ML022240048

R. E. Ginna Nuclear Power Plant Application for Renewed Operating License, Volume 3, Chapter 5, Page 5-1 - Attachments, List of Oversized Drawings

ML022240048
Person / Time
Site:	Ginna
Issue date:	07/30/2002
From:	Mecredy R Rochester Gas & Electric Corp
To:	Jack Cushing Document Control Desk, Office of Nuclear Reactor Regulation
References
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Download: ML022240048 (166)

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R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 5 Appendix E - Environmental Report 5.0 ASSESSMENT OF NEW AND SIGNIFICANT INFORMATION NRC "The environmental report must contain any new and significant information regarding the environmental impacts of license renewal of which the applicant is aware." 10'CF#R 5'153(c-')(3)(iv)

The U.S. Nuclear Regulatory Commission (NRC) licenses the operation of domestic nuclear power plants and provides for license renewal, requiring an application that includes an environmental report (ER) (10 CFR 54.23). NRC regulations at 10 CFR 51 prescribe the ER content and identify the specific analyses the applicant must perform. In an effort to perform the environmental review efficiently and effectively, the NRC has resolved most of the environmental issues generically, but requires an applicant's analysis of all the remaining applicable issues.

While NRC regulations do not require an applicant's ER to contain analyses of the impacts of those environmental issues that have been generically resolved [10 CFR 51.53(c)(3)(i)], the regulations do require that an applicant identify any new and significant information of which the applicant is aware [10 CFR 51.53(c)(3)(iv)]. The purpose of this requirement is to alert the NRC staff to such information so that the staff can determine whether to seek the NRC's approval to waive or suspend application of the Rule with respect to the affected generic analysis. The NRC has

_._ explicitly indicated, however, that an applicant is not required to perform a site specific validation of its Generic EnvironmentalImpact Statement for License Renewal of Nuclear Plants (GELS) conclusions (Ref. 5.1-1, page C9-13, Concern Number NEP.01 5).

Rochester Gas and Electric Corporation (RG&E) assumes new and significant information would be the following:

" Information that identifies a significant environmental issue that the GElS does not cover and is not codified in the regulation, or

"* Information that the GElS analyses did not cover and that leads to an impact finding different from that codified in the regulation.

The NRC does not define the term "significant." For the purpose of its review, RG&E used guidance available in Council on Environmental Quality (CEQ) regulations.

The National Environmental Policy Act (NEPA) authorizes the CEQ to establish implementing regulations for federal agency use. The NRC requires license renewal applicants to provide the NRC with input, in the form of an ER, that the NRC will use to meet NEPA requirements as they apply to license renewal (10 CFR 51.10). CEQ guidance provides that federal agencies should prepare environmental impact statements for actions that would significantly affect the environment (40 CFR 1502.3), to focus on significant environmental issues (40 CFR 1502.1), and to eliminate from detailed study issues that are not significant [40 CFR 1501.7(a)(3)].

The CEQ guidance includes a lengthy definition of "significantly," which requires consideration of the context of the action and the intensity or severity of the impact(s)

(40 CFR 1508.27). RG&E assumed that moderate or large impacts, as the NRC Page 5-1

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 5 Appendix E - Environmental Report defines, would be "significant." Section 4.1.2 presents the NRC definitions of "moderate" and "large" impacts.

RG&E is aware of no new and significant information regarding the environmental impacts of R.E. Ginna Nuclear Power Plant (Ginna Station) license renewal.

Page 5-2

R.E. Ginna Nuclear Power Plant Applicatioh for Renewed Operating License Chapter 5 Appendix E - Environmental Report 5.1 References Ref. 5.1-1 U.S. Nuclear Regulatory Commission. Public Comments on the Proposed 10 CFR Part 51 Rule for Renewal of Nuclear PowerPlant OperatingLicenses and Supporting Documents: Review of Concernsand NRC Staff Response. NUREG-1 529. Office of Nuclear Regulatory Research. Washington, D.C. May 1996.

Page 5-3

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 6 Appendix E - Environmental Report 6.0

SUMMARY

OF LICENSE RENEWAL IMPACTS AND MITIGATING ACTIONS 6.1 License Renewal Impacts Rochester Gas and Electric Corporation (RG&E) has reviewed the environmental impacts associated with renewing the R.E. Ginna Nuclear Power Plant (Ginna Station) operating license and has concluded that all of the impacts would be small and would not require mitigation. This environmental report documents RG&E's bases for its conclusion. Section 4.1.1 incorporates by reference U.S. Nuclear Regulatory Commission (NRC) findings for the 50 Category 1 issues that apply to Ginna Station, all of which have impacts that are SMALL (see Appendix A).

Subsections 4.2 through 4.15 of Chapter 4 analyze the 16 Category 2 issues that apply to Ginna Station, most of which have impacts that would be SMALL or non existent due to the lack of refurbishment activities associated with Ginna Station license renewal. Section 4.16 discusses the basis for inclusion and appropriate depth of an environmental justice analysis, summarizing that there are no disproportionately high and adverse human health or environmental effects since impacts from all Category 1 and Category 2 issues applicable to Ginna Station are SMALL. Table 6.1-1 summarizes the impacts that Ginna Station license renewal would have on resources associated with Category 2 issues and environmental justice.

Page 6-1

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 6 Appendix E - Environmental Report Table 6.1-1 Environmental Impacts Related to License Renewal at Ginna Station No. issuea Environmental Impact Surface Water Quality, Hydrology, and Use (for all plants) 13 Water use conflicts (plants NONE. The issue is not applicable because Ginna Station is not with cooling ponds or equipped with cooling ponds or cooling towers.

cooling towers using makeup water from a small river with low flow)

Aquatic Ecology (for all plants with once-through and cooling pond heat dissipation systems) 25 Entrainment of fish and SMALL. RG&E has a current SPDES permit that constitutes shellfish in early life stages compliance with CWA Section 316(b) requirements to provide best available technology to minimize entrainment.

26 Impingement of fish and SMALL. RG&E has a current SPDES permit that constitutes shellfish compliance with CWA Section 316(b) requirements to provide best available technology to minimize impingement.

27 Heat shock SMALL. Ginna Station has an approved CWA Section 316(a) variance that allows for a 320-acre mixing zone in Lake Ontario from the point of discharge.

Groundwater Use and Quality 33 Groundwater use conflicts NONE. The issue is not applicable because Ginna Station is not (potable and service water, a direct user of groundwater (no dewatering; potable and service and dewatering; plants that water are from municipal supply).

use more than 100 gpm) 34 Groundwater use conflicts NONE. The issue is not applicable because Ginna Station is not (plants using cooling towers equipped with cooling towers.

withdrawing makeup water from a small river) 35 Groundwater use conflicts NONE. The issue is not applicable because Ginna Station does (Ranney wells) not use Ranney wells.

39 Groundwater quality NONE. The issue is not applicable because Ginna Station is not degradation (cooling ponds equipped with cooling ponds.

at inland sites)

Terrestrial Resources 40 Refurbishment impacts NONE. RG&E has no plans for major refurbishment at Ginna Station.

Threatened or Endangered Species 49 Threatened or endangered SMALL. Species of concern have a low potential for occurrence species in habitats affected by plant operations and lack of observed impacts during operational monitoring.

Air Quality 50 Air quality during NONE. RG&E has no plans for major refurbishment at Ginna refurbishment Station.

(nonattainment and maintenance areas)

Page 6-2

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 6 Appendix E - Environmental Report Table 6.1-1 (continued)

Environmental Impacts Related to License Renewal at Ginna Station No. issuea Environmental Impact Human Health 57 Microbiological organisms SMALL. Water temperatures would not support viable (public health) (plants using populations of thermophilic microbiological organisms; thereby lakes or canals, or cooling minimizing potential public health impacts.

towers or cooling ponds that discharge to a small river) 59 Electromagnetic fields, SMALL. All circuits meet National Electrical Safety Codes acute effects (electric requirements for limiting current-induced shock.

shock)

Socioeconomics 63 Housing impacts SMALL. No impacts are anticipated because no additional employees are expected. Analyzed impact from adding as many as 60 employees during the license renewal term; 100 housing units would be required in an area with a population greater than 829,000. This impact would be small.

65 Public services: public SMALL. No impacts are anticipated because no additional utilities employees are expected. Analyzed impact from adding as many as 60 employees during the license renewal term; this could result in as many as 308 new residents in Monroe and Wayne Counties and approximately 22,500 additional gallons of water per day demand on water systems in the two counties.

This impact would be small.

66 Public services: education NONE. RG&E has no plans for major refurbishment at Ginna (refurbishment) Station.

68 Offsite land use NONE. RG&E has no plans for major refurbishment at Ginna (refurbishment) Station.

69 Offsite land use (license SMALL. RG&E annual property tax payments for Ginna Station renewal term) averaged approximately 2.0 percent of Wayne County's total annual revenues, and are trending towards 10 percent for both the Town of Ontario's and the Wayne Central School District's total annual revenues. License renewal tax-driven land-use changes would generate very little new development and minimal changes in the area's land-use patterns.

70 Public services: SMALL. Analyzed impact from adding as many as 60 transportation employees during the license renewal period; the impact would be small and mitigative measures such as increased traffic control would not be warranted.

71 Historic and archaeological SMALL. No impacts to historic or archaeological resources resources were identified.

Page 6-3

R.E. Ginna Nuclear Power Plant Applicaiion for Renewed Operating License Chapter 6 Appendix E - Environmental Report Table 6.1-1 (continued)

Environmental Impacts Related to License Renewal at Ginna Station No. Issue' Environmental Impact Postulated Accidents 76 Severe accidents SMALL. RG&E identified four potentially cost-beneficial severe accident mitigation measures that are subject to continued evaluation. None are related to-aging and would not be implemented under 10 CFR 54. However, RG&E will continue to refine the evaluation and consider implementation of cost beneficial modifications through the current plant change process.

Environmental Justice 92 Environmental justice SMALL. No disproportionately high or adverse impacts to minority or low-income populations.

a. 10 CFR 51, Subpart A,Appendix B, Table B-1.

CWA = Clean Water Act gpm = gallons per minute No. = Issue number RG&E = Rochester Gas and Electric Corporation SPDES = State Pollutant Discharge Elimination System Page 6-4

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 6 Appendix E - Environmental Report 6.2 Mitigation NRC "The report must contain a'consideration of alternatives for reducing adverse impacts..;for all Category 2 license renewal issues..." 10 CFR 51.53(c)(3)(iii)

"The environmental report shall include an analysis that considers and balances

...alternitives available for reducih6 or avoiding adverse environmental effects...

10 CFR 51..45(c).as incorporate.d.b 10 CFR 51.53(c)(2)

All impacts of license renewal at Ginna Station are small and would not require additional mitigation. RG&E implemented mitigative measure during original construction to minimize potential operational impacts. Ginna Station's once-through cooling system was designed and constructed so as to minimize impacts to aquatic life. The intake is located approximately 3,100 feet offshore and covered with a velocity cap, with the bottom of the port openings about four feet above the lake bottom, and an intake velocity of 0.8 feet per second. Placement of the intake off shore is preferable to locating it within the more productive nearshore areas. More organisms, including macroinvertebrates, ichthyoplankton, and fish, reside near the lake bottom (especially during daytime), thus keeping the intake ports off the lake bottom reduces entrainment into the intake. The velocity cap minimizes the formation of a vortex and establishes a horizontal intake current to which fish can better sense and respond. Finally, the relatively low intake velocity is well within the swimming speeds for most resident fish.

Current operations include mitigative activities that would continue during the term of Ginna Station's license renewal. RG&E has undertaken several protective measures that will lessen impacts on impinged aquatic life. The current SPDES Permit requires RG&E to modify the traveling screen debris/fish sluiceway to make it less injurious to fish being returned to the Lake. Such modifications were completed in July 1998. A modification was initiated, in 2000, to change the mesh on the traveling screens.

The modification changed the 3/8-inch square, galvanized-wire woven mesh to 3/16 inch by 1-inch rectangular, stainless steel "crimped fit" mesh. The purpose of the change is to increase the ability of the screens to capture and remove lake algae, primarily Cladophora,so it does not enter the condenser cooling system, while still maintaining the required flow area through the screens. The original woven mesh design tended to trap such algae in the screens due to crevices in the woven joints.

The new screens are smoother, and less algae is trapped. Also, the smoother texture helps to enhance fish survival, as the fish will experience less abrasion. Two of the four traveling screens had been replaced by May 2002. The other two replacements are scheduled to be completed before the end of 2003. One of the two replaced screens was coated with an anti-fouling material to further reduce the propensity to trap algae. Based on two years of operating experience, no difference in algae impingement was detected between the coated and uncoated screens, and wear from traveling screen use was causing the coating to become dislodged.

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R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 6 Appendix E - Environmental Report Further enhancements to the traveling screens will not employ the anti-fouling coating.

In response to SPDES permit conditions, RG&E has a water use minimization program in which one of the Ginna Station circulating pumps is typically shut down during refueling outages. To minimize stress upon impinged fish, RG&E has also modified the screen washwater fish/debris trough and operates each of the traveling screens 15 minutes of each hour. These actions reduce the impacts of operations on aquatic life in Lake Ontario.

Since 1994, RG&E has, as a part of its Environmental Stewardship Program, participated in several area conservation efforts including the Rochester Peregrine Falcon Project, the New York River Otter Project, the Famous Historic Trees Program, and the American Kestrel Nest Box Program. Current operations also include environmental monitoring activities that would continue during the license renewal term. These activities include the radiological environmental monitoring program, radiological effluents control program, and SPDES discharge monitoring.

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R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 6 Appendix E - Environmental Report 6.3 Unavoidable Adverse Impacts NRC The environmental report shall discuss any A9"...adverse environmental effects which cannot be avoided should the proposal be implemented....". 10 CFR 51.45(b)(2) as adopted by 51.53(6)(2)

RG&E adopts by reference for this environmental report the NRC findings stated in the Generic EnvironmentalImpact Statement for License Renewal of Nuclear Plants (GELS) for applicable Category 1 issues (see Appendix A), including discussions of any unavoidable adverse impacts. In Chapter 4.0, RG&E examined the 21 Category 2 issues the NRC identified in the GElS and the environmental justice issue, and identified the following unavoidable adverse impacts of renewing the operating license for Ginna Station:

" The cooling water system would cause some early life stages of fish to be lost by entrainment during plant operation. Operational monitoring conducted at Ginna Station has indicated that an average of 89 million fish eggs and 17 million fish larvae pass through the system annually, predominantly alewife, smelt, and johnny darters. Considering the Lake ichthyoplankton community and the species entrained, it was concluded that entrainment losses from Ginna Station operation have minimal adverse effects on local fish populations in Lake Ontario (see Section 4.2.1).

"* Some fish would be lost due to impingement on the traveling screens at Ginna Station. Impingement monitoring at Ginna Station has been conducted since 1973, with impinged fish consisting predominantly of alewife and smelt.

The 19-year average impingement percentages for alewives and smelt are 0.00100 and 0.00084, respectively. Results of these studies indicated that the overall effects of impingement on Lake Ontario fish populations in the vicinity of Ginna Station were minimal (see Section 4.2.2).

" RG&E does not expect to add staff for the license renewal period. However, for the purpose of preparing a bounding analysis, RG&E assumed that license renewal could necessitate adding as many as 60 staff. The assumed addition of 60 direct workers to Wayne and Monroe Counties, where approximately 92 percent of the Ginna Station workforce resides, could result in small impacts to housing availability, public water supplies, and offsite land use. Impacts to the transportation infrastructure could also result in small impacts (see Sections 4.8, 4.9, 4.11, and 4.12).

Page 6-7

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 6 Appendix E - Environmental Report 6.4 Irreversible or Irretrievable Resource Commitments NRC The environmental report shall discuss any ....irreversible and irretrievable commitments of resources which would be involved in the proposed action should it be implemented ...... 10 CFR 51.45(b)(5) as adopted by 51.53(c)(2) .

The continued operation of Ginna Station for the license renewal term will result in irreversible and irretrievable resource commitments, including:

"* Nuclear fuel, which is utilized in the reactor and converted to radioactive waste,

"* Land required to permanently store or dispose of this spent nuclear fuel and the low-level radioactive wastes generated from plant operations,

"* Elemental materials that will become radioactive, and

"* Materials used for the normal industrial operations of the plant that cannot be recovered or recycled or that are consumed or reduced to unrecoverable forms.

Page 6-8

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 6 Appendix E - Environmental Report 6.5 Short-term Use Versus Long-term Productivity of the Environment NRC~

The environmental report shall discuss the "...relationship between local short-term uses of man's environment and the maintenance and enhancement of long-term, prýodyctivity...." IO CFR 51.45(b)(4) as adoptbd by 51.53(6)(2)

The current balance between short-term use and long-term productivity of the environment at the Ginna Station site was set in 1969, when the unit began operating. The U.S. Atomic Energy Commission (AEC) documented its evaluation of this balance in its final environmental statement for Ginna Station (Ref. 6.5-1), noting the conversion of approximately 41 acres of land to electric power generation facilities. The AEC noted that, upon decommissioning, much of the facility could be dismantled and restored to its original condition for the long term.

RG&E notes that the current balance is now well established and can be expected to remain essentially unchanged by renewal of the operating license and extended operation of Ginna Station. Extended operation of the plant would postpone restoration of the site and its potential availability for uses other than electric power generation. It would also result in other short-term impacts on the environment, all of which have been determined to be small on the basis of the NRC's evaluation in the GElS and RG&E's evaluation in this environmental report.

Page 6-9

R.E. Ginna Nuclear Power Plant Applicatidr for Renewed Operating License Chapter 6 Appendix E - Environmental Report 6.6 References Ref. 6.5-1 U.S. Atomic Energy Commission. FinalEnvironmentalStatement Related to the Operationof R.E. Ginna Nuclear Power Plant Unit 1, RG&E Corporation,Docket No. 50-244. Washington, D.C.

December 1973.

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R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report 7.0 ALTERNATIVES TO THE PROPOSED ACTION NRC The environmental report shall discuss "Alternatives to the proposed action....". 10 CFR51.45(b)(3), as adopted by reference at 10 CFR 51.53(c)(2)

"....The report is not required to include discussion of need for power or economic costs and benefits of ... alternatives to the' roposed action except insofar as such costs and benefits are either essential for a determination regarding the inlusion of an alternative inthe range of alternatives considered or relevant to mitigationn..... 10

~CFR 51,53(cf(2')

":While any methods are available for generating electricity; and a huge number of combinations or mixes can be assimilated to 'meet a defined generating requirement, such expanisive consideration would be too unwieldy to perform given the purpos Ies of this analysis. Therefore, NRC has idetermined that a reasonable set of alternativesshould be limited to analysis of single, discrete electric generation sources and only electric generation sources that are technically feasible and commercially viable...." (Ref. 7.0-1, Section'8 -,)

"...The consideration of alternative energy sources in individual license renewal reviews will considertho"se alternatives that are reasonable for the region, including power~purchases from outside the applicant's service area ...... (Ref. 7.0-2, Section lHPage 66541) 11M The National Environmental Policy Act (NEPA) requires the U.S. Nuclear Regulatory Commission (NRC) to consider the environmental impacts of the proposed action (i.e., license renewal) and alternatives to the proposed action when deciding whether to approve renewal of an applicant's operating license. Rochester Gas and Electric Corporation (RG&E) identifies in this chapter reasonable alternatives to renewal of the R. E. Ginna Nuclear Power Plant (Ginna Station) operating license and presents its evaluation of associated environmental impacts. This chapter also includes descriptions of alternatives RG&E considered but determined to be unreasonable to consider in detail, and associated supporting rationale.

In Section 7.1, RG&E addresses the "no-action" alternative in terms of the potential environmental impacts of not renewing the Ginna Station operating license independent of any actions taken to replace or compensate for the associated loss of generating capacity. RG&E describes, in Section 7.2, feasible alternative actions that could be taken, which also essentially are elements of the no-action alternative, and presents other alternatives RG&E does not consider to be reasonable.

Section 7.3 presents RG&E's environmental impact evaluations of the reasonable alternatives.

The environmental impact evaluation of alternatives presented in this chapter is not intended to be exhaustive. Rather, the level of detail and analysis relies on the NRC's decision-making standard for license renewal, as follows:

"...the NRC staff, adjudicatory officers, and Commission shall determine whether or not the adverse environmental impacts of license renewal are so great that Page 7-1

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report preserving the option of license renewal for energy planning decision makers would be unreasonable" [10 CFR 51.95(c)(4)].

Therefore, analyses were generally scoped to provide enough information to support NRC decision-making by demonstrating whether an alternative would have a smaller, comparable, or greater environmental impact than the proposed action.

Additional detail or analysis was not considered useful or necessary if it would identify only additional adverse impacts of license renewal alternatives; i.e.,

information beyond that necessary for a decision based on the standard quoted above. This approach is consistent with the Council on Environmental Quality regulations, which provide that the consideration of alternatives (including the proposed action) be adequately addressed so reviewers may evaluate their comparative merits [40 CFR 1502.14(b)].

RG&E characterizes environmental impacts in this chapter using the same definitions of "Small," "Moderate," and "Large" used in Chapter 4 of this environmental report (ER) and by the NRC in its Generic EnvironmentalImpact Statement for License Renewal of Nuclear Plants (GElS) (Ref. 7.0-1). In Chapter 8, RG&E presents a summary comparison of environmental impacts of the proposed action and alternatives.

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R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report 7.1 No-action Alternative RG&E considers the no-action alternative addressed in this ER to be a scenario in which the NRC does not renew the Ginna Station operating license, RG&E ceases plant operation upon license expiration in 2009 and decommissions the facility, and RG&E and/or others take appropriate actions to meet system-generating needs created by discontinued operation of the plant. RG&E addresses only the impacts of decommissioning in this section.

In the GELS, the NRC defines decommissioning as the safe removal from service of a nuclear generating facility and the reduction of residual radioactivity to a level that permits release of the property for unrestricted use and termination of the license.

Decommissioning options evaluated in the GElS include immediate decontamination and dismantlement, and safe storage of the stabilized and defueled facility followed by decontamination and dismantlement. Regardless of the option chosen, decommissioning must be completed within 60 years after operations cease (10 CFR 50.82). In the event the NRC does not renew the Ginna Station operating license, RG&E currently plans to operate the plant until the current license expires, then initiate decommissioning activities in accordance with NRC requirements. The NRC's description of decommissioning activities in the GElS is based on an evaluation of a reactor larger than Ginna Station (the pressurized water, 1,175 megawatt Trojan Nuclear Plant), which essentially bounds the decommissioning activities RG&E would conduct at Ginna Station.

The NRC presents in the GElS (Ref. 7.0-1, Chapter 7 and Section 8.4) a generic evaluation of environmental impacts associated with decommissioning and associated changes resulting from license term extension based on its Final Generic EnvironmentalImpact Statement on Decommissioning of Nuclear Facilities(Ref. 7.1 1), which is currently being updated. The evaluation addresses occupational and public dose; impacts of waste management; and impacts to air, water, ecological, and socioeconomic resources. Based on its review, RG&E considers the generic evaluation appropriate to Ginna Station.

Decommissioning activities and their impacts are not discriminators between the proposed action and the no-action alternative. RG&E is required to decommission Ginna Station regardless of the NRC's decision on license renewal; renewal would merely postpone decommissioning for another 20 years. In the GElS, the NRC established that the timing of decommissioning operations does not substantially influence the environmental impacts of decommissioning. RG&E adopts by reference the NRC's findings to the effect that delaying decommissioning until after the renewal term would have small environmental impacts (10 CFR 51, Subpart A, Appendix B, Table B-I, Decommissioning). The discriminators between the proposed action and the no-action alternative lie within the choice of generation replacement options that compose the no-action alternative. Section 7.3 presents RG&E's analysis of the impacts from these options.

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R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report RG&E concludes that the decommissioning impacts under the no-action alternative would not be substantially different from those the NRC identified in the GElS as the impacts that would occur following license renewal. These impacts would be temporary and would occur at the same time as the impacts from meeting system generating needs.

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R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report 7.2 Alternatives That Meet System Generating Needs Ginna Station has a net summer capability of approximately 490 megawatts (MW) and, in the year 2000, Ginna generated approximately 3.8 terawatt-hours of electricity (Ref. 7.2-1, Table 111-2). This power, equivalent to the energy used by approximately 560,000 residential customers, would be unavailable to the New York wholesale energy market and RG&E's retail customers in the event the Ginna Station operating license is not renewed. RG&E examines in this section potential alternatives to accommodate these losses in the event the Ginna Station operating license is not renewed.

In Section 7.2.1, RG&E provides general background information regarding the regulatory status of the electric power industry in the State of New York, and information pertinent to development of new generating facilities in the State.

Section 7.2.2 provides more specific information about alternatives RG&E considers to be reasonable, for purposes of this analysis, to replace the generating capability that would be lost in the event the Ginna Station operating license is not renewed.

These include power purchase (Section 7.2.2.1), new natural gas-fired generation (Section 7.2.2.2), and new coal-fired generation (Section 7.2.2.3). Section 7.2.3 describes other alternatives considered and RG&E's rationale for not considering them to be reasonable options for replacing power produced by Ginna Station.

7.2.1 General Considerations 7.2.1.1 Restructuring Initiatives The electric power industry in New York has undergone substantial restructuring in recent years with the transition to functional wholesale and retail markets. Strategic direction and policy guidance for energy production and use in the State, including the restructuring initiative, is provided by the New York State Energy Planning Board (NYSEPB). NYSEPB planning results are set forth in the State Energy Plan; progress with respect to the plan and an assessment of need to update the plan are provided in NYSEPB Annual Reports (e.g., Ref. 7.2-2).

NYSEPB's 2002 State Energy Plan (Ref. 7.2-3, pages S-2, S-3) adopted the following public policy objectives:

" Supporting the continued safe, secure, and reliable operation of the State's energy and transportation systems infrastructures;

" Stimulating sustainable economic growth, technological innovation, and job growth in the State's energy and transportation sectors, through competitive market development and government support;

" Increasing energy diversity in all sectors of the State's economy through greater use of energy efficiency technologies, and alternative energy resources, including renewable-based energy;

" Promoting and achieving a cleaner and healthier environment; and, Page 7-5

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report

• Ensuring fairness, equity, and consumer protections in an increasingly competitive market economy.

The NYSEPB's 2002 State Energy Plan documents progress in the restructuring initiative. It indicates that more than 80 percent of generating capacity formerly owned by utilities in the State has been sold to independent power producers who participate in the State's competitive wholesale electricity market, and all retail electricity customers in the State formerly served by regulated utilities now have a choice of supplier (Ref. 7.2-3, page 1-10).

The New York State Public Service Commission (NYSPSC) implements many provisions of the State Energy Plan. The Commission has played a central role in efforts to develop competitive wholesale and retail electricity markets, primarily through mandates for and approval of restructuring plans by the State's utilities during the late 1990s. The NYSPSC set the terms and conditions for introduction of retail competition (customer choice) and divestiture of generating plants in New York.

Under terms of its NYSPSC-approved restructuring plan, RG&E is not required to divest its limited generating facilities, but has functionally separated its generating business from its other businesses (e.g., transmission and distribution) and allows all customers in its service territory the option to purchase electricity from either RG&E or other qualified energy service companies (ESCos).

Restructuring has resulted in additional responsibilities for the New York State Energy Research and Development Authority (NYSERDA). NYSERDA sponsors energy research and development programs to promote safe and economical energy production and efficiency technologies, provides funding vehicles for energy-related projects, and analyzes the effect of New York's energy-related policies on energy consumers in the State (Ref. 7.2-4). NYSERDA implements the New York Energy

$martTM Program, which is designed to continue energy efficiency, research and development, and environmental protection programs during the State's transition to electric retail competition. The NYSPSC named NYSERDA administrator of this program to ensure the continued benefit of these services, which were traditionally offered by utilities. The program is paid for by a SBC on the electricity transmitted and distributed by the State's investor-owned utilities, and is being implemented in those utility territories (Ref. 7.2-5).

The New York State Reliability Council (NYSRC) promotes and preserves the reliability of electric service on the New York State Power System by developing, maintaining, and monitoring compliance with reliability rules that must be complied with by the New York Independent System Operator (NYISO) and all other entities engaged in electric transmission, ancillary services, and energy and power transactions on the New York State Power System (Ref. 7.2-6). The NYSRC sets the installed capacity requirements for the New York Control Area (NYCA) consistent with the Northeast Power Coordinating Council reliability criterion, which is revisited annually. For 2001, the NYSRC set this installed capacity requirement at 18 percent over the NYCA year-2001 summer peak load (Ref. 7.2-1).

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R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report The NYISO, which initiated operations December 1, 1999, upon establishment of New York's wholesale electric energy market, is responsible for the safe and reliable operation of New York State's bulk power system and for the operation of wholesale electric energy markets in the State. The NYISO has a central role in planning efforts needed to ensure continued adequacy of electric generation and transmission capabilities (Ref. 7.2-7). The NYISO assigns a proportion of the installed capacity requirement established by the NYSRC to each load-serving entity (LSE) located in the NYCA, including RG&E. LSEs within the NYCA may meet their installed capacity requirements through procurement of capacity from appropriately qualified resources within the NYCA or neighboring control areas directly interconnected to the NYCA (Ref 7.2-1, pages 1, 2).

Construction and operation of electric generating facilities with a capacity of 80 MW or more requires a Certificate of Environmental Compatibility and Public Need in accordance with Article X of the New York State Public Service Law (NY Consolidated Laws, Chapter 48, Article X). The New York State Board on Electric Generation Siting and the Environment, chaired by the Chairman of the Public Service Commission and supported by the Department of Public Service, conducts the Article X reviews, which include an examination of alternatives to and detailed environmental impact analyses of each proposed facility (Ref. 7.2-8).

7.2.1.2 Generation and Utilization Electric power generating capability and utilization in New York, projected energy needs, and current actions being taken to meet those needs reflect the influence of technical and regulatory viability and energy markets, and offer insight regarding potentially reasonable alternatives to replace power produced by Ginna Station.

As Figure 7.2-1 shows, power plants that rely primarily on natural gas for fuel, including gas-fired, oil- or gas-fired, and combined-cycle facilities, represent approximately 47 percent of generating capability in New York, followed by approximately 11 percent to 15 percent of generating capability each by hydroelectric, nuclear, petroleum-fired, and coal-fired facilities (Ref. 7.2-1).

Comparison with actual utilization of this capability indicates that coal and nuclear are used to a substantially greater degree relative to available capability than either oil-fired or gas-fired generation (Ref. 7.2-9). This condition reflects the relatively low fuel cost and baseload suitability for nuclear power and coal-fired plants, and relatively higher use of gas- and oil-fired units to meet peak loads. Comparison of capability and utilization for petroleum and gas-fired facilities indicates a strong preference of gas firing over oil firing, indicative of higher cost and air emissions associated with oil firing. Energy production from hydroelectric sources is similarly preferred from a cost standpoint, but capacity is limited and utilization can vary substantially depending on water availability.

NYSERDA has compiled annual New York electric generation by fuel type for the period 1985 to 1999. The amount of New York electric power generated in 1999 Page 7-7

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report Figure 7.2-1 New York Electric Capability and Utilization: 2000 Coal Petroleum Petroleum 11 2% 11 3% Coal 11 1%

Other Hydroelectnc 23%

15 5%

Gas 284%

Oil/GasHydroelectric 349% 176%

Nuclear 14 1%

Gas & Combined Cyde Nuclear 120% 228%

Capability Utilization Source: Ref. 7.2-1, Ref. 7.2-10.

compared to that in 1985 by source has increased substantially for natural gas (196 percent) and nuclear (54 percent), and decreased substantially for petroleum (48 percent). The amount of power from hydroelectric generation has decreased by 20 percent, while power from coal-fired plants generally exhibited a slight increase through this period (Ref. 7.2-10).

RG&E has limited generation resources, totaling approximately 887 MW.

Approximately 56 percent of this capability is nuclear power (from the Ginna Station) and 28 percent is coal-fired (from RG&E's Russell Station). Most of its remaining capacity is gas-fired (8 percent), primarily for peaking, and conventional hydroelectric (6 percent). As noted above for the State as a whole, RG&E preferentially relies on nuclear power and coal-fired generation to meet its baseload generating requirements.

NYISO projections through 2020, which account for DSM load reductions and assume shutdown of nuclear generating facilities in the State, including Ginna Station, when their current operating licenses expire, indicate that the NYCA will need additional capacity beyond 2001 to meet an anticipated 18 percent reserve margin (Ref. 7.2-1). However, NYISO anticipates that the additional resources necessary to meet the reserve margin would be procured through the installed capacity market, noting that facilities representing substantial additional capacity had approved Article X applications or were in the pre-application phase of the Article X process (Ref. 7.2-1).

Page 7-8

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report The NYSEPB (Ref. 7.2-3, page 1-11 and 3-108) indicates that, as of May 2002, seven new plants representing a net addition of 4,990 MW, were approved through the Article X process; applications for an additional eleven plants totaling 6,883 MW were filed; and another six plants totaling 4,325 MW were announced in the State.

Some of these projects, however, are on hold, some have been abandoned, and decisions to drop others could occur. A review of proposed new generation projects that have filed Article X applications or have filed pre-application reports or pre scoping statements (Ref. 7.2-11) indicates that virtually all of these facilities utilize natural gas as exclusive or primary fuel, and those proposed for baseload service use combined-cycle technology. The NYSEPB (Ref. 7.2-3, pages 3-106, 3-107, 3 108, 1-29) points out that over the next 20 years, the State's dependence on natural gas for electric generation could increase from 25 percent to almost 40 percent. This trend can be traced to power plant emission standards, New York State environmental siting review requirements, the cost and availability of gas and gas fired power plants, the development of high-efficiency combined cycle technology, and the restructuring of the electric industry. Unfortunately, reduced fuel diversity due to this growing dependence on natural gas increases the State's risk exposure to fuel supply disruption and price swings, a concern expressed by the NYSEPB.

According to the NYSEPB in the New York State Energy Plan (Ref 7.2-3, pages 1 31, 3-172, 3-177), future gas demand, supply, and price are especially difficult to project due to the dynamic changes taking place in the gas and electric industries and rapidly changing market conditions. Nonetheless, adequate supplies are expected to be available and real prices are projected to drop slightly on average, although they will remain volatile. Even if no post-2003 pipeline expansion projects are built, the existing gas systems are expected to be adequate to meet all generation scenarios studied.

The 2002 New York State Energy Plan (Ref 7.2-3, pages 3-141 through 3-145, 1-30, 1-32) assumed that all nuclear plant licenses will be extended. A scenario was studied in which this did not occur. Wholesale prices by 2020 were found to rise roughly 10 percent above the base case scenario, and emissions were found to increase (subject to the limits of the statewide emission caps). Natural gas dependence approached 50 percent. The Plan also concluded that advanced coal technologies offer a means to provide fuel diversity, lower wholesale prices, and reduced emissions in relation to conventional coal-fired generation technologies, although not in relation to gas-fired generation.

