ML13088A370

2013/03/29 Indian Point Lr Hearing - FW: Draft Monitoring Plan for Indian Point Energy Center Take of Atlantic and Shortnose Sturgeons by Impingement at Cooling Water Intakes (29 March 2013)

ML13088A370
Person / Time
Site:	Indian Point
Issue date:	03/29/2013
From:	NRC/OGC
To:	Division of License Renewal
References
Download: ML13088A370 (46)

Text

1 IPRenewal NPEmails From: Turk, Sherwin Sent: Friday, March 29, 2013 3:30 PM To: IPRenewal NPEmails; 'I PNonPublicHearingFile'

Subject:

FW: Draft Monitoring Plan for Indian Point Ener gy Center Take of Atlantic and Shortnose Sturgeons by Impingement at Cooling Water Intakes (29 March 2013)

Attachments:

IPEC draft sturgeon monitoring plan.pdf From: Mark Mattson [mailto:mmattson@normandeau.com

] Sent: Friday, March 29, 2013 2:47 PM To: Julie Crocker; Balsam, Briana; Logan, Dennis; Turk, Sherwin; James, Lois; Pickett, Douglas; Bridget.Frymire@dps.ny.gov Cc: Dacimo, Fred R.; Gray, Dara F; 'Zoli, Elise N (EZoli@goodwinprocter.com)'; 'Fitzgerald, Robert H'; ksutton@morganlewis.com; 'Barnthouse@lwb-env.com'; Douglas Heimbuch' (DHeimbuch@akrf.com

)'; jyoung@asaac.com; Paul Lindsay

Subject:

Draft Monitoring Plan for Indian Point Ener gy Center Take of Atlantic and Shortnose Stur g eons by Impin g ement at Cooling Water Intakes (29 March 2013)

Please find attached to this email one PDF copy of the proposed, draft monitoring plan that was prepared on behalf of Entergy Nuclear Operations, Inc. Indian Point Energy Center by Normandeau Associates, Inc. and ASA Analysis and Communications, Inc. to address Reasonable and Prudent Measure #1 as specified in Terms and Conditions #1 of the Final Biological Opinion for Continued Operation of Indian Point Nuclear Generating Unit Nos. 2 and 3 dated 30 January 2013: "Proposed Draft Monitoring Plan for Indian Point Energy Center Take of Atlantic and Shortnose Sturgeons by Impingement at Cooling Water Intakes" 29 March 2013.

A copy of the cover letter a nd distribution list is include d in the Draft Monitoring Plan document after the title page. Printed copies were also distributed by Federal Express overnight delivery to each recipient in the distribution list with a mailing address specified. We look forward to mee ting with NMFS technical staff at the Indian Point facility in the near future for a tour of the intakes, to discuss implem entation of the proposed draft study plan, and to answer any remaining questions that you may have.

Thank you. Mark

><((((:> ><((((:> ><((((:> ><((((:> Mark T. Mattson, Ph.D., Vice President Normandeau Associates, Inc

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

Hearing Identifier: IndianPointUnits2and3NonPublic_EX Email Number: 4090 Mail Envelope Properties (E09C30551FD42442BA284ECF9858105F01E3138A4EC7)

Subject:

FW: Draft Monitoring Plan for Indian Point Energy Center Take of Atlantic and Shortnose Sturgeons by Impingement at Cooling Water Intakes (29 March 2013) Sent Date: 3/29/2013 3:29:40 PM Received Date: 3/29/2013 3:29:51 PM From: Turk, Sherwin Created By: Sherwin.Turk@nrc.gov Recipients: "IPRenewal NPEmails" <IPRenewal.NPEmails@nrc.gov> Tracking Status: None

"'IPNonPublicHearingFile'" <> Tracking Status: None

Post Office: HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 2122 3/29/2013 3:29:51 PM IPEC draft sturgeon monitoring plan.pdf 6003151 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

Proposed Draft Monitoring Plan for Indian Point Energy Center Take of Atlantic and Shortnose Sturgeons by Impingement at Cooling Water Intakes Presented to: Indian Point Energy Center 450 Broadway, Suite 1 Buchanan, NY 10511 Submitted: 29 March 2013 Submitted by: Normandeau Associates, Inc. 25 Nashua Road Bedford, NH 03110 and ASA Analysis and Communication, Inc. 921 Pike Street, P.O. Box 303 Lemont, PA 16851

www.normandeau.com

30 International Drive, Suite 6, Pease International Tradeport Portsmouth, NH 03801 Tel (603) 319-5300 Fax (603) 334-6397 www.normandeau.com Bedford, NH (Corporate) North Haven, CT Falmouth, MA Haverstraw, NY Stowe, PA Stevenson, WA Lewes, DE Gainesville, FL Falmouth, ME Hampton, NH Portsmouth, NH Westmoreland, NH Oswego, NY Drumore, PA Aiken, SC Moncks Corner, SC Vancouver, WA E. Wenatchee, WA An Employee-Owned Company An Equal Opportunity Employer 29 March 2013

Mr. John K. Bullard, Regional Administrator National Marine Fisheries Service 55 Great Republic Drive Gloucester, MA 01930-2276 Dr. Amy Hull, Branch Chief Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Program U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Re: Draft Monitoring Plan Required by Reasonable and Prudent Measure #1 of the Final Biological Opinion for Continued Operation of Indian Point Nuclear Generating Unit Nos. 2 and 3

Dear Mr. Bullard and Dr. Hull:

Please find enclosed one copy of the following proposed, draft monitoring plan that was prepared on behalf of Entergy Nuclear Operations, Inc. (Entergy) Indian Point Energy Center (IPEC) by Normandeau Associates, Inc. (Normandeau) and ASA Analysis and Communications, Inc. (ASA) to address Reasonable and Prudent Measure (RPM) #1 as specified in Terms and Conditions (T&C) #1 of the Final Biological Opinion for Continued Operation of Indian Point Nuclear Generating Unit Nos. 2 and 3 dated 30 January 2013:

Proposed Draft Monitoring Plan for Indian Point Energy Center Take of Atlantic and Shortnose Sturgeons by Impingement at Cooling Water Intakes 29 March 2013. A copy of this letter and the Draft Monitoring Plan were also sent by Email to the members of your staff identified in the enclosed distribution list. As discussed with your staff, we look forward to meeting with them at the Indian Point facility in the near future for a tour of the intakes, to discuss implementation of the proposed draft study plan, and to answer any remaining questions that you may have.

Sincerely, NORMANDEAU ASSOCIATES, INC.

Mark T. Mattson, Ph.D. Vice President 2 Email Distribution List 29 March 2013 (those with mailing addresses will also receive printed copy):

Proposed Draft Monitoring Plan for Indian Point Energy Center Take of Atlantic and Shortnose Sturgeons by Impingement at Cooling Water Intakes 29 March 2013.

Ms. Briana Balsam (NRC)

Briana.Balsam@NRC.gov Mr. Dennis Logan (NRC) Dennis.Logan@NRC.gov Mr. Sherwin Turk (NRC)

Sherwin.Turk@NRC.gov

Ms. Lois James (NRC)

Lois.James@NRC.gov Mr. Douglas Picket (NRC) Douglas.Pickett@NRC.gov

Ms. Bridget Frymire (PSC)

Bridgeft.Frymire@dps.ny.gov Ms. Julie Crocker (NMFS)

Julie.Crocker@NOAA.gov National Marine Fisheries Service Protected Resources Division, NMFS/NERO 55 Great Republic Drive Gloucester, MA 01930-2276

Mr. Fred Dacimo (IPEC) fdacimo@entergy.com Indian Point Energy Center 450 Broadway, Suite 1 Buchanan, NY 10511 Ms. Dara Gray (IPEC) dgray@entergy.com Indian Point Energy Center 450 Broadway, Suite 1 Buchanan, NY 10511

3 Email Distribution List 29 March 2013 (those with mailing addresses will also receive printed copy):

Proposed Draft Monitoring Plan for Indian Point Energy Center Take of Atlantic and Shortnose Sturgeons by Impingement at Cooling Water Intakes 29 March 2013.

