Generic Environmental 

Impact Statement for License 

Renewal of Nuclear Plants

Supplement 38

Regarding Indian Point 

Nuclear Generating

Unit Nos. 2 and 3

Draft Report for Comment

 

Office of Nuclear Reactor Regulation

NUREG-1437

Supplement 38

Volume 5
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Generic Environmental

Impact Statement for License 

Renewal of Nuclear Plants

Supplement 38

Regarding Indian Point

Nuclear Generating

Unit Nos. 2 and 3

Draft Report for Comment

 

Manuscript Completed: November 2015

Date Published: December 2015

Office of Nuclear Reactor Regulation

NUREG-1437

Supplement 38

Volume 5

iii

1 COVER SHEET

2 Responsible Agency: U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor 

3 Regulation. There are no cooperating agencies involved in the preparation of this document.

4 Title: Generic Environmental Impact Statement for License Renewal of Nuclear Plants, 

5 Supplement 38, Volume 5, Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3, Draft 

6 Report for Comment (NUREG–1437).

7 Indian Point Nuclear Generating Unit Nos. 2 and 3 are located in Buchanan, New York.

8 For additional information or copies of this document contact:

9 Division of License Renewal

10 U.S. Nuclear Regulatory Commission

11 Office of Nuclear Reactor Regulation

12 Mail Stop O-11F1

13 11555 Rockville Pike

14 Rockville, Maryland 20852

15 Phone: 1-800-368-5642, extension 6459

16 Fax: (301) 415-2002

17 Email: michael.wentzel@nrc.gov

18 ABSTRACT

19 This second supplement to the final supplemental environmental impact statement (FSEIS) for 

20 the proposed renewal of the operating licenses for Indian Point Nuclear Generating Unit Nos. 2 

21 and 3 incorporates new information that the U.S. Nuclear Regulatory Commission (NRC) staff 

22 has obtained since the publication of the first supplement to the FSEIS in June 2013.

23 This supplement includes the NRC staff’s evaluation of revised engineering project cost 

24 information for severe accident mitigation alternatives, newly available aquatic impact 

25 information, the additional environmental issues associated with license renewal resulting from 

26 the June 2013 revision to Table B–1 in Appendix B to Subpart A of Title 10 of the Code of 

27 Federal Regulations (10 CFR) Part 51 and NUREG–1437, Generic Environmental Impact 

28 Statement for License Renewal of Nuclear Plants, and incorporates the impact determinations 

29 of NUREG–2157, Generic Environmental Impact Statement for Continued Storage of Spent 

30 Nuclear Fuel, in accordance with the requirements in 10 CFR 51.23(b). Additionally, this 

31 supplement describes the reinitiation of consultation under Section 7 of the Endangered 

32 Species Act regarding the northern long-eared bat (Myotis septentrionalis) and provides an 

33 update on the status of the operating licenses for Indian Point Nuclear Generating Unit Nos. 2 

34 and 3.

v

1 TABLE OF CONTENTS

2 ABSTRACT.............................................................................................................................. iii

3 TABLE OF CONTENTS ............................................................................................................ v

4 LIST OF FIGURES ................................................................................................................... ix

5 LIST OF TABLES................................................................................................................... xiii

6 EXECUTIVE SUMMARY ......................................................................................................... xv

7 ABBREVIATIONS, ACRONYMS, AND SYMBOLS................................................................ xix

8 1.0 INTRODUCTION............................................................................................................. 1

9 2.0 TIMELY RENEWAL ........................................................................................................ 3

10 3.0 REVISED SAMA ENGINEERING PROJECT COST ESTIMATES.................................. 5

11 Review of Entergy’s Completed Engineering Project Cost Estimates for 

12 SAMAs Previously Identified as Potentially Cost Beneficial................................. 5

13 3.1.1 Background......................................................................................... 5

14 3.1.2 Entergy’s Completed Engineering Project Cost Estimates .................. 7

15 3.1.3 Review of Entergy’s Refined Cost Estimates ...................................... 8

16 3.1.3.1 NRC Staff’s Review of Six SAMAs Identified as Not 

17 Cost Beneficial as a Result of Refined Cost 

18 Estimations ....................................................................... 13

19 3.1.3.2 The NRC Staff’s Review of 16 Potentially 

20 Cost-Beneficial SAMAs ..................................................... 17

21 3.1.3.3 Sensitivity Analysis............................................................ 17

22 3.1.3.4 Conclusion of the NRC Staff’s Review of Entergy’s 

23 Refined Cost Estimates..................................................... 19

24 3.1.4 Review of Entergy’s Deferral of Certain Cost-Beneficial SAMAs 

25 Pending Implementation of Fukushima Dai-ichi Action Items ............ 19

26 3.1.5 Conclusions ...................................................................................... 21

27 Revisions to the 2010 FSEIS Resulting from Entergy’s Completed 

28 Engineering Project Cost Estimates for SAMAs Previously Identified as 

29 Potentially Cost Beneficial................................................................................. 21

30 4.0 ENTERGY’S REPORTEDLY NEW INFORMATION FOR ENTRAINMENT AND

31 IMPINGEMENT IMPACTS ........................................................................................... 25

32 Background....................................................................................................... 25

33 Entergy’s New Information ................................................................................ 27

34 NRC Staff’s Independent Analysis of the AKRF (2014) Report and 

35 Updated Field Data........................................................................................... 33

36 5.0 NEW ENVIRONMENTAL ISSUES RESULTING FROM THE REVISION TO 10 

37 CFR PART 51 .............................................................................................................. 39

38 Air Quality Impacts (All Plants).......................................................................... 40
Table of Contents

vi

1 5.1.1 Revisions to Section 2.1.5.1, “Nonradioactive Waste Streams,” 

2 and Section 2.2.4.3, “Air Quality,” of the FSEIS................................. 41

3 5.1.2 Revisions to Section 3.2.3, “Air Quality during Refurbishment 

4 (Nonattainment and Maintenance Areas)”......................................... 44

5 5.1.3 Category 1—Air Quality Impacts (All Plants)..................................... 45

6 Geology and Soils............................................................................................. 47

7 Effects of Dredging on Surface Water Quality ................................................... 49

8 Radionuclides Released to Groundwater.......................................................... 50

9 5.4.1 Site Description and Hydrology ......................................................... 50

10 5.4.1.1 Hudson River .................................................................... 50

11 5.4.1.2 Groundwater ..................................................................... 51

12 5.4.1.3 Water Resources .............................................................. 56

13 5.4.2 Radionuclides Released to Groundwater .......................................... 57

14 5.4.2.1 History of Releases ........................................................... 57

15 5.4.2.2 Extent of Groundwater Contamination............................... 58

16 5.4.2.3 Monitoring Groundwater Contamination ............................ 64

17 5.4.2.4 Independent Evaluations................................................... 65

18 5.4.2.5 Corrective Actions ............................................................. 68

19 5.4.3 Environmental Consequences .......................................................... 75

20 Effects on Terrestrial Resources (Noncooling System Impacts)........................ 75

21 Exposure of Terrestrial Organisms to Radionuclides......................................... 77

22 Cooling System Impacts on Terrestrial Resources (Plants with 

23 Once-Through Cooling Systems or Cooling Ponds).......................................... 78

24 Exposure of Aquatic Organisms to Radionuclides............................................. 79

25 Effects of Dredging on Aquatic Organisms........................................................ 81

26 Impacts of Transmission Line Right-of-Way Management on Aquatic 

27 Resources......................................................................................................... 81

28 Human Health Impacts from Chemicals and Physical Occupational 

29 Hazards ............................................................................................................ 82

30 Minority and Low-Income Populations............................................................... 83

31 Greenhouse Gas Emissions and Climate Change ............................................ 84

32 5.13.1 Revisions to Section 6.2, “Greenhouse Gas Emissions” ................... 84

33 5.13.2 GHG Emissions and Climate Change ............................................... 85

34 5.13.2.1 GHG Emissions from License Renewal............................. 85

35 5.13.2.2 Climate Change Impacts to Resource Areas..................... 86

36 Cumulative Impacts .......................................................................................... 94

37 5.14.1 Air Quality and Noise ........................................................................ 97

38 5.14.1.1 Air Quality ......................................................................... 97

39 5.14.1.2 Noise................................................................................. 98

40 5.14.2 Geology and Soils............................................................................. 99

41 5.14.3 Surface Water................................................................................. 100

42 5.14.4 Groundwater................................................................................... 105
Table of Contents

vii

1 5.14.5 Terrestrial Resources...................................................................... 106

2 5.14.6 Aquatic Resources.......................................................................... 106

3 5.14.7 Radiological Impacts....................................................................... 107

4 5.14.8 Waste Management and Pollution Prevention................................. 108

5 5.14.9 Socioeconomic Impacts .................................................................. 108

6 5.14.10 Historic and Cultural Resources...................................................... 109

7 5.14.11 Environmental Justice..................................................................... 109

8 5.14.12 Global Climate Change................................................................... 111

9 5.14.13 Conclusions Regarding Cumulative Impacts ................................... 113

10 6.0 CONTINUED STORAGE OF SPENT NUCLEAR FUEL ............................................. 115

11 Issuance of the Revised 10 CFR 51.23 and NUREG–2157 ............................ 116

12 6.1.1 CLI-14-08: Determination That Revised 10 CFR 51.23 and 

13 NUREG–2157 Satisfy the NRC’s NEPA Obligations for 

14 Continued Storage and Accounting for the Environmental 

15 Impacts in NUREG–2157................................................................ 118

16 6.1.1.1 At-Reactor Storage ......................................................... 118

17 6.1.1.2 Away-from-Reactor Storage............................................ 119

18 6.1.1.3 Cumulative Impacts......................................................... 120

19 6.1.1.4 Conclusion ...................................................................... 121

20 6.1.2 Revisions to the 2010 FSEIS Resulting from Revisions to 

21 10 CFR 51.23.................................................................................. 121

22 7.0 SECTION 7 CONSULTATION .................................................................................... 125

23 Reinitiation of Consultation due to FWS’s Listing of Northern 

24 Long-eared Bat ............................................................................................... 125

25 8.0 SUMMARY AND CONCLUSIONS.............................................................................. 127

26 Environmental Impacts of License Renewal from Issues Considered in 

27 this Supplement .............................................................................................. 128

28 Recommendation............................................................................................ 129

29 Revisions to Chapter 9 of the 2010 FSEIS...................................................... 129

30 9.0 REFERENCES............................................................................................................ 133

31 10.0 LIST OF PREPARERS ............................................................................................... 153

32 APPENDIX A REVISED IMPINGEMENT AND ENTRAINMENT IMPACT ANALYSIS 

33 FOR INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 ............A-1

ix

1 LIST OF FIGURES

2 Figure 5–1. Site Location and Topography .......................................................................... 52

3 Figure 5–2. Topographic Cross-Section to Hudson River .................................................... 53

4 Figure 5–3. Monitor Wells Located near Plant Buildings ...................................................... 59

5 Figure 5–4. Cross-Section of Strontium-90 Plume from IP1 to the Hudson River................. 61

6 Figure 5–5. IP2 and IP1 Tritium Plumes in the 4th Quarter of 2014 ..................................... 62

7 Figure 5–6. Strontium-90 Plume in the 4th Quarter of 2014 ................................................. 63

8 Figure 5–7. IP2 Tritium Plume in 2007................................................................................. 73

9 Figure 5–8. Strontium-90 Plume in 2007.............................................................................. 74

10 Figure A–1. Sampling Regions of the Hudson River Monitoring Program............................A-4

11 Figure A–2. Weeks Sampled from 1985 through 2011 by the Three Hudson River 

12 Monitoring Program Surveys: the Long River Survey (LRS), Fall Shoals 

13 Survey (FSS), and Beach Seine Survey (BSS)................................................A-5

14 Figure A–3. One Realization of the Monte Carlo Simulation Using Parameter 

15 Estimates for White Perch..............................................................................A-19

16 Figure A–4. Example Frequency Distribution of the Relative Difference in Cumulative 

17 Abundance from the Monte Carlo Simulation (n = 1000). Dashed lines 

18 indicate the first and third quartiles (Q1 and Q3) of the distribution ................A-19

19 Figure A–5. Estimated Linear Slopes and Confidence Intervals (Blue Bars with Error 

20 Bars) and the P-Values for the Test of Zero Slope (Red Thick Circles) for 

21 Each American Shad Population Measure of Abundance ..............................A-23

22 Figure A–6. Estimated Linear Slopes and Confidence Intervals (Blue Bars with Error 

23 Bars) and the P-Values for the Test of Zero Slope (Red Thick Circles) for 

24 Each Atlantic Tomcod Population Measure of Abundance.............................A-23

25 Figure A–7. Estimated Linear Slopes and Confidence Intervals (Blue Bars with Error 

26 Bars) and the P-Values for the Test of Zero Slope (Red Thick Circles) for 

27 Each Blueback Herring Population Measure of Abundance ...........................A-24

28 Figure A–8. Estimated Linear Slopes and Confidence Intervals (Blue Bars with Error 

29 Bars) and the P-Values for the Test of Zero Slope (Red Thick Circles) for 

30 Each Rainbow Smelt Population Measure of Abundance...............................A-24

31 Figure A–9. Estimated Linear Slopes and Confidence Intervals (Blue Bars with Error 

32 Bars) and the P-Values for the Test of Zero Slope (Red Thick Circles) for 

33 Each Bluefish Population Measure of Abundance..........................................A-25

34 Figure A–10. Estimated Linear Slopes and Confidence Intervals (Blue Bars with Error 

35 Bars) and the P-Values for the Test of Zero Slope (Red Thick Circles) for 

36 Each Hogchoker Population Measure of Abundance .....................................A-26

37 Figure A–11. Estimated Linear Slopes and Confidence Intervals (Blue Bars with Error 

38 Bars) and the P-Values for the Test of Zero Slope (Red Thick Circles) for 

39 Each Striped Bass Population Measure of Abundance ..................................A-26
List of Figures

x

1 Figure A–12. Estimated Linear Slopes and Confidence Intervals (Blue Bars with Error 

2 Bars) and the P-Values for the Test of Zero Slope (Red Thick Circles) for 

3 Each White Catfish Population Measure of Abundance .................................A-27

4 Figure A–13. River Segment 4 Alewife Population Trends Based on the BSS 

5 Standardized Density for Two Subsets of Years of Monitoring Data ..............A-35

6 Figure A–14. River Segment 4 Weakfish Population Trends Based on the FSS 

7 Standardized Density for Two Subsets of Years of Monitoring Data ..............A-35

8 Figure A–15. River Segment 4 White Perch Population Trends Based on the BSS 

9 Standardized Density for Two Subsets of Years of Monitoring Data ..............A-36

10 Figure A1. River Segment 4 LRS YOY Density (May–July Sampling Events, 1985–

11 2011, with 3 yr. Moving Average Smoothing).................................................A-48

12 Figure B1. River Segment 4 FSS YOY Density (July–Oct Sampling Events, 1985–

13 2011, with 3 yr. Moving Average Smoothing).................................................A-49

14 Figure C1. River Segment 4 BSS YOY Density (July–Oct Sampling Events, 1985–

15 2011, with 3 yr. Moving Average Smoothing).................................................A-50

16 Figure D1. River Segment 4 LRS YOY CPUE (May–July Sampling Events, 1985–

17 2011) .............................................................................................................A-51

18 Figure E1. River Segment 4 FSS YOY CPUE (July–Oct Sampling Events, 1985–

19 2011) .............................................................................................................A-52

20 Figure F1. Riverwide LRS YOY CPUE (May–July Sampling Events, 1985–2011)...........A-53

21 Figure G1. Riverwide FSS YOY CPUE (July–Oct Sampling Events, 1985–2011)............A-54

22 Figure H1. Riverwide BSS YOY CPUE (July–Oct Sampling Events, 1985–2011)............A-55

23 Figure I1. Riverwide LRS YOY Abundance Index (1974–2011) .....................................A-56

24 Figure J1. Riverwide FSS YOY Abundance Index (1979–2011) .....................................A-56

25 Figure K1. Riverwide BSS YOY Abundance Index (1974–2011).....................................A-57

26 Figure A2. Alewife Estimated Slope (Blue Bars with Error Bars) and the P-Values for 

27 the Test of Zero Slope (Red Thick Circles) for Each Measure of 

28 Abundance.....................................................................................................A-65

29 Figure B2. American Shad Estimated Slope (Blue Bars with Error Bars) and the 

30 P-Values for the Test of Zero Slope (Red Thick Circles) for Each 

31 Measure of Abundance..................................................................................A-66

32 Figure C2. Atlantic Tomcod Estimated Slope (Blue Bars with Error Bars) and the 

33 P-Values for the Test of Zero Slope (Red Thick Circles) for Each 

34 Measure of Abundance..................................................................................A-66

35 Figure D2. Bay Anchovy Estimated Slope (Blue Bars with Error Bars) and the 

36 P-Values for the Test of Zero Slope (Red Thick Circles) for Each 

37 Measure of Abundance..................................................................................A-67

38 Figure E2. Blueback Herring Estimated Slope (Blue Bars with Error Bars) and the 

39 P-Values for the Test of Zero Slope (Red Thick Circles) for Each 

40 Measure of Abundance..................................................................................A-67
List of Figures

xi

1 Figure F2. Bluefish Estimated Slope (Blue Bars with Error Bars) and the P-Values 

2 for the Test of Zero Slope (Red Thick Circles) for Each Measure of 

3 Abundance.....................................................................................................A-68

4 Figure G2. Gizzard Shad Estimated Slope (Blue Bars with Error Bars) and the 

5 P-Values for the Test of Zero Slope (Red Thick Circles) for Each 

6 Measure of Abundance..................................................................................A-68

7 Figure H2. Hogchoker Estimated Slope (Blue Bars with Error Bars) and the 

8 P-Values for the Test of Zero Slope (Red Thick Circles) for Each 

9 Measure of Abundance..................................................................................A-69

10 Figure I2. Rainbow Smelt Estimated Slope (Blue Bars with Error Bars) and the 

11 P-Values for the Test of Zero Slope (Red Thick Circles) for Each 

12 Measure of Abundance..................................................................................A-69

13 Figure J2. Spottail Shiner Estimated Slope (Blue Bars with Error Bars) and the 

14 P-Values for the Test of Zero Slope (Red Thick Circles) for Each 

15 Measure of Abundance..................................................................................A-70

16 Figure K2. Striped Bass Estimated Slope (Blue Bars with Error Bars) and the 

17 P-Values for the Test of Zero Slope (Red Thick Circles) for Each 

18 Measure of Abundance..................................................................................A-70

19 Figure L2. Weakfish Estimated Slope (Blue Bars with Error Bars) and the P-Values 

20 for the Test of Zero Slope (Red Thick Circles) for Each Measure of 

21 Abundance.....................................................................................................A-71

22 Figure M2. White Catfish Estimated Slope (Blue Bars with Error Bars) and the 

23 P-Values for the Test of Zero Slope (Red Thick Circles) for Each 

24 Measure of Abundance..................................................................................A-71

25 Figure N2. White Perch Estimated Slope (Blue Bars with Error Bars) and the 

26 P-Values for the Test of Zero Slope (Red Thick Circles) for Each 

27 Measure of Abundance..................................................................................A-72

xiii

1 LIST OF TABLES

2 Table 3–1. Summary of Refined and Corrected Cost Estimates for 22 SAMAs .................. 10

3 Table 3–2. Summary of the NRC Staff Sensitivity Analysis................................................. 18

4 Table 4–1. Differences in Methodology among the FSEIS (NRC 2010, 2013b), 

5 Entergy (2015c; AKRF 2014, 2015), and the Present Analysis. ........................ 34

6 Table 4–2. Impacts of Impingement and Entrainment at IP2 and IP3 on Hudson 

7 River Representative Important Species in FSEIS, Entergy’s Analysis, 

8 and the Present Analysis .................................................................................. 37

9 Table 5–1. Revised 10 CFR Part 51 Issues........................................................................ 40

10 Table 2–0. Nonattainment and Maintenance Areas for Connecticut, New Jersey, 

11 and New York Counties within a 50-mi (80-km) Radius of IP2 and IP3 ............. 42

12 Table 5–2. Radionuclide Concentration Levels/Limits......................................................... 64

13 Table 5–3. Yearly Averages of Radionuclide Concentrations in Onsite Groundwater 

14 Sampling Stations Located near the Hudson River ........................................... 71

15 Table 5–4. Estimated Greenhouse Gas Emissions from Operations at IP2 and IP3 ........... 86

16 Table 5–5. Actions and Projects Considered in the Cumulative Impacts Analysis 

17 Subsequent to the Issuance of the 2010 FSEIS................................................ 95

18 Table 5–6. Comparison of GHG Emission Inventories...................................................... 112

19 Table 6–1. Category 1 Issues Applicable to the Uranium Fuel Cycle and Solid 

20 Waste Management during the Renewal Term ............................................... 122

21 Table 9–1 Summary of Environmental Significance of License Renewal

22 and Alternatives.................................................................................131

23 Table 10–1. List of Preparers ............................................................................................. 153

24 Table A–1. Hudson River Monitoring Studies Used To Assess Impacts.............................A-6

25 Table A–2. Representative Important Hudson River Aquatic Species ................................A-8

26 Table A–3. Comparison of Riverwide Median Young-of-Year (YOY) Catch-per-Unit27 Effort (CPUE) Among Hudson River Estuary Monitoring Surveys, 

28 1985-2011......................................................................................................A-10

29 Table A–4. Percentage of Each Life Stage Entrained by Season and the 

30 Contribution of Major Taxa Represented in the Samples ...............................A-12

31 Table A–5. Method for Estimating Taxon-Specific Entrainment Mortality Rate (EMR) 

32 Based on River Segment 4 Standing Crop for the Strength-of33 Connection Analysis ......................................................................................A-13

34 Table A–6. Estimated Annual Standing Crop of Eggs, Larvae, and Juvenile RIS 

35 within River Segment 4 (thousands of fish)....................................................A-14

36 Table A–7. Annual Estimated Number of RIS Entrained at IP2 and IP3 (thousands 

37 of fish)............................................................................................................A-15

38 Table A–8. Estimate of the River Segment 4 Entrainment Mortality Rate (EMR) and 

39 the 95 Percent Confidence Limits for the Riverwide Entrainment CMR 

40 (1974–1997) ..................................................................................................A-16

41 Table A–9. Percentage of Each Life Stage Impinged by Season and the 

42 Contribution of Major Taxa Represented in the Samples ...............................A-17
List of Tables

xiv

1 Table A–10. Cumulative Conditional Impingement Mortality Rate Estimated by Year 

2 Class for Indian Point Used to Estimate the Taxon-Specific 

3 Impingement Mortality Rate (IMR) for the Strength of Connection 

4 Analysis. ........................................................................................................A-18

5 Table A–11. Use and Utility Attributes and Scores Used To Evaluate RIS Population 

6 Trends Associated with IP2 and IP3 Cooling System Operation ....................A-20

7 Table A–12. Assessment of Population Impacts for IP2 and IP3 River Segment 4.............A-27

8 Table A–13. Assessment of Riverwide Population Impacts................................................A-28

9 Table A–14. Weight of Evidence Results for the Population Trend Line of Evidence .........A-29

10 Table A–15. Table A–15 Parameter Values Used in the Monte Carlo Simulation...............A-30

11 Table A–16. Quartiles of the Relative Difference in Cumulative Abundance and 

12 Conclusions for the Strength-of-Connection from the Monte Carlo 

13 Simulation......................................................................................................A-31

14 Table A–17. Weight of Evidence for the Strength-of-Connection Line of Evidence for 

15 YOY RIS Based on the Monte Carlo Simulation.............................................A-32

16 Table A–18. Impingement and Entrainment Impact Summary for Hudson River YOY 

17 RIS ................................................................................................................A-33

18 Table A–19. P-Values for Mann-Whitney Test of Equal Median Abundance Pre- and 

19 Post-1985 for Each Population Metric ............................................................A-34

20 Table A. Linear Analysis of LRS Region 4 YOY Density ..............................................A-58

21 Table B. Linear Analysis of FSS Region 4 YOY Density ..............................................A-58

22 Table C. Linear Analysis of BSS Region 4 YOY Density ..............................................A-59

23 Table D. Linear Analysis of LRS Region 4 YOY CPUE ................................................A-59

24 Table E. Linear Analysis of FSS Region 4 YOY CPUE ................................................A-60

25 Table F. Linear Analysis of LRS Riverwide YOY CPUE...............................................A-61

26 Table G. Linear Analysis of FSS Riverwide YOY CPUE...............................................A-62

27 Table H. Linear Analysis of BSS Riverwide YOY CPUE...............................................A-63

28 Table I. Linear Analysis of LRS Abundance Index ......................................................A-63

29 Table J. Linear Analysis of FSS Abundance Index ......................................................A-64

30 Table K. Linear Analysis of BSS Abundance Index ......................................................A-64
xv

1 EXECUTIVE SUMMARY

2 BACKGROUND

3 By letter dated April 23, 2007, Entergy Nuclear Operations, Inc. (Entergy), submitted an 

4 application to the U.S. Nuclear Regulatory Commission (NRC) to issue renewed operating 

5 licenses for Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3) for additional 

6 20-year periods.

7 Under Title 10 of the Code of Federal Regulations (10 CFR) 51.20(b)(2) and the National 

8 Environmental Policy Act of 1969, as amended (NEPA) (42 U.S.C. 4321 et seq.), the renewal of 

9 a power reactor operating license requires preparation of an environmental impact statement 

10 (EIS) or a supplement to an existing EIS. In addition, 10 CFR 51.95(c) states that the NRC shall 

11 prepare an EIS, which is a supplement to the Commission’s NUREG–1437, Generic 

12 Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), Revision 1, 

13 which was issued in June 2013.

14 The NRC staff published its final supplemental environmental impact statement (FSEIS) for IP2 

15 and IP3 in December 2010. In June 2013, the NRC staff issued a supplement to the FSEIS, 

16 updating its final analysis to include corrections to impingement and entrainment data presented 

17 in the FSEIS; revising conclusions on thermal impacts based on newly available thermal plume

18 studies; and providing an update of the status of the NRC’s consultation, under Section 7 of the 

19 Endangered Species Act of 1973, as amended, with the National Marine Fisheries Service

20 regarding the shortnose sturgeon and Atlantic sturgeon.

21 Subsequent to publishing the 2013 FSEIS supplement, the NRC staff identified new information 

22 that necessitated changes to its assessments in the FSEIS and Supplement 1to the FSEIS. 

23 This new information is derived from the following:

24 • Entergy provided refined engineering project cost estimates for the 22 potentially 

25 cost-beneficial severe accident mitigation alternatives (SAMAs) previously identified 

26 in the FSEIS.

27 • Entergy provided newly available information relevant to the NRC staff’s evaluation 

28 of impacts from the operation of IP2 and IP3 on certain aquatic species in the 

29 Hudson River.

30 • In June 2013, the NRC amended its regulations at Appendix B to Subpart A of 

31 10 CFR Part 51 to redefine the number and scope of the environmental issues that 

32 must be addressed during license renewal environmental reviews. This revision was 

33 supported by analyses conducted for, and reported in, Revision 1 to the GEIS.

34 • In September 2014, the NRC amended its regulations at 10 CFR 51.23 to adopt the 

35 generic impact determinations made in NUREG–2157, Generic Environmental 

36 Impact Statement for Continued Storage of Spent Nuclear Fuel, regarding the 

37 continued storage of spent nuclear fuel.

38 To address this new information, the NRC staff has prepared this supplement to the FSEIS in 

39 accordance with 10 CFR 51.92(a)(2) and 10 CFR 51.92(c), which address preparation of a 

40 supplement to a final EIS for proposed actions that have not been taken under one of the 

41 following conditions:

42 • There are new and significant circumstances or information relevant to 

43 environmental concerns and bearing on the proposed action or its impacts.
Executive Summary

xvi

1 • The NRC staff determines, in its opinion, that preparation of a supplement will further 

2 the purposes of NEPA.

3 In addition to supplementing the FSEIS for the reasons stated above, the NRC is also taking the 

4 opportunity to provide an update on the status of the IP2 and IP3 operating licenses and the 

5 reinitiation of consultation under Section 7 of the Endangered Species Act regarding the 

6 northern long-eared bat (Myotis septentrionalis).

7 PROPOSED ACTION

8 The proposed action as stated in the FSEIS (on pages 1–6 and 1–7) has been revised, as 

9 follows, to reflect the change in status for the IP2 license:

10 The proposed Federal action is renewal of the operating licenses for IP2 

11 and IP3 (IP1 was shut down in 1974). IP2 and IP3 are located on 

12 approximately 239 acres of land on the east bank of the Hudson River at 

13 Indian Point, Village of Buchanan, in upper Westchester County, New 

14 York, approximately 24 miles north of the New York City boundary line. 

15 The facility has two Westinghouse pressurized–water reactors. IP2 is 

16 currently licensed to generate 3216 megawatts thermal (MW(t)) (core 

17 power) with a design net electrical capacity of 1078 megawatts electric 

18 (MW(e)). IP3 is currently licensed to generate 3216 MW(t) (core power) 

19 with a design net electrical capacity of about 1080 MW(e). IP2 and IP3 

20 cooling is provided by water from the Hudson River to various heat loads 

21 in both the primary and secondary portions of the plants. The current 

22 operating license for IP2 expires on September 28, 2013, and the 

23 current operating license for IP3 expires on December 12, 2015. By 

24 letter dated April 23, 2007, Entergy submitted an application to the NRC 

25 (Entergy 2007a) to renew the IP2 and IP3 operating licenses for an 

26 additional 20 years. The operating licenses for IP2 and IP3 were set 

27 to expire on September 28, 2013, and December 12, 2015, 

28 respectively. However, having met the requirements in 

29 10 CFR 2.109, Entergy is allowed to continue to operate IP2 and IP3 

30 under the existing licenses until the NRC reaches a decision on the 

31 license renewal request.

32 PURPOSE AND NEED FOR ACTION

33 The purpose and need for action remains the same as stated in the FSEIS (on page 1–7):

34 Although a licensee must have a renewed license to operate a reactor 

35 beyond the term of the existing operating license, the possession of that 

36 license is just one of a number of conditions that must be met for the licensee 

37 to continue plant operation during the term of the renewed license. Once an 

38 operating license is renewed, State regulatory agencies and the owners of 

39 the plant will ultimately decide whether the plant will continue to operate 

40 based on factors such as the need for power or matters within the State’s 

41 jurisdiction—including acceptability of water withdrawal, consistency with 

42 State water quality standards, and consistency with State coastal zone 

43 management plans—or the purview of the owners, such as whether 

44 continued operation makes economic sense.
Executive Summary

xvii

1 Thus, for license renewal reviews, the NRC has adopted the following 

2 definition of purpose and need (GEIS Section 1.3): 

3 The purpose and need for the proposed action (renewal of an operating 

4 license) is to provide an option that allows for power generation capability 

5 beyond the term of a current nuclear power plant operating license to 

6 meet future system generating needs, as such needs may be determined 

7 by State, utility, and where authorized, Federal (other than NRC) decision 

8 makers.

9 This definition of purpose and need reflects the Commission’s recognition 

10 that, unless there are findings in the safety review required by the Atomic 

11 Energy Act of 1954, as amended, or findings in the NEPA environmental 

12 analysis that would lead the NRC to reject a license renewal application, the 

13 NRC does not have a role in the energy–planning decisions of State 

14 regulators and utility officials as to whether a particular nuclear power plant 

15 should continue to operate. From the perspective of the licensee and the 

16 State regulatory authority, the purpose of renewing the operating licenses is 

17 to maintain the availability of the nuclear plant to meet system energy 

18 requirements beyond the current term of the plant’s licenses.

xix

1 ABBREVIATIONS, ACRONYMS, AND SYMBOLS

2 °C degree(s) Celsius

3 °F degree(s) Fahrenheit

4 AACE Association for the Advancement of Cost Engineering

5 International

6 ac acre(s)

7 ADAMS Agencywide Documents Access and Management System

8 AEC Atomic Energy Commission

9 AFW auxiliary feedwater

10 AREOR Annual Radiological Environmental Operating Report

11 ASMFC Atlantic States Marine Fisheries Commission

12 ASLB Atomic Safety and Licensing Board

13 BCG Biota Concentration Guide

14 BLS Bureau of Labor Statistics

15 BMPs best management practices

16 BSS Beach Seine Survey

17 CAA Clean Air Act of 1970

18 CFR Code of Federal Regulations

19 cfs cubic foot (feet) per second

20 CHGEC Central Hudson Gas and Electric Corporation

21 CIMR conditional impingement mortality rate

22 CMR conditional mortality rate

23 cm centimeter

24 CO2eq carbon dioxide equivalent

25 CPUE catch per unit effort

26 CV coefficient of variation

27 CWA Clean Water Act

28 dBA A-weighted decibels

29 DOE U.S. Department of Energy

30 DOT U.S. Department of Transportation

31 DPS distinct population segment

32 EIA Energy Information Administration

33 EIS environmental impact statement

34 EMR entrainment mortality rate
Abbreviations, Acronyms, and Symbols

xx

1 Entergy Entergy Nuclear Operations, Inc.

2 EPA U.S. Environmental Protection Agency

3 ER Environmental Report

4 ESA Endangered Species Act of 1973, as amended

5 FAA Federal Aviation Administration

6 FEMA Federal Emergency Management Agency

7 FLIGHT Facility Level Information on GreenHouse gases Tool

8 FR Federal Register

9 FSEIS final supplemental environmental impact statement

10 FSS Fall Shoals Survey

11 ft foot (feet)

12 Fukushima Dai-ichi Fukushima Dai-ichi Nuclear Power Plant

13 FWS U.S. Fish and Wildlife Service

14 GEIS NUREG-1437, “Generic Environmental Impact Statement for 

15 License Renewal of Nuclear Plants”

16 GHG greenhouse gas

17 gpm gallon(s) per minute

18 Gy/d gray per day

19 ha hectare(s)

20 HCFC hydrochlorofluorocarbons

21 I&E impingement and entrapment

22 IMR impingement mortality rate

23 in. inch(es)

24 IP1, IP2, and IP3 Indian Point Nuclear Generating Unit Nos. 1, 2, and 3

25 IPEC Indian Point Energy Center

26 ISFSI independent spent fuel storage installation

27 ISLOCA intersystem loss-of-coolant accident

28 ITS incidental take statement

29 kV kilovolt

30 L/min liter(s) per minute

31 LOE line of evidence

32 LRS Long River Survey

33 m meter(s)

34 mm millimeter(s)

m3 35 /min cubic meter(s) per minute
Abbreviations, Acronyms, and Symbols

xxi

m3 1 /s cubic meter(s) per second

2 mrem millirem

3 MCL maximum contaminant level(s)

4 MMT million metric tons

5 MT metric ton(s)

6 MWe megawatt electric

7 NAAQS National Ambient Air Quality Standards

8 NEI Nuclear Energy Institute

9 NEPA National Environmental Policy Act of 1969

10 NES LME Northeast U.S. Continental Shelf Large Marine Ecosystem

11 NHPA National Historic Preservation Act of 1966

12 NMFS National Marine Fisheries Service

13 NOAA National Oceanographic and Atmospheric Administration

14 NRC U.S. Nuclear Regulatory Commission 

15 NYB New York Bight

16 NYCRR New York Codes, Rules, and Regulations

17 NYSDEC New York State Department of Environmental Conservation

18 OTR ozone transport region

19 PCB polychlorinated biphenyl

20 pCi/L picocurie(s) per liter

21 PM particulate matter

22 PM2.5 particulate matter, 2.5 microns or less in diameter

23 PM5 particulate matter, 5 microns or less in diameter

24 PM10 particulate matter, 10 microns or less in diameter

25 PORV power-operated relief valve

26 QA quality assurance

27 QC quality control

28 rad/d radiation-absorbed dose per day

29 RAI request for additional information

30 REMP Radiological Environmental Monitoring Program

31 RHR residual heat removal

32 RIS representative important species

33 Rkm river kilometer

34 RM river mile

35 ROW right of way
Abbreviations, Acronyms, and Symbols

xxii

1 RP Recommended Practice

2 SAMA severe accident mitigation alternative

3 SEIS supplemental environmental impact statement

4 SOC strength of connection

5 SPDES State Pollutant Discharge Elimination System

6 SRM Staff Requirements Memorandum

7 USACE U.S. Army Corps of Engineers

8 USCB U.S. Census Bureau

9 USGCRP U.S. Global Change Research Program

10 USGS U.S. Geological Survey

11 VOC volatile organic compound

12 WOE weight of evidence

13 yd yard(s)

14 YOY young-of-year
1

1 1.0 INTRODUCTION

2 The U.S. Nuclear Regulatory Commission (NRC) staff prepared this supplement to the final 

3 supplemental environmental impact statement (FSEIS) for Indian Point Nuclear Generating 

4 Unit Nos. 2 and 3 (IP2 and IP3), in accordance with Title 10 of the Code of Federal Regulations

5 (10 CFR) 51.92(a)(2) and 10 CFR 51.92(c), which address the preparation of a supplement to 

6 an FSEIS for proposed actions that have not been taken if the following conditions apply:

7 • There are new and significant circumstances or information relevant to 

8 environmental concerns and bearing on the proposed action or its impacts.

9 • The NRC staff determines, in its opinion, that preparation of a supplement will further 

10 the purposes of the National Environmental Policy Act of 1969, as amended (NEPA) 

11 (42 U.S.C. 4321 et seq.).

12 The NRC staff prepared this supplement to the FSEIS because it received new data and 

13 analyses from Entergy Nuclear Operations, Inc. (Entergy), which had the potential to change, 

14 and in some cases did change, the NRC staff’s conclusions in the FSEIS, as supplemented by 

15 the 2013 supplement to the FSEIS. Additionally, the NRC revised its regulations at 

16 10 CFR Part 51, which resulted in changes to the number and scope of environmental issues 

17 that must be addressed during license renewal environmental reviews. This supplement 

18 contains the text, tables, and figures that changed as the result of this new information.

19 Four sources provided information that was evaluated in this supplement.

20 First, by letter dated May 6, 2013, Entergy (2013b) provided refined engineering project cost 

21 estimates for the 22 potentially cost-beneficial severe accident mitigation alternatives (SAMAs) 

22 previously identified in the FSEIS. As a result of the revised cost estimates, Entergy stated that 

23 six of the SAMAs that had previously been identified as potentially cost beneficial were no 

24 longer cost beneficial. Chapter 3 of this supplement presents the NRC staff’s evaluation of this 

25 new information.

26 Second, Entergy (2014b) submitted new information and analyses relevant to the NRC’s 

27 species-specific impact determinations in the FSEIS for the blueback herring, hogchoker, 

28 rainbow smelt, and white perch. Chapter 4 of this supplement presents the NRC staff’s 

29 evaluation of this new information.

30 Third, the NRC amended its regulations at Table B–1 in Appendix B to Subpart A of 

31 10 CFR Part 51 in June 2013 to redefine the number and scope of the generic and site-specific 

32 environmental impact issues that must be addressed during license renewal environmental 

33 reviews (Volume 78 of the Federal Register (FR), page 37282 (78 FR 37282)). This 

34 amendment was supported by analyses conducted for, and reported in, Revision 1 to 

35 NUREG–1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants

36 (GEIS), dated June 19, 2013 (NRC 2013a). Based on its review of the 2013 GEIS and 

37 Table B–1 in Appendix B to Subpart A of 10 CFR Part 51, the NRC staff determined that several 

38 environmental issues have been added to the scope of license renewal environmental reviews 

39 since issuing the FSEIS in December 2010 and the first supplement to the FSEIS in June 2013. 

40 Chapter 5 of this supplement presents the NRC staff’s evaluation of these issues.

41 Fourth, in September 2014, the NRC revised its regulations at 10 CFR 51.23 addressing the 

42 environmental impacts of continued storage of spent nuclear fuel beyond the licensed life for 

43 operation of a reactor (79 FR 56238). The revised rule adopts the generic impact 

44 determinations made in NUREG–2157, Generic Environmental Impact Statement for Continued 

45 Storage of Spent Nuclear Fuel (NRC 2014f) and codifies the NRC’s generic determinations 
Introduction

2

1 regarding the environmental impacts of continued storage of spent nuclear fuel beyond a 

2 reactor’s operating license. Chapter 6 incorporates the impact determinations of NUREG–2157.

3 In addition to supplementing the FSEIS for the reasons stated above, the NRC is also taking the 

4 opportunity to provide an update on the status of the IP2 and IP3 operating licenses and the 

5 reinitiation of consultation under Section 7 of the Endangered Species Act regarding the 

6 northern long-eared bat (Myotis septentrionalis). Chapter 2 of this supplement updates the 

7 information in the FSEIS pertaining to the expiration date of the IP2 and IP3 licenses. Chapter 7 

8 of this supplement discusses the status of consultation regarding the northern long-eared bat.

9 Where appropriate, bold text indicates specific text corrections or additions to the FSEIS, and 

10 bold strikeout indicates deletions from the text.
3

1 2.0 TIMELY RENEWAL

2 By letter dated April 23, 2007, Entergy Nuclear Operations, Inc. (Entergy), submitted an 

3 application to the U.S. Nuclear Regulatory Commission (NRC) to renew the Indian Point 

4 Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3) operating licenses for an additional 

5 20 years. The operating licenses for IP2 and IP2 were set to expire on September 28, 2013, 

6 and December 12, 2015, respectively. However, Entergy is allowed to continue to operate IP2

7 and IP3 under the existing licenses in accordance with the requirements in Title 10 of the Code 

8 of Federal Regulations (10 CFR) 2.109. The NRC’s regulations at 10 CFR 2.109 implement 

9 Section 558 of the Administrative Procedure Act of 1946 (5 U.S.C. 500 et seq.), which states 

10 that “[w]hen the licensee has made timely and sufficient application for a renewal or a new 

11 license in accordance with agency rules, a license with reference to an activity of a continuing 

12 nature does not expire until the application has been finally determined by the agency.” Under 

13 10 CFR 2.109(b), an application for renewal is considered timely if a licensee files a sufficient 

14 request for a renewed operating license at least 5 years before the expiration of its current 

15 license. Because Entergy submitted its application for renewed licenses—which the NRC found 

16 sufficient for docketing—more than 5 years before the expiration of the IP2 and IP3 licenses, it 

17 is allowed to continue the operation of IP2 under its existing license until the NRC reaches a 

18 decision on the license renewal request. The operating license of IP3 is set to expire on 

19 December 12, 2015.

20 Based on the change in status for the IP2 license, the NRC staff has updated the FSEIS as 

21 described below.

22 Lines 13-15 of page xv in the Executive Summary of the FSEIS are revised as follows:

23 If the operating licenses are not renewed, then IP2 and IP3—the 

24 licenses for which were set to expire on September 28, 2013, and 

25 December 12, 2015, respectively, but are allowed to continue to 

26 operate under the existing licenses pending completion of the 

27 NRC’s review—would be required to shut down.

28 Lines 24-29 of page 1-1 in Section 1.0 of the FSEIS are revised as follows:

29 IP2 has operated under operating license DPR-26 since August 1974. 

30 The IP2 operating license will expire was set to expire on 

31 September 28, 2013. IP3 has operated under operating license DPR-64 

32 26 since August 1976. The IP3 operating license will expire was set to 

33 expire on December 12, 2015. However, having met the requirements 

34 in 10 CFR 2.109, Entergy is allowed to continue to operate IP2 and 

35 IP3 under the existing licenses until the NRC reaches a final 

36 decision on the license renewal request. Indian Point Unit No. 1 (IP1), 

37 which is not the subject of this license renewal application, was shut 

38 down in 1974 and is currently in SAFSTOR (a decommissioning strategy 

39 that includes maintenance, monitoring, and delayed dismantlement to 

40 allow radioactivity to decay prior to decommissioning).

41 Lines 7-10 of page 1-7 in Section 1.3 of the FSEIS are revised as follows:

42 The current operating license for IP2 expires on September 28, 2013, 

43 and the current operating license for IP3 expires on 

44 December 12, 2015. By letter dated April 23, 2007, Entergy submitted 

45 an application to the NRC (Entergy 2007a) to renew the IP2 and IP3 
Timely Renewal

4

1 operating licenses for an additional 20 years. The operating licenses

2 for IP2 and IP3 were set to expire on September 28, 2013, and 

3 December 12, 2015, respectively. However, having met the 

4 requirements in 10 CFR 2.109, the facility is allowed to continue to 

5 operate under the existing licenses until the NRC reaches a decision 

6 on the license renewal request.
5

1 3.0 REVISED SAMA ENGINEERING PROJECT COST ESTIMATES

2 The severe accident mitigation alternatives (SAMAs) analysis constitutes a systematic and 

3 comprehensive process for identifying potential plant improvements, evaluating the 

4 implementation costs and risk reduction for each SAMA, and determining which SAMAs may be 

5 cost beneficial to implement. The analysis is technically rigorous and consistent with the

6 expectation by the National Environmental Policy Act of 1969, as amended (NEPA) 

7 (42 U.S.C. 4321 et seq.), that Federal agencies take a “hard look” at the environmental impacts 

8 of their proposed actions, including consideration of viable alternatives. If a SAMA is 

9 determined to be potentially cost beneficial but is not related to adequately managing the effects 

10 of aging during the relicensing period, it is not required to be implemented as part of the license 

11 renewal process pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 54. 

12 Further refinement beyond determining whether a SAMA is potentially cost beneficial is not 

13 necessary for an objective evaluation. Nevertheless, potentially cost-beneficial alternatives are 

14 identified and considered as part of the license renewal process, and licensees often commit to 

15 further evaluate the most promising cost-beneficial SAMAs among those that have been 

16 identified for possible future implementation in order to further reduce plant risk. Such a 

17 commitment to perform a further evaluation is not a condition of granting a renewed license. 

18 Accordingly, a license renewal applicant’s decision to defer this further evaluation of the 

19 potentially cost-beneficial SAMAs that it has identified to some point in the future (i.e., outside 

20 the license renewal SAMA review) is acceptable.

21 Notwithstanding the acceptability of the SAMA analysis described in the 2010 final supplemental 

22 environmental impact statement (FSEIS), in a letter dated May 6, 2013, Entergy Nuclear 

23 Operations, Inc. (Entergy), submitted revised cost estimates for SAMAs previously identified as 

24 potentially cost beneficial (Entergy 2013b). Based on the refined cost estimates, Entergy 

25 determined that 6 of the 22 SAMAs previously determined to be potentially cost beneficial would 

26 no longer be cost beneficial. These SAMAs for Indian Point Nuclear Generating Unit Nos. 2 

27 and 3 (IP2 and IP3) are identified as IP2-021, IP2-022, IP2-053, IP2-056, IP3-018, and IP3-019. 

28 In addition to providing refined cost estimates, Entergy’s letter dated May 6, 2013, discussed 

29 deferring the consideration of certain cost-beneficial SAMAs pending implementation of action 

30 items related to the U.S. Nuclear Regulatory Commission’s (NRC’s) comprehensive safety 

31 assessment in response to the events affecting the Fukushima Dai-ichi Nuclear Power Plant 

32 (Fukushima Dai-ichi) (Entergy 2013b). The NRC staff’s assessment of Entergy’s revised cost 

33 estimates and the deferral of certain cost-beneficial SAMAs are discussed below.

34 Review of Entergy’s Completed Engineering Project Cost Estimates for 

35 SAMAs Previously Identified as Potentially Cost Beneficial

36 3.1.1 Background

37 As required by 10 CFR 51.53(c)(3)(ii)(L), Entergy (2007a) performed and submitted the results 

38 of its SAMA analysis as part of its Environmental Report. Through the course of review by the 

39 NRC staff, and as a result of NRC staff questions, Entergy revised the SAMA analysis and

40 ultimately found that 22 SAMAs were potentially cost beneficial (Entergy 2009b). For these 

41 SAMAs, Entergy stated that it submitted the potentially cost-beneficial SAMAs for engineering 

42 project cost-benefit analysis (Entergy 2007a, 2009b).

43 In the 2010 FSEIS (NRC 2010), the NRC staff found that the methods used by Entergy for the 

44 evaluation of the SAMAs were sound and that “the treatment of SAMA benefits and costs 

45 support the general conclusion that the SAMA evaluations performed by Entergy are reasonable 
Revised SAMA Engineering Project Cost Estimates

6

1 and sufficient for the license renewal submittal.” In addition, the NRC staff agreed that further 

2 evaluation of the cost-beneficial SAMAs by Entergy was appropriate. However, the NRC staff 

3 stated that the cost-beneficial SAMAs do not relate to adequately managing the effects of aging 

4 during the period of extended operation and, therefore, do not need to be implemented as part 

5 of license renewal.

6 The State of New York filed several contentions regarding the license renewal application, 

7 including NYS-35, which contended that Entergy’s SAMA cost-benefit analysis was incomplete, 

8 and NYS-36, which contended that the NRC staff either require implementation of 

9 cost-beneficial SAMAs before issuing a renewed license or provide its rationale for not requiring 

10 their implementation.

11 In June 2010, the Atomic Safety and Licensing Board Panel (ASLBP) issued Order LBP-10-13 

12 granting admission of NYS-35 and consolidating it with NYS-36 (ASLBP 2010). In its decision, 

13 the ASLBP noted the following:

14 The NRC Staff’s obligation regarding SAMAs under NEPA and Part 51 is 

15 met by taking a hard look at those SAMAs identified as potentially cost16 beneficial. While the only SAMAs that an applicant must implement as 

17 part of a license renewal safety review are those dealing with aging 

18 management, an order by the NRC Staff to implement SAMAs not dealing 

19 with aging management can be issued concurrently as part of a Part 50 

20 CLB review. Consistent with the mandate of the Administrative 

21 Procedure Act (APA) and NEPA, if properly carried out, the NRC Staff’s 

22 hard look analysis of all potentially cost-beneficial SAMAs under NEPA 

23 and Part 51 (not just those that are aging-related) ensures that it has 

24 given proper consideration to all relevant factors in granting a license 

25 renewal.

26 In January 2011, the State of New York filed a motion for summary disposition, requesting that 

27 the ASLBP deny Entergy’s application for a renewed license because both Entergy’s and the 

28 NRC staff’s analyses of cost-beneficial SAMAs were not adequate.

29 In July 2011, the ASLBP granted New York State’s Motion for Summary Disposition (and denied 

30 Entergy’s and the NRC’s motions) regarding contention NYS-35/36 (ASLBP 2011) ordering the 

31 following:

32 Entergy’s licenses cannot be renewed unless and until the NRC Staff 

33 reviews Entergy’s completed SAMA analyses and either incorporates the 

34 result of these reviews into the FSEIS or, in the alternative, modifies the 

35 FSEIS to provide a valid reason for recommending the renewal of the 

36 licenses before the analysis of potentially cost-effective SAMAs is 

37 complete and for not requiring the implementation of cost-beneficial 

38 SAMAs.

39 Entergy appealed the ASLBP’s decision to the Commission; however, in December 2011, the 

40 Commission found that the appeal was interlocutory (NRC 2011). The Commission noted the 

41 following:

42 NEPA is a procedural statute—although it requires a “hard look” at 

43 mitigation measures, it does not, in and of itself, provide the statutory 

44 basis for their implementation. In granting New York’s motion for 

45 summary disposition of Contention NYS-35/36, the Board was careful not 

46 to require that the Staff impose the cost-beneficial SAMAs as a condition 

47 on the renewal of Entergy’s licenses. Rather, it provided the Staff with an 
Revised SAMA Engineering Project Cost Estimates

7

1 option to explain further its reasoning for not requiring implementation of 

2 cost-beneficial SAMAs in the context of this license renewal review. To 

3 the extent the Board would have the Staff elaborate on its analysis, the 

4 Board’s decision, in our view, does not appear patently unreasonable.

5 By letter dated May 6, 2013 (Entergy 2013b), Entergy submitted the results of completed, 

6 refined engineering project cost estimates for those SAMAs that it previously determined to be 

7 potentially cost beneficial. As a result of the refined cost estimation, Entergy determined that 

8 6 of the 22 SAMAs were no longer cost beneficial. Entergy also stated that it has elected to 

9 voluntarily implement four of the cost-beneficial SAMAs but to defer implementation of the 

10 remaining 12 cost-beneficial SAMAs until resolution of certain issues, such as actions required 

11 in response to NRC Order EA-12-049, “Order to Modify Licenses with Regard to Requirements 

12 for Mitigation Strategies for Beyond-Design-Basis External Events.”

13 Entergy did not adjust the benefit for the remaining potentially cost-beneficial SAMAs to account 

14 for implementation or planned implementation of the four cost-beneficial SAMAs. As noted in its 

15 letter, Entergy stated that “certain SAMA candidates are acting on the same accident 

16 sequences. Therefore, as certain SAMAs (or post-Fukushima Dai-ichi actions) mitigating the 

17 dominant accident sequences are implemented, the baseline risk, as calculated, is reduced. 

18 This reduces the likelihood that other SAMA candidates acting on the same accident sequences 

19 will remain potentially cost-beneficial” (Entergy 2013b).

20 By letter dated November 22, 2013, the NRC requested that Entergy provide additional detailed 

21 information describing the revised engineering project cost estimates (NRC 2013c). By letter 

22 dated January 2, 2014, Entergy provided detailed engineering project cost estimates for each of 

23 the 22 previously identified, potentially cost-beneficial SAMAs (Entergy 2014a).

24 3.1.2 Entergy’s Completed Engineering Project Cost Estimates

25 As a result of its SAMA analysis, which the NRC staff found acceptable in the 2010 FSEIS, 

26 Entergy found that 22 SAMAs would be potentially cost beneficial (Entergy 2009b). For each of 

27 these SAMAs, Entergy provided a detailed project cost estimate (Entergy 2014a). The 

28 estimates include a description of the proposed modification, along with a preliminary materials 

29 list, an impact screening summary, conceptual design sketches (if applicable), and a cost 

30 estimate. The cost estimate includes a summary of the assumptions, a cost estimate summary, 

31 and a detailed implementation estimate worksheet. Entergy compared the refined engineering 

32 project cost estimates to the benefits previously calculated for the SAMAs identified in 2009 as 

33 being potentially cost beneficial (Entergy 2009b, 2013b).

34 Entergy’s refined cost estimates include, as applicable, costs associated with the following:

35 • Entergy engineering support, including study, design, and project management;

36 • contract engineering support, including field engineers and planners;

37 • materials and equipment;

38 • plant craft labor;

39 • other Entergy support, including quality control (QC), training, and operations 

40 department; and

41 • other contract support, including security, health physics, and radwaste processing 

42 and storage.
Revised SAMA Engineering Project Cost Estimates

8

1 Entergy stated that the cost estimates are based on 2012 craft labor billing rates at IP2 and IP3

2 and are projected to 2014 by increasing the rates 3 percent per year (Entergy 2013b). 

3 However, in a letter dated November 20, 2014, Entergy clarified that the craft labor billing rates 

4 are from 2010 (Entergy 2014j). In addition, the estimates incorporate a site encumbrance 

5 premium (i.e., 20 percent) to reflect NRC-imposed site access restrictions, some of which were 

6 not in effect when the initial conceptual cost estimates were prepared (Entergy 2013b). In 

7 addition, each cost estimate incorporates project contingencies (i.e., 20, 30, 40, or 50 percent) 

8 to reflect the location and complexity of the work and consistency with guidance from the

9 Association for Advancement for Cost Engineering (AACE) International (Entergy 2013b). 

10 Lastly, the cost estimates include “loaders” of 30 percent, as explained below (Entergy 2014a).

11 3.1.3 Review of Entergy’s Refined Cost Estimates

12 The NRC staff reviewed the description of each proposed modification and compared it against 

13 the conceptual design sketches provided. The NRC staff confirmed that the cost estimates 

14 included costs for design, implementation, and materials appropriate for the design modification. 

15 The NRC staff then verified the reasonableness of the costs for materials by contacting several 

16 manufacturers or vendors noted in the literature provided by Entergy.

17 The NRC staff reviewed the assumptions listed in the Implementation Estimate and compared 

18 those assumptions with costs stated in the Implementation Estimate Work Sheet to see if there 

19 were any discrepancies. For example, an assumption might be that training will be provided for 

20 12 operations personnel. The NRC staff then reviewed the cost in the Implementation Estimate 

21 Work Sheet to confirm that a cost for training of 12 operations personnel was included.

22 The NRC staff reviewed all line items in the Implementation Estimate Work Sheet provided by 

23 Entergy to determine whether the description, level of effort, and cost for each activity of the 

24 proposed modification were reasonable. The staff compared similar activities from one 

25 proposed modification to those in a similar modification. For example, if the modification 

26 included installation of a concrete slab, the NRC staff confirmed that the labor, hours, and 

27 materials needed to install a concrete slab in one modification were similar to the labor, hours, 

28 and materials needed to install a concrete slab in another modification. In addition, the NRC 

29 staff compared assumptions, labor hours, labor rates, and material costs across the proposed 

30 modifications noting any discrepancies.

31 During its review of the refined cost estimates, the NRC staff noted some discrepancies or 

32 found that some practices were not explained or described in detail in the supporting 

33 documentation. In most instances, correction, inclusion, or exclusion of a particular cost did not 

34 alter Entergy’s conclusion about whether a SAMA is or is not potentially cost beneficial. 

35 However, when the missing or unexplained information was generic in nature or affected 

36 multiple SAMAs, the NRC staff requested additional information. The staff’s requests, and 

37 Entergy’s responses, are discussed below.

38 In its letter dated May 6, 2013, Entergy explained that the refined cost estimates “incorporate a 

39 site encumbrance premium to reflect NRC-imposed site access restrictions, including security 

40 and personnel access training and controls, some of which were not in effect when the initial 

41 conceptual cost estimates were prepared.” Entergy added a site encumbrance of 20 percent to 

42 the subtotal for each SAMA (Entergy 2013b). However, it did not provide the basis for the value 

43 used as the site encumbrance premium. The NRC staff also noticed that Entergy added the 

44 premium to the materials. Therefore, by letter dated October 6, 2014, the NRC staff issued a 

45 request for additional information (RAI) requesting that Entergy provide the basis for the value 

46 used for the site encumbrance premium and that it explain why it was levied against all aspects 

47 of the modification (NRC 2014h).
Revised SAMA Engineering Project Cost Estimates

9

1 In its response dated November 20, 2014, Entergy explained that site encumbrance premium 

2 represents the percentage increase over the normal time required to perform the work 

3 associated with a plant modification if the work was performed in a non-nuclear facility 

4 (Entergy 2014j). The value is based on site-specific and industry experience and is similar to 

5 the term “productivity/difficulty factor” that is used in Entergy fleet administrative procedures to 

6 improve the accuracy of the cost estimate based on the location of the work being performed. 

7 Entergy also explained that the encumbrance premium is applied to all aspects of the SAMA 

8 modification because site constraints affect all aspects of work performed within the Owner 

9 Controlled Area, such as transporting the materials through security checkpoints, receiving them 

10 in the warehouse, moving the materials through security fencing into the protected area and 

11 then possibly into a vital area within the protected area.

12 The NRC staff reviewed Entergy’s response and has determined that the application of 

13 encumbrance premium for the purpose of accounting for site access restrictions is reasonable. 

14 Entergy is required to have a physical security plan in place, including owner-controlled area 

15 searches and personnel access authorization requirements. Because all the proposed 

16 modifications affect systems or structures within the owner-controlled area, all persons 

17 performing work on, or delivering materials to, the site must go through various personnel 

18 access controls or vehicle searches. The inclusion of a cost factor to account for the additional 

19 burden associated with granting access to a licensed nuclear power plant versus a non-nuclear 

20 facility is reasonable.

21 In each of the refined cost estimates, provided by letter dated January 2, 2014, Entergy applied 

22 “loaders” of 30 percent (Entergy 2014a). The “loaders” were applied to the total after the 

23 contingency and site encumbrance premium were applied. However, Entergy did not provide 

24 an explanation for what is included in the “loaders,” nor did it provide a basis for the value. 

25 Therefore, by letter dated October 6, 2014, the NRC staff issued an RAI requesting that Entergy 

26 explain what the term “loaders” includes and that it provide the basis for the value used 

27 (NRC 2014h).

28 In its response dated November 20, 2014, Entergy explained that the 30-percent loader applied 

29 to the refined SAMA cost estimates accounts for the total sum of the estimated overhead costs 

30 for material loaders, capital suspense, and applied interest allowance for funds used during 

31 construction (Entergy 2014j). It also stated that the site finance department determined the 

32 specific value and that its fleet administrative procedures for project cost estimating specify that 

33 estimates for capital projects should include applicable loaders. The NRC staff reviewed 

34 Entergy’s response and finds that inclusion of a loader is reasonable because this is a standard 

35 practice for Entergy plants that involve capital expenditures.

36 As noted in the individual Implementation Estimate Work Sheet for each SAMA 

37 (Entergy 2014a), Entergy applied a factor of 1.7 to the labor rates for work conducted during 

38 outages, but an explanation was not provided. Therefore, by letter dated October 6, 2014, the 

39 NRC staff issued an RAI requesting that Entergy provide a brief explanation of the use of this 

40 factor and the basis for the value used (NRC 2014h). In its response dated 

41 November 20, 2014, Entergy explained that the factor of 1.7 is a factor applied to craft labor 

42 hours associated with the installation phase of the modification for the SAMAs requiring outage 

43 work in the reactor containment building to account for time and productivity losses associated 

44 with the difficulty of working in the highly restricted containment area (Entergy 2014j). Entergy 

45 further explained that its cost-estimating template provides a table for the unit rate 

46 adjustments/difficulty factors for use during the estimating phase of the modification and that 

47 this table specifies a factor of 1.7 as a multiplier to use when performing work in the reactor 

48 containment building. The NRC staff reviewed Entergy’s response and finds that inclusion of a 

49 factor applied to craft labor hours for installation inside containment is reasonable. The NRC 
Revised SAMA Engineering Project Cost Estimates

10

1 staff acknowledges that work performed inside containment, particularly modifications, can be 

2 difficult due to space limitations, environmental conditions, and radiation hazards. Therefore, 

3 the NRC staff concludes that it is reasonable to account for productivity losses associated with 

4 such constraints.

5 During its review of the cost estimates in the Implementation Estimate Work Sheet for the 

6 22 SAMAs, the NRC staff noted that Entergy used various labor rates for the same labor 

7 category, but it did not provide an explanation for the labor categories. Because the NRC staff 

8 could not readily determine why different labor rates were used for the same labor category, it 

9 issued an RAI requesting an explanation of the differences in the labor rates used for the same 

10 labor category (NRC 2014h). In its response, Entergy made corrections to the labor categories 

11 and provided revised, corrected SAMA cost estimates (Entergy 2014j). Entergy stated that the 

12 percent changes in the cost estimates were small and ranged from a decrease of 1.44 percent 

13 to an increase of 3.90 percent; however, the revised cost estimates did not change its 

14 conclusions in its May 6, 2013, letter regarding the economic feasibility of the 22 SAMAs. The 

15 NRC staff reviewed Entergy’s response and finds that it is acceptable because Entergy provided 

16 corrected labor rates inflated to 2014 and revised corrected SAMA cost estimates (see

17 Table 3–1).

18 The table below contains a summary of the 22 previously identified, potentially cost-beneficial 

19 SAMAs; the estimated benefit with uncertainty; the previous estimated cost; and the refined cost 

20 estimate.

21 Table 3–1. Summary of Refined and Corrected Cost Estimates for 22 SAMAs

SAMAs Previously Determined To 

Be Cost Beneficial

Benefit with 

Uncertainty

Estimated 

Cost (2009)

Refined 

Estimated 

Cost (2013)

Corrected 

Estimated 

Cost (2014)

IP2-009 – Create a reactor cavity 

flooding system – Deferred

$13,363,217 $4,1000,000 $1,738,982 $1,741,724

IP2-021 – Install additional pressure 

or leak monitoring instrumentation 

for inter-system loss of coolant 

accidents (ISLOCAs) 

$4,408,109 $3,200,000 $4,607,051 $4,632,227

IP2-022 – Add redundant and 

diverse limit switches to each 

containment isolation valve

$2,255,716 $2,200,000 $7,685,460 $7,692,784

IP2-028 – Provide a portable dieseldriven battery charger$2,856,939 $938,000 $2,137,804 $2,154,767

IP2-044 – Use fire water system as 

backup for steam generator 

inventory

$4,948,485 $1,656,000 $3,046,418 $3,073,130

IP2-053 – Keep both pressurizer 

power-operated relief valve (PORV) 

block valves open

$1,388,873 $800,000 $1,467,848 $1,471,234

IP2-054 – Install flood alarm in the 

480 V switchgear room

$11,772,170 $200,000 $456,985 $458,843

IP2-056 – Keep residual heat 

removal (RHR) heat exchanger 

discharge motor operated valves 

(MOVs) normally open

$102,574 $82,000 $1,705,367 $1,704,938
Revised SAMA Engineering Project Cost Estimates

11

SAMAs Previously Determined To 

Be Cost Beneficial

Benefit with 

Uncertainty

Estimated 

Cost (2009)

Refined 

Estimated 

Cost (2013)

Corrected 

Estimated 

Cost (2014)

IP2-060 – Provide added protection 

against flood propagation from 

stairwell 4 into the 480 V switchgear 

room

$2,684,920 $216,000 $715,145 $721,303

IP2-061 – Provide added protection 

against flood propagation from the 

deluge room into the 480 V 

switchgear room

$5,799,982 $192,000 $933,981 $943,792

IP2-062 – Provide a hard-wired 

connection to a safety injection (SI)

pump form alternate safe shutdown 

system (ASSS) power supply

$1,789,822 $1,500,000 $1,624,840 $1,662,692

IP2-065 – Upgrade the ASSS to 

allow timely restoration of seal 

injection and cooling

$11,772,170 $560,000 $1,789,771 $1,859,587

IP2-GAG – Steam Generator safety 

gagging device (To be Implemented)

$13,000,000 $50,000 $458,617 $453,745

IP3-007 – Create a reactor cavity 

flooding system

$7,301,552 $4,100,000 $1,869,811 $1,874,933

IP3-018 – Route the discharge from 

the main steam safety valves 

through a structure where a water 

spray would condense the steam 

and remove most of the fission 

products

$14,637,545 $12,000,000 $35,676,701 $35,691,159

IP3-019 – Install additional pressure 

or leak monitoring instrumentation 

for ISLOCAs

$3,082,120 $2,800,000 $6,462,470 $6,369,223

IP3-052 – Open city water supply 

valve for alternative AFW pump 

suction (Implemented) 

$361,446 $50,000 $138,378 $138,378

IP3-053 – Install an excess flow 

valve to reduce the risk associated 

with hydrogen explosions (To be 

Implemented) 

$722,892 $228,000 $340,790 $344,599

IP3-055 – Provide hard-wired 

connection to an SI or RHR pump 

from the Appendix R bus 

(MCC 312A)

$5,903,118 $1,288,000 $1,589,189 $1,601,888

IP3-061 – Upgrade the ASSS to 

allow timely restoration of seal 

injection and cooling

$6,317,929 $560,000 $2,258,137 $2,282,668

IP3-062 – Install flood alarm in the 

480 V switchgear room

$6,317,929 $196,800 $494,175 $496,071

IP3-GAG – Steam Generator safety 

gagging device (To be Implemented)

$19,000,000 $50,000 $458,617 $453,745

Source: Entergy 2013b, 2014j; NRC 2010
Revised SAMA Engineering Project Cost Estimates

12

1 As indicated in its cost estimates and in its response to an NRC staff RAI, Entergy used 

2 all-inclusive man-hour contractor billing rates, which include factors, such as overhead, general 

3 and administrative costs, and profit. The NRC staff finds that the use of actual billed labor rates 

4 as inflated, for cost-estimating purposes, is a reasonable approach because the rates are 

5 known labor rates and they represent what will likely be charged for a future modification.

6 Entergy stated that it inflated the 2012 billed craft labor rates by 3 percent per year to 2014 

7 (Entergy 2014a). According to the Bureau of Labor and Statistics (BLS), compensation costs 

8 for private industry workers increased 2.3 percent over the year, and wages and salaries 

9 increased 2.3 percent for the current 12-month period ending September 2014 (BLS 2014). 

10 Although a 3-percent increase in labor rates is slightly higher than the current rate at which 

11 compensation costs and wages rose, the NRC staff does not believe that its use is 

12 unreasonable for the purposes of estimating costs for SAMAs. The use of a lower inflation 

13 factor would result in insignificant changes to the cost estimates and would not alter Entergy’s 

14 conclusions about the economic feasibility of the SAMAs.

15 In the Implementation Estimate Work Sheets for the 22 refined cost estimates, Entergy provided 

16 hourly rates for various activities conducted by Entergy plant personnel; however, the basis for 

17 these rates was not provided, nor did Entergy indicate for which year the labor rates were given. 

18 Therefore, by letter dated October 6, 2014, the NRC staff issued an RAI requesting that Entergy 

19 explain the basis for these hourly rates, what costs are included in the rates, and in terms of 

20 year, on which year the rates are based (NRC 2014h).

21 In its response dated November 20, 2014, Entergy explained that to allow flexibility to either 

22 subcontract the tasks to an engineering firm or perform the tasks using in-house engineering 

23 resources, it used contract engineering rates, which bound in-house engineering personnel 

24 rates (Entergy 2014j). Entergy also stated that the rates, which are all-inclusive man-hour billing 

25 rates, are based on 2012 and were not inflated to 2014 dollars. Entergy further stated that the 

26 rates do not include contingencies and Entergy loaders, which are applied above these values. 

27 Lastly, Entergy clarified that the quality assurance (QA) and health physics personnel rates 

28 should be $100 per hour, not $80 per hour, to reflect the assumption that it would subcontract 

29 the necessary QA and health physics tasks to a qualified outside firm. The revised cost 

30 estimates, as shown in Table 3–1, include this correction (Entergy 2014j). The staff reviewed 

31 Entergy’s response and finds that the rates used for activities presumably performed by Entergy 

32 plant personnel are reasonable. The rates were based on contractor engineering rates and 

33 bound Entergy’s engineering rates.

34 As noted in the Impact Screening Summary for several of the SAMAs (e.g., IP2-021, IP2-022, 

35 IP2-028, IP2-044), Entergy checked the Nuclear Analysis item as “YES,” indicating that the 

36 proposed modification involves changes to plant evaluations, Technical Specifications, 

37 Technical Requirements Manual, or a full 10 CFR 50.59 evaluation. However, for these noted 

38 SAMAs, Entergy did not include a cost for this activity. By comparison, for SAMA IP2-009, 

39 Entergy checked the Nuclear Analysis item as “YES” and included a cost of $81,000 

40 (675 hours) for “Tech Specs/FSAR, Analysis Calcs [calculations].” The NRC staff further 

41 noticed that, for other SAMAs (e.g., IP-054 and IP2-061), an assumption on the Implementation 

42 Estimate states that the estimate does not include funding for unreviewed safety questions or 

43 NRC submittals, but if required, the additional cost will be added. Because the same apparent 

44 activity was treated differently amongst the SAMAs, the NRC staff issued an RAI requesting 

45 Entergy to explain why this activity/task was treated differently for the SAMAs and to indicate 

46 whether a cost for such an evaluation should have been included (NRC 2014h).