7.2.1.3 Regulatory Considerations for Air Quality Use of either natural gas-fired combined-cycle or clean-coal technologies would be subject to air emission controls and limits established in accordance with applicable U.S. Environmental Protection Agency (EPA) regulations (40 CFR 50-99) and State regulations [e.g., New York State Department of Environmental Conservation (NYSDEC) regulations at 6 NYCRR Chapter Ill]. As a minimum standard, the facilities would be required to comply with New Source Performance Standards (NSPS) set forth by EPA at 40 CFR 60. For a large bituminous coal-fired power Page 7-9

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report plant, NSPS generally require that particulate matter emissions be reduced by at least 99 percent from uncontrolled levels and not exceed 0.03 pounds per million British thermal units (Ib/MMBtu) heat input. Sulfur dioxide (S02) emissions must generally be reduced by at least 90 percent from uncontrolled levels and not exceed 1.20 Ib/MMBtu, and nitrogen oxide (NO.) emissions (expressed as nitrogen dioxide, NO2) must not exceed 0.50 Ib/MMBtu (for sub-bituminous coal combustion) or 0.60 Ib/MMBtu (for bituminous or anthracite coal combustion). For large natural-gas turbines, the NSPS for NO) emissions is a calculated value that depends on fuel bound nitrogen and heat rate of the unit, generally amounting to approximately 75 parts per million (ppm); SO 2 emissions are limited to 0.015 percent by volume at 15 percent oxygen (dry basis); and fuel must contain sulfur less than 0.8 percent by weight. More stringent performance standards may be applied by states. For example, 6 NYCRR 227 specifies application of reasonably available control technology for NO, of 0.42 Ib/MMBtu for very large tangentially fired dry-bottom coal fired boilers, and 42 ppm corrected to 15 percent oxygen for large natural gas-fired combined-cycle combustion turbines.

The NSPS are seldom limiting, and emission limits for individual plants are established on the basis of air emission source designation, attainment status of potentially affected areas with respect to air quality standards, technology and fuel type, and related factors. Located in an area that is in attainment or unclassified with respect to national ambient air quality standards (NAAQS; 40 CFR 50), such as is the case for most of western upstate New York including the Ginna Station site region, these plants would qualify as a major source subject to the new source review provisions of the Prevention of Significant Deterioration (PSD) rules (40 CFR 51.166). Under these provisions, emission limits are established on the basis of best available control technology (BACT) for regulated pollutants that exceed established PSD significant emission rates and a demonstration that ambient air quality standard compliance would not be jeopardized. If the facility is located in a nonattainment area with respect to one or more NAAQS pollutants, emission rates for the nonattainment contaminants would be established under nonattainment new source review provisions (e.g., as set forth for New York at 6 NYCRR 231). In this case, emission standards for the nonattainment contaminants are generally established on the basis of more stringent lowest achievable emission rates (LAERs). In addition, offsets of 1:1 or more could be required for nonattainment contaminant emissions.

Because NO, is an ozone precursor, emissions of this pollutant are subject to the more stringent LAER controls for plants located in New York or elsewhere in EPA's designated Ozone Transport Region where changes in state implementation plans (SIPs) were implemented in accordance with EPA's NO, SIP Call (63 FR 57356, October 27, 1998). For example, even if located in an attainment area, NO, emissions for a plant in New York would be established on the basis of LAER, and offsets amounting to a ratio of at least 1.15:1 would be required using emission reduction credits, per 6 NYCRR 231. In addition, large fossil fuel-fired electric generating units are subject to an industry cap on NO, emissions through a market Page 7-10

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report based trading system under New York's NO, Emissions Budget and Allowance Program (6 NYCRR 204). Under this program, each affected source must have allowances for each ton of NO. actually emitted during the ozone season (May 1 through September 30). The allowances are allocated to new and existing sources based on an emission rate of 0.15 Ib/MMBtu for the ozone season.

Clean Air Act acid rain provisions (Title IV)are a particular concern with respect to S02 emissions from a coal-fired power plant. These provisions capped aggregate SO 2 emissions from power plants and established a market-based trading system for SO 2 allowances. Development of a new coal-fired plant thus would require acquisition of allowances sufficient to cover SO 2 emissions from the plant. Additional acid rain program provisions are a consideration for new coal-fired plants built in New York. New York currently limits sulfur content of coal used as fuel in new stationary combustion installations with total heat input greater than 250 million British thermal units per hour (Btu/hr) to an annual average of 1.7 pounds of sulfur per million Btu of gross heat content (6 NYCRR 225-1.2). In addition, New York has issued draft regulations under its Acid Rain Reduction Initiative which, when enacted, will require electric generators in the State to reduce SO 2 emissions an additional 50 percent below levels currently allowed under the Clean Air Act Acid Rain Program requirements by 2008, corresponding to target levels for large coal-fired facilities of 0.6 Ib/MMBtu, and will effectively extend the current 5-month NO. emission target of 0.15 Ib/MMBtu to the entire year.

7.2.2 Feasible Alternatives In view of the background information presented above, RG&E considers that purchased power and new generating capacity represented by natural gas combined-cycle technology are reasonable alternatives to Ginna Station license renewal for purposes of detailed review in this ER.

The economic and regulatory viability of developing new coal-fired baseload capacity in New York is less clear considering air emission concerns and required control measures, as evidenced by the fact that all new baseload generation planned for the State consists of combined-cycle units using natural gas as primary fuel. However, as noted in Section 7.2.1.2, the NYSEPB acknowledges that clean-coal technologies can play a role in helping the State achieve its energy, economic, and environmental goals. By increasing the fuel diversity, use of coal would also contribute to overall supply reliability and price stability for electricity in the State. Therefore, RG&E includes a modern coal-fired plant featuring clean-coal technology in its evaluations for purposes of this ER.

Specific clean-coal generating technologies that would represent viable alternatives in the case of western upstate New York are uncertain. Modern pulverized coal plants with advanced, clean-coal technology air emission controls are commercially available, and integrated gasification combined-cycle and pressurized fluidized-bed combustion technologies are at or near commercial viability. On the basis of in house feasibility investigations, RG&E considers that atmospheric circulating fluidized-bed (ACFB) technology represents a potentially viable option in view of Page 7-11

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report overall economic, technical risk, and environmental performance considerations. In this technology, solid fuel (e.g., coal, coke) is crushed and mixed with pulverized limestone, which is blown into the bottom of the ACFB combustor, where it is suspended by hot, forced air as a "fluidized bed." Emissions of sulfur oxides and NO, are controlled largely in the combustion process through capture of sulfur in the coal by the limestone and by low ignition temperatures, which reduce NO, formation.

The mixture of ash and other solid wastes from the combustion process, primarily calcium sulfate (i.e., gypsum, upon hydration) formed by the reaction of the limestone and sulfur, is a useful and potentially salable byproduct (Ref. 7.2-12, Sections 2.1.2, 2.1.4.2).

The potential viability of ACFB technology for some applications in the general region is indicated by development of a 520 MW addition to the Seward Power Plant in western Pennsylvania, which is designed to burn waste coal and is scheduled for commercial operation in 2004 (Ref. 7.2-13). In addition, the JEA CFB Combustor Project, a 297.5 MW (gross), 265 MW (net) repowering of JEA's Northside Generating Station Unit 2 steam turbine in Duval County, Florida, which uses ACFB technology, has been constructed and was in startup testing as of July 2002 (Ref. 7.2-14, Ref. 7.2-15, Ref. 7.2-16). The JEA project is being undertaken to demonstrate ACFB for large, baseload applications with sponsorship by the U.S.

Department of Energy (DOE); however, JEA independently repowered a companion generating unit (Northside Unit 1) in identical fashion on a schedule that calls for completion approximately six months prior to completion of the Unit 2 repowering, indicating confidence in the viability of this technology. These units are scheduled for commercial operation in Fall 2002 (Ref. 7.2.2). Therefore, RG&E includes an ACFB coal-fired alternative for purposes of comparison in this ER.

Descriptions of these alternatives are provided in Sections 7.2.2.1 through 7.2.2.3.

Other alternatives considered by RG&E and reasons for not considering them in detail are presented in Section 7.2.3.

7.2.2.1 Purchased Power As noted in Section 7.2.1, electric industry restructuring initiatives in the State of New York are designed to promote competition in energy supply markets by facilitating participation by non-utility suppliers, a regulatory structure is in place to appropriately anticipate and meet electricity demands, and RG&E has restructured to enable participation in the resulting wholesale electricity market. As an additional facet of this restructuring effort, retail customers in RG&E's service territory now may choose among RG&E and other sources (i.e., qualified ESCos) to supply their power, resulting in uncertainty with regard to future RG&E load obligations. In view of these conditions, RG&E assumes for purposes of this ER that adequate supplies of electricity would be available, and that purchased power would be a reasonable alternative to meet the Company's load requirements in the event the operating license for Ginna Station is not renewed.

The source of this purchased power is speculative, but may reasonably include new generating facilities developed within RG&E's service territory, elsewhere in the Page 7-12

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report State, or neighboring power pool jurisdictions. The technologies that would be used to generate this purchased power are similarly conjectural. However, considering the current and projected development of additional generating capabilities in New York noted above, natural gas combined-cycle units, such as those described in Section 7.2.2.2, would be a most likely candidate. RG&E assumes one or more of the technologies the NRC evaluated in the GElS would be used, and considers the GElS descriptions of these technologies to be appropriately representative.

RG&E does not anticipate that any additional transmission infrastructure would be needed in the event RG&E purchased power to replace Ginna Station capacity.

From a local perspective, loss of the Ginna Station would not result in a load pocket that would require construction of new transmission lines, although RG&E expects that planned reinforcement of its 110 kilovolt distribution system would be implemented sooner to ensure local system stability. From a regional perspective, New York State's interconnected transmission system is highly reliable, and the market-driven process for generation addition in the State is expected to have a positive impact on overall system reliability (Ref. 7.2-17, pages 1-5, 39-42, 58-59).

The traditional strain on the New York transmission system is west-to-east as a result of relatively low-cost generation in western upstate New York and higher demand in the east and downstate. As noted by a recent NYISO-sponsored study (Ref. 7.2-18, pages 4-5, 22-25), power imports from New England in the next few years are expected to relieve this strain in the near term, and the addition of new generation within the State is expected to reduce the frequency of encountering transmission constraints in the future.

7.2.2.2 Representative Natural Gas-fired Generation For purposes of this analysis, RG&E assumes development of a modern natural gas fired combined-cycle plant with design characteristics similar to those being developed elsewhere in New York, and with a generating capacity similar to the Ginna Station. The Wawayanda Energy Center, a 540 MW (nominal) plant near Middletown, New York, meets these general criteria. Therefore, RG&E used characteristics of this plant as described in its Article X application (Ref. 7.2-19) and other relevant resources as bases for the representative plant description in this section and the associated environmental impact assessment in Section 7.3.2.

RG&E assumes that the representative plant would be located at the Ginna Station site, which offers potential advantages of existing infrastructure (e.g., cooling water system, transmission, roads, technical and administrative support facilities).

However, the plant reasonably could be located elsewhere, and RG&E's analysis of the gas-fired alternative considers as a variation of this alternative the location of the plant at a greenfield site in western upstate New York. Except for the plant location at the Ginna Station site, RG&E assumes that the location and design of the facility and any associated new infrastructure would be subject to substantial environmental review and approvals under New York's current Article X or similar process.

Assuming a design comparable to the proposed Wawayanda Energy Center, the generating facilities for the representative plant would be housed in a 106-foot-high Page 7-13

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report building, and consist primarily of two 180 MW combustion turbines (CTs), associated heat recovery steam generators (HRSGs), and a 180 MW steam turbine generator.

The total capacity of the combined-cycle unit, 540 MW (nominal), is comparable to the 490 MW net capacity of Ginna Station. Based on daily consumption estimates for Wawayanda (Ref. 7.2-19, Section 9.2.4), and assuming a capacity factor of 80 percent for the representative plant, annual natural gas consumption for the facility would be approximately 27 billion cubic feet.

The facility would be designed to meet BACT or LAER standards, as applicable, for control of criteria air emissions. As a minimum, RG&E assumes that the plant would feature dry, low NO, combustion turbines, to minimize formation of NO,, and selective catalytic reduction for post-combustion NO, control. Emissions of particulate matter and carbon monoxide (CO) would be limited through proper combustion controls. Exhaust from the CTs would be dispersed through individual stacks approximately 225 feet high(Ref. 7.2-19, Section 3.0).

RG&E assumes for this comparative analysis that the representative plant located at the Ginna Station site could utilize either once-through cooling or closed-cycle cooling using mechanical-draft cooling towers, which would be approximately 60 feet high (Ref. 7.2-19, Section 5.6.5). Located at a greenfield site, the representative plant is assumed to use closed-cycle cooling with mechanical draft cooling towers or, in the event impacts associated with water use are a critical concern, air-cooled condensers such as are proposed for the Wawayanda Energy Center. Use of a once-through system would result in cooling water intake and discharge flows substantially less than those required for the Ginna Station, primarily because the steam-cycle portion of the combined-cycle unit would be only one-third of the total plant capacity. Based on estimated water-use requirements for the Wawayanda Energy Center (Ref. 7.2-19, Section 5.6.2), the cooling tower option would result in cooling water intake and discharge (cooling tower blowdown) flows of approximately 2,500 gallons per minute (gpm) and 500 gpm, respectively, the difference representing evaporative loss in the cooling towers. Water requirements for an air cooled condenser option are estimated to be 170 gpm (Ref. 7.2-19, Section 5.6.2).

The Ginna Station site was originally planned to accommodate an additional nuclear power unit west of the existing plant. RG&E assumes the representative plant would be located in this area, and estimates that approximately 30 acres would be required to accommodate the facility. Additional land for support infrastructure and buffer likely would be needed to locate the facility at a greenfield site. For example, the Wawayanda Energy Center site consists of approximately 53 acres (Ref. 7.2-19, Section 3.2.1), and the NRC estimates that 110 acres would be required for a 1,000 MW plant (Ref. 7.0-1, Table 8.1).

Except for a gas supply pipeline, no offsite infrastructure would have to be constructed for the representative plant located at the Ginna Station site. The nearest natural gas supply pipeline likely to have sufficient capacity and pressure to supply the plant is the Empire Pipeline, which lies approximately 14 miles due south of the Ginna Station site. RG&E assumes for this analysis that this pipeline would be Page 7-14

R E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report a suitable fuel source, and that 16 miles of supply pipeline to the site would be constructed, primarily within or along the existing transmission line corridor that extends southward from the site. Consistent with plans for the Wawayanda Energy Center (Ref. 7.2-19, Section 9.6.1.1), RG&E assumes right-of-way (ROW) widths of 75 feet and 50 feet for construction and operation, respectively.

Offsite infrastructure needed to locate the plant at a greenfield site is conjectural, but could reasonably include a natural gas supply pipeline, transmission line, and makeup water and discharge pipelines. The extent to which such infrastructure would be required is location-specific; however, such needs would be considered in siting the facility and would be subject to regulatory scrutiny.

Based on estimates provided for the Wawayanda Energy Center (Ref. 7.2-19, Sections 3.3, 3.4; Table 12-4), RG&E assumes that the representative plant would be constructed in two years with average and peak onsite workforces of approximately 240 and 420 workers, respectively, and that a permanent workforce of 25 persons would be required to operate the plant.

7.2.2.3 Representative Coal-fired Generation For purposes of this analysis, RG&E assumes development of a coal-fired power plant utilizing ACFB combustion technology with design characteristics similar to those being developed elsewhere in the U.S., and with generating capacity similar to the Ginna Station. JEA's repowering of its Northside Generating Station Units 1 and 2 in Duval County, Florida, meets these general criteria. The companion units each have a capacity of 297.5 MW (gross) and 265 MW (net) and, except for the steam turbine-generators, virtually all major facilities (e.g., combustors; emission control equipment; stack; fuel, limestone, waste receiving/handling and storage facilities; stormwater runoff control basins) are new construction. RG&E used characterization of the JEA Northside Project and associated environmental impacts documented by the DOE (Ref. 7.2-12), and other relevant resources as bases for the representative plant description in this section and the associated environmental impact assessment in Section 7.3.3.

For purposes of this ER, RG&E assumes that the representative coal-fired plant would be located at the Ginna Station site, which offers potential advantages of existing infrastructure (e.g., cooling water system, transmission, roads, technical and administrative support facilities). However, the Ginna Station site lacks infrastructure for delivery of coal and limestone, which would necessitate construction of barge delivery and unloading facilities, or railway from the main CSX line in Rochester.

Therefore, such a plant likely would be located elsewhere, and RG&E's analysis of the coal-fired generation alternative considers as a variation of this alternative the location of the plant of a greenfield site in western upstate New York. Except for plant location at the Ginna Station site, RG&E assumes that the location and design of the facility and any associated new infrastructure would be subject to substantial environmental review and approvals under New York's current Article X or similar process.

Page 7-15

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report The use of ACFB technology would enable the representative plant to burn a relatively broad range of coal types (Ref. 7.2-15). However, RG&E assumes for this analysis that the plant would burn medium-sulfur bituminous coal of the type currently used at its Russell Station. This coal originates in Pennsylvania and West Virginia. Average characteristics of this fuel include a heat content of 13,233 Btu/lb, a sulfur content of 2.22 percent by weight (1.68 lb/MMBtu), and an ash content of 7.35 percent by weight (Ref. 7.2-20). Scaling from DOE estimates for the Northside units, taking into account differences in fuel heat content and capacity factor, RG&E estimates that the plant would consume approximately 1.4 million tons of coal per year.

The JEA Northside Generating Station ACFB units are indicative of the size units that would potentially be available to replace the capacity of Ginna Station, and descriptive information is readily available from the DOE (Ref. 7.2-12). Therefore, RG&E assumes that the representative plant would have a capacity of 530 MW, consistent with the combined capacity of the JEA units. This capacity is somewhat higher than that of the Ginna Station. However, RG&E expects that availability of the ACFB units would be somewhat less than a nuclear power unit. To establish a better basis of comparison, RG&E has assumed for this analysis a capacity factor of 80 percent for the representative plant, which corresponds to annual net production of approximately 3.7 terawatt-hours of electricity, comparable to that of Ginna Station.

The facility would be designed to meet BACT or LAER standards, as applicable, for control of criteria air emissions. Specific air-emission controls and resulting emission rates are speculative. However, RG&E assumes for this analysis that they would be comparable to those described for the JEA Northside units (Ref. 7.2-12, Section 2.1.3, Table 2.1.1). Scaling from the DOE's estimate, accounting for differences in coal consumption as noted above and coal sulfur content, RG&E estimates that approximately 1.4 million tons of limestone would be used for combustion control of SO 2 emissions. Post-combustion emission controls would minimally include selective noncatalytic reduction for NO, control and fabric filtration (baghouse) for 99.8 percent particulate emissions removal, and 98 percent of SO 2 would be removed through control of the combustion process and possible addition of a polishing scrubber. Expected emission rates for major criteria pollutants are: SO 2, 0.15 lb/MMBtu; NO 2 , 0.09 lb/MMBtu; and particulates less than 10 microns in diameter (PM 10), 0.03 lb/MMBtu. Exhaust from the units would be dispersed through a common stack approximately 500 feet high (Ref. 7.2-12, Section 2.1.3, Table 2.1.1).

RG&E assumes for this comparative analysis that the representative plant located at the Ginna Station site could utilize either once-through cooling or closed-cycle cooling using mechanical-draft cooling towers, which may be up to 100 feet high.

Located at a greenfield site, the representative plant is assumed to use closed-cycle cooling with mechanical-draft cooling towers. Use of a once-through system would result in cooling water intake and discharge flows slightly less than required for the Ginna Station, assuming a somewhat higher thermal efficiency of the ACFB units.

Substantially smaller flows would result from the use of closed-cycle cooling.

Page 7-16

R.E. Ginna Nuclear Power Plant Applicaiion for Renewed Operating License Chapter 7 Appendix E - Environmental Report However, water consumption, due to evaporation from the cooling towers, would be greater than for a once-through system.

The Ginna Station site was originally planned to accommodate an additional nuclear power unit west of the existing plant, and RG&E assumes that the power block for the representative plant would be located in this area. RG&E estimates that approximately 60 acres would be needed to accommodate the power block; fuel and limestone delivery, handling, and storage facilities; cooling towers; and related support facilities.

Additional land would be required for storage and disposal of combustion solid waste (predominantly ash and gypsum) from the facility. For purposes of this analysis, it is assumed that RG&E would actively market this material, but the amount that could be sold for beneficial uses would be conjectural. Scaling from estimates for the JEA Northside project (Ref. 7.2-12, Section 5.0) to account for differences in capacity factor and coal characteristics (i.e., heat value, sulfur and ash content) and assuming an average fill height of 30 feet, approximately 260 acres of land would be required to dispose of all such material generated during the entire 30-year life of the facility.

Consistent with plans for the JEA Northside project (Ref. 7.2-12, Section 4.1.7.2), the disposal facility would feature a double liner, leachate collection system, and runoff controls.

Offsite infrastructure for delivery of coal and limestone would be needed to develop the coal-fired plant at the Ginna Station site. Potential options include reconstructing/upgrading approximately 18 miles of abandoned railroad from the CSX main line approximately 1 mile west of the Genessee River, in Rochester, to the site and constructing a new 3-mile spur segment into the site; or constructing a barge unloading terminal at the site. RG&E has not investigated the economic or regulatory viability of either of these options but, as with the coal-fired alternative as a whole, is including them in the interest of examining potential environmental impacts of generation alternatives compared to extended operation of the Ginna Station.

Locating the representative plant at a greenfield site may require more site acreage than for the Ginna Station siting alternative to provide for additional onsite support infrastructure and buffer areas. For example, scaling for plant size from the NRC's estimate for a 1,000 MW plant (Ref. 7.0-1, Table 8.1), a 900-acre site could be required. Offsite infrastructure needed to locate the plant at a greenfield site is conjectural, but could reasonably include construction of a rail spur or barge unloading terminal, transmission line, and makeup water and discharge pipelines.

The extent to which such infrastructure would be required is location specific; however, such needs would be considered in siting the facility and would be subject to regulatory scrutiny.

Consistent with estimates provided by the DOE for the JEA Northside project (Ref.

7.2-12, Sections 2.1.4, 2.1.5), RG&E assumes that the representative coal-fired plant would be constructed in approximately three years with a peak onsite workforce of Page 7-17

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report approximately 820 workers, and that a permanent workforce of approximately 100 150 persons would be required to operate the plant.

7.2.3 Other Alternatives Considered RG&E describes in this section alternatives-other than purchasing power and developing new coal- or natural gas-fired generation facilities-that were considered to ensure system energy needs are met in the event that the Ginna Station operating license is not renewed. The discussion includes the reasons why RG&E does not consider these alternatives to be reasonable or feasible for purposes of this evaluation.

7.2.3.1 Generation Alternatives In addition to coal-fired and natural gas-fired generation, representative examples of which are identified as feasible alternatives in Section 7.2.2, the NRC evaluated several other generation technologies in the GElS (Ref. 7.0-1, Chapter 8.0). RG&E has considered these options as potential alternatives to continued operation of Ginna Station and determined them to be unreasonable on the basis of economics, high land-use impacts, low capacity factors, geographic limitations, insufficiently developed technology, or other reasons. Table 7.2-1 summarizes the results of the review.

7.2.3.2 Delayed Retirement of Existing Non-nuclear Units As the NRC noted in the GElS (Ref. 7.0-1, Section 8.3.13), extending the lives of existing non-nuclear generating plants beyond the time they were originally scheduled to be retired represents another potential alternative to license renewal.

However, this option is not available to RG&E with respect to Ginna Station because Ginna Station constitutes over 50 percent of RG&E's current generating capability, and RG&E has only one other plant, the 257 MW Russell Station, that is designed for baseload service. RG&E is not aware of opportunities for delayed retirement that may be available to other energy suppliers in the State.

7.2.3.3 Conservation The history, status, and projections of energy conservation initiatives in New York are summarized by the NYSEPB (Ref. 7.2-3, Section 3.2). As noted by the Board, energy efficiency programs in New York have changed substantially in recent years as the State has transitioned to a competitive retail electricity market. The most significant early investments in energy efficiency, in the 1980s, occurred under the DSM programs implemented by investor-owned utilities in the State, including RG&E. Initial focus of these programs was on load management, then the focus broadened to include other energy efficiency measures in response to regulatory actions in the early 1990s. By 1992, DSM program offerings were diverse, ranging from rebates for residential customers (e.g., for use of off-peak power or installation of energy-efficient appliances) to financial incentives for installing high-efficiency measures in industrial facilities. Annual expenditures by investor-owned utilities in New York for DSM programs peaked at $286 million in 1992, but declined in the mid 1990s due to market conditions. In 2001, investor-owned utility expenditures for Page 7-18

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report DSM and related programs stood at $6.8 million, reflecting the transition to competitive energy markets and implementation of the SBC program as an alternative means of fostering energy efficiency in the State (Ref. 7.2-3, page 3-13).

The NYSPSC established New York's SBC in 1996. The SBC consists of a charge on electric utility transmission and distribution systems, revenues from which are used to fund public policy initiatives in the area of energy efficiency, associated research and development, and other areas that are not expected to be adequately addressed by competitive markets. Administered by NYSERDA, the SBC program thus represents a transition from utility-sponsored rebate-driven offerings to market development initiatives. Utility spending for DSM- and SBC-funded initiatives remains a minor component of energy efficiency expenditures in the State; a diverse array of programs administered by NYSERDA, public power authorities including the Long Island Power Authority and New York Power Authority, and other federal and state agencies comprise the majority of expenditures and corresponding energy savings (Ref. 7.2-3, Section 3.2).

These combined energy efficiency initiatives were estimated to reduce summer peak demand statewide by nearly 1,600 MW (roughly 5 percent of total peak demand) between 1999 and 2000, and additional peak demand reductions on the order of 900-1,300 MW are projected to result from these efforts in the 2004-2006 time frame (Ref. 7.2-3, Section 3.2). However, DSM is acknowledged in load forecasts prepared by NYISO (e.g., see Ref. 7.2-10, Table V-2) and it is expected that projected energy efficiencies would be anticipated by the market. As a practical matter, it would be impossible to increase those energy savings by an additional 500 MW to replace Ginna Station generating capability, particularly in or near RG&E's service territory, which represents a relatively small fraction of electrical load in the State. For these reasons, RG&E does not consider energy conservation to represent a reasonable alternative to renewal of the Ginna Station operating license.

Page 7-19

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report Table 7.2-1 Other Generation Technology Options Considered Alternative ConsiderationslReasons for Not Evaluating Further Wind Intermittency of adequate wind speed and expense of energy storage results in capacity factors too low for baseload generation, and land requirements are very large for 500 MW capacity (Ref. 7.0-1, Section 8.3.1).

Based on a partially complete NYSERDA study (Ref. 7.2-3, pages 3-59, 3-60), New York has the technical potential (the upper limit of renewable electricity production and capacity that could be brought online over the next 20 years, without regard to cost, market acceptability, or market constraints) for roughly 17,000 MW of installed windpower capacity, of which slightly more than 3,000 MW could be assumed to be available during summer peak hours. Although technology-specific results are not available yet, based on past experiences and studies, estimates of achievable potential are expected to fall in the range of 10-50 percent of technical potential estimates. Wind farms, the most economical wind option, consist of 10-50 turbines in the 1-3 MW range. Factors constraining the full exploitation of wind energy include land availability and land-use patterns, surface topography, offshore conditions, infrastructure constraints, environmental constraints, wind turbine capacity factor, wind turbine availability, and grid availability. From a practical perspective, the scale of this technology is too small to directly replace a power plant of the size of Ginna, and the functionality is not equivalent.

Solar Low solar resource availability in New York (e.g., less than 2.8 kWh/m2 per day in Photovoltaic RG&E's service territory, less than half of that available in the southwestern U.S.),

and Solar intermittency of this resource, and expense of energy storage results in capacity Central factors too low for practical baseline generation, and land requirements are very Receiver large. Based on estimates presented in the GELS, approximately 7,000 acres and 17,500 acres, respectively, would be required for a 500 MW solar thermal or solar photovoltaic generating facility even in areas of high solar availability (Ref. 7.0-1, Sections 8.2.3, 8.3.3).

The NYSERDA study (Ref. 7.2-3, pages 3-70, 3-71) did not evaluate central station solar technology. However, it did examine photovoltaics as a distributed resource, finding a technical potential for roughly 33,000 MW of installed photovoltaic capacity, with a summer peak contribution of roughly 8,500 MW and a winter peak contribution of about 1,500 MW. The cost of this technology was anticipated to remain quite high during the period studied, the size of the individual facilities were even smaller than the wind facilities, and the capacity factor was only slightly higher than that of wind, nowhere near comparable to nuclear.

Hydroelectric Relatively low capacity factor, large land-use requirement (e.g., inundation of approximately 500,000 acres or more could be required for a new 500 MW plant),

and ecological impacts during operation (e.g., fish impingement, entrainment) are associated with this option (Ref. 7.0-1, Section 8.3.4).

According to the NYSERDA study (Ref. 7.2-3, pages 3-61 through 3-63), future growth in hydroelectric capacity depends largely on the ability to implement public policies that eliminate or overcome legal and regulatory obstacles, often related to environmental considerations. The study identified a technical potential for approximately 7,000 MW of installed hydroelectric capacity, of which roughly one third would contribute to summer peak. Although the individual plants could be larger than wind turbines or photovoltaic installations, the capacity factor of these units would fall substantially short of wind or solar.

Page 7-20

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report Table 7.2-1 (continued)

Other Generation Technology Options Considered Alternative ConsiderationslReasons for Not Evaluating Further Geothermal As noted by the NRC, hydrothermal reservoirs in the U.S. are most prevalent in contiguous U.S. western states, Alaska, and Hawaii, and are limited in New York State (Ref. 7.0-1, Section 8.3.5).

A study commissioned by NYSERDA and the DOE, and completed in 1996, found that there is some potential for geothermal electric power production in western upstate New York, but high cost continues to inhibit its development (Ref. 7.2-21).

Biomass Biomass resources are classified as either closed-loop (grown exclusively to be used as energy feedstock) or open-loop (byproducts of the wood processing industry or clean woody waste materials retrieved from the municipal solid waste stream). The NYSERDA study (Ref. 7.2-3, pages 3-63 through 67) examined both for their ability to contribute to New York's energy needs, although certain technologies (e.g., customer-sited combined heat and power facilities burning mill residues, animal manure digesters, and wastewater methane combustors), are primarily of value for individual end-use applications. Keeping this in mind, the study identified a technical potential of approximately 1,000 MW of installed biopower capacity, essentially all of which would contribute to summer peak. Only cofiring biomass with coal offers the technical potential capacity for the entire State greater than the current capacity of Ginna Station, and as pointed out above, the economic and achievable potential are almost certain to be substantially less than the technical potential. Currently, several New York coal-fired units have or are waiting approval for roughly 10 MW of cofiring capability - far from enough capacity to replace a nuclear unit.

Municipal Solid As noted by the NRC, installed capital cost of a municipal solid-waste-fueled plant is Waste higher than that of a wood-waste-fueled plant (Ref. 7.0-1, Section 8.3.7). Use of this option is primarily a waste management decision, and tipping fees, availability of landfill space, and reduced heat content of the waste stream due to segregation and recycling of high-heat-content components (e.g., wood, paper, plastics) affects economic viability.

The NYSEPB points out in the 2002 State Energy Plan (Ref. 7.2-3, pages 3-113, 3 114) that there are ten waste-to-energy facilities operating today in New York, all of which became operational before 1994, for a total of 260 MW of installed capacity.

Incineration technology is relatively mature. However, the NYSERDA study did examine the technical potential for producing electricity from landfill gas, a byproduct of municipal solid waste when it is covered to prevent windblown litter.

Landfill gas has about half the heating value of typical natural gas. "Large" systems to take advantage of this fuel - where the quantity and location are very site-specific

- are sized in the range of 3-5 MW, for a total technical potential of approximately 19 MW of installed capacity, all of which would be available on summer peak.

Together, large and small systems would offer a total technical potential of 135 MW of installed capacity statewide.

Page 7-21

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report Table 7.2-1 (continued)

Other Generation Technology Options Considered Alternative ConsiderationslReasons for Not Evaluating Further Oil As a result of relatively high cost and air emissions concerns, use of petroleum for electric generation in New York has been reduced in recent years in favor of natural gas. NYSERDA reports that electric generation from petroleum in New York fell approximately 48 percent, from 31,911 GWh in 1986 to 15,385 GWh in 2000, even as total generation increased by 17 percent, from 129,965 GWh to 156,632 GWh during that same period (Ref. 7.2-11). Based on projections reported by the NYSEPB (Ref. 7.2-3, pages 3-120, 3-121), electric generation from oil relative to other sources is expected to decline from 5.0 percent in 2002 to 4.1 percent in 2005, and then rise again toward 7.8 percent by 2020 as overall reserve margins in the State begin to decline.

Advanced Increased interest in the development of advanced nuclear power plants has been Nuclear expressed recently by members of both industry and government. However, RG&E Reactor has no plans to construct a new nuclear power plant, and considers it unlikely that a replacement for the Ginna Station could be planned, licensed, constructed, and on line by the time the operating license expires in 2009.

DOE = U.S. Department of Energy GElS = Generic Environmental Impact Statement for License Renewal of Nuclear Plants GWh = gigawatt hours kWh = kilowatt hour(s) m = square meter(s)

MW = megawatt(s)

NRC = U.S. Nuclear Regulatory Commission NYSEPB = New York State Energy Planning Board NYSERDA = New York State Energy Research and Development Authority Ref. = Reference RG&E = Rochester Gas and Electric Corporation SBC = Systems Benefit Charge Page 7-22

R.E. Ginna Nuclear Power Plant Applicaiion for Renewed Operating License Chapter 7 Appendix E - Environmental Report 7.3 Environmental Impacts of Alternatives RG&E's evaluations of environmental impacts for the feasible generation alternatives are presented in the following sections. Section 7.3.1 addresses impacts of the purchased power alternative. Sections 7.3.2 and 7.3.3, respectively, address impacts associated with RG&E's natural gas-fired and coal-fired representative alternatives. These new generating plants would not be constructed only to operate for the period of extended operation of Ginna Station. Therefore, RG&E assumes for this analysis a design life of 30 years for the coal-fired plant, consistent with the design life established for the JEA Northside units (Ref. 7.2-12, Section 2.1.5), and a typical design life of 25 years for the combined-cycle natural gas-fired plant, and further assumes that these plants would be constructed on a schedule that would allow them to be in service in 2009 when Ginna Station would shut down.

RG&E focused its evaluation of these alternatives located at the Ginna Station site.

However, key differences in impact that could be expected as a result of locating these plants at a greenfield site are noted. Chapter 8 presents a summary comparison of the environmental impacts of license renewal and the alternatives discussed in this section.