Ms. Elise N. Zoli (Goodwin Procter)

EZoli@goodwinprocter.com Goodwin Procter LLP Exchange Place Boston, MA 02109 Ms. Kathryn Sutton (Morgan Lewis) ksutton@morganlewis.com Dr. Larry Barnthouse (LWB Environmental)

Barnthouse@lwb-env.com LWB Environmental Services, Inc. 1620 New London Road Hamilton, OH 45013

Dr. Douglas Heimbuch (AKRF)

DHeimbuch@AKRF.com AKRF, Inc. 7250 Parkway Drive, Suite 210 Hanover, MD 21076

Dr. John Young (ASA) jyoung@asaac.com ASA Analysis & Communications, Inc.

921 Pike Street, P.O. Box 303 Lemont, PA 16851-0303

Dr. Mark Mattson (Normandeau) mmattson@normandeau.com Normandeau Associates, Inc. 30 International Drive, Suite #6 Portsmouth, NH 03801

DRAFT MONITORING PLAN FOR IPEC STURGEON IMPINGEMENT IPEC draft sturgeon monitoring plan.docx 3/29/13 ii Normandeau Associates, Inc.

Table of Contents Page

1.0 INTRODUCTION

................................................................................ 1

1.1 REGULATORY

CONTEXT ..................................................................... 1

1.2 DESCRIPTION

OF IPEC AND OPERATIONS RELEVANT TO THE PROPOSED MONITORING P LAN .. 1 1.2.1 Cooling Water Intake Structures ............................................. 2

1.2.2 Cooling

Water Flow Management ............................................ 3

1.2.3 Optimized

Ristroph-Type Traveling Water Screens

........................ 3

2.0 MONITORING

PROGRAM

...................................................................... 5

2.1 MONITORING

AT TRASH RACKS ............................................................. 5 2.1.1 IP2 and IP3 .................................

..................................... 5 2.1.2 IP1 ................................................................................ 6

2.1.3 Trash

Rack Monitoring Implementation Schedule, Modifications, and Permits ..................................................................... 6

2.2 MONITORING

IN FOREBAYS .................................................................. 7

2.3 MONITORING

AT T RAVELING SCREENS ....................................................... 7

2.3.1 Traveling

Screen Monitoring at IP2 and IP3 ................................. 7

2.3.2 Traveling

Screen Monitoring at IP1 .......................................... 9

2.3.3 Traveling

Screen Monitoring Implementation Schedule, Modifications, and Permitting ................................................ 9 2.4 F ISH H ANDLING PROCEDURES .............................................................. 10 2.4.1 Live Fish ........................................................................ 10 2.4.2 Dead Fish ....................................................................... 11

2.4.3 Genetic

Samples ............................................................... 11 2.5 A NCILLARY DATA .......................................................................... 12

2.5.1 Temperature

................................................................... 12

2.5.2 Water

Velocity .................................................................

12 2.5.3 Plant Operating Data ......................................................... 14

2.5.4 Ancillary

Data Collection Implementation Schedule, Monitoring, and Permits .................................................................... 14

2.6 REPORTING

................................................................................ 14 2.6.1 Take Notification .............................................................. 14

2.6.2 Annual

Report

.................................................................. 14

2.6.3 Genetic

Samples ............................................................... 15 2.6.4 Dead Sturgeon or Sturgeon Parts

............................................ 15

2.7 TRAINING

OF F IELD BIOLOGISTS ........................................................... 15 2.8 QA/QC PROCEDURES ..................................................................... 15

3.0 LITERATURE

CITED ..........................................................................

16 FIGURES ...............................................................................................

18 DRAFT MONITORING PLAN FOR IPEC STURGEON IMPINGEMENT IPEC draft sturgeon monitoring plan.docx 3/29/13 iii Normandeau Associates, Inc.

List of Figures Page Figure 1-1.

Indian Point Unit 2 cooling water intake. ............................................ 19 Figure 1-2.

Indian Point Unit 3 cooling water intake. ............................................ 20 Figure 2-1.

Sonar system for detecting shortnose sturgeon or Atlantic sturgeon impinged at the IPEC trash racks. ..................................................... 21 Figure 2-2.

Proposed location of collection tanks at Unit 2. .................................... 24 Figure 2-3.

Proposed location of collection tank at Unit 3. ..................................... 25 Figure 2-4 Incident report form for incidental take of shortnose sturgeon or Atlantic sturgeon by impingement at the IPEC cooling water intakes. .......... 26 Figure 2-5.

Summary form for environmental data associated with incidental take of shortnose sturgeon or Atlantic sturgeon. ......................................... 28 Figure 2-6.

Instructions for collecting, certifying, identifying, and shipping sturgeon tissue samples. ........................................................................... 29 Figure 2-7.

Certification of species, sample identification, and chain of custody form. ....................................................................................... 30 Figure 2-8.

Summary form for sturgeon genetic tissue samples. ............................... 31 Figure 2-9.

Guidelines and form for air shipment of excepted quantities of ethanol solutions. ........................................................................ 32 Figure 2-10.

Sturgeon salvage form. .................................................................. 34

DRAFT MONITORING PLAN FOR IPEC STURGEON IMPINGEMENT IPEC draft sturgeon monitoring plan.docx 3/29/13 1 Normandeau Associates, Inc.

1.0 Introduction

1.1 Regulatory Context On 30 January, 2013, the National Marine Fisheries Service (NMFS) issued a final Biological Opinion (Opinion) and Incidental Take Statement (ITS) authorizing takes of shortnose and Atlantic sturgeon during the continued operation of the Indian Point Energy Center (IPEC) pursuant to existing operating licenses and proposed renewed operating licenses to be issued by the U.S. Nuclear Regulatory Commission (NRC). In the Opinion, NMFS addressed shortnose sturgeon and the Gulf of Maine Distinct Population Segment (DPS), the New York Bight DPS, and the Chesapeake Bay DPS of Atlantic sturgeon. Among other things, the Opinion requires that "Entergy must develop a proposed, draft monitoring plan designed to document all shortnose and Atlantic sturgeon impinged at IP1, IP2 and IP3 (trash racks and intake screens) while these facilities are operating under their existing operating licenses and the proposed renewed operating licenses. The draft monitoring plan must be provided to NMFS and NRC within 60 days of the issuance of this Opinion for NMFS review and approval. The Opinion also contains Reasonable and Prudent Measures (RPMs) and Terms and Conditions (T&C) that are to be "developed in coordination with the action agency and applicant, if any, to ensure that the measures are reasonable" (USFWS & NMFS, 1998). This document provides Entergy's proposed monitoring plan for NMFS review in a manner that is responsive to the RPMs and T&C, while accounting for NMFS fundamental findings in the Opinion and ITS. The proposed plan addresses RPMs #1-#5, and T&C #1-8 of the Opinion as completely as possible; however, there are certain aspects of the T&C that cannot reasonably be implemented at IPEC. The plan identifies departures from the T&C, provides an explanation for the departure, and presents reasonable alternatives that will still achieve the objectives of the monitoring plan. 1.2 Description of IPEC and Operations Relevant to the Proposed Monitoring Plan Entergy Nuclear Operations, Inc. (Entergy) currently operates two NRC-licensed pressurized water reactors and associated generating units (IP2 and IP3; collectively, IPEC). These units condense the steam exiting the turbines by transferring heat to water withdrawn from the Hudson River, which is then discharged back to the river. Maximum cooling water flow is 840,000 gpm at each unit. Both IP2 and IP3 also use once-through systems to manage auxiliary heating loads, referred to as service water systems. These service water systems at IP2 and IP3 are significantly smaller than the cooling water systems, with maximum (design) service water flow of 30,000 gpm at IP2 and 36,000 gpm at IP3 (Enercon 2010), although service water flows are typically 15,000 gpm or less for each unit. The cooling water system for IP1 was originally designed to provide 280,000 gpm before the generating unit was retired in November 1974. The cooling water pumps at the IP1 intake were removed in the 1990s, but the IP1 service DRAFT MONITORING PLAN FOR IPEC STURGEON IMPINGEMENT IPEC draft sturgeon monitoring plan.docx 3/29/13 2 Normandeau Associates, Inc.

