sturgeon will be deployed at the selected trash rack location by the field crew using a long-handled pole while standing from the bulkhead deck. This pole is in 8-foot long sections

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that can be screwed together or telescoped to extend the full depth of the selected trash rack, and has a locking noose on the terminal end to deploy or retrieve fish (Figure 2-2). Direct observations of the condition of the test White Sturgeon on the trash racks at IP2 and IP3 will be made over the next 21 days or until the test White Sturgeon has completely degraded in less than 21 days. Observations of each test White Sturgeon will be recorded by deploying a low light digital underwater camera (SplashCam Deep Blue Pro) and underwater light LED source (Figures 2-3, 2-4, and 2-5) mounted on a second long pole with guides that slide up and down the trash racks from the CWIS bulkhead deck through the trash rack slot.

The pilot study will be conducted by placing one test White Sturgeon in one randomly selected grid square on the upstream face of one randomly selected trash rack at each of IP2 and IP3 on Day 1. Each test White Sturgeon deployed on Day 1 will be observed and the condition will be recorded (without removing the test fish) by the pole-mounted underwater camera system once per day on each of the next seven consecutive days (Day 2, Day 3, Day 4, Day 5, Day 6, Day 7, and Day 8) during the first pilot study test week. If the test fish has not degraded after seven consecutive days of observations, the fish will be allowed to remain tethered to the trash rack and observations will be made twice per week for the next two weeks by the regularly scheduled routine trash rack monitoring as described in Section 2.1.3 below (i.e., Day 11, Day 12, and Day 19, and Day 20) until the fish has completely degraded or the pilot test is terminated on Day 22 after 21 days of soak time.

The pilot study will repeated once per season for a total of four studies during the first year.

Test White Sturgeon remaining after the 21 days of pilot testing will be removed from the trash racks using the telescoping pole and recovery noose, aided by direct observations from the low light camera, to guide the recovery noose around the test fish. Recovery of the test White Sturgeon with the pole and noose rather than simply retrieving the test fish using the mesh bag and rope tether is intended to provide training for the crew to deploy both the camera and recovery device. Wild Atlantic or Shortnose Sturgeon, if any, observed by the pole-mounted camera during each pilot study will be removed using the recovery noose as described above and processed as described in Section 2.4 below.

Compiling and analyzing the results from the four pilot study test periods in the first year will determine the appropriate observation interval for sturgeon on the trash racks at IP2 and IP3 for routine monitoring in subsequent years.

2.1.3 Routine Trash Rack Monitoring at IP2 and IP3 Routine trash rack monitoring at IP2 and IP3 will be conducted with the same pole-mounted low light digital underwater camera (SplashCam Deep Blue Pro) and underwater light LED source described above for the pilot study. The frequency of routine monitoring during the first year will be two consecutive days per week (i.e., Monday and Tuesday). Data from the pilot study of sturgeon degradation rates and first year observations will be analyzed and used to establish an appropriate and efficient sampling frequency in the second and subsequent years of trash rack monitoring. Sampling from the CWIS bulkhead decks and not by boat as originally proposed in the first Study Plan dated 29 March 2013 should help insure that few or no trash rack observations are missed due to extreme weather conditions such as river ice, thunderstorms, hurricanes, or storm surges. On each of the scheduled two days of trash rack monitoring during the first year, all trash racks at IP2 and IP3 will be

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inspected using the pole-mounted camera system. Atlantic or Shortnose Sturgeon observed by the pole-mounted camera during a complete scan of the upstream face of each trash bar rack at IP2 and IP3 will be removed using the recovery noose as described above, and processed as described in Section 2.4 below.

2.1.4 Pilot Study and Routine Trash Rack Monitoring at IP1 Given the absence of intact trash racks at IP1, no pilot study or routine trash rack monitoring is proposed.

2.1.5 Trash Rack Monitoring Implementation Schedule, Modifications, and Permits The pilot study for trash rack monitoring at IP2 and IP3 will be implemented within 270 days of final approval of this monitoring plan by NMFS. The use of low light underwater cameras to monitor the trash racks as proposed will not require any major modification to IPECs intake structures that would need NRC or NYSDEC approvals before implementation. A modification will be required at IP2 and IP3 to allow access to the tops of the trash racks from the CWIS bulkhead deck at IP2 and IP3 for deployment of the camera and fish recovery devices. In addition, prior to implementation of trash rack monitoring, IPEC will need to provide the necessary safety and security clearances for the field crew to deploy the cameras through the trash rack slots at IP2 and IP3.

2.2 Monitoring in Forebays The Opinion requires monitoring for and removal of sturgeons from the intake forebays (i.e., the spaces between the trash racks and the traveling screens) in RPM#1 and T&C#s 1.d, 1.e, and 1.f. There are several reasons why this requirement is not reasonable to implement at IPEC, or warranted. First, any live sturgeon in the forebays will either swim back out into the river voluntarily through the trash racks or they will be collected on the continuously rotating Ristroph screens and released back into the river via the fish return troughs, making their removal from the forebays unnecessary. Second, this location is very difficult to access without major structural modifications and is a confined space posing safety issues for anyone working within it. Third, detection of sturgeon within the forebays using imaging sonar technology would not work well in this confined space due to interference from the structures with the sonar beams. Fourth, even if sturgeon could be detected, it would not be possible to capture and remove them in a way that would impose less stress than allowing them to either return to the river voluntarily or be collected on the Ristroph screens (a system proven to produce high survival rates).

Nonetheless, to address NMFSs request for information on the length of time that sturgeon spend in the forebays in the 23 October 2013 review letter, we propose to install a surveillance camera system through the downstream (forebay) sides of the trash rack slots at IP2 and IP3 (Figure 2-1) to observe sturgeon near the bottom within each of the forebays of IP2 and IP3 when the circulating water pumps are operating at those units. Due to the confined space and limited access, there is no feasible way to recover any sturgeon observed in the forebays of IP2 or IP3 by the camera systems.

Forebay monitoring will not be performed at IP1 because the IP1 CWIS no longer has intact trash racks to isolate the forebays.

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2.2.1 Forebay Monitoring at IP2 and IP3 Sturgeon present in the forebays of IP2 and IP3 will be monitored with a Splash Cam SideWinder 360 low-light digital underwater camera and underwater LED light source (Figure 2-6 and Figure 2-7). One SideWinder 360 camera unit will be deployed in each of the six isolated forebays at the IP2 intake structure (six total cameras). Six SideWinder 360 cameras will also be installed for viewing the forebays at IP3, one just inside near each of the trash racks, to observe the common plenum forebay structure there.

The SideWinder 360 is a dual camera unit. One camera within the SideWinder 360 views horizontally with a 360 degree panning motion. The second camera looks straight down.