47 Entergy explained that although the “Nuclear Analysis” box was checked YES for the SAMAs 

48 noted in the RAI, the evaluations are not expected to require significant Entergy resources or 
Revised SAMA Engineering Project Cost Estimates

13

1 regulatory agency review; therefore, they do not have an associated cost for this activity 

2 (Entergy 2014j). Entergy further explained that, in contrast, significant evaluations would be 

3 required for SAMA IP2-009; therefore, a cost of $81,000 was included. Lastly, Entergy 

4 explained that it did not need to change any cost estimates to address the NRC staff’s issue. 

5 The NRC staff reviewed Entergy’s response and finds that its explanation for exclusion of costs 

6 for nuclear analyses is sufficient and agrees that inclusion of costs deemed to be insignificant at 

7 this stage of the cost estimating is unnecessary.

8 Similar to the issue described above, for several of the SAMAs (e.g., IP2-028, IP2-053, 

9 IP2-062), on the Impact Screening Summary, Entergy checked the Simulator Impact item as 

10 “YES,” indicating that the proposed modification impacts or involves changes to the simulator. 

11 However, for these SAMAs, Entergy did not include a cost for this activity. In comparison, for 

12 SAMAs IP2-054, IP2-056, IP2-060, IP2-061, and IP3-062, the Simulator Impact item is checked 

13 “YES,” and a cost was included for “Simulator Changes.” Because the same apparent activity 

14 was treated differently amongst the SAMAs, the NRC staff issued an RAI requesting Entergy to 

15 explain why this activity/task was treated differently for the SAMAs and to indicate whether a 

16 cost for such an evaluation should have been included (NRC 2014h).

17 Entergy explained that for SAMAs, such as IP2-028, IP2-053, and IP2-062, for which only an 

18 operating procedure is affected, no additional costs for simulator changes were included. 

19 However, costs were included for simulator procedure changes under the “OPS/OPS Support”

20 line item (Entergy 2014j). Although not indicated by Entergy in its response, the NRC staff 

21 notes that Entergy did not alter any cost estimates as a result of its review and response. The 

22 NRC staff reviewed Entergy’s response and finds that it is acceptable because costs for 

23 changes to the simulator were appropriately included when necessary, and changes to 

24 procedures for the simulator were included when appropriate.

25 3.1.3.1 NRC Staff’s Review of Six SAMAs Identified as Not Cost Beneficial as a Result of 

26 Refined Cost Estimations

27 In its letter dated May 6, 2013, Entergy stated that as a result of the refined cost estimation, it 

28 determined that six of the 22 SAMAs previously identified as potentially cost beneficial are no 

29 longer cost beneficial. These SAMAs are IP2-021, IP2-022, IP2-053, IP2-056, IP3-018, and 

30 IP3-019 (Entergy 2013b). These determinations did not change as a result of Entergy’s 

31 corrections to costs in response to the NRC staff’s RAIs, as discussed earlier.

32 Because Entergy’s conclusion on the economic feasibility of these SAMAs changed from its 

33 conclusion in 2009, the NRC staff’s review of these six SAMAs is described below. A brief 

34 description of the proposed modification is given followed by the NRC staff’s observations about 

35 various aspects of the cost estimate that appeared to be errors, overestimations, or could not be 

36 readily understood. The NRC staff focused on these aspects because it believed they could 

37 potentially alter the estimated cost of the modification.

38 SAMA IP2-021

39 This modification involves the installation of pressure transmitters at nine intersystem 

40 loss-of-coolant accident (ISLOCA) paths to measure pressure changes within an isolation 

41 boundary and to transmit the information to a location outside containment for remote display 

42 and monitoring (Entergy 2013b). The original cost estimate was $3.2 million (Entergy 2009b). 

43 The refined cost estimate is $4.63 million, which exceeds the estimated benefit with uncertainty 

44 of $4.4 million by $224,000 (Entergy 2014j).
Revised SAMA Engineering Project Cost Estimates

14

1 NRC Staff Observations:

2 • On the Implementation Estimate Work Sheet for the QA/QC verification item, a cost 

3 of $15,000 is listed, but there is also a cost of $15,000 for a subcontractor. It is not 

4 clear what this additional $15,000 subcontractor cost is for. The similar SAMA for 

5 IP3 (IP3-019) does not include an additional subcontractor cost.

6 • On page 1 of the Implementation Estimate Work Sheet, Item 1 of the non-outage 

7 work appears to be a labor-only item, the cost being $2,466. However, a cost of 

8 $2,466 is also included as a material cost. In comparison, for SAMA IP2-009, the 

9 same item (“Gather material and stage tools and materials”) is only a labor cost; 

10 there is no materials cost for that line item.

11 • For the fire watch (during the outage), the FCTR (factor) is only 1.0, not 1.7. 

12 Because the work is being performed inside containment, a factor of 1.7 should have 

13 been used.

14 For these items, the NRC staff determined that, even if the cost estimate was decreased to 

15 remove the costs in the first two items or increased to reflect the factor of 1.7 for the fire watch 

16 in containment, the total cost would still be higher than the estimated benefit. However, as 

17 discussed in Section 3.1.3.4, there appears to be large uncertainty in the cost estimates; 

18 therefore, the NRC staff recommends that Entergy retain this SAMA for further consideration.

19 SAMA IP2-022

20 This modification involves the installation of limit switches to monitor the position of 22 check 

21 valves and 2 motor-operated valves within containment associated with an ISLOCA and to

22 transmit information on valve position to a remote location outside containment. Entergy 

23 determined that a retrofit of the valves to accommodate the switches would be very difficult; 

24 therefore, the modification includes new valves (Entergy 2013b). The original cost estimate was 

25 $2.2 million (Entergy 2009b). The refined cost estimate is $7.69 million, which exceeds the 

26 estimated benefit with uncertainty of $2.26 million by $5.44 million (Entergy 2014j).

27 NRC Staff Observations:

28 • For qualification testing of the valve, the largest and more costly valve is used.

29 • A cost range for the valves was given; however, in the cost estimate, the highest cost

30 for each valve is used.

31 • On the Implementation Estimate, Item 2 assumes that non-outage work will occur in 

32 2011, yet the labor rates for the non-outage work are presumably for 2014 because 

33 the labor rates are not different from those used for outage work, which is assumed 

34 to occur in 2014.

35 • There are hourly charges for nondestructive evaluation profile of the welds for the 

36 valves; however, there is also a subcontractor charge for non-destructive evaluation 

37 of $70,000.

38 For these items, the NRC staff determined that, even if the cost estimate was decreased to 

39 reflect testing of a smaller and less costly valve, the lower price in the cost range for the valves 

40 was used, the labor rates were reduced by 3 percent per year to 2011, and the subcontractor 

41 charge of $70,000 was eliminated, the total cost would still be higher than the estimated benefit 

42 and would not alter Entergy’s conclusion about the economic feasibility of the proposed 

43 modification.
Revised SAMA Engineering Project Cost Estimates

15

1 SAMA IP2-053

2 As described in Entergy’s May 6, 2013, letter, this SAMA undoes a previous modification to two 

3 pressurizer power-operated relief valve (PORV) block valves. The control circuit of the two 

4 PORV block valves will be modified to keep the valves open during normal plant operations. 

5 Previously, a modification was made that installed an interlock in each PORV block valve’s 

6 control circuit to keep it closed during normal operations. The modification will require a new 

7 10 CFR Part 50, Appendix R (fire protection), compliance analysis (Entergy 2013b). The 

8 original cost estimate was $800,000 (Entergy 2009b). The refined cost estimate is 

9 $1.47 million, which exceeds the estimated benefit with uncertainty of $1.39 million by $82,000 

10 (Entergy 2013b).

11 NRC Staff’s Observations:

12 • Item 7 of the Implementation Estimate assumes that a 10 CFR Part 50, Appendix R,

13 evaluation will cost $250,000 and will be performed by a contract person; however, in 

14 response to RAI 5l (Entergy 2008a), although Entergy acknowledged that a change 

15 to the fire protection program would be needed, it did not initially include $250,000 

16 for the evaluation.

17 • 1,700 hours of contractor design support are estimated. This seems high for what 

18 appears to be a relatively straightforward design (i.e., undo the previous 

19 modification).

20 The NRC staff acknowledges that any changes to a 10 CFR Part 50, Appendix R, fire protection 

21 program require evaluations; therefore, the staff does not disagree that a cost for an evaluation 

22 should be included. The NRC staff notes that for a SAMA for IP3 (SAMA IP3-053), which also 

23 involves a 10 CFR Part 50, Appendix R, evaluation, Entergy proposed the same cost of 

24 $250,000 for the evaluation. As an aside, the NRC staff notes that, even though Entergy stated 

25 in the assumptions for IP3-053 that a cost of $250,000 is included for the 10 CFR Part 50, 

26 Appendix R, evaluation, the actual cost estimate did not include the $250,000 cost 

27 (Entergy 2014a).

28 With regard to the seemingly large contractor design support effort to “un-install the 

29 modification” and “restore the original design” (Entergy 2014a), the NRC staff notes that 

30 contractor design support efforts for other proposed modifications that are “new” are on the 

31 order of 1,000 to 1,700 hours and that several are even less. A reduction in the contractor 

32 design support effort of 325 hours would reduce the total cost estimate to a value that would 

33 make the modification potentially cost beneficial.

34 As discussed in Section 3.1.3.4, there appears to be large uncertainty in the cost estimates; 

35 therefore, the staff recommends that Entergy retain this SAMA for further consideration.

36 SAMA IP2-056

37 This modification previously considered changes to plant procedures and required analytical 

38 confirmation to maintain two residual heat removal (RHR) heat exchanger discharge valves, 

39 which are normally open during normal plant operations (Entergy 2013b). Entergy subsequently 

40 determined that this change could not be implemented with the current system configuration 

41 without increasing the potential over-pressurization risk to the RHR heat exchangers and piping. 

42 Therefore, additional RHR system pressure relief valves are required (Entergy 2013b). The 

43 original cost estimate for SAMA IP2-056 was $82,000 (Entergy 2009b). The refined cost 

44 estimate is $1.7 million, which exceeds the estimated benefit with uncertainty of $103,000 by 

45 $1.6 million (Entergy 2013b).
Revised SAMA Engineering Project Cost Estimates

16

1 NRC Staff’s Observations:

2 • On the Implementation Estimate, Items 2 and 3 assume that the non-outage and 

3 outage work will be completed in 2012. However, the labor rates are presumably for 

4 2014 because the labor rates used are not different from those used for other 

5 SAMAs for which work was assumed to be conducted during 2014.

6 • A cost for a decontamination contractor ($10,000) has been included; however, a 

7 cost for radwaste has not been included. Although it is not clear whether radioactive 

8 waste will be generated as part of this modification, it is also not clear why a 

9 decontamination contractor is needed for this modification. The NRC staff notes that 

10 a decontamination contractor is proposed only for this SAMA and SAMA IP2-022, 

11 which does involve the replacement of existing valves.

12 For these items, the NRC staff determined that even if the cost estimate was decreased to 

13 reflect labor rates in 2012 and to remove the decontamination contractor cost of $10,000, the 

14 total cost would still be higher than the estimated benefit and would not alter Entergy’s 

15 conclusion about the economic feasibility of the proposed modification.

16 SAMA IP3-018

17 This modification involves the installation of a system or facility that captures the steam released 

18 from the main steam safety valves and that processes the steam to remove fission products 

19 (Entergy 2013b). There are a total of 20 main steam safety valves. The proposed modification 

20 consists of four large vessels (one for each main steam line), each enclosed in its own structure. 

21 Each vessel requires a piped water supply and pumps to spray the steam with water to 

22 condense the steam. Additional controls for maintaining the water level and its recirculation 

23 also would be needed, as well as electrical power for pumps, controls, heaters, and exhaust 

24 fans (Entergy 2013b). The original cost estimate was $12 million (Entergy 2009b). The refined 

25 cost estimate is $35.7 million, which exceeds the estimated benefit with uncertainty of 

26 $14.6 million by $21 million (Entergy 2013b).

27 This proposed modification is extensive, and the costs associated with it are large and most 

28 likely underestimated. Even with large uncertainty in the cost estimate, as discussed in 

29 Section 3.1.3.4, the NRC staff does not believe that Entergy’s conclusion about the economic 

30 feasibility of this modification will be altered.

31 SAMA IP3-019

32 This modification involves the installation of pressure transmitters at 15 ISLOCA paths to 

33 measure pressure changes within an isolation boundary and to transmit the information to a 

34 location outside containment for remote display and monitoring (Entergy 2013b). The original 

35 cost estimate was $2.8 million (Entergy 2009b). The refined cost estimate is $6.4 million, which 

36 exceeds the estimated benefit with uncertainty of $3.1 million by $3.3 million (Entergy 2013b).

37 NRC Staff’s Observations:

38 • On the Implementation Estimate Work Sheet for QA/QC verification, a cost of 

39 $15,000 is listed, but there is also a cost of $15,000 for a subcontractor. It is not 

40 clear what this additional $15,000 subcontractor cost is for.

41 • On page 1 of the Estimate Worksheet, Item 1 of the non-outage work appears to be 

42 a labor-only item, the cost being $2,466. However, a cost of $18,000 is also included 

43 as a material cost. For SAMA IP2-021, the material cost is $2,466. It is not clear

44 what comprises these material costs.
Revised SAMA Engineering Project Cost Estimates

17

1 • There is not a materials cost for “testing,” but there is one in IP2-021, which is the

2 similar SAMA for IP2.

3 • For the fire watch (during the outage), the FCTR (factor) is only 1.0, not 1.7. 

4 Because the work is being performed inside containment, a factor of 1.7 should have 

5 been used.

6 For these observations, the NRC staff determined that even if the cost estimate was decreased 

7 to remove the costs in the first two items or increased to reflect the factor of 1.7 for the fire 

8 watch in containment, the total cost would still be higher than the estimated benefit and would 

9 not alter Entergy’s conclusion about the economic feasibility of the proposed modification.

10 3.1.3.2 The NRC Staff’s Review of 16 Potentially Cost-Beneficial SAMAs

11 For the 16 SAMAs that Entergy identified as potentially cost beneficial, the NRC staff notes that 

12 only one, IP2-062, is slightly cost beneficial (i.e., cost beneficial by 10 percent). The remainder 

13 of the potentially cost-beneficial SAMAs are sufficiently cost beneficial such that most sensitivity 

14 studies would not render them not cost beneficial.

15 3.1.3.3 Sensitivity Analysis

16 Entergy stated that the cost estimates incorporate project contingencies consistent with AACE 

17 International’s Recommended Practice (RP) No. 18R-97, “Cost Estimate Classification System

18 – As Applied in Engineering, Procurement, and Constructions for the Process Industries” 

19 (Entergy 2013b). Entergy stated that although the AACE International’s recommended practice 

20 applies to process industries, Entergy judged the cost-estimating principles in the guidance to 

21 be “reasonable and appropriate for estimating nuclear power plant engineering project costs” 

22 (Entergy 2014j).

23 AACE International’s RP No. 18R-97 defines five classes of cost estimates—Class 1 through 5 

24 (AACE 2005). Class 5, which is the least developed cost estimate, is described as generally 

25 being “prepared for any number of strategic business planning purposes, such as but not limited 

26 to market studies, assessment of initial viability, evaluation of alternate schemes, project 

27 screening, project location studies, evaluation of resource needs and budgeting, long-range 

28 capital planning,” and have a wide range in accuracy. Class 4 cost estimates are “prepared for 

29 a number of purposes, such as but not limited to, detailed strategic planning, business 

30 development, project screening at more developed stages, alternative scheme analysis, 

31 confirmation of economic and/or technical feasibility, and preliminary budget approval or 

32 approval to proceed to next stage,” and have fairly wide accuracy ranges. For the refined cost 

33 estimates, Entergy classified all of the estimates as either Class 4 or Class 5 (Entergy 2014a).

34 Figure 1 of RP No. 18R-97 entitled, “Cost Estimate Classification Matrix for Process Industries,” 

35 suggests that the expected accuracy range for a Class 5 cost estimate, after application of 

36 contingency, can be low by -20 percent to -50 percent and high by +30 percent to +100 percent. 

37 In addition, for a Class 4 estimate, the typical accuracy ranges are -15 percent to -30 percent on 

38 the low side, and +20 percent to +50 percent on the high side.

39 Using the information from RP No. 18R-97, the NRC staff performed a sensitivity analysis 

40 assuming the accuracy range for Class 5 cost estimates to determine whether the uncertainty in 

41 the cost estimates would affect the outcome of the SAMA. The NRC staff used the highest high 

42 value of 100 percent and the lowest low value of 20 percent. The NRC staff applied the values 

43 to the total cost to be consistent with the approach taken by Entergy and with the guidance in 

44 RP No. 18R-97, which states that the accuracy range is determined after application of the 

45 contingency.
Revised SAMA Engineering Project Cost Estimates

18

1 Below is a summary table of the cost estimates.

2 Table 3–2. Summary of the NRC Staff Sensitivity Analysis

SAMAs Benefit with 

Uncertainty

Corrected Estimated 

Cost (2014)a

Estimated Cost 

if Low by 20%

Estimated Cost if 

High by 100%

IP2 SAMAs

IP2-009 $13,363,217 $1,741,724 $2,090,069 $870,862

IP2-021 $4,408,109 $4,632,227 $5,558,672 $2,316,114

IP2-022 $2,255,716 $7,692,784 $9,231,341 $3,846,392

IP2-028 $2,856,939 $2,154,767 $2,585,720 $1,077,384

IP2-044 $4,948,485 $3,073,130 $3,687,756 $1,536,565

IP2-053 $1,388,873 $1,471,234 $1,765,481 $735,617

IP2-054 $11,772,170 $458,843 $550,612 $229,422

IP2-056 $102,574 $1,704,938 $2,045,926 $852,469

IP2-060 $2,684,920 $721,303 $865,564 $360,652

IP2-061 $5,799,982 $943,792 $1,132,550 $471,896

IP2-062 $1,789,822 $1,662,692 $1,995,230 $831,346

IP2-065 $11,772,170 $1,859,587 $2,231,504 $929,794

IP2-GAG $13,000,000 $453,745 $544,494 $226,873

IP3 SAMAs

IP3-007 $7,301,552 $1,874,933 $2,249,920 $937,467

IP3-018 $14,637,545 $35,691,159 $42,829,391 $17,845,580

IP3-019 $3,082,120 $6,369,223 $7,643,068 $3,184,612

IP3-052 $361,446 $138,378 $166,054 $69,189

IP3-053 $722,892 $344,599 $413,519 $172,300

IP3-055 $5,903,118 $1,601,888 $1,922,266 $800,944

IP3-061 $6,317,929 $2,282,668 $2,739,202 $1,141,334

IP3-062 $6,317,929 $496,071 $595,285 $248,036

IP3-GAG $19,000,000 $453,745 $544,494 $226,873

Source: Entergy 2014j

3 As can be seen from Table 3–2, if the cost estimates are high by as much as 100 percent, then 

4 SAMAs IP2-021 and IP2-053 would become potentially cost beneficial. Similarly, if the cost 
Revised SAMA Engineering Project Cost Estimates

19

1 estimates are low by as little as 20 percent, then SAMA IP2-062 would no longer be potentially 

2 cost beneficial. The economic feasibility of no other SAMAs was affected by the sensitivity 

3 analysis.

4 The NRC staff performed other sensitivity analyses, such as eliminating the site encumbrance 

5 premium. The results of those sensitivity analyses are the same as the one presented in Table 

6 3–2 above—the economic feasibility of SAMAs IP2-021, IP2-053, and IP2-062 are the only 

7 SAMAs affected.

8 3.1.3.4 Conclusion of the NRC Staff’s Review of Entergy’s Refined Cost Estimates

9 Entergy developed a conceptual design and implementation cost estimates in accordance with 

10 its accepted design engineering practices. The cost estimates were based on actual billed labor 

11 rates that were adjusted to 2014 dollars. Entergy applied certain cost factors to account for 

12 NRC-imposed site access restrictions and overhead costs consistent with its fleet administrative 

13 procedures for project cost estimations. Additionally, Entergy included project contingencies 

14 consistent with AACE International guidance. In response to an NRC staff RAI, Entergy 

15 corrected the refined cost estimates. These corrections did not alter Entergy’s conclusion about 

16 the economic feasibility of the proposed modifications. The NRC staff finds Entergy’s use of 

17 AACE International Class 4 and Class 5 cost estimates, which are commonly used for project 

18 planning and viability screening, appropriate for the use in a SAMA cost-benefit analysis. 

19 Further, based on its review of the refined cost estimates, the NRC staff believes that the 

20 approach used and the costs provided are reasonable.

21 Based on the refined cost estimates, Entergy determined that 6 of the 22 SAMAs are no longer 

22 cost beneficial—SAMAs IP2-021, IP2-022, IP2-053, IP2-056, IP3-018, and IP3-019. The NRC 

23 staff reviewed these six SAMAs and identified some minor discrepancies or unexplained costs. 

24 However, the inclusion or exclusion of these costs would not alter Entergy’s conclusion about 

25 the economic feasibility of the proposed modifications.

26 Notwithstanding the reasonableness of Entergy’s cost estimates, the NRC staff believes that for 

27 two of the SAMAs that have been identified as no longer cost beneficial (IP2-021 and IP2-053), 

28 the incremental difference by which the SAMAs are not cost beneficial, when viewed in the 

29 context of uncertainties in the cost estimates, is too small to exclude them from further 

30 consideration. In this regard, the corrected refined estimated cost for SAMA IP2-021 is 

31 approximately $4.63 million. When compared to the benefit with uncertainty of $4.41 million, the 

32 SAMA is not cost beneficial by approximately $224,000, which represents less than a 5-percent 

33 difference. The corrected refined cost estimate for SAMA IP2-053 is approximately 

34 $1.47 million. When compared to the benefit with uncertainty of $1.39 million, the SAMA is not 

35 cost beneficial by approximately $82,000, which represents less than a 6-percent difference.

36 According to AACE International’s RP No. 18R-97, estimated costs for a Class 5 estimate can 

37 be high by as much as 100 percent or low by as much as 50 percent. Based on this large range 

38 of uncertainty, the staff recommends that Entergy retain SAMAs IP2-021 and IP2-053 for further 

39 consideration.

40 3.1.4 Review of Entergy’s Deferral of Certain Cost-Beneficial SAMAs Pending 

41 Implementation of Fukushima Dai-ichi Action Items

42 The NRC is conducting a comprehensive safety review of requirements and guidance 

43 associated with severe accident mitigation measures for all power reactors. On 

44 March 12, 2012, the NRC issued Order EA-12-049, “Order to Modify Licenses with Regard to 

45 Requirements for Mitigation Strategies for Beyond-Design Basis External Events” (NRC 2012b). 

46 That Order applies to all power reactors and requires additional measures and strategies by 
Revised SAMA Engineering Project Cost Estimates

20

1 licensees to increase the capability to mitigate certain beyond-design-basis events to assure 

2 adequate protection of public health and safety, including during extended loss of alternating 

3 current power events. The required strategies include additional ways to maintain or restore 

4 core cooling, containment, and spent fuel pool cooling capabilities.

5 As noted by Entergy, certain NRC-mandated actions, as well as the nuclear power industry’s 

6 initiatives to address the challenges faced at Fukushima Dai-ichi, are likely to have an impact on 

7 certain SAMA candidates previously found to be potentially cost beneficial. For instance,

8 Nuclear Energy Institute (NEI) report 12-06, “Diverse and Flexible Coping Strategies (FLEX) 

9 Implementation Guide,” identifies upgrading to low leak reactor coolant pump seals as a method 

10 to improve reactor coolant system inventory control (NEI 2012). Such an upgrade may address 

11 SAMAs IP2-065 and IP3-061 to upgrade the alternate safe shutdown system to allow timely 

12 restoration of seal injection and cooling. Therefore, Entergy states, and the NRC staff agrees, 

13 that any potential accident mitigation improvement achieved by these SAMAs may be 

14 addressed, at least in part, through the NRC’s generic process reviewing all plants’ current 

15 licensing bases regarding their ability to deal with beyond-design-basis events.

16 As identified by Entergy, other SAMAs potentially affected by ongoing Fukushima Dai-ichi action 

17 items include IP2-009 and IP3-007 to create a reactor cavity flooding system, IP2-028 to provide 

18 a portable diesel-driven battery charger, and IP2-044 to use the fire water system as backup to 

19 maintain steam generator inventory. These SAMAs involve actions to maintain reactor core 

20 cooling and inventory, including during extended loss of alternating current power events. The 

21 NRC staff agrees with Entergy that deferring further consideration of these SAMAs is 

22 reasonable to avoid redundancies that could arise between implementation of Order EA-12-049 

23 and implementation of these SAMAs.

24 Entergy has implemented the following SAMAs that were determined to be potentially cost 

25 beneficial: (1) IP3-052 to open the city water supply valve for alternative auxiliary feedwater

26 pump suction, (2) IP3-053 to install an excess flow valve to reduce the risk associated with 

27 hydrogen explosions, and (3) IP2 and IP3-GAG to install steam generator safety valve gagging 

28 devices.

29 In addition, Entergy asserts that the remaining six SAMAs that have been determined to be 

30 potentially cost beneficial should be deferred due to the likelihood that the benefits associated 

31 with these SAMAs will be substantially reduced due to the risk reduction achieved by 

32 implementing SAMAs IP3-052, IP3-053, IP2-GAG, and IP3-GAG, as well as the plant 

33 improvements associated with completing the required actions to respond to Order EA-12-049. 

34 These six remaining potentially cost-beneficial SAMAs include IP2-054 to install a flood alarm in 

35 the 480 volt switchgear room, IP2-060 to provide added protection against flood propagation 

36 from stairwell 4 into the 480-volt switchgear room, IP-061 to provide added protection against 

37 flood propagation from the deluge room into the 480- volt switchgear room, IP2-062 to provide a 

38 hard-wired connection to a safety injection pump from the alternate safe shutdown system 

39 power supply, IP3-055 to provide a hard-wired connection to a safety injection or RHR pump 

40 from the 10 CFR Part 50, Appendix R, bus (MCC 312A), and IP3-062 to install a flood alarm in 

41 the 480- volt switchgear room.

42 The NRC staff notes that when any SAMA that was previously determined to be potentially cost 

43 beneficial is implemented, the risk profile from which the SAMA analysis is derived will 

44 necessarily change. Therefore, after the initial SAMA analysis is completed, decisions to 

45 implement potentially cost-beneficial SAMAs should be viewed as a dynamic process. In the 

46 case of Entergy’s SAMA process, the implementation of the four SAMAs mentioned and the 

47 implementation of plant improvements associated with Order EA-12-049 will lower the plant’s 

48 risk profile and, therefore, will tend to lower the benefits associated with the remaining six 
Revised SAMA Engineering Project Cost Estimates

21

1 SAMAs previously determined to be potentially cost beneficial. Therefore, the NRC staff finds 

2 that Entergy’s decision to defer actions related to the implementation of certain SAMAs until the 

3 risk profile for each plant is reevaluated following the completion of both voluntary and required 

4 plant improvements designed to reduce the risk of a severe accident is reasonable.

5 3.1.5 Conclusions

6 The NRC staff has previously found Entergy’s SAMA analysis to be reasonable, as described in 

7 Section G.7 of the 2010 FSEIS. In a letter dated May 6, 2013, Entergy submitted revised cost 

8 estimates for SAMAs that were previously identified as potentially cost beneficial 

9 (Entergy 2013b). Based on the refined cost estimates, Entergy determined that 6 of the 

10 22 SAMAs that were previously determined to be potentially cost beneficial would no longer be 

11 cost beneficial. These SAMAs are identified as IP2-021, IP2-022, IP2-053, IP2-056, IP3-018, 

12 and IP3-019. The NRC staff reviewed Entergy’s revised cost estimates and identified some 

13 minor discrepancies or unexplained costs. The NRC staff has concluded that, for two of the 

14 SAMAs that were identified as no longer being cost beneficial (IP2-021 and IP2-053), the 

15 incremental difference by which the SAMAs are not cost beneficial is too small to exclude them 

16 from further consideration.

17 In addition to providing refined cost estimates, Entergy’s letter dated May 6, 2013, discussed the 

18 deferral of certain cost-beneficial SAMAs pending implementation of action items related to the 

19 NRC’s comprehensive safety assessment in response to the events impacting Fukushima 

20 Da-ichi (Entergy 2013b). The NRC staff reviewed the assessment of Entergy’s decision 

21 regarding deferring action for these SAMAs and concludes that it is reasonable to defer actions 

22 regarding SAMAs IP2-009, IP2-028, IP2-044, IP2-065, IP3-007, and IP3-061 because these 

23 SAMAs would act to reduce similar risks that are being addressed by NRC-issued 

24 Order EA-12-049 (NRC 2012b). In addition, the NRC staff agrees with Entergy that because of 

25 the dynamic nature of a SAMA analysis, it is reasonable to defer action on SAMAs IP2-054, 

26 IP2-060, IP2-061, IP2-062, IP3-055, and IP3-062 until the risk profile for each plant is 

27 re-evaluated following the completion of both voluntary and required plant improvements 

28 designed to reduce the risk of a severe accident.

29 The NRC staff concurs with Entergy’s identification of areas in which risk can be further reduced 

30 in a cost-beneficial manner through the implementation of SAMAs IP3-052, IP3-053, IP2-GAG,

31 and IP3-GAG, which were identified as being potentially cost-beneficial SAMAs. Given the 

32 small margin by which SAMAs IP2-021 and IP2-053 were determined to not be cost beneficial, 

33 the NRC staff has determined that further evaluation of these SAMAs by Entergy would be 

34 appropriate. However, neither these SAMAs, nor those being deferred, relate to adequately 

35 managing the effects of aging during the period of extended operation. Therefore, neither these 

36 SAMAs, nor any of the other SAMAs that have been determined to be cost beneficial, need to 

37 be implemented as part of license renewal pursuant to 10 CFR Part 54.

38 Revisions to the 2010 FSEIS Resulting from Entergy’s Completed 

39 Engineering Project Cost Estimates for SAMAs Previously Identified as 

40 Potentially Cost Beneficial

41 After line 5 on page 5-12 in Section 5.2.6 of the FSEIS, the following text is to be added:

42 5.2.6.1 Conclusions Based on Information Submitted after May 6, 

43 2013

44 In a letter dated May 6, 2013, Entergy submitted revised cost 

45 estimates for SAMAs previously identified as potentially cost 
Revised SAMA Engineering Project Cost Estimates

22

1 beneficial (Entergy 2013b). Based on the refined cost estimates, 

2 Entergy determined that 6 of the 22 SAMAs previously determined to 

3 be potentially cost beneficial were no longer deemed to be cost 

4 beneficial. These SAMAs are identified as IP2-021, IP2-022, IP2-053, 

5 IP2-056, IP3-018, and IP3-019. The NRC staff reviewed Entergy’s 

6 revised cost estimates and identified some minor discrepancies or 

7 unexplained costs. The NRC staff has concluded that for two of the 

8 SAMAs that were identified as no longer being cost beneficial 

9 (IP2-021 and IP2-053), the incremental difference by which the 

10 SAMAs are not cost beneficial is too small to exclude them from 

11 further consideration.

12 In addition to providing refined cost estimates, Entergy’s letter 

13 dated May 6, 2013, discussed the deferral of certain cost-beneficial 

14 SAMAs pending implementation of action items related to NRC’s 

15 comprehensive safety assessment in response to the events 

16 impacting the Fukushima Dai-ichi Nuclear Power Plant (Entergy 

17 2013b). The NRC staff reviewed Entergy’s assessment regarding 

18 deferring action for these SAMAs and concludes that Entergy’s 

19 determination to defer actions related to the implementation of 

20 SAMAs IP2-009, IP2-028, IP2-044, IP2-065, IP3-007, and IP3-061 is 

21 reasonable since these SAMAs would act to reduce risks that are 

22 similar to risks that are being addressed by NRC-issued 

23 Order EA-12-049 (NRC 2012b). In addition, the NRC staff agrees with 

24 Entergy that because of the dynamic nature of a SAMA analysis, it is 

25 reasonable to defer action on SAMAs IP2-054, IP2-060, IP2-061, 

26 IP2-062, IP3-055, and IP3-062 until the risk profile for each plant is 

27 reevaluated following the completion of both voluntary and required 

28 plant improvements designed to reduce the risk of a severe 

29 accident.

30 The NRC staff concurs with Entergy’s identification of areas in 

31 which risk can be further reduced in a cost-beneficial manner 

32 through the implementation of SAMAs IP3-052, IP3-053, IP2-GAG,

33 and IP3-GAG, which were identified as being potentially cost34 beneficial SAMAs. Given the small margin by which SAMAs IP2-021 

35 and IP2-053 were determined not to be cost beneficial, the NRC staff 

36 has determined that further evaluation of these SAMAs by Entergy 

37 would be appropriate. However, neither these SAMAs, nor those 

38 being deferred, relate to adequately managing the effects of aging 

39 during the period of extended operation. Therefore, they need not 

40 be implemented as part of license renewal pursuant to 

41 10 CFR Part 54.

42 After line 41 on page G-49 in Section G.7 of the FSEIS, the following text is to be added:

43 G.7.1 Conclusions Based on Information Submitted after May 6, 

44 2013

45 In a letter dated May 6, 2013, Entergy submitted revised cost 

46 estimates for SAMAs previously identified as potentially cost 

47 beneficial (Entergy 2013b). Based on the refined cost estimates, 

48 Entergy determined that 6 of the 22 SAMAs previously determined to 
Revised SAMA Engineering Project Cost Estimates

23

1 be potentially cost beneficial were no longer deemed to be cost 

2 beneficial. These SAMAs are identified as IP2-021, IP2-022, IP2-053, 

3 IP2-056, IP3-018, and IP3-019. The NRC staff reviewed Entergy’s 

4 revised cost estimates and identified some minor discrepancies or 

5 unexplained costs. The NRC staff has concluded that for two of the 

6 SAMAs that were identified as no longer being cost beneficial 

7 (IP2-021 and IP2-053), the incremental difference by which the 

8 SAMAs are not cost beneficial is too small to exclude them from 

9 further consideration.

10 In addition to providing refined cost estimates, Entergy’s letter 

11 dated May 6, 2013, discussed the deferral of certain cost-beneficial 

12 SAMAs pending implementation of action items related to NRC’s 

13 comprehensive safety assessment in response to the events 

14 impacting the Fukushima Dai-ichi Nuclear Power Plant (Entergy 

15 2013b). The NRC staff reviewed Entergy’s assessment regarding 

16 deferring action for these SAMAs and concludes that Entergy’s 

17 determination to defer actions related to the implementation of 

18 SAMAs IP2-009, IP2-028, IP2-044, IP2-065, IP3-007, and IP3-061 is 

19 reasonable since these SAMAs would act to reduce risks that are 

20 similar to risks being addressed by NRC-issued Order EA-12-049 

21 (NRC 2012b). In addition, the NRC staff agrees with Entergy that 

22 because of the dynamic nature of a SAMA analysis, it is reasonable 

23 to defer action on SAMAs IP2-054, IP2-060, IP2-061, IP2-062, IP3-055, 

24 and IP3-062 until the risk profile for each plant is reevaluated 

25 following the completion of both voluntary and required plant 

26 improvements designed to reduce the risk of a severe accident.

27 The NRC staff concurs with Entergy’s identification of areas in 

28 which risk can be further reduced in a cost-beneficial manner 

29 through the implementation of SAMAs IP3-052, IP3-053, IP2-GAG, 

30 and IP3-GAG, which were identified as being potentially cost31 beneficial SAMAs. Given the small margin by which SAMAs IP2-021 

32 and IP2-053 were determined not to be cost beneficial, the NRC staff 

33 has determined that further evaluation of these SAMAs by Entergy 

34 would be appropriate. However, neither these SAMAs, nor those 

35 being deferred, relate to adequately managing the effects of aging 

36 during the period of extended operation. Therefore, they need not 

37 be implemented as part of license renewal pursuant to 

38 10 CFR Part 54.

25

1 4.0 ENTERGY’S REPORTEDLY NEW INFORMATION FOR 

2 ENTRAINMENT AND IMPINGEMENT IMPACTS

3 This section addresses Entergy Nuclear Operations, Inc.’s (Entergy’s) February 19, 2014, letter 

4 and attached report prepared by AKRF, Inc. (AKRF) (Entergy 2014b; AKRF 2014), which 

5 Entergy stated contained new information, data, analyses, and observations that potentially 

6 change some of the U.S. Nuclear Regulatory Commission (NRC) staff’s conclusions in the 

7 2010 final supplement environmental impact statement (FSEIS), as supplemented in 

8 Supplement 1 (FSEIS Volume 4) in June 2013. Entergy asserted that this new information and 

9 analysis indicated that potential impacts to certain aquatic species as a result of projected 

10 entrainment and impingement at Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and 

11 IP3) during the license renewal period would change, but that the NRC staff’s general 

12 conclusion for aquatic resources would “not be affected by this submission.” The NRC staff had 

13 concluded in the FSEIS that those impacts were MODERATE. In reviewing Entergy’s 

14 submission, the NRC staff considered written statements in Entergy’s letter and AKRF’s report, 

15 explicit and implicit assumptions in the analysis, analytic methods, and other new material.

16 Entergy’s submission is a reassessment of the NRC staff’s analysis of the effects of 

17 impingement and entrainment at IP2 and IP3 on aquatic resources in the Hudson River. After 

18 reviewing Entergy’s submittal, the NRC staff concluded that it did not agree with all aspects of 

19 Entergy’s submission. This section summarizes the results of the NRC staff’s detailed review 

20 (see Appendix A) and discusses parts of AKRF’s analysis with which the NRC staff disagreed. 

21 The NRC staff attempted to reproduce AKRF’s analysis, requested the data needed to 

22 reproduce the analysis, found inconsistencies in those data, and requested corrected data. The 

23 NRC staff then conducted an independent analysis of the new data and other information.

24 In the 2013 FSEIS supplement, the NRC staff assessed what was then new and significant 

25 information on aquatic resources and presented its evaluation of this information, along with 

26 revisions to the text, tables, and figures in the 2010 FSEIS. The NRC staff’s evaluation in this 

27 second supplement is a “standalone” presentation that references information in previous 

28 FSEIS volumes, and does not contain redline-strikeout text, figures, or tables to replace 

29 information and statements presented in the 2010 FSEIS or 2013 FSEIS supplement. Except 

30 where it is necessary to differentiate between the volumes, the NRC staff collectively refers to 

31 the 2010 FSEIS, as modified by the 2013 FSEIS supplement, as the FSEIS in this chapter.

32 Background

33 By letter dated April 23, 2007, Entergy submitted an application and associated environmental 

34 report pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 54 and 

35 10 CFR Part 51, to renew the operating licenses for Indian Point Nuclear Generating Unit Nos. 2 

36 and 3 (IP2 and IP3), for review by the NRC. The NRC staff documented its findings related to 

37 the environmental review of Entergy’s license renewal application in Supplement 38 to 

38 NUREG-1437 (FSEIS, Volumes 1–3), issued in December 2010 (NRC 2010).

39 In 2011, the NRC staff received new data, analyses, and comments from several sources that, 

40 upon evaluation, resulted in changes to some of the NRC staff’s conclusions in the 2010 FSEIS. 

41 Two sources provided information that changed the NRC staff’s conclusions in the FSEIS 

42 regarding the effects of impingement and entrainment at IP2 and IP3. First, in comments to the 

43 NRC, dated March 29, 2011, Entergy (Entergy 2011c; AKRF 2011b) provided new information 

44 regarding the entrainment, impingement, and field data that it had previously provided to the 

45 NRC for its aquatic resource impact assessment in Entergy (2007b), a December 2007 
Assessment of Thermal Impacts

26

1 supplement to its license renewal application. Second, comments submitted on behalf of 

2 Entergy (Goodwin Proctor 2011; AKRF 2011a) on the FSEIS and the NRC staff’s Essential Fish 

3 Habitat Assessment contained related new information. In part, these documents corrected

4 some units in an Entergy (2008b) data submission that were used in the FSEIS. The NRC staff 

5 found that the new information necessitated some changes to the impingement and entrainment 

6 impact findings in FSEIS Sections 4.1.2 through 4.1.3 and Appendices H and I. In June 2013, 

7 the NRC staff issued a final supplement (Volume 4) to the FSEIS (NRC 2013b). The 

8 2013 FSEIS supplement included corrections to impingement and entrainment data that had 

9 been presented in the 2010 FSEIS, among other matters.

10 By letter dated February 19, 2014, Entergy (2014b) submitted a letter with an attached report 

11 (AKRF 2014), which Entergy stated contained new information that potentially changed the 

12 NRC staff’s conclusions in the FSEIS regarding IP2 and IP3 entrainment and impingement 

13 impacts on certain fish species, although its submission would not affect the NRC staff’s general 

14 conclusion. Entergy says that, as a result of the new information and the AKRF report, which 

15 relies on different data than that what was used in the FSEIS, the following findings for four fish 

16 species would change:

17 • blueback herring would change from Large to Small,

18 • hogchoker would change from Large to Moderate,

19 • rainbow smelt would change from Moderate-Large to Small, and

20 • white perch would change from Large to Small.

21 Entergy did not submit the underlying data for the AKRF report from which the NRC staff might 

22 independently verify the analysis.

23 The NRC staff, by letter dated August 28, 2014 (NRC 2014d), issued a request for additional 

24 information (RAI) based on its review of Entergy’s February 19, 2014 submittal. On 

25 September 16, 2014, the NRC staff held a conference call with Entergy to clarify its request 

26 (NRC 2014g), and on September 26, 2014, the NRC staff issued a revised letter requesting 

27 additional information (NRC 2014e) that replaced the August 28, 2014, letter to Entergy.

28 Entergy responded to the RAI in October 2014 (Entergy 2014i; ASA and AKRF 2014). In its 

29 quality assurance review of the data supplied by Entergy, the NRC staff found inconsistencies 

30 within the 2014 information and between the 2014 and 2008 information and data submissions. 

31 The NRC staff also found that it could not reproduce the intermediate analysis tables and results 

32 in the AKRF (2014) submission with the October 2014 data submitted by Entergy.

33 On November 24, 2014, the NRC staff sent Entergy a draft of second-round RAIs for 

34 clarification. On December 11, 2014; January 13, 2015; and February 12, 2015, the NRC staff 

35 conducted conference calls with Entergy and its biological contractors to clarify the data and the 

36 availability of data requested in the draft RAI (NRC 2015a, 2015d). On February 18, 2015, the 

37 NRC sent a second-round RAI to Entergy (NRC 2015b).

38 Entergy replied to the RAI with replacement data files and other information on April 6, 2015 

39 (Entergy 2015c). Attachments to the cover letter included a letter from Goodwin Proctor to 

40 Entergy (Goodwin Proctor 2015) and reports by Entergy’s biological contractors (Heimbuch et 

41 al. 2015; AKRF 2015) with specific RAI response information. Heimbuch et al. (2015) explained

42 the differences and inconsistencies in the information sent to the NRC in 2008 and 2014, and 

43 Entergy’s April 2015 submission included replacement data sets with corrected information. 

44 AKRF (2015) provided corrected tables of intermediate and final analysis results to replace the 

45 tables in Entergy’s original submission (AKRF 2014; Entergy 2014b).
Assessment of Thermal Impacts

27

1 The differences in the data sets result from the following: (1) the NRC staff requested that data 

2 be summarized by sampling week (also called river run), in response to which Entergy’s 

3 different contractors used different algorithms to assign individual samples to sampling week; 

4 (2) samples were coded to identify valid samples for subsequent analysis, but Entergy’s various 

5 contractors used somewhat different criteria to identify valid samples; (3) the NRC staff 

6 requested “total count” information, which was calculated somewhat differently for the 2008 and 

7 2014 data submissions; (4) some errors in data or programming resulted in differences in the 

8 number of samples, the volume sampled, or counts of fish in the 2007, 2008, and 2014 data 

9 submissions; and in some instances, particularly in the early years of the sampling programs, 

10 life stage categories (i.e, conversion of length categories into age classes) that the investigators 

11 consider synonymous today were handled differently. As a result, there was a 5.4 percent

12 difference between the data sets received in 2007 and 2008 and the data that the NRC staff 

13 received in 2014. These differences do not include the differences observed in the total counts 

14 (the 2014 data did not include the early life stages in the total count) and the differences 

15 observed in the age class. After the NRC staff obtained the final corrected data sets, it finalized 

16 its independent analysis of the new data.

17 Entergy’s New Information

18 Entergy’s (2014b) letter to the NRC identified “new information from regulators charged with 

19 overseeing fisheries that are relevant to NRC staff’s subsidiary findings for certain fish species” 

20 in the FSEIS, and summarized a report finding by Entergy’s contractor, AKRF (2014), attached 

21 to the letter with respect to “Entergy’s identification and correction of an inadvertent discrepancy 

22 in NRC staff’s use of certain Entergy data files to reach these subsidiary findings” regarding 

23 certain fish species in the FSEIS. This section summarizes information that Entergy (2014b) 

24 specifically identifies as new. Each summary is followed by the NRC staff’s assessment as to 

25 whether the information is new to the FSEIS and whether the information may change previous 

26 FSEIS conclusions. Section 4.3 addresses the AKRF technical report.

27 Entergy identified three sources of new information from “public documents issued by regulators 

28 after issuance of the FSEIS that bear directly on species analyzed by NRC staff in the FSEIS.” 

29 The information pertains to 2 species (blueback herring, Alosa aestivalis, and rainbow smelt, 

30 Osmerus mordax) of the 18 representative and important species (RIS) addressed by the 

31 NRC’s assessment of the effects of the entrainment and impingement at IP2 and IP3 on Hudson 

32 River aquatic resources. Entergy’s sources of information and its reasons for stating that the 

33 NRC staff should reconsider its assessment of the two species are as follows:

34 (1) The National Marine Fisheries Service’s (NMFS’s) listing determination for 

35 blueback herring (Volume 78 of the Federal Register (FR), page 48944

36 (FR 78 48944)) and the Atlantic States Marine Fisheries Commission (ASMFC) 

37 supporting material, which Entergy maintains “cannot readily be reconciled with a 

38 LARGE impact finding from a specific CWIS [cooling water intake system], and 

39 therefore suggest that reconsideration of that finding is warranted;”

40 (2) a New York State Department of Environmental Conservation (NYSDEC) review 

41 of the Hudson River blueback herring population and conclusion, in Entergy’s 

42 words, that “the population, although variable, was stable, even with existing 

43 mortality imposed through in-river fishing harvests,” which Entergy asserts 

44 underscores “the importance of reconsideration of a LARGE finding for blueback 

45 herring;” and

46 (3) a report by the National Oceanographic and Atmospheric Administration (NOAA) 

47 that a rainbow smelt “population has not existed in the Hudson River for several 
Assessment of Thermal Impacts

28

1 decades (at least), which in Entergy’s opinion cannot be reconciled with a finding 

2 of future LARGE impacts to that species during the license renewal period, and 

3 therefore suggest that reconsideration of that finding is warranted.”

4 Entergy’s New Information Source (1). In February 2014, Entergy (2014b) stated that the 

5 NMFS “considered, but ultimately refused to list as threatened or endangered, blueback herring, 

6 including within the Hudson River.” The NRC staff disagrees with Entergy’s characterization of 

7 NMFS’s findings. NMFS’s listing determination considered the two species of river herring—

8 alewife and blueback herring—and found that “both species are at low abundance compared to 

9 historical levels, and monitoring both species is warranted.” The NMFS found significant data 

10 deficiencies for both species and uncertainties associated with the available data. Further, 

11 although many restoration and conservation efforts are ongoing and new management 

12 measures are being initiated or considered, it is not possible to quantify the positive benefits for 

13 those efforts. Rather than refusing to list blueback herring as Entergy asserts, the NMFS 

14 concluded that “based on the best scientific and commercial information available, we have 

15 determined that listing blueback herring as threatened or endangered under the Endangered 

16 Species Act of 1973, as amended (ESA) is not warranted at this time.” Furthermore, the NMFS 

17 concluded that “[g]iven the uncertainties and data deficiencies for both species, we commit to 

18 revisiting both species in 3 to 5 years.” The NMFS further stated that the 3- to 5-year time 

19 period will allow for “time to complete ongoing scientific studies (e.g., genetic analyses, ocean 

20 migration patterns, climate change impacts) and for the results to be fully considered” and “for 

21 the assessment of data to determine whether the preliminary reports of increased river counts in 

22 many areas along the coast in the last 2 years represent sustained trends [78 FR 48994].” 

23 Thus, rather than “refusing” to list the species, NMFS postponed the listing decision until certain 

24 data deficiencies could be resolved and further analysis could be completed. Indeed, NMFS 

25 (2015) presently considers river herring to be a “Species of Concern” and “Candidate Species” 

26 for future listing. 

27 In late 2013, NMFS and the ASMFC formed a River Herring Technical Expert Working Group to 

28 assist them in developing more complete information on the species and invited participants in 

29 this Working Group from Federal Government agencies, State fish and wildlife agencies, East 

30 Coast Native American Tribes and First Nations, academic and scientific groups, fishery 

31 management councils, conservation and environmental groups, industry (e.g., hydropower and 

32 fishing), and recreational groups. The Technical Expert Working Group set up a web page on 

33 NMFS’s web site,

34 (http://www.greateratlantic.fisheries.noaa.gov/protected/riverherring/tewg/index.html), where it 

35 posts its activities and information.

36 In its letter, Entergy (2014b) stated that “NMFS and ASMFC ranked all cooling water intake 

37 structure impacts, such as I&E [impingement and entrainment], in conjunction with a variety of 

38 other industrial impacts that may occur throughout the species’ range, as a cumulative “medium 

39 low” threat to blueback herring throughout its range.” AKRF (2014) stated that in the listing 

40 document 

41 [...] NMFS concluded that water withdrawals and outfalls (including 

42 pumped storage, irrigation, thermal discharges, industrial pollutants and 

43 atmospheric deposition) collectively posed only a “medium low” threat to 

44 blueback herring. The number one threat was listed as “dams and other 

45 barriers”. Behind that, “climate change,” “water quality (chemical)”, 

46 “incidental catch”, and “predation”, ranked as medium threats. The 

47 NMFS’s findings are consistent with the change in impact conclusion for 

48 blueback herring of “Large” to “Small” for IP2 and IP3.
Assessment of Thermal Impacts

29

1 The NRC staff disagrees with Entergy and AKRF’s characterization. The NMFS listing 

2 determination presents tables of “qualitative ranking of threats” not only for blueback herring 

3 throughout its range but also for the four individual stock complexes that comprise the entire 

4 rangewide population: the Canadian, the northern New England, the southern New England, 

5 and the Mid-Atlantic stock complexes. Hudson River blueback herring belong to the southern 

6 New England stock complex. Threats are ranked numerically from 1 to 5 as follows: 1 – low, 

7 2 – medium/low, 3 – medium, 4 – medium/high, and 5 – high. 

8 The NMFS conclusions that AKRF cites are for the entire population of blueback herring, 

9 however, and not the southern New England stock complex to which Hudson River blueback 

10 herring belong. For the southern New England stock complex and the threat category “Water 

11 Withdrawal/Outfall (physical and temp.)” into which large cooling water withdrawals such as 

12 operation of IP2 and IP3 falls, the mean rank is 2.6, which is the third greatest of the 

13 22 potential threats ranked, and the mode rank is “2,3”, which indicates that the mode is equally 

14 split between medium/low and medium. The southern New England stock ranking is more 

15 appropriate for Hudson River blueback herring and higher than that characterized by Entergy 

16 and AKRF. This information does not support Entergy’s (2014b) statement that the NRC’s 

17 finding for blueback herring should be changed from Large to Small.

18 At this time, ASMFC expressed difficulty in parsing the relative magnitudes of the various 

19 threats to river herring. In its River Herring Benchmark Stock Assessment, ASMFC (2012a) 

20 observed:

21 Multiple factors are likely responsible for river herring decline such as 

22 overfishing, inadequate fish passage at dams, predation, pollution, water 

23 withdrawals, acidification, changing ocean conditions, and climate 

24 change. It is difficult to partition mortality into these possible sources and 

25 evaluate importance in the decline of river herring.

26 In its blueback herring factsheet summarizing the results of its investigations, ASMFC (undated) 

27 considers both “water withdrawal facilities” and “thermal and toxic discharges” as two of seven 

28 identified threats to blueback herring habitat. ASMFC’s recommendations to improve the 

29 habitat quality include “Alter water withdrawal rates or water intake velocities to reduce alosine 

30 mortality. Locate water withdrawal facilities along the river where impingement will be low.” 

31 These recommendations are directly related to the threat posed by water withdrawal facilities, 

32 such as IP2 and IP3.

33 Therefore, the NRC staff disagrees with Entergy’s (2014b) assertion that NMFS’s listing 

34 document for blueback herring (78 FR 48944) and ASMFC supporting material support a 

35 change in the NRC staff’s findings for this species from Large to Small. Entergy’s proposed 

36 change is supported by the AKRF analysis, which uses a different set of years than what was

37 used in the FSEIS. As a result of the new data and information that Entergy submitted in 

38 support of the AKRF report, the NRC staff reassessed impacts to blueback herring and other 

39 species. The results of the NRC staff’s independent analysis are summarized in Section 4.3.

40 Entergy’s New Information Source (2). Although Entergy (2014b) identified NYSDEC 

41 information separately from its new information source (1), the NYSDEC report on the status of 

42 New York river herring stocks, Hattala et al. (2011), was a submission to the ASMFC and much 

43 of the information appears as Hattala et al. (2012) in Volume 2 of the ASMFC (2012a, 2012b) 

44 river herring benchmark stock assessment that serves as supporting material for the NMFS

45 listing document (78 FR 48944). Entergy (2014b) identified both the listing document and the 

46 ASMFC (2012a, 2012b) report as new information source (1) although it essentially simply 

47 repeats information in Entergy’s new information source (2).
Assessment of Thermal Impacts

30

1 Hatalla et al. (2011) assessed the information from the Hudson River utilities’’ Beach Seine 

2 Survey (BSS, 1974 through 2009) and Fall Shoals Survey (FSS, 1979 through 2009) monitoring 

3 programs, the same sampling programs that were analyzed by the NRC staff in the FSEIS (see 

4 Section 2.2.5.3 of the 2010 FSEIS and Appendix A of this supplement for additional discussion 

5 of the various surveys conducted as part of the Hudson River Monitoring Program). They used 

6 a geometric mean young-of-year (YOY) index to assess trends in the Hudson River blueback 

7 herring and did not perform a regression analysis. The conclusion for blueback herring is 

8 identical in both documents, and was described in Hattala et al. (2012) as follows: 

9 From 1980 through 1994, the NYSDEC geometric mean YOY annual 

10 index for blueback herring averaged about 24 fish per haul, with only one 

11 year (1981) dropping below 10 fish per haul ... After 1994, the mean 

12 dropped to around 17 fish per haul, and then began the same high-low 

13 pattern observed for alewife. The [...] survey data indicate that yoy

14 blueback abundance was also higher in the 1970s and has declined 

15 erratically since then to the present. [Table and Figure references 

16 deleted.]

17 Furthermore, Hattala et al. (2012) observed:

18 The underlying reason for the wide variation in yoy river herring indices is 

19 not clear. The same erratic trend that occurs since 1998 is also evident 

20 for American shad (Hattala and Kahnle 2007). The trend in all three 

21 alosines may indicate a change in overall stability in the system.

22 This conclusion regarding stability is similar to the conclusion that the NRC staff reached.

23 In the Sustainable Fishing Plan for New York river herring stocks, Hattala et al. (2011) 

24 concluded that “[g]iven the inconsistent measures of stock status described above, we do not 

25 feel that the data warrant a complete closure of the Hudson River fishery at this time.” The 

26 NYSDEC therefore proposed a 5-year restricted fishery in the main-stem Hudson River, a 

27 partial closure of the fishery in tributaries, and annual stock monitoring, as well as a 

28 sustainability target for juvenile indices.

29 This information from NYSDEC contradicts Entergy’s (2014) statements that the NYSDEC finds 

30 “the blueback herring population, although variable, was stable” with “declining trend that neither 

31 NMFS, nor NYSDEC determined to be real.”

32 Entergy’s New Information Source (3). Entergy’s sources of new information and its reasons 

33 for stating that the NRC staff should reconsider the assessment of rainbow smelt are as follows:

34 A consortium of regulators, including from the National Oceanic and 

35 Atmospheric Administration, in conjunction with fisheries regulators from 

36 Massachusetts, New Hampshire and Maine (collectively, “NOAA”), 

37 performed a comprehensive analysis of the migratory range of rainbow 

38 smelt. NOAA employed current datasets, and determined that the 

39 anecdotal Hudson River population (in the 1870’s) has been effectively 

40 extirpated, in part because smelt’s habitat range long ago shifted north, 

41 and no longer includes the Hudson River (all, for identified reasons 

42 unrelated to I&E [impingement and entrainment]). See, e.g., Rainbow 

43 Smelt: An Imperiled Fish in a Changing World (2010); A Regional 

44 Conservation Plan for Anadromous Smelt (2012) (reporting its 

45 comprehensive data analysis from 2006 through 2012, including its 

46 analysis of Hudson River data collected by Entergy and its predecessors). 

47 NOAA’s determination that a population has not existed in the Hudson 
Assessment of Thermal Impacts

31

1 River for several decades (at least) cannot be reconciled with a finding of 

2 future LARGE impacts to that species during the license renewal period, 

3 and therefore suggest that reconsideration of that finding is warranted.

4 The NRC staff identified rainbow smelt as one of 18 representative important species (RIS) to 

5 use in assessing the impacts of IP2 and IP3 (NRC 2010). The NRC staff selected the 18 RIS 

6 from those species “[...] identified in past analyses conducted by NYSDEC, the NRC, and the 

7 current and past owners of IP2 and IP3. The RIS identified in this section are meant to 

8 represent the overall aquatic resource and reflect the complexity of the Hudson River 

9 ecosystem by encompassing a broad range of attributes, such as biological importance, 

10 commercial or recreational value, trophic position, commonness or rarity, interaction with other 

11 species, vulnerability to cooling system operation, and fidelity or transience in the local 

12 community” (NRC 2010). Once common in the Hudson River, rainbow smelt declined abruptly 

13 in the Hudson River after 1994. In the 1985 through 2011 data sets used in the weight of 

14 evidence (WOE) analysis (Appendix A), rainbow smelt YOY last occurred in the Long River 

15 Survey (LRS), Fall Shoals Survey (FSS), and Beach Seine Survey (BSS) in 1995, 1998 (one 

16 fish), and 1993, respectively, roughly midway through the period analyzed here. The Hudson 

17 River population appears to have been extirpated in the mid-1990s.

18 Although Entergy asserts that the extirpation of rainbow smelt from the Hudson River and a shift 

19 in the range of the species possibly due to climate change constitute new information, the NRC 

20 staff addressed these issues in the FSEIS (NRC 2010) and described the disappearance of 

21 rainbow smelt in the Hudson River as follows:

22 Once a prevalent fish in the Hudson River, an abrupt population decline in 

23 the Hudson River was observed from 1994, and the species may now 

24 have no viable population within the Hudson River. The last tributary run 

25 of rainbow smelt was recorded in 1988, and the Hudson River Utilities’ 

26 Long River Ichthyoplankton Survey show that PYSL essentially 

27 disappeared from the river after 1995 (Daniels et al. 2005). When 

28 present, the largest abundances of eggs and YSL occurred from 

29 Poughkeepsie to the Catskills, and the largest abundances of PYSL, 

30 YOY, and older individuals were distributed from approximately Yonkers 

31 to Hyde Park (Table 2-5, Figure 2-6). Rainbow smelt runs in the coastal 

32 streams of western Connecticut declined at about the same time as in the 

33 Hudson River (Daniels et al. 2005). Smelt landings in waters south of 

34 New England have dramatically decreased, although the reasons for this 

35 are unknown. Daniels et al. (2005) note slowly increasing water 

36 temperatures in the Hudson River and suggest that the disappearance of 

37 rainbow smelt from the Hudson River may be a result of global warming. 

38 Rainbow smelt were observed in both impingement and entrainment 

39 samples obtained from IP2 and IP3.

40 Therefore, the NRC staff finds that the information on extirpation of rainbow smelt from the 

41 Hudson River and a shift in the range of the species possibly due to climate change does not

42 constitute new information.

43 At the time when Indian Point Nuclear Generating Unit No. 1 (IP1), IP2, and IP3 were under 

44 construction and beginning operation, rainbow smelt were common in the Hudson River. The 

45 former owner of IP2 and IP3 included rainbow smelt, then called American smelt, in its 

46 Environmental Reports (Con Edison 1971a, 1971b) among ubiquitous species that “comprise 

47 the numerically most important species in the study area.” In a draft environmental impact 

48 statement for the effects of power plant operation on the Hudson River environment, CHGE et 
Assessment of Thermal Impacts

32

1 al. (1999) note that in the period 1974 through 1997, rainbow smelt larvae were the sixth most 

2 common of 44 species reported in Hudson River ichthyoplankton sampling.

3 Early on, government agencies and the Hudson River electric-generating utilities specifically 

4 identified Hudson River rainbow smelt as a target species for assessing the effects of power 

5 plant operation. The former owners of IP2 and IP3, along with owners of other operating power 

6 plants on the Hudson River (CHGE et al. 1999), included rainbow smelt among 17 selected 

7 (target) species (16 fish and one crab) for assessing the effects of power plant operation on 

8 Hudson River biology. The Atomic Energy Commission (AEC) (1972), the predecessor to the 

9 NRC, chose rainbow smelt as an indicator species for the effects of IP2 impingement and 

10 entrainment. The AEC (1972) found that “[t]hose species most likely to be affected include the 

11 tomcod, bay anchovy, blueback herring, alewife, American eel, smelt, American shad, white 

12 perch, and striped bass” and predicted that “[a]mong the anadromous fishes, the alewife, 

13 blueback herring, smelt, American shad, tomcod, and striped bass may be significantly affected 

14 by Plant operation.” 

15 Hudson River rainbow smelt were identified as a target species for assessing the effects of 

16 impingement and entrainment for several reasons. Rainbow smelt are among Hudson River 

17 fish species whose “recruitment rates and standing crops of several species may be appreciably 

18 lowered in response to the increased mortality caused by entrainment of eggs and larvae and of 

19 impingement of young-of-the-year” (AEC 1972). The AEC (1972) voiced concern not only 

20 because of the direct mortality from impingement and entrainment, but also because of changes 

21 in the food web that supports the indicator species. Changes due to entrainment that occur in 

22 planktonic and epibenthic invertebrates, which are the principal food organisms for many fishes, 

23 could affect the availability of the food for rainbow smelt and other fish populations (AEC 1972). 

24 For rainbow smelt and other vulnerable species, the increased mortality or decreased 

25 reproductive success would reduce their ability to endure additional mortality from other causes 

26 and result in distinct reductions in population size (AEC 1972). Rainbow smelt stocks are 

27 generally confined to their natal estuaries and nearby coastal areas. Therefore, it is unlikely that 

28 rainbow smelt of Hudson River origin contribute significantly to other coastal stocks or that other 

29 stocks would influence the abundance of the Hudson River population (CHGE 1999). The 

30 rainbow smelt population declined noticeably in the Hudson River after 1994 and it appears to 

31 have been extirpated sometime within the following 3 years.

32 The NRC staff disagrees with Entergy’s assertion that a population that “[...] has not existed in 

33 the Hudson River for several decades (at least) cannot be reconciled with a finding of future 

34 LARGE impacts to that species during the license renewal period.” The NRC staff defined its 

35 use of RIS in the FSEIS as follows:

36 The RIS identified in this section are meant to represent the overall 

37 aquatic resource and reflect the complexity of the Hudson River 

38 ecosystem by encompassing a broad range of attributes, such as 

39 biological importance, commercial or recreational value, trophic position, 

40 commonness or rarity, interaction with other species, vulnerability to 

41 cooling system operation, and fidelity or transience in the local 

42 community. 

43 The NRC staff’s use of RIS follows common practice and reflects the past use of RIS to assess 

44 impacts to Hudson River aquatic communities. The Hudson River is home to many species. 

45 For example, Waldman et al. (2006) found that as of 2005, 212 fish species had been reported 

46 from the Hudson River drainage; Strayer (2006) reported approximately 300 species of 

47 macrobenthic invertebrates alone from the tidal-freshwater portion of the Hudson River estuary;

48 and Cerrato (2006) reported 328 marine benthic species from the Lower Hudson River Bay 
Assessment of Thermal Impacts

33

1 Complex. Because all of these species cannot be analyzed, investigators select a small 

2 number of RIS to represent the entire aquatic community. 

3 The NRC staff explained its use of RIS in the FSEIS (NRC 2010, page 4–10):

4 Because the Hudson River estuary represents a complex system with 

5 hundreds of aquatic species, the NRC staff chose to focus its analysis of 

6 impact on a subset of RIS historically used to monitor the lower Hudson 

7 River (as indicated in Section 2.2.5.4 of this SEIS). By focusing on a 

8 subset of species that are representative of many of the species that exist 

9 in the lower Hudson River fish community, the NRC staff can more-easily 

10 analyze impacts to the Hudson River community, and the NRC staff can 

11 make use of a large body of sampling data compiled over many years. 

12 The NRC staff acknowledges that the simplification inherent in relying on 

13 RIS may introduce some additional uncertainty, but the NRC staff finds 

14 that the utility of the RIS approach (due to the availability of large, long15 term data sets; applicability to species with similar characteristics; and 

16 comparability to other Hudson River studies) in evaluating 

17 communitywide effects outweighs the uncertainties associated with 

18 using it.

19 The fate of an RIS helps inform the impact determination because it stands as a surrogate for 

20 other species in the aquatic community that share life history attributes. If an RIS was once 

21 abundant and has since been extirpated, it can stand as a warning to further investigate the 

22 other species sharing similar attributes that might also suffer adverse impacts. In this way, the 

23 RIS are sentinel species.

24 The NRC staff finds that Entergy’s asserted new information on rainbow smelt already had been 

25 taken into account by the NRC staff; therefore, it is not new information with regard to the 

26 FSEIS. Because both government agencies and the electric generating utilities identified 

27 rainbow smelt early in Hudson River monitoring as a vulnerable population that would serve as 

28 an indicator for a wide range of aquatic resources, knowledge of past impacts to this species 

29 can help predict future impacts to the greater Hudson River aquatic ecology. Knowledge that 

30 this species has been extirpated can help predict future impact of other similarly vulnerable 

31 species. Therefore, the NRC staff finds that the extirpation of Hudson River rainbow smelt does 

32 not warrant changing the finding from Moderate-Large to Small. Entergy’s proposed change is 

33 supported by the AKRF analysis, which uses a different set of years than what was used in the 

34 FSEIS. As a result of the new information that Entergy submitted in support of the AKRF report, 

35 the NRC staff reassessed impacts to rainbow smelt and other species. The results of the NRC 

36 staff’s independent analysis are summarized in Section 4.3.

37 NRC Staff’s Independent Analysis of the AKRF (2014, 2015) Reports and 

38 Updated Field Data

39 The AKRF (2014, 2015) reports update the NRC staff’s FSEIS aquatic impact analysis by 

40 incorporating newly available field data collected in the LRS, FSS, and BSS from 2006 through 

41 2011 to provide more current results. AKRF excluded data collected in those programs from 

42 1979 through 1984 that the NRC staff used in the FSEIS, partly justifying the exclusion as due 

43 to a change in sampling gear for the bottom and shoal strata in the FSS in 1984 and 1985 (no 

44 gear change occurred for the channel stratum) and partly due to interannual changes in the 

45 sample week numbers in the early years of the surveys. AKRF largely employed the methods 

46 that the NRC used in the FSEIS and found that using the altered data sets (1979 through 2005 
Assessment of Thermal Impacts

34

1 versus 1985 through 2011) changed the NRC staff’s (2010, 2013b) FSEIS findings for some 

2 species.

3 The NRC staff reviewed AKRF’s (2014, 2015) reports and conducted an independent analysis 

4 that considered the assumptions and methods in the FSEIS, AKRF’s comments and methods, 

5 and the updated data. The NRC staff’s present analysis appears in Appendix A and differs 

6 somewhat from the analyses in the FSEIS (NRC 2010, 2013b), Entergy’s (2014b) and AKRF’s 

7 (2014) submissions, and Entergy’s (2015c) and AKRF’s (2015) submissions in response to 

8 NRC staff (2015b) RAIs (Table 4–1). The NRC staff’s present independent analysis uses data 

9 from 1985 through 2011 for both the population trend analyses and for the regression and 

10 variability parameters used in the Monte Carlo strength of connection analysis, as does AKRF 

11 (2014, 2015), but it incorporates field data updated by Entergy following submission of the 

12 AKRF report (reviewed in Section 4.1). In addition, another difference between AKRF’s and the 

13 NRC staff’s analyses is that AKRF selected periods of consistent sampling based on sample 

14 week number, whereas the NRC staff uses month designations because of differences in the 

15 available data sets.

16 Table 4–1. Differences in Methodology among the FSEIS (NRC 2010, 2013b), Entergy 

17 (2015c; AKRF 2014, 2015), and the Present Analysis.

Method Analysis Feature

FSEIS

(NRC 2010,2013b)

Entergy (2015c; 

AKRF 2014, 2015) Present Analysis

Population 

Trends

Years of data 

analyzed

1979 through 2005 1985 through 2011 1985 through 2011

Survey sampling 

periods used

LRS: all weeks 

sampled

FSS: weeks 27 

through 43

BSS: weeks 22 

through 43

LRS: weeks 17 

through 27

FSS: weeks 29 

through 42

BSS: weeks 28 

through 42

LRS: May through 

July

FSS: July through 

October

BSS: July through 

October

Regression 

methods used

Linear and segmented 

regression adjusted 

based on an FSS gear 

change analysis; 

regression with and 

without extreme 

values

Linear and segmented 

regression; no FSS 

gear change analysis

Linear regression with 

and without extreme 

values; no FSS gear 

change analysis

Riverwide catch 

per unit effort 

(CPUE) 

calculation

Total catch (all 

sampling events all 

lifestages)/total 

volume sampled

Total young-of year 

caught within 

designated 

weeks/volume 

sampled

Total young-of-year 

caught within 

designated 

months/volume 

sampled

Utilities’ Riverwide 

Abundance Index 

years analyzed

1979 through 2005 1985 through 2011 1974 through 2011

Strength of 

Connection 

(SOC)

Years used for 

the estimated 

slope and 

standard error of 

RIS density and 

regression mean 

square error

1979 through 2005 1985 through 2011 1985 through 2011
Assessment of Thermal Impacts

35

Method Analysis Feature

FSEIS

(NRC 2010,2013b)

Entergy (2015c; 

AKRF 2014, 2015) Present Analysis

Years used to 

calculate the 

coefficient of 

variation of the 

population density

1979 through 2005 1985 through 1996 1985 through 2011

Levels of 

classification for 

SOC

Low or High Low or High Low or High or 

Unresolved

Conditional 

entrainment 

mortality rate 

(EMR) parameter 

values

Updated in NRC 

(2013b) due to error in 

units reported to NRC

Original NRC (2010) 

values, not updated 

as in NRC (2013b)

Updated in NRC 

(2013b) due to error in 

units reported to the 

NRC

Weight of 

Evidence

Impact levels Small, Moderate, and 

Large

Small, Moderate, and 

Large

Small, Moderate, 

Large, Unresolved, 

and results from 

NMFS (2015) 

biological opinion for 

threatened and 

endangered species.

