ML11195A160

Final Report, 2010 Field Program & Modeling Analysis of the Cooling Water Discharge from Indian Point Energy Center. Appendix E to End

ML11195A160
Person / Time
Site:	Indian Point
Issue date:	01/31/2011
From:	Cohn N, Crowley D, Decker L, Yeon Kim, Mendelsohn D, Miller L, Swanson C Applied Science Associates
To:	Entergy Nuclear Northeast, Office of Nuclear Reactor Regulation
References
Download: ML11195A160 (77)

Text

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge APPENDIX E: MOBILE SURVEY CTD PROFILES www.asascience.com ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile I during Spring Tide Salinity at Profile 1 during Neap Tide 20 40F'60-80o 4) 100-120 140 160 2 13.Jul 08:36 SBF-13-Jul 10:29 Flood-13-Jul 12:23 Flood 13-Jul 15:35 SBE 0)0 U 20 40 60 80 100 120 140 160 03-Aug 09:38 Ebb-03-Aug 12:56 SBF-- 03-Aug 14:57 Flood 03-Aug 19:00 Flood 2 4 6 8 10 1: Salinity (psu)4 6 8 Salinity (psu)10 12 2 Temperature at Profile 1 during Spring Tide Temperature at Profile 1 during Neap Tide 20 40-d)0 60-80-.13-Jul 08:36 SBF-13-Jul 10:29 Flood--13-Jul 12:23 Flood 13-Jul 15:35 SBE~60.~80 k.20 40 03-Aug 09:38 Ebb--03-Aug 12:56 SBF-- 03-Aug 14:57 Flood... .03-Aug 19:00 Flood 100-120-140-160r-75 d)0 100-120 -140-160 -75 80 85 90 Temperature (OF)80 85 Temperature (OF)90 Figure E-1: Salinity and temperature profiles at location 1 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 2 during Spring Tide Salinity at Profile 2 during Neap Tide A 2 4 6 8.4-I 0.0 0 (D 4)0.=J 0-0-0-0-0-o .. 03-Aug 09:35 Ebb-03-Aug 13:00 SBF-03-Aug 15:00 Flood 0 03-Aug 18:55 Flood 2 4 6 8 10 1 10 12 14 16 2 Salinity (psu)Salinity (psu)Temperature at Profile 2 during Spring Tide Temperature at Profile 2 during Neap Tide 0 20 40~60-=.. 80.too-0) 100-120 140 16 _5................

--1 .= o .0 s ,-13-Jul 08:40 SBF-13-Jul 10:32 Flood-13-Jul 12:26 Floodil.. ..13-Jul 15:38 SBE 20 40-60* 80 4) 100 0 F.....03-Aug 09:35 Ebb-03-Aug 13:00 SBF-03-Aug 15:00 Flood.....03-Aug 18:55 Flood 120-140 160L 75 80 85 90 80 85 90 Temperature (OF)Temperature (OF)Figure E-2: Salinity and temperature profiles at location 2 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 3 during Spring Tide A 2 4 8 a.4) 10 12 14 16l0 ...................

....... ....... .... ...........

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i. ..... ... ....i I- 134u 10:34 lood 0-13-Jul 12:30 Flood 13-Jul 15:41 SBE 2 4 6 8 10 1 Salinity (psu)Salinity at Profile 3 during Neap Tide 0 20 0 40..4)a)60-80k 100--120-140-160-2-03-Aug 09:31 Ebb-03-Aug 13:04 SBF-03-Aug 15:03 Flood-- 03-Aug 18:50 Flood 2 4 6 8 Salinity (psu)10 12 Temperature at Profile 3 during Spring Tide Temperature at Profile 3 during Neap Tide A 20 40 20 40~60-o-a) 100-0 120-140 160 75 4-, a)60.I 80F 03-Aug 09:31 Ebb-03-Aug 13:04 SBF-03-Aug 15:03 Flood 03Ag18:50 Flood-" .13-Jul 08:43 SBF-13-Jul 10:34 Flood-13-Jul 12:30 Floodi-13-Jul 15:41 SBE 100-120-140-160 75 80 85 90 80 85 90 Temperature (OF)Temperature (OF)Figure E-3: Salinity and temperature profiles at location 3 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 4 during Spring Tide Salinity at Profile 4 during Neap Tide 2 4 4) 10 12 14 16 0 0-0-0 --..... ..0-0-0. Jul 08:48 SBF-13-Jul 10:43 Flood 0- Jul 12:34 Flood 0 13-Jul 15:4O SBE 2 4 6 8 10 1: Salinity (psu)20 40 60 80 4-a a-U)03-Aug 09:25 Ebb-03-Aug 13:07 SBF-03-Aug 15:07 Flood 03-Aug 18:45 Flood 100-120-140-160-2 2 4 6 8 Salinity (psu)10 12 Temperature at Profile 4 during Spring Tide Temperature at Profile 4 during Neap Tide n U,.20 40 60 4:-a-U)20 40 860.c80 F 80W 100 U)120-140-160 *75 13-Jul 08:48 SBF-13-Jul 10:43 Flood-13-Jul 12:34 Flood 13-Jul 15:46 SBE 100 120-140-160-75...03-Aug 09:25 Ebb-03-Aug 13:07 SBF-03-Aug 15:07 Flood 03-Aug 18:45 Flood 80 85 90 80 85 90 Temperature (OF)Temperature (OF)Figure E-4: Salinity and temperature profiles at location 4 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 5 during Spring Tide A Salinity at Profile 5 during Neap Tide 20 40 60 4-I a)%80WF__-- 13-Jul 08:58 SBF-13-Jul 10:49 Flood-13-Jul 12:38 Flood-13-Jul 15:50 SBE 20 40 60 a)C: 0 80 03-Aug 09:05 Ebb-03-Aug 13:22 SBF-03-Aug 15:24 Flood-03-Aug 18:25 Flood 100 120 140 160 100-120-140 160-2 4 6 8 Salinity (psu)10 12 4 6 8 Salinity (psu)10 12 Temperature at Profile 5 during Spring Tide Temperature at Profile 5 during Neap Tide A U..20 40 4::60.80 4) 100 CI 20 40 60 r 80 4) 100 a I-03-Aug 09:05 Ebb-03-Aug 13:22 SBF-03-Aug 15:24 Flood 03-Aug 18:25 Flood 120F 140.160-75-. 13-Jul 08:58 SBF--13-Jul 10:49 Flood-13Jul 12:38 Flood..13-Jul 15:50 SBE 120-140-160-75 80 85 90 80 85 90 Temperature (OF)Temperature (OF)Figure E-5: Salinity and temperature profiles at location 5 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 6 during Spring Tide Salinity at Profile 6 during Neap Tide A I 2 4 6 8 4-'0.a)0 0 0 -....... ........... .-N ..... .....................................0 ........ ..........

................

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0-0 ........i .......i ............... ... ...........0 -- 13-Jul 09:02 SBF-13-Jul 10:52 Flood 0 Jul 12:43 Flood 0 ................

.... Jul 15:54 SBE 2 4 6 8 10 1 Salinity (psu)10'12'14'16'2 4 4- 0 Q 10 12 14 16 0 0-.. ......""".. ".. ""." ". "'" 00 ..... .. ...... .... .. ..... ..0- .. .... -- 03-Aug 09:01 Ebb-03-Aug 13:27 SBF 0 -.03-Aug 15:28 Flood 0 .03-Aug 18:18 Flood 2 4 6 8 10 12 Salinity (psu)2 Temperature at Profile 6 during Spring Tide Temperature at Profile 6 during Neap Tide nt U -'20 40 4-, 0~a)60 I 80.. ...13-Jul 09:02 SBF-13-Jul 10:52 Flood-. 13-Jul 12:43 Flood.........

13.Jul 15:54 SBE 40 F 0.a)60F 20 80 -,! ~ ~ ~ .. .. .. .. .... .....-..... 03-Aug 09:01 Ebb-03-Aug 13:27 SBF-03-Aug 15:28 Flood.......03-Aug 18:18 Flood 100 E 120-140-160 75 100-120-140-160 75 80 85 90 80 85 90 Temperature (OF)Temperature (OF)Figure E-6: Salinity and temperature profiles at location 6 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 7 during Spring Tide Salinity at Profile 7 during Neap Tide Li 20 40-2 4 6'-a 0)60k 80k 100-120-140L 160k 2 Q, 0_-13-Jul 09:06 SBF-13-Jul 10:57 Flood-13-Jul 12:47 Flood-I_ 13-Jul 15:59 SBE-8 10 12 14 U 0 --0 0-0 0-0 --03-Aug 08: 37 Ebb-03-Aug 13:47 SBF 0- Aug 15:48 Flood 0, 03-Aug 17: 59 Flood 2 4 6 8 10 1 Salinity (psu)4 6 8 Salinity (psu)10 12 16 2 Temperature at Profile 7 during Spring Tide Temperature at Profile 7 during Neap Tide 20 40 20 40~60." 80 4D 100-120-140[160 -75'60.r80 k 03-Aug 08:37 Ebb-03-Aug 13:47 SBF-03-Aug 15:48 Flood 03-Aug 17:59 Flood ()0 13-Jul 09:06 SBF-13-Jul 10:57 Flood-13-Jul 12:47 Flood--13-Jul 15:59 SBE 100-120-140-160-75 80 85 90 80 85 90 Temperature (OF)Temperature (OF)Figure E-7: Salinity and temperature profiles at location 7 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 8 during Spring Tide 0 20 40 S60.c 80 Q 100.4-I 0.a)a Salinity at Profile 8 during Neap Tide 0 20: 4 0 ......60-s o .. ......................i. ......... ....................100 120 -- 03-Aug 08:31 Ebb-03-Aug 13:54 SBF 140 Aug 15:51 Flood 160 .03-Aug 17:52 Flood 2 4 6 8 10 12 Salinity (psu)0 120- Jul09:1S0 F-13-JUl 11:00 Flood 140 -I -- 13-Jul 12:50 Flood 10 i---13.Jul 16:03 SEE 2 4 6 8 10 12 Salinity (psu)Temperature at Profile 8 during Spring Tide Temperature at Profile 8 during Neap Tide 20- 20 1J j40-G o .. ... ... ... ... .... ..... .. .. ... ..... .. .6 0 -~60- 0 a-0)80 100-120.- 13-Jul 09:10 SBF-13-Jul 11:00 Flood 140 Jul 12:50 Flood 160.. ..- .13-Jul 16:03 SBE 75 80 85 90 C~10 100 120 03-Aug 08:31 Ebb-03-Aug 13:54 SBF 140 Aug 15:51 Flood 160L ...... 03-Aug 17:52 Flood 75 80 85 90 Temperature (OF)Temperature (OF)Figure E-8: Salinity and temperature profiles at location 8 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 9 during Spring Tide Salinity at Profile 9 during Neap Tide.4-0.2 4"6 8 10 12 14 16 Uo .. ... ..... .... , -i 0 0-0 0 0 --13.Jul 09:15 SBF-13-Jul 11:04 Flood o0 Jul12:54 Flood 0 .13-Jul 16:07 SBE 0 20 40 60 80 0.0)0 03-Aug 08:26 Ebb-03-Aug 13:58 SBF-03-Aug 15:55 Flood 03-Aug 17:47 Flood 2 4 6 8 10 1: Salinity (psu)100 120 140 160 2 4 6 8 Salinity (psu)10 1 2 2 Temperature at Profile 9 during Neap Tide U , , 20 40 60-r- 80 go-') 100 120 140 160 75 03-Aug 08:26 Ebb-03-Aug 13:58 SBF-03-Aug 15:55 Flood--- 03-Aug 17:47 Flood 75 80 85 90 Temperature