Drift fins keep the camera from spinning when deployed from the reinforced video and power cable that would be extended down from the intake bulkhead deck to near the bottom in the IP2and IP3 forebays. A counter weight (downrigger ball) may be used if needed to keep the deployed camera and cable from drifting in the current towards the rotating traveling screen.

All six cameras at a unit (IP2 or IP3) will be connected to a single digital video recorder that is programmed to systematically and continuously sample the side-looking and down-looking SideWinder 360 cameras at five minute intervals. Five-minute recordings from each of the two viewing perspectives (horizontal or vertical) in each forebay will be labeled by location, sequentially arranged in time, and stored on the digital storage device (i.e., digital video recorder) using a Windows based software system designed for security surveillance systems (e.g., GeoVision DVR 16 Channel Analog Base i5 System Model PCPRO-GV16).

Therefore, one hour of recorded forebay observations from IP2 will contain five minutes of 360° horizontal viewing followed by 5 minutes of downward looking images from near the bottom of the IP2 Screen 21 forebay, followed by the same pair of horizontal and downward 5-minute observations from Screen 22, and so forth for the Screen 23, Screen 24, Screen 25, and Screen 26 forebays. The next hour of recorded forebay observation data at IP2 will repeat the first hour sequence, and continue to do so continuously for each successive hour in each week of the year when the IP2 CWIS is operating. A similar set of forebay observations will be obtained from the six SideWinder 360 cameras deployed at the IP3 CWIS, and recorded on a second dedicated digital video recorder and software system.

The field crew present each week to perform trash rack monitoring (Section 2.1 above) and traveling screen impingement monitoring (Section 2.3 below) will download the recorded digital video data from IP2 and IP3 onto a removable hard drive or thumb drive and take the digital recordings to the office for processing.

Efficient processing of 24/7 video monitoring data from IP2 and IP3 will require specialized commercial software (e.g., FishTick by Salmonsoft) to help apportion the recorded images into two types of images: those with sturgeon present, and those when sturgeon are not present. The digital recordings with sturgeon present, if any, then will be examined to enumerate the frequency and number of observations of sturgeon from the forebays of IP2 and IP3, and whether the fish observed appear to be alive or dead. The success in identifying sturgeon, and their condition, will depend on water clarity, turbidity, and orientation of the fish in the camera field of view. Concerns associated with distinguishing multiple counts of the same fish over time from multiple fish counted over time will be addressed to the extent practicable. Sturgeon images identified will be carefully scrutinized

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for the presence of any injuries or other unique identifying features that could facilitate resolving the sturgeon taxonomy and counts, where practicable.

2.2.2 Forebay Residence Study Implementation Schedule, Modifications, and Permits The forebay monitoring study for IP2 and IP3 will be implemented within 270 days of final approval of this monitoring plan by NMFS. Monitoring the forebays at IP2 and IP3 as proposed will require minor civil modifications to the security plates at the top of trash rack slots at IP3. Since these minor modifications are the same as needed for the trash rack monitoring at IP2 and IP3, the process to secure the necessary approvals will run concurrently for both studies. In addition, prior to implementation of the proposed forebay residence study, IPEC will need to provide the necessary safety and security clearances for the fixed installation of the cameras through the trash rack slots to monitor the forebays at IP2 and IP3.

2.3 Monitoring at Traveling Screens Monitoring, detection, and handling of sturgeons impinged on the traveling screens are required by RPM#1 and T&C#1.e of the Opinion.

As described in Section 1, IPEC's traveling screens meet USEPA's definition of Best Available Technology for reducing impingement mortality by (1) ensuring that aquatic organisms are retained on the screens for a very short time due to continuous rotation, (2) using modified "buckets" that provide a haven of stilled water protecting fish from turbulence before the screen rotates above the water, (3) having a specially designed wash system to remove organisms from the screens with a minimum of damage, (4) employing optimized return trough designs to eliminate damage during transit back to the river, and (5) releasing fish at locations selected to minimize re-impingement and predation. This entire system, designed and installed more than 20 years ago through the cooperative efforts of the IPEC owners, NYSDEC, and HRFA, minimizes mortality of fish and other organisms that interact with the traveling screens, if it is allowed to operate as designed.

Modifications to the system, and operation in a way that would ensure that all (as opposed to a representative sample of) sturgeon are detected, identified, and handled, will result in unnecessary mortality on many other species of impinged fish, particularly clupeids (herrings) and engraulids (anchovies), which are not as hardy as sturgeons. For this reason, we propose a sampling approach to this requirement that will permit accurate estimation of the levels of sturgeon impingement (Cochran 1977), while still allowing most other impinged fish to be returned rapidly to the river and minimize their mortality.

2.3.1 Traveling Screen Sluice Sampling Consistent with the shared goal (by Entergy, NYSDEC, HRFA, and presumably also NMFS) of minimizing stress on all impinged fish (including sturgeon), sturgeon that are collected by the continuously rotated traveling screens will be sampled during three 24-hour sampling days per week at each operating unit during the first year of monitoring. In the second year, Entergy will examine the results from the first year to consider and discuss with NMFS whether a variable frequency sampling plan can be implemented in which that sampling effort is redistributed among seasonal sampling strata (Mattson et al. 1988) to better reflect the observed seasonality of sturgeon impingement. If the variable frequency

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plan is not adopted, the year one methodology described below will be followed in year two.

To enable IPECs fish handling and return system to convey live impinged fish promptly back into the Hudson River with minimal stress, impingement sampling will be scheduled for 24 consecutive hours (one sampling day) on the three selected sampling days per week.

Instead of diverting 24-hours of sluice flow into one or more large collection tanks as described in our first study plan of 29 March 2013, impingement sampling will be accomplished by filtering the screen wash contents from all operating traveling screens at IP1, IP2, and IP3 through sampling nets inserted in the combined return sluices at each unit.

At each unit, both the fish sluice and the debris sluice will be sampled. The field crew will continuously staff and monitor each collection net during all 24-hours of each sampling day to detect and remove each sturgeon shortly after it is collected (i.e., within one hour). A blocking net made of 3/8 inch delta mesh liner and an outer 1-inch knotted-twine chafing net will be inserted into each sluice and held in place by U-channel guides (Figure 2-8). A second blocking net, located in the same sluice but just downstream from the first, will insure that one net is always collecting the sluice flow contents while the other net is being cleaned of debris and checked for sturgeon.

As soon as a sturgeon is observed, it will be removed from the sluice sampling net and placed in a 150-gallon oval holding tank located on the deck level adjacent to the sampler for subsequent processing (Figure 2-9). The holding tank at each unit will be covered with a mesh panel to prevent fish escapement and deter predator access and supplied with a continuous flow of ambient (un-chlorinated) river water at a flow rate where the volume is replaced every 15 or 20 minutes (Kahn and Mohead 2010). Water temperature, pH, dissolved oxygen concentration, total residual chlorine, and total ammonia nitrogen will be monitored and recorded in the water of the holding tank(s) during each interval when one or more sturgeon are being held for processing. Since this revised study plan no longer proposes to divert sluice flow into large collection tanks, and instead proposes to use standard and commercially available holding tanks and practices recommended by NMFS, this revised study plan does not anticipate the need to provide the series of engineering drawings requested by NMFS in Section 2.3.3 of their letter of 23 October 2013.