water system is still operational and provides up to 16,000 gpm of supplemental service water for IP2 if needed. 1.2.1 Cooling Water Intake Structures Cooling water for IP2 and IP3 is obtained through their respective cooling water intake structures (CWISs), located approximately 700 feet apart along the eastern shoreline of the Hudson River at approximately Hudson River mile 42.8 (42.8 miles upstream from the southern end of Battery Park in lower Manhattan). The CWISs are located within IPECs federally mandated Safety and Security Zone (S&SZ). The IP2 intake structure contains seven bays or channels, which are separated by 3-foot thick concrete walls (Figure 1-1). Each intake bay is equipped with a debris wall that extends to a depth of -1 foot mean sea level (MSL), and a vertical bar rack, or trash rack, with 3-inch spaces between bars, to prevent large pieces of debris from entering the structure. The bar racks extend the full height of the opening (-27 ft to -1 ft MSL). Design velocities through the bar racks for the six cooling water intake bays range from 0.5 to 0.8 fps depending on pumping rate and tide height. Design velocity through the bar rack protecting the service water bay in the center of the intake structure at IP2 ranges from 0.06 fps to 0.17 fps. The design of the intake with the top of the trash bar rack submerged 1 ft below MSL and near the opening of each intake bay minimizes the buildup of debris on the bar racks, and there is no need for a mechanized cleaning system. The bar racks are inspected twice annually, and any accumulated large debris is removed at that time. The IP3 intake structure, located south of the IP1 intake, consists of a concrete structure with nine openings which provide flow to a common plenum (Figure 1-2). The seven openings along the face (western side) of the intake are each equipped with a debris wall and vertical bar rack similar to those at IP2. Design velocity through the bar racks is 0.5 to 0.9 fps depending on cooling water flow rate and water level. Actual velocities through the seven bar racks is less than the design value because there are two additional openings, one at the north end and one at the south end of the structure (Figure 1-2). These openings contain additional bar racks. As at IP2, debris accumulation on the bar racks at IP3 has not been an issue because the racks are submerged 1 ft below MSL and are located at the outer edge of the intake structure. The IP3 intakes are cleared of any built-up debris accumulation during twice annual inspections. Unlike the seven isolated bays at the IP2 intake structure, the design of the IP3 intake structure makes it possible for fish that pass through the trash racks associated with any of the seven openings on the western side of the structure to swim within the structure parallel to the traveling screens and exit the structure through the openings at the north and south ends. The IP1 intake structure is located between the IP2 and IP3 intakes (south of IP2 and north of IP3), behind a pile-supported dock. The IP1 intake is outfitted with coarse bar screens (3.5 inch on center spacing, 3 inch open space) at each of four intake bays, which are arranged in two sets of two bays each. Since the original IP1 intake was designed to accommodate 280,000 gpm of cooling water flow, but now withdraws no more than 16,000 gpm of service water flow, the through bar rack intake velocities at IP1 are considerably lower than at IP2 or IP3. A single 0.125-inch mesh dual- flow screen is located within the DRAFT MONITORING PLAN FOR IPEC STURGEON IMPINGEMENT IPEC draft sturgeon monitoring plan.docx 3/29/13 3 Normandeau Associates, Inc.

service water portion of each of the two intake bay sets at IP1. Each dual flow traveling screen at IP1 has a design through-screen velocity estimated as less than 0.5 ft/second, which is considered to be the best technology available (BTA) for reducing impingement by USEPA in their proposed regulations of cooling water intake structures at existing facilities (40CFR §125.94(b)(2) (28 March 2011). 1.2.2 Cooling Water Flow Management The dual speed cooling water pumps at IP2 and variable speed cooling water pumps at IP3 were installed in the mid-1980s to minimize impingement and entrainment of fish by reducing the amount of water used for cooling. Since the amount of water needed for efficient operation varies with the river temperature, cooling water flow is reduced as much as 50% during winter months when river temperature is at its annual low. Lower flow rates not only reduce the amount of water withdrawn, but also reduce the intake velocity, facilitating escapement of fish that otherwise might be susceptible to impingement. At IP2, each of the six of the cooling water bays provides water to an individual cooling water pump, which is located 35 feet behind the traveling screens. At the maximum pumping rate (140,000 gpm per pump), the maximum (at mean low water) calculated through-screen velocity for the IP2 traveling screens is 1.6 fps (Enercon 2010). The IP2 cooling water pumps can also be operated at 84,000 gpm, which proportionally reduces the maximum average through-screen velocity to 1 fps. For the service water intake bay at IP2, the maximum through-screen velocity is 0.35 fps when all six service water pumps are operated at a maximum (design) capacity of 30,000 gpm. The six IP3 cooling water pumps, each enclosed in an intake bay and located 28 feet behind the traveling screens, have a continuously variable capacity between 70,000 and 140,000 gpm. Three of the bays are also equipped with 3,200 gpm screen wash pumps. The seventh bay, located in the center of the structure, provides water to the six service water pumps, which have a maximum combined capacity of 36,000 gpm. As at IP2, the maximum average through-screen velocity for the cooling water bays is 1.6 fps (Enercon 2010), and is 0.4 fps for the service water bay. The dual-flow screens in the IP1 intake filter the water drawn by the single 16,000-gpm service water pump and the two 1500-gpm spray wash pumps in each of the two intake bay sets. The screens are washed automatically when water level differences between the front and back of the screens exceed predetermined settings. Materials removed from the traveling screen mesh are sluiced to the Hudson River in the wash water flow. During normal operation only one of the two service water pumps and two of the spray wash pumps is in operation at any given time at IP1(Enercon 2010). 1.2.3 Optimized Ristroph-Type Traveling Water Screens The IP2 and IP3 intakes are outfitted with optimized Ristroph-type traveling screens and fish handling and return systems. The Ristroph-type screens and fish return systems were operational at IP3 in 1990, and at IP2 in 1991, following a collaborative research, design, and validation effort among the former owners of IP2 and IP3, the New York State Department of Environmental Conservation (NYSDEC), and the scientific advisor to the Hudson River Fishermans Association (HRFA, now Riverkeeper). The Ristroph-type screens have the following aquatic organism protection features:

DRAFT MONITORING PLAN FOR IPEC STURGEON IMPINGEMENT IPEC draft sturgeon monitoring plan.docx 3/29/13 4 Normandeau Associates, Inc.