(°F)80 85 90 Temperature (OF)Figure E-9: Salinity and temperature profiles at location 9 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 10 during Spring Tide Salinity at Profile 10 during Neap Tide A-C.4-.0.U)0 6 8 10 12 2 4 6 8 Salinity (psu) Salinity (psu)Temperature at Profile 10 during Spring Tide Temperature at Profile 10 during Neap Tide 20-40-~60-80-100 120[140 160 75 0.*4)0 U-20..40*,,60.80-100 120 140 160 75......................i. ......03-Aug 07:50 Ebb-03-Aug 14:37 SBF-03-Aug 16:13 Flood.-03-Aug 17:27 Flood i- 13-Jul 09:20 SBF-13-Jul 11:09 Flood-13-Jul 12:58 Flood 13-Jul 16:11ISBE 80 85 90 80 85 90 Temperature (OF)Temperature (OF)Figure E-10: Salinity and temperature profiles at location 10 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 11 during Spring Tide n Salinity at Profile 11 during Neap Tide 2 4) 10 12 14 16 s 0 ....................... ... ......... .........t0 0O .........

... ....++ t il 0 ...... .i ....... ..... ... .... .................. ...........0 o0 13-Jul 10:00 SBF-13-Jul 11:52 Flood o0 -1 3-Jul 13:44 Flood 0 .13-Jul 16:53 SB!2 4 6 8 10 1 2 Salinity (psu)2 4 6 8 Salinity (psu)10 12 Temperature at Profile 11 during Spring Tide Temperature at Profile 11 during Neap Tide U0 A 20 40 a-a.60F 80-- 13-Jul 10:00 SBF-13-Jul 11:52 Flood-13-Jul 13:44 Flood 13-Jul 16:53 SBE I ' I" r-a.V 20 40 60.80 100 120 140 160 _75 100 L u 120 " 140 160 -75 S Aug 08.04 Ebb-03-Aug 14-03 SBF--03-Aug 16:0 Flood-- 03-Aug 17A43 Flood 80 85 90 80 85 90 Temperature (OF)Temperature (OF)Figure E-11: Salinity and temperature profiles at location 11 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 12 during Spring Tide Salinity at Profile 12 during Neap Tide A 2 4*:6 4) 10 12 14 16 0-0-0 -13-Jul 10:02 SBF-13-Jul 11:54 Flood 0 Jul 13:46 Flood 0- 13-Jul 16:55 SBE 2 4 6 8 10 1: Salinity (psu)-C-I-.0.0)0 2 Salinity (psu)Temperature at Profile 12 during Spring Tide Temperature at Profile 12 during Neap Tide a ft 20 40 6o (D a)80.... 13-Jul 10:02 SBF-13-Jul 11:54 Flood-13-Jul 13:46 Flood 13-Jul 16:55 SBE 0.a)0 20-406 60 80 100 120 140 160 75--- 03-AugO0t.2Ebb 03-Aug SBF.. ...03-Aug 16:03 Flood--03-Aug 17:40 Flood 100-120-140-160-75 80 85 90 80 85 9O Temperature (OF)Temperature (OF)Figure E-12: Salinity and temperature profiles at location 12 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 13 during Spring Tide Salinity at Profile 13 during Neap Tide 0-C 2 4 6 010 12 14 16 0 0-0-0-0 03-Aug 07: 59 Ebb-03-Aug 14:08 SBP.0 Aug 16:05 Flood 0 r.....03-Aug 17:37 Flood 2 4 6 8 10 C Salinity (psu)6 8 Salinity (psu)Temperature at Profile 13 during Spring Tide Temperature at Profile 13 during Neap Tide 20 40 --C.4-'0.0)0 60-.C: 80 g--0100 120 140 160-75-03-Aug 07-.59 Ebb-03-Aug 14:08 SBF-03-Aug 16:05 Flood--03-Aug 17:37 Flood.90 80 85 90 Temperature (OF)Temperature (OF)Figure E-13: Salinity and temperature profiles at location 13 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 14 during Spring Tide Salinity at Profile 14 during Neap Tide A U ..20 40F~so-4) 800-4-'20 40~60.- 80 W) 100 120 140 160... ... ... .. .... .. .... ... .. 0 3 A u ....7 ....b 03-Aug 07:57 Ebb-03-Aug 14:10 SBF-03-Aug 16:08 Flood 03-Aug 17:34 Flood 120 140 160 2-- 13-Jul 10:06 SBF-13-Jul 12:00 Flood-13.Jul 13:51 Flood-- 13-Jul 17:00 SBE 4 6 8 Salinity (psu)10 12 6 8 Salinity (psu)10 12 Temperature at Profile 14 during Spring Tide Temperature at Profile 14 during Neap Tide 20 40 60-go-a) 100 120-, 140 160 75 13-Jul 10:06 SBF-13-Jul 12:00 Flood-13-Jul 13:51 Flood 13-Jul 17:00 SBE U 20 40 60 4-I a-80 100 120 140 160 75 03-Aug 07:57 Ebb-03-Aug 14:10 SBF-03-Aug 16:08 Flood 03-Aug 17:34 Flood 80 85 90 80 85 90 Temperature (OF)Temperature (OF)Figure E-14: Salinity and temperature profiles at location 14 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 15 during Spring Tide Salinity at Profile 15 during Neap Tide 2 4 8-8 W) 10 12 14 16 0 " 0o .... ........................................................... .0o ................i ......- ..............................0m 0 0i 0 Jul 13:54 Flood--- 13-Jul 17:03 SBE 2 4 6 8 10 1 Salinity (psu)20 40 0.a)60 80-03-Aug 07:54 Ebb-03-Aug 14:14 SBF-03-Aug 16:10 Flood 03-Aug 17:31 Flood 100-120 140 160-2 2 4 6 8 Salinity (psu)10 12 Temperature at Profile 15 during Spring Tide Temperature at Profile 15 during Neap Tide n ft 20 40 -.60.80 4) 100 0 P F............... ....-13-Jul 13:54 Flood....13-Jul 17:03 SBE 0.a)20 40 60 F 80 F 120" 140-160 75 100-120-140-160 -75.03-Aug 07:54 Ebb-03-Aug 14:14 SBF-03-Aug 16:10 Flood.........

.... 03-Aug 17:31 Flood 80 85 90 80 85 90 Temperature (OF)Temperature (OF)Figure E-15: Salinity and temperature profiles at location 15 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 21 during Spring Tide A Salinity at Profile 21 during Neap Tide 2 4 6 8'4-I a)0 10 0 -- .. .. ..0O ..................

... ..... ..... ....... .................

0 0 ................-............ .............................. .0O .... ... .......'0-13-Jul 11:36 Flood 0 Jul 13:26 Flood 0---- 13-Jul 16:36 SEE 2 4 6 8 10 12 Salinity (psu)20 12 14 16 40-~60." 80 a) 100 120 140 160 2.............................i ............: ...... ....... ..03-Aug 08:50 Ebb-03-Aug 13:31 SBF-03-Aug 15:32 Flood 03-Aug 18:03 Flood 4 6 8 Salinity (psu)10 12 Temperature at Profile 21 during Spring Tide Temperature at Profile 21 during Neap Tide LiP T T 20 20 40-.40 I 60 -,* 80-4100-a 120-140 -160 75 60-.- 80-0 100-120-140 160 75..... .......i ........ 03-Aug 08:50 Ebb-03-Aug 13:31 SBF-03-Aug 15:32 Flood--- ---- 03-Aug 18:03 Flood-13-Jul 11:36 Flood-13-Jul 13:26 Flood 13-Jul 16:36 SBE 80 85 90 80 85 90 Temperature (OF)Temperature (OF)Figure E-16: Salinity and temperature profiles at location 21 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 22 during Spring Tide Salinity at Profile 22 during Neap Tide Ar T 20 40F 60F.- 80k 4 100 0-13-Jul 11:38 Flood-13-Jul 13:30 Flood.13-Jul 16:38 SBE 2 4-I 0.'6 8 10 0-0-0 0 03-Aug 08:48 Ebb-03-Aug 13:34 SUF 0- Aug 15:35 Flood o 03-Aug 18:05 Flood 2 4 6 8 10 1 Salinity (psu)120 140F 160L 2 12 14 16 4 6 8 Salinity (psu)10 12 2 Temperature at Profile 22 during Spring Tide Temperature 0 20 at Profile 22 during Neap Tide P 20 40.40 [4-.0~0 0 60k 80W 60-.c 80 4) 100 a 100o 120 [140 160 -._75-13-Jul 11:38 Flood-13-Jul 13:30 Flood 13-Jul 16:38 SBE 120 140 160-75-03-Aug 08:48 Ebb-03-Aug 13:34 SBF-03-Aug 15:35 Flood--- 03-Aug 18:05 Flood 80 85 90 80 85 90 Temperature (OF)Temperature (OF)Figure E-17: Salinity and temperature profiles at location 22 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 23 during Spring Tide Salinity at Profile 23 during Neap Tide 2 4.- 8 Q) 10 12 14 16 U 0o .........i....... ..............

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...... ..... ..0-) 0 -.. ................................ ... 4 .. .. .... ....0O ....... ....... ,... ... .. .............0-i :i [ 13-Ju1 11:40 Flood 0 0 Jul 13:32 Flood 0 --13-Jul 16:40 SBE 2 4 6 8 10 1: Salinity (psu)2 4 6 C)8 10 0 -.T. .0o ... .......................i ............. .....o .........