Pairs of the sluice sampling nets will be installed and operated in the combined fish sluice and in the combined debris sluice at the north end of IP2 (Figure 2-10). The sluice sampling nets for IP3 will be installed in the elevated fish sluice and the elevated debris sluice at the south end of the screen house (Figure 2-11). The sluice sampling nets for IP1 will be installed and operated where the combined fish sluice and combined debris sluice exit at the southwest end of the screen house (Figure 2-12). All fish and debris collected during each sampling day will be examined for the presence of sturgeon, and any sturgeon found will be removed and processed as described in Section 2.4. During each scheduled sampling day the field crew will also systematically inspect the entire sluice system and water boxes at each intake structure for the presence of resident sturgeon and remove any sturgeon that were not washed through the system into the collection nets. The recovery location (sluice, water box, net) of each sturgeon will be recorded.

A batch of 36 dead White Sturgeon between 100 mm TL and 600 mm TL will be obtained from the same commercial caviar hatchery operation described above for trash rack residency tests (Section 2.1 above) and used to determine the collection efficiency of

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impingement sampling with the sluice samplers. Each collection efficiency fish will be marked with a PIT tag and 18 tagged White Sturgeon will be introduced in random order in the forebay area near or on the ascending face of each of the six randomly selected Ristroph screens at IP2 or IP3 (3 fish per screen) on one randomly selected sampling date per month.

The number of White Sturgeon recovered in the deployed sluice samplers compared to the number released will determine both the collection efficiency for each intake structure and the apportionment of these test sturgeon among the fish and debris sluices. Recovered test fish will be frozen and re-used in subsequent collection efficiency tests if not in a state of advanced decay.

Fish, other than sturgeon and debris, will be allowed to return to the river in the sluice flow downstream from the sampling devices without being processed, because previous studies have optimized the survival of these fish during development and testing of the Ristroph screens and fish return system at IPEC (Fletcher 1990). We have been advised by counsel that obtaining additional data describing the impingement abundance of fish species other than Atlantic and Shortnose Sturgeon, which is outside of NMFS jurisdiction, will be addressed directly with NYSDEC within the SPDES permitting process.

2.3.2 Traveling Screen Monitoring Implementation Schedule, Modifications, and Permitting Once NMFS has approved the final monitoring plan and NYSDEC has approved any modifications to the CWIS within its jurisdiction, there are certain other reviews required by IPEC to ensure that continued safe operation of IPEC is not jeopardized by the proposed CWIS modifications. Traveling screen monitoring is proposed to be implemented within approximately 270 days after the later of NYSDECs approval of the monitoring plan and the associated changes to the design and operation of the Ristroph screen sluice system or the completion of the NRC-mandated modification review discussed below.

Traveling screen monitoring will require minor modifications of the NYSDEC-approved fish return systems to allow the deck grates or plating that cover the sluices to be removed or modified and the sluice samplers to be installed. Thus, NYSDECs prior approval may be required before making these changes to IPECs fish return system and its operation.

Consultations will be held with NYSDEC during the finalization of the monitoring plan to obtain their necessary approval in advance.

Entergy also provided the following list of steps that likely will be required to install the sluice sampling systems at IP1, IP2 and IP3 in compliance with all applicable IPEC procedures:



Obtain a Project Manager/Engineer and project team,



Develop a Project Plan,



Obtain detailed cost estimate and funding approval,



Obtain plant approval from engineering change review group and other management committees, as needed,



Develop an Engineering Request and Engineering Change,



Develop a Risk Management Plan,

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Perform a 10CFR50.59 screening to determine if an NRC review is required (an NRC review is not likely to be required),



Determine the actual screen wash flow rates to enable finalization of the size and design of the collection tanks,



Perform an engineering structural analysis to ensure that flooring and underground utilities can support the weight of the sturgeon holding tanks at the chosen locations,



Obtain a contractor,



Procure the equipment,



Develop IPEC operating procedures,



Develop biologist Standard Operating Procedures (SOP), and



Connect the completed system and test it, 2.4 Fish Handling Procedures Any Atlantic or Shortnose Sturgeon collected will be processed as required under the federal Endangered Species Act following the stated RPMs and T&Cs of the Opinion.

2.4.1 Live Fish All live sturgeon will be processed as specified in RPM#2 and T&C#3 of the Opinion by the procedures described in this section to check for previously applied tags, measure the length and weight, record any physical abnormalities, photograph, apply a passive-integrated transponder (PIT) tag in each untagged live sturgeon larger than 250 mm TL that was not previously tagged, collect a genetic sample, and release the specimen away from the intake via the existing fish return system.

Previously applied tags could include yellow USFWS Floy tags, Carlin-Ritchie disc tags, or PIT tags. A hand-held PIT tag reader will be used to examine for the presence of internal PIT tags. The tag type and number of any tags found will be recorded and the condition of the tag insertion site will be noted (whether healed or infected).

The total length (TL) will be measured to the nearest mm and the fish will be weighed to the nearest gram.

Any obvious external physical abnormalities, such as fin rot, will be recorded and photographed.

Photographs will also be taken of all sturgeon to provide verification of the species identification and condition. Digital photographs of each specimen will include a close-up of the eyes with a mm ruler for scale, a close-up of the mouth with a mm rule for scale, a close-up side view of the base of the anal fin to reveal the presence or absence of anal scutes, and lateral views of the left and right side of the fish.

Before a live sturgeon >250 mm TL is released it will be tagged with a PIT tag (if one is not already present and, if in the judgment of the field crew, doing so would not disable or kill the fish) to assess re-impingement and post impingement handling and tagging survival.

The tag will be inserted with a large hypodermic needle under the third or fourth dorsal scute by first puncturing in a fleshy area and then positioning the needle to push up

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underneath the scute. The fish will be scanned with the PIT tag reader and the tag number will be recorded.

A genetic sample will be collected by the procedures in Section 2.4.3 from all sturgeon collected and sent every six months to the NOAA archives in Charleston, SC.

Live sturgeon will be released in the screen wash flow through existing return sluices, which were designed to transport impinged fish to locations sufficiently deep and far enough from the intakes to avoid the thermal plume and the intakes.

2.4.2 Dead Fish All dead sturgeon will be processed as specified in RPM#3 and T&C#4 of the Opinion. Dead sturgeon will be checked for previously applied tags. External criteria will be used to determine if a dead sturgeon was freshly killed or previously dead. Fish considered alive at the time of impingement will exhibit signs of life (body movement, opercular movement, etc.) or show indications of recent death (red or only slightly faded gill filaments; King et al.

