ML070660079

Comment (16) of Stephen J. Bethay, on Behalf of Entergy Nuclear Operations, Inc., on NUREG-1437, Supplement 29, Regarding Generic Environmental Impact Statement for License Renewal of Pilgrim Nuclear Power Station

ML070660079
Person / Time
Site:	Pilgrim
Issue date:	02/27/2007
From:	Bethay S Entergy Nuclear Operations
To:	Lesar M Rulemaking, Directives, and Editing Branch
References
71FR75280 00016, NUREG-1437
Download: ML070660079 (46)

Text

SEn tergy Entergy Nuclear Operations, Inc.Pilgrim Station 600 Rocky Hill Road Plymouth, MA 02360 February 27, 2007 Mr. Michael Lesar Chief, Rules Review a U.S. Nuclear Regulatc Mail Stop T6-D59 Washington, DC 2055

SUBJECT:

1C'40 ý Z/0' '--Stephen J. Bethay Director, Nuclear Assessment Ind Directives Branch ory Commission 15/0001i-i Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station ... -Docket No. 50-293 License No. DPR-35 ---. z z Comments on Draft Generic Environmental Impact Staterrent:

"" NUREG-1437 Supplement 29 Regarding Pilgrim Nuclear"Power Steon -'Entergy letter, License Renewal Application, dated January 25, 2006 (2.06.003)

C-)C/-)

REFERENCE:

Draft Report for Comment NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 29, Regarding Pilgrim Nuclear Power Station, December 2006 LETTER NUMBER: 2.07.017

Dear Sir or Madam:

In the referenced Entergy letter, Entergy Nuclear Operations, Inc. applied for renewal of the Pilgrim Station operating license. NRC TAC NO. MC9669 was assigned to the application.

The referenced draft NUREG was issued in December 2006, after NRC license renewal staff review of the environmental portion of the License Renewal Application.

The NUREG provided the opportunity to submit comments on the NUREG for consideration by the NRC staff by February 28, 2007. Enclosures 1 and 2 of this letter provide Entergy Nuclear Operations, Inc.comments on the referenced draft NUREG.Also, a compact disc, containing the 1990 Southeastern Massachusetts Health Study and other materials related to the study, was included with the copy of this letter that was mailed to Ms.Alicia Williamson, NRC Project Manager. The study and materials were discussed during the NRC Public Meeting held on January 24, 2007 to solicit comments on the draft NUREG.This letter contains no commitments.

Please contact Mr. Bryan Ford, (508) 830-8403, if you have any questions regarding this subject.Sincerely, DWE/dl

Enclosures:

(as stated)cc: see next page 5v~OZ7 (-u Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station Letter Number: 2.07.017 Page 2 cc: with Enclosures Mr. Perry Buckberg Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Alicia Williamson Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Susan L. Uttal, Esq.Office of the General Counsel U.S. Nuclear Regulatory Commission Mail Stop 0-15 D21 Washington, DC 20555-0001 Sheila Slocum Hollis, Esq.Duane Morris LLP 1667 K Street N.W., Suite 700 Washington, DC 20006 cc: without Enclosures Mr. James Kim Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Mr. Jack Strosnider, Director Office of Nuclear Material and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-00001 Mr. Samuel J. Collins, Administrator Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 NRC Resident Inspector Pilgrim Nuclear Power Station Mr. Joseph Rogers Commonwealth of Massachusetts Assistant Attorney General Division Chief, Utilities Division 1 Ashburton Place Boston, MA 02108 Mr. Matthew Brock, Esq.Commonwealth of Massachusetts Assistant Attorney General Environmental Protection Division One Ashburton Place Boston, MA 02108 Diane Curran, Esq.Harmon, Curran, and Eisenberg, L.L.P.1726 M Street N.W., Suite 600 Washington, DC 20036 Molly H. Bartlett, Esq.52 Crooked Lane Duxbury, MA 02332 Mr. Robert Walker, Director Massachusetts Department of Public Health Radiation Control Program Schrafft Center, Suite 1 M2A 529 Main Street Charlestown, MA 02129 Mr. Ken McBride, Director Massachusetts Emergency Management Agency 400 Worchester Road Framingham, MA 01702 Mr. James E. Dyer, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-00001 ENCLOSURE 1 to Letter 2.07.017 (26 pages)Comments on Draft NUREG-1437 Supplement 29 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29 Note: The page number(s) and line number(s) cited in the following listing correspond to the page number(s) and line number(s)as identified in the published hard copy version of draft NUREG-1437 Supplement 29, not the pdf version of the NUREG.# Page Line Number(s)

Comment The sentence "Additional mitigation to minimize the impacts of entrainment and impingement may be justified." should be deleted. In addition to mitigation already being addressed in the last sentence of 1 xxi 17-18 this paragraph (Lines 20-22), with the EPA recognized as the regulating authority, the NRC is not known to have been delegated authority under the Clean Water Act to make recommendations regarding mitigation measures associated with "aquatic matters".The number of homes serviced by electricity from PNPS is grossly understated.

Rather than 13,000 2 1-8 10-11 homes, previous estimates by the electrical system transmission and distribution operator (NSTAR)identified the number to be about 550,000 homes.3 2-1 24 There is no "Boston Edison Company 1974" reference in the Section 2.3 reference.

4 2Plant nominal ground level is 23 ft above MSL. Thus most major structures are situated at or above 23 4 2-1 24-25 f S ft MSL 5 2-1 32 There is no "Boston Edison Company 1974" reference in the Section 2.3 References.

6 2-4 5 The plant is accessed via Power House Road. It is no longer called Edison Access Road.The "nature area" has been closed to the public since shortly after 9/11/2001 but limited use is allowed 7 2-4 12-14 to employees of PNPS. It is no longer referred to as a nature area and the trails, etc. are not currently maintained as a nature area.8 2-7 12 Suggest deleting the space after "MSL".The sentence "Debris and large, impinged organisms are removed from the bar racks using a 9 2-7 18-19 mechanical rake." should be changed to read "Debris and large, impinged organisms are removed from the bar racks using divers." since the mechanical rake is not currently used.I ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29 Line# Page Number(s)

Comment The sentence 'The mixture is used to ensure the total residual chlorine discharge concentration does not exceed a maximum daily concentration of 0.10 parts per million (ppm) and an average monthly 0 2-7 38-40 concentration of 0.5 ppm in the service water discharge." is incorrect.

The Condenser Cooling Water NPDES Permit total residual chlorine limitations are "0.10" maximum daily and "0.1" average monthly.The Plant Service Cooling Water NPDES Permit total residual chlorine limitations are "1.0" maximum daily and "0.5" average monthly.11 2-9 12-14 Suggest changing the sentence "Since the chlorination events ... only one pump." to "Condenser chlorination is usually conducted only when both circulating water pumps are running." Based on the PNPS NPDES Permit and Table 2-2 of the PNPS Draft SEIS, there are no temperature 12 2-10 38 limitations on the service water. Therefore, the sentence 'The permitted change in temperature across the service water is 5 to 10 0 F." is incorrect and should be deleted.13 Comment number not used.Fission products are not "normally" released from the fuel rods. However, on rare occasions, a small 14 2-12 19-20 defect in a fuel rod can occur which allows small amounts of fission products to be released to the reactor coolant.15 2-13 30 The word should be "Thermex", not "thermix".

It is unclear why the High Pressure Coolant Injection System is singled out here. A number of systems 16 2-16 2 could conceivably cause steam leakage outside primary containment that would be monitored by the reactor building vent system.17 2-17 8-10 These 3 lines are an exact repeat from the previous paragraph (lines 2-5).18 2-17 30 Typo -"resuse" should be "reuse".19 2-20 31-32 Entergy has a PILOT (payment in lieu of taxes) arrangement with the Town of Plymouth.20 2-21 3 Suggest deleting the redundant "the" in the sentence "The Entergy-owned property boundary, including 2th the PNPS site and the woodlands tract, is shown in Figure 2-3." 2 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29 Line# Page Number(s)

Comment There are contradictory statements regarding the transmission ROW (right of way) crossing state 2-21 13-14 parks, etc. Page 2-21 (lines 13-14) indicates the ROW is within the Myles Standish State Forest while 21 2-92 16,18-19 Page 2-92 (line 16) indicates the ROW "does not cross any state or federal parks" and lines 18-19 (Page 2-92) has the same wording as Page 2-21 (lines 13-14).22 2-22 30 Suggest changing "and NPDES permit" to "a NPDES permit'.The sentence "Notes: For the majority of outfalls, the pH shall not be greater than or less than 0.5 23 2-23 33 standard units of the influent." is inaccurate.

Only four outfalls have the "0.5" limit while one outfall has no pH limit, and five outfalls have pH values that range from 6.0 to 8.5. Therefore, the majority of the outfalls do not have the "0.5" value.This should also state that PNPS received certification from the Commonwealth of Massachusetts 24 2-21 27-28 Office of Coastal Zone Management (letter dated 7/11/06), instead of only that the certification was filed.25 2-25 1 Suggest changing "100 mg/L" to "1000 mg/L" to accurately reflect the limitations outlined in the PNPS Groundwater Discharge Permit.26 2-25 19 Suggest changing "50.751 (g)" to "50.75(g)(1

)" to accurately reflect the regulatory citation.27 2-26 35 Line 35 needs to be deleted since it is currently an empty space and separates a continuing sentence.28 2-27 14-15 The sentence "Massachusetts was designated as being in "moderate nonattainment" of the 8-hour ozone standard in June 2005." should have a reference.

29 2-27 24-25 Suggest deleting the sentence that starts with "This permit limits..." The emissions cap is not a permit and only limits emissions on a rolling 12 month basis.30 2-28 1-2 Suggest deleting the first sentence that starts with 'Water depths...", and replace with 'Water depths in the vicinity of PNPS are typically 10 ft and up to 120 ft within 5 miles off shore of the site." On Page 2-11 (lines 30-32) it is stated that 'The sediments were described as having relatively low concentrations of the chemical parameters tested polychlorinated biphenyls (PCBs), polycyclic 31 2-30 8-9 aromatic hydrocarbons (PAHs), pesticides, ... ". However, Page 2-30 (lines 8-9) states "PAHs, pesticides, and PCBs were not detected in any sediment sample." These statements appear to contradict each other.3 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29 Line# Page Number(s)

Comment Suggest changing the sentence "However, these tests indicated that sediment from the intake embayment would have a significant impact on the survival of the amphipod (Ampelisca abdita), and the development of the larval stage of the blue mussel (Mytilus edulis)." to "Although unrelated to PNPS operations, these tests indicated that sediment from the intake embayment would have a significant impact on the survival of the amphipod (Ampelisca abdita) and the development of the larval stage of the blue mussel (Mytilus edulis)." The reference "NEFMC 1998" is intended to be either "NEFMC 1998a" or "NEFMC 1998b" based on the references listed in the Section 2.3 References.

The reference "NEFMC 1998" is intended to be either "NEFMC 1998a" or "NEFMC 1998b" based on the references listed in the Section 2.3 References.

35 2-41 28-29 Suggest changing "Cargnelli 1999e" to "Cargnelli, et al. 1999e" since the Section 2.3 references does not list a reference only for Cargnelli 1999e.The wording "approximately several miles" in the sentence "Jones River, located approximately several 6 2-42 32-34 miles north of PNPS, has its headwaters in Pembroke, Kingston, and Plympton before it empties into Plymouth Harbor (Lawton et al. 1990 in ENSR 2000)." should be reworded.

Suggest "approximately" be deleted from this sentence.37 2-43 3 The "McKenzie 1964" reference is not listed in the Section 2.3 References.

The reference "NMFS 2003" is intended to be either "NFMS 2003a" or "NFMS 2003" based on the references listed in the Section 2.3 References.

The reference "Provincetown Center for Coastal Studies 2006" should be changed to "Prescott 2005" to accurately reflect the listing in the Section 2.3 References.