7.3.1 Purchased Power As discussed in Section 7.2.2.1, RG&E assumes that the generating technology employed under the purchased power alternative would be one of those that the NRC analyzed in the GELS. RG&E is adopting by reference the NRC analysis of the environmental impacts from those technologies. Therefore, under the purchased power alternative, environmental impacts would still occur, but would be located elsewhere in the region, the U.S., or Canada. RG&E does not anticipate that new transmission facilities attributable to such power purchases would be needed (see Section 7.2.2.1).

7.3.2 Gas-fired Generation Potential impacts associated with RG&E's natural gas-fired representative alternative, as described in Section 7.2.2.2, are addressed in the following subsections by resource category.

Land Use Development of the representative combined-cycle natural gas-fired plant at the Ginna Station site would require approximately 30 acres of the 488-acre site, parcels of which are variously actively cultivated, cleared and maintained, open land on and near the spoil pile from plant construction, and former cropland and orchard. The 16 miles of natural gas supply pipeline required for the plant would be located on a 75-foot ROW, which would be reduced to 50 feet following construction. The ROW is assumed to be located on or adjacent to the existing transmission line ROW for most of its length. This route predominantly traverses rural agricultural land with some rural residential use along local roadways. More intensive development along Page 7-23

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report this route is confined primarily to the areas along and near New York State (NYS)

Route 104.

Current agricultural use on the site would be precluded in the area required for the plant, and some localized and mostly temporary disruption of current land use (primarily farming) may occur along the pipeline route. However, the facility would represent expansion of an existing industrial use, the land area affected would be small, and environmental reviews and approvals that would be required under Article X would act to minimize potential adverse effects on land use. RG&E considers that impact on land use from this alternative would be small.

Additional onsite acreage would likely be required to locate the representative plant at a greenfield site, and supporting offsite infrastructure could also be required.

However, these facilities would be located and designed in consideration of land-use impacts and protections afforded under Article X or comparable rules. RG&E considers that impact on land use at a greenfield site also would likely be small.

Water Use and Quality As noted in Section 7.2.2.2, cooling water intake and discharge flows for the representative gas-fired plant would be substantially lower than currently occur for the Ginna Station, even for a once-through cooling system option. Potable and service water use and other wastewater discharges would also be less and, like Ginna Station, wastewater discharges would be regulated under the federal Clean Water Act (CWA) and corresponding State programs by a State Pollutant Discharge Elimination System (SPDES) permit. Therefore, RG&E concludes that impact on water use and quality for the representative plant located at the Ginna Station site would be small. For these same reasons, RG&E concludes that impacts on water use and quality also would be small for the greenfield site alternative.

Air Quality Potential for adverse impacts to air quality from a fossil-fueled power plant are substantially different from those of a nuclear power plant as a result of the combustion process, which results in emissions of criteria pollutants including NO2 ,

SO 2, CO, and particulates, as well as carbon dioxide (C0 2), an unregulated "greenhouse gas" implicated as a potential contributor to global warming. Natural gas contains very little sulfur and other contaminants that are present in coal and oil, and is inherently a relatively clean-burning fossil fuel.

Scaling from values reported for the Wawayanda Energy Center (Ref. 7.2-19, Table 6-8) to account for assumed differences in capacity factor, approximate emission rates for principal criteria pollutants from the representative gas-fired alternative plant would be: NO,, 95 tons/year; SO 2 , 30 tons/year; PMI1 0, 110 tons/year; and (assuming use of oxidation catalysts) CO, 58 tons/year. These emissions may result in noticeable reduction in local air quality. However, these emission rates are relatively low and, as noted in Section 7.2.1.3, an offset of 1.15:1 would have to be obtained for NO) emissions, which would act to improve regional air quality with respect to this Page 7-24

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report constituent. RG&E concludes that the overall impact on air quality from this alternative, located either at the Ginna Station site or a greenfield site elsewhere in western upstate New York, would be small to moderate.

Waste Management Operation of the gas-fired alternative would generate small quantities of municipal and industrial waste, and some spent catalyst used for NO, control, a potentially hazardous waste. These wastes would be disposed of in accordance with applicable regulations at a permitted offsite disposal facility, regardless of the plant's location.

RG&E concludes that the gas-fired generation waste management disposal impacts would be small.

Ecological Resources Development of the gas-fired alternative plant at the Ginna Station site-would result in the displacement of approximately 30 acres on site. Most of this area is actively cultivated, or cleared and maintained, and offers marginal habitat value. The plant communities on remaining areas represent early successional communities on formerly disturbed areas (former cropland and orchard). These old field habitats provide food and cover for wildlife species on the site, which are typical of those in the area (see Section 2.5).

Construction of the 16-mile long gas supply pipeline using an assumed construction ROW of 75 feet could disturb up to 145 acres of terrestrial habitat. However, the permanent ROW would be reduced to 50 feet and is expected to be located on or near the existing transmission corridor from the Empire Pipeline northward to the site. Most of this area consists of active agricultural land. The remainder of the area on and near the transmission ROW consists predominantly of shrubland and scattered woodlots, which would require clearing as necessary to accommodate the pipeline. Crossing of several small tributary streams would also be required, a few of which feature associated wetlands (e.g., along tributaries of Red Creek, which joins the Erie Canal approximately 13 miles south of the Ginna Station site). RG&E expects that some minor overall reduction of forest habitat may result from the pipeline installation; however, shrubland could be restored and maintained in much of the ROW following installation, and wetland disturbance is likely to be temporary and amenable to restoration or appropriate mitigation. Stream crossing and wetland disturbance would be subject to provisions of a U.S. Army Corps of Engineers (USACE) permit (CWA Section 404), NYSDEC Protection of Waters Permit (6 NYCRR Part 608), and NYSDEC Wetlands Permit (6 NYCRR Parts 662-663), as applicable.

As noted in Sections 2.5 and 2.6, habitats on and in the vicinity of the Ginna Station site and associated transmission corridor from the site to NYS Route 104 are typical of those found in central and western upstate New York, and no threatened or endangered species are known to reside in these areas. RG&E assumes comparable conditions exist along the remainder of the assumed pipeline ROW.

Page 7-25

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report Potential impact to aquatic communities of greatest potential concern relate to operation of the cooling water system. However, the cooling system for the plant would be designed and operated in compliance with the CWA, including SPDES limitations for physical and chemical parameters of potential concern and provisions of CWA Sections 316(a) and 316(b), which are respectively established to ensure appropriate protection of aquatic communities from thermal discharges and cooling water intakes. Moreover, the cooling water intake and discharge flows would be less than for Ginna Station, the impact from which is considered to be small (see Chapter 4).

Considering the foregoing and assumed environmental protections that would be afforded in routing the natural gas pipeline, including those under Article X or a comparable program, RG&E concludes that development of the natural gas-fired plant at the Ginna Station site would have essentially no noticeable impact on ecological resources of the area, and impacts, therefore, would be small.

Impact on ecological resources from construction and operation of the natural gas fired representative plant and associated offsite infrastructure elsewhere in western upstate New York is conjectural. However, ecological resources throughout much of the area would be similar to those for the Ginna Station site alternative and the siting, design, and operation of the facility would be subject to the environmental protections noted above. RG&E concludes that the associated impact on ecological resources would be small to moderate.

Socioeconomics Major sources of potential socioeconomic impacts from the representative gas-fired generation alternative include:

" Temporary increases in jobs, economic activity, and demand for housing and public services in communities surrounding the site during the construction period, and

" Changes in permanent jobs and economic activity attributable to gas-fired plant operation and shutdown of Ginna Station.

RG&E estimates that the representative 540 MW gas-fired plant would be constructed in approximately two years with an average work force of 240 and a peak work force of 420. It is assumed that construction would take place while Ginna Station continues operation. With a large labor pool in the metropolitan area of Rochester, within 20 miles of the site, it is expected that most workers would commute and relatively few would relocate to Webster or other small communities in the area. The increase in demand for housing and public services that would result from those choosing to temporarily relocate with their families might be noticeable, but could be readily accommodated. The resulting impact is, therefore, considered to be small to moderate.

The communities surrounding the Ginna Station would realize temporary economic benefits during construction, including increased jobs and expenditures for the plant, Page 7-26

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report tax base represented by the gas-fired and the long-term benefit of a replacement would plant. After construction, the communities be impacted by the loss of some 475 jobs since the operating work force at the gas-fired plant is expected to be 25 workers as compared to the 500 permanent employees currently at Ginna Station. However, this net loss of direct jobs would take place over a period of several years as a result of decommissioning activities. As discussed in Section 3.4, 44 percent of all employees at Ginna Station resides in Monroe County, which is dominated by the Rochester metropolitan area. Considering that the Rochester metropolitan area had a year 2000 population of over one million (Ref. 7.2-22), the loss of these jobs would have a minor impact on the area. Approximately 48 percent of the current Ginna Station workforce resides in Wayne County, of which about 14 percent resides in the Town of Ontario (year 2000 population 9,778) and 8 percent resides in Williamson (year 2000 population 6,777); the remaining employees reside in 13 different communities. It is expected that the loss of jobs and reduction in general economic activity resulting from Ginna Station shutdown would be more noticeable in these local communities, but would not destabilize local economies, particularly considering proximity to the Rochester metropolitan area, which is within commuting distance of the site. In addition, the potential loss of tax revenues is expected to amount to 10 percent or less of the total annual budget of each taxing jurisdiction (see Section 2.10). The resulting impact is, therefore, considered to be small to moderate.

Transportation impacts from increased vehicular traffic associated with construction and operating personnel commuting to the site would be within the bounds of conditions currently experienced during outage periods and so would be small.

Regular workforce numbers at Ginna Station are 500, with outages increasing the number of workers by 700. During the construction period, worker numbers would increase by 240 on average and peak at 420. If an outage were to occur during the construction period, however, worker numbers could reach 1,620, resulting in moderate impacts to the local transportation network. Transportation impacts from the operating workforce of 25 for the gas-fired plant would be negligible. RG&E, therefore, concludes the overall socioeconomic impact of this alternative would be small to moderate.

Location of the gas-fired alternative at a greenfield site in western upstate New York if located outside of Wayne County would result in corresponding loss of tax revenues and employment in the area. However, based on information noted above for the Ginna site alternative, these impacts may be noticeable, but would likely not be destabilizing. The greenfield site alternative would result in a temporary increase in demand for housing and public services in the communities surrounding the selected site during the construction phase. Projection of these impacts would be conjectural and could range from small to moderate. Factors influencing the magnitude of impacts include the location of the site, its proximity to the large population centers in RG&E's service area, and the degree to which growth in the communities surrounding the plant will offset the loss of jobs once construction is completed. There would also be the temporary economic benefits of increased jobs Page 7-27

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report and expenditures for the plant and the long-term benefit of the addition of the plant to the area's tax base. The addition of the 25 employees needed to operate the plant would have small positive impacts on the surrounding communities. Therefore, these impacts would be small to moderate.

Transportation impacts associated with construction personnel commuting to a greenfield site are conjectural and would depend on the condition of the transportation network in the area chosen. The impacts associated with the operational workforce of 25 would be negligible. RG&E assumes that appropriate infrastructure accommodations would be made such that impacts from development of a gas-fired plant would be small. In conclusion, the overall socioeconomic impacts of this alternative located at a greenfield site would be small to moderate.

Human Health The NRC cites workplace accidents and inhalation of toxics and particulates associated with air emissions as potential human health risks from gas-fired generation (Ref. 7.0-1, Tables 8.1, 8.2). RG&E assumes that regulatory requirements related to occupational safety and health and air emissions are designed to protect human health and that compliance with those requirements would ensure that any associated impacts would be small.

Aesthetics Potential aesthetic impacts of construction and operation of a gas-fired plant include visual impairment resulting from the presence of a large industrial facility, including a 106-foot-high building housing the CTs and HRSGs, two 225-foot-high stacks, and potentially mechanical-draft cooling towers, approximately 60-feet high, with associated condensate plumes. The stacks and condensate plumes from the mechanical-draft cooling towers, if used, would be visible for some distance from the site. However, development of the representative gas-fired plant at the Ginna Station site would represent an incremental addition to an existing plant with similar characteristics and would be remotely located relative to major thoroughfares and residential developments. The gas supply pipeline would likely be located on or near the transmission corridor from the Empire Pipeline northward to the site and so would be routed through sparsely populated areas. Associated aesthetic impacts from the pipeline are, therefore, considered to be small. Overall, RG&E concludes that aesthetic impact from development of a gas-fired plant at the Ginna Station site would be small.

Any discussion of the potential aesthetics impact of the gas-fired alternative at a greenfield site in western upstate New York is conjectural. However, RG&E assumes the plant location and design would be subject to review under New York's Article X or a comparable program, and concludes that the impact could range from small to moderate, depending on location.

Page 7-28

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report CulturalResources The area developed for the gas-fired generating plant at the Ginna Station site would be located on previously disturbed areas, primarily agricultural land, and no archaeological or historic sites are known to exist on the plant property. RG&E assumes that the gas supply pipeline would be routed with consideration of cultural resources under New York's Article X program or a similar review and approval process, and that appropriate measures would be taken to recover or provide other mitigation for loss of any such resources discovered during onsite or offsite construction. On this basis, RG&E considers the potential adverse impact on cultural resources from this alternative to be small.

RG&E assumes that siting and development of a gas-fired plant and associated offsite infrastructure at a greenfield site would similarly consider cultural resource impacts, and that associated impacts would therefore be small.

7.3.3 Coal-fired Generation RG&E's impact evaluation for the representative coal-fired generation alternative is presented in the following subsections by resource category.

Land Use Development of the representative ACFB coal-fired plant at the Ginna Station site would require approximately 60 acres of the 488-acre site for the power block; fuel and limestone delivery, handling, and storage facilities; cooling towers (if used); and related support facilities. Under assumptions of this analysis, none of the combustion solid waste (ash and gypsum) would be used beneficially, and 260 acres would be needed for disposal of this material (see Section 7.2.2.3) for a total land requirement of approximately 320 acres. RG&E assumes that development would be confined to on-site areas north of Lake Road, possibly with additional offsite lands dedicated to these uses. RG&E estimates that approximately 75 percent of this area consists of active cropland and orchards, and most of the remainder consists of cleared and maintained areas, or recently abandoned or fallow cropland/orchards available for agricultural use. Depending on the configuration of waste disposal areas, the three farmsteads on the property could be essentially isolated and possibly abandoned; it is assumed that woodlands on the site would remain essentially intact. Under either scenario, RG&E assumes, however, that the disposal areas eventually could be restored and developed as recreational areas consistent with regional land use.

Potential for adverse impact to offsite land uses could result from delivery of coal and limestone to the plant. As noted in Section 7.2.2.3, the rail option would likely involve construction of a rail line from the CSX main line in Rochester to the site, a distance of approximately 21 miles, 18 miles of which RG&E assumes would coincide with a rail line that once provided freight service to the area. Most of this rail line is now abandoned. However, a segment of the line, from approximately 1 mile west of Webster eastward to Sodus, remains in light-duty service, including use for sight seeing tours; approximately 7 miles of this active segment would require upgrade to Page 7-29

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report accommodate deliveries to the plant. Considering the present use of this rail segment for recreation and tourism, and the developed nature of this rail corridor, particularly in and near Rochester, which includes residential areas, substantial land use conflicts are likely associated with this option. Some potential for inhibition of lakeshore recreational use could result from perceived aesthetic impairment from barge terminal facilities and associated traffic in the barge delivery option.

On the basis of the above considerations, RG&E concludes that changes in land use associated with the barge delivery option would be clearly noticeable, but would not destabilize land use in the vicinity, a characteristic of moderate impact. Substantial land-use disruption could result from the rail delivery option, and RG&E therefore considers the associated impact from the rail option to be moderate to large.

Land-use impacts from development of the plant at a greenfield site are conjectural, though additional buffer areas would be possible with a larger site (e.g., 900 acres; see Section 7.2.2.3). RG&E assumes that the facility location and design would be subject to substantial regulatory scrutiny under Article X or a comparable program, and that associated land-use impacts would be moderate.

Water Use and Quality Potential construction-phase impacts on water quality of greatest potential concern are those associated with development of infrastructure for coal and limestone delivery (e.g., navigation channel, shoreline protection, and terminal) in the event that option is chosen. Dredging, pile-driving, and related construction activities would be expected to result in suspension of bottom sediments and increased turbidity in affected areas of Lake Ontario. However, these activities would be regulated by the USACE under the CWA and Section 10 of the Rivers and Harbors Act, by the NYSDEC via permits issued under 6 NYCRR Parts 505 and 608, and by the New York Department of State under the state's Coastal Zone Management program; and adverse effects would be localized and temporary.

As noted in Section 7.2.2.3, cooling water intake and discharge flows for the representative coal-fired plant would be comparable to those for Ginna Station for a once-through system, or substantially lower for a closed-cycle system that uses cooling towers. Wastewater discharges would be similarly regulated by a SPDES permit. Therefore, RG&E concludes that the impact on water use and quality for the representative plant located at the Ginna Station site would be small. For these same reasons, and considering the environmental review of water use and quality issues afforded under Article X or an equivalent program, RG&E concludes that the impacts would be also be small for a greenfield site alternative.

Air Quality The principal air emissions from a coal-fired power plant are the same as those noted in Section 7.3.2 for the natural gas alternative, and include the criteria pollutants NO 2 , SO 2 , CO, and particulates, as well as C0 2 , which is currently unregulated. However, coal contains much higher concentrations of sulfur, and Page 7-30

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report combustion is less efficient than for natural gas. As a result, even with application of appropriate control technologies, emission of these pollutants from a coal-fired facility are typically higher than for a natural gas-fired facility of comparable size. In addition, coal contains other constituents (e.g., mercury, beryllium) that are potentially emitted as hazardous air pollutants. Of these, beryllium is considered a criteria pollutant by New York State in its ambient air quality standards (6 NYCRR Part 257).

Scaling from values reported for the JEA Northside plant (Ref. 7.2-12, Table 2.1.1) to account for assumed differences in capacity factor, approximate emission rates for principal criteria pollutants from the coal-fired alternative plant would be: NO,, 1,760 tons/year; SO 2 , 2,933 tons/year; PM 10 , 215 tons/year; and CO would be equal to or less than a proposed cap of 3,066 tons/year for the JEA Northside units. Emissions of beryllium and mercury would be less than 0.01 and 0.1 tons/year, respectively, assuming that the content of these constituents in coal used at the representative plant is substantially equivalent to typical coal used for the JEA Northside plant (Ref.

7.2-12, Table 4.1.5).

RG&E expects that these emissions would result in noticeable reduction in local air quality. However, as noted in Section 7.2.1.3, equivalent allowances for SO 2 emissions would have to be obtained and credits to more than offset NO, emissions, by a ratio of 1.15:1, would have to be obtained. Therefore, the plant would not add to regional SO 2 emissions and regional NO, emissions would be somewhat lower.

The representative plant would add to regional concentrations of other pollutants, including the criteria pollutants CO and particulates, hazardous air pollutants such as beryllium and mercury, and C0 2, a potential contributor to global warming.

RG&E concludes that the overall impact on air quality from this alternative, located either at the Ginna Station site or a greenfield site elsewhere in western upstate New York, would be moderate.

Waste Management The representative plant would produce substantial quantities of solid waste from the combustion process, consisting primarily of ash from the coal and calcium sulfate (gypsum, upon hydration). Consistent with plans for the JEA Northside plant, RG&E assumes that none of this material could be used beneficially, and that it would be disposed of in a 260-acre lined landfill (see Section 7.2.2.3). As noted by the DOE in its environmental review of the JEA Northside facility (Ref. 7.2-12, Section 4.1.7.2),

leachate from this combustion waste would not be expected to exceed applicable regulatory thresholds. Considering these waste characteristics and protections that would be afforded by a double liner and design provisions for leachate and runoff management, RG&E would not expect significant impacts to groundwater quality from the facility. Upon closure of the facility, the area eventually could be restored to other uses (e.g., recreation area) that would not compromise the landfill integrity.

Although impacts from disposal of this waste would be noticeable, it would not be expected to destabilize any important resource. RG&E concludes on this basis that Page 7-31

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report the impacts of waste disposal for the representative coal-fired plant would be moderate for both the Ginna Station site option and a greenfield location.

Ecological Resources Development of the coal-fired alternative plant at the Ginna Station site would result in the displacement of approximately 320 acres. As noted in the Land Use discussion above, approximately 75 percent of this area consists of active cropland and orchards, which has marginal habitat value. The plant communities on remaining areas consist predominantly of early successional communities on formerly disturbed areas (former cropland and orchard). These old field habitats provide food and cover for wildlife species on the site, which are typical of those in the area (see Section 2.5). With appropriate configuration of facilities on the site, RG&E assumes that mature woodlands on the site would remain intact, and that any disturbance to Deer Creek and Mill Creek would be minor.

RG&E presumes that construction of a rail line to the site under the coal and limestone rail delivery option would involve removal of some early successional plant communities on and adjacent to abandoned segments of railroad bed, primarily in the Rochester urban area. Construction of a 3-mile spur from the existing rail line into the site likely would be located near the existing Ginna Station transmission corridor and thus would traverse mostly agricultural land; however, this new construction also likely would involve some clearing of shrubland and forested habitats. As noted in Sections 2.5 and 2.6, habitats on and in the vicinity of the Ginna Station site and associated transmission corridor from the site to NYS Route 104 are typical of those found in central and western New York, and no threatened or endangered species are known to reside in these areas. RG&E assumes comparable conditions exist along the route assumed for rail delivery.

Dredging of a navigation channel, turning basin, and dockage area, and construction of related terminal facilities for barge delivery of limestone and coal would result in permanent alteration of natural shoreline and nearshore habitats. Fish and benthic communities would be initially disrupted, but would be expected to reestablish with accompanying localized changes in species composition and distribution in response to changes in bottom substrate availability, water depth, and other factors. Potential for some adverse impact on aquatic communities would persist through the operational period as a result of large boat traffic, periodic maintenance dredging, and potential for spills of coal, petroleum products, or other materials. However, construction and maintenance dredging would be conducted in accordance with the provisions of applicable permits from USACE and NYSDEC such as were noted in Section 7.3.2; similarly, spill prevention measures would be applied during the operational period.

Operation of the cooling water system for the plant is also a potential source of impact to aquatic communities. However, the cooling system for the plant would be designed and operated in compliance with the CWA, including SPDES limitations for physical and chemical parameters of potential concern and provisions of CWA Page 7-32

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report Sections 316(a) and 316(b), which are respectively established to ensure appropriate protection of aquatic communities from thermal discharges and cooling water intakes. Moreover, the cooling water intake and discharge flows would be comparable to or less than for Ginna Station, the impact from which is considered to be small (see Chapter 4).

Considering the foregoing, RG&E concludes that development of the coal-fired alternative plant at the Ginna Station site would have a small to moderate impact on ecological communities under the rail delivery option. Development of the plant under the barge delivery option would involve clearly noticeable, though localized, impacts on ecological resources in Lake Ontario, and the associated impact is therefore considered to be moderate. For the same reasons cited in Section 7.3.2, RG&E concludes that the impact on ecological resources from construction and operation of the coal-fired representative plant at a greenfield site would be small to moderate.

Socioeconomics RG&E assumes that the representative ACFB coal-fired plant would be constructed in approximately three years with a peak onsite workforce of approximately 820 workers. It is assumed that construction would take place while Ginna Station continues operation with its regular permanent workforce of 500. Considering the nearness of the Ginna Station site to the Rochester metropolitan area, few workers are likely to relocate to Webster or other smaller communities in the area, and little increased demand for housing and public services would occur. The communities in the area would easily accommodate any increase that does occur. The resulting impact is considered to be small to moderate.

As RG&E indicates in Section 7.3.2 for the representative gas-fired alternative, location of the ACFB coal-fired plant at the Ginna Station site would provide the local communities with temporary economic benefits by way of increased jobs and expenditures for the plant during the construction phase. The ACFB coal-fired plant would provide a long-term economic benefit with the replacement tax base at the Ginna Station site as well. Since the ACFB coal-fired plant would have a permanent workforce of 100 to 150, implementation of this alternative would result in the eventual net loss of about 300 jobs and the associated economic activity from the shutdown of Ginna Station. However, this net loss of jobs would take place over a period of years as a result of decommissioning activities. As discussed in Section 7.3.2, impacts on Webster and the other surrounding communities would likely be small to moderate.

Transportation impacts from location of the ACFB coal-fired plant at the Ginna Station site would be associated with the increased vehicular traffic from the construction and operating workforce commuting to the site. During construction, the peak construction workforce of 820 would be added to the Ginna Station permanent workforce of 500, totaling some 1,320 workers on site. When Ginna Station outages occur during the construction period, an additional 700 workers would be on site.

Page 7-33

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report The resulting impact on the transportation network could be moderate to large.

However, RG&E assumes that appropriate mitigation measures, which could reasonably include staggered shifts and increased traffic control during peak periods, would be employed to ensure that impacts would be maintained at moderate levels.

Transportation impacts from an operating workforce of 100-150 for the ACFB coal fired plant would be small. RG&E therefore concludes the overall socioeconomic impact of this alternative to be small to moderate.

As RG&E noted in Section 7.3.2 for the gas-fired alternative, locating the ACFB coal fired plant at a greenfield site in western upstate New York, depending on location, could result in a greater decrease in tax revenues and employment in local communities than would occur for the Ginna site option. However, for the same reasons cited in Section 7.3.2, these impacts may be noticeable, but likely not destabilizing. Location of the coal-fired plant at the greenfield site also would result in a temporary increase in demand for housing and public services in the communities surrounding the selected site during the construction phase. Projection of these impacts would be conjectural and could range from small to moderate. With the temporary economic benefit of increased jobs and expenditures for the plant, there would also be the long-term benefit of the addition of the plant to the area's tax base. The addition of approximately 100 to 150 employees to operate the coal-fired plant would have small positive impacts on the surrounding communities. The transportation impacts for the ACFB coal-fired plant located at a greenfield site in western upstate New York would be similar to those described in Section 7.3.2 for the gas-fired plant similarly located. Determination of impacts from the construction workforce, which would peak at 820 workers, would be conjectural and depend on the site chosen. These impacts could be small to large. Impacts associated with an operational workforce of as many as 150 would be less than those of the construction workforce and RG&E assumes that appropriate infrastructure accommodations would be made such that the impacts would be small. Considering the regulatory review assumed to occur under Article X or a comparable program, RG&E concludes that, overall, the socioeconomic impacts from locating the ACFB coal-fired plant at a greenfield site in western upstate New York would be small to moderate, depending on location.

Human Health In the GELS, the NRC cites risk of accidents to workers and public risks (e.g., cancer, emphysema) from the inhalation of toxics and particulates associated with air emissions as potential risks to human health associated with the coal-fired generation alternative (Ref. 7.0-1). RG&E assumes that regulatory requirements imposed on facility design and operations under the authority of the Occupational Safety and Health Act, Clean Air Act, and related statutes are designed to provide an appropriate level of protection to workers and the public with respect to these risks, and that compliance with those requirements would result in small, if any, impacts on human health, regardless of plant location.

Page 7-34

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report Aesthetics Potential aesthetic impacts of construction and operation of an ACFB coal-fired plant include visual impairment resulting from the presence of a large industrial facility (including a building housing the combustors; turbine-generators; emission control equipment; one 500-foot stack; fuel, limestone, and waste receiving/handling and storage facilities; stormwater runoff control basins; and, potentially, mechanical-draft cooling towers, approximately 100-feet high, with associated condensate plumes).

Noise and light from plant operations would be detectable off site. The stack and condensate plumes from the mechanical-draft cooling towers, if they are used, would be some distance from the plant. Development of the ACFB coal-fired plant at the Ginna Station site represents an incremental addition to an existing plant that is remotely located relative to major thoroughfares and residential developments.

However, the Ginna Station site lacks the infrastructure for delivery of coal and limestone, so it would be necessary to construct barge delivery and unloading facilities on Lake Ontario or a railway from the main CSX line in Rochester. The associated aesthetic impacts are therefore considered to be moderate to large.

Any discussion of the potential aesthetics impact of the ACFB coal-fired alternative at a greenfield site in western upstate New York is conjectural, and the impact could range from small to large, depending on location.

Cultural Resources The area developed for the coal-fired generating plant at the Ginna Station site would be located on previously disturbed areas, primarily agricultural land, and no archaeological or historic sites are known to exist on or near the plant property.

RG&E assumes that facility development would take place with appropriate consideration of cultural resources under New York's Article X program or similar review and approval process, and that appropriate measures would be taken to recover or provide other mitigation for loss of any such resources discovered during construction.

RG&E has done no detailed investigation of potential cultural resources that may exist along the assumed route for delivery of coal and limestone by rail. However, RG&E assumes all but approximately 3 miles of the 21 miles of rail required would consist of reconstruction or upgrade of an abandoned or currently used light-duty railroad line (see Land Use subsection above) and that the construction would consider and mitigate, as appropriate, related impacts to cultural resources.

Considering the foregoing, RG&E concludes that the potential impact on cultural resources would be small for the representative coal-fired plant located at the Ginna Station site under either coal and limestone delivery option. RG&E assumes that siting and development of a coal-fired plant and associated offsite infrastructure at a greenfield site would appropriately consider cultural resources under New York's Article X program or similar approval process, and that any associated impacts also would be small.

Page 7-35

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report 7.4 References Ref. 7.0-1 U.S. Nuclear Regulatory Commission. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. NUREG 1437. Office of Nuclear Regulatory Research. Washington, D.C.

May 1996.

Ref. 7.0-2 U.S. Nuclear Regulatory Commission. "Environmental Review for Renewal of Nuclear Power Plant Operating Licenses." Federal Register. Vol. 61, No. 244. (December 18, 1996): 66537-54.

Ref. 7.1-1 U.S. Nuclear Regulatory Commission. FinalGeneric Environmental Impact Statement on Decommissioning of Nuclear Facilities.

NUREG-0586. Office of Nuclear Regulatory Research. Washington, D.C. August 1988.

Ref. 7.2-1 New York Independent System Operator. 2001 Load and Capacity Data. Accessible at http:l/www.nyiso.com/servicesldocuments/plannincqlpdf/2001 -gold b ook.pdf.

Ref. 7.2-2 New York State Energy Planning Board. Annual Report to the New York State Energy Plan and Final EnvironmentalImpact Statement.

March 2001. Accessible at http://www.nvserda.orqlsep.html.

Ref. 7.2-3 New York State Energy Planning Board. New York State Energy Plan and Draft EnvironmentalImpact Statement. June 2002.

Accessible at http'//www.nyserda.org/sep.html.

Ref. 7.2-4 New York State Energy Research and Development Authority.

"About NYSERDA." http://www.nyserda.orq/about.html. Accessed June 5, 2002.

Ref. 7.2-5 New York State Energy Research and Development Authority. "New York Energy $mart TM ." http://www.nvserda.orq/enerqvsmart.html.

Accessed June 5, 2002.

Ref. 7.2-6 New York State Reliability Council. "New York State Reliability Council -Welcome." http://www.nysrc.orqlabout.html. Accessed June 5, 2002.

Ref. 7.2-7 New York Independent System Operator. New York Independent System OperatorStatement of Energy Policies,Planning Objectives, and Strategies for New York State Energy Plan. September 21, 2000. Accessible at http://www.nyiso.com/services/documents/plannincq .html.

Page 7-36

R.E. Ginna Nuclear Power Plant Applicati6n for Renewed Operating License Chapter 7 Appendix E - Environmental Report Ref. 7.2-8 New York State Public Service Commission. Guide to the CertificationReview Processfor MajorElectric GeneratingFacilities Under Article X of the New York State Public Service Law. Board on Electric Generation Siting and the Environment. February 11, 2002.

http://www.dps.state.ny.us/articlex process.html. Accessed June 6, 2002.

Ref. 7.2-9 Energy Information Administration. Electric PowerAnnual 2000:

Volume 1. DOE/EIA-0348(2000)/1. Office of Coal, Nuclear, Electric and Alternate Fuels. Washington, D.C. August 2001. Accessible at http:l/www.eia.doe..qovlcneaf/electricitylepavl /epavl sum.html.

Ref. 7.2-10 New York State Energy Research and Development Authority.

Patternsand Trends - New York State Energy Profiles: 1986-2000.

Albany, New York. December 2001. Accessible at http://www.nvserda.orqlenerqvinfo.html.

Ref. 7.2-11 New York State Board on Electric Generation Siting and the Environment. Department of Public Service Article X Cases.

Revised May 30, 2002. Accessible at http:l/www.dps.state.nv.us/xtable.PDF.

Ref. 7.2-12 U.S. Department of Energy. FinalEnvironmentalImpact Statement for the JEA CirculatingFluidized Bed Combustor Project, Jacksonville, Florida. DOE/EIS-0289. June 2000.

Ref. 7.2-13 Environmental News Network. "New 'Clean Coal' Power Plant Set for Pennsylvania." July 31, 2001. Accessible at http:l/www.enn.com/news/enn-stories/20011/07107312001/

coal 44470.asp.

Ref. 7.2-14 U.S. Department of Energy. "JEA Large-Scale CFB Combustion Demonstration Project." Project Fact Sheet. Office of Fossil Energy.

http:l/www.lanl.qov/proiects/cctc/factsheets/iacksliackeademo.html.

Accessed May 25, 2002.

Ref. 7.2-15 U.S. Department of Energy. The JEA Atmospheric Fluidized Bed Clean Coal Project, Repowering Northside Units I and 2. National Energy Technology Laboratory, Pittsburgh, PA. October 2001.

Accessible at http://www.lanl..ov/proiects/cctc/resources/librarv/bibliocqraphy/demo nstration/aepqlbaepcqfb iackea.html#proqram.

Ref. 7.2-16 Ducan, J. JEA. Current Status - JEA Northside Atmospheric Fuidized Bed Combustion (AFBC) Project. Personal communication with G. DeCamp. July 22, 2002.

Ref. 7.2-17 New York State Energy Planning Board. Report on the Reliability of New York's Electric Transmission and DistributionSystems.

November 2000. Accessible at http://www.nyserda.orq/t&dreport.pdf.

Page 7-37

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 7 Appendix E - Environmental Report Ref. 7.2-18 Sanford, M., V. Banunarayanan, and K. Wirgau. Implications of CapacityAdditions in New York on Transmission System Adequacy.

MAPS study performed for the New York Independent System Operator. Rev. 2, March 2, 2001. Accessible at httD:l/www.nviso.com/services/plannina .html#tpr.

Ref. 7.2-19 Wawayanda Energy Center. LLC (Calpine). Article XApplication for Wawayanda Energy Center. New York State Department of Public Service Case No. 00-F-1256. August 27, 2001. Accessible at http://www.wawayanda-enercqy.com/pacqes/frame.html.

Ref. 7.2-20 Energy Information Administration. Cost and Quality of Fuels for Electric Utility Plants 2000 Tables: Table 24, "Origin of Coal Received by Electric Utility and Plant, 2000." DOE/EIA-0191(00).