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...... ......0--03-Aug 13:36 SFlo 0r 03-Aug 18:08 Flood 2 4 6 8 10 Salinity (psu)12 14 16 2 2 Temperature at Profile 23 during Spring Tide 20 40-4-'0.a), 0 60-80-* ............ ........ ...... .................... ...-13-Jul 11:40 Flood-13-Jul 13:32 Flood 13-Juli16:40 SBE Temperature 0 20.40[Q4-60F at Profile 23 during Neap Tide 80 F 100 -1W0 13 120-140 -160 75 120-140-160 75--- 03-Aug 08:46 Ebb-03-Aug 13:36 SBF-03-Aug 15:37 Flood-03-Aug 18:08 Flood 80 85 90 80 85 90 Temperature (OF)Temperature (OF)Figure E-18: Salinity and temperature profiles at location 23 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 24 during Spring Tide Salinity at Profile 24 during Neap Tide A 20 40 6O 00 100 2 4 I-Q-6 8 10 0 0 0 0 0- --03-Aug 08:44 Ebb 03-Aug 13:39 SBF 0 --03-Aug 15:39 Flood or 03-Aug 18:10 Flood 2 4 6 8 10 1 Salinity (psu)120h 140F 160 2-13-Jul 11:42 Flood-13-Jul 13:34 Flood-- 13-Jul 16:44 SBE 12 14 16 4 6 8 Salinity (psu)10 12 2 Temperature at Profile 24 during Spring Tide Temperature 0 20.40 at Profile 24 during Neap Tide 20 40 4-a 0~0)0 60-80.4~9 0~0)60F 80-03-Aug 08:44 Ebb-03-Aug 13:39 SBF-03-Aug 15:39 Flood 03-Aug 18:10 Flood 100-1W0 i 120[-140 F 160..75-13-Jul 11:42 Flood-13-Jul 13:34 Flood---13-Ju116:44 SBE 120-140-160.75 80 85 Temperature (OF)90 80 85 90 Temperature (OF)Figure E-19: Salinity and temperature profiles at location 24 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 25 during Spring Tide Salinity at Profile 25 during Neap Tide 2 4 6 8 a.a)0 0-0-0-0-0--1 3-Jul 11:44 Flood , Jul 13:36 Flood o 16:46 S.E 2 83- 10 12 1 Salinity (psu)2 4 a) 10 12 14 16 10'0 0-0-0-0-0 Aug 08:42 Ebb-03-Aug 13:42 9SF o Aug 15:41 Flood 0 03-Aug 18:12 Flood 2 4 6 8 10 1 Salinity (psu)12'14'16(2 Temperature at Profile 25 during Spring Tide Temperature at Profile 25 during Neap Tide U T r II, 20 40-4)0 606 80W-13-Jul 11:44 Flood-13-Jul 13:36 Flood 13-Jul 16:46 SUE 4~9 a.a), 20 40 60 80F 100o 100 m 120 [140 160 75 120 140 160 75.03-Aug 08:42 Ebb-03-Aug 13:42 SBF-03-Aug 15:41 Flood 03-Aug 18:12 Flood 80 85 90 Temperature (OF)80 85 90 Temperature (OF)Figure E-20: Salinity and temperature profiles at location 25 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 31 during Spring Tide a Salinity at Profile 31 during Neap Tide 0-a)2 4 6 8 10 12 14 16...... .= .i .............. ..................0 ... ... ........ .....................

0 -.......... .................................( .... ... .. .. ... .-u 09 2 SB i -- 13-Jul 11:14 Flood 10 JUl 13:04 Flood 0 i --"13-Jul 16:15 SBE 2 4 6 8 10 1;20 40~60 so-a) 100-0 120-140 160 2-- 03-Aug 09:09 Ebb-03-Aug 13:12 SBF-03-Aug 15:12 Flood... .....03-Aug 18: 29 Flood 2 Salinity (psu)4 6 8 10 12 Salinity (psu)Temperature at Profile 31 during Spring Tide Temperature at Profile 31 during Neap Tide A 20 40 60 4-a 0.a)0 0..ae 80 100 120-140-160-75 03-Aug 09:09 Ebb-03-Aug 13:12 SBF-03-Aug 15:12 Flood-- -- -.03-Aug 18:29 Flood 90 80 85 90 Temperature (OF)Temperature (OF)Figure E-21: Salinity and temperature profiles at location 31 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 32 during Spring Tide Salinity at Profile 32 during Neap Tide 20 40 a-03"60.- 80_4) 100-120 140 160 2 03-Aug 09:10 Ebb 03-Aug 13:14 SBF-03-Aug 15:14 Flood-03-Aug 18:31 Flood 6 8 Salinity (psu)4 6 8 Salinity (psu)10 12 Temperature at Profile 32 during Spring Tide Temperature at Profile 32 during Neap Tide 20 40 6O.- 80 IO0 a) 100 120 140 160 75.... ... ....... ...13-Jul 09:27 SBF-13-Jul 11:16 Flood-13-Jul 13:07 Flood 13-Jul 16:20 SBE 20 40 60 0.*0)0 b, J 80W 100-120-140-160-75--03-Aug 00:10 Ebb-03-Aug 13:14 SBF-03-Aug 15:14 Flood 03-Aug 18:31 Flood 80 85 90 80 85 90 Temperature (OF)Temperature (OF)Figure E-22: Salinity and temperature profiles at location 32 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 33 during Spring Tide Salinity at Profile 33 during Neap Tide A 20 40~60." 80 4) 100 0 120 140 160 2 2 4 a) 10 10 12 14 16 U 0.0-....0-)0 .... .... ... ....0 ---03-Aug 09:13 Ebb-03-Aug 13:16 SBF O --03-Aug 15:16 Flood 0- 03-Aug 18:34 Flood 2 4 6 8 10 12 Salinity (psu)-13-Jul 09:30 SBF-13-Jul 11:19 Flood-13-Jul 13:10 Flood 13.Jul 16:22 SSE 6 8 Salinity (psu)10 12 Temperature at Profile 33 during Spring Tide Temperature at Profile 33 during Neap Tide U.*20-40.GI: o-.c 80-4) 100-120-140 160-75 20 40 60 0~a)80 100 m 120--140-160 75-03-Aug 09:13 Ebb-03-Aug 13:16 SBF-03-Aug 15:16 Flood 03-Aug 18:34 Flood 80 85 Temperature (OF)90 80 85 90 Temperature (OF)Figure E-23: Salinity and temperature profiles at location 33 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 34 during Spring Tide Salinity at Profile 34 during Neap Tide 20 40 60 80 4) 100 120 140 160 20 40 60 4.J a)0 80k 03-Aug 09:15 Ebb ug 13:18 SBF-03-Aug 15:19 Flood 03-Aug 18:36 Flood 100-120-140 160-2 4 6 8 Salinity (psu)10 12 Temperature at Profile 34 during Spring Tide U, , , 20 (D 4-a)40 60 8o 100 120 140 160-13.Jul 09:33 SBF-13-Jul 11:22 Flood-13-Jul 13:13 Flood-13-Jul 16:25 SBE Temperature at Profile 34 during Neap 0 20-401'60 Tide 4-.a-a)80F 100F 120 140 160L 75--- 03-Aug 09:15 Ebb-03-Aug 13:18 SBF-03-Aug 15:19 Flood 03-Aug 18:36 Flood 75 80 85 90 80 85 90 Temperature (OF)Temperature (OF)Figure E-24: Salinity and temperature profiles at location 34 from the two intensive mobile surveys.

ASA 2010 Field Program and Modeling Analysis of the IPEC Discharge Salinity at Profile 35 during Spring Tide Salinity at Profile 35 during Neap Tide a Ur,, 20 40 60 4)'0 80F-... 11:5.. .o--13-Ju1 11:25 Flood.13-Jul 13:16 Flood.13-Jul16:27 SBE 4-9 0.20 40 60 8o 100 120 140 160 100F--03-Aug 09:17 Ebb-03-Aug 13:20 SBF 03Aug 15:20 Flood 03-Aug 18:41 Flood 2 4 6 8 10 1: Salinity (psu)120 140 160 4 6 8 Salinity (psu)10 1 2 2 Temperature at Profile 35 during Spring Tide Temperature at Profile 35 during Neap Tide U , 20 40 20 40 4-'0.a)0 60-80.p60-.. 80o.4-'0..Q 100-a-03-Aug 09:17 Ebb-03-Aug 13:20 SBF-03-Aug 15:20 Flood 03-Aug 18:41 Flood 100 -120-140 -160 L 75-13-Jul 11:25 Flood-13-Jul 13:16 Flood 13-Jul 16:27 SBE 120-140-160-75 80 85 90 80 85 90 Temperature (OF)Temperature (OF)Figure E-25: Salinity and temperature profiles at location 35 from the two intensive mobile surveys.

ENCLOSURE 3 TO NL-11-078 Part 1 of Response to the NYSDEC Staff Review of the 2010 Field Program and Modeling Analysis of the Cooling Water Discharge from the Indian Point Entergy Center (March 29, 2001)ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 and 3 DOCKET NOS. 50-247 and 50-286 Prepared for: Entergy Nuclear Indian Point 2, LLC and Entergy Nuclear Indian Point 3, LLC Buchanan, NY Part 1 of Response to the NYSDEC Staff Review of the 2010 Field Program and Modeling Analysis of the Cooling Water Discharge from the Indian Point Energy Center ASA Project 09-167 29 March 2011 Prepared by: Daniel Mendelsohn Craig Swanson Deborah Crowley Applied Science Associates, Inc.55 Village Square Drive South Kingstown, RI 02879 asa Introduction Applied Science Associates, Inc. (ASA) submitted a report on 31 January 2011 that documented the 2010 field program and modeling analysis of the cooling water discharge to the Hudson River from the Indian Point Energy Center (IPEC). The New York State Department of Environmental Conservation provided a series of comments (NYSDEC Comments) dated 10 March 2011 on that report. A technical meeting!discussions occurred last Thursday, 24 March, to clarify the comments.

The following reflect ASA's response to those NYSDEC Comments, with the NYSDEC Comment first repeated, followed by ASA's Response.

NYSDEC has provided nine (9) comments.

This response (Part1) addresses six (6) of the nine (9) comments including

1. 3, #4, #5, #6, #8, and #9. The remaining three (3) responses

(#1, #2, and #7)will follow shortly as Part 2.1 NYSDEC (Section 5) Comment #3 DEC staff recommend that Entergy should use transects noted in Figure 2-3 of the report for determining compliance with 6NYCCR Part 704.2(b)(5).