2010). Fish considered dead prior to impingement will exhibit bodily decay, bleached gill filaments, or other signs of morbidity or death prior sample collection (King et al. 2010).

The nature of observed external injuries will be described. Genetic samples will be collected by the procedures in Section 2.4.3 from all dead sturgeons that were not previously tagged.

Dead specimens or body parts of Atlantic or Shortnose Sturgeon retrieved from the IPEC intakes will be photographed, measured, labeled with a unique sample number, and retained by freezing until delivered to a qualified individual (recommended by NMFS) annually to perform necropsies.

2.4.3 Genetic Samples RPM#4 and T&C#5 of the Opinion requires that a genetic sample will be taken from any live or dead Atlantic or Shortnose Sturgeon collected that was not previously tagged. Genetic sampling procedures will follow the description in the Appendix provided with the Opinion. A new pair of latex gloves and a new scalpel blade will be used for each individual fish to avoid cross-contamination of genetic material. If obvious contamination is observed, that genetic sample will be discarded. A 1 cm2 section will be cut from a pelvic fin and placed in a vial of 95% to 100% ethanol that has not been denatured with methanol or other chemical additives. The vial will be taped to prevent leakage, labeled with the sample number and fish identification number using a permanent marker, and sealed in a small Ziploc bag labeled internally and externally with the sample number. All genetic samples collected from alive or dead Atlantic and Sturgeon Shortnose observed while monitoring at IPEC will be accumulated in the field laboratory and shipped once every six months to the NOAA-NOS genetic tissue sample archive in Charleston, SC following the procedures specified in Section 2.6.3 below.

2.5 Ancillary Data 2.5.1 Temperature RPM#1 and T&C#1.l of the Opinion specifies temperature measurements at the trash racks and at the traveling screens, at surface, mid-depth, and bottom for each unit when a take of either species of sturgeon is observed.

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RPM#1 and T&C#1.l of the Opinion will be addressed by reporting the measured water temperature for each sampling event when a sturgeon of either species is observed on the trash racks or traveling screens at IP1, IP2, or IP3. A sampling event is defined as the time interval during which the sturgeon was collected. Measured water temperatures will be obtained from loggers (e.g., Onset TidbiT v2 Water Temperature Data Logger) installed in the fish and debris sluice of IP1, IP2, and IP3 at the locations of the sluice samplers that continuously measure water temperature and logs the values at 5-minute intervals. The number of valid temperature observations and the mean, standard deviation, maximum and minimum values will be reported for each sturgeon sampling event.

2.5.2 Water Velocity RPM#1 and T&C 1.k of the Opinion specifies measuring actual water velocity at the trash racks (approach velocity and through the rack), in the intake forebays, and at the traveling screens (both approach velocity and through-screen velocity) at all three units "so that this information can be reported any time a take occurs." NMFS further clarified T&C 1.k in their letter of 23 October 2013 that their interest in these data is out of a concern for possible hotspots of high velocities at locations across one or more of the trash racks and traveling screens that render average velocities inaccurate for verifying the assumptions and conclusions of the Opinion. The velocity data requested by NMFS includes the high and low approach and through-screen velocities in each 2-foot square grid across the face of each trash rack and traveling screens representative of a range of tidal and weather conditions and actual pump operations that would bound all expected scenarios.

The intake velocity information sought by NMFS in RPM#1 and T&C 1.k of the Opinion, and further clarified in the 23 October 2013 letter, suggests that an empirical study may be required to obtain velocity data. However, robust modeling of velocity is now the norm and will produce more accurate information, and therefore is preferable as discussed below.

Indeed, are many reasons why direct measurement of approach and through-screen velocity at the IP1, IP2 and IP3 CWISs would be a futile effort:

1. Velocities at the IP1 traveling screens are already well below the 0.5 fps through screen value that USEPA considers sufficient to eliminate impingement concerns.

2. Due to the way that IPEC is operated, intake velocity is relatively constant.

Although the IPEC pumps can pump at different rates (IP2 at 60% or 100%, IP3 at a continuum of 50%-100%), the amount of water needed at any given time is determined by the river temperature. Therefore pumping rates, and subsequently intake velocities, actually have little variation from one day to the next and are typically higher in the summer and lower in the winter.

3. Due to the design of the trash racks, their location at the outer edge of the IP2 and IP3 intake structures, the presence of skimmer walls, and the ecology of the Hudson River estuary, debris accumulation at the trash racks is insufficient to block flow and substantially increase velocities at either the trash racks or traveling screens. The trash racks and traveling screens also serve to straighten the intake currents that pass through them, thus reducing the variation in velocity across the ascending face of the Ristroph-type traveling screens. Trash racks are cleaned only twice per year, during a semi-annual inspection, which is

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frequent enough to avoid high intake velocity incidents. The Ristroph-type traveling screens are cleaned continuously.

4. Sturgeon impingement events are not likely to be frequent enough to establish a meaningful relationship with velocity. Even if there is a large enough sample size, the low amount of flow variation will make establishing any relationship extremely unlikely.

5. It will not be possible to determine which traveling screens an impingement occurred on, therefore the exact velocity at the place of impingement cannot be determined.

6. The impracticality of continuous monitoring of sturgeon interaction with either the trash racks or traveling screens, and the herculean effort required to monitor velocity at all trash racks and traveling screens, would make it impossible to relate actual impingement events to a specific velocity.

7. Velocity will differ over the face of trash racks.

8. Measurements of actual through-screen velocity are not possible in the field for the continuously rotated traveling screens.

We propose to address the requirements of RPM #1 and T&C 1.k of the Opinion by using two existing nearfield Hudson River water current data sets to parameterize a computational fluid dynamics (CFD) model of the IP2 and IP3 CWISs. The CFD model will then be used to describe the mean, standard deviation and range of approach and through-screen velocities at a resolution no greater than 1 square foot across the face of each trash rack and each traveling screen operated at IP2 and IP3 under a bounding range of tidal, river flow, weather and intake pump scenarios.

The velocity distribution at the trash rack and the traveling water screens can vary when the approach flow is not normal to the screen surface. At IPEC this occurs because of the river currents. The river currents will cause a higher through screen velocity skewed towards the downstream end of the trash rack. The skewed velocity profile can propagate through the forebay resulting in a skewed velocity distribution at the traveling screens. The skew in the velocity distribution is caused and proportional to the velocity component parallel to the screen surface.

One of several commercially available computational fluid dynamics models that exist will be applied to the proposed modeling effort (e.g., Fluent, by ANSYS; or FLOW-3D, by Flow Science). The two models are similar in that both solve the Reynolds Averaged Navier-Stokes (RANS) equations with options for various turbulence models to simulate the creation, transport and dissipation of turbulent kinetic energy. However, implementation of the governing equations differs; Fluent uses a boundary fitted grid and FLOW-3D uses a structured grid. The solver in Fluent is better suited to steady state simulations while the FLOW-3D solver is very efficient for unsteady (time-dependent) simulations. Both models have the ability to simulate the trash rack and the traveling water screens with a porous media approximation. We propose to use Fluent with a steady state approximation for an efficient modeling effort rather than FLOW-3D and an unsteady simulation.