August 2001. Accessible at http://www.eia.doe.qov/cneaf/electricitv/cq/cq sum.html Ref. 7.2-21 New York State Energy Research and Development Authority.

Renewable & Indigenous Energy R&D Program- Indigenous Resources.

http:llwww.nvserda.org/energyresources/indiqenous.html. Accessed October 7, 2001.

Ref. 7.2-22 U.S. Census Bureau. Table DP-1, "Profile of General Demographic Characteristics: 2000." Geographic Area: Rochester, NY MSA.

http'//www.census.qov. Accessed July 12, 2002.

Page 7-38

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 8 Appendix E - Environmental Report 8.0 COMPARISON OF ENVIRONMENTAL IMPACT OF LICENSE RENEWAL WITH THE ALTERNATIVES NRC' "To the extent practicable, the environmental impacts of the proposal and the alternativess should be presented in comparative form ...... 10 CFR 51.45(b)(3) as, adopted by 51.53(c)(2),

Rochester Gas and Electric Corporation's (RG&E's) evaluations of the environmental impacts associated with the R.E Ginna Nuclear Power Plant (Ginna Station) operating license renewal (the proposed action) are presented in Chapter 4, and those associated with the selected alternatives are described in Chapter 7. This chapter provides a comparative summary of these environmental impacts. The comparison addresses Category 2 issues associated with the proposed action and issues the U.S. Nuclear Regulatory Commission (NRC) identifies in the Generic EnvironmentalImpact Statement for License Renewal of Nuclear Plants (GELS)

(Ref. 8.0-1, Section 8.1) as major considerations in an alternatives analysis. For example, the NRC concluded in the GElS that air impacts from the proposed action would be small (Category 1), but indicated that there is a potential for major human health concerns associated with air emissions from fossil-fuel generation alternatives (see Section 7.2.1.3).

RG&E provides a comparative summary of its conclusions regarding these issues in Table 8.0-1, and a more detailed comparison in Table 8.0-2.

Page 8-1

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 8 Appendix E - Environmental Report Table 8.0-1 Impacts Comparison Summary No-Action Alternative Proposed Action Base With Coal- With Gas- With (License (Decommis- Fired Fired Purchased Impact Renewal) sioning) Generation Generation Power Land Use SMALL SMALL MODERATE SMALL All impacts are to LARGE dependent on Water Use and SMALL SMALL SMALL SMALL generation Quality technologies used and location Air Quality SMALL SMALL MODERATE SMALL to but would be MODERATE comparable to Waste Management SMALL SMALL MODERATE SMALL the alternatives Ecological Resources SMALL SMALL SMALL to SMALL addressed in MODERATE Section 8.3 of the GELS.

Socioeconomics SMALL SMALL SMALL to SMALL to MODERATE MODERATE Transportation SMALL SMALL SMALL to SMALL MODERATE Human Health SMALL SMALL SMALL SMALL Aesthetics SMALL SMALL MODERATE SMALL to LARGE Cultural Resources SMALL SMALL SMALL SMALL SMALL - Environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource.

MODERATE - Environmental effects are sufficient to alter noticeably but not to destabilize any important attribute of the resource.

LARGE - Environmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource (10 CFR 51, Subpart A, Appendix B, Table B-I, footnote 3).

Page 8-2

C (

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 8 Appendix E - Environmental Report Table 8.0-2 Impacts Comparison Detail No-Action Alternative Proposed Action Base With Coal-Fired With Gas-Fired (License Renewal)a (Decommissioning) a Generation Generation With Purchased Power Description Ginna Station license renewal Decommissioning New construction at New construction at Adopting by reference for 20 years, followed by following expiration of Ginna Station site. Plant Ginna Station site. Plant NRC description in the decommissioning (see current Ginna Station characteristics as follows characteristics as follows GElS of alternate Chapter 3). license. Adopting, by (see Section 7.2.2.3): (see Section 7.2.2.2): technologies (see reference, NRC Two 265 MW (net) One combined-cycle Section 7.2.1.3).

description in the GElS atmospheric circulating 540 MW (nominal) unit; as bounding Ginna fluidized-bed combustion consisting of two decommissioning (see units; capacity factor 0.8. 180 MW combustion Section 7.1). Either once-through turbines and a 180 MW cooling or closed-cycle steam turbine generator; cooling with mechanical capacity factor 0.8.

draft cooling towers. Either once-through Assumed fuel pulverized cooling or closed-cycle bituminous coal; 13,233 cooling with mechanical Btu/pound; 7.35% ash; draft cooling towers or 2.22% sulfur. Fuel air-cooled condensers.

consumption 1.4 million Natural gas consumption:

tons coal/yr. Delivery of 27 billion scf/yr. Delivery coal and limestone via via new 16-mile-long barge and newly pipeline on 50-foot-wide constructed barge ROW (75-foot-wide for terminal, or by rail via 18 construction).

miles of reconstructed/ Dry-low NO, combustor; upgraded line and new selective catalytic 3-mile-long spur. reduction. PM and CO Selective noncatalytic emissions limited through reduction for NO, control. proper combustion controls. Exhaust from Page 8-3

C ( R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 8 Appendix E - Environmental Report Table 8.0-2 (continued)

Impacts Comparison Detail No-Action Alternative Proposed Action Base With Coal-Fired With Gas-Fired (License Renewal)a (Decommissioning)' Generation Generation With Purchased Power Description (continued)

Fabric filtration (99.8% combustion turbines removal efficiency) for dispersed through two particulate control. 225-foot-tall stacks.

Limestone addition and, Construction work force:

if needed, polishing 240 average, 420 peak.

scrubber (98% removal Additional operating work efficiency for SO 2). force: 25.

Emissions dispersed through single 500-foot tall stack.

Peak construction work force: 820. Operating work force: 150.

Land Use Impacts SMALL - Adopting by SMALL - Not an impact MODERATE to LARGE - SMALL - Approximately Impact dependent on reference applicable NRC evaluated in the GElS Approximately 320 acres 30 acres of land generation technology findings for GElS Category 1 (Ref. 8.0-1, Section 7.3). of land converted to converted to industrial and location. Adopting issues (Issues 52, 53). industrial use at existing use at existing plant site. by reference NRC plant site, including 60 Sixteen miles of natural- description in the GElS acres for power block gas supply pipeline to be of land use impacts from and related support constructed through rural alternate technologies facilities and 260 acres agricultural land on (Ref. 8.0-1, Section 8.3).

for waste disposal. 50-foot-wide constructed Construction of 21 miles ROW (see Section of rail line (18 miles on 7.3.2).

abandoned or existing rail corridor), which traverses some urban Page 8-4

( R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 8 Appendix E - Environmental Report Table 8.0-2 (continued)

Impacts Comparison Detail No-Action Alternative Proposed Action Base With Coal-Fired With Gas-Fired (License Renewal) a (Decommissioning) a Generation Generation With Purchased Power Land Use Impacts (continued) residential and recreational areas, could result in large land use impact (see Section 7.3.3).

Water Use and Quality Impacts SMALL - Adopting by SMALL - Adopting by SMALL - Construction SMALL - Construction Impact dependent on reference applicable NRC reference applicable impacts reduced by use impacts minimized by generation technology findings for GElS Category I NRC finding for GElS of best management use of best management and location. Adopting issues (Issues 3, 5-12). No Category 1 issue (Issue practices and regulatory practices and regulatory by reference NRC applicable Category 2 issues. 89). No Category 2 controls. Operation- controls. Operation- description in the GElS issues. phase impacts similar to phase impacts less than of water quality impacts or less than those of those of Ginna Station from alternate Ginna Station (see (see Section 7.3.2). technologies (Ref. 8.0-1, Section 7.3.3). Section 8.3).

Air Quality Impacts SMALL - Adopting by SMALL - Adopting by MODERATE - SMALL to MODERATE - Impact dependent on reference applicable NRC reference applicable

• 2,933 tons S0 2/yr 9 30 tons S0 2/yr generation technology findings for GElS Category 1 NRC finding for GElS

• 1,760 tons NO/yr 9 95 tons NO/yr and location. Adopting issue (Issue 51). No Category 1 issue (Issue

• 1,066tonsNO/yr

• 5 tons NO/yr by reference NRC applicable Category 2 issues. 88). No Category 2 * <3,066 tons CO/yr

• 58 tons CO/yr description in the GElS issues. o 215 tons PM 10/yr 9 110 tons PM 10/yr of air quality impacts (see Section 7.3.3). (see Section 7.3.2). from alternate technologies (Ref. 8.0-1, Section 8.3).

Page 8-5

( ( R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 8 Appendix E - Environmental Report Table 8.0-2 (continued)

Impacts Comparison Detail No-Action Alternative Proposed Action Base With Coal-Fired With Gas-Fired (License Renewal)' (Decommissioning) Generation Generation With Purchased Power Waste Management Impacts SMALL - Adopting by SMALL - Adopting by MODERATE - Waste SMALL -Relatively low Impact dependent on reference applicable NRC reference applicable disposed of on site in a waste generation (see generation technology findings for GElS Category I NRC finding for GElS 260-acre lined landfill Section 7.3.2). and location. Adopting issues (Issues 77-84). No Category 1 issue (Issue (see Section 7.3.3). by reference NRC Category 2 issues. 87). No Category 2 description in the GElS issues. of waste management impacts from alternate technologies (Ref. 8.0-1, Section 8.3).

Ecological Resource Impacts SMALL - Adopting by SMALL - Adopting by SMALL to MODERATE- SMALL - Loss of 30 Impact dependent on reference applicable NRC reference applicable Loss of 320 acres, acres of mostly actively generation technology findings for GElS Category 1 NRC finding for GEIS approximately 75% of cultivated or cleared land and location. Adopting issues (Issues 15-24, 45-48). Category 1 issue (Issue which consists of on site. Potential for by reference NRC Ginna Station has a current 90). No Category 2 cropland and orchards. impacts to aquatic description in the GElS New York SPDES permit, issues. Rail delivery option: ecology reduced by best of ecological resource which constitutes compliance construction of 3-mile- management practices impacts from alternate with CWA Section 316(b) long spur to existing rail and regulatory controls. technologies (Ref. 8.0-1, requirements to provide best line likely to involve minor Cooling water discharge Section 8.3).

available technology to clearing of shrubland and impacts comparable to or minimize entrainment and forested habitats. less than those for Ginna impingement (see Section Barge delivery option: Station (see Section Dredging of navigation 7.3.2).

4.2.1, Issue 25; Section 4.2.2, Issue 26). channel, turning basin, The NYSDEC has approved dockage area, and the Ginna Nuclear Power related construction Plant 316(a) Demonstration, induced alteration of which analyzed the potential shoreline and nearshore Page 8-6

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 8 Appendix E - Environmental Report TABLE 8.0-2 (continued)

Impacts Comparison Detail No-Action Alternative Proposed Action Base With Coal-Fired With Gas-Fired (License Renewal)3 (Decommissioning) a Generation Generation With Purchased Power Ecological Resource Impacts (continued) for heat shock and found no habitats; continued problem (see Section 4.3, disturbance during Issue 27). operation from Impacts to threatened and maintenance dredging, endangered species expected barge traffic. Potential to be small due to low for impacts to aquatic potential for occurrence in ecology reduced by best habitats affected by plant management practices operation and lack of and regulatory controls.

observed impacts during Cooling water intake- and operational monitoring (see discharge-related Section 4.5, Issue 49). impacts comparable to or less than those for Ginna Station (see Section 7.3.3).

Socioeconomic Impacts SMALL - Adopting by SMALL - Adopting by SMALL to MODERATE - SMALL to MODERATE - Impact dependent on reference applicable NRC reference applicable Increased demand for Increased demand for generation technology findings for GElS Category 1 NRC finding for GElS public services from public services from and location. Adopting issues (Issues 64, 67). Category 1 issue (Issue nearby communities nearby communities by reference NRC 91). No Category 2 during construction, and during construction, and description in the GElS Location in area of high issues. net loss of jobs in net loss of jobs in of socioeconomic population minimizes potential for housing impacts (see Webster and surrounding Webster and surrounding impacts from alternate Section 4.8.2, Issue 63). communities with communities with technologies (Ref. 8.0-1, associated reduction in associated reduction in Section 8.3).

Tax-driven land-use changes economic activity from economic activity from would be small given that the shutdown of Ginna shutdown of Ginna county has an established Station may result in Station may result in development pattern and is Page 8-7

( C R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 8 Appendix E - Environmental Report TABLE 8.0-2 (continued)

Impacts Comparison Detail No-Action Alternative Proposed Action Base With Coal-Fired With Gas-Fired (License Renewal)' (Decommissioning) a Generation Generation With Purchased Power Socioeconomic Impacts (continued) growing at a relatively slow noticeable, but not noticeable, but not rate (see Section 4.11.2, Issue destabilizing, impacts destabilizing, impacts 69). (see Section 7.3.3). (see Section 7.3.2).

Capacity of public water supply minimizes potential for related impacts (see Section 4.9, Issue 65).

Transportation Impacts SMALL - Adopting by SMALL - Not an impact SMALL to MODERATE - SMALL - Temporary Impact dependent on reference applicable NRC evaluated in the GElS Temporary increase in increase in traffic of 420 generation technology finding for GElS Category 1 (Ref. 8.0-1, Section 7.3). traffic of 820 (maximum) (maximum) vehicle and location. Not an issue (Issue 85). vehicle round-trips per round-trips per day impact evaluated in the Traffic capacity of NYS day during construction. during construction. GELS.

Route 104 and secondary Operating workforce of Negligible impacts from roads providing access to 100 to 150 would result operational workforce of Lake Road minimizes in small impacts (see 25 (see Section 7.3.2).

potential for transportation Section 7.3.3).

impacts (see Section 4.12, Issue 70).

Human Health Impacts SMALL - Adopting by SMALL - Adopting by SMALL- Some risk of SMALL - Same as for Impact dependent on reference applicable NRC reference applicable cancer and emphysema coal-fired alternative (see generation technology findings for GElS Category 1 NRC finding for GElS from air emissions and Section 7.3.2). and location. Adopting issues (Issues 56, 58, 61, 62). Category 1 issue risk of accidents to by reference NRC SMALL - Water temperatures (Issue 86). No workers, as the NRC description in the GElS would not support viable Category 2 issues. notes in the GEIS. of human health impacts from alternate Page 8-8

( R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 8 Appendix E - Environmental Report TABLE 8.0-2 (continued)

Impacts Comparison Detail No-Action Alternative Proposed Action Base With Coal-Fired With Gas-Fired (License Renewal) a (Decommissioning) a Generation Generation With Purchased Power Human Health Impacts (continued) populations; thereby, Regulatory controls technologies (Ref. 8.0-1, minimizing public health assumed to reduce risks Section 8.3).

impacts from thermophilic to acceptable levels (see microbiological organisms Section 7.3.3).

(see Section 4.15, Issue 57).

Risk due to transmission line induced currents minimal due to conformance with National Electric Safety Code criteria (see Section 4.7, Issue 59).

Aesthetic Impacts SMALL - Adopting by SMALL - Not an impact MODERATE to LARGE - SMALL - No significant Impact dependent on reference applicable NRC evaluated in the GElS Construction and aesthetic impacts generation technology findings for GElS Category 1 (Ref. 8.0-1, Section 7.3). operation of new barge anticipated for and location. Adopting issues (Issues 73,74). No delivery and unloading development at Ginna by reference NRC Category 2 issues. facilities on site, or Station site (see description in the GElS railway line to Rochester Section 7.3.2). of aesthetic impacts from may result in significant alternate technologies aesthetic impacts (see (Ref. 8.0-1, Section 8.3).

Section 7.3.3).

Page 8-9

C R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 8 Appendix E - Environmental Report TABLE 8.0-2 (continued)

Impacts Comparison Detail No-Action Alternative Proposed Action Base With Coal-Fired With Gas-Fired (License Renewal) 0 (Decommissioning) a Generation Generation With Purchased Power Cultural Resource Impacts SMALL - Lack of cultural SMALL - Not an impact SMALL - No known SMALL - Same as coal- Impact dependent on resources and SHPO evaluated in the GElS cultural resources in fired alternative (see generation technology consultation minimize (Ref. 8.0-1, Section 7.3). affected onsite areas; Section 7.3.2). and location. Adopting potential for impact (see mitigation measures, if by reference NRC Section 4.13, Issue 71). necessary, would description in the GElS minimize impact (see of cultural resource Section 7.3.3). impacts from alternate technologies (Ref. 8.0-1, Section 8.3).

a. See Appendix A, Table A.1-1, for a list of issues and applicability.

Impact Definitions:

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

MODERATE - Environmental effects are sufficient to alter noticeably but not to destabilize any important attribute of the resource.

LARGE - For the issue, environmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource.

(10 CFR 51, Subpart A, Appendix B, Table B-I, footnote 3).

<= less than or equal to NYSDEC = New York State Department of Environmental

= percent Conservation Btu = British thermal unit PM = particulate matter CO = carbon monoxide PM10 = filterable particulates having diameter less than 10 microns CWA = Clean Water Act ROW = right-of-way GElS = Generic EnvironmentalImpact Statement scf = standard cubic feet for License Renewal of Nuclear Plants (Ref. 8.0-1) SHPO = State Historic Preservation Officer MW = megawatt(s) SO 2 = sulfur dioxide NOx = nitrogen oxide(s) SPDES = State Pollutant Discharge Elimination System NRC = U.S. Nuclear Regulatory Commission yr = year NYS = New York State Page 8-10

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 8 Appendix E - Environmental Report 8.1 References Ref. 8.0-1 U.S. Nuclear Regulatory Commission. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. NUREG 1437. Office of Nuclear Regulatory Research. Washington, D.C.

May 1996.

Page 8-11

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 9 Appendix E - Environmental Report 9.0 STATUS OF COMPLIANCE 9.1 Proposed Action NRC "The environmental report shall list all Federal permits, licenses, approvals and other entitlements which must be obtained in connection with the proposed acton and shall describe the status of compliance with these requirements. The environmental report shall also include a discussion of the status of compliance witwith applicable environmental quality standards and requirements including, but not limited to",applicable zoning and land-use regulations, and thermal and other~water p pollution limitations or requirements which have been imposed by Federal, State,,

regional,"and local agencies having responsibility for environmental protection."

10 CFR 51 .45(d), as require'd-by 10"CFR' 51.53(c)(2) 9.1.1 General Table 9.1-1 lists environmental authorizations that Rochester Gas and Electric Corporation (RG&E) has obtained for current R.E. Ginna Nuclear Power Plant (Ginna Station) operations. In this context, RG&E uses "authorizations" to include any permits, licenses, approvals, or other entitlements. RG&E expects to continue renewing these authorizations during the current license period and throughout the proposed license renewal period. Based on the new and significant information identification process described in Chapter 5, RG&E concludes that Ginna Station is in compliance with applicable environmental standards and requirements.

Table 9.1-2 lists additional environmental authorizations and consultations related to U.S. Nuclear Regulatory Commission (NRC) renewal of the Ginna Station license to operate. As indicated, RG&E anticipates needing relatively few such authorizations and consultations. Sections 9.1.2 through 9.1.5 discuss some of these items in more detail.

9.1.2 Threatened or Endangered Species Section 7 of the Endangered Species Act (16 USC 1531 et seq.) requires federal agencies to ensure that agency action is not likely to jeopardize any species that is listed or proposed for listing as endangered or threatened. Depending on the action involved, the Act requires consultation with the U.S. Fish and Wildlife Service (FWS) regarding effects on non-marine species, the National Marine Fisheries Service (NMFS) for marine species, or both. FWS and NMFS have issued joint procedural regulations, at 50 CFR 402, Subpart B, that address consultation, and FWS maintains the joint list of threatened and endangered species at 50 CFR 17.

Although not required of an applicant by federal law or NRC regulation, RG&E has chosen to invite comment from federal and state agencies regarding potential effects that Ginna Station license renewal might have. Appendix C includes copies of RG&E correspondence with FWS and the New York State Department of Environmental Conservation (NYSDEC). RG&E did not consult with NMFS because species under the auspices of NMFS are not known to be in the Ginna Station vicinity.

Page 9-1

( R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 9 Appendix E - Environmental Report Table 9.1-1 Environmental Authorizations for Current Operations Expiration Agency Authority Requirement Number Date Authorized Activity New York State Department NYS ECL Part 675 Water Withdrawal NYGLWR- 07/10/02a Withdraw water from Lake of Environmental Registration 0002810 Ontario Conservation State of Tennessee Tennessee Code Annotated Radioactive Shipment T-NY004-L01 12/31/02 Shipment of radioactive Department of Environment 68-202-206 License material to a licensed and Conservation disposal/processing facility within Tennessee Utah Department of R313-26 of the Utah Utah Department of 0109 000 005 06/30/03 Delivery of radioactive Environmental Quality Radiation Control Rules Environmental Quality wastes to a land disposal Division of Radiation facility located within Utah Control Generator Site Access Permit Accessing A Land Disposal Facility Within Utah South Carolina Department Act No. 429 of 1980 (South South Carolina 0034-31-01 12/31(02 Transport of radioactive of Health and Environmental Carolina Radioactive Waste Radioactive Waste waste into South Carolina Control Transportation and Disposal Transport Permit Act)

New York State Department NYS ECL 11-0515 (1), New York State Fish and LCP01-756 12/31/02 Collection and possession of Environmental NYCRR Part 175 Wildlife License of fish and wildlife Conservation New York State Department NYS ECL Article 40 Hazardous Substance Bulk 8-000170 07/18/03 Registration of hazardous of Environmental Storage Registration substance bulk storage Conservation Certificate on site New York State Department NYS ECL Title 8 of Article 17 State Pollution Discharge NY-0000493 02/01/03 Discharge of wastewaters of Environmental Elimination System to waters of the State Conservation (SPDES) Permit U.S. Department of 49 CFR Part 107, Subpart G Certificate of Registration 06200255003K 06/30/03 Transportation of Transportation for Transportation of hazardous materials Hazardous Materials Page 9-2

C R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 9 Appendix E - Environmental Report Table 9.1-1 (continued)

Environmental Authorizations for Current Operations Expiration Agency Authority Requirement Number Date Authorized Activity U.S. Nuclear Regulatory Atomic Energy Act (42 USC Facility Operating License DPR-18 09/18/09 License to operate a Commission 2011 et seq.), 10 CFR 50.10 nuclear power plant

a. Registration renewal submitted June 24, 2002.

Page 9-3

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 9 Appendix E - Environmental Report Table 9.1-2 Environmental Authorizations for License Renewala Agency Authority Requirement Remarks U.S. Nuclear Regulatory Atomic Energy Act (42 License renewal Environmental report Commission USC 2011 et seq.) submitted in support of license renewal application U.S. Fish and Wildlife Endangered Species Consultation Requires federal agency Service Act, Section 7 (16 USC issuing a license to consult 1536) with FWS (see Appendix C)

New York State Clean Water Act, Certification SPDES permit documents Department of Section 401 (33 USC compliance with Clean Environmental 1341) Water Act standards Conservation New York State Office National Historic Consultation Requires federal agency of Parks, Recreation, Preservation Act, issuing a license to consider and Historic Section 106 (16 USC cultural impacts and consult Preservation 470f) with State Historic Preservation Officer (see Appendix D)

New York State Federal Coastal Zone Certification Requires an applicant to Department Of State Management Act (16 provide certification to the USC 1451 et seq.) federal agency issuing the license that license renewal would be consistent with the federally approved state coastal zone management program; based on its review of the proposed activity, the State must concur with or object to the applicant's certification (see Appendix F)

a. No renewal-related requirements identified for local or other agencies.

Page 9-4

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 9 Appendix E - Environmental Report Based on the RG&E submittals and other information, as discussed in detail in Section 4.5, the agencies concur with the RG&E conclusion that Ginna Station license renewal would not adversely affect threatened or endangered species or critical habitat.

9.1.3 Coastal Zone Management Program Compliance The Federal Coastal Zone Management Act (16 USC 1451 et seq.) imposes requirements on applicants for a federal license to conduct an activity that could affect a state's coastal zone. The Act requires the applicant to certify to the licensing agency that the proposed activity would be consistent with the state's federally approved coastal zone management program [16 USC 1456(c)(3)(A)]. The National Oceanic and Atmospheric Administration has promulgated implementing regulations indicating that the requirement is applicable to renewal of federal licenses for activities not previously reviewed by the state [15 CFR 930.51(b)(1)]. The regulation requires that the license applicant provide its certification to the federal licensing agency and a copy to the applicable state agency [15 CFR 930.57(a)].

The NRC office of Nuclear Reactor Regulation has issued guidance to its staff regarding compliance with the Act. This guidance acknowledges that New York has an approved coastal zone management program (Ref. 9.1-1). Ginna Station, located in Wayne County, is within the New York coastal zone. Concurrent with submitting the "Applicant's Environmental Report - Operating License Renewal Stage" to the NRC, RG&E submitted a copy of the environmental report to the New York Department of State Coastal Zone Management Program in fulfillment of the regulatory requirement for submitting a copy of the coastal zone consistency certification to the appropriate state agency.

9.1.4 Historic Preservation Section 106 of the National Historic Preservation Act (16 USC 470 et seq.) requires federal agencies having the authority to license any undertaking to, prior to issuing the license, take into account the effect of the undertaking on historic properties and to afford the Advisory Committee on Historic Preservation an opportunity to comment on the undertaking. Committee regulations provide for establishing an agreement with any State Historic Preservation Officer (SHPO) to substitute state review for Committee review (35 CFR 800.7). Although not required of an applicant by federal law or NRC regulation, RG&E has chosen to invite comment by the New York SHPO. Appendix D includes copies of RG&E correspondence with the SHPO regarding potential effects that Ginna Station license renewal might have on historic or cultural resources.

Based on the RG&E submittal and other information, as discussed in detail in Section 4.13, the New York SHPO concurred with RG&E's conclusion that Ginna Station license renewal would not affect known historic or archaeological properties.

9.1.5 Water Quality (401) Certification Federal Clean Water Act Section 401 requires applicants for a federal license to conduct an activity that might result in a discharge into navigable waters to provide Page 9-5

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 9 Appendix E - Environmental Report the licensing agency a certification from the state that the discharge will comply with applicable Clean Water Act requirements (33 USC 1341). The NRC has indicated in its Generic Environmental Impact Statement for License Renewal of NuclearPlants (GELS) that issuance of a National Pollutant Discharge Elimination System (NPDES) permit implies certification by the state (Ref. 9.1-2, page 4-4). The U.S.

Environmental Protection Agency granted New York State authority to issue NPDES permits under its own program, the New York State Pollutant Discharge Elimination System (SPDES). RG&E is applying to the NRC for a license renewal to continue Ginna Station operations. Appendix B contains the Ginna Station SPDES permit, which authorizes plant discharges. Consistent with the GElS, Ginna Station is providing the copy of its SPDES permit as evidence of state water quality (401) certification.

The most recent NYSDES SPDES inspection, conducted on March 20, 2002, found Ginna Station to be in compliance with the permit. As identified in Table 9.1-1, the Ginna Station SPDES permit will expire on February 1, 2003. In accordance with SPDES regulations, the Ginna SPDES permit renewal application will be filed at least 180 days prior to current permit expiration.

As part of RG&E's communication with regulatory agencies and interested parties concerning the Ginna License Renewal environmental review, the NYSDEC provided comments concerning entrainment and impingement at Ginna Station.

The NYSDEC comments pertaining to entrainment can be summarized as requesting an updated study of in-plant entrainment. RG&E acknowledges the value of such a study, and agrees to work with NYSDEC to include a mutually acceptable program within the on-going Ginna SPDES Permit.

The NYSDEC comments pertaining to impingement are summarized below.

1. Previous impingement reports should be utilized to summarize Ginna potential impact to Lake Ontario fish populations.

2. Gobies should be added as a target species within the impingement program.

3. Yellow perch should remain a target species within the impingement program.

4. Impingement mitigation requirements contained within the current SPDES Permit have been met.

5. The NYSDEC has reviewed the current traveling water screen replacement program, and agrees that such an upgrade is acceptable to meet Best Technology Available standards.

As part of the current SPDES program, RG&E has incorporated items 1, 2, and 3 above into the annual Fish Impingement Program Report required by the current Ginna SPDES Permit (Ref. 9.1-3).

Page 9-6

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 9 Appendix E - Environmental Report 9.2 Feasible Alternatives The coal- and gas-fired generation and purchase power alternatives that Section 7.2.2 discusses probably could be constructed and operated so as to comply with all applicable environmental quality standards. RG&E notes that increasingly stringent air quality protection requirements could make construction of a large fossil-fuel-fired power plant infeasible in many locations.

Although construction and operation details for the purchase power alternative (see Section 7.2.2.1) are not known, it is reasonable to assume that any facility offering power for purchase would be in compliance.

Page 9-7

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Chapter 9 Appendix E - Environmental Report 9.3 References Ref. 9.1-1 U.S. Nuclear Regulatory Commission. "Procedural Guidance for Preparing Environmental Assessments and Considering Environmental Issues." NRR Office Instruction LIC-203. Office of Nuclear Reactor Regulation. Washington, D.C. June 21, 2001.

Ref. 9.1-2 U.S. Nuclear Regulatory Commission. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. NUREG 1437. Office of Nuclear Regulatory Research. Washington, D.C.

May 1996.

Ref. 9.1-3 Rochester Gas and Electric Corporation. Fish Impingement Program, 1997-2001 Analysis Report, Ginna NuclearPower Station.

RG&E Report No. B-13-389. Rochester, NY. 2001.

Page 9-8

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix A Appendix E - Environmental Report APPENDIX A. DISCUSSION OF NRC LICENSE RENEWAL NATIONAL ENVIRONMENTAL POLICY ACT ISSUES Rochester Gas and Electric Corporation (RG&E) has prepared this Environmental Report - OperatingLicense Renewal Stage; Ginna Station in accordance with the requirements of U.S. Nuclear Regulatory Commission (NRC) regulation 10 CFR 51.53. The NRC included in the regulation a list of National Environmental Policy Act (NEPA) issues for license renewal of nuclear power plants. Table A-1 lists these 92 issues with assigned categorization and identifies where RG&E addressed each issue in the environmental report. A cross-reference to the section in the NRC's Generic EnvironmentalImpact Statement for License Renewal of Nuclear Plants (GELS) (Ref. A.1-1; Ref. A.1-2) containing the NRC's generic analysis is also presented for the issues applicable to Ginna Station license renewal. For expediency, RG&E has assigned numbers to each issue and uses the issue numbers throughout the environmental report.

