ML20079N348

Industry Survey in Support of License Renewal Rulemaking for Indian Point 2

ML20079N348
Person / Time
Site:	Indian Point
Issue date:	07/06/1990
From:	CONSOLIDATED EDISON CO. OF NEW YORK, INC.
To:
References
RTR-NUREG-1437 AR, S, WM, NUDOCS 9111110173
Download: ML20079N348 (27)

Text

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INDUSTRY SURVEY (n Support of UCENSE RENEWAL RULEMAKING d

for CONSOUDATED EDISON's lNDIAN POINT 2

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f July 6,1990 i

L ' Note: . Response to Aquatic Resources Questions are for the site which 1.* cludes the New York Power Authority Indian Point 3, otherwise all the remaining responses apply .

only to Con Edison and Indian Point 2, 4.

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y/ASTE MANAGEMENT OUESTIONS

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A. Spent Fuel Questions:

1. Which of the following patrgn1 techniques for at reactor storage are you using and how?

A. Re-racking of spent fuel.

2. Do you plan on continuing the use of these fattntal techniques for at-reactor storage of spent fuel during the remaining time of your operating lleensing or do you expect to change or modify them in some way?

A. Indian Point 2 is currently reracking the Spent Fuel Pool. The new racks will provide storage until 2007. The current Indian Point 2 license explies it: 2013. No additional reracks will be possible triter this rerack so the racks have been designed to hold consolidated fuel. Fuel consolidation and other options will be considered in the late 1990's, as will enforcement of the current legislative requirements for the ,

federal government to assume responsibility.

3. Which of the following techniques for at-reactor storage do you .

enticinato using until off site spent fuel storage iecomes available and how?

A. The last rerack it currently being dane and dry storage, rod consolidation and loriger fuel burnup are all being considered in the everst DOE has not started accepting fuel by 2007.

4. Will the techniques described above be adequate for continued at-reacter storage of spent fuel for the operating lifetime of the plant, including 20-year period of license renewal, or are you developing other plans?

A. See answers to 2 and 3. These options will provide sufficient storage space.

5. Do you anticipate the need to acquire additional land for the ,

storage of spent-fuel for the operating lifetime of the plant, including a 20-year period of license renewal? If so, how much ,

land? When would this acquisition occur? Where? (if answer is .

• yes",3-4 sentences).

A. No

Waste Management Questions (cont'd)

. i

6. Do you anticipato any additional construction activity on-sito or immediately

. adjacent to the power plant sito, associated with the continued at reactor storago of spent fuel for the operating lifetimo of the plant, including a 20. year period of licenso renewal? (yes/no).

A. No.

B. Low-level Radioactive Waste Management Questions:

1. Under the current scheme for LLRW disposal (l.o. LLRW Policy

^ mondments Act of 1985 and regional compacts) is thoro currently or will sufficient disposal capacity for wastes generated during the license renewal period be available to your plant (s)? If so, what is the basis for this conclusion?

A. The ctatus of the search for a New York State LLRW disposal site is uncertain at this time. The continuing use of existing or other compact sites for our waste, and for what period of time, is unclear.

2. If for any reason your plant (s) is/are denied access to a licensed disposal site for a short period of time, what plans do you havo for a

continued LLRW disposal?

A. We will continue our volume reduction program and nave it stored onsite up to 5 years per the NRC guidance in a qualified lOS facility.

3. in a couplo of pages, please describe the specific methods of LLRW management r:urrently utilized by your plant. What porcentage of your current LLRT Dy volume) is m&aaged by:

a. Waste compaction?

30% - Soda Ash Drums are ore-qomnslesLt9_25.0 Kihen supercompacted to 500 lbs plus at CNSI's lilinois faellity I

b. Wasto segregation (through special controls or segregation at radiation check point)?

, 55 % - Colored baa system or manual secregation: applies to a. c and e.

• c. Metal decontamination. sectioning and supercompaction by SEG Inc.

5_0%

Waste Management Questions (cont'd)

d. Sorting of waste prior to shipment? I -

100% all comoactaAle DAW: app!!es to a,

e. Other (please specify) 15%

EDELBJialling Steam Cleanina Freon Cleanina Sectionina Free.Rt! fait 4

f. Direct Burla!

5% - Resin. Fitters and dhdge

4. In a couple of pages, please describe the anticioated plans for LL9W management to be utilized by your plant (s) during the remainder of the operating license and through the license renewal term. What percentage of your antig.lR312d waste (by volume) will be managed by:

A. Waste compaction?

B. Waste segregation (through special controls or segregation at radiation ,

check points)?

C. Decontamination of wastes?

D. Sorting of waste prior to shipment?

E. Other (please identify).

A. We would liksly keep the above mix plus incineration and metal molting. The cost associated with further volume reduction and the availability of disposal will be factors used in evaluating cost efftetive methods for waste management,

5. Do you anticipate the need to acquire adoitional land for storage of LLRW for the operating lifetime of the plant, including a 20-year period of license renewal? If do, how much land? When would this acquisition occur? Where? (if answeris "yes* 3-4 sentences).

l A. Not at the present time, as long as the NRC does l not place substantial restrictions on the use of l

owner controlled land for storage. ,

l

6. To provide information on the timing of future low level waste streams, if you answered yes to Question #5, over what penod of

• time are these activitics contemplated?

Waste fJianagement Questions (cont'd)

7. Do you anticipato any additional ccnstruction activity, on-site, or immediately adjacent to the power plant site, associated with

. temporary LLRW storage for the operating lifetime of the plant, including a 20-year period of license renewal? (yes/ne).