1 In the FSEIS, the population trend analysis conducted by the NRC staff applies both linear and 

2 segmented regression on the 1979 through 2005 LRS, FSS, and BSS data. AKRF also used

3 both regression types in its analysis. The 2010 FSEIS states that the segmented regression 

4 analysis was used to account for possible delayed population responses. Indian Point Nuclear 

5 Generating Unit No.1 began operation in 1963 and was shut down on October 1, 1974; IP2 was 

6 initially licensed for operation on September 28, 1973; and IP3 was initially licensed for 

7 operation on December 12, 1975. Because several of the RIS live for decades, and because 

8 possible indirect effects through trophic and interspecific interactions take time, delayed 

9 population effects in the 1979 through 2005 population data are possible. Delayed effects, 

10 however, are less likely to appear 6 years later in the updated period of analysis of 1985 

11 through 2005; therefore, the NRC staff’s present independent analysis uses only linear 

12 regression to assess population trends. This differs from AKRF’s analysis, which generally 

13 followed the procedure although not exactly the reasoning in the FSEIS analysis. Further, in the 

14 FSEIS, the regression analyses are split (pre- and post-gear change) based on a determination 

15 of whether FSS population trends could be affected by a 1985 change in gear. The present 

16 analysis, with the exception of the utilities’ abundance indices, and AKRF’s (2014, 2015) 

17 analysis are based on data following the gear change, and both have eliminated the 

18 assessment of a potential gear-change effect in the FSS.

19 In the FSEIS, one of the riverwide measures of abundance, catch per unit effort (CPUE), was 

20 calculated for each RIS and sampling survey as the annual total fish caught for all life stages of 

21 that species, divided by the total volume sampled. AKRF (2014) suggested a potential 

22 confounding effect of sampling design changes with estimates of annual abundance. The NRC 

23 staff’s present analysis calculates the riverwide CPUE as the total YOY fish caught within the 

24 restricted sampling period divided by the volume sampled, which avoids potential confounding 

25 effects.

26 The new data (Entergy 2015c) includes utilities’ abundance indexes calculated from multiple 

27 sampling surveys for several RIS, whereas Entergy’s previous submittals included only one 
Assessment of Thermal Impacts

36

1 abundance index for each RIS for analysis in the FSEIS. In the present analysis, for each RIS

2 the NRC staff used the utilities’ abundance index associated with the survey that had the 

3 greatest median riverwide CPUE from 1985 through 2011 (Appendix A, Table A–3). 

4 In the FSEIS, riverwide population trends based on the abundance index used the years 1979 

5 through 2005. For the present analysis, the NRC staff used all available years 

6 (1974 through 2011) in the regression because the early data (1974 through 1979) were used in 

7 published studies elsewhere (e.g., Daniels et al. 2005; ASMFC 2007AS; O’Connor et al. 2012). 

8 As a result, in the present analysis more RIS population trends were analyzed using the LRS 

9 data than had been analyzed in the FSEIS. 

10 The FSEIS assumed that because Atlantic tomcod are winter spawners with young that migrate 

11 down the river and the LRS is the earliest survey in the year, the LRS would be appropriate only 

12 for Atlantic tomcod. In examining the data for the present analysis, the NRC staff found that 

13 based on the highest CPUE, sometimes the LRS is also the most appropriate index for other 

14 species. The LRS is the earliest sampling survey conducted, and it employs the smallest net 

15 mesh size. Also, the CPUE of YOY for any RIS is probably affected by the metamorphosis of 

16 the larvae to the YOY stage, and the high early numbers of YOY before the mortality that occurs 

17 before the start of other sampling programs. In contrast, the FSS and BSS, which occur later in 

18 the year, may sample YOY RIS when populations have been reduced by mortality and when 

19 catch efficiency may be reduced at the end of the sampling periods as fish grow and are more 

20 able to avoid the sampling gear. These processes would explain why the LRS is sometimes the 

21 most appropriate survey for calculating an abundance index for some RIS. In the present 

22 analysis, all available YOY RIS with greater than eight annual observations for any given 

23 sampling survey were analyzed for the population trend line of evidence. The NRC staff applied 

24 this criterion in both the FSEIS and the present analysis for determining which RIS population 

25 trends to analyze for the FSS and BSS data.

26 In its strength of connection (SOC) analysis, AKRF used the parameter values from the NRC 

27 staff’s 2010 FSEIS (2010) rather than the updated values from the 2013 FSEIS supplement

28 (2013b). The NRC staff’s independent analysis updates the SOC analysis by using the updated 

29 1985 through 2011 data for consistency of years across its analysis. Also, in selecting the River 

30 Segment 4 population trends to include in the SOC analysis, for each RIS the NRC staff chose 

31 the trend with the greatest median YOY CPUE among the Hudson River Estuary monitoring 

32 surveys using updated 1985 through 2011 data, which for two species was a different 

33 monitoring program than in the 2010 FSEIS (2010) or 2013 FSEIS supplement (2013b). In the 

34 present analysis, the NRC staff also included a category, “Unresolved” for those RIS for which a 

35 Population Trend line of evidence (LOE) could not be established and too little data were 

36 available to model the SOC. Previously, the FSEIS and AKRF’s analyses assumed the impact 

37 level to be Small where this occurred. The NRC staff’s analysis differs from AKRF’s in these 

38 ways.

39 The NRC staff finds that four species had statistically significant declines consistently across 

40 measures of abundance: American shad, Atlantic tomcod, blueback herring, and rainbow smelt

41 (Table 4–2). Of these RIS, blueback herring and rainbow smelt had a high SOC, and the NRC 

42 staff concludes that for these RIS there is a Large potential impact of IP2 and IP3 cooling 

43 system operation during the relicensing period. Three RIS show a variable population trend 

44 response across measures of abundance: bluefish, hogchoker, and white catfish. Of these 

45 RIS, only hogchoker had a high SOC. The WOE conclusion for hogchoker changed from Large 

46 in the FSEIS to Moderate in the present analysis because of a change in the population trend 

47 LOE. The change results from the difference in time periods considered. The present analysis 

48 does not include early years (1974–1984) when hogchoker abundance was relatively higher 

49 than in years common to both analyses (1985–2005) and includes later years (2006–2011) 
Assessment of Thermal Impacts

37

1 when abundance increased in some years (see Appendix A, Addendum A-1). Considering all 

2 years and all measures of abundance, the hogchoker population abundance curve appears to 

3 be “u-shaped,” which would explain the variable results of linear regressions used in the present 

4 population trend LOE.

5 Because of undetected declines in population trend combined with low SOC, the NRC staff 

6 concludes that license renewal would have a Small potential impact level for 10 RIS: alewife, 

7 American shad, Atlantic tomcod, bay anchovy, bluefish, spottail shiner, striped bass, weakfish, 

8 white catfish, and white perch. Because of undetected declines in population trend, combined 

9 with unresolved strength of connection, impacts could not be resolved for Atlantic menhaden, 

10 gizzard shad, blue crab, Atlantic sturgeon, and shortnose sturgeon. In the FSEIS, the NRC staff 

11 assigned species with unresolved SOC assessments a value of “Low” rather than ”Unresolved,” 

12 the same description that is used for an unresolved population trend LOE, because these 

13 species generally occurred in low numbers in entrainment and impingement samples. 

14 Assigning an impact level of “Low” to unresolved SOC assessment for these species in the 

15 FSEIS resulted in a final WOE impact of “Low.” Here, the lack of resolution in both LOEs is 

16 assigned a WOE impact value of “Unresolved” to make the decision rules for both LOEs the 

17 same, to remove an assumption in the SOC analysis, and to more clearly communicate a lack 

18 of resolution in the SOC analysis where it occurred. Differences in three individual species 

19 (alewife, weakfish, and white perch) conclusions for the level of impact between the current 

20 analysis and the FSEIS are related to the years of data used in the analysis, in a manner similar 

21 to that described above for hogchoker (Table 4–2).

22 Atlantic and shortnose sturgeon are both listed under the ESA. In Supplement 1 to the FSEIS, 

23 the NRC staff described the unresolved impacts to Atlantic and shortnose sturgeon as “Small.” 

24 No information has been received by the NRC staff that would further resolve the impact levels. 

25 In June 2013, the NRC (2013a) updated NUREG–1437, Generic Environmental Impact 

26 Statement for License Renewal of Nuclear Plants. Based on the guidance contained in the 

27 GEIS update, the NRC now expresses results for ESA-listed species not as Small, Moderate, or 

28 Large, but in language prescribed by the ESA. To be consistent with the NRC’s updated 

29 practice, the NRC staff’s new analysis incorporates the conclusions of NMFS’s biological 

30 opinion concerning the effects of IP2 and IP3 cooling water system operation on the 

31 endangered Atlantic and Shortnose sturgeon. As such, the biological opinion (NMFS 2013) 

32 concludes that the continued effects of impingement and entrainment at IP2 and IP3 are likely to 

33 adversely affect, but not jeopardize the continued existence of, both species, and the NRC staff 

34 incorporates the biological opinion conclusion in the WOE results for the two Federally listed 

35 species.

36 Table 4–2. Impacts of Impingement and Entrainment at IP2 and IP3 on Hudson River 

37 Representative Important Species in FSEIS, Entergy’s Analysis, and the Present Analysis

Species

FSEIS 

(NRC 2013b)

Entergy 

(2015)

Present 

Analysis

Alewife Moderate Small Small (d)

American Shad Small Small Small

Atlantic Menhaden Small(a)(b) Small(a)(b) Unresolved(a)(b)

Atlantic Sturgeon Small(a)(b) Small(a)(b) Likely to adversely affect(a)(b)(c)

Atlantic Tomcod Small Small Small

Bay Anchovy Small Small Small

Blueback Herring Large Small Large

Bluefish Small Small Small
Assessment of Thermal Impacts

38

Species

FSEIS 

(NRC 2013b)

Entergy 

(2015)

Present 

Analysis

Gizzard Shad Small(a)(b) Small(a)(b) Unresolved(a)(b)

Hogchoker Large Moderate Moderate

Rainbow Smelt Moderate-Large Moderate Large

Shortnose Sturgeon Small(a)(b) Small(a)(b) Likely to adversely affect(a)(b)(c)

Spottail Shiner Small Small Small

Striped Bass Small Moderate Small

Weakfish Moderate Small Small(d)

White Catfish Small Small Small

White Perch Large Small Small(d)

Blue Crab Small(a)(b) Small(a)(b) Unresolved(a)(b)

(a) Population Trend LOE could not be established.

(b) Strength of Connection could not be established using Monte Carlo simulation.

(c) From NMFS’s (2013) biological opinion. In Supplement 1 to the FSEIS, the NRC staff described the unresolved 

impacts to Atlantic and shortnose sturgeon as “Small.” No information has been received by the NRC staff that 

would further resolve the impact levels.

(d) Change in conclusion from FSEIS may be related to the difference in years of data used in the analysis.
39

1 5.0 NEW ENVIRONMENTAL ISSUES RESULTING FROM THE 

2 REVISION TO 10 CFR PART 51

3 In accordance with the requirements in Title 10 of the Code of Federal Regulations

4 (10 CFR) Part 51, “Environmental protection regulations for domestic licensing and related 

5 regulatory functions,” the U.S. Nuclear Regulatory Commission (NRC) staff prepared the final 

6 supplemental environmental impact statement (FSEIS) for Indian Point Nuclear Generating Unit 

7 Nos. 2 and 3 (IP2 and IP3) as a supplement to NUREG–1437, Generic Environmental Impact 

8 Statement for License Renewal of Nuclear Plants (GEIS) (NRC 2013a). The NRC staff 

9 originally issued the GEIS in 1996, and issued Addendum 1 to the GEIS in 1999. The GEIS 

10 established 92 separate issues for the NRC staff to consider. Of these issues, the NRC staff

11 determined that 69 are generic to all plants (Category 1), whereas 21 issues do not lend 

12 themselves to generic consideration (Category 2). Two other issues remained uncategorized: 

13 (1) environmental justice and (2) chronic effects of electromagnetic fields. These two issues 

14 must be evaluated on a site-specific basis. A list of all 92 issues can be found in Appendix B to 

15 10 CFR Part 51.

16 On June 20, 2013, the NRC published a final rule (Volume 78 of the Federal Register (FR), 

17 page 37282 (78 FR 37282)), which revised the agency’s regulations in 10 CFR Part 51.

18 Specifically, the final rule updated the potential environmental impacts associated with the 

19 renewal of an operating license for a nuclear power reactor for an additional 20 years. A 

20 revised GEIS (NRC 2013a), which updates the 1996 GEIS, provides the technical basis for the 

21 final rule. The revised GEIS specifically supports the revised list of issues in the National 

22 Environmental Policy Act of 1969, as amended (NEPA) (42 U.S.C. 4321 et seq.), and 

23 associated environmental impact findings for license renewal in Table B–1 in Appendix B to 

24 Subpart A of the revised 10 CFR Part 51. The revised GEIS and final rule reflect lessons 

25 learned and knowledge gained during previous license renewal environmental reviews. In 

26 addition, public comments received on the draft revised GEIS and rule and those received 

27 during previous license renewal environmental reviews were reexamined to validate findings on

28 existing environmental issues and to identify new ones.

29 The final rule identifies 78 environmental impact issues; 17 of these issues will require 

30 plant-specific analysis. The final rule consolidates similar Category 1 and 2 issues, changes 

31 some Category 2 issues into Category 1 issues, and consolidates some of those issues with 

32 existing Category 1 issues. The final rule also adds new Category 1 and 2 issues.

33 The final rule became effective July 22, 2013, after its publication in the Federal Register

34 (78 FR 37282). Compliance by license renewal applicants is required for license renewal 

35 Environmental Reports (ERs) submitted later than 1 year after publication (i.e., applications 

36 submitted after June 20, 2014). Because Entergy Nuclear Operations, Inc. (Entergy), submitted 

37 its ER before the effective date of the final rule, it is not required to submit an ER that complies 

38 with the final rule. However, under NEPA, the NRC must consider and analyze potentially

39 significant impacts, including impacts described in the final rule as new Category 2 issues and, 

40 to the extent there is any new and significant information, the potentially significant impacts 

41 described in the final rule as new Category 1 issues. Table 5–1 lists the environmental issues 

42 added to the scope of license renewal subsequent to publication of the FSEIS; the following 

43 sections document the NRC staff’s evaluation of those issues.
New Environmental Issues Resulting from the Revision to 10 CFR Part 51

40

1 Table 5–1. Revised 10 CFR Part 51 Issues

Issues 2013 GEIS 

Section Category

Air quality impacts (all plants) 4.3.1.1 1

Geology and soils 4.4 1

Effects of dredging on surface water quality 4.5.1.1 1

Radionuclides released to groundwater 4.5.1.2 2

Effects on terrestrial resources (noncooling system impacts) 4.6.1.1 2

Exposure of terrestrial organisms to radionuclides 4.6.1.1 1

Cooling system impacts on terrestrial resources (plants with 

once-through cooling systems or cooling ponds)

4.6.1.1 1

Exposure of aquatic organisms to radionuclides 4.6.1.2 1

Effects of dredging on aquatic organisms 4.6.1.2 1

Impacts of transmission line ROW management on aquatic resources 4.6.1.2 1

Human health impacts from chemicals 4.9.1.1.2 1

Physical occupational hazards 4.9.1.1.5 1

Minority and low-income populations 4.10.1 2

Cumulative impacts 4.13 2

Source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51; NRC 2013a

2 In addition to the issues identified in Table 5–1, the NRC staff has included in this supplement 

3 an updated evaluation of greenhouse gas (GHG) emissions at IP2 and IP3 and an analysis of 

4 the cumulative impacts of GHG emissions on climate. Although the NRC did not add the issues 

5 of GHG emissions and climate change as part of the update to Table B–1 in Appendix B to 

6 Subpart A of the revised 10 CFR Part 51, the Commission’s Memorandum and Order in 

7 CLI-09-21 direct the NRC staff to “include consideration of carbon dioxide and other GHG

8 emissions in its environmental reviews for major licensing actions under [NEPA]” (NRC 2009). 

9 Accordingly, the NRC staff conducts plant-specific analyses in each license renewal review of 

10 the impacts of GHG emissions over the course of the license renewal term (NRC 2013a).

11 Air Quality Impacts (All Plants)

12 The NRC approved a revision to its environmental regulations in 10 CFR Part 51, including 

13 revisions to the list of issues and associated environmental impact findings for license renewal 

14 in Table B–1 in Appendix B to Subpart A of the revised 10 CFR Part 51. With respect to air 

15 quality, the final rule amended Table B–1 by changing the issue, “Air quality during 

16 refurbishment (nonattainment and maintenance areas),” from a Category 2 (site-specific) issue

17 to a Category 1 (generic) issue and renamed the issue, “Air quality impacts (all plants).” The 

18 Category 1 issue, “Air quality impacts (all plants),” considers air quality impacts from continued 

19 operation and refurbishment associated with license renewal and has an impact level of SMALL. 
New Environmental Issues Resulting from the Revision to 10 CFR Part 51

41

1 The 2010 FSEIS (NRC 2010) considered the air quality impacts during refurbishment, but the 

2 air quality impacts from continued operation were not discussed. The discussion is revised 

3 below to address air quality impacts from continued operation during the license renewal term.

4 5.1.1 Revisions to Section 2.1.5.1, “Nonradioactive Waste Streams,” and 

5 Section 2.2.4.3, “Air Quality,” of the FSEIS

6 Section 2.2.4.3 of the 2010 FSEIS (NRC 2010) describes the ambient air quality in the region 

7 where IP2 and IP3 are located and in the vicinity of the site. The NRC staff (NRC 2014i) issued 

8 a request for additional information (RAI) requesting that Entergy identify any new and 

9 significant information pertinent to the Category 1 issue, “Air Quality impacts (all plants).” 

10 Entergy’s response (Entergy 2015a) provided updated information on IP2 and IP3 air permits 

11 and air quality designations in the region where IP2 and IP3 are located and new information on 

12 the air permit compliance history at IP2 and IP3. As a result of this information, the NRC staff

13 has updated Section 2.1.5.1 and Section 2.2.4.3 of the FSEIS as described below.

14 Lines 6-7 on page 2-23 in Section 2.1.5.1 of the FSEIS are revised as follows:

15 Emissions are managed in accordance with the combined IP2 and IP3 

16 air quality permits, 3-5522-00011/00026 and 3-5522-00105/00009, 

17 respectively (Entergy 2007a 2015).

18 After line 4 on page 2-30 in Section 2.2.4.3 of the FSEIS, the following text is to be added:

19 IP2 and IP3 are located in Westchester County, New York, which is 

20 part of the New Jersey–New York–Connecticut Interstate Air Quality 

21 Control Region (40 CFR 81.13). Air Quality Control Regions (AQCR) 

22 include inter/intrastate counties that share a common airshed. With 

23 respect to NAAQS, Westchester County is designated a 

24 nonattainment area for ozone (O3) and a maintenance area for 

25 carbon monoxide (CO) and particulate matter less than 2.5 microns 

26 in diameter (PM2.5).

27 Lines 6-8 on page 2-30 in Section 2.2.4.3 of the FSEIS are revised as follows:

28 The 50-mi (80-km) radius includes designated nonattainment areas for 

29 the ozone (O3) 8-hour standard, and particulate matter less than 

30 10 microns in diameter (PM10), and particulate matter less than 

31 2.5 microns in diameter (PM2.5) and designated maintenance areas 

32 for carbon monoxide (CO) and particulate matter less than 

33 2.5 microns in diameter (PM2.5).

34 Lines 11-26 on page 2-30 in Section 2.2.4.3 of the FSEIS are modified as follows:

35 The currently designated nonattainment areas for Connecticut 

36 counties within a 50-mi (80-km) radius of the site are as follows:

37 • Fairfield and New Haven*—O3 and PM2.5

38 • Litchfield—O3

39 The currently designated nonattainment areas for New Jersey 

40 counties within a 50-mi (80-km) radius of the site are as follows:

41 • Bergen, Essex, Hudson, Morris, Passaic, Somerset, and Union*—O3 and 

42 PM2.5

43 • Sussex*—O3
New Environmental Issues Resulting from the Revision to 10 CFR Part 51

42

1 The currently designated nonattainment areas for New York counties within a 

2 50-mi (80-km) radius of the site are as follows: 

3 • Bronx, Kings, Nassau, Orange, Queens, Richmond, Rockland, Suffolk, and 

4 Westchester*—O3 and PM2.5

5 • Dutchess and Putnam—O3

6 • New York*—O3, PM10, and PM2.5

7 Note that the counties labeled with an “*” are part of the EPA-designated 

8 “New York—New Jersey—Long Island Nonattainment Area” (EPA 2006a).

9 The currently designated nonattainment and maintenance counties for 

10 Connecticut, New Jersey, and New York counties within a 50-mi (80-km) radius of 

11 IP2 and IP3 are identified in Table 2–0.

12 Table 2–0. Nonattainment and Maintenance Areas for Connecticut, New 

13 Jersey, and New York Counties within a 50-mi (80-km) Radius of IP2 and IP3

State County

Designation

Nonattainment 

Area

Maintenance 

Area

Connecticut Fairfield O3 CO and 

PM2.5

Litchfield O3 CO 

New Haven O3 PM2.5

New Jersey Bergen O3 CO and 

PM2.5

Essex O3 CO and 

PM2.5

Hudson O3 CO and 

PM2.5

Middlesex O3 CO and 

PM2.5

Morris O3 PM2.5

Passaic O3 CO and 

PM2.5

Somerset O3 PM2.5

Sussex O3

Union O3 CO and 

PM2.5

Warren O3

New York Bronx O3 CO and 

PM2.5

Dutchess O3

Kings O3 CO and 

PM2.5
New Environmental Issues Resulting from the Revision to 10 CFR Part 51

43

State County

Designation

Nonattainment 

Area

Maintenance 

Area

Nassau O3 CO and 

PM2.5

New York O3 and PM10, CO and 

PM2.5

Orange O3 PM2.5

Putnam O3

Queens O3 CO and 

PM2.5

Richmond O3 CO and 

PM2.5

Rockland O3 CO 

Suffolk O3 CO 

Westchester O3 CO and 

PM2.5

Source: EPA 2015a

1 Lines 27-30 on page 2-30 in Section 2.2.4.3 of the FSEIS are revised as follows:

2 New York State air permits for IP2 and IP3, 3-5522-00011/00026 and 

3 3-5522-000105/00009, respectively, regulate emissions from boilers, 

4 turbines, and generators. These permits restrict nitrogen oxides 

5 (NOx) emissions to 23.75 tons (t) (22 metric tons (MT)) per year per 

6 station by restricting engine run time and fuel consumption.

7 The New York State Department of Environmental Conservation 

8 (NYSDEC) issued a combined IP2 and IP3 air permit (Air State 

9 Facility Permit No. 3-5522-00011/00026) in December 2014 (NYSDEC 

10 2015a). The air permit regulates air emissions from combustion 

11 sources at IP2 and IP3 and restricts nitrogen oxide emissions to 

12 24.5 tons (22.2 metric tons) per year. Permitted air emission 

13 sources at IP2 and IP3 include diesel generators, gas turbines, 

14 diesel fire pumps, and heating boilers. These are operated 

15 infrequently during testing and maintenance activities (Entergy 

16 2015a). NYSDEC Air State Facility Permits are issued to facilities 

17 that are not considered to be a major source of air pollutants (i.e., a 

18 source that directly emits or has the potential to emit 100 tons per 

19 year (91 metric tons per year) or more of a regulated pollutant);

20 therefore, IP2 and IP3 are considered minor air emission sources 

21 (Entergy 2015a; NYSDEC 2015b). IP2 and IP3 have been in 

22 compliance with the Air State Facility Permit and have not received 

23 any notice of violations over the last 5 years (2010 to 2014) (Entergy 

24 2015a; EPA 2015b).
New Environmental Issues Resulting from the Revision to 10 CFR Part 51

44

1 After line 2 on page 2-31 in Section 2.2.4.3 of the FSEIS, the following text is to be added:

2 EPA recommends that emission sources located within 62 mi 

3 (100 km) of a Class I area be modeled to consider adverse impacts 

4 (EPA 1992). Considering the distance to the nearest Class I area 

5 and the minor amount of air emissions from the site, there is little 

6 likelihood that ongoing activities at IP2 and IP3 adversely affect air 

7 quality and air quality-related values (e.g., visibility or acid 

8 deposition) in any of the Class I areas.

9 5.1.2 Revisions to Section 3.2.3, “Air Quality during Refurbishment (Nonattainment 

10 and Maintenance Areas)”

11 As a result of the change of the issue from Category 2 to Category 1 and updated information 

12 pertaining to the air quality designations in the region where IP2 and IP3 are located, the NRC 

13 staff has removed and revised its discussion in Section 3.2.3 of the IP2 and IP3 2010 FSEIS 

14 (NRC 2010) regarding air emissions resulting from refurbishment activities and is addressing

15 the impacts from continued operation and refurbishment associated with license renewal 

16 together in Section 5.1.3 of this supplement.

17 Lines 7-42 on page 3-9 and lines 1-5 on page 3-10 in Section 3.2.3 are deleted; these 

18 impacts are addressed in Section 5.1.3 of this supplement:

19 3.2.3 Air Quality During Refurbishment (Nonattainment and Maintenance 

20 Areas)

21 Air quality during refurbishment (nonattainment and maintenance areas) is a 

22 Category 2 issue. Table B–1 of Appendix B to 10 CFR Part 51, Subpart A, notes 

23 the following:

24 Air quality impacts from plant refurbishment associated with license 

25 renewal are expected to be small. However, vehicle exhaust 

26 emissions could be cause for concern at locations in or near 

27 nonattainment or maintenance areas. The significance of the 

28 potential impact cannot be determined without considering the 

29 compliance status of each site and the numbers of workers 

30 expected to be employed during the outage.

31 The May 14, 2008, RAI response from Entergy (Entergy 2008b) indicates that the 

32 replacement of reactor vessel heads and CRDMs for IP2 and IP3 will result in 

33 minor impacts to air quality. Citing the GEIS, Entergy states that the only 

34 potential sources of impacts to air quality would be (1) fugitive dust from site 

35 excavation and grading for construction of any new waste storage facilities and 

36 (2) emissions from motorized equipment and workers’ vehicles. Entergy indicates 

37 that the bulk of air quality impacts during the postulated refurbishment activity 

38 would result from exhaust emissions released by onsite motorized equipment and 

39 workers’ vehicles (Entergy 2008b). These effects include temporary increases in 

40 atmospheric concentrations of nitrogen oxides (NOx), carbon monoxide (CO), 

41 sulfur dioxide (SO2), volatile organic compounds (VOCs), ammonia, and 

42 particulate matter (PM). A table summarizing the attainment status of the counties 

43 within the immediate area of IP2 and IP3 shows nonattainment of the National 

44 Ambient Air Quality Standards (NAAQS) for 8-- ozone in Dutchess, Orange, 

45 Putnam, Rockland, and Westchester Counties. There is nonattainment of the 

46 NAAQS for particulate matter, 2.5 microns or less in diameter (PM2.5) in Orange, 
New Environmental Issues Resulting from the Revision to 10 CFR Part 51

45

1 Rockland, and Westchester Counties. Westchester County is designated as a 

2 maintenance county for CO. Based on a conservative assumption that 400 

3 additional vehicles would travel to and from the site each day during a 65-day 

4 outage period (conservative because Entergy projects that only 300 additional 

5 workers over 60 days could accomplish the replacement activities), Entergy 

6 estimated that air emissions of VOCs, CO, and NOx would increase by 0.95 tons 

7 (0.86 metric tons (MT)), 16.1 tons (14.6 MT), and 1.02 tons (0.926 MT), respectively 

8 (Entergy 2008b). The regulatory conformity thresholds for VOCs, CO, and NOx are 

9 50 tons (45 MT), 100 tons (90.7 MT), and 50 tons (45 MT), respectively, as indicated 

10 in 40 CFR 51.853(b). A comparison of Entergy’s conservative estimates for 

11 vehicle emissions versus the associated regulatory conformity levels indicates 

12 that none of the thresholds would be exceeded. Based on this analysis, the NRC 

13 staff finds that air quality impacts during the postulated reactor vessel head and 

14 CRDM replacement would be SMALL.

15 5.1.3 Category 1—Air Quality Impacts (All Plants)

16 As discussed in the 2013 GEIS (NRC 2013a), air emissions resulting from refurbishment 

17 activities at locations in or near air quality nonattainment or maintenance areas would be short 

18 lived and would cease after refurbishment activities are completed. Operating experience has 

19 shown that the scale of refurbishment activities has not resulted in exceedance of the de 

20 minimis thresholds for criteria pollutants. Furthermore, sources of air emissions during normal 

21 plant operation result from operation of fossil fuel-fired equipment, such as diesel generators, 

22 boilers, and fire pumps. Operation of fossil fuel-fired equipment must comply with State and 

23 local regulatory air quality permitting requirements. Fossil fuel-fired equipment is operated 

24 infrequently and for short duration during testing and maintenance and are generally low 

25 emitters of criteria pollutants. Therefore, the impacts on ambient air quality from the operation 

26 of this equipment are minimal.

27 The NRC staff (NRC 2014i) issued an RAI requesting that Entergy identify any new and 

28 significant information pertinent to the Category 1 issue, “Air Quality impacts (all plants),” and to 

29 describe Entergy’s air permit compliance history. In summary, Entergy responded 

30 (Entergy 2015a) that the New York State Department of Environmental Conservation 

31 (NYSDEC) issued a combined IP2 and IP3 air permit (Air State Facility Permit

32 No. 3-5522-00011/00026) in December 2014. Previously, IP2 and IP3 had separate air quality 

33 permits issued by NYSDEC. Permitted air emission sources at IP2 and IP3 include diesel

34 generators, gas turbines, diesel fire pumps, and heating boilers. These are operated 

35 infrequently during testing and maintenance activities (Entergy 2015a). Furthermore, IP2 and 

36 IP3 are considered minor air emission sources because emissions are below 100 tons

37 (91 metric tons (MT)) per year (NYSEDC 2015a). Over the previous 5 years (2010 to 2014), 

38 there have been no notices of violations associated with IP2 and IP3 air permits, and operation 

39 of these air emission sources is maintained within the opacity, fuel sulfur content, operational 

40 run times, and fuel usage limits established in the air permit (Entergy 2015a).

41 Entergy (Entergy 2008e, 2015a) indicated that refurbishment activities may include reactor 

42 vessel head and control rod drive mechanism replacement. Sources of air emissions from 

43 refurbishment activities would result from fugitive dust from site excavation and grading for 

44 construction of any new waste storage facilities, motorized equipment, and worker vehicles 

45 (Entergy 2008e). Fugitive emissions and exhaust emission from motorized equipment will be 

46 temporary, localized (occurring only in the immediate vicinity of construction areas), and short in 

47 duration. Therefore, worker vehicle exhaust emissions would be the main contributor to air 

48 quality impacts. With respect to the National Ambient Air Quality Standards (NAAQS), 
New Environmental Issues Resulting from the Revision to 10 CFR Part 51

46

1 Westchester County, where IP2 and IP3 are located, is designated a nonattainment area for 

2 ozone (O3) and a maintenance area for carbon monoxide (CO) and particulate matter less than 

3 2.5 microns (PM2.5). New York is part of the ozone transport region (OTR). The OTR is 

4 established in Section 184 of the Clean Air Act of 1970, as amended (CAA) 

5 (42 U.S.C. 7651 et seq.), and it requires those States in the OTR to take steps to control 

6 interstate transport of air pollutants that form ozone. Ozone is formed when nitrogen oxides and 

7 volatile organic compounds (VOCs) combine in the presence of heat and sunlight; hence, VOCs 

8 and nitrogen oxides are precursors that contribute to the formation of ozone.

9 U.S. Environmental Protection Agency (EPA) regulations at Subpart B of 40 CFR Part 93

10 require Federal agencies to conduct an applicability analysis if a proposed action occurs in a

11 NAAQS nonattainment area or maintenance area to determine whether emissions of criteria 

12 pollutants would exceed threshold emissions levels (40 CFR 93.153(b)). If threshold levels are 

13 exceeded, a conformity determination may need to be performed. As a result of the 

14 nonattainment and maintenance counties identified and OTR designation of New York, the 

15 increase in ozone precursors (VOCs and nitrogen oxides), carbon monoxide, and particulate 

16 matter emissions and their precursors (nitrogen oxides and sulfur dioxide) that may result from 

17 the additional workforce needed during refurbishment activities were estimated to determine 

18 whether emissions would be likely to exceed established threshold emission levels in 

19 nonattainment or maintenance areas.

20 Entergy estimates that an additional 500 peak workers (250 workers for each replacement) for 

21 60 days would be needed for refurbishment-related activities (Entergy 2008e). It is assumed 

22 that the additional workforce needed would travel from areas within the 50-mile (mi)

23 (80-kilometer (km)) radius of IP2 and IP3 (which is a reasonable assumption because IP2 and 

24 IP3 employees reside in Dutchess, Orange, Putnam, and Rockland Counties, which are within 

25 50 mi (80 km) of IP2 and IP3 (Entergy 2008e)), and each of the 500 workers would travel 

26 100 mi (160 km) daily commuting to and from IP2 and IP3. This travel would result in an 

27 estimated additional 500 vehicles and 50,000 vehicle mi (80,000 vehicle km) per day within the 

28 region and a total of 3,000,000 vehicle mi (5,000,000 vehicle km) during the 60-day 

29 refurbishment timeframe. Using the vehicle emission factors presented in EPA (2008) and Cai 

30 et al. (2013), this results in an additional 3.4 tons (3.1 MT) of VOC, 31.1 tons (28.2 MT) of 

31 carbon monoxide, 2.3 tons (2.1 MT) of nitrogen oxides, 0.08 tons (0.07 MT) of sulfur dioxide,

32 and 0.01 tons (0.01 MT) of PM5. The regulatory conformity thresholds for VOCs and nitrogen 

33 oxides for designated nonattainment areas are 50 tons (45 MT) and 100 tons (91 MT),

34 respectively (40 CFR 51.853(b)). The regulatory conformity threshold for carbon monoxide and

35 PM2.5 and precursors (nitrogen oxides and sulfur dioxide) for designated maintenance areas are

36 100 tons (91 MT) for each pollutant (40 CFR 51.853(b)). Therefore, the additional emissions 

37 from workers during refurbishment will not exceed the regulatory conformity thresholds. 

38 Consequently, the additional vehicular emissions from the additional workforce will not be 

39 significant.

40 The NRC staff did not identify any new and significant information related to air quality during its

41 review of the Entergy’s response to the NRC staff’s RAIs and other available information. 

42 Therefore, the NRC staff finds that there are no impacts beyond those discussed in the 

43 2013 GEIS, which concludes that the impacts to air quality during the license renewal term 

44 would be SMALL.
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1 Geology and Soils

2 Geology and Soils is a Category 1 (generic) issue. This section describes the current geologic 

3 environment of the IP2 and IP3 site and vicinity, including landforms, geology, soils, and seismic 

4 conditions, as well as the potential impacts of the proposed action (license renewal).

5 Physiography and Geology and Soils

6 The IP2 and IP3 site is located in Westchester County, New York. In Westchester County, the 

7 bedrock consists of closely folded igneous and metamorphic rocks. The principal bedrock units 

8 in the County are (1) the Fordham gneiss, (2) the Inwood Marble, and (3) the Manhattan schist. 

9 Outcrops of bedrock are numerous, but the bedrock surface in most of the county is covered by 

10 unconsolidated deposits of till and outwash of Pleistocene age that range in thickness from a 

11 few feet to as much as 200 feet (ft) (61 meters (m)) (Perlmutter 1960).

12 The IP2 and IP3 site is within the Manhattan Prong physiographic province and is bordered on 

13 the west by the Hudson River. The province includes a portion of Staten Island, all of 

14 Manhattan Island, a small portion of western Long Island, and most of Westchester County. 

15 The province is characterized as a belt of worn-down complex mountains now almost reduced 

16 to a plain. The ridges and valleys of the worn-down mountains trend north-northeast and 

17 south-southwest, giving the entire area a gently fluted surface of moderate relief. The maximum

18 relief is 800 ft (244 m) in the north, whereas in New York City, the relief is moderately low

19 (NYSDOT 2013).

20 The topography is predominantly controlled by bedrock overlain with by glacial and alluvial

21 deposits. The geology of the bedrock is extremely complex. The rocks have been described as 

22 ancient sedimentary rocks that have been intensely metamorphosed, recrystallized, and 

23 thoroughly reorganized. Resistant rocks of schist, gneiss, and granodiorite form the ridges,

24 whereas marble, which is less resistant to erosion, forms the valleys. Numerous lakes and 

25 reservoirs that supply the Metropolitan New York City area dot the surface of central and 

26 western Westchester County (NYSDOT 2013).

27 The soils at the IP2 and IP3 site are formed from glacial deposits that overlay the bedrock. 

28 They are loamy soils that are often rocky to very rocky and occur on steep slopes. The IP2 and 

29 IP3 site was excavated into the bedrock with the areas between site structures generally 

30 covered with construction and fill material. Where possible, buffer zones were forested. 

31 A significant portion of the IP2 and IP3 site is urban land because the soils are not considered to 

32 be suitable for prime farmland. Soil stabilization measures and erosion preventive practices are 

33 in place to prevent erosion and sedimentation impacts to the IP2 and IP3 site and vicinity. Any 

34 site activity that disturbs one or more acres would require a construction storm water permit 

35 from NYSDEC. The construction storm water permit would specify any best management 

36 practices (BMPs) that should be taken to reduce soil erosion (Entergy 2015a; USDA 2015).

37 The Inwood Marble is the first bedrock unit encountered over most of the IP2 and IP3 site. It 

38 consists of metamorphosed beds of dolostones and limestones that steeply dip 30 to 

39 70 degrees to the southeast. Because the beds of the Inwood Marble are steeply dipping, it is 

40 found at a considerable depth beneath the IP2 and IP3 site. Near the IP2 and IP3 site, a 

41 measured section of rock recorded more than 830 ft (253 m) of Inwood Marble. The Inwood 

42 Mable is underlain by the Lowerre Quartzite and the Fordham Gneiss (Entergy 2014c, 2014d;

43 GZA 2008; Merguerian 2010; USNY 1970; Williams 2008). The bedrock units are fractured,

44 and the IP2 and IP3 site contains three known major groups of faults (GZA 2008).

45 With the exception of the Inwood Marble, the IP2 and IP3 site is not known to contain any 

46 economic geologic (mineral) or energy deposits. Just outside the southeast site boundary, the 
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48

1 Inwood Marble has been mined as a source of limestone (Verplanck Quarry). This quarry is no 

2 longer operational. On the opposite side of the Hudson River, the Inwood Marble unit is 

3 currently mined (Thomkins Cove Quarry) for use as aggregate (Applebome 2009;

4 Merguerian 2010; TILCON 2015).

5 Seismic Setting

6 The area around New York City and IP2 and IP3 has experienced ground shaking from 

7 earthquakes originating locally and in other areas in the State of New York. The area has also 

8 experienced shaking from earthquakes originating in Canada, Pennsylvania, New Jersey, 

9 Connecticut, Massachusetts, and the New Madrid area of Southern Illinois (USGS 2015b, 

10 2015c, 2015d, 2015e). Earthquakes with magnitudes as high as 5.2 have occurred throughout 

11 the lower Hudson region and in northern New Jersey. Since 1952, within a 50-mi (8-km) radius 

12 of the IP2 and IP3 site, earthquake magnitudes have ranged from 3.0 to 3.6 (Entergy 2015a). 

13 Although the largest earthquakes that have occurred in the New York City area since the 1930s 

14 were of about a magnitude 4, the longer historic record includes three earthquakes larger than a 

15 magnitude 5 (Sykes et al. 2008).

16 The area has a relatively low earthquake hazard, but because of the large population in the 

17 area, there is a high potential for an earthquake to affect many people (as opposed to areas of 

18 low population) (Sykes et al. 2008). Seismic hazard maps project that in any given 50-year 

19 period, there is a 2-percent chance the area will experience an earthquake that produces 

20 ground movement that exceeds 14 percent to 20 percent of a “G” (acceleration due to gravity) 

21 (USGS 2015a). Earthquake hazard maps by the Federal Emergency Management Agency 

22 indicate the area would likely experience moderate shaking from earthquakes. Moderate 

23 shaking would be felt by all of the populace. The shaking would result in slight damage, with 

24 some heavy furniture moved and with a few instances of fallen plaster (FEMA 2015).

25 Nuclear power plants, including IP2 and IP3, are designed and built to withstand site-specific 

26 ground motion based on their location and nearby earthquake activity. This seismic design 

27 basis is established during the initial siting process, using site-specific seismic hazard 

28 assessments. For each nuclear power plant site, applicants estimate a design-basis ground 

29 motion based on earthquake sources, wave propagations, and site responses, which is then 

30 accounted for in the design of the plant. In this way, nuclear power plants are designed to 

31 withstand the maximum credible earthquake for a given site. However, because methods of 

32 assessing seismic hazards evolve over time and scientific understanding of earthquake hazards 

33 improves (NRC 2014b), the NRC’s understanding of the seismic hazard for a given nuclear 

34 power plant may change over time. As new seismic information becomes available, the NRC 

35 evaluates the new information to determine whether any changes are needed at existing plants 

36 or to NRC regulations. The NRC’s evaluation of the impact of seismic activity on a nuclear 

37 power plant is an ongoing process that is separate from the license renewal process.

38 On December 23, 2011, the Consolidated Appropriations Act of 2012 (Public Law 112-74) was 

39 signed into law. Section 402 of the law directs the NRC to require reactor licensees to 

40 re-evaluate the seismic hazard at their sites against current applicable Commission 

41 requirements and thereafter, when appropriate, as determined by the Commission 

42 (NRC 2012a). In 2012, the NRC required all licensees to reevaluate the seismic hazards at 

43 their sites, using updated seismic information and present-day regulatory guidance and 

44 methodologies (NRC 2012a). The purpose of that request was to gather information to update 

45 the seismic hazards analysis to enable the NRC staff to determine whether individual site 

46 licenses should be modified, suspended, or revoked (NRC 2014a).

47 For those nuclear power plants for which the reevaluated seismic hazard exceeds the seismic 

48 design basis, licensees are required to implement interim seismic evaluations to demonstrate 
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49

1 whether the plant can cope with the higher seismic hazard, whereas longer-term seismic risk 

2 evaluations are ongoing. The goal of the long-term risk evaluations is to determine whether

3 there is sufficient seismic safety margin for beyond-design-basis ground motion so that the NRC 

4 can make risk-informed decisions (NRC 2014a). The NRC staff is currently reviewing Entergy’s 

5 interim seismic evaluation for IP2 and IP3 (Entergy 2014c, 2014d), with respect to ongoing 

6 facility operations outside of the license renewal process; the licensee is expected to complete 

7 its long-term seismic risk evaluation by June 30, 2017 (NRC 2014a).

8 The NRC staff has not identified any new and significant information during its review of 

9 Entergy’s RAI response or other available information. The NRC staff concludes that there are

10 no impacts beyond those described in the 2013 GEIS, which concludes that the impacts to 

11 geology and soils during the license renewal term would be SMALL.

12 Effects of Dredging on Surface Water Quality

13 Section 2.1.3 of the December 2010 FSEIS (NRC 2010) describes the surface water intake 

14 structures and related once-through cooling and auxiliary systems that support IP2 and IP3. 

15 Section 2.2.3, “Water Quality,” describes the general water quality of the Hudson River and the 

16 regulation of effluent discharges from IP2 and IP3 pursuant to the State Pollutant Discharge 

17 Elimination System (SPDES) permit administered by NYSDEC. Section 2.2.5, “Aquatic 

18 Resources,” of the 2010 FSEIS describes that historic and ongoing dredge and fill activities 

19 have altered the aquatic environment and have affected flow patterns in the Hudson River; 

20 these activities are likely to continue to have an impact on the river system. Section 2.2.5.2 

21 specifically notes that the U.S. Army Corps of Engineers (USACE) continues to maintain a 

22 shipping channel from the ocean to the Port of Albany and that dredging in some river segments 

23 occurs every 5 years.

24 The new Category 1 (generic) issue, “Effects of dredging on surface water quality,” considers 

25 the potential effects on surface water quality resulting from the dredging of sediment deposits. 

26 At nuclear power plant sites, dredging may be conducted in the vicinity of surface water intakes, 

27 canals, and discharge structures in order to remove deposited sediment and maintain the 

28 function of plant cooling systems. Dredging also may be needed to maintain barge shipping 

29 lanes. As discussed in the 2013 GEIS (NRC 2013a), commonly employed mechanical, suction, 

30 or other dredging techniques may affect surface water quality by temporarily increasing the 

31 turbidity of the water column, with associated effects on aquatic life. Dredging can also mobilize 

32 heavy metals, polychlorinated biphenyls (PCBs), or other contaminants in the sediments. The 

33 frequency of dredging depends on the rate of sedimentation. The effects of maintenance 

34 dredging are generally localized and short in duration (NRC 2013a).

35 When conducted, dredging operations are performed under permits issued by the USACE and 

36 often under permits from State and other agencies as well. The USACE regulates the 

37 discharge of dredged or fill material, or both, under Section 404 of the Clean Water Act of 1977, 

38 as amended (CWA) (33 U.S.C. 1251 et seq.). Further, Section 401 of the CWA requires that 

39 the applicant for a Section 404 permit also obtain a Water Quality Certification from the State in 

40 which the activity will take place to ensure that the activities will comply with applicable State 

41 water quality standards. The impact of dredging has not been found to be a problem at 

42 operating nuclear power plants. In the 2013 GEIS, the NRC staff concluded that dredging has 

43 localized effects on water quality that tend to be short lived and that the impact of dredging on 

44 water quality is SMALL for all nuclear plants.

45 The new Category 1 (generic) issue, “Effects of dredging on surface water quality,” was not 

46 considered in either the 2010 FSEIS (NRC 2010) or the June 2013 FSEIS supplement 

47 (NRC 2013b), and neither analysis specifically evaluated the impacts of maintenance dredging 
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1 of the IP2 and IP3 surface water intake structures. Nevertheless, Section 3.2.2 of the 2010 

2 FSEIS states that Entergy had identified no plans to conduct dredging activities at its dock 

3 facility and was not otherwise planning any other activities that would adversely affect the 

4 aquatic environment. In Section 4.23.1 of its ER (Entergy 2007a), Entergy had indicated, 

5 without affirmatively stating that such activities were likely, that ongoing operational activities,

6 such as “minimal maintenance dredging associated with the intake structures,” could have 

7 localized impacts on the aquatic environment of the lower Hudson River during the license 

8 renewal term.

9 By letter dated December 11, 2014, the NRC staff requested that Entergy provide a discussion 

10 of its dredging practices conducted over the past 5 years in relation to IP2 and IP3 operations

11 and provide copies of current permits related to such activities (NRC 2014i). Entergy (2015a)

12 responded, in part, that it has historically performed dredging associated with the IP2 and IP3 

13 cooling water intake structures on an infrequent basis. Entergy last performed dredging in 1994 

14 and stated that, given the infrequent nature of the activity, it may not perform additional dredging 

15 during the course of the license renewal period. Entergy also stated that it possesses no 

16 current permits from the USACE and NYSDEC to authorize dredging but that any future 

17 activities at IP2 and IP3 would be reviewed and permitted by the USACE and NYSDEC. In its 

18 response, Entergy concluded that since IP2 and IP3 would be required to comply with permit 

19 conditions specified in the USACE and NYSDEC permits, including appropriate mitigation 

20 measures, dredging impacts would be localized and SMALL.

21 As discussed above, operations experience from nuclear power plants for which dredging is 

22 conducted indicates that associated effects are localized and temporary in nature and result in a 

23 SMALL impact on ambient water quality. The NRC staff did not identify any new and significant 

24 information with regard to the effects of dredging on surface water quality based on review of 

25 the Entergy’s response to the NRC staff’s RAIs and other available information. Furthermore, 

26 Entergy would be required to obtain a Section 404 permit from the USACE and authorization 

27 from NYSDEC before performing any future dredging activities at IP2 and IP3. Based on this 

28 information and foregoing considerations, the NRC staff concludes that there are no impacts

29 beyond those described in the 2013 GEIS, which concludes that the effects on water quality 

30 from dredging during the license renewal term would be SMALL.

31 Radionuclides Released to Groundwater

32 The issue, “Radionuclides Released to Groundwater,” is a new Category 2 issue. This section 

33 provides the NRC staff’s assessment of any past inadvertent releases of radionuclides into the 

34 groundwater at IP2 and IP3. It includes a description of any past inadvertent releases and the 

35 projected impact to the environment (e.g., aquifers, rivers, lakes, ponds, and ocean) during the 

36 license renewal term. Specifically, this review evaluates the impact of inadvertent releases of 

37 radionuclides on groundwater and surface water quality over the period of license renewal 

38 (10 CFR 51.53 (c)(3)(ii)(P)).

39 5.4.1 Site Description and Hydrology

40 5.4.1.1 Hudson River

41 The IP2 and IP3 site is located on the eastern shore of the Hudson River at River Mile (RM) 43

42 (River Kilometer (Rkm) 69). At the IP2 and IP3 site, the river is approximately 4,500 ft (1,372 m) 

43 wide and 40 ft (12 m) deep. The flow of the Hudson River past the site is controlled more by 

44 tides than freshwater inflow. Eighty percent of the time, the tidal flow is approximately 80 million 

45 gallons per minute (gpm) (129 million liters per minute (L/min)). Depending on the tides and 
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1 rate of downstream fresh water flow, Hudson River water at the IP2 and IP3 site is usually either 

2 saline or brackish (Entergy 2007a).

3 5.4.1.2 Groundwater

4 A detailed description of groundwater flow and radiological transport beneath the IP2 and IP3 

5 site is contained in a site investigation report that documents a 2-year study conducted by an 

6 Entergy contractor from 2005 through 2007 (GZA 2008). This study includes data from 

7 numerous groundwater monitoring locations and geophysical, hydraulic, radiological, and water 

8 chemistry tests. An onsite monitoring network contains over 150 depth-specific sampling 

9 locations at 65 monitoring installations. The groundwater flow system beneath the site is also 

10 described in a U.S. Geological Survey (USGS) Report (Williams 2008). This report contains a 

11 description derived from geophysical and hydrologic tests performed by USGS staff using 

12 24 onsite monitoring wells.

13 The IP2 and IP3 site is located in Westchester County, New York. Across the county, the 

14 bedrock consists of closely folded igneous and metamorphic rocks. Outcrops of bedrock are 

15 numerous, but the bedrock surface in most of the County is covered by unconsolidated deposits 

16 of glacial till and outwash (stream deposits) that range in total thickness from a few feet to as 

17 much as 200 ft (61 m). Groundwater is produced from glacial deposits of till (nonstratified 

18 material deposited directly by glacial ice), outwash (gravel and sands deposited by glacial melt 

19 water), and foliated metamorphic rocks (schist and gneiss).

20 The IP2 and IP3 site is bordered on the northwest by the Hudson River. At the river, the 

21 elevation of the land surface is 10 ft (3 m) above the National Geodetic Vertical Datum of 1929

22 (NGVD-29). Moving east from the river, the land surface rises up to approximately 140 ft (43 m) 

23 NGVD-29 near the eastern site boundary (GZA 2008; Williams 2008). The site topography 

24 slopes generally toward the Hudson River. Surface drainage is toward the Hudson River 

25 (Entergy 2007a) (see Figure 5–1 and Figure 5–2).
New Environmental Issues Resulting from the Revision to 10 CFR Part 51

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1 Figure 5–1. Site Location and Topography

2 Source: Modified from Entergy 2015b
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1 Figure 5–2. Topographic Cross-Section to Hudson River

2 Source: NRC staff generated

3 The Hudson River at the site is a tidally influenced estuary that usually experiences two high 

4 tides and two low tides each day. During high tides, the river water flows north, and during low 

5 tides, it flows south. At the site, tidally induced river water elevations can vary from -1.1 to 3.8 ft 

6 (0.3 to 1.2 m) NGVD-29 (GZA 2008).

7 A cooling water discharge canal serves the reactor complex and runs parallel to the Hudson 

8 River along the plant site. The walls of the discharge canal are constructed of low structural 
New Environmental Issues Resulting from the Revision to 10 CFR Part 51

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1 concrete, but the bottom of the canal consists of a 0.5-ft (0.2-m) thick mud slab in some areas 

2 and an open bedrock bottom in other areas. Therefore, the water in the discharge canal is likely 

3 in hydrologic communication with the underlying groundwater (GZA 2008).

4 At the site, surficial materials that overlay the bedrock range in thickness from 3.5 to 59 ft (1.1 to 

5 18 m) below ground surface. Where not occupied by buildings or other physical structures, the 

6 land surface is covered by soils, glacial deposited material (till), river sediments, and engineered 

7 fill material. The engineered fill materials are made up of mixtures of sand, gravel, and silty 

8 clay. In areas adjacent to structures with foundations that are excavated into bedrock, the 

9 engineered fill is made up of concrete, compacted granular soils, and rock blasted from the 

10 bedrock (GZA 2008). Surficial materials in areas undisturbed by site construction activities 

11 consist of glacial till or silty clays, organic silt, clay, and sandy material overlain by granular fill. 

12 A 20- to 50-ft (7- to 15-m) thick sequence of river sediments (organic silts) occurs near the river 

13 (GZA 2008).

14 As discussed in Section 5.2, the Inwood Marble underlies the surficial materials and site 

15 structures. With the exception of the eastern and northern site boundaries (where it is overlain 

16 by the Manhattan schist), it is the first bedrock unit encountered. During plant construction, the 

17 Inwood Marble was extensively blast excavated. It consists of beds of metamorphosed 

18 dolostone and limestone that dip steeply at 30 to 70 degrees to the southeast. Because of its 

19 steep dip, the Inwood Marble extends to a considerable depth beneath the site. Near the site,

20 more than 830 vertical ft (253 vertical m) of Inwood Marble has been mapped 

21 (Merguerian 2010). The Inwood Marble is underlain by the Lowerre Quartzite and the Fordham 

22 Gneiss (Entergy 2014c, 2014d; GZA 2008; Merguerian 2010; USNY 1970; Williams 2008).

23 With the exception of engineered fill material placed along the river, the water table occurs in 

24 the Inwood Marble (GZA 2008). The water table at the IP2 and IP3 site is recharged by 

25 precipitation. Precipitation at the site is approximately 36 inches (in.) (91 cm) per year. This 

26 level of precipitation is estimated to produce 10 in. (25 cm) per year of recharge to the water

27 table (GZA 2008).

28 The rock matrix of the Inwood Marble has a very low porosity, and groundwater does not easily 

29 flow through it (GZA 2008). Site characterization activities have not detected evidence of any 

30 solution features (i.e., cavities or voids) that could store significant volumes of water or form 

31 preferential pathways for groundwater flow (GZA 2008). Therefore, within the Inwood Marble,

32 fractures and faults create the void space and the pathways for groundwater storage and 

33 movement (GZA 2008). However, the aperture of the faults and fractures is very small. The 

34 void (porosity) of the fracture network is substantially less than 1 percent of the volume of the 

35 rock. Therefore, although the fracture network forms the groundwater pathways through the 

36 rock, it does not hold a large volume of water (Entergy 2012a; GZA 2008; Williams 2008).

37 Fracture aperture (width), spacing, and the degree of fracture interconnectivity are dominant 

38 variables in how groundwater flows through a fractured bedrock environment. The Inwood 

39 Marble contains three fracture sets that intersect each other. One set trends 

40 northeast-southwest, another trends north-south, and another trends east-west. The dip angles 

41 for these fracture sets range from 30 to 70 degrees. In addition to these fracture sets, the 

42 Inwood Marble contains numerous horizontally and vertically oriented fractures. Taken 

43 together, the fractures at the site create a fracture network both horizontally and vertically that 

44 has a high degree of connectivity. The fractures in the network appear to be spaced from 

45 0.3 and 2.2 ft (0.1 and 0.7 m) apart and have an average spacing of 0.7 ft (0.2 m) (GZA 2008).

46 There are also three major groups of faults that have been identified at the site (GZA 2008). 

47 Depending on the amount of clay contained in the faults, they may act as barriers to 

48 groundwater flow, or, with less clay, they may enhance flow through the network 
New Environmental Issues Resulting from the Revision to 10 CFR Part 51

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1 (Williams 2008). While there are some localized trends in fracture strike direction, there is an 

2 abundance of intersecting fractures. Fracture data analysis indicates the Inwood Marble is 

3 highly fractured, but does not contain large individual structures that can readily transmit 

4 groundwater across the site (GZA 2008).

5 At the IP2 and IP3 site, the elevation of the water table along the river bank is the same height 

6 as the water in the river. Moving away from the river, the top of the water table is found at 

7 increasing elevations as the topography increases, and it generally mirrors the surface 

8 topography. The reactor unit farthest from the river is Indian Point Nuclear Generating 

9 Unit No. 1 (IP1). Approximately 175 ft (53 m) southeast of IP1, the water table is approximately 

10 50 ft (15 m) higher than the river at low tide (GZA 2008). Higher water levels on the north, east, 

11 and south boundaries of the site cause the groundwater in the Inwood Marble to flow toward the 

12 Hudson River.

13 All groundwater at the site either discharges directly to the Hudson River or discharges indirectly 

14 through facility drains to the discharge canal, which flows to the Hudson River. The rate of 

15 groundwater discharge to the river is influenced by groundwater recharge rates and river water 

16 levels (GZA 2008). On the west bank of the Hudson River, opposite the IP2 and IP3 site, 

17 groundwater also flows toward, and discharges to, the river (Heisig 2010; Williams 2008). The 

18 size and depth of the Hudson River and the direction of groundwater flow under and on each 

19 side of the river mean that it is extremely unlikely that onsite groundwater in the Inwood Marble 

20 could flow under the Hudson River to the other side (GZA 2008).

21 Groundwater elevations in the Inwood Marble respond to tidal changes in Hudson River water 

22 levels. As the distance from the river increases, changes in groundwater levels from tides 

23 decrease in magnitude and exhibit greater lag time (delayed response to changes in river water 

24 levels). Most of the impact of the tide on groundwater levels is confined to the fill material along 

25 the Hudson River. Tidally induced changes in groundwater levels are noticeable up to 400 ft 

26 (122 m) from the river; however, at greater distances from the river, tidally induced changes in 

27 water levels are very small and difficult to measure (GZA 2008). Tide and groundwater level 

28 data collected throughout 2007 indicate that the general direction of groundwater flow is toward 

29 the river for a range of tide elevations. The same analysis indicates that the rate of groundwater 

30 flow to the river appears to be greatest during the drier part of the year and during times of low 

31 tide (i.e., during times of low water levels in the river relative to groundwater elevations in the 

32 fracture network) (GZA 2008).

33 Laterally and vertically, the fracture network appears to have some preferred directions of 

34 groundwater flow (Entergy 2015b). Blasting the bedrock during facility construction may have 

35 created more fractures in the top of the Inwood Marble. The fracture network appears to be 

36 able to transmit groundwater easier within the upper 40 to 50 ft (12 to 15 m) of the network than 

37 at deeper depths. The presence of more fractures in the top of the Inwood Marble is supported 

38 by a statistical analysis of hydraulic conductivities of individual fractures, which showed higher 

39 hydraulic conductivities within the upper 40 ft (12 m) of the fracture network than below 40 ft 

40 (12 m). In addition, onsite measurements of fracture-network transmissivities are greater in the 

41 upper 50 ft (15 m) of the Inwood Marble than they are at deeper depths (GZA 2008). This 

42 means groundwater in the Inwood Marble can more readily flow through the fracture network 

43 near the surface than it can at deeper depths.

44 Although the groundwater flows laterally across the site and then into the Hudson River, some 

45 groundwater takes a longer pathway to the river. Most of the groundwater movement is 

46 believed to take place in the upper 50 ft (15 m) of the Inwood Marble where fractures can more 

47 readily transmit groundwater, but some of the groundwater flows downward, then moves 

48 laterally across the site, and then moves upward and into either the discharge canal or the 
New Environmental Issues Resulting from the Revision to 10 CFR Part 51

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1 Hudson River. Vertical groundwater flow directions have been measured in 16 onsite 

2 monitoring wells. Vertical flow was found to be downward in eight wells and upward in four 

3 wells (Williams 2008). The four wells in which upward flow was observed are located near the 

4 Hudson River, whereas wells with downward vertical flow are generally located in the eastern 

5 part of the site that has a higher topographic relief (Williams 2008). Because the fracture 

6 network is less permeable with depth and the deeper pathways to the river are longer, 

7 groundwater moving through the deeper parts of the fracture network should take longer to 

8 reach the river.

9 The abundant fractures in the Inwood Marble suggest the fracture network can be appropriately 

10 modeled using an equivalent porous media model (as a nonhomogenous anisotropic, porous 

11 medium) (GZA 2008). Entergy has used an analytical equivalent porous media groundwater 

12 flow model based on a precipitation mass balance analysis to estimate groundwater flux 

13 beneath the site and into the discharge canal and the Hudson River. This analysis is based on 

14 the assumption that, on a long-term average, groundwater flowing through and discharging from 

15 the aquifer is equal to the watershed infiltration recharge. In September 2014, the model 

16 calculated that, over a 12-month period of time, the groundwater discharge rate to the Hudson 

17 River was 17 gpm (64 L/min). Of this amount, 3 gpm (11 L/min) flowed to the discharge canal,

18 and 14 gpm (53 L/min) discharged directly to the Hudson River (Entergy 2014h, 2014k, 2015b).

19 5.4.1.3 Water Resources

20 Potable water sources near the IP2 and IP3 site are not presently derived from groundwater 

21 sources or the Hudson River (NRC 2010). There are no residential or municipal drinking water 

22 wells near IP2 and IP3 (Entergy 2012a; NYSDEC 2007; NRC 2010). Because municipal water 

23 is readily available in the area, it is unlikely that potable or irrigation wells will be installed near 

24 the site in the reasonably foreseeable future (GZA 2008).

25 There are no surface reservoirs near the plant. Drinking water in the area (Village of Buchanan 

26 and City of Peekskill) is obtained from surface water reservoirs located in Westchester County 

27 and the Catskills region of New York. The closest reservoir (Camp Field) is located 3.3 mi 

28 (5.3 km) north and upstream of the site. The other local public drinking water supply is the New 

29 Croton Reservoir, which is 6.3 mi (10.1 km) east of the site. Both of these public drinking water 

30 supplies are several watersheds away from IP2 and IP3 and are at much higher elevations 

31 (GZA 2008; NRC 2012e). Surface water samples collected from the drinking water reservoirs 

32 do not exhibit impacts from the site (GZA 2008). United Water has proposed to construct and 

33 operate a desalination facility in the town of Haverstraw, approximately 4 mi (6.5 km) 

34 south-southwest downstream of the IP2 and IP3 site. This facility, referred to as the Haverstraw 

35 Water Supply Project, would provide desalinated (fresh) water from the Hudson River as a 

36 source of drinking water for Rockland County. As discussed in Section 5.14.4, the operations of 

37 IP2 and IP3 are not expected to adversely affect operation of the proposed facility.

38 The site does not use groundwater either for plant operations or for potable water. Potable 

39 water is supplied to the site by the Village of Buchanan, New York, Public Water Supply system. 

40 Wells located at the site are used for monitoring purposes only (Entergy 2007a).

41 The Inwood Marble contains fresh water, but then becomes brackish in quality near the river

42 (Entergy 2012a). Onsite, the hydraulic properties of the Inwood Marble will not support large 

43 yields of water to wells (Entergy 2012a; GZA 2008). Although wells drilled with conventional 

44 techniques might be able to produce enough water to supply an individual household, the low 

45 hydraulic conductivities and porosities of the fractures are insufficient to supply a public water 

46 system.
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1 5.4.2 Radionuclides Released to Groundwater

2 Groundwater contamination in the Inwood Marble has been traced back to the IP1 and IP2

3 spent fuel pools. Historically, leaks from the IP1 spent fuel pool created contaminant plumes 

4 consisting of strontium-90 and tritium. Leaks associated with the IP2 spent fuel pool and its 

5 associated fuel transfer canal created another plume of tritium contamination (GZA 2008;

6 NRC 2012e). The radionuclides cesium-137, nickel-63, and cobalt-60 have been sporadically 

7 identified in the groundwater on site. How these radionuclides got into the groundwater has not 

8 been determined, but no discrete plumes of contamination have been found for these 

9 radionuclides (Entergy 2008c, 2009a, 2010a, 2011a, 2012b, 2013a, 2014f, 2014h, 2015b, 

10 2015f; GZA 2008).

11 5.4.2.1 History of Releases

12 The following is a summary of radionuclide releases into the groundwater. Detailed descriptions 

13 are contained in Entergy 2012a, 2015b, 2015f; GZA 2008; and NRC 2012e.

14 IP1 Spent Fuel Pool Leak

15 The IP1 reactor ceased operation on October 31, 1974. Fuel was off-loaded from the reactor 

16 and placed into the IP1 spent fuel pools, which were kept full of water to keep the fuel cool. 

17 Leakage into the groundwater from one of the IP1 spent fuel pools was discovered in 

18 April 1990. Unlike the IP2 and IP3 fuel pools, which are lined on the inside with stainless steel, 

19 the inside walls of the IP1 spent fuel pools were made of epoxy-lined concrete. To manage the 

20 leak, foundation and curtain drains associated with the IP1 reactor building were used to 

21 capture contaminated groundwater from the IP1 spent fuel pools. The captured water was then 

22 processed through the plant’s radioactive waste disposal system.

23 In 2006, it was discovered that some contaminated groundwater had bypassed the foundation 

24 and curtain drains and moved with the groundwater to the Hudson River. At the same time, the 

25 removal of spent fuel from the IP1 spent fuel pools began (Entergy 2014k, 2015a). At one point 

26 in the fuel removal process, water levels in the spent fuel pools and the fuel transfer canal had 

27 to be raised so that plant workers could safely remove the spent fuel from the pools. For a short 

28 time, the higher water levels caused increased leakage from the spent fuel pools into the 

29 groundwater. By 2008, all of the spent fuel and the water in the IP1 spent fuel pools had been 

30 removed (Entergy 2015b). This stopped all leakage of radionuclides from the IP1 spent fuel 

31 pools (Entergy 2012a).

32 IP2 Spent Fuel Pool Leaks

33 In 1990, a small hole was detected in the IP2 spent fuel pool stainless steel liner. An estimated 

34 50 gallons (189 liters) per day had been leaking through this hole. An epoxy seal was installed 

35 to plug the hole. Later in 1992, a steel box was welded over the epoxy-sealed hole to 

36 permanently seal the hole. In 2007, a pinhole leak was discovered in one corner of the IP2

37 spent fuel transfer canal. The pinhole leak was repaired that year. No further leaks from the 

38 IP2 spent fuel pool or the transfer canal have since been detected.

39 In April 2014, elevated tritium was detected in three monitoring wells located near the building 

40 containing the IP2 spent fuel pool. The elevated levels of tritium are believed to have been 

41 caused by a floor drain that backed up during refueling activities in 2014. The backed-up water 

42 then came into contact with floor/wall joints that provided a pathway for the water to reach the 

43 groundwater (Entergy 2015a).
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1 5.4.2.2 Extent of Groundwater Contamination

2 Entergy established an onsite monitoring network containing over 150 depth-specific sampling 

3 locations at 65 monitoring installations, which allows the groundwater to be monitored and 

4 sampled at various depths from the groundwater surface to over 300 ft (91 m) below the top of 

5 the bedrock. To better characterize the groundwater, several of the wells in the network are 

6 completed through the floors and basements of buildings. Included in the overall groundwater 

7 monitoring program are approximately 75 storm drains and 25 sumps throughout the IP2 and 

8 IP3 site (GZA 2008; Entergy 2012a). Figure 5–3 shows monitor well locations located inside 

9 and near plant buildings.
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1 Figure 5–3. Monitor Wells Located near Plant Buildings

2 Sources: Modified from Entergy 2008c, 2015b

3 Radionuclide contamination is found above and in the water table. When contaminated water 

4 leaked into the Inwood Marble, it first flowed through the fractures of the Inwood Marble above 

5 the water table. As the contaminated water moved downward under gravity, it moved both 

6 vertically and laterally. As a result, it is believed the leaks from the IP2 spent fuel pool 

7 contaminated a small area of the Inwood Marble water table between IP2 and IP1 with tritium 

8 (Entergy 2014h, 2014k, 2015b).
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1 The direction of groundwater flow in the water table prevents contaminated groundwater from 

2 migrating off the site property to the north, east, or south. Therefore, when leaked radionuclides 

3 reached the water table, they moved downgradient with the groundwater toward the Hudson 

4 River (GZA 2008; NRC 2012e). As previously described, three plumes of contamination were 

5 created in the water table: (1) a tritium plume from the IP2 spent fuel pool, (2) a tritium plume 

6 from the IP1 spent fuel pool, and (3) a strontium-90 plume from the IP1 spent fuel pool. These 

7 plumes comingle with each other and extend to the Hudson River (GZA 2008; NRC 2012e). 

8 Over much of their areal extent, they occur under buildings and other plant structures. Before 

9 they reach the Hudson River, all three plumes are confined to the site and both vertically and 

10 laterally to the Inwood Marble.

11 As discussed above, most of the groundwater movement to the river takes place in the upper 

12 50 ft (15 m) of the Inwood Marble where the fractures can more readily transmit groundwater. 

13 However, some of the groundwater flows downward in arching pathways, then moves laterally 

14 across the site, and then moves upward and into either the discharge canal or the Hudson 

15 River. Groundwater samples have confirmed that the plumes are largely within the upper 50 ft 

16 (15 m) of the Inwood Marble; and even when they are deeper, they are moving toward the river 

17 (Entergy 2015b). Figure 5–4 contains a vertical cross-section of the strontium-90 plume from 

18 IP1 to the river at the end of June 2014.

19 Groundwater contamination plume maps show the lateral extent of the plumes from their points 

20 of origin to their discharge locations near the Hudson River. Figure 5–5 shows the lateral extent 

21 of both the IP2 and IP1 tritium plumes in the 4th quarter of 2014. Figure 5–6 shows the lateral 

22 extent of the strontium-90 plume in the 4th quarter of 2014. Groundwater monitoring data 

23 confirm that tritium and strontium-90 groundwater contamination moves toward and into the 

24 Hudson River. Contamination has not been detected moving off the site in any other direction 

25 (Entergy 2014h, 2014k, 2015b, 2015f).
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1 Figure 5–4. Cross-Section of Strontium-90 Plume from IP1 to the Hudson River

2 Source: Modified from Entergy 2015b
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1 Figure 5–5. IP2 and IP1 Tritium Plumes in the 4th Quarter of 2014

2 Source: Modified from Entergy 2015f
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1 Figure 5–6. Strontium-90 Plume in the 4th Quarter of 2014

2 Source: Modified from Entergy 2015f
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1 For short periods of time, from 2007 through June of 2014, cesium-137, nickel-63, and cobalt-60 

2 were sporadically detected in some wells located near plant structures. How these 

3 radionuclides got into the groundwater has not been determined. However, cesium-137 and 

4 nickel-63 have been consistently detected at sample location MW-42-49. Sample location 

5 MW-42-49 is located close to the IP1 spent fuel pool (Figure 5–5) (Entergy 2008c, 2009a, 

6 2010a, 2011a, 2012b, 2013a, 2014f, 2014h, 2015b, 2015f).