Page A-1

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix A Appendix E - Environmental Report Table A-1 Ginna Station Environmental Report Discussion of License Renewal NEPA Issues Section of this Environmental GElS Cross Referenceb issuea Category' Report (SectionlPage)

1. Impacts of refurbishment 1 NAc on surface water quality

2. Impacts of refurbishment 1 NA9 on surface water use

3. Altered current patterns 1 4.1 4.2.1.2.1/4-4 at intake and discharge structures

4. Altered salinity gradients 1 NAW

5. Altered thermal 4.1 4.2.1.2.3/4-6 stratification of lakes

6. Temperature effects on 4.1 4.2.1.2.3/4-6 sediment transport capacity

7. Scouring caused by 4.1 4.2.1.2.3/4-6 discharged cooling water 1

8. Eutrophication 1 4.1 4.2.1.2.3/4-6

9. Discharge of chlorine or 4.1 4.2.1.2.4/4-10 other biocides

10. Discharge of sanitary 1 4.1 4.2.1.2.4/4-10 wastes and minor chemical spills

11. Discharge of other 1 4.1 4.2.1.2.4/4-10 metals in waste water

12. Water use conflicts 1 4.1 4.2.1.3/4-13 (plants with once-through cooling systems)

13. Water use conflicts 2 NA9 (plants with cooling ponds or cooling towers using makeup water from a small river with low flow)

14. Refurbishment impacts to I NA9 aquatic resources

15. Accumulation of 1 4.1 4.2.1.2.4/4-10 contaminants in sediments or biota

16. Entrainment of 4.1 4.2.2.1.1/4-15 phytoplankton and zooplankton Page A-2

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix A Appendix E - Environmental Report Table A-1 (continued)

Ginna Station Environmental Report Discussion of License Renewal NEPA Issues Section of this Environmental GElS Cross Referenceb issue' Categorya Report (Section/Page)

17. Cold shock 1 4.1 4.2.2.1.5/4-18

18. Thermal plume barrier to 1 4.1 4.2.2.1.4/4-17 migrating fish

19. Distribution of aquatic 1 4.1 4.2.2.1.6/4-19 organisms

20. Premature emergence of 1 4.1 4.2.2.1.7/4-20 aquatic insects

21. Gas supersaturation (gas I 4.1 4.2.2.1.8/4-21 bubble disease)

22. Low dissolved oxygen in 4.1 4.2.2.1.9/4-23 the discharge 1

23. Losses from predation, 4.1 4.2.2.1.10/4-24 parasitism, and disease among organisms 1 exposed to sublethal stresses

24. Stimulation of nuisance 4.1 4.2.2.1.11/4-25 organisms (e.g.,

shipworms)

25. Entrainment of fish and 2 4.2 4.2.2.1.2/4-16 shellfish in early life stages for plants with once-through and cooling pond heat dissipation systems

26. Impingement of fish and 2 4.2 4.2.2.1.3/4-16 shellfish for plants with once-through and cooling pond heat dissipation systems

27. Heat shock for plants 2 4.3 4.2.2.1.4/4-17 with once-through and cooling pond heat dissipation systems

28. Entrainment of fish and 1 NAe shellfish in early life stages for plants with cooling-tower-based heat dissipation systems

29. Impingement of fish and 1 NA!

shellfish for plants with cooling-tower-based heat dissipation systems Page A-3

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix A Appendix E - Environmental Report Table A-1 (continued)

Ginna Station Environmental Report Discussion of License Renewal NEPA Issues Section of this Environmental GElS Cross Referenceb Issue' Category8 Report (Section/Page)

30. Heat shock for plants NAe with cooling-tower-based heat dissipation systems

31. Impacts of refurbishment NAc on groundwater use and quality

32. Groundwater use 1 NA' conflicts (potable and service water; plants that use less than 100 gpm)

33. Groundwater use 2 NA' conflicts (potable, service water, and dewatering; plants that use greater than 100 gpm)

34. Groundwater use 2 NA!

conflicts (plants using cooling towers withdrawing makeup water from a small river)

35. Groundwater use 2 NA9 conflicts (Ranney wells)

36. Groundwater quality 1 NA9 degradation (Ranney wells)

37. Groundwater quality 1 NA' degradation (saltwater intrusion)

38. Groundwater quality 1 NAe degradation (cooling ponds in salt marshes)

39. Groundwater quality 2 NAe degradation (cooling ponds at inland sites)

40. Refurbishment impacts to 2 4.4 3.6/3-6 terrestrial resources

41. Cooling tower impacts on 1 NAe crops and ornamental vegetation

42. Cooling tower impacts on NAe native plants Page A-4

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix A Appendix E - Environmental Report Table A-1 (continued)

Ginna Station Environmental Report Discussion of License Renewal NEPA Issues Section of this Environmental GElS Cross Referenceb Issuea Categorya Report (Section/Page)

43. Bird collisions with I NAe cooling towers

44. Cooling pond impacts on 1 NAe terrestrial resources

45. Power line right-of-way 1 4.1 4.5.6.1/4-71 management (cutting and herbicide application)

46. Bird collisions with power 4.1 4.5.6.214-74 lines 1 4.1 4.5.6.3/4-77

47. Impacts of electromagnetic fields on flora and fauna (plants, agricultural crops, honeybees, wildlife, livestock)

48. Floodplains and wetlands I 4.1 4.5.7/4-81 on power line right-of way

49. Threatened or 2 4.5 3.9/3-48, 4.1/4-1 endangered species

50. Air quality during 2 4.6 3.3/3-2 refurbishment (nonattainment and maintenance areas)

51. Air quality effects of 1 4.1 4.5.2/4-62 transmission lines

52. Onsite land use 1 4.1 3.2/3-1

53. Power line right-of-way 1 4.1 4.5.3/4-62 land-use impacts

54. Radiation exposures to 1 NAc the public during refurbishment

55. Occupational radiation NAc exposures during refurbishment

56. Microbiological I 4.1 4.3.6/4-48 organisms (occupational health)

Page A-5

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix A Appendix E - Environmental Report Table A-1 (continued)

Ginna Station Environmental Report Discussion of License Renewal NEPA Issues Section of this Environmental GElS Cross Referenceb Issue' Category" Report (Section/Page)

57. Microbiological 2 4.15 4.3.6/4-48 organisms (public health)(plants using lakes or canals, or cooling towers or cooling ponds that discharge to a small river)

58. Noise 1 4.1 4.3.7/4-49

59. Electromagnetic fields, 2 4.7 4.5.4.114-66 acute effects (electric shock)

60. Electromagnetic fields, NAh 4.1.3 4.5.4.2/4-67 chronic effects

61. Radiation exposures to 4.1 4.6.2/4-87 public (license renewal term)

62. Occupational radiation 4.1 4.6.3/4-95 exposures (license renewal term)

63. Housing impacts 2 4.8 3.7.2/3-10, 4.7.1/4-101

64. Public services: public 1 4.1 3.7.4/3-14, 3.7.4.3/3-18, safety, social services, 3.7.4.4/3-19, 3.7.4.6/3-20, and tourism and 4.7.3/4-104, 4.7.3.3/4-106, recreation 4.7.3.4/4-107, 4.7.3.6/4-107

65. Public services: public 2 4.9 3.7.4.5/3-19, 4.7.3.5/4-107 utilities

66. Public services, 2 4.10 3.7.4.1/3-15 education (refurbishment)

67. Public services, 1 4.1 4.7.3.1/4-106 education (license renewal term)

68. Offsite land use 2 4.11.1 3.7.5/3-20 (refurbishment)

69. Offsite land use (license 2 4.11.2 4.7.4/4-107 renewal term)

70. Public services, 2 4.12 3.7.4.2/3-17, 4.7.3.2/4-106 transportation

71. Historic and 2 4.13 3.7.7/3-23, 4.7.7/4-114 archaeological resources Page A-6

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix A Appendix E - Environmental Report Table A-1 (continued)

Ginna Station Environmental Report Discussion of License Renewal NEPA Issues Section of this Environmental GElS Cross Referenceb Issue' Categorya Report (Section/Page)

72. Aesthetic impacts I NAc (refurbishment)

73. Aesthetic impacts 4.1 4.7.6/4-111 (license renewal term)

74. Aesthetic impacts of 4.1 4.5.8/4-83 transmission lines 1 (license renewal term)

75. Design basis accidents 4.1 5.3.2/5-11, 5.5.1/5-114

76. Severe accidents 2 4.14 5.3.3/5-12, 5.5.2/5-114

77. Offsite radiological 1 4.1 6.2.4/6-27, 6.6/6-87 impacts (individual effects from other than the disposal of spent fuel and high-level radioactive waste)

78. Offsite radiological I 4.1 6.2.4/6-27, 6.6/6-88 impacts (collective effects)

79. Offsite radiological I 4.1 6.2.4/6-28, 6.6/6-88 impacts (spent fuel and high-level radioactive waste disposal)

80. Nonradiological impacts 1 4.1 6.2.2.6/6-20, 6.2.2.7/6-20, of the uranium fuel cycle 6.2.2.8/6-21, 6.2.2.9/6-21, 6.6/6 90

81. Low-level radioactive 1 4.1 6.4.2/6-36, 6.4.3/6-37, 6.4.4/6-48, waste storage and 6.6/6-90 disposal

82. Mixed waste storage and 1 4.1 6.4.516-63, 6.6/6-91 disposal

83. Onsite spent fuel I 4.1 6.4.6/6-70, 6.6/6-91

84. Nonradiological waste I 4.1 6.5/6-86, 6.6/6-92

85. Transportation 1 4.1 Addendum 1 (Ref. A.1-2)

86. Radiation doses I 4.1 7.3.1/7-15, 7.4/7-25 (decommissioning)

87. Waste management I 4.1 7.3.2/7-19, 7.4/7-25 (decommissioning)

Page A-7

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix A Appendix E - Environmental Report Table A-1 (continued)

Ginna Station Environmental Report Discussion of License Renewal NEPA Issues Section of this Environmental GElS Cross Referenceb issuea Category" Report (Section/Page)

88. Air quality 1 4.1 7.3.3/7-21, 7.4/7-25 (decommissioning)

89. Water quality 1 4.1 7.3.4/7-21, 7.4/7-25 (decommissioning)

90. Ecological resources 1 4.1 7.3.5/7-21, 7.4/7-25 (decommissioning)

91. Socioeconomic impacts 1 4.1 7.3.7/7-24, 7.4/7-25 (decommissioning)

92. Environmental justice NAh 4.16

a. 10 CFR 51, Subpart A, Appendix B, Table B-1 (Issue numbers added to facilitate discussion).

b. Ref. A.1-1.

c. NRC findings are not applicable because RG&E has no plans for major refurbishment

d. Not applicable because Ginna Station discharges to a large freshwater lake

e. Not applicable because Ginna Station is not equipped with cooling ponds or cooling towers.

f. Not applicable because Gmnna Station is not a direct user of groundwater (no dewatering; potable water is from municipal supply and service water is from Lake Ontario).

g. Not applicable because Ginna Station does not use Ranney wells.

h Not applicable Regulation does not categorize this issue CFR = Code of FederalRegulations GElS = Generic Environmental Impact Statement for License Renewal of Nuclear Plants gpm = gallons per minute NA = Not applicable NEPA = National Environmental Policy Act NRC = U.S. Nuclear Regulatory Commission RG&E = Rochester Gas and Electric Corporation Page A-8

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix A Appendix E - Environmental Report A.1 References Ref. A.1-1 U.S. Nuclear Regulatory Commission. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. NUREG-1437.

Office of Nuclear Regulatory Research. Washington, D.C. May 1996.

Ref. A. 1-2 U.S. Nuclear Regulatory Commission. Generic EnvironmentalImpact Statement for License Renewal of Nuclear Plants. Section 6.3, "Transportation," and Table 9.1, "Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants." NUREG-1437, Vol. 1, Addendum 1. Office of Nuclear Reactor Regulation. Washington, D.C.

August 1999.

Page A-9

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix B Appendix E - Environmental Report APPENDIX B. SPDES PERMIT AND 316 DOCUMENTATION Section Paqe B.1 NYSDEC SPDES Discharge Permit .......................................................................... B-2 B.2 NYSDEC Correspondence Regarding Ginna Station Intake System Evaluations ..... B-16 Page B-1

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix B Appendix E - Environmental Report B.1 NYSDEC SPDES Discharge Permit Page B-2

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix B Appendix E - Environmental Report 91-20-2 (1/89) NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION State Pollutant Discharge Elimination System (SPDES)

DISCHARGE PERMIT JAN 15 1998 Special Conditions (Part I)

Industrial Code: 4911 SPDES Number. NY-0000493 Discharge Class (CL) 03 DEC Number: 8-5434-00010/00003-0 Toxic Class (TX): T Effective Date (EDP): .. 0/11/98 Major Drainage Basin. 03 Expiration Date (ExDP): W2/01/03 Sub Drainage Basin. 02 Modification Date(s):

Water Index Number: Ontario Attachment(s)- General Conditions (Part ll)TDte 11/90 Compact Area:

This SPDES permit Is Issued in compliance with Title 8 of Article 17 of the Environmental Conservation Law of New York State and In compliance with the Clean Water Act as amended, (33 U S C Section 1251 et. seq )(hereafter referred to as *theAct")

PERMITnEE NAME AND ADDRESS Attention Mar nager Environmental Health &

Safety Name: Rochester Gas & Electric Corporation Street: 89 East Avenue City- Rochester Statte NY ZipCode. 14649 Is authorized to discharge from the facility described below-.

FACIUTY NAME AND ADDRESS Name: Ginna Nuclear Power Plant - Station 13 Location (C,TV): Ontario (T) County. Wayne FacilityAddress* 1503 Lake Road City: Ontario State: NY ZipCode: 14519 NYTM - E: NYTM - N. 4 FromOutfallNo: 001 at Latitude: 430 16' 44" &Longitude: "770 18' 34" into receiving waters known as Lake Ontario Class A Special and, (list other Outfalls, ReceMng Waters &Water Classifications) 001A to 001D Lake Ontario Class A - Special 002, 003 Lake Ontario Class A - Special 004, 005, 006 Mill Creek Class D - C In accordance with the effluent limitations, monitoring requirements and other conditions set forth In Special Conditions (Part I)and General Conditions (Part Ii)of this permit.

DISCHARGE MONITORING REPORT (DMR) MAIUNG ADDRESS MallingName: Ginna Nuclear Power Plant - Station 13 Street 89 East Avenue City: Rochester State. NY Zip Code. 14649 9 Responsible Official orAgent' Jeffrey L. Williams Phone. (716)J724-8129 This permit and the authorization to discharge shall expire on midnight of the expiration date shown and the pernittee shall not discharge after the expiration date unless this permit has been renewed, or extended pursuant to law To be authorized to discharge beyond the expiration date, the permittee shall apply for a permit renewal no less than 180 days prior to the expiration date shown above.

DISTRIBUTION Permit Administrator I Address* ,"I-*..., " -.:,-J '*- " 31 Page B-3

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix B Appendix E - Environmental Report 91-20-2a (1/89) SPDES No.: NY-ooo 0493 Part 1, Page 2 of 13 FINAL EFFLUENT UMITATIONS AND MONITORING REQUIREMENTS During the period beginning February 1. 1998 and lasting until February 1, 2003 the discharges from the permitted facility shall be limited and monitored by the permittee as specified below Minimum Monitoring Requirements Outfall Number & Discharge Umitations Measurement Sample Effluent Parameter Daily Avg Daily Max. Units Frequency Type 001 Circulating Cooling Water Flow Monitor 490 MGD Continuous Pump Logs Discharge Temperature Monitor 102 OF Continuous Recorder

• Intake-Discharge Temperature Difference 28 OF Continuous Recorder Total Residual Chlorine Monitor 02 mg/I Continuous during period a of chlorination pH (Range) 60-90 SU Weekly Grab 001-A House Service Boiler Blowdown Flow Monitor Monitor GPD Annual Estimate Oil & Grease Monitor 15 mg/I Annual Grab Suspended Solids 30 100 mg/I Annual Grab pH (Range) 60-90 SU Annual Grabb Iron NA 40 mg/I Annual Grab Copper NA 1.0 mg/1 Annual Grab 001-B Hiah Conductivity Waste Tank Discharge (Includes Steam Generator Blowdown)

Flow NA Monitor GPD Quarterly Instantaneous Oil & Grease Monitor 15 mg/I 2/year Grab Suspended Solids NA 50 mg/I Quarterly Grab Chromium, Total NA is mg/I Monthly Grab Copper NA 1.0 mg/i Monthly Grab Zinc NA 03 mg/I Monthly Grab Boron NA 20 mg/I Monthly Grab Iron NA 40 mg/i Monthly Grab Arsenic NA 0.15 mg/I Monthly Grab

• One second temperature readings of untempered Intake and discharge water will be used to compute the hourly average temperature difference Twenty four hourly average temperatures would be used to compute the daily average temperature difference The highest hourly temperature difference recorded during the day would be the maximum reported Page B-4

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix B Appendix E - Environmental Report SPDES No: NY-000 0493 Part 1, Page 3 of 13 FINAL EFFLUENT UMITATIONS AND MONITORING REQUIREMENTS During the period beginning - February 1. 1998 and lasting until February 1 2003 the discharges from the permitted facility shall be limited and monitored by the permittee as specified below:

Minimum Monitoring Requirements Outfall Number & Discharge Limitations Measurement Sample Effluent Parameter Daily Avg Daily Max. Units Frequency Type 001 .C Radiation Waste Holduo and Treatment System (Includes Condensate Tank, A&B Monitor Tanks, Laundry Tanks)

Flow NA Monitor GPD Quarterly Grab Oil & Grease NA 15 mg/I Quarterly Grab Suspended Solids 30 100 mg/I Quarterly Grab pH (Range) 60 -90 SU Quarterlye Grabb Boron 40 NA lbs/day Quarterly Grab 001-D Screenwash Return Water (No monitoring required)

NOTES

a. Chlorine may be discharged up to 120 minutes per day.

b The pH limit may be exceeded when conductivity Is less than 10 micro mhos per cm 2 . Conductivity monitoring Is only required when the pH limit Is exceeded.

Page B-5

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix B Appendix E - Environmental Report 91-20-2a (1/89) SPDESNo: NY-000 0493 Part 1, Page 4 of 13 FINAL EFFLUENT UMITATIONS AND MONITORING REQUIREMENTS During the period beginning February 1, 1998 and lasting until February 1, 2003 the discharges from the permitted facility shall be limited and monitored by the permittee as specified below.

Minimum Monitoring Requirements Outfall Number & Discharge Umitations Measurement Sample Effluent Parameter Daily Avg Dally Max. Units Frequency Type 002 - Storm Water Runoff & Low Volume Wastes (No monitoring required) 002-A Retention Tank gIncludes Demineralizer Fleoeneration Wastes and Floor Drains)

Flow Monitor Monitor GPD Monthly Instantaneous Oil& Grease Monitor 15 mg/I Monthly Grab Suspended Solids 30 100 mg/I Monthly Grab pH* 6 0 - 9.0 (Range) SU Continuous Recorder Copper NA 1.0 mg/I Monthly Grab Iron NA 40 mg/I Monthly Grab 003 - Storm Water Runoff (No monitoring required) 004 - Storm Water Runoff (No monitoring required) 005 - Storm Water Runoff (No monitoring required) 006 - Redundant House Service Water Testing Flow Monitor Monitor Each Discharge Estimate

"*Where pH Is continuously recorded, the permittee Is allowed excursions from the designated, allowable pH range, subject to the following conditions:

(1) The total time during which the pH values of each discharge are outside the required range shall not exceed 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> and 26 minutes in any calendar month (2) No Individual excursion shall exceed 60 minutes In duration (3) No excursion shall cause or contribute to a contravention of water quality standards Page B-6

R.E. Ginna Nuclear Power Plant Applicati6n for Renewed Operating License Appendix B Appendix E - Environmental Report 91-20-2a (1/89) SPDES No: NY-000 0493 Part 1, Page 5 of 13 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning February 1, 1998 and lasting until February 1, 2003 the discharges from the permitted facility shall be limited and monitored by the permittee as specified below:

Minimum Monitoring Requirements Outfall Number & Discharge Umitations Measurement Sample Effluent Parameter Daily Avg. Daily Max. Units Frequency Type Outfall 001 Chlorine, Total Residual N/A 01 mg/I Dally* Grab

• Samples shall be collected and analyzed daily for Total Residual Chlorine during periods of chlorine addition for Zebra Mussel control Sptecial Conditions The chlorine program for zebra mussel control, approved by letter dated June 24, 1993 to J Williams of RG&E. is allowed with the following conditions concerning circulating cooling water:

1. Each Individual chlorine zebra mussel control shall be limited to a maximum of 30 days of continuous treatment

2. Chlorine treatments for zebra mussel control shall be limited to a maximum of four treatments annually Treatment shall be separated by at least 30 days.

3. Records of chlorine dosage concentration, effluent flow and effluent concentration of total residual chlorine during addition and discharge must be maintained. The flow shall be measured at the frequency specified for flow elsewhere In this permit or at the frequency of the parameter specified above, whichever Is more frequent.

4 The Regional Water Engineer shall be notified not less than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to Initiation of zebra mussel control program.

5 The reports describing the results of the effectiveness of the zebra mussel control program and effluent analysis for total residual chlorine shall be submitted to the Regional Water Engineer. NYSDEC, by March 1st of the year following such treatments.

6. This permit modification Is Issued based on the best environmental and aquatic toxicity Information available at this time This authorization Is subject to modification or revocation any time new Information becomes available which Justifies such modification or revocation.

Page B-7

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix B Appendix E - Environmental Report 91-20-2e (2/89) SPDESNo: NY-000 0493 Part 1, Page 6 of 13 DEFINITIONS OF DAILY AVERAGE AND DAILY MAXIMUM The daily average discharge is the total discharge by weight or in other appropriate units as specified herein, during a calendar month dMded by the number of days In the month that the production or commercial facility was operating Where less than daily sampling is required by this permit, the daily average discharge shall be determined by the summation of all the measured daily discharges In appropriate units as specified herein divided by the number of days during the calendar month when measurements were made The daily maximum discharge means the total discharge by weight or In other appropriate units as specified herein.

during any calendar day.

MONITORING LOCATIONS The permittee shall take samples and measurements, to comply with the monitoring requirements specified In this permit, at the locatIon(s) Indicated below- (Show sampling locations and outfalls with sketch or flow diagram as appropriate) (see page 7 of 13)

LAK11E ONTARiO Page B-8

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix B Appendix E - Environmental Report No. NY 000 0493 1 aLAge7 oNrof1

'Page 7of 13.'*"...

0 MON ITO 2JNG L)C~AC~T,1,

.... A SrjA"--- r- 0 r'-~ '5

-'~C A .5 ~ ~'~ j-,-- '

Page B-9

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix B Appendix E - Environmental Report SPDES No: NY-000 0493 Part 1 Page _8 of 13 Additional Requirements

1. The Department has tentatively approved the permittee's request pursuant to Section 316(b) of the Clean Water Act for the 5-year life of this permit. A Biological monitoring program to evaluate future compliance with this section is outlined in Additional Requirement #4.

2. The permittee shall submit written notification, which shall include detailed descriptions and appropriate figures, to the DEC Chief, -X Bureau of Environmental Protection, Regional Fisheries Manager and Regional Engineer at least 60 days in advance of any change which results in the alteration of the location, design, construction, operations or capacity of the cooling water intake structure. The permittee shall submit, with its written notification a demonstration that the change reflects the best technology currently available for minimizing adverse environmental impact. Prior DEC approval is required before initiating such change. A permit modification may be required.

3. Each impingement report submitted during this permit period shall include figures and a complete description of the cooling water intake system including trash racks; traveling screen type, size, mesh, and standard operating procedures; screen washwater discharge sluice configuration and disposition of screen washings, and the nature and estimated quantities of debris collected at this facility.

4. Impingement Monitoring Program.

a. An annual impingement monitoring program is required in order to document the impact of this facility on the aquatic environment of Lake OntariQ. The methodologies described in Ginna Nuclear Power Station Impingement Plan of Study, RG&E Report No. B-13-293 (July 1985) are required with the following modification:

i. The wire mesh collection basket that fits into the screenwash sluiceway shall be constructed of mesh that is approximately 1/2 of the bar mesh of the traveling screens in order to minimize loss of organisms washed off the traveling screens.

Page B-10

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix B Appendix E - Environmental Report SPDES No: NY-000 0493 Part 1,Page_._ of 13 ii. By October 1, 1997 the permittee shall submit to the offices noted in Additional Requirement 2, for review and approval, a plan to conduct a special study to quantify the loss of impinged organisms through the standard impingement collection device. The study shall be implemented within 2 months of approval of the study plan.

b. At the permittee's option a modified impingement abundance program may be submitted for DEC review and approval. The goal of the modified program would be to reduce the cost of impingement monitoring while continuing to provide adequate information for the department's determination to 6NYCRR 704 and the Clean Water Act Section 316. The impingement program identified in 4.a above shall continue in effect until an alternative is approved by the DEC.

5. Impingement Mitigation

a. During any time when a circulating pump is operational each traveling screen shall be washed for approximately fifteen (15) minutes each hour, excepting when a screen is inoperable due to required maintenance.

b. By January 1, 1998 the permittee shall submit a plan for review and approval to those individuals indicated in Additional Requirement 2, that provides for the resurfacing of the screen washwater/fish and debris sluice in order to minimize any additional trauma imposed on viable fish washed from the intake traveling screens and being returned to Lake Ontario. By July 1, 1998. the permittee shall report to the offices noted in Additional Requirement 2, either compliance with the plan approved by DEC, or provide an estimate of the additional time and efforts needed to achieve compliance.

c. No sampling gear other impediments to the return of impinged fish to Lake Ontario shall be placed int he washwater sluice excepting those necessary to conduct studies approved by the DEC.

Page B-1I

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix B Appendix E - Environmental Report SPDES No.: NY-000 0493 Part 1.Page I0 of 13

d. By January 1, 1998, the permittee shall provide the offices noted in 2 above a plan for minimizing water use at this facility. The plan must consider options such as increased recirculation of cooling water and/or operation on one circulating water pump (CWP) during winter months, installation of variable speed CWP's complete cessation of CWP operation during outages lasting more than a few days, and other possible means of reducing the use of cooling water. It is understood that special studies may be needed to establish suitable operational parameters under reduced flow conditions. Once completed, those elements of this plan acceptable to both the permittee and the DEC shall become condition of this permit.

6. The thermal discharge from this facility shall assure the protection and propagation of a balanced indigenous population of shellfish, fish and wildlife in and on Lake Ontario. In this regard, the Department has approved the permittee's request for alternative effluent limitations pursuant to Section 316(a) of the Clean Water Act for the 5 year life of the permit. The effluent limitations in this permit reflect this approval. The water temperature at the surface of Lake Ontario shall not be raised more than three Fahrenheit degrees over the temperature that existed before the addition of heat of artificial origin except that in a mixing zone consisting of an area of 320 acres from the point of discharge, this temperature may be exceeded.

7. Reporting

a. A copy of all reports pertaining to environmental impacts on water resulting from this facility, which the applicant submits to any federal, state or local agency, shall also be submitted to the Department of Environmental Conservation offices in Avon and Albany. The permittee shall also notify the Department within one week from the time of submission to the Nuclear Regulatory Commission of any requested change in the environmental technical specifications which could effect the requirements of this permit.

b. Copies. of all reports regarding water and biological parameters related to intake and discharge considerations, whether generated for this permit or otherwise, shall be sent to the offices in Section 2 above.

Page B-12

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix B Appendix E - Environmental Report SPDESNo: NY-O00 0493 Pan 1, Page 11 of 13

c. Report(s) submitted in fulfillment of permit conditions shall clearly identify on the title page the permit number and the specific section(s) by character and number that the report(s) fulfill. Each section of the text of such report shall identify the section(s) of the permit that it fulfills.

d. The annual impingement monitoring report shall be submitted by July 1 of the following year. The analyses, content and appendices shall follow that provided in previous impingement abundance reports as in RG&E Report No. B-13-357- Rochester Gas and Electric Corporation Fish Impingement Program Analysis Report.

8. Biological specimens may be required to be submitted to NYSDEC upon request if notice by the Department is given prior to collection.

9. There shall be no discharge of auxiliary boiler chemical cleaning wastes and other metal cleaning wastewaters other than those using boric acid.

10. In regards to general condition #11.5 items c and d shall be reported annually to NYSDEC offices in Avon.

11. The permittee shall submit on a quarterly basis a report to the Department's offices in Albany and Avon by the 28th of the month next following the end of the period:

a. Daily minimum, average, and maximum station electrical output shall be determined and logged.

b. Daily minimum, average, and maximum water use shall be directly or indirectly measured or calculated and logged.

c. Daily minimum, average, and maximum intake and discharge temperatures shall be logged.

d. Measurement in a,b, and c shall be taken on an hourly basis.

12. There shall be no discharge of PCB's from this facility.

13. Radioactivity: Concentrations of radioactivity in effluent are subject to the requirements of the U.S. Nuclear Regulatory Commission license conditions.

Page B-13

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix B Appendix E - Environmental Report 91-20-2C (2/91) SPDES No: NY-000 0493 Part 1, Page 12 of 13 SCHEDULE OF COMPLIANCE a) The permittee shall comply with the following schedule.

Action Outfall Code Numberýs) Compliance Action Due Date 50008 001D Special study to quantify the loss of Impinged organisms through standard 10/1/97 Impingement collection device.

34599 001D Annual Impingement monitoring report on the program required In Additional July 1 of the Requirement #4 of this permit. following year from data collection 01299 001D Submit plan for resurfacing of screen washwater/fish debris sluice (as 1/1/98 required A.R. #5b) 59499 001D Construction schedule to achieve compliance with Item above (A.R. #5b) 7/1/98 01299 001 Water use minimization plan (A.R. #5d) 1/1/98 03OMS 002, 003, Stormwater pollution prevention plan 9/98 004, 005 b) The permittee shall submit a written notice of compliance or non-compliance with each of the above schedule dates no later than 14 days following each elapsed date, unless conditions require more Immediate notice under terms of the General Conditions (Part II), Section 5. All such compliance or non-compliance notification shall be sent to the locations listed under the section of this permit entitled RECORDING, REPORTING AND ADDITIONAL MONITORING REQUIREMENTS. Each notice of non-comol1ance shall Include the following Information

1. A short description of the non-compliance;

2. A description of any actions taken or proposed by the permittee to comply with the elapsed schedule requirements without further delay and to limit environmental Impact associated with the non-compliance; 3 A description or any factors which tend to explain or mitigate the non-compliance; and

4. An estimate of the date the permittee will comply with the elapsed schedule requirement and an assessment of the probabilty that the permittee will meet the next scheduled requirement on time c) The permittee shall submit copies of any document required by the above schedule of compliance to NYSDEC Regional Water Engineer at the location listed under the section of this permit entitled RECORDING, REPORTING AND ADDITIONAL MONITORING REQUIREMENTS, unless otherwise specified In this permit or In writing by the Department Page B-14

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix B Appendix E - Environmental Report 91-20-2f (5/94) SPDES No.: NY 0000493 Part 1, Page 13 of 13 RECORDING, REPORTING AND ADDmONAL MONITORING REQUIREMENTS a) The permittee shall also refer to the General Conditions (Part I1)of this permit for additional Information concerning monitoring and reporting requirements and conditions b) The monitoring Information required by this permit shall be summarized, signed and retained for a penod of three years from the date of the sampling for subsequent Inspection by the Department or its designated agent. Also;

[X I (if box Is checked) monitoring Information required by this permit shall be summarized and reported by submitting completed and signed Discharge Monitoring Report (DMR) forms for each 1 month reporting period to the locations specified below. Blank forms are available at the Department's" -banyoffice listed below. The first reporting period begins on the effective date of this permit and the reports will be due no later than the 28th day of the month following the end of each reporting period.

Send the original (top sheet) of each DMR page to:

Department of Environmental Conservation Division of Water Bureau of Watershed Compliance Programs 50 Wolf Road Albany, New York 12233-3506 Phone: (518) 457-3790 Send the first copy (second sheet) of each DMR page to:

Department of Environmental Conservation Regional Water Engineer Region 8 6274 East Avon-Lima Road Avon, New York 14414 c) A monthly "Wastewater Facility Operation Report .." (form 92-15-7) shall be submitted (if box Is checked) to the I ]Regional Water Engineer and/or [ ) County Health Department or Environmental Control Agency listed above.

d) Noncompliance with the provisions of this permit shall be reported to the Department as prescribed In the attached General Conditions (Part II).

e) Monitoring must be conducted according to test procedures approved under 40 CFR Part 136, unless other test procedures have been specified In this permit.

f) If the permittee monitors any pollutant more frequently than required by this permit, using test procedures approved under 40 CFR Part 136 or as specified In this permit, the results of this monitoring shall be Included In the calculations and recording on the Discharge Monitoring Reports.

g) Calculations for all limitations which require averaging of measurements shall utilize an arithmetic mean unless otherwise specified In this permit.

h) Unless otherwise specified, all Information recorded on the Discharge Monitoring Report shall be based upon measurements and sampling carried out during the most recently completed reporting period I) Any laboratory test or sample analysis required by this permit for which the State Commissioner of Health Issues certificates of approval pursuant to section five hundred two of the Public Health Law shall be conducted by a laboratory which has been Issued a certificate of approval. Inquiries regarding laboratory certification should be sent to the Environmental Laboratory Accreditation Program, New York State Health Department Center for Laboratories and Research. Division of Environmental Sciences, The Nelson A. Rockefeller State Plaza, Albany, New York 12201.

Page B-15

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix B Appendix E - Environmental Report B.2 NYSDEC Correspondence Regarding Ginna Station Intake System Evaluations Page B-16

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix B Appendix E - Environmental Report New York State Department of Environmental Conservation Division of Fish, Wildlife & Marine Resources Bureau of Habitat, Room 576 I -o 50 Wolf Road, Albany, New York 12233-4756 Phone: (518) 457-6178

• FAX: (518) 485-8424 W John P. Cahill Website: www.dec.state ny.us Comnisio*r September 7, 1999 Mr. Paul Sawyko Rochester Gas & Electric Corporation 89 East Avenue Rochester, N.Y. 14649-0001 Dear Mr. Sawyko Thank you for submitting the fish impingement reports for the Ginna Nuclear Power Station and the Russell Power Station The 5 year monitoring study (1994-1998) reported impingement totals at the Russell Power Station to be approximately 1,800-15,000 fish/year, and at the Ginna Nuclear Power Station to be approximately 10,00-55,000 fish/year. The reports concluded that the impingement losses have negligible effects on fish populations in Lake Ontario Both NYCRR Part 704 5 and Part 316(b) of the federal Clean Water Act require the use of best technology available (BTA) to minimize adverse environmental impacts at cooling water intake systems Consistent with these state and federal requirements, the Department's goal is to seek elimination, if possible, and otherwise minimization of mortality to fish at cooling water intakes Although impingement at these stations is lower than at most other major steam-clectric plants utilizing open cycle cooling, it has yet to be determined whether the cooling water intakes represent BTA for minimizing adverse environmental impacts With the proliferation of new merchant plants under a deregulated electric industry, it is important now more than ever to mitigate the impacts of electric generation on our aquatic resources. Currently, mitigation of impingement impacts are underway at older power plants across the state, and new proposals under the PSC Article X regulations are being met with very stringent requirements to protect aquatic resources. I will be contacting you shortly to begin discussions on the future operations at the Ginna and Russell Power Stations, and what alternatives are available to minimize the loss of fish at these plants Page B-17

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix B Appendix E - Environmental Report

-2 I look forward to discussing this important matter with you. If you have any questions, please call me at 518-457-9439.

B o oSin L cerely, Conservat Biologist cc E. Radle mzjcrtmprcpl Page B-18

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix B Appendix E - Environmental Report New York State Department of Environmental Conservation Division of Fish, Wildlife & Marine Resources Bureau of Habitat, Room 576 A

50 Wolf Road, Albany, New York 12233-4756 Phone: (518) 457-6178 - FAX: (518) 485-8424 JIoil P. CahIll Website: www.dec.state ny.us Comnvsasloner September 22, 1999 Mr. Paul. Sawyko Rochester Gas & Electric Corporation 89 East Avenue Rochester, N.Y. 14649-0001 Dear Mr Sawyko" In my September 7' letter to you I discussed the results of the 5 year biological monitoring program and the need to look at alternatives available to minimize mortality to fish impinged at the Gunna and Russell Power Stations Subsequently, I have become aware that RG&E has been working with the Department to reduce impacts of their cooling water intake structures such as redesigning the fish return sluice at the Ginna NGS, and shutting off pumps during unit outages to reduce cooling water use. In light of this recent work and the degree of impact revealed through the monitoring program, the Department does not consider it necessary to pursue additional mntigative actions at the Guina or Rusell Power Stations at this time.

However, I strongly urge you to keep this office informed of any significant changes to be made to the plants intake systems or other large related capital improvements Such activities may provide cost effective opportunites to minimize impingcment mortality The Department is strongly committed to eliminate, if possible, or otherwise minimize the loss of fish at water intake systems.

Thank you very much for your cooperation. Please call me at 518-457-9439 if you have any additional questions Sincerely, Michael J. Calaban Conservation Biologist mjc/umprep2 Page B-19

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix C Appendix E - Environmental Report APPENDIX C. THREATENED AND ENDANGERED SPECIES CORRESPONDENCE Page C-1

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix C Appendix E - Environmental Report United States Department of the Interior FISH AND WILDLIFE SERVICE 3817 Lukcr Road Cortland, NY 13045 February 25, 2002 Mr. Paul M Sawyko Ginna License Renewal Environmental Report Lead Rochester Gas & Electric Corporation 89 East Avenue Rochester, NY 14649-0001 Dear Mr Sawyko This responds to your letter of January 23, 2002, requesting information on the presence of endangered or threatened species in the vicinity of the Ginna Nuclear Power Plant in the Town of Ontario, Wayne County, New York.

Except for occasional transient individuals, no Federally listed or proposed endangered or threatened species under our jurisdiction are known to exist in the project impact area In addition, no habitat in the project impact area is currently designated or proposed "critical habitat" in accordance with provisions of the Endangered Species Act (87 Stat. 884, as amended, 16 U S C 1531 et seq ). Therefore, no Biological Assessment or further Section 7 consultation under the Endangered Species Act is required with the U.S Fish and Wildlife Service (Service).

Should project plans change, or if additional information on listed or proposed species or critical habitat becomes available, this determination may be reconsidered A compilation of Federally listed and proposed endangered and threatened species in New York is enclosed for your information Tie above comments pertaining to endangered species under our jurisdiction are provided pursuant to the Endangered Species Act This response does not preclude additional Service comments under other legislation For additional information on fish and wildlife resources or State-listed species, we suggest you contact the appropriate New York State Department of Environmental Conservation regional office(s) as shown on the enclosed map, and New York State Department of Environmental Conservation New York Natural Heritage Program Information Services 625 Broadway Albany, NY 12233 (518) 402-8935 Page C-2

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix C Appendix E - Environmental Report Since wetlands may be present, you are advised that National Wetlands Inventory (NWI) maps may or may not be available for the project area. However, while the NWI maps are reasonably accurate, they should not be used in lieu of field surveys for determining the presence of wetlands or delineating wetland boundaries for Federal regulatory purposes Copies of specific NW! maps can be obtained from:

Cornell Institute for Resource Information Systems 302 Rice Hall Cornell University Ithaca, NY 14853 (607) 255-4864 Work in certain waters and wetlands of the United States may require a permit from the U.S Army Corps of Engineers (Corps) If a permit is required, in reviewing the application pursuant to the Fish and Wildlife Coordination Act, the Service may concur, with or without stipulations, or recommend denial of the permit depending upon the potential adverse impacts on fish and wildlife resources associated with project implementation The need for a Corps permit may be determined by contacting the appropriate Corps office(s) as shown on the enclosed map.