A. Yes. The station will need to expand its capacity to store resin and ft ter wastes. These wastes would be solidified or dewatered in disposal containers and then placed in large concrete shields in a butler style building, in addition, if the station replaces its present steam generators it will require a storage loCition for the old generators.

8. If you answered yes to Question #7, briefly describe this construction activity (e.g., storage areas for steam generator components or other materials exposed to reactor environment).

A. We would build a butler style building, on Indian Point property, for storage of the wet processed wastes. For the old steam generators we would

. build a large concrete shielded building similar to that built by the New York Power Authority for Indian Po!nt 3's Steam Generators.

9. To provide information on future low-level waste streams which may offect workforce levels, exposure, and waste compact planning, do you anticipate any major plant modifications or refurbishment that are likely to generato unusual volumes of low-level radioactive waste prior to, or during, the relicensing period for the plant? If so, please describo these activities. Also, what type of modifications do you anticipate to 'be necessary to achieve licenses renewal operation 91 rough a 20-year license renewel term?

A. o The site is examining the possible use of chemical decontamination of the reactor coolant system. This would generate up to 3500-4000 ft.'

of spent resin and filters. 400 ft' would be Class "C",600 ft* Class *B" and the remainder Class "A".

The project could occur as early as 1993.

. o Steam Generator replacement could occur as early as 1993. No decision has yet been made on replacement.

o RCCA replacement

. - ..- __ . . - . . . - - . . - - = . . . . -. . . - - .- ._ _

l l

Waste Management Questions (cont'd)

C. Mixed Low-level Radioactive Waste Question:

1. If your plant generatos mixed LLRW, how is it current!y being stored and what p!ans do you havo for managing tr.ls during tho .

licenso renewal period? -

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O r

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f I.

SOClOECONOMIC QUESTIONS FOR,, ALL UTILITIES t

+

1. To understand the importanco of the plant and the degreo of its socioeconomic impacts on the local tegion, estimate the number of permanont workers on site for the most rotont year for which data are available.

ANSWER: Con Edison Employees 564; Contractors - 171

, 2i To understand the importance of the plant to the local region, and how that has changed over time, asilmate the average nu;nbor of permanent workers on site, in fivo. year increments starting with the issuanco of the plant's Operating Ucense.

If possible, provido this.information for each unit at a plant site.

ANSWER: '

PERMANENT ON SITE EMPLOYEES ASSIGNED TO INDIAN POINT

~DAIE NUMBER OF CON EDISON NUMBER OF CONTRACTOR -

. EMPLOYEES EMPLOlEER

.10/1/73 425 15

• (Unit #2 on-lino, license).  ;

10/1/77' 358 45  :

10/1/82- 433 85

-10/1/87- 542 144 Present SS4 171  !

l 3.' To understand the potent!al impact of continued operation for an additional 20 years beyond the original licensing torm, please provide for the following throo cases: ,

1:

. A) a typical planned outago; .

B) an ISI outago; and

\ is . C) - the largest-sin 0 l o outage (in-torms of the number of workers r

involved) that has occu' rod to dato I[ an e!,timate of additional workors involved (for the entiro outage and for each l

principal task). longth of outage, months and year in which work occurrod, and lE cost. Also, estimato occupational doses roccived by permanent and temporary -

workers during each principal task.

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1

Socioeconomic Questions (cont'd)

QUTAGE OCCUPATIONAL DO.SEE Man Rem Man-Rem Permanent Temporary MnRm 1018 Personnel Personnel lotal Refueling 10 110 120 A)

Steam Generator 5 115 120 B) 50 60 110 C) Corrective / Preventative Maintenance 40 90 130 D) Ten Year ISI (1984)

Total Outage Dose Outage Costs leat Ipika EAnn-Remi Duration /Date Ml!llQD 1984 A,B,C,D 2400 06/02/84 10/17/84 10.0 1986* A, B, C, 1200 01/13/86-03/12/63 31.5 1987 A,B,C 1180 10/05/87 01/19/88 41.1 1989 A, B, C 1270 03/18/89 47/01/89 56.5 ,

4. To understand the plant's fiscal importance to specific jurisdictions, for 1980, 1985, and the latest year for which data are available, estimate the entire plant's -

taxable astossed value and tne amount of taxes paid to the state and to each local taxing jurisdiction.

ANSWER: Town of Cortlandt 1980 8,943,370 1985 11,109,G18 1989 -14,902,435 Villane of Buchanan 1980 - 889,082 1985 -1,062,883 1989 -1,396,344 The 1990 taxable assessed value is 42,516,000 for the Town of Cortlandt and 36,956,700 for tM Village of Buchannan These taxable assesed values have not changed appreciably in the past 5 years.

'* Largest Outage in Terms of Werkers involved Approximately 3800 Badged Workers

- S_QCJOECONQMIC QUESTIONS FOR CASE STUDY SITES This portion of the questionnairo is designed to gather intermation about the socioeconomic impacts of nuctoar power plants, ll estimatos ero ree'iired, the estimates should be qualified as appropriato, ,

Based on our pilot study, the Socioeconomic questions for caso study sites should take approximately 15 man hours to answer.

i A. Employment and Expenditures j

1. To understand the importance of the plant to local communitics, and how that has changed over timo, provido estimates of total plant expenoitures, by local l i

community, for equipment, materlats, and services used in normal operations for the most recent year data available.