7 To better characterize the impacts on groundwater quality (i.e., the groundwater as a resource),

8 it is helpful to compare the concentrations of the radionuclides in the groundwater to EPA 

9 maximum contaminant levels (MCL). For radionuclides in drinking water, EPA has established 

10 an MCL of 4 millirem (mrem) per year for various radionuclides. This MCL includes cesium-137, 

11 cobalt-60, nickel-63, strontium-90, and tritium. The MCL represents the sum of all 

12 radionuclides, so that, taken together, the annual dose from all the applicable radionuclides will 

13 not exceed 4 mrem per year. However, for ease of comparison, Table 5–2 presents a 

14 concentration that would be required from an individual radionuclide to yield a dose of 4 mrem

15 per year (i.e., without the added contribution of any other radionuclides). Looking at the 

16 concentrations in Table 5–2, strontium-90 concentrations have the biggest influence on dose,

17 and tritium has the least influence on the dose calculation.

18 Table 5–2. Radionuclide Concentration Levels/Limits

Radionuclide Concentration (pCi/L)

(a)

Cesium-137 200

Cobalt-60 100

Nickel-63 50

Strontium-90 8

Tritium 20,000

(a) Concentration for this radionuclide to produce a dose of 4 mrem per 

year.

Sources: EPA 2002a, 2002b, 2002c, 2002d, 2002e

19 In the third quarter of 2014, tritium concentrations in the plume from the IP2 spent fuel pool were 

20 below the concentration in Table 5–2 over much of the area of the plume but exceed the 

21 concentration in Table 5–2 in a small area near the IP2 spent fuel pool. Tritium concentrations 

22 in the plume from the IP1 spent fuel pool are all below the concentration in Table 5–2 over the 

23 entire plume length. Concentrations of strontium-90 usually exceeded the Table 5–2 limit over 

24 much of the plume area. For cesium-137, cobalt-60, and nickel-63, only cesium-137 and 

25 nickel-63 exceeded their limits in Table 5–2, and that was at sample location MW-42-49. From 

26 2003 through 2013, routine monitoring of tritium in Hudson River water has been conducted. 

27 Concentrations in the river water did not exceed 800 picocuries per liter (pCi/L). This is a very 

28 low-level concentration relative to the concentration in Table 5–2 (Entergy 2014g).

29 5.4.2.3 Monitoring Groundwater Contamination

30 Entergy began a Long-Term Monitoring Program in 2005 (NRC 2010). This expanded 

31 monitoring program is designed to provide groundwater information to address the following four 

32 main objectives (Entergy 2014h, 2014k, 2015b, 2015f):
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1 (1) characterize the current and potential future offsite groundwater contaminant 

2 migration to the Hudson River,

3 (2) confirm that contaminated groundwater is not migrating off the property to 

4 locations other than the Hudson River,

5 (3) monitor groundwater proximate to critical structures, systems, and components 

6 that might have releases that cannot be visually detected and might carry an 

7 activity level of significance, and

8 (4) monitor changes in plume concentrations.

9 As previously described, the monitoring network contains over 150 depth-specific sampling 

10 locations at 65 monitoring installations.

11 In accordance with NRC regulatory requirements, Entergy also conducts a Radiological 

12 Environmental Monitoring Program (REMP) that provides for the monitoring and reporting of 

13 radiological impacts resulting from plant operations. Entergy has institutionalized the 

14 Long-Term Monitoring Program in the Offsite Dose Calculation Manual and its implementing 

15 procedures (Entergy 2008f; NRC 2012e). This means that in addition to the REMP, the Long16 Term Monitoring Program is subject to NRC inspection activities. The NRC staff currently 

17 inspects Entergy’s Long-Term Monitoring Program and will continue to do so in the future.

18 As previously discussed, a porous media groundwater flow model is used by Entergy to 

19 compute radionuclide release rates to the discharge canal and directly to the Hudson River 

20 (Entergy 2014h, 2014k, 2015a). The model calculates groundwater flow rates across the site. 

21 Yearly rolling average radionuclide levels within each zone are then used to calculate the 

22 release rate. The results of this monitoring program are reported annually in an Annual 

23 Radioactive Effluent Release Report and an Annual Radiological Environmental Operating 

24 Report (AREOR). These reports are publicly available on the NRC Web site at 

25 http://www.nrc.gov/reactors/operating/ops-experience/tritium/plant-specific-reports/ip2-3.html.

26 Entergy committed to the following conditions as part of a settlement with Riverkeeper, Inc.,

27 Hudson and River Sloop Clearwater, Inc. (Riverkeeper, Inc., Hudson and River Sloop 

28 Clearwater, Inc., and Entergy Nuclear Operations 2012):

29 • Publish on a publicly available Web site each new quarterly Indian Point radionuclide 

30 groundwater monitoring report within 6 months of the end of each quarter. In the 

31 event that any such report is unavailable within 6 months of the end of the quarter, 

32 publish the final quality assurance-reviewed groundwater monitoring data for that 

33 quarter instead.

34 • Conduct additional downstream fish sampling at a location in Haverstraw Bay or in 

35 the vicinity in accordance with Entergy’s REMP for IP2 and IP3 and report the results 

36 of such monitoring in the AREOR.

37 The radionuclide groundwater monitoring reports are available to the public at 

38 http://www.safesecurevital.com/environment/reports.html.

39 5.4.2.4 Independent Evaluations

40 In 2005, the NRC staff established an independent inspection team in response to the discovery 

41 of groundwater contamination at the IP2 and IP3 site. The NRC inspection team included NRC 

42 staff experts, as well as experts from the USGS and NYSDEC. The NRC inspection team 

43 reviewed Entergy’s progress, questioned the adequacy of the conceptual site model, and 

44 examined Entergy’s conclusions. From 2005 through 2009, the NRC staff completed eight

45 inspections associated with the groundwater contamination issue. The NRC staff concluded 
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1 that Entergy’s investigation of groundwater contamination at the IP2 and IP3 site provided a 

2 sound understanding of the extent of radiological groundwater contamination, including the 

3 spatial location and vertical depth of the radionuclide plumes. The NRC staff found that 

4 Entergy’s investigation had established site groundwater flow parameters and had developed an 

5 acceptable precipitation mass/flow methodology to calculate the groundwater flux. This 

6 methodology provided a reasonable basis to quantify offsite radiological releases from 

7 groundwater. The NRC staff also concluded that continued implementation of Entergy’s current 

8 groundwater monitoring program should provide reasonable assurance that if any future leaks 

9 occur they will be detected (NRC 2012e).

10 The NRC staff conducted its own independent groundwater sample testing to confirm the types 

11 and concentrations of radioactive contaminants that were present. The details of this analysis 

12 are discussed in NRC 2012e. In addition to tritium, the sampling program also included 

13 strontium-90, cobalt-60, nickel-63, and cesium-137. The inspection team determined that the 

14 consumption of fish and invertebrates in the Hudson River was the only viable exposure 

15 pathway to humans from the discharge of contaminated groundwater from the site 

16 (NRC 2012e).

17 In conjunction with the State of New York, the NRC staff performed an independent fish 

18 sampling study to investigate the strontium-90 background levels present in Hudson River fish. 

19 Fish samples obtained far upstream from the IP2 and IP3 site were compared with strontium-90 

20 levels in fish samples taken near the site. This comparative analysis showed no contamination 

21 in any fish samples near the site greater than background levels (NRC 2012e).

22 In September 2009, the NRC staff issued its final groundwater-related special inspection report 

23 in which it concluded that Entergy’s Long-Term Monitoring Program was effectively 

24 implemented and maintained to monitor groundwater conditions. The report confirmed that

25 Entergy was conforming to NRC regulatory requirements that protect public health and safety 

26 and the environment (NRC 2012e).

27 As discussed in Sections 2.1.4.1 and 2.2.7 of the 2010 FSEIS (NRC 2010), radiological 

28 environmental monitoring and surveillance has been conducted at the site and reported to the 

29 NRC, beginning 4 years before the startup of IP1 in 1958. The objectives of the program are to 

30 enable the identification and quantification of changes in the radioactivity of the area and to 

31 measure radionuclide concentrations in the environment attributable to site operations. The 

32 preoperational program was designed and implemented to determine the background 

33 radioactivity and to measure variations in activity levels from natural and other sources in the 

34 vicinity, as well as fallout from nuclear weapons tests. In addition to monitoring direct radiation 

35 and the radiation from the site via the airborne pathway, monitoring includes waterborne 

36 pathways. The waterborne pathway is monitored by collecting and analyzing samples of 

37 Hudson River water, fish and invertebrates, aquatic vegetation, bottom sediment, and shoreline 

38 sediment. Measurements of the media comprising the waterborne pathway have indicated that 

39 there is no radiological impact to the surrounding environment from the IP2 and IP3 site 

40 (NRC 2010). Additional information on the radiological impact of normal operations can be 

41 found in Section 4.3 of the 2010 FSEIS (NRC 2010).

42 The New York State Department of Health performs independent sampling and analysis of 

43 radionuclide concentrations around the site. It typically collects samples of air, water, milk, 

44 sediment, vegetation, animals, and fish (NRC 2010). NYSDEC and the New York State 

45 Department of Health oversaw Entergy’s investigation into the source and fate of the 

46 radionuclide contamination in the groundwater at the IP2 and IP3 site. The State’s goals were 

47 to ensure that Entergy performed a comprehensive characterization of site groundwater 

48 contamination, took appropriate actions to identify and stop the sources of the leaks, carried out 
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1 any necessary remedial actions, and developed a comprehensive monitoring program to detect 

2 any future leaks (NYSDEC 2008a).

3 Sampling by the State showed no significant difference between strontium-90 in the flesh of fish 

4 caught near the site and fish caught as far as 70 mi (113 km) upstream (NYDEC 2008;

5 NRC 2012e; Skinner and Sinnott 2009). In September 2007, the NYSDEC published some of 

6 the findings from the State’s ongoing monitoring activities. The findings confirmed Entergy’s 

7 calculated dose to humans from fish and concluded that (1) there are no residential or municipal 

8 drinking water wells or surface reservoirs near the plant, (2) there are no known impacts to any 

9 drinking water source, (3) no contaminated groundwater is moving toward surrounding 

10 properties, (4) contaminated groundwater is moving into the Hudson River, and (5) public 

11 exposure can only occur from the groundwater entering the Hudson River through the 

12 consumption of fish. The State also stated that it would continue to provide an independent 

13 source of information for the counties and other interested parties on topics related to the IP2 

14 and IP3 groundwater investigation and that it would evaluate long-term monitoring plans 

15 (NYSDEC 2007).

16 In May 2008, the State reported that it had (NYSDEC 2008a) conducted the following activities:

17 • Collected split samples of groundwater from onsite and offsite monitoring wells.

18 • Reviewed and made recommendations on the work of Entergy's hydrology 

19 contractor.

20 • Performed an independent assessment of potential public health impacts.

21 • Recommended that Entergy expand its Hudson River fish sampling program in 2007 

22 to address questions regarding potential impacts from strontium-90.

23 • Collected split samples of fish flesh from this enhanced effort and unilaterally 

24 collected bone samples for strontium-90 analysis.

25 • Participated in periodic stakeholder calls and meetings.

26 The State reported the following key findings (NYSDEC 2008a):

27 • Groundwater from the site flows east to west directly toward and into the Hudson 

28 River and does not flow to surrounding properties.

29 • Concentrations of strontium-90 have been detected on site at up to 14 times the 

30 drinking water standard.

31 • Contaminated groundwater is moving into the Hudson River, but the levels of 

32 radionuclides in the river are below State surface water standards for tritium 

33 (20,000 pCi/L) and strontium-90 (8 pCi/L).

34 • No drinking water sources are affected because the Hudson River in this area is 

35 brackish and, therefore, is not used as a drinking water source.

36 • Because the Hudson River is not used as a drinking water source in this area, the 

37 only pathway for a dose to the public from groundwater entering the River is through 

38 consumption of fish.

39 The State reported the following investigation outcomes (NYSDEC 2008a):

40 • NYSDEC and the New York State Department of Health have accepted Entergy’s 

41 characterization of the extent and levels of contamination reported in its report 
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1 entitled, “Hydrogeologic Site Investigation Report for the Indian Point Energy 

2 Center,” dated January 7, 2008 (GZA 2008).

3 • The planned remedy for the strontium-90 contamination (i.e., removal of the spent 

4 fuel and water from the IP1 spent fuel pool) will remove the active source of 

5 contamination for that plume, but residual contamination will continue for many 

6 years.

7 • The tritium contamination primarily came from the IP2 spent fuel pool.

8 • Although the known leaks have been stopped in the IP2 spent fuel pool, the full 

9 extent of the leaks is not known because of an inability to inspect the liner in the IP2 

10 spent fuel pool while the unit is operating. 

11 • With the removal of the active contamination source, Entergy’s planned use of 

12 monitored natural attenuation is an acceptable approach to managing the remaining

13 strontium-90 and tritium plumes.

14 • Because tritium becomes part of the water molecule, it cannot be removed from site 

15 groundwater by current treatment methods.

16 • Entergy’s 2007 calculated doses to the public through fish consumption 

17 (0.00027-mrem whole body and 0.00099-mrem organ dose) are less than 1 percent

18 of the NRC dose limits.

19 The State also reported the following (NYSDEC 2008a): 

20 • The New York State Department of Health has confirmed Entergy’s calculated dose 

21 to humans from fish.

22 • The enhanced 2007 fish sampling effort showed no significant difference between 

23 strontium-90 in the flesh of fish caught near the site and fish caught as far as 70 mi

24 (113 km) upstream.

25 In 2015, the State reported the following (NYSDEC 2015c):

26 • The results of the 2006 REMP found no differences in strontium-90 concentrations in 

27 fish caught near the plant and those caught upriver at a control location near 

28 Newburgh, New York, and no public health threat from consumption of fish caught in 

29 the Hudson as a result of the strontium-90 groundwater flow into the river.

30 • The results of the 2007 enhanced REMP analyses again showed no differences in 

31 strontium-90 concentration in fish flesh between fish caught near the Indian Point 

32 Energy Center (IPEC) and those caught near Newburgh, New York. There was also 

33 no difference between flesh concentrations in fish caught at either of these locations 

34 and the fish caught near Catskill, New York. Additionally, there was no difference in 

35 the more sensitive indicator of strontium-90 concentrations in fish bones caught in 

36 these three locations.

37 5.4.2.5 Corrective Actions

38 To eliminate the source of radionuclide groundwater contamination, Entergy completed the 

39 following corrective measures:

40 • The IP2 transfer canal liner weld imperfection was repaired in December 2007.

41 • The fuel rods in the IP1 spent fuel pool were removed and the fuel pool was drained 

42 of water in late 2008.
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1 Removing the fuel rods and draining the water from the IP1 spent fuel pool stopped it from 

2 adding more radionuclides to the groundwater. Repairing the weld imperfection in the IP2

3 transfer canal liner eliminated a source that was adding tritium to the groundwater (GZA 2008;

4 Entergy 2015b).

5 A Long-Term Monitoring Program with multi-level groundwater monitoring installations was 

6 established throughout the site. Some monitoring installations are located near existing 

7 releases, and some are positioned to detect any future inadvertent releases that might occur in 

8 other areas of the site (GZA 2008).

9 Different options were considered to address the existing radiological groundwater 

10 contamination. Entergy concluded that pumping the groundwater had the risk of expanding the 

11 strontium-90 plume over a larger area. Therefore, Entergy decided to continue with the existing 

12 active groundwater restoration activities via drains near the IP1 spent fuel pool and to use 

13 monitored natural attenuation as a remediation approach (NRC 2012e). Monitored natural 

14 attenuation is a methodology endorsed by EPA and NYSDEC that, depending on site-specific 

15 circumstances, is used to reduce or attenuate the concentration of contaminates in the 

16 groundwater (EPA 1999a, 2012; NYSDEC 2010). Natural attenuation relies on natural 

17 processes, such as dilution, sorption, evaporation, radioactive decay, and chemical reactions 

18 with natural substances.

19 At the IP2 and IP3 site, depending on the radionuclide, the primary natural processes 

20 attenuating radionuclide contamination in the groundwater are radioactive decay, dilution, and 

21 sorption. Radioactive decay results in a reduction in the quantity of a radionuclide that is 

22 present over time. Dilution decreases the concentrations of contaminants as they move through 

23 and mix with clean groundwater. Sorption causes contaminants to bind to soil or rock. As part 

24 of a monitored natural attenuation program to remediate groundwater contamination, the site is 

25 monitored to ensure that natural attenuation is working (EPA 2012).

26 Based on radionuclide half-lives over a 20-year license renewal period, the NRC staff estimates 

27 that radioactive decay would reduce the mass of colbalt-60 by approximately 93 percent, but it 

28 would only reduce cesium-137 by 32 percent and nickel-63 by 13 percent. Because tritium has 

29 a half-life of 12.3 years and strontium-90 has a half-life of 29 years, the tritium plumes will be 

30 more attenuated by radioactive decay than the strontium-90 plume. Over a 20-year license 

31 renewal period, radioactive decay would reduce the mass of the tritium plumes by 

32 approximately 68 percent and the mass of the strontium-90 plume by approximately 38 percent. 

33 As the mass of a radiological contaminants decreases, the concentration of that radiological 

34 contaminants would see a corresponding decrease.

35 When the radiological contaminants move into the Hudson River, they are greatly diluted by the 

36 high volume of water in the Hudson River because the flow rate of contaminated groundwater 

37 into the river is very low with respect to the volume of water flowing in the river. Entergy will 

38 continue to use groundwater and surface water quality monitoring during the license renewal 

39 term to confirm that radionuclide attenuation is occurring as expected and that Hudson River 

40 water quality is not being significantly affected.

41 Tritium is a hydrogen atom with an atomic mass of 3, and it behaves chemically like an ordinary 

42 hydrogen atom. Hydrogen readily binds with oxygen to form water; tritium also reacts with 

43 oxygen to form water. This means that a tritium atom usually moves through the environment 

44 as part of a water molecule. A water molecule that contains tritium will behave in the 

45 environment just like a water molecule that does not contain tritium would behave.

46 When the source of water containing tritium is stopped, the contaminated water reaching the 

47 water table should eventually stop. The plume of contamination in the water table should begin 
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1 to attenuate by the natural flow of groundwater toward the Hudson River. However, some of the 

2 fractures above the water table in the Inwood Marble may have trapped some of the water 

3 containing tritium. Local rainfall should eventually flush this water out and move it down to the 

4 water table. The addition of this formerly trapped tritium to the water table would lengthen the 

5 time for natural flushing to fully attenuate the groundwater in the Inwood Marble.

6 Releases of water containing strontium-90 also flow through the fractures in the Inwood Marble 

7 above the water table. Some of this water may also be temporarily trapped in fractures above 

8 the water table. Like the tritium plumes, the trapping of this water would lengthen the time for 

9 strontium-90 to reach the water table. However, unlike tritium, strontium-90 atoms do not move 

10 at the same rate as the water because strontium-90 can be adsorbed onto rock and minerals 

11 within the fractures. As strontium-90 concentrations increase in the water, some of the 

12 strontium-90 moves out of the water and is adsorbed. Later, as strontium-90 concentrations in 

13 the water decrease, some of the strontium-90 desorbs from the rock and moves back into the 

14 water. This same process of adsorption and desorption, referred to as retardation, occurs 

15 above the water table and in the water table along the entire groundwater flow path to the river. 

16 This process of retardation not only will lengthen the period of plume attenuation but it will also 

17 reduce the rate that strontium-90 enters the river. In effect, less strontium-90 will be released 

18 per year over a longer period of time than if the strontium-90 did not adsorb onto the rock and 

19 minerals of the Inwood Marble fractures.

20 As tritium flows into the Hudson River, it will readily move with the water in the river. However, 

21 as groundwater containing strontium-90 flows into the river, some will mix with the water in the 

22 river, and some may temporarily adsorb to the sediments in the river before it mixes with the 

23 river water.

24 Groundwater chemistry data collected since 2007 record the rate of groundwater restoration. 

25 The data show that tritium concentrations in the groundwater have decreased substantially 

26 (Entergy 2008c, 2009a, 2010a, 2011a, 2012b, 2013a, 2014e, 2014f, 2014h, 2014k, 2015b, 

27 2015f). The concentrations in the tritium plume from the IP1 spent fuel pools have been 

28 reduced to the point that they are all well below the concentration in Table 5–2 of 20,000 pCi/L. 

29 From Quarter 2 of 2007 through Quarter 1 of 2014, the radioactivity in the tritium plume from the 

30 IP2 spent fuel pool has decreased by 80 percent (Entergy 2014h). However, the April 2014 

31 release near IP2 (described above) has increased the radioactivity in the tritium plume. As a 

32 result, the amount of radioactivity in the tritium plume in Quarter 4 of 2014, while still less 

33 than 2007, contained only 46 percent less radioactivity (Entergy 2015f).

34 As discussed in Section 5.4.2.1, operations to remove the spent fuel from the IP1 spent fuel 

35 pools temporarily increased the leakage rate to groundwater. This increased leakage rate 

36 resulted in increased strontium-90 radioactivity levels in the IP1 strontium-90 plume, relative to 

37 average pre-defueling radioactivity levels. However, strontium-90 radioactivity levels in the IP1

38 strontium-90 plume have exhibited an overall decrease since the spent fuel in the IP1 spent fuel 

39 pools was removed and the pools were dewatered (Entergy 2014f, 2014h, 2015a). From 

40 Quarter 4 of 2008—when the IP1 spent fuel pools were defueled and strontium radioactivity 

41 values were at their highest reported levels in the groundwater—until Quarter 3 of 2014, 

42 strontium radioactivity levels have decreased by 77 percent. Overall, this is a 40 percent

43 decrease from average pre-defueling radioactivity when strontium-90 radioactivity was at lower 

44 levels (Entergy 2015f).

45 To illustrate the rate of attenuation, Figure 5–7 shows the extent of the tritium plume from the 

46 IP2 spent fuel pool in 2007, and Figure 5–5 shows the extent of the plume in the 4th quarter of 

47 2014. Figure 5–8 shows the extent of the strontium-90 plume in 2007, and Figure 5–6 shows 

48 the extent of the plume in the 4th quarter of 2014. Over this time period, the tritium plume 
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1 shows a marked reduction in concentrations over most of the plume. The strontium-90 plume 

2 shows decreased concentrations in the upper one-half of the plume (away from the river and 

3 near IP1), but it generally covers the same area.

4 As previously mentioned, the fracture network appears to have some preferred directions of 

5 groundwater flow. This might explain why existing groundwater contamination plumes have 

6 originated at different areas of the site, but discharge into the Hudson River at about the same 

7 location (Entergy 2015b). Table 5–3 displays changes with time in the concentration (maximum 

8 yearly average) of tritium and strontium-90 in groundwater near the Hudson River. The table 

9 reports concentrations from sampling stations at monitor wells MW-66 and MW-67. These 

10 sampling stations are located near the river and within the plumes (Entergy 2008c, 2009a, 

11 2010a, 2011a, 2012b, 2013a, 2014f, 2015d). Well locations MW-66 and MW-67 are shown on

12 Figure 5–5 through Figure 5–8. From 2007 through 2014, tritium concentrations have generally 

13 decreased, whereas strontium concentrations stayed the same or decreased. The implication is 

14 that the two plumes are being diluted by clean groundwater as the radionuclides move toward 

15 the river. Because of this process, the concentrations of radionuclides in groundwater entering 

16 the river are generally remaining the same or decreasing. Therefore, over the period of license 

17 renewal, the Hudson River is unlikely to see higher concentrations of radionuclides flowing into 

18 the Hudson River.

19 Table 5–3. Yearly Averages of Radionuclide Concentrations in

20 Onsite Groundwater Sampling Stations Located near the Hudson River

Year

Groundwater Sampling Stations near the Hudson River

MW-66-36

Tritium (pCi/L)

MW-67-39

Tritium (pCi/L)

MW-66-36

Strontium-90

(pCi/L)

MW-67-39

Strontium-90

(pCi/L)

2007 9,030 4,970 9 23

2008 5,950 3,730 14 18

2009 3,850 3,260 9 11

2010 2,700 3,200 5 9

2011 3,440 3,680 11 12

2012 3,475 2,765 8 10

2013 1,858 1,171 9 9

2014 1116 1500 8 7

Sources: Entergy 2008c, 2009a, 2010a, 2011a, 2012b, 2014f, 2015d

21 In addition, from 2007 through 2013, tritium concentrations in Table 5–3 were at low levels 

22 relative to the concentration in Table 5–2 of 20,000 pCi/L, whereas strontium-90 concentrations 

23 in the same two wells were above the concentration in Table 5–2 of 8 pCi/L (Entergy 2014g). 

24 However, as previously discussed, the September 2014 groundwater flow model calculated that 

25 over a 12-month period of time, the groundwater discharge rate to the Hudson River was 

26 17 gpm (65 L/min). Using the tidal flow of 80 million gpm (302 million L/min) in the Hudson 

27 River, this rate of groundwater discharge is approximately 0.0002 percent of the water flowing in 

28 the river. This would dilute strontium and tritium values to concentrations well below the 

29 concentrations in Table 5–2.

30 As stated in Section 5.4.2, the radionuclides cesium-137, nickel-63, and cobalt-60 have been 

31 sporadically identified at local areas within the IP2 and IP3 site, but no plumes of contamination 

32 have been identified for these radionuclides. In September 2014, no cobalt-60 was found above 
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1 the lower limit of detection in any sample stations, but cesium-137 and nickel-63 were detected 

2 above the lower limit of detection at groundwater sample station MW-42-49. However, 

3 since 2007, cesium-137 and nickel-63 do not seem to have moved far from the area monitored 

4 by this well. Therefore, over the period of license renewal, cesium-137 and nickel-63 

5 contamination is likely to remain near groundwater sample station MW-42-49 and should not 

6 reach the Hudson River.

7 Should onsite groundwater contamination remain after the period of license renewal, Entergy 

8 would be required to address any residual contamination during decommissioning of the facility, 

9 as necessary.
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1 Figure 5–7. IP2 Tritium Plume in 2007

2 Source: Modified from Entergy 2015b
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1 Figure 5–8. Strontium-90 Plume in 2007

2 Source: Modified from Entergy 2008d
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1 5.4.3 Environmental Consequences

2 This section evaluates the impact of inadvertent releases of radionuclides on groundwater and 

3 surface water quality projected over the period of license renewal from the continued operation 

4 of IP2 and IP3. The combined impacts from IP1, IP2, and IP3 are evaluated in Section 5.14.4.

5 As previously stated, the radionuclides cesium-137, nickel-63, and cobalt-60 have been 

6 sporadically identified at local areas within the IP2 and IP3 site, but no plumes of contamination 

7 have been identified for these radionuclides. Over the period of license renewal, groundwater 

8 contamination from these radionuclides are expected to remain small in area extent and should 

9 not reach the Hudson River. Entergy would be required to address any residual contamination 

10 during decommissioning of the facility, as necessary.

11 The sealing of leaks associated with the IP2 spent fuel pool has stopped the leakage of tritium 

12 into the groundwater from those sources. The groundwater monitoring program quickly 

13 detected the April 2014 leaks of tritium into the groundwater. The Long-Term Monitoring 

14 Program is subject to NRC oversight. If any inadvertent releases of radionuclides to the 

15 groundwater occur over the period of license renewal, it is likely that they will be readily 

16 detected by the Long-Term Monitoring Program, allowing corrective actions to be quickly taken.

17 The NRC staff concludes that groundwater contamination will either remain onsite, or be 

18 discharged into the Hudson River. Therefore, off-site groundwater supplies should continue to 

19 be unaffected by ongoing operations. At the IP2 and IP3 site, the hydraulic properties of the 

20 Inwood Marble will not support large yields of water to wells. The onsite groundwater quality in 

21 the Inwood Marble has been noticeably altered relative to the concentrations in Table 5–2. 

22 Therefore, the NRC staff concludes the current impact on the onsite groundwater quality is 

23 MODERATE.

24 However, the groundwater quality is being improved by natural attenuation processes. The site 

25 is being monitored to judge the effectiveness of radionuclide attenuation and to quickly identify 

26 any inadvertent future releases of radionuclides. With the elimination of radionuclide leaks to 

27 the groundwater and with the use of monitored natural attenuation, the impact on groundwater 

28 quality could move to SMALL. Therefore, the overall impacts to groundwater due to the IP2 and 

29 IP3 license renewal would be SMALL to MODERATE.

30 The only surface water body that could be affected is the Hudson River. At this location, the 

31 Hudson River is brackish or saline and, therefore, is not currently used as a source of drinking 

32 water (see Section 5.14.4 for the impacts to the proposed Haverstraw Water Supply Project). 

33 The concentration of tritium in groundwater discharging to the Hudson River is below the 

34 concentration in Table 5–2. Furthermore, over the period of license renewal, the concentrations 

35 of radionuclides in groundwater discharging to the Hudson River should be rapidly diluted to 

36 such low levels they may not be noticeable. Therefore, the NRC staff concludes that the impact 

37 on surface water quality is SMALL.

38 Effects on Terrestrial Resources (Noncooling System Impacts)

39 In the 2013 GEIS (NRC 2013a), the NRC staff determined that noncooling system effects on 

40 terrestrial resources is a Category 2 issue that requires site-specific evaluation during each 

41 license renewal review. According to the 2013 GEIS, noncooling system impacts can include 

42 those impacts that result from landscape maintenance activities, stormwater management, 

43 elevated noise levels, and other ongoing operations and maintenance activities that would occur 

44 during the renewal period and that could affect terrestrial resources on and near a plant site.
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1 Landscape Maintenance Activities

2 As indicated in Section 2.2.6.1 of the FSEIS regarding IP2 and IP3 license renewal (NRC 2010), 

3 the IP2 and IP3 site includes small tracts of forest that total approximately 25 acres (ac)

4 (10 hectares (ha)) interspersed among the site’s facilities and paved areas, maintained areas of 

5 grass that cover about 7 ac (2.8 ha) of the site, and a forest area that covers approximately 

6 70 ac (28 ha) of the northern portion of the site. The majority of site landscape maintenance is 

7 performed within the protected area and not within natural areas on the site. Entergy (2015a) 

8 has no plans to disturb any previously undisturbed natural habitats on the site as part of or 

9 following the proposed IP2 and IP3 license renewal. Therefore, landscape and maintenance 

10 activities are unlikely to result in noticeable effects on terrestrial resources during the proposed 

11 license renewal term.

12 Stormwater Management

13 Entergy maintains a BMP plan in accordance with Special Condition 1 of the site’s SPDES

14 permit (Permit No. NY-0004472) (NYDSEC 2000). The BMP plan identifies practices to prevent 

15 or minimize the potential for release of significant amounts of toxic or hazardous pollutants to 

16 the waters of the State through plant site runoff, spillage and leakage, sludge or waste disposal, 

17 and stormwater discharges. Entergy further monitors areas with the potential for spills of oil or 

18 other regulated substances under a Spill Prevention, Control, and Countermeasure Plan, which 

19 is required by the EPA’s Oil Pollution Prevention Rule under the authority of Section 311(j)(1)(C) 

20 of the CWA (40 CFR Part 112; Entergy 2007a). Collectively, these measures ensure that the 

21 effects to terrestrial resources from pollutants carried by stormwater would be minimized during 

22 the proposed license renewal term.

23 Noise

24 The 2013 GEIS (NRC 2013a) indicates that elevated noise levels could be a noncooling system 

25 impact to terrestrial resources. However, the 2013 GEIS also concludes that generic noise 

26 impacts would be SMALL because noise levels would remain well below regulatory guidelines 

27 for offsite receptors during continued operations and refurbishment associated with license 

28 renewal. The NRC staff did not identify any information during its review that would indicate that 

29 noise impacts to terrestrial resources at IP2 and IP3 would be unique or require separate 

30 analysis.

31 Other Operations and Maintenance Activities

32 Other operations and maintenance activities that could occur as a result of license renewal 

33 include potential replacement of the IP2 and IP3 reactor vessel heads and control rod drive 

34 mechanisms. Section 3.2.1 of the FSEIS (NRC 2010) addresses impacts to terrestrial 

35 resources that could result from these refurbishment activities. In the FSEIS, the NRC staff 

36 concluded that impacts of refurbishment on terrestrial resources would be SMALL, and the NRC 

37 staff has not identified any new and significant information that would change this conclusion.

38 Entergy (2015a) anticipates that all maintenance and repair of plant infrastructure (including 

39 roadways, piping installations, fencing, and other security-related infrastructure) that may be 

40 undertaken during the license renewal term would be confined to previously disturbed areas of

41 the site. Entergy (2007a) maintains fleet procedural controls to ensure that environmentally 

42 sensitive areas, if present, are appropriately considered during site operations and project 

43 planning. These controls require Entergy personnel to review potential impacts to the 

44 environment when projects will require additional construction, require a change in the 

45 conditions of existing permits, or otherwise result in an environmental impact. Additionally, the 

46 IP2 and IP3 licenses (NRC 1973, 1975) contain Environmental Protection Plans that require 

47 Entergy to report to the NRC any occurrence of an unusual or important environmental event 
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1 that could result in significant impacts causally related to plant operation. Such events include, 

2 but are not limited to, bird impaction events, fish kills, and the mortality of any species protected 

3 under the Endangered Species Act of 1973, as amended (ESA) (16 U.S.C. 1531 et seq.). 

4 Entergy must report such events to the NRC within 24 hours and must submit a written report of 

5 events within 30 days.

6 Conclusion

7 Based on its independent review, the NRC staff concludes that the landscape maintenance 

8 activities, stormwater management, elevated noise levels, and other ongoing operations and 

9 maintenance activities that Entergy might undertake during the renewal term would primarily be 

10 confined to disturbed areas of the IP2 and IP3 site. These activities would not have noticeable 

11 effects on terrestrial resources, nor would they destabilize any important attribute of the 

12 terrestrial resources on or in the vicinity of the IP2 and IP3 site. Therefore, the NRC staff 

13 expects noncooling system impacts on terrestrial resources during the license renewal term to 

14 be SMALL.

15 Exposure of Terrestrial Organisms to Radionuclides

16 This section addresses the issue of potential impacts of radionuclides on terrestrial organisms 

17 resulting from normal operations of a nuclear power plant during the license renewal term. This 

18 issue is a new Category 1 issue that the NRC staff evaluated in the 2013 GEIS (NRC 2013a) 

19 due to public concerns about the impacts of radionuclides on terrestrial organisms at some 

20 power plants.

21 Section 4.6.1.1 of the 2013 GEIS considers the effects of direct and indirect exposure of 

22 terrestrial organisms to radionuclides through various pathways, including air and liquid effluent 

23 releases. The 2013 GEIS considers a number of radionuclides, including the noble gases 

24 krypton, xenon, and argon; tritium; isotopes of iodine and cesium; strontium; cobalt; and 

25 chromium. These radionuclides may be deposited directly on terrestrial plants, animals, or soils 

26 if released from power plant vents during normal operation, or terrestrial organisms may take up 

27 radionuclides if the radionuclides enter shallow groundwater. Accordingly, terrestrial organisms 

28 may be exposed to ionizing radiation from radionuclides through direct contact with air, water, or 

29 other media; inhalation; or ingestion of food, water, or soil.

30 In 2002, the U.S. Department of Energy (DOE) created a general screening methodology that 

31 provides limiting radionuclide concentration values (called Biota Concentration Guides (BCGs)) 

32 for aquatic and terrestrial biota. The DOE’s BCGs were developed on the basis of experimental 

33 evidence that negative effects would not occur at the guideline doses. If site-specific data 

34 indicate that the BCGs are exceeded, the DOE’s screening methodology leads the user to 

35 conduct a more detailed analysis. The BCGs for terrestrial organisms are as follows:

36 • riparian animal (0.1 radiation-absorbed dose per day (rad/d)) (0.001 gray per day 

37 (Gy/d)),

38 • terrestrial animal (0.1 rad/d) (0.001Gy/d), and

39 • terrestrial plant (1 rad/d) (0.01 Gy/d).

40 In the 2013 GEIS, the NRC estimates the total dose expected to be received by the three 

41 terrestrial receptors (riparian animal, terrestrial animal, and terrestrial plant) based on 

42 site-specific radionuclide concentrations in water, sediment, and soils at 15 nuclear plants using 

43 the RESRAD-BIOTA dose evaluation model (DOE 2004). The IP2 and IP3 site (which includes 

44 IP1) is one of the sites evaluated. The estimated radiation doses listed in the 2013 GEIS for the 
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1 IP2 and IP3 site, which are based on the site’s 2006 REMP results as reported in the AREOR 

2 (Entergy 2007a), are as follows:

• riparian animal (2.30x10-3 rad/d) (2.3 x 3 -5 Gy/d),

• terrestrial animal (2.22x10-3 rad/d) (2.22 x 4 -5 Gy/d), and

• terrestrial plant (2.44x10-4 rad/d) (2.44 x 5 -6 Gy/d).

6 The maximum estimated dose rate calculated for IP2 and IP3 site and the other 14 plants 

7 evaluated in the 2013 GEIS is well below the DOE’s guideline values. Based on these 

8 calculations and on a review of the available literature, the NRC staff concludes in the 

9 2013 GEIS that the impact of routine radionuclide releases from past and current operations 

10 and refurbishment activities on terrestrial biota would be SMALL for all nuclear plants and would 

11 not be expected to appreciably change during the license renewal period.

12 The NRC staff has not identified any new and significant information related to the exposure of 

13 terrestrial organisms to radionuclides during its independent review of Entergy’s ER; the last 

14 5 years of IP2 and IP3 AREOR reports (Entergy 2010b, 2011b, 2012c, 2013c, 2014g); the last 

15 5 years of IP2 and IP3 radioactive effluent release reports (Entergy 2010a, 2011a, 2012b, 

16 2013a, 2014f); the supplemental information submitted by Entergy in March 2015 (2015a); or 

17 other available information. Section 2.1.4 of the FSEIS regarding IP2 and IP3 license renewal 

18 (NRC 2010) describes Entergy’s radioactive waste management program to control radioactive 

19 effluent discharges to ensure that discharges comply with NRC regulations in 10 CFR Part 20. 

20 Section 4.3 of the FSEIS contains the NRC staff’s evaluation of IP2’s and IP3’s radiological 

21 impacts during normal operations, which provide further support for the conclusion that the 

22 impacts to terrestrial organisms from radioactive effluents are SMALL. The NRC staff 

23 concludes that there are no impacts beyond those described in the 2013 GEIS, which concludes 

24 that the impacts from license renewal on terrestrial organisms from radionuclides would be 

25 SMALL.

26 Cooling System Impacts on Terrestrial Resources (Plants with

27 Once-Through Cooling Systems or Cooling Ponds)

28 This section addresses the effects that continued operation of the IP2 and IP3 cooling system 

29 during the proposed license renewal term might have on terrestrial vegetation and wildlife. In 

30 the 1996 GEIS (NRC 1996), this issue only applied to nuclear power plants with cooling ponds. 

31 Accordingly, this issue was not addressed in the 2010 FSEIS (NRC 2010) because it did not 

32 apply to IP2 and IP3 when the FSEIS was published. This Category 1 issue was expanded in 

33 the 2013 GEIS (NRC 2013a) to include plants (like IP2 and IP3) with once-through cooling 

34 systems.

35 Section 4.6.1.1 of the 2013 GEIS considers the effects that cooling systems might have on 

36 terrestrial resources, including the following:

37 • increased water temperatures,

38 • humidity and fogging,

39 • disturbance of wetlands or riparian habitat during maintenance dredging,

40 • erosion of shoreline wetlands, and

41 • contaminants in surface water or groundwater.
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1 Elevated water temperatures associated with cooling systems may affect the distribution of 

2 some terrestrial plant and animal species associated with riparian or wetland communities. 

3 For example, the growth of plants along the cooling pond shoreline is restricted by the thermal 

4 effluent at the H.B. Robinson Steam Electric Plant, Unit 2, in South Carolina (NRC 2003). 

5 Increased humidity and fogging around the cooling system discharge resulting from elevated 

6 water temperatures may alter the distributions of some vegetation communities. Maintenance 

7 dredging near cooling system intakes or discharges may disturb wetland habitats along with 

8 accumulated sediments, and sedimentation from dredging disposal may indirectly affect 

9 wetlands. Shoreline wetlands or riparian habitats may be affected by erosion resulting from 

10 high-velocity effluent discharges or altered current patterns. The cooling system may also 

11 transport contaminants generated during normal power plant operations to animal and plant 

12 receptors. Terrestrial biota may be exposed to contaminants released from the power plant’s 

13 cooling system through direct contact with cooling system effluent or through uptake from 

14 aquatic or riparian food sources near the cooling system. Contaminants of potential concern in 

15 the cooling system effluent include chlorine and other biocides, heavy metals, VOCs, oil 

16 products, tritium, and strontium. The concentrations of these contaminants have been found to 

17 be low within the liquid effluent discharged from the nuclear power plants, and compliance with 

18 applicable NPDES permits should ensure that nonradioactive contaminant concentrations 

19 discharged in cooling system effluents are low enough to have only small impacts on terrestrial 

20 biota. Regarding tritium and strontium, the NRC (2013a) found that the maximum estimated 

21 dose rate to terrestrial organisms at nuclear power plants is well below the DOE’s guidelines for 

22 terrestrial biota. Exposure of terrestrial organisms to these and other radionuclides is discussed 

23 in more detail in Section 5.6 of this supplement.

24 To evaluate the impacts of these potential effects in the 2013 GEIS, the NRC staff reviewed 

25 site-specific radiological effluent release reports, site environmental reports, and supplemental 

26 environmental impact statements (SEISs) for license renewal at eight nuclear power plants with 

27 different types of cooling systems. Impacts on terrestrial biota associated with the operation of 

28 the cooling systems were not found to be an issue at any of the nuclear power plants evaluated, 

29 and the NRC concludes in the 2013 GEIS that cooling system impacts on terrestrial resources 

30 are SMALL for all nuclear power plants during the license renewal term.

31 The NRC staff has not identified any new and significant information related to cooling system 

32 impacts on terrestrial resources during its independent review of Entergy’s ER; the last 5 years 

33 of IP2 and IP3 radioactive effluent release reports (Entergy 2010a, 2011a, 2012b, 2013a, 

34 2014f); the supplemental information submitted by Entergy in March 2015 (Entergy 2015a); or 

35 other available information. The NRC staff concludes that there are no impacts beyond those 

36 impacts described in the 2013 GEIS, which concludes that the impacts from license renewal on 

37 terrestrial organisms from continued operation of the cooling system would be SMALL.

38 Exposure of Aquatic Organisms to Radionuclides

39 The issue of potential impacts of radionuclides on aquatic organisms resulting from normal 

40 operations of a nuclear power plant during the license renewal term is a new generic 

41 (Category 1) issue in the 2013 GEIS (NRC 2013a). The 2013 GEIS includes this issue due to 

42 public concern about the impacts of radionuclides on aquatic organisms at some power plants. 

43 Section 4.6.1.2 of the 2013 GEIS considers the effects of direct and indirect exposure of aquatic 

44 organisms to radionuclides, and greater detail on this subject can be found there.

45 Aquatic organisms can be exposed externally to ionizing radiation from radionuclides in water, 

46 sediment, and other biota and can be exposed internally through ingested food, water, and 

47 sediment and absorption through the integument and respiratory organs. The 2013 GEIS notes 
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1 that some radionuclides tend to follow pathways similar to their nutrient analogs and can 

2 therefore be transferred rapidly through the food chain. These include (1) radionuclides, such 

3 as strontium-90, barium-140, radon-226, and calcium-46, that behave like calcium and that are 

4 therefore accumulated in bony tissues, (2) radionuclides, such as iodine-129 and iodine-131,

5 that act like stable iodine and accumulate in thyroid tissue, (3) radionuclides, such as 

6 potassium-40, cesium-137, and rubidium-86, that follow the general movement of potassium 

7 and that can be distributed throughout the body, and (4) radionuclides, such as tritium, which 

8 resembles stable hydrogen, that are distributed throughout the body of an organism.

9 The DOE (DOE 2002, 2004) developed and published a screening methodology that provides 

10 limiting radionuclide concentration values (called BCGs) for aquatic and terrestrial biota. The 

11 DOE’s BCGs were developed on the basis of experimental evidence that negative effects would 

12 not occur at or below the guideline doses.

13 Of the aquatic test subjects considered, the early life stages (especially developing eggs and 

14 the young) of some fish species appear to be the most sensitive to the effects of ionizing 

15 radiation. Significant histological effects on the gonads of small tropical fish were detected at a 

16 dose rate of 1 rad/d (0.01 Gy/d), although the majority of tests for chronic effects of ionizing 

17 radiation on aquatic organisms did not find significant effects unless the dose was much greater. 

18 The DOE’s guideline for radiation dose rates from environmental sources recommends limiting 

19 the radiation dose to aquatic biota to no more than 1 rad/d (0.01 Gy/d) at which level the DOE 

20 expects no negative population-level effects. Because fish at early life stages were the most 

21 sensitive subjects reviewed, this dose rate should be protective of aquatic biota in general.

22 In the 2013 GEIS, the NRC staff reported dose rates for aquatic biota calculated with the 

23 RESRAD-BIOTA dose evaluation model using site-specific radionuclide concentrations in water 

24 and sediments from REMP reports for 15 NRC-licensed power plants, including IP2 and IP3. 

25 The estimated radiation doses listed in the 2013 GEIS for IP2 and IP3 site (which includes IP1) 

26 are based on the site’s 2006 REMP results reported in Entergy’s AREOR as follows:

• water (5.01x10-2 rad/d) (5.01 x 27 -4 Gy/d),

• sediment (2.03x10-5 rad/d) (2.03 x 28 -7 Gy/d), and

• total (5.01x10-2 rad/d) (5.01 x 29 -4 Gy/d).

The total calculated dose to aquatic biota at the IP2 and IP3 site of 5.01x10-2 rad/d (5.01 x -4 30

31 Gy/d) is one-twentieth of the DOE’s guideline value of 1 rad/d (0.01 Gy/d), which indicates that 

32 no adverse effects would occur.

33 The total calculated dose rates for aquatic biota for all 15 plants were all less than 0.2 rad/d 

34 (0.002 Gy/d), which is less than the guideline value of 1 rad/d (0.01 Gy/d), and the 2013 GEIS 

35 anticipates that normal operations of these facilities would not result in negative effects on 

36 aquatic biota. Based on literature reviewed and on the dose rates that have been estimated for

37 aquatic biota from site-specific data, the 2013 GEIS concludes that the impact of radionuclides 

38 on aquatic biota from past operations would be SMALL for all nuclear plants and would not be 

39 expected to change appreciably during the license renewal period. The 2013 GEIS also 

40 concludes that the impact of radionuclides on aquatic biota resulting from continued operations 

41 is a generic (Category 1) issue for license renewal.

42 The NRC staff did not identify any new and significant information related to the exposure of 

43 aquatic organisms to radionuclides from IP2 and IP3 during its independent review of Entergy’s 

44 ER; the last 5 years of IP2 and IP3 AREOR reports (Entergy 2010b, 2011b, 2012c, 2013c, 

45 2014g); the last 5 years of IP2 and IP3 radioactive effluent release reports (Entergy 2010a, 

46 2011a, 2012b, 2013a, 2014f); the supplemental information submitted by Entergy in March 2015 
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1 (2015a); or other available information. Section 2.1.4 of the FSEIS regarding IP2 and IP3 

2 license renewal (NRC 2010) describes Entergy’s radioactive waste management program to 

3 control radioactive effluent discharges to ensure that discharges comply with NRC regulations at 

4 10 CFR Part 20. Section 4.3 of the FSEIS contains the NRC staff’s evaluation of IP2 and IP3’s 

5 radiological impacts during normal operations, which indicates that the impacts from radioactive 

6 effluents are SMALL. The NRC staff identified no impact to aquatic organisms from operation of 

7 IP2 and IP3 due to radionuclides beyond those impacts described in the 2013 GEIS, which 

8 concludes that the impacts to aquatic organisms during the license renewal term from 

9 radionuclides due to normal plant operation would be SMALL.

10 Effects of Dredging on Aquatic Organisms

11 The issue of effects of dredging on aquatic organisms associated with normal operations of a 

12 nuclear power plant during the license renewal term is a new generic (Category 1) issue in the 

13 2013 GEIS (NRC 2013a). The affected environment for aquatic resources is described in

14 Section 2.2.5 of the December 2010 FSEIS (NRC 2010). Section 2.2.5.2 describes dredging, 

15 channelization, and dam construction in the Hudson River. This section describes historic and 

16 ongoing dredge and fill activities that have altered the aquatic environment and affected flow 

17 patterns in the Hudson River, which in turn affects the river’s ecosystem. Section 2.2.5 does not 

18 discuss any dredging associated with the IP2 and IP3 intake structures. In response to the 

19 NRC staff’s RAI, Entergy (2015a) reported no dredging activities associated with the IP2 and 

20 IP3 intake structures over the last 5 years and reported infrequent dredging before that, with the 

21 last dredging occurring in 1994. Regarding future dredging, Entergy (2015a) states that “it may 

22 well be that no dredging occurs during the license renewal period.” If dredging were to occur, 

23 such dredging must comply with USACE and NYSDEC permit requirements, including 

24 mitigation measures.

25 The 2013 GEIS (NRC 2013a) reviews the effects of dredging at nuclear power plants on aquatic 

26 organisms and finds that dredging would generally occur infrequently, would be relatively short 

27 in duration, and would only affect relatively small areas. On this basis, the 2013 GEIS 

28 concludes that the impact of dredging on aquatic organisms would be SMALL and would be a 

29 generic (Category 1) issue. The conditions described by the 2013 GEIS apply to dredging that 

30 might occur at IP2 and IP3 intake structures over the license renewal period if any dredging 

31 were to occur. As discussed above, Entergy (2015a) reported no dredging activities associated 

32 with the IP2 and IP3 intake structures over the last 5 years and reported infrequent dredging 

33 before that, with the last dredging occurring in 1994. Further, Entergy does not anticipate 

34 dredging during the license renewal period at this time. Accordingly, the NRC staff finds no 

35 impacts beyond those described in the 2013 GEIS, which concludes effects of dredging on the 

36 aquatic organisms during the license renewal term would be SMALL.

37 Impacts of Transmission Line Right-of-Way Management on Aquatic 

38 Resources

39 The 2013 GEIS (2013a) redefined the effects of transmission line right-of-way (ROW)

40 management on aquatic resources in two ways. First, it separated this issue from other aquatic 

41 resource issues. Second, the NRC (2013a) redefined the action area in Section 3.1.6.5 to 

42 exclude transmission lines that may have been constructed and operated to connect the power 

43 plant to the regional electrical distribution grid but that are no longer owned or managed by the 

44 licensees and would remain energized regardless of a license renewal decision. The new 

45 issue, impacts of transmission line ROW management on aquatic resources, is a generic 

46 (Category 1) issue in the 2013 GEIS (NRC 2013a).
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1 Sections 2.1.7 and 4.2.1 of the 2010 FSEIS (NRC 2010) describe the two 345-kilovolt (kV) 

2 transmission lines that distribute power to the electric grid and the two 138-kV lines that use the 

3 same transmission towers to supply offsite (standby) power. These lines are within the IP2 and 

4 IP3 property boundary except for where they cross a public road to connect to the Buchanan 

5 substation owned by Consolidated Edison. Under the 2013 GEIS definition, this is the only 

6 ROW transmission line segment in scope for license renewal. In response to the NRC staff’s 

7 RAI, Entergy (2015a) reports that this ROW does not cross any aquatic habitat.

8 Based on the absence of potentially affected aquatic habitat, no impacts are associated with the 

9 impacts of transmission line ROW management on aquatic resources beyond those considered 

10 in the 2013 GEIS, which concludes that the impact level for this issue is SMALL.

11 Human Health Impacts from Chemicals and Physical Occupational Hazards

12 Two new Category 1 (generic) issues related to Human Health were added in the NRC’s 2013 

13 revision to 10 CFR Part 51: “Human health impact from chemicals” and “Physical occupational 

14 hazards.” The first issue considers the impacts from chemicals to plant workers and members 

15 of the public. The second issue considers the nonradiological occupational hazards of working 

16 at a nuclear power plant. An understanding of these nonradiological hazards to nuclear power 

17 plant workers and members of the public has been well established at nuclear power plants 

18 during those plants’ current licensing terms. The impacts from chemical hazards are expected 

19 to be minimized through the applicant’s use of good industrial hygiene practices as required by 

20 permits and Federal and State regulations (e.g., in compliance with the Occupational Safety and 

21 Health Administration’s regulation on chemical hazards and the use of the Material Safety Data 

22 Sheet for the respective facilities). In addition, the impacts from physical hazards to plant 

23 workers will be of small significance if workers adhere to safety standards and use protective 

24 equipment as required by Federal and State regulations (e.g., Occupational Safety and Health 

25 Administration rules for industrial safety, such as mitigation measures for asphyxiation concerns

26 and working in an enclosed space or with overhead loads). The impacts to human health for 

27 each of these new issues from continued plant operations are SMALL.

28 In response to the NRC staff’s RAI, Entergy indicated that the use and storage of chemicals at 

29 IP2 and IP3 are controlled in accordance with Entergy’s chemical control program procedure 

30 and appropriate industrial safety procedures to ensure that necessary practices are taken to 

31 protect the plant workers from exposure to hazardous chemicals. These practices can entail the 

32 use of personal protection equipment; industrial hygiene monitoring; or respiratory protection, as 

33 appropriate, based on the specific chemical hazards. In addition to the chemical storage 

34 requirements specified in Entergy’s chemical control program procedure, IP2 and IP3 also have 

35 site-specific spill prevention plans and waste management procedures to minimize the potential 

36 for a chemical or hazardous waste release into the environment (Entergy 2015a).

37 Wastewater discharges from IP2 and IP3, including wastewater that may contain minimal 

38 amounts of chemicals or metals, are controlled in accordance with a water discharge permit 

39 issued by the State of New York. Sanitary wastewater from the facility is sent to the Village of 

40 Buchanan’s publically owned treatment works system. However, there are a few isolated plant 

41 areas that have their own septic tanks, which are pumped out by a septic company and taken to 

42 an offsite facility for disposal (Entergy 2015a).

43 Workers at or around the IP2 and IP3 site would be involved in non-nuclear work, such as

44 electrical work, electric power line maintenance, repair work, and maintenance activities and, 

45 therefore, would be exposed to some potentially hazardous physical conditions (e.g., falls, 

46 excessive heat, cold, noise, electric shock, and pressure). Entergy maintains an occupational 
New Environmental Issues Resulting from the Revision to 10 CFR Part 51

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1 health and safety program consistent with Occupation Safety and Health Administration 

2 standards to address occupational hazards at IP2 and IP3 (Entergy 2015a).

3 The NRC staff has not identified any new and significant information related to these 

4 nonradiological issues during its independent review of Entergy’s ER and responses to the NRC 

5 staff’s RAIs. The NRC staff concludes that there are no impacts beyond those described in the 

6 2013 GEIS, which concludes that the impacts to human health from chemicals or physical 

7 hazards during the license renewal term are SMALL.

8 Minority and Low-Income Populations

9 With respect to environmental justice concerns, the NRC’s 2013 revision to 10 CFR Part 51 

10 added a new Category 2 issue (“Minority and low-income populations”) to evaluate the impacts 

11 of continued operations and any refurbishment activities during the license renewal term on 

12 minority populations and low-income populations living in the vicinity of the plant. The 

13 environmental justice issue was not evaluated in the 1996 GEIS because guidance for 

14 implementing Executive Order (EO) 12898 (59 FR 7629) was not available before its completion

15 but was listed in Table B–1 of 10 CFR Part 51 as an uncategorized issue. As such, the 

16 previous finding in Table B–1 stated that “[t]he need for and the content of an analysis of 

17 environmental justice will be addressed in plant-specific reviews.” Therefore, environmental 

18 justice was, and continues to be, addressed as a plant-specific issue in each SEIS), including 

19 the 2010 FSEIS (NRC 2010), along with other Category 2 license renewal NEPA issues.

20 Under EO 12898, Federal agencies are responsible for identifying and addressing, as 

21 appropriate, disproportionately high and adverse human health and environmental impacts on 

22 minority and low-income populations. Independent agencies, such as the NRC, are not bound 

23 by the terms of EO 12898 but are, as stated in paragraph 6-604 of the EO, “requested to comply 

24 with the provisions of [the] order.” In 2004, the Commission issued a Policy Statement on the 

25 Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions

26 (69 FR 52040), which states, “The Commission is committed to the general goals set forth in 

27 EO 12898, and strives to meet those goals as part of its NEPA review process.”

28 Section 4.4.6 of the 2010 FSEIS (NRC 2010) describes minority and low-income populations 

29 within 50 mi (80 km) of IP2 and IP3 using information from the 2000 decennial Census. 

30 Updated 2010 decennial Census information on minority and low-income populations residing 

31 within 50 mi (80 km) of IP2 and IP3 is provided below.

32 Minority Population

33 According to 2010 Census data, 53 percent of the U.S. population residing within a 50-mi 

34 (80-km) radius of IP2 and IP3 (approximately 17,231,000 individuals) identified themselves as 

35 minority. The largest minority group was Hispanic or Latino (of any race) (24 percent) followed 

36 by Black or African American (17 percent) (EPA 2015c).

37 According to the U.S. Census Bureau’s (USCB’s) 2010 Census data, minority populations in 

38 Westchester County increased by approximately 63,000 persons and now comprise

39 approximately 43 percent of the total population. The largest increase occurred in the Hispanic 

40 or Latino population (an increase of 44 percent), to 22 percent of the total population, followed 

41 by the Asian population (an increase of 25 percent), to 5 percent of the total population 

42 (USCB 2015).

43 Low-Income Population

44 According to the USCB’s 2012 American Community Survey 5-Year Estimates, approximately 

45 15 percent of individuals residing within a 50-mi (80-km) radius of IP2 and IP3 were identified as 
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1 living below the Federal poverty threshold in 2010 (CAPS 2012). The 2012 Federal poverty 

2 threshold was $23,492 for a family of four (USCB 2015).

3 According to the USCB’s 2013 American Community Survey 1-Year Estimates, 7.2 percent of 

4 families and 9.7 percent of individuals in Westchester County were living below the 2012 

5 Federal poverty threshold. People living in Westchester County had a median household 

6 income average of $84,220 and a per capita income of $47,305 (USCB 2015).

7 Analysis of Impacts

8 Section 4.4.6 of the 2010 FSEIS (NRC 2010) describes potential human health and 

9 environmental effects of license renewal on minority and low-income populations living near IP2 

10 and IP3. The analysis uses the current human health and environmental effects of IP2 and IP3 

11 as a “baseline” for assessing potential impacts to minority and low-income populations during 

12 the period of extended operation. Because current human health and environmental effects to 

13 minority and low-income populations are SMALL and because those effects are expected to 

14 remain unchanged during the period of extended operation, minority and low-income 

15 populations are not expected to experience disproportionately high and adverse impacts during 

16 the period of extended operation.

17 During the adjudicatory proceeding on the IP2 and IP3 license renewal application, an 

18 intervenor filed a contention challenging the adequacy of the NRC staff’s analysis of the 

19 environmental impacts to minority and low-income populations in the 2010 FSEIS, largely 

20 focusing on the consequences of a radiological emergency requiring sheltering-in-place or an 

21 evacuation. The Commission upheld the NRC staff’s analysis, finding, in pertinent part, that the 

22 FSEIS appropriately considered the reasonably foreseeable impacts of license renewal to 

23 minority and low-income populations and that supplementation of the FSEIS was not required

24 (NRC 2015c).

25 Although minority and low-income populations have increased within a 50-mi (80-km) radius of 

26 IP2 and IP3 since publication of the FSEIS in 2010, supplementation of the environmental 

27 justice analysis in the FSEIS is not required because there were neither substantial changes 

28 made to the proposed action, nor did the other environmental analyses conducted for this 

29 supplement identify any new and significant human health and environmental effects.

30 The supplemental site-specific analysis for the license renewal of IP2 and IP3 included a review 

31 of the Entergy ER, the response to the RAI, public comments, and other information and data 

32 gathered during the site visit to IP2 and IP3. The review revealed no new and significant 

33 information about possible human health and environmental effects that would exceed those 

34 previously discussed in the 2010 FSEIS.

35 Greenhouse Gas Emissions and Climate Change

36 The following sections discuss GHG emissions released from operation of IP2 and IP3 and the 

37 environmental impacts that could occur from changes in climate conditions. The cumulative 

38 impacts of GHG emissions on climate are discussed in Section 5.14.12.

39 5.13.1 Revisions to Section 6.2, “Greenhouse Gas Emissions”

40 The lifecycle GHG emission studies and analysis presented in Section 6.2 of the 2010 IP2 and 

41 IP3 FSEIS (NRC 2010) have been updated and included in the 2013 GEIS (Section 4.12.3.1, 

42 “Greenhouse Gas Emissions”). Therefore, the NRC staff is removing the discussion of GHG 

43 emissions presented in Section 6.2 of the 2010 FSEIS in its entirety and is replacing it with an 
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1 evaluation of GHG emissions and climate change impacts at IP2 and IP3, which are presented 

2 in Section 5.13.2 of this supplement.

3 Lines 33-38 on page 6-8, lines 1-39 on page 6-9, lines 1-37 on page 6-10, lines 1-43 on 

4 page 6-11, lines 1-22 on page 6-12, lines 1-5 on page 6-13, lines 1-13 on page 6-14, 

5 lines 1-4 on page 6-15, lines 1-44 on page 6-16, and lines 1-3 on page 6-17 in Section 6.2 of 

6 the FSEIS are deleted.

7 5.13.2 GHG Emissions and Climate Change

8 5.13.2.1 GHG Emissions from License Renewal

9 Gases found in the Earth’s atmosphere that trap heat and play a role in the Earth’s climate are 

10 collectively termed GHGs. GHGs include carbon dioxide (CO2); methane (CH4); nitrous oxide 

11 (N2O); water vapor (H2O); and fluorinated gases, such as hydrofluorocarbons (HFC), 

12 perfluorocarbons (PFC), and sulfur hexafluoride (SF6). The Earth’s climate responds to 

13 changes in concentration of GHGs in the atmosphere as GHGs affect the amount of energy 

14 absorbed and heat trapped by the atmosphere. Increasing GHG concentration in the 

15 atmosphere generally increases the Earth’s surface temperature. Atmospheric concentrations 

16 of carbon dioxide, methane, and nitrous oxide have significantly increased since 1750 

17 (IPCC 2007, 2013). Carbon dioxide, methane, nitrous oxide, water vapor, and fluorinated gases 

18 (termed long-lived GHGs) are well-mixed throughout the Earth’s atmosphere and their impact 

on climate is long-lasting as a result of their long atmospheric lifetime1 19 (EPA 2009b). Carbon 

20 dioxide is of primary concern for global climate change due to its long atmospheric lifetime, and 

21 it is the primary gas emitted as a result of human activities. Climate change research indicates 

22 that the cause of the Earth’s warming over the last 50 years (see Section 5.13.2.2) is the 

23 buildup of GHGs in the atmosphere resulting from human activities (USGCRP 2014;

24 IPCC 2013). The EPA has determined that GHGs “may reasonably be anticipated both to 

25 endanger public health and to endanger public welfare” (74 FR 66496).

26 Plant operations at IP2 and IP3 release GHGs directly and indirectly. Direct GHG emissions are 

27 from sources owned or controlled by the entity, which include emissions from fossil fuels burned 

28 on site, emissions from entity-owned or entity-leased vehicles, and other direct sources. 

29 Indirect GHG emissions are from sources that are not owned or directly controlled by the 

30 reporting entity but that are related to the entity’s activities, such as vendor supply chains, 

31 delivery services, outsourced activities, and employee travel and commuting. Annual total

32 (direct and indirect) GHG emissions at IP2 and IP3 for the 2009 to 2013 period are presented in 

33 Table 5–4. The GHG emission sources include permitted combustion equipment (diesel 

34 generators, boiler, and gas turbines); electrical equipment; and worker vehicles. 

35 Combustion-related sources and vehicles release primarily carbon dioxide; however, electrical 

36 equipment results in fugitive release of sulfur hexafluoride. Fluorinated gases are typically 

37 emitted in small quantities but their impacts could be substantial because of their high global 

38 warming potential (GWP).

39 Additional GHG emission sources present at IP2 and IP3 include refrigerant equipment and 

40 delivery vehicles. However, these are not presented in Table 5–4 because data were not 

41 readily available to quantify emissions. Entergy does not compile data on delivery vehicles 

42 (Entergy 2015a). Refrigerant equipment contains ozone-depleting substances, such as

 

1 Atmospheric lifetime is the average time that a molecule resides in the atmosphere before it is removed 

by chemical reaction or deposition. This can also be thought of as the time that it takes after the 

human-caused emission of a gas for the concentrations of that gas in the atmosphere to return to 

natural levels. Greenhouse gas lifetimes can range from a few years to a few thousand years.
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1 chlorofluorocarbons and hydrochlorofluorocarbons (HCFC), but these substances are typically 

2 excluded from GHG emission inventories (EPA 2014a); estimating GHG emissions from these 

3 substances is complicated because of their ability to deplete ozone (which is also a GHG), thus

4 making their GWPs difficult to quantify. Table 5–4 shows that GHG emissions resulting from 

5 operations at IP2 and IP3 are below the EPA’s reporting threshold of 25,000 MT (27,558 tons)

of carbon dioxide equivalent (CO2eq),

2 6 above which facilities are required to report GHG 

7 emissions to EPA annually in accordance with 40 CFR Part 98.

8 Table 5–4. Estimated Greenhouse Gas Emissions from Operations at IP2 and IP3

Year

Combustion Related 

Sources 

(CO2eq (MT/year))

(a)

Worker Vehicles

(CO2eq (MT/year))

Electrical 

Equipment Related 

Sources 

(CO2eq (MT/year))

(b)

Total 

(CO2eq (MT/year))

(c)

2009 330 4,470 1,250 6,050

2010 750 4,470 3,740 8,960

2011 360 4,470 1,250 6,080

2012 290 4,470 6,230 10,990

2013 490 4,470 N/A 4,960

(a) Sources include diesel generators, pumps, boilers, and gas turbines. Emissions estimated based on annual fuel 

usage.

(b) Represents emissions of sulfur hexafluoride used in electrical equipment. Entergy does not track pounds of sulfur 

hexafluoride added to electrical equipment. Emission values were estimated based on the number of sulfur 

hexafluoride canisters (115 pounds per canister) utilized, assuming the entire canister represents GHG emissions. 

No data are available for 2013.

(c) Total emissions from combustion sources, worker vehicles, and electrical equipment.

Source: Entergy 2015a

9 5.13.2.2 Climate Change Impacts to Resource Areas

10 Climate change is the decades or longer change in climate measurements (e.g., temperature

11 and precipitation) that has been observed on a global, national, and regional level (IPCC 2007a;

12 EPA 2014b; USGCRP 2014). Climate change can vary regionally, spatially, and seasonally 

13 depending on local, regional, and global factors. Just as regional climate differs throughout the 

14 world, the impacts of climate change can vary between locations.

15 On a global level, from 1901 to 2013, average surface temperatures have risen at a rate of 

16 0.15 °F (0.08 °C) per decade, and total annual precipitation has increased at an average rate of 

17 0.2 percent per decade (EPA 2014b). The observed global change in average surface 

18 temperature and precipitation has been accompanied by an increase in sea surface 

19 temperatures, a decrease in global glacier ice, an increase in sea level, and changes in extreme 

20 weather events. Such extreme events include an increase in the frequency of heat waves, 

 

2 Carbon dioxide equivalent (CO2eq) is a metric used to compare the emissions of GHG based on their

GWP. The GWP is a measure used to compare how much heat a GHG traps in the atmosphere. The 

GWP is the total energy that a gas absorbs over a period of time compared to carbon dioxide. CO2eq is 

obtained by multiplying the amount of the GHG by the associated GWP. For example, the GWP of 

methane is estimated to be 21; therefore, 1 ton of methane emission is equivalent to 21 tons of carbon 

dioxide emissions.
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1 heavy precipitation, and minimum and maximum temperatures (IPCC 2007a; USGCRP 2009, 

2 2014; EPA 2014b).

3 In the United States, the U.S. Global Change Research Program (USGCRP) reports that from 

4 1895 to 2012, average surface temperature has increased by 1.3 °F to 1.9 °F (0.72 to 1.06 °C),

5 and since 1900, average annual precipitation has increased by 5 percent (USGCRP 2014). On 

6 a seasonal basis, warming has been the greatest in the winter and spring. Since the 1980s, an 

7 increase in the length of the frost-free season, the period between the last occurrence of 32 °F

8 (0 °C) in the spring and first occurrence of 32 °F (0 °C) in the fall, has been observed for the 

9 contiguous United States; between 1991 and 2011, the average frost-free season was 10 days 

10 longer than that between 1901 and 1960 (USGCRP 2014). Since the 1970s, the United States 

11 has warmed at a faster rate as the average surface temperature rose at an average rate of 0.31 

12 to 0.45 °F (0.17 to 0.25 °C) per decade, and the year 2012 was the warmest on record 

13 (USGCRP 2014; EPA 2014b). Observed climate-related changes in the United States include 

14 increases in the frequency and intensity of heavy precipitation, earlier onset of spring snowmelt 

15 and runoff, rise of sea level in coastal areas, increase in occurrence of heat waves, and a 

16 decrease in occurrence of cold waves (USGCRP 2014).

17 Average air temperatures for the U.S. Northeast region, where IP2 and IP3 are located, 

18 increased by 2 °F (1.1 °C) between 1895 and 2011, and precipitation increased by more than 

19 10 percent (USGCRP 2014). Additionally, the temperature of Northeast coastal waters has

20 warmed by roughly 1.1 °F (0.6 °C) or by about 0.1 °F (0.05 °C) per decade. Between 1958 and 

21 2010, the Northeast experienced a 71-percent increase in heavy precipitation events, the 

22 largest increase of any region in the United States. Other climate-related changes in the 

23 Northeast include a sea level rise by 1 ft (0.3 m) since 1900, a rate that exceeds the global

24 average of 8 in. (20 cm) (USGCRP 2014). The frost-free period has increased by 10 to 14 days 

25 during the 1991 to 2012 timeframe. River flooding in the Northeast region from the 1920s 

26 through 2008 indicate an increasing trend in flooding magnitude. Since the 1980s, the intensity, 

27 frequency, and duration of North Atlantic hurricanes have increased (USGCRP 2014). Increase 

28 in the frequency of hurricanes has been linked to higher sea surface temperatures; however, 

29 numerous interacting factors contribute to hurricane activity, and these complex interactions are 

30 currently being analyzed (USGCRP 2014). Although an increase in the frequency of hurricanes 

31 has been observed, a similar trend in landfall frequency is lacking.