If you require additional information please contact Michael Stoll at (607) 753-9334 Sincerely, Aating For David A Stilwell Field Supervisor Enclosures cc NYSDEC, Avon, NY (Environmental Permits)

NYSDEC, Albany, NY (Natural Heritage Program)

COE, Buffalo, NY 2

Page C-3

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix C Appendix E - Environmental Report FEDERALLY LISTED AND PROPOSED ENDANGERED AND THREATENED SPECIES IN NEW YORK Common Name Scientific Name Status Distribution FISHES Sturgeon, shortnose* Acipenser brevirostrum Hudson River & other Atlantic coastal rivers REPTILES Turtle, bog Clemmys muhlenbergit Albany, Columbia, Dutchess, Genesee, Orange, Oswego, Putnam, Seneca, Sullivan, Ulster, Wayne, and Westchester Counties Turtle, green* Chelontamydas Oceanic summer visitor coastal waters Turtle, hawksbill* Eretmochelys imbricata Oceanic summer visitor coastal waters Turtle, leatherback* Dermochelys coriacea Oceanic summer resident coastal waters Turtle, loggerhead* Carettacaretta Oceanic summer resident coastal waters Turtle, Atlantic Lepidochelys kempti Oceanic summer resident ridley* coastal waters BIRDS Eagle, bald Hahaeetusleucocephalus Entire state Plover, piping Charadriusmelodus Great Lakes Watershed Critical Habitat - Eastern Lake Ontario shoreline from Salmon River (Oswego County) to Stony Point (Jefferson County)

Remainder of coastal New York Tern, roseate Sterna dougalhidougalln Southeastern coastal portions of state MAMMALS Bat, Indiana Myotis sodahs Entire state Cougar, eastern Fehs concolor couguar Entire state - probably extinct Whale, blue* Balaenopteramusculus Oceanic Whale, finback* Balaenopteraphysalus Oceanic Whale, humpback* Megapteranovaeanghae Oceanic Whale, right* Eubalaenaglaciahs Oceanic Whale, set* Balaenopteraboreahs Oceanic Whale, sperm* Physeter catodon Oceanic

• Except for sea turtle nesting habitat, prncipal responsibility for these species is vested with the National Manne Fisheries Service 1 Region 5 - I2V13/01 - 2 pp Page C-4

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix C Appendix E - Environmental Report FEDERALLY LI STED AND PROPOSED ENDANGERED AND THREATENED SPECIES IN NEW YORK (Cont'd)

Common Name Scicntific Name Status Distribution MOLLUSKS Snail, Chittenango Novisuccinea chittenangoensts Madison County ovate amber Mussel, dwarf wedge A lasmidonta heterodon Orange County - lower Neversink River Delaware and Sullivan Counties Delaware River BUTIFERFLIES Butterfly, Kamer Lycaeides melissa samuehs Albany, Saratoga, Warren, blue and Schenectady Counties PLANTS Monkshood, northern Acontum noveboracenve Ulster, Sullivan, and wild Delaware Counties Pogonia, small whorled Isotriamedeoloides Entire state Swamp pink Helonias bullata Staten Island - presumed extirpated Gerardia, sandplain Agalins acula Nassau and Suffolk Counties Fern, American Asplenium scolopendrium Onondaga and Madison hart's-tongue var. americana Counties Orchid, eastern prairie Platantheraleucophea Not relocated in New York fringed Bulrush, Scirpusancistrochaefus Not relocated in New York northeastern Roseroot, Leedy's Sedum integrifohum ssp West shore of Seneca Lake Leedyi Amaranth, seabeach Amaranthuspumilus Atlantic coastal plain beaches Goldenrod, Houghton's Solidago houghtoni Genesee County E=endangered T--threatened P=proposed 2 Region 5 - 12113101-2 pp Page C-5

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix C Appendix E - Environmental Report Page C-6

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix C Appendix E - Environmental Report Page C-7

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix D Appendix E - Environmental Report APPENDIX D. CULTURAL RESOURCES CORRESPONDENCE Page D-1

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix D Appendix E - Environmental Report

'i~gxr-d New York State Office of Parks, Recreation and Historic Preservation

• Historic Preservation Field Services Bureau NEWYOSTATE

• Peebles Island, PO Box 189, Waterford, New York 12188-0189 518-237-8643 Bernacdette Castro Comn*ssloner October 31, 2001 Dennis J. Mooney Principal Environmental Analyst Rochester Gas and Electric Corporation 89 East Avenue Rochester, New York 14649-0001 Dear Mr. Mooney Re: NRC Ginna Nuclear Power Plant/2640 Lake Rd/Extend License Ontario/Wayne County 01PR5031 Thank you for requesting the comments of the State Historic Preservation Office (SHPO) We have reviewed the project in accordance with Section 106 of the National Historic Preservation Act of 1966 Based upon our review, it is the SHPO's opinion that your project will have No Effect upon cultural resources in or eligible for inclusion in the National Register of Historic Places If further correspondence is required regarding this project, please be sure to refer to the OPRHP Project Review (PR) number noted above.

Sincerely, Ruth L. Pierpont Director RLP. cmp An Equal Opportunity/Affirmaitve Aciton Agency 0 pnnted en ,eycled*.P.r Page D-2

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report APPENDIX E. SEVERE ACCIDENT MITIGATION ALTERNATIVES E.1 Ginna Station PSA Model and Risk Profile E.1.1 PSA Model Background In response to Generic Letter 88-20, "Individual Plant Examination of Severe Accident Vulnerabilities," and its supplements, Rochester Gas and Electric Corporation (RG&E) performed a Level 1 and full-scale Level 2 probabilistic safety assessment (PSA) for R.E. Ginna Nuclear Power Plant (Ginna Station). In March 1994, RG&E submitted a report to the U.S. Nuclear Regulatory Commission (NRC) documenting the methodology and a summary of the final results. This original Individual Plant Examination (IPE) constituted what has been historically designated as Revision 0 of the Ginna Station PSA (Ref. E.1-1). The purpose of the IPE was to achieve the following objectives:

a. Develop an appreciation for severe accident behavior;

b. Understand the most likely severe accident sequences that could occur;

c. Gain a more quantitative understanding of the overall probabilities of core damage and fission product releases; and

d. Reduce, if necessary, the overall probabilities of core damage and fission product releases by modifying, where appropriate, hardware and procedures that would prevent or mitigate severe accidents.

In addition, the information obtained through achievement of the above objectives has been used for many other purposes (e.g., on-line maintenance). As such, RG&E incorporated many other features and attempted to address additional issues beyond those required by Generic Letter 88-20. Consequently, the IPE is considered a subset of the PSA since the PSA is intended to be used for future issues and concerns.

Since that time, RG&E has expanded the original models and factored into the analysis several items, such as a change to an 18-month fuel cycle; replacement of the steam generators; conversion to Improved Technical Specifications; monitoring of system, structure, and component performance under the Maintenance Rule; and analysis of the risk from internal fires, floods, and shutdown operation. In addition, the NRC raised several questions concerning the original models, and these questions have subsequently been addressed. All these updates constitute model Revisions 1 through 4, with the most recent having been submitted to the NRC in February 2002. The following paragraphs provide a brief summary of each revision.

Revision 1 (Ref. E.1-2) was produced primarily in response to questions raised by the NRC as a result of the original IPE submittal. An extensive re-analysis of the Level 1 PSA was performed, including significant enhancement of the modeling for human reliability.

Page E-1

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report Revision 2 (Ref. E.1-3) provided a supplement to Revision 1 and provided a detailed Level 2 (containment performance) analysis. This submittal completed the response to the original IPE questions.

Revision 3 was completed in January 2000, and incorporated the risk from internal fires and the risk during shutdown operation. Additional upgrades were performed in the model for internal flooding and quantification of initiating event frequencies and common-cause failures to incorporate the most recent operating data and industry advances. Additional human reliability analysis was performed to address operator actions during fires, floods, and shutdown. The Level 2 analysis was also updated by merging selected results from the previous detailed Level 2 analysis with the simplified methodology advocated by the NRC in NUREG/CR-6595.

Revision 4 (Ref. E.1-4) accounts for a major modification performed in December 2000, to eliminate the dominant contributor to core damage frequency that was identified during the updated flooding analysis in Revision 3 (large Service Water flood in the Battery rooms). The generic and plant-specific data for component failures have been updated from the time frame used in the original IPE (1980s) to account for industry and plant-specific operation through 2000. RG&E also explicitly modeled the risk from hydrogen and other exothermic explosions.

An industry peer review was performed in May 2002. In preparation for the peer review, RG&E conducted an internal self-assessment. Incorporation of the results of this self assessment generated Revision 4.1, which was used for the peer review and the severe accident mitigation alternative (SAMA) analysis. The findings of the peer review will be incorporated into future revisions of the model. While the peer review findings could not be incorporated into the model in time to support this submittal, RG&E did account for anticipated model impacts in the analysis of the candidate SAMAs.

E.1.2 Ginna Station Risk Profile The current total core damage frequency (CDF) is 3.97E-05. Table E.1-1 provides a ranking of the accident scenarios contributing greater than two 2 percent of the overall CDF, and Table E.1-2 illustrates the distribution of accident types. As these tables indicate, external events dominate the risk profile for Ginna Station.

Specifically, floods within the Auxiliary Building and fires within the Control Room, Diesel Generator rooms, Turbine Building, or battery rooms dominate the results.

Fire events are dominated by Control Room fires where evacuation is required and only a limited set of equipment is available. Other fire locations fail either alternating current or direct current electrical trains, which also limits the available equipment.

Flooding events are dominated by floods within the Auxiliary Building, as floods in this location can fail all charging, safety injection, residual heat removal, and spent fuel pool pumps.

As noted earlier, the full-scope Level 2 analysis has been replaced by a simplified approach based on NUREG/CR-6595. The large early release frequency is 2.09E

06. The results of the Level 2 analysis are shown in Table E.1-3 and indicate that the large early release frequency is dominated by steam generator tube ruptures and spent fuel pool cooling with subsequent pool boiling. However, the results are Page E-2

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report Table E.1-1 Contributions to CDF by Accident Scenario Scenario Percent Contribution Fire - Control Room 15 Shutdown - residual heat removal 14 Flood - Auxiliary Building 11 Fire - Turbine Building 9 Fire - Battery Room 8 Steam generator tube rupture 7 Loss of service water 6 Fire - diesel generator 4 Small loss-of-coolant accident 4 Flood - Turbine Building 3 At power fuel handling accident/Spent Fuel Pool 3 cooling Interfacing system loss-of-coolant accident 2 Fire - Auxiliary Building 2 Flood - Relay Room 2 Other 10 Table E.1-2 Contribution to CDF by Accident Type Accident Type Percent Contribution Fire 39.20 Flood 18.15 Shutdown 16.25 Small break loss-of-coolant accident 11.79 Transient 5.70 Fuel handling accident/Spent Fuel Pool 3.37 cooling Large break loss-of-coolant accident 3.10 Station blackout 2.43 Anticipated transient without scram 0.02 E-3 Page Page E-3

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report Table E.1-3 Contribution to the Large Early Release Frequency by Accident Type Accident Type Percent Contribution Steam generator tube rupture 35.7 Spent Fuel Pool cooling 22.4 Loss of containment heat removal 19.1 Containment failure at high reactor coolant 16.2 system pressure when the reactor vessel ruptures Containment isolation failures 3.1 Temperature-induced steam generator tube 2.3 rupture Containment failure at low reactor coolant 0.9 system pressure when the reactor vessel ruptures Interfacing system loss-of-coolant accident 0.3 dominated by flooding scenarios that flood the Auxiliary Building basement (thus potentially removing a water source) and loss of spent fuel pool cooling under full core-offload conditions. The next highest percentage contributor is loss of containment heat removal functions attributable to fire and flood events that lead to core damage and also directly impact containment spray and containment recirculation fan coolers E.1.3 Importance Analysis The importance of systems and components is a significant insight into the risk profile for Ginna Station. RG&E has generated two types of importance measures, Fussell-Vesely (F-V) and Risk Achievement Worth (RAW), the results of which are briefly summarized below. To support the Ginna Station PSA, RG&E combined these two importance measures with the F-V value greater than 0.05 at the system level (greater than 0.05 at the component level) and the RAW greater than 10 at the system level (greater than 2 at the component level) to indicate "high" risk significance.

Initiating events identified as high risk significance include fire in the Control Room requiring evacuation, loss of offsite power during 24-hour period when shut down, loss of residual heat removal during shutdown, and total loss of service water.

Test and maintenance events identified as high risk significance include three scenarios: the turbine-driven auxiliary feedwater pump is out of service; the motor driven auxiliary feedwater train A and steam generator A are out of service due to testing or maintenance; and test or maintenance renders charging pump A unavailable.

Systems identified as high risk significance include 125 volt direct current power, 480 volt alternating current power, auxiliary feedwater, component cooling water Page E-4

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report (CCW), chemical and volume control, diesel generator, fire protection, offsite power, reactor coolant, residual heat removal, standby auxiliary feedwater (SAFW), safety injection, and service water.

Components identified as high risk significance include the following:

Motor-operated valves: 738A fails open 738B fails open Air-operated valves: Pressure control valve 430 fails to reseat after steam relief Pressure control valve 431C fails to reseat after steam relief Pumps/compressors/fans: CCW pump PAC02A fails to start CCW pump PAC02B fails to start Spent fuel pool recirculation pump A fails to start on demand Failure of SAFW pump 1C Major electrical components: Local faults on 480 volt alternating current Bus 16 120 volt alternating current instrument Bus C faults Diesel generator A fails to start/run Diesel generator B fails to start/run Check valves: Check valve 853A fails to remain closed Check valve 853B fails to remain closed E.1.4 Station Design Features and Improvements There are several unique and important features of the Ginna Station that contribute to core damage prevention. In addition, as a result of the insights obtained from the Ginna Station PSA, several identified vulnerabilities have resulted in station modifications and procedural changes.

E.1.4.1 Station Design Features Important to Core Damage Prevention Station design features that are important to core damage prevention include the SAFW system, limited requirements for ventilation, the service water system design, and use of the City Water system. These are briefly discussed in the following paragraphs.

Page E-5

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report The SAFW system comprises two 100 percent motor-driven pumps that are completely redundant to the preferred auxiliary feedwater system. The SAFW system was installed to mitigate the potential common-mode failures of the preferred auxiliary feedwater system (e.g., high energy line breaks in the Intermediate Building). As such, four motor-driven auxiliary feedwater pumps and one turbine driven auxiliary feedwater pump are available, any one of which can facilitate steam generator cooling.

The Ginna Station layout typically does not include the use of compartments or rooms to protect various trains from one another. Instead, system components are generally grouped together on one floor level. This configuration eliminates the need for dynamic equipment cooling by enabling passive cooling to occur via the large air volumes and recirculation.

The service water system design is one of a large loop header that is supplied by four pumps. Two pumps are powered from one electrical train and two pumps are powered from a second electrical train. In-series motor-operated valves are also provided at various points to isolate non-critical loads on the loop header. Any one of the four service water pumps can provide cooling water to any system load. This design allows significant flexibility, which reduced the service water contribution to core damage.

The City Water system is used to supply plant domestic loads and the yard fire loop.

The yard fire loop consists of the fire hydrants that are located outside the power block. Sprinkler systems and hose reels within the power block are supplied by two onsite fire pumps (one motor- driven and one diesel-driven). In the event that all service water is lost, the City Water system can be used to supply the SAFW system and provide cooling water to the diesel generators.

E.1.4.2 Summary of Station Modifications As a result of the insights gained from the Ginna Station PSA, RG&E has implemented station modifications or procedural changes to address identified vulnerabilities. The following vulnerabilities have been addressed:

" Standby auxiliary feedwater system out-of-service activities - The SAFW system is specifically credited for providing steam generator cooling water in the event of a high energy line break in the Intermediate or Turbine Building.

Procedural modifications were made to avoid situations in which both trains of the SAFW system could be taken out of service at the same time.

" Removal of large service water piping within battery rooms - The service water piping that ran through the two battery rooms was relocated to avoid the potential loss of both battery rooms due to failure in isolating non-safety related service water line breaks prior to flooding the rooms and failing direct-current equipment.

" Procedural guidance for relay room internal floods - The procedure, "Alternate Shutdown for Control Complex Fire," was revised to also apply to relay room floods. Previously the relay room procedure only addressed fire.

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R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E -Environmental Report

" Fire in the diesel generator B vault - A new procedure was developed to instruct plant personnel to manually close the Bus 18 breakers to prevent a station blackout condition in the event of a worst-case fire that fails the B electrical train (Buses 16 and 17) and offsite power and control power to Bus 18 of electrical train A, which, in turn, would result in loss of all service water.

" Guidance in control room evacuation due to fires - Changes were made to the control room evacuation procedures to require entry into the emergency operating procedures to provide necessary core cooling.

Page E-7

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report E.2 Melcor Accident Consequences Code System Modeling This section of Appendix E describes the assumptions made and the results of modeling performed to assess the risks and consequences of severe accidents (U.S.

Nuclear Regulatory Commission Class 9).

The Level 3 analysis was performed using the Melcor Accident Consequences Code System (MACCS) 2 code (Ref. E.2-1). MACCS2 simulates the impacts of severe accidents at nuclear power plants upon the surrounding environment. The principal phenomena considered in MACCS2 are atmospheric transport, mitigative actions based on dose projections, dose accumulation by a number of pathways including food and water ingestion, early and latent health effects, and economic costs. Input for the Level 3 analysis includes the reactor core radionuclide inventory, source terms from the Ginna Station PSA model, site meteorological data, projected population distribution (within a 50-mile radius), emergency response evacuation modeling, and economic data. These inputs are described in the following section.

E.2.1 Input Data The input data required by MACCS2 are outlined below.

E.2.1.1 Core Inventory RG&E calculated the core inventory activity for fission products and actinides for the purpose of developing sources for use in dose calculations. The core inventory data are presented in Table E.2-1. The core inventory was evaluated at the end of a 525 day fuel cycle and was conservatively based on plant operation at 102 percent of the power level [1,550 megawatts (thermal)] to allow for calibration error. The equilibrium core at the end of a fuel cycle is assumed to consist of fuel assemblies with three different burnups, i.e., approximately 1/3 of the core is subjected to one fuel cycle, 1/3 of the core to two fuel cycles, and 1/3 of the core to three fuel cycles.

Minor variations in fuel irradiation times and duration of refueling outages will have a slight impact on the estimated inventory of long-lived isotopes in the core. However, these changes will have an insignificant impact on the radiological consequences of postulated accidents.

E.2.1.2 Source Terms The atmospheric source terms used in the MACCS2 model were obtained from the latest Level 2 Ginna Station PSA model analysis.

E.2.1.3 Meteorological Data Ginna Station meteorological data for calendar years 1992, 1993, and 1994, were considered. For these years, consecutive hourly meteorological data (wind speed, wind direction, stability class, and precipitation) were placed in MACCS2 format.

Where data blocks were missing in the source files, supplementary information was Page E-8

R.E. Ginna Nuclear Power Plant Applicat16n for Renewed Operating License Appendix E Appendix E - Environmental Report Table E.2-1 Ginna Station Core Inventory Nuclide Fraction Nuclide Fraction Kr-85 4 98E+05 Tc-99m 6.94E+07 Kr-85m 1.11E+07 Ru-1 03 6.34E+07 Kr-87 2.13E+07 Ru-1 05 4.34E+07 Kr-88 3.00E+07 Ru-1 06 2.25E+07 Xe-131m 4.55E+05 Rh-1 05 3.98E+07 Xe-133 8 19E+07 Sb-127 4.50E+06 Xe-1 33m 2.67E+06 Sb-129 1.34E+07 Xe-135 2.17E+07 Te-127 4 45E+06 Xe-1 35m 1.67E+07 Te-127m 5.81 E+05 Xe-138 7.04E+07 Te-129 1.32E+07 1-131 4.16E+07 Te-129m 1.96E+06 1-132 6 03E+07 Te-131 m 6.05E+06 1-133 8.53E+07 Te-132 5 93E+07 1-134 9 35E+07 Ba-139 7.62E+07 1-135 7.97E+07 Ba-140 7.34E+07 Rb-86 1.01E+05 La-140 7.87E+07 Cs-1 34 9.46E+06 La-141 6 95E+07 Cs-136 2.48E+06 La-142 6.72E+07 Cs-137 5 43E+06 Ce-141 6 97E+07 Sr-89 4.07E+07 Ce-143 6.47E+07 Sr-90 3.94E+06 Ce-144 5.43E+07 Sr-91 5 06E+07 Pr-143 6.27E+07 Sr-92 5 47E+07 Nd-147 2.79E+07 Y-90 4.09E+06 Pu-238 1.98E+05 Y-91 5 25E+07 Pu-239 1.61E+04 Y-92 5.49E+07 Pu-240 2.44E+04 Y-93 6.34E+07 Pu-241 5.41E+06 Nb-95 7.13E+07 Np-239 8 45E+08 Zr-95 7.07E+07 Am-241 6 87E+03 Zr-97 7.03E+07 Cm-242 1.48E+06 Mo-99 7.92E+07 Cm-244 2.1 OE+05 Page E-9

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report derived from meteorological data obtained from the National Oceanic & Atmospheric Administration (NOAA) from the Rochester Airport, approximately 15 miles west of Ginna Station (Ref. E.2-2). The available NOAA data were insufficient to calculate the stability factors; therefore, these factors were taken from the National Climatic Data Center (Ref. E.2-3). Comparison of the meteorological data for years 1992 1994 were used to demonstrate that the 1992 data set is both a reasonable and conservative data year for use as a representative year for the offsite risk calculation (see Appendix Section E.2.3 for a discussion of the sensitivity case for weather).

E.2.1.4 Emergency Response To determine the appropriate emergency response assumptions, RG&E reviewed the Ginna Station Nuclear Emergency Response Plan (Ref. E.2-4) and the New York State Radiological Emergency Preparedness Plan (Ref. E.2-5) coupled with local geographic and demographic characteristics. RG&E determined that a 7,200 second evacuation delay time and a 1.8 meters per second evacuation speed were appropriate. RG&E also assumed that 95 percent of the population surrounding the plant would evacuate in an emergency.

E.2.1.5 Population Distribution For consistency within the site data file, RG&E initially used a projected year-2000 population distribution in the base case analysis and performed a sensitivity analysis on the projected year-2030 population distribution (see Section E.2.3) to determine the effect of increased population on the offsite consequences. The results indicate that the average increase across all the release categories is greater than 20 percent for both dose and economic cost and, therefore, the year 2030 population projection is used in the analysis. This also accounts for increased population near the end of plant life.

To generate the population input data, RG&E used the RSICC code SECPOP90:

Sector Population, Land Fraction, and Economic Estimation Program (Ref. E.2-6) as the baseline population distribution for estimating the projected population used in the analysis. The 50-mile region includes the Rochester Metropolitan Area and 13 counties that are completely or partially within the 50-mile radius. SECPOP90 provides the population distribution by sectional rosette centered on the Station and divided into 9 radial intervals out to 50 miles. The rosette consists of 16 directional sectors, the first of which is centered on due north, the second on 22.5 degrees east of north, and so on. The total 1990 population residing in the 50-mile radius region was estimated to be 1,222,212 persons.

SECPOP90 uses year 1990 block level census data to calculate the population within each rosette section. Given that the year 2000 census data at the block level were not available at the time the Level 3 model was prepared, the SECPOP90 population data input file could not be updated by block group before the rosette population matrix was generated. Therefore, the 1990 population numbers were updated by rosette sector after running SECPOP90. RG&E extracted county-level data from the year 2000 census data to develop a weighted average population projection for each rosette section. Changes in population between 1990 and 2000 were calculated under the assumption that increase or decrease in the population for Page E-10

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report each rosette section within a given county were the same as those for the county as a whole and that residents are uniformly distributed throughout each county and within the portion of the county contained within a rosette section. Specifically, the 1990 rosette population value was projected for year 2000 by using the ratio of 1990 to 2000 county populations multiplied by the estimated fraction of each county included within the respective rosette section. The county population change factors were applied to the respective rosette section to generate a population distribution for year 2000. The total year 2000 50-mile radius population estimate is 1,260,679 persons.

The 50-mile population data presented in Section 2.7 of the environmental report were calculated using Geographic Information System techniques and year 2000 census data at the census block level. Using this technique the 50-mile population was estimated to be 1.25 million. This comparison demonstrates that the projection method used in the Level 3 model is reasonable.

The year 2000 to year 2030 projection was developed using the same methodology with county population projections obtained from Cornell University for year 2020 (Ref. E.2-7) as input for determining long-term population trends. Yearly growth rates for each county between 1990 to 2000, 2000 to 2020, and 1990 to 2020, were averaged and used to calculate a 30-year growth rate that was applied to the year 2000 population projection, thus creating a year 2030 projection. To account for non-linear population growth, RG&E incorporated a 10 percent population multiplier into the projection. The total 50-mile population projected for year 2030 is estimated to be 1.57 million.

E.2.1.6 Land Fractions Land fractions represent the portions of the total surface area which are land for each sector, and they are calculated using an algorithm that weights the county-level land fraction data. This is possible because the code contains a county level database with the land fractions for each county and every record in the block level database includes the area of the block and a code to indicate which county in the U.S. the block resides.

RG&E used the values generated by the SECPOP90 code for each rosette section directly in the analysis.

E.2.1.7 Regional Economic Data Agricultural economic data required for MACCS2 include (Tables E.2-2 and E.2-3):

1) the fraction of land devoted to farming;

2) the farmland property values;

3) the total annual farm sales; and

4) the fraction of farm sales resulting from dairy production.

The SECPOP90 database includes county economic data derived from the year 1990 census and various other government documents dated 1992 to 1994. For Page E-11

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report Table E.2-2 MACCS2 Agricultural Data Fraction of Fraction of Farm Farmland Land Devoted Sales Resulting from Total Annual Farm Property Values County to Farming Dairy Production Sales ($/hectare) ($/hectare)

Cayuga 0.567551 0.548727 1,133 3,270 Genesee 0.540334 0446257 1,585 3,324 Livingston 0.487920 0.547562 913 3,354 Monroe 0.244337 0.126225 1,149 5,329 Onondaga 0.294566 0.528181 1,192 3,753 Ontario 0450810 0.421387 1,036 4,333 Orleans 0.572415 0.110997 1,071 3,279 Oswego 0.168057 0.348064 7,58 3,468 Seneca 0.564681 0.362439 864 3,245 Steuben 0.391511 0.531443 557 2,295 Wayne 0.432344 0.140398 1,590 4,777 Wyoming 0.513566 0818453 1,707 3,431 Yates 0.484063 0423508 949 4,654 Table E.2-3 Per Capita Regional Economic Data Non-Farm Wealth Farm Wealth Value Non-Farm Wealth County ($/hectare) Value ($/person)

Cayuga 3,270 100,317 Genesee 3,324 108,797 Livingston 3,354 107,174 Monroe 5,329 139,306 Onondaga 3,753 129,254 Ontario 4,333 128,273 Orleans 3,279 90,333 Oswego 3,468 101,637 Seneca 3,245 104,222 Steuben 2,295 129,213 Wayne 4,777 110,002 Wyoming 3,431 88,504 Yates 4,654 93,849 Page E-12

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report preparation of the Ginna Station Level 3 model the SECPOP90 site input file was manually updated to circa 2000 for the 13 counties within 50 miles of the plant.

Therefore, the Level 3 input files contain updated values for each economic region and, hence, for each sector. The agricultural economic data were updated using available data from the 1997 Census of Agriculture (Ref. E.2-8) supplemented by data available through other federal agencies (Ref. E.2-9; Ref. E.2-1 0; Ref. E.2-1 1; Ref. E.2-12).

Additional regional economic data factored into the Ginna Station risk analysis includes the value of farm wealth, the fraction of farm wealth in the region due to improvements, and the value of non-farm wealth. The value of farm wealth and non farm wealth by county are presented in Table E.2-3. The fraction of farm wealth in the region due to improvements was calculated to be 0.11 using the average farm wealth (Table E.2-3) and the average value of farm real estate (Ref. E.2-9).

E.2.1.8 Food Pathway Assumptions The MACCS2 ingestion model preprocessor, COMIDA2, was used to model the ingestion pathway. Crop season and share data were not used, as the ingestion model uses diet assumptions versus agricultural production to define food intake.

However, the COMIDA2 code does require input for waterborne nuclides of concern for the water ingestion model, as well as, food. RG&E identified the four nuclides, Sr-89, Sr-90, Cs-1 34, and Cs-1 37, as input to the ingestion model.

Based on the size, Lake Ontario could be treated as an ocean watershed with zero uptake. However, RG&E conservatively treated the Lake as a lake watershed since, unlike an ocean, it is a source of drinking and irrigation water.

E.2.1.9 Deposition Velocities RG&E calculated a Ginna Station specific deposition velocity value of 0.2 meters per second. The range of values recommended in NUREG/CR-4551 (Ref. E.2-13) is 0.03 to 3.0 with a specific recommendation of 0.3. Considering the surrounding terrain and the formula provided in NUREG/CR-4551, a site-specific value was calculated.

E.2.2 Results The result of the Level 3 model is a matrix of offsite exposure and offsite property costs associated with a postulated severe accident in each release category. This matrix was combined with the results of the Level 2 model to yield the probabilistic offsite dose and probabilistic offsite property damage resulting from the analyzed plant configuration. Using the bounding base case (year 2030 population projection plus 10 percent and 10 percent source term increase), the offsite exposure risk for Ginna Station is 4.09 person-rem per year. Table E.2-4 provides the baseline exposures associated with each release category. The offsite exposure risk was calculated by multiplying the frequency of the release by the dose.

The bounding base case offsite economic risk is $24,100 per year. Table E.2-4 also provides the base case offsite economic costs associated with each release Page E-13

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report Table E.2-4 Summary of Offsite Consequences Offsite Offsite Offsite Dose Offsite Economic Economic Release Category Frequency (person-rem) Dose Risk Costs ($) Risk ($)

Intact Containment 3.75E-05 2.27E+04 0.851 2.82E+07 $1,058 ISLOCA 4.OOE-09 1.76E+07 0.070 2.27E+10 $91 LOCI 1.51E-07 3 38E+06 0.510 1.11E+10 $1,676 SGTR WET 1.020E-06 1.15E+06 1.171 9.43E+09 $9,600 SGTR DRY 0.0 4 62E+06 0 000 1.82E+10 $0 SGTR ARV Cycle 9.25E-09 6 89E+05 0 006 5.62E+09 $52 Late Failure Global 5.65E-07a 9.39E+05 0 531 9.41 E+09 $5,317 Late Failure Small 5 65E-07a 4.51E+05 0.255 2.19E+09 $1,237 TISGTR 1.84E-08 4.72E+06 0.087 1.90E+10 $350 HPRCS 4.43E-07 1.36E+06 0 602 1.06E+10 $4,696 LPRCS 3.40E-08 1.94E+05 0 007 8.07E+08 $27 Total 3.97E-05 4.09 $24,100

a. This value represents the total release frequency for both "global" and "small" containment failures ARV = atmospheric relief valve HPRCS = high pressure reactor coolant system break ISLOCA = interfacing system loss-of-coolant accident LOCI = loss of containment isolation LPRCS = low pressure reactor coolant system break SGTR = steam generator tube rupture TISGTR = thermally induced steam generator tube rupture category. The economic risk for each release category was calculated by multiplying its frequency by the corresponding economic costs.

The final result of a Level 3 evaluation of a SAMA is a value of the cumulative dose expected to be received by offsite individuals and a value of the expected offsite property losses due to severe accidents given the plant configuration under evaluation.

E.2.3 Sensitivity Analysis Sensitivity analyses were performed to assess variations in certain input factors including weather, population projections, and fission product release.

E.2.3.1 Weather Data from the years 1992 to 1994 were input into the MACCS2 code for the base case. Dose and cost results for each release category was compared to the average for the three-year period. The results show that the total dose and cost results for the most severe release category (ISLOCA) are within 12 percent of the average.

This indicates that the offsite consequences are not highly sensitive to year-to-year Page E-14

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report variations in weather for the years evaluated. While there is no single year in which all release cases yield the most conservative results, the 1992 data yield results above the three-year average for all releases. Therefore, the 1992 meteorological data are both reasonable and conservative for use in the base case calculation.

E.2.3.2 Population The initial base case evaluation was performed using year 2000 data, and a sensitivity case was performed using projections to year 2030 plus 10 percent. The results indicate the projected population would increase 25 percent over the year 2000 50-mile population, and the resulting effect on the offsite consequences averaged greater than a 20 percent increase for both offsite dose and economic costs. Given the significance of this increase, the year 2030 population projection plus 10 percent was used in the analysis.

E.2.3.3 Fission Product Release A sensitivity analysis was performed for a 10 percent increase in fission product release. The core inventory was increased by 10 percent while maintaining the release fractions. While short-term dose effects are proportional to the releases, the impact of long-term dose effects associated with groundshine, resuspension, and ingestion is limited by the use of MACCS2 interdiction triggers, which are based on U.S. Environmental Protection Agency Protective Action Guide dose limits. These triggers impact population relocation, ingestion, and long-term land uses. A 10 percent increase in the source term results in an approximate 7 percent increase in population dose increase.

E.2.3.4 Conclusion The magnitude of the results presented above indicates that the variation in population and source term should be considered in the offsite consequence calculation. Therefore, in order to bound these uncertainties, RG&E used the year 2030 population projection plus 10 percent and the 10 percent source term increase as input into the MACCS2 model for the base case calculation, as well as the evaluation of each potential modification. This represents a bounding analysis for the purposes of evaluating the offsite consequences for Ginna Station during the period of extended operation.

Page E-15

R E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report E.3 SAMA Assessment Sheets This section includes an evaluation summary for each of the eight SAMAs RG&E evaluated in the cost-benefit analysis. Each summary includes a Ginna Station specific description of the candidate SAMA, a discussion of the potential benefits, a summary of the evaluation and resulting benefits, and a discussion of the associated implementation costs.