ANSWER: The total plant expenditures for 1989 for equipment, materials and services used in normal l operations was approximately 30 million dollars. l About 5 to 10% of this amount was paid out to i businesses in the four counties surrounding Indian Point (Orange, Rockland, Westchester and Putnam).

2. To understand the possible offect of the plant on the local economy, how do the average salaries paid to plant employees compare to averago salaries for comparable jobs, if they exist, in the local area (e.g., engineers, secretaries, custodial personnel, electronics technicians, maintenance journoymen, food service employees)?

ANSWER: The average salary for , plant employees (Engineeis and Secretaries) is about 15% higher than comparable jobs in the local area. Salaries for electronics technicians and maintenance journeymen are dictated by the Union contract.

Food services and custodial personnel are contracted for.

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,y _ _ _ _ , - _ _ _ . . _ ,

Socioeconomic Questions for Case Study Sites (cont'd)

3. To understand the possible effect of the plant on the local economy, what

. programs has the utility sponsored in the local area to improve employment opportunities, such as hiring policies, job training programs, or industrial -

recruitment.

ANSWER:

o Indian Point has strived to recruit prospective employees from the surrounding area by advertising job ooenings locally.

o On occasion, we have done limited recruiting at the Westchester Community College campus.

o in 1990 we expect to develop a program between local high schools and Westchester Community College, to send selected students through a math / science oriented curricula geared to the potential technical positions which wl3 be available at Indian Point in the future.

4. To understand the importance of the plant to specific jurisdictions near the plant, whet is the current distribution, by city and county or zip code or residence, or permanent workers on site?

ANSWER:

- --- City 7d.E # Of }*0P.3I Lincoln Park 07035 1 williston Park 11596 1 Upper Sadle River 07458 1 Crompound 10517 3 West Nyack ,

10994 1 Warwick 10990 1 Crugers 10521 1 e'ar ringt.on Pa r k 07640 2 New rairfield 06012 1 Cranford 07016 1 Somers 10589 1 Campbell lloll 10916 1 Hastings 10706 1 Pt. Washi gton 11050 1 New York MMthADB) 10019 1 Jamaica states 11423 1 Franklin Lakes 07417 1 ^

spring Valloy 10977 1 Congers 10920 1 Wentwood 07675 1 .

Middle Village 11379 1 Thiells 10984 1 walden 12586 1 Rivetdole 10463 1 L.I. City 11106 1 Paramus 0 7 t,5 2 1

Glenham 12527 2

- Elmsford 10523 1 Dloomingburg 12721 1 12501 2 Stanfordv111e tia r t iman 10926 2 10930 6 liigland Mills Ulutet Poik 12947 1

• 10034 1 Lake Peekskill 10501 1 Amawalk Woodhaven 11321 1 Hutsboro 12790 1 Rosedale 11422 1 Brooklyn 11206 1 11225 1 11234 1 Stony Point 10980 3 Wect Haverstraw 10993 i 12518 9 Cornwall 2 Harriman 10926 Garrison 10524 2 Rock Tavern 12575 1 Pleasant Valley 12569 2 New Milford 06086 1 10536 2 Katonah KeptGardens 11415 1

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Slotuburg 10974 1 12567 2 Pine Plains Purdy Station 1057U 1 Dronx 10472 1 10461 2 Mohegan Lake 10547 2 Dunbury 06810 1 10707 2 Tuckahoe tlArlboro 12542 1 Queenc 11419 1 Mt. Kit;" 10549 . 3 Florida 10921 1 Milton 12547 1 Mt. Pleasant 15666 1 tionuuL 10064 3 '

12528 6 tiighland Falle Accord 12404 1 Ardaley 10502 1 Jersey city 07306 1 Hillsdalc 07642 1 Scarudale 10503 2 Edicon 08820 1

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Washingtonville 10992 5 Drewster 10509 5 Blauvett 10913 1 Rhinebeck 12572 2 Montvalu 01645 1 Manhaccot 11030 1 Little Neck 11362 1

Lagtangeville 12540 7 Suffetn 10901 4

• Mount Kisco 10549 3 Stormville 125B2 4 wallkill 1 25119 7 .

10511 9 Duchanan Peekskill 10566 68 s Yorktown 10598 12 Bolivar 15923 1 llopewell Junction 12533 37 Putnam Valley 10579 9 ned Hook 12571 1 nuacon 12500 22 ~

Wappinger ralls 12590 54 Poughquaq 12570 4 Mahopac 10541 17 Pawling 12771 2 New City 10956 5 Monroe 10950 10 Carmel 10512 10 Brooklyn 11230 1 Croton 10S20 10 Cold Spring 10516 9 Helsonville 10516 2 Yonkers 10703 4 Hudson 12534 1 Newburgh 12550 6 New Windsor 12550 13 Hiddletown 10940 2  ;

Poughkuopcie 12601 A Modena 12548 1 Montgomery 12549 3 rishkill 12524 20 Chester 10918 4 North Tarrytown 10591 1 Hawthorne 10532

• 2 tiighland 12520 4 Montrose 10548 11 Goshen 10924 2 Mount Vernon 10550 1 Oanining 10562 5 Pine Bush 12566 1 New Rochelle 10005 1 Dover Plainc 12522 1 Verplanck 10596 7 Harrison 10528 1 White Plains 10606 3 Sollabury Mills 12577 1 Patterson 07503 1 Lake Shenotock 10507 2 m

l SOClOECONOMIC QUESTIONS FOR CASE STUDY SITES

. B. Taxes I

1. QUESTION: What type of local taxes must be palv on the plant and property?

ANSWER: Real Property Taxes.