Any transect close to any one of the transects noted in Figure 5-1 should be dropped in consultation with the DEC staff. In addition actual ambient temperature data at these transects must be provided.ASA Response NYSDEC has requested that ASA evaluate the compliance to the thermal criteria along transects implied by the 2010 thermistor chain stations in the immediate area of the IPEC Plant. ASA has post processed the 2010 model results to develop an additional compliance analyses for the alternative transects implied by stations in Fig 2-3 of the report, as requested.

As detailed below, compliance is established for these alternative additional transects.

There are four implied, cross-river transects made up of three to five thermistor chains in the Indian Point area. They are defined as follows and presented in Figure 3-1:* NYSDEC Transect 1 -Thermistor Stations 13, 15 & 16* NYSDEC Transect 2 -Thermistor Stations 17, 18, 19 & 20 0 NYSDEC Transect 3 -Thermistor Stations 25, 26, 27, 28 & 29 NYSDEC Transect 4 -Thermistor Stations 34, 35, 36 & 37*42 ,IPEC O11 Figure 3-1 Locations of the four NYSDEC transects in the Indian Point area It should also be noted that the four new transects are nearly coincident with four of the transects presented in the January 2011 report. Starting to the south and moving north, new transects NYSDEC 2 T1, T2, T3 and T4 are similar in location and therefore will replace report transects S2, S1, C and Ni, respectively.

Using the difference between the model results from the 2010 actual (with power plant) case and the environmental background case, a delta temperature(dT) case was developed for each grid cell over the entire simulation period. The cross-sectional area coverage, in percentage, of the 4°F dT was then evaluated for each transect, over the July study period (7/8-7/31).

The time history of the 4°F dT cross sectional area coverage percent for all of the transects and the cross-river length coverage percent are plotted in Figure 3-2 and 3-3, respectively.

The maximum percentages experienced at each transect are presented in Table 3-1 below.Table 3-1 Maximum area and width coverage for the 4°F temperature rise Maximum Maximum Cross Cross Section River Transect Area (%) Width (%)NYSDEC T1 8.0 28.6 NYSDEC T2 10.5 24.9 NYSDEC T3 12.3 22.1 NYSDEC T4 3.4 15.8 The actual ambient temperatures predicted by the model for the designated transects are plotted in Figure 3-4 for the study time period. The ambient temperatures were developed from the environmental background case where there are no anthropogenic sources of heat. These are representative of the temperatures that are used to evaluate the temperature rise and compliance of the IPEC thermal effluent plume (the actual compliance evaluation used a point for point dT calculation for every cell of the model grid at every time step).3 2010 Vertical Cross-Sectional Area Coverage of the 4F dT at ThermistorTransects Near the IPEC Station NYSDEC T1 -NYSDEC T2 NYSDEC T3 -NYSDEC T4 --Regulatory Threshold 100 90 80 70 1~60 40 30 20 10 0 7/8 7/10 7/12 7/14 7/16 7/18 7/20 7/22 7/24 7/26 7/28 7/30 Figure 3-2 Cross-sectional area coverage of the 4°F dT at the four thermistor transects 2010 Surface Width Coverage of the 4F dT at ThermistorTransects Near the IPEC Station-NYSDECT1 -,NYSDECT2 NYSDEC T3 -NYSDEC T4 --Regulatory Threshold 100 90 80 70-60 S50 c 40 30 30 20 10 7/8 7/10 7/12 7/14 7/16 7/18 7/20 7/22 7/24 7/26 7/28 7/30 Figure 3-3 Cross-river width coverage of the 4°F dT at the four thermistor transects 4 NYSDEC TI -NYSDEC T2 NYSDEC T3 NYSDEC T4 --83F Criteria 85 84 83 --- ------------------------------------82 E 81 s0 79 78 7/8/10 7/10/10 7/12/10 7/14/10 7/16/10 7/18/10 7/20/10 7/22/10 7/24/10 7/26/10 7/28/10 7/30/10 Figure 3-4 Actual ambient temperatures predicted by the model for the four designated transects In sum and as detailed above, compliance is demonstrated at these additional alternative transects.

5 NYSDEC (Section 5) Comment #4 In Section 5.2.2 it indicates that Station 27 was used as a proxy for natural ambient (condition) in the region during the simulation.

DEC staff believes that Station 27 is too close to the IPEC discharge to use as a reference station for ambient. Staff requests that a station outside the influence of the IPEC plume be used as a reference station. If Entergy believes that Station 27 is not in any way impacted by the discharge, an explanation of the adequacy of the location as the reference point must be submitted for staff review.ASA Response In this response, ASA further explains the method used to determine the background ambient temperature at the Station 27 location.

This explanation details how the ambient temperatures referred to in the text are the model predicted, environmental background (ambient) temperatures, estimated for the river without any anthropogenic heat sources added. The use of the Station 27 location ambient was only to provide guidance as to which NYSDEC regulation (4°F vs. 1.5°F) was appropriate for use in determining water quality criteria compliance, it was not used for calculation of any temperature differentials above background.

For the 2010 study period, ASA ran two separate and distinct model simulations; one with the real 2010 conditions for tides, rivers, temperatures and plant loads (IPEC and others) and a second simulation with the exact same environmental conditions but without any of the plant loads, which provides the requisite assurance that background conditions are established and therefore constitutes the"environmental background" or "ambient" case. ASA used this environmental background simulation in several ways, one of which was to evaluate what the temperature in the area of the plant might be if there were no thermal effluent from IPEC; a true ambient. The temperature at the Station 27 location for the environmental background case was selected as representative of the ambient conditions in the river in the IPEC area. The temperature record at the Station 27 location for the ambient conditions clearly does not and cannot show any impacts from the plant effluent, and is presented in Figure 4-1 below.6

--83F Criterion Stn 27 Location 85 84 83 -- ..................--82' 81 4, 79 78 7/8 7/10 7/12 7/14 7/16 7/18 7/20 7/22 7/24 7/26 7/28 7/30 Figure 4-1 Environmental background (ambient) temperature predictions for the Station 27 location 7 NYSDEC (Section 5) Comment #5 In Section 5.3 (Page 110) it states that "in order to estimate the A4 0 F temperature rise the model results were based on no thermal loads from any power plants (ambient conditions) were subtracted from model results based on thermal loads from IPEC and other power plants." DEC staff recommends that all the modeling work and the projection scenarios should be conducted at the full thermal loading conditions, i.e. all power plants running at full capacity.ASA Response ASA ran the model as described to simulate the actual observed conditions in the Hudson River during the 2010 summer study period so that the model predictions could be directly compared to the observations and provide a verification of the model, which was calibrated to the 2009 observations.

The simulations implemented plant flows and temperatures as recorded in order to reflect actual conditions in the river.Reiterating what was explained in response to the previous comment, for the 2010 study period ASA ran two separate and distinct model simulations; one with the real 2010 conditions for tides, rivers, atmospheric, temperatures and plant load, and a second simulation with the exact same environmental conditions but without any of the plant loads, which constitutes the "environmental background" or"ambient" case. The environmental background was then used to create a temperature excess analysis by numerically subtracting the environmental background (ambient) temperatures from the simulation that included plant loads on a cell by cell, level by level basis for every time step of the model simulation.

The result is a delta temperature model "simulation" for the full study period, which literally has the ambient conditions removed from the actual conditions allowing analysis of the dynamic prediction of the thermal plume temperature rise to evaluate the 1.5°F and 4 0 F cross-sectional and surface width limits. Therefore, the model run with no thermal discharges from any plant is only one step in the larger process of evaluating the IPEC compliance with regulations, and does not represent the conclusion regarding compliance.

Furthermore, in that the 2010 simulation was a validation run, it does not make sense to implement conditions for any of the power plant effluents that did not occur, (e.g. full capacity, all the time), as the records clearly show that the other plants on the river were not running at full capacity.

The model predicted A4 0 F temperature rise was therefore based on realistic operational and environmental conditions, which in this case provided a wide range of those conditions during the summer of 2010.Additionally, prior analysis of the plant operating conditions provided to NYSDEC established that the thermal discharges of other Hudson River facilities do not influence or are not concomitant with the thermal discharge from Indian Point (Swanson et al., 2010).Swanson et al, 2010, "Response to the NYSDEC CWA § 401 Water Quality Certification Notice of Denial Related to Thermal Discharges from the Indian Point Energy Center", prepared for: Entergy Nuclear Indian Point 2, LLC and Entergy Nuclear Indian Point 3, LLC, Buchanan, 29 April 2010.8 NYSDEC (Section 6) Comment #6 In Section 6.3 (page 118) states that the model was run with no thermal discharges from any plant. DEC staff recommends that all the model runs for determining compliance with 6NYCCR Part 704.2(b)(5) should be made under "full thermal loading and ambient conditions" -(all plants on Hudson River, as applicable).

ASA Response ASA ran the 2010 model as described to simulate the actual observed conditions in the Hudson River during the summer study period so that the model predictions could be directly compared to the observations and provide a "verification" of the calibrated model and selected parameters from the 2009 study. The simulations implemented plant flows and temperatures in order to reflect actual conditions in the river.For the 2010 study period, ASA ran two separate and distinct model simulations; one with the real 2010 conditions for tides, rivers, temperatures and plant loads and a second simulation with the exact same environmental conditions but without any of the plant loads, which constituted the "environmental background" or "ambient" case. ASA used this environmental background simulation to determine a temperature excess by numerically subtracting the environmental background (ambient) temperatures from the simulation that included plant loads on a cell by cell, level by level basis for every time step of the model simulation.

The result is a delta temperature model "simulation" for the full study period, which literally has the ambient conditions removed from the actual conditions allowing review and analysis of a dynamic prediction of the thermal plume temperature rise which can be used to evaluate the 1.5F and 4'F cross-sectional and surface width limits.In that the 2010 simulation was a validation run, it does not make sense to implement conditions for any of the power plant effluents that did not occur, (e.g. full capacity, all the time), as the records clearly show that the other plants on the river were not running at full capacity.

The model-predicted A4 0 F temperature rise was therefore based on realistic operational and environmental conditions, which in this case provided a wide range of those conditions during the summer of 2010. The 2010 water temperatures are near the 2005 extreme environmental conditions which provided an additional test of the IPEC compliance.

In addition, at several times during the 2010 study period, all plants were operating at near capacity levels. Thus, the validation study did include all plants at near capacity and from the subsequent analyses, it is apparent that there are no criteria violations.