Dual-speed continuous rotation - The screens are rotated continuously. Under low debris loading conditions, the screens are rotated at 2.5 fpm and under high debris loading at 10 fpm. Impingement on the screens and mortality of those organisms that are impinged is less likely to occur when low through-screen velocities are maintained by the continuous removal of debris. Continuous rotation also minimizes the time that impinged organisms are retained on the screen panels or in the fish buckets. These features significantly reduce the potential stress on impinged organisms. Smooth screen mesh - The 0.5 inch x 0.25 inch clear opening slot mesh on the screen panels is smooth, to minimize abrasion to fish transferred into the fish return systems. Flow deflector lip on fish buckets - The curved lip at the leading edge of the fish buckets is designed to minimize vortex stress on fish inside the buckets. The lip eliminates turbulent flow in the interior of the buckets and provides sufficient water depth to allow fish to maintain a stable, upright position (Fletcher 1985). Dual-pressure spray wash systems - The screens encounter a series of spray washes in the operating rotation. First, high-pressure sprays are used to remove debris from the screen mesh surface. During this process, deflector plates are used to protect aquatic organisms in the fish buckets. Low-pressure sprays are then used to gently remove aquatic organisms from the fish buckets for release through the fish return system. Finally, another series of high-pressure sprays are used to wash off any remaining debris to prevent carryover into the intake bays and assist in maintaining the available open area of each screen panel to reduce the potential for impingement. The current fish handling and return systems at IPEC also incorporate several design features specifically selected to enhance fish survival: Separate fish return and debris return systems are provided. Fish return systems have smooth surface coatings and gentle transition sections to minimize the potential for fish abrasion during transport. Design water depths are maintained to allow the fish to remain in a stable, upright position during transport. Design trough/sluice water velocities are maintained between 2 fps and 5 fps, which are sufficient to transport the organisms back to the river while minimizing stress during transport. Return pipe discharge locations were selected following dye and fish release studies to minimize the potential for re-impingement. Collectively, the optimized Ristroph-type screens and the fish return systems, both developed through the extensive collaborative process referenced above, reflected first-in-kind design when installed, and continue to reflect state-of-the-art design today. The effectiveness of the modified Ristroph-type screens in reducing impingement losses was demonstrated in studies showing the technology to be fully optimized as BTA for DRAFT MONITORING PLAN FOR IPEC STURGEON IMPINGEMENT IPEC draft sturgeon monitoring plan.docx 3/29/13 5 Normandeau Associates, Inc.

impingement (Fletcher 1990), a conclusion supported by the inclusion of the IPEC configuration as BTA for impingement on a nationwide basis (USEPA 2011). Entergy proposes to continue operating IPEC using this once-through cooling system for the duration of its operating licenses, or until a different system is determined to be BTA for the IPEC facility and the alternative system can be permitted, constructed, and installed. 2.0 Monitoring Program The implementation schedules for monitoring (1) trash racks, (2) intake bays, (3) the traveling screens, as well as (4) collecting ancillary data associated with sturgeon occurrences, are set forth in the program components below (with references to the specific section of the Opinion in which the program element is specified). 2.1 Monitoring at Trash Racks Monitoring sturgeons at the trash racks is specified by RPM#1, and T&C#s 1.a, 1.b, and 1.c of the Opinion. 2.1.1 IP2 and IP3 The main focus of trash rack monitoring is on moribund or dead sturgeon, which would be impinged at the trash racks solely because they are incapable of escapement. Specifically, since sturgeon large enough to become impinged on the trash racks are also large enough to easily avoid or overcome the intake approach velocity at the trash racks ranging from 0.5 to 0.9 fps, the only sturgeon likely to be found against the trash racks are ones that died before encountering the IPEC intake and drifted against the trash racks in the intake flow. It is expected that sturgeon impingement on the trash racks will be extremely infrequent because (1) sturgeon large enough that they could not fit through the trash racks (i.e., those greater than 3 inches in limiting body width dimensions, or approximately 600 mm total length) would have few predators and low natural mortality rates and (2) closure of the shad and sturgeon fisheries in the Hudson River has eliminated the fisheries by-catch mortality that was the likely source of many previously observed sturgeon impingements at IPEC. There are no feasible access points to assess impingement at the trash racks from the bulkheads at the CWISs, either directly by visual observation or with remote sensing equipment. The only practical method of detecting impingement on the trash racks is to use a sampling vessel equipped with mobile imaging sonar. Due to the expected low frequency of occurrence, as well as the expense, difficulty, and safety concerns inherent in conducting sampling vessel operations at the face of an operating intake structure, Entergy proposes to monitor the trash racks once weekly (except in extreme weather conditions such as ice flows in the winter or high winds, waves, and other storm events) during the first two years of the monitoring program. This frequency of monitoring, which is commonly used for impingement sampling programs, will be used to evaluate whether trash rack monitoring frequency should be increased, decreased, or discontinued altogether in remaining years. Another consideration determining the appropriate monitoring frequency is the rate at which dead fish are likely to deteriorate to the extent that they can no longer be detected.

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Degradation of fish carcasses results from scavenger predation and bacterial decomposition, with both processes occurring more rapidly at warmer temperatures. Weekly monitoring at the trash racks should be frequent enough so that decomposition does not prevent the detection and collection of any dead impinged sturgeon. If deterioration of sturgeon impinged on trash racks in less than a week is indicated by the presence of decayed sturgeon or sturgeon parts in traveling screen impingement collections (Section 2.3), then a deterioration rate study will be designed in conjunction with NMFS and conducted to establish the appropriate adjustment to the trash rack monitoring frequency. Examination of trash racks for impinged sturgeon will be conducted using a mobile imaging sonar unit called an Adaptive Resolution Imaging Sonar (ARIS) Explorer 1800, manufactured by Sound Metrics Corporation (Figure 2-1), deployed from a sampling vessel in front of each intake bay. ARIS is a further development of the successful dual-frequency identification sonar (DIDSON) technology, with increased resolution and reliability, enhanced electronic capabilities, and decreased weight and power consumption. This technology can distinguish sturgeon from other fishes (Nelson et al. 2010) and was effective within a range of 20 m in detecting white sturgeon and estimating their sizes in spawning concentrations in the Columbia River (Crossman et al. 2011). Any sturgeon will be removed from the trash racks with a long handled (35 ft -40 ft) dip net while observing the positioning of the net opening with the ARIS to guide it to the impinged fish. This dip net is a wire basket mounted in a frame that slides down and up on grooved rollers or guides that align with the 3.5-inch on center spacing of the bar racks to guide the net as it is lowered through the water while being pressed against the trash rack by the intake current. Any sturgeon removed from the trash racks will be processed as described in Section 2.4. 2.1.2 IP1 The Unit 1 trash racks are deeply recessed behind the fuel dock, which precludes access to the outside of the trash racks by boat, and there are no deck openings that would provide access from above. It is therefore not possible to effectively monitor the IP1 trash racks. Given the unknown but low expected frequency of occurrence at the IP2 and IP3 trash racks, and the much lower flows and associated through-rack intake velocity at IP1 (about 1% of the flow rate for all three units combined), it is expected that impingement at IP1 trash racks would be exceedingly rare. Indeed, expected impingement would be well below the typical thresholds for considering impingement impacts, particularly (1) for robust species, such as sturgeon, and (2) because any sturgeon impinged on the IP1 trash racks was likely dead before becoming impinged. For these reasons, trash rack monitoring of Unit 1 is not reasonable in light of the fundamental objectives of the Opinion and monitoring program. 2.1.3 Trash Rack Monitoring Implementation Schedule, Modifications, and Permits Trash rack monitoring at IP2 and IP3 will be implemented within 120 days of NMFS final approval of this monitoring plan. Trash rack monitoring will not require any modification to IPECs intake structures that would need NRC or State of New York approvals before implementation. Although no physical plant alterations are required for trash rack monitoring, prior to implementation DRAFT MONITORING PLAN FOR IPEC STURGEON IMPINGEMENT IPEC draft sturgeon monitoring plan.docx 3/29/13 7 Normandeau Associates, Inc.