Suggest inserting the wording "due to the breakwater walls providing an ideal habitat" after "grounds" and "therefore" between "habitat" and "cunner" so that the sentence reads "The PNPS area is a cunner 40 2-50 31-33 spawning and nursery grounds due to the breakwater walls providing an ideal habitat; therefore, cunner have a high incidence of entrainment and impingement at PNPS relative to other species (Lawton et al.2000)." This would be a more accurate statement of facts whereas the draft wording could be mis-leading.41 2-54 24 The 'Woods 1982" reference is not listed in the Section 2.3 References.

4 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29# Page Line Number(s)

Comment 42 2-55 22 The reference "Steimle 1999b" should be changed to "Steimle et al. 1999b" as shown in the Section 2.3 References.

Suggest deleting the sentences "Rock gunnel larvae have been collected in the PNPS entrainment 43 2-58 15-17 sampling." and "Juveniles and/or adults have also been observed in the PNPS impingement sampling program." since these are repeats of the previous two sentences.

44 2-58 32 The "Morse 1978" reference is not listed in the Section 2.3 References.

45 The 'Terciero 1995" reference is not listed in the Section 2.3 references.

Moreover the correct spelling ("Terceiro")

appears to be that as identified on Page 2-167 (lines 1-2 and 3-4).46 2-63 18 The "NFSC 1998" reference is not listed in the Section 2.3 References.

The sentence "No life stages of the tautog have ever been observed in the PNPS entrainment sampling." contradicts the sentence (Lines 18 -20) 'Tautog eggs and larvae have been observed in the PNPS entrainment sampling (Normandeau Associates 2006a)." In addition, the sentence"Juveniles and/or adults have been observed in the PNPS impingement sampling program." is a repeat of the sentence (Lines 20- 21)"...tautog have also been periodically collected as part of the PNPS impingement sampling (Normandeau Associates 2006b)." 48 2-66 32 The "Langton and Bowman 1981" reference is not listed in the Section 2.3 References.

49 2-67 39 Suggest changing "Chang et al. 199b" to "Chang et al. 1999b".50 2-67 6 Suggest changing "Chang et al. 199b" to "Chang et al. 1999b".There is no "Hendrickson 2000b" listing in the Section 2.3 References.

Although there are two"Hendrickson 2000" listings in the Section 2.3 references, neither is listed as "2000b".52 2-68 9-21 The comment is fully described in Enclosure 2.The reference "NEFSC 2005" appears to be the source for "Figure 2-7"; however "NEFMC 2006" is listed as the source for "Figure 2-7". Therefore, there appears to be a discrepancy.

54 2-68 23-29 The comment is fully described in Enclosure 2.5 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29 Line# Page Number(s)

Comment 55 2-69 19 Although there are "NEFMC 2006a" and "NEFMC 2006b" listings in the Section 2.3 references, there is no "NEFMC 2006" listing only.56 2-73 4 Although there are "Cadrin 2000a" and "Cadrin 2000b" listings in the Section 2.3 references, there is no"Cadrin 2000" listing only.57 2-73 12 Suggest changing "Cooper et al. 1998" to "Cooper and Chapleau 1998" to accurately reflect the listing in the Section 2.3 References.

58 2-73 21 Suggest changing "Cooper et al. 1998" to "Cooper and Chapleau 1998" to accurately reflect the listing in the Section 2.3 References.

59 2-73 21 There is no "DFO 1997" listing in the Section 2.3 References.

60 2-74 10 Suggest changing "Brodziak et al. 1996" to "Brodziak and Macy 1996" to accurately reflect the listing in the Section 2.3 References.

61 2-74 18 There is no "Cargnelli et al. 1999" listing in the Section 2.3 References.

62 2-74 32 Suggest changing "Hendrickson 2004" to "Hendrickson and Holmes 2004" to accurately reflect the listing in the Section 2.3 References.

63 2-74 34 Suggest changing "Hendrickson 2004" to "Hendrickson and Holmes 2004" to accurately reflect the listing in the Section 2.3 References.

64 2-74 40 Suggest changing "Hendrickson 2004" to "Hendrickson and Holmes 2004" to accurately reflect the listing in the Section 2.3 References.

65 2-76 10 There is no "Anjaru 1964" listing in the Section 2.3 References.

66 2-78 36 There is no "Matthiessen 1984" listing in the Section 2.3 References.

67 2-79 29-30 Suggest changing "Hart et al. 2004" to "Hart and Chute 2004" to accurately reflect the listing in the Section 2.3 References.

68 2-80 39 There is no "NEFSC 2004" listing in the Section 2.3 References.

69 2-80 11 There is no "Hines 1991" listing in the Section 2.3 References.

6 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29 Line# Page Number(s)

Comment 70 2-83 11 "RWQCB 2004" should be changed to "CRWQCB 2004" to accurately reflect "California Regional Water Quality Control Board"."Marine Mammal Protection Act (MMPA) of 1972" should be listed in the Section 2.3 references to be consistent with other regulatory Acts listed in the Section 2.3 References.

The reference "Provincetown Center for Coastal Studies 2006a" should be changed to "Prescott 2005" 72to accurately reflect the listing in the Section 2.3 References.

73 2-3 34The reference "Provincetown Center for Coastal Studies 2006a" should be changed to "Prescott 2005" to accurately reflect the listing in the Section 2.3 References.

The reference "Provincetown Center for Coastal Studies 2006a" should be changed to "Prescott 2005" to accurately reflect the listing in the Section 2.3 References.

The reference "Provincetown Center for Coastal Studies 2006a" should be changed to "Prescott 2005" to accurately reflect the listing in the Section 2.3 References.

The reference "Provincetown Center for Coastal Studies 2006a" should be changed to "Prescott 2005" to accurately reflect the listing in the Section 2.3 References.

77 2-84 25 Although there are "NHESP 2006a" and "NHESP 2006b" listings in the Section 2.3 references, there is no "NHESP 2006" listing only.78 2-85 22 Suggest deleting the comma after "Prescott".

79 2-85 28 Suggest deleting the '"T after "to".80 2-85 32 Suggest changing "Entergy 2006" to "Entergy 2006a" to accurately reflect the source and listing in the Section 2.3 References.

81 2-85 34 Suggest changing "Entergy 2006" to "Entergy 2006a" to accurately reflect the source and listing in the Section 2.3 References.

82 2-87 8 Although there are "NHESP 2006a" and "NHESP 2006b" listings in the. Section 2.3 references, there is no "NHESP 2006" listing only.83 2-87 14 Although there are "NHESP 2006a" and "NHESP 2006b" listings in the Section 2.3 references, there is no "NHESP 2006" listing only.7 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29 Line# Page Number(s)

Comment 84 2-93 34-35 Although there are "FWS 2006a" and "FWS 2006b" listings in the Section 2.3 references, there is no"FWS 2006" listing only.85 2-97 31 Although there are "FWS 2006a" and "FWS 2006b" listings in the Section 2.3 references, there is no"FWS 2006" listing only.86 2-98 3 Although there are "FWS 2006a" and "FWS 2006b" listings in the Section 2.3 references, there is no"FWS 2006" listing only.The "Entergy 2006a" reference at the end of the sentence 'This program includes the collection, 87 2-99 23-25 analysis, and evaluation of data in order to assess the radiological impact of PNPS on the environment and on the general public ..." is incorrect since the PNPS Environmental Report did not contain such as statement.

88 2-100 17 Suggest changing "Entergy 2003" to "Entergy 2003c" to accurately reflect the source and listing shown in the Section 2.3 References.

89 2-108 16, 18,28 Suggest using Town of Plymouth or Plymouth, rather than Plymouth Town.90 2-109 18 Suggest deleting the comma between "Commission" and "2003".91 2-111 11 Suggest using Town of Barnstable or Barnstable, rather than Barnstable Town.92 2-117 18 Suggest changing "Figure 2-12" to "Figure 2-11" to accurately reflect location of minority populations.

Figure 2-12 shows low-income populations only.PNPS (Entergy) should be listed as one of the largest employers.

With over 700 employees, it would be the second largest employer in Plymouth per the numbers listed in this section.94 2-124 3 Entergy has a PILOT (payment in lieu of taxes) arrangement with the Town of Plymouth.95 2-124 23-24 Entergy has a PILOT (payment in lieu of taxes) arrangement with the Town of Plymouth.Entergy has a PILOT (payment in lieu of taxes) arrangement with the Town of Plymouth which was 96 2-124 32-33 signed on March 5, 2002 and became effective for FY 2003, not 2007 as stated. It is NSTAR which has payments of $1 million which begin in 2007, not Entergy. Refer to 2nd paragraph of Section 2.7 in the PNPS Environmental Report.8 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29 Line# Page Number(s)

Comment 97 2-125 25 Suggest changing "Entergy 2006" to "Entergy 2006a" to accurately reflect source and listing in the Section 2.3 References.

98 2-126 37 Suggest changing "Route 3a" to "Route 3A".The "recreation area" has been closed to the public since shortly after 9/11/2001 but limited use is 99 2-128 29 allowed to employees of PNPS. It is no longer referred to as a nature area and the trails, etc. are not currently maintained as a recreation area.The "recreation area" has been closed to the public since shortly after 9/11/2001 but limited use is 100 2-129 5, 9 allowed to employees of PNPS. It is no longer referred to as a nature area and the trails, etc. are not currently maintained as a recreation area.101 2-129 26 Suggest changing "ACE 2006" to "USACE 2006" to accurately reflect the listing in the Section 2.3 References.

102 2-129 30 Suggest changing "ACE 2006" to "USACE 2006" to accurately reflect the listing in the Section 2.3 References.

103 2-134 22-23 The "Cadrin and King 2002" reference is not in the Sections 2.0 -2.2 write-ups.

104 2-134 32 Suggest changing "RWQCB" to "CRWQCB" to accurately reflect "California Regional Water Quality Control Board".105 2-143 15-16 The "Hart 2001" reference is not in the Sections 2.0 -2.2 write-ups.

106 2-143 37 Suggest changing "Hendrickson, L. 2000" to "Hendrickson, L. 2000a" to match write-ups.

107 2-143 40 Suggest changing "Hendrickson, L. 2000" to "Hendrickson, L. 2000b" to match write-ups.

108 2-144 19-20 The "Idoine, J. Undated" reference is not in the Sections 2.0 -2.2 write-ups.

109 2-145 37-38 The "Kocik and Brown 2001" reference is not in the Sections 2.0 -2.2 write-ups.

The "Massachusetts Office of Coastal Zone Management 2006" reference is not in the Sections 2.0 -110 2-150 21-23 22wieus 2.2 write-ups.

111 2-151 8Suggest changing "l1998" to "l1998b" to match write-ups in the Draft SEIS.9 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29 Line# Page Number(s)112 2-155 31-33 The "National Marine Fisheries Services (NMFS) 2006e" reference is not in the Sections 2.0 -2.2 write-ups.

113 2-156 39-41 The "Neilson 1986" reference is not in the Sections 2.0 -2.2 write-ups.

114 2-157 4-6 The "New England Fishery Management Council (NEFMC) 1987" reference is not in the Sections 2.0 -2.2 write-ups.

115 2-157 18-19 The "New England Fishery Management Council (NEFMC) 1999" reference is not in the Sections 2.0 -2.2 write-ups.

The "New England Fishery Management Council (NEFMC) 2003a" reference is not in the Sections 2.0 116 2-157 21-23 -.wieus-2.2 write-ups.

117 2-158 29-31 The "Nuclear Regulatory Commission (NRC) 1996" reference is not in the Sections 2.0 -2.2 write-ups.

118 2-159 1-4 The "Nuclear Regulatory Commission (NRC) 2006" reference is not in the Sections 2.0 -2.2 write-ups.

119 2-160 1-3 The "Olsen and Merriman 1946" reference is not in the Sections 2.0 -2.2 write-ups.

120 2-160 18 Suggest changing "Cadri" to "Cadrin" to reflect accurate spelling.121 2-161 5-6 The "Pava et al. 1997" reference is not in the Sections 2.0 -2.2 write-ups.

122 2-161 11-12 A space should be added between Lines 11 and 12.124 2-161 15-16 A space should be added between Lines 15 and 16.This reference is incorrect.

The referred to document is email correspondence between Jill Brochu at Entergy and Robert Prescott.