Further, ASA has determined from the observations and model results that the other Hudson River plants do not affect the IPEC plume. The thermal impact of these stations is not a material factor in establishing the potential thermal impacts of Indian Point. As such, running simulations with all plants at capacity is not material in assessing Indian Point's thermal discharge.

ASA has previously investigated the potential influence of other plants on the IPEC thermal plume and reported the results elsewhere, (Swanson et al, 2010).Additionally, prior analysis of the plant operating conditions provided to NYSDEC established that the thermal discharges of other Hudson River facilities do not influence or are not concomitant with the thermal discharge from Indian Point (Swanson et al., 2010).ASA has evaluated other plant data available for the past five years from the NYISO Gold Book.Reviewing the operational statistics for the five year record, it was found that the annual capacity factor for those plants averages 5%, 13% and 53% for Bowline, Roseton and Danskammer, respectively.

In 9 addition, during the 2010 study period, the capacity factor averages were similarly 12%, 47% and 59%for Bowline, Roseton and Danskammer, respectively (Figure 6-1). This indicates that even though these plants were in operation at the same time, they were all running well below capacity since they are peaking plants and not baseload plants. In addition, it is unlikely that these plants would run at or near capacity in the future due to other limitations, such as air quality impacts..... Danskammer (MW -Avg)-Danskammer Nameplate Bowline (MW -Avl) # * .Roseton (MW -Avg)Bowline Nameplate

-Roseton Nameplate 1400 3 lOW at a a.~ -at Rh at~4W 2W 7I/ 7/12 7/16 7/20 7/24 7/Z 9/1 Figure 6-1 Average daily power production for the Roseton, Danskammer and Bowline power plants during the 2010 study period.Swanson et al, 2010, "Response to the NYSDEC CWA § 401 Water Quality Certification Notice of Denial Related to Thermal Discharges from the Indian Point Energy Center", prepared for: Entergy Nuclear Indian Point 2, LLC and Entergy Nuclear Indian Point 3, LLC, Buchanan, 29 April 2010.10 NYSDEC Comment #8 In addition, please indicate if the nearfield model was used to establish thermal field and later used as input to the farfield model thermal. The response should also indicate how the model handled the momentum-based intrusion into ambient waters and later into far field areas.ASA Response The ASA near field approach in the far field'model was to distribute the inflow and temperatures over the several model cells adjacent to outfall canal location in a manner that captures the realistic thermal dispersion.

The momentum plume was accounted for through the initial distribution of the heat and flow for purposes of the far field model. The initial area was estimated from preliminary CORMIX simulations, analytical calculations and assessment of the temperature observations from the thermistor array.A detailed section of the model grid in the area of the plant is presented in Figure 8-1. The fixed array thermistor stations are plotted as red dots and numbered on the map for reference.

An example of the near field plume distribution can be found in the observations for stations 25, 26 and 27, forming a transect extending away from the discharge canal. During the 2010 field program, Station 25, 60m offshore from the discharge canal reaches 95'F with an average of 87 0 F, station 26 at approximately 150m offshore barely exceeds 91 0 F, averaging 85°F, and by station 27, just greater 250m offshore the temperature just hits 88 0 F, averaging 84°F. With the distribution determined from the analyses, ASA was able to parameterize and capture the near field plume distribution sufficiently for implementation in the far field model as can be seen in Table 8-1, comparing the near field model predictions to observations over the 2010 study period. The table shows the model results slightly exceeded the observed temperatures in the very near field (Station 25) but were in very good agreement by Station 27, thereby demonstrating an appropriate initial distribution of plan heat and flow.Table 8-1 Comparison of near field model predicted and observed temperatures at selected stations.Model Observations Mean Max (F) (F) Mean (F) Max (F)Station 25 89 96 87 95 Station 26 86 94 85 91 Station 27 84 88 84 88 11 NYSDEC Comment #9 DEC Staff would like to know the fresh water inflow incorporated into the model. Staff would like to see model projections at 7Q10 flow of 3,200 cfs at Bear Mountain Bridge (over the Hudson River). The 7Q10 at Troy Dam is expected to be less than the noted flow.ASA Response In all model applications (2009 -Calibration, 2005 -Extreme Scenario, 2010 -Validation), freshwater inputs were incorporated into the model at the northern boundary, i.e., the Troy dam, which is north of the Bear Mountain Bridge. These inputs were based on observed conditions at this upstream location.The model forcing of freshwater inputs is conservative (understated) in all cases in that it does not include any watershed inputs south of this northern boundary, and therefore does not account for the additional influx of fresh water at the Bear Mountain Bridge or the intervening tributaries south of the Troy dam to the Bear Mountain Bridge. Thus, the modeling understated fresh water flow.Furthermore, the Extreme Scenario (1 August -15 August 2005) had daily average upstream river inputs that ranged from 2,475 -3974 cfs with an average of 3,167 cfs which is lower and therefore more conservative than the NYSDEC referenced 7Q10 flow of 3,200 cfs at Bear Mountain Bridge. The results of the Extreme Scenario, as well as the Calibration and Validation scenarios, confirm compliance to the NYSDEC WQS criteria.Finally, it should also be noted that, as long as the freshwater flow in the River is relatively low, the actual value is not particularly significant, since flow, transport and dispersion in the Hudson River is controlled primarily by the tides. A comparison between freshwater flow and tidal flow can be made to show the relative importance of each. The tidal flow is calculated from the tidal prism, which is the volume of water that flows upstream on a flood tide and flows downstream on an ebb tide. Assuming a mean tide range of 4 ft and a River surface area of 1.827 billion ft 2 gives a volume of 7.306 billion ft 3.Multiplying the volume by one half the typical tidal cycle period (12.42 hrs) results in an average tidal flow rate of approximately 327,000 cfs, this volume is over 100 times larger than the 1-15 August 2005 daily averaged flow of 3,167 cfs. Due to the complex nature of freshwater induced estuarine circulation the ratio of freshwater induced flow near the plant at any given moment may be less than the 100:1 ratio of tidal to freshwater flows, however the tidal flow is still dominant during low freshwater periods and small variations in low flows have negligible effect on the temperatures near IPEC.12 ENCLOSURE 4 TO NL-1 1-078 PART 2 OF RESPONSE TO THE NYSDEC STAFF REVIEW OF THE 2010 FIELD PROGRAM AND MODELING ANALYSIS OF THE COOLING WATER DISCHARGE FROM THE INDIAN POINT ENTERGY CENTER (MARCH 31, 2011)ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 and 3 DOCKET NOS. 50-247 and 50-286 Prepared for: Entergy Nuclear Indian Point 2, LLC and Entergy Nuclear Indian Point 3, LLC Buchanan, NY Part 2 of Response to the NYSDEC Staff Review of the 2010 Field Program and Modeling Analysis of the Cooling Water Discharge from the Indian Point Energy Center ASA Project 09-167 31 March 2011 Prepared by: Craig Swanson Deborah Crowley Yong Kim Nicholas Cohn Daniel Mendelsohn Applied Science Associates, Inc.55 Village Square Drive South Kingstown, RI 02879 asa Introduction Applied Science Associates, Inc. (ASA) submitted a report on 31 January 2011 that documented the 2010 field program and modeling analysis of the cooling water discharge to the Hudson River from the Indian Point Energy Center (IPEC). The New York State Department of Environmental Conservation provided a series of comments (NYSDEC Comments) dated 10 March 2011 on that report. A technical meeting /discussions occurred last Thursday, 24 March, to clarify the comments.

The following reflect ASA's response to those NYSDEC Comments, with the NYSDEC Comment first repeated, followed by ASA's Response.

NYSDEC has provided nine (9) comments.

An earlier response (Part1) submitted on 29 March 2011 addressed six (6) of the nine (9) comments including

1. 3, #4, #5, #6, #8, and #9. This response (Part 2) addresses the remaining three (3) responses

(#1, #2, and #7).1 NYSDEC (Section 3) Comment #1 Section 3.2.2 (Page 45) Entergy Indian Point needs to provide temperature profiles and temperature distribution (plan view) at "slack before ebb", "slack before flood" and ebb tidal conditions at the transects indicated in Figure 2-3. The information should also include vertical temperature distribution for the noted transects similar to Figure 3-27.ASA Response NYSDEC requested a visual representation of the temperature structure in the river during slack before ebb, slack before ebb, and ebb tidal conditions using the data collected as part of the 2010 field program. A series of plan view and vertical cross section temperature plots were created from the fixed station thermistor data for the requested tidal phases occurring consecutively during a single tidal cycle (11 July and 12 July). A series of transects were chosen for the vertical cross sections based on suggestions by NYSDEC, as shown in Figure 1-1.(F IPEC Oilo 1 Figure 1-1 Locations of the four NYSDEC transects in the Indian Point area In order to graphically display the data, a numerical interpolation scheme must be employed.

A numerical contouring method was applied by using a Matlab software routine based on the combination of three interpolation functions (nearest neighbor interpolation, triangle linear interpolation and bilinear (tensor product linear) interpolation) via laplacian regularization to provide a smooth contouring of these results (for details see http://www.mathworks.com/matlabcentral/fx-files/8998/2/content/gridfitdir/demo/html/gridfit-dem o.html). It should be noted that, although a sophisticated approach was used, the limitations of the contouring process using irregularly spaced observations (due to the requirement that no thermistor stations be located in the shipping channel) can sometimes result in inaccurate interpolations.

2 For the vertical cross section profiles, the closest bathymetry points to each transect, as acquired from a 30m resolution bathymetric grid obtained from the NYS GIS Clearinghouse, are displayed to add context of the temperature variability within the river. Note that due to variations in bathymetry and the thermistor station mooring line lengths as recorded from the field survey, the location of all thermistor strings may not always be consistently displayed (normally shown as open circles in the figures), although the data from these thermistors is included in the numerical interpolation scheme.Only the measured temperatures from the deployed thermistors are shown in the figures. To see the 4°F temperature rise contours due to plant discharge refer to the graphics shown in Comment Response#7.The first set of contour plots (Figures 1-2 to 1-6) display the river temperature structure during maximum ebb tide on 11 July 2010 at 1800. The first figure in all sets is the surface temperature plan view contours followed by the vertical section contours Ti, T2, T3 and T4, which are respectively located from downstream to upstream of IPEC. During this period, the warmest temperatures occur directly near the plant, with the migration of the plume to the south. As the ebbing currents move the warmer plume downstream, cooler water migrates from the north to the area around Indian Point.The vertical profiles for the same period show that the warmer area is confined to the near surface and close to the eastern (right side of figure) shore. Transects Ti (Figure 1-3) and T2 (Figure 1-4) observe some increase in temperature from the thermal plume, although the increases are relatively small. The T3 (Figure 1-5) and T4 (Figure 1-6) transects observe no discernable impact from the plume during ebb tide, as they are located upstream of the IPEC discharge.