IPEC will need to approve the project-specific Health and Safety Plan (HASP), and provide the necessary security clearance for the observer boat to approach the intake structures. 2.2 Monitoring in Forebays The Opinion requires monitoring for and removal of sturgeons from the intake forebays (spaces between the trash racks and the traveling screens) in RPM#1 and T&C#s 1.d, 1.e, and 1.f. There are several reasons why this requirement is not reasonable to implement at IPEC. First, any live sturgeon in the forebays will either swim back out into the river voluntarily through the trash racks or they will be collected on the continuously rotating Ristroph screens and released back into the river via the fish return troughs, making their removal from the forebays unnecessary. Second, this location is very difficult to access and would not be a place where people could work safely. Third, detection of sturgeon within the forebays would be difficult because the imaging sonar technology used for detection would not work well in this confined space due to interference from the structures. Fourth, even if sturgeon could be detected, it would not be possible to capture and remove them in a way that would impose less stress than allowing them to either return to the river voluntarily or be collected on the Ristroph screens (a system proven to produce high survival rates). Thus, this is not a reasonable monitoring requirement for implementation at IPEC. 2.3 Monitoring at Traveling Screens Monitoring, detection, and handling of sturgeons impinged on the traveling screens is required by RPM#1 and T&C#1.e of the Opinion. As described in Section 1, IPEC's traveling screens meet USEPA's definition of Best Available Technology for reducing impingement mortality by (1) ensuring that aquatic organisms are retained on the screens for a very short time due to continuous rotation, (2) using modified "buckets" that provide a haven of stilled water protecting fish from turbulence before the screen rotates above the water, (3) having a specially designed wash system to remove organisms from the screens with a minimum of damage, (4) employing optimized return trough designs to eliminate damage during transit back to the river, and (5) releasing fish at locations selected to minimize re-impingement and predation. This entire system, designed and installed more than 20 years ago through the cooperative efforts of the IPEC owners, NYSDEC, and HRFA, minimizes mortality of fish and other organisms that interact with the traveling screens, if it is allowed to operate as designed. Modifications to the system, and operation in a way that would ensure that all (as opposed to a representative sample of) sturgeon are detected, identified, and handled, will result in unnecessary mortality on many other species of impinged fish, particularly clupeids (herrings) and engraulids (anchovies), which are not as hardy as sturgeons. For this reason, we propose a sampling approach to this requirement that will permit accurate estimation of the levels of sturgeon impingement (Cochran 1977), while still allowing most other impinged fish to be returned rapidly to the river and minimize their mortality. 2.3.1 Traveling Screen Monitoring at IP2 and IP3 Consistent with the shared goal (by Entergy, NYSDEC, HRFA, and presumably also NMFS) of minimizing stress on all impinged fish (including sturgeon), sturgeon that are collected DRAFT MONITORING PLAN FOR IPEC STURGEON IMPINGEMENT IPEC draft sturgeon monitoring plan.docx 3/29/13 8 Normandeau Associates, Inc.

by the continuously rotated traveling screens will be sampled during one 24-hour sampling event per week at each operating unit during the first year of monitoring. In the second year, Entergy will consider and discuss with NMFS whether a variable frequency sampling plan can be implemented in which that sampling effort is redistributed among seasonal sampling strata (Mattson et al. 1988) to better reflect the observed seasonality of sturgeon impingement. If the variable frequency plan is not adopted, the year one methodology described below will be followed in year two. To enable IPECs fish handling and return system to convey live impinged fish promptly back into the Hudson River with minimal stress, fish in the screen wash flow in the fish return sluices will be diverted by modified fish sluice sections into temporary holding tanks. The tanks will be designed to minimize handling stress and sized to accommodate maximum expected impingement loadings of fish over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, considering both the number and sizes of fishes that could be impinged. Tanks will normally be staffed for one eight-to-ten-hour shift each sampling day to process the fish and debris collected over the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. All fish and debris collected will be examined for the presence of sturgeon, and any sturgeon found will be removed and processed as described in Section 2.4. Fish other than sturgeon will be allowed to return to the river in the screen wash flow downstream from the sampling devices without being processed. Suitable locations for the required sampling tanks were identified at both IP2 and IP3 during a site visit on 26 February 2013, and will be a topic of discussion during the proposed intake tour with NMFS: IP2 - There are two separate sluice systems, each serving three of the six CW pumps. Each of the IP2 fish sluices drops below deck level soon after passing the last of the three screens it services, and the junction of the flows from the two fish sluices is below deck. A separate holding tank will be installed at each of the two fish sluices at IP2 (South for screens 21-23, and North for screens 24-26), where there is available space for an above-deck tank that can drain into the below-deck sluice (Figure 2-2). IP3 - The single fish sluice will be diverted into a single collection tank located between the discharge canal and the building housing the traveling screens (Figure 2-3). Each holding tank will be fitted with a screened area of 0.5 inch x 0.25 inch mesh to temporarily retain all fish and debris for examination. The mesh will surround the top of the tank to maximize filtering area and therefore minimize through-mesh velocity, minimizing both the stress on the fish and the potential for debris to clog the mesh. Although holding stress in the collection tanks will be minimized to the extent possible, the holding period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> will be likely to induce some mortality, particularly in pelagic, active swimming species, such as herrings and anchovies. Consistent with hatchery experience, it is expected that sturgeons will not be adversely affected by retention in the tanks for this 24-hour period because juvenile and adult shortnose sturgeon have been held in hatchery facilities with cylindrical outdoor tanks for periods of months to years for experimental testing (Collins et al. 2002). Apart from minimizing physical stress from turbulence, the two critical aspects that control survival rates of fish in holding tanks are biomass density (kg/m

3) and turnover rate, which is the number of tank volumes exchanged per hour (Wedemeyer 2001). The tanks must be DRAFT MONITORING PLAN FOR IPEC STURGEON IMPINGEMENT IPEC draft sturgeon monitoring plan.docx 3/29/13 9 Normandeau Associates, Inc.

large enough to avoid overcrowding, but small enough so that the flow rate through the tanks generated by the screen wash water will provide adequate water exchange, thus maintaining favorable dissolved oxygen concentrations and preventing accumulation of metabolic wastes. The critical aspects of density and turnover are determined by three factors: the flow rate through the tank, the total biomass of fish, and the size of the tank (Wedemeyer 2001). Tank dimensions will be designed to maintain acceptable levels of biomass density and turnover rate within the constraints of (1) the maximum flow rate, (2) the maximum anticipated impingement rate, (3) available space, and (4) practical limits of the size tank that can be tended by a crew of two in a reasonable amount of time. 2.3.2 Traveling Screen Monitoring at IP1 Due to the extremely low flows at IP1, where only one set of service water pumps and screen wash pumps are in use at an intake structure designed for much higher flow rates, the amount of water withdrawn is so small and the intake velocities are so low that expected impingement is nearly zero. NMFS expectation stated in the Opinion, based on the proportion of water withdrawn at IP1 but not considering the lower intake velocities, is a rate of 1 shortnose sturgeon and 1 Atlantic sturgeon per 10 years of operation. Furthermore, each dual flow traveling screen at IP1 has a design through-screen velocity estimated as less than 0.5 ft/second, which is considered to be the best technology available (BTA) for reducing impingement by USEPA in their proposed regulations of cooling water intake structures at existing facilities (40CFR §125.94(b)(2) (28 March 2011). Therefore, it is not reasonable to expend the time and effort to monitor for events that are this infrequent, particularly if the same information can be gained by monitoring at locations where expected occurrences are much more frequent. 2.3.3 Traveling Screen Monitoring Implementation Schedule, Modifications, and Permitting Once both NMFS and NYSDEC have approved the final monitoring plan, there are certain reviews required by IPEC (including an engineering structural analysis of load-bearing requirements) to ensure that continued safe operation of IPEC is not jeopardized by the proposed CWIS modifications.