The proposed model will extend from downstream of the traveling water screens to a distance of two to four intake widths into the Hudson River. Because the skew in the

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velocity profile is expected to increase with increasing river currents (shear flow), the skew can be bounded without knowing exact river current magnitudes or direction. Shear flow will then be applied in the model without a need to model the cause of the shear flow. High resolution river bathymetry in front of the intake (Substructure 2010) will be used to describe the Hudson River bottom contours and substrate near the IP2 and IP3 CWISs.

The magnitude of the shear flow will be bounded using the existing ADCP data sets from two studies performed in the nearfield area of the Hudson River adjacent to IP2 and IP3 during 2010 (Normandeau 2011) and 2011 (Normandeau 2012). Typically river currents are slower near the shore than in the center of the river. A conservative estimate of the shear flow is to use the maximum observed velocities from the 2010 ADCP Stations 2A and 2B offshore near the IP2 CWIS and Stations 3A and 3B offshore near the IP3 CWIS (Figure 2-13). A less conservative estimate would use the measured ADCP velocities from in between the IP2 and IP3 CWISs at the IP1 barge site from the 2011 study (Figure 2-13). To cover the range of possible maximum velocities, this model will use the maximum from all locations for the initial simulations. Skew in the velocity should also be more pronounced at lower intake pump flows that typically occur during the winter. Therefore, a bounding simulation for each model will be run with the minimum pumping flow.

Two models will be created, one for each of the IP2 and IP3 CWIS. Each model will include the actual trash racks and traveling screens and the relevant intake geometry. Each trash rack or screen surface will be modeled as a porous medium with either the observed or designed headloss characteristics of that trash rack or screen. The headloss characteristics will be obtained either from actual observations recorded by IPEC, or directly from the screen manufacturer. If sufficient headloss information is not available from either of these two sources, headloss will be estimated from the screen open area and screen design.

Manufacturers data is considered more reliable than the estimates. Each model will be run for the maximum upriver and downriver velocity resulting in four simulations to define the extreme case condition. Depending on model results, additional simulations may be used to simulate average river conditions or river conditions with a specific exceedence probability.

The velocity distribution three inches upstream of each trash rack and traveling screen will be post-processed to create plots that show the percentage of screen area on the horizontal axis and the velocity percentile above or below the nominal through screen velocity on the vertical axis. The plots will quantitatively show the skew in the approach velocity.

The trash racks and the traveling screens cause headloss which serves to create a more uniform velocity distribution through the screens. The velocity distribution on the surface of the screen can be used to estimate the variability in the through screen velocity. The distribution is considered an estimate because the model will not include every bar and every gap in the trash rack or the traveling water screens. Resolving each screen member is beyond the limitations of existing computational resources. However, the estimated through slot velocity is expected to be very reliable. Plots quantifying the variability in velocity distribution across each trash rack or traveling screen will be made. In addition to the quantitative plots described above, color contour plots will be created for each trash rack and screen colored by absolute velocity or by or a dimensionless velocity showing the velocity distribution.

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IPEC has two data sets of continuously recorded nearfield Hudson River water currents available to be used to develop and validate the CFD model of the IP2 and IP3 intakes described above. These two data sets encompass the range of tidal and weather conditions, river flows, and pump operations that are representative of the Hudson River near IPEC.

The first data set consists of more than 4.5 million data points of current velocity and direction obtained during five-minute periods from 0.5 m or 1.0 m vertical depth layers overlying four acoustic Doppler current profilers (ADCPs) deployed in the Hudson River near the IP2 and IP3 CWISs during 4 March through 2 November 2010 (Figure 2-13). Water current velocity and direction were continuously monitored in each depth layer at four locations (Stations 2A and 2B offshore from IP2; Stations 3A and 3B offshore from IP3) throughout the overlying water column water to 1) evaluate the percentage of time that river currents of a particular velocity range equaled or exceeded designated current velocity increments, 2) determine the primary axes of current flow direction at each of the four Stations, and 3) determine frequency distributions of peak tidal current velocity data throughout the entire nine month monitoring period at each of the four Stations.

Two in situ upward-looking ADCPs were also installed on the Hudson River bottom at Stations 1S and 2N in close proximity to the IP1 pier (Figure 2-13) to continuously record river current velocity and direction throughout the overlying water column from 25 May through 26 September 2011. Water column turbulence data was also collected to provide actual field values of turbulence intensity for CFD modeling of the intake structures. The fixed position ADCPs measured and recorded the physical dynamics of the Hudson River currents in a data set consisting of more than 729,000 data points of current direction and velocity during five-minute intervals from 0.5 m and 1.0 m depth intervals throughout a 50 foot deep water column at the IP1 location, which is in between the IP2 and IP3 CWISs.

This 2011 ADCP data set also includes approximately 58 million data points represented by bursts of water direction and velocity data obtained to measure turbulence at one-second intervals. Data recorded from this IP1 site are available for analysis from daily and tidal timescales down to one-second turbulence timescales, including velocity, direction, temperature, depth, and water surface elevation.

2.5.3 Plant Operating Data RPM#1 and T&C 1.m of the Opinion requires that the plant operating conditions at each unit are documented for the previous 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> associated with each take, the field staff will contact the control room and obtain and record data provided by the plant operators regarding the number of circulating pumps operating.

2.5.4 Ancillary Data Collection Implementation Schedule, Monitoring, and Permits Ancillary data collection will be implemented when sturgeon impingement monitoring is initiated. No NRC or State of New York approvals are required before implementation of ancillary data collection. No physical plant alterations are necessary to allow ancillary data collection to be implemented other than affixing the temperature loggers in the return sluices near the collection nets.

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2.6 Reporting This section describes procedures for reporting to NMFS all sturgeon incidental takes and sample transfers as required by RPM#5 and T&C#s 6, 7 and 8 of the Opinion.

2.6.1 Take Notification NMFS will be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of finding any live or dead Atlantic or Shortnose Sturgeon in association with the IPEC intakes as required by RPM#5 T&C#6 of the Opinion.

The form for reporting each incidental take of any sturgeon (alive or dead) is shown in Figure 2-14.