3 Figure 1-2. Plan view of surface temperatures near IPEC on 11 July 2010 at 1800 during maximum ebb.Color scale (in degrees F) shows the interpolated horizontal temperature distribution.

Figure 1-3. Vertical section of temperatures at T1 transect on 11 July 2010 at 1800 during maximum ebb.Color scale (in degrees F) shows the interpolated vertical temperature distribution.

4 Figure 1-4. Vertical section of temperatures at T2 transect on 11 July 2010 at 1800 during maximum ebb.Color scale (in degrees F) shows the interpolated vertical temperature distribution.

Figure 1-5. Vertical section of temperatures at T3 transect on 11 July 2010 at 1800 during maximum ebb.Color scale (in degrees F) shows the interpolated vertical temperature distribution.

5 Figure 1-6. Vertical section of temperatures at T4 transect on 11 July 2010 at 1800 during maximum ebb.Color scale (in degrees F) shows the interpolated vertical temperature distribution.

The second set of contour plots (Figures 1-7 to 1-11) display the river temperature structure during the slack before flood on 11 July 2010 at 2000, occurring directly after the period as shown in the previous set of figures (maximum ebb on 11 July 2010 at 1800). Because this time occurs directly after ebb, when waters flow downstream, the temperatures are still slightly warmer downstream of the plant rather than upstream.The vertical profiles from the same period indicate that the plume from the plant is confined to the near surface and close to the eastern shore (right side of figure). T1 (Figure 1-8) show slight warming in the surface layer, particularly in the western portion of the river, while T2 (Figure 1-9) shows slight warming in the surface layer mostly on the eastern side of the river. As expected, the transect closest to the plant, T3 (Figure 1-10), shows the largest thermal increase from the plant during this slack before flood tide. During this tidal phase, flow has not progressed to the upstream transect and there is no discernible evidence of the plume at T4 (Figure 1-11) anywhere in the water column.6 Figure 1-7. Plan view of surface temperatures near IPEC on 11 July 2010 at 2000 during slack before flood. Color scale (in degrees F) shows the interpolated horizontal temperature distribution.

Figure 1-8. Vertical section ot temperatures at T1 transect on 11 July 2010 at 2000 during slack betore flood. Color scale (in degrees F) shows the interpolated vertical temperature distribution.

7 Figure 1-9. Vertical section of temperatures at T2 transect on 11 July 2010 at 2000 during slack before flood. Color scale (in degrees F) shows the interpolated vertical temperature distribution.

Figure 1-10. Vertical section of temperatures at T3 transect on 11 July 2010 at 2000 during slack before flood. Color scale (in degrees F) shows the interpolated vertical temperature distribution.

8 Figure 1-11. Vertical section of temperatures at T4 transect on 11 July 2010 at 2000 during slack before flood. Color scale (in degrees F) shows the interpolated vertical temperature distribution.

The final set of contour plots (Figures 1-12 to 1-16) display the temperature structure in the river during the slack before ebb tide stage on 12 July 2010 at 0200, occurring six hours after the period as shown in the previous five figures (slack before flood on 11 July 2010 at 2000). There is a preference for heating downstream of the plant over upstream, as shown by the elevated temperature tail migrating downstream along the eastern shoreline.

The plume does not appear significantly upstream during this tidal current stage because the maximum upstream extent actually occurs approximately one hour earlier.The vertical profiles taken at the same time show that the warmer waters during this time period are also confined to the near surface and remain close to the eastern shore (right side of figure). T1 (Figure 1-13) is not heated substantially during this period. However, at this time the depth of the 81 °F contour is the deepest of any of the other two tidal stages. This trend is similarly observed at the other three transects.

At T2 (Figure 1-14), T3 (Figure 1-15), and T4 (Figure 1-16) there are apparent temperature inversions, whereby waters on the surface are slightly cooler than the waters just below them, and hypothesized to be the effects of radiative heat loss at nighttime.

However, the plume only directly affects the T2 transect, just south of the IPEC discharge.

9 Figure 1-12. Plan view of surface temperatures near IPEC on 12 July 2010 at 0200 during slack before ebb. Color scale (in degrees F) shows the interpolated horizontal temperature distribution.

t-igure 1.-1i. vertical section ot temperatures at i 1 transect on 11 July Zulu at uYL0U during slack betore ebb. Color scale (in degrees F) shows the interpolated vertical temperature distribution.

10 Figure 1-14. Vertical section of temperatures at T2 transect on 12 July 2010 at 0200 during slack before ebb. Color scale (in degrees F) shows the interpolated vertical temperature distribution.

Figure 1-15. Vertical section of temperatures at T3 transect on 12 July 2010 at 0200 during slack before ebb. Color scale (in degrees F) shows the interpolated vertical temperature distribution.

11 Figure 1-16. Vertical section of temperatures at T4 transect on 12 July 2010 at 0200 during slack before ebb. Color scale (in degrees F) shows the interpolated vertical temperature distribution.

12 NYSDEC (Section 4) Comment #2 Entergy needs to calibrate the model to more accurately match observed data (modeling protocol/best practice norms/limit, to bring the calculated temperature values to within one-half degree (0.5 0 F). The variation in criteria temperature is in the range of 1.5-4 0 F for various sections of 6NYCCR Part 704.2(b)(5).

Plots for stations:

17 thru 33 must be updated and submitted with revised sections of the report.ASA Response The first portion of the response deals with the correlation between observations and model predictions.

During our meeting with NYSDEC on 24 March 2011 it was agreed that a comparison of the difference between model predictions and observations was a good and sufficient statistical measure to establish model validation.

This measure can be expressed as the difference between the average of model predictions and the average of observations, which we calculated for each station and then took the average of all stations.

Using all 66 surface and 66 bottom thermistors from the 3-week validation period from the 2010 field program and modeling analysis we get values of 1.44°F (0.80°C) at the surface and 0.84°F (0.46°C) at the bottom with an average of 1.14°F (0.63°C).ASA also has reviewed similar studies under NYSDEC jurisdiction to understand the measures of acceptable approaches/performance.

We specifically examined other recent studies available for New York triaxial studies where both a hydrothermal model and a field observation program were utilized to compare their error estimates to the 0.5°F (0.28°C) level suggested by NYSDEC: " HydroQual, 2005. Near-Field and Far-Field Modeling Studies for the R. E. Ginna Nuclear Power Plant. Prepared for Constellation Energy, Ontario, NY. Only a qualitative model / data comparison was made by plotting time series for a 4-day segment of an 11-day field program utilizing four locations with thermistors at surface and bottom. Based on an estimate from the time series, the average of the absolute mean errors for all the stations is approximately 1.8°F (1°C). No quantitative statistics were reported.

No model validation was performed.

• HydroQual, 2009. Near-Field and Far-Field Modeling Studies for the Nine Mile Point Unit 1 and 2. Prepared for Constellation Energy, Ontario, NY. A quantitative model / data calibration was made for a 3-day segment of an 11-day field program utilizing four locations with thermistors at surface and bottom. The average of the station model / data bias (defined as the difference of the average observed temperature and the average model computed temperature) estimates for the calibration was 0.66°F (0.37°C) at the surface and 0.387F (0.21°C) at the bottom. There was no validation of the model." Lowe, S.A., F. Schuepfer, and D.J. Dunning, 2009. Case Study: Three dimensional Hydrodynamic model of a power plant discharge.

ASCE Journal of Hydraulic Engineering, Vol. 135, No. 4, April 2009. A quantitative model / data calibration and validation was performed for the Poletti thermal discharge using a data set of eight surveys over two days with data collected at four depths at three stations.

The average of the station "mean absolute error" estimates between model and data for calibration was 0.23°F (0.13°C).

The average of the station "mean absolute error" estimates between model and data for validation was 1.67°F (0.93°C).None of these studies showed performance of better than (less than) 0.5°F (0.28°C).

Further, the calibration performance for Indian Point exceeded the validation performance as shown by the Lowe 13 study of the Poletti thermal discharge.

Indeed, the Indian Point study was significantly better (less) at 1.14-F (0.63°C) than the Lowe study at 1.67°F (0.93°C).During the March 24 meeting, model accuracy was also discussed relative to the compliance criteria.The model accuracy in terms of predicting absolute temperatures was proven reasonable specifically with respect to the predicted area above 90°F, of which there are multiple observation stations close to the plant which had good model agreement.

With respect to determining temperature rise (delta T), it should be noted that since the environmental background results are subtracted out from the actual (with plants) case, the margin of error is reduced for these delta T predictions.

The second portion of the response deals with the presentation of additional time series plots of observations and model predictions.

Model to observation graphical comparisons for stations 17 through 33 (except stations 27 and 29 previously provided in the report) follow below in Figure 2-1 through 2 -15 as requested by NYSDEC. Note that, as previously described in Comment Response #8, some of the near field thermistor locations are within the area defining the initial plume distribution (Stations 24, 25, 26 and 30). Therefore, some larger variances in plume signal compared to observed temperatures within the initial plume zone were not considered significant as the stations immediately outside the initial distribution captured the signal well, as represented by Stations 23, 27 and 31. Some of the other differences may be due to the modeled location of the plume being shifted slightly horizontally due to modeled current shear from the physical thermistor location.

A choice of an adjacent model grid cell may more closely reflect the observed temperature.

For example, Figure 2-16 shows a plot of observed and model predicted at station 33 as well as the model predicted temperatures in the grid cell next to the station 33 location, which shows a better match to observations.