It is not available at the location noted. Also Robert Preston is employed 125 2-161 29-31 at the Massachusetts Audubon Society, not the Provincetown Center for Coastal Studies. If the reference is for the fish study which has somehow been included, Robert Prescott is not the author and the date of 1/15/2005 would be incorrect.

126 2-162 5-7 The Reid et al. 1999a reference is a repeat of the reference shown on Lines 17 -19.127 2-162 38-39 Suggest changing "1 986a" to "1986" to accurately reflect the listing in the Section 2.2.5 write-up.10 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29 Line# Page Number(s)

Comment 128 2-163 12-14 The "Salerno et al. 2001" reference is not in the Sections 2.0 -2.2 write-ups.

129 2-166 5-6 The "Stevenson 1936" reference is not in the Sections 2.0 -2.2 write-ups.

130 2-167 18-20 The "Toner 1984b" reference is not in the Sections 2.0 -2.2 write-ups.

131 2-167 33-34 The "Town of Plymouth 2006c" reference is not in the Sections 2.0 -2.2 write-ups.

132 2-170 18-19 A space should be added between Lines 18 and 19.133 2-170 27-29 Suggest adding "1982." to reflect actual year that material was published and to be consistent with how the reference is listed in the Section 2.2 write-up for the Monkfish (pp. 2-54 to 2-55).Regarding "The abundance estimates in 2005 were <50% of the 1995-2004 time series. " This sentence, given without any perspective, may lead to the wrong conclusion about the status of winter 134 4-12 16-17 flounder in Cape Cod Bay. The 2006 estimate of immature winter flounder was the fourth highest over the 12-year monitoring series, indicating that an ample amount of recruitment is occurring, which propagates the population in the vicinity of PNPS.135 4-12 21 Although there are "MRI 2005a" and "MRI 2005b" listings in the Section 4.10 references, there is no"MRI 2005" listing only.136 4-12 25 Although there are "MRI 2005a" and "MRI 2005b" listings in the Section 4.10 references, there is no"MRI 2005" listing only.The 4% entrainment rate mentioned in this line was for stage four larvae only and was considered an 137 4-12 35 artifact of the sampling methodology resulting from the difficulty in obtaining samples within a few feet of the bottom. The overall entrainment rates for the four surveys in 2002 were 1.28%, 0.95%, 0.11%and 0.07% respectively 138 4-12 29 Although there are "MRI 2005a" and "MRI 2005b" listings in the Section 4.10 references, there is no"MRI 2005" listing only.139 4-12 33 Although there are "MRI 2005a" and "MRI 2005b" listings in the Section 4.10 references, there is no 1 4 I "MRI 2005" listing only.140 4-12 38 There is no "MRI 2002" listing in the Section 4.10 References.

I1 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29# Page Line Comment____ Page__ Number(s)141 4-12 40 There is no "MRI 2002" listing in the Section 4.10 References.

142 4-13 2 There is no "MRI 2000" listing in the Section 4.10 References.

143 4-13 5 There is no "MRI 2000" listing in the Section 4.10 References.

144 4-13 5 There is no "MRI 2002" listing in the Section 4.10 References.

145 4-13 12 Although there are "MRI 2005a" and "MRI 2005b" listings in the Section 4.10 references, there is no"MRI 2005" listing only.Regarding

"...Jones River ... the principal spawning ground for smelt in the Plymouth area." Simply because adult and juvenile smelt are found in the vicinity of Plymouth does not mean they were 146 4-13 24-25 spawned in the Jones River. Within approximately 20 nautical miles of PNPS there are about 20 smelt runs which are possible contributors to the smelt frequenting the coastal waters of Plymouth.

This is important because it means the number of smelt that are impinged at PNPS must be measured against a pool of fish that is larger than the smelt population of the Jones River.Regarding "PNPS had reduced the Jones River spawning population by less than 1% ..." This statement is based on the incorrect assumption that Rainbow smelt impinged at PNPS originate only from the Jones River. Smelt are highly mobile, and there is no information to suggest that even a majority of those caught on the screens spawned in the Jones River. Most smelt are impinged in the fall or early winter, after moving to coastal waters where mixing among the spawning populations from various sources has occurred.Regarding

"...significant events..." and "...high entrainment events can contribute a significant percentage of the overall annual entrainment numbers for certain species. " This statement(s) is misleading because -although its obvious that high ichthyoplankton densities in close proximity to the 14, CWIS are expected to increase the annual entrainment numbers -it has not been determined that 148 4-15 19-20, these are "events," or that they are anything more than natural fluctuations, when compared with the 21 long-term data set. Use of the word "significant" is improper because it is in quotes yet it is not used at all in the pertinent section of the referenced Annual Report, and it is not statistically appropriate.

This statement is not a basis for determining a trend or establishing that an impact exists, so its relevance is unclear.12 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29 Line# Page Number(s)

Comment Regarding "Normandeau (2006a) compared recent estimates of the loss of age 3 adults ..." The text referring to Table 4-4 references Normandeau as the source, and discusses the estimated percent loss of adults as if this terminology is used in the 2005 Annual Report referenced.

However, the headers 149 4-21 2-7 (description of data columns) presented in Table 4-4 are quite different from those in the reference document.

One is also incorrect; the Area-Swept survey should be all adult winter flounder (those equal to or longer than 280 mm TL) not just age-3 fish. Please duplicate the entire table as it appeared in the original source, or eliminate the citation altogether.

150 4-21 25 Although there are "MRI 2005a" and "MRI 2005b" listings in the Section 4.10 references, there is no"MRI 2005" listing only.151 4-21 27-28 The comment is fully described in Enclosure 2.152 4-21 28 Although there are "MRI 2005a" and "MRI 2005b" listings in the Section 4.10 references, there is no"MRI 2005" listing only.Figure 4-1 does not represent "the loss of adults from the local stock," it is the "numbers of equivalent 153 4-22 adult winter flounder estimated from entrainment and impingement data at PNPS." It should be made clear that the equivalent adult method yields a hypothetical estimate not an actual measurement.

154 4-23 3 There is no "NEFSC 2003" listing in the Section 4.10 References.

155 4-23 8 Suggest changing "Figures 2-10 and 2-11" to "Figures 2-9 and 2-10" since reference to "Figure 2-11" is incorrect.

156 4-30 17 There is no "Entergy 2006" listing only in the Section 4.10 References.

4-23 42 157 4-24 1-3 This comment is fully described in the Enclosure 2 comments.13 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29 Line# Page Number(s)

Comment Rainbow smelt are schooling, pelagic fish, occupying inshore coastal waters and mid-waters of large lakes (Scott and Crossman 1973; Carlander 1969). They undertake significant migrations during their life history. In spring, typically March-May in New England, rainbow smelt leave coastal waters and travel to freshwater streams to spawn (Scott and Crossman 1973; Carlander 1969). Some individuals may travel up to 1000 km upstream to spawn (Froese and Pauly 1999). After spawning they return to 158 4-29 1-3 coastal waters.Between the Cape Cod Canal and Boston Harbor there are approximately 21 streams and rivers that have been reported to support smelt runs. Since smelt emigrate to coastal waters following the spawning season mixing among populations from these other sources occurs during the summer months. Rainbow smelt are highly mobile, and there is no information to suggest that juveniles and adults impinged at PNPS originate only from the Jones River.4-34 Section Discussion of these alternatives and their possible application at PNPS should be left to the 316(b)159 T 4.1.4 process currently underway.4-38 The NRC is not known to have been delegated authority under the Clean Water Act to make 4-34 recommendations regarding mitigation measures associated with "aquatic matters".

In addition, 316(b)160 thru 4.1.4 is associated with numerical performance standards and does not define "impact".

Mitigation 4-38 measures in the future, if any, will be developed and jointly agreed upon between EPA Region I and I _Entergy as part of the 316(b) compliance process.161 4-38 16 Suggest changing "Figure 2-5" to "Figure 2-6" since "Figure 2-5" shows the intake structure and not the transmission ROW (right of way).162 4-50 4 There is no "MOCZM 2006" listing in the Section 4.10 References.

163 4-51 1 Entergy has a PILOT (payment in lieu of taxes) arrangement with the Town of Plymouth.Entergy has a PILOT (payment in lieu of taxes) arrangement with the Town of Plymouth which was 164 4-51 8 signed on March 5,,2002 and became effective for FY 2003, not 2007 as stated. It is NSTAR which has payments of $1 million which begin in 2007, not Entergy. Refer to 2nd paragraph of Section 2.7 in the PNPS Environmental Report.165 4-51 15-17 NSTAR payments are not payments made by PNPS, but are as the result of deregulation.

14 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29# Page Line Comn# Page Number(s)166 4-51 41 There is no "OCPC 2000" listing in the Section 4.10 References.

The "recreation "area" has been closed to the public since shortly after 9/11/2001 but limited use is 167 4-52 34 allowed to employees of PNPS. It is no longer referred to as a nature area and the trails, etc. are not currently maintained as a recreation area.168 4-54 33 Suggest changing "Figure 2-12" to "Figure 2-11" since "Figure 2-12" shows low-income populations and not minority block groups.169 4-55 7 Suggest changing "percent" to "percentage" to correct a typographical error.170 4-55 19 Suggest changing "Figure 2-13" to "Figure 2-12" since "Figure 2-13" shows facility layout and not low-income block groups.171 4-58 29 There is no "NHESP 2006" listing in the Section 4.10 References.

172 4-58 31 There is no "Entergy 2006" listing only in the Section 4.10 References.

173 4-59 22 There is no "NHESP 2005a" listing only in the Section 4.10 References.

174 4-62 14 There is no "BEIR VII 2005" listing in the Section 4.10 References.

The Entergy references utilized in this discussion are incorrect since these references are associated 175 4-63 1-2 with radiological environmental reports and not radioactive effluent release reports which is a separate report that deals with doses.176 4-63 6 There is no "NRC 2005" listing in the Section 4.10 References.

177 4-65 3 Suggest changing "...in NRC 2006a..." to "...in NRC 2006a)." to correct a typographical error.178 4-66 17 There is no "MPDH 1990" listing in the Section 4.10 References.

179 4-66 26 Suggest changing "Sever 1993" to "Sever et al. 1993" to accurately reflect the listing in the Section 4.10 References.

180 4-66 26 Suggest changing "Hoffman 1992" to "Hoffman et al. 1992" to accurately reflect the listing in the Section 4.10 References.

15 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29 Line# Page Number(s)

Comment The Entergy references utilized in this discussion are incorrect since these references are associated 181 4-67 3 with radiological environmental reports and not radioactive effluent release reports which is a separate report that deals with doses.182 4-67 3 There is no "NRC 2005a" listing in the Section 4.10 References.

The Entergy references utilized in this discussion are incorrect since these references are associated 183 4-67 30 with radiological environmental reports and not radioactive effluent release reports which is a separate report that deals with doses.'184 4-69 2 Suggest deleting "and" between "may" and "as" to correct a typographical error.185 4-70 32 There is no "USACE 2006" listing in the Section 4.10 References.

186 4-77 28-31 The "Entergy Nuclear Operations, Inc. (Entergy).

2000" reference is not in the Section 4.0 write-ups.

187 4-78 4-7 The "Entergy Nuclear Operations, Inc. (Entergy).

2005b" reference is not in the Section 4.0 write-ups.

188 4-78 17 Suggest changing "Entergy Cultural Resources Procedure" to "Environmental Reviews and Evaluations" to accurately reflect the title of the procedure.

189 4-81 27-29 The "National Academy of Sciences (NAS). 1972" reference is not in the Section 4.0 write-ups.

190 4-81 31-34 The "National Academy of Sciences (NAS). 1980" reference is not in the Section 4.0 write-ups.

191 4-91 36-38 The "National Academy of Sciences (NAS). 1990" reference is not in the Section 4.0 write-ups.

192 4-82 7 The "National Environmental Policy Act of 1969" reference is not in the Section 4.0 write-ups.

193 4-82 36-38 The "Natural Heritage and Endangered Species Program (NHESP). 1995a" reference is not in the Section 4.0 write-ups.