2.6.2 Annual Report An annual report of all incidental takes of Atlantic and Shortnose Sturgeon occurring at the IPEC intakes during each calendar year will be submitted to NMFS and NRC by 15 February of the following year as required by RPM#5 T&C#7 of the Opinion. The annual report will include any necropsy reports of specimens, all incidental take reports, photographs, a record of all sightings of Atlantic or Shortnose Sturgeon in the vicinity of Indian Point, conditions at the time of the take (IPEC operations as well as environmental conditions including water temperature and water flow), and a record of when inspections of the intake trash racks and Ristroph screens were conducted. The report will include a summary table of environmental sampling data in the format specified by NMFS (Figure 2-15). The annual report will also identify any potential measures to reduce Atlantic or Shortnose Sturgeon impingement, injury, and mortality at the intake structures along with any plans to implement those measures.

Following the submittal of each annual report and prior to 15 April of each year, Entergy will participate in a meeting or conference call with NMFS and NRC to discuss the take information of the prior year and any changes to the monitoring program that NMFS, NRC, or Entergy believes are necessary as required by RPM#5 T&C#8 of the Opinion.

2.6.3 Genetic Samples As specified in the NMFS instructions for collecting, certifying, identifying, and shipping sturgeon tissue samples (Figure 2-16), each shipment of sturgeon genetic tissue samples will be accompanied by (1) a completed Certification of Species, Sample Identification, and Chain of Custody form for each fish (Figure 2-17); (2) a completed Summary Sheet for Genetic Tissue Samples form if the shipment contains multiple samples (Figure 2-18); (3) a completed NMFS Guidelines for Air-Shipment of Excepted Quantities of Ethanol Solutions form (Figure 2-19); and (4) a copy of the ESA permit authorizing the collection of the sample(s). Because the origin of impinged fish factors into the take limits specified in the ITS, Entergy requests to receive the results of the genetic analysis as testing is completed on each fish.

2.6.4 Dead Sturgeon or Sturgeon Parts If any dead specimens of Atlantic or Shortnose Sturgeon are found in association with the IPEC intake sampling procedures specified in this monitoring plan, after they are processed as described in Section 2.4.2, NMFS may request transfer of the specimens to NMFS or to a NMFS-approved laboratory or researcher for necropsy. In addition to the take notification

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form (Section 2.6.1), a Sturgeon Salvage form (Figure 2-20) will also be submitted to an individual or laboratory qualified to perform necropsies and recommended by NMFS, to document the disposition of each dead specimen.

2.7 Training of Field Biologists Qualifications of all personnel who will be handling sturgeon will include previous training and experience in the implementation of NMFS Permit to Take Protected Species for Scientific Purposes Permit No. 17095 (and its predecessor, Permit No. 1580) for the Hudson River Biological Monitoring Program (HRBMP). All field personnel participating in the IPEC sturgeon monitoring will be required to read the SOP and will be provided with the appropriate training. Monitoring personnel unfamiliar with a task will be directly supervised by an experienced technician for at least the first two attempts and be subjected to 100% inspection of at least the first five samples analyzed independently.

2.8 QA/QC Procedures The basis for all quality control (QC) and quality assurance (QA) monitoring of program activities will be the SOP, consisting of written documentation of sampling and data collection protocols. The SOP will be developed from the objectives and methods in the final monitoring plan approved by NMFS, and will be prepared before monitoring begins.

The SOP will function to (1) insure that consistent and appropriate procedures are followed, (2) provide Entergy with documentation of the procedures used, and (3) enable a QA auditor observing program activities to determine whether the required procedures are being followed.

QC will be conducted continually by qualified project staff. All field observations and measurements of sturgeon (identification, length, weight, injury, condition, tag numbers, etc.) will be subject to a standard and appropriate QC and QA review based on a Military Inspection Standard (MIL-STD) inspection plan derived from MIL-STD 1235 Single and Multiple Level Continuous Sampling Procedures and Tables for Inspection by Attributes to achieve a 10% Average Outgoing Quality Limit (AOQL). QC re-inspections for these sample processing tasks will be performed according to the continuous sampling plan CSP-1 at the 10% AOQL level, to insure that at least 90% of samples satisfy the projects acceptance criteria. This level of quality meets or exceeds New York, industry-wide, and HRBMP standards for fisheries measurement data.

All final data files and reports will be subject to a standard and appropriate QC inspection to achieve a 1% AOQL so that the final data files will be certified through statistical inspection to document that less than one record (line of data) out of every 100 records will be in error. A QC inspection plan (CSP-1) will be used at the 1% AOQL level to insure that values of all variables in at least 99% of the data records provided in each data file correctly correspond to values coded on the original data sheets. This level of quality meets or exceeds New York, industry-wide, and HRBMP standards for fisheries data files.

At least one QA Audit of the field activities described in Sections 2.1 through 2.5 above will be performed per year to verify adherence to the technical protocols specified in the SOP and verify the effectiveness of the QC system. QA auditors will be technically qualified to evaluate the activities being observed but independent from the project team. The audits

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will cover all activities described in the SOP, including transfer of data from field to completed data deliverables. The audit results will be documented in a written report for review by project management, Normandeau corporate management, and Entergy.

3.0 Literature Cited ASA (Applied Science Associates, Inc.). 2011. 2010 field program and modeling analysis of the cooling water discharge from the Indian Point Energy Center. Final report. ASA Project 2009-167. Prepared for: Indian Point Energy Center, Buchanan, New York. 31 January 2011.

Bergman, P. 2011. Videography Monitoring of Adult Sturgeon in the Feather River Basin, CA. Report prepared by Cramer Fish Sciences for Anadromous Fish Restoration Program.

http://www.fws.gov/stockton/afrp/documents/Feather_Sturgeon_Report_022811.pdf Bergman, P., J. Merz, and B. Rook. 2011. Memo: Green Sturgeon Observations at Daguerre Point Dam, Yuba River, CA. FWS Grant Number: 813329G011.

http://www.fws.gov/stockton/afrp/documents/Yuba_River_Sturgeon_Memo.pdf Cochran, W.G. 1977. Sampling techniques. Third Edition. John Wiley and Sons, New York.

428pp.

Enercon (Enercon Services, Inc.). 2010. Evaluation of alternative intake technologies at Indian Point Units 2 & 3. Prepared for Entergy Nuclear Indian Point 2, LLC, and Entergy Nuclear Indian Point 3, LLC, February 2010.

Electric Power Research Institute (EPRI). 2004. Impingement Abundance Monitoring Technical Support Document. EPRI Report 1008470. Palo Alto, CA.

Fletcher, R.I. 1985. Risk analysis for fish diversion experiments: pumped intake systems.

Trans. Amer. Fish. Soc. 114:652-694.

Fletcher, R.I. 1990. Flow dynamics and fish recovery experiments: water intake systems.

Trans. Amer. Fish. Soc. 119:393-415.

Garman, G.C. 1992. Fate and potential significance of postspawning anadromous fish carcasses in an Atlantic coastal river. Trans. Amer. Fish. Soc. 121: 390-394.

King, R.G., G. Seegert, J. Vondruska, E.S. Perry, and D. A. Dixon. 2010. Factors Influencing Impingement at 15 Ohio River Power Plants. North American Journal of Fisheries Management 30: 1149-1175.