2. QUESTION: To what jurisdictions are the taxes pald? i ANSWER: Town of Cortlandt and Village of Buchanan, N.Y.

3. QUESTION: What type of state taxes must be paid on the plant and property?

ANSWER: None.

4. QUESTION: For each tax type, please estimate the total amount the utility paid to each relevant state and local jurisdictions in 1980,1985 and 1989 ol the most recent year for which data are available? l l

ANSWER: Iggn_pf Cortlandt 1980 - 8,943,370 1985 - 11,109,918 1989 - 14,902,435 Villaae of puchanan 1980 - 889,082 1985 - 1,062,883 1989 - 1,396,344

5. QUESTION: Have major plant modifications or refurbishment affected the plant's taxable assessable value?

ANSWER: Yes.

6. QUESTION: Would an extended outage for major plant modifications or refurbishment result in a temporary cessation or reduction of tax payments to stato and/or local governments?

ANSWER: No.

7. QUESTION: Would tax payments cease in the event of plant decommissioning?

- ANSWER: Only on equipment, buildings would continue to be taxable.

l Socioeconomic Questions for Case Study Sites (cont'd) ,

C. Public Services This question is asked to validate information obtained from local government sources or to obtain information if local government fail to provido it.

1)

Pleaso estimate the total annual plant expondituto for each foo paid public service (o.g, water, sewer, etc.) in fivo year intervals sinco plant operations began.

ANSWER 1973 $ 12,675 1974 38,058 1975 50,488 1976 27,992 1977 200,834 1978 287,639 1979 299,621 1980 299,005 1981 399,855 .

1982 1,037,256 1983 954,821 1984 985,318 1985 971,807 1986 908,930 1987 776,466 1988 881,458 1989 851,516 e

AQUAT1G. RESOURCE QUESJ1QMS EdgU.lalory B6ekoround The Atomic Energy Commission (AEC) issued an operating license for Indian Point 2 in 1973 and the station began commercial operation 61974. The license allowed Indian Point Unit No. 2 to operate with once-through cooling unti' May 1, 1979. After that date, a cooling tower was required unless new studies showec' tbc impact of once through cooling was negligible, in 1975, the Nuclear Regulmary Commission (successor to AEC) issued an operating license to Indiar 1 oint Unit No.

3 subject to the same restrictions,i.e. cessation of once through cooling by May 1, 1979.

The requirement for closed cycle cooling (i.e. a cooling tower) was based an AEC crwirotunental impact statement (1972) that concluded that entrainment of striped bass by Indian Point could substantially deplete the lludson River striped bass population and recommended that a closed cycle cooling system be built to reduce water withdrawals from the river. Beginning in 1973, con Edison and other utility companies (Orange and Rockland Utilities, incorporated, and Cental 11udson Gas and Electric Company) operating power plants on the lower and middle zones of the Hudson River funded a research effort to obtain the evidence needed to resolve the entrainment question. The New York Power Authority later joined this effort, in 1975, subsequent to issuance of the operating licenses for Indian Point Units 2 and 3, the US Emironmental Protection Agency (EPA) issued a NPDES permit for Units 1 and 2 and a separate NPDES permit for Unit 3 pursuant to the authorities of the 1972 amendments to the Federal Water Pollution Control Act Amendments of 1972 (FWPCA). The permits would have reo,uired the installation of a closed-cycle cooling system for Indian Point Unit No. 2 by May 1,1979 and for Indian Point Unit No. 3 by September 15,1980. (Unit No. I has not operated since October 1974). In December,1975, the New York Power Authority (NYPA) acquired Indian Point No. 3 from Con Edison. At that time, the permittee's name in the Unit No.1 NPDES permit was changed from Con Edison to NYPA. (NOTE: In 1975, EPA also issued NPDES permits for 2 fossil fuel plants which required the construction and operation of closed-cycle cooling systems: Howline operated by

- Orange and Rockland and jointly owned by Orange and Rockland and Con Edison; and Roseton operated by Centrailludson and jointly owned by Central liudson, Con Edisen and Niagara Mohawk.)

1

All of these closed cycle cooling requirements were imposed because EPA determined that it was the best technology available to minimize what it considered to be unacceptable entrainment impacts on striped bass and other species by these plants pursuant to Section 316(b) of the FWPCA. At that time, EPA also determined that it did not have sufficient information to decide whether or not to grant the ,

utilities' requests for alternative thermal limits (equivalent to existing once through cooling systems) under Section 316(a) of the FWPCA.

He five utility companies affected by the NPDES cooling tower requirements

- Con Edison, NYPA, Orange and Rockland, Niagara Mohawk, and Central Iludson

- contested the permits and asked for adjudicatory hearings on the closed-cycle cooling requirements. The utilities contended that the impact of their existing once '

through cooling systems was not biologically significant, would not result in any material reduction in the fish populations of the liudson River, and did not justify the construction and operation of cooling towers which are expensive and also have adverse erwironmentalimpacts of their own.

The adjudicatory hearings began in 1977 and ended with a 1980 settlement agreement among the utilities, EPA, the NYS Department of Environment.al Conservation (DEC), other government agencies and environmental groups. The settlement became effective in May 1931 and was made part of the SPDES permit DEC issued to Indian Point in 1981. ihis was a single permit, covering discharges from all Indian Point Units. (The Settlement Agreement was also made part of -

SPDES permits issued to other lludson River power plants.) The Settlement Agreement called for continued operation of the plants with once-through cooling ,

systems for a ten year period in return for the cancellation of Con Edison's proposal Cornwall Pumped Storage Plant and other actions by the utilities to reduce the effects of the plants' operations on the lludson River fishery. A copy of the Settlement Agreement is attached (see Exhibit A).