32 The NRC staff analyzed temperature and precipitation trends for the period of 1865 to 2014 in 

33 the Hudson Valley region. Average annual temperatures during this time period show large 

34 year-to-year variations, but a clear upward trend in temperature is observed. Since 1865, 

35 temperatures have increased by 0.2 °F (0.1 °C) per decade (NCDC 2015). Average annual 

36 precipitation also displays year-to-year variations; however, precipitation has increased at a rate 

37 of 0.47 in. (1.2 cm) per decade (NCDC 2015). Average sea level rise along the New York State 

38 coastline is 1.2 in. (3 cm) per decade since 1900 (Horton et al. 2014). Seekell and Pace (2011) 

39 document a long-term warming trend in the Hudson River Estuary of 0.015  ̊C (0.027  ̊F) per 

40 year over the course 63 years (1946 to 2008). Seekell and Pace (2011) have found that 

41 warming of the Hudson is driven by increases in air temperature along with a seasonal 

42 relationship between air temperatures and water temperatures. Changes in air temperatures 

43 had the greatest effect on water temperatures during the spring and summer.

44 Future GHG emission concentrations (emission scenarios) and climate models are commonly 

45 used to project possible climate change. Climate models indicate that over the next few 

46 decades, temperature increases will continue due to current GHG emission concentrations in 

47 the atmosphere (USGCRP 2014). Over the longer term, the magnitude of temperature 

48 increases and climate change effects will depend on both past and future GHG emissions 

49 (IPCC 2007a; USGCRP 2009, 2014).
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1 The Northeast is projected to face continued warming and more extensive climate-related 

2 changes. For the proposed license renewal period for IP2 and IP3 (2013 through 2033 and 

3 2015 through 2035, respectively), climate models (between 2021 and 2050 relative to the 

4 reference period (1971 to 1999)) indicate an increase in annual mean temperature for the 

5 Northeast region of 1.5 to 3.5 °F (0.8 to 1.9 °C) under a low-emission modeled scenario and 

6 2.5 to 3.5 °F (1.4 to 1.9 °C) under a high-emission modeled scenario (NOAA 2013;

7 USGCRP 2014). The predicted increase in temperature during this time period occurs for all 

8 seasons, with the largest increase occurring in the summertime (June, July, and August). 

9 Climate model simulations (for the time period 2021 to 2050) suggest spatial differences in 

10 annual mean precipitation changes for the Northeast. A 0- to 6-percent increase in annual 

11 mean precipitation is projected for both a low- and high-emission modeled scenario, with the 

12 northern areas of the Northeast experiencing the larger increases (NOAA 2013). Although there 

13 is great uncertainty, mean global sea levels are expected to rise 0.5 to 1.5 ft (0.15 to 0.46 m) by 

14 2050 and 1 to 4 ft (0.3 to 1.2 m) by the end of this century (USGCRP 2014). Sea level along the 

15 Northeast coast is projected to rise 0.7 to 1.7 ft (0.2 to 0.5 m) by 2050, depending on the extent 

16 of glacier and ice sheet melt (USGCRP 2014). Future sea level rise has been difficult to predict 

17 and is dependent on the amount of warming; ice melt from glaciers and ice sheets; and local 

18 processes, such as land subsidence or uplift. Projected hurricane activity from models is 

19 uncertain: some models project increases in hurricanes and intensity, whereas others project a 

20 decrease in hurricanes and intensity (USGCRP 2014). However, models are in agreement that 

21 hurricane-associated precipitation will increase.

22 The New York State Energy Research and Development Authority sponsored a technical report 

23 to assess climate change impacts for the State (Horton et al. 2014; Rosenzweig et al. 2011). 

24 The report projects that air temperatures may increase 2.0 to 3.4 °F (1.1 to 1.9 °C) by 2020 and 

25 4.1 to 6.8 °F (2.3 to 3.8 °C) by 2050 for the State of New York. Precipitation is projected to 

26 increase by approximately 1 to 8 percent by the 2020s and 3 to 12 percent by the 2050s, with 

27 much of the additional precipitation occurring during the winter months. Furthermore, sea level 

28 rise along the New York State coastline and in the tidal Hudson River is projected to rise by 3 to 

29 8 in. (7.6 to 20 cm) by 2020 and 9 to 21 in. (23 to 53 cm) by 2050. Regional average sea 

30 surface temperatures surrounding New York are projected (between 2040 to 2069) to increase 

31 by 1.8 to 2.5 °F (1.0 to1.4 °C) for near-shore waters (Rosenzweig et al. 2011). The frequency 

32 and duration of heat waves and intense precipitation events are projected to increase across the 

33 State of New York by 2020 (Horton et al. 2014).

34 Changes in climate have broader implications for public health, water resources, land use and 

35 development, and ecosystems. For instance, changes in precipitation patterns and increase in 

36 air temperature can affect water availability and quality, distribution of plant and animal species, 

37 land use patterns, and land cover; these changes can in turn affect terrestrial and aquatic 

38 habitats. The sections below discuss how future climate change may affect air quality, water 

39 resources, land use, terrestrial resources, aquatic resources, and human health in the region of 

40 interest for IP2 and IP3. Although the exact future climate change is uncertain, the discussions 

41 provided below demonstrate the potential implications of climate change on resources.

42 Air Quality

43 Air pollutant concentrations result from complex interactions between physical and dynamic 

44 properties of the atmosphere, land, and ocean. The formation, transport, dispersion, and 

45 deposition of air pollutants depend in part on weather conditions (IPCC 2007b). Air pollutant 

46 concentrations are sensitive to winds, temperature, humidity, and precipitation (EPA 2009a). 

47 Hence, climate change can impact air quality as a result of the changes in meteorological 

48 conditions.
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1 Ozone has been found to be particularly sensitive to climate change (IPCC 2007b; EPA 2009b). 

2 Ozone is formed, in part, by the chemical reaction between nitrogen oxides (NOx) and VOCs in 

3 the presence of heat and sunlight. Nitrogen oxides and VOC sources include both natural 

4 emissions (e.g., biogenic emissions from vegetation or soils) and human activity-related 

5 emissions (e.g., motor vehicles and power plants). Sunshine, high temperatures, and air 

6 stagnation are favorable meteorological conditions to higher levels of ozone (IPCC 2007b;

7 EPA 2009a). The emission of ozone precursors also depends on temperature, wind, and solar 

8 radiation (IPCC 2007b); both nitrogen oxides and biogenic VOC emissions are expected to be 

9 higher in a warmer climate (EPA 2009b). Although surface temperatures are expected to 

10 increase in the Northeast, this may not necessarily result in an increase in ozone 

11 concentrations. The observed correlation between increased ozone concentrations and 

12 temperature has been found to occur in polluted and urban regions (i.e., those areas where 

13 ozone concentration is greater than 60 parts per billion). Additionally, increases in ozone 

14 concentrations correlated with temperature increases occur in combination with cloud-free 

15 regions and air stagnation episodes (Jacob and Winner 2009; IPCC 2013). Climate models 

16 indicate increases in summertime daily ozone concentrations with climate change for the 

17 Northeast (e.g., Wu et al. 2008) but decreases in annual average ozone concentrations 

18 (e.g., Tagaris et al. 2007). However, increases in summertime daily ozone concentrations due 

19 to climate change have been found to be small (Tagaris et al. 2007).

20 Water Resources

21 Predicted changes in the timing, intensity, and distribution of precipitation would likely result in 

22 changes in surface water runoff affecting water availability and quality across the Northeast. As 

23 discussed above, precipitation is projected to increase across the Northeast. Additionally, 

24 increases in the frequency and intensity of extreme (heavy) precipitation events are projected 

25 across the State of New York. However, changes in precipitation alone do not equate 

26 necessarily to changes in water resources since hydrology is dependent on a number of 

27 interacting factors (Horton et al. 2014). As cited by the USGCRP, in spite of increased annual 

28 average precipitation, the loss of moisture from soils because of higher temperatures along with 

29 increased evapotranspiration from vegetation and increased average number of days without 

30 precipitation is likely to intensify short-term (seasonal or shorter) droughts across the region into 

31 the future (USGCRP 2009, 2014). Such conditions can potentially reduce the amount of water 

32 available for surface runoff and streamflow on a seasonal timeframe. However, increases in 

33 runoff and streamflow have been observed in the Northeast. In addition, the Hudson River has 

34 been identified as a water source with low sensitivity to drought (Rosenzweig et al. 2011).

35 The effects of climate change are projected to significantly increase water demand across most 

36 of the United States. When accounting for projected changes in population along with climate 

37 change, the eastern portion of New York may experience an increase of up to 10 percent in 

38 water demand (Figure USGCRP 2014; Figure 3.11). Furthermore, sea level rise can lead to 

39 increased saltwater advance, altering the location of the salt line (front) of the Hudson River, 

40 and to a decline in freshwater dilution downstream (Rosenzweig et al. 2011). As for water 

41 quality implications, increases in the frequency of very heavy precipitation events can result in 

42 increases in the runoff of nutrients, sediment, and other contaminants into surface water, which 

43 can lower the overall water quality (USGCRP 2014).

44 Climate change impacts on groundwater availability depends on basin geology, frequency and 

45 intensity of high rainfall periods, recharge, soil moisture, and interaction between groundwater

46 and surface water (USGCRP 2014). Precipitation and evapotranspiration are key drivers in 

47 aquifer recharge. Although exact responses in groundwater storage and flow to climate change 

48 are not well understood, recent studies have started to consider the effects that climate change 

49 has on groundwater resources (USGCRP 2014). Average annual recharge is expected to 
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1 remain the same with climate change, although there may be changes in the yearly timing of 

2 recharge (Horton et al. 2014). With much of the additional precipitation forecast to occur during 

3 the winter months across New York State, at least a portion of this precipitation would fall as 

4 snow. As a result, much of the snow is likely to slowly melt in place and would not otherwise 

5 suffer significant loss through evapotranspiration during the winter months, contributing

6 positively to groundwater recharge.

7 Sea level rise can also result in saltwater intrusion to coastal aquifers. Flooding and sea water 

8 intrusion from sea level rise and increasing storm surge threaten New York City and many other 

9 cities along the Atlantic Coast (USGCRP 2014).

10 Land Use

11 Anthropogenic land use is both a contributor to climate change, as well as a receptor of climate 

12 change impacts (Dale 1997). As described previously, the Northeast will likely experience rising 

13 temperatures and heavier precipitation events. Growing urban areas will further exacerbate 

14 these changes by continuing to inhibit natural ecosystem functions that could moderate climate 

15 change effects. The USGCRP (2014) indicates that land use changes, such as the continued 

16 expansion of urban areas, paired with climate change effects, such as heavier precipitation 

17 events, can exacerbate climate change effects, including reduced water filtration into the soil 

18 and increased surface runoff due to increases in impervious surface area. Although

19 anthropogenic land uses will contribute to climate change in these and other ways, land uses 

20 will also be affected by climate change in several ways. For instance, plant winter hardiness 

zones3 21 are likely to shift one-half to one full zone by the end of the proposed license renewal 

22 period (USGCRP 2014). This shift could affect the ability of native plant species to grow and 

23 could result in the introduction of new, non-native species (USGCRP 2014). Such changes in 

24 land cover and expansion of exurban and suburban areas could reduce the quality and 

25 availability of land resources and agricultural productivity. Changes or fluctuations in river water 

26 and sea levels could cause land use changes along affected water bodies and impacts to 

27 infrastructure. Such changes could necessitate infrastructure redesign and replacement. 

28 However, the limited extent of climate change that could occur during the 20-year license 

29 renewal term would not cause any significant land use changes in the vicinity of the IP2 and IP3

30 site.

31 Aquatic Resources

32 This discussion supplements subsection, “Climate Change,” of Section 4.8.1, “Cumulative 

33 Impacts on Aquatic Resources,” and Appendix H.2 of the 2010 FSEIS (NRC 2010).

34 The future impacts of climate change on the aquatic resources of the Hudson River will be 

35 complex due to the number of environmental factors that could change and the diversity of 

36 aquatic life in the river that will be affected. Because the understanding of how all the 

37 environmental drivers affect the interconnected web of aquatic life is incomplete, much cannot 

38 be predicted, but some effects of climate change have already been observed, and these 

39 provide some basis for predicting future impacts.

40 The introduction to this section discusses some specific stressors to Hudson River aquatic 

41 resources associated with climate change that have already been observed and are predicted to 

42 continue. Primarily, these stressors are increase in earth surface temperature, sea level rise in 

43 the Northeast region of the United State, an increase in heavy precipitation events, an increase 

44 in the length of the frost-free season, and long-term warming of the waters of the Hudson River 

 

3 Plant hardiness zones represent the geographic area in which certain categories of plant life are likely 

to grow based on the climate of the area.
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1 estuary. For example, Seekell and Pace (2011) documented a long-term warming trend in the

2 Hudson River Estuary of 0.015  ̊C (0.027  ̊F) per year over the course of 63 years (1946 to 

3 2008). Sea level rise along the New York State coastline and in the tidal Hudson River, regional 

4 sea surface temperature rise surrounding New York, and climatic changes are summarized 

5 above. Another observed aspect of climate change that affects aquatic resources is 

6 acidification of water resulting from dissolution of atmospheric carbon dioxide.

7 The IP2 and IP3 site lies in the transition zone of the Hudson River estuary where freshwater 

8 meets saltwater; therefore, the aquatic ecology can be complicated. For example, Waldman et 

9 al. (2006) found that, as of 2005, 212 fish species had been reported from the Hudson River 

10 drainage, and they classified those species into 12 groups based on zoogeographic origins. 

11 Some are resident in the river and estuary, some are migrants, and some are strays. In regard 

12 to salinity preference and residence, fish may be grouped as freshwater species, marine 

13 species, estuarine species (some of which migrate within the estuary), and diadromous species 

14 (those that spawn in freshwater but migrate to the sea and those that do the opposite). The 

15 invertebrate fauna is more complex. As examples, Strayer (2006) reports approximately 

16 300 species of macrobenthic invertebrates alone from the tidal freshwater portion of the Hudson 

17 River estuary, and Cerrato (2006) reports 328 marine benthic species from the Lower Hudson 

18 River Bay Complex. These groups of bottom-living animals exhibit a wide array of body sizes 

19 and shapes, life histories, ecologies, and taxonomy.

20 Rose (2005) examined data for 141 fish species of the temperate to subarctic North Atlantic 

21 Ocean. He found evidence of distributional changes of some species due to climate change 

22 and identified groups of species that might be expected to react differently due to climate 

23 change. He notes that climate variability and change and their effects may not be uniform over 

24 the North Atlantic and that changes in the distribution of forage fish species may have major 

25 influences on ecosystem structure and the productivity of species that feed on them.

26 The National Marine Fisheries Service (NMFS) (2009) found sustained perturbations in the 

27 Northeast U.S. Continental Shelf Large Marine Ecosystem (NES LME) due to environmental 

28 and anthropogenic impacts over the last 4 decades. The NMFS found that thermal conditions in 

29 the NES LME are changing due to warming of coastal and shelf waters and cooling in the 

30 northern end of the range that have resulted in a constriction of thermal habitats in the 

31 ecosystem, a northward shift in the distributions of some fish species, and a shift to a warmer

32 water fish community. In concert with the climate and physical process acting over the North 

33 Atlantic basin, zooplankton community structures and some components of benthic 

34 communities have changed. The NMFS reports a pronounced shift from a demersal 

35 fish-dominated community to one dominated by elasmobranchs (sharks and rays) and pelagic 

36 fish and from a fish community that has also been affected by a persistent change in conditions 

37 from one that favors temperate-cold water fish species to one favoring warmer water species. 

38 In addition to climate change, the NMFS cites overfishing of marine stocks as a driver of these 

39 changes. Such changes affect the Hudson River aquatic resources not only through the 

40 intrusion of sea water and marine species into the lower estuary but also through the migration 

41 of diadromous species between fresh water and the sea. Several diadromous species occur 

42 seasonally in the river near IP2 and IP3.

43 Nye et al. (2009) reported specifically on the results of the NMFS’s investigations on spatial 

44 distribution of fish stocks on the Northeast U.S. continental shelf in relation to climate and 

45 population size from 1968 through 2007. Of 36 fish stocks examined, 24 display statistically 

46 significant changes consistent with warming as indicated by a poleward shift in the center of

47 biomass and an increase in mean depth of occurrence, and two more show weak indications of 

48 distributional changes consistent with warming. Some of these species occur in the lower 
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1 Hudson River estuary, and two, American shad (Alosa sapidissima) and alewife (Alosa 

2 pseudoharengus), are regular seasonal migrants that occur in the river near IP2 and IP3.

3 Overholtz et al. (2011) have found changes in the distribution or the Northwest Atlantic stock of 

4 Atlantic mackerel (Scomber scombrus), which occurs from Cape Hatteras to Newfoundland and 

5 migrates great distances on a seasonal basis. During a period of over 40 years (1968 through 

6 2008), the distribution of the stock has shifted about 250 km (155 mi) to the north and east. The 

7 depth distribution of the stock has also changed from deeper off-shelf locations to shallower 

8 on-shelf ones. These areal and bathymetric changes in distribution correlate with interannual 

9 temperature variability and gradual warming. Waldman et al. (2006) report the occurrence of 

10 Atlantic mackerel in the Hudson River estuary as “temperate marine strays.”

11 O’Connor et al. (2012) examined the effects of climate change on the Hudson River estuary fish 

12 community over 32 years from 1974 through 2005 using data from the sampling surveys done 

13 by the Hudson River electric utilities; these surveys are the same ones that the NRC staff 

14 examined in other sections of this supplement. O’Connor et al. chose a variety of resident 

15 marine, freshwater, and anadromous fish species and life stage combinations to represent the 

16 fish community. They found that the Hudson River estuary fish community has changed 

17 significantly over the 32-year time period and that similar changes have been reported in other 

18 estuaries. They examined 20 species life stage combinations and found that changes correlate 

19 with local hydrology (freshwater flow and water temperature) and regional climate.

20 Invertebrates and fish are affected by climate change. The distribution of blue crabs 

21 (Callinectes sapidus) is also moving north. Blue crab is a commercially and recreationally 

22 important invertebrate species that occurs in the Hudson River and is sometimes impinged at 

23 IP2 and IP3. Johnson (2015) has documented that the northern range of the blue crab has 

24 moved northward from its historic limit, although it is too early to determine whether this change 

25 is permanent or ephemeral. The effects of global warming on invertebrates are not limited to 

26 blue crabs. Byrne (2011) finds that marine and estuarine invertebrates in general are adversely 

27 affected by climate change. Global warming and increased atmospheric carbon dioxide levels 

28 have deleterious effects through the direct effect of water temperature on metabolism and the 

29 narcotic effect of increased levels of dissolved carbon dioxide. Increased levels of dissolved 

30 carbon dioxide react with water and cause ocean acidification and decreases in the availability 

31 of carbonate ions that larvae require to build skeletons. Increased acidification also affects 

32 metabolism directly. These processes can affect persistence and stability of aquatic 

33 ecosystems, species invasions, and community function.

34 In summary, the effects of climate change and increased levels of carbon dioxide on the aquatic 

35 resources of the Hudson River are already observable. The NRC staff expects that effects will 

36 continue through the proposed license renewal period. The aquatic resources of the Hudson 

37 River estuary are diverse. The responses to environmental stressors and the interactions within 

38 and among the populations are complex. Because of these complexities, the NRC staff cannot 

39 predict the future responses of aquatic resources to climate change and increased levels of 

40 carbon dioxide.

41 Terrestrial Resources

42 As described above, the Eastern United States will likely experience rising temperatures, rising 

43 sea levels, more precipitation, and heavier precipitation events during the proposed license 

44 renewal period. As the climate changes, terrestrial resources either will need to be able to 

45 tolerate the new physical conditions or shift their population range to new areas with a more 

46 suitable climate. Scientists currently estimate that species are shifting their ranges at a rate of 

47 between 6.1 to 11 m (20 to 36 ft) in elevation per decade and 6.1 to 16.9 km (3.8 to 10.5 mi) in 

48 latitude per decade (Chen et al. 2011; Thuiller 2007). A study by Woodall et al. (2009) suggests 
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1 that northward tree migration is currently underway at a rate of 100 km (62-mi) per century for 

2 many species. Although some species may readily adapt to a changing climate, others may be 

3 more prone to experience adverse effects. For example, species whose ranges are already 

4 limited by habitat loss or fragmentation or that require very specific environmental conditions 

5 may not be able to successfully shift their ranges over time. Migratory birds that travel long 

6 distances may also be disproportionately affected because they may not be able to pick up on 

7 environmental clues that a warmer, earlier spring is occurring in the United States while 

8 overwintering in tropical areas. Fraser et al. (2013) found that songbirds overwintering in the 

9 Amazon did not leave their winter sites earlier, even when spring sites in the Eastern United 

10 States experienced a warmer spring. As a result, the song birds missed periods of peak food 

11 availability. Special status species and habitats, such as those that are Federally protected by 

12 the ESA, would likely be more sensitive to climate changes because these species’ populations 

13 are already experiencing threats that are endangering their continued existence throughout all 

14 or a significant portion of their ranges. For instance, in its final rule to list the red knot (Calidris 

15 canutus rufa), a shorebird that migrates through the Eastern United States during fall and 

16 spring, the U.S. Fish and Wildlife Service cites several effects resulting from climate change as 

17 factors contributing to the species’ decline (79 FR 73706). These effects include habitat loss 

18 from sea level rise, asynchronies in the timing of annual cycles, and increased frequency of 

19 severe storm events. Climate changes could favor non-native, invasive species and promote 

20 population increases of insect pests and plant pathogens, which may be more tolerant to a 

21 wider range of climate conditions. For instance, Albani et al. (2010) anticipate that climate 

22 change will enable the hemlock wooly adelgid (Adelges tsugae), an insect that has killed many 

23 eastern hemlocks (Tsuga canadensis) in recent years, to expand its range. Sea level rise could 

24 reduce threaten wetland, floodplain, and riparian habitats in the Eastern United States. 

25 Reductions in these habitats, which serve as natural buffers against storm surges, could 

26 exacerbate effects to inland habitats, especially given that the intensity of storm events in the 

27 Eastern United States is likely to increase.

28 Historic and Cultural Resources

29 Increases in sea and river water levels because of changes in meteorological conditions due to 

30 climate change could result in the loss of historic and cultural resources from flooding, erosion, 

31 or inundation. Some resources could be lost due to erosion and inundation from sea and river 

32 water level changes before they could be documented or otherwise studied. However, as 

33 discussed above, future sea level changes are uncertain. The limited extent of climate change

34 that could occur during the 20-year license renewal term would not have a significant effect on 

35 historic and cultural resources at the IP2 and IP3 site.

36 Socioeconomics

37 Rapid changes in climate conditions could have an impact on the availability of jobs in certain 

38 industries. For example, tourism and recreation are major job creators in some regions, 

39 bringing billions of dollars to regional economies. Climate change, including changes in sea 

40 temperature and water levels, could affect the unique economic characteristics of coastal areas. 

41 Across the Nation, fishing, hunting, and other outdoor activities make important economic 

42 contributions to rural economies and are also a part of the cultural tradition. A changing climate 

43 would mean reduced opportunities for some activities in some locations and expanded 

44 opportunities for others. Hunting and fishing opportunities could also change as animals’ 

45 habitats shift and as relationships among species are disrupted by their different responses to 

46 climate change (USGCRP 2014). For instance, surface water thermal changes might cause a 

47 northward shift of fish; changes in the abundance and distribution of fish can potentially affect

48 commercial and recreational fishing (USGCRP 2014). Water-dependent recreation could also 

49 be affected (USGCRP 2009). Coastal area economies are also sustained by the income from 
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1 tourism, recreation, and seaport commerce. Sea level rise, which increases coastal erosion, 

2 along the Northeast region is projected to rise 0.7 to 1.7 ft (0.2 to 0.5 m) by 2050; and hurricane 

3 rainfall and intensity is also projected to increase (USGCRP 2014). A changing climate 

4 resulting in stronger storms, coastal erosion, inundation, and flooding could damage seaports 

5 and reduce beach attractiveness. However, the limited extent of climate change that could 

6 occur during the proposed 20-year license renewal term would not cause any significant 

7 changes in socioeconomic conditions in the vicinity of the IP2 and IP3 site.

8 Human Health

9 Increasing temperatures due to changes in climate conditions could have an impact on human 

10 health. However, changes in climate conditions that may occur during the proposed license 

11 renewal term will not result in any change to the impacts from IP2 and IP3 radioactive and 

12 nonradioactive effluents.

13 Environmental Justice

14 Rapid changes in climate conditions could disproportionately affect minority and low-income 

15 populations. Sea level rise has the potential to place communities in coastal areas at risk from 

16 storms, coastal erosion, inundation, and flooding. Specifically, minority and low-income 

17 communities in coastal areas may be more vulnerable to the impacts of climate change 

18 because of their inability to afford property insurance and other protective measures. Sea level 

19 rise and inundation of coastal lands could also cause the displacement of minority and 

20 low-income communities, resulting in reduced contact and declining community cohesiveness 

21 (USGCRP 2014).

22 The USGCRP (2014) indicates that “infants and children, pregnant women, the elderly, people 

23 with chronic medical conditions, outdoor workers, and people living in poverty are especially at 

24 risk from a variety of climate related health effects.” Examples of these effects include 

25 increased heat stress, air pollution, extreme weather events, and diseases carried by food, 

26 water, and insects. The greatest health burdens related to climate change are likely to fall on 

27 the poor, especially those lacking adequate shelter and access to other resources, such as air 

28 conditioning. Elderly people living on fixed income, who are more likely to be poor, are more 

29 likely to have debilitating chronic diseases or limited mobility. In addition, elderly people can 

30 have a reduced ability to regulate their own body temperature or sense when they are too hot. 

31 According to the USGCRP (2009), they “are at greater risk of heart failure, which is further 

32 exacerbated when cardiac demand increases in order to cool the body during a heat wave.” 

33 The USGCRP (2009) study also found that people taking medications, such as diuretics for high 

34 blood pressure, have a higher risk of dehydration.

35 The USGCRP (2014) study reconfirmed the previous report findings regarding the risks of 

36 climate change on low-income populations and also warns that climate change could affect the 

37 availability and access to local plant and animal species, thus affecting the people who have 

38 historically depended on them for food or medicine. However, because of the limited extent of 

39 climate change that could occur during the proposed 20-year license renewal term, minority and 

40 low-income populations living near the IP2 and IP3 site are not expected to experience 

41 disproportionately high and adverse impacts.

42 Cumulative Impacts

43 Cumulative impacts are those that result from the incremental impact of an action when added 

44 to other past, present, and reasonably foreseeable future actions, regardless of what agency 

45 (Federal or non-Federal) or person undertakes such other actions. As discussed in Section 5.0 

46 of this supplement, the revised GEIS (NRC 2013a) and final rule (78 FR 37282) amended 
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1 Table B–1 in Appendix B to Subpart A of 10 CFR Part 51 by adding cumulative impacts as a 

2 new Category 2 issue subject to site-specific review during license renewal.

3 Section 4.8 of the 2010 FSEIS (NRC 2010) addresses potential cumulative impacts that could 

4 occur in conjunction with IP2 and IP3 license renewal, including the contributory effects of 

5 several Federal projects and activities described in Section 2.2.10 of the FSEIS. The following 

6 sections of this supplement update the cumulative impacts analysis presented in the 

7 2010 FSEIS.

8 The table below identifies new actions and projects considered in the NRC staff’s analysis of 

9 cumulative impacts in this supplement related to the environmental analysis of the continued 

10 operation of IP2 and IP3. These new actions and projects are in addition to those previously 

11 considered in Sections 2.2.10 and 4.8 of the 2010 FSEIS.

12 Table 5–5. Actions and Projects Considered in the Cumulative Impacts 

13 Analysis Subsequent to the Issuance of the 2010 FSEIS

Project Name Summary of Project

Approximate 

Location (Relative to 

IP2 and IP3)

Status

Electrical Distribution Projects

Champlain Hudson

Power Express Project 

1,000-MW 

high-voltage 

transmission system 

extending 335 mi 

(539 km), primarily 

underground, from the 

Canadian border to the 

New York City 

Metropolitan area. 

Cables would be 

buried along existing 

ROWs and within 

several waterbodies, 

including the Hudson 

River. 

0.7 mi (1.1 km) 

northwest of the IP2 

and IP3 site at the 

nearest location

Proposed construction

from 2015 to 2017 

(FERC 2015; TDI 2015)

West Point

Transmission Project

1,000-MW

high-voltage 

transmission system 

from Athens to 

Cortlandt, New York. 

The line would be 

buried in the Hudson 

River for 74 mi 

(119 km).

0.5 mi (0.8 km) 

southwest of the IP2 

and IP3 site at the 

nearest location

Proposed construction

in 2016 (FERC 2015; 

Times-Herald 

Record 2013)

Natural Gas Energy Projects

Algonquin Incremental 

Market (AIM) Project

Construction and 

operation of 37.4 mi 

(60.2 km) of a natural 

gas pipeline and 

associated equipment 

and facilities in New 

York, Connecticut, and 

Massachusetts.

Proposed to cross 

southern portion of the

IP2 and IP3 site

Proposed construction

from 2015 to 2016 

(FERC 2015)
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Project Name Summary of Project

Approximate 

Location (Relative to 

IP2 and IP3)

Status

NRG Bowline 

Repowering Project

Modernization of the 

existing 580-MW 

peaking plant to 

produce two 500-MW 

natural gas 

combined-cycle plants.

4.5 mi (7 km) 

south-southwest of the 

IP2 and IP3 site on the

Hudson River

Proposed but no 

established 

construction/operating 

schedule (FERC 2015; 

Reuters 2013)

Water Supply and Treatment Facilities

Haverstraw Water

Supply Project

Proposed water 

treatment plant, intake 

pumping station, and 

transmission and 

distribution mains. It 

would provide up to 

7.5 million gallons of 

potable water per day 

to Rockland County.

4 mi (6.5 km) 

south-southwest of the

IP2 and IP3 site with 

water intake on 

Hudson River

Undetermined

(FERC 2015; 

HWSP 2012)

Manufacturing Facilities

U.S. Gypsum Company 

dredging activities

Maintenance dredging 

of an access channel 

(approximately once 

every 5 years).

3 mi (4.8 km) 

south-southwest of the 

IP2 and IP3 site

Ongoing (FERC 2015)

IP2 and IP3 Projects

Expansion of the 

existing independent 

spent fuel storage 

installation at IP2 and 

IP3

Expansion of the dry 

spent fuel storage 

facility to handle 

additional spent 

nuclear fuel generated 

during the license 

renewal term.

On the IP2 and IP3 site Undetermined

(Entergy 2015a)

Other Projects

Future Urbanization Construction of 

planned residential, 

commercial, and 

industrial 

developments and the 

associated 

transportation and 

utility infrastructure 

and the water and 

wastewater treatment 

and distribution 

facilities.

Throughout the region Future construction as 

described in State and 

local land use planning 

documents

1 Potential cumulative impacts associated with these new actions and projects are discussed in 

2 the following subsections. Not all actions or projects listed in this table are considered in each 

3 resource area because of the uniqueness of the resource and its geographic area of 

4 consideration.
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1 5.14.1 Air Quality and Noise

2 5.14.1.1 Air Quality

3 This section addresses the direct and indirect effects of license renewal on air quality when 

4 added to the aggregate effects of other past, present, and reasonably foreseeable future 

5 actions. Air quality designations for criteria air pollutants are generally made at the county level. 

6 Therefore, the geographic area considered in the cumulative air quality analysis is the County 

7 where IP2 and IP3 are located, Westchester County, New York. With regard to NAAQS, 

8 Westchester County is designated a nonattainment area for ozone and a maintenance area for 

9 carbon monoxide and PM2.5 (EPA 2015a). Furthermore, New York is part of the OTR. The 

10 OTR is established in Section 184 of the CAA and requires those States in the OTR to take 

11 steps to control interstate transport of air pollutants that form ozone.

12 As noted in Section 5.1.3 of this supplement, the incremental impacts from the proposed license 

13 renewal would be SMALL. Entergy does not anticipate increases of air emissions associated 

14 with continued operation with IP2 and IP3 during the license renewal period (Entergy 2015a). 

15 Any unforeseen increases from future activities at IP2 and IP3 that may increase air emissions 

16 would require an air permit from NYSDEC, and additional emissions will be limited and in 

17 accordance with the requirements set forth in the air emissions permit.

18 Table 5–5 above and Section 2.2.10 of the 2010 FSEIS identify present and reasonably 

19 foreseeable projects that could contribute to cumulative impacts to air quality. Although project 

20 timing and location are difficult to predict, some of the activities in Table 5–5 can have 

21 cumulative impacts to air quality. Construction of the projects identified in Table 5–5 will emit air 

22 pollutants as a result of diesel or gasoline exhaust from construction equipment, land clearing 

23 and excavation, and worker vehicle emissions. However, air emissions will be temporary 

24 (through the duration of construction), intermittent, and localized. Therefore, potential emissions 

25 resulting from construction-related activities associated with these projects/activities are not 

26 anticipated to significantly affect air quality.

27 Operation of the natural gas combined-cycle plants identified in Table 5–5 will emit criteria 

28 pollutants (nitrogen oxides, sulfur dioxide, carbon monoxide, and PM) and could qualify as a 

29 major emitting industrial facility that would be subject to a New Source Review under 

30 requirements of the CAA. Air emissions from these facilities will need to be permitted in 

31 accordance with State and Federal regulatory requirements, and compliance with such 

32 requirements and permits will minimize impacts to air quality.

33 Operation of the Algonquin Incremental (AIM) project will result in additional air emissions both 

34 within and outside of the geographic area considered in this air quality cumulative analysis 

35 (Westchester County). Emissions would result from the operation of new and current 

36 compressor units, meter and regulating stations, and fugitive releases from the pipeline and 

37 components. Although the operation of the AIM project will require major or minor New Source 

38 Review permits, the Federal Energy Regulatory Commission concluded that operational 

39 emissions for the project would not contribute to a violation of NAAQS (FERC 2015). 

40 Furthermore, as a result of modifications of existing equipment, removal of existing compressors 

41 at compressor stations near IP2 and IP3, or both, emissions will be reduced from their current 

42 levels for those specific project locations (FERC 2015). While the Haverstraw Water Supply 

43 Project would be located outside the geographic area of analysis, it is considered in this air 

44 quality cumulative impact analysis because of its proximity to IP2 and IP3 (approximately

45 5 miles) and Westchester County. Operation of the water treatment plant will emit pollutants as 

46 a result of testing and operation of emergency diesel generators and mobile sources 

47 (e.g., delivery trucks and employee vehicles); however, emissions from the generators are 
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1 anticipated to be a minor air source that will not exceed major air source thresholds. Further,

2 mobile source emissions were concluded to not have a significant impact on air quality 

3 (HWSP 2012). With respect to the New York/New Jersey/Philadelphia Metropolitan Area 

4 Airspace Redesign project, the U.S. Department of Transportation (DOT)/Federal Aviation 

5 Administration (FAA) determined that the project would not result in emissions that would 

6 exceed applicable de minimis emission levels and, therefore, will not cause a new violation, 

7 worsen an existing violation, or delay meeting the NAAQS (DOT/FAA 2007a). Development 

8 and construction activities associated with regional growth of housing, business, and industry, 

9 as well as associated vehicular traffic, will also result in additional air emissions.

10 As discussed in Section 5.13 of this supplement, climate change can impact air quality as a 

11 result of the changes in meteorological conditions. Specifically, ozone has been found to be 

12 particularly sensitive to climate change. Increases in ground-level ozone depend on a number 

13 of factors, including background ozone concentrations, temperature, air stagnation events, and 

14 solar insolation. Computer models project decreases in annual average concentrations for the 

15 Northeast region (e.g., Tagaris et al. 2009) but increases in summertime ozone concentrations 

16 (e.g., Wu et al. 2008; Sheffield et al. 2011). In other words, seasonal (summertime) or 

17 short-term increases in ozone concentrations may occur. Westchester County, as discussed 

18 above, is designated a nonattainment area for ozone. Projections specific to Westchester 

19 County, under a high-emissions modeled scenario, project a 7-percent increase in summertime 

20 (June, July, and August) ozone concentrations by the 2020s (Sheffield et al. 2011).

21 The NRC staff concludes that the incremental impacts to air quality from the proposed license 

22 renewal of IP2 and IP3 would be SMALL. However, the NRC staff concludes that the 

23 cumulative impacts from past, present, and reasonably foreseeable future actions on air quality 

24 during the license renewal term would be SMALL to MODERATE. A SMALL impact would be 

25 expected under the condition of minimal climate change impacts on air pollutants with the 

26 lowest emissions scenario and compliance of major emitting industrial facilities with air permits 

27 to minimize impacts to air quality. Given Westchester County’s designated nonattainment area 

28 for ozone, a MODERATE impact would be expected under the condition that climate change 

29 increases concentrations of ozone, thus worsening current ozone air quality conditions in 

30 Westchester County.

31 5.14.1.2 Noise

32 This section addresses the direct and indirect effects of license renewal on noise when they are 

33 added to the aggregate effects of other past, present, and reasonably foreseeable future 

34 actions. The geographic area considered in the cumulative noise analysis is a 1-mi (1.6-lm) 

35 radius from IP2 and IP3.

36 Principal noise sources from nuclear power plant operation include transformers, loudspeakers, 

37 and auxiliary equipment (e.g., pumps). At IP2 and IP3, noise sources are intermittent and 

38 typically not audible, with the exception of emergency sirens, beyond the site boundary 

39 (Entergy 2015a). The nearest resident is approximately 715 m (0.44 mi) from IP2 and IP3 

40 (Entergy 2014g). Ambient sound levels (L90) measured at sensitive noise receptors in the 

41 vicinity of IP2 and IP3 ranged between 36 to 61 A-weighted decibels (dBA) (Enercon 2003). 

42 Sound levels below 60 dBA are typically considered comfortable.

43 Noise levels may increase as a result of refurbishment activities, such as reactor vessel head, 

44 control rod drive mechanism replacement, and construction of a storage building, due to 

45 additional worker vehicles and motorized and construction equipment needed for these 

46 activities. Increased traffic volumes due to the additional 250 workers needed during 

47 refurbishment activities can increase noise levels on U.S. Highway 9 and roads near IP2 and 

48 IP3. Noise emissions from common construction equipment could be in the 85- to 100-dBA 
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1 range (FHWA 2006); however, noise levels attenuate rapidly with distance. For instance, a 

2 noise level of 80 dBA at a distance of 50 ft (15 m) from construction equipment drops to 

3 65.5 dBA at a distance of 200 ft (60 m) from the same construction equipment (FHWA 2006). 

4 Noise impacts from refurbishment are anticipated to be minimal because they would be 

5 intermittent (during use of equipment and workers commuting time) and temporary because

6 they would only last through the duration of refurbishment (60 days). Additionally, the activities 

7 associated with refurbishment will occur inside buildings and, therefore, are not anticipated to be 

8 audible beyond the site boundary (Entergy 2015a). Furthermore, any additional noise due to 

9 refurbishment activities would need to be in accordance with the Buchanan sound ordinance 

10 (Chapter 211-23 of the Village Zoning Code). Given the distance of the nearest resident, 

11 attenuations of noise with distance, short-term duration of refurbishment activities, and location 

12 of activities, noise from refurbishment activities are not anticipated to cause noise issues.

13 The cumulative impacts on noise depend on the nuclear plant’s proximity to other noise 

14 sources. Ongoing or foreseeable future projects in and around IP2 and IP3 identified in Table 

15 5–5 will increase noise levels in the vicinity of their noise sources. However, the majority of 

16 these projects or activities are beyond the region of influence; therefore, combined noise levels 

17 are not expected to be high enough to cause noise issues. For those projects that are within 

18 the region of influence (the Champlain Hudson Power Express Project, West Point 

19 Transmission Project, AIM Project, and independent spent fuel storage installation (ISFSI)

20 expansion), noise levels can increase as a result of motorized equipment required during 

21 construction of these activities and additional vehicles from the workforce. However, any 

22 additional noise will be temporary, occurring during the period of construction. The DOT/FAA

23 determined that the New York/New Jersey/Philadelphia Metropolitan Area Airspace Redesign 

24 project would result in significant noise and noise-related impacts (DOT/FAA 2007a). However, 

25 mitigation measures were developed to reduce noise impacts (DOT/FAA 2007b).

26 Noise levels from present and future actions are not anticipated to contribute to noise impacts in 

27 the vicinity of IP2 and IP3. Therefore, cumulative impacts on the noise environment are 

28 expected to be SMALL.

29 5.14.2 Geology and Soils

30 This section addresses the direct and indirect effects of license renewal on geology and soils 

31 when they are added to the aggregate effects of other past, present, and reasonably 

32 foreseeable future actions. As described in Section 5.2, the incremental impacts on geology 

33 and soils from the continued operations of IP2 and IP3 during the license renewal term would be 

34 SMALL. Ongoing operation and maintenance activities at the IP2 and IP3 site are expected to 

35 be confined to previously disturbed areas (Entergy 2015a). Any soil-disturbing activities will be 

36 localized to the site and will be minimized by adherence to regulations and permits and the use 

37 of BMPs.

38 Any use of geologic materials, such as aggregates, to support operation and maintenance 

39 activities would be procured from local and regional sources. These materials are abundant in 

40 the region. The continued operations of IP2 and IP3 would not prevent access to economically 

41 valuable mineral resources.

42 Future changes in climate are unlikely to change the soils or result in changes to site operations 

43 that could affect local soils. Geologic conditions are not expected to change during the license 

44 renewal term. Thus, activities associated with continued operations are not expected to affect 

45 the geologic environment. Considering ongoing activities and reasonably foreseeable actions, 

46 the NRC staff concludes the cumulative impacts on geology and soils during the IP2 and IP3 

47 license renewal term would be SMALL.
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1 5.14.3 Surface Water

2 This section addresses the direct and indirect effects of the proposed action (license renewal) 

3 on surface water resources when they are added to the aggregate effects of other past, present, 

4 and reasonably foreseeable future actions.

5 As described in Section 4.1 of the 2010 FSEIS (NRC 2010), the incremental impacts on surface 

6 water resources from continued operations of IP2 and IP3 during the license renewal term were 

7 projected to be SMALL for all Category 1 (generic) issues, with the impacts on those issues 

8 determined to be bounded by those discussed in the 2013 GEIS. No Category 2 (site-specific) 

9 issues were deemed applicable to IP2 and IP3 operations.

10 As discussed in Section 5.14 of this supplement, the NRC staff has updated its review and 

11 evaluation of additional projects and actions in determining their contribution to cumulative 

12 impacts on surface water resources (see Table 5–5). The NRC staff’s assessment included 

13 consideration of Entergy’s responses to the NRC staff’s RAIs (Entergy 2015a) and a review for 

14 new and significant information.

15 The descriptions of the affected environment in Sections 2.2.2, 2.2.3, 2.2.5.1, and 2.2.5.2 of the 

16 2010 FSEIS together serve as the baseline for the cumulative impacts assessment for surface 

17 water resources. A summary of affected environment conditions relevant to this cumulative 

18 impacts analysis is presented below and has been updated as necessary with respect to the 

19 physical descriptions and trends in water resource conditions in proximity to, and affected by,

20 operation of IP2 and IP3.

21 The geographic area of analysis considered for the surface water resources component of the 

22 cumulative impacts analysis spans the lower Hudson River Basin or watershed but focuses on a 

23 5-mi (8-km) radius surrounding the intake and discharge structures for IP2 and IP3. As such, 

24 this review focused on those projects and activities that would withdraw water from, or 

25 discharge effluent to, the lower Hudson River and to its connecting waterways and on the 

26 potential for impacts to ambient surface water quality and water availability for downstream 

27 users. Following a summary of relevant affected environment conditions, the cumulative 

28 impacts on surface water use and quality, along with associated climate change considerations, 

29 are presented below.

30 Affected Environment Considerations

31 As discussed in Section 2.2.5.1 of the 2010 FSEIS (NRC 2010), the Hudson River originates in 

32 the Adirondack Mountains of northern New York State and flows south for 315 mi (507 km) to its 

33 mouth at the Battery, at the south end of the Island of Manhattan. The Hudson River Basin 

34 extends 128 mi (206 km) from east to west and 238 mi (383 km) from north to south and drains 

35 an area of 13,336 square miles (34,540 square kilometers), with most of this area located in the 

36 eastern-central part of New York State and small portions in Vermont, Massachusetts, 

37 Connecticut, and New Jersey.

38 IP2 and IP3 are located within the lower Hudson River Basin, which encompasses the Hudson 

39 River estuary. This tidally influenced portion of the river begins at the Troy Dam near Albany, 

40 New York, at RM 152 (river kilometer (Rkm) 245) and extends south. IP2 and IP3 are located 

41 on the east bank of the Hudson River at RM 43 (Rkm 69) and about 24 mi (39 km) north of New 

42 York City (see Figure 2–10 in the 2010 FSEIS). In the vicinity of the IP2 and IP3 site, the 

43 Hudson River estuary is approximately 4,500 ft (1,370 m) wide and averages 40 ft (12 m) deep. 

44 This stretch of the river is characterized as oligohaline (i.e., low salinity). The salt front (or 

45 wedge) is the location where freshwater flowing toward the mouth of the river intersects the 

46 denser seawater pushing up the Hudson River estuary, creating a distinct boundary. Its edge is 

47 defined at the point where the measured salt concentration is 100 milligrams per liter. With high 
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1 runoff in the spring, the salt front is typically found between RM 17 and RM 27 (Rkm 27 

2 and Rkm 43) and migrates north during the summer past the IP2 and IP3 site to just south of 

3 Poughkeepsie near RM 75 (Rkm 121). Drought conditions may enable the front to move further 

4 north past Poughkeepsie (Entergy 2007a; NRC 2010; NYSDEC 2015d, 2015e).

5 The flow and salinity in the lower Hudson are influenced by tidal flux and excursion that typically 

6 can result in water movement of 3 to 6 mi (5 to 10 km) or more upstream during the tidal cycle. 

7 This tidal flux prevents an accurate measurement of freshwater flow in the lower estuary and in 

8 the vicinity of IP2 and IP3. However, freshwater flow is measured upstream of the IP2 and IP3 

9 site by the USGS at Green Island, New York, and just upstream from the Troy Lock and Dam. It 

10 is the farthest downstream USGS gage on the Hudson above tidewater (NRC 2010). The mean 

11 annual river discharge measured at Green Island, New York, for water years 1946 through 2013 

is 14,380 cubic feet per second (cfs) (406 cubic meters per second (m3 12 /s)). The lowest average 

annual mean flow recorded over the period of record is 6,386 cfs (180 m3 13 /s). The mean 

90-percent exceedance flow is 4,410 cfs (125 m3 14 /s). The 90-percent exceedance flow is an 

15 indicator value of hydrologic drought in a watershed and is the flow rate that is exceeded 

16 90 percent of the time (USGS 2014).

17 Flow in the downriver stretch extending past the IP2 and IP3 site is tidally dominated and 

18 influenced by river channel morphology, a relatively flat water surface elevation, and other 

19 factors. Still, freshwater flow contributions exceed the cited values at the USGS Green Island 

20 gage by virtue of the larger drainage area, minus intervening losses and other diversions. In 

21 total, the tidally driven flow volume of the Hudson River near the IP2 and IP3 site is 

approximately 80 million gpm (303,000 cubic meters per minute (m3 22 /min)), which is equivalent to 

a flow of about 178,000 cfs (5,030 m3 23 /s). This flow is estimated to occur about 80 percent of the 

24 time. In the nearshore waters immediately adjacent to the IP2 and IP3 site corridor, the 

80-percent frequency flow volume is estimated to be 9 million gpm (34,000 m3 25 /min), which is 

equivalent to 20,000 cfs (560 m3 26 /s). This point estimate is for a location that is approximately 

27 500 ft (150 m) from the shoreline and that encompasses the area from which cooling water is 

28 withdrawn and to which return cooling water flows are returned (Entergy 2007a; NRC 2010).

29 With respect to water quality and beneficial use, the segment of the lower Hudson adjacent to 

30 the IP2 and IP3 site is classified by the NYSDEC as Class SB saline waters. The best usages 

31 of Class SB waters are for primary and secondary contact recreation and fishing. New York 

32 State further stipulates that such waters must be suitable for fish, shellfish, and wildlife 

33 propagation and survival (6 NYCRR 701; NYSDEC 2008b, 2014).

34 Nonetheless, and as described in Section 2.2.5.2 of the 2010 FSEIS, water and sediment 

35 quality in the lower Hudson River have been affected by historic and ongoing activities 

36 throughout the watershed and in the main stem of the river. These activities include dredging, 

37 channelization, and dam construction; industrial water use; municipal wastewater treatment 

38 discharges; chemical contaminants; nonpoint pollution; and invasive or exotic species (Entergy 

39 2007a; NRC 2010). The river segment encompassing the IP2 and IP3 site and extending from 

40 Riverdale, New York, to Bear Mt. Bridge is listed as “impaired” by NYSDEC and unable to meet 

41 certain water quality standards pursuant to Section 303(d) of the CWA. Contaminants include 

42 PCBs in contaminated sediment, which result in fish consumption advisories, dioxins/furans, 

43 polycyclic aromatic hydrocarbons, pesticides, mercury, and other heavy metals (NYSDEC 

44 2014).

45 Water Use Considerations

46 The Hudson River is an important regional resource and is extensively used for navigation,

47 transportation, and recreation and as a water supply source. Water is withdrawn from the lower 

48 Hudson River for municipal potable water supply, for industrial makeup and cooling water, and 
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1 for permitted or other authorized municipal and industrial wastewater discharges. As stated in 

2 Section 2.2.5.2 of the 2010 FSEIS, the chemical industry has the greatest number of industrial 

3 users followed by oil, paper, and textile manufacturers; sand, gravel, and rock processors; 

4 power plants; and cement companies (Entergy 2015a; NRC 2010).

5 Power plants are the primary users of water along the Peekskill–Haverstraw portion of the lower 

6 Hudson River. More specifically, the approximately 5-mi (8-km) segment of the Hudson River 

7 along which IP2 and IP3 are located supports several major facilities dominated by 

8 thermoelectric power-generating plants. These include the Wheelabrator Westchester 

9 waste-to-energy facility located approximately 1 mi (1.6 km) north and upstream of the IP2 and 

10 IP3 site. The facility has a generation capacity of about 60 megawatt electric (MWe) and 

withdraws about 40 million gallons per day (mgd) (61 cfs (1.7 m3 11 /s)) of water, with peak daily 

withdrawals of 52 mgd (80 cfs (2.3 m3 12 /s)) (NYDEC 2015f; Wheelabrator Technologies 2015). 

13 Approximately 4 mi (6 km) downstream of IP2 and IP3 is the Bowline Generating Station. It is a 

14 758-MWe natural-gas fired plant (NRG 2015). Like IP2 and IP3, Bowline has a once-through 

cooling system and withdraws an average of 227 mgd (351 cfs (9.9 m3 15 /s)) of water, with a peak 

daily withdrawal of 979 mgd (1,515 cfs (42.8 m3 16 /s)) (NYSDEC 2015f).

17 IP2 and IP3 each employ once-through cooling systems that withdraw water from the Hudson 

18 River, as further described in Section 2.1.3 of the 2010 FSEIS. The combined, maximum 

19 (nominal) surface water withdrawal rate for IP2 and IP3 is 1,731,000 gpm (3,855 cfs

(108.9 m3

/s)), or a total volume of about 2,490 mgd (3850 cfs (109 m3 20 /s)). Virtually the same 

21 amount of water that is withdrawn for condenser cooling and service water is discharged. Some 

22 water is lost due to increased evaporation in the heated cooling water effluent. The NRC 

previously estimated this loss at less than about 60 cfs (1.7 m3 23 /s), or about 39 mgd (60 cfs 

(1.7 m3 24 /s)) (NRC 2010). This estimate reflects a consumptive water use of less than 2 percent. 

In 2013, reported withdrawals for IP2 and IP3 averaged 2,029 mgd (3,139 cfs (88.7 m3 25 /s)), with 

a maximum daily withdrawal of 2,477 mgd (3,832 cfs (108.2 m3 26 /s)) (NYDEC 2015f).

27 The NRC staff stated in Section 4.8.1 of the 2010 FSEIS (NRC 2010) that water withdrawals for 

28 power generation and other uses in the freshwater portions of the Hudson River will continue to 

29 occur and will increase in the future due to urbanization and industrial expansion. Nevertheless, 

30 based on the above information, average surface water withdrawals at IP2 and IP3, combined 

31 with those from other large surface water users along the

32 Peekskill–Haverstraw portion of the lower Hudson River, total about 2,296 mgd (3,552 cfs 

(100.4 m3 33 /s)). This is approximately 2 percent of the normal tidal flow of the river

(i.e., 178,000 cfs (5,030 m3 34 /s)). The vast majority of this water is not consumptively used, but is 

35 returned to the river.

36 Under the State of New York’s Water Resources Law, which was updated in 2011, a permit is 

37 required for any type of water withdrawal system having the capacity to withdraw 0.1 mgd 

(378 m3 38 ) or more of surface water or groundwater. Previously, this law applied only to public 

39 water supplies (NYSDEC 2015g; 6 NYCRR 601). This regulatory oversight would be expected 

40 to improve the management of the water resources of the basin, especially new allocations or 

41 diversions of surface water, such as for the Haverstraw Water Supply Project or the NRG 

42 Bowline repowering project (see Table 5–5), into the future. In summary, regulated water 

43 withdrawals and the current low rate of consumptive use, including by IP2 and IP3, is not likely 

44 to have a substantial cumulative impact on the downstream availability of surface water during 

45 the license renewal term.

46 Water Quality Considerations

47 Section 4.8.1 of the 2010 FSEIS evaluated a number of contributors to cumulative impacts on 

48 aquatic resources and, by extension, to surface water resources, including surface water 
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1 quality. These contributors include continued operation of IP2 and IP3 and other water 

2 withdrawals (considered above), habitat loss, changes to water and sediment quality, and 

3 climate change (discussed below). The State of New York cites the following as major water 

4 quality concerns for the lower Hudson River Basin: (1) municipal wastewater and combined 

5 sewer overflows from urban areas, (2) urban stormwater runoff and industrial impacts,

6 (3) agricultural and other nonpoint sources of nutrients, (4) impacts from legacy PCB discharges 

7 in the upper Hudson River Basin, and (5) declining fishery stocks from habitat loss, power 

8 generation withdrawals, and other causes (NYSDEC 2015e).

9 An increase in heavy precipitation events, which is forecast to continue across the Northeast 

10 portion of the United States associated with climate change, would be additive to the manmade 

11 contributors to water quality decline from increased surface runoff laden with nutrients, 

12 sediment, and other contaminants. Degraded surface water quality also increases the costs of 

13 water treatment for both industrial cooling water and potable water supply because of the need 

14 for increased filtration and higher additions of chemical treatments, such as for corrosion control 

15 and for disinfection.

16 As discussed in Sections 4.8.1 and 2.2.5.2 of the 2010 FSEIS, there are indications that the 

17 overall water quality of the lower Hudson River is improving. In summary, efforts to address 

18 PCB contamination in the sediments above the Troy Dam continue, and upgrades to the 

19 region’s wastewater treatment plants have improved the quality of sanitary effluents. 

20 Additionally, on an individual facility and project basis (see Table 5–5), NYSDEC-administered 

21 SPDES permits issued under Section 402 of the CWA would set limits on wastewater, 

22 stormwater, and other point source discharges to surface waters, as applicable.

23 Likewise, chemical and thermal characteristics of the IP2 and IP3 effluent discharges are limited 

24 by SPDES Permit No. NY-0004472. The permit has been administratively continued by 

25 NYSDEC since it expired in 1992. Entergy continues to operate IP2 and IP3 in accordance with 

26 the permit and mitigation measures prescribed by the Hudson River Settlement Agreement (as 

27 detailed in Section 2.2.5.3 of the 2010 FSEIS) while adjudicatory proceedings associated with 

28 the SPDES permit renewal continue.

29 SPDES permitting requirements apply to existing industrial facilities and to large land-disturbing 

30 activities and projects, and such requirements would also apply to future activities in the basin. 

31 Regardless, non-point sources of chemicals and nutrients from agriculture and urban areas;

32 climate change; and the presence of persistent chemicals, such as PCBs and metals in riverine 

33 sediments, with associated implications for aquatic life, will continue to be a major challenge for 

34 water quality in the lower Hudson River Basin and contributors to cumulative water quality 

35 impacts.

36 Climate Change Considerations

37 The NRC staff considered USGCRP’s most recent compilations of the state of knowledge 

38 relative to global climate change effects (USGCRP 2009, 2014). In Section 4.8.1 of the 

39 2010 FSEIS, the NRC staff indicated that the cumulative effects of climate change could have 

40 substantial impacts on the aquatic and water resources of the Hudson River Basin (NRC 2010).

41 As detailed in Section 5.13.2.2, ambient air temperatures in the Northeast region and sea 

42 surface temperatures in the North Atlantic have increased since about 1900. This trend in air 

43 and ocean surface temperatures is projected to persist into the future. In a tidal regime such as 

44 that at the IP2 and IP3 site, the immediate implication of warmer source water is an increased 

45 water demand for plant cooling systems and decreased plant capacity, with a corresponding

46 rise in the temperature of cooling water effluents (USGCRP 2014). Power plants and other 

47 industrial facilities using the Hudson River as a water source would have to account for such 
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1 changes in operational practices and procedures, perhaps requiring investment in additional 

2 infrastructure and capacity.

3 A rise in global and North Atlantic sea levels has also been observed and increases are forecast 

4 to continue (see Section 5.13.2.2). Changes in sea level at any one coastal location depend not 

5 only on the increase in the global average sea level but also on various regional geomorphic, 

6 meteorological, and hydrological factors (USGCRP 2009). Specific to the Northeast U.S. coast, 

7 sea level rise is projected to exceed the global rate due to local land subsidence and will rise 0.7 

8 to 1.7 ft (0.2 to 0.5 m) by 2050, depending on the extent of glacier and ice sheet melt

9 (USGCRP 2014).

10 The intensity, frequency, and duration of North Atlantic hurricanes have increased since the 

11 1980s, and the Northeast region has experienced the largest increase in heavy precipitation 

12 events over the last 50 years. Hurricane-associated storm intensity and rainfall are projected to 

13 increase, as well as heavy precipitation events. Sea level rise, increased coastal storm intensity 

14 with associated surge, and heavy precipitation events can result in an increase in the incidence 

15 of coastal flooding (USGCRP 2014).

16 The IP2 and IP3 site has not experienced tidal flooding. The tidal range averages 4 ft (1.2 m) 

17 (Entergy 2007a). Water levels, such as those from a storm surge, would have to exceed 15 ft 

18 (4.6 m) to challenge the critical elevation of IP2 and IP3 facilities on the site (Entergy 2013d). 

19 Thus, projected increases in sea level alone would not be expected to threaten the site during 

20 the license renewal term. The NRC staff continues to review Entergy’s flooding hazard 

21 reevaluation for IP2 and IP3 (Entergy 2013d) that was submitted in response to the NRC’s RAI

22 under Recommendation 2.1 of the Japan Lessons Learned Near-Term Task Force 

23 (NRC 2012a). The NRC staff will use the information collected during its review and inspection 

24 to determine whether Entergy should be required to update the design basis and plant 

25 structures, systems, and components important to safety. Meanwhile, Entergy has taken 

26 interim actions to protect structures, systems, and components up to flood levels of more than 

27 17 ft (5.2 m) (Entergy 2013d).

28 Sea level rise associated with climate change could cause an increase in the upstream 

29 migration of the salt line, which could potentially affect fresh water availability. However, 

30 increases in precipitation over the Hudson River Basin and increased runoff and freshwater 

31 inflow to the main stem of the Hudson River from heavy precipitation events could have the 

32 effect of dampening any increased tidal influence from rising sea levels. The overall likelihood 

33 of substantial changes in salinity levels in the waters near the IP2 and IP3 site during the license 

34 renewal term is deemed to be low.

35 Conclusions

36 Water withdrawals from continued operation of IP2 and IP3, combined with other users, are not 

37 expected to substantially affect downstream surface water availability during the license renewal 

38 term. Such uses will remain a relatively small percentage of the normal tidal flow of the river, 

39 and a regulatory framework is in place to manage surface water withdrawals from the Hudson 

40 River Basin.

41 Legacy contamination, hydrologic alteration, and ongoing pollutant loading continue to affect

42 sediment and ambient water quality for beneficial uses in the lower Hudson River. Development 

43 trends, coupled with ongoing climate change, could exacerbate some of these water quality and 

44 hydrologic stressors despite ongoing efforts to address water quality impacts through cleanup 

45 activities and improvements in wastewater treatment and effluent regulation. The effects from 

46 climate change could have negative implications for industrial cooling and potable water uses, 
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1 requiring additional water treatment, operational changes, and a potential need for added 

2 infrastructure investment.

3 In addition, the chemical and thermal characteristics of cooling water and other wastewater and 

4 stormwater discharges from IP2 and IP3 would continue to be regulated during the period of 

5 continued operations in accordance with SPDES permit provisions. These permit requirements 

6 will apply to other industrial users and major development projects as well.

7 Overall, the NRC staff finds that the incremental impacts on water use and quality from the 

8 continued operation of IP2 and IP3 during the license renewal term will continue to be SMALL. 

9 However, although uncertainly exists with respect to the magnitude of future climate change 

10 impacts, the hydrology and water quality of the lower Hudson River Basin will be increasingly 

11 and incrementally affected by other contributors within the license renewal timeframe and 

12 beyond. As a result, the NRC staff concludes that the cumulative impacts from past, present, 

13 and reasonably foreseeable future actions and trends on surface water resources during the 

14 license renewal term would be SMALL to MODERATE.

15 5.14.4 Groundwater

16 This section addresses the direct and indirect effects of license renewal on groundwater use 

17 and quality when they are added to the aggregate effects of other past, present, and reasonably 

18 foreseeable future actions. The IP2 and IP3 reactors do not and would not use onsite 

19 groundwater. Onsite groundwater is not likely to be used as a source of public water or to affect 

20 any offsite groundwater resources. The impact to offsite water resources would be through 

21 discharge of radiologically contaminated groundwater into the Hudson River.

22 In Section 4.8.3 of the 2010 FSEIS, the NRC staff reported that within the 50-mi (80-km) radius 

23 of IP2 and IP3, there are no other nuclear power reactors or uranium fuel cycle facilities 

24 (NRC 2010). Therefore, within that radius, most radiological releases to the Hudson River are 

25 likely to be from operations at IP2 and IP3 and the migration of contaminated groundwater to 

26 the river. Tritium releases to the Hudson River are expected to occur from contaminated 

27 groundwater and from routine permitted releases directly to the river or the air. Depending on 

28 the atmospheric conditions, some of the tritium released to the air may condense and find its 

29 way into the river. From 2003 through 2013, routine monitoring of Hudson River water for 

30 tritium has shown that near the IP2 and IP3 site, tritium concentrations in the river are at very 

31 low levels relative to the 20,000 pCi/L drinking water standard (Entergy 2014g). These very 

32 low-level concentrations of tritium in the river are expected to continue over the proposed 

33 license renewal period.

34 Strontium-90 resulting from the now drained IP1 spent fuel pool would enter the river via the 

35 discharge of contaminated onsite groundwater. As discussed in Section 5.4, any strontium-90

36 entering the river from groundwater discharge would be diluted to very low concentrations. 

37 Because there are no other new sources of strontium-90, the level of strontium-90 in the river 

38 should continue to be very low.

39 The amount of river water flowing past the IP2 and IP3 site is not likely to be adversely affected

40 by climate change because the amount of water in the river and the rate of river flow throughout 

41 most of the year are dominated by the tides. Therefore, a large volume of river water is

42 available to dilute any radiological discharges. Future climatic changes should not result in 

43 changes to site operations that would result in increased impacts to the radiological quality of 

44 the surface water resources.

45 It is unlikely that the proposed Haverstraw Water Supply Project would be adversely affected by 

46 contaminated groundwater discharging to the Hudson River at the IP2 and IP3 site. This is 
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1 because of the extremely low levels of contamination in the Hudson River that might result from 

2 the flow of groundwater into the river. Should the facility be built, United Water will be required 

3 to meet NYSDEC’s permit requirements and EPA’s drinking water standards, thus assuring 

4 public safety (NRC 2012e).

5 Considering ongoing activities and reasonably foreseeable actions, the NRC staff concludes 

6 that the cumulative impacts on groundwater quality and, indirectly, on surface water quality via 

7 the discharge of radionuclides from contaminated groundwater beneath the IP2 and IP3 site 

8 during the license renewal term would be SMALL.

9 5.14.5 Terrestrial Resources

10 In Section 4.8.2 of the 2010 FSEIS, the NRC staff described the cumulative impacts on 

11 terrestrial resources from past, present, and reasonably foreseeable future actions (NRC 2010). 

12 The NRC staff concluded that the cumulative impacts on terrestrial resources were LARGE 

13 relative to predevelopment conditions and that much of this impact occurred before the 

14 construction of IP2 and IP3. The NRC staff considered whether the actions and projects in 

15 Table 5–5 or the information provided by Entergy (2015a) constitute new information that could 

16 change the staff’s conclusion in the 2010 FSEIS. Although the proposed AIM Project includes 

17 construction of a gas pipeline that would cross a portion of the IP2 and IP3 property, the 

18 implementation of the AIM project would not change the staff’s previous conclusion of LARGE 

19 for cumulative impacts on terrestrial resources. Accordingly, the staff concludes that no new 

20 and significant information exists regarding cumulative impacts on terrestrial resources and that 

21 impacts to this resource are bounded by the staff’s previous assessment in the 2010 FSEIS.

22 5.14.6 Aquatic Resources

23 Cumulative impact for aquatic resources addresses the direct and indirect effects of license 

24 renewal on aquatic resources when added to the aggregate effects of other past, present, and 

25 reasonably foreseeable future actions. The cumulative impact is the total effect on the aquatic 

26 resources of all actions taken, no matter who has taken the actions (CEQ 1997). Two related 

27 concepts bound the analysis of cumulative impacts: the timeframe and geographic extent. The 

28 timeframe for cumulative analyses for ecological resources extends far enough into the past to 

29 understand the processes that affect the present resource conditions and to examine whether 

30 and why aquatic resources are stable or unstable, which the NRC definitions of impact levels 

31 require. The timeframe for cumulative impact analysis is more extensive than that for the direct 

32 and indirect impact analysis.

33 The geographic area of interest considered in the cumulative aquatic resource analysis depends 

34 on the particular cumulative impacts being discussed. The geographic area considered for 

35 cumulative impacts to aquatic resources is the lower Hudson River Estuary. The level of 

36 cumulative impacts is measured against a baseline. Consistent with other agencies’ and 

37 CEQ’s (1997) NEPA guidance, the term “baseline” pertains to the condition of the resource 

38 without the action, i.e., under the no-action alternative. Under the no-action alternative, the 

39 plant would remain but be shut down and the resource would conceptually return to its condition 

40 without the plant, which is not the same as the condition before the plant was constructed 

41 because of changes that have occurred to the potentially affected resources. The baseline, or 

42 benchmark, for assessing cumulative impacts on aquatic resources takes into account the 

43 pre-operational environment as recommended by EPA (1999b) for its review of NEPA 

44 documents.

45 This section updates the previous cumulative impacts sections from the 2010 FSEIS with 

46 information that became available subsequent to publication pertaining to two projects that 
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1 could potentially affect aquatic resources. The assessment of new information in Chapter 4 on 

2 the direct and indirect impacts of impingement and entrainment to aquatic resources does not 

3 substantially change the overall finding of the 2010 FSEIS of MODERATE. The FSEIS 

4 (NRC 2010) presents cumulative impacts to aquatic resources in Section 4.8.1, Appendix H.2, 

5 and Appendix I.3, and finds that the level of cumulative impact is LARGE. Section 5.13.2.2 of 

6 this supplement assesses the effects of climate change and supplements discussion on the 

7 effects of climate change on aquatic resources in FSEIS (NRC 2010) Section 4.8.1 and 

8 Appendix H.2.

9 The proposed Haverstraw Water Supply Project (2012) includes a water treatment plant, intake 

10 pumping station, and transmission and distribution mains that would provide up to 7.5 million 

11 gallons (34 million liters) of potable water per day to Rockland County, New York. It would have 

12 a water intake structure on the Hudson River 4 miles (6.5 km) south-southwest of the IP2 and 

13 IP3 site where impingement and entrainment of fish and aquatic invertebrates would occur. The 

14 draft environmental impact statement (EIS) prepared by United Water, the applicant for the 

15 project, finds that use of a wedge-wire screen as mitigation to minimize impingement and 

16 reduce entrainment would minimize losses to the target fish species and “would not result in 

17 significant adverse impacts on regional target species populations, or to regional populations of 

18 other fish, plankton or macroinvertebrates” (Haverstraw Water Supply Project 2012, 

19 Chapter 9A).

20 The Tappan Zee Hudson River Crossing Project is replacing the current Tappan Zee Bridge 

21 across the Hudson River south of the IP2 and IP3 site. The final EIS (NYSDOT and 

22 NYSTA 2015) finds that about 13 acres (5.25 hectares) of oyster habitat would be adversely 

23 impacted by construction operations (discussed in NYSDOT and NYSTA 2015, Chapter 18, 

24 “Construction Impacts”), some or all of which may be permanently lost. Compensatory 

25 mitigation for the project includes the restoration of 13 acres (5.25 hectares) of hard 

26 bottom/shell oyster habitat and the reintroduction of oysters to the habitat. The final EIS for the 

27 Tappan Zee Hudson River Crossing Project (NYSDOT and NYSTA 2015, Chapter 16) finds that 

28 the project would not have the potential to result in adverse impacts on aquatic biota.

29 The updated information does not substantially alter the NRC staff’s previous analysis, as 

30 documented in the 2010 FSEIS (NRC 2010). The level of impact to aquatic resources 

31 considering the updated information is bounded by the NRC staff’s previous assessment, which 

32 concluded that the cumulative impacts to aquatic resources is LARGE.