Kahn, J. and M. Mohead. 2010. A protocol for use of Shortnose, Atlantic, Gulf and Green Sturgeons. U.S. Dep. Commerce, NOAA Tech. Memo. NMFS-OPR-45, 62 p.

Mattson, M.T., J.B. Waxman, and D.A. Watson. 1988. Reliability of impingement sampling designs: an example from Indian Point Station. Amer. Fish. Soc. Monogr. 4:161-169.

Normandeau Associates, Inc. (Normandeau) 2011. Analysis of Near-Bottom Flow in the Hudson River at Indian Point Energy Center from Data Collected by Acoustic

MONITORING PLAN FOR IPEC STURGEON IMPINGEMENT REVISION 1 IPEC_sturgeon_monitoring_plan_revision_1.docx 1/8/14 22 Normandeau Associates, Inc.

Doppler Current Profilers 4 March through 2 November 2010. Prepared for Indian Point Energy Center; Buchanan, NY.

Normandeau 2012. Current velocity and turbulence monitoring for the cylindrical wedgewire screen efficacy study at Indian Point Energy Center. Prepared for Indian Point Energy Center; Buchanan, NY.

Schneider, J.C. 1998. Fate of dead fish in a small lake. Am. Midland Naturalist 140 (1): 192-196.

Substructure, Inc. 2010. Data report for the April 2010 multibeam and sub-bottom profile survey in the Hudson River near Peekskill, New York. Prepared for Normandeau Associates, Inc. Bedford, NH.

USEPA (U.S. Environmental Protection Agency). 2011. Technical development document for the proposed Section 316(b) Phase II existing facilities rule, March 28, 2011, p. 7-2.

USFWS (U.S. Fish and Wildlife Service) and NMFS (National Marine Fisheries Service).

1998. Endangered Species Act consultation handbook procedures for conducting Section 7 consultations and conferences. March 1998 Final.

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Figures

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Figure 1-1. Indian Point Unit 2 (IP2) cooling water intake structure - plan view.

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Figure 1-2. Indian Point Unit 2 (IP2) cooling water intake structure - sectional view.

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Figure 1-3. Indian Point Unit 3 (IP3) cooling water intake structure - plan view.

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Figure 1-4. Indian Point Unit 3 (IP3) cooling water intake structure - sectional view.

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Figure 2-1. Trash rack slots at the outer (western) side of the IP2 cooling water intake structure.

Figure 2-2. Telescoping pole with locking noose proposed to retrieve sturgeon observed on the outer side of the trash racks at IP2 and IP3.

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Sturgeon detection by underwater video on the trash racks at IP2 and IP3:



Ability to detect sturgeon directly related to turbidity of surrounding waters



Previous studies and surveys have successfully identified sturgeon at depths of 30 feet or more, with water clarity of about 15 feet or less; and turbidity = 1.75 NTU or less (Bergman 2011) using video



Splash Cam© Deep Blue Pro underwater camera http://www.splashcam.com/deepblue/db.htm o Approximately $1500 o High resolution color picture o Low Light Operation o Virtually Indestructible Camera Housing o Military Grade Umbilical Cable (15 m standard) o High Bright LED Underwater Lighting o Easy Deployment / Recovery o Recessed Lens Will Not Scratch o No Installation Required, Fully Portable



EverFocus ECOR 4D 465 GB DVR unit with GPS and time overlay and displayed in real-time on a 38 cm LCD monitor o DVR about $500 o Monitor about $300



Auxiliary removable light source o Underwater Lighting $90 o Battery operated underwater 2.4 watt Xenon lighting pod. Depth rated to 500 ft. Allows for viewing of up to 15 feet from the camera in complete darkness.

o P/N: LP-100DB - MADE FOR DEEP BLUE CAMERA Figure 2-3. Low-light underwater camera system proposed for observations of trash rack impingement of Atlantic and Shortnose Sturgeon at IP2 and IP3.

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Camera Specifications Video Output:

Composite NTSC (PAL Optional) - works with any video device with RCA video input Focus:

Fixed 1 inch to focal infinity Auxiliary Lighting:

High Intensity LED Resolution:

520 TV Lines CCD:

1/3" Sony Super HAD II Pixel Array 768(H )X 494(V)

Lens:

3.6mm Iris:

Electronic Operating Temp:

-10 to 55C Light Sensitivity:

0.1 lux Input Voltage:

12 volts DC Current Draw:

90 mA Physical Specifications Body Construction:

Anodized Cast Aluminum Exterior Finish:

Thermoplastic Paint Camera Weight:

1.2lbs water / 2lbs air (Dive weight can be added)

Depth Rating:

800ft standard / 2000ft with upgrade Cable Strength:

700lbs break strength / 250lbs nominal work load Available Cable Lengths:

50-1000ft in 50ft. increments Dimensions:

3" Dia. / 3.5" Length Weight with 50ft Cable:

10lbs Figure 2-4. Specifications of a Splash Cam Deep Blue Pro Video system for detecting Atlantic and Shortnose Sturgeon impinged at the IP2 and IP3 trash racks.

Camera is shown mounted on auxiliary light source.

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Figure 2-5. Example screen capture from a Splash Cam Deep Blue Pro video of a free-swimming white sturgeon at a depth of 6.7 m and turbidity of 1.75 NTU in the Yuba River, California, USA (Bergman, et al. 2011).

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Figure 2-6. Low-light 360°panning underwater camera system (Splash Cam SideWinder 360) deployed with stabilizer fins for forebay observations of Atlantic and Shortnose Sturgeon at IP2 and IP3.

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Camera Specifications Video Ouput:

Composite NTSC (PAL Optional) - works with any video device with RCA video input Auxiliary Lighting:

High Intensity White LED Resolution:

510 TV Lines CCD:

1/3" Sony Focus:

1.5" to Focal Infinity Lens:

3.6mm Iris:

Electronic Operating Temp:

-10 to 55C Light Sensitivity:

0.3 lux Input Voltage:

12 volts DC Current:

270 mA max.

Figure 2-7. Specifications of a Splash Cam SideWinder 360 dual underwater camera unit for detecting Atlantic and Shortnose Sturgeon in the intake forebays of the IP2 and IP3.

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Physical Specifications Body Construction:

Stainless Steel / Acrylic Camera Weight:

3.2lbs water / 4lbs air Depth Rating:

450ft.

Cable Strength:

200lbs break strength / 50lbs nominal work load Cable Length 290ft Dimensions 10 H x 3 D Figure 2-7.

(Continued)

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Figure 2-8. Example of a sluice sampling net and frame (without delta mesh liner).

Figure 2-9. Example of two 150-gallon sturgeon holding tanks.

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Figure 2-10. IP2 Ristroph screen fish sluice (right) and debris sluice (left) return system shown under yellow deck grating looking north from the north end of the IP2 intake bulkhead.