Page E-16

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report SEVERE ACCIDENT MITIGATION ALTERNATIVE ASSESSMENT SHEET SAMA No. 1 TITLE: Obtain a skid-mounted 480V diesel generator

Description:

Obtain a skid-mounted 480 volt (V) diesel generator that could be directly connected to one train of the safeguards buses in the event of a failure of the two existing diesel generators. Rather than relying on station blackout (SBO) mitigation equipment that is alternating current (AC)-independent, an additional skid-mounted diesel capable of carrying SBO mitigation loads could be added to make the SBO mitigation strategy be alternate AC. The size of the diesel is 1000 kilowatts. The diesel would not be safety-related, and would be subject to quality assurance controls per NRC Regulatory Guide 1.155.

SAMA Benefits:

RG&E assumes that all SBO sequences would be mitigated with the availability of a skid-mounted diesel generator.

Evaluation:

RG&E assumes that the failure rate for the skid-mounted diesel generator is the same as for the existing diesel generators (i.e., failure to start (FTS) = 1.01 E-02 and failure to run (FTR) = 4.46E-02). Analysts conservatively assume a failure rate of 0.01 for the operators correctly connecting the diesel generator to a safeguards train.

This was simulated by changing the value of SBO from 1.0 to 0.0647 (i.e., 0.0101 +

0.0446 + 0.01) in both the CDF and large early release frequency (LERF) cutset files. The resulting delta CDF value is 5.88E-06, and the delta LERF is 1.52E-07.

The reduction in population dose is estimated to be 4.39 person-rem per year.

Cost of Implementation RG&E estimates the cost of the skid-mounted diesel to be approximately $250,000.

Additional costs related to training, procedure revision, and documentation are estimated at $100,000, and breakers, cabling, fuel storage, and oil abatement facilities are estimated to cost an additional $50,000, for a total cost of $400,000.

Page E-17

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report SEVERE ACCIDENT MITIGATION ALTERNATIVE ASSESSMENT SHEET SAMA No. 2 TITLE: Obtain a third fire water source independent of existing suction source for the motor- and diesel-driven fire pumps

Description:

Obtain a third fire water source independent of existing suction source for the motor and diesel-driven fire pumps (potentially a portable connection to the discharge canal). This would be used in the event of a total loss of the screenhouse due to a fire or flood or loss of all service water section due to environmental causes (e.g., frazile ice, seagrass, etc.). The pump should be of comparable size to the current pumps, since the functions would be comparable. The pump could be connected to the existing fire water piping and used for fire suppression or as a source of suction to the auxiliary feedwater pumps. It need not be safety-related, but would be subject to specified quality assurance requirements.

SAMA Benefits:

This SAMA would mitigate the loss of all auxiliary feedwater due to a failure of the service water suction source or a global failure of the screenhouse equipment due to fire or flooding (either in the screenhouse or other areas that will fail the equipment e.g., relay room), or loss of service water section due to environmental concerns.

Evaluation:

RG&E assumes that the failure rate for the new diesel-driven fire pump is the same as for the existing one (i.e., FTS = 9.36E-04 and FTR = 3.18E-03). Analysts assume a failure rate of 0.1 for the operators correctly connecting the new diesel-driven pump to the SAFW system. Since use of the yard loop is always an option in these cases (i.e., event AXHFDCITYW or AXHFDSAFWX is in all of the cutsets), the value of 0.1 assumes dependence with these other events (i.e., if operators fail to use the yard loop, there is an increased probability that they will fail to use the portable diesel pump). Simulate this by changing the value of AXHFDCITYW from 1.5E-02 to 1.5E 03 (i.e., 1.5E-02

• 0.1, since this failure dominates the equipment failures) and AXHFDSAFWX from 5.2E-03 to 5.2E-04 in both the CDF and LERF cutset files.

Resulting CDF and LERF reduction values are 2.13E-06 and 5.OE-09, respectively.

This new pump could also be used to recover fire events where the existing diesel driven fire pump fails. Again, assume that the failure rate for the new diesel-driven fire pump is the same as for the existing one (i.e., FTS = 9.36E-04 and FTR = 3.18E 03). In this case, however, the operator failure would be independent of any other human failure and is estimated at 0.01. Simulating this model change by changing the value of events FSDGFPFP01 and FSDGAPFP01 from 3.18E-03 and 9.36E-04, respectively, to 4.19E-05 [i.e., 3.18E-03 * (3.18E-03 + 0.01)] and 1.02E-05

[i.e., 9.36E-04 * (9.36E-04 + 0.01)] results in a CDF reduction of 7.OE-08 and a 9.OE 09 reduction in the LERF.

Thus the total expected change is 2.13E-06 + 7.OE-08 = 2.20E-06 for CDF and 5.OE 09 + 9.OE-09 = 1.40E-08 for LERF. The reduction in population dose is estimated to be 1.63 person-rem per year.

Page E-18

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report SEVERE ACCIDENT MITIGATION ALTERNATIVE ASSESSMENT SHEET SAMA No. 2 (continued)

TITLE: Obtain a third fire water source independent of existing suction source for the motor- and diesel-driven fire pumps Cost of Implementation:

RG&E estimates the cost of the electric motor-driven pump to be $100,000, and estimates the associated procedure revisions, training, and documentation to be

$50,000. The breaker and cabling would add an additional $50,000, for total cost of

$200,000.

Page E-19

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report SEVERE ACCIDENT MITIGATION ALTERNATIVE ASSESSMENT SHEET SAMA No. 3 TITLE: Add a standby charging pump powered from a protected AC source

Description:

This SAMA involves adding a standby charging pump powered from a protected power source and located in the Intermediate or Turbine Building, or SAFW Pump Building. These locations would avoid the failure mechanisms discussed below. It would not have to be safety-related, and so could be powered from Bus 13 or 15 in the Turbine Building. It would have to be mounted so its failure would not adversely affect safety-related equipment. Connections to existing charging lines would have to be safety-related. Bus 13 or 15 would have to be upgraded to achieve the quality assurance requirements for a protected AC source. Significant technical issues to resolve include providing a high volume, primary-grade-quality water source, including the capability to inject borated water.

SAMA Benefits:

This new pump could be used to mitigate fires requiring entry into procedure "Alternate Shutdown for Control Complex Fire" or fires disabling train B, where the A charging pump is out of service or fails to run. It could also be used to mitigate fires in the Charging Pump Room, floods in the Auxiliary Building that fill the basement to a level that will fail all charging, or other failures of all three pumps.

Evaluation:

RG&E assumes that all cutsets that have the following:

a) Charging pump A out of service or failed directly (i.e., not by the initiator or support system failure), or b) an Auxiliary Building flood that is sufficiently large to fill the basement to a critical height and disable all three charging pumps (event IFAZDABISL), or c) a Charging Pump Room fire (event FIOOOCHG),

can be mitigated by using the Intermediate Building charging pump powered from Bus 14. Analysts assume that the Intermediate Building pump would autostart on low flow or pressure (i.e., without operator action). The failure rates for starting and running of the pump are 5.11E-05 and 7.22E-04, respectively (i.e., the same as the existing pumps). RG&E simulated this modification by:

a) Changing the value of CVTMCHPMPA from 7.04E-02 to 5.44E-05 [i.e., 7.04E-02

• (5.11 E-05 + 7.22E-04)] in both the CDF and LERF cutset files; b) Changing the value of CVMPAPCH1A from 5.11E-05 to 2.61 E-09 [i.e., 5.11E-05

• 5.11E-05] and CVMPFPCH1A from 7.22E-04 to 5.21E-07 [i.e., 7.22E-04

• 7.22E-04];'

c) Changing the value of IFAZDABISL from 0.1 to 7.73E-5 [i.e., 0.1 * (5.11 E-05 +

7.22E-04)] in both the CDF and LERF cutset files. Note that this is a very conservative number in that it does not take into account failures of the support systems for the new pump (i.e., suction source, AC power, etc.); and Page E-20

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report SEVERE ACCIDENT MITIGATION ALTERNATIVE ASSESSMENT SHEET SAMA No. 3 (continued)

TITLE: Add a standby charging pump powered from a protected AC source d) Changing the value of FI000CHG from 5.4E-03 to 4.17E-06 [i.e., 5.4E-03 *

(5.11 E-05 + 7.22E-04)] in both the CDF and LERF cutset files. (Note that event FI000CHG does not appear in either file).

The resulting delta CDF is 5.86E-06, and the delta LERF is 1.29E-07. The reduction in population dose is estimated to be 0.23 person-rem per year.

Cost of Implementation:

Cost of hardware modifications is estimated to be greater than $1,000,000 for the pump, piping, valves, engineering analysis, hangers, supports, bus upgrades, cabling, and instrumentation. Procedure revisions, training, and documentation are estimated at $100,000, for a total of $1.1 million.

Page E-21

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report SEVERE ACCIDENT MITIGATION ALTERNATIVE ASSESSMENT SHEET SAMA No. 4 TITLE: Modify procedures to allow charging pump B or C to be manually aligned to Bus 14

Description:

This SAMA involves a procedure modification to allow charging pump B or C to be manually realigned to Bus 14. This alignment could be used to mitigate fires requiring entry into procedure "Alternative Shutdown for Control Complex Fire" or fires disabling train B, where the A charging pump is out of service or fails to run. An existing spare cable could be routed from Bus 14 to either pump B or C using existing connections.

SAMA Benefits:

This alignment could be used to mitigate fires requiring entry into procedure "Alternative Shutdown for Control Complex Fire" or fires disabling train B, where the A charging pump is out of service or fails to run.

Evaluation:

RG&E assumes all cutsets in which charging pump A is out of service or failed directly (i.e., not by the initiator or support system failure), can be mitigated by swinging the B or C pump to Bus 14. Analysts conservatively assume that the failure rate for the operators swapping the pump over is 2.OE-03 (0.1 times the value of CVHFDSUCTN), and the failure rates for starting and running the pump are 5.11E 05 and 7.22E-04, respectively. RG&E simulated this modification by:

a) Changing the value of CVTMCHPMPA from 7.04E-02 to 1.94E-04 [i.e., 7.04E-02

• (0.002 + 5.11E-05 + 7.22E-04)] in both the CDF and LERF cutset files; and b) Changing the value of CVMPAPCH1A from 5.11E-05 to 1.42E-07 [i.e., 5.11E-05

• (0.002 + 5.11E-05 + 7.22E-04)] and CVMPFPCH1A from 7.22E-04 to 2.OOE-06

[i.e., 7.22E-04 * (0.002 + 5.11 E-05 + 7.22E-04)] in both the CDF and LERF cutset files.

The resulting delta CDF is 4.78E-06, and the delta LERF is 1.31E-07. The reduction in population dose is 0.21 person-rem per year.

Cost of Implementation:

RG&E estimates the modification to the procedure and associated training costs to be $20,000.

Page E-22

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report SEVERE ACCIDENT MITIGATION ALTERNATIVE ASSESSMENT SHEET SAMA No. 5 TITLE: Add redundant check valves in the two RHR injection lines to the RCS

Description:

Install redundant check valves upstream of check valves 853A and 853B. Currently, the position of the 853A and 853B check valve obturators are checked on a refueling outage frequency to ensure the check valves have properly closed. However, if the check valve fails or leaks in between refueling outages, there is no indication of this condition. A spurius safety injection (SI) would cause motor-operated valves (MOV) 852A and 852B to open, allowing the 2250 pounds per square inch (psi) reactor coolant to directly interface with the 600 psi residual heat removal (RHR) piping, potentially resulting in a loss-of-coolant accident (LOCA) in the Auxiliary Building, which could not be isolated. A second check valve in these lines would reduce the probability of this event. The new check valves would be Safety Class 1, 2500 psi rated, safety related.

SAMA Benefits:

Adding redundant check valves in series with check valves 853A and 853B would reduce the ISLOCA frequency in the two RHR injection lines.

Evaluation:

This modification would reduce the ISLOCA frequency for those two lines through penetration 111 (although it would not affect the line containing 720 and 721), since the new alignment would require failure of both check valves and the MOV, or both check valves and an inadvertent opening of the MOV, or a spurious SI signal which opens the MOV.

Based on Table 8-4 equation 2 from the PSA final report, the probability of an ISLOCA in a line with two check valves and a normally closed MOV is:

AT = {[T2(AL2 + 2ALAR + AR2 ) + AHT(AL+ AR) + T(CCFR + CCFL)] * [T(AML+ AMR)

+ AMH]}/PCF However, this equation assumes that the MOV is locked closed and, therefore, not subject to an operator opening the valve, or opening due to an inadvertent SI. Since that is not the case for this line, equation 2 must be modified to account for these two events. In addition, there is the potential for the operators to close the MOV, if it is inadvertently opened or opens on a spurious SI. Per Table 7-15 from the PSA final report, the probability that operators fail to close the MOV is 0.04. Therefore, the equations becomes:

AT = {[T2(AL2 + 2ALA\R + AR2 ) + \HT(AL+ AR) + T(CCFR + CCFL)] * [T(A\ML+ AMR)

+ AMH + (0.04)AMO] + [T2(AL2 + 2ALAR + AR2 ) + AHT(AL+ AR) + T(CCFR +

CCFL)]

• TSI(AMS)(0.04)}/PCF This simplifies to:

A\T = {[T2(AL2 + 2ALAR + AR2 ) + AHT(AL+ AR) + T(CCFR + CCFL)] * [T(AML+ AMR)

+ AMH + (0.04)(AMO + TSI(AMS))])/PCF Page E-23

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report SEVERE ACCIDENT MITIGATION ALTERNATIVE ASSESSMENT SHEET SAMA No. 5 (continued)

TITLE: Add redundant check valves in the two RHR injection lines to the RCS Using the data values from Table 8-5 of the PSA final report gives:

AT = {[(6570 hr)2((6.8E-07/hr)2 + 2(6.8E-07/hr)(1.0E-07/hr) + (1.OE-07/hr)2 ) +

(2.7E-04)(6570 hr)(6.8E-07/hr + 1.OE-07/hr) + (6570 hr)((3.OE-03)(6.8E-07/hr)

+ (3.0E-03)(1.0E-07/hr))] * [(6570 hr)(5.7E-07/hr + 1.6E-09/hr) + 2.7E-04 +

(0.04)(2.68E-04 + (6570 hr)(6.30E-06/hr))}/.923

= {[(6570 hr)2(6.084E-13/hr2) + (6570 hr)(2.106E-10/hr) + (6570 hr)(2.34E 09/hr)]*[(6570 hr)(5.716E-07/hr) + 2.7E-04 + (0.04)(4.166E-02)]}/.923

= {[2.626E-05 + 1.384E-06 + 1.537E-05]*[3.755E-03 + 2.7E-04 + 1.67E-3]}/.923

= {4.301 E-05

• 5.69E-03}/.923

= (2.447E-07 )/.923

= 2.652E-07/yr Multiplying this by 2 and adding to the CDF from the third line in this penetration (i.e.,

the line containing 720 and 721) results in a total CDF from this penetration of:

2*2.652E-07 + 1.05E-05 = 1.1OE-05 Adding in the pipe break probability of 2.29E-02 results in a total CDF of:

1.1OE-05

• 2.29E-02 = 2.53E-07 Since a third of the RHR piping that would be exposed to Reactor Coolant System (RCS) pressure is inside containment, it was assumed that the LERF for this penetration would be a third of the CDF, or 8.433E-08. The current CDF contribution from this penetration is 1.576E-06, while the current LERF is 5.25E-07; therefore, the resulting delta CDF is 1.32E-06, and the delta LERF is 4.41 E-07. The population dose reduction would be 17.6 person-rem per year.

Cost of Implementation:

RG&E estimates the purchase, installation, analysis, and documentation of this modification is estimated to be at least $1,000,000. There is little room for installation of these check valves, which adds to the complexity of the installation/analysis. It is expected that additional supports would also be required to maintain this piping Seismic Category I.

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R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report SEVERE ACCIDENT MITIGATION ALTERNATIVE ASSESSMENT SHEET SAMA No. 6 TITLE: Modify the motor-driven AFW pump cooling system to be independent of SW

Description:

Modify the motor- and turbine-driven AFW pump cooling system to be independent of SW. This would route AFW flow from the discharge of the pumps through a breakdown orifice to self-cool the outboard bearings and lube oil coolers. This would eliminate the dependency on the SW and fire water systems for cooling those components.

SAMA Benefits, This SAMA would prevent failure of the motor-driven AFW pumps in the event of a loss of all suction to the fire and SW pumps, or a loss of the screenhouse due to fire or flood.

Evaluation:

RG&E assumes all cutsets that involve a loss of all AFW due to a failure of the SW suction source or a global failure of the screenhouse equipment due to fire or flooding [either in the screenhouse or other areas that will fail the equipment (e.g.,

relay room)] will no longer lead to core damage due to the availability of the motor driven pumps. Failure rates for the motor-driven AFW pumps to start and run are 9.85E-04 and 3.58E-04, respectively. Analysts simulate this by changing the value of AXHFDCITYW from 1.5E-02 to 2.01E-05 [i.e., 1.52E-02 * (9.85E-04 + 3.58E-04)]

and AXHFDSAFWX from 5.2E-03 to 6.97E-05 [i.e., 5.2E-02 * (9.85E-04 + 3.58E-04)]

in both the CDF and LERF cutset files. The expected delta CDF is estimated to be 2.32E-06 and the delta LERF is estimated to be 6.OOE-09. The resulting reduction in population dose is estimated to be 0.05 person-rem per year.

Cost of Implementation:

RG&E estimates the cost of this safety-related modification, including parts, construction, analysis, testing, and documentation to be approximately $200,000.

Page E-25

R E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report SEVERE ACCIDENT MITIGATION ALTERNATIVE ASSESSMENT SHEET SAMA No. 7 TITLE: Modify AOV 112C to fail closed and AOV 112B to fail open on loss of instrument air

Description:

This SAMA involves a modification to air-operated valve (AOV) 11 2C to fail closed and AOV 112 B to fail open on loss of instrument air. This change would allow the refueling water storage tank (RWST) to become the suction source for charging, instead of the volume control tank (VCT) which has limited volume.

SAMA Benefits:

This SAMA would eliminate the need for manual operator actions on low VCT levels (manual actions are required to prevent introducing air into the charging system when the VCT voids).

Evaluation:

This modification would eliminate the need for operators to manually switch over the suction source from the VCT to the RWST (event CVHFDSUCTN). RG&E assumes all cutsets that contain event CVHFDSUCTN can be mitigated by this modification.

Analysts simulate this change by setting CVHFDSUCTN to false in both the CDF and LERF cutset files. The resulting reduction in CDF is 2.51 E-06 and the reduction in LERF is 1.44E-07. The resulting reduction in population dose is estimated to be 0.19 person-rem per year.

Cost of Implementation:

This change would require swapping the valve operators as well as making post modification control system adjustments and operating procedure changes. RG&E expects the cost of this modification to be approximately $50,000 for components, design, engineering, analysis, testing, and documentation.

Page E-26

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report SEVERE ACCIDENT MITIGATION ALTERNATIVE ASSESSMENT SHEET SAMA No. 8 TITLE: Reconfigure the PORVs so they transfer automatically from instrument air to N2 on low pressure and convert N2 supply line AOV to DC powered motor-operated valve

Description:

This SAMA involves reconfiguration of the power-operated relief valves (PORVs) so they transfer automatically from instrument air to N2 on low pressure and convert the N2 supply line AOV to DC powered motor-operated valve.

SAMA Benefits:

This SAMA would mitigate scenarios where the PORVs are not available due to a loss of instrument air, particularly for feed-and-bleed operations or rapid depressurization of the RCS.

Evaluation:

In order to quantify the effect of this modification, the model was altered to add a flag event to the gates representing failures of instrument air to the PORVs (430 and 431C). The following changes were made:

a) Under RC302A, replace RC321 with SDR1 011 AND RC321 RCAAIA0430 b) Under RC310A, replace RC351 with SDR1014 AND RC351 RCAAIA431C c) Under RC320, replace RC321 with SDR1011 d) Under RC350, replace RC351 with SDR1014 RCAAIA0430 and RCAAIA431C are flag events with a value of 1.0 that can be used to identify sequences where the PORVs fail due to loss of instrument air. Setting RCAAIA0430 and RCAAIA431C equal to 4.76E-03 (the failure rate of the components in the nitrogen system) results in a delta CDF of 3.60E-07 and a delta LERF of 5.OOE-09. Note that these values are conservative since the failure rate for the nitrogen system does not include support systems failures (e.g., direct current power) that may fail independently or be failed by the other failures in the cutset.

The reduction in population dose is estimated to be 0.01 person-rem per year.

Cost of Implementation:

Implementation of this SAMA would require logic and instrumentation changes as well as replacement of one or two safety-related environmentally qualified solenoid valves. Reanalysis of certain accident scenarios, such as anticipated transients without scram, may also be needed. Extensive changes to procedures, training, and documentation would also be needed. RG&E estimates the cost to be approximately

$400,000.

Page E-27

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report E.4 References Ref. E.1-1 R.C. Mecredy (RG&E) letter to the Document Control Desk (NRC),

"Generic Letter 88-20." March 15, 1994.

Ref. E.1-2 R.C. Mecredy (RG&E) letter to the Document Control Desk (NRC),

"Generic Letter 88-20, Level 1 Probabilistic Safety Assessment (PSA)." January 15, 1997.

Ref. E.1-3 R.C. Mecredy (RG&E) letter to the Document Control Desk (NRC),

"Generic Letter 88-20, Level 2 Probabilistic Safety Assessment."

August 30, 1997.

Ref. E.1-4 R.C. Mecredy (RG&E) letter to the Document Control Desk (NRC).

"Ginna Station Probabilistic Safety Assessment (PSA), Final Report."

Revision 4. February 15, 2002.

Ref. E.2-1 Oak Ridge National Laboratory. RSICC Computer Code Collection, MACCS2, Version 1.12, CCC-652 Code Package. 1997.

Ref. E.2-2 National Oceanic & Atmospheric Administration, National Climatic Data Center (NCDC). "Theoretical Meteorological Year (TMY) Data for Rochester, NY - DATSAV3 Surface." CD-ROM (TMY Data for 1992, 1993, and 1994).

Ref. E.2-3 National Oceanic & Atmospheric Administration, National Climatic Data Center (NCDC). "Theoretical Meteorological Year (TMY) Data for Rochester, NY."

http://rredc.nrel.qov/solar/old data/nsrdb/tmy2/State.html. Accessed February 22, 2002.

Ref. E.2-4 RG&E. Ginna Station Nuclear Emergency Response Plan (NERP).

Revision 20. Rochester, NY. October 19, 2000.

Ref. E.2-5 New York State Emergency Management Office. New York State Radiological Emergency PreparednessPlan. Available at:

http://www.nysemo.state.ny.us/radioloqical.html. Accessed January 14, 2002.

Ref. E.2-6 S. L. Humphreys, et al. "SECPOP90: Sector Population, Land Fraction, and Economic Estimation Program," NUREGICR-6525.

January 1999.

Ref. E.2-7 New York Statistical Information System. "New York State Data, Population Projections." http://www. nvsis.cornell.edu/data html.

Accessed October 25, 2001.

Ref. E.2-8 U.S. Department of Agriculture. 1997 Census of Agriculture- New York State and County Data. AC97-A-32, Volume 1. Geographic Area Series, Part 32.

Page E-28

R E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix E Appendix E - Environmental Report Ref. E.2-9 U.S Department of Agriculture, National Agricultural Statistics Service, "Agricultural Land Values, Final Estimates 1994- 1998."

Statistical Bulletin Number 957. Available at:

http://www.usda ,ov/nass/pubs/histdata.htm#sb.

Ref. E.2-10 U.S. Department of Labor, Bureau of Labor Statistics, "Consumer Price Index - U.S. City Average."

ftp://ftp.bls.gov/pub/special.requests/cpi/cpiai.txt. Accessed May 7, 2002.

Ref. E.2-11 U.S. Department of Commerce. "Statistical Abstract of the United States: 2000." March 2000. Available at:

http://www.census.qov/prod/Www/statistical-abstract-us.html.

Ref. E.2-12 Bureau of Economic Analysis, "Regional Accounts Data, Local Area Personal Income, Per Capita Personal Income." Available at:

http'/lwww.bea.doc.,qov/bea/regqional/reis. Accessed May 9, 2002.

Ref. E.2-13 J.L. Spring, et al. Evaluation of Severe Accident Risks:

Quantificationof Major Input ParametersMACCS Input.

NUREG/CR-4551, SAND86-1309. Vol. 2, Rev. 1, Part 7.

December 1990.

Page E-29

R.E. Ginna Nuclear Power Plant Application for Renewed Operating License Appendix F Appendix E - Environmental Report APPENDIX F. COASTAL MANAGEMENT PROGRAM CONSISTENCY DETERMINATION

COASTAL MANAGEMENT PROGRAM CONSISTENCY DETERMINATION New York has an approved coastal zone management program documented by the U.S. Nuclear Regulatory Commission (NRC) (Ref. 1). Rochester Gas and Electric Corporation (RG&E) has determined that the proposed R. E. Ginna Nuclear Power Plant (Ginna Station) license renewal complies with the New York-approved coastal management program and will be conducted in a manner consistent with such program.

Proposed Activity RG&E operates Ginna Station pursuant to NRC Operating License DPR-18, which will expire September 18, 2009. RG&E is applying to the NRC for renewal of the license, which would permit RG&E to operate Ginna Station for an additional 20 years (i.e., until September 18, 2029). License renewal would give RG&E the option of relying on Ginna Station to meet a portion of New York's future needs for electric generation.

Ginna Station is located on the southern shore of Lake Ontario in the Town of Ontario, in the northwest corner of Wayne County, New York, approximately 20 miles east of the center of the City of Rochester and 40 miles west-southwest of Oswego (see Figures 1 and 2).

Ginna Station is shown in Figure 3. The plant consists of a pressurized light-water reactor with two steam generators that produce steam that turns turbines to generate electricity. The plant is capable of an output of 1,520 megawatts (thermal) [MW(t)],

with a corresponding net electrical output of approximately 490 megawatts (electric)

[MW(e)].

Ginna Station utilizes a once-through heat dissipation system that withdraws cooling water from and discharges to Lake Ontario. RG&E uses small amounts of chlorine in the cooling water system that discharges to offsite surface waters. There are eleven outfalls permitted under the site's State Pollutant Discharge Elimination System permit. The main outfall is associated with the once-through and intake cooling water systems discharging through the discharge canal to Lake Ontario. The next seven of these are internal outfalls, discharging to the discharge canal and ultimately to Lake Ontario. The last three outfalls discharge to Mill Creek (as designated in the SPDES permit) and consist of two unmonitored storm water runoff outfalls and a Redundant House service water discharge.

Ginna Station uses once-through cooling water from Lake Ontario to remove waste heat from the electricity generation process in a two-loop, three-stage heat-transfer design. The primary and secondary loops are closed systems utilizing demineralized water that has been treated to control chemistry and corrosion. The final stage of the heat transfer system involves the circulating water system, which is unconfined.

Lake water is withdrawn through an offshore intake structure into a concrete-lined Figure 1 50-Mile Region TSDA: Tribal Designated Statistical Area Figure 2 6-Mile Region I

I 9 ) 9

tunnel, which directs the water into the screenhouse. This water then passes through the four parallel traveling screens before it is pumped through the main condensers to the discharge canal. The heated water is discharged back to Lake Ontario at the shoreline. The cooling water intake structure is located approximately 3,100 feet offshore at a depth of about 33 feet of water at mean lake level (244.7 feet) and is completely submerged below the surface of the Lake. Even an occurrence of historical low water level will result in no less than 15 feet of water covering the intake structure. The intake itself is an octagonal-shaped structure, 50.8 feet across, containing electrically heated screen racks in each of the eight 17.3-foot-wide by 10-foot-high ports. Heavy screen racks with bars spaced 10 14 inches apart, center to center, prevent large objects from entering the system. At conditions of full flow (354,600 gallons per minute), the velocity at the intake screen racks is 0.8 feet per second. Water enters the intake from all sides in a circle, protecting against stoppage by a single, large piece of material. The low velocity plus the submergence provide assurance that floating ice will not plug the intake.

The discharge canal transports the heated cooling water to Lake Ontario, where it is discharged at the shoreline to the surface of the Lake. Normal temperature increase over ambient water at the point of discharge is about 20 degrees Fahrenheit (OF),

and the size of the thermal plume is normally about 175 acres. Temperature of the discharged cooling water and extent of the thermal plume is limited by the State Pollutant Discharge Elimination System permit for Ginna Station.

The service water system for Ginna Station is also a once-through cooling system, but uses much less water than the circulating water system. Up to 14,600 gallons per minute of lake water are pumped from the screenhouse through heat exchangers for non-contact cooling for a wide variety of plant equipment. Discharge is to the discharge canal and low-level chlorination is used to control biofouling of the system.

An alternate service water discharge flow path exists via a discharge structure to Deer Creek. This path is used very infrequently, primarily during surveillance testing or when maintenance work is required in the preferred service water discharge path.

When in use, flows are documented in the monthly Discharge Monitoring Report submitted to the New York State Department of Environmental Conservation and chlorine injection is not allowed in the system.

Ginna Station uses approximately 100,000 gallons of water per day from the Ontario Water District in the Town of Ontario. This municipal water is the source of supply for the plant's process (auxiliary boiler feed and condensate to makeup and polishing), potable, and sanitary water systems. Ginna Station discharges treated waste process water into the discharge canal. These discharges are regulated under the plant's State Pollutant Discharge Elimination System permit. Sanitary wastewater is not disposed on site, but is piped to the Town of Ontario, New York's, wastewater treatment system for treatment and disposal.

RG&E employs a permanent workforce of approximately 500 employees at Ginna Station. Approximately 48 percent of the workforce lives in Wayne County and 44 percent lives in Monroe County. The site workforce increases by as many as 700 workers for temporary (30 to 40 days) duty during refueling outages that occur about once every eighteen months. RG&E does not anticipate the need for additional staff to support operations during extended operations.

In compliance with the NRC regulations, RG&E has analyzed the effects of plant aging and identified activities needed for Ginna Station to operate for an additional 20 years. RG&E conservatively assumes that renewal of the Ginna Station operating license would require the addition of no more than 60 workers to perform the additional license renewal surveillance, monitoring, inspection, testing, trending, and reporting. Ginna Station license renewal would involve no plant refurbishment.

Ginna Station transmission lines connect the plant through corridors to the State's electric grid at Substation 204 (Fruitland), south of the plant (see Figure 2). Four underground cables transmit electricity from the plant to Substation 13A, which is located south of the plant on the south side of Lake Road. Four overhead transmission lines emanate from Substation 13A and run in a southerly direction to connect to the transmission grid at Substation 204. RG&E owns the transmission corridor from Ginna Station to Substation 204 and maintains it as a low-growing vegetative community with selected management techniques under a New York State Public Service Commission-approved long-range vegetation management plan Ginna Station provides about 40 percent of the electrical load in the RG&E service territory, located primarily in upstate western New York. In other words, the extended operation of Ginna Station would meet the electrical needs of approximately one million people in the RG&E nine-county service area.

State Program New York's coastal management program is administered by the New York Department of State, Division of Coastal Resources. For federal agency activities, the Division reviews projects to ensure adherence to the State program or an approved Local Waterfront Revitalization Program. Applicants for federal agency approvals or authorizations are required to submit copies of federal applications to the Division, together with a Federal Consistency Assessment Form and consistency certification. The Department reviews the consistency certification and proposal for consistency with the State of New York Coastal Management Program as documented in 44 specific policies established in the Department's 1982 Final Environmental Impact Statement. The policies articulate the State's vision for its coast by addressing the following areas:

"* Development

"* Fish and Wildlife

"* Flooding and Erosion Hazards

"* General

"* Public Access

"* Recreation

"* Historic and Scenic Resources

"* Agricultural Lands

"* Energy and Ice Management

"* Water and Air Resources Tables 1 and 2 identify licenses, permits, consultations and other approvals necessary for Ginna Station continued operation and license renewal, respectively.

RG&E consulted with the Federal and State regulator agencies listed below to inform them of plans to seek license renewal for Ginna Station. RG&E described for the agencies its license renewal efforts and requested input from the agency representatives regarding issues of concern.

Federal U.S. Fish and Wildlife Service U.S. Army Corps of Engineers U.S. Environmental Protection Agency State of New York Department of State Department of Environmental Conservation Office of Parks, Recreation, and Historic Preservation Probable Effects The NRC has prepared a Generic EnvironmentalImpact Statement for License Renewal of Nuclear Plants (GELS) which analyzes the environmental impacts associated with the renewal of nuclear power plant operating licenses (Ref. 2; Ref. 3). The NRC has codified its findings by rulemaking (10 CFR Part 51, Subpart A, Appendix B, Table B-I). The codification identifies 92 potential environmental issues, 69 of which are generically identified as having small impacts and are called "Category 1"issues. Absent findings of new and significant information, the NRC will rely on its codified findings, as amplified by supporting information in the GELS, for its assessment of environmental impacts associated with license renewal. The codification and GElS discuss the following types of Category 1 environmental issues:

"* Surface water quality, hydrology, and use;

"* Aquatic ecology;

"* Groundwater use and quality;

"* Terrestrial resources;

"* Air quality;

"* Land use;

"* Human health;

"* Socioeconomics; C C Table I Environmental Authorizations for Current Operations R.E. Ginna Nuclear Power Plant Expiration Agency Authority Requirement Number Date Authorized Activity New York State Department NYS ECL Part 675 Water Withdrawal NYGLWR- 07/10/02a Withdraw water from Lake of Environmental Registration 0002810 Ontario Conservation State of Tennessee Tennessee Code Annotated Radioactive Shipment T-NY004-L01 12/31/02 Shipment of radioactive Department of Environment 68-202-206 License material to a licensed and Conservation disposal/processing facility within Tennessee Utah Department of R313-26 of the Utah Utah Department of 0109 000 005 06/30/03 Delivery of radioactive Environmental Quality Radiation Control Rules Environmental Quality wastes to a land disposal Division of Radiation facility located within Utah Control Generator Site Access Permit Accessing A Land Disposal Facility Within Utah South Carolina Department Act No. 429 of 1980 (South South Carolina 0034-31-01 12/31/02 Transport of radioactive of Health and Environmental Carolina Radioactive Waste Radioactive Waste waste into South Carolina Control Transportation and Disposal Transport Permit Act)

New York State Department NYS ECL 11-0515 (1), New York State Fish and LCP01-756 12/31102 Collection and possession of Environmental NYCRR Part 175 Wildlife License of fish and wildlife Conservation New York State Department NYS ECL Article 40 Hazardous Substance Bulk 8-000170 07/18/03 Registration of hazardous of Environmental Storage Registration substance bulk storage Conservation Certificate on site C C Table I (continued)

Environmental Authorizations for Current Operations R.E. Ginna Nuclear Power Plant Expiration Agency Authority Requirement Number Date Authorized Activity New York State Department NYS ECL Title 8 of Article 17 State Pollution Discharge NY-0000493 02/01/03 Discharge of wastewaters of Environmental Elimination System to waters of the State Conservation (SPDES) Permit U.S. Department of 49 CFR Part 107, Subpart G Certificate of Registration 06200255003K 06/30/03 Transportation of Transportation for Transportation of hazardous materials Hazardous Materials U.S. Nuclear Regulatory Atomic Energy Act (42 USC Facility Operating License DPR-1 8 09/18/09 License to operate a Commission 2011 et seq.), 10 CFR 50.10 nuclear power plant

a. Registration renewal submitted June 24, 2002.