33 5.14.7 Radiological Impacts

34 In Section 4.8.3 of the 2010 FSEIS, the NRC staff described the cumulative radiological impacts 

35 on human health from past, present, and reasonably foreseeable future actions. The 

36 radiological dose limits for protection of the public and workers have been developed by the 

37 NRC and EPA to address the cumulative impact of acute and long-term exposure to radiation 

38 and radioactive material. These dose limits are codified in 10 CFR Part 20 and 

39 40 CFR Part 190. Based on its review of radiological effluent and environmental monitoring 

40 data, the NRC staff concluded that the cumulative impacts on human health were SMALL. The 

41 NRC staff also considered whether the actions and projects in Table 5–5 or the information 

42 provided by Entergy (Entergy 2015a) constitute new information that could change the staff’s 

43 conclusion in the 2010 FSEIS (NRC 2010). The NRC staff identified one project that may affect 

44 the radiological impacts from the IP2 and IP3 site—the expansion of the ISFSI to store 

45 additional spent nuclear fuel. However, as discussed in Section 4.8.3 of the 2010 FSEIS, the 

46 installation and monitoring of the ISFSI is governed by NRC requirements in 10 CFR Part 72. 

47 Radiation from this facility and from the operation of IP2 and IP3 must not exceed the radiation 

48 dose limits in 10 CFR Part 20, 40 CFR Part 190, and 10 CFR Part 72. Accordingly, expansion 
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1 of the ISFSI is not expected to change Entergy’s ability to maintain radiological doses to 

2 members of the public well within regulatory limits.

3 5.14.8 Waste Management and Pollution Prevention

4 This section describes waste management impacts from IP2 and IP3 during the license renewal 

5 term when they are added to the cumulative impacts of other past, present, and reasonably 

6 foreseeable future actions. For the purpose of this cumulative impacts analysis, the area within 

7 a 50-mi (80-km) radius of IP2 and IP3 was considered. The NRC staff concluded in 

8 Sections 4.3 and 6.1 of the 2010 FSEIS that the potential human health impacts from IP2’s and 

9 IP3’s radioactive and nonradioactive waste during the license renewal term would be SMALL.

10 As discussed in Sections 2.1.4 and 2.1.5 of the 2010 FSEIS, Entergy maintains waste 

11 management programs for radioactive and nonradioactive waste generated at IP2 and IP3 and 

12 is required to comply with Federal and State permits and other regulatory requirements for the 

13 management of waste material. Other facilities and projects listed in Table 5–5 within a 50-m 

14 (80-km) radius of IP2 and IP3 are also required to comply with appropriate NRC, EPA, and New 

15 York State requirements for the management of radioactive and nonradioactive waste. Waste 

16 management activities at IP2 and IP3 are expected to be stable during the license renewal term 

17 and to comply with Federal and State requirements for radioactive and nonradioactive waste. 

18 Adequate disposal options at licensed disposal facilities are expected to handle the cumulative 

19 volume of radioactive and nonradioactive waste generated by IP2, IP3, and other facilities. If 

20 access to a disposal facility is temporarily unavailable, the waste will be safely stored in 

21 accordance with NRC, EPA, and State requirements.

22 Based on the above information, the NRC staff concludes that the potential cumulative impact 

23 from radioactive and nonradioactive waste would be SMALL.

24 5.14.9 Socioeconomic Impacts

25 The NRC staff described the cumulative socioeconomic impacts from past, present, and 

26 reasonably foreseeable future actions in Section 4.8.4 of the 2010 FSEIS. Based on its review, 

27 the NRC staff concluded that the contributory effects of IP2 and IP3 to socioeconomic 

28 conditions in the region has been SMALL. In this supplement, the NRC staff considers whether 

29 the actions and projects listed in Table 5–5 or the information provided by Entergy 

30 (Entergy 2015a) constitute new information that could change the cumulative impacts

31 conclusion in the 2010 FSEIS.

32 Based on the information presented in Chapter 4 of the 2010 FSEIS, there would be no new or 

33 increased contributory effect on socioeconomic conditions in the region during the license 

34 renewal term from the continued operation of IP2 and IP3 beyond what is currently being 

35 experienced. Therefore, the only contributory effects would come from reasonably foreseeable 

36 future planned activities at IP2 and IP3, unrelated to the proposed action (license renewal), and 

37 from other reasonably foreseeable planned offsite activities. For example, offsite residential 

38 development is planned throughout the region. Therefore, the availability of new housing could 

39 attract individuals and families from outside the region, thus increasing the local population and

40 causing, in turn, increased traffic on local roads and increased demand for public services.

41 In general, the population in the region surrounding IP2 and IP3 continues to experience growth, 

42 increasing economic activity and tax revenue and changing demographics. Installation of the 

43 AIM pipeline and ISFSI expansion, if these activities occur simultaneously, would increase the 

44 total number of workers at the IP2 and IP3 site. This situation could increase the demand for 

45 rental housing and public services, as well as traffic volumes near IP2 and IP3. However, given 
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1 the relatively short amount of time needed to complete these actions, socioeconomic conditions 

2 in the vicinity of IP2 and IP3 would not be permanently affected. Again, when combined with 

3 other past, present, and reasonably foreseeable future activities (e.g., AIM pipeline installation 

4 and ISFSI expansion), the contributory effects of continued reactor operations at IP2 and IP3 

5 would have no new or increased impact on socioeconomic conditions in the region beyond what 

6 is currently being experienced. Therefore, the actions and projects listed in Table 5–5 and the 

7 information provided by Entergy would not change the cumulative impacts conclusion in the 

8 2010 FSEIS for socioeconomics. Accordingly, the cumulative effects of these additional 

9 activities remain bounded by the previous assessment in the 2010 FSEIS.

10 5.14.10 Historic and Cultural Resources

11 This section addresses the direct and indirect effects of license renewal (the proposed action) 

12 on historic and cultural resources in and around IP2 and IP3 when added to the aggregate 

13 effects of other past, present, and reasonably foreseeable future actions. Section 2.2.9 of the 

14 2010 FSEIS discusses the cultural background and known historic and cultural resources in and 

15 around IP2 and IP3.

16 As described in Section 4.4.5 of the 2010 FSEIS, the NRC concluded that license renewal 

17 would have a SMALL impact on historic and cultural resources at IP2 and IP3. However, 

18 ground-disturbing maintenance and operations activities during the license renewal term could 

19 affect undiscovered historic and archaeological resources. Additionally, the construction of the 

20 proposed AIM pipeline through the IP2 and IP3 site could also affect historic and cultural 

21 resources.

22 Entergy has established procedures for the protection of cultural resources at IP2 and IP3 

23 (Entergy 2007a). These procedures are designed to ensure that site investigations and 

24 appropriate consultations are conducted and that cultural resources are adequately protected. 

25 Any ground-disturbing maintenance and operations activities during the license renewal term at 

26 IP2 and IP3 would be evaluated in accordance with these procedures.

27 According to Entergy’s procedures, should historic or archaeological resources be encountered 

28 during excavations, work would cease until Entergy environmental personnel can assess the 

29 situation and consider possible mitigation measures and, if necessary, consult with the New 

30 York State Historic Preservation Officer, as appropriate.

31 Based on this information, there would be no contributory effect on historic and cultural 

32 resources in the region during the license renewal term from the continued operation of IP2 and 

33 IP3 beyond what has already occurred. Therefore, the only contributory effects would come 

34 from reasonably foreseeable future planned activities at IP2 and IP3 unrelated to the proposed 

35 action (license renewal) and from other reasonably foreseeable planned offsite activities. When 

36 combined with other past, present, and reasonably foreseeable future activities, the contributory 

37 effects of continued reactor operations at IP2 and IP3 would not contribute to the overall 

38 cumulative impact on historic and cultural resources.

39 5.14.11 Environmental Justice

40 The NRC staff described the cumulative environmental justice impacts from past, present, and 

41 reasonably foreseeable future actions in Section 4.8.4 of the 2010 FSEIS. Based on the review, 

42 it was concluded that there would be no disproportionately high and adverse human health and 

43 environmental effects on minority and low-income populations in the region. In this supplement, 

44 the NRC staff considers whether the actions and projects listed in Table 5–5 or the information 
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1 provided by Entergy (2015a) constitutes new information that could change the cumulative

2 impacts conclusion in the 2010 FSEIS.

3 The environmental justice cumulative impact analysis evaluates the potential for 

4 disproportionately high and adverse human health and environmental effects on minority and 

5 low-income populations that could result from past, present, and reasonably foreseeable future 

6 actions, including the continued operational effects of IP2 and IP3 during the renewal term. 

7 Everyone living near Indian Point experiences the operational effects of IP2 and IP3, including 

8 minority and low-income populations. As explained in the 2010 FSEIS, the NRC addresses 

9 environmental justice matters for license renewal by identifying the location of minority and low10 income populations, determining whether there would be any potential human health or 

11 environmental effects to these populations, and determining if any of the effects may be 

12 disproportionately high and adverse.

13 Adverse health effects are measured in terms of the risk and rate of fatal or nonfatal adverse 

14 impacts on human health. Disproportionately high and adverse human health effects occur 

15 when the risk or rate of exposure to an environmental hazard for a minority or low-income 

16 population is significant and exceeds the risk or exposure rate for the general population or for 

17 another appropriate comparison group. Disproportionately high environmental effects refer to 

18 impacts or risks of impacts on the natural or physical environment in a minority or low-income 

19 community that are significant and that appreciably exceed the environmental impact on the 

20 larger community. Such effects may include biological, cultural, economic, or social impacts. 

21 Some of these potential effects have been identified in resource areas presented in Chapter 4 of 

22 the 2010 FSEIS and this supplement. 

23 As explained in Section 4.4.6 of the 2010 FSEIS, there would be no disproportionately high and 

24 adverse impacts on minority and low-income populations from the continued operation of IP2 

25 and IP3 during the license renewal term. Because Entergy has no plans to hire additional 

26 workers during the license renewal term, employment levels at IP2 and IP3 would remain 

27 relatively constant, and there would be no additional demand for housing or increased traffic. 

28 Based on this information and the analysis of human health and environmental impacts 

29 presented in the 2010 FSEIS, it is not likely that there would be any disproportionately high and 

30 adverse contributory effect on minority and low-income populations from the continued 

31 operation of IP2 and IP3 during the license renewal term. Therefore, the only contributory 

32 effects would come from the other reasonably foreseeable future planned activities at the IP2 

33 and IP3 site unrelated to the proposed action (license renewal) and from other reasonably 

34 foreseeable planned offsite activities.

35 Potential impacts to minority and low-income populations during the installation of the AIM

36 pipeline and ISFSI expansion would mostly consist of environmental effects (e.g., noise, dust, 

37 traffic, and housing impacts). However, given the relatively short amount of time needed to 

38 complete these actions, environmental conditions in the vicinity of IP2 and IP3 would not be 

39 permanently affected.

40 Noise and dust impacts during construction would be temporary and limited to onsite activities. 

41 Minority and low-income populations residing along site access roads could experience 

42 increased truck material and equipment delivery and commuter vehicle traffic especially during 

43 shift changes. Increased demand for inexpensive temporary housing by construction workers 

44 could disproportionately affect low-income populations; however, given the availability of rental 

45 housing in the region, impacts to minority and low-income populations would be limited. 

46 Radiation doses after the expansion of the ISFSI are expected to remain within regulatory limits.

47 Based on this information and the analysis of human health and environmental impacts 

48 presented in this supplement, AIM pipeline installation and ISFSI expansion would not have 
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1 disproportionately high and adverse human health and environmental effects on minority and 

2 low-income populations residing in the vicinity of the IP2 and IP3 site. When combined with 

3 other past, present, and reasonably foreseeable future activities (e.g., AIM pipeline installation 

4 and ISFSI expansion), the contributory effects of continued reactor operations at IP2 and IP3 

5 would not likely cause disproportionately high and adverse human health and environmental 

6 effects on minority and low-income populations residing in the vicinity of the IP2 and IP3 site. 

7 Therefore, the actions and projects listed in Table 5–5 and the information provided by Entergy 

8 would not change the cumulative impacts conclusion in the 2010 FSEIS for environmental 

9 justice. Accordingly, the cumulative effects of these additional activities remain bounded by the 

10 previous assessment in the 2010 FSEIS.

11 5.14.12 Global Climate Change

12 This section addresses the impact of GHG emissions resulting from continued operation of IP2 

13 and IP3 on global climate change when added to the aggregate effects of other past, present, 

14 and reasonably foreseeable future actions. Climate is influenced by both natural and 

15 human-induced factors; the observed global warming (increase in the Earth’s surface 

16 temperature) in the 21st century has been attributed to the increase in GHG emissions resulting 

17 from human activities (USGCRP 2009, 2014). Climate model projections indicate that future 

18 climate change is dependent on current and future GHG emissions (IPCC 2007a;

19 USGCRP 2009, 2014). As described in Section 5.13 of this supplement, operations at IP2 and 

20 IP3 emit GHG. Therefore, GHG emissions from the continued operation of IP2 and IP3 may 

21 contribute to climate change.

22 The cumulative impact of a GHG emission source on climate is global. The GHG emissions are 

23 transported by wind and become well mixed in the atmosphere as a result of their long 

24 atmospheric residence time. Therefore, the extent and nature of climate change is not specific 

25 to where GHGs are emitted. In April 2015, EPA (2015d) published the official U.S. inventory of 

26 GHG emissions, which identifies and quantifies the primary anthropogenic sources and sinks of 

27 GHGs. The EPA GHG inventory is an essential tool for addressing climate change and for 

28 participating with the United Nations Framework Convention on Climate Change to compare the 

29 relative global contribution of different emission sources and GHGs to climate change. In 2013, 

30 the United States emitted 6,673 million metric tons (MMT) of CO2eq; total U.S. emissions have 

31 increased by 5.9 percent from 1990 to 2013 (EPA 2015d). In 2012 and 2013, the total amount 

32 of CO2eq emissions related to electricity generation was 2,022.2 MMT and 2,039.8 MMT, 

33 respectively (EPA 2015d). The Energy Information Administration (EIA) reported that, in 2012, 

34 electricity production alone in New York was responsible for 35.6 MMT CO2 (approximately 

35 36.0 MMT of CO2eq) (EIA 2015). Facilities that emit 0.025 MMT of CO2eq or more per year are 

36 required to annually report their GHG emissions to EPA. These facilities are known as direct 

37 emitters, and the data are publicly available in the EPA’s Facility Level Information on 

38 GreenHouse gases Tool (FLIGHT). In 2013, FLIGHT identified four facilities in Westchester 

39 County, New York, that emitted a total of 448,046 MT of CO2eq (EPA 2015e). In 2013, FLIGHT 

40 identified 221 facilities in New York that emitted a total of 42.5 MMT of CO2eq (EPA 2015e).

41 Permitting and licensing requirements and other mitigative measures can minimize the impacts 

42 of GHG emissions. For instance, in 2012, EPA issued a final GHG Tailoring Rule 

43 (77 FR 41051) to address GHG emissions from stationary sources under the CAA permitting 

44 requirements; the GHG Tailoring Rule establishes when an emission source will be subject to 

45 permitting requirements and control technology to reduce GHG emissions. On June 25, 2013,

46 the Climate Action Plan was established to reduce carbon pollution (EOP 2013). The Climate 

47 Action Plan will reduce carbon pollution, prepare the United States for the impacts of climate 

48 change, and lead international efforts to combat global climate change. Under the Climate 
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1 Action Plan, EPA has proposed rules to reduce carbon pollution from new and existing power 

2 plants. The Clean Power Plan Final Rule (80 FR 64662), aimed at reducing carbon pollution 

3 from power plants, requires carbon emissions from the power generating sector to be reduced 

4 to a level that is 32 percent below 2005 levels (870 million tons (789 MMT) less). The Clean 

5 Power Plan sets forth carbon dioxide emission performance rate standards for power plants that 

6 should be achieved by 2030. Furthermore, EO 24, issued in August 2009, set a goal to reduce 

7 GHG emission in New York State by 80 percent below 1990 levels by the year 2050

8 (NYSDEC 2009). EO 24 also established a Council that was directed to develop a draft Climate 

9 Action Plan. The draft Climate Action Plan, among a number of things, identifies actions that 

10 will reduce GHG emissions in New York and identifies continued operation or expansion of 

11 nuclear plants to attain GHG reduction goals (New York State Climate Action Council 2010).

12 The EPA’s U.S. inventory of GHG emissions illustrates the diversity of GHG source emitters, 

13 such as electricity generation, industrial processes, and agriculture. As discussed in 

14 Section 5.13 of this supplement, GHG emissions resulting from operations at IP2 and IP3 for the 

15 2009 to 2013 timeframe ranged between 4,960 and 10,990 MT of CO2eq. In comparing IP2 and 

16 IP3 GHG emission contributions to different emissions sources, whether they are total 

17 U.S. GHG emissions, emissions from New York, or emissions on a county level, GHG 

18 emissions from IP2 and IP3 are relatively minor (see Table 5–6). Climate models indicate that 

19 climate change (through the year 2030) is dependent on past GHG emissions. Climate models 

20 indicate that, even if GHG emissions were to be completely eliminated, the Earth’s average 

21 surface temperature will continue to increase and climate-related changes will persist over the 

22 next few decades (USGCRP 2014). Therefore, short-term climate change is projected to occur 

23 with or without present and future GHG emissions from IP2 and IP3. The magnitude of the 

24 continued increase in GHG emission rates will determine the amount of additional future 

25 warming and long-term (beyond 2030) climate change. Climate change and climate-related 

26 changes have been observed on a global level, and climate models indicate that future climate 

27 change will depend on present and future GHG emissions. The USGCRP (2014) concludes 

28 that climate change and related impacts are happening. In summary, the cumulative impact of 

29 GHG emissions on climate change during the IP2 and IP3 license renewal timeframe 

30 (2013 through 2033 and 2015 through 2035, respectively) is noticeable but not destabilizing. 

31 The NRC staff concludes that the incremental impact from the contribution of GHG emissions 

32 from continued operation of IP2 and IP3 on climate change would be SMALL. The cumulative 

33 impacts on climate change from the proposed license renewal and other past, present, and 

34 reasonably foreseeable projects would be MODERATE.

35 Table 5–6. Comparison of GHG Emission Inventories

Source CO2eq (MMT/year)

Global emissions (2013)(a) 35,300

U.S. emissions (2013)(b) 6,673

New York emissions (2013)(c) 42.5

Westchester County emissions(2013)(c) 0.45

IP2 and IP3 emissions(d) 0.01

(a) Source: European Commission (2014)

(b) Source: EPA (2015d)

(c) GHG emissions account only for direct emitters, i.e., those facilities that emit 25,000 MT or more a year 

(EPA 2015e).

(d) Emissions include direct and indirect emissions from the operation of IP2 and IP3, and the highest emission 

from 2009 to 2013 is presented (Entergy 2015a).
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113

1 5.14.13 Conclusions Regarding Cumulative Impacts

2 As addressed in Section 4.8.6 of the 2010 FSEIS, the NRC staff determined that the cumulative 

3 impacts to the environment surrounding IP2 and IP3 from past and present human activities 

4 (beyond impacts from IP2 and IP3) have generally been LARGE and could continue to be 

5 LARGE in some issue areas and that future development is likely to continue to affect these 

6 resources. The NRC staff has subsequently considered the actions and projects identified in 

7 Table 5–5 of this supplement and concludes that the potential cumulative impacts associated 

8 with these additional actions would continue to be bounded by the assessment in the 

9 2010 FSEIS.

115

1 6.0 CONTINUED STORAGE OF SPENT NUCLEAR FUEL

2 The U.S. Nuclear Regulatory Commission’s (NRC’s) findings on the environmental impacts 

3 associated with the renewal of a power reactor operating license are contained in Table B–1, 

4 “Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants,” in

Appendix B to Subpart A of Title 10 of the Code of Federal Regulations (10 CFR) Part 51.”4 5 

6 In 1996, as part of the 10 CFR Part 51 license renewal rulemaking, the NRC determined that 

7 offsite radiological impacts of spent nuclear fuel and high-level waste disposal would be a 

8 Category 1 (generic) issue with no impact level assigned (Volume 61 of the Federal Register

9 (FR), pages 28467 and 28495 (61 FR 28467, 28495)). The NRC analyzed the 

10 U.S. Environmental Protection Agency’s (EPA’s) generic repository standards and dose limits in 

11 existence at the time and concluded that offsite radiological impacts warranted a Category 1 

12 determination (61 FR 28467, 28478). In its 2009 proposed rule, the NRC stated its intention to 

13 reaffirm that determination (74 FR 38117, 38127).

14 For the offsite radiological impacts resulting from spent fuel and high-level waste disposal and 

15 the onsite storage of spent fuel, which will occur after the reactors have been permanently shut

16 down, the NRC’s Waste Confidence Decision and Temporary Storage Rule (Waste Confidence 

17 Decision and Rule) (10 CFR 51.23) historically represented the Commission’s generic 

18 determination that spent fuel can continue to be stored safely and without significant 

19 environmental impacts for a period of time after the end of the licensed life for operation. This 

20 generic determination meant that the NRC did not need to consider the storage of spent fuel 

21 after the end of a reactor’s licensed life for operation in documents prepared under the National 

22 Environmental Policy Act of 1969, as amended (NEPA) (42 U.S.C. 4321 et seq.), that support 

23 its reactor and spent fuel storage application reviews.

24 The NRC first adopted the Waste Confidence Decision and Rule in 1984. The NRC amended 

25 the Waste Confidence Decision and Rule in 1990; reviewed them in 1999; and amended them 

26 again in 2010, as published in the Federal Register (49 FR 34685, 34694; 55 FR 38472,

27 38474; 64 FR 68005; and 75 FR 81032, 81037). The Waste Confidence Decision and Rule 

28 were codified in 10 CFR 51.23.

29 On December 23, 2010, the Commission published in the Federal Register a revision of the 

30 Waste Confidence Decision and Rule to reflect information gained from experience in the 

31 storage of spent fuel and the increased uncertainty in the siting and construction of a permanent 

32 geologic repository for the disposal of spent fuel and high-level waste (75 FR 81032, 81037). In 

33 response to the 2010 Waste Confidence Decision and Rule, the States of New York, New 

34 Jersey, Connecticut, and Vermont—along with several other parties—challenged the 

35 Commission’s NEPA analysis in the decision, which provided the regulatory basis for the rule. 

36 On June 8, 2012, the U.S. Court of Appeals for the District of Columbia Circuit, in New York v. 

37 NRC, 681 F.3d 471 (D.C. Cir. 2012), vacated the NRC’s 2010 Waste Confidence Decision and 

38 Rule, finding that it did not comply with NEPA.

39 In response to the Court’s ruling, the Commission, in CLI-12-16 (NRC 2012c), determined that it 

40 would not issue licenses that rely upon the Waste Confidence Decision and Rule until the issues 

 

4 The Commission issued Table B–1 in June 1996 (61 FR 28467). The Commission issued an additional 

rule in December 1996 that made minor clarifying changes to, and added language inadvertently 

omitted from, Table B–1 (61 FR 66537). The NRC revised Table B–1 and other regulations in 

10 CFR Part 51, relating to the NRC’s environmental review of a nuclear power plant’s license renewal 

application, in a 2013 rulemaking (78 FR 37282).
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116

1 identified in the Court’s decision are appropriately addressed by the Commission. In CLI-12-16, 

2 the Commission also noted that the decision not to issue licenses only applied to final license 

3 issuance; all licensing reviews and proceedings should continue to move forward.

4 In addition, the Commission directed in Staff Requirements Memorandum 

5 (SRM)-COMSECY-12-0016 (NRC 2012d) that the NRC staff proceed with a rulemaking that 

6 includes the development of a generic environmental impact statement (EIS) to support a 

7 revised Waste Confidence Decision and Rule and to publish both the EIS and the revised 

8 decision and rule in the Federal Register within 24 months (by September 2014). The 

9 Commission indicated that both the EIS and the revised Waste Confidence Decision and Rule 

10 should build on the information already documented in various NRC studies and reports, 

11 including existing environmental assessments that the NRC developed as part of the 

12 2010 Waste Confidence Decision and Rule. The Commission directed that any additional 

13 analyses should focus on the issues identified in the court’s decision. The Commission also 

14 directed that the NRC staff provide ample opportunity for public comment on both the draft EIS 

15 and the proposed Waste Confidence Decision and Rule.

16 Issuance of the Revised 10 CFR 51.23 and NUREG–2157

17 As discussed above, in New York v. NRC, 681 F.3d 471 (D.C. Cir. 2012), the Court vacated the 

18 Commission’s 2010 Waste Confidence Decision and Rule (10 CFR 51.23). In response to the 

19 Court’s vacatur, the Commission developed a revised rule and associated Generic 

20 Environmental Impact Statement for Continued Storage of Spent-Nuclear Fuel (GEIS) 

21 (NUREG–2157). Before the issuance of the revised 10 CFR 51.23 and NUREG–2157, the NRC 

22 issued the 2013 final license renewal rule, which amended Table B–1 in Appendix B to 

23 Subpart A of 10 CFR Part 51—along with other 10 CFR Part 51 regulations—and stated that,

24 upon finalization of the revised Waste Confidence Decision and Rule and accompanying 

technical analyses,

5 25 the NRC would make any necessary conforming amendments to Table B–1

26 (78 FR 37282, 37293).

27 On August 26, 2014, the Commission approved the Continued Storage Rule and associated 

28 NUREG–2157 (NRC 2014f). Subsequently, on September 19, 2014, the NRC published the 

29 final rule (79 FR 56238) in the Federal Register, and published NUREG–2157 (79 FR 53238, 

30 56263). The Continued Storage Rule adopts the generic impact determinations made in 

31 NUREG–2157 and codifies the NRC’s generic determinations regarding the environmental 

32 impacts of continued storage of spent nuclear fuel beyond a reactor’s operating license 

33 (i.e., those impacts that could occur as a result of the storage of spent nuclear fuel at at-reactor 

34 or away-from-reactor sites after a reactor’s licensed life for operation and until a permanent 

35 repository becomes available). As directed by 10 CFR 51.23(b), the impacts assessed in 

36 NUREG–2157 regarding continued storage are deemed incorporated by rule into this license 

37 renewal SEIS.

38 In the Continued Storage Rule, the NRC made conforming changes to the following two 

39 environmental issues in Table B–1 that were affected by the vacated Waste Confidence 

40 Decision and Rule: (1) “Onsite spent fuel” storage and (2) “Offsite radiological impacts (spent 

 

5 At the time of the 2013 final license renewal rule, the Continued Storage Rule was referred to by its 

long-standing historical name, “Waste Confidence.”
Continued Storage of Spent Nuclear Fuel

117

fuel and high-level waste disposal).”6 1 Although NUREG–2157 (the technical basis for the 

2 Continued Storage Rule) does not include high-level waste disposal in the analysis of impacts, it 

3 does address the technical feasibility of a repository in Appendix B to NUREG–2157 and 

4 concludes that a geologic repository for spent fuel is technically feasible, and that the same 

5 analysis applies to the feasibility of geologic disposal for high-level waste.

6 The Commission revised the Table B–1 finding for “Onsite storage of spent nuclear fuel” to add 

7 the phrase “during the license renewal term” to make clear that the finding of SMALL impact is 

8 for the license renewal term only. Some minor clarifying changes were also made to the 

9 paragraph. The first paragraph of the column entry now reads, “During the license renewal 

10 term, SMALL. The expected increase in the volume of spent nuclear fuel from an additional 

11 20 years of operation can be safely accommodated onsite during the license renewal term with 

12 small environmental impacts through dry or pool storage at all plants.”

13 In addition, a new paragraph was added to address the impacts of onsite storage of spent fuel 

14 during the continued storage period. The second paragraph of the column entry reads, “For the 

15 period after the licensed life for reactor operations, the impacts of onsite storage of spent 

16 nuclear fuel during the continued storage period are discussed in NUREG–2157 and as stated 

17 in § 51.23(b), shall be deemed incorporated into this issue.” The changes reflect that this issue 

18 covers the environmental impacts associated with the storage of spent nuclear fuel during the 

19 license renewal term, as well as the period after the licensed life for reactor operations.

20 The Table B–1 entry for “Offsite radiological impacts of spent nuclear fuel and high-level waste 

21 disposal” also was revised to reclassify the impact determination as a Category 1 issue with no 

22 impact level assigned. The finding column entry for this issue includes reference to the EPA’s 

23 radiation protection standards for the high-level waste and spent nuclear fuel disposal 

24 component of the fuel cycle. Although the status of a repository, including a repository at Yucca 

25 Mountain, is uncertain and outside the scope of the generic environmental analysis conducted

26 to support the Continued Storage Rule, the NRC believes that the current radiation standards 

27 for Yucca Mountain are protective of public health and safety and the environment and may 

28 properly be cited in environmental analyses prepared under NEPA.

29 The changes to these two issues finalize the Table B–1 entries that the NRC had intended to 

30 issue in its 2013 license renewal rulemaking but was unable to do so because the 2010 Waste 

31 Confidence Decision and Rule had been vacated.

32 NUREG–2157 concludes that deep geologic disposal remains technically feasible, although the 

33 bases for the specific conclusions in Table B–1 in Appendix B to Subpart A of 10 CFR Part 51

34 are found elsewhere (e.g., the 1996 rule that issued Table B–1 and the 1996 license renewal 

35 GEIS, which provided the technical basis for that rulemaking, as reaffirmed by the 

36 2013 rulemaking and final license renewal GEIS). Based on the Continued Storage Rule, these 

37 two issues were revised accordingly in Table B–1.

 

6 The 2013 license renewal rule renamed these two issues as ‘‘Onsite storage of spent nuclear fuel” and 

‘‘Offsite radiological impacts of spent nuclear fuel and high-level waste disposal,’’ respectively. (See 

“Revisions to Environmental Review for Renewal of Nuclear Power Plant Operating Licenses,” 78 FR 

37282–37324).
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1 6.1.1 CLI-14-08: Determination That Revised 10 CFR 51.23 and NUREG–2157 Satisfy

2 the NRC’s NEPA Obligations for Continued Storage and Accounting for the 

3 Environmental Impacts in NUREG–2157

4 In CLI-14-08 (NRC 2014c), the Commission held that the revised 10 CFR 51.23 and associated 

5 NUREG–2157 cure the deficiencies identified by the Court in New York v. NRC, 681 F.3d 471 

6 (D.C. Cir. 2012) and stated that the rule satisfies the NRC’s NEPA obligations with respect to 

7 continued storage for initial, renewed, and amended licenses for reactors.

8 As the Commission noted in CLI-14-08, the NRC staff must account for these environmental 

9 impacts before finalizing its licensing decision in an individual licensing proceeding. To account 

10 for these impact determinations, the generic environmental impact determinations made 

11 pursuant to the Continued Storage Rule and the associated NUREG–2157 are deemed 

12 incorporated into this final supplemental environmental impact statement (FSEIS) supplement.

13 The NRC staff relies on the Continued Storage Rule and its supporting GEIS

14 (i.e., NUREG–2157) to provide NEPA analyses of the environmental impacts of spent fuel 

15 storage at the reactor site or at an away-from-reactor storage facility beyond the licensed life for 

16 reactor operations. By virtue of the revised 10 CFR 51.23 regulation, the impact determinations 

17 in NUREG–2157 regarding continued storage complete the analysis of the environmental 

18 impacts associated with spent fuel storage beyond the licensed life for reactor operations and 

19 are deemed incorporated into this FSEIS supplement, as further described below.

20 6.1.1.1 At-Reactor Storage

21 The analysis in NUREG–2157 concludes that the potential impacts of at-reactor storage during 

22 the short-term timeframe (the first 60 years after the end of licensed life for operations of the 

23 reactor) would be SMALL (see Section 4.20 of NUREG–2157). Furthermore, the analysis in 

24 NUREG-2157 states that disposal of the spent fuel by the end of the short-term timeframe is the 

25 most likely outcome (see Section 1.2 of NUREG–2157).

26 However, the analysis in NUREG–2157 also evaluated the potential impacts of continued 

27 storage if the fuel is not disposed of by the end of the short-term timeframe. The analysis in 

28 NUREG–2157 determined that the impacts to historic and cultural resources from at-reactor 

29 storage during the long-term timeframe (the 100-year period after the short-term timeframe) and 

30 the indefinite timeframe (the period after the long-term timeframe) are dependent on factors that 

31 are unpredictable this far in advance and, therefore, concluded those impacts would be SMALL 

32 to LARGE (see Section 4.12 of NUREG–2157). Among other things, as discussed in

33 NUREG–2157, the NRC cannot accurately determine at this time what resources may be 

34 present or discovered at a continued storage site a century or more in the future and whether 

35 those resources will be historically or culturally significant to future generations. Additionally, 

36 impacts greater than SMALL could occur if the activities to replace an independent spent fuel 

37 storage installation (ISFSI) and the dry transfer system (DTS) adversely affect cultural or historic 

38 resources and if the effects cannot be mitigated. As discussed in NUREG–2157, given the 

39 minimal size of an ISFSI and DTS and the large land areas at nuclear power plant sites, 

40 licensees should be able to locate these facilities away from historic and cultural resources. 

41 Potential adverse effects on historic properties or impacts on historic and cultural resources 

42 could also be minimized through development of agreements, license conditions, and 

43 implementation of the licensee’s historic and cultural resource management plans and 

44 procedures to protect known historic and cultural resources and address inadvertent discoveries 

45 during construction and replacement of these facilities. However, it may not be possible to 

46 avoid adverse effects on historic properties under the National Historic Preservation Act 

47 of 1966, as amended (NHPA) (16 U.S.C. 470 et seq.), or impacts on historic and cultural 
Continued Storage of Spent Nuclear Fuel

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1 resources under NEPA; therefore, the analysis in NUREG–2157 concluded that impacts would

2 be SMALL to LARGE (see Section 4.12.2 of NUREG–2157).

3 The analysis in NUREG–2157 also concludes that the impacts of nonradioactive waste in the 

4 indefinite timeframe would be SMALL to MODERATE, with the higher impacts potentially 

5 occurring if the waste from repeated replacement of the ISFSI and DTS exceeds local landfill 

6 capacity (see Section 4.15 of NUREG–2157). Although the NRC concluded that nonradioactive 

7 waste disposal would not be destabilizing (or LARGE), the range reflects uncertainty regarding 

8 whether the volume of nonradioactive waste from continued storage would contribute to 

9 noticeable waste management impacts over the indefinite timeframe when considered in the 

10 context of the overall local volume of nonradioactive waste.

11 As previously discussed, the NRC found in NUREG–2157 that disposal of the spent fuel is most 

12 likely to occur by the end of the short-term timeframe. Therefore, disposal during the long-term 

13 timeframe is less likely, and the scenario depicted in the indefinite timeframe—continuing to 

14 store spent nuclear fuel indefinitely—is unlikely. As a result, the most likely impacts of the 

15 continued storage of spent fuel are those considered in the short-term timeframe. In the unlikely 

16 event that fuel remains on site into the long-term and indefinite timeframes, the associated 

17 impact ranges in NUREG–2157 reflect the accordingly greater uncertainties regarding the 

18 potential impacts over these very long periods of time. Taking into account the impacts that the 

19 NRC considers most likely, which are SMALL; the greater uncertainty reflected in the ranges in 

20 the long-term and indefinite timeframes compared to the greater certainty in the SMALL 

21 findings, and the relative likelihood of the timeframes, the impact determinations for at-reactor 

22 storage presented in NUREG–2157 are deemed incorporated into this FSEIS supplement 

23 pursuant to 10 CFR 51.23.

24 6.1.1.2 Away-from-Reactor Storage

25 In NUREG–2157, the NRC concluded that a range of potential impacts could occur for some 

26 resource areas if the spent fuel from multiple reactors is shipped to a large (roughly 

27 40,000 metric tons of uranium) away-from-reactor ISFSI (see Section 5.20 of NUREG–2157). 

28 The ranges for some resources are driven by the uncertainty regarding the location of such a 

29 facility and the local resources that would be affected.

30 As discussed in NUREG–2157, for away-from-reactor storage, the unavoidable adverse 

31 environmental impacts for most resource areas is SMALL across all timeframes, except for air 

32 quality, terrestrial resources, aesthetics, waste management, and transportation for which the 

33 impacts are SMALL to MODERATE. Socioeconomic impacts range from SMALL (adverse) to 

34 LARGE (beneficial), and historic and cultural resource impacts could be SMALL to LARGE 

35 across all timeframes. The potential MODERATE impacts on air quality, terrestrial wildlife, and 

36 transportation are based on potential construction-related fugitive dust emissions, terrestrial 

37 wildlife direct and indirect mortalities, terrestrial habitat loss, and temporary construction traffic 

38 impacts. The potential MODERATE impacts on aesthetics and waste management are based 

39 on noticeable changes to the viewshed from construction of a new away-from-reactor ISFSI and 

40 from the volume of nonhazardous solid waste generated by assumed facility ISFSI and DTS 

41 replacement activities for the indefinite timeframe, respectively. The potential LARGE beneficial 

42 impacts on socioeconomics are due to local economic tax revenue increases from an 

43 away-from-reactor ISFSI.

44 As further discussed in NUREG–2157, the potential impacts to historic and cultural resources 

45 during the short-term storage timeframe would range from SMALL to LARGE. The magnitude 

46 of adverse effects on historic properties and impacts on historic and cultural resources largely 

47 depends on where facilities are sited, what resources are present, what the extent of proposed 

48 land disturbance will be, whether the area has been previously surveyed to identify historic and 
Continued Storage of Spent Nuclear Fuel

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1 cultural resources, and whether the licensee has management plans and procedures that are 

2 protective of historic and cultural resources. Even a small amount of ground disturbance 

3 (e.g., clearing and grading) could affect a small but significant resource. In most instances, 

4 placement of storage facilities on the site can be adjusted to minimize or avoid impacts to any 

5 historic and cultural resources in the area. However, the NRC recognizes that this may not 

6 always be possible. The NRC’s site-specific environmental review and compliance with the 

7 NHPA process could identify historic properties, identify adverse effects, and potentially resolve 

8 adverse effects on historic properties and impacts on other historic and cultural resources. 

9 Under the NHPA, mitigation does not eliminate a finding of adverse effect on historic properties. 

10 The potential impacts to historic and cultural resources during the long-term and indefinite 

11 storage timeframes would also range from SMALL to LARGE. This range takes into 

12 consideration routine maintenance and monitoring (i.e., no ground-disturbing activities), the 

13 absence or avoidance of historic and cultural resources, and potential ground-disturbing 

14 activities that could affect historic and cultural resources. The analysis also considers 

15 uncertainties inherent in analyzing this resource area over long timeframes. These 

16 uncertainties include any future discovery of previously unknown historic and cultural resources; 

17 resources that gain significance within the vicinity and the viewshed (e.g., nomination of a 

18 historic district) due to improvements in knowledge, technology, and excavation techniques and 

19 changes associated with predicting resources that future generations will consider significant. If 

20 construction of a DTS and replacement of the ISFSI and DTS occurs in an area with no historic 

21 or cultural resource present or construction occurs in a previously disturbed area that allows 

22 avoidance of historic and cultural resources, then impacts would be SMALL. By contrast, a 

23 MODERATE or LARGE impact could result if historic and cultural resources are present at a 

24 site and, because they cannot be avoided, are affected by ground-disturbing activities during the 

25 long-term and indefinite timeframes.

26 NUREG–2157 indicates that impacts on Federally listed species, designated critical habitat, and 

27 essential fish habitat would be based on site-specific conditions and determined as part of 

28 consultations required by the ESA and the Magnuson–Stevens Fishery Conservation and 

29 Management Reauthorization Act of 2006, as amended (16 U.S.C. 1801–1884).

30 Finally, as discussed in NUREG–2157, continued storage of spent nuclear fuel at an away-from31 reactor ISFSI is not expected to cause disproportionately high and adverse human health and 

32 environmental effects on minority and low-income populations. As indicated in the 

33 Commission’s policy statement on environmental justice (69 FR 52040), should the NRC 

34 receive an application for a proposed away-from-reactor ISFSI, a site specific NEPA analysis 

35 would be conducted, and this analysis would include consideration of environmental justice 

36 impacts. Pursuant to 10 CFR 51.23, the impact determinations for away-from-reactor storage 

37 presented in NUREG–2157 are deemed incorporated into this FSEIS supplement.

38 6.1.1.3 Cumulative Impacts

39 NUREG–2157 examines the incremental impact of continued storage on each resource area 

40 analyzed in NUREG–2157 in combination with other past, present, and reasonably foreseeable 

41 future actions. NUREG–2157 indicates ranges of potential cumulative impacts for multiple 

42 resource areas (see Section 6.5 of NUREG–2157). However, these ranges are primarily driven 

43 by impacts from activities other than the continued storage of spent fuel at the reactor site; the 

44 impacts from these other activities would occur regardless of whether spent nuclear fuel is 

45 stored during the continued storage period. In the short-term timeframe, which is the most likely 

46 timeframe for the disposal of the fuel, the potential impacts of continued storage for at-reactor 

47 storage are SMALL and, therefore, would not be a significant contributor to the cumulative 

48 impacts. In the longer timeframes for at-reactor storage, or in the less likely case of 

49 away-from-reactor storage, some of the impacts from the storage of spent nuclear fuel could be 
Continued Storage of Spent Nuclear Fuel

121

1 greater than SMALL. As noted in NUREG–2157, other Federal and non-Federal activities 

2 occurring during the longer timeframes include uncertainties as well. It is primarily these 

3 uncertainties (i.e., those associated with activities other than continued storage) that contribute 

4 to the ranges of potential cumulative impacts discussed throughout Chapter 6 of NUREG–2157 

5 and summarized in Table 6-4 of NUREG–2157. Because, as stated above, the impacts from 

6 these other activities would occur regardless of whether continued storage occurs, the overall 

7 cumulative impact conclusions in NUREG–2157 would still be the stated ranges regardless of 

8 whether there are impacts of continued storage from any individual licensing action.

9 Taking into account the impacts that the NRC considers most likely, which are SMALL; the 

10 uncertainty reflected by the ranges in some impacts; and the relative likelihood of the 

11 timeframes, the impact determinations for cumulative impacts presented in NUREG–2157 are 

12 deemed incorporated into this FSEIS supplement pursuant to 10 CFR 51.23.

13 6.1.1.4 Conclusion

14 Based on the information discussed above, the impacts of continued storage of spent nuclear 

15 fuel are those presented in NUREG–2157 and are deemed incorporated into this FSEIS 

16 supplement pursuant to 10 CFR 51.23. The revised 10 CFR 51.23 and

17 NUREG–2157 have gone through a rulemaking process that involved significant input from the 

18 public. Therefore, the NRC staff concludes that the information in NUREG–2157 provides the 

19 appropriate NEPA analyses of the potential environmental impacts associated with the 

20 continued storage of spent fuel beyond the licensed life for reactor operations at Indian Point 

21 Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3).

22 The NRC staff concludes that the revised 10 CFR 51.23, which adopts the generic impact 

23 determination regarding continued storage from NUREG–2157, satisfies the NRC’s NEPA 

24 obligations with respect to continued storage of spent nuclear fuel as it relates to the issues 

25 “Offsite radiological impacts of spent nuclear fuel and high-level waste disposal” and “Onsite 

26 storage of spent nuclear fuel” for the environmental review associated with the license renewal 

27 for IP2 and IP3.

28 6.1.2 Revisions to the 2010 FSEIS Resulting from Revisions to 10 CFR 51.23

29 To account for the revisions to 10 CFR 51.23 and the resulting conforming changes throughout 

30 10 CFR Part 51, the NRC staff has updated the FSEIS as described below.

Lines 28-39 on page xvi in the Executive Summary of the FSEIS are revised as follows:

7 31

32 The supplemental environmental impact statement for license renewal is 

33 not required to include discussion of need for power or the economic 

34 costs and economic benefits of the proposed action or of alternatives to 

35 the proposed action except insofar as such benefits and costs are either 

36 essential for a determination regarding the inclusion of an alternative in 

37 the range of alternatives considered or relevant to mitigation. In addition, 

38 the supplemental environmental impact statement prepared at the license 

39 renewal stage need not discuss other issues not related to the 

40 environmental effects of the proposed action and the alternatives., or any 

41 aspect of the storage of spent fuel for the facility within the scope of 

42 the generic determination in 10 CFR 51.23(a)[“Temporary storage of 

 

7 The revised language in 10 CFR 51.95(c)(2) includes revisions made as part of the NRC’s 2013 update 

to 10 CFR Part 51 (78 FR 37282) that were discussed in Chapter 5 of this supplement.
Continued Storage of Spent Nuclear Fuel

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1 spent fuel after the cessation of reactor operation–generic 

2 determination of no significant environmental impact”] and in 

3 accordance with 10 CFR 51.23(b). The analysis of alternatives in the 

4 supplemental environmental impact statement should be limited to 

5 the environmental impacts of such alternatives and should 

6 otherwise be prepared in accordance with § 51.71 and appendix A to 

7 subpart A of this part. As stated in § 51.23, the generic impact 

8 determinations regarding the continued storage of spent fuel in 

9 NUREG–2157 shall be deemed incorporated into the supplemental 

10 environmental impact statement.

11 Lines 7-10 on page 1-5 in Section 1.2.2 of the FSEIS are revised as follows:

12 • discuss any aspect of the storage of spent fuel within the scope 

13 of the generic determination in 10 CFR 51.23(a) in accordance 

14 with 10 CFR 51.23(b)the environmental impacts of the continued 

15 storage of spent fuel, as stated in 10 CFR 51.23

16 • pursuant to 10 CFR 51.2353(c)(3)(iii) and (iv), contain an analysis of 

17 any Category 1 issue unless there is significant new information on a 

18 specific issue

19 Table 6–1 on page 6-2 in Section 6.1 of the FSEIS is revised as follows:

20 Table 6–1. Category 1 Issues Applicable to the Uranium Fuel Cycle

21 and Solid Waste Management during the Renewal Term

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B–1 GEIS Section

Uranium Fuel Cycle and Waste Management

Offsite radiological impacts (individual effects from other than the 

disposal of spent fuel and high-level waste)

6.1; 6.2.1; 6.2.2.1; 6.2.2.3; 

6.2.3; 6.2.4; 6.6

Offsite radiological impacts (collective effects) 6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6

Offsite radiological impacts (of spent nuclear fuel and high-level 

waste disposal)

6.1; 6.2.2.1; 6.2.2.2; 6.2.3;

6.2.4; 6.64.11.1.3(a)

Nonradiological impacts of the uranium fuel cycle 6.1; 6.2.2.6; 6.2.2.7; 6.2.2.8; 

6.2.2.9; 6.2.3; 6.2.4; 6.6

Low-level waste storage and disposal 6.1; 6.2.2.2; 6.4.2; 6.4.3; 6.4.4

Mixed waste storage and disposal 6.1; 6.4.5; 6.6

Onsite storage of spent nuclear fuel 6.1; 6.4.6; 6.64.11.1.2(b)

Nonradiological waste 6.1; 6.5; 6.6

Transportation 6.1; 6.3, Addendum 1; 6.6

(a) NRC 2013a

(b) The environmental impact of this issue during the license renewal term is contained in the 2013 GEIS 

(NRC 2013a). The environmental impact of this issue for the timeframe beyond the licensed life for reactor 

operations is contained in NUREG–2157 (NRC 2014f).

22 Before line 5 on page 6-2 of Section 6-1 of the FSEIS, the following text is added:

23 The NRC staff’s evaluation of the environmental impacts associated 

24 with spent nuclear fuel is addressed in two issues in Table 6–1, 

25 “Offsite radiological impacts of spent nuclear fuel and high-level 

26 waste disposal” and “Onsite storage of spent nuclear fuel.” 
Continued Storage of Spent Nuclear Fuel

123

1 However, as explained later in this section, these two issues now 

2 incorporate the generic environmental impact determinations 

3 codified in the revised 10 CFR 51.23 pursuant to the Continued 

4 Storage Rule (79 FR 56238).

5 Regarding the remaining issues in Table 6–1, Entergy Nuclear 

6 Operations, Inc. (Entergy), stated in the IP2 and IP3 environmental report 

7 (ER) (Entergy 2007) that it is not aware of any new and significant 

8 information associated with the renewal of the IP2 and IP3 operating 

9 licenses, though it did identify leaks to groundwater as a potential new

10 issue.

11 Lines 6-42 on page 6-4, lines 1-43 on page 6-5, and lines 1-33 on page 6-6 of Section 6.1 of 

12 the FSEIS are deleted.

125

1 7.0 SECTION 7 CONSULTATION

2 Reinitiation of Consultation due to FWS’s Listing of Northern Long-eared 

3 Bat

4 On April 2, 2015, the U.S. Fish and Wildlife Service (FWS) published a final rule that lists the 

5 northern long-eared bat (Myotis septentrionalis) as threatened throughout its range under the 

6 Endangered Species Act of 1973, as amended (ESA) (16 U.S.C. 1531 et seq.) (Volume 80 of 

7 the Federal Register (FR) (FR 17974)). On June 8, 2015, Entergy (2015e) submitted to the 

8 U.S. Nuclear Regulatory Commission (NRC) information concerning Federally listed bats at 

9 Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3). NRC (2015e) prepared a 

10 biological assessment that evaluated the potential effects of the proposed license renewal on 

11 the northern long-eared bat, a species that was not considered in the 2010 final supplemental 

12 environmental impact statement (FSEIS) or the 2013 supplement to the FSEIS. The biological 

13 assessment also considered whether Entergy’s updated information affected the NRC’s (2010) 

14 previous finding that IP2 and IP3 license renewal is “not likely to adversely affect” the Indiana 

15 bat (Myotis sodalis). In the biological assessment, the NRC concluded that the proposed IP2 

16 and IP3 license renewal may affect, but is not likely to adversely affect, the northern long-eared 

17 bat and Indiana bat. This conclusion was based on the NRC’s assessment of several potential 

18 effects, which are summarized as follows.

19 • The proposed license renewal could result in injury or mortality of northern long20 eared or Indiana bat individuals through collision with plant structures, but this impact 

21 would be discountable because the impact is extremely unlikely given that no bat 

22 collisions of any species have been documented on the site since IP2 and IP3 began 

23 operating in the mid-1970s.

24 • The proposed license renewal would result in no habitat loss, degradation, 

25 disturbance, or fragmentation, and the continued preservation of forest habitat on the 

26 site would result in a beneficial impact to the two species, if present on the site.

27 • Site maintenance activities would not result in effects significantly different than 

28 those experienced by bats during the current license terms and any additional 

29 impacts resulting from the replacement of the IP2 and IP3 reactor vessel head and 

30 control rod drive mechanisms would be temporary, insignificant, and discountable.

31 In a letter dated July 1, 2015, the NRC (2015f) transmitted its biological assessment to the FWS

32 for review. In a letter dated July 14, 2015, the FWS (2015) provided its concurrence with the 

33 NRC’s “not likely to adversely affect” determinations for northern long-eared and Indiana bats. 

34 The FWS (2015) also confirmed that no further consultation or coordination pursuant to the ESA 

35 is required with the FWS unless project plans change or additional information on listed or 

36 proposed species or critical habitat becomes available.

127

1 8.0 SUMMARY AND CONCLUSIONS

2 By letter dated April 23, 2007, Entergy Nuclear Operations, Inc. (Entergy), submitted an 

3 application to the U.S. Nuclear Regulatory Commission (NRC) to issue renewed operating 

4 licenses for Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3) for additional 

5 20-year periods. As required by Title 10 of the Code of Federal Regulations (10 CFR) 51.95(c), 

6 the NRC staff prepared a supplement to NUREG–1437, Generic Environmental Impact 

7 Statement for License Renewal of Nuclear Plants (GEIS) (NRC 1996); the supplement to the 

8 1996 GEIS was published on December 10, 2010 (NRC 2010). The 2010 final supplemental 

9 environmental impact statement (FSEIS) documents the NRC staff’s analysis that considers and 

10 weighs the environmental effects of the proposed action (including cumulative impacts), the 

11 environmental impacts of alternatives to the proposed action, and mitigation measures available 

12 for reducing or avoiding adverse effects. The 2010 FSEIS also includes the NRC staff’s 

13 recommendation regarding the proposed action—renewal of the IP2 and IP3 operating licenses 

14 for additional 20-year periods. As documented in the 2010 FSEIS, the NRC staff concluded 

15 that:

16 Based on (1) the analysis and findings in the [1996] GEIS, (2) the ER and 

17 other information submitted by Entergy, (3) consultation with Federal, 

18 State, Tribal, and local agencies, (4) the NRC staff’s consideration of 

19 public scoping comments received, and comments on the draft SEIS, and 

20 (5) the NRC staff’s independent review, the recommendation of the NRC 

21 staff is that the Commission determine that the adverse environmental 

22 impacts of license renewal for IP2 and IP3 are not so great that 

23 preserving the option of license renewal for energy planning 

24 decisionmakers would be unreasonable.

25 In June 2013, the NRC staff issued a supplement to the 2010 FSEIS, updating its final analysis 

26 to include corrections to impingement and entrainment data presented in the FSEIS, revised

27 conclusions regarding thermal impacts based on newly available thermal plume studies, and 

28 provided an update of the status of the NRC staff’s consultation under Section 7 of the 

29 Endangered Species Act of 1973, as amended (ESA) (16 U.S.C. 1531 et seq.), with the

30 National Marine Fisheries Service regarding the shortnose sturgeon and Atlantic sturgeon. As 

31 documented in the 2013 FSEIS supplement, the NRC staff revised its conclusion on the impacts 

32 of impingement and entrainment on the spottail shiner from LARGE to SMALL. However, the 

33 NRC staff’s conclusion that the overall impacts due to impingement and entrainment resulting 

34 from the operation of the IP2 and IP3 cooling systems, as documented in the 2010 FSEIS, 

35 remained MODERATE. For the issue of thermal impacts, the NRC staff revised its conclusion 

36 to SMALL, from SMALL to LARGE, based on the availability of thermal plume studies that were 

37 not available at the time that the 2010 FSEIS was published. With respect to consultation under 

38 Section 7 of the ESA, the NRC staff examined the new information from consultations with the 

39 National Marine Fisheries Service and determined that the level of impact for aquatic special 

40 status species remained SMALL.

41 The NRC staff prepared this supplement to address new information identified subsequent to 

42 publishing the 2013 FSEIS supplement. This new information was derived from (1) refined 

43 engineering project cost estimates for the 22 potentially cost-beneficial severe accident 

44 mitigation alternative (SAMAs) previously identified in the FSEIS; (2) newly available information 

45 relevant to the impacts from the operation of IP2 and IP3 on certain aquatic species in the 

46 Hudson River; (3) the NRC’s amended regulations at Appendix B to Subpart A of 

47 10 CFR Part 51, “Environmental Protection Regulations for Domestic Licensing and Related 
Summary and Conclusions

128

1 Regulatory Functions”; and (4) the NRC’s amended regulations at 10 CFR 51.23. In addition, 

2 this supplement describes the reinitiation of consultation under Section 7 of the Endangered 

3 Species Act regarding the northern long-eared bat (Myotis septentrionalis) and provides an 

4 update on the status of the operating licenses for IP2 and IP3.

5 Environmental Impacts of License Renewal from Issues Considered in this 

6 Supplement

7 Based on its review of the engineering cost estimates provided by Entergy Nuclear Operations, 

8 Inc. (Entergy), the NRC staff concludes that the approach used and costs provided are 

9 reasonable. For the six SAMAs that Entergy identified as no longer being potentially cost

10 beneficial, the NRC staff concludes that, for two of the SAMAs that were identified as no longer 

11 being cost beneficial (IP2-021 and IP2-053), the incremental difference by which the SAMAs are 

12 not cost beneficial is too small to exclude them from further consideration. However, these

13 SAMAs do not relate to adequately managing the effects of aging during the period of extended

14 operation. Therefore, they need not be implemented as part of license renewal pursuant to

15 10 CFR Part 54.

16 Based on its review of Entergy’s new information relating to the impacts to aquatic resources, 

17 the NRC staff concludes that the potential impacts to aquatic resources as a result of projected 

18 impingement and entrainment at IP2 and IP3 during the relicensing period would be no more 

19 than MODERATE. This conclusion is similar to that found in Entergy’s February 19, 2014, letter 

20 transmitting the new information and is not greatly different than the NRC staff’s conclusion of 

21 MODERATE found in the 2010 FSEIS, as supplemented by the 2013 FSEIS supplement.

22 The NRC’s 2013 amendment to its regulations at Table B–1 of Appendix B to Subpart A of 

23 10 CFR Part 51 redefined the number and scope of the generic and site-specific environmental

24 impact issues that must be addressed during license renewal environmental reviews. The NRC 

25 staff identified 10 Category 1 issues that either had been added to Table B–1 of Appendix B to 

26 Subpart A of 10 CFR Part 51 or had changed in scope as part of the 2013 rulemaking. As part 

27 of its review of these issues, the NRC staff did not identify any new and significant information 

28 related to these Category 1 issues that would call into question the conclusions in the 

29 2013 GEIS. Therefore, the NRC staff relied on the conclusions of the 2013 GEIS for these

30 Category 1 issues.

31 For the new Category 2 issue “Effects on terrestrial resources (non-cooling system impacts),” 

32 the NRC staff concludes that issuing renewed licenses for IP2 and IP3 would have SMALL 

33 impacts. For the Category 2 issue “Radionuclides released to groundwater,” the NRC staff 

34 concludes that the impacts to groundwater quality due to the continued operation of IP2 and IP3 

35 would be SMALL to MODERATE. Specifically, the NRC finds that MODERATE impacts to 

36 groundwater quality, which are a result of radiological contamination from inadvertent releases 

37 of radionuclides to groundwater, could be mitigated to SMALL during the license renewal term 

38 through the elimination of radionuclide leaks to the groundwater and the use of monitored 

39 natural attenuation.

40 For the two new Category 2 issues added to Table B–1 of Appendix B to Subpart A of 

41 10 CFR Part 51 for which an analysis had been performed in the 2010 FSEIS—“Minority and 

42 low-income populations” and “Cumulative impacts”—the NRC staff concludes that the 

43 environmental impacts of issuing renewed licenses for IP2 and IP3 are bounded by the 

44 conclusions in the 2010 FSEIS.
Summary and Conclusions

129

1 Additionally, as discussed in Chapter 6 of this supplement, the impacts of continued storage of 

2 spent nuclear fuel are those presented in NUREG–2157 and are deemed incorporated into this 

3 FSEIS supplement pursuant to 10 CFR 51.23.

4 Recommendation

5 Based on its evaluation of information available since publication of the FSEIS in 

6 December 2010, as documented in the first FSEIS supplement published in June 2013, as well 

7 as this FSEIS supplement, the NRC staff reaffirms its recommendation in the 2010 FSEIS. 

8 Specifically, the NRC staff recommends that “the Commission determine that the adverse 

9 environmental impacts of license renewal for IP2 and IP3 are not so great that preserving the 

10 option of license renewal for energy planning decision makers would be unreasonable.”

11 Revisions to Chapter 9 of the 2010 FSEIS

12 Lines 14-17 of page 9-1 in Section 9.0 of the FSEIS are revised as follows:

13 If the license renewal review is ongoing at the time of license expiration, 

14 the units will be allowed to continue operating until the NRC makes a 

15 determination. The IP2 operating license will was set to expire on 

16 September 28, 2013; the IP3 operating license will was set to expire on 

17 December 12, 2015.

18 Lines 28-38 on page 9-2 of Section 9.0 of the FSEIS are revised as follows:

19 The supplemental environmental impact statement for license renewal is 

20 not required to include discussion of need for power or the economic 

21 costs and economic benefits of the proposed action or of alternatives to 

22 the proposed action except insofar as such benefits and costs are either 

23 essential for a determination regarding the inclusion of an alternative in 

24 the range of alternatives considered or relevant to mitigation. In addition, 

25 the supplemental environmental impact statement prepared at the license 

26 renewal stage need not discuss other issues not related to the 

27 environmental effects of the proposed action and the alternatives., or any 

28 aspect of the storage of spent fuel for the facility within the scope of 

29 the generic determination in 10 CFR 51.23(a) and in accordance with 

10 CFR 51.23(b).(2) 30 The analysis of alternatives in the supplemental 

31 environmental impact statement should be limited to the 

32 environmental impacts of such alternatives and should otherwise be 

33 prepared in accordance with § 51.71 and appendix A to subpart A of 

34 this part. As stated in § 51.23, the generic impact determinations 

35 regarding the continued storage of spent fuel in NUREG–2157 shall 

36 be deemed incorporated into the supplemental environmental 

37 impact statement.

38 Footnote 2 on page 9-2 of Section 9.0 of the FSEIS is deleted.

39 Lines 7-21 on page 9-5 of Section 9.1 of the FSEIS, as modified in the 2013 FSEIS 

40 supplement, are revised as follows:

41 For all issues of SMALL significance, current measures to mitigate the 

42 environmental impacts of plant operation were found to be adequate. For 

43 the issues of MODERATE significance (i.e., issues related to aquatic 

44 ecology), mitigation measures are addressed both in Chapter 4 and in 
Summary and Conclusions

130

1 Chapter 8 as alternatives based on determinations in the draft New York 

2 State Department of Environmental Conservation (NYSDEC) State 

3 Pollutant Discharge Elimination System (SPDES) permit proceeding, 

4 Clean Water Act Section 401 proceeding, and in draft policy statements 

5 published by the State. In Chapter 8, the NRC staff considers the 

6 impacts that may result if the plant converts from once-through cooling to 

7 a closed-cycle cooling system (Section 8.1.1).

8 Cumulative impacts of past, present, and reasonably foreseeable future 

9 actions were considered, regardless of what agency (Federal or non10 Federal) or person undertakes such other actions. The NRC staff 

11 concludes that the cumulative impacts to the environment around IP2 and 

12 IP3 license renewal would be LARGE for some affected resources, given 

13 historical environmental impacts, current actions, and likely future actions. 

14 With the exception of aquatic resources and radionuclides released to 

15 groundwater, the contribution of IP2 and IP3 to cumulative impacts is 

16 SMALL.

17 Lines 9-12 on page 9-6 of Section 9.1.1 of the FSEIS are revised as follows:

18 Adverse impacts of continued operation from (a) heat shock and (b) the 

19 combined effects of entrainment and impingement of fish and shellfish are 

20 considered to be potentially SMALL to LARGE, and MODERATE, 

21 respectively. Other adverse impacts are considered to be of SMALL 

22 significance.

23 Lines 24-34 on page 9-7 of Section 9.2 of the FSEIS are revised as follows:

24 Table 9–1 shows the significance of the plant-specific environmental 

25 effects of the proposed action (renewal of IP2 and IP3 operating licenses) 

26 as well as the environmental effects of alternatives to the proposed 

27 action. Impacts from license renewal would be SMALL for all impact 

28 categories except aquatic ecology, which includes the impacts of heat 

29 shock, entrainment, and impingement, and water use and quality, 

30 which includes the issue of radionuclides released to groundwater. 

31 Chapter 4 of this SEIS describes the MODERATE impacts of plant 

32 operation on aquatic ecology through impingement and entrainment 

33 (impact levels vary by species), and the potentially SMALL to LARGE 

34 impacts from thermal shock. Overall, impacts to aquatic ecology from 

35 continued operation of IP2 and IP3 without cooling system modifications 

36 or restoration actions are SMALL to LARGE MODERATE. License 

37 renewal will result in SMALL to MODERATE impacts to water use 

38 and quality as a result of inadvertent releases of radionuclides to 

39 groundwater. A single significance level was not assigned for the 

40 collective offsite radiological impacts from the fuel cycle and from 

41 high-level radioactive waste spent fuel disposal (see Chapter 6) or for the 

42 impacts of greenhouse gases (GHG).

43 Table 9–1 on page 9-9 of Section 9.2 of the FSEIS is revised as follows:
Summary and Conclusions

131

1 Table 9–1. Summary of Environmental Significance of License Renewal and 

2 Alternatives

Impact 

Category

Proposed 

Action

No-Action 

Alternative(b)

License 

Renewal with

NGCC(d)

License 

Renewal

Plant 

Shutdown

New ClosedCycle 

Cooling

At the IP Site or a 

Repowered Site At a New Site

Land Use SMALL SMALL SMALL to

LARGE

SMALL to

MODERATE

MODERATE to 

LARGE

Ecology—

Aquatic

SMALL to

MODERATE

and SMALL 

to LARGE(a)

SMALL SMALL SMALL SMALL

Ecology—

Terrestrial

SMALL SMALL SMALL to

MODERATE

SMALL SMALL to 

MODERATE

Water Use and

Quality

SMALL to 

MODERATE

SMALL SMALL to 

MODERATE

SMALL SMALL to 

MODERATE

Air Quality SMALL SMALL SMALL to

LARGE

SMALL to

MODERATE

SMALL to 

MODERATE

Waste SMALL SMALL SMALL to

LARGE

SMALL SMALL

Human Health SMALL(c) SMALL SMALL SMALL SMALL

Socioeconomic

s

SMALL SMALL to

MODERATE

SMALL SMALL to

MODERATE

SMALL to 

MODERATE

Transportation SMALL SMALL SMALL to

LARGE

SMALL to

MODERATE

SMALL to 

MODERATE

Aesthetics SMALL SMALL MODERATE

to LARGE

SMALL SMALL to 

LARGE

Historical and 

Archeological

Resources

SMALL SMALL SMALL to

MODERATE

SMALL to

MODERATE

SMALL to 

MODERATE

Environmental 

Justice

SMALL SMALL SMALL SMALL to LARGE SMALL to 

LARGE

3 Table 9–1 on page 9-10 of Section 9.2 of the FSEIS is revised as follows:

4 Table 9–1 (continued)

Conservation/Energy 

Efficiency Combination of Alternatives

Impact Category

Option 1:

One IP unit, onsite 

gas, offsite 

renewables, and

conservation

Option 2:

Gas, offsite

renewables, 

additional imported 

power, and

conservation

Land Use SMALL SMALL to MODERATE SMALL to MODERATE

Ecology – Aquatic SMALL SMALL to LARGE SMALL to LARGE

Ecology – Terrestrial SMALL SMALL to LARGE SMALL to LARGE

Water Use and Quality SMALL SMALL to LARGE SMALL to LARGE
Summary and Conclusions

132

Conservation/Energy 

Efficiency Combination of Alternatives

Air Quality SMALL SMALL to MODERATE SMALL to MODERATE

Waste SMALL SMALL to LARGE SMALL to LARGE

Human Health SMALL SMALL SMALL

Socioeconomics SMALL to MODERATE SMALL SMALL to MODERATE

Transportation SMALL MODERATE MODERATE

Aesthetics SMALL SMALL to LARGE SMALL to LARGE

Historical and 

Archeological

Resources 

SMALL SMALL to MODERATE SMALL to MODERATE

Environmental Justice SMALL SMALL to LARGE SMALL to LARGE

(a) NRC staff analysis indicates that impingement and entrainment impacts are MODERATE, but that thermal

shock effects could potentially range from are likely to be SMALL to LARGE.

(b) The no-action alternative does not, on its own, meet the purpose and need of the GEIS. No action would

necessitate other generation or conservation actions which may include—but are not limited to—the alternatives

addressed in this table.

(c) For the collective offsite radiological impacts from the fuel cycle and from high-level waste and spent fuel 

disposal, a specific significance level was not assigned. See Chapter 6 for details.

(d) Analysis was based on use of a closed-cycle cooling system.
133

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1 10.0 LIST OF PREPARERS

2 Members of the NRC’s Office of Nuclear Reactor Regulation prepared this FSEIS supplement 

3 with assistance from other NRC organizations, as well as contract support from the Pacific 

4 Northwest National Laboratory. Table 10–1 identifies each contributor’s name, affiliation, and 

5 function or expertise.

6 Table 10–1. List of Preparers

Name Affiliation Function or Expertise

NRC

Russell Chazell Nuclear Reactor Regulation Human Health

James Danna Nuclear Reactor Regulation Branch Chief

Kevin Folk Nuclear Reactor Regulation Surface Water

William Ford Nuclear Reactor Regulation Groundwater

Briana Grange Nuclear Reactor Regulation Ecology

Kimberly Green Nuclear Reactor Regulation Severe Accident Mitigation Alternatives

Robert Hoffman Nuclear Reactor Regulation Cumulative Impacts

Steve Klementowicz Nuclear Reactor Regulation Radioactive Waste

Dennis Logan Nuclear Reactor Regulation Ecology

Nancy Martinez Nuclear Reactor Regulation Air Quality, Greenhouse Gases

John Parillo Nuclear Reactor Regulation Severe Accident Mitigation Alternatives

Michael Wentzel Nuclear Reactor Regulation Project Manager

David Wrona Nuclear Reactor Regulation Branch Chief

Contractor

Valerie Cullinan Pacific Northwest National Laboratory Statistics, Ecology

1 APPENDIX A

2

3 REVISED IMPINGEMENT AND ENTRAINMENT

4 IMPACT ANALYSIS FOR

5 INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3

A-1

1 A. REVISED IMPINGEMENT AND ENTRAINMENT IMPACT ANALYSIS 

2 FOR INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3

3 A.1 Introduction

4 By letter dated April 23, 2007, Entergy Nuclear Operations, Inc. (Entergy) submitted an 

5 application to the U.S. Nuclear Regulatory Commission (NRC) to issue renewed operating 

6 licenses for Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3) for additional 

7 20-year periods. Under Title 10 of the Code of Federal Regulations (10 CFR) 51.20(b)(2) and 

8 the National Environmental Policy Act of 1969, as amended (NEPA) (42 U.S.C. 4321 et seq.), 

9 the renewal of a power reactor operating license requires preparation of an environmental 

10 impact statement (EIS) or a supplement to an existing EIS. In addition, 10 CFR 51.95(c) states 

11 that the NRC shall prepare an EIS, which is a supplement to the Commission’s NUREG–1437, 

12 Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), 

13 Revision 1, which was issued in June 2013.

14 The NRC staff published its final supplemental environmental impact statement (FSEIS) for IP2 

15 and IP3 in December 2010. The FSEIS (NRC 2010) considered the effects of impingement and 

16 entrainment (I&E), among other topics. In 2011, Entergy and others submitted new and revised 

17 I&E data, analyses, and comments. The NRC staff considered this new information, 

18 incorporated it into its analysis, modified some of its I&E findings, and published a supplement 

19 to the FSEIS in June 2013 (NRC 2013). In February 2014 and April 2015, Entergy (2014, 2015) 

20 submitted additional new information that affected some of the NRC staff’s results. The NRC 

21 staff has considered the new information and updated its impact assessment. This Appendix 

22 addresses Entergy’s new information on the impacts of I&E at IP2 and IP3 and provides support 

23 for the discussion contained in Section 4 of the current FSEIS supplement. As such, it 

24 constitutes a separate analysis from the analyses presented in the 2013 FSEIS supplement and 

25 Chapter 4 and Appendices H and I of the 2010 FSEIS for the license renewal of IP 2 and IP 3.

26 The IP2 and IP3 site is located on the Hudson River estuary at River Kilometer 67 (River 

27 Mile 42). Cooper et al. (1988) and Levinton and Waldman (2006) describe the geological, 

28 physical, chemical, and biological setting of the Hudson River. Beebe and Savidge (1988), 

29 Daniels et al. (2005), and Waldman et al. (2006) describe the fish communities of the Hudson 

30 River estuary and their environment. IP2 and IP3 began operation in 1974 and 1976, 

31 respectively, and withdraw more cooling water than any other facility intake from the Hudson 

32 River estuary. The investigation of the effects of power plant water intakes on the Hudson River 

33 ecosystem began in the early 1960s, and the results of many I&E studies have been published. 