Traveling screen monitoring is proposed to be implemented within approximately 180 days after the later of NYSDECs approval of the monitoring plan and the associated changes to the design and operation of the Ristroph screen system or the completion of the NRC-mandated modification review discussed below. Traveling screen monitoring will require modification of the NYSDEC-approved fish return systems to allow diversion of the flow in the fish sluices into holding tanks and drainage from the tanks back into the fish return system farther downstream. Thus, NYSDECs prior approval will be required before making these changes to IPECs fish return system and its operation, including temporary stoppage of traveling screen washing and rotation to connect modified sluice sections to the tanks. Consultations will be held with NYSDEC during the finalization of the monitoring plan to obtain in advance their necessary approval. Entergy also provided the following list of steps that likely will be required to install the collection tanks and modify the fish sluices at IP2 and IP3 in compliance with all applicable IPEC procedures:

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Obtain a Project Manager/Engineer and project team Develop a Project Plan Obtain detailed cost estimate and funding approval Obtain plant approval from engineering change review group and other management committees, as needed Develop an Engineering Request and Engineering Change Develop a Risk Management Plan Perform a 10CFR50.59 screening to determine if an NRC review is required (an NRC review is not likely to be required) Determine the actual screen wash flow rates to enable finalization of the size and design of the collection tanks Perform an engineering structural analysis to ensure that flooring and underground utilities can support the weight of the filled tanks at the chosen locations Obtain a contractor Procure the equipment Develop IPEC operating procedures Develop biologist Standard Operating Procedures (SOP) Connect the completed system and test it 2.4 Fish Handling Procedures Any sturgeon collected will be processed as required under the federal Endangered Species Act following the stated RPMs and T&Cs of the Opinion. 2.4.1 Live Fish All live sturgeon will be processed as specified in RPM#2 and T&C#3 of the Opinion by the procedures described in this section to check for previously applied tags, measure the length and weight, record any physical abnormalities, photograph the specimen if smaller than 250 mm total length (TL), apply an external tag if the specimen is larger than 250 mm TL and was not previously tagged, apply a magnetic tag if one is not already present, collect a genetic sample, and release the specimen away from the intake via the existing fish return system. Previously applied tags could include yellow USFWS Floy tags, Carlin-Ritchie disc tags, or passive-integrated transponder (PIT) tags. A hand-held PIT tag reader will be used to examine for the presence of internal PIT tags. The tag type and number of any tags found will be recorded and the condition of the tag insertion site will be noted (whether healed or infected). The total length (TL) will be measured to the nearest mm and the fish will be weighed to the nearest gram. Any obvious physical abnormalities, such as fin rot, will be noted. Photographs will be taken of sturgeon smaller than 250 mm TL and any recaptured previously tagged specimens to provide verification of the species identification. Three DRAFT MONITORING PLAN FOR IPEC STURGEON IMPINGEMENT IPEC draft sturgeon monitoring plan.docx 3/29/13 11 Normandeau Associates, Inc.

digital photographs of each specimen will include a close-up of the eyes with a mm ruler for scale, a close-up of the mouth with a mm rule for scale, and a close-up side view of the base of the anal fin to reveal the presence or absence of anal scutes. If the sturgeon is larger than 250 mm TL and was not previously tagged, a Floy dart tag will be attached to the dorsal fin base by inserting the tag forward and angled slightly downward through the dorsal pterygiophores and twisting it to ensure anchor attachment. Before a sturgeon is released alive it will be tagged with a PIT tag (if one is not already present) to assess re-impingement and post impingement handling and tagging survival. The tag will be inserted with a large hypodermic needle under the third or fourth dorsal scute by first puncturing in a fleshy area and then positioning the needle to push up underneath the scute. The fish will be scanned with the PIT tag reader and the tag number will be recorded. A genetic sample will be collected by the procedures in Section 2.4.3 from each live sturgeon that was not previously tagged. To minimize the risk of re-impingement or exposure to the thermal plume, live sturgeon will be released in the screen wash flow through existing return sluices, which were designed to transport impinged fish to locations sufficiently deep and far enough from the intakes to avoid the thermal plume and the intakes. 2.4.2 Dead Fish All dead sturgeon will be processed as specified in RPM#3 and T&C#4 of the Opinion. Dead sturgeon will be checked for previously applied tags. External criteria will be used to determine if a dead sturgeon was freshly killed or previously dead. The nature of observed external injuries will be described. Genetic samples will be collected by the procedures in Section 2.4.3 from all dead sturgeons that were not previously tagged. Dead specimens or body parts of Atlantic and shortnose sturgeon retrieved from the IPEC intakes will be photographed, measured, and retained. They will be frozen until transferred to NMFS or to an appropriately permitted research facility designated by NMFS, so that a necropsy can be conducted in an attempt to determine the cause of death. 2.4.3 Genetic Samples RPM#4 and T&C#5 of the Opinion requires that a genetic sample will be taken from any live or dead Atlantic or shortnose sturgeon collected that was not previously tagged. A new pair of latex gloves and a new scalpel blade will be used for each individual fish to avoid cross-contamination of genetic material. If contamination occurs, that genetic sample will be discarded.

A 1 cm 2 section will be cut from a pelvic fin and placed in a vial of 95% to 100% ethanol that has not been denatured with methanol or other chemical additives. The vial will be taped to prevent leakage, labeled with the sample number and fish identification number using a permanent marker, and sealed in a small Ziploc bag labeled internally and externally with the sample number. Genetic samples will be kept in a cooler on ice until returning to the field laboratory, where they will be refrigerated until they are shipped to NMFS or the analytical laboratory designated by NMFS.

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2.5 Ancillary

Data 2.5.1 Temperature RPM#1 and T&C#1.l of the Opinion specifies temperature measurements at the trash racks and at the traveling screens, at surface, mid-depth, and bottom for each unit when a take of either species of sturgeon is observed. It is not possible to determine exactly when or where impingement events will have occurred within the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. At IP2, the CWIS fish return design is such that it will be possible to determine whether a take on a traveling screen occurred at screens 21-23 or at screens 24-26 (Figure 2-2), but not the depth at which it was impinged. At IP3, the CWIS design is such that it will not be possible to determine at which screen a take occurred, or at which depth (Figure 2-3).Therefore, given the general stability of thermal conditions, the typical absence of thermal stratification (ASA 2011), and the amount of information already available on thermal conditions near the intakes, this level of additional data collection is unnecessary. There are no sources of heat addition during the transit of the water through the trash racks to the traveling screens and to the condensers. Therefore, the current hourly measurement of temperatures at the condenser inlet water boxes provides an accurate description of the depth-averaged water temperatures at the intakes. The large volume and degree of mixing in the Hudson near IPEC due to the channel configuration and tidal currents makes it a fairly stable thermal environment that is not prone to rapid temperature changes. What vertical temperature structure that exists is due primarily to the IPEC discharge plume that rises to the surface and during flood tides may be recirculated back to the intakes. The thermal stratification and plume characteristics are well-described by recent data collection and modeling efforts (ASA 2011). In light of the available information and the inability to precisely determine the time or location of an impingement event, the requirement for additional temperature data measured at the bar racks and traveling screens as specified in RPM#1 and T&C#1.l of the Opinion does not reasonably or materially advance the purposes of the Opinion or the monitoring program. RPM#1 and T&C#1.l of the Opinion will be addressed by reporting intake temperature obtained from plant operating records and reported in summarized format (mean, standard deviation, maximum and minimum) for each sampling event when a sturgeon of either species is observed on the trash racks or traveling screens. 2.5.2 Water Velocity RPM#1 and T&C 1.k of the Opinion specifies measuring actual water velocity at the trash racks (approach velocity and through the rack), in the intake forebays, and at the traveling screens (both approach velocity and through-screen velocity) at all three units "so that this information can be reported any time a take occurs." The statement of the purpose for velocity monitoring appears to presume that some relationship between velocity and impingement could be determined from the data so that either (1) intakes could be designed or operated to keep velocity below some threshold for impingement, or (2) velocity monitoring will provide an advance signal of high potential impingement so that preventive measures can be taken. Although this goal is admirable, the actual situation at IPEC is that there are many reasons why this would be a futile effort:

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

2. Due to the way that Indian Point is operated, intake velocity is relatively constant. Although the IPEC pumps can pump at different rates (IP2 at 60% or 100%, IP3 at a continuum of 50%-100%), the amount of water needed at any given time is determined by the river temperature. Therefore pumping rates, and subsequently intake velocities, actually have little variation from one day to the next.