The current Indian Point SPDES permit was issued in 1987 and expires in October 1992. The Settlement Agreement expires in May 1991. Barring a change in state and federal legislation, successive five-yect renewal SPDES permits will be required for the remaining service lives of the liudson River power plants, including Indian Point. Permit conditions could be more or less stringent than at present. New permit applications for the Indian Point plants will be filed in April 1992.

Onnlign No:1: Describe any such madifications and/or operational changes to the bondenser cooling water intake and discharge bystems since the

~

issuance of the Operating License.

BDSp3D10

'the Settlement Agreement called for Con Edison and NYPA to implement certain structural and operational modifications to minimize water intake impacts regarding fish impingement and entrainment.These actions include: scheduled plant outages; installation of dual speed pumps; cooling water flow rate restrictions; installation of Ristroph intake screens equipped with impingement mitigation devices; and operation of a striped bass hatchery.

C9911ngMater Flow Restrictions. A cooling water flow rate schedule was established to minimize river water withdrawals, with consideration given to operating efficiency and the minimization of thermally induced mortality in entrained fish. Flow rates vary seasonally, ranging from full Dow between June 9th and September 30th to 60% of full flow between November 1st and May 15th.

Duni Soeed Pumns. To facilitate achieving the required flow schedule, new dual speed circulating water pumps were installed at Unit 2 in 1984 and varitble speed pumps were installed at Unit 3 in 1985.

~

Elsnt Outage Schedules. Units 2 and 3 combined were required to average 42 unit days off-line each year between May 10 and August 10 during the 10 year agreement period (a total

- of 420 Unit days). The outage requirements generally reflected the prior operating history of the units and were intended to ensure that entrainment impacts did not increase above the historical level.

Fish Protective Screens.The Agreement anticipated that angled intake screens, a promising technology at the time of the Settlement, would be installed, llowever, it provided that other devices could be substituted if tests. then unplenvay elsewhere, suggested that angled screens would not be effective. It was subsequently determined that angled screen effectiveness at an intake as large as those at Indian Points Units 2 and 3 was uncertain and alternative fish protective intake modifications were considered. After field and laboratory testing, modified Ristroph screens were determined to reflect the best available technology for Indian Point. These screens are scheduled to be installed at both units by spring of 1991 (see Exhibit H).

Stripnl Bass llaidiery A striped bass hatchery designed to produce 600,000 three inch striped bass for stocking into the river annually was completed in 1983 and is scheduled to

- operate at least through 1991.

The current SPDES permit reflected modifications to condenser chlorination and service water chlorination practices. This permit change is discussed in Exhibit C.

3 l

.Quentoit N6;2i Sumniadze~ntidfdherits (or:nreside documentation.on any knnithnmicIS gn aquatic resources {c,g. fish _ kills violations of discharce permit conditions) or Natiomil -

l'allulant Dischargt. Elimination System (NPDES) enfon.cipent actionE.llinLhave occurred Eince issuance of the ODirating Licenied.lin'.N.hatC_these been nsalted or changed over timel . .

Response

SPDES permit renewal applications require the a}.plictmt to sammarize any permit violations during the period of the existant permit. The SPDES permit renewal application submitted in September 19'9 eported no violations. The 1986 renewal application reported violations for tb- t from the sewage treatment plant which was used to treat sanitary wastes from ; . Indian Point site. (See Exhibit D). These violations, which are not specific to .ar power plant, were resolved via a Consent Order attached to the current SPDES . , Pursuant to that Consent Order, connections to the mt nicipal sewer system were raata an.1 the discharge of samtary wastewater from Indian Point was terminated in 1989. Pursua it to agreement with local officials whereby discharge to the municipal sewer system was achieved, the radioactive limits on plant sewage discharge are controlled by NRC regulations at 10 CFR Section 20.

Intermittent minor variances from maximum seasonal flow rates established in the -

Settlement Agreement have been experienced. Deviations are largely flows less than those listed in the Settlement Agreement. Flow reductions occur when pumps are turned off to accommodate repairs or to clean debris from intake screens or condenser tubes. They have ,

been reported to DEC and noted to the Settlement parties in annual reports as required.

No concerns have been expressed by any Settlement parties relative to those variances.

Here have been other, periodic incidents i.e., discharge of sewage with elevated concentrations of radioactive material (June 1986); discharge of boron through an outfall other than that specified in the permit but 'dthin, the plant's effluent limits (December, 1987). These have not been repetitive events and do not reflect any trends.

No discharge related fish kills have been observed since Indian Point Units 2 and 3 began operation in 1974 and 1976, respectively. Intake-related fish kills -- i.e. entrainment and impingement -- are summarized in response to Question 5.

From 1972 to 1980,Ind;an Point operated pursuant to a Consent Order entered into with the DEC which required the adjustment of cooling water flows whenever specified daily impingem:nt limits were exceeded. Additionally, from 1972 to 1976 the Consent Order required the operation of an air bubbler system outside the intake screens to divert fish ~

from the screens whenever the water temperature was below 40T. On occasion, flow correctives were required. The Consent Order was superseded by the 1981 Settlement Agreement.