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Figure 2-11. IP3 Ristroph screen fish sluice (top) and debris sluice (bottom) return system shown looking north from the south end of the IP3 intake bulkhead.

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Figure 2-12.

IP1 sluice system located under deck plates at the southwestern corner of the screen house where sluice sampling would occur when the plates are removed.

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Figure 2-13.

Acoustic Doppler current profiler (ADCP) monitoring station locations near IP2 and IP3 from continuous monitoring studies performed during 2010 (Stations 2A, 2B, 3A, 3B) and 2011 (Stations 1S and 2N). The base image is from Google Earth.

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Incident Report Sturgeon Take - Indian Point Photographs should be taken and the following information should be collected from all sturgeon (alive and dead) found in association with the Indian Point intakes. Please submit all necropsy results (including sex and stomach contents) to NMFS upon receipt.

Observer's full name:_______________________________________________________

Reporters full name:_______________________________________________________

Species Identification :__________________________________________

Site of Impingement (Unit 2 or 3, CWS or DWS, Bay #, etc.):________________________________

Date animal observed:________________ Time animal observed: ________________________

Date animal collected:________________ Time animal collected:_________________________

Environmental conditions at time of observation (i.e., tidal stage, weather):

Date and time of last inspection of intakes:_____________________________________

Water temperature (°C) at site and time of observation:_________________________

Number of pumps operating at time of observation:____________________________________

Average percent of power generating capacity achieved per unit at time of observation:________

Average percent of power generating capacity achieved per unit over the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> previous to observation:___________________________________________________________________

Sturgeon Information:

Species _________________________________

Fork length (or total length) _____________________ Weight ______________________

Condition of specimen/description of animal Fish Decomposed: NO SLIGHTLY MODERATELY SEVERELY Fish tagged: YES / NO Please record all tag numbers. Tag # ________________

Photograph attached: YES / NO (please label species, date, geographic site and vessel name on back of photograph)

Figure 2-14. Incident report form for incidental take of Atlantic Sturgeon or Shortnose Sturgeon by impingement at the IPEC cooling water intakes.

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Draw wounds, abnormalities, tag locations on diagram and briefly describe below Description of fish condition:

Figure 2-14 (continued).

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Figure 2-15. Summary form for environmental data associated with incidental take of Atlantic Sturgeon or Shortnose Sturgeon.

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Figure 2-16. Instructions for collecting, certifying, identifying, and shipping sturgeon tissue samples.

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Figure 2-17. Certification of species, sample identification, and chain of custody form.

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Figure 2-18. Summary form for sturgeon genetic tissue samples.

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Figure 2-19. Guidelines and form for air shipment of excepted quantities of ethanol solutions.

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Figure 2-19 (continued).

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Figure 2-20. Sturgeon salvage form.

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Figure 2-20 (continued)

30 International Drive, Suite 6, Pease International Tradeport Portsmouth, NH 03801 Tel (603) 319-5300 Fax (603) 334-6397 www.normandeau.com Bedford, NH (Corporate)

North Haven, CT Falmouth, MA Haverstraw, NY Stowe, PA Stevenson, WA Lewes, DE Gainesville, FL Falmouth, ME Hampton, NH Portsmouth, NH Westmoreland, NH Oswego, NY Drumore, PA Aiken, SC Moncks Corner, SC Vancouver, WA E. Wenatchee, WA An Employee-Owned Company An Equal Opportunity Employer 3 December 2013 Mr. John K. Bullard, Regional Administrator National Marine Fisheries Service 55 Great Republic Drive Gloucester, MA 01930-2276 Re: Proposed Monitoring Plan for Indian Point Energy Center Take of Atlantic and Shortnose Sturgeons by Impingement at Cooling Water Intakes Revision 1

Dear Mr. Bullard:

Please find enclosed one copy of the revised (Revision 1) Monitoring Plan that was prepared on behalf of Entergy Nuclear Operations, Inc. (Entergy) Indian Point Energy Center (IPEC) by Normandeau Associates, Inc. (Normandeau) and ASA Analysis and Communications, Inc. (ASA) to address Reasonable and Prudent Measure (RPM) #1 as specified in Terms and Conditions (T&C) #1 of the Final Biological Opinion for Continued Operation of Indian Point Nuclear Generating Unit Nos. 2 and 3 dated 30 January 2013, and your subsequent comments in a letter to Ms. Dara Gray of IPEC dated 23 October 2013.

A copy of this letter and the Revision 1 Monitoring Plan were also sent by email to the members of your staff and others identified in the enclosed distribution list. We look forward to answering any remaining questions that you or your staff may have and to implementing the Revision 1 Monitoring Plan as proposed. Please contact Ms. Dara Gray of IPEC at the address shown below if you have further questions.

Sincerely, NORMANDEAU ASSOCIATES, INC.

Mark T. Mattson, Ph.D.

Vice President

2 Email Distribution List 3 December 2013 (those with mailing addresses will also receive printed copy):

Proposed Monitoring Plan for Indian Point Energy Center Take of Atlantic and Shortnose Sturgeons by Impingement at Cooling Water Intakes Revision 1 3 December 2013.

Ms. Mary A. Colligan Assistant Regional Administrator for Protected Resources National Marine Fisheries Service Protected Resources Division, NMFS/NERO 55 Great Republic Drive Gloucester, MA 10930-2276 Ms. Julie Crocker Julie.Crocker@NOAA.gov National Marine Fisheries Service Protected Resources Division, NMFS/NERO 55 Great Republic Drive Gloucester, MA 01930-2276 Donald Dow (NMFS)

Donald.dow@noaa.gov Ms. Julie Williams Julie.williams@noaa.gov Mr. Chuck Nieder wcnieder@gw.dec.state.ny.us Steam Electric Unit Leader New York State Department of Environmental Conservation 625 Broadway, 5th Floor Albany, NY 12233-4756 Briana Grange (NRC)

Briana.Grange@nrc.gov Mr. Dennis Logan (NRC)

Dennis.Logan@NRC.gov Michelle Moser (NRC)

Michelle.Moser@nrc.gov Mr. Fred Dacimo (IPEC) fdacimo@entergy.com Indian Point Energy Center 450 Broadway, Suite 1 Buchanan, NY 10511

3 Email Distribution List 3 December 2013 (continued)

Ms. Dara Gray (IPEC) dgray@entergy.com Indian Point Energy Center 450 Broadway, Suite 1 Buchanan, NY 10511 Dr. Larry Barnthouse (LWB Environmental)

Barnthouse@lwb-env.com Dr. Douglas Heimbuch (AKRF)

DHeimbuch@AKRF.com Dr. John Young (ASA) jyoung@asaac.com Dr. Mark Mattson (Normandeau) mmattson@normandeau.com Normandeau Associates, Inc.

30 International Drive, Suite #6 Portsmouth, NH 03801