34 Results of early investigations into the effects of I&E at IP2 and IP3 appear in 

35 Barnthouse et al. (1988). NRC (2010) describes IP2 and IP3 and the impact of plant operation, 

36 including I&E, on the environment.

37 For assessing impacts under NEPA, the NRC classifies impacts into three levels using 

38 definitions found in 10 CFR Part 51 and NRC (2013):

39 • SMALL—Environmental effects are not detectable or are so minor that they will 

40 neither destabilize nor noticeably alter any important attribute of the resource.

41 • MODERATE—Environmental effects are sufficient to alter noticeably, but not to 

42 destabilize, any important attributes of the resource.

43 • LARGE—Environmental effects are clearly noticeable and are sufficient to 

44 destabilize any important attributes of the resource.
Appendix A

A-2

1 • The NRC’s definitions of SMALL, MODERATE, and LARGE impact levels center on 

2 two properties of the response of the resource to the environmental stresses from 

3 power plant operation: Is the response detectable or noticeable and is it sufficient to 

4 destabilize any important attributes of the resource. The definitions do not define 

5 “stabilize” or “destabilize,” and ecologists have adopted over a dozen different 

6 operational definitions of ecological stability, depending on application. For effects 

7 on aquatic resources, the NRC staff has adapted the concept of stability meaning not 

8 changing in time or space due to power plant operation. This concept of stability has 

9 several advantages here. Attributes of populations can be statistically tested for 

10 change using analysis of variance (ANOVA), regression (trend analysis), or other 

11 means; commercial and recreational fishing records or other information can be used 

12 in addition to local monitoring studies; and past responses of the resource to plant 

13 operation can be used to predict future impacts. The analysis below applies these 

14 concepts to determine impacts to representative species and life stages to infer an 

15 overall level of impact for aquatic resources.

16 Previous analyses of I&E at IP2 and IP3, as at most power plants, generally employed modified 

17 fisheries models. Fisheries biology models tend to focus on single species attributes, such as 

18 sustaining a harvest rate, regardless of any changes in the attributes of other species within the 

19 ecosystem. The Hudson River estuary is a dynamic, open-ended system containing a complex 

20 food web hydrologically connected from freshwater habitats near the Troy Dam to the Atlantic 

21 Ocean, and I&E affects the various life stages of many species, their predators, prey, and 

22 competitors simultaneously. Even under the best circumstances, the number of unknowns in 

23 such typical fisheries models greatly exceeds the number of observations in the environment, 

24 and the models have shortcomings and should be viewed skeptically (Schnute and 

25 Richards 2001). In assessing the impacts of power plant operations on Hudson River striped 

26 bass, Fletcher and Deriso (1988) found that routine or creative uses of existing 

27 spawner-recruitment models were not useful for long-term impact forecasting and that the 

28 techniques and methods of analysis that fail in fishery assessments are also likely to fail in 

29 impact assessment.

30 The NRC staff analysis (NRC 2010, 2013) sought to consider potential impacts across trophic 

31 levels and life history strategies by weighting two lines of evidence (LOEs), as recommended by 

32 the U.S. Environmental Protection Agency (EPA) (EPA 1998) for ecological risk assessments, 

33 to several sentinel species to achieve an ecosystem-level understanding. The approach is 

34 empirical and minimizes the number of unknowns and assumptions. A weight of evidence 

35 (WOE) approach combines the two LOEs for impact assessment loosely following 

36 Menzie et al. (1996).

37 The first LOE is population trends of representative important species (RIS), with decreasing 

38 trends in population size of crabs and young-of-the-year fish (together referred to as YOY) 

39 across the 27 years of monitoring data being evidence of resource destabilization. The second 

40 LOE, called strength of connection (SOC), employs a Monte Carlo technique to determine 

41 whether statistically significant decreasing trends in abundance could be observable. The final 

42 WOE combines the two LOEs to address the components of resource stability and observability 

43 in the NRC staff’s impact-level definitions. The WOE integrates the two LOEs following the logic 

44 developed by EPA for evaluating the ecological effects of environmental stressors (EPA 1998). 

45 In this assessment, the IP2 and IP3 cooling system operation is the stressor; the aquatic 

46 community, as represented by sentinel populations, is the receptor; the SOC qualifies degree of 

47 exposure; and the trend analysis quantifies the effect on the receptors.
Appendix A

A-3

1 A.2 Methods

2 The NRC staff’s present analysis differs somewhat from the analyses in the FSEIS 

3 (NRC 2010, 2013), Entergy’s (2014) and AKRF’s (2014) submissions, and Entergy’s (2015) and 

4 AKRF’s (2015) submissions in response to NRC staff (2015) requests for additional information. 

5 The NRC staff’s present independent analysis uses data from 1985 through 2011 for both the 

6 population trend analyses and for the regression and variability parameters used in the Monte

7 Carlo SOC analysis, as does AKRF (2014, 2015), but it incorporates field data updated by 

8 Entergy following the submission of the AKRF report (reviewed in Section 4.1). In addition, 

9 another difference between AKRF’s and the NRC staff’s analyses is that AKRF selected periods 

10 of consistent sampling based on sample week number, while the NRC staff uses month 

11 designations, due to differences in the available data sets. The NRC staff’s evaluation in this 

12 appendix is a “standalone” presentation that references information in previous FSEIS volumes 

13 and does not contain redline-strikeout text, figures, or tables to replace information and 

14 statements presented in the 2010 FSEIS or 2013 FSEIS supplement. Except where it is 

15 necessary to differentiate between volumes, the NRC staff collectively refers to the 2010 FSEIS, 

16 as modified by the 2013 FSEIS supplement, as the FSEIS in this appendix.

17 Data sources 

18 Data on fish in the Hudson River come from a multi-utility Hudson River Monitoring Program. 

19 Several Hudson River utilities have conducted monitoring studies of fish in the Hudson River 

20 from 1975 through the present. At the NRC staff’s request, Entergy supplied data from the 

21 Hudson River Estuary Monitoring Program in 2007, corrected and new information in 2008, and 

22 new information in 2011. Entergy voluntarily submitted new information in 2014, including 

23 additional years of data. In response to additional NRC staff requests, Entergy provided data 

24 from the Hudson River monitoring programs in October 2014 and corrected data in April 2015.

25 The Hudson River Monitoring Program (Program) includes three surveys to sample fish in the 

26 river. The Long River Survey (LRS) collects eggs, larvae, and juvenile fish; the Fall Shoals 

27 Survey (FSS) collects juvenile and older fish in the river; and the Beach Seine Survey (BSS) 

28 collects juvenile and older fish in shallow beach areas. The Program divides the river into 

29 13 regions or segments (Figure A–1) from the Federal dam in Troy south to the Battery in 

30 Manhattan (Klauda et al. 1988, Abood et al. 2006). IP2 and IP3 lie in River Segment 4, the 

31 Indian Point segment. Each river segment consists of four habitat strata. The shore stratum 

32 extends from the shoreline to a depth of 10 feet (ft) (3 m) (sampled by the BSS). The shoal 

33 stratum extends from the shore to a depth of 20 feet (6 m) at mean low tide (sampled by the 

34 LRS and FSS) on both sides of the river. The stratum bottom extends upward from the bottom 

35 to 10 feet (3 m) above the river bottom where the water depth is greater than 20 feet (6 m) at 

36 mean low tide (sampled by the LRS and BSS). The channel stratum is the portion of the river 

37 not considered bottom where the river depth exceeds 20 feet (6 m) at mean low tide (sampled 

38 by the LRS and FSS). The Program allocates samples to segments and strata in a stratified 

39 random design. The LRS samples early in the year (Figure A–2) and is designed to capture 

40 ichthyoplankton, although it also captures YOY of some species. The FSS and BSS sample 

41 later in the year and are designed to capture YOY and older fish. ASA (2013) describes the 

42 Program and survey methods in detail.

43 Sampling methods varied somewhat in the early years of the Program until 1985. The FSS 

between 1974 and 1984 employed a 1-square meter (m2

) (1-yard (yd)2 44 ) Tucker trawl with a 

3-millimeter (mm) (1/8-in.) mesh to sample the channel and a 1-m2 (1-yd2 45 ) epibenthic sled with a 

46 3-mm (1/8-inch (in.)) mesh to sample the bottom and shoal strata. From 1985 to present, a 

47 3-m (1-yd) beam trawl with a 38-mm (11⁄2-in.) mesh on all but the cod-end replaced the 

48 epibenthic sled. Size selectivity and relative catch efficiency between gear types was tested 
Appendix A

A-4

1 during nocturnal samplings between August and September 1984, and the beam trawl sampled 

2 bay anchovy, American shad, and weakfish more efficiently than the epibenthic sled 

3 (NYPA 1986).

4 Figure A–1. Sampling Regions of the Hudson River Monitoring Program

5 Source: ASA 2013
A-5

Figure A–2. Weeks Sampled from 1985 through 2011 by the Three Hudson River Monitoring Prog1

the Long River Survey (LRS), Fall Shoals Survey (FSS), and Beach Seine Survey (BSS2
Appendix A

A-6

1 This gear change does not affect samples from the shore (BSS) or channel strata (LRS and 

2 FSS), which have consistently been sampled by beach seines and Tucker trawls, respectively, 

3 since the program began. NRC (2010, Appendices H and I) analyzes the effects of the FSS 

4 gear change on abundance estimates for various Hudson River fish species. The present 

5 assessment relies primarily on data from 1985 through 2011.

6 Data on entrainment and impingement survival at IP2 and IP3 come from Entergy (2007). 

7 Impingement was monitored from 1975 through 1990 and entrainment in 1981 and from 

8 1983 through 1987. Fletcher (1990) reports impingement survival estimates that were not 

9 verified after new Ristroph screens were installed at IP2 and IP3 in 1991. The present analysis 

10 uses I&E data from these studies, including impingement survival estimates. Table A–1 

11 summarizes relevant aspects of the monitoring studies used here to assess impacts.

12 Table A–1. Hudson River Monitoring Studies Used To Assess Impacts

Study Study Dates Information Available

Impingement 

Abundance1

1975–1990 Number of fish impinged at IP2 and IP3.

Entrainment 

Abundance1

1981

1983–1987

Entrainment density by species and life stage for IP2 and IP3 

combined.

Longitudinal River 

Ichthyoplankton or 

Long River Survey

(LRS)2

1974–2011 Standing crop, temporal and geographic distributions, and growth 

rates for ichthyoplankton forms of fish species, with an emphasis on 

Atlantic tomcod, American shad, striped bass, white perch, and bay 

anchovy. Sampling generally occurred in spring, summer, and fall.

Fall Juvenile or

Fall Shoals Survey

(FSS)2

1974–2011 Standing crop and temporal and geographic indices for YOY fish in 

shoal, bottom, and channel habitats in the estuary with an emphasis 

on Atlantic tomcod, American shad, striped bass, and white perch. 

Surveys generally conducted in midsummer and fall.

Beach Seine 

Survey

(BSS)2

1974–2011 Abundance and distribution of YOY fish in the shore-zone habitat in 

the estuary, with an emphasis on American shad, Atlantic tomcod, 

striped bass, and white perch. Surveys generally conducted in 

summer and fall.

1 Data provided by Entergy (2007)

2 Data provided by Entergy (2015)

13 Entergy (2014, 2015) provided the annual Hudson River Estuary Monitoring Program Year 

14 Class Reports for 2006 through 2011 (ASA 2008-2013), and the data for this analysis from all 

15 three field surveys (LRS, FSS, and BSS). The three data sets included the utilities’ annual YOY 

16 Abundance Index values for each requested taxon from 1974 through 2011; the weekly total 

17 catch of YOY and yearling and older fish, number of samples, and volume sampled per taxon 

18 and river segment from 1979 through 2011; and the weekly YOY catch density per taxon for 

19 each river segment for the RIS from 1979 through 2011. The weekly volume, total catch, and 

20 catch density were the combined results of each gear type. Some changes to the sampling 

21 intensity and duration occurred for all three sampling programs, including about five levels of 

22 sampling intensity in the LRS and three-to-four levels of sampling intensity in the FSS and BSS.

23 The NRC staff assessed population trends by examining the consistency of multiple measures 

24 of abundance for several sampling programs. Because each sampling program and measure 

25 emphasized a different season or aspect of each population, the NRC staff believes that 

26 examining consistency provides a better understanding of trends than an examination of any 

27 single measure. Population Trends LOE uses multiple measures of abundance to incorporate 
Appendix A

A-7

1 survey information at two geographic scales (River Segment 4 and Riverwide), different 

2 sampling periods (May to July and July to October), different river strata (shore, bottom, shoals, 

3 and surface), and weighting schemes. The LRS, FSS, and BSS all employ a stratified random 

4 design to account for the variability of the timing and location of YOY in the river, and each 

5 sampling program targets a specific time period and specific river strata. The LRS targets fish 

6 from May to July within the same river strata (bottom, shoals, and surface) as the FSS, which 

7 targets fish from July to October. The BSS targets fish along the shoreline from July to October.

8 For data provided by week, the NRC staff used LRS data collected from May through July and 

9 FSS and BSS data collected from July through October between 1985 and 2011 to calculate 

10 annual measures of abundance for trend analysis. Data collected between 1985 and 2011 

11 postdate the mid-1970s when operation began at IP2 and IP3. The YOY populations may have 

12 responded soon after operation began and subsequently restabilized at lower levels before 

13 1985, which argues for using data starting in 1975 as in the FSEIS, but the sampling protocols 

14 from 1985 through 2011 were relatively consistent and did not include the gear change for 

15 bottom and shoal strata in the FSS in 1984–1985, which simplifies the analysis and is used 

16 here.

17 The NRC staff calculated river-segment measures of YOY abundance from the LRS, FSS, and 

18 BSS as the 75th percentiles of the weekly density (provided by Entergy) and weekly catch-per 

19 unit-effort (CPUE; number caught/volume sampled) from 1985 through 2011 (n = 27 annual 

20 observations for each RIS). The BSS River Segment 4 CPUE index was identical to the density 

21 index (both calculated as the number of YOY caught divided by the number of tows) and was 

22 not used in the trend analysis. The NRC staff calculated a Riverwide measure of YOY 

23 abundance of total CPUE (total number caught/total volume sampled) from the LRS, FSS, and 

24 BSS for 1985 through 2011 (n = 27 for each RIS).

25 Entergy provided the utilities’ annual Abundance Index values for the YOY RIS from the LRS, 

26 FSS, and BSS from 1979 through 2011, and ASA (2013) provides index values for 1974 

27 through 1978. The utilities’ riverwide LRS and FSS Abundance Indices weight average river 

28 segment densities by the volumes of the river segments. The construction of the LRS and the 

29 FSS abundance indices is similar and provides unbiased estimates of the total and mean 

30 riverwide population abundance. The indices are constructed as a weighted mean of the 

31 average species densities, with weight given by the volume of each stratum (channel, bottom, 

32 and shoal) for a given river segment. The Poughkeepsie and West Point river segments have 

33 the greatest channel volumes, Poughkeepsie and Tappan Zee have the greatest bottom 

34 volumes, and the Tappan Zee has the greatest shoal volume. Because River Segment 4, 

35 where IP2 and IP3 lie, does not have large bottom or shoal volumes, the utilities’ LRS and FSS 

36 Abundance Indices are not sensitive to changes in population trends near IP2 and IP3 and are 

37 most sensitive to the river segments and strata with greatest volumes. By weighting all regions 

38 equally, the NRC staff’s measures of riverwide abundance are more sensitive to changes in 

39 population trends near IP2 and IP3. Other sources of information on population trends include 

40 the New York State Department of Environmental Conservation’s (NYSDEC’s) indices of 

41 riverwide abundance for YOY striped bass, YOY American shad, and Atlantic tomcod, and

42 National Marine Fishery Service’s (NMFS’s) (2013) biological opinion on the effect of the IP2 

43 and IP3 cooling water intake systems on Atlantic sturgeon and shortnose sturgeon.

44 Representative Important Species (RIS)

45 The NRC staff identified 18 RIS as sentinel species for assessing the impacts of I&E 

46 (Table A–2). This list contains RIS identified in past analyses conducted by the NYSDEC, the 

47 NRC, and the current and past owners of IP2 and IP3. The selected RIS are sentinels for the 

48 overall aquatic resources and reflect the complexity of the Hudson River ecosystem by 
Appendix A

A-8

1 encompassing a broad range of attributes, such as biological importance, commercial or 

2 recreational value, trophic position, commonness or rarity, interaction with other species, 

3 vulnerability to cooling system operation, and fidelity or transience in the local community. The 

4 I&E impact assessment focuses primarily on the potential impacts to YOY and yearling fish and 

5 their prey. Although fish eggs and larvae are important components of the food web, their 

6 natural mortality rates are high (Barnthouse et al. 2008, Secor and Houde 1995), and fish 

7 surviving to YOY and older are more likely to add to the adult breeding population, so that 

8 mortality from the cooling system operation on these life stages more likely affects population 

9 stability.

10 Table A–2. Representative Important Hudson River Aquatic Species

Common 

Name Scientific Name

Occurrence

and Status Predator/Prey Relationships

Alewife Alosa 

pseudoharengus

Anadromous Juveniles eat insect larvae and amphipods; 

adults eat zooplankton, small fish, and fish 

eggs. Species is prey of bluefish, weakfish, 

and striped bass.

Atlantic 

menhaden

Brevoortia 

tyrannus

Permanent or 

seasonal resident

Juveniles and adults eat phytoplankton, 

zooplankton, copepods, and detritus. 

Species is prey of bluefish and striped bass.

American 

shad 

Alosa sapidissima Anadromous Juveniles and adults primarily eat 

zooplankton, small crustaceans, copepods, 

mysids, small fish, and fish eggs. Species 

is prey of oceanic species.

Atlantic 

sturgeon

Acipenser 

oxyrinchus

Anadromous

Protected

Juveniles and adults are bottom feeders, 

subsisting on mussels, worms, shrimp, and 

small fish. 

Atlantic 

tomcod

Microgadus 

tomcod

Anadromous

permanent or 

seasonal resident

Diet includes crustaceans, polychaete 

worms, mollusks, and small fish. Juveniles 

are prey of striped bass when anchovies are 

scarce.

Bay anchovy Anchoa mitchilli Estuarine Species primarily eats zooplankton and is 

prey of YOY bluefish and striped bass.

Blueback 

herring

Alosa aestivalis Anadromous Species’ diet includes insect larvae and 

copepods. It is prey of bluefish, weakfish, 

and striped bass.

Bluefish Pomatomus 

saltatrix

Permanent or 

seasonal resident

Juveniles eat bay anchovy, Atlantic 

silverside, striped bass, blueback herring, 

Atlantic tomcod, and American shad. 

Species is prey of a variety of birds.

Gizzard 

shad

Dorosoma 

cepadianum

Freshwater Juveniles eat daphnids, cladocerans, adult

copepods, rotifers, algae, phytoplankton, 

and detritus; adults eat phyto- and 

zooplankton. Species is prey of striped 

bass, other bass species, and catfish.

Hogchoker Trinectes 

maculates

Estuarine Adults are generalists and eat annelids, 

arthropods, and tellinid siphons. Species is 

prey of striped bass.

Rainbow 

smelt

Osmerus mordax Anadromous Larval and juvenile smelt eat planktonic 

crustaceans; larger juveniles and adults 

feed on crustaceans, polychaetes, and fish. 
Appendix A

A-9

Common 

Name Scientific Name

Occurrence

and Status Predator/Prey Relationships

Adults eat anchovies and alewives. 

Species is prey of striped bass and bluefish.

Shortnose 

sturgeon

Acipenser 

brevirostrum

Federally 

endangered;

permanent or 

seasonal resident

Juveniles feed on benthic insects and 

crustaceans.

Spottail 

shiner

Notropis 

hudsonius

Freshwater Species eats aquatic insect larvae, 

zooplankton, benthic invertebrates, and the 

eggs and larvae of fish, including their own 

species. Species is prey of striped bass.

Striped bass Morone saxatilis Anadromous Species eats menhaden river herring, 

tomcod, and smelt. Larvae are prey of 

spottail shiner, white perch, striped bass, 

bluegill, and white catfish.

Weakfish Cynoscion regalis Permanent or 

seasonal resident

Small weakfish feed primarily on 

crustaceans, while larger weakfish feed 

primarily on anchovies, herrings, spot. 

Species is prey of bluefish, striped bass, 

and other weakfish.

White catfish Ameiurus catus Freshwater Juveniles eat midge larvae. Adults are 

omnivores, feeding on anything from fish to 

insects to crustaceans.

White perch Morone americana Estuarine Species eat eggs of other fish and larvae of 

walleye and striped bass. Prey of larger 

piscivorous fish and terrestrial aquatic 

vertebrates.

Blue Crab Callinectes 

sapidus

Estuarine Zoea eat phytoplankton, and dinoflagellates; 

adults opportunistic. Larval crabs are the 

prey of fish, shellfish, jellyfish; juvenile and 

adult blue crabs are prey of a wide variety of 

fish, birds, and mammals.

1 Population Trend LOE

2 The Population Trend LOE uses data from the LRS, FSS, and BSS and the utilities’ Abundance 

3 Index to address the stability of the populations. Population trends were calculated on two 

4 geographic scales. A measure of local effects examines trends from 1985 through 2011 within 

5 only River Segment 4 (the Indian Point segment). The River Segment 4 data are the weekly 

6 LRS and FSS CPUE (YOY catch divided by the volume sampled) and LRS, FSS, and BSS 

7 catch density provided by Entergy. The Riverwide data are the utilities’ Abundance Index (1974 

8 through 2011) and the LRS, FSS, and BSS CPUE calculated as the annual sum of the weekly 

9 catch over all river segments divided by the total volume (or total number of tows for the BSS) 

10 sampled. This results in several measures of abundance and trend analyses at both the River 

11 Segment 4 and Riverwide (all river regions) scales for each RIS.

12 The annual River Segment 4 estimate of the population response is the 75th percentile of the 

13 weekly data for a given year, because it was not as sensitive as the mean to the few large 

14 observations collected each year (Sunitha et al. 2014), and a percentile provides a better 

15 measure of central tendency, given the highly skewed data. The NRC staff chose the 

16 75th percentile rather than the median because, on average, 52 and 65 percent of the weekly 
Appendix A

A-10

1 FSS and BSS catches were zero for the RIS. A measure of riverwide effects is based on 

2 population trends in all river segments of the 1985 through 2011 annual CPUE and on the 

3 1974 through 2011 annual abundance index values provided by Entergy. For several of the 

4 RIS, Entergy provided annual abundance index values from multiple surveys, of which the NRC 

5 staff used only the one with the greatest median CPUE over years (Table A–3).

6 The NRC staff standardized the annual measure of abundance values by subtracting the mean 

7 and dividing by the standard deviation among years to allow comparisons of the shape of the 

8 data over time among surveys and RIS. Because of the large variability in the density measure 

9 of abundance between years (coefficients of variation (CVs) ranging from 54 to 298 percent), 

10 the NRC staff used a 3-year moving average to smooth the river-segment standardized annual 

11 density index before the trend analysis.

12 Table A–3. Comparison of Riverwide Median Young-of-Year (YOY) Catch-per-Unit-Effort 

13 (CPUE) Among Hudson River Estuary Monitoring Surveys, 1985-2011

RIS

Data used for YOY 

and Yearling 

Abundance Index in 

Year Class Reports

FSS

(no./1000 m3)

LRS

(no./1000 m3)

BSS(b)

(no./1000 m3)

Survey With

Greatest 

CPUE

Alewife FSS-Channel 0.356 1.166 2.753 BSS

American 

shad

BSS 0.466 0.583 15.378 BSS

Atlantic 

tomcod

LRS 1.771 23.107 0.026 LRS

Bay anchovy FSS-Channel 24.467 24.128 15.420 FSS

Blueback 

herring

FSS-Channel 8.723 4.245 71.840 BSS

Bluefish BSS 0.026 0.072 0.679 BSS

Hogchoker FSS-Bottom 0.525 0.033 0.064 FSS

Rainbow 

smelt(a)

FSS-Channel 0.119 1.217 0.000 LRS

Spottail 

shiner

FSS-Channel 0.021 0.003 11.925 BSS

Striped bass BSS 2.203 1.444 15.425 BSS

Weakfish FSS-Channel 1.096 0.745 0.011 FSS

White catfish BSS 0.097 0.006 0.002 FSS

White perch BSS 0.866 0.149 9.736 BSS

(a) Using years 1985 through 1998 (last observation for FSS)

(b) Volume sampled for the BSS is calculated assuming each tow has a volume of 450 m3

14 The NRC staff fit a simple linear regression of each annual measure of abundance (y) against 

15 time for each RIS using GraphPad Prism Version 4.0, 2003. The form of the regression model 

16 is y = a + Sx, where x is the year, a is the intercept, and S is the slope of the line. Regressions 

17 were fit with and without extreme values greater than 3 standard deviations from the mean. A 

18 two-sided t-test of the null hypothesis, H0: S = 0 (α = 0.05), was used to determine if the trend 
Appendix A

A-11

1 was detectible, and the direction of the estimated slope was used to assess the population trend 

2 (increasing or decreasing).

3 Strength of connection LOE

4 The SOC LOE represents the ability of I&E at the IP2 and IP3 cooling water intake structures to 

5 produce noticeable changes in population trends in the RIS. The SOC uses I&E monitoring 

6 data for RIS at IP2 and IP3 from 1975 through 1990. Impingement and/or entrainment can also 

7 remove RIS prey and reintroduce them as detritus or injured organisms into the aquatic system. 

8 This process may alter food web dynamics and produce indirect effects such as decreased 

9 recruitment, changes in predator-prey relationships, changes in population feeding strategies, or 

10 movements of populations closer to or farther away from the cooling system structure. The 

11 SOC uses an estimate of uncertainty provided by a Monte Carlo simulation that examines the 

12 differences in population trends with and without losses of YOY fish by I&E.

13 The analysis used the information from two types of samples: I&E data from 1975 through 1990 

14 and long-term River Segment 4 population density data from 1985 through 2011 from the LRS, 

15 FSS, and BSS. The NRC staff determined the SOC from the uncertainty in estimating the 

16 difference in the RIS YOY population abundance with and without losses from I&E. A series of 

17 Monte Carlo simulations (n = 1000 for each series) was used to estimate the first and third 

18 quartiles of the modeled relative cumulative difference in the population abundance achieved 

19 over a specified number of years (i.e., t = 1 to 27) with and without removal of eggs, larvae, and 

20 juveniles by I&E. The NRC staff used a simple exponential model to estimate the annual 

21 juvenile population abundance (Nt) as follows:

NNtt = NN0eerr + (δδNN0eerr )εεtt 22 (1)

23 where

24 t = 1 to 20 (number of years associated with relicensing) or 27 years (number of years for trend 

25 analysis: 1985 through 2011);

26 N0 = the initial juvenile population abundance at the beginning of the YOY life stage set to either 

1000 or 1x108 27 ;

28 r = the population growth rate estimated from the slope from the linear model of standardized 

29 YOY River Segment 4 (Indian Point) LRS, FSS, or BSS density data (1985 through 2011), 

30 whichever had the greatest riverwide median CPUE for a given RIS (Table A–3);

31 δ = the level of variability in the density data which was estimated as the sum of the CV of the 

32 annual 75th percentiles from the weekly catch density and the error mean square from the linear 

33 regression; and

34 εt = an independent Normal (0,1) random variable.

35 Two different values for the starting population parameter N0 and the extent of the number of 

36 years simulated (20 or 27) were used to assess their impact on the simulation results. The 

37 number of simulation runs (1,000) should be large enough such that these two parameters will 

38 not affect the results. Equation (1) models annual abundance of YOY RIS with the removal of 

39 eggs, larvae, and juveniles from entrainment and impingement implicit in the parameters N0

40 and r. Annual abundance of YOY RIS without losses of eggs, larvae, and juveniles from 

41 entrainment and impingement was estimated using the same model form but with an 

42 independent εt ,and N0 and r replaced with

NN0

∗ = NN0(1 + EEEEEE) and rr∗ = rrUL 43 (1 − II )/max(1,CV) (2)

44 where
Appendix A

A-12

1 EMR [entrainment mortality rate] and IMR [impingement mortality rate] are conditional mortality 

2 rates (CMRs) for entrainment and impingement;

3 rUL is the upper limit of the linear slope defined as the estimated slope plus one standard error of 

4 the estimated slope; and

5 CV is the coefficient of variation of the annual 75th percentiles from the weekly catch density.

6 The growth rate divided by the CV in the density data provides an alternative growth rate closer 

7 to zero for negative values of r and a slightly larger growth rate for positive values of r with the 

8 amount of increase dependent on the magnitude of the variability. The divisor is set to 1 

9 (allowing a maximum increase in growth rate) when the CV is greater than 1. The parameter 

10 EMR for each RIS is estimated from entrainment and River Segment 4 field data supplied by 

11 Entergy (2007). The parameter IMR for each RIS is estimated from published conditional 

12 impingement mortality rates (CIMRs) (CHGEC 1999). Estimates for EMR assume 100 percent 

13 mortality, and the IMR incorporates impingement survival rates.

14 The NRC staff estimated EMR as the ratio of the number entrained to the sum of the standing 

15 crop of eggs, larvae, and juveniles in River Segment 4 (Indian Point) obtained from the LRS, 

16 FSS, and BSS 1981 and 1983 through1987 data. The NRC staff used all three surveys,

17 because entrainment of juveniles was proportionally greater during July and August than during 

18 May and June, which was when the majority of the sampling for the LRS took place 

19 (Table A–4). Estimation of the number entrained and the river segment standing crop is based

20 on the calculations presented in Table A–5.

21 Table A–4. Percentage of Each Life Stage Entrained by Season and the Contribution of 

22 Major Taxa Represented in the Samples

Life Stage

Season 1

Jan.–

March

Season 2

April–

June

Season 3

July–

Sept.

75th Percentile of 

Abundance over Yearsa

EGG 3% 20% 78% 210,801 x 103

Rainbow Smelt 99% 2% 0%

Bay Anchovy 0% 92% 100%

White Perch 0% 4% < 1%

Alosa species 1% 2% 0%

YOLK-SAC LARVA 8% 89% 3% 23,140 x 103

Atlantic Tomcod 100% 0% 0%

Herring Family 0% 91% < 1%

Bay Anchovy 0% 2% 94%

Striped Bass 0% 5% 1%

Hogchoker 0% 0% 3%

POST YOLK-SAC LARVA < 1% 52% 48% 618,393 x 103

Atlantic Tomcod 100% < 1% 0%

Alosa species 0% 37% < 1%

Bay Anchovy 0% 11% 58%

Anchovy Family 0% 2% 39%

White Perch 0% 12% 1%
Appendix A

A-13

Life Stage

Season 1

Jan.–

March

Season 2

April–

June

Season 3

July–

Sept.

75th Percentile of 

Abundance over Yearsa

Striped Bass 0% 17% 1%

Herring Family 0% 20% < 1%

JUVENILE 2% 44% 54% 10,989 x 103

White Perch 96% 10% 10%

Atlantic Tomcod 0% 67% 2%

Weakfish 0% 1% 50%

Bay Anchovy 0% 1% 17%

Rainbow Smelt 0% 9% 3%

Striped Bass 0% 6% 5%

Anchovy Family 0% 1% 4%

Alosa species 0% 2% 2%

White Catfish 4% < 1% 0%

Blueback Herring 0% < 1% 3%

UNDETERMINED STAGE 10% 77% 13% 4,469 x 103

Atlantic Tomcod 100% < 1% 0%

Morone species 0% 88% 2%

Bay Anchovy 0% 9% 83%

Anchovy Family 0% 0% 10%

Alosa species 0% 0% 4%

a Calculations are based on the 75th percentile of number of fish entrained in each season over years (1981 and 

1983 through 1987). No entrainment sampling occurred in October through December.

1 Table A–5. Method for Estimating Taxon-Specific Entrainment Mortality Rate (EMR) 

2 Based on River Segment 4 Standing Crop for the Strength-of-Connection Analysis

Property or Method Number Entrained River Segment 4 Standing Crop

Input 

Data

Variables Mean density organisms 

entrained by IP2 and IP3 

(number per 1000 m3)

LRS density (by life stage)

FSS density of YOY

(number per 1000 m3)

BSS density of YOY

(# per haul)

Volume of cooling water 

withdrawn by IP2 and IP3

(1000 m3/min)

River Segment 4 volume (m3)

River Segment 4 shore zone 

surface area (m2)

Frequency Per week of sampling Per week of sampling

Summary 

Statistics

Season by year Sum of weekly estimates of 

number of organisms entrained 

by IP2 and IP3

Sum of weekly standing crop 

estimates
Appendix A

A-14

Property or Method Number Entrained River Segment 4 Standing Crop

Annual Sum of Season 1, 1986, with

each year’s totals from Season 2 

and Season 3

Sum of seasonal standing crop 

estimates for River Segment 4

EMR 75th percentile annual number entrained

75th percentile (annual number entrained + annual standing crop)

Units of numerator 

and denominator of 

EMR

number of organisms

Years of Data 1981 and 1983–1987 1981 and 1983–1987

Life Stages Eggs, larvae, and juveniles Eggs, larvae, and juveniles (YOY)

Taxonomic Substitutions Alewife, blueback herring, and unidentified alosids are treated 

collectively as river herring

“Unidentified anchovy spp.” are allocated to bay anchovy

“Unidentified Morone spp.” are allocated proportionally to the 

identified striped bass and white perch in entrainment samples.

1 The number of RIS by life stage (I = eggs, yolk sac larvae, post-yolk sac larvae, juvenile, and 

2 undetermined) entrained (Eijk) was calculated weekly (k = 2 through 35) for each year (j = 1981, 

3 1983 through1987) as

Eijk = dıȷk ����� 4 (VIP2 + VIP3)(60 × 24 × 7 × 1000) (3)

where ddıııııı ����� is the input mean weekly density entrained (number/1000 m3 5 ) for a given RIS 

(Table A–5) along with the associated volume of water withdrawn (1000 m3 6 /min) at IP2 and IP3 

7 (VIP2 and VIP3, respectively). The NRC staff calculated seasonal numbers of RIS entrained by 

8 summing over life stages and weeks. Season 1 (January–March) was only sampled in 1986, so 

9 that the number of fish entrained during that season was added to the totals for all other years.

10 The NRC staff based the estimate of the River Segment 4 standing crop of each life stage on 

11 the combined standing crop estimates from the LRS, FSS, and BSS (Table A–5). The LRS and 

12 FSS weekly standing crops are estimated as the weekly density of fish caught times the River 

Segment 4 volume (208,336,266 m3 13 ; 168,901 acre-ft). The BSS weekly standing crop was 

14 estimated as the weekly density of fish caught times the River Segment 4 surface area of the 

shore stratum (4,147,000 m2

; 1,025 acres) divided by the area of a seine sample (450 m2 15 ; 

4,844 ft2 16 ). The total number of RIS at risk from I&E was calculated as the sum of those RIS 

17 entrained (or impinged) and the RIS caught in the river. The annual standing crops of eggs, 

18 larvae, and juveniles estimated in River Segment 4 from the LRS, FSS, and BSS are presented 

19 in Table A–6. The estimated number of each RIS entrained for the SOC analysis is calculated 

20 from the mean density entrained (1981 and 1983 through 1987) at IP2 and IP3 (Table A–7). 

21 The estimated EMR values can be compared to the Riverwide CMRs from CHGEC (1999) 

22 (Table A–8).

23 Table A–6. Estimated Annual Standing Crop of Eggs, Larvae, and Juvenile RIS within 

24 River Segment 4 (thousands of fish)

Taxon 1981 1983 1984 1985 1986 1987

Alewife and 

Blueback Herring

297,085 1,357,925 1,038,835 78,631 354,051 25,296

American Shad 10,499 2,913 95,680 2,544 4,237 1,193
Appendix A

A-15

Taxon 1981 1983 1984 1985 1986 1987

Atlantic Menhaden Unknown Unknown Unknown Unknown Unknown Unknown

Atlantic Sturgeon Unknown Unknown Unknown Unknown Unknown Unknown

Atlantic Tomcod 200,780 25,139 135,175 401,977 151,137 207,732

Bay Anchovy 2,075,519 1,139,353 1,190,840 1,545,767 497,221 1,886,658

Bluefish 540 1,208 883 391 536 1,394

Gizzard Shad Unknown Unknown Unknown Unknown Unknown 24.1

Hogchoker 1,897 587 1,063 1,135 3,529 6,399

Rainbow Smelt 1,341 841 16,111 992 46,771 21,926

Shortnose Sturgeon Unknown Unknown Unknown Unknown Unknown Unknown

Spottail Shiner 29.7 103 16.1 235 38.7 16.6

Striped Bass 1,336,839 626,169 628,247 79,970 406,016 292,179

Weakfish 1,473 3,547 15,306 3,495 1,245 985

White Catfish Unknown 1.84 27.3 215 Unknown 31.9

White Perch 796,095 913,925 438,271 92,322 758,591 69,237

1 Table A–7. Annual Estimated Number of RIS Entrained at IP2 and IP3

2 (thousands of fish)

Taxa 1981 1983 1984 1985 1986 1987

Alewife and 

Blueback Herring

20,159 119,801 181,006 954 186 44.6

American Shad 350 359 18,175 26.0 242 9.27

Atlantic Menhaden 0 0 0 0 0 0

Atlantic Sturgeon 0 0 0 0 0 0

Atlantic Tomcod 4,231 2,951 8,557 12,737 4,925 3,714

Bay Anchovy 1,241,061 352,177 467,558 344,483 182,493 236,713

Bluefish 0 0 3.88 19.7 0 0

Gizzard Shad 0 0 0 0 0 0

Hogchoker 3,188 2,168 961 745 585 185

Rainbow Smelt 6,089 6,090 7,146 6,126 10,952 6,857

Shortnose Sturgeon 0 0 0 0 0 0

Spottail Shiner 0 9.13 3.93 0 0 0

Striped Bass 85,626 43,256 49,716 20,495 78,666 33,076

Weakfish 3,130 4,154 9,485 2,062 631 102

White Catfish 7.23 7.23 10.8 7.23 10.5 7.23

White Perch 48,743 68,418 29,734 11,137 71,501 8,297

All fish taxa 1,446,376 795,342 888,363 403,092 463,644 288,208
Appendix A

A-16

1 Table A–8. Estimate of the River Segment 4 Entrainment Mortality Rate (EMR) and the 

2 95 Percent Confidence Limits for the Riverwide Entrainment CMR (1974–1997)

Taxa

75th Percentile 

Annual Number 

Entrained 

(number x 106)

75th Percentile

of Number at 

Risk 

(number x 106) EMR

Riverwide CMR 

for Entrainment

at IP2 and IP3

Lower 95%

Confidence 

Limit

Upper 95%

Confidence 

Limit

Alewife and Blueback 

Herring

94.9 1003 0.095 0.00747 0.0324

American Shad 0.357 9.26 0.039 0 0.016696

Atlantic Menhaden 0 NA NA Not Modeled

Atlantic Sturgeon 0 NA NA Not Modeled

Atlantic Tomcod 7.65 210 0.036 0.152 0.234

Bay Anchovy 439 2065 0.212 0.0925 0.140

Bluefish 0.00291 1.13 0.003 Not Modeled

Gizzard Shad 0 NA NA Not Modeled

Hogchoker 1.87 4.84 0.385 Not Modeled

Rainbow Smelt 7.07 27.4 0.258 Not Modeled

Shortnose Sturgeon 0 NA NA Not Modeled

Spottail Shiner 0.00295 0.0937 0.031 0.0802 0.104

Striped Bass 71.4 676 0.106 0.181 0.276

Weakfish 3.90 7.17 0.544 Not Modeled

White Catfish 0.00965 0.0848 0.114 Not Modeled

White Perch 63.5 841 0.075 0.0568 0.108

3 Impingement mortality for YOY RIS is greatest in July through December, Table A–9; although 

4 impingement data from 1981 through 1990 were not available by life stage, the NRC staff 

5 estimated IMR as the maximum cumulativeCIMR (1984 through1990; CHGEC 1999) for an 

6 annual cohort from the juvenile life stage through the last age of impingement vulnerability 

7 (Table A–10). The minimum value of IMR was set at 0.0005. The CIMR values are calculated 

8 from the estimated number impinged and the Ristroph screen 8-hour mortality rate reported by 

9 Fletcher (1990).

10 The relative cumulative difference in the population abundance achieved over a specified 

11 number of years between models with and without the effects of entrainment and impingement 

is estimated as the sum of the annual differences divided by N0 (1000 or 108 12 ) and the number of 

13 years of data (20 or 27). One realization of a simulation using t = 27, N0 = 1000 highlights the 

14 annual difference achieved in the YOY population abundance with and without entrainment and 

15 impingement effects (Figure A–3). An example frequency distribution of the relative cumulative 

16 difference in the population abundance achieved from all 1,000 simulations is presented in 

17 Figure A–4. Negative values occur when a single simulation has greater negative annual 

18 differences (i.e., greater abundance with the model incorporating entrainment and impingement 

19 mortality, shown in black in Figure A–3). If the model included no variation (δ = 0), all 

20 differences would be positive. Allowing δ to be greater than 0 incorporates the variation 
Appendix A

A-17

1 observed in the YOY population and the error in the linear model used to estimate population 

2 growth. If the range of the first and third quartiles of the resulting distribution includes zero, the 

3 effect of entrainment and impingement was not large enough to detect over the variation 

4 observed in the population.

5 Four simulation series for each RIS incorporated all possible pairs of the parameters t and N0 

6 (n = 1000 for each) and all other model parameter values for a given RIS remained the same for 

7 each simulation series. The SOC was low if the range of the first and third quartiles of the 

8 distribution of the relative cumulative difference in YOY population abundance included zero for 

9 any of the simulation series. The SOC was high if both quartiles were positive for all parameter 

10 t and N0 pairs. The latter result occurs when the effects of entrainment and impingement are 

11 consistently greater than the modeled variation.

12 Table A–9. Percentage of Each Life Stage Impinged by Season and the Contribution of 

13 Major Taxa Represented in the Samples

Life Stage

Season 1

Jan–Mar

Season 2

Apr–Jun

Season 3

Jul–Sep

Season 4

Oct–Dec

75th Percentile 

over Years

Young-of-Year 0% 9% 43% 48% 3,214 x 103

Atlantic Tomcod 0% 98% 60% 1%

White Perch 0% 0% 16% 72%

American Shad 0% 0% 6% 1%

Blueback Herring 0% 0% 3% 24%

Weakfish 0% 0% 5% < 1%

Yearling 82% 17% 1% 1% 3,747 x 103

White Perch 95% 94% 60% 93%

Striped Bass 4% 1% 5% 1%

Atlantic Tomcod 1% < 1% 14% 1%

Alewife < 1% < 1% 12% 1%

Blueback Herring < 1% 1% 9% 3%

Older 19% 19% 53% 9% 1,320 x 103

White Perch 83% 41% 3% 5%

Bay Anchovy < 1% 15% 85% 40%

Rainbow Smelt 10% 18% 1% 12%

Hogchoker < 1% 20% 6% 16%

Alosa species < 1% < 1% < 1% 16%

a Note: because only 2 years had life stage information available (1979 and 1980), calculation of the 

75th percentile was based on the weighted average of the ranked observations, i.e., y = 0.25*X(1) + 0.75*X(2) 

where X(i) is the ranked observation in increasing order.
Appendix A

A-18

1 Table A–10. Cumulative Conditional Impingement Mortality Rate Estimated by Year 

Class for Indian Point1 Used to Estimate the Taxon-Specific Impingement Mortality Rate2 2

3 (IMR) for the Strength of Connection Analysis

RIS 1984 1985 1986 1987 1988 1989 1990

Maximum

= IMR

Alewife NA 0.002 0.002 0.001 0.001 0.001 NA 0.002

American Shad NA < 0.0005 < 0.0005 < 0.0005 < 0.0005 < 0.0005 < 0.0005 0.0005

Atlantic Tomcod NA NA 0.008 0.030 0.005 0.003 0.004 0.030

Bay Anchovy NA 0.002 0.004 < 0.0005 < 0.0005 < 0.0005 < 0.0005 0.004

Blueback Herring NA 0.003 0.004 0.002 0.001 0.001 NA 0.004

Bluefish NA NA NA NA NA NA NA 0.0005

Hogchoker NA NA NA NA NA NA NA 0.0005

Rainbow Smelt NA NA NA NA NA NA NA 0.0005

Spottail Shiner NA 0.002 0.001 0.007 < 0.0005 0.001 < 0.0005 0.007

Striped Bass 0.008 0.003 0.005 0.005 < 0.0005 < 0.0005 0.001 0.008

Weakfish NA NA NA NA NA NA NA 0.0005

White Catfish NA NA NA NA NA NA NA 0.0005

White Perch NA 0.026 0.032 0.012 0.011 0.014 0.007 0.032

1 CHGEC (1999) Appendix VI

2 IMR estimates include a correction for partial survival

NA = Not available
Appendix A

A-19

1 Figure A–3. One Realization of the Monte Carlo

2 Simulation Using Parameter Estimates for White Perch

3 Gray and black shading represents positive and negative annual differences in abundance 

4 between the two models.

5 Figure A–4. Example Frequency Distribution of the Relative Difference in Cumulative 

6 Abundance from the Monte Carlo Simulation (n = 1000). Dashed lines indicate the first 

7 and third quartiles (Q1 and Q3) of the distribution

0

50

100

150

200

250

300

350

-0.6 -0.4 -0.2 0 0.2 0.4 0.6 0.8

Frequency

Q1 Q3

Relative Difference in Cumulative Abundance

Frequency of Occurrence
Appendix A

A-20

1 Weight of Evidence

2 To classify impacts as small, moderate, or large, a WOE approach combined the results of two 

3 LOEs using both numerical scoring and decision rules. For the population trend LOE, the NRC 

4 staff used a simple linear regression of annual population measurements over years to assign 

5 the level of adverse impact. The statistical significance of the estimated slope (α = .05) 

6 determines if a population trend is detectable. For each population trend, the number of data 

7 sets and measures of abundance available for each RIS and geographic scale (River 

8 Segment 4, which includes IP2 and IP3, and Riverwide) varies. The following decision rules 

9 score the two possible outcomes for each trend (i.e., a statistically significant decreasing trend 

10 or not):

11 • RIS populations are not declining if population trends had slopes that are significantly 

12 greater than or not significantly different from zero (i.e., detectible population 

13 increase or an undetectable population trend). Trends satisfying this description 

14 receive a score of 1.

15 • RIS populations are declining if population trends had negative slopes that are 

16 significantly different from zero (i.e., detectible population decline). Trends satisfying 

17 this description receive a score of 4.

18 A value of 4 represents declining trends, because it allows scaled intermediate scores when 

19 combining the results of multiple measures of abundance within each geographic scale. Each 

20 measure of abundance set within a geographic scale was considered equally relevant, and the 

21 population trend scores were then averaged, which can produce intermediate scores between 1 

22 and 4. The NRC staff gauged the consistency of results by using trends from multiple River 

23 Segment 4 and Riverwide data sets.

24 River segment and riverwide scores were then combined using attributes intended to reflect 

25 their use and utility for measuring total impact using methods adapted from Menzie et al. (1996). 

26 Each attribute was assigned an ordinal score corresponding to a ranking of low (1), medium (2), 

27 or high (3) based on the best professional judgment of three investigators (Table A–11), and 

28 overall use and utility scores are the averages of the individual attribute scores. The overall 

29 scores characterize the overall use and utility of the measurement as low, medium, or high, 

30 using the following definitions:

31 • Low use and utility—overall score of <1.5 (questionable for decisionmaking);

32 • Medium use and utility—overall score of ≥1.5 and ≤2 (adequate for decisionmaking); 

33 and

34 • High use and utility—overall score of >2 (very useful for decisionmaking).

35 Table A–11. Use and Utility Attributes and Scores Used To Evaluate RIS Population 

36 Trends Associated with IP2 and IP3 Cooling System Operation

Use and Utility Attribute

River Segment 4 

RIS Trends

Riverwide RIS 

Trends

Strength of Association between Measurement and Community 

Response

3 2

Stressor-specificity 2 1

Site-Specificity of Measurement in Relation to the Stressor 2 1

Sensitivity (Variability) of Measurement 2 2

Spatial Representativeness 3 2
Appendix A

A-21

Use and Utility Attribute

River Segment 4 

RIS Trends

Riverwide RIS 

Trends

Temporal Representativeness 3 3

Correlation of Stressor to Response 2 1

Overall (Mean) Utility Score 2.4 1.7

Overall Assessment(a) High Medium

(a) Overall Assessment: Scores <1.5 are of low utility (questionable use for decisionmaking); 1.5 ≤ scores ≤ 2.0 are 

of medium utility (adequate for decisionmaking); scores >2.0 are of high utility (very useful for decisionmaking).

1 Using the decision rules above, a total impact score is calculated from the impact scores at the 

2 two geographic scales by using a weighted mean across geographic scales: 

 overall utility score

(overall utility score )(decision rule result score )

WOEScore ∑

∑

=

i

i

i

i

i

3 ,

where i = 1 to the number of measurements; the overall utility score i 4 is defined in Table A–11; 

and the result score i 5 equals the average of 1s and 4s defined in Step 4 following decision rules

6 that characterize each trend. From the WOE scores, three impact levels are characterized as 

7 follows:

8 • Small impact: WOE score < 2.2

9 • Moderate impact: WOE score ≥ 2.2 and ≤ 2.8

10 • Large impact: WOE score > 2.8

11 The NRC staff defined boundary values between impact categories based on the possible 

12 outcomes for each geographic scale. WOE scores of less than 2.2 occurred when population 

13 trend data produced more result scores of 1 than of 4. WOE scores greater than 2.8 occurred 

14 when population trend data produced more result scores of 4 than of 1.

15 For the SOC LOE associating IP2 and IP3 cooling system operation to the observability of RIS 

16 population declines, all of the RIS appeared in either the impingement or the entrainment 

17 samples, and so the connections or pathways to the population abundance from the operation 

18 of the cooling systems has been established. This LOE uses decision rules to qualify the 

19 influence of impingement and entrainment on any observed population declines. The 

20 qualification depends on the ability of a simple exponential model to approximate RIS population 

21 trends through time and to estimate a biologically relevant measure of uncertainty associated 

22 with the cause of decline in RIS populations in the Hudson River. The NRC staff conducted 

23 simulation runs with different model parameter values to provide a greater sense of the 

24 separation between conclusions on the SOC and specific model assumptions.

25 Based on two possible outcomes in SOC (i.e., noise in the data either precludes differentiating 

26 the effect of I&E on the population trend or not), the following decision rules characterize the 

27 SOC:

28 • The RIS had a Low SOC if the interval between the first and third quartiles of the 

29 difference in modeled cumulative abundance for a given YOY RIS with and without 

30 mortality from entrainment, impingement, and loss of prey included zero for at least 
Appendix A

A-22

1 one of the simulation runs. That is, the variability in the species population trend was 

2 too large to enable the detection of losses from entrainment and impingement, and a 

3 high level of uncertainty is associated with the link between the population trend and 

4 the direct and indirect effects of the operation of IP2 and IP3 cooling systems.

5 • The RIS had a High SOC if the interval between the first and third quartiles of the 

6 difference in modeled cumulative abundance for a given YOY RIS with and without 

7 mortality from entrainment, impingement, and loss of prey did not include zero for 

8 any of the simulation runs. That is, the effects of entrainment and impingement were 

9 greater than the variability in the population trend, and the direct and indirect effects 

10 of the operation of IP2 and IP3 cooling systems affected species population trends.

11 A.3 Results

12 Trend Analysis

13 Consistency of trends can be examined across species on the River Segment 4 and Riverwide 

14 scale or across sampling programs and geographic scales within species without regard to the 

15 statistical significance of slopes. Plots of YOY population density and CPUE trends from the 

16 LRS and FSS programs in River Segment 4 (Addendum A–1, Figures A1 through E1) appear 

17 consistent: populations have been decreasing with few exceptions. Plots show decreasing 

18 trends for all species measured by LRS density and FSS density, all species except bay 

19 anchovy measured by FSS CPUE, and all species except striped bass and weakfish measured 

20 by LRS CPUE. BSS density trends vary more, with five populations appearing to decrease and 

21 four appearing to increase. In River Segment 4 (Addendum A–1, Figures F1 through K1), plots 

22 show consistent decreases for American shad, Atlantic tomcod, and rainbow smelt. Plots show 

23 either flat or decreasing trends for blueback herring, bluefish, weakfish, white catfish, and white 

24 perch. Alewife have an increasing trend for all riverwide measures of abundance. Spottail 

25 shiner and striped bass had mixed results in riverwide population measures. Overall, a 

26 consistent pattern of decreasing trends in YOY fish abundance occurs in River Region 4, where 

27 IP2 and IP3 are located, but a more varied pattern occurs, still with many decreases, riverwide. 

28 For population trends across sampling programs within River Segment 4 and Riverwide scales, 

29 declines within both geographic scales are statistically significant (p ≤ 0.05) for American shad 

30 (Figure A–5), Atlantic tomcod (Figure A–6), blueback herring (Figure A–7), and rainbow smelt 

31 (Figure A–8) for all or most sampling programs.
Appendix A

A-23

1 Figure A–5. Estimated Linear Slopes and Confidence Intervals (Blue Bars with Error 

2 Bars) and the P-Values for the Test of Zero Slope (Red Thick Circles) for Each American 

3 Shad Population Measure of Abundance

4 Figure A–6. Estimated Linear Slopes and Confidence Intervals (Blue Bars with Error 

5 Bars) and the P-Values for the Test of Zero Slope (Red Thick Circles) for Each Atlantic 

6 Tomcod Population Measure of Abundance

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

-0.14

-0.12

-0.10

-0.08

-0.06

-0.04

-0.02

0.00

LRS DensityFSS Density

BSS Density

LRS CPUEFSS CPUELRS CPUEFSS CPUE

BSS CPUE

BSS Abundance Index

River Segment 4 Riverwide

Level of Significance for H0: Slope = 0

Slope 

± 2* Standard Error of Slope

Slope p-value

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

-0.12

-0.10

-0.08

-0.06

-0.04

-0.02

0.00

0.02

LRS DensityFSS Density

BSS Density

LRS CPUEFSS CPUELRS CPUEFSS CPUE

BSS CPUE

LRS Abundance Index

River Segment 4 Riverwide

Level of Significance for H0: Slope = 0

Slope 

± 2* Standard Error of Slope

Slope p-value
Appendix A

A-24

1 Figure A–7. Estimated Linear Slopes and Confidence Intervals (Blue Bars with Error 

2 Bars) and the P-Values for the Test of Zero Slope (Red Thick Circles) for Each Blueback 

3 Herring Population Measure of Abundance

4 Figure A–8. Estimated Linear Slopes and Confidence Intervals (Blue Bars with Error 

5 Bars) and the P-Values for the Test of Zero Slope (Red Thick Circles) for Each Rainbow 

6 Smelt Population Measure of Abundance

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

-0.12

-0.10

-0.08

-0.06

-0.04

-0.02

0.00

0.02

0.04

0.06

LRS DensityFSS Density

BSS Density

LRS CPUEFSS CPUELRS CPUEFSS CPUE

BSS CPUE

BSS Abundance Index

River Segment 4 Riverwide

Level of Significance for H0: Slope = 0

Slope 

± 2* Standard Error of Slope

Slope p-value

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

-0.12

-0.10

-0.08

-0.06

-0.04

-0.02

0.00

LRS DensityFSS Density

BSS Density

LRS CPUEFSS CPUELRS CPUEFSS CPUE

BSS CPUE

LRS Abundance Index

River Segment 4 Riverwide

Level of Significance for H0: Slope = 0

Slope 

± 2* Standard Error of Slope

Slope p-value
Appendix A

A-25

1 Less consistency of trend results among measures of abundance and geographic scales occurs 

2 for bluefish, hogchoker, striped bass, and white catfish. For bluefish (Figure A–9), three of the 

3 five negative slopes in River Segment 4 are significant and two are not, while riverwide results 

4 are more mixed. Hogchoker (Figure A–10) and striped bass (Figure A–11) trends are 

5 inconsistent among measures of abundance within both River Segment 4 and Riverwide scales. 

6 Only riverwide sampling provided enough catches for trend analyses of white catfish 

7 (Figure A–12), and the results are inconsistent.

8 Figure A–9. Estimated Linear Slopes and Confidence Intervals (Blue Bars with Error 

9 Bars) and the P-Values for the Test of Zero Slope (Red Thick Circles) for Each Bluefish 

10 Population Measure of Abundance

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

-0.12

-0.10

-0.08

-0.06

-0.04

-0.02

0.00

0.02

0.04

LRS DensityFSS Density

BSS Density

LRS CPUEFSS CPUELRS CPUEFSS CPUE

BSS CPUE

BSS Abundance Index

River Segment 4 Riverwide

Level of Significance for H0: Slope = 0

Slope 

± 2* Standard Error of Slope

Slope p-value
Appendix A

A-26

1 Figure A–10. Estimated Linear Slopes and Confidence Intervals (Blue Bars with Error 

2 Bars) and the P-Values for the Test of Zero Slope (Red Thick Circles) for Each Hogchoker 

3 Population Measure of Abundance

4 Figure A–11. Estimated Linear Slopes and Confidence Intervals (Blue Bars with Error 

5 Bars) and the P-Values for the Test of Zero Slope (Red Thick Circles) for Each Striped 

6 Bass Population Measure of Abundance

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

-0.12

-0.10

-0.08

-0.06

-0.04

-0.02

0.00

0.02

0.04

0.06

0.08

0.10

LRS DensityFSS Density

BSS Density

LRS CPUEFSS CPUELRS CPUE

FSS CPUE

BSS CPUE

FSS Abundance Index

River Segment 4 Riverwide

Level of Significance for H0: Slope = 0

Slope 

± 2* Standard Error of Slope

Slope p-value

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

-0.12

-0.10

-0.08

-0.06

-0.04

-0.02

0.00

0.02

0.04

0.06

0.08

0.10

LRS DensityFSS Density

BSS Density

LRS CPUEFSS CPUELRS CPUEFSS CPUE

BSS CPUE

BSS Abundance Index

River Segment 4 Riverwide

Level of Significance for H0: Slope = 0

Slope 

± 2* Standard Error of Slope

Slope p-value
Appendix A

A-27

1 Figure A–12. Estimated Linear Slopes and Confidence Intervals (Blue Bars with Error 

2 Bars) and the P-Values for the Test of Zero Slope (Red Thick Circles) for Each White 

3 Catfish Population Measure of Abundance

4 Population Trend LOE

5 For each measure of abundance and RIS, application of scoring and decision rules to the trend 

6 results produced a River Segment 4 assessment score (Table A–12) and a Riverwide 

7 assessment score (Table–13). Insufficient catches for some RIS resulted in some unknown 

8 assessments. Although all measures of abundance for any RIS derive from samples from the 

9 same YOY population, trend scores can differ, probably due to different sampling efficiencies, 

10 different distributions of populations in relation to sampling locations, etc.

11 Table A–12. Assessment of Population Impacts for IP2 and IP3 River Segment 4

Species

Density Catch-per-Unit Effort River Segment

LRS FSS BSS LRS FSS Assessment

Alewife N/A(a) 4 1 N/A 1 2.0

American Shad 4 4 4 4 4 4.0

Atlantic Menhaden N/A N/A N/A N/A N/A Unknown

Atlantic Sturgeon N/A N/A N/A N/A N/A Unknown

Atlantic Tomcod 1 4 N/A 1 4 2.5

Bay Anchovy N/A 4 1 1 1 1.8

Blueback Herring N/A 4 4 N/A 4 4.0

Bluefish 4 1 1 4 4 2.8

Gizzard Shad N/A N/A N/A N/A N/A Unknown

Hogchoker N/A 4 1 N/A 4 3.0

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

-0.12

-0.10

-0.08

-0.06

-0.04

-0.02

0.00

0.02

0.04

LRS DensityFSS Density

BSS Density

LRS CPUEFSS CPUELRS CPUEFSS CPUE

BSS CPUE

BSS Abundance Index

River Segment 4 Riverwide

Level of Significance for H0: Slope = 0

Slope 

± 2* Standard Error of Slope

Slope p-value
Appendix A

A-28

Species

Density Catch-per-Unit Effort River Segment

LRS FSS BSS LRS FSS Assessment

Rainbow Smelt 4 4 N/A 4 4 4.0

Shortnose Sturgeon N/A N/A N/A N/A N/A Unknown

Spottail Shiner N/A N/A 1 N/A N/A 1.0

Striped Bass 1 4 1 1 4 2.2

Weakfish 1 1 N/A 1 1 1.0

White Catfish N/A N/A N/A N/A N/A Unknown

White Perch N/A 1 1 N/A 1 1.0

Blue Crab N/A N/A N/A N/A N/A Unknown

(a) N/A: not applicable; YOY not present in samples.

Note: Tabulated values for density and CPUE data are either 1 (undetected decline) or 4 (detected 

decline). The river segment assessment is an average of the scores for the given row.

1 Table A–13. Assessment of Riverwide Population Impacts

Species

CPUE Abundance Index Riverwide 

LRS FSS BSS LRS FSS BSS Assessment

Alewife 1 1 1 N/A(a) N/A 1 1.0

American Shad 4 4 4 N/A N/A 4 4.0

Atlantic Menhaden N/A N/A N/A N/A N/A N/A Unknown

Atlantic Sturgeon N/A N/A N/A N/A N/A N/A Unknown

Atlantic Tomcod 4 4 4 4 N/A N/A 4.0

Bay Anchovy 1 1 1 N/A 4 N/A 1.8

Blueback Herring 1 4 1 N/A N/A 4 2.5

Bluefish 4 4 1 N/A N/A 1 2.5

Gizzard Shad N/A 1 1 N/A N/A N/A 1.0

Hogchoker 1 1 1 N/A 1 N/A 1.0

Rainbow Smelt 4 4 N/A 4 N/A N/A 4.0

Shortnose Sturgeon N/A N/A N/A N/A N/A N/A Unknown

Spottail Shiner 1 4 1 N/A N/A 1 1.8

Striped Bass 1 4 1 N/A N/A 1 1.8

Weakfish 1 1 1 N/A 4 N/A 1.8

White Catfish 1 4 1 N/A N/A 4 2.5

White Perch 1 1 1 N/A N/A 4 1.8

Blue Crab N/A N/A N/A N/A N/A N/A Unknown

(a) N/A: not applicable; YOY not present in samples

Note: Tabled values for the abundance index and CPUE data are either a 1 (undetected decline) or a 4 (detected 

decline). The riverwide assessment is an average of the scores for the given row.

2 The NRC staff combined the River Segment 4 and Riverwide population assessments to yield 

3 an overall population trend conclusion (Table A–14). Several RIS (Atlantic menhaden, Atlantic 

4 and shortnose sturgeon, and blue crab) had too few catches to make a population trend 
Appendix A

A-29

1 assessment, and results are “Unresolved.” Four RIS (American shad, Atlantic tomcod, 

2 blueback herring, and rainbow smelt) had detected declines, three RIS (bluefish, hogchoker, 

3 and white catfish) had a variable response, and seven RIS (alewife, bay anchovy, gizzard shad, 

4 spottail shiner, striped bass, weakfish, and white perch) did not exhibit detectable declines.

5 Table A–14. Weight of Evidence Results for the Population Trend Line of Evidence

Measurement

River Segment

Assessment 

Score

Riverwide 

Assessment Score

WOE

Score(b)

Impact

Conclusion

Utility Score(a) 2.4 1.7

Alewife 2.0 1.0 1.6 Undetected Decline

American Shad 4.0 4.0 4.0 Detected Decline

Atlantic Menhaden Unknown Unknown Unknown Unresolved(c)

Atlantic Sturgeon Unknown Unknown Unknown Unresolved(c)

Atlantic Tomcod 2.5 4.0 3.1 Detected Decline

Bay Anchovy 1.8 1.8 1.8 Undetected Decline

Blueback Herring 4.0 2.5 3.4 Detected Decline

Bluefish 2.8 2.5 2.7 Variable

Gizzard Shad Unknown 1.0 1.0 Undetected Decline

Hogchoker 3.0 1.0 2.2 Variable

Rainbow Smelt 4.0 4.0 4.0 Detected Decline

Shortnose Sturgeon Unknown Unknown Unknown Unresolved(c)

Spottail Shiner 1.0 1.8 1.3 Undetected Decline

Striped Bass 2.2 1.8 2.0 Undetected Decline

Weakfish 1.0 1.8 1.3 Undetected Decline

White Catfish Unknown 2.5 2.5 Variable

White Perch 1.0 1.8 1.3 Undetected Decline

Blue Crab Unknown Unknown Unknown Unresolved(c)

(a) Use and Utility Scores are the weights for the WOE Score calculated as a weighted mean.

(b) WOE Score: Undetected Decline <2.2; Variable ≥ 2.2 but ≤ 2.8; Detected Decline >2.8

(c) Unable to make a WOE conclusion because of a lack of data for trend assessment

6 Strength of Connection LOE

7 For the SOC analysis, the NRC staff conducted four simulation series for each RIS using all 

8 possible pairs of the parameters t and N0 (n = 1000 for each). The NRC staff estimated the 

9 growth-rate parameters for a given RIS from the linear regressions of the River Segment 4 

10 population density and incorporated the estimated EMR and IMR (Table A–15). The SOC was 

11 low if the range of the first and third quartiles of the distribution of the relative cumulative 

12 difference in YOY population abundance included zero for any of the simulation series. The 

13 SOC was high if both quartiles were positive for all parameter t and N0 pairs. The latter result 
Appendix A

A-30

1 occurs when the effects of entrainment and impingement are consistently greater than the 

2 modeled variation.

3 Table A–15. Table A–15 Parameter Values Used in the Monte Carlo Simulation

RIS

Survey 

Used

Estimated 

Linear 

Slope

(r)

Slope + 

Standard 

Error of the 

Slope 

Estimate 

(rUL)

Mean 

Square 

Error from 

Regression

CV of 

Density 

Data

(1985-2011) EMR IMR

Alewife BSS 0.050 0.060 0.123 1.290 0.095 0.0020

American Shad BSS -0.073 -0.064 0.117 0.689 0.039 0.0005

Atlantic Tomcod LRS -0.013 0.000 0.213 1.050 0.036 0.0300

Bay Anchovy FSS -0.053 -0.037 0.314 0.583 0.212 0.0040

Blueback 

Herring

BSS -0.046 -0.033 0.232 1.629 0.095 0.0040

Bluefish BSS -0.019 -0.003 0.347 0.712 0.003 0.0005

Hogchoker FSS -0.068 -0.056 0.175 1.927 0.385 0.0005

Rainbow Smelt LRS -0.071 -0.056 0.300 2.067 0.258 0.0005

Spottail Shiner BSS -0.015 0.001 0.349 1.137 0.031 0.0070

Striped Bass BSS 0.013 0.026 0.229 0.538 0.106 0.0080

Weakfish FSS -0.034 -0.016 0.399 0.877 0.544 0.0005

White Catfish(a) FSS 0.007 0.010 0.010 3.520 0.114 0.0005

White Perch BSS -0.010 0.007 0.387 0.958 0.075 0.0320

(a) Data for regression from 1979–2005 (last density observation was in 2003)

4 The results and SOC conclusions of the Monte Carlo simulations (n = 1000) for each pair of 

N0 (1000 and 108 5 ) and number of years modeled (20 and 27) are presented in Table A–16. In 

6 general, for a given RIS, the difference in the median simulation results for 20 verses 27 years 

modeled (t) decreased with increasing initial abundance (N0). For N0 = 1000 and 1 x 108 7 , the 

8 median difference between the simulation results with a different number of years modeled was 

9 2 percent across all RIS. For t = 20 and 27 years, the median difference between the results of 

10 the simulations with different initial abundance was 1 percent and 0.2 percent respectively 

11 across all RIS.

12 The SOC analysis assumes that the IP2 and IP3 cooling systems can affect aquatic resources 

13 both directly through impingement or entrainment and indirectly by affecting trophic and other 

14 relationships. By examining the distribution of the simulated differences in the cumulative 

15 annual abundance of YOY RIS with and without losses from impingement and entrainment, the 

16 NRC staff could assess the effect of the IP2 and IP3 cooling systems on the River Segment 4 

17 population trends (e.g., how strongly are the effects of the cooling system connected to the RIS 

18 of interest). The results of this analysis indicate a High SOC for seven species (Table A–17). 

19 For those species, the IP2 and IP3 cooling systems were removing the species at levels that 

20 were proportionally higher than expected from the observed abundance in the river. For six 

21 RIS, the SOC was Low (minimal evidence of connection).
Appendix A

A-31

1 Table A–16. Quartiles of the Relative Difference in Cumulative Abundance and 

2 Conclusions for the Strength-of-Connection from the Monte Carlo Simulation

Taxa

Number 

of

Years

N0 = 1000 N0 = 1 x 108 StrengthofConnection 

Conclusion

Median Q1 Q3 Median Q1 Q3

Alewife 20 0.10 -0.38 0.57 0.14 -0.30 0.59 Low

27 0.03 -0.45 0.53 0.09 -0.37 0.54

American Shad 20 0.07 -0.01 0.15 0.07 -0.02 0.15 Low

27 0.06 -0.01 0.12 0.06 0.00 0.13

Atlantic 

Tomcod

20 0.20 -0.01 0.41 0.17 -0.03 0.39 Low

27 0.22 0.06 0.41 0.22 0.05 0.38

Bay Anchovy 20 0.27 0.14 0.39 0.26 0.12 0.38 High

27 0.24 0.15 0.33 0.24 0.15 0.32

Blueback 

Herring

20 0.34 0.10 0.57 0.32 0.12 0.54 High

27 0.35 0.19 0.55 0.37 0.20 0.57

Bluefish 20 0.18 -0.01 0.34 0.15 -0.01 0.34 Low

27 0.20 0.07 0.33 0.19 0.06 0.34

Hogchoker 20 0.68 0.42 0.95 0.67 0.41 0.94 High

27 0.70 0.49 0.92 0.71 0.52 0.93

Rainbow Smelt 20 0.64 0.37 0.91 0.67 0.39 0.96 High

27 0.68 0.48 0.93 0.64 0.44 0.85

Spottail Shiner 20 0.24 0.00 0.46 0.21 -0.03 0.44 Low

27 0.27 0.07 0.46 0.26 0.07 0.46

Striped Bass 20 0.31 0.11 0.52 0.32 0.13 0.54 High

27 0.43 0.25 0.61 0.42 0.25 0.61

Weakfish 20 0.71 0.47 0.93 0.65 0.42 0.89 High

27 0.69 0.52 0.86 0.66 0.47 0.87

White Catfish 20 0.14 -0.41 0.66 0.13 -0.38 0.65 Low

27 0.12 -0.38 0.61 0.10 -0.38 0.53

White Perch 20 0.28 0.03 0.52 0.29 0.04 0.53 High

27 0.34 0.16 0.56 0.35 0.15 0.55
Appendix A

A-32

1 Table A–17. Weight of Evidence for the Strength-of-Connection Line of Evidence for YOY 

2 RIS Based on the Monte Carlo Simulation

RIS

Strength of 

Connection RIS Strength of Connection

Alewife Low Hogchoker High

American Shad Low Rainbow Smelt High

Atlantic Menhaden Cannot be Modeled(a) Shortnose Sturgeon Cannot be Modeled(a)

Atlantic Sturgeon Cannot be Modeled(a) Spottail Shiner Low

Atlantic Tomcod Low Striped Bass High

Bay Anchovy High Weakfish High

Blueback Herring High White Catfish Low

Bluefish Low White Perch High

Gizzard Shad Cannot be Modeled(a) Blue Crab Cannot be Modeled(a)

(a) Estimates for model parameters were unavailable or information was lacking.