4

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Qttes11on NoF3PProvide si bricLsummarv' of chaDm (1uttLv. hen'theyscurred) to_ the NPDES permit for the nlagt since issuance of the Operatinc License,

. llesponse The 1975 NPDES permit for Units 1 and 2 and Unit 3, set forth thermal criteria, specifying that water temperature at the surface of the receiving river (reuld not be more than 90 F at any point, provided further at least 50 percent of the cross sectional area and/or one-third of the surface width could not be raised more than 4 F or a maximum of 83 F, whichever is less. However, during July through September if the water temperature at the surface of an estuary before the addition of heat was more than 83*F, an increase in temperature not to exceed 1.5 F, at any paint of the estuarine passageway was permitted.

Further, monthly isothermal measurements of the thermal plume were required. The maximum discharge temperature was 96 F.

In August,1980, Con Edison reported on its thermal survey program. The thermal survey program was designed to fulfill regulatory requirements imposed upon Con Edison and PASNY by the United States Nuclear Regulatmv Commission (NRC) through the Environmental Technical Specification Requirements fo the Station, EPA, and the Ww York State Department of Environmental Conservation (NYSDEC). The Report concluded that operation of the Indian Point Generating Station wculd comply with the cross sectional area and surface width constraints of the NYS therrM criwia. The station would also comply with the 90 F thermal criteria for surface temperature vith the exception that the

- 90"F surface temperature limitation might not be met if the rive ambient temperature exceeded 79 F. Furthermore, it recommended that further thermal surveys not be conducted and that existing analytical techniques (and a knowledge of plant operating conditions and available river ambient data) be used to describe thermal plume pstterns.

The thermal criteria and requirements to conduct thermal plume su veys were not included in the 1981 permit. The maximum discharge temperature was r"ised to 110"F from 96 F. A new requirement limiting the number 'of times the daily average discharge temperature could exceed 93.2 F between April 15th and June 30th was impesed. The Settlement Agreement, discussed pr;viously, was attached to the 1981 permit.

Exhibit C contains a d!scussion of changes in the 1987 SPDES permit from the 1981 permit.

Since issuance in 1987, two modifications have been made to the current SPDES permit. First,in April,1989 the permit was modified to annex a December 1988 agreemen:

signed by all parties to the Settlement Agreement providing for the installation of Ristroph screens (see Exhibit B). Secondly, also ia April 1989, the permit was modified to allow the discharge of boron from an additional internal waste stream.

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B DBM5rinnNoUwater Fauality Gnd monatic"blota%@ freintedVt o NPI)ES *nermits; l EnvironmentalTechnical Specifications? site.snecif1s monitoring suglied by federat or state . j

'l laienclss11 Rcawitse The response to question 3 referenced the thermal survey p;ogram that was ccnducted. The thermal survey program was conducted to fulfill regulatory requirements imposed upon Con Edison and PASNY by the United States Nuclear Regulatory Commission (NRC), through the Environmental Technical Specification Requirements for the Station; EPA, through the 1975 NPDES permit; and the New York State Department of En<ironmental Conservation (NYSDEC), through the Section 401_ Water Quality  ;

Certification. Considerable amounts of. data were chtained through twenty (20) field smveys; results were contained in P t9tal of eighteen (18) reports suomitted to both the NRC and the NYSDEC periodicdt during the six years from 1974 to 1980. The conclusions from the August 1980 summary report are contained in Appendix E.

Estuary-wide measurements of temperature, dissolved oxygen, and salinity have been taken since 1973 in conjunction with biological monitoring; prior to 1982, pH and turbidity were also measured. During the 1970's, sampling was done throughout the year bu. . since 1981, riverwide sampling has been largely resuicted to April through early November. A .

summary of trendt in these parameters through 1987 is found the 1986 and 1987 Year Class Report for the Hodson River Estuary Monitoring Program (See Exhibit F). ,

Hudson Riser water temperatures Ductuate in a regular seasonal cycle, between a minimum m 0*C and a maximum of approximately 28-29=C. Thermal discharges from the Indian 1 int stadons have little effect on either the rate of warming in the spring or maximum sununer temperature in the vicinity of Indian Point; however, thermal discharges from Indian Point, Lovett Generating Station, and Bowline Point may all contribute, along with intrusion of marine waters, to a delay in fall' cooling. lxmg-term data indicate that mean temperatures in the middle estuary have increased about 0.5*C since 1951.

Salinky in the Hadson is controlled primarily by freshwater inflow. Salt front position generally fluctuates between Poughkeepsie during exceptionally dry periods and Yonkers during rainy periods. Annual trends follow trent in rainfall.

Dissolved oxygen in the Hudson River fluctuates seasonally, with lowest DO

_(approximately 5 ppm) in the warmest months. DO is lowest in the Yonkers (closest to New York City) and Albany regions, and highest in the middle part of the estuary. Meen weekly dissolved oxygen has not dropped below 4 ppm in any region since 1983, indicative of a trend of reduced sewage inflow to the river.

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No trends in Ph or turbidity have been distinguishable. l Aquatic Biota

- Since the mid-1970's monitoring efforts have concentrated almost exclusively on fish. Three estuary wide sampling programs have been conducted annually to monitor abundance of key fish species, primarily striped bass, white perch, Atlantic tomcod, and American shad. The monitoring studies include an ichthyoplankton  !

I survey conducted from April through June, a beach seine survey conducted from June through November, and an off shore survey conducted from July through November. Other specialized studies have been conducted for particular species, such as bottom trawl surveys for white perch, and bottom trawl and box trap surveys for Atlantic tomcod.