In any event the temperature offset seen between model and data at some stations does not affect the determination of modeled temperature rise since the offset is essentially eliminated when the ambient model run (no plant on) is subtracted from the "with plant on" model run to determine the temperature rise.14 Station17 Top C.E 07/10 07/12 07/14 07/16 07/18 07/20 07/22 07124 07/26 07/28 07/30 Station17 Bottom U-z90 85 0.E 80 I-J/ Model 07/08 07/10 07/12 07/14 07/16 07/18 07/20 07/22 07/24 07/26 07/28 07/30 Figure 2-1 Time series of model vs. observed temperatures at station 17 during 2010 validation period Station18 Top 90' 85 0.E 80 4-____Observed

____Model 07/08 07/10 07/12 07/14 07/16 07/18 07/20 07/22 07/24 07/26 07/28 07/30 Station18 Bottom 95 7 --7 oOiobserved 85 75 -- 1 A -07108 07/10 07/12 07/14 07/16 07/18 07/20 07122 07124 07/26 07/28 07/30 Figure 2-2 Time series of model vs. observed temperatures at station 18 during 2010 validation period 15 Station19 Top l -.. .. .-- O s r e S85-0.0-I7 07108 07110 07112 07/14 07/16 07/18 07/20 07/22 07/24 07/26 07/28 07/30 Station19 Bottom 95 80 I-75-07108 07/10 071/12 07/14 07116 071/18 07/20 07122 07;24 07/26 07/28 07/30 Figure 2-3 Time series of model vs. observed temperatures at station 19 during 2010 validation period Station20 Top 95-go.85-E 80 75 07/08 07110 07112 07/14 07116 07/18 07/20 07/22 07/24 07126 07128 07/30 Station20 Bottom 95 1 9075 07/08 07110 07/12 07/14 07/16 07/18 07/20 07/22 07/24 07/26 07/28 07/30 Figure 2-4 Time series of model vs. observed temperatures at station 20 during 2010 validation period 16 Station2l Top 95 o 90 a, 85 E.E80!I-07/10 07/12 07/14 07/16 07/18 07/20 07/22 07/24 07/26 07/28 07/30 Station2l Bottom 90 85 E0 I-____ Observed___Model.07/08 07/10 07/12 07/14 07/16 07/18 07/20 07/22 07/24 07/26 07/28 07/30 Figure 2-5 Time series of model vs. observed temperatures at station 21 during 2010 validation period Station22 Top c u-0 E.E I--Station22 Bottom 90 85 E 80 I-____ Observed Model 7 --1 -- -- -- --l- ._1 I -07/08 07/10 07/12 07/14 07/16 07/18 07/20 07/22 071/24 07/26 07/28 07/130 Figure 2-6 Time series of model vs. observed temperatures at station 22 during 2010 validation period 17 Station23 Top L-E I-07/10 07112 07/14 07/16 07/18 07/20 07/22 07/24 07126 07/28 07130 Station23 Bottom~90~85 E s0 0)____ Observed_____ Model i07108 07/10 07/12 07114 07/16 07/18 07/20 07/22 07124 07/26 07/28 07130 Figure 2-7 Time series of model vs. observed temperatures at station 23 during 2010 validation period Station24 Top 0 C.E I-Station24 Bottom.90 85 0.E 80 I--Observed-- Model i -07/08 07/10 07/12 07/14 07/16 07/18 07/20 07122 07/24 07/26 07/28 07/30 Figure 2-8 Time series of model vs. observed temperatures at station 24 during 2010 validation period 18 Station25 Top 95 1-1 1 1 1. 1., 1., E eo0 4)75 07/08 07110 07112 07/14 07/16 07/18 07/20 07122 07124 07/26 07128 07/30 Station25 Bottom 95 ---T -T .m sdbservedtn vad Uttin2-TModel go--75-07/08 07110 07/12 07/14 07/16 07/18 07/20 07/22 07/24 07/26 07/28 07/30 Figure 2-9 Time series of model vs. observed temperatures at station 25 during 2010 validation period Station26 Top 95 g-o*~85 CL E Bo Station26 Bottom 95-90'85 E 8o 07/08 07110 07/12 07114 07/16 07/18 07/20 07/22 07/24 07/26 07/28 07130 Figure 2-10 Time series of model vs. observed temperatures at station 26 during 2010 validation period 19 Station28 Top 90 M-85 E 80 07/08 07/10 07/12 07/14 07/16 07/18 07/20 07/22 07/24 07/26 07/28 07/30 Station28 Bottom 95 Figre2-1 Tme eres f ode v. osevedtepertues t taton28 urng- 01 valirv dainpro ca 90 ..... .E80 7:i T 07/08 07/10 07/12 07/14 07/16 07/18 07/20 07/22 07/24 07/26 07/28 07130 Figure 2-11 Time series of model vs. observed temperatures at station 28 during 2010 validation period Station30 Top 95 A -- Observed I1. Model 90 85 1 E 8o0 4,)707/08 07/10 07112 07/14 07/16 07118 07/20 07/22 07/24 07/26 07/28 07/30 Station30 Bottom j -Observed 9 0 , E 8: 75 07/08 07110 07/12 07114 07/16 07/18 07/20 07/22 D7/24 07/26 07/28 07/30 Figure 2-12 Time series of model vs. observed temperatures at station 30 during 2010 validation period 20 Station3l Top C CZ-90 0.*~85 E 80 I-07/10 07/12 07/14 07116 07/18 07/20 07/22 07/24 07/26 07/28 07/30 Station3l Bottom Observed U,. Model 85-E 8o-07/08 07/10 07/12 07/14 07/16 07/18 07/20 07/22 07/24 07/26 07/28 07/30 Figure 2-13 Time series of model vs. observed temperatures at station 31 during 2010 validation period Station32 Top 95 4z-9085 0.E 8o I-75L 1 1 1 07/08 07/10 07/12 07t14 07/16 07/18 07/20 07/22 07/24 07/26 07/28 07/30 Station32 Bottom 95 0 0.E I--07/10 07/12 07114 07/16 07118 07/20 07/22 07/24 07/26 07/28 07/30 Figure 2-14 Time series of model vs. observed temperatures at station 32 during 2010 validation period 21 Station33 Top Si 0 E 80 I-____ Observed_ _ _ M o d e l 07 08 07/10 07112 07/14 07/16 07/18 07/20 07/22 07/24 07/26 07/28 07/30 Station33 Bottom CL Ei 0.fl I I Observed 07/08 07/10 07/12 07114 07/15 07/18 07/20 07/22 07/24 07/26 07/28 07/30 Figure 2-15 Time series of model vs. observed temperatures at station 33 during 2010 validation period Station33 Top°z- 90 ,-g0 85 C-E.E 80 Si I--Observed Model Model Neighboring Cell 07'08 07/10 07/12 07/14 07/16 07/18 07/20 07/22 07/24 07/26 07/28 07/30 Station33 BottomC°z- 90 85 IV.Si 0.E 80 I-Observed Model Model Neighboring Cell 07/08 07/10 07/12 07/14 07/16 07/18 07/20 07/22 07/24 07/26 07/28 07/30 Figure 2-16 Time series of model vs. observed temperatures at station 33 during 2010 validation period that includes the model output at the a grid cell next to station 33 22 NYSDEC (Additional Comments)

Comment #7 DEC staff request the actual aerial delineation of IPEC thermal plume during the field surveys and comparison with the model projected spatial extents of the thermal plume. An explanation should be provided relating to the model reproduction of the dimensional extents of the thermal plume.ASA Response The extent of the surface thermal plume is relative to the temperature increase by which it is defined, which in this case is a 4 0 F increment over ambient. The 4 0 F plume changes in size and shape depending on the stages of the tide. The 4 0 F plume was determined for seven different tidal current stages (discrete times) over a tidal cycle to illustrate the variable spatial extent of the 4°F plume. This variable spatial extent is presented for both model predictions and observations over the same tidal cycle using the process described below.Determination of the model-predicted 4 0 F plume is based on subtracting the results from an environmental background model run (real tides and other environmental conditions but no plant loads)from the actual model run (real tides and environmental conditions and with plant loads) at every grid cell in the model domain. This differencing results in a delta T representing temperatures in excess of ambient or environmental background.

The extent of the model-predicted 4°F plume for seven representative stages of the tidal currents is shown in Figure 7-1.Determination of the 4'F plume from field observations in areas affected by the plant discharge requires development of an ambient condition (free from plant loads). Since there is only a discrete set of measurements at observation stations, numerical contouring methods (i.e., interpolation and extrapolation) are necessary to resolve the temperature distribution between observation stations.

In order to estimate the spatial extent of a 4°F plume based on measurements at the seven representative stages of the tide (similar to the analysis performed on model output discussed above) three steps were followed.First, the surface modeled ambient temperature at each thermistor location at the appropriated time of tidal current stage was subtracted from the value observed at the same location and time. The thermistors where this subtraction was performed included stations 13, 15, 16, 17, 18, 19, 20, 25, 26, 27, 28, 29, 35, 34, 35, 36 and 37.Second, a numerical contouring method for filling data gaps among stations was used to generate the spatial distribution of temperature rise over the ambient temperature.

A numerical contouring method that is widely used in topographic mapping, which accurately represents the geospatial relationships among irregularly spaced observation locations, was applied by using a Matlab software routine based on the combination of three interpolation functions (nearest neighbor interpolation, triangle linear interpolation and bilinear (tensor product linear) interpolation) via laplacian regularization (for details see http://www.mathworks.com/matlabcentral/fx -files/8998/2/content/gridfitdir/demo/html/gridfitdem o.html). It should be noted that although a sophisticated approach was used, the limitations of the contouring process using irregularly spaced observations (due to the requirement that no thermistor stations be located in the shipping channel) can sometimes result in inaccurate interpolations, for example extending the thermal plume past its actual dimensions.

23 Finally, once the spatial data gaps were filled in, the extent of the 4°F plume was drawn as a temperature rise of 4°F higher than the time varying modeled ambient temperature, as was done for the model predicted temperature rise. Figure 7-2 illustrates the resulting 4 0 F plume extent defined by the observations while also showing the locations of the thermistor stations used in the analysis.As can be seen by comparing Figure 7-1 and 7-2 there is generally good agreement between model predictions and observations in the temporal variability of spatial extent of the 4 0 F surface plume.However, there are some differences in the results stemming from some variances in model predictions compared to observations or from limitations of contouring based on irregularly spaced observations.

For example, the model predictions show a maximum ebb extent further downstream than the observations.

This is likely caused by an overprediction by the model at certain locations downstream of the observed maximum ebb plume (Figure 7-1).24 N Figure 7-1 Extent of the 4*F plume over a tidal cycle using model predictions 25 IPEC 4+Figure 7-2 Extent of the 4 0 F plume over a tidal cycle using contoured observed temperatures with modeled ambient subtracted 26 ENCLOSURE 5 TO NL-1 1-078 ALTERNATIVE MIXING ZONE EXPLANATION (MAY 3, 2011)ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 and 3 DOCKET NOS. 50-247 and 50-286 Alternative Mixing Zone Explanation

-3 May 2011 The material presented below supports the alternative mixing zone for Indian Point delineated in acreage, consistent with what we understand is NYSDEC Staff's ongoing efforts on a state-wide basis, as set forth in the May 2, 2011 correspondence from Entergy to NYSDEC Staff.Surface Area Extent of Thermal Plume The extreme environmental conditions determined from an analysis of historical conditions over the 10-year period from 2000 to 2009 and reported in Swanson et al. (2010) identified the extreme period (the Extreme Scenario).