Table 2 Environmental Authorizations for R.E. Ginna Nuclear Power Plant License Renewala Agency Authority Requirement Remarks U.S. Nuclear Regulatory Atomic Energy Act (42 License renewal Environmental report Commission USC 2011 et seq.) submitted in support of license renewal application U.S. Fish and Wildlife Endangered Species Consultation Requires federal agency Service Act, Section 7 (16 USC issuing a license to consult 1536) with FWS New York State Clean Water Act, Certification SPDES permit documents Department of Section 401 (33 USC compliance with Clean Environmental 1341) Water Act standards Conservation New York State Office National Historic Consultation Requires federal agency of Parks, Recreation, Preservation Act, issuing a license to consider and Historic Section 106 (16 USC cultural impacts and consult Preservation 470f) with State Historic Preservation Officer New York State Federal Coastal Zone Certification Requires an applicant to Department of State Management Act (16 provide certification to the USC 1451 et seq.) federal agency issuing the license that license renewal would be consistent with the federally approved state coastal zone management program; based on its review of the proposed activity, the State must concur with or object to the applicant's certification

a. No renewal-related requirements identified for local or other agencies.

FWS = U.S. Fish and Wildlife Service SPDES = State Pollutant Discharge Elimination System

"* Uranium fuel cycle and waste management; and

"* Decommissioning.

For plants such as Ginna Station that are located within the coastal zone, many of these issues involve impact to the coastal zone. RG&E has adopted by reference the GElS analysis for all Category I issues.

The NRC review of environmental impacts arising out of license renewal identified 21 issues as "Category 2," for which license renewal applicants must submit additional, site-specific information.' There are 16 Category 2 issues that are applicable to Ginna Station.2 The applicable issues and conclusions for these issues are as follows:

Aquatic ecology - RG&E has a current State Pollutant Discharge Elimination System permit and related correspondence equivalent to Clean Water Act Section 316(b) determination. It has been documented that the existing intake structure reflects the best technology available for minimizing entrainment and impingement impacts. Thermal plume studies indicated the thermal discharge from Ginna Station complies with New York Water Quality Standards and has an approved Clean Water Act Section 316(a) variance. Consequently, the impacts of continued plant operation from entrainment, impingement, and heat shock would be small.

Terrestrial resources - RG&E has no plans to perform major refurbishment activities; therefore, impacts due to refurbishment are not expected.

Threatened and endangered species - RG&E has no plans to perform major refurbishment activities; therefore, impacts due to refurbishment are not expected and impacts to these species through license renewal would be small.

Air quality - RG&E has no plans to perform major refurbishment activities; therefore, impacts due to refurbishment are not expected.

Human Health - Ginna Station transmission lines meet the National Electric Safety Code@ recommendations for preventing electric shock from induced currents; therefore, the impact from electric shock would be small.

Socioeconomics - RG&E has no plans for refurbishment activities; therefore, impacts to the local education system and transportation due to refurbishment are not expected. RG&E's conservative bounding analysis of 60 additional license renewal personnel would not result in significant impacts to available housing or local water systems.

Offsite land use - RG&E has no plans to perform major refurbishment activities; therefore, impacts due to refurbishment are not expected. The tax-related impacts of continued operations would be small.

10 CFR 51, Subpart A, Appendix B, Table B-I, also identifies two issues as "NA," for which the NRC could not come to a conclusion regarding categorization. RG&E believes that these issues, chronic effects of electromagnetic fields and environmental justice, do not affect the "coastal zone" as that phrase is defined by the Coastal Zone Management Act [16 USC 1453(1)].

2 Some Category 2 issues are applicable to plants having features that are not present at Ginna Station (e.g , cooling towers).

Historic and archeological resources - RG&E has no plans to perform major refurbishment activities; therefore, impacts due to refurbishment are not expected, and continued operations would have no impacts.

Severe accident mitigation alternatives - RG&E identified four potentially cost beneficial modifications that would reduce the impacts of a severe accident.

Findings

1. The NRC has determined that the significance of Category 1 issue impacts is small. A small significance level is defined by the NRC as follows:

For the issue, environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource. For the purpose of assessing radiological impacts,,the Commission has concluded that those impacts that do not exceed permissible levels in the Commission's regulations are considered small as the term is used in this table. (10 CFR Part 51, Subpart A, Appendix B, Table B-i)

RG&E has adopted by reference the NRC findings for Category 1 issues.

2. For applicable Category 2 issues, RG&E has determined that the environmental impacts are small as that term is defined by the NRC. Impact to the coastal zone, therefore, would also be small.

3. To the best of its knowledge, RG&E is in compliance with New York licenses, permits, approvals, and other requirements as they apply to Ginna Station impacts on the New York coastal zone.

4. Ginna Station license renewal and continued operation of Ginna Station facilities, and their effects, are all consistent with the enforceable policies of the New York Coastal Management Program.

State Notification By this certification, the State of New York is notified that the Ginna Station license renewal is consistent with the New York Coastal Management Program.

Attachment I to this Report is a completed New York State Department of State Federal Consistency Assessment Form. The State's concurrence, objections, or notification of review status shall be sent to the following contacts:

Sam Lee, Branch Chief License Renewal and Standardization Branch Office of Nuclear Reactor Regulation U.S Nuclear Regulatory Commission One White Flint 11555 Rockville Pike Rockville, Maryland 20555 (301) 415-1183 George Wrobel, License Renewal Project Manager Rochester Gas and Electric Corporation 89 East Avenue Rochester, New York 14649-0001 (716) 546-2700 References Ref. 1 U.S. Nuclear Regulatory Commission. "Procedural Guidance for Preparing Environmental Assessments and Considering Environmental Issues." Revision 2. Office of Nuclear Reactor Regulation. Washington, D.C. 1999.

Ref. 2 U.S. Nuclear Regulatory Commission. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. NUREG 1437. Office of Nuclear Regulatory Research. Washington, D.C.

May 1996.

Ref. 3 U.S. Nuclear Regulatory Commission. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Section 6.3, "Transportation," and Table 9-1, "Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants." NUREG 1437, Vol. 1, Addendum 1. Office of Nuclear Reactor Regulation.

Washington, D.C., August 1999.

Attachment New York State Department of State Coastal Management Program Federal Consistency Assessment Form

NEW YORK STATE DEPARTMENT OF STATE COASTAL MANAGEMENT PROGRAM Federal Consistency Assessment Form An applicant, seeking a permit, license, waiver, certification or similar type of approval from a federal agency which is subject to the New York State Coastal Management Program (CMP), shall complete this assessment form for any proposed activity that will occur within and/or directly affect the State's Coastal Area. This form is intended to assist an applicant in certifying that the proposed activity is consistent with New York State's CMP as required by U.S. Department of Commerce regulations (15 CFR 930.57). It should be completed at the time when the federal application is prepared. The Department of State will use the completed form and accompanying information in its review of the applicant's certification of consistency.

A. APPLICANT (please print)

1. Name: Rochester Gas & Electric Corporation

2. Address: 89 East Avenue, Rochester, NY 14649-001

3. Telephone: Area Code (585) 546-2700 B. PROPOSED ACTIVITY

1. Brief description of activity:

Rochester Gas & Electric Corporation is applying to the U.S. Nuclear Regulatory Commission to renew the operating license of the R. E. Ginna Nuclear Power Plant for an additional 20 years of plant operation.

2. Purpose of activity:

The purpose and need for the proposed action (renewal of an operating license) is to provide an option that allows for power generation capability beyond the term of a current nuclear power plant operating license to meet future system generating needs, as such needs may be determined by State, utility, and, where authorized, Federal (other than NRC) decision makers.

3. Location of activity:

Wayne County Town of Ontario 1503 Lake Road

4. Type of federal permit/license required: U. S. Nuclear Regulatory Commission Operating License Renewal

5. Federal application number, if known: NRC Operating License DPR-18

6. If a state permit/license was issued or is required for the proposed activity, identify the state agency and provide the application or permit number, if known: Not Applicable C. COASTAL ASSESSMENT Check either "YES" or "NO" for each of these questions. The numbers following each question refer to the policies described in the CMP document (see footnote on page 2) which may be affected by the proposed activity.

Will the proposed activity result in any of the following: YES NO

a. Large physical change to a site within the coastal area which will require the preparation of an environmental impact statement? (11, 22, 25, 32, 37, 38, 41, 43) ..................................... X

b. Physical alteration of more than two acres of land along the shoreline, land under water or coastal waters? (2, 11, 12, 20, 28, 35, 44) ......................................................... X

c. Revitalization/redevelopment of a deteriorated or underutilized waterfront site? (1) ........... - X

d. Reduction of existing or potential public access to or along coastal waters? (19, 20) ................- X

e. Adverse effect upon the commercial or recreational use of coastal fish resources? (9,10) ........ X

f. Siting of a facility essential to the exploration, development and production of energy resources in coastal waters or on the Outer Continental Shelf? (29) ......................................... .X_

g. Siting of a facility essential to the generation or transmission of energy? (27) .......................... X

h. Mining, excavation, or dredging activities, or the placement of dredged or fill material in coastal waters? (15, 35) .............................................................................................................. X

i. Discharge of toxics, hazardous substances or other pollutants into coastal waters? (8, 15, 35). X

j. Draining of stormwater runoff or sewer overflows into coastal waters? (33) .......................... X

k. Transport, storage, treatment, or disposal of solid wastes or hazardous materials? (36, 39) ...... X

1. Adverse effect upon land or water uses within the State's small harbors? (4) ........................... X

2. Will the proposed activity affect or be located in, on, or adjacent to any of the following: YES NO

a. State designated freshwater or tidal wetland? (44) .................................................................... X

b. Federally designated flood and/or state designated erosion hazard area? (11, 12, 17,) ........... X

c. State designated significant fish and/or wildlife habitat? (7) ...................................................... X

d. State designated significant scenic resource or area? (24) ......................................................... X

e. State designated important agricultural lands? (26) .................................................................. X

f. Beach, dune or barrier island? (12) .......................................................................................... . X

g. Major ports of Albany, Buffalo, Ogdensburg, Oswego or New York? (3) ................................ X

h. State, county, or local park? (19, 20) ........................................................................................ X

i. Historic resource listed on the National or State Register of Historic Places? (23) .........- X

3. Will the proposed activity require any of the following: YES NO

a. Waterfront site? (2, 21, 22) ........................................................................................................ X

b. Provision of new public services or infrastructure in undeveloped or sparsely populated sections of the coastal area? (5) ................................................................................................. X

c. Construction or reconstruction of a flood or erosion control structure? (13, 14, 16) ........ - X

d. State water quality permit or certification? (30, 38, 40) ......................................................... X

e. State air quality permit or certification? (41, 43) ...................................................................... X YES NO

4. Will the proposed activity occur within and/or affect an area covered by a State approved local waterfront revitalization program? (see policies in local program document) ................................ - X

D. ADDITIONAL STEPS

1. If all of the questions in Section C are answered "NO", then the applicant or agency shall complete Section E and submit the documentation required by Section F.

2. If any of the questions in Section C are answered "YES", then the applicant or agent is advised to consult the CMP, or where appropriate, the local waterfront revitalization program document*. The proposed activity must be analyzed in more detail with respect to the applicable state or local coastal policies. On a separate page(s), the applicant or agent shall: (a) identify, by their policy numbers, which coastal policies are affected by the activity, (b) briefly assess the effects of the activity upon the policy; and, (c) state how the activity is consistent with each policy. Following the completion of this written assessment, the applicant or agency shall complete Section E and submit the documentation required by Section F.

E. CERTIFICATION The applicant or agent must certify that the proposed activity is consistent with the State's CMP or the approved local waterfront revitalization program, as appropriate. If this certification cannot be made, the proposed activity shall not be undertaken If this certification can be made, complete this Section.

"The proposed activity complies with New York State's approved Coastal Management Program, or with the applicable approved local waterfront revitalization program, and will be conducted in a manner consistent with such program."

Applicant/Agent's Name: Robert C. Mecredy, Vice President, Nuclear Operations Address: R.E. Ginna Nuclear Power Plant, 1503 Lake Road, Ontario, NY 14519 Telephone: Area Code (585) 771-3494 Applicant/Agent's Signature: Date:

F. SUBMISSION REQUIREMENTS I. The applicant or agent shall submit the following documents to the New York State Department of State, Division of Coastal Resources, 41 State Street - 8th Floor, Albany, New York 12231.

a. Copy of original signed form

b. Copy of the completed federal agency application.

c. Other available information which would support the certification of consistency.

2. The applicant or agent shall also submit a copy of this completed form along with his/her application to the federal agency.

3. If there are any questions regarding the submission of this form, contact the Department of State at (518) 474-6000.

• These state and local documents are available for inspection at the offices of many federal agencies, Department of Environmental Conservation and Department of State regional offices, and the appropriate regional and county planning agencies. Local program documents are also available for inspection at the offices of the appropriate local government.

R.E. GINNA NUCLEAR POWER PLANT OPERATING LICENSE RENEWAL FEDERAL CONSISTENCY ASSESSMENT FORM SUPPLEMENTAL INFORMATION The following table contains a listing of the New York State Coastal Management Program Polices affected by the proposed activity, license renewal of the R. E. Ginna Nuclear Power Plant. Discussion follows the table, detailing how the proposed activity affects the individual policies. Policies 11, 15, and 35 are not included in the discussion because there are no plans to construct new buildings or structures or to conduct mining, excavation, or dredging in coastal waters as part of the proposed activity.

Table 1. New York State Coastal Management Program Policies Affected by R. E. Ginna License Renewal Policy 8 Protect fish and wildlife resources in the coastal area from the introduction of hazardous wastes and other pollutants which bio-accumulate in the food chain or which cause significant sublethal or lethal effect on those resources.

Policy 12 Activities or development in the coastal area will be undertaken so as to minimize damage to natural resources and property from flooding and erosion by protecting natural protective features including beaches, dunes, barrier islands, and bluffs.

Policy 17 Non-structural measures to minimize damage to natural resources and property from flooding and erosion shall be used whenever possible.

Policy 30 Municipal, industrial, and commercial discharge of pollutants, including but not limited to, toxic and hazardous substances, into coastal waters will conform to state and national water quality standards.

Policy 33 Best management practices will be used to ensure the control of stormwater runoff and combined sewer overflows draining into coastal waters.

Policy 36 Activities related to the shipment and storage of petroleum and other hazardous materials will be conducted in a manner that will prevent or at least minimize spills into coastal water; all practicable efforts will be undertaken to expedite the cleanup of such discharges; and restitution for damages will be required when these spills occur.

Policy 38 The quality and quantity of surface water and groundwater supplies will be conserved and protected, particularly where such waters constitute the primary or sole source of water supply.

Policy 39 The transport, storage, treatment and disposal of solid wastes, particularly hazardous wastes, within coastal areas will be conducted in such a manner so as to protect groundwater and surface water supplies, significant fish and wildlife habitats, recreation areas, important agricultural land, and scenic resources.

Policy 40 Effluent discharged from major steam electric generating and industrial facilities into coastal waters will not be unduly injurious to fish and wildlife and shall conform to state water quality standards.

With regard to Policy 8, the renewal of the R. E. Ginna Nuclear Power Plant operating license would have no additional effect on the fish and wildlife resources through the introduction of hazardous wastes and other pollutants.

Hazardous wastes and other pollutants which bio-accumulate in the food chain that Ginna Station operations would generate or have on site would be present in the following: effluent discharges from operations, pesticides used for facility and property maintenance, petroleum bulk storage, chemical bulk storage, and mixed and hazardous wastes generated by operations. State and federal programs regulate these potential sources of hazardous materials. All effluent discharges are regulated under the New York State Department of Environmental Conservation through the State Pollutant Discharge Elimination System (SPDES) permit program and Ginna Station has been issued a SPDES permit (NY-0000493) with effluent limitations, monitoring requirements, and other conditions that ensures that all discharges are in compliance with Title 8 of Article 17 of the Environmental Conservation Law of New York State and the Clean Water Act as amended (33 U.S.C. Section 1251 et seq.). Ginna Station is in compliance with its SPDES permit and is meeting all requirements and conditions set forth in the permit and is, therefore, protecting fish and wildlife resources in the Lake Ontario area where the plant is located.

Pesticide use is regulated by the New York State Department of Environmental Conservation (NYSDEC) under 6 NYCRR Part 325. Ginna Station has in place the NYSDEC Pesticide Business Registration and labels, prepares the required annual reports to the State, and maintains appropriate applicator certifications to ensure that pesticide use and storage on site are done properly and in accordance with regulations and is, therefore, protecting fish and wildlife resources in the Lake Ontario area where the plant is located.

Petroleum bulk storage on site is regulated by the New York State Department of Environmental Conservation under 6 NYCRR Parts 612.2-3, 613.6, and 613.8-9. Ginna Station facilities have the appropriate registrations and procedures are in place for spill prevention, response, and reporting. Chemical bulk storage on site is regulated by the New York State Department of Environmental Conservation under 6 NYCRR Parts 595.3, 596.2, 596.4, 596.6, 598.1, 598.4-5, and 598.7-10. Ginna Station has in place a Spill Prevention, Control, and Countermeasures Plan as required under 40 CFR 112 to prevent the discharge of oil to surface waters or surface water tributaries. Ginna Station facilities have the appropriate registrations and procedures in place for proper materials handling and storage; spill prevention, response, and reporting; and storage systems inspection, maintenance, and repair. Ginna Station has in place processes and procedures to ensure that hazardous chemicals stored and used on site are handled and stored in accordance with applicable State and Federal regulations. Ginna Station is, therefore, protecting fish and wildlife resources in the Lake Ontario area.

Mixed and hazardous wastes generated on site are packaged, temporarily stored, and shipped off site for processing and disposal. The New York State Department of Environmental Conservation regulates these activities under 6 NYCRR Parts 372.2, 373.1.1, 373.2, and 373.3. Ginna Station has in place processes and procedures to ensure that mixed and hazardous wastes are packaged, stored, and shipped so as to comply with the applicable State and Federal regulations, thus ensuring that fish and wildlife resources are protected. In summary, the hazardous wastes and other pollutants, which bio-accumulate in the food chain and could be introduced into the environment as a result of Ginna Station operations, are minimized through compliance with applicable environmental regulations. Fish and wildlife resources in the Lake Ontario area are, therefore, protected and the proposed activity is consistent with Policy 8.

With respect to Policies 12 and 17, a revetment composed of large stones covers the shoreline of Lake Ontario, within the Ginna Station protected area. The revetment was originally designed to provide surge flooding protection. The continued operation of the Ginna Station during the license renewal period will not involve any activities that would disturb the shoreline either to the east or west of the revetment. There are no plans for activities along the shoreline in the protected area. Ginna Station has no plans for activities or development along the shoreline as a part of the proposed activity, and so the proposed activity is consistent with Policies 12 and 17.

With respect to Policy 30, the effluent discharges from Ginna Station are regulated under the New York State Department of Environmental Conservation through the State Pollutant Discharge Elimination System (SPDES) permit program. Ginna Station has been issued a SPDES permit (NY-0000493) with effluent limitations, monitoring requirements, and other conditions, that ensures that all discharges are in compliance with Title 8 of Article 17 of the Environmental Conservation Law of New York State and the Clean Water Act as amended (33 U.S.C. Section 1251 et seq.). Ginna Station is in compliance with its SPDES permit and is meeting all requirements and conditions set forth in the permit and the proposed activity is therefore consistent with Policy 30.

With respect to Policy 33, Ginna Station has in place a Storm Water Pollution Prevention Plan. Best management practices to control storm water runoff and sewer overflows are an element of that plan. The New York State Department of Environmental Conservation regulates storm water management under 6 NYCRR, Part 751, ECL 17 0701 and 17-0808, and GP-98-03. The U.S. Environmental Protection Agency has authority under 40 CFR 122.

The proposed activity is therefore consistent with Policy 33.

With respect to Policy 36, Ginna Station has in place procedures to ensure that petroleum and other hazardous materials used on site are safely handled and stored. The New York State Department of Environmental Conservation regulates petroleum bulk storage under the authority of 6 NYCRR Parts 612.2-3, 613.6, and 613.8-9.

Ginna Station facilities have the appropriate registrations and procedures are in place to prevent and report spills.

Chemical bulk storage on site is regulated by the New York State Department of Environmental Conservation under 6 NYCRR Parts 595.3, 596.2, 596.4, 596.6, 598.1, 598.4-5, and 598.7-10. Ginna Station has in place a Spill Prevention, Control, and Countermeasures Plan as required under 40 CFR 112 to prevent the discharge of oil to surface waters or surface water tributaries. Ginna Station facilities have the appropriate registrations and procedures in place for proper materials handling and storage; spill prevention, response, and reporting; and storage systems inspection, maintenance, and repair. Ginna Station has in place processes and procedures to ensure that hazardous chemicals stored and used on site are handled and stored in accordance with applicable State and Federal regulations so as to prevent the release of these materials to coastal waters. Therefore, the proposed activity is consistent with Policy 36.

With respect to Policy 38, Ginna Station does not use groundwater as a resource for any plant operations or as a potable water resource. Processes and procedures are in place for the handling and storage of hazardous materials on site to prevent spills and to respond to any that occur so as to minimize impacts to groundwater or surface water resources. Effluents from plant operations are regulated under Ginna Station's SPDES permit so as to minimize the impacts to surface water supplies (Deer and Mill Creeks and Lake Ontario) and minimize water use. A Stormwater Pollution Prevention Plan is in place to protect surface water resources. Ginna Station has in place a Spill Prevention, Control, and Countermeasures Plan as required under 40 CFR 112 to prevent the discharge of oil to surface waters or surface water tributaries. Ginna Station has in place processes and procedures that conserve and protect both groundwater and surface water resources. Therefore, the proposed activity is consistent with Policy 38.

With respect to Policy 39, Ginna Station does not dispose of solid waste on site. Mixed and hazardous wastes generated on site are packaged, temporarily stored, and shipped off site for processing and disposal. The New York State Department of Environmental Conservation regulates these activities under 6 NYCRR Parts 372.2, 373.1.1, 373.2, and 373.3. Ginna Station has in place processes and procedures to ensure that mixed and hazardous wastes are packaged, stored, and shipped so as to comply with the applicable State and Federal regulations, thus ensuring that groundwater and surface water supplies, significant fish and wildlife habitats, recreation areas, important agricultural land, and scenic resources are protected. The proposed activity is therefore consistent with Policy 39.

With respect to Policy 40, the effluent discharges from Ginna Station are regulated under the New York State Department of Environmental Conservation through the State Pollutant Discharge Elimination System (SPDES) permit program. Ginna Station has been issued a SPDES permit (NY-0000493) with effluent limitations, monitoring requirements, and other conditions that ensure that all discharges are in compliance with Title 8 of Article 17 of the Environmental Conservation Law of New York State and the Clean Water Act as amended (33 U.S.C. Section 1251 et seq.). Ginna Station is in compliance with its SPDES permit and is meeting all requirements and conditions set forth in the permit and so is minimizing impacts to fish and wildlife. The proposed activity is, therefore, consistent with Policy 40.

THE FOLLOWING IS A LISTING OF OVERSIZED DR N**NGS CONTAINED WITHIN ýTHIS DOCUMENT.

TO VIEW A DRAWING, REFERENCE *THE DRAWlING NUMBER SPECIFIC TO THE DESIRED DRAWING ON THE LIST AND LOCATE IT WITHIN THIS PACKAGE OR, PERF0RM A SEARCH USING THE DRAWING NUMBER

LI0, FOVVIERSIZED DRAWINGS DRAWING NO. RE-V.NO. TITLE

1. 33013-1231-LR 29 Main Steam (MS) (Safety Related)

2. 33013-1232-LR 19 Main Steam Non-Safety Related (MS)

3. 33013-1234-LR 25 Condensate Storage (CDST)

4. 33013-1236 Sheet I of 2-LR 12 Feedwater (FW)

5. 33013-1236 Sheet 2 of 2-LR 11 Feedwater (FW)

6. 33013-1237-LR 41 Auxiliary Feedwater (FW)

7. 33013-1238-LR 19 Standby Auxiliary Feedwater (FW)

8. 33013-1239 Sheet I of 2,LR 19- Diesel Generator-A (DG)

9. 33013-1239 Sheet 2 of 2-LR .17 Diesel Generator-B (DG) 10.. 33013-1242-LR S29 Fire Protection Relayand Multiplexor Rooms (FP)

11. 33013-1245-LR 19 Auxiliary Coolant Component Cooling Water (AC)

12. 33013-1246 Sheet I of 2-LR 11 Auxiliary Coolant Component Cooling Water (AC)

13. 33013-1246- Sheet 2 of 2-LR 9 Auxiliary Coolant Component Cooling Water (AC)

14. 33013-1247-LR -33 Auxiliary Coolant :Residual Heat Removal (AC)

15. 33013-1248-LR '27, Auxiliary Coolant S6ient Fuel Pool Coc ling (AC) 35 Station Service Cooling Water Safety

16. 33013-1250 Sheet I of 3-LR1 ilil Related (SW)

DRAWING NO. RE V. NO. TITLE 281 Station service Cooling Water Safety

17. 33013-1250- Sheet 2 of 3-LR Related (SW) 20 Station Service Cooling Water Safety

18. 33013-1250 Sheet 3 of 3-LR Related (SW)

19. 33013-1256-LR 17 Technical Support Center HVAC

20. 33013-1258-LR 23 Reactor Coolant Pressurizer (RC)

21. 33013-1260-LR 21 Reactor Coolant (RC)

22. 33013-1261-LR 33, Containment Spray (SI)

23. 33013-1262 Sheet I of 2-LR 19 Safety Injection and Accumulators (SI)

24. 33013-1262 Sheet 2 of 2-LR 6 Safety Injection and Accumulators (SI)

25. 33013-1263 LR 10 RCS Overpressure Protection Nitrogen Accumulator System

26. 33013-1264-LR 20 Chemical & Volume Control Letdown (CVCS)

27. 33013-1265 Sheet I of 2-LR 9 Chemical and Volume Control System Charging (CVCS)

28. 33013-1265 Sheet 2 of 2-LR 9 Auxiliary Building Chemical Volume Control System Charging (CVCS)

29. 33013-1266-LR 24 Auxiliary Building Chemical Volume Control System Boric Acid (CVCS)

30. 33013-1267-LR 15 Auxiliary Bldg. Chemical Volume & Control Holdup Tanks to Gas Strippers (CVCS)

31. 33013-1268-LR 17 Auxiliary Bldg. Chemical Volume & Control Boric Acid Evaporator to Monitor Tanks

,(CVCS)

-3 DRAWING NO. REV. NO. TITLE

32. 33013-1269-LR 8 Auxiliary Bid6. Reactor Makeup Water (CVCS) 11 Waste Disposal-Liquid Waste Drains,

33. 33013-1270 Sheet I of 2-LR Holdup Tank, Spent Resin Tanks (WD)

34. 33013-1272 Sheet I of 2-LR 8 Waste Disposal-Liquid RC Drain Tank (WD)

35. 33013-1272 Sheet 2 of 2 11 Waste Disposal-Liquid RC Drain Tank (WD) 36.33013-1273 Sheet I of 2-LR 5 Waste Disposal - Gas (WD)

37. 33013-1274-LR 17 Waste Disposal-Gas Hydrogen and Nitrogen (WD)

38. 33013-1275 Sheet I of 2-LR 10 Waste Disposal -Gas Hydrogen Recombiner (WD)

39. 33013-1275 Sheet 2 of 2-LR 4 Waste Disposal - Gas Hydrogen Recombiner (WD)

40. 33013-1277 Sheet 2 of 2-LR 16 Steam Generator Blowdown (SGB)

41. 33013-1278 Sheet of 2-LR 15 Nuclear Sampling (SS)

42. 33013-1278 Sheet 2 of 2-LR 14 Nuclear Sampling (SS)

43. 33013-1279-LR 10 Post Accident Sampling System (SS)

44. 33013-1607-LR .23 Fire Protection System Yard Loop

45. 33013-1863-LR 13 Containment HVAC Systems Containment Recirculating and Cooling System, Post Accident Charcoal Filters

46. 33013-1864-LR 14 Containment HVAC Systems Cont.

Auxiliary Charcoal Filters, Refueling Water Ventilation, Reactor Compartment and Control Rod Drive Cooling

DRAWING NO. REV. NO. TITLE

47. 33013-1865-LR 11 CONTAINMENT HVAC SYSTEMS PURGE SUPPLY

48. 33013-1866-LR 20 CONTAINMENT HVAC SYSTEMS PURGE EXHAUST PENETRATION COOLING

49. 33013-1867-LR 15 CONTROL BUILDING HVAC SYSTEMS CONTROL ROOM HVAC CONTROL ROOM POST ACCIDENT CHARCOAL FILTERS CONTROL ROOM LAVATORY EXHAUST

50. 33013-1869-LR 07 AUX./INT.BLDGS. HVAC SYSTEMS COOLING'FOR CHARGING, SAFETY INJECTION, CONT. SPRAY, RHR &

SAFW PUMPS, NITROGEN AND HYDROGEN VENTS

51. 33013-1870-LR 16 AUXILIARY/INTERMEDIATE BLDS. HVAC SYSTEMS VOLUME CONTROL TANK EXHAUST AUXILIARY BLDG. CHARCOAL FILTER AUXILIARY BLDG. IG FILTER

52. 33013-1873-LR 21 TURBINE/MISC. BLDG. HVAC SYSTEM VENTILATION FOR DIESEL GENERATORS, FEED PUMPS, OIL STORAGE, TURBINE BLDG. GAS BOTTLE STORAGE, ELEVATOR AND SCREENHOUSE

53. 33013-1882-LR 17 CONTAINMENT VESSEL AIR & PROOF TEST

& BREATHING AIR

54. 33013-1884 SHEET I 09 PENETRATION PRESSURIZATION SYSTEM OF 2-LR

55. 33013-1884 SHEET 2 11 PENETRATION PRESSURIZATION SYSTEM OF 2-LR

.5-DRAWING NO. REV. NO. TITLE

56. 33013-1885 SHEET 2 30 l CIRCULATING WATER OF 2-LR

57. 33013-1886 SHEET 2 12 SERVICE AIR OF 2-LR

58. 33013-1891-LR 12 Is INSTRUMENT AIR AUXILIARY BUILDING

59. 33013-1893-LR INSTRUMENT AIR INTERMEDIATE BLDG.

60. 33013-1908 SHEET 3 12 PRIMARY WATER TREATMENT OF 3-LR

61. 33013-1915-LR 18 INTERMEDAITE BLDG. AND CONTAINMENT HEATING STEAM AND CONDENSATE

62. 33013-1989-LR 20 FIRE PROTECTION SYSTEMS FIRE SERVICE WATER PLANT SYSTEMS

63. 33013-1990 SHEET I 10 FIRE PROTECTION SYSTEMS FIRE SERVICE OF 2-LR WATER TURBINE BUILDING AND TECHNICAL SUPPORT CENTER

64. 33013-1990 SHEET 2 07 FIRE PROTECTION SYSTEMS FIRE SERVICE OF 2-LR WATER TURBINE BUILDING AND TECHNICAL SUPPORT CENTER

65. 33013-1991-LR 14 FIRE PROTECTION FIRE SERVICE WATER AUXILIARY BLDG.I INTERMEDIATE BLDG.

CONTAINMENT BLDG.

66. 33013-1992-LR 08 FIRE PROTECTION SYSTEMS FIRE SERVICE WATER FIRE WATER HEADER "A" AUXILIARY BUILDING HEADER

DRAWING NO. 1EV. NO. TITLE

67. 33013-1993 SHEET I 07 FIRE PROTECTION SYSTEMS FIRE SERVICE OF 2-LR WATER HEADER B

68. 33013-1993 SHEET 2 08 FIRE PROTECTION SYSTEMS FIRE SERVICE OF 2-LR WATER HEADER "B"

69. 33013-2248-LR 09 RCP MOTOR LUBE OIL SYSTEM RCP MOTOR LUBE OIL SPILLAGE COLLECTION SYSTEM

70. 33013-2278-LR 03 INCORE DETECTORS DRIVE NUTS SKID

71. 33013-2285-LR 12 MOTOR DRIVEN AND TURBINE DRIVEN AUXILIARY FEEDWATER PUMPS LUBE OIL SKID

72. 33013-2287-LR 09 RETENTION TANK SKID

73. 33013-2288-LR 02 TSC EMERGENCY DIESEL SKID (ED)

74. 33013-2344-LR 01 SPRINKLER SYSTEM AT DELUGE VALVE 8548U

75. 33013-2345-LR 04 SPRINKLER SYSTEM AT DELUGE VALVE 5233F

76. 33013-2346-LR 02 SPRINKLER SYSTEM AT DELUGE VALVE 5233F

77. 33013-2347-LR 06 SPRINKLER SYSTEM AT DELUGE VALVE 5233F 78.33013-2348 02 SPRINKLER SYSTEM AT DELUGE VALVE 5233F

79. 33013-2349-LR 02 SPRINKLER SYSTEM AT DELUGE VALVE 9201FP AND 9204F

DRAWING NO. REV. NO. TITLE

80. 33013-2350-LR 04 SPRINKLER SYSTEM AT DELUGE VALVES 9274F, 9275, AND 9282 AND SAS/PPCS COMPUTER ROOM AUTOMATIC HALON SYSTEM S37

81. 33013-2351-LR 01 SPRINKLER SYSTEM AT DELUGE VALVES 5234F AND 9219F

82. 33013-2352-LR 02 SPRINKLER SYSTEM AT DELUGE VALVES 9189F, 9195F AND 9247F

83. 33013-2353-LR 01 SPRINKLER SYSTEM AT DELUGE VALVES 9240F AND 9244F

84. 33013-2354 01 SPRINKLER SYSTEM AT DELUGE VALVES 5231F AND 9242F

85. 33013-2355-LR 02 SPRINKLER SYSTEM AT DELUGE VALVES 5228F, 5229F AND 5230F

86. 33013-2356-LR 02 SPRINKLER SYSTEM AT DELUGE VALVES 5208F AND 521OF

87. 33013-2357-LR 03 SPRINKLER SYSTEM AT DELUGE VALVES 5204F, 5205F, AND 5207F 88a 33013-2358-LR 01 SPRINKLER SYSTEM AT DELUGE VALVES 5209F, 5232F AND 9213F

89. 33013-2359-LR 02 SPRINKLER SYSTEM AT DELUGE VALVES 9211F, 9215F, 9217F, AND 5216

90. 33013-2681-LR 04 SUMP PUMPS, DRAINS, AND SEWAGE PUMPS