Data have been used to calculate indices of abundance and, wit h information from entrainment and impingement sampling programs (described in response to Question #5), to estimate plant impacts on fish populations. A description of the basic study program and patterns of abundance of species of interest through 1987 appears in the 1987 Year Class Report (see Exhibit F). In contrast to predictions by EPA scientists during the hearings on tbc 1975 NPDES permit that populations of some species might be substantially reduced by entrainment and impingement, notwithstanding operation of the Hudson River power plants since the 1970s, fish populations of interest have either increased in abundance or are fluctuating within j expected ranges. l 4

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OsFstion N6l 5i SshiniarizfM6faddTjiuinheis (or p(ovide 'dodumentation);of organistns entraised andflinpinged}by the"conderiserl cooling water (system sinbejissuancefofJthe OperctingjLicense.: zDescribe"any? seasonal patternsfussociated withfentrainmentiand

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impingement;j How hasjentrainment and impingement changed over time?

Resoonse:

Entrainment Entrainment monitoring at Indian Point was conducted periodically from the early 1970's through 1987. Studies were also conducted to assess the survival rates of entrained zooplankton and ichthyoplankton. Results of studies up to the time of the 1977 adjudicatory hearings were summarized in the 316(a) and 316(b) materials.

Macrozooplankton commonly entrained include Gammarus spp., Neomysis americana, Monoculodec edvrardsi, Leptocheirus plumulosus, and Chaoborus punctipennis.

Microzooplankton primarily consist of copepod nauplii and rotifers. Survival of entrained zooplankton was shown to be high and that fact, coupled with the short generation time of these organisms, indicates that population effects are insignificant. Zooplankton monitoring -

has not been required since 1979.

Ichthyoplankton monitoring continued through 1987. Species composition and .

abundance of entrained ichthyoplankton varies from year to year, but seven taxa consistently comprise the major part of entrained ichthyoplankton (Table I). Studies of the survival of ,

entrained ichthyoplankton were conducted in 19t 5 and 1988. These studies confirmed the earlier work demonstrating that substantial proportions of some species survive entrainment, if the discharge temperature does not exceed lethal limits (see Exhibit G). Representative

- estimates of the numbers ofichthyoplankters entrained and killed are presented in the 1987 entrainment report (see Exhibit H).

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Table I

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Species Composition (%) and Total Number of Ichthyoplankton Collected in Entrainment Samples at Indian Point Generating Units 1985-1987 Taxon M M J282 Bay anchovy 88 3 41.8 80.9 Striped bass 33 16.7 11.6 White perch 1.9 14.5 2.9 American shad <0.1 < 0.1 <0.1 Blueback herring /afewife <0.1 16.5 0.4 Rainbow smelt < 0.1 0.8 03 L Atlantic tomcod 1.7 03 0.4 Others 4.5 93 3.4 Total Number Collected 76,655 161,746 128,120 l.

Imningement i

Impingement monitoring has been conducted since Indian Point Unit 2 began operation in 1974, and Unit 3 in 1976. Monitoring of impinged fish was conducted daily from 1974 through 1980, and on a reduced schedule in accordance with a stratified random l sampling design since 1981. Additional studies hhve been done to estimate collection i efficiency, survival of fish impinged on fine-mesh and Ristroph-type screens, and to in,restigate the potential for various devices to reduce impingement (bubble curtains, pneumatic " poppers", sound pulses, lights).

Seasonal and annual trends in impingement are summarized in annual reports of which the 1988 annual report is representative (see Exhibit I). Monitoring studies have demonstrated a distinct reduction in impingement since 1982, particularly for the most commonly collected taxa, white perch, blueback herring, and bay anchovy. For all three species, the decline in impingement can be attributed, at least partially, to reduced abundance in the immediate vicinity of the Indian Point intakes, although this reduction in

! abundance is not representative of abundance throughout the entire estuanj.

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R!jdictg Response; There have been no substantive changes in monitored water quality or habitat characteristics in the vicinity of the Indian Point Station since the Unit 2 license was issued in 1973 (see response to Question #.n. t Since many of the species of interest at Indian Point are anadromous or migratory over large expanses of the estuary water,or are commonly found over a large range of the Eastern U.S. nnd elsewhere, water quality beyond .the immediate vicinity of the station influences the seasonal abundance of entrainable and impingeable fish. There has been notable improvement in sewage treatment throughout the estuary, resulting in measurable increases in dissolved oxygen below Albany and in the New York City area.

Although there are restrictions on the consumption of many fish and shellfish taken from the Hudson estuary because levels of toxic substances (primarily PCB's and cadmium) exceed FDA tolerance levels, the effects of toxic substances, if any, on the abundance of

- biota is unknown. Changes in toxicant levels through tim: are largely undocumented, but .

levels of certain_ organic toxicants have probably declined.

The distribution of white perch seems to have shifted up tiver and away from the Indian _ Point stations beginning in about 1982 and continuing to the present. This up river shift has resulted in a reduction of about 70% in impingement of that species, which

typically comprises 60% to 70% of total impingement at Indian Point. The cause of the shift is uncertain but may be largely attributable to a proliferation of water chestnut in the

. shallow areas - upriver. The-spread of water chestnut is undoubtedly the result of a prohibition'on the use of herbicides since 1975, it has also been hypothesized that the heated discharge from a small (60 mw) refuse burning generating station built immediately upriver from Indian Point may have caused fish migrating downstream through the Indian

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Point area to move offshore and away from the Indian Point intakes.

Under the terms of the Settlement Agreement, the Hudson River Utilities have operated a striped bass hatchery. Since 1983, an average of 240,000 striped bass of at least three inches in length have been stocked each year (total through 1989,1.6 million fish).