3. Due to the design of the bar racks, their location at the outer edge of the intake structures, and the ecology of the Hudson River estuary, the trash racks do not have debris accumulations sufficient to block flow and substantially increase velocities at either the trash racks or traveling screens. The trash racks also serve to straighten the intake currents that pass through them, thus reducing the variation in velocity across the ascending face of the Ristroph-type traveling screens. Trash racks are cleaned only twice per year, during a semi-annual inspection, which is frequent enough to avoid high intake velocity incidents. The Ristroph-type traveling screens are cleaned continuously.

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

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

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

7. Velocity will differ over the face of both the bar racks and trash racks.

8. Measurements of actual through-screen velocity are not possible in the field for the Ristroph-type traveling screens. Rather than continuous measurement of intake velocities at each unit, Entergy proposes to measure the approach velocities upstream from the bar racks, using acoustic Doppler velocity (ADV) meters deployed at four different times during the first study year to characterize the range of variation expected. Ambient river current velocity, flow direction, and tide height will be measured to establish river flow boundary conditions simultaneously with the bar rack approach velocity measurements using acoustic Doppler current profilers (ADCPs) deployed in the river near the intakes. Bar rack approach velocity measurements will be taken at middle and upstream intake bays at IP2 and at IP3. Due to the difficulties of access at IP1 and at the forebays in front of the traveling screens, no velocity measurement will be taken there.

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Velocity measurements will be taken to represent the variation observed across the upstream face of each bar rack sampled, at nine points located at the intersection of three horizontal and vertical lines spread evenly among three depths and three lateral positions. The velocity measurements will be taken during peak and slack tidal currents at four times during the first year, representing high intake flow rates (140,000 gpm per pump) and high tide height, high intake flow rates and low tide height, low intake flow rates (~84,000 gpm per pump) and high tide height, and low intake flow rates and low tide height. Velocities through the bar racks and through the traveling screens will be calculated using each set of observations during the first year and the associated physical dimensions of the racks and screens. 2.5.3 Plant Operating Data RPM#1 and T&C 1.m of the Opinion requires that the plant operating conditions at each unit are documented for the previous 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> associated with each take, the field staff will contact the control room and obtain and record data provided by the plant operators regarding the number of circulating pumps operating. 2.5.4 Ancillary Data Collection Implementation Schedule, Monitoring, and Permits Ancillary data collection will be implemented when sturgeon impingement monitoring is initiated (except for water velocity and temperature measurements at the CWIS, which will be conducted only during the first year of the monitoring period). No NRC or State of New York approvals are required before implementation of ancillary data collection. No physical plant alterations are necessary to allow ancillary data collection to be implemented, but recording condenser inlet temperatures in a computer file (Section 2.5.1 above) will require a procedural modification at IPEC. 2.6 Reporting This section describes procedures for reporting to NMFS all sturgeon incidental takes and sample transfers as required by RPM#5 and T&C#s 6, 7 and 8 of the Opinion. 2.6.1 Take Notification NMFS will be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of finding any live or dead Atlantic or shortnose sturgeon in association with the IPEC intakes as required by RPM#5 T&C#6 of the Opinion. The form for reporting each incidental take of any sturgeon (alive or dead) is shown in Figure 2-4. 2.6.2 Annual Report An annual report of all incidental takes of Atlantic and shortnose sturgeon occurring at the IPEC intakes during each calendar year will be submitted to NMFS and NRC by 15 February of the following year as required by RPM#5 T&C#7 of the Opinion. The annual report will include any necropsy reports of specimens, all incidental take reports, photographs, a record of all sightings of Atlantic or shortnose sturgeon in the vicinity of Indian Point, conditions at the time of the take (IPEC operations as well as environmental conditions including water temperature and water flow), and a record of when inspections of the intake trash bars and Ristroph screens were conducted. The report will include a DRAFT MONITORING PLAN FOR IPEC STURGEON IMPINGEMENT IPEC draft sturgeon monitoring plan.docx 3/29/13 15 Normandeau Associates, Inc.

summary table of environmental sampling data in the format specified by NMFS (Figure 2-5). The annual report will also identify any potential measures to reduce shortnose or Atlantic sturgeon impingement, injury, and mortality at the intake structures along with any plans to implement those measures. Following the submittal of each annual report and prior to 15 April of each year, Entergy will participate in a meeting or conference call with NMFS and NRC to discuss the take information of the prior year and any changes to the monitoring program that NMFS, NRC, or Entergy believes are necessary as required by RPM#5 T&C#8 of the Opinion. 2.6.3 Genetic Samples As specified in the NMFS instructions for collecting, certifying, identifying, and shipping sturgeon tissue samples (Figure 2-6), each shipment of sturgeon genetic tissue samples will be accompanied by (1) a completed Certification of Species, Sample Identification, and Chain of Custody form for each fish (Figure 2-7); (2) a completed Summary Sheet for Genetic Tissue Samples form if the shipment contains multiple samples (Figure 2-8); (3) a completed NMFS Guidelines for Air-Shipment of Excepted Quantities of Ethanol Solutions form (Figure 2-9); and (4) a copy of the ESA permit authorizing the collection of the sample(s). Because the origin of impinged fish factors into the take limits specified in the ITS, Entergy requests to receive the results of the genetic analysis as testing is completed on each fish. 2.6.4 Dead Sturgeon or Sturgeon Parts If any dead specimens of Atlantic or shortnose sturgeon are found in association with the IPEC intakes, after they are processed as described in Section 2.4.2, NMFS may request transfer of the specimens to NMFS or to a NMFS-approved laboratory or researcher for necropsy. In addition to the take notification form (Section 2.6.1), a Sturgeon Salvage form (Figure 2-10) will also be submitted to NMFS, to document the disposition of each dead specimen. 2.7 Training of Field Biologists Qualifications of all personnel who will be handling sturgeon will include previous training and experience in the implementation of NMFS Permit to Take Protected Species for Scientific Purposes Permit No. 17095 (and its predecessor, Permit No. 1580) for the Hudson River Biological Monitoring Program (HRBMP). All field personnel participating in the IPEC sturgeon monitoring will be required to read the SOP and will be provided with the appropriate training. Monitoring personnel unfamiliar with a task will be directly supervised by an experienced technician for at least the first two attempts and be subjected to 100% inspection of at least the first five samples analyzed independently. 2.8 QA/QC Procedures The basis for all quality control (QC) and quality assurance (QA) monitoring of program activities will be the SOP, consisting of written documentation of sampling and data collection protocols. The SOP will function to (1) insure that consistent and appropriate procedures are followed, (2) provide Entergy with documentation of the procedures used, DRAFT MONITORING PLAN FOR IPEC STURGEON IMPINGEMENT IPEC draft sturgeon monitoring plan.docx 3/29/13 16 Normandeau Associates, Inc.