3 The SOC for Atlantic menhaden, Atlantic and shortnose sturgeon, gizzard shad, and blue crab 

4 could not be modeled. Atlantic menhaden did not occur in entrainment samples (1981, 

5 1983–1987) and occurred in low numbers (approximately 630 annually) in impingement

6 samples. The number impinged represented 0.05 percent of all fish and blue crab impinged 

7 (1975–1990). Neither Atlantic nor shortnose sturgeon occurred in entrainment samples (1981, 

8 1983–1987), and an estimated total of 71 shortnose sturgeon and 1,334 Atlantic sturgeon 

9 occurred in impingement samples from 1974 through 1990 (NMFS 2013). Gizzard shad did not 

10 occur in entrainment samples (1981, 1983–1987) but appeared regularly in impingement 

11 samples, increasing from about 2,400 annually from 1975 to 1984 to about 7,700 annually from 

12 1985 to 1990. Sampling for blue crab in impingement samples began in 1983, with numbers 

13 increasing from about 2,000 annually from 1983 to1987 to 56,600 annually from 1988 to1990. 

14 Despite the increase in impingement, gizzard shad and blue crab represent only about 

15 1 percent of all RIS impinged.

16 Integration

17 The WOE integrates the population trend and SOE LOEs into final impact conclusions 

18 (Table A–18). Assignment of an NRC staff level of impact for any aquatic species (Small, 

19 Moderate, or Large) requires information on both a measurable response in the RIS population 

20 and modeling showing that the RIS is influenced to an observable degree by the operation of 

21 the IP2 and IP3 cooling system operation. If the SOC is low, the impact level will not be greater 

22 than Small because of little evidence that an observable relationship exists between the cooling 

23 system and RIS trend. Conversely, if an RIS exhibits a high SOC to the IP2 and IP3 cooling 

24 system operation but no statistically significant population decline, the final determination will be 

25 Small. If, for any RIS, the population trend is unresolved and the SOC could not be modeled, 

26 the WOE conclusion is “unresolved.”

27 Both Atlantic and shortnose sturgeon populations are listed under the Endangered Species Act

28 (ESA). As discussed in the 2013 FSEIS supplement, the NRC staff and NMFS conducted a 

29 Section 7 consultation, and NMFS (2013) issued a biological opinion on the effects of 

30 impingement at IP2 and IP3, which concludes that continued operation of either IP2 or IP3 
Appendix A

A-33

1 individually is likely to adversely affect but is not likely to jeopardize the continued existence of 

2 these species. This conclusion is used as a final impact conclusion.

3 Table A–18. Impingement and Entrainment Impact Summary for Hudson River YOY RIS

Species

Population Trend Line of 

Evidence

Strength of 

Connection

Line of 

Evidence

Impacts of IP2 and IP3 

Cooling System 

Operation

Alewife Undetected Decline Low Small

American Shad Detected Decline Low Small

Atlantic Menhaden Unresolved(a) Unresolved (b) Unresolved

Atlantic Sturgeon Unresolved(a) Unresolved (b) Likely to adversely affect

but not jeopardize(c)

Atlantic Tomcod Detected Decline Low Small

Bay Anchovy Undetected Decline High Small

Blueback Herring Detected Decline High Large

Bluefish Variable Low Small

Gizzard Shad Undetected Decline Unresolved (b) Unresolved

Hogchoker Variable High Moderate

Rainbow Smelt Detected Decline High Large

Shortnose Sturgeon Unresolved(a) Unresolved (b) Likely to adversely affect

but not jeopardize(c)

Spottail Shiner Undetected Decline Low Small

Striped Bass Undetected Decline High Small

Weakfish Undetected Decline High Small

White Catfish Variable Low Small

White Perch Undetected Decline High Small

Blue Crab Unresolved(a) Unresolved (b) Unresolved

(a) Population Trend LOE could not be established

(b) SOC could not be established using Monte Carlo simulation

(c) From NMFS’s (2013) biological opinion. In Supplement 1 to the FSEIS, the NRC staff described the unresolved 

impacts to Atlantic and shortnose sturgeon as “Small.” No information has been received by the NRC staff that 

would further resolve the impact levels.

4 Uncertainty Analysis for Changing Years of Analysis

5 Both the population trend LOE and the SOC LOE were based on data collected nearly 10 years 

6 after the start of operation of the IP2 and IP3 cooling system. A nonparametric Mann-Whitney 

7 test of the equality of the median abundance pre- and post-1985 provides an indication of a 

8 change in status that would not be reflected in the 1985 through 2011 data used in the WOE 

9 analysis (Table A–19).
Appendix A

A-34

1 Table A–19. P-Values for Mann-Whitney Test of Equal Median Abundance Pre- and 

2 Post-1985 for Each Population Metric

Species

River Segment 4 Population Metrics Riverwide Population Metrics Proportion

Detected

Change

LRS

Density

FSS

Density

BSS

Density

LRS

CPUE

FSS

CPUE

LRS

CPUE

FSS

CPUE

BSS

CPUE

Abundance

Index

Alewife -- 0.22 0.06 -- <0.01 NA <0.01 0.50 NA 0.29

American 

Shad

0.22 0.01 <0.01 0.28 <0.01 0.05 <0.01 0.02 0.04 0.78

Atlantic 

Tomcod

0.10 0.04 <0.01 0.07 0.05 0.31 0.10 <0.01 0.40 0.44

Bay 

Anchovy

-- 0.01 NA NA <0.01 NA <0.01 0.19 0.14 0.38

Blueback 

Herring

-- 0.01 0.15 -- <0.01 NA <0.01 0.01 0.02 0.71

Bluefish 0.27 <0.01 0.02 0.49 <0.01 NA <0.01 0.02 0.02 0.67

Gizzard 

Shad

-- -- -- -- -- -- NA NA -- 0.00

Hogchoker -- 0.17 0.03 -- 0.38 0.28 NA 0.19 0.25 0.14

Rainbow 

Smelt

0.05 0.06 -- 0.03 0.01 0.04 0.01 0.06 0.03 0.75

Spottail 

Shiner

-- -- 0.07 -- -- NA 0.25 NA 0.44 0.00

Striped 

Bass

NA NA NA NA 0.42 NA NA NA NA 0.00

Weakfish NA 0.01 -- NA <0.01 NA <0.01 0.02 0.03 0.63

White 

Catfish

-- -- -- -- -- 0.31 0.06 0.45 <0.01 0.25

White 

Perch

-- 0.23 0.01 -- 0.06 NA 0.03 <0.01 <0.01 0.57

NA = Pre-1985 Median < Post-1985 Median; Highlighted cells are significant α = 0.05; and -- = Not enough data

3 Two RIS (American shad and rainbow smelt) had at least 75 percent of their population metrics 

4 showing a reduction in the median abundance post-1985. Both American shad and rainbow 

5 smelt population trend conclusions were Detected Decline. The slopes of the BSS and LRS 

6 River Segment 4 density metrics used in the SOC analysis for American shad and rainbow 

7 smelt, respectively, were also significantly decreasing. Thus, it is unlikely that the decision to 

8 use only the 1985 through 2011 data affected the WOE impact conclusion of LARGE.

9 Seven RIS (alewife, Atlantic tomcod, bay anchovy, blueback herring, bluefish, weakfish, and 

10 white perch) had greater than 25 percent but less than 75 percent of their population metrics 

11 showing a reduction in the median abundance post-1985. Of these RIS, alewife (Figure A–13), 

12 weakfish (Figure A–14), and white perch (Figure A–15) had a change in their WOE impact 

13 conclusions from that published earlier (NRC 2013). The years of monitoring data used to 

14 assess alewife, weakfish, and white perch population density trends used in the SOC analysis 

15 could affect the WOE impact conclusions.
Appendix A

A-35

1 Figure A–13. River Segment 4 Alewife Population Trends Based on the BSS Standardized 

2 Density for Two Subsets of Years of Monitoring Data

3 Figure A–14. River Segment 4 Weakfish Population Trends Based on the FSS 

4 Standardized Density for Two Subsets of Years of Monitoring Data

1980 1990 2000 2010

-1

0

1

2

1979-2005 1985-2011

Year

BSS R4 Smoothed

Standardized Density

1980 1990 2000 2010

-2

-1

0

1

2

1979-2005 1985-2011

Year

FSS R4 Smoothed

Standardized Density
Appendix A

A-36

1 Figure A–15. River Segment 4 White Perch Population Trends Based on the BSS 

2 Standardized Density for Two Subsets of Years of Monitoring Data

3 A.4 Discussion

4 Across species, population trends of many species appear to be decreasing, particularly in 

5 River Segment 4. These decreases occur in spite of a long-term trend of better water quality 

6 (Levinton and Waldman 2006) and no evidence that populations are adjusting to overly high 

7 population levels in the past. Four species had statistically significant declines consistently

8 across measures of abundance and geographic scales: American shad, Atlantic tomcod, 

9 blueback herring, and rainbow smelt.

10 American shad YOY population trends for all measures of abundance for both River Segment 4 

11 and Riverwide scales are negative and statistically significant (Figure A–5). These results 

12 reflect a coastwide decline. East coast commercial fishery landings of American shad have 

13 been declining since the late 1800s (NMFS 2015). In the Hudson River, several measures of 

14 shad abundance have decreased, including commercial landings, since the late 1800s (Hattala 

15 and Kahnle 2009); abundance of YOY American shad since 1980 (NYSDEC 2015); and 

16 spawning stock since 1985 (Hattala and Kahnle 2009). The decline in American shad has 

17 generally been attributed principally to overfishing, not only in the Hudson River but along the 

18 Atlantic coast; habitat loss and degradation; and cooling water intakes (Hattala and 

19 Kahnle 2009, Kahnle and Hattala 2010). Examining potential effects of striped bass predation 

20 on American shad has not yielded evidence that an increase in the striped bass population has 

21 caused a decline in the shad population (ASMFC 2007, Hattala and Kahnle 2009, 

22 NYSDEC 2009DE, Kahnle and Hattala 2010). Both NYSDEC and Cornell (2015) and 

23 NYSDEC (2015) present an index of Hudson River YOY American shad abundance from 1984 

24 through 2013 and find that highs in the 1980s were much lower than historical highs; production 

25 of YOY decreased significantly in 2002 and continued to decline through 2013.

26 The SOC for Hudson River American shad is Low (Table A–17), and so the impact of IP2 and 

27 IP3 operation is Small (Table A–18). This finding is consistent with Hattala and Kahnle’s (2009) 

28 conclusion that I&E losses of American shad due to once-through cooling water intakes at 

29 power generating stations on the Hudson River south of Newburgh Bay, such as IP2 and IP3, 

1980 1990 2000 2010

-1

0

1

2

1979-2005 1985-2011

Year

BSS R4 Smoothed

Standardized Density
Appendix A

A-37

1 are relatively small because the spawning habitat is well upstream. When added to other more 

2 serious stresses, however, power plant impingement mortality in the Hudson River contributes 

3 to increased mortality rates (ASMFC 2009).

4 Like American shad, alewife and blueback herring are anadromous alosid species that spawn 

5 upstream of IP2 and IP3 and their YOY pass the plant on the downstream migration. Due to 

6 difficulties in distinguishing between alewife and blueback herring, these congeneric species are 

7 collectively called ‘‘river herring.’’ They have similar ranges and life histories, are often caught 

8 together in commercial and recreational fisheries, and are managed together. River herring 

9 populations are well below historic levels of the mid-20th century, possibly because of 

10 overfishing and habitat destruction. Severe declines in coastwide river herring populations 

11 starting in the 1970s led NMFS to consider listing river herring as threatened or endangered 

12 species (78 FR 48944). Both are anadromous species that, in the Hudson River, spawn upriver 

13 from IP2 and IP3 in tributaries and shallow areas of the main stem (Hattala et al. 2011), and 

14 YOY are vulnerable to IP2 and IP3 impingement during the seaward migration.

15 The population trends LOE shows a decline in the blueback herring YOY population that was 

16 consistent in measures of abundance within River Segment 4 and less consistent Riverwide 

17 (Figure A–7, Table A–14). For alewife, however, results were mixed (Tables A–12 and A–13). 

18 Statistically significant trends in River Segment 4 are positive for BSS density and negative for 

19 FSS density (Addendum A–1, Figures B1 and C1), even though both surveys sample the YOY 

20 population at the same time of year and the Riverwide trend in FSS CPUE is positive (but not 

21 significant). Trends in other measures of abundance are mixed and not significant. Using a 

22 variety of fishery dependent and fishery independent data from the Hudson River, 

23 Hattala et al. (2011) found that yearly recruitment has become extremely variable for both 

24 species and that a decline is occurring in YOY blueback herring while an increasing trend is 

25 occurring in YOY alewife. NMFS found similar results on a larger scale for the stock complexes, 

26 which typically include populations from several rivers. The Southern New England alewife 

27 stock complex, which includes the Hudson River, appears stable, and the mid-Atlantic blueback 

28 herring stock complex, which includes the Hudson River, is significantly decreasing 

29 (78 FR 48944). The population trends LOE (Tables A–12, A–13, and A–14) also shows a 

30 decrease in YOY Hudson River blueback herring but mixed trends for alewife that partially 

31 depend on how YOY abundance is measured, perhaps due to high alewife recruitment 

32 variability combined with a lower population density of alewife compared to blueback herring.

33 The SOC conclusion is Low for alewife and High for blueback herring (Table A–17), which, 

34 together with the population trends LOE, results in a level of IP2 and IP3 impact of Small for 

35 alewife and Large for blueback herring. In IP2 and IP3 I&E samples, some young alosids 

36 cannot be further identified to species and are reported as unidentified alosids. The NRC staff 

37 allocated these in proportion to the identified river herring in the SOC estimate of EMR, but 

38 some uncertainty is introduced into the analysis. In its blueback herring factsheet, the Atlantic 

39 States Marine Fisheries Commission (ASMFC) (undated) considers both “water withdrawal 

40 facilities” and “thermal and toxic discharges” as two of seven identified threats to blueback 

41 herring habitat. ASMFC’s recommendations to improve the habitat quality include “[a]lter water 

42 withdrawal rates or water intake velocities to reduce alosine mortality.” Hattala et al. (2012) 

43 could not identify the reason for the wide variation in YOY river herring indices and note that the 

44 same erratic trend that occurs since 1998 in river herring is also evident for American shad. 

45 They conclude that the trend of increasing recruitment variability in all three alosines may 

46 indicate a change in overall stability of the Hudson River system.

47 Rainbow smelt is an anadromous species once common in the Hudson River, but it has 

48 undergone an abrupt population decline in the Hudson River since 1994, and the species may 

49 no longer have a viable population within the Hudson River. The last tributary run of rainbow 
Appendix A

A-38

1 smelt was recorded in 1988, and the post-yolk sac larvae essentially disappeared from LRS 

2 samples after 1995 (Daniels et al. 2005). Rainbow smelt YOY were last captured in the LRS, 

3 FSS, and BSS in 1995, 1998 (one fish), and 1993, respectively (Addendum A–1, Figures F1

4 and G1). In the population trends LOE, statistically significant declines in YOY rainbow smelt 

5 occurred in all (4 of 4) of the River Segment 4 and all (3 of 3) Riverwide measures of abundance 

6 The EMR is the fourth highest of all species analyzed (25.8 percent, Table A–15), and the SOC

7 is High (Table A–17), indicating that the effect of IP2 and IP3 on the population would be 

8 observable. The WOE conclusion is that the impact of IP2 and IP3 cooling system operation on 

9 rainbow smelt is High.

10 Large cooling water withdrawals may be a source of adverse impact to rainbow smelt 

11 coastwide. For example, NRC (2007) finds that the impingement impacts of Pilgrim Nuclear 

12 Power Station on rainbow smelt and winter flounder populations in the James River are 

13 Moderate, whereas effects on other fish species are Small-to-Moderate. Daniels et al. (2005) 

14 note slowly increasing water temperatures in the Hudson River and suggest that the 

15 disappearance of rainbow smelt can be attributed to global warming, and NYSDEC (2003) 

16 indicates that thermal effluents from Hudson River power plants may have contributed to its 

17 disappearance. Additional factors contributing to rainbow smelt population declines include 

18 dams, overfishing, pollution, changes in trophic interactions, shifts in aquatic communities, and 

19 watershed land use (Enterline et al. 2012).

20 Although rainbow smelt became absent from LRS, FSS, and BSS about midway through the 

21 period considered here, this RIS is retained in the analysis. The fate of an RIS helps inform the 

22 impact determination, because it stands as a surrogate for other species in the aquatic 

23 community. The RIS are sentinel species: The extirpation of an RIS stands as a warning that 

24 other species with similar attributes could suffer adverse impacts.

25 Like rainbow smelt, Atlantic tomcod is a cold-water, anadromous species, and the only 

26 winter-spawning fish species in the Hudson River (Dew and Hecht 1994). Although its range 

27 once extended as far south as Virginia, the Hudson River is now the southern limit (Stewart and 

28 Auster 1987). Tomcod larvae hatch upriver from IP2 and IP3 and pass by the plant on their 

29 spring seaward migration, where, because of their vertical migration patterns and tidal currents 

30 in this two-layered estuarine system, may be exposed to the cooling water withdrawal several 

31 times (Dew and Hecht 1994). The lifespan of Hudson River tomcod is relatively short, perhaps 

32 not much over 1 year.

33 Population trends for YOY Atlantic tomcod are consistently negative (Figure A–6), with trends 

34 for 2 of 4 measures of abundance statistically significant for River Segment 4 (Table A–12) and 

35 4 of 4 Riverwide (Table A–13), indicating an unstable population. NYSDEC and Cornell (2015) 

36 present an Atlantic tomcod index of abundance for the Hudson River from 1974 through 2014 

37 that shows a continual decline with high variability. The SOC is Low (Table A–17), which 

38 indicates that the effect of IP2 and IP3 on the population would not be observable. The 

39 resulting impact conclusion is Small (Table A–18). The causes of the decline of Atlantic tomcod 

40 in the Hudson River have not been clearly identified but may be similar to those affecting 

41 rainbow smelt, which is also a cold water, anadromous species. Particular threats include 

42 global warming and the thermal environment as well as pollution (Daniels et al. 2005), and 

43 thermal stress could increase tomcod susceptibility to other stresses.

44 One species, hogchoker, had varied population trends and a high SOC. Hogchoker is a 

45 semi-anadromous flatfish species in the Hudson River estuary, surrounding bays and coastal 

46 waters. Adults tend to live in low salinity waters from late fall through spring, migrate 

47 downstream into high salinity waters to spawn in spring and summer, and then migrate back 

48 upstream. In summer and fall, the larvae and early juveniles migrate from marine waters upriver 
Appendix A

A-39

1 to low salinity areas, and the EMR from IP2 and IP3 is relatively high (38.5 percent, 

2 (Table A–15). The population trend LOE showed variable trends with consistent declines in 

3 River Segment 4 but not Riverwide (Tables A–12, A–13, and A–14). The statistically significant 

4 trends, however, were all negative: FSS density and CPUE in River Segment 4 (Figure A–10). 

5 The SOC LOE was High, indicating that the effect of I&E at IP2 and IP3 would be observable. 

6 Considered together, the impact of IP2 and IP3 cooling water system operation was Moderate 

7 (Table A–18). The relatively high EMR and decreasing trends of abundance in River Segment 4 

8 but not Riverwide suggest that the river habitat near IP2 and IP3 is becoming poorer for 

9 hogchoker.

10 The SOC LOE was High although population levels did not consistently decline for four species: 

11 bay anchovy, striped bass, weakfish, and white perch. Bay anchovy are part of a coastal 

12 population that spawns not only in the Hudson River but in many other parts of the 

13 Hudson-Raritan estuary complex. Only 1 of 4 trends in both River Segment 4 and Riverwide 

14 scales is significant, and both are negative: FSS density (Table A–12) and the FSS Abundance 

15 Index (Table A–13), respectively. Trends of the other measures of abundance are not 

16 statistically significant, resulting in an undetected decline for the population trends LOE.

17 Bay anchovy EMR in River Segment 4 is relatively high, about 21 percent (Table A–15), and the 

18 SOC is High (Table A–17). That, together with undetectable population declines, yielded an 

19 impact conclusion of Small (Table A–18). Bay anchovy live about 2 years, and adults move out 

20 of the estuary to the continental shelf in the fall and back into the estuary in the spring. 

21 Vouglitois et al. (1987) found that, in Barnegat Bay, New Jersey, the population levels appear to 

22 be regulated largely by the survival rate and migratory patterns of the overwintering population 

23 on the shelf and to a lesser degree by events occurring within the estuary during the first few 

24 months of life. Bay anchovy in the Chesapeake Bay compensate for high mortality rates by 

25 maturing early and having high reproductive capacity (Newberger and Houde 1995). The same 

26 may be true in the Hudson River estuary.

27 Hudson River weakfish are also seasonal residents that are part of a coastal population. 

28 Weakfish overwinter in deeper waters of the continental shelf, generally between Chesapeake 

29 Bay and Cape Fear, North Carolina (Wilk 1979), and older weakfish begin to move toward shore 

30 and then head north along the coast when inshore waters begin to warm in spring. Spawning 

31 occurs in nearshore coastal and marine waters in spring and summer, and the larvae move into 

32 bays and estuaries. Weakfish typically occur in the Hudson River from July through 

33 mid-August. In fall, juvenile weakfish begin to leave northern estuaries and move toward

34 southern overwintering areas.

35 Trends in 6 of 8 total measures of abundance appear to be negative (Addendum A–2, 

36 Figure L2). Only one trend is statistically significant (Riverwide FSS Abundance Index, 

37 Table A–13), and it is negative, which leads to a Population Trend LOE conclusion of an 

38 undetected decline (Table A–14). The CEMR is high (54.4 percent, Table A–15), and the SOC

39 is High. Because the weakfish population is only seasonal in the Hudson River and spends 

40 much of the year offshore, the high EMR of fish that do reside in River Segment 4 does not 

41 appear to result in long-term population declines.

42 Striped bass are anadromous. Adults live along the coast in nearshore waters and tend to 

43 migrate north in winter and return to aggregate near the mouths of their natal rivers before the 

44 spring spawning migration. Spawning occurs primarily between mid-May and mid-June in the 

45 middle portion of the Hudson River estuary, which renders the early life stages susceptible to 

46 both impingement and entrainment at IP2 and IP3. By the end of their first summer, many of 

47 the juvenile striped bass move to the southern extreme of the estuary, and at age 2 or 3 leave 

48 the estuary to begin seasonal migrations along the coast. Because of the commercial and 
Appendix A

A-40

1 recreational importance of Hudson River striped bass, the LRS, FSS, and BSS were originally 

2 focused on this species. Population trends in 3 of 9 indices of abundance are statistically 

3 significant, all of them negative (Figure A–11): 2 of 4 in River Segment 4 (FSS Density and FSS 

4 CPUE, Table A–12) and 1 of 4 (FSS CPUE, Table A–13) Riverwide. The inconsistency of 

5 results yields an undetected decline for the Population Trends LOE (Table A–14). The 

6 NYSDEC also monitors the abundance of Hudson River YOY striped bass with a beach seine 

7 survey and calculates a riverwide abundance index. In reviewing the NYSDEC Striped Bass 

8 Young-of-Year Index of Abundance values from 1984 through 2014, NYSDEC and 

9 Cornell (2015) conclude that “[w]hile 2014 was a good year for production of young striped bass 

10 in the Hudson, the overall trend in recent years has been downward.” The SOC is High, which 

11 suggests that effects of I&E may be observable, and combined with an undetected decline 

12 conclusion for the Population Trends LOE, results in a small level of impact from IP2 and IP3 

13 (Table A–18).

14 White perch is a congener of striped bass, a resident species throughout the Hudson River from 

15 Albany south to Manhattan, and a numerically dominant species in many parts of the river (Bath 

16 and O’Connor 1982). It is semi-diadromous and migrates within the Hudson River but does not 

17 go to sea. Adults move shoreward and upriver to spawn in freshwater and brackish water of low 

18 salinity (<4.2 parts per thousand) in spring and early summer, the larvae drift downstream, and 

19 fry and juveniles migrate downstream (Stanley and Danie 1983). White perch, along with 

20 hogchoker, are one of the few species that can tolerate the interannual transitions between 

21 limnetic and oligohaline conditions in River Segment 4 and are a dominant year-round resident 

22 there (Bath and O’Connor 1982). Population trends in 7 of 7 measures of abundance are 

23 negative (Addendum A–2, Figure N2), although only one trend was statistically significant, and 

24 so a white perch population decline was undetected (Table A–14). The EMR is 7.5 percent of 

25 the River Segment 4 YOY population annually (Table A–15) and the SOC was High (Table A–

26 17), indicating that the effects of I&E could be observable. Because of the undetectable 

27 population trend, the impact level was Small (Table A–18).

28 Beside weakfish, two other species, bluefish and Atlantic menhaden, are marine and use the 

29 estuary primarily as a nursery. Hudson River bluefish YOY population trends appear to be 

30 consistently negative with one exception, the riverwide BSS CPUE (Addendum A–2, Figure F2),

31 which is not statistically significant. The statistically significant trends are negative in River 

32 Segment 4 (3 of 5, Table A–12) and Riverwide (2 of 4, Table A–13). The EMR is low 

33 (0.3 percent, Table A–15) and the SOC is Low. Adult bluefish are marine and pelagic, and the 

34 YOY are seasonal visitors to the estuary.

35 Atlantic menhaden belong to a single stock. Rogers and Van Den Avyle (1983) report that over 

36 winter, fish of all ages congregate in the ocean south of Cape Hatteras, North Carolina. In 

37 spring, they migrate north and inshore and spawn as they move inshore. Larvae enter estuaries 

38 after 1 to 3 months at sea, and move into low salinity (<5 ppt) parts of the estuary. Juveniles 

39 emigrate from the estuaries in fall. Menhaden have been heavily fished historically, and fishery 

40 landings fell drastically in the 1960s, rebounded somewhat in the 1980s, and have declined 

41 since then (SEDAR 2015). Catches in the LRS, BSS, and FSS were too few to calculate 

42 populations tends in River Segment 4 (Table A–12) or Riverwide (Table A–13) and so the 

43 impact was unresolved (Table A–18).

44 Gizzard shad, spottail shiner, and white catfish are freshwater species. For all of these species, 

45 population trends were variable or had undetected declines. Too few gizzard shad were caught 

46 to assess trends in River Segment 4, and two trends, not statistically significant, could be 

47 assessed Riverwide. The SOC could not be modeled, and the impact was unresolved 

48 (Table A–18). Spottail shiner trends were inconsistent, and the SOC was low (Table A–18). 

49 Too few white catfish were caught in River Segment 4 to assess trends (Table A–12). Trends 
Appendix A

A-41

1 could be calculated Riverwide, and the two statistically significant trends were both negative 

2 (Table A–13). The SOC is low (Table A–17). For both Spottail shiner and white catfish, the 

3 impact level was Small (Table A–18).

4 Atlantic and shortnose sturgeon were not captured often enough to determine trends. Although 

5 the present study found no significant population trends for YOY Atlantic sturgeon for any 

6 measure of abundance, the NYSDEC also calculates an index of relative abundance from 

7 Hudson River fisheries surveys. NYSDEC and Cornell (2015) report that, although the index 

8 has high interannual variability, the trend in abundance is increasing from 2006 through 2014 

9 (the last year reported) and is attributable to the 1996 closure of the Hudson River sturgeon 

10 fishery. Both Atlantic and shortnose sturgeon populations are greatly reduced from past levels, 

11 however, and both are listed under the ESA. The NRC staff and NMFS conducted a Section 7 

12 consultation for protection of the species f at IP2 and IP3. Atlantic sturgeon (Acipenser 

13 oxyrinchus oxyrinchus) is listed by distinct population segment (DPS), of which three occur in 

14 the Hudson River: the New York Bight and Chesapeake Bay DPSs are endangered and the 

15 Gulf of Maine DPS is threatened. NMFS (2013) issued a biological opinion on the effects of 

16 impingement at IP2 and IP3 and concluded that continued operation of either IP2 or IP3 

17 individually is likely to adversely affect but is not likely to jeopardize the continued existence of 

18 shortnose sturgeon or the three DPSs of Atlantic sturgeon in the Hudson River. No critical 

19 habitat is designated in the action area. In accordance with the biological opinion, IP2 and IP3 

20 are conducting monitoring studies to provide more information on the impacts to these species.

21 Blue crab were not captured often enough to determine River Segment 4 or Riverwide 

22 population trends or to determine SOC. This study could therefore not resolve the impact of I&E 

23 on this species.

24 A.5 Conclusions

25 The NRC staff used a WOE approach to combine a Population Trends LOE and an SOC LOE 

26 to assess the impact of impingement and entrainment at IP2 and IP3 on YOY Hudson River fish 

27 and on blue crab. The NRC staff assessed population trends by examining the consistency of 

28 multiple measures of abundance for several sampling programs at two geographic scales. 

29 Because each sampling program and measure emphasized a different season or aspect of 

30 each population, the NRC staff believes that examining consistency provides a better 

31 understanding of trends than examination of any single measure. Across species, population 

32 trends of many species appear to be decreasing, particularly in River Segment 4, and four 

33 species had consistent statistically significant declines among measures of abundance: 

34 American shad, Atlantic tomcod, blueback herring, and rainbow smelt.

35 A Monte Carlo-based assessment of SOC combined information on EMR, CMR, and population 

36 trends to indicate the degree to which the effects of impingement and entrainment at IP2 and 

37 IP3 would be observable. Species with high SOC included bay anchovy, blueback herring, 

38 hogchoker, rainbow smelt, striped bass, weakfish, and white perch.

39 The impact levels of operation of the IP2 and IP3 cooling water intakes are Moderate for one 

40 species (hogchoker) and Large for two species (blueback herring and rainbow smelt). The 

41 impact levels are Small for ten species: alewife, American shad, Atlantic tomcod, bay anchovy, 

42 bluefish, spottail shiner, striped bass, weakfish, white catfish, and white perch. Impacts could 

43 not be resolved for Atlantic menhaden, gizzard shad, and blue crab. The years of monitoring 

44 data used (1979 through 2005 vs. 1985 through 2011) to assess alewife, weakfish, and white 

45 perch population trends and used to estimate the parameters for the SOC analysis could affect 

46 the WOE impact conclusions for these RIS.
Appendix A

A-42

1 For Hudson River populations of Atlantic and shortnose sturgeon populations listed under the 

2 ESA, too few individuals were collected to determine either population trends or SOC. For 

3 these species, continued operation of either IP2 or IP3 individually is likely to adversely affect 

4 but is not likely to jeopardize the continued existence of these species (NMFS 2013).

5 A.6 References

6 References with Agencywide Documents Access and Management System (ADAMS)

7 Accession numbers can be read or downloaded using the NRC’s Web-based ADAMS search 

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34 bay anchovy in New Jersey. Transactions of the American Fisheries Society 116(2):141-153.

35 Waldman J, Limburg K, Strayer D (editors). 2006. Hudson River Fishes and Their 

36 Environment. American Fisheries Society Symposium 51, Bethesda, MD.

37 Wilk S.J. 1979. Biological and Fisheries Data on Weakfish, Cynoscion regalis (Bloch and 

38 Schneider). U.S. Department of Commerce, National Marine Fisheries Service Technical 

39 Series Report No. 21:1–49. Available at 

40 <http://www.nefsc.noaa.gov/publications/series/shtsr/shltsr21.pdf> (accessed 30 July 2015).
Appendix A

A-47

1 Addendum A–1: Linear Analysis of Population Trends

2 This addendum presents supporting plots and tables for the trend analysis presented in 

3 Appendix A and summarized in Chapter 4 of this supplement. The analysis uses the LRS, FSS, 

4 and BSS years 1985 through 2011, which have relatively consistent sampling design and no 

5 change in the FSS sampling gear. Trend analysis for the abundance index incorporates the 

6 years 1974 through 2011. Data are standardized by subtracting the mean and dividing by the 

7 standard deviation over years 1985 through 2011. Trend analysis are calculated with and 

8 without extreme observations defined as absolute standardized observations >3.

9 Figures A through C present the smoothed and standardized River Segment 4 annual YOY 

10 density measure of abundance (75th percentile of the weekly density) and the fitted simple 

11 linear trends for the LRS, FSS, and BSS 1985 through 2011 data. Regression lines associated 

12 with slopes that are significantly different from zero are represented with solid lines and dashed 

13 95 percent confidence intervals about the fitted line. Regression lines associated with slopes 

14 that are not significantly different from zero are represented by a dashed line and without a 

15 95 percent confidence interval. Figures D and E present the standardized River Segment 4 

16 annual YOY catch-per-unit-effort (CPUE) measure of abundance (75th percentile of the weekly 

17 CPUE). The fitted regressions are for the LRS and FSS 1985 through 2011 only. White catfish 

18 had a maximum of five annual observations > 0 for the years 1985 through 2011 in River 

19 Segment 4 and was not analyzed. Figures F through H present the standardized Riverwide 

20 annual CPUE (annual total YOY catch divided by the volume sampled) for the LRS, FSS, and 

21 BSS for 1985 through 2011. Figures I through K present the standardized riverwide annual 

22 YOY abundance index (provided by Entergy) for the LRS, FSS, and BSS 1974 through 2011 

23 data.

24 Tables A through K present the regression statistics including the mean squared error (MSE), 

25 the estimated linear slope (S) plus or minus the standard error of the estimated slope, the 

26 p-value associated with the null hypothesis H0: slope equals zero, the conclusion about the 

27 linear trend (S = 0, S < 0, and S > 0), and the decision score (1 or 4). Tables A through E are 

28 the River Segment 4 regression result, presented in the same order as the figures, and Tables F 

29 through K are the Riverwide regression results. Decision scores for each River Segment 4 and 

30 Riverwide measure of abundance are for the most protective result (e.g., if a negative significant 

31 slope is statistically significant with the extreme value but not with the extreme value removed 

32 from the regression, the decision for the trend is a 4).
A-48

Figure A1. River Segment 4 LRS YOY Density (May–July Sampling Events, 1985–2011, with 3 yr. M1

Smoothing) 2

1990 2000 2010

-1

2

1

0

American shad

Year

LRS R4 Smoothed Standardized Density

1990 2000 2010

-1

2

1

0

Atlantic tomcod

Year

LRS R4 Smoothed Standardized Density

1990 

-1

2

1

0

Blue

Ye

LRS R4 Smoothed Standardized Density

1990 2000 2010

-1

2

1

0

Rainbow smelt

Year

LRS R4 Smoothed Standardized Density

1990 2000 2010

-1

2

1

0

Striped bass

Year

LRS R4 Smoothed Standardized Density

1990 

-1

2

1

0

We

Ye

LRS R4 Smoothed Standardized Density
A-49

Figure B1. River Segment 4 FSS YOY Density (July–Oct Sampling Events, 1985–2011, with 3 yr. Moving Av1

1990 2000 2010

-1

-2

2

1

0

Alewife

Year

FSS R4 Smoothed Standardized Density

1990 2000 2010

-1

-2

2

1

0

American shad

Year

FSS R4 Smoothed Standardized Density

1990 2000 2010

-1

-2

2

1

0

Atlantic tomcod

Year

FSS R4 Smoothed Standardized Density

1990 

-1

-2

2

1

0

Ba

FSS R4 Smoothed Standardized Density

1990 2000 2010

-1

2

1

0

Blueback herring

Year

FSS R4 Smoothed Standardized Density

1990 2000 2010

-1

2

1

0

Bluefish

Year

FSS R4 Smoothed Standardized Density

1990 2000 2010

-1

2

1

0

Hogchoker

Year

FSS R4 Smoothed Standardized Density

1990 

-1

2

1

0

Ra

FSS R4 Smoothed Standardized Density

1990 2000 2010

-1

-2

2

1

0

Striped bass

Year

FSS R4 Smoothed Standardized Density

1990 2000 2010

-1

-2

2

1

0

Weakfish

Year

FSS R4 Smoothed Standardized Density

1990 2000 2010

-1

-2

2

1

0

White perch

Year

FSS R4 Smoothed Standardized Density
A-50

Figure C1. River Segment 4 BSS YOY Density (July–Oct Sampling Events, 1985–2011, with 3 yr. Moving Av1

1990 2000 2010

-1

-2

2

1

0

Alewife

Year

BSS R4 Smoothed Standardized Density

1990 2000 2010

-1

-2

2

1

0

American shad

Year

BSS R4 Smoothed Standardized Density

1990 2000 

-1

-2

2

1

0

Bay anchovy

Year

BSS R4 Smoothed Standardized Density

1990 2000 2010

-1

-2

2

1

0

Blueback herring

Year

BSS R4 Smoothed Standardized Density

1990 2000 2010

-1

-2

2

1

0

Bluefish

Year

BSS R4 Smoothed Standardized Density

1990 2000 

-1

-2

2

1

0

Hogchoker

Year

BSS R4 Smoothed Standardized Density

1990 2000 2010

-1

2

1

0

Spottail shiner

Year

BSS R4 Smoothed Standardized Density

1990 2000 2010

-1

2

1

0

Striped bass

Year

BSS R4 Smoothed Standardized Density

1990 2000 

-1

2

1

0

White perch

Year

BSS R4 Smoothed Standardized Density
A-51

Figure D1. River Segment 4 LRS YOY CPUE (May–July Sampling Events, 1985–20111

1990 2000 2010

-1

4

3

2

1

0

American shad

Extreme Value

LRS R4 Standardized CPUE

Year

1990 2000 2010

-1

4

3

2

1

0

Atlantic tomcod

Extreme Value

LRS R4 Standardized CPUE

Year

1990 2000 

-1

4

3

2

1

0

Bay anchovy

Extreme Value

Year

LRS R4 Standardized CPUE

1990 2000 2010

-1

3

2

1

0

Bluefish

Year

LRS R4 Standardized CPUE

1990 2000 2010

-1

5

4

3

2

1

0

Rainbow smelt

Extreme Value

LRS R4 Standardized CPUE

Year

1990 2000 

-1

3

2

1

0

Striped bass

Year

LRS R4 Standardized CPUE

1990 2000 2010

-1

5

4

3

2

1

0

Weakfish

Extreme Value

LRS R4 Standardized CPUE

Year
A-52

Figure E1. River Segment 4 FSS YOY CPUE (July–Oct Sampling Events, 1985–2011) 1

1990 2000 2010

-1

-2

5

4

3

2

1

0

Extreme Value

Alewife

Year

FSS R4 Standardized CPUE

1990 2000 2010

-1

-2

2

1

0

American shad

Year

FSS R4 Standardized CPUE

1990 2000 2010

-1

-2

3

2

1

0

Atlantic tomcod

Year

FSS R4 Standardized CPUE

1990 

-1

-2

3

2

1

0

FSS R4 Standardized CPUE

1990 2000 2010

-1

-2

5

4

3

2

1

0

Blueback herring

Extreme Value

Year

FSS R4 Standardized CPUE

1990 2000 2010

-1

-2

4

3

2

1

0

Bluefish

Year

FSS R4 Standardized CPUE

1990 2000 2010

-1

-2

4

3

2

1

0

Hogchoker

Extreme Value

Year

FSS R4 Standardized CPUE

1990 

-1

5

4

3

2

1

0

R

FSS R4 Standardized CPUE

1990 2000 2010

-1

-2

3

2

1

0

Striped bass

Year

FSS R4 Standardized CPUE

1990 2000 2010

-1

-2

4

3

2

1

0

Weakfish

Year

FSS R4 Standardized CPUE

1990 2000 2010

-1

4

3

2

1

0

White perch

Extreme Value

Year

FSS R4 Standardized CPUE
A-53

Figure F1. Riverwide LRS YOY CPUE (May–July Sampling Events, 1985–2011) 1

1990 2000 2010

-1

-2

4

3

2

1

0

Extreme Value

Year

Alewife

LRS Riverwide Standardized CPUE

1990 2000 2010

-1

-2

3

2

1

0

American shad

Year

LRS Riverwide Standardized CPUE

1990 2000 2010

-1

-2

3

2

1

0

Atlantic tomcod

Year

LRS Riverwide Standardized CPUE

1990 2000 2010

-1

-2

4

3

2

1

0

Bay anchovy

Extreme Value

Year

LRS Riverwide Standardized CPUE

-1

-2

4

3

2

1

0

LRS Riverwide Standardized CPUE

1990 2000 2010

-1

-2

4

3

2

1

0

Extreme Value

Bluefish

Year

LRS Riverwide Standardized CPUE

1990 2000 2010

-1

-2

3

2

1

0

Hogchoker

Year

LRS Riverwide Standardized CPUE

1990 2000 2010

-1

-2

4

3

2

1

0

Rainbow smelt

Extreme Value

Year

LRS Riverwide Standardized CPUE

1990 2000 2010

-1

-2

5

4

3

2

1

0

Spottail shiner

Extreme Value

Year

LRS Riverwide Standardized CPUE

-1

-2

5

4

3

2

1

0

LRS Riverwide Standardized CPUE

1990 2000 2010

-1

4

3

2

1

0

Weakfish

Extreme Value

Year

LRS Riverwide Standardized CPUE

1990 2000 2010

-1

5

4

3

2

1

0

White catfish

Extreme Value

Year

LRS Riverwide Standardized CPUE

1990 2000 2010

-1

3

2

1

0

White perch

Year

LRS Riverwide Standardized CPUE
A-54

FigureG1. Riverwide FSS YOY CPUE (July–Oct Sampling Events, 1985–2011)1

1990 2000 2010

-1

-243210

Extreme Value

Alewife

Year

FSS Riverwide Standardized CPUE

1990 2000 2010

-1

-23210

American shad

Year

FSS Riverwide Standardized CPUE

1990 2000 2010

-1

-243210

Extreme Value

Atlantic tomcod

Year

FSS Riverwide Standardized CPUE

1990 2000 

-1

-23210

Bay anchov

Year

FSS Riverwide Standardized CPUE

1990 2000 2010

-1

-243210

Extreme Value

Blueback herring

Year

FSS Riverwide Standardized CPUE

1990 2000 2010

-1

-243210

Extreme Value

Bluefish

Year

FSS Riverwide Standardized CPUE

1990 2000 2010

-1

-2543210

Extreme Value

Gizzard shad

Year

FSS Riverwide Standardized CPUE

1990 2000 

-1

-243210

Hogchoke

Extreme V

Year

FSS Riverwide Standardized CPUE

1990 2000 2010

-1

-2543210

Rainbow smelt

Extreme Value

Year

FSS Riverwide Standardized CPUE

1990 2000 2010

-1

-243210

Extreme Value

Spottail shiner

Year

FSS Riverwide Standardized CPUE

1990 2000 2010

-1

-243210

Striped bass

Extreme Value

Year

FSS Riverwide Standardized CPUE

1990 2000 

-1

-23210

Weakfish

Year

FSS Riverwide Standardized CPUE

1990 2000 2010

-1

-23210

White catfish

Year

FSS Riverwide Standardized CPUE

1990 2000 2010

-1

-23210

White perch

Year

FSS Riverwide Standardized CPUE
A-55

Figure H1. Riverwide BSS YOY CPUE (July–Oct Sampling Events, 1985–2011) 1

1990 2000 2010

-1

-2

4

3

2

1

0

Extreme Value

Alewife

Year

BSS Riverwide Standardized CPUE

1990 2000 2010

-1

-2

3

2

1

0

American shad

Year

BSS Riverwide Standardized CPUE

1990 2000 2010

-1

-2

4

3

2

1

0

Extreme Value

Atlantic tomcod

Year

BSS Riverwide Standardized CPUE

1990 2000 2010

-1

-2

5

4

3

2

1

0

Bay anchovy

Extreme Value

Year

BSS Riverwide Standardized CPUE

-1

-2

3

2

1

0

BSS Riverwide Standardized CPUE

1990 2000 2010

-1

-2

5

4

3

2

1

0

Extreme Value

Bluefish

Year

BSS Riverwide Standardized CPUE

1990 2000 2010

-1

-2

5

4

3

2

1

0

Gizzard shad

Extreme Value

Year

BSS Riverwide Standardized CPUE

1990 2000 2010

-1

-2

3

2

1

0

Hogchoker

Year

BSS Riverwide Standardized CPUE

1990 2000 2010

-1

-2

3

2

1

0

Spottail shiner

Year

BSS Riverwide Standardized CPUE

-1

-2

3

2

1

0

BSS Riverwide Standardized CPUE

1990 2000 2010

-1

-2

4

3

2

1

0

Extreme Value

Weakfish

Year

BSS Riverwide Standardized CPUE

1990 2000 2010

-1

-2

4

3

2

1

0

White catfish

Extreme Value

Year

BSS Riverwide Standardized CPUE

1990 2000 2010

-1

-2

4

3

2

1

0

White perch

Extreme Value

Year

BSS Riverwide Standardized CPUE
Appendix A

A-56

1 Figure I1. Riverwide LRS YOY Abundance Index (1974–2011)

2 Figure J1. Riverwide FSS YOY Abundance Index (1979–2011)

1970 1980 1990 2000 2010

-2

-1

0

1

2

3

4

Atlantic tomcod

Year

LRS Riverwide Abundance Index

1970 1980 1990 2000 2010

-2

-1

0

1

2

3

4

Extreme Value

Rainbow smelt

Year

LRS Riverwide Abundance Index

1980 1990 2000 2010

-2

-1

0

1

2

3

Bay anchovy

Year

FSS Riverwide Abundance Index

1970 1980 1990 2000 2010

-2

-1

0

1

2

3

4

Extreme Value

Hogchoker

Year

FSS Riverwide Abundance Index

1980 1990 2000 2010

-2

-1

0

1

2

3

4

Extreme Value

Weakfish

Year

FSS Riverwide Abundance Index
A-57

FigureK1. Riverwide BSS YOY Abundance Index (1974–2011)1

1970 1980 1990 2000 2010

-1

-23210

Alewife

Year

BSS Riverwide Abundance Index

1970 1980 1990 2000 2010

-1

-23210

American shad

Year

BSS Riverwide Abundance Index

1970 1980 1990 2000 

-1

-23210

Blueback herring

Year

BSS Riverwide Abundance Index

1970 1980 1990 2000 2010

-1

-26543210

Extreme Value

Bluefish

Year

BSS Riverwide Abundance Index

1970 1980 1990 2000 2010

-1

-23210

Spottail shiner

Year

BSS Riverwide Abundance Index

1970 1980 1990 2000 

-1

-23210

Striped bass

Year

BSS Riverwide Abundance Index

1970 1980 1990 2000 2010

-1

-2543210

White catfish

Extreme Value

Year

BSS Riverwide Abundance Index

1970 1980 1990 2000 2010

-1

-23210

White perch

Year

BSS Riverwide Abundance Index
Appendix A

A-58

1 River Segment 4 Tables

2 Table A. Linear Analysis of LRS Region 4 YOY Density

3 (May–July Sampling Events, 1985–2011, with 3 yr. Moving Average Smoothing)

Linear Regression LRS River Segment 4 Density

RIS MSE

Slope ± 1 Standard

Error of Slope P value Slope Decision

American Shad 0.241 -0.039 ± 0.014 0.009 S<0 4

Atlantic Tomcod 0.213 -0.013 ± 0.013 0.316 S=0 1

Bluefish 0.212 -0.068 ± 0.013 < 0.001 S<0 4

Rainbow Smelt* 0.300 -0.071 ± 0.015 < 0.001 S<0 4

Striped Bass 0.251 -0.027 ± 0.014 0.061 S=0 1

Weakfish* 0.300 -0.012 ± 0.015 0.445 S=0 1

4 * Nine and eight annual non-zero values for smelt and weakfish respectively.

5 Table B. Linear Analysis of FSS Region 4 YOY Density

6 (July–Oct Sampling Events, 1985–2011, with 3 yr. Moving Average Smoothing)

Linear Regression FSS River Segment 4 Density

RIS MSE

Slope ± 1 Standard

Error of Slope P value Slope Decision

Alewife 0.344 -0.048 ± 0.016 0.008 S<0 4

American Shad 0.146 -0.081 ± 0.011 < 0.001 S<0 4

Atlantic Tomcod 0.223 -0.038 ± 0.013 0.008 S<0 4

Bay Anchovy 0.314 -0.053 ± 0.016 0.002 S<0 4

Blueback Herring 0.139 -0.033 ± 0.010 0.004 S<0 4

Bluefish 0.275 -0.029 ± 0.015 0.059 S=0 1

Hogchoker 0.175 -0.068 ± 0.012 < 0.001 S<0 4

Rainbow Smelt* 0.297 -0.056 ± 0.015 0.001 S<0 4

Striped Bass 0.209 -0.034 ± 0.013 0.013 S<0 4

Weakfish 0.399 -0.034 ± 0.018 0.067 S=0 1

White Perch 0.328 -0.030 ± 0.016 0.075 S=0 1

7 * Eight annual non-zero values
Appendix A

A-59

1 Table C. Linear Analysis of BSS Region 4 YOY Density

2 (July–Oct Sampling Events, 1985–2011, with 3 yr. Moving Average Smoothing)

Linear Regression BSS River Segment 4 Density

RIS MSE

Slope ± 1 Standard

Error of Slope P value Slope Decision

Alewife 0.123 0.050 ± 0.010 < 0.001 S>0 1

American Shad 0.117 -0.073 ± 0.009 < 0.001 S<0 4

Bay Anchovy 0.317 0.031 ± 0.016 0.063 S=0 1

Blueback Herring 0.232 -0.046 ± 0.013 0.002 S<0 4

Bluefish 0.347 -0.019 ± 0.016 0.264 S=0 1

Hogchoker 0.350 0.021 ± 0.016 0.211 S=0 1

Spottail Shiner 0.349 -0.015 ± 0.016 0.377 S=0 1

Striped Bass 0.229 0.013 ± 0.013 0.339 S=0 1

White Perch 0.387 -0.010 ± 0.017 0.571 S=0 1

3 Table D. Linear Analysis of LRS Region 4 YOY CPUE

4 (May–July Sampling Events, 1985–2011)

Linear Regression LRS River Segment 4 CPUE

RIS MSE

Slope ± 1 Standard

Error of Slope P value Slope Decision

American Shad 0.931 -0.041 ± 0.024 0.100 S=0 4

American Shad with 1 value removed 0.411 -0.036 ± 0.016 0.032 S<0

Atlantic Tomcod 0.930 -0.041 ± 0.024 0.098 S=0 1

Atlantic Tomcod with 1 value removed 0.636 -0.017 ± 0.021 0.429 S=0

Bay Anchovy 1.036 -0.008 ± 0.025 0.743 S=0 1

Bay Anchovy with 1 value removed 0.529 -0.002 ± 0.018 0.932 S=0

Bluefish 0.733 -0.068 ± 0.021 0.003 S<0 4

Rainbow Smelt* 0.924 -0.042 ± 0.024 0.089 S=0 4

Rainbow Smelt* with 1 value removed 0.175 -0.026 ± 0.010 0.022 S<0

Striped Bass 1.040 0.002 ± 0.025 0.950 S=0 1

Weakfish 1.032 -0.011 ± 0.025 0.671 S=0 1

Weakfish with 1 value removed 0.146 0.010 ± 0.010 0.302 S=0

5 * Eight annual non-zero values
Appendix A

A-60

1 Table E. Linear Analysis of FSS Region 4 YOY CPUE

2 (July–Oct Sampling Events, 1985–2011)

Linear Regression FSS River Segment 4 CPUE

RIS MSE

Slope ± 1 Standard

Error of Slope P value Slope Decision

Alewife 1.022 -0.017 ± 0.025 0.509 S=0

1 Alewife with 1 value removed 0.346 -0.019 ± 0.015 0.196 S=0

American Shad 0.798 -0.061 ± 0.022 0.011 S<0 4

Atlantic Tomcod 0.762 -0.065 ± 0.022 0.006 S<0 4

Bay Anchovy 1.036 0.008 ± 0.025 0.765 S=0 1

Blueback Herring 0.876 -0.050 ± 0.023 0.041 S<0

4

Blueback Herring with 1 value removed 0.187 -0.014 ± 0.011 0.220 S=0

Bluefish 0.852 -0.054 ± 0.023 0.027 S<0 4

Hogchoker 0.810 -0.059 ± 0.022 0.013 S<0

4

Hogchoker with 1 value removed 0.467 -0.052 ± 0.017 0.006 S<0

Rainbow Smelt* 0.907 -0.045 ± 0.024 0.067 S=0

4 Rainbow Smelt* with 1 value removed 0.125 -0.028 ± 0.009 0.004 S<0

Striped Bass 0.803 -0.060 ± 0.022 0.012 S<0 4

Weakfish 1.008 -0.022 ± 0.025 0.380 S=0 1

White Perch 0.939 -0.039 ± 0.024 0.114 S=0

1

White Perch with 1 value removed 0.357 -0.014 ± 0.015 0.353 S=0

3 * Eight annual non-zero values 
Appendix A

A-61

1 Riverwide Tables

2 Table F. Linear Analysis of LRS Riverwide YOY CPUE

3 (May–July Sampling Events, 1985–2011)

Linear Regression LRS Riverwide CPUE

RIS MSE

Slope ± 1 Standard

Error of Slope P value Slope Decision

Alewife 0.995 0.026 ± 0.025 0.297 S=0

1 Alewife with 1 value removed 0.650 0.024 ± 0.020 0.233 S=0

American Shad 0.606 -0.081 ± 0.019 <0.001 S<0 4

Atlantic Tomcod 0.787 -0.062 ± 0.022 0.009 S<0 4

Bay Anchovy 1.024 -0.016 ± 0.025 0.529 S=0

1

Bay Anchovy with 1 value removed 0.409 -0.009 ± 0.016 0.595 S=0

Blueback Herring 0.987 -0.028 ± 0.025 0.257 S=0

1

Blueback Herring with 1 value removed 0.454 -0.012 ± 0.017 0.484 S=0

Bluefish 0.768 -0.064 ± 0.022 0.006 S<0

4 Bluefish with 1 value removed 0.306 -0.047 ± 0.014 0.003 S<0

Hogchoker 0.950 0.037 ± 0.024 0.137 S=0 1

Rainbow Smelt 0.790 -0.062 ± 0.022 0.009 S<0

4 Rainbow Smelt with 1 value removed 0.349 -0.040 ± 0.015 0.014 S<0

Spottail Shiner 0.989 0.028 ± 0.025 0.267 S=0

1 Spottail Shiner with 1 value removed 0.157 0.002 ± 0.010 0.875 S=0

Striped Bass 1.004 -0.024 ± 0.025 0.348 S=0

1 Striped Bass with 1 value removed 0.335 -0.003 ± 0.015 0.855 S=0

Weakfish 1.034 -0.009 ± 0.025 0.718 S=0

1 Weakfish with 1 value removed 0.445 0.008 ± 0.017 0.635 S=0

White Catfish 1.040 0.000 ± 0.025 0.998 S=0

1 White Catfish with 1 value removed 0.140 0.012 ± 0.009 0.210 S=0

White Perch 0.921 -0.043 ± 0.024 0.084 S=0 1
Appendix A

A-62

1 Table G. Linear Analysis of FSS Riverwide YOY CPUE

2 (July–Oct Sampling Events, 1985–2011)

Linear Regression FSS Riverwide CPUE

RIS MSE

Slope ± 1 Standard

Error of Slope P value Slope Decision

Alewife 1.014 0.020 ± 0.025 0.440 S=0

1 Alewife with 1 value removed 0.453 0.017 ± 0.017 0.313 S=0

American Shad 0.561 -0.086 ± 0.019 < 0.001 S<0 4

Atlantic Tomcod 0.666 -0.076 ± 0.020 0.001 S<0

4

Atlantic Tomcod with 1 value removed 0.434 -0.061 ± 0.017 0.001 S<0

Bay Anchovy 1.040 -0.002 ± 0.025 0.952 S=0 1

Blueback Herring 0.678 -0.074 ± 0.020 0.001 S<0

4

Blueback Herring with 1 value removed 0.431 -0.063 ± 0.016 0.001 S<0

Bluefish 0.706 -0.071 ± 0.021 0.002 S<0

4 Bluefish with 1 value removed 0.293 -0.073 ± 0.013 < 0.001 S<0

Gizzard Shad 1.040 -0.001 ± 0.025 0.960 S=0

1 Gizzard Shad with 1 value removed 0.165 -0.010 ± 0.010 0.327 S=0

Hogchoker 0.954 -0.036 ± 0.024 0.146 S=0

1

Hogchoker with 1 value removed 0.667 -0.018 ± 0.021 0.391 S=0

Rainbow Smelt 0.917 -0.043 ± 0.024 0.079 S=0

4 Rainbow Smelt with 1 value removed 0.066 -0.026 ± 0.006 0.001 S<0

Spottail Shiner 0.832 -0.056 ± 0.023 0.019 S<0

4 Spottail Shiner with 1 value removed 0.415 -0.042 ± 0.016 0.016 S<0

Striped Bass 0.857 -0.053 ± 0.023 0.030 S<0

4 Striped Bass with 1 value removed 0.599 -0.036 ± 0.020 0.083 S=0

Weakfish 0.950 -0.037 ± 0.024 0.137 S=0 1

White Catfish 0.859 -0.053 ± 0.023 0.031 S<0 4

White Perch 1.018 -0.019 ± 0.025 0.461 S=0 1
Appendix A

A-63

1 Table H. Linear Analysis of BSS Riverwide YOY CPUE

2 (July–Oct Sampling Events, 1985–2011)

Linear Regression BSS Riverwide CPUE

RIS MSE

Slope ± 1 Standard

Error of Slope P value Slope Decision

Alewife 0.737 0.068 ± 0.021 0.004 S>0

1 Alewife with 1 value removed 0.403 0.045 ± 0.016 0.012 S>0

American Shad 0.613 -0.081 ± 0.019 <0.001 S<0 4

Atlantic Tomcod 0.634 -0.079 ± 0.020 0.001 S<0

4

Atlantic Tomcod with 1 value removed 0.307 -0.068 ± 0.014 < 0.0001 S<0

Bay Anchovy 0.794 0.061 ± 0.022 0.010 S>0

1

Bay Anchovy with 1 value removed 0.347 0.035 ± 0.015 0.033 S>0

Blueback Herring 1.040 -0.001 ± 0.025 0.962 S=0 1

Bluefish 1.040 0.003 ± 0.025 0.916 S=0

1 Bluefish with 1 value removed 0.184 0.000 ± 0.011 0.985 S=0

Gizzard Shad 0.814 0.059 ± 0.022 0.014 S>0

1 Gizzard Shad with 1 value removed 0.277 0.027 ± 0.014 0.061 S=0

Hogchoker 1.018 0.018 ± 0.025 0.476 S=0 1

Spottail Shiner 0.737 0.068 ± 0.021 0.004 S>0 1

Striped Bass 1.006 0.023 ± 0.025 0.362 S=0 1

Weakfish 0.923 -0.042 ± 0.024 0.087 S=0

1 Weakfish with 1 value removed 0.572 -0.016 ± 0.020 0.423 S=0

White Catfish 1.034 -0.009 ± 0.025 0.710 S=0

1 White Catfish with 2 values removed 0.063 0.008 ± 0.007 0.257 S=0

White Perch 1.038 -0.003 ± 0.025 0.902 S=0

1

White Perch with 1 value removed 0.590 -0.014 ± 0.019 0.473 S=0

3 Table I. Linear Analysis of LRS Abundance Index

4 Standardized Data (1974–2011)

Linear Regression LRS Riverwide Abundance Index

RIS MSE

Slope ± 1 Standard

Error of Slope P value Slope Decision

Atlantic Tomcod 0.886 -0.033 ± 0.014 0.022 S<0 4

Rainbow Smelt 0.864 -0.036 ± 0.014 0.013 S<0

4 Rainbow Smelt with 1 value removed 0.569 -0.025 ± 0.011 0.037 S<0
Appendix A

A-64

1 Table J. Linear Analysis of FSS Abundance Index

2 Standardized Data (1979–2011; Hogchoker 1974–2011)

Linear Regression FSS Riverwide Abundance Index

RIS MSE

Slope ± 1 Standard

Error of Slope P value Slope Decision

Bay Anchovy 0.839 -0.045 ± 0.017 0.012 S<0 4

Hogchoker 1.000 -0.015 ± 0.015 0.328 S = 0

1

Hogchoker with 1 value removed 0.646 -0.016 ± 0.012 0.190 S = 0

Weakfish 0.732 -0.056 ± 0.016 0.001 S<0

4 Weakfish with 1 value removed 0.495 -0.045 ± 0.013 0.002 S<0

3 Table K. Linear Analysis of BSS Abundance Index

4 Standardized Data (1974–2011)

Linear Regression BSS Riverwide Abundance Index

RIS MSE

Slope ± 1 Standard

Error of Slope P value Slope Decision

Alewife 0.995 0.016 ± 0.015 0.287 S = 0 1

American Shad 0.631 -0.056 ± 0.012 < 0.001 S<0 4

Blueback Herring 0.885 -0.034 ± 0.014 0.021 S<0 4

Bluefish 1.028 0.000 ± 0.015 0.988 S = 0

1 Bluefish with 1 value removed 0.173 -0.008 ± 0.006 0.213 S = 0

Spottail Shiner 0.946 0.025 ± 0.014 0.086 S = 0 1

Striped Bass 1.022 0.007 ± 0.015 0.634 S = 0 1

White Catfish 0.668 -0.053 ± 0.012 < 0.001 S<0

4 White Catfish with 1 value removed 0.317 -0.050 ± 0.008 < 0.001 S<0

White Perch 0.859 -0.036 ± 0.014 0.012 S<0 4
Appendix A

A-65

1 Addendum A–2: Summary of Population Trends by RIS

2 This addendum presents supporting plots for the trend analysis presented in Appendix A and 

3 summarized in Chapter 4 of this supplement. Each plot provides a visual summary of the 

4 results of each measure of abundance for a given RIS. The bar for each measure of 

5 abundance indicates the estimated linear slope and the thick circle is the associated p-value for 

6 the test of the null hypothesis H0: the linear slope S = 0. RIS are presented in alphabetical 

7 order.

8 Figure A2. Alewife Estimated Slope (Blue Bars with Error Bars) and the P-Values for the 

9 Test of Zero Slope (Red Thick Circles) for Each Measure of Abundance

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

-0.10

-0.08

-0.06

-0.04

-0.02

0.00

0.02

0.04

0.06

0.08

0.10

LRS DensityFSS Density

BSS Density

LRS CPUEFSS CPUELRS CPUEFSS CPUE

BSS CPUE

BSS Abundance Index

River Segment 4 Riverwide

Level of Significance for H0: Slope = 0

Slope 

± 2* Standard Error of Slope

Slope p-value
Appendix A

A-66

1 Figure B2. American Shad Estimated Slope (Blue Bars with Error Bars) and the P-Values 

2 for the Test of Zero Slope (Red Thick Circles) for Each Measure of Abundance

3 Figure C2. Atlantic Tomcod Estimated Slope (Blue Bars with Error Bars) and the P-Values 

4 for the Test of Zero Slope (Red Thick Circles) for Each Measure of Abundance

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

-0.14

-0.12

-0.10

-0.08

-0.06

-0.04

-0.02

0.00

LRS DensityFSS Density

BSS Density

LRS CPUE

FSS CPUELRS CPUEFSS CPUE

BSS CPUE

BSS Abundance Index

River Segment 4 Riverwide

Level of Significance for H0: Slope = 0

Slope 

± 2* Standard Error of Slope

Slope p-value

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

-0.12

-0.10

-0.08

-0.06

-0.04

-0.02

0.00

0.02

LRS DensityFSS Density

BSS Density

LRS CPUEFSS CPUELRS CPUEFSS CPUE

BSS CPUE

LRS Abundance Index

River Segment 4 Riverwide

Level of Significance for H0: Slope = 0

Slope 

± 2* Standard Error of Slope

Slope p-value
Appendix A

A-67

1 Figure D2. Bay Anchovy Estimated Slope (Blue Bars with Error Bars) and the P-Values 

2 for the Test of Zero Slope (Red Thick Circles) for Each Measure of Abundance

3 Figure E2. Blueback Herring Estimated Slope (Blue Bars with Error Bars) and the 

4 P-Values for the Test of Zero Slope (Red Thick Circles) for Each Measure of Abundance

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

-0.10

-0.08

-0.06

-0.04

-0.02

0.00

0.02

0.04

0.06

0.08

LRS Density

FSS Density

BSS Density

LRS CPUEFSS CPUELRS CPUEFSS CPUE

BSS CPUE

FSS Abundance Index

River Segment 4 Riverwide

Level of Significance for H0: Slope = 0

Slope 

± 2* Standard Error of Slope

Slope p-value

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

-0.12

-0.10

-0.08

-0.06

-0.04

-0.02

0.00

0.02

0.04

0.06

LRS DensityFSS Density

BSS Density

LRS CPUEFSS CPUELRS CPUEFSS CPUE

BSS CPUE

BSS Abundance Index

River Segment 4 Riverwide

Level of Significance for H0: Slope = 0

Slope 

± 2* Standard Error of Slope

Slope p-value
Appendix A

A-68

1 Figure F2. Bluefish Estimated Slope (Blue Bars with Error Bars) and the P-Values for the 

2 Test of Zero Slope (Red Thick Circles) for Each Measure of Abundance

3 Figure G2. Gizzard Shad Estimated Slope (Blue Bars with Error Bars) and the P-Values 

4 for the Test of Zero Slope (Red Thick Circles) for Each Measure of Abundance

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

-0.12

-0.10

-0.08

-0.06

-0.04

-0.02

0.00

0.02

0.04

LRS DensityFSS Density

BSS Density

LRS CPUE

FSS CPUELRS CPUEFSS CPUE

BSS CPUE

BSS Abundance Index

River Segment 4 Riverwide

Level of Significance for H0: Slope = 0

Slope 

± 2* Standard Error of Slope

Slope p-value

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

-0.04

-0.03

-0.02

-0.01

0.00

0.01

0.02

0.03

0.04

0.05

0.06

LRS DensityFSS Density

BSS Density

LRS CPUEFSS CPUELRS CPUEFSS CPUE

BSS CPUE

Abundance Index

River Segment 4 Riverwide

Level of Significance for H0: Slope = 0

Slope 

± 2* Standard Error of Slope

Slope p-value
Appendix A

A-69

1 Figure H2. Hogchoker Estimated Slope (Blue Bars with Error Bars) and the P-Values for 

2 the Test of Zero Slope (Red Thick Circles) for Each Measure of Abundance

3 Figure I2. Rainbow Smelt Estimated Slope (Blue Bars with Error Bars) and the P-Values 

4 for the Test of Zero Slope (Red Thick Circles) for Each Measure of Abundance

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

-0.12

-0.10

-0.08

-0.06

-0.04

-0.02

0.00

0.02

0.04

0.06

0.08

0.10

LRS DensityFSS Density

BSS Density

LRS CPUEFSS CPUELRS CPUEFSS CPUE

BSS CPUE

FSS Abundance Index

River Segment 4 Riverwide

Level of Significance for H0: Slope = 0

Slope 

± 2* Standard Error of Slope

Slope p-value

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

-0.12

-0.10

-0.08

-0.06

-0.04

-0.02

0.00

LRS DensityFSS Density

BSS Density

LRS CPUEFSS CPUELRS CPUEFSS CPUE

BSS CPUE

LRS Abundance Index

River Segment 4 Riverwide

Level of Significance for H0: Slope = 0

Slope 

± 2* Standard Error of Slope

Slope p-value
Appendix A

A-70

1 Figure J2. Spottail Shiner Estimated Slope (Blue Bars with Error Bars) and the P-Values 

2 for the Test of Zero Slope (Red Thick Circles) for Each Measure of Abundance

3 Figure K2. Striped Bass Estimated Slope (Blue Bars with Error Bars) and the P-Values for 

4 the Test of Zero Slope (Red Thick Circles) for Each Measure of Abundance

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

-0.10

-0.05

0.00

0.05

0.10

0.15

LRS DensityFSS Density

BSS Density

LRS CPUEFSS CPUE

LRS CPUEFSS CPUE

BSS CPUE

BSS Abundance Index

River Segment 4 Riverwide

Level of Significance for H0: Slope = 0

Slope 

± 2* Standard Error of Slope

Slope p-value

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

-0.12

-0.10

-0.08

-0.06

-0.04

-0.02

0.00

0.02

0.04

0.06

0.08

0.10

LRS DensityFSS Density

BSS Density

LRS CPUEFSS CPUELRS CPUEFSS CPUE

BSS CPUE

BSS Abundance Index

River Segment 4 Riverwide

Level of Significance for H0: Slope = 0

Slope 

± 2* Standard Error of Slope

Slope p-value
Appendix A

A-71

1 Figure L2. Weakfish Estimated Slope (Blue Bars with Error Bars) and the P-Values for the 

2 Test of Zero Slope (Red Thick Circles) for Each Measure of Abundance

3 Figure M2. White Catfish Estimated Slope (Blue Bars with Error Bars) and the P-Values 

4 for the Test of Zero Slope (Red Thick Circles) for Each Measure of Abundance

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

-0.10

-0.08

-0.06

-0.04

-0.02

0.00

0.02

0.04

0.06

LRS Density

FSS Density

BSS Density

LRS CPUEFSS CPUELRS CPUEFSS CPUE

BSS CPUE

FSS Abundance Index

River Segment 4 Riverwide

Level of Significance for H0: Slope = 0

Slope 

± 2* Standard Error of Slope

Slope p-value

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

-0.12

-0.10

-0.08

-0.06

-0.04

-0.02

0.00

0.02

0.04

LRS DensityFSS Density

BSS Density

LRS CPUEFSS CPUELRS CPUEFSS CPUE

BSS CPUE

BSS Abundance Index

River Segment 4 Riverwide

Level of Significance for H0: Slope = 0

Slope 

± 2* Standard Error of Slope

Slope p-value
Appendix A

A-72

1 Figure N2. White Perch Estimated Slope (Blue Bars with Error Bars) and the P-Values for 

2 the Test of Zero Slope (Red Thick Circles) for Each Measure of Abundance

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

-0.10

-0.08

-0.06

-0.04

-0.02

0.00

0.02

0.04

LRS DensityFSS Density

BSS Density

LRS CPUEFSS CPUE

LRS CPUEFSS CPUE

BSS CPUE

BSS Abundance Index

River Segment 4 Riverwide

Level of Significance for H0: Slope = 0

Slope 

± 2* Standard Error of Slope

Slope p-value




NUREG-1437

Volume 

Supplement 38

5

Generic Environmental Impact Statement for License Renewal of Nuclear Plants 

Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3