194 4-83 37-38 The "Nuclear Regulatory Commission (NRC). 1987" reference is not in the Section 4.0 write-ups.

195 4-84 11-13 The "Nuclear Regulatory Commission (NRC). 1996b" reference is not in the Section 4.0 write-ups.

196 4-84 36-37 The "Nuclear Regulatory Commission (NRC). 2006b" reference is not in the Section 4.0 write-ups.

16 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29 Line# Page Number(s)

Comment 1, Suggest adding a period after "2006c" to correct a typographical error.197 4-85 6 -7 The "Old Colony Planning Council (OCPC). 2000" reference is not in the Section 4.0 write-ups.

The "United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR) 2000" reference is not in the Section 4.0 write-ups.

199 4-86 7-8 The "U.S. Census Bureau (USCB) 1991" reference is not in the Section 4.0 write-ups.

200 4-86 13-14 The "U.S. Census Bureau (USCB) 2001" reference is not in the Section 4.0 write-ups.

201 5-3 32 Suggest deleting "NRC 1996." Footnote on page 5-1 states that all GElS references are to the GElS and Addendum 1.202 5-4 21 Suggest changing "(2006a)" to "(Entergy 2006a)" to reflect the listing in the Section 5.3 References.

203 5-5 6 Suggest changing SAMAs to SAMA.204 5-6 30 Suggest changing "equivalents (person-rem]" to "equivalent man (person-rem)".

All For consistency with the other sections suggest adding 10 CFR 50, 10 CFR 51, 10 CFR 54, 10 CFR 73 and 10 CFR 100 to the Section 5.3 References.

206 8-14 28 Suggest changing "(USEPA 2000b)" to "(EPA 2000b)" to reflect the listing the Section 8.4 References.

207 8-21 18-19 Need a space between Lines 18 and 19.208 8-29 28 Suggest changing "powerbock" to "power block" to correct a typographical error.209 8-29 29 Need a space above Line 29.210 8-30 14 Need a space above Line 30.Suggest changing "MODERATE" for Alternate Greenfield Site column to "SMALL to MODERATE" 211 8-30 18 since Line 11 of Page 8-28 states "SMALL to MODERATE" for siting at PNPS or an Alternate Greenfield Site.212 8-30 19 Need a space above Line 19.17 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29# Page Line Number(s)

Comment 213 8-37 21 Suggest changing "MODERATE" under the impact Column to "SMALL to MODERATE" since Line 8 of 2 8Page 8-36 states "SMALL to MODERATE".

214 8-47 8 Suggest changing "powerbock" to "power block" to correct a typographical error.Suggest changing "MODERATE" under Natural Gas-Fired Generation Alternate Greenfield Site column 215 9-10 17 to "SMALL to MODERATE" since Line 11 of Page 8-28 states "SMALL to MODERATE" for siting at PNPS or an alternate Greenfield site".216 9-10 19 Suggest changing "MODERATE" under the New Nuclear Generation Alternate Greenfield Site column to "SMALL to MODERATE" since Line 8 of Page 8-36 states "SMALL to MODERATE".

Appendix E has three subsections, all labeled Appendix E with no subsection designations.

Two of these subsections use the same numbering scheme (e.g. Section 1.0 on Pages E-22 and E-51). The Appendix E subsections should have unique designators such that two different sections of the report do not have the same designator (e.g. Appendix E Section 1.0).The current DOT registration number is No. 053006 550 0050. It was issued 5/30/2006 and expires 218 E-2 6/30/2007.

13 The current Depredation Permit (#MB831184-0) was effective on 7/1/2006 and expires 6/30/2007.

219 E-3 12 The issue and expiration dates need to be updated for Materials License 49-0078. The current license was issued May 11, 2006 and expires May 31, 2011.The issue and expiration dates need to be updated for South Carolina Radioactive Waste Transport 220 E-4 5 Permit 0007-20-1.

The current permit number is 0007-20-07-X, was issued 12/12/2006 and expires 12/31/2007.

The issue and expiration dates need to be updated for Tennessee Radioactive Waste License-for-221 E-4 11 Delivery T-MA004-L01.

The current license number is T-MA004-L07, was issued 12/5/2006 and expires 12/31/2007.

222 E-15 30 Apparent error "disch temp diff. ranging from 33.8 -48 degrees F ..." The typical temperature difference is 26 -29 degrees F.223 E-15 35 PNPS is not attempting "to offset adverse impacts" by stocking 25,000 winter flounder.

It is a pilot program intended to determine the feasibility of this approach (which could be scaled up as needed).18 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29 Line# Page Number(s)

Comment 224 E-26 9 Typo "1998 MWt" should be 2028 MWt.225 E-28 41 There is no "ENSR 2002" listing in the Section 7.0 References.

226 E-29 30-32 Suggest changing the sentence "Since the chlorination events ...only one pump." to "Condenser chlorination is usually conducted only when both circulating water pumps are running." 227 E-32 11 There is no "BSC Group 1996" listing in the Section 7.0 References.

228 E-32 21-22 There is no "Entergy 2006a" listing in the Section 7.0 References.

229 E-32 22 There is no "AEC 1972" listing in the Section 7.0 References.

230 E-32 24 There is no "Entergy 2006a" listing in the Section 7.0 References.

231 E-32 29 There is no "Entergy 2006a" listing in the Section 7.0 References.

232 E-32 29-30 There is no "NSTAR 2006" listing in the Section 7.0 References.

233 E-32 31 There is no "NSTAR 2006" listing in the Section 7.0 References.

234 E-34 18 Suggest changing the first sentence of the paragraph to read as follows: "Water depths in the vicinity of PNPS are typically 10 ft and up to 120 ft fives miles offshore of the site." 235 E-34 22 There is no "ENSR 2002" listing in the Section 7.0 References.

236 E-34 28 There is no "EG&G 1995" listing in the Section 7.0 References.

237 E-34 28 There is no "ENSR 2002" listing in the Section 7.0 References.

238 E-34 30 There is no "ENSR 2002" listing in the Section 7.0 References.

239 E-34 37 There is no "ENSR 2002" listing in the Section 7.0 References.

240 E-34 40 There is no "ENSR 2002" listing in the Section 7.0 References.

241 E-37 19 Although there are "FWS 2006a" and "FWS 2006b" listings in the Section 7.0 references, there is no"FWS 2006" listing only.19 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29 Line# Page Number(s)

Comment 242 E-37 20 Although there are "FWS 2006a" and "FWS 2006b" listings in the Section 7.0 references, there is no"FWS 2006" listing only.243 E-37 23 Although there are "FWS 2006a" and "FWS 2006b" listings in the Section 7.0 references, there is no"FWS 2006" listing only.244 E-43 20 Suggesting adding the clarification that no sturgeon of any type has ever been observed at PNPS;therefore, there has been no chance of mis-identification.

The "Fish and Wildlife Service (FWS) 2006e" reference is not in the Sections 1.0 -6.0 write-ups 245 E-45 9-11 (Pages E-22 through E-43).The "Mass Audubon 2003" reference is not in the Sections 1.0 -6.0 write-ups (Pages E-22 through E-43).247 E-45 36-39 The "National Marine Fisheries Service (NMFS) 2002" reference is not in the Sections 1.0 -6.0 write-ups (Pages E-22 through E-43).This reference is incorrect.

The referred to document is email correspondence between Jill Brochu at 248 E-47 18-19 Entergy and Robert Prescott.

It is not available at the location noted. Also Robert Preston is employed at the Massachusetts Audubon Society, not the Provincetown Center for Coastal Studies.249 E-51 32 The "Endangered Species Act" should be listed in the Section 9.0 references to be consistent with other regulatory Acts listed in the Section 9.0 References.

250 E-52 38-39 Suggest changing the first sentence of the paragraph to read as follows: "Water depths in the vicinity of PNPS are typically 10 ft and up to 120 ft fives miles offshore of the site." 251 E-57 1 There is no "Lawton et al. 1995" listing in the Section 9.0 References.

The sentence "Debris and large, impinged organisms are removed from the bar racks using a 252 E-57 38-39 mechanical rake." should be changed to read "Debris and large, impinged organisms are removed from the bar racks using divers." since the mechanical rake is not currently used.20 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29 Line# Page Number(s)

Comment The sentence "The mixture is used to ensure the total residual chlorine discharge concentration does not exceed a maximum daily concentration of 0.10 parts per million (ppm) and an average monthly concentration of 0.5 ppm in the service water discharge." is incorrect.

The Condenser Cooling Water NPDES Permit total residual chlorine limitations are "0.10" maximum daily and "0.1" average monthly.The Plant Service Cooling Water NPDES Permit total residual chlorine limitations are "1.0" maximum daily and "0.5" average monthly.254 E-60 33-35 Suggest changing the sentence "Since the chlorination events ...only one pump." to "Condenser chlorination is usually conducted only when both circulating water pumps are running." Based on the PNPS NPDES Permit and Table 2-2, there are no temperature limitations on the service water. Therefore, the sentence "The permitted change in temperature across the service water is 5 to S110F." is incorrect and should be deleted. Also, suggest adding another space to separate the sentence from the next sentence.256 E-63 13 There is no "BSC Group 1996" listing in the Section 9.0 References.

257 E-66 24 Suggest changing "Marine Research, Inc. 2005b" to "MRI 2005b" to be accurate with the listing in the Section 9.0 References.

258 E-66 41 Suggest changing "Marine Research, Inc. 2005b" to "MRI 2005b" to be accurate with the listing in the Section 9.0 References.

259 Comment number not used.The "Clean Water Act" should be listed in the Section 9.0 references to be consistent with other regulatory Acts listed in the Section 9.0 References.

261 E-67 36 There is no "EPA 1994" listing in the Section 9.0 References.

The sentence states "Condenser tubes at PNPS are cleaned by backwashing on a 1 to 2-week interval, 262 E-68 34-35 depending on the degree of bio fouling." is incorrect.

Thermal backwashing is done 4 to 5 times per year. This process was accurately described on Page E-62, 3rd Paragraph, starting at Line 25.263 E-73 19 There is no "NMFS 2005a" listing in the Section 9.0 References.

264 E-80 8 There is no "Steimle et al. 1999d" listing in the Section 9.0 References.

21 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29 Line# Page Number(s)

Comment 265 E-73 38-39 This comment is fully described in the Enclosure 2 comments.266 E-74 1-5 This comment is fully described in the Enclosure 2 comments.267 E-75 36-40 This comment is fully described in the Enclosure 2 comments.268 E-77 33-34 This comment is fully described in the Enclosure 2 comments.269 E-80 35 There is no "NMFS 2005c" listing in the Section 9.0 References.

270 E-81 26 There is no "Shepherd 2000b" listing in the Section 9.0 References.

271 E-81 32 There is no "Deuel 1964" listing in the Section 9.0 References.

272 E-85 8-9 Suggest changing "NOAA 1998a" to "NOAA 1998" to accurately reflect the listing in the Section 9.0 References.

273 E-89 1 Suggest changing "Normandeau 206b" to "Normandeau 2006b" to correct a typographical error.274 E-89 5-10 This comment is fully described in the Enclosure 2 comments.275 E-91 15 There is no "Bowman et al. 2000" listing in the Section 9.0 References.

276 E-98 35 Suggest changing "Pereira 1999" to "Pereira et al. 1999" to accurately reflect the listing in the Section 9.0 References.

277 E-96 37-40 This comment is fully described in the Enclosure 2 comments.278 E-97 35-39 This comment is fully described in the Enclosure 2 comments.279 E-99 24 Suggest changing "Scott 1982a" to "Scott 1982" to accurately reflect the listing in the Section 9.0 references.

280 E-99 8-13 This comment is fully described in the Enclosure 2 comments.281 E-100 22-23 There is no "Burnett et al. 1992" listing in the Section 9.0 References.

22 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29 Line# Page Number(s)

Comment 282 E-101 26 Suggest changing "Cooper et a. 1998" to "Cooper and Chapleau 1998" to accurately reflect the listing in the Section 9.0 References.

The NRC is not known to have been delegated authority under the Clean Water Act to make E-102 Sections recommendations regarding mitigation measures associated with "aquatic matters".