The calibrated hydrothermal model was run for this Extreme Scenario, and the model results post-processed to determine the maximum surface area coverage predicted during that period. Figure 1 shows the relationship of maximum surface area to surface temperature.

The 90°F maximum surface area was found to be 35 ac, as reported in Swanson et al. (2010). An 89°F maximum surface area, representing a IF margin that appropriately accounts for the predictive tolerance of the hydrothermal model and the measurement capabilities of the thermal monitoring equipment, results in a 75 ac surface area.Maximum Surface Area Coverage vs Temperature 140 120~1 S80 6-0 U w 40 20 '-----------

_ _ __--_ ____ ______T __20 88.0 89.0 90.0 91.0 92.0 Temperature (F)Figure 1. Maximum surface area coverage as defined by surface temperature.

Linear Extent of Thermal Plume Potential upstream and downstream limits for surface areas enclosed by the 89°F isotherms under the Extreme Scenario, based on the same analysis as described above using the Extreme Scenario model results documented in Swanson et al. (2010), are identified below. Specifically, Figures 2a and 2b show 1 plan views of these surface areas (in green) for downstream and upstream Extreme Scenario conditions, respectively.

Figure 2. Maximum extent of thermal plume in downstream (a) and upstream (b) directions based on model predictions during the Extreme Scenario (1-15 August 2005).The maximum extent defined by the 89F isotherm is summarized in Table 1.Table 1. Maximum extent of thermal plume in downstream and upstream directions.

Maximum Extent Distance (ft) Distance (mi)Downstream 8,900 1.69 Upstream 3,700 0.71 Importantly, the typical downstream and upstream extents of the 89°F isotherms during the Extreme Scenario are significantly smaller than the maximum values presented in Figure 2 and Table 1. Figures 3a and 3b shows plan views of these surface areas (again, in green) with extents for downstream and upstream conditions, respectively.

These typical downstream and upstream extents are summarized in Table 2.2 Figure 3. Typical extent of thermal plume in downstream (a) and upstream (b) directions based on model predictions during the Extreme Scenario (1-15 August 2005).Table 2. Typical extent of thermal plume in downstream and upstream directions.

Typical Extent Distance (ft) Distance (mi)Downstream 3,000 0.57 Upstream 2,800 0.53 3 ENCLOSURE 6 TO NL-1 1-078 NYSDEC LETTER (MAY 16, 2011)ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 and 3 DOCKET NOS. 50-247 and 50-286 New York State Department of Environmental Conservation Office of General Counsel, 1 4 th Floor 625 Broadway, Albany, New York 12233-1500 Fax: (518) 402-9018 or (518) 402-9019 Website: www.dec.ny.gov Joe Martens Commissioner May 16, 2011 VIA HAND DELIVERY AND ELECTRONIC MAIL Hon. Maria E. Villa Hon. Daniel P. O'Connell Administrative Law Judges New York State Department of Environmental Conservation Office of Hearings and Mediation Services 625 Broadway, 1st Floor Albany, New York 12233-1550 Re: EntergT Indian Point Nuclear Units 2 and 3 SPDES Permit Renewal / §401 WQC Application Proceedings DEC Staff's Review of Thermal Information

Dear Judges Villa and O'Connell:

In accordance with ¶ "4" of Your Honors' May 6, 2011 "Scheduling Order" in the above-referenced proceedings, this letter is submitted on behalf of DEC staff in order to advise this Tribunal and the parties of the results of staff s review of thermal discharge/impact information submitted to DEC in recent months by Entergy for the Indian Point nuclear facilities.

Specifically, DEC staff reviewed data and information contained in Entergy's 2010 Field Program and Modeling Analysis of the Cooling Water Discharge from the Indian Point Energy Center (January 31, 2011), as well as in Part 1 of Response to NYSDEC Staff Review of the 2010 Field Program and Modeling Analysis of Cooling Water Discharge from IPEC (March 29, 2011)and Part 2 of Response to NYSDEC Staff Review of the 2010 Field Program and Modeling Analysis of Cooling Water Discharge from IPEC (March 31, 2011), and Entergy's Alternative Mixing Zone Explanation and Request (May 3, 2011), and, based upon this information and the applicable regulations (6 NYCRR Part 704 -Criteria Governing Thermal Discharges), has determined that allowance for a thermal mixing zone in the Hudson River near Indian Point not to exceed a maximum of seventy-five (75) acres in total size during any time of a given year (6 NYCRR §704.3) will provide reasonable assurance of compliance with water quality standards and criteria for thermal discharges set forth in 6 NYCRR §§704.1 and 704.2, respectively.!

1 Previously, by letter dated April 11, 2011, and in conjunction with the Joint Submission Regarding§401 WQC Issue No. 5 and SPDES Entergy Issue No. 9 dated April 8, 2011, DEC staff informed the Tribunal and parties that Entergy had provided DEC with sufficient thermal analyses and information that were lacking at the time of DEC's April 2, 2010 Notice of Denial of Entergy's

§401 WQC application.

Consequently, DEC staff proposes to amend or otherwise modify the Draft SPDES permit for the Indian Point nuclear facilities, originally noticed for public comment in November 2003 and subsequently revised on March 1, 2004 (See SPDES permit Issues Conference Exhibit"11 C"), to include the following draft condition to replace the current Special Condition 7(b) [on Page 10 of 24 of March 1, 2004 revised Draft SPDES permit] as follows: "b. The thermal discharge from the Indian Point nuclear facilities shall assure the protection and propagation of a balanced, indigenous population of shellfish, fish and wildlife in and on the Hudson River.In this regard, the Department has approved the permittee's request for a thermal discharge mixing zone pursuant to 6 NYCRR section 704.3 for the 5-year term of this SPDES permit. The water temperature at the surface of the Hudson River shall not be raised more than 1.5 degrees Fahrenheit (from July through September, when surface water temperature is greater than 83 degrees Fahrenheit) above the surface temperature that existed before the addition of heat of artificial origin (6 NYCRR section 704.2[b][5][iii])

except in a mixing zone of seventy-five (75) acres (total) from the point of discharge.

The thermal discharge from the Indian Point nuclear facilities to the Hudson River may exceed 90 degrees Fahrenheit (6 NYCRR section 704.2[b][5][i]

of the State's Criteria Governing Thermal Discharges) within the designated mixing zone area, the total area of which shall not exceed seventy-five (75) acres (3,267,000 square feet) on a daily basis." As indicated in other submissions to this Tribunal, Entergy recently provided DEC staff with sufficient thermal analyses and information, including a tri-axial (3-Dimensional) thermal study, as well as technical material and a proposal for a thermal discharge mixing zone (6 NYCRR §704.3), that had previously been required by Special Condition 7(b) of the March 1, 2004 revised Draft SPDES permit for the Indian Point nuclear facilities (see fn 1). With this and other thermal discharge information for the facilities, Entergy has now effectively satisfied the applicable substantive requirements that were designated in Special Condition 7(b) of the March 1, 2004 revised Draft SPDES permit, thereby rendering the provisional terms of that permit condition superfluous at this point in time. Accordingly, DEC staff intends to replace the prior provisions of Special Condition 7(b) in the March 1, 2004 revised Draft SPDES permit with the proposed condition cited above which, DEC staff maintains, appropriately represents the current state of thermal discharge information for the Indian Point nuclear facilities.

We trust if there are any questions regarding DEC staff's intention or proposal in this regard, that they can be addressed in the upcoming call with Your Honors and parties in these matters scheduled for Thursday, May 19, 2011, at 10:00 AM.2 Thank you for your courtesies and attention to these matters.Very truly yours, Mark D. Sanza Assistant Counsel VIA ORDINARY U.S.AND ELECTRONIC MAIL: Elise N. Zoli, Esq.Robert H. Fitzgerald, Esq.Goodwin Procter LLP Exchange Place Boston, Massachusetts 02109 Rebecca Troutman, Esq.Riverkeeper, Inc.20 Secor Road Ossining, New York 10562 Melissa-Jean Rotini, Esq.County of Westchester Room 600, 148 Martine Avenue White Plains, New York 10601 Daniel Riesel, Esq.Sive, Paget & Riesel, P.C.460 Park Avenue, 10th Floor New York, New York 10022 Richard L. Brodsky, Esq.2121 Saw Mill River Road White Plains, New York 10607 Michael J. Delaney, Esq.Director, Energy Regulatory Affairs New York City Department of Environmental Protection 59-17 Junction Boulevard, 1 9 th Floor Flushing, New York 11373-5108 ezoli@goodwinprocter.com rfitzgerald@goodwinprocter.com jenglander@goodwinprocter.com gwilliams@goodwinprocter.com rtroutman@riverkeeper.org mjrl @westchestergov.com driesel@sprlaw.com vshiah@sprlaw.com richardbrodsky@gmail.com mdelaney@dep.nyc.gov 3

Sam M. Laniado, Esq.Read and Laniado, LLP 25 Eagle Street Albany, New York 12207-1901 Robert J. Glasser, Esq.Robert J. Glasser, P.C.284 South Avenue Poughkeepsie, New York 12601 sml@readlaniado.com dbj@readlaniado.com bob.glasser@robertj glasserpc.com VIA E-MAIL ONLY: Ned Sullivan Hayley Mauskapf, Esq.Paul Schwartzberg Scenic Hudson, Inc.Karl S. Coplan, Esq.Daniel E. Estrin, Esq.Pace Environmental Litigation Clinic, Inc.Deborah Brancato, Esq.Phillip H. Musegaas, Esq.Nicholas Goldstein Katherine Leisch Scott Troia Geoffrey H. Fettus, Esq.Natural Resources Defense Council Steven Blow, Esq.NYS Department of Public Service Frank V. Bifera, Esq.Hiscock & Barclay, LLP Kelli M. Dowell, Esq.Entergy Services, Inc.nsullivan@scenichudson.org hmauskapf@scenichudson.org schwartzberg@scenichudson.org kcoplan@law.pace.edu destrin@law.pace.edu dbrancato@riverkeeper.org phillip@riverkeeper.org ngoldstein@law.pace.edu kleisch@law.pace.edu stroia@law.pace.edu gfettus@nrdc.org stevenblow@dps.state.ny.us fbifera@hblaw.com kdowell@entergy.com EDMS#398966vl 4