Monitoring suggests these fish have contributed a few percent on average to annualjuvenile recruitment. .

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I Ou6stlihi?No?7.TDEsclribi[(oilr6vid6Ed6cunientati6n f6f)'6ther^rieniby usis7of satsrs affected byc6oling water systems _(elg switnming, boating, annual harvest by co_mmercialfand Fecreational fisheries) and liow these impacts have etianged since issuance of the; Operating License; Enpmtat Fisheries statistics for Hudson River species affected by the Indian Point Station were discussed to the extent they were available through 1975 in the Section 316 materials. (see Question #9). Of those species, only striped bass and American shad have continued to support commercial fisheries of any importance.

The commercial fishery for striped bass and many other fish in the Hudson estuary above the George Washington Bridge was closed in 1976 because PCB levels exceeded FDA guidelines for consumption. In 1984, the FDA revised its guidelines downward to 2 ppm and the closure of the striped bass fishery was extended to all but certain eastern waters of New York's marine district. In 1986, the fishery was closed entirely in response to Atlantic State Marine Fisheries Commission (ASMFC) plans to restore the Chesapeake striped bass stock. The ASMFC has recently moved to allow limited commercial fishing and New York State has proposed a limited commercial fishery in marine waters for the fall of 1990. However, the commercial fishery in the Hudson estuary proper will remain closed, and coastal fishing will be restricted to certain eastern district waters because of PCB levels of fish from these waters. Although there was some decline in PCB levels in fish from the

. late 1970's through the early 1980's, levels have since stabilized and PCB-related commercial fishing restrictions are expected to continue through the foreseeable future. Reduction in fishing has contriHed substantially to an increasing Hudson River stock of striped bass.

Commercial landings of American shad in the New York portion of the Hudson River increased substantial'y after 1976, and have remained relatively stable over a range of about 400,000 to 700,000 pounds. Commercial fishing for shad migrating through coastal water is increasing. No information is avail'able on the recreational shad catch, but it is believed to be limited.

Since 1980, a commercial fishery has developed in the Hudson River for blue crabs.

Although poorly documented, recreational crabbing is believed to have increased substantially in recent years, in spite of health advisories limiting consumption.

Since fishing licenses are not required on the tidal portion of the Hudson, information on recreational fishing within the Hudson estuary is extremely limited. Fishing is probably general and opportunistic. However, fishing for large-mouth and small-mouth bass, mostly well above the Indian Point area, has increased greatly in recent years and numerous tournaments are held each year.

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.Qsilon~NoT8fDderibe other sbbrees of impact (on aquatic resources (e.g., industrial discharges, hther power plants, agricultural runoff) that could contribute to cumulative impacts.LWhat are the relative contributions by percent of these sources, including the contributions due to the power plant, .

toioveralljyater;gualip degradation and losses of aquatic biota?

Itesponse:

The effects of four fossil fueled electric generating stations (Bowline Point, Roscion, Lovett and Danskammer) on the lludson estuary above and below Indian Point were considered during the NPDES permit hearings for the Indian Point Station and the cumulative effects are treated in the 316(b) documents. Changes in the operation of two of these stations, Bowline Point and Roseton, were conditions of the Settlement Agreement (Exhibit A). The impacts of the other Hudson River stations relative to that of Indian Point remain substantially the same as presented in the 316(b) demonstration materials. (see question #9).

• Four relatively large base load station and several small peak load stations on the East River, O Arthur Kill and lower Hudson River may contribute to a limited extent to the cumulative impact on g some of the anadromous and migratory Hudson River species, but the effects have not been quantified. Similarly, one smaller station on the Iludson estuary at Albarn (about 50 miles upriver) may contribute slightly to the effects on a few species. These plants have all been on-line since at least 1977 and most began operation much earlier, so their effects have long been reflected in the biota. More recently (1984), a small (60 MW) refuse burning station began operation immediately upstream from Indian Point. Its effects are minimal. .

At the time the licenses were issued for Indian Point Units 2 and 3 and during the subsequent "

NPDES permit hearings, a large pumped storage plant was planned at Cornwall upstream from the Indian Point station. It was estimated that the impacts of that storage plant would exceed the impacts of the Indian Point Station and the cumulative effect of Indian Point and the Cornwall plant was of concern Under the terms of the Settlement Agreement, plans for the pumped storage p' ant were abandoned.

Several municipalities and institutions withdraw' domestic water from the upper estuary, but the effects are unquantified. New York City operates a drought emergency water pumping station about 10 miles north of Indian Point. It has operated only three times during the 1980's for a total ofless than six months. Its contribution to entrainment and impingement have not been quantified and its future operation is uncertain.

The effects,if any, of point and non-point discharges on lludson River biota have not been quantified (see response to Question #6). Efforts are currently underway through the National I Estuary Program to identify the extent to which water quality impairment in llang Island Sound and the New York /New Jersey Harbors may be impacting fish and other taxa in those waters. Water -

quality impairment is currently viewed as the greatest threat to biota in these water adjacent to the Iludson River.

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4 QisM16n'N679?Pf691delT00pyNy6tir Section 316(a) di4 (b)" demonstration Reportirequired by the Clean:Wat'er- Act(jWhat'Sectionl1316(6)fand;(b), determinations.have, beenLmade by the regulatory authorities?

Ersponse:

The cover page and table of contents from all Section 316(a) and 316(b) demonstrations reports are contained in Exhibit J. In lieu of Section 316(a) and (b) determinations, all interested parties entered into a Settlement Agreement (see Exhibit A).

O A

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