In addition, 316(b)283 E-105 7.0 and is associated with numerical performance standards and does not define "impact".

Mitigation 8.0 measures in the future, if any, will be developed and jointly agreed upon between EPA Region I and Entergy as part of the 316(b) compliance process. Therefore, Section 7.0 should be deleted.284 E-103 37 There is no "Earth Tech 2006a" listing in the Section 9.0 References.

285 E-104 5 There is no "Siemens 2006" listing in the Section 9.0 References.

286 E-104 6 There is no "EPRI 2006" listing in the Section 9.0 References.

287 E-106 1-3 The "Able et al. 1982" reference is not in the Sections 1.0- 8.0 write-ups (Pages E-51 through E-105).The "Burnett et al. 1983" reference is not in the Sections 1.0 -8.0 write-ups 288 E-107 20-22 (Pages E-51 through E-105).289 E-107 24 Suggest changing "2000a" to "2000" to correct a typographical error and so that the reference is consistent with what is shown in the Sections 1.0 -8.0 write-ups (Pages E-51 through E-105).The "Cargnelli et al. 1999f" reference is not in the Sections 1.0 -8.0 write-ups (Pages E-51 through E-105).The "Chang et al. 1999c" reference is not in the Sections 1.0 -8.0 write-ups (Pages E-51 through E-105).292 E-109 38 Suggest changing "1 988a" to "1998" to correct a typographical error so that the reference is consistent with that shown in the Sections 1.0 -8.0 write-ups (Pages E-51 through E-105).293 E-110 1-2 The "Dooley 1978" reference is not in the Sections 1.0 -8.0 write-ups (Pages E-51 through E-105).The "Fahay et al. 1999b" reference is not in the Sections 1.0 -8.0 write-ups (Pages E-51 through E-105).23 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29 Line# Page Number(s)

Comment The "Freeman and Turner 1977" reference is not in the Sections 1.0 -8.0 write-ups (Pages E-51 through E-105).296 E-1 11 1-2 Suggest listing all authors for this reference instead of only "Galya et al. 1997" to be consistent with other sections References.

The "Grimes et al. 1986" reference is not in the Sections 1.0 -8.0 write-ups (Pages E-51 through E-105).The "Hendrickson and Holmes 2004" reference is not in the Sections 1.0 -8.0 write-ups (Pages E-51 through E-105).299 E-1 12 21 Suggest changing "1999a" to "1999" to correct a typographical error and to be consistent with how the reference is shown in the Sections 1.0 -8.0 write-ups (Pages E-51 through E-105).300 E-.112 29-30 The "Kelly and Barker 1961a" reference is not in the Sections 1.0- 8.0 write-ups (Pages E-51 through E-105).The "Kelly and Barker 1961 b" reference is not in the Sections 1.0 -8.0 write-ups (Pages E-51 through E-105).The "Lawton et al. 1984" reference is not in the Sections 1.0 -8.0 write-ups (Pages E-51 through E-105).303 E-114 33-34 The "Marak 1967" reference is not in the Sections 1.0 -8.0 write-ups (Pages E-51 through E-105).304 E-114 36-27 The "Marak 1973" reference is not in the Sections 1.0 -8.0 write-ups (Pages E-51 through E-105).The "Marine Research, Inc. (MRI) 2005a" reference is not in the Sections 1.0 -8.0 write-ups (Pages E-51 through E-105).Suggest inserting

"(MRI)" between "Inc." and "2005b" to correct a typographical error and to be 306 E-1 15 6 consistent with how the reference is shown in Sections 1.0 -8.0 write-ups (Pages E-51 through E-105).The "Marine Research, Inc. (MRI) 2006" reference is not in the Sections 1.0 -8.0 write-ups 307 E-115 11-14____ (Pages E-51 through E-105).24 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29 Line# Page Number(s)

Comment The "Pikanowski et al. 1999" reference is not in the Sections 1.0 -8.0 write-ups (Pages E-51 through E-105).309 E-118 23 Suggest changing "1 999a" to "1999" to correct a typographical error and to be consistent with how the reference is shown in the Sections 1.0- 8.0 write-ups (Pages E-51 through E-105).The "Steimle et al. 1999e" reference is not in the Sections 1.0 -8.0 write-ups (Pages E-51 through E-105).311 G-1 20 Remove":" 312 G-4 6 Suggest changing "(NRC 1997b)" to "(NRC 1997a)".313 G-4 9 Suggest changing "equivalents (person-rem)" to "equivalent man (person-rem)".

314 G-8 25 Suggest inserting

"(Entergy 2006b)" after "was evaluated." 315 G-9 16, 21 Suggest inserting "Exchanger Room" after "Heat".316 G-12 29 Suggest changing "w"to "was".317 G-13 2 Suggest changing "one percent increase" to "two percent increase".

318 G-13 14 There is no "USDA 1998" listing in the Section G.8 references (Pages G-38 through G-40).319 G-16 9 Suggest inserting

"(Entergy 2006b)" after "potential SAMAs." 320 G-16 10 Suggest inserting "components" after "rugged".Suggest deleting the sentence "One block wall included in the list of important faults has a 321 G-16 13-14 conservatively determined capacity of 1.06 g." This information was not included in reference Entergy 2006b and does not belong in this paragraph.

322 Comment number not used.323 G-23 12-14 Suggest deletion of "are completely eliminated" from assumptions statement since it is redundant.

25 ENCLOSURE 1 Comments on Draft NUREG-1437 Supplement 29 Line# Page Number(s)

Comment 324 G-28 25 Suggest adding "benefits and" prior to "costs" since the response to RAI 5.e changed both the benefits estimate and the cost for SAMA 27.325 G-32 23 Suggest changing "$4.5M" to "$4.6M" since $914,000 x 5 = $4,570,000.

The "Nuclear Regulatory Commission (NRC) 2003" reference is not in the Sections G.1 -G.7 write-ups (Pages G-1 through G-38).26 ENCLOSURE 2 to Letter 2.07.017 (16 pages)Comments on Draft NUREG-1437 Supplement 29 ENCLOSURE 2 Comments on Draft NUREG-1437 Supplement 29 2.0 Plant Interaction with the Environment Page 2-68, lines 9-21: This paragraph provides various statements about winter flounder stock and attempts to offer related data from different times and locations, apparently to provide a basis for drawing conclusions about the status of the 'Gulf of Maine stock'. However, much of the information presented is not truly relevant, and it oversimplifies the question of regional winter flounder abundance.

Rather than citing references used to manage fishing limits across the entire Gulf of Maine, it is more appropriate that the report focus on abundance indicators that most closely reflect the status of winter flounder in the area of Cape Cod Bay, for example, the most recent (2006) data from PNPS's annual 'Area Swept' abundance estimates.

The references that rely on commercial landings, and which discuss the degree of 'exploitation' or'overfishing' are biased by factors unrelated to the number of fish present, and may be more reflective of changes in the level of fishing effort or catch restrictions over the time period. There are numerous variables that affect efforts to estimate winter flounder abundance, many of which have not been reliably quantified or standardized.

Those statistics obtained from the fishing industry should be omitted or given less credence than information collected using scientifically approved methods.Page 2-68, lines 23-29: states "... data from the local population

...indicate that the annual abundance estimates of winter flounder in western CCB continue to decline (Figure 2-8)." This sentence implies that the "trends" from the prior paragraph are not matched by the abundance estimates in the vicinity of PNPS. This is an erroneous conclusion for two reasons: 1] it is an incorrect inference from the data in Figure 2-8 (PNPS's annual 'Area Swept' monitoring effort), and 2] it falsely presumes that the information given in the first paragraph constitutes evidence that a 'trend' is present in the Gulf of Maine winter flounder abundance data (see comment above). Simply because the 2005 winter flounder collection numbers were the smallest catch over the time series does not mean there is a declining trend (based on the three previous years).In fact, the number of sub-adult winter flounder collected in the most recent 'Area Swept'survey increased substantially.

The 2006 estimate of immature winter flounder (total length less than 280 mm) was the fourth highest over the 12-year series, indicating that a healthy level of recruitment continues to occur in the vicinity of PNPS (see Figure 1 on the following page). Given that fish populations will often exhibit substantial variations as a natural consequence of environmental factors, the fluctuations observed over the 12-year history of the 'Area Swept' winter flounder abundance monitoring do not constitute a declining trend.I ENCLOSURE 2 Comments on Draft NUREG-1437 Supplement 29 Winter Flounder -- Annual Abundance of 'Sub-adults' Total Length < 280 mm TL (Spring 1995-2006) tokf- , V;+, floo Aoo +t M,0 I fo ~l to *0" 001-5O0000 4 z 0 CL 0 A 400000 300000 a num ercu -tu ui -U'Ul .vut~ o ;un v elr -y- .y lav. m;a.sexual maturity) is an indication of the degree of recruitment.

This provides insight into the ability of the population base to increase, regardless of the potential effects of entrainment.

Impact assessments using adult abundance estimates are complicated by reductions due to fishing mortality.

232 193 569 324 192 362 159 265 136 90 103 279 200000 ]100000 Anni. Estim. in Thousands

='95 '96 '97 '98 '99 '00 '01 '02 '03 '04 '05 '06 YEAR Figure 1: Winter Flounder -Annual Abundance of Sub-adults 2

ENCLOSURE 2 Comments on Draft NUREG-1437 Supplement 29 4.0 Environmental Impacts of Operation Page 4-21, lines 27-28: "...there were several methodological difficulties, which impart a high degree of uncertainty to these estimates." The Larval Transport Studies provide a direct method of measuring

'percent entrainment' of winter flounder at PNPS using larval densities from the plant and from Cape Cod Bay, obtained simultaneously.

The obvious benefit to this approach is that it eliminates the reliance on hypothetical models (and their inherent uncertainties) and instead, uses real time field data collected at the site. The key challenge is to ensure that using a net to sample larvae close to the bottom (larval stages 3 and 4) does not underestimate the actual number of larvae present in the bay. As with many field studies, new techniques were employed to address this difficulty and they were not completely successful.

There was no problem with the stage 3 and 4 larval densities obtained from sampling in the discharge canal, which collects all larval stages with equal efficiency.

To determine'percent entrainment' these values were then divided by the number sampled in the bay.As a result, it was apparent that the few elevated entrainment values for stage 3 and 4 larvae obtained in 2002 and 2004 were due to low numbers of stages 3 and 4 collected in the bay (i.e. under sampling larvae close to the bottom). However, this discrepancy does not cause a high degree of uncertainty and it does not detract from the key conclusion that the amount of winter flounder larvae in northwest Cape Cod Bay entrained by PNPS is estimated (from direct measurement) to be less than 1% of the net larval transport.

Page 4-23, Line 42; Page 4-24, Lines 1-3: states "Based on the decline of the local population, their percentage take of the local population, and the considerable uncertainties in the stock status, the staff's conclusion is that continued operation of PNPS would have a MODERATE impact on the local winter flounder population due to entrainment over the course of the license renewal term." NRC's draft conclusion was apparently based on a comparison between numbers of equivalent adults (EA) and numbers of fish estimated with an area swept trawl study.The equivalent adult methodology is a common screening tool that relies on fixed estimates of egg and larval survival rates to predict how many adults might be expected to result from a particular number of eggs and larvae. Applied to numbers of eggs and larvae entrained by a circulating water system such as at PNPS, the methodology provides one way of understanding the significance of what at first may appear to be large numbers of individual eggs and larvae. Introduced by Horst (1975) the methodology was developed by Goodyear (1978), Saunders (1978), Boreman et al.(1981) and Saila et al. (1997). 'The equivalent adult methodology provides little insight into the long term viability of the affected populations and should be used only to obtain a first approximation of the severity of potential losses." (Goodyear 1978).Unfortunately, determining the survival rate of fish eggs and larvae in the real world is very difficult to do. Rates are very small numbers because most fish eggs and larvae do not survive. They are highly variable from one year to the next if not from day to day, and rarely available for specific populations of fish. As a result, survival rates obtained from the scientific literature are almost always from geographical areas other than the Station being studied and not uncommonly from different species. Small variations in the estimated survival rates result in dramatic changes in the EA values. Recognizing 3

ENCLOSURE 2 Comments on Draft NUREG-1437 Supplement 29 the uncertainty inherent in the EA model, egg and larval rates for winter flounder in the PNPS area for use in the EA model were obtained from three sources and the resulting values averaged (Normandeau 2006).Historically, equivalent adult estimates for winter flounder at PNPS were small particularly when compared with numbers landed by fishermen.