and (3) enable a QA auditor observing program activities to determine whether the required procedures are being followed. QC will be conducted continually by qualified project staff. All field observations and measurements of sturgeon (identification, length, weight, injury, condition, tag numbers, etc.) will be subject to a standard and appropriate QC and QA review based on a Military Inspection Standard (MIL-STD) inspection plan derived from MIL-STD 1235 Single and Multiple Level Continuous Sampling Procedures and Tables for Inspection by Attributes to achieve a 10% Average Outgoing Quality Limit (AOQL). QC re-inspections for these sample processing tasks will be performed according to the continuous sampling plan CSP-1 at the 10% AOQL level, to insure that at least 90% of samples satisfy the projects acceptance criteria. This level of quality meets or exceeds New York, industry-wide, and HRBMP standards for fisheries measurement data. All final data files and reports will be subject to a standard and appropriate QC inspection to achieve a 1% AOQL so that the final data files will be certified through statistical inspection to document that less than one record (line of data) out of every 100 records will be in error. A QC inspection plan (CSP-1) will be used at the 1% AOQL level to insure that values of all variables in at least 99% of the data records provided in each data file correctly correspond to values coded on the original data sheets. This level of quality meets or exceeds New York, industry-wide, and HRBMP standards for fisheries data files. At least one QA Audit of the field activities described in Sections 2.1 and 2.3 through 2.5 above will be performed per year to verify adherence to the technical protocols specified in the SOP and verify the effectiveness of the QC system. QA auditors will be technically qualified to evaluate the activities being observed but independent from the project team. The audits will cover all activities described in the SOP, including transfer of data from field to completed data deliverables. The audit results will be documented in a written report for review by project management, Normandeau corporate management, and Entergy. 3.0 Literature Cited ASA (Applied Science Associates, Inc.). 2011. 2010 field program and modeling analysis of the cooling water discharge from the Indian Point Energy Center. Final report. ASA Project 2009-167. Prepared for: Indian Point Energy Center, Buchanan, New York. 31 January 2011. Cochran, W.G. 1977. Sampling techniques. Third Edition. John Wiley and Sons, New York. 428pp. Collins, M.R., D.W. Cooke, T.I.J. Smith, W.C. Post, D.C. Russ, and D.C. Walling. 2002. Evaluation of four methods of transmitter attachment on shortnose sturgeon, Acipenser brevirostrum. J. Appl. Ichthyol. 18: 491-494. Crossman, J.A., G. Martel, P.N. Johnson, and K. Bray. 2011. The use of dual-frequency identification Sonar (DIDSON) to document white sturgeon activity in the Columbia River, Canada. J. Appl. Ichthyol. 27 (Suppl. 2): 53-57.

DRAFT MONITORING PLAN FOR IPEC STURGEON IMPINGEMENT IPEC draft sturgeon monitoring plan.docx 3/29/13 17 Normandeau Associates, Inc.

Enercon (Enercon Services, Inc.). 2010. Evaluation of alternative intake technologies at Indian Point Units 2 & 3. Prepared for Entergy Nuclear Indian Point 2, LLC, and Entergy Nuclear Indian Point 3, LLC, February 2010. Electric Power Research Institute (EPRI). 2004. Impingement Abundance Monitoring Technical Support Document. EPRI Report 1008470. Palo Alto, CA. Fletcher, R.I. 1985. Risk analysis for fish diversion experiments: pumped intake systems. Trans. Amer. Fish. Soc. 114:652-694. Fletcher, R.I. 1990. Flow dynamics and fish recovery experiments: water intake systems. Trans. Amer. Fish. Soc. 119:393-415. Mattson, M.T., J.B. Waxman, and D.A. Watson. 1988. Reliability of impingement sampling designs: an example from Indian Point Station. Amer. Fish. Soc. Monogr. 4:161-169. Nelson, T.C., P. Doukakis, S.T. Lindley, A. Drauch Schreier, J.E. Hightower, L.R. Hildebrand, R.E. Whitlock, and M.A.H. Webb. 2010. Modern technologies for an ancient fish: tools to inform management of migratory sturgeon stocks. A report for the Pacific Ocean Shelf Tracking (POST) project. Available:

http//www.postprogram.org. Accessed 14 March 2013. USEPA (U.S. Environmental Protection Agency). 2011. Technical development document for the proposed Section 316(b) Phase II existing facilities rule, March 28, 2011, p. 7-2. USFWS (U.S. Fish and Wildlife Service) and NMFS (National Marine Fisheries Service).

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

Wedemeyer, G.A. (ed.). 2001. Fish hatchery management. 2nd edition. Amer. Fish. Soc.

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Figures

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Figure 1-1. Indian Point Unit 2 cooling water intake.

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Figure 1-2. Indian Point Unit 3 cooling water intake.

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Sturgeon detection by imagining sonar: The best image for visual recognition is achieved when the sonar beam pointing angle is shallow relative to the surface of interest such that the sound travels down the surface of the target and reflected back to produce the image. In this application, perhaps 10-30 deg angle down would appropriate at close horizontal distance to the bar racks. One-week FREE demo period; rent one for a pilot study Rotator available, e.g., to vessel-mount pole. Software allows files to save at any range and orientation automatically starting a programmed duration. ARIS EXPLORER 1800: 1.8 MHz Identification frequency; 1.1 MHz Detection frequency with rotator to control pan, tilt, and roll ; nominal effective range is 35 m detection/ 15 m identification; 3mm to 10 cm downrange resolution o About $80,500 o Rotator about $2500 o 1-Month lease = $12,500 ARIS EXPLORER 3000: 1.8/3.0 MHz, range 15/5 m probably not appropriate for our ranges Figure 2-1. Sonar system for detecting shortnose sturgeon or Atlantic sturgeon impinged at the IPEC trash racks.

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a b c (a) Example of fixed-location DIDSON and split-beam echo sounder to monitor fish impingement at a trash rack. (b) Monitoring trash rack effectiveness from 35-50 ft away with 1.8 MHz DIDSON. (c) Acoustic image of sturgeon at a dam from imagining sonar. www.soundmetrics.com Figure 2-1 (Continued).

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Acoustic image of sturgeon in river from imagining sonar. www.soundmetrics.com

Figure 2-1 (Continued).

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Figure 2-2. Proposed location of collection tanks at Unit 2.

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Figure 2-3. Proposed location of collection tank at Unit 3.

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

Observer's full name:_______________________________________________________ Reporters full name:_______________________________________________________

Species Identification :__________________________________________

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

Date animal observed:________________ Time animal observed: ________________________ Date animal collected:________________ Time animal collected:_________________________

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

Date and time of last inspection of intakes:_____________________________________ Water temperature (°C) at site and time of observation:_________________________ Number of pumps operating at time of observation:____________________________________ Average percent of power generating capacity achieved per unit at time of observation:________ Average percent of power generating capacity achieved per unit over the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> previous to observation:___________________________________________________________________

Sturgeon Information: Species _________________________________

Fork length (or total length) _____________________ Weight ______________________

Condition of specimen/description of animal

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

Fish Decomposed: NO SLIGHTLY MODERATELY SEVERELY Fish tagged: YES / NO Please record all tag numbers. Tag # ________________

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

Figure 2-4 Incident report form for incidental take of shortnose sturgeon or Atlantic sturgeon by impingement at the IPEC cooling water intakes.

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Draw wounds, abnormalities, tag locations on diagram and briefly describe below

Description of fish condition:

Figure 2-4 (continued).

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Figure 2-5. Summary form for environmental data associated with incidental take of shortnose sturgeon or Atlantic sturgeon.

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Figure 2-6. Instructions for collecting, certifying, identifying, and shipping sturgeon tissue samples.

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Figure 2-7. Certification of species, sample identification, and chain of custody form.

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Figure 2-8. Summary form for sturgeon genetic tissue samples.

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Figure 2-9. Guidelines and form for air shipment of excepted quantities of ethanol solutions.

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Figure 2-9 (continued).

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Figure 2-10. Sturgeon salvage form.

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Figure 2-10 (continued)