The relatively high EA values in 4 of the 26 years examined (1997, 1998, 2004 and 2005) likely reflect years when natural egg and larval survival rates were relatively high and exceptional numbers of winter flounder eggs and/or larvae survived the early life history stages. PNPS operations did not change during those years in any way that could result in increased entrainment and there is no reason to believe that circulating water patterns in Cape Cod Bay varied in a way that would result in a disproportionate level of entrainment.

As a result of the uncertainties in early life history stage survival rates and the EA values obtained in 1997 and 1998, a three-year larval transport study was completed to directly measure the number of larval winter flounder drifting past PNPS. Field collections of winter flounder were made at a series of stations in Cape Cod Bay as well as in the PNPS discharge.

Bottom and boat mounted acoustic Doppler current profilers were deployed to directly measure water velocity and direction in conjunction with the plankton samples.Significant conclusions of the larval transport study were:* There is a consistent net flow of winter flounder to the south along coastal Cape Cod Bay in the vicinity of PNPS.* A very small amount -less than 0.1% -- of the net volumetric flow of water in Cape Cod Bay passes through PNPS.* The amount of winter flounder larvae in northwest Cape Cod Bay that is entrained by PNPS is conservatively estimated at less than 1% of the net larval transport.

The larval transport study provides the best estimate of entrainment losses at PNPS.Consistent with the empirical transport model used extensively to assess impacts on the Hudson River and other large rivers systems (Boreman et al. 1978, 1981, Boreman and Goodyear 1988) it represents a direct comparison of numbers entrained with numbers available to be entrained.

The methodology does not require the assumptions about survival rates of larvae that are historically difficult if not impossible to measure and are required for the EA model.Winter flounder stock assessment data from the Massachusetts Division of Marine Fisheries indicate that abundance remains at historically low levels south of Cape Cod.The Massachusetts Division of Marine Fisheries Region 4 and 5 data for north of Cape Cod however has ranged from 10 to 35 kg per tow between 1978 and 2004 varying without trend over the time series. NRC noted that the National Marine Fisheries Service Gulf of Maine time series declined in 2003 and 2004 (lines 6-8, page 4-23) the last two years available at the time the document was prepared.

Catch per unit effort increased in 2005 and 2006, thus the time series has also varied without trend from 1979 to 2006 ranging between 2 and 12 fish per tow.4 ENCLOSURE 2 Comments on Draft NUREG-1437 Supplement 29 Additional information currently available also suggests that the winter flounder population in the Cape Cod Bay area is not in a downward trend. Beach seine sampling in Plymouth Harbor completed in conjunction with Entergy's young winter flounder hatchery release program indicate that numbers of young, wild fish remain strong and in fact have increased over the past two years (see Figure 2 below). It is also interesting to note that numbers of young fish collected during the summer do not appear to be correlated with the number of larvae entrained at PNPS the previous spring. This local field data suggest that numbers of winter flounder entrained do not translate into reduced numbers of young fish.Young Of Year Winter Flounder 140 iI100 80-a. 8 E 60 z S40-~20 0 2002 2003 2004 2005 2006 Figure 2: Mean numbers of wild young of year winter flounder collected by 100-ft beach seine in Plymouth Harbor (during the month of July) from 2002-2006.

5 ENCLOSURE 2 Comments on Draft NUREG-1437 Supplement 29 Appendix E Pilgrim Nuclear Power Station Compliance Status and Consultation Correspondence Page E-73, Line 38-39: The DSEIS states "Eggs and larvae of the American plaice dominated entrainment studies at PNPS..." As widely reported in the fisheries literature adult and juvenile American plaice prefer moderately deep water and are found near shore only in colder waters in the northern Gulf of Maine approximately 250 miles north of Pilgrim Nuclear Power Station (PNPS)and on northward to Newfoundland and Greenland (Collette and Klein-MacPhee 2002)."Adults have never been caught in less than 18 m of water in the Gulf of Maine, and their preferred depth off the coast of Maine is 100-119 meters" (Sherman et al. 1993). This is far deeper than the 5 to 10 meter depths near PNPS. This reported distribution is consistent with local collections conducted by the Massachusetts Division of Marine Fisheries as no American plaice were taken in 13 years of their bottom trawl survey in the waters around PNPS (1970 -1982; Lawton et al. 1995). The Division of Marine Fisheries completed 1,322 trawl tows over that period of time using methods and equipment that would have been expected to capture American plaice were they present in the area. Plaice also were only rarely collected in more recent intensive spring bottom trawl sampling around PNPS from 1995 through 2006 and only two individuals were impinged at PNPS in the 27 years between 1980 and 2006 (Normandeau 2006). These data strongly suggest that PNPS is not located within essential fish habitat for adult and juvenile plaice.The DSEIS suggests that American plaice eggs dominate entrainment studies at PNPS.This statement represents a misunderstanding of the PNPS entrainment data. Plaice spawn pelagic eggs primarily between March and May at a time of year when most fish spawn demersal adhesive eggs. They therefore account for a relatively high percentage of fish eggs only at that time of year although small numbers of them are entrained; typical monthly mean densities average less than 3 eggs per 100 m 3 of water. To state that eggs and larvae of the American plaice dominated entrainment studies at PNPS is misleading since such densities are small, particularly when compared to species that produce pelagic eggs at other times of the year.The DSEIS also states that American plaice larvae dominate entrainment studies at PNPS. This is incorrect.

Thirteen species of fish larvae typically account for 95% of the larvae entrained at PNPS on an annual basis and plaice is not included among those species. Monthly mean densities typically range between 0.1 and 2.1 larvae per 100 m 3 of water during months when they occur at all and they occur only during the months of March through August when several years are considered together.

In 2004, for example, they appeared only in April and May.Finally, irrespective of the numbers of American plaice eggs and larvae collected at PNPS, entrainment of American plaice egg and larval life stages represents a mere fraction of those life stages present in the larger pool of plaice distributed throughout the Gulf of Maine and Georges Bank, not from a localized population inside Cape Cod Bay (ENSR 2000). Ichthyoplankton collections from Cape Cod Bay (Scherer 1984) indicate that early stage American plaice eggs are most common at the mouth of the Bay well to the north of PNPS and consistent with their preference for colder, northern waters. For these reasons, it is unlikely that the continued operation of PNPS, including entrainment 6

ENCLOSURE 2 Comments on Draft NUREG-1437 Supplement 29 of American plaice eggs and larvae, will have a 'substantial adverse effect' on the essential fish habitat of this species.Page E-74, Lines 1-5: states "Continued operation of PNPS may also have the potential to affect prey items of various life stages of the American plaice either through entrainment of phytoplankton, zooplankton, or ichthyoplankton, or via impingement of small forage fish species." The National Marine Fisheries Service designates essential fish habitat using 10 minute squares of latitude and longitude.

The size of each block varies with latitude but they are approximately 10 nautical miles on each side or approximately 100 square nautical miles in area. Such large blocks of habitat are of limited consequence in the open ocean but in coastal areas like Plymouth near shore blocks are designated as EFH even though a species preferred habitat is in deep water well removed from shore. That is notably the case for American plaice, which are rarely found in the immediate vicinity of PNPS because their habitat preference is moderately deep water. They utilize relatively shallow water only in the northern Gulf of Maine, Newfoundland and Greenland (Sherman et al. 1993, Collette and Klein-MacPhee 2002). Fisheries studies around PNPS as well as entrainment sampling at the site support these observations.

The diet of the juvenile and adult life stages of American plaice consists of a wide variety of invertebrate taxa, particularly benthic invertebrates including brittle stars, sand dollars, polychaetes, shrimp, and bivalves (Bowman et al. 2000). American plaice are opportunistic feeders -'They prey on practically any bottom-living animals that are small enough for them to devour" (Collette and Klein-MacPhee 2002). Their diet varies and shifts over time in response to relative abundance of prey items and to where they are located. For example, in southern New England they eat large quantities of amphipods, Crangon shrimp, polychaetes, and bivalves while on Georges Bank they consume primarily star fish, brittle stars, and sand dollars (Collette and Klein-MacPhee 2002).They occasionally eat small fish such as sand lance (Pitt 1967) but that does not appear to be an important part of their diet.The primary contributors to the diet of American plaice are not directly affected by impingement at PNPS because many of the invertebrates they prey upon occur on the bottom where they are not subject to impingement.

It is unlikely that they would be indirectly affected by entrainment of planktonic organisms such as phytoplankton and zooplankton that provide food for larger invertebrate prey -studies have shown that these lower trophic level organisms typically survive entrainment.

At PNPS "the combined effects of heat and chlorine had no effect on survival rates" of entrained phytoplankton at temperatures below 17C (Bridges and Anderson 1984). The majority of productivity studies with entrained phytoplankton at PNPS indicated that productivity increased following entrainment (MRI 1978). Studies at other New England power stations indicate that the ability of phytoplankton to carry out photosynthesis is not adversely affected by entrainment (MRI 1980). Zooplankton entrained at PNPS generally showed high survival rates ranging from 95% to 100% at most operating conditions (Bridges and Anderson 1984). Ichthyoplankton have also been widely shown to survive entrainment by circulating water systems at power stations including PNPS (MRI 1978, 1982, Ecological Analysts 1981, EPRI 2000, LMS 2001). In any event, neither entrainment, nor impingement results in the removal of plants and animals from the ecosystem.

Thus, even those plants and animals that do not survive passage through the Station settle to the bottom where they provide food for benthic invertebrates that in turn provide food for American plaice.7 ENCLOSURE 2 Comments on Draft NUREG-1437 Supplement 29 Based upon the information above, continued operation of PNPS will not have a'substantial adverse effect' on the essential fish habitat of the American plaice. Thus, it is erroneous for the DSEIS, in Appendix E, to suggest a potential food web or habitat impact. Plaice frequent deep water well removed from PNPS, their food supply is diverse and unlikely to be affected either directly or indirectly by entrainment or impingement.

Page E-75, Lines 36-40: states "Continued operation of PNPS may also have the potential to affect prey items of juvenile and adult life stages of the Atlantic cod as several prey items of the Atlantic cod (sand lance and herring) have been commonly reported in the impingement and entrainment sampling program at PNPS." The National Marine Fisheries Service designates essential fish habitat using 10 minute squares of latitude and longitude.

The size of each block varies with latitude but they are approximately 10 nautical miles on each side or approximately 100 square nautical miles in area. Such large blocks of habitat are of limited consequence in the open ocean but in coastal areas like Plymouth near shore blocks are designated as EFH even though a species preferred habitat is in deep water well removed from shore. That is notably the case for Atlantic cod. Cod juveniles and adults are typically found in deeper waters further offshore than those around PNPS (Collette and Klein-MacPhee 2002).While young fish are more common in coastal waters they move to deeper waters as they age and mature (Cote et al. 2003). This information is supported by the 13-year trawl survey conducted by the Massachusetts Division of Marine Fisheries from 1970 to 1982 (Lawton et al. 1995); cod were not among the top six taxa accounting for the majority of the catch in 1,322 bottom samples.Regardless, diet of juvenile and adult Atlantic cod has been extensively studied throughout its range and they are known to eat a broad array of taxa (see for example Bowman et al. 2000, Collette and Klein-MacPhee 2002, Link and Garrison 2002). Their diet varies and shifts over seasons and years in response to relative abundance of prey items. For example, "Cod will pursue and gorge on squids anytime they are available." and "Any shellfish a cod encounters that can be swallowed whole is likely to be consumed." (Collette and Klein-MacPhee 2002). Fish, crabs, lobster, shellfish such as scallops, mussels and clams, squid, sea stars, sea urchins, sea cucumbers, and shrimp are readily found in their stomachs.

While fish are most often encountered in their stomachs they feed on a wide variety of species including Atlantic herring, Atlantic mackerel, sand lance, silver hake, redfish, and flounder.The DSEIS states that continued entrainment and impingement of sand lance and herring will have a 'substantial adverse effect' on the essential fish habitat of the Atlantic cod. Sand lance eggs are not entrained at PNPS because they are demersal and adhere to the bottom. Atlantic herring eggs are not entrained at PNPS because they are demersal and adhere to the substrate when spawned. While herring larvae are entrained they originate primarily outside Cape Cod Bay and those entrained originate from a large pool of larvae distributed throughout the Gulf of Maine and Georges Bank and not a localized population (ENSR 2000, Normandeau 2006). Assessment of the potential effects of larval entrainment indicate that equivalent adult losses amount to about 0.007% of the regional spawning stock biomass. While herring are impinged on the PNPS intake screens the annual estimated number averages only 1,179 fish (1980-2004, Normandeau 2006). Sand lance are also occasionally impinged but they are uncommon, an annual average of only 53 fish being recorded over the 1980-2005 time period (Normandeau 2006).8 ENCLOSURE 2 Comments on Draft NUREG-1437 Supplement 29 Fish and invertebrates entrained and impinged on the intake screens at PNPS are not removed from the near shore waters of northwestern Cape Cod Bay. Small organisms that do not survive drift to the bottom where they contribute to the nutrition of local benthic organisms.

Larger animals that may not survive entrainment or impingement are still consumed by scavengers such as crabs, lobsters, and fish; these in turn can be eaten by any cod that stray in the vicinity of PNPS. It is unlikely therefore that the continued operation of PNPS will have a 'substantial adverse effect' on the essential fish habitat of this species.Page E-77, Lines 33-34: states "Continued operation of PNPS may also have the potential to affect prey items of adult mackerel as several of its prey items (small squid and fish eggs) are commonly reported in the impingement and entrainment sampling program at PNPS." Atlantic Mackerel adults are rarely found in the vicinity of PNPS since they are "fish of the open sea" and not "directly dependent either on the coastline or on the bottom in any way at any stage in their lives" (Collette and Klein-MacPhee 2002). Estimated total numbers impinged annually total five individuals over the 1980-2005 time period consistent with their preference for open ocean.The DSEIS suggests that essential fish habitat for adult mackerel will be adversely affected by PNPS because squid and fish eggs are entrained and impinged.

That conclusion is unrealistic because adult Atlantic mackerel consume a wide variety of prey including euphausiid, pandalid, and crangonid shrimp, arrow worms or chaetognaths, pelagic polychaetes, squid, copepods, amphipods, and a variety of fish species (Bowman et al. 2000, Collette and Klein-MacPhee 2002). They are opportunistic feeders -- "Practically all floating animals that are neither too large nor too small regularly serve to nourish mackerel" (Collette and Klein-MacPhee 2002).Squid are impinged at PNPS but the annual number is not large. The estimated annual average number of squid impinged was only 81 animals over the 26-year period from 1980 -2005. Squid spawn year round, grow rapidly, and are short lived (Cadrin 2000).Therefore, the impingement of small numbers of these animals is not expected to impact the food supply for mackerel.

Fish eggs are entrained at PNPS and many of them are expected to survive (MRI 1978, 1982, Ecological Analysts 1981, EPRI 2000, LMS 2001).In any event, neither entrainment nor impingement results in the removal of plants and animals from the ecosystem.

Thus, even those plants and animals that do not survive passage through the PNPS circulating water system remain available as food for other animals that are known to become prey for adult mackerel.Based on the wide geographical range of adult mackerel, their primarily offshore distribution and varied diet, it is unlikely that the continued operation of PNPS will have a'substantial adverse effect' on the essential fish habitat of this species.9 ENCLOSURE 2 Comments on Draft NUREG-1437 Supplement 29 Page E-89, Lines 5-10: states "Continued operation of PNPS may also have the potential to affect prey items of various life stages of the red hake, as several prey items of the red hake (zooplankton, squid, herring, flatfish species, and mackerel) have been commonly reported in the impingement and entrainment sampling program at PNPS." Red hake like Atlantic cod frequent deeper waters further offshore than those around PNPS. This is supported by the 13-year trawl survey conducted by the Massachusetts Division of Marine Fisheries (Lawton et al. 1995). Red hake were not among the top six taxa collected in that study that involved 1,322 bottom tows between 1970 and 1982.Red hake also prefer softer bottoms composed of mud and sand (Collette and Klein-MacPhee 2002) than is prevalent around PNPS.Red hake larvae, juveniles and adults are opportunistic feeders that prey on a wide variety of taxa (Luczkovich and Olla 1983, Bowman et al. 2000). Their prey changes seasonally and throughout their life history (Steimle et al. 1999). Larval red hake prey on copepods and other microcrustaceans, whereas juveniles consume chaetognaths (arrow worms) and small benthic and pelagic crustaceans including amphipods, decapods, mysids, euphausiids, and copepods.

Adult red hake prey on crustaceans, an assortment of fish species such as haddock, silver hake, sand lance and mackerel, and squid (Steimle et al. 1999). The dominance of these prey items changes seasonally, for example "Copepods are important in the fall and winter; arrow worms are eaten in the spring and summer" (Collette and Klein-MacPhee 2002).It is unlikely that red hake would be indirectly affected by entrainment of planktonic organisms such as zooplankton that provide food for larger invertebrate prey and small fish -studies have shown that these lower trophic level organisms typically survive entrainment.

In studies at PNPS zooplankton entrained generally showed high survival rates ranging from 95% to 100% at most operating conditions (Bridges and Anderson 1984). Larger invertebrates like squid are impinged at PNPS but the annual number is not large. The estimated annual average number of squid impinged is only 81 animals over the 26-year period from 1980 -2005. Squid spawn year round, grow rapidly, and are short lived (Cadrin 2000). Therefore the impingement of small numbers of these animals is not expected to impact the food supply for red hake.Atlantic herring eggs are not entrained at PNPS because they are demersal and adhere to the substrate when spawned. While herring larvae are entrained they originate primarily outside Cape Cod Bay and those entrained originate from a large pool of larvae distributed throughout the Gulf of Maine and Georges Bank and not a localized population (ENSR 2000, Normandeau 2006). Assessment of the potential effects of larval entrainment indicate that equivalent adult losses amount to about 0.007% of the regional spawning stock biomass. While herring are impinged on the PNPS intake screens the annual estimated number averages only 1,179 fish (1980- 2004, Normandeau 2006).Atlantic mackerel eggs and larvae are entrained by the circulating water system and juveniles and adult are occasionally impinged on the intake screens at PNPS. Analyses suggest that the number of age-1 fish that might reasonably be expected to result from the numbers of eggs and larvae entrained had they all died are equivalent to 0.2% of the local mackerel landings.

Ichthyoplankton have also been widely shown to survive entrainment by circulating water systems at power stations including PNPS (MRI 1978, 1982, Ecological Analysts 1981, EPRI 2000, LMS 2001). Atlantic mackerel are swift 10 ENCLOSURE 2 Comments on Draft NUREG-1437 Supplement 29 swimmers and they are not often impinged at PNPS. They occurred in samples during only six years from 1980 -2005 with an average of five individuals annually.

In any event, neither entrainment, nor impingement results in the removal of plants and animals from the ecosystem.

Thus, even those plants and animals that do not survive passage through the Station settle to the bottom where they provide food for benthic invertebrates that in turn provide food for red hake.Based on their preference for deeper waters and soft bottom and varied diet it is unlikely that the continued operation of PNPS will have a 'substantial adverse effect' on the essential fish habitat of red hake.Page E-96, Lines 37-40: states "Continued operation of PNPS may also have the potential to affect prey items of adult whiting, as several prey items of the whiting (small fish and squid) have been commonly reported in the impingement and entrainment sampling program at PNPS. Continued PNPS operations may have a substantial adverse effect on EFH for the whiting." Whiting or silver hake are a wide ranging species utilizing the entire water column over the course of the day. They are not among the more abundant species of fish eggs and larvae entrained at PNPS and they appear on the intake screens only sporadically.

Silver hake eggs were collected each year from 1999 to 2006; however, they were one of fourteen species that contributed less than 1% to the annual egg collections during these years. Larvae were collected in 1999 to 2003, 2005, and 2006; however, they were one of thirty-eight species that contributed at most 7% to the annual larvae collections during these years (Normandeau 2006). Numbers of silver hake impinged annually averaged only 35 fish between 1980 and 2006 (Normandeau 2006). These observations are consistent with the reported distribution of the species which includes North American continental shelf waters from North Carolina to Newfoundland (Bigelow and Schroeder 1953) and suggest that silver hake are not in any way localized around PNPS.The DSEIS suggests that whiting essential fish habitat will be adversely affected by PNPS because small fish and squid are entrained and/or impinged.

This is unreasonable because adult and juvenile silver hake prey on a wide variety of taxa including many species of fish such as anchovies, hake, herring, mackerel, menhaden, alewives, sand lance, and silversides.

They also feed on crustaceans and squid (Bowman et al. 2000, Collette and Klein-MacPhee 2002). They are opportunistic feeders and their diet varies with season and location (Lock and Parker 2004).There is no information available on entrainment of small squid at PNPS. Larger juvenile and adult individuals are impinged at PNPS but the annual estimated total is not large. The estimated annual number of squid impinged averaged 81 over the 26-year period from 1980 -2005. Squid spawn year round, grow rapidly, and are short lived (Cadrin 2000) therefore impingement of such a small number of animals is not expected to affect the ability of silver hake to find adequate food. Very small fish are entrained by the circulating water system at PNPS but they have also been widely shown to survive entrainment by circulating water systems at other power stations (Ecological Analysts 1981, EPRI 2000, LMS 2001). Small fish are also impinged on the intake screens at PNPS but many of them have been shown to survive (MRI 1984, Normandeau 2006). In any event, neither entrainment, nor impingement results in the removal of animals from the ecosystem.

Thus, even those animals that do not survive passage through the I1 ENCLOSURE 2 Comments on Draft NUREG-1437 Supplement 29 Station's circulating water system remain available as food for other animals that are known to become prey for adult whiting.Based on their wide geographical range and varied diet and given that prey are not removed as a result of entrainment and impingement it is unlikely that the continued operation of PNPS will have a 'substantial adverse effect' on the essential fish habitat of this species.Page E-97, Lines 35-39: states "Continued operation of PNPS may also have the potential to affect prey items of the windowpane flounder, as one of its prey items (small fish) has been commonly reported in the impingement and entrainment sampling program at PNPS." The DSEIS suggests that windowpane essential fish habitat will be adversely affected by continued operation of PNPS because small fish are entrained and/or impinged.

This is unlikely because windowpane are widely distributed over muddy sediments throughout the Gulf of Maine (Chang et al. 1999) and juveniles and adults are opportunistic feeders.They prey on a wide variety of taxa consisting chiefly on fish but also crustaceans.

They also consume an assortment of other taxa including arrow worms, squids, mollusks, and polychaetes (Bowman et al. 2000).Very small fish are entrained by the circulating water system at PNPS but they have been widely shown to survive entrainment by circulating water systems at other power stations (Ecological Analysts 1981, EPRI 2000, LMS 2001). Small fish are also impinged on the intake screens at PNPS but many of them have been shown to survive (MRI 1984, Normandeau 2006). In any event, neither entrainment nor impingement results in the removal of animals from the ecosystem.

Thus, even those animals that do not survive passage through the Station's circulating water system remain available as food for other animals that are known to become prey for windowpane.

Based on their ubiquitous distribution throughout New England waters and their varied diet and given that prey biomass is not removed as a result of entrainment and impingement it is unlikely that the continued operation of PNPS will have a 'substantial adverse effect' on the essential fish habitat of windowpane.

Page E-99, Lines 8-13: states "Continued operation of PNPS may also have the potential to affect prey items of the winter flounder, as they have been described as omnivores preying on a variety of fish and invertebrate species, many of which have been commonly reported in the impingement and entrainment sampling program at PNPS." Winter flounder is a widely distributed species that is found over a variety of sediment types including mud, sand, cobble, and rocks (Pereira et al. 1999). They are among the more abundant larvae entrain at PNPS and typically occur on the intake screens (mean occurrence of 917 fish from 1980-2004; Normandeau 2006).Winter flounder are opportunistic feeders that prey on a wide variety of taxa. Larvae feed on abundant forms of phytoplankton and zooplankton such as diatoms, rotifers, dinoflagellates, and copepods (Pearcy 1962, Klein-MacPhee 1978, MRI 1979, 1983).Juveniles are "euryphagus";

27 organisms representing 7 phyla having been identified in their stomachs by Pearcy 1962 (see also Klein-MacPhee 1978). Adult winter flounder are described as omnivorous "eating whatever is available" (Klein-MacPhee 1978).12 ENCLOSURE 2 Comments on Draft NUREG-1437 Supplement 29 Chief prey items include polychaete worms, anthozoans, isopods and amphipod shrimp.They also prey on small crabs, squid, bivalves and other taxa small enough to be consumed with their small mouth (Bowman et al. 2000). MacPhee (1969) reported that the most important category of food in a winter flounder's diet depends on the type of bottom on which a fish resides.The DSEIS suggests that winter flounder essential fish habitat will be adversely affected by continued operation of PNPS because a variety of fish and invertebrate species are entrained and/or impinged.

This is unreasonable because all life stages of winter flounder are opportunistic feeders that prey on a wide variety of taxa. It is unlikely that flounder would be directly or indirectly affected by entrainment of planktonic organisms such as phytoplankton and zooplankton

-studies have shown that these lower trophic level organisms typically survive entrainment.

Zooplankton entrained at PNPS generally showed high survival rates ranging from 95% to 100% at most operating conditions (Bridges and Anderson 1984). Very small fish are entrained by the circulating water system at PNPS but they have been widely shown to survive entrainment by circulating water systems at other power stations (Ecological Analysts 1981, EPRI 2000, LMS 2001). Small fish are also impinged on the intake screens at PNPS but many of them have been shown to survive (MRI 1984, Normandeau 2006). In any event, neither entrainment nor impingement results in the removal of animals from the ecosystem.

Thus, even those animals that do not survive passage through the PNPS circulating water system remain available as food for flounder as well as other animals that are known to become prey for winter flounder.Based on their wide geographic range and varied diet and given that prey are not removed as a result of entrainment and impingement it is unlikely that the continued operation of PNPS will have a 'substantial adverse effect' on the essential fish habitat of this species.References Cited in the Comments: Bigelow, H.B., and W.C. Schroeder.

1953. Fishes of the Gulf of Maine. Fish. Bull., U.S.53: 1-577.Boreman, J., C.P. Goodyear, and S.W. Christensen.

1978. An empirical transport model for evaluating entrainment of Aquatic organisms by power plants. U.S.Fish and Wildlife Service. FWS/OBS-78/90.

Boreman, J., and C.P. Goodyear.

1988. Estiamtes of entrainment mortality for striped bass and other fish species inhabiting the Hudson River Estuary.American Fisheries Society Monograph 4:152-160.

Boreman, J., C.P. Goodyear, and S.W. Christensen.

1981. An empirical methodology for estimating entrainment losses at power plants sited on estuaries.

Trans. Am. Fish. Soc. 110:253-260.

Bowman, R.E., C.E. Stillwell, W.L. Michaels, and M.D. Grosslein.

2000. Food of Northwest Atlantic fishes and two common species of squid. NOAA Tech.Memo. NMFS-F / NE-155, 138 pp.13 ENCLOSURE 2 Comments on Draft NUREG-1437 Supplement 29 Bridges, W.L. and R.D. Anderson 1984. A brief summary of Pilgrim Nuclear Power Plant effect upon the marine aquatic environment.

In J.D. Davis and D.Merriman eds. Observations on the ecology and biology of western Cape Cod Bay, Massachusetts.

p. 263-271. Lecture notes on Coastal and Estuarine Studies 11. Springer-Verlag, NY.Cadrin S.X. 2000. Status of Fishery Resources off the Northeastern United States -longfin inshore squid. Available at ttp://www.nefsc.noaa.gov/sos/spsyn/iv/lfsquid/.

Carlander, K.D. 1969. Handbook of Freshwater Fishery Biology. Volume One. The Iowa State University Press, Ames, Iowa. 752p.Chang, S., P.L. Berrien, D.L. Johnson, and W.W. Morse. 1999. Essential Fish Habitat Source Document:

Windowpane, Scophthalmus aquosus, life history and habitat characteristics.

NOAA Technical Memorandum NMFS-NE-1 37.National Oceanic and Atmospheric Administration, National Marine Fisheries Service, Northeast Fisheries Science Center.Collette, B.B. and G.K. Klein-MacPhee, Eds. 2002. Bigelow and Schroeder's Fishes of the Gulf Of Maine, 3 rd edition. Smithsonian Institution Press, 748 pp.Cote, D., L.M.N. Ollerhead, D.A. Scruton,and R.S. McKinley.

2003. Microhabitat use of juvenile Atlantic cod in a coastal area of Newfoundland determined by 2D telemetry.

Mar. Ecol. Prog. Ser. 265:227-234.

Ecological Analysts, Inc. 1981. Entrainment survival studies. Research Report EP 9-11. Submitted to Empire State Electric Energy Research Corporation, New York.ENSR Corporation.

2000. 316 Demonstration Report -Pilgrim Nuclear Power Station.Prepared for Entergy Nuclear Generation Company. Doc. No. 0970-021-200.

EPRI (Electric Power Research Institute).

2000. Review of Entrainment Survival Studies: 1970-2000.

Froese, R. and D. Pauly. 1999. Fishbase.

World Wide Web electronic publication.

http://www.fishbase.org.

Goodyear, C.P. 1978. Entrainment impact estimates using the equivalent adult approach.

U.S. Fish and Wildlife Service, Biological Service Project. FWS/OBS-78/65. 14p.Horst, T.J. 1975. The assessment of impact due to entrainment of ichthyoplankton.

In S.B. Saila, ed. Fisheries and energy production:

a symposium.

p. 107-118.Heath, Lexington, Massachusetts.

Klein-MacPhee, G. 1978. Synopsis of biological data for the winter flounder, Pseudopleuronectes americanus (Walbaum).

NOAA Tech. Rept. Circ. No. 414.Lawton, R.P., B.C. Kelly, V.J. Malkoski, and J. Chisholm.

1995. Annual report on monitoring to assess impact of the Pilgrim Nuclear Power Station on selected finfish populations in western Cape Cod Bay. Project Report No. 58 (January-14 ENCLOSURE 2 Comments on Draft NUREG-1437 Supplement 29 December 1994). IIIA.i-77.

In: Marine Ecology Studies Related to Operation of Pilgrim Station, Semi-annual report No.45. Boston Edison Company.Link, J.S. and L.P. Garrison.

2002. Trophic ecology of Atlantic cod Gadus morhus on the northeast US continental shelf. Mar. Ecol. Prog. Ser. 227: 109-123.LMS (Lawler, Matusky, and Skelly). 2001. Brayton Point Station entrainment survival study 1997-1998.

Prepared for PG&E National Energy Group. September 2001.Lock, M.C. and D.B. Packer. 2004. Essential Fish Habitat Source Document:

Silver hake, Merluccius bilinearis, life history and habitat characteristics.

NOAA Technical Memorandum NMFS-NE-1

86. National Oceanic and Atmospheric Administration, National Marine Fisheries Service, Northeast Fisheries Science Center.Luczkovich, J.J. and B.L. Olla. 1983. Feeding behavior, prey consumption, and growth of juvenile red hake. Trans. Am. Fish. Soc. 112: 629-637.MacPhee, G.K. 1969. Feeding habits of the winter flounder, Pseudopleuronectes americanus (Walbaum), as shown by stomach content analysis.

M.A. Thesis, Boston University, Boston. 66pp.MRI (Marine Research, Inc). 1978. Entrainment investigations and Plymouth Bay phytoplankton, zooplankton and Chondrus spore studies August 1973 -December 1975. In Marine Ecology Studies Related to Operation of Pilgrim Station, Finall Report July 1969 -December 1977. Vol. 2. Submitted to Boston Edison Company.MRI (Marine Research, Inc). 1979. Environmental impacts of Brayton Point Electric Generating Station on Mount Hope Bay: A five part study. Submitted to New England Power Company.MRI (Marine Research, Inc). 1980. Brayton Point Generating Station Mount Hope Bay Somerset, Massachusetts.

Section 316(b) Demonstration.

Submitted to New England Power Company.MRI (Marine Research, Inc). 1982. Supplementary winter flounder egg studies conducted at Pilgrim Nuclear Power Station, March-May 1982. Submitted to Boston Edison Company. 4p.MRI (Marine Research, Inc). 1983. The prediction of abundance of larval winter flounder (Pseudopleuronectes americanus), Atlantic menhaden (Brevoortia tyrannus), and bay anchovy (Anchoa mitchilli) from prey densities in Mount Hope Bay. Submitted to New England Power Company.MRI (Marine Research, Inc). 1984. Assessment of finfish survival at Pilgrim Nuclear Power Station. Final Report 1980 -1983. Submitted to Boston Edison Company.Normandeau.

2006. Impingement of organisms on the intake screens at Pilgrim Nuclear Power Station January-December 2005. In Marine Ecology Studies Related to Operation of Pilgrim Station, Annual Report No. 67. Entergy Nuclear Generation Company.15 ENCLOSURE 2 Comments on Draft NUREG-1437 Supplement 29 Pearcy, W.C. 1962. Ecology of an estuarine population of winter flounder, Pseudopleuronectes americanus (Walbaum).

Bull. Bingham Oceanogr.

Coll.18(1 ):1-78.Pereira, J.J., R. Goldberg, J.J. Ziskowski, P.L. Berrien, W.W. Morse, and D.L. Johnson.1999. Essential Fish Habitat Source Document:

Winter flounder, Pseudopleuronectes americanus, life history and habitat characteristics.

NOAA Technical Memorandum NMFS-NE-138.

National Oceanic and Atmospheric Administration, National Marine Fisheries Service, Northeast Fisheries Science Center.Pitt, T.K. 1967. Diurnal variation in the catches of American plaice, Hippoglossoides platessoides (Fabr.) from Grand Bank. ICNAF Res. Bull. 4:53-58.Saila, S.B., E. Lorda, J.D. Miller, R.A. Sher, and W.H. Howell. 1997. Equivalent adult estimates for losses of fish eggs, larvae, and juveniles at Seabrook Station with use of fuzzy logic to represent parametric uncertainty.

North American Journal of Fisheries Management 17:811-825.

Saunders, W.P., Jr. 1978. A simple model for assessing the potential loss of adult fish resulting from ichthyoplantkon entrainment.

In J.H. Thorp and J.W. Gibbons, eds.Energy and environment stress in aquatic systems. p. 49-56. U.S. Department of Energy, Technical Information Center, Washington D.C.Scherer, M.D. 1984. The ichthyoplankton of Cape Cod Bay. In J.D. Davis and D.Merriman eds. Observations on the ecology and biology of western Cape Cod Bay, Massachusetts.

p. 151-190. Lecture notes on Coastal and Estuarine Studies 11.Springer-Verlag, NY.Scott, W.B. and E.J. Crossman.

1973. Freshwater fishes of Canada. Fisheries Research Board of Canada. Bulletin 184. 966p.Sherman S. R. Langton, D. Schick, M. Brown, J. Burnett, and F. Almeida. 1993.Distribution and abundance of groundfish along the coast of Maine, USA. J. Fish.Biol. 43 (Suppl. A): 334.Steimle, F.W., W.W. Morse, P.L. Berrien, and D.L. Johnson. 1999. Essential Fish Habitat Source Document:

Red hake, Urophycis chuss, life history and habitat characteristics.

NOAA Technical Memorandum NMFS-NE-133.

National Oceanic and Atmospheric Administration, National Marine Fisheries Service, Northeast Fisheries